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Home My WebLink About97-03084 ~ \l '" . .. e-.. ~ .... '" '> \. \l I? ... ~ 0-- ,--0 "- ~\ \ ~ -- r-' ,- '"9. (~~ c.: '. ci p: .. . ~ ~.'t. 0 ,,: 0- UI~ . '. l{) cy ..,. ,I. ~ 00 0 -, ~~.: l!- ~ .., ',::.I . .9 M :.~ , e' C':l "ir') ~ In , . 0' 1.,1': l,t. ,z ~ it f.:', , i'.t-f ltJ I " ; ~n~ ct. .. \: c- " cJ u .- u " ~:!l ~~ Ul Ul llttll ~ ~ ~~ \loI 01.1 " \loI l::l .. ti z .", I'll ~ kI ~ lilt 01.1 'tl fi1 l::l l::l ::J ~ 0: ~ ~ ~ o . :J: ..:l ..", . Ql I u ~ U~ ~ M C3~ . C3~ ~ lj Z Z - g Z VI ~ ffi" .. r.. ~ tIlllt > tIlC 0 :! .. o I U M H ~ ~r . 0 t!l t!l ~ :.: ~ ~ E-<U :z: :z: :z: Z :> ~ S M H ".. ~ tIl tIl ~ N - 81 E3 Z . . " x ~ ~ ~ III ..:l ~ ~ ~ ::! :z:~ ~ 0 B 0 U MU U :z: tIl tIl _. dO. -.,.. <. -. @ . JUN 11199\ I ^"" tJtlli", MAUUN It f'o.h l-AU:U SCOTT B. SINGISER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - NO. ql - 308"1 CUSTODY CIVIL LAW SARAH L. SINGISER, Defendant ORDER OF COURT AND NOW, ..J'.Jf\'"e II . , 1997, upon consideration of the attached Complaint, it is hereby directed that the parties and their r~spect~ve counsel appear before , the conciliator, at :A on the :\ \ day of , 1997, at I \ '.(~ .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 the conference may provide grounds for entry of a temporary or permanent order. 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 be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. FOR THE COURT: By: ~\\J'f\. ~. ~Ulf'\.~, Custo y Conciliator (~) 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. Court Administrator Fourth Floor Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania 17013 (717) 240-6200 - SCOTT B. SINGISER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. (/7. 3of'l CIVIL CUSTODY SARAH L. SINGISER, Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff herein is SCOTT B. SINGISER, residing at 718 South Market Street, Borough of Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant herein is SARAH L. SINGISER, residing at 65 North Middleton Road, Carlisle (North Middleton Township), Cumberland County, Pennsylvania. 3. The Plaintiff seeks custody of the following child: Name Present Residence ~ Amanda Jo Singiser 65 North Middleton Road 10 years Carlisle, PA 17013 Zachary Scott Singiser 65 North Middleton Road 8 years Carlisle, PA 17013 The children were not born out of wedlock. The children is presently in the physical custody of the Defendant at the residence set forth in Paragraph 2, above. During the past five years, the children have resided with the following persons and at the following addresses: Persons Addresses Dates Sarah L. Singiser, Lawrence Failor, Emma Failor, IAWlI"t(I', Keisha Nolan, MA"UN " M, CAtUl Cody Fai lor. * 65 North Middleton Road Carlisle, PA 17013 8/89 to date (* From 1989 through 1995, Defendant's brother, lAW .lll!! I', MAIH.lN If MIl ^II~II Plaintiff has no information of any other custody proceedings concerning the children pending in a court in 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. 7. The best interests and permanent welfare of the children will be served by granting the relief requested because: (a) Since the Plaintiff and Defendant separated and were subsequently divorced, Plaintiff has maintained a close and loving relationship with both children and has enjoyed liberal visitations with and partial custody of them; (b) Defendant plans to move to Texas in the near future to live with her boyfriend; (c) Plaintiff believes and therefore avers that Defendant's pending move to Texas is not work- related, nor due to any job promotion or career advancement; (d) Virtually all of the maternal and paternal family and relatives of the children reside in this general area and none presently reside in Texas; (e) Plaint~ff can provide a good home and proper environment in which to raise the children; (f) It is in the best interests of the children to reside with their father in order to maintain and continue an ongoing close and loving relationship with him and with their family and relatives; (g) Defendant agrees that it is in the best interests of the children to live with their father. 8. Each parent whose parental rights to the children have not been terminated and the persons who have physical custody -3- .... ell i:: 1J; ..'~ i~' .. ti: plr~ ..-.. -;."",' ',- .-...'. ',1; (' . ':',< ....., .:;.. l~ .. .:~: ,":\ If'L. ~:.,.l v 0:. ~" . G'; ..'J I I I..'.: ". ., b.P1 .. , 1"'"" . , t:! '.',;J r:: ~\.~l~ , ,..~ It, I" U .J ", W ii 1m ~~~ ~ o! I ~8 II: :; 81 s:;: u t:l I tol < >< iS~ ..:I:;; ~ II: ~ . III I-l uiB lioI lioI .... ., ..~ Cl~ 1Illl< I-l t!l II: I-l III . III ~ III . III l> ., c:: nl 'tl .m Clliol III 8 I-l Ii I-l III E-o ~ tl i3r..1-l ~o~ ~ III . ..:I ~ III III ~ !l ~ !: ~~ '" ~ ~ t1 ~ ~ ~ ~ u "II: ~ ~ ,.. .. '" z z ~ ~ ffi~H ~ ~ B~~ f!!! il N z C :t U '" 2 , . . . . . (!)~ ~~~ ~ ~I~~ =' ill tIS ::J'Ji ... ttj .... ~~ ~.g.a~!: ~~u~~ ~~ - - I cn< ... /1( iii. - .9 Do .... , ~ . ~ c , I" r ffl'ftl . ~~ ~~ IOtIli ! :I! (!)~ ~8 l1J = S'~'3 1Ilp:: ~2: ~~g~- ~ Jl _..~ ~ ~~~ ~ ~ ~~ - t::: - '" ~f;t,Cli,,", r5 III III :;; . . m ~ ell ~ ~ I E-o ~ ~ .- .' . .. -' .. ., . SCOTT B. SINGISER, Plaintiff IN THE COURT OF COOMOO PLEAS OF : CUMBERLAND~, PENNSYLVANIA . . vs. : NO. 97-3064 CIVIL TERM . . SARAH L. SINGISER, Defendant CIVIL ACTION - LAW IN CUSTODY aIDER OF <XXJRT AND lQ, this 11. ~ day of &~... , 1997, upon consideration of the attached Custody Conciliatiori Report, it is ordered and directed as follows: I. The Father, Scott B. Singiser, and the Mother, Sarah L. Singiser, shall have shared legal custody of Amanda Jo Singiser, born April 26, 1987, and Zachary Scott Singiser, born September 27, 1988. 2. The Father shall have primary physical custody of the Children. 3. The Mother shall have partial physical custody of the Children as set forth in a separate Custody Stipulation to be submitted to the Court by the Father's counsel. 4. The maternal grandparents, Lawrence ~I. Faillor, Sr., and Emna Alice Faillor, shall have partial custody of the Children one weekend per month from Friday after school until Sunday at 8:00 p.m. The monthly weekend period of custody shall be scheduled on the weekend that the Father works the four (4) night weekend shift. 5. In addition, the maternal grandparents shall have custody of the Children for one week during each sUIllllE!r (from Sunday through Sunday) upon providing notice to the Father by May 30 of each year. The maternal grandparents shall also have custody of the Children to go on camping trips over the Memorial Day and July 4th holidays, with specific arrangements to be made by mutual agreement between the Father and the maternal grandparents. 6. The parties agree that the maternal grandparents' periods of custody with the Children shall be subject to and subordinate to the Mother's periods of partial custody set forth by Stipulation. 7. The maternal grandparents may have additional periods of custody with the Children as agreed between the Father and the maternal grandparents. 8. This Order is entered pursuant to an agreement at a Custodoy conciliation Conference. The provisions of this Order may be modified by I ~ ~I ~ ~ ..::J ,- ";;- lJ.Jr--) 0; ::1 .... (.) -:;. ():...'0 I~!,.,.' - 0.~~~ t,~ _', ..... 91.. ...-:: '-"1- .,..> FB' "I . ~ 'l ~ - '.'.:,") ~ ,.... Ii:! ' c .., :~ I .:5 . :.1(1) "'" ;..:-}L:..; l:~ " :s 0 o~ (,) 5CO'IT B. SINGISER, . IN THE COURT OF COOMOO PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. . NO. 97-3064 CIVIL TERM . . . SARAH L. SINGISER, : CIVIL ACTION - LAW Defendant : IN CUS'IODY ClJS'1a)y ~LIATI~ SlIlI1Arel RBPCRr IN l\OCXJUWfCB WI'l'H <nmilRLAND CXXNlY RllLB OF CIVIL PRO< OK> .JRB 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIImI April 26, 1987 September 27, 1988 aJilRmrLy IN ClJS'1a)y OF Amanda Jo Singiser Zachary Scott Singiser Defendant/Mother Defendant/Mother 2. A Conciliation Conference was held on July 31, 1997, with the following individuals in attendance: The Father, Scott B. Singiser, with his counsel, Marlin R. McCaleb, Esquire, and the naternal grandparents, Lawrence M. Faillor, Sr., and Errma Alice Faillor, with their counsel, Marcus A. MCKnight, Esquire. The Conciliator was advised that the Mother, Sarah L. Singiser, currently resides in Texas with her boyfriend and chose not to attend the Conference although she had notice thereof. 3. Although neither counsel for the Father or the naternal grandparents had direct contact with the Mother, counsel advised the Conciliator that it was their understanding that the Mother agrees that the Father would have primary custody of the Children with the Mother having partial custody for one month in the surrrner and during a period over the Christmas holiday. The maternal grandparents appeared with counsel at the Conciliation Conference to request periods of custody with the Children who had previously lived with them for 8 years. The Father and the maternal grandparents reached an agreement at the Conference as to ongoing custody arrangements for the grandparents. Counsel for the Father indicated that he would proceed to have the CUstody Agreement between the Mother and the Father documented by Stipulation and present it to the Court separately for entry as an Order. 4. The Father and the maternal grandparents agreed to entry of an Order in the form as attached. !lu~.uW Date G. 1'19 7 ~"Al_jd. Dawn S. Sunday, Esqu Custody Conciliator Q,; C-:i >- c, -- , u; '''; [.. ~ .~ - 0- c~ ;~ cr lUQ " fe t,;:!~ f' .l J:...' '.. ....~ '~! J~ rl . (L. - 9,_, 1..- . cr. ..' .- ~l" ,-'> U L'... N " ff: ~ :,' '" r ',- ~... f' ~;1~ ~ -, -:;: It. r- ~:) 0 <." ~) €) ~ ~:s E-o ~~ f3 0 t) III ..:1>1 ~ III r.. 0 llllll 0 !: ~; lioI ., c Il-I c:: Cl '" ti z '..t nl ~ IIJ ~ !Elll ., 'tl lil t1 ,. ~ ~ ~ c:: c:: ~ ~~ ~ .,... . III 0 u ffi z ~ Cl~ . Cl~ ii: ~Ci~ffi III ~ .. ~ > 0 t&J~lDa. lIlll< IIlQ ~ m~ .. o I I-l I-l '" OlJ 0 "" t!l t!l ~ :I: a.; a: z " E-o t) :z: co :z: :z: II: c", il ~I ~~ I-l I-l 0 II: _ III III I-l &Ir. N Z o E-o ~ C t) UI . . :t < >< III ..:l l;! ~ ..:I:;; Q 2 0 ~ ~ III E-o~ I-l E-o I-l II: ~c:i III E-o C U III I-l t) t) :z: tJ III III , '. t, i:,.' :i HJF';~';;_-;; \'.\:, ,~y < ):> ,-:~-....,;. r:r f' ~~,"'l\"j~'Ct~;: C'-;j; \,... ~,'" '..;";~!!)-; tt/~':'i.\~,j;~lt: i,'l.,;,t'" ( ..' ~ ,.'.,., ,.,' " ( ." f'.' >- 0\ -- 0:; "'-' f- <, 1-' N ", UJ9. <':..;Z::.,: (-2(~ ..- f;) # H....., ~ . ~f ~r. .."l::::J r' ':,->.. r.t O. ~::. 1'1) ~(;. ('..J "j ;~: .~ . -,., -I' c:. ;..iLD U;:'i =- r-= ..;:; t!~a... .' lJ.. r- ::J 0 en U loA""" Of"I(t:~ MARLIN A Mer .'LEB SCOTT B. SINGISER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97 - 3084 CIVIL CUSTODY vs. SARAH L, SINGISER, Defendant STIPULATION OF PARTIES WHEREAS, Plaintiff is the natural father and Defendant is the natural mother of the minor children: AMANDA JO SINGISER (born April 26, 1987) and ZACHARY SCOTT SINGISER (born September 27, 1988); and WHEREAS, a Complaint for Custody was filed by the father on June 10, 1997/ and a true copy of said Complaint, together with a true copy of the Order of Court dated June 17, 1997, was personally served upon the mother on June 19, 1997; and WHEREAS, mother has moved to 920 McClure Lane, Harker Heights, Texas 76548; and WHEREAS, the said minor children are now in the physical custody of their father; and WHEREAS, Plaintiff and Defendant have come to an agreement concerning custody of the said children, NOW, THEREFORE, SCOTT B, SINGISER, Plaintiff, and SARAH L, SINGISER, Defendant, agree to the following Stipulation with regard to the custody of the said minor children: 1, The parties shall share legal custody of their children, AMANDA JO SINGISER and ZACHARY SCOTT SINGISER. 2. Father shall have pri~ary physical custody of the said children,