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HomeMy WebLinkAbout01-5001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HEATHER A. WINERITER : Plaintiff, : VS. : : RANDALL S. WlNERITER : Defendant. : CIVIL ACTION- LAW NO. cO/_ I F';¢,' I CUSTODY STIPULATION AND AGREEMENT FOR CUSTODY The Plaintiff is Heather A. Wineriter, presently residing at 8013 Scenic Drive, Shippensburg, Franklin County, Pennsylvania 17257. The Defendant is Randall S. Wineriter, presently residing at 577 South Mountain Estate Road, Shippensburg, Southampton Township, Cumberland County, Pennsylvania 17257. Plaintiff seeks custody of the following children: NAME PRESENT RESIDENCE Jordan Margaret Wineriter 8013 Scenic Drive Shippensburg, PA 17257 Madison Iris Wineriter 8013 Scenic Drive Shippensburg, PA 17257 AGE DATE OF BIRTH 3 years June 15, 1998 3 years June 15, 1998 The children were not bom out of wedlock. The children are presently in the custody of Mother, who resides at 8013 Scenic Drive, Shippensburg, Pennsylvania 17257. During the past five years, the children have resided with the following persons and at the following addresses: NAME Heather Wineriter Carol Gimmi (grandmother) Robert Gimmi (grandfather) Alex Gimmi (sister) ADDRESS 8066 Scenic Drive Shippensburg, PA 17257 DATE Birth to December 1998 Randall Wineriter Heather Wineriter Alex Gimmi (sister) 6100 East Rancier Ave, Lot 363 Killeen, TX 76543 December 1998 to April 2000 Randall Wineriter Heather Wineriter Alex Gimmi (sister) 577 South Mountain Estate Road Shippensburg, PA 17257 April 2000 to February 2001 Heather Wineriter Carol Gimmi Robert Gimmi Alex Gimmi 8066 Scenic Drive Shippensburg, PA 17257 March 2001 to April 2001 Heather Wineriter 8013 Scenic Drive April 2001 to Alex Gimmi Shippensburg, PA 17257 Present The mother of the children is Heather A. Wineriter, currently residing at 8013 Scenic Drive, Shippensburg, Pennsylvania 17257. She is married. The father of the children is Randall S. Wineriter, currently residing at 577 South Mountain Estate Road, Shippensburg, Pennsylvania. He is married. The relationship of Plaintiff to the children is that of mother. The Plaintiff currently resides with the following persons: NAME Jordan M. Wineriter Madison I. Wineriter Alexandria Gimmi RELATIONSHIP Daughter from this marriage Daughter from this marriage Daughter from previous relationship The relationship of Defendant to the children is that of father. The Defendant currently resides with the following persons: NAME RELATIONSHIP Self only Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person, not a party to the proceedings, who has physical custody of the children or claims to have custody or visitation rights with respect to the children. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene: NAME ADDRESS BASIS OF CLAIM None The parties have reached an agreement with regard to the custody of the children and desire to reduce their agreement to an Order of Court. NOW THEREFORE, the parties intending to be legally bound and waiving their right to be present when this Agreement and Order are presented and executed hereby stipulate and agree that the Court may enter the following Order of Court in the above-captioned case: ORDER OF COURT NOW, , 2001, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: Legal custody of the minor child, Jordan M. Wineriter, born June 15, 1998, and Madison I. Wineriter, born June 15, 1998, shall be shared by Randall S. Wineriter (hereinafter referred to as "Father") and Heather A. Wineriter (hereinafter referred to as "Mother"). Primary physical custody of the minor children shall be with Mother. Father shall exercise partial custody of the minor children from Friday afternoon until the following Monday morning except on the weekend of the third (3rd) Saturday of the month. 3rd S On the weekend of the third ( ) aturday of each month, Mother shall exercise partial custody from Friday afternoon until the following Monday morning. Father shall exercise partial custody at such other times as the parties from time to time may mutually agree. WEIGLE, PERKINS & ASSOCIATES David P. Perkins, Esquire Attorney for Plaintiff I.D.#34342 126 East King Street Shippensburg, PA 17257 Telephone 71%532-7388 The parties further agree that, in procuring this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other. IN WITNESS WHEREOF, the parties, intending to be bound by the terms and conditions of this agreement, execute this Agreement by signing below. Witness Witness I- F~EATHER A~. WIN~RITER I verify that the statements made in this Stipulation and Agreement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. HEATHER .~. WINERITER I verify that the statements made in this Stipulation and Agreement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to falsification to authorities. Dated: RANDALL S. WINERITER MARK, WEIGLE AND PERKINS, ATTORNEYS AT LAW 126 EAST KING STREET, SHIPPENSBURG, PE~A. 17257 T~LE~'HOnE: (717) 532-7388 FAX: (717) 532-6552 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HEATHER A. WINERITER Plaintiff, VS. RANDALL S. WINERITER Defendant. CIVIL ACTION - LAW NO. ~) CUSTODY NOW, ~ Agreement, it is hereby ordered as ORDER OF COURT ,2001, upon consideration of the within Stipulation and tbllows: Legal custody of the minor child, Jordan M. Wineriter, bom June 15, 1998, and Madison l. Wineriter, born June 15, 1998, shall be shared by Randall S. Wineriter (hereinafter referred to as "Father") and Heather A. Wineriter (hereinafter referred to as "Mother"). Primary physical custody of the minor children shall be with Mother. Father shall exercise partial custody of the minor children from Friday afternoon until the following Monday morning except on the weekend of the third (3rd) Saturday of the month. On the weekend of the third (3fa) Saturday of each month, Mother shall exercise partial custody from Friday afternoon until the following Monday morning. Father shall exercise partial custody at such other times as the parties from time to time may mutually agree.