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HomeMy WebLinkAbout01-03755 "- ~, -~.,_ ~~_L~ ~ , '^-,l.. , .. . AMBER J. SHUEY, Petitioner It~~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA -to STEVEN J. WARREN, IC\: Respondent rl ft; NO. 2001-3755 CIVIL ACTION - CUSTODY ORDER & RULE ANDNOW,this ;r1aYOf O~ , 2004, upon consideration of the within application for special relief and on motion of Jerry A. Philpott, Esquire, attorney for petitioner, the following relief is hereby immediately ordered, pending a hearing on the.;1~""^ day of_ ~ ,2004, at 1(),'O$clocJJ!.m., prevailing time, in Court Room ~ of the Cumberland County Courthouse: lJB.tU It,uu:""'e, ii1HBBB.tl, J_nlhL. 1. BL."u.'J' ~h."H hAno- iJ.Jh., ~JiJl...cd ...u"..udJ' ~"}"iJ" I lE;"pUnd"lU "' lit "..~u.&" ~"t illaMlto'R talUB ki... Y~J ..cL.....b. UP"'; mewcanons flL ..Ii__ h.... 1.._8 'Ill Cot} __...l.....d.y. -=.i <-'''"'''''j" (f J, 0.' _"'_ .( - _c',," t, . r AMBER J. SHUEY, Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. NO. 2001-3755 STEVEN J. WARREN, Respondent CIVIL ACTION - CUSTODY PETITION FOR SPECIAL RELIEF PURSUANT TO RULE 1915.13 To The Honorable, the Judges of the Said Court: Petitioner, Amber J, Shuey, by her attorney, Jerry A. Philpott, Esquire, files this petition pursuantto Rule 1915.13 of the Rules of Civil Procedure and respectfully represents the following: 1. Petitioner is Amber J. Shuey, who resides at 180 Hunkey Hollow Road, Duncannon, PA 17020. 2, Respondent is Steven J, Warren, who resides at 420 Ross Avenue, New Cumberland, PA 17070. 3. A custody matter is pending at the above docket number. Under the existing agreement, Matthew lives with his mom, petitioner, and visits his dad, respondent, every other weekend. 4. Matthew is under psychiatric care and has had psychotropic medications prescribed. Therapists and school counselors have advised that he has substantial emotional and learning disabilities. His father does not believe he should be taking psychotropic medications, For example, when the pharmacy accidentally mailed the medications to father, he refused to even give them to mother, who had to order a duplicate prescription. 5, Attached hereto as Exhibit A is a note from one of Matthew's therapists at the . ., ,",', , ~j,~" - , ,- -, "'''"1~!Jl.'l:.\},~~' Stevens Center to the effect that Matthew not taking his medications on a regular basis is a hindrance to Matthew's mental health. WHEREFORE, your petitioner respectfully prays that this Honorable Court for an order terminating father's alternate weekend partial custody unless father will ensure that Matthew takes his medications when he visits his father. In addition, after hearing, or - if the matter is submitted for conciliation - petitioner will seek an order that respondent participate in family counseling with Northwestern Human Services at Steven's Center, which will cost the respondent nothing. Dated: October 22, 2004 ~~~ ~Q~ 1 Oc~ 20 04 07:55p DOUGLAS A SHUEY t~T-2~-26Q~ e6:~e PM RAY~OHDwL.HOFFMAH ,',:..;' "I."""~-~lI\!'!)' "tit'a.''''-'':;1i~-"- "~~~~,, i(, :":"l'!$~J .ilio~ :J~c! . ,.\t;".:i ?' -;:::t':l To Wholtllt May CoticmJ: '. . ;'., i:j 1lll1l writing Ibis lelter~~th reguds to Mr. Matthew Warren. I am pArt oftbe fam!!y based menl8lliealth ~ces t~ who is wmiting with him and his family, We N H II .~... <f' n'. 7178343484 TIT 624 994' 1011912004 ~"., ~ :::.~. " ~~~7- have been wOlting wifh him !ince October 6, 2004. IMatthew lives with his'mother, step-titther, :and step-brQther, He goes 10 his fAther'. home spproo:imately two lime. per month. it ha$ be1lO\ brought \0 my lllWntion !hat when he i. It hi, filth",.' s horne,. he does net take his psychotropic: medications all p"""cn'bed by the doctor, This i. becauSe Mati's father believes he does net need them. [n the mort time I have been working with Matt. it """"". 10 me AS ifMau functions better when he takes his medications, Matt !wi also stated mat he feels better when lie tal<es them. Matthew's mod1er i. CllITentiy reviewing issues ofwbat happens when Man is at h.. father', home :and whether they help or hinder hi! mental health. It i. my opinion !hat Matt not taking his mcdicatiOllS on .. regular ba.'Ii. it " hindrance to his mental health, Sincerely, Trend A Harman ,/\~ ~.1k~ Trend Harmon r~ORTHWESTERN HUI.IV\N SERVICES ~:.! EVEr--J '5 CENTER 1:,~!~\II.Y_8~SED SERVICES ._',,~ :'lTAIEh\!f:NUE CARLISLE, PA 170; 3 ~-888.243-!)1.};3,3 exf419 i'_dll:5J4-6754 p.l P.Q! ! ~ " ,.r~;::'!-' .' r" " :~fi.:' 1.'(:01: r.L~~ t~ "1~::!1 ,." ~ ."".. ~~ ,-. To' ~,_,_ ,--,'. ;, "-""-'.,,-, ,"-': [Ii '--Ji.l..d~~~ I verifY that the statements made in this Petition for Special Relief 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, ;.' ii"'jj-'-'''':-'. 0:~'~~";-""""ii!L'Ir~IliiW~""'i;(]j,""I;h}-!L'B'futt;;,,,,0_W~~~t~i'!I:iili*~ _l'~,~.."",,,,,,,,,,>, .'~ "' ,......1'.;-,.~~~" ~,,~" ~ ,I II C:I '" l-~ ~ C::Jo C~. C;J -' l ~ .'1". C) --\ "'""f-' (-) t11?~ ~ ~ ~"l r,) Jjt? r'0 ~ ~ \ ',~() ~-~~ +:r~ "- _>J.. ~)(~ '\:. c5 ;"'-,';,("'1"1 ~ u ~ . "....1 '-.J ~. (,J ;;~~ ,.',-, ". I",t) ~~ "' ~-",'-=_.,- ~,~"_",=~,__<,~ '-""_"~O" '-" _.~-',",,,, ~-" , .". ", ~"~- ... - , -, , ,.,,,,,L I ",. ~ -. - .~ " STEPHEN J, WARREN ; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. AMBERJ, SHUEY : NO. 2001-3755 CIVIL TERM CUSTODY - CIVIL ACTION STIPULATION AND ORDER OF COURT AND NOW, this 16TH day of JULY, 2001, counsel are present today to enter the following stipulation and order of court, natural mother Amber Shuey will have primary physical custody of Matthew and Tiffany Warren and natural father will have periods of temporary physical custody on alternating weekends from Friday at 7:00 p.m. until Sunday at 7:00 p,m. The first period commencing Friday, July 20,2001. This is a temporary order until the Custody Conciliation Hearing scheduled for Wednesday, August 1,2001, at 10:30 a,m. before the conciliator, Jacqueline M. Verney, Esquire, By the Court, Thomas S, Diehl, Esquire For the Petitioner 'A~ dE. Guido, lS -nf rn ,.. ~ :::-:::: ~:. ;C,':I' c,::-, ~~~ Jerry A. Philpott, Esquire For the Respondent -"r',. ~:_'" ( ~-'(- .- -. : sid ~ _ ,h ,lt~!'~ ('., . "-' .--\'! :.,) ~ ,'~h ~, , "",-1/ . -,.,- L<~ _..._',", -,'.J ,', -'--"I'ilji~'/t~1 MISLlTSKY AND DIEHL JUL 9 - 2001 JilL Q - ?nDL ONE WEST HIGH STREET SUITE 2.08 P. O. Box 12.90 CARLISLE, PENNSYLVANIA t 7013 (717) 240-0833 , ""'-...' THOMAS S. DIEHL RICHARD p, MISLITSKV* KIMBERLY L. HOUGH LEGAL ASSISTANT 14 NqRTH MAIN STREET SUITE 550 CHAMBERSBURG, PENNSYLVANIA 172.01 (717) 261-0208 KATHIE J. DIEHL LEGAL SECRETARY (717) 2.40-0893 - FACSIMILE REPLY TO: CARLISLE FILE No. 01173 July 6, 2001 VIA FACSIMILE (717) 834-5437 & FIRST-CLASS MAIL Jerry A, Philpott, Esquire 227 North High Street P.O, Box i 16 Duncannon, P A 17020 RE: Warren v. Shuey No. 2001-3755 IIll Custody Dear Attorney Philpott: Please find enclosed a copy of the Order of Court scheduling the above parties for a hearing before the Honorable Judge Guido on Monday, July 16,2001 at 10:00 a.m. Pursuant to our telephone conversation earlier today, it is my understanding that you have received a copy of the Petition for Special Relief and Complaint for Custody from your client, Amber Shuey, and are accepting service of the within Order on her behalf, Thank you for your assistance in this matter. rours, j/ a//-1 ;- ! i // L-..---'"' " Thomas S. Diehl TSD/klh Enclosure cc: Stephen J, Warren *CERTIFIED AS A CIVIL TRIAL ADVOCATE BY THE NATIONAL BOARD OF TRIAL ADVOCACY A PENNSYLVANIA SUPREME COURT ACCREDITED AGENCY J? -,. ",,'-~ J. - , _,.~_ '.0" ",-,_.d,J -, -'";~_ l-- .' "---C:':"",-".C;-_,:, ,_,'_ ---"jili["1 , , ! STEPHEN J. WARREN, Petitioner v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-3755 CIVIL TERM AMBER J. SHUEY, Respondent CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 20th day of June, 2001, it appearing to the Court that Petitioner was unable to effectuate service, the hearing on the attached petition for Special Relief is rescheduled for July 16, 2001, at 10:00 a.m. Petitioner is directed to serve a copy of this order and the petition upon Respondent at least 10 days prior to the date of the scheduled hearing. By the Court, Edward E. Guido, J. Thomas S, Diehl, Esquire Attorney for petitioner srs " " ';'. " "I~ ..' .~'~"'" STEPHEN J. WARREN, Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001-3755 CIVIL TERM AMBER J. SHUEY, Respondent CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 20th day of June, 2001, it appearing to the Court that Petitioner was unable to effectuate service, the hearing on the attached Petition for Special Relief is rescheduled for July 16, 2001, at 10:00 a.m. Petitioner is directed to serve a copy of this order and the petition upon Respondent at least 10 days prior to the date of the scheduled hearing. By the Court, Edward E. Guido, J. Thomas S. Diehl, Esquire Attorney for Petitioner ~ -dL I, 'tuh-R cI (,J- lC -01 srs " !i 1'; I'; ,:1 ;~ I :<l - e~4 ~,.,.,. 11 JJ.~~" _ IW8J]~_Ik}J J _ 01J1f:]?U ,-- ~ - ]: n3 CUMDCi'iU,iL) c;CdNTY PENNSYLVANiA ~_"Ii~~' -~'-i!<~~';'~"",~I}H;4iWi,,~;'(i"\'fi"''l'',-W1l'Jt~'4io/'l:j1l1ii'\W''~*)$;li/;ii!il@;:,,,,,)tii:~,,,W_~~1.~~~ " ~ ...'10. " )t-"I'" . . STEPHEN J, WARREN PLAINTIFF V. AMBER J. SHUEY DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-3755 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, June 20, 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, July 18, 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 schednled hearing. FOR THE COURT, By: Isl Jacqueline M, Vern0" Esq.tt) 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 ATIORNEY AT ONCE, IF YOU DO NOT HAVE AN ATIORNEY 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 _' _ '0 " "',1 '" _-~' .___"",_~~"." ",." -~~~ . . "'~-, "'~,~-_.~. -". M..,.,"_~_",_"," ':IIi: \--;~~[jP\l '"II 01' Ifl',).... , ... 0U t f 2:Sp ~ cup", t1riht.L/ -'.' -, -~~< ,1.../-1 '(-\J' "',< 'I' PENNSYILV,j 1\j~}jNTY '11/ it\ 6'dl-CJf ~ ;;2/-,:::Y ~ ;21-cJ1 M~~$a(-~ ~~~ ;;~' ~~~4~b# ,.! I; .!i.",' " :: i' '1 'I il ,I , . : ~ &" l1_'JIt.&fW1 n _'1::l~~jlHl\ll~~$l!!~1!!1~'M!~-"'-"-"'_"';!i~!~:\;~""~;"!'''''_ji''k;:-'x_, ';-;'-1l1"".;;:-'I<'flfl!~~;\I.~~.I<!,'ii!!~!!!r!'i:~_\';:'i~~iIi!'t_~~ '-,"- L "_., STEPHEN J. WARREN Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO,2001-37:i'S CIVILTERM AMBER J. SHUEY, 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 I 10 . """'~-I""ili~W,: STEPHEN 1. WARREN Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001- 37).~{ CIVIL TERM AMBER J. SHUEY, Defendant : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY I, Plaintiff is Stephen J , Warren, an adult individual currently residing at 315 Shed Road, Newville, Cumberland County, Pennsylvania 17241. 2, Defendant is Amber 1. Shuey, an adult individual currently residing at 180 Hunky Hollow Road, Dnncannon, Perry County, Pennsylvania 17020, 3, The Plaintiff is the Father of the child, Matthew Allen Warren, born July 19, 1989, 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 of time: NAME Stephen Warren A DDRFSS 315 Shed Road Newville, P A D A TFS February 2001 to present Stephen Warren New Cumberland, P A 1999 to February 2001 Etters, P A 1998 to 1999 Stephen Warren 6, The natural Mother of the child is the Defendant, who resides as foresaid. She is married. .,. I J.";' " ~ft-~;,~,_ 7. The Father of the child is the Plaintiff, who resides as foresaid. He is single. 8. The relationship of the Plaintiff to the child is that of Father. The Plaintiff currently resides with his fiance and the child, 9. The relationship of the Defendant to the child is that of natural Mother. The Defendant currently resides with her husband, 10. The Plaintiff has no information of a custody proceeding concerning the child pending in any Court of this Commonwealth. II. The best interest and permanent welfare of the child will be best served by granting the relief requested as tbe 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, Stepben J. Warren, respectfully requests this Honorable Court to enter an Order scheduling the Par1ies for a Custody Conciliation. Respectfully submitted, Date: ra-tfJ-[)( omas S, Diehl, E quire Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 " "- .,j, J. o~_i/illialili~Ij[:,;(", VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C,S. S 4904, relating to unsworn falsification to authorities, ~uJ. --..... I ..J ,',.1. ,- i'~~.t-c',:, STEPHEN J, WARREN : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. AMBER J, SHUEY : NO. 2001-3755 CIVIL TERM CUSTODY - CIVIL ACTION STIPULATION AND ORDER OF COURT AND NOW, this 16TH day of JULY, 2001, counsel are present today to enter the following stipulation and order of court, natural mother Amber Shuey will have primary physical custody of Matthew and Tiffany Warren and natural father will have periods of temporary physical custody on alternating weekends from Friday at 7:00 p,m, until Sunday at 7:00 p,m, The first period commencing Friday, July 20,2001. This is a temporary order until the Custody Conciliation Hearing scheduled for Wednesday, August 1,2001, at 10:30 a.m, before the conciliator, Jacqueline M, Verney, Esquire, By the Court, , /J J., :sld 1-/(r 0/ to ~.. r-S h/"\ y. ..lEA -fa C () I.A hS E; L ' Thomas S. Diehl, Esquire For the Petitioner Jerry A. Philpott, Esquire For the Respondent "j ^'C ~ ,. l..' .. ';"'--'n-"--'"',.;iO[ STEPHEN J. WARREN Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO, 2001- J'7s-S-CIVIL TERM AMBER J, SHUEY, Respondent : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 19.,nday of Uti ~E... , 2001 upon review of the attached Petition for Special Relief, this Court sets a hearing in this matter for ~ ~ day of V-:"'lI.tl.. , 2001, at ;...: (} () o'clock w~. ,the J:l .m" in Courtroom Number 6" of the Cumberland County Courthouse, Carlisle, Pennsylvania, - f-cllA~ruI. E. Cu.: Id J, , / 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 ;X~ 2 LIBERTY AVENUE * CARLISLE,PA 17013 A\;Y> ~ ~ (717)249-3166 to\" .l 0\ 1-800-990-9108 V,r ,-" ::","",_,"";",;,.,,~ _ '.' JfitH _ _ j.~I!~'i!l. ~._ = ." '- "'''''ii Of: F:i " !-" '-'-.,<~::2/~'9Cc: h 0149'" "11 I /), L'J' II" t..., i'"I, -,,'.; 19 /-I,' ell! ,; 'JOt,,- lIit .',-,>. <,. ^; c.. V/C;:::.i~" ',,' . \,,1 f~-' ,L<,-,}, /,-) CiVil"" "iJ {""I 011.!?i~',~u)Vry 'iitA tH~I~jllm..-J.. _ ."W'J:JA1__'"",_"",_ .~""~ ~*'lrlM"imJttfW:,,"!,%~~,ir"'7d€ij,tNE\/f;k';l?'{<;"~~.n1ti~~~~;mw~~~~\i': ,~~' J, ~~ , . -~~,'lh-, STEPHEN J. WARREN Petitioner v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 2001- ..s'7.s-S-CIVIL TERM AMBER 1. SHUEY, Respondent : CIVIL ACTION - LAW : IN CUSTODY PETITION FOR SPECIAL RELIEF 1. Petitioner is Stephen J, Warren, an adult individual currently residing at 315 Shed Road, Newville, Cumberland County, Pennsylvania 17241, 2. Respondent is Amber 1. Shuey, an adult individual currently residing at 180 Hunky Hollow Road, Duncannon, Perry County, Pennsylvania 17020, 3. Petitioner incorporates the pleadings a set forth in his Complaint for Custody, which is attached hereto and referenced as Petitioner's Exhibit 'A', 4. Said attached Complaint for Custody was filed contemporaneously with this Petition. 5, There is no existing Custody Order between the parties, 6, Petitioner believes that the absence of a temporary order is contrary to the best interest of the childfor the following reasons: (a) The parties of this action were separated and divorce in 1996; (b) The parties' child, Matthew Allen Warren, age eleven, has resided primarily with Petitioner since the parties' divorce; (c) On June 12,2001, Respondent advised Petitioner that she was not going to return child to Petitioner. " ,~ ",'" L, - .' ""~ (d) Respondent stated that her reason for not returning the child was that the child no longer desires to reside with Petitioner. (e) The child at issue is aged eleven and is currently enrolled in Learning Support classes at school as his comprehension is at a fourth-grade level. (f) Respondent's refusal to return the child directly followed a Domestic Relations Conference held on May 17, 200 I, in which Petitioner sought and received an Order for child support. WHEREFORE, the Petitioner, Stephen J. Warren, respectfully requests this Honorable Court set an emergency hearing so as to set the parties' herein in regard to custody of the parties' child, Matthew Allen Warren, G-lg--o, bmitted, Date: ) ~ j)[; 1ll0mas S. Diehl, Esquire Attorney for the Petitioner One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 -- " ";' >.t.'~._--," ",-,- -'_l. J J, ,,~. t "-1- ~.'.k VERIFICATION I verifY that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C,S, 9 4904, relating to unsworn falsification to authorities, m!>.' . J -.L.._~ """- ~ H ~ ~'" " - "I~~} EXHIBIT A . ~ - ,~ .__, t~ ,- .I~:J _ .~ ~." _n ,., _,,'~ -, " .'~."" f:ii STEPHEN J. WARREN Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001- CIVIL TERM AMBER J. SHUEY, Defendant : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Stephen J, Warren, an adult individual currently residing at 315 Shed Road, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is Amber 1. Shuey, an adult individual currently residing at 180 Hunky Hollow Road, Duncannon, Perry County, Pennsylvania 17020, 3, The Plaintiff is the Father of the child, Matthew Allen Warren, born July 19, 1989, 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 of time: NAMF ADDRFSS DA TFS Stephen Warren 315 Shed Road February 2001 to Newville, PA present Stephen Warren 1999 to New Cumberland, P A February 2001 Stephen Warren 1998 to Etters, P A 1999 6. The natural Mother of the child is the Defendant, who resides as foresaid. She is married, ~ , ~ - -., " -, -J, .'," ,'~". ,,,I ",- , <_ I 'L~ 7. The Father of the child is the Plaintiff, who resides as foresaid. He is single. 8. The relationship of the Plaintiff to the child is that of Father. The Plaintiff currently resides with his fiance and the child. 9, The relationship of the Defendant to the child is that of natural Mother. The Defendant currently resides with her husband. 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, Stephen J, Warren, respectfully requests this Honorable Cour1 to enter an Order scheduling the Parties for a Custody Conciliation. Respectfully submitted, Date: ro~tB-"-6( ~ } ()l;' 'Trlomas S, Diehl, E quire Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 STEPHEN J. WARREN Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO. 2001- J'7.>S-CIVIL TERM AMBER J. SHUEY, Respondent : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this J9~day of.~L , 2001 upon review of the attached Petition for Special Relief, this Court sets a hearing in this matter for J. (JIA day of ~/\lL ,2001, at ;':00 o'clock wt-eL. ,the ,.tJ .m., in Courtroom Number;' of the Cumberland County Courthouse, Carlisle, Pennsylvania. - EdtAl~rz.A. E: CuI tld 1. . / 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 A VENUE CARLISLE, P A 17013 (717) 249-3166 1-800-990-9108 ,,~ - -~,lt~~~l' .~1\~41,W~Mi!flXB<'@.<.1i~~.~l~i'#f.f[,I,::.'.!;i!;lnW5i1 ,"" - \'i;i;~~~j,~~i'ii~~,,- . "~ "J ~...~_ "_ _",n _ ""'"-~~~~-!,,_, \, i AUG 0 2 2001 rfJ STEPHEN J. WARREN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA : NO.2001-3755 CIVIL TERM V. AMBERJ. SHUEY, Defendant : CIVIL ACTION . LAW : IN CUSTODY ORDER OF COURT AND NOW, this 1 i tl day of A v.J ~ c;,., + ,2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Stephen J. Warren, and the Mother, Amber J, Shuey, shall have shared legal custody of Tiffany Warren, born February 12, 1986 and Matthew Allen Warren, born July 19, 1989. 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, The Mother shall have primary physical custody of Tiffany. 3, The parties agree that Tiffany shall remain enrolled at The Hershey School unless otherwise agreed by the parties, 4. During the summer vacation from school, the parties shall have physical custody of Tiffany on alternating weekends from Friday at 7 :00 p.m, to Sunday at 7 :00 p.m., consistent with the regulations and schedule of The Hershey School. These weekends shall be coordinated with the alternating weekend schedule for Matthew such that the children shall spend the weekend in the same household. 5. During the school year, each parent shall have custody of Tiffany one day each weekend, at times consistent with the regulations and schedule of The Hershey School. 6. Mother shall have primary physical custody of Matthew until August 17, 2001, Father shall have partial physical custody of Matthew the weekend of August 4, 2001 from Friday at 7:00 p,m. to Sunday at 7:00 p.m. 7, Beginning August 17,2001 and continuing thereafter, Father shall have primary physical custody of Matthew in order for Matthew to attend school. While .2 Ii !i Ii II II !! ij II :1 il II II II I, !~ " !I ii..I. :~ '..'1. I~ " :11 .. I j - ~ ,-~ .~~-,"- _ lI.,.~__-,,_,___,u _ _~'-_,_ ,','-. ~- " '~""7_",~_'_'"->'.',v~ \.-_"''-i''._' ~_<'_ ,~ , ~ ~ c:: ~-L FL> ~I "', ~~~;Y"Ni~' (~,,~1, ':t. c;,rI II"' \ l~ t' .....,.~,..... 0\ M,)t? \,~ . I' .~, )\\1'1 CIJ'f';:HI !'~'.iJ UJ, I " ?E~1~1SYL)J ANIA ,~,~~~~~~~~~i!B'JP'1"':O---"'*~:W$,ij--)IiF-'~-;r";t"j'j"!~;~~~~1~W!~J{__~w,;:~,~)~;m~! . . , ""',",,...'~' . L J 'r~:\;>}i!<~",,4h.' '> I Father has primary physical custody, Mother shall have partial physical custody of Matthew on alternating weekends from Friday at 7:00 p,m. to Sunday at 7:00 p.m, with the first weekend being August 24, 2001. 8. The parties shall share transportation unless otherwise agreed. 9. The parties shall keep each other advised immediately relative to any medical care or medical emergencies concerning the children and shall further take any necessary steps to ensure that the health and well being of the children is protected. During such illness or medical emergency, both parents shall have the right to visit the child as often as helshe desires consistent with the proper medical care ofthe child. 10, Neither parent shall do or say anything nor let anyone in the children's presence to say or do any1hing that may estrange the children from the other parent, injure the opinion of the children as to the other parent or hamper the free and natural development of the children's love and respect for the other parent. 11. Both parents shall have liberal and reasonable telephone contact with the children when the children are in the custody of the other parent. 12. Both parties and those members of their households who the custody evaluator deems relevant, shall submit to a custody evaluation by an evaluator agreed to by the parties, The parties shall share in the costs of the evaluation, although Mother agrees to pay the costs with Father reimbursing her. 13. This Order is entered pursuant to an agreement ofthe parties at a Custody Conciliation Conference, 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. BY THE COURT, IJ< . J, cc: Thomas S, Diehl, Esquire, Counsel for Fat er Jerry Philpott, Esquire, Counsel for Mother ~ K.I(.ol ~ ~ . " ... J^~, _L ",'~~ ,~ .\ - .~, ~-" AUG 0 2 2001 to STEPHEN J. WARREN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA V. : 2001-3755 CIVIL TERM AMBER J. SHUEY, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido CUSTODY CONCILIATION SUMMARY REPORT .IN'.';'<;:CPRJ)MW.EWIl'IICUl\fIlERI,AND COUNTY RULE OF CIVIL PR<JCEDlJIU: 1915j:8;the';ll;,dersi~~dCusiody Conciliator submits the f~llowing report: 1, The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Tiffany Warren Matthew Allen Warren February 12,1986 July 19, 1989 Mother Mother 2, A Conciliation Conference was held in this matter on August I, 2001, with the following individuals in attendance: The Father, Stephen J. Warren, with his counsel, Thomas S, DieW, Esquire, and the Mother, Amber J, Shuey, with her counsel, Jerry Philpott, Esquire. 3. The parties agreed to entry of an Order in the form as attached, 8-/-0/ Date %.i ac eline M. Verney, Esquire Custody Conciliator ,. , IiJ =' ,~ .1 ."~1R;;;;o ; STEVEN J. WARREN PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 01-3755 CIVIL ACTION LAW AMBER 1. SHUEY DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, November 04, 2004 , 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, Cumberlaud County Courthouse, Carlisle on Thursday, December 02, 2004 at 9:30 AM 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 enhy 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 honrs prior to scheduled hearinl!. FOR THE COURT. By: Isl facqueline M. Verney, Esq. Custody Conciliator mho 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~~ < .~ '" ~~-"-" ~.,~- ~ -~-~ ..~" -,-" "'.' , ~ ~ ,~. _.~"' - ^, ^ , ,- ~~ ~<""'~"^~ - ~ ~, ~ <" F!LED-fJfF1CE C,; T...,1: D[)(jYUn'I'-'-I''''V . l.!.- lllv!' '\"/1"1) flJ-1. loa~ NOY -5 PM 2: 26 CUl'd3,H~,;;;) COUNTY Dr"i\;~_ 'e:' 'i 'lit ~ III 1 Ci 'lii\i,,)~' L'I.!hl\~)A w' ~~ '?J a:! ~;tt ~~z~ 1!5tJV~ ~~ a/f'.~.p, //s ~'I' 1/ :5 '&f ~i ,I [j ~I 'I 1'1 ~~ ~~it~llill:ljllllll r ,Wl~II_~~""~~~~,,.;10i',,~~~~f!5<j~""'~'V}FW'-'i"""''''.:e''i''_WW"'~'~fi~~IIlJ!I~~lfgr$l'l(jl~~~1~~~1 , '. ~ ,~ ~" "Ii-, ~~ '.__,r..' -'-:J:,^ "'-' 0tWlllBiililC'E"4 '-f AMBER J. SHUEY, . . I 1\,..1.-t Petitioner IQI:)I" I: ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO. 2001-3755 STEVEN J. WARREN, ( t:\ I liJ<' Respondent ,-VI.; CIVIL ACTION - CUSTODY NOTICE AND ORDER OF COURT You, Steven J. Warren, have been sued in court to obtain custody, partial custody or visitation ofthe child, Matthew. You are ordered to appear in person at , on , 20_, at .m" for [] a conciliation or mediation conference. [] a pretrial conference. [] a hearing before the court. If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. 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. Lawyers' Referral Service 100 South Street P. O. Box 186 Harrisburg, PA 17108 800-692-7375 or Mid Penn Legal Services 213A N. Front St. Harrisburg, P A 17101 1-800-932-0356 J -~ ~ '., _<.'.1-- ",- .~, ,. . L ~-J , ,- L '''< 1 'o"'..~.;[: AMBER J. SHUEY, Petitioller IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. NO. 2001-3755 STEVEN J. WARREN, Respondent CIVIL ACTION - CUSTODY PETITION TO MODIFY CUSTODY To the Honorable Judges of said Court: Petitioner, Amber J. Shuey, by her attorney, Jerry A Philpott, Esquire, files this petition and respectfully represents the following: 1. Petitioner is Amber J. Shuey, who resides at 180 Hunkey Hollow Road, Duncannon, PA 17020. 2. Respondent is Steven J . Warren, who resides at 420 Ross Avenue, New Cumberland, PA 17070. 3. On August 24, 2001, the Honorable J. Wesley Oler entered a custody order after a conciliation conference, a copy of which is attached as Exhibit A, splitting the custody of the two children as between the parents. Subsequently, pursuant to Paragraph 13 of the order, the parties entered into a written agreement after a custody evaluation that petitioner would have primary physical custody of both children, See Exhibit B. It does not appear that this was ever reduced to a court order, but the parties have abided by the agreement ever since. 4. Since the entry of Exhibit A and the modification by agreement in Exhibit B, the following substantial circumstances and facts have changed, giving rise to this petition: Matthew is under the care of a psychiatrist, who has prescribed medication. When he goes to his father's home .-~ , ,,~ --1- , 1._ ~> ~:~/i for partial custody periods, the father tells him he does not need to take his medications. He suffers adverse effects from being offhis medications during visits with his father. Father has not been willing to participate in family counseling. 5. As a result of the foregoing, the existing provisions regarding custody are no longer in the best interest and welfare of the child, 6. The best interests and welfare of the child will be promoted by a modification of the present visitation schedule for the above reasons. WHEREFORE, your petitioner respectfully prays that this Honorable Court modify the visitation schedule as follows: terminate father's partial custody periods unless and until he will comply with Matthew's medical and psychiatric need for medication and participate in family counseling intended to copy with Matthew's problems. Dated: October 22, 2004 AUG /) 2 ZOOt tP ~~-"."-'-""'...__...,." "-~>~'_u_____,_.," . v. IN THE COURT OF COIHMON PLEAS OFc . CUMBERLAND COUNTY,PENNSYLV ANIA ' i;, AUr, 1 f) 2001 ! I, : NO. 2001-3755 CIVIL TER1\f . - . 'i' 'U _ L If c~..,..,> i L:=/ ' J --.~~_.....l ' i ,)'/<1 ...':;'" : CIVIL ACTION - LAW L.__, . --"",/o:"!~._._._j . :1' . ':-."~'. STEPHEN J. WARREN, Plaintiff AlVIBERJ. SHUEY, Defendant : IN CUSTODY ORDER OF COU'RI AND NOW, this....L"I $-_ day of C~J' -,2001, upon consideration of the attached Custody Conciliat on Report, it is ordered and directed as follows: 1. The Father, Stephen J. Warren, and the Mother, Amber J. Shuey, shall have shared legal custody of Tiffany Warren, born February 12. 1986 and Matthew Allen Warren, born July 19, 1989, Each parent shall have an equal right, to be exercised jointly with the other parent, to make ail major non-emergency decisions affecting the Children's general wen.being including, but not limited to, all decisions regarding their health. education and religion. .., ... The Mother shall have primary physical custody of Tiffany. 3. The parties agree that Tiffany shall remain enrolled at The Hershey School unless otherwise agreed by the parties. 4. During the summer vacation from school, the parties shaIl have physical custody of Tiffany on alternating weekends from Friday at 7:00 p.m. to Sunday at 7:00 p.m., consistent with the regulations and schedule of The Hershey School. These weekends shall be coordinated with the alternating weekend schedule for Matthew such that the children shall spend the weekend in the same household. S. During the school year, each parent shall have custody of Tiffany one day each weekend, at times consistent with the regulations and schedule of The Hershey School. 6. lIv'fother shaH have primary physical custody of Matthew until August 17, 2001. Father shall have partial physical custody of Matdlew the weekend of August 4, 2001 from Friday at 7:00 p.m. (0 Sunday at 7:00 p,m. 7. Beginning August 17,2001 and continuing thereafter, Father shall have primary physical custody of Matthew in order for Matthew to attend school. While ~=>~~._' ~,....,,",, ". ~ -~~~~~-'-~ . ~, " - . J ~ " .1< _ ,'" Or. jii,~ t~~~~~~i~~~~!~fl~ff^1~:1':JJ,jL~~~ "" ""-~.' ,'_ _'_,' '," ,_ - :_," "_c_",',:"':;:;;- : _'" " . Fatj1~~P~'P.~~s!f~~~Y'Pd~:~~~^A~~~pa-;tilllP~S~F~.l:~~R~Yllf ...... ......... Mll~~onltlternatingw~}{\:jia,sfrol11Fridayaf1:00 p.m. to Sunday at 7:00p.m. with the fli'st weekend being August24, 2001. 8. The parties shall s~ transportation unless otherwise agreed. 9. The parties shall keep each other advised immediately relative to any medical care or medical emergencies concerning the children and shall further take any necessary steps to ensure that the health and well being of the children 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. 10. Neither parent shall do or say anything nor let anyone in the children's presence to say or do anything that may estrange the children from the other parent, injure the opinion of the children as to the other parent or hamper the free and naturltl development of the children's love and respect for the other parent. 11. Both parents shall have liberal and reasonable telephone contact with the children when the children are in the custody of the other parent. 12. Both parties and those members of their households who the custody evaluator deems relevant, shall submit to a custody evaluation by an evaluator agreed to by the parties. The parties shall share in the costs of the evaluation, although Mother agrees to pay the costs with Father reimbursing her. 13. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the tenns of this Order shall control. BY THE COURT, Ii (.) Lv...h'! ro.P.I~ ~ , Q^ J. cc: Thomas S. Diehl, Esquire, Counsel for Father Jerry Philpott, Esquire, Counsel for Mother. TRUE COpy FROM RECORD In Te3til11lloywl1sreof. there untflSlrt my hand and thes~ofsaidCtlUrtatcarliSle, Pa. fillS. 't) ..~Yfl.~~i~:~ / . ~ . .. "'PfOfu()flflfarl "'.>0 STEVEN J, WARREN, Plaintiff IN THE COURT OF COJ\illVION PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001-3755 CIYIL TERM A.MBER J. SHUEY. Defendant CIVIL ACTION - LAW IN CUSTODY CUSTOQY AGREEMENT COME NOW the above parties to this action, tather arId mother respectively of Tiffany and 1\latthew Warren, the children who are the subjects of this action, and agree as follows: 1 , Th.e Father, Steven J , Warren, and the Mother. Amber J, Shuey, shall have shared legal c\!.Stody of Tiffany Warren. born February 12, 1986. and Matthe..'I Allen Warren, born July 19, 1989. Each parent shall have an equal right, to be exercised jointlY'Nith the other parent, to rnake all majornon- emergency decisions a.fte..:ting the Cnildren's genera! well-being inciuding, but not limited to, all decisions regarding their health. education, and religion. , .c. The Mother shall have pr'illlary physical ,;ustody of the Children, 3 . Tbe F ather shall have partial physical custody 0 f ivlatthew on at ternating \veekends from Friday at 7:00 p.m. to Sunday at 7:00 p,m. 4. Tiffanv shall remain enrolled at The Hershey School unlessothervl/lse agreed by the parents, 5. During the summer vacation from school, the parties shall have physical custody ofTiffany 'em aiternatingweekends from Friday at 7:00 p,m. to Sunday at 7:00 p,m.. consistent with the regulations and schedule of The Hershey Sch00L These weekends shall be coordinated with tlte clternating weekend schedule for Matthew such that the children shall spend the weekend in the same household. 6, During the school year. each oarent shall have custody of Tiffany one day each weekend, at times consistent with the regulations and schedule of The Hershey School. The pacties shall share transportation lmless ()then-vise agreed, g, The parties shall keep t:ilch other advised Immediately relalJve to any medical care or medical emergenCIes concerning the chiklren and shall further take a..y necessary steps to ensure that the health and well being of the children is protected. During such iIlness or medica! emergency, both parents shall have the right to v1slt the children as often as he/she desires consistent with propermedi ,.'~> """ ~. '["' .,."j~,~, , - ,. J "~, (!l;:I!/~'ilii.' .h .......'fI'c.'....'...' .' .''; ,..' , ..... "",,~' children. ,~ :-". 9. NeitherparentshalI do orsay anything nor let anyone in the children's presence say or do anything that may estrange' the children from the other parent, injure the opinion of the children as to the other parent, or hamper the free and natural development of the children's love and respect for the other parent. 10, Both parents shall have liberal and reasonable telephone contact with the children when the children are in the custody of the other parent. The parties ask the Court to enter an order adopting these tenus. as S. Diehl Counsel for father . ~ -~, , '0 - ,.:, L_,~ 'iiiti[,~!,; I verify that the statements made in this Petition to Modify Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. 94904 relating to unsworn falsification to authorities, ~~m1,,,,,,,;".;hdh:.'"!0lti"'iMO'iil)..i.~~,,"i""~~Iiilt"r.lI:~IW.w""ih<'MlO ~;i.litJljalHOild'~- ---"'.b.Li-J -. ~~'-"-~.\lIiiiIi.~llI .~. r-,' () <,:;:;:;> '".:,:..":' -1'1 -,. ~ (':) C'") ~ ~ -", i',:' ~ r'-' ~ ~ J"';, ~ \. ::::;;:: ~ CJ- "- ~. ~ ~ L"J \,C \;;'- '-.J ....... "'" ..,~-'-""".~-- -""~~ ~-~ " '~'r' - ~= ,- . ~ V ,I Ii "'II I ~ I , , #' , .~~ ,~ '^ ',""~' .~ 'if' Ib \5 1.:.. ,> , ~_ ~.lrr. v DEe Q 9 2004J STEPHEN J. WARREN, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA V. : NO. 2001-3755 CIVIL TERM AMBER J. SHUEY, Defendant/Petitioner : CML ACTION - LAW : IN CUSTODY ORDER OF COURT . ~ ,..... u j.-., ANDNOW,this~dayof I~v , ,2004,upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated August 14,2001 and October 28, 2004 are hereby vacated. 2. The Father, Stephen 1. Warren, and the Mother, Amber J, Shuey, shall have shared legal custody of Matthew Allen Warren, born July 19, 1989, 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 his health, education and religion. 3. The Mother shall have primary physical custody of the child. 4, Father shall enjoy periods of partial physical custody as the parties agree, 5, and child. Family counseling shall commence as soon as practicable between Father 6. During periods of partial physical custody, Father shall see to it that the child takes all prescribed medications. 7. Both parties shall cooperate with the child's psychological and psychiatric counseling. Both parties shall be entitled to be kept fully informed by the medical care providers as to the child's treatment and progress, 8. The parties shall e-mail each other every other day regarding the welfare of the child. The party having primary physical custody of the child shall institute the e- mail. The other party shall respond. Copies of these e-mails should be retained to be presented as exhibits in any future custody proceeding. ~~ - --I '\..-."' , ~ i ,_ , -'" '-, - ~ -,"'- ~ 9. Father may e-mail the child and Mother shall encourage the child to respond and communicate with Father, 10. 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. 11. 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. 12. This Order is entered pursuant to an agreement ofthe parties at a Custody Conciliation Conference. 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. Another Conciliation Conference is scheduled for March 10, 2005 at 8:30 a.m, BY J. ccd91Y Philpott, Esquire, Counsel for Mother vlSteven 1. Warren, pro se 420 Ross Avenue NewCumberJand, PA 17070 ,,>' <__'0 '~"~-' ~{. " ':C,' :i ii :1 I I ii ;1 I1 il iI ;1 I 'I 'j ;J " 'I .... , ~ "7'"' ~~IIII~~ ~~~, , ". ",.,. ()c V. 1~~~~7K~i:6~i~jTPRY r',~,.,.. t,O r;MQ, ~l\-l Luth l...a...'\.I ....., 'i'_', ~;rJ' f'll (~ .... L,::./JNTY I I Ji; {,~~<;i .-.-,-~ ~ q.. _%J ~ ~ilI~. " ,!J\!i'l!.~~~~~lll~!j!illWi"'~-'!-''''''~~~'}~~~~I[~,~ _ _8r! ,JIi][~~i<<'~~h" ~ '"""'7- ,~_. j: DEe 0 9 2004 STEPHEN J. WARREN, PlaintifflRespondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA : 2001-3755 CIVIL TERM V. AMBER J. SHUEY, DefendantlPetitioner : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. 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 Matthew Allen Warren July 19, 1989 Mother 2, A Conciliation Conference was held in this matter on December 9, 2004, with the following individuals in attendance: The Mother, Amber J. Shuey, with her counsel, Jerry Philpott, Esquire, and the Father, pro se. 3. The Honorable J. Wesley Oler, Jr. entered an Order of Court dated August 14,2001 providing for shared legal custody and Father having primary physical custody of the child, Thereafter pursuant to a recommendation of a custody evaluation and the agreement of the parties, Mother assumed primary physical custody of the child. Mother filed a Petition for Emergency Relief which was heard by the Honorable Edward E. Guido. Judge Guido entered an Order of Court dated October 28, 2004 providing for shared legal custody, Mother having primary physical custody, and Father having alternating weekends. 4. The parties agreed to entry of an Order in the form as attached. ~e~y:~/ Custody Conciliator 1;)..-'1 -oi Date '. ,.___. d"~>,' -<] "',' ~, ~,- -',;,;>>':1, .,,,;.,~ ^ ~ - li'l. Ii. '~;'" ~ AMBER J. SHUEY, Petitioner v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-3755 CIVIL TERM STEVEN J. WARREN, Respondent IN RE: CIVIL ACTION - CUSTODY TEMPORARY CUSTODY ORDER ORDER OF COURT AND NOW, this 28th day of October, 2004, we enter the following Temporary Order that shall remain in effect pending conciliation and/or further Order of Court: 1. The parties shall have shared legal custody of their son, Matthew Warren, date of birth July 19, 1989. Mother shall have primary physical custody of the child subject to periods of partial physical visitation with the Father as follows: A. Every other weekend from Friday at 6:00 p.m. until Sunday at 6:00 p.m. B. Such other times as the parties agree. 2. During his periods of partial custody, Father shall see to it that the child takes all prescribed medications. 3. Both parties are directed to cooperate with the child's psychological and psychiatric counseling at Northwestern Human Services and/or with any other medical care provider. Both parties shall be entitled to be kept fully informed by the medical care providers as to their son's treatment and progress. 4. The parties shall e-mail each other on a daily basis regarding the welfare of their son. The party having primary physical custody of the child shall institute the e-mail. The other party shall respond. Copies of these e-mails should be retained to be presented as an exhibit in any future custody proceeding. is "."- , ,. ~ '. " '\ ~ . ~rry A. Philpott, Esquire 227 North High Street P.O. Box 116 Duncannon, PA 17020 For the Petitioner ~even J. Warren 420 Ross Avenue Floor 2 New Cumberland, PA 17070 Respondent, Pro se srs >"L -~ " _ -"'C" '"'";".0',)<..,,. _ , : ~L,; ~! > l~ ~~,;;~/J,. --'~~-'<~rl - 'ta~l~ll~~l!I~~l Jiiu *0 ~l~W~~'o1rii)t:,-\ii"hN~~~~m~~('~~.; II ~=,.;,.tlIiliIUr..-...=___tiiv' ' : ~trn ~ ~ "'- '-'-< ~". _ _.~,,~ _ __''''_'"''''''~''~'''O''~''~'''' _~<,;_, ,~, J~' ~_.'^ _ , ' _"'_7 . ~'. ., ^,~ """"""'" I, I' I , , 1',1 II , , I , - I ~ II II II ~ I I J i I ~ ~ 0 """ ~ "3 ~ , '2:- --- ;:;. )>.) ~ % --;-.. --c:. ~ ~ '" ~ ~ ~ ~ f,:' ,-'- 1,,,-, . -_:..i..._i~ ~E~'~' RECEIVED JUN 2 8 ?nn~~ STEPHEN J. WARREN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001-3755 CIVIL TERM AMBER J. SHUEY, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 28th day of June, 2005, the Conciliator not being contacted for more than 90 days following a general continuance, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, .ic y Conciliator ~'". -,- ,-~ ,.~.,," ,,~,,-, .""",-,..-' ,. ~, ~". &W-" .~. ~ '9' - F1LED-Oi:fiCE I'lF TH~r: CD()T,,~nf\lrJ'TbJ~v 'W' I,,,,., .",.,,, dhd /;'0 --4 r/ ;; 2"0" I"" "8 U ':., ,~."-, ~- v vU,~ f.. Dl' ". I u' l j ~-,' CU:\J;C~~:;' , ::,.~\Jl,nY H ~ I 1 ; , , , , ,; il 'I ~i 11 II I' J, 1\, " _ ~~~ !!JlW.",lf! "",..,.,,.,.,'C'~~.~II;\/j){t~;:~'W~'\>'R,:i"'J.1'?'~~:,~Vfri"_1~K~Jl!~~~:Ii~,_"~t~"":,,,,,"~~-_~l~~'