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HomeMy WebLinkAbout07-5338TRAVIS LEE KISE, : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO: ~ ~ _ S.3 3 ~ C7 ~ r 1 ~ ~ <~.~. CIVIL ACTION -LAW WENDY SHUNIC, IN CUSTODY .Defendant. COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, Travis Lee Kise, by and through his attorneys, Mancke, Wagner, Spreha & McQuillan, and files the following Complaint For Gtistody: 1. The Plai~iff, Travis Lee Kise, is an adult individual `n~siding at 203 Indian Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant, Wendy Shunk, is an adult individual has an address at S7S Willow Street, Apt. K., Highspire, Dauphin County, Pennsylvania. 3. The Plaintiff is the natural father of 1 child, Karis Naomi Kise, born July 7, 2007, and the Defendant is the natural mother of said child. 4. From the birth of the child until Thursday, August 30, 2007, the child resided together with the Plaintiff and the Defendant at the address contained in paragraph 1 above, together with the paternal mother, Karen Lee Renaut. S. The Plaintiff knows of no other person asserting a claim to custody or partial custody of the child. 6. The child was born out of wedlock. 7. Plaintiff believes and therefore avers that it is in the best of the dtild to grant primary physical custody of the child unto the Plaintiff becau.4e the Plaintiff is able to care of the day to day needs of the child, has in the past since birth, taken care of the day to day needs of the child, and has a support system, including the paternal grandmother, available to assist in the custodial care of the child. WHEREFORE, Plaintiff requests the Court to great relief in granting primary physical custody of the Karis Naomi Kise to the Plaintiff herein. Respectfully submitted, Manske, Wagner, Spreha & McQuillan Richard Wagner, 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Plaintiff Date: .1" G~Z_ VERiFiCATIOIY I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. x ~ DATE: / ~~'/'0 7 C'~ ~ p ~ ~'~ m ~~"--. ' ~ r~ ~ ~` (n ~ ~ ~ ! ' C~ - d < ,_,y ~ , , 4.. .C d _ - ~ 3~ _,~ r _, .; .? ~- ' ~ = c-n -C ~- ~ ~ ~ n ~ r ,,~ t 1 TRAVIS LEE KISE, v. Plaintiff/Petitioaer, WENDY SHUNI~, Defendant/Respondent. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN Ci3STODY AND NOW, comes the Petitioner, Travis Lee Kise, by and through his attorneys, Mancke, Wagner, Spreha & McQuillan, and files the following Petition For Emergency Relief: 1. Your Petitioner, Tavis Lee Kise, is the Plaintiff in the above-captioned custody action. 2. The Respondent, Wendy Shunk, is the Defendant in the above-captioned custody action. 3. Petitioner and Respondent had been residing together at 203 Indian Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania, together with their child, Karis Naomi Kise, born July 7, 2007. 4. On August 30, 20(}7, without consent of the Petitioner, and without a Court Order, the Respondent removed the child from the jurisdiction of Cumberland County, moving to Willow Street, Apt. K, in Highspire, Dauphin County, Pennsylvania, in a part of the Highspite area which Petitioner believes to not be in the best interests of the child as an environment. 5. Petitioner requests the Court to grant his Petition For Emergency Relief by directing the return of the child, Karis Naomi Kise, unto the Petitioner herein, pending outcome of the underlying custody complaint, or direct that the Respondent return with the child to the jurisdiction of Cumberland County Court at 203 Indian Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania WHEREFORE, Petitioner prays this Court to grant the relief as requested. Respectfi~lly submitted, Mancke, Wagney Spreha & McQuillan P. Ri~Z3 ~ I.D. 103 3~"ront Street PA 17110 (717) 234-7051 Attorneys for Petitioner Datc:~~ ~ -2- I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. k ~",~L Yom' DATE: ~'~~~ / `~ V+~, `~.3 ~. ~~ T9[ ~~ y-: ~ ~ ~ ~ ~ ~~ ...~ i- _ Tip' -~ C", .;~ti`~ .~ © ~'' '. t .. ~~ ~. ~~~^~ ~`7 Lf! ~.` ~s,, { V _ ~M ~4 t '~~ TRAVIS LEE KISE, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5338 CIVIL V. CIVIL ACTION -LAW WENDY SHUNK, DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 12"' day of September, 2007, upon consideration of the Petition for Emergency Relief filed by the Plaintiff, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Defendant to show cause why the relief requested should not be granted; 2. The Defendant will file an answer on or before October 2, 2007; 3. The Prothonotary is directed to forward said Answer to this Court. 4. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Plaintiff shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Defendant files an answer to this Rule to Show Cause, and the answer raises disputed issues of material fact, an evidentiary hearing will then be scheduled. By the Court, Richard Wagne Attorney for Plainti ~lendy Shunk , Defendant bas ~~ M. L. Ebert, Jr., J. ~~~~~ ~yr~, 1 ~, :1111 ~ i ~ ~OflZ ~~~ ~ ~~~ TRAVIS LEE KISE PLAINTIFF V. WENDYSHUNK DEFENDANT IN THE CUMBE T OF COMMON PLEAS OF COUNTY, PENNSYLVANIA • 07-5338 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, September 12, 2007 , up it is hereby directed that parties and their respective counsel appear be at 4th Floor, Cumberland County Courthouse, Carlisle on ' for aPre-Hearing Custody Conference. At such conference, an effort if this cannot be accomplished, to define and narrow the issues to be t order. Al] children aQe five or older may also be present at the confer provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all Special Relief orders, and Custody orders to the conciliator 48 ho FOR THE COURT, By: /s/ Custody The Court of Common Pleas of Cumberland County is with Disabilites Act of 1990. For information about accessible fa available to disabled individuals having business before the court must be made at least 72 hours prior to any hearing or business be conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR AT'I HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO FORTH BELOW TO FIND OUT WHERE YOU CAN GET LE( Cumberland County B~ 32 South. Bedfor~ Carlisle, Pennsylvan Telephone (717) consideration of the attached Complaint, 'e Jacqueline M. Verney, Esq. ,the conciliator, arsday, October 04, 2007 at 8:30 AM 11 be made to resolve the issues in dispute; or rd by the court, and to enter into a temporary ~e. Failure to appear at the conference may Ming Protection from Abuse orders, prior to scheduled hearing. liator squired by law to comply with the Americans ;ilities and reasonable accommodations please contact our office. A11 arrangements Fore the court. You must attend the scheduled )RNEY AT ONCE. IF YOU DO NOT )R TELEPHONE THE OFFICE SET ~L HELP. Association Street ~ 17013 •9-3166 ~o-~~. ~ ~-l~1111~SNN~d 0 ~ ~~I Ind ~ I d3S EDOZ 1~i1'l1Qi~vi-kl4~d ~ ~0 ~~~~~ TRAVIS LEE KISE, PETITIONER v. WENDY SHUNK, RESPONDENT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.07-5338 CIVIL ACTION -CUSTODY ANSWER TO PLAINTIFF'S PETITION FOR SPECIAL RELIEF Defendant, Wendy Shunk, by and through her counsel Codi Tucker, Esquire and YWCA Domestic Violence Legal Clinic answers Plaintiff's Petition for Special Relief as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted in part, Denied in part. Defendant left the parties' residence on August 30, 2007 due to domestic violence. Defendant fled to Dauphin County, where her sister resides. Due to the incident of physical abuse, on September 3, 2007, Defendant filed a Petition for a Protection from Abuse Order. See attached Exhibit "A". Defendant was granted a Temporary Protection from Abuse Order on September 5, 2007. See attached Exhibit "B". On September 14, 2007, Plaintiff and Defendant were scheduled for a hearing on a Final Protection from Abuse Order. At this court date, the parties entered into an agreed Final Protection from Abuse Order on Defendant's behalf. See attached Exhibit "C". On September 4, 2007, Defendant filed a Custody Complaint in Dauphin County, however a custody conciliation conference has not yet been scheduled. See attached Exhibit "D". 5. Denied. Due to Plaintiff's abusive behavior, Defendant should continue to be the minor child's primary caregiver pending a conference in this matter. WHEREFORE, Respondent respectfully requests that Plaintiff's Petition for Special Relief be denied and that a custody conference be held as scheduled on October 4, 2007. Respectfully submitted, r Date: 1 13y Codi ucker, Esquire YWCA Legal Clinic 114 Walnut Street Harrisburg, PA 17101 (717) 724-0516 Attorneys for Defendant Sep 2Q L?7 11.:35a YW Le~a.l Clinic ~tIFICATION 7I7 '724 Q53a• p.4 I verify that the statements made in this Answer to Plaintiff's P~titition for Special Relief are true and ooitect. Y understanc!. that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date-~ `y -c~0 O~` `~ L~ Wendy Shunk, efendant/Respondent Petition For Protection From Abuse Page 1 of 5 PFAD Number QU2874664F Wendy Shunk Plamt~ff v. Travis Kise Defendant : IN THE COURT OF COMMON :PLEAS DAUPHIN COUNTY, PENNSYLVANIA `/ ~`~ "/ ri` No 1( ' CIVIL ACTION -LAW PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE ,., r + 1. Plaintiffs name is• ~;; ~ ~w i ~ ,'s Wendy Shunk t ~ ~ _ _ ~ ~ ; .'~ c~, c~?_~ - C ~ ~ C ~~ ,,,~ • -~1'~ + -d ~' f Y'i ` -,, 2 I, (the Plaintiff), am filing this petition on behalf of. .: '~ `• 'r' ~ - cn . - myself ° 3. Name(s) of ALL person(s), including minor children, who seek protection from abuse. a. Wendy Shunk 4 Plaintiffs address is confidential 5 Defendant's Name is. Travis Kise 6 Dcfendant is believed to live at the following address. 203 Indian Creek Drive ,Mechanicsburg, PA 17050 7. Defendant's Date of Birth is November 7,1984 https://www.pfad.org/PFADLive/petition asp?PetitionID=121752&cmdMove=Vlew+Print... 8/31/2007 Petition For Protection From Abuse 8. Defendant is an adult. 9. The relationship between Plaintiff and Defendant ls. ~ 1 spouse or former spouse of Defendant [x] parent of a child with Defendant [xl current or former sexual or intimate partner with Defendant [ 1 child of Plaintiff C 1 child of Defendant C 1 family member related by blood (consanguinity) to Defendant ~ ~ family member related by marriage or affinity to Defendant ~ 1 sibling (person who shares parenthood) of Defendant ~ ~ current or former cohabitant (person who lives with) Defendant 10. Defendant has been involved in a criminal court action. 11 Defendant is currently on probation /parole. 12. Defendant is currently on County probation /parole. Description: Curnberland County 13. Plaintiff and Defendant are the parents of the following minor child/ren: a Karis Naomi Kise Age•8 weeks Child's address is: Confidential 14. Plaintiff is seeking an order of child custody as part of this petition. The following is a list of the children and where they have live for the past 5 years a. Karis Naomi Kise For the past 5 years, this child has hued with: "There is no order or pending action for custody in this or any other jurisdiction." The child has lived with both parents since birth. 15. The facts of the most recent incident of abuse are as follows• Page 2 of 5 On about Wednesday, August 24, 2007 at approximately 4:37AM location: 203 Indidan Creek Drive, Mechanicsburg, PA 17050 The defendant called me en my cell phone after work and started telling me how angry he was so he threatened me that when we get home he will knock me out if I go to the house without our daughter. Even knowing that our daughter was sick he did not care and woke the baby up and then pushed me and continued to grab me and throw me against the wall, he stretched my hand,and punched me in the side of nny jaw. He left marks on my body and https (/www pled orl;/PFADLive/petition.asp?PetitionlD=121752&cmdMove=View+pnnt 8/31/2007 Petition For Protection From Abuse Page 3 of 5 the baby was crying for the rest of the night. 16. Prior incidents of abuse that Defendant has committed against Plaintiff or the minor children, (including any threats, inures, or incidents of stalking) arc as follows: The defendant was physically abusive towards me about a year ago in 2006 when we used to live together and he threatened me with a knife. The defendant punched me in my face and broke open my lips and once again he left marks and bruises on my body. I ended up calling the police and he was arrested for domestic violence and they took him to prison. After that incident the defendant started drinking mor often and the problem started to escalate. He began to became extremly physically abusive towards me. 17. (a) Has Defendant uscd or threatened to use any firearms or other weapons against Plaintiff or the minor child/ren? YES If so, please describe the use or threatened use below and list on Attachment A to Petition, which is incorporated by reference into this petition, any firearms, other weapons or ammunition Defendant used or threatened to use against Plaintiff and/or the minor children: The defendant has threatened me with a knife. (b) Other than the firearms, other weapons or ammunition Defendant uscd or threatened to use against Petitioner or the minor child/ren, does Defendant, to the best of your knowledge or belief, own or possess any additional firearm, othcr weapon, ammunition or any firearm license NO (c) If the answer to (b) above is "Yes", list any additional firearm, other weapon or ammunition owned by or 111 the possession of Defendant on Attachment A to Petition, which is incorporated by reference into this petition (d) Plaintiff DOES request that the court order Defendant to relinquish fircarms, other weapons or ammunition Listed on Attachment A to Petition See Attachment A to Petition, for a list of firearms, other weapons and ammunition Plaintiff requests the court to order Defendant to relinquish 18. The sherff, police department or law enforcement agency that should be provided with a copy of the protection order are• Harrisburg Hampton Township 19. There is an immediate and present danger of further abuse from Defendant 20. FOR THE REASONS SET FORTII ABOVE, Y REQUEST THAT THE COURT ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: https.//www.pfad.org/PFADLive/petition asp~PetittonID=121752&emdMove=View+Print... 8/31/2007 Petition For Protection From Abuse Page 4 of 5 a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or the minor child/ren in any place where Plaintiffand/or the children may be found. b. Evict/exclude Defendant from Plaintiff s residence and prohibit Defendant from attempting to enter any temporary or permanent residence of Plaintiff. c Award Plaintiff temporary custody of the minor child/rcn and place the following restrictions on contact between Defendant and the child/ren d. Prohibit Defendant from having any contact with Plaintiff and/or the minor child/ren, either in person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Plaintiffs school, business, or place of employment, except as the court may find necessary with respect to partial custody and/or visitation with the minor children. e Prohibit Defendant from having any contact with Plaintiff s relatives and P1alntifFs children listed in this petition, except as the court may find necessary with respect to partial custody andor visitation with the minor childrren. The following persons are Plaintiffs relatives or family and household members that Plaintiff believes require protection from stalking and harassment by Defendant f Order Defendant to temporarily relinquish some or all of the firearms, other weapons and/or ammunition listed on Attachment A to Petition and any firearm license to the sheriff of this county and/or prohibit Defendant from transferring, acquiring, or possessing some or all firearms for the duration of the order g Order Defendant to pay the costs of this action, including filing and service fees. h. Order the following additional relief, not listed above• The defendant will receive a drag and alcohol evaluation and follow through with all recommended treatment. The defendant shall enroll in and successfully complete a 26-week batterers counseling program. i. Grant such other relief as Plaintiff requests and/or ttie court deems appropriate. j. Order the police, sheriffor other law enforcement agency to serve Defendant with a copy of this petition, any order issued, and the order for hearing Plaintiff will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. https•//www pfad org/PFADLive/petition asp?PetitionlD=121752&cmdMove=View+Print... 8/31!2007 Petition For Protection From Abuse VERIFICATION I verify that I am the petrt~oner as designated in the present action and that the facts and statements contained m the above petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the Penalties of 18 Pa C.S A. §4904, relating to unsworn falsification to authorities Signature Date Respectfully Submitted by• Heather A.Siler Page S of S Agency. Victim Witness Assistance Program of Dauphin County SEP~~~, I hereby certify thcot~of theoor g nil true and correc PY filed. ~d . , fi~QXvr-ter https //www.pfad org/PFADLive/petition asp?PetitionID=121752&cmdMove=View+Prmt... 8/31/2007 Temporary Protection From Abuse Order Wendy Shunk Plaintiff Page 1 of 4 IN THE COURT OF COMMON :PLEAS DAUPHIN COUNTY, PENNSYLVANIA v. . No V~ - v - ~ ` ~ rt,l~ Travis Kise . Defendant 'CIVIL ACTION -LAW ' PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER ~, ~» r_= ° vs -~~ '~ Defendant's Name is: Travis Kise ~~ m=,:. '~ i f i 7 ~ :~-*i~ ~ cn f~~.,t,1 ~~ - Defendant's Date of Birth is: November 7,1984 ~* ~ T ~ ,, ~; c,~~i . ~ ha x, Defendant's Social Security Number is: ~~ w Names} of All protected persons, including Plaintiff and minor children: 1. Wendy Shunk AND NOW, on ~lst Day of August, 2007 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons In any place where they might be found. 2. Defendant is evicted and excluded from the residence at. or any other permanent or temporary residence where Plaintiff or any other person protected under this order may live. Plaintiff Is granted exclusive possession of the residcncc Defendant shall have no nght or privilege to enter or be present on the premises of Plaintiff or any other pcrson protected under this order. 3. Except for such contact with the minor children as may be permitted under paragraph 5 of this order, Defendant is prohibited from having ANY CONTACT with Plaintiff, or any other person protected under this order either directly or Indirectly, at any location, including but not limited to any contact at Plaintiffs or other protected party's school, business, or place of employment. hops //www.pfad org/PFADLive/temporder asp~TempOrderID=189772&cmdMove=View.. 8/31/2007 Temporary Protection From Abuse Order Page 2 of 4 4. Except for such contact with the minor children as may be permitted under paragraph 5 of this order, Defendant shall not contact Plaintiff, or any other person protected under this order, by telephone or by any other means, including through third persons. 5. USTODY P ding the outcom of the final hearing in is matter, Plainti is awarded tem rary custody of following minor chi ren. ^ 1. is Naomi Kise The local la enforcement agen in the jurisdiction w re the childre arE located shall a ure that the child/r are placed in the car and control o Plaintiff in acco ance with the term of this order 6. FIREARMS, OTHER WEAPONS AND AMMUNITION RESTRICTIONS Defendant is prohibited from possessing, transferring ar acquiring any firearms for the duration of this order. Defendant shall relinquish to the sheriff the following firearms licenses owned or possessed by Defendant. Defendant is directed to relinquish to the sheriff any firearm, other weapon or ammunition listed m Attachment A to Temporary Order, which is incorporated herein by references. Defendant may relinquish any firearms, other weapons or ammunition to the sheriff As an alternative, Defendant may relinquish firearms, other weapons and ammunition to a third party provided Defendant and the third party first comply with all the requirements to obtain a safekeeping permit. Defendant must relinquish any firearm, other weapon, ammunition or firearm license ordered to be relinquished no later than 24 hours after service of this order. If, due to their current location, firearms, other weapons or ammunition cannot reasonably be retrieved within the time for relinquishment, Defendant shall provide to the sheriff an affidavit listing the firearms, other weapons or ammunition and their current location no later than 24 hours after service of this order Failure to timely relinquish any firearm, other weapon, ammunition or any firearm license shall result in a violation of this order and may result in criminal conviction under the Uniform Firearms Act, 18 Pa C S A §6105 7. A certified copy of this order shall be provided to the sheriff: or police department where Plaintifl"resides and any other agency specified hereafter: Ilarrisburg Hampton Township 8. The sheriff, police or other law enforcement agencies are directed to serve Defendant with a copy of the petition, any order issued, and the order for hearing. Petitioner will inform the designated authority of any addresses, othex than Defendant's residence, where Defendant can be served. 9• TIIIS ORDER SUPERSEDES ANY PRIOR PROTECTION FROM https•//www.pfad org/PFADLive/temporder.asp?TempOrderID=189772&cmdMove=View. 8/31/2007 Temporary Protection From Abuse Order Pagc 3 of 4 ABUSE ORDER OBTAINED BY TIIE SAME PLAINTIFF AGAINST THE SAME DEFENDANT. 10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL AUGUST 31, 2010 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING NOTICE TO THE DEFENDANT Defendant is hereby notified that violation of this order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000 and/or up to six months in jail. 23 Pa.C.S.A. § 6114. Consent of Plaintiff to Defendant's return to the residence shall not invalidate this order, which can only be changed or modified through the filing of appropriate court papers for that purpose 23 Pa.C.S.A. § 6108 (g). If Defendant is required to relinquish any firearms, other weapons or ammunition or any firearm license, those items must be relinquished to the sheriff within 24 hours of the service of this order. As an alternative, Defendant may relinquish any firearm, other weapon or ammunition listed herein to a third party provided Defendant and the third party first comply with all requirements to obtain a safekeeping permit. If, due to their current location, firearms, other weapons or ammunition cannot reasonably be retrieved within the time for relinquishment, Defendant shall provide an affidavit to the sheriff listing the firearms, other weapons or ammunition and their current location no later than 24 hours after the service of this order. Defendant is further notified that violation of this order may sublcct him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. § § 2261-2262 NOTICE TO SHERIFF, POLICE AND LAW ENFORCEMENT OFFICIALS This order shall be enforced by the police department or sheriff who has jurisdiction over Plaintiff s residence OR any location where a violation of this order occurs OR where Defendant maybe located If Defendant violates Paragraphs 1 through 6 of this order, Defendant shall be arrested on the charge of indirect criminal contempt An arrest for violation of this order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence of a police officer or sheriff Subsequent to an arrest, the law enforcement officer or sheriff shall seize all firearms, other weapons and ammunition in Defendant's possession which were used or threatened to be used during the violation of the protection order or during prior incidents of abuse and any other firearms in Defendant's possession Any firearm, other weapon, ammunition or any firearm license must be delivered to the sheriffs office of the county which issued this order, which office shall maintain possession of the firearms, other weapons and ammunition until further order of this court, unless the weapons arc evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer or shenff made the arrest ~3Y THE COURT: hops://www.pfad org/PFADLive/temporder.asp?TempOrderID=189772&cmdMove=View... 8/31/2007 Temporary Protection From Abuse Order Pagc 4 of 4 .~- Jos H Kleinfelter ~_ ~~ ?~~~ ~ Date Distnb to ion to• Prothonotary for service on Pennsylvania State Police and Harrisburg Police Department Dauphin County Shenff: Serve PlaintiffDauphm County VWAP Serve Defendant Dauphin County Shenff Harrisburg Police Dcpartment (Plaintiffs Residence) Hampton Township Po11ce Department (Defendant's Rcsidence) Other: SEP 2 ,~ mil, I her®by certify that the foregoing is a true and correct copy of the original filed. Pr(1th~nn~~n, ~ ~ ~~~~ hops://www pfad.org/PFADLive/tcmporder,asp?TempOrder1D=189772&cmdMove=Vrew , 8/31/2007 Final Protection From Abuse Order Wendy Shunk Plaintiff v. Travis Kise Defendant Page 1 of 6 IN THE COURT OF COMMON :PLEAS DAUPHIN COUNTY, PENNSYLVANIA No. 2007 cv 08994 ab ' CIVIL ACTION -LAW PROTECTION FROM ABUSE FINAL ORDER OF COURT Defendant's Name: Travis Kise Defendant's Date of Birth: November 7,1984 Defendant's Social Security Number: Names and Dates of Birlth of All Protected Persons, including Plaintiff and minor children: Names Dates of Birth 1. Wendy Shunk November 8,1983 Plaintiff or Protected Person(s) is/are: [ ] spouse or former spouse of Defendant [X] parent of a child with Defendant [X] current or former sexual or intimate partner with Defendant [ ] child of Plaintiff [ ] child of Defendant [ ] family member related by blood (consanguinity) to Defendant [ ] family member related by marriage or affinity to Defendant [ ] sibling (person who shares parenthood) of Defendant [X] current or former cohabitant (person who lives with) Defendant. Defendant was served in accordance with Pa. R.C.P. 1930.4 and provided notice of the time, date and location of the hearing scheduled in this matter. Appearances by Parties and/or Counsel: • Plaintiff appeared personally and is represented by: Codi Tucker, Esquire https://www.pfad.org/PFADLive/finalorder.asp?FinalOrderID=119143 &cmdMove=View... 9/ 14/2007 Final Protection From Abuse Order • Defendant appeared personally and is represented by: Richard Wagner, Esquire AND NOW, this 14th Day of September, 2007 the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows: Page 2 of 6 This order is entered by agreement without an admission. Without regard as to how the order was entered, this is a final order of court subject to full enforcement pursuant to the Protection From Abuse Act. Plaintiff s request for a final protection order is granted. 1. Defendant shall not abuse, stalk, harass, threaten or attempt to use physical force that would reasonably be expected to cause bodily injury to Plaintiff or any other protected person in any place where they might be found. 2. Defendant is completely evicted and excluded from the residence at: Andy place that Plaintiff may reside or any other residence where Plaintiff or any other person protected under this order may live. Exclusive possession of the residence is granted to Plaintiff. Defendant shall have no right or privilege to enter or be present on the premises of Plaintiff or any other person protected under this order. 3. Defendant is prohibited from having ANY CONTACT with Plaintiff either directly or indirectly, or any other person protected under this order, at any location, including but not limited to any contact at Plaintiffs or other protected party's school, business, or place of employment. Defendant is specifically ordered to stay away from the following locations for the duration of this order. Parties may have limited peaceful contact regarding the minor child 4. Defendant shall not contact Plaintiff, either directly or indirectly, or any other person protected under this order, by telephone or by any other means, including through third persons. 5• The following additional relief is granted as authorized by §6108 of the Act: https://www.pfad.org/PFADLive/finalorder.asp?FinalOrderID=119143 &cmdMove=View... 9/ 14/2007 Final Protection From Abuse Order PHASE ONE Defendant is ordered within 10 days of the entry of this order to contact Mosaic (540-8041), SOLAIS (939-0519), or Tressler Lutheran Services (795-0330) to enroll in, and successfully complete Phase One (minimum 6 sessions) of the batterer's intervention counseling program. Upon completion of Phase One, the defendant is further ordered to comply and follow through with any recommendations resulting from the participation in Phase One. The defendant must successfully complete the program by satisfying all counseling and administrative requirements of the provider. The defendant is responsible for all fees for the evaluation and counseling. DRUG AND ALCOHOL COUNSELING Page 3 of 6 Defendant is ordered within 10 days of the entry of this order to participate in a drug and alcohol evaluation. The defendant is further ordered to comply and follow through with any recommendations resulting from that evaluation. The defendant must successfully complete the treatment by satisfying all counseling and administrative requirements of the provider. The defendant is responsible for all fees of the evaluation and treatment. Defendant is directed to to provide a copy of the Petition and any Court Ordered treatment.(Private Evaluation, Psychological or Drug and Alcohol, Seminar for Separating Parents, and Batterer's Treatment). A copy of the evaluation shall be provided to Pretrial Services. Defendant is also directed to provide their current address to Pretrial Services and advise them of any changes. Defendant shall have partial physical custody of the minor child on Friday September 21, 2007 until Monday Septemeber 24, 2007. Plaintiff will contact Defendant after the child's appointment on Friday Septemeber 21, 2007 to arrange a pick up time. Plaintiff shall pick up the child on Monday September 24, 2007 at 3:30PM at Defendant's residence. Should Defendant refuse to return the child to Plaintiff s custody on Monday September 24, 2007 at 3:30PM, local law enforcement officers shall assist Plaintiff in the return of the child. Plaintiff gives Defendant permission to remove the minor child from the https://www.pfad. org/PFADLive/finalorder.asp?FinalOrderID=119143 &cmdMove=View... 9/ 14/2007 Final Protection From Abuse Order State of Pennsylvania to travel to Ocean City, Maryland during the weekend of September 21-24, 2007. No person shall dispense prescription medication to the minor child without PlaintifFs consent. Plaintiff shall be permitted to contact Defendant once a day while Defendant has partial custody of the minor child. Defendant shall return Plaintiff s phone calls if she leaves a message. 6. (a) The costs of this action are imposed on Defendant, as follows: As per separate order 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Harrisburg Hampton Township 8. THIS ORDER SUPERSEDES ANY PRIOR PROTECTION FROM ABUSE ORDER OBTAINED BY THE SAME PLAINTIFF AGAINST THE SAME DEFENDANT. 9. All provisions of this order shall expire in 1 year, 6 months on March 14, 2009. NOTICE TO THE DEFENDANT Page 4 of 6 VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT- CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S.A. §6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. A VIOLATION OF THIS ORDER MAY RESULT IN THE REVOCATION OF THE SAFEKEEPING PERMIT, WHICH WILL REQUIRE THE IMMEDIATE RELINQUISHMENT OF YOUR FIREARMS, OTHER WEAPONS AND AMMUNITION TO THE SHERIFF. PLAINTIFF'S CONSENT TO CONTACT BY DEFENDANT SHALL NOT INVALIDATE THIS ORDER WHICH CAN ONLY BE MODIFIED BY FURTHER ORDER OF COURT. 23 Pa.C.S.A. § 6108(g). THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. §2265. IF YOU TRAVEL OUTSIDE OF THE STATE https: //www.pfad.org/PFADLive/finalorder. asp?FinalOrderID=119143 &cmdMove=View... 9/ 14/2007 Final Protection From Abuse Order Page 5 of 6 AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C §§2261-2262. IF YOU POSSESS A FIREARM OR ANY AMMUNITION WHILE THIS ORDER IS IN EFFECT, YOU MAY BE CHARGED WITH A FEDERAL OFFENSE EVEN IF THIS PENNSYLVANIA ORDER DOES NOT EXPRESSLY PROHIBIT YOU FROM POSSESSING FIREARMS OR AMMUNITION. 18 U.S.C. §922(g)(8). NOTICE TO SHERIFF, POLICE AND LAW ENFORCEMENT OFFICIALS The police and sheriff who have jurisdiction over Plaintiffs residence OR any location where a violation of this order occurs OR where Defendant maybe located, shall enforce this order. The court shall have jurisdiction over any indirect criminal contempt proceeding, either in the county where the violation occurred or where this protective order was entered. An arrest for violation of paragraphs 1 through 4 of this order maybe without warrant, based solely on probable cause, whether or not the violation is committed in the presence of the police or any sheriff. 23 Pa.C.S.A. §6113. Subsequent to an arrest, and without the necessity,of a warrant, the police officer or sheriff shall seize all firearms, other weapons and ammunition in Defendant's possession that were used or threatened to be used during the violation of the protection order or during prior incidents of abuse and any o~her firearms in Defendant's possession. The Dauphin County Sheriff shall maintain possession of the firearms, other weapons or ammunition until further order of this court. When Defendant is placed under arrest for violation of this order, Defendant shall be taken to the appropriate authority or authorities before whom Defendant is to be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police officer, sheriff OR Plaintiff. Plaintiff s presence and signature are not required to file the complaint. If sufficient grounds for violation of this order are alleged, Defendant shall be arraigned, bond set, if appropriate and both parties given notice of the date of the hearing. Date Entered pursuant to the consent of plaintiff and defendant: https: //www.pfad. org/PFADLive/finalorder.asp?FinalOrderID=119143 &cmdMove=View... 9/ 14/2007 __- _~sEP 1 ~---_- Final Protection From Abuse Order Page 6 of 6 Plaintiffs Signature Defendant's Signature Distribution to: Prothonotary for service on Pennsylvania State Police and Harrisburg Police Department Dauphin County Sheriff: Serve Plaintiff Serve Defendant Police Department (Plaintiff s Residence) Police Department (Defendant's Residence) Other: 1 hereby certify that the forgoing is a true and collect copy f the original filed. .. ~~ PrA https://www.pfad.org/PFADLive/finalorder.asp?FinalOrderID=119143 &cmdMove=View... 9/ 14/2007 r Name:~J v Address: ~_~,~~~ ~ 0.. city: Y r s , PA Zip; 101 Telephone ~~' ~~ 1 ~~~..'~ ~~~ Email• ~~~+e SY\~' ~~~ GJ ~~~a~' • ~ W S Plaintiff v. Defendant N t...7 ...,r <n ti (r( -t: ;' ~J m -- ( :t",-, '~ ., - ~? ~, f N /~~ iN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. ~L CV q~~ CU CIVIL ACTION - I.AW CUSTODY ACTION COMPLAINT FOR CUSTObYw,-` 'v' _ -1~rr,'~ .~ 7c~ cam. t.> r `~ ~ ~-r ~ r--~ ''" _, I C~ :~~ _.~ 1. The Plaintiff is ,residing at - -- - ~ i ~ ~ -- - ; Y r ~ 5 r i County, PA - - - . (Sfreef a Tess) (City) (Zlp code) ,-~ 2. The Defendant is _ _ ~'`C'o`V ~,~~~_ ~ k ~ 5~.. ,residing at X43 ~~~h G~~QY ~ ~~1 County, PA ~~~. - (Sfreef address) - ~~ (Cify) ~ - °- - - - - (Zip code} -. _ = _- " 3(a). Plaintiff seeks ustody) partial custody) (visitation) of the following child(ren). - - ~ ~ "-` Name Present Residence Date of Birth Revised 9 0-06 ©Dauphrn Caunty Court of Common Pleas 3(b}. The child(ren) wa were) (was not/were not) born out of wedlock. The child(ren) are presently in the custody of ~ ~ ,who resides at `~tiq r ~ , PA. His or her relationship to the child(ren) is ~ t'~( During the past fve years, the child(ren) have resided with the following persons and at the following addresses: List Alt Persons list All Addresses) Dates ~~.~~ `~~~ ~~~c~ ~~~r ~ 1i~1 ~p ~a"il ' v ~ ~`10~p 3(c) The mother of the child(ren) is currently residing at ~,OhC,- U~~~~ 1 _ , PA. She is (married (divorced) (single). The father of the child(ren) is~KCJ.y~~ ~ s ~. ~ S~e~ , - currently residing at ~o"~~.r~;,~,~,, C,~re.2~ V(~ V~ - - , PA~ He is a _ _ (married) {divorced) single}. 4. The relationship of Plaintiff to the child(ren) is that o Mother (Father) (Other): If Other, explain: currently resides with the following persons: The Plaintiff Revrsed 10-06 ©Dauphm County Court of Camman P{eas Name Relationship 5 The relationship of Defendant to the child(ren) is that of (Mother) l=athe ) (Other): if Other, explain: The Defendant currently resides with the following persons: Name ` c~v ~ S 1.~ ~;~5~ ~~~ ~~~~ Relattonshio ~~~~ r 6(a). Plaintiff (ha (has not) participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child(ren) in this or another court. The court, term and number, and its relattonship to this action is: -- - 6{b) -Plaintiff (has) (has no information of a custody proceeding concerning the -- - . child(ren) pending in a court of this Commonwealth or any other state The court, term and number, and its relationship to this action is: Revised 4 0-06 Q Dauphin County Court of Common Peas 6(c). Plaintiff {knows) does not know of a person not a party to the proceedings who has physical custody of the child(ren) or claims to have custody or visitation rights with respect to the child(ren). The name and address of such person is: 7. The best interest and permanent welfare of the children} wilt be served by granting the relief requested because (set forth facts showing that the granting of the relief requested* will be in the` best inRterest and permanent welfare~of th\e child(ren): ~Q ~ ~ ~ ~~-~ ~ o w.-~,S ~ G v 8. Each parent whose parental rights the person who has physical custody of the ch~id(ren) have been named as parties to this action. Aii other persons, named below, who are known to have or claim a right to custody or visitation of the child(ren) will be given notice of the pendency of this action ~tld(ren} have not been terminated anti~~ ~~' ~-~ and the right to intervene: Name Address Basis of Claim Wherefore, plaintiff requests the court to grant custody (partial custody) (visitation) of the child. Revised 10-06 m Dauphin County Court of Common Pleas I verify that the statements made in the Complaint are true and correct I understand that false statements herein are made subject to the penalties of 1$ Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date VJe~. ~ ~n Signature of laintiff Telephone Number of Plaintiff sEP z ~ ~oo~ I hereby certify that the foregoing is a true and correct copy of the original filed. ~~J C.. fi i Revised 10-Q6 Pri~thOn t8ry ©Dauphm County Court of Common Pleas !N THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA Plaintiff v, ; NO. CV CU IN CUSTODY Defendant . AFFIDAVIT OF SERVICE 1, ,hereby verify that on day of 20_, t served the other party with a true and correct copy of the Custody Complaint and scheduling order by one of the following methods. (CHECK ONE) () Service was made by United States Postal Service, first class mail, postage ` prepaid, certified, restricted delivery, retum receipt requested to the other party, on the day of 20___. The return receipt signed by the other party is attached hereto. () The other party was personally served with a true and correct copy of the Custody Complaint by hand-delivering the same to the other party. Personal service was made at the following location and time: on the day of - , 20 , at o'clock. . i verify that the statements made in this affidavit are true and correct. ! understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: SIGNATURE OF THE PERSON WHO MADE SERVICE Revised 10-06 © Dauphin County Court of Common Pleas . (pQ~, .fj~V Plaintiff . v. . `YOIVi ~...,. , ~~ ti Defenda~ j~ . iN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA NO. SOU ~ CV ,~~ CU CIVIL ACTION iN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint #or Custody, it is hereby directed that the parties and their respective counsel appear before the Custody Conference Officer on the day of , 20~, at _.m. at the Dauphin County Courthouse, 4~' Floor, Front and Market Streets, J ~~~ -~~- - ` Harrisburg,'PR for-a Cu-stody Confie~ence:4Rt~such Conference;~ri-effort will ;be made -_~~=. , _- , _ to resolve the issues in dispute; or if this cannot be accomplished, to define arld narrow - - the issues to be heard by the Court, and to enter into a Temporary Order..-Children ~, , should not attend the conference unless requested by the Custody Conference Officer. For the Court, Date: Custody Conference Officer YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT aNCE. IF YOU DO NOT -=- .--~~~ HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. DAUPHIN COUNTY LAWYER REFERAL SERV{CE 213 North Front Street Harrisburg, PA 17101 {717) 232-7536 Revised 10-06 ©Dauphm County Court of Common Pleas AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Dauphin County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessib{e facilities and reasonable accommodations available to disabled individuals having business before the court, please contact the Court Administrator's Office at (717} 780-6624. A11 arrangements must be made at least 72 hours prior to any hearing or business before the court, You must attend the scheduled conference. Revised 10-06 (~ Dauphin County Court of Common Pleas C'? ~' ~5 `':~ -st t _..- w t,s . } -' ?=-~ ~.'S :`C. .. , r~ TRAVIS LEE KISE, Plaintiff v. WENDY SHUNK, Defendant To Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND, PENNSYLVANIA NO. 07-5338 CIVIL ACTION -LAW CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Wendy Shunk, to proceed in forma pauperis. I, Codi Tucker, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party. '~; 1 ! 1 Date: ~ ~: ~ ~ ~~ ~ ' ~ ~. ~ ~ ~ ~ Codi Tucker, Esq. YWCA Domestic Violence Legal Clinic 114 Walnut Street Harrisburg PA 17101 (717)724-0516 Attorneys for Defendant ORDER AND NOW, this day of ,pursuant to Pa.R.Civ.P. 240(d), upon pres 'nand eration of the within Praecipe to Proceed In Forma Pauperis 'on is hereby granted. Prothonotary ~' ~ t"~ i 4. q W' ~ .. r' _~:.. 5 ~} w, ~~ ~ ~~~ t~ • , t ~ S s '';. it J i' i": . l J- .~^^ .. TRAVIS LEE KISE, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. N0.07-5338 WENDY SHUNK, :CIVIL ACTION -LAW Defendant :CUSTODY CERTIFICATE OF SERVICE I, Codi Tucker, Esquire, of the YWCA Domestic Violence Legal Clinic, attorney for Defendant, Wendy Shunk, hereby certify that I have served a copy of the Answer to Plaintiff's Petition for Special Relief on the following on the date and in the manner indicated below: U.S. First Class Mail, Postage Pre-Paid Richard Wagner, Esquire 2233 N. Front Street Harrisburg, PA 17110 Date: YWCA Domestic Violence Legal Clinic i By. odi ucker, Esq. 114 Walnut Street, 2"d Floor Harrisburg, PA 17101 (717) 724-0516 Attorneys for Defendant N n r--_ ~ = ~.,, -~ .. -i S ~~ __ _'a " :y - h? `~ TRAVIS LEE KISE, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-5338 C1VIL CIVIL ACTION -LAW WENDY SHUNK, DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 4th day of October, 2007, upon consideration of the Plaintiff's Petition for Emergency Relief and the Defendant's Answer thereto and the Court noting that a custody conciliation hearing was held before Jacqueline M. Verney, Esquire at 8:30 a.m. on this date, IT IS HEREBY ORDERED AND DIRECTED that the Plaintiff's Petition for Special Relief is hereby DENIED. By the Court, ~~ M. L. Ebert, Jr., P. Richard Wagner, Esquire Attorney for Plaintiff ~o ,£S ,~~~L~. Codi Tucker, Esquire 1 Attorney for Defendant /O~N107 bas ~~ J. I. j~{ f ~v;, .: i i -,_~~~_~~r.~ _/ fl CT 0 5 200~j, TRAVIS LEE KISE, Plaintiff VI. WENDY SHUNK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-5338 CIVIL ACTION -LAW IN CUSTODY ORDER OF COURT t~- c( AND NOW, this 1 ~ day of ~ c,~C 0~4 L~ , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Travis Lee Kise and the Mother, Wendy Shunk, shall have shared legal custody of Karis Naomi Kise, born July 7, 2007. 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 her health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. The parents shall have shared physical custody of the child on the following schedule: A. Father shall always have physical custody of the child on Mondays and Tuesdays overnight. B. Mother shall always have physical custody of the child on Wednesday and Thursday overnights. C. The parties shall alternate weekends from Friday to Monday morning. Father shall have the first weekend, starting October 5, 2007. D. Thanksgiving shall be shared with Father having physical custody of the child from 9:00 a.m. to 3:00 p.m. and Mother having physical custody of the child from 3:00 p.m. to 9:00 p.m. 3. In the event that the custodial parent is in need of a babysitter during their weekend custodial period for more than four hours, they shall contact the non-custodial parent and offer said time to the non-custodial parent. 4. Father shall be responsible for all transportation and exchanges shall occur at Mother's daycare. 5. Neither party shall partake of alcohol or illegal drugs to the point of intoxication while the child is in their physical custody. 6. The non-custodial parent may contact the custodial parent one time per day to receive an update about the child. 7. Only medication prescribed for the child may be administered to her. 8. Compliance with this Order supersedes the provisions of the PFA Order. 9. 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. Another Custody Conciliation Conference is scheduled for December 4, 2007 at 8:30 a.m. BY THE COURT, J. cchard Wagner, Esquire, Counsel for Father ~Z"odi Tucker, Esquire, Counsel for Mother V AA ~~ ly /~ /O ~~I ~ ~~ ~f 1 y ~ a ~ ~~o ~,pQZ ~~ ~~ ~~, TRAVIS LEE KISE, Plaintiff V. WENDY SHUNK, Defendant PRIOR JUDGE: None IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-5338 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 Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Karis Naomi Kise July 7, 2007 Mother 2. A Conciliation Conference was held in this matter on October 4, 2007, with the following in attendance: The Father, Travis Lee Kise, with his counsel, P. Richard Wagner, Esquire, and the Mother, Wendy Shunk, with her counsel, Codi Tucker, Esquire. 3. A PFA Order of Court dated September 14, 2007 was entered by the Honorable Joseph H. Kleinfelter of the Court of Common Pleas of Dauphin County at No. 2007 cv 08994 ab, providing protection for mother from contact with father except for custody matters. 4. The parties agreed to an Order in the form as attached. Date ac eline M. Verney, Esquire Custody Conciliator DEC 0 3 2p0a TRAVIS LEE KISE, : IN THE COURT OF COMMON PL Plaintiff :CUMBERLAND COUNTY, PENNSYLV A IA ~'' : N0.2007-5338 CIVIL ACTION -LAW WENDY SHUNK, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 3rd day of December, 2007, being advised that the arties p are satisfied with the current Order of Court, the Conciliator hereby relin uishes q jurisdiction in this matter. FOR THE COURT, / ,~ ~~ ~. ~ ~ ' Jacq ine M. Verney, Esquire, Custo ~ Conciliator ~ ~~1 l ~ .s { ~ i_ 1n~iR n, ~ ,- 1-~