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THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
~
STATE OF ~~~! PENNA.
KENNETH G. EMIG, JR.,
1'\ II.
3240
"c,~nL.,. 1l)95
I'la!ntiff
\"'I',""S
WANNA 8, EMIG,
Defendant
DECREE IN
DIVORCE
AND NOW, ' . . ,::r.7.tJ.Y .0\1'1 ,II ' . . . . . . . " 19"", it Is ordered and
decreed that,......,.. K~~~l~th. G:, Emig,. :'r:.,..,..,.."........, plalnflff,
and. , . , , , . . . . . , , . . . . . , ,\4a~I~~ II. Emig , ,
, . , , . . . , , " . '" , " defendant,
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
been raised of record in this action for which a finol order has not vet
been entered;
Incorporating the terms of the Separation Agreement dated :'uue 19, 1995.
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SEPARATION AQREEMENT
THIS IS AN Agreement made thiB Il} Ii, day of jl-Wt , 1995,
by and between Kenneth G. ~ Jr., of Mt. Holly springs,
Cumberland County, Pennsylvania, (hereinafter referred to as
Husband) and Wanna n. Emig, of Mt. I/olly Springs, Cumberland
County, Pennsylvania, (hereinafter referred to as Wife),
WHEREAS, Ilusband and Wife were married on September 27,1976, in
Carlisle, Cumberland County, pennoylvania; and
WI/EREAS, various differences have arisen between I/usband and Wife;
and
WHEREAS, the]arties have agreed to maintain separate and permanent
domicileo an to live apart from each other; and
WHEREAS, the parties desire to enter into an amicable oettlement to
provide for all of the property rights of the parties and to
diBpose of the rights and obligations of each to the other in
respeot to aupport, maintenanoe, alimony, oounoel fees, equitable
diotribution, and all other righto and ob1i.gations under the
Divoroe Code of 1900, as amended, and it is the intention and
agreement of the parties that this Agreement be a full, complete
and final uettlement of all of thoee rights and obligations under
said Divoroe Code; and
NOW, TIlEREFORE, for and in exchange of mutual considerations, and
intending to be bound by the provisions hereof, the parties agree
that their reoitals form a part of thio Agreement and waive any
right to counoeling under the Divorce Code of 1900, ae amended, and
right to counsel fees, costs, alimony, support, maintenance, and
any other rights under the said Divorce Code not provided for
herein and agree as followal
1. SEPARATION. The partieo agree that it shall be lawful for each
party, at all times hereafter, to live eeparate and apart from the
othsr, at such place or plaoes as he or she may, from time to time,
ohoooe or deem fit. Each party ohall be free from interferenoe,
authority or contact by the other, as fully aa if he or she were
single and unmarried, eKcept as may be necessary to carry out the
provisions of this Agreemont and as may be necessary to exohange
information that pertaina to the partiee' minor children. Neither
party shall moleet tho other or attempt to ondeavor to molest the
other, nor compel the other to cohabit with the other, or in any
way harass or malign tho other, nor in any way interfere with the
peaoeful oxiatence, separate and apart, from t:,e other.
.
2. REAL ESTATE. Huoband and Wife jointly own the marital
residence locatsd at One Westwood Drive, Mt. Holly springs,
Cumberland County, Pennsylvania. The marital reoldence presently
has outstanding mortgages in favor of PNC Bank and York Federal
Savings & Loan. Wife shall dsed any righte, title an interest she
has in the marital residence to Husband. Huoband ohall assume and
be eolely responoible for the aforesaid mortgages encumbering the
property. Husband shall be solely responsible for all mortgage
payments, liabilities, taxes, assessments, inourance and the cost
of maintenance on the marital residence. Husband shall indemnify
and hold Wife harmless from any liability, claims, causes of
action, suits, or litigation for money owed, damages, indirect or
conoequential, including legal feeo, arising out of failure of
Husband to so pay such liens and encumbrances.
3. AUTOMOBILES. Wife ohall have as her sole and excluoive
property, title to and possession of the 1994 GEO Priem. Husband
shall have as his sole and excluoive property, title to and
possesoion of the 1994 Ford Explorer, Each party shall indemnify
and hold the other harmless from any liability on any loan
encumbering the vehicle, cost of repairo, maintenance,
registration, insurance and/or inspection of the vehicle which each
is taking ao his/her sole and exclusive property.
4. PERSONAL PROPERTY. The partieo have divided or have agreed to
a division of their personal property which includes bank accounts,
certificateo of deposit, life insurance policies, jewelry,
clothing, furniture and other personal itemo. Huoband shall
receive ao hio sole and separate property, in addition to the itemo
oet forth above, the Duke Power stock. After the aforeoaid
division of the personal property is complete, any and all property
in the possession of Husband shall be his sole and separate
property. Any and all property in the poooession of Wife ohall be
her eole and separate property. Each party forever renounces
whatever claimo he/she may have with respsct to the property which
the other is taking. Each party understands that he/she has no
right or claim to any property acquired by the other after the
oigning of this Agreement.
5. PENSION/RETIREMENT PLANS. Wife hereby releases any and all
claims or demando she may have on Hueband's pension or retirement
plans.
6, DEBTS. Husband agrees to assume and to pay and be solely
responsible for the AT&T VISA Account No. 4784 5500 0294 9715 and
GM MasterCard Account No. 5407 6902 6036 6075 in sxistence at the
time of the signing of this Agreement, Wife agrees to aseume and
to pay and be solely responolble for any and all charge accounts and
,
other debts and obligations in exiotence at the time of the signing
of this Agreement in her name alone. Neither party shall contract
nor incur any debt or liability for which the other or his/her
property or estate might be reoponsible and agrees to indemnify the
other from any claimo made againot the other becauee of
debt%bligationo not incurred by the other.
7 . ALIMONY. ALIMONY PENDENTE LITE. SUPPORT OF SPOUSE. The
parties waive any and all right to receive from the other any
payment of alimony, alimony pendente lite, and/or spoueal support.
8. CHILD CUSTODY. The partiee stipulate and agree that the
parties' minor children, Melissa K. Emig, born March 15, 1980, and
Michelle M. Emig, born September 19, 1983, ahall be in the primary
physical custody of Husband. Wife shall have partial custody
rights as the parties may agree. Legal custody of the minor
children shall be shared by the parties. The partieo further
stipulate and agree that a Cuetody Stipulation and Agreement shall
be executed oimultaneously with the execution of this Agreement
which shall call for the entry of a Court Order confirming the
agreement of the parties regarding custody,
9. EFFECTIVE DATE. The effective date of this Agreement ohall be
the date of execution by the partieo if they had each executed the
Agreement on the same date. Otherwise, the execution date of this
Agreement shall be defined as the date of execution by the party
last executing this Agreement.
10. DIVORCE. The partieo agree that should either party file a
Complaint in Divorce, claiming that the marriage io irretrievably
broken under the no-fault mutual coneent provision of section
330l(c) of the Pennsylvania Divorce Code, then both parties agree
to execute any and all affidavits or other documents neceasary for
the parties to obtain an absolute divorce purouant to Section
330l(c) of the Divorce Code including waiver of all rights to
requeot Court ordered counoeling. It io agreod and understood
between the partieo that in the event a divorce proceeding is filed
by either party in any other jurisdiction, that the partin shall
not contest, but instead consent to ouch proceedingo and shall
execute any and all documento neceooary so as to proceed with and
obtain an absolute and final divorce.
11. INCORPORATION INTO DECREE. Should a decree, judgment or order
of separation or divorce be obtained by either of the parties in
this or any other otate, country, or jurisdiction, each of the
parties hereby ccnsents and agrees that this Agrsement and all of
its covenants shall not be affected in any way by any ouch
ssparation or divorcel and that nothing in any ouch decree,
judgment, order or further modification and reviaion thereof ahall
alter, amend or vary any term of this Agreement, whether or not
either or both of the partiea ahall remarry, it being underatood by
and between the partee hereto that thie Agreement ahall eurvive and
shall not be merged into any decree, judgment, or order of divorce
or separation. It ie apecifically agreed, however, that a copy of
this Agreement or the aubatance of the proviaiona thereof, may be
incorforated by reference into any divorce, judgment or ite decree.
Thie ncorporation, however, shall not be regarded aa a merger, it
being the apecific intent of the partiee to rermit this Agreement
to survive anr judgment and to be forever b nding and concluaive
upon the part es.
12. MUTUAL RELEASE. Husband and Wife do hereby mutually remiae,
releaoe, quit claim or forever discharge the other and the estate
of ouch other, for all time to come, and for all purpooes
whatsoever, from any and all righte, title and intereat, or claima
in or againat the estate of such other, of whatever nature and
wherever eituate, which he or ahe now has or at anytime hereafter
may have against ouch othor, the estate of ouch other or any part
thereof, whether arioing out of any former acts, contracts,
engagements or liabilities of ouch other or by way of dower or
curtesy of claima in the nature of dower or curteay, or widow's or
widower's rights, family exemption or eimilar allowance or under
ths intestate lawal or the right to take againat the spouse'a willI
or the right to treat a lifetime conveyance by the other aa
testamentary or all or other righto of the aurv ving apouse to
participate in a deceaaed apouee's eatate, whethor arising under
the laws of Pennsylvania, any otate, commonwealth or territory of
the United States, or any other country or any right which either
party may now havft or at anytime hereafter have for past, preoent
or future aupport or maintenance, alimony, alimony pendente lite,
counsel feeo, coste or expenoes, whether ariaing aa a result of the
marital relation or otherwiae, eKcept and only except all righta
and agreements and obligetiona of whatooever nature arising or
which may arise under thia Agreement or for the breach of any
proviaion thereof. It 1 s the intention of Husband and Wife to give
to each other by the execution of this Agreement a full, complete
and general releaee with respect to any and all property of any
kind or nature, real, personal or mixed, which the other now owns
or may hereafter acquire, except and only except all rights and
agreements and obligations of whatsoever nature arising or which
may ariBe under this Agreement or for the breach of any provioion
thereof.
13. COUNSEL FBBS. Each party individually covenanto and agrees
that he or she will individually asoume the full and oole
reoponsibility for legal expenseo for his or her attorney, if any,
and court costs in connection with any divorce action which may be
brought by either party and shall make no claim against the other
for ouch costs or fees.
14. ADDITIONAL INSTRUMENTS. Each of the parties shall, from time
to time, at the request of the other, execute, acknowledge and
deliver to the other party any and all further instruments or
documente that may be reaoonably required to give full force and
effect to the provisions of thio Agreement.
15. MODIFICATION OR WAIVER. A modification or waiver of any of
the provisions of thie Agreement shall be effective only if made in
writing and executed with the same formality ae thio Agreement.
The failure of either party to insist upon the otrict performance
of any of the provisions of this Agreement shall not be conotrued
as a waiver of any subsequent default of the same or similar
nature.
16. ENTIRE AGREEMENT. This Agreement contains the entire
underotanding of the partiee and there are no repreoentations,
warranties, covenants or undertakings other than those expresoly
oet forth herein.
17. SEPARATE PARAGRAPHS. It is epecifically understood and agreed
by and bstwesn the parties thereto that each paragraph hereof shall
be deemed to be a separate and independent agreement.
lB. BREACH. If either party breaches any provision of this
Agreement, the other party ehall have the right, at his or her
election, to oue for damages for ouch breach or seek such other
remedies or relief as may be available to him or her and the party
breaching thio Agreement shall be responsible for payment of legal
fees and coete incurred by the other in enforcing the rights under
this Agreement, or in eeeking ouch other remediee or relief as may
be available to him or her,
19. CONTROLLING LAW. Thio Agreement shall be construed under the
laws of the Commonwealth of pennoylvania.
20. INVALIDITY OF PROVISIONS. If any term, condition, clause or
provieion of this Agreement shall be determined or declared to be
void or invalid in law or otherwiee, then only that term,
condition, clause or provision shall be stricken from this
Agreement, and, in all other respects, this Agreement ohall be
valid and continue in full force, effect and operation,
Nolarlal Seal
Karen F. Oyer., Notary Public
Carll.'e Boro. Cumberland County
My Comml..lon E,plre. March 1 B. 109P
COMMONWEALTH OF PENNSYLVANIA I
I ss
COUNTY OF CUMBERLAND I
.--
On thie, the /'l't" day of JIJ"fJ. , 1995, before me, the
undersigned of~ personally appeared Wanna B. Emig, known to me
(or satisfactorily proven) to be the person whoae name is
subecribed to the within instrument, and acknowledged that ohe
executed ths eame for the purpoee therein contained.
IN WITNESS WHEREOF, I have hereunto Bet my hand and notarial eeal.
~/IJ J :6ye1f~__
N tary Public ,.
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Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENN8YLVANIA
:
: 95-3240 CIVIL TERM
:
: CIVIL ACTION - LAW
:
KENNETH E. EMIG, JR.,
Plaintiff
v
WANNA B. EMIG,
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY I
Transmit the record, together with the following information, to
the Court for entry of a divorce decree:
1. Ground for Divorcel Irretrievable breakdown under Section
(X)3301(c) ()3301(d)(I) of the Divorce Code. (Check applicable
section. )
2. Date and manner of service of the Complaint I June 16, 1995/
by personal delivery.
3. (Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by
Section 3301(c) of the Divorce Codel By Plaintiff I September 29,
1995/ by Defendant: December 27, 1995.
(b) (1) Date of execution of the Plaintiff's affidavit
required by Section 3301(d) of the Divorce Codel
(2) Date of eervice of the Plaintiff's affidavit upon the
Defendant:
/
4. Related claims pending I Subject to Separation Agreement dated
June 19, 1995, incorporated into Divorce decree.
.
5. Date and manner of servioe of the Notioe of Intention to File
Praeoipe to Transmit Reoord, a oopY of whioh is attached, if the
deoree is to be entered under Seotion 3301(d)(l)(i) of the Divoroe
Codel N/A
/
/
v' /
//7
, ,/\,
. Houoton, Esqu re
for Plaintiff
Broujoo, Gilroy & Houston, P.C.
4 North Hanover Street
Carlisle, PA 17013
717 - 243-4574
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KENNETH G. EMIG, JR. , , IN TilE COURT OF COMMON PLEAS OF
Plaintiff t CUMBERLAND COUNTY, PENNSYLVANIA
,
v I CIVIL DIVISION - LAW
I 95- .;2'-10
WANNA B. EMIG, I CIVIL TERM
Defendant I
I IN DIVOIlCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wioh to defend against the
claims set forth in the followLlg pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
entered against you by the Court. A judgment may also be entered
against you for any other claim or rel[ef requested in theoe papers
by the Plaintiff. You may loee money or property or other rights
important to you, including custody or visitation of your children.
When the grounds for divorce is indignitiee or irretrievable
breakdown of the marriage, you may requeet marriage counseling. A
list of marriage counselors io available in the prothonotarr I s
Office at the Cumberland County Courthouse, Carliole, Penn sylvan a.
IF YOU DO NOT FILl A CLAIM FOR ALIMONY, DIVIIION OF PROPIRTY,
LAWYER'I Fill OR IXPINIII, BIFORI A DIVORCE OR ANNULMENT II
ORANTID, YOU MAY LOll THI RIOHT TO CLAIM ANY OF THIM.
YOU IHOULD TAKI THII PAPIR TO YOUR LAWYER AT ONCI. IF YOU DO
NOT HAVI A LAKYER OR CANNOT AfFORD ONE, 00 TO OR TILIPHONI TII
orrICE liT rORTH BILOK TO rIND OUT WHIRE YOU CAN OIT LIGAL
HILP.
COUIlT ADMINISTRATOIl
CUMBEIlLAND COUNTY COUIlTHOUSE
CAIlLISLE, PENNSYLVANIA 17013
TBLBPHONEI 717 - 240-6200
tmlg,dlv
KENNETH G. EMIG, JR., . IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
v . CIVIL DIVISION - LAW
.
WANNA B. EMIG, . 95- CIVIL TERM
Defendant .
. IN DIVORCE
COHPLAINT
Plaintiff, Kenneth G. Emig, Jr., by and through his attorneys,
Broujos, Gilroy & Houston, P.C., sets forth the following.
1
Plaintiff, Kenneth G. Emig, Jr., is an adult individual residing at
One Westwood Drive, Mt. Holly Springs, Cumberland County,
Pennsylvania.
2
Defendant, Wanna B. Emig, is an adult individual residing at One
Westwood Drive, Mt. Holly Springs, Cumberland County, Pennsylvania.
3
The partiea were married on September 27, 1976, in Carlisle,
Cumberland County, Pennsylvania.
4
Plaintiff and Defendant have lived continuously in the Commonwealth
of Pennoylvania for at least eix months prior to the commenoement
of this action.
5
This action is not collusive.
6
There have been no prior aotions for divoroe or annulment in thie
or any other jurisdiction within the knowledge of the Plaintiff.
7
In accordance with Section 3301(c) of the Divorce Code, the
marriage between the partieo is irretrievably broken.
B
Plaintiff has been advised that counseling is available and that
Plaintiff may have the right to request that the Court require the
partieo to participate in counoeling.
WHEREFORE, the Plaintiff requests your Honorable Court to decree
that the Plaintiff be divorced from the Defendant.
BROUJOS.'/GJ.R
/ zhr; "
By (.. .
C C r stopher C. Ho ston,
Attorney for Plaintiff
4 North Hanover Street
Carlisle, PA 17013
717 - 243-4574
p.e.
EsqU re
I verify that the statements in the foregoing pleading are true and
oorreot. I underetand that falee statementa herein are made
eubjeot to the penalties of 18 PaCS 4904 relating to unsworn
falsifioation to authorities.
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KENNETH G. EMIG, JR.,
Plaintiff
I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I 95-3240 CIVIL TERM
I
I
I IN DIVORCE
v
WANNA B. EMIG,
Defendant
AFFIDAVIT OF SERVICE
I, Christopher C. Houoton, Esquire, being duly sworn according to
law do depose and state that a copy of the Complaint filed in the
above-captioned matter along a copy of a Notice to Plead and a
Notice of Availability of Marriage counseling was served on the
Defendant, Wanna B. Emig, by personal oervice, a copy of eaid
Said
return receipt evidencing delivery being attached hereto.
/"
/
eervice on June 16, 1995.
C r stoph C. Houston, Esqu re
Attorney for Plaintiff
Broujoo, Gilroy' "oueton, P.C.
4 North Hanover Street
Carliele, PA 17013
717 - 243-4574
Sworn and subscribed to
.J /,
before me this ~ day
of JA'1\J.O";r , 1996.
~~a'!pu&"~
,.~I.Ulal Soal
, lfC'l r Oyers. Nolarv Public
<i('t Uoro, Cwnbutlimd C:uunlV
. ';!Ion E).pilIlS Mindl In 1000
~
KENNBTH a. BMla, JR., I IN THB COURT OF COMMON PLEAS OF
plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
v I CIVIL DIVISION - LAW
I
WANNA B. EMla, I 95- '} ~ '({l CIVIL TERM
Defendant I
I IN DIVORCE
ACCEPTANCE OF SERVICE
I accept Bervice of the Complaint in Divorce.
(~J/G /1' J-
Date , I
LJ ___ /3 f.--j,"11 '
Wanna B. Emig -
One WeBtwood Drive
Mt. Holly SpringB, PA 17065
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KENNETH G. EMIG, JR., I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
v I CIVIL DIVISION - LAW
I
WANNA B. EMIG, I NO. 95-3240 CIVIL TERM
Defendant ,
, IN DIVORCE
AFFIDAVIT OF CONSENT
1. A comflaint in Divorce under Section 3301(c) of the Divorce
Code was f led on June 16, 1995.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and 90 days have elapsed from the date of filing the
Complaint.
3. I consent to the entry of a final decree in divorce.
4. I understand that if a claim for alimony, alimony pendente
lite, marital property or counsel fees or expenses has not been
filed with the Court before the entry of a final decree in divorce,
the right to claim any of them will be lost,
5. I understand that I may request marriage counseling and I
hereby waive any right to marriage counseling which is afforded me
under the law.
DATE'
I verify that the otatements made in this affidavit are true and
correct. I understand that false statements herein are made
eubject to the penaltiec of Ie Pa.C.S. Section 4904 relating to
unsworn falsification to authoriti~.
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KENNETH G. EMIG, JR. /
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KENNBTH G. EMIG, JR., , IN THB COURT OF COMMON PLEAS OF
Plaintiff , CUMBERLAND COUNTY, PENNSYLVANIA
,
v , CIVIL DIVISION - LAW
,
WANNA B. EMIG, , NO. 95-3240 CIVIL TERM
Defendant ,
, IN DIVORCE
~FIDAV!T OF CONSENT
1. A comrlaint in Divorce under Section 3301(c) of the Divorce
Code was f led on June 16, 1995.
2. The marriage of Plaintiff and Defendant io irretrievably
broken and 90 days have elapsed from the date of filing the
Complaint.
3. I consent to the entry of a final decree in divorce.
4. I understand that if a claim for alimony, alimony pendente
lite, marital property or counsel feeo or expenoes has not been
filsd with the Court before the entry of a final decree in divorce,
the right to claim any of them will be lost.
5. I understand that I may request marriage counseling and I
hereby waive any right to marriage counseling which is afforded me
under the law.
I verify that the statements made in this affidavit are true and
correct. I understand that false statements herein are made
eubject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to autho.itiea.
DATE' :)'/ Ul.t' '/5'
t./annn f3, ~'f?-
WANNA B. EMI
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BAOU.JOB, all_AOY Be HOUSTON, p,c.
ATTOANlEye AT LAw
4 NO"TH HANOVER eTRCET
CARLotaLIE. f8..NNaVL.VANIA .70.a
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Defendant
, IN THE COURT OF COMMON PLBAS OF
, CUMBERLAND COUNTY, PBNNSYLVANIA
,
, CIVIL ACTION - LAW
,
, 95-3240 CIVIL TERM
,
, IN DIVORCE
KBNNETH G. EMIG, JR.,
Plaintiff
v
WANNA B. BMIG,
ORDER OF COURT
AND NOW, this
21"
day of
tu....
,
1995, upon a
stipulation and Agreement for Cuotody, it is hereby ordered and
direoted as followel
A. The parties shall have shared legal cuotody of the minor
ohildren.
B. The Plaintiff shall have primary physical custody of the minor
children.
C. The Defendant shall have partial custody rights of the
ohildren at such times ao the parties may agree.
By the Court,
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KENNETH G. EMIG, JR.,
Plaintiff
Defendant
I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I CIVIL ACTION - LAW
I
I 95-3240 CIVIL TERM
I
I IN DIVORCE
v
WANNA B. EHIG,
STIPULATION AND AGREEMENT IN CUSTODY
AND NOW, comeo the Plaintiff, Kenneth G. Emig, Jr., by and through
his attorney, Christopher c. Houston, Esquire, and the Defendant,
Wanna B. Emig, who stipulate and agree as followsl
1
Plaintiff and Defendant are the parents of Meliasa K. Emig, date of
birth March 15, 1980, and Michelle M. Emig, date of birth September
19, 1983.
2
The parties desire to enter into a Stipulation and Agreement
pertaining to the custody of the aforeeaid minor children and do
further stipulate and agree that the termo and provisions of this
stipulation and Agreement shall be entered as an Order of Court,
with the terms thereof being ao folloWSI
A. The parties shall have ohared logal custody of the minor
children.
B. The Plaintiff shall have primary physical custody of the minor
children.
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