HomeMy WebLinkAbout02-0529REBECCA J. RICHWINE,
Plaintiff
AMY BRENIZER AND
SHAWN FREEMAN,
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 20011~ -C.~:~ CIVIL TERM
:
: CIVIL ACTION - LAW
: IN CUSTODY
CUSTODY STIPULATION AND AGREEMENT
THIS AGREEMENT AND STIPULATION is entered into on the day and year
hereinafter set forth, by and between Plaintiff, Rebecca J. Richwine, hereinafter referred to as
"Grandmother"; and Defendants, Amy Brenizer, hereinafter referred to as "Mother", and Shawn
Freeman, hereinafter referred to as "Father".
WHEREAS, the Defendants are the natural parents of Amber Marie Ann Freeman, bom
June 25, 1996; and Brooklyn Lee Ann Freeman, bom July 4, 1997; and
WHEREAS, Plaintiff is the biological mother of Defendant, Amy Brenizer; and
WHEREAS, Plaintiff is the maternal grandmother of the children at issue; and
WHEREAS, Amy Brenizer and Shawn Freeman are currently subject to a Court Order
dated April 18, 2001, attached hereto and incorporated by reference as Exhibit 'A'; and
WHEREAS, the parties wish to enter into an agreement relative to custody and partial
custody of the children.
NOW THEREFORE, in consideration of the mutual covenants, promises, and
agreements as hereinafter set forth, the parties agree as follows:
Grandmother and Mother shall have shared legal custody of the children.
Grandmother shall maintain primary physical custody of the children.
Mother shall enjoy periods of partial physical custody at such times as mutually
agreed to by Mother and Grandmother.
4. Father shall enjoy periods of partial physical custody and/or visitation at such
times as mutually agreed to between Father and Grandmother.
5. Any modification or waiver of any of the provisions of this Agreement shall be
effective only if made in writing and only if executed with the same formality as this Stipulation
and Agreement.
6. The parties desire that this Stipulation and Agreement be made an Order of the
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 children
at issue who have resided in Cumberland County for more than six months, and shall retain such
jurisdiction should circumstances change and any party desires or requires modification of said
Order.
7. 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 duress or undue influence.
IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms
hereof set forth their signatures the day and year written below.
DATE' Rebecca J. Richxl~e, Grandmother
DATE Shra'wn Freeman, Father
ORDER OF COURT
AND NOW, this day of ,2001, upon presentation and
consideration of the above Custody Stipulation and Agreement it is hereby ordered and directed
that it be entered as an Order of Court.
BY THECOURT,
SAIDIS
lUFF, FLOWER
& LINDSAY
Ci'TO~AT.LAW
W. High Street
Carlisle, PA
.~uMY BRENi ZER,
V0
SHAWN FREEMA~N,
AND NOW this
: iN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COL~TY, PENNSYLVaNiA
Plaintiff
: No.: 98-05500 Civil Term
:
: IN CUSTODY
:
Defendant :
STIPULATION
I
come the parties to stipulate as follows:
, 2001,
1. Plaintiff is Amy Brenizer, an adult individual
currently residing at 49 ~ west High Street, Apt. 3, Carlisle,
Pennsylvania.
2. Defendant is Sha%~n Freeman, an adult individual
currently residing at 410 North Bedford Street, Carlisle,
Pennsy!vania.
3. The parties are the na'~ura! parents of Amber
Freeman, da~e of birth June 4, 1996 and Brooklyn~~=o~_-m~-., date
cf blr5h July 4, 1997.
-'-~ car~ies ~c =~ -"a~ Amy
-~-~-=~.~.~_..~_, shall have full and cermane.--=- oust-~''~_~ cf sal!
-_hildren ,-¼e ~ar~ies furuher ~o~ 5h?.-_ '
.... a~- -- as Drl.T. ar~;
_-uszcdLan, Amy Brer. izer ma',' mcve wizh
5. The par~ies further agree'~ha~ periods of partial
physical cuszcdy and/or visitation by 5he Defendan~ ~'
w. ii be by
agreement cf Zhe parties.
6. The par~ies agree that this agreement be evidenced
by an Order of Court.
witness
witness
AIDIS
FLOWER
,INDSAY
High Street
disle. PA
REBECCA J. RICHWINE,
Plaintiff
AMY BRENIZER AND
SHAWN FREEMAN,
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 200~ ~C..~] CIVIL TERM
: CWIL ACTION - LAW
: IN CUSTODY
CUSTODY STIPULATION AND AGREEMENT
THIS AGREEMENT AND STIPULATION is entered into on the day and year
hereinafter set forth, by and between Plaintiff, Rebecca J. Richwine, hereinafter referred to as
"Grandmother"; and Defendants, Amy Brenizer, hereinafter referred to as "Mother", and Shawn
Freeman, hereinafter referred to as "Father".
WHEREAS, the Defendants are the natural parents of Amber Marie Ann Freeman, bom
June 25, 1996; and Brooklyn Lee Ann Freeman, bom July 4, 1997; and
WHEREAS, Plaintiff is the biological mother of Defendant, Amy Brenizer; and
WHEREAS, Plaintiff is the matemal grandmother of the children at issue; and
WHEREAS, Amy Brenizer and Shawn Freeman are currently subject to a Court Order
dated April 18, 2001, attached hereto and incorporated by reference as Exhibit 'A'; and
WHEREAS, the parties wish to enter into an agreement relative to custody and partial
custody of the children.
NOW THEREFORE, in consideration of the mutual covenants, promises, and
agreements as hereinafter set forth, the parties agree as follows:
1. Grandmother and Mother shall have shared legal custody of the children.
2. Grandmother shall maintain primary physical custody of the children.
3. Mother shall enjoy periods of partial physical custody at such times as mutually
agreed to by Mother and Grandmother.
4. Father shall enjoy periods of partial physical custody and/or visitation at such
times as mutually agreed to between Father and Grandmother.
5. Any modification or waiver of any of the provisions of this Agreement shall be
effective only if made in writing and only if executed with the same formality as this Stipulation
and Agreement.
6. The parties desire that this Stipulation and Agreement be made an Order of the
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 children
at issue who have resided in Cumberland County for more than six months, and shall retain such
jurisdiction should circumstances change and any party desires or requires modification of said
Order.
2
7. 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 duress or undue influence.
IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms
hereof set forth their signatures the day and year written below.
Rebecca J. Rich~e,'Granlmoth~er'
DATE S~a'wn Freeman, Father
ORDER OF COURT
AND NOW, this ~ [~ day of ~e ~ s-u ~ n , ~1, upon presentation and
consideration of the above Custody Stipulation ~d Agreement it is hereby ordered ~d directed
that it be entered as ~ Order of Com.
BY THECOURT,