HomeMy WebLinkAbout08-6219Kristin E. Keefer,
Plaintiff/ Petitioner
V.
Ryan Sheffield,
Defendant/ Respondent
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION -LAW
IN CUSTODY
No. 08- ?0/ ?' CIVIL TERM
COMPLAINT FOR CUSTODY
The plaintiff, Kristin E. Keefer, by her attorneys, the Family Law Clinic, sets forth the
following cause of action in custody.
1. The Plaintiff is Kristin E. Keefer, residing at 3101 Spring Road, Carlisle, Cumberland
County, Pennsylvania 17013.
2. The Defendant is Ryan Sheffield, residing at, 2207 Walnut Bottom Road, Carlisle,
Cumberland County, Pennsylvania 17105.
3. Plaintiff seeks primary custody of the minor children, Keiria Destiny Sheffield, born
May 30, 2006, and Jersey Louise Sheffield, born July 1, 2008.
The children were born out of wedlock.
The children are presently in the custody of Defendant, who resides at 2207 Walnut
Bottom Road, Carlisle, Cumberland County, Pennsylvania 17105.
During the past five years the children have resided with the following persons at the
following addresses:
Persons Address Dates
Jersey Sheffield:
Ryan Sheffield 2207 Walnut Bottom Rd. 10/17/08 - present
Andre Rodriguez III Carlisle, PA 17015
Edwina Rodriguez
Connie Hutchinson
Ed Hutchinson
Kristin Keefer 3101 Spring Road 9/08 -10/17/08
Norman Keefer Carlisle, PA 17013
Kristin Keefer 47 Walnut Street birth - 9/08
Ryan Sheffield Carlisle, PA 17013
Dawn Hutchinson
Kevin Hutchinson
Jeremy Hutchinson
Kevin Hutchinson, Jr.
Keiria Sheffield:
Ryan Sheffield 2207 Walnut Bottom Rd. 10/17/08 - present
Andre Rodriguez III Carlisle, PA 17015
Edwina Rodriguez
Connie Hutchinson
Ed Hutchinson
Kristin Keefer 3101 Spring Road 9/08 - 10/17/08
Norman Keefer Carlisle, PA
Kristin Keefer 47 Walnut Street May 2008 - present
Ryan Sheffield Carlisle, PA
Dawn Hutchinson
Kevin Hutchinson
Jeremy Hutchinson
Kevin Hutchinson, Jr.
Kristin Keefer 18 Tiptop Circle Sept. 2006 - May 2008
Ryan Sheffield Carlisle, PA
Kristin Keefer 414 E. Main Street birth - Sept. 2006
Ryan Sheffield Shermanstown, PA
Karen Sheffield (aunt)
The mother of the children is Kristin E. Keefer.
She is single.
The father of the children is Ryan Sheffield.
He is single.
4. The relationship of Plaintiff to the child is that of mother. Plaintiff currently resides
with the following persons:
Name
Norman Keefer
Relationship
Father
5. The relationship of Defendant to the child is that of father. Defendant currently resides
with the following persons:
Name
Andre Rodriguez III
Edwina Rodriguez
Relationship
Mother's uncle
Mother's aunt
Connie Hutchinson
Ed Hutchinson
Mother's grandmother
Mother's grandfather
6. Plaintiff has not participated as a party or witness, or in another capacity, in other
litigation concerning the custody of the children in this or another court.
Plaintiff has no information of a custody proceeding concerning the children pending in
a court of this Commonwealth, or any other state.
Plaintiff does not know of a person not a party to the proceedings who has physical
custody of the children or claims to have custody or visitation rights with respect to the
children.
7. The best interest and permanent welfare of the children will be served by granting the
relief requested because:
a. Plaintiff has been the children's primary caretaker for all of the children's lives;
b. Plaintiff provides the children with a stable home and environment with
adequate moral, emotional, and physical surroundings as required to meet the
children's needs;
c. Plaintiff has permitted contact between Defendant and the children and will
continue to do so;
d. Plaintiff is willing to accept custody of the children.
e. The safety of the children is at risk while in Defendant's care.
Each parent whose parental rights to the children have not been terminated and the
person who has physical custody to the children have been named as parties to this
action.
WHEREFORE, Plaintiff requests the court to grant her shared legal custody and
primary physical custody of the children, with the Defendant having periods of partial
custody.
Respectfully submitted,
Date: 10/20/
cqu ine Collette
Certified Legal Intern
THOM S M. PLACE
ROBERT E. RAINS
LUCY JOHNSTON-WALSH
ANNE MACDONALD-FOX
MEGAN RIESMEYER
Supervising Attorneys
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
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.C.S. § 4904 relating to
unsworn falsification to authorities.
Date Kristin E. Keefer
c
.
? J
Kristin E. Keefer,
Plaintiff/ Petitioner
V.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
: PENNSYLVANIA
CIVIL ACTION -LAW
IN CUSTODY
Ryan Sheffield,
Defendant/ Respondent No. CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
TO THE PROTHONOTARY:
Kindly allow Kristin E. Keefer, Plaintiff, to proceed in forma pauperis.
The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies
that we believe the party is unable to pay the costs and that we are providing free legal service to
the party.
Respectfully submitted,
Date 10/Z?>Zp?
S cqu in?l e Collette
Certified Legal Intern
ROBE T E. RAINS
THOMAS M. PLACE
ANNE MACDONALD-FOX
MEGAN RIESMEYER
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
C':)
c?°
,=
_
_ ? " 1-f
'r•y „v +
d
_ Pin-,.,?
?q j -._
", f"'?
l.o>
"_' `
?
'
f is w?
„?.
Kristin E. Keefer,
Plaintiff/ Petitioner
V.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION -LAW
IN CUSTODY
Ryan Sheffield,
Defendant/ Respondent No. 08- CIVIL TERM
PETITION FOR SPECIAL RELIEF SEEKING EMERGENCY CUSTODY
PURSUANT TO PA R.C.P. 1915.13
AND NOW, this 20th day of October, 2008, pursuant to Rule 1915.13 of the
Pennsylvania Rules of Civil Procedure, comes the Petitioner, Kristin Keefer, by her
attorneys, the Family Law Clinic, seeking emergency custody of the minor children,
Keiria Destiny Sheffield, born May 30, 2006, and Jersey Louise Sheffield, born July 1,
2008. In support of her Petition for Emergency Relief, Petitioner avers the following:
1. The petitioner is Kristin E. Keefer (Mother), an adult individual who resides at
3101 Spring Road, Carlisle, Cumberland County, PA 17013.
2. The respondent is Ryan Sheffield (Father), an adult individual who resides at
2207 Walnut Bottom Road, Carlisle, Cumberland County, PA 17015.
3. The petitioner is the biological mother of the children, Keiria Destiny Sheffield,
born May 30, 2006, and Jersey Louise Sheffield, born July 1, 2008 (Children).
4. The respondent is the biological father of the children.
5. The children were born out of wedlock.
6. Children have resided with Mother their entire lives.
7. Mother has been the primary caretaker of the children since birth.
8. The parties resided together until on or around September 1, 2008.
9. Following their separation on or around September 1, 2008, the children remained
with mother until October 17, 2008.
10. On Friday, October 17, 2008, Mother offered to allow Father to have the
Children overnight on the condition that Father would return the Children on the
evening of Sunday, October 19, 2008.
11. On Friday, October 17, 2008, Father telephoned Mother and informed her that he
would not return the Children at all.
12. Father has refused to allow Mother to see Children.
13. Father is not acting in the Children's best interests for reasons including, but not
limited to, the following:
a. The child, Keiria, requires insulin shots for her diabetes four times a day.
Father does not have the medicine or the needles required for the insulin
shots. Mother sent only enough insulin and needles for two days worth of
shots when she sent Keiria for the weekend visit on Friday, October 17,
2008.
b. The child, Jersey, uses a breathing machine three times a day. While
Father has the breathing machine, he does not have the medicine to be
used with the breathing machine. Mother sent only enough medicine for
two days worth of breathing treatments when she sent Jersey for the
weekend visit on Friday, October 17, 2008.
c. Father cannot obtain additional medicine because Mother has the
insurance cards and the refill information. Mother contacted the
Children's doctor and learned that Father has not contacted the doctor in
an effort to obtain additional medicine for the children.
d. Mother believes father does not have the diapers or formula required for
the care of the three-month-old child, Jersey. Mother also believes father
does not have the financial resources to buy these necessities.
e. Mother believes Father is living with Andre Rodriguez III. Mother
believes that Andre Rodriguez III is a registered sex offender.
14. Mother is filing a Complaint for Custody contemporaneously with this Petition
for Special Relief.
15. Mother believes and therefore avers that it is in the best interests of the Children
that Mother be granted shared legal and temporary primary physical custody of
the children, pending further Order of Court.
WHEREFORE, the petitioner, Kristin E. Keefer, respectfully requests that this
Honorable Court restore the status quo by entering an Order granting Petitioner shared
legal and temporary primary physical custody of the Children, Keiria Destiny Sheffield
and Jersey Louise Sheffield, by ordering Respondent to return the Children immediately
to Petitioner and by scheduling this matter for hearing or conciliation.
Respectfully submitted,
10/2- 0 /09 0% . , o Al (? D? -Q
Date iquAine Collette
Certified Legal Intern
?C.11
ROBE E. RAINS
THOMAS M. PLACE
ANNE MACDONALD-FOX
MEGAN RIESMEYER
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013-2899
(717) 243-2968
Fax: (717) 243-3639
VERIFICATION
I verify that the statements made in the foregoing Petition for Special Relief
Seeking Emergency Custody are true and correct, to the best of my knowledge,
information and belief. I understand making any false statement would subject me to the
penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities.
Date: lb G ?J Agj?fvyl
Kristin E. Keefer4Peti er
°? ?=? ??'
r"'
< .s '1
?
t
?; . ?rt
r._
"C? ??.,
1?."?
«?; ?
°"?
? `,:+
.?
:;
?,
?_.?
,.c` -M.f _
--G
OCT 2 0 2008
Kristin E. Keefer,
Plaintiff/ Petitioner
V.
Ryan Sheffield,
Defendant/ Respondent
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION -LAW
IN CUSTODY
: No. fry/' CIVIL TERM
ORDER OF COURT
AND NOW this` o?daY of , 2008, upon consideration of the attached
? ?
Petition for Special Relief, it is hereby Ordered as follows:
1. The petitioner, Kristin E. Keefer, shall have temporary legal and primary physical
custody of her minor children, Keiria Destiny Sheffield, born May 30, 2006, and
Jersey Louise Sheffield, born July 1, 2008, pending further Order of Court.
2. The respondent, Ryan Sheffield, shall immediately return Keiria Destiny
Sheffield and Jersey Louise Sheffield to petitioner's care and custody.
3. The respondent, Ryan Sheffield, shall not remove Keiria Destiny Sheffield and
Jersey Louise Sheffield from the jurisdiction of this Court pending further order
of this Court.
4. This matter shall be scheduled for a hearing on the M day of
2008
oo p rh. ?
, gyc;
.3
`v
Sr
a r,_ cis
u iC'
cv ?
4
Kristin E. Keefer, IN THE COURT OF COMMON PLEAS
Plaintiff/ Petitioner OF CUMBERLAND COUNTY,
PENNSYLVANIA
V. CIVIL ACTION -LAW
IN CUSTODY
Ryan Sheffield,
Defendant/ Respondent No. 08-6219 CIVIL TERM
AFFIDAVIT OF SERVICE
I, Linda Carver, hereby certify that I personally served a true and correct copy of the Order
of Court regarding the Emergency Petition for Custody, on Ryan Sheffield at 2207 Walnut Bottom
Rd., Carlisle, PA 17013 at 12:00 p.m. on October 21, 2008.
I verify that the statements made in this Affidavit of Service are true and correct to the best
of my personal knowledge and belief. I understand that false statements herein are made subject to
the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities.
Date: A IA-A4"'
Linda C er
c"I
rr.
`
C1
t
I
t
KRISTIN E. KEEFER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. 2008-6219 CIVIL ACTION LAW
RYAN SHEFFIELD
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, Thursday, October 23, 2008 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, November 04, 2008 at 1:00 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. 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/ John J, Mangan, r , Esq. /.) P?
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
plow
or ?Pme 4w
V IlNVAI),SNN -'d
C Z .c Wd hz 130 BUZ
?Wj( )jo , d 3Hi d0
gip.,-e al
Kristin E. Keefer, IN THE COURT OF COMMON PLEAS
Plaintiff/ Petitioner OF CUMBERLAND COUNTY,
PENNSYLVANIA
V. CIVIL ACTION -LAW
IN CUSTODY
Ryan Sheffield,
Defendant/ Respondent No. 08-6219 CIVIL TERM
CERTIFICATE OF SERVICE
I, Jacqueline Collette, Certified Legal Intern, Family Law Clinic, hereby certify that I
served a true and correct copy of the Complaint for Custody, Petition for Special Relief Seeking
Emergency Custody and Order of Court on Ryan Sheffield, residing at 2207 Walnut Bottom Rd.,
Carlisle, PA 17015, by depositing a copy of the same in the United States first class mail,
postage prepaid.
Date: j0f 27 / O S Qa r a o Q o (Wo 0
cque ne Collette
Certified Legal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
.-,
,?
=- ?
;??
? F-r
.r_i ;?-?
? t{?
?
r?
. L?.
: °a 1
-T,r
:r,=?
f> _i
_? ?---,
y
r .,
NOV 2 4 20084
KRISTIN ]KEEFER,
Plaintiff
V.
RYAN SHEFFIELD,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2008-6219 CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this )--? 1? day of 1 v , 2008, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
The prior Order of Court dated October 20, 2008 shall remain in full force and
effect, unless the parties agree to modify it by mutual consent.
cc: Katie Maxwell, Esquire, Counsel for Mother' 'nt4"
Grace D'Alo, Esquire, Mid Penn Legal Services, Counsel for Father
"X7 T7 TT llnT T"l r
?s,; oc
r
KRISTIN KEEFER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2008-6219 CIVIL ACTION - LAW
RYAN SHEFFIELD,
Defendant : IN CUSTODY
PRIOR JUDGE: J. Wesley Oler, Jr., 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
Keiria Destiny Sheffield May 30, 2006 Mother
Jersey Louise Sheffield July 1, 2008 Mother
2. A Conciliation Conference was held in this matter on November 24, 2008,
with the following in attendance: The Mother, Kristin Keefer, with her counsel, Katie
Maxwell, Esquire, and the Father, Ryan Sheffield, who indicated that he was represented
by Grace D'Alo, Esquire, Mid Penn Legal Services, but she was unable to attend.
;. A prior Order of Court was entered by the Honorable J. Wesley Oler, Jr.,
dated October 20, 2008 providing for Father to return the children to Mother and
scheduling a hearing for December 9, 2008.
4. In light of the pending hearing and the fact that the parties could not agree
to any custody order, the Conciliator recommends the attached Order.
1(-a? -off
Date
-lacoeline M. Verney, Esquir
Custody Conciliator
Kristin E. Keefer,
Plaintiff/ Petitioner
V.
Ryan Sheffield,
Defendant/ Respondent
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION -LAW
IN CUSTODY
: No. 08-6219 CIVIL TERM
CERTIFICATE OF SERVICE
I, Jacqueline Collette, Certified Legal Intern, Family Law Clinic, hereby certify that I
served a true and correct copy of the Custody Conciliation Order on Ryan Sheffield, residing at
2207 Walnut Bottom Road, Carlisle, PA 17015, by depositing a copy of the same in the United
States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was
complete upon receipt by Ryan Sheffield, on the 24th day of November 2008 as evidenced by the
attached green card.
N N
O)
w
ao
0
Ln
0
N W
`0
0
0
0
C3
W
0
o,
W
0
W
M
03
g
i
%cqu&ne Collette
Certified Legal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
,?..:?
.--< y ,
r
..--e s 11
? s
Kristin E. Keefer,
Plaintiff/ Petitioner
V.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION -LAW
IN CUSTODY
Ryan Sheffield,
Defendant/ Respondent No. 08-6219 CIVIL TERM
WITHDRAWAL AND ENTRY OF APPEARANCE
TO THE PROTHONOTARY OF SAID COURT:
PLEASE withdraw my appearance as attorney of record for the Petitioner, Kristin
E. Keefer, at the above captioned docket.
Dated: 12- /ok / oA
Respectfully submitted by:
r r& a Oa av. Q - COQ ?I-t-p
ac quei ie Collette
Certified Legal Intern
la %?L
ROB RAT RAINS
THOMAS M. PLACE
ANNE MACDONALD-FOX
MEGAN RIESMEYER
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
Fax: 717-243-3639
PLEASE enter my appearance as attorney of record on behalf of the Petitioner,
Kristin E. Keefer, at the above captioned docket.
Dated:
Respectfully submitted by:
Katie J. well, Esq.
Martso aw Offices
10 E. High Street
Carlisle, PA 17013
?
?"? ° -'
r-- ?
..,?
-. `?
- t7 -,? --?
?
?' ?;, ?-
_;
? _
;L.?
N
- ? { t
?
i
«:».x
??1 Z
^
:
?
.
KRISTEN E. KEEFER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 08-6219 CIVIL TERM
RYAN SHEFFIELD, : CIVIL ACTION - LAW
Defendant/Respondent : IN CUSTODY
PRAECIPE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please withdraw the Petition for Special Relief Seeking Emergency Custody which was
scheduled a hearing before Judge J. Wesley Oler on December 9, 2008, at 3:30 p.m.
MARTSON LAW OFFICES
Date: `cam/ 06
By
Kafie J. Ma D 11, Esquire
Attorney I. D. -'
No. 206018
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff/Petitioner
{
? • t
CERTIFICATE OF SERVICE
I, Mary M. Price, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller,
hereby certify that a copy of the foregoing Petition for Appeal was served this date by facsimile,
addressed as follows:
Grace D'Alo, Esquire
MidPenn Legal Services
VIA FACSIMILE: 243-8026
MARTSON LAW OFFICES
By L&? V?,
M. Price
n East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: g lqlgJI"
G
{
y n
co
l
KRISTEN E. KEEFER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 08-6219 CIVIL TERM
RYAN SHEFFIELD, : CIVIL ACTION - LAW
Defendant/Respondent : IN CUSTODY
PRAECIPE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please make the attached Certificate of Service part of the Praecipe to withdraw the Petition
for Special Relief Seeking Emergency Custody which was filed today.
MARTSON LAW OFFICES
By /&
Katie J. M 11, Esquire
Attorney I. ft o. 206018
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff/Petitioner
? ?
Date: / 2 C
CERTIFICATE OF SERVICE
I, Mary M. Price, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller,
hereby certify that a copy of the foregoing Praecipe was served this date via facsimile as follows:
Grace D'Alo, Esquire
MidPenn Legal Services
VIA FACSIMILE: 243-8026
MARTSON LAW OFFICES
By
Nnry M. Price
n East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: 1-1/01/,10
?{ payy
KRISTEN E. KEEFER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
RYAN SHEFFIELD,
Defendant NO. 08-6219 CIVIL TERM
IN RE: PETITION FOR SPECIAL RELIEF
SEEKING EMERGENCY CUSTODY
ORDER OF COURT
AND NOW, this 9`" day of December, 2008, upon consideration of the Praecipe
filed in the above matter on December 9, 2008, to withdrawn the above motion, the
hearing previously scheduled for December 9, 2008, is cancelled.
BY THE COURT,
Katie J. Maxwell, Esq.
10 East High Street
Carlisle, PA 17013
Attorney for Plaintiff
? Grace D'Alo, Esq.
MidPenn Legal Services
401 East Louther Street
Carlisle, PA 17013
Attorney for Defendant
:rc
12of tbzcL
to/g/dg
?:?7
1 ? rr f Ir
Wesley Ol' r, Jr., J.
a 4 :1 Wd 6- 330 01
DEC 19
KRISTIN KEEFER,
Plaintiff
V.
RYAN SHEFFIELD,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2008-6219
CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this day of De c , 2008, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
The prior Orders of Court dated November 25, 2008 and October 20, 2008
are hereby vacated.
2. The Mother, Kristin Keefer and the Father, Ryan Sheffield, shall have
shared legal custody of Keiria Destiny Sheffield, born May 30, 2006 and Jersey Louise
Sheffield, born July 1, 2008. 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. Pursuant to the terms of 23 Pa.C.S. §5309, each parent
shall be entitled to all records and information pertaining to the children including, but
not limited to medical, dental, religious or school records, the residence address of the
children 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 children. 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.
Mother shall have primary physical custody of the children.
4. Father shall have the following periods of supervised visitation and partial
physical custody:
A. Supervised visitation for 1 hour on December 23, 2008 and December
30, 2008 at Children & Youth Services at a time agreed to by C&Y.
20M er
i Ii :01 '-I ? 3uO Fgcl ili IV rS4E i ? ? ? Jt.:
B. Assuming Father has appropriate supervised visitations with the
children as aforesaid, he shall have periods of partial physical custody
on Saturday, January 3, 2009 and January 10, 2009 from 10:00 a.m. to
6:00 p.m.
Both parties shall voluntarily cooperate and follow any recommendations
of C&Y.
6. Mother shall be responsible for all transportation for Father's Saturday
visits.
7. 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 January 16, 2009 at 1:30 p.m.
BY THE COURT,
Oler, Jr., C) " J
cc'K ' Maxwell, Esquire, Counsel for Mother
race D'Alo, Esquire, Mid Penn Legal Services, Counsel for Father
S
? C ??,?
l ('! e ??
-, :-?
? ?}
KRISTIN KEEFER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2008-6219 CIVIL ACTION - LAW
RYAN SHEFFIELD,
Defendant : IN CUSTODY
PRIOR JUDGE: J. Wesley OLer, Jr.
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
Keiria Destiny Sheffield May 30, 2006 Mother
Jersey Louise Sheffield July 1, 2008 Mother
2. A Conciliation Conference was held in this matter on December 18, 2008,
with the following in attendance: The Mother, Kristin Keefer, with her counsel, Katie
Maxwell, Esquire, and the Father, Ryan Sheffield, with his counsel, Grace D'Alo,
Esquire, Mid Penn Legal Services.
3. Prior Orders of Court were entered by the Honorable J. Wesley Oler, Jr.
dated November 25, 2008 and October 20, 2008 providing for Mother to have temporary
legal and primary physical custody of the children.
4. The parties agreed to an Order in the form as attached.
/1-6
-41-6y -
Date
acq line M. Verney, Esquire
Custody Conciliator
JAN ? R 2009 (rKRISTIN KEEFER,
Plaintiff
V.
RYAN SHEFFIELD,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2008-6219
: IN CUSTODY
ORDER OF COURT
CIVIL ACTION - LAW
Zoa?
AND NOW, this day of W7. , 299$; upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The prior Order of Court dated December 24, 2008 shall remain in full
force and effect with the following modifications:
2. Father shall have the following periods of partial physical custody :
A. Beginning Saturday, January 24, 2009, every Saturday from 10:00
a.m. to 6:00 p.m. with Keiria.
B. Beginning Sunday, January 25, 2009, every Sunday from 10:00 a.m. to
6:00 p.m. with Jersey.
C. Beginning Wednesday, February 4, 2009 every Wednesday from 1:00
p.m. to 4:00 p.m. with Keiria.
3. Neither party may partake in alcoholic beverages to the point of
intoxication or illegal drugs immediately before or during their periods of physical
custody.
4. 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. A
telephone conference is scheduled for February 23, 2009 at 9:30 a.m.
BY THE COURT,
cc:?catie Maxwell, Esquire, Counsel for 40ther
./Grace D'Alo, Esquire, Abraham Prozes_ky, Esquire,
Counsel for Father
c,T,-es a,LL
I j.2-9/0?
tz;l
Mid Penn Legal Services,
.9 _ ° U4 NVr 60OZ
? 1,
KRISTIN KEEFER,
Plaintiff
V.
RYAN SHEFFIELD,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2008-6219 CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: J. Wesley OLer, Jr.
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
Keiria Destiny Sheffield May 30, 2006 Mother
Jersey Louise Sheffield July 1, 2008 Mother
2. A Conciliation Conference was held in this matter on January 23, 2009,
with the following in attendance: The Mother, Kristin Keefer, with her counsel, Katie
Maxwell, Esquire, and the Father, Ryan Sheffield, with his counsel, Grace D'Alo,
Esquire, and Abraham Prozesky, Esquire, Mid Penn Legal Services.
3. The Honorable J. Wesley Oler, Jr. entered a prior Order of Court dated
December 24, 2008 providing for shared legal custody, Mother having primary physical
custody of the children, and Father having periods of partial physical custody.
4. The parties agreed to an Order in the form as attached.
Date Jac eline M. Verney, Esquire
Custody Conciliator
/'
KRISTIN KEEFER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2008-6219 CIVIL ACTION - LAW
RYAN SHEFFIELD,
Defendant : IN CUSTODY
ORDER OF COURT cm =-{
+
rn
:z m -n
M
rn;=-
?. co
AND NOW, this 23`d day of February, 2011, being advised that this
rri i Cr
s
--? c?
<
being handled in dependency court, the Conciliator hereby relinquishes jurisdi
i
rL ;
this matter
. FOR THE COURT,
ac eline M. Verney, Esquire, stody Conciliator