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Home My WebLink About01-1611 FX '\! THERESA D. SHOENBERGER, PETITIONER : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 01. /(,/1 CIVIL TERM DALE M. EURICH, RESPONDENT IN CUSTODY ORDER OF COURT AND NOW, this day of .2001, upon 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, 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 this conference may provide grounds for entry of a temporary or pennanent order. By the Court, By: Custody Conciliator YOU SHOULD TAKE TIDS 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, Peunsylvania 17013 (717) 249-3166 1-800-990-9108 C", _0_ ~",:",,~, ';..;',=' ,~~., ',,",~,' ",,' "I,"'.,"",. ,^""~,_,, v,,", ,~~__,~""'," _""n,t,"" _ ",,_, '''-- h,~,_ 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 scheduling conference or hearing. '['. -- ,~> ",,:' , ',~,'l""~,, -^ " " ~~ :;=,\,,,< , "',~,' ~,'" _,"_""_< . ~ ," ~" .' , ,,-" ,.' ,~, " .',? ,~ THERESA D. SHOENBERGER, PETITIONER : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. OJ-jt, If CIVIL TERM IN CUSTODY DALE M. EURICH, RESPONDENT PETITION FOR CUSTODY AND NOW, this 20th day of March 2001, comes the Petitioner, Theresa D, Shoenberger, by her attorneys, Irwin, McKnight and Hughes, and presents the following Petition for Custody. 1. The petitioner is Theresa D. Shoenberger, an adult individual residing at 182 CME, Newville, Cumberland County, Pennsylvania 17241, 2. The respondent is Dale M. Eurich, an adult individual residing at 327 Stoner Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The parties are the natural parents of one minor child, namely, Amber N, Warnock, born October 19,1991, age nine (9), '~*'t'tt ~ - ~''f! ',_,'I, \_"'_~o"''''''',<",,,,,,_ _",~_':,_ ~,o,' ",,'-,",'1",',:>'-' ~'_'~_',_,"" ,_,_~ . 4, Petitioner desires primary physical custody of the child and joint legal custody with periods of visitation to respondent as can be mutually arranged between the parties, 5. The best interest of the child 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 child and joint legal custody with periods of visitation to respondent as can be mutually arranged between the parties. Respectfully submitted, IRWIN, Mc GRT & HUGHES By: Marcus (.\. Mc Attorney for Petitioner, Theresa D. Shoenberger 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court I. D, No. 25476 Date: March 20,2001 4,t"l',C~ ~ ',,' "'",p,,-. ,,,~, ,;_,,",,__ ~,',;'07<,',~" ~'~"''''",l~',~~"'''. ,_,~," ",,"_,,~,~~__, 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 head 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, ~ ~~~~ \\=...~ ,,' , THERESA D, SHOENBERGE Date: MARCH 20' .2001 ~~-",z,-d, ,M,,_~,_,'~"'~"'''''''''-''''''''~~' "'~~ ~,,~~,,_'~""'. ""01'"",,., " ~,' ,~, ~~, -" , 1".1 ~ r~ .... <>. -0 (:; ...... '- "<J '" L. "' ~ ~'" ",~ '" c_,'~~_ _,IJIr'i'q"" , '~, .~. 0 ''''",''f_''''~.'' .. __,. ,~ ._/~,,,,,!~~~1ll:1 (') c: ~ ~tt Lt... en.;> i~' p~ 2: =< .~~ _'W,~ "-'"' _' _'.'_;'< C:J C) --q ~~ ;,:;:1:) ", C) -_,j ;"-r;;Jj , i-r! -"":? ~';, :-~; po:::; -:; -."\..-' c5rn ::;! ::'0 -~ ~I t:" (,u @ ~ ~~ ..... q, ~ "I ~ <> cl ~ g I)- d ,,!,",,,-"""""'~,,,,~,IOIIII~$i,~J .... , THERESA D, SHOENBERGER PLAINTIFF V, DALE M, EURICH DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-1611 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, Cnmberland County Conrthouse, Carlisle on Wednesday, April 25, 2001 at 2:30 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 JacqueUneAl. Verney.Esq~ 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 :"'f., , '" 1'1" 1 " , ---- ,!fu~~:~lI:i,!';t~"'!liM~-edil::il'!!!i-h.~iUIili,~llIM"di2",",~O&.,"')'v"""""";"Il,i,"'{J;h,,,,;;j;\,~,~,.^'".tili~;,'<'~ill'1.>::,,)i~L.lm1liililli-'~ ~iliili!uilliliul:1fIIr~" i>k-.,~~~ , .3 02& ~( 3 ;,)~ ,:? I .3 -O?&tJ/ 1j ur 1l11,t-" ~- ... ii--::"\ (:'0 Pt.! -"). n- . f-' ,t:::J Clft', ,{;:":,'~'~'- ': ',:.." , v or..;, f'll t,\'U ","", PEr:~{vs\i\^i!\~\lJNTY ,r'l "" ;}vf, ~ ~ ?f 4 /U~ ~~~4.~ ~~~ 4'~~~' 1s JJ_" ph^" ", ",~," ''''-i'',:"'.'~<' ~H;" .,..,.."',~".,' ',"",_'" ,_ >"',""~,,~__ ",,,q<~,, ,"'," '""',"",...."~n:,-'" ..,.._ ,~,_ w "'!,~, .. THERESA D. SHOENBERGER, Plaintiff MAY 2 3 2001Qt7 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA V. : NO.2001-1611 CIVIL TERM DALE M. EURICH, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this c?l~ay of ,vt"q , 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1, The Mother, Theresa D, Shoenberger, and the Father, Dale M, Eurich, shall have shared legal custody of Amber N, Warnock, born October 19, 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 Child's general well-being including, but not limited to, all decisions regarding her health, education and religion, 2, The Mother shall have primary physical custody of the child, 3, The Father shall have the following periods of partial physical custody: A, Alternating weekends from Friday at 6:30 p,m, to Sunday at 6:30 p,m" except during summer school vacation the Sunday time shall be 8:30 p,m, B, Two non-consecutive weeks during the summer, with Father providing Mother with thirty (30) days prior notice, C. Father's birthday and Father's Day, 4, The parties shall alternate the Christmas holiday, Block A shall be from 12:00 Noon Christmas Eve until 12:00 Noon Christmas Day and Block B shall be from 12:00 Noon Christmas Day until 12:00 Noon on December 26, Mother shall have Block A in odd numbered years and Block B in even numbered years, Father shall have Block A in even numbered years and Block B in odd numbered years, 5, The parties shall alternate the following holidays Memorial Day, July 4, Labor Day, Thanksgiving and Easter. 6, Father shall provide Mother with twenty-four (24) hour notice of cancellation of his partial custody, unless a family emergency arises, I, , - "~"~_..,,"'" A.."W~ " 7, The party receiving custody shall provide transportation, 8, The parties shall keep each other advised immediately relative to any medical care or medical emergencies concerning the child and shall further take any necessary steps to ensure that the health and well being of the child is protected, During such illness or medical emergency, both parents shall have the right to visit the child as often as he/she desires consistent with the proper medical care of the child, 9, Neither parent shall do or say anything nor let anyone in the child's presence to say or do anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent or hamper the free and natural development of the child's love and respect for the other parent. 10, Both parents shall have liberal and reasonable telephone contact with the child when the child is in the custody of the other parent. 11, To the maximum possible extent, the parties shall deal directly with each other on matters concerning the child, rather than communicating through third parties or the child, 12, This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference, The parties may modify the provisions ofthis Order by mutual consent. In the absence of mutual consent, the terms of this Order shall controL J. cc: Marcus A. McKnight, III, Esquire, Counsel for Mother John M, Glace, Esquire, Counsel for Father 1 ~ "< ~~, I r , " ., THERESA D. SHOENBERGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. : 2001-1611 CIVIL TERM DALE M. EURICH, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: None 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 Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Amber N, Warnock October 19, 1991 Mother 2, A Conciliation Conference was held in this matter on May 23,2001, with the following individuals in attendance: The Mother, Theresa D, Shoenberger, with her counsel, Marcus A. McKnight, III, Esquire, and the Father, Dale M, Eurich, with his counsel, John M, Glace, Esquire, 3, The parties agreed to entry of an Order in the form as attached, S~:J..3-()( Date %,V{ cq ine M, Verney, Esquire Custody Conciliator ,">;-,1"!I!"'ll!llMll!~ ~. I" "~ ~._~,~