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SCOTT B, WINTERS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94- '-I~~'1 CIVIL TERM
v.
MICHELLE R. PIERCE,
Defendant
IN CUSTODY
,I ORDER OF COURT
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AND NOW, this (7 day of jJtA t l S J ,1994, the attached Stipulation and
Agreement is hereby made an Order of Court and all prior orders on this matter are hereby
vacated,
BY THE COURT,
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SCOTI B, WINTERS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
94- ,+(0(,'1 CIVIL TERM
MICHELLE R. PIERCE,
Defendant
IN CUSTODY
CUSTODY STIPULATION AND AGREEMENT
THIS AGREEMENT AND STIPULATION entered into the day and year
hereinafter set forth by and between Scott B, Winters, (hereinafter referred to as "Father")
and Michele R. Pherribo, (hereinafter referred to as "Mother");
WHEREAS, the parties are the natural parents of Christopher S. Winters, born
January 15, 1989, (hereinafter referred to as "child"); and
WHEREAS, the parties are presently divorced; and
WHEREAS, the parties wish to enter into an agreement relative to the custody and
guardianship of the child; and
NOW, THEREFORE, in consideration of the mutual covenants promises and
agreements as hereinafter set forth, the parties agree as follows:
1. The parties will share legal custody of the child with the child's grandmother,
Jean Saa Saa,
2, The grandmother, Jean Saa Saa will have primary physical custody of the
child,
3, The parties will have temporary physical custody of the child at such times as
the parties agree between themselves and Jean Saa Saa,
4. The parties agree that Jean Saa Saa is authorized to make decisions regarding
necessary medical treatment and decisions involving the child's education,
I,
.
5, The parties and Jean Saa Saa desire that this Stipulation and Agreement be
made an Order of Court to the Court of Common Pleas of Cumberland County, and further
acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have
jurisdiction over the issue of custody of the parties' minor child, and shall retain such
jurisdiction should the circumstances change and either party desire or require modification
of said Order,
6, The parties agree that in making this Agreement, there has been no fraud,
concealment, overreaching, coercion, or other unfair dealing on the party of the other,
7. The parties acknowledge that they have read and understood the provisions
of this Agreement. Each party acknowledges that the Agreement is fair and equitable and
that it is not the result of any duress or undue influence,
IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the
terms hereof, set forth their hands and seals the day and year written below,
Y~~~C0~ f~
...... scon 8, WINTERS
DATE: O~ /3/9t.j
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DATE: D~/ q / q4-
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MiCHELLE R. PIERCE
The child's grandmother. Jean Saa Saa. joins in this agreement and accepts its terms,
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JEAN SAA SM
DATE: Df? /!J /9 1
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STATE OF Pennsylvania
COUNTV OF Cumberland
I 55.
AND NOW, this31:#day Of~~ ,1994, before me, the undersigned
officer, personally appeared Scott B, Winters, known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within instrument, and acknowledged that he
executed same for the purposes therein contained,
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Not:r..lI Si\\1
~11 F. Uf"( ,'r, N:-:lry Puhf.c
C"r,L~:'.. [k'l(J. e~.:r.:"l:'l, '~'...f c.;"...r-:'1 ...
M.,.C.';nJr;:~';:d:" .,,/.,' .,L..X,
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STATE OF Pennsylvania
55.
COUNlY OF Cumberland
AND NOW, this 9.t:'aay of ~'-'<)<. , 1994, before me, the undersigned
officer, personally appeared Michelle R, Pierce, known to me (or satisfactorily proven) to
be the person whose name is subscribed to the within instrument, and acknowledged that
she executed same for the purposes therein contained,
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Nvt't.ia!St-al
Anoola F. Urlf),~r. f :.:~11V F\1ic
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M/C.~~:jllr..::>:, ::. -'-.' (.'-,~ . r..Y.)
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