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Home My WebLink About01-2721 FX r~'~'" ~^ _,I .~ , -,'i; -" CLARK T. GODUSKY, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 2001. J7J-/CIVIL TERM BEVERLY 1. SHUTE (GODUSKY), Defendant : CIVIL ACTION. LAW : 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 , Pennsylvania, on the day of , 2001, at o'clock _,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 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 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 HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1.800.990.9108 'dW~ LL ~..,- -- l' ~~, ' -- CLARK T. GODUSKY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2001-). 7 LI CIVIL TERM BEVERLY 1. SHUTE (GODUSKY), Defendant : CIVIL ACTION. LAW : IN CUSTODY COMPLAINT FOR CUSTODY L Plaintiff is Clark T. Godusky, an adult individual currently residing at 12 Belle Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Beverly 1. Shute (Godusky), an adult individual currently residing at 7607 B Weatherworn Way, Columbia, Maryland 21046. 3. The Plaintiff is the natural mother of the child, Brittany Godusky, born April 28, 1986. 4. The child was born in wedlock. 5. For the past five years, the child has resided with the following persons at the following addresses for the following lengths oftime: NAMF AOORFSS OATFS Clark Godusky 12 Belle Drive June 2000 to Brenda Godusky Carlisle, P A present Beverly Godusky Oregon July 1997 to June 2000 Beverly Godusky Maryland July 1997 to 1996 6. The natural Mother of the child is the Defendant, who resides as foresaid. She is single. ~.~ ~~ -~ ~ ~ " ",'-' 7. The natural Father of the child is the Plaintiff, who resides as foresaid. He is married. 8. The relationship of the Plaintiff to the child is that of natural Father. The Plaintiff currently resides with his wife, Brenda Godusky, a daughter, stepson, and the child at issue. 9. The relationship of the Defendant to the children is that of natural Mother. The Plaintiff currently resides alone. 10. The Plaintiff has no information of a custody proceeding concerning the child pending in any Court of this Commonwealth. 11. The best interest and permanent welfare of the child will be best served by granting the relief requested as the Plaintiff is better suited to provide a stable environment to foster the child's well being. 12. The Plaintiff does not know of any person not a party to the proceedings who claims to have custody or visitation rights with respect to the child. WHEREFORE, the Plaintiff, Clark T. Godusky, respectfully requests this Honorable Court to enter an Order scheduling the Parties for a Custody Conciliation. Respectfully submitted, Date: s- ] -0 ( mas S. Diehl, Esquire Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240.0833 ~~_-.,. _b"... ~"'<. ~ ~ L ~ ~'"~ ". .~~ jrBitob-; VERIFICATION I verifY that the statements made in this Complaint are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904, relating to unsworn falsification to authorities. cJ~ CLARK 1. GODUSKY, Plaintiff j~ " ."..~" . .1 - - - it ,,.....~ 'n "~ikf t CLARK T. GODUSKY PLAINTIFF V. BEVERLY 1. SHUTE (GODUSKY) DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA 01-2721 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 17, 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 Couuty Courthouse, Carlisle on Thursday, Juue 07, 2001 at 8:30 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 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 the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Hubert X. Gilroy. Esq. {;C 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 TIllS 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 - --,,- n~~_l-" "'-'-IT~1' Uili1t'BlifuY.A!i!fuili.Hliil!!B:P"",}!i,,"!l!!t;l:~,A4i~#\f,Wlfilliii1!,---'JW&l-.f;\;ji~,*');!i" l~,ik",,""f-,',"i'l, "f~"i\t'-",,--1,iM~~~_"'~ 1b :_,HJl!f I ~ ~._~ ~ ~.~ /tl-;t/~ '- :;Jfp ~ ~ ~~ /{/.~/? /r:a ..~ t ~1V ~tl'~ /(;?'~/F \1\t'~'-d;\l,lSNNjd ,,' , ',,, r'l\ .-,!r\"'l"] 1, I....' 1.....I'i (1,\ .,. \-1~, ,,,~r,, i \' /,_j\l\ ".,,/ ' ,,", ',' '-,:_-,-", - ~ -, !1 \ Zt1 :c: ',,:0 Dl,', \D }\t\V1C"::=:,",--':i-",-' ~ ,", _~,"~_, ~ ,,,W,",, ,. '" _~" _ ,~>-'~_, ~,~ ,. .. _ ,'" c, -- ~" ~ f. ....... CLARK T, GODUSKY, Plaintiff JON 1 1 ;:Lilil~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION. LAW BEVERLY J. SHUTE (GODUSKY), Defendant NO. 01 -2721 CIVIL IN CUSTODY COURT ORDER AND NOW, this JJ.f\t. day of June, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The court determines that Pennsylvania and Cmnberland County have jurisdiction to enter a custody order for Brittany Godusky, born April 28, 1986. 2, The Father, Clark T. Godusky, and the Mother, Beverly J. Shute, shall enjoy shared legal custody of Brittany Godusky, born April 28, 1986. 3. The Father shall enjoy primary physical custody of the minor child. 4. The Mother shall enjoy liberal periods of temporary physical custody with the minor child as agreed upon by the parties. Specifically, the Mother shall be guaranteed time as follows: A. Por a planned trip to Portland that is scheduled for June 15, 2001 for a period of at least two weeks. B. Por at least two other weeks during the summer months for a period of vacation as long as Mother gives adequate notice and those weeks do not interfere with Father's previously scheduled vacation and the child's previously scheduled cheerleading camp. C. For alternating weekends from Friday through Monday. When Monday is a holiday, Mother's periods of time shall extend through Monday. D. At such other times as may be agreed between the parties. 5. Mother shall enjoy reasonable telephone contact with the minor child when the child is in the custody of the Father, and Father shall enjoy reasonable telephone contact with the minor child when she is in the custody of the Mother. "-- , "",-- _~ '0'"', _ ,_:''''<''_. '"'~j",, ,.-", ., "-- ",,~, , "' 'r:'.;"-" ""~," '" ' ' " "'--,,,,-!dcii,~: " . 6. Mother shall handle transportation for exchange of custody unless agreed otherwise between the parties. However, Mother's obligation for all transportation is based upon the fact that Father has not instituted a support action against Mother. In the event Father does institute a support action Mother, Mother may ask the court to reconsider this issue and at that time request that Father perform all or a portion of the transportation for exchange of custody. 7. In the event either party desires to modify this order at any time in the future for any reason, that party may petition the court to have the case again scheduled before the Custody Conciliator for a conference. 1. cc: Thomas S. Diehl, Esquire ir:OI aJl ~j Beverly 1. Shute 7607 B Weatherworn Way Columbia, MD 21046 '.:~_-"', ..;,o-".~1l'~~II:Eiblt~illllill._~fu,.m*.<,;,}ffii,~~~Iil* '{lNn~:jvJ~~8t(~{3d "":' rf-i-r!!l!Ir"I ^ -.),. H ;'J 9c :f' '. v /-./_.,~J '" , . /1 '~:."'n --' j' ~11i / {'l . ,I AINu-"" , V~l;j!',-; ,::/~l -:,~J1L-,~~,r,;;,AJI,~t~,",-~~",~.. " ,,,,_ __'c ~ ~ ,"fl~~,>~_ ,,,.',,~~"'" '""__~" "wy~,"'~'=__'" -,','"'.. III '0 J:lili>i ~ ~'~ ~"" '1'1 ,,' ,'l.C.'''';L ~ - - ,,"-~ ~ j, i I ~ .. " n' .--. " -- ....-' ~," - ,. ~"'--"---:' -- ." , - '; -,,~,_ ,--',,-,,-, ,cO, -' ", <~_'~',',_._, .. i CLARK T. GODUSKY, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BEVERLY J. SHUTE (GODUSKY), Defendant NO. 01-2721 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 information pertaining to the child who is the subject of this litigation is as follows: Brittany Godusky, born April 28, 1986. 2. A Conciliation Conference was held on June 7, 2001, with the following individuals in attendance: The Father, Clark T. Godusky, with his counsel, Thomas S, Diehl, Esquire; and the Mother, Beverly 1. Shute who appeared without counsel. 3. The parties agree to the entry of an order in the form as attached. ~ ( 8(0 I DATE ?)t~ Hubert X. Gilroy, E Custody Conciliat