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Home My WebLink About96-05749 ~ ..... . ... ") .... . --'<", :;;;.' "i#' , -~~1 il '.,.t .~._~ .~ JOHN L. SHOPE, JR., Plaintiff : IN TilE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSVLVANIA : Defendant CIVIL ACTION . LAW 96.57 tfdlVIL TERM IN CUSTODY v LOIS L. SHOPE, 9RPER OF COURT AND NOW, this .al.!.f.\day of fr\ob, 1996, in consideration of the attached petition, it Is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esquire, the conciliator, on the 4th Floor of the Cumberland County Courthouse on the ~~day of Nw('",J,t1" 1996 at /(),'Jv J1.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. All children age five or older may also be present at the conference, Failure to appear at this conference may provide grounds for entry of a temporary or pennanent order. By the Court, --- YOU SHOULD TAKE TillS PAPER TO YOUR LAWVER AT ONCE. IF YOU DO NOT HAVE A LAWVEll OR CANNOT AFFORD ONE, GO TO on TELEPHONE TilE OFFICE SET FOItTH BELOW TO FIND OUT WIIERE YOU CAN GET LEGAL IIELP. Court Administrator Cumberland County Courthouse I Courthou&e Square Carlisle, Pennsylvania 17013 (717) 240-6200 OF n~Lf(?~ 'I 1\'1TMY 96 nr.r 24 PH 31 IS ell"" , nj~':JjJ '," ,',,, , , . " L' .' 'I"IY ',:dNS\1.I'.<WE\v , /Cav.fll !M ';-;7.~~ ;f. '"4 'J!(t.c'~ ,r; c.Jl/ ' fit. 7,~ ,?J(I!4~ ~ d~ )/)0I1('Y6 /~ ~~ .M1 I:#&~p ;~- i I , i I 1 I I r JOHN L. SHOPE, JR., PlalntllT : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION . LAW 96-', j"bVIL TERM LOIS L. SHOPE, Defendant IN CUSTODY PETITION FOR CUSTODY AND NOW comes the Plaintiff, John L. Shope, Jr,. by his attorneys, Irwin, McKnIght & Hughes, and presents the following Petition for Custody, 1. The Plaintiff is John L, Shope, Jr., an adult individual residing at 607 East Keller Street, Mechanlcsburg, Cumberland County, Pennsylvania 17055, 2, The Defendant is Lois L, Shope, an adult individual residing at 626 Woodland Avenue, Mount Holly Springs, Cumberland County, Pennsylvania 17065, ], The parties are the natural parents of three children, namely, John L, Shope, III, born May 15, 1986, Christopher A, Shope, born January 19, 1985, and Ashley L, Shope. born January 19, 1985. 4. The PlalntllT has enjoyed periods of partial custody and the detendant has maintained primary physical custody of the children since 1985. 5, The PlalntilT believes that the best interests of the children require that they be permitted to live with him instead of the defendant, 6, PlaintllT desires primary physical custody of the children and Joint legal custody with periods of visitation to Defendant as can be mutually arranged between the parties, 7. The best Interests and pennanent welfare of the children require that primary physical and shared legal custody of the children be as provided above. WHEREFORE, Plaintiff, John L, Shope, Jr, respectfully requests that he be awarded primary physical custody and primary legal custody of the children as provided herein, Respectfully submitted. BYI Date: October 111,1906 . . . . ~ The foregoing document is based upon Information which has been gathered by my counsel and me In the preparation of this actlon, The language of the document may in part be the language of my counsel and not my own, I have read the statements made In this document and to the extent that it Is based upon information which I have given to my counsel, it Is true and correct to the best of my knowledge, Information and belief, To the extent that the contents of the statements are that of counsel, I have relied upon counsel in making this verification, I understand that false statements herein made are subject to the penalties of 18 Pa.C,S,A, Section 4904, relating to unsworn falsification to authorities, /~ti SHOPB,IE Datel Oct /& .1996 . ... 'pi JOHN L. SHOPE, JR. , , IN THE COURT OF COMMON PLEAS OF Plaintiff , CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW : LOIS L. SHOPE, , NO. 96 - 5749 CIVIL TERM Defendant : , CIVIL ACTION - CUSTODY COURT ORDER AND NOW, this " tl day of --Jzn..., l>., oonsideration of the attaohed Custody Conoi~iation ordered and direoted as follows: , 199'/, upon Report, it is 1. All prior oustody orders entered in this oase are vaoated. 2. The Mother, Lois L. Shope, and the Father, John L. Shope, Jr., shall enjoy shared legal oustody of John L. Shope, III, born May 15,1983, ChristopherA. Shope, born January 19,1985 and Ashley L. Shope, born January 19, 1985. 3. The Mother shall enjoy primary physioal oustody of the minor ohildren. 4. The Father shall enjoy periods of temporary physioal oustody of the minor children as follows: A. On alternating weekends. B. On alternating holidays. C. At such other times as agreed upon by the parties. 5. For Christmas 1996, Father shall have custody of the minor ohildren from Christmas Day at 2:00 p.m. until Sunday, December 29 at 7:00 p.m. 6. The parties shall meet with the Custody Conciliator again for a conoiliation conference on Friday, February 28, 1997 at 8:30 a.m. in the 4th Floor Conferenoe Room, Cumberland County Courthouse. 7. This Order is entered pursuant to an agreement reached by the parties at a custody conciliation conferenoe and is a temporary order and shall not prejudice either party from advanoing a contrary position at a hearing in this case. -' 8. The parties shall submit themselves to some type of family counseling as arranged between the parties and their attorneys. The parties shall cooperate in that counseling and also insure that the children are involved in any counseling as required by the counselor. By the court, --J .tU,~ oi/s J: eel Michael A, Scherer, Bsquire _ ~""-m......t.t 1/7"',." Marcus A, McKnight, III, Esquire .., .a, '-, , . -. JOHN L. SHOPE, JR, , 1 IN THE COURT OF COMMON PLEAS OF Plaintiff 1 CUMBERLAND COUNTY, PENNSYLVANIA 1 v. 1 CIVIL ACTION - LAW 1 LOIS L. SHOPE, 1 NO. 96 - 5749 CIVIL TERM Defendant 1 1 CIVIL ACTION - CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following reportl 1. The information pertaining to the children who are subject of this litigation is as folloWSI John L. Shope, III, born May 15, 1983 Christopher A, Shope, born January 19, 1985 Ashley L. Shope, born January 19, 1985 2, A Conciliation Conference was held on December 20, 1996. Present Were the Father, John L. Shope, Jr., with his counsel Marcus McKnight, Esquire, and the Mother, Lois L. Shope, with her counsel Michael Scherer, Esquire. 3, The parties agreed to the entry of an order in the form as attached. /.l3/.Q7 Date .,.. .' . ., ! ! . \ }"? :" / i ) t'r JOHN L. SHOPE, JR., Plaintiff V , IN THE COURT OF COMMON PLEAS OF ,CUMBERLAND COUNTY, PENNSYLVANIA , ,CIVIL ACTION - LAW r rNOr 96 - 5749 CIVIL TERM r rCIVIL ACTION - CUSTODY LOIS L. SHOPE, Defendant Prior Judger G88~gg F ~~ifvr "I.\)U\11 0\(1', J"f". COURT ORDER AND NOW, this \ '1 ~ day of 1M ~ rc..L. ,1997, upon consideration of 1JIeIattaohed Custody Conoiliation Report, it is ordered and directed as followsr 1, All prior custody orders entered in this case are vacated. 2. The Mother, Lois L. Shope, and the Father, John L. Shope, Jr., shall enjoy shared legal custody of John L. Shope, III, born May 15, 1983; Christopher A. Shope, born January 19, 1985 and Ashley L. Shope, born January 19, 1985. 3. The Mother shall enjoy primary physical oustody of the minor children. 4, The Father shall enjoy periods of temporary physical custody of the minor children as followsr A. On alternating weekends from Friday evening until Sunday evening. B. On alternating holidays to include Easter, Memorial Day, July 4, Labor Day and Thanksgiving. Mother shall have the children for Easter 1997 with the parties alternating thereafter. C. At such other times as agreed upon by the parties. 5. For the Christmas holiday, the Mother shall have custody from Christmas Eve until Christmas Day at 2rOO P.M. with the Father enjoying custody from Christmas Day at 2rOO P.M. until December 26 at 2rOO P.M. The parties shall also work to arrange some equal sharing of some time over the Christmas vacation. , . ... 6. 7. 8. 9. 10. CCI The summer months shall be split equally with the Father having the second portion of the summer from July 15 until three days before the start of school when Father shall deliver the children back to the Mother. The Father shall be sensitive to the children's social! athletic schedule and be flexible in modifying his periods of temporary custody to allow those periods of temporary custody to adjust for the children's schedule and preferences. Both parties shall enjoy reasonable telephone contact with the children when they do not have custody. Father shall also enjoy temporary custody on the first day of hunting season of each year as long as that day is a vacation from school day for the children. Assuming that hunting day shall be on a Monday, Father's period of custody shall be from Sunday evening through Monday evening. This Order is entered pursuant to an agreement reached by the parties at a Custody Conoiliation Conference. In the event either party desires to modify this Order, that party may petition the Court to have the oase again scheduled with a Custody Conciliator. Marous A. McKnight, III, Lois L. Shope 626 Woodland Avenue Mt. Holly Springs, PA BY THE COURT, ;] . td. do o~ /..-J. Esquire I _ c.,.,.,u...... ,ll>."'("{ 3/('1 '1'1. -Y ..s. r', 17065 . ,. .IJI<. JOHN L. SHOPE, JR., plaintiff V :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : :CIVIL ACTION - LAW : :NO: 96 - 5749 CIVIL TERM : :CIVIL ACTION - CUSTODY LOIS L. SHOPE, Defendant Prior Judge: George E. Hoffer 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 reportl 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: John L. Shope, III, born May 15, 1983 Christopher A. SJlope, born January 19, 1985 Ashley L. Shope, born January 19, 1985 2. A Conciliation Conference was held on March 4, 1997. present were the Father, John L. Shope, Jr. with his counsel Marcus McKnight, Esquire/ and the Mother, Lois L. Shope, who appeared without counsel. 3. The parties agreed to the entry of an order in the form as attached. ,~~1 q7