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HomeMy WebLinkAbout99-06292 ?? t? : J ??? - y ar. f ?? a"1 r Z }wY} l?_ 3 .. { t i?.r ' ' ir " iy p n +! w i ? ?k s 2 t ? t1?e; ?' L vv?. 'xq (7 ? s ? q 1?.C+1 c x E'er. S ? 4 .: t yi / . L J ° t 3 ? Y? ?'? 4 ?v sV ,EY. w ?F '?YF'? S r w,. r ^"?'? 3 . t k + 1 + e ??-: . \{Stt?.`? I ?) ? .,y x i ?'J`??yw(.K' 3'? J ?y?- ' ' t r ? ? d3'+. .'. •? k 4d fief LS , ? ? ^ ? ? ?(i: 3P ? ? y? ? Y J ? \j ?( ? ?L r _ ? ? ??:. * Y ? S j ? t"? t y c £ ?' j . ( ? t n ! ? Y+'l d yv z}Y, ? ? W ?? y Yj S r ?? ?M , yU +Sr l ? j ? YY1 1 b? ? ) ?v 3:. a { ? . ? m iY V ? v r" r ? a4i e +? ?,?" 4 ? ? 3 t t \t#y? A f#'XY ?J Ylt;t?4, ?? ?i ` 3 r 3 ?c'-3u `F - rii Y f C+ 41c x { f a'1.?. l ' 99 F£? ?? V ! ? `N"? tY'f 1wL 4 Y! t 3?! d ?I L S:". ? i?? Y 1 r? r g Y? I ? ?f ? \ F+ v t?: l ?•rt _ v ip ? w t ? F l 3 ?. -. Z y3 . f 4 ? t.C ' ? tY f' t ' s t Y? w. ? ? ? V: t v(( . ? i. e 1? ? 'Tb+.^ r} M_ . ?;.?? M Ua! f _ ? ? ? ? ? 11??yt _ L ? +lf I ` ? a ?? .? da. S ?. ? .. ? ., 1?P? I? ? 3 St ` \ ? ? 4 ?'. _ ?10.?, ,/ ?r' I (4??.n , ? '. Y 3 % Y t ? ?? 3 r ', t Y? , E Y 'i#i r, ? ? ?. ? ,.: . ? ., { - ?? ` ? ? ? ? ? ? E ? ;?if A?? ?Atj ?F .L - "??? ;' f; KENNETH ALLEN SHEETS, Jr., Plaintiff V. NANCY MARIE SNIPE, Defendant . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY, . PENNSYLVANIA . CIVIL ACTION-CUSTODY NO. 99- AND NOW, 10 j_-,)a19q , upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel , appear before CL1?K1S?.c`cb I A? AL, the conciliator, at U=,'-N on the day of tl,- f 1`-i , 197'1 , at M. M., for a Pre-Hearing-Custody Conference. At such conference an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: d-x1.l sx, 11. n11, Custody Conciliator 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 r 'b dew 1D;41? Af /o ac Ay may' v KENNETH ALLEN SHEETS, Jr., Plaintiff V. NANCY MARIE SHIPE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-CUSTODY NO. 99- You, Nancy Marie Shipe, Defendant, have been sued in court to obtain shared legal custody and visitation, partial physical custody and shared legal custody of the child: Tyler Mark Ships (DOB:8-26-99). You are ordered to appear in person at the Cumberland County Courthouse, Carlisle, PA, Room , on , 1999, at o'clock _.M. for: X_ a conciliation or mediation conference. a pretrial conference. a hearing before the Court. X The presence of the children is not required The presence of the children is required. If you fail to appear as provided by this order or to bring the child, if so ordered, an Order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, FOURTH FLOOR CARLISLE, PA 17011 (717) 240-6200 AMERICAN WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Adams 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. BY THE COURT, Dated: J. 2 KENNETH ALLEN SHEETS, Jr., Plaintiff V. NANCY MARIE SHIPE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-CUSTODY 6.29-2 T? - NO. 99- COMPLAINT FOR CUSTODY 1. The Plaintiff is Kenneth Allen Sheets, Jr., residing at 61 Rake Factory Road, Biglerville, Adams County, Pennsylvania 17307. 2. The Defendant is Nancy Marie Ships, residing at 251 East Crestwood Drive, Apt. B-2., Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff seeks custody of the following child: NAME PRESENT RESIDENCE Tyler Mark Ships 251 East Crestwood Drive, Apt B-2 DOB: 8/26/99 Camp Hill, Pennsylvania The child was born out of wedlock. AGE 2 weeks The child is presently in the physical custody of Defendant, who resides as set forth above. Since birth, the child has resided with the following persons and at the following addresses: LIST OF ALL PERSONS LIST OF ALL ADDRESSES DATES Defendant, Isabella Ships, 251 East Crestwood Drive, Apt B-2 birth and Barbara Ships Camp Hill, PA to present The mother of the child is Nancy Marie Ships, currently residing as set forth above. She is single. The father of the child is Kenneth Allen Sheets, Jr., currently residing as set forth above. He is single. 4. The relationship of Plaintiff to the child is that of natural father. The Plaintiff currently resides with no one. 5. The relationship of Defendant to the child is that of natural mother. The Defendant currently resides with the following persons: NAME Isabella Ships Barbara Ships RELATIONSHIP half-sister maternal aunt 6. 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. Plaintiff has no information of a custody proceeding concerning the child pending in a court of th's Commonwealth other than as set forth above. Plaintiff does not know of a person not 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. 7. The best interest and permanent welfare of the child will he served by granting the relief requested because the child should establish a parental bond with Plaintiff. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. 2 WHEREFORE, Plaintiff requests the Court to grant shared legal custody, visitation and eventual partial physical custody and shared physical custody of the child to him. WOLFE & RICE By: fl u r Patrick W. Quinn, Esq. Attorney for Plaintiff 47 West High Street Gettysburg, PA 17325 717/337-3754 Sup. Ct. ID No. 77412 3 ¦ KENNETH ALLEN SHEETS, Jr., Plaintiff V. NANCY MARIE SHIPE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-CUSTODY NO. 99- V£RIFICAT= I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date:g // 911=?C /L10O?j ennetn Allen Sheets, J ., Plaintiff ?1F e: t , ,: . f f KENNETH ALLEN IN THE COURT OF COMMON PLEAS OF SHEETS, JR., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. CIVIL ACTION - LAW NANCY MARIE SHIPE, Defendant NO. 99-6292 CIVIL TERM ORDER OF COURT AND NOW, this 1 day of October, 1999, upon consideration of Plaintifrs Petition for DNA/Blood Tests To Determine Paternity, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, J. esley 01 , r. Patrick W. Quinn, Esq. 47 West High Street Gettysbi,rg, PA 17325 Attorney for Plaintiff Nancy Marie Shipe 251 East Crestwood Drive Apt. B-2 Camp Hill, PA 17011 Defendant, Pro Se :rc ?. KENNETH ALLEN SHEETS, Jr., Plaintiff/Petitioner V. NANCY MARIE SNIPE, Defendant/Respondent AND NOW, this day of , 1999, upon consideration of the foregoing Petition, it is hereby ORDERED that: 1. A rule is issued upon the Defendant to show cause why the Plaintiff is not entitled to the relief requested; 2. The Defendant should file an answer to the Petition within twenty (20) days of service of this Rule upon Defendant; 3. The Petition shall be decided under Pa.R.C.P. No. 206.7; 4. _ The parties shall: - appear 1999, at in Courtroom of the Cumberland County Courthouse, to determine appropriate procedure for determining disputed facts; - consult with the Court within ten (10) days after an answer is filed to determine appropriate procedure for determining disputed facts; _ An evidentiary hearing on disputed facts shall be held 1999, at , in Courtroom IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-CUSTODY Q^'?Q ?°^^ NO. 99- G o1 92- Cumberland County Courthouse; _ Depositions shall be completed within days of this date; _ Argument shall be held on 1999, at in Courtroom , of the Cumberland County Courthouse; 5. No tice of the entry of this order shall be provided to all parties by the petitioner. BY THE COURT, a= x7 ;n :V?Fr ?. ? yy f? M ? 1J4 1 e`? !R 2 b ksa <<- +;es' KENNETH ALLEN SHEETS, Jr., Plaintiff/Petitioner V. NANCY MARIE SHIPE, Defendant/Respondent AND NOW, comes the Petitioner, Kenneth Allen Sheets, Jr., by and through his attorneys, Wolfe & Rice, and files this Petition for DNA/Blood Tests to Determine Paternity, and avers in support the following: 1. Petitioner is the Plaintiff in a custody action that has been filed in conjunction with this Petition. 2. Plaintiff/Petitioner is Kenneth Allen Sheets, Jr., residing at 61 Rake Factory Road, Biglerville, Adams County, Pennsylvania 17307 and is the putative father of the child. 3. The Defendant/Respondent is Nancy Marie Shipe, residing at 251 East Crestwood Drive, Apt. B-2., Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff/Petitioner is the putative father of the IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-CUSTODY NO. 99- (OA9.2 t wx 74,L -... following child: NAME PRESENT RESIDENCE AGE Tyler Mark Shipe 251 East Crestwood Drive, Apt B-2 2 weeks DOB: 8/26/99 Camp Hill, Pennsylvania 4. The child was born out of wedlock. 5. The child is presently in the physical custody of Defendant/Respondent, who resides as set forth above. 6. Defendant/Respondent has stated on several occasions during the pregnancy and after birth that Plaintiff/Petitioner is the natural father of the child. , Plaintiff/Petitioner is requesting that the Court issue a rule upon Defendant/Respondent to show cause why a DNA/Blood Test should not be performed on the child and Plaintiff/Petitioner to establish whether Plaintiff/Petitioner is the natural father of the child. WOLFE & RICE By: "2" W ,H ??. Patrick V,./Quinn, Esq. Attorney for Plaintiff 47 West High Street Gettysburg, PA 17325 717/337-3754 Sup. Ct. ID No. 77412 2 KENNETH ALLEN SHEETS, Jr., Plaintiff/Petitioner V. NANCY MARIE SHIPE, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-CUSTODY NO. 99- I verity that the statements made in this Petitioner are true and correct. I understand that false statements herein are made sub3ect to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: 9 - /?- 9 9 ?dL 29kt enneth Allen Sheets, Jr , Plaintitt/Petitioner ? 4 ? '- a _ ra ?? ?. ? ? ? w ? 'i0 m T 5 , 1.- '4' ? ?`£' ? • v ? ?p 1 ? n. 1 .. J . x.(11 ?iT FA?IRi , ? ? v? , ? } ? ?tV$ ? • ? ? ? KENNETH ALLEN SHEETS, Jr., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA CIVIL ACTION-CUSTODY V. NANCY MARIE SHIPE, NO. 99- 1r,293v Defendant RETURN OF SERVICE (United States Mail) The undersigned makes the following return of service: The Custody Complaint with Order of Court dated October 22, 1999, was mailed to Defendant, Nancy Marie Ships, on October 29, 1999, at 4:00 p.m., at 529 St. Mary's Drive, Steelton, PA 17113: X The receipt is attached. The mail, refused and returned, is attached. A copy mailed to Defendant at the same address by ordinary mail with the return address of the sender appearing thereon has not been returned within fifteen days after mailing. Signature and Affidavit I, Stacie Sease, certify that I am a competent adult not a party to the action. I verify that the statements made in this affidavit and return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 5 4904, relating to unsworn falsi ication to =thti Date: 141AII?g Stacie ease ¦ Complete hvina-i n 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 mallpiece, or on the front if space permits. 1. Article Addressed to: Nancy Marie Shipe 529 St. Mary's Drive Steelton, PA 17113 i A. Received by (P(ease Pant CA,") B. Date of Del" r . Slgruture 10 0 Agent `?? Addressee 0. Is dew" merest from darn 17 O Yee If YES, enter delve ry address below. 0 No 3. §erwe Type died Mail 0 Express Mail t 0 Registered 0 Return Receipt for Merchandise i 13 IInsufod Mail 0 coo. Restricted Defiverp (Fibs Feel Ye ( 1 PS Form 3811, July 1999. Domestic Return Receipt gzsss.aa.u.vae i i 12. kfe N ber (Copy from service tab*Q T-1 ' ^f fL'C ? ? s j ? j rrLLL ( CA Y?A - ' a) y t ? 3 t KENNETH ALLEN SHEETS, JR., Plaintiff Vs. NANCY MARIE SHIPS, Defendant : IN THE COURT OF COMM PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6292 CIVIL TERM CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this day of ?a , . , 2000, upon consideration of the attached Custody Conc 1 at on R? eport, it is ordered and directed as follows: 1. The Father, Kenneth Allen Sheets, Jr., and the Mother, Nancy Marie Shipe, shall have shared legal custody of Tyler Mark Shipe, born August 26, 1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. The Mother shall notify the Father of any medical emergencies which arise while the Child is in her custody. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have periods of visitation with the Child every Sunday from 2:00 p.m. until 6:00 p.m. at the mother's residence or in another supervised visitation setting agreed upon by the parties. The person to provide the supervision shall be selected by agreement of the parties. 4. After following the custody schedule set forth in this order for a period of at least 90 days, counsel for either party may contact the Conciliator to schedule an additional Custody Conciliation Conference if necessary to review the custody arrangements. 5. 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 COURT, cc: Patrick W. Quinn, Esquire - Counsel fo Father Paula Burkett and Jan Terpening - fo Mother ` ptl J?L 27-00 RKg J.. ?, + L??1 try :C1T" r,Y oo.?r=?; z7 f?? s: ns CU;"ar;: CUUfJY PENNSYLV,INUti , KENNETH ALLEN SHEETS, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-6292 CIVIL TERM NANCY MARIE SHIPE, CIVIL ACTION - LAW Defendant 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 Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Tyler Mark Ships August 26, 1999 Mother 2. A Conciliation Conference was held on January 191 2000, with the following individuals in attendance: The Father, Kenneth Allen Sheets, Jr., with his counsel, Patrick W. Quinn, Esquire, and the Mother, Nancy Marie Ships, with her counsel, Paula Burkett and Jan Terpening. 3. The parties agreed to entry of an order in the form as attached. 1 n /9 --t- Dawn S. Sunday, Esqu to Date 21 Custody Conciliator O -W 44 L pi 44 ?g ?R to ???3 53 JAN 2 1 2pOq?i r' KENNETH ALLEN SHEETS, JR. IN TI IE COURT Oi; COMMON PLEAS OF PLAINTIFF : Cl1MBIiIlI.AND COUNTY, I'IiNNSYI.VANIA V. NANCY MARIE SHIPE DEFENDANT 99-6292 CIVIL ACTION LAW IN CUSTODY AND NOW, Tuesday, April 17, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday. May 10, 2001 at 9:00 a.m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to he 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: lsl Dawn S. Strtl?cJy, Eiq, Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilitcs 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 A'I-I'ORNEY AT ONCE- IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR '1'Ii1.liP110NE'I'I1li OI:hICii Sl r FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Ear Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 4110101 vww KENNETH ALLEN SHEETS, Jr., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA V. CIVIL ACTION-CUSTODY NANCY MARIE SHIPE, NO. 99-6292 Defendant ORDER OF COURT AND NOW, , upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the ay o , 19 at m., for a Pre-Heang Custody Conference. At suc conTe-rence 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: Custody Conciliator The Court of Common Pleas of Cumberland County is required oy 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 KENNETH ALLEN SHEETS, Jr., Plaintiff V. NANCY MARIE SHIPE, Defendant . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-CUSTODY NO. 99-6292 PETITION FOR MODIFICATION OF VISITATION ORDER 1. The petition of Kenneth Allen Sheets, Jr. respectfully represents that on February 26, 2000 an Order of Court was entered for visitation, a true and correct copy of which is attached. 2. This Order should be modified because: A. Plaintiff was subjected to verbal abuse by members of Defendant's household during his periods of visitation with the child. B. Defendant refused to cooperate in arranging another setting for supervised visitation with the child. C. Supervised visitation with the child is unnecessary. WHEREFORE, Petitioner requests that the Court modify the existing Order for visitation because it will be in the best interest of the child. WOLFE 6 RICE, LLC By: fit, 1c( w1u, 1A 'Patric`- Quinn, Esq. Attorneys for Plaintiff 47 West High Street Gettysburg, PA 17325 717/337-3754 Sup. Ct. ID No. 77412 f Y KENNETH ALLEN SHEETS, JR., Plaintiff VS. NANCY MARIE SNIPE, Defendant 0" : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6292 CIVIL TERM CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this ) day of , 2000, upon consideration of the attached Custody onci at Report, it is ordered and directed as follows: 1. The Father, Kenneth Allen Sheets, Jr., and the Mother, Nancy Marie Shipe, shall have shared legal custody of Tyler Mark Shipe, born August 26, 1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. The Mother shall notify the Father of any medical emergencies which arise while the Child is in her custody. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have periods of visitation with the Child every Sunday from 2:00 p.m. until 6:00 p.m. at the Mother's residence or in another supervised visitation setting agreed upon by the parties. The person to provide the supervision shall be selected by agreement of the parties. 4. After following the custody schedule set forth in this order for a period of at least 90 days, counsel for either party may contact the Conciliator to schedule an additional Custody Conciliation Conference if necessary to review the custody arrangements. S. 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. ,.,, ..., •TRUE CO!'*- T' In Tw im-uy •. t,.r:., , ,. i rcni BY THE COURT, and fl ;c Th' :,cal .,o.. f s i•J ..... h1C da 01 a 15y -jd,. M. cc: Patrick W. Quiv6;h M?Ibl counsel for Father Paula Burkett and Jan Terpening - for Mother pft? Id4? KENNETH ALLEN SHEETS, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 99-6292 CIVIL TERM NANCY MARIE SHIPS, CIVIL ACTION - LAW Defendant CUSTODY CUSTODY CONCILIATION SUNYmW REPORT IN ACCORDANCE WITH CL)MBERLAND COUNTY ROLE OF CONIC PROcw= 1915.3-8, the undersigned Custody Conciliator submits the fcllowing report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: DATE OF BIRTH Tyler Mark Shipe Augpst 26, 1999 CURRENTLY IN CUSTODY OF Mother 2. A Conciliation Conference was held on January 19, 2000, with the following individuals in attendance: The Father, Kenneth Allen Sheets, Jr., with his counsel, Patrick W. Quinn, Esquire, and the Mother, Nancy Marie Shipe, with her counsel, Paula Burkett and Jan Terpening. 3. The parties agreed to entry of an Order in the form as attached. 1 ? a-rn? o Date Dawn S. Sunday, Esqui e Custody Conciliator KENNETH ALLEN SHEETS, Jr., Plaintiff V. NANCY MARIE SHIPS, Defendant . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY. V6NNb1LV8N18 CIVIL ACTION-CUSTODY NO. 99-6292 VERIFICATION I verify that the statements made in this Petition are true and correct. i understand that false statements herein are made subject to the penalties, of 16 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: 3'Zp t. ennet Al en Sheets, if/, P a ntit ,., ? : . ,.. t ?, ; ?,? .A. 7..1 .?? V ?F1 . I i C?i fi j} _ ;:L .: V n ?!YYMT..n?.Y'M a ' ...... ........ .... .. ..., ... I 1 1 1 KENNETH ALLEN SHEETS, Jr., Plaintiff v. NANCY MARIE SHIPE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-CUSTODY NO. 99-6292 CERTIFICATE OF SERVICE The undersigned, Jamie Gebhart, hereby certifies that a true and attested copy of the Petition for Modification of Visitation Order with Order of Court dated April 17, 2001, was served upon Defendant, through her counsel, Paula Burkett, by depositing same in the United States mail, first class postage prepaid, at Gettysburg, Pennsylvania, on the 25`h day of April, 2001, and addressed to Paula Burkett, Legal Services, 8 Irvine Row, Carlisle, PA 17013. Date: 5aol Jam a hart C-j f : ,L at r r 7i ' , 1 N. ti r , KENNETH ALLEN SHEETS, Jr., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA CIVIL ACTION-CUSTODY V. NANCY MARIE SHIPE, NO. 99-6292 Defendant CERTIFICATE OF SERVICE The undersigned, Jamie Gebhart, hereby certifies that a true and attested copy of the Petition for Modification of Visitation order with Order of Court dated April 17, 2001, was served upon Defendant, Nancy Marie Shipe, by certified mail, restricted delivery, return receipt requested, a copy of which is attached hereto as Exhibit "A". Date: VA AAl Jamie Gebhart ¦ Complete Items 1, 2, and 3. AM complete Rem 4 If Restricted Delivery Is deemed. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the beck of the mallpiece, or on the front If space permits. 1. Ankle AddmeaedMMla MCA( S ?Ca- isr, t P l ?u3 ?. AmkN Wwnbw PCopy from service MW r? Ps Form 3811, duty 1999 A. Received by (Please Prim Cbery) B. Data of oetNary. i'yY-(f I C. Signature t O Apmtt ^\ \ _ O Masasee 0. Is deMery address Brent from em 17 O Yes ; R YES, enter dew address below: I] r4o 3. Service type `$&MAIW Mall M Express M&W U Repbterad O inwred Mau 4. Restricted DeMeM ) Domestic Return Receipt ` ., Ia75eS-0aY-0eSt cl. il13 n c.. .? j U i'? f_'> KENNETH ALLEN SHEETS, JR., Plaintiff vs. NANCY MARIE SNIPE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6292 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this -` day of 2001, upon consideration of the attached Custody Conciliation Report, t is ordered and directed as follows: 1. The prior order of this Court dated January 26, 2000 is vacated and replaced with this order. 2. The Mother shall have primary physical and sole legal custody of Tyler Mark ships, born August 26, 1999. 3. The Mother shall notify the Father of any major decisions she has made affecting the Child's general well-being and welfare. 4. The Father may have periods of supervised visitation with the Child as arranged by agreement of the parties. BY THE COURT, .4, cc: Patrick W. Quinn, Esquire - Counsel for Father Debra D. Cantor, Esquire - Counsel for Mother 119.4 b? ?TAny U! JU,11-a AHII: 18 CVtA? tju •V PENNSMw? ??1JY KENNETH ALLEN SHEETS, JR., Plaintiff Va. NANCY MARIE SHIPE, Defendant PRIOR JUDGE: Kevin A. Hera IN THE COURT OF WMMON PLEAS OF CUMBERLAND CWNTY, PENNSYLVANIA NO. 99-6292 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMMERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-81 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: DATE OF BIRTH CURRENTLY IN CUSTODY OF Tyler Mark Ships August 26, 1999 Mother 2. A Custody Conciliation Conference was held on May 29, 2001, with the following individuals in attendance: The Father, Kenneth Allen Sheeta, Jr., with his counsel, Patrick W. Quinn, Esquire, and the Mother, Nancy Marie Shipe, with her counsel, Debra D. Cantor, Esquire. 3. This Court previously entered an order in this matter on January 26, 2000 under which the Mother was to have primary physical custody of the child and the Father was to have weekly periods of supervised visitation at the mother's residence, with a provision for an additional Custody Conciliation Conference. The Father subsequently filed a Petition for Modification and the present Conciliation Conference was scheduled. However, at the Conference, the Father stated that he was not seeking physical custody of the child, but simply wanted the income tax exemption. After consulting with counsel, the Father withdrew his Petition for modification and physical custody. 4. The parties agreed to entry of an order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator JUN0a ¦ ' a ' ? i1 w7 4] 6ti' ? ? ? a + W Q ?