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Home My WebLink About06-6213 KRISTIE L CORLE, Plaintiff = IN THE COURT OF COMMON PLEAS OF = CUMBERLAND COUNTY, PENNSYLVANIA . . Y. = CIVIL ACTION. LAW = NO. 2006 - CIVIL TERM JASON L CORLE, . . Defendant = IN CUSTODY COMPLAINT FOR CUSTODY NOW comes the plaintiff and files this complaint and agreement for custody, representing as follows: 1. The plaintiff is KRISTIE L. CORLE, an adult individual residing at 3148 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is JASON L. CORLE, an adult individual residing at 3148 Spring Road, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of a minor child, ALEISA KATE CORLE (born December 11, 2002). 4. The child was born during the marriage of the parties and has resided with both parties from the date of her birth through the present. The parties are in the process of separating, but intend to continue to reside together at 3148 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013 at this time. 5. Neither party has participated as a party, witness or in any other capacity in other litigation concerning the custody of the child in this or another court. 6. The plaintiff has no information regarding any other custody proceeding concerning the child pending in a court of this Commonwealth. 7. The 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. 8. The plaintiff believes and therefore avers that the best interests and permanent welfare of the child require that the parties have joint legal and physical custody of the child in accordance with the mutual agreement of the parties as hereinafter set forth. 9. Both parties, as evidenced by their joint execution of this complaint, have mutually agreed upon an amicable arrangement for the legal, physical and temporary custody of the child and request that the Court enter an order as provided below without the necessity of a hearing: A. The parties shall have joint legal custody of their minor child, ALEISA KATE CORLE (born December 11, 2002). Joint legal custody means both parents shall jointly share the right of control of their child and shall share in making decisions of importance in the life of their child, including educational, medical and religious decisions. Both parents shall be entitled to equal access to the child's school, medical, dental and other important records. Notwithstanding the foregoing, non-major decisions involving the child's day-to-day living shall be made by the parent then having physical custody, consistent with the other provisions of this Agreement and Order and the best interests of the child. B. The parties shall have joint physical custody of the child, it being their intention that they shall both have equal time with the child as much as is reasonably possible. C. The parties shall have reasonable telephone contact with the child while the child is in the other's custody. D. The parties shall keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to insure that the health, welfare and well being of the child is protected. E. The parties shall do nothing that may estrange the child from the other party or hinder the natural development of the child's love or affection for the other party. F. In the event of the breach of this agreement by either party, the nonbreaching party shall have the right to file a petition for contempt of court and to seek specific performance of the terms of the agreement of the parties. All costs, expenses and reasonable attorney fees incurred by the successful party in any litigation to obtain an order of contempt or specific performance of this agreement shall be recoverable as part of the judgment entered by the court. G. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality as this agreement. H. The Court of Common Pleas of Cumberland County has jurisdiction over these issues and shall retain such jurisdiction should circumstances change and any party desire further or require further modification of said Order. WHEREFORE, the plaintiff respectfully requests that the court enter an order providing for the legal and physical custody of the children as aforesaid without the requirement of a custody conciliation or hearing. October 24, 2006 , . VERIFICATION AND CONFIRMATION OF AGREEMENT We do hereby verify that the acts set forth in this complaint are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. ~ 4904, relating to unsworn falsification to authorities. Furthermore, by the execution of this Confirmation, we do each unequivocally express our mutual and voluntary agreement to the amicable custody arrangement provided above and request that the terms thereof be entered as an Order of Court without the necessity of a custody conciliation, hearing or other proceeding. October 24, 2006 k10bl i~ 0ffJ ~ ~/a/ (SEAL) October 24, 2006 (SEAL) . . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND :5S: On this, the 24th day of October, 2006, before me, the undersigned officer, personally appeared JASON L. CORLE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. EAL) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jane Adams, Notary Public .QRiile Boro, Cumberland County ~yCOinmission Expires Sept. 6, 2088 On this, the 24TH day of October, 2006, before me, the undersigned officer, personally appeared KRISTIE L. CORLE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official se . (SEAL) COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jane Adams Notary Public Carlisle Boro, Cumberlan~ County My Commission Expire- ~ept. 6, 2088 >- ~ l- we ~_-7r --)c:' G:: -~~ '.l_...i- \"....\--- lJQ oc: WO- cEl.lJ IE u... o 0"\ o N z: 0... tn N t- U o u=> =-> c;=> ~ "'2~ ,- ~ 3 J"' \.() gL "'" QO\-i ~ ~ 0 "jO~ i ~ p . a=.'O ~ {] ~ 0.- <>? r ~ ", ~ HAROLD S. IRWIN, III ESQ ATTORNEYIDNO.~ 84 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-8080 ATTORNEY FOR DEFENDANT Mr KRISTIE L CORLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . Y. : CML ACTION - LAW : NO. 2006 - ~ ~/3 CIVIL TERM .JASON L CORLE, Defendant : IN CUSTODY ORDER OF COURT NOW, this 3tA. day of p ~ , 2006, upon presentation and consideration of the within complaint and the stipulation and agreement incorporated therein, and upon agreement of the parties, it is hereby ordered and decreed as follows: A. The parties shall have joint legal custody of their minor child, ALEISA KATE CORLE (born December 11, 2002). Joint legal custody means both parents shall jointly share the right of control of their child and shall share in making decisions of importance in the life of their child, including educational, medical and religious decisions. Both parents shall be entitled to equal access to the child's school, medical, dental and other important records. Notwithstanding the foregoing, non-major decisions involving the child's day-to-day living shall be made by the parent then having physical custody, consistent with the other provisions of this Agreement and Order and the best interests of the child. B. The parties shall have joint physical custody of the child, it being their intention that they shall both have equal time with the child as much as is reasonably possible. C. The parties shall have reasonable telephone contact with the child while the child is in the other's custody. . \ D. The parties shall keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to insure that the health, welfare and well being of the child is protected. E. The parties shall do nothing that may estrange the child from the other party or hinder the natural development of the child's love or affection for the other party. F. In the event of the breach of this agreement by either party, the nonbreaching party shall have the right to file a petition for contempt of court and to seek specific performance of the terms of the agreement of the parties. All costs, expenses and reasonable attorney fees incurred by the successful party in any litigation to obtain an order of contempt or specific performance of this agreement shall be recoverable as part of the judgment entered by the court. G. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality as this agreement. H. The Court of Common Pleas of Cumberland County has jurisdiction over these issues and shall retain such jurisdiction should circumstances change and any party desire further or require further modification of said Order. ! I~ 3- {)(p c . ~ ~L -:)J> Vi ,\: \1'/,-1. ~.sN f{3d U Nr'-.'" ,""\....- .~"-'^!""'I"\ I ~; ;t..J.., : >,'.-! :>::..:~:i~'~! i;...} Z2 :2 ~;,!d 8- AON 9DOl ILI\-!; nl'!;-'~"'~l.'..,.c-' :lHl .10 I\(j V ..:....h '.\....' I 1 ..\...! ,->Io..J ....J .J",..:J-' 3:,}:: !:i()_:' Cl3':lH,