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children one time eaoh week during the father's period of
lummer oustody at a time to be mutually agreed upon between
the parties.
c, For half of the children's Christmas vacation at timss
to be mutually agreed upon between the parties, The father
will have Christmas Eve and Christmas Day in 1995 and in
alternate years thereafter.
d, Alternate holidays inoludingt Easter, Memorial Day,
Fourth of July, Labor Day, and Thanksgiving, In 1994, the
father will have Thanksgiving.
4. The father will be responsible for the transportation of
the ohildren to and from his periods of partial custody. If the
mother's income, inoluding child support received, reaches 187.5\
of the Federal Poverty Guidelines, the mother will be responsible
for one-half of the transportation costs. Each year, the mother
will provide the father with a copy of her income tax return for
inoome verification.
5. The mother and father, by mutual written agreement, may
vary from this schedule at any time,
6. The mother and father will notify each other of all
medical care the children receive while in that parent's care.
Each parent will notify the other immediately of medical
emergencies which arise while the children are in that parent's
care, Th~ father will ensure that Richard takes his presoribed
medication consistent with doctor's orders during his periods of
partial custody.
7. Neither party shall do anything which may estrange the
PAMELLA CRUMLICH/
plaintitt
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
RICHARD CRUMLICH, SR"
DlItendant
NO. 94-
CUSTOl)Y
CIVIL TERM
CONSENT AGREEMENT
....JI\
This Agreement is entered on this [
1994, by the plaintiff, Pamella crumliah, and
day of ,.J1U9U\ -;
the defendant,
Richard Crumlioh, Sr, The plaintiff is represented by Joan Carey
of ~egal Servioes, Ino./ the defendant is represented by Dawn
sunday of sunday and sunday.
Thm defendant, hereinafter referred to as the father, and
the plaintiff, hereinaf.ter referred to as the mother, agree to
the entry of an Order providing for tho following custody
sohedule for their children stephanie Cay crumlich and Richard
Lee Crumlioh, Jr,l
1. The mother and the father will share legal custody of
the children.
2. The mother will have primary physical custody of the
children,
3. The father will have partial physical custody of the
children according to the following schedulel
a, Every other weekend from Friday at 6100 p.m, until
Sunday at 6100 p.m. In the father's absence and with three
days notice to the mother, the paternal gr.andparents or the
paternal aunt may have the children either Saturday or
Sunday from 9100 a.m. until 5100 p.m.
b. For six weeks each summer, with the children to be
returned to the mother no later than throe days before the
start ot the Bohool year. The father will give the mother
two weeks notice as to when his period of summer oustody
will take plaoe. The mother will have the right to oall the
children one time each week during the father's period of
summer oustody at a time to be mutually agreed upon botween
the parties,
c, For half of the children's Christmas vacation at times
to be mutually agreed upon between the parties, The father
will have Christmas Eve and Christmae Day in 1995 and in
alternate years thereafter.
d. Alternate holidays including~ Easter, Memorial Day,
Fourth of July, Labor Day, and Thanksgiving. In 1994, the
father will have Thanksgiving.
4, The father will be responsible for the transportation of
the children to and from his periods of partial oustody. If the
mother's income, inclUding child support received, reaches 187.5\
of the Federal Poverty Guidelines, the mother will be responsible
for one-half of the transportation costs. Each year, the mothe.r
will pr.ovide the father with a copy of her income taK return for
income verification.
5. The mother and father, by mutual written agreement, may
vary from this schedule at any time.
6. The mother and father will notify each other of all
medical care the children receive while in that parent's care,
Each parent will notify the other immediately of medioal
emergencies which arise while the children are in that parent's
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Oertificates of Deposit~ -.__.~___lL_.__
Re.l Estate (including home) ~ __..__tj1.A___
Motor \leh i c Ie: Make ".H9IJ.d1L_.._.___. Year 1888
Cost ._G1..f.t.__.m.____ Amount owed_.__.Jl._
Stocks ~ bonds: . ..______.___.._~L_._.__...___"
othe r: ._._.__...____.__. u____~_~LA__._......____...___
Debts and obligations
Mortgage: ._.__h__.____.._.__.._.__.Q_____.____.
Rent: ._..__.. ______,,_____J.~.l.Q..,_O.Q_..,,_____
--
Loansl___________... ..._..... ......_______....__. ........_.... "_,,
Month I y Expenses: ~roc;;~r j 1iI!1 n()t;..~()Y8nHL.b.y_..f.g..9d_J.t.!lmg!l__
l1!i...o.Q:..g!\El.for Gar $~O, go: In!lYr~nC;:!l f9r. c;;.Ar....J..69..JtQI-._
Tll.llll:lh9nEl $40,00: J;leGl;r1G $(i9,00: TV. C!\I-lJ!LI21..,.OQL.___
gftl} fOf h'ilat/Gqok i n9 $:l9, 90 i68wl;lr/Tf!\ljhl2~,,,OQ.;..Qr.ll.d_U
QAr.dILI/iQ, 90: Watl'lf$,3:l,OO:. MJsG!illlan89\.HLll..QQ",Q1L__
(9) Persons dspendent upon you for support
(Wife) (Husband) Narne:_____... N/A_....____._m_._.____
Chi ldren, if any:
Name :_~.t.Qgban tl'lC ,c;rymJ j .Gh Age :____.J.2"..i'~..!I____
...BJ..QbM.qJ,Q~ ~rLlmJ Lc;:.h_. . ___.__ml)."y"g~r.lL_
4. I understand that I have a continuing obligation to
inform the court of improvement in my financial circumstances
whioh would permit me to pay the costs incurred herein.
6. I verify that ths statements made in this affidavit
srs true and correct. I understand that false statements herein
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She is married.
The father of the ohild is Riohard crumlioh, sr., currently
residing at 201 Lookout Ridge Road, Apartment 31 B, Harber
Heights, Texas,
He is married.
4, The relationship of plaintiff to the ohildren is that of
mother.
The plaintiff ourrently is residing at 127 s. chestnut st.,
Meohaniosburg, Pennsylvania,
5. The relationship of defendant to the children is that of
father,
The defendant currently resides with the following persons I
Name Relationship
Unknown
6, The plaintiff has not participated as a party or
witness, or in another capacity, in other litigation conoerning
the custOdy of the children in this or another court,
7, The plaintiff has no information of a custody prooeeding
oonoerning the children pending in a court of this commonwealth,
8, The plaintiff does not know of a person not a party to
the proceedings who has physical custody of the children or
olaims to have custody or visitation rights with respeot to the
children,
9, The best interest and permanent welfare of the children
will be served by granting the relief requested because the
children have always lived with the plaintiff and she has the
resourcos to continue providing for them,
10, Each parent whose parental rights to the children have
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1, The Molher shall hava primary physical custody of the children,
2, The Mother and Father shall share legal custody of their children,
3, The Father's \llslt9110n and/or partlel physical custody rights to the
children are modified 8S follows;
The Father shall ha\le partial physical clJstody of Ihe children for six
weeks each summer, with the children 10 be returned to the Mother no later than three
dlllYs before the start of the school year, The Falher will gl\le Ihe Mother two weeks
nollce as to when his period of Eummer custody will take place. The Mother will have
the right to call the chlldrel1lhree to four limes per week or more If an emergency arises
during this period. Additionally, Ihe children will be provided unlimited reasonable
telephone access 10 the Molher; the Mother to be responsible for the cost of Ihese calls
by Iha children,
The Father further agrees Ihal during this period of partial physical
custody he will place the children's Interests first. Should the children express a desire
to return to the Mother prior to Ihe conclusion of this six week period of partial physical
custody, Ihe Father wllltako all reasonable steps to accommodate Ihelr wishes and
return them 10 the Molher,
Iff 4. The Mother and Father further agree Ihatthe children's paternal , ffw
'il1{' grandp~fp'nts or the paternal aunt shall be pro\llded wllh Ihe, opport~, ~JIy.ior"~Y'leekend P..{~') l'....rrf ..
c.1J~10(,1./ 'tIIeit wit" the children at least one weekend per month. S~cr. :f~~~~~.. '(Q);$ as the Wt:: It -
Mother and grandparents or aunt shall agree. Addltlonatas may oEl'p rml\\eCl as the
Mother and grandparents or aunt a~ree. Itl~ ynd,r~lQpp{\lll1d agreed that should It be {fe--
Impossible to schedule a weekend'\~~'tor '0 pahlcular m'o'l'1th, e\lery reasonable"eJfC?rt.lJ 01<<1... ph.'"
will be made by the Mother and grandparents or l:luntto schedule _ additional t~ ~or ,.
the fOllowing month,
5, It Is expressly understood and agreed Ihatthls agreement modifies the
terms of the custody order of Augusl1 0, 1994, conlalned In paragraphs 3, a, and 3. b,
It Is further underslood and agreed thatlhe remaining pro\llslons contained In the
custody order of August 1 0, 1994, remain In effect and are reaffirmed by Ihls
agreement.
6. The MOlher and Father, by mutual wrlllen agreement, may \lary from
this schedule at any lime but the order shall remain In effect until ellher parant petlllons
to have It modified or changed.