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CINDY L. WICKARD,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 94 - jt} 'lJ CIVIL TERM
JOHN C. WICKARD,
Defendant
PROTECTION FROM ABUSE
AND CUSTODY
Tt:MP,oRhRY PROTECTIVj;oRPeR
AND NOW, this leu.. day of ~, 1994, upon
presentation and consideration of the wi thin Peti tion, and upon
finding that the plaintiff, CINDY L. WICKARD, now residing at 416
Mumper Lane, Dillsburg, York County. Pennsylvania, is in immediate
and present danger of abuse from the defendant, JOHN C. WICKARD,
the following Temporary Order is entered.
The defendant, JOHN C, WICKARD, now residing at 1722A Walnut
Bottom Road, Cumberland County, Pennsylvania, is hereby enjoined
from physically abusing the plaintiff, CINDY L, WICKARD, or placing
her in fear of abuse.
The defendant is enjoined from damaging or destroying any
property owned jointlY by the parties or owned solely by the
plainti ff,
The defendant is ordered to refrain from harassing or stalking
the plaintiff, and harassing the plaintiff's relatives or minor
children.
The defendant is ordered to stay away from the residence
located at 416 Mumper Lane, Dillsburg, Pennsylvania, or any other
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residence the plaintiff may establish for herself In the future,
except to facilitate custody, when the defendant will pick up and
drop off the child, outside of the residence,
The defendan t is hereby no I if i od I ha t if he resi des in the
plaintiff's domicile contrary to this Ordor, he may be In Indirect
criminal contempt which Is punishable by a fino not to exceed
$1,000.00 and/or by a sentence of up to six months in jail and any
other appropriate punishment. Resumption of co-residence on the
part of the plaintl ff and defendant shall not null i fy the
provisions of the Court Order directing the defendant to refrain
from abusing the plaintiff.
Temporary custody of ERICA M, WICKARD 16 hereby awarded to the
plaintiff, CINDY L. WICKARD.
This Order shall remain in effect until a final order is
entered in this case. A hearing shall be held on this matter on
the .2-1~ day O_f ~, 1994, at q..~O a .m. in
Courtroom No.~, Cumberland County Courthouse, Carlisle,
Pennsylvania.
The plaintiff may proceed In forma Pauperis pending a further
order after the hearing.
The Cumberland County Sheriff's office shall attempt to make
service at the plaintiff's request, but service may be accomplished
under any applicable rule of Civil Procedure,
The Pennsylvania State Police Department and the Dillsburg
Police Department will be provided with a copy of this Order by
attorneys for the plaintiff. This Order shall be enforced by any
law enforcement agenoy where a violation oocurs by arrest for
indireot criminal oontempt without warrant upon probable oaUse that
this Order has been violated, whether or not the violation is
committed in the presenoe of the police officer. In the event that
an arrest is made under this section, the defendant shall be taken
without unnecessary delay before the court that issued the Order,
When that court is unavailable, the d 11 be taken before
the appropriate district 66113).
J.
CINDY L. WICKARD
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
v,
NO. 94 -
CIVIL TERM
JOHN C. WICKARD,
Defendant
PROTECTION FROM ABUSE
AND CUSTODY
NonCE
You have been sued In court. If you wish to defend against
the claims set forth In the followlng pages, you must take actlon
promptly after thls Petitlon, Order and Notlce are served, by
appearing personally or by attorney at the hearlng scheduled by the
Court and presentlng to the Court your defenses or objectlons to
the c1alms set forth agalnst you. You are warned that lf you fall
to do so the Court may proceed wlthout you, and a jUdgment may ba
entered agalnst you by the Court wl thout further notlce for any
money c1almed ln the Petitlon or for any other c1alm or re11ef
requested by the p1alntlff. You may lose money or property or
other rlghts lmportant to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 00
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.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
CINDY L. WICKARD
Plaintiff
I IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
v.
NO. 94 -
CIVIL TERM
JOHN C. WICKARD.
Defendant
PROTECTION FROM ABUSE
AND CUSTODY
P~IITION FOR PROTECTIVE ORDER
AND CUSTODY
R~I.I~FpUND~A THE PAOTECTIONFROM ABUS~ ACT
~3 P.S. SECTION 6101
A. ABUSE
1. The plaintiff is an adult indiVidual whose permanent
address is 1722A Walnut Bottom Road. Carlisle, Cumberland County,
Pennsylvania. 17013.
2. The defendant Is an adult individual residing at 1722A
Walnut Bottom Road. Carlisle. Cumberland County. Pennsylvania,
17013.
3. The defendant is the plaintiff's husband.
4. Since August. 1992. the defendant has attempted to cause
and has Intentionally. knowingly, or recklessly caused bodlly
injury. and by physical menace has placed the plaintiff in fear of
Imminent serious bodily injury, This has included but Is not
limited to the followfng specific instances of abuse:
a. On or about July 4, 1994. the plaintiff was lying in bed
when the defendant became angry with her and threw himself directly
on the plafntiff, pushing her onto tho floor and causing her to
twist her back, hit her hip, and scrape her elbow. The plaintiff
call ed the poll ce lmmed la te 1 y, but the defendant 1 eft the home
before the police arrived, As a result of the defendant's abuse,
the plaintiff suffered back pain, lacerations and brush burns.
b. On or about June 26, 1994, while driving home the
defendant became angry with the plaintiff and begen screaming at
her. The p1alnt1ff, In an attempt to block out his screams, put
her fingers In her ears. The defendant reached over and slapped
the p1alnt1ff's left arm down, but the plaintiff replaced her
fingers. When they reached a stoplight the defendant grabbed both
of the p1alnt1ff's arms, crossing them In front of her so she
couldn't move, and pulled her down so that the upper portion of her
body was lying across the arm rest, The defendant shook the
plaintiff, threatened her, demanding, "You will talk to me."
c. On or abou t Apr 11 1993, t he defendant became angry wi th
the p1alnt1ff while the plaintiff was attempting to remove the
chlld's car seat from the car. The defendant backed up the car
while the plaintiff was standing between the open passenger side
door and the car causing the plaintiff to twist her ankle In an
attempt to get out of the path of the mOVing car. As a result of
the defendant's abuse the plaint 1 ff received medical treatment from
her physician.
d. On or about March, 1993, when the plaintiff was
apprOXimately eight months pregnant, the defendant became angry
with the plaintiff and slapped her across her cheek, causing welts.
e. In addl t Ion to the above Instances of abuse, the defendant
has abused the plaintiff In ways Inoludlng grabbing the plaintiff
by her arms. oausing bruises. pushing the plaintiff into a table.
oausing bruising about her upper thigh, and pushing the plaintiff
about her body oausing bruises. In addition. the defendant has
frightened the plaintiff and attempted to ls01ate her by pUlling
the phones from the wall and unplugging the spark plugs from the
plaintiff's oar.
5. On or about July 6, 1994. the plaintiff and her two
children left their residence at 1772A Walnut Bottom Road.
Carlisle. Cumberland County, Pennsylvania. In order to avoid
further abuse.
6. The plaintiff believes and therefore avers that she will
be in immediate and present danger of abuse from the defendant
should she return to the home with her children and that she is in
need of protection from such abuse.
7. The p1alnt I ff desi res that the defendant be ordered to
stay away from the residence located at 416 Mumper Lane, Dlllsburg.
Pennsylvania, or any other residence the plaintiff may establish
for herself in the future. oxcept to facilitate custody, when the
defendant will pick up and drop off the child, outside of the
residence.
8. The plaintiff desi res that the defendant be restrained
from harassing or stalking the plaintiff, and harassing the
plaintiff's relatives or minor children,
B. TEMPORARY CUSTODY
9. The plalntlff seeks temporary custody of the follOWing
child:
NllmQ
ERICA M. WICKARD
prpaQnt Rp1l1dQncp
416 Mumper Lane
Dillsburg, PA
AOQ
1 year old
The child was not born out of wedlock.
The child is presently in the custody of CINDY L. WICKARD who
currently resides at 416 Mumper Lane, Dillsburg, Pennsylvania.
During the child's lifetime the child has resided with the
following persons and at the following addresses:
Namp AddressQs
OA1!Ui
4/93 to 9/93
Plaintiff. Benjamin 416 Mumper Lane
J. Cassel Dillsburo, PA
(plaintiff's minor
son), Doris and Gary
Cassel (plainti f f' s
parents)
Plaintiff, defendant 1722A Walnut Bottom Road
and Benjamin J. Carlisle, PA
Cassel
Plaintiff, Doris and 416 Mumper Lane 2 weeks during
Gary Cassel and Dillsburg, PA 12/93
Benjamin J. Cassel
9/93 to 12/93
Plaintiff, Defendant 1722A Walnut Bottom Road 12/93 to
and Benjamin J. Carlisle, PA 7/6/94
Cassel
Plaintiff, Doris and 416 Mumper Lane 7/6/04 to
Gary Cassel and Dillsburg present
Benjamin J. Cassel
The mother of the child is CINDY L. WICKARD, currently
residing at 416 Mumper Lane, Dillsburg, Pennsylvania.
She is married.
The father of the child is JOHN C. WICKARD, currently residing
at 1722A Walnut Bottom Road, Carlisle, Pennsylvania.
He is married.
The plaintiff currently resides with the following persons:
Name RelAtionship
Doris Cassel Mother
Gary Cassel Father
Benjamin J. Cassel Minor Son
Erica M. Wickard Minor Daughter
Gary E. Cassel, II Brother
The defendant currently resides alone.
10. The plaintiff has not preViously partioipated in any
litigation ooncerning oustody of the above mentioned ohild in this
or any other Court,
11. The plaintiff has no knowledge of any custody proceedings
concerning this ohild pending before a court in this or any other
j u r i sd i c t ion.
12. The plaintiff does not know of any person not a party to
this action who has physical custody of the child or olaims to have
oustody or visitation rights with respect to the child.
13. The best interests and permanent welfare of the child
will be met if custody is temporarily granted to the plaintiff
pending a hearing in this matter for the following reasons:
a. The plaintiff i8 a fit parent who can best take care
of her ohild.
b, The defendant has shown by his abuse of the
plaintiff that he is not an appropriate role model for the ohild.
C. SUPPORT
14. The defendant has a duty to support tho plaint Iff and
their minor child.
15. The defendant works at Leer Electric, Inc., and hu
annual salary In excess of $24,000,
16. The plaintiff currently has no income.
17. The plaintiff Intends to petition for support within two
weeks of the Issuance of a protective order.
D. ATTORNEY FEES
18. The plaintiff asks for attorney foos. payablo to Legal
Services, Inc.. pursuant to the Protection from AbuBO Act,
E, STATUS TO PROCEED IN FORMA PAUPERIS
19. The plaintiff does not have funds avallablo to pay tho
fees for filing and service.
WHEREFORE. pursuant to the provisIons of tho "protootlon from
Abuse Act" of October 7. 1976, 23 P.B. 66101 01 spq.. as amonded,
the plaintiff prays this Honorablo Court to grant the follOWing
relief:
A, Grant a Temporary Order pursuant to tho "Protootlon from
Abuse Act:"
1. ReqUiring the defendant to rofratn from abu81ng the
plaintiff or placing her In foal' of abuBo.
2. Roquirlng that tho defondant bo r08tratnod from
harassing or stalking tho plaintiff, and harassing the
plalntlff's relativos or minor chlldron.
3. Grent Ing tomporary custody of tho minor I:hild to tho
plaintiff.
4. ordering the defendant to stay away from the
residence located at 416 Mumper Lane, Dillsburg, Pennsylvania,
or any residence the plaintiff may establish for herself in
the future, except to facilitate custody, when the defendant
will pick up and drop off the child, outside of the residence.
B. Schedule a hearing in accordance with the provisions of
the .Protection from Abuse Act,. and, after such hearing, enter an
order to be in effect for a period of one year:
1. Requiring the defendant to refrain from abusing the
plaintiff or placing her in fear of abuse.
2. Requiring that the defendant be restrained from
harassing or stalking the plaintiff, and harassing the
plaintiff's relatives or minor children.
3. Ordering the defendant to stay away from the
res i dence 1 oca ted at 416 Mumper Lane, Di 11 sburg, Pennsyl vani a,
or any other residence the plaintiff may establish for herself
in the future, except to facilitate custody, when the
defendant will pick up and drop off the child, outside of the
residence.
4. Granting support to the plaintiff in the amount of
$220.00 per week, payable by mail.
5. Ordering the defendant to pay all costs of filing and
service of this lawsuit and attorney fees.
The plaintiff further asks that this Petition be filed and
served wi thout payment of COGts, pending a further order at the
hearing, and that a copy of this Petition and Order be delivered to
the Pennsylvania State Police Department and the DIllaburg Police
Department a8 the Pollee Departments with jurisdiction to enforce
this Order.
The plaintiff prays for such other relief as may be just and
proper.
COUNT II
CUltLQD.LUtfD.!;R. f'!;NNSnVANIA CUSTODY LAW
20. The allegations of Count I above are Incorporated herein
as if fully set forth.
21. The best interests and permanent wel faro of the child
will be served by confirming custodY In tho plaintiff aa sot forth
In Paragraph 13 of the Petition.
WHEREFORE, pursuant to 23 P,S. 66301 el lIuq., and other
applicable rules and law, the plaintiff prays this Honorable Court
to award custody of the minor child to her.
The plaintiff prays for such olher rollof a8 may be just and
proper.
Respoctfully sUbmilled,
It. If)
,.-~-I I ~(t-f._'
an Caroy
llorney for Pl~f
LEGAL SERVICES, INC.
a Irvine Row
Carllale, PA 17013
(717) 243-0400
The above-named Plaintiff, CINDY L. WICKARD, verifies that
the statements made in the above Petition are true and correct.
Plaintiff understands that false statements herein are made
subjeot to the penalties of 18 Pa. C.S. 64904. relating to
unsworn falsification to authorities.
Date: _'11 r~J!L'7___
.
_1!~y..d~1AJ K kc.)1f{
CIND~. WICKARD, Plaintiff
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SlmRIFF I S RE'ItJRN
CCM>lClNWEAI1I11 OF PENNSYLVANIA I
COUN'l'Y OF CLMI3ERLAND
In The Court of Common Pleas of
Cumberland County, Pennsylvania
No. 3973 Civil Term 1994
Temporary Protective Order
Protection From Abuse and Custod
Cindy L. Wickard
VS
John C. Wickard
WIlliam Diehl
, SOOtiU>oo<Deputy Sheriff of
Cunberland COWlty, Pennsylv/lllia, who being duly s\\\Jrn according to law, says,
that he served the within Temporary Protective Order Protection From, Abuse
and Custody ,
upon John C. Wickard
, the defendant, at 5: 05
o'clock
P .M. ~ I EDST, on the
20
day of
July
, 19..2!at
l722A Walnut Bottom Road, Carlisle
, C\Jnberl/llld County,
Pennsylvania, by handing to
John C. Wickard
a true and attested copy of the Temporary Protective Order protection Frol11 Abuse
and Custody
and at the sarro time directing his attention to the contents thereof and
the "Notice to Plead" endorsed thereon.
Sheriff's COStSI
Docketing
Service
Affidavit
Surcharge
14.00
2.80
16.80
~~~~~
R. Thanas Kline, Sheriff
Sworn and subscribed to before 100
this olJ ,'4l day of .5~+=-
19-..9L- A.D.
'~hU- 0. }I4I'i., '7 (4-"') ,
Prothonotary
b~ -&:; ~fj~
va.
IN TilE COUIlT OF COMMON PLEAS OF
CUMHEIlLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 94 - 3973 CIVIL TERH
JOliN C. WICKARD,
Defendant
PROTECTION FROM ABUSE
AND cUS'rODY
AND NOW, thiB
ORDER FOR CONTINUANCE
,-
~, day of July, 1994, upon
conaideration of the plaintiff's Hotion for Continuance, the
hearing acheduled for July 22, 1994, at 9:30 a,m. in Courtroom
No.2, ia generally continued to afford the partiea time to
execute a Conaent Agreement. Thia Order ia entered without
prejudice to either party to requeat a hearing.
The Temporary Protective Order will remain in effect for a
period of one year or until ft final Order is entered in this
csse.
A copy of this Order for Continuance will be provided to the
Pennsylvania State Police Department and the Dillsburg Police
Department by the attorneys for the
Edgar B.
.,
JUt zs I 35 PH '9~
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CINDY L, WICKARD,
Plaintiff
IN TilE COURT OF COMMON PLEAS OF
CUMBERI.AND COUNTY, PENNSYINANIA
CIVIL ACTION - LAW
NO. 94 - 3973 CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
vs,
JOliN C, IHCKARD,
Defendant
MOTION FOR CONTINUANCE
The plaintiff moves the Court for an Order continuins the
hearins of this case until further Order of the Court, on the
srounds that:
1. A Temporary Protective Order was issued by this Court on
July lB, 1994, scheduling a hearing for July 22,1994, at 9:30
a.m.
2. The parties request that the hearing be generally
continued to afford them time to execute a Consent Agreement.
3. The parties understand that the Order for Continuance is
entered without prejudice to request a hearing.
4. The plaintiff requests that the Temporary Protective
Order remain In effect pending further Order of Court.
6. A copy of the Order for Continuance will be delivered to
the Mid Cumberland Valley Police Department by attorney for the
plaintiff.
WHEREFORE, the plaintiff moves the Court to grant the
~
plaintiff's Hotion. and to oontinue this matter until further
Order of Court.
Respeotfully submitted,
-I ~,--<
Oarey,
ttorney for Plain ff
LEOAL SERVICES. INC.
a Irvine Row
Oarlisle, PA 17013
(717) 243-9400
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CINDY L. WICKARD.
Plalnlill
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
vs.
CIVIL ACTION - LAW
JOHN C, WICKARD,
Defendant
NO. 94 - 3973 CIVIL TERM
PROTECTION FROM ABUSE AND
CUSTODY
PROTECTIVE ORDER
AND NOW, this ~ day of
August, 1994, upon consideration
of the Consent Agreement of Ihe parties, the following Order Is
entered:
1. The defendant, JOHN C, WICKARD, Is enjoined from
physically abusing the plaintiff, CINDY L, WICKARD, or from
placing her In fear of abuse.
2. The defendant Is enjoined from harassing or stalking the
plaintiff and the plaintiff's relatives or minor children,
3. The defendant Is enjOined from damaging or destroying
any property owned jointly by the parties or owned solely by the
plaintiff.
4. The defendant Is ordered to stay away from the residence
localed at 416 Mumper Lane, DIllsburg, Pennsylvania, or any other
residence the plaintiff may establish for herself In the future,
except 10 facilitate cuslody, when the defendanl will pick up and
drop off the child, outside the residence. The defendant is
hereby nolified Ihat If he resides In Ihe plaintiff's domicile
contrary to this Order, he may be in indirect orlmlnal contempt
which Is punishable by a fine not to exoeed $1,000 and/or by a
sentence of up to six months In jail and any other appropriate
punishment, Consent of the plaintiff to the defendant's
resumption of residence with the plaintiff shall not invalidate
this Order, The defendant shall seek modification (change) of
this Order before resuming residence in the plaintiff's domicile.
The defendant shall seek modification (change) of this Order
before living with the plaintiff in a domicile she may establish
for herself in the future, wherever it may be.
5. The defendant is ordered to pay support to the plaintiff
in the amount of $50.00 per week, payable by mail. until an Order
is entered by the Domestic Relations Office,
6. This Order shall remain in effect for a period of one
year.
7. The Pennsylvania State Police and the Dillsburg Police
Department will be provided with a copy of this Order by
attorneys for plaintiff and may enforce this Order by arrest for
indirect criminal contempt without warrant upon probable cause
that this Order has been violated, whether or not the violation
is committed in the presence of the police officer. In the event
that an arrest is made under this section, the defendant shall
not be taken to jail but shall be taken without unnecessary delay
before the Court that issued the Order. When that Court is
unavailable, the defendant shall be arraigned before a district
justice who shall set bail according to the prOVisions of Chapter
1
;j
i
CUSTODY ORDER
AND NOW, this ~ day of August, 1994, upon consideration
of the parties' Consent Agreement, the following Order is entered
with regard to custody of the parties' child, ERICA M. WICKARD.
1. The plaintiff, hereinafter referred to as the mother,
and the defendant, hereinafter referred to as the father, will
share legal custody of the child.
2. The mother will have primary physical custody of the
child.
3, The father will have partial physical custody of the
child according to the following schedule: every other weekend
from 6:00p.m. on Friday to 6:00p.m. on Sunday and one additional
weeknight every week, to be arranged by mutual agreement of the
parties.
4, The mother and father will alternate the following
holidays: Memorial Day, Labor Day, and the Fourth of July,
5. The mother and father will alternate Christmas Eve and
Christmas Day each year, one parent having the child on Christmas
Eve until Christmas Day at 10:00 a.m. and the other parent having
the child from Christmas Day at 10:00 a.m. until Christmas Day at
8:00 p.m.
6. The mother and father will share the following holidays:
Easter and Thanksgiving.
7. The father will have the right to see the child on her
birthday. at a time to be mutually agreed upon by the mother and
father.
8. The father will have additional periods of partial
custody during the summer, at times to be mutually agreed upon by
the mother and father.
9. The defendant's custody rights are contingent on him
taking all medications prescribed to him, according to the
medications' directions and according to the defendant's
physician.
10. The mother and father, by mutual agreement, may vary
from this schedule at any time, but this Order shall remain in
effect until either party petitions to have it changed.
11. The mother and father will notify the other of all
medical care the child receives while in that parent's care.
Each parent will notify the other immediately of medical
emergencies which arise while the child is in that parent's care.
12. Neither party shall do anything which may estrange the
child from the other parent, or injure the opinion of the
child as to the other parent or which may hamper the free
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destroying any property owned jointly by the parties or owned
solely by the plaintiff.
6. The defendant agrees to pay support to the plaintiff in
the amount of $60.00 per week, payable by mail, until an Order is
entered from the Domestic Relations Office.
6. The defendant, although entering into this Agreement,
does not admit the allegations made in the Petition.
7. The defendant understands that the Protective Order
entered in this matter shall be in effect for a period of one
year.
8. The defendant understands that this Order will be
enforceable in the same manner as the Court's prior Temporary
Protective Order entered in this case.
9. The defendant and the plaintiff agree to the entry of
an Order providing for the following custody schedule for their
child, ERICA M. WICKARD:
a. The plaintiff, hereinafter referred to as the
mother, and the defendant, hereinafter referred to as the
father, will share legal custody of the child.
b. The mother will have primary physical custody of
the child.
c. The father will have partial physical custody of
the child according to the following schedule: every other
weekend from 6:00p.m. on Friday to 6:00p.m, on Sunday and
one additional weeknight every week, to be arranged by
mutual agreement of the parties.
d. The mother and father will alternate the following
holidaye: Memorial Day, Labor Day, and the Fourth of July.
e. The mother and father will alternate Christmas Eve
and Christmas Day each year, one parent having the child on
Christmas Eve until Christmas Day at 10:00 a.m. and the
other parent having the child from ~nristmas Day at 10:00
a.m. until Christmas Day at 8:00 p.m.
e. The mother and father will share the following
holidays: Easter and Thanksgiving.
f. The father will have the right to see the child on
her birthday, at a time to be mutually agreed upon by the
mother and father.
g. The father will have additional periods of partial
custody d~ring the summer, at times to be mutually agreed
upon by the mother and father.
h. The defendant understands that his custody righte
are contingent on him taking all medications prescribed to
him, according to the medications' directions and according
to the defendant's physician.
10. The mother and father, by mutual agreement, may vary
from this scheduls at any time, but the Order shall remain in
effect until either party pstitions to have it changed.
11. The mother and father agree that each will notify the
other of all medical care the child receives while in that
parent's care, Each parent will notify the other immsdiately of
medical emergencies which arise while the child is in that
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