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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
STEFANNIE S. SHOVER, TIMOTHY
SPERRY and JOYCE SPERRY,
Plaintiffs
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IN CUSTODY
CIVIL ACTION - LAW
vs.
NO. 98-4505 CIVIL TERM
RANDY A. SHOVER,
Defendant
AFFIDAVIT OF SERVICE BY CERTIFIED MAIL
AMY M, ROSELLI, being duly sworn according to law, deposes and says as
follows:
1. That she is an employee of Samuel L, Andes, attorney for the Plaintiff
herein.
2, That on 25 August 1998 , she delivered to the U.s. Postal Service in
Lemoyne, Pennsylvania, as certified mail (Receipt No. Z 075 084 298) return receipt
requested, addressed to the Defendant herein, a true and correct copy of the
Petition for Custody and the Order scheduling a conciliation conference filed in the
above-captioned action duly endorsed with a Notice to Defend and Claim Rights.
3. Said return receipt card is attached hereto as Exhibit A showing a date of
delivery to the Defendant of 28 August 1998.
flmfflm . ~fJMj k
AMY ,ROSELLI
Sworn to and subscribed
I before me this 2 'J ff, day
'I of :S''f'-b,~k , 1998.
'I L,,<-y~ auw~{ ~ ~ pU;l
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llComJ:11Mllttema 3, 411, and 4b.
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102595-97,0,0179 Domestic Return Receipt
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INTHECOURTOFCOMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
STEFANNIE S. SHOVER, TIMOTHY
SPERRY AND JOYCE SPERRY,
Plaintiffs
RANDY A, SHOVER,
Defendant
NO. 1/ r. " ~-,-, j'"
IN CUSTODY
CIVIL TERM
QRQER OLe.OURT
AND NOW, this ...JD- day of I\.Xj0:::'~, 1998, upon consideration of the
Complaint filed in this matter, it is hereby directed that the parties and thp.ir respective :
counsel appear before \~ N-r\'i.G~(D1t8t" the conciliator, at. ~ 4"'A.'.\.J('{ ~kl~rMi
~,c",,,<,~r\Cf\6 CD. CtLc\lno.:)~, Pennsylvania, on ~,the ;:)~ day i
of XC('}.,... , 19!:Rl, at \U o'c1ockQ.rn. 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 a temporary order. All children aged 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.
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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249.3166
FOR THE COURT,
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STEFANNIE S, SHOVER, TIMOTHY
SPERRY AND JOYCE SPERRY,
Plaintiffs
vs.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
RANDY A. SHOVER,
Defendant
NO, r; l' - 'I \-~, \'-
IN CUSTODY
CIVIL TERM
C_OMPLAINT IN CUSTOJ1Y
AND NOW comes Stefannie S. Shover, by her attorney, Samuel L. Andes, and
makes the following Complaint for custody based upon the following:
1. The Plaintiffs are Stefannie S. Shover, Timothy Sperry, and Joyce Sperry, all
adult individuals who resides at 25 Warwick Circle in Mechanicsburg, Cumberland
County, Pennsylvania.
2. The Defendant is Randy A. Shover, who resides at 54A Garden Parkway in
Carlisle, Cumberland County, Pennsylvania.
3. The Plaintiff, Stefannie S. Shover and the Defendant are the parents of three
minor children, Amanda L, Shover, age 7, born 1 March 1991, Hailey A. Shover, age 7,
born 1 March 1991, and Emily A. Shover, age 3, born 5 April 1995.
4. Plaintiff seeks custody of the three minor children, Amanda L. Shover, age 7,
born 1 March 1991, Hailey A. Shover, age 7, born 1 March 1991, and Emily A. Shover,
age 3, born 5 April 1995.
5. The children were not born out of wedlock and are presently in the custody of
the Plaintiff.
6. During the past five years, the minor children have resided with the following
persons at the following addresses:
1993. January of 1998
With both the Mother
and Father
Various Addresses
In Carlisle
(Except for one month in 1994 when the parents were separated and all three
children resided with the Mother and the other two Plaintiffs in Mechanicsburg.)
~
January 1998 ' April 1998 Wilh the Father
8 Garden Parkway
Carlisle, PA
April 1998 . mid June 1998 Emily and Hailey have
Resided with the Plaintiffs
25 Warwick Circle
Mechanicsburg, PA
8 Garden Parkway
Carlisle, PA
Amanda has resided with
The Defendant
Mid June 1998 to present
All three children resided
With Plainli11
25 Warwick Circle
Mechanicsburg, PA
7. Timothy Sperry and Joyce Sperry are the parents of the Plaintiff, Stefannie S,
Shover and are the maternal grandparents of the subject children.
8. The Plaintiffs live at that address with the children Amanda, Hailey, and Emily.
9. The Defendant resides with his sister, Kelly Shover.
10, The Plaintiff has not participated as a party or in any other way in any litigation
concerning the custody of the children in this or any other court.
The Plaintiff has no information of a custody proceeding concerning the children
pending in a court of this or any other jurisdiction.
Plaintiff knows of no other person not a party to this action already who has
physical custody of or claims to have custody or visitation rights with the said children.
11. The Plaintiffs believes that the best interests of the children will be served by
awarding primary physical custody of all three of the children to Plaintiffs for the following
reasons:
A. The Defendant does not have adequate living quarters for the
children; and
B. Amanda has health problerm which are aggravated by the constant
smoking of the Defendant; and
C. The Defendant neglects the children by failing to treat their medical
conditions. by failing to keep them clean and presentable for school, and by
generally failing to provide adequately for their needs; and
D. The Plaintiffs are providing a good and suitable home for the
children and can provide a much better home for them than can the
Defendant; and
E. The Plaintiff, Stefannie S. Shover has been the primary care
provider of the children for almost all of their lives.
12. Each parent whose parental rights to the children have not been terminated
and the person who has physical custody of the children have been named as parties to
this action.
WHEREFORE. Stefannie S. Shover, Timothy Sperry and Joyce Sperry, request this
Court to grant them custody of the children, Amanda, Hailey, and Emily.
By ah>~t.,
Samu ' L. Andes
Attorney for Plaintiff
Supreme Court ID# 17225
525 North 12th Street
Lemoyne, PA 17043
(717) 761.5361
. ,..."t< .':'1:':';';~,
COMMONWEALTH OF PENNSYLVANIA )
( 55..
COUNTY OF CUMBERLAND )
Joyce Sperry, being duly sworn according to law, deposes and says that the facts
set forth in the foregoing Complaint for Custody i1rc true and correct to the best of her
knowledge, information, and belief.
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Joyc ;' fJ~rry-'
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Sworn to and subscribed
befo~l\me this .")4) day
of '\jlJ....Q.tj .. . 1998.
nU)'tl \\...n).\..QpN Q O~
Notary Pliblic.
N01'ARIA!..8&.L
NlfIJ, RtmUJ, NoByPl:l*
~.Ilom, Ol.'T.blII1andClllllltt. PA
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STEFANNIE S. SIIOVI':R, TIMOTlIY
SPERR Y AND JOYCE SI'ERR y,
Plailltill's
IN TilE COI JR r OF COMMON I'/.EAS OF
('tiMBERLAND COUNTY, I'ENNSYI. VANIA
\'
CIVIl. ACTION. LA W
RANDY A, SIIOVER,
f)clellualll
NO. 9H.4505 CIVIL
IN CUSTODY
Prior Judgc:
CONCILIATION CONFEIU:NCF: SUMMARY REI'ORT
IN ACCORDANCE WITII TilE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915,3-8(b), thc undersigncu Custody Conciliator submits thc following rcpon:
1. The pertincnt inlomlation pcnaining to the children who arc thc subject of this litigation is
as follows:
Amanda L. Shover, bom March I, 1991; Hailey A. Shovcr. born March I, 1991; and Emily
A. Shover, bom April 5. 1995.
2. A Conciliation Contercnce was hcld on October 22, 199H, with the following individuals in
attendanec:
Thc Mothcr Stefannie S. Shovcr and the matcmal grandmothcr Joycc Sperry along with
their counsel Samucl Andes, Esquirc; thc Father did not appear. Attomey Andcs indicated
that the Father was servcd with notice of the eonfcrence. Funhermore. the Mothcr indicated
that she has had discussions with thc Father and he acknowlcdgcd that he was aware of the
date of the eonfcrenee but that he was not planning to attcnd because of his work schedule.
3. The 3 minor ehildren have been in the custody of the Mother and the maternal grandparents
for the past 4-5 months. Father is secing the children pursuant to an existing flexible
arrangcment betwcen the Mothcr and Father. Thc Conciliator recommends an Order in the
form as attaehcd.
~.?J./ qf?
DA E
C1&h
Hubert X. Gilroy, ESql . e
Custody Conciliator
II
vs.
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
STEFANNIE S. SHOVER, TIMOTHY
SPERRY AND JOYCE SPERRY,
Plaintiffs
CIVIL ACTION. LAW
RANDY A. SHOVER,
Defendant
./
NO. qy- 'f ,0 S
IN CUSTODY
CIVIL TERM
COMPLAINT IN CUSTODY
AND NOW comes Stefannie S. Shover, by her attorney, Samuel L. Andes, and
makes the following Complaint for custody based upon the following:
1. The Plaintiffs are Stefannie S. Shover, Timothy Sperry, and Joyce Sperry, all
adult individuals who resides at 25 Warwick Circle in Mechanicsburg, Cumberland
County, Pennsylvania.
2. The Defendant is Randy A. Shover, who resides at 54A Garden Parkway in
Carlisle, Cumberland County, Pennsylvania.
3. The Plaintiff, Stefannie S. Shover and the Defendant are the parents of three
minor children, Amanda L. Shover, age 7, born 1 March 1991, Hailey A. Shover, age 7,
born 1 March 1991. and Emily A. Shover, age 3, born 5 April 1995.
4. Plaintiff seeks custody of the three minor children, Amanda L. Shover, age 7,
born 1 March 1991, Hailey A. Shover, age 7, born 1 March 1991, and Emily A. Shover,
age 3, born 5 April 1995.
5, The children were not born out of wedlock and are presently in the custody of
the Plaintiff,
6. During the past five years, the minor children have resided with the following
persons at the following addresses:
1993 . January of 1998
With both the Mother
and Father
Various Addresses
In Carlisle
(Except for one month in 1994 when the parents were separated and all three
children resided with the Mother and the other two Plaintiffs in Mechanicsburg.)
II
January 1998 - April 1998 With the Father
8 Garden Parkway
Carlisle, PA
April 1998 - mid June 1998 Emily and Hailey have
Resided with the Plaintiffs
25 Warwick Circle
Mechanicsburg, PA
Amanda has resided with
The Defendant
8 Garden Parkway
Carlisle, PA
Mid June 1998 to present
All three children resided
With Plaintiff
25 Warwick Circle
Mechanicsburg, PA
7. Timothy Sperry and Joyce Sperry are the parents of the Plaintiff, Stefannie S,
Shover and are the maternal grandparents of the subject children.
8. The Plaintiffs live at that address with the children Amanda, Hailey, and Emily.
9. The Defendant resides with his sister, Kelly Shover.
10, The Plaintiff has not participated as a party or in any other way in any litigation
concerning the custody of the children in this or any other court.
The Plaintiff has no information of a custody proceeding concerning the children
pending in a court of this or any other jurisdiction.
Plaintiff knows of no other person not a party to this action already who has
physical custody of or claims to have custody or visitation rights with the said children.
11. The Plaintiffs believes that the best interests of the children will be served by
awarding primary physical custody of all three of the children to Plaintiffs for the following
reasons:
A, The Defendant does not have adequate living quarters for the
children; and
II
8, Amanda has health problems which are aggravated by the constant
smoking of the Defendant; and
C. The Defendant neglects the children by failing to treat their medical
conditions, by failing to keep them clean and presentable for school, and by
generally failing to provide adequately for their needs; and
0, The Plaintiffs are providing a good and suitable home for the
children and can provide a much better home for them than can the
Defendant; and
E. The Plaintiff, Stefannie S. Shover has been the primary care
provider of the children for almost all of their lives.
12, Each parent whose parental rights to the children have not been terminated
and the person who has physical custody of the children have been named as parties to
this action,
WHEREFORE, Stefannie S, Shover, Timothy Sperry and Joyce Sperry, request this
Court to grant them custody of the children, Amanda, Hailey, and Emily.
By ~~t.,
Samu L. Andes
Attorney for Plai ntiff
Supreme Court 10# 17225
525 North 12th Street
Lemoyne, PA 17043
(717) 761.5361
11
COMMONWEALTH OF PENNSYLVANIA )
( 55..
COUNTY OF CUMBERLAND )
Joyce Sperry, being duly sworn according to law, deposes and says that the facts
set forth in the foregoing Complaint for Custody ilre true and correct to the best of her
knowledge, information, and belief.
~yCe/
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Sworn to and subscribed
befo~~r:ne thiS. ,:Y-Yl day
oi '-dL,,-Q~ _ ' 1998,
QUll~ \.()~I\j~&tI~Q U "-
Notary Pic.
NOfAA/llL 8M.
,.,,, ~ I~ NolIIIyNilc
1cI..~8onI. ClliIolhIrolldCaullly, PA
My Clo,b","-lIoI\ ~ Hm. 20, ?OO"
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II
COMMONWEALTH OF PENNSYLVANIA )
( 55.
COUNTY OF CUMBERLAND )
Stefannie S, Shover, being duly sworn accurding to law, deposes and says that the
facts set forth in the foregoing Complaint for Cuscody are true and correct to the best of
her knowledge, information, and belief.
s~~s~i;;;
Sworn to and subscribed
beforr.r:r.e \!lis eJ;+i day
of '-jL.UGl~ .' ' 1998.
Ctn ll~ \._(', )~1Q&~ Q LA
Notary blic.
NOTNIW. 8lW.
MIV" ~. WlIlIIyNllc
~ lIcnl, cu......'" CluIly, PA
~,_ My ~"'" "',""'," 1Ic'N. 20.100'1
II
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vs.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
STEFANNIE S, SHOVER, TIMOTHY
SPERRY AND JOYCE SPERRY,
Plai ntiffs
RANDY A. SHOVER,
Defendant
NO,9P-'I5""Os'"
I N CUSTODY
CIVIL TERM
ORDER OF COURT
AND NOW, this \C~ day of ~ )5v.:.~, 1998, upon consideration of the
comPlaintfile.d in this matter, it is hereb~directed that the parties ar:! their resp~ctive 1
cou~sel appear bef~re l}h-r-\-'X.r.)\\fO-j~' the conciliator, at. ~ I..j 11.,,}J('i ~\IIot"rct;
~\....'l"\\;Rr\C[)d Lo.. lQ;Cm~c ' Pennsylvania, on Fncl>-j ,the Q$ day
of Sc~},... , 19!:18, at 10 o'clocka..rn. 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 a temporary order, All children aged 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.
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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249.3166
FOR THE COURT,
BY
CUSTODY CONCILIATOR
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
STEFANNIE S. SHOVER, TIMOTHY
SPERRY and JOYCE SPERRY,
Plaintiffs
CIVIL ACTION - LAW
NO. 98-4505 CIVIL TERM
RANDY A. SHOVER,
Defendant
IN CUSTODY
AFFIDAVIT OF SERVICE BY CERTIFIED MAIL
AMY M. ROSELLI, being duly sworn according to law, deposes and says as
follows:
1. That she is an employee of Samuel L. Andes, attorney for the Plaintiff
herein.
2. That on 25 August 1998 , she delivered to the U.s. Postal Service in
Lemoyne, Pennsylvania, as certified mail (Receipt No. Z 075 084 298) return receipt
requested, addressed to the Defendant herein, a true and correct copy of the
Petition for Custody and the Order scheduling a conciliation conference filed in the
above-captioned action duly endorsed with a Notice to Defend and Claim Rights.
3. Said return receipt card is attached hereto as Exhibit A showing a date of ~l.---
delivery to the Defendant of 28 August 1998.
flmf( lm . v?1ML1 ~
AMY . ROSELLI
Sworn to and subscribed
before me this 2 <) 11., day
'I of 5'..,,*-~ , 1998.
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Notafy Public. L'iMll Et'li!!'~~7oU;~Q \
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'tI -Complete items 1 andfor 2 for additionaIlMH'Vicu.
.. -Complete items 3, 48, and 4b.
., -Print your name and address on the reverH ofthle form 80 that we can return this
E card to you.
>" -Attach this fonn to the front of the mailplece, or on the back jf space does not
permit.
~ -Write-Return R8CSipt ReqlJtlBted" on the malIpiece be60w the article number.
t= -The Return Receipt will show to whom the article was d8llvered ancIthe date
delivered.
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I also wish to receive the
following services (for an
extra fee):
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2. 0 Restricted Delivery
Consu~ posbnaster for fee.
48. Artide Number
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Express Mail 0 Insured f
o Return Receipt for Merchandise 0 COD l5
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4b. Service Type
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102595-97-8-0179 Domestic Return Receipt
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OCT 2 3 1998 tP
STEFANNIE S, SHOVER, TIMOTHY
SPERRY AND JOYCE SPERRY,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LAW
RANDY A, SHOVER,
Defendant
NO, 98-4505 CIVIL
IN CUSTODY
COURT ORDER
""-
AND NOW, this -, day of October, 1998, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
I, The Mother, Stefannie S, Shover shall enjoy legal and physical custody of Amanda
1. Shover, born March I, 1991, Hailey A. Shover, born March I, 1991, and Emily
A. Shover, born April 5, 1995,
2, The Father Randy 1. Shover shall enjoy periods of temporary physical custody with
the 3 minor children at such times and under such circumstances as agreed upon by
the parties.
3, In the event the Father becomes dissatisfied with the temporary custody arrangement
and desires a more specified schedule or otherwise wants to modify this Order, the
Father may petition the court to have the case again scheduled with the Custody
Conciliator for a Conference. It is noted that the Father was not in attendance at the
Custody Conciliation Conference and, in the event of any future conference or Court
hearing, the Father can at that time raise whatever issues he feels may be appropriate
for consideration by the Court.
J,
cc: Sam Andes, Esquire _ C~ ,-Y"1AJ;u{ I cJ::; 8/9 k .
Randy A. Shover . ~ ,.J ii'.
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STEF ANNIE S, SHOVER, TIMOTHY
SPERRY AND JOYCE SPERRY,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LAW
RANDY A. SHOVER,
Defendant
NO, 98-4505 CIVIL
IN CUSTODY
Prior Judge;
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:
I. The pertinent information pertaining to the children who are the subject of this litigation is
as follows:
Amanda 1. Shover, born March 1,1991; Hailey A. Shover, born March I, 1991; and Emily
A. Shover, born April 5, 1995.
2, A Conciliation Conference was held on October 22, 1998, with the following individuals in
attendance:
The Mother Stefannie S. Shover and the maternal grandmother Joyce Sperry along with
their counsel Samuel Andes, Esquire; the Father did not appear, Attorney Andes indicated
that the Father was served with notice of the conference. Furthermore, the Mother indicated
that she has had discussions with the Father and he acknowledged that he was aware of the
date of the conference but that he was not planning to attend because of his work schedule.
3, The 3 minor children have been in the custody of the Mother and the maternal grandparents
for the past 4-5 months. Father is seeing the children pursuant to an existing flexible
arrangement between the Mother and Father. The Conciliator recommends an Order in the
form as attached,
10(:1;)/ q9
DATE
Cf&:;/(o
Hubert X. Gilroy, Esq
Custody Conciliator