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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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,JEfFREX,A" CASPER
Plaintiff
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LINDA J. CASPER
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DECREE IN t :
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AND NOW. '
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decreed that."." ,J,J;:!,',F,~F;Y,., .~.S.I~J;:\l""".,..""""",.. plaintiff,
and, " . . ,. , , , , , , , , . ~;r.lIIQI), ,1'" . <;:(I,q~J;:I.l, , . , , , . . , , , . , , , , . , , . , ", defendant,
are divorced from the bonds of matrimony.
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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;
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JEFFREY A. CASPER,
Plaintill'
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY PENNSYL VANIA
v,
, 98- '::>'7 f::) (. r', _
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: IN DIVORCE
LINDA J. CASPER,
Dcfcndant
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against the claims set forth in the fol/owing
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 of 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may
request marriage counseling, A list of marriage counselors is available in the Prothonotary's Office
at the Cumberland County Courthouse, Carlisle, Pennsylvania.
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
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 240.6200
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
; 98- 3 10{ &~.-<j -r;,~.....
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JEFFREY A, CASPER,
Plaintiff
LINDA J. CASPER,
Defendant
IN DIVORCE
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COMPLAINT
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Plaintiff, Jeffrey A. Casper, by his attorney, Lindsay D, Baird, Esquire, sets forth the following:
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Plaintiff, Jeffrey A. Casper, is an adult individual residing at 20 Eastwood Drive, Carlisle,
Cumberland County, Pennsylvania,
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Defendant, Linda J, Casper, is an adult individual residing at 469 Brook Circle, Meehaniesburg,
Cumberland County, Pennsylvania,
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The parties were married on November 26, 1983, in Pittsburgh, Allegheny County, Pennsylvania.
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Plaintift'and Defendant have lived continuously in the Commonwealth of Pennsylvania for at least
six months prior to the commencement of this action.
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This action is not collusive,
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There have been no prior actions for divorce or annulment in this or any other jurisdiction within the
knowledge of the Plaintiff,
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In accordance with Section 330 I (e) of the Divorce Code, the marriage between the parties is
irretrievable broken,
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Plaintiff has been advised that counseling is available and that Plaintill' may have the right to
request that the Court require the parties to participate in counseling,
WHEREFORE, the PlaintifT requests your Honorable Court to decree that the Plaintiff be divorced
from the Defendant.
Lit ,LL- l,
~ndsay D, rd, Esquire
Attorney for the Plaintiff
37 S. Hanover Street
Carlisle, P A 17013
717 - 243-5732
I verify that the statements in the foregoing pleading are true and correct. I understand that false
statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification
to authorities.
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Plaintiff
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IN TIlE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYL VANIA
NO,l)H-375 CIVIL TERM
LINDA J. CASPER,
Delcndunt
CIVIL ACTION - LA W
AFFJI)A VIT OF CONSENT
Pursuuntto Pu. R,C,P, Rule 1920.72
I. A Compluint in Divorce under Section 3301(c) of the Divorce Code wus liIed on
Junuary 21, 1998, und un Acceptunce of Service wus signed by the Delcndant on Fcbruury 3.
1998.
2. The marriuge of Pluintiff und Delcndunt is irretrievubly broken und ninety days huve
elapsed from the dute of liIing und service of the Compluint.
3. I consent to the cntry ofu final Dccree in Divorcc either uncI' service ofu Notice of
Intention to Request Entry of the Decree,
I verify that the statements mude in this Affidavit arc true und correct. I understund tlmt
false statements herein me made subject to the penalties 01'18 Pu. C,S. Section 4904 reluting to
unsworn falsification to authorities,
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JEFFREY A, CASPER,
Plaintiff
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IN TIlE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY.
PENNSYLVANIA
NO, 98-375 CIVIL TERM
LINDA J. CASPER,
Defendant
CIVIL ACTION - LA W
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 331l1(e) OF TIlE DIVORCE CODE
I, I consent to the entry of a linal decree in divorce without notice.
2, 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.
3. (understand that I will not be divorced until a divorce decree is entered by the court
and that a copy of the decree will be sent to me immediately aner it is tiled with the
I verify that the statements made in this At1idavit arc true and correct. (understand that
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Prothonotary.
false statements herein arc made subject to the penalties of 18 Pa, C.S, Section 4904 relating to
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unsworn fhlsilication to authorities,
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IN THE COURT OF COMMON PLEAS
OF CUMI3ERLAND COUNTY,
PENNSYLVANIA
JEFFREY A. CASPER,
PluintifT
NO, 98.375 CIVIL TERM
LINDA J. CASPER,
Defendunt
CIVIL ACTION - LAW
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 33111(e) OF THE DIVORCE CODE
I, I consent to the entry ofulinul decree in divorce wilholltnotiee.
2, 11Inderstund thutl muy lose rights concerning alimony, division of property, lawyer's
fees. or expenses if I do not claim them before a divorce is granted,
3. I understund that I will not be divorced until a divorce decree is cntered by the court
and thatu copy of the decree will be sent to me immediately uner it is filcd with the
Prothonotury.
I verify that the statements made in this Afliduvit arc true and correct. I understand that
false statemcnts herein arc made subject to the pcnalties of 18 Pa. C,S. Scetion 4904 relating to
unsworn falsification to authorities,
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LINDA J. CAS 'ER
Dated
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JEFFREY A, CASPER,
Plnintilr
vs,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
pENNSYL VANIA
LINDA J. CASPER,
Defendnnt
CIVIL ACTION - LA W
NO, 98-375 CIVIL TERM
IN DIVORCE
DEFENDANT'S ACCEPTANCE OF SERVICE
I hereby necept service of the Complnint in Divorce in this mntter in nceordnnee with Pn.
R.C,p, 1920.4 nnd 402(b).
DATED:
2/3/98
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LINDA J, CASPER
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IN TilE COURT OF COMMON PLEAS OF
CUMDERLAND COUNTY, PENNSYLVANIA
CIVIl, ACTION - LAW
NO. Qf,. ~1~ CIVIl,
IN l~lVOIlCE
19
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(b) Provide approximate date when discovery will be
complete and indicate \~hat action is being taken
to complete discovery,
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COUNSEL FOR PLAINTIFF
COUNSEL FOR DEFENDANT
NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
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THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
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JEFFREY A. CASPER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO, 98 - 375 CIVIL
LINDA J. CASPER,
Defendant
IN DIVORCE
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TO: Robert L, O'Brien
Attorney for Plaintiff
Michael L. Bangs Attorney for Defendant
DATE: Tuesday, January 18, 2000
CER'l'I FICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
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(b) Provide approximate date when discovery will be
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to complete discovery.
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COUNSEL FOR DEFENDANT
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NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
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THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
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IN TIlE COURT OF COMMON PI.EAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
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JEFFREY A, CASPER.
Plaintiff
NO, 9S.375 CIVIL TERM
LINDA J, CASPER,
Defendant
CIVIL ACTION - LA W
j- ;)P-OCJ
Date
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JEF . A ASPER'
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AFFIDAVIT OF CONSENT
Pursuant to Pa. R,C,P, Rule 1920,72
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was /iled on
January 21, 1995, and an Acceptance of Servicc was signed by the Defendant on Fcbruary 3.
1995,
2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final Decrce in Divorcc cithcr aftcr servicc of a Noticc of
Intention to Rcquest Entry of the Decree,
I verify that the statements made in this Affidavit are truc and correct. I understand that
false statements herein are made subject to the penalties oriS Pa, C.S, Section 4904 relating to
unsworn falsification to authorities,
vs.
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IN TIlE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
JEFFREY A, CASPER,
Plaintiff
LINDA .I. CASPER,
Defendant
NO, 98.375 CIVIL TERM
CIVIL ACTION - LA W
AFFIDAVIT OF CONSENT
Pursuant to Pa, R,C,P, Rule 1920,72
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filcd on
January 21, 1998, and an Acceptancc of Scrvice was signed by the Defendant on February 3.
1998.
2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3, I consent to the entry of a linal Decree in Divorce either aftcr scrvice of a Notice of
Intention to Request Entry of the Decree,
I verify that the statements made in this Affidavit arc true and correct. I understand that
false statements herein arc made subject to thc penalties of 18 Pa, C,S, Section 4904 relating to
unsworn falsification to authorities.
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LINDA .I. CASPER
Date
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JEFFREY A, CASPER,
Plaintifl'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v,
NO, 98-375 CIVIL TERM
LINDA J, CASPER,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
PRAECIPE FOR WITHDRA W AL OF COUNSEL
AND APPEARANCE OF COUNSEL
TO: Lawerence Welker, Prothonotary
Please note my withdrawal as counsel for Jeflrey A, Casper, Plaintiff in the above matter,
Dated: .q; ~ 3 ,98
BY:
/lr/-I!o,t ii'~
Lind~ ' Baird, Esquire
37 South Hanover Street
Carlisle, Pennsylvania 17013
(717) 243-5732
Kindly enter our appearance on behalf of Jeffrey A. Casper, Plaintiff in the above matter,
,
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Robert L, O'Brien, Esquire
17 West South Street
Carlisle, P A 17013
(717) 249.6873
BY:
Dated: 4l~?)q~
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CERTIFICATE OF SERVICE
I hereby certily Ihat on April d.?z..., 1998, I, DlIvid A, Baric, Esquire, of O'Brien. Baric &
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Scherer, did serve the Praecipe for Entry of Appearance, by first class U,S. mail, postage prepaid. to
Ihe parties listed below, as follows:
Lindsay D, Baird, Esquire
37 South Hanover Street
Carlisle, Pennsylvania 17013
Michael L, Bangs, Esquire
302 South 18th Street
Camp Hill, Pennsylvania 170 II
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Robert L, O'Brien, Esquire
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JEFFREY A. CASPER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, 98-375 CIVIL TERM
Vs.
LINDA J, CASPER
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW THIS I'd day of l---\0,1 , 1998, upon consideration of the
attached complaint, it is hereb , dire~rties and their respective counsel
appear before " ' , ,the conciliator, at dq W ~ tj":11 ('\~, )
,-\c-chl1\l\h_l~on the -1b day of ' " , 1998 at J.illJ A.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,
BY THE COURT,
BY ciSnuJ\\ J\ ,J\,H)Ad~ '
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 be made at
least 72 hours prior to any hearing or business before the court. You must allend the
scheduled conference or hearing,
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YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT
HAVE A LAWYER OF CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
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JEFFREY A, CASPER,
Plaintiff
Vs,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION - LAW
NO, 98.375 CIVIL TERM
IN CUSTODY
LINDA J, CASPER
Defendant
COMPLAINT FOR CUSTODY
1, Plaintiff is Jeffrey A. Casper, an adult individual, currently residing at 20
Eastwood Drive. Carlisle, Cumberland County, Pennsylvania. He and the Defendant
are presently separated,
2, Defendant is Linda J, Casper. an adult individual, currently residing at 469
Brook Circle, Mechanicsburg, Cumberland County, Pennsylvania,
3, Defendant seeks custody of the following children: Preston Clark Casper
born 10/16/88 and Sloane Reba Casper born 11/5/91,
The children were not born out of wedlock.
The children are presently in the custody of the Mother. Linda J, Casper,
During the past five years, or since the child's birth, they have resided with the
following persons at the following addresses:
(a) from 1989 to September 1996 with the parties at 1053 Wayne Ave"
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Carlisle, Pa,
(b) from September 1996 to January 1998 at 20 Eastwood Drive,
Carlisle. Pa,
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JEFFREY A. CASPER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 98-375 CIVIL TERM
CIVIL ACTION - LAW
LINDA J. CASPER,
Defendant
.
.
IN CUSTODY
OODER OF COORT
C../-\\ ~ 1
AND tOtI, this ( day of (..'-'~
consideration of the attached CUstody C cilAtion
and directed as follows:
, 1998, upon
Report, it is ordered
1. The Father, Jeffrey A. Casper, and the Mother, Linda J. Casper,
shall have shared legal custody of Preston Clark Casper, born October 16,
1988, and Sloane Reba Casper, born November 5, 1991. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make
all major non-emergency decisions affecting the Children's general
well-being including, but not limited to, all decisions regarding their
health, education and religion. Pursuant to the terms of this paragraph,
each parent shall be entitled to all records and information pertaining to
the Children including, but not limited to, school and medical records and
information.
2. Pending a second CUstody Conciliation Conference on August 18,
1998, the Mother shall have primary physical custody of the Children and
the Father shall have visitation and/or partial physical custody of the
Children in accordance with the recommendations of the Children's
counselor.
3. Both parties shall cooperate in participating in and insuring that
the Children participate in counseling.
4. The parties and their counsel shall attend a second CUstody
Conciliation Conference on August l8, 1998 at l:OO p.m. in the office of
the Conciliator Dawn S. Sunday, Esquire.
5. Neither party shall do or say anything which may estrange the
Children from the other parent, injure the opinion of the Children as to
the other parent, or hamper the free and natural developnent of the
Children's love and respect for the other parent.
J.
cc: Robert L. O'Brien, Esquire - Counsel for Father
Barbara Sumple-Sullivan, Esquire - Counsel for Mother
~~,u n-~~J., 7/I'f-j9f{,
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"
JEFFREY A. CASPER,
Plaintiff
IN THE COURT OF COMMON PLEJlS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 98-375
CIVIL TERM
LINDA J. CASPER,
Defendant
.
.
CIVIL ACTION - LAW
IN CUSTODY
cusrooy COOCILIATICtl SlHIARY REPORT
IN AexnmANCE WITH ClI1BERLAND COlNl'Y RULE OF CIVIL PROCEIlURE
19l5.3-8, the undersigned Custody Conciliato~ submits the following report:
1. The pertinent information concerning the Child~en who are the
subjects of this litigation is as follows:
NAME
DATE OF BIRTII
CURRENl'Ly IN cusrooy OF
Preston Clark Casper
Sloane Reba Casper
Octobe~ 16, 1988
November 5, 1991
Mother
Mother
2. A Conciliation Conference was held on June 3D, 1998, with the
following individuals in attendance: The Father, Jeffrey A. Casper, with
his counsel, Robert L. O'Brien, Esquire, and the Mother, Linda J. Casper,
with her counsel, Barbara surnple-Sullivan, Esquire.
3. ~e parties agreed to entry of an Orde~ in the form as attached.
J-u.-G.,
Date '
Da1l.~~~cl:d
Custody Conciliator
I, 199cf
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.... "~;,;':~;v:>;:(;!,':~'~,:z'r":.~~1fJi,
JEFFREY A. CASPER,
Plaintiff
IN TUE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 98-375
CIVIL TERM
LINDA J. CASPER,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
PRIOO JUDGE: Edward Guido
ClJS'IDOY CCR:ILIATlOO SUMMARY REPOOT
IN ACXXJRDANCE WITH CllIBERIJ\ND CXXJNTY RULE OF CIVIL t'~
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 BIRTfI
CURRENl'Ly IN ClJS'IDOY OF
Preston Clark Casper
Sloane Rebo Casper
October 16, 1988
November 5, 1991
Mother
Mother
2. A second Conciliation Conference was held on August 18, 1998, with
the following individuals in attendance: The Father, Jeffrey A. Casper,
who is no longer represented by counsel in this matter, and the Mother,
Linda J. Casper, with her counsel, Barbara Sumple-Sullivan, Esquire.
3. The parties agreed that it is not necessary to obtain a Court
Order at this time modifying the current Order dated July 9, 1998. The
parties were able to agree, however, on a course of action to accelerate
the process through which Father will be able to develop his relationship
with the Children through counseling and visitation. It was agreed that
the Father will take the initiative to obtain information on an institution
offering supervised visitation so that periods of custody can be
established as soon as possible. At the same time, the parties will both
discuss with the current counselor, Paul Dickerson, their mutual desire to
more aggressively pursue progress toward expanded custody arrangements
through counseling. Finally, the Father will contact an independent
counselor to arrange sessions specifically for the parties' daughter.
4. A third Custody Conciliation Conference is scheduled for November
19, 1998 at 1:00 p.m.
47)tnMJI- / C; /99tY
Date r:T '
d2~~..~d'b
Dawn S. Sunday, Esquire
Custody Conciliator
:~
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11~~
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cc: Jeffrey A. Casper, Father
Barbara Sumple-Sullivan, Esquire - Counsel for Mother
~~ l"",o...c.(L 'ill;)c, /98,
....!,. ~7.
,..,
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"1~~J
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J~l;i.{{:::-< :':T.':;~:';;:: ;:.: :;, ':, -
JEFFREY A. CASPER,
Plaintiff
.
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUN1~, PENNSYLVANIA
vs.
NO. 98-375
CIVIL TERM
:
LINDA J. CASPER,
CIVIL ACTION - LAW
IN CUSTODY
Defendant
ORDER OF CXXlRT
. 301
AND tl:M, thIS
consideration of the attached
and directed as follows:
day of ~ , 1998, upon
Custody Conciliation Report, it is ordered
1. This Court's prior Order dated July 9, 1998 is vacated and replaced
with this Order.
2. The Father, Jeffrey A. Casper, and the Mother, Linda J. Casper,
shall have shared legal custody of Preston Clark Casper, born October 16,
1988, and Sloane Rebo Casper, born November 5, 1991. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make
all major non-emergency decisions affecting the Children's general
well-being including, but not limited to, all decisions regarding their
health, education and religion. Pursuant to the terms of this paragraph,
each parent shall be entitled to all records and information pertaining to
the Children including, but not limited to, school and medical records and
information.
.
!
Ii
Ii
I
3. The Mother shall have primary physical custody of the Children.
4. The Father shall have partial physical custody of the Children in
accordance with the fOllowing schedule:
Sunday, November 22, 1998 and Sunday, November 29, 1998 from 1:00
p.m. until 6:00 p.m.
Sunday, December 6, 1998 and Sunday, December 13, 1998 from 9:00
a.m. until 6:00 p.m.
Saturday, December 19, 1998 at 9:00 a.m. through Sunday, December
20, 1998 at 6:00 p.m.
Saturday, January 2, 1999 at 9:00 a.m. through Sunday, January 3,
1999 at 6:00 p.m.
Saturday, January 16, 1999 at 9:00 a.m. through Sunday, January
17, 1999 at 6:00 p.m.
Saturday, January 30, 1999 at 9:00 a.m. through Sunday, January
31, 1999 at 6:00 p.m.
Beginning on February 12, 1999 and continuing thereafter, on
alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00
p.m.
At such additional times as reasonably requested by the Father and
arranged by agreement of the parties.
5. During the Father's periods of custody with the Children through
November 29, 1998, the Father shall ensure that the Children do not have
contact with the Father's girlfriend who also resides in the Father's home.
This limitation shall not apply following the Father's period of custody
with the Children on November 29, 1998.
6. The parties shall share or alternate having custody of the
Children on holidays as follows:
A. Christmas: In every year, the Father shall have custody of
the Children on Christmas Eve from 9:00 a.m. until 6:00 p.m.
The Mother shall have custody of the Children from Christmas
Eve at 6:00 p.m. through Christmas Day at 6:00 p.m.
B.
Alternating Holidays:
custody of the Children
a.m. until 6:00 p.m.:
The parties shall alternate having
on the fOllowing holidays from 9:00
Thanksgiving, New Years Day, Memorial Day, July 4th, and Labor
Day. The alternating holiday schedule shall begin with the
Mother having custody of the Children on Thanksgiving in 1998.
D. Mother's Day/Father's Day: In every year, the Mother shall
have custody of the Children on Mother's Day from 9:00 a.m.
until 6:00 p.m. and the Father shall have custody of the
Children on Father's Day from 9:00 a.m. until 6:00 p.m.
7. The holiday custody schedule shall supersede and take precedence
over the regular custody schedule.
8. Each party shall be entitled to have custody of the Children for
two (2) weeks (consecutive or non-consecutive) during each sunmer school
vacation, upon providing at least thirty (30) days advance notice to the
other party.
9. The Father agrees to attend counseling sessions with the Children
through December 13, 1998.
10. The parties shall exchange custody of the Children at George's
Family Restaurant in New Kingston.
11. Neither party shall do or say anything which may estrange the
Children from the other parent, injure the opinion of the Children as to
the other parent, or hamper the free and natural development of the
JEFFREY A. CASPER,
Plaintiff
.
.
IN 'I'HE COURT OF COMMON PLEAS OF
CUMBERLAND ~, PENNSYLVANIA
vs.
: NO. 98-375
CIVIL TERM
Defendant
CIVIL ACTION - LAW
: IN CUSTODY
LINDA J. CASPER,
PRICE JUDGE: Bdward E. Guido
CUSTODY cnlCILIATIOO SU9IARY REPCm.'
IN ACXXIU>ANCE wrm ctImERIJ\ND caNJ.Y RULE OF CIVIL p~
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. '!tie pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
DATE OF BIRTH
CURRENrLY IN CUSTODY OF
Preston Clark Casper
Sloane Rebe Casper
October 16, 1988
November 5, 1991
Mother
Mother
2. A third Conciliation Conference was held on November 19, 1998,
with the following individuals in attendance: The Father, Jeffrey A.
Casper, Pro Se, and the Mother, Linda J. Casper, with her counsel, Barbara
Sumple-Sullivan, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
/.J~
Date
..;J.o /9'lR
,
/1_ AA,~
Dawn S. Sunday, Esqu re
CUstody Conciliator
.
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JEFFREY A, CASPER.
Plaintil1'
: IN TIlE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION - CUSTODY
LINDA J. CASPER,
Delcndant
NO. 98-375
OIU)EI~
AND NOW, this _ day of
, 1999, upon consideration of the PETITION FOR
SPECIAL RELIEF TO MODIFY CUSTODY ORDER as liIed by Defendant, it is hereby Ordered
that:
I. Unsupervised Visitntion. Suspend unsupervised visitation pending conciliation
conference and psychological evaluation of Respondent; CIIC'
.AJtgrn"t~"'i'ly. p",uding Cal1riliaLt:ou cUllrcrcllce:
1. AI\.uhul ulld DIII!;~. fdllu';l ~11(,1I1 \;fi dill 1) VIII Luldng altml'nli~ hpHerJ1ggE ~Rd drugs
.at 'vast ::-4 I,uu>> 1.11 101 10 Ihe; IIllle he has cuslOdy uF du: child"," ,,"d cUlIliuuing to
ref~iA HOIII <UIY ,",uu::,ulllptiUIl WI.i1l; lit.: hit~ du;; d.i1dH.;u. f',ulu;,a ::.llHllucvcl L1all~ort
th~ ~bildnJR afl:-;:r be h!1C pit!,p.r ,jrnnk Hlr.ohol or tnkp.n rlnlg.i FatRer's right! of
cJJstQej' 3hall bG illllll(.diatd) .:n'13penaeEl hy ~1ethGr t.llt:1 \ovlI":I:,,l:OIl jfit i~ Apparent
that he is ~1R8er the inAth:uI..o\:i uf :)UIIlC :)ubslance.
1. (6rIl01..1 P....;.III..~III. I"mher shall nl1meOlalely cease all corporal 01 physical
pllnishRlcnt of tl", "',ild,clI. AllY 1'a..hel corporal pUlli~IIIII\'1Il will b" dc"med a
"inlntinq gfthig Order lImllllllisl,t3 aftlIlSUp'" v;.~d \ou.ludy .I'ull bc ,u'fJ~"dcd by
Mgtller !leAding eencililltion.
3. Cvunscling ~!lthpr cha11 re ~Rt~r withiQ U"q (5) eRj'S incli"idl1nl cvulI;:)",l:ug to
~r1r1rpci hiE phygieal viekllGG. The tIIGlnp:.,l LI,ut rutlu... ",llvv.;)\"" iliuM be: ijyalified to
aaclre3s i.Hu'-o\ ofph)3ieal yial\)R(''' !lnrt CII?rtanee alnllse.
4. 3w..11 udlt':l I ",l;"r tl.c. CS1:irt el98RU; a~f)rgpriate.
Judge Edward E. Guido
6, A conciliation conference bclore Dawn S. Sunday, Esquire was held on June 30, IlJlJK
at which timc thc parties agreed to participate in counseling, Father was granted rights of supervised
custody in accordance with the recommendations of the children's counselor, A second conciliation
was scheduled for August 18, 1998. A copy of the Order dated July 9, 1998 is marked as Exhibit
"A" and attached hereto,
7. The children's counselor, Paul Dickerson, M.A., forwarded a report on August 13,
1998 to provide the parties feedback on the progress of the counseling tor the second conciliation
conference. At the second conciliation confcrcnce, it was agrccd thatthc parties would continue with
the counseling in the hopes of accelerating thc progrcss towards cxpandcd custody arrangcmcnts and
the custody continued to bc supcrviscd,
8. A third conciliation confcrcncc was schcduled on Novcmber J 9, 1998. A copy of thc
August 13, 1998 report and Custody Conciliation Summary Rcport dated August 19, 1998 are
marked as Exhibit "8" and attached hcrcto.
9. At the third conciliation confcrcnce, the parties agreed to a gradual schedulc of partial
unsupervised custody which culminated in Fathcr's lirst weckend visitation on Fcbruary 12, 1999,
A copy of the Order dated December 3, 1998 is marked as Exhibit "C" and attachcd hcrcto,
"
10.
Fathcr had agrccd to attcnd counscling scssions with thc children through Dcccmber
,-
"
I.
"
i
I'
13, 1998 but no counseling was, in fact, arrangcd.
2
, .
I..
II, Since the termination of the counseling sessions and the commencement of the
unsupervised overnight visitation, Father's behavior has become erl'lltic, aggressive und threutening.
He has quit his employment. During the overnight on Junuury 2, 1999, Futher l'lIised his Iistut his
son as ifhe was going to hit him, The following day, although Futher WllS drinking most of the day,
he still tl'llnsported the children home.
12. Father was charged with assaulting his live-in girlfriend which situlltion raised concerns
with Petitioner for fear of the children's safety lInd well being as well as fear that no residence would
be available to the children during their visit with their Father,
13. In response to a letter from Petitioner's counsel, Respondent indicated that he was
again residing in the house lInd the custody would not be disrupted. Petitioner allowed the custody
to occur.
14, During Father's recent weekend overnight visitation on February 12, 1999,
Respondent hit the parties' son with a strap because he asked to call his Mother and punched the
child's ann. This type of action occurred by Respondent during the marriage but Petitioner was there
to stop any violence against the children.
15. Petitioner believes that Father's behavior and decision making skills had deteriorated
to the point where he is presently using corporal punishment on the child further aggravating the
3
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JEFFRE:{ A. CASPER,
plaintiff
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND caJNTY, PENNSYLVANIA
.
.
vs.
: NO. 98-375 CIVIL TERM
: CIVIL ACTION - LAW
LINDA J. CASPER,
Defendant
:
: IN CUSTODY
ClIDER OF COORT
AND tl:M, this Cf::tJv day of ~
consideration of the attached CUstody Con lia ion
and directed as follows:
, 1998, upon
Report, it is ordered
1. The Father, Jeffrey.A. Casper, and the Mother, Linda J. Casper,
shall have shared legal custody of Preston Clark Casper, born October 16,
1988, and sloane Rebo Casper, born November 5, 1991. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make
all major non-emergency decisions affecting the Children's general
well-being including, but not limited to, all decisions regarding their
health, education and religion. pursuant to the terms of this paragraph,
each parent shall be entitled to all records and information pertaining to
the Children including, but not limited to, school and medical records and
information.
2. Pending a second custody conciliation Conference on August 18,
1998, the Mother shall have primary physical custody of the Children and
the Father shall have visitation and/or partial physical custody of the
Children in accordance with the recommendations of the Children's
counselor.
3. Both parties shall cooperate in participating in and insuring that
the Children partici~.te in counseling.
4. The parties and their counsel shall attend a second custody
Conciliation Conference on August 18, 1998 at 1:00 p.m. in the office of
the Conciliator Dawn S. sunday, Esquire.
5. Neither party shall do or say anything which may estrange the
Children from the other parent, injure the opinion of the Children as to
the other parent, or hamper the free and natural developnent of the
Children's love and respect for the other parent.
TRUE COpy FROM RECORD
In Te$l m3ny " h r, of. I h:re unto SElt my hand
and the seal of said Courl at Carlisle, Pa.
This 131!'-"d day oL,..M~......:1. 19..'l..f.
, ,(T~,
. ....1-I.......a-
..................~..:.~;~i.h'O';W;~
cc: Robert L. O'Brien, Esquire - Counsel for Father
Barbara Sumple-Sullivan, Esquire - Counsel for Mother
BY THE COURT,
HI U.roML c... l:t~
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JEFFREY A. CASPER , : IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COONTY, PENNSYLVANIA
.
.
.
, vs. : NO. 98-375 CIVIL TERM
.
.
LINDA J. CASPER, . CIVIL ACTION - LAW
.
Defendant . IN CUSTODY
.
CUSTODY cnlCn.IATIOO &HlARY REPORT
IN ACXXlUlANCE wrm ctImERIJ\ND cx:oNTY: RULE OF CIVIL 1'~
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. '!tie pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
DATE OF BIRTH
CURRENrLY IN CDS'l'ClDY OF
Preston Clark Casper
Sloane Rebo Casper
October 16, 1988
November 5, 1991
Mother
Mother
2. A Conciliation Conference was held on June 30, 1998, with the
following individuals in attendance: The Father, Jeffrey A. Casper, with
his counsel, Robert L. O'Brien, Esquire, and the Mother, Linda J. Casper,
with her counsel, Barbara sumple-Sullivan, Esquire.
3. '!tie parties agreed to entry of an Order in the form as attached.
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Daii~c~
CUstody Conciliator
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JEFFREY A. CASPER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
\
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:
vs.
:
NO. 98-375
CIVIL TERM
LINDA J. CASPER,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
.
. '
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PRICE. JUDGE: Bdward Guido
CUSTCOY c:x:NCILIATICN SlJlolHARY REPCm.'
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IN ACOJRDANCE WITH ctlmERLAND CXXJNrY RULE OF CIVIL PROCEIXlRE.
1915.3-8, the undersigned Custody Conciliator submits the following report:
r
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1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
DATE OF BIRTH
alRRENrLY IN CUSTODY OF
Preston Clark Casper
Sloane Rebo Casper
October 16, 1988
November 5, 1991
Mother
Mother
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2. A second Conciliation Conference was held on August 18, 1998, with
the following individuals in attendance: The Father, Jeffrey A. Casper,
who is no longer represented by counsel in this matter, and the Mother;
Linda J. Casper, with her counsel, Barbara Sumple-Sullivan, Esquire.
3. The parties agreed that it is not necessary to obtain a Court
Order at this time modifying the current Order dated July 9, 1998. The
parties were able to agree, however, on a course of action to accelerate
the process through which Father will be able to develop'his relationship
with the Children through counseling and visitation. It was agreed that
the Father will take the initiative to obtain information on an institution
offering supervised visitation so that periods of custody can be
established as soon as possible. At the same time, the parties will both
discuss with the current counselor, Paul Dickerson, their mutual desire to
more aggressively pursue progress toward expanded custody arrangements
through counseling. Finally, the Father will contact an independent
counselor to arrange sessions specifically for the parties' daughter.
4. A third CUstody Conciliation Conference is scheduled for November
19, 1998 at 1:00 p.m.
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'Date r:J '
dl~~dn. -
Dawn S. Sunday, Esquire ti
Custody Conciliator
cc: Jeffrey A. Casper, Father
Barbara Sumple-Sullivan, Esquire - Counsel for Mother
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100 Ca)' Semi
CarUst., PA 11013
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'0:(717)204191
HARJUSIt/R.C
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HurlIbWlo PA mot
(717)671-9610
Fax: (117) 67t-96!0
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6f/19MainStrftI
Eut P.tenburs.'A Imo
(717)560-19OI!
FlJC(T17).s60-49-41
LEBANON
.os N. f1hunth AnnUl
Lc~n. PA li'OU
(717)272-1653
FU:(717)m-tl66
READINC
1733 r'M Annu'
Wyom1ulns Hilli, PA ,_
CultrOtyOlflu
SOl WaihlnlfDnStm:t
SWttJOI
Readlns.PAl9601
(610)670-TZ7l)
Fu:(6111j678-38'2
RENAISSANO
10 I Chestnut Strftt
~I\PAI70i1
('117)21"21,11
F&x:(717) 274.S405
'YORK
16 Mount ZIon ao.4
York,PAI7.w2
(717)&4a.o?&4
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Pennsylvania Counseling Services - West Shore
HS Celly.burg Pike. Mech.nlcburg, PA 17055 . (717) 795-8363 . Pax: (717) 796-1466
Barb.../. Sdunltt, M.A" CAC, Clinic Dim/or
Roy A. Smith /r" Ph,D" P,rsWtnt, CEO' Ruth M. D.vls, MBA, E.rtcUtlvc Vicc.P,rsWtn'
August 13, 199B
Mr. Jeffrey Casper
Dear Mr. Casper,
I am writing to 'review my recommendations for treatment .and
visitation in preparation for the conciliation hearing set for
August, 199B. I will be forwarding a copy of this letter to Ms.
Linda Casper as we discussed earlier today, so that you each may
present the goals listed here at that hearing to foster communication
and cooperation.
The recommendations are:
1) Continue with weekly sessions here at Pennsylvania Counseling
Services--West Shore Office with you and your son. These
appointments should be held regularly as standing appointments, and
should only be preempted in the case of emergencies, or mutually
agreed-upon changes. This would include your daughter at a time
after she has had a chance to meet with another therapist for '
evaluative sessions. I will continue to work with you and Ms. Casper
to procure this additional therapy. As we have reviewed befere,
procuring this additional therapy has been difficult because of
confusion regarding insurance access policy in this complex
situation, and because it is difficult finding therapists with
available evening appointments.
2) Supervised visits with the children, with their general pace
in mind (perhaps at a YWCA, or with another agreed-upon third party,
and not at your home to begin with). The supervised arrangement
would be in place to minimize needless misunderstandings.
3) Schedule visits, at your children's general pace, at your
home during a weekend, not to be overnight to begin with.
4) Overnight weekend visits as a goal.
Any specific dates that are suggested regarding this process
should be seen with the children's best interests in mind, and should
be considered as desirable goals, rather than firm deadlines. It is
also important for the sake of the children that this process not be
needlessly prolonged. Also, again to minimize needless
misunderstandings, transportation should be arranged by Ms. Casper
until sufficient rapport has been re-established with the children.
"
I have worked to provide a general atmosphere of permission
I . . (' ('\
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. .
I
i JEFFREY A. CASPER, . IN THE COURT OF COMMON PLEAS OF
i .
I Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. : NO. 98-375 CIVIL TERM
I :
LINDA J. CASPER, . CIVIL, ACTION - LAW
.
Defendant . IN CUSTODY
.
ORDER OFaxJRT
AND tl:M, this 3...,.(
consideration of the attached
and directed as follows:
day of ,(&~J~l-<....... , 1998, upon
CUstody Conciliation Report, it is ordered
1. This Court's prior Order dated July 9, 1998 is vacated and replaced
with this Order.
2. The Father, Jeffrey A. Casper, and the Mother, Linda J. Casper,
shall have shared legal custody of Preston Clark Casper, born October 16,
1988, and Sloane Rebo Casper, born November 5, 1991. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make
all major non-emergency decisions affecting the Children's general
well-being including, but not limited to, all decisions regarding their
health, educati,on and religion. Pursuant to the tel:lllS of .this paragraph,
each parent shall be entitled to all records and information pertaining to
the Children including, but not limited to, school and medical records and
information.
3. The Mother shall have primary physical custody of the children.
4. The Father shall have partial physical custody of the Children in
accordance with the following schedule:
"
Sunday, November 22, 1998 and Sunday, November 29, 1998 from 1:00
p.m. until 6:00 p.m..
Sunday, December 6, 1998 and Sunday, December 13, 1998 from 9:00
a.m. until 6:00 p.m.
Saturday, December 19, 1998 at 9:00 a.m. t~!ough Sunday, December
20, 1998 at 6:00 p.m.
Saturday, January 2, 1999 at 9:00 a.m. through Sunday, January 3,
1999 at 6:00 p.m.
Saturday, January 16, 1999 at 9:00 a.m. through Sunday, January
17, 1999 at 6:00 p.m.
Saturday, January 30, 1999 at 9:00 a.m. through Sunday, January
(,
(-
I
31, 1999 at 6:00 p.m.
Beginning on February 12, 1999 and continuing thereafter, on
alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00
p.m.
At sUch'additional times as reasonably requested by the Father and
arranged by agreement of the parties.
"
"
5. During the Father's periods of custody with the Children through
November 29, 1998, the Father shall ensure that the Children do not have
contact with the Father's girlfriend who also resides in the Father's home.
This limitation shall not apply following the Father's period of custody
with the Children on November 29, 1998.
6. The parties shall share or alternate having custody of the
Children on holidays as follows:
A. Christmas: In every year, the Father shall have custody of
the Children on Christmas Eve from 9:00 a.m. until 6:00 p.m.
The Mother shall have custody of the Children from Christmas
Eve at 6:00 p.m. through Christmas Day at 6:00 p.m.
B.
Alternating Holidays:
custody of the Children
a.m. until 6:00 p.m.:
Thanksgiving ,- New Years Day, Memorial Day, July 4th, and L'abor
Day. The alternating holiday schedule shall begin with the
Mother having custody of the Children on Thanksgiving in 1998.
The parties shall alternate having
on the following holidays from 9:00
D. Mother's Day/Father's Day: In every year, the Mother shall
have custody of the Children on Mother's Day from 9:00 a.m.
until 6:00 p.m. and the Father shall have Custody of the
Children on Father's Day from 9:00 a.m. until 6:00 p.m.
7. The holiday custody schedule shall supersede and take precedence
over the regular custody schedule.
8. Each party shall be entitled to have custody of the Children for
two (2) weeks (consecutive or non-consecutive) during each sunmer school
vacation, upon providing at least thirty (30) days advance notice to the
other party.
9. The Father agrees to attend counseling sessions with the Children
through December 13, 1998.
'10. The parties shall exchange custody of the Children at George's
Family Restaurant in New Kingston.
11. Neither party shall do or say anything which may estrange the
Children fran the other parent, injure the opinion of the Children as to
the other parent, or hamper the free and natural development of the
(
()
Children's love and respect for the other parent.
12. This Order is entered prusuant 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.
,
.'
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BY THE COURT,
/~tdU;:LGjdf li....A J.
cc: Jeffrey A. casper, Father - Pro Se
Barbara Sumple-sullivan, Esquire - Counsel for Mother
TRUE COpy FROM RECORD
In To~llmony W!W6ot, I ham unto wI my hand
and the ~al of said Coort at Carlisle, Pa.
This 1/') day O~~~190>
l t~~. Z'! .N.". ~
. Prothonotary
"
. .
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.
JEFFREY A. CASPER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUNBERLAND COUNTY, PENNSYLVANIA
vs.
.
.
: NO. 98-375
CIVIL TERM
LINDA J. CASPER,
Defendant
.
.
CIVIL ACTION - LAW
IN CUSTODY
PRIOO JUDGE: Edward E. Guido
CIJS"la)y a:NCII.IATIOO stMoIARY REPCm.'
IN Ac:xnmANcE WITH CDIBERLANo CXXlNTY RULE OF crvn. PROCEIlORE
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. '!tie pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
-
DAi'E OF BIRTH
CURREN.rr.y IN CUSToDY OF
Preston Clark Casper
-Sloane Rebo Casper
October 16, 1988
November 5, 1991
Mother
Mother
2. A third Conciliation Conference was held on November 19, 1998,
with the following individuals in attendance: The Father, Jeffrey A.
Casper, Pro Se, and the Mother, Linda J. Casper, with her counsel, Barbara
Sumple-Sullivan, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
;0;,,,..- ..I., A
Date
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,
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Dawn S. Sunday, Esqu re
CUstody Conciliator .
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JEFFREY A. CASPER,
Plaintiff
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IN T"E COURT OF COMMON PLEAS
OF CUM/JERLAND COUNTY,
PENNSYLVANIA
vs.
LINDA J. CASPER,
Defendant
NO.lJll-J75 CIVIL TERM
CIVIL ACTION - LA W
[;(Q){JiJ\1
COUNTER-AFFIDA VIT UNDER SECTION 33/11 d OF THE DlVOI~CE CODE
I. Check either (a) or (b):
- (a) 1 do not oppose the entry of a divorce decree.
- (b) I oppose the entry of a divorce decree because (Check (i), Oi) or both):
0)
-
The parties to this action have not lived separate and apart for a
period of at least two years.
_Oil
The marriage is not irretrievably broken.
2. Check either (a) or (b):
- (a) I do not wish to make any claims for economic relief. I understand that I may
lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim
them before a divorce is granted.
- (b) I wi3h to claim economic relief which may include alimony, division of
property, lawyer's fees or expenses or other important rights.
I verify that the statements made in this counter-aflidavit are true and correct.
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:
JEFFREY A. CASPER
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JEFFREY A. CASPER,
Plaintiff
IN TilE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 98-375
.
.
LINDA J. CASPER,
Defendant
CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF CXXlRT
.J A...u~
AND tl:M, this J~ day of ~- ~
upon consideration of the attached Custody Conciliation
ordered and directed as follows:
, 1999,
Report, it is
1. The prior Orders of this Court dated December 3, 1998 and
February 24, 1999 are vacated and replaced with this Order.
2. The Father, Jeffrey A. Casper, and the Mother, Linda J.
Casper, shall have shared legal custody of Preston Clark Casper, born
October 16, 1988, and Sloane Rebo Casper, born November 5, 1991. Each
parent shall have an equal right, to be exercised jointly with the other
parent, to make all major non-emergency decisions affecting the Children's
general well-being including, but not limited to, all decisions regarding
their health, education and religion. Pursuant to the terms of this
paragraph, each parent shall be entitled to all records and information
pertaining to the Children including, but not limited to, school and
medical records and information.
Children.
3. The Mother shall have primary physical custody of the
4. The Father shall have partial physical custody of the
Children in accordance with the following schedule:
Sunday, April 18, 1999 and Sunday, April 25, 1999 from 1:00 p.m.
until 3:00 p.m. The maternal grandfather will bring the
Children to the Trindle Bowling Alley in Mechanicsburg and shall
remain at the bowling alley during these two periodS of custody.
Sunday, May 2, 1999 from 1:00 p.m. through 5:00 p.m.
Sunday, May 9, 1999, Sunday, May 16, 1999 and Sunday, May 23,
1999 from 9:00 a.m. until 6:00 p.m
Saturday, June 5, 1999 at 9:00 a.m. through Sunday, June 6, 1999
at 6:00 p.m.
"
"
"
Saturday, June 19, 1999 at 9:00 a.m. through Sunday, June 20,
1999 at 6:00 p.m.
Saturday, July 3, 1999 at 9:00 a.m. through Sunday, July 4, 1999
at 6:00 p.m.
Saturday, July 17, 1999 at 9:00 a.m. through Sunday, July 18,
1999 at 6:00 p.m.
Beginning on July 30, 1999 and continuing thereafter, on
alternating weekends from Friday at 6:00 p.m. until Sunday at
6:00 p.m.
At such additional times as reasonably requested by the Father
and arranged by agreement of the parties.
5. The parties shall share or alternate having custody of the
Children on holidays as follows:
A. CHRISTMAS: In every year, the Father shall have custody of
the Children on Christmas Eve from 9:00 a.m. until 6:00 p.m.
and the Mother shall have custody of the Children from
Christmas Eve at 6:00 p.m. through Christmas Day at 6:00
p.m.
B. ALTERNATING HOLIDAYS: The parties shall alternate having
custody of the Children on the following holidays from 9:00
a.m. until 6:00 p.m.: Thanksgiving, New Years Day, Memorial
Day, July 4th, and Labor Day. The alternating holiday
custody schedule shall continue on the same cycle which
originated with the Mother having custody of the Children on
Thanksgiving in 1998.
C. MOl'fIER'S DI\Y/FATIIER'S DAY: In every year, the Mother shall
have custody of the Children on Mother's Day from 9:00 a.m.
until 6:00 p.m. and the Father shall have custody of the
Children on Father's Day from 9:00 a.m. until 6:00 p.m.
6. The holiday custody schedule shall supersede and take
precedence over the regular custody schedule.
7. Beginning in 2000, each party shall be entitled to have
custody of the Children for two weeks (consecutive or non-consecutive)
during each summer school vacation, upon providing at least thirty days
advance notice to the other party.
8. The Father shall refrain from consuming alcoholic
beverages/illegal dL'1lgs for at least 24 hours prior to his periods of
custody with the Children and continuing throughout his periods of custody.
9. Neither party shall use corporal or physical punishment in
disciplining the Children.
10. The Father shall complete the 26 week counseling program
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JEFFREY A. CASPER, . IN TilE COURT OF COMMON PLEAS
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
vs. NO. 98-375
:
LINDA J. CASPER, CIVIL ACTION - LAW
Defendant . IN CUSTODY
.
PRICE JUDGE: Edward E. Guido
CUS'roDY CXH:ILIATlOO SlIlMARY REPOOT
IN AlXnIDANcE WITH <nIBERLAND CXXNlY RULE OF CIVIL p~
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:
Child I S Name
Date of Birth
CUrrently In Custody of
Preston C. Casper
Sloane R. Casper
October 16, 1988
November 5, 1991
Mother
Mother
2. A Conciliation Conference was held on April 14, 1999, with
the following individuals in attendance: The Father, Jeffrey A. Casper,
with his counsel, James K. Jones, Esquire, and the Mother, Linda J. Casper,
with her counsel, Barbara Sumple-Sullivan, Esquire.
attached.
3. The parties agree to entry of an Order in the form as
I~
Date
ac.-~~c~
Dawn S. Sunday, Esquire
Custody Conciliator
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JEFFREY A. CASPER,
CQ,M.1V10JiVlLEALJ'lLQE..e.ENN_SYL V A!\ll~
G!:tUJIJTY_OLC_U_IV1B_EIlLI;\ N l:!._s"S.1
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
vS.
LINDA J. CASPER,
NO. 98.375 CIVIL TERM
Dafandant
CIVIL ACTION, LAW
MOTION FOR APPOINTMENT QF MASTER
LINDA J. CASPER, ( ) Plaintiff ( X ) Dafendant moves the court to appoint a Master with respect
to the following claims:
(X ) Divorce
( ) Annulment
( ) Alimony
( ) Alimony Pendente Lite
X ) Distribution of Property
) Support
) Counsel Fees
) Costs and Expenses
and in support of the motion states:
1. Discovery is complete as to the claim(s) for which the appointment of a Master is
requested.
2. The Plaintiff ( X ) has ( ) has not appeared in the action ( ) personally ( X ) by his
attorney, James K. Jones, Esquire, although it is believed that the Plaintiff is now representing
himself pro se.
3. The statutory ground(s) for divorce (is) (are): irretrievable breakdown (3301 (c)) and
3301 (d) (the parties separated on December 27, 1997).
4. Check the applicable paragraph(s), by check mark:
) The action Is not contested.
) An agreement has been reached with respect to the following claims: None.
( X) The action is contested with respect to the following claims: Equitable Distribution
and Divorce.
5. The action ( ) involves ( X ) does not involve complex issues of iaw or fact.
6. The hearing is expected to take two hours.
Date:
7. Additional information, if any, relevant to the motion:
Y0'7'i-1 )0
Attorney for Def~t'}-J
/.:2-- . 2000, E. bert Elicker, II, Esquire, is appointed
9 claims: " ;/
// JAe;J6XD
AND NOW. (
as master with respect/t'o the followi
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JEFFREY A. CASPER
PLAINTIFF
V.
LINDA J. CASPER
DEFENDANT
INTI IE COURT OF COMMON PLEAS OF
CLlMBERI.AND COUNTY, PENNSYLVANIA
98-375
CIVIl. ACTION LAW
IN CUSTODY
OJUlIo:R OF eOllRT
AND NOW, this 27TH day of OCTOBER. 2000, upon considcration of the attached Complaint,
it is hereby directed that the parties and their respective counsel nppear befllre Dawn S. Sunday, Esq. ,the conciliator.
at 39 West Main Street, Mechanlcsbur~,I'A 17055 on the 16TItlayof NOVEMBER. 2000, at --2;30 P.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 10 be heard by the court, and to enter into a temporary
order. All children age live or older may lllso be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary 01' penn anent order.
FOR THE COURT,
l3y: /s/
Dawl/ S. Sill/day. Esq/IJ
Custody Conciliator
The Court of Common Pleas of Cumberlllnd County is required by law to comply wilh the
Americans with Disabilites Act of 1990. For information about accessible faeilitics and reasonable
accommodations aVllilablc to disabled individuals having business before the court, please contact our office.
All arrangements musl be madc 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 A'/TORNEY AT ONCE. IF YOU DO NOT
HAVE AN A ITORNEY 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 A venue
Carlisle. Pennsylvania 17013
Telephone (717) 249-3166
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IN TIlE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
JEFFREY A. CASPER,
Plaintill'
Defendant
.
.
.
.
.
.
.
CIVIL AC'I'/ON - CUSTODY
NO. 98-375
V.
LINDA J. CASPER,
ORDER
YOU, LINDA ,I, CASI'ER, arc ORDEREI) to appear in person in the Custody Conciliation
Office, Cumber/and County Courthouse, One Courthouse Square, Carlisle, Pennsylvania on the
day of ,2000, at o'clock, AMII'M
for a Custody Pre-Hearing Conference.
AT such Conference an eflort 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 a Temporary
Order. All children age live (5) or older shall also be prescnt at the Conference at the request of
either party. IF YOU FAIL TO AI'I'EAR as provided by this Order, an Order for custody may be
entcrcd against you or the Court may issue a warrant for your arrcst.
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
Cumber/and County Courthouse
3 S. Hanover Street
Carlisle, PA 170/3
Telephone: (717) 697-0371
FOR THE COURT:
Date:
Custody Conference Officer
.
JEFFREY A. CASPER,
Plaintiff
IN THE COUR7' OF' COMMON PLEAs
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
.
.
LINDA J. CASPER,
Defendant
: No. 98-375
CIVIL ACTION - LAW
: IN CUSTODY
~OF~
..J .
AND 1OI, this ;;9 day of ~
upon consideration of the attached Custody Conciliation
ordered and directed as follows:
, 1999,
Report, it is
1. The prior Orders of this Court dated December 3, 1998 and
February 24, 1999 are vacated and replaced with this Order.
2. The Father, Jeffrey A. Casper, and the Mother, Linda J.
Casper, shall have shared legal custody of Preston Clark Casper, born
October 16, 1988, and Sloane Rebo Casper, born November 5, 1991. Each
parent shall have an eqUal right, to be exercised jointly with the other
parent, to make all major non-emergency decisions affecting the Children's
general well-being inclUding, but not limited to, all decisions regarding
their health, education and religion. Pursuant to the terms of this
paragraph, each parent shall be entitled to all records and information
pertaining to the Children inClUding, but not limited to, schOOl and
medical records and information.
\
Children.
3. The Mother shall have primary phYsical custody of the
.
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4. The Father shall have partial physical custody of the
Children in accordance with the following Schedule:
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Sunday, April 18, 1999 and Sunday, April 25, 1999 from 1:00 p.m.
until 3:00 P.m. The maternal grandfather will bring the
Children to the Trindle BOWling Alley in Mechanicsburg and shall
remain at the boWling alley during these two periods of custody.
Slmday, May 2, 1999 from 1:00 p.m. through 5:00 P.m.
Sunday, May 9, 1999, Sunday, May 16, 1999 and Sunday, May 23,
1999 from 9:00 a.m. until 6:00 p.m
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Saturday, June 5, 1999 at 9:00 a.m. through Sunday, June 6, 1999
at 6:00 P.m.
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Exhibit "A"
Saturday, June 19, 1999 at 9:00 a.m. through Sunday, June 20,
1999 at 6:00 p.m.
Saturday, July 3, 1999 at 9:00 a.m. through Sunday, July 4, 1999
at 6:00 p.m.
Saturday, July 17, 1999 at 9:00 a.m. through Sunday, July 18,
1999 at 6:00 p.m.
Beginning on July 30, 1999 and continuing thereafter, on
alternating weekends from Friday at 6:00 p.m. until Sunday at
6:00 p.m.
At such additional times as reasonably requested by the Father
and arranged by agreement of the parties.
5. The parties shall share or alternate having custody of the
Children on holidays as follows:
A. CHRISTMAS: In every year, the Father shall have custody of
the Children on Christmas Eve from 9:00 a.m. until 6:00 p.m.
and the Mother shall have custody of the Children from
Christmas Eve at 6:00 p.m. through Christmas Day at 6:00
p.m.
B. ALTERNATING HQLIDl\YS: The parties shall alternate having
custody of the Children on the following holidays from 9:00
a.m. until 6:00 p.m.: Thanksgiving, New Years Day, Memorial
Day, July 4th, and Labor Day. The alternating holiday
custody schedule shall continue on the same cycle which
originated with the Mother having custody of the Children on
Thanksgiving in 1998.
C. MO~~'S DAY/FATHER'S DAY: In every year, the Mother shall
have custody of the Children on Mother's Day from 9:00 a.m.
until 6:00 p.m. and the Father shall have custody of the
Children on Father's Day from 9:00 a.m. until 6:00 p.m.
6. The holiday custody schedule shall supersede and take
precedence over the regular custody schedule.
7. Beginning in 2000, each party shall be entitled to have
custody of the Children for two weeks (consecutive or non-consecutive)
during each sunmer school vacation, upon providing at least thirty days
advance notice to the other party.
8. The Father shall refrain from consuming alcoholic
beverages/illegal drugs for at least 24 hours prior to his periods of
custody with the Children and continuing throughout his periods of custody.
9. Neither party shall use corporal or physical punishment in
disciplining the Children.
10. The Father shall complete the 26 week counseling program
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at Tressler Lutheran Services in which he is currently participating. The
Father shall provide to the Mother's counsel a written progress report from
his counselor on a biweekly basis.
ll. The parties shall exchange custody of the Children at
George's Family Restaurant in New Kingston.
12. Neither party shall do or say anything which may estrange
the Children from the other parent, injure the opinion of the Children as
to the other parent, or hamper the free and natural development of the
Children's love and respect for the other parent.
13. 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
Edward E. Guido,
J.
cc:
James K. Jones, Esquire - Counsel for Father
Barbara Sumple-Sullivan, Esquire - Counsel for Mother
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JEFFREY A. CASPER, . IN THE CCURT OF CXlMMON PLEAS OF
.
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. . NO. 98-375 CIVIL TERM
.
LINDA J. CASPER, . CIVIL ACTION - LAW
.
Defendant : IN CUSTODY
ORDER OF CXXlRT
AND tl:M, this J ( ~ day of tJ ~
upon consideration of the attached CUstody Conciliation
ordered and directed as follows:
, 2000,
Report, it is
1. The prior Order of this Court dated April 22, 1999 is vacated and
replaced with this Order.
2. The Mother shall continue to have primary physical custody of the
Children.
3. The Father shall participate in at least one individual ccunseling
session and the Mother shall arrange and make the Children available for a
separate counseling session both of which shall be scheduled with the same
counselor in preparation for joint cOlmseling for the Father and Children.
The purpose of the ccunseling shall be tc reinitiate contact between the
Father and the Children through a process which will best serve the
interests of the Children. The parties shall follow the recommendations of
the counselor with respect to initiation and expansion of contacts between
the Father and Children and with respect to additional counseling, if
necessary. The counselor shall be selected by agreement of the parties and
counsel. The Father shall be responsible for all costs of counseling which
are not reimbursed by insurance coverage.
4. '!tie Father shall enroll and participate on an ongoing basis in the
Alcoholics Anonymous program and shall follow the recommendations of the
program counselor or sponsor. The Father shall provide, to the Mother or
her counsel, monthly documentation of the Father's attendance and
participation in the program. If the Father is unable to oetain
documentation fran the program, the Father shall authorize the Mother or
the Mother's ccunsel to obtain documentation pertaining to the Father's
attendance and participation in the program directly from program
personnel.
5. within 9C days of the first ccunseling session required by
paragraph 3 of this Order, ccunsel for either party may contact the
~
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Conciliator to schedule an additional CUstody Conciliation Conference, if
necessary.
J.
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cc: Timothy J. Colgan, Esquire - Counsel for Father
Barbara SUmple-Sullivan, Esquire - Counsel for Mother
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JEFFREY A. CASPER,
plaintiff
:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
VB.
NO. 98-375
CIVIL TERM
LINDA J. CASPER,
Defendant
CIVIL ACTION - LAW
IN CUSTOCY
PRICE JUDGE: Edward E. Guido
CUSTODY cnlCILIATIOO SlHIARY REPCR:r
IN ACCXJRDANCE WITII ctImERIJ\ND CXXmY RULE OF CIVIL PROCEDURE
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 BIRTH
CURRENrLY IN CUSlOOY OF
Preston Clark Casper
Sloane Rebo Casper
October 16, 1988
November 5, 1991
Mother
Mother
2. A Conciliation Conference was held on November 16, 2000, with the
following individuals in attendance: The Father, Jeffrey A. casper, with
his counsel, Timothy J. Colgan, Esquire, and the Mother's counsel, Barbara
Sumple-Sullivan, Esquire. The Mother, Linda J. Casper was unable to attend
the Conference at the scheduled time.
3. The parties agreed (through counsel, on behalf of the Mother) to
entry of an Order in the form as attached.
Date
;UcJN!..,......~1 /Ct.:'JNJr)
,
~^_.d.il,..-",d.a
Dawn S. Sunday, Esqulr
Custody Conciliator