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Home My WebLink About05-3251 MELINDA J. LEHR, Plaintiff AND ON BEHALF OF HER MINOR CHILDREN: Amanda J. Price and Amber R. Price : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~ oS" - .l:lS/ Ci,-,L~~ : NO.~!l &'1'86 CIVIL TERM v. ROBERT T. PRICE, JR., Defendant : PROTECTION FROM ABUSE : AND CUSTODY STIPULATION AND AGREEMENT AND NOW, this 17 day of ~ , 2005, the parties, have reached an agreement regarding the best interests of their minor child, AMANDA J. PRICE, born January 20, 1989 which shall be entered as an Order of Court to resolve the issues raised by Defendant in the pending action to modify custody: 1, The parties shall have shared legal custody of the subject minor child. They shall consult with each other relative to all important decisions concerning the subject minor child including such matters as health, education and religion. Both parties must be listed as the primary emergency contacts at any schools, hospitals, doctors' offices and on any other form requiring emergency contacts. Each parent is responsible for keeping the other apprised of all activities involving the child so that both parents have an opportunity to be present The party having physical custody shall be responsible for getting the child to all regularly-scheduled activities, 2. Defendant, ROBERT T. PRICE, shall have primary physical custody of the minor child, AMANDA J. PRICE, subject to Plaintiffs rights of partial custody at such times and places as the parties may hereinafter agree. 3. Plaintiff and Defendant shall share the responsibility for transportation necessary to exercise the Plaintiff's periods of partial custody. The pick up and return shall take place at the other parent's home, unless otherwise agreed to by the parties. 4, The parent having physical custody of the child shall have the duty to immediately advise the other parent of any unusual occurrence, illness or accident (other than e.g. minor cold, minor injury), The parties shall notify each other in advance of any medical or dental appointments scheduled for the child. 5, During any period of custody or partial custody, the parties agree not to possess or use controlled substances or consume alcoholic beverages to the point of intoxication. The parties agree to likewise assure to the extent possible that other household members and/or houseguests comply with this prohibition. 6. The parties shall have reasonable telephone contact with the minor child at all times. 7. Mother and Father shall keep the other apprised of all school events (including, but not limited to, teacher meetings, school performances, club activities, etc.). Each parent shall share school documents with the other parent (including, but not limited to, report cards and teacher correspondence). Neither parent shall unilaterally withdraw or enroll the child in a different school without notice to the other parent. 8. Each parent shall keep the other informed as to their current physical addresses and telephone numbers (home and work). Neither party shall move to another address unless he or she first provides notice to the other party. 9. Neither party shall attempt to alienate or destroy the affection of the child for the other parent, but shall exert every reasonable effort to foster a feeling of affection between the child and both parties. Moreover, both parties must take all reasonable steps to prevent anyone else from disparaging the other party. Each party shall cooperate with the other to the maximum extent possible to assure that the best interests and welfare of the child are served, The welfare and convenience of the child shall be the prime consideration of the parties. 10. Mother and Father agree that the Court of Common Pleas of Cumberland County, Pennsylvania shall retain jurisdiction over the within custody case for purposes of enforcement and all future modifications regardless of any change of residence by either party, --'-- ~,-{'^qnOj~ Witness ~ ~.t -ItP-}- Defendant MELINDA J. LEHR, Plaintiff AND ON BEHALF OF HER MINOR CHILDREN: Amanda J. Price and Amber R. Price : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA 05'- 3~$f : NO. .ge (;786 CIVIL TERM v. ROBERT T. PRICE, JR., Defendant : PROTECTION FROM ABUSE : AND CUSTODY COMPLAINT TO MODIFY CUSTODY AND NOW, comes the Defendant, ROBERT T. PRiCE, JR., by and through his attorney, ROBERT B. LIEBERMAN, ESQUIRE and respectfully represents as follows: I. The Plaintiff is MELINDA J. LEHR, residing at 1917 Spring Road, Apt. 4, Carlisle, Cumberland County, Peunsylvania. 2. The Defendant is ROBERT T. PRICE, JR, residing at 244 Beacon Drive, Harrisburg, Dauphin County, Pennsylvania. 3. Defendant seeks custody of the following child: Name Residence Age Amanda J. Price 244 Beacon Drive Harrisburg, Pennsylvania 16 years The child was born to the marriage of Plaintiff and Defendant. The child is presently in the custody of Defendant, ROBERT T. PRICE JR., who resides at 244 Beacon Drive, Harrisburg, Dauphin County, Pennsylvania. The child has resided with the Plaintiff, MELINDA J. LEHR, previously at 1917 Spring Road, Apt. 4, Carlisle, Cumberland County, Pennsylvania. The mother of the child is MELINDA J. LEHR, currently residing at 1917 Spring Road, Apt. 4, Carlisle, Cumberland County, Pennsylvania. She is single, The father of the child is ROBERT T. PRICE JR., currently residing at 244 Beacon Drive, Harrisburg, Dauphin County, Pennsylvania. He is single. 4. The relationship of Plaintiff to the child is that of Mother. The Plaintiff currently resides with Amber R. Price, her daughter and Cameron Shaeffer, her son. 5. The relationship of Defendant to the child is that of Father. The Defendant currently resides with the child and Christy R. Walker, his fiancee. 6. Plaintiff and Defendant have previously participated as parties in litigation concerning the custody of the child in this court. See Order dated December 13, 1995 which is attached hereto. Defendant has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. -2- Defendant does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interests and permanent welfare of the child will be served by granting the relief requested because Defendant is ready, willing and able to provide a stable home environment for the child, 8, Each party 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. 9. Plaintiff and Defendant have entered into a Stipulation and Agreement requesting that this Honorable Court transfer custody from Plaintiff to Defendant. WHEREFORE, Defendant requests this Honorable Court to grant him shared legal and primary physical custody of the subject minor child, Respectfully submitted, DATED: ~ I ~ 2. COS" t ~5? 'ROBERT B. LIEBERMAN, ESQUIRE 500 North 3'd Street, 12th Floor P.O. Box 1004 Harrisburg, PAl 7108-1004 (717) 236-1485 Attorney for Defendant -3- VERIFICATION I verify that the statements made in the foregoing Complaint to Modify Custody are true and correct based upon my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S4904, relating to unsworn falsification to authorities. DATED:..r... I ~. 0 S ~,!L9 Defendant 1-~ 'i.s- -- -- -- - ~ ~ Q- D VI ~ ~ ~ ~ ~ ~..~ -:. w o ~) c:.::> ,...:-;) ~, ( ~: -- o -n -t :r r.-.:D ,-- ~~cq ,0h~ ~~~ f.~ >' :z "" -.J ::..:..." :::;".: c' CO MELINDA J. LEHR, Plaintiff AND ON BEHALF OF HER MINOR CIDLDREN: Amanda J. Price and Amber R. Price : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v\ : 11 . l'--.-f, RECEIVL:l.l _..113 l\l1fj;v{\ : D~ - J..<S'I ~tt"l.l~~ fI' : NO. ~, 6"'116 CIVIL TERM v. ROBERT T. PRICE, JR., Defendant : PROTECTION FROM ABUSE : AND CUSTODY ORDER OF COURT AND NOW, this ,,: day Of~' 2005, the: terms and conditions of the attached Stipulation and Agreement are hereby made an Order of this Honorable Court , J fi ~t ~f , <:s. Vii~\;I/\l'(SNI',::Jd }J'ln~~' T "r""""n" .1'11\..,';.' !,,:-, .i~I~'!::-::!'~, V f L I :2 Wd I - lOrsOOl Al:I'I'10NOHIOCJd 3Hl :10 3:>l:I:KXI31l:l ~ ~