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E~/Of'\- i<Jt,,,,- 1./,1.111t..( jOf('- ChflJj.sh"V'/.S tJ//7' i .511l,L-T J'tJ 6' (AJ ~.'oc), i \ EV~j'-l 7~A. o~ sqf t)::,.fJ,.. ,A,..;o /''1/17 /9-ih ! the~ fJ/l.Alf,'FF }l;Jy-) (JeJ=.P.I'J{jf7tJ+ t.ll/l .::sfedO fl<:..t::Jf'! : 9' f,J\'\ to L( fi" jtJ5c.:thf'.12- f'O C~le~.,e.ltr<. 1'..,::. c.h,'QUNr ! r..... J 1 JfI {b) M 1, OlV J .::;. F / t I!Je...cPI""'S A f~or:::,lel'\ !Ne- t wI/I ,A 1 "kL,v' /t1e-- 7ff1.eS j cf." / O/!-f"d QrJ C h.IJ../:.:,-tf'l~s /JAY ik.fJfJ/'5 E 1'1e."*,L~N AND SUBSeRI E~t TO BEFORj ME THIS ..1.~DAY OF "II~'W ~ I " '" (") -..10 C :c z -~ "'0 G.' 0 f11rT\ ~~ ~ --- Z:Ll 8 z~ C"' (f.l .C' ~ ~Cj :> "- ~8 :x ......... c.? I::l<) )>c -c:, ~ ~ ~ 0" .,..1 \' P ~ r;;.' 1'tl ~ ~ "'\ o "T\ t":";':; - ;.:!i'rl !:l:}~ (;,:):'1) :::'.0 15rn --I ~ 'VOV 2 () 2eO~ d:I 0 1-' ()50~5 }J' Dr;NJJ/5 e !'1EY~/2- JE_ fllji,tJj,';::r- -:[tJ tk CQu!1.t 0;: v CQjVJIVYJ;) fIe;?.> .oF (U!'l[J?l"lnhj) e. oVlv11 / feAJ/J:S"YL v/}A/.../i I :Vt1/IJEt /1} (VICIE. (2- Depe.No/!".,t. C !Vie jiChON L/J"i,J .-- !lJ,o, Ct;:;O';) CIV/~ ;)0 ~ C\J51oPj / '//:5 1f,1'f/otJ I ~' - I. i,/1/')O jVovJ./ 1 AJf Jt. O/J'/ oP IJ~ U pop) I Crvl'Js l.oee/ttl^i.J OF 1J.,€... 17iM c.he.O R..ee"tl€sf /3Y _ lJ)eJJtJi"S 6- (ne'/e.fL.:r12. ;1/1fJ J!JNct /0/) I'1Ei'Ef?- /3t:: I ~ fiHEtP.-O jJ..s /I rere../I1/iAJ€JJt O/2..[)eR. or- cu.sfoCij /Vlsl1!1+/0f..!. I 6Y: ee: DENNIS MEYER 7073 Carlisle Pike Carlisle, Pa. 17013 ~Op'I(l.5 1/-!l.1-()/ ~ti\L(ll RXS JANET M. t1EYER 7073 Carlisle Pike Lot 132 Carlisle, Pa. 17013 . " . VlNVAl).SNN3d Ai.Nnoo OJl,0/7!:E!8?'V~ ZF; : 1/ /./V LZ Mil 10 IL''-i''')!;'!)'''II'''':';i ..f(O I\OV.L.l.l1 '_. /'^,'vc...; .....; '..... _ JJlj:!O'0:37d RODERICK KECK, Appellant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. COMMONWEALTH OF PENNSYLVANIA: PENNSYLVANIA DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, Appellee 01-6605 CIVIL TERM ORDER OF COURT AND NOW, this 25th day of January, 2002, the appeal of Roderick Keck from the suspension of his operating privileges and the imposition of a requirement by the Department, sua sponte, that he comply with the ignition interlock requirements, is sustained in part and denied in part. It is sustained in that the direction by the Department that he comply with the guardian interlock requirements is overruled. It is denied insofar as the Department has suspended his license for the conviction under 373l(a) of the Vehicle Code. This order is entered pursuant to the Commonwealth Court's recent decision in Schneider versus Commonwealth of Pennsylvania Deoartment of Transoortation, No. 1513 C.D. 2001. ~egory Cutler, Esquire VFor the petitioner L df1UD;;;;J > OIJO -O,z L RXS Guido, J. ~eorge Kabusk, Esquire t/For the Commonwealth It l/iN\i^lASNN3d AlNnm O~~/lir-:;81^Jm ES fJI 21 :6 HV OS NYI' 20 A!:fvlONC' , '. ;:)0 3Cx~:,!,~)-{j::J .i!.~ 61 VS :IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . OI-wOS ; NO .016505" CIVIL TERM Dennis E. Meyer, Plaintiff I Petitioner Janet M .Meyer Defendant I Respondent : CUSTODY PETITION TO MODIFY CUSTODY ORDER -------------------- THE PETITIONER ,Dennis E . Meyer Jr. ,by and through state the following : I. The Petitioner, hereinafter referred to as the father , is an adult individual who currently resides at 7073 Carlisle Pike , Lot 132 , Carlisle, Pennsylvania . 2 . The Respondent, Janet M. Meyer, hereinafter referred to as the mother, is an individual who currently resides in Carlisle, Pennsylvania. 3 . The parties are the parents of Raven A. Meyer, Melissa N. Meyer and Dakota J . Meyer . 4 . Both parents have shared custody and shared legal custody entered by this court on November of2001 . WHEREFORE, the petitioner, Dennis E . Meyer Jr. , requests that this Court modify the order of November 2001 ,and grant him primary physical custody of the minor children, Raven A. Meyer, Melissa N . Meyer and Dakota J. Meyer. Respectfully submitted , ~~ ~~_Jl.. Dennis E . Meyer Jr. ~ ~ ~ - ~ ~ ~ ~ i32 ~ B o !:; ~6~"; Mln: -;><..... ~< ./._..c. 0.-':~ 2C:: ~:c: ~(5 :l>c z =< D 1'0 i'') N C'''~'' :!;.')'> '2 i:j ~g -< ...J PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DENNIS E. MEYER V. 01-6505 CIVIL ACTION LAW JANET M. MEYER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, April 02, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueliue M. Veruey, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, May 01, 2002 at 3:30 PM 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. All children age five or older may also be present at the conference. Fai]ure 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: Isl Jacqueline M. VernQ'. 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 ATIORNEY AT ONCE. IF YOU DO NOT HAVE AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlis]e, Pennsylvania 17013 Telephone (717) 249-3166 -~~AP~~~ -w~F? ~ ~-rP , \i;~N!\l^SNNjd ,1J.NnCC' II .,) "I - "J".O . . ~>~ c-d'J'j(j. '. ("'c7 t:< It C'~.~;, . v ~6 2002 6, VS :IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . 0 I, WOS : NO .016505" CIVIL TERM Dennis E. Meyer, Plaintiff I Petitioner Janet M .Meyer Defendant I Respondent : CUSTODY PETITION TO MODIFY CUSTODY ORDER THE PETITIONER ,Dennis E . Meyer Jr. ,by and through state the following : I. The Petitioner, hereinafter referred to as the father , is an adult individual who currently resides at 7073 Carlisle Pike , Lot 132 , Carlisle, Pennsylvania. 2 . The Respondent, Janet M. Meyer, hereinafter referred to as the mother, is an individual who currently resides in Carlisle, Pennsylvania. 3 . The parties are the parents of Raven A. Meyer, Melissa N. Meyer and Dakota J . Meyer. 4 . Both parents have shared custody and shared legal custody entered by this court on November of2oo1 . WHEREFORE, the petitioner, Dennis E . Meyer Jr. , requests that this Court modifY the order of November 200 I , and grant him primary physical custody of the minor children, Raven A . Meyer, Melissa N . Meyer and Dakota J. Meyer. Respectfully submitted , ~__e_~~,- Dennis E . Meyer Jr. ~ ~ ~ - ~ ~ ~ --- iE. .:Q 'B o s "tltL nl. . ~---- L.~ '1 C: 3> -, ._. c. 6(:) Pc: ~ . CJ r-..) ~''''. i'.J "', ~; (5 ::_) ."'.i ~~ :0 --< ....J V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. of - 6505 CIVIL TERM DENNIS E. MEYER, JR., Plaintiff JANET M. MEYER, Defendant IN CUSTODY PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of the Family Law Clinic on behalf of Dennis E. Meyer, Jr., the Plaintiff in the above captioned matter. April 17, 2002 ~,[\ ~- %3 Jenm er er y ~-:~~ .~ THOMAS M. PLACE LUCY JOHNSTON-WALSH Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 DENNIS E. MEYER, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CML ACTION-LAW NO. 02 - 6505 CIVIL TERM JANET M. MEYER, Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Jennifer Heverly, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a true and correct copy of Praecipe to Enter Appearance on Defendant, Janet Meyer, of 834 Factory Street, Carlisle, Pennsylvania, 17013, by depositing a copy of the same in the United States mail, First Class, postage prepaid, this 17th day of April, 2002. '-- Jennifer Hev ly Certified Le al Intern THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 () c:: ~ "1::>"< !1')C;: ~f.}} tf.( if~;. J~ .<...() ~Cj c:: $ / R5 ho -0 ;:0 o -" - :~ i[i ,J"1 '. r--= _:{fTl ':'''6 ...../ r~' - ?''j--j1 :,3-0 (5m .:-/ ~ ""<; ......, -', ::t w " I",> 0"\ MAY 2 3 200t' J) DENNIS E. MEYER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2001-6505 CIVIL TERM JANET M. MEYER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this J~ day of 1t"7r , 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Dennis E. Meyer, and the Mother, Janet M. Meyer, shall have shared legal custody of Raven A. Meyer and Melissa N. Meyer, born May 12,2000 and Dakota J. Meyer, born September 27,2001. 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. The parties shall have shared physical custody of the children on the following schedule: A. Week on/week off with Saturday at 2:00 p.m. being the exchange day and time. Father's week shall begin May 25, 2002. B. The non-custodial parent shall have physical custody of the children on Wednesdays from 4:00 p.m. to 8:00 p.m., except when the custodial parent is on vacation or otherwise out of the area. 3. The exchange of physical custody shall take place with the "receiving parent" providing transportation so that the parties have as little contact with each other. 4. schedule: The following holiday schedule shall supercede the regular custody A. Mother shall have physical custody of the children on Mother's Day; Father shall have physical custody of the children on Father's Day, both at 10:00 a.m. to 8:00 p.m. B. The parties shall share the children's birthdays as agreed by the parties, from 8:00 a.m. to 1 :00 p.m. and 1 :00 p.m. to 6:00 p.m. C. The parties shall alternate the Thanksgiving holiday from 10:00 a.m. to 8:00 p.m. Mother shall have physical custody of the children on Thanksgiving in even numbered years; Father shall have physical custody of the children in odd numbered years. D. Easter Sunday shall be alternated between the parties from lO:OO a.m. to 8:00 p.m. Mother shall have physical custody ofthe children in even numbered years; Father shall have physical custody of the children in odd numbered years. E. The Christmas holiday shall be divided into two Blocks. Block A shall be from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be from Christmas Day at l2:00 noon to December 26 at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. 5. Neither party shall leave the jurisdiction of Pennsylvania without prior notification of the other party, along with the location, address and telephone number where the children may be contacted. 6. Neither party shall consume alcoholic beverages to the point of intoxication or illegal drugs while the children are in their physical custody. 7. Neither party shall do anything, nor permit a third party to do anything that may estrange the children from the other party, or injure the opinion of the children as to the other party, or may hamper the free and natural development of the children's love or affection for the other party. 8. The parties shall keep each other advised immediately relative to any emergencies, medical or otherwise, concerning the children and shall, further, take any necessary steps to ensure that the health and well being of the children is protected. During such illness or medical emergency, each party shall have the right to visit the children as often as her/she deems consistent with the proper medical care of the children. 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. BY J. Edward E. Guido, c<Aennifer Heverly, certified legal jntern, Lucy Johnston-Walsh, Esquire, Family Law Clinic, Counsel for Father J-isa Marie Coyne, Esquire, Counsel for Mother II t... ~ 5-~~b-Od-. \:fIN\lf\lJ\SNN3d I llo.\n(',r'\ (1lo."F'''-\-:;?\~\\1''\ 1\'.\,1'\ ,oJ..) 'j" ".~." _'0 ' ...J L \ ~\\ \.,y~~ Bl, h\li.o\'ZO )...'d1 \. G:;;~;"\' ".' , " jO ji)\J::,()--c:d \\:1 DENNIS E. MEYER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2001-6505 CIVIL TERM JANET M. MEYER, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. 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 DATE OF BIRTH CURRENTLY IN CUSTODY OF Raven A. Meyer Melissa N. Meyer Dakota J. Meyer May l2, 2000 May 12,2000 September 27, 2001 shared shared shared 2. A Conciliation Conference was held in this matter on May 21,2002, with the following individuals in attendance: The Father, Dennis E. Meyer, with his counsel, Jennifer Heverly, certified legal intern and Lucy Johnston-Walsh, Esquire, from the Family Law Clinic and the Mother, Janet M. Meyer, with her counsel, Lisa Marie Coyne, Esquire. 3. A prior Order of Court, dated November 26, 200 1 was entered by the Honorable Edward E. Guido, providing for shared legal and physical custody on a week on/week offbasiso PFA Orders, dated March 14,2002 and April 29, 2002, are also in effect by Order of the Honorable Co Joseph Rehkamp, Perry County, Pennsylvania, restricting Father from contact with Mother except for discussion and transfers regarding the childreno A petition for indirect criminal contempt is currently pending before the Honorable 1. Wesley Oler, Jro in the PFA matter. 40 The parties agreed to the entry of an Order in the form as attached. .s - a... I '0 ')....- Date ac line M. Verney, Esquire Custody Conciliator DENNIS E. MEYER PlaintifflPetitioner : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2001-6505 CIVIL TERM JANET M. MEYER, DefendantIRespondent IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW comes the Petitioner, Dennis E. Meyer, Jr., by his attorneys, Irwin & McKnight, and presents the following Petition for Modification of Custody. 1. The Petitioner, Dennis E. Meyer, Jr., is an adult individual with an address of 7073 Carlisle Pike, Lot 132, Carlisle, Pennsylvania 17013. 2. The Respondent, Janet Mo (Meyer) Martyn, 7073 Carlisle Pike, Lot 112, Carlisle, Pennsylvania, 17013. 3. The parties are the natural parents of three (3) children, namely Raven A. Meyer and Melissa N. Meyer, born May 12, 2000, and Dakota J. Meyer, born September 27,2001. 4. The Petitioner desires that the parties have shared legal custody of said minor children. 50 The Petitioner desires primary physical custody of said minor children, with periods of temporary physical custody to Respondent as the parties agree is in the best interest of said childreno 60 The best interests and permanent welfare of the minor children requires that the Court grant the Petitioner's request as set forth aboveo WHEREFORE, Petitioner, Dennis Eo Meyer, Jr., respectfully requests that he be awarded primary physical custody and shared legal custody of Raven A. Meyer, Melissa No Meyer, and Dakota Jo Meyer, as provided herein, with periods of temporary physical custody to Respondent as provided hereino By: Marcu Attorne for Plaintiff 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court 1. D. No. 25476 Date: Jnne 16,2005 EXHIBIT "A" M~'l ( 3 ;)0:1;, .~ _'.,' 1 ./ DENNIS E. MEYER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2001-6505 CIVIL TERJ"I .JANET M. MEYER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW. this dK'tI" day of _ f'11r(J. .____,2002. upon considcrmion of the mtached Custody Conciliation Repon, it is ordered and directed as follows: I, The Father, Detmis E, Meyer, and the Mother. Janet tv!. Meyer, shall have share.9J~~al custody of Raven A, Meyer and Melissa N. Meyer. born !\lay 12.2000 and Dakota J, Meyer, born September 27.2001. Each parent shall have an equal right. to be exercised jointly with the other parent to make all major non-emergency decisions affecting the Childrenos general well-being including. but not limited to, all decisions regarding their healtho education and religion. 2, The parties shall have share_c!Yhys~a] custody of the children on the following schedule: A. Week on/week off with Saturday at 2:00 p.m. being the exchange day and time, Father's week shall begin May 25, 2002. B. The non-custodial parent shall have physical custody of the children on Wednesdays from 4:00 p.m. to 8:00 p.m" except when the custodial parent is on vacation or otherwise out of the area. ~ The exchange of phy~ical custody sh:lH take place \vith the "receiving parent" providing transportation so that the parties have as little contact with each other. 4. schedule: The following holiday schedule shall supercede the regular custody A. Mother shall have physical custody of the children on Mother's Day; Father shall have physical custody of the childrcn on Father's Day. both at 10:00 a.m, to 8:00 p.m. B. The parties shall share the children's birthdays as agreed by the parties, from 8:00 a.m. to 1 :00 p,m. and 1 :00 p.m. to 6:00 p.m. C. The parties shall alternate the Thanksgiving holiday from 10:00 a.m. to 8:00 P,l11, Mother shall have physical custody of the children on Thanksgiving in even numbered years; Father shall have physical custody of the children in odd numbered years. D. Easter Sunday shall be alternated between the parties from 10:00 a.m. to 8:00 p.m. lVlother shall have physical custody of the children in even numbered years; Father shall have physical custody of the children in odd numbered years. E, The Christmas holiday shall be divided into two Blocks, Block A shall be from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. 5, Neither party shall leave the jurisdiction of Pennsylvania without prior notification of the other party, along with the location, address and telephone I1lnnber where the children may be contacted, 6. Neither party shall consume alcoholic beverages to the point of intoxication or illegal drugs while the children are in their physical custody. 7. Neither party shall do an/1hing. nor permit a third pat1y to do anything that may estrange the children from the other pat1y, or injure the opinion of the children as to the other party, or may hamper the free and natural development of the children's love or affection for the other party. 8, The par1ics shall keep each other advised immediately relative to any emergencies, medical or otherwise, concerning the children and shall, further, take any necessary steps to ensure that the health and well being of the children is protected. During such illness or medical emergency, each party shall have the right to visit the children as often as her/she deems consistent with the proper medical care of the childrcn. 9. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Cmlference, The parties may moditY the provisions of this Ordcr by mutual consent. In the absence of mutual consent, the terms of this Order shall control. TRUE COpy FROM RECORD In Teslimol1Y wherecf, I !Yr~ "11<1 set my hand and~h s~a\of sai Coe "'. ""rt yrrlis\o, Pa. 1~i ..../S y .-1'c'J4IJ;' tfJ.2-f " ," ,v .' .{ll j; ;()....' / .. .f.dl/:J<'-........A. , 1 / P ulhonolary cc: Jennifer Heverly, certitied legal intern, Lucy Johnston-Walsh, Esquirc, Family Law Clinic. Counsel for Father Lisa Marie Coyne, Esquire, Counsel for Mother BY l Edward E. Guido, DENNIS E. l\IEYER, Plaintiff ; IN THE COURT OF COMMON PLEAS Of : CUMBERLAND COUNTY, I'ENNSYL\'ANIA v. ; 2001-6505 CIVIL TERM .JANET Mo MEYER, Defendant : CIVIL ACTION - LAW : IN CUSTODY PIUOR JUDGE: Edward Eo Guido, .1. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUl\lHERLAND COlJ/"TY JWLE OF CIVIL J'ROCEDURE 1915.3-8, the undersigned Custody Conciliul<lr submits the following report: l. The pel1inent information concerning the Children who are the subjcct of this litigation is as follows; NAME DATE OF BIRTH CURRENTL Y IN CUSTODY OF Ravcn A. Meyer Melissa N, Meyer Dakota.l, Meyer May 12, 200!l May] 2, 2000 September 27,200 I shared shared shmed 2. A Conciliation Conference was held in this malleI' on May 2l, 2002, with the following individuals in attendance: The Father, Dennis E. t\lcyero with his eOllnsel, Jennifer Hevcrly, certified Icgal intern and Lucy Johnston-Walsh, Esquire, ham the Family Law Clinic and the Mother, Janet Iv1. Meyer, wilh her eOllllsd, Lisa Maric Coyne, Esquire. 3. A prior Order of Court, dilted November 26, 200! was t'lltered by the Honorable Edward E, Guido, providing for shared legal and physical custody on a week on/week ofT basis. PFA Orders, dated Marcil 14,2002 and April 29, 2002, ar~ also in enect by Order oflile Honorable C. Joseph Rehkamp, Perry County, Pennsylvania, restricting Father from contact with Mother cxc~pt !()r Jiseussion aml trunsl<:rs regarding the childrello ^ pctition I()r indir~ct criminal contempt is clllTenlly pellJillg betore tll<' Honorable J. Wesley Oler, .II'. in Ille PFA matter. 4. The parties agreed to the entry 0 I' an Onkr in the form as attached, .s ,. ,). I 'c ;;- Dalc 'J ',( j \ .... .L,-,-~, . ..V'-cL.JtJ.Jl1.~=~",~ /Jac'i?;[lillc M. Vcr'lIey. Esquire 6 (, Custody Cone; liatol' . .' VERIFICATION The foregoing document is based upon information which has been gathered by counsel and myself in the preparation of this action, I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. 05~ e ~J/(_ DENNIS E. MEYER, JR. Date: ~\\ - (1 ~.", 'i,~ : ~ ~ ~ ,::, ~; , , ~ \5'\ o ~. 0' ~ J- <A IJ.l Y o r-' ""? C.) L~I"' C_ ~ ...~- - <:J' (" \ (, ; ..", '> r:-? (fl C) \ o -n ~"" f\ .'F" <t _,,0'\ :b~ {::?~ l<} _._-,-, ",'00" -\1 ;;) ('') ;.5\11 , "r- "'-J :~ ~c/o DENNIS E. MEYER Plaintiff/Petitioner : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2001-6505 CIVIL TERM JANET M. MEYER, DefendantlRespondent IN CUSTODY ORDER OF COURT AND NOW, this day of , 2005, upon consideration of the attached Petition for Modification, it is hereby directed that the parties and their respective counsel appear before Esquire, the conciliator, at on the day of , 2005 at . Mo 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. All children age five or older may also be present at the conference. Failure to appear at this conference may provide grounds for entry of a temporary or permanent order. By the Court, By: Custody Conciliator YOU SHOULD TAKE TillS 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 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 scheduling conference or hearingo DENNIS E. MEYER PlaintifflPetitioner : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2001-6505 CIVIL TERM (') c c~ c, r-> coo C::::;) "" <- c- -- .~ PETITION FOR MODIFICATION OF CUSTODY C) , ;:: -1 -<. N <11 o ~ '... ::J:..." rnp "CT1 -.,./0 I:) \) ....,C r .'T; ',.:,1 ~""~(~ .'C:; rn \-) ".:.:~l 'D '< JANET M. MEYER, DefendantIRespondent IN CUSTODY ifl ~ , -{, 0' ..." AND NOW comes the Petitioner, Dennis E. Meyer, Jr., by his attorneys, Irwin & McKnight, and presents the following Petition for Modification of Custody. 1. The Petitioner, Dennis Eo Meyer, Jr., is an adult individual with an address of7073 Carlisle Pike, Lot 132, Carlisle, Pennsylvania 17013. 2. The Respondent, Janet Mo (Meyer) Martyn, 7073 Carlisle Pike, Lot 112, Carlisle, Pennsylvania, 17013. 3. The parties are the natural parents of three (3) children, namely Raven A. Meyer and Melissa N. Meyer, born May 12, 2000, and Dakota Jo Meyer, born September 27, 2001. 4. The Petitioner desires that the parties have shared legal custody of said minor children. 5. The Petitioner desires primary physical custody of said minor children, with periods of temporary physical custody to Respondent as the parties agree is in the best interest of said children. 60 The best interests and permanent welfare of the minor children requires that the Court grant the Petitioner's request as set forth above. WHEREFORE, Petitioner, Dennis Eo Meyer, Jr., respectfully requests that he be awarded primary physical custody and shared legal custody of Raven A. Meyer, Melissa N. Meyer, and Dakota Jo Meyer, as provided herein, with periods of temporary physical custody to Respondent as provided hereino By: Marcu Attorne for Plaintiff 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court 1. D. No. 25476 Date: June 16,2005 EXHIBIT "A" r,l.A v " :~ "'nq.c " '-' ~,! <! I.' j ./ DENNIS E. MEYER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA Yo : NOo 2001-6505 CIVIL TERM .JANET M. MEYER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT tI" AND NOW, this d~ day of ~ "0'_______.2002. upon <:onsidermion of the attached Custody Conciliation Repon, it is ordered and directed as tallows: 1. The Father. Dennis E. Meyer, and the Mother. Janet IV!. Meyer, shall have sharejJ~gal custody of Raven A, Meyer and IvIclissa N, Meyer. born 1\1ay 12.2000 and Dakota J. Meyer, born September 27. 2001. 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 dccisions regarding their health, education and religion. 2. The parties shall have shared physical custody of the children on the tdlowing schedule: - - A. Week on/week off with Saturday at2:00 p,m, being the exchange day and time, Father's week shall begin May 25,2002. B. The non-custodial parent shall have physical custody of the children on Wednesdays frol114:00 p.m, to 8:00 p,m., except when the custodial parent is on vacation or otherwise out of the area. ,., The exchange of physical custody sh:1!l take phce \vith the '''receh'ing parent" providing transportation so that the parties have as little contact with each other. 4. schedule: The following holiday schedule shall supercede the regular custody A Mother shall have physical custody of the children olll\1other's Day; Father shall have physical custody of the children on Father's Day. both at 10:00 a,m, to 8:00 p.m. B. The parties shall share the children' s birthdays as agreed by the parties. from 8:00 a,m, to 1 :00 p,m, and 1 :00 p.m, to 6:00 p.m. C. The parties shall alternate the Thanksgiving holiday from 10:00 a.m. to 8:00 p.lTI, Mother shall have physical custody of the children on Thanksgiving in even numbered years; Father shall have physical custody of the children in odd numbered years. D. Easter Sunday shall be alternated between the paliies from 10:00 a.m. to 8:00 p,m. Mother shall have physical custody of the children in even numbered years; Father shall have physical custody of the children in odd numbered years. E, The Christmas holiday shall be divided into two Blocks. Block A shall be from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years, Father shall have Block A in even numbered years and Block B in odd numbered years. 5. Neither party shall !eave the jurisdiction of Pennsylvania without prior notification of the other party, along with the location. address and telephone number where the children may be contacted, 6, Neither party shall cons lime alcoholic beverages to the point of intoxication or illegal drugs while the children are in their physical custody, 7, Neither party shall do anything. nor pennit a third patty to do anything that may estrange the children from the other patty. or injure the opinion of the children as to the other party, or may hamper the free and natural development of the children's love or affection for the other party, 8, The pmties shall keep each other advised immediately relative to any emergencies, medical or otherwise, concerning the children and shall, further, take any n~cessary steps to ensure that the health and well being of the children is protected. During such illness or medical emergency, each party shall have the right to visit the children as often as her/she deems consistent with the proper medical care ofth~ children. 9. This Order is entered pursuant to an agreement of the parties at a Custody C)!1ci!!atio!1 Confhenee. The parties may modi(v the provisions of this Order by mutual consent. In the absence of mutual consent the terms of this Order shall controL TRUE COpy FROM RECORD In Testimony whcr&pf, I iFr', t:nr~ set my hand an~ t~) s1110f 50i[...1. oc .."~. "{,tYjld'), ;;' 7.2- Th! ?J y .... .... A),;j, f4f ",......,......, ~- "IJ.^,~ . " (/'12' . ,..., , "l'n'. ,l,~" , / .~ .1.i.. .!.J:.~.... ..~-..."'" - ." 1 P "thonotary cc: J':nnifcr Heverly, certified legal intern, Lucy Johnston- Walsh, Esquire, Family Law Clinic, Counsel for Father Lisa Marie Coyne, Esquire, Counsel for Mother BY J. Edward E. Guido, . ' . . DENNIS E. MEYER, Plaintiff : IN THE COURT OF COMl\WN PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : 2001-6505 CIVIL TERM JANET M. MEYER, Defendant : CIVIL ACTION., LAW : IN CUSTODY PHIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND CO Ui"TY HULk; OF CIVIL j'HOCEDURE 19\5.3-8, the undersigned Custody Conciliator submits the following report: l. The pertinent information eonccrning the Childn::n who arc thc subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTL Y IN CUSTODY OF Ravcn A. Meyer Melissa N. Meycr Dakota J. Meyer May 12, 200{) May 12, 2000 Septembcr 27, 2()O! shared shared sharcd 2, A Conciliation Conference was held in this mattcr on IVlay 21. 2002, with the following indiviuua1s in attcndance: The Father, Dennis E. fl.kyer, with his counsel. .knnifcr Hevcrly, ccrtiijeu legal intern anu Lucy Johnston-Walsh, [squire, li"om thc Family Law Clinic anu the Mother, Janet 1\.1. Meyer, with her counsel. Lisa Maric Coyne. Esquire. 3. A prior Order of Court. dated November 26, 200lwas t'Iltcn:d by Ille Honorable Edward E. Guido, providing for shured kgal and physical custody on a week on/week off basis, PFA Orders, dated March 14,2002 and April 29, 2002, are also in clTcct by Orucr orthe Honorable C. Joscph Rehkamp, Perry County, Pennsylvania, restricting Father rrom contact with Mother l'xcept lor discussion and transfers I\'garding the: childrcn. A pctition l(lI' indirect criminal contempt is ellrrcntly penJing betl)!"c the' Ilonorable J. Wesley Olel', Jr. in the PFA mattero 4. The parties agreeu to the entry oC an Order in the form as attached. ,r; . ,). I '(1 2~ Date ('..b~/f~~""'C'~~~'~~~-- j.lacl(\fl'"lille M, Vcrncyo Esquire 6 Custody Concilialor ~ VERIFICATION The foregoing document is based upon information which has been gathered by counsel and myself in the preparation of this action. 1 have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to nnswom falsification to authorities. c/I~ e JJ7J~J(<-, DENNIS E. MEYER, JR. Date: DENNIS E. MEYER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 01-6505 CIVIL ACTION LA W JANET M. MEYER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, June 23, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esqo , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, July 14, 2005 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. 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 priow to scheduled hearing. FOR THE COURT, By: Isl Tacqueline M Verney, Esq. Custody Conciliator ,JV The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990, For infonnation 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 SIred Carlisle, Pennsylvania 17013 Telephone (717) 249-3 166 _~ ';>~~;<71r ~ ~~ . l' ~z;$'."'i'Ii'"7 ~ 5tJ E:e,"J ..;:J:p ?-- ~ ~k, .>0- n::,1 ~;JW ~ 1- ~ ~'r9 5tJ. f:c:" . "l ZS :S Hd 82 Nflf'SOOl /o.io:J'ilO;YJi t..G8d 3Hl :JO 381:!:IC'rmll:l DENNIS E. MEYER, Plaintiff \JDV : t [0(15 BYH&.... ' --'..cd_~~~_c==" : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2001-6505 CIVIL TERM JANET M. MEYER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 16th day of November, 2005, having continued this matter for more than 90 days and no request to schedule a conciliation conference having been received, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, ( . tL-v-< / ine M. Verney, Esquire, CuJody Conciliator S I :Z He! L ~ ("\" 1 ,..,!' ';',..., hUn :rtJUr... },>-:",;,i", ,u~.:...'... ::C:U.. \/,',1 ~JHl ~}CI~i-!H :10