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Home My WebLink About99-07265 i ?w ROY A. KERN vs : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA SONDRA 1). (KERN) SHEARER Defendant : CIVIL DIVISION - LAW NO. 99 : 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. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 717 - 240-6200 ROY A. KERN vs : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA SONDRA D. (KERN) SHEARER Defendant CIVIL DIVISION - LAW NO. 99 72GS IN CUSTODY ORDER OF COURT AND NOW, this p day of?)CC_ , 1999, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Conciliator, at 39 W. Main Street. Mechanicsburg, PA 17055, on the .D day of1999, at l.Q(Z -P.m., for a Prehearing 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. Either party may bring the child who is the subject of this custody action to the conference, but the child's attendence is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: BY: _AN-vSg?\ C\ 19f/?4VC0 I Custody Conciliator c I?l 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, PENNSYLVANIA 17013 (717) 249-3166 r? id/?/• 9n ? ?ta?? Flo ?l' %a./4. 99 ROY A.. KERN : IN THE. COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA vs : CIVIL DIVISION - LAW SONDRA D. (KERN) SHEARER NO. 99 • %26 S T-- DEFENDANT. CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, by and through his attorneys, Broujos & Gilroy, P.C., and avers as follows: I. Plaintiff is Roy A. Kern an adult individual residing at R.D. #1, Box 1065, Elliottsburg, Perry County, Pennsylvania, 17024. 2. Defendant is Sondra D. (Kern) Shearer an adult individual residing at 894 Torway Road, Gardners, Cumberland County, Pennsylvania 17324. 3. Plaintiff seeks custody of the child Matthew A. Kern residing at R. D. #1, Box 1065, Elliottsburg,Per y County. Pennsylvania 17024. • Matthew A. Kern was born January 2, 1985. • The child was born in wedlock. • The child is presently in the custody of Plaintiff. Plaintiff resides at R. D. #1, Box 1065, Elliottsburg, Perry County. Pennsylvania 17024. During the past five years, the child has resided with the following persons and at the following addresses: Person Address Dates Roy A. Kern R. D. #l, Box 1065, Blliottsburg, PA 17024 September 19, 1999 to present Sondra D. (Kern) Shearer 894 Torway Road, Gardners. PA 17324 January 2. 1985 to September 18, 1999 • The mother of the child is Sondra D. (Kern) Shearer currently residing at 894 Torway Road, Gardners, Cumberland County, Pennsylvania 17324. • She is not married to Plaintiff. • The father of the child is Roy A. Kern, currently residing at R. D. #L Box 1065, Elliottsburg, Perry County, Pennsylvania 17024. • He is not married to Defendant. 4. The relationship of Plaintiff to the children is that of father. • The Plaintiff currently resides with the following persons: Name Relationship Karen A. Kern stepmother Matthew A. Kern son 5. The relationship of Defendant to the children is that of the mother. • The Defendant currently resides with the following persons: Name Relationshin Sondra D. (Kern) Shearer mother Douglas Shearer stepfather Renee A. Kern sister 6. The Plaintiff 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. 7. Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth. 8. Plaintiff does not know ofa person not a party to the proceedings who has physical custody of the children or claims to have custody of visitation rights with respect to the children. 9. The best interest and permanent well'are of the child will be served by granting the relief requested because the child has been in the custody of the Plaintiff since September 19, 1999, and because the Plaintiff is capable of providing for this child. 10. Each parent who has parental rights to the child which have not been terminated and the person who has physical custody of the child are parties to the action. WHEREFORE, Plaintiff requests this Court to grant custody of the child to Plaintiff. John A1!9 icy for Plaintiff BROUJOS & GILROY, P.C. 4 North Hanover Street Carlisle, Pennsylvania 17013 717/243-4574 717/766-1690 FAX# 717/243-8227 ,1 I verity that the statements in the foregoing pleading are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. Roy A. K n, Plaintiff Te+ A I I n C.1 - r p G c ZU , (C ) `? NO ROY A. KERN PLAINTIFF vs SONDRA D. (KERN) SHEARER DEFENDANT. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW NO. 99-7265 Civil CUSTODY ORDER AND NOW, this 13* day of January, 2000, upon stipulation by the parties, it is ordered and directed that the custody of the child and visitation rights are set forth in the Stipulation and Order of Court. By the Court: 1-13-00 RX3 71 Q.?FIGa FILc _D- r pF T!: 00 g d 13 513 t r,Utij;_I-,%U :D cOUNT r PE l-,\laYWAN'A ROY A.. KERN PLAINTIFF vs SONDRA D. (KERN) SHEARER DEFENDANT. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW NO. 99-7265 CUSTODY STIPULATION The parties hereto stipulate as follows, requesting the Court to enter an order in accordance herewith: 1. The parties shall have shared legal custody. 2. Primary physical custody of the child shall be in Father Roy A. Kern. 3. Mother shall have visitation rights in accordance with the following schedule: A. Every other weekend commencing January 7, 2000 at 5:00 p.m. to Sunday, January 9 at 6:30 p.m. B. On alternating holidays each year of Thanksgiving, Christmas, New Year's, Easter, Memorial Day, July 4, Labor Day, and birthday, alternating every other year, in accordance with and to accommodate the work schedules of both parties. C. Summer vacation of one week during the months of June, July, or August, or as the parties shall otherwise agree. 4. Transportation by each parent for delivery and pick-up of the child shall be at a mutually agreeable location. 5. Mother and Father shall have liberal telephone contact with the child at reasonable times. ?ianwwh vnt ..r.?p1 tltC. F F S 6. Father is represented by John H. Broujos and Mother has waived her right to counsel. IN WITNESS WHEREOF, the parties set their hands and seals. Roy Al Kern -'gondra D. Shearer 4s s? l?-.P y < ' ? S? ? ? ? J(? ll ?.a L1Jl'.' ? ?? - \ 4l (t? ? ? r y-? !:'- ? ? J o• o ?$Q? cv ROY A. KERN, . IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW : NO. 99-7265 SONDRA D. (KERN) SHEARER, Defendant, IN CUSTODY ORDER OF COURT ..4? JAN 10 2000 AND NOW, this 4th day of January, 2000, the Conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved between the parties by a written and signed Stipulation, hereby relinquishes jurisdiction in this case. The Custody Conciliation Conference scheduled for January 20, 2000, is canceled. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator 4: 03 i_ { 'r?N(dSYL?r??`d!A PROTHONOTARY FOR THE COUNTY OF CUMBERLAND IN THE COMMONWEALTH OF PENNSYLVANIA,. IN RE KERN V. SHEARER IN CUSTODY 1999-7265 17- PRAECIPE TO WITHDRAW AS COUNSEL TO THE PROTHONOTARY PLEASE WITHDRAW MY APPEARANCE AS COUNSEL IN THE ABOVE-REFERENCED MATTER SINCE I HAVE RETIRED FROM PRACTICE AND HAVE NOT BEEN INVOLVED FOR SOME TIME. DATE: 10-24-2011 Jo H. BROUJOS ATTORNEY ID #6268 4 NORTH HANOVER ST. CARLISLE, PA. 17013 PHONE: 717-243-4574