HomeMy WebLinkAbout02-5995
IN THE COURT OF COMMON PLEAS OF
THE 39th JUDICIAL DISTRICT OF PENNSYLVANIA
FRANKLIN COUNTY BRANCH
Jamie M. Strayer, ) Civil Action - Law
Plaintiff, )
) UJ.- 57iq~ ~
vs. ) No.
)
Steven R. Strayer, )
Defendant, ) (Custody)
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against the claims set forth in
the following pages, you must take prompt action. You are warned that if you fail to do so,
the case may proceed without you and a Order of Court for Custody may be entered
against you by the Court. A judgment may also be entered against you for any other claim
or relief requested in these papers by the Plaintiff. You may lose money or property or
other rights important to you, including custody or visitation of your children.
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.
Pennsylvania Bar Association
Lawyer Referral Service
1-800-692-7375 (PA Only) or
(717) 238-6715
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Franklin 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 be made at least 72 hours prior
to any hearing or business before the court. You must attend the scheduled conference
or hearing.
IN THE COURT OF COMMON PLEAS OF
THE JUDICIAL DISTRICT OF PENNSYLVANIA
CUMBERLAND COUNTY BRANCH
Jamie M. Strayer, )
Plaintiff, )
)
vs. )
)
Steven R. Strayer, )
Defendant, )
Civil Action - Law
No.
Custody
COMPLAINT FOR CUSTODY
1. The Plaintiff is Jamie M. Strayer (natural mother) residing at 914 Baltimore
Road, Shippensburg, Cumberland County, Pennsylvania 17257.
2. The Defendant is Steven R. Strayer (natural father) residing at 324 Airport
Road, Shippensburg, Cumberland County, Pennsylvania 17257.
3. Plaintiff seeks custody of the following children:
Name
Cierra Jane Strayer
Address
914 Baltimore Rd. (Part-time)
Shippensburg, PA 17257
and
324 Airport Road (Part-time)
Shippensburg, PA 17257
Age
4 years (DOB 1/2/98)
Skye Marie Strayer
914 Baltimore Rd. (Part-time)
Shippensburg, PA 17257
and
324 Airport Road (Part-time)
Shippensburg, PA 17257
1 year (DOB 4/1/01)
The children are presently in the shared custody of both natural parents at the
addresses noted above.
During the past five years the children have resided with the following persons and
at the following addresses:
Name
Steven R. Strayer (part-time)
Address
324 Airport Road
Shippensburg, PA 17257
Date
June 2, 2002
to present
Jaime Strayer (part-time)
Ron Koser
Gloria Koser
Jody Koser
91 4 Baltimore Road
Shippensburg, PA 17257
June 2, 2002
to present
Steven Strayer
Jaime Strayer
324 Airport Road
Shippensburg, PA 17257
October 1997
to June 2,
2002
The mother of the children is Jamie M. Strayer, 914 Baltimore Road,
Shippensburg, Cumberland County, Pennsylvania 17257.
The father of the children is Steven R. Strayer 324 Baltimore Road, Shippensburg,
Cumberland County, Pennsylvania 17257.
4. The relationship of Plaintiff to the children is that of natural mother. The
Plaintiff currently resides with the following persons:
Name
Cierra Jane Strayer
Skye Marie Strayer
Relationship
daughter
daughter
5. The relationship of Defendant to the children is that of natural father. The
Defendant currently resides with the following persons:
Name
Cierra Jane Strayer
Skye Marie Strayer
Relationship
daughter
daughter
6. Plaintiff, Jamie M. Strayer, is represented by Lynn Y. MacBride, Esquire with
regard to this matter.
7. Defendant, Steven R. Strayer, is represented by Richard L. Webber, Jr.,
Esquire with regard to this matter.
8. 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 any other court.
Plaintiff has no information of a custody proceeding conceming the children pending
in a Court of this Commonwealth.
Plaintiff does not know of a person not a party to the proceedings who has physical
custody of the children or claims to have custody or visitation rights with respect to the
children.
9. The best interests and permanent welfare of the children will be served by
granting the relief requested because the parties have reached an agreement with regard
to the children's needs at this point in time.
10. Each parent whose parental rights to the children have not been terminated
and the person who has physical custody of the children 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 children will be given notice of the pendency of this action and
right to intervene:
NONE
11. A copy of this Complaint will be provided to Richard L. Webber, Jr., Esquire
of Weigle, Perkins & Associates, 126 E. King Street, Shippensburg, Pennsylvania 17257.
BARLEY, SNYDER, SENFT & COHEN, LLC
By:
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I verify that the statements made in this Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
Date: I~~~ ~
~flnv'ln. 1b~
Jami M. Strayer, Plaintiff
1117240
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
Jaime M. Strayer, ) Civil Action - Law
Plaintiff, )
)
vs. ) No.
)
Steven R. Strayer, )
Defendant, ) Custody
STIPULATION AND AGREEMENT
This Stipulation and Agreement is made this Md. day of ])eavnk.i , 2002 by and
between Jaime M. Strayer of 914 Baltimore Road, Shippensburg, Cumberland County,
Pennsylvania, hereinafter referred to as "Jaime" and Steven R. Strayer of 324 Airport Road,
Cumberland County, Pennsylvania, hereinafter referred to as "Steven".
1. Steven and Jaime the natural parents ofCierra Jane Strayer, born January 2, 1998, and
Skye Marie Strayer, born April 1,2001, hereinafter referred to as "the children".
2. Jaime and Steven were married at the time of the birth of the children.
3. None of the parties know of any person not a party to the proceedings who has physical
custody ofthe children, or claims to have custody or visitation rights with respect to the children.
4. Neither party has participated as a party or witness, or in any other capacity, in other
litigation concerning the custody ofthe children in this or any other Court.
5. None of the parties has infonnation of a custody proceeding concerning the children
pending in this Court or any Court of this Commonwealth.
6. During the last five years, the children have resided with the fOllowing persons and at the
following addresses:
Name
Steven R. Strayer (part-time)
Address
324 Airport Road
Shippensburg, PAl 7257
Date
June 2, 2002 to
present
Jaime Strayer (part-time)
914 Baltimore Road
June 2, 2002 to
. ~
Name
Ron Koser
Gloria Koser
Jody Koser
Address
Shippensburg, P A 17257
Date
present
Steven Strayer
Jaime Strayer
324 Airport Road
Shippensburg, P A 17257
October 1997 to
June 2, 2002
7. Plaintiff, Jaime M. Strayer, is represented by Lynn Y. MacBride, Esquire with regard to
this matter.
8. Defendant, Steven R. Strayer, is represented by Richard L. Webber, Esquire with regard
to this matter.
9. The parties have reached an agreement with regard to the custody of the children and
desire to reduce their agreement to an Order of Court.
NOW THEREFORE, the parties intending to be legally bound and waiving their right to be
present when this Agreement and Order are presented and executed hereby stipulate and agree that
the Court may enter the following Order of Court in the above-captioned case:
ORDER OF COURT
NOW, , 2002, upon consideration ofthe within Stipulation
and Agreement, it is hereby ordered as follows:
1. Jamie M. Strayer ("Jaime") and Steven R. Strayer ("Steven") shall have shared legal
custody of children, Cierra 1. Strayer, born January 2, 1998, and Skye M. Strayer, born April 1, 2001
(collectively, the "children").
2. Jaime and Steven shall share physical custody ofthe children as follows:
a. Jamie and Steven shall have custody of the children on an alternating-week basis,
transferring custody each Thursday evening at 7:30 p.m. until the following Thursday at
7:30 p.m.;
b. During Jaime's weeks of physical custody, Steven shall have periods of midweek
custody on Tuesday evenings from 7:00 p.m. until 8:30 p.m., and on Sunday evenings from
7:00 p.m. until 8:30 p.m.
. ,.
c. During Steven's weeks of physical custody, Jaime shall have periods of midweek
custody on Tuesday evenings from 3:30 p.m. until 7:30 p.m., and Sunday evenings from
3:30 p.m. until 7:30 p.m.
3. Holiday custody shall be alternated between the parties as follows:
a. New Years Holiday shall be from 7:30 p.m. on December 31 until 7:30 p.m. on
January 1. The New Years holiday shall be considered to fall in the year in which New
Years day falls;
b. Easter Holiday shall always be with Jaime from 7:30 p.m. the Saturday prior to
Easter until 7:30 p.m. on Easter Sunday, with the exception that Steven shall have custody
for a three-hour period on Easter Sunday. The time to be mutually agreed upon between
Jaime and Steven;
c. Memorial Day Holiday shall be from 7:30 p.m. the Sunday pnor to
Memorial Day until 7:30 p.m. Memorial Day Monday;
d. July 4th Holiday shall always be with Steven from 7:30 p.m. on July 3 until
7:30 p.rn. on July 4t\ with the exception that Jaime shall have custody for a three-hour period
on July 4th. The time to be mutually agreed upon between Jaime and Steven;
e. Labor Day HolidaY' shall be from 7:30 p.m. the Sunday prior to Labor Day until
7:30 p.m. Labor Day Monday;
f. Thanksgiving Holiday shall have two parts, Part I shall be from 7:30 p.m. the
Wednesday prior to Thanksgiving until 3:30 p.m. Thanksgiving Thursday, and Part II shall
be from 3:30 p.m. Thanksgiving Thursday until 3:30 p.m. the Friday following
Thanksgiving;
g. Christmas Holiday shall be in two parts, Part I shall be from 12:00 noon on
December 24 until 12:00 noon on December 25, and Part II shall be from 12:00 noon on
December 25 until 12:00 noon on December 26;
h. In 2002 and each even year thereafter, Jaime shall exercise custody for the
holidays of Easter, Memorial Day, Thanksgiving Part II, and Christmas Part I. Steven shall
exercise custody for New Years, July 4th, Labor Day, Thanksgiving Part I, and Christmas
Part II;
i. In 2003 and each odd year thereafter, Jaime shall exercise custody for the
holidays of New Years, Easter, Labor Day, Thanksgiving Part I, and Christmas Part II;
Steven shall exercise custody for the holidays of Memorial Day, July 4th, Thanksgiving Part
II, and Christmas Part I.
4. Each party shall be entitled to one week of uninterrupted vacation custody. Each shall
advise the other, in writing, at least thirty (30) days prior to their desired vacation time.
5. Each party shall have additional periods of custody as the parties may mutually agree
from time to time.
6. So long as there is shared physical custody between the parties, the parties shall share
dependency exemptions for children for income tax purposes. Jaime shall claim Skye as her
dependent, and Steven shall claim Cierra as his dependent.
By the Court
J.
The parties further agree that, in procuring this Agreement, there has been no fraud,
concealment, overreaching, coercion, or other unfair dealing on the part of the other.
IN WITNESS WHEREOF, the parties, intending to be bound by the tenus and conditions
of this Agreement, execute this Agreement by signing below.
W~~,
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Jai eM. Strayer
Witness:
St,~y1 ~
I verify that the statements made in this Stipulation and Agreement are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
~"~OJ 1rl.~
Jai e M. Strayer . .
I verify that the statements made in this Stipulation and Agreement are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
1104428
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
IJt: C .l 9 2002
Jaime M. Strayer, ) Civil Action - Law
Plaintiff, )
) OJ- 5-qq5 ~
vs. ) No.
)
Steven R. Strayer, )
Defendant, ) Custody
ORDER OF COURT
NOW, O~ 2,7 ,2002, upon consideration of the within Stipulation
and Agreement, it is hereby ordered as follows:
1. Jamie M. Strayer ("Jaime") and Steven R. Strayer ("Steven") shall have shared legal
custody of children, Cierra J. Strayer, born January 2, 1998, and Skye M. Strayer, born April 1, 2001
(collectively, the "children").
2. Jaime and Steven shall share physical custody of the children as follows:
a. Jamie and Steven shall have custody of the children on an alternating-week basis,
transferring custody each Thursday evening at 7:30 p.m. until the following Thursday at
7:30 p.m.;
b. During Jaime's weeks of physical custody, Steven shall have periods of midweek
custody on Tuesday evenings from 7:00 p.m. until 8:30 p.m., and on Sunday evenings from
7:00 p.m. until 8:30 p.m.
c. During Steven's weeks of physical custody, Jaime shall have periods of midweek
custody on Tuesday evenings from 3:30 p.m. until 7:30 p.m., and Sunday evenings from
3:30 p.m. until 7:30 p.m.
3. Holiday custody shall be alternated between the parties as follows:
a. New Years Holiday shall be from 7:30 p.m. on December 31 until 7:30 p.m. on
January 1. The New Years holiday shall be considered to fall in the year in which New
Years day falls;
Cont'd
Jaime M. Strayer v. Steven R. Strayer
Page 2
#
b. Easter Holiday shall always be with Jaime from 7:30 p.m. the Saturday prior to
Easter until 7:30 p.m. on Easter Sunday, with the exception that Steven shall have custody
for a three-hour period on Easter Sunday. The time to be mutually agreed upon between
Jaime and Steven;
c. Memorial Day Holiday shall be from 7:30 p.m. the Sunday pnor to
Memorial Day until 7 :30 p.m. Memorial Day Monday;
d. July 4th Holiday shall always be with Steven from 7:30 p.m. on July 3 until
7:30 p.m. on July 4th, with the exception that Jaime shall have custody for a three-hour period
on July 4th. The time to be mutually agreed upon between Jaime and Steven;
e. Labor Day Holiday shall be from 7:30 p.m. the Sunday prior to Labor Day until
7 :30 p.m. Labor Day Monday;
f. Thanksgiving Holiday shall have two parts, Part I shall be from 7:30 p.m. the
Wednesday prior to Thanksgiving until 3 :30 p.m. Thanksgiving Thursday, and Part II shall
be from 3:30 p.m. Thanksgiving Thursday until 3:30 p.m. the Friday following
Thanksgiving;
g. Christmas Holiday shall be in two parts, Part I shall be from 12:00 noon on
December 24 until 12:00 noon on December 25, and Part II shall be from 12:00 noon on
December 25 until 12:00 noon on December 26;
h. In 2002 and each even year thereafter, Jaime shall exercise custody for the
holidays of Easter, Memorial Day, Thanksgiving Part II, and Christmas Part I. Steven shall
exercise custody for New Years, July 4th, Labor Day, Thanksgiving Part I, and Christmas
Part II;
Cont'd
Jaime M. Strayer v. Steven R. Strayer
Page 3
#
i. In 2003 and each odd year thereafter, Jaime shall exercise custody for the
holidays of New Years, Easter, Labor Day, Thanksgiving Part I, and Christmas Part II;
Steven shall exercise custody for the holidays of Memorial Day, July 4th, Thanksgiving Part
II, and Christmas Part 1.
4. Each party shall be entitled to one week of uninterrupted vacation custody. Each shall
advise the other, in writing, at least thirty (30) days prior to their desired vacation time.
5. Each party shall have additional periods of custody as the parties may mutually agree
from time to time.
6. So long as there is shared physical custody between the parties, the parties shall share
dependency exemptions for children for income tax purposesY'}Jaime shall claim Skye as her
dependent, and Steven shall claim Cierra as his dependent. .l
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JAIME M. (STRAYER) SUDERS, :
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2002-5995
CIVIL TERM
STEVEN R. STRAYER,
Defendant
CIVIL ACTION-LAW
PETITION TO MODIFY CUSTODY
AND NOW, comes Steven R. Strayer, by and through his attorney, Michael A. Scherer,
Esquire, and respectfully represents that:
1. The Petitioner is the Defendant, Steven R. Strayer, (hereinafter referred to as
"Father"), who resides at 9 Independence Drive, Shippensburg, Cumberland County,
Pennsylvania, 17257-8218.
2. The Respondent is the Plaintiff, Jaime M. Suders, (hereinafter referred to as
"Mother"), who resides at 1264 Baltimore Road, Shippensburg, Cumberland County,
Pennsylvania, 17257-9422.
3. The parties are the natural parents of Cierra J. Strayer, born January 2, 1998,
and Skye M. Strayer, born April 1 , 2001, (hereinafter referred to as "children").
4. Father and Mother share physical custody of the children.
5. Father and Mother are governed by an Order entered in this matter on
December 23,2006, which is attached hereto as "Exhibit A."
6. Father finds the present custody Order inconvenient for his children and himself,
given the childrens' activities and Father's work schedule.
7. Father desires to continue to share custody but would like the Order modified
such that there are fewer exchanges of custody.
il
8. Father's work schedule is such that the exchange of custody of the children on
Sunday is inconvenient and disruptive to the childrens' schedules and with various family
activities.
WHEREFORE, Father respectfully requests that the Order entered in this matter on
December 23, 2002 be modified to provide as follows:
a. That the parties have shared physical custody of the children which alternates on
a weekly basis with exchanges occurring each Thursday at the Cleversburg Community
Center; and,
b. That during Mother's week Father has the children each Tuesday evening from
4:30 p.m. until 8:30 p.m. and that during Father's week Mother have the children each
Tuesday evening from 4:30 p.m. until 8:30 p.m. The pickup at 4:30 p.m. shall be at Father's
grandmother's house, and the exchange at 8:30 p.m. shall be at the Cleversburg Community
Center; and
d. That the parties share holidays and that each party have some period of time
with the children for summer vacation.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
4:cu~
Michael A. Scherer, Esquire
1.0. # 61974
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
mas/Domestic/Strayer\modify . pet
. .
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
lJt:c .l , 2002
Jaime M. Strayer, ) Civil Action - Law
Plaintiff, )
) OJ-- ~l{q5 ~
VS. ) No.
)
Steven R. Strayer, )
Defendant, ) Custody
ORDER OF COURT
NOW, O~ 27 ,2002, upon consideration of the within Stipulation
and Agreement, it is hereby ordered as follows:
1. Jamie M. Strayer ("Jaime") and Steven R. Strayer ("Steven'') shall have shared legal
custody of children, Cierra J. Strayer, born January 2, 1998, and Skye M. Strayer, born April 1, 2001
(collectively, the "children'').
2. Jaime and Steven shall share physical custody of the children as follows:
a Jamie and Steven shall have custody of the children on an alternating-week basis,
transferring custody each Thursday evening at 7:30 p.m. until the following Thursday at
7:30 p.m.;
b.. During Jaime's weeks ofphysicaI custody, Steven shall have periods of midweek
custody on Tuesday evenings from 7:00 p.m. until 8:30 p.m., and on Sunday evenings from
7:00 p.m. until 8:30 p.m.
c. During Steven's weeks ofphysicaI custody, Jaime shall have periods of midweek
custody on Tuesday evenings from 3:30 p.m. until 7:30 p.m., and Sunday evenings from
3:30 p.m. until 7:30 p.m.
3. Holiday custody shall be alternated between the parties as follows:
a. New Years Holiday shall be from 7:30 p.m. on December 31 until 7:30 p.m. on
January 1. The New Years holiday shall be considered to fall in the year in which New
Years day falls;
EXHIBIT "A"
Cont'd
Jaime M. Strayer v. Steven R. Strayer
Page 2
#
b. Easter Holiday shall always be with Jaime from 7:30 p.m. the Saturday prior to
Easter until 7:30 p.m. on Easter Sunday, with the exception that Steven shall have custody
for a three-hour period on Easter Sunday. The time to be mutually agreed upon between
Jaime and Steven;
c. Memorial Day Holiday shall be from 7:30 p.m. the Sunday prior to
Memorial Day until 7:30 p.m. Memorial Day Monday;
d. July 4th Holiday shall always be with Steven from 7:30 p.m. on July 3 until
7:30 p.m. on July 4th, with the exception that Jaime shall have custody for a three-hour period
on July 4th. The time to be mutually agreed upon between Jaime and Steven;
e. Labor Day Holiday shall be from 7:30 p.m. the Sunday prior to Labor Day until
7:30 p.m. Labor Day Monday;
f. Thanksgiving Holiday shall have two parts, Part I shall be from 7:30 p.m. the
Wednesday prior to Thanksgiving until 3:30 p.m. Thanksgiving Thursday, and Part II shall
be from 3:30 p.m. Thanksgiving Thursday until 3:30 p.m. the Friday following
Thanksgiving;
g. Christmas Holiday shall be in two parts, Part I shall be from 12:00 noon on
December 24 until 12:00 noon on December 25, and Part II shall be from 12:00 noon on
December 25 unti112:00 noon on December 26;
h. In 2002 and each even year thereafter, Jaime shall exercise custody for the
holidays of Easter, Memorial Day, Thanksgiving Part II, and Christmas Part I. Steven shall
exercise custody for New Years, July 4th, Labor Day, Thanksgiving Part I, and Christmas
Part ll; -
Cont'd
Jaime M. Strayer v. Steven R. Strayer
Page 3
#
i. In 2003 and each odd year thereafter, Jaime shall exercise custody for the
holidays of New Years, Easter, Labor Day, Thanksgiving Part I, and Christmas Part II;
Steven shall exercise custody for the holidays of Memorial Day, July 4th, Thanksgiving Part
II, and Christmas Part I.
4. Each party shall be entitled to one week of uninterrupted vacation custody. Each shall
advise the other, in writing, at least thirty (30) days prior to their desired vacation time.
5. Each party shall have additional periods of custody as the parties may mutually agree
from time to time.
6. So long as there is shared physical custody between the parties, the parties shall share
dependency exemptions for children for income tax purposes Jaime shall claim Skye as her
dependent, and Steven shall claim Cierra as his dependent.
J.
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JAIME M. (STRAYER) SUDERS, :
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002-5995 CIVIL TERM
CIVIL ACTION-LAW
V.
STEVEN R. STRAYER,
Defendant
VERI FICA TION
I verify that the statements made in the foregoing Petition To Modify Custody are true
and correct. I understand that false statements herein are made subject to the penalties of 18
Pa. C.S.A. 9 4904, relating to unsworn falsification to authorities.
Date: May II ,2006
L<~~
Steven Str yer
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JAIME M, (STRAYER) SUDERS
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
02-5995 CIVIL ACTION LAW
STEVEN R STRAYER
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Thursday, May 18,2006
. upon consideration of the attached Complaint.
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq.
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, June 22, 2006
, the conciliator,
at 8:30 AM
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 the conference may
provide grounds for entry of a temporary or permanent order,
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinl!.
FOR THE COURT.
By: /sl
Hubert X Gilroy, Esq.
Custody Conciliator
ff!l'A..
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites 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 be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HA VE AN ATTORNEY 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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RECEl.VED i
AUG 3 1 20116
By:(/l<l __ _=..
JAIME M. (STRAYER) SUDERS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 02-5995 CIVIL ACTION - LAW
STEVEN R. STRAYER,
Defendant
IN CUSTODY
COURT ORDER
AND NOW, this _, yt-- day of September, 2006, upon consideration of the
attached Custody Conciliation Report, it is ordered that this Court's prior Order of
December 23, 2002 is vacated and replaced with the following Order:
1. The Mother, Jaime M. Suders, and the Father, Steven R. Strayer, shall enjoy
shared legal and shared physical custody of Cierra J. Strayer, born January 2,
1998 and Skye M. Strayer, born April 1, 2001.
2. Physical custody shall be handled on a week on/week off basis with exchange of
custody on Sundays at 6:00 p.m. unless agreed otherwise by the parties.
3. On the parties' off week, the parties shall enjoy physical custody of the minor
children on Wednesdays from 4:00 p.m. until 8:00 p.m. or at such other times as
agreed by the parties.
4. Legal counsel for the parties shall conduct a telephone conference call with the
Conciliator on Wednesday, October 4,2006 at 8:00 a.m. At that time, the parties
shall address how the off-week visitation is going and shall determine if shall
remain at one day or whether it needs to be expanded to two days. Additionally,
the parties may address holiday visitation if that is an issue.
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FILED-O~FICE
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2006 SEP -I AM 9: 50
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JAIME M. (STRAYER) SUDERS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 02-5995 CIVIL ACTION - LAW
STEVEN R. STRAYER,
Defendant
IN CUSTODY
Prior Judge: The Honorable Edgar B. Bayley
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CML RULE OF
PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following
report:
I. The pertinent information pertaining to the children who are the subject of this
litigation is as follows:
Cierra J. Strayer, born January 2, 1998
Skye M. Strayer, born April I, 2001
2. A Conciliation Conference was held on August 31, 2006 with the following individuals
in attendance:
The Mother, Jaime M. Suders, with her counsel, Marylou Matas, Esquire
The Father, Steven R. Strayer, with his counsel, Michael A. Scherer, Esquire
3. The parties agreed to the entry of an Order in the form as attached.
Date: August 31, 2006
OCT 1 0 2006 .(
JAIME M. (STRAYER) SUDERS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v
CIVIL ACTION - LAW
STEVEN R. STRAYER,
Defendant
NO. 02-5995
IN CUSTODY
COURT ORDER
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AND NOW, this ~ day of October, 2006, the Conciliator being advised the
parties have reached an agreement, the Conciliation Conference in this matter is cancelled
and Conciliator relinquishes jurisdiction.
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JAIME M. (STRAYER) SUDERS,
Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
NO. 02-5995 CIVIL ACTION - LAW
STEVEN R. STRAYER,
Defendant
IN CUSTODY
COURT ORDER
AND NOW, this 21 day of March, 2007, upon consideration of the attached
Custody Conciliation Report, it is ordered and directed that this Court's prior Order of
September 1, 2006 is vacated and replaced with the following Order:
1. The Mother, Jaime M. Suders, and the Father, Steven R. Strayer, shall enjoy
shared legal and shared physical custody of Cierra J. Strayer, born January 2,
1998 and Skye M. Strayer, born April 1, 2001.
2. Physical custody shall be handled on a week on/week off basis with exchange of
custody on Sundays at 6:00 p.m. unless agreed otherwise by the parties.
3. On the parties' off week, the parties shall enjoy physical custody of the minor
children on Wednesdays from 4:00 p.m. until 8:00 p.m. or at such other times as
agreed by the parties.
4. The parties shall handle summer vacation with each parent having at least one
week of uninterrupted vacation with the minor children. During that week, the
Wednesday evening visitation with the non-custodial parent shall be suspended.
Each parent shall advise the other parent at least 45 days in advance as to when
they intend to exercise the one week of vacation. In the event the one week of
vacation time conflicts with the other parent's scheduled weekly period of
custody, a replacement shall be afforded to that other parent. Additionally,
father shall endeavor to as reasonably as possible to schedule his vacation time
so as not to interfere with the picnic of mother's employer.
5. The holiday schedule shall be handled as follows:
a. New Year's holiday shall be from 6:00 p.m. on December 31 until 6:00
p.m. on January 1. The New Year's holiday shall be considered to fall in
the year in which the New Year's Day falls and shall be alternated by the
parties. Mother shall have the New Year's holiday for the upcoming
December 31-January 1.
b. Easter holiday shall be split with the first part being from 6:00 p.m. on
Saturday to Noon on Easter Sunday and the second part being from
Noon on Easter Sunday to 6:00 p.m. on Sunday. Mother shall enjoy the
first part of the Easter holiday in odd years and the father enjoying the
second part in odd years, with the parties alternating in even years.
c. Memorial Day holiday shall be from 6:00 p.m. the Sunday prior to
Memorial Day until 6:00 p.m. on Memorial Day Monday. Father shall
have Memorial Day 2007 with the parties alternating thereafter.
d. Labor holiday shall be from 6:00 p.m. the Sunday prior to Labor Day
until 6:00 p.m. Labor Day Monday. Mother shall have Labor Day 2007
with parties alternating thereafter.
e. The Thanksgiving holiday shall have two parts, with part one being from
6:00 p.m. the Wednesday prior to Thanksgiving until 3:30 on
Thanksgiving Day, with part two being from 3:30 p.m. Thanksgiving Day
until 3:30 p.m. the Friday following Thanksgiving. Mother shall have
part one in 2007 with father having part two, the parties alternating
thereafter.
f. Christmas holiday shall be split into two parts, with the first part being
from Noon on December 24 until Noon on December 25, and part two
being from Noon on December 25 until Noon on December 26. Father
shall have part one in 2007 with mother having part two, the parties
alternating thereafter.
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g. In addition to holidays and vacations, the parties observe a work picnic
day each year. In 2007, father's picnic day is the Sunday closest to July 4
and mother's picnic day is the first weekend after Labor Day.
h. For Halloween, mother shall have the children on trick or treat night for
Shippensburg in even numbered years and father shall have the children
on trick or treat night in Shippensburg for odd numbered years.
i. The parties may modify this Custody Order as they agree. Absent an
agreement, this Order shall control.
j. In the event either party desires to modify this Order, that party may
Petition the Court to have another conference before the Custody
Conciliator.
k. For purposes of income taxes and based upon an agreement of the parties
and further assuming the Custody Order set forth above remains in
place, the parties shall share exemptions for the children for income tax
purposes. Mother shall claim Skye as her dependent and Steve shall claim
Cierra as his dependent.
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JAIME M. (STRAYER) SUDERS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
NO. 02-5995 CIVIL ACTION - LAW
STEVEN R. STRAYER,
Defendant
IN CUSTODY
Prior Judge: The Honorable Edgar B. Bayley
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
report:
1. The pertinent information pertaining to the children who are the subject of this
litigation is as follows:
Cierra J. Strayer, born January 2,1998
Skye M. Strayer, born April 1, 2001
2. A Conciliation Conference was held on March 21, 2007 with the following
individuals in attendance:
The Mother, Jaime M. Suders, with her counsel, Marylou Matas, Esquire
The Father, Steven R. Strayer, with his counsel, Michael A. Scherer, Esquire
3. The parties agreed to the entry of an Order in the form as attached.
Date: March 22, 2007