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HomeMy WebLinkAbout01-2715 TRACIE E. DERR, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. ~/- ~ 7~~ CIVIL TERM : ROBERT L. DERR, : CIVIL ACTION - LAW Defendant : IN CUSTODY STIPULATION FOR CUSTODY WHEREAS, the Plaintiff and Defendant are the parents of two minor children, to wit: Brooke Derr, born November 23, 1993, and Tyler Derr, born June 25, 1997; WHEREAS, the Plaintiffand Defendant, after careful consideration and the opportunity for the advice and assistance of counsel, have reached an a~'eement to provide for the custody of these children without the need to litigate the matter before this Honorable Court and asks the Court to adopt this agreement as its Order; Wi~'.REAS, it is the belief of the Piaintiffand Defendant that the asreement reached herein provides for the best interest of these children; NOW Tnr. REFORE, intendin~ to be lesally bound, the parties agree as follows: 1. Plaintifl~, Tracie E. Derr, and Defendant, Robert L. Deft, shall have shared legal custody of Brooke Derr, bom November 23, 1993, and Tyler Derr, bom June 25, i 997. Each parent shall have an equal fight, to be exercised jointly with the other parent, to make all major non- eme~ency decisions affecting the children's general well-bein~ including, but not limited to, all decisions affecting the children's health, education, and relision. Pursuant to the terms of this paragraph, each parent shall be entitled to ail records and information pertaining to the children, including, but not limited to, school and medical ~ecords and information. 2. Plaintiffand Defendant shall have shared physical custody of the minor children. Each parent shah have the children for seven (7) consecutive days at which time, physical custody shall transfer to the other parent. The transfer of physical custody shall take place on F~idays, with the exact location and the exact times of transfer to be at the discretion oftbe parties. This schedule shall begin on May 18, 2001. 3. Holidays shall be shared between the parties upon the following schedule: A. Plaintiffshall be entitled to visitation on Mothers Day and Defendant shall be entitled to visitation on Fatber's Day, with the exact details to be det~,,,,ined by the parties. B. The parties shall share custody of the children on the Christmas holiday as follows: 1. $chedule A: From 6:00 p.m. on Christmas Eve until 1:00 p.m. on Chri~imas Day; and 2. Schedule B: From 1:00 p.m. on Christmas Day until 6:00 p.m. on December 26th. Plaintiffshall exercise her period ofcustudy over the children in accordance with the Schedule A provisions. Defendant shall exemise his period of custody over the children in accordance with the Schedule B provisions. C. The followin8 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, ,~uly Fourth, Labor Day, and Thanksgivin8 Day. D. Any additional periods of physical custody which the parties may agree upon. 4. The parties shall keep each other informed of their respective current addresses and telephone numbers. 5. Both parties shall encourage the children to love and respeet the other and shall not make, nor allow others to make, in the presence ofthe children, derogatory comments about the other parent. Further, each parent shall encourage the children to have significant contact with thc other parent, and shall make certain that the children are ready on time for the transfer of physical custody of the children from one patent to the other. 6. 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. 7. This agreement has been reached after careful consideration of the needs of the children. The parties agree that they shall not seek to change this shared custody arrangement unless this arrangement constitutes a clear and present danger to the physical or emotional well-being of the children. 8. Plaintiffis represented by Cara A. Boyenowski, Esquire. Defendant is not represented '.4. by counsel ,~,11 parties have been informed ofthe purpose ofthis Agreement and its legal effects and con.sequences 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 ~'ITNKSS WIIEREOF, intending to be legally bound hereby, the parties hereto have set d~eir hands and seals on this ~ l~ daY of ~,~/~ .,2001. wI'rNESS ! u-~!(- .. '-.. " x'-tZa,'a A ko~anowsltJ, Esquire Trade E. Den' -'witness ~i Robert I'..'~-~ : IN ~ COURT OF COMMON pLI~AS TRACI~ E. DERR, : CUMBE~ COUNTY, pENNSYLVANIA Plaintiff : NO.OI - .27/-5' CIVIL TERM Vo :CIVIL ACTION - I~AW ROBERT L. Dg. RR, : IN CUSTODY Defendant stipulation of thc parties, it is bereby Ordered and Decreed: 1. Plaintiff, Tracie E. Deft, and Defendant, Robert L. Derr, shall have shared legai custody ofBrookeDerr, bornNovember 23' 1993, and Tyler Derr, born lone 25, 1997. Each parent shall have an equal fight, to be exercised jointly with the other parent, to make ail major non- emergency decisions affecxin$ the children's general well-baing including, but not limited to, all decisions affecting the children's health, education, and relision. Pursuant to the terms of this paragraph, each parent shall be entitled to ail records and information pertainin8 to the children, incioding, but not limited to, school and medical records and information. 2. plaintiffand De~,enclant shail have shared physicai custody ofthe minor children. Each parent shall have the children for seven (?) consecutive days at which time, physical custody shall trenst'er to the other parent. The transfer of physical custody shall take place on Fridays, with the exact location and the exact tunes of transfer to be at the discretion oftbe parties. This schedule shall besin onMay 18, 2001. 3. Holidays shall be shared between the parties upon the foilowin8 schedule: A. Plaintiff shall be entitled to visitation on Motbe~s Day and Defendant shall be entitled to visitation on Fatbei's Day, with the exact details to be determined B. The parties shall share custody ofthe children on the Christmas holiday as follows: 1. ScbeduleA: From 6:00 p.m. on Christmas Eve until 1:00 p.m. on Christmas Day; and 2. SchedulcB: From 1:00 p.m. on Christmas Day until 6:00 p.m. on December 26th. Plaintiff shall exercise her period of custody over the children in accordance with the Schedule A provisions. Defendant shall exercise his period of custody over the children in accordance with the Schedule B provisions. C. The followin8 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, luly Fourth, Labor Day, and ThenksBivin$ Day. D. Any additional periods ofpbysical custody which the parties may ~ upon. 4. The parties shall keep each other informed of their respective current addresses and telephone numbers. · ~:,~o~. ,~ I,we and resl~ct the other and shall not . noth ~ies s~ ~e t~ c~u~,, ...... ~' ~ ~-- · ..... r~ oft~ cMld~ d~o~t~ ~ts ~ut the ~, nor ~ow ot~ to ~, m mc p ~t ~n~ ~th the oth~ ~nt. Fu~h~, ~h p~ s~l ~e the c~dr~ to have . p~t, ~d s~l ~e ~ t~t the ~d~ ~ r~Y on t~me for ~ t~ of phy~ ~st~Y of t~ cMldr~ ~om o~ p~t to the ~hff. 6 ~ ~ ~od of ~ody or ~s~tion ~e ~i~ to t~s ~d~ ~ not ~s~ss or u~ ~ ~ntroll~ sub~, n~th~ ~! th~ ~n~e ~holic b~~ to the point of i~o~tion. ~e p~ies ~l ~ ~' ~ the ~t possiUle, ~t oth~ hou~hold ~s ~or hou~ ~e~s ~mply ~ tMs pmMbMon. ~ ~ ~ r~h~ ~ ~! ~nsideration of the n~s of the 7. TMs ~' ......,--~ c~e tMs sh~M ~st~y ~ u~s c~d~. The p~i~ a~ t~t th~ ~ not ~-,~ tMs ~t ~nsti~ a cle~ ~d ~t d~S~ to the p~ ~ ~go~ wSl-~ of children.