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LAW OFFICES
ll.tlWI./)S,IRWISIII
OCT
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1/ V
1994
.'
v,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY. PENNSYLVANIA
: CIVIL ACTION . LAW
,
: NO. 'N'!'f /" '7~ 6.....J -r ~
: IN CUSTODY
TIMOTHY A. H. SWEENEY,
P1alntltT
TINA M, SOMMER,
Defendant
ORDER OF COURT
NOW, this c( ~ of October, 1994, upon presentation and consideration of the
attached stipulation and agreement and upon agreement of the parties, it is hereby ordered and
decreed that the attached agreement is made an Order of Court.
BY THE COURT,
J,
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TIMOTHY A. H. SWEENEY,
PlaintilT
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION . LAW
TINA M. SOMMER,
Defendant
: NO.
: IN CUSTODY
STIPULATION AND AGREEMENT
THIS STIPULATION AND AGREEMENT entered into this ;5'" day of 0<.1000,
1994, by and between TIMOTHY A. H. SWEENEY (hereinafter referred to as "Father") and
TINA M. SOMMER (hereinafter referred to as "Mother"),
NOW THIS AGREEMENT WITNESSETH THAT:
WHEREAS, the parties are the natural pw-ents of the minor child, Timothy A. H.
Sweeney, Jr., bom June 18, 1987; and
WHEREAS, the parties wish to enter into an agreement relative to the custody and
partial custody of the child.
NOW, THEREFORE, in con,ideration of the mutual covenants, promises and
agreements as hereinafter set forth and intending to be legally bound, the panies hereto agree as
follows:
I. The parties shall have joint legal custody of the child,
2. Father shall have primary physic!li custody of the child, subject to the Mother's liberal
rights of partial physical custody and visitation as the parties may mutually agree.
3. The parties will keep each other advised immediately relative to any emergencies
concerning the child while he is in their custody l\I1d shall take any necessary steps to ensure that
the health, welfare and well being of the child is protected,
4. The parties shall do nothing that may estrange the child from each other or hinder the
natural development of the child's love or affection for the other party,
5. Any modification or waiver of any of the provisions of this agreement shall be effective
only if made in writing and only if executed with the same formality of this agreement.
6. The parties agree that in making this agreement there has been no fraud, concealment,
overreaching, coercion or other unfair dealing on the part of the other.
7. The parties desire that this agreement be made an order of Court through the Court of
Common Pleas of Cumberland County and further acknowledge that the Court of Common Pleas
of Cumberland County has jurisdiction over the issue of custody of the child and shall retaitt such
jurisdiction should circumstances chl\l1ge and either party desire further or require further
modification of said Order.
IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the tenus
hereof, set forth their hands and seals the day and year herein set forth.
WITNESSETH:
-:t....,)/ III! s:.C<""'~ s;{
TIMOTHY A. H. SWE NEY
(SEAL)
Date: Ii). ~ '1'1
/-'",.
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Date:/,:? 3 '1'1 .--::::' J(d,YIi .5>}{nL~.t '
t TINA M. SOMMER
(SEAL)
COMMONWEALTH OF PENNSYLVANIA
:ss:
COUNTY OF CUMBERLAND
~,,"-
On this, the2-day of October, 1994, before me, the undersigned officer, personalty
appeared Timothy A, H. Sweeney and Tina M. Sommer, known to me or satisfactorily proven)
to be the persons whose names are subscribed to the within instrument and acknowledged that
they executed same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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_ /11)..-1 L)(--/ ./
Notary Public
(SEAL)
NOlana! Seal
Harold S, Irwin III, Notary Publlo
Ca"I.Iolloro, Cumberlanil County
My Commls.lon expires SePf. 14. t 998
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LAW OFFICES
1/..1 R () ID S. I R IVIN. III
{lEe : 7 lq~iL.--
TIMOTHY A. H. SWUNEY.
Plaintlrr
I IN THE COURT OF COMMON PLEAS or
I CUMBERLAND COUNTY. PENNSYLVANIA
v.
: CIVIL ACfION - LAW
TINA M. SOMMER,
Defendant
: NO. 94. S696 CIVIL TERM
: IN CUSTODY
ORDER OF COURT
,f,-- .
NOW, this R day of ;:J.!!,Ajl'l iN.) . 1994, upon presentation and consideration
of the attached stipulation and agreement and upon agreement of the parties, it is hereby ordered
and decreed that the attached agreement is made an Order of Court,
.'
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TIMOTHY A. H. SWEENEY,
PlalntllT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: CIVIL ACTION. LAW
TINA M, SOMMER,
Defendant
: NO. 94. S696 CIVIL TERM
: IN CUSTODY
STIPULATION AND AGREEMENT
mls STIPULATION AND AGREEMENT entered into this_day of December.
1994, by and between TIMOTHY A. H. SWEENEY (hereinafter referred to as "Father") and
TINA M. SOMMER (hereinafter referred to as "Mother").
NOW THIS AGREEMENT WITNESSETH TIIA T:
WHEREAS, the parties are the natural parents of the minor child, Timothy A R
Sweeney, Jr., born June 18, 1987; and
WHEREAS, on October 3, 1994, the parties entered into an agreement for the custody
and partial custody of the child, which agreement was confirmed by Order of Court dated October
4, 1994, and a copy of which is attached hereto as Exhibit "A"; and
WHEREAS, the parties wish to modifY their previous agreement relative to the custody
and partial custody of the child.
NOW, THEREFORE, in consideration of the mutual covenants, promises and
agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as
follows:
I. The parties shall have joint legal custody of the child.
2. Mother shall have primary physical custody of the child, subject to the Father's
liberal rights of partial physical custody and visitation as the parties may mutually agree.
3. Father understands and agrees that Mother resides in Nebraska and has no
objection to Mother taking the child to reside with her in Nebraska, Both parties agree that they
will keep each other advised of their current address and phone number so that both parties may
be reached in the event of an emergency with the child and so that both parties may have contact
with the child by telephone or otherwise while the child is in their custody,
4. 1I1e parties will keep each other advised immediately relative to any emergencies
concerning the child while he is in their custody and shall take any necessary steps to ensure that
the health, welfare and well being of the child is protected.
5. The parties shall do nothing that may estrange the child from each other or hinder
the natural development of the child's love or affection for the other party.
6. Any modification or waiver of any of the provisions of this agreement sha11 be
effective only if made in writing and only if executed with the same formality of this agreement.
7. The parties agree that in making this agreement there has been no fraud, concealment,
overreaching, coercion or other unfair dealing on the part of the other.
8. The parties desire that this agreement be made an order of Court through the Court of
Common Pleas of Cumberland County.
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 herein set forth,
WITNESSETH:
. .) ---- j?A y/ " sP
Date: k...2-,-'II( ~Y'1r' ,-8 ,~,-!Q),i?, I'.....
TIMOTHY A. H. SWEEN Y
(SBAL)
Date: /'}.)..)-'?'1 ~ l' ~ /'1 S;;fn( m-LlL
I TINA M. SOMMER
(SEAL)
COMMONWEALTH OF PENNSYL VANIA
:8S:
COUNTY OF CUMBERLAND
On this, the 171'day of December, 1994, before me, the undersigned officer, personally
appeared Timotby A, H. Sweeney and Tina M, Sommer, known to me or satisfactorily
to be the persons whose names are subscribed to the within instrument and
they executed same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
a1
Notary Public
(SBAL)
alSeal
Harold S. Irwin III, NOIIIIy Public
Carllll. ""ro, Cumberlend Counly
My COmmission Expire. Sept 14. 1998
, MIrrCIooI", ......... AuodoIIon 01 Nola1eo
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TIMOTHY A. H. SWEENEY,
Plain tilT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
TINA M. SOMMER,
Defendant
,
,
: NO. 9'1- Sf. 'Ie. f!..tu..:.I r~
: IN CUSTODY
ORDER OF COURT
NOW, this 'I ~ day of October, 1994, upon presentation and consideration of tho
attached stipulation and agreement and upon agreement of the parties, it is hereby ordered and
decreed that the attached agreement is made an Order of Court,
BY THE COURT,
/5/ ~.... F. /./if-;
I ' J.
TRUE COpy FROM RECORD
In Tosllmooy whmol, I h:!re ur.!O !et my lI;>nd
and lllI seat of 5&ld eoor1 ill G.1rUHle, PI.
T11ta !It/... day 01 c;.,,~ 19""
C J:-;.. _ (] . . fp~ .
I Prothonoiary
TIMOTHY A. H. SWEENEY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CML ACTION . LAW
v.
TINA M. SOMMER,
Defendant
: NO.
: IN CUSTODY
STIPULATION AND AGREEMENT
THIS STIPULATION AND AGREEMENT entered into this 3''>1 day of October,
1994, by and between TIMOTHY A. H. SWEENEY (hereinafter referred to as "Father") and
TINA M. SOMMER (hereinafter referred to as "Mother").
NOW THIS AGREEMENT WnNESSETH THAT:
WHEREAS, the parties are the natural parents of the minor child, Timothy A H.
Sweeney, Jr., bom June 18, 1987; and
WHEREAS, the parties wish to enter into an agreement relative to the custody and
partial custody of the child.
NOW, THEREFORE, in consideration of the mutual covenants, promises and
agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as
follows:
, :l~'