HomeMy WebLinkAbout01-2906 : IN THE COURT OF COMMON PLEAS OF
MARYANN P. NEAL,
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
V.
KAREN HEATHERLY and : NO. 01- -~ e/O{; CIVIL TERM
PAUL J. COSTELLO, JR. :
Defendants : IN CUSTODY
~USTODY STIPULATION AND AGREEMENT
THIS STIPULATION AND AGREEMENT entered into the day and year hereinafter set
forth, by and between M.,~RYANN P. NEAL, (hereinafter referred to as "Neal") and KAREN
HE,4THERLY, (hereinafter referred to as "Mother") and PAUL J. COSTELLO, JR., (hereinafter
referred to as Father ).
WHEREAS, Mother and Father are the natural parents of one child, Paul J. Costello, III,
bom April 21, 1984, (hereinafter referred to as "Child"); and
WHEREAS, Neal is a party unrelated to the Child, but with whom the child presently
resides;
WHEREAS, the parties wish to vacate that prior Order and enter into an Order of Court
based upon the within Stipulation and Agreement.
NOW THEREFORE, in consideration of mutual covenants, promises and agreements as
hereinafter set forth, the parties stipulate and agree as follows:
1. Neal shall have primary physical and legal custody of the child.
2. Mother and Father shall each, independently, have periods of partial physical custody
with the Child as the parties may agree, taking into consideration the desires of the
Child.
3. The Child has resided for his entire life in Cumberland County, Pennsylvania, and
Cumberland County has jurisdiction relative to custody of the child.
4. The parties desire that this Stipulation and Agreement be made an Order of Court
of the Court of Common Pleas of Cumberland County, and further acknowledge
that the Court of Common Pleas of Cumberland County does, in fact, have
jurisdiction over the issue of custody of the Child, who has resided for his entire
life in Cumberland County, Pennsylvania.
5. The parties stipulate that in making this Agreement. there has been no fraud,
concealment, overreaching, coercion, or other unfair dealing on the part of the
other party.
6. The parties acknowledge that they have read and understand the provisions of this
Agreement. Each party acknowledges that the Agreement is fair and equitable
and that it is not the result of any duress or undue influence.
IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms
hereof, set forth their hands and seals the day and year hereinafter mentioned.
COMMONWEALTH OF PENNSYLVANIA :
:
COUNTY :
officer, personally appeared MARYANN P. NEAL, known to me (or satisfactory proven) to be
the person whose name is subscribed to the within Agreement and acknowledged that she
executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
COMMONWEALTH OF PENNSYLVANIA :
COUNTY OF (- UL Vvk ~c)~ ~' ~'f't ~' "'t' k :
On this 4'4~ day of ~k.~,'~.~ ,2001, before me. the undersigned
officer, personally appeared I6,1REN It£ATItERL¥, known to me (or satisfactory proven) to be
the person whose name is subscribed to the within Agreement and acknowledged that she
executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Notary Public
k~ly Commlssl F=xp~ ·
STATE OF FLORIDA :
COUNTY OF g774/~ I° X/ :
On this /O~7/day of /4/)/~ / ~'' , 2001, before me, the undersigned
officer, personally appeared PAUL J. COSTELLO, JR., known to me (or satisfactory proven) to
be the person whose name is subscribed to the within Agreement and acknowledged that he
executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
,tary Public '/7
MARYANN P. NEAL, : IN THE COURT OF COMMON PLE ~/~..~. _i '; ~.~:~- ~?
Plaintiff CUMBERLAND COUNTY, PENNSYlVaNIA .....
:
: CIVIL ACTION - LAW
V.
KAREN HEATHERLY and : NO. O] -~ O~ CIVIL TERM
PAUL J. COSTELLO, JR. :
Defendants : IN CUSTODY
ORDER OF COURT
ANDNOWthis /~day°flt~'' , 2001, upon presentation and
consideration of the Stipulation and Agreement is hereby ordered and directed that the attached
Stipulation and Agreement is hereby made an Order of Court with all prior Orders and
Agreements being vacated.
BY THE~~...~
Attorney Jbr Plaintiff
Karen Heatherly, Defendant, pro se
Paul J. Costello, Jr., Defendant, pro se