Loading...
HomeMy WebLinkAbout02-3786 C VERIFICATION I verify that the statements made in this Complaint are true and correct. I understan that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 490z relating to unsworn falsification to authorities. Dated: ~_~eresa A. Le~is, J~laintiff SAIDIS ;HUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA Theresa A. Lewis Plaintiff Kenneth M. Lewis, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ~,~_,~, '2.,~. CIVIL 2002 SAIDIS ;HUFF, FLOR~_~ & LINDSAY 26 W. High Street Carlfsle, PA STIPULATION FOR CUSTODY AND NOW, these parties by and through the respective Counsel, to stipulate as follows: 1. The Plaintiff is Theresa A. Lewis, an adult individual residing at 1804 Kent Drive, Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is Kenneth M. Lewis is an adult individual residing at 1804 Kent Drive, Camp Hill, Cumberland County, Pennsylvania; 3. The parties are the natural parents of Courtney Lewis, date of birth 09-18-1997. 4. The parties agree that they shall share legal custody of said child. 5. The parties further agree that the Mother shall have primary physical custody of the said child. 6. The parties further agree that the Father shall have periods of partial physical custody at such times as the parties may mutually agree. 7. The parties further agree that Mother shall be able to relocate with the child to Texas. 8. The parties desire that this Agreement be evidenced by an Order of Court. 9. The Parties have the right to modify any provision of the custody SChedule hereto upon mutual agreement by both parties. In the event that a proposed Modification is not agreed to, the schedule as stated herein shall be complied with by the parties. The parties reserve the right to modify this Stipulation Agreement through the Court pursuant to Pennsylvania Law, and Cumberland County Pennsylvania shall retain jurisdiction hereto. WHEREFORE, the parties hereto request your Honorable Court to enter an Order awarding custody as stipulated above. Respectfully submitted, SAIDIS, SHUFF, FLOWER & DNDSAY SAIDIS SHUFI~, ~OWF_,R & LINDSAY 26 W. High Street Carlisle, PA Dated: '~- 0 2~ c~_ WITNESS: Attorney I.D. # 53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff Kenneth M. Lewis -- Theresa A. Lewis Plaintiff Kenneth M. Lewis, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA : · NO. ~,1,--3~7~P(~ CIVIL 2002 : : : : ORDER AND NOW this /~'" day ¢~y, ~", 2002 a consideration of the attached Stipulation it is hereby ordered and decreed that the parties shall share legal custod~ of the child, Courtney Lewis, date of birth 09-18-1997. The parties further agree that Plaintiff shall have primary physical custody of said child, subject to periods of partial physical custody with the Father as the parties may agree. SAIDIS SHUFF, FLOWER & LINDSAY ATrO~*ATeLAW 26 W. High Street Carlisle, PA BY THE COURT: SAIDIS SI-RIFF, FLOWER & LINDSAY A'I'FORE~YS*AT*LAW 26 W. High Street Carlisle, PA Theresa A. Lewis Plaintiff Kenneth M. Lewis, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : · NO. ~,-~ '7,~(, CIVIL 2002 STIPULATION FOR CUSTODY AND NOW, these parties by and through the respective Counsel, to stipulate as follows: 1. The Plaintiff is Theresa A. Lewis, an adult individual residing at 1804 Kent Drive, Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is Kenneth M. Lewis is an adult individual residing at 1804 Kent Drive, Camp Hill, Cumberland County, Pennsylvania; 3. The parties are the natural parents of Courtney Lewis, date of birth 09-18-1997. 4. The parties agree that they shall share legal custody of said child. 5. The parties further agree that the Mother shall have primary physical custody of the said child. 6. The parties further agree that the Father shall have periods of partial physical custody at such times as the parties may mutually agree. 7. The parties further agree that Mother shall be able to relocate with the child to Texas. 8. The parties desire that this Agreement be evidenced by an Order of Court. 9. The parties have the right to modify any provision of the custody schedule hereto upon mutual agreement by both parties. In the event that a proposed Modification is not agreed to, the schedule as stated herein shall be complied with by the SAIDIS SHUFF, FLOWER & LINDSAY ATrORNEYS*AT*LAW 26 W. High Street Carlisle, PA parties. The parties reserve the right to modify this Stipulation Agreement through the Court pursuant to Pennsylvania Law, and Cumberland County Pennsylvania shall retain jurisdiction hereto. WHEREFORE, the parties hereto request your Honorable Court to enter an Order awarding custody as stipulated above. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Dated: John~/'riaJ ~/ ' ¢"~--'~ · Kopecky, Esquire Attorney I.D. # 53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff WITNESS: ,/,/T~esa A. Lewis Kenneth M. Lewis