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HomeMy WebLinkAbout94-04600 ~ !, -0 - J '. J I, 3 . ., ,., ~ " J Ii " ) ,/ , I ,! J J " ,! o <: .._~!!.-~_.!! _"!_-i . ~,~ :l! _~, ~. :*.:, ole':*' 'le ,*' ,*, '. :*')<'~~-~:~.:I!' _~_'!t_.!!!.<~~ t . . . . . . . . . . . . . , . * . - . , ~ ~ . . ~ . . . . , . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF .. PENNSYLVANIA DALB I., DAVIDSON, II N o. '~':'".riQQ ,..~J,Y.Uf 1994 'I I , l'lnJ.nt:it t' Vl'l'tHlli JUDI'l'll B. DAVIDSON, DIlt'endant DECREE IN AND NOW,~.. .('. ~.~. ~ 1:'~~ !.!d~ a~ J1 decreed that""""""." ,11l1l,l': ,J"" JlIWmSON"""""".,. plaintiff, and, , , , , , , , . , , , , ' , , , , ,J,UOn')I, I':., ,PlIV.I.11S0tl. , , , , , , , , , , , , , , , " defendant, are divorced from the bonda of matrimony. The court retalna jurladlctlon of the following claims which have been raised of record In thla action for which a final order has not yet been entered; NON": .. ,.".. ,...., 0""""""" ,. ."",."., ...,..,.. "..,. ...,.., '" ,.". ", ".." ,..".", ,.... .....", I""'" .,1 , , . /,'-~~, 'f';'''~t t' I<...L-(;tf:~ ;t.~,7t/-7/e.t; J. '. . c/ ' :; '/../,;1"" Ie", ~'S.()Ir'. . ./ A_Y."'J Prothonotary . . . . . . . . . . . . . . f . . . . * ~ . ij . e ~ . ~ . * * ~ $ ~ ~ ~ ~ .... .. ...-..--.-:s;'...- ~ ..' ..' .*. ::..;".,'.i::;":,'.i:: ..'.>>::1iC,.l.;: -..;,,;.- :.:-;J , , ~ \. ) ". , , ./ . 'J .~ \ ~ I , ~ \"r l i \\., "',l ..... . , "~\~ \ \ D , .} \. ~ ,', "'j " " a; . ,.J ., , ,J \, .. '. .. I~ , OJ' I,/l I, I.) : I ~ 1 ,. ~ . ~~ ~ j ~~ ~~ @l t ~ J ~P< tl .... l-J ~ ~~~~~ E-< .... . ~ ,::) ~..: I': "i o . P: .... . :z: III ,-...'r.~~.. U>< ,-1 0 .l-J P 0'1J :z: <( '" <.: I;l ~~ H ~ :z: ~ VI I:: H w.: 'r., . _ ...:. I :> 0 0'''' ,::) V ~ ' I:i ;oj <,,; ., t: I H l/l11l S] t: , I; I" ~ t 0 u Z ,::).-i I;l ~ ~ 9. c " E-<U HP< f g~ H ~ ,::) ~ ~l:wJ~:::~ .,;!\ ~... ,::) . ~ :JCo $ I U~ W I . 0 CC 'r. ~~ ... ...:t ~ U <( , '" ~ W ~ ~p, . ~ ~ a , . M \It~. \\111".- \'\t1I.lllhl..", \, 11I1l'''' \" \1 1\\\ Ill.',,,, h....,~""tllll '111I'1"....,111111,1'1"...' 11!~7 11111'11""" 11IH~H.;,lIUI ." 11171~U.f.~."Il . ' VB. I IN THE COURT OF COMMON PLEAS OF I OUMBERLAND COUNTY, PENNSYLVANIA I I CIVIL ACTION ~ LAW I I 94~4600 CIVIL TERM I IN DIVORCE DALE L. DAVIDSON, PlIIinti tf JUDITH E. DAVIDSON, Defendant ~rID1YIT or OOHSIBT 1. A Complaint in Divorce under seotion 3301(0) of the Divorce Code wu filed on August 16, 1994. 2. The marriage of Plaintiff and Defendant is irretrievebly broken and ninety (90) days have elapsed from the date of the tiling of the Complaint. ~. I consent to the entry of a final Decree of Divoroe. 4. I have been advised of the availability of marriage ooun..ling, that I may request that the Court require that my spouse and I participate in oounseling, and that the Court maintains a 1.lst of marriage counselors in the Prothonotary's Offioe, which list is available to me upon request. Bei.ng so advised, I deoline to request that the Court require that my spouse and I partioipate in counseling. 5. I underotand that I may lose rights concerning alimony. division of property, lawyers' fees or expenses if I do not claim them before a divorce is granted. I VERIFY THAT THE STATEHENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa. C. S. 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: I //c~ IY.}- . (' . ,{' ,0~t ~,,.Iik~ UDITH E. DAVIDSON Defendant 1/' "' ~ I, , " ~ t'.1 -I} I ( J {; .. , - - i , , ri l ..-t== ~~~~~ I .-...-- ~~ ~ j ~ ~ . +i ~ >- Il ~ ~ ~ .... J:: lJllll ~ ~ ~ ~ I : ffi ~ .... . 111 . 0 'Il . - f: I 'M ~] ~U a~ ~~E +.l o Po E-< >: Hr.- . ! t;; ~ ~" r ~ . ,-1 . '>-I lJl.... ~~ Cl :t. q: ~ ZI1l ~~ ~~""l~~ o ~ H OM . I u ~ ~ lJlp. p ~S ~;!\ ..: iii - r.- u 0 0 00 H Poo III ~ . H < ~i 0 w 1'-1 1:; :of. 0 u 0 III ,:t: . ~ ..: or 0 H I ~ H or iJ.l ~ ~W '" 0 g III 0 . e1 0 Z H -..-.- "" , I (~ ~~ ~I i ~ 8 ~ ~~ .... .... .. "" '0 -t ~~ 0( ~ t. ~ ~ ~ ~ ':) ,.r3 .J It () ~ - ~~I I~ ' ~ " ' . ~~ 6 ... . " In Il ~ ~~ . . Bt:; ~ 1 11. g' ~ u . . n ~ I./l " 1 w ~ ~ :J 23 . % 1 ~ .. m ~ o I ~ ~iT ~ tJl I. .J ~ w ~ Z ,1 ~ ~ ~ ~tii ~ ~ E .( ll..1 7 , ffi 8 ' . . I N Ij , ' , ' , . .. v. IN THE COURT OF COMMON PLEAS or CUMB~RLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 94-4600 CIVIL TERM IN CUSTODY DALE L. DAVIDSON, Plaintiff JUDITH E. DAVIDSON, Defendant CUS'fODY STIPULATION AND AGREEMENT THIS AGREEMENT AND STIPULATION entered into the day and year hereinafter set forth, by and between Judith E. Davidson, (hereinafter referred to as "Hother") and Dale L. Davidson, (hereinafter referred to as "Father"). WHEREAS, the parties are the natural parents of Lauren Marie Davidson, born December 22, 1983, and Jaolyn Renee Davidson, born Maroh 10, 1987 (hereinafter the "children")' and WHEREAS, the parties are presently separated and livinq in s.parete residences, and WHEREAS, the parties wish to enter into an agreement relative to custody and partial custody of the ohildren, and NOW, THEREFORE, in oonsideration of the mutual covenant., promises and aqreements as hereinaftet' set forth, the parties agree as followSI 1. The parties shall have shared legal custody of the ohildren. 2. Mother shall have primary physioal oustody of the ohildren. /I/,J :J. Father shall have temporary or partial phya10al oustody ot the ohildren on the following sohedulel (a) Every other weekend from Friday afternoon or evening until the following Monday morning when the Father shall deliver the ohildren to school, (b) During the week following the weekend period of temporary oustody desoribed in (1I) above, Father shall have the ohildren on Tuesday evenin9 and Thursday evening from the 01088 of school or the end of Father's workday until approximatelY 714~ p.m., and (0) During the week prior to the weekend period of temporary oustody described in (a) above, Father shall have the children on Monday evening and Wodnesday evening from the olose of school or the end of Father's workday until approximately 714~ p.m. 4. The parties a9ree to alternate periods of temporary oustody with the ohildren on the following holidays 1 New YoIlar's Day, Presidents' Day, MElmorial Day, 4th of July and Labor Day, with Mother having the ohildren on New Year's Day, 1995. When a parent has the children for a designated holiday, they shall have the children from 9100 a.m. until 7115 p.m. on that day, with the exoeption of the 4th of July, when the parent having that holiday shall be entitled to keep the child overnight and abide by the routine sohedule described IIbove beginning with the mornin9 of July 5 of eech year. 5. The paJ:'tie. each shall be entitled to two week. of vaoation eaoh year by giving thl other parent 30 day. notice of their intention to exercise these periods of physioal cu.tody. 6. During the chrLstmae holiday seaeon, the partie. will altel.'nate physical custody ot the children during the following two periods of time, with Mother having the first period designated herein for Christmas, 1994r (a) From 5100 p.m. on the last day of school prior to Christmas until 1100 p.m. on Christmas day, and (b) From 1100 p.m. on Christmas day until 7130 p.m. on December 31 of each yoar at 7r30 p. m. 7. The parties will alternate the period of phyl10al custody of the children over the Thanksgiving holiday by alternating the following two periods of time, with Mother having the first period designllted herein for Thanksgiving, 19941 (a) From 5100 p.m. on the Wednesday before Thanksgiving until 1100 p.m. on Thanksgiving day, and (b) The period from 1100 p.m. on Thanksgiving day until 7130 p.m. on the Friday following Thanksgiving. 8. The parties will alternate the period of physical custody of the children over the Easter holiday by alternating the fOllowing two periods of time, with Father having the first period designated herein for Easter, 1995. (a) From 5100 p.m. on the Friday before Eauter until 7130 p.m. on the Saturday before Easterl and (b) From 7130 p.m. on the Saturday before Easter until 7130 p.m. on Easter day. II! ~ 9. The p~rti.. a9ree that they share trftn.portution of the children. In the event the part.Les oannot otherwile make arrangellllnt. relative to transportation, Mother will piok u'jl the ohildren when it i. time for her to seoure or return phy.ioal custody to her and Fathllr will piok up the ohildren when it iI tillle to sscure phye10al oustody of the children. Father shall be re.pondble, whir.. relevant, to return the ohildren to sohool when it is a school dey and he has had the ohildren for an overnight period of temporary custody. 10. Then shall be additional and/or alternate periods of partial physical custody or visitation as the parties may mutually agree for Father to be with the children upon Father providing Mother with at least 24 hours advance notioe. 11. The pllrties agree that Mother shall retain the child, Jaclyn Renee Davidson, as an incoma tax dependent for all Federal Income Tax Returns from this time forward unless otherwise agreed upon by the parties. 12. The parties agree that Father shall retain the ohild, Lauren Marie Davidson, as an income tax dependent for all Federal Inoome Tax Returns from this time forward unless otherwise agreed upon by the parties. 13. The parties will keep each other advised immediately in the event of serious illness or medical emergency concerning the ohildren and shall further take any necessary steps to ensure that the health end well being of the ohildren i8 proteoted. During .uoh Lllne.. or medicel Gmergenoy, both part i.. shall have the right to vidt the children as otten as he or she dedr.. consi.tent with the proper medical care of the children. 14. Neither parent shall do anything whioh may estrange the ohildren from the other party, or injure the opinion of the ohildren as to the other party, or which may hamper the free and natural development of the children's love or afflllotion for the other party. 115. Any modification or waiver of any of the provilion. of thil Agreement shall be effective only if made in writinq and only if executed with the same formality as this stipulation and Agreement. 16. Tho parties desire that this StipUlation and Agreement be made an Order of Court to the Court of Common Pleas of Cumberland county, and further IIcknowledge that the Court of common Pleas of Cumberland county does, in faot, have jurisdiction over the issue of oustody of the parties' minor child and shall retain such jurisdiction should ciroumstances ohange and either party desire or require modification of said Order. 17. The parties agree that in making this Agreement, there has been no fraud, concealment, overreaching, coeroion, or other unfair dealing on the part of the other.