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Home My WebLink About01-2043 FX " CHARLES A. SATTERLY Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NO. 0/.;)0'13 ~ I..L<-- BARBARA A. SATTERLY Defendant. IN CUSTODY ORDER OF COURT AND NOW, this day of , 2001, 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 o'clock _' M., for a Pre-Hearing Cont\rence. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be ac~mplished, to defme and narrow the issues to be heard by the court, and to enter in to a temporary order. ' All children 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. BY THE COURT, 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 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, P A Telephone Number 717-249-3166 WEIGLE, PERKINS & ASSOCIATES - ATTORNEVS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397 (W1>"~~ ~ ,'-, "- , ~. <," I" n,,' .......'."" " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CHARLESA.SATTERLY Plaintiff, CIVIL ACTION - LAW vs. NO. 01- d..b'l3 ~ I,L......" BARBARA A. SATTERLY Defendant. IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Charles A. Satterly, an adult individual, presently residing at 1553 Mainsville Road, Shippensburg, Franklin County, Pennsylvania 17257. 2. The Defendant is Barbara A. Satterly, an adult individual, presently residing at 150 Rustic Drive, Shippensburg, Cumberland County, Peunsylvania 17257. 3. Plaintiff seeks custody of the following child: NAME PRESENT RESIDENCE AGE Cory A. Satterly 150 Rustic Drive Shippensburg, P A 17257 9 years The child was not born out of wedlock. The child is presently in the custody of Barbara A. Satterly, who resides at 150 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania 17257 During the past five years, the child has resided with the following persons and at the following addresses: NAME ADDRESS DATE Charles A. Satterly and Barbara A. Satterly 1553 Mainsville Road Shippensburg, P A 17257 1991 - 1997 Barbara A. Satterly 219 Meadow Drive Shippensburg, P A 17257 2/1997 - 2/1998 WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 :{:~~,^,,"""'1,ffl:_",___ '.' "'1,' ""1.-"",'","'--" . "' ""', ~J!'I!F.rn~ II Barbara A. Satterly 150 Rustic Drive Shippensburg, P A 17257 2/1998 - Present The mother of the child is Barbara A. Satterly, currently residing at 150 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania 17257. She is divorced. The father of the child is Charles A. Satterly, currently residing at 1553 Mainsville Road, Shippensburg, Franklin County, PA 17257. He is divorced. 4. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons: NAME RELATIONSIDP Nicole M. Satterly Deirdre L. Satterly Plaintiff's daughter from another relationship Plaintiff's daughter from another relationship 5. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the following persons: NAME RELATIONSIDP Cory A. Satterly Nancy Forney Son Defendant's Mother 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person, not a party to the proceedings, who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because the parties currently do not have a regular schedule for the exercise of Plaintiff's rights of partial custody. 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. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: WEIGLj::, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397 >'':l~,.l ffl\'iIlJ1IlI!!fl I,'~ : I'. ,- ]," . r' ~, - - " , , NAME None ADDRESS BASIS OF CLAIM WHEREFORE, Plaintiff requests the Court to grant both shared legal and shared physical custody of the minor child to the Plaintiff and Defendant. WEIGLE, PERKINS & ASSOCIATES By: \?)~ oz U~ David P. Perkins, Esquire Attorney for Plaintiff I.D.# 34342 126 East King Street Shippensburg, P A 17257 Telephone 717-532-7388 WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 ;:~f<, ~-""!'I , .~: " -" . " VERIFICATION I verify that the statements made in the foregoing Complaint 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: ;tl/lt{'1; 2f1 ~I a CHARL A. SAT ERLY WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397 'I~' -"T>""',"_'. .'-1", , , ,-< ~~ wt ~ r~ , '" "" ~ ~ (v 8 1,.. 'I ,~ .. r~ 0_' "'~ - '''~ , ., .... '.-=-"~,".- -':J ;;:~ rTi''::'< -:;- J:_ U~ r== :-. ~12' ~ -<: 'TI'W'_ ;=-2 C) '. ;~ .", \ ,~, _,J co :'/1 I ci{) '" i? C f - ,,~,,- -- 5J ....... ~ j' ., .fj, '-' c:l ., ,,', ,-y ,~~.~"'~~ ."_ """~~I~~!I!~ll@l'~.!"''l*~j'iW;lj'!!~>-',;7rli\''\1'iY"'''*'';';'~;;'?'''j'MIRI'!f::t)l;';!I&r~~\~tffijlli!;g;;WM~";:\lll'~~Il'M~I'mij'~I!!I:~lN~1 CHARLES A. SA TTERL Y PLAINTIFF V. BARBARA A. SATTERLY DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-2043 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, April 17, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Huber! X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberlaud County Courthouse, Carlisle on Thursday, May 24, 2001 at 9:30 a.m. fer 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. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to tbe conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Hubert X. Gilroy. Esq. bJl 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 ,"i'-jrl**~:o;- ;,w _r I' ~, ". ,~ 1~~~.ii'ilW~l1;j~~;lIii;"il;jjIiiJk!;J'Ir.,~,d&~,wdii~~~Bf\iM"'i,,~j,'\of';";',,:';,iWkH'i' ,1",/".,.- ';;:"c"i.li'dBMi~,~~:m~1P.Iii!liil$;~ - ,. i1O\!1I~~~~'" tj.!'l&( liP! (') I 4~/~ -tJ/ ".,~, --".^.' ,~.. 'T' 'I"' ",,'t :'1' t ~ ,- ~ " , ,"i ~-', ; " '~~'C ':,~ [\\T'{ ,\._, PE(\\\\'::::'(0.//~,t\~V\ M~~~4~ ~~$~- - t~ ~ .4<-- ;4.44 ~ . '-I,',"""'",,',,"" ~~, ~',~,"~" "",",,,'''''','''''~''~' """',~""',"J<,~,r',""e",,, <.,~~ ,~',",' ',~ .' '~.y<, "- ".1 '0 ~-~ 1t ",. ~-~.~ p~ .- lij: !: p~ ~ 'I /' , , ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHARLESA.SATTERLY Plaintiff, CIVIL ACTION - LAW VS. NO. 2001-02043 BARBARA A. SATTERLY Defendant. IN CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND Rhonda R, Wolford, being duly sworn according to law, deposes and says that on April 24, 2001, true and attested copies of Complaint for Custody together with Order of Court were served upon the Defendant, Barbara A. Satterly. Manner of service: by mailing the same postage paid, certified mail, addressee only, and return receipt requested, at Shippensburg, Pennsylvania, addressed as follows: Barbara A. Satterly 150 Rustic Drive Shippensburg, P A 172857 ~ci~ Sworn to and subscribed before me this 25th day of April, 2001. 41, ;:,. /2 ~fh-<j 0 Notary Public . ,." __~.o '~."""~" _..,- f_ L ',,:,,,~> " .- \F- " / -'/ /'""v, ,~o ,'-'- ;; ""- .- ~ ',;::: \~ "~"'.t..- _ j---,:.:.~,- ':"'>."-:-'."';\'.\ \ ~':: - < ~ - :'--.;, I>....-~ .... " Notartal Seal ' Patricia L. Tome, Notary Public Shippensburg Bora, CumbertandCounty My Commission Expires June 7, 2004 r,,:" '~1" -~- "<,.,,- -/'-~ ,.~ ._-~:~';~"~~~;~~:~/~' >/"-'.~~~~,~~~:~~~~f~~""& ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397 ,'''~''...'.'''m__ ","",""'.... I" II .:Ilr L I I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHARLES A. SATTERLY Plaintiff, CIVIL ACTION - LAW vs. NO. 2001-02043 BARBARA A. SATTERLY Defendant. IN CUSTODY PROOF OF SERVICE I:] I'T1 :r IT" RG p~ 17257 .--=t Postage $ I'T1 r-==I Certified Fee -D Return Receipt Fee C (Endorsement Required) I:] I:] I:] $1.90 $1.50 0257 05 Postmark H'''' Restricted Delivery Fee (Endorsement Required) $3.20 Total Postage & Fees $ $7.15 0412312001 t:] I"- ...II Recipient's Name (Please Print Clearly) (to be completed by mailer) ..... _ f.l:,r. r:ba.((\.__..A,..~a.-\::\e.cl>l.mm.mm..mm............." ~Apt.~orpOBoXNO. , .I~~LJS.\,l~';\\\.\'...m_J:x:J_y'g.....m..m...._..............___m__.. .C ,State, ZIP+4 ~ ',--- -'-," . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card tq the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Addressee es No 3. Service Type ~rtified Mail" 0 Express Mail o Registered J51cAeturn Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 2. Article N!JlIl1D~n(CO@Y~q1:sefViC&:ab~!l.:." '. " . ~~~~~~.C.iPt ~O-('bo.f<l (J... ~1A.H~cl~ tso ~l.\.5.-\-;t- lX,ue.- ~~\fpens.bW'<j ~f1 IY)"dS1 Yes"' :__Pi , "nya.-A 1025~5-00.M-0952 ... -- -~'-~_.~~,--~~ WEIGLE. PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 '~ ", ~ ,..... ~o r~~':--~~' ,",I~-"W "', ~~:~~.~Rl~:~ ~:~~,: I, 'I - ;,'.1 I I ! [1 ~ I ;1 ~. ! ij " ~ K ~ " .. ,~-" ,- '" " '" ,'","'H'P "'c"!:"":'r'"F"'\ ".".,,,, """ - T- - , 'JiiiI. -~ ~ ,~'.'; *,' J,-o .!" .o~,__R~~~~rr.~f:",}k: '/l;,,"- ; (") co 0 C -n ~ Po ~:j v eLl " ~';iiIl mo:: ::u Z...<_. N ~~ z!J: (.1)2: O"l -<~,~ <0 ;::.. SC) 3: ~-'(J --0 9 'C:"n Pc .-0), "=-0 ~ w ~ co -< ~~Wlmi~~~1 ilrn~?~I,,;,,_c >--,','":'c,, _ - . ... JlJ/I; t IMn1 tJ" CHARLES A. SATTERLY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO, 01 - 2043 CIVIL ACTION - LAW BARBARAA. SATTERLY, Defendant : IN CUSTODY COURT ORDER -rl:, AND NOW, this 51 day of June, 2001, the Conciliator being advised that the parties have reached an agreement, the Conciliator relinquishes jurisdiction. BY THE COURT, Q#-~ Hubert X. Gilroy, Esq . Custody Conciliator "F""",,, ~. -';";'~ ',,'--j-- "\'0_,.'= .~y _1,,:"":_ < "",c,._,,,,.,~ ~""'" r 1'-"~,-~~~'-' ~,_ '!II'liIlIlI~ "" 9~ , .~- ~,~ - ,L, ! "'" ,'_,,' 0 ",' " ~ -"w'~ ,'~<'.". .-, ,',. .""""~ 'dIN\f!\lASNN3d }J.NnO') (j!\!\nHj8V~m n^'\ 0' I'''' \,.' : 1 i") S\ tmf \0 AHV1C>;:~'H:.C ,,;'[ ~J\,YD"; , :~l :2'.J , L~l w~~ l" I r J~ll'^~"iMl'lnE\i~'I',t~li?<':i,.-~,<ft",Fk!;!~~,~~~~". ~1 ~.,~~lWt II , , .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHARLES A. SATTERLY Plaintiff, CIVIL ACTION - LAW VS. NO. 2001-02043 BARBARA A. SATTERLY Defendant. IN CUSTODY STIPULATION AND AGREEMENT This Stipulation and Agreement is made this 611'1f\ day of May, 2001, by and between Charles A. Satterly, of 1553 MainsvilJe Road, Shippensburg, Franklin County, Pennsylvania, (hereinafter referred to as "Father") and Barbara A. Satterly, of 150 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania, (hereinafter referred to as "Mother"). 1. Charles A, Satterly and Barbara A. Satterly are the natural parents of Cory A, Satterly, born May 3, 1991, hereinafter referred to as "the child". 2. Charles A. Satterly has initiated a child custody action in the Court of Common Pleas of Cumberland County and the parties are currently subject to a temporary Order of Court and Directive for Conciliation with a pre-hearing custody conference scheduled for Thursday, May 24, 2001, at 9:30 a.m. 3. The parties desire to continue generally the pre-hearing custody conference scheduled for May 24, 2001. 4. The parties have reached an agreement with regard to the custody of the child, Cory A. Satterly, and desire to reduce their agreement to an Order of Court. NOW THEREFORE, the parties intending to be legally bound and waiving their right to be present when this Agreement and Order are presented and executed hereby stipulate and agree that the Court may enter the following Order of Court in the above-captioned case: ORDER OF COURT NOW, , 2001, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 li1~"."lfJ!1~ "..~"__P"',f:"'o__' 1..'_ ^ , " , .. I. Charles A. Satterly and Barbara A. Satterly shall have shared legal custody of the child, Cory A. Satterly, born May 3,1991. 2. Charles A. Satterly and Barbara A. Satterly shall have shared physical custody of the child, Cory A. Satterly. 3. Father and Mother shall share all educational and medical information concerning the child and shall keep the non-custodial parent advised with respect to any medical emergencies. By the Court, J. The parties further agree that, in procuring this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part ofthe other. IN WITNESS WHEREOF, the parties, intending to be bound by the terms and conditions of this agreement, execute this Agreement by signing below. ili,.,.;...,~.T~.o Witness cff~y l:,~;(f~J ~~.~ ARBARAA. SATTERLY By: Respectfully submitted WEIGLE, PERKINS & ASSOCIATES 9)~ a C?~ David P. Perkins, Esquire Attorney for Plaintiff Attorney J.D. #34342 126 East King Street Shippensburg, P A 17257 Telephone 717-532-7388 WEIGLE, PER!<INS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 1~,HU ',' ~~, , , " . " . I verifY that the statements made in this Stipulation and Agreement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, Dated:/Yk( zl ~( ~~ CHARL A. S TTERL Y I verifY that the statements made in this Stipulation and Agreement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to falsification to authorities. Dated: <&. ~'l-C)I ~[\. s..~ BARBARA A. SA TTERL Y WEIGLE, PERKINS & ASSOCIATES - ATTORNEVS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257~1397 ';'~:J~!, I"" ,,_ ,..r, I'" -~^.~ " -"'~1iI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHARLES A. SATTERLY Plaintiff, CIVIL ACTION - LAW VS. NO. 2001-02043 BARBARA A. SATTERLY Defendant. IN CUSTODY ORDER OF COURT NOW, \U'" '-z.o , 2001, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: I. Charles A. Satterly and Barbara A. Satterly shall have shared legal custody of the child, Cory A. Satterly, born May 3, 1991. 2. Charles A. Satterly and Barbara A. Satterly shall have shared physical custody of the child, Cory A. Satterly. 3. Father and Mother shall share all educational and medical information concerning the child and shall keep the non-custodial parent advised with respect to any medical e encies. ,--- / BY7~' . \ J. / ~pl~.s rndllUC -6 ~ '~!us ducLj)€:PI. B~a~ {J'~"1l<ii'4.L1" ~~{ JOI WEIGLE, PERKINS & ASSOCIATES ~ ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 -,~," ~'" ','" ,--"'- " ';,1'''''-,''' It, ,'- " ' 1~~ &tJ ~d f,. . ly1N\f;1~ )J.l\f;.r!:J.~./ A~~,~YN9d - ':', jJ.j-,(",/, . , ~~"'ln-) " "-'11J . '- ". r /' -() " .... y '(J to_'~r "'I:!- llie,!., 1\'-.i\I~~C:J I ?,,-, '- Iii if fO ~~h .~SI!m!1ffflmlll'l_f,iffiiil~ .'=',,'- .'~ ~= 'A' 'n-~~--~' '> - .- ""'--~"'". -'<", ,~. '-"<,,",,:;-(,,,;0',"-," -I~ ~"",~ .","r\' ,.~o"".fJ~~~t;!l'\'-'J!,!!~i'f.jf1'~i,"'~:-m",f~R:0"'f\~l'l!i~~~"81iEi!1ll1~i~~~~~", ;,1. ...i