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09-6173
n JAMIE SPANGLER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 01-6/73 SHAUN SPANGLER, : CIVIL ACTION - LAW Defendant : IN 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 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 Prothonotary, Carlisle, Pennsylvania. 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 32 South Bedford Street Carlisle PA 17013 (717) 249-3166 Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y pueda entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle PA 17013 (717) 249-3166 JAMIE SPANGLER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. . NO. p l? l 3 I SHAUN SPANGLER, : CIVIL ACTION - LAW Defendant : IN DIVORCE COUNTI COMPLAINT FOR DIVORCE UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE AND NOW, comes the above-named Plaintiff, Jamie Spangler, by her attorney, Mark A. Mateya, Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant upon the grounds hereinafter more fully set forth. 1. Plaintiff is Jamie Spangler, who is an adult individual who currently resides at 28 Sussex Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. All legal papers may be served on Plaintiff by service on her Attorney, Mark A. Mateya, Esquire with a mailing address of P.O. Box 127, Boiling Springs, PA 17007. 3. Defendant is Shaun Spangler, an adult individual who currently resides at 28 Sussex Road, Camp Hill, Cumberland County, Pennsylvania 17011. 4. Plaintiff and Defendant are bona fide residents of the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 5. The Plaintiff and Defendant were married on July 19, 2003, in Shiremanstown, Cumberland County, Pennsylvania. 6. There have been no prior actions of divorce or for annulment of marriage between the Parties in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. Neither the Plaintiff nor the Defendant are members of the armed services of the United States or any of its allies. 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. COUNT II CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER THE DIVORCE CODE 10. Plaintiff and Defendant are the owners of various items of real property, personal property, furniture and household furnishings that may be subject to equitable distribution by this Court. 11. Plaintiff and Defendant are the owners of various motor vehicles, bank accounts, investments, insurance policies and retirement benefits which may be subject to equitable distribution by this Court. WHEREFORE, Plaintiff requests the Court to enter a Decree: a. Dissolving the marriage between Plaintiff and Defendant; b. Equitably distributing all property owned by the parties hereto; C. In the event that a written Separation Agreement is reached between the parties hereto prior to the time of hearing on this Complaint, Plaintiff respectfully requests that pursuant to §304(a)(1) and (4) and §401(b) of the Divorce Code the Court approve and incorporate, but not merge such Agreement in the Final Divorce Decree; e. For such further relief as the Court may determine equitable and just. Respectfully submitted, Dated q-10-0q V/`4- A-. kA: By: Mark A. Mateya Attorney I.D. No. 78931 P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 Attorney for Plaintiff VERIFICATION I, Jamie Spangler, verify that the facts set forth in the foregoing Complaint for Divorce are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. DATED: v 2a Ja `ie Spangler 20 09 Sc' I I PIS 12: 4 2 i I 1 4 33 Sr. so ,; 4-Qv $ 4q ,so pd y ck ? 10 ? P-3 v c/? 7 JAMIE SPANGLER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. :NO. SHAUN SPANGLER, : CIVIL ACTION - LAW Defendant : IN 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 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 Prothonotary, Carlisle, Pennsylvania. 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 32 SOUTH BEDFORD STREET CARLISLE PA 17013 (717) 249-3166 Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y pueda entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CON15EGUIR ASISTENCIA LEGAL CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE PA 17013 (717) 249-3166 JAMIE SPANGLER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. © / - c? / 7 3 C t-v I SHAUN SPANGLER, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT FOR CUSTODY AND NOW, comes the above-named Plaintiff, Jamie Spangler, by her attorney, Mark A. Mateya, Esquire, and seeks to obtain custody of Dominic Spangler, age 3 years, born October 31, 2005. COUNT I - COMPLAINT FOR CUSTODY Plaintiff is Jamie Spangler, an adult individual who currently resides at 1006 East Coover Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. All legal papers may be served on Plaintiff by service on her Attorney, Mark A. Mateya, Esquire with a mailing address of P.O. Box 127, Boiling Springs, Pennsylvania 17007. 3. Defendant is Shaun Spangler, an adult individual who currently resides at 28 Sussex Road, Camp Hill, Cumberland County, Pennsylvania 17011. 4. Plaintiff and Defendant are bona fide residents of the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 5. Plaintiff seeks custody of DOMINIC SPANGLER, born 10/31/2005, (hereinafter the child), who currently resides at 28 Sussex Road, Camp Hill, Cumberland County, Pennsylvania. 6. The child was born in wedlock. 7. The child is presently in the custody of Plaintiff, Jamie Spangler and Defendant Shaun Spangler. 8. During the past five years the child has resided with the following persons at the following addresses: A. From Birth - to the present at 28 Sussex Road, Camp Hill, Pennsylvania, with Plaintiff and Defendant; B. For the past two months with Mother and Rebecca McClaughlin and Derek McClaughlin at 1006 East Coover Street, Mechanicsburg, Cumberland County, Pennsylvania. 9. The mother of the child is Jamie Spangler, and she has a present address of 1006 East Coover Street, Mechanicsburg, Cumberland County, Pennsylvania. 10. The father of the child is Shaun Spangler, and he has a present address of 28 Sussex Road, Camp Hill, Cumberland County, Pennsylvania. 11. The relationship of the Plaintiff to the child is that of natural mother. 12. The relationship of the Defendant to the child is that of natural father. 13. The Plaintiff has not participated as a party in any action brought by Defendant or any other persons relating to the custody of the child. 14. Plaintiff desires to have primary physical custody of the child with a reasonable custody schedule of shared physical custody with father. 15. The best interests and permanent welfare of the child will be served by granting the relief requested because: a. Plaintiff is the mother of the child; b. Plaintiff has been present in the life of the child since his birth; C. Plaintiff can continue to provide a stable home for the child; WHEREFORE, the Plaintiff requests this Honorable Court to issue a temporary Order granting Plaintiff full legal and physical custody of the child until further Order of this Court. Respectfully submitted, Mark A. Mateya Attorney I.D. No. 78931 P.O. BOX 127 Boiling Springs, PA 17007 (717) 241-6500 Date: q-10-09 Attorney for Plaintiff VERIFICATION I, Jamie Spangler, verify that the facts set forth in the foregoing Complaint for Custody are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. DATED: "? V ALED-- 2000, SEP I I PM Q: 4, 1 ti w i -Nr , V,; s 1 D$C- Od ?? a?Y G? ? ?Q ?. '?" ?d (05 -304177 JAMIE SPANGLER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. SHAUN SPANGLER DEFENDANT 2009-6173 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Tuesday, September 15, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at _ 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, October 06, 2009 at 1:30 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/ ac ueline M. Verne Es q- A W-11 Custody Conciliator 10, 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 OF THE P;- -'?,OTARY 2009 SCE' 16 PM 2: {1 awv- ? • / .. 1, ?? G ??? • JAMIE SPANGLER, Plaintiff PENNSYLVANIA VS. SHAUN SPANGLER, Defendant AND NOW, this 23 Attorney for Plaintiff, who, 1. A Complaint September 11, 2009. 2. On September Custody was sent to the Defe: pursuant to Pa. R.C.P. 1920.4. herein by reference. 3. On September 11, via first class mail, postage f Exhibit "B" and is : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, NO. 09-6173 CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF SERVICE day of September, 2009, comes Mark A. Mateya, Esquire, duly sworn according to law, deposes and says that: f Divorce and Custody was filed to the above term and number on 11, 2009, a certified copy of the Complaint for Divorce and ?dant via certified mail, restricted delivery, return receipt requested I See the Receipt attached hereto as Exhibit "A" and incorporated b009, a certified copy of the Complaint was sent to the Defendant epaid. A copy of the Certificate of Mailing is attached hereto as J herein by reference. 4. On or about 19, 2009, undersigned counsel for Plaintiff received the return receipt card signed by toe Defendant on September 18, 2009. Said receipt is attached hereto as Exhibit "A" and is i herein by reference. Respectfully submitted, Mark A. Mateya, squire Attorney I.D. No. 78931 P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 (717) 241-3099 Fax Attorney for Plaintiff I 41b CC) •• - m ? R 'AfF t 8th . f? Postage 4? $ ,? r-l Ce fled Fee C3 Return R ceipt Fee ?7. 11 C3 (Endorsement squired) 0, O Restricted ivery Fee (Endorsemen uired) , ? ® r-1 ? fly 39 . CO Total Posts & Fees r1J -a se"`Z ---------------- C3 or POBox N - Su dd. - --_------_ ?C? .----- '` an s??e. +4l?a M p l4 )LL PA 1101, ¦ Complete hems 1, 2, 3. Also complete Item 4 if Restricted Del Is desired, ¦ Print your name and ad rasa on the reverse so that we can return t card to you. ¦ Attach this card to the k of the mailpiece, or on the front if space its, 1. Article Addressed to: ??AWAA ? .v6,C Ek- a ,29 Su 55£ ICOAT> e?mP >y? LL -JO A I /r /6)/ 2. Article Number (rmmfw ft m servk e Ps Form 3811, Febn A. sI? X ecreWed by (Oe / C. D de of Dal iV ( q r D. Is delivery eddrosa df m Rem 1? ? Yes If YES, enter delivery address below: 0 No 3. Service lype V Certified Mail ? Express Mail 0 Registered ? Return Receipt for Merchandlee 0 Insured mail ? C.O.D. 1 4. Restricted DWWwy? (Extra Fee) Yes 7008 2810 0001 1660 1638 004 Domestic Return Receipt 102595-02-M-1540 V.J. rVJ,?r v?....?? MAY B USED FOR DOMESTI AND INTERNATIONAL MAIL, DOES N PROVIDE FOR INSURANCE- OSTMASTER Received From: ?o?L?,?? P.2?aJb:? PA 1'7001 One piece of ordinary mail addressed w 43 AAL uAJ 6 PA&6L.F-). GI o? s o m o Nb o T y o c m , mN 0 o N?= NY). O'9 Jz 0 v. A Z. 000 cP-6 --j .vim , (n oV , to z L-) CD"l w N m D PS Form 3817, Mar. 19$9 2009 OCT °6 P?l 1: 4 1 OCT 0 7 20096 JAMIE SPANGLER, Plaintiff V. SHAUN SPANGLER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-6173 CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 7 day of 6 Ckbi.u , 2009, upon consideration of the attached Custody Conciliation Report. it is ordered and directed as follows: 1. The Mother, Jamie Spangler and the Father, Shaun Spangler, shall have shared legal custody of Dominic Spangler, born October 31, 2005. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his 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 the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. The parties shall share physical custody of the child on the following schedule: A. Sunday overnight to Wednesday with Mother. B. Wednesday overnight to Saturday with Father. C. Alternating Saturday overnights to coincide with Father's work schedule. `I The parties shall have reasonable telephone contact with the child. 4. Neither party shall take the child outside of the Commonwealth of Pennsylvania without the express consent of the other parent with seventy-two (72) hours notice prior to the out of state visit. 5. Neither party shall make any disparaging remarks regarding the other party in the presence of the child. Additionally, neither party shall permit third persons to make disparaging remarks concerning the other party in the presence of the child. 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent in writing. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, .' cc: ark A. Mateya, Esquire, Counsel for /Shaun Spangler, pro se 28 Sussex Road J. Camp Hill, PA 17011 COP[ - ES moat Lf-CL, /v/s/07 `zrq JAMIE SPANGLER, Plaintiff V. SHAUN SPANGLER, Defendant PRIOR JUDGE: None 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 Child who is the subject of this litigation is as follows: NAME Dominic Spangler : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-6173 CIVIL ACTION - LAW IN CUSTODY DATE OF BIRTH CURRENTLY IN CUSTODY OF October 31, 2005 shared 2. A Conciliation Conference was held in this matter on October 6, 2009, with the following in attendance: The Mother, Jamie Spangler, with her counsel, Mark A. Mateya, Esquire, and the Father, Shaun Spangler, pro se. 3. The parties agreed to an Order in the form as attached. Date: 16) 6 Q Jac eline M. Verney, Esquire Custody Conciliator RLEG--s:l* r E 2009 OCT -8 AM g: 1 U t L ? lk'ti.l t ? ?'V; Date defendant's Waiver of Notice in §3301( c) Divorce was filed with the prothonotary: Simultaneously herewith Plaintiff has filed a Waiver of the Notice of Intention to Request Entry of A Divorce Decree. Mark A. Mateya quire P.O. BOX 127 Boiling Springs, PA 17007 (717) 241-6500 Attorney for Plaintiff JAMIE SPANGLER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLV ANIA C ' VS. NO. 09-6173 tom" r i : ? - T SHAUN SPANGLER, : CIVIL ACTION - LAW Defendant : IN DIVORCE 0-1 ;Z tv .x PRAECIPE TO TRANSMIT RECORD ac TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301 ( c) of the Divorce Code. 2. Date and manner of service of the complaint: By certified mail on or about September 18, 2009. 3. Complete either paragraph (a) or (b): (a) Date of execution of the affidavit of consent required by Section 3301(c) of ; the Divorce Code: by Plaintiff March 24, 2010 by Defendant March 24, (b)(1) Date of execution of the Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiffs affidavit upon the Defendant: 4. Related claims pending: None 5. (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintiffs Waiver of Notice in §3301( c) Divorce was filed with the prothonotary: simultaneously herewith. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jamie Spangler V. Shaun Spangler NO. 09-6173 DIVORCE DECREE AND NOW, CLo.?'/ ?Z zv 10 it is ordered and decreed that Jamie Spangler plaintiff, and Shaun Spangler bonds of matrimony. defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. The Marriage Settlement Agreement entered into by and between the parties is incorporated but not merged into the Divorce Decree. By the Court, n ;j ?- ? J. o-A)l PrIhonotary 4.15.1 0 Ce-c- - C N\Qo k.1 14. X3.10 IIJa-'t i cf.- McN ke. --o AA -bo --becq4-. ? C4-Lz JAMIE. SPANGLER, Respondent/Plaintiff v. SHAUN SPANGLER, Petitioner/Defendant § IN THE COURT OF COMMON PLEAS OF § CUMBERLAND COUNTY, PENNSYLVANIA § NO. 2009-6173 ~: ~r~~ -T' § CIVIL ACTION -CUSTODY -~~ ~ `~ s ' =_; § ~ -_W ':, ., -, =-, T ~, ~. _ - _ ~~ `; ~~ PETITION FOR MODIFICATION OF PARTIAL CUSTODY OR y ~-; ~. VISITATION ORDER PURSUANT TO 23 Pa.C.S. 5310 "~' AND NOW, comes the Petitioner, Shaun Spangler, by his attorney, Tanner Law Offices, LLC, and represents as follows: 1. Petitioner/ Defendant is Shaun Spangler, an adult individual currently residing at 246 Cumberland Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Respondent/ Plaintiff is Jamie Spangler, an adult individual currently residing at 285 D West Cabin Hollow Road, Dillsburg, Pennsylvania 17019. 3 . The parties are the parents of one minor child, Dominic Spangler, born October 31, 2005. 4. On October 7, 2009, an Order of Court was entered for Custody, a copy of which is attached hereto as Exhibit "A". The Order memorialized the agreement the parties reached at a custody conciliation, on October 6, 2009. 5. The Order granted the parties joint legal and physical custody of the child. Specifically, the physical custody schedule as set forth in the Order is as follows: The child is with Petitioner every Wednesday overnight to Saturday, ~$3, mid (~~ a~~ ~ '~~~S31a~ with Respondent every Sunday overnight to Wednesday, and the child alternates Saturday overnights between the parties. 6. Petitioner has had a drug and alcohol problem for which he has successfully completed an inpatient rehabilitation program. 7. During Petitioner's treatment, the parties had agreed that Petitioner would have limited contact with the child. 8. Petitioner has been clean and sober for more than a year. Respondent has refused to allow Petitioner any expanded visitation with the child. All visitation has been extremely limited and is at the discretion of Respondent. 9. Respondent has failed to comply with the terms of the October 7, 2009, Order regarding legal custody. For example, Respondent has refused to share critical information regarding the child's medical care and education with Petitioner, including a recent in-patient admission at Penn State Hershey Medical Center. 10. Respondent speaks negatively about Petitioner in front of the child and puts the child in the middle of the custody dispute by yelling to Petitioner in front of the child, "Dominic doesn't want you here! I don't want you here," and by communicating custody matters through the child. 11. Respondent monitors all phone contact between Petitioner and the child, limiting the child's ability to freely and openly communicate with Petitioner. 12. This Order should be modified to provide Petitioner with meaningful time with the child. The requested modification is in the best interest of the child. WHEREFORE, Petitioner requests that the Court modify the existing order for Custody because it will be in the best interest of the child. Respectfully submitted, /~a ~`t, Tabetha A. Tanner, Esquire Supreme Court I.D. No.: 91979 Attorney for Petitioner/Defendant TANNER LAW OFFICES, LLC 3507 Market Street, Suite 303 Camp Hill, PA 17011 (717) 731-8114 VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that false statements made herein may subject me to penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: ~'('• ~~ Sh n pa er OCT C 7 2009 JAMIE SPANGLER, Plaintiff V. SHAUN SPANGLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2009-6173 CIVIL ACTION -LAW IN CUSTODY ORDER OF COURT AND NOW, this ~ ~ day of D c~i~e+ , 2009, upon consic~Prasi~n ~f the attached Custody Conciliation Report. it is ordered and directed as follow s: 1. The Mother, Jamie Spangler and the Father, Shaun Spangler, shall have shared legal custody of Dominic Spangler, born October 31, 2005. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regazding his 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 the other parent. To the extent one pazent has possession of any such records or information, that pazent shall be required to shaze the same, or copies thereof, with the other pazent within such reasonable time as to make the records and information of reasonable use to the other parent. Both pazents shall be entitled to full participation in all educational and medicaUtreatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as pazents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. The parties shall share physical custody of the child on the following schedule: A. Sunday overnight to Wednesday with Mother. B. Wednesday overnight to Saturday with Father. C. Alternating Saturday overnights to coincide with Father's work schedule. Exhibit "A" 3. The parties shall have reasonable telephone contact with the child. 4. Neither party shall take the child outside of the Commonwealth of Pennsylvania without the express consent of the other parent with seventy-two (72) hours notice prior to the out of state visit. 5. Neither party shall make any disparaging remarks regazding the other party in the presence of the child. Additionally, neither party shall permit third persons to make disparaging remarks concerning the other party in the presence of the child. 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent in writing. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, ~1 .~ cc:~vlark A. Mateya, Esquire, Counsel for /Shaun Spangler, pro se 28 Sussex Road Camp Hill, PA 17011 f. e © i'ES' m~ l: f £c~i 1o~Slo~ ~~ J. c: C`~ C.r r-~ ~_~ ....{ JAMIE SPANGLER IN THE COURT OF COMMON PLEAS OF~~ ~ ~ `"'~ „ - ~~ r*i c~ ~ - ..~ t : . PLAINTIFF CUMBERLAND COUNTY, PENNSYLVAI ~ , ~ -~ <<~ ,~ ~ ~~ c y c= ~.,. _ ~-, -~-, ~' 2009-6173 CIVIL ACTION LAW ~'" ""' ~ # ~> SHAUN SPANGLER ~m`• v~i ;. IN CUSTODY ' DEFF,NDANT ORDER OF COURT AND NOW, Wednesday, November 21, 2012 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, December 12, 2012 at 8:30 A~ for aPre-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/ Jacqueline M. Yerney, EsgV/.~ 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 f ~~ Telephone (717) 249-3166 o ~/~ ~p~C i ~ia7~f" ~~~~ G~Z JAMIE SPANGLER, Plaintiff V. SHAUN SPANGLER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-6173 CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this / i' day of )k&I2At , 2012, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The prior Order of Court dated October 7, 2009 is hereby vacated. 2. The Father, Shaun Spangler and the Mother, Jamie Spangler, shall have shared legal custody of Dominic Spangler, born October 31, 2005. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his 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 the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. During the school year: A. Mother shall have primary physical custody of the child. B. Father shall have periods of partial physical custody every Wednesday from 5:00 p.m. to 7:30 p.m. Should Father's work schedule change to make the Wednesday night visits impracticable, the parties shall cooperate to ensure that Father exercises custody at least one evening per week. Father shall provide both ends of the transportation for this custodial period. C. Father shall have periods of partial physical custody on alternating weekends from Friday after school until Sunday at 7:30 p.m. Mother shall drop off at Father's home on Fridays and Father shall drop off the child at Mother's home on Sundays. Should a school holiday fall on a Monday following Father's weekend and Father also has that day off from work, Father's weekend shall be extended to include that Monday holiday until 7:30 p.m. Father's alternating weekend schedule shall coincide with his weekend work schedule. 4. During the summer: A. Mother shall have primary physical custody. B. Father shall have periods of partial physical custody on an alternating week schedule. For Week one, Father shall have physical custody from Wednesday at 10:30 a.m. to Sunday at 7:30 p.m. For Week two, Father shall have physical custody from Wednesday at 10:30 a.m. to Thursday at 7:30 p.m., to coordinate with Father's work schedule. 5. Holidays shall take precedence other the regular schedule: A. Christmas: For 2012 and all even numbered years thereafter, Father shall have physical custody of the child on Christmas A, defined as: December 24 at 7:30 p.m. to December 25 at 3:00 p.m. Mother shall have physical custody on Christmas B, defined as December 25 at 3:00 p.m. until December 26 at 10:30 a.m. In 2013 and all odd numbered years thereafter, Mother shall have Christmas A and Father shall have Christmas B. B. New Year's: for 2012 and all even numbered years thereafter, Mother shall have custody of the child from December 31, at 3:00 p.m. to January 1 at 3:00 p.m. For 2013 and all odd numbered years thereafter, Father shall have custody of the child on December 31, at 3:00 p.m. to January 1 at 3:00 p.m. C. Easter shall be divided 9:00 a.m. to 3:00 p.m. and 3:00 p.m. to 9:00 p.m. Father shall always have the earlier time and Mother shall always have the later time. D. Memorial Day. In 2013 and all odd numbered years thereafter, Mother shall have custody of the child on Memorial Day. In 2014 and all even numbered years thereafter, Father shall have custody of the child on Memorial Day. The times shall be from 9:30 a.m. to 7:30 p.m. E. Labor Day: In 2013 and all odd numbered years thereafter, Father shall have custody of the child on Memorial Day. In 2014 and all even numbered years thereafter, Mother shall have custody of the child on Memorial Day. The times shall be from 9:30 a.m. to 7:30 p.m. F. Independence Day. In 2013 and all odd numbered years thereafter, Mother shall have custody of the child on July 41h from 10:30 a.m. until July 5 at 7:30 p.m. In 2014 and all even years thereafter, Father shall have custody of the child on July 4 at 10:30 a.m. until July 5 at 7:30 p.m. G. Halloween/Child's Birthday: In 2013 and all odd numbered years thereafter, Father shall have custody of the child from after school until 8:00 p.m. if it falls on a school day and from 9:30 a.m. until 7:30 p.m. if it falls on a weekend. In 2014 and all even years thereafter, Mother shall have custody of the child from after school until 8:00 p.m. if it falls on a school day and from 9:30 a.m. to 7:30 p.m. if it falls on a weekend. H. Thanksgiving: Every year, Father shall have custody of the child from Thanksgiving Eve from after school until Thanksgiving Day at 3:00 p.m. Mother shall have custody of the child from Thanksgiving Day at 3:00 p.m. until the Friday after Thanksgiving until 10:30 a.m. 1. Vacation. Each party shall have two non-consecutive weeks during the year provided they give the other party 30 days prior notice. Said weekends shall coincide with the party's regularly scheduled weekend. b. Telephone calls: When the child is in the other parent's custody, the non- custodial parent shall be afforded reasonable, unmonitored phone calls. The child shall be permitted to speak to the non-custodial parent in a private space which is not on speaker-phone and in which the custodial parent and/or members of his or her household do not listen on the child's extension and/or on any additional telephone extensions. Should the custodial parent miss a call from the non-custodial parent, the custodial parent shall ensure that the child returns the phone call within 2 hours of the missed call. 7. Medical/Emergency: Should a medical or emergency situation arise with the child, the custodial parent at that time shall immediately contact the other parent to share the medical or emergency situation and shall encourage that parent's participation at the medical or emergency event. 8. School/Emergency Contact: Within five (5) days of this Order, Mother shall sign all necessary :releases and documentation to inform the child's school that Father is an emergency contact for the child and is authorized to pick up from school. 9. Custodial exchanges: During the custodial exchanges, the parents' respective significant others shall remain in their vehicles. 10. Neither party shall make any disparaging remarks regarding the other party in the presence of the child. Additionally, neither party shall permit third persons to make disparaging remarks concerning the other party in the presence of the child. 11. Neither party shall take the child outside of the Commonwealth of Pennsylvania without the express consent of the other parent with seventy-two hours notice prior to the out of state visit. 12. Neither party may partake in illegal drugs or alcohol to the point of intoxication immediately before or during their period of physical custody. 13. RELOCATION: No party shall be permitted to relocate the residence of the child which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation or the court approves the proposed relocation. A person proposing to relocate MUST comply with 23 Pa. C. S. § 5337. 14. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent in writing. In the absence of mutual consent, the terms of this Order shall control. cc Tabetha A. Tanner, Esquire, Counsel Jamie Spangler, pro se 285 D. West Cabin Hollow Road Dillsburg, PA 17019 C??il'S RIA c? BY THE COURT, JAMIE SPANGLER, Plaintiff V. SHAUN SPANGLER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-6173 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Kevin A. Hess, P.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 Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Dominic Spangler October 31, 2005 Mother 2. A Conciliation Conference was held in this matter on December 13, 2012, with the following in attendance: The Father, Shaun Spangler, with his counsel, Tabetha A. Tanner, Esquire and the Mother, Jamie Spangler, pro se, by telephone counsel. 3. The Honorable Kevin A. Hess, P.J. previously entered an Order of Court dated October 7, 2009 providing for shared legal and shared physical custody. 4. The parties agreed to an Order in the form as attached. Date: / - /3 -/ ?- a eline M. Verney, EsquireJ? v Custody Conciliator JAMIE SPANGLER, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA v. § NO 2009-6173 CIVIL ACTIf ITT § SHAUN SPANGLER, § CIVIL ACTION - IN DIVOR ' ` --Y Defendant - ' - PETITION FOR MODIFICATION OF PARTIAL CUSTODY OR` VISITATION ORDER PURSUANT TO 23 Pa.C.S. 5310 AND NOW, comes the Petitioner, Shaun Spangler, by his attorney, Tanner Law Offices, LLC, and represents as follows: 1. Petitioner, Shaun Spangler, is an individual currently residing at 246 Cumberland Road, Camp Hill, Cumberland County, Pennsylvania. 2. Respondent, Jamie Spangler, is an adult individual currently residing at 285 D West Cabin Hollow Road, Dillsburg, York County, Pennsylvania. 3. Petitioner respectfully represents that on December 19,2012,an Order of Court was entered in Cumberland County regarding custody of the parties' child, Dominic Spangler, born October 31, 2005. (Attached hereto as Exhibit "A") 4. Petitioner seeks an increase in custodial time with the parties' son. 5. Respondent has recently filed for disability, indicating that she is frequently dizzy and is unable to work due to undifferentiated connective tissue disease. 6. Petitioner believes that Respondent's medical condition, which leaves her unable to work, also renders her unable to be the primary caretaker of an active 8 year old child to the extent that she is currently. 453.00 ry, €4 €4i 304/ A' 29c )1i 7. Petitioner works from 8:00 P.M. until 8:00 A.M. on Monday and Tuesday nights, and every other Friday though Sunday night. It is in the best interest of the child that the custody schedule be modified so that Petitioner has custody of the child on all days that he is not working overnights. In other words, Petitioner seeks custody of the child every Wednesday through Friday on Week 1, and Wednesday through Sunday on Week 2. 8. It is in the best interest of the child that Petitioner take the child to his boy scout meetings every Sunday. WHEREFORE, Petitioner requests that the Court modify the existing order for Custody because it will be in the best interest of the child. Respectfully submitted, -7 va 4. - , Tabetha A. Tanner, Esquire Supreme Court I.D. No.: 91979 Attorney for Petitioner/Defendant TANNER LAW OFFICES, LLC 3507 Market Street, Suite 303 Camp Hill, PA 17011 (717) 731-8114 VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that false statements made herein may subject me to penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. �i 4 Zo(3 Date: ��_��j-- Shaun pangler JAMIE SPANGLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-6173 CIVIL ACTION - LAW SHAUN SPANGLER, Defendant : IN CUSTODY ORDER OF COURT AND NOW,this /i '‘1 day of A.)eitheei , 2012, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated October 7,2009 is hereby vacated. 2. The Father, Shaun Spangler and the Mother, Jamie Spangler, shall have shared legal custody of Dominic Spangler,born October 31, 2005. Each parent shall have an equal right,to be exercised jointly with the other parent,to make all major non- emergency decisions affecting the Child's general well-being including,but not limited to, all decisions regarding his 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 the other parent. To the extent one parent has possession of any such records or information,that parent shall be required to share the same,or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist,teacher or authority and copies of any reports given to them as parents including,but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 3. During the school year: A. Mother shall have primary physical custody of the child. B. Father shall have periods of partial physical custody every Wednesday from 5:00 p.m. to 7:30 p.m. Should Father's work schedule change to make the Wednesday night visits impracticable, the parties shall cooperate to ensure that Father exercises custody at least one evening per week. Exhibit "A" Father shall provide both ends of the transportation for this custodial period. C. Father shall have periods of partial physical custody on alternating weekends from Friday after school until Sunday at 7:30 p.m. Mother shall drop off at Father's home on Fridays and Father shall drop off the child at Mother's home on Sundays. Should a school holiday fall on a Monday following Father's weekend and Father also has that day off from work, Father's weekend shall be extended to include that Monday holiday until 7:30 p.m. Father's alternating weekend schedule shall coincide with his weekend work schedule. 4. During the summer: A. Mother shall have primary physical custody. B. Father shall have periods of partial physical custody on an alternating week schedule. For Week one, Father shall have physical custody from Wednesday at 10:30 a.m. to Sunday at 7:30 p.m. For Week two, Father shall have physical custody from Wednesday at 10:30 a.m. to Thursday at 7:30 p.m., to coordinate with Father's work schedule. 5. Holidays shall take precedence other the regular schedule: A. Christmas: For 2012 and all even numbered years thereafter, Father shall have physical custody of the child on Christmas A, defined as: December 24 at 7:30 p.m. to December 25 at 3:00 p.m. Mother shall have physical custody on Christmas B, defined as December 25 at 3:00 p.m. until December 26 at 10:30 a.m. In 2013 and all odd numbered years thereafter, Mother shall have Christmas A and Father shall have Christmas B. B. New Year's: for 2012 and all even numbered years thereafter, Mother shall have custody of the child from December 31, at 3:00 p.m. to January 1 at 3:00 p.m. For 2013 and all odd numbered years thereafter, Father shall have custody of the child on December 31, at 3:00 p.m. to January 1 at 3:00 p.m. C. Easter shall be divided 9:00 a.m. to 3:00 p.m. and 3:00 p.m. to 9:00 p.m. Father shall always have the earlier time and Mother shall always have the later time. D. Memorial Day. In 2013 and all odd numbered years thereafter, Mother shall have custody of the child on Memorial Day. In 2014 and all even numbered years thereafter, Father shall have custody of the child on Memorial Day. The times shall be from 9:30 a.m. to 7:30 p.m. E. Labor Day: In 2013 and all odd numbered years thereafter, Father shall have custody of the child on Memorial Day. In 2014 and all even numbered years thereafter, Mother shall have custody of the child on Memorial Day. The times shall be from 9:30 a.m. to 7:30 p.m. F. Independence Day. In 2013 and all odd numbered years thereafter, Mother shall have custody of the child on July 4th from 10:30 a.m. until July 5 at 7:30 p.m. In 2014 and all even years thereafter, Father shall have custody of the child on July 4 at 10:30 a.m. until July 5 at 7:30 p.m. G. Halloween/Child's Birthday: In 2013 and all odd numbered years thereafter, Father shall have custody of the child from after school until 8:00 p.m. if it falls on a school day and from 9:30 a.m. until 7:30 p.m. if it falls on a weekend. In 2014 and all even years thereafter, Mother shall have custody of the child from after school until 8:00 p.m. if it falls on a school day and from 9:30 a.m. to 7:30 p.m. if it falls on a weekend. H. Thanksgiving: Every year, Father shall have custody of the child from Thanksgiving Eve from after school until Thanksgiving Day at 3:00 p.m. Mother shall have custody of the child from Thanksgiving Day at 3:00 p.m. until the Friday after Thanksgiving until 10:30 a.m. I. Vacation. Each party shall have two non-consecutive weeks during the year provided they give the other party 30 days prior notice. Said weekends shall coincide with the party's regularly scheduled weekend. 6. Telephone calls: When the child is in the other parent's custody, the non- custodial parent shall be afforded reasonable, unmonitored phone calls. The child shall be permitted to speak to the non-custodial parent in a private space which is not on speaker-phone and in which the custodial parent and/or members of his or her household do not listen on the child's extension and/or on any additional telephone extensions. Should the custodial parent miss a call from the non-custodial parent, the custodial parent shall ensure that the child returns the phone call within 2 hours of the missed call. 7. Medical/Emergency: Should a medical or emergency situation arise with the child, the custodial parent at that time shall immediately contact the other parent to share the medical or emergency situation and shall encourage that parent's participation at the medical or emergency event. 8. School/Emergency Contact: Within five (5) days of this Order, Mother shall sign all necessary releases and documentation to inform the child's school that Father is an emergency contact for the child and is authorized to pick up from school. 9. Custodial exchanges: During the custodial exchanges, the parents' respective significant others shall remain in their vehicles. 10. Neither party shall make any disparaging remarks regarding the other party in the presence of the child. Additionally, neither party shall permit third persons to make disparaging remarks concerning the other party in the presence of the child. 11. Neither party shall take the child outside of the Commonwealth of Pennsylvania without the express consent of the other parent with seventy-two hours notice prior to the out of state visit. 12. Neither party may partake in illegal drugs or alcohol to the point of intoxication immediately before or during their period of physical custody. 13. RELOCATION: No party shall be permitted to relocate the residence of the child which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation or the court approves the proposed relocation. A person proposing to relocate MUST comply with 23 Pa. C. S. § 5337. 14. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent in writing. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, /51 f-.Cll," J .4160 J. cc: Tabetha A. Tanner, Esquire, Counsel for Father Jamie Spangler,pro se 285 D. West Cabin Hollow Road Dillsburg, PA 17019 ,1,r or— r1/43 Cs; r_ 6�G -�' r- co TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said Co at Carlisle, Pa. This < L,, day of r'_- 70 Pr orh/o0not.ary "-xt 9y7/ Jamie Spangler IN THE COURT OF COMMON PLEAS PLAINTIFF Cumberland County, Pennsyl ania vs. Na 2009-6173 Civil Shaun Spangler CZ » DEFENDANT CIVIL ACTION -CUSTODY rncn E� �c�o CRIMINAL RECORD REC�D/ABUSE HISTORY VERIFICATION mr — � c�` Shaun Spangler - r--� r |. . hereby swear or affirm, mutdect�ic: , .� z~�� PRINT NAME r- _ > • pmnab�oo[�windud�Q1GPaI.S.§4804,o�0nQhounmvwornfa|o�cabonUoou1huhUesthat �- ' �� 1. Unless indicated by my checking the "YES" box next to a crime below, neither I nor any othe member of my household have been convicted or pled guilty or pled no contest or was adjudicated delinquen 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: Answer Crime Self Other Date of convIction, Sente e Yes or No household guilty plea,no contest member plea or pendIng charges YES NO CI [29 18 Pa.C.S. Ch.25 Fl Fl (relating to criminal homicide) O NI 18Pa.C.8. §2702 (relating to aggravated assault) O El 18Pa.C.S.§2706 Fl CI (relating to terroristic threats) [] �� 18 Pa.C.S.§2709.1 0 �] . (relating to stalking) CI El 18Po.C.S. §2901 1:1 (relating to kidnapping) O El 18Pa.O.S.§2902 0 0 (relating to unlawful restraint) [] El 18Po.C.S.§2903 (relating to false imprisonment) 9-3-13 Answer Crime Self Other Date of conviction, Sentens.e Yes or No household guilty plea,no contest member plea or pending charges YES NO ❑ ® 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) El ® 18 Pa.C.S.§3123 ❑ El (relating to involuntary deviate sexual intercourse) ❑ ® 18 Pa.C.S.§3124.1 ❑ ❑ (relating to sexual assault) ❑ ® 18 Pa.C.S. §3125 ❑ ❑ (relating to aggravated indecent assault) ❑ ® 18 Pa.C.S.§3126 ❑ ❑ (relating to indecent assault) ❑ ® 18 Pa.C.S. §3127 ❑ El (relating to indecent exposure) ❑ ® 18 Pa.C.S.§3129 ❑ ❑ (relating to sexual intercourse with animal) ❑ N 18 Pa.C.S.§3130 ❑ ❑ (relating to conduct relating to sex offenders) 9-3-13 Answer Crime Self Other Date of conviction, Senten Yes or No household guilty plea,no contest member plea or pending charges YES NO ❑ ® 18 Pa.C.S. §3301 ❑ 0 (relating to arson and related 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&other sexual materials& performances) ❑ ® 18 Pa.C.S.§6301 ❑ ❑ (relating to corruption of minors) ❑ ® 18 Pa.C.S. §6312 ❑ ❑ (relating to sexual abuse of children) ❑ M 18 Pa.C.S. §6318 ❑ ❑ (relating to unlawful contact with minor) 9-3-13 Answer Crime Self Other Date of conviction, Senten. Yes or No household guilty plea,no contest member plea or pending charges YES NO El ® 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 ® ❑ 9/11/2012 72hrs-6 mths drugs or alcohol confinement/d g/alcohol evaluation ❑ ® 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"YES"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: Answer Self Other D. e Yes or No household member YES NO ❑ ® A finding of abuse by a 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: ❑ ❑ 9-3-13 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: Psychological Evaluation completed by Riegler Shienvold &Associates on December 27, 2012 indicating that Mr. Spangler"presents a low probability of risk at this time with respect to allowing alcohol or drug abuse to interfere with his judgment in caring for his son, Dominic." 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: N/A I verify that the statements made in the Criminal Record/Abuse History Verification are true and correct to the best of my knowledge, information and 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 and can be punishable by fine or imprisonment. di* *1►■ Signature OF Shaun Spangler Printed Name 9-3-13 JAMIE SPANGLER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 2009-6173 CIVIL ACTION LAW 2 ' SHAUN SPANGLER m o• IN CUSTODY DEFENDANT ;rn ORDER OF COURT • AND NOW, Friday,October 04,2013 , upon consideration of the attached CBrnplaat, ipis hereby directed that parties and their respective counsel appear before Jacqueline M. Verney,Esq. , the conciliator, at 4th Floor,Cumberland County Courthouse,Carlisle on Wednesday,November 13,2013 10:30 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. You must file with the Court a verification regarding any criminal record or abuse history regarding you and anyone living in your household on or before the initial in-person contact with the court(including, but not limited to, a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition. No party may make a change in the residence of any child which significantly impairs the ability of the other party to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and Pa.R.C.P. No. 1915.17 regarding relocation. FOR THE COURT, By: Is/ ,Jacqueline M. Verney, Esq,�/ Custody Conciliator �� The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR 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 Qp j 1'c3 ivz l 32 South Bedford Street n , Carlisle, Pennsylvania 17013 194 �, � � Telephone (717) 249-3166 i , 194-1-y Oca_Lsty lc)/40, l , JAMIE SPANGLER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2009-6173 CIVIL ACTION—LAW c'a , SHAUN SPANGLER, : .1N CUSTODY -0Z w --- Defendant : - c -71 -ter cnr- PRAECIPE FOR ENTRY OF APPEARANCE To David D. Buell, Prothonotary: Please enter my appearance on behalf of the Plaintiff, Jamie Spangler, in the above captioned case. Respectfully submitted, /41111. tab" %UM Jessica Holst, Esqui MidPenn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 Date: `\ `" JAMIE SPANGLER, . : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2009-6173 CIVIL ACTION—LAW SHAUN SPANGLER, : IN CUSTODY Defendant CERTIFICATE OF SERVICE I, Jessica Ho1st, Esquire, of MidPenn Legal Services, attorney for the Plaintiff, Jamie Spangler,hereby certify that I have served a copy of the foregoing PRAECIPE FOR ENTRY OF APPEARANCE by personally handing it to: Tabetha A. Tanner, Esquire Tanner Law Offices, LLC 3507 Market Street, Suite 303 Camp Hill, PA 17011 Date: \\ kel• 3 �k``t'��+ Jess ca Holst, Esquire MidPenn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 JAMIE SPANGLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2009-6173 CIVIL TERM • SHAUN SPANGLER, • Defendant : CUSTODY L71 c, r~� r r---;" I c a CRIMINAL RECORD/ABUSE HISTORY VERIFICATION >c-a c I (�,� � < 11 f, hereby swear or affirm, subject to penalties of la` v <.4 including 18 Pa.C.S. § 4904 relating to unsworn 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 conviction, Sentence all that household guilty,plea, no apply member 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) ❑ 18 Pa.C.S. § 2709.1 ❑ ❑ (relating to stalking) Check Crime Self Other Date of conviction, Sentence all that household guilty plea,no apply member contest plea or pending charges ❑ 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) 1 Check Crime Self Other Date of conviction, Sentence all that household guilty plea, no apply member 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) El 18 Pa.C.S. § 3129 ❑ ❑ (relating to sexual intercourse with animal) ❑ 18 Pa.C.S. § 3130 ❑ ❑ (relating to conduct relating to sex offenders) ❑ 18 Pa.C.S. § 3301 ❑ ❑ (relating to arson and related offenses) ❑ 18 Pa.C.S. § 4302 ❑ ❑ (relating to incest) ❑ 18 Pa.C.S. § 4303 ❑ ❑ (relating to concealing death of child) • Check Crime Self Other Date of conviction, Sentence all that household guilty plea, no apply member contest plea or pending charges ❑ 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(b)/(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 ❑ ❑ trelating to unlawful contact with minor) ❑ 18 Pa.C.S. § 6320 ❑ ❑ (relating to sexual exploitation of children1 Check Crime Self Other Date of conviction, Sentence all that household guilty plea, no apply member contest plea or pending charges ❑ 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 member ❑ A finding of abuse by a Children& ❑ ❑ Youth Agency or similar agency in Pennsylvania or similar statute in another jurisdiction ❑ Abusive conduct as defined under the ❑ El Protection from Abuse Act in Pennsylvania or similar statute in another jurisdiction Check Self Other Date all that household apply member ❑ Other: ❑ LI 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 member o the other party's household has or have a criminal/abuse history,please explain: ' - / C.1�) �- a a 1 (YI J 4/p , 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. ter ,, ,rte Signature L (44 uy- Printed Name 11 �/9/6 Date s JAMIE SPANGLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-6173 CIVIL ACTION-LAW SHAUN SPANGLER, Defendant : IN CUSTODY ORDER OF COURT AND NOW,this day of �. co�c/ , 2013, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A pretrial conference with the assigned Judge is hereby scheduled in the above case on the X IQ day of 4 , 201 at 30 cam. in courtroom number S' of the Cumb rland County Courthouse. The parties are directed to proceed with filing a pretrial statement with the Court and the other party consistent with the Pennsylvania Rule of Civil Procedure 1915.4-4. 2. A Hearing is scheduled in Court Room No. , of the Cumberland County Court House, on the q�6t day of _, 201 , at 2,'3 O o'clock,-,4-. M., at which time testimony will be taken. For purposes of this Hearing, Father shall be deemed to be the moving party and shall proceed initially with testimony. 2. Pending the hearing,the prior Order of Court of the Honorable Kevin A. Hess dated December 19, 2012 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, QD J. cc: etha Tanner, Esquire, Counsel for Father ✓Jessica Holst, Esquire, MidPenn Legal Services, Counsel for Mother w -es tmfyl JAMIE SPANGLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. : NO. 2009-6173 CIVIL ACTION -LAW SHAUN SPANGLER, Defendant : IN CUSTODY PRIOR JUDGE: Kevin A. Hess, P.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 Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Dominic Spangler October 31, 2005 Mother 2. A Conciliation Conference was held in this matter on November 19, 2013, with the following in attendance: The Father, Shaun Spangler, with his counsel, Tabetha Tanner, Esquire, and the Mother, Jamie Spangler, with her counsel, Jessica Holst, Esquire, MidPenn Legal Services. 3. The Honorable Kevin A. Hess previously entered an Order of Court dated December 19, 2012 providing for shared legal custody, Mother having primary physical custody and Father having periods of partial physical custody every Wednesday evening and alternating weekends Friday to Sunday. Father filed a Petition to Modify to increase his overnight during the school year to 6 out of 14. 4. Father's position on custody is as follows: Father seeks shared legal custody and partial physical custody, on Week 1 Wednesday to Friday and Week 2 Wednesday to Sunday to coincide with this work schedule. Father asserts that he is a nurturing, loving Father who can properly care for the child. He further asserts that Mother is seeking disability claiming she is dizzy and unable to work, which impedes her ability to care for the child. 5. Mother's position on custody is as follows: Mother seeks to maintain the status quo,but is willing for Father's alternating weekends to be extended to Mondays. Mother has concerns about Father properly supervising the child's homework. Mother denies being physically unable to care for the child. 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. Date acqtQline M. Verney, Esquire Custody Conciliator TANNER BARCAVAGE, LLC 3507 Market Street, Suite 303 i ;:: ► 7 { Camp Hill, PA 17011 Li 1 , Eit tyiti Phone: (717) 731-8114 :�. � � - ,� iI Fax (717) 731-8115 JAMIE SPANGLER, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA v. § NO. 2009-6173 CIVIL ACTION LAW SHAUN SPANGLER, § CIVIL ACTION - IN DIVORCE Defendant § DEFENDANT'S PRE-TRIAL STATEMENT AND NOW COMES the Defendant, Shaun Spangler, by his attorney, Tabetha A. Tanner, Esquire, and respectfully submits the following in reference to the Order dated November 21, 2013, directing the parties to submit a Pretrial Statement. I. LIST OF EXPERT WITNESSES A. None. II. LIST OF WITNESSES A. Shaun Spangler, Defendant 246 Cumberland Road Camp Hill, PA 17011 - Counsel has communicated with this witness B. Kristi Harmon, Defendant's Wife 246 Cumberland Road Camp Hill, PA 17011 - Counsel has communicated with this witness C. Reva Spangler, Defendant's Mother 21 Rife Drive Mechanicsburg, PA 17050 - Counsel has communicated with this witness II. PROPOSED ORDER Defendant proposes that an Order be entered granting him joint legal custody and partial periods of physical custody in accordance with the days he has off work. Specifically, Defendant proposes that an Order be entered granting him partial periods of physical custody of the child every Wednesday through Friday on Week 1, and Wednesday through Sunday on Week 2 as well as a holiday and vacation schedule. Respectfully submitted, Date: January 16, 2014 id-arloo H / Tabetha A. Tanner, Esquire PA I.D. No. 91979 TANNER BARCAVAGE 3507 Market Street, Suite 303 Camp Hill, PA 17011 Telephone (717) 731-8114 TANNER BARCAVAGE, LLC 3507 Market Street, Suite 303 Camp Hill, PA 17011 Phone: (717) 731-8114 Fax (717) 731-8115 JAMIE SPANGLER, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA v. § NO. 2009-6173 CIVIL ACTION LAW SHAUN SPANGLER, § CIVIL ACTION - IN DIVORCE Defendant § CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of Defendant's Pre- Trial Statement by depositing same in the United States Mail, first class, postage pre-paid addressed as follows: Jessica Ho1st, Esquire MidPenn Legal Services 401 E. Louther Street Carlisle, PA 17013 Respectfully submitted, Date: January 6, 2014 /641) liebrY Tabetha A. Tanner, Esquire Supreme Court I.D. No.: 91979 JAMIE SPANGLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION—LAW SHAUN SPANGLER, • Defendant : NO. 09-6173 CIVIL TERM IN RE: CUSTODY PRE-TRIAL ORDER OF COURT AND NOW, this 22n1 day of January, 2014, upon agreement of counsel, the pretrial conference in the above matter previously scheduled for January 22, 2014, will be held prior to the custody hearing scheduled for April 7, 2014, at 9:30 a.m., in Courtroom No. 5, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, 7/7 Christyree L. Peck, J. .. MidPenn Legal Services 401 E. Louther Street Suite 103 Carlisle, PA 17013 Attorney for Plaintiff abetha Tanner, Esq. 3507 Market Street Suite 303 Camp Hill, PA 17011 m 32.. '' Attorney for Defendant ii) c -0> w ca .rc c.D (11 D� N r -4 CAI //?.2/i(( 0 JAMIE SPANGLER, : IN THE COURT OF COMMON PLEAS Plaintiff • CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2009-6173 CIVIL ACTION- LAW SHAUN SPANGLER, Defendant : IN CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE To the Prothonotary: Kindly enter the appearance of Paul D. Edger, Esquire of MidPenn Legal Services, as Attorney for the Plaintiff, Jamie Spangler, in the above-captioned matter. Respectfully Submitted, / /Date: 3�Z��ly _ 1 MidPenn Lega/►cervices Paul D. Edger, Esquire Supreme Court I.D. 312713 401 E. Louther St., Suite 103 Carlisle, PA 17013 Attorney for Plaintiff cnr— N-1 �c JAMIE SPANGLER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. •• NO. 2009-6173 CIVIL ACTION- LAW • SHAUN SPANGLER, • Defendant •• IN CUSTODY CERTIFICATE OF SERVICE I, Paul D. Edger, Esquire, Attorney for the Plaintiff, Jamie Spangler, state that I did mail a copy of the foregoing document upon the following individual(s) and in the manner indicated below: USPS First Class Mail Tabetha Tanner, Esquire 3507 Market Street, Suite 303 Camp Hill, PA 17011 Date: 3!2 thy Paul D. Edger d^°'quire JAMIE SPANGLER, IN THE COURT OF COMMON PLEAS OFm= '11.'` ? Plaintiff CUMBERLAND COUNTY, PENNSYLVANdIA' rtu I ��(. �';tji;' F , v . : NO. -2-&&&r4-. 0 . P� -9 e{ 1: ' CIVIL ACTION - LAW SHAUN SPANGLER, . Defendant IN CUSTODY CUMBEiRL n ND JN 'O Y PENNSYLVANIA C T IN RE: PETITION FOR MODIFICATION OF CUSTODY ORDER AMENDING ORDER OF COURT AND NOW, this 7th day of April, 2014, this being the time and place set for a hearing on the Petition for Modification of Custody Order, pursuant to an agreement between the parties, the Order of Court dated December 19, 2012, is hereby amended as follows: Paragraph 3 -B shall be modified as follows: Week 1: Commencing with the week of April 6, 2014, Father shall have partial periods of custody every Wednesday from after school until Thursday morning when he drops the child off at school. Week 2: Father shall have partial periods of custody every Thursday after school until Monday morning when he drops the child off at school. Should there be a Monday holiday, Father's time shall continue until Monday at 7:30 p.m. This schedule shall continue until the end of the current academic school year. Assuming that there is no substantial change with regard to Dominic's academic performance and overall well being as a result of this increase in custodial time to Father, then commencing with the first full week of summer break in 2014, Father shall enjoy partial periods of custody on week 1 at 10:30 a.m. on Wednesday to 10:30 a.m. on Friday during the summer. This schedule will continue into the following academic year, however, the time shall be modified during the academic year from Wednesday after school until Friday when Father drops off at school. The summer academic year schedule will continue until further Order of Court or agreement of the parties. Paragraph 3-C shall be deleted. Paragraph 4 shall be amended to be: 4. Transportation: During the summer custodial exchanges, the parties assuming custody will provide the transportation. Paragraph 5-A is modified as follows: Christmas: For 2014 and all even numbered years thereafter, Father shall have physical custody of the child on Christmas A, defined as December 24 at 3:00 p.m. until December 25 at 3:00 p.m. Mother shall have physical custody on Christmas B, defined as December 25 at 3:00 p.m. until December 26 at 3:00 p.m. In 2015 and all odd numbered years thereafter, mother shall have Christmas A, and Father shall have Christmas B. All other provisions contained in the December 19, 2012, Order of Court shall remain in full force and effect. By the Court, (2,1' Chris ylee L. Peck, J. dPenn Legal Services Paul D. Edger, Esquire For the Plaintiff Tabetha Tanner, Esquire For the Defendant pcb Q ies 02.12 Lk, QM •■••■•12.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA M. SWINN Plaintiff No 10-3617 Civil Action - Law JOHN A. SWINN Defendant ORDER Divorce AND NOW, this kVt, day of r-:-Le--1 2014, upon consideration of the Motion for Modification of This Court's Order o January 27, 2014, the Motion is granted. The parties shall have thirty(30) days from the entry of an. Order in the Federal Bankruptcy Court in the Middle District of Pennsylvania lifting the automatic stay to comply with this Court's January 27, 2014 Order. BY THE COURT: Christylee . Peck, J. • LOI;Vit.) 9/9/1Y --i c - > C—) ---r ›. C GO (7) ! 7 -.< 4--- - TINA M. SWINN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION — LAW JOHN A. SW1NN, Defendant : NO. 10-3617 CIVIL TERM IN RE: PETITION TO SHOW CAUSE WHY LISTED VALUES SHOULD NOT GRANTED TO DEFENDANT LIST OF MATTERS TO BE RESOLVED WITH CASE NUMBER 10-3617 TO COMPLY WITH ANY AND ALL COURT ACTIONS [sicl ORDER OF COURT AND NOW, this 8th day of April, 2014, up-on consideration of the above-captioned Petition, the Petition is denied. ii Bickley, Esq. 41 Central View Road Dillsburg, PA 17009 Attorney for Plaintiff A. Swinn 220 Willow Mill Park Road Mechanicsburg, PA 17050 Defendant, pro Se :rc BY THE COURT, trzIK- Chris lee L. Peck, J.