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STEVEN C. SINGISER, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
: CUSTODY/VISITATION
SHERRE L. SINGISER,
Defendant : NO. 99.34/S'3 CIVIL TERM
ORDER OF COURT
AND NOW, C I \G 19Q , 1999, upon consideration of the attached Complaint, it is hereby
directed that the parties and their respective counsel appear before
the conciliator, at -zn \j, ? Aa t!1
PAon the day of, 1999, at 3 o'clock,
4L. in., for a re-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.
FOR THE COURT:
By: 9 5(V ct?jb
Custody Conciliator (j?l
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with
Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All
arrangements must be made at least 72 hours prior to any hearing or business before the court. You must
attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Office of the Court Administrator
Cumberland County Court House, Fourth Floor
Carlisle, PA 17013
(717) 240-6200
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STEVEN C. SINGISI?R, JR.,
Plaintiff
v.
SHERRE L. SINISER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
CUSTODY/VISITATION
NO. 99- -iYS3 CIVIL TERM
COMPLAINT FOR CUSTODY
1. The Plaintiff is Steven C. Singiser, Jr., residing at 807-B West Valley Street, Mechanicsburg,
Cumberland County, Pennsylvania 17055.
2. The Defendant is Sherre L. Singiser, residing at RR #2 Box 427, Richfield, Juniata County,
Pennsylvania 17086.
3. Plaintiff seeks custody of the following child:
NAME RESIDENCE DOB AGE
Cheyene Rena Singiser RD. 92 Box 427, Richfield, PA 17086 12/2/93 5 yrs. 6 months
A. Child resides at 607 Williams Grove Road, Cumberland County, Pennsylvania,
approximately 3 or 4 days per week. That residence is that of the child's maternal grandparents Mr. and
Mrs. Richard Wise. Wile this appears to be a "babysitting arrangement", Plaintiff respectfully alleges, as
her father, he could provide the same or better care of the child.
B. Child resides at 307 Sandbank Road, Mt. Holly Springs, Cumberland County,
Pennsylvania, at the residence of the child's Aunt, Ms. Shelly Wise, anywhere from one to two days per
week.
C. The child was not burn out of wedlock.
D. The child is presently in the partial custody of the Defendant, her mother, Sherre L. Singiser
4. During her life, the child has resided with the following persons and at the following
addresses:
NAME ADDRESS DAIT:S
A. Steven C. Singiser and
Sherre L. Singiscr 807-B West Valley Street, Mechanicsburg, PA 17055 12/93 to 12/95
B. Sherre L. Singiscr RR #2 Box 427, Riehardf ield, PA 17086 12/95 to present
(Also, see 3A and 3B above)
5. The mother of the children is Sherre L. Singiser, currently residing at RR #2 Box 427,
Richfield, Pennsylvania 17086. She is re-married.
6. The father of the children is Steven C. Singiser, currently residing at 807-B West Valley
Street, Mechancisburg, Pennsylvania 17055. lie is presently unmarried, however he is engaged to be married
at a date yet to be decided.
7. The relationship of the Plaintiff to the child) is that of father.
8. The Plaintiff currently resides with the following persons:
A. Bobbie Mundt, fiane6;
B. Echo Marie Mundt, minor child of Bobbie Mundt;
C. Destiny Lee Mundt, minor child of Bobbie Mundt.
9. The relationship of the Defendant to the child is that of mother.
10. The Defendant currently resides with the following persons:
A. Andy Griffith, Husband;
B. Hunter Griffith, minor child of Andy Griffith.
11. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation
concerning the custody of the child in this or another court.
12. Plaintil7'bas no iNbrmation ofn custody proceeding concerning the child pending in a
court of this Commonwealth.
13. Plaintiff does not know or a person nor a party to the proceedings who has physical custody
of the child or claims to have custody or visitation rights with respect to the child.
14. The best interest and permanent welfare of the child will be served by granting the relief
requested for the following reasons:
A. A Count Order of custody and structured visitation is desired so that Plaintiff and the
child may plan their schedules accordingly, and so that misunderstandings and unmet expectations
regarding custody and visitation can be avoided, and also so that the child are not used in a
manipulative fashion.
15. Each parent whose parental rights to the child have not been terminated and the person
who has physical custody of the child has been named as parties to this action.
WHEREFORE, Plaintiff requests the Court to grant shared legal and periods of partial physical
custody of the child to Plaintiff.
Respe ully nutted,
By:
Paul Bradford Orr, Esq.
Attorney for Plaintiff
50 East High Street
Carlisle, PA 17013
Telephone: (717) 258-8558
Supreme Court 1D No. 71786
COMMONWEALTH OF PENNSYLVANIA )
: SS.
COUNTY OF CUMBERLAND )
1 verify that the statements made in the foregoing Complaint are true and correct. 1 understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom
falsification to authorities.
DATE: zC roz -?C ,
Steven C. Singiser, k. , laintiff
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STEVEN C. SINGISER, JR., : IN THE COURT OF COMMON PLEAS OF f
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
CUSTODY/VISITATION
SHERRE L. SINGISER,
Defendant :NO.99-3q 53 CIVIL TERM
i
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF CUMBERLAND )
AND NOW, this 14th day of June, 1999, I Paul Bradford Orr, Esquire, attorney for Steven C.
Singiser, Jr., Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the
Complaint for Divorce and Order of Court, executed by the Plaintiff in the above-captioned matter, upon
the Defendant by depositing the same in the U.S. Mail, postage prepaid, certified, deliver to addressee
only, return receipt requested. The original return receipt card signed by the Defendant on April 10,
1999 indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof.
LAW-QFFICES OF PAUL$RA D ORR
By:
Paul Bradford rr, Esquire
Attorney for Plaintiff
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STEVEN C. SINGISER, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : NO. 99-3453 CIVIL TERM
SHERRE L. SINGISER, CIVIL ACTION - LAW
Defendant a IN CUSTODY
ORDER OF OMW
AMID NOW, this day of
consideration of the attached Custody COncti iation Report, it is9orderreedd
and directed as follows:
1. The Father, Steven C. Singiser, Jr., and the Mother, Sherre L.
Griffith, (formerly Singiser) shall have shared legal custody of Cheyene
Rena Singiser, born December 2, 1993. Each parent shall have an equal
right, to be exercised jointly with the other parent, to make all major
non-emergency decisions affecting the child's general well-being including,
but not limited to, all decisions regarding her health, education and
religion.
2. The Mother shall have primary physical custody of the child.
3. The Father shall have partial physical custody of the Child on
alternating weekends from Friday at 4:00 p.m. through Sunday at 6:00 p.m.,
and any additional times as arranged by agreement of the parties.
Beginning in 2000, the parties shall share having custody of the Child
during the summer school break on an alternating weekly basis with the
exchange of custody to take place each week on Friday at 6:00 p.m. The
summer custody schedule shall begin the first full week after the end of
the school year and shall terminate one full week before the new school
year begins.
4. The parties shall share or alternate having custody of the Child
on holidays as follows:
A. CHRISIpM: The Christmas holiday shall be divided into
Segment A, which shall run from Christmas Eve at 10:00 a.m.
through Christmas Day at 10:00 a.m., and Segment B, which
shall run from Christmas Day at 10:00 a.m. through December
26 at 10:00 a.m. The Father shall have custody of the Child
during Segment A in odd numbered years and during Segment B
in even numbered years. The Mother shall have custody of
the child during Segment A in even numbered years and during
Segment B in odd numbered years.
3. THANKSGIVING: The Thanksgiving holiday shall be divided
into Segment At which shall run from after school on the
Wednesday before Thanksgiving through Thanksgiving Day at
10:00 a.m., and Segment B, which shall run from Thanksgiving
S
Day at 10:00 a.m. through the following Friday at 12:00
noon. The Father shall have custody of the Child during
Segment A in odd numbered years and during Segment B in even
numbered years. The Mother shall have custody of the Child
during Segment A in even numbered years and during Segment B
in odd numbered years.
C. EASTER SUNDAY: Both parties shall have a period of custody
with the Child on Easter Sunday each year as arranged by
agreement between the parties.
D. MEMORIAL DAY/LABOR DAY: The party who otherwise has custody
of the Child under the regular alternating weekend schedule
over the Memorial Day and Labor Day weekends shall retain
custody of the Child through the day of the holiday until
6:00 p.m.
E. JULY 4TH: The Mother shall have custody of the Child on
July 4th from 10:00 a.m. until 6:00 p.m. in odd numbered
years and the Father shall have custody of the Child on July
4th from 10:00 a.m. through 6:00 p.m. in even numbered
years.
F. MDTHMIS DAY/FATHER'S DAY: The Mother shall have custody of
the Child every year on Mother's Day from 10:00 a.m. until
6:00 p.m. and the Father shall have custody of the Child
every year on Father's Day from 10:00 a.m. until 6:00 p.m.
5. Unless otherwise agreed between the parties, the party
relinquishing c-austody of the Child shall be responsible to provide
transportation for the exchange of custody to the other party's residence.
6. Both parties shall refrain from using illegal drugs or substances
during his or her periods of custody with the Child. Both parties shall
also ensure that third parties refrain from using illegal drugs or
substances in the presence of the Child.
7. Neither party shall have possession of firearms in his or her
residence unless the firearms are maintained in a safe location which is
inaccessible to the Child.
8. This order is entered pursuant to an agreement of the parties at a
Custody Conciliation Conference. The parties may modify the provisions of
this order by mutual consent. In the absence of mutual consent, the terms
of this order shall control.
BY THE CO ,
cc: Paul B. Orr, Esquire - Counsel for Father
Andrew C. Sheely, Esquire - Counsel for Mother
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STEVEN C. SNGISER, JR.,
Plaintiff
vs.
SHERRE L. SINGISER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3453 CIVIL TERM
CIVIL ACTION - LAW
CUSTODY
CUSDDDY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
NAME DATE OF BIM CURRENTLY IN CUSTODY OF
Cheyene Rena Singiser December 21 1993 Mother
2. A Conciliation Conference was held on July 27, 1999, with the
following individuals in attendance: The Father, Steven C. Singiser, Jr.,
with his counsel, Paul B. Orr, Esquire, and the Mother, Sherre L. Griffith,
(formerly Singiser), with her counsel, Andrew C. Sheely, Esquire.
3. The parties agreed to entry of an order in the form as attached.
Dat--Y= - 7? Dawn S. Sunday, Esquire
Custody Conciliator