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Home My WebLink About95-03896 \ - ~ ~ 01 . ~ - d ~ ~ o ~ JI ~! 0- ; Do (YJI , ,- L() I '0- \ ~ CJ ~ ~\~ ':r :r- .. f ~ ~ => -, . Lr> en - ,~ .... ::;':;: . ..: N ~:%< ',:;:' :x: co.. ... '" - ...... I.' >4. -, ., ~ <' I'tl ,. .... ~ ., , , .... - " .. JUI. 2 4 /995; ,...-' , . IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA DAPHNE K. GUTSHALL, PETITIONER : CIVIL ACTION - LAW V. NO. 95- 3 ~'1c:... CIVIL TERM MICHAEL L. GUTSHALL, RESPONDENT CUSTODY ORDER OF COURT NOW, , 1995, upon consideration of the within Agreement, it is hereby ordered as follows: 1, PETITIONER and RESPONDENT shall share legal custody of their minor child, ERIC MICHAEL GUTSHALL, and pursuant to this grant of shared legal custody, each parent shall have equal access to all pertinent information and reports that may be generated by medical, educational, psychological and other professionals who msy work with their child, Each parent shall discuss major decisions effecting the child's well being in the areas of medical, educational, emotional, spiritual, social, and material needs with the opposite parent, 2, PETITIONER shall exercise primary residential custody of said minor children, RESPONDENT shall be entitled to exercise partial custody on alternating weekends, and one (1) evening per week at a date and time mutually agreed upon by the parties, 3, On holidays, the parties shall exercise shared physical , \ custody of the child as can be mutually agreed, 4, RESPONDENT shall exercise partial custody for one interrupted week, said week to be mutually agreed upon by the parties, 5, RESPONDENT shall kecp the child whenever the child is ill, for the first day, PETITIONER shall keep the child for the second day of said illness, 6, Such other exercises of partial custody may be scheduled hercafter as the parties may agree upon with due deference and respect to the child's interest, schedule and ultimate welfare, 7, Neither party shall do anything which may estrange the children from thc other parent, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love or respect for the other parent, J. Richard L, Webber, Jr" Esquire Michael L, Gutshall R,D, #2 Newville, PA 17241 e..,..~.... ,..",":"C,L 1/;;'<f/ ~.f. , . .J.!f'. 56. HJ LE S ~'Z lOr DAPHNE K. GUTSHALL, PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 95- H? ~ CUSTODY CIVIL TERM MICHAEL L, GUTSHALL, RESPONDENT PETITION FOR ENTRY OF AGREEMENT AND NOW comes the through her attorney, Petition pursuant to following: Petitioner, DAPHNE K, GUTSHALL, by Richard L, Webber, Jr" and files Pa,R,C,P, No, 1915,7, averring and this the 1, Cumberland PA 17241, Petitioner is Daphne K, Gutshall, who resides in County, Pennsylvania, at 36 Windy Hill Road, Newville, 2, Respondent is Michael L, Gutshall, who resides in Cumberland County, Pennsylvania, at R,D, #2, Newville, PA 17241, 3, The Petitioner and Respondent are natural parents of ERIC MICHAEL GUTSHALL, born July 31, 1989, 4, On or about June 23, 1995, the parties entered into an Agreement regarding custody of the child, Said Agreement is attached hereto and incorporated by reference herein, 5, The best interest of the child would be served by the entry of an Order of Court reflecting the terms of the Agreement, WHEREFORE, Petitioner requests your Honorable Court to approve the attached Agreement and enter it as an Order of Court, Respectfully submitted, ,] l:./ A'1/~1'.1M- Richard L, Webber, Jr, Attorney for Petitioner 366 Green Spring Road P,O, Box: 40 Newville, PA 17241-0040 (717) 776-6566 ""~' .-,",-..-, '.c_ IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA ,i I DAPHNE K. GUTSHALL, PETITIONER CIVIL ACTION - LAW V, NO, 95- 3\''/(. CIVIL "ERM MICHAEL L, GUTSHALL, RESPONDENT CUSTODY THIS STIPULATION AND AGREEMENT is mllde this }.:3____ flllY 01' June , 1995, b~' IInd between DAPHNE 1\, UUTSHAI.I.. hereinafter referred to "s "PETITlONEIl," IInd HICHAEI, I.. UUTSHAI.I., hereinafter referred to as "IlESI'ONIlENT," I, PETITIONER and RESPONIlF.NT lire the n"tlll'" 1 IHlI'ents 01' ERIC MICHAEL GUTSHALL. born July 31, 19M9, 2, PETITIONER and RESPONDENT were lII"r'r'i(.d ,IUI\l! Iii, IIIM.I, at Newville, Cumberland Count~., Penns~'lvanill. II rill sel'"r"ted on 01' about ) v 0"'1" ) '3 1'/ IJ:.'- ) 3, WiLh the exception of this IIclion, neilher pllrty hllH participated as II pllrt~. in other 1 itigntion concerning the custody of the child in lhis or nny olher court, 4, None 01' lhe parties hilS infol'mlll.ioll 01' II cIIHtod~' proceedin!l concerninll the child,'..n pendinl( in II COIII'1. within 01' outside this Commolll<elllth, 5, None of the pUI'Lies Jwows of UIIY P'H'SOIl 1I0L a purt~. to DAPHNE K, GUTSHALL AD))RESS 3G (,../~.(? H'/I (l~'-I /11....-;11. ),,,, , "I)-LII R,D, II:.! Newville, PA 17:.!41 DATE ~/J3/ftr "f f'~"'.' 7/31/89 to 61H/fr the proceedings who hus physicul cusLody of Lhe children or claims to have custody or visitlltioll l'il{hts ,dth I'espect to the children, 6, During the past five (51 years, the children have resided with the following persons and at the following addresses: NAME DAPHNE K, GUTSHALL and MICHAEL L, GUTSHALL 7, The parties have reuched an agreement with respect to the custody of their minor children and desire to reduce and incorporate their agreement to an order of court, 8, The parties further agree that, in procuring this Agreement, there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other, NOW. THEREFORE, the parties intend to be legally bound and waiving their right to be present when this Agreement and Order are presented and executed, hereby stipulate and agree that the Court may enter the following Order of Court in the above captioned case: ORDER OF COURT NOW, t 1995, upon consideration of the within Stipulation and Agreement, 5, RESPONDENT sllld I K""P 1.1... ch I I d whellever the I i I I I r \ l I it is hereby ordered as follows: 1, PETITIONER alld RESPONDENT shalJ shnre le~nJ custody of their minor child. EIHC MICHAEL GUTSHAt.I" and pursunnt to this ~ranl. 01' shllred Iel,lnl clIstod)', each parent shall have eqllal Ilccess 1.0 III I pertillelll. illformation and reports that may be ~I'"C"lll.l'd hy medical. educntional, ps)'chologlcnl nlld ol.he,' professionals who mny work with theil' chi Id, Elich parent shall discuss major decisiolls "rl'''cl.llI~ I.Ill' child's well bein~ in the arclls 01' medlclll, educational. emotional, spiritllul. soCilll, IIl1d IOIlI."I'illl needs with the opposite parent, 2, PETITIONER shall exercise primllry ,'esideIlUIII custody of said minor children, RESPONDENT Kllll11 he entitled to exercise partilll clIsl.od)' 011 IIltl'I'lulling weekends, and one (1) eveninl( pel' weeK III. n dllte, IInd time mutllally ugreed upon by the pllrtles, 3, On holidays, 1.Ill' pllrl.les shllil excl'cise shllred physical custod)' 01' I.he chi Id ilK ellll Ill' mlltllaIJ)' agreed, _\, RESPONDENT shill I eXI','ciMl' plIl'lllll custod)' for one illtel'rllplNI w,'cll, slIid w"..11 1.0 be mutuall)' agreed upon by the PIII'l.i,'s, child is ill, 1'01' I.h.. I'lrsl. dll)', PETITIONER shall keep ---.. , the child for the second day of said illness, 6, Such other exercises of partial custody may be scheduled hereafter as the parties may agree upon with due deference and respect to the child's interest, schedule and ultimate welfare, 7, Neither party shall do anything which may estrange the children from the other parent, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love or respect for the other parent, By the Court, J, IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, do execute this Stipulation and Agreement, WITNESS: JJ~del1 rJ;tLthjll~ DAPHNE K, GUTSHALL ]lvJl~f .I..4:J;jlJJ MlCHAEL L, GUTSHALL I verif~' Lhat. t.he st.nt.ements made in t.his Stipulnlion nre true and correct, I undel'stand thnt fnlse statements herein are made subject to the pennlties of LB Pa,C,S,A, Sect.ion 4904 relating to unsworn falsificntion to authorities, Da te: ..QurZ P /JiW9!J1i ~~li~/j'L~ Daphne K, Gutshall, Petitioner 1 verify that the statements made in this Stipulation are true and correct, I understnnd that false statements herein are made subject to the penalties of 18 Pa,C,S,A, Section 4904 relating to unsworn falsification t.o authorities, Date: JU'1e .").3; Iqq~ 17/tckaeJ LAJ-J?J1J Michael L, Gutshall, Respondent