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HomeMy WebLinkAbout04-4558SANDRA A. SHEPHERD, Plaintiff HENRY C. SHEPHERD, Jla, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2004- /f~y IN DIVORCE CML TERM 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 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 fights 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 &the Prothonotary, Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT 1S 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 Lawyers Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 LAW OFFICES OF PETER J. RUSSO, P.C. PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 SCOTT A. STEIN, ESQUIRE PA Supreme Court ID: 81738 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 SANDRA A. SHEPHERD, : Plaintiff : _. : HENRY C. SHEPHERD, JR., : Defendant : Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) AND 3301(d) OF THE DIVORCE CODE AND NOW, COMES, the above-named Plaintiff by and through her attorneys, Law Offices of Peter J. Russo, P.C., and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff is an adult individual residing at 206 York Street, Enola, Cumberland County, Pennsylvania and is a citizen of the United States. 2. Defendant is an adult individual residing at 206 York Street, Enola, Cumberland County, Pennsylvania and is a citizen of the United States. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for most of her life and has resided continuously therein for at least six months prior to filing of this Complaint. his life and has resided continuously therein for at least six months prior to filing of this Complaint. Defendant has been a resident of the Commonwealth of Pennsylvania for most of 5. Plaintiff and Defendant were married on September 10, 1983, in Cumberland County, Pennsylvania. 6. There is one child of the parties under the age of eighteen (18): Holly A. Shepherd June 21, 1987 COUNT I - DIVORCE 7. Plaintiff hereby incorporates by reference averments 1 through 6 of this Complaint as if each averment were set forth fully hereunder. There has been no prior action for divorce by either party against the other. Ne/ther Plaintiffnor Defendant is in the Armed Forces of the Un/ted States or any of 9. its allies. 10. 11. Plaintiff avers that the marriage between the parties is irretrievably broken. 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, but does not request the same. 12. Plaintiff and Defendant have property which will be subject to a property settlement agreement addressing support issues, which will be filed herein at the appropriate time. WHEREFORE, Plaintiff, Sandra A. Shepherd, prays that a decree be entered in favor of the Plaintiffand against Defendant as follows: A. That a decree in divorce be entered dissolving the marriage between the two parties. COUNT Il: DIVORCE - EOUITABLE DISTRIBUTION 13. Plaintiff hereby incorporates by reference averments 1 through 12 ofthis Complaint as if each averment were set forth fully hereunder. 14. Plaintiff and Defendant have acquired property, both real and personal, during the course of their marriage. 15. The parties have also acquired home furnishings, motor vehicles, bank accounts, retirement accounts, investments and miscellaneous items of personal property. 16. Thus far plaintiff and defendant have not agreed to an equitable distribution of said property. WItEREFORE, Plaintiff, Sandra A. Shepherd, prays that a decree be entered as follows: A. That a decree be entered granting equitable distribution of marital property as agreed upon. COUNT IH - CUSTODY 17. Plaintiffhereby incorporates by reference averments 1 through 16 of this Complaint as if each averment were set forth fully hereunder. 18. Plaintiff is Sandra A. Shepherd residing at 206 York Street, Enola, Cumberland County, Pennsylvania. 19. Defendant is Henry C. Shepherd, Jr. residing at 206 York Street, Enola, Cumberland County, Pennsylvania. 20. Plaintiffseeks joint custody of the following child: Name Present Residence DOB Holly A. Shepherd 206 York Street, Enola, PA June 21, 1987 21. The child was not bom out of wedlock. 22. The child is presently in the shared custody of both Plaintiff and Defendant, who both reside at, 206 York Street, Enola, Cumberland County, Pennsylvania. 23. In the last five years the child has resided with the following persons and at the following address: Name Plaintiffand Defendant Address Dates 206 York Street, Enola, PA birth to present. 24. The Plaintiff, the mother of the child, is residing at, 206 York Street, Enola, Cumberland County, Pennsylvania. She is married. 25. The Plaintiff currently resides with the following persons: Name Relationship Hem3, C. Shepherd, Jr. Husband 26. The Defendant, the father of the child, is Henry C. Shepherd, Jr., residing at 206 York Street, Enola, Cumberland County, Pennsylvania. He is married. 27. The Defendant currently resides with the following persons: N~one Relationshi, o Sandra A. Shepherd Wife 28. Plaintiffhas not participated as a party or witness, or in another capacity, in other litigation concern'lng the custody of the child in this or another court. 29. Plaintiff has no information of a custody proceeding concem/ng the child pending in a court of this Commonwealth. 30. Plaintiff does not know of a perSon not a party to the proceedings who has physical custody of the child or da/ms to have custody or visitation fight with respect to the child. 31. The best interest and permanent welfare of the child will be served by granting the relief requested because Mother has been primary care giver for the child's entire life. 32. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests this Honorable Court to order that the parties share custody arrangements as set forth in a proposed Custody Agreement which has been provided to the Defendant. COUNT IV - SUPPORT 33. Plaintiffhereby incorporates by reference averments 1 through 32 of this Complaint as if each averment were set forth fully hereunder. 34. The parties are the parents of the following unemancipated child who reside with Plaintiff and Defendant: N..ame Holly A. Shepherd 35. support. 36. 'Aec Sex Date of Birth 17 Female June 21, 1987 Defendant is employed and has the income earning capacity to provide appropriate Defendant is obligated to provide for the reasonable support of his child. WHEREFORE, plaintiff respectfully requests that, pursuant to Section 3104(a)(3) and 3323('o) of the Divorce Code, an order of temporary child support be entered against the defendant until final heating and permanently thereafter until such time as defendant is no longer legally obligated to contribute toward the support, and pursuant to Section 4351(a), appropriate counsel fees, filing fees and expenses. Date: Respectfully submitted, LAW OFFICES OF PETER J. RUSSO, P.C. Scott A. Stein, Esquire 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 LAW OFFICES OF PETER J. RUSSO, P.C. PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 SCOTT A. STEIN, ESQUIRE PA Supreme Court ID: 81738 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 SANDRA A. SHEPHERD, : Plaintiff : .. ¥o .. HENRY C. SHEPHERD, JR., : Defendant : Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2004 - CIVIL TERM IN DIVORCE VERIFICATION I, Sandm A. Shepherd, verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Sandra A. Shepherd LAW OFFICES OF PETER J. RUSSO, P.C. PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 SCOTT A. STEIN, ESQUIRE PA Supreme Cou~ ID: 81738 3800 Market S~reet Camp Hill, PA 17011 (7~7) 59t-t755 SANDRA A. SHEPHERD, : Plaintiff : HENRY C. SHEPHERD, JR., : Defendant : Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2004 - CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Debm A. Micklo, hereby certify that I am on this day serving a copy of the foregoing documents upon the person (s) and in the manner indicated below; Service by Certified Mail, Restricted Delivery, Postage Prepaid, and Addressed as Follows: Henry C. Shepherd, Jr. 206 York Street Enola, PA 17025 i~j~ Debra A. Micldo, Paralegal SANDRA A. SHEPHERD PLAINTIFF V. HENRY C. SHEPHERD, JR. DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 04-4558 CIVIL ACTION LAW : : IN CUSTODY ORDER OFCOURT AND NOW, Thursday, September 23, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective cotmsel appear before Jaequeline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, October 14, 2004 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an et'lhrt 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. 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 hearin!~. FOR THE COURT, By: /s/ Jacqueline M. Verney, Esq. Custody Conciliator mhc 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 b,usiness 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 SANDRA A. SHEPHERD, Plaintiff HENRY C. SHEPHERD, JR., Defendant S£P IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -. LAW NO. 2004- qJ'.(~ CIVIL TERM IN DIVORCE ORDER OF COURT AND NOW, this day of ,2004, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before ., the Conciliator, at , on the . day of ,2004, at .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 at the request of either attorney or party, be present at the conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, By:_ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with thc Americans with Disabilities 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 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 Lawyers Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 SANDRA A. SHEPHERD, Plaintiff HENRY C. SHEPHERD, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -. LAW NO. 2004- q.5~(ff~ CIVILTERM 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 be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Court House, 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 Lawyers Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 LAW OFFICES OF PETER J. RUSSO, P.C. PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 SCOTT A. STEIN, ESQUIRE PA Supreme Court ID: 81738 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 SANDRA A. SHEPHERD, Plaintiff HENRY C. SHEPHERD, JR., Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2004- ~tt5'5;~ CML TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c~ AND 3301¢d~ OF THE DIVORCE CODE AND NOW, COMES, the above-named Plaintiff by and through her attorneys, Law Offices of Peter J. Russo, P.C., and seeks to obtain a Decree iln Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: I. Plaintiff is an adult individual residing at 206 York Street, Enola, Cumberland County, Pennsylvania and is a citizen of the United States. 2. Defendant is an adult individual residing at 206 'York Street, Enola, Cumberland County, Pennsylvania and is a citizen of the United States. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for most of her life and has resided continuously therein for at least six months prior to filing of this Complaint. · 4. Defendant has been a resident of the Commonwealth of Pennsylvania for most of his life and has resided continuously therein for at least six months prior to filing of this Complaint. 5. Plaintiff and Defendant were married on September 10, 1983, in Cumberland County, Pennsylvania. 6. There is one child of the parties under the age of eighteen (18): Holly A. Shepherd June 21, 1987 its allies. COUNT I - DIVORCE 7. Plaintiff hereby incorporates by reference averments 1 through 6 of this Complaint as if each averment were set forth fully hereunder. 8. There has been no prior action for divorce by either party against the other. Neither Plaintiffnor Defendant is in the Armed Forces of the United States or any of 10. Plaintiff avers that the marriage between the parties is irretrievably broken. 11. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to partieipate in counseling, but does not request the same. 12. Plaintiff and Defendant have property which will be subject to a property settlement agreement addressing support issues, which will be filed herein at/he appropriate time. WHEREFORE, Plaintiff, Sandra A. Shepherd, prays that a decree be entered in favor of the Plaintiffand against Defendant as follows: A. That a decree in divorce be entered dissolving the marriage between the two parties. COUNT II: DIVORCE - EOUITABLE DISTRIBUTION 13. Plaimiffhereby incorporates by reference averm~ats 1 through 12 of this Complaint as if each averment were set forth fully hereunder. 14. Plaintiff and Defendant have acquired property, hoth real and personal, during the course of their marriage. 15. The parties have also acquired home furnishing,,;, motor vehicles, bank accounts, retirement accounts, investments and miscellaneous items of personal property. 16. Thus far plaintiff and defendant have not agreed to an equitable distribution of said property. WHEREFORE, Plaintiff, Sandra A. Shepherd, prays that a decree be entered as follows: A. That a decree be entered granting equitable distribution of marital property as agreed upon. COUNT III - CUSTODY 17. Plainfiffhereby incorporates by reference averments I through 16 of this Complaint as if each averment were set forth fully hereunder. 18. Plaintiff is Sandra A. Shepherd residing at 206 York Street, Enola, Cumberland County, Pennsylvania~ 19. Defendant is Henry C. Shepherd, Jr. residing at 206 York Street, Enola, Cumberland County, Pennsylvania. 20. Plaintiffseoks joint custody of the following child: Name Present Residence DOB Holly A. Shepherd 206 York Street, Enola, PA June 21, 1987 21. The child was not bom out of wedlock. 22. The child is presently in the shared custody of both Plaintiff and Defendant, who both reside at, 206 York Street, Enola, Cumberland County, Pennsylvania. 23. In the last five years the child has resided with the following persons and at the following address: Name Plaintiff and Defendant Address Dates 206 York Street, Enola, PA birth to present. 24. The Plaintiff, the mother of the child, is residing at, 206 York Street, Enola, Cumberland County, Pennsylvania. She is married. 25. The Plaintiff currently resides with the following persons: Name Relationshln Henry C. Shepherd, Jr. Husband 26. The Defendant, the father of the child, is Henry C. Shepherd, Jr., residing at 206 York Street, Enola, Cumberland County, Pennsylvania. He is married. 27. The Defendant currently resides with the following persons: Name ~ Sandra A. Shepherd Wife 28. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 29. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 30. Plaintiff does not know of a perSon not a party to the proceedings who has physical custody of the child or claims to have custody or visitation right with respect to the child. 31. The best interest and permanent welfare of the child will be served by granting the relief requested because Mother has been primary care giver for the child's entire life. 32. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests this Honorable Com~ to order that the parties share custody arrangements as set fo~h in a proposed Custody Agreement which has been provided to the Defendant. COUNT IV - SUPPORT 33. Plaintiff hereby incorporates by reference avermen'~s 1 through 32 of this Complaint as if each averment were set forth fully hereunder. 34. The parties are the parents of the following unerrtancipated child who reside with Plaintiffand Defendant: Name Holly A. Shepherd 35. support. 36. -A~e Sex Date of Birth 17 Female June 21, 1987 Defendant is employed and has the income earning capacity to provide appropriate Defendant is obligated to provide for the reasonable support of his child. WHEREFORE, plaintiff respectfully requests that, pursuant to Section 3104(a)(3) and 3323(b) of the Divorce Code, an order of temporary child support be entered against the defendant until final hearing and permanently thereafter until such time as defendant is no longer legally obligated to contribute toward the support, and pursuant to Section 4351(a), appropriate counsel fees, filing fees and expenses. Date: Respectfully submitted, LAW OFFICES OF PETER J. RUSSO, P.C. Peter J. Russo, Esqt~e Scott A. Stein, Esquire 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 LAW OFFICES OF PETER J. RUSSO, P.C. PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 SCOTT A. STEIN, ESQUIRE PA Supreme Court ID: 81738 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 SANDRA A. SHEPHERD, : Plaintiff : -_ V. _. _. HENRY C. SHEPHERD, JR., : Defendant : Attomeys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -. LAW NO. 2004- IN DIVORCE CIVIL TERM VERIFICATION I, Sandra A. Shepherd, verify that the statements made ha the foregoing document are tree and correct. I understand that false statements made herein a~e subject to the penalties of 18 Pa.C.S. {}4904 relating to unswom falsification to authorities. Date: Sandra A. Shepherd LAW OFFICES OF PETER J. RUSSO, P.C. PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 SCOTT A. STEIN, ESQUIRE PA Supreme Court ID: 81738 3800 Market Street Camp Hill, PA 17011 (7~7) 59~4755 SANDRA A. SHEPHERD, Plaintiff HENRY C. SHEPHERD, JR., Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2004- IN DIVORCE CIVIL TERM CERTIFICATE OF SERVICE. I, Debra A. Mi¢ldo, hereby ceaify that I am on this day serving a copy of the foregoing documents upon the person (s) and in the manner indicated below; Service by Certified Mail, Restricted Delivexy, Postage Prepaid, and Addressed as Follows: Henry C. Shepherd, Jr. 206 York Street Enola, PA 17025 ebra A. Micklo, Paraiegal {/ sANDRA A. SBEPI~ERD, plaintiff HENRY C. SHEPHERD, JR., Defendant IN THE coURT OF coMMON PLEAS OF :cUMBERLAND couNTY, pENNSYLVANIA :NO. 2004-4558 CIVIL TERM : : C1VIL ACTION ' LAW :IN cUSTODY follows: Father, Henry C. Shepherd, Jr., .... ^ hepherd, andthe , -~ 987. Each parent The Mother, banma ¢,. S t. Shepherd, bom jun~ ~,, l to make all maior 1. , .... ~ leoal custody of Holly ,~ · the other parent, shall have snat~,~ ~, general well-being including, but not shall have an equal right, to be exercised jointly w~th health, education and religion- non-emergency decisions affecting the Child' s limited to, all decisions regarding her 2. Mother shall have primary physical custody of the Child. 3. Father shall have partial physical custody as follows, provided he maintains sobriety: mating weekends from Friday after school to Sunday at 9:00 p.m. A. ARe . -- ..... the narties agree. B. Such ot~er umc~ ,,o ather shall have physical custody ~, : ' - shall be shared such that F ~ a,,~her shall physical custo, dy of 4 tnanksgtvm~.. ~-~-..~dav at 3:15 p.m. ~"": .... A by the parttes. ,,,~-'~nesdav after school to tt~-7' ;/-:da'/evening at a time agt~,,,~ ¢ · from w~,~ ~, da'/at 3.15 p.m. t° r~' the child from lnurs y ' to Monday at times agreed by the part~es. · -'-~istmas shall be shared ~ a~ther shall have physical custody from 5. ~.c.t~---~o Eve until 10:00 p.m. t~"~he rest of the christmas holiday shall the child on Unnsunao to christmas Day. christmas Eve at 10:00 p.m. be shared as agreed. . ical custody of the child from ar'S Day. Father shall have ?~h~,~ shall have physical custody of o. New Ye , ~ t 3:15 p.m. New Year's Eve to New Year s t)ay a the child from New Year's Day at 3:15 until the start of school. ye nhvsical custody of the · ~ ~, ..... Da'/ Mother shall ha _ ~. ~,~,.,~ on Father' s Day. 7. Mother's Day./vau,~},~.'av~'nhysical custody o~ tl~e Child on Mother's Day. Famer snmt ~ ther shall have physical custody of the ~ . ~ - ~ divided such that F~ . ,, ~.,~ ~hvsic~ custody of the 8 ~aster sBau o~ ' ~ ~ ~ m Mother sBffii ~ta~ ' · a at iu:uup. · . . child from Frtda~ tosp¢2. 7 resumpUon of school child from Sat~aaY m tu.~ v. 9. Memorial Day shall be divided as agreed. 10. Transpoaation shall be shared such that the receiving pagy shall transpog. 11. Neither pagy may consume alcohol to the point of intoxication prior to or while the Child is in their custody. an~hing which may estr ~ ' nor he,it a ?ird pagy }o.do or say Neither paay will do or s~y ~&er p~Y, or injure the optmon of the ~ an-e the Child tromm Child as to Ce other parent or which may hmper the free and natural development of the Child's love and respect er the other parent. a reement of the pagies at a Custody 13. This Order is entered pursuant t~.~n.}~ ~.~,,;~i ns of this Order by mutual Conciliation Conference. The parties may mommy mc p ...... o consent. In Ce absence of mutual consent, the terms of this Order shall control. c .~cott A. Stein, Esquire, Counsel for Mother ¢A~enry C. Shepherd, Jr., pro se 1101 Lindham Ct. Apartment 102 Mechanicsburg, PA 17055 SANDRA A. SHEPHERD, plaintiff HENRY C. SHEPHERD, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2004-4558 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY 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 Holly A. Shepherd DATE OF BIRTH June 21, 1987 cuRRENTLY 1N CUSTODY OF Mother · 'liation Conference was held in this matter on October 14, 2004, 2.A .. .A C.onc}~ -Z--ce' The Mother, Sandra A. Shepherd, w~th her counsel, with the tollowlng m attenuaL, . ' Scott A. Stein, Esquire. Father did not appear. 3. Mother requested an Order in the form as attached. Date ~uire~ff--- Custody Conciliator