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HomeMy WebLinkAbout02-0918Shannon (3. Heinbaugh, Plaintiff Christopher S. Heinbaugh, Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02- (~ I<~ CIVIL TERM · CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Shannon G. Heinbaugh, an adult individual whose residence is at 20 Hays Grove Road, Newville, Cumberland County, Pennsylvania. 2. Defendant is Christopher S· Heinbaugh, an adult individual whose residence is at 419 Factory Street, Carlisle, Cumberland County, Pennsylvania. 3. On February 15, 2002, Plaintiff and Defendant have entered into a Stipulation of Custody of their child Courtney Nicole Heinbuagh, born January 9, 2000, currently residing at 20 Hays Grove Road, Newville, Pennsylvania. A copy of said Stipulation is attached hereto (as Exhibit A) and incorporated herein by reference. WHEREFORE, Plaintiff requests your Honorable Court to enter a Court Order in accordance with the Parties' Stipulation. Respectfully Submitted TURO LAW OFFICES Date Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff Shannon G. Heinbaugh, Plaintiff Christopher S. Heinbaugh, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA 'NO. · CIVIL ACTION - CUSTODY CUSTODY STIPULATION AND NOW, this 15th day of February, 2002, it is hereby stipulated and agreed between the parties as follows: 1. Courtney Nicole Heinbaugh, born January 9, 2000 is the natural child of Shannon G. Heinbaugh and Christopher S. Heinbaugh. 2. Shared legal custody of the child as contemplated by the Act of October 30, 1985, P.L. 264, 23 P.S. §5301, et seq., will be in both of the parties, as the natural parents. 3. Primary physical custody of the child shall be in the mother subject to the following periods of partial custody with the father: Every other weekend from Friday at 7:00 p.m. through Sunday at 7:00 p.m. b. Alternating holidays from 9:00 a.m. to 7:00 p.m. The holidays shall be New YeaYs Day, Memorial Day, 4th of July, Labor Day and Thanksgiving Day, with the father having custody on Memorial Day 2002. c. The parties shall alternate the Christmas holiday. The father shall have custody of the child from 2:00 p.m. Christmas Eve until 2:00 p.m. Christmas Day in odd numbered years and the mother shall have this period in even numbered years. The mother shall have custody of the child from 2:00 p.m. Christmas Day until 2:00 p.m. December 26 in odd numbered years and the father shall have this period in even numbered years. d. The parties shall split the Easter Holiday with mother having the child from 9:00 a.m. to 2:00 p.m. in even numbered years and from 2:00 p.m. to 7:00 p.m. in odd numbered years; and the father shall have the child from 9:00 a.m. to 2:00 p.m. in odd numbered years and from 2:00 p.m. to 7:00 p.m. in even numbered years e. Mother shall have physical custody from 9:00 a.m. until 7:00 p.m. on Mother's Day and Father shall have physical custody from 9:00 a.m. until 7:00 p.m. on Father's Day. f. And other such times as the parties may mutually agree. 4. Neither party shall remove the child beyond a hundred mile radius from the child's home without informing the non-custodial party of where the child will be and a telephone number for contact in case of emergencies. 5. Whereas the child is asthmatic, neither party shall allow anyone to smoke in the child's presence. 6. The party receiving custody shall provide transportation from the custodial parent's residence. The party receiving custody shall forfeit his right to custody on any period if he or she shall arrive more than 30 minutes late for the transfer of custody without prior notification to the custodial parent. 7. The exchange of custody shall occur at the custodial parent's residence unless other arrangements are made and agreed to by both parties for an alternate place for the exchange of custody. 8. The custodial parent shall inform the non-custodial parent immediately of all medical appointments and problems pertaining to the child. 9. Neither parent shall do or say anything which may estrange the child from the other parent, injure the opinion of the child as to the other parent or hamper the free and natural development of the child's love and respect for the other parent. 10. The custodial parent shall provide copies of the child's report card and other reasonable papers affecting the child's education, medical condition, or welfare. Date Shannon G. Heinbaugh, Plaintiff Christopher S. Heinbaugh, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ~ - ?/'~> : CIVIL ACTION - CUSTODY : ORDER OF COURT AND NOW, this of the within Stipulation, it is hereby order that: ~IL day of ~r~a~ between the parties as follows: ,2002, upon consideration 1. Courtney Nicole Heinbaugh, born January 9, 2000 is the natural child ol Shannon G. Heinbaugh and Christopher S. Heinbaugh. 2. Shared legal custody of the child as contemplated by the Act of October 30, 1985, P.L. 264, 23 P.S. §5301, et seq., will be in both of the parties, as the natural parents. 3. Primary physical custody of the child shall be in the mother subject to the following periods of partial custody with the father: Every other weekend from Friday at 7:00 p.m. through Sunday at 7:00 p.m. b. Alternating holidays from 9:00 a.m. to 7:00 p.m. The holidays shall be New Year's Day, Memorial Day, 4th of July, Labor Day and Thanksgiving Day, with the father having custody on Memorial Day 2002. c. The parties shall alternate the Christmas holiday. The father shall have custody of the child from 2:00 p.m. Christmas Eve until 2:00 p.m. Christmas Day in odd numbered years and the mother shall have this period in even numbered years. The mother shall have custody of the child from 2:00 p.m. Christmas Day until 2:00 p.m. December 26 in odd numbered years and the father shall have this period in even numbered years. d. The parties shall split the Easter Holiday with mother having the child from 9:00 a.m. to 2:00 p.m. in even numbered years and from 2:00 p.m. to 7:00 p.m. in odd numbered years; and the father shall have the child from 9:00 a.m. to 2:00 p.m. in odd numbered years and from 2:00 p.m. to 7:00 p.m. in even numbered years e. Mother shall have physical custody from 9:00 a.m. until 7:00 p.m. on Mother's Day and Father shall have physical custody from 9:00 a.m. until 7:00 p.m. on Father's Day. f, And other such times as the parties may mutually agree. 4. Neither party shall remove the child beyond a hundred mile radius from the child's home without informing the non-custodial party of where the child will be and a telephone number for contact in case of emergencies. 5. Whereas the child is asthmatic, neither party shall allow anyone to smoke in the child's presence. 6. The party receiving custody shall provide transportation from the custodial parent's residence. The party receiving custody shall forfeit his right to custody on any period if he or she shall arrive more than 30 minutes late for the transfer of custody without prior notification to the custodial parent. 7. The exchange of custody shall occur at the custodial parent's residence, unless other arrangements are made and agreed to by both parties for an alternate place for the exchange of custody. 8. The custodial parent shall inform the non-custodial parent immediately of all medical appointments and problems pertaining to the child. 9. Neither parent shall do or say anything which may estrange the child from the other parent, injure the opinion of the child as to the other parent or hamper the free and natural development of the child's love and respect for the other parent. 10. The custodial parent shall provide copies of the child's report card and other reasonable papers affecting the child's education, medical condition, or welfare. BY THE COURT,