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cl)nllldered major decisions and shall be made by the parties Jointly,
after dlsCUIIsion lInd consultation with each Clther and with a view
towards obtaining and following a harmonious policy in the child's best
Interests,
3. Mother shall have primary physical custody of the minor
child subject to periods of partial custody and visitation with Father as
follows:
A, On alterneting weakends such that Father will pick
up the child no later than 5:30 p,m, and will deliver the child
on Sunday at 6:30 p.rn,. or if thero Is a major holiday on a
Monday, then the time will be extended until Monday at 6:30
p.m. Father will either pick lip the child at the child's day care
or at a neutral site, The pick up of the child will be determined
after the parties have been in discussion with Bonnie Howard,
The parties acknowledge that Bonnie Howard will make the
final determination as to the appropriate pick up spot, This
alternating schedule will begin on 9 February 1996.
B. On alternating Tuesdays beginning at 5:30 p.m, until
8:00 p.m. on Tuesday evening, Father will either pick up the
child at the child's day care or at a neutral site. The pick up of
the child will be determined after the parties have boen in
dlacu..IQIl with Bonnie Howard, The partlel aoknowledge that
Bonnl, Howard will make the final determination 88 to the
appropriate pi ok up spot. Thl8 alternating sohedule will begin
on Tuesdey, 20 FebrUlIrY 1996.
4. The parties will share the following holidaye: New Year'a
Day, Easter, Memorisl Day, and Labor Day. Father will have New
Year's Day and Memorial Day in even-numbered years and Easler and
labor Day in odd-numbered years. Mother will have Easter and Labor
Day In even-numbered years and New Year's Day and Memorial Day In
odd-numbered years, The times for these periods of visitation will be
from 10:00 a.m. until 7:00 p.m.
6. Since Father's birthday is on July 4th, he shall have
visitation on that day every year, In consideration for that holiday,
Mother shall have Thanksgiving Day every year. The times for these
periods of visitation will be from 10:00 a.m. until 7:00 p.m.
6. Father shall have Christmas Day every year beginning at
10:00 a.m. and ending at 7:00 p.m.
7. Father shall be entitled to fourteen (, 4) days of vacation
with the child and he will provide Mother with at least two weeks'
notloe of the dllYs In which he intends to exercise these times except
thet If Father Intends to have s period of seven days or more, he must
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provide Mother with thirty (30) days notice In advance. The partlel
elJrefl that this vocation time will not be exercised until ot least the
lummer and only until Bonnie Howard Indicates that It is acceptable
for these visitation periods to occur.
8. Mother shall have Mother's Day each year, and Father shall
have Father's Day each year.
9. Should a holiday fall on either party's scheduled weekend,
the holiday sholl toke precedent over tho regular schedule.
10. If the child becomes ill during either party's custody with
the child, then that party shail notify the other party immlldiately
regarding either return 01 the child or the doctor's instructions, if any.
11. Should Father not be available to ba with the child during
his periods of visitation, the child sholl be left in the temporary care of
either Grace Brooker or Martha Brooker, In the event Father ill not
available for the entire weekend, .Jennlfer sholl remain in the custody
of her Mother. Should Mother not be aveilable to be with the child
during times other then normal working hours, Jennifer shall be left in
the csre of either Delores Wells or Deb Wells, This paragraph sholl be
reviewed by Bonnie Howard and eny changes or elterations to it shall
be made by Bonnie Howard end the parties agree to whatever changes
Êshe suggesta.
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'UL 1It00Q.,
Plaintiff
v.
I IN THE CQURT or COMMON P~A'
I
I CUMBERLAND COUNTY, PENNSYLVANIA
I
l NO. 89 Civil, 1994
I
CIVIL ACTIO/l - LAW
DJ:JUl'N~ "11.1.8,
D03fendant
CUSTODY
o R ULE
AND NOW, 'rrl~,t.. .;I1i':tJ..., 1994, upon oonsider~tion of the
foregoing stipulation, it is hereby ORDERED ~nd DECREED, ~.
follows:
1. The parties shall have shared legal custody of the
parties child, Jennifer Lynn Wells, born October 19, 1989 and
Defendant mother shall have primary physical custody of the
child.
2. The Plaintiff father shall have partial physical custody
for the purpose of visitation as followsl
a. Beginning March 27, 1994 from 12:00 p.m. until 4:00 p.m.;
April 10, 1994 from 12:00 p.m. to 4:00 p.m.; April 23, 1994 from
12:00 p.m. until 5:30 p.m.; May 7, 1994 from 12:00 p.m. until
5:30 p.m., May 21, 1994 from 12:00 p.m. until 5:30 p.m. and May
22, 1994 from 12:00 p.m. until 5:30 p.m.
b. Beginning June 3, 1994 from 6:30 p.m. until June 4, 1994
at 6:30 p.m.; June l~, 1994 from 6130 p.m. until June 18, 1994 at
6:30 p.m.
Exhibit "A"
c. Beginning July 2, 199~ frow 12:00 p.m, until July 4,
1994 at 6:30 p.m., thereafter every other. weekend beginning
Friday July 15, 1994 at 6:30 p.m. until Sunday at 6130 p.m.
d. Christmas Day eaoh year from 12:00 noon until 6100 p.m.
e. Every other holiday whioh shall inolude New Year's Day,
Easter, Memorial Day, Labor Day from 10:00 a.m. until 7100 p.m.
Since Father's birthday i~ on July 4th, he shall have visitation
on that day every yellr. In consideration for that: holiday, Mother
shall have Thanksgiving day ~very year. The holiday schedule
ahall begin with Mother having Easter, 1994.
3. Mother shall. have Mother' fl Day each year and Father shall
have Father's Day each year.
4. Should a holiday tall on either parties' scheduled
weekend, the holiday shall take precedent over the regular
schedule.
5. Father shall not be permitted to pick the child up at
any daycare facility where she may be attending without mother's
consent.
6. Father agrees to be responsible for all transportation
relative to his viaitation periods.
7. If the child becomes ill during Father's physical
custody, Mother shall be consulted immediately regarding either
the return of the child or dootor's instructions.
8. Should Father not be available to be with the child
during his periods of visitation, the child shall be left in the
temporary care of either Grace Brooker or Martha Brooker. In the
event father is not available for the entire weekend, Jennifer
shall remain in the custody of her mother. should Mother not b.
available to be with Jonnifer during times other than normal
working hours, Jennifer shall be left in the oare ot either
Uelores Wells or Deb Wolls.
9. The child shall not be removed trom tho state ot
Pennsylvania without each parties' knowledge.
lO. Father shall pay to MolhAr, tor the support of the
partl.es' child, ,.he sum at $80.00 per week. 'l'his amount may be
modlfied, if necessary. ~dther shall also De responsible to
provide medical insurance coverage, as long as he has coverage
available through hJ.s employment, for the child IIntil suoh time
as she reaches age IB, or graduates from college, whichever ie
later. Any dental and medical expenses not covered by insuranoe,
including the expenses excluded by the deductible, shall be
equally shared by Mother and Father. In the event ~'ather no
longer has coverage through employment, he shall share the oost
with Mother to maintain medical coverage tor Jennifer through her
employment. In the event neither party has medical coverage
provided through their employment, then the parties shall share
the cost of medical coverage for Jennifer. This support agreement
shall be entered as an ordered through the Dauphin County
Domestic Relations Office should Father become delinquent in the
payment of child support for a period of two weeks. In the event
an Order is entered through Domestic Relations, a wage attachment
shall be entered against Father.
11. Upon mutual 'agreement , an expanded or altered schedule
may be agreed upon between the parties for and in the best
o. Beginning July 2, 1994 froM 12:00 p.m. until July 4,
1994 at 6:30 p.m.1 ther~after every other weekend beginning
Friday July 15, 19~4 at 6:30 p.m. until Sunday at 6:30 p.m.
d. Christmas Day each year from 12:00 noon until 6100 p.~.
e. Every other holiday which shall include New Year's Day,
EastRr, Memorial Day, Labor Day from 10:00 a.m. until 7:00 p,m.
Since Father's birthday is on July 4th, he shall have visitation
on that day every yea". In con~ider~tion for that hOliday, Hother
shall have Thanksgiving day every year. The holiday schedule
shall begin with Mother having Easter, 1994.
3. Mother shall have Mother's Oay each year and Father shall
have Father's Day each year.
4. Should a holiday fall on either parties' scheduled
weekend, the holiday shall take preoedent over the regular
~chedulo.
5. Father shall not be permitted to pick the ohild up at
any daycare facility where she may be attending without mother's
oonsent.
6. Father agrees to be responsible for all transportation
relative to his visitation periods.
7. Father agrees that if the child becomes ill during his
physical custody, Mother shall be consulted immediately regarding
either the return of the child or doctor's instructions.
8. Father agrees that if he is not available to be with the
child during his periods of visitation, the child shall be left
in the temporary care of either Grace Brooker or Martha Brooker.
In tho event father is not available for the entire weekend, he
agrees that Jennifer shull remuin in the oustody of her mother.
Mother also agrees that if she is not available to be with
Jenniter dUl'ing times other than normal working hours, that
Jenniter shall be loft in the care of either Deiores Wells or Deb
Wells.
9. The parties agrees that they ahall not remove the child
tram the State of Pennsylvania without tlach other's knowledge.
10. Father agroes to pay Mother, tor the support at the
parties' child, the sum of $80.00 per week. The parties agree
that this amount may be modified, if necessary. Father shall also
be responsible to provide medical insurance ooverage, as long as
he has coverage available through his employment, for the child
until such time as she reaches age 18, or graduates from college,
whichever is later. Any dental and medical expenses not covered
by insurance, including the expenses excluded by the deductible,
shall be equally shared by Mother and Father. In the event
Father no longer has coverage through flmployment, he agrees to
share the cost to Mother to maintain medical coverage for
Jennifer through her employment. In the event neither party has
medical coverage provided through their employment, then th~
parties agree to share the cost of medi.cal coverage for Jenniter.
The parties agree that this support agreement shall be entered as
an ordered through the Dauphin county Domestic Relations otfice
should Father become delinquent in the payment of child support
tor a period of two weeks. In the event an Order is entered
through Domestic Rel~tions, Father also agrees to the entry ot a
wage attachment.
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c. Beginning July 2, 1994 froM 12/00 p.m. until July 4,
1994 at 6/30 p.m" thereafter every other weekend beginning
Friday July 15, 1994 at 6130 p.m. until Sunday at 6/30 p.m.
d, Christmas Day each year from 12100 noon until 6/00 p.m.
e. Every other holiday which shall include New Year's Day,
Easter, Memorial Day, Labor Day from 10100 a.m. until 7/00 p,m.
Since 'ather's birthday is on July 4th, he shall have visitation
on that day every year. In Qoncideration for that hOliday, Mother
shall have Thanksgivinq day every year. The holiday schedule
shall begin with Mother having Easter, 1994.
3. Mother shall have Mother's Day each year and Father shall
have Father's Day each year.
4. Should a holiday fall on either parties' scheduled
weekend, the holiday shall take precedent over the regular
schedule.
5. Father shall not be permitted to pick the child up at
any daycare faoility where she may be attendinq without mother'.
consent.
6, Father agrees to be responsible for all transportatiQn
relative to his visitation periods.
7. Father agrees that if the child becomes ill during hi.
physical custody, Mother shall be consulted immediately regarding
either the return of the child or doctor's instructions.
8. Father agrees that if he io not available to be with the
ohild during his periods of visitation, the child shall be left
in the temporary care of either Grace Brooker or Martha Brooker.
In the event father is not available for the entire weekend, he
agrees that Jennifer shall remain in the custody of he~ mother.
Mother also agrees that if she is not available to be with
Jennifer c;lul'lng times other than normal working hours, that
Jenni.ftlr shall be left in the oare of either Delores Wells or Deb
Wells.
9. The parties agrees that they shall not remove the ohilc;l
trom the state of pennsylvania without each other's knowlec;lge.
10. Father agroes to pay Mother, for the support of the
parties' chilc;l, the eum of $80.00 per week. The parties agree
that this amount may be moc;lified, if necessary. Father shall aleo
be responsible to provide medioal insurance coverage, as long ae
he has ooverage available through his employment, for the child
until such time as she reaches age lB, or graduates from oollege,
whiohever is later. Any dental and medical expenses not oovered
by insurance, including the expenses exoluded by the c;leduotible,
shall be equally shared by Mother and Father. In the event
Father no longer has coverage through employment, he agrees to
share the cost to Mother to maintain medioal ooverage for
Jennifer through her employment. In the event neither party has
medical coverage provided through their employment, then th..
partiee agree to share the cost of medioal coverage for Jennifer.
The parties agree that this support agreement shall be entered .s
an ordered through the Dauphin County Domestic Relations Office
should Father become delinquent in the payment of chilc;l support
for a period of two weeks. In the event an Order is entered
through Domestic Relations, Father also agrees to the entry of a
wage attaohment.
IUL .aoo..., I IN THE COURT or COMMON PLlAS
I
Plaintiff I CUMBERLAND COUNTY, PENNSYJ,VANJA
I
V. I NQ. 89 Civil, 1994
I
DI1UDIA WILLI, I CIVIL ACTION - LAW
I
Oefendant I CUSTODY
0 R D E R
AND NOW, n,..c.I. il'r 1994, upon consideration of the
foreqoinq stipUlation, it is hereby ORDERED and DECREED, a.
follows,
1. The parties shall have shared legal custody of the
parties child, Jennifer Lynn Wells, born October 19, 1989 and
Defendant mother shall have primary physioal custody of the
child,
2. The Plaintiff father shall have partial physical custody
for the purpose of visitation as follows,
a. Beginning March 21, 1994 from 12:00 p.m. until 4'00 p.m.,
April 10, 1994 from 12:00 p.m. to 4'00 p.m.; April 23, 1994 frolll
12100 p.m. until 5:30 p.m.; May 7, 1994 from 12:00 p.m. until
5130 p.m., May 21, 1994 from 12:00 p.m. until 5130 p,m. and May
22, 1994 frolt,i~,uo pill. until 5130 p.m.
b. Beginnl~~'June 3; 1994 from 6:30 p.m. until June 4, 1994
at 6130 p.t~"I/~ii^q,l7fjZ Uf.94 from 6'30 p.m. until June 18, 1994 at
6:30 p.m.
o. Beginning July 2, 199~ fro~ 12100 p.m. until July 4,
111114 at 6130 p.m., thereaft.er every other weekend beginning
Friday July 15, 1994 at 6130 p.m. until Bunday at 6130 p.m.
d. Christmas Day eaoh year from 12100 noon unt.ll 6100 p,m.
e. Every other holiday whioh shall inolude New Year's Day,
Easter, Memorial Day, Labor Day from 10100 a.m. until 7100 p.m.
Sinoe Father's birthday is on July 4th, he shall have visitation
on that day every year. In considerat.ion for that holiday, Mother
shall have Thanksgiving day every year. The holiday schedule
shall begin with Mother having Easter, 1994.
3. Mother shall have Mother's Day eaoh year and Father shall
have Father's Day each year.
4. Should IS holiday fall on either partiss' scheduled
weekend, the holiday shall take precedent over the regular
schedule.
5. Father shall not be permitted to pick the child up at
any daycare facility where she may be attending without mothsr's
consent.
6. Father agrees to be responsible for all transportation
relative to his visita~ion periods.
7. If the child becomes ill during Father's physioal
oustody, Mother shall be consulted immediately regarding either
the return of the ohild or doctor'o instructions.
8. Should Father not be available to be with the ohild
during his periods of visitation, the child shall be left in the
temporary care of either Graoe Brooker or Martha Brooker. In the
event father is not available for the entire weekend, Jennifer
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shall remain in the custody of her Mothe.r. Should Mother not be
available to be with Jennifer during times other than normlill
working hours, Jennifer shall be left in the care of eithlilr
Delores Wells or Deb Wells.
9. The child shall not be removed from the state of
Pennsylvania without each parties' knowledge.
10. Father shall pay to Mother, for the support of the
parties' ohild, the sum of $UO.OO per week. Thls amount may be
modified, if necessary. Father shall also be responslble to
provide medical insurance ooverago, as long as he has coverage
available through his emplClyment, for t.he child until such time
ae she reaches age 18, or graduates from college, whichever is
later. Any dental and medical expenses not covered by insurance,
inoluding the expenses excluded by the deductible, shall be
equally shared by Mother and Father. In the event Father no
longer has coverage through employment, he shall share the cost
with Mother to maintain medical coverage for Jennifer through her
employment. In the event neither party has medical coverage
provided through their employment, then the parties shall share
the cost. of medical coverage for Jellnifer. 'l'his support agreement
shall be entered as an ordered through the Dauphin county
Domestic Relations Office should Father become delinquent in the
payment of child support for a period of two weeks. In the event
an Order is entered through Domestic Relations, a wage attachment
shall be entered against Father.
11. Upon mutual agreement, an expanded or altered schedule
may be agreed upon between the parties for and in the best
kall
January 5, 1994
a. Plaintiff wishes to be a part of Jennifsr'u lif.
and it is 1n Jennlfar's bast intareats to have II meaningful
relationship with her father.
b. Plaintiff is able to oare for Jennifer during his
periods of oustody.
8. Plaintiff L"equellts shared legal oustody and the
following schedule of partJ.al CUEltody:
a. Plaintiff shall have custody of Jennifer every
other Monday after work untJ.l B:OO p.m.
b. Plaintiff shall have custody of Jennifer ever.y
other weekond from after work on Friday until Sunday at 7:30 p.m.
o. Plaintiff and Defendant shall alternate major
Holidays with Jennifer, major Holidays being New Years Eve, New
Years Day, Easter Sunday, Memorial Day, July 4th, Labor Day,
Thanksgiving Day, Christmas Eve and Christmas Day.
d. Father shall have Jennifer for Father's Day and
Mother for Mother's Day. If Mother's Day falls on Father's
custodial weekend, he shall return Jennifer to Mother's home by
8:00 p.m. Saturday evening betore Mother's Day. The same
schedule shall pertain to Father's Day, if Father's Day falls on
Mother's custodial weekend.
e. Father shall have custody of Jennifer for Father's
birthday and Mother for Mother's birthday. If Father's birthday
occurs during Mother's custodia 1 period, she shall return
Jennifer to Father's home by 6:00 p.m. on the evening before
3
kas
J anullry 5, 1994
Father's birthday. The same sohedule shall pertain to Mother's
birthday, if Mother's birthday ocours during Father's custodial
period.
f. The above schedule shall be in effect throughout
the lIohool year and .Jennifer shall reside with Mother. During
summer vaoation Jennifer shall reside wIth Father and Mother
shall have custodial periods as stated In a. and b. above.
g. Mother shall notify Father of .11 Illnesses and/or
dootor visits.
h. Mother shall notify Father of any school
activities, such as parent/teacher meetings, school functions,
field trips, etc. to facilitate participation by both parents.
I. Two sets of school pictures shall be ordered, one
for each parent, each parent being responsible for payment of
their own set of pictures.
j. Mother shall continue health insurance coverage
for Jennifer as is currently in effect.
9. Each parent whose parental rights to th. child have not
been terminated and the person who has physical custody of the
child have been named as parties to this action.
WHEREFORE, Plaintiff requests the court to grant partial
custody of the child to him in accordance with the requested
schedule.
L,t~. vf '7{fdtt."K.-.-
'~a L. Mellt n
Attorney for Plaintiff
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