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Home My WebLink About98-03818 ROIINUY 11, N1101+14Y, 1 IN T11110, COURT OF G1)MMON I'hWAS OF t (1)MI1U•RI+ANI) COUNTY 1'IainUtl' 1 vs , CIVn, ACTION - LAW t t NUM1110,141 9H- 2")' CIVI14TFIRM TINA S??OL1.Y, I I IN CUSTODY p0fcndnnt t ORDER OF COURT AND NOW, t 1998, upon eonsf0oration of 1110 ottaolrocl complaint for Modification of Custody Order, It Is hereby directed that the parties and their rospootivo opunsol anpoar before a? ?Y, -;?\fp? 1110 conciliator, lit IN r Ism-44 & f A X51.1-1\? ?L1.?? an 1 ho ? _. d1?y of `xv ?C, 1998, it G1.1nt„ for it IIIc-Iloaring custody Contbronaa. At such conference, an ollbri will be made to resolve tiro lssnos in dispute; or If this cannot be acoomplishod, to 0011110 and narrow tiro lmios to be hoard by the Coarl, and to enter Into o temporary, Order. All children ago five or older may also be present at the conforonoe. Failure to appear at the conference may provide grounds for entry of a temporary or permanent Order, For the courts By: 1111wo? Custody Couollialor t? YOU SHOULD TAKE Tills PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER Olt CANNOT AFFORD ONE, GO TO OR TELEP11ONE THE OFFICE SET FORI'll BELOW TO FIND OUT WHERE YOU CAN GET LEGAL IIELP, OFFICE OF THE COURT ADMINIsTRATOR COURTHOUSE, 41,m FLOOR CARLISLE, PA 17013 (717) 240.6200 RODNI",Y D, $1101414Y, vs 1'INlntlff IN'r1lb; COl1R'1' 0G COMMON 1114VAS AID ClIMT14'.R14AND COVNTV CIVII, AC'rION - I,AW NIIMIII;R1 9N.* / ' CIVI1491k4RM 'T'INA $1111014LYt 001101111/1111 IN CIIS'I'ODV COMPLAINT IFOR C115'rODY COMES NOW, the Plnintlll, RODNEY D, $1101414Y, by and through 1118 coullscl, Molly d, Winder, Esquire, and (Ines flue 1110 following Camplahll for Custody, 1. 'Pilo Plaintill'is RODNEY D, SIIO1414V, a Bill Juris Alit Individual, residing at 7 Spring Drive, Shipponsburg, Southalnptnn Township, Cumborland County, Ponnsylvania, 2, 'Pilo Dofundant ls'rINA SIIOI4LY, a sill Juris adult Individual with it nalling address of P O Boy, 35, Lowis Center, Ohio 43035, ?araY?;»sM ax y,,. k'V ma, qh7 ,; (fin) rae,am 3, Plaintiff 8coks Custody of JORDAN D, M1101414Y, born January 05, 1993, Tile owid was not born out of wodlook, The Child Is 14e801111y In the custody of fathm•, RODNEY D, SIIOLLY, who W410 at 7 Spring Drive, Shlpponsburg, Pennsylvania, During tiro past ilvo yours, tiro child has rusided with 1110 following persons and at the following addresses, With both parents at 19 Towne Mills, Shlpponsb4g, Pennsylvania bru birth until March 1994; with both parents at 7 Spring Drive, Shlpponsburg, Pennsylvania, from March 1994 until the parents separated in August 1996, Tile ewid lips resided with the fllthor, RODNEV D,, SIIOLLV, at 7 Spring Drive, Shlpponsburg, Pennsylvania, from August 1996 to present. Tile mother of tiro child 18 TINA $11OLLY, currently rosidhl8 at a oampground in bowls Center, Ohio, Silo Is still married to father, 'file father ol'tho ohild Is RODNEY D, SI101414Y; utlrrontly residing at 7 Spring Drive, . Shlpponsburg, PCnnsylvalOw 110 is still married to mother, although separated, Al HORNGY 11, N1101,1+Y v TINA I11101+IN Pogo k 4. The rolationship of Plaltgiffto tits child IN tbnl of natural lhlltor; tine Plninlifrourrontly rosidos with Jonnlfor Kosor since February 1998. 5. The rolatiombip of Pofendant to the ohildron Is tint of nsturol mullion tile Polbodorn currently rosides with hor boyftiond at it campgrounds In Lpwis center, Ohio, 6, Plointlff bas not participated its a party or witness, or in onotl?or capacity, in othor iltlgatlon concoming the custod'y' of file child It this or anothor Court, Plnioliffhap no hnformollon of a custody prooooding ooncorninu the child pending in a Court of this Commonwealth Plnlntllfdoos not know of it person not it porly to tine prooeotling who has physical custody of tho ohlld or claims to have ouatcity or visitation rights with respect to lino child, 7. The host Interests and pormanont wolflaro of tine child, will be served by granting the relief requested because the child Into primarily boon in tiro core and custody and undor the nurturing of fbihor since the parents separated in August, 1996, Most recently, lino child wont to visit with mother at Lewis Connor, Oldo, and motbor Into rofbsod to bring the child home before tle and oftho sunnnor, The child !)as oalled the Whor crying and asking him to come, got hi?n and saying that ho does not wont to stay with Ms mothor any'longer, The mother Is living in a eampor troller In a oompgrounds and Is not providing proper care and supervision for the child, 8, NO )arant whose porernol rights to the chill have not been tomilinited and tile person who has physlonl Custody of tho child have boon namod as parties to this action, WHEREFORE, Plalntlff roquasls the Court to grant primary residential Custody of tiro child to hi?n subject to reasonable rights of visitation and partial custody lit tile Doforldant, Rospeotlldly submitted, .V 1., - Sally J, WI r, Esquire Attorney 110 InintlIT, RODNEY D. SHOLLY vrwFICA TION I vorli that Ilia alalontonla ntado In tho Porogninlt Complollit In Into on(I oorroot to IN boat of my poraonal knowiacillo and Imhof, 1 undoratttnd that tttluo atatomonta liorain pro tnado auhJoot to tho,ponnitiua of to pit, CIS. Sootlon 4904, rolollnp to anawpnt NsIfioallon to aothorltioal Darn; v"' ?--? R06 V D, IIOL V I, i. i IA PSm h! .I ' .I Ilr 1 ! l I,?y , .. iY,1 111. I. r , I , HAILLv J. WINDEW sa JUI. b N 1894. ANnrneg n1 how f "r 7111 It, KIIIN Simi sIjjpf mImIS,4'A 17257 15P 1 5 ItODNV,Y I), 811OI- N, hlnlntll'I' V TINA hIPI,I,Y, Defendant IN TI IV VOI lIk 1' t)I' Ct1MMON VI,I'AS 01" i CI IMI)I?Itl,r\NI) COUNTY, j1VNNSYI,VANIA 1 CIVII, ACTION . I.AW No, 9H-3418 CIVII• IN CI Ih'I'OPY LMI 7 dn? ' or flu ltumhur, 1098, upon eonsIdcrallo11 Ill' IN Ilunullucl Cuatody this lI AND NOW, 1 CnneIll(Itlon (tupol'h II i4 nrdQrcd (11111 dlruQWd 118 lilllowsf 1 The Hither Rodney 1), Sholly and IN Illolh0r 'I'haI'Sholly Shall e111oy Hharud legal o1141ody o(Jordall 1). Sholly, born ,Iluasay S, 11)91,. 21 The Ihlhur Hhall ellloy pi Inun•y phy41Ci11 CUmNly 01'11110 11111101' 0111111, 11 Thu mother 411111101t10y tualp0rtny physical vamody ol'Ihu Inimlr 011111 as R111OWH1 A, 1)111'11113 the 411nlmur nlontl14 one Week lion) when the child IH 1'010114011 t}'oal school milli Iwo \vCOks before the Chill 14 I•aquil•ed to I'etol'11 to solalol, (fin this vocallon, mother 4111111 make 1111•ange1110als 1111, hml4porlatloll of I116' minor child at the beginning or her period of lumporary otima j' and Oder„ shall make arrangements lilt Iranspurpniun of 1110 CI11Id Mien he 14 to 1111Ve easlolly 1,01111-ned t0 111111 at the clad (11'1110 minaller. IL When Illothul' III In the Si11p11011Hblll•g III-ea 11114 gIVC4 11111101' 1'e114011ablu notice In advancul mother Inay eserClsu periods or lelllpol'la'y Ciamody IIH ligreed upon by tale parties during the Hchool Year, 11 I. The 111111-cuHlodtill parent 4111111 ullloy reilsolalhle lulephollu access \vitll 1110 111111111' Child when the Child IH In the tither pm•u1114' ellmody, When Illothcl' has Custody dla•Ing the salnntur months, motherr AI.III IIl1orn1 Ilse father of it phone nlallWr Where situ 0011 be 1'1'11011011 1111' p11rpOHC4llt'Cltll`rgl,acy calls Hnd.lnothcr 8111111 IIIHO olimire that the Child culls the bather and has I11QIa11110111 telephone CollVersatlolls with the hither at loam once a Week, When h11her I1I18 CIIHII1dy of Ilic child, the child shall he avallable to recelve telephone Contact li•oln the mother on 11 regular basis, ,, . , .... 5, ?I?hIH l11'tlul',IH 0111u1'ucl {1411'BIIlllll In {111 11{11'Pul11u111 I'utluhPcl h?' llW 11tIr1IuH II{ n C11H{pdy ? C nllullhllit11l G tllllpl'ulluu Ill thu ovollt ullhul' Ittll'I>' tlur ll'uy Io.Illntllly lhiH O1'dul', 111t1t pllrly miry pulllhon thu C uo.t w hilvo 1110 ui1HU 41811111 Hulludl11od litr it C'o11lurcnpe wi111 .1 Illu C11Htmly C'olluillowl" II In 1111'thur noml 111111 11111101' OXItl'uHHed Hpl11u eullwul'I1H III Illy ConOllJill ion annlul'cltco ruhllivc to nlothur lokl18 010 Lhil(I In work with hur wlwn Hilo how uuHlotiy o1' 1110 minor OlIILI, Ifithur rusurvun 111011Ott, to rill so IImi IHHIIu In 1110 111tur0 In Ihu uvullt h0 llulur1111110H IN 111111tu1' 1100(IH to 110 11dthuHHUd by thu A' Ily'I'III'rC r? I r uuI liolly.I.willdcl' q11 I'htn tihollY 4 ,?5? ?('? r .I KOPNFY I), 81 1OI.I,Y, I'lilinllll' V TINA 811()ld-Y, Pol''undnnl IN TI II' COI I T (. F COMMON 11I,1'A5 n1. (11 M111'.I(I.ANI) COUNTY, pi'NNSYI.VANIA CIVII. ACTION - I,AW „ No, 98-38IH CIVII• IN CUSTODY C'ONCII,IA'I'I( CONFERENC , SUMMARY'jtIT0111 ' ITV ACCORDANCI' WI'I'I I CUMIII' l ANP COUN'T'Y CIVII, 10.11,1`1 OF POCTOU141, 1915,3•H(b), Ihu taldul'sIB11e11 Ctlmotly C'nllulIlillor silbI111IN the IoIIowlIIB 1'epol'11 I, The purtinunl Inlilrntalloa perlahllnB to II)e c:hlld whe 14 Ilio 41111luot of Ills Illlglitloll 18 114 lilllnlval Jordan la, Sholly, born January 5, 1993, 2, A C'clnulllolion C:otllbrunw \vos 1101c1 1111 5 011I0111IM' 10, 1998, with the Rdlowf»p II1(JIVId111114 In allundancol The lolher Rochlcy h, Sholly, wllll Ilk Co11114e1 Still), ,I, Windur, I'4glllru, and Ihu nlolhur I'Inll Sholly, who opliuared Wllhoul uoan4ul. 31 Thu porky have agreed upon an cntly ol'an Ordor as attached, PATV I lldwrt X, Cllroy, I'sga C'u4lody C'onclHalul. RODNEY D. SHOLLY, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY V. : CIVIL ACTION -LAW : No. 98-3818 CIVIL TERM TINA SHOLLY, Defendant. IN CUSTODY STIPULATION TO AMEND CUSTODY ORDER DATED SEPTEMBER 17,1998 AND NOW, this day of 1_4 2008, upon agreement of both parties, it is ordered and directed as fol ows: 1. The father, Rodney D. Sholly and the mother, Tina Sholly shall enjoy shared legal custody of their son, Jordan D. Sholly, born January 5, 1993. 2. The mother shall enjoy primary physical custody of the minor child. 3. The father shall enjoy temporary physical custody of the minor child as follows: A. During the summer months, beginning one week from the date the child is released from school until two weeks before the child is required to return to school. On this visitation, father shall make transportation arrangements at the beginning of his period of temporary custody and mother shall make transportation arrangements when she is to have custody returned to her at the end of the period of temporary custody. B. Father may, upon reasonable notice in advance, exercise periods of temporary custody as agreed upon by the parties during the school year. 4. The non-custodial parent shall enjoy reasonable telephone, internet, or any other agreed upon access to the minor child when the child is in the other parent's custody. Both parties shall inform the other party of a telephone number where they can be reached for purposes of emergency calls. Both parties agree to encourage and allow the minor child to have telephone conversations with the non-custodial parent on a regular basis at a minimum of once a week while the child is in their custody unless otherwise agreed to by both parties in advance. 5. The current child support Order in place with Franklin County, Pennsylvania shall be discontinued after the filing of this Modification. 6. Father and Mother have reached an agreement for payment by Father of $50.00 per week for the minor child. WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 7. Both parties agree that any further support matters will be presented in the state having jurisdiction over the child at the time the matter arises. 8. Father agrees to transfer custody of the minor child to Mother two weeks prior to the start of his school year beginning the summer of 2008. 9. Both parties agree that the foregoing changes to the Custody Order are in the best interest of the minor child. WHEREFORE, both Plaintiff and Defendant respectfully request the Court to grant the above listed modifications and grant primary residential custody to Mother with continued shared legal custody to both parties and granting Father specified temporary physical custody during summer vacations. Respectfully submitted, WEIGLE & ASSOCIATES, P.C. Date: By: ? . Jerry A. eigle, Esquire Attorney for Petitioners Attorney ID #01624 126 East King Street Shippensburg, PA 17257 717-532-7388 WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 I have read and understand the above, and I am signing it as a free and voluntary act. WITNESS my hand and seal this day of TL 2008. Rodney . Sholly STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND SS On this, the 1U,, day of , 2008, before me, a Notary Public in and for said County and State, a and signed officer, personally appeared Rodney D. Sholly, known to me (or satisfa torily oven) to be, the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto sez.lyy hand and off seals Rhonda R. WOltord, Notary pd* Shfppensburg Boro, Cumberland County _MY Commission Expires Jan 20, ,2009 WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 I have read and understand the above, and I am signing it as a free and voluntary act. WITNESS my hand and seal this day of 2008. a-- Tina Sholly STATE OF SOUTH CAROLINA SS COUNTY OF AV t On this, the day of ? , 2008, before me, a Notary Public in and for said County and State, the dersigned officer, personally appeared Tina Sholly, known to me (or satisfactorily proven) to be, the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. moo`' 0sE A. v, '.• .,........,• q ''c % , 99 :•My Pl/Or4/fy B M T ? ,• 34?Ol fs: 0, •••......?• gV TCouto WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 ? _ _ ? n r=`; ` ?! _ r-- ;' ' r= ?e-: F 7-. r - G7"s s-- '?+ -. , '- } f, C?:' -?' i I ? 9 2008 RODNEY P. SHOLLY, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY V. CIVIL ACTION -LAW No. 98-3818 CIVIL TERM TINA SHO LY, Defendant. : IN CUSTODY ORDER OF COURT 1)4? NOW, this day of , 2008, upon agreement of the AND parties, and pon motion of Jerry A. Wei , E ire Attorney for Plaintiff, it is hereby ORDERED as follows: 1. Legal c4tody of the minor child, Jordan D. Sholly, born January 5, 1993, shall be shared withi the meaning of 232 Pa. C.S.A. § 5301 et seq., as amended. 2. Primary hysical custody of the minor child, Jordan D. Sholly, shall be with Mother, Tina Sholly. 3. The fathe?, Rodney D. Sholly, shall enjoy temporary physical custody of the minor child, JordanD. Sholly, as follows: A. During the summer months, beginning one week from the date the child is releas d from school until two weeks before the child is required to return to schoo . On this visitation, father shall make transportation arrangements at the begi 'ng of his period of temporary physical custody and mother shall make trans rtation arrangements when she is to have custody returned to her at the end of the period of temporary physical custody. B. Father may, upon reasonable notice in advance, exercise periods of temp ary physical custody as agreed upon by the parties during the school year. 4. The non agreed upon Both parties reached for p minor child tl WEIGLE & ustodial parent shall enjoy reasonable telephone, internet, or any other ccess to the minor child when the child is in the other parent's custody. hall inform the other party of a telephone number where they can be rposes of emergency calls. Both parties agree to encourage and allow the have telephone conversations with the non-custodial parent on a regular P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 basis at a n jinimum of once a week while the child is in their custody unless otherwise agreed to b both parties in advance. 5. The current child support Order in place with Franklin County, Pennsylvania shall be discontin ed after the filing of this Modification. 6. Father and Mother have reached an agreement for payment by Father of $50.00 per week fo the minor child. 7. Both parties agree that any further support matters will be presented in the state having jurisdiction over the child at the time the matter arises. 8. Father agrees to transfer custody of the minor child to Mother two weeks prior to the start of s school year beginning the summer of 2008. By J. WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 ?Pos -L-?- *W"I'- Pt, -) 72 `:w S3?f(?o SS -01 WV U err ODOZ - Or r/k AdVii;`N6' _.Ovd -:l!I l dC