HomeMy WebLinkAbout10-41056
APRIL KRAMER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
16-
V
NO
r
.
.
• ?
- DIVORCE AND CUSTODY F
CIVIL rv
C?
T7
JOEL KRAMER, Y'
Defendant ll
--+ i
r co c-,
l
- Tft
t
.
C
J "
Y
NOTICE TO DEFEND Fo-
(
^?'
c,
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the case
may proceed without you and a decree of divorce or annulment may be entered against you by
the court. A judgment may also be entered against you for any other claim or relief requested in
these papers by the plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
When the ground for divorce is indignities or irretrievable breakdown of the marriage,
Y 5 Offim Of
M. err
020 Ritter Road
suite 108
MecheNCSbuug, PA 17055
PHom: 717.766.4008
FAX: 717.766.4066
you may request marriage counseling. A list of marriage counselors is available in the Office of
the Prothonotary at the first floor in the Cumberland County Courthouse, 1 Courthouse Square,
Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR
EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT
TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
It 35--l'06
It CC-shady tar.
yG7. Sa Pd- y
r-A ` 76 5-
44- 0-f31sz
APRIL KRAMER,
Plaintiff
V.
JOEL KRAMER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. /0- q Q S
CIVIL - DIVORCE AND CUSTODY
COMPLAINT IN DIVORCE WITH CUSTODY COUNT
AND NOW, comes the Plaintiff, April Kramer, by her attorney, John M. Kerr, Esquire,
pursuant to Section 3301(c) and 3301 (d) of the Pennsylvania Divorce Code, and seeks to obtain
a Decree in Divorce from the Defendant, Joel Kramer, upon the grounds set forth:
COUNT I - NO-FAULT DIVORCE UNDER 3301(c) or 3301(d)
1. The Plaintiff, April Kramer, is an adult individual residing at 1709 English Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. The Defendant, Joel Kramer, is an adult individual presently residing at 48 Thornwood
Road, Harrisburg, Dauphin County, Pennsylvania 17112.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on March 31, 2000 in Mechanicsburg,
?otln M. err
5020 RftW Road
Sul[e 109
Med-rdMbtu$. PA 17055
P11om: 717.788.9008
FAx: 717.788.9088
Pennsylvania.
5. Defendant separated from Plaintiff on April 24, 2010.
6. There have been no prior actions of divorce or annulment between the parties in this or
any other jurisdiction.
7. The Plaintiff and Defendant are both citizens of the United States of America.
8. The Defendant is not a member of the United States Armed Forces.
9. The cause of action and section of Divorce Code under which Plaintiff is proceeding is
the marriage is irretrievably broken under 23 Pa. Const. Stat. §3301(c) or 3301(d).
10. Plaintiff requests this Honorable Court to enter a decree of divorce pursuant to Section
3301(c) or 3301 (d) of the Divorce Code.
COUNT II - CUSTODY
11. Paragraphs 1-10 of this Complaint are incorporated by reference, as if fully set forth in
their entirety.
12. Plaintiff April Kramer (hereinafter, "Mother") resides at 1709 English Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
13. Defendant Joel Kramer (hereinafter, "Father"), resides at the present time at 48
Thornwood Road, Harrisburg, Dauphin County, Pennsylvania 17112.
14. Mother seeks to confirm primary physical custody and joint legal custody of the
90:7m";!err
5020 Rester Road
suite 108
Mechanicsburg. PA 17055
Prow 717.766.4008
FAx: 717.766.4088
following children:
Name Present Residence
Austin Kramer 1709 English Drive
Mechanicsburg, PA 17055
Alexis Kramer 1709 English Drive
Mechanicsburg, PA 17055
The children were not born out of wedlock.
D.O.B.
September 26, 2001
November 22, 2003
15. The children are presently in the custody of Mother who is resides at 1709 English Drive,
Mechanicsburg, Pennsylvania 17055.
16. Since the time of their birth, the children have resided with the following persons and at
the following addresses:
Names Residences
Dates
April Kramer 1709 English Drive
Joel Kramer 9/26/01-4/24/10
Mechanicsburg, PA 17055
April Kramer 1709 English Drive
4/24/10-present
17. The Mother of the children is April Kramer, who resides at 1709 English Drive,
Mechanicsburg, PA 17055.
She is married.
18. The Father of the children is Joel Kramer, who resides at the present time at 48
Thornwood Road, Harrisburg, PA 17112.
He is married.
19. The relationship of the Mother to the children is that of mother-children. The children
are currently living with the mother.
20. The relationship of the Father to the children is that of father-children.
POZI. err
Soto Ritter RMd
Sutte 108
McCiW4C3buM, PA 17055
P40m: 717.766.4008
FAX: 717.766.4066
21. Each parent whose parental rights to the children have not been terminated, and the
person who has physical custody of the children, have been named as parties to this action.
22. The best interests and permanent welfare of the children will be furthered by granting
primary physical custody and joint legal custody to Mother because: a) Mother has resided with
her children from their birth and been the primary caregiver; b) Father abandoned the marital
residence on April 24, 2010 and has had limited contact with the children since, failing to appear
on May 28, 2010 for a custody exchange; and c) the childrens' best interests and social,
emotional and physical well-being will be furthered by granting the requested relief.
WHEREFORE, the Plaintiff/Mother requests that the Court:
a) enter a decree of divorce under either §§ 3301 (c) or 3301(d) of the Divorce Code;
and
b) grant primary physical custody and joint legal custody to her.
Respectfully submitted,
Jo n M. Kerr, Esquire
I.D. #26414
Law Office of John M. Kerr, Esquire
5020 Ritter Road
Suite 109
Mechanicsburg, PA 17055
(717) 766-4008
ke?comcast net
Dated: June 18, 2010
otul M. err
5020 FUtter pond
Suite log
MedOnt-AXIrg, PA 17055
Pli0m: 717.766.4008
FAx: 717.766.4066
VERIFICATION
The undersigned, April Kramer, hereby states that she is the Plaintiff in the foregoing Divorce
and Custody action and, as such, is authorized to execute this Verification and that any factual
statements contained in the preceding Complaint in Divorce with Custody Count are true and correct to
the best of her knowledge, information and belief. She understands that any false statements are
subject to the penalties prescribed at 18 Pa.C.S.§4904, relating to unsworn falsification to authorities.
April Kramer
I'll ELI
APRIL KRAMER, Fi ,-,,! RN THE COURT OF COMMON PLEAS
Plaintiff 2010 JUd 18 : CUMBERLAND COUNTY, PENNSYLVANIA
Ahl 12; 3
CUMLZ;
V. pr,
- ufV i / ?{ U
r
JOEL KRAMER, CIVIL ACTION - CHILD CUSTODY
Defendant
COMPLAINT IN CUSTODY
orf
5020 Rttler )load
SUM 108
Medwzdcs". PA 17055
PHONE: 717.788.4008
1. 717.788.4088
1. Plaintiff is April Kramer. an adult individual residing at 1709 English Drive,
Mechanicsburg, Pennsylvania 17055 (hereinafter, "Mother")
2. Defendant is Joel Kramer, an adult individual who is residing temporarily at
48 Thornwood Road, Harrisburg, Pennsylvania 17112. (hereinafter, "Father")
3. The parties are the natural parents of the following minor children: Austin
Kramer, born September 26, 2001 and Alexis Kramer, born November 22, 2003
(hereinafter, "the children")..
4. The children were not born out of wedlock.
5. The children are presently in the custody of Plaintiff, who resides at 1709
English Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055.
6. Since the time of their birth, the children have resided with the following
persons and at the following addresses:
Names Addresses Dates
April Kramer 1709 English Drive 4/24/10 - present
Mechanicsburg, PA 17055
April Kramer 1709 English Drive 9/26/01 - 4/24/10
Joel Kramer Camp Hill, PA 17011
7. The mother of the children is Plaintiff, April Kramer, who resides at 1709
English Drive, Mechanicsburg, Pennsylvania 17055. She is married.
8. The father of the children is Defendant, Joel Kramer, who resides at the
present time at 48 Thornwood Road, Harrisburg, Pennsylvania 17112. He is married.
9. The relationship of the Plaintiff to the children is that of Mother. The Plaintiff
currently resides with the following persons:
Name Relationship
No one other than himself and the children
10. The relationship of the Defendant to the children is that of Father. The
Defendant currently resides with the following persons:
Name
Relationship
Name Not Known Paramour
10; M. CCU
5020 RMler Road
SUMO 109
Mechanicshug. PA 17055
Flio : 717.766.4008
FAx: 717.766.4066
11. Plaintiff has not participated as a party or witness, or in another capacity, in
other litigation concerning the custody of the children in this or another court.
12. Plaintiff has no information of a custody proceeding concerning the children
pending in a court of this Commonwealth or any other state.
13. Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the children or claims to have custody or visitation rights with respect
to the children.
14. Each parent whose parental rights to the children have not been terminated
and the person who has physical custody of the children have been named as parties to
this action.
15. The best interest and permanent welfare of the children will be served by
granting the relief requested because:
a) Mother has resided with her children since the date of their birth and has
functioned as primary caregiver;
b) Plaintiff Father abandoned the marital residence on April 24, 2010 and has had
limited contact with the children since, having failed to appear for a custody
exchange on May 28, 2010;
c) The emotional, physical and/or spiritual development of the children will be
enhanced by granting primary physical custody and joint legal custody of the
children to Plaintiff Mother.
WHEREFORE, Plaintiff requests that the Court grant to her primary physical custody and
joint legal custody of the children, Austin Kramer and Alexis Kramer.
Respectfully submitted,
- U., )#)??
John 4. Kerr, Esquire
Attorney I. D. # 26414
Law Office of John M. Kerr, Esquire
5020 Ritter Road, Suite 109
Mechanicsburg, Pennsylvania 17055
(717) 766-4008
Attorney for Plaintiff, April Kramer
Dated: June 18, 2010
law 0®ae M
ohn Meff
5o2o Futter Road
suite 109
MedieNGSbUr$. PA 17055
Flk ?: 717.766.4008
FAx: 717.766.4066
APRIL KRAMER 1N THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
v.
• 2010-4105 CLVIL ACTION LAW
,IOEL KRAMER
[)F:FF.N RANT
IN CUSTODY
O1tllF..R OF COU12T
AN[) NOS Wednesday,_June_30, 2010 _____, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator,
at 4th Floor ,Cumberland County Courthouse, Carlisle on Friday, July 30, 2010 at 9:30 AM
for aPre-F-[earing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
4pccial Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ Hubert X. Gilro Es .
Custody Conciliator
l~he Court of Common Pleas of Cumberland County is required by law to comply with the Americans
~~ ith Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
a~ ailahle tip disabled individuals having business before the court, please contact our off-ice. All arrangements
must. he made at least 72 hours prior to any hearing ar business before the cow-t. You must attend the sche duled
conference or hearing.
YOU SHOUL.U TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF Y OU DO NOT
HAV1=. AN ,A~1'~fORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE S~,T' _
FOR~LI-l BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. (7 =' n
//~~e/" ~/~ /y~/~~ Cumberland County Bar Association
W 1~~N.~~~
~ ~ °; ~--
E~I~7- ~ -~
"'~C"
.
-~'~~ W~
32 South Bedford Street ~ z`' ca ~~'~
1 j, ~.~~ Carlisle, Pennsylvania 17013 r-~.'. (_ A•.~?
Telephone (717) 249-3166 ~ ~-; ~ ~~' ~`
I~sZ-~-. c'' -~
~ • 30 ~ t o Co~ c,` _ placed •~n fl~ G-~ 1 ro c~`s =~ 1~-
Jul 2 $ 200
APRIL KRAMER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION -LAW
JOEL KRAMER, NO. 2010-4105
Defendant IN CUSTODY
ORDER
AND NOW, this 27`~ day of July, 2010, the Conciliator being advised the parties have
reached an agreement, the Conciliator relinquishes jurisdiction.
Hubert X. Gilroy, Esquire
Custody Conciliator
c~
-~
-,. ;- _ .,
- ~ `~
w -- _
.. ~ -~
o ;W
APRIL KRAMER,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2010-4105
CIVIL-DIVORCE
JOEL KRAMER, {-a
'~
Defendant ~ _
~' ~~
~
~ ~ J ""~? ;-~
~V.7
;
~~ ~
DEFENDANT'S AFFIDAVIT OF CONSENT ~ `~ ~~ =_
UNDER SECTION 3301(c) OF THE DIVORCE CODE ~' ~ -~
-~-= ~ -~-`
°
»~ ~ ~ a
~ c
~~
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed~n J~4~ie 1
~. _.~;
2010.
2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
4. I verify that the statements made in this affidavit are true and correct. i understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to
unsworn falsification to authorities.
Dated: 9"2°' 2o/o Signature:
APRIL KRAMER,
Plaintiff
v.
JOEL KRAMER,
Defendant .
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2010-4105
CIVIL -DIVORCE
r.~ ~'
,.
~ ~~ t
.,v =~~ ~ ~
~,~,
-wi'rl C7 .._.
r-,_$
. r ~_
\
~
//--. ~.~~~ i
-
~
~, L~J
... .
_A~
1
..
~....~,'~ ~ WV
~.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE
1. I consent to entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S.§4904, relating to
unsworn falsification to authorities.
Date: !~~•n ~ ~~ y ~~~
Joel Kramer, Defendant
APRIL KRAMER, IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2010-4105
CIVIL -DIVORCE '~
JOEL KRAMER, -~ ~+ ~t
Defendant ~~ ~ ```~~
CJ') ~ t :?J c~°.~
ti~T
~ a
~~ _
~
{,
PLAINTIFF'S AFFIDAVIT OF CONSENT ~''~
UNDER SECTION 3301(c) OF THE DIVORCE CODE ~? ~
~.
d~ c~ :s7
~.c~
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on~une 18, "~~
2010.
2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
4. I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to
unsworn falsification to authorities.
Dated: ~' 2 ~ - ~d Signature: ~ ~(~[~ 0
APRIL KRAMER,
Plaintiff
v.
JOEL KRAMER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2010-4105
CIVIL -DIVORCE
~ ~
°~ ~ ~, °-~
r`t~t
c ~ s' ~.~
~ °:f:
-=~ ~
CJ7 ~ ----s
p ~
..
:~ ~--t
_
;
....
-
~~ N ~~
~
=-=i t~
WAIVER OF NOTICE OF INTENTION TO RE4UEST ENTRY OF
A DIVORCE DECREE UNDER §3301(cl OF THE DIVORCE CODE
1. I consent to entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S.§4904, relating to
unsworn falsification to authorities.
Date: ~- 20" ~ ~ tb~( ~~Q~~~
April Kramer. Plaintiff
APRIL KRAMER IN THE COURT OF COMMON PLEAS OF ,
:CUMBERLAND COUNTY, PENNSYLVANIA
v.
JOEL KRAMER
: NO. 10-4105
DIVORCE DECREE
~,,'~' /,'4r1~,0./Y~ .
AND NOW, ~ ~~, 4~1~d , it is ordered and decreed that
APRIL KRAMER plaintiff, and
JOEL KRAMER ,defendant, are divorced from the
bonds of matrimony.
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente lite if any economic claims remain pending.
The court retains jurisdiction of any claims raised by the parties to this action
for which a final order has not yet been entered. Those claims are as follows: (If no
claims remain indicate "None.")
NONE
By the C ,
Attest: J.
Pr thonotary
io - as - rv ~-~ ~~
~~~ ~ ~~~ t
/O-ao -~o `yla~~
APRIL KRAMER, IN THE COURT OF ~B~IIMON PLEAS
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2010-4105
v. CIVIL ACTION
. ~ ~ ~
'°C7 ~
JOEL KRAMER, CUSTODY ~_ b
° ~
~_
Defendant ~'i-'' "'"'
tv °'~i~
~,;a
-~ ~ ~v `=-
~~
~ ~
~~~ ~ ~~
~ _
~ C'"7
STIPULATION ~.~ ~ ~~
~'` ~ ~
-1
AND NOW, come the above-named parties, April Kramer and Joel Kramer, and
STIPULATE AND AGREE that the Court shall enter the attached Order to resolve the custody
matters now pending between them. They represent that either their attorney has reviewed the
proposed Order with them, or that they had an opportunity to obtain a lawyer to do so.
IN WITNESS WHEREOF, the parties have set their hands and seals on the dates below
written.
pril Kramer
Joel Kramer
4- 2Q-la
(Date)
9-2rr .1s ~ a
(Date)
4.
NOV 01 lU1U
APRIL KRAMER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION -LAW
N0.10-4105
~ ro p
C a 'rf
JOEL KRAMER, IN CUSTODY -ts=~ a --r
Defendant r~~ `~= ~~
~~~ ~ rn~
~ r-- ~ c~ ~
~~
~. ~~
~ "rt
ORDER OF COURT
~~ =`y ~~
_
--~ ~ O
s~ ~` -°; -- ~'
NOW, this ~ day of ,, iv d~ • , 2010, upon consideration of the executed ``
Stipulation of the parties, IT IS ORDERED, as follows:
1. Leal Custody. The Mother, April Kramer, and the Father, Joel Kramer, shall share legal
custody of Austin Kramer, born September 26, 2001 and Alexis Kramer, born November 22,
2003. The parties shall have equal right to make all non-emergency decisions affecting the
childrens' general well-being including, but not limited to, all decisions regarding the childrens'
health, education and religion. Pursuant to the terms of 23 Pa. C.S.§5309, each parent shall be
entitled to all records and information pertaining to the children including, but not limited to,
medical, dental, religious or school records, the residence address of the children and of the
other parent. In the event of a medical emergency, the custodial party shall notify the other
party as soon as possible after the emergency has abated. Notice shall be furnished within
twenty-four (24) hours to the non-custodial parent regarding any non-emergent injury or illness
necessitating medical treatment or intervention. The parties shall strive to discuss and reach
agreement regarding all significant parenting decisions.
2. Physical Custodv. Mother shall have primary physical custody of the children subject to
Father's partial physical custody, as follows:
A. On alternating weekends, from Saturday at 12:00 noon. until Sunday at 7:00 p.m.
B. At such other times as the parties may mutually agree.
3. Holidays and Vacations. The following shall govern holidays and vacation periods
A. Thanksgiving and Christmas holidays shall be split into block A and block B. Block A
shall be Christmas Eve/Thanksgiving Eve from 2:00 p.m. to the same time on
Christmas Day/Thanksgiving Day. Block B shall be Christmas Day/Thanksgiving Day
at 2:00 p.m. to the day after Christmas /Thanksgiving at 2:00 p.m. The parties shall
alternate block A and B on a yearly basis. Mother shall have Block A during even
years and Father odd years.
B. The remaining holidays shall be divided in accordance with mutual agreement
between the parties
C. Each party shall have two (2) non-consecutive weeks of uninterrupted physical
custody during the summer. Each party shall provide no less than thirty (30) days
notice of their scheduled week(s). Vacation weeks are seven (7) days and will
include the vacationing parent's alternating weekend. Should a party's vacation
week fall partially on the other's alternating weekend, then the other party shall be
entitled to equal make-up weekend days as determined in advance of the vacation
by the agreement of the parties.
4. Scheduled Events. The parties shall keep each other informed of all other scheduled
events involving the children, including but not limited to ,school functions; parent/teacher
meetings; extracurricular events; and sporting events so that both parents have the opportunity
to take part in these events.
5. Telephone contact. Each party shall have reasonable telephone contact with the
children during the other party's periods of physical custody. Mother and Father shall make all
i ~
efforts to ensure such contact. The parties shall ensure that each has a working telephone
contact number from the other for this purpose. Communication shall be by telephone or text
messaging.
6. Non-Disoaraeement. The parties shall do nothing, nor permit a third party to do
anything, that may estrange the children from the development of their love and affection for
the other parent. The parties shall not disparage one another in front of the children nor allow
third parties to do so. In this connection.
7. This Order is entered pursuant to the Stipulation of the parties. The parties may modify
the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of
this Order shall control.
~~
J.
Distribution:
.Kerr, Esquire, 5020 Ritter Road, Suite 109, Mechanicsburg, PA 17055
Joel Kramer, 48 Thornwood Road, Harrisburg, Pennsylvania 17112
~U t-~ r~n.at c ~~
1~ ~. ` w
~r~