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HomeMy WebLinkAbout04-5645 ANN MARIE WILSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. C>LI -~4S Ct~~L T~ CRAIG ALLEN WILSON, Defendant CIVIL ACTION - LA W IN CUSTODY COMPLNNTFORCUSTODY 1. The Plaintiff is Ann Marie Wilson, an adult individual, who resides at 2270 Tonto Avenue, Auburn, Schuylkill County, Pennsylvania 17299. 2. The Defendant is Craig A. Wilson, an adult individual, who resides at 119 Cricket Lane, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff seeks primary custody of the following child: Name Present Residence Age Jeffrey C. Wilson 119 Cricket Lane Camp Hill, P A 17011 15 4. The child was not born out of wedlock. 5. The child is presently in the custody of Defendant Craig A. Wilson, who resides at 119 Cricket Lane, Camp Hill, PA 17011. 6. During the past five years, the child has resided with the following persons and at the following addresses: Custodians Addresses Dates Craig A. Wilson Ann Marie Wilson 119 Cricket Lane Camp Hill. PA 17011 November 1, 1999 to May 1. 2004 Craig A. Wilson 119 Cricket Lane Camp Hill, PA 17011 May 1,2004 to Present 7. The mother of the child is Ann Marie Wilson, currently residing at 2270 Tonto Avenue, Auburn, PA 17299. The mother is married to the father, Craig A. Wilson. 8. The father of the child is Craig A. Wilson, currently residing at 119 Cricket Lane, Camp Hill, P A 17011. 9. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 10. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 11. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. 12. The best interest and welfare of the child will be served by granting the relief requested because: a) Plaintiff is better able to provide for, care for, and love the child, b) Plaintiff can provide a loving and safe environment for the child, and c) The child wants to live with his mother 13. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as Parties to this action. WHEREFORE, Plaintiff requests the Court to grant custody of the child to her. November 5, 2004 ~~~~ Peter B. Foster, Esquire Attorney for Plaintiff Pinskey & Foster 114 South Street Harrisburg, P A 17101 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. ~ 4904 relating to unsworn falsification to authorities. November 5, 2004 G/u 1/J1, ,/ ~kJ Ann Marie W~l~~' N (:j ~ 1- """- #- -- \) ........ ---- B ~ ~ ~ "'l f[! ~ () r--.." € ~'~ c>';) 0 c.:'}. ~",:~>;'i ...t:.~'" -n :;~ :y3 c.~ -.::: /,"j ::D '."'j r'- I .;JfTl '. tiJ :I'J? j" i ! () " """1-, ~;:f] , .. 3: "'.). ,. ~ () ~", "11 . .. \. ..J =2 .-:--i 0 .",~ ~;J Q ....<: ANN MARIE WILSON PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 04-5645 CIVIL ACTION LA W CRAIG ALLEN WILSON DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, November 16,2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, P A 17043 on Monday, December 20, 2004 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or ifthis cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearine. FOR THE COURT. By: /s/ Meh"ssa P. Greevy. Esq. Custody Conciliator mhc The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~ p ;E ~ ~>1t? -/Je-J/ .~ ~ -7 ~ ~u, A{?:.je.// ~~ r fl!. 'pT~ ~?~ AO'>llJ'./1 VH\j\il\1\SNr~3d ""'-". ~,-~" ""-,un"" AlN. ;1;'.; ':- ,H. ~-;/\f oJ r. 8 : II WV ~2 liON ~DOl Il.MIONOHIOUd 3Hl :10 A'..lV !:::1-U 388;10-0.:1 b } Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-5645 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ANN MARIE WILSON, v. CRAIG ALLEN WILSON, Defendant INTERIM ORDER OF COLlRT AND NOW, this 2..1 day of January, 2005, upon consideration of the attached Custody Conciliation Summqry Report, it is hereby ordered and directed as follows: 1. Leaal CustodY. The parties, Ann Marie Wilson and Craig Allen Wilson, shall have shared legal custody of the minor child, Jeffrey C. Wilson, born December 30, 1988. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's gElneral well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa. C. S. 95309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical CustodY. Father shall have temporary primary physical custody subject to Mother's rights of partial custody which shall occur on two weekends per month. A weekend period of custody shall be defined as that period of Friday evening at 6:00 p.m. until Sunday evening at 6:00 p.m. However, the parties may agree otherwise, in light of the child's sport and work schedule. Mother's first custodial weekend shall occur January 21, 2005. 3. Transportation. Mother shall provide transportation incident to the custodial exchange at the beginning of her custodial period. The parties shall meet for the Sunday evening custodial exchange at the State Police Barracks off of 1-81, Exit 77. 4. Holidays. Mother will have custody for Easter 2005. Father will have custody for Memorial Day 2005. The custodial period for these hOlidays shall be from 6:00 p.m. the day before the holiday until 6:00 p.m. on the holiday itself. NO. 04-5645 CIVIL TERM 5. A hearinl'l is scheduled in-.9~ Numb'9r ~ of the Cumberland County Courthouse, on the 'Bu day of . . .' 2005, at 1/. 30 o'clock -p"'.M., at which time testimony will be taken. For the purposes of the hearing, the Mother, Ann Marie Wilson, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties or the parties pro se shall file with the Court and opposing counsel/party a memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These memoranda shall be filed at least ten days prior to the hearing date. /' "- ./ BY THI;COURT: /i '~7 ~<lV' / J. I Dist ~ter B. Foster, Esquire, 114 South Street, Harrisburg, PA 17101 v-Maria P. Cognelti, Esquire, 210 Grandview Avenue, Suite 102, Camp Hill, PA 17011 ~Lr~ ~ OJ -J5i'-O~ " f~_l1<t)C"---- \ O I .j-, I!! L" 1."1' nail' .'1 l,r~: (, n~t '.:!. -1.1(, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-5645 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ANN MARIE WILSON, v. CRAIG ALLEN WILSON, Defendant CUSTODY CONCilIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVil PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Jeffrey C. Wilson December 30, 1988 Father 2. A Custody Conciliation Conference was held on January 7, 2005, with the following individuals in attendance: the Mother, Anne Marie Wilson, and her counsel, Peter B. Foster, Esquire; the Father, Craig Allen Wilson, and his counsel, Maria P. Cognetti, Esquire. 3. The parties reached an Interim Order in the form as attached, pending hearing. 4. Mother's position on custody is as follows: Mother reports the child wants to live with her. She believes that she is better able to provide, for the child than is Father. She believes that she can provide more supervision than can Falther. She also thinks the child is not getting along well with Father. Mother is concerned that the child is presently attending Cedar Cliff High School in the West Shore School District which is utilizing an intensive scheduling model for classes. This model makes class timEl much longer than in her school district where classes are 40 minutes in duration. She believes that a shorter class duration will help the child to do better in school. 5. Father's position on custody is as follows: F<~ther reports the child does not want to leave the school that he is attending because he has been in the same school district for a lengthy period of time and does not want to leave a familiar environment and his friends. Further, Father believes the child wants to reside with him. Father reports the child is doing as well in school as he has ever done and does not see the intensive scheduling as a problem. The child is presently working part-time for Giant Food Store and plays soccer. NO. 04-5645 CIVIL TERM Due to Mother's history of parent this child. I J ~i)1 Date / ;242644 emical dependency, Fath(~r sees himself as better suited to \ Jj'~[9-f ~lissa Peel Greevy, Esquire Custody Conciliator "" ANN M. WILSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-5645 CIVIL TERM ~RAIG A. WILSON, Defendant CIVIL ACTION - LAW IN CUSTODY PLAINTIFF'S MOTION TO IMPLEMENT CUSTODY AGREEMENT AND NOW, this 6th day of May, 2005, comes Plaintiff Ann Marie Wilson, by her ttorney, Peter B. Foster, Esquire, and moves to have the Court implement the Parties' Custody greement and, in support thereof, avers, as follows: 1. On April 18, 2005, a Custody Hearing was scheduled relative to custody of the larties' minor child, Jeffrey C. Wilson. 2.. Prior to said Hearing on April 18, 2005, the Parties verbally agreed to a custody ~angement for Jeffrey in settling said dispute. , 3. On April 18,2005, the Court instructed the Parties to work out a written custody tipulation pursuant to said agreement and submit said stipulation with a court order for the ourt's endorsement. I 4. Plaintiff Ann Marie Wilson believes and avers that the Parties have verbally rgreed on all the terms of an agreement regarding custody of Jeffrey Wilson. I 5. However, eighteen days have passed since said verbal agreement was reached and o written stipulation regarding said agreement has been entered into by the Parties, as the Court equested. 6. Plaintiff believes that the attached Stipulation for Custody, marked Exhibit "A," mbodies all the terms of the Parties' said verbal custody agreement. WHEREFORE, Plaintiff Ann Marie Wilson respectfully requests this Honorable Court to implement said Stipulation for Custody by adopting it entirely and incorporating it into a court (Jrder. Respectfully submitted, I' 6, 2005 I I I I ~~ ~,~~( Peter B. Foster, Esquire Attorney for Plaintiff Pinskey & Foster 114 South Street Harrisburg, PA 17101 (717) 234-9321 ANN M. WILSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-5645 CIVIL TERM CRAIG A. WILSON, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT . AND NOW, to wit, this day of ,2005, it is hereby I I pRDERED and DECREED that the attached Stipulation for Custody is made an Order of this Fourt and said Stipulation is adopted in its entirety and incorporated herein as an Order of Court. BY THE COURT: J. Exhibit "A" . ANN M. WILSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-5645 CIVIL TERM CRAIG A. WILSON, Defendant CIVIL ACTION - LAW IN CUSTODY STIPULATION FOR CUSTODY AND NOW, this day of , 2005, the parties having been , I ~dvised of their rights by their respective counsel, and having the best interests of their minor ~hild, Jeffrey C. Wilson, born December 30, I988, in mind, do hereby agree and stipulate as , ~ollows: , ! 1. The parties hereby agree to share legal custody of the minor child. All decisions I fffecting the child's growth and development including, but not limited to: choice of day care ~rovider; medical and dental treatment; psychotherapy, psychoanalysis or like treatment; I ~ecisions relating to actual or potential litigation involving the child, directly or as beneticiary, , , pther than custody litigation; and, education, both secular and religious, shall be considered I rajor decisions and shall be made by the parties jointly, after discussion and consultation with bach other and with a view toward obtaining and following a harmonious policy in the child's I ~est interest. , 2. Defendant, Craig A. Wilson (hereinafter referred to as "Father") shall continue to ~ave primary physical custody of the minor child through the start of the 2005-2006 school year ~n early September, 2005. i I I I I rave partial physical custody ofthe child on alternating weekends according to the current fchedule until said time referred to in Paragraph 2 of this Stipulation. I , ! I i I , , 3. Plaintiff, Ann M. Wilson (hereinafter referred to as "Mother") shall continue to , 4. Following the close of the 2004-2005 school year, Jeffrey shall spend the first two weeks with Father, the next week with Mother, and then continue this two week lone week i . pattern for the remamder of the summer. Custody shall change, for these purposes, on Sunday ~venings at 6:00 p.m. I 5. Beginning with the school year 2005-2006, Mother shall have primary physical ustody ofthe child. 6. Beginning with the school year 2005-2006, Father shall have partial physical ustody of the child on alternate weekends, from Friday at 6:00 p.m. through Sunday at 6:00 .m. 7. Mother shall have custody of the minor child on Mother's Day and Father shall ustody of the minor child on Father's Day. The custodial period on these days shall run from :00 a.m. through 9:00 p.m. 8. The parties shall alternate the holidays of Easter, Memorial Day, Fourth of July, abor Day and Thanksgiving. The custodial period shall run from 9:00 a.m. on the day ofthe oliday through 9:00 p.m. that same day. This schedule shall begin with Father having custody fthe minor child on Memorial Day 2005, and Labor Day 2005, and Mother having custody on he Fourth of July 2005 and Thanksgiving 2005. In 2006, Father shall have Easter, Fourth of uly and Thanksgiving, and Mother shall have Memorial Day and Labor Day. The holidays will ontinue to alternate in this fashion thereafter. 9. The Christmas holiday shall be divided into two (2) Segments. Segment A shall e defined as beginning on December 24 at 12:00 noon and ending on December 25 at 12:00 oon. Segment B shall be defined as beginning on December 25 at 12:00 noon and ending on ecember 26 at 12:00 noon. The parties will alternate custody of the minor child for these '. Segments and the schedule will begin with Father having custody of the minor child for Segment A in 2005 and Mother having custody of the minor child for Segment Bin 2005. In 2006, the : parties would alternate their Segments so that Mother has Segment A and Father has Segment B and this alternating of Segments shall continue in this same manner thereafter. 10. The parties agree that the holiday schedule enumerated above takes precedence over the normal custody schedule. II. Mother shall provide transportation incident to the custodial exchanges at the I I Ibeginning of her custodial periods. The parties shall meet at the State Police Barracks off ofI- 81, Exit 77, for the start of Father's periods of custody. 12. The parties agree that Jeffrey shall attend counseling with Psychologist Jose Delerme, Pinnacle Health Behavioral Services, 307 South Front Street, Harrisburg, P A. This counseling is for the purpose of improving Jeffrey's relationship with Father and curing Jeffrey's Idepression. Mother shall provide transportation for Jeffrey, to these sessions, if they occur during her periods of custody. Mother agrees to be responsible for facilitating these counseling sessions and insuring Jeffrey's attendance thereat. The parties agree to share the costs of said ounseIing. Mother is only responsible for her share of said counseling costs as long as the reating psychologist is included under her employer's health insurance plan and said costs are aid under this plan. 13. The parties agree that because Mother is called to work at Pottsville Hospital on hort notice and at unusual times, she will not always be able to comply with the custody xchange schedules set forth in this Stipulation. Mother agrees to give Father at least two hours dvance notice of any change in said custody exchange schedules due to her employment. . 1 14. The parties acknowledge that this Stipulation is not the result of any duress or undue influence in that this Stipulation is being entered into freely and voluntarily after having received legal advice from their respective counsel. 15. The parties further agree that this Stipulation shall be entered as an Order of Court. As such, this Stipulation shall have the same full force and effect as if this matter had been tried and decided. 16. This Stipulation and Order of Court shall replace and supersede any existing custody arrangements between the parties. \ 17. This Stipulation and Order of Court shall continue in full force and effect until I [further Order of Court or an amended agreement in writing between the parties. I I 18. The parties hereby waive their respective rights to present this agreement in open I Icourt or to have their case heard by the court at this time. I I IN WITNESS WHEREOF, the parties hereto have set their hands and seals the date and ~ear first above written. I I ~itness I I \ ~itness I I I I I I ANN MARIE WILSON CRAIG ALLEN WILSON . , CERTIFICATE OF SERVICE I hereby certify that on this date, May 6, 2005, I served a copy of the foregoing Motion to Implement Custody Agreement on the Defendant by mailing said copy by first class mail at Harrisburg, P A to the attorney for Defendant at the following address: Maria P. Cognetti, Esquire 210 Grandview Avenue, Suite 102 Camp Hill, P A 17011 6,2005 ~ b-~{ Peter B. Foster, Esquire Attorney for Plaintiff C) t--:J C;:l ," " C..i1 -- .-.,; i G' "1 , ~, tv o -" ::;:! n'l :TI r- \~~! (;~) --') ,Ti ~ J~ RECEIVED MAY 09 200S }. *' ANN M. WILSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-5645 CIVIL TERM CRAIG A. WILSON, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, this to day of May, 2005, upon consideration of Plaintiff Ann Marie Wilson's Motion to Implement Custody Agreement, a Rule is hereby issued upon Defendant Craig A. Wilson to show cause why said Motion should not be granted. lo-~ (~ Rule returnable within j ("7 days of service~ BY THECOURT: ;/ ( J. ~ ~ ~cJ ':)\ D r"~ '1'- V, FIU.I THE p:': <')nT,'" ",. ',I ! 0 dJ~ t,;." 3~53 ,. ~ ANN M. WILSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-5645 CIVIL TERM CRAIG A. WILSON, Defendant CIVIL ACTION - LA W IN CUSTODY STIPULATION FOR CUSTODY AND NOW, this day of , 2005, the parties having been advised of their rights by their respective counsel, and having the best interests of their minor child, Jeffrey C. Wilson, born December 30, I988, in mind, do hereby agree and stipulate as follows: 1. The parties hereby agree to share legal custody of the minor child. All decisions effecting the child's growth and development including, but not limited to: choice of day care provider; medical and dental treatment; psychotherapy, psychoanalysis or like treatment; decisions relating to actual or potential litigation involving the child, directly or as beneficiary, other than custody litigation; and, education, both secular and religious, shall be considered major decisions and shall be made by the parties jointly, after discussion and consultation with each other and with a view toward obtaining and following a harmonious policy in the child's best interest. 2. Defendant, Craig A. Wilson (hereinafter referred to as "Father") shall continue to have primary physical custody of the minor child through the start of the 2005-2006 school year in early September, 2005. 3. Plaintiff, Ann M. Wilson (hereinafter referred to as "Mother") shall continue to have partial physical custody of the child on alternating weekends according to the current schedule until said time referred to in Paragraph 2 ofthis Stipulation. ... . . 4. Following the close of the 2004-2005 schoo] year, Jeffrey shall spend the first two weeks with Father, the next week with Mother, and then continue this two week lone week pattern for the remainder of the summer. Custody shall change, for these purposes, on Sunday evenings at 6:00 p.m. 5. Beginning with the school year 2005-2006, Mother shall have primary physical custody of the child. 6. Beginning with the schoo] year 2005-2006, Father shall have partial physical custody ofthe child on alternate weekends, from Friday at 6:00 p.m. through Sunday at 6:00 p.m. 7. Mother shall have custody of the minor child on Mother's Day and Father shall custody of the minor child on Father's Day. The custodial period on these days shall nm from 9:00 a.m. through 9:00 p.m. 8. The parties shall alternate the holidays of Easter, Memorial Day, Fourth of July, Labor Day and Thanksgiving. The custodia] period shall run from 9:00 a.m. on the day of the holiday through 9:00 p.m. that same day. This schedule shall begin with Father having custody of the minor child on Memoria] Day 2005, and Labor Day 2005, and Mother having custody on the Fourth of July 2005 and Thanksgiving 2005. In 2006, Father shall have Easter, Fourth of July and Thanksgiving, and Mother shall have Memorial Day and Labor Day. The holidays will continue to alternate in this fashion thereafter. 9. The Christmas holiday shall be divided into two (2) Segments. Segment A shall be defined as beginning on December 24 at ]2:00 noon and ending on December 25 at 12:00 noon. Segment B shall be defined as beginning on December 25 at ]2:00 noon and ending on December 26 at ]2:00 noon. The parties will alternate custody of the minor child for these .t . . .- ~ Segments and the schedule will begin with Father having custody of the minor child for Segment A in 2005 and Mother having custody of the minor child for Segment Bin 2005. In 2006, the parties would alternate their Segments so that Mother has Segment A and Father has Segment B and this alternating of Segments shall continue in this same manner thereafter. 10. The parties agree that the holiday schedule enumerated above takes precedence over the normal custody schedule. 1 I. Mother shall provide transportation incident to the custodial exchanges at the beginning of her custodial periods. The parties shall meet at the State Police Barracks off ofT- 81, Exit 77, for the start of Father's periods of custody. 12. The parties agree that Jeffrey shall attend counseling with Psychologist Jose Delerme, Pinnacle Health Behavioral Services, 307 South Front Street, Harrisburg, PA. This counseling is for the purpose of improving Jeffrey's relationship with Father and curing Jeffrey's depression. Mother shall provide transportation for Jeffrey, to these sessions, ifthey occur during her periods of custody. Mother agrees to be responsible for facilitating these counseling sessions and insuring Jeffrey's attendance thereat. The parties agree to share the costs of said counseling. Mother is only responsible for her share of said counseling costs as long as the treating psychologist is included under her employer's health insurance plan. Psychologist Delerme is covered under Mrs. Wilson's health insurance plan with her employer, Pottsville Hospital. If the parties jointly decide to change psychologists for Jeffrey, Father agrees to a new treating psychologist covered by Mother's employers' health insurance plan. 13. The parties agree that because Mother is called to work at Pottsville Hospital on short notice and at unusual times, she will not always be able to comply with the custody J. ~ _. ..T\,t exchange schedules set forth in this Stipulation. Mother agrees to give Father at lea~t two hours advance notice of any change in said custody exchange schedules due to her employment. 14. The parties acknowledge that this Stipulation is not the result of any duress or undue influence in that this Stipulation is being entered into freely and voluntarily alter having received legal advice from their respective counsel. 15. The parties further agree that this Stipulation shall be entered as an Order of Court. As such, this Stipulation shall have the same full force and effect as if this matter had been tried and decided. 16. This Stipulation and Order of Court shall replace and supersede any existing custody arrangements between the parties. 17. This Stipulation and Order of Court shall continue in full force and effect until further Order of Court or an amended agreement in writing between the parties. 18. The parties hereby waive their respective rights to present this agreement in open court or to have their case heard by the court at this time. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the date and year first above written. ~~c~ ANC}t71 l/(If;t UiiJ A MARIE WI SON Witness \ ~ I; f "\. JL)(.~ IG ALLEN WILSON Lc.. ".' " l .. .,.. y RECEIVED MAY 252005 ANN M. WILSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-5645 CIVIL TERM CRAIG A. WILSON, Defendant CIVIL ACTION - LA W IN CUSTODY ORDER OF COURT ~ ,2005, it is hereby "- ORDERED and DECREED that the attached Stipulation for Custody is made an Order of this AND NOW, to wit, this "2-Jo day of Court and said Stipulation is adopted in its entirety and incorporated herein as an Order of Court. / J. BY THE eoURT: / / I~ L ----- r:c::> '"J .-~._....,.....--,-----~--~