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HomeMy WebLinkAbout02-2321DIANE R. CRUM PLAINTIFF V. RONALD E. CRISAMORE DEFENDANT : 02-2321 : IN CUSTODY ORDER OF COURT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW 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 12:30 PM 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 enh3' 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. Greevy. Esq. t.c6? 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 heating or business before the corot. 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 Diane Crum/5.8.02/Custody Complaint DIANE R. CRUM, : Plaintiff : V. : RONALD E. CRISAMORE, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002 ~3~ CIVIL TERM CIVIL ACTION - LAW CUSTODY AND NOW, consideration DIRECTED that appear before conciliator, at the __ day of THIS day of , 2002, upon of the attached Complaint, IT IS HEREBY ORDERED AND the parties and their respective legal counsel shall , the on 2002, at ,o'clock .m. for a Conciliation Custody Conference. At such conference an effort will be made to resolve the issue 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. Either party may brinG the Child or Children who are the subject of this custody action to the conference, but the child's/children's attendance is not mandatory. Failure to appear at the conference may provide Grounds for entry of a temporary or permanent order. Diane Crum/5.8.02/Custody Complaint YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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, PA 17013 (717) 249-3166 FOR THE COURT: CUSTODY CONCILIATOR AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the American with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. Ail 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~ Diane Crum/5.8.02/Custody Complaint ~ DIANE R. RONALD E. o 4 o CRUM, Plaintiff V. CRISAMORE, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002 - QB2{ CIVIL TERM CIVIL ACTION - LAW CUSTODY CUSTODY COMPLAINT The Plaintiff Mechanicsburg, The Defendant is Ronald E. Road, Hanover, York County, is Diane R. Crum, residing at Q-4 Antrim Drive, Cumberland County, Pennsylvania 17050. Crisamore, residing at 120 Blackrock Pennsylvania 17331. Plaintiff seeks custody of the followin9 child: NAME P~CE OF RESIDENCE AGE Sierra Renee Crisamore Q-4 Antrim Drive 8 1/31/94 Mechanicsburg, PA 17050 The child was not born out of wedlock. The child is presently in the custody of the mother, Diane R. Crum, who resides at Q-4 Antrim Drive, Mechanicsburg, Cumberland County, Pennsylvania. During the past following persons and at five years, the child has resided with the the following addresses: Diane Crum/5.8.02/Custody Complaint D2DDRESSE~ PERSONS Diane R. Crum, mother Q-4 Antrim Drive 8/00 to Ralph R. Crum, Step-father Mechanicsburg, PA present Sean R. Crum, Half-brother Diane R. Crum, mother 207 Matrix Run 5/98 to Galloway, NJ 8/00 Diane R. Crum, mother 1008 Wesley Drive 12/97 to Ocean City, NJ 5/98~ Diane R. Crum, mother L-5 Spring Hollow 11/96 to Spring Grove, PA 12/972 10. 11. 12. The mother of the child is Diane R. Crum, currently residing at Q-4 An%trim Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. The mother is married to Ralph R. Crum. The father of the child is Ronald E. Crisamore, at 120 Blackrock Road, Hanover, York County, The father divorced. The relationship of Plaintiff to the child is that of natural mother. The Plaintiff currently resides with the following persons: currently residing Pennsylvania. ~During the period from separation through August of 1999, the parties shared custody on an equal basis, sometimes on an alternating weekly basis and sometimes on an alternating two week basis. 2See Footnote 1. Diane Crum/5.8.02/Custody Complaint Sierra Renee Crisamore Daughter Sean R. Crum Son Ralph R. Crum Husband 13. The relationship of Defendant to the child is that of natural father. 14. The Defendant currently resides with the following persons: None 15. Plaintiff has participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. The particulars regarding that prior custody action and its relevance to the within case are as follows: a. There was a prior custody action initiated in York County, Pennsylvania and docketed to no. 96-SU-05178-03. b. The York County, Pennsylvania case was resolved by the entry of an Order dated April 26, 1999, which Order was entered by agreement of the parties. A copy of the April 26, 1999 Order is attached hereto, marked Exhibit ~A" and made a part hereof. - 5 - Diane Crum/5.8.02/Custody Complaint 2002 Order changed and Plaintiff. There were no hearings held in the York County custody action. The child has not resided in York County, Pennsylvania since the fall of 1999 when pursuant to the terms of the April 26, the joint custody arrangement of the parties primary custody of the child was vested in e. The child has resided with the Plaintiff in Cumberland County, Pennsylvania since AuGust 2000, a period of almost two years and the majority of the information and witnesses regardinG the best interest of the child is found in Cumberland County. 16. Plaintiff has no information of a custody proceedinG concerninG the child pending in a court of this Commonwealth other than as set forth in ParaGraph 15 herein. 17. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 18. Plaintiff's husband, Ralph R. Crum is on active duty in the United States Army, ranked as a captain, and currently stationed at Ft. Indiantown Gap, Pennsylvania. Diane Crum/5.8.02/Custody Complaint 19. Plaintiff's husband, Ralph R. Crum has been reassigned to Ft. Levenworth, Kansas and is due to report to that assigned duty post on August 1, 2002. 20o As the result of Plaintiff's husband's military reassignment, Plaintiff is required to move with her husband to Ft. Levenworth, Kansas and desires to take the child with her to that new residence. 21. The best interest and permanent welfare of the child will be served by granting the relief requested because: Mother has been the primary caretaker of the child for the majority of the child's life and has been the primary caretaker of the child continuously since August of 1999. The child has been in the primary custody of mother since the fall of 1999. C · The child should be raised with her half brother, Sean R. Crum, with whom she has resided for the past two years. do The child has a close relationship with her step-father, Ralph R. Crum Plaintiff is not moving with the child out of malice to father, but rather as the result of the required military reassignment of her husband. Plaintiff has proposed a reasonable alternate partial custody schedule for Defendant, as set forth in Exhibit "B", attached hereto and made a part hereof. The father works third shift and is unable to provide proper care and supervision for the child. - 7 - Diane Crum/5.8.02/Custody Complaint h. The stability and continuity of the child will be served by permitted the child to move to Kansas with Plaintiff, her husband and half-brother. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WI~EREFORE, Plaintiff requests the Court to enter an Order granting mother the right to move to Kansas with the child, and to set the legal and physical custody rights between the parties in accordance with the provisions of the Proposed Order attached hereto as Exhibit KB" and made a part hereof. Respectfully submitted, Camp Hill, PA 1 7011 Phone: (717) 737-0100 Fax: (717) 975-0695 Supreme Court ID # 32112 Attorney for Plaintiff - 8 - Diane Crum/5.8.02/Custody Complaint I verify that true and correct. subject to the penalties of falsification to authorities. VERIFICATION the statements made in this Custody Complaint are I understand that false statements herein are made 18 Pa.C.S. 4904 relating to unsworn IN THE COURT OF COMMON PLEAS YORK COUNTY, PENNSYLVANIA E. CRISAMORE, : Plaintiff : : NO. 96-SU-05178-03 v. : CUSTODY DIANE R. CRISAMORE, : Defendant : ORDER NOW this-- ~d*~t day of ~-~ , 1999, upon consideration of the within Stipulated Custody Agreement, IT IS HEREBY ORDEHED AND DECREED as follows: DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 LEGAL CUSTODY: The PARENTS shall share and have joint legal custody of their minor CHILD, SIERRA CRISAMORE, born January 31, 1994, (hereinafter referred to as "the CHILD"). Each PARENT shall be entitled to participate, jointly with the other PARENT, in CHILD'S Pursuant all major non-emergency decisions affecting the health, education, religion and general well being. to the foregoing the following shall apply: 1. Each PARENT shall be entitled to access to any and all information, persons, entities and documentation regarding the same so that informed decisions can be made. Non-major decisions involving the living shall be made by the PARENT but to the extent possible, CHILD'S day to day then having custody, the parties shall attempt to EXHIBIT "A" 4/26/99 YORK COUNTY ORDER )lANE G. RADCLIFF ~448 TRINDLE ROAD ;AMP HILL, PA17011 717} 737-0100 make such rules and follow such schedules as would provide the CHILD with continuity in their lives regardless of the PARENT with whom they are then residing. Emergency decisions regarding the CHILD shall be made by the PARENT then having physical custody, but that PARENT shall communicate to the other PARENT the nature and extent of the emergency and shall provide that other PARENT with all information pertaining to the treatment so that the other PARENT may be involved in the decision making process at ~he earliest possible time. Upon receipt by a PARENT, copies of the CHILD'S school schedules, special events notifications, report cards and the like shall be provided to the other PARENT. Each PARENT shall share with the other PARENT any othe~ information and documentation, or copies thereof, that each PARENT possesses regarding the CHILD within such reasonable time as to make the records and information of reasonable use to the other PARENT. Each PARENT shall provide the other PARENT with at least 48 hours advance notice of school or other activities whenever possible. Neither PARENT shall make any derogatory comments about the other PARENT in the presence of the CHILD and to the extent possible shall prevent third parties from making any such comments in the presence of the CHILD. Further, neither PARENT shall discuss any aspect of the custodial -2- )lANE G. RADCLIFF ~448 TRINDLE ROAD :AMP HILL, PA 17011 717) 737-0100 situation with the CHILD and shall not utilize the CHILD for purposes of conveying information or inquiries pertaining to the CHILD to the other PARENT. 7. Each PARENT shall notify the other PARENT of any medical, dental, optical and psychological appointments and/or treatment for the CHILD sufficiently in advance thereof so that the other PARENT can attend. 8. Each parent shall provide the other PARENT with the name, address and phone number of any babysitter or other daycare providers that regularly watch the CHILD for that PARENT. 9. Both PARENTS shall be afforded reasonable telephone contact with the CHILD while in the other PARENT'S custody. 10. If either PARENT intends on removing the CHILD from that PARENT'S residence for a period in excess of forty-eight (48) hours that PARENT shall provide the other PARENT with the address and phone number where the CHILD can be reached during the period of absence. 11. Each PARENT shall advise the other parent of any intended move from his or her current residence at least sixty (60) days in advance of said move so that any changes to the custody schedule herein provided as may be necessitated by said move may be negotiated or litigated. If a negotiated change to custodial schedule can not be reached during that time period each party shall be at liberty to petition the court for a change in the terms -3- )lANE G. RADCLIFF 3448 TRINDLE ROAD :AMP HILL, PA 17011 717) 737-0100 hereof. The PARENTS shall share physical custody accordance with the following schedule: 1. Until the Friday of the last full of the CHILD in week before the commencement of school in the fall 1999 when the CHILD will enter kindergarten, the parties shall have joint physical custody of the child on an alternating two (2) week basis. The two (2) week schedule shall commence with FATHER'S week commencing January 8, 1999. The exchange time shall be on Fridays at 6:00 p.m. Commencing with the Friday of the last full week before the commencement of school in the fall of 1999, the MOTHER shall have primary physical custody of the CHILD subject to FATHER'S rights of partial custody hereafter set forth. Commencing with the Friday of the last full week before the commencement of school in the fall of 1999 FATHER shall have rights of partial custody of the accordance with the following schedule: a. During the school year, commencing with CHILD in the first Friday after the beginning of each school year through and including the last full weekend before the end of the school year, FATHER shall have custody for three (3) out of every four (4) weekends and MOTHER shall have custody on the fourth (4~h) weekend.) Each weekend custodial -4- :3lANE G. RADCLIFF 3448 TRINDLE ROAD :AMP HILL, PA 17011 717) 737-0100 period shall be from Friday at 6:00 p.m. until Sunday at 7:00 p.m. (or until Monday at 7:00 p.m. if Monday is a school holiday). During the school summer vacation period commencinc on the first Friday after the end of school, FATHER shall have custody of the Child for a period of eight (8) weeks during the school summer vacation period, to be exercised in two (2) consecutive four (4) week blocks. FATHER'S first four (4) week period shall commence on the first Friday after the end of the school year and shall run for a total of four (4) consecutive weeks ending on the fifth (5th) Friday following the end of school at 6:00 p.m. Mother shall than have custody for a period of two weeks commencing at 6:00 p.m. on that fifth (5=h) Friday and ending at 6:00 p.m. on the seventh (7~h) Friday after the end of school. Father shall then have custody for his second four (4) week period commencing at 6:00 p.m. on the seventh (7tn) Friday and ending on the eleventh (11tn) Friday after the end of school. Mother shall then have custody for the remainder of the summer until the weekend schedule recommences on the first (lst Friday after the recommencement of school in the fall. The foregoing notwithstanding Mother shall have two (2) weekend custodial periods from Friday at 6:00 p.m. until Sunday at 7:00 p.m. on the weekends occurring DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 4. The at the beginning of Father's weeks three (3) and nine (9). The foregoing schedule is and shall be in accordance with the following table: 1sT FRIDAY AFTER BEGINS FATHER'S CUSTODY SCHOOL ENDS 1~ WEEK EXCHANGES 2~ FRIDAY !BEGINS FATHER'S 2nd WEEK 3~ FRIDAY BEGINS FATHER'S MOTHER HAS 3~ WEEK CHILD FOR WEEKEND 4TM FRIDAY BEGINS FATHER'S 4TM WEEKS 5TM FRIDAY BEGINS MOTHER'S CUSTODY 1sT WEEK EXCHANGE 6TM FRIDAY BEGINS MOTHER'S SECOND WEEK 7TM FRIDAY BEGINS FATHER'S CUSTODY 5TM WEEK EXCHANGE 8TM FRIDAY BEGINS FATHER'S 6TM WEEKS 9TM FRIDAY BEGINS FATHER'S MOTHER HAS 7TM WEEK CHILD FOR WEEKEND 10TM FRIDAY BEGINS FATHERS 8TM WEEK 11TM FRIDAY BEGINS MOTHER'S CUSTODY 3~ WEEK EXCHANGES 12TM FRIDAY, IF APPLICABLE BEGINS MOTHERS 4TM WEEK PARENTS shall alternate custody on the following major holidays under the terms and as set forth below: a. Easter (from Friday before Easter at 6:00 p.m. through Easter Sunday at 7:00 p.m.); b. Memorial Day (from Friday before Memorial Day at 6:00 p.m. through Memorial Day 7:00 p.m.); -6- DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 c. Labor Day from Friday before Labor Day at 6:00 p.m. through Labor Day at 7:00 p.m.); d. Thanksgiving(from Wednesday before Thanksgiving Day at 6:00 p.m. through Sunday after Thanksgiving Day at 6:00 p.m.). In odd nurabered years, FAT~ER shall have custody of the CHILD for the Easter and Labor Day holidays and MOTHER shall have custody of the CHILD on the Memorial Day and Thanksgiving holidays. In even numbered years the above schedule shall reverse and MOTHER shall have custody of the CHILD on the Easter and Labor Day holidays and FATHER shall have custody on the Memorial Day and Thanksgiving holidays. For the calendar year 1998, Mother shall have custody from noon on December 24, 1998 until noon on December 25, 1998 and Father shall have custody from noon on December 25, 1998 until noon on December 26, 1998. Commencing with 1999 and thereafter, the Christmas holiday period, commencing the first day of the school Christmas holiday period (not including the last day of school) and ending the last day of that holiday period, shall be divided into 2 segments. FATHER'S segment shall be for a period of 6 days and MOTHER'S se~wnent shall be for the remaining holiday period. In even numbered years MOTHER shall exercise her segment for the first part of the holiday period and' FATHER'S shall exercise his segment for the DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 Co last part of the Holiday period. In odd numbered years the schedule shall reverse and FATHER shall exercise his segment during the first part of the holiday period and MOTHER shall exercise her segment during the last part of the holiday period. The 4 week rotating weekend schedule set forth on Paragraph 3a. above shall be suspended during this period and shall recommence on the first Friday after the end of the school Christmas break at the same place in the school year weekend schedule as it had been before the Christmas holiday period herein provided commenced. MOTHER shall have custody of the CHILD each Mother's Day from 7:00 p.m. the Friday before Mother's Day through 7:00 p.m. on Mother's Day and FATHER shall custody of the CHILD each Father's Day from 7:00 p.m. the Friday before Father's Day through 7:00 p.m. on Father's Day. For 1999 only, if those special weekends are not the PARENT'S regular weekend, the PARENTS shall switch weekends, either before the holiday of after the holiday, so that neither PARENT has custody of the CHILD for more than 2 consecutive weekends. MIECELLA_N'EOUS CUSTODY TEP~4S: 1 2 The PARENTS will switch any weeks or weekends herein provided necessary to accommodate any unavoidable special needs or requirements of a PARENT including, but not limited to, work or drill requirements. The transportation necessary for the custodial exchanges -8- DIANE G, RADCUFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 herein set forth shall be shared by the PARENTS with the exchanges being made at Wilmington Delaware in accordance with the past practice of the PARENTS. The holiday and special day or special weekend schedule shall take precedence over any other custodial period set forth herein. The other miscellaneous custodial periods shall take precedence over the weekend schedule. -9- DIANE G. RADCLIFF 344~ TRINDLE ROAD CAMP HILL, PA 17011 {717) 737-0100 IN TH~ COURT OF COMMON PLF. AS YORK COUNTY, PENNSYLVANIA RONALD ~. CRISAMOR~, Plaintiff DIAITE R. CRISAMOR~, Defendant NO. 96-SU-05178-03 CUSTODY ~ NOW, this CRISAMOR~ (hereafter referred Co CRISAMOR~ (hereafter referred to hereafter referred to as "PARENTS") follows: L~~ The PARENTS shall share and have joint as ,, FAT}{ER" ) and RONALD E. DIANE R. as "MOTKER") (collectively hereby stipulate and agree as legal custody of their minor CHILD, SIERRA CRISAMORE, born January 31, 1994, (hereinafter referred to aa "the CHILD"). Each PARENT shall be entitled to participate, jointly with the other PARENT, in all major non-emergency decisions affecting the CHILD'S health, education, religion and ~eneral well being. to the foregoing the following shall apply: 1. Each PARENT shall Purauant information, persons, regarding the same so made. be entitled to access to any and all entities and documentation that informed decisions can be Non-major decisions involving the CEILD'S day to day living shall be made by the PARENT then having custody, .]- 10/12/98 11:18 DIANE G. RADCLIFF 344.8 T~INOLE ROAD CAMP HILL, PA 17011 i7 ~7} 737.0100 but [o the extent possible, =he par~ies shall attempt to make such rules and follow such schedules as would provide ~he CHILD with continuity in their lives regardless of the P~.RENT with whom =hey are then residing. Emergency decisions regarding the CHILD shall be made by the PARENT ~hen having physical custody, but =hat PARENT shall communicate to the other PARENT ~he nature and extent of che emergency and shall provide that other PARENT with all information pertaining ~o the treatment so Ehat ~he other PARENT may be involved in the decision making process at the earliest possible time. Upon receipt by a PARENT, copies of the CHILD'S school schedules, special events noCifications, report cards and the like shall be provided ~o the other PARENT. Each PARENT shall share with the other PARENT any other information and documentation, or copies =hereof, that such each PARENT possesses regardin9 the CMILD within reasonable time as to make ~he records and information of raascnablm use to the other PARENT. Each PARENT shall provide ~he other PARENT with at least 48 hours advance notice of school or other activities whenever possible. Neither PARENT shall make any derogatory comments about the other PARENT in the presence of ~he CHILD and to =he ex~sn~ possible shall preven~ ~hird par~ies from making any such comments in =he presence of the CHILD. Further, -2- 11:18 DIANE, rIIANE G. RADCLICF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 10. 11, neither PARENT shall discuss any aspect of the custodial situation with the CHILD and shall not utilize the CHILD for purposes of conveying info-~mation or inquiries pertaining to the CHILD to the other pARENT. Each PARENT shall notify the o:her PARENT of any medical, dental, optical and psychological appointments and/or treatment for :he CHILD sufficiently in advance thereof so 5ha~ the other PARENT can attend. Each parent shall provide the other PARENT with the name, address and phone nur~er of any babysitter or other daycare providers that regularly watch the C~I~D for that PARENT. Both PARENTS shall be afforded reasonable telephone contact with the CHILD while in the other pARP~NT'S cussody. If either PARENT intends on removing :he cHILD from that PARF~NT'S residence for a period in excess of forty-eight (48) hours that PAR~T shall provide the o~her PARENT with the address and phone number where the CHILD can be reached during the period of absence. Each PARENT shall advise :he other parent of any intended move from his or her curren~ residence at least sixty (60) days in advance of said move so that any changes to the custody schedule herein provided a~ may be necessitated ~y said move may be nego:iated or li~igatsdo If a negotiated chan~e to custodial schedule can not be reached during that time period each party shall be a: -3- 'FANE G. RADCL;FF 448 TRINDLE ROAD AMp HILL, PA 17011 ~7) 737-0100 liberty to petition the court for a hereof. The PARENTs shall share physical custody accordance with Ehe following schedule: 1. change in the terms of the CHILD in Until the Friday of the last full week.before the commencement of school in he fall 199~ ~en~he CHILD will enter kindez'~ar=en, the parties shall have joint physical custody of the child on an alzern~wo (2) week basi~ The two (2) week schedule s~a~mence with FATH~R,S/~,.- · ~ '.'~'~9~ /~-,~:r:~ wee~ commencing ,~/~q-~.~<199V' The exchange ~ime shall be on Fridays aC St00 p.m. Commencin~ with the Friday of the last full week before the commencement of school in the fall of 19~, the MOTHER shall have primary physical custody of the CHILD subject to FATHER'S rights of partial custody hereafter set forth. Commencin~ with the Friday of the last full week before the commencement of school in the fall of 19~ FAT~IER shall have ri~hus of partial custody of ~he CHILD in accordance with the following schedule: a. Durin~ the school year, commencin~ with the first Friday after the be~innin~ of each school year ~hrou~h and includin~ the last full weekend before the end of the school year, FATHER shall have custody for three (3) out of every four (4) weekends and MOTHER shall have custody on the -4- DiAN~ G. RADCLIFF 34~g TRINDLE ROAD CAMP HILL, PA 17011 1717) 737-0100 fourth (4=~) weekend,) Each weekend custodial period shall be from Friday at 6:00 p.m. until 9unday at 7:00 p.m. (or until Monday at 7:00 p.m. if Monday is a school holiday). During the school summer vacation period ccmmencin9 on the first Friday after the end of school, FATHER shall have custody of the Child for a period of eight (8) weeks during the school summer vacation period, to be exercised in zwo (2) consecutive four (4) week blocks. FATMER'E first four (4) week period shall commence on the first Friday after the end of the school year and shall run for a total of four (4) consecutive weeks ending on the fifth (5~) Friday following the end of school at 6:00 p.m. Mother shall than have custody for a period of two weeks commencing at 6:00 p.m. on tha~ fifth (5~) Friday and ending a~ 6:00 p.m. on ~he seventh (7:~) Friday al:er the end of school, Father shall then have custody for his second four (4) week period co~encin~ at ~:00 p.m. on the seventh (7:h) Friday and.ending on the elevensh (ll~n) Friday afZer the end of school. Mother shall then have custody for the remainder of the summer until the weekend schedule recommences on ~he firs~ (lst Friday after the recommencement of echoo! in ~he fall, The fore~oin~ notwiZhstanding Mother shall have two (2) weekend custodial periods from Friday at 6:00 p,m. -5- DIANE G. RADCLIFF 3448 TRINOLE ROAD CAMP HILL, PA 17011 (717} 737-0100 until Sunday at 7:00 p.m, on the weekends occurring at the beg£nning of Father's weeks three (3) and nine (9). The foregoing schedule is and shall be in accordance with the following table: 1sT FRIDAY AFTER SCHOOL ENDS 2~ FRIDAY 3~ FRIDAY FRIDAY FRIDAY FRIDAY FRIDAY @7, FRIDAY 9= FRIDAY ~0~ FRIDAY IlTM FRIDAY 12TM FRIDAY, IF APPLICABLE BEGINS FATHER'S 1': WEEK BEGINS FATHER'S 2~ WEEK BEGINS FATHER'S 3~ WEEK !BEGINS FATHER'S 4TM WEEKS BEGINS MOTHER'S 1~= WEEK BEGINS MOTHER'S SECOND WEEK BEGINS FATHER'S 5TM WEEK BEGINS FATHER'S 6TM W~EKS BEGINS FATHER'S 7TM WEEK BEGINS FATHERS 8~" WEEK BEGINS MOTHER'S 3~: WEEK BEGINS MOTHERS 4TM WEEK CUSTODY EXCHANGES MOTHER HAS CHILD FOR WEEK~ND CUSTODY EXCHANGE CUSTODY EXCHANGE MOTHER HAS iC~ILD FOR WEEKEND CUSTODY EXC~%NGES the following forth below: a= 6:00 p.m. The PA.RENTS shall alUernate custody on major holidays under the ~erms and as set a. Eas~er (from Friday before ~aster =hrough Easter Sunday at 7:00 p.m.); b. Memorial Day (from Friday before Memorial Day at -6- DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 6:00 p.m. through Memorial Day 7:00 p.m.); c. Labor Day from Friday before Labor Day at 6:00 p.m. through Labor Day at 7:00 p.m.); d. Thanksgiving(from Wednesday before Thanksgiving Day at 6:00 p.m. through Sunday after Thanksgiving Day at 6:00 p.m.). In odd numbered years, FATHER shall have custody of the CHILD for the Easter and Labor Day holidays and MOTHER shall have custody of the CHILD on the Memorial Day and Thanksgiving holidays. In even numbered years the above schedule shall reverse and MOTHER shall have custody of the CHILD on the Easter and Labor Day holidays and FATHER shall have custody on the Memorial Day and Thanksgiving holidays. For the calendar year 1998, Mother shall have custody from noon on December 24, 1998 until noon on December 25, 1998 and Father shall have custody from noon on December 25, 1998 until noon on December 26, 1998. Commencing with 1999 and thereafter, the Christmas holiday period, commencing the first day of the school Christmas holiday period (not including the last day of school) and ending the last day of that holiday period, shall be divided into 2 segments. FATHER'S segment shall be for a period of 6 days and MO~ER'S segment shall be for the remaining holiday period. In even numbered years MOTHER shall exercise her segment for the first part of the holiday DIANE G. P, ADCLIFF 34~.8 TRINDLE ROAD .?,.AMP NIL[., PA 17011 71 ?} 737-0100 period and FATHER'S shall exercise his segment for the last part of the Holiday period. In odd numbered years the schedule shall reverse and FATHER shall exercise his segment during ~he first part of the holiday period and MOTHER shall exercise her segment during the last par= of the holiday period. The 4 week rotating weekend schedule set forth on Paragraph ~a. above shall be suspended during ~his period and shall recommence on the first Friday after the end of the school Christmas break at the same place in the school year weekend schedule as it had been before the Chris,mas holiday period herein provided commenced. 6. MOTHER shall have custody of the CHILD each Mother's Day from 7:00 p.m. the Friday before Mother's Day through 7:00 p.m. on Mother's Day and FATHER shall custody of ~he CHILD each Father's Day from 7:00 p.m. ~he Friday before Father,a Day through 7:00 p.m. on Father's Day. For 1999 only, if those special weekends are not the PARENT'S regular weekend, the PARENTS shall switch weekends, either before the hoii~ay of after ~he holiday, so that neither PARENT has cus=ody of the CHILD for more than 2 consecutive weekends. MI~C~I. LAN~OU~ ~U~TODY T~; 1. The PARENTS will switch any weeks or weekends herein provided necessary to accommodate any unavoidable special needs or requirements of a PARENT including, but not limited to, work or drill requirements. -8- DIANE G. RADCLiFF 3z~48 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-01(30 The transportation necessary for the custodial exchanges herein set forth shall be shared by the PARENTS with the exchanges being made at Wilmington Delaware in accordance with the past practice of the PARENTS. The holiday and special day or special weekend schedule shall take precedence over any other custodial period set forth herein~ The other miscellaneous custodial periods shall take precedence over the weekend schedule. The PARENTS authorize the Court to enter an Order incorporating the terms of this Stipulated Agreement. the day and year above WITNESS: IN WITNESS W~EREOF the parties have set ~heir hands and seals first written. DTk~"~v Ri 'CR'rStm~OR~ - '" R~NALD E. CRISAMORE -9- Diane Crum/5.8.02/Custody Complaint IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA RONALD E. CRISDJ40RE, Plaintiff DIANE R. CRISAMORE, : Defendant : NO. CUSTODY CIVIL TERM ORDER AND NOW this __ day of , 2002, upon consideration of the facts in the within custody action pertaining to Diane R. Crum ("Mother") and Ronald E. Crisamore ("Father"), and their minor child, Sierra R. Crisamore, born January 31, 1994, (the ~Child"), IT IS HEREBY ORDERED AND DECREED as follows: RELOCATION: Mother is hereby granted the right to relocate with the Child to a new residence at Ft. Levenworth, Kansas and to any subsequent residence that she may have to establish as the result of future military assignments of her husband, Ralph R. Crum. LEGAL CUSTODY: The Parents shall share and have joint legal custody of the Child. Each Parent shall be entitled to participate, jointly with the other Parent, in all major non-emergency decisions affecting the Child's health, education, religion and general well being. Pursuant to the foregoing the following shall apply: Access to Information: Each Parent shall be entitled to access to any and all information, persons, entities and documentation regarding the same so that informed decisions can be made. Non-Maior Decisions: Non-major decisions involving the Child's day to day living shall be made by the Parent then EXHIBIT "B" Diane Crum/5.8.02/Custo~ Complaint o o having custody, but to the extent possible, the Parents shall attempt to make such rules and follow such schedules as would provide the Child with continuity regardless of the then existing custodial Parent. Emergency Decisions: Emergency decisions regarding the Child shall be made by the Parent then having physical custody, but that Parent shall immediately communicate to the other Parent the nature and extent of the emergency and shall provide that other Parent with all information pertaining to the treatment so that the other Parent may be involved in the decision making process at the earliest possible time. Copies of Documents: To the extent not reasonably available to the other parent, upon receipt by a Parent, copies of the Child's school schedules, special events notifications, report cards and the like shall be provided to the other Parent, unless the documents are otherwise reasonably available to the other Parent. Each Parent shall share with the other Parent any other information and documentation, or copies thereof, that each Parent possesses regarding the Child within such reasonable time as to make the records and information of reasonable use to the other Parent. No Derogatory Comments: Neither Parent shall make any derogatory comments about the other Parent in the presence of the Child and to the extent possible shall prevent third parties from making any such comments in the presence of the Child. No Discussion: Neither Parent shall discuss any aspect of the custodial situation with the Child and shall not utilize the Child for purposes of conveying information or inquiries pertaining to the Child to the other Parent. TelePhone Contact: Both Parents shall be afforded reasonable telephone contact with the Child while in the other Parent's custody and for said purposes each Parent shall provide the other Parent with his or her home phone number where the Child can be reached when in the that Parent's custody. Diane Crum/5.8.02/Custody Complaint Temporary Absence from Commonwealth: If either Parent intends on removing the Child from his or her residence during that parent's period of custody for a period in excess of forty- eight (48) hours that Parent shall provide the other Parent with the address and phone number where the Child can be reached during the period of absence. PHYSICAL CUSTODY: The following shall apply regarding physical custody of the Child: Primary Custody: Mother shall have primary physical custody of the Child, subject to the custody schedule hereafter set forth. Partial Custody: Father shall have rights of partial physical custody of the Child, subject to the custody schedule hereafter set forth. o Custody Schedule: The Parents rights of custody shall be in accordance with the following schedule: so APril 26, 1999 Custody Schedule: Pending Mother's move to Ft. Levenworth, Kansas, the physical custody schedule shall be in accordance with the terms of the April 26, 1999 York County Order, incorporated by reference hereto. Upon and after, mother's move to Ft. Levenworth Kansas, the physical custody schedule shall be in accordance with the hereinafter set forth schedule. Primary Custodian's Periods: Mother shall have custody of the Child for all periods not specifically reserved for Father in herein. Weekends: Father shall have the right to exercise custody of the Child for one weekend per month from Friday until Sunday (or until Monday if Monday is a school holiday) anytime Father is in the area where the Child resides, upon one (1) week advance notice to Mother. d. Holidays/Special Days: Custody for major holidays and - 3 - Diane Crum/5.8.02/Custody Complaint special days shall be in accordance with the following schedule: Easter/Sprin9 School Break Thanksgivin9 School Break Christmas School Break 1~t Segment Christmas School Break 2nd Segment Mothers Day Fathers Day Beginning to end of break Beginnin9 to end of break 1st day of school break through 12/25 Father Father Father Father Father Mother 12/26 through day before recommencement of school Friday through Sunday Friday through Sunday Father Father Mother Mother Father Father Summer: Father shall have custody of the Child for the majority of the summer school vacation break commencing with the first day of the summer break and ending on the date two weeks prior to the recommencement of school in the fall at which time custody of the Child shall be return to Mother. MISCELLANEOUS CUSTODY TER~S: The following miscellaneous terms shall apply to the custody of the child: Trans rtati n: The transportation necessary for the custodial exchanges herein (with the exception of the weekend periods set forth in Paragraph C. (3) (c)-(e) above shall be coordinated between the parties based on there being available air flights for the Child to travel from and to the Child's - 4 - Diane Crum/5.8.02/Custody Complaint residence to and from Father's home. Except as hereafter set forth, the parties shall share in the costs of that transportation on an equal basis. The flights and flight dates to be selected shall be the dates upon which the lowest possible fare price is available at a date at or near the dates listed in the custody schedule above. If the lowest rate is not available precisely on the time set forth in the above schedule the schedule shall be modified to commence or end on that lowest fare date; provided, however, that if Father pays for the increase in costs above that lowest price, there shall be no modification of the above schedule. o Precedence: The holiday and special day schedule shall take precedence over any other custodial period set forth herein. Modification: The Parents shall be at liberty to modify the custodial periods herein provided to accommodate their respective schedules and special events, subject, nonetheless in all respects to the mutual agreement of the Parents for any such modifications. BY THE COURT: Distribution to: Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 Attorney for Plaintiff DIANE R. CRUM : : PLAINTIFF V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-2321 CIVIL ACTION LAW RONALD E. CRISAMORE DEFENDANT : IN CUSTODY 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. Greev~, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Monday, June 17, 2002 at 12:30 PM 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 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: Is/ Melissa P. Greevy. Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabihtes 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 heating or business before the court. You must attend the scheduled conference or heating. 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 DIANE R. CRUM, Plaintiff V. RONALD E. CRISAMORE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02 2321 CIVIL TERM : : CIVIL ACTION - LAW : CUSTODY I hereby certify that a true and correct copy of the Custody Complaint has been served upon the Defendant, Ronald Crisamore, by Certified Mail, Restricted Delivery on the 15t~ day of May, 2002. The return receipt for said mailing is attached hereto as Exhibit "A" and made a part hereof. Respectfully submitted, ~T~ind~C~, ESQUIR Camp Hill, PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID ~ 32112 Attorney for Plaintiff Postmark Here · Complete items 1, 2, and 3. Also complete item 4 if Restricted Oelivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. Article Addressed to; · C. Signature X · ff YES, · [] Agent [] Addressee 17 I'lyes r-I No [] Express Mail Registered [] Return Receipt for Merchandise Insured MaLl [] C.O.D. PS Form 3811, July 1999 Domestic Return Receipt Diane R. Crum/! Custody Stipulation/ 5.16.02 DIANE R. CRUM, Plaintiff RONALD E. CRISAMORE, Defendant : IN THE COURT OF COMM : CUMBERLAND COUNTY, : : NO. 02-2321 CIVIL TERM : : CIVIL ACTION - LAW : CUSTODY STIPULATION FOR CUSTODY (2 AND NOW This 127 day of~-~-~, 2002, DIANE R. CRUM CRISAMORE ("Father") hereby stipulate and agree that the foregoing Cus~ the Court in the above captioned matter. IN WITNESS WHEREOF the Parents, intending to be legally bom and seals the day and year below written. DIANE R. CRUM RONALD E. CRISA - 5 - ON PLEAS OF ,ENNSYLVANIA RDER "'Mother") and RONALD E. ~dy Order shall be entered by ~d hereby, have set their hands JUN ~ i ZO0~ ~ DIANE R. CRUM, Plaintiff RONALD E. CRISAMORE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2321 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 16th day of June, 2002, upon receipt of an executed Stipulation presented by counsel for the Plaintiff, having determined that the parties have reached an agreement resolving Plaintiff's petition, the Conciliator hereby relinquishes jurisdiction of the above-captioned matter. ~~~~ e'l~'ss~ ~el Greevy, Esquire' ~ ~ustody Conciliator :159671 Dist: Diane G. Radcliff, Esquire, 3448 Trindle Road, Camp Hill, PA 17011 Ronald E. Crisamore, pro se, 112 Blackrock Road, Hanover, PA 17331 Diane R. Crum/ Custody Stipulation/ 5.16.02 DIANE R. CRUM, Plaintiff V RONALD E. CRISAMORE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-2321 CIVIL TERM : : CIVIL ACTION - LAW : CUSTODY AND NOW this zS~.' day of ~"~ t~ R ,2002, upon consideration of the Stipulation for Custody Order executed by Diane R. Crum ("Mother") and Ronald E. Crisamore ("Father"), pertaining to their minor child, Sierra R. Crisamore, bom January 31, 1994, (the "Child"), IT IS HEREBY ORDERED AND DECREED as follows: Mother is hereby granted the right to relocate with the Child to a new residence that she may have to establish as the result of military assignments of her husband, Ralph R. Cram. LEGAL CUSTODY: .~i.i The Parents shall share and have joint legal custody ofth~ Child. Each Parent shall be entitled to participate, jointly with the other Parent, in all major non-emergency decisions affecting the Child's health, education, religion and general well being. Pursuant to the foregoing the following shall apply: Access to Information: Each Parent shall be entitled to access to any and all information, persons, entities and documentation regarding the same so that informed decisions can be made. Non-M~or Decisions: Non-major decisions involving the Child's day to day living shall be made by the Parent then having custody, but to the extent possible, the Parents shall attempt to make such rules and follow such schedules as would provide the Child with continuity regardless of the then existing custodial Parent. Emergency Decisions: Emergency decisions regarding the Child shall be made by the Parent then having physical custody, but that Parent shall immediately communicate to the other Parent the nature and extent of the emergency and shall provide that other Parent with all information pertaining to the treatment so that the other Parent may be involved in the decision making process at the earliest possible time. C. Diane R. Crum/ Custody Stipulation/ 5.16.02 Copies of Documents: To the extent not reasonably available to the other parent, upon receipt by a Parent, copies of the Child's school schedules, special events notifications, report cards and the like shall be provided to the other Parent, unless the documents are otherwise reasonably available to the other Parent. Each Parent shall share with the other Parent any other information and documentation, or copies thereof, that each Parent possesses regarding the Child within such reasonable time as to make the records and information of reasonable use to the other Parent. No Derogatory_ Comments: Neither Parent shall make any derogatory comments about the other Parent in the presence of the Child and to the extent possible shall prevent third parties from making any such comments in the presence of the Child. No Discussion: Neither Parent shall discuss any aspect of the custodial situation with the Child and shall not utilize the Child for purposes of conveying information or inquiries pertaining to the Child to the other Parent. Telephone Contact: Both Parents shall be afforded reasonable telephone contact with the Child while in the other Parent's custody and for said purposes each Parent shall provide the other Parent with his or her home phone number where the Child can be reached when in the that Parent's custody. Temporary_ Absence from Commonwealth: If either Parent intends on removing the Child from his or her residence during that parent's period of custody for a period in excess of forty-eight (48) hours that Parent shall provide the other Parent with the address and phone number where the Child can be reached during the period of absence. PHYSICAL CUSTODY: The following shall apply regarding physical custody of the Child: Primary_ Custody: Mother shall have primary physical custody of the Child, subject to the custody schedule hereafter set forth. Partial Custody: Father shall have rights of partial physical custody of the Child, subject to the custody schedule hereafter set forth. Custody Schedule: The Parents fights of custody shall be in accordance with the following schedule: April 26, 1999 Custody Schedule: Pending Mother's relocation, the physical custody schedule shall be in accordance with the terms of the April 26, 1999 York County Order, incorporated by reference hereto. Upon and after, mother's relocation, the Diane R. Crum/ Custody Stipulation/ 5.16.02 physical custody schedule shall be in accordance with the schedule set forth in subparagraphs b-e of this Paragraph C-3. primary_ Custodian's Periods: Mother shall have custody of the Child for all periods not specifically reserved for Father in herein. Weekends: Father shall have the right to have custody of the Child for two weekends per month fi:om Friday until Sunday (or until Monday if Monday is a school holiday) anytime Father is in the area where the Child resides, upon one (1) week advance notice to Mother. Holidays/Special Days: Custody for major holidays and special days shall be in accordance with the following schedule: Easter/Spring Beginning to end of break Father Father School Break Thanksgiving Beginning to end of break Father Father School Break Christmas School 1st day of school break Father Mother Break 1st Segment through 12/25 Christmas School 12/26 through day before Father Father Break 2nd Segment recommencement of school Mothers Day Friday through Sunday Mother Mother Fathers Day Friday through Sunday Father Father Summer: Commencing with the summer of 2003 Father shall have custody of the Child for the majority of the summer school vacation break commencing with the first day of the summer break and ending on the date at least one week prior to the recommencement of school in the fall at which time custody of the Child shall be returned to Mother. The foregoing notwithstanding, for the summer of 2002 Father shall return the Child to Mother's custody approximately two (2) weeks prior to the start of the 2002 school year, the exact date to be scheduled by the parties so as to allow for driving time to Mother's new residence and to permit the Child to adjust Diane R. Crum/ Custody Stipulation/ 5.16.02 to a new school. MISCELLANEOUS CUSTODY TERMS: The following miscellaneous terms shall apply to the custody of the child: Transportation/Schedule Modification: The transportation necessary for the custodial exchanges herein (with the exception of the weekend periods set forth in Paragraph C.(3)(c)- (e) above shall be coordinated between the parties based on there being available air flights for the Child to travel fi:om and to the Child's residence to and fi:om Father's home. Except as hereafter set forth, the parties shall share in the costs of that transportation on an equal basis. The flights and flight dates to be selected shall be the dates for which the lowest possible fare price is available at a date at or near the dates listed in the custody schedule above. If the lowest rate is not available precisely on the date set forth in the above schedule, the schedule shall be modified to commence or end on that lowest fare date; provided, however, that if Father pays for the increase in costs for air fare above that lowest price, there shall be no modification of the above schedule. Precedence: The holiday and special day schedule shall take precedence over any other custodial period set forth herein. Distribution to: Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 Attorney for Plaintiff Modification: The Parents shall be at liberty to modify the custodial periods herein provided to accommodate their respective schedules and special events, subject, nonetheless, in all respects to the mutual agreement of the Parents for any such modifications. BY THE COURT: /~/~,J /~. /4~-55', j. Ronald E. Crisamore 112 Blackrock Road Hanover, PA 17331 Pro Se Diane R. Crum/ Custody stipulation/ 5.16.02 DIANE R. CRUM, Plaintiff RONALD E. CRISAMORE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-2321 CIVIL TERM : : CIVIL ACTION - LAW : CUSTODY STIPULATION FOR CUSTODY ORDER AND NOW This 1~'4- day of'~'J~,2002, DIANE R. CRUM ("Mother") and RONALD E. CRISAMORE ("Father") h-ereb~ stipulat~ and agree that the foregoing Custody Order shall be entered by the Court in the above captioned matter. IN WITNESS WltEREOF the Parents, intending to be legally bound hereby, have set their hands and seals the day and year below written. RONALD E. CRISAMORE