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HomeMy WebLinkAbout03-3027AMY C. KEEFER, Plaintiff VS. MICHAEL P. KEEFER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-30Q7 00 GFILrr? CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PENNSYLVANIA 17013. IF YOU DO NOT WISH TO FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOUR 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. COURT ADMINISTRATOR, 4TH FLOOR CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 240-6200 AMY C. KEEFER, Plaintiff VS. MICHAEL P. KEEFER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03 - 367 ?t? ?L? CIVIL ACTION LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW COMES the above-named Plaintiff, by Lori K. Serratelli, Esquire and the law firm of SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C., and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: COUNT I DIVORCE 1. Plaintiff is Amy C. Keefer, who currently resides at 653 Diane Drive, Etters, York County, Pennsylvania 17319 since May 25, 2001. 2. Defendant is Michael P. Keefer, who currently resides at 189 Spanglers Mill Road, New Cumberland, Cumberland County, Pennsylvania 17070 since March 2, 2003. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 3, 1992, in York County, Pennsylvania 5. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. The Defendant is not a member of the Armed Services of the United States or any of its allies. 9. The Plaintiff and Defendant are both citizens of the United States. 10. Plaintiff avers that there are two children of the parties under the age of 18, namely Christopher A. Keefer, born December 31, 1996; and Megan A. Keefer, born May 31, 2000. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. COUNT II EQUITABLE DISTRIBUTION 11. Paragraphs one through ten are hereby incorporated by reference herein. 12. Plaintiff states that Plaintiff and Defendant possess various items of both real and personal marital property which is subject to equitable distribution by the court. 13. Plaintiff requests that this court grant equitable distribution. WHEREFORE, Plaintiff prays that Your Honorable Court: (a) Equitably distribute all property, personal and real owned by the parties; (b) Grant Plaintiff exclusive possession of the marital residence; (c) Grant such further relief as the Court may deem equitable and just. Respectfully submitted, Lo K. gSerra?tell"1,Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statement made in the foregoing Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of IS Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: ?? Amy Keefe a AMY C. KEEFER Plaintiff V. MICHAEL P. KEEFER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3027 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property of other rights important to you, including the custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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, PA 17013 717-249-3166 AMY C. KEEFER IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 03-3027 CIVIL TERM MICHAEL P. KEEFER CIVIL ACTION - LAW Defendant IN DIVORCE ANSWER AND COUNTERCLAIM TO COMPLAINT IN DIVORCE AND NOW, comes the Defendant, Michael P. Keefer, by and through his attorney, Charles Rector, Esquire, and files the following Answer and Counterclaim to Complaint in Divorce: COUNT I - DIVORCE 1. Admitted. 2. Denied. Defendant resides at 186 Spanglers Mill Road, New Cumberland, Cumberland County, Pennsylvania, 17070. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Denied. Paragraph 7 constitutes a legal conclusion which requires no answer and proof thereof is demanded and the same is deemed denied. 8. Admitted. 9. Admitted. 10. Admitted. WHEREFORE, Defendant prays that your Honorable Court deny Plaintiffs request for a Divorce Decree under Section 3301 (c) of the Divorce Code. COUNT II - EQUITABLE DISTRIBUTION 11. No answer required. 12. Admitted. 13. Admitted. WHEREFORE, Defendant requests that the Court equitably distribute all property, personal and real, owned by the parties and further deny Plaintiff's request for exclusive possession of the marital home. COUNTERCLAIM COUNT/// -ADULTERY 14. The allegations of Paragraphs 1 through 13 are incorporated herein by reference and made a part thereof. 15. Plaintiff has committed adultery. 16. This action is not collusive as defined by Section 3309 of the Divorce Code. WHEREFORE, Defendant requests your Honorable Court to enter a divorce decree pursuant to Section 3301 (a)(2) of the Divorce Code. COUNT IV - CUSTODY 17. The allegations of Paragraphs 1 through 16 are incorporated herein by reference and made a part thereof. 18. Defendant is seeking primary physical custody of the minor children: Christopher Allen Keefer (DOB 12/31/96) and Megan Andrea Keefer (DOB 5/31/00). The children were not born out of wedlock. The parties are currently enjoying a 50/50 shared custody arrangement. During the past five years, the children have resided with the following persons and at the following addresses: a. 653 Diane Drive, Etters, PA with both parties. b. 500 Mumper Lane, Dillsburg, PA with both parties. 19. The relationship of the Plaintiff to the children is that of Mother. To the best of Defendants knowledge, the Plaintiff currently resides with no persons other than the children. 20. The relationship of the Defendant to the children is that of Father. The Defendant currently resides with his parents, John Keefer, Jr. and Shirley Keefer, and the children. 21. Defendant has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Defendant has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Defendant does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 22. The best interest and permanent welfare of the children will be served by granting the Defendant primary physical custody. WHEREFORE, Defendant requests the Court to grant him primary physical custody of the minor children. Date: /?° ° 1104 Fernwood Avenue, Ste. ZU3 Camp Hill, PA 17011 (717) 761-8101 Attorney for Plaintiff I verify that the statements made herein 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. ///(A2 A Michael P eefer Date: '7-10-0 a -v )? - r ry j T G` T ?l YI 7D <a -a AMY C. KEEFER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 03-3027 CIVIL ACTION LAW MICHAEL P. KEEFER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday July 30, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy Esq. the conciliator, 301 Market Street, Lemoyne, PA 17043 on Thursday, August 28, 2003 at 10:30 AM at 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: /s/ Aaelissa P r evv Fsa 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-31.66 g 47w 4m2 , oF=L. ?n?m,?s?vnr?d no q of ;nr c0 Jo 3?f?a??li?f SEP 0 2 2003 ? w AMY C. KEEFER, V. Plaintiff MICHAEL P. KEEFER, AND NOW, attached Custody follows: Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA NO. 03-3027 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT this '4 day of September, 2003, upon consideration of the Conciliation Summary Report, it is hereby ordered and directed as 1. Legal Custody. The parties, Amy C. Keefer and Michael P. Keefer, shall have shared legal custody of the minor children, Christopher Allen Keefer, born December 31, 1996, and Megan Andrea Keefer, born May 31, 2000. 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. Pursuant to the terms of Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to, medical, dental, religious or school records, the residence address of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational records, attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school night, and the like. 2. Physical Custody. The parents will share physical custody of the children in accordance with the following schedule: A. The parties will alternate parenting weeks each Sunday to commence August 31, 2003. Father will have the week commencing August 31, 2003. Mother will have the week commencing September 7, 2003. Custodial exchanges will occur on Sundays at 7:00 p.m. unless otherwise agreed. MNdMSNN3d IJ,Nw-) NO. 03-3027 CIVIL TERM B. In recognition of the children's ages, the parties will be flexible in providing each other with periods of evening partial custody for the non- custodial parent. 3. Transportation. The parent receiving custody will be responsible for providing transportation incident to the custodial exchange. 4. Holidays. A. Thanksgiving. Custody for Thanksgiving Day will alternate between the parties with Mother having custody for Thanksgiving Day in odd- numbered years and Father having custody for Thanksgiving Day in even- numbered years. B. Christmas. Custody for Christmas will be shared between the parties on an alternating basis. Segment A shall be from December 24th at 8:00 p.m. until December 25th at 2:00 p.m. Segment B will be from December 25th at 2:00 p.m. until December 26th at 8:00 p.m. The parent with custody for Segment B shall also be entitled to a period of partial custody on Christmas Eve which shall end at 8:00 p.m. and begin after that parent is off work for Christmas Eve. In odd-numbered years, Mother will have Segment A and Father will have Segment B. In even-numbered years, Father will have Segment A and Mother will have Segment B. 5. If within sixty (60) days of the date of this Order either party believes that the Custody Conciliation Conference would need to reconvene to revisit the arrangements of the physical custody plan, that request may be made by letter to the Conciliator. BY THE COURT: J. Dist: on K. Serratelli, Esquire, 2080 Ling lestown Road, Suite 201, Harrisburg, PA 17110 ,.Charles Rector, 1104 Fernwood Avenue, Suite 203, Camp Hill, PA 17011 11 . o9-a5-c? AMY C. KEEFER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3027 CIVIL TERM V. CIVIL ACTION - LAW MICHAEL P. KEEFER, Defendant IN CUSTODY 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 children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Christopher Allen Keefer December 31, 1996 Mother and Father Megan Andrea Keefer May 31, 2000 Mother and Father 2. A Custody Conciliation Conference was held on August 28, 2003 following Father's filing of a Counterclaim for Custody in the Divorce Complaint. Present for the conference were: the Mother, Amy C. Keefer, and her counsel, Lori K. Serratelli, Esquire; the Father, Michael P. Keefer, and his counsel, Charles Rector, Esquire. 3. The parties reached an agreement in the form of an as attached. ga91o3 Date Melissa Peel Greevy, Esquire Custody Conciliator :217760 AMY C. KEEFER, : IN THE COURT OF COMMON PLEAS IN Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 03-3027 CIVIL TERM : CIVIL ACTION -LAW MICHAEL P. KEEFER, Defendant IN DIVORCE (CUSTODY) PETITION TO MODIFY CUSTODY AND NOW comes Petitioner/Plaintiff, Amy C. Keefer, by and through her attorney, Lori K. Serratelli, Esquire, and the law firm of Serratelli, Schiffman, Brown & Calhoon, P.C., who files this Petition to Modify Custody and avers as follows: Petitioner/Plaintiff is Amy C. Keefer, an adult individual currently residing at 1100 Pines Road, Etters, York County, Pennsylvania 17315. 2. Respondent/Defendant is Michael P. Keefer, an adult individual currently residing at 189 Spanglers Mill Road, New Cumberland, Cumberland County, Pennsylvania 17070. Two children were born unto the parties, namely Christopher Allen Keefer, born December 31, 1996; and Megan Andrea Keefer, born May 31, 2000. 4. On June 25, 2003, Petitioner/Plaintiff filed a Complaint in Divorce. 5. On July 11, 2003, Respondent/Defendant filed an Answer and Counterclaim to Complaint in Divorce. Said Counterclaim contained a Count for custody. 6. On August 28, 2003, Custody Conciliation Conference was held before Melissa Peel Greevy, Esquire, Custody Conciliator. On August 29, 2003, the Custody Conciliator issued a Custody Conciliation Summary Report. 8. On September 4, 2003, an Order of Court relative to custody was issued by the Honorable Kevin A. Hess whereby the parties were granted shared legal custody and shared physical custody of the parties' minor children. 9. On March 29, 2004, Petitioner/Plaintiff filed a Protection from Abuse action against Respondent/Defendant due to Respondent/Defendant's threats of physical harm to Petitioner/Plaintiff. 10. Respondent/Defendant has on several occasions told Petitioner/Plaintiff, in front of the subject minor children, that he wished her dead. Respondent/Defendant has also told the subject minor children their mother does not love them. Recently, on March 28, 2004, at 7:05 p.m. when Respondent/Defendant came to pick up the children, he stated in front of the children that Petitioner/Plaintiffs only way out, if she does not reconcile, is in a casket. Further, he stated he had her in the sight of a scope of a gun. 11. Respondent/Defendant does not have the children's best interest in mind and is causing the children undue emotional stress. 12. Petitioner/Plaintiff is seeking primary physical custody and shared legal custody of the subject minor children and that Respondent/Defendant be ordered to take a parent counseling course. WHEREFORE, Petitioner/Plaintiff prays this Honorable Court award Petitioner/Plaintiff primary physical custody and shared legal custody of the children, with periods of partial custody/visitation to Respondent/Defendant, and order Respondent/Defendant to take a parent counseling course. Respectfully submitted, Lo K. erratelli, Esquire Attorney ID No. 27426 SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Petitioner/Plaintiff VERIFICATION I verify that the statements made in the foregoing document 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 unworn falsification to authorities. Date: - -Q 1 Amy C eefer CERTIFICATE OF SERVICE I, Lori K. Serratelli, Esquire, do hereby certify that on this 12s' day of May 2004,1 served a copy of the foregoing document by United States Mail, First Class, postage pre-paid, to the following person(s): Charles Rector, Esquire 1104 Femwood Avenue Suite 203 Camp Hill, PA 17011-6912 . Sen-atelli, squire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for V) Ck) c _ w o .? a ci, Q- - Tl p. _? T ftl _ ;? rrr w ?[ ? yl C71 - . AMY C. KEEFER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 03-3027 CIVIL ACTION LAW MICHAEL P. KEEFER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday. May 27 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greew, Esq. the conciliator, Thursday, July 01, 2004 at 10:30 AM at 301 Market Street Lemoyne, PA 17043 on 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: Melissa "' 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 an contact our office. accommodations available to disabled individuals having business before the court, please 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ur?rIr," ,/'0 ?t "Jr" 7C, L2A?°ddh00l A*'o,°,;OHuoad r»i ?o JUN 2 1 2004 AMY C. KEEFER, Plaintiff V. MICHAEL P. KEEFER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3027 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY HESS, J. -- TEMPORARY ORDER OF COURT AND NOW, this 25 day of June, 2004, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Leaal Custody. The parties, Amy C. Keefer and Michael P. Keefer, shall have shared legal custody of the minor children, Christopher Allen Keefer, born December 31, 1996, and Megan Andrea Keefer, born May 31, 2000. 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. Pursuant to the terms of Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to, medical, dental, religious or school records, the residence address of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational records, attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school night, and the like. 2. Physical Custody. The parents will share physical custody of the children in accordance with the following schedule: A. The parties will alternate parenting weeks each Sunday at 7:00 p.m. c CcD z to j N =i LL U 3 a NO. 03-3027 CIVIL TERM B. In recognition of the children's ages, the parties will be flexible in providing each other with periods of evening partial custody for the non- custodial parent. 3. Transportation. The parent receiving custody will be responsible for providing transportation incident to the custodial exchange. 4. Holidays. The following holiday schedule will supersede the regular schedule. A. Thanksgiving. Custody for Thanksgiving Day will alternate between the parties with Mother having custody for Thanksgiving Day in odd- numbered years and Father having custody for Thanksgiving Day in even- numbered years. B. Christmas. Custody for Christmas will be shared between the parties on an alternating basis. Segment A shall be from December 24th at 8:00 p.m. until December 25th at 2:00 p.m. Segment. B will be from December 25th at 2:00 p.m. until December 26th at 8:00 p.m. The parent with custody for Segment B shall also be entitled to a period of partial custody on Christmas Eve which shall end at 8:00 p.m. and begin after that parent is off work for Christmas Eve. In odd-numbered years, Mother will have Segment A and Father will have Segment B. In even-numbered years, Father will have Segment A and Mother will have Segment B. C. Independence Day and Labor Day. Father will have custody for Independence Day 2004. Mother will have custody for Labor Day 2004. D. Mother's Day / Father's Day. Mother will have custody for Mother's Day. Father will have custody for Father's Day. The custodial periods for these days are from 9:00 a.m. to 8:00 p.m. E. In the event that a Monday holiday follows a parent's custodial weekend, that parent's custodial weekend will continue until 7:00 p.m. on Monday. 5. Joyce A. Hechler, the maternal grandmother, shall be the contact person and intermediary for the parties' communication regarding custody. All custodial exchanges shall occur at the home of the maternal grandmother. NO. 03-3027 CIVIL TERM 6. Vacation. Father shall have custody for purposes of Summer vacation for the period from August 21, 2004 through August 27, 2004. Mother shall have custody for a seven (7) day period during the Summer 2004 not to include the period of August 21, 2004 through August 27, 2004. Mother will provide Father with fifteen (15) days notice of her intended vacation plans. Additionally, the vacationing parent shall provide a telephone number and location where they can be reached during the vacation. 7. The parties shall submit themselves and their minor children to an independent custody evaluation to be performed by Dr. Arnold Shienvold. The parties shall sign all necessary releases and authorizations for the evaluator to obtain medical and psychological information pertaining to the parties. Additionally, the parties shall extend their full cooperation in completing this evaluation in a timely fashion and in the scheduling of appointments. Mother shall initially bear the cost of the evaluation. However, Mother reserves the right to seek contribution from Father regarding the cost of the evaluation at the time of the custody trial. 8. The Custody Conciliation Conference may reconvene upon a letter request by counsel for either party if the request is made within ten (10) days of the receipt of the custody evaluation report. g. The Cumberland County Court of Common Pleas shall retain jurisdiction of this custody matter. Dist: Lori K. Serratelli, Esquire, 2080 Linglestown Road, Suite 201, Harrisburg, PA 17110 „,,; ?yN y Q,NL Charles A. Rector, Esquire, 1104 Femwood Avenue, Suite 203, Camp Hill, PA 17011 ?;as0Y , BY THE COURT: AMY C. KEEFER, Plaintiff V. MICHAEL P. KEEFER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3027 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY 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 children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Christopher Allen Keefer December 31, 1996 Mother and Father Megan Andrea Keefer May 31, 2000 Mother and Father 2. The parties' second Custody Conciliation Conference was held June 15, 2004 following Mother's Petition to Modify Custody filed on May 7, 2004. Present for the conference were: the Mother, Amy C. Keefer, and her counsel, Lori K. Serratelli, Esquire; the Father, Michael P. Keefer, and his counsel, Charles A. [Rector, Esquire. 3. There is presently a PFA Order in York County docketed to No. 2004-FC- 000628-Y12. 4. The parties reached an agreement in t or )of an Order as attached. ?te 4z"-? Dat Melissa Peel Greevy, squire Custody Conciliator :230711 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, Petitioner CIVIL ACTION - LAW V. IN CUSTODY 'MICHAEL P. KEEFER, NO. 03-3027 Respondent NOTICE r have been sued in court. If you wish to defend against the claims set forth in the following es, you must take action within twenty (20) days after this complaint and notice are served, by ;ring a written appearance personally or by attorney and filing in writing with the court your crises or objections to the claims set forth against you. You are warned that if you fail to do so case may proceed without you and a j udgment may be entered against you by the court without her notice for any money claimed in the complaint or for any other claim or relief requested by plaintiff. You may lose money or property or other rights important to you. OU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH FLOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 NOTICIA Le ban demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia escrita o en persona o per abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una Orden contra usted sin previo aviso o notification ypor cualguier queja o alivio que es pedido en lapeticion de demanda. Usted puede perder dinero o sus propiendades o otros derechos importantes para usted. LEVE ESTA DEMANDAA UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO S I NO TIENE EL DINERO SOFICIENTE DE PAGAR TAL SERVICO, V AYA EN PERS ONAL LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA BAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 KNIGHT & ASSOCIATES, P. 1 M. Shultz, squire Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorneys for Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, Respondent CIVIL ACTION - LAW V. IN CUSTODY MICHAEL P. KEEFER, NO. 03-3027 Petitioner PETITION TO MODIFY CUSTODY AND NOW, this V day of , 2005, comes the Petitioner, Amy C. Keefer, by land through her attorneys, Knight & Associates, P.C., and files the following Petition to Modify ? (Custody and in support thereof avers as follows: 1. The Petitioner is Amy C. Keefer, an adult individual residing at 355 Hemlock Lane, Etters, Pennsylvania 17319. 2. The Respondent is Michael P. Keefer, an adult individual residing at 186 Spanglers Mill Road, New Cumberland, Pennsylvania 17070. 3. Petitioner seeks a modification of the Order of Court dated June 25, 2004, a copy of which is attached hereto and made a part hereof and is marked as Exhibit "A." 4. The Parties are the natural parents of the following minor children: ame Present Residence Age Christopher Allen Keefer 355 Hemlock Lane, Etters, PA 17319 8 186 Spanglers Mill Road New Cumberland, PA 17070 Megan Andrea Keefer 355 Hemlock Lane, Etters, PA 17319 4 186 Spanglers Mill Road New Cumberland, PA 17070 Said children were not born out of wedlock. The children are presently in the shared physical custody of the Petitioner and the Respondent. In addition to Petitioner's and Respondent's present addresses, during the past five years, the :, children have resided with the following persons at the following addresses: a. From May 25, 2001 to July, 2003 with the parties at 653 Diane Drive, Etters, Pennsylvania; b. From July 2003 to February 2004 with the Petitioner at 1447 Hillcrest Court, 306, Camp Hill, Pennsylvania; and C. From February 2004 to end of July, 2004 with Petitioner at 1100 Pines Road, Pennsylvania. The mother of the children is the Petitioner, Amy C. Keefer, who resides at 355 Hemlock Etters, Pennsylvania 17319. The father ofthe children is the Respondent, Michael P. Keefer, who resides at 186 Spanglers Road, New Cumberland, Pennsylvania. 5. The relationship of Petitioner to the children is that of mother. She is married to the The Petitioner currently resides with the children and her boyfriend, Scott Whitebread. 6. The relationship of the Respondent to the children is that of father. He is married to The Respondent currently resides with the children and his parents, John H. Keefer, Jr, Shirley L. Keefer. 7. The Petitioner has previously participated in litigation concerning custody of the children in this Court at the above-referenced docket. An Order of Court was entered une 25, 2004. Said Order is cited in Paragraph 3 above and is attached hereto as Exhibit "A" is incorporated by reference herein. The Petitioner has no knowledge of any custody proceedings concerning the custody of the children pending before this or any other Court. The Petitioner does not know of a person not a party to the proceedings who has physical i custody of the children or claims to have custody or visitation rights with respect to the children. 8. Petitioner requests the following changes be made to the June 25, 2004 Custody Order: a) Petitioner requests that the Order state that Respondent cannot remove the ldren from Red Mill Elementary School for as long as at least one of the parties lives in the West school district; b) Petitioner requests that Respondent be ordered to ensure that the minor child, , completes his homework when he is in the custody of the Respondent; and C) Petitioner requests that Respondent pay for Christopher's school lunches or him lunch when he is in the custody of the Respondent. 9. Each parent whose parental rights to the children have not been terminated and the who has physical custody of the children have been named as parties to this action. There no other persons who are known to have or claim a right to custody or visitation of the children. 10. The best interests and permanent welfare of the children will be met if the custody is modified as requested because: a) The Petitioner is a fit parent who can best take care of the children; b) The Petitioner can provide the children with a home with adequate moral, and physical surroundings as required to meet the childrens' needs; c) The Petitioner is, and has always been, willing to accept custody of the and d) The Petitioner continues to exercise parental duties and responsibilities and enjoys the love and affection of the children. WHEREFORE, the Petitioner respectfully requests Your Honorable Court modify the Custody Order dated June 25, 2004 as requested. Respectfully submitted, KNIGHT & ASSOCIATES, P.C. Sean M. Shultz, Esquire Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorneys for Petitioner Docs\Gend0c5200n3796 2pot. midify cvtc ywpd VERIFICATION I VERIFY that the statements set forth in the attached document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Dater +Cee-rer p'13 -E?hlbit « FEB?01-2005 7UE 09:26 AN PSERq 2. 2004 H:490 B, & C, AMY C, KEEFER, Plaintiff v. MICHAEL P, KEEFER, Defendant FAX NO, 71738780 P. 02 Hog, Fa, 17110 NO, 5298? 1 F. 2/4? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3027 CIVIL. TERM CIVIL ACTION - LAW IN CUSTODY HESS, J. -- T,MPORARY ORDER 2E COLIFff AND NOW.,thz? day of June, 2004, upon consideration of the attached Custody Concilis n Summary Report, It is hereby ordered and directed as follows: t. LWI Custtodv. The parties, Amy C, Keefer and Michael P. Keefer, shall have shared legal custridy of the minor children, Christopher Allen Keefer, born December 31, 1986, and Megan Andrea Keefer, bom May 31, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency (decisions affectin; the children's general wellbeing Including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terns of Pa.C.S, 15309, each parer it shall be entitled to all records and information pertaining to the children Including, but not limited to, medical, dental, religious or school records, the residence 9ddress of the ch8dren and of the other parent. To the extent one parent has possession of ny such records or Information, that parent shall be required to share the same, or copies eraof, with the other parent within such reasonable time as to make the records and rmation of reasonable use to the other parent Both parents shall be entitled to full articipation in all educational and madicei/treatment planning meetings and evaluations Ith regard to thu minor children. Each parent shall be entitled to full and complete rmation from a iy physician, dentist, teacher or authority and copies of any reports given r them as parents including, but not limited to: medics( records, birth carMcates, school or Fcht,)ani1 tional records, attendance records or report cards, Additionally, each parent shall be td. to .receive copies of..any. notices which come from. school with regard to school 1s, exte nioular aWyMes, children's parties, musical presentations, back to-school n the like_ 2. ptA cal Custodv. The parents will share physical custody of the childmn in uc}cordance with th a following schedule: A. The parties will alternate parenting weeks each Sunday at 7:00 P.M. EB}01-2005 TUE ' JSEP. 2, 2004 09:26 AN PSE I? FAX NO. 7172Q38760 14:49,itia B. & C. Hbg, Pa, 111 i4 N'0.5298 NO, 03.3027 CIVIL. TERM B. in recognition of the children's ages, the parties will be flexible in providing each other With periods of evening partial custody for the non. custodial parent. P. 03 P. 314 3. I=avo ati n, The parent receiving custody will be responsible for providing transportation Inc; lent to the custodial exchange. 4. if„Qf)N§Wr The-following holiday schedule will supersede the regular schedule. A. Thank@avving, Custody for Thanksgiving Day will aitemate between th a parties with Mother having custody for Thanksgiving Day In odd- numbered years and Father having custody for Thanksgiving Day in even- numbered gears. s. rhdstmas Custody for Christmas will be shared between the parties on an alternating basis, Segment A shall be from December 240, at 9:00 p.m, until December 2501 at 2:00 p.m. Segment Swill be from December 250, at 2:OC p.m, until December 260, at 9:00 p.m, The parent with custody for Segment 8 shall also be entitled to a period of partial custody on Christmas Eve which shall end at 8:00 p.m. and begin after that parent is off work for Christmas Eve, In odd-numbered years, Mother will have Segment A and Father will have Segment 8, In even-numbered years, Father will have Segment A and Mother will have Segment S. C. independence Day and La or Qav. Father will have custody for Independer ice Day 2004, Mother will have custody for labor Day 2004. - " " - - " °D - ktath -Day ! -Father's Day. Mother will have custody for Mother's Coy. Father will have custody for Father's Day. The custodial periods for these days are from 9:00 a.m. to 8:00 p.m. E. In the event that a Monday holiday follows a parent's custodial weekend, that parents custodial weekend will continue until 7:00 p.m. on Monday. i 5. Joyco A. Hechler, the maternal grandmother, shall be the contact person and intermediary for tie parties' communication regarding custody. All custodial exchanges sh U occur at the home of the maternal grandmother. I p?Vl CVVu .? 2 iuc VJ.c nit rac 2004 10:440 . 61 & C. NO. 03-3027 CIVIL TERM rnn "J. 1110otou H6t, Pa. 17110 r, u4 N0.5248 P. 4/4 6. VM ion. Father shall have custody for purposes of Summer vacation for the period from August 21, 2004 through August 27, 2004. Mother shall have custody for a seven (7) day petod during the Summer 2004 not to include the period of August 21, 2004 through August 27, 2004. Mother will provide Father with fifteen (15) days notice of her intended vacatior plans. Additionally, the vacationing parent shall provide a telephone numberand location where they can be reached during the vacation, 7. The parties shall submit themselves and their minor children to an Independent custody evaluation to be performed by Dr. Arnold Shienvold. The parties shall sign all necessary releases and authorizations for the evaluator to obtain medical and psychological Infc irrnation pertaining to the parties. Additionally, the parties shall extend their full cooperat on In completing this evaluation In a timely fashion and In the scheduling of appointments. Mother shall initially bear the cost of the evaluation, However, Mother reserves the right to seek contribution from Father regarding the cost of the evaluation at the time of the cut Itooy trial, S. The Custody Conciliation Conference may reconvene upon a letter request by counsel for elthel party If the request Is made within ten (10) days of the receipt of the custody evaluation report. 9. The Cumberland County Court of Common Pleas shall retain jurisdiction of this custody matte r. 8Y THE COURT; ?i r b)"A, 0j,,1, Kevin A, Hess, J. --??? 0113t: Lod K. Serreta D, Faqulre, 208013n9lWWffi Road. Suite 201, Wardeburg, PA 17110 Chagas A. Rec tor, Uquira,1104 Femwaod Avonue, Suite 203, Camp HID, PA 17011 rAUE COPY FROM RECOFO in Tsatirts" wharwi. I hm unto yet my hard and tits of saki oprillat CWIWQ. FL -IV rhas. !K dey . a . ftlwotwi ? d 0 ((`??? ? d n_ ^? c? r(V i' C 3 TI (? ?- ?Z - ( ? ? n -? ?J I'?+-- ? ? ? ni r,.- ? ? 7 ?-? ? ?n [,. _ w AMY C. KEEFER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 03-3027 CIVIL ACTION LAW MICHAEL P. KEEFER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday May 06, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. the conciliator, at DJ Manlove's, 1901 State St., Camp Hill, PA 17011 on _ Friday, June 10, 2005 at 9:00 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 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: /s/ Melissa R Greevy, Esy. 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 infonnation 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 schedules 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 FORT] I 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 log, 17.7 r u EO Rx Date/Time MAY-27-2005(FRI) 09:40 7172490457 05/27/2005 10:41 7172490457 HANFT & KNIGHT,PC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, Petitioner V. MICHAEL P. KEEFER, Respondent CIVIL ACTION - LAW INCUSTODY NO. 03-3027 ACCEPTANCE OF SERVICE P. 014 PAGE 14/14 1, Charles A. Rector, Esquire, accept service of the Petition to Modify Custody in the above- captioned matter on behalf of the Respondent, Michael P. Keefer, and I certify that I am authorized to do so. Date: *a s 4harles A. R tor, Esquilte Attorney ID No, J I e6;j 1104 Fernwood Avenue, Suite 203 Camp Hill, Pennsylvania 17011 (717) 761-8101 F. . FWd.Vim s?oM4eAdoCf1 W F197/63nxsa srpd N O z O Vl ..? m?z ? T ?i_. yy"? _ ? ? ' . 4YJ 1 -G .. ? W Lf r-?_ L ?' 3 ? ?' I ?? fi7 ?, W C? O 01 4 RECEIVED Jut. 2-5 7"1 AMY C. KEEFER, Plaintiff V. MICHAEL P. KEEFER, Defendant HESS, J. --- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3027 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this z 1;' day of July, 2005, upon consideration of the Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. This court's order of June 25, 2004 shall remain in full force and effect. 2. Neither parent may withdraw the children from the West Shore School District without the consent of the other parent or leave of court. BY THE COURT: A. Hess, J. Dist: Sean M. Shultz, Esquire, 11 Roadway Drive, Suite B, Carlisle, PA 17013 Charles A. Rector, Esquire, 1104 Fernwood Avenue, Suite 203, Camp Hill, PA 17011 ?.1 G-6S L?- I t? ? r nP?V' . ,aa JHi J6 AMY C. KEEFER, Plaintiff V. MICHAEL P. KEEFER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3027 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY 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 children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Christopher Allen Keefer December 31, 1996 Mother Megan Andrea Keefer May 31, 2000 Mother 2. Mother filed a Petition for Modification of Custody on May 2, 2005. A Custody Conciliation Conference was held on July 7, 2005. Attending the Conference were: the Mother, Amy C. Keefer, and her counsel, Sean M. Shultz, Esquire; the Father, Michael P. Keefer, and his counsel, Charles A. Rector, Esquire. The p reached an agreement in the form of an Order as attached. 1UPS D e Melissa Peel Greevy, Esqui Custody Conciliator MPG:ead:254205 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, Plaintiff CIVIL ACTION - LAW V. MICHAEL P. KEEFER, Defendant NO. 03-3027 IN DIVORCE AFFIDAVIT OF CONSENT STATE OF PENNSYLVANIA ) SS. COUNTY OF ) A Complaint in divorce under Section 3301(c) ofthe Divorce Code was filed on June 25, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I verify that the statements made in this affidavit 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. Date- ??'jR..,, 2008 Sworn to and subscribed before me this day of , 2008. N?N WOOF PRoISYLVA IA CON & iJoMartal Sod P"a A Gordon. NoWY Public f=WMW Twp., Y(WCCo 3 Y AM commioslon Expires 4* Member, Pennsylvania psaootation of Notarise 12vu'? e--Z?v A Amy C. efer ,, 15" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, Plaintiff CIVIL ACTION - LAW V. NO. 03-3027 MICHAEL P. KEEFER, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER P301(C) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit 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. Date: I ?la? y . Keefer C) C K E z1 F . c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, Plaintiff V. MICHAEL P. KEEFER, Defendant CIVIL ACTION - LAW NO. 03-3027 IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a counter-affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in March of 2003 and have continued to live separate and apart from each other for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Date: f , 2008 (1, ` Amy C eefer PlaintifTJ J Q IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, No. 03-3027 Plaintiff V. MICHAEL P. KEEFER, Defendant IN CUSTODY NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualguier quej a o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiendades o otros derechos importantes para usted. LLEV E ESTA DEMANDAA UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SOFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONAL O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 & ASSOCIA Sean M. Shultz, Esquire Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorneys for Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, No. 03-3027 Plaintiff V. IN CUSTODY MICHAEL P. KEEFER, Defendant PETITION TO MODIFY CUSTODY AND NOW, this Zq rf'? day of June, 2008, comes the Petitioner, Amy C. Keefer, by and through her attorneys, Knight & Associates, P.C., and files the following Petition to Modify Custody and in support thereof avers as follows: 1. The Petitioner is Amy C. Keefer, an adult individual residing at 398 Big Spring Road, New Cumberland, Pennsylvania 17070. 2. The Respondent is Michael P. Keefer, an adult individual residing at401 Lopax Road, Apt. G2, Harrisburg, Pennsylvania 17112. 3. Petitioner seeks a modification of the Orders of Court dated June 25, 2004 and July 25, 2005, copies of which are attached hereto and made a part hereof and marked as Exhibit "A." 4. The parties are the natural parents of the following minor children: Name Present Residence Age Christopher Allen Keefer (Christopher) Megan Andrea Keefer (Megan) 398 Big Spring Road New Cumberland, PA 17070 11 401 Lopax Rd., Apt. G2 Harrisburg, PA 17112 398 Big Spring Road New Cumberland, PA 17070 8 401 Lopax Rd., Apt. G2 Harrisburg, PA 17112 Christopher and Megan were not born out of wedlock. Christopher and Megan are presently in the shared physical custody of the Petitioner and the Respondent with a week on/ week off rotation. In addition to Petitioner's and Respondent's present addresses, during the past five years Christopher and Megan have resided with the following persons and at the following addresses: a. From June of 2003 to July of 2003 with the parties at 653 Diane Drive, Etters, Pennsylvania; b. From July 2003 to February 2004 with the Petitioner at 1447 Hillcrest Court, Apt. 306, Camp Hill, Pennsylvania; C. From July 2003 to August 2006 with Respondent and his parents, John H. Keefer, Jr. and Shirley L. Keefer, at 186 Spanglers Mill Road, New Cumberland, Pennsylvania; d. From February 2004 to the end of July 2004 with Petitioner at 1100 Pines Road, Etters, Pennsylvania; and e. From July 2004 to September 2006 with Petitioner, Petitioner's boyfriend, Scott Whitebread, and his brother, Timmy, at 355 Hemlock Lane, Etters, Pennsylvania. The mother of Christopher and Megan is the Petitioner, Amy C. Keefer, who resides at 398 Big Spring Road, New Cumberland, Pennsylvania. The father of Christopher and Megan is the Respondent, Michael P. Keefer, who resides at 401 Lopax Rd., Apt. G2, Harrisburg, Pennsylvania. 5. The relationship of Petitioner to Christopher and Megan is that of mother. She is married to the Respondent. Petitioner currently resides with Christopher, Megan and Scott Whitebread. 6. The relationship of the Respondent to Christopher and Megan is that of father. He is married to the Petitioner. Respondent currently resides with Christopher and Megan. 7. The Petitioner has previously participated in litigation concerning custody of the above-named children in this Court at the above-referenced docket. An Order of Court was entered on June25, 2004 and on July 25, 2005. Said Orders are cited in Paragraph 3 above and are attached hereto as Exhibit "A" and by reference incorporated herein. The Petitioner has no knowledge of any custody proceedings concerning the custody of Christopher and Megan pending before this or any other Court. The Petitioner does not know of a person not a party to the proceedings who has physical custody of Christopher and Megan or claims to have custody or visitation rights with respect to them. 8. Respondent has told Christopher and Megan that Petitioner is a "whore" and that she does not love them. 9. Respondent has threatened to harm Petitioner in the presence of Christopher and Megan. 10. Respondent has told Christopher and Megan that he wants to slit Petitioner's throat and watch her bleed and also to drive up into her front yard and shoot her. 11. Respondent has been charged with making terroristic threats in the presence of the children. 12. Respondent does not ensure that Christopher and Megan complete their homework when they are in Respondent's custody. 13. Respondent has not paid for Christopher and Megan's school lunches for three years. 14. Respondent does not show loving emotion toward Christopher and Megan or give them moral support. 15. Christopher has expressed to Petitioner that he wishes he would die because of how he is treated by Respondent. 16. Christopher and Megan do not discuss any problems or school functions with Respondent because of his lack of involvement and dependability. 17. On February 12, 2008, Christopher testified against Respondent in Court regarding criminal charges filed against Respondent for terroristic threats against Petitioner. Respondent then punished Christopher for testifying against him. 18. Petitioner requests the following changes be made to the July 7, 2003 and October 23, 2003 Custody Order: a) Petitioner requests sole legal custody of Christopher and Megan be awarded to her; b) Petitioner requests primary physical custody of Christopher and Megan; and C) Petitioner requests that Respondent have periods of supervised visitation with Christopher and Megan as follows: 1) Every other Saturday from 4:00 p.m. until 8:00 p.m.; 2) Father's Day from 10:00 a.m. until 2:00 p.m.; 3) Christmas Day at 5:00 p.m. until 5:00 p.m. on December 26; and 4) Such other times as the parties can mutually agree upon. d) Respondent shall complete an anger management program and shall complete a parenting program that addresses his volatile behavior regarding Petitioner; e) Neither party shall make derogatory statements about the other. 19. Each parent whose parental rights to Christopher and Megan have not been terminated and the person who has physical custody of Christopher and Megan have been named as parties to this action. There are no other persons who are known to have or claim a right to custody or visitation of Christopher and Megan. 20. The best interests and permanent welfare of Christopher and Megan will be met if the custody order is modified as requested because: a) The Petitioner is a fit parent who can take care of Christopher and Megan; b) The Petitioner can provide Christopher and Megan with a home with adequate moral, emotional and physical surroundings as required to meet their needs; C) The Petitioner is, and has always been, willing to accept custody of Christopher and Megan; d) The Petitioner continues to exercise parental duties and responsibilities and enjoys the love and affection of Christopher and Megan. 21. Respondent is represented by Charles Rector, Esquire in this matter. A copy of this Petition was sent to Attorney Rector at 1104 Fernwood Avenue, Suite 203, Camp Hill, Pennsylvania 17011. WHEREFORE, the Petitioner respectfully requests Your Honorable Court modify the Custody Orders dated June 25, 2004 and July 25, 2005 as requested. Respectfully submitted, HT & ASSOCIATES, P.C. Sean M. Shultz, Esquire Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorneys for Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, No. 03-3027 Plaintiff V. IN CUSTODY MICHAEL P. KEEFER, Defendant , i ?I Y 1 I verify that the statements made in the foregoing Petition to Modify are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904, relating to unworn falsification to authorities. F:\U?a PoWalFirm Docs1C? Fia13786-3 Amy K?p?tianmoikt5'•ivpd Exhibit "A" FEB-0 -2005 TUE 09:26 AM PSERs 2.2004 10:49.41 B. & C, h ,AMY C, KEEFER, V. Plaintiff MICHAEL P, KEEFER, Defendant FAX NO, 717'7x38760 P. 02 N4 Pa, 11110 0 110, 5298? 1 P. 2/4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 03-3027 CIVIL. TERM CIVIL ACTION - LAW IN CUSTODY HESS, J. -- TEM , Y ORDER COURT AND NOW this.. day of June, 2004, upon consideration of the attached Custody ConcillaWn SummaryReport, it Is hereby ordered and directed as follows: 1. uaai Cud ¢y. The parties, Amy C, Keefer and Michael P. Keefer, ehail have shared legal custc?dy of the minor children, Christopher Allen Keefer, bom December 31, 1996, and Megan Andrea Keefer, born May 31, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions aftectin; the children's general well-being Including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of Ps.C.S, 18309, each parer it shall be entitled to all records and information pertaining to the children Including, but not limited to, medical, dental, religious or school records, the residence address of the children and of the other parent To the extent one parent has possession of any such records or information, that parent shall be required to share the name, or copies ;hereof, with the ether parent within such reasonable tlmd as to make the recorft and iWormation of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations 1NM regard to tho minor children. Each parent shall be entitled to full and complete Information from xiy physician, dentist, teacher or authority and copies of any reports given In them as parents including, but not limited to: medical records, birth certificates, school or educational records, attendance records or report cards, Additionally, each parent shall be 4nMed. to 4ecebm coplea of-any- notlow which come from, school with regard to school pictures, extracurricular actlvldes, children's parties, musical presentations, back-to-school alight, and the like. 2. EWcel CuAWy. The parents will share physical custody of the children in rcccordance with the following schedule: A. The parties will alternate parenting weeks each Sunday at 7:00 P.M. a R-01-2005 TUE 09:26 AM PSE • "FF. 2.200410:49.W a. & C. NO, 03-3027 CIVII. TERM FAX NO. 7138760 N ? g, P a. 1111 a P. 03 h0.5298 P. 3./4 B. In reoognition of the ohildren's ages, the parties will be flexible in providing each other with periods of evening partial custody for the non• custodial parent. 3. lWeaort tlQ0, The parent receiving custody will be responsible for providing transportation Inc Ftentto the custodial exchange. 4.; Tha•following holiday schedule will supersede the regular schedule. A. ThpnNggiving. Custody for Thanksgiving Day will alternate between th s parties with Mother having custody for Thanksgiving bey in odd- numbered years and Father having custody for Thanksgiving Day In even- numbered gears. S. dp . Custody for Christmas will be shared between the parties on an afkemating basis, Segment A shall be from December 24th at 8:00 p.m. until December 25°1 at 2:00 p.m. Segment B will be from December 231' at 2:OC p.m. unt i December 261' at 8:00 p.m. The parent with custody for Segment 8 shall also be entitled to a period of partial custody on Christmas Eve which shall end at 8:00 p.m. and begin after that parent is off work for Christmas Eve, In odd-numbered years, Mother will have Segment A and Father will have Segment B, In even-numbered years, f=ather will have Segment A and Mother will have Segment s. C. Independence Day a La or tav. Father will have custody for Independer ice Day 2004, Mother will have custody for Labor Day 2004. -D:`"-~ h!91 -flay !-Fathers Dsv. Mather will have custody for Mother's Day. Father will have custody for Father's Day. The custodial periods for these days are from 9:00 a.m. to 8:00 P.M. E. In the event that a Monday holiday follows a parent's custodial weekend, chat parent's custodial weekend will continue until 7:00 p.m. on Monday. 6. Joyc s A. Hechler, the maternal grandmother, shall be the contact person and intermediary for tie parties' communication regarding custody. All custodial exchanges shall occur at the I tome of the matemel grandmother. p V l LVU:J tuc uu - c nil r ac r nn nu, i 1?JO 1 Ou 2004 10:494 !?! B. & C. het, Pa. 11110 NO. 03-3027 Cl\A L TERM r. u4 NO-11298 P. 4/4 6. Vw ion. Father shall have custody for purposes of Summer vacation for the period from August 21, 2004 through August 27, 2004. Mother shall have custody for a seven (7) day period during the Summer 2004 not to include the period of August 21, 2004 through August 27, 2004. Mother will provide Father with fifteen (15) days notice of her intended vacator plans. Additionally, the vacationing parent shall provide a telephone number and location where they can be reached during the vacation, 7. The parties shall submit themselves and their minor children to an Independent custody evaluation to be performed by Dr. Arnold Shienvold. The parties shall sign all necessary releases and authorizations for the evaluator to obtaln medical and psychological Infc-rmation pertaining to the parties. Additionally, the parties shall extend their full cooperat on In completing this evaluation In a timely fashion and In the scheduling of appointments. Mother shall initially bear the cost of the evaluation, However, Mother reserves the righi to seek contribution from Father regarding the cost of the evaluation at the time of the cu: itody trial, 8, The Custody Conciliation Conference may reconvene upon a letter request by counsel for elthei party if the request Is made within ten (10) days of the receipt of the custody evaluation report. 9. The Cumberland County Court of Common Pleas shall retain jurisdiction of this custody matte r. BY THE COURT: Kevin A, Hess, J. Dim Lod K. Serrat&k Eaquim, 2080 UnglW wn Fload. SUIZQ 201, Harrisburg, PA 17110 Chades A. Rac tor, Esquire, 1104 Femwood Avenue, Suite 203, Camp Hip, PA 17011 TRUE COPY FROM RECORD in T19kr+Y Wh"d. I two taro eat MY hand Boo tip std 1A Carme. FL rh is ]z: ..-...... . -v AWL - v 4VVJ AMY C. KEEFER, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3027 CIVIL TERM CIVIL ACTION - LAW MICHAEL P. KEEFER, IN CUSTODY Defendant HESS, J. ORDER OF COURT AND NOW, this -.2S d-' day of July, 2005, upon consideration of the Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. This court's order of June 25, 2004 shall remain in full force and effect. 2. Neither parent may withdraw the children from the West Shore School District without the consent of the other parent or leave of court. BY THE COURT: Kevin A. Hess, J. Dist: Sean M. Shultz, Esquire, 11 Roadway Drive, Suite B, Carlisle, PA 17013 Charles A. Rector, Esquire, 1104 Femwood Avenue, Suite 203, Camp Hill, PA 17011 TpUE COPY FROM RECD '?J? to 1 ircY, Wlf1lfilr , I here unto sets M hand am 9W tow of sew cpmn as Car*w, Pa. T - .2t, A. a2& 5 .r ?rthaineldry AMY C. KEEFER, Plaintiff V. MICHAEL P. KEEFER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3027 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY 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 children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Christopher Allen Keefer December 31, 1996 Mother Megan Andrea Keefer May 31, 2000 Mother 2. Mother filed a Petition for Modification of Custody on May 2, 2005. A Custody Conciliation Conference was held on July 7, 2005. Attending the Conference were: the Mother, Amy C. Keefer, and her counsel, Sean M. Shultz, Esquire; the Father, Michael P. Keefer, and his counsel, Charles A. Rector, Esquire. The reached an agreement in the form of an Order as ttached. D e Melissa Peel Greevy, Esqui Custody Conciliator MPG:ead:254205 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, No. 03-3027 Plaintiff V. IN CUSTODY MICHAEL P. KEEFER, Defendant CERTIFICATE OF SERVICE AND NOW, this Zqt'?` day of June, 2008, I, Sean M. Shultz, Esquire, hereby certify that I have this day served the following with a copy of the foregoing Petition to Modify Custody by first class, United States Mail, postage pre-paid, addressed as follows: Charles Rector, Esquire Law Offices of Charles Rector, Esquire, P.C. 1104 Femwood Avenue, Suite 203 Camp Hill, Pennsylvania 17011 Attorney for Respondent Respectfully submitted, KNIGHT & ASSOCIATES, P.C. Sean M. Shultz, Esquire Attorney I.D. No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorney for Petitioner 73 f 4 AMY C. KEEFER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2003-3027 CIVIL ACTION LAW MICHAEL P. KEEFER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, June 30, 2008 , 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 Tuesday, July 29, 2008 at 8:30 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. 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: Is/ ae ueline M. Verne Es q. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 lo? LO :z 11AIJ, oc Nnr HE ITI JUL 3 0 Md AMY C. KEEFER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2003-3027 CIVIL ACTION - LAW MICHAEL P. KEEFER, Defendant : IN CUSTODY ORDER OF COURT 2008, upon AND NOW, this %514f" day of Qjj consideration of the attached Custody Concili ion port, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. 7 , of the Cumberland County Court House, on the .?41'4 day of , 2008, at 936 o'clock, A . M., at which time testimony will be taken. For purposes of this Hearing, the Mother shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least five days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Orders of Court dated June 25, 2004 and July 25, 2005 shall remain in full force and effect with the following additions. 3. The parties shall cooperate with therapeutic family counseling with Christopher. The parents shall participate as directed by the counselor. The counselor shall be selected by the attorneys for the parties. Father is not responsible for any costs associated with counseling. 4. During his weeks of physical custody, Father shall be responsible for transporting Christopher to school on time and Megan to her latchkey program before school. Father shall be financially responsible for the cost of the latchkey program. Maternal grandmother shall pick up the children after school and Father will pick up the children from Grandmother's after work. r C 5. 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. (? Fc ?'(?" ? . ?.? .. ,. rr..,,_ ,??? ?? -? ?, BY THE COURT, J? Kevin,A. Hess, J. cc:ean M. Shultz, Esquire, counsel for Moth Diane Radcliff, Esquire, counsel for Father GoPties env.tLt.? AMY C. KEEFER, Plaintiff V. MICHAEL P. KEEFER, Defendant PRIOR JUDGE: Kevin A. Hess, J. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003-3027 CIVIL ACTION - LAW : IN CUSTODY 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 Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Christopher Allen Keefer December 31, 1996 shared Megan Andrea Keefer May 31, 2000 shared 2. A Conciliation Conference was held July 29, 2008 with the following individuals in attendance: The Mother, Amy C. Keefer, with her counsel, Sean M. Shultz, Esquire, and the Father, Michael P. Keefer, with his counsel, Diane Radcliff, Esquire. 3. The Honorable Kevin A. Hess previously entered Orders of Court dated June 25, 2004 and July 25, 2005 providing for shared legal custody and shared physical custody and that the children attend West Shore Schools. 4. Mother's position on custody is as follows: Mother seeks sole legal and primary physical custody with Father having supervised visitation of the children. Mother asserts that charges are pending against Father in Dauphin County for terrorist threats based on Christopher telling his Mother that Father has told both children that Father wants to slit Mother's throat and watch her bleed and to drive up to the front yard and shoot Mother. Mother also alleges that Father does not assist in homework and does not show affection toward the children. 5. Father's position on custody is as follows: Father seeks to maintain the status quo. He denies the allegations of the criminal charges. Trial is set for August, 2008. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and maintaining the status quo with modifications that the parents agreed to. It is expected that the Hearing will require one day. 2 -z?-0S ?A v Date Jac eline M. Verney, Esquire Custody Conciliator AMY C. KEEFER, Plaintiff VS. MICHAEL P. KEEFER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3027 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Charles Rector, Esquire, attorney for the Defendant in the above-captioned matter, hereby certify that on July 10, 2003 I accepted service of the Complaint in Divorce filed June 25, 2003. 8/ Y/15 'p- Dated Charles Rector, Esquire 1104 Fernwood Avenue Suite 203 Camp Hill, PA 17011 (717) 761-8101 C <r co ?c U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, Plaintiff CIVIL ACTION - LAW V. NO. 03-3027 MICHAEL P. KEEFER, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Code. Ground for divorce: irretrievable breakdown under Section 3301 (d)(1) of the Divorce 2. Date and manner of service of the complaint: Service on Defendant's attorney of record, Charles Rector, Esquire, on 01 03 . A copy of the Acceptance of Service is attached -4 11 hereto. 3. Date of execution of the Plaintiff's affidavit required by §3301(d) of the Divorce code: December 24, 2007. 4. Date of filing and service of the Plaintiff's affidavit upon the Respondent: Plaintiff's Affidavit was filed June 4, 2008 and mailed to Defendant's attorney, Charles Rector, Esquire, by U.S. certified, return receipt requested mail on June 9, 2008 and received on June 11, 2008. See copy of Domestic Return Receipt attached hereto. 5. Related claims pending: None. 6. Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: Mailed to Defendant's attorney, Charles Rector, Esquire, by U.S. certified, return receipt requested mail on July 2, 2008 and received on July 7, 2008. See copy of Domestic Return Receipt attached hereto. Date: 22, 2008 & ASSOCIA San M. Shultz, Esquire Attorney I.D. No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorneys for Plaintiff f AMY C. KEEFER, Plaintiff VS. MICHAEL P. KEEFER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3027 CIVIL TERM CIVIL ACTION - LAW Defendant IN DIVORCE 0 N) ACCEPTANCE OF SERVICE [`. ` L7 J I, Charles Rector, Esquire, attorney for the Ddfen nt,?in the above-captioned matter, hereby certify that on July 10, 2003 I accepted service of the Complaint in Divorce filed June 25, 2003. 8 / Y?15 ? Dated Charles Rector, Esquire 1104 Fernwood Avenue Suite 203 Camp Hill, PA 17011 (717) 761-8101 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, Plaintiff V. MICHAEL P. KEEFER, Defendant CIVIL ACTION - LAW NO. 03-3027 IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: MICHAEL P. KEEFER, Defendant c/o Charles Rector, Esquire Law Offices of Charles Rector, Esquire, P.C. 1104 Fernwood Avenue, Suite 203 Camp Hill, Pennsylvania 17011-6912 Amy C. Keefer, Plaintiff, intends to file with the court the attached Praecipe to Transmit Record on or after July 25, 2008, requesting that a final decree in divorce be entered. Respectfully submitted, & ASSOCIATES. P.C. F:\User FolderTirm Docs\Clients Files\1786-1 Amy KeefeAnotice.wpd Sean M. Shultz, Esquire Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorney for Plaintiff e ¦ 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 to the back of the mailpiece, or on the front if space permits. 1. Articles Addressed to: OkkrlLJ ?qo(' FS1 110 0 NAVVOd d AW . Wi 41203 (LNL WI. P4- 0011 A. Si ature ? Agent X O ? AddresseE i B. Received by ( F d N C. Date of Delivery J` ?nf?? 1(0 -11 'D8" D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ? No 3. jj;t?Type 4 Mall ? Express Mail Registered ? Return Receipt for Merchandisc ? insured mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. ArticleNt 7005 1160 0002 1108 9926 (Transfer PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-154 ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. t Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. A. X Agent 1. Article Addressed to: C h r l?? 0??r, Fsq - II?UI mmod?q- B. Receive y (Printed Name) C. Date f D liv r -71&Y D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ? No 3. t 51?Gertifled Mail ? Registered ? Insured Mail ' - / 4. Restricted Wive 2. Article 7003 2260 0000 8709 5685 PS Form 3811, February 2004 Domestic Return Receipt A ? Express Mail ? Return Receipt for Merchandisc ? C.O.D. ryl (Extra Fee) ? Yes 102595-02-M-154 N TM: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, Plaintiff V. MICHAEL P. KEEFER, Defendant CIVIL ACTION - LAW NO. 03-3027 IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please withdraw the Equitable Distribution Count (Count II) in the Divorce Complaint filed in the above-captioned matter on June 25, 2003. Respectfully submitted, KNIGHT & ASSOCIATES, P.C. Sean M. Shultz, Esquire Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorney for Plaintiff J, . , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, Plaintiff V. MICHAEL P. KEEFER, Defendant CIVIL ACTION - LAW NO. 03-3027 IN DIVORCE CERTIFICATE OF SERVICE AND NOW, thisZ(O?ay of August, 2008, I, Sean M. Shultz, Esquire, hereby certify that I have this day served the following with a copy of the foregoing Praecipe by first class, United States Mail, addressed as follows: Charles Rector, Esquire Law Offices of Charles Rector, Esquire, P.C. 1104 Fernwood Avenue, Suite 203 Camp Hill, Pennsylvania 17011-6912 Attorney for Defendant Respectfully submitted, KNIGHT & ASSOCIATES, P.C. Sean M. Shultz, Esquire Attorney I.D. No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorneys for Plaintiff F:\User Folder\Firm DocsVie is Files\PWi Amy Keefer\praccipe.l.wpd N _ ? G'7 t l r; - ...r Ul IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. AMY C. KEEFER. Plaintiff VERSUS MICHAEL P. )E'ER, N 0. 03-3027 Defendant DECREE IN DIVORCE AND NOW, ?yokaL ? DECREED THAT AMY C. KEEFER 2008, IT IS ORDERED AND AND MICHAEL P. E'ER ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; n/a ARY -V -0?14? O?V -,R /V - OW *V -,,oz ^e-v>,w Aw -'JeT Petition to Withdraw as Legal Counsel Prepared By: Diane G. Radcliff, Esquire 3448 Trindte Road, Camp Hit[, PA 17011 Supreme Court ID # 32112 Phone: 717-737-0100 • Fax: 717-975-0697 • Email: dianeradcliff @comcast.net Attorney for Defendant, Michael P. Keefer IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, Plaintiff NO. 03-3027 CIVIL TERM V. CIVIL ACTION - LAW MICHAEL P. KEEFER, IN CUSTODY Defendant PETITION TO WITHDRAW AS LEGAL COUNSEL AND NOW, this day of , 2008, comes the Petitioner, Diane G. Radcliff, Esquire and files the above referenced Petition and represents that: 1. Your Petitioner is Diane G. Radcliff, Esquire an attorney duly authorized to practice law in the Commonwealth of Pennsylvania and having a principal place of business located at 3448 Trindle Road, Camp Hill, PA 17011. Petitioner is hereafter referred to as "Attorney Radcliff". 2. Plaintiff is Amy C. Keefer and is currently represented by Sean M. Shultz, Esquire. Amy C. Keefer is hereafter referred to as "Plaintiff" 3. Defendant is Michael P. Keefer and is currently represented by Attorney Radcliff. Michael P. Keefer is hereafter referred to as "Defendant". 4. This is a Domestic Relations action including divorce and custody, the divorce portion having been resolved by the entry of a decree in divorce on 9/3/08. 5. Since 7/10/03 Defendant has been represented by Charles Rector, Esquire, in these proceedings including but not limited to representation in the 2004 and 2005 custody proceedings and in finalizing the divorce in September, 2008. 1 6. Attorney Rector has never withdrawn his appearance on behalf of Defendant in this case. 7. On or about 7/24/08, Attorney Radcliff was retained by Defendant for the sole purpose of assisting him at the 7/29/08 Custody Conciliation Conference. 8. It was agreed by Attorney Radcliff and Defendant that after the Conciliation Defendant would decide if he wanted Attorney Radcliff to represent him in any further custody proceedings, and if so, a retainer fee was required to be paid by Defendant to Attorney Radcliff. 9. Attorney Radcliff attended the 7/28/08 Custody Conciliation Conference with Defendant and at that conference advised the Custody Conciliator and Plaintiff's counsel, Attorney Shultz, that by attending the conference she was not officially entering her appearance on behalf of the Defendant, just assisting him, and all notices and orders resulting from the conference were to be sent directly to Defendant. 10. As the result of the 7/28/08 conciliation conference an Order dated 7/31/08 was entered by the Honorable Kevin A. Hess, scheduling the case for hearing on 10/30/08. 11. The 7/31/08 Order references Attorney Radcliff as Defendant's attorney even though no official entry of appearance was ever filed and Attorney Radcliff specifically advised the Conciliator that she was not entering her appearance in this case. 12. Attorney Radcliff did not put that hearing date in her calendar since she had not been retained by Defendant but rather sent a letter to him on 8/4/08 providing Defendant with a copy of the 7/31/08 Order and advising him that if he wanted Attorney Radcliff to represent him at the 10/30/08 hearing he would have to sign and return the enclosed fee agreement and pay Attorney Radcliff the retainer fee referenced therein. 13. Attorney Radcliff has not heard from Defendant since she sent her 8/4/08 letter to him. 14. Defendant has not signed the fee agreement nor paid the required retainer. 15. Attorney Radcliff cannot attend the 10/30/08 hearing since she is scheduled to be out of the country from 10/23/08 through 10/30/08. 16. Attorney Radcliff provided Plaintiff's Attorney with a copy of this Petition prior to filing and Plaintiff's attorney has not responded to her. 17. Attorney Radcliff provided Defendant with a copy of this petition prior to filing and Defendant has not responded. 2 18. The only judge involved in this case is the Honorable Kevin A. Hess, who entered all of the custody orders and entered the divorce decree in this case. WHEREFORE, the Petitioner respectfully requests this Honorable Court to enter an Order granting her leave to withdraw as legal counsel for Defendant, Michael P. Keefer. Respectfully submitted, ,01 NE G. RA LIFF, ESQUIRE e Road Camp Hill, PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 3 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. FF, ESQUIRE 4 CERTIFICATE OF SERVICE AND NOW, this ,?day of JQ? , 2008, I, DIANE G. RADCLIFF, ESQUIRE, hereby certify that I have this day served a copy of the foregoing document upon the following named person(s), by mailing same by first class mail, postage prepaid, addressed as follows: Michael P. Keefer 401 Lopax Road, Apt. G2 Harrisburg, PA 17112 (Defendant) Sean M. Shultz, Esquire Knight £t Associates 11 Roadway Drive • Suite B Carlisle, PA 17013 (Attorney for Plaintiff) r' r IANE DCLIFF, ESQUIRE 3448-Trrle Road Camp Hill, PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 5 ?- `. ,..# C. -jc "+ co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, Plaintiff V. MICHAEL P. KEEFER, Defendant NO. 03-3027 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY RULE TO SHOW CAUSE AND NOW this ` daY of -r, 2008, upon consideration of the within Petition a Rule is issued upon the Plaintiff, Amy C. Keefer, and the Defendant, Michael P. Keefer, to show cause why Diane G. Radcliff, Esquire should not be granted leave to withdraw as legal counsel for the Defendant, Michael P. Keefer. Rule Returnable .d days after service. JUDGE D! tribution to: torney for Plaintiff: Sean M. Shultz, Esquire, Knight 8 Associates, 11 Roadway Drive • Suite B, Carlisle, PA 17013 torney for Defendanane G. Radcliff, Esquire, 3448 Trindle Road, Camp Hill, PA 17011 efendant: Michael P. Keefer, 401 Lopax Road, Apt. G2, Harrisburg, PA 17112 .++ frA Al 'J V /J t??'~ yjJ?L I W 9-130 HE 31U ?O IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, V. Plaintiff NO. 03-3027 CIVIL TERM : CIVIL ACTION - LAW MICHAEL P. KEEFER, IN CUSTODY Defendant CERTIFICATE OF SERVICE I, DIANE G. RADCLIFF, ESQUIRE, hereby certify that on October 2. 20089 I served a true and correct copy ofthe Petition to Withdraw as legal Counsel, filed on October 1, 2008, upon Defendant and upon Plaintiff's attorney, by mailing same by first class mail, postage prepaid, addressed as follows: Michael P. Keefer 401 Lopax Road, Apt. G2 Harrisburg, PA 17112 (Defendant) Sean M. Shultz, Esquire Knight & Associates 11 Roadway Drive • Suite B Carlisle, PA 17013 (Attorney for Plaintiff) I further certify that on October 7.2008,1 served a true and correct copy of the Rule dated October 6, 2008 entered regarding the aforesaid Petition to Withdraw as legal Counsel upon Defendant and upon Plaintiff's attorney, by mailing same by first class mail, postage prepaid, addressed as follows: Michael P. Keefer 401 Lopax Road, Apt. G2 Harrisburg, PA 17112 (Defendant) s Sean M. Shultz, Esquire Knight & Associates 11 Roadway Drive • Suite B Carlisle, PA 17013 (Attorney for Plaintiff) True and correct copies of the cover letters for the aforesaid service are attached hereto and made a part hereof. G. RADCLIFF, E UIRE FF. 3448 Trindle Road, Camp'Hill, PA 1701 Phone: 717-737-0100 Fax: 717-975-0697 E-mail: dianeradcliffCcomcast.net October 2, 2008 Sean M. Shultz, Esquire Knight Ft Associates 11 Roadway Drive • Suite B Carlisle, PA 17013 Michael P. Keefer 401 Lopax Road, Apt. G2 Harrisburg, PA 17112 Re: Amy C. Keefer vs. Michael P. Keefer Cumberland County Custody No. 03-3027 Gentlemen L] Enclosed is a time stamped copy of the Petition to Withdraw filed with the Court on October 1, 2008. A copy of the Order will be sent to you upon entry. Should Mr. Keefer hire replacement counsel please advise me immediately. Please also note that I will be out of the country on the scheduled hearing date. Very truly yours, DIANE G. RADCLIFF, ESQUIRE DGR/dr Enclosure(s): Transmitted to Addressee by mail cc: File 73-08-C s Duplicate Duplicate Duplicate -2- FF 3448 Trindle Road, Camp Hill, PA 1701 Phone: 717-737-0100 Fax: 717-975-0697 E-mail: dianeradcliff@comcast.net October 7, 2008 Sean M. Shultz, Esquire Knight Et Associates 11 Roadway Drive • Suite B Carlisle, PA 17013 Michael P. Keefer 401 Lopax Road, Apt. G2 Harrisburg, PA 17112 Re: Amy C. Keefer vs. Michael P. Keefer Cumberland County Custody No. 03-3027 Gentlemen: Enclosed is a time stamped copy of the Rule entered on October 6, 2008 on my Petition to Withdraw as Legal Counsel. Should either of you not oppose this request I would appreciate it if you would sign the enclosed "Consent" form and return it to my office in the envelope provided. If both of you sign this Consent form, then I will ask the court to enter an immediate order permitting my withdrawal. Very truly yours, DIANE G. RADCLIFF, ESQUIRE DGR/dr Enclosure(s): 10/6108 Rule Consent Farm Return Envelope Transmitted to Addressees by mail cc: File 73-08-C - ?` z3 r? ? .-r-E ,.._., 7',-=" C.:3 ",` . ?: ?. ; ?` ?' .., ? ; Motion to Make 10.6.08 Rule Absolute re Petition to Withdraw as Defendant's Legal Counsel Prepared By: Diane G. Radcliff, Esquire 3448 Trindle Road, Camp Hill, PA 17011 Supreme Court ID # 32112 Phone: 717-737-0100 • Fax: 717-975-0697 • Email: dianeradcliff @comcast.net IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, Plaintiff NO. 03-3027 CIVIL TERM V. CIVIL ACTION - LAW MICHAEL P. KEEFER, IN CUSTODY Defendant MOTION FOR RULE ABSOLUTE RE PETITION TO WITHDRAW AS LEGAL COUNSEL Diane G. Radcliff, Esquire, Attorney for Defendant, Michael P. Keefer, hereby moves this Honorable Court to make the Rule entered on October 6, 2008 absolute and to grant Diane G. Radcliff, Esquire leave to withdraw as legal counsel and attorney of record for Defendant, and assigns the following reasons therefor: 1. On October 1, 2008, your Petitioner, Diane G. Radcliff, Esquire filed a Petition seeking to withdraw as legal counsel for Defendant, Michael P. Keefer. 2. On October 2, 2008 Plaintiff served a true and correct copy of the Petition upon Defendant, Michael P. Keefer, and upon Plaintiff's Attorney, Sean, M. Sultz, Esquire. 3. On October 6, 2008, this Honorable Court entered a Rule against the Respondents, Defendant, Michael P. Keefer and Plaintiff, Amy C. Keefer, to show cause why the requested relief should not be granted, which Rule was returnable twenty (20) days after service. e 4. On October 7, 2008, The Petitioner, Diane G. Radcliff, Esquire, served a true and correct copy of the Petition and Rule upon the Respondents. 5. The 20 day time period provided in the October 6, 2008 Rule expired on October 27, 2008. 6. More than twenty (20) days have elapsed since the Petition and Rule were served on the Respondents. 7. No Answer to the Rule has been filed by the Respondent, Michael P. Keefer. 8. Plaintiff by her attorney has consented to the withdraw as evidenced by the consent form attached hereto, marked Exhibit "A" and made a part hereof. 9. Since Respondent, Michael P. Keefer failed to file a timely answer to the Rule and Plaintiff has consented to the withdrawal, this Court should make the Rule absolute and grant Petitioner leave to withdraw as legal counsel for Defendant. 10. The only judge assigned to this case is the Honorable Kevin A. Hess. 11. Petitioner notified the parties of the intended filing of this motion on 10/27/08 Wherefore, Petitioner, Diane G. Radcliff, Esquire respectfully requests this Honorable Court to make the Rule entered on October 6, 2008, absolute and grant her leave to withdraw as legal counsel and attorney of record for Defendant, Michael P. Keefer. Respectfully submitted, ;DIANE. G. RAD LIFF, ESQUIRE 37-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 CERTIFICATE OF SERVICE AND NOW, this ern day of October, 2008, I, DIANE G. RADCLIFF, ESQUIRE, hereby certify that I have this day served a copy of the foregoing document upon the following named person(s), by mailing same by first class mail, postage prepaid, addressed as follows: Michael P. Keefer 401 Lopax Road, Apt. G2 Harrisburg, PA 17112 (Defendant) Sean M. Shultz, Esquire Knight Ft Associates 11 Roadway Drive • Suite B Carlisle, PA 17013 (Attorney for Plaintiff) )CLIFF, ESQUIR Road Camp Hill, PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 EXHIBIT "A" Consent to Withdraw as Legal Counsel Prepared By: Diane G. Radcliff, Esquire 3448 Trindle Road, Camp Hill, PA 17011 Supreme Court ID # 32112 Phone: 717-737-0100 • Fax: 717-975-0697 • Email: dianeradcliff @comcast.net Attorney for Defendant, Michael P. Keefer IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, Plaintiff NO. 03-3027 CIVIL TERM V. CIVIL ACTION - LAW MICHAEL P. KEEFER, IN CUSTODY Defendant CONSENT TO THE WITHDRAWAL OF DIANE G. RADCLIFF, ESQUIRE AS DEFENDANT'S LEGAL COUNSEL 1, Sean M. Shultz, Esquire, attorney for Plaintiff in the above captioned matter having been served with a copy of the Petition to Withdraw as Legal Counsel and the Rule entered on that Petition on October, 6, 2008, hereby consent to the withdrawal of Diane G. Radcliff, Esquire as Defendant's legal counsel and authorize the Court to enter an Order granting Diane G. Radcliff, Esquire leave to withdraw as Defendant's legal counsel. ?-SLA 5? - Sean M. Shultz, Esquire Knight Et Associates 11 Roadway Drive • Suite B Carlisle, PA 17013 (Attorney for Plaintiff) C'? ^v t-- ? ?? :., ' 't`r ? '- - r7 c i --?r r= C:;.r ? t :R'x+ r ?? .. _. .i .. ?..? i?J "S' .. OCT 2 8 20086 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY C. KEEFER, Plaintiff NO. 03-3027 CIVIL TERM V. CIVIL ACTION - LAW MICHAEL P. KEEFER, IN CUSTODY Defendant ORDER AND NOW this Z 5' day of O041 b v , 2008, there being no Answer filed to the Rule entered on October 6, 2008, of Diane G. Radcliff Esquire to withdraw as legal counsel, upon Motion of Diane G. Radcliff, Esquire, IT IS HEREBY ORDERED AND DECREED that: 1. The Rule entered on October 6, 2008 on Diane G. Radcliff Esquire's Petition to Withdraw as Legal Counsel is made absolute. 2. Diane G. Radcliff Esquire is hereby granted leave to withdrawal as legal counsel and attorney of record for Defendant, Michael P. Keefer. Distribution to: ? P itioner: Diane G. Radcliff, Esquire, 3448 Trindle Road, Camp Hill, PA 17011 Defendant: Michael P. Keefer, 401 Lopax Road, Apt. G2, Harrisburg, PA 17112 ?torney for Plaintiff: Sean M. Shultz, Esquire, Knight Ft Associates, 11 Roadway Drive * Suite B, Carlisle, PA 17013 'eCL 1. Its rn?; t( l0`?.3`D8 BY THE COURT / cI r co -: } LLS G.3 v -1 C AMY C. KEEFER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 03-3027 CIVIL MICHAEL P. KEEFER, Defendant IN CUSTODY ORDER AND NOW, this day of November, 2008, after hearing, on agreement of the parties as announced in open court and in their presence, it is ordered and directed as follows: 1. Legal Custody. The parties, Amy C. Keefer and Michael P. Keefer, shall have shared legal custody of the minor children, Christopher Allen Keefer, born December 31, 1996, and Megan Andrea Keefer, born May 31, 2000. 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. Pursuant to the terms of Pa.C.S.A. 5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to, medical, dental, religious or school records, the residence address of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or r r educational records, attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school night, and the like. 2. Physical Custody. The mother, Amy C. Keefer, shall have primary physical custody of the children, Christopher and Megan, with periods of partial custody in the father, Michael P. Keefer, as follows: a. Beginning on November 7, 2008, the father shall have periods of partial physical custody on alternating weekends from Friday at 5:00 p.m. until Sunday at 7:00 p.m. The father's weekend shall extend to Monday at 5:00 p.m. if the children have a Monday holiday from school. b. The father shall have physical custody of the children for one week during the summer vacation. The father shall give the mother written notice of same by May 30th of each year. c. The father shall have a period of partial physical custody on Father's Day from 9:00 a.m. until 6:00 p.m. Mother shall have physical custody on Mother's Day from 9:00 a.m. until 6:00 p.m. d. The parties will alternate Thanksgiving Day with the mother having custody for Thanksgiving Day in even-numbered years and the father having custody for Thanksgiving Day in odd-numbered years. e. Custody for Christmas will be shared between the parties on an alternating basis. Segment A shall be from December 24th at 8:00 p.m. until December 25 th at 2:00 p.m. Segment B shall be from December 25th at 2:00 p.m. until December 26th at 8:00 p.m. The parent with custody during Segment B shall also be entitled to a period of partial custody on Christmas Eve which shall end at 8:00 p.m. and begin after that parent ends work for Christmas Eve. In odd-numbered years mother shall have Segment A and father shall have Segment B. In even-numbered years, father shall have Segment A and mother shall have Segment B. 3. Neither party shall make derogatory statements regarding the other party while in the presence of the children. BY THE COURT, Sean Shultz, Esquire For the Plaintiff 'Michael P. Keefer, Pro Se Defendant Am 0-oz C V-s nsa t h'-L 1/14(100 4` ? +;~,. t"? ., !` 1?. :`?'.. - t? ??? _ ?'p ?1`? w.. i ?or 1:.?. -'A?