HomeMy WebLinkAbout02-2302PAUL A. KELLER,
Plaintiff
V.
TRACI M. COLM,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
IN CUSTODY
COMPLAINT IN CUSTODY
AND NOW, this ~ day of /~O~[{~t ,201~L comes the Plaintiff, Paul A. Keller,
by and through his attorney, Melissa L. Van Eck, Esquire, and the law firm of Metzger,
Wickersham, Knauss & Erb, P.C., and files the within Complaim of which the following is a
s~temem:
1.
The Plaintiff, Paul A. Keller, is an adult individual residing at 309 Race Street,
Middletown, Dauphin County, Pennsylvania, 17057.
2. The Defendant, Traci M. Colm, is an adult individual residing at 856 Melissa Court,
Enola, Cumberland County, Pennsylvania, 17025.
3. Plaintiff seeks partial physical custody and shared legal custody of the following
child:
Nallle
Draven Patrick Keller
Present Address Date of Birth
856 Melissa Court 01/19/2002
Enola, PA 17025
Plaintiff and Defendant are the natural parents of the above-mentioned minor child.
The child was bom out-of-wedlock.
Document #: 233243.1 1
The child is presently in the custody of Defendant who resides at 856 Melissa
Court, Enola, Cumberland County, Pennsylvania, 17025.
Since birth, the child has resided with the following persons at the following addresses:
Name Address Date
Traci M. Colm 856 Melissa Court From birth to present time.
Enola, PA 17025
The mother of the child is Defendant, Traci M. Colm, who resides at 856 Melissa
Court, Enola, Cumberland County, Pennsylvania, 17025.
The father of the child is Plaintiff, Paul A. Keller, who resides at309 Race Street,
Middletown, Dauphin County, Pennsylvania, 17057.
4. The relationship of Defendant to the children is that of natural mother. The
Defendant resides with the following persons:
Name Relationship
Self
The relationship of Plaintiff to the child is that of natural father. The Plaintiff
currently resides with the following persons:
Name Relationship
Donna Keller Mom
Lori Keller Sister
John Keller, Jr. Brother
6. Plaintiff has not participated as a party or wimess, or in any other capacity in any
other litigation concerning the custody of the child in this or another Court.
Plaintiffhas no information of a custody proceeding concerning the children
pending in a Court of Law of this Commonwealth.
Document #: 233243.1 2
Plaintiff does not know of a person not a party to the proceedings who has physical
custody of the children or claims to have custody or visitation with respect to the children.
7. The best interest and permanent welfare of the children will be served by granting
the relief requested because:
a. Plaintiff, Paul A. Keller, has been a primary caregiver of the minor child
since birth.
b. Plaintiff, Paul A. Keller, is in a position, both financially and
emotionally, to provide stability and custody for the minor child.
c. Plaintiff is in a position to provide a stable, responsible
environment for the raising of the minor child.
d. The best interests of the minor child will best be served by having a
relationship with his father.
8. Each parent whose parental rights to the children have not been terminated and the
person who has physical custody of the children have been named as parties to this action.
WHEREFORE, the Plaintiff, Paul A. Keller, requests the Court to grant him partial
physical and shared legal custody of the minor child.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By
Attorney I.D. No. 85869
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorneys for Plaintiff
Paul A. Keller
Date: May
~/ ,2002
Document #: 233243.1 3
VERIFICATION
I, PAUL A. KELLER, hereby certify that the facts set forth in the foregoing Complaint In
Custody are tree and correct to the best of my knowledge, information and belief, and that false
statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom
falsification to authorities.
Date: May "/ ,2002
PAUL A. KELLER
Document #: 233243.1
PAUL A. KELLER
PLAINTIFF
V.
TRACI M. COLM
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
02-2302 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Thursday, May 16, 2002 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator,
at 301 Market Street, Lemoyne, PA 17043 on Monday, June 17, 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 de£me 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 prior to scheduled hearing.
FOR THE COURT,
By: /s/
Melissa P. Greenly, 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 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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
JUN 2, :1 200~ ~-'
PaUL A. KELLER,
TRACI M. COLM,
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-2302 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
INTERIM ORDER OF COURT
AND NOW, this , tf?l[, day of ~ ,2002, upon consideration
of the attached Custody Conciliation Summar~Rep(~r~, it is hereby ordered and directed as
follows:
1. ~. The parties, Paul A. Keller and Traci M. Colm, shall have shared
legal custody of the minor child, Draven Patrick Keller, born January 19, 2002. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make all major non-
emergency decisions affecting the child's general well-being including, but not limited to, all
decisions regarding his health, education and religion. Pursuant to the terms of Pa. C. S.
§5309, each parent shall be entitled to all records and information pertaining to the child
including, but not limited to, medical, dental, religious or school records, the residence
address of the child and of the other parent. To the extent one parent has possession of
any such records or information, that parent shall be required to share the same, or copies
thereof, with the other parent within such reasonable time as to make the records and
information of reasonable use to the other parent.
2. ~. Mother shall have primary physical custody. Father shall
have partial physical custody arranged as follows:
A. On each Wednesday evening from 4:45 p.m. until 8:00 p.m. The
parties contemplate that the return time for the Wednesday evening period of custody
will be changed to a later return time as the child gets older and bedtime is later.
Father shall provide all transportation incident to his periods of custody on
Wednesdays.
B. June 29, 2002 and June 30, 2002 from 10:00 a.m. to 5:00 p.m.
Transportation for these visits shall be shared with the parent receiving custody
providing the transportation.
C. The weekends of July 6, 2002 and July 20, 2002 from Saturday at
10:00 a.m. until Sunday at 5:00 p.m. Mother shall provide all transportation incident
to these periods of custody.
D. Effective August 2, 2002 from Friday at 5:00 p.m. until Sunday at 5:00
p.m. on alternate weekends. The parent receiving custody shall provide
transportation incident to Father's periods of custody.
A. Mother's Day/Father's Day. Mother shall have custody for Mother's
Day. Father shall have custody for Father's Day. In the event that this holiday falls
on the non-custodial parent's weekend, the period of custody shall be from 10:00
a.m. to 8:00 p.m.
B. D. tJ3~J:fl;~. The parties shall have an alternating holiday schedule
which shhll begin with Father having Independence Day 2002. The following
holidays will be alternated: Easter, Memorial Day, 4th of July, Labor Day and
Thanksgiving.
C. Christmas. Christmas shall be shared on an NB schedule. Segment A
shall be from December 24th at 10:00 a.m. until December 25th at 12:00 p.m.
Segment B shall be from December 25th at 12:00 p.m. until December 26th at 5:00
p.m. In even numbered years, Mother shall have Segment A and Father shall have
Segment B. In odd numbered years, Father shall have Segment A and Mother shall
have Segment B.
4. At Mother's expense, private home studies will be performed on both parties' homes.
5. A hearing is scheduled in Courtroom Number
Courthouse, on the ~,~- day of ~ of the Cumberland County
, 200 ;, at ~.',/'_~ o'clock
~- .M., at which time testimony will be taken. For the purposes of the hearing, the Mother,
, shall be deemed to be the moving party and shall proceed initially
with testimony. Counsel for the parties or the parties pro se shall file with the Court and
opposing counsel/party a memorandum setting forth each party's position on custody, a list
of witnesses wh.o are expected to testify at the hearing, and a summary of the anticipated
testimony of each witness. These memoranda shall be filed at least ten days prior to the
hearing date. Reports of the home studies shall be
hearing.
Dist:
Melissa L. Van Eck, Esquire, P.O. Box 5300, Harrisburg, PA 17110-0300 -
James W. Abraham, Esquire, 513 North Second Street, Harrisburg, PA 1 I
at least ten days prior to the
PAUL A. KELLER,
TRACI M. COLM,
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-2302 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPO~ I
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:
Draven Patrick Keller
Janua~ 19,2002
CURRENTLYIN THE CUSTODY OF
Mother
2. A Custody Conciliation Conference was held on June 17, 2002 pursuant to the
Petition filed by Father on May 9, 2002. Attending the conference were the Father, Paul A.
Keller, and his counsel, Melissa Van Eck, Esquire; the Mother, Traci M. Colm, and her
counsel, James W. Abraham, Esquire.
3. The parties reached an agreement about a holiday schedule and weekly
partial custody for Father on Wednesday evenings. Additionally, the parties reached an
agreement for a plan to share transportation and legal custody. The issues unresolved
were the sharing of Christmas and how long Father would need to wait for having periods of
custody which would including having the child in his care over night.
4. Father's position on custody is that he wants an opportunity to continue to
develop his relationship with the child and for the child to get to know his family. He
acknowledges that Mother has allowed some periods of custody in the last few months.
However, he states that at the beginning of these times would not allow him to remove the
child from her home during those periods of custody. She did, however, let him serve as a
baby-sitter on some Thursday evenings when she would go bowling. Father works Monday
through Friday from 8:00 a.m. to 4:30 p.m. in Harrisburg. He does not work weekends.
Initially, Father asked for alternating weekends from Friday after work until Sunday evening
at 5:00 p.m. He later, in an attempt to resolve the dispute, offered to have alternate
weekend custody for the period from Saturday at 10:00 a.m. until Sunday at 5:00 p.m. This
was also unacceptable to Mother.
5. Mother's position on custody is that the child has not had much contact with
Father and that this baby needs to be home with her by no later than 8:00 p.m. so that she
can go through the structure of his bedtime routine. She believes that the structure is very
important to this baby's well being. She does not rule out the possibility that Father could
have periods of overnight physical custody at some point in the future. However, she
believes that he is too young to have periods of overni ht custod
age six months. Her nr ,~ oo, ~o *~ ,=-.. ..... g. y away from her home at
~. o,.o.,u, ,o ,u ,,..[ ~-amers weekend time to be on Saturdays and
Sundays from 12:00 p.m. to 6:00 p.m. on alternate weekends. Mother Presently works in
Harrisburg from 7:00 a.m. to 3:00 p.m., Monday through Friday. The child is in a day care
arrangement in Enola during Mother's work hours. The child has been in day care since
age six weeks. Mother expressed concern that because of the Father's limited contact with
the child that he would not be able to comfort the child if he cried.
6. The Conciliator made a recommendation to the parties which would provide a
tiered order gradually increasing Father's time and starting full weekend periods of custody
in August. Because the Mother did not agree with the recommended Order, Mother is
asking for a hearing before Court. She is also asking for home studies which shall be done
on both homes at Mother's expense.
7. The Conciliator provides the attached recommended interim physical custody
order which contains the parties' agreements on all holidays but Christmas, legal custody
and Wednesday evening partial custody with Father.
Date
MelTsSa Peel Gmevy, Esl~uire
Custody Conciliator
:159669
PAUL A. KELLER, :
Plaintiff :
TRACI M. COLM, :
:
Defendant :
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-2302
CIVIL ACTION - LAW
IN CUSTODY
STIPULATED CUSTODY AGREEMENT
WHEREAS, Paul A. Keller, hereinafter referred to as "Plaintiff," and Traci M. Colm,
hereinafter referred to as "Defendant," are the natural parents of Draven Patrick Keller (d.o.b.
January 19, 2002); and
WHEREAS, Plaintiff and Defendant desire to make custody arrangements for the
custody and visitation of the said 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 Stipulated 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. Legal Custody. The parties shall share legal custody of the minor child. Each
parent shall have an equal right, to be exercised jointly with the other parent, to make all of the
major non-emergency decisions affecting the child's general well-being, including, but not
limited to, all decisions regarding his health, education, and religion. Pursuant to the te~ms of
Document #: 240785.1
Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child
including, but not limited to, medical, dental, religious, or school records, the resident address of
the child, and of the other parent. To the extent that one parent has possession of any such
records or info,xxxation, that parent shall be required to share the same, or copies thereof, with the
other parent within such reasonable time as to make the records and information of reasonable
use to the other parent.
2. Physical Custody. Mother shall have primary physical custody. Father shall have
partial physical custody arranged as follows:
a. On each Wednesday evening from 4:45 p.m. until 8:00 p.m. The parties
contemplate that the return time for the Wednesday evening period of custody will be
changed to a later return time as the child grows older and bedtime is later. Father shall
provide all transportation incident to his periods of custody on Wednesdays.
b. Father shall also have periods of custody alternating weekends from
Friday, 5:00 p.m., until Sunday, 5:00 p.m. The parent receiving custody shall provide
transportation incident to Father's alternating weekend custody.
3. Holidays.
a. Mother's Day/Father's Day. Mother shall have custody for Mother's Day.
Father shall have custody for Father's Day. In the event that this holiday falls on the non-
custodial parent's weekend, the period of custody shall be from 10:00 a.m. until
8:00 p.m.
Document #: 240785.1 2
b. Other holidays. The parties shall have an alternating holiday schedule
which shall begin with Father having Independence Day, 2002. The following holidays
will be alternated:
(1)
(2)
(3)
(4)
Easter
Memorial Day
Fourth of July
Labor Day
(5) Thanksgiving
c. Christmas. Christmas shall be shared on an A/B schedule. Segment "A"
shall be from December 24, at 5:00 p.m., until December 25, at 5:00 p.m. Segment "B"
shall be from December 25, at 5:00 p.m., until December 26, 5:00 p.m. In even
numbered years, Mother shall have Segment "A" and Father shall have Segment "B." In
odd numbered years, Mother shall have Segment "B" and Father shall have
Segment "A."
4. Vacations. Each parent shall be entitled to two non-consecutive weeks of
vacation during the summer. Each party's summer vacation weeks shall include the parent's
regularly scheduled weekend, and each week shall be from Sunday, 12:00 noon, until the
following Sunday, 12:00 noon. The parties are responsible for providing thirty (30) days written
notice of the weeks they wish to utilize for vacation purposes.
5. The Holiday schedule shall take precedence over the regularly scheduled
custodial periods.
Document #: 240785.1 3
6. Both 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 all parties to continue to
foster and develop a good and healthy relationship with the child. To that end, the parties agree
to cooperate with one another to encourage the relationship of the child with each other and
agree to refrain from any and all contact, activity, or communication which would adversely
affect the child's relationship with either party. Neither party shall make disparaging comments
about the other in front of the minor child, nor will they permit any other relative or any other
party to do so.
7. Both parties shall be responsible for providing the other party with a current
telephone number and address at all times.
8. Both parties agree that this Agreement may only be modified in writing or
through further Order of Court.
9. This Agreement shall be effective immediately upon signature of the parties and
its validity is not contingent upon court approval.
WHEREFORE, the parties pray that the Court enter the Order attached hereto.
We verify that the statements made in this Agreement are tree and correct. We
understand that false statements herein are made subject to the penalties of Pa.C.S. §4904
relating to unsworn falsifications to authorities.
PAUL A. KELLER/Plaintiff Father
Document 14: 240785.1 4
Date:
TP~CI M. COLM/Defendant Mother
Document #: 240785.1 5
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
ACKNOWLEDGEMENT
Personally appeared before me, a notary public in and for said Commonwealth and County,
the undersigned, Paul A. Keller, Plaintiff Father, who, being duly sworn according to law, deposes
and says that he is the Father and that the facts set forth in the within Stipulated Custody Agreement
are tree and correct to the best of his knowledge, information, and belief.
IN WITNESS WHEREOF, I hereunto set my hand and official seal this .2,~---day of
Notary Public
My Commission Expires:
(SEA[)
CAROL A, LYTER, Notary
Ctty of Harrisburg, Dauphin
My Corem salon Exp res Dee, 28, 2004
COMMONWEALTH OF PENNSYLVANIA :
COUNTY OF DAUPHIN :
ACKNOWLEDGEMENT
Personally appeared before me, a notary public in and for said Commonwealth and County,
the undersigned, TRACI M. COLM, Defendant Mother, who, being duly sworn according to law,
deposes and says that she is the Mother and that the facts set forth in the within Stipulated Custody
Agreement are tree and correct to the best of her knowledge, information, and belief.
IN WITNESS WHEREOF, I hereunto set my hand and official seal thisc,Q07~ay of
~,~ ~ t-, 2002. ~ _
Notary Public
My Commission Expires:
Document #: 240785.1
(SEAL)
Notarial Seal
James W. Abraham, Notary Pubiic
City of Harrisburg, Dauphin Count7
My Commission Expires Apr. 30, 2005
Member, Pennsylvania Association of Nofa~es
PAUL A. KELLER,
Plaintiff
TRACI M. COLM,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-2302
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this b~'xlay of ~, 2002, upon review and consideration
of the Stipulated Custody Agreement of the parties, a copy of which is attached hereto, said
Agreement is HEREBY APPROVED, ADOPTED, MERGED and INCORPORATED herein as
the Order of this Court.
C;
Melissa L. Van Eck, Esquire (Attorney for Plaintiff)
James W. Abraham, Esquire (Attorney for Defendant)
Document ii.. 240785.1
PAUL A. KELLER, :
Plaintiff :
TRACI M. COLM, :
Defendant :
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-2302
CIVIL ACTION - LAW
IN CUSTODY
STIPULATED CUSTODY AGREEMENT
WHEREAS, Paul A. Keller, hereinafter referred to as "Plaintiff," and Traci M. Colm,
hereinafter referred to as "Defendant," are the natural parents of Draven Patrick Keller (d.o.b.
January 19, 2002); and
WHEREAS, Plaintiff and Defendant desire to make custody arrangements for the
custody and visitation of the said 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 Stipulated 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. Legal Custody. The parties shall share legal custody of the minor child. Each
parent shall have an equal right, to be exercised jointly with the other parent, to make all of the
major non-emergency decisions affecting the child's general well-being, including, but not
limited to, all decisions regarding his health, education, and religion. Pursuant to the terms of
Document tr: 240785.1
Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child
including, but not limited to, medical, dental, religious, or school records, the resident address of
the child, and of the other parent. To the extent that one parent has possession of any such
records or information, that parent shall be required to share the same, or copies thereof, with the
other parent within such reasonable time as to make the records and infmmation of reasonable
use to the other parent.
2. Physical Custody. Mother shall have primary physical custody. Father shall have
partial physical custody arranged as follows:
a. On each Wednesday evening from 4:45 p.m. until 8:00 p.m. The parties
contemplate that the return time for the Wednesday evening period of custody will be
changed to a later return time as the child grows older and bedtime is later. Father shall
provide all transportation incident to his periods of custody on Wednesdays.
b. Father shall also have periods of custody alternating weekends from
Friday, 5:00 p.m., until Sunday, 5:00 p.m. The parent receiving custody shall provide
transportation incident to Father's alternating weekend custody.
3. Holidays.
a. Mother's Day/Father's Day. Mother shall have custody for Mother's Day.
Father shall have custody for Father's Day. In the event that this holiday falls on the non-
custodial parent's weekend, the period of custody shall be from 10:00 a.m. until
8:00 p.m.
Document #: 240785.1 2
b. Other holidays. The parties shall have an alternating holiday schedule
which shall begin with Father having Independence Day, 2002. The following holidays
will be alternated:
(1)
(2)
Easter
Memorial Day
(3)Fourth of July
(4)Labor Day
(5)Thanksgiving
c. Christmas. Christmas shall be shared on an A/B schedule. Segment "A"
shall be from December 24, at 5:00 p.m., until December 25, at 5:00 p.m. Segment "B"
shall be from December 25, at 5:00 p.m., until December 26, 5:00 p.m. In even
numbered years, Mother shall have Segment "A" and Father shall have Segment "B." In
odd numbered years, Mother shall have Segment "B" and Father shall have
Segment "A."
4. Vacations.. Each parent shall be entitled to two non-consecutive weeks of
vacation during the summer. Each party's summer vacation weeks shall include the parent's
regularly scheduled weekend, and each week shall be from Sunday, 12:00 noon, until the
following Sunday, 12:00 noon. The parties are responsible for providing thirty (30) days written
notice of the weeks they wish to utilize for vacation purposes.
5. The Holiday schedule shall take precedence over the regularly scheduled
custodial periods.
Document ii: 240785.1 3
6. Both 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 ail parties to continue to
foster and develop a good and healthy relationship with the child. To that end, the parties agree
to cooperate with one another to encourage the relationship of the child with each other and
agree to refrain from any and all contact, activity, or communication which would adversely
affect the child's relationship with either party. Neither party shall make disparaging comments
about the other in front of the minor child, nor will they permit any other relative or any other
party to do so.
7. Both parties shall be responsible for providing the other party with a current
telephone number and address at all times.
g. Both parties agree that this Agreement may only be modified in writing or
through further Order of Court.
9. This Agreement shall be effective immediately upon signature of the parties and
its validity is not contingent upon court approvai.
WHEREFORE, the parties pray that the Court enter the Order attached hereto.
We verify that the statements made in this Agreement are true and correct. We
understand that faise statements herein are made subject to the penaities of Pa.C.S. {}4904
relating to unsworn falsifications to authorities.
Date:
PAUL A. KELLER/Plaintiff Father
Document #: 240785.1 4
Date:
TR~CI M. COLM/Defendant Mother
Document #: 240785.1 5
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
ACKNOWLEDGEMENT
Personally appeared before me, a notary public in and for said Commonwealth and County,
the undersigned, Paul A. Keller, Plaintiff Father, who, being duly sworn according to law, deposes
and says that he is the Father and that the facts set forth in the within Stipulated Custody Agreement
are tree and correct to the best of his knowledge, information, and belief.
,/qas~r''n'olN WITNESS WHEREOF, I hereunto set my hand and official seal this .2.z~---day of
. ,2002.
Notary Public
My Commission Expires:
(SEAL)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
CAROL A. LYTER, Notary
City of Hard~urg, Dauphin
My Commission Expires Dau. 28, 2004~
ACKNOWLEDGEMENT
Personally appeared before me, a notary public in and for said Commonwealth and County,
the undersigned, TRACI M. COLM, Defendant Mother, who, being duly sworn according to law,
deposes and says that she is the Mother and that the facts set forth in the within Stipulated Custody
Agreement are true and correct to the best of her knowledge, information, and belief.
.~ ~ IN WITNESS WHEREOF, I hereunto set my hand and official seal thisc~TV~clay of
taoov ~ ~/-, 2002.
Notary Public
My Commission Expires:
Document #: 240785.1
(SEAL)
Notarial Seal
Jallles..W..~.~m., Notary Public
, ?tYco~i .l'l~m~sou_rg .Dauphin County
~ m ss~on Expires Apr. 30, ~
Mernl3er, Pennsylvania Association of Notaries