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Home My WebLink About00-01485 , \ KAREN M. SHATTO, plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-1485 CIVIL TERM : : CIVIL ACTION - LAW TIMarHY J. SHATTO, Defendant : : CUSTODY ctIDER OF cotIRT AND Naf, this 1(. r consideration of the attached and directed as follows: day of r?~ ' 2000, upon CUstody Conciliat on Report, it is ordered 1. The Mother, Karen M. Shatto, and the Father, Timothy J. Shatto, shall have shared legal custody of Devon A. Shatto, bom December 16, 1995. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have partial physical custody of the Child on altemating weekends, beginning May 20, 2000, from Saturday at 9:00 a.m. through Sunday at 5:00 p.m. The Father shall also have custody of the Child at any other times arranged by agreement of the parties. 4. The parties shall share having custody of the Child on holidays as follows: A. SHARED HOLIDAYS: The parties shall share having custody of the Child on Christmas, New Years Day, Thanksgiving, Easter, Memorial Day, July 4th, and Labor Day, with the Father having custody on the day of each holiday from 10:00 a.m. until 3:00 p.m. and the Mother having custody from 3:00 p.m. until 8:00 p.m.. B. MCfl'IlER'S DAY/FATHER'S DAY: The Mother shall have custody of the Child every year on Mother's Day fran 3:00 p.m. until 8:00 p.m. and the Father shall have custody of the Child on Father's Day every year fran 3:00 p.m. until 8:00 p.m. D. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 5. The Father shall ensure that the Child has adult supervision at all times during his periods of custody. 6. The Father shall ensure that the Child has her own bed to sleep in at the Father's residence. 7. The party receiving custody shall be responsible to provide , 'mwq ~ , "_1,0' , ~ 1t.illIllil!Bli8'_~ 1 ""'''''~l-ifj~i!li1lj:"i<IWIIIl!~mjHt!!i"~!lR. > ~.~'-"I~ , , " ~ ,~ "0 UDil~' ,~ ",- 1iIiIiliIliII~'-'"~ ~.~ 1, * FIL8)-DFfiICE. . Of THE PROTHONOTARY 00 tiff I G Pi'\ 3: 12 CUMB[~RLJ.ND COUNTY PENNSYLVANiA ~- i i , ,'! ">';1>- ~ transportation for the exchange of custody. 8. In the event either party intends to remove the Child from his or her residence for an overnight period or longer, that party shall provide the other party with an address and telephone number where the Child can be contacted. 9. This order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this order by mutual consent. In the absence of mutual consent, the terms of this order shall control. BY THE OJURT, cc: Mary A. Dissinger, Esquire - Counsel for Mother Timothy J. Shatto, Father ", --I' , ~ ~~ .:)-/&-00 RK3 ,~"=- . KAREN M. SHA'l'TO, . IN THE OOURT OF OOMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 00-1485 CIVIL TERM . : . CIVIL ACTION - LAW . TIMOrHY J. SfJATTO, . . Defendant . CUSTODY . COS'.OC.VY C'aiCILIATIClII SUMMARY REPCm IN ACCXIIDANCE WITH COMBERLAND <XXlN'.lY RULE OF CIVIL PROCEDURE 1915.3-8, th~ undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this liti9ation is as follows: NAME DATE OF BIRTH CORRENTLY IN CDSTODY OF ., .1 1 I I 1 ;1 ;! Ii ,i Devon A. Shatto December 16, 1995 Mother 2. A Conciliation Conference was held on May 10, 2000, with the following individuals in attendance: The Mother, Karen M. Shatto, with her counsel, Mary A. Dissinger, Esquire, and the Father, Timothy J. Shatto, who was not represented by counsel in this matter. 3. The parties agreed to entry of an Order in the form as attached. Date ~ 1/ ~O 00 . cOa-JU. ~ DawnS. Sunday, Esquire Custody Conciliator 'Wl! . I' -,-- - 4/- ~. AFFIDAVIT OF MAILING Mary A. Etter Dissinger, Esquire, the attorney ,for Plaintiff, being duly sworn according to law, says that she mailed by United states Certified Mail, Restricted Delivery, a true and correct copy of the Plaintiff's Complaint in Divorce in this action to the Defendant at his residence, and that Defendant did receive same as evidenced by the signed receipt dated 03/15/2000 attached hereto as Exhibit "A". ~~o~:. ' Mary A Etter Dissinger ~ Attorney for Plaintiff Dissinger & Dissinger 28 North 32nd Street Camp Hill, PA 17011 717-975-2840 Sworn to and subs~Eibed befo e me C his ~ day of , 2000. NOT A~!AL SEAL JODI A. McN~EL V, Nat~'l' Pub'ic Maryz\lille Boro. fler;y Couni)' l My Comw..~!;~o~ bpjlW_~~ril ~;!C~:..J "i, ,~~ ,_ > ,,<. - I . -~"". """""'" ~ -~,,., ~~ .~.." .. ., if j Cl ::; Q)@ L-__',_ -/, ~t~_~ ~~~~ ..-c::. ,_r " ~ ,~,' - ":- ~ -,- "- ' ~ -, ,~ CJ ~>>' :'-(J :-.<J ;"'-.) 0" .'-0 () -'n .~JIIffll1~1'Jll~ '~J!I~n~lIi'!l~)fo/~!jiIlji!il~i~\mW!i'1~~!'I!!i!IU"~'~II~~l~!I~~~f!~WIlllj!~ ."," '-''=-'' -. ... 1'1 r=::-: ,......" c,) 'C:: i i-~ ." -'-- -', 'r-~ .f;...j '~. . . ''''J1i'!~~ ~ SENDER: 'iij ~ ~ l!! m S " o '" ~ .ji E 8 " I also wish to receive the follow- ing services (for an extra fee): D Complete items 1 and/or 2 for additional services. Complete items 3, 4a, and 4b. D Print your name and address on the reverse of this form so that we can retum this card to you. D Attach this form to the front of the mallpiece, or on the back jf space does not permit. D Write "Rerum Receipt Requested" on the mailpiece below the article number. C The Retum Receipt will show to whom the article was..delivered and the date delivered. 3. Article Addressed to: TIMOTHY J. SHATTO 141 SPRING ROAD DILLSBURG PA 17ID19 ~- 1. 0 Addressee's Address 2'~Restrjcted Delivery 4a. Article Number Z 328 6,87 502 4b. Service Type o Registered o Express Mail o Return Receipt for Merchandise )6 Certified o Insured oeOD 7. Date of Delivery 03-(5'-00 ~ 8, Addressee's Address (Only if requested and fee is paid) 102595.99-8.0223 Domestic Return Receipt fJ.-OO-S/:I- EXHIBIT "A" . - ail u, ~ rill a; I.; r:: ' ...! a ~-~ "', e , 1i ~I 0' - " g., ..' e, m ~ . o f~"; ~~~, ~~~~' ~~~ z -< ...~ I., . (~ f';::) D> "4 , 'h )0''',-1 . :~;-l '71 CJ ~2~ :~~ / :'9 -.. ;::,~ i'0 (T> ~'TI' ::;z: -.; llIJll1l!ml'M~~r.Jl'II:~" ~. 1i!l1I!':!g~'1ft,~ .~"~ _~,,,,,,,"~~~1;,,-!t-~j!f,~,"""'r~l""J1H\'!>''Jii!'!W.'n1llllIil~~~U!!mPim~m~""='!4,r,NJ~ lII!IIJII~l"<O' , Karen M. Shatto, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA . . vs. : : CIVIL ACTION - CUSTODY Timothy J. Shatto, Defendant . . NO. CIC'C.D- HgS ~ 7efYl1 : ORDER OJ' COURT AND NOW, ~ \ \ c-., 2000, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before ~~~ s,s~~ the conciliator, at 39 \,J, \J..Q\\'I.:st-'\\-\C~\C~lrh. on the \Q day of ~ , 2000, at ~ ..12L.m., for a Pre-Hearing cuatody 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 the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: ~~ ,~<Uif\dnel~ Custody Conciliator . ~,l The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must by made at least 72 hours prior to any hearing or business before the court. You must attend scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 '-WJJ~ '''~ - ia~i!!el!liliill!l~~!I.!i~~W~i",,~!l!ii<lliiM/;J!ifufuihhW."fiWl,"~i,;<~~~L" .'" ;""~I ~ H I.. 3~~ 3~ a:> :} ;,)Q) '00 jUBUlt;lJldlW~lill ~ Cli Pl'.\-n~F\CE , _~. J VI r-. ., >,. ->-~~ll"l~'~'fAPY 't" i 1-,1,'- i-,I_;~ \ ].'.: '(.I '"\n .). ",., ' ,>c.," j _." ",~ " 00 Mi'\R 22 PH 12: 34 CUMBERLi'-ND COUr~TY PENNSYLVANIA ~ . &vi. ~ ~ ~ ~ fJj4-'~ ~ ~ z,J/ ~~-;.~~. ~"'"'.~~ lilli ~.:..- Karen M. Shatto, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. CIVIL ACTION - CUSTODY Timothy J. Shatto, Defendant . . NO. NOTICB TO DBI'BND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL : HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE PA 17013 717-249-3166 ~d(;:~ ~ j Mary . E ter D1ss1nger, Esquire Attorney for Plaintiff ;'-^."~,- - -1",__' . ~ II ,'- " I Karen M. Shatto, Plaintiff vs. . IN THE COURT OF COMMON PLEAS . . OF CUMBERLAND . . PENNSYLVANIA . . . : CIVIL ACTION - CUSTODY . . ;)000 - /41?s . NO. . Timothy J. Shatto, Defendant COMPLAINT FOR CUSTODY 1. Plaintiff is Karen M. Shatto, residing at 121B South 2nd Street, cumberland County, Pennsylvania. 2. Defendant is Timothy J. Shatto, residing at 141 Spring Road, Cumberland county, Pennsylvania. 3. Karen M. Shatto seeks custody of the following child, Devon A. Shatto: Name Devon A. Shatto Present Residence 121B South 2nd Street Lemoyne, PA 17043 Age 4 4. The child was not born out of wedlock. 5. The child, Devon A. Shatto, is presently in the custody of Karen M. Shatto who resides at 121B South 2nd Street, Lemoyne, Cumberland County, Pennsylvania. , 6. During the past five years, the child, Devon A. Shatto has resided with the following persons at the following addresses: Persons Addresses Date Karen M. Shatto 121B South 2nd Street,Lemoyne,PA 3/01/99 Lemoyne, PA to present Karen M. Shatto Carol Bingaman Stan Bingaman 760 South 80th Street Harrisburg, PA 9/18/98 until 3/01/99 .l~~ ", I - , " , Karen M. Shatto Timothy J. Shatto 602 Bay Street, Mechanicsburg,PA 11/ /95 until 9/18/98 7. The mother of the child, Devon A. Shatto is Karen M. Shatto who currently resides at 121B South 2nd street,Lemoyne,cumberland County, Pennsylvania. 8. She is single. 9. The father of the child, Devon A. Shatto is Timothy J. Shatto who currently resides at 141 Spring Road, Dillsburg, York County, Pennsylvania. 10. He is single. 11. The relationship of Plaintiff to the child, Devon A. Shatto is that of mother. The Plaintiff currently resides with only the child. 12. The relationship of Defendant to the child, Devon A. Shatto is that of father. The Defendant currently resides with his Parents. I 13. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child Devon A. Shatto in this or another court. 14. Plaintiff concerning the Commonwealth. has no information of a custody proceeding child Devon A. Shatto pending in a court of this ':-ilcUl! ~I , '~-^'" -- '; ", 15. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child Devon A. Shatto or claims to have custody or visitation rights with respect to the child Devon A. Shatto. 16. The best interest and permanent welfare of the child Devon A. Shatto will be served by granting the relief requested because . Plaintiff has been the primary caregiver, and the child has always remained with her. 17. Each parent whose parental rights to the child Devon A. Shatto has not been terminated and the person who has physical custody of the child, Devon A. Shatto, have been named as parties to this action. All other persons, named below who are known to have or claim a right to custody or visitation of the child, Devon A. Shatto, will be given notice of the pendency of this action and the right to intervene: WHEREFORE, Plaintiff requests the Court to grant custody of the child Devon A. Shatto to Karen M. Shatto. Respectfully Submitted: DISSINGER & DISSINGER By: ~~<< ~ ___~. Mary A. D1ssinger, Esquire Attorney for Plaintiff Supreme Court I.D. #27736 28 N 32nd Street Camp Hill, PA 17011 (717) 975-2840 -, ..' -~ ").Il/III,~,.~ VERIFICATION I, Karen M. Shatto, verify that the statements made in the Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn falsification to authorities. ~#~~ K r n M. . hat 0, ~intJ.ff I -