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Home My WebLink About06-1946 ~ V. :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY,PENNSYL VANIA :CNILACTION- Ol" - jC14b CILJJ:--T~ : CNIL TERM : CUSTODY JONA ALDIS, PLAINTIFF, MICHAEL BEATTY, DEFENDANT, AGREEMENT AND STIPULATION THIS STIPULATION AND AGREEMENT entered into this , 'J tJ f!1 day of ~;-d ,2006, by and between Jona Aldis, (hereinafter referred to as "Mother") and Michael Beatty, (hereinafter referred to as "Father"). WHEREAS, Father and Mother are the natural parents of Cheyenne Jane Beatty (DOB 8/29/04); and WHEREAS, Father and Mother desire to enter into a comprehensive Custody Stipulation and Agreement setting forth the physical and legal custody arrangements for their minor child, to be in effect hereafter and until altered by subsequent agreement or order of court; and WHEREAS, Father and Mother desire to confirm their agreement relative to custody of their minor child and execute a Stipulation and Agreement to affect the same, NOW, THEREFORE, in consideration of the mutua! covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: I. Mother shall have sole legal and physical custody of the child, 2. Father shall have periods of visitation with the minor child, supervised by Mother. 3. Visitations with the minor children shall be at times agreed to by the parties. 4. Neither parent shall remove the child from the state without prior written notice to and consent from the other parent. " 5, Upon request, Mother shall provide Father with relevant health and school records. 6. The parties agree that when the child is able to verbally communicate, there shall be reasonable telephone contact with Father. 7. Neither party shall do anything that may estrange the child from the other party, or injure the opinion of the child as to the other party, or may hamper the free and natural development of the child's love and affection for the other party, Nor shall either parent permit other relatives or friends to speak or act in such a manner in the presence of the child. 8. Upon request Mother shall provide Father with information from any doctor, dentist, teacher or other similar authority. Such documents include, but are not limited to, medical reports, academic and school report cards. 9. Any permanent modification or waiver of the provisions of this Agreement must be in writing and shall be affective only if made in writing and executed with the formality of this Stipulation and Agreement. 10. The parties acknowledge that entering into this Stipulation and Agreement, there has been no fraud, concealment, overreaching, coercion or other unfair dealings on the part of either party. I I. The parties acknowledge that they have read and understood the provisions of this Stipulation and Agreement. Each party acknowledges that the Stipulation and Agreement is fair and equitable and that it is not the result of duress or undue influence. IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year above written. WITNESS: ;J~i dl1r - MICHAEL BEATTY ;!~-1 (!tt,-- STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND On this, the .3::) day of ~/Z-;;;' 2006 , before me this undersigned officer, personally appeared JONA ALDIS, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed same for the purposes therein contained, ~ ;--' --_._----- i SUSM, K, ~~gl:;~~L~~\ARYP~:~;-] CITY OF CAMP Hi! L, CUMBERLAND COUNW , MY Cm~i\jl~~~.~~'i~_~!!~\_~ Ar'::jll ?~i, 2007 . STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND On this, the~ day of ~ 2006 , before me this undersigned officer, personally appeared MICHAEL BEATTY, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed same for the purposes therein contained, IN WITNESS WHEREOF, I hereunto set my hand and office seal. '7 '" ,-"'"' ,. NOTARIAL SEAL :J \ UICK'CRO, NOTA;WPU~L\~, ' ';"iT,'IF r ',I,W ~ i:[ CUMSERL/.'/i Lout"n i :"",' ~~",:,!' ,.' <J(~' [,',,~, '/', ?'CI1 I ~ JONA ALDIS, PLAINTIFF, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY,PENNSYL VANIA :CIVIL ACTION - 6~ - I Q4/P C;(;~l~&2--~ V. MICHAEL BEATTY, DEFENDANT. : CIVIL TERM : CUSTODY COMPLAINT FOR SOLE CUSTODY I. The Plaintiff is JONA ALDIS, who currently resides at 609A Apt. 31, Geneva Road, . Mechanicsburg, Cumberland County, Pennsylvania, 2. Defendant is MICHAEL BEATTY, who currently resides at 4341 Carlisle Pike, Apt. CI, Camp HilI, Pennsylvania. 3. Plaintiff seeks custody of the following child: Name Present Residence Age 19 months CHEYENNE JANE BEATTY 609AApt. 31 Geneva Rd. Mechanicsburg The parties were never married. The child is presently in the physical custody of plaintiff Mother, who resides at the address in paragraph I in Cumberland County, Pennsylvania and has resided in Cumberland County Pennsylvania for the past year. During the past five years, the child has resided with the foIlowing persons and at the foIlowing addresses: I. Mother 609 A Apt. 3 I Geneva Rd. Mechanicsburg February 2006 to present 2. Mother and maternal grandfather 145 Old Ford Dr. Camp HilI January 2006 3. Mother and father 4341 Carlisle Pike Mechanicsburg August 29, 2004 to January 2006 The mother of the child is Jona Aldis, Plaintiff, currently residing at the address in Paragraph 1. She is single and living separately from defendant. .. The father of the child is Michael Beatty, Defendant, currently residing at the address in Paragraph 2. He is single and living separately from plaintiff. 4. The relationship of defendant to the child is that of father. The defendant currently resides with his 9 year-old child from another relationship, 5. The relationship of the plaintiff to the child is that of mother. The plaintiff currently resides with the following persons: Cheyenne Jane Beatty 6, Plaintiff has not participated as a party in a custody action concerning the custody of the minor child. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. Plaintiff does not know of any 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 interest and permanent welfare of the child will be served by granting plaintiff sole physical custody and legal custody of said minor child with appropriate supervised visitation to father. 8. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, plaintiff respectfully requests your Honorable Court to grant sole physical and legal custody rights to plaintiff. ~ 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.s 4904 relating to unsworn falsification to authorities. DATE: 3-?O- Qlp JONA ALDIS, PLAINTIFF, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY,PENNSYL VANIA :CIVIL ACTION - V. MICHAEL BEATTY, DEFENDANT. : CIVIL TERM : CUSTODY ACKNOWLEDGMENT OF SERVICE The undersigned, Michael Beatty, does hereby personally accept service of the Complaint in Custody filed at the caption and number set forth above. 5 -.:0'-a;; Date Michael Beatty JJ \t- - -l. \'- -C \) -::t. -w.. o -. FIl ~ \) tv (J ~~ 3- t~o~ ('A ----3 ,- ,.c.-.(i; \ <0"1 . , ;-:\" .::'::" -, ,~ " C'; .. ,,=>="'I'7'H 1",'.'[ ) I .. ~.... . I I APR 1 0 2006 1(,\ it.,,,.. f:( j .) --- -..-.,--.. .'~.".:..~:~~'-C--"~----' - . JONA ALDIS, PLAINTIFF, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY,PENNSYL VANIA :CNIL ACTION - O~ - NLJb C ;ulL'-r'UL.i v, MICHAEL BEATTY, DEFENDANT. : CNIL TERM : CUSTODY ORDER OF COURT AND NOW, this ,9v day of i1k" I , 2006, upon consideration of the attached , Stipulation and Agreement, the terms and conditions contained in the attached Stipulation and Agreement are hereby made an Order of Court. B;~AJ / Judge " r'}\ ,