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Home My WebLink About08-6751Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 HEATHER L. SCHREINER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. O G S/ BRIAN S. SCHREINER, CIVIL ACTION -LAW Defendant IN CUSTODY CUSTODY COMPLAINT 1. The Plaintiff is Heather L. Schreiner (hereinafter referred to as "Mother"), who currently resides at 1005 Chelmsford Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant is Brian S. Schreiner (hereinafter referred to as "Father"), who currently resides at 480 Big Spring Road, New Cumberland, York County, Pennsylvania 17070. 3. Plaintiff seeks an order of shared legal and primary physical custody of the following child: NAME PRESENT RESIDENCE DATE OF BIRTH Reyna Lynn Schreiner 1005 Chelmsford Drive February 21, 2006 Mechanicsburg, PA 17050 4. The child is presently in the custody of Mother who is currently residing at 1005 Chelmsford Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 5. During the past five years the child has resided with the following persons at the following addresses: DATES 2/21/2006 to 6/ 1 /2007 6/ 1 /2007 to 7/l/2008 7/ 1 /2008 to Present ADDRESSES 3507 Countryside Lane Camp Hill, PA 17011 363 Stonehedge Lane Mechanicsburg, PA 17055 1005 Chelmsford Drive Mechanicsburg, PA 17050 NAMES OFPERSONS IN HOUSEHOLD Father, Mother, Trent Golden (sibling) Mother, Trent Golden (sibling) Mother, Trent Golden (sibling) 6. The Father of the child is Brian S. Schreiner, currently residing at 480 Big Spring Road, New Cumberland, York County, Pennsylvania 17070. 7. The Mother of the child is Heather L. Schreiner, currently residing at 1005 Chelmsford Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. The parties are currently married but are separated. 8. The relationship of the Plaintiff to that of the child is that of Mother. The Plaintiff currently resides with the following persons: NAME Reyna Lynn Schreiner Trent Golden RELATIONSHIP Daughter Son 2 U 9. The relationship of the Defendant to the child is Father. The Defendant currently resides with the following persons: NAME Frank J. Schreiner Susan N. Schreiner RELATIONSHIP Father Mother 10. 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. 11. The Plaintiff has no information of a custody proceeding concerning the child pending in any court of this Commonwealth. 12 Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 13 The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff can best provide a stable, loving environment for her child. The child is bonded to her Mother. Mother can facilitate a relationship between the child and Father. 14. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child have been named as parties to this action. 3 WHEREFORE, the Plaintiff requests the Court to grant shared legal and primary physical custody of the child to the Plaintiff. Dated: November 7, 2008 Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 4 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 HEATHER L. SCHREINER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. BRIAN S. SCHREINER, Defendant . NO. CIVIL ACTION -LAW IN CUSTODY VERIFICATION I, HEATHER L. SCHREINER, hereby certify that the facts set forth in the foregoing CUSTODY COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. D Dated: a , 2008 rffil? 0 LA E THER L. S MER V 9 ? ° !U W (R ? ca p O 4 HEATHER L. SCHREINER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. BRIAN S. SCHREINER DEFENDANT 2008-6751 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, November 19, 2008 _,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, December 17, 2008 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to 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/ Dawn S. Sunda 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 VINVA-tAS N'3d X1.4 N MY", 7 N-e-" PiNnJ CO d I NV 61 AON SOOZ Mtf it WRL d Ni 30 90LJRO" d T Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 HEATHER L. SCHREINER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. BRIAN S. SCHREINER, Defendant : NO. 08-6751 CIVIL ACTION -LAW IN CUSTODY AFFIDAVIT OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served a copy of the Custody Complaint and Order of Court scheduling the Custody Conciliation for Wednesday, December 17, 2008 at 8:30 a.m. in the above-captioned matter by United States Mail, Restricted Delivery, Certified No. 7008 0150 0002 5289 7507, Return Receipt Requested, on Mr. Brian S. Schreiner, on November 21, 2008 at his last known address: 480 Big Spring Road, New Cumberland, Pennsylvania 17070. The Complaints in Custody and Divorce were served in the same parcel. The original receipt and return receipt card is attached to the Affidavit of Service filed in Divorce Action to Docket No. 08 - 6750. A copy of said receipt and return receipt card are attached hereto as Exhibit "A" for ease of reference. I hereby certify that the facts set forth above are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. §4904 relating to Dated: December 2, 2008 to authorities. Bar ara umple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff U.S. Postal Ser vice CERTIFIED M AIL, RECEI PT o ,. rnesfic Mail Only: •. .. No Insurance Coverage For delivery information visit our %websiteat www.usps.com r? - .. o r #2.i72 0070 r u Postage cerurrea Fee $2.70 g?? lrU 4f Ln f ` 0 O Retum Receipt Fee (Endorsement Required) 2.2 ./ may f U .s Ln ra Total Postage & Fees C3 7p.g ED fO C S in r e i ru/) c ---------- C3 p SP 6 r or PO BaxNo. City State, ZFP+4 - - - - MOW W C I I - - - 14, --- -- --- ¦ Complete4tems1, pefiver - is d°s'red- item 4 if Restricted on the reverse ¦ Print your name and the ? to you. so that 1. ca return ¦ pttach:this card to the back of the mailpiece, or-on:Ui-e runt-ifspace permits- Article addressed to: Pf1Aj 2. Article Number (Trar sferfiomsemc law ` - 2004 pS Form 3811, February ?008 SO-01302 5289 7567 Domestic Retum Receipt 1025ss-024A-150 EXHIBIT "A" E Q =m C-) f?= ? t 3 cn DEC 22 2008 HEATHER L. SCHREINER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2008-6751 CIVIL ACTION LAW BRIAN S. SCHREINER Defendant IN CUSTODY ORDER AND NOW, this 16th day of December, 2008, the conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement between the parties, hereby relinquishes jurisdiction. The custody conciliation conference scheduled for December 17 is cancelled. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator J .-i? f... : ? . ; ?' ?z i f:`i 4?;. ?-•-} •? :?' w 0019 4 KC is ?/ Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 HEATHER L. SCHREINER, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 6751 BRIAN S. SCHREINER, : CIVIL ACTION -LAW Defendant : IN CUSTODY ORDER ADOPTING STIPULATION OF PARTIES th AND NOW, to wit, this Wday of L t_t t j& y , 2008, upon motion of Barbara Sumple-Sullivan, Esquire, counsel for Plaintiff, Heather L. Schreiner, it is hereby ordered, adjudged and decreed that the terms, conditions and provisions of the attached Stipulation for Custody dated December 16, 2008 are adopted as an Order of Court. BY THE COURT, Di bution: arbara Sumple-Sullivan, Esquire, 549 Bridge Street, New Cumberland, PA 17070 ;/1111 . Brian S. Schreiner, 480 Big Spring Road, New Cumberland, PA 17070 A %3o'v S ;1 ! 114V 6 Z 330 0001 -Hl JO Dr'Ri ,._03-IIJ , Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 HEATHER L. SCHREINER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. BRIAN S. SCHREINER, Defendant : NO. 08 - 6751 CIVIL ACTION -LAW IN CUSTODY STIPULATION REGARDING CUSTODY THIS AGREEMENT is made this ) 6 y of_heCo rw 2008, by and between Heather L. Schreiner, (hereinafter referred to as "Mother") an adult individual residing at 1005 Chelmsford Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050, and Brian S. Schreiner, (hereinafter referred to as "Father") an adult individual residing at 480 Big Spring Road, New Cumberland, York County, Pennsylvania 17070. WITNESSETH: WHEREAS, Mother and Father are the natural parents of one (1) minor child, Reyna Lynn Schreiner, born February 21, 2006. WHEREAS, a custody action was filed on November 13, 2008 and a custody conciliation is scheduled with conciliator Dawn S. Sunday, Esquire for December 17, 2008; WHEREAS, the parties now desire to amicably resolve all matters concerning custody by agreement and avoid the need for conciliation; NOW THEREFORE, the parties intending to be legally bound, do agree as follows: A. Lezal Custody: It is in the best interest of the minor child for the continuation of shared legal custody of the minor child. The parties agree that major decisions concerning the child's health, welfare, education, religious training and upbringing shall be made by the parents jointly, after discussion and consultation with each other, with a view towards obtaining and following a harmonious policy to arrive at a decision that is in the child's best interest. Each party agrees to keep the other informed of the progress of the child's education and social adjustments. Each party agrees not to impair the other parties' right to share legal custody of the child. Further, each party agrees to give support to one another in the role as parents and to take into account the consensus of the other parent for the physical and emotional well being of the child. The parties agree not to either attempt or alienate the affections of the child for the other parent. Each party shall notify the other of any activity that could reasonably be expected to be of significant concern to the other. The parties agree that the child will be encouraged to contact the other parent by telephone and e-mail at all reasonable times. B. Physical Custody: 1. Mother shall enjoy primary physical custody of the parties' minor child; 2. Father shall enjoy periods of partial physical each Friday when Mother goes into work until Sunday when Mother gets off of work; and 3. Such other times as the parties shall mutually agree upon. IN WITNESS WHEREOF, the parties hereto acknowledge that they are entering in to this Agreement with the full knowledge that this Agreement shall be entered as a court order with the same force and effect as if a full hearing on this matter has been held. SIGNED, SEALED AND DELIVERED IN THE PRESENCE OF: 4 ? LLMJ I INER kYME ATHER M. SCHREINER 2 ti COMMONWEALTH OF PENNSYLVANIA ) ) SS. COUNTY OF Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared Heather L. Schreiner, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing Stipulation Regarding Custody are true and correct to the best of her knowledge, information and belief. to before me this I ' day of 6 2008. NOTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA FPI My commission expires: ? b o?" ) W C0Mff**aiort Expires-Nov.15, 20C 11 t? Member, Pennsylvania Association or Notaries COMMONWEALTH OF PENNSYLVANIA ) eU-MJDM1Af?J )SS. COUNTY OF Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared Brian S. Schreiner, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing Stipulation Regarding Custody are true and correct to the best of his knowledge, information and belief. Affirmed and subscribed to before me this /J- day of ??.em L, 2008. C41 U4 d - V - NOTAR PUBLIC My commission expires: 3 14 a4 ?? (SEAL) COMMONWEALTH OF PENNSYLVANIA Notarial Seal Cheryl A. Wil Jay, Notary Public Lower Swatara Twp., Dauphin County My CornrKeSion Expires Mar. 14, 2010 Member, Pennsylvania Association of Notaries 3