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Home My WebLink About08-2145i SHELLY D. CAVANAUGH Plaintiff, V. KEITH S. CAVANAUGH Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08- CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY NOW comes the Plaintiff, Shelly D. Cavanaugh, by and through her attorney, Mark F. Bayley, Esquire, and presents the within complaint for custody, representing as follows: 1. The Plaintiff, Shelly D. Cavanaugh, is an adult individual residing at 5 Penn Drive, Newville, PA 17241. 2. The Defendant, Keith S. Cavanaugh, is an adult individual residing at 720 Pinetown Rd., Lewisberry, PA 17339. 3. Plaintiff seeks custody of the following child: Name Present Residence Awe D/OB Elliot J. Cavanaugh 5 Penn Drive, Newville, PA 1 02/08/2007 4. The child was not born out of wedlock. 5. The relationship of the Plaintiff to the child is that of natural mother. The Plaintiff currently resides with: Name Lolonhi Gettle David Gettle She is married. Relationship (to the child) Grandmother Grandfather 6. The relationship of the Defendant to the children is that of natural father. He is married. 7. During the past five years, the child has resided with: Name Shelly Cavanaugh LoLonhi Gettle David Gettle Address 5 Penn Drive Newville, PA 17241 Date 4/3/2008/-Present Shelly Cavanaugh Keith Cavanaugh 720 Pinetown Rd. Lewisburg, PA 17339 2/8/08-4/3/2008 8. The Plaintiff has not participated as a party or witness, or in another capacity in other litigation concerning the custody of the children is this or any other Court. 9. Plaintiff has no information of a custody proceeding concerning the children pending in any Court of this Commonwealth or any other state. 10. Plaintiff does not know of a person nor a party to the proceeding who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 11. The best interests and permanent welfare of the children require Plaintiff to have primary physical custody and for Defendant to have specified periods of partial physical custody which may be agreed upon by the parties or otherwise be determined by the Court. WHEREFORE, Plaintiff requests this Honorable Court to schedule a custody conciliation conference. Respectfully submitted, BAYLEY & MANGAN Date: L?- Mark F. Bayley, 17squire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 Attorney for Plaintiff SHELLY D. CAVANAUGH : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW KEITH S. CAVANAUGH : NO. 08- CIVIL TERM Defendant. : IN CUSTODY VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unworn falsification to authorities. - P4,6. - Shelly D. Ca anaugh, Plaintiff flx? P e -W. SHELLY D. CAVANAUGH IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KEITH S. CAVANAUGH DEFENDANT 2008-2145 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Wednesday, April 09, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, May 09, 2008 at 9:30 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 define and narrow the issues to be heard by the court, and to enter into a temporary order. 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/ Hubert X. Gilroy, Es q. 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 Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 /00? * ?O - kh VI NY1 t AS'N 3d 1 1 :6 Wd 6- 8dV 8001 AUVIONO'Hi ldid 3NI ?O 2 3 20011y 4 SHELLY D. CAVANAUGH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW KEITH S. CAVANAUGH, NO. 2008-2145 Defendant IN CUSTODY COURT ORDER AND NOW, this 5 day of 40 2008, upon consideration of the attached Custody _4? Conciliation Report, it is ordered and directed as follows: 1. The mother, Shelly D. Cavanaugh, and the father, Keith S. Cavanaugh, shall enjoy shared legal custody of Elliot J. Cavanaugh, born February 8, 2007. 2. The mother shall enjoy primary physical custody of the minor child. 3. The father shall enjoy periods of temporary physical custody of the minor child as follows: A. On Monday and Wednesday from after daycare until approximately 8:00 p.m. B. On every weekend, with the parties alternating a schedule where on weekend one the father shall have custody from Friday after daycare until Saturday at approximately 7:00 p.m. and mother shall have the remainder of the weekend, with the second weekend father having custody from Saturday at approximately 7:00 p.m. through Sunday at approximately 8:00 p.m. C. At such other times as agreed upon by the parties. 4. The following shall also apply with respect to vacation and holidays: A. Each parent shall be entitled to two non-consecutive weeks of vacation with the minor child with the understanding that the parents shall give each other at least thirty days notice as to when they desire to exercise this time. B. The Christmas Holiday shall be divided into two segments; segment `A' from Christmas Eve at Noon until Christmas Day at Noon and segment `B' from Christmas Day at Noon until December 26 at Noon. For 2008, the mother shall have segment `A' and the father shall have segment `B' with the parties alternating thereafter. s. C. In even years, the father shall have Memorial Day and Labor Day and mother shall have New Years, Easter, July 4 and Thanksgiving Day. The parties shall alternate in odd years. 5. Exchange of custody shall be handled with the receiving party providing transportation unless the parties agree otherwise. 6. The parties may modify or alter the custody schedule set forth above upon agreement of the parties. If the parties do not agree, the parties shall follow the schedule as set forth above. In the event either party desires to modify this order, that party may petition the court to have the case again scheduled with the Custody Conciliator for a conference. ,Judge cc: " Wk F. Bayley, Esquire ?Mr. Keith S. Cavanaugh (2of ES MZ L LL (.Ps/oB y Cl) Y 7 3;. C1, • h SHELLY D. CAVANAUGH, Plaintiff VS. KEITH S. CAVANAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-2145 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Elliot J. Cavanaugh, born February 8, 2007 2. A Conciliation Conference was held on June 19, 2008, with the following individuals in attendance: The mother, Shelly D. Cavanaugh, who appeared with her counsel Mark F. Bayley, Esquire, and the father, Keith S. Cavanaugh, who appeared without counsel. 3. The parties agree to the entry of an Order in the form as attached. Date: June a 3 , 2008 4-v Hubert X. Gilroy, E: Custody Conciliator