HomeMy WebLinkAbout01-4635WILLIAM A. DOYLE,
Plaintiff/Petitioner
VS.
PATRICIA A. DOYLE,
Defendant/Respondent
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
No. ol -
Civil Action - Custody
CUSTODY AGREEMENT
ANDNOW, this /¢ day of ,_.~,~ 2001come the parties, WilliamA.
/
Doyle and Patricia A. Doyle, and requests this Honorable Court enter the attached Order for the
following reasons:
WHEREAS, William A. Doyle, (hereinafter referred to as "FATHER") and Patricia A.
Doyle, (hereinafter referred to as "MOTHER") are the natural parents of Brooke A. Doyle (DOB
11/12/97); and
WHEREAS, FATHER and MOTHER desire to make arrangements for the custody and
visitation of the said minor child; and,
WHEREAS, both parties have been advised by counsel or have had the opportunity to be
advised by counsel; and,
WHEREAS, the parties intend to submit this Custody Agreement to the Court of
appropriate jurisdiction for incorporation and merger into a Court Order approving said Agreement;
NOW, THEREFORE, it is hereby stipulated and agreed as follows:
1. The Petitioner, WILLIAM A. DOYLE, is an adult individual residing at 4183 Cove
Court, Apt. 108, Mechanicsburg, Cumberland County, Pennsylvania 17055.
Document # 194833 l
2. The Respondent, PATRICIA A. DOYLE, is an adult individual residing at 136 West
South Street, Carlisle, Cumberland County, Pennsylvania 17013.
3. For the past five (5) years, the minor child has resided with the following persons at
the following addresses:
Name
William A. Doyle
Patricia A. Doyle
Address
4183 Cove Court, Apt. 108
Mechanicsburg, PA 17055
120 W. Main Street
Walnut Bottom, PA 17036
136 W. South Street
Carlisle, PA 17013
Dates
11/2000 to
present
1996 to
11/2000
11/2000 to
present
120 W. Main Street 1996 to
Walnut Bottom, PA 17036 11/2000
The Mother of the child is Patricia A. Doyle, who resides at 136 W. South Street,
Carlisle, Cumberland County, Pennsylvania. She is not married.
5. The Father of the children is William A. Doyle, who resides at 4183 Cove Court,
Apt. 108, Mechanicsburg, Pennsylvania 17055. He is not married.
6. The relationship of Petitioner to the minor child is that of Father. Petitioner currently
resides with the following persons.
Name Relationship
William A. Doyle self
7. The relationship of Respondent to the minor child is that of Mother. Respondent
currently resides with the following persons:
Document #: 194833.1
Name Relationship
Patricia A. Doyle self
Brooke A. Doyle Daughter
Kelly Gettle Boyfriend
10.
DOYLE.
11.
8. Brooke A. Doyle is presently in the custody of PATRICIA A. DOYLE, who
resides at 136 W. South Street, Carlisle, Pennsylvania.
9. MOTHER shall have majority physical custody of the minor child, and FATHER
shall have minority physical custody.
Both FATHER and MOTHER will have shared legal custody of BROOKE A.
Visitation by FATHER will be at on alternating weekends from Friday at 10:00 a.m.
through Sunday at 5:00 p.m.
12. FATHER will have Wednesday visitation with BROOKE A. DOYLE from 5:30
p.m. to 8:00 p.m. on the week that he does not have the minor child for the weekend.
13. The parties shall alternate New Year's Day, Easter Sunday, Memorial Day, Fourth
of July, and Labor Day from year to year. In 2001 and odd numbered years thereafter, FATHER
shall have Easter Sunday, Fourth of July and MOTHER shall have New Year's Day, Memorial Day
and Labor Day. In the year 2002 and even numbered years thereafter, FATHER shall have New
Year's Day, Memorial Day and Labor Day and MOTHER shall have Easter Sunday, and Fourth of
July. Unless otherwise agreed between the parties, the holiday partial custody shall commence at
9:00 a.m. and shall end at 9:00 p.m.
Document #: 194833.1
14. MOTHER shall have Mother's Day and FATHER shall have Father's Day. This
provisions shall supersedes all other custody provisions. Unless otherwise agreed the period of
partial custody will commence at 9:00 a.m. and end at 9:00 p.m.
15. The parties shall divide Christmas vacation as follows:
The period of time from December 24 at 2:00 p.m. through December 25 at 2:00
p.m. shall be identified as Segment A. The period of time from December 25 at 2:00 p.m. to
December 26 at 8:00 p.m. shall be identified as Segment B. MOTHER and FATHER shall
alternate Segment A and B with MOTHER having segment A on 2001 and every other year
thereafter.
16. The parties shall divide Thanksgiving Day as follows:
The period of time from the day before Thanksgiving at 2:00 p.m. through
Thanksgiving Day at 2:00 p.m. shall be identified as Segment A. The period of time from
Thanksgiving Day at 2:00 p.m. to the day after Thanksgiving at 8:00 p.m. shall be identified as
Segment B. MOTHER and FATHER shall alternate Segment A and B with MOTHER having
segment A on 2001 and every other year thereafter.
17. The parties agree that neither will attempt to move from the Commonwealth of
Pennsylvania with the child without first obtaining the written consent of the other parent or
obtaining a Court Order permitting such move.
18. FATHER is entitled to up to three (3) weeks of summer vacation. Each parent must
provide to the other advance written notice of their intent to exercise those weeks with a thirty (30)
day advance notice.
Document #: 194833 l
19. Both parties shall permit liberal telephone calls to the minor child from the non-
custodial parent.
20. The parties agree to cooperate with one another in the implementation of the
aforesaid Agreement and understand and agree that other changes or modifications in the aforesaid
schedule and/or times specified may be necessary to enable both parents to continue to foster and
develop a good and healthy relationship with the children. To that end, the parties agree to
cooperate with one another to encourage the relationship of the children with the other parent and
agree to refrain from any and all conduct, activity, or communication which would adversely affect
the children's relationship with either parent.
21. Upon the knowledge of pending relocation, temporary or permanent, of either
parent, each parent must immediately inform the other of his/her new address and telephone
number.
22. Both parties shall utilize child restraint seats and seat belts while transporting the
child by automobile.
23. This Agreement shall be effective immediately upon signature by both parties and
its validity is not contingent upon Cou~ approval.
/ / William A. Do3?le, Plaint~f "
Date: 7/ ]~ /[_.)1
Patricia A. Doyle, Defendant
Document #: 194833 1
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF O_~o~.~.~e.~4.~,x~_[
SS
Personally appeared before me, a notary public in and for said Commonwealth and County,
the undersigned, WILLIAM A. DOYLE, Plaintiff, who, being duly sworn according to law,
deposes and says that he is the FATHER and that the facts set forth in the within Custody
Agreement are tree and correct to the best of his knowledge, information, and belief.
x3~illia~n-A. Doyle.'P~aintiff-- I ~
Sworn to and subscribed
before me this ~'4 day
of ~/ ,2001.
josep~ L Grove, N?~._~. ~'u~E.. /
My Conimisslon Expires .June ~, ~ I
Member, pennsylvania I~sociat~on of Notaries
Document #' 208229 1
WiI,LIAM A. DOYLE,
PlaJntiflTPetitioner
VS.
PAI'RICIA A. DOYLE,
Defendant/Respondent
IN THE ('OUI~ I ()1: ('()MM()N PI,EAS
CUMBER[,AN I) ('O[ 5N'I'Y,
PENNSYI~VANIA
Civil Action - Custody
CONSENT ORDER PURSUANT TO
PA.R.C.P. IN(). 1915.7
AND NOW. this day of . 2001, upon review and
consideration of the Custody Agreement of the parties hereto, a copy of which is mtached hereto.
said Agreement is hereby APPROVED, Al)OPTED. MERGED and INCORPORATED herein as
the Order of this Court.
Stcven C. Courtney, Esquire