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Home My WebLink About96-01877 " I ;,1' i 'It ~~.;!- -J :{J-l ,~'l i '1'11 (( i ~iI , 'II' ,1 ,;;'IJ I 'I ' :Il ,I I I I I., ; -I, 1 1 : .<.t I ' ; ! ! ~ ~~ 1 1< ~. i l 'i ' J , i , i d I E I ~) ~i 0--' . ~I i l. ! . '\ ,~",,"V I \! j;!~hV' KATHRYN ROGERS, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . . 9" - /P'l7 (.,~ I ( '-ri',v., v. NO. MARK L. ROGERS, CIVIL ACTION - LAW Defendant CUSTODY ORDER OP COURT AND NOW, f1rr r. \ 10.', 1996, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before Michael L, Bangs, Esquire, the conciliator, at 302 S. l~th Street, Camp_Hill, Pennsylvania, on _J:l1e C/1/, day of rv"''! , 1996, at ~ o'clock ~.m., for a Pre-Hearing custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Either party may bring the children who are the subjects of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. Ir YOU DO NOT HAVE A LAWYER OR CANNOT UPORD ONE, GO '1'0 OR TELEPHONB THE OPFICE SET FORTH BELOW TO FIND OUT WHERB YOU CAN GET LEGAL HELP. orFICB OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH rLOOR CARLISLB, PA 17013 (717) 240-6200 J. I/'/,) yr., (~J fir:;/,'",.,t!; id1f jJ.,,~~ 1./.) Pc. fli.",t~,. ~",;tj// .z ,fill, Ij'/J ft. I", J, J (1'1 i'f}' /J tj~,1.... .;It /JI. /-J~.,'f'" y:.& . 7-- -,.. ~ '- r-- d! 0 i " . "1 ; .. ! \}o <4 " (.; ~ lU ~ ^l C,'I. i () l..J:l c- .,- l.'-.' l l..1 ---, '- ...., L I V, 1t ~ l., : li . , ~ 0 . 0./. l ,_OJ Q,.. L . . &!~wJ ;~~~~ il!~g ~~a~ " , '" 3. plaintiff seeks custody of the following childron: liIDIUl Present Residence Date of Birth Sara M. Rogers 921C Bosler Avenue Lemoyne, PA 17043 May 2, 1989 Elaine L. Rogers 921C Bosler Avenue Lemoyne, PA 17043 February 19, 1992 4. The children were born in wedlock. 5. The children are presently in the custody of Plaintiff, who resides at 921C Bosler Avenue, Lemoyne, Cumberland county, Pennsylvania, 17043. 6. During the past five years, the children have resided with the following persons and at the following addresses: Plaintiff 921C Bosler Avenue Lemoyne, PA 17043 Plaintiff and Defendant 4 Riddle Road camp Hill, PA 17011 6/95 - Present 5/87 - 6/95 7. The mother of the children is plaintiff, Kathryn Rogers, who currently resides at 921C Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania 17043. She is married. 8, The father of the children is Defendant, Mark L. Rogers, who currently resides alone at 4 Riddle Road, camp Hill, Cumberland county, Pennsylvania, 17011. He is married. 2 ~ 9. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this commonwealth, plaintiff does not know of a person not a party to the proceeding who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 10. The best interest and permanent welfare of the children will be served by granting the relief requested because Plaintiff serves as primary care giver of the children and it is in their best interest to maintain that relationship. 11. Each parent whose parental rights to the children have not been terminated and the person who has custody of the children have been named as parties to this action. WHEREFORE, Plaintiff, Kathryn Rogers, requests this Honorable Court to grant her shared legal and primary physical custody. Respectfully submitted, RBAGBR , ADLER, PC Datel April 8, 1996 BYI I) Ii' '" DB BRA A. DENISON, BSQUIRB ) 3 Theresa Barrett Hale Supreme Court 146439 10 south Harket square Suite 500 Hsrrisburg, fA 17101 (717) 233-3220 Attorney For Detendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN ROGERS, Plaintiff v. NO. 96-1877 civil Term MARK L. ROGERS, Defendant CIVIL ACTION - CUSTODY ACCEPTANCE OF SERVICE On behalf of Defendant Mark L. Rogers, I hereby accept Rervice of the Complaint for custody and Order soheduling a conciliation conference for May 9, 1996 at 3:00 p.m. in the above action and certify that I am authorized to do so. :Z:~J:i vu::tf ae<- Theresa Barrett Male, Esquire Date: 1jU!J6 KATHRYN ROGERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. MARK L. ROGERS, Defendent CIVIL ACTION. LAW NO. 96-1877 CIVIL TERM CUSTODY 0t 0~ "~';' ~ AND NOW, this ~ l~ day of J" ._J'> t,... , 1996, upon rec~dt of ;'f -<." 0'\ !;.i.. the Conciliator's Report, It appeerlng that the parties have agreed to the teJW~ an~ ~.!; ~ provisions of this Order which was dictated in their presence and approved oy thl!r ORDER ;1 :~ r:mlii! I.' :J '. ) J. .:5. 'i ~ and their counsel, it Is hereby ordered and directed as follows: 1. The parties shall share legal custody of their minor children, Sara M. Rogers, d.o.b. 2 May 1989, and Elaine L. Rogers, d.o.b. 19 February 1992. 2. Mother shall hava primary physical custody of the minor children subject to periods of partial custody and visitation with Father as follows: A. On alternating weekends beginning on Friday at 4:30 p.m. until Monday morning at which time Father will return the children either to sohool or the parties' day care provider. B. Every Wednesday from 4:30 p.m. until Thursday morning at which time Father will return tha children either to school or to the parties' day care provider. 3. The parties shall elternete the following major holidays: Easter, Memorial Day, Fourth of July, Labor Day, and Thanksgiving. These periods of partial custody and visitation shall be from 9:00 a.m. until 6:30 p.m., except that on Memorial Day and Labor Day, they shall include the entire weekend from Friday at 4:30 p.m. until Monday at 6:30 p.m. Mother shall hava Memorlel Dey In 1996, and the schedule shall alternate thereafter. 4. The Christmas holiday shall be broken into two segments. Segment A shall occur from when the children are released from school until 25 December at 10:00 a.m. Segment B shall occur from 25 December at 10:00 a.m. until 27 December at 10:00 a.m. Mother shall have Segment A in 1996 and all even-numbered years thereafter, while Father shell have Segment A In 1 997 end all odd-numbered years theraafter. 5. During the summer months, Father shall have the children for five (5) weeks and shall be entitled to have them for no more than two consecutive weeks at a time. In addition, Mother shell be entitled to three (3) weeks of uninterrupted custody with the children with no more then two consecutive weeks at a time. Mother shall provide Fether with notice by 1 February of eech year as to which weeks she Intends to exercise her vacation period. Thereafter, Father Is entitled to choose the remaining five weeks. 6. Mother shall have the children on Mother's Day, and Father shall have the children on Father's Day. These periods of partial custody shall occur from 9:00 a.m. until 6:30 p.m. The parties shall share transportation In that the party that Is assuming custody shall provide the transportation to begin that custodial period. 7. The parties agree that the children shall have reasonable telephone access with the other parent while the children ere In their respective custody. BY THE COURT, J. Debra Denison, Esquire Attorney for Plaintiff ~e-F.w (l'~'.t "16/9&'. ...s. ('. Theresa Barrett Male, Esquire Attorney for Defendent mlb KATHRYN ROGERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. MARK L. ROGERS, Dofendant CIVIL ACTION - LAW NO. 96.1877 CIVIL TERM CUSTODY JUDGE PREVIOUSLY ASSIGNED: None (No Judicial Conflicts) CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 191 5.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent Information concerning the chlld(renl who Is(are) the subject of this litigation Is as follows: NAME BIRTHDA TE CURRENTLY IN CUSTODY OF Sara M. Rogers Elaine L. Rogers 2 May 1989 19 February 1992 Plaintiff Plaintiff 2. A Conciliation Conference was held on 30 May 1996, and the following Individuals were present: the Plaintiff and her attorney, Debra Denison, Esquire; the Defendant appeared with his attorney, Theresa Barrett Male, Esquire. 3. Items resolved by agreement: See attached Order. 4. Issues yet to be resolved: See attached Order. 1 5. The Plaintiff's position on custody Is as follows: See attached Order. 6. The Defendsnt's position on custody Is as follows: See attached Order. 7. Need for separate counsel to represent children: Neither party requested and the Conciliator does not believe any Is necessary. 8. Need for Independent psychological evaluation or counseling: None requested. Date: 3 June 1 996 '\ J} 'I ,1 / I II V (1.._ ! f' Michael L. Bangs Custody Conciliator I 2