HomeMy WebLinkAbout98-00493
,-
'@ FEH 2 ti 199B
SUSAN A. SHEAFFER,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
.
,
V
:CIVIL ACTION - LAW
.
.
TIMOTHY C. SHEAFFER,
Defendant
:NO: 493 CIVIL 1998
:IN CUSTODY
COURT ORDER
AND NOW, this d.6 t:A day of February, 1998, upon consideration of
the attached Custody Conciliation Report, it is ordered and
directed as follows:
1. The Mother, Susan A. Sheaffer, and the Father, Timothy C.
Sheaffer, shall enjoy shared legal custody of Jessica A.
Sheaffer, born March 14, 1988; Pamela R. Sheaffer, born
December 13, 1989; and William Carl Sheaffer, born January 3,
1993.
2. The Mother shall enjoy primary physical custody of the minor
children.
3, Father shall enjoy liberal periods of temporary physical
custody of the minor children at such times as agreed upon by
the parties. It is anticipated by this Order that the Father
would be able to enjoy some extended summertime vacation with
the children
4. In addition to the three children named above, Father shall
also enjoy temporary custody with Cassandra L. Duppstadt, born
February 17, 1987, when he has custody of the other three
children. Cassandra is the natural child of the Mother and
the Father's rights to see Cassandra pursuant to the agreement
of the parties is based upon his close relationship with the
minor child over the past few years.
5. This Order is entered pursuant to an agreement reached by the
parties at a Custody Conciliation Conference, In the event
either party desires to modify this agreement, that party may
petition the Court to have the case again scheduled for a
conference with the Custody Conciliator,
J.
Edward E. Guido
cc: James J. Kayer, Esquire
Timothy C. Sheaffer
144 McAllister Church Road
Carlisle, PA 17013
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SUSAN A. SHEAFFER,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:
V
:CIVIL ACTION - LAW
.
.
TIMOTHY C. SHEAFFER,
Defendant
:NO: 493 CIVIL 1998
:IN CUSTODY
Prior Judge: Edward E. Guido
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the
following report:
1. The pertinent information pertaining to the children who are
the subject of this litigation is as follows:
Jessica A. Sheaffer, born March 14, 1988; Pamela R, Sheaffer,
born December 13, 1989; and William Carl Sheaffer, born
January 3, 1993.
2. A Conciliation Conference was held on February 19, 1998, with
the following individuals in attendance:
The Mother, Susan A. Sheaffer, wi th her counsel, James J.
Kayer; and the Father, Timothy C. Sheaffer, who appeared
without legal counsel.
3. The parties agreed to the entry of an Order in the form as
attached.
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Hubert X. Gilroy,
Custody Conciliat
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LAS ON SYSTEMS, INC,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
Plaintiff,
v.
CAPITAL RECOVERY ASSOC"
INC"
CIVIL ACTION. LA W
Defcndant.
NO, 96.493 Civil Tcrm
ORDER
AND NOW, this
day of
" 1998, upon considcration of
Defendant's Motion for Non.Pros in the abovc captioncd matter, said Motion is hercby
GRANTED.
BY THE COURT
J,
Distribution:
Norma R. Frank, Esquire
405 Andrcw Road
Marion, P A 19066
Deanna Lynn Smith, Esquire
76 Greenmont Drive
Enola, P A 17025
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SUSAN A, SHEAFFER,
Plnintiff/petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
( ") '. -l
NO, 98- CIVIL TERM ;""01
CIVIL ACI'ION - LA W "
';,
v.
TIMOTHY C, SHEAFFER,
Defendant/Respondent
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IN CUSTODY
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EMERGENCY PETITION Fon SPECIAL RELIEF UNDER PlI.n.C,P,1915.13 ::~,j
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COMES NOW, the Petitioner, SUSAN A, SHEAFFER, throngh her altorneysl'Kayer;&
Brown, and who does hereby aver as follows:
1. The Petitioner, Susan A, Sheaffer is an adult individual residing at Lot 180, Big Spring
Terrace, Newville, Cumberland County, Pennsylvania, 17241.
,
2, The Respondent in this action, Timothy C, Sheaffer, is an adult individual believed
to be residing at 144 McAllister Church Road, Carlisle, Cumberland County, Pennsylvania,
17013,
3, The Petitioner in this action has concurrently filed with this Petition, a Complaint for
Custody of three children, Jessica A, Sheaffer, date of birth March 14, 1988, Pmnela R. Sheaffer,
date of birth December 13, 1989 and William Carl Sheaffer, date of birth, January 3, 1993, The
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Petitioner is the mother of these children and has lived with them their entire lives,
4, The Respondent is the father of the subject children,
5, lllCre is no prior Court Order or agreement pertaining to the custody of the children,
6, Petitioner mId Respondent resided together at the marital residence located at Lot 180,
Big Spring Terrace, Newville, PA, until January 27, 1998,
7, On January 27, 1998, Respondent packed his bags and left the marital residence and
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advised the Petitioner that she would ultimately regret forcing him to leave the marital home,
8, On the morning of January 27, 1998, Petitioner received a telephone call from the
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'yEHIFICA'I'ION OF PLEADINGS
The foregoing documcnl is bascd upon information which has becn !lathcred by Illy
counscl and mysclf in thc prcparalion of this IIclion, The IlIuguagc of the documenlmay, in part,
be the IlInguagc of m)' counsel and not lilY own, I have rcad lhe slatemcnts made in this
document amI to the exlent Ihal it is based upon information which I have givcn to m)' counsel,
il is Irue IInd cOlTecl to the besl of my knowlcdge, inforllllltion IInd belief, To the c,xlcnllhat thc
contents of the slatements IIrc that of counsel, I have relied upon counscl in making this
Vcrification, I understand lhat false statemcnts herein IIrc made subject to the Jlcnallies of 18 Pa,
C,S, Seclion 4904, I'elnting to unsworn falsification to authorities,
Date: ~0\.m rl '7
, 1998
b d it," !/Jd
/ / 1/
. Sv~C\0 A..s, \'\ea{-\e r
: IN TIlE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
Plaintiff
v,
· \\mo\""-I c.., ~""c:C\ ~~r
Dcfcndant
: CIVIL ACTION LA W
iNo. L\9~ CIVIL 19q8
: CUSTODY VISITATION
ORDER OF COURT
And now, this lJ~"Ilqg ,upon consideration ofthc attached com laint, it is hereby directcd
that the above parties and their respcctive counsel appear before 'r-\- ' ,
Esquire, the conciliator, at L\ \-1"\ f"\, (' f-:'I-{\ ,
" Pennsylvania, on the I q day of l-f> I:-i'. ICl Y , 1998, at q:.::, (J A, I 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 to be heard
by the court, and to enter into a temporary order, All children age five or older may be present at
the conference. Failure to appear at the conference may provide grounds for the entry of a
temporary or permanent order.
FOR THE COURT:
By: rE;'nOr\ { J(,~l"M_
Custody Conciliator em':) -"'\"
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER 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,
THE CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY A VENUE
CARLISLE, PA 17013
(7 I 7) 249.3166
1-800.990-9108
From 1993 umil Juue 19lJ6 with mother and fnther, Susan Sheaffer & Timothy Sheaffer allll Shirley
Sheaffer, patenml grandmother, at 144 McAllister Church Road, Carlisle, PA, 17013.
4. 11m mother of the children is Susan A. Sheaffer, who resides at Lot 180 Big Spring Terrace,
Newville, PA 17241. She is married.
5. The father of the children is Timothy Sheaffer, believed to be residing 1lI 144 McAllister
Church Road, Carlisle, PA 17013. He is married.
6. 11le relationship of Plaintiff to the children is that of mother. The Plaintiff currently resides
with the children and the following person(s):
Name
Relationship
NONE
7. 11le relationship of the defendant to the children is that of father. The Defendant currently
resides with the following person(s):
Name
Relationship
Shirley Sheaffer
Paternal Grandmother
8. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation
concerning the custody of the children in this or another court. Plaintiff has no information of a custody
proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know
of a person not a party to the proceedings who has physical custody of the children or claims to have
custody or visitation rights with respect to the children.
9. The best interest and pennanent welfare of the children will be served by granting the relief
requested because the Plaintiff, Susan Sheaffer, can provide a more stable and nurturing atmosphere.
Defendant has threlllened to remove the children from their school district. Plaintiff has traditionally
been the primary caretaker for the children since their birth.
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