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Home My WebLink About01-1610 FX v KENNETH M. SHEAFFER, Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW ol-I""/) CIVILTERM JEVONNE M. SHEAFFER, Respondent IN CUSTODY ORDER OF COURT AND NOW, this day of 2001, in consideration of the attached petition, it is hereby directed that the parties and their respective counsel appear before . Esquire, the conciliator, at on the _ day of .2001 at .m. for a Pre-hearing Custody Conference, At such conference, 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 this 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. Court Administrator Cmnberland County Courthouse 1 Courthouse Square Carlisle, Pennsylvania 17013 (717) 240-6200 "'~""",~,~ ~'",'",'~-")ry"!~'~,,,,",,:-r'.,,,,,,-<;,,,,,"~.,~,",,,,._,"_' ~"I". '^'~"""~" _"~",,,,,'""-,,,' ..._,' , 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, i'r,;'!i,~"',~ , _ ,""<,"'-'=~" ~ h ,. ~~"__~ ,=,~.~_'_' "~_ ~"" '", d< ",_ KENNETH M. SHEAFFER, Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW o {, "10 CIVIL TERM JEVONNE M. SHEAFFER, Respondent IN CUSTODY PETITION FOR CUSTODY AND NOW comes the Petitioner, Kenneth M, Sheaffer, by his McKnight & Hughes, and presents the following Petition for Custody, 1. o Cl c: Z ::;J: -u 0'5 "'" rnrl', ;;;:l Z."(' z( N (J) ~~ c::> -<:..:; ~=, ~ zL.-< sS'2 r:-? z ~) ;::< (;'l attorneys, Irwm, The Petitioner is Kenneth M. Sheaffer, an adult individual residing at 1634 Pine Road, Carlisle, Cumberland County, Pennsylvania 17013, 2. The Respondent is Jevonne M. Sheaffer, an adult individual residing at 26 Pine Street, Carlisle, Cumberland County, Pennsylvania 17013. 3, The parties are the natural parents of three children, namely, Cortney L. Sheaffer, born February 23, 1983, Kendra E. Sheaffer, born February 21, 1989, and William Powell Sheaffer, born April 24, 1991. , I i I I I I I I I , , I I,~ , - 0,__~ ':' _ '0 ",,,,,,,,~'~c"_,~= ___"" "'~~,-", _,,~-" ''''~,")f,,,,_,.,,,,., ,,~, ~c _"' ~ ,,_ ~ ,> ~" ,'_ _', '. ~,,,-,,,," '" , o -n -< ;)~7J _.-,,>-'n (~~ 't-;~ --l ~ =< 4, Petitioner desires primary physical custody of the children and joint legal custody with periods of visitation to respondent as the parties agree is appropriate and in the best interest of the children, 5. The best interest of the children requires that the court grant the petitioner's request as set forth above, WHEREFORE, petitioner respectfully seeks the entry of an Order of Court seeking primary physical custody of the children and joint legal custody with periods of visitation to respondent as listed above, Respectfully submitted, IRWIN, McKNIGHT & HUGHES By: Ma cus A. McKni t, Attorney for Petition 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court I,D, No. 25476 Date: March 20,2001 "'f 0 ,~ "'-""'~'-'''''''i,,'->!,'- -<"","""",,,-<,,-,,,,_ ,'''h." _""._~",'"," n.." '~, ,,~',", _, '_"~'~ VERIFICATION The foregoing Petition for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action, I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief, I understand that false statements herein made are subject to the penalties of 18 Pa, C.S.A. Section 4904, relating to unsworn falsification to authorities, ~M Jy-- KENNETH M, SHEAFFER Date: March 20, 2001 ,"'. < - ,,"'-,,;--, - "",",; "~"~,,- ,"~"'t, ~' ,,~(',"'~, k7>"",-<,,>,'-e:,C,O'h"f'''',u,H, ,-',~"', ",._,~",__,-" ,I , '~'" p...~~_ ,>,', "~"~, C'""_ "~ ..., ~. ",~ ,- s r , ~ '- .... " .., ~ " ~ \ - ~v V1tiVI\lASNN:1d I ''In( r I n' '",'~l'~""" I\J.Ji I I oJ',~ U;\!',,' ',,~~, !I.'\I"" " ,~, -,{J' Ill..) C<' '.Z vV Hd o n;'1\~ I 0 AI:JVy)"r 'H ., " .,." 1(' ~'_;,~;' :,:~>"--.',,,:,",,,; u. :.J ::J,.)i"b.i"O:,;!U _c 1_ '. , ...,?!1". ,~~, ,",>,," - ~, ",,,,=_~, '","',"~,""'" "" ''-. ~",~, ,', , 'J ,~'" ... ,., . _ -~'''',"'''',~,<>~."""",," " "'.0.-' ",,~- .""",.,. ~ " J? "- " ~ l...1~ ~ ",-' V <:, V( d c: Cl ,"< ,tl~'t"!!lJI~~~I'J1.~~_~q,,1JI , " ~IMM~~,. '_"""'''\~ , KENNETH M, SHEAFFER PLAINTIFF V, JEVONNE M, SHEAFFER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-1610 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, March 23, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, April 25, 2001 at 1:30 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, Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR TIIE COURT, By: Isl Jacqueline M. Vern"O'. Esq.bP 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 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 ~jr7, ~"" <'''-' '- - ~, ,,~" 'I ~ - I' - _,,_~","H .~ ~ i I I -;.., A<r" " ,"' ,', ~" r rf~ fn ~,~'~~ jfr ,~'~ ~ phw ft? ~ r 4; ,.-p/ VIN\f;\lASNr~::;-1 ) I,~ If +1"'," ~, ....1'.... ,_,!\~. ~l / I f' /\:1,,,, t-l"~~~ln . ".',: '.," ,,' :'~",~:~'~;!l;1 j Cf}'7 " I _,:(.J ,,_, ;:!(: 9?lJi"},'J I D :;-~o ~, ~","_, ,",~, ~,' ,"~ ,', _,~'"""',~,. ~o," "~-.o<~'~ '"~, "'," ., .,'" /(7. 'Jr- t' /rJ 9l- [' /(7 ~E ",,",o"""-'1'""'"~Olll~li. ~ '1ll!~"'A~"" ~"!l!\iI"i~J~W~""if!"'\i",,";"i' "P':F,,'!"i~n,?'(Y"'''1;-'':'W'i,w:~,q''''MiriH%f'i#~<,!;''f''';i,(''!R>.,,-"!j""'''i~'''''W;''''~\l!!'!'''1'''lf'Ip.'~ll\'~W;;'!#.-1: .,. APR 2 52001tf/ KENNETH M. SHEAFFER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2001-1610 CIVIL TERM JEVONNE M. SHEAFFER, Defendant : CIVIL ACTION -LAW : IN CUSTODY ORDER OF COURT AND NOW, this ,rdayof ~ ,2001, upon consideration of the attached Custody Conciliation Report, It is ordered and directed as follows: I, The Father, Kenneth M, Sheaffer, and the Mother, Jevonne M, Sheaffer, shall have shared legal custody of Courtney 1. Sheaffer, born February 21, 1983, Kendra E, Sheaffer, born February 23,1989 and William Powell Sheaffer, born April 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, 2, Father shall have primary physical custody of the children with Mother having periods of partial physical custody as agreed by the parties, 3, Mother shall provide Father with 48 hours notice of the time she desires to have partial physical custody of the children, 4, Mother insures that the children will not be left alone with her boyfriend without prior consent of Father, 5, Transportation shall be as agreed by the parties, 6, The parties may modifY the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BYT J, cc: Marcus A, McKnight, II, Esquire - Counsel for Father Marylou Matas, Esquire - Counsel for Mother m<("",,~,'llj "~~I , , c - ~~, ~~ ~ ~ ~"1~' ~,,,. ~' ;, fr; C) ~ ~, <= ~ ., ::><( t"b,;,o - 0-- ~~, ~ U~ ,~ 0- 0::3 '7>- ~'JW I . :z: Ll_;'-o_ .r-Z -"",", >- iJ..l,& u: "'" ::'D_ ::c ~ u~ ::> 0 Cl (,) i',.,,_~,. L ~v "' __ " m~;!Illi'lI!'!'!I~"M:lor: .~ ~,lflljl~'I' ,~"," ,;",,0' - __""T "." ''''?'~'' ~"""k''''''"' ",~,,,,',,,,,,,",,,,,'";;;;':''''''~''',,",,,,,''''-'^,''''' - ' - '''''''''''T''''' 'IN'" :' "u" "'ff]" It ~" ,!!";_~~~@'f'f~''''''''''?~'~~:\~1'1',fu~",fW,*1'\'"<~;;S%.l'!\fll!IW!'G!,.'ji~!!I!~;OO-l'>.l'l'jf''''fW''',\\fl""f''!l'-\i~,Ojiil1!i!f~i -# ~ APR 2 5 2001 KENNETH M. SHEAFFER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2001-1610 CIVIL TERM : CIVIL ACTION - LAW JEVONNE M. SHEAFFER, Defendant : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915,3:S;thelmclersigi}edCustody Conciliator submits the following report: I, The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Courtney 1. Sheaffer Kendra E, Sheaffer William Powell Sheaffer February 21,1983 February 23, 1989 April 24, 1991 Father Father Father 2, A Conciliation Conference was held in this matter on April 25, 2001, Father, Kenneth M, Sheaffer, was present with counsel, Marcus A, McKnight, II, Esquire, and Mother, Jevonne M, Sheaffer, was present with counsel, Marylou Matas, Esquire, 3, The parties agreed to an Order in the form attached. tf-2- 5 -0 I Date 7;;.i, cq ine M, Verney, Esquire Custody Conciliator , "jI<j~ , "~ I I -~