HomeMy WebLinkAbout95-01697
6. TIle relationship of Plaintiff to the child is that of mother. The Plaintiff currently resides with
the following person(s):
Name Relationship
Kristy Allen Daughter
Dana Allen Daughter
7. TIle relutionship of the defendant to the child Is tlmt of futher. TIle Defendant currently
resides with the following person(s):
Name Relationship
None
8. Plaintiff hus not punlciputed us a puny or witness, or in another capucity, in other litigation
conceming the custody of the child in this or another coun. Plaintiff has no infonnation of a custody
proceeding conceming the child pending In a court of this Commonwealth. Plaintiff does not know of
a person not a purty to the proceedings who has physical custody of the child or claims to have custody
or visitation rights with respect to the child.
9. TIle best interest und pennunent welfure of the child will be served by grunting the relief
requested becuuse the Plulntiff, Kuren L. Moloney, cun provide umore stable und nurturing atmosphere.
Grunting Plaintiff custody will be in the best interest and pennanent welfare of the child. Plaintiff left
the marital home dae to the threat of abuse by the Defendunt. Plaintiff wishes to ullow Defendant access
to the child while u Conciliution Conference Is pending, but docs not trust Defendant to retum child to
her. Accordingly, she requests this Honoruble Coun to confirm thut pending the Conciliation
Conference, that Plaintiff is grunted primury physical custody of the child with the Defendant receiving
cenuln specified periods of partial physical castody.
a) Alternating weekends (from Friday at 6:00 p.m. until
sunday at 6:00 p.m.) beginning May 26, 1995. The parties agree to
cooperate with each other if switching weekends is necessary due to
work schedules or other important matters;
b) One weekday per week (providing Father gives Mother
seventy-two (72) hours' notice prior to such date; and
c) Fathor ~/ill have such furthor 1 tbar",l pnr.i.odA of
physical custody as the parties may agree. Further, Mother agrees
to cooperate with Father to allow him additional liberal periods of
physical custody during holidays. Accordingly, the parties agree
that a specific holiday custody provision is not necessary.
3. Neither party may take Kyle outside Cumberland County
other than for short trips which do not effect the other party's
visitation. In the event Mother wishes to relocate, she must first
petition the Court of Common Pleas of Cumberland County for a
further custody/visitation Order.
4. The parties agree that this Interim stipulation and the
accompanying Interim Order shall be given no effect in determining
subsequent custody/visitation petitions.
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WITNE
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a) Alternating weekends (from Friday at 6:00 p,m. until
sunday at 6:00 p.m.) beginning May 26, 1995. The parties agree to
cooperate with each other if switching weekends is necessary due to
work schedules or other important matters;
b) One weekday per week (providing Father gives Mother
seventy-two (72) hours' notice prior to such date; and
c) Father will have such further liberal periods of
physical custody as the parties may agree. Further, Mother agrees
to cooperate with Father to allow him additional liberal periods of
physical custody during holidays. Accordingly, the parties agree
that a specific holiday custody provision is not necessary.
3. Neither party may take Kyle outside Cumberland County
other than for short trips which do not effect the other party's
visitation. In the event Mother wishes to relocate, she must first
petition this Court for a further custody/visitation Order.
4. The parties agree that this Interim Order (and the Interim
stipulation on which this order is based) shall be given no effect
in determining subsequent custody/ViAit~i~ petitions.
BY THE CO,PHT:
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