HomeMy WebLinkAbout94-06698
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NOV 28 1994cV-'
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SANDRA J. BASEHORE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
94- ~f., 'if
CIVIL TERM
CARRIE L. DOHERTY and
STEPHEN MORGAN,
Defendants
STIPULATION FOR CUSTODY
AND NOW, this :;.3<</ day of A/tJtlf'I/10e", 1994, comes
SAlOIS, GUIDO,
SHUFF &
MASLAND
26 W. H1ah S"<<I
C"lill"PA
SANDRA J. BASEHORE, CARRIE L. DOHERTY and STEPHEN MORGAN, to
stipulate as follows:
(1) Your Petitioner is Sandra J. Basehore, an adult
individual who currently resides at 501A E. Elmwood Avenue,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
(2) Respondent Carrie L. Doherty, who is the daughter of
the Petitioner, is a minor individual who currently resides
with the Petitioner at 501A E. Elmwood Avenue, Mechanicsburg,
Cumberland County, Pennsylvania 17055.
(3) Respondent Stephen Morgan is a minor individual, who
currently r.esides with his parents at 600 E. Coover Street,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
(4) The Petitioner is the maternal grandmother of one
child, Allison Marie Morgan, D.O.B. 10-31-94.
(5) The Respondents are the natural parents of said
Allison Marie Morgan.
(6) The parties agree that the Petitioner shall be the
legal guardian of the said minor child, and shall have primary
legal and physical custody of the said child.
(71 The parties further agree that periods of partial
...
SAID IS, GUIDO,
SHUFF &
MAS LAND
26 W, IUgh Slrecl
CarUIi.,PA
custody/visitation shall be enjoyed by the Respondents at times
to be mutually agreed upon by the parties.
(8) The parties further agree that your Petitioner and
legal guardian will have primary responsibility for financial
and emotional support, including but not limited to healthcare
coveragu and decisions, education, and welfare of said child.
(9) The parties further agree that the Petitioner shall
take the said child as a dependent deduction for Pennsylvania
and federal income tax purposes.
(10) The parties further agree that no child support will
be paid by the Respondents until such time as they are able to
provide financially for the support of said child.
(11) The parties desire that this agreement be evidenced
by an Order of Court.
(12) The parties further agree that this Stipulation may
be amended as circumstances change.
WHEREFORE, the parties hereto request Your Honorable Court
to enter an order awarding legal custody to the Petitioner,
subject to the terms as provided herein.
~A-.I,. f.Z! ~"-V';r J;(';<:J<lluJ
Witness l
l_ '/.'1"-/ (] ..,g{l.;J.('.1#-U /
~~dra J. ~sehore
C0 ,",~j f.,,])o-A 0 ~I
Carrie L. Doherty V
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