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Eve at noon until christmas Day at noon, and the other parent
havinq the ohild from christmas Day at noon until December 26th
at noon. In evsn-numbered years, the father will have the period
beginning christmas Day.
5. The parties will sharo Thanksgiving, one parent having
the child from B:OO a.m. to 2:00 p.m., and the other having the
child from 2:00 p.m. to B:OO p.m. In even-numbered years, the
father will have the child from 2:00 p.m. to 8:00 p.m.
6. The parties will alternate the following holidays from
9:00 a.m. to 6:00 p.m.: New Year's Day, Easter, Memorial Day,
the Fourth of July, and Labor Day. The father will have the
child on the Fourth of July in 1994. If the father's scheduled
holiday falls on a Monday following his weekend, he may keep the
child Sunday evening and return her at 6:00 p.m. on Monday.
7. The father will have the right to partial custody of the
child for two nonconsecutive weeks during the year, not to
include the whole week after Christmas. The father will give the
mother thirty days written notice as to when his periods of week
long custody will take plac~. If the father is not off from work
during these week long custody periods, the child will be cared
for by either the maternal or paternal grandparents. The mother
will have the right to a two week vacation with the child to
include three weekends. The father will have the child for the
two weekends following the mother's vacation. The mother will
give the father thirty days written notice as to her vacation
period.
8. The father will have the child on Father's Day from 9100
a.m. to 6100 p.m. The mother will have the child on Mother's Pay
from 9100 a.m. to 6100 p.m.
9. Holidays and Father'a Pay/Mother's Pay will supersede
the regular weekend schedule.
10. The mother and father, by mutual agreement, may vary
from this schedule at any time. Both parties agree to cooperate
in altering this schedule for unforeseen circumstances or speoial
events. Neither party will unreasona~ly withhold consent for
reasonable requests to alter this arrangement.
11. The father will provide transportation for those
periods in which he exercises his rights of partial custody. The
mothor and father agree that the child will always be safety
belted during periods in which she is in their custody.
12. The mother and father will notify each other of all
medical visits the child receives while in that parent's care
within 24 hours, whether those visits are check-ups or for
illness.
Each parent will keep the other notified of the
child's treating physicians, and will notify the other
immediately of medical emergencies which arise while the child is
in that parent's care.
13. Neither party will do anything which may estrange the
child from the other parent, or
of the child
as to the other parent, or
development of the child'S
which meW hampe
love o{ respec,
By t~o
nd natural
parent.
/
v-//
J.
MELISSA L. NAILOR,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 94-
CIVIL TERM
RODGER A. BRICS,
Defendant
cUs'rODY
CONSENT AGREEMENT
This Agreement is entered on this -i!!-I day of .i/~JJ).J
1994, by the plaintiff, Melissa L. Nailor, and the defendant,
Rodger A. Brice. The plaintiff is represented by Joan carey of
Legal Services, Inc., the defendant is represented by Jacqueline
C. Barnett of Pomper and Barnett.
1. The defendant, hereinafter referred to as the father,
and the plaintiff, hereinafter referred to as the mother, agree
to the entry of an Order providing for the following custody
schedule for their child:
a. The mother and father will share legal custody of
the child. They will discuss and agree upon major
issues involving the child including, but not limited
to, medical treatment, education, and religious
upbringing. This Agreement will act as a consent by
both parents to release information to either parent
from all medical, educational, and religious
individuals who possess any information or records
pertaining to the child.
b. The mother will have primary physical custody of
the child.
o. The father will have partial physical custody of
'j' '
the ohi1d every other weekend commencing July 1, 1994,
tram Friday at 6tOO p.m. to Sunday at 6100 p.m. If the
father is oalled into work on sunday, he will inform
the mother and leave the child in the care of either
the maternal or paternal grandparents.
d. The father and moth$r will alternate Ch~istmas Eve
and Christmas Day each year, one parent having the
child on Christmas Eve at noon until ehristmas Day at
noon, and the other parent having the child from
Christmas Day at noon until December 26th at noon. In
even-numbered years, the father will have the period
beginning Christmas Day.
o. The parties will share Thanksgiving, one parent
having the child from 8:00 a.m. to 2:00 p.m., and the
other having the child from 2:00 p.m. to 8:00 p.m. In
even-numbered years, the father will have the ohild
from 2:00 p.m. to 8:00 p.m.
f. The parties will alternate the following holidays
from 9100 a.m. to 6:00 p.m.: New Year's Day, Easter,
Memorial Day, the Fourth of July, and Labor Day. The
father will have the child on the Fourth of July in
1994. If the father's scheduled holiday falls on a
Monday following his weekend, he may keep the child
Sunday evening and return her at 6:00 p.m. on Monday.
g. The father will have the right to partial custody
of the child for two nonconsecutive weeks during the
,"
ysar, not to include the whole wee~ after christmas.
The father will give the mother thirty days written
notioe ae to when his periods of weo~ long oustody will
ta~. place. If the father is not off from wor~ during
these wee~ long custody periods, the child will be
oared for by either the maternal or paternal
grandparents. The mother wi,ll heve the right to a two
week vaoation with the child to include three weekends.
The father will have the child for the two weekends
following the mother's vacation. The mother will give
the father thirty days written notice as to her
vacation period.
h. The father will have the child on Father's Day from
9tOO a.m. to 6tOO p.m. The mother will have the ohild
on Mother's Day from 9:00 a.m. to 6:00 p.m.
i. Holidays and Father's Day/Mother'S Day will
supersede the regular weekend schedule.
2. The mother and father, by mutual agreement, may VAry
from this schedule at any time. Both parties agree to cooperate
in altering this schedule for unforeseen circumstances or special
events. Neither party will unreasonably withhold consent for
reasonable requests to alter this arrangement.
3. The father will pr.ovide transportation for those periods
in which he exercises his rights of partial custody. The mother
and father agree that the child will always be safety belted
during periods in which she is in their custody.
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Stocks: bonds:
Other:
(f) Debts and obligations
Mortgage: . __._Jjf}.___u_______
Rent: $46, 99/!$.Yl1!tldJzv.Qu _u___.__
Loans: Automob11. I~O,OO
Month 1 y Expenses: Gro<;er I et;! not <;oYen~~L.bY JQ_Q.d.u~.t.DlllRL_.
U.Q. QQjTl11llPhone $26.00 i E llill<tr I <; $137,00 ....IY.uC.oDJ.JL_....__
.1_24.,00: G"5 for car $60.00 i lneurl;lnc::lt uf9rG.!\Lul_49JQO..._
RvYolYlng Charglil paym~nt $20.00: C;:19thJn91~Q.9Q.;____.u_
M.1 Qce llanflOLHl househo lcj e)<PElmlet;! $40,00. _ .. . .___
(g) Persona dependent upon you for support
(W i fe) (Husband) Name: .......______
Children, !fany:
Name: A'ilhleY 6rl<;e Age: _._....___~_ Years_
4. I understand that I have a continuing obl igation to
inform the court of improvement in my financial circumstances
which would permit me to pay the costa incurred herein.
6. I verify that the statements made in this affidavit
are true and correct, I understand that false statements herein
Oheck i ng Account: ... _ ..l4.9_10'Ou__..______ ...___._
SaYings Aocount: .. O.OQ_.....____.. ____
Oertlficates of Deposit: _ _m.tUA______ . _____
Real Elltate ( including home): .._ NI!I__._________.___.____
Motor vlllh i c 1 e: Make N I !IIIr:1l1 Year. Jj.ll~ __.. ___
G08 t $2700,00 Amount owed_J2.~\1.o...Jl{L
NI A. __ _...__ _______~
. .N/A_ __._______
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The tather of the ohi1d is Rodger A. Brioe, currently
re.iding at B06 Baltimore Road, Dillsbur9, PennsYlvania.
He is single.
4. The relationship of plaintiff to the ohild is that of
mother.
The plaintiff currently resides with her daughter Ashley N.
Brioe.
5. The relationship of defendant to the child is that of
father.
The defendant currently resides with the following persons I
Name
Diane Crawford
Relationship
Girlfriend
6. The plaintiff has not participated as a party or
witness, or in another capacity, in other litigation concerning
the custody of the child in this or another court.
7. The plaintiff has no information of a custody proceeding
conoerning the child pending in a court of this eommonwealth.
B. 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.
9. The best interest and permanent welfare of the child
will be served by granting the relief requ~sted because the
mother has always been the primary caretaker of the child and she
would like to continue in that role.
10. Each parent whose parental rights to the child have not
been terminated and the person who has physical custody of the
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