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. SEP 28 1995 ~Qt-
vs.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY. PENNSYLVANIA
: CIVIL AcrlON - LAW
Michelle E. Nicholson,
Plaintiff
Robert L. Grosholz, Sr. and
Patricia A. Grosholz
Defendants
; NO. (]c, ,>uCf'O CIVIL TERM
: CUSTODY
PETITION
AND NOW, comes Michelle E. Nicholson. Plaintiff herein. by and through her
allorneys, Frey & Tiley, and makes the following statement:
J. Plaintiff is Michelle E. Nicholson, an adult individual. of 1410 Milford Street.
N.E., of Canton, Ohio.
2. Defendants are Robert L. Grosholz. Sr. and Patricia A. Grosholz. husband and
wife, adult individuals, of 5019 Muirfield Place, Mechanicsburg. Cumberland County.
Pennsylvania.
3. Defendants are the natural parents of Brian R. Grosholz. born
currently residing at 1410 Milford Street. N .E., of Canton. Ohio. Defendants are also the natural
parents of Plaintiff. who is now an adult individual.
4. Plaintiff and Defendants have entered into an agreement concerning the custody and
visitation of the aforesaid child, which agreement is attached hereto as Exhibit "A".
5. Plaintiff and Defendant agreed as a part of the Agreement that the Agreement should
be entered as an Order of Court as it is believed that the tenns of the agreement will best serve the
interests of the aforesaid child.
6. Defendants have joined in the execution of this Petition to confinn their desire that
the tenns of the Agreement be entered as an Order of Court.
CUSTODY AGREEMENT
,L
ENTERED INTO this 2 1 day of September, 1995
BETWEEN, Robert L. Grosholz, Sr., hereinafter referred to as "Father", and Patricia
A. Grosholz, , hereinafter referred to as "Mother", both of 5019 Muirfield Place, Mechanicsburg,
Pennsylvania,
AND Michelle E, Nicholson, of 1410 Milford Street, N.E., of Canton, Ohio,
hereinafter referred to as "Sister",
WHEREAS, Father and Mother are the parents of Brian R. Grosholz, bom
hereinafter referred to as "the child";
WHEREAS, the home of Father and Mother and the child is in Mechanicsburg,
Cumberland County, Pennsylvania;
WHEREAS, previous to the 1995-1996 academic year, the child allended high school in
Canton, Ohio, and Father and Mother believe that it is in the best interests of the child to be able to
complete his high school education in Canton, Ohio;
WHEREAS, Sister is the natural daughter of Father and Mother and is the full sister of
the child and lives in Canton, Ohio where Father and Mother wish the child to complete high
school;
WHEREAS, Father and Mother and Sister have reached an agreement whereby the child
wiIllive with Sister for the 1995-1996 academic year;
WHEREAS, Father and Mother and Sister desire to have said agreement entered as an
Order of Court having jurisdiction over the child to satisfy the requirements of the School District
in which the child is now allending classes;
NOW THEREFORE, in consideration of the mutual covenants, promises, and
agreements as hereinafter set forth, the parties agree as follows:
I . Mother and Father shall have joint legal custody of the child.
2. Sister shall have primary physical custody of the child through June, 1996.
3, Mother and Father shall have reasonable periods of partial or temporary custody
with the child.
4. Mother and Father agree that the exchange of the child in all cases shall occur at the
home of Sister with Mother and Father taking responsibility for the transportation of the child.
5. Mother and Father and Sister agree that after the end of June, 1996, Mother and
Father shall have primary physical custody of the child.
6. It is understood by Mother and Father that this Agreement shall be submilled for
incorporation into an Order of Court and may be modified by the Court of Common Pleas of
Cumberland County or any other Court having proper jurisdiction based on the laws in effect in
the jurisdiction.
nHr81T "".
INTENDING to be legally bound, witness our hand and seal the day and year first above
written, "...... . ... .
ah tll!/ld1V'l : /I';tll/'/( e~4 (SEAL)
t7 Robert L. Grosholz, Sr.
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,(,..ah<'.....~ ,,/ "'~""A'" /, (SEAL)
Patricia A. GroshoIf " '
~SEAL)
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