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Home My WebLink About03-4381 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA CHRISTOPHER BARR, Plaintiff V. JULIE BARR, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : : NO. 2003- /7/_~' : : : CIVIL ACTION - IN CUSTODY CCJMPI AINT FOR CIIRT~r~Y 1. The Plaintiff is Christopher Mechanicsburg, Pennsylvania 17055. 2. The Defendant is Julie Mechanicsburg, Pennsylvania 17055. Barr, residing at 4182 Elk Court, Barr residing at 6308 Valleybrook Drive, 3. The Plaintiff seeks custody of the following children, Katelyn Nicole Barr and Kristiana Marie Barr who reside at 6308 Valleybrook Ddve, Mechanicsburg, PA 17055. The children were not born out of wedlock. The children are presently in the custody of Julie Barr, who resides at 6308 Valleybrook Drive, Mechanicsburg, PA 17055. During the past five years, the children have resided with the following persons and at the following addresses: NAME Christopher Barr & Julie Barr Julie Barr ADDRESS FROM/TO 6308 Valleybrook Drive, Mechanicsburg, PA 17055 6308 Valleybrook Drive, Mechanicsburg, PA 17055 until July 1, 2003 July 1,2003 to present SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Slreet Carlisle, PA The mother of the child is Julie Barr, currently residing at 6308 Valleybrook Drive, Mechanicsburg, PA 17055. She is married. The father of the children is Christopher Bart, currently residing at 4182 Elk Court, Mechanicsburg, PA 17055. He is married. 4. The relationship of the Plaintiff to the children is that of father. The Plaintiff currently resides with the following person(s): n/a 5. The relationship of the Defendant to the children is that of mother. The Defendant currently resides with the following person(s): Katelyn Nicole Barr and Kristiana Marie Barr. 6. 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. 7. The Plaintiff has no information of a custody proceeding conceming the children pending in a court of the Commonwealth. 8. 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 children. 9. 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 physical and emotional needs of children. 10. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, the Plaintiff requests this Court to grant shared physical custody of the children to the Plaintiff. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for ~F~ak~'f Carol J. Li .nd's~y,'~squire ID# 4469,~ 26 West ~'¢S"treet Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA VERIFICATInN I, Christopher Barr, 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: C h~r B~'/~r r/~ SAIDIS SHUFF, FLOWER & LINDSAY 26 w. High Streel Carlisle, PA CHRISTOPHER BARR : IN THE COURT O]? COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 03-4381 CIVIL ACTION LAW JULIE BARR : IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, September 11, 2003 , upon co~tsideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, September 30, 2003 at 8:30 AM 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 def'me 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. 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: /s/ Jacqueline M. Verney. Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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 ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 Associat/on 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 CHRISTOPHER BARR, Plaintiff JULIE BARR, Defendant · IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2003-4381 CIVIL TERM : : CIVIL ACTION. LAW : IN CUSTODY ORDER OF COURT AND NOW, this ~& day offs_____, 2003, upon Cfo°l~oSiwdseSation of the attached Custody Conciliation Report, it is ordered and directed as 1. The Father, Christopher Bart and the Mother, Julie Barr, shall have shared legal custody ofKatelyn Nicole Bart, born February 27, 1996 and Kristiana Marie Barr, born September 10, 1994. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to all decisions regarding their health, education and religion. 2. Mother shall have primary physical custody of the Children. 3. Father shall have the following periods of partial physical custody: A. Beginning Wednesday, October I, 2003, every Monday and Wednesday from 5:00 p.m. to 8.'00 p.m. B. Beginning Friday, October 3, 2003 alternating weekends from Friday at 5:00 p.m. to Sunday at 8:00 p.m. C. Such other times as the parties agree. 4. The physical custody set forth in paragraph 3 shall be supervised by Father's Mother or brother or other acceptable adult until Father receives a letter from his treating psychiatrist indicating that he is not a danger to himself or his children. Supervision shall cease once said letter is received by Mother. 5. Transportation shall be shared such that the receiving party shall transport the Children, unless otherwise agreed by the parties. 6. The parties shall submit themselves for and cooperate with a custody evaluation to be performed by Dr. Arnold Shienvold. Payment for the evaluation shall be shared by the parties. 7. Father shall assure that the children receive their while they are in his physical custody, appropriate medication 8. Father shall assure that the children are transported to their religious obligations and extracurricular activities while they are in his physical custody. 9. This · Order ~s entered pursuant to 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:d2~ol Lindsay, Esquire, Counsel for Father Joanne Clo~ugh, Esquire, (Debra Cantor, Esquire) Counsel for Mother CHR/STOPHER BARR, Plaintiff JULIE BARR, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2003-4381 CIVIL, TERM : : CIVIL ACTION .. LAW : : IN 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 Children who are the subject of this litigation is as follows: NAME Katelyn Nicole Barr Kristiana Marie Barr DATE OF BIRTH February 27, 1996 September 10, 1994 CURRENTLY IN CUSTODY OF Mother Mother 2. A Conciliation Conference was held in this matter on September 30, 2003, with the following individuals in attendance: The Father, Christopher Barr, with his counsel, Carol Lindsay, Esquire. The Mother, Julie Barr, with her counsel, Joan_ne Clough, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. /0~1-o 5 Date tacqttgl~ne M. Verney, Es~ Custody Conciliator