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HomeMy WebLinkAbout95-06059 ,7,'j,;'.,\-:,,' ~Jf~~. ~~'c tt~\,'. . ~;,!':'.:' J?' ~~ if~;;5\. ',~il:J'> . ')~;~fC;; , -v -;-F.'oJ. ; '\1',. ,,~j~, ' i: " -.. "~ ,;,;- ""r.-,"'- ii' .i"- ,~ -,- i: .; .~ ~., ,Ji:'J 1:,_-1. . ~::> ~ tf:;,r,::; ~;o- ..,~. ~:~~l , i}{:';' ~",,,,: J.1-'i!.::- i~,;~:' ~~i>-,;:' :ri'_::' JESSICA BERRY, Plaintiff I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA I I C}S-r. I NO. 0.05Q CIVIL m5 I I IN CUSTODY v. ROBERT BERRY, Defendant CUSTODY ORDER DD liON, this .20'" day of , 1995, upon ()v.. " uc. agreement and stipulation of the parties, the following is hereby ordered and decreed, with respect to the minor child, Tyler H. Berry, born August 9, 1994. 1. The parties shall share legal and physical custody. 2. The exchanges of physical custody are to take place as follows I The child, Tyler M. Berry, shall be in the physical care of mother, Jessica Berry, with the exception of the following time periods I a. every other week for a period of three days, so long as father, Robert Berry, providee at least 48 hours advance notice : of the three day time frame. The first week of thie alternating schedule begins the week of October 30, 1995; b. during thoee times that mother is at work or attending classes, with the exception of Wednssdays, the child shall be with father or with father's mother, Doreen Berry; c. the holiday schedule shall provide for the following alternating holidayul i; New Years Easter Memorial Day I' i! Fourth of July Child's Birthday Labor Day Thanksgiving Christmas Eve Christmas Day d. The schedule will begin alternating holidays with the fathsr exercising custody on Thanksgiving 1995. e. The Christmas schedule will alternate from year to year with one parent having Christmas Eve from 5100 p.m. to Christmas morning at 11100 a.m., and the other parent having Christmas day from 11100 a.m. to 8100 p.m. Ths Christmas 1995 schedule will begin with mother having care of the child on the Christmas Eve time frame. Holiday schedules will take precedence over regularly scheduled visits. f. Except as described above for the Christmas holiday, the time either party exercises their holiday schedule shall be from 10100 a.m. to 8100 p.m. 3. The parties may mutually agree to times of physical custody other than those provided for in this Order. 4. The parties will make every effort to encourage a positive relationship with the other parent and will not make disparaging remarks about the other parent in the presence of the child. By the Court, --0~' A..d- / J. c. the holiday achedule ahall provide for the following alternating holidayal New Yeare Eaeter Memorial Day Fourth of July Child'e Birthday Labor Day Thankegiving Chrietmae Eve Chrietmae Day d. The echedule will begin alternating holidaye with the father exercieing cuetody on Thankegiving 1995. e. The Chrietmae echedule will alternate from year to year with one parent having Chrietmae Eve from 5100 p.m. to Chrietmae morning at 11100 a.m., and the other parent having Chrietmae day from 11:00 a.m. to 8:00 p.m. The Chrietmae 1995 echedule will begin with mother having care of the child on the Chrietmae Eve time frame. Holiday echedulee will take precedence over regularly echeduled vieita. f. Except ae deecribed above for the Chrietmae holiday, the time either party exercieee their holiday echedule ehall be from 10100 a.m. to 8100 p.m. 2. The partiee may mutually agree to timee of phyeical cuetody other than thoee provided for in thie Order. 4. The partiee will make every effort to encourage a poeitive relationehip with the other parent and will not make diaparaging remarke about the other parent in the preeence of the child. 5. The Defendant acknowledgee that he hae accepted aervice of the Cuetody Complaint and that he hae received a copy of thie Conaent Agreement and propoeed Order. JESSICA BERRY, I IN THE COURT OF COMMON PLEAS Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. 9s (,OS'? 1?r"... I CIVIL ~ ROBERT BERRY, I Defendant I IN CUSTODY CUSTODY COMPLAINT 1. The Plaintiff ia Jessica Berry, residing at 1205 Trindle Road, Carlisle, Cumberland County, PA, 17013. 2. The Defendant is Robert Berry, residing at 33 Valley Street, Carlisle, Cumberland County, PA, 17013. 3. The Plaintiff and Defendant have agreed to a custody arrangement for their son, Tyler M. Berry. 4. The child was not born out of wedlock. 5. The child is presently in the custody of the Plaintiff. 6. Since his birth on August 9, 1994, to October 1994, the child resided with Plaintiff, Jessica Berry, with Defendant, Robert Berry, with William and Doreen Berry and Ken Berry, at 33 Valley Street, Carliele, Cumberland County, PA, 17013. From October 1994 to October 18, 1995, the child resided with Plaintiff, Jessica Berry and at times with Defendant, Robert Berry, at 3101 Spring Road, Carlisle, Cumberland County, PA, 17013. From October 18, 1995 to the present, the child has been residing with Plaintiff, Jessica Berry, and Plaintiff's parents at 1205 Trindle Road, Carliole, Cumberland County, PA, 17013. Plaintiff, the mother of the child, io married. The father of the child io the Defendant, Robert Berry. He iB married. 7. The relationohip of Plaintiff to the child is that of biological mother. The Plaintiff currently resideo with the child and her parents. B. The relationohip of the Defendant to the child io that of biological father. To the beat knowledge of the Plaintiff, the Defendant resideo at 33 Valley Street, Carlisle, Cumberland County, PA, 17013. 9. Plaintiff hao not participated ao a party or witneso, or in another capacity, in other litigation concerning the custody of the child in thio or another court. Plaintiff has no information of any other cuotody proceeding concerning the child pending in a court of thio Commonwealth. 10. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or vioitation righto with reopect to the child. 11. The best intereot and permanent welfare of the child will be oerved by granting the relief requeoted, ao agreed upon by the parties. 12. Each parent whooe parental righto to the child have not been terminated and the peroon who has physical custody of the child have been named as parties to this action. No other persons are known to have or claim a right to custody or visitation of the child. f , ! 1 a- ';)- 11. ~ 0 0 rI) () () C) -.... lJ') 0 (() en .. " 0 - \j) ~= \I) C 11 11 ,-"- .. . It) ~ ~<:i ,.., , ~ In 0') c:J = ~ l-..J I- ..... =