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HomeMy WebLinkAbout01-1610KENNETH M. SHEAFFER, IN THE COURT OF COMMON PLEAS OF Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW of-1610 CIVILTERM C-) LD n JEVONNE M.SHEAFFER, 7 77 T .? 'C7 CC + '-; --r7 Respondent IN CUST013Y :Y PETITION FOR CUSTODY f..J "77 AND NOW comes the Petitioner, Kenneth M. Sheaffer, by his attorneys Irw n, McKnight & Hughes, and presents the following Petition for Custody. 1. The Petitioner is Kenneth M. Sheaffer, an adult individual residing at 1634 Pine Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Respondent is Jevonne M. Sheaffer, an adult individual residing at 26 Pine Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of three children, namely, Cortney L. Sheaffer, born February 23, 1983, Kendra E. Sheaffer, born February 21, 1989, and William Powell Sheaffer, born April 24, 1991. 4. Petitioner desires primary physical custody of the children and joint legal custody with periods of visitation to respondent as the parties agree is appropriate and in the best interest of the children. 5. The best interest of the children requires that the court grant the petitioner's request as set forth above. WHEREFORE, petitioner respectfully seeks the entry of an Order of Court seeking primary physical custody of the children and joint legal custody with periods of visitation to respondent as listed above. Respectfully submitted, IRWIN, McKNIGHT & HUGHES By: Matcus A. rdcKni t, 111, Es Attorney for Petition 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Date: March 20, 2001 VERIFICATION The foregoing Petition for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unworn falsification to authorities. KENNETH M.M. SHEAFFER March 20, 2001 C C uwn» c,N {{?? tl?cZI Utiitilc c° nHVI:. _n3, . ?o V ?r KENNETH M. SHEAFFER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JEVONNE M. SHEAFFER DEFENDANT 01-1610 CIVILACTIONLAW • IN CUSTODY ORDER OF COURT AND NOW, Friday, March 23, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Vernev Esq._ the conciliator, at 4th Floor, Cumberland County Courthouse Carlisle on Wednesday, April 25, 2001 at 1:30 a.m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: /s/ acqueline M Vern, 0 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 r VIN'tiAIASNN?7,d APR z 5 2001 KENNETH M. SHEAFFER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO.2001-1610 CIVIL TERM JEVONNE M. SHEAFFER, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this 19' day of_2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Kenneth M. Sheaffer, and the Mother, Jevonne M. Sheaffer, shall have shared legal custody of Courtney L. Sheaffer, born February 21, 1983, Kendra E. Sheaffer, born February 23, 1989 and William Powell Sheaffer, born April 24, 1991. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 2. Father shall have primary physical custody of the children with Mother having periods of partial physical custody as agreed by the parties. 3. Mother shall provide Father with 48 hours notice of the time she desires to have partial physical custody of the children. 4. Mother insures that the children will not be left alone with her boyfriend without prior consent of Father. 5. Transportation shall be as agreed by the parties. 6. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terns of this Order shall control ?. BY cc: Marcus A. McKnight, II, Esquire - Counsel for Father Marylou Matas, Esquire - Counsel for Mother r t}r " J. ' ?.p 1 ¢ I\S 5 C R j ) t - rr L., 2 ? i © U APR 2 5 2001 KENNETH M.SHEAFFER, Plaintiff V. JEVONNE M.SHEAFFER, Defendant PRIOR JUDGE: None IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :2001-1610 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY CUSTODY CONCILIATION SUMMA]Ly REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I • The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Courtney L. Sheaffer February 21, 1983 Kendra E. Sheaffer February 23, 1989 Father William Powell Sheaffer April 24, 1991 Father Father 2. A Conciliation Conference was held in this matter on April 25, 2001. Father, Kenneth M. Sheaffer, was present with counsel, Marcus A. McKnight, II, Esquire, and Mother, Jevonne M. Sheaffer, was present with counsel, Marylou Matas, Esquire. 3. The parties agreed to an Order in the form attached. Date--_rney, Esquire Custody Conciliator KENNETH M. SHEAFFER, Petitioner V. JEVONNE M. SHEAFFER, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2001-1610 CIVIL TERM IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW comes the Petitioner, Kenneth M. Sheaffer, by her attorneys, Irwin & McKnight, and presents the following Petition for Modification of Custody. 1. The Petitioner is Kenneth M. Sheaffer, an adult individual residing at 1634 Pine Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Respondent is Jevonne M. Sheaffer, an adult individual residing at 231 Mill Street, Mount Holly Springs, Cumberland County, Pennsylvania 17065. 3. The parties are the natural parents of one minor child, namely, William Powell Sheaffer, born April 24, 1991. 4. The Petitioner desires primary physical custody of the minor child, William Powell Sheaffer, who has resided with the Petitioner since Tuesday, March 11, 2008 and joint legal custody with periods of visitation to respondent as the parties agree is appropriate and in the best interest of the child. 5. The best interest of the children requires that the court grant the petitioner's request as set forth above. WHEREFORE, petitioner respectfully seeks the entry of an Order of Court seeking primary physical custody of the children and joint legal custody with periods of visitation to respondent as listed above. Respectfully submitted, IRWIN & By: / ' L Marcus . McKni , Esquire Attorney r Petitioner 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Date: March 14, 2008 VERIFICATION The foregoing Petition for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unworn falsification to authorities. TH M. SHEAFFER Date: March 14, 2008 ?l tA` `': [(may\\\ 0 b ...F 1.." r? N C;.m f'T3 r Cam' r ern KENNETH M. SHEAFFER IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. 2001-1610 CIVIL ACTION LAW JEVONNE M. SHEAFFER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, March 19, 2008 , 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, April 22, 2008 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 tff'I Al1ASIv!N -J J ?.x.ILr f t d4d QZ Bw HE Du do r? MAY 8 8 2008,?,r Y KENNETH M. SHEAFFER, Plaintiff V. JEVONNE M. SHEAFFER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-1610 : IN CUSTODY ORDER OF COURT CIVIL ACTION - LAW AND NOW, this 3o - day of Ma,, , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Kenneth M. Sheaffer and the Mother, Jevonne M. Sheaffer, shall have shared legal custody of William Powell Sheaffer, born April 24, 1991. 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 parents shall have shared physical custody as agreed. 3. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. ,.<? ?, ? c:;iL ..? ?1 .1 z cc: arcus arylou A. McKnight, III, Esquire Matas, Esquire, Counsel for Mother aopies m7t I S'?301dS BY THE COURT, NAY 3 8 2008 KENNETH M. SHEAFFER, Plaintiff V. JEVONNE M. SHEAFFER, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-1610 CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 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 William Powell Sheaffer April 24, 1991 Father 2. A Conciliation Conference was held in this matter on May 27, 2008 with the following in attendance: Father's counsel, Marcus A. McKnight, III, Esquire and Mother's counsel, Marylou Matas, Esquire. 3. The parties agreed that the child will continue to attend Boiling Springs High School. 4. The parties agreed to an Order in the form as attached. Date Jac eline M. Verney, Esquire Custody Conciliator