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HomeMy WebLinkAbout08-7436 Paige Macdonald-Matthes, Esquire Pa. Supreme Court ID No. 27426 Serratelli, Schiffman, Brown and Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, Pennsylvania 17110 Telephone (717) 540-9170 Fax (717) 540-5481 Attorney For Plaintiff MATTHEW SHEALER IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. d 7 If 3t, 1-"- CIVIL ACTION -LAW NICOLE SHEALER : Defendant IN DIVORCE CUSTODY COMPLAINT TO THE HONORABLE, THE JUDGES OF SAID COURT: 1. The Plaintiff is Matthew Shealer, who currently resides at 29 Sherwood Circle, Enola, Cumberland County, Pennsylvania. 2. Defendant is Nicole Shealer, who currently resides at 29 Sherwood Circle, Enola, Cumberland County, Pennsylvania. 3. Plaintiff seeks primary physical custody and shared legal custody of the parties' one minor child, Morgan Shealer, born February 16, 2006. 4. The child was born out of wedlock. 5. The child is currently in the custody of the both parties who resides at 29 Sherwood Circle, Enola, Cumberland County, Pennsylvania. 6. During the past five years the child(ren) has/have resided with the following persons and at the following addresses: Persons Nicole & Matt Shealer Miles Albriton Nicole and Lita LeMaster Myles Albriton Address 327 Stonehedge Lane Mechanicsburg, PA East Berlin, PA Nicole and Miles Albriton New Oxford, PA Dates 2/16/06 - 8/06 8/06 - 10/06 10/06 - 7/07 7. The father of the child is Matthew Shealer, who currently resides at 29 Sherwood Circle, Enola, Cumberland County, Pennsylvania. 8. The relationship of Plaintiff, Matthew Shealer, to the child is that of father. 9. The relationship of Defendant, Nicole Shealer, to the child is that of the mother. The Defendant currently resides with the child, as well as her son from her first marriage, Myles Albriton and Plaintiff and the persons listed in Paragraph 6 above. 10. Plaintiff has not participated as a party, witness, or otherwise in litigation concerning the custody of the said child. Specifically, Defendant filed for custody in Adams County, Pennsylvania as soon as the child was born at Docket No. 2006-5-419. No further action has been taken with regard to this custody proceeding since June 28, 2006. Subsequent to the custody complaint being filed and the Order of Court being issued on May 28, 2006, the Parties married thus rendering the Court's May 28, 2006 Custody Order moot. 11. Plaintiff has no information of a custody proceeding concerning the child pending in a 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. Plaintiff seeks shared legal and physical custody of the Parties' minor child. 14. The best interests and permanent welfare of the child will be served by granting the relief requested because the Plaintiff is the father of the child and the child looks to Plaintiff as a constant source of love, stability and support. Moreover, by granting Plaintiff shared physical and legal custody will foster the parent/child relationship. 15. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff respectfully prays that Your Honorable Court award primary physical custody and shared legal custody of the child to the Plaintiff. Respectfully submitted, A c4 . coo Jl? ?? et?tvc?1 d lU a Paige Macdonald-Matthes, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2040 Linglestown Road Suite 106 Harrisburg, PA 17110 (717)540-9170 Attorney for Plaintiff VERIFICATION I, Matthew Shealer, verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: I? (ce Matthew Shealer CERTIFICATE OF SERVICE I, Paige Macdonald-Matthes, Esquire, do hereby certify that on this 22nd day of December, 2008, I served a copy of the foregoing Custody Complaint by first-class mail, postage prepaid, in the Post Office at Harrisburg, Pennsylvania, to the following person(s): Nicole Shealer 29 Sherwood Circle Enola, PA Paige Macdonald-Matthes, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2040 Linglestown Road Suite 106 Harrisburg, PA 17110 (717)540-9170 ,? .? 3 ?, ?`'• ; *r ?? ? ? -- ?;.. r 4,, .:: e.,, r?.; ?c '. MATTHEW SHEALER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NICOLE SHEALER DEFENDANT 2008-7436 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, December 30, 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 Thursday, January 15, 2009 _ at 12:00 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. 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 l ???,? -s ' ? ?. ?? 4 ? .? ?? a i,`?? Paige Macdonald-Matthes, Esquire Pa. Supreme Court ID No. 66266 Serratelli, Schiffman, Brown and Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, Pennsylvania 17110 Telephone (717) 540-9170 Fax (717) 540-5481 Attorney for Plaintiff MATTHEW SHEALER, vs. NICOLE SHEALER Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008-CV-7436 CIVIL ACTION - LAW : IN CUSTODY PRAECIPE TO SUBSTITUTE PAGE TO THE PROTHONOTARY: Please substitute the attached page to Plaintiff's Custody Complaint that was filed on or about December 22, 2009. The purpose of this filing is to correct Plaintiff counsel's Pennsylvania Supreme Court Identification Number. Respectfully submitted, Date: March 10, 2009ew?2 c ?-a ?; Paige Macdonald-Matthes, Esquire Attorney I.D. #66266 SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 540-9170 Attorneys for Plaintiff, Matthew Shealer CERTIFICATE OF SERVICE I, Paige Macdonald-Matthes, Esquire, counsel for the Plaintiff in the above captioned matter, certify that on this 10`" day of March, 2009, I served a copy of the foregoing Praecipe to Substitute Page upon the person(s) indicated below by U.S. Mail, postage paid, and addressed as follows: Carol J. Lindsay, Esquire Saidis Shuff Flower & Lindsay 26 West High Street Carlisle, PA 17013 Attorney for Defendant Paige Macdonald-Matthes, Esquire . Paige Macdonald-Matthes, Esquire Pa. Supreme Court ID No. 66266 Serratelli, Schiffman, Brown and Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, Pennsylvania 17110 Telephone (717) 540-9170 Fax (717) 540-5481 Attorney For Plaintiff MATTHEW SHEALER IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2008-7436 CIVIL ACTION - LAW NICOLE SHEALER Defendant CUSTODY CUSTODY COMPLAINT TO THE HONORABLE, THE JUDGES OF SAID COURT: 1. The Plaintiff is Matthew Shealer, who currently resides at 29 Sherwood Circle, Enola, Cumberland County, Pennsylvania. 2. Defendant is Nicole Shealer, who currently resides at 29 Sherwood Circle, Enola, Cumberland County, Pennsylvania. 3. Plaintiff seeks primary physical custody and shared legal custody of the parties' one minor child, Morgan Shealer, born February 16, 2006. 4. The child was born out of wedlock. 5. The child is currently in the custody of the both parties who resides at 29 Sherwood Circle, Enola, Cumberland County, Pennsylvania. 6. During the past five years the child(ren) has/have resided with the following persons and at the following addresses: t? 1 1,d 1.} MAR 2 6 7000 ? MATTHEW SHEALER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2008-7436 CIVIL ACTION LAW NICOLE SHEALER Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of 2009, upon M"Z- consideration of the attached Custody Conciliation Report, it is ordered and erected as follows: 1. The parties shall submit themselves, their minor Child, and any other individuals deemed necessary by the evaluator to a custody evaluation to be performed by Arnold Shienvold, PhD. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best meet the needs of the Child. The parties shall sign any authorizations deemed necessary by the evaluator in order to obtain additional information pertaining to the parties or the Child. The costs of the evaluation shall be paid as agreed between the parties or as determined by the Court. 2. The Father, Matthew Shealer, and the Mother, Nicole Shealer, shall have shared legal custody of Morgan Shealer, born February 16, 2006. Major decisions concerning the Child including, but not necessarily limited to, her health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in the Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the Child. Neither party shall attempt to alienate the affections of the Child from the other party. Each party shall notify the other of any activity or circumstance concerning the Child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. 3. On a temporary basis pending completion of the custody evaluation and further Order of Court or agreement of the parties, the parties shall share having physical custody of the Child in accordance with the following schedule: A. The parties shall alternate having custody of the Child on weekends from Friday after work through Monday morning before work. e; r. B. During weeks following the Father's weekend periods of custody, the Father shall have custody of the Child from Tuesday after work through Thursday morning before work. During weeks following the Mother's weekend periods of custody, the Father shall have custody of the Child from Tuesday after work through Wednesday morning before work. C. The Mother shall have custody of the Child at all times not otherwise specified for the Father in this provision. D. Unless otherwise agreed between the parties, all custody exchanges shall take place at the Child's daycare. 4. Within sixty (60) days of receipt of the written custody recommendations, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary. 5. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision. 6. 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. cc: Z- Macdonald-Matthes Esquire - Counsel for Father JUge Carol J. Lindsay, Esquire - Counsel for Mother PtP,4 M?uLa AOP ,I e, :01 Wv 0' 8vw 60oz ?1 f G i'i 1' .k Sul ]Hi r 4% MATTHEW SHEALER Plaintiff VS. NICOLE SHEALER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-7436 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: The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Morgan Shealer February 16, 2006 Mother/Father 2. A custody conciliation conference was held on March 13, 2009, with the following individuals in attendance: the Father, Matthew Shealer, with his counsel, Paige Macdonald-Matthes, Esquire, and the Mother, Nicole Shealer, with her counsel, Carol J. Lindsay, Esquire. 3. The parties agreed to entry of an Order in the form as attached requiring that the parties complete a custody evaluation with Dr. Arnold Shienvold. The Order also provides temporary custodial arrangements pending completion of the evaluation, which are the recommendations of the conciliator as the parties were unable to agree. Without additional information which makes either of the parties' proposed custody schedules more beneficial than the other to the Child's interests, the conciliator recommends an arrangement which incorporates both of the parties' positions. 4. The parties also were unable to agree as to responsibility for payment of the costs of the evaluation. The Father's counsel indicated that she intended to file a Petition with the Court to apportion the costs. 5. The conciliator recommends an Order in the form as attached. 0. j L-,? a, Date Dawn S. Sunday, Esquir Custody Conciliator MATTHEW SHEALER Plaintiff vs. NICOLE SHEALER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-7436 CIVIL ACTION - LAW : CUSTODY STIPULATION TO MODIFY CUSTODY 4-/ THIS AGREEMENT, made this day of June, 2009 by and between Matthew Shealer (hereinafter referred to as "FATHER") and Nicole Shealer (hereinafter referred to as "MOTHER"). WITNESSETH: WHEREAS, the Parties are the parents of one child, Morgan Shealer (DOB 2/16/06); WHEREAS, FATHER AND MOTHER separated on December 22, 2008 and have been living separate and apart since February 28, 2009; WHEREAS, a Temporary Custody Order was entered by the Court on March 30, 2009, which grants the parties shared legal and physical custody of their minor child; and WHEREAS the Parties are desirous of modifying the previously entered Temporary Order for Custody to address the particular needs and concerns of Morgan Shealer. NOW THEREFORE, in consideration of the mutual promises, covenants and undertakings hereinafter set forth, and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the Parties hereto, FATHER and MOTHER, each intending to be legally bound hereby covenant and agree as follows: 1. LEGAL CUSTODY: FATHER and MOTHER shall have shared (joint) legal custody of Morgan Shealer. Joint legal custody means the right of both parents to control and to share in making decisions of importance in the life of their children, including educational, medical and religious decisions. Both parents shall be entitled to equal access to a child's school, medical, dental and other important records. Notwithstanding that the Parties shall share legal custody, non-major decisions involving the child's day to day living shall be made by the parent then having custody, consistent with the other provisions of this Agreement. 2. PHYSICAL CUSTODY: FATHER AND MOTHER shall have shared physical custody of Morgan pursuant to the schedule attached hereto as Exhibit "A", and continuing thereafter in the manner set forth in Exhibit "A". 3. ALTERNATE HOLIDAYS: FATHER and MOTHER agree to alternate the holidays of New Year's Day, Easter, Memorial Day, Independence Day, Labor Day and Thanksgiving. Except for Thanksgiving, the holiday time period will run from 9:00 a.m. to 9:00 p.m., and the alternating holiday schedule will commence with FATHER having Easter in 2009. With regard to Thanksgiving, that holiday will run from Thursday at 9:00 a.m. until Sunday following Thanksgiving. 4. MOTHER'S DAY and FATHER'S DAY: MOTHER shall always have the right of partial custody on Mother's Day. FATHER shall always have the right of partial custody on Father's Day. The rights of partial custody shall be exercised from 9:00 a.m. until 9:00 p.m. 5. CHRISTMAS: MOTHER shall have Morgan from December 24 at 10:00 a.m. until December 25 at 2:00 p.m. FATHER shall have Morgan from December 25 at 2:00 p.m. until December 26 at 6:00 p.m. 6. HOLIDAYS A PRIORITY: The periods of partial custody for holidays, vacations or other special days set forth in this Agreement shall be in addition to, and shall take precedence over, but shall not alter the schedule or sequence of regular periods of custody, as set forth in paragraph 2 herein. Holidays and other special days for custody set forth in this Agreement shall take precedence over vacations. 7. SUMMER: The Parties agree that they each shall be entitled to have two (2) full, non-consecutive weeks of summer visitation with Morgan. For purposes of this paragraph, a week shall consist of seven (7) days. The Parties shall notify each other in writing by June 1 of their intended vacation plans. In the event that the Parties select the same time period, the Party providing the written notice to the other Party FIRST shall be entitled to have first choice of the vacation time. 8 OTHER TIMES OF PARTIAL CUSTODY: The Parties hereto agree that each non-custodial parent shall be entitled to other periods of partial physical custody as the Parties may agree from time to time, including but not limited to, holidays not specifically provided for herein. 9. TRANSPORTATION: The Parties agree that they shall share the transportation of Morgan, with the Party relinquishing custody to provide the transportation either to the other Party's home or to Morgan's day care provider. The Parties further agree that they will be punctual for the custodial exchange. 10. LATE FOR EXCHANGE: In the event that either parent is more than 30 minutes late for a scheduled custody exchange, in the absence of a telephone call or other communication from the parent who is or will be late, the other parent may assume that the parent who is late has chosen not to exercise that period of custody, the first'day of the scheduled custody period will be forfeited (unless otherwise agreed to by the Parties), and the other parent will be free to make other plans with the child. 11. TELEPHONE CONTACT: Each parent shall be entitled to reasonable telephone contact with Morgan when she is with the other parent PROVIDED HOWEVER that telephone calls during each Parent's custodial time will not exceed three (3) in number during the entire period and shall not last for more than 15 minutes. The custodial parent shall make every effort to allow Morgan to speak with the non-custodial parent at the time the non-custodial parent initiates the telephone contact to the custodial parent's residence or other location where Morgan may be. The custodial parent shall provide the non-custodial parent with the telephone number and location of where Morgan will be if she would not be in the custodial parent's primary residence for more than a twenty-four (24) hour period in order to enable the non-custodial parent to make reasonable telephone contact with Morgan. If the parent wants to speak with the other parent in conjunction with a phone call, the parent is to permit Morgan to speak with the other parent first. 12. ALTERNATIVE CHILD CARE/RIGHT OF FIRST REFUSAL: The Parties shall keep each other apprised of the alternative child care arrangements made for Morgan while Morgan is in their custody to the extent that the Parties themselves are not personally taking care of Morgan. This shall include the obligation to provide the names, addresses and telephone numbers of the individual(s) charged with Morgan's care. In the event that either Party is unable to personally care for Morgan for a period in excess of three (3) hours, that Party shall notify the non-custodial parent and provide the non- custodial parent the opportunity to assume custody of conditions set forth in paragraph 11 herein; B. Access to report cards and other relevant information concerning the progress of Morgan in school; C. Prior approval of extraordinary medical and/or dental treatment, except, in the case of an emergency and provided that such approval shall not be unreasonably withheld; and D. Each of the Parties' rights to participate in making major decisions affecting the best interests of Morgan, including major medical, religious and educational decisions; educational decisions shall be defined as those decisions directly related to or affecting the academic performance of Morgan in the classroom. 17. FEDERAL INCOME TAX: MOTHER and FATHER shall alternate each year to claim Morgan Shealer as a dependent on the federal and state income tax returns. FATHER will claim Morgan Shealer as a dependent in the even years and MOTHER shall claim Morgan Shealer as a dependent in the odd years. 18. EXCHANGE OF INFORMATION/RELOCATION: The Parties agree to provide the other with their telephone number(s), and to advise each other of any change thereof within twenty-four hours (24) hours of any such change. Each of the Parties further agree that in the event that they intend to move from their present residence, each shall give the other written notice of their intent no less than thirty (30) days prior to their intended relocation date. 19. ILLNESS OF THE CHILDREN: In the event of any serious illness and/or injury of Morgan at any time, the parry then having physical custody of Morgan shall immediately communicate with the other parry by telephone, informing the other party of the nature of the illness and/or injury. During such illness and/or the treatment of such injury, each parent shall have the right to visit Morgan as often as s/he desires, consistent with the proper medical care of Morgan. 20. DOCUMENTS: Each Party shall, at the request of the other, execute, acknowledge and deliver to the other Party any documents which may be reasonably necessary to give full force and effect to this Stipulation for Custody. 21. VOLUNTARY EXECUTION AND FAIRNESS OF THIS AGREEMENT: Each Party hereto acknowledges that this Stipulation has been entered into by his/her own volition, and with the advice of separate, independent counsel, with full knowledge of the facts and full information as to their legal rights and that each believe that the Stipulation to be reasonable and in the best interest of Morgan Shealer under the circumstances and not the result of any duress or undue influence. 22. ENTRY OF COURT ORDER: FATHER and MOTHER agree that this Stipulation shall be formalized by the entry of an Order in accordance with the terms and provisions of this Stipulation by the Court of Common Pleas, Cumberland County, Pennsylvania. 23. GOVERNING LAW: This Stipulation shall be construed and governed in accordance with the laws of the Commonwealth of Pennsylvania. 24. VENUE: The Parties agree that any future disputes regarding the terms of this Stipulation or modification of this Stipulation shall be brought before the Court of Common COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On this `? day of , 2009, before me, the undersigned officer, personally appeared Nicole Shealer, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. 40TARY PUB M(" AL otary Public SEAL: Ema nd County, PA s June'!, 2011 Pleas, Cumberland County, Pennsylvania, provided that the jurisdiction appropriately remains in Cumberland County, Pennsylvania under the Uniform Child Custody Jurisdiction Enforcement Act ("UCCJEA"). See 23 Pa. C.S. §5402. 25. DESCRIPTIVE HEADINGS: The descriptive headings herein are for convenience purposes only. They shall have no effect whatsoever in determining the rights and obligations of the Parties. 26. BINDING EFFECT: Each of the Parties hereto intends to be legally bound hereby, and this Stipulation shall be binding upon their heirs, personal representatives and assigns of the respective Parties hereto. In the event that either Parry breaches any provision of this Stipulation or violates any provision of the Order that shall be entered in accordance with this Stipulation and the non-breaching Party retains counsel to assist them in enforcing the terms thereof, the non-breaching Party shall be entitled to recover all counsel fees, costs and expenses from the breaching Party. IN WITNESS THEREOF, the Parties hereto have set their hands and seals the day and year first above written. Witness W' ss d?' ?OL? Matthew Shealer Nicole Sh r O O N = h a F w G c? r-? z ° O N c N z ? w w a z N z ? w a ° LO z N W C a a o F o F o H w o F w o F r--a 9 00 z Lr) N z N o a O H a i y Z N 00 N O z L d i O O N w Q r--? ? Oi0 Q ? w U Q y w G ? a O E.., a V s ? ? ? ? w 3 ?--+ z 00 r--+ z N N z w ? ? a ? o F Li z ?--? ? N z N ? c h 0 o H N z v CIA O O N ?I I b?A A ca W Q ?? ° o0z Lf) ?? N Nz O N? 00 l?z ?? Nz N? y a h a ? 2 z N N z ? ny ?M a F a 3 Lf) 0 z t-+ x N z Q o ? z c F O p " z O Q c'0 y 4 O O N .C] ? ?a E.., w O F-, ?a a F a F w ?v w w O N r-.-i z z ? H ? E-? ?a E- ' ,a E" C E" O z a0 r--+ z N N z ? L? ? ? ?+ r--? ? ? ? N c ? ono N z o o H y te H N ? 2 r -- ;: 64 2 ON O O N W O U 0 N z 2 r-+ z N c? z ? w w l? w O H w ? H 3 V ? Li z r -+ N z N o o ? c F., a F. a 00 Lr) p G 4 a w O O N s., N 7 O z A to ? F a ? a t% t"r ? 0 ? Q M vv VV L? ? ? z N ? N z ? w w a H o ? V H Lf) z z N a a H H 3 d+ z Q cc z Lr) N ? ? O F O o F c c ? ? ce p ?" o o N o L N H ?c a d w C*N O O N U N Q b W W y ? O H O Lf) ? z N z ? V w a F w w T. w Lr) b b 3 O O N z ? ? r+ z N z c? z ? w w w a H F O Lf') F O F ? N z N o ? F a h Li z ? ? N z N ? w w H ? o ? o x c z N 7 N z a a? d w COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On this 16-4A day of - l4n C , 2009, before me, ?Q?vv? rnu E, ?j pQe , the undersigned officer, personally appeared Matthew Shealer, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. MaTN11Al SEAL SEAL: 1N1?1? E air i_Y?OIAl1AIMN ? i?01NlTr Mt ?MMM Ap i. lA1? OTARY VUBTL?(O r _ F^ ? i r ^f i ! f~ c'. Yon" I wow IUW vmm+?!?'a? slogM 00 ,.... I . MATTHEW SHEALER Plaintiff vs. NICOLE SHEALER Defendant JUN 18 20096 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-7436 CIVIL ACTION - LAW CUSTODY ORDER AND NOW, this L V day of June, 2009, upon consideration of the Parties' Stipulation to Modify Custody, a copy of which is annexed hereto, it is ORDERED that the Parties shall have shared legal and primary physical custody of Morgan Nicole Shealer consistent with the agreed upon terms of the Parties' June IL, 2009 Stipulation to Modify Custody. a 1?ti... "':._? JF T,k.R`l tir?? Q?(,lf ?C'ypt ?f6S 2009 JU?,' 19 Ali 9: C') tfc?