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Home My WebLink About01-0044 FX - , VICKI E. SHAFER PLAINTIFF V. JOHN R. SHAFER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-44 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 5th day of January, 2001, 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 6th day of February ,2001, 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 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 THE COURT, By: Isl Melissa P. Greev s 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 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, Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 t'l:.,.~~ I . , ,., . , ~."...,~ " ~-" o' "'- .', ''''''_ -" d.' 'c ~~",';..-; j,-~l'-,,~.-~-:"; - ""'I""';;""'->-"<="-b'"-~l-_-"J'-"-T'r- t--__ , ~.? ~ ~-"4W &; Irl'}.f 4f;.~ ~ ~14 J(J}( '5% $ r1# ~ fo/ 1(l'J! I , Yit~lv?\:1),Sr\!N3j 1\11'11" ," 'v.', ", ."., . ,I, J,! ' ,,-' :""i-,,',,:ifol{)'J -'>.' , I _!:,,:.',!!!. q "';~ .',c,' 1 J., , ,\ ,., \_, 8v'~[.~'~.r ~j,,~ ).}." ':~"lJ!Ii __'''''''''F'~I1fll~~'~~flW_~~,',!,*;Yj"J''",.':~_'''_n'''''''_N-i-'-"~''i'i",r'''VJ~'''''~'_"'~W'f,!~~I_3'f!i~tJi!-'I:;;_?IIN!'~ljl'mfn~~9I1a,r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VICKI E. SHAFER, Plaintiff v. . . NO.O I-Lit Civil Term JOHN R. SHAFER, Defendant . . 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 , the Conciliator, at on the day of , 2000, at ___.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. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent Order. BY THE COURT: 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, PA 17013 (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 the office set forth above. 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. - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VICKI E. SHAFER, Plaintiff . . NO. 0 \ - ~~ Civil Term v. . . : JOHN R. SHAFER, Defendant IN CUSTODY COMPLAINT IN CUSTODY AND NOW comes the Plaintiff, VICKI E. SHAFER, by and through her attorney, Maryann Murphy, Esquire, of Mid-Penn Legal Services, and ~espectfully files this Complaint in Custody, and in support thereof avers as follows: 1. plaintiff is VICKI E. SHAFER who resides at 317 Juniper Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is JOHN R. SHAFER who resides at 269 South Pitt Street, Carlisle, .Cumberland County, Pennsylvania. 3. Plaintiff is the biological mother of the minor children: INDIGO SHAFER, born October 9, 1997; and GENEVIEVE SHAFER, born March 18, 1995. 4. Defendant is the biological father of the minor children. 5. The minor children were born in wedlock. 6. The children are presently in the custody of Plaintiff. 7. During the lifetime of the children, they have resided -',\ ~ '." _"" ".I:"! ,1""1 < ~,.., - with the following persons at the following addresses: Dates Addresses Persons birth-10/23/2000 269 s. pitt St. Carlisle, PA Plaintiff/Defendant Defendant's daughter 10/23/2000-present 317 Juniper St. Carlisle, PA Plaintiff/Plaintiff's friend 8. Plaintiff and Defendant are married to each other. 9. Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the minor children in this or any other Court, except as set forth above. 10. Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth or in any Court. 11. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the minor children, or claims to have custody or visitation rights with respect to the children. 12. Each parent whose parental rights to the minor children have not been terminated, and the person who has physical custody of the children, have been named as parties to this action. There are no other persons known to have or claim a right to custody or visitation of the children and therefore, no further notice of the pendency of this action and the right to intervene shall be given, ,'cr., r.l_ 1''''' . other than to the parties named herein. 13. The best interests and permanent welfare of the minor children will be served by granting primary physical custody to Plaintiff and partial physical custody to Defendant. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree granting her primary physical custody of INDIGO and GENEVIEVE. Respectfully submitted: Maryann urphy, Esquir MID PENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. #61900 Attorney for Plaintiff I~ ,ii. _~'_1 ~ , 1~1.' VERIFICATION I, VICKI E. SHAFER, do hereby verify that I am the Plaintiff in the within action, and that the statements made in the foregoing Complaint in Custody 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. VICKI E. SHAFER ~- ~ ~ - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VICKI E. SHAFER, Plaintiff . . NO. 0l-lf ~ Civil Term v. JOHN R. SHAFER, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Maryann Murphy, Esquire, do hereby certify that on the day of , 2000, a true and correct copy of the Complaint in Custody was served upon the Defendant by placing a copy of same in the United States Mail, first class, postage prepaid, certified/restricted delivery, addressed as follows: John R. Shafer 269 South pitt Street Carlisle, PA 17013 Respectfully submitted: urphy, Esquir LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 1. D. #61900 Attorney for Plaintiff 7>1 ~. ~.' . '~I ,,~~, ~MlM_~;:r 11' ~_~1!'ll~~~,-,,'!IjIJl!<~ "~""lJ'J!\!W-;!ir-->_, "" ""0-'" ~,,'~-,,'-' "~"~:Oe ,,, .,c,c,~, "'1 ':';'"'f~'<'_'/''':i''I1''r_ttRi"",i''''' "tr"1"-1i::'u,'i(''' ;,;n'~r:'> mi~lV"! \, ~ i , fJ D ~-;,; ~V co -, ~: 1-'~ f~~~ :< /; ~ \U. ~ - , '" .L c o " (. . -~ ---'" ':;1 '''\,) CD () -q "-1 l ":'] ~) ~B ;-t: :S! :D """'" llllll! 11_ r.1/ill!.IWJ!lIIIJ~1!'~~MWi;-'''''--, '>-"",~";r '_i~~"""'F'''''''!f,T~,,",U''''F1T'!W;:''''!''Wi@ji'jF!I;e,~"!w_<'i,~,;"';--""O':~.jll"r~f'J'I!!\fiW!~~ffi!l~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VICKI E. SHAFER, Plaintiff ~ NO. 0 \ - 4- t Civil Term v. : IN CUSTODY JOHN R. SHAFER, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, VICKI E. SHAFER, Plaintiff, to proceed in forma DauDeris. I, Maryann Murphy, Esquire, of Legal Services, Inc., attorney for the party proceeding in forma Dauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. ~M~M.L Maryann hy, Esquire Mid-Penn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaintiff ~ ""roll ~~ ~--- , "'1=) .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VICKI E. SHAFER, Plaintiff : NO. 0 \ - '+ ~ Civil Term v. : IN CUSTODY JOHN R. SHAFER, Defendant AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS I. I am VICKI E. SHAFER, Plaintiff in the above matter and because of my fInancial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the infonnation below relating to my ability to pay the fees and costs is true and correct.. (a) Name: VICKI E. SHAFER Address: 317 Juniper Street. Carlisle. PA 17013 (b) Social Security Number: 165-58-1079 If you are presently employed, state Employer: Lehigh University Address: Bethlehem. PA Salary or wages per month: $ 1000.00 Type of work: teaching :-"!;l;I' ,- ~ If you are presently unemployed, state N/A Date of last employment: N/ A Salary or wages per month: N/A Type of work: N/A (c) Other income within the past twelve months Business or profession: -0- Other self-employment: -0- Interest: -0- Dividends: ,0- Pension and annuities: ,0- Social Security benefits: -0- Support payments: -0- Disability payments: -0- Unemployment compensation and supplemental benefits: -0- Workman's compensation: -0- Public Assistance: -0- ()ther: ,0- (d) Other contributions to household support NONE (Wife)(Husband) Name: N/A the parties are seoarated If your (husband) (wife) is employed, state Employer: N/A ", ~, '"'l'iI!l!l , (g) Persons dependent upon you for support (Wife) (Husband) Name: N/A f%ll!! I','" ',-. " I"!"I ' " - Children, if any: Name: Indigo Age: 3 Name: Genevieve Age: 5 4. I understand that I have a continuing obligation to inform the court of improvement in my fInancial circumstances which would permit me to pay the costs incurred herein. 5. 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. Dat(!i-- t )-f)() I 1/ J ,I -'I~~1 _--_'1""'1 ~,. ~ ~~ ,.', - "" ' ,.-~~, ." ^.-,~~-,,,., .~ ,~~,~~~","_y.~IiWifI~,*aN<)."d'i!q~~!ffi~mS~~~'?7~""",,!n.:'" ;,'V<.'.\,'..,"F, ~- ~._h~""-'~"_ ''''''','~..i,,,., lTf"'ili'tti __W'o', -- '-\-:~r~-" (") c: -v~f.; S2.f}:" l~~}t};. ce-, "-'- j'f~ -:-J!" :~ "', c.'J ,-- '"j" o -n ..~ .":'-- (",', -.. " ' ..1,,;(S ~~~ ql ~i -< ~. ." r;? ~-..:> (,::l ~ '.". "!W~'W?lme""~f'lii'i'__l"'t"f"/IfP~1'!!",",;r'~<i1"lIl-,,.Gf7,:~'f*"''li100'Jjf.ji~'W\W.F-" FEB 1 2 2001 i > ,. . Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-44 VICKI E. SHAFER, vs. Defendant CIVil ACTION - LAW CUSTODY JOHN R. SHAFER, TEMPORARY ORDER OF COURT AND NOW, this l'l day of February, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1, legal Custody. The parties, Vicki E. Shafer and John R. Shafer, shall have shared legal custody of the minor Children, Indigo Shafer, born October 9, 1997, and Genevieve Shafer, born March 18, 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 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. Physical Custody. The Mother shall have primary physical custody of the minor Children subject to Father's rights of partial physical custody, Father shall have partial custody at such times agreed to by the parties upon a 24- to 48-hour notice provided by Father to Mother. 3, Holidays. A. Thanksgiving/Christmas, The parties shall alternate Thanksgiving and Christmas each year. In 2001 and all odd-numbered years thereafter Mother shall have Thanksgiving and Father shall have Christmas Eve night through Christmas Day. In 2002 and all even-numbered years thereafter Father shall have Thanksgiving and Mother shall have Christmas Eve night through Christmas Day. B. Easter Sunday. The parents shall share Easter Sunday with the Children each year. '<~"~~, r^ ,061 ~, ,'"" (. . No, 01-44 C. Mother's Day/Father's Day. Father shall have Father's Day and Mother shall have Mother's Day each year regardless of the usual schedule, D. Vacation, Each parent shall have the opportunity for summer vacation with the minor Children each year. Written notice shall be given to the other parent as soon as possible, In the event that both parents choose the same time for their summer vacation, the parent who first gives notice shall prevail. The schedules for holidays, vacations and special occasions shall take priority over the usual schedule. 4, Both parents shall permit reasonable telephone access between the Children and the other parent. The Children shall be permitted reasonable telephone access to place calls to each of their parents while they are with the other. 5, Both parents shall work together to arrange for the Children to enjoy regular periods of partial custody with the Father. 6. This Order is temporary in nature. Upon proper petition, either party may request Modification of this Order following which a Custody Conciliation Conference shall be scheduled. BY THE COURT, /~ // /.- J, Disl: Maryanne Murphy, Esquire, MidPenn Legal Services, 8 Irvine Row, Carlisle. P >17013 Johnna J. Kopecky, Esquire, 26 W. High Street, Carlisle, PA 17013 t~ /f;JJ- 02-1t/-OJ ~~ A'IIll '" .", . , '\ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-44 VICKI E. SHAFER, vs. Defendant CIVIL ACTION - LAW CUSTODY JOHN R. SHAFER, 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 Indigo Shafer Genevieve Shafer October 9, 1997 March 18, 1995 Mother Mother 2, A Custody Conciliation Conference was held on February 6, 2001, with the following individuals in attendance: the Mother, Vicki E. Shafer, and her counsel, Maryanne Murphy, Esquire; the Father, John R. Shafer, and his counsel, Johnna J. Kopecky, Esquire. 3. The parties reached an agreement in the for of an Order as attached, hssa Peel Greevy, Esquire Custody Conciliator d ..q- () / Date -'1"1lIl,~,..,.,_ I 1'1-- "f