HomeMy WebLinkAbout01-1775JOSEPH L. MUELLER,
Plaintiff
JANNA L. KNAPP,
Defendant
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:
:CIVIL ACTION - LAW
:IN DIVORCE/CUSTODY
STIPULATION OF CUSTODY
THIS IS A STIPULATION AND AGREEMENT entered into the day and year
hereinafter set forth, by and between JANNA L. KNAPP (hereinafter referred to as
"Mother") and JOSEPH L. MUELLER (hereinafter referred to as "Father")
WHEREAS, the parties are the parents of one (1) minor child, namely Kayla J.
Mueller, bom March 27, 1990 (hereinafter referred to as the "Child");
WHEREAS, the parties are divorced, living separate and apart, and wish to
establish an agreed upon Court Ordered arrangement relative to the physical and legal
custody of their child; and
WHEREAS, the parties hereby direct their Counsel to-submit this Stipulation to
the Court and ask that the Cou~ enter a Custody Order adopting the terms hereof.
NOW, THEREFORE, in consideration of the mutual covenants, promises and
agreements as hereinafter set forth and intending to be legally bound hereby, the parties
stipulate and agree as follows:
Mueller.
The parties shall share legal custody of the minor child: Kayla J.
2. The parties shall share physical custody of the parties' minor Child
according to the following arrangement:
a. Father shall have physical custody of the Child one evening per
week f~om 6:00 p.m. until 7:30 p.m. during the week when Father does not have physical
custody on the weekend. Father shall provide transportation.
b. Father shall physical custody of the Child every other weekend
from Friday evening at 5:30 p.m. until Sunday evening at 7:00 p.m.
3. Fathe~ shall provide transportation on Friday evenings and holidays, and
Father and Mother agree to meet at a mutually agreeable spot on Sunday evenings and
holidays.
4. The parties shall alternate custody on the following holidays to include:
New Years Eve/Day, Memorial Day, Independence Day and Labor Day. These holidays
shall be alternated as follows:
Odd Numbered Years -- Father shall have the Child on New Years Day and
Independence Day from 5:00 p.m. the day before the actual holiday until 7:00 p.m. the
day of the holiday, and Mother shall have the Child on Memorial Day and Labor Day.
Even Numbered Years -- Father shall have the Child on Memorial Day and Labor
Day from 5:00 p.m. the day before the holiday until 7:00 p.m. the day of the holiday and
Mother shall have the Child on New Years Day and Independence Day.
5. Custody during the Thanksgiving holiday shall be divided as follows:
2
Mother shall have custody of the Child from Wednesday at 5:00 p.m. until
Thanksgiving Day at 3:00 p.m.
Father shall have custody of the Child from Thanksgiving Day at 3:00 p.m. until
Friday at 5:00 p.m.
6. Custody during the Christmas holiday shall be alternated as follows:
Odd Numbered Years -- Father shall have the Child from 1:00 p.m. on Christmas
Day until 5:00 p.m. on December 26 and Mother shall have the Child thereafter.
Even Numbered Years -- Father shall have the Child from 8:00 p.m. Christmas
Eve until 1:00 p.m. Christmas Day and Mother shall have the Child thereafter.
7. Custody dur'mg the Easter holiday shall be alternated as follows:
Odd Numbered Years -- Father shall have the Child from 5:00 p.m. on the day
before Easter Sunday until 1:00 p.m. on Easter Sunday and Mother shall have the Child
from 1:00 p.m. until 7:00 p.m. on Easter Sunday.
Even Numbered Years -- Mother shall have the Child from 5:00 p.m. on the day
before Easter Sunday until 1:00 p.m. on Easter Sunday and Father shall have the Child
from 1:00 p.m. until 7:00 p.m. on Easter Sunday or until 7:00 p.m. the following Monday
provided the Child has off school that Monday.
8. Father shall have custody of the Child on Father's Day from 9:00 a.m.
until 7:00 p.m. and Mother shall have custody of the Child on Mother's Day from 9:00
a.m. until 7:00 p.m.
9. Father shall have custody of the Child for three (3) weeks during the
Child's summer vacation from school to be taken one (I) week per month. The week
shall begin on a Friday of Father's regular weekend at 5:30 p.m. and end the following
Friday at 7:00 p.m.
a. The parties agree that they may each take the Child away on
vacation and agree to provide each other at least one week's notice prior to the vacation.
10. The parties shall have custody of the Child at such other times as the
parties may agree.
IN WITNESS WHEREFORE, the parties hereto intending to be legally bound by
the terms hereof, set foFth their hands and seals the day and year set forth below.
!u~I" .~eller
Eliz)flSeth S. Beckley, Esq.~
Att5' for Joseph L. Muelle~r
fnnaL. Kna~pp/ '~/' / ?'
Date
Robert B. Lieberman, Esq.
Atty for Janna L. Knapp
4
JOSEPH L. MUELLER,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
v. :CIVIL ACTION - LAW
:CUSTODY
JANNA L. KNAPP, :
Defendant :NO. t~l
ORDER
AND NOW, this0~day of ~ ~ ,2001, after careful review of
the Stipulation of Custody entered into by the parties and attached hereto, and in
accordance with the parties' request that said Stipulation of Custody be entered as an
Order of Court, it is hereby ORDERED that the parties shall share legal and physical
custody of their minor child pursuant to the terms of said Stipulation~