HomeMy WebLinkAbout01-1466CRISTY L. PAUL,
Plaintiff
JEFFREY BURRELL,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
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CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
,200~, upon
AND NOW, this
stipulation of the parties, it is hereby Ordered and Decreed:
1. Plaintiff, Cfisty L. Paul, and Defendant, Jeffrey Burrell, shall have shared legal custody
of Jason Burrell, bom November 17, 1984. Each parent shall have an equal fight, to be exercised
jointly with the other parent, to make all major non-emergency decisions affecting the child's general
well-being including, but not limited to, all decisions affecting the child's health, education, and
religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and
information pertaining to the child, including, but not limited to, school and medical records and
information.
2. The Plaintiff shall have primary physical custody of the child, subject to the
Defendant's rights of partial physical custody, during the school months, as follows:
A. Defendant shall be entitled to visitation every other weekend, from
Friday, after Defendant's work, until Sunday at 6:00 p.m. When a national holiday
is observed on a Monday, subsequent to Defendant's weekend period of custody, and
school is not in session, Defendant shall retain custody of the minor child until 6:00
p.m. on the day of the holiday; and
Any additional periods of physical custody which the parties may agree
upon.
3. During the non-school months, Defendant shall exercise periods of partial physical
custody, as follows:
A. Defendant shall he entitled to visitation every other weekend, fi.om
Friday, at the end of Defendant's work schedule, until Sunday at 6:00 p.m. When a
national holiday is observed on a Monday, subsequent to Defendant's weekend period
of custody, and school is not in session, Defendant shall retain custody of the minor
child until 6:00 p.m. on the day of the holiday;
B. Every Tuesday evening, overnight, fi.om the end of Defendant's work
schedule, until Wednesday morning before work;
C. Every Wednesday evening, overnight, fi.om the end of Defendant's work
schedule, until Thursday morning before work;
D. One (1) full week of uninterrupted visitation during the summer
months, with the exact details to he determined by the parties; and
Any additional periods of physical custody which the pa~ies may agree
upon.
4. Holidays shall he shared between the parties upon the following schedule:
A. Defendant shall be entitled to visitation on Father's Day and Plaintiff
shall be entitled to visitation on Mother's Day, with the exact details to be determined
by the parties.
B.
as follows:
The parties shall share custody of the child on the Christmas holiday
1. Schedule A: From 6:00 p.m., or
earlier if agreed upon between the parties, on
Christmas Eve umil 12:00 p.m. on Christmas Day; and
2. ScheduleB: From 12:00 p.m. on
Christmas Day until 6:00 p.m., or later if agreed upon
between the parties, on December 26th.
Plaintiff shall exercise her period ofcnstody over the child in
accordance with the Schedule A provisions in all odd numbered years
and with the Schedule B provisions in alt even numbered years.
Defendant shall exercise his period of custody over the child in
accordance with the Schedule A provisions in all even numbered years
and with the Schedule B provisions in all odd numbered years.
C. The following major holidays shall be equally divided between the
parties, with the exact details of such to be determined by the parties: New Year's
Day, Easter, Memorial Day, July Fourth, Labor Day, and Thanksgiving Day.
5. The parties shall keep each other informed of their respective current addresses and
telephone numbers.
6. Each parent shall be entitled to reasonable telephone contact with the child while he
is in the custody of the other parent. The child should be encouraged to telephone the non-custodial
parent at reasonable intervals.
7. Each parent shall encourage the participation of the child in extracurricular activities
and the child's part-time employment through Burger King. Each party agrees to remain flexible and
understanding, durin8 any conflicts which may arise between the child's employment schedule and
the stated custody schedule and times set forth in this stipulation. Transportation to and from
extracurricular activities and employment, shall he the responsib'flity of the parent exercising physical
custody. The parties agree during the months of September through and including December,
Plaimiff shall be responsible for providing transportation for the child on Sundays.
8. Both parties shall encourage the child to love and respect the other and shall not make,
nor allow others to make, in the presence of the child, derogatory comments about the other parem.
Further, each parent shall encourage the child to have significant contact with the other parent, and
shall make certain that the child is ready on time for the transfer of physical custody &the child from
one parent to the other.
9. During any period of custody or visitation the parties to this Order shall not possess
or use any controlled substance, neither shall they consume alcoholic beverages to the point of
intoxication. The parties shall likewise assure, to the extent possible, that other household members
and/or house guests comply with this prohibition.
CRISTY L. PAUL,
Plaintiff
JEFFREY BURRELL,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
;
:No. ol-/~(~L CIVH, TERM
:
: CIVIL ACTION - LAW
: IN CUSTODY
STIPULATION FOR CUSTODY
WHEREAS, the Plaintiff and Defendant are the parents of one minor child, to wit: Jason
Burrell, bom November 17, 1984;
WHEREAS, the Plaintiff and Defendant, after careful consideration and the opportunity for
the advice and assistance of counsel, have reached an agreement to provide for the custody of this
child without the need to litigate the matter before this Honorable Court and asks the Court to adopt
this agreement as its Order;
WHEREAS, it is the beliefoftbe Plaintiff'and Defendant that the agreement reached herein
provides for the best interest of this child;
NOW THEREFORE, imending to be legally bound, the parties agree as follows:
1. Plaintiff, Cristy L. Paul, and Defendant, Jeff.o/Burrell, shall have shared legal custody
of Jason Burrell, born November 17, 1984. Each parent shall have an equal fight, to he exercised
jointly with the other parent, to make ail major non*emergency decisions affecting the child's general
well.4~ing including, but not limited to, all decisions affecting the child's health, education, and
religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and
information pertaining to the child, including, but not limited to, school and medical records and
infuxmation.
2. The Plaintiff shall have primary physical custody of the child, subject to the
Defendant's fights of partial physical custody, during the school months, as follows:
A. Defendant shall be entitled to visitation every other weekend, from
Friday, after Defendant's work, until Sunday at 6:00 p.m. When a national holiday
is observed on a Monday, subsequent to Defendant' s weekend period of custody, and
school is not in session, Defendant shall retain custody of the minor child until 6:00
p.m. on the day oftbe holiday; and
B. Any additional periods of physical custody which the parties may agree
upon.
3. During the non-school months, Defendant shall exercise periods of partial physical
custody, as follows:
A. Defendant shall be entitled to visitation every other weekend, from
Friday, at the end of Defendant's work schedule, until Sunday at 6:00 p.m. When a
national holiday is observed on a Monday, subsequent to Defendant' s weekend period
of custody, and school is not in session, Defendant shall retain custody of the minor
child until 6:00 p.m. on the day of the holiday;
B. Every Tuesday evening, overnight, from the end of Defendant's work
schedule, until Wednesday morning before work;
C. Every Wednesday evening, overnight, from the end of Defendant's work
schedule, until Thursday morning before work;
D. One (1) full week of uninterrupted visitation during the summer
months, with the exact details to be determined by the parties; and
E. Any additional periods of physical custody which the parties may agree
upon,
4. Holidays shall he shared between the parties upon the following schedule:
A. Defendant shall he entitled to visitation on Father's Day and Plaintiff
shall he entitled to visitation on Mother's Day, with the exact details to be determined
by the parties.
B.
as follows:
The parties shall share custody of the child on the Christmas holiday
t. ScheduteA: From 6:00 p.m. on
Cbxistmas Eve until 12:00 p.m. on Christmas Day; and
2. ScheduleB: From 12:00 p.m. on
Christmas Day until 6:00 p.m. on December 26th.
Plaintiff shall exercise her period of custody over the child in
accordance with the Schedule A provisions in all odd numbered years
and with the Schedule B provisions in all even numbered years.
Defendant shall exercise his period of custody over the child in
accordance with the Schedule A provisions in all even numbered years
and with the Schedule B provisions in all odd numbered years.
C. The following major holidays shall he equally divided between the
parties, with the exact details of such to be determined by the parties: New Year's
Day, Easter, Memorial Day, July Fourth, Labor Day, and Thanksgiving Day.
5. The parties shall keep each other informed of their respective current addresses and
telephone numbers.
6. Each parent shall be entitled to reasonable telephone contact with the child while he
is in the custody oftbe other parent. The child should be encouraged to telephone the non-custodial
parent at reasonable intervals.
7. Each parent shall encourage the participation of the child in extracurricular activities
and the child's part-time employment through Burger King. Each party agrees to remain flexible and
understanding, during any conflicts which may arise between the child's employment schedule and
the stated custody schedule and times set forth in this stipulation. Transportation to and from
extracurricular activities and employment, shall be the responsihitity oftbe parent exercising physical
custody. The parties agree during the months of September through and including December,
Plaintiff shall be responsible for providing transportation for the child on Sundays.
8. Both parties shall encourage the child to love and respect the other and shall not make,
nor allow others to make, in the presence of the child, derogatory corers about the other parent.
Further, each parent shall encourage the child to have significant contact with the other parent, and
shall make certain that the child is ready on time for the transfer of physical custody of the child from
one parent to the nther~
9. During any period of custody or visitation the parties to this Order shall not possess
or use any controlled substance, neither shall they consume alcohoY~c beverages to the point of
intoxication. The parties shall likewise assure, to the extent possible, that other household members
and/or house guests comply with this prohibition.
10. Plaintiffis represented by Cara A. Boyanowski, Esquire. Defendant is not represented
by counsel. All parties have been informed of the purpose of this Agreement and its legal effects and
consequences.
11. Each of the parties has carefully read and fully considered this Stipulation and all of
the statements, terms, conditions, and provisions thereof prior to signing below.
IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have
set their hands and seals on thisC~d-)(~ day of
WITNESS:
Coumei for Plaintiff
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