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ANNE P. ALGER
PLAINTIFF
V.
KIM S. ALGER
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
00-7690 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 3rd day of November, 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 ~ day of December ,2000, at ---.!;OO 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 also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
FOR THE COURT,
By: Isl
elissa P. Greev Es
Custody Conciliato
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 THIS PAPER TO YOUR ATIORNEY AT ONCE. IF YOU DO NOT
HA VB AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR 1ELEPHONE 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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Anne P. Alger,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. tV - 7(P lJoiw-J
Kim S. Alger,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, upon consideration of the attached Complaint, it is hereby directed
that the parties and their respective counsel appear before,
Esquire, the Conciliator, on the day of , 2000, at _ AlP.M., in
Pennsylvania, 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 shall 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 of Order:
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.
OFFICE OF THE COURT ADMINISTRATOR
CUMBERLAND COUNTY COURT HOUSE
FOURTH FLOOR
CARLISLE, PA 17013
(717) 240-6200
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Anne P. Alger,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. tJO- '7(..90 G..::J T~
CIVIL ACTION - LAW
IN CUSTODY
Kim S. Alger,
Defendant
COMPLAINT FOR CUSTODY
1. The Plaintiff is Anne P. Alger residing at 108 Laurel Drive, Enola, PA
17025
2. The Defendant is Kim S. Alger, residing at 810 Charlotte Way, #101,
Enola, PA 17025
3. Plaintiff seeks to confirm primary physical custody of the following
children:
children
Date of Birth
Madeliene
Leigh Anne
12/6/88
7/19/90
The children were not born out of wedlock and are in the custody of Plaintiff.
During the past five years, the children have resided with the following persons and at
the following addresses:
NAME
RESIDENCE
DATES
Anne P. Alger
108 Laurel Drive, Enola PA
1999 to present
Anne P. Alger
Kim S. Alger
The mother of the children is Plaintiff, Anne P. Alger and is single.
108 Laurel Drive, Enola PA
past 5 years to 1999
The father of the children is Kim S. Alger and is single.
4. The relationship of Plaintiff to the children is that of mother. Plaintiff
currently resides with her children named herein.
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5. The relationship of Defendant to the children is that of father. The
Defendant currently resides with the following persons: N/A.
6. 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.
7. The best interest and permanent welfare of the children will be served by
granting the relief requested.
8. Each parent whose parental rights to the children has not been
terminated and the person who has physical custody of the children has been named
as parties to this action. All other persons, named below, are known to have or claim a
right to custody or visitation of the childrenren will be given notice of the pendency of
this action and the right to intervene: N/A
WHEREFORE, Plaintiff requests the court to grant her custody of the minor
children.
Respectfully submitted,
~IJ;L
iller, Esquire
2010 M et Street
Ca ill,PA17011
17) 737-6400
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VERIFICATION
I verify that the statements made in the attached are
true and correct. I understand that false statements herein
are made subject to the penalties of 18 Pa. C.S. Section
4904 relating to unsworn falsification to authorities.
Date: IO/U/OD
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ArmeP. Alger,
Plaintiff
IN THE COURT OF COMMON PLEAS
Cumberland COUNTY, PENNSYL V ANlA
v.
NO. 00-7690
Kim S. Alger,
Defendant
CIVIL ACTION - LAW
IN Custody
AFFIDA VIT OF SERVICF. OF Custody COMPLAINT
I, James A. Miller, Esquire, hereby certifY that I served the Defendant, Kim S.
Alger, with a certified copy of the divorce complaint as evidenced by the attached United
States First Class Mail retum receipt card number P 016 244 733.
DATE: /1, h. - u.n-o
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~..SENDER: .
.~~ ~ Complete items 1 and/or 2 for additional services.
~ . Complete items 3, and 4a & b.
:;:::fl _ 0- Print your name and address on the reverse of this form so that we can
Q) return this card to you. _
~-. Attach this form to the front of the mailpiece, or on the back if space
'-";;'--=-does not permit.
'~_"'--Write "Return Receipt Requested" on the mailpiece below the article number.
.=-~~- . The Return Receipt will show to whom the article was delivered and the date
"-5 delivered.
~ -- 3. Article Addressed to:
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ij: Kim S. 14/9u-
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Consult ostmaster for fee.
Article Number
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ANN P. ALGER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-7690
vs.
KIM S. ALGER,
Defendant
CIVIL ACTION - LAW
CUSTODY
ORDER OF COURT
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AND NOW, this day of December, 2000, upon consideration of the
attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. Legal Custody: The parties, Ann P. Alger and Kim S. Alger, shall have shared legal
custody of the minor Children, Leigh Anne Alger, born July 19, 1990, and Madeliene Alger,
born December 6, 1988. 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 Pa. C. S. 9 5309, each parent shall be entitled to all records and
information pertaining to the Children including, but not limited to, medical, dental, religious or
school records, the residence address of the Children 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. Primary Physical Custody: Mother shall have primary physical custody subject to
Father's rights of partial physical custody.
3. Partial Physical Custody: Father's physical custody schedule shall be coordinated
with his days off work. Because Father's shift and work schedule may change, it is
contemplated that the parties may need to be prepared to modify this Order in the future.
Father will provide Mother with a copy of his work schedule and/or notices of changes in his
work schedule at his earliest opportunity so that the parties may work together toward a
mutually agreeable plan to ensure that Father has frequent and continuing contact with the
minor Children. To that end, Father's present work schedule for 2001 is included as an
attachment to this Order. The following schedule is a minimum amount of partial custody for
the Father. The parties shall cooperate with each other with regard to the occasional need to
modify the custodial plan with a view toward obtaining and following a harmonious policy in the
Children's best interest. Father's physical custody shall be arranged as follows:
A. On the eight weekends per year when Father is off work from Friday
through Monday, Father shall have physical custody from 5:00 p.m. Friday
until 9:00 p.m. Sunday. These weekends are on the attached schedule
identified as numbers 1 - 8.
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No. 00-7690
B. On weekends following Father's four days off work, Father shall have
physical custody from Saturday at 3:00 p.m. until Sunday at 9:00 p.m.
These weekends are identified on the attached schedule as A-H. Father
shall have additional periods of weekday custody each Tuesday from after
school until 9:00 p.m.
4. Vacations: Each party shall be entitled to up to two blocks of seven consecutive
days not to be used consecutively for vacation each summer. The parties shall provide each
other no less than a thirty-day notice of any upcoming vacation plans. Vacation time shall be
arranged on a first-come, first-served basis wherein the parent first providing written notice to
the other parent of their vacation plans shall have choice of that requested week. At the
vacationing parent's option, the seven-day vacation period may be combines with a custodial
weekend. Father shall notify Mother of the bid which he is making for vacation time at the time
of that occurrence.
5. Holidays:
A. Christmas 2000: Father shall have physical custody from December 23rd
at Noon until December 25th at 2:00 p.m.
B. Subsequent holidays: For the holidays of Christmas, Thanksgiving, Labor
Day, Memorial Day, Independence Day, Easter and New Year's Day,
Father's custodial periods shall be arranged as follows: if Father is
working the 6:00 a.m. to 2:00 p.m. shift, Father shall have custody from
after work until 9:00 p.m. If the Holiday follows on Father's day off, Father
shall have custody from 9:00 a.m. until 3:00 p.m., unless otherwise
agreed.
6. Communication: In the presence of the Children, neither parent shall make or
permit another person to make any remarks or do anything which could in any way be
construed as derogatory or uncomplimentary to the other parent. The parents shall
communicate directly with one another concerning any parenting issue requiring consultation
and agreement and regarding any proposed modification to the physical custody schedule,
which may from time to time become necessary, and shall specifically not use the Children as
a messenger. Neither parent shall discuss with the Children any proposed changes to the
physical custody schedule, or any other issues requiring consultation and agreement prior to
discussing the matter and reaching an agreement with the other parent.
7. Neither parent shall schedule activities which may interfere with the other parent's
custodial time without that parent's express prior approval.
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No. 00-7690
8. In the event that either parent would remove the Children from the Commonwealth
of Pennsylvania during any given custodial period, that parent shall notify the other parent of
where they shall be with the Children and provide a telephone number where they are able to
be reached.
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Dis!: Kim S. Alger, 810 Charlotte Way, #101, Enola, PA 17025
James A. Miller, Esquire, 2010 Market Street, Camp Hill, PA 17011
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ANN P. ALGER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-7690
vs.
KIM S. ALGER,
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
Madeliene Alger
Leigh Anne Alger
December 6, 1988
July 19, 1990
Mother
Mother
2. A Custody Conciliation Conference was held on December 5, 2000, with the
following individuals in attendance: the Mother, Ann P. Alger, and her counsel, James A.
Miller, Esquire; the Father, Kim S. Alger, pro se.
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3. The parties reached an agreement in the form of an Order as attached.
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Melissa Peel Greevy, Esquire
Custody Conciliator
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Date