The URL can be used to link to this page

Home My WebLink About06-6979 14471811302006 Franklin County Prothonotary's Office Page 1 Py'C~lC... aivil Case print. /) · 1994-16363 HEIDI L BAILEY ~) SHANNON L ARROWOOD .. Ol-- {.9'll(" LLUlt Reference No..: Filed. .......: 7~ Case Type.....: CUSTODY Time.........: 12:00 Judgment...... .00 Execution Date 0/00/0000 Judge Assigned: Jury Trial.... Disposed Desc.: Disposed Date. 0/00/0000 ____________ Case Comments ------------- Higher Crt 1.: Higher Crt 2.: ******************************************************************************** General Index Attorney Info BAILEY HEIDI L CUMBERLAND COUNTY ARROWOOD SHANNON LEE W EIGHTH ST WAYNESBORO PA 17268 PLAINTIFF HAGGERTY KARA W DEFENDANT ******************************************************************************** * Date Entries * ******************************************************************************** 7/17/1995 4/01/1999 7/14/2006 7/14/2006 7/21/2006 7/21/2006 7/25/2006 7/25/2006 7/25/2006 7/25/2006 8/03/2006 10/09/2006 10/09/2006 11/30/2006 _ - - - - - - - - - - - - FIRST ENTRY - - - - - - - - - - - - - - STIPULATION AND AGREEMENT IN CUSTODY FILED. ------------------------------------------------------------------- ADDED TO NEW COMPUTER ON 4/1/99. EARLIER DOCKET ENTRIES IN DOCKET BOOK FR 1994-363 FILED. ------------------------------------------------------------------- PETITION FOR SPECIAL RELIEF FILED WITH COPIES AND HANDED TO LAW CLERK TO BE PRESENTED UPSTAIRS. ------------------------------------------------------------------- PETITION TO TRANSFER VENUE FILED WITH COPIES AND HANDED TO LAW CLERK TO BE PRESENTED UPSTAIRS. ------------------------------------------------------------------- PETITION FOR SPECIAL RELIEF WITH COPIES FILED AND HANDED TO THE LAW CLERK FOR PRESENTATION UPSTAIRS. ------------------------------------------------------------------- PETITION TO TRANSFER VENUE WITH COPIES FILED AND HANDED TO THE LAW CLERK FOR PRESENTATION UPSTAIRS WITH JUDGE VAN HORN. ------------------------------------------------------------------- ORDER OF COURT DATED JULY 24 2006 SETTING HEARING FOR OCT 9 2006 @ 9:30 AM FILED. BY CAROL L VAN HORN JUDGE. ------------------------------------------------------------------- NOTICE OF ENTRY OF ORDER OR DECREE PURSUANT TO PA R.C.P NO 236 NOTIFICATION. THIS DOCUMENT HAS BEEN FILED IN THIS CASE. PROTHONOTARY FRANKLIN COUNTY PA. KARA W HAGGERTY ESQ & SHANNON ARROWOOD PRO SE VIA REGULAR MAIL. ------------------------------------------------------------------- ORDER OF COURT DATED JULY 24 2006 REGARDING PETITION FOR SPECIAL RELIEF AND SETTING HEARING FOR OCT 9 2006 FILED. BY CAROL L VAN HORN JUDGE. ------------------------------------------------------------------- NOTICE OF ENTRY OF ORDER OR DECREE PURSUANT TO PA R.C.P NO 236 NOTIFICATION. THIS DOCUMENT HAS BEEN FILED IN THIS CASE. PROTHONOTARY FRANKLIN COUNTY PA. KARA W HAGGERTY ESQ & SHANNON ARROWOOD PRO SE VIA REGULAR MAIL. ------------------------------------------------------------------- AFFIDAVIT OF SERVICE FILED. ------------------------------------------------------------------- ORDER OF COURT DATED OCTOBER 9 2006 STATING COURT DECLINES TO ASSUME FURTHER JURISDICTION FOR MODIFICATION OF THIS ORDER AND DIRECTS THAT PARTIES FILE DOCUMENTS IN CUMBERLAND COUNTY WHICH IS APPROPRIATE COUTY OF JURISDICTION WITH COPIES FILED. BY: CAROL L VAN HORN JUDGE. ------------------------------------------------------------------- NOTICE OF ENTRY OF ORDER OR DECREE PURSUANT TO PA R.C.P NO 236 NOTIFICATION. THIS DOCUMENT HAS BEEN FILED IN THIS CASE. PROTHONOTARY FRANKLIN COUNTY PA. ------------------------------------------------------------------- CERTIFIED COPIES OF FILE AND DOCKET ENTRIES SENT TO CUMBERLAND COUNTY PROTHONOTARY VIA CERTIFIED MAIL AT THE REQUEST OF ATTORNEY KARA HAGGERTY. 14471811302006 PYp'~ 1 ~ 1994-16363 HEIDI L Franklin,C9unty Prot~6notary's ~lVll Case Prlnt BAI LEY ~) SHANNON L ARROWOOD Office Page 2 . - - - - - - LAST ENTRY Execution Date Jury Trial. . . . Disposed Date. Higher Crt 1.: Higher Crt 2.: 7/19/1995 12:00 0/00/0000 0/00/0000 Reference No.. : Case Type.....: CUSTODY Judgment...... .00 Judge Assigned: Disposed Desc. : ------------ Case Comments ------------- Filed. Time. . ******************************************************************************** * Escrow Information * * Fees & Debits Beq Bal Pvmts/Adl End Bal * ********************************~*********************************************** SUBPOENA 3.00 3.00 .00 3.00 3.00 .00 ******************************************************************************** * End of Case Information * ******************************************************************************** -,- ; I 1 A 1>"........1 atrrtifirb f t-Io"-- .~ ~A:T-"--- ...~~' C: ..,. ...... Ll1 County, PA ;0 (:) -c.q. '~ ~ ~ ~ ~e ~ ~ ""'" ~~ 0 ;:; ""0 (L' rn p'\ q;c' CJ -om ......... , , -nO k- .~ C)(") ~ 8 -:7 \ (.J\ t8 ~::_~~ i~ ~ -." r.::, -0 (,t~ ~ ~ - ~.\c~, ....... S~ ~ V w YC .- ")?" p: Z "" ~ :2 ~ ~ -f-- ...z::- IN THE COURT OF COMMON PLEAS OF THE 39TH JUDICIAL DISTRICT, PENNSYLVANIA FRANKLIN COUNTY BRANCH HEIDI L. BAILEY VS SHANNON L. ARROWOOD CIVIL ACTION NO. 1994-363 APPEARANCES: it Or- I z. -D ow ~.~ )> I ~~ :::= U'I ~ Kara W. Haggerty, Esquire, appears Plaintiff. ORDER OF COURT .." ::0 1>" Z::o ~ -::r Zo (jz 00 C=-I ...1:::>- .. -< :::0 --<-< October 9, 2006, the matter having come before the Court on a petition for special relief filed by Plaintiff on July 21, 2006, and on a petition to transfer venue filed the same date, and the Court having reviewed the record to determine that both documents were properly served on the Respondent who fails to appear this date, after brief testimony in this matter, IT IS HEREBY ORDERED as follows: 1. Primary legal and physical custody of the child, Cortney Lynn Arrowwood, born October 31, 1992, is granted to Heidi L. Bailey. 2. Jurisdiction in this matter appears to be vested in Cumberland County since Heidi L. Bailey and Cortney Lynn 25 Arrowwood have primarily resided within its bounds since at ._.....,-'",.....o;."'~.,.__" ....._~_''''''~,.._____..,..,,,....,__,.,.....,'''__...-..>..-. -., ( 1 .., of .. 1 C" 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 least 1998. In the event further custody proceedings are necessary regarding the child, this court hereby declines to assume further jurisdiction for modification of this order and directs that the parties shall appropriately file the documents in Cumberland County which is the appropriate county of jurisdiction. By the Court, ~~ ~~...) J. c. Kara W. Haggerty, Esquire Shannon Arrowood 2 Sharon A. Welty, RPR Official Court Reporter cY """ fl.; .' e e HEIDI L. BAILEY, Petitioner : IN THE COURT OF COMMON PLEAS : 39TH JUDICIAL BRANCH : FRANKLIN COUNlY, PENNSYLVANIA v. SHANNON L. ARROWOOD, Respondent : NO. F.R. 1994-363 a .'""'1 : <J ~C;: <J r- : CIVIL ACTION - CUSTOD_~ 2;?; I -, ;.~ -_ .....;a ~' ~.~: ( ': ,~-. . _c, ORDER OF COURT I :':,': - ........., '= = CJ- ..., ::t ~;{J :;:-::t - '0 r--, <- c:: r- ~', , . " -- ': (~:~~ -- ('I 11 _ .~"",i I ~,-: AND NO~ this ;y~ day of July, 2006, upon consideration of the foregoing ;tition, IT IS HEREBY ORDERED that: 1. A rule is issued upon the Respondent to show cause why the Petitioner is not entitled to relief requested. 2. The Respondent shall file a verified Answer to the Petition for Special Relief within twenty (20) days of service upon the Respondent; 3. The Petition shall be decided under Pa.R.c.P. No. 206.7. 4. Deposition shall be completed within days of the service upon Petitioner of the Answer to the Petition for Special Relief. 5. Hearing and/or argument shall be held on ManAA:y - QC,,\~(' ~ .2006, at q'.~ A.m., in Courtroom No. ~ of the Franklin County Courthouse, Chambersburg, Pennsylvania. 6. If Items 4 and 5 are left blank, depositions and or argument or hearing will be considered upon request of any party; and 7. Notice of the entry of the Order shall be provided to all parties by the petitioner. "", e e V' 8. This Honorable Court in the interim immediately awards the Petitioner sole physical custody and legal custody of the minor child until such time a hearing can be scheduled on the matter. By the Court: ~tK~~"- Honorable Carol VanHom Distribution: Kara W. Haggerty, Esquire ABOM & KUTULAKIS, LLP 36 S. Hanover Street Carlisle, P A 17013 Shannon Arrowood, Pro Se W. Eighth Street Waynesboro, PA 17268 -, , e e . HEIDI L. BAILEY, Petitioner : IN THE COURT OF COMMON PLEAS : 39TI1 JUDICIAL BRANCH : FRANKLIN COUNlY, PENNSYLVANIA v. : NO. F.R. 1994-363 SHANNON L. ARROWOOD, Respondent : CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this _ day of July, 2006, upon consideration of the attached Petition for Special Relief, it is ORDERED and DECREED that the Petitioner shall immediately take primary physical and legal custody of the subject minor child. Father shall exercise partial physical custody at such times as agreed upon by the parties. IN THE AL lERNA TIVE, it is Ordered and Decreed that the parties and their respective counsel appear before This Honorable Court, on the day of 2006, at .m., for a Hearing on said Petition. BY THE COURT, J. Kara W. Haggerty, Esquire Shannon Arrowood, W. 8th Street, Waynesboro, P A, 17268 ,. e e HEIDI L. BAILEY, Petitioner : IN THE COURT OF COMMON PLEAS : 39TH JUDICIAL BRANCH : FRANKLIN COUNTY, PENNSYLVANIA v. : NO. F.R. 1994-363 SHANNON L. ARROWOOD, Respondent CIVIL ACTION - CUSTO~ -cl -C I c:::o~ ~ -< OCJ 1- -< --1-.:;. 'I :::r:" N i :~~) : I ...c.. ~ " ~'- ., \ ~.-. -") - \ -< f__~) \ AND NOW, this 20th day of July, 2006, comes the Petitioner, Heidi L. ~ailey, by and ....... = = c:r ""T1 ::0 J'" '"0 Z::O ~o r-< :::;:::I: ~-o --,_..., TO THE HONORABLE JUDGE OF SAID COURT: J> (..J ., .-j _.~ :-;,- ~'J -<-< PETITION FOR SPECIAL RELIEF 0) through her attorney, Kara W. Haggerty, Esquire, of ABOM & KUTULAKIS, L.L.P., and respectfully petitions this Honorable Court to grant Petitioner special relief, and in support thereof avers the following: 1. On or about July 18, 1995, lbis Honorable Court entered an Order granting Petitioner primary physical custody and Respondent partial physical custody of the subject minor child, Cortney L. Arrowood (born October 21, 1992). A copy of the July 18, 1995, Order of Court is attached hereto as 'Exhibit N. 2. On or about 1999, Mother relocated with the child to Cumberland County, Pennsylvania, without an objection from the Father. 3. Mother and the Child have resided in Cumberland County, Pennsylvania since 1999. 4. Between 1995 and present day, Father exercised partial physical custody with the Child even though the Child's primary residence with Mother is in Cumberland County. 5. Since 1999 all medical service providers of the Child are located in Cumberland County. 6. In the beginning of June, Cortney began counseling at the Stevens Center in Carlisle to address issues of emotional abuse by her father and his girlfriend. 7. The Stevens Center requested that Cortney see a psychologist at the Center. e e 8. The psychologist immediately made a referral for a child abuse investigation to Cumberland County Children and Youth. 9. Cumberland County Children and Youth Services made a home visit on July 3, 2006, the same day the referral was made from The Stevens Center. 10. OnJuly 3, 2006, Cumberland County Children and Youth Services issued a 30-day "No Contact" Order against the Father on behalf of Cortney, and immediately transferred the referral to Franklin County Children and Youth Services since the incidents took place at the Father's home in Franklin County. 11. Mother received a letter from Franklin County Children and Youth Services reporting a suspected child abuse incident involving the Child on July 5, 2006. 12. During the home visit by Cumberland County Children and Youth Services, the family was advised that it was that caseworker's belief that this matter would be 'Indicated'. 13. The letter from Franklin County Children and Youth indicated that the Mother was not listed as the alleged perpetrator. 14. It is believed and therefore averred that it is in the child's best interests to be in Mother's primary custody to prevent or limit any negative impact of these actions on the child. 15. It is believed and therefore averred that it is in the child's best interests to be in Mother's primary custody because Mother is able to provide a stable and safe home environment. 16. It is believed and therefore averred that it is in the child's best interests to be in Mother's primary custody because Mother will ensure that her daughter continues with her counseling at The Stevens Center, which is located in the Cumberland County area. e e WHEREFORE, Petitioner prays that This Honorable Court grant her Petition for Special Relief and award her sole physical custody and legal custody of the minor child pending the outcome of the investigation by Franklin County Children and Youth Services. Respectfully submitted, ABOM & KUTULAKIS, L.L.P. DATE D1 Wzj 0& ~uuJ. Kara W. Haggerty, Es Attorney ID No. 8691 36 South Hanover Street Carlisle, P A 17013 (717) 249-0900 Attomry for Petitioner '" e e CERTIFICATE OF SERVICE AND NOW, this ZDt1'L-day of ~ 2006, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Petition for Special Relief, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Shannon Arrowood W. 8th Street Waynesboro, PA 17268 Respectfully submitted, Abom & Kutulakis, L.L.P. Kara W. Haggerty, Es Attorney ID No. 8691 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 ~ 5 cJ/ "1 e e HEIDI L. BAILEY, Petitioner IN THE COURT OF COMMON PLEAS 39TH JUDICIAL BRANCH FRANKLIN COUNTY, PENNSYLVANIA v. : NO. P.R. 1994-363 SHANNON L. ARROWOOD, Respondent o r'l CIVIL ACTION - CUSTO~ ;;'J:: , 0;':": -, _-t'-.J ....... ..,., ~ :n 0:::= c;r :t> <J L- :z: :::0 = A CJ r- !- --I ,- -:1-: "-) " C.) ','I ,.....~ - . '.--' U -j - .~:> " ; -- - '. -< ORDER OF COURT i -- ~- t;'c .-..^r'..' I W ,0 , ...J' AND NOW, this ~ day of July, 2006, upon consideration of the foregoing petition, IT IS HEREBY ORDERED that: 1. A rule is issued upon the Respondent to show cause why the Petitioner is not entided to relief requested. 2. The Respondent shall file a verified Answer to, the Petition to Transfer Venue within twenty (20) days of service upon the Respondent; 3. The Petition shall be decided under Pa.R.C.P. No. 206.7. 4. Deposition shall be completed within days of the service upon Petitioner of the Answer to the Petition to Transfer Venue. 5. Hearing and/or argument shall be held on llaaJA.y Oc.\.bc- ~ ,2006, at ~.m., in Courtroom No. ~ of the Franklin County Courthouse, Chambersburg, Pennsylvania. 6. If Items 4 and 5 are left blank, depositions and or argument or hearing will be considered upon request of any party; and 7. Notice of the entry of the Order shall be provided to all parties by the petitioner. \, "i, e Distribution: Kara W. Haggerty, Esquire ABOM & KUTULAKIS, UP 36 S. Hanover Street Carlisle, PA 17013 Shannon Arrowood, Pro Se W. Eighth Street Waynesboro, PA 17268 e By the Court: ~~ ~#.... Honorable Carol VanHom ~ e e HEIDI L. BAILEY, Petitioner : IN THE COURT OF COMMON PLEAS : 39m JUDICIAL BRANCH : FRANKLIN COUNTY, PENNSYLVANIA v. : NO. F.R. 1994-363 SHANNON L. ARROWOOD, Respondent : CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW: this _ day of June, 2006, it is hereby ORDERED and DECREED that 1bis Honorable Court transfers jurisdiction over the above-docketed custody action to Cumberland County, Pennsylvania. By the Court: J. Distribution: Kara W. Haggerty, Esquire ABOM & KUTULAKIS, LLP 36 S. Hanover Street Carlisle, P A 17013 Shannon Arrowood, Pro Se W. Eighth Street Waynesboro, P A ..... e e HEIDI L. BAILEY, Petitioner : IN THE COURT OF COMMON PLEAS : 39TH JUDICIAL BRANCH : FRANKLIN COUNTY, PENNSYLVANIA v. : NO. F.R. 1994-363 SHANNON L. ARROWOOD, Respondent c.- ~ ('...) ~ :::n -.p.-o :;l:?J ~o I~ .-- .."....- ..-- C) ,,-.") -,..~ (--:JC::> ('-~ 7.;::: ._' ....J .< -<. : CIVIL ACTION - CUSTO~ -0 -0 c:. c: ?J -:r- -' OC) -<. --". ~ \ -,- ~ "(~) r- ch\ ~~ ~ B -<'0 .' N 1. On or about July 18, 1995, This Honorable Court entered an Order granrg Petitioner primary physical custody and Respondent partial physical custody of the subject minor child, r-' <g cr PETITION TO TRANSFER VENUE ~:.-.. Cortney L. Arrowood (born October 21, 1992). 2. On or about July 17, 1995, This Honorable Court entered an Order granting Petitioner and Respondent shared legal custody of the subject minor Child, Cortney L. Arrowood (born October 21, 1992). 3. On or about 1999, Mother relocated with the child to Cumberland County, Pennsylvania, without an objection from the Father. 4. Mother and the Child have resided in Cumberland County, Pennsylvania since 1999. 5. Between 1995 and present day, Father exercised partial physical custody with the Child even though the Child's primary residence with Mother is in Cumberland County. 6. Since 1999 all medical service providers of the Child are located in Cumberland County. 7. On July 5, 2006, Mother received a letter from the Franklin County Children and Youth Service reporting a suspected child abuse incident involving the Child. 8. The letter from Franklin County Children and Youth indicated that the Mother was not listed as the alleged perpetrator. , .... e e 9. Mother avers that Cumberland County, not Franklin County, is the proper venue for this custody action, pursuant to the Uniform Child Custody Jurisdiction and Enforcement Act, and that the custody action filed in Franklin County should be dismissed.1 10. The provisions of the Uniform Child Custody Jurisdiction and Enforcement Act allocating jurisdiction and functions between and among courts of different states shall also allocate jurisdiction and functions between and among courts of common pleas of this Commonwealth.2 11. The Court of Common Pleas of Franklin County does not have exclusive, continuing jurisdiction over this custody matter because neither the children nor their Mother reside in or have a significant connection with Columbia County, and substantial evidence is no longer available in Columbia County concerning the children's care, protection, training and personal relationships.3 WHEREFORE, Respondent respectfully requests This Honorable Court to transfer jurisdiction over the above-docketed custody action to Cumberland County, Pennsylvania. Respectfully submitted, I 23 Pa.C.S.A. ~ 5401 et. seq. 223 Pa.C.S.A. ~ 5471. 3 23 Pa.C.S.A. ~ 5422. . .- \ ~ . ~ e e CERTIFICATE OF SERVICE AND NOW, this 2D~y of ~ 2006, I, Kan W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Petition to Transfer Venue, upon the Defendant/Respondent by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Shannon L. Arrowood U7. Eighth Street Waynesboro, PA 17268 Respectfully submitted, ABOM & KUTULAKIS, L.L.P. Kara W. Haggerty ID No. 86914 36 South Hanover Street Carlisle, P A 17013 (717) 249-0900 Attornry for Plaintiff/Petitioner CL ~'I ......, ' e e HEIDI L. BAILEY, Petitioner : IN THE COURT OF COMMON PLEAS : 39TI-I JUDICIAL BRANCH : FRANKLIN COUNTY, PENNSYLVANIA v. : NO. F.R. 1994-363 AFFIDAVIT OF SERVICE : . 8' nI- -- : CIVIL ACTION - CUSTO... . ;g~ ~ <'^ ,00 G") -< ....);lo :x: I or- w z. ~~ )> );lo~ .. ::: fiiiil :':! , rved with ltme and 1\ :8 )>-0 z:;g ~ r--t %::t: oi 0>0 c:..... :z,)li' ~.~ SHANNON L. ARROWOOD, Respondent I, Kara W. Haggerty, Esquire, hereby certify that the Defendant was correct copy of the Petition for Special Relief on July 26, 2006, by personal service by David K Rudy, as well as with the Petition to transfer Venue on July 28, 2006, by depositing, or causing to be deposited, same in the U.S. mail, certified, restricted delivery, postage prepaid, addressed as follows: Shannon Arrowood 560 West am Street Waynesboro, PA 17268 . Affidavit of Service acknowledging receipt on July 26, 2006, is attached as Exhibit "A". . Return card acknowledging receipt on July 28, 2006, is attached as Exhibit "B". ABOM & KUTULAKIS, LLP Date:~DlID& I!~U). ~I Kara W. Haggerty, E / Supreme Court lD. 8 36 South Hanover Street Carlisle, P A 17013 (717)249-0900 Attornry for Plaintiff -' .r. e e HEIDI L. BAILEY, Petitioner : IN THE COURT OF COMMON PLEAS : 39TI-I JUDICIAL BRANCH : FRANKLIN COUNTY, PENNSYLVANIA v. : NO. F.R. 1994-363 SHANNON L. ARROWOOD, Respondent : CIVIL ACTION - CUSTODY AFFIDAVIT OF SERVICE DAVID K. RUDY, being duly swom according to law deposes and says that I am a competent adult, and that on :1'\,)1.'1 ~C.I ,2006, at ~: 1~.M., I personally served Shannon L. Arrowood at SG,O l..u ~ sr WIIYNt&~l(nIlO Franklin County, Pennsylvania with a true and correct copy of the Petition for Special Relief and Order of Court dated July 24, 2006, issued in the above-captioned matter. ~~ -<)f- DATE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this, the ~IJ?Iv day of -V~ . ' 2006, before me, the undetsigned officer, petsonalIy appeared ~410~ known to me to be the person whose name is subscribed to the within instrument and that ~cuted same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. ~. NOTARY PUBLIC ~ COMMONWEALTH OF PENNSYLVANiA Notarial Seal . Rhonda D. Rudy, Notaryl d Puc b~ Carlisle Boro. CUl~ber an 0 ~ 1 My Commission Expires Aug. 12, 2 Member. Pennsylvania Assocl8tIon of Notaries ,; (~t-.' e e . Com,.. IteriIe 1,2{ ahd S. Also complete Item 4 If Reetricted Delivery Is deslr8d. . Print your neme and ac:IcfnI8s on the I1Mll"88 10 that we CIII'I ...un the card to you. . AttIch thl8 card to the back of the mal1p1ece, or on the front If space permits. . 1. ArtIcIa~ to: ~ ArrMood. 5(,0 WeAt- ~ Sw WlVjf\l~~ FA /7~~ I. ArtIcIa NUmber (11ansfer tvm IIIMceIebel) ~ Pi .......,1. ~ J.G04 3. ServIce 1YPe ~ Mal 0 ElqneaMIIII o RegIstnd .~etuinRecelpt for MerohandIIe o Insured MaH o C.O.D. : 4. Re8trtcted DelIvery? (Ext78 Fee) 'I'M 7003 3110 0004 5768 3927 ~ RIIum...... I ..... : l' milt..,.. i ., . ,. e 4. e IN THE COURT OF COMMON PLEAS OF THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA FRANKLIN COUNTY BRANCH Heidi L. Border, Civil Action - Law Plaintiff, VB. No. F.R. 1994-363 Shannon L. Arrowood, Defendant, Custody ORDER OF COURT NOW, this 1 g t-- day of J <.,;0, , 1995, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: 1. Heidi L. Border (Heidi) and Shannon L. Arrowood (Shannon) shall have shared legal custody of Cortney L. Arrowood (the child), born October 31, 1992. 2. Heidi shall have primary residential custody of the child. 3. Shannon shall have partial residential custody of the child as follows: a. Alternate weekends from Friday at 5:00 p.m. until Sunday at 8:00 p.m.; b. Two unconsecutive periods of summer custody of one week each. c. Shannon shall provide Heidi thirty days written notice as to the weeks he wishes to exercise as his periods of summer custody in 1996 and each year thereafter. In 1995, Shannon shall provide a two-week written notice. 4. Holiday custody shall be as follows: a. In 1995 and each odd year thereafter, Shannon shall have partial custody of the child from 8:00 a.m. to 8:00 p.m. on New Year's Day, July 4 and Thanksgiving. In 1995 and each odd year thereafter, H~idi shall have custody of the child from 8:00 a.m. until 8:00 p.m. on Easter and on the child's birthday, October 31. In 1996 and each even year thereafter, Shannon shall have partial custody of the child at the above times on Easter and on October 31; Heidi shall custody of the child on New Yea:[~ Day~.] Ju 1 y 4 and Thanksg i v ing ; ~ ~ r r.: ~~ ~~ :-:" ~,K ~'. ~ ' l CJ ~.. ~,j.. (... (-i _ --:...;0 c,..:,o "r1 c; F..; '"tI c: 0 :n ;;~ Q r-" 2 .;.Ui ~63 .. ~~rtJ m.r::.. 0 :t1 ~lJ CJ") ;po a, .. e e cont'd. Heidi L. Border v. Shannon L. Arrowood F.R. 1994-363 Page Two b. Christmas shall be shared such that in 1995 and each odd year thereafter, Heidi shall have custody of the child from 6:00 p.m. December 23 until 12:00 Noon on December 25; Shannon shall have partial custody of the child from 12:00 Noon on December 25 until 6:00 p.m. on December 27. In 1996 and each even year thereafter, Shannon shall have partial custody of the child from 6:00 p.m. December 23 until 12:00 Noon December 25 and Heidi shall have custody of the child from 12:00 Noon December 25 until 6:00 p.m. December 27. 5. Holiday custody shall take precedence over all regularly-scheduled periods of weekend and/or summer custody. 6. Transfer of custody shall take place at the Norland Shopping Center McDonald's. 7. The costs of this proceeding have been paid by the Plaintiff. By the Court, k.L q ,l~ J. " e e IN THE COURT OF COMMON PLEAS OF THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA FRANKLIN COUNTY BRANCH Heidi L. Border, Civil Action - Law Plaintiff, V8. No. F.R. 19ftoJ~C'~ '4 ~ ~'I" 'f C! · ..... ~ .=J C,', ~ ...,.' ( J Shannon L. Arrowood, ( . ( - r' : 2) ~> f.;.Y-"'-.i ~.~"'" .....: . C.,; 1 Defendant, CU8tody --J ......,... , .....~. , . "'" "'J _n ..:"",., 8 ~~ ~~.~ ~ ,,~ 0 -;-1 " ~ ;~;;J (-) - · · _oj 5, fn This Stipulation and Agreement is made thi -A_____ 4ey 0~'8 ,T~,(l~ ' 1995, by and between Heidi L. Border of 5699 oatowq.> I Road, Or stown, Franklin County, Pennsylvania (hereinafter referred to as "Heidi") and Shannon L. Arrowood of 401 Hood Street, Chambersburg, Franklin County, Penn8ylvania (hereinafter referred to as "Shannon"). STIPULATION AND AGREEMEH!r 1. Heidi and Shannon are the natural parents of Cortney L. Arrowood, born October 31, 1992, (hereinafter referred to as "the child"). 2. Heidi and Shannon are not married. 3. Neither party has participated as a party in other litigation concerning the custody of the child in this Court. 4. None of the parties has information of a custody proceeding concerning the child pending in a court of this commonwealth. 5. None of the parties knows of any person not a party to the proceedings who has physical custody of the child, or claims to have custody or visitation rights with respect to the child. 6. Since birth, the child has resided with the following persons at the following addresses: Persons Addresses ~ Heidi L. Border Paul S. Burkholder Christine M. Burkholder 5699 Orrstown Road Orr8town, PA From Birth to December, 1992 Heidi L. Border Shannon L. Arrowood Don Arrowood Joyce Arrowood Amanda Arrowood 401 Hood Street Chambersburg, PA December, 1992 to May, 1993 e e Heidi L. Border WIN Shelter Chambersburg May, 1993 to June, 1993 Heidi L. Border Shannon Arrowood Lincoln Way West Chambersburg, PA June, 1993 to April, 1994 Heidi L. Border Paul S. Burkholder Christine M. Burkholder 5699 Orrstown Road Orrstown, PA April, 1994 to Present 7. The parties have reached an agreement with regard to the custody of the child and desire to reduce their agreement to an Order of Court. NOW, THEREFORE, the parties, intending to be legally bound and waiving their right to be present when this Agreement and Order are presented and executed, hereby stipulate and agree that the Court may enter the following Order of Court in the above-captioned case: ORDER OF COUR~ NOW, this day of , 1995, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: 1. Heidi L. Border (Heidi) and Shannon L. Arrowood (Shannon) shall have shared legal custody of Cortney L. Arrowood (the child), born October 31, 1992. 2. Heidi shall have primary residential custody of the child. 3. Shannon shall have partial residential custody of the child as follows: a. Alternate weekends from Friday at 5:00 p.m. until Sunday at 8:00 p.m.; b. Two unconsecutive periods of summer custody of one week each. c. Shannon shall provide Heidi thirty days written notice as to the weeks he wishes to exercise as his periods of summer custody in 1996 and each year thereafter. In 1995, Shannon shall provide a two-week written notice. 4. Holiday custody shall be as follows: a. In 1995 and each odd year thereafter, Shannon shall have partial custody of the child from 8:00 a.m. to 8:00 p.m. on New Year's Day, July 4 and Thanksgiving. In 1995 and each odd year thereafter, Heidi shall have custody of the child from 8:00 a.m. until 8:00 p.m. on Easter and on the child's birthday, October 31. In 1996 and each even year thereafter, Shannon shall have partial custody of the child at the above times on Easter and on October 31; Heidi shall custody of the child on New Year's Day, July 4 and Thanksgiving; , ,'" e . b. Christmas shall be shared such that in 1995 and each odd year thereafter, Heidi shall have custody of the child from 6:00 p.m. December 23 until 12:00 Noon on December 251 Shannon shall have partial custody of the child from 12:00 Noon on December 25 until 6:00 p.m. on December 27. In 1996 and each even year thereafter, Shannon shall have partial custody of the child from 6:00 p.m. December 23 until 12:00 Noon December 25 and Heidi shall have custody of the child from 12:00 Noon December 25 until 6:00 p.m. December 27. 5. Holiday custody shall take precedence over all regularly-scheduled periods of weekend and/or summer custody. 6. Transfer of custody shall take place at the Norland Shopping Center KcDonald's. 7. The costs of this proceeding have been paid by the Plaintiff. By the Court, J. The parties further agree that, in procuring this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other. IN WITNESS WHBREOF, the parties, intending to be bound by the terms and conditions of this Agreement, execute this Agreement by signing below. wtl~ lhCLJ ~.~~ ~itness "" ~cJ,~ Heidi L. Border ,jJ~_ /t;vU07---./~ Shannon L. Arrowood I verify that the statements made in this Stipulation and Agreement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authoriU... /fI2~( /. -lbrilfL Heidi L. Border ", .... . . I verify that the statements made in this Stipulation and Agreement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. M4/VI.LT""7'7", d",z1<n'd) (L~ Shannon L. Arrowood