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Home My WebLink About01-1704 FX SAlOIS SHUFF, FLOWER & LINDSEY ATIORNEYS'AT'UW 26 W. High Street Carlisle, PA ;--"1. " LISA A. THOMAS and WILLIAM STEVENS, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW TERESA STEVENS, Defendant NO.{)/- /70'{ Civd th- 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 , 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 shall 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: Custody Conciliator 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. 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, Pennsylvania 17013 (717) 249-3166 -, ',.-- """,_"-,_~~_ .'- -,~, -, ~', '"~_"'_. ,,"~L_._ '.--".'-' - ~- ',e SAlOIS SHUFF, FLOWER & LINDSEY ATI'ORNEYS.AT.LAW 26 W. High Street Carlisle, PA '"~ _ -, , "- ",-" - ' ","". . ~ ,- II LISA A. THOMAS and WILLIAM STEVENS, Plaintiffs : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW TERESA STEVENS, Defendant NO. OJ. /7D'-ICw:J. t.e.- IN CUSTODY PETITION FOR CUSTODY AND NOW comes the Petitioners, Lisa A. Thomas and William Stevens, by and through their attorneys, Saidis, Shuff, Flower & Lindsay, to aver the following: 1. The Petitioners are William Stevens, an adult individual residing at 8 Orange Street, Mt. Holly Springs, Cumberland County, Pennsylvania and Lisa Thomas, an adult individual residing at 33 Chestnut Ridge Road, Gardners, Cumberland County, Pennsylvania. 2. The Respondent is Theresa Stevens, an adult individual residing at 216 Scenic Drive, Shippensburg, Cumberland County, Pennsylvania. 3. William Stevens and Theresa Stevens are the parents of two children, Adam Stevens, date of birth 7/6/85 and Andrew Stevens, date of 7/27/86. 4. The Petitioners seek custody of those children. 5. The children have lived with Lisa A. Thomas at 33 Chestnut Ridge Road in Gardners, Pennsylvania since March of 2000, and prior to that they lived with William Stevens and ";~~"'1"'I,-"t .ocr. ,- I-r" ~:-^ ,,','--,"' - ,'.; I~ - I' , "I -',- .,. , ,-~ . SAID IS SHUFF, FLOWER & LINDSEY ATIORNEYS-AT-LAW 26 W. High Street Carlisle. P A .'~~ I " Theresa Stevens at 120 Peach Glen Road in Gardners, Pennsylvania. 6. The father of the children is William Stevens, his address is 8 Orange Street, Mt. Holly Springs, Pennsylvania 7. The mother of the children is Theresa Stevens, her address is 216 Scenic Drive, Shippensburg, Pennsylvania. 8. The relationship of the Plaintiff is that maternal aunt and she lives with both of the boys. 9. The best interest and permanent welfare of the children will be served by granting the relief requested. The children have been residing with the Petitioner, Lisa Thomas, for the past year, are comfortable in the environment, and continue to see their father on a regular basis. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Dated: '3 - ft(--(j} J. Att ney I . # 53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiffs .. ..,.> .""" .,..... -. . .~, ,'c, ",' SAlOIS SHUFF, FLOWER & LINDSEY ATTORNEYS-AT-LAW 26 W. High Street Carlisle. PA -'" I" .-, " VERIFICATION I verify that the statements made in the foregoing Petition for Custody are true and correct. I understand that false statements herein are made subj ect to the penal ties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. DATED: I1r-L ~. (} ~/ i A .-. '-.LL.~ \ Lisa A. Thomas JO, ,xJol , r. 3__ . ,..,.", 'I', -,_\..' .'; ~ -.1 " . '" , ,. _, ,-L- ,-'~, ". '-"1 . ,-r . SAlOIS SHUFF, FLOWER & LINDSEY ATI'ORNEYS.AT-LAW 26 W. High Street Carlisle. PA " VERIFICATION I verify that the statements made in the foregoing Petition for 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. DATED: !i14 c;20,.;oLJI / ILlLL--:?L William Stevens Jl'; --~! ;-~ .' ,-',~"~- , . ~ p ~c'I,'!""'"_ -""I~':'h I ~__ ~,,_,o "" ,"., . -'''' . . .. , I . ~ SAlOIS SHUFF, FLOWER & LINDSEY ATIORNEYS'AT'LAW 26 W. High Street Carlisle. PA C>:" J, ! 0 ~ ~ -f. " CERTIFICATE OF SERVICE On this r')]fld day of ~ fi h I 2O<2LI If hereby certify that I served a true and correct copy of the foregoing petition for Custody upon all parties of record via United States Mail, postage prepaid, addressed as follows: Theresa Stevens 216 Senior Drive Shippensburg, PA 17257 SAIDIS, SHUFF & MASLAND By: , "0' ,,". ., , =~ . _ _"'1,"_' ,j. - I" ,_1 'C r", - < ,~,', . - I '"'. cr-, '. .", '.",'~ ,".,. " ,"'" F~ " ~ 0 '" ~ '" "'V \J 0 "" '--'''1'''''' ~ ",., c.,,-"' -,-, .~_. ~" , -, .,.,..,~~ . ~~.. " ~1lJ!_ '~r" __"~~~~ "._0 " "' "~r'''' J Q C:'} .c:, , ---. r:"_ " .,}.:: _'''.J ;i~: " ~) r, C' ~) '---1 , ("V 'c , 1 ~~ ' , "'lJ '--' )..':~ \ " :J;;: r ~_ 1', ,j C; () .-'" )> r-' '::' :,) rn -" :;:i L_ ;" --4 :0 , 01 -, -< ~ ~ _F .. ... C tr ~ C \ '" V a ~ OJ ~~ ) Jlm~~%_\lWel~~;~rm1U!""!\lemrffl!l'i1~.fT<-t1~W~~~I'~"___l,!lliI_~"~" _,_"",!,>~, LISA A. THOMAS AND WILLIAM STEVENS PLAINTIFF V. TERESA STEVENS DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-1704 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, March 30, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, April 12, 2001 at 10:30 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. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Hubert X. Gilroy. Esq. f;P 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 ,~" -.~,-, .~ 1- - 11 I' ~_ ~ _0 " ",O^, ~--..".," l"~~~i.:$~1bW:ii<.l;..)M<J"Ji""bhj!~I~ir!iW'l1..'1l';;""ili,hii>~"J1ic;J;~,,",2d,:tj',,__'''-d'''d'''Ld:cl,,,_,~_,k'''l&~~'MHm~BiI;' ~~ t ~lilll!i Lfd-tJ/ 1'-,) .tJ ( fI<:2 '01 ,l!"."LlnIl ._,~_ "h_, ""'" '" "_".~"",,," _ (y: - OifFR-2 f:~: !'). r C1 j Ilk..;')", C11",~:'::';':[.': - ',:' '\ "Y~'; 1)_ ;~r( ......IV,__"~I iL/"\j '~L' G',-,f\.}j\ I \ PENN3Ylv~l\N~'\ twI-~~~ '71fl0 ~~ ~~~ :.." ~"-~_."'" "_~. '_- -J"...., ~ 1 eo- ~~"-~__.__, 1>'0 Ili - . tlPR 2 3 2001~ , LISA A. THOMAS and WILLIAM STEVENS, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION. LAW TERESA STEVENS, Defendant NO. 01.1704 CIVIL IN CUSTODY COURT ORDER AND NOW, this J.. <; tL, day of April, 2001, upon Conciliation Report, it is ordered and directed as follows: consideration of the attached Custody 1. The Mother, Teresa Stevens, the Father, William Stevens and the minor children's cousin, Lisa A. Thomas, shall enjoy shared legal custody of Adam C. Stevens, born July, 6, 1985; and Andrew C. Stevens, born July 27,1986. 2. Lisa A. Thomas shall enjoy primary physical custody of the minor children. 3. The Father shall enjoy periods of temporary physical custody with the minor children pursuant to a schedule that the Father and Ms. Thomas will work out between themselves. 4. The Mother shall enjoy periods of temporary physical custody with the minor children as follows: A. On alternating Saturdays from 9:00 a.m. until 5:00 p.m. and on one evening per week at a time to be arranged between the parties. B. It is anticipated that Mother's periods of temporary custody shall be expanded as time progresses assuming the Mother's periods of time with the minor children proceed without incident. The parties can work out between themselves an expansion of custody as they agree. C. Mother shall also have temporary custody of the minor children for the holidays pursuant to a scheduled as agreed upon by the parties. 5. In the event either party desires to have the minor children involved in any counseling programs, the other party will cooperate in providing the children to that counseling. .- _ ;.1' ,,- _ ' - -- -" ,~'" - ,"-",""'_'; of ", _'''' '-. ,," ,r'" 'I""~' ~ , 'I -,,,- ""_ r -- ',,", . ,.~ "-' T ~ lii ~ ~-~ ".- ~'" "'~'- ~~,' , -- -'- -, . .~" 'VIN'V'SIJ.SNN3d JJ,Nno:J Cl\'~V1H?,8\~nO tjO:\ Md 92 Bd~ \Q A\:JV1!JiiiJ;;J!2'\; 30 38U:lO--G:nd -"~ ',,-' -~ -,"'. ~-."-",,,,'(,~, - = - ~- ~" . '"~~~~~ ~ _..,.~ ~!,.,....",_fl!l"1 r_uu: J!mll~~:W" ~,~_~'It~>l~r;~:;>~dili'""'-~ ..",."",.,Wcll:lll~ ~1~~':':~M [ ~l""'Ti;CWn' ," ; "- -,~!"I'-'I ~~ ~, ~ cc: \{,.~,~ ,'j , .,~'., -~''''" 6. In the event either party desires to modify this order, that party may petition the court to have the case against scheduled with the Custody Conciliator for a Conciliation Conference. Johrma J. Kopecky, Esquire Joan Carey, Esquire J. ~ * .,., _'''_I<-'',~,'''<,,~1''';I__",,"'''"_''"'___ '_'..." n,' ""IJ ,e, ,.-,-,0 I"" ,.,-- ,-~, .' J . c._ ! 1'. . LISA A. THOMAS and WILLIAM STEVENS, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW TERESA STEVENS, Defendant NO. 01-1704 CIVIL IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent infonnation pertaining to the children who are the subject of this litigation is as follows: Adam C. Stevens, born July, 6,1985; and Andrew C. Stevens, born July 27,1986. 2. A Conciliation Conference was held on April 12, 2001, with the following individuals in attendance: The Mother, Teresa Stevens, with her counsel, Joan Carey, Esquire; and the Father, William Stevens and cousin Lisa A. Thomas, with their counsel, Joluma Kopecky, Esquire. 3. The parties agree to the entry of an order in the form as attached. ~I ('it Dt DATE Hug. G~SqUire Custody Conciliator '~'~"1!':"1':r~ ,';C-~""-!;:'""", ,.""._,. _,"'0' '. _'-"7 -',',_r'~"r,~, """"'.,1,,,"0, '-"'_~ I':~,_' ,_,< __ -'.'1'- , ,~,,-, '1"'" " -.- ;' I ,