HomeMy WebLinkAbout00-08434 NMFILED-QFEIC
2011 AUG I I AM 11: 4 5
"'JMBERLA U HUMP(
PENNSYLVANIA
DALE L. ROBINSON : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
: No. 00-8434 Civil
LISA M. ROBINSON,
Defendant
: IN CUSTODY
r?
This Stipulation and Custody Agreement is made this day ofd,
2011 by and between Lisa M. Robinson, (Hereinafter referred to as "Mother") and Dale L.
Robinson, (Hereinafter referred to as "Father").
WHEREAS, Mother and Father are the natural parents of one child, namely,
Paige Marie Robinson, date of birth, March 14, 1996, age 15;
WHEREAS, Mother and Father have reached an agreement relative to the future care,
custody and visitation of their child, the terms of which agreement both parties desire to set forth
in the present Stipulation and Custody Agreement, and;
WHEREAS, Mother and Father desire the provisions of the present Stipulation and
Custody Agreement be approved by the Honorable Court of Common Pleas of Cumberland
County and entered as a Court Order, with the same force and effect as though said. Order had
been entered after Petition, Notice and Hearing. This agreement replaces the prior order entered
by the Honorable Judge Edward E. Guido on February 7, 2001.
NOW THEREFORE, the parties, intending to be legally bound, and in consideration of
the mutual promises and agreements contained herein, hereby agree to the custody order as
follows:
1. LEGAL CUSTODY: Mother and father shall have shared legal custody of the child.
2. PHYSICAL CUSTODY: Mother and father shall have shared physical custody on a week
on/week off basis from Sunday at 7:00pm until the following Sunday at 7:00pm.
3. VACATION: Mother and Father shall each have two non-consecutive weeks of vacation
when that parent may have uninterrupted custody of the child. A week shall be defined as
Sunday at 7:00 p.m. until the following Sunday at 7:00 p.m. Each parent shall give at least thirty
(30) days written notice of intent to take the period or periods of summer vacation to the other
parent. The party who first gives notice to the other shall take precedence, and the other party
shall not schedule a period of vacation during that time.
4. HOLIDAYS: Mother and father shall share the holidays as follows:
Christmas: The Christmas Holiday shall consist of two (2) periods. Period (a) shall
commence at 12:00 p.m. on December 24 and end at 12:00 p.m. on December 25. Period (b)
shall commence at 12:00 p.m. December 25 and end at 12:00 p.m. on December 26. Mother
shall have period (a) in odd years and period (b) in even years. Father shall have period (b) in
odd years and period (a) in even years.
Easter: Easter Sunday shall consist of two (2) periods. Period (a) shall commence
at 9:00 a.m. on Easter Sunday and end at 2:00 p.m. on Easter Sunday. Period (b) shall
commence at 2:00 p.m. Easter Sunday and end at 8:00 p.m. on Easter Sunday. Mother shall have
period (a) in odd years and period (b) in even years. Father shall have period (b) in odd years
and period (a) in even years.
Thanksgiving: Thanksgiving Day shall consist of two (2) periods. Period (a) shall
commence at 9:00 a.m. on Thanksgiving Day and end at 2:00 p.m. on Thanksgiving Day. Period
(b) shall commence at 2:00 p.m. Thanksgiving Day and end at 8:00 p.m. on Thanksgiving Day.
Mother shall have period (a) in odd years and period (b) in even years. Father shall have period
(b) in odd years and period (a) in even years.
New Year's Day, Memorial Day, Fourth of July and Labor Day: Mother and Father
shall alternate New Year's Day, Memorial Day, Fourth of July and Labor Day.
Mother's Day, Father's DU: Mother shall always have Mother's Day from 9:00 a.m.
until 7:00 p.m. Father shall always have Father's Day from 9:00 a.m. until 7:00 p.m.
Child's Birthday: Mother shall always have custody of the child on the child's
birthday during even numbered years and Father shall always have custody of the child on the
child's birthday on odd numbered years. Custody shall be from 9:00 a.m. until 7:00 p.m.
5. TRANSPORTATION: Transportation shall be shared by the parties, with the parent who is
to receive custody at the time of exchange, responsible for providing transportation.
6. TELEPHONE/E-MAIL CONTACT: The custodial parent shall assure that the non-
custodial parent has reasonable access to the child via telephone and/or email.
7. DISPARAGING REMARKS: Each of the parties and any third party in the presence of the
child shall take all measures deemed advisable to foster a feeling of affection between the child
and the other party. Neither parent shall do nor shall either parent permit any third person to do
or say anything which may estrange the child from the other parent, their spouse or relatives, or
injure the child's opinion of the other parent or which may hamper the free and natural
development of the child's love and respect for the other parent.
8. MUTUAL CONSULTATION: Each parent shall confer with the other on all matters of
importance relating to the child's health, maintenance, and education with a view towards
obtaining and following a harmonious policy in the child's education and social adjustments.
Each party agrees to keep the other informed of his or her residence and telephone number to
facilitate communication concerning the welfare of the child and visitation.
9. WELFARE OF THE CHILD TO BE CONSIDERED: The welfare and convenience of
the child shall be the prime consideration of the parties in any application of the provisions of
this Order. Both parents are directed to listen carefully and consider the wishes of the child in
addressing the custodial schedule, any changes to the schedule and any other parenting issues.
10. ALCOHOL/ILLEGAL SUBSTANCES: Neither parent shall drink alcoholic beverages to
excess or consume illegal substances when in the presence of the child and no party shall be
under the influence of alcoholic beverages or illegal substances when in the presence of the
child. Neither parent shall allow others to drink alcoholic beverages to excess or consume illegal
substances when in the presence of the child.
11. MODIFICATION OF ORDER: The parties are free to modify the terms of this Order but
in order to do so the Court makes it clear that both parties must be in complete agreement to any
new terms. That means that both parties must consent on what the new terms of the custody
arrangement or visitation schedule shall be.
12. GOVERNING LAW: This Agreement shall be governed and controlled by the laws of
Pennsylvania.
IN WITNESS WHEREOF, the parties have hereto duly executed the present Stipulation
and Custody Agreement the day and year first above written.
WITNESS:
-?
fitness
Lisa . Robinson
Witness Dale L. Robinson
IN THE COURT OF COMMON PLEAS OF
DALE L. ROBINSON :
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff :
(-7) ,.
: Civil Action- Law _ - ? -?
v s i
s = r?
No. 00-8434 Civil ,
:
:Tr}
_
,-
LISA M. ROBINSON, - ` ?
C,
Defendant 'j
IN CUSTODY -
C.j
ORDER OF COURT
?J day of I , 2011, the attached
AND NOW, this
Stipulation and Custody Agreement is hereby incorporated as an Order of Court.
cc: 'Michael J. Whare, Esq.
? Dale L. Robinson, Pro Se
0 if e-6 Male
op 81
4.