HomeMy WebLinkAbout05-2662
CHRISTINA D. WRIGHT,
Plaintiff,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
~ NO. 0 S - <RJg' '--
~ -Jsvv-....
SHANNON P. WRIGHT,
Defendant
: CIVIL ACTION - LAW
: CUSTODY
COMPLAINT FOR CUSTODY
AND NOW, comes Petitioner, Christina D, Wright, by and through her attorney, Mark A.
Mateya, and respectfully represents:
I, The Plaintiffis Christina D. Wright, who presently resides at 1170 Redwood Drive,
Carlisle, Cumberland County, Pennsylvania, 17013,
2, The Defendant is Shannon P. Wright, presently residing at 530 Bedford Court,
Mechanicsburg, Cumberland County, Pennsylvania.
3, Plaintiff seeks custody of the following child:
Name
Present Residence
Age D/O/B
Nathan A. Wright
1170 Redwood Drive
Carlisle, P A 17013
9 Yrs 6/1/95
4. The child was born out of wedlock.
5, The child is presently in the custody of Christina D. Wright, who presently resides
at 1170 Redwood Drive, Carlisle, Cumberland County, Pennsylvania 17013.
6, During the past five (5) years the child has resided with the following persons at the
following addresses:
a, With Plaintiff and Defendant, at 1170 Redwood Drive, Carlisle, Cumberland
County, Pennsylvania 17013.
7. The mother of the child, Christina D. Wright, is currently residing at 1170 Redwood
Drive, Carlisle, Cumberland County, Pennsylvania, and she is married.
8. The father of the child is Shannon P. Wright, who is currently residing at 530 Bedford
Court, Mechanicsburg, Cumberland County, Pennsylvania 17013 and he is married.
9, The relationship of the Plaintiff to the child is that of natural mother. The Plaintiff
currently resides with the minor child Nathan A. Wright.
10, The relationship of the Defendant to the child is that of natural father. The defendant
currently resides with his mother,
11. The 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 any other Court.
12, Plaintiffhas no information of a custody proceeding concerning the child pending in
any Court of this Commonwealth or any other state,
13, Plaintiff does not know of a person not a party to the proceeding who has physical
custody ofthe child or claims to have custody or visitation rights with respect to the child.
14, The best interest and permanent welfare of the child will be served by granting the
relief requested because:
a. Plaintiff is the mother of the child;
b. Plaintiff has been involved in the raising of the child from the time of the
child's birth to the present;
c, Plaintiff is able to provide a stable home for the child.
d. Plaintiff is fully employed and able to provide economically for the child.
e. Plaintiff and Defendant informally agreed to share custody of the child.
- 2 -
WHEREFORE, Plaintiff requests this Honorable Court to schedule a custody
conciliation conference between the parties at the court's earliest convenience.
Respectfully submitted,
Dated:
s I~I()S-
'fl,v1A , ln~
Mark A. Mateya
Attorney I.D. No. 78931
P.Q, Box 127
Boiling Springs P A 17007
(717) 241-6500
Attorney for Plaintiff
- 3 -
VERIFICATION
I, CHRISTINA D, WRIGHT, verifY that the facts set forth in the foregoing COMPLAINT
FOR CUSTODY are true and correct to the best of my knowledge, information, and belief. I
understand that false statements herein are subject to the penalties of 18 Pac C.S. ~4904, relating to
unsworn falsification to authorities.
" ,-'')
,-/ ".~ i
I'"~ -, "-- -......
( !Jl~Jt{ l/~ L 't;Pl
Christina D. Wright (j
DATED: 5/IL/ /(/5
I I
- 4 -
C)
(
~
~ <
-.
A () ,~
..........
'" :---..
~ .....
G 0'
-.t- )
~ ~
w '-
..J
r
~; 0
'~;:::J -1"1
~,""."l
... ::;:1
j"',,)
Co.
~
-':1
-"'.
,
-,
,
n
:-<
CHRISTINA D, WRIGHT
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v,
05-2662
CIVIL ACTION LAW
SHANNON p, WRIGHT
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Thursday, May 26, 2005 __.' upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq.
, the conciliator,
at
4th Floor, Cumberlaud Couuty Courthouse, Carlisle on
Thursday, Juue 16, 2005____ 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
if this 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 mav
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 hearing.
FOR THE COURT.
By: /s/
Hubert X Gilrov. Esq,__._~.._._
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For infonnation about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our omce. 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
HA VE 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
. wi ~ If ~ t7-r ihh; SiJ1C;-
r:h ~ /'If":" ~ 5(' 'H:' 5
~ VP 7- -r"'" Awl f"J P 1<'5
G'-'. '\' .,.
-"
-
o
CHRISTINA D. WRIGHT,
Plaintiff,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 05-2662
v.
SHANNON P. WRIGHT,
Defendant
: CIVIL ACTION - LAW
: CUSTODY
AFFIDAVIT OF SERVICE
AND NOW, this 10th day ofJune. 2005, comes Mark A. Mateya, Esquire, Attorney for
Plaintiff, who, being duly sworn according to law, deposes and says that:
I. A Complaint for Custody was filed to the above term and number on May 20, 2005.
2. On May 23, 2005, a certified copy of the Complaint in Custody was sent to the
I
Defendant via certified mail, restricted delivery, return receipt requested pursuant to Pa, R,C.P.
1920.4. A copy of the Certified Mail Receipt is attached hereto as Exhibit "A" and is incorporated
herein by reference.
3, On May 23,2005, a certified copy of the Complaint was set to the Defendant via first
class mail, postage prepaid. A copy ofthe Certificate of Mailing is attached hereto as Exhibit "B"
and is incorporated herein by reference.
.
4. On or about June 8, 2005, undersigned counsel for Plaintiff received the Certified
Mail back from the U.S. Postal Service which was marked as unclaimed. A copy of said envelope
is attached hereto as Exhibit "C" and is incorporated herein by reference.
Respectfully submitted,
~f.l;~
Attorney J.D. No. 78931
P.O. Box 127
Boiling Springs, P A 17007
(717) 241-6500
(717) 241-3099 Fax
Attorney for Plaintiff
.
.
.
IT
LIl
<<l
LIl
U.S. Postal Service,.
CERTIFIED MAIL. RECEIPT
(Domestic Mail Only; No Insurance Coverage Provided)
LIl
ru
I'T1
ru
..~~.... .,...
=r
Cl
Cl
c:J Return Reciept Fee
(Endorsemenl Required)
o Restricted DBllvery Fee
C (Endorsement RequIted}
LIl
Cl
Certified Fee
$2.30
n.75
$3.50
~ '\
'3~~
-:',~
Total Postages. Fees $ $8..15
I'T1
g Sent 0 .5 /1tJ).)OJV . 1l/IZJ6I1T
I'- ~:t;,:-:t:::::;-33D-mlJiD-Fb;?b------eouff-----'--'
Ci60:s';;;e,n'n-----iiil;i:;ii-e;,s/jis.----Pif.-.---jfji5Si)---
-"_'}-r1C'~ , j
0512311005'
EXHlsrr
I A
.
.
.
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERr'ATIONAL MAil, DOES NOT
PROVIDE FOR INSURANCE - POSTMASTER
Received From
.
Bod-IN&-
One piece of ordinary mail addressed to:
.s/~ANAiDN p t/y.f /(IBIfT
530 ]31=1> PM/> (! CtlltT
'1UE OJAV/ts'BuR. fr PA
Q
~~
~c::;)
Ul_
iSl.C
1'1 V!5C ~c::;)
PS Form 3817, Mar, 1989
EXHIBrr
1--:8
I
,
'-,-.,
,
.
"'
<>
Lt") .
III
~~
CX)<>
~g
~
o
.( ~
~~..~
~~~o:
~>,><ui
.~OO
~~g~
~'< "
~
g
<>
'"
<>
.. '
- ,
~-~~
, ,,)
,
-)
,
j
"
.... ,_.If
IT'
U1
<0
U1
U1
ru
ITl
ru
=t'
C::J
C::J
C::J
C::J
C::J
U1
c::J
ITl
c::J
c::J
f'-
.:;j
'"
1~
'" :3
,..~,~ t:;~
, ~~ti=~
'J g':ICa:LLI~
oC~~~g;
, !Zz2=L4.
,! ....,o~LLle
i j Q~:c:::w
.... u..G. .-1.-1
...... u..,=eUWIllI
~_ =14.1==..
1. U)~VJt-Z
.. !:!c~~=;'
DODD
I" <<:(.)U)
'0
,,--=,
E-t
E-tP:;";
:xl::>'"
t:!O
HUt:!
P:; P:;
~'Cl ::>
P:;1Il
~OUl
....U
:z:ClH
Orol:z:
Z~a:
Z ::::
..;oU
t:::<"lrol
Ul"'::;:
o
uJ>-
....0::
(.)uJ
->
0::-
....-'
(/)uJ
uJQ
0::
EXHIBIT
I
Q.,
o
'"
o
,...
~
j..
,
,
o
~;
v)'.
rr' ~
Z
:;?
r..;-~
::::~ \-
:S_~. t.
.;.'''(---
-<
""
C.:J
{;::,.:)
c-l~
o
-\1
.....
Ai ~~~
~J~(;-)
'-'~C~
;~~'i~
.,
~.",.
~:q
.",
c_
s;;
c.n
-"':'.'
':?
.C-
\'-.)
-
~
CHRISTINA D. WRIGHT,
Plaintiff
RECEIVED JUN 242005,1,1\
IN THE COURT OF COMMON PLEAS OF jU
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LAW
SHANNON P. WRIGHT,
NO. 05-2662
COURT ORDER
AND NOW, this Z-I' day of June, 2005, upon consideration of the attached
Custody Conciliation report, it is ordered and directed as follows:
1. The father, Shannon P. Wright, and the mother, Christina D. Wright, shall enjoy
shared legal cnstody of Nathan A. Wright, born JUBl~ 1, 1995.
2. The mother shall enjoy primary physical cnstody of the minor child.
3. The father shall enjoy liberal periods of temporary cllstody of the minor child at such
times as agreed upon by the parties.
4. In the event the father becomes dissatisfied in the future with the amount of
temporary custody provided to him with the minor child, father may at that time
petition the Court to have this case again scheduled before a Custody Conciliator for
a Conference.
BY THE COURT,
cc: Mark A Mateya, Esquire} ~
Shannon P. Wright
J
G ,) <1---.. ~rr-
:~
'Pif
/\.1,:\1
-!.}\':'-j~)
I .., .f" 11 J ,.'J Ui",r 0007
(, -0 1"\1 l(.. Hi j jlHJC.
'uv ." 'U" .'.., , "Hl '0
Au 'ill,)>\ ~"u.Uda.:lt :1
j:JI:JJO-G:lll:l
I
.
CHRISTINA D. WRIGHT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAJ"ID COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LAW
SHANNON P. WRIGHT,
Defendant
NO. 05-2662
IN CUSTODY
Prior Judge:
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF
PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following
report:
1. The pertinent information pertaining to the child who is the subject of this litigation
is as follows:
Nathan A. Wright, born June 1, 1995.
2. A Conciliation Conference was held on June 16, 2005, with the following individuals
in attendance:
The mother, Christina D. Wright, with her counsel, Mark A. Mateya, Esquire, and
the father, Shannon P. Wright, who appeared without counsel.
3. The parties agree to the entry of an Order in the foml as attached.
U ( :2 3( (j r-
DATE
Kg ~mre
Custody Con . ator
CHRISTINA D. WRIGHT,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYL VANIA
v.
: No. 05-2662
SHANNONP. WRIGHT,
Defendant
: CIVIL ACTION - AT LAW
: FOR CUSTODY
PETITION TO MODIFY ORDER OF CUSTODY
AND NOW, comes Plaintiff, Shannon P. Wright, by and through his attorneys, The Law
Offices of Patrick Lauer, Jr., and files this Petition to ModifY Order of Custody, and in support
thereof, avers the following:
1. Petitioner/Defendant is Father, who currently resides at 530 Bedford Court,
Mechanicsburg, Cumberland County, Pennsylvania, 17050.
2. RespondantlPlaintiff is Mother, who currently re'sides at an 1170 Redwood Drive,
Carlisle, Cumberland County, Pennsylvania, 17013,
3. The parties hereto are the parents of the following minor child:
Name Date of Birth
Nathan A. Wright
June I, 1995
4. On June 24, 2005, the Court of Common Please, Cumberland County entered an
Order of Custody, granting Plaintiff primary physical and shared legal custody of the parties'
child, and granting Defendant shared legal, and liberal periods of temporary, custody of the
parties' child. A true and correct copy of this Order is marked Exhibit "A," attached hereto, and
made part thereof.
5. This order was the result of a proported agreement of the parties reached at a
custody conciliation conference held on Thursday, Thursday, June 16, 2005 before Custody
Conciliator Hubert X. Gilroy, Esquire.
6. The Defendant submits that this order was not his understanding of the agreement
reached at the conciliation conference.
7. The Defendnat was under the impression that primary physical and legal custody
would be equally shared between the parties on a week on/week off basis.
WHEREFORE, Petitioner respectfully requests that this Court modifY the existing Order
for Custody and grant him physical and legal custody of his child, as is in the child's best
interest.
Date: OS- !J.-./r;6
, (
ph D. Caracio 0, Esquire
08 Market Street, Aztec Building
amp Hill, Pennsylvania 17011-4706
ID# 90919 Tel. (717) 763-1800
CHRISTINA D. WRIGHT,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYL VANIA
v.
: No. 05-2662
SHANNON P. WRIGHT,
Defendant
: CIVIL ACTION - AT LAW
: FOR CUSTODY
VERIFICATION
I verify that the statements made in the foregoing document are true and correct to the best
of my knowledge, information and belief. To the extent that any of the averments are based upon
an understanding or application of law, I have relied upon counsel in making this Verification.
I understand that false statements herein are made subjel~t to the penalties of 18 Pac C.S. 9
4904, relating to unsworn falsification to authorities.
Signature: ~- 7 ~
SHANNON P. WRIGHT
Date: ':& _./Z- 0,,\
CHRISTINA D. WRIGHT,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYL VANIA
v.
: No. 05-2662
SHANNON P. WRIGHT,
Defendant
: CIVIL ACTION - AT LAW
: FOR CUSTODY
I hereby certifY that I am this day serving a copy of the fc)fegoing Petition upon the person
and in the manner indicated below, which service satisfies the requirements of the Pennsylvania
Rules of Civil Procedure, by depositing a copy of the same in th.e United States Mail, Camp Hill,
Pennsylvania, through First class mail, prepaid and addressed as follows:
Mark A. Mateya, Esquire
P.O. Box 127
Boiling Springs, P A 17007
(Attorney for Plaintiff)
Date:Oy II J-Icr
( {
eph D. CaraclOlo, Esquire
08 Market Street., Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 90919 Tel. (717) 763-1800
CHRISTINA D. WRIGHT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LAW
'.
SHANNON P. WRIGHT,
NO. 05-2662
COURT ORDER
AND NOW, this ~ day of June, 2005, upon consideration of the attached
Custody Conciliation report, it is ordered and directed as follows:
1. The father, Shannon P. Wright, and the mother, Christina D. Wright, shall enjoy
shared legal custody of Nathan A. Wright, born Jun.e 1, 1995.
2. The mother shall enjoy primary physical custody of the minor child.
3. The father shall enjoy liberal periods of temporary custody of the minor child at such
times as agreed upon by the parties.
4. In the event the father becomes dissatisfied in Ithe future with the amount of
temporary custody provided to him with the minolr child, father may at that time
petition the Court to have this case again scheduled before a Custody Conciliator for
a Conference.
BY THE COURT,
{5(/(~~
Judge
cc: Mark A Mateya, Esquire
Sharmon P. Wright
"r;~~E: <..opy FROM ReCORD
I;i; !iii:I"'1>11(~1wilefllOf. , here unto set m h<lIlCt
~. C rt~_~
(~.
-l.9
~ (0 Vl.
f'.\l C> ~ q,
\) ~ 1,~
~
- ~ "'") -o'q
vO
- r - t?\CJ
~ -' - -r
..c: r -~~
~ -0 ~1
-0 ::;r.. ./",rr\
l) ~ r;-? ~~~
f;".:. }7
}) ...:-.-\ en a.
( ~ ......'- f':J
CHRISTINA D, WRIGHT
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
05-2662 CIVIL ACTION LAW
SHANNON p, WRIGHT
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Wednesday, An2nst 24, 2005
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hnbert X. Gilroy, Esq.
at 4th Floor, Cnmberland Connty Conrthonse, Carlisle on Friday, September 30,2005
, the conciliator,
at 8:30 AM
for a Pre-Hearing Custody Conference, At such conference, an effort will be made to resolve the issues in dispute; or
if this 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 priolr to scheduled hearin!!:.
FOR THE COURT.
By: isi
Hubert X Gilrov. Esq.
Custody Conciliator
JY
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) 249-3 166
fr/ ~ -j;t ~ ~ ~J J'c?- '7e.-;$
~;;7 yz.~ ~ >>~~
~~~~'n >>'7e?~
"
:'/\1(10
62 : I 1,1e! 92 ~nv goaz
^l:i~lCl':O;!.LGcd 3i-ll :JO
3:)j:l;IO-C!]ll:)
jECEIVED SEP 062005
CHRISTINA D. WRIGHT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
NO.05-2662 CIVIL ACTION - LAW
SHANNON P. WRIGHT,
Defendant
: IN CUSTODY
COURT ORDER
AND NOW, this 2,.(./ day of September, 2005, the Conciliator being advised that
the parties have reached an agreement, the Conciliator relinquishes jurisdiction.
07!-4
Hubert x~:~y, Esquire
Custody Cidiator
lei :Ci H\I t..
cnn7
.l"u...
3:.-11.:1('
C1.~n\_j
:
CHRISTINA D. WRIGHT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 05-2662
SHANNON P. WRIGHT,
Defendant
: CIVIL ACTION - LAW
CUSTODY AGREEMENT
AND NOW, this .5IJJ;!ayof ~t;~
, 2005, Christine D. Wright
(Mother") and Shannon P. Wright ("Father"), stipulate to the following provisions being made an
Order of Court:
1. Mother and Father shall share legal custody oftheir child, Nathan A. Wright, born
June 1, 1995 (age 10). Both parents realize that it is critical for the child's health development to
feel good about, and loving toward, both parents and that both parents playa major role in
helping to achieve this goal.
2. The parties agree and acknowledge that Legal Custody shall mean the legal right to
make major decisions affecting the best interests of the child, including, but not limited to,
medical, religious, and education decisions, Each party shall notify the other of any activity or
circumstance concerning the child that could reasonably be expected to be of concern to the
other. Day to day decisions shall be the responsibility ofthe parent then having physical custody.
3. Mother shall have primary physical custody of the child. Father shall have periods of
partial custody as follows:
A. Father shall have physical custody of the child for two weeks, followed by
Mother's custody of the child for two weeks. Father's custodial time with child shall continue,
alternating two weeks on/two weeks off.
B. During Father's two week custodial period, Mother shall pick up the child
from school and maintain custody of the child until such time as father retrieves child from
Mother's residence after his work day is completed.
C. During each parties period of physical custody, they shall make a concerted
effort to allow the child liberal communication with the other parent, and shall inform the other
parent of events and activities occurring during such period.
4. The parties shall work together to arrange for a mutually agreeable holiday schedule.
In the event the parties are unable to agree on holiday visitation, the parties' custody rights as
outlined above shall apply.
5. Each party understands that this custody schedule can be modified at any time with
mutual consent, and can be permanently modified by mutual written consent in the form of an
Amended Custody Agreement.
6. Both parents shall provide the other with all applicable telephone numbers, including
home, work and cell phone numbers. Both parents shall provide the other addresses where the
child will be residing.
7, The parties shall share transportation, with each party being responsible for arranging
transportation to begin his/her custodial period.
8. During any period of physical custody, the parties shall not possess or use any
controlled substance (other than legally prescribed medicines), nor shall they consume alcoholic
beverages to excess. The parties shall ensure, to the extent possible, that others in the presence
of the child comply with these prohibitions.
9. Each party agrees to not attempt to alienate the affections of the child from the other
and will make a special effort to promote the relationship of the child with both parties. Both
parties shall refrain from making derogatory comments about th,~ other in the presence ofthe
child and, to the extent possible, shall not permit third parties from making such comments in the
presence of the child, whether the child is sleeping or awake.
~u~
WITNESS
(J 'I -p-"7
" "_1 ,i ,," .,/ _
. ,.<" .. . .,/
( (,f... " .'"..- /( /, .." l..i.7>~tE;.... -'
v _ "
CHRISTINE D. WRiGHT -
?--?
SHANNON P. WRIGHT
(") ......, 0
=
r:; = -n
~,
. 0 -l
(:-) ffi:.o
...... ,-
-n IT:
_,~~ r-")
N ;')'1.
:'1\-)-
~ C =T~
~ -)C-)
;;.-fT1
CO U
i"J
en :1:]
(X) .<
-
RECEIVED OCT 13 Z005;)
CHRISTINA D. WRIGHT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 05-2662
SHANNON P. WRIGHT,
Defendant
: CIVIL ACTION - LAW
ORDER
.
AND NOW this ....!:J...- day of
Ochl W-
, 2005, upon consideration of
the foregoing Stipulation and Agreement entered into by the parties attached hereto:
IT IS HEREBY ORDERED AND DECREED that the Stipulation and Agreement
regarding CustodyNisitation dated September 30, 2005, entered into by the parties herein is
hereby approved as fully as though, and with the same force and effect as if such Order had been
entered after Petition, Notice and Hearing..
BY THE COURT:
. <Ii
J.
.- -
-':<,'\(10
6 I : II H'J L I no soal