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Home My WebLink About97-05706 ~ J:J tI) ~ cQ " . of) 7 ;0 ~Ji aJ v ~ / r Eo I ~ I JI Ii ii z1 t; & . :... .:tt- .:.. 11 !~ i~ I. ~ ~ ~ 8 8 ~ 8 8 8 8 8 8 8 lC f~ lC l~ ~ 8 ~ ,;, " i~ J III . :~ i. i~ ( I~ ) .~ .:+:. -:.:- .:.:. .:.:. .:.:. .:.:. .:>>:. .~.*,~.*.*.~.~.~..~~.~..~~-~:-:~.~~~:~~:~.:~.-~~~.~ ~. . 'n . ~\ . , 1I ~, ./ ." "'1 ~I ~I ~I ~I ~ 8 w " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY "l' STATE OF ~~ ......J'-" ..., PENNA. TAMMY LYNNE SHEESLEY, ;'\ II. 97-5?06l:lVU.l~~. Plaintiff ,;, ~, ~ CIVIL ACTION - LAW VI'J':.QU KEVIN SHANE SHEESLEY, IN DIVORCE ~ .' Defendant ~ ~ ~ w " ~I ~ " ~ 8 8 8 ~ ~ ~ ~ ~ 8 ~ ~ ... ~ ~ ~ ~ ~ - -......... '->>;. 'lOC' .lO:. .lO:. .lO:. .It:. 'lO:' .;,0:. DECREE IN DIVORCE AND NOW, . . . M.&> d..t.. It. . . . . . . .. '. 199\1..... it is ordered and decreed that ......... .TAMMY .LX~~r; .SI!r;E~Lr;X . . . . . . . . . . . . . . . . . . " plaintiff, and. . . . . . . . . . . . . . . . . . . KEYW ~!4\N". ~!l~ESL~Y. . . . . . . . . . . . . . . . . . . defendant, are divorced from the bonds 01 matrimony. The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; NONE .................. .., .....,.......... ..... flv The ~ ^".." J ~ . Prothonotary -:.:. .:+:. .:.:. -:.:- .:.;. .:.:. -:.;- .:.: .:.;. :.:.:+> -:.: .;+;. .;.;. -:.:. 8 8 8 !8 18 ~ 8 8 8 ~ 8 3'1;;J.~ .J /.;J f( - 1 ,.~f ~.1 ~ #...w~d<:J' ;'W4~ /1~u /JU"~ -z: .179 J6'i,u,..&t.-~v./It..-... ,..~ ~hl 0= ; ~~ .... j .... IB~~ .... ... .~ ... . QI i , ~ IE; II ~~S~ S~ S.... ~& ~ !I. ~!.';' ~ It t ~ ~ ::. ~~~~~ Q Ul ,..;:: J . ~ OOE en ~ ~ ~ I li; ~ EM 1~~2= ~ , ; l ~ uI ~ I> Jal . S ill ~ . :l t.lOl ~ . r ~ ;~ I l!!l '1 u B '" ~ II.:' ....... ~~ t, '---. --:. 7- Q: , I. ..J rt ...,.., - ~ () c< 1-. ~ vr>. Q ('- ":l v I ,^ ,. ~ ri "" ..../ t2'V,; it ~ ~ 6: eJ. !!Ii .... .~ u ~~ .... ... ~Ii; i 1'101'1 .... ... :a""Cl B!~ ~ .~ 0""8 i~!g~ .... i:!!llj g~ 5~ Cl~~ i ~ II Pi !!IRiju5 I~ a~ i!!llll~ ~ i !~ I ~- III I~~ j ~ I t; ~ ~i II~~= ~ I ; . .. . i :iI ~ l> ~I:i . ~ ~ ~ ~ '1 u p. ~ .. . lAW OFFICES r7 // (1"/ R P. Cy'/" R .~h'u~",. . ,1/,.- I/ln~?n~ L\: l'l/~~?/i".J TAMMY LYNNE SHEESLEY PlalntllT : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION. LAW 97. ~'7~rVIL TERM KEVIN SHANE SHEESLEY, Defendant IN DIVORCE NOTICE 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 decree in divorce or annulment 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. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonolary. Cumberland County Courthouse, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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 Cumberland County Courthouse I Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 717-249-6200 TAMMY LYNNE SHEESLEY Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Y. CIVIL ACTION - LAW 7L\~ 97-!!) CIVIL TERM KEVIN SHANE SHEESLEY, Derendant IN DIVORCE COMPLAINT lli DIVORCE PURSUANT TO SECTION 330lW OF THE DIVORCE CODE -- NOW comes the plaintiff, Tammy Lynne Sheesley, by her attorney, Marcus A. McKnight, III, Esquire, and files this complaint in divorce against the defendant, Kevin Shane Sheesley, representing as follows: 1. The plaintiff is Tammy Lynne Sheesley, an adult individual residing at 205 Alter Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Kevin Shane Sheesley, an adult individual residing IV, 6 10hns Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on August 14, 1982 in Carlisle, Pennsylvania. 5. There were two children born to this marriage, namely, Kevin Michael Sheesley, born October 17, 1987, age 9; and Kristen Rachael Sheesley, born January 8, 1990, age 7. 6. Pursuant to the Divorce Code, Section 330l(c), the plainliffavers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 7. The plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. cKNIGHT, III in tiff 60 West Pomrret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court 1.0. No. 25476 ,.. Date: October /& ,1997 TAMMY LYNNE SHEESLEY Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 97- CIVIL TERM KEVIN SHANE SHEESLEY, Derendant IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: I. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verilY that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. October ...l1e.., 1997 -:/ ~..... ~4; TAM LY E SHEESLEY ~ .... !.'j . " I . ~. . , . .' , '. ,. ' , . . II I~ f \<", "_ ;~ I!i l!ilol ~ I I ... I ~~ ~~ ~ ..,!j . I~::~ .. ~ ~l:l~ "] " Ql ~fa<~~~ i ~ I ; HI ~... i" I~ 80 ~l'l ~~~~~ ~~~~~ . !II i:~ I ~~~ . ~1Zl fa< ~ ~ I ti ~ E~ ~ po ~ li~i~ ~ ~ .. ~U~ i II ~ .~ ~ ~~ I ~ ~~ l'lM ~ , . ) , LAW OFFICES .~"",. .ft.5f::7.t1 & (/~ " TAMMY LYNNE SHEESLEV, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 97-5706 CIVIL TERM KEVIN SHANE SHEESLEY, Derendant IN DIVORCE AFFIDA VIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330\(cl OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 16, 1997. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a final Decree of Divorce wilhout notice. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. S. I understand that I will not be divorced unlil a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verilY that the statemenls made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, Date: f ~9 ,1998 '. . ,. ~ ~ . ' .: :' \ i :' ( .~ . ~ . l~ ' r_. J ~a I!i l!ilol ~ ~~!I ... .. ~~:~~ :::l i ~ I i I .. ~ O~~ it ~ "] Ii ~~Ii~ . ~ I ill i~ tl;h ~. I ~ .! ~!iH ~ I ! i1=:. . 1=:~ ~ ~ I ~ ~ Ei I ~~~ . ~ po ~ ~ ~ ~~~i!~ . i II i . ~D ! ~ ~~ 'i l'lM ~ ._-- ---- , , , . , , .' -. , . .." '.; ~5 ~hl ~~ ... .. .~ J ;~ I~~~ .. l~ ' ~ I ! ; I! "e ~ ~ ~~ ~~ to:l . ~. 11:)0' ~ ~~~u~ a ~ l~iF . Cl ~ ~ ~~ ~ ~ I ~ ~ Ei ~ ~~~ . I~ ~ po ~ 8~ .t t II ~ ~ U~ ~ l'l~ .; ~ I ~ ~~ e ~ --::::!~ r". ...... '\ .. .,"\' (: IA >~ , ,I '. . '.)~~ _,10-; I. .,) :...: ",' 'J"; . -:,::, ,".:(.; f. .L..# ,";;- l"j(U (. "~~ 0.. r- :5 .l" IJ ~i .... ~ ... "'" ..... ~I!~ fa<~'" QI><"'" ... .. .... ~III i ~ of l>lS" U "'" ... T I.~~I o~ ~~ ~... f:l ~ !~I II II In ~ i~ I~ ... t!~ ~ fa< Q . ... i I :!l~ ~ . I ~I~ 5 ~ I i t.~ . I~~ po II i ~ u~ ~ ..: ~ ~ '1 c.i I!l . . ~ lIll " 'r.> . ,.,' itf- , . . . , . . t/H";r "".1'; J. . // /.: . .. · . IO"I'JI .1/," l/if/I., \' "",'"'' P 4'12 345 &&0 US Postal Se"'lce Receipt 'OL ~erti'led Mall No lnaurence Coverage Provided, . 00 not use lor Inl.mallonal Mail 5e. ",vefSS Sent 10 MR KEVIH SBAIIE SHEESLEY &- 6 JOBHS DR ott . SUle, & ZIP Code MECHAHICSBURG PA 1 0 5 PoollgO S , 5 ~ Certified Fee 1,::.<; ~~F.. IWtrldodOeli...e F on 8l ReIum _ Shod'll. - Whom I Ollie Oeh'ered a ....._9wnl.""'" <I( o.,IWeuee'sMieu g TOTAL Postage I Fees ~ Ponnaltl Of Dale 8 u. <tl Q. " -,-- 'J 1.10 S (,.lS KllE 10-16-97 DIVORCE COMPLAINT "'1 . _CorrlpIIIelelml t 1ilWN0I a tor ~ ....... .~_:I,"'ond4ll. I aPrinl your neme -.d addr-... on N 1'1....... of lhIrI bm 10 I\at WI can,.um INt ......- aAaaoh" Iontllo....ttont of the rNiIp6ece. Of on thI '** II.... doeI not , .~R&m R.,.,. ~on the mdpIecI bIklw the article ruT'OeI. aThl "-I..., ReceIpI WIll thow 10 WlIhom the IftIdI WI. ~ Ir'ld 1M dB I- I . MIele _Iued 10: I ., SIgne . X PS Fonn38", leloowtehlD_1I1e foIIowtng _I (lor en _lee): 1:-0 Md_'e~ t ~ ReotrtcIed DelIvery~ I ConIU1 poollTlel1er lor fee. J 4a. MIele Number P 492 345 880 J 4b. S8I\/Ice T " D Reiliot -r.ANIc.~ III Cer1l1Ied D ~~ D IIIIlnd f D DeaD 7. DI'e I ; .. '-0' f . I a. Mdr";":...~~(~y"_r.d I IIId lee Ia pekJt ~ MR DVIH SHARE SHEESLEY 6 JOBHS DR MECBARICSBURG PA 17055 5. Received By: (Print Name) :":- -"" .... !-~ L....; (:: I. .. , j HJ~~: C" " r.L.... ( .. -. -- '''.. j,-; . ; ~ t./t ~#- , ;.J , , ,-:) II ~ r~ , II, . . , , I{oj ,.: i-' .' . :JU- t'" -- .'- 11 ,.. ...1 0 0" ....) ~~~ ~i~5 ... .} ~ ... ..... ~i f ~'J ~ ~~51 ..... . I: ~~ i8 ,j 3 .l~ "~JI I~ . ~! ,'" 1i ~ ~ iJ'lIi t r Ul ; S~J.ijl ~J~~ ~ ~ ~ ~ ia Ji;l. , ill:ll ~ :~~ I ~ ..... . .. " .. . - .. I :OJ l .~ J. , . N~J'I ;" ,I I' I'J I TAMMY LYNNE SIlEESLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND CXXJNTY, PENNSYLVANIA vs. NO. 97-5706 CIVIL TERM KEVIN SHANE SHEESLEY, Defendant CIVIL ACTION - LAW CUSTODY OODER OFaxJRT AND tOI, this ~ day of ~ It \It. _~cJ , 1997, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Tammy Lynne Sheesley, and the Father, Kevin shane Sheesley, shall have shared legal custody of Kevin Michael Sheesley, born October 17, 1987, and Kristen Rachael Sheesley, born January 8, 1990. 2. The Mother shall have primary physical custody of the Children. 3. At such time as the Father obtains appropriate accomodations for overnight periods of partial custody with the Children, the Father shall have custody of the Children on alternating weekends from Friday at 5:00 p.m. until sunday at 7:00 p.m. and every Tuesday and Thursday evenings from 5:00 p.m. until 9:00 p.m. Until the Father obtains accomodations for overnight custody with the Children, the Father shall have custody under the foregoing schedule with the exception of the overnight periods and at such times as agreed upon by the parties. 4. The parties shall share or alternate having custody of the Children on holidays as follows: A. Christmas: The Mother shall have custody of the Children every year over the Christmas holiday from Christmas Eve at 12:00 noon until Christmas Day at 1:00 p.m. The Father shall have custody of the Children over the Christmas holiday every year from Christmas Day at 1:00 p.m. until December 26 at 9:00 p.m. B. Thanksgiving Day: The Mother shall have custody of the Children on Thanksgiving Day and the Friday fOllowing Thanksgiving in odd numbered years and the Father shall have custody of the Children on Thanksgiving Day and the Friday fOllowing Thanksgiving in even numbered years. The times for exchanges of custody over the Thanksgiving holiday shall be arranged by mutual agreement of the parties. C. ~ster: The Mother shall have custody of the Children every year on Easter Sunday at times to be arranged by mutual agreement of the parties. D. Memorial Day/Labor Day: The Father shall have custody of the Children on Memorial Day in even nwrbered years and on Labor Day in odd numbered years. The Mother shall have custody of the Children on Memorial Day in odd numbered years and on Labor Day in even numbered years. The times for exchanges of custody on these holidays shall be arranged by mutual agreement of the parties. E. Father's Day/Mother's Day: The Father shall have custody of the Children every year on Father's Day and the Mother shall have custody of the Children every year on Mother's Day. 5. Each party shall have custody of the Children during the summer each year for two uninterrupted non-consecutive weeks upon providing advance notice ot at least thirty (30) days to the other party. 6. 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 agreement. In the absence of mutual agreement, the terms of this Order shall control. BY THE COURT, J. . cc: Marcus A. McKnight, III, Esquire - Counsel for Mother Jay R. Braderman, Esquire - Counsel for Father . ,,1 :2.5/9'). COO"'- ~.J. ..s . -('. TAMMY LYNNE SHEESLEY, Plaintiff IN THE aJURT OF CCf1MCtI/ PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 97-5706 CIVIL TERM KEVIN SHANE SHEESLEY, Defendant CIVIL ACTlOO - LAW CUSTODY CUl'l'OOY a:N:ILIATICIf 5lJlIMARY REPCRT IN AaXPLll\NCE WITH ClJlBERLAND cxumc RULE OP CIVIL PIl(lI "" >mE 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 OP BIRTH aJRREtfl'LY IN cn>'l'OOY OP Kevin Michael Sheesley Kristen Rachael Sheesley October 17, 1987 January 8, 1990 Plaintiff/Mother plaintiff/Mother 2. A Conciliation Conference was held on November 18, 1997, with the following individuals in attendance: The Mother, Tarrmy Lynne Sheesley, with her counsel, Marcus A. McKnight, III, Esquire, and the Father, Kevin Shane Sheesley, with his counsel, Jay R. Braderman, Esquire. 3. The parties agreed to entry of an Order in the form as attached. f\.J 1'1/"'1'1&'" If /1 Ii 7 . c;L</JJ~-"Lj~~ Dawn S. sunday, Esqul Custody Conciliator Date " ~a ~ I I ~E~B I< .. ~ g e ~ i; !;I~I I~ .1 ~ i ~1 B !~lllh ~! m ''lll Li !~~/ !!l ~ . ; po ~ ~ ill! ~ ~ 'j ~ ~~ ~ . . . ~..'" .. " .. . , . ,Y... ,II :. ~J) . 0'11(; 1 I '{ 1997 , ~f"'(" . /;': /.,' ,. . .;',/ . \. '-' , ,...,.,.... , TAMMY LYNNE SHEESLEV Petitioner : IN TilE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW At"'" 97- .:> . CIVIL TERM KEVIN SHANE SHEESLEY, Respondent IN CUSTODY ORDER OF COURT AND NOW, this _ . day of _ _ 1997, 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 _th Floor, Cumberland County Courthouse on the day of 1997 at _ _.M. for a Pre-hearing Custody Conference, At such conference, an effort will be made to resolve the issues in dispute; or if thi$ 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 permanent order. By the Court, Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LA WnR OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TilE OFFICE SET FORTH BELOW TO FIND OUT WIIERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse 1 Courthouse Square Carlisle, Pennsylvania 17013 (717) 240-6200 AMERICAN WITH DISABILITIES ACT OF 1990 The Court oCCommon 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 dislIbled 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 beCore the court. You must attend the scheduled conference or hearing. v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW '1& 97- ~ CIVIL TERM TAMMY LYNNE SHEESLEY Petitioner KEVIN SHANE SHEESLEY, Respondent IN CUSTODY PETITION FOR CUSTODY AND NOW comes the Pelitioner, Tammy Lynne Sheesley, by her attorneys, Irwin, McKnight & Hughes, and presents the following Petition for Custody. I. The Petitioner is Tammy Lynne Sheesley, an adult individual residing at 205 Alter Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Respondent is Kevin Shane Sheesley, an adult individual residing at 6 Johns Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055, 3. The parties are the natural parents of two children, namely, Kevin Michael Sheesley, born October 17,1987, age 9 years; and Kristen Rachael Sheesley, born January 8,1990, age 7 years. YERIFICATIO~ The foregoing Petition is based upon information which has been gathered by my counsel and myself in the preparation of this action. The language of the Petition may in part be the language of my counsel and not my own, I have read the statements made in this Petition 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. TAM Date: OctOber.1fe....., 1997