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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
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STATE OF PENNA. 1t
DEDDRAH J. NEIDIQI,
11.
Plaintiff 95-6322 19 k
,
THOMAS A. NEIDIQI, JR,
Defendant
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DECREE IN
DIVORCE
AND NOW, ....... Fw?......'.yj.. . • 19 .9!' .. , it is ordered and K
decreed that Deborah J. Neidigh plaintiff,
and ................ ?hanas• n.• Neldigh,, Jr,.... .... .... • defendant,
are divorced from the bonds of matrimony. !!K
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The court retains Jurisdiction of the following claims which hnve
been raised of record in this action for which a final order has not yet j .
been entered:
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Stipulation for CLstody and y
Separation Agreanent- incorporated herein. ,IS
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SEPARATION A(D EHAMIsNT
THIS IS AN AGREEMENT made this day of LL'?-? G l 1995, by and
between Thomas A. Neidigh Jr.,of Carlisle, Cumberland County,
Pennsylvania, (hereinafter referred to as Husband) and Deborah J.
Neidigh, of Carlisle, Cumberland County, Pennsylvania, (hereinafter
referred to as Wife).
WHEREAS, Husband and Wife were married on March 6, 1999 in
Carlisle, Cumberland County, Pennsylvania ; and
WHEREAS, various differences have arisen between Husband and Wife,
whereby they have been living separate and apart since March 18,
1995; and
WHEREAS, the parties have agreed to maintain separate and permanent
domiciles and to live apart from each other; and
WHEREAS, the parties desire to enter into an amicable settlement to
provide for all of the property rights of the parties and to
dispose of the rights and obligations of each to the other in
respect to support, maintenance, alimony, counsel fees, equitable
distribution, and all other rights and obligations under the
Divorce Code of 1980, as amended, and it is the intention and
agreement of the parties that this Agreement be a full, complete
and final settlement of all of those rights and obligations under
said Divorce Code; and
NOW, THEREFORE, for and in exchange of mutual considerations, and
intending to be bound by the provisions hereof, the parties agree
that their recitals form a part of this Agreement and waive any
right to counseling under the Divorce Code of 1980, as 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 follows:
1. SNPARATION. The parties agree that it shall be lawful for each
party, at all times hereafter, to live separate and apart from the
other, at such place or places as he or she may, from time-to-time,
choose or deem fit. Each party shall be free from interference,
authority or contact by the other, as fully as if he or she were
single and unmarried, except as may be necessary to carry out the
provisions of this Agreement and as may be necessary to exchange
information that pertains to the parties, minor child. Neither
party shall molest the other or attempt to endeavor to molest the
other, nor compel the other to cohabit with the other, or in any
1
way harass or malign the other, nor in any way interfere with the
peaceful existence, separate and apart, from the other.
2. REAL !STATE. Husband and Wife own no real estate in common as of
March 18, 1995. Any real estate purchased after that date by either
individual is the sole property of that individual.
3. AUTONDBILES. Husband and Wife agree to sell the 1992 Ford
mustang, sharing equally the proceeds therefrom. The parties will
divide equally the insurance and loan payments for the Ford Mustang
through April 23, 1995, after which Husband will assume all
payments and expenses including any loan obligation to DAFCU
remaining after the sale of the Ford Mustang. Husband will not
operate nor permit the Ford Mustang to be operated unless he
purchases it outright at the agreed upon selling price and pays to
wife her one-half share of that price. Wife shall have as her sole
and exclusive property, title to and possession of the 1993 Pontiac
Grand Am. Each party shall indemnify and hold the other harmless
from any liability on any loan encumbering the vehicle, cost of
repairs, maintenance, registration, insurance and/or inspection of
the vehicle which each is or may be taking as his/her sole and
exclusive property.
4. PERSONAL PROPERTY. The parties have divided or have agreed to a
division of their personal property which includes bank accounts,
certificates of deposit, life insurance policies, jewelry,
clothing, furniture and other personal items. After the aforesaid
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 possession of Wife
shall be her sole and separate property. Each party forever
renounces whatever claims he/she may have with respect 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 signing of this Agreement.
5. PENSION/RBTIRRMM PLANS. Wife hereby releases any and all
claims or demands she may have on Husband's pension or retirement
plans. Husband hereby releases any and all claims or demands he may
have on Wife's pension or retirement plans.
6. DEBTS. Husband will pay all utilities and phone charges arising
as of March 16, 1995 from the rented property located at 592 West
Louther Street, Carlisle. Husband will pay $320.00 per month for
the consolidated loan with IBM Pennsylvania Employees Federal
Credit Union. The balance of said loan as of March 18, 1995 totals
$9,500.00 and is to be paid off by January, 1998. In consideration
for assuming the consolidated loan payments exclusively, Husband
agrees to pay to Wife and Wife agrees to receive $150.00 each
2
month as child support beginning April 1, 1995. The parties
represent and warrant to each other that neither has incurred any
other debts nor made any other contracts for which the other or
his/her estate may be liable, from date of separation forward.
Neither party shall contract nor incur any debt or liability for
which the other or his/her property or estate might be responsible
the
agrees and se of debts/obligations r not a incurred claims by made aother.
other because
7 L+ND ?T TL-iW o@6"lVW-rV r TTQ BQPPORT 07 8POQ8i. The parties
waive any and all right to receive from the other any payment of
alimony, alimony pendente lite, and/or spousal support.
8. UFFECTIVQ DRTR. The effective date of this Agreement shall be
the date of execution by the parties as 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.
9. DIVORCE. The parties agree that should either party file a
Complaint in Divorce, claiming that the marriage is irretrievably
broken under the no-fault mutual consent provision of
Section 3301(c) of the Pennsylvania Divorce Code, then both
parties agree to execute any and all affidavits or other documents
necessary for the parties to obtain an absolute divorce pursuant to
Sections 3301(c) of the Divorce Code including waiver of all rights
to request Court ordered counseling. It is agreed and understood
between the parties that in the event a divorce proceeding is filed
by either party in any other jurisdiction, that the parties shall
not contest, but instead consent to such proceedings and shall
execute any and all documents necessary so as to proceed with and
obtain an absolute and final divorce.
10. IKCORPORATION INTO DECRBB. Should a decree, judgment or order
of separation or divorce be obtained by either of the parties in
this or any other state, country, or jurisdiction, each of the
parties hereby consents and agrees that this Agreement and all of
its covenants shall not be affected in any way by any such
separation or divorce; and that nothing in any such decree,
judgment, order or further modification and revision thereof shall
alter, amend or vary any term of this Agreement, whether or not
either or both of the parties shall remarry, it being understood by
and between the parties hereto that this Agreement shall survive
and shall not be merged into any decree, judgment, or order of
divorce or separation. It is specifically agreed, however, that a
copy of this Agreement or the substance of the provisions thereof,
may be incorporated by reference into any divorce, judgment or its
decree. This incorporation, however, shall not be regarded as a
merger, it being the specific intent of the parties to permit this
3
Agreement to survive any judgment and to be forever binding and
conclusive upon the parties.
11. MUTUAL AELEABE. Husband and Wife do h
release, quit claim or forever discharge tt
of such other, for all time to come,
whatsoever, from any and all rights, title a
in or against the estate of such other, e
wherever situate, which he or she now has c
may have against such other, the estate of
thereof, whether arising out of any fo
engagements or liabilities of such other
curtesy of claims in the nature of dower or
widower's rights, family exemption or simi
the intestate laws; or the right to take aga
or the right to treat a lifetime convey
FeeM n.n?nf ?.-.. nr n11 r.r nthnr rinhta of tl
ireby mutually remise,
e other and the estate
and for all purposes
nd interest, or claims
if whatever nature and
r at anytime hereafter
such other or any part
rmer acts, contracts,
or by way of dower or
curtesy, or widow's or
lar allowance or under
Lnst the spouse's will;
ance by the other as
iP surviving spouse to
participate in a deceased spouse's estate, whether arising under
the laws of Pennsylvania, any state, commonwealth or territory of
the United States, or any other country or any right which either
party may now have or at anytime hereafter have for past, present
or future support or maintenance, alimony, alimony pendente lite,
counsel fees, costs or expenses, whether arising as a result of the
marital relation or otherwise, except and only except all rights
and agreements and obligations of whatsoever nature arising or
which may arise under this Agreement or for the breach of any
provision thereof. It is the intention of Husband and Wife to give
to each other by the execution of this Agreement a full, complete
and general release 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 arise under this Agreement or for the breach of any provision
thereof.
12. COUNSEL PEES. Each party individually covenants and agrees that
he or she will individually assume the full and sole responsibility
for legal expenses for his or her attorney 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 such costs or
fees.
13. ADDITIONAL INBTRUMMS. Each
to-time, at the request of the
deliver to the other party any
documents that may be reasonable
effect to the provisions of this
of the parties shall, from time-
other, execute, acknowledge and
and all further instruments or
required to give full force and
Agreement.
4
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14. MODIFICATION OR WAIVER. A modification or waiver of any of the
provisions of this Agreement shall be effective only if made in
writing and executed with the same formality as this Agreement. The
failure of either party to insist upon the strict performance of
any of the provisions of this Agreement shall not be construed as
a waiver of any subsequent default of the same or similar nature.
15. WTIRS AGREEMENT. This Agreement contains the entire
understanding of the parties and there are no representations,
warranties, covenants or undertakings other than those expressly
set forth herein.
16. @EPARATE PARAGRAPHS. It is specifically understood and agreed
by and between the parties thereto that each paragraph hereof shall
be deemed to be a separate and independent agreement.
17. BRRACK. If either party breaches any provision of this
Agreement, the other party shall have the right, at his or her
election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her and the party
breaching this Agreement shall be responsible for payment of legal
fees and costs incurred by the other in enforcing the rights under
this Agreement, or in seeking such other remedies or relief as may
be available to him or her.
le. CONTROLLING LAN. This Agreement shall be construed under the
laws of the Commonwealth of Pennsylvania.
19. INVALIDITY OF PROVISIONS. If any term, condition, clause or
provision of this Agreement shall be determined or declared to be
void or invalid in law or otherwise, then only that term,
condition, clause or provision shall be stricken from this
Agreement, and, in all other respects, this Agreement shall be
valid and continue in full force, effect and operation.
20. BINDING NATURE. Except as otherwise set forth herein, this
Agreement shall be binding and shall inure to the benefit of the
parties hereto and their respective heirs, executors,
administrators, successors and assigns.
6
4 .7
IN NITNN88 NURROY, the parties have hereunto set their hands and
seals the day and year first above written.
NITNXBs
i V
Thomas A. Neidigh, Jr.
j D borah J Neidigh 'T
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DEBORAH J. NEIDIGH,
Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
THOMAS A. NEIDIGH, JR,, : 95 - 6322 CIVIL TERM
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following Information, to the Court for entry of a divorce
decree:
1. Ground for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code.
2. Date and manner of service of the Complaint: November 7, 1995. U.S. Postal Service,
Certified mall, Return Receipt.
3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code:
By Plaintiff; February 9, 1996; by Defendant: February 10,1996.
4. Related claims pending:
(a) Stipulation for Custody,
(b) Separation Agreement.
4Da - X?,C
Baird, Esquire
Attomey for the Plaintiff
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Deborah J, Neldigh, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v : CIVIL ACTION - LAW
Thomas A. Neidigh, Jr., :95- CIVIL TERM
Defendant
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against the claims set forth In the following
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 relief requested in these papers by
the Plaintiff, You may lose money or properly or other rights Important to you, including custody or
visitation of your children.
When the grounds for divorce is Indignities or irretrievable breakdown of the marriage, you may
request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office
at the Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S
FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY
LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 240-6200
Deborah 1. Neidigh, : IN THE COURT OF COMMON PLEAS OF
Plaintiff s CUMBERLAND COUNTY, PENNSYLVANIA
v s CIVIL DIVISION - LAW
Thomas A. Neidigh, Jr., :95-e"3.')') CIVIL TERM
Defendant s
s IN DIVORCE
COMPLAINT
Plaintiff, Deborah ). Neidigh, by her attorney, Lindsay D. Baird, Esquire, sets forth the
following:
Plaintiff, Deborah 1. Neidigh, is an adult individual residing at 226 Walnut Bottom Road,
Carlisle, Cumberland County, Pennsylvania.
Defendant, Thomas A. Neidigh, Jr., is an adult Individual residing at 592 West Louther
Street, Carlisle, Cumberland County, Pennsylvania.
The parties were married on March 6, 1994, In Carlisle, Cumberland County, Pennsylvania.
4
Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for
at least six months prior to the commencement of this action.
5
This action is not collusive.
6
There have been no prior actions for divorce or annulment In this or any other jurisdiction
within the knowledge of the Plaintiff.
In accordance wilh Section 3301(c) of the Divorce Code, the marriage between the parties
is Irretrievable broken.
8
Plaintiff has been advised that counseling Is available and that Plaintiff may have the right
to request that the Court require the parties to participate in counseling.
WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be
divorced from the Defendant.
L
V indsay D. rd, Esquire
Attorney for the Plaintiff
37 S. Hanover Street
Carlisle, PA 17013
717 • 243.5732
i verify that the statements in the foregoing pleading are true and correct. 1 understand that
false statements herein are male subject to the penalties of IS PaCS 4904 relating to
unsworn falsification to authorities.
n D. Bair ,E uire
DEBORAH J. NEIDIGH, t
Plaintiff t
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V. :
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THOMAS A. NEIDIGH, JR., t
Defendant s
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95-6322 CIVIL TERM
1 ORDER OF COURT
AND NOW, this I0 day of February, 1996, upon consideration
of the attached custody stipulation with respect to the parties,
child, Erin Alexandra Neidigh, born December 9, 1994, the terms of
the stipulation are entered as an order of court.
BY THE COURT,
Lindsay Dare Baird, Esq.
37 South Hanover Street
Carlisle, PA 17013
Attorney for Plaintiff
Thomas A. Neidigh, Jr.
P.O. Box 463
Boiling Springs, PA 17007
Defendant
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Deborah J. Neldigh, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v : CIVIL ACTION - LAW
Thomas A. Neidlgh, Jr., : 95.6322 CIVIL TERM
Defendant
CUSTODY/VISITATION
ORDER OF COURT
AND NOW, this day of 1996, it is ordered that Deborah J. Neldigh,
Mother, has legal custody and primary physical custody of the minor child Erin Alexandra
Neidigh, bom December 9, 1994.
AND, It Is further ordered that Thomas A. Neidigh, Jr., Father, has unlimited visitation with the
said minor child at either the Mother's residence or at the residence of the maternal grandmother
situated at 524 Hillcrest Drive, Carlisle, Pennsylvania.
BY THE COURT,
J.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Deborah J. Neidigh,
Thomas A. Neldigh, Jr.,
Defendant
Plaintiff
95 - 6322 CIVIL TERM
CUSTODY/VISITATION
STIPULATION FOR CUSTODY
STIPULATION made this _- day of February, 1996, between Deborah J. Neldigh,
hereinafter referred to as Mother, and Thomas A. Neidigh, Jr., hereinafter referred to as Father.
WHEREAS, the above-named Mother and Father had bom to them the following child on the
following dale:
NAME BIRTH DATE
Erin Alexandra Neidigh December 9, 1994
AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the
custody of the above-sold child and to the visitation rights of the non-custodial parent:
NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and
Father hereby stipulate that:
1. The Mother shall have legal custody of the child.
2. The Mother shall have primary physical custody of the child.
3. The Father shall have visitation as follows: Visitation shall be unlimited at the
residence of the Mother or at the residence of the child's maternal grandmother, 524
Hilicrest Drive, Carlisle, Pennsylvania.
4. The Mother, if she desires to relocate a distance more than one hundred miles from
her present location, shall not do so until suitable modifications shall have been made
In the arrangements set forth in paragraph 3, supra.
TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this
Stipulation and desire to have the Stipulation entered as an Order of Court.
Witness:
Indsay Belyd/D ,?sq.
Q.0 ???
LLIWI
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Deborah J, Neldigh, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Thomas A. Neldigh, : 95 - 6322 CIVIL TERM
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE
I, Lindsay Dare Baird, Esq., being duty sworn according to law do depose and state that a copy
of the Complaint filed in the above-captioned matter along with a copy of a Notice to Plead and a
Notice of Availability of Marriage Counseling was served on the Defendant, Thomas A. Neldigh,
Jr„ by Certified Mail - Return Receipt Requested, a copy of said return receipt evidencing
delivery being attached hereto. Said service on November 7, 1995.
'L
Lindsay D. Baird, Esquire
Attorney for Plaintiff
37 S. Hanover Street
Carlisle, PA 17013
717 - 243.5732
Swom and Subscribed to
before me this 7th day
of February,1996.
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Notary Public
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Deborah J. Neidigh, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v
Thomas A. Neldigh, Jr.,
Defendant
CIVIL ACTION - LAW
95-8322
CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
November 3, 1995.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing the Complaint.
3. 1 consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unswom falsification to authorities.
DATE: - _t ` b 16 IftJ
Deborah J. Neidigh
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Deborah J. Neidigh, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v
Thomas A, Neidigh, Jr.,
Defendant
CIVIL ACTION - LAW
95 - 8322
CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER i 3301(c( OF THE DIVORCE CODE
1. 1 consent to the entry of a final decree of divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of property, lawyers fees or
expenses If I do not claim them before a divorce is granted.
3. 1 understand that I will not be divorced until a divorce decree Is entered by the Court and that a
copy of the decree will be sent to me immediately after it is filed with the prothonotary.
I verify that the statements made In this affidavit are true and correct. 1 understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom
falsification to authorities.
DATE: `1 ?4&& 6L1 -
Deborah J. Neidigh
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Deborah J. Neldigh, ; IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
Thomas A. Neldigh, Jr.,
Defendant
v
CIVIL ACTION - LAW
CIVIL TERM
IN DIVORCE
95 - 6322
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
November 3, 1995.
2. The marriage of Plaintiff and Defendant is Irretrievably broken and ninety days have
elapsed from the date of filing the Complaint.
3. 1 consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
I verify that the statements made In this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 16 Pa.C.S. Section 4904 relating to
unswom falsification to authorities.
2-lo Thomas A. Neidigh, Jr.
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Deborah J. Neldigh,
Plaintiff
Thomas A. Neidigh, Jr.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
95 - 8322 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER! 3301(c) OF THE DIVORCE CODE
1. 1 consent to the entry of a final decree of divorce without notice.
2. 1 understand that l may lose rights concerning alimony, division of property, lawyer's fees or
expenses If I do not claim them before a divorce Is granted.
3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a
copy of the decree will be sent to me Immediately after it Is filed with the prothonotary.
I verify that the statements made In this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom
falsification to authorities.
DATE: IU - L? ?i:%? l1 J 1/
homes A. eldigh, Jr.
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DEBORAI1 J. DITMNR (NEID161I),
I'laintiff/Respondent
V.
'T'HOMAS A. NFIDIGI I, JR.,
Defendant/l'ctitioncr
IN '1'1ll: COURT. OF COMMON PLEAS OI:
CUMBERLANI) 0)UNTY, PH,NNSYLVANIA
NO. 95.6322 C'IVILTERM
CIVIL ACT10N - LAW
CUSTODY/VISITATION
ORDER OF COUNT
AND NOW, thisalhil day of _-Januar 1000, upon presentation
and consideration of the attached petition, it is here l directed that the parties and their
respective counsel appear before --drlbar Esquire, the
conciliator, at, Cumb-c ,_?? hWse , r-1i4i F1 Cumberland County,
pennsylvunia on the day of 2(100. at . ) _A.nn.,
for a Pre-I learing Custody Conference, At such conference an effort "ill he made to resolve the
issues in dispute, or if this cannot be accomplished, to define unu narrow the issues to he heard
by the Court and to enter into a temporary Order. Hither party may bring the child(REN) who is
subject to this custody action to the conference, but the child!children's attendance is not
mandatory. Failure to appear at the coiki-ence may provide grounds fur entry ofu temporary or
permanent Order.
FUR T I IF C0I1R'I':
Ily: U)AL t X.,,dj
L?J
`
qustody Conciliator t
YOU SIIOIII.D'I•AKI:'I'I IIS IIAplilt'IO YU(Jlt I.AWYI?R A'I' ONCI?, IF YOU DO NO'T'
I IAVI? A LAWYFIt Olt CANNOT AFFORDON F, 60-1'0 OR'I'FLI.I'l1ONIi TI IF OI•'I'ICI:
SI'T FORTII BELOW'I'U FIND (AFF WI II:RI? YOU CAN( F' LFGA,11F.P.
Cumberland County Bar Association
2 Liberiv Avenue
C'uthslc, I'A 17013
(717) 249-3166
t. , .t
OU !!i'l 3 i Pl I
CUPJ, a +_ !iY
AMI RICANS WITH DISABILITIES ACT Qh 19911
The Court 01' Common Pleas of Cumberland County is required by low Ui comply with
the Americans with Disabilities Act of 1990. For information about accessible fhcililies and
reasonable accommodations available to disabled individuals having business before the court,
please contact our oflice. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must intend the scheduled conference or hearing.
DFBORAII J. DITMI:R (NFIDIGII),
PIaintiIT/Resixmdent
THOMAS A. Nl:lDlUl I, IR.,
Delendant/l'clitioner
IN TI II'. COURT OF COMMON ITFAS OF
C UMBI:RLAND COUNTY, PENNSYLVANIA
NO 95.6322 CIVIL TERM
CIVIL ACTION - LAW
C't1STOD)WISITATION
PETITION FOR MODIFICATION OF CUSTODY ORDER
The Petitioner is the abme-named Del'endunt, 'I'honras A. Ncidigh, Jr., un adult
individual currently residing at 229 Hill Street, Mount Holly Springs, Cumberland County,
Pennsylvania 17065.
2. The Respondent is the above-named I'laintill; Deborah J. Dinner (Ncidigh), an
adult individual currently residing at 424 Limestone Road, Carlisle, Cumberland County,
Pennsylvania 17013.
3. The parties are the natural parents of the child Frin Alexandra Ncidigh, horn
December 9, 1994. The child was horn in %%cdlock.
4. The parties are currently subject to a Custody Order dated February 14, 1996,
which "as the result of a Custody Stipulation. A copy ul' dic resulting Order and Stipulation are
attached hereto and incorporated herein by reference ns I'.xhihit "A.-
5. There hove been no additional actions relutt%c to custody of the within named
child in any jurisdiction to the Petitioner's knowledge
6. Since the entry ol'the Court's Order of fcbnuur 14, 1196, the child has primarily
resided with the Respondent.
7. Paragraph 3 ol'the Court's Older of I cbruary 14, 1999 reads, "Visitation shall be
unlimited at the residence ol'the Mother or lit the residence ol'the child's maternal grundmolher "
8. The Respondent has informed the Petitioner that he will no longer be pertained
contact with the child at the maternal grandnntheCs home. Furthermore, the Respondent hus
routinely rescheduled or cancelled urnutged periods of visitation that were to take place at her
home.
9. Since the Order of February 14, 1996, the Respondent has, on several occasions,
permitted the Petitioner periods of unsupervised custody ol'the child, further indicating that such
supervision as required by the prior Order is no longer necessary.
Ill. Father was not represented by counsel at the time the stipulation was drawn up
nor when it became an Order of the Court on February 14, 1996.
If. The existing Order has proven to be impracticable and biased. In order far father
to exercise any visitation, the Order necessitates the Mother's agreement, which has heretofore
been withheld.
12. The natural mother ol'the child is Deborah J. Dinner. She is married.
13. The natural lather ol'the child is Thomas A. Neidigh, Jr. Ile is single.
14. The relationship ol'the Petitioner to the child is that of natural lather. The natural
father currently resides with Latina Brutko and her eleven-%cur-old daughter, Jennifer.
IS. The relationship of the Respondent to the child is that of natural mother. The
natural mother currently resides with the child, and tier husband, John Dinner.
10. The Petitioner has not participated as a parry in a witness in any other capacity in
litigation concerning the child.
17, Petitioner has no infinrnmtion of any custody proceeding concerning the child
pending' in any Court ol'this Conini mveuhh.
18. The best interest of llrc child will be provided by modifying the existing Custody
Order f'or the following reasons:
(a) Mother's non-coolxrution has made the existing Order unmanageable;
(b) In order for father to luster u hculthy relationship with the child, he must he
expressly permitted to have unfettered contact with the child outside the presence ol'the
Mother's home; and
(c) Working towards u standard, alternating weekend schedule would afford the
parties and the child a more consistent and predictable schedule to facilitate planning
activities with the child.
19. Petitioner does not know of any person not a party to these proceedings who
claim to have custody or visitation rights with reslxct to the child.
WI IGRBfORF, Petitioner requests your I lonorable Court to grant his request to enter an
Order scheduling a Custody Conciliation regarding the custody modilicatian.
Respectful bmitted,
.% i
Date: January 21, 2000
ion s S. Dic r , Esquire
Attorney for DelcndantTetitioner
401 Bust Louther Street, Suite 103
Carlisle, Pennsylvania 17013
(717) 240-0833
(717) 240-0893 - I AX
EXHIBIT A
DEBORAH J. NEIDIGH, s
Plaintiff s
s
V. s
THOMAS A. NEIDIGH, JR., s
Defendant s
IN THE COURT OF COMMON PLEAS OF.
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
N0. 95-6322 CIVIL TERM
ORDER OF_000RT
AND NOW, this lyi`day of February, 19961 upon consideration
of the attached custody stipulation with respect to the parties,
child, Erin Alexandra Neidigh, born December 9, 1994, the terms of
the stipulation are entered as an order of court.
BY THE COURT,
Lindsay Dare Baird, Esq.
37 South Hanover Street
Carlisle, PA 17013
Attorney for Plaintiff
Thomas A. Neidigh, Jr.
P.O. Box 463
Boiling Springs, PA 17007
Defendant
src
Deborah J, Neidigh,
Plaintiff
v
Thomas A. Neidigh, Jr.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
:95 - 8322 CIVIL TERM
CUSTODY/VISITATION
ORDER OF COURT
AND NOW, this By of 1998, it is ordered that Deborah J. Neldlgh,
Mother , has legal custody and primary physical custody of the minor child Erin Alexandra
Neldigh, bom December 9, 1994.
AND, it is further ordered that Thomas A. Neidigh, Jr., Father, has unlimited visitation with the
said minor child at either the Mother's residence or at the residence of the matemal grandmother
situated at 524 Hillcrest Drive, Carlisle, Pennsylvania,
BY THE COURT,
J.
Deborah J Neldlgh,
Plaintiff
Thomas A. Neidigh, Jr.,
Defendant
IN TIDE COURT OF COMMON PLEAS Of
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
95 - 6322 CIVIL TERM
CUSTODY/VISITATION
STIPULATION FOR CUSTODY
STIPULATION made this Q?4' day of February, 1996, between Deborah J. Neidigh,
hereinafter referred to as Mother, and Thomas A. Neidigh, Jr., hereinafter referred to as Father.
WHEREAS, the above-named Mother and Father had born to them the following child on the
following date:
NAME
Erin Alexandra Neidigh
BIRTH DATE
December 9, 1994
AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the
custody of the above-said child and to the visitation rights of the non-custodial parent:
NOW, THEREFORE, In order to effectuate the above purpose, the above-named Mother and
Father hereby stipulate that:
1. The Mother shall have legal custody of the child.
2. The Mother shall have primary physical custody of the child.
3. The Father shall have visitation as follows: Visitation shall be unlimited at the
residence of the Mother or at the residence of the child's matemal grandmother, 524
Hillcrest Drive, Carlisle, Pennsylvania.
4. The Mother, if she desires to relocate a distance more then one hundred miles from
her present location, shall not do so until suitable modifications shall have been made
in the arrangements set forth in paragraph 3, supra.
TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this
Stipulation and desire to have the Stipulation entered as an Order of Court.
Witness:
i
Indsay 960 Baird,,Fsq.
QD /6
VERIFICATION
I verily that the statements made io this Petition are true and correct. I understand that
false statements herein are etude subject to the Ixnalties of 18 N.C.S. § 4904, relating to
unswom falsification to authoritics.
I'I IOMAs A. Ni.11AGI I, JR.,
Defendant/Petitioner
MAR 2 s ZOW
DEBORAH J. DITMER.
Plaintiff
v
THOMAS A. NEIDIGH, JR.,
Defendant
IN 1'I IE COUIt7' 01' COMMON I'LI'sAS OF
: CUMI3Eit1-AND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, 95-6322 CIVIL
IN CUSTODY
COURT ORDER
AND NOW, this Zi day of March, 2000, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
1. This Court's prior Order on custody dated February 14, 1996 is vacated.
2. The Mother, Deborah J. Ditmer, and the rather,'rhomas A. Neidigh, Jr., shall enjoy
shared legal custody of Erin Alexandra Ncidigh, born December 9, 1994.
3. The Mother shall enjoy primary physical custody of the minor child.
4. The Father shall etoy periods of temporary physical custody of the minor child as
follows:
A. During the summer months, on alternating weekends from Sunday
r e, > morning through Monday evening at limes to be agreed upon by the
` parties.
R. During the school year, from Sunday morning through Monday
morning, again the times for exchange to be agreed upon by the
parties.
ca } C. On an additional one morning per week, the schedule to be arranged
between the parties.
D. At such other times as agreed upon by the parties.
5. rather shall be ullorded two (2) weeks of non-consecutive vacation with the child
during the summer months. Father shall give notice to Mother on or before May I"
of each year as to when he intends to exercise his custody. Mother shall be afforded
a similar time of vueution, and Mother shall notify rather in advance as soon as
possible as to when her vacation schedule is set.
6. When the Father has custody of the minor child, the child shall not be in the
presence of Mr. Tim Travis. Additionally, when Father has custody of the child, the
child shall not be exposed in any way, to any type of illegal drugs or drug activity.
Violation of this provision will subject Father to an appropriate contempt order.
7. Each party shall enjoy reasonable telephone contact with the minor child when the
child Is with the other parent. Both parents shall keep the other parent informed with
respect to their residence mid phone number. In the event either party leaves their
regular home I'ur an overnight stay with the minor child, the custodial parent shall
notify the non-custodial parent of the location they would be in and also provide an
appropriate phone number in order to be contacted in the event of an emergency.
S. The holiday schedule shall be handled as follows:
A. For Christmas, the Mother shall always have Christmas Eve and
Christmas moming- Father shall have Christmas Day from 4:00 p.m.
until December 26 at 4:00 p.m.
B. For Thanksgiving, Mother shall always have Wednesday evening
and the morning of Thanksgiving. Father shall have the child from
4:00 p.m. on Thanksgiving Day until 4:00 p.m. the following Friday.
C. The Father shall always have custody of the minor child on Father's
Day and the Mother shall always have custody on Mother's Day.
D. For the child's birthday, the parties shall make arrangements so the
Father shall have custody of the child to celebrate the birthday on the
day before tine actual day of the birthday and, if possible, both
parents will be Abided the opportunity to spend some time with the
minor child on the actual day of the birthday celebration.
9. The parties shall share transportation for exchange of custody with the
understanding that on some weekends Mother has guard duty and she is not
available to provide transportation.
10. The alternating weekend schedule shall he handled such that the weekend the
Mother has guard duty shall be one of the weekends the Father has custody of the
minor child.
r
II. This order is entered pursuant to an agreement reached by the parties at a Custody
Conciliation Conference. In the event the parties agree to modify this order
themselves, they may reach such an agreement. Absent any agreement to modify
this order, this order shall control. In the event either party desires to modify this
order and is unable to reach an agreement with the other party, either party may
petition the court to have this case again scheduled with the Custody Conciliator for
a Conference.
nV 1'HE COURT
cc: Thomas S. Diehl, Esquire
Robert O'Brien, Esquire
,
) /Z J.
esley Oler
$,0O
4,5
y %P
DEBORAH J. DITMER,
Plaintiff
v
THOMAS A. NEIDIOH, JR„
Defendant
Prior Judge: J. Wesley Oler
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL. ACTION - LAW
NO. 95-6322 CIVI1.
IN CUSTODY
CONCILIATION CONFERENCE. SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
The pertinent information pertaining to the child who is the subject of this litigation is as
follows:
Erin Alexandra Neidigh, bom December 9, 1994.
2. A Conciliation Conference was held on March 16, 2000, with the following individuals in
attendance:
The Father, Thomas A. Neidigh, Jr., with his counsel, Thomas S. Diehl, Esquire; and the
Mother, Deborah J. Dinner, with her counsel, Robert O'Brien, Esquire.
3. The parties agree to the entry of an order in the form as attached.
.3booo 6??q?lz
DATE Hubert X. Oil , Esquire
Custody Con lator
DEBORAH DITMER, now known as
DEBORAH J. LYONS,
Plaintiff
VS.
THOMAS A. NEIDIGH,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL IN CUSTODY
NO. 1995-6322
MOTION FOR COURT ORDER
AND NOW, comes counsel for Plaintiff and moves this Honorable Court to approve and
adopt the attached Stipulation as an Order of Court.
BUZGON DAVIS LAW OFFICES
BY:
Edward J. Coyle, Esqui
Attorney I.D. #49742
525 South Eighth Street
Post Office Box 49
Lebanon, PA 17042-0049
(717) 274-1421
Fax: (717) 274-1752
E-mail: coyle@buzgondavis.com
Attorneys for Plaintiff
, a-
I diWDonwstic KelationsA,wn _. Dehorah'Stipulation fw custodg doc - 4114S'09 f :30 P%1
DEBORAH DITMER, now known as IN THE COURT OF COMMON PLEAS OF
DEBORAH J. LYONS,
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
vs.
NO. 1995-6322
THOMAS A. NEIDIGH, JR.,
Defendant
IN CUSTODY
STIPULATION TO MODIFY PRIOR CUSTODY ORDER
AND NOW, comes the Plaintiff, Deborah Ditmer, now known as Deborah J. Lyons
(hereinafter "MOTHER") and Defendant, Thomas A. Neidigh, Jr. (hereinafter "FATHER"), who
respectfully represent:
1. The parties are the parents of one (1) minor child, Erin Alexandra Neidigh, born
December 9, 1994 (hereinafter "CHILD")
2. The parties are subject to a Custody Order entered by this Court dated March 24,
2000.
3. MOTHER desires to relocate CHILD's residency from Cumberland County,
Pennsylvania, to Arizona in or about June 2009.
4. FATHER consents to the relocation of CHILD's residency, with MOTHER, from
Cumberland County, Pennsylvania, to Arizona, in or about June 2009.
5. As such, effective immediately upon MOTHER's aforementioned relocation, the
parties do hereby agree to vacate the last Custody Order dated March 24, 2000, and in its place
stipulate and agree as follows:
(a) Upon relocation, MOTHER shall continue to have primary physical custody
of CHILD, while the parties shall continue to share legal custody of CHILD:
(b) Upon relocation, FATHER shall be entitled to periods of visitation and
partial custody, to occur in Cumberland County, Pennsylvania, as the parties may agree. Failing to
agree, FATHER shall be entitled to the following periods of visitation and partial custody:
(1) One (1) continuous four (4) week period each year during the child's
summer vacation from school, with the specific weeks to be as agreed upon by the parties;
(2) One (1) additional week each year during the school year, with the
exact week to be as agreed upon by the parties;
(3) During FATHER's periods of partial custody, except for those
occasions when the CHILD is visiting friends or relatives, FATHER shall provide adult supervision
for the CHILD at all times, with the adult supervision to be provided by one of the following
individuals:
- the Defendant, Thomas Neidigh;
- the Defendant's wife, Nancy Neidigh;
- the CHILD's Godmother, Lori Ellen Orr;
- the CHILD's paternal grandmother, Susan Neidigh; or
- the CHILD's maternal grandmother, Olga Lyons.
(c) MOTHER shall pay for the plane tickets required for FATHER's periods of
partial custody detailed in paragraph 3(b) above.
(d) Each parent shall provide the other parent with his/her home address,
telephone number, cell phone number and/or an e-mail address via which the parties can
communicate with respect to issues that arise regarding the CHILD. In addition, the parent having
physical custody of the CHILD shall not unreasonably withhold telephone and e-mail
communication between the CHILD and the non-custodial parent.
-2-
(e) While in the presence of the CHILD, neither parent shall make or permit any
other person to make any remarks or do anything which could, in any way, be construed as
derogatory or uncomplimentary to the other parent. It shall be the express duty of each parent to
uphold the other parent as one whom the CHILD should respect and love.
(f) With regard to any emergency decision that must be made, the parent with
whom the CHILD is physically residing at the time shall be permitted to make the decision
necessitated by the emergency without consulting the other parent in advance. However, that parent
shall inform the other of the emergency and consult with the other parent as soon as possible. Day-
to-day decisions of a routine nature will be the responsibility of the parent having physical custody
at the time.
(g) Nothing shall prevent the parties from agreeing to other or modified periods
of partial custody or visitation.
(h) This Stipulation shall be entered as an Order of Court and be enforceable as
such. 11,1A ? n
A?J
-ffl 1A if I
DEBORAH J. LYON , Plaintiff
Date: , 2009
sworn and subsoribed to
before me this i dw
of APri I
IDy ThunczS 11
V?1 e Cd nh r br11 .
T OMAS A. NEIDIGH, JR., Defendant
Date: 2009
COMMUNWtt3LIH OF PENNSYLVANIA
NOTARIAL SEAL
DARCIE A. NEIL, Notary Public
Boro of Carlisle, Cumberland County
My Commission Expires Nov. 24, 20C19
-3-
VERIFICATION
I, DEBORAH J. LYONS, do hereby verify that I am the Plaintiff in the within action, and
that the facts set forth in the foregoing STIPULATION TO MODIFY PRIOR CUSTODY
ORDER are true and correct to the best of my knowledge, information and belief. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to
unsworn falsification to authorities.
n
s
DEBORAH J.LYONS7
Date: , 2009
VERIFICATION
I, THOMAS A. NEIDIGH, do hereby verify that I am the Defendant in the within action,
and that the facts set forth in the foregoing STIPULATION TO MODIFY PRIOR CUSTODY
ORDER •are true and correct to the best of my knowledge, information and belief. 1 understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to
unworn falsification to authorities.
O S A. NEIDIGH
DEBORAH DITMER, now known as IN THE COURT OF COMMON PLEAS OF
DEBORAH J. LYONS,
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
vs.
THOMAS A. NEIDIGH, JR.,
Defendant
IN CUSTODY
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
) ss:
COUNTY OF LEBANON )
I, SHARON SECOGES, an employee of Buzgon Davis Law Offices, 525 South Eighth
Street, Lebanon, Lebanon County, Pennsylvania, Attorneys for Plaintiff, being duly sworn
according to law, depose and say that I mailed for filing on May 12, 2009, in the Office of the
Prothonotary of Lebanon County, Pennsylvania, the original and two true and correct copies of
STIPULATION TO MODIFY PRIOR CUSTODY ORDER and proposed ORDER and that I
provided the Prothonotary with a stamped envelope addressed to: Thomas A. Neidigh, Jr., 221
Meals Road, Carlisle, PA 17013. f
Sharon M. Secoges
Sworn to and subscribed
efore me this 12th day
TNT A.D., 2009.
An n
otary
COMMONWEALTH OF PENNSYLVANIA
CIVIL ACTION - LAW
: NO. 1995-6322
Notarial Seal
OWM A. StePa{avich, Notary Public
City of Lebanon. Lebanon CouMY
My Commission EMfts Dec. 20, 2012
Member, Pennsylvania Association of Notaries
r,
DEBORAH DITMER, now known as IN THE COURT OF COMMON PLEAS OF
DEBORAH J. LYONS,
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff :
CIVIL ACTION - LAW
vs.
NO. 1995-6322
THOMAS A. NEIDIGH, JR.,
IN CUSTODY
Defendant
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY OF SAID COUNTY:
Please enter the appearance of BUZGON DAVIS LAW OFFICES, whose address is
525 South Eighth Street, P.O. Box 49 Lebanon Pennsylvania, 17042, as attorneys for Deborah
Ditmer n/k/a Deborah J. Lyons., Plaintiff, in the above-captioned matter.
BUZGON DAVIS LAW OFFICES
BY:
Edward J. Coyle, Esquire)
Attorney I.D. #49742
525 South Eighth Street
Post Office Box 49
Lebanon, PA 17042-0049
(717) 274-1421
Fax: (717) 274-1752
E-mail: coyle@buzgondavis.com
Attorneys for Plaintiff
Dated: May 1, 2009
-:;C
FILEU-
OF THE
2009 MAY 14 Plill 2: 616
MAY 15 2009(4
DEBORAH DITMER, now known as IN THE COURT OF COMMON PLEAS OF
DEBORAH J. LYONS,
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
vs. :
NO. 1995-6322
THOMAS A. NEIDIGH, JR.,
IN CUSTODY
Defendant
ORDER
AND NOW, this jr7 day of , 2009, upon consideration of the
attached Stipulation to Modify Prior Custody Order dated April 16, 2009, IT IS HEREBY
ORDERED that all terms and provisions of the said Stipulation are hereby made and entered as
an Order of this Court.
J.
BY THE COURT,
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