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HomeMy WebLinkAbout03-4198JASON L. SLOOP, Plaintiff VS. KIMBERLY L. SLOOP, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 03-/'/?)2 CIVIL TERM : IN DIVORCE NOTICE 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 Jose 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 the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff I;~93 say, Esquire 26 West High Street Carlisle, PA 17013 (717) 243-6222 JASON L. SLOOP, Plaintiff VS. KIMBERLY L. SLOOP, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 03- q/~f~ : IN DIVORCE CIVIL TERM COMPLAINT SAIDIS SI-lUff, FLOWER & LINDSAY 26 W. High Street Carlisle, PA JASON L. SLOOP, Plaintiff, by his attorneys, SAIDIS, SHUFF, FLOWER & LINDSAY, respectfully represents: 1. The Plaintiff is JASON L. SLOOP, who currently resides at 928 Factory Street, Carlisle, Cumberland County, Pennsylvania, where he has resided since 1995. 2. The Defendant is KIMBERLY L. SLOOP, who currently resides at 425 Kerrsville Road, Carlisle, Cumberland County, Pennsylvania, where she has resided since May 1, 2003. 3. The Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 12, 1995 in Plainfield, Cumberland County, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff avers that he is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. Date: SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff Carol J. ,LindsC~y, Esquire-( ID # 44~3~/ \ 26 West'Fl'~gh Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA VERIFICATION I, the undersigned, hereby 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. § 4904, relating to unsworn falsification to authorities. Jason L. Sloop " Date: SAIDIS SHUFF, FLOWER LINDSAY W. High Street Carlisle, PA SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High $~reet Carlisle, PA JASON L. SLOOP, Plaintiff VS. KIMBERLY L. SLOOP, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 0:3- 4198 CIVIL TERM : IN DIVORCE PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Please reinstate the Complaint filed in the captioned case. SAIDIS, SH~'FTFI_'Q~NDSAY, P.C. Attorne,~ys forX ~ / ;R[ainti¢ / f' Carol ~- Lind-s~yTE sq[~i~ - / ID#44693 / .) 26 West High~ ! Carlisle PA 17013 Phone: (717) 243.6222 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA JASON L. SLOOP, Plaintiff VS. KIMBERLY L. SLOOP, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 03 - 4198 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVlCF AND now, this 20th day of September, 2003, I, Carol J. Lindsay, Esquire, of the law firm of SAIDIS, SHUFF, FLOWER & LINDSAY, Attorneys, hereby certify that I served on the Defendant a Praecipe to Reinstate and Divorce Complaint by certified United States Mail, First Class, as attested by the attached signed return receipt card. SAIDIS, SHUFF, FLOWER & LI Attorneys for Pla~r ~---- Carol. ID# .4fi~. ~ 13 26 Wc=~ ~AY, P.C. h Street Carlisle, PA 17013 (717) 243-6222 MARITAL SETTLEMENT AGREEMEN¥ THIS Agreement made this ~ day of ~_~/~¢~'~ , 2000, by and between KIMBERLY SLOOP, of 266 South Hanover Street, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as WIFE, and JASON L. SLOOP, of 928 Factory Street Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as HUSBAND, WITNESSETH: WHEREAS, the parties hereto are husband and wife, having been joined in marriage on August 12, 1995, in Plainfield, Pennsylvania; and WHEREAS, the parties hereto are desirous of settling fully and finally their respective financial and Property dghts and obligations as between each other, incJuding, without limitation, the settling of all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente//te, counsel fees and costs, and in general, the settling of any and all claims and possible claims against the other or against their respective estates. NOW, THEREFORE, in consideration of these considerations, and the mutual promises and undertakings hereinafter set forth, and for other good and valuable consideration, receipt and sufficiency of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each intending to be legally bound, hereby covenant and agree as follows: sloop ... rosa ... tjb March ~4, 2000 1. Advice of Counsel: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this agreement with which to consult with counsel. HUSBAND is represented by Carol J. Lindsay, Esquire, and WIFE has been advised that she may be represented by counsel of her choice. Each party acknowledges and accepts that this agreement is, in the circumstances, fair and equitable, and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge as each has sought from counsel, and that execution of this agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. 2. Divorce: In the event that one of the parties hereto files a Complaint in Divorce, the ~arties agree that within 90 days of the service of the Complaint in Divorce, they will sign Affidavits of Consent and Waivers of Notice under Section 3301(c) of the Divorce Code, consenting to the entry of a Decree in Divorce. 3. Personal Property: The parties hereto have satisfactorily divided their household goods and personal items. Attached hereto as Exhibit "A" are those items of personalty which HUSBAND will transfer to WIFE at her request. Within ten (10) days of the date of this Agreement, HUSBAND will cause to be transferred to WIFE the 1992 Toyota Camry which is presently titled to HUSBAND's business. HUSBAND will retain the Chevrolet S-10 pickup which is also titled to his business. The parties warrant that there are no liens or encumbrances on either of the vehicles and shall, from the date of sloop ,.. msa ... tjb March 14, 2000 transfer of the vehicles, be solely and exclusively responsible for any obligation on account of the vehicles. 4. Real Property: The parties are owners of a home at 928 Factory Street, Carlisle, Cumberland County, Pennsylvania. On the same day as the date of this Agreement, WIFE will execute a Special Warranty Deed transferring to HUSBAND all her right, title and interest in the marital home. HUSBAND shall be solely and exclusively responsible for paying the mortgage on the marital home and the taxes and insurance thereon, and he shall indemnify and hold WIFE harmless on account of any loss from any failure of his to do so. 5. Alimony: The parties waive any claim that they may have one against the other for alimony, alimony pendente lite or spousal support or separate maintenance. The parties acknowledge that each has sufficient assets and income with which to maintain themselves after divorce. 6. Marital Debt: The parties have incurred certain marital debt in the course of their marriage. HUSBAND will be solely responsible for paying the following debt: A) Mortgage on the marital home; B) Cornerstone Federal Credit Union loan; C) Cornerstone Federal Credit Union credit card. WIFE will be solely responsible for paying the following credit card debt: A) Discover Card, No. 6011-0027-0026.0656; B) Bank of America, No. 4356-2390-0190_2184; C) Sears, No. 05- 54668-22904-6 and her Talbot's, Hecht's and Bon Ton charges. For the two months commencing March 1, 2000 and Apdl 1, 2000, HUSBAND will make the minimum payment due on those credit cards for which WIFE has accepted liability above. 3 sloop ... rosa ... tjb March 14, 2000 Commencing May 1, 2000, WIFE will be solely and exclusively responsible for payment of the which she is assuming. The parties will make their payments on the debt assumed in a timely manner so that neither party has an adverse credit report and shall indemnify and hold the other harmless against any claim by a creditor he or she has agreed to pay on account of his or failure to do so. 7. Exchange of Information: The parties have ~"equested from each other and received any information regarding their assets, liabilities, income and expenses which the party requires )rior to entering into the terms of this Agreement. The parties acknowledge that the terms of this Agreement are fair and equitable and constitute an equitable distribution of marital property and debt, taking into account all of the relevant factors set out in Section 3502 of the Divome Code, 23 Pa. C.S.§3502 including the length of the marriage; any prior marriage of the parties; the age, health, station, amounts and soumes of income, vocational skills, employability, estate, liabilities and needs of each of the parties; the contribution by each party to the education, training or increased earning power of the other; the opportunity of each party for future acquisitions of capital assets and income; the sources of income of both parties, including but not limited to, medical, retirement, insurance or other benefits; the contribution or dissipation of each party in the acquisition, 3reservation, depreciation, or appreciate of the marital property, including the contribution of a party as homemaker; the value of the property set apart to each party; the standard of living of the parties during the marriage; the economic cimumstances of each party, including federal, state and local tax ramifications at the time of the division of the property, and whether the party will be serving as custodian of any dependent minor children. 4 sloop ... msa ... tjb March 14, 2000 8. Modification: No modification, rescission, o.r amendment of this agreement shall be effective unless in writing signed by each of the parties hereto. 9. Applicable Law: All acts contemplated by this agreement shall be construed and enfomed under the laws of the Commonwealth of Pennsylvania. 10. Agreement Binding on Parties and Heirs: This agreement, except as otherwise expressly provided herein, shall bind the parties hereto, and their respective heirs, executors, administrators, legal rePresentatives, assigns and successors in any interest of the parties. 11. Agreement Not to be Merged: This agreement shall be incorporated into the final decree of divorce of the parties hereto for purposes of enforcement only, but otherwise shall not be merged into said decree. The parties shall have the right to enforce this agreement under the Divorce Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity under this agreement as an independent contract. Such remedies in law or equity are specifically not waived or released. 12. Documents: The parties hereto agree that they will execute and deliver one to the other any documents necessary to give effect to the terms of this Agreement. 13. Full and Final Settlement: WIFE and HUSBAND each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, titles, interests or claims in or against the property (including income and gain from property hereafter accruing, of the other) or against the estate of such other, of whatever nature and wheresoever situate, which she or he now has or at any time hereafter may have against such other, the estate of such other or any part sloop ... rosa ... tjb March 14, 2000 thereof, whether adsing out of any former acts, contracts, engagements or liabilities of such other, or by way of dower or courtesy, or claims in the nature of dower or curtsey, or widows' or widowers' rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any other State, or any other Country,. or any rights which either spouse may have, or at any time hereafter have, for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except and only except, all dghts and agreements and obligations of whatsoever nature arising or which may adse under this Agreement or for the breach of any term thereof. It is the intention of HUSBAND and WIFE to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except, all rights and agreements and obligations of whatsoever nature adsing or which may arise under this Agreement, or for the breach of any term thereof, subject, however, to the implementation and satisfaction of the Condition precedent as s;et forth herein above. 14. BREACH: In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court costs and counsel fees of the other party. In the event of breach, the other party 6 sloop ... msa ... tjb March 14, 2000 shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. WITNESS: Ja~f'~ L. Sloop ' I~irn/eerly SloOp (SEAL) (SEAL) SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Sffeet Carlisle, PA JASON L. SLOOP, Plaintiff VS. KIMBERLY L. SLOOP, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION. LAW : NO. 03 -4198 CIVIL TERM : : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODF AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 26, 2003 and reinstated on September 18, 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. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. 4. I verify that the statements made in this Affidavit 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. Date: /~,~- ,-~, - c~..~~ PLAINITFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER Section 3301(c) OF THE DIVORCE CODF 1. 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 tees or expenses if I oo not ciaim 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. 4. I verify that the statements made in this Affidavit 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. ~ff SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA JASON L. SLOOP, Plaintiff VS. KIMBERLY L. SLOOP, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 03 -4198 CIVIL TERM : : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODF AND WAIVER OF COUNSELIN~ 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 26, 2003 and reinstated on September 18, 2003. 2. The marriage of plain[i[[ and defendant is irre[rievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. 4. I verify that the statements made in this Affidavit 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. Kimbedy'L. Sl~o~), De~end/nt DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER Section 3301(c) OF THE DIVORCE CODF 1. 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. 4. I verify that the statements made in this Affidavit 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 unswom falsification to authorities. Date: Kimbe~'ly L~ Sl~p, Defe~ant JASON L. SLOOP, KIMBERLY L. SLOOP, Plaintiff VS. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. Il3- 4198 CIVIL TERM Defendant : IN DIVORCE SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA PRAEC~IPE TO TRAN~qMIT RF,,CORI~ To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) 3351(d)(i) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Defendant was served via certified United States Mail, First Class September 20, 2003 with Praecipe to Reinstate and Divorce Complaint, Certificate of Service and Proof of Service tiled October 2, 2003 (copy of which is enclosed) (Complete either paragraph (a) or po)). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) &the Divorce Code: by the Plaintiff December 26, 2003; by the Defendant December 27, 2003. Date of tiling of Plaintiff's and the Defendant's Affidavits of Consent: ~ . 4. Related claims pending: Nnne: Re~olved hy Mn~tnl Property. Rettlement nnd Re.naratinn Agreement dnted Mnreh 15:2000 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached: (b) Date Plaintiffs Waiver of Notice in 3301(c) Divorce was executed: December 26, 2003; Date Plaintiff's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: ~)~c Date Defendant's Waiver &Notice in 3301(c) Divorce was executed: December 27, 2003. Date Defendant's Waiver of Notice in 330l(c) Divorce was filed with the Prothonotary: sCa~r;Is f ~ ~ :f~f~r ~iidd s ay 26 West High Street Carlisle PA 17013 Phone: '717.243.6222 Atiorne) for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ,~~¢. PENNA. JASON L. SLOOP Plaintiff VERSUS KIMBERLY L. SLOOP Defendant NO. 03-4198 AND NOW, DECREED THAT DECREE IN DIVORCE , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, Jason L. Sloop AND Kimberly L. Sloop ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; None: The terms of the marital settlement agreement of March 15, 2000 are incorporated but not merged into the Decree in Divorce. BY THE COURT: //7 .+++~ ++ ++ +++++++++++++++ +++++7+ + +++++++ + ++ ++++ SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA JASON L. SLOOP, Plaintiff VS. KIMBERLY L. SLOOP, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 03 -'H98 CIVIL TERM . : IN DIVORCE COMPLAINT FOR CH~TOI3Y The Plaintiff is Jason L. Sloop, residing at 928 Factory Street, Carlisle, Pennsylvania 17013. The Defendant is Kimberly L. Lynch, residing at 17 Fairfield Street, Newville, Pennsylvania. The Plaintiff seeks custody of the following children, Jordan W. Sloop, born June 2, 1995 and Jacob T. Sloop, born June 19, 1997. The children were not born out of wedlock. The children are presently in the custody of their Father who resides at 928 Factory Street, Carlisle, Pennsylvania and their Mother, who resides at 17 Fairfield Street, Newville, Pennsylvania. During the past five years, the children has resided with the following persons and at the following addresses: Name Jason L. Sloop and _Kimberly L. Sloop Jason L. Sloop Kimberly L. Sloop Kimberly L. Lynch & Clayton Lynch _{fka Kimberl¥ L. Sloop) Jason L. Sloop [~imberly L. Lynch & Clayton Lynch Jason L. Sloop Address From/To Birth to May 2003 928 Factory Street Cadisle, PA 928 Factory Street Carlisle, PA Home of her parents Vicky & Roger Baker Horseshoe Rd. Carlisle, PA 928 Factory Street Carlisle, PA 17 Fairfield SI:. Newville, PA 928 Factory Street Carlisle, PA May 2003 - June 2003 3 niclhts per week May 2003-June 2003 4 nights per week July 2003-July 2004 4 nights per week July 2003-July 2004 3 niqhts per week July 2004 - present 4 nights per week July 2004 - present 3 n qhts per week SAIDIS SHUFF, FLOWER & LINDSAY 26W. High Street Carlisle, PA ,, 10. The mother of the children is Kimberly L. Lynch, currently residing at 17 Fairfield Street, Newville, Pennsylvania. She is married. The father of the children is Jason L. Sloop, currently residing at 928 Factory Street, Carlisle, Pennsylvania. He is single. The relationship of the Plaintiff to the children is that of Father. The Plaintiff currently resides with the following person(s): N~ oth~.r except for the childrP, n. The relationship of the Defendant to the child is that of Mother. The Defendant currently resides with the following person(s): ~ Plaintiff has not participated as a party or witness, or in any other capacity in other litigation concerning the custody of the children in this or another jurisdiction. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of the Commonwealth. The 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 child. The best interest and permanent welfare of the children will be served by granting the relief requested because: a) The Plaintiff can best provide for the educational continuity of the children. SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA 11. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, the Plaintiff requests this Court to grant primary physical custody of the children to the Plaintiff. Respectfully submitted, Saidis, Shuff, Flower & Lindsay By: Carol J. I~ds~y "~ ID ¢fi¢469~ ~,/ 26 West I-Ti~h Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Streel Carlisle, PA I, the undersigned, hereby 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. § 4904, relating to unsworn falsification to authorities. Date: ~.,,~o, ~,,~ ,¢-aS~n L. Sloop, ¢laintiff SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Slreel Carlisle, PA JASON L. SLOOP, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 03 - 4198 CIVIL TERM KIMBERLY L. SLOOP, : Defendant IN DIVORCE AND now, this ~ day of ~~ 2004, I, CAROL J. LINDSAY, Esquire, of the law firm of SAIDIS, SHUFF, FLOWER & LINDSAY, A~orneys, hereby cedify that I se~ed the Defendant, Kimberly L. Lynch, (formerly Kimberly L. Sloop) on September 25, 2004, with the Complaint in Custody by Ce~ified Mail, Return Receipt Requested, addressed to: Kimberly L. Lynch 17 Fairfield Street Newville, PA 17241 and proof thereof, the signed Return Receipt Card, is attached hereto. SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiiff By_ uarol J//!._ir~ay, Esquire ID # 4~..J~g,~ 26 West High Street Carlisle,, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY Carlisle, PA JASON L. SLOOP, Plaintiff VS. KIMBERLY L. SLOOP, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03 - 4198 CIVIL TERM : IN DIVORCE PROOF OF SERICE_ SAIDIS SHUFF, FLOWER & LINDSAY JASON L. SLOOP, Plaintiff VS. KIMBERLY L. SLOOP, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . : CIVIL ACTION - LAW : NO. 03 -4198 CIVIL TERM : : IN DIVORCE .STIPULATION FOR CIJSTODY The parties hereto stipulate as follows: They are the parents of Jordan W. Sloop, born June 2, 1995 and Jacob T. Sloop, born June 19, 1997. The parties separated in May 2003 and have been sharing custody of the children since that time. The parties agree the children shall continue to attend Crestview Elementary School in Carlisle, Pennsylvania. The parties shall share legal custody of the children, each of them having the right to obtain information with regard to their children and the right to participate in makin9 important decisions regarding their children. During the school year, the children will reside at their Father's house Sunday evening through Wednesday morning when Father shall deliver them to school and at their Mother's house from Wednesday morning through Thursday evening. Additionally, the parties will alternate weekends Friday after school or work until Sunday evening. In the summer time, the parties will again share custody with Father having the children on Monday morning until Wednesday morning and Mother having custody of thE; children from Wednesday morning through Fdday morning. Additionally, the parties will altemate the weekends from Friday after work until Monday morning. Neither party will seek child support from the other. The parties intend for this agreernent to be entered as an order of court at least until a new order is entered after a conciliation conference. In the event the parties determine that this schedule set out herein is acceptable, they may, together cancel the conciliation conference and the terms of this agreement shall become the order of court in the case. Witnesses: Kimberly L. f~nc~'Defendant (Formerly Kimberly L. Sloop) SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA JASON L. SLOOP PLAINTIFF KIMBERLy L. SLOOP DEFENDANT IHE r~ OF COMMON PLEAs OF IN ~-.OURT CUMBERLAND COUNTY, PENNSYLVANIA 03-4198 CIVIL ACTION LAW IN CUS FODY ORDER OF COURT AND NOW, ~_____~, October OS, 2004 it is , upon consideration of the attached Complaint, hereby d~rected that part, es and thmr respective Counsel appear betore Jacks .~z~' the conciliator, a~ Courthouse, Carlisle on Thursday, October 28, 2004 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort w/ll 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 are five or older may also be present at the conference. provide grounds for entry ora temporary or permanent order. Failure to a~ear at the conference may The court hereby directs the parties to furnish S · any and all existing Protection from Abuse orders, pec~ai Rellef orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT~ By: ~~rnhc Custody Conciliator American?w~,kC°r,..u~t~ ,o(,.C, om,mon Pleas of Cumberland Count ' '- .... ~,~aomtes Act of 1990. For information ab~Yu;Sa;;qe~;~?~i~;l~ ;~rP~aYs:~tahbI~e 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 betbre the Court. You must attend the scheduled conference or heating. HAVE YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEy AT ONCE. IF YOU DO NOT AN ATTORNEy OR CANNOT AFFORD ONE, GO TO OR TELEPttONE 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 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA OCT 11 2004 JASON L. SLOOP, Plaintiff VS, KIMBERLY L. SLOOP, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 03 -4t98 CIVILTERM : : IN DIVORCE _ORDER OF COURT NOW, this t'~ IJ~ day of ~ ~-'~. , 2004, upon consideration of the within Stipulation of the Parties, the terms of the Stipulation are hereby made an Order of Court. By the Court, JASON L. SLOOP, Plaintiff V. KIMBERLY L. SLOOP, Defendant OCT 21 2004 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2003-4198 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this 20th day of October, 2004, being advised that the parties have reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THECOURT, y, Esquire, Cushy Conciliator