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Home My WebLink About96-01515 \ " ) Ir l~ ! I ~ J .~ ~ -\r1 ........ ~/ \ . ..j (.:)0- ~ Il' , 1.- , . ,J ., , -. \ \01 \--. - , . " ( '" \..J ' , "-I' t, ~ .t~ ~ (\,; ,,> -- -C.J " '" f"'-...- ('0) ,-- .~ '~ . ''''iJ ,2:0 ~.~(~ ..: U1": ..:> ~.:l .:l>< l1!U1 Z ZZ O~ ~l1! o ' U>< r..f4 Oe:; f40 p:;U 00 OZ U": ~:;] :I:~ f4 ~ . ZOO p:; r.:I Z >< r.. Z p:; r.. ..: >< 0 ..: ~ 0 :I: t.:l H 0 ;; UI p:; p:; f4 .~ $~ 0 l1! Ul Z ~ ::> 3: '" a:~ Z J>: U ~ ~ "' In . f4 ~ ~;~~ ..: Ul 0 > f4 r.. .:l >< 0 ..: '" i ~~~~ .:l U f4 U ~ J>: UI Z H ~ ~ ~~ r.:I 0 H Ul ~ P'l ..: >< ~ .:l .:l :I: !?~ H ..: l1! l1! :<: Z ~ 0 0 J>: U .. . ~ t6I7J...l.-4/~.1O a.eo.t)' C~AVl.lW ApnllI, 1996 KIMBERLY ANN SHOFFNER, Plaintitt v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 96-1515 RONALD SCOTT MORGAN, Defendant CIVIL ACTION - CUSTODY ANSWER AND COUNfERCLAIM TO COMPLAINT FOR PRIMARY PHYSICAL CUSTODY AND NOW, this If day of ~,,:_J , 1996, comes the Defendant, Ronald Scott Morqan, by and throuqh his counsel, Smiqel, Anderson , Sacks, and respectfully answers as tollows: 1. Admitted. 2. Admitted. J. Admitted. 4. Denied. The date of the divorce decree is July J, 1991. 5. Admitted. 6. Admitted in pa~t and denied in part. It is admitted that the parties have been sharinq custody of the minor children. It is denied that is in the best interests of the children that primary physical custody be qranted to Plaintiff. Rather, the best interests of the children would best be served by awarding primary physical custody to Defendant, with partial custody for purposes of visitation qranted to Plaintiff. 7. Denied. From the children's birth until 1989 the parties resided together at Wertzville Road, Enola, Pennsylvania. From 1989 until March 1991 the parties resides together at 2211 Spring Run Drive, Mechanicsburq, Pennsylvania. Plaintiff and Defendant have parties are remarried. 5. The relationship of Plaintiff/Defendant in counterclaim to the children is that of mother. Plaintiff/Defendant in counterclaim currently resides with the followinq persons: ~ RelationshiD Joey Shoffner Amanda Louise Morqan Husband Dauqhter 6. The relationship of Defendant/Plaintiff in counterclaim to the children is that of father. Defendant/Plaintiff in counterclaim currently resides with the followinq persons: ~ RelationshiD Sandra Jean Morqan Ryan Scott Morqan Xaelyn Patrice Brudnok Ryan George Brudnok Wife Son Step-daughter Step-son 7. Defendant/Plaintiff in Counterclaim has not participated as a party or witness, or in another capacity, in other litiqation cancerning the custody of the children in this or another Court. Defendant/Plaintiff in Counterclaim has no information of a custody proceeding concerninq the children pendinq in a Court of this Commonwealth. Defendant/Plaintiff in Counterclaim does not know of a person not a party to the proceedinqs who has physical custody of the children or who claims to have custOdy or visitation rights with respect to the children. Pursuant to an Order of Court dated March 22, 1996, a conciliation conference has been scheduled before Attorney MiChael Banqs on May 9, 1996 at 1:00 p.m. 8. The best interest and permanent welfare of the children will be served by granting the relief requested because: 4 < H UI ~~ ..:1>- l1!CIl Z e ZZl.o J>: r.:I Or.:lCU r.:I U ;; ~l1!f4 Z z H $5 r.. < > .~ o ,... r.. t.:l J>: ~ or:! U >-.... 0 l>: r.:I ~ til f4> :I: 0 Ul ~ .. o~ r..z..... Ul ~ .. "':~~ oou r.. ,. > 0 Z f4 0 '" '" f:~~ f4Uli'l Z E-< ~ l u~5 ' J>: ~ < Ul 0 r.:I 5 '" Ii OOli'l ;. t.: U ~ I;l 5lii! OZ~ >< UI Z Uj"!' ..:l ..: -!!1 J>: 0 f4 !!~ r.:IIXO'l r.:I ..:l llo :l:r.:I 1Il ..: r.:I f4P'l X Z U x . H 0 U zoo :<: IX ..: HUZ . '-f .~ii~ .;: 4G', l.. I . '-f C. The parties shall alternate the weekends from Friday through Monday morning. 3. The parties shall alternate the major holidays; those holidays being defined as Easter, Memorial Day, Fourth of July, labor Day, and Thanksgiving. This alternating schedule shall begin with Father having Easter in 1997. 4. The parties shall share the Christmas holiday, which shall be broken into two segments. Segment A shall be from 12:00 noon on December 24th until 12:00 noon on Christmas Day, and 12:00 noon on December 29th until 12:00 noon on January 1 st. Segment B shall be from 12:00 noon on Christmas Day until 12:00 noon on December 29th. Father shall have Segment A in 1997 and all odd-numbered years thereaher, and Segment B in 1998 and all even-numbered years thereafter. Mother shall have Segment B in 1997 and all odd- numbered years thereafter, and Segment A in 1998 and all even- numbered years thereafter. 5. Each party is entitled to one uninterrupted week of vacation with the children. The parties shall provide each other with a minimum of thirty (301 days advance notice as to when they intend to exercise this period of exclusive vacation time. In addition, the parties will permit the children to call the non-custodial parent at a minimum of one time during these periods of vacation. 6. Mother and Father hereby agree that they shall be responsible for one-half each, for the costs of all sports activities, school related activities, or any other such items which are not solely related to one particular household. Father shall bear the costs of coat and shoes for Ryan, and Mother shall bear the costs of coat and shoes for Amanda. Each household shall be responsible for the everyday clothing for that household. 7. Both parties shall cooperate to be sure that the children go to all of their extra curricular activities which occur during their custodial periods. 8. Medical and dental insurance coverage shall be provided by either Mother or Father, whomever is able to provide the best coverage with as little cost to them as possible. All uninsured medical bills including dental expenses shall be divided one-half each between Mother and Father. All information concerning medical insurance coverage shall be provided to the other parent. 9. Mother and Father hereby acknowledge and agree that they shall each pay one-half of the college expenses incurred by their children that exceed funds received from grants, scholarships, " I t - I , .. c C' =: ... 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