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Home My WebLink About99-05889r. i {r f,' /dr G, r 5 r y : ?. r p?? , ?r r Y µ l ?'s5 1 r . ?? AA Sy A <ru ^^ N ++ Ada. ( Y+. W r f` > 'Pr A?4r? 1 , +Ay { J s ;; s. 19 4 n1wvwLe 1N04h4ft1.wwd,w wpd sw.. u, Im MICHAEL G. SHENK, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. qC1 at?L DIANE CAROL REGAN SHENK, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before 1kK_\7 r R Esquire, Conciliator, at the S, ?R?,, t ?0 hp ??` Pennsylvania, on the day of )c1\ 1999, at 9; n o Q .m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or, if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter intoa temporary Order. o Either party may bring the child who is the subject of this custody acticr to the onf ence, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT DATEDAIa?Pq BY: Y% Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 rf Fo-o -;. --F OF 7L.' ;4^rr• l :9'S.P2 9 ri1 ?;?S Lfr.l.ri 9a9?99 ??? ,?? l 9a99? ?, ?? Al. H WPTLEADIN ems•muddym wpd MICHAEL G. SHENK, Plaintiff V. DIANE CAROL REGAN SHENK, Defendant s.ywn .n. Im IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. QQ_ 5 RFC? CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY Plaintiff is Michael G. Shenk, residing at 4 West Red Gold Circle, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is Diane Carol Regan Shenk, residing at 525 Fairway Drive, Camp Hill, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following children: Name Present Address Aee Jillian Shenk 4 West Red Gold Circle 10 Camp Hill, PA 17011 Danielle Shenk 4 West Red Gold Circle 7 Camp Hill, PA 17011 4. The children were not bom out of wedlock. The children are presently in the custody of Plaintiff, who resides at 4 West Red Gold Circle, Camp Hill, Cumberland County, Pennsylvania. 5. During the past five (5) years, the children have resided with the following persons at the following addresses: 11AW9wLE MOWmk-anodym wpd Sqw wU, 1999 Name Address Dates Michael and Diane Shenk 4 West Red Gold Circle 1990 to Camp Hill, PA September, 1999 Michael Shenk 4 West Red Gold Circle September, 1999 Camp Hill, PA to present 6. The mother of the children is currently residing at 525 Fairway Drive, Camp Hill, Cumberland County, Pennsylvania. She is married. 7. The father of the children is currently residing at 4 West Red Gold Circle, Camp Hill, Cumberland County, Pennsylvania. He is married. 8. The relationship of Plaintiff to the children is that of father. Plaintiff currently resides with the following persons: Name Relationship Jillian Shenk Daughter Danielle Shenk Daughter 9. The relationship of Defendant to the children is that of Mother. Defendant currently resides with the following persons: w' Name Relationship No One 10. Plaintiff has not participated as a party or a witness, or in any other capacity in other litigation concerning the custody of the children in this or any other Court. r? 11. Plaintiff has no information of a custody proceeding concerning the children r? i.r?{FY A ?, H VPTLewwrnuat. M" ca vpd pending in a court of this Commonwealth. SIVMbo 21, IM . 12. Plaintiff 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. 13. The best interest and permanent welfare of the children will be served by granting the relief requested. 14. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant him primary custody of the children. Respectfully Dated: September 22, 1999 /app k.P Maria P. C gnetti uire Sup. Ct. I.D. 4279 200 North Third Street Twelfth Floor P.O. Box 689 Harrisburg, PA 17108-0689 (717) 232-2103 VERIFICATION I, MICHAEL G. SHENK, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn verification to authorities. MICHAEL G. SHENK DATE: 9- as - q 9 cc?-! f ( A' N ` T \X r M t1. L J i] Iu Il. .. m 7 T^, W O Gn C) J ' J° Cognetti & Braderman P,O.Oox 689 Hmrisburg, PA 171084689 SEP 2 7 1999 (717)232.2103 • (717)232-6600 FAx(717) 232.5775 MICHAEL G. SHENK, V. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA DIANE CAROL REGAN SHENK, Defendant TO THE PROTHONOTARY: NO. 99-5889 CIVIL CIVIL ACTION - LAW IN CUSTODY PRAECIPE Kindly correct the Defendant's name in the above-captioned matter to reflect the following spelling: DYAN CAROL REGAN SHENK. Dated: October 15, 1999 Maria P. C gnetti, s ire Sup. Ct. I.D. #27914 200 North Third Street Twelfth Floor P.O. Box 689 Harrisburg, PA 17108-0689 (717) 232-2103 .I F= w9 N ?Q u-(%- In N -;'gin -1z Ll,; 1- :Z1tU c U k "eK 4? H WpTLUDMMkenk•.e d wpd MICHAEL G. SHENK, Plaintiff V. f Ona 27, Im IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-5889 CIVIL DYAN CAROL REGAN SHENK, : CIVIL ACTION -LAW Defendant : IN CUSTODY AFFIDAVIT OF SERVICE I, MARIA P. COGNETTI, ESQUIRE, do hereby certify that a true and correct copy of the Complaint for Custody was served upon the Defendant by certified mail, return receipt requested, on the 18th day of October, 1999. The original signed return receipt, number P 397 742 720, is attached hereto and made a part hereof. Sworn to and subsch'bed bef a me this Rr day of 1999. Maria P. gnetti, uire Sup. Ct. I.D. #279 4 200 North Third Street Twelfth Floor P.O. Box 689 Harrisburg, PA 17108-0689 (717)232-2103 my aomrmecon Expires March 0, 2002 Member, Pen 0M1a Assa iabm 01 Plurafias >` e• .camptw aims t or s ror sdatlaW as rk.s. eponpWa MM 3,4e, artd fib. d*wondumand wsfamr?oOW"Cenrdwnd" A I dso WIWh to receive the fogoW g services (tor an e*afee): i * ¦G .Font yoywnwrte M tw was A p.u does not oe r eAowMtotes" of the meppeo. a ' S .Ap d e 1.O Addressee's Address. t ? ? a s. p p? ! .yew•Rarwm AwWM p•Ws»m NpTM below ttsemcle n.mwr. .1Tw ROM Raodpt vAA Omto"Mtw article was dWVWW end the date 2. C3 Restricted Delivery = • (,'enetlli ppAbnae[ef for iBB. Mats& 3. Arlds Addroeeed to: 4F 5 40 /7i0sC. , fj 1 4a. a Nurnber 39 ' y Sao 4b. Service Type / r J // I Ca,Cil y?fG,lzl 7620 77 Ja?? 0 Registered ca Mall ' ? I 4r, $: 3?? c M?KG?„?c ReWlnReagtaMetdteridse C3 000 s. nSASv? ?? 1,710 / ' au Ow 999yyy /n? ?j' J? ? / '? r !J S. Addressee's Address (OMyHregtxstetl and fee is paid) 'a t. SlgneWre: (Addresses or Agent) X . a PS Form 3811 r December 1994 Domestic Retum Race pt t .. __ lL" p . F., i. t J I ? MICHAEL G. SHENK, ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA VS. ) NO. 99-5889 CIVIL TERM DYAN CAROL REGAN SHENK, ) Defendant ) CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, this z Y ' day of lVrvc,.,&y 1999, upon receipt of the Conciliator's Report, it appearing that the parties have agreed to the terms and provisions of this interim Order which was dictated in their presence and approved by them and their counsel, it is hereby ordered and directed as follows: 1. The parties shall share legal custody of the minor children, Jillian, d.o.b. February 6, 1989, and Danielle, d.o.b. November 12, 1992. 2. The parties shall share physical custody of the minor children on a week-on, week-off schedule. The switch day shall be Sunday at 12:00 p.m. Additionally, each party shall be entitled to Wednesday overnight during their off weeks, from after school on Wednesday until Thursday, at which time the children will be taken to the appropriate bus stop for school. 3. The parties agree that the children shall remain in the East Pennsboro School District and that the bus stop shall remain at the current location. 4. The parties agree to share the Thanksgiving holiday whereby Mother shall have the children from their release from school until Thanksgiving Day at 'FILED^CFFICE 10F 0NCTAAY 99 h0V 24 011:30 CUN6Ei,u;.C CUUN Y PENNSYLVAjNI!A 9:00 a.m.; Father shall then have the children from Thanksgiving Day at 9:00 a.m. until Sunday, November 28, 1999, at 12:00 p.m. 5. The parties agree to evenly share the Christmas holiday. The Christmas holiday is defined from the children's release from school until the Sunday prior to their return to school. 6. Both parties agree that during this interim Order they will ensure that the children have no contact with any third-party paramours of the individual parties. The parties are encouraged during this interim period and thereafter that if they have any difficulties related to the custodial arrangements with the children, that they shall engage a mediator or another appropriate individual to help them work through any of those issues. 7. The parties shall reconvene for a custody conciliation conference before Michael L. Bangs, Esquire, on Thursday, March 2, 2000, at 9:00 a.m. BY THE COURT, X. J. Maria P. Cognetti, Esquire Paul J. Esposito, Esquire -A.19 mlb MICHAEL G. SHENK, ) Plaintiff ) VS. ) DYAN CAROL REGAN SHENK, ) Defendant ) JUDGE PREVIOUSLY ASSIGNED: None IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-5889 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child(ren) who is(are) the subject of this litigation is as follows: NAME Jillian Shenk Danielle Shenk CURRENTLY IN CUSTODY OF Plaintiff Plaintiff 2. A Conciliation Conference was held on November 11, 1999, and the following individuals were present: the Plaintiff and his attorney, Maria P. Cognetti, Esquire; the Defendant and her attorney, Paul J. Esposito, Esquire. 3. Items resolved by agreement: See attached Order. 4. Issues yet to be resolved: See attached Order. 5. The Plaintiff's position on custody is as follows: See attached Order. 6. The Defendant's position on custody is as follows: See attached Order. 7. Need for separate counsel to represent child(ren): Neither party requested. 8. Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe any is necessary. 9. Other matters or comments: The parties shall reconvene for a custody conciliation conference before Michael L. Bangs, Esquire, on Thursday, March 2, 2000, at 9:00 a.m. Date: November 19, 1999 Michael L. Bangs Custody Conciliator 111 Nnv 2 2 MAR 1 4 2000 a" MICHAEL G. SHENK, Plaintiff VS. DYAN CAROL REGAN SHENK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-5889 CIVIL TERM CIVIL ACTION - LAW ORDER AND NOW this ,1- day of ? , 2000, it being reported to the Conciliator that the parties have reached an agreement which makes further proceedings unnecessary, the undersigned Conciliator hereby relinquishes jurisdiction and returns the matter to the Court Administrator. If either of the parties wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, AV 1 MICHAEL L. BANGS Custody Conciliator cc: Maria P. Cognetti, Esquire Ann Levin, Esquire o } '' -x S 0 ?? ? ? 4 O r O tir'F': ? '?Z W O O O Q V