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Home My WebLink About00-07785 ~, ~ . . . . .. , . . . . , . . . .. . .' . , . .. , . . . . . . . , ., . . . .. . . . . . . . . . . . . . . . . . . . . . . . . .. . . . .. " . . , ,~" ~'''''~, , . .. ~~ ~ ~~~~~~~ ~ ~~~ ~ ~~~~~~~~ ,.,,.,:t;;t;:f.:"':!i;f.;l;'" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Christopher R. Sheaffer, Plaintiff NO. No. 00 - 7785 Civil Term VERSUS April D. Sheaffer, Defendant DECREE IN DIVORCE AND NOW, ~;; ,: ~1 A."" . d{)O~ ':IS ORDERED AND DECREED THAT Christopher R. Sheaffer April D. Sheaffer AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. " ...-.....-~ ~;~I.'\. .,.., - "Co' ""'i. .;::-.... \ /.....;;;;,. . . -, --;-. ~ = ~ ~ ~ - , J..,'- V ~-- -:.' ,~;.. ;,- " ~ > ~ .. , ~J Ams~ . . ..-, '.. ~ .,7....1~. ~~:::~,,~- /'1' ,- -,- . 1"";,,,------,'-("\ '<I-i!~I;r~.:..~;. "(... . .. "':l' :t' "";!' "'Of. Of"":f .. 'j," ." '. '['" 'I f,' . . . .. .. . . PROTHONOTARY . . . .. ~ ~ ~~~~~~~~~~~~~ ;+;:+;:+;:+::f;+, . . . . . . . . . . . . . . . .. . .. . . . . . . . . . . . .. . .. .. . . . . . . . , . , . , , . . .. . . . .. . .. . .. .. . . . . . . . . . . .. . . . . . . . . . . J. ........". ~.ro!;1JIliIliIiiIiliiIJ~~~~l~.' I....'."'~ ....... "",-",I ." '=~M~'iIWlliIIIIiIiI ~ .-9 "c_ f( I, I....... 1; , -~~.." \.. , l, ~ ~, \ ., ii' " I, I I' ~. ii- , t(/~ '&9" M- ~~~ 4' $~ ~'J~ -[;Jf( /1~'~ ~~. I r ! I I - . CHRISTOPHER R. SHEAFFER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 00 - 7785 Civil Term APRIL D. SHEAFFER, Defendant : ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under &3301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered bv certified mail. restricted delivery. return receipt requested. delivered on: November 7, 2000. 3. Date of execution ofthe affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: March 29,2001. By Defendant: March 28, 2001. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in g3301(c) Divorce was filed with the Prothonotary: :) - d ~ -0 I Date Plaintiffs Waiver of Notice in g3301(c) Divorce was filed with the Prothonotary: ~~a'1-o \ n." '6/21 P 'I ~. , ,~. ~". '" ~, . , '-i';':': 't" ~, ,';"'C;,:'-j';~ltf~'l~""Uijf'-'" -;,";-;"~"',,',-'" .,"~-, ~/'I',--' i , i I 1 I I I I I , I j j l I i ',1 ~ ,j I , I I I , I I I ~"",'~ ,_d ,.~.'" ,-,-.' '>'. ' ~'" - ~- #L-' f'\) 0'1 "'> C'.:::.;;t "'~ ..... C:< '-q 5,;:'? :.::;j n'i:n r- ::BEi &;cf~ ~~nl ~',"~ ::~: X'''0 ~~"~W~.jl$!!~I'I<'I"fI~~~~~~.""" r."II!I~~~" vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; No. :lOCO-?f8~ CHRiSTOPHER R. SHEAFFER, Plaintiff APRiL D. SHEAFFER, Defendant : ACTION IN DIVORCE 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 of 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. Where the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RiGHT TO CLAIM THEM. YOU SHOULD TAKE THlS 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 vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; No. iHJ - 17 J:j Ci.;;J}~ CHRISTOPHER R. SHEAFFER, Plaintiff APRIL D. SHEAFFER, Defendant : ACTION IN DIVORCE COMPLAINT IN DIVORCE AND NOW COMES, Christopher R. Sheaffer, by and through his attorney, Jane Adams, Esquire and respectfully represents: COUNT I - DIVORCE 1. Plaintiff is Christopher R. Sheaffer, an adult individual, who has resided at 62 Betty Nelson Trailer Court, Lot 161, Carlisle, Cumberland County, Pa., 17013, since June 1999. 2. Defendant is April D. Sheaffer, an adult individual, who has resided at 62 Betty Nelson Trailer Court, Lot 161, Carlisle, Cumberland County, Pa. 17013, since June 1999. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on October 16, 1992 in Bartlesville, Oklahoma. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have two children together, namely, Christopher R. Sheaffer, dob 5113/98, and Sarah J. Sheaffer, dob 3/24/91. 8. Plaintiff and Defendant are both citizens ofthe United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces ofthe United States of any of its allies. ''o/J'l~_.~ 10. The Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken; and/or (b) The Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render his condition intolerable and life burdensome. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. COUNT n - CUSTODY 1. Plaintiff (hereinafter referred to as "Father") is Christopher R. Sheaffer, who currently resides at 62 Betty Nelson Trailer Court, Lot 161, Cumberland County, Carlisle, Pa. 17013. 2. Defendant (hereinafter referred to as "Mother") is April D. Sheaffer, who currently resides at 62 Betty Nelson Trailer Court, Lot 161, Cumberland County, Carlisle, Pa. 17013. 3. Plaintiff seeks primary physical custody of the following children: NAME ADDRESS AGE Christopher R. Sheaffer 62 Betty Nelson Trailer Court Lot 161 Carlisle, Pa. 17013. 2, dob 5/13/98. Sarah J. Sheaffer 62 Betty Nelson Trailer Court Lot 161 Carlisle, Pa. 17013 9, dob 3/24/91. Sarah J. Sheaffer was born out of wedlock, however, Mother and Father married on October 16, 1992. Christopher R. Sheaffer was not born out of wedlock. The children are in the custody of: both Mother and Father; however, Father seeks primary physical custody. ~'l" _,,_ -~ I~ 0 , ~ .. During the past five years, the children have resided with the following persons and at the following addresses: NAME ADDRESSES DATES April and Christopher Sheaffer 1657 S. Hickory St. 1995-ApriI1999. Bart1esville, Ok. April and Christopher Sheaffer Lee and Cindy Farner (paternal grandparents) 347 W. North St. Aprill999-June 1999 Carlisle, Pa. 17013 April and Christopher Sheaffer 62 Betty Nelson Trailer Ct. June 1999 - present. Lot 161 Carlisle, Pa. 17013 The mother of the children is: April Sheaffer, currently residing at: 62 Betty Nelson Trailer Court, Lot 161, Carlisle, Pa. 17013. She is married, however a divorce is pending (see Count 1.) The father of the children is: Christopher Sheaffer, currently residing at: 62 Betty Nelson Trailer Court, Lot 161, Carlisle, Pa. 17013. He is married, however a divorce is pending (see Count 1.) 4. The relationship of plaintiff to the children is that of Father. The plaintiff currently resides with Mother. 5. The relationship of defendant to the children is that of Mother. The persons that the defend~t currently resides with are: Father. 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. ~'m ,f"~~ ". , ~ Plaintiff does not know of 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 because: Father plans to move into his parents house. which is a seven room filflll house on Middlesex Road in Carlisle. The best interests of the children would be served by this move because the children would benefit from the loving attention of their paternal erandparentsand the large and pleasant countly environment of the home. The home is also close to Mother's employment and would provide Mother with a convenient location for visitation. Father is in the best position to provide suitable housing and a better home environment for the children. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests the court to grant custody of the children. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: ':/1.,;< , 00 Respectfully submitted, ~~ J.D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ""~~~-- ~, Complete Items 1, 2, and 3. Also cOmplete item 4 jf Restricted Delivery is' desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece. or on the front if space permits. 1. Article Addressed to: ~,o,~ ~~~~~ I (Cor c~ / /)/7013 D. Is deli ry address different from 1 If YES, enter delivery address belOW: 3. Servic..!.liPe l3"'Certified Mail 0 Express Mail cr Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.Q,D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article N'i'mb\9'r (qOPY,',tfOf11 serviq; la~ J (1 t! i t be' ,f ,ffl,'J i i,!",! , ! ,..;.z......~' '/ J' :::;'''' '[ :;; r> co...... PS Form 3811 , July 1999 Domestic Return Receipt ~,..,..., ~,1 ' "~,-I ", 102595-99-M-1789 CHRISTOPHER R. SHEAFFER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 00 - 7785 Civil Term APRIL D. SHEAFFER, Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF THE ORDER SETTING CUSTODY CONFERENCE. AND NOW, this November 28, 2000, I, Jane Adams, Esquire, hereby certify that on or about November 22, 2000, a true and correct copy of the ORDER SETTTING A CUSTODY CONFERENCE for December 12, 2000 was served, via certified mail, restricted delivery, return receipt requested, addressed to: April D. Sheaffer 62 Betty Nelson Trailer Court #161 Carlisle, Pa. 17013 DEFENDANT Respectfully Submitted: ~ l. . e Adams, Esquire J.D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ""'~~f ,~, I'" I"" I" ~ .._,-,. ,~_._-----.._._,-,--,-----_.._----.! CHRISTOPHER R. SHEAFFER PLAINTIFF V. APRIL D, SHEAFFER DEFENDANT IN TItE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-7785 CMLACTIONLAW IN CUSTODY ORDER O'f COIJRT AND NOW, this 9th 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 HUl, PA 17011 on the 12th 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: Is! Melissa P. Gref!V.JI_ Es~ Custody Conciliator (f 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 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. " - ....._~--'-_.,-'- --roo . ,I Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 T~UE COpy FROM RECORD In Testimony whereof, I here u~'" sot n' h d d h .".,J ..; 1\/ ,an an f e s~al of suld Court al Car!',,'", Pa,' TI,is 13" ", day of/](J:f)." 024::0 ~a~ k' .,:;,- r~ . ~ W- . .....'P';o~hnn~t~:~;. , _'''. ;~~~~~I::~~C::~~~~:IO' ~ 7, ~.. ~ 11 ~ I I lj 'j ,i II ij " [I' L :~ :1 :j f~ u ','ie' ~ .- :,1',1' ;1 i:, " , :,','1' ,;1. 'i; ;1 - . C) c.... C C::J ~~: ~ " IJ' C,:J f'l r-.-' / i:';.' [f) N _/ co r::c; ,,' --- ~~: :): ""',:~ , -1 ':'1:1 -< fv -<: ~5'l \ f;/~ " r,~~~";i,.'~.^~w,'-lB;"'S.~'I-'~';R;;;!,~YlIliq!!iIm".f>'1:l-1t~"1':l"!\~'j~fflflll,"i@fl~!llm~~ CHRISTOPHER R. SHEAFFER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 00 - 7785 Civil Term APRIL D. SHEAFFER, Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF THE NOTICE TO DEFEND AND COMPLAINT AND NOW, this November 14, 2000, I, Jane Adams, Esquire, hereby certify that on November 7, 2000, a true and correct copy of the NOTICE TO DEFEND and COMPLAINT were served, via certified mail, restricted delivery, return receipt requested, addressed to: April D. Sheaffer 62 Betty Nelson Trailer Court #161 Carlisle, Pa. 17013 DEFENDANT Respectfully Submitted: ~ ane Adams, Esquire LD. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF q~, " ._f " ~ ,I , I , Is delivery address different from i 'If YES, enter delivery address below: I ~service'TY o Express Mall stared 0 Return Receipt for Merchandise . 0, Insured Mail 0 C.O.D. stricted Dellvery? (Extra Fee) PS Form 3811, July 1999 i i~ i b1 ~ i ~0t L/ ; i!3,i&-tyi Oomestib Return Receipt '~~J ~--- "!'11i c,,.,,, 1 02595.00-M.0952' '; I CHRISTOPHER R. SHEAFFER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. QQ,- 7785 Ciyil Term APRIL D. SHEAFFER, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on November 2,2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S, 4904, relating to unsworn falsification to authorities. Date: j' -..< 9 - 0 I WAIVER OF NOTICE OF INTENTION TO R~QUESr ENTRY OF A DIVORCE DECREE UNDER U3011cl OF THE DIVORCE CODE 1, I consent to entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of properly, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. Datej_2 ~'C>/ 'r;"" .""V". . lial~_"",llI:;kilill1ll<iili1lil::':;f~"!i&iML=fj<('<L~.iir;btW~,'M,~,",-)-.""~,~.,,',t',,~,;<ii';;'<',"ll!.Ii<iM'~"",')'b,,~~~~~-lili~llllfl'Il:!i---"" o C :t''; -C)ft>:, OJ6: ~~;;. CI5~.. ~f.~' ~~ zQ j;i=i z =<! -" ~, - ^, ~, ."", .",-~" '"~, ""~",",,~,,,,~.'. ,.". w (~, r, a ,e..... U -i) ..,~ ~, -;:"'" :-u ,:=0 Cl " -'-:CI'I :;;'1-1 'i~~ g~~ '" 5:"1 -< :2 ,-,~- ',""''''''-''''" ~"'--" '" CHRISTOPHER R. SHEAFFER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 00 - 7785 Civil Term APRIL D. SHEAFFER, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on November 2, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsifICation to authorities. Date: 3 - Ol,:~ ~ 0 \ Qrn!~ WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVQRCE DECREE UNDER 633011cl OF THE DIVORCE CODE 1. I consent to entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, laWyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. !l4904 relating to unsworn falsification to authorities. Date: ~ ~ d..'b - 0 \ 'f i\,~:"~ , I. II ,I I I' I II I: II II I I II Ii I I I' I II 'j II II Ii 1,1 I, I:!: I,' ~~ ,~ .",,'~' ,'-'- ." ",' .",~, '".~ - ..', ""'"~ -~'. ~""~'. '."."~ ~'~~"""'~"''"''>~y','"'' ","'",,"'W;,'" ,~, ,'.- ", 1""-"---" ", .~" o S; -~ ~H~' ze. (); ~~' / " ~c~ }::;c-; ~Cl Y(:: :2: :::2. -c~:: 4:l ; 1'-0 -~~) ~2 ",. (,:J ~ __ -L J:..~~,~",".,~mll!l!!i?"~*"5!'~~!!'!!!W'~1'"""~lIi'''''=~~'"""",, ,__.if,.~;:;r.~WF,"f!"''''-'''-'!,1;~:1f<rn'fl'-1''1''''nf~''lJ!W!r$l!f~~!!ffi']'ij!l~I'll'lf!~ '~,l Ill' CHRISTOPHERR. SHEAFFER PLAINTIFF v. APRIL D, SHEAFFER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-7785 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 9tb 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 12tbdayof 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 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 HAVE AN ATIORNEY 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 ''f'i'\''i!o/!!J'~ -, I ~i8l1lll'tJIDl!""~",,-"<;;;""iill~,~"_~';!~~~J,,";"''''''''--''''''''''';;r.\--'",-1~r.bj,",,,':''"'-'~''~,illIll-1~ :1J'[ 1 """I"""'.-"~-~~~ ~ '~~"""&""''''---- '!' :' <.", ~-:' : !C:'<ClfARY 1'0 lln" I ", CH ,. '0 WI rhJ\i ':;1 nl t. U "UMQ""" ' ", "O"UNTY V II 1l,...crtW";J\JU ~-" PENNSYLVANiA ///J.t:JeJ &vi ~~ ~ 42f@~ 11-13,6t1 'J1~ ~ zi;~- /(.J3.CJ?J ~j1/I~ z:;aZf ~ - . NOV 3 200~ IJ\ VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. gOqj - 77f5'" CHRISTOPHER R. SHEAFFER, Plaintiff APRIL D. SHEAFFER, Defendant ACTION IN DiVORCE ORDER OF COURT AND NOW, this day of , 2000, upon consideration of the attached complaint, it is hereby direCted that the parties and their respective counsel appear before , Esquire, the conciliator, at , Pennsylvania, on , the day 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 define and narrow the issues to be heard by the court, and te enter into a temporary order. Either party may bring the child who is the subject ofthis custody action to the conference, but the child's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or pennanent order. FOR THE COURT, By Custody Conciliator . YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER 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 ADMINIST A TOR CUMBERLAND COUNTY COURTHOUSE, 4TH FLOOR CARLISLE, P A. 17013 (717) 240-6200 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 infonnation about accessible facilities and reasonable accomodations 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. '"~, ~ ~ ',--'''^ ,-- "," ,..I~ .-~ 1 ~~ JANE ADAMS ATTORNEY AT LAW I I 7 SOUTH HANOVER STREET CARCISCE. PA. I 70 I 3 (7 I 7l 245-8508 (717l 245-8538 FAX VIA CERTIFIED MAIL, RESTRICTED DELIVERY November 3, 2000 April D. Sheaffer 62 Betty Nelson Trailer Court #161 Carlisle, Pa. 17013 Re: Sheaffer v. Sheaffer No. 2000 - 7785 Clivil Term (Cumberland County) Dear April: Enclosed please find a Complaint' in Divorce which has been filed with the Cumberland County Prothonotary under section 3301 of the Divorce Code. Under this section of the Divorce Code, a final Divorce Decree may be requested in ninety (90) days after filing Affidavits of Consent. Please contact me if there are any questions regarding the above. Thank you for your kind attention to this matter. Very truly yours, (COpy Jane Adams, Esquire /JA Z 013 344 382 cc: Christopher Sheaffer US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mail (See reverse) Senllo Street & Number , Post Office, Slate, & r Code Postage I $ Certified Fee Spedal Delivery Fee Restricted Oelive'Y Fee '" '" I, ~~, mr ~6 b .. ,~~ ~~~ ...."!'1"'r~ - ',' liJ.1'" ,~W~','l!. \ lln~ , " '~'"' "_~""""'''' ,d',,_ ".,~,_,,,-,~.,.,o,'~_ o ?P '"1:Jf{ ~fIj U)"t- -<.,'-:" ~8 .J.--"C ~ -< ill r Ii o C> o '-'1 :?:: ::::> "c -v --_"li"': , ' "~)" . -~':::j :-l;;;:::b :,;,;:-,r'., ,~:sn; ~:~ :='0 -< .-J "" _ ',,....,~~'''!''' '!i':~"'JW,"'if';l;U'~"'"j~,"',,^~~""" "'c!"~"p '.;:"f'rT.~~~~;i'j!!~r-~!I\!Il1JlJ!lq~l' ~~" _ ,,-,~J",~ ~ ~ '" vs. \ DEe 14 20~'" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-7785 CHRISTOPHER R. SHEAFFER, Plaintiff Defendant CIVIL ACTION - LAW CUSTODY APRIL D. SHEAFFER, ORDER OF COURT AND NOW, this I ~ ~ 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, Christopher R. Sheaffer and April D. Sheaffer, shall have shared legal custody of the minor Children, Christopher R. Sheaffer, born May 13, 1998, and Sarah J. Sheaffer, born March 24, 1991. 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. ~ 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 copiel1 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 a shared physical custody arrangement which shall be arranged around the parties' work schedules. Additionally, Mother shall have one seven-day period of vacation each summer. If a conflict should arise with regard to the custodial schedule, the schedule shall be arranged in a week-on week-off schedule which will be deemed to have commenced on December 18, 2000, with Father having custody for that week. 3. Relocation: Neither party shall relocate beyond a fifty-mile radius from their present residences in Cumberland County, absent proper petition to the Court and a sixty-day notice provided to the other parent. J. la-p-;'D -fY(~ }:2.-J5-OO RK5 ,''%' Disl: Jane Adams, Esquire, 117 S. Hanover Street, Carlisle, PA 17013 Karl E. Rominger, Esquire, 155 S. Hanover Street, Carlisle, PA 17013 l'-' ?, '"', ," ~ I -'''''""''''''-};":;'d""n",d,,,,,*,,;1,,=,,,,.ir.Mi!liI.-..l"'''''---" ..~...'; ~. -~ "" *11.II_iilIj*(~~~_ i' ,__ " ... ..t!:liJJ.....l1m ~"',=, "c 'o~ "'w",' '" ~,' " . "~ '.o;;,~~'~'~1IW ~i!IJ!illI!lillil~ ' oc. ~ " '~'1IlII 'j " .~. FitED-OfFICE OF' -, ,... .... '",'cur'l' I"T' RY !t";:: L;""\~'!l ,\.,J.\".lfl\, 00 DEe 1 5 M1ID: f 0 CUMBEiiLANO COUNTY PENNSYLVANIA "Il!'$ ,. b ) .. CHRISTOPHER R. SHEAFFER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-7785 Defendant CIVIL ACTION - LAW CUSTODY APRIL D. SHEAFFER, 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 Christopher R. Sheaffer Sarah J. Sheaffer May 13,1998 March 24, 1991 Mother and Father Mother and Father 2. A Custody Conciliation Conference wa~ held on December 12, 2000, with the following individuals in attendance: the Father, C~ristopher R. Sheaffer, and his counsel, Jane Adams, Esquire; the Mother, April D. Sheaffer, and her counsel, Karl E. Rominger, Esquire. 3. The parties reached an agreement in the form of an Order as attached. /;) -/3 - l..b-P-v U!~ Melissa Peel Greevy, Esquire" Custody Conciliator Date ,,~ ~' ,~ ~ ,'," "I;, , CHRISTOPHER R. SHEAFFER : PLA/NTIFF : V. APRIL D. SHEAFFER : DEFENDANT : IN THE COURT OF COMMON PLEAs OF CUMBERLAND COUNTY, PENNSYLVANIA 00-7785 CIVIL ACTION LAW IN CUSTODY ~URT AND NOW, this 9th --_ day of Novembe_r_r, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear befureMelissa p. Greev , Ey~Eq~, the conciliator, at_ 21._~4 Senat_._._._e Avenue, Sm're 105, Cam Hill, PA 17011 on the 12thday of December ,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 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 prov/de grounds for entry of a temporary or permanent order. FOR THECOURT, By: /s/ Melj~sa 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 TI-IlS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ItELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~ '£1 CHRISTOPHER R. SHEAFFER, Plaintiff vs. APRIL D. SHEAFFER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COIINTY, PENNSYLVANIA : : No. : ACTION IN DIVORCE : AND NOW, this day of ,2000, upon consideration of the attached complaint, it is hereby directed that the par~ie,,; and their respoctive counsel appear before , Esquire, the conciliator, at · Pennsylvania, on , the day 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 define and narrow the issues to be heard by the court, and to enter into a temporary order. Either party may bring the child who is the subject ofthls custody action to the conference, but the child's attendance is not mandatory. Failure to appear at the conference may provide grounds for ertlD, ora temporary or permanent order. ,, FOR THE COURT, 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 HE[,P. OFFICE OF THE COURT ADMINISTATOR CUMBERLAND COUNTY COURTHOUSE, 4TH FLOOR CARLISLE, PA. 17013 ~. (717) 240-6200 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 accomodatinns 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. CHRISTOPHER R. SHEAFFER, Plaintiff VS. APRIL D. SHEAFFER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. : ACTION IN DIVORCE : 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 of 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. Where the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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, Pa. 17013 (717) 249~3166 CHRISTOPHER R. SHEAFFER, Plaintiff VS. APRIL D. SHEAFFER, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. ACTION IN DIVORCE COMPLAINT IN DIVORCE AND NOW COMES, Christopher R. Sheaffer, by and through his attorney, Jane Adams, Esquire and respectfully represents: COUNTI-DIVORCE I. Plaintiffis Christopher R. Sheaffer, an adult individual, who has resided at 62 Betty Nelson Trailer Court, Lot 161, Carlisle, Cumberland County, P'a., 17013, since June 1999. 2. Defendant is April D. Sheaffer, an adult individual, who has resided at 62 Betty Nelson Trailer Court, Lot 161, Carlisle, Cumberland County, Pa. 17013, since June 1999. 3. Plaintiffand Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiffand the Defendant were married on October 16, 1992 in Bartlesville, Oklahoma. 5. There have been no prior actions of divorce or for armulment between the parties. 6. Plaintiff has been advised that counseling is available., and that plaintiff may have the right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have two children together, namely, Christopher R. Sheaffer, dob 5/13/98, and Sarah J. Sheaffer, dob 3/24/91. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiffavers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken; m~d/or (b) The Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render his condition intolerable and life burdensome. WHEREFORE, Plaintiffrequests the court to enter a decree in divorce. COUNT II - CUSTODY 1. Plaintiff (hereinafter referred to as "Father") is Christopher R. Sheaffer, who currently resides at 62 Betty Nelson Trailer Court, Lot 161, Cumberland County, Carlisle, Pa. 17013. 2. Defendant (hereinafter referred to as "Mother") is April D. Sheaffer, who currently resides at 62 Betty Nelson Trailer Court, Lot 161, Cumberland County, Carlisle, Pa. 17013. 3. Plaintiff seeks primary physical custody of the following children: Christopher R. Sheaffer Sarah J. Sheaffer 62 Betty Nelson Trailer Court Lot 161 Carlisle, Pa. 17013. 62 Betty Nelson Trailer Court Lot 161 Carlisle, Pa. 17013 2, dob 5/13/98. 9, dob 3/24/91. The children are in the custody off both Mother and Father; however, Father seeks primary physical custody. Sarah J. Sheaffer was bom out of wedlock, however, Mother and Father married on October 16, 1992. Christopher R. Sheaffer was not bom out of wedlock. During the past five years, the children have resided with the following persons and at the following addresses: NAME ~ DATES April and Christopher Sheaffer 1657 S. Hickory St. Bartlesville, Ok. 1995-April 1999. April and Christopher Sheaffer Lee and Cindy Famer (paternal grandparents) 347 W. North St. Carlisle, Pa. 17013 April 1999~June 1999 April and Christopher Sheaffer 62 Betty Nelson Trailer Ct. Lot 161 Carlisle, Pa. 17013 June 1999 - present. The mother of the children is: April Sheaffer, currently' residing at: 62 Betty Nelson Trailer Court, Lot 161, Carlisle, Pa. 17013. She is married, however a divorce is pending (see Count I.) The father of the children is: Christopher Sheaffer, ctnrently residing at: 62 Betty Nelson Trailer Court, Lot 161, Carlisle, Pa. 17013. He is manSed, however a divorce is pending (see Count I.) 4. The relationship ofplalntiffto the children is that ot' Father. The plaintiff currently resides with Mother. 5. The relationship of defendant to the children is that of Mother. The persons that the defenda~nt currently resides with are: Father. 6. Plaintiffhas 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 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 because: Father plans to move into his parenlls house, which is a seven room farm house on Middlesex Road in Carlisle. The best interests of the children would be served by this move because the children would benefit from the loving attention of their Paternal grandparents and the large and oleasant country_ environment of the home. The home is also close to Mother's employment and would provide Mother with a convenient location for visitation. Father is in the best position to provide suitable housin? and a better home environment for the children. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as pm'ties to this action. WHEREFORE, Plaintiff requests the court to grant custody of the children. I verify that the statements made in this Complaint are, true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Respectfiffiy submitted, ms, Esquire t'/I.D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245;-8508 ATTORNEY FOR PLAINTIFF CHRISTOPHER R. SHEAFFER, Plaintiff VS. APRIL D. SHEAFFER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 00-7785 Civil Term : : ACTION IN DIVORCE ~FIDA¥IT O~ SE~.R__VIC~Y.~OI~, T_H_~ DEFEr!tO CO ,fP_L_At T AND NOW, this November 14, 2000, I, lane Adams, [',squire, hereby certify that on November 7, 2000, a truc and correct copy of thc NOTICE TO DEFEND and COMPLAINT were served, via certified mail, restricted delivery, return receipt requested, addressed to: April D. Sheaffer 62 Betty Nelson Trailer Court #161 Carlisle, Pa. 17013 DEFENDANT Respectfully Submitted: ~squire I.D. No. 79465; 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF JANE ADAMS ATTORNEY AT LAW I I 7 SOUTH HANOVER STREET CARLISLE:, Pa,. 170 I 3 (7 I 7) ~45-8508 (7 I 7) E45-8538 r~x VIA CERTIFIED MAIL, RESTRICTED DELIVERY November 3, 2000 April D. Sheaffer 62 Betty Nelson Trailer Court #161 Carlisle, Pa. 17013 Re: Sheaffer v. Sheaffer No. 2000 - 7785 Oivil Term (Cumberland County) Dear April: Enclosed please find a Complaint'in Divorce which has been filed with the Cumberland County Prothonotary under section 3301 of the Divorce Code. Under this section of the Divorce Code, a final Divorce Decree may be requested in ninety (90) days al~er filing Affidavits of Consent. Please contact me if there are any questions regarding the above. Thank you for your kind attention to this mattet:i /JA cc: Christopher Sheaffer Very truly yours, COPY Jane Adams, Esquire Z 013 344 282 US Posta~ Service Receipt for Certified Mail No Insurance Coverage Providsd. Do not use for International Ma (See reverse] -Sent lo Res~cted De~ive~ Fee item 4 if Restricted D ry · · print your name and address on the reverse so that we can return the card to you. , · Attach this card to the back of the mallplece, or on the front if space permits. 1, Article Addressed to; Date of Delivery I address yES, entre delivery address below: ~i Agent lyes [3 No [~ Express Mai[ [~3 Registered [~ Return Receipt for Merchandise Restricted Delivery? (Extra Fee) Domestic Return Receipt · Sender: Please print your name, address, and ZIP+4 in this box · CHRISTOPHER R. SHEAFFER, Plaintiff VS. APRIL D. SHEAFFER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 00-7785 Civil Term : : ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF THE ORDER SETTING CUSTODY CONFERENCE. AND NOW, this November 28, 2000, I, Jane Adams, Esquire, hereby certify that on or about November 22, 2000, a true and correct copy of the ORDER SETTTING A CUSTODY CONFERENCE for December 12, 2000 was served,, via certified mail, restricted delivery, return receipt requested, addressed to: April D. Sheaffer 62 Betty Nelson Trailer Court #161 Carlisle, Pa. 17013 DEFENDANT Respectfiflly Submitted: .]6ne Adams., Esquire ID. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF CHRISTOPHER R. SHEAFFER PLAINTIFF V, APRIL D. SHEAFFER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-7785 CIVIL ACTION LAW IN CUSTODY AND NOW, this 9th day of November , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear beforeMelissa P. Greev~, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 12thday of December ,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 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: Is/ Mellc~a P. Gree~v. .~ Custody Conciliator 0X The Court of Common Picas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessib]le facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must bc made at least 72 hours prior to any hearing or business before thc court. You must attend the scheduled conference or hearing. '~OU 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 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 TRUE COPY FROM RECORD In Testimony whereof, I h~re ~'~:,~ s~t m,/hand and ~he s.-.a[ of s,~id Court ~t C~rl':!.~, ~, This /~3 day of ~ - p "LWhom & Date De~vered · Complete items 1, 2, and 3. Also Complete item 4 if Rest¢icted Delivery is desired. · Print your name and address on the re'Cer~e so that we can return the card t~ you. · Attach this card to the bac~'of 1 or on the front if space t. Article Addressed to: 2, Article Number (Copyfrom PS Form 3811, July 1999 A. ReCeived by (Please Pdnt Cleady) B. Date of Delivery ~] Agent Is delivery address different YES, enter delivery address below: E] No ~] Express Mail F~ Return Receipt for Merchandise U Insured Mail U C.O.D. Defivew? (Extra ¢~) ~ Domestic Return Receipt ~ ~ f 02595-00-M-0952 UNITED STATES pOSTAL ,,~,¢** -~ ~; uSPS 4 'i , I III., , , L~ __-- · Sender: Please pnn~ y~ , vs. : NO. 00-7785 : : ClVlLACTION- LAW Defendant : CUSTODY CHRISTOPHER R. SHEAFFER, Plaintiff APRIL D. SHEAFFER, DEC :L IN THE COl, JRT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 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. ~: The parties, Christopher R. Sheaffer and April D. Sheaffer, shall have shared legal custody of the minor Children, Christopher R. Sheaffer, born May 13, 1998, and Sarah J. Sheaffer, born March 24, 1991. Each parent slhall 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. § 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. ~:~L,~L~E~tg~: The parties shall have a shared physical custody arrangement which shall be arranged around the parties' work schedules. Additionally, Mother shall have one seven-day period of vacation each summer. If a conflict should arise with regard to the custodial schedule, the schedule shall be arranged in a week-on week-off schedule which will be deemed to have commenced on December 18, 2000, with Father having custody for that week. 3. Relocation: Neither party shall relocate beyond a fifty-mile radius from their present residences in Cumberland County, absent proper petition to the Court and a sixty-day notice provided to the other parent. Dist: Jane Adams, Esquire, 117 S. Hanover Street, Carlisle, PA 17013 Karl E. Rominger, Esquire, 155 S. Hanover Street, Carlisle, PA 17013 CHRISTOPHER R. SHEAFFER, : Plaintiff .' .' vs. : NO. 00-7785 : : CIVIL ACTION - LAW Defendant : CUSTODY APRIL D. SHEAFFER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CUSTODY CONCILIATION SUMMARYREPORT 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 CURRENTLYIN CUSTODY OF Christopher R. Sheaffer Sarah J. Sheaffer May 13, 1998 March 24, 1991 Mother and Father Mother and Father 2. A Custody Conciliation Conference was held on December 12, 2000, with the following individuals in attendance: the Father, Christopher R. Sheaffer, and his counsel, Jane Adams, Esquire; the Mother, April D. Sheaffer, and her counsel, Karl E. Rominger, Esquire. 3, The parties reached an agreement in the form of an Order as attached. Date Custody Conciliator CHRISTOPHER R. SHEAFFER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 00 - 7785 Civil Term APRIL D. SHEAFFER, Defendant : ACTION IN DIVORCE AFFIDAVIT OF CONSENT* 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on November 2, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken :~nd ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divoroe after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date:_,? -2 ~' O / Christopher R. Sheaffer~intiff WAIYER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER Ii3301(c~ OF THE DIVORCE CODE 1. I consent to entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and corract. I understand that false statements herein ara made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Chdstol~er R. Scheaffe~aintiff CHRISTOPHER R. SHEAFFER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 00- 7785 CiviITerm APRIL D. SHEAFFER, Defendant : ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divome under section 3301(c) of the Divome Code was filed on November 2, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: ;Aj_ c:~,'"~ ' (~ [ April D. Sheaffer, Defendant ~ WAIVER OF NOTICE OF INTENTIG~ TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301~c~ OF THE DIVORCE CODE 1. I consent to entry of a final decree of divome without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divome decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit ara true and correct I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: ::~-~"~ -(~ ~ "A"p~l~l~i Sc-F~afferi-Plaint~ ~ CHRISTOPHER R. SHEAFFER, Plaintiff VS. APRIL D. SHEAFFER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COU2qTY, PENNSYLVANIA : : No. 00- 7785 Civil Term : : ACTION IN DIVORCE; PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail, restricted delivery, return receipt requested, delivered on: November 7, 2000. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: March 29, 2001. By Defendant: March 28, 2001. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Diw>rce was filed with the Prothonotary: ~ ~'4D [ Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: ~--~.~c~ ~0 [ ~ Respect fully~.~Sub/~_d: /,~a~ Adarns~E~quir~ - / I.D.~No. 79465 [ 36 ~. Pitt Street ~aflisle, Pa. 17013 (717) 245-8508 Attomey fi)r Plaintiff IN THE COURT Of COMMON PLEAS Christopher R. Sheaffer, Plaintiff VERSUS April D. Sheaffer, Defendant OF CUMBERLAND COUNTY STATE OF PENNA. No. 00 - 7785 Civil Term NO. DECREE IN DIVORCE AND NOW,~~J~ ~ , IT IS ORDERED AND DECREED THAT AND Christopher R. Sheaffer April D. Sheaffer , PLAINTIFF, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY, THe COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YEt BEEN ENTERED; None. ATTEST: J. PROTHONOTARY