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Home My WebLink About00-06553 ~'i_'.o,.t~" .' CHRISTINE A. PEPPERMAN PLAINTIFF V. DAVID B. PEPPERMAN DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-6553 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 29 day ofEPTEMBE ,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 Avenne, Snite 105, Camp Hill, PA 17011 on the 24TH day of OCTOBER ,2000, at 9:15 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. Fai]ure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR TI!E COURT, By: Isl Melissa P. Greevy. Esq.tIJ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabi]ites Act of ]990. 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 PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTI! BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Te]ephone (717) 249-3166 - "- ~ .-. cr ,. ,,',' ". ",. j-, Jr-'''''; 1- \lv ,..'r ' i \ j ~ n,\,. r\t, \ ...!.. ~J \" . ," (, IJ\j' '1'1 ,.",._~" .',>,~,\J U \'{i l "'I,,\,"cnV," ,,'''I' ,;VI> PENNS'{lv/\"'"'' /Od-CO M. ~ ~ zj 4 ~ /0-0( 1Q? 71~ pu~ ~~. 1,f)<>2~ ~ /t<t.~ ~..~ ~ I I I II 11 Ii..... ! " i't'"'lV'"",.~~~~"",,,"' J~iilii!:~!i:f11f,.~~;J~'"i'"I1:'JMi'tl!!~t!l~_ ,_~_"...l!!fI.fIHll.m!J~_rn . -, ",<0''',;' "'''" . ',,-, '" _"_'-';_C ",""-d,'_ ~"-;~-''',,;-:;'' ~'-''''"';,'; .,"" ill .. . . (Y) SEP 2 8 zoorfl? CHRISTINE A. PEPPERMAN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 2000- &553 CIVIL TERM CIVIL ACTION - LAW DAVID B. PEPPERMAN, IN CUSTODV~- Defendant ORDER OF COURT You, DAVID A. PEPPERMAN, Defendant, have been sued in court to obtain custody, partial custody or visitation of the minor children: DAVID P. PEPPERMAN and MICHAEL P. PEPPERMAN. You are ordered to appear in person at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania on ,2000, at .M., for o a conciliation or mediation conference. o a pretrial conference. o a hearing before the court. If you fail to appear as provided by this Order, an Order for custody, partial custody or visitation may be entered against you or the Court may issue a warrant for your arrest. 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. FOR THE COURT, By: J. ~~- > <"-,.., li-": l,,;c'\ O:'~'~""_' , ,- '"'"'I' M'" '-'J"~~;:"::~;-;;6'.~,.j.j~;;"--o'~';i,, ,-.,,~.., -1.1l.iL-"'--"":;: ... Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson LD. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania l7043~01 09 (717)761-4540 Attorneys for PlaiIitiff CHRISTINE A. PEPPERMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLANb COUNTY. PENNSYLVANIA NO. 2000- I t5.5-3 CIVIL TERM CltlL ACTION - LAW , IN CUSTODY v. DAVID B. PEPPERMAN, Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is Christine A. Pepperman, hereinafter referred t~ as "MOTHER," who resides at 720 Allenview Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is David B. Pepperman, hereinafter referred tb as "FATHER," who resides at 25 North 17th Street, Camp Hill, Cumberland County, Pennsylvania. 3. MOTHER 'seeks custody of the following children: DAVID P. PEPPERMAN, age seven, whose date of birth is February 21, 1993; and MICHAEL P. PEPPERMAN, age five, whose date of birth is I January 13, 1995. 4. The children were not born out of wedlock. 5. The children are presently in the custody of MOTHER at 720 Allenview Drive, Mechanicsburg, Cumberland County, Pennsylvania. _ " ., _ '_.'. .,C_, " _ __ I ' , .,_,j~",,,,, ' H - - -, '- '---'0" ~." " ,---",,;.-;;".-, , "_".>--,_.y",'C,j,C_"''.. - "'jil! ','C,,).:, ..4 6. Since birth, the children have resided with the following persons at the following addresses: A. From birth until approximately April 1996 - with MOTHER and FATHER on South 15th Street in Camp Hill, Pennsylvania. B. From approximately April 1996 until February 1998 - with MOTHER and FATHER on High Street in Camp Hill, Pennsylvania. C. From approximately February 1998 until present - with MOTHER at 720 Allenview Drive, Mechanicsburg. Cumberland County, Pennsylvania. 7. The mother of the children is Plaintiff, Christine A. Pepperman. She is single. 8. The father of the children is Defendant, David B. Pepperman. He is married. 9. The relationship of Plaintiff to the children is that of natural mother. Plaintiff currently resides with the following persons: the two minor children. 10. The relationship of Defendant to the children is that natural father. The Defendant currently resides with the following persons: Cathy Pepperman - wife; Marissa, 10 years old - Cathy Pepperman's young daughter; Cecilia, 11 years old - Cathy Pepperman's young daughter. 11. MOTHER has not participated as a party or witness, or in any other capacity, in any other litigation concerning the custody of these children in this or another court. 12. MOTHER has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 13. MOTHER 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. ~~-=, -~. -~ '- - L '" ,_ , ,,-,,,,,-,,,-,_-,~,-,o '--- """""--'- ..;,',;~..-,.o -' "'~I'Ih1~'; ." 14. The best interest and permanent welfare of the children will be served by granting the relief requested because: A. MOTHER has been the children's primary caretaker since birth; B. The children have resided on a primary basis with MOTHER since the parties separated in approximately February 1998; C. FATHER's contact with the children has been sporadic at best and has never been more than on an alternating weekend basis; D. The children have developed a trusting and loving relationship with MOTHER. 15. 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, MOTHER requests that the Court confirm primary custody of the children in her, subject to FATHER's periods of liberal partial custody to be exercised on an alternating weekend basis. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER BY:~W~ Keirsten W. Davidson : 138626 ~.~.- ,~ ,.,cr._ "" " ,_ -. -, , , .[,.', ,-- ,-~. -';-', "_0'_ - ,--'._ , 'd-' h- '__,:_",:r!~",:__,..~',;L_- __ __~~" """";"":~ .; VERIFICA TlON I, Christine A. Pepperman, verify that the statements made in the foregoing Complaint for Custody are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. f!jJwo?'~a J7~~ Christine A. Pepperm Dated: September 25, 2000 ~ .-, 1lIiliii<i~lF"k--< """~aw'- ~/IllIi~.J-lr ~ -~ ,-';" ~ - -,' -J I <----",-" . ,.-~ 'as ,,- \ ~ ~ ~~ () c::J ~ C c:., (') '\. ~~~ -o~; "On (/) nl~ r<l ~_.,~ ~ ~ ~~ -U 1"',,) I", \ ~. \ .... \::) " ~ ~cj ~-:} ~ , )> ." , ~ -7(.--" :2: 6f~ ~ ~C'I )>c r;-:> ~ :::> o-i (Tl ~ :'; i'=~"""""<""""~~ I J...J "--k.'__._ '-, "- -" ."",-, "-.r. VS. OCT 2 6 ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-6553 .At It CHRISTINE A. PEPPERMAN, Plaintiff DAVID B. PEPPERMAN, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this:11 day of -~ooo, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Christine A. Pepperman and David B. Pepperman, shall have shared legal custody of the minor Children, David P. Pepperman, born February 21, 1993, and Michael P. Pepperman, born January 13,1995. 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. 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 Mother shall have primary physical custody subject to Father's rights of partial physical custody which shall be arranged as follows: A. To commence October 27,2000, Father shall have the children on alternating weekends from Friday after school until Monday morning when he shall deliver them to school or to the summer daycare provider. """,,,~-=' ,'~" ~ - '._0.' ~". " - - -, r!i;i .. r- NO. 00-6553 B. To commence November 1, 2000, on alternating Wednesday evenings from after school until Thursday mornings. C. To commence November 8,2000, on alternating Wednesdays from 4:00 p.m. until 8:00 p.m. This shall be the Wednesday evening schedule during the school year. During the summer, Father shall have custody Wednesday nights overnight until Thursday each week. 3. Holidays. The parties shall share the holidays equally as the parties shall mutually agree. 4. During the period of time wherein Mother has training with the National Guard and weekend obligations for the National Guard, Father shall have first right of refusal for custodial time when mother is unavailable. At her earliest opportunity, Mother shall provide notice to the Father as to what her schedule shall be for National Guard training. 5. Summer Vacation. Father and Mother shall each have two non-consecutive weeks of summer vacation. The parties shall endeavor to provide each other with at least a 30-day notice of the vacation weeks chosen. In the event that both parties have chosen the same week, the party first providing notice shall be entitled to choose that week. The vacation weeks for the parties are not to include the week before school begins each year. 6. The parties shall allow reasonable phone contact between the Children and the non-custodial parent during any period of custody. 7. The parties shall return to the Custody Conciliator for an additional Conference on Wednesday, January 17, 2000, at 11 :00 a.m. ;:JjIilJ-. l-W ~ O"~ " ,i ,--. _~_ ,:n ". __" '. --'" ... r NO. 00-6553 J. Dis!: Keirsten W. Davidson, Esquire, PO Box 109, Lemoyne, PA 17043-0109 Austin F. Grogan, Esquire, 24 N. 32nd Street, Camp Hill, PA 17011 . 0 (\-I'\~ \,0 LPY 0':; ,) Q, \ ~~ ~ , . .. .,.~ - (k "'!, <%> <:6 a /-0'\ \.-j 0:., 7.')' '~'fQo .....5f.. .;> "<<:;;.., ''ZA ~/ ;'" l (..... ,0."''<' '/,1/( . ""'->/~, .A' '0 '/h, ;:$, 'Y/jf ~,L) 'i(l] It, ~, ?} ~~PQ '(" vl21f~ . ,,_~ ,U "_,~ _^. _ " _, .,~~~llllJl],li"!'ii'C''''''~i!~~I'tl_'nlfimfl~~ - - - ~ "-~~ , . -. ~ , -"',- - '.1 -..ri .",. . CHRISTINE A. PEPPERMAN, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-6553 DAVID B. PEPPERMAN, 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 Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF David P. Pepperman Michael P. Pepperman February 21, 1993 January 13, 1995 Mother Mother 2. A Conciliation Conference was held on October 24, 2000, with the following individuals in attendance: the Mother, Christine A. Pepperman, and her counsel, Keirsten W. Davidson, Esquire; the Father, David B. Pepperman, and his counsel, Austin F. Grogan, Esquire. 3. The parties reached an agreement in the form of an Order as attached. IO/atJUJ7f--p w~~ e Issa ee reevy, sqUire Custody Conciliator Date 1 I ,~" --"~"U ~~ ',,-,;- MAR 0 5 20010f CHRISTINE A. PEPPERMAN, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-6553 DAVID B. PEPPERMAN, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this 22nd day of February, 2001, the Conciliator, having received a request from counsel for the Plaintiff for an indefinite Continuance on January 16, 2001, and having received no subsequent request to schedule an additional Custody Conciliation Conference, hereby relinquishes jurisdiction. FOR THE COURT, UlfU/YJ ~ Melissa Peel Greevy, Esquire Custody Conciliator ,'~-~~, <~mll ;.. l.jjibt&Jtl!il!~Il'~~" -. M~__,'t~,,"illfu.ki1!,1h:iil~JJ'QJiftit.b.: ".,-',:" ,~]mJ!'lJ ._" _ ,-"" _-"., ",_"oc_ .,,'~_ ," ," "'f'".'- _ ,o_~, ^'"'" ~'-> -'-,--" .'. .-,.',.- '"'.-" -".~~<,~~~" y- ,~ ~, (') ~ L1\J-~ 92~{, ~i~~ -------. ~.- ~:_:C:; ~~E-'~ .v-,~ -..!, C~j ,. " ,<, C"'J -~ '" S:? :51 01 Z;',