The URL can be used to link to this page

Home My WebLink About04-4058 NATHAN C. WOLF, ESQUIRE ATtORNEY ID NO, 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATtORNEY FOR PLAINTIFF v, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CML ACTION - LAW ANGELA S. SCHULTZ, Plaintiff Defendant ; NO. 04 -'feSt : IN DIVORCE CML TERM RYAN E. SCHULTZ, NOTICE 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 in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities orirretrievable breakdown of the marriage, you may request maniage counseling. A list of maniage counselors is available in the Office of the Prothonotary, G.unberland County Courthouse, Carlisle, Pennsylvania 17013. 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 Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 NATIIAN C, WOLF, ESQUIRE AlTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 AlTORNEY FOR PLAINTIFF ANGELA S, SCHULTZ, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW Defendant ; NO. 04 - ilos<{ : IN DIVORCE CIVIL TERM RYAN E, SCHULTZ, COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(C) OF THRDIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Angela Schultz, an adult individual residing at 85 West Main Street, Newville, Cumberland County, Pennsylvania 17241. 2. The defendant is Ryan E. Schultz, an adult individual residing at 326 Meadow Drive, Shippensburg, Cumberland County, Pennsylvania 17257. 3. The plaintiff and defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on July 1,1999, in Waynesboro, Franklin County, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as this Honorable Court may deem equitable and just. I verify that the statements made in this complaint are tme and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.CS. Section 4904, relating to unsworn falsification to authorities. /Iv? I fo ,2004 aaJ~ J ~J;t AngelfS:' S~hu1tz, Plaintiff ? ,'" 9 [--,) \::> \A. 7'=> +t=- ~ -S> --.. - 0 U"I '" ~ 3 ':\ w " --4:. -0 0'\ >>- c c: c: ":> ...., NATHAN C, WOLF, ESQUIRE ATrORNEY ID NO, 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 1701.3 (717) 241-4436 ATrORNEY FOR PLAINTIFF ANGELA S. SCHULTZ, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW Defendant :NO,04- WO~ : IN DIVORCE CIVIL TERM RYAN E. SCHULTZ, PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being dulyswom according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the coUrt require that my spouse and I participate in counseling. 2. I understand that the coUrt maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the coUrt require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. CS. Section 4904 relating to unsworn falsification to authorities. cjYfC? ,2004 ~if!~ut~~ NATHAN C, WOLF, ESQUIRE ATIORNEY ID NO, 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLlSLE PA 17013 (717) 241-4436 ATIORNEY FOR PLAlNfIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ANGELA S. SCHULTZ, Plaintiff Defendant : CIVIL ACTION{W ; NO, 04 - _lfOS CIVIL TERM : IN DIVORCE v, RYAN E. SCHULTZ, ACCEPTANCE OF SERVICE I, Ryan E. Schultz, certify that I am the defendant in this matter. Furthermore, I hereby certify that on / 0' J,.S' O''i , 2004, I received a certified copy of the divorce complaint filed in this action, J O-ZJ"f,ol" ,2004 ~E,\:L~ Ryan E. Schultz j Defendant ,f~C~ /!/~o OCt.,? ;> /t?tl( Q ~,~ '-Ci(",i:j [1'11'1',1 -7.~'_':.1 65 i;~,,: _.c,. r:.:. ~'. &~i ~ '"I -") -'- ....., c:~ c~-:') ...- o ... ..... -1: ...., ~~ ::;.J :f.\ 5: \1 f~?' (~:~ (J'1 :~;2 '" c:> " -l N -' RECEIVED OCT 27 ZOO4 NATIIAN C, WOLF, ESQUIRE ATIORNEY ID NO, 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATIORNEY FOR PLAINTIFF ANGELA S, SCHULTZ, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION -LAW Defendant :NO.04- VI1<;1 : IN DIVORCE CIVIL TERM RYAN E. SCHULTZ, DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. es. Section 4904 relating to unsworn falsification to authorities. IO-J.t,-OY ,2004 }~~ ~ 1~ Ryan E. Schultz, Deren' ant trf"Cf"/Jtf"O" <fCl ~7,?" ". trf"Cf"/Jtf"O OCr" <; /"""- o G .:..,. -o(j;.~1 fYlll.'; -'7."),." .;~~ ~.~. 0)::,:, ;::;C) :i.~("! =<., (' :, ~;t;.~; :2 ~ ~ ~ c:> ~:JJ ~ i~~~ N _') -1 ~~..::::! -ri "1:.1' ~ ;,'20 ~ f?\fT\ - "':.'~ ~;" ~:l OJ NATHAN C, WOLF, ESQUIRE AlTORNEY ID NO, 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 AlTORNEY FOR PLAINTIFF ANGELA S, SCHULTZ, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW Defendant : NO. 04 - 4058 CIVIL TERM : IN DIVORCE RYAN E. SCHULTZ, PRAECIPE TO TRANSMIT RECORD 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: On or about October 25, 2004, defendant was served with a copy of the divorce complaint via regular first class mail, addressed to the counsel for defendant. (See Acceptance of Service previously filed, October 27,2004,) 3. Complete either paragraph (a) or (b): (a) Date of execution of cons em required by Section 3301(c) of the Divorce Code: By the plaintiff: January25,2005 By the defendant: January 25, 2005 (b) (1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A (b)(2) Date of filing and service of the plaintiff's affidavit upon the defendant: N/ A 4. Related claims pending: None 5, Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/ A. Date plaintiff's Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: January 25,2005 Date defendant's Waiver of Notice in Section 330l(c) Divorce was filed with the Prothonotary: January 25, 201~? "/ /A~~ ~ATHAN C,wOLF C~)laintiff (b) January 2.<:; ,2005 () ~; .-ot5~:: f1lf' Z""I'" ~.?' ) ~j~ 'C:>:' 1,."- ' --- j..""".-' Z,,: j.;'f~ 3 ~ ....., = .c:;;;:) "'" <- )>0 z N en Co -" ::;1 ni :q -C)h1 :,,0 ''''J I ~1~:) 2)~ ;~5;nl :".) :;3 -< "'" :x l..D c:> cO) NATHAN C, WOLF, ESQUIRE ATTORNEY In NO, 87380 37 SOlITH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ANGELA S, SCHULTZ, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW RYAN E. SCHULTZ, Defendant : NO. 04 - 4058 CIVIL TERM : IN DIVORCE PLAIN.TIFF'S AFFIDA VIr OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about August 16, 2004 and served upon defendant on October 25, 2004 (see acceptance of service filed October 27,2004). 2, The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C S. Section 4904 relating to unsworn falsification to authorities. ~\\ffi- d'S ,2005 l~c~rL~~W1o (") c: ~,,"" .,"Oi;;?) f11{"'i", _,)""'1' ~{~:: C;::C.. ,*-Q ~..~ (~,) ;V' (" .:::-;- 2 .....> = ~';::';,:) Gf' ,- ,to" % r-) <J\ .." ::lIZ r:-:"' o -n '1...,., r-r\-;:;::: ___If... ~X10 ,.:J(':, j~-~,\ ~4~) orr1 ~ CP v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW ANGELA S. SCHULTZ, Plaintiff Defendant : NO, 04 - 4058 CIVIL TERM : IN DIVORCE RYAN E. SCHULTZ, DEFENDANT'S AFFIDAVIT OI1 CONSENT 1. A complaint in divorce under Section 3301(c) OJ[ Section 3301(d) of the Divorce Code was filed in this matter on or about August 16, 2004 and served upon defendant on October 25,2004 (see affidavit of service filed October 27,2004). 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are tlUe and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S, Section 4904 relating to unsworn falsification to authorities. 1- ?5 , 2005 f) F ~ I~ c..~ RYAN E. SCHUr; z ~ .....' c;;.:l = ~4 t- "'" :r N ':.11 ~~J ::r.: ~?, :2-n rnf':;;;; -or.!:\ -,39 c:;,c: ~~ ~~~~; ,.-:. r;? 0:> - NATHAN C, WOLF, ESQUIRE ATTORNEY ID NO, 87380 37 SOUTH HANOVER STREET. SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ANGELA S, SCHULTZ, Plaintiff v, : CIVIL ACTION - LAW Defendant : NO, 04 - 4058 CIVIL TERM : IN DIVORCE RYAN E. SCHULTZ, WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION ~301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce v,>ithout notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.CS. Section 4904 relating to unsworn falsification to authorities, 2J<1\'1 d- S ,2005 j)Mi~ ~p JAuig ~;;CHULTZ o c: <'~:' V1-~ r:D~:.-, ,~.- "- S',~. reel. ~~t.~ )::. c- ::3 --. """ "':;:0 c::J en <- ~ N Ul o -n :;:l.,... rnr;:; 86 ~-i'" ...- -...-, (~c"; ';~n'1 U :.;:1 'c:q :....::, -0 ::JI: ,.." .- w ~ v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : ClVILACTION - ~LAW ANGELA S, SCHULTZ, Plaintiff Defendant : NO. 04 - 4058 CIVIL TERM : IN DIVORCE RYAN E. SCHULTZ, WAIVER OF ~OTICE OF INTENTION TO llEOUEST ENTRY OF A OIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the CoUlt and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.GS. Section 4904 relating to unsworn falsification to authorities. ]-;),,-5 ,2005 ~cl~ RYAN E. SCHU TZ () C ..;..,. -'Ol~fi \'1.1.]'1\ '::;'~: ~l. ZI, ~~ :~ ~C. ~(, "",-U rc; -7 3 ..-' "'" "'" cF' (,... """ :;.::: N U' -0 ::s. r:? C'i ~~, .,.J :J: ~,... ,'\'\-" C" :.8 lTI ,)1:( ::3~1~ ::,,~:,:"p ",..",(' "6rt< ;~~- >J:j - :+::.::+::+:+::+:+. . . . :.::+::+.:+. :+:+.:.::+.:+::+::+::+ . . :++:+::++:+::+++:+'++'1'0+ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '" +. +. ",+ +:+::+:+.+.'f:++ :+::+:+.:+:++++:+:+.+.+.++:+++++++.'f+++.++++:+: IN THE COURT OF COMMON PLEAS STATE OF . . . . . . . . . . . . . . . . . . Angela S. Schultz . VERSUS . . . . . . . . . . . . Ryan E. Schultz . . . . . . . . . . . . . . . . . . . . AND NOW, OF CUMBERLAND COUNTY PENNA, No. 2004 4()~R DECREE IN DIVORCE f~ ;,)-- ~ 1():17~'fV' - , 200? IT IS ORDERED AND DECREED THAT Angela S. Schultz , PLAINTIFF, Ryan E. Schultz AND . . . . . . . . . . . . . . . . . . , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT none . . . . . . . . . . . . . . . . . . . . . . . :++.:+' + + Amct'~ PROTHONOTARY ... . ++.+++++++:+'+++.+++++++'f+'++'++'+.++++++++++++++++'+++++++ . .. . . J, . h:2 ~/ ?~~~ _sr./. frJ y?;7 /-lT~t/ ~l,PP 51] " , . L'f c~ (" NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO, 87380 37 SOlITH HANOVER STREET, SUITE 201 CARL1SLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAlNT1FF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ANGELA S. SCHULTZ, Plaintiff v, : CIVIL ACTION - LAW Defendant : NO. 2004 - 4058 CIVIL TERM : IN DIVORCE RYAN E, SCHULTZ, NOTICE OF PRAECIPE OF INTENTION TO RETAKE AND USE PRIOR NAME TO THE PROTHONOTARY: Kindly file the attach Notice of Intention to Retake and Use Prior Name: I, ANGELA S. SCHULTZ, hereby give notice, avowing my intention to resume and hereafter use my prior surname, to wit: ANGELA S. RAY, in accordance with the provisions of the Act of December 16, 1982, P.L. 1309, No. 295, Section 704 (a) (54 Pa.e.S. Section 704 (a)) and in support there I aver as follows: 1. I, Angela S. Schultz, am an adult resident of Newville Borough, Cumberland County, Pennsylvaoia. 2. My divorce, docketed to the above term and numb(~r was granted on the 2ND day of February, 2005. I verify that the statements made in this document are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.GS. Section 4904 relating to unsworn falsification to authorities. IN WITNESS WHEREOF, I have hereunto set my hand and seal this -1!!- day of February, 2005. / t1d1.' dvkhA/15 (SEAL) ANGE S. SCHULTZ WITNESSTH: TO BE KNOWN AS: 'Ie NAT~~WOLF, ES A Z_~~:i~ti~, {f-J1fRA~1 G~ (SEAL) COMMONWEALTH OF PENNSYLVANIA Notarial Seal Nathene. Wot!. Natant DtJbtk:: CarlisJe Boro. Cumo:;; ; i),unty My Commission Exptres M 19,2008 Member, Pennsylvania A88OCi~j'on Of Notaries \~~~ 1; }'J '--" \ --- 'f0 ~ S:: ~ ( ~~ ~ ,"", i ..~ ~('4 -\'1 :-:--J C"-::: 1" .. c:- o NATHAN C. WOLF, ESQUIRE ATIORNEY ID NO, 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATIORNEY FOR PLAINTIFF ANGELA S. RAY (fonnerly SCHULTZ), Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW Defendant : NO. 2004 - 4058 CIVIL TERM : IN DIVORCE - CUSTODY RYAN E. SCHULTZ, COMPLAINT FOR CUSTODY NOW comes the Plaintiff, Angela S. Ray, by her anomey , Nathan C Wolf, Esquire, and respectfully represents as follows: 1,) Plaintiff is Angela S. Ray (formerly Schultz), (hereinafter "Mother"), an adult individual, who resides at 85 West Main Street, Newville, Cumberland County, Pennsylvania, 17241. 2.) Defendant is Ryan E. Schultz, (hereinafter, "Father"), an adult individual, who resides at 326 Meadow Drive, Shippensburg, FraokIin County, Pennsylvania, 17257. 3.) Mother seeks an order granting shared legal custody and primary physical custody of the parties minor children, namely: Mune Kyle Jacob Schultz Present Residenl:!': 85 West Main Street Carlisle, P A 17013 Age 4 years DOB 6/23/2000 Austin Taylor Schultz 85 West Main Street Carlisle, P A 17013 2 years DOB 3/1/2002 4,) Mother and Father are the natural parents of the children. 5,) The children were born during the marriage of the parties, 6.) The children are presently in the custody of Mother, who, until recently, had provided father with opportunities to see the children, Prior to the parties separation, the children resided with both parents from birth, The parties separated on or about September 19, 2003, Since that time the parties have been in the primary custody of Mother. 7.) The parties were divorced by decree of this Court dated February 2,2005, 8,) Mother has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 9,) Mother has no information of a custody proceeding (;oncerning the children pending in any court of this Commonwealth or any other state, 10,) Mother does not know of a person not a party to the proceedings who has physical custody ofthe children or claims to have custody or visitation rights with respect to the children, 1 1,) The best interest and permanent welfare of the children will be served by granting the relief requested herein because the parties have been without a formal custody order since their separation, and now their divorce and Mother seeks the entry of an order to establish some formality to the current situation, 12,) Upon her retrieving the children from a visit with Father in January of 2005, Mother discovered a mark around the neck of the oldest child, Kyle, Mother immediately took the child to Carlisle Regional Medical Center who referred the matter to Children and Youth Services, 13,) Mother believes that Children and Youth Services of Franklin County has determined the reported abuse to be unfounded. 14,) Mother nonetheless believes and therefore avers that the child was injured while in the care of Father and that Father either caused the injury or failed! to prevent the injury. 15.) Mother recognizes that the children should have a meaningful and substantial relationship with their Father, but for the immediate future, any visits should be supervised. 16,) Mother believes that without an order confirming shared legal and primary physical custody of the children with her, that Father could attempt to l)xercise custody without her having any recourse, 17,) Mother maintains a stable household and environment within which to care for the children, WHEREFORE, for the reasons set forth herein, Plaintiff, Angela S. Ray, respectfully requests that the Court enter an order confinning shared legal custody and establishing primary physical custody of the children to the Plaintiff, and directing that Defendant be grmted only periods of supervised visistation with the children, along with granting any other relief the Court deems appropriate. Respectfully submitted, February {i, 2005 VERIFICATION I do hereby verify that I am the plaintiff in the foregoing action and that the facts set forth in this complaint are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.CS, Section 4904, relating to unsworn falsification to authorities. veb. \ <h ,2005 6\~A- J. JJtL~ ANGE S. SCHULTZ 9 (:;;;; ~~ ("0- ~ '~ ~ r-c:5 ~ 5'. ~ I"'. , ,-' ,~ ~. ; ~ c. <7' .5' , ' ~ .-- ~ - ----- ---- ANGELA S. RAY PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANJA V. 04-4058 CIVIL ACTION LAW RYAN E. SCHULTZ DEFFNDANT IN CUSTODY 9RDER OF COLlRT AND NOW, Thursday, Februar:'(.24, 2005 ._,_, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueliue M, Verney, Esq, . the conciliator, at 4th Floor, Cumberland County Courthouse, Ca~lisJ"_ on .__..._.._Thursday, March ~'!,1()05 at 8:30 AM for a Pre-Hearing Custody Conference. At such confcrence, an effort will bc madc to resolve the issues in dispute; or if this cannot be accomplished, to deline and narrow the issues to he heard by the eour!, and to entcr into a temporary order, All children agc five or oldcr may also be prescnt at thc conference. Failure to appcar at the confercnce 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: -,-~J'15:gueline M, Verl1_ev. Es.<L..... .~ Custody Conciliator -,vr- The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990, For infonnation about accessible facilities and reasonablc accommodations available to disabled individuals having business before the court, please contact our oftice. All alTangements must be made at least 72 hours prior to any hearing or busioess 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 HA VE 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 170 I 3 Telcphone (717) 249-3166 off ~ !p ~ ~ ~ ~.~ ~ JO.hcCO o;fiP ~ ~ ~!L, 5r?~1z'.C' ~(l fP #- ~~) P{/ j'o,;/Jl'-C Ii vJ )1 I' :11 WJ fJz. 93.:1 SQOz . MAR 28 2005jlf' 6 ANGELA S. RAY, Plaintiff : IN THE COURT OF COMMON PL AS OF : CUMBERLAND COUNTY, PENNS LV ANIA V. : NO. 2004-4058 CIVIL TERM RY AN E. SCHULTZ, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT <" ,.J.. ! AND NOW, this '36 day of fI'. ,)2005, up n consideration of the attached Custody Conciliation Report, it is order~d and dir cted as follows: . 1. The Mother, Angela S. Ray and the Father, Ryan E, Shultz, sh II have shared legaL custody of Kyle Jacob Schultz, born June 23, 2000 and ustin Ta lor Schultz, bGffi March 1, 2002. Each party shall have an equal right, to be exerci ed jointly with the other party, to make all major non-emergency decisions affe ting the hildren's general well-being including, but not limited to, all decisions regardi g their he lth, education and religion. This means that both parents shall be entitled to all inD rmation from school and medical professionals, 2. ! , Mother shall have primary physical custody of the Children Father shall have periods of partial physical custody o~the Chil en as , i ! A. Alternating weekends, beginning April I, 2005 fro~ Friday t 3:00 p.m. to Sunday at 7:00 p.m, except that the first fo r such pe iods shall be supervised with the children's paternal grandmo her, grea grandmother, paternal uncles or aunts and Father's, ouse ma e as supervisors, !! B, Such other times as agreed by the parties, 3. follows: 4. Holidays: . ! A. Easter. Father shall have four hours supervised ph~sical cust dyon Easter,2005, Thereafter, Easter shall be shared as agreed by the . ' parties. B. Mother's Day/Father's Day, Mother shall have ph}lsical Cllst dyof the children on Mother's Day from 9:00 a,m. to 7:0p p,m. F her shall . have physical custody of the children on Father's Day from 9: 0 a.m. to 7:00 p.m. C, Thanksgiving, The parties shall share Thanksgiving from 9:0 a,m. to 3:00 p,m, and 3:00 p.m, to 9:00 p,m. Said holiday shall be alt mated as agreed by the parties. D, Christmas shall be divided into two blocks. Block Ai shall be rom Christmas Eve at 12:00 noon to Christmas Day at q:OO p.m. lock B shall be from Christmas Day at 12:00 noon to Decerj1ber 26 a 12:00 noon, Mother shall have Block A in odd numbered years and Block B in even numbered years, Father shall Block A in evtn numbe ed years and Block B in odd numbered. I E. Memorial Day, July 4th and Labor Day shall be shar~d or alte ated as agreed. i 5. Each party shall be entitled to one full week of physical custody i the summer provided they give the other party 30 days prior notice, , 6, Transportation shall be shared such that the receiving pry shall ansport. 7. This Order is entered pursuant to an agreement of the plrties at a ustody Conciliatiort Conference. The parties may modify the provisions ofth's Order b mutual consent. In the absence of mutual consent, the terms of this Order shal controL J. c~han C. Wolf, Esquire, Counsel for Mother ~an E. Schultz, pro se 26 Maple Avenue Walnut Bottom, P A 17266 9' ,r I'" (J .1) .i ,j , (~ \'1H \ p;irj" ! t.. ('j"Jil :J,:J~{J -1(\ .JI,.} ,"--.-..---. MAR 2 8 2005 fT' f ANGELA S. RAY, Plaintiff : IN THE COURT OF COMMON PLE S OF : CUMBERLAND COUNTY, PENNSY VANIA V. : 2004-4058 CIVIL TERM RYAN E. SCHULTZ, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: None i I CUSTODY CONCILIATION SUMMARY REPOtI IN ACCORDANCE WITH CUMBERLAND COUNTY RJLE OF IVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submi~s the fall wing ~~ I I.' The pertinent information concerning the Children who are the s bject of this litigation is as follows: NAME DA TE OF BIRTH CURRENTLY 1 CUSTO Y OF Kyle Jacob Schultz June 23, 2000 Mother I Austin Taylor Schultz March 1,2002 Mother ! I 2, A Conciliation Conference was held in this matter on Jarch 24, 005, with the following individuals in attendance: Mother, Angela S. Ray, }vith her c unsel, Nathan C. Wolf, Esquire and Ryan E, Schultz, pro se, I 3. The parties agreed to the entry of an Order in the form ~s attach d, , I , I I i I I ! , i, ';....~ sqUire 3-.).4-05- Date