HomeMy WebLinkAbout01-1228 STIPULATION AND AGREEMENT
FOR CUSTODY AND PARTIAL CUSTODY
COMES NOW, MARK A. BILLOW AND MELISSA D. BILLOW, by and through their attorney,
James J. Kayer, Esquire, and NICOLE GREENE, having been advised of her right to consult with counsel
and choosing to represent herself pro se, do stipulate and agree upon the following:
1. NICOLE GREENE, residing at 307 B North Bedford Street, Cumberland County, Carlisle, PA
17013 is the natural mother of one minor child, MALIA RAE GREENE, bom December 7, 2000. The
natural father has not been identified and is not named on the child's birth certificate.
2. Primary physical custody of the minor child, MALIA RAE GREENE, shall be placed in MARK
A. BILLOW and MELISSA D. BILLOW residing at 25 Rays Drive, Newville, Cumberland County, PA.
3. Primary legal custody of the minor child, MALIA RAE GREENE, shall be placed in MARK A.
BILLOW and MELISSA D, BILLOW. Legal custody shall be understood as authorizing the custodians to
make any and all decisions regarding the child's welfare including the authorization of medical treatment,
and consultation with physicians and other healthcare providers, registering the child in school and having
complete access to all of the child's school records and interacting with all appropriate school officials
including teachers, administrators and counselors, as well as supervising and guiding the child's spiritual
upbringing to include regular attendance and participation in the parties' place of worship as they may
choose.
4. The mother, NICOLE GREENE, shall have certain rights of partial physical custody of the
minor child. Mother shall have access to the child at those dates and times as may be mutually agreed upon
by the parties.
5. MARK A. BILLOW and MELISSA D. BILLOW shall not unreasonably withhold rights of
visitation or temporary physical custody.
6. The mother, NICOLE GREENE enters into this agreement knowingly and of her own free will
and agrees that she has not been compelled or forced in any way to agree to the terms set forth in this
Agreement and Stipulation for Custody,
7. Mother shall be responsible for transportation arrangements to and from partial physical custody
unless otherwise mutually agreed upon between the parties.
8. The parties agree and anticipate that this Agreement for Custody and Visitation may be entered
as an Order of Court in the Court of Common Pleas of Cumberland County, Pennsylvania.
9. The parties to this agreement agree and stipulate that this agreement serves to establish an in loco
parentis relationship between MARK A. BILLOW and MELISSA D. BILLOW and the child.
10. The parties do hereby stipulate and agree that they waive their respective rights to be present in
court at the time an order is made pursuant to this Agreement for Custody and Visitation.
IN WITNESS WHEREOF, the parties thereto and each of them have thereunto set their hands and
seals intending to be legally bound thereby this Ist day of March, 2001.
tnes J. Kayer, Esquire
a'Pff-..~. ~.~t ·
MARK A. BILLOW
MELISSA D. BILLOW
NICOLE GREENE
MARK A. BILLOW and MELISSA
BILLOW,
Plaimiff
VS.
NICOLE GREENE,
Defendant
: 1N THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
: NO. 2001 - /,2.Z~c-3
: IN CUSTODY
ORDER OF COURT
AND NOW, this {~ ,hx day of ~ ,2001 it is decreed that the Stipulation and
Agreement for Custody and Partial Custody that has been executed by the parties named above shall be made
an Order of this Court. The Court of Common Pleas of Cumberland County shall maintain jurisdiction in
this matter.
CC;
James J. Kayer, Esquire
Attorney for Plaintiffs
Nicole Greene, Pro Se