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Home My WebLink About95-07371 . (. .\l JI . , 1 -..... ,...... f!l ~ ~ 0'\ ~ g 0 ~t~ .. ",. ..:r -~,r . . (_ 1.1 ". (J ~~J cli1,: lJ_ ("),:: ~', ' ".J (' <.0 J.. l~. ~ ,'. '"'J .,.~ ( ., ) . f,:p' c..l n ,:, j'" i' 101 .:,,"1 ... (,;,1 ....U. () \." !:i Ul 0 ~~ ~~ 11< III ~~ o .): U~..c I<<Z..:l Opl Eo< 0 ~U?: pOl>< 8 e t: g :( u [~ I'l..:l..c UI IIlCl..:l e Eo<~H ;z: > OZ H ZH ~ \~ ~'" \~ ~ ~ ~ ~ ..... ~ ,~ ~-\ ')"L., '! '.9 c:.; \o.C. ~ i , i - ~ ~~ ... .'... l-,,j.) I:l U1,... Hill ~M 011< ~ 'tl I:l III Eo< ~ ~ III ,j.) I:l III 'tl I:l II! ... II! ~ . U ..c III UI H n: Eo< 'tl I:l III Eo< ~ ~ . ;z: .0 ..:l~ ~t!l HP >0 ..cEo< ~U1 Cl ~~ mO ~~ Cl ..c;z: o l><H ~E-< 0": tis PI1< UH Eo< UI c{ u 3 ~ Ul ~i - o..J ~ . ~ ~. .J I~~~ >- . fj: z olll o ..,11. ~ J: 0(:: ~ I- ~ z c{ . UI > . iii ~ RAY E. WERT and DORIS J. WERT Plaintiffs VS. DAVID L. WERT and TRISHA c. STOUGHTON, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. q~ 1 j 71 (l J.. LLt~-L Jtt-'Y1'-~ IN CUSTODY ORDER AND NOW, to wit, this ~ day of December, 1995, the court adopts the agreement of the parties concerning the custody and visitation of the child, STEVEN L. WERT, as the Court's own order. A copy of that agreement is attached hereto and made a part hereof as fully as if entered specifically by the court. We direct that a copy of this order be furnished to all parties. -" / ~Y THE CO,'' WYv/ / J ? RAY E. WERT and DORIS J. WERT I plaintiffs I I VS. DAVID L. WERT and TRISHA C. STOUGHTON, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN CUSTODY STIPULATION WHEREAS, the parties have reached an agreement as to the custody and visitation of STEVEN L. WERT born to DAVID L. WERT and TRISHA C. STOUGHTON, and wish a court Order to reflect that agreement; THEREFORE, with due consideration fer the welfare of said child, the parties hereby agree as folloWS, to wit: 1. Majority physical custody of said child, STEVEN L. WERT, and visitation of said child shall be determined by an agreement executed by the parties hereto, attached hereto as Exhibit "A", and made a part hereof and incorporated herein by reference. 2. It is contemplated and requested by the parties hereto that this agreement be adopted by Order of court. WI~NES:: ('/Q, _/ I'. {it{~ .,..Y,4~J/; I"rt c~V ~/ ( f {7", r -X, ("ll ,') ~ '/)r f ('X {\, f. '1' A!.{!' Ray E./ Wert /":("1':' ~. >~ ,: iT' Doris J. Wert ,j!. ,/ ~J 1~ Y-- David L. ~ert ~USTODY AGREEMENT THIS AGREEMENT, made this;?Y1r day of December, 1995, by and between RAY E. WERT and DORIS J. WERT, of carlisle, Cumberland county, Pennsylvania and DAVID L. WERT, of Carlisle, cumberland county, Pennsylvania and TRISHA C. STOUGHTON, of Mechanicsburg, Cumberland County, Pennsylvania. WITNESSETH: WHEREAS, DAVID L. WERT and TRISHA C. STOUGHTON had previously been married to each other and were subsequently divorced in cumberland county, Pennsylvania; and WHEREAS: Two (2) children were born of this marriage, namely STEVEN L. WERT, born on May 13, 1979; and BRYAN L. WERT, born on January 13, 1982; and WHEREAS, BRYAN L. WERT resides with his mother's sister in the state of West Virginia; and WIIEREAS, STEVEN L. WERT resides with his grandparents, RAY E. WERT and DORIS J. WERT at 385 Sherwood Drive, carlisle, Cumberland county, Pennsylvania; and WIIEREAS, the natural father, DAVID L. WERT, and the natural mother, TRISIIA c. STOUGHTON, consent to the PlaintiffS, RAY E. WERT and DORIS J. WERT having custody of the said STEVEN L. WERT. copies of their consents are attached hereto, incorporated herein by reference, and marked as Exhibit "B" and Exhibit "c"; and WHEREAS, the grandparents, RAY E. WERT and DORIS J. WERT, consent to accepting custody of the said STEVEN L. WERT. copies of EXllIlll'l' "A" their consents are attached hereto, incorporated herein by reference, and marked as Exhibit "Oil and Exhibit "E". NOW THEREFORE, in consideration of the mutual covenants herein made, as well as other good and valuable consideration, the receipt of which hereby is acknowledged, the parties hereto, intending legally to be bound hereby, do covenant and agree as follows: A. The custody of the aforesaid child, during minority, hereby is given to RAY E. WERT and DORIS J. WERT, except as otherwise may be provided by an appropriate court, having proper jurisdiction of the subject. B. DAVID L. WERT and TRISHA C. STOUGHTON shall have the right of reasonable visitation of said child, as mutually may be agreed upon by the parties. In the event the parties are unable to agree upon visitation, DAVID L. WERT or TRISHA C. STOUGHTON shall have the right of visitation every other weekend, commencing at 6 o'clock P.M. on Friday and ending at 6 o'clock P.M. on Sunday. With respect to the major holidays consisting of New Year's Day, Easter, Memorial Day, Fourth of July, Labor Day, and Thanksgiving, DAVID L. WERT or 'fRISHA C. STOUGHTON shall have the right of visitation as mutually agreed upon by the parties. With respect to Christmas, the parties shall divide the Christmas holiday as mutually agreed upon by the parties. C. DAVID L. WERT or TRISHA C. STOUGHTON shall notify RAY E. WERT and DORIS J. WERT, not less than 24 hours in advance, of any change in plan to exercise such visitation rights. D. It shall be the responsibility of RAY E. WERT and DORIS J. WERT to keep the natural parents, DAVID L. WERT and TRISHA C. STOUGHTON advised of the address where STEVEN L. WERT will be living and of any medical emergencies concerning the STEVEN L. WERT. E. RAY E. WERT, DORIS J. WERT, DAVID L. WERT and TRISHA C. STOUGHTON agree that in making this agreement there has been no fraud, concealment, over-reaching, imposition, coercion, or other unfair dealing on the part of any party. F. RAY E. WERT, DORIS J. WERT, DAVID L. WERT and TRISHA C. STOUGHTON hereby agree and therefore etipulate that it is their intent and request that the Court of Common Pleas of Cumberland County, Pennsylvania adopt this agreement as a decree and Ordor of Court. IN WITNESS WHEREOF, the parties hereto have executed thie the day and year first above written. WITNESSI (') "" ;/. 'i( /. (" . ~ p-.U"jlf).;" /' a~ . ':t(--d '-~' a;~ (;i.fl..L ~ Cf)'1tt- (SEAL) RiiVE. J we~t . li,d 'J / octrl~j~ w'rt /.'/i' IT (SEAL) oJf~'~L:'<~~ t(~ .51 (SEAL) (SEAL) RAY E. WERT and DORIS J. WERT plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. DAVID L. WERT and TRISHA c. STOUGHTON, Defendants NO. IN CUSTODY CONSENT David L. Wert, bsing duly sworn according to law, deposee and saYSl 1. That he is the natural father of steven L. Wert. 2. That my son, steven L. Wert, has been residing with my parents, Ray E. Wert and Doris J. Wert at 385 Sherwood Drive, carlisle, Cumberland county, Pennsylvania for quite some time. 3. That he knowingly and voluntarily consents to Ray E. Wert and Doris J. Wert having custody of his son, Steven L. Wert. WITNESS ~ . (/az:~ a Q"~ J~~~f/ (l~ //{~~ D vid L. Wert Datedl J.~V~;{ p/ ;i j- , , -..- -] t4n!.H!i11 :'1':11 MUlJOfl1l ^ IlI..\ Ill,] lI'I;H.' I'HII'te f.lIdl' 1.';1&; '11 1"11 Clllli( .": I',j r;',"1~ Mt CUnillll! ''101~~~1~~:':.:~2:-_ ',-~"lil!!! r rl! ' I ' '"Ii ;) '-,j I.I/l Jlli I;,~; Sworn to and subscribed before me this ,''Ill day of December, 1995. ')1 . /' II N ( (L. EXHIBIT "B" RAY E. WERT and DORIS J. WERT I Plaintiffs I I I I I I I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. DAVID L. WERT and TRISHA C. STOUGHTON, Defendants NO. IN CUSTODY CONSENT Trisha C. stoughton, being duly sworn according to laW, deposes and saysI 1. That she is the natural mother of Steven L. Wert. 2. That my son, steven L. Wert, has been residing with Ray E. Wert and Doris J. Wert at 385 Sherwood Drive, Carlisle, cumberland county, Pennsylvania for quite some time. J. That she knowingly and voluntarily consents to Ray E. Wert and Doris J. Wert having custody of her son, steven L. Wert. WITNESS /7' IlL:, ~ ",If I /' f, (~ll"\;lr/' /Z"r/..n~~l r!.y( Dated I IJ - :) ./ q 5 II Trisha c. stoughton [ --, Sworn to and subscribed Now";,!:;,,,,1 . I . MiI'!l'Hlll A DIll IF it f~I:I,IIV PuLl!( before me this ,:\J ,/1J. day f,,,;'h I,' Jt. 1''" 1\.;>(",."", ",1, <;'1" of December, 1995. M{ Cll1l11hl'."lrll fl!lHl", ti I' I 1:.,'1'.1 ~ , ',' ~"/(I. K IC-'-'-;-:-:'--,f,~,--,.;;"::;-;'t:;;;:u J~~tt:.; I;~bl c.1' u /(0'<_ EXHIBIT "c" RAY E. WERT and DORIS J. WERT I Plaintiffs I I I I I I I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. DAVID L. WERT and TRISHA C. STOUGHTON, Defendants NO. IN CUSTODY CONSENT Ray E. Wert, being duly sworn according to law, deposes and saysl 1. That he is the paternal grandfather of steven L. Wert. 2. That my grandson, steven L. Wert, has been residing with me and my wife, Doris J. Wert, at 385 Sherwood Drive, Carlisle, Cumberland County, Pennsylvania for quite some time. 3. That he knowingly and voluntarily coneents to having custody of his grandson, steven L. Wert. WITNESS ~ . '. (/)/1 ~/' " L-1A(~ r/, ,,(U'r41t't''j (~ Da ted I I ;L .. 'J. 7 - q 0 (\/~t, t: (1Y J Ray Erwert -----. Sworn to and subscr ibed till """ ';",11 before me this',)l.tt day M'''I''''''^ 0"'11I"11''''1'1'""1,,, f D b 19.9 111li'11I~1' lnl "'jl' ',1, I' j(' I, o ecem er,. MfL","', ,,1'1""',U"" 11".'1 .1) f}~':/ :u{~ ,{) .' 8., :;:;.~:"D:C"-'-"""~' RAY E. WERT and DORIS J. WERT plaintiffs I I VS. I I DAVID L. WERT and I TRISHA C. STOUGHTON, I Dsfendants I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN CUSTODY , CONSENT Doris J. Wert, bsing duly sworn according to law, dsposes and saYSl 1. That she is the paternal grandmother of Steven L. Wert. 2. That my grandson, Steven L. Wert, has been residing with me and my husband, Ray E. Wert, at 385 Sherwood Drive, carlisle, Cumberland county, Pennsylvania for quite some time. 3. That she knowingly and voluntarily consents to having custody of her grandson, Steven L. Wert. WITNESS a~ ( /' dJ:i/ tt.' ....' 7""'/';.' ,.,,,....,( c- . , f ~. (I ' i /." , .\ r~;lL.A . ,Vtf/.t- Doris J." Wert Dated: /1 / .1 ~/ 9..3- Sworn to and subscr iIJed Nnl,llInl1illill before me this 'Y~:(,( day M"'I()II"~ (Milt] ~kl;"yl'"hlic f D b f;oulh..tdd..}l',ll fl';l' 1.:'!I'~I,"i:r'1(,..J,',t) o ecem er, 199 . MvCuP"Ill""nnl'i'"""tlll I I""~ '-'1')1 ~~~ ,- P:il'io/Pp 'f-?'(~ r ~'1I..iYrim"1:::7.~~~iTiJ.:;;;'~ , EXHIBIT ~E~