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HomeMy WebLinkAbout02-1622 Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA TERRY L. MONN, vs. : CIVIL ACTION - LAW : NO. oJ..vJ~'):L- : IN CUSTODY CIVIL TERM LUCINDA A. MONN, Defendant PRAECIPE TO FILE A CUSTODY DECREE OF ANOTHER JURISDICTION PURSUANT TO 23 PA.C.S.A. ~5356 Pursuant to 23 Pa.C.S.A. ~5356 and 23 Pa.C.S.A. ~5364 of the Domestic Relations Code, relating to Uniform Child Custody Jurisdiction Act, please file of record the attached certified Order of Court, dated December 19, 1997, from the Court of Common Pleas of the 39th Judicial District of Pennsylvania, Franklin County Branch, attached hereto. Respectfully submitted, Marylo a Attorney for laintifJ GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 : .- IN THE COURT OF COMMON PLEAS OF THE 39TH JUDICT ~ T nN'T'DK'T OF PENNSYL VANIA - FRANKLIN COUNTY a.. RANCH ~;r. . <1'.. i). " '\ ,",,~..t<""I'''~)'' ; "K~ ~':"l'.~' Lucinda A. Monn,.. . . Civil Action Law \ . II. M' ! PlamtlfflPetItloner I ,;:1 this .Ji!.C'.'ilY of "(IIrcJ" 0l1Jl)~; No. F.R. 1991- 444 Iq{~~~~;t.t~ ------.".,--.., v. Terry L. Monn, DefendantJRespondent Custody ;......,;) 1 ~"'<) t ORDER OF COURT NOW, I C1 De CI ,19.ilupon consideration of Agreement, it is hereby ordered as follows: 1. Terry L. Monn, hereinafter referred to as Terry, and Lucin .. en . Monn, here~fter referred to as Lucinda, shall have shared legal custody oftheir son, Trevor Monn, hereinafter referred to as Trevor, born February 23, 1990. 2. Lucinda shall have primary residential custody of Trevor subject to the following periods of partial custody in Terry: A. Each Tuesday from 5:00 p.m. until 7:30 p.m., Terry to have notified Lucinda at least 24 hours in advance ifhe is going to exercise said partial custody. B. Commencing OeC(?('(\Qer I;;}..... , 1997 and on alternate weekends thereafter from Friday at 4:30 p.m. until Sunday at 4:30 p.m. C. Beginning in June of 1998 and commencing the first Friday for Father's regularly scheduled weekend after school is out for summer vacation from Friday at 4:30 p.m. until the following Friday at 4:30 p.m. and alternating thereafter so that Terry has the first week after school is out and the child is back in Lucinda's custody for a full week before school commences and the parties having alternating weeks of custody in the interim. 3. Holidays shall be shared between the parties such that in 1997 and in all odd numbered years Terry shall have physical custody of Trevor on Easter Sunday and the nationally recognized holiday for the Fourth of July celebration, and Lucinda shall have physical custody of Trevor on New Year's Day, the nationally recognized holiday for the Memorial Day celebration =~ .. r&~..' " /LJc"':' k. (.0 ,-..', .L.o .. ~~~.. '.' .~ . L':'""'~-'____.._.n___. "".' ,....... . . --. : Lucinda A. Monn, Plaintiff vs. Terry L. Monn, Defendant - Page 2 - No. F. R. 1991 - 444 In Custody and Labor Day. The holidays shall be reversed in even numbered years. The times for the holiday custody periods for Easter Day, New Year's Day, the nationally recognized holiday for the Memorial Day celebration and Labor Day shall be between the hours of 4:30 p.m. the evening prior to said holiday until 4:30 p.m. the day of said holiday. The times for the holiday custody for July 4th shall be from 9:00 a.m. on the nationally recognized holiday for July 4th until 9:00 a.m. the next day. 4. Terry shall have Trevor each and every Father's Day from 9:00 a.m. until 5:00 p.m. and Lucinda shall have Trevor each and every Mother's day from 9:00 a.m. until 5:00 p.m. 5. Physical custody of Trevor shall be shared for the Thanksgiving holiday such that in 1997 and all odd numbered years Terry shall have Trevor from 4:30 p.m. the evening prior to Thanksgiving until 4:30 p.m. on Friday, the day after Thanksgiving. In odd numbered years Lucinda shall have Trevor from 4:30 p.m. on Friday (the day after Thanksgiving) until 4:30 on the Sunday after Thanksgiving. Said time period shall alternate on a yearly basis such that in 1998 and in even numbered Lucinda shall have Trevor from 4:30 p.m. the evening prior to Thanksgiving until 4:30 p.m. on Friday, the day after Thanksgiving and Terry shall have Trevor from 4:30 p.m. on Friday (the day after Thanksgiving) until 4:30 p.m. on the Sunday after Thanksgiving. 6. Pending further Order of Court, the Christmas custody shall be as detailed Paragraph 5 in the July 15, 1993 Order of Court, attached hereto. 7. The holiday custody schedule as defined in Paragraphs 3, 4, 5, and 6 above shall take precedence over the regular custody schedule defmed in Paragraph 2 above. Lucinda A. Monn, Plaintiff vs. Terry L. Monn, Defendant - Page 3 - F.R. 1991 0444 In Custody 8. Transportation shall be shared for all periods of physical custody other than on Tuesday evenings when Terry provides all transportation such that Terry shall be responsible for picking up the child for the exercise of Terry's custody and Lucinda shall pick up the child for the exercise of her custody. In the event neither parent is able to fulfill the transportation responsibilities, he or she may designate a responsible adult known to both parties and the child to act in his or her place and shall provide notice of said designation to the other party. The only exception shall be that if Lucinda shall be scheduled to work and is working on the day after the nationally recognized holiday for July 4th when Trevor has been with Terry for the July 4th holiday, then Terry or his designated driver shall return Trevor to Lucinda's care and custody by 9:00 a.m. on July 5th the day after the nationally recognized holiday. 9. Neither party nor members of his or her respective family shall make any disparaging remarks regarding the other parent and his or her respective family members in the presence of Trevor. 10. Neither party shall consume alcoholic beverages or use illegal drugs for the 24 hour period preceding and at all times during his or her periods of physical custody of Trevor. Excessive use of alcohol by others in Trevor's presence shall also be prohibited. 11. Reasonable telephone contact by the parent not exercising physical custody of Trevor shall be permitted by all parties two times a week. 12. Neither party will enroll the child in any activity that would infringe on the other parent's time with the child without first consulting the other parent. Said consultation shall be in written format specifying the date and time of the activity. The parties shall cooperate and make every effort to allow Trevor to participate in the activities of his choice as much as is possible taking into consideration both parents' schedule and the distance between the parties. " 13. The costs in this proceeding have been paid by the Plaintiff. By the Court, M 0(\(\ ~ M ()'\f\ fP-lq9Hy,~ QO"~J~~~ G IN THE COURT OF COMMON PLEAS OF THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA - FRANKLIN COUNTY BRANCH Lucinda A. Monn, Plaintiff/Petitioner Civil Action Law v. No. F.R. 1991 - 444 Terry L. Monn, DefendantlRespondent (,.(;) -.J o Pl " Custody STIPULATION AND AGREEMENT 0") . THIS STIPULATION AND AGREEMENT is made and between Lucinda A. Monn, of hereinafter referred to as "Plaintiff', and Terry L. Monn, ofWaynesb Pennsylvania, hereinafter referred to as "Defendant". 1. Plaintiff and Defendant are the natural parents of Trevor L. Monn, born February 23, 1990. 2. Plaintiff and Defendant were married on August 11, 1989, in Hagerstown, Washington County, Maryland, and divorced by Decree entered on August 7, 1992. 3. With the exception of the action filed to the above-captioned number and term, neither party has participated as a party in other litigation concerning the custody of the child in this Court. 4. None of the parties has information of a custody proceeding concerning the child pending in a court of this Commonwealth. 5. None of the parties knows 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. 6. During the past 5 years, the child has resided with the following persons and at the following addresses: Persons Addresses Dates A. Lucinda A. Monn and Kathleen Fisher (maternal grandmother) 1528 Lakeshore Drive Chambersburg, P A 17201 from 1992 to August, 1997 B. Lucinda A. Monn and Kathleen Fisher August, 1997 to present 7. The parties have reached an agreement with regard to the custody of their minor child and desire to reduce their agreement to an Order of Court. NOW THEREFORE, the parties intend 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, ,19_, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: 1. 1. Terry L. Monn, hereinafter referred to as Terry, and Lucinda A. Monn, hereinafter referred to as Lucinda, shall have shared legal custody of their son, Trevor Monn, hereinafter referred to as Trevor, born February 23,1990. 2. Lucinda shall have primary residential custody of Trevor subject to the following periods of partial custody in Terry: A. Each Tuesday from 5:00 p.m. until 7:30 p.m., Terry to have notified Lucinda at least 24 hours in advance ifhe is going to exercise said partial custody. Oe~ B. Commencing A::tlo".,t 12-, 1997 and on alternate weekends thereafter from Friday at 4:30 p.m. until Sunday at 4:30 p.m. C. Beginning in June of 1998 and commencing the first Friday for Father's regularly scheduled weekend after school is out for summer vacation from Friday at 4:30 p.m. until the following Friday at 4:30 p.m. and alternating thereafter so that Terry has the first week after 6. Pending further Order of Court, the Christmas custody shall be as detailed Paragraph 5 in the July 15, 1993 Order of Court, attached hereto. 7. The holiday custody schedule as defined in Paragraphs 3, 4, 5, and 6 above shall take precedence over the regular custody schedule defined in Paragraph 2 above. 8. Transportation shall be shared for all periods of physical custody other than on Tuesday evenings when Terry provides all transportation such that Terry shall be responsible for picking up the child for the exercise of Terry's custody and Lucinda shall pick up the child for the exercise of her custody. In the event neither parent is able to fulfill the transportation responsibilities, he or she may designate a responsible adult known to both parties and the child to act in his or her place and shall provide notice of said designation to the other party. The only exception shall be that if Lucinda shall be scheduled to work and is working on the day after the nationally recognized holiday for July 4th when Trevor has been with Terry for the July 4th holiday, then Terry or his designated driver shall return Trevor to Lucinda's care and custody by 9:00 a.m. on July 5th the day after the nationally recognized holiday. 9. Neither party nor members of his or her respective family shall make any disparaging remarks regarding the other parent and his or her respective family members in the presence of Trevor. 10. Neither party shall consume alcoholic beverages or use illegal drugs for the 24 hour period preceding and at all times during his or her periods of physical custody of Trevor. Excessive use of alcohol by others in Trevor's presence shall also be prohibited. 11. Reasonable telephone contact by the parent not exercising physical custody of Trevor shall be permitted by all parties two times a week. '. 12. Neither party will enroll the child in any activity that would infringe on the other parent's time with the child without first consulting the other parent. Said consultation shall be . in written format specifYing the date and time of the activity. The parties shall cooperate and make every effort to allow Trevor to participate in the activities of his choice as much as is possible taking into consideration both parents' schedule and the distance between the parties. 13. The costs in this proceeding have been paid by the Plaintiff. BY THE COURT: 1. The parties further agree that, in procuring this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part ofthe 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: ~ ..' ,-.,~., C:LtfAtV'/, 1.4,;. ~7'1. ~. <e/( ~ .. tuviL " 7Y(~ 0-u inda A. Moun ~~2- Terry . Moun I verify that the facts set forth in the above 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. Date: ./f2tc -~ ,192:7 ~cA.~L-/ inda A. Monn I verify that the facts set forth in the above 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. Date: I::A/r~ I ,1911 T~~~ I IN THE COUIt* OF.' CODON PLEAS'.'OF'THE 39TH JUDICIAL Dr'~TRICT OF PENNSYLVANIA FRANKLIN COUNTY BRANCH Lucinda A. Monn : CIVIL ACTION LAW . . vs . . . . Terry L. Monn : FR 1991 - 444 APPEARANCES: Carol L. Van Horn, Esquire, appears on behalf of the plaintiff. Terry L. Monn appears pro se. ORDER OF COURT NOW, this 15th day of July, 1993, on stipulation of Lucinda A. Monn and her attorney, Carol Van Horn, Esquire, and Terry L. Monn, pro se, it is ordered and decreed that: 1. Terry L. Monn hereinafter Terry, and Lucinda A. Monn, hereinafter Lucinda shall have shared legal custody of their son Trevor Monn hereinafter Trevor born February 23, 1990; 2. Lucinda shall have primary physical custody of Trevor subject to the following periods of partial custody in Terry: a. each Tuesday and Thursday from 2:30 p.m. until 5:30 p.m. b. beginning July 17, 1993 and on alternate EXHIBIT "A" </ saturdays thereafter from 12,30 p.m. ~"il<S'30 p,m. providing that Terry has consistently exercised his rights to partial custody as described in subparagraph (b) above and has no more than two unexplained absences, then c. beginning September 12 and on alternate Sundays thereafter from 12:30 p.m. until 5:30 p.m. and again providing that Terry has consistently exercised his rights to partial custody as described in subparagraphs (b) and (C) above and has no more than two unexplained absences, then. d. beginning November 20 and on alternate weekends thereafter from 12:30 p.m. Saturday until 5:30 Sunday e. beginning in 1994 for one full week during the month of June, July or August with one additional week added each of the next three years such that Terry shall have Trevor for four full weeks during the summer months in 1997 with no more than two weeks to be exercised consecutively. Terry shall notify Lucinda in writing by May 1 of each year as to his desired week or weeks of custody during the summer months. 3. Holidays shall be shared between the parties such that in 1993 and all odd numbered years Terry shall have physical custody of Trevor on Easter Day, the na~~ona~ly recognized hpliday for the F.qur~~ of July . . celebration, and Thanksgiving Day, and Lucinda'shall have physical custody of Trevor on New Years Day, the nationally recognized holiday for the Memorial Day celebration and Labor Day. The holidays shall be reversed in even numbered years. The times for the holiday cust~dy periods in 1993 shall be between the hours of 9:00 a.m. and 5:00 p.m. Beginning with Terry's partial custody of Trevor for the Memorial Day celebration in 1994 and continuing for all holidays thereafter the times fer holiday custody periods shall be from 7:00 p.m. the evening prior to the holiday until 5:00 p.m. on the holiday. 4. Terry shall have Trevor each and every Father's Day from 9:00 a.m. until 5:00 p.m. and Lucinda shall have Trevor each and every Mother's Day from 9:00 a.m. until 5:00 p.m. 5. Physical custody of Trevor shall be shared on Christmas such that in 1993 and all odd numbered years Lucinda shall have Trevor from noon on December 24 until noon on December 25, and Terry shall have Trevor from noon on December 25 until noon on December 26. Said time periods shall alternate on a yearly basis such that in 1994 and all even numbered years Terry shall have Trevor from noon on December 24 until noon on December 25 and . ----- -~_._-_.-_. ..-.- ---- -------------.. Lucinda sha~l have Trevor. on noon December 25 unti~ noon , , . . ". .. . on December 26. 6. The holiday custody schedule as defined in paragraphs three, four and five above shal~ take precedence over the regular custody schedu~e defined in paragraph two above. 7. Transportation for all periods of physical custody for Terry shall be provided by Terry. 8. Neither party nor members of his or her respective family shall make a.ny disparaging remarks regarding the other parent and his or her respective family members in the presence of Trevor. 9. Terry shall make every effort to notify Lucinda of any changes needed to the within schedule as far in advance as possible and Lucinda shall cooperate in signing written documentation of the requested changes and the reasons therefore which sha~l be prepared by Terry and presented by him to Lucinda for signature. 10. Neither party sha~l consume alcoholic beverages or use illegal drugs for the 24 hour period preceding and at all times during his or her periods of physical custody of Trevor. Excessive use of alcohol by others in Trevor's presence sha~l also be prohibited. 11. Reasonable telephone contact by the parent not exercising physical custody of Trevor shall be ----. -.... .. petmi~ted by both part~es~ , . 'I 12. Costs to'be pa~d by the pla~nt~ft. By the Court, . W. Keller, . S.J. cc: Carol Van Horn, Esq. (2) Terry Mann .-..... .~..-....- ---... ',~ . . , 0 0 (:) ~ N ., ~ :$". :t:.. ---j -On.) -0 'T" rnj,,,, ;::0 inr_ 2;i:] I -o,n f ~ -F z); w ~J7? C/) "._ ~~;':: <:) ;::$6 :!< -0 ~3J ~o ::ii: 00 "- ~ 5;8 ~rn ~ og - ~ .. \l' ..... .... ~ N ~ (t ~ " .&- ~ ~ J. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA TERRY L. MONN, vs. : CIVIL ACTION - LAW LUCINDA A. MONN, Defendant : NO. 02- tc,2J.,. : IN CUSTODY CIVIL TERM PETITION FOR MODIFICATION OF CUSTODY AND NOW, comes Petitioner, Terry L. Monn, by and through his counsel of record, Marylou Matas, Esquire, and petitions the Court as follows: 1. Your Petitioner is the above-named Plaintiff, Terry L. Monn, an adult individual currently residing at 1345 Swope Drive, Boiling Springs, Cumberland County, Pennsylvania. 2. Your Respondent is the above-named Defendant, Lucinda A. Monn, an adult individual currently residing at 236 Skyline View, Carlisle, Cumberland County, Pennsylvania. 3. The parties are the natural parents of one child, Trevor Lyn Monn, born February 23, 1990. 4. The parties are subject to an Order of Court dated December 19, 1997, relative to the custody of their child, a copy of which is attached hereto and incorporated herein by reference as Exhibit "A." A Praecipe to transfer this Order from the Court of Common Pleas of the 39'h Judicial District of Pennsylvania, Franklin County Branch, to the Court of Common Pleas of Cumberland County was filed on April 3,2002. 5. For the past five (5) years, or since the child's birth, the child has resided with the following persons at the following addresses for the following periods oftime: NAME ADDRESS DATES Lucinda A. Monn December 1997 to Kathleen Fisher Chambersburg, P A 1999 Lucinda A. Monn 236 Skyline View 1999 to Kathleen Fisher Carlisle, P A Present 6. The child has resided in Cumberland County, Pennsylvania, for more than the past two years, thus providing the Court of Common Pleas of Cumberland County with jurisdiction of these proceedings. 7. The relationship of Petitioner to the child is that of natural father. Petitioner currently resides with his wife, Belinda A. Monn and their two children, Jacob and Benjamin. 8. The relationship of Respondent to the child is that of natural mother. Respondent currently resides with her mother, Kathleen Fisher, and the child at issue. 9. Under the terms of the current Order, Respondent has primary physical custody of the child and Petitioner has partial physical custody of the child on alternating weekends during the school year and on alternating weeks during the summer. 10. Petitioner believes it is in the child's best interest for Petitioner to be more involved with the child's education. II. Petitioner is and has been actively involved in the child's education, frequently volunteering to participate in various school and extracurricular activities. 12. Petitioner has always encouraged and fostered a relationship between the child, Respondent, and her family, as well as a relationship between the child and Petitioner's family. 13. The child has developed an emotional attachment to his siblings, Petitioner's other children. 14. Petitioner believes it would be in the child's best interest to be more involved with his siblings. 15. Petitioner believes and therefore avers that it is in the best interest and permanent welfare of the child for the parties to share physical custody of the child on an alternating weekly basis throughout the entire year. 16. Petitioner is a stay at home father and has the ability to care for the child during any period of time when Respondent is unavailable. 17. Petitioner believes that it is in the child's best interest to be placed in Petitioner's care during the day in the summer months during Respondent's weekday periods of custody while she is at work. WHEREFORE, Petitioner requests your Honorable Court to schedule a conciliation conference followed by a hearing at which time he should be granted shared physical or residential custody of the child. Respectfully submitted, Mary Attorn r Petitioner/Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. DATE: L//~2 ~~~ - TERRY . MONN, Petitioner/Plaintiff Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA TERRY L. MONN, vs. : CIVIL ACTION - LAW ; NO.()J... 1/,.23- : IN CUSTODY CIVIL TERM LUCINDA A. MONN, Defendant PRAECIPE TO FILE A CUSTODY DECREE OF ANOTHER JURISDICTION PURSUANT TO 23 PA.C.S.A. 95356 Pursuant to 23 Pa.C.S.A. S5356 and 23 Pa.C.S.A. S5364 of the Domestic Relations Code, relating to Uniform Child Custody Jurisdiction Act, please file of record the attached certified Order of Court, dated December 19, 1997, from the Court of Common Pleas of the 39th Judicial District of Pennsylvania, Franklin County Branch, attached hereto. Respectfully submitted, Marylo a Attorney for laintifJ GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 lRUE COpy FROM RECORO IIi T esHmony w\1f:lrecf. ! hariJ unto. sel my hand md tile s2al of s.aid Court at Carlisle. Pa, n1\S 51)~~ ~~J~;V Prothonotary !Xh/ bit II An ,. IN THE COURT OF COMMON PLEAS OF THE 39TH JUQlCJ A T nT<::TI'ICT ----,..,.. OF PENNSYLVANIA - FRANKLIN CO~TY ,RANCH G1t'rUfh:h, Lucinda A. Moun, Civil Action Law 1 1 M' \ Plaintiffi'Petitioner I ,':1 this .dJ!..csy or I r lPrd, , f)~tJ:)l : No. F.R. 1991 _ 444 \ ,.._ tJ. v. Terry L. Moun, DefendantJRespondent ~",..~ -~<! Custody ORDER OF COURT '.'-", CJ r'-'l " r-.-:>l 1"'<>' '<. NOW, Iq Dte; , 19 j]upon consideration of . ;;~:.~ ~C" .,," ',i';~ ::~~:, ':("f\ ,:~tipulatlen and',,,,, :~:; .,,, ';;;0 ~ :: ~: ~tlhi~, -<.r.:J ;".... ""< r"~ c.n ""'1:; ::;-f~ . Moun, hereh:ilfter ;"' Agreement, it is hereby ordered as follows: 1. Terry L. Monn, hereinafter referred to as Terry, and Lucin referred to as Lucinda, shall have shared legal custody of their son, Trevor Moun, hereinafter referred,to as Trevor, born February 23, 1990. 2. Lucinda shall have primary residential custody of Trevor subject to the followmg periods of partial custody in Terry: A. Each Tuesday from 5:00 p.m. until 7:30 p.m.., Terry to have notified Lucinda at least 24 hours in advance ifhe is going to exercise said partial custody. B. CommencingOeCQ.rrlQe.r1 d- , 1997 and on alternate weekends thereafter from Friday at 4:30 p.m. until Sunday at 4:30 p.m. C. Beginning in June of 1998 and commencing the first Friday for Father's regularly scheduled weekend after school is out for summer vacation from Friday at 4:30 p.m. until the ' following Friday at 4:30 p.m. and alternating thereafter so that Terry has the first week after school is out and the child is back in Lucinda's custody for a full week before school commences and the parties having alternating weeks of custody in the interim. 3. Holidays shall be shared between the parties such that in 1997 and in all odd numbered years Terry shall have physical custody of Trevor on Easter Sunday and the nationally recognized holiday for the Fourth of July celebration, and Lucinda shall have physical custody of Trevor on New Year's Day, the nationally recognized holiday for the Memorial Day celebration '~ ~I'"'\ Lucinda A. Monn, Plaintiff vs. Terry 1. Monn, Defendant - Page 2- No. F. R. 1991- 444 In Custody and Labor Day. The holidays shall be reversed in even numbered years. The times for the holiday custody periods for Easter Day, New Year's Day, the nationally recognized holiday for the Memorial Day celebration and Labor Day shall be between the hours of 4:30 p.m. the evening prior to said holiday unti14:30 p.m. the day of said holiday. The times for the holiday custody for July 4th shall be from 9:00 a.m. on the nationally recognized holiday for July 4th unti19:00 a.m. the next day. 4. Terry shall have Trevor each and every Father's Day from 9:00 a.m. until 5:00 p.m. and Lucinda shall have Trevor each and every Mother's day from 9:00 a.m. unti15:00 p.m. 5. Physical custody of Trevor shall be shared for the Thanksgiving holiday such that in 1997 and all odd numbered years Terry shall have Trevor from 4:30 p.m. the evening prior to Thanksgiving unti14:30 p.m. on Friday, the day after Thanksgiving; In odd numbered years Lucinda shall have Trevor from 4:30 p.m. on Friday (the day after Thanksgiving) unti14:30 on the Sunday after Thanksgiving. Said time period shall alternate on a yearly basis such that in 1998 and in even numbered Lucinda shall have Trevor from 4:30 p.m. the evening prior to Thanksgiving until 4:30 p.m. on Friday, the day after Thanksgiving and Terry shall have Trevor from 4:30 p.m. on Friday (the day after Thanksgiving) unti14:30 p.m. on the Sunday after Thanksgiving. 6. Pending further Order of Court, file Christmas custody shall be as detailed Paragraph 5 in file July 15, 1993 Order of Court, attached hereto. 7. The holiday custody schedule as defmed in Paragraphs 3, 4, 5, and 6 above shall take precedence over file regular custody schedule defined in Paragraph 2 above. Lucinda A. Monn, Plaintiff vs. Terry L. Monn, Defendant - Page 3 - F.R. 1991 0444 In Custody 8. Transportation shall be shared for all periods of physical custody other than on Tuesday evenings when Terry provides all transportation such that Terry shall be responsible for picking up the child for the exercise of Terry's custody and Lucinda shall pick up the child for the exercise of her custody. In the event neither parent is able to fulfill the transportation responsibilities, he or she may designate a responsible adult known to both parties and the child to act in his or her place and shall provide notice of said designation to the other party. The only exception shall be that if Lucinda shall be scheduled to work and is working on the day after the nationally recognized holiday for July 4th when Trevor has been with Terry for the July 4th holiday, then Terry or his designated driver shall return Trevor to Lucinda's care and custodyby 9:00 a.m. on July 5th the day after the nationally recognized holiday. 9. Neither party nor members of his or her respective family shall make any disparaging remarks regarding the other parent and his or her respective family members in the presence of , Trevor. 10. Neither party shall consume alcoholic beverages or use illegal drugs for the 24 hour period preceding and at all times during his or her periods of physical custody of Trevor. Excessive use of alcohol by others in Trevor's presence shall also be prohibited. 11. Reasonable telephone contact by the parent not exercising physical custody of Trevor shall be permitted by all parties two times a week. 12. Neither party will enroll the child in any activity that would infringe on the other parent's time with the child without first consulting the other parent. Said consultation shall be in written format specifying the date and time of the activity. The parties shall cooperate and make every effort to allow Trevor to participate in the activities of his choice as much as is possible taking into consideration both parents' schedule and the distance between the parties. , . 13. The costs in this proceeding have been paid by tile Plaintiff. By the Court, M 11 ~ NO"''^' 0(\ f (Z I CJC) Hy,~ QO',.t,,)s~-r- U IN THE COURT OF COMMON PLEAS OF THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA - FRANKLIN COUNTY BRANCH Lucinda A. Monn, Plaintiff/Petitioner Civil Action Law v. : No. F.R. 1991 - 444 Terry L. Monn, DefendantJRespondent Custody 000 1"....1.< ~ ~ .' ~, " , ..',' t"'"'" (..Q ......., Cl r''1 b " ::::;;: ~1il, ;~7~z~! ""'..)r-'''' and between Lucinda A. Monn, of hereinafter referred to as "Plaintiff', and Terry L. Monn, ofWaynesb Pennsylvania, hereinafter referred to as "Defendant". en .' .".).-. ...,.;'Z i;E;,;~Ji~1ft 'iC.q-n -~ :-i ~ '.:'_)>''''J -, m '_<.:r.l - -<0 :p 71 :? STIPULATION AND AGREEMENT THIS STIPULATION AND AGREEMENT is made 1. Plaintiff and Defendant are the natural parents of Trevor L. Monn, born February 23, . '1990. 2. Plaintiff and Defendant were married on August 11, 1989, in Hagerstown, Washington County, Maryland, and divorced by Decree entered on August 7, 1992. 3. With the exception of the action filed to the above-captioned number and t=, neither party has participated as a party in other litigation concerning the custody of the child in this Court. 4. None of the parties has information ofa custody proceeding concerning the child pending in a court of this Commonwealth. 5. None of the parties knows 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. 6. During the past 5 years, the child has resided with the following persons and at the following addresses: Persons Addresses Dates A. Lucinda A. Monn and Kathleen Fisher (maternal grandmother) 1528 Lakeshore Drive Chambersburg, P A 17201 from 1992 to August, 1997 B. Lucinda A. Monn and Kathleen Fisher August, 1997 to present 7. The parties have reached an agreement with regard to the custody of their minor child and desire to reduce their agreement to an Order of Court. NOW THEREFORE, the parties intend 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, , 19_, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: 1. 1. TerryL. Monn, hereinafter referred to as Terry, and LucindaA. Monn, , hereinafter referred to as Lucinda, shall have shared legal custody of their son, Trevor Monn, hereinafterreferred to as Trevor, born February 23,1990. 2. Lucinda shall have primary residential custody of Trevor subject to the following periods of partial custody in Terry: A. Each Tuesday from 5:00 p.m. nntil 7:30 p.m., Terry to have notified Lucinda at least 24 hours in advance ifhe is going to exercise said partial custody. Oe~ B. Commencing Alio..st 12..., 1997 and on alternate weekends thereafter from Friday at ' 4:30 p.m. until Sunday at 4:30 p.m. C. Beginning in June of 1998 and commencing the first Friday for Father's regularly scheduled weekend after school is out for summer vacation from Friday at 4:30 p.m. until the following Friday at 4:30 p.m. and alternating thereafter so that Terry has the first week after school is out and the child is back in Lucinda's custody for a full week before school commences and 1he parties having alternating weeks of custody in the interim. 3. Holidays shall be shared between 1he parties such that in 1997 and in all odd numbered years Terry shall have physical custody of Trevor on Easter Sunday and the nationally recogoized holiday for the Fourth of July celebration, and Lucinda shall have physical custody of Trevor on New Year's Day, the nationally recogoized holiday for the Memorial Day celebration and Labor Day. The holidays shall be reversed in even numbered years. The times for the holiday custody periods for Easter Day, New Year's Day, the nationally recognized holiday for the Memorial Day celebration and Labor Day shall be between the hours of 4:30 p.m. the evening prior to said holiday until 4:30 p.m. the day of said holiday. The times for the holiday custody for July 4th shall be from 9:00 a.m. on the nationally recognized holiday for July 4th until 9:00 a.m. the next day. 4. Terry shall have Trevor each and every Father's Day from 9:00 a.m. until 5:00 p.m. and Lucinda shall have Trevor each and every Mother's day from 9:00 a.m. until 5 :00 p.m. 5. Physical custody of Trevor sha11be shared for the Thanksgiving holiday such that in 1997 and all odd numbered years Terry shall have Trevor from 4:30 p.m. the evening prior to Thanksgiving until 4:30 p.m. on Friday, the day after Thanksgiving. In odd numbered years Lucinda shall have Trevor from 4:30 p.m. on Friday, (the day after Thanksgiving) until 4:30 on the Sunday after Thanksgiving. Said time period shall alternate on a yearly basis such that in 1998 and in even numbered Lucinda shall have Trevor from 4:30 p.m. the evening prior to Thanksgiving until 4:30 p.m. on Friday, the day after Thanksgiving and Terry ~hall have Trevor from 4:30 p.m. on Friday the day after Thanksgiving until 4:30 p.m. on the Sunday after Thanksgiving. 6. Pending further Order of Court, the Christmas custody shall be as detailed Paragraph 5 in the July 15, 1993 Order of Court, attached hereto. 7. The holiday custody schedule as defined in Paragraphs 3, 4, 5, and 6 above shall take precedence over the regular custody schedule defined in Paragraph 2 above. 8. Transportation shall be shared for all periods of physical custody other than on Tuesday evenings when Terry provides all transportation such that Terry shall be responsible for picking up the child for the exercise of Terry's custody and Lucinda shall pick up the child for the exercise of her custody. In the event neither pareut is able to fulfill the transportation responsibilities, he or she may designate a responsible adult known to both parties and the child to act in his or her place and shall provide notice of said designation to the other party. The only exception shall be that if Lucinda shall be scheduled to work and is working on the day after the nationally recognized holiday for July 4th when Trevor has been with Terry for the July 4th holiday, then Terry or his designated driver shall return Trevor to Lucinda's care and custody by 9:00 a.m. on July 5th the day after the nationally recognized holiday. 9. Neither party nor members of his or her respective family shall make any disparaging remarks regarding the other parent and his or her respective family members in the presence of Trevor. 10. Neither party shall consume alcoholic beverages or use illegal drugs for the 24 hour period preceding and at all times during his or her periods of physical custody of Trevor. Excessive use of alcohol by others in Trevor's presence shall also be prohibited. 11. Reasonable telephone contact by the parent not exercising physical custody of Trevor shall be pennitted by all parties two times a week. 12. Neither party will enroll the child in any activity iliat would infringe on the oilier parent's time with the child without first consulting the other parent. Said consultation shall be . in written format specifying the date and time of the activity. The parties shall cooperate and make every effort to allow Trevor to participate in the activities ofms choice as much as is possible taking into consideration both parents' schedule and the distance between the parties. 13. The costs in this proceeding have been paid by the Plaintiff. BY THE COURT: J. ......................................... 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 ofthis Agreement, execute this Agreement by signing below. Witness: ~/-I'/ 7~~'l ~. sA' ( (: u,cdL. 7Y(~ l.,Lu inda A. Monn ~ ~ ::z- Terry . Monn I verify that the facts set forth in the above 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. 'I Date: ~(jiC :~ ,1927 (!~,::!::cj~LJ I verify that the facts set forth in the above Stipulation and Agreement are true and correct. I understand that false statements herein are made subj ect to the penalties of 18 Pa. C.s. Section 4904, relating to unsworn falsification to authorities. Date: fa h.') I , 19'0 ~/~ Te . MonTI ' IN THE COUR.~ OF' COMMON PLEAS OF THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA FRANKLIN"COUNTY BRANCH Lucinda A. Monn : CIVIL ACTION LAW . . vs : . . Terry L. Monn : FR 1991 - 444 APPEARANCES: Carol L. Van Horn, Esquire, appears on behalf of the plaintiff. Terry L. Monn appears pro se. ORDER OF COURT NOW, this 15th day of July, 1993, on stipulation of Lucinda A. Monn and her attorney, Carol Van Horn, Esquire, and Terry L. Monn, pro se, it is ordered and decreed that: 1. Terry L. Monn hereinafter Terry, and Lucinda A. Monn, hereinafter Lucinda shall have shared legal custody of their son Trevor Monn hereinafter Trevor born February 23, 1990; 2. Lucinda shall have primary physical custody of Trevor subject to the following periods of partial custody in Terry: a. each Tuesday and Thursday from 2:30 p.m. until 5:30 p.m. b. beginning July 17,.1993 and on alternate EXHIBIT "A" saturdays thereafter fr~m 12~30 p.m. until,5:30 p,m. Providing that Terry has consistently exercised his rights to partial custody as described in subparagraph (b) above and has no more than two unexplained absences, then c. beginning September 12 and on alternate Sundays thereafter from 12:30 p.m. until 5:30 p.m. and again providing that Terry has consistently exercised his rights to partial custody as described in subparagraphs (b) and (C) above and has no more than two unexplained absences, then. d. beginning November 20 and on alternate weekends thereafter from 12:30 p.m. Saturday until 5:30 Sunday e. beginning in 1994 for one full week during the month of June, July or August with one additional week added each of the next three years such that Terry shall have Trevor for four full weeks during the summer months in 1997 with no more than two weeks to be exercised consecutively. Terry shall notify Lucinda in writing by May 1 of each year as 'co his desired week or weeks of custody during the summer months. 3. Holidays shall be shared between the parties such that in 1993 and all odd numbered years Terry shall have physical custody of Trevor on Easter Day, the nat~onally recognized hpliday for the Fqurth of July cele"bration, and Thanks"givinq Day, and Lucinda shall have physical custody of Trevor on New Years Day, the nationally recognized holiday for the Memorial Day celebration and Labor Day. The holidays shall be reversed in even numbered years. The times for the holiday cust~dy periods in 1993 shall be between the hours of 9:00 a.m. and 5:00 p.m. Beginning with Terry's partial custody of Trevor for the Memorial Day celebration in 1994 and continuing for all holidays thereafter the times fer holiday custody periods shall be from 7:00 p.m. the evening prior to the holiday until 5:00 p.m. on the holiday. 4. Terry shall have Trevor each and eve,ry Father's Day from 9:00 a.m. until 5:00 p.m. and Lucinda shall have Trevor each and every Mother's Day from 9:00 a.m. until 5:00 p.m. 5. Physical custody of Trevor shall be shared on Christmas such that in 1993 and all odd numbered years Lucinda shall have Trevor from noon on December 24 until noon on December 25, and Terry shall have Trevor from noon on December 25 until noon on December 26. Said time periods shall alternate on a yearly basis such that in 1994 and all even numbered years Terry shall have Trevor from noon on December 24 until noon on December 25 and Lucinda shall have,Trevor on noon December 25 until noon on December 26. 6. The holiday custody schedule as defined in paragraphs three, four and five above shall take precedence over the regular custody schedule defin,ed in paragraph two above. 7. Transportation for all periods of physical custody for Terry shall be provided by Terry. 8. Neither party nor members of his or her respective family shall make, any disparaging remarks regarding the ather parent and his or her respective family members in the presence of Trevor. 9. Terry shall make every effort to notify, Lucinda of any changes needed to the within schedule as far in advance as possible and Lucinda shall cooperate in signing written documentation of the requested changes anc the reasons therefore which shall be prepared by Terry anc presented by him to Lucinda for signature; 10. Neither party shall consume alcoholic beverages or use illegal drugs for the 24 hour period preceding and at all times during his or her periods of physical custody of Trevor. Excessive use of alcohol by others in Trevor's presence shall also be prohibited. 11. Reasonable telephone contact by the parent not exercising physical custody of Trevor shall be permi~ted by both part~e~~ 12. Costs to"be paid by the p1aintiff. By the Court, c::Z~~ ~ W. Keller, . S.J. cc: Carol Van Horn, Esq. (2), Terry Monn V\, -'2: ~ 0- :>:: ('. ~ C"( (j-.. c.~ -" \'1- ~::: -- t~~~ €:J ::J ~ ('/\ Cl~ }- :~ Q"~ """ ~ ""-'- t:J- Ci~ - (~}~..') 00 ":~-'(n 1 1.-:-:' :-~.: 52 ~ ~ I. I , cr: t'C2 .-... ..... 'I'u ~ \..-: C._ (fJa. "'" o:jt 'L. C'J -) 0 0 D . . PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TERRY L. MONN v. 02-1622 CIVIL ACTION LAW LUCINDA A. MONN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, April I?, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqnellne M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, May 15, 2002 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 herehy directs the parties to furnish any and aU existing Protection from Ahuse orders, Special Relief orders, and Custody orders to the conciliator 48 honrs prior to scheduled hearing. FOR THE COURT, By: Isl Jacqueline M. Verney. Esq. ?Jrv1 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 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 ATIORNEY AT ONCE. IF YOU DO NOT HA VB AN ATIORNEY 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 2 Liberty A venue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ",4...p~ -- ~ ~ <0(/.,7 .~~~ ~ ~14' ~t7'(I,t7 ~~ ~-77~>Y 4/"j ~ 'C't?-c./'~ NWil}..SNN3d t'\ VI r,' \'o1lICP8V'lnv J...LNn08 \.,:11. I..' . L I (\d~ 20 SG :s lid .r_,,3hl:.lO I tlV10NU,-IYJ"a;1\:1 ^ 38\:1:,0:J ~ 0 2002 TERRY L. MONN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2002-1622 CIVIL TERM LUCINDA A. MONN, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this \ \ day of ,~ V ~ ' 2002, upon , consideration of the attached Custody Conciliation Report, t IS ordered and dlrected as follows: 1. The prior Order of Court, dated December 19,2002 shall remain in full force and effect with the following additional provisions: 2. The parties shall submit to a Phase I custody evaluation with Georgi Anderson. The parties shall share the cost of said evaluation and cooperate with the scheduling of any appointment for the child. 3. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Either party may contact the Conciliator to schedule another Conciliation Conference. J. cC:~arylou Matas, Esquire, Counsel for Father 'Taylor Andrews, Esquire, Counsel for Mother I v. C~ &-11-0;). I ~ co ~ Ln 0 8 5<( t'3:z u::Q :lC ()~ u-L c:I: 025 ~b ~~ C" UJci.: -' Z lB~ o::~ =:J 1-- ..., ::i: ~ ('-J ::') 0 (,) JU~ 2002 TERRY L. MONN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2002-1622 CIVIL TERM LUCINDA A. MONN, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Trevor Lyn Monn February 23,1990 Mother 2. A Conciliation Conference was held in this matter on June 5 and June 7, 2002, with the following individuals in attendance: The Father, Terry L. Monn, with his counsel, Marylou Matas, Esquire and the Mother, Lucinda A. Monn, with her counsel, Taylor Andrews, Esquire. The child, Trevor Lyn Monn, was also present on June 7, 2002 and spoke with the Conciliator. 3. A prior Order of Court, dated December 19, 1997 was entered by the Honorable Douglas Herman of Franklin county, Pennsylvania that provided for shared legal custody, Mother having primary physical custody during the school year with Father having alternating weekends and Tuesday evenings. During the summer, the parties have shared physical custody on a week on/week off basis. 4. Father filed for a modification of the prior Order seeking shared physical custody year round maintaining that the child indicated to him that he wanted to spend more time with his Father. The child advised the Conciliator that he may have given his Father that impression but that it was not accurate. Father is a 'stay at home' Dad. Father requested additional time with the child which Mother refused. 5. &-7-0'1- Date The parties agreed to the entry of an Order in the form as attached. ~<j;,.<~ cq line M. Verney, Esquire Custody Conciliator JAN 0 3 2003 \S TERRY L. MONN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2002-1622 CIVIL TERM LUCINDA A. MONN, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 2nd day of January, 2003, as the parties have not contacted the Conciliator since June 7, 2002 to request a Conference, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, b*li;~, Cust y Conciliator ). .~), _ _~..........i ; \-J\N'Ifi\lASNN3d AL'\lnCn C1\\:\ri'):~jgv~nC) '"' ~ :fll tPi Q - 1,\\1\" eo ~;;l I..' "..\I -' I'j~ t" Plaintiff : IN THE COUlU OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA TERRY L. MONN v. : CIVIL ACTION - LAW LUCINDA A. MONN Defendant : NO. 2002.1622 CIVIL TERM : IN CUSTODY STIPULATION REGARDING CUSTODY. VISITATION Plaintiff, TERRY L. MONN, hereinafter referenced as Father, and Defendant, LUCINDA A. MONN, hereinafter referred to as Mother, hereby agree to the entry by the Honorable Edgar B. Bayley of the following terms in a Court Order defining custody and partial custody rights and responsibilities in relation to the parties' minor child: TREVOR L YN MONN born February 23, 1990, hereinafter referenced as TREVOR: (1) Legal custody of TREVOR as contemplated by the: Act of November 5, 1984, P.S. gIOOI, et seq., is awarded to Mother. (2) Physical custody of TREVOR is awarded to Moth\:r subject to unscheduled partial custody by Father as shall be agreed to by Father and TREVOR (3) Father and Mother shall provide transportation for TREVOR so that the parent obtaining TREVOR shall provide the transportation, until TREVOR has obtained a drivers license and can arrange his 0 ~?icL?h TE L. MONN, Plaintiff 5tIJ~c;4~ CJLPCINDA A. MONN, De endant AGREEMENT RE: CUSTODY AND SUPPORT OF TREVOR L YN MONN AGREEMENT, made this 1'iJ" day of OJ? ,2005, between TERRY L. MONN (hereinafter called "Father") and LUCINDA A. MONN (hereinafter called "Mother"). WITNESSETH: The parties hereto are Father and Mother of TREVOR L YN MONN, born February 23, 1990. There are currently Court Orders in existence that establish legal custody and partial physical custody rights of Father with regard to TREVOR, and that also require Father to pay child support to Mother for TREVOR L YN MONN; Due to changing personal dynamics and relationships, Father and Mother desire to change these existing Court Orders so that Father's support obligation will be suspended effective July 1,2005, and so that TREVOR L YN MONN will be empowered to approve or disapprove of all partial custody by Father. NOW THEREFORE, in consideration of the premIses and of the mutual promises, covenants and undertakings hereinafter set forth, Father and Mother, each intending to be legally bound hereby, covenant and agree as follows: 1. Father shall sign the Stipulation regarding custody in the same form as is attached hereto. 2. Upon receipt of Father's signed Stipulation, Mother shall file a request with the Franklin County Domestic Relations Office to suspend the operation of the support order [PACSES #1102000328] that directs Father to pay support for Trevor Lyn Monn effective July I, 2005 and including all arrearages that existed as of July 1,2005, and including all collection of medical expenses incurred before or after July 1, 2005. 3. After Mother has acted to suspend the support order as indicated in paragraph #2 above, Mother shall file the stipulation regarding custody as is referenced in paragraph #1 above. 4. Mother and Father each acknowledge that this agreement may be terminated by either at any time by the filing of an action to reinstate the support or to amend the custody order. 5. Each party hereby expresses his and her present intent to abide by this agreement into the future. IN WITNESS WHEREOF, the parties hereto have set their hands the day and year first above written. This Agreement is executed in duplicate, and in counterparts, and Father and ge the receipt of a duly executed copy hereof. 0/ O~EI~~ 1. MONN )/J'/if~iLctl.lm~ -' ~ LUCINDA A. MONN (") C- -,...; ,,'c ;:~ r~ ~ .;;;,':';:) "'" 2: G") N v> c L~ ~-\ ./., ~ ..-\ :r;~ rnf=.: -aI:f' ",,0 J..J . (),(') -::i ::r: ;::':~';~, ;/~ ?f. :~?\ ");.- 'a - r N -