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HomeMy WebLinkAbout09-46340 Derek Cordier, Esq. #83284 319 South Front Street, Harrisburg, PA 17104-1621 (717) 919-4002 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA Kevin L. Paul: Plaintiff VS. Shelly Kay Paul Defendant (erm Docket No. nq- 4103q aivi( Civil Action - Law Divorce NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Cumberland County Prothonotary at One Courthouse Square, Carlisle, PA 17013-3387. Phone: (717) 240-6195. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE., CARLISLE, PA 17013 (717) 249-3166 OR 1-800-990-9108 Derek Cordier, Esq. #83284 319 South Front Street, Harrisburg, PA 17104-1621 (717) 919-4002 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA Kevin L. Paul: Plaintiff VS. Shelly Kay Paul Defendant . Docket No. 0 9- y L 3 1 Civil Action - Law Divorce COMPLAINT UNDER 43301(c) AND 0301(d) OF THE DIVORCE CODE AND NOW comes Plaintiff, Kevin L. Paul, by his counsel, Derek J. Cordier, and states against Defendant, Shelly Kay Paul, as follows: 1. Plaintiff is Kevin L. Paul and he has resided at 1 Lula Lane, Enola, PA 17025. 2. Defendant is Shelly Kay Paul and she has resided at 1 Lula Lane, Enola, PA 17025. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 7, 1994 in Enola, Cumberland County, Pennsylvania. 5. The parties separated on March 1, 2009. 6. There have been no prior actions of divorce or annulment between the parties. 2 7. The marriage is irretrievably broken. 8. Neither party is currently enlisted in or commissioned by any branch of the United States Military. 9. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. Wherefore, Plaintiff requests the court to enter a decree of divorce. COUNT I: EQUITABLE DISTRIBUTION 10. Plaintiff incorporates and alleges by reference herein Paragraphs 1 through 9 above. 11. Plaintiff and Defendant possess various items of both real and personal marital property, as well as marital debts, which are subject to equitable distribution by this Court. Wherefore, Plaintiff requests the Court to equitably distribute all marital property and marital debts. COUNT II: CUSTODY 12. Plaintiff incorporates and alleges by reference herein Paragraphs 1 through 11 above. 13. Plaintiff seeks shared legal and physical custody of the following Children: Savhanna Paul, residing at 1 Lula Lane, Enola, PA 17025 AGE: 12, born July 11, 1997 Tristan Paul, residing at 1 Lula Lane, Enola, PA 17025 AGE: 8, born January 30, 2001 The Children were not born out of wedlock. The Children are presently in the physical custody of both parties, residing at 1 Lula Lane, Enola, PA 17025. During the past 12 years, the Children have resided with the following persons and at the following addresses: Father and Mother, at 1 Lula Lane, Enola, PA 17025 from birth until present. 3 The Father of the Children is Kevin L. Paul, currently residing at 1 Lula Lane, Enola, PA 17025. The Mother of the Children is Shelly Kay Paul, currently residing at 1 Lula Lane, Enola, PA 17025. 14. The relationship of Plaintiff to the Children is that of Father to Daughters. The Plaintiff currently resides with the following persons: Plaintiff resides with Mother, Shelly Kay Paul, both children, and no one else. 15. The relationship of Defendant to the Children is that of Mother to Daughters. 16. 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. 17. The best interest and permanent welfare of the Children will be served by granting the relief requested because: It is in the best interest of the Children in that their financial, physical, and emotional well being shall be served by Children's Father having shared legal and physical custody of the Children. 18. Each parent whose parental rights to the Children have not been terminated and the person who has physical custody of the Children have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the Children will be given notice of the pendency of this action and the right to intervene: There are no other persons having a claim of right to custody. Wherefore, Plaintiff requests the court to grant Father shared legal custody and shared physical custody of the Children. 4 VERIFICATION I, Kevin L. Paul, verify that the statements made in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information, and belief. I understand that the statements made therein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. /G L 7 f l?l D`l Kevin L. Paul, Plaintiff Date Respectfully submitted by: Der Cordier, Es . #83284 319S6 treet Harrisburg, PA 17104-1621 (717) 919-4002 1 HE i i?. ?. 1009 SJI 10 t 2' r 1 y Co(o . 5o PD pTN Ck,? 023101 R aa-7 stP4 nG 1pD" `uy1 Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Defendant KEVIN L. PAUL, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2009-4634 V. CIVIL ACTION - LAW SHELLY KAY PAUL, IN DIVORCE/CUSTODY Defendant MOTION FOR APPOINTMENT OF CUSTODY CONCILIATOR AND NOW, this LL6d'ajy of November, 2009, the Defendant, Shelly Kay Paul, by and through her attorneys, Johnson, Duffle, Stewart & Weidner, files this Motion to Appoint a Custody Conciliator, and avers in support thereof as follows: 1. The Defendant and Mother is Shelly Kay Paul who presently resides at 3 Lula Lane, Enola, Cumberland County, Pennsylvania. 2. The Plaintiff and Father is Kevin L. Paul, who presently resides at 1 Lula Lane, Enola, Cumberland County, Pennsylvania. 3. The Petitioner is represented by the undersigned counsel. 4. The Plaintiff, Kevin L. Paul is represented by Derek Cordier, Esq. 5. A Complaint in Divorce was filed on July 10, 2009. 6. The Complaint was served on July 29, 2009. 7. The Complaint in Divorce contains a count regarding custody of the parties' two (2) children. 8. Thus, Defendant expects that Plaintiff will concur with this Motion and is awaiting confirmation. 9. The parties have not been able to reach an agreement with regarding to sharing of the parental responsibilities now that they are not living together and the Defendant/Mother does not believe an agreement is likely to be reached outside the assistance of a custody conciliator. 10. No Judge has been assigned to this matter. WHEREFORE, the Defendant respectfully requests this Honorable Court assign a Custody Conciliator and promptly arrange for a Conciliation Conference. JOHN?%i , UFFIE, STEWART & WEIDNER lissa Peel Greevy :383317 CERTIFICATE OF SERVICE AND NOW, this day of November, 2009, the undersigned does hereby certify that she did this date serve a copy of the foregoing Motion for Appointment of Custody Conciliator upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Derek Cordier, Esq. 319 South Front Street Harrisburg, PA 17104-1621 JOHNSO FFIE, STEWART & WEIDNER C. - ( &'9-? Melissa Peel Greevy OF THE )CAW NOV 17 PH 12= 15 "11.1" : KEVIN L. PAUL IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. SHELLY KAY PAUL DEFENDANT 2009-4634 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, November 23, 2009 , 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, December 29, 2009 at 2:30 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. Failure to appear at the conference may provide grounds for entry ofa 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/ ohm . Mangan, r. Es . 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 FILED-OffiCE OCF THE PROTIHNO ARY 2009 NOV 23 PM 1: 4 3 r_± G'3 ? 11/ ???-qq?'MrJ Johnson, Duffie, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Defendant KEVIN L. PAUL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 2009-4634-DV SHELLY KAY PAUL, CIVIL ACTION - LAW Defendant IN DIVORCE CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant hereby certifies that: (1) A Notice Of Intent To Serve A Subpoena, with a copy of the subpoena attached thereto, was mailed, or delivered to Plaintiff at least twenty (20) days prior to the date on which the subpoena was sought to be served; (2) A copy of the Notice Of Intent, including the proposed subpoena, is attached to this Certificate; (3) No objection to the subpoena has been received; and (4) The subpoena to be served is identical to the subpoena attached to the Notice Of Intent. Respectfully submitted, DUFFIE, STEWART & WEIDNER Date: 1 Johnson, Duffie, Stewart & Weidner By: Melissa Peel Greevy, Esquire I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 KEVIN L. PAUL, Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 2009-4634-DV CIVIL TERM SHELLY KAY PAUL, Defendant IN DIVORCE NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 To: Derek Cordier, Esquire 319 South Front Street Harrisburg, PA 17104-1621 PLEASE TAKE NOTICE that Defendant intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. Date: rll I I I 447845 Respectfully submitted, JO,?i'NSO%DUFFIE, STEWART & WEIDNER ssa Peel Greevy, Esquire CERTIFICATE OF SERVICE ?' r AND NOW, this _- day of J 2011, the undersigned does hereby certify that she did this date serve a copy of the f egoing Notice Of Intent to Serve Subpoena to Produce Documents And Things For Discovery Pursuant To Rule 4009.21 upon the counsel of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Derek Cordier, Esquire 319 South Front Street Harrisburg, PA 17104-1621 JOHN§D?J, DUFFIE, STEWART & WEIDNER Melissa Peel Greevy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEVIN L. PAUL, Plaintiff vs. SHELLY KAY PAUL, Defendant No. 2009-4634-DV IN DIVORCE SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: State Employees' Retirement System (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: 2009 Statement of Account as of December 31, 2009 - Basic Data and 2009 Statement of Account - Estimated Retirement Benefits for Kevin L. Paul Date of Birth 2/15/72 SS# 163-56-6268 at Johnson, Duffie, Stewart & Weidner, 301 Market Street P.O. Box 109, Lemoyne PA 17043. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Melissa Peel Greevy Esquire ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID 77950 BY THE COURT: L'_e'L Prothonotary/Clerk, Civil Division Deputy DATE : 30 I l Seal of the Court (Eff. 7/97) CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing Certificate Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22 upon the person indicated below by depositing a copy of the same in the United States mail, postage prepaid, at Lemoyne, Pennsylvania, on the Z-il-- day of July, 2011: Derek Cordier, Esquire 319 South Front Street Harrisburg, PA 17104-1621 NSON, DUgFIE, STEWART & WEIDNER By: Greevy :450708 0Ti Q1v0TA" ' 2 2 FEB 17 PM 2: 12 CUMBERLAND COUNT PENNSYLVANIA Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I. D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 KEVIN L. PAUL, Plaintiff vs. SHELLY KAY' PAUL, Defendant Attorneys for Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2009-4634-DV IN DIVORCE PETITION TO RAISE DEFENDANT'S CLAIMS FOR EQUITABLE DISTRIBUTION PURSUANT TO Pa R C.P. 1920.15(b) AND COUNSEL FEES, COSTS AND EXPENSES AND NOW, comes the Defend ant/Petitioner, SHELLY KAY PAUL, by and through her attorneys, Johnson, Duffie, Stewart & Weidner, and files this Petition to Raise Defendant's Claims for Equitable Distribution Pursuant to Pa. R.C.P. 1920.15(b) and Counsel Fees, Costs And Expenses and in support of her Petition avers as follows: COUNT I - EQUITABLE DISTRIBUTION 1. Plaintiff is Kevin L. Paul, an adult individual currently residing at 301 Chestnut Street, Apt. 902, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant is Shelly Kay Paul, an adult individual currently residing at 3 Lula Lane, Enola, Cumberland County, Pennsylvania. Qf\o? %gs.06 Pet C?* 3ags y P-4?a T 91 7 14 ,.L.N A I - ti_U /I C 3. A Complaint in Divorce in this matter was filed with the Court on July 10, 2009. 4. Plaintiff and Defendant have legally and beneficially acquired certain real and personal property during their marriage. 5. The parties have not yet, but may, enter agreements for the resolution of their divorce and equitable distribution. COUNT 11 - COUNSEL FEES, COSTS AND EXPENSES 6. The Defendant has retained an attorney to represent her in this action and has agreed to pay a reasonable fee. 7. The Defendant is not financially able to meet the expenses and costs involved in connection with this action, or the fees to which her attorney will be entitled in this case. 8. Reserving the right to apply to the Court for temporary counsel fees, costs and expenses prior to final hearing, Defendant requests that after final hearing, the Court order the Plaintiff to pay Defendant's reasonable counsel fees, costs and expenses. 9. Defendant believes she is entitled to counsel fees pursuant to 42 Pa.C.S. §2503(7). WHEREFORE, Defendant prays that your Honorable Court enter a Decree in Divorce as follows: (a.) dissolving the marriage between the parties; (b) equitably distributing, dividing or assigning the marital property of the parties; (c.) ordering Plaintiff to pay counsel fees, costs and expenses of this action to Defendant; and (d.) granting such other further relief as the Court deems appropriate. Respectfully submitted, JOHN.. @d UFFIE, STEWART & WEIDNER `"MelN?'sa Peel Greevy :474147 VERIFICATION I, SHELLY KAY PAUL, verify that the statements made in the foregoing Petition To Raise Defendant's Claims for Equitable Distribution Pursuant To Pa. R.C.P. 1920.15(b) and Counsel Fees, Costs and Expenses are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A §4904, relating to unsworn falsification to authorities. Date: ?- SHELLY PZNL CERTIFICATE OF SERVICE AND NOW, this day of February, 2012, the undersigned does hereby certify that -1 lo she did this date serve a copy of the foregoing Petition to Raise Defendant's Claims for Equitable Distribution Pursuant to Pa.R.C.P. 1920.15(b) and Counsel Fees, Costs and Expenses upon the Plaintiff's counsel causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Derek Cordier, Esquire 319 South Front Street Harrisburg, PA 17104-1621 Attorney for Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER By: nne H. McCullough F1 L E D f= E;CE 0E THE DR0 rf0?10TAry Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 KEVIN L. PAUL, Plaintiff vs. SHELLY KAY PAUL, Defendant 26M FEB 17 PM 2: 00 CUMBERLAND COUNT`,( PENNSYLI A'flA Attorneys for Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2009-4634-DV IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated on March 1, 2009 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit 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: -/1 J 12 SHELLY L, DEFENDANT CERTIFICATE OF SERVICE AND NOW, this 1U'- day of February, 2012, the undersigned does hereby certify that she did this date serve a copy of the foregoing Affidavit Under Section 3301(d) of the Divorce Code upon the Plaintiffs counsel causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Derek Cordier, Esquire 319 South Front Street Harrisburg, PA 17104-1621 Attorney for Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER By: -V-6uj? Anne H. McCullough :472441 LE -GFI SCE- y` F T'E 0T 0N0 TA, Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 2G 12 FEB 17 PM 2= C CUMBERLA14D COUNT PENNSYLVANIA Attorneys for Defendant KEVIN L. PAUL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2009-4634-DV SHELLY KAY PAUL, Defendant IN DIVORCE DEFENDANT'S INVENTORY Defendant files the following inventory of all property owned or possessed by either party at the time the action was commenced and all property transferred within the preceding three (3) years. Defendant verifies that the statements made in this Inventory are true and correct. Defendant understands that false statements herein are made subject to penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: + 2 N SHELLY L, Defendant Submitted by, J HNSON, D FFIE STEW' A^RT & WEIDNER Melissa Peel Greevy ASSETS OF PARTIES Defendant marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. (X) (X) (X) (X) (X) (X) (X) (X) (X) 1. Real property 2. Motor vehicles 3. Stocks, bonds, securities and options 4. Certificates of deposit 5. Checking accounts, cash 6. Savings accounts, money market and savings certificates 7. Contents of safe deposit boxes 8. Trusts 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) 10. Annuities 11. Gifts 12. Inheritances 13. Patents, copyrights, inventions, royalties 14. Personal property outside the home 15 Businesses (list all owners, including percentage of ownership, and office/director positions held by a party with a company) 16. Employment termination benefits-severance pay, worker's compensation claim/award 17. Profit sharing plans 18. Pension plans, thrift savings plans (indicate employee contribution and date plan vests), 401(k) 19. Retirement plans, Individual Retirement Accounts 20. Disability payments 21. Litigation claims (matured and unmatured) 22. MilitaryN.A. benefits 23. Education benefits 24. Debts due, including loans, mortgages held 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) 26. Insurance benefits MARITAL PROPERTY Defendant lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced. Defendant reserves the right to supplement this list prior to time of trial. See attached Spreadsheet which includes marital property. NON- MARITAL PROPERTY Description 1. SERS Retirement (non-marital portion) 2. American Funds 403(b) (non-marital portion) 3. AmeriHealth Mercy 401(k) (non-marital portion) Owner Basis for Exclusion Kevin Portions acquired prior to marriage and subsequent to separation Shelly Contributions acquired subsequent to separation Shelly Contributions acquired subsequent to separation PROPERTY TRANSFERRED The marital home located at 1 Lula Lane, Enola, Pennsylvania, was sold jointly by the parties and the proceeds have been divided between the parties, to their mutual satisfaction. JOINT LIABILITIES OF PARTIES Creditors 1. PSECU auto loan - Honda Accord 2. PSECU auto loan - Toyota Camry 3. Citimortgage - now satisfied 4. Navy Federal Credit Union HELOC - now satisfied 5. PSECU Visa 6. JcPenney 7. Target 8. CitiFinancial - Just Cabinets 9. Home Depot 10. Boscov's 11. Kohl's 12. Kohl's 13. Lowe's 14. Navy Federal Credit Union Debtors Shelly and Kevin Shelly and Kevin Shelly and Kevin Shelly and Kevin Shelly and Kevin Shelly and Kevin Kevin Kevin Kevin Kevin Shelly Kevin Kevin Kevin Defendant believes that the parties have distributed the debt to their mutual satisfaction. I ! I 11 I 1 C I II ! V II I 1! II 1 I I I I v 0) C)' m ? C O c C V1 (n M o wa? E N ? a v m rn o ? 1 a z° E a =31 ? M 1 0 G U . l IM' ? O c ' t) O O 0) C 1 cn N p p VII a? 1 I Ic QI co > I c c O O I l f?0 O O 0\ll \O i U C ioo' E o ' ? N L f6 l M CV) - II O v 0 0) Y cn N - - - M M - O I-? - I M M i to 61+ Q c? O 00 (O j 00 (O (D N I i (D M co M LO l Lo LO 64 = F/3 GH O U? 'er ?, co O O ? CY) ? O U. , O ? (fl i ' O I I I I O O N 6R to b9 Efl (R Oi O U-) LO O L L 7 N N W ?I d I i Q ' a I d g'I I>, E 0 U 0 0' =1 I - N 00; > a? N L Y cn Q _ w I cm E c ? _ ? rn? ; O ;c C G> CI c d - " N LL C (o O d' V C? ,I O p m ca O O rn o N O F- O 2 m I E ? V N 2 V' Q? >> J JJ i r cv co O ca i ? ? '? Y' V U U Q I O1 O O O t 10 ; O 75 a) 010 iL ? O O 'N ON m Z a- Q- O 1 G L (n fn ?# I 1 ? I - I O O 0 m Q ?j CJ IIIm U NI M !D ?- NM W p , CERTIFICATE OF SERVICE AND NOW, this day of ?G?ot?al? 2012, the undersigned does hereby certify that she did this date serve a copy of the foregoing Defendant's Inventory and Appraisement upon the Plaintiffs counsel causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Derek Cordier, Esquire 319 South Front Street Harrisburg, PA 17104-1621 Attorney for Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER By: Anne H. McCullough :474175 W r- 73 C.r CD Jane Adams ATTORNEY AT LAW Attorney I.D.No.79465 C: C: 17 W.South St. Carlisle,Pa.17013 "" = (717)245-8508 esgadams@gmail.com ---------------------------------------------- KEVIN L. PAUL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2009 -4634 Civil Term SHELLY KAY PAUL, CIVIL ACTION - LAW Defendant IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW, comes Plaintiff/Petitioner, Kevin L. Paul, by and through his counsel, Jane Adams, Esquire, and petitions the Court as follows: 1. Kevin L. Paul, (hereinafter referred to as "Father"), is the Plaintiff in the above-captioned matter, and is an adult individual currently residing at 1922 Green Street, Harrisburg, Dauphin County, Pennsylvania, 17102. 2. Shelly Kay Paul, (hereinafter referred to as "Mother"), is the Defendant in the above-captioned matter, and currently resides at 3 Lula Lane, Enola, Cumberland County, Pennsylvania, 17025. 3. The parties are the natural parents of two children, namely, Savhanna Paul, born July 11, 1997, age 15, and Tristan Paul, born January 30, 2011, age 12. 4. The parties are subject to a stipulation and an Order of Court, dated December 28, 2009, which provides that the parties have shared legal custody and that Father has physical custody of the children every other weekend during the school year, and on a week on, week off basis during the summer. 4-s 3. �0 ct g,#1 .2-,? J 5. Since entry of the last Order, there has been a substantial change of circumstances in that: (a) Savhanna is now fifteen (15) years old and has repeatedly and consistently indicated, without prompting, to Father that she would like to see Father on an equal basis during the school year. (b) Father would like to have equally shared physical legal custody of Savhanna during the school year. Father would like to see Tristan more during the school year as well, but does not feel that shared physical custody of Tristan is a good fit for him at this time. (c)Since initiation of the divorce, and entry of the prior custody Order in 2009, Father's situation has stabilized and he feels that his request is appropriate given the child's ages and the current circumstances. 6. Father is requesting that the current custody Order be modified, such that he have substantially more physical custody with the children. 7. It would be in the best interest of the children to modify this Order because a substantial change of circumstances has occurred and the prior agreement and Order do not adequately provide the children to have frequent and ongoing contact with both parents. 8. It is believed and averred that the best interest and permanent welfare of the children will be promoted by changes proposed in this custody petition. WHEREFORE, Plaintiff requests the court to set a conciliation date to examine issues regarding custody of the children. Respectfully submitted Date: / e Adams, Esquire 1 . No. 79465 17 West South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR FATHER KEVIN L. PAUL VERIFICATION 1 verify that the statements made in this Petition are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. 4m; . Date: , /� �� Kevin L. Paul, Petitioner KEVIN L. PAUL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2009 - 4634 Civil Term SHELLY KAY PAUL, CIVIL ACTION - LAW Defendant IN CUSTODY PRAECIPE FOR WITHDRAWAL AND ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of Derek J. Cordier, Esquire, as Attorney of record for Kevin L. Paul. Respectfully submitted, �-, ,, 2 rq -rZ -G CO O C7 Date: x7 C3 DerekT C dier, squire -� 319 S. Front CD Harrisburg, Pa. 1 104 D CD M Please enter the appearance of Jane Adams, Esquire as Attorney of record for Kevin L. Paul. l pectfully Submitted: Date: J ne Adams, Esquire .D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 KEVIN L. PAUL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA • : CIVIL ACTION - LAW vs. : NO. 09-4634 CIVIL • SHELLY KAY PAUL, • Defendant ORDER AND NOW, this �' day of July, 2013, the above-captioned case is assigned to the Honorable J. Wesley Oler, Jr., Senior Judge. BY THE COURT, - 4 1,14, Kevin : . Hess, P. J. The Honorable J. Wesley Oler, Jr. Court Administrator :rim r/e//3 C) -40 X rn CO C7 >C: Cir • --I C!� rso KEVIN L. PAUL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-4634 CIVIL ACTION -LAW SHELLY KAY PAUL, Defendant : IN CUSTODY ORDER OF COURT AND NOW,this 5S �4 day of_ �, , 2013, upon consideration of the attached Custody Conciliation Repo•t, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. , of the Cumberland County Court House, on the * t"-1ay oP—nDUAr- ,cam , 2013, at C?.,3 a o'clock, ]�* . M., at which time testimony will betaken. For purposes of this Hearing, Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness.' These Memoranda shall be filed at least five days prior to the Hearing date. 2. Pending the hearing, the prior Order of Court of the Honorable J. Wesley Oler, Jr. dated December 28, 2009 shall remain in full force and effect. 3. 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 THE COURT, a,Weslc Z Gl.��rs J. N cc�J e Adams, Esquire, Counsel for Father c - � �.rn = Melissa P. Greevy, Esquire, Counsel for Mother - r- -<s' _�CN a KEVIN L. PAUL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-4634 CIVIL ACTION -LAW SHELLY KAY PAUL, 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 Savhanna Paul July 11, 1997 Mother Tristan Paul January 30, 2001 Mother 2. A Conciliation Conference was held in this matter on July 2, 2013, with the following in attendance: The Father, Kevin L. Paul, with his counsel, Jane Adams, Esquire, and the Mother, Shelly Kay Paul, with her counsel, Melissa P. Greevy, Esquire. 3. The Honorable J. Wesley Oler, Jr. previously entered an Order of Court dated December 28, 2009 providing for shared legal custody, Mother having primary physical custody and Father having periods of partial physical custody from Friday to Monday on alternating weekends during the school year, and week on/week off during the summer. 4. Father's position on custody is as follows: Father seeks shared legal custody and shared physical custody during the school year of Savhanna and one additional overnight on Father's alternating weekend schedule with Tristan during the school year. Father indicates that Savhanna has requested additional time with Father. Father asserts that he is a good parent to the children, prepared meals for them and assisted with homework when he was in the marital home. He agrees to transport the children to their activities although some were put into place by Mother without his consultation. 5. Mother's position on custody is as follows: Mother seeks to maintain the status quo but would agree to Father having additional time with the children during the school year several days per week after school. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing, and maintaining the status quo. It is expected that the Hearing will require one-half day. 7 � Date Jacckeline M. Verney, Esquire Custody Conciliator t w : KEVIN L. PAUL, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. SHELLY KAY PAUL, DEFENDANT 09-4634 CIVIL TERM ORDER OF COURT AND NOW, this 2`a 1 h day of August, 2013, the hearing currently scheduled for November 4, 2013 is cancelled and rescheduled to commence on Thursday, November 14, 2013, at 9:30 a.m., in Courtroom Number 4, Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, J �sley O , Jr., S.J. Jane Adams, Esquire For Kevin L. Paul ✓ Melissa P. Greevy, Esquire For Shelly Kay Paul :sal �T1 =M c z�n : co , 71 "O CC ) X CD C- l :.E --i N --C co _�F i 1 O THE PRO1HVN6ViARY 2013 AUG 30 AFB g. CUMBERLAND COUNTY PENNSYLVANIA KEVIN L. PAUL, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA '. vs. NO. 2009-4634-DV SHELLY KAY PAUL, DEFENDANT IN DIVORCE ENTRY OF APPEARANCE AS A SELF-REPRESENTED PARTY i 1. 1 am the ❑ Plaintiff [9 Defendant in the above-captioned(MARK ONE)9 custody,®divorce,❑ support, ❑ protection from abuse,❑ paternity case. 2. ❑ This(MARK ONE)❑ is ❑ is not a new case and I am representing myself in this case and have decided not to hire an attorney to represent me. OR(check only one box) ❑ This is NOT a new case and previously (Name of Attorney) represented me in this case. I have decided not to be represented`by that attorney and direct the Prothonotary to remove that attorney as my counsel of record in this case. I have provided a copy of this form to that attorney listed above at the following address: OR(check only one box) Q IR I am entering my appearance as a self-represented party(sign) My attorney acknowledges hi er al as attorney in this case. (Attorney signat . Esq. 3. My address for the purpose of receiving all future pleadings an other legal notices is:Go Van Milbrand,3 Lula Lane, Engle, PA 17025. 1 understand that this address will bet y address to which notices and pleadings in this case will be sent,and that I am responsible to regularly check my mail at this address to ensure that I do not miss important deadlines or proceedings. This is my home address. ❑ This is not my home address. 4. My telephone number where I can be reached during normal business hours(8:00 a.m.—4:30 p.m. Monday y—Friday) is,(717)307-8474. My email address is shellyCa)milbrand.com v?t - (OSa .3 I To X T4 S 3 ❑ My telephone number.and email address are confidential pursuant to a Protection From Abuse Order. 5. 1 UNDERSTAND I MUST FILE A NEW FORM EVERY TIME MY ADDRESS OR TELEPHONE NUMBER CHANGES. 6. 1 have provided a copy of this form to all other attorneys or other self-represented parties at the following addresses as listed below: (Use reverse side if you need more space) Name Jane Adams, Esquire Address 17 West South Street,Carlisle,PA 17013 Name Address I 4 7. 1 fully understand that by deciding to represent myself,the Court will hold me to the same standards of knowledge j regarding the statutory law,evidence law, Local and State Rules of Procedure and applicable case law as a I Pennsylvania licensed attorney,and that I must be fully prepared to meet those responsibilities. i I verify that the statements made in this Entry of Appearance as a Self-Represented Party are true and ' correct. I understand that if I make false statements herein, that I am subject to the criminal penalties of 18 Pa.C.S.§4904 relating to unsworn falsification to authorities which could result in a fine and/or prison term. i Date Shelly'VCV Pa fendant I i i I i I i e j I i i I I I I i j i t CERTIFICATE OF SERVICE AND NOW, this day of , 2013, the undersigned does hereby y ce rtify that she did this date serve a true and correct copy of the foregoing Entry of Appearance as a Self- Represented Party upon the counsel of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Jane Adams, Esquire 17 West South Street Carlisle, PA 17013 Counsel for Plaintiff JOHNSON, DUFFIE, STEWART&WEIDNER i Melissa P. Greevy i i :577215 i KEVIN L. PAUL, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVAIN 6 ` -vim ``' vs. : No. 2009 - 4634 Civil Term z r c cn SHELLY KAY PAUL, : CIVIL ACTION - LAW r - -. , Defendant IN CUSTODY ` `' MOTION FOR CONTINUANCE AND NOW comes the Plaintiff/Petitioner, Kevin L. Paul, by and through his attorney, Jane Adams, and respectfully represents the following: 1. Plaintiff is Kevin L. Paul. He is represented by Jane Adams, Esquire. 2. Defendant is Shelly Kay Paul. She is SELF-REPRESENTED. 3. The parties are the natural parents of two children, namely, Savhanna Paul, age 16, and Tristan Paul, age 12. 4. A hearing is set in this matter for November 14, 2013 before Judge Oler. 5. After communication with both parties, it appears that the parties are close to reaching a written agreement in this matter. 6. Plaintiff is requesting a continuance of the hearing scheduled for November 14, 2013, to allow more time to reach a written agreement. 7. Counsel for Plaintiff spoke with Defendant, who is self-represented on November 4, 2013 on the phone, and she indicated she would not object the hearing being cancelled or continued. 8. This matter was previously assigned to Judge Oler. 9. Plaintiff has not requested any other continuances in this matter. WHEREFORE, Plaintiff/Petitioner respectfully requests that the hearing date in this matter be continued. Respectfully submitted, Date: ( .. s---- t( /_rte , _ t Ja Adams, Esquire • 0. 79465 . South St. 'arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF Kevin L. Paul CERTIFICATE OF SERVICE AND NOW, this Novembert' ;2013, I, Jane Adams, Attorney for Father, Kevin L. Paul, hereby certify that a copy of Plaintiff's MOTION FOR CONTINUANCE has been duly served upon the Defendant by placing such in the custody of the United States Postal Service, via certified mail, postage pre-paid addressed to: Shelly Kay Paul 3 Lula Lane Enola, Pa. 17025 DEFENDANT/MOTHER 1111, A/4 F ne Adams, Esquire .D. No. 79465 / 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF • 1 6iC/ 1 1 KEVIN L. PAUL, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 2009 - 4634 Civil Term SHELLY KAY PAUL, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 120 Day of November, 2103, upon Plaintiff's Motion, the hearing currently scheduled for November 14, 2013, is continued to commence on ,.)"-e-"tkal 1 17 , 2014 at 1-31-) a.m./orrl, In Courtroom No. oZ-- Cumberland County Courthouse, Carlisle, Pa. 17013. • By the Court: d . J esley OI S.J. cc: "Ja Adams Es Esquire, for Plaintiff C) Shelly Kay Paul, Defendant -40 -.. 1 L r tor- N o '�-,- -+c) 'dc.' -o 7 /11413 pc) = r-� --/PY) 7".7:. *. ",-; —1 en 1 c7 KEVIN L. PAUL, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVAW {i+��.� W h` vs. : No. 2009 - 4634 Civil Term rte' 0' c SHELLY KAY PAUL, : CIVIL ACTION - LAW Defendant IN CUSTODY STIPUATION AND CUSTODY AGREEMENT 511‘AND NOW this Day of F, wy , 2011-this Stipulation and Custody Agreement is made between the parties, namely, Shelly Kay Paul, (hereinafter referred to as "Mother"), of Enola, Cumberland County, Pennsylvania, and Kevin L. Paul, (hereinafter referred to as "Father"), of Harrisburg, Dauphin County, Pennsylvania; WHEREAS, the parties are the natural parents of two children, namely, Savhanna Paul, born July 11, 1997; and Tristan Paul, born January 30, 2001; WHEREAS, Mother and Father have reached an agreement relative to the future care and custody of their children, the terms of which agreement both parties desire to set forth in the present Agreement, and; WHEREAS, Mother and Father desire the provisions of the present Agreement be approved by the Honorable Court of Common Pleas of Cumberland County and entered as a Court Order, with the same force and effect as though said Order had been entered after Petition, Notice and Hearing. There is a prior court Order in place addressing custody of the children, under the above-docket number which was entered on December 28, 2009. The parties agree as follows: 1. Legal Custody. Mother, Shelly Kay Paul, and Father, Kevin L. Paul, shall continue to share legal custody of their children, Savhanna Paul, born July 11, 1997; and Tristan Paul, born January 30, 2001. Both parties shall have the equal right to make and participate in all major decisions affecting their children's general well-being, including, but not limited to, all decisions regarding medical treatment, 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 child, including, but not limited to, medical, dental, religious, or school records, the residence address of the child and of 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. Each party shall notify the other of any medical, dental, optical and other appointments of a child with a healthcare provider, sufficiently in advance thereof so that the other party can attend. In the event of a medical emergency, the party with physical custody at the time shall make any emergency decisions, and shall promptly notify the other party as soon as practicable after the emergency is handled. 2. Physical Custody. The parties have agreed that physical custody of each child shall be as follows: a. Physical custody of Tristan Paul shall continue as provided by the schedule contained in the parties December 22, 2009 Stipulation and which was incorporated into the Order of December 29, 2009. Mother shall continue to have primary physical custody of Tristan, and Father shall have periods of physical custody of Tristan as provided by the stipulation and order, and additional times as the parties mutually agree. b. Beginning January 1, 2014, Physical custody of Savhanna Paul shall be shared by the parties on an equal basis, on a week on, week off schedule, with the exchanges to take place every Friday. During the school year, the party with custody shall drop the child off at school on Friday, and the party receiving custody shall make sure the child is picked up at school. c. Summer vacations. Mother has indicated that she may wish to take the children to her family reunion and on vacation over the summer. The parties will work together to accommodate these events. Mother shall provide Father with requested dates for additional summer events at least thirty (30) days before the requested event. In her request, Mother shall provide the dates, transportation arrangements, general itinerary, and contact information. Thereafter, the parties shall work together to agree on an amended schedule of physical custody to accommodate Mother's request; Father's consent for the children to attend such requested events with Mother over the summer shall not be unreasonably refused. Mother shall offer Father make-up time to compensate for any additional time she receives. d. All other provisions regarding physical custody, including the provisions regarding holidays and summer, contained in the Stipulation of December 22, 2009 shall remain in effect. However, upon the agreement of both parties, the terms of the stipulations and court order may be amended; the parties are encouraged to work together to come to mutual arrangements and agreements to benefit the children. 3. Extracurricular Activities. Each party will ensure that each child attends the extracurricular activities that the child is currently enrolled in, and shall provide transportation to the child's extracurricular activities during their period of physical custody. Neither party will sign a child up for additional extracurricular activities after the date of this stipulation without consulting the other parent. The parties will discuss dividing costs of any extracurricular activities. 4. Relocation. Pursuant to 23 Pa.C.S.§5337, which became effective January 22, 2011, no party shall be permitted to relocate the residence of the child which significantly impairs the other parties' ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed custody relocation or the court approves the proposed relocation in a court Order. A person proposing to relocate must comply with 23 Pa.C.S.§ 5337, and give notice under this section. 5. Factors and Best interest of the children. In ordering any form of custody, the court can determine the best interest of the children, by considering all relevant factors, including those listed in 23 Pa.C.S.§5328, giving weighted consideration to those that affect the safety of the child. The parties have considered all of the relevant factors, and have attempted to craft a custody agreement which provides for the best interest of the child or children. The parties understand that while this matter could be heard by the Court, they are not requesting a hearing or court intervention on this matter, at this time, as they have been able to reach an agreement beneficial to the children, and it is in the best interest of the children and the parties to resolve this matter without litigation and with minimal conflict. 6. Stipulation. This Stipulation is entered pursuant to an agreement of the parties. The parties agree that this stipulation may be incorporated as an Order of Court and may be enforceable as an Order of Court. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this agreement and Order shall control. The parties agree that the hearing which was previously scheduled in this matter may be cancelled. 7. Governing Law. This Agreement shall be governed and controlled by the laws of Pennsylvania. The parties consent to jurisdiction in Cumberland County, Pennsylvania. WITNESSETH: \\&,,,. % Ilk 1 Witness Shelly Kay ll •they Date:0k\C4) ,), \,0D\U\ (.--------5:::::)/ Witness Kevin L. Paul, Father Date: 2 / 5 f I Y • KEVIN L. PAUL, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIAN - : _.4 vs. . No. 2009-4634 Civil Term rn SHELLY KAY PAUL, : CIVIL ACTION-LAW �v en Defendant : IN CUSTODY �c -a r Pca p CRIMINAL RECORD I ABUSE HISTORY VERIFICATION �— :' - ., I, ►CE•V tN L• PA V L ,hereby swear or affirm, subject to penalties • of law including 18 Pa.C.S. § 4904 relating to unworn falsification to authorities that: 1. Unless indicated by my checking the box next to a crime below,neither I nor any other member of my household have been convicted or pled guilty or pled no contest or was adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act, 42 Pa.C.S. §6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges: Check Crime Self Other Date of Sentence All that household conviction, apply member guilty plea,no contest plea or pending charges _ 18 Pa.C.S. Ch. 25 ❑ ❑ (relating to criminal homicide) 18 Pa.C.S. §2702 ❑ ❑ (relating to aggravated assault) _ 18 Pa.C.S. §2706 ❑ ❑ (relating to terroristic threats) Check Crime Self/Other Date of Sentence All that household conviction, apply member guilty plea,no contest plea or pending charges 18 Pa.C.S. §2709.1 ❑ ❑ (relating to stalking) _ 18 Pa.C.S. §2901 ❑ ❑ (relating to kidnapping) _ 18 Pa.C.S. §2902 ❑ ❑ (relating to unlawful restraint) _ 18 Pa.C.S. §2903 ❑ ❑ (relating to false imprisonment) 18 Pa.C.S. §2910 ❑ ❑ (relating to luring a child into a motor vehicle or structure) _ 18 Pa.C.S. §3121 ❑ ❑ (relating to rape) _ 18 Pa.C.S. §3122.1 ❑ ❑ (relating to statutory sexual assault) _ 18 Pa.C.S. §3123 ❑ ❑ (relating to involuntary deviate sexual intercourse) 18 Pa.C.S. §3124.1 ❑ ❑ (relating to sexual assault Check Crime Self/Other Date of Sentence All that household conviction, apply member guilty plea,no contest plea or pending charges 18 Pa.C.S. §3125 ❑ ❑ (relating to aggravated indecent assault) 18 Pa.C.S. §3126 ❑ ❑ (relating to indecent assault) 18 Pa.C.S. §3127 ❑ ❑ (relating to indecent exposure) 18 Pa.C.S. §3129 ❑ ❑ • (relating to sexual intercourse with animals) _ 18 Pa.C.S. §3130 ❑ ❑ (relating to conduct Relating to sex offenders) 18 Pa.C.S. §3301 ❑ ❑ (relating to arson and relating offenses) 18 Pa.C.S. §4302 ❑ ❑ (relating to incest) 18 Pa.C.S. §4303 ❑ ❑ (relating to concealing death of child) 18 Pa.C.S. §4304 ❑ ❑ (relating to endangering welfare of children) 18 Pa.C.S. §4305 ❑ ❑ _ (relating to dealing in infant children) 18 Pa.C.S. §5902(b) ❑ ❑ (relating to prostitution and related offenses) 18 Pa.C.S. §5903(c) or ❑ ❑ (d)(relating to obscene and other sexual materials and performances) 18 Pa.C.S. §6301 ❑ ❑ (relating to corruption of minors) 18 Pa.C.S. §6312 ❑ ❑ (relating to sexual abuse of children) 18 Pa.C.S. §6318 ❑ ❑ (relating to unlawful contact with minors) .^ 18 Pa.C.S. §6320 ❑ ❑ (relating to sexual exploitation of children) .� 23 Pa.C.S. §6114 ❑ ❑ (relating to contempt for violation of protection order or agreement) Driving under the ❑ ❑ influence of drugs or alcohol Manufacture,sale, ❑ ❑ _ _ delivery,holding, offering for sale or possession of any controlled substance or other drug or device 2. Unless indicated by my checking the box next to an item below, neither I nor any other member of my household have a history of violent or abusive conduct including the following: Check Self Other Date all that household apply members A finding of abuse by Children&Youth ❑ ❑ Agency or similar agency in Pennsylvania or similar statute in another jurisdiction Abusive conduct as defined under the ❑ ❑ Protection from Abuse Act in Pennsylvania or similar statute in another jurisdiction Other: ❑ ❑ 3. Please list any evaluation,counseling or other treatment received following conviction • or finding of abuse: 4.If any conviction above applies to a household member,not a party,state that person's name,date of birth and relationship to the child. • 5.If you are aware that the other party or members of the other party's household has or have a criminal/abuse history,please explain: I verify that the information above is true and correct to the best of my knowledge, information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. fLPJ ne Date: 216 !y . vr&j L. PAVL Printed Name • 1 - 61e� f THE 231.4 FEB 12 AM 8: 53 CUMBERLAND COUNTY PENNSYLVANIA KEVIN L. PAUL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2009 - 4634 Civil Term SHELLY KAY PAUL, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this day f ff Y �e 1� . , 2014, having reviewed the agreement between the parties signed and dated the 5th day of February 2014, is hereby ORDERED and DECREED th"at.the attached stipulation shall be' entered and incorporated into this Order of Court. By the Court: cc.. �V�J/la— e Adams, Esquire, for Plaintiff Shelly Kay Paul, Defendant, self-represented �7 7 - .