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Home My WebLink About94-06096 , i ,'l' , " , ' i " " .. I, I. , I, I, "ld ," '. ; "i']"'I!1 I , I' I'i) , " 1,'\ " , I I', X P '1- 't' , , ",' ,'I " " , , I.', i,' " ',I . ;1 I.,. , , II , . ;1.0,1 " '{ " , II ., , I, " ,'," , ., , , .' 1 " , " , , , , , ;, , , , , ,..," , , ,I r " ., , ,Il 1" " " , , " , I; "I" " " I L '1 :, I " I" I.- " " , , " " t, .',1 " , , , ,Ii '" j j I " '" t '~ " I ~r 0'" . '-/' ", " 'i," ,I, ','I' , , , , , " " " \'1' " " . J\' ,'1, if, I " , ... . GOLDlIIQ. KAT.'" . ..Z..... ..c. Paul J. Sapoaito . I.D. .25454 Attorneya for Pleintiff 320S Market Street strawberry Square P.O. Box 1268 HarrioDurg, PA 17108-1268 (717) 234-4161 v. IN THB COURT OF COMMON PLaAS CUMBERLAND COUNTY, PBNNSYLVANIA No.~CCjf;cIVIL 1994 CIVIL ACTION - LAW CUSTODY/VISITATION RUTH M. CRAWFORD, Plaintiff GARY M. CRAWFORD, JR., Defendant A1fJ) HOW, ~RD.1l. thiS~~ day of , 1994, upon presentation and consideration of the attached Stipulation, it is hereby ORD.Il.KD A1fJ) D.C.-aD that the said Stipulation, as submitted and executed by the parties, shall be incorporated into and made a part of this Order, thereby giving said Stipulation the full force and effect as an Order of this Court. J. :\it\H , " \t\~ r.. ',,~ ~_ "". ..,f\ .. '", ,,', (r,'I ' j\, ~l 1M- " ,.J \ '. .',1\0, \ ~'tj 'l')\l'.' . " '11, \'l\} ~~. ~~ Qt \, . r. ~ .. -; QOLDIIIQ, KATIllIIAIf . ..Z~. ..c. Paul J. sspoBito - I.D. .25454 Attorneys for Plaint i H 3208 Market Street St rawberry Square P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 RUTH M. CRAWFORD. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. CIVIL 1994 GARY M. CRAWFORD. JR., Defendant CIVIL ACTION - LAW CUSTODY/VISITATION STIPOLATIOH VQR CUSTODY THIS STIPULATION, made this ~_ day of (}id:Je.r . 1994. by and between RUTH M. CRAWFORD, plaintiff, and GARY M. CRAWFORD, JR.. Defendant. WITHBSSBTH, WHEREAS, Plaintiff has filed a Complaint for CUstody regarding the parties' one minor child, JEFFREY DAVID CRAWFORD, born November 7. 1992; and WHEREAS, the parties have reached agreement relative to the custodial arrangements for their son and wish to enter into the instant Stipulation. which will be submitted to the Court for issuance of an Order. NOW, THEREFORE. the parties stipulate and agree as follows: . r . .' , 'w . 1. Plaintiff shall have primary legal and physical custody of their one minor child, JBFFRB'i DAVID CRAWFORD. 2. Defendant shall have temporary physical custody of the parties' minor child as follows: A. Each Sunday from 10:00 a.m. until 9:00 p.m.; and B. At such other times as the part.ies shall mutually agree upon and arrange. 3. The parties have each had the opportunity to have this Stipulation and its legal effects fully explained to them by their legal counsel. Each party acknowledges that this Stipulation is fair and that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. 4. The parties agree that a Court Order encompassing the provisions herein set forth shall be entered by the Court of common Pleas of Cumberland County, pennsylvania, which Court shall retain jurisdiction over this matter. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. WITNESS: -') \. l,- II il// {I . / Ii R~H: I M :)~l1.JFo~~<('t1i ti 1+' G:9~W~JR. " ." .~ ~~ ~, o .... .l 4 ,~ ,~ ,,' " ',,; . Birth - 9/24/93 417 North 3rd Street, Steel ton , Dauphin County, Pennsylvania Plaintiff and Defendant 9/24/93 - Present 348 Black Latch Lane. Camp Hill, Cumberland County, Pennsylvania Plaintiff and Plaintiff's slster and her husband, Leila and Andreas Bendzin The mother of the child is RUTH M. CRAWFORD, Plaintiff herein. \'.tIO is currently residing at 348 Black Latch Lane, Camp Hill, Cumberland County. Pennsylvania. She is was formerly married to the Defendant, The father of the child is GARY M. CRAWFORD, JR., Defendant herein, who is currently residing at 417 North 3rd Street. Steel ton. Dauphin County, Pennsylvania. He was formerly married to the Plaintiff. 5. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently resides with her sister and her sister's husband. Leila and Andreas Bendzin and the child. 6. The reI ati onshi p of Defendant to the chil d is that of father, Defendant currently resides with his girlfriend. Gina (last name unknown). 7. PI ai nt iff has no i nformat ion of a custody proceedi ng concern I ng the child pending in a court of this Commonwealth. 8. Plaintiff does not know of a person not a party to the proceedings who has physical custOdy of the child or claims to have custody or visitation rights with respect to the child, 9. The best interests and permanent welfare of the child will be served by the reI ief requested. 10. Plaintiff has not participated as a party, witness or in another capacity or in other litigation concerning the custody of the child in this or another Court. 11. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as a party to this action. WHEREFORE. Plaintiff respectfully requests that this Honorable Court enter an order grilnting shared legal custody and primary physical custody of the parties' minor child. JEFFREY DAVID CRAWFORD. to her, Respectfully submitted. GOLD~~G. ., AN :7rIPMAN. By (P-tlf ;J*~ au, s o. squ re 320E ark Street Post Office Box 1268 Harr'isburg. PA 17108-1268 (717) 234-4161 Attorneys for Plaintiff P.C. 'I', " " .' , ~EBlfICAIlllN I verify that the statements contained in the foregoing CC>>1PLAINT FOO CUSTODY are true and correct to the best of my knowledge. information and belief. I understand that false statements contained herein are made subject to the penalties of 18 Pa.C.S. ~4904 relatlng to unsworn falsification to authorities. Date: q-/(tJ-9~ ~t.{Zwa~~ i' I, , , " .