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Home My WebLink About94-04670 ] ~ 5 11 ~ VJ I ~ I -cJ <f. vi I 7 ! I i J ~ ~j I I I "::j-. 0-1 ,/ ~ ~) \i ~ ..~ .".. en ,- ~ :.:J - " ., 0 r;:, :::c ..' -, 1,;'\ l1 D_ ',' r Q In l) M Q ("1 :r- lJ - -.I .~ r::-..:J " => -,' Z OQ~ ~Zz ~j~ Ol:l:...l Utol;>o< ;"!;l[ll O;:EZ f-o::JZ l:l:Utol ::J;..CI.o 00;;': U[Il'" tol<Z :l::tol::J .....:10 ZCl.oU ... "0 C C 01.. c"O .."0 III "0 01'" "O~C 01 01 ....."0 ~..C .~~ < ..... .....Q c c ...01 ~Z ... \ \n ~l "'(") ... Z Z o tol "'Q~ E:Ztol ...<tol tol l:l: CI.o c.; < 3: - l!l iU~~o~ =~~~N I-U; l;..F:' ~>- clL& LU " .; >-Z~ii~ Wa::;:e~ a:Ol=olJg u. .. - c(an ~ vi e ..... "0... <: c ..s:; ...is: ... ... .. =: . III .. AUG ,~ 1994 'II )n r-- ::t' ,l ..;J. <..J -d j -, ~ 'J '-L I ,I. ',- vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . : CIVIL ACfION - LAW ~ NO. q 1./ - LIID 70 CIVIL TERM : CUSTODY Betty L. Adams, Plaintiff Wayne A. Madden and Nancy Lee Madden, Defendants AND NOW, this 7..'1 day of A ~ 1994, upon consideration of the within Petition and upon Agreement of the parties attached to the within Petition as Exhibit "A", it is ordered and decreed that primary custody be granted to Betty L. Adams, with partial custody to Wayne A. Madden and Nancy Lee Madden, as more specifically set forth in the Agreement of the parties. J. 6!; - "".. ~.... .dr . ~.., l..o I '. " ; , A;~ ~~U"l ~. :::,~. ,. . _. ~ ""fj~ \. ~ l.~ :f.. ,. " 2: 0.- M .... N ...., C'-.l .., :::> o<L '....:-.. ,. Betty L. Adams, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . : CIVIL ACfION - LAW ; NO. qLI_ I./{p 70 CIVIL TERM : CUSTODY vs. Wayne A. Madden and Nancy Lee Madden, Defendant PETITION AND NOW, comes Betty L. Adams, Plaintiff herein, by and through his attorneys, Frey & Tiley, and makes the following statement: I. Plaintiff is Betty L. Adams of 12306 Worchester Avenue, Tampa, Florida. 2. Defendants are Wayne A. Madden and Nancy Lee Madden of 34 1/2 North Hanover Street, Carlisle, Pennsylvania. 3. Defendants are the natural parents of Rebecca Lynn Madden, born May 19, 1980, currently residing at 34 1/2 North Hanover Street, Carlisle, Pennsylvania. Plaintiff is the maternal aunt of said child. 4. Plaintiff and Defendants have entered into an agreement concerning the custody and visitation of the aforesaid child, which agreement is attached hereto as Exhibit "A". 5. Plaintiffs and Defendants now desire to have this agreement entered as an Order of Court as it is believed that the terms of the agreement will best serve the interests of the aforesaid child. WHEREFORE, Plaintiff respectfully requests that the Court grant shared legal custody to the parties herein and primary physical custody to Plaintiff with visitation to Defendant as agreed to by the parties in Exhibit" A". Respectfully submitted, Frey & Tiley ,-- --1. ' by: Robert G. Frey ..-"'....- We verify that the statements made herein I\fC true and correct and undcrstand that fulse statements herein I\fC made subjcctto the penal tics of 18 Pa. C. S. A. A 4904 relating to unsworn fulsification to authorities. Thc undersigned Waync A. Madden and Nancy Lee Madden further verify that they have joincd in thc signing thc within Pctition to confinn thcir desire that the Custody Agreement executcd by them be entcred us an Order of Court. Dated: August 18. 1994 ~~% OdAAN-<1./ Belly L. r v w0JfIM~p~kJ- nO/VJ04 dn madd~l /"0- ~cy Lee ~adden " CUSTODY AGREEMENT (-1- ENTERED INTO this I g day of August. 1994 BETWEEN, Wayne A. Madden and Nancy Lee Madden, of 34 1/2 North Hunover Street. Carlisle. Pennsylvunia. hereinafter referred to us "Parents", AND Belly L. Adams. of 12306 Worchester Avenue, Tampa. Florida, hereinafter referred to us "Aunt", WHEREAS, Parents are the parents of Rebecca Lynn Madden, born May 19. 1980. a minor. hereinafter referred to us "the child"; WHEREAS, Parents und Aunt are no longer living together; WHEREAS, Parents und Aunt acknowledge that arrungements have been now been made for the child to live with Aunt. which arrungement is a chunge from prior custody; WHEREAS, Parents and Aunt acknowledge that the child has stated a desire that she live with Aunt; WHEREAS, it is the hope that a time with Aunt may help the child overcome some difficulties which she hus recently had; WHEREAS, Parents and Aunt believe that the best interests of the child is served by the present custodial arrangement; WHEREAS, Parents and Aunt believe that it is in the best interests of their child to reach un agreement us to the relative custody, partial custody. and visitation of their child; WHEREAS, Parents und Aunt desire to have said agreement entered as un Order of Court having jurisdiction over the child NOW THEREFORE, in consideration of the mutual covenants, promises. und agreements as hereinafter set forth, the parties agree as follows: I . Aunt und Parents shall have joint legal custody of the child. 2. Aunt shall have primary physical custody of the child. 3. Parents shall have reasonable and generous periods of partial or temporary custody with the child. which periods shall be as agreed by the parties from time to time. 4. Aunt and Parents agree that the exchange of the child in all cases shall occur at a mutually agreeable location. S. Aunt und Parents agree that they will work to the best interests of child. 6. Aunt and Parents agree that they will each notify the other immediately in cases of medical emergencies that occur while the child is in their custody. . 7. Any modification or waiver of any of the provisions of this Agreement shall be effective only if mode in writing executed with the same formulity us this Agreement. 8. Neither purent shall do anything which may estrange the child from the other or injure the opinion of the child as to the other. or which may hamper the free and naturul development of the child's love or affection for the other. 9. Aunt and Parents each agree that in making this Agreement. there has been no froud. concealment, overreaching, coercion, or other unfair deuling on the purl of the other. 10. It is understood by Aunt and Parents that this Agreement shall be submitted for incorporation into an Order of Court and may be modified by the Court of Common Pleas of Cumberland County or any other Court having proper jurisdiction based on the laws in effect in the jurisdiction. INTENDING to be legally bound, witness our hand and seal the day and yeur first above written. kl.~~A.-/l'SEAL) Wayne A 0 en () n /1/1 (]-~ ,ll (I') (,deL I (~L) Nancy Lee M(l den ~ ~f1LX /V~UJ./ (SEAL) etty \6.dams '~d,'''':