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TIIERESA V, KANELOS
PLAINTIFF
V.
CHRIS JAMES SHIRK, SR.
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
00-6284 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 22nd day of September ,2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator,
at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 10th day of October ,2000, at 1:00 p.m.
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
ifthis cannot be accomplished, to defme 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.
FOR TIlE COURT,
By: Isl
Melissa P. Greev:y. Esq4/J
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites 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
attend the scheduled conference or hearing.
YOU SHOULD TAKE TIllS PAPER TO YOUR ATfORNEY AT ONCE, IF YOU DO NOT
HA VB AN ATfORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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THERESA V. KANELOS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLANDCOUNTY, PENNSYLVANIA
v.
: NO. 06 - 1DU>tf
Co;(<-r~
CHRIS JAMES SHIRK, SR.,
Defendant
: CIVIL ACTION - LAW
: CHILD CUSTODY
ORDER
AND NOW, this _ day of , 2000, in consideration
of the attached Complaint, it is hereby directed that the parties and their respective
counsel, shall appear before , the Conciliator, on the _ day
of , 2000, at _.m., at
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to
resolve the isstles 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 and older may also 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:
Date:
By:
Custody Conciliator
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, P A 17013
Telephone: (717) 249-3166
THERESA V, KANELOS,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.
CHRIS JAMES SHIRK, SR.,
Defendant
: CIVIL ACTION - LAW
: CHILD CUSTODY
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN sued in Court. If you wish to defend against the
claims set forth in the following pages, you must take prompt action. You are warned
that if you fail to do so, the case may proceed without you and a Decree in Divorce or
annulment may be entered against you by the Court. A judgment may also be entered
against you for any other claim or relief requested in these papers by the Plaintiff. You
may lose money or property or other rights important to you, including custody or
visitation of your children.
When the ground for divorce is indignities or irretrievable breakdown of
marriage, you may request marriage counseling. A list of marriage counselors is
available in the Office ofthe Prothonotary, Cumberland County Courthouse, One
Courthouse Square, 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 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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
Telephone: (717) 249-3166
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THERESA V. KANELOS,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLANDCOUNTY, PENNSYLVANIA
~ NO. &-0- t; 2f'f &~ --reU_
CHRIS JAMES SHIRK, SR.,
Defendant
CIVIL ACTION - LAW
CHILD CUSTODY
COMPLAINT FOR CHILD CUSTODY
AND NOW comes the Plaintiff, Theresa V. Kanelos, by and through her
attorney, Mark T. Silliker, Esquire, and respectfully requests this Honorable Court award
her custody of the subject minor child, and in support thereto, avers the following:
1. Plaintiff is Theresa V. Kanelos, an adult individual residing at 105 2nd
Street, West Fairview, Cumberland County, Pennsylvania, 17025..
2. Defendant is Chris James Shirk, Sr., an adult individual residing at P.O.
Box 71, Lewisberry, York County, Pennsylvania. 17339.
3. The subject child is Chris James Shirk, Jr., born March 14,2000.
4. The relationship ofthe Plaintiff to the subject minor child is that of
natural mother.
5. The relationship of the Defendant to the subject minor child is that
of natural father.
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6, The minor child has resided at the following addresses, in the custody
ofthe following individuals:
A. From birth to May 14, 2000, the subject minor child resided with
both parties at 2535 Penbrook Avenue, Harrisburg, P A 17104.
B. Since May 14, 2000, the subject minor child has resided with the
Plaintiff, natural mother, Theresa V. Kane10s, at 105 2nd Street,
Apartment 4, West Fairview, Cumberland County, PA 17025.
7. There have been no prior actions for custody of the subject minor child
in this or any other jurisdiction.
8. The Plaintiff is not aware of the existence of any other individuals who
have any type of claim whatsoever regarding the custody of the subject minor child.
9. The Plaintiff believes and therefore avers that she is much better able to
meet the needs of the subject minor child than the Defendant.
10. The Plaintiff believes and therefore avers that it is in the best interest
of the subject minor child that he be placed in her legal and physical custody.
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WHEREFORE, Plaintiff requests this Honorable Court award him/her
custody of the subject minor child.
Date:
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Respectfully submitted,
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Mark T. Silliker, Esquire
5922 Linglestown Road
Harrisburg, PA 17112
(717) 671-1500
I.D. No. 33671
Attorney for Plaintiff
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AFFID A VIT
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, hereby certify that the aforegoing is true
and correct to the best of my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C, S. 4909 relating to
unsworn falsifications to authorities,
Dated:
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THERESA V. KANELOS,
Plaintiff
vs,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-6284
CHRIS JAMES SHIRK, SR.,
Defendant
CIVIL ACTION - LAW
CUSTODY
INT 1M 0 DE
AND NOW, this 3 ( day of , 2000, upon consideration of
the attached Custody Conciliation Summary Report, it is hereby ordered and directed as
follows:
1, Legal Custody. The Mother, Theresa V. Kanelos, and the Father, Chris James
Shirk, Sr., shall have shared legal custody of the minor Child, Chris James Shirk, Jr., born
March 14, 2000, Each parent shall have an equal right, to be exercised jointly with the other
parent, to make all major non-emergency decisions affecting the Child's general well-being
including, but not limited to, all decisions regarding his health, education and religion,
Pursuant to the terms of this paragraph, each parent shall be entitled to all records and
information pertaining to the Child inCluding, but not limited to medical records and
information, To the extent one parent has possession of any such records or information, that
parent shall be required to share the same, or copies thereof, with the other parent within such
reasonable time as to make the records and information of reasonable use to the other parent.
2. PhYSical Custody. Mother shall have primary physical custody subject to Father's
rights of partial physical custody as follows: Each Sunday from Noon until 7:00 PM and each
Tuesday and each Thursday from 5:00 PM until 8:00 PM,
3. The parties shall attend the Seminar for Separating Parents.
4, The parties shall participate in a custody evaluation with at Guidance Associates,
Following the completion of the custody evaluation the parties shall return to the Custody
Conciliator who will have been provided a copy of the report by counsel. The next Custody
Conciliation Conference shall be scheduled on Wednesday, January 3, 2000, at 1 :00 PM.
BY THE COURT,
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Disl: Mark T. Silliker, Esquire, 5922 Linglestown Road, Harrisburg. PA 17112
James J, Kayer, Esquire, 4 E, Liberty Avenue, Carlisle, PA 17013
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THERESA V. KANELOS,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 00-6284
CHRIS JAMES SHIRK, SR.,
Defendant
CIVIL ACTION - LAW
CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915,3-8, the undersigned Custody Conciliator submits the following report:
1, The pertinent information concerning the Child who is the subject of this litigation is
as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Chris James Shirk, Jr.
March 14,2000
Mother
2. A Conciliation Conference was held on October 10, 2000, with the following
individuals in attendance: Theresa V. Kanelos, the Mother, and her counsel, Mark T. Silliker,
Esquire; Chris James Shirk, Sr., the Father, and his counsel, James J, Kayer, Esquire,
3. The parties reached an agreement in the form of an Order as attached.
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Me IS Peel Greevy, Esquire
Custody Conciliator
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THERESA V. KANELOS,
Plaintiff,
:IN THE COURT OF COMMON PLEAS
:OF CUMBERLAND COUNTY, PENNSYLVANIA
v.
No. 00-6284 CIVIL ACTION - LAW
CHRIS JAMES SHIRK,
Defendant.
IN CUSTODY
ORDER OF COURT
AND NOW, this 1st day of February, 2001, the Conciliator, being advised by counsel for
both parties that all custody issues have been resolved, hereby relinquishes jurisdiction in this
case. The Custody Conciliation Conference scheduled for February 5, 2001 is canceled.
FOR THE
LilciA (w8
Melissa Peel Greevy, Esquire (
Custody Conciliator
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CHRIS J, SIDRK, SR,
PLAINTIFF
V.
THERESA V ASSO KANELOS
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
00-6284 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Friday, March 30, 2001 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator,
at 214 Senate Avenne, Snite 105, Camp HiD, PA 17011 on Monday, April 30, 2001 at 11:00 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 defme 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,
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: Isl
Melissa P. Greevy. EsqU
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilitcs 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
attend the scheduled conference or hearing,
YOU SHOULD TAKE THIS P MER TO YOUR ATTORNEY AT ONCE, IF YOU DO NOT
HA VB AN ATTORNEY 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, Pennsylvania 17013
Telephone (717) 249-3166
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CHRIS J. SHIRK, SR.,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 2000 - 6284 CIVIL TERM
: CIVIL ACTION - LAW
THERESA V ASSO KANELOS,
Defendant
: IN CUSTODY
ORDER OF COURT
AND NOW, this
day of
, 2000, upon
consideration of the attached Petition, it is hereby directed that the parties and their respective
counsel appear before
Esquire, Custody Conciliator, at
on
of
2000, at
o'clock _.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
defme 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 ofa temporary or permanent order.
FOR THE COURT,
By:
, Esquire
Custody Conciliator
cc: James J. Kayer, Esquire
Attorney for Plaintiff
Mark Silliker, Esq.
Attorney for Defendant
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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, Pennsylvania 17013
Telephone (717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
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 attend the scheduled conference or hearing.
James J. Kayer, Esquire
Attorney for Plaintiff
4 East Liberty Avenue
Liberty Loft
Carlisle, P A 17013
(717) 243-7922
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CHRIS J. SHIRK, SR.,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2000 - 6284 CIVIL TERM
: CIVIL ACTION - LAW
THERESA V ASSO KANELOS,
Defendant
: IN CUSTODY
MOTION TO REAPPOINT CONCILIATOR
COMES NOW, Chris J. Shirk, Sr., by his attorney, James J. Kayer, Esq., who does
hereby aver as follows:
1. The Petitioner is Chris J. Shirk, Sr., Plaintiff in the above captioned action.
2. The Respondent is Theresa Vasso Kanelos, Defendant in the above captioned action.
The parties are the natural parents of Chris J. Shirk, Jr, 105 2nd Street, Apt. #4, Enola,
Pennsylvania, born, March 14, 2000.
3. The Plaintiff filed a Complaint for Child Custody on September 14, 2000. A
conciliation conference was scheduled and held before Melissa P. Greevy, Esq., for October 10,
2000.
4. The parties were to complete a custody evaluation with Guidance Associates and
return to a Custody Conciliation Conference on January 3, 200.
5. By mutual agreement of the parties and counsel, that conference was continued
generally pending the Guidance Associate Evaluation.
6. As the parties are now prepared to attend the Guidance Associate custody evaluation,
it is necessary to address custody once again.
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WHEREFORE, the Petitioner requests this Honorable Court to reappoint Melissa P.
Greevy as conciliator and to direct the conciliator to schedule a conciliation conference as soon
as practicable.
Respectfully submitted,
Date:
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VERIFICATION OF PLEADINGS
The foregoing document is based upon information which has been gathered by my counsel
and myself in the preparation of this action, The language of the document may, in part, be the
language of IllY cotU1sel and not my own. I have read the statements made in this document and to
the extent that it is based upon information which I have given to IllY counsel, it is true and correct
to the best of my knowledge, information and belief. To the extent that the contents of the
statements are that of counsel, I have relied upon counsel in making this Verification. I understand
that false statements herein are made subject to the penalties of 18 PA. C.S. S 4904, relating to
unsworn falsification to authorities.
Date: / ~ ~egf.!7
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CERTIFICATE OF SERVICE
I hereby certifY that a true copy of the foregoing PETITION TO MODIFY CUSTODY
was served on the following persons by First-class mail, postage prepaid, by forwarding a true
and correct copy unto:
Mark T. SilIiker, Esq.
5922 Linglestown Road
Harrisburg P A 17112
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AfAY 0 8 2001 ~
CHRIS J. SHIRK, SR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 00-6284
vs.
THERESA VASSO KANELOS,
Defendant
CIVIL ACTION - LAW
CUSTODY
ORDER OF COURT
",.
AND NOW, this I , day of May, 2001, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. Le9al Custody. The parties, Chris J, Shirk, Sr., and Theresa Vasso Kanelos, shall
have shared legal custody of the minor Child, Chris J. Shirk, Jr., born March 14, 2000. Each
parent shall have an equal right, to be exercised jointly with the other parent, to make all major
non-emergency decisions affecting the Child's general well-being including, but not limited to,
all decisions regarding his health, education and religion. Pursuant to the terms of Pa. C. S, ~
5309, each parent shall be entitled to all records and information pertaining to the Child
including, but not limited to, medical, dental, religious or school records, the residence address
of the Child and of the other parent. To the extent one parent has possession of any such
records or information, that parent shall be required to share the same, or copies thereof, with
the other parent within such reasonable time as to make the records and information of
reasonable use to the other parent.
2, Physical Custody. The parties shall have shared physical custody of the minor
Child arranged as the parties may agree. However, in the event that the parties cannot agree,
at minimum Father shall have custody from Sunday at Noon until Monday at 5:30 p.m, and
Tuesdays and Thursdays from 8:30 a.m. until between 8:00 p,m. and 8:30 p.m.
3. The parties have determined that since they have reached an agreement that no
custody evaluation shall be necessary.
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Dis!:
James J, Kayer, Esquire, 4 E, Liberty Avenue, Liberty Loft, Carlisle, PA 17013)' ,
MarK T, SilliKer, Esquire, 5922 Linglestown Road, Harrisburg, PA 17112 . ~
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CHRIS J. SHIRK, SR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 00-6284
vs.
THERESA VASSO KANELOS,
Defendant
CIVIL ACTION - LAW
CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915,3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is
as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Chris J, Shirk, Jr.
March 14, 2000
Mother
2. A Custody Conciliation Conference was held on April 30, 2001, with the following
individuals in attendance: Chris J. Shirk, Sr., and his counsel, James J. Kayer, Esquire; the
Mother, Theresa Vasso Kanelos, and her counsel, Mark T. Silliker, Esquire.
3. The parties reached an agreement in the form of an Order as attached.
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Date
Me Issa Peel Greevy, Esquire
Custody Conciliator