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Home My WebLink About95-02696 ~ 8 3 . 'I j .-0 3. ~ J j ! ...., 0- · ..::JI ~I \ l.{)1 CT' BRETT M, WOODBURN. Plaintifl" IN TilE COl!ln OF ('()MMON PI.EAS OF CIJMBElU.AND COUNTY. PENNSYl.VANIA V's, NO. 95-26% CIVIl. TERM DENISE M, WOODBURN. Dclcndant CIVIl. ACTION -l.AW ( 'lJSTODY OIU>lm AND NOW. this ~ <j' day of I-pyt-IA- . 11)97. upon rcceipt of the Conciliator's Rcp1ll1. itappcaring thatthc panics have ugrccd to thc tcrms ant! provisions of this Ordcr which was dictlltcd in thcir prcscncc and approvcd hy thcm, it is hcrchy ordcrcd und dircctcd as lilllows: I. Thc panics shall shurc Icgal custody ofthcir minor child, Brcll Michuel Woodhurn, d.o.h, Novcmhcr 25, 19H9, 2, Fathcr shull havc primary physical custody ofthc minor child subjcct to pcriods of partial custody and visitation with Mothcr as lilllows: A. On the sCCllnd weekcnd of cach month IhulI Friday hctween 1);00 and 10:00 p.m. until Sunduy helwccn9;()O and 10:00 p.m, .1. Thc parties shullnllernutc thc Th:mksgi\ing holiday, That holiday is heinll dclincd as thc cntir~' timc when thc child is oil" Iillm school during that hrenk. I he times lillthis period ofl'artial custody ullll visitution shull hcgin on the day thc ('hilt! is releascd hllm sl'honl het\\~'cn'J:()O und IIUlO p,m. until thc day the dnld is tll lell/lnlll schllllllwt\wcn');IHl 1I1ll11 ():O() pnl. 1\1nthcr shull hllvc Ihc Thllnksgiving holidllY in 1997 IInd 1111 odd-numhcrcd ycurs Ihcrcllncr. und FlIthcr shllll hllvc thc Thllnksgiving holiday in 199H IInd 1111 cvcn-nulllhcred ycurs IhcrclIl\cr. 4. Thc Christllllls hllllday shall bc illllccordllncc with Ihc lillluwlng schcdulc: In 1997 IInd ulll1lld-numhcrcd ycars Ihcrcal\cr. FUlhcr shall hllvc Ihc child frolllthc relcasc from Scholllunlil Dcccmhcr 26th at H:OO p.llI. Mothcr shllll havc thc child Ihllll Dcccmbcr 26th at H:OO p.m. unlil JanulIry I slllt 3 :00 p.llI. In 199H IInd 1111 c\'Cn-nulllbcrcd ycars thcrclll\cr. FlIlhcr shall havc thc child Ihllll his relcasc from school until Dcccmbcr 24th lit 12:00 noun, IInd Mothcr shall hllvc thc child Ihllll Dcccmbcr 24th utI2:0() noon until Junuary 1st lit 3:00 p.IlI, 5. Thc partics shallllltcrnatc thc Eastcr holiday; this holiday is dctincd as bcginning thc day thc child is rclcllscd from SChOlll hctwccn9:00 IInd )0:00 p.m.. untillhc cvcning bctorc thc child is to rclurn 10 schoul bctwccn 9:0() and lO:O() p.llI. This shllll bc IIltcrnatcd cach ycar with Mothcr having Eastcr in 1998 and all cven-numbcrcd ycars thcrcancr, and FlIthcr shall havc Eastcr in 1999 and nil odd. nUll1bcrcd ycars thcrcllncr. fl. Mothcr shllll hllvc IItutal uf lillII' (4) wccks of sUll1mcr custody with thc child, Shc may havc onc pcriod Ill' timc which includcs IWll consccutivc wccks. Thc uthcr two wccks shall bc non-consccutivc, Mothcr shall providc FlIlhcr wilh thc dlltcs in which shc intcnds to cxcrcisc thcsc pcriods of partilll cuslody with thc child by April t stor cach ycar. BRErr M, WOODBURN. Pluintill' ) ) ) ) ) ) ) ) IN TilE l'OlmT OF {'OMMON PLEAS OF ('UMBEI{LAND ('OUNTY, PENNSYI.V ANIA VS, No''I5-2(,'i6 CIVIL TERM DENISE M, WOODBURN, Delcndunt CIVIL A('TlON - LAW ('I ISH lilY JliDOE PREVIOUSLY ASSIONED: None ClJSTOI)Y CONCILIATION ('ONFElmNCJ<: SlJMI\tAltY Iml'OltT IN ACCORDANCE WITII CUMBERLAND COUNTY RULE OF CIVIL I'[WCEDURE l'I15.3-8(h), the undersigned Custody ('onciliutor suhmits the f()lIowing report: I. The pertinent inl(lfI11utlon concerning the child(ren) who is(ure) the subject of this Iitlgution is us (()!lows: NAME BIRTlIDATE CURRENTLY IN CUSTODY OF Brell Michuel Woodhurn NO\'Cl11her 25, 1911'1 Plaintiff 2. A Conciliution Conlcrence wus held on Septemher 1'1. ('1'17. und the Ibllowing individuuls were present: the Pluintitl' uppeured pro se: the Defcnduntuppeured with her ullorney, Mullhew J, Eshelmun, I.squire, l Items resolved hy agreel;lent: See alluched Order. 4. Issues yet to he resolved: See lIttllched Order. 5. The Pluintitrs position on custody is us fi)lIows: See alluched Order. 6, The Defcndunt's position on custody is us I(,!lows: See ullllched Order, BRETT M, WOODBURN, Plaint if f I IN TilE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I No. 95-2696 CIVIL TERM I I CIVIL ACTION - AT LAW I CUSTODY VB, DENISE M, WOODBURN, Defendant AND NOW, thle ORDER OF COURT -1 I ) l\ 1(\'. I , upon conBideration of the attached RequeBt for Re-Conciliation, it iB hereby directed that the partieB and their reBpective counBel appear before ~ ~, the conciliator, at )~,,) ~. \'\~\\"::,\-..((nf H'i\\. _PA. , on the _I \ day of '>r k->11\\ 1"( , 1997 at \ '.Ot) \-.m., for a prehearing Custody Conference. At such conference, an effort will be made to reBolve the iSBues in dispute I or if this cannot be accomplished, to define and narrow the iSBues to be heard by the court, and to enter into a temporary order. Either party may bring the children who are the Bubject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide groundB for entry of a temporary or permanent order, FOR litE COUtT Ij ) BYI H.::l\fll' r tnl104,Lvh.. Custody conci~ YOU SHOULD TAU THIS PAPER TO YOUR LAWYBR AT ONCE. IF YOU 00 NOT DAVE A LAWYBR OR CANNOT AFFORD ONB, GO TO OR TBLEPHONE THE OFFICB BET FORTH BBLOW TO FIND OUT WHBRE YOU CAN GBT LEGAL HELP. OFFICE OF TUB COURT ADMINISTRATOR COURTHOUSE, ~~URTH FLOOR CARLISLB, PA 17013 (717)240-6200 llRE'rT M, WOODBURN, . IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA I vs. I No. 95-2696 CIVIL TERM I OIlNIBE M, WOODBURN, . CIVIL ACTION - AT LAW Defendsnt . CUSTODY IwaUHST FOR CONCILIATION CONFBRHNCB 1~e Defendant, Denise M, Woodburn, by and through her attorney, Jeanne ll. Wigbels, Esquire, files thle Request for a ConcH iation Conference regarding the above-captioned Action in Custody. 1, The Defendant is Denise M. Woodburn, an adult individual and the natural Mother, who currently resides at 4754 Brian Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2, The Plaintiff is Brett M, Woodburn, an adult individual and the natural Father, who currently resides at 309 15th Street, New Cumberland, Cumberland County, Pennsylvania 17070. 3. The Defendant seeks a conference regarding the following , childl liAInIl Present Address lW. llrett Michael Woodburn 309 15th Street 7 New Cumberland, PA 17070 O,O.B, 11/25/89 'rhe child was nol borll out of wedlock. 4, The chi ld is presently in the custody of the Plaintiff, llrell H. Woodburll, who currently resides at 309 15th Street, New Cumberland, Pennsylvania 17070, 5, During the past five years, the child resided with the followi n9 persons snd al the following addresses. ~ Addreee Brett M. Woodburn, McKeee Rocke, PA Denise M. Woodburn, and maternal grandmother Datee 6/1990- 10/1992 Brett M. Woodburn, Denise M. Woodburn, and father's parents Brett M. Woodburn, Denise M. Woodburn, and father's parents paxtonia, PA 10/1992- 6/1993 309 15th Street New Cumberland, PA 6/1993 3/1994 Brett M. Woodburn and Denise M. Woodburn 531 Bedford Court Mechaniceburg, PA 531 Bedford Court Mechaniceburg, PA Washington County, PA 3/1994 8/1994 8/1994 1/1995 2/1995 3/1995 3/1995 5/1995 5/1995 8/1995 8/1995 6/1996 6/1996 8/1996 8/1996 5/1997 5/1997 Preeent Denise M. Woodburn Father'e grandmother Maternal grandmother Allegheny County, PA Brett M. Woodburn and hiB parente Brett M. Woodburn 309 15th Street Ada, Ohio Father's grandmother Washington County, PA Brett M. Woodburn Ada, Ohio Brett M. Woodburn and hiB parent 309 15th etreet New Cumberland, PA 6, The Mother of the child ie Deniee M. Woodburn, who currently reeidee at 4754 Brian Road, Mechaniceburg, Cumberland , County, Penneylvania 17055. Father. The Mother is divorced from the 7. The Father of the child 18 Brett M, Woodburn, who currently reeidea alone, at 309 15th Street, New Cumberland, Cumberland County, Pennsylvania 17070, with the subject of this petition, his son. The Father is divorced from the natural Mother. B. The most recent Order of Court regarding this matter is dated June B, 1995 (attached). 9. The following changes in circumstance have occurred since ' the June B, 1995, Order of Court I (a) Father is presently in the process of moving back to Ada, Ohio, with the child which will make it more difficult for Mother to visit with the child. (b) Father has moved with the child on several occasions without giving Mother notice of his new address. (c) Father uses visitation with the child as a tool against Mother to obtain property for which he neglected to file a claim prior to the finalization of the divorce. WHEREFORE, Defendant respectfully requests that this Honorable Court enter an Order scheduling a conciliation conference regarding this matter. Respectfully submitted I .' \. ' . ;,<, j" ,,. I v''<l6'Y.. ~ Jeanne B. Wigbela; Esq ire Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp lIill, Pennsylvania 17011-4706 PA Supreme ct. 10 No. 6B735 Phonel (717) 763-1BOO 1 ! DATED I I 1()/ /; 7 BRETT M. WOODBURN, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I vs. I No, 95-2696 CIVIL TERM I DENISE M. WOODBURN, I CIVIL ACTION - AT LAW Defendant I CUSTODY VERIFICATION I, Denise M. Woodburn, state that I am the Defendant in the above-captioned case and that the facts set forth in this document are true and correct to the best of my knowledge, information, and belief. I realize that false statements herein are subjeot to the penalties for unsworn falsification to authorities under 18 Pa. C.S. S 4940. --:j),,~w' IJ;; uJdI~, Denise M. Woodburn Date I +//8/9::; ..... en 11; '-' L 1I,t', ('J '-J; , :J'. I " [[I ... 0) ~ ~ ~1::, "l N til.: I , '\;1 :':'1 I -. lL IJ. r-- .1 U <1' U rAlIIIC!l. t., J.AlJI(R. JII, AlIurllft a' I.alt llllti M,,~., ~"""I A,Je.. HuihllllB ('allillll 1l.I'A 111111 OPt 1',\ 1M 10 ~ m! l,~ ~ :S1Ia~~ ,t. III F.i;!! IIoi e . M l!: ~ l:S!~~e-E ~< N ~ ~ Ili~1 Woodburn and father's parents Brett M. Woodburn, Denise M. Woodburn and Hither's parents 309 15th Street New Cumberland, I'A 6/1993. 3/1994 Brett M. Woodburn and Denise M. Woodburn 531 Bedford Cl. Mechanicsburg, I) A 3/1994- 8/1994 (Late August, 1994,I'Iaintilfmoved to Ada, Ohio to attend Law school, with Defendant and child expected to follow in December 1994.) Denise M. Woodburn 531 Bedford Cl. Mechanicsburg, I) A 8/1994- 9/24/94 Father's grandmother Washington, PA 9/25/94- 10/16/94 Denise M, Woodburn 531 Bedford Cl. Mechanicsburg, P A 10/17/94- 11/12/94 Father's grandmother Washington, PA 11/13/94- 11/20/94 Denise M. Woodburn 531 Bedford Ct. MechanicsbUlg, P A 11/21/94- 12103/94 Father's grandmother Washington,l'A 12104/94- 12/11/94 Denise M. Woodburn 531 Bedford Cl. Mechanicsburg, P A 12112194- 12/25/94 Brett Woodburn and father's parents 309 15th Street New Cumberland, PA 12126/94- 01/08/95 Denise M Woodburn 531 Bedford Ct. Mechanicsburg, P A 01/09/95- 01/28/95 Father's grandmother Washington, PA 01/29/95- 03/10/95 Malernalgrandrnother McKees Rocks, PA 03/11/95-Palrn Sunday (a) Plaintitf currently resides in SmethpUlt, McKean ('OUllty, I'ennsylvanin. (b) Mother has always been apprised of Plaint in's and child's addresses and phone numbers, Further, all addrcsses for the previous five ycars arc detailcd abovc. ( c) Visitation has nevcr been used as "a tool against Mother to obtoin propcrty." NEW MATTER 10. Plaintiff Fathcr hos maintained sole and continuous custody of the child beginning on May 13, 1995 and continuing through the prescnt. II, Plaintiff Father has provided the sole mcans of support for the child, including food, housing, clothing, medical expenses, dental expcnses and incidentals. 12. Mother has not paid ony child support. 13. Plaintiff Father has not denicd Mother access to child, and has coordinated visitations based upon Mocher's schedule, Father's schedule and child's schedule and desire to visit Mother. 14. The trip from Ada, Ohio to Pittsburgh.I'ennsylvania is approximately two hundred and sixty miles (260). 15. The trip from Ada, Ohio to Mechanicsburg, Pennsylvania is approximately four hundred and filly miles (450) 16, PlaintitfFather agreed to facilitate visitation while he and the child were living In Ohio by meeting the Mother in I'illsburgh, Pennsylvania WHEREFORE, Plaintilf respecll1.llIy liIes this I{esponse to Request for Conciliation Conference, agreeing to same Respectfully submitted Dated [/'1 /~ 7 I , ~;J~L Drett M Woodburn 33 I;, Bank Street Smcthp0l1, I)A 16749 (814) 887 - 5008 .n ) >..J I ';. , , " :, \ .111 I .' l)l .! " ,....' BRETT M WOODBURN, 11laintilr IN TIm COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 95-2696 CIVIL TERM DENISE M WOODBURN Defendant CIVIL ACTION - AT LAW CUSTODY AND NEW MATTER RESPONSE TO REOlJEST I<'OR CONCILIATION CONFERENCE The Plaintiff, Brett M, Woodburn, pro se, files this Response to Request for Conciliation Conference regarding the above-captioned Action in Custody: I , Admitted 2, Admitted in part, denied in part. Plaintiff is an adult individual and the natural father. Plaintiff currently resides at 33 '/, Bank Street, Smethport, McKean County, Pennsylvania, 16749. 3. Admitted in part, denied in part. The child, Brett Michael Woodburn II, does currently, and has at all times since May 13, 1995 resides with Plaintin~ The child was not born out of wedlock 4. Admitted in part, denied in part The child is presently inlhe custody of Plaintiff, See paragraph 2 tor correcl address 5. Denied During the pasl five years lhe child has resided with the following persons at the following addresses ~ Addrrn Data Brett M Woodbnrn, Denise M Woodburn and malernall!randmother McKees Rocks, PA 6/1990- 10/1992 Brett M Woodburn, Denise M I'axtonia, I' A 10/1992. ()/ 1993 Father's grandmother, Hrett M. Woodburn and father's parents Washington, I'A, New Cumberland, PA Friday before I'alm Sunday Ihm Easter Monday 1995 Maternal grandmother McKees Rocks, I' A Easter Monday thm 05/12/95 Hrett M Woodburn and father's parents New Cumberland, I' A 05/13/95- 08/19/95 Brett M Woodburn Ada, Ohio 08/20/95- 05/19/96 Brett M. Woodburn and father's grandmother Washington,l'A (Summer jub) OS/20/96- 08/23/96 Brett M. Woodburn Ada, Ohio 08/24/96- 05/31/97 Brett M. Woodburn and father's parents New Cumberland, I'A (Bar Exam) 06/01/97- 07/29/97 Brett M Woodburn Smethport, I'A 07/30/97 - Present 6. Admitted 7. Admitted in part, denied in part The Father of the child is Brett M. Woodburn. who currently resides with the child at JJ \I, Hank Street, Smethport, McKean County. l'e'IDsylvania, 111e Father is divorced ftomlhe natural Mother I'laintilfhas never resided alone at 3()9 15th Street, New Cumberland, Cumberland County, I'ennsylvania This has at all times been the address or I'laintifl's parents R Neither admitted nor denied The order rel'ererll;cd in Defendant's Request for ('unciliation Conference was not attached to the notice served onl'laintifl' () Denied (a) Plaintiff currently resides in Smelhport, McKean County, Pennsylvania, (b) Mother has always been apprised of Plaintiffs and child's addresses and phone numbers. Further, all addresses for the previous five years are detailed above. ( c) Visication has never been used as "a tool against Mocher to obtain property." NEW MATIER 10. PlaintitTFather has maintained sole and continuous custody of the child beginning on May 13, 1995 and continuing through the present. I ] . PlaintitT Father has provided the sole means of support for the child, including food, housing, clothing, medical expenses, dental expenses and incidentals. 12. Mother has not paid any child support. 13. PlaintitT Father has not denied Mother access to child, and has coordinated visitations based upon Mother's schedule, Father's schedule and child's schedule and desire to visit Mother. 14. The trip from Ada, Ohio to Pittsburgh, Pennsylvania is approximately two hundred and sixty miles (260). 15. The trip from Ada, Ohio to Mechanicsburg, Pennsylvania is approximately four hundred and fifty miles (450). 16, PlaintiffFather agreed to facilitate visitation while he and the child were living in Ohio by meeting che Mother in Pictsburgh, Pennsylvania WIlEREFORE, Plaintilf respectfully files this Response to Request for Conciliation Conference, agreeing tn same BRETT M, WOODBURN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, No, 95-2696 CIVIL TERM DENISE M, WOODBURN Defendant CIVIL ACTION - AT LAW CUSTODY AND NEW MATTER VERI FICA TION I, BrelC M. Woodburn, state that I am the Plaintiff in the above-captioned case and that the facts set forth in this document are true and correct to the best of rny knowledge, Infonnatlon, and belief I realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S, * 4940, ~t<ML Breit M. Woodburn Dated: 'i/-tH1 I , COURT ADMINIIl'l'IlA'I'OR, FOURTH FLOOR CUMDERLAND COUNTY CQUIl'l'1l0IJSE CARLISLE, PENNSYLVANIA 1701J TELEPHONE I 7 I 7-24 0-G2 00 For the court, BYI -A".,,-(/~.) IJIl J_ custody concil ator ~ c~ f~fI' I ' W ^ VNE 1', SIIAI'" ^'''''llf)' .ll.v. HWnlf'lIl;lIl1rlHlltfl ("lll!;lr. l'tnn~)hllll' lW11 (b) From June of 1990 through october of 1992, with the parties and the maternal grandmother in McRees Rocks, Pennsylvania; (c) From october of 1992 through June of 1993 with the parties and the father's parents in Paxtoni" Dauphin County, Pennsylvania; (d) From June of 1993 through March of 1994 with the parties and the father's parents at the present address of the father as set forth above; (e) From March of 1994 through August of 1994 with the parties hereto at the present address of the mother; (f) From August of 1994 through January of 1995, with the mother at her present address; (g) From February of 1995 through the middle of March of 1995 with the father's grandmother in Washington county, Pennsylvania; (h) From the middle of March of 1995 through May 13, 1995, with the maternal grandmother in Allegheny County, Pennsylvania; and (i) From May 13, 1995, to the date of filing of this complaint, with the father and his parents at the address of the father set forth above, 6, The relationship of Plaintiff to the child is that of the father, WAYNE F. SIIAIlI' Allowr)' It I....... ~)Wt'lll't1mhrl "Ifni 1'..litlt.IYIUII}I\'a1ul 11111) -2- ... o I' to. ~ J o ~ ~ \~ :r" ,. ... e g:: . "':" "" '" (~ ,. " - r:::., - - .. "'= ()! ~~ ~ n~~ '" B - . ! j j ~ ~~ 2 IBS6 1Il~ i pj c:l -.-4 ~~ ~ ~~~ J j ~ <! J ,.-I . iEll< > ~ u B . , ~ >- I: ~I~'~ U(.,...... In ..,<,- .... ~6t...':'; ... :r:w~.. N O.~.;r..1 I!. :1'; .~ ~, \~:c., li:~ c.o . t,,14,:r: I..i. ~.l'll" . ..211. D ::i ..., ~\.,\ ';,.,' ~l":' ~"ll ~ '1 1 ( n 'r. ~ g IU B s .., - . . l!l ~ ~ ~I~~ ~~ ~ B ~ Sill i ~ ~u 1Il~ 1Il~ 2 fI.l ~ I ~ C';! C~ BI~~ ~,~ J~ ~ ~ I a ~ ~ ~ III a ~~~ OM o~ 0 :E:2l ~ ~ < ~! :E:P< > ~ III !Ii ~Q~ UJ ~ j " , . . JUN - 7 199r j'" BRETT M, WOODUURN, Plaintiff 1 N 'I'llI' coUIl'I' OF COMMON PLEAS OF CUMlIERLAND COUN'I'Y, PENNSYLVANIA CIVIL IIC'I'ION - LAW v, NO, Y5-2hYh CIVIL TERM DENISE M, WOODUURN, Defendant CUSTODY ORDER OF COURT IIND NOW, this _!.'-. day of \7"..,..... , 1995, Plaintiff BRETT M, WOODBURN and Defendant DENISE M. WOODBURN, having stipulated and agreed with regard to custody of their minor child, Ul-ett Michael \1oodburn, 11, born November 25, 1989, it is hereby ordered and decreed, as follows: 1. Shared legal custody of said child as contemplated by the Act of Novembel- 5, 1eW1, 1'.1" 322, 23 P.S. S1001, et seq., will be in both of the parties hereto as the natural parents. 2. Shared physical custody of said child shall be in both parents with the schedule of shared custody to be resolved by the parties upon a flexible basis in accordance with their mutual agreement. By the COlu-t, ~~AJ.. / J. / WHNI' F, SIIM'I' A,IlPrIIr)' III I..... HWr.,I"lllllu-1 !\lInl I '1I111~1t 1'111I1\. II ~1II' lilli' BRETT M. WOODBURN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIII CIVIL IICTION - LAW v. DENISE M. WOODBURN, Defendant NO. 95-2696 CIVIL TERM CUS'I'ODY STIPULATION FOR CHILD CUSTODY AND NOW, this 31 day of ~, 1995, come Plaintiff BRETT M. WOODBURN and Defendant DENISE M. WOODBURN and with regard to custody of their minor child, Brett Michael Woodburn, II, born November 25, 1989, stipulate and agree, as follows: 1. Custody of said child shall be as set forth in the foregoing Order of Court. 2. should either party at anytime in the future petition the Court for a modification of this Order, it shall not be necessary for the party to show a change in circumstances and all relevant facts and circumstances shall be subject to jUdicial review and not only those existing subsequently to the entry of this Order. 3. It is the desire and intention of the parties hereto that this Stipulation for Child custody be entered in the Court of Common Pleas of Cumberland County, Pennsylvania, and that it be endorsed as an Order of Court so as to have the full effect thereof. WAI'NI' F, SIIAllI' AlIlll1U") .1 I A"" .'lWttt 1'''lIIln"' Slrnl l'alll~lr. 1'(,llIu)hlUIIIl IWI'