Sophia Byrnes v. Timothy Byrnes (2011)

JOINT PARENTING PLAN

1. The parties shall share joint legal custody of their minor children, with primary residence to the Plaintiff mother.

2. The father shall parent the children on alternate Fridays from 6 p.m. until Sunday at 8 p.m., with the mother to drop the children off at the father's residence and the father to drop the children off at the mother's residence.

4. The parties shall alternate spring and winter breaks, and all major holidays.   On even years the father shall parent the children on Christmas Eve and New Years Eve from 11:00 a.m. overnight through 11:00 a.m. on Christmas Day and New Years Day when they shall be dropped off at the mother's residence.   On odd years the opposite shall apply.

5. The children shall spend Father's Day with the father, and Mother's Day with the mother.

6. The parties shall alternate the minor children's birthdays on an annual basis.   Starting 2011 for the mother.

7. The children shall spend the father's birthday with him from 9:30 a.m. (4:30 p.m. if the birthday falls on a school day) until 8 p.m. The children shall spend the mother's birthday with her.

9. Neither party shall relocate in excess of thirty (30) miles from their current residences without having first given the other party ninety (90) days advance notice.

10. If during the father's visitation the children have any school projects to work on that are due the following week, the father shall assist in such projects to comply with school requirements.

12. The parties shall share jointly in the expenses for any dental needs for the children, including but limited to dental surgery and/or orthodontic treatment.

13. The parties shall employ every reasonable effort to maintain free access and unhampered contact between the minor children and each of the parties, including but not limited to telephone contact, and to foster a feeling of affection between the children and the other party.   Neither party may do anything which may estrange the child from the other party nor injure the opinion of the child as to his or her mother or father, nor act in such a way as to hamper the free and natural development of the children's love and respect for the other party.   Any decision regarding the children shall be considered with a view to the children's best interests and not with a view to the personal wishes of the parties.   The mother shall have the right to make decisions concerning the daily regular care of said minor children (except for such times when said minor children are with the father, then such decisions shall be made by the father).   Both parents shall share jointly and equally in the decision-making process for all matters concerning the minor children dealing with their education (including choices and costs of school, day care, camp or other similar programs), religious upbringing and medical and dental decisions (including but not limited to the choice of physicians, dentists and/or other healthcare professionals, surgeons, orthodontia and psychological and psychiatric care).   The parties shall split equally agreed upon extra-curricular activity costs for the children, said consent not to be unreasonably withheld.   The father shall be entitled to see the children's report cards and to be informed of their behavior and progress in school and in general.   The father shall also have the right to be given adequate notice of any competition performance or school function in which the children may participate in order that he may attend.

RESPECTFULLY SUBMITTED

The Plaintiff, Sophia Byrnes

The Defendant, Timothy Byrnes

Attorney for Plaintiff, Rashmi N. Patel, Esq., Juris No. 425997

Attorney for Defendant, Alice M. McQuaid, Esq. Juris No. 4099558.

Shay, Michael E., J.