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HomeMy WebLinkAbout04-6473DAWN CELESTE SHUEY, MARK GARMAN SHUEY, Plaintiff : · NO. 04- Defendant : CUSTODY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL TERM COMPLAINT FOR CUSTODY 1. The plaintiff is Dawn Celeste Shuey, hereinafter refered to as Mother. Mother's permanent residence is 216 Reno Street, New Cumberland, Cumberland County, Pennsylvania 17070. 2. The defendant is Mark Garman Shuey, hereinafter referred to as Father. Father resides at 1919 Enfield Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Mother seeks custody of the minor children: Sallie Hannah Elizabeth Shuey Present Residence Age 216 Reno Street 5/1/1989 DOB, 15 years old New Cumberland, PA 17070 Jacob Garman Shuey 216 Reno Street 9/26/1993 DOB, 11 years old New Cumberland, PA 17070 Evan Winston Shuey 216 Reno Street 4/12/1996 DOB, 8 years old New Cumberland, PA 17070 All the children, Hannah, Jacob and Evan were bom during the parties' marriage. The children are presently in the custody of Mother. During the child's lifetime, Hannah Elizabeth Shuey has resided with the following persons and at the following addresses: Name Address Date Dawn Celeste Shuey Mark Garman Shuey 2733 North Fourth Street Harrisburg, PA 17110 Birth to 9/26/92 Dawn Celeste Shuey Mark Garman Shuey 1925 Enfield Street Camp Hill, PA 17011 9/26/92 - 9/26/93 Dawn Celeste Shuey Mark Garman Shuey Jacob Garman Shuey 1925 Enfield Street Camp Hill, PA 17011 9/26/93 - 4/12/96 Dawn Celeste Shuey Mark Garman Shuey Jacob Garman Shuey Evan Winston Shuey 1925 Enfield Street Camp Hill, PA 17011 4/12/96 - 10/14/03 Dawn Celeste Shuey Barry Lee Dando Jacob Garman Shuey Evan Winston Shuey 216 Reno Street Camp Hill, PA 17011 10/14/03 - present During the child's lifetime, Jacob Garman Shuey has resided with the following persons and at the following addresses: Name Address Date Dawn Celeste Shuey Mark Garman Shuey Hannah Elizabeth Shuey 1925 Enfield Street Camp Hill, PA 17011 Birth to 4/12/96 Dawn Celeste Shuey Mark Garman Shuey Hannah Elizabeth Shuey Evan Winston Shuey 1925 Enfield Street Camp Hill, PA 17011 4/12/96- 10/14/03 Dawn Celeste Shuey Barry Lee Dando Hannah Elizabeth Shuey Evan Winston Shuey 216 Reno Street New Cumberland, PA 17070 10/14/03 - present During the child's lifetime, Evan Winston Shuey has resided with the following persons and at the following addresses: Name Address Date Dawn Celeste Shuey Mark Garman Shuey Hannah Elizabeth Shey Jacob Garman Shuey 1925 Enfield Street Camp Hill, PA 17011 Birth to 10/14/03 Dawn Celeste Shuey Barry Lee Dando Hannah Elizabeth Shuey Jacob Garman Shuey 216 Reno Street New Cumberland, PA 17070 10/14/03 - present The parties are divorced from each other. 4. Mother currently resides with the following persons: Name Relationship Barry Lee Dando Fiance Hannah Elizabeth Shuey Daughter with Defendant Jacob Garman Shuey Son with Defendant Evan Winston Shuey Son with Defendant 5. Father currently resides with the following persons: Name Relationship Terry Webb Family Friend Scott Webb Family Friend Michael Webb Family Friend 6. 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. 7. Mother has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 8. Mother does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 9. The best interest and permanent welfare of the children will be served by granting the relief requested for reasons including, but not limited to the following: a) Mother can provide for the children's emotional, physical, educational, and medical needs and a stable home environment for the children. b) Mother and her fiance, Barry Dando, actively participate in parenting the children, assist the children with their schoolwork and attend school functions. c) Mother is the parent who can best facilitate any interaction between the children and the defendant. d) Father has not acted in the best interest of the child in ways including but not limited to the following: i) Father has a volatile temper that he cannot control, even in front of the children. ii) Mother obtained a Protection From Abuse Order against Father that is effective until April 24, 2005. iii) When Father gets angry, he is destructive and breaks furniture. During the course of the marriage, Father would wake the children so that they could watch him fight with Mother. This behavior scared the children and created an unhealthy environment for them. iv) On at least one occasion, Father attempted to intimidate Mother and children with his .357 Magnum by clicking the trigger as if he was preparing to fire the weapon. v) Following the entry of the Final Protection From Abuse Order, Father attempted suicide by overdosing on medication. vi) Father's instability confuses the children and would be even more unhealthy for them if they were exposed to such behavior on a daily basis. 11. Every person with rights to custody or having actual physical custody of the children has been named as parties to this action. WHEREFORE, Mother requests this Court to grant her the following reliefi 1) 2) 3) 4) 5) Grant the parties shared legal custody of the children. Grant Mother primary physical custody of the children. Grant Father periods of partial custody on alternating weekends, beginning at 6:00 p.m. on Friday and ending at 6:00 p.m. on Sunday. The exchange will begin with Mother delivering the children to Father at the beginning of the custodial periods and Father will return the children to Mother at the end of the custodial periods. Grant Father periods of partial custody on his non-custodial weeks, from 6:00 p.m. until 8:30 p.m. on Thursdays. Transportation will be the same as the weekend custodial exchanges. Grant the parties an appropriate holiday schedule as follows: a. The parties shall alternate physical custody of the children on Memorial Day, July 4, and Labor Day, with Mother having custody Labor Day in 2004. b. The parties shall alternate the Thanksgiving holiday each year from 9:00 a.m. until 9:00 p.m., with Father having custody in the even numbered years and Mother having custody in the odd numbered years. c. The parties shall alternate the Christmas holiday in two blocks. Block A will consist of a custodial period from December 24 at noon until December 25 at noon. Block B will consist of a custodial period from December 25 at noon until December 26 at noon. Mother shall have Block A in even numbered years and Father shall have Block B in even numbered years. d. Upon providing two weeks notice, Father shall have the children for two weeks each summer. During Father's two-week period of partial custody, if Father has not taken the children out of the area, Mother shall have a right to the children on the weekends. e. Mother will also be entitled to an extended summer vacation with the children, and such vacation may include up to two weekends away. f. Both parties will provide the other with current telephone numbers and addresses. This information will also be provided if and when the parties take the children on vacations. g. Any further relief that this Court finds to be just and proper. Jessica Diamondstone Attomey for Plaintiff Mid Penn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 VERIFICATION The above-named PLAINTIFF, DAWN CELESTE SHUEY, verifies that the statements made in the above complaint For Custody are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. c.s. §4904, relating to unsworn falsification to authorities. shuey DAWN CELESTE SHUEY, Vo MARK GARMAN SHUEY, Plaintiff Defendant ·IN THE COURT OF COMMON PLEAS OF ·CUMBERLAND COUNTY, PENNSYLVANIA 'NO. 04- CIVIL TERM CUSTODY AFFIDAVIT OF SERVICE BY MAIL I, Jessica Diamondstone, do hereby swear that I served Mark Garman Shuey with a Complaint For Custody on3r//~f ~ ? ,2004 by certified mail, return receipt, restricted delivery, to the person and address below: Mark Garman Shuey 1919 Enfield Street Camp Hill, PA 17011 I, Jessica Diamondstone, verify that the statements made in this Affidavit of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: j~' a~ ~'C)L/ Signature,~ · DAWN CELESTE SHUEY, Vo MARK GARMAN SHUEY, Plaintiff · 'NO. 04- 6 Defendant · CUSTODY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Dawn Celeste Shuey, Plaintiff, to proceed in forma pauperis. I, Jessica Diamondstone, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Jessi~!ndstone Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 DAWN CELESTE SHUEY PLAINTIFF Vo MARK GARMAN SHUEY DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COLINTY, PENNSYLVANIA 04-6473 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, January 03, 2005 , 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, February. 01, 2005 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. 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 hearing. FOR THE COURT, By: /s/ .[acqueline M. Vernt~y~ 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 170113 Telephone (717) 249-3166 DAWN CELESTE SHUEY, Vo MARK GARMAN SHUEY, Plaintiff Defendant 8 2004 z IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04- (aq'73I CIVIL TERM CUSTODY ORDER OF COURT AND NOW, 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 ~md 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 zmd all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. By the Court, Date: Custody Conciliator 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, PA 17013 (717) 249-3166 OR (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, Pease 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 con:terence or hearing. DAWN CELESTE SHUEY, Vo MARK GARMAN SHUEY, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04- ~ ~-/7_;~ CIVIL TERM CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Dawn Celeste Shuey, hereinafter refered to as Mother. Mother's permanent residence is 216 Reno Street, New Cumberland, Cumberland County, Pennsylvania 17070. 2. The defendant is Mark Garman Shuey, hereinafter retErred to as Father. Father resides at 1919 Enfield Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Mother seeks custody of the minor children: SalTle Hannah Elizabeth Shuey Present Residence Age 216 Reno Street 5/1/1989 DOB, 15 years old New Cumberland, PA 1.7070 Jacob Garman Shuey 216 Reno Street 9/26/1993 DOB, 11 years old New Cumberland, PA 17070 Evan Winston Shuey 216 Reno Street 4/12/1996 DOB, 8 years old New Cumberland, PA 17070 All the children, Hannah, Jacob and Evan were bom during the parties' marriage. The children are presently in the custody of Mother. During the child's lifetime, Hannah Elizabeth Shuey has resided with the following persons and at the following addresses: Name Address Date Dawn Celeste Shuey Mark Garman Shuey 2733 North Fourth Street Harrisburg, PA 17110 Birth to 9/26/92 Dawn Celeste Shuey Mark Garman Shuey 1925 Enfield Street Camp Hill, PA 17011 9/26/92 - 9/26/93 Dawn Celeste Shuey Mark Garman Shuey Jacob Garman Shuey 1925 Enfield Street Camp Hill, PA 17011 9/26/93 - 4/12/96 Dawn Celeste Shuey Mark Garman Shuey Jacob Garman Shuey Evan Winston Shuey 1925 Enfield Street Camp Hill, PA 17011 4/12/96 - 10/14/03 Dawn Celeste Shuey Barry Lee Dando Jacob Garman Shuey Evan Winston Shuey 216 Reno Street Camp Hill, PA 17011 10/14/03 - present During the child's lifetime, Jacob Garman Shuey has re, sided with the following persons and at the following addresses: Name Address Date Dawn Celeste Shuey Mark Garman Shuey Hannah Elizabeth Shuey 1925 Enfield Street Camp Hill, PA 17011 Birth to 4/12/96 Dawn Celeste Shuey Mark Garman Shuey Hannah Elizabeth Shuey Evan Winston Shuey 1925 Enfield Street Camp Hill, PA 17011 4/12/96- 10/14/03 Dawn Celeste Shuey Barry Lee Dando Hannah Elizabeth Shuey Evan Winston Shuey 216 Reno Street New Cumberland, PA 170'70 10/14/03 - present During the child's lifetime, Evan Winston Shuey has resided with the following persons and at the following addresses: Name Address Date Dawn Celeste Shuey Mark Garman Shuey Hannah Elizabeth Shey Jacob Garman Shuey 1925 Enfield Street Camp Hill, PA 17011 Birth to 10/14/03 Dawn Celeste Shuey Barry Lee Dando Hannah Elizabeth Shuey Jacob Garman Shuey 216 Reno Street New Cumberland, PA 171)70 10/14/03 - present The parties are divorced from each other. 4. Mother currently resides with the following persons: Nalne Barry Lee Dando Hannah Elizabeth Shuey Jacob Garman Shuey Evan Winston Shuey Relationship Fiance Daughter with Defendant Son with Defendant Son with Defendant Name Terry Webb Scott Webb Michael Webb Father currently resides with the following persons: Relationship Family Friend Family Friend Family Friend 6. 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. 7. Mother has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 8. Mother does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 9. The best interest and permanent welfare of the children will be served by granting the relief requested for reasons including, but not limited to the following: a) Mother can provide for the children's emotional, physical, educational, and medical needs and a stable home environment for the children. 11. b) Mother and her fiance, Barry Dando, actively participate in parenting the children, assist the children with their schoolwork and attend school functions. c) Mother is the parent who can best facilitate any interaction between the children and the defendant. d) Father has not acted in the best interest of the child in ways including but not limited to the following: i) Father has a volatile temper that he cannot control, even in front of the children. ii) Mother obtained a Protection From Abuse Order against Father that is effective until April 24, 2005. iii) When Father gets angry, he is destructive and breaks furniture. During the course of the marriage, Father would wake the children so that they could watch him fight with Mother. This behavior scared the children and created an unhealthy environment for them. iv) On at least one occasion, Father attempted to intimidate Mother and children with his .357 Magntrrn by clicking the trigger as if he was preparing to fire the weapon. v) Following the entry of the Final Protection From Abuse Order, Father attempted suicide by overdosing on medication. vi) Father's instability confuses the clfildren and would be even more unhealthy for them if they were exposed to such behavior on a daily basis. Every person with fights to custody or having actual physical custody of the children has been named as parties to this action. WHEREFORE, Mother requests this Court to grant her the following relief: 4) 5) Grant the parties shared legal custody of the children. Grant Mother primary physical custody of the children. Grant Father periods of partial custody on altemating weekends, beginning at 6:00 p.m. on Friday and ending at 6:00 p.m. on Sunday. The exchange will begin with Mother delivering the children to Father at the begimfing of the custodial periods and Father will return the children to Mother at the end of the custodial periods. Grant Father periods of partitfl custody on his non-custodial weeks, from 6:00 p.m. until 8:30 p.m. on Thursdays. Transportation will be the stone as the weekend custodial exchanges. Grant the parties an appropriate iholiday schedule as follows: a. The parties shall alternate physical custody of the children on Memorial Day, July 4, and Labor Day, with Mother having custody Labor Day in 2004. b. The parties shall alternate the Thanksgiving holiday each year from 9:00 a.m. until 9:00 p.m., with Father having custody in the even numbered years and Mother having custody in the odd numbered years. c. The parties shall alternate the Christmas holiday in two blocks. Block A will consist of a custodial period from 1) 2) 3) December 24 at noon until December 25 at noon. Block B will consist of a custodial period from December 25 at noon until December 26 at noon. Mother shall have Block A in even numbered years and Father shall have Block B in even numbered years. d. Upon providing two weeks notice, Father shall have the children for two weeks each summer. During Father's two-week period of partial custody, if Father has not taken the children out of the area, Mother shall have a right to the children on the weekends. e. Mother will also be entitled to an extended summer vacation with the children, and such vacation may include up to two weekends away. f. Both parties will provide the other with current telephone numbers and addresses. This information will also be provided i[f and when the parties take the children on vacations. g. Any further relief that this Court finds to be just and proper. Jessica Diamondstone Attorney for Plaintiff Mid ]?enn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 VERIFICATION The above-named PLAINTIFF, DAWN CELESTE SHUEY, verifies that the statements made in the above complaint For Custody are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. c.s. §4904, relating to unsworn falsification to authorities. Celeste shuey DAWN CELESTE SHUEY, Vo MARK GARMAN SHUEY, Plaintiff Defendant · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04- CIVIL TERM CUSTODY AFFIDAVIT OF SERVICE BY MAIL I, Jessica Diamondstone, do hereby swear that I served Mark Garman Shuey with a Complaint For Custody on..]~/~.~,~ ,~ ? ,2004 by certified mail, return receipt, restricted delivery, to the person and address below: Mark Garman Shuey 1919 Enfield Street Camp Hill, PA 17011 I, Jessica Diamondstone, verify that the statements made in this Affidavit of Service are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: j~' a~ 3r'C~/ Signature: ..--~/~/~~ DAWN CELESTE SHUEY, Vo MARK GARMAN SHUEY, Plaintiff · · NO. 04- 6 Defendant · CUSTODY DEC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL TERM 2004 PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Dawn Celeste Shuey, Plaintiff, to proceed in forma pauperis. I, Jessica Diamondstone, attorney for the party proceeding in forma paupefis, certify that I believe the party is unable to pay the costs and that I am pn)viding free legal services to the party. Jcss~o~ Diamondstonc Atto~e¥ fo~ Plaintiff MiclPc~ Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 DAWN CELESTE SHUEY, PENNSYLVANIA Vo MARK GARMAN SHUEY, Plaintiff Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, · CUSTODY 73 CWIL TERM AMENDED AFFIDAVIT OF SERVICE BY MAIL I, Jessica Diamondstone, do hereby swear that I served Mark Garman Shuey with a Complaint For Custody on January 10, 2005, by certified mail, return receipt, restricted delivery, to the person and address below: Mark Garman Shuey 1919 Enfield Street Camp Hill, PA 17011 I, Jessica Diamondstone, verify that the statemen~Is made in this Affidavit of Service are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date:' c>~ ~--' Signature; ?-"/,/.~_. )- fEB 1 0 2005 ,.J ?11 DAWN CELESTE SHUEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2004-6473 CIVIL TERM MARK GARMAN SHUEY, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this \ \ day of 1iiI.M. /__ ,2005, upon consideration ofthe attached Custody Conciliation Report, it is ordered and directed as follows: l. The custody provisions of the PFA entered at Docket No. 03-5413 are hereby vacated. 2. The Mother, Dawn Celeste Shuey, and the Father, Mark Garman Shuey, shall have shared legal custody of Hannah Elizabeth Shuey, born May 1, 1989, Jacob Garman Shuey, born September 26,1993 and Evan Winston Shuey, born April, 12, 1996. 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 h(~alth, education and religion. 3. Mother shall have primary physical custody of the children. 4. Father shall have periods of partial physical custody as follows: A. Alternating weekends from Friday at 6:00 p.m. to Sunday at 6:00 p.m. B. On weeks when Father does not have w€:ekend custodial periods with the children, he shall have physical custody on Thursday evenings from 6:00 p.m. to 8:30 p.m. C. Such other times as the parties agree. 5. Father shall be responsible for all transportation. 6. The parties shall alternate major holidays to include Memorial Day, July 4th and Labor Day. Father shall begin with custody on Memorial Day in 2005. 7. The parties shall alternate the Easter holiday each year from 9:00 a.m. to 9:00 p.m. Mother shall have odd numbered years and Father shall have even numbered years. 8. The parties shall alternate the Thanksgiving holiday each year from 9:00 a.m. to 9:00 p.m. Mother shall have odd numbered years and Father shall have even numbered years. 9. The Christmas holiday shall be divided into two alternating Blocks, Block A being from December 24 at 12:00 noon until Christmas Day at 12:00 noon, and Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years and Father shall have Block A even numbered years and Block B in odd numbered years. 10. Mother shall have custody of the children on ]l.1other's Day and Father shall have custody of the children on Father's Day. 11. Upon providing two weeks notice, Father shall have custody of the children for two weeks each summer. During Father's summer visits, if the children remain in the area, Mother shall have a right to the children on the weekends. 12. Upon providing two weeks notice, Mother shall have the children during the summer for an extended period of vacation which may include up to two weekends away. During Mother's extended vacation, if the children remain in the area, Father shall have the right to exercise his regularly scheduled periods of custody on the weekend. 13. The parties shall notify the other immediately of medical emergencies that arise while the children are in that parent's care. 14. The parties shall keep each other informed as to their current address and telephone number. This shall also apply when the parties take the children on vacations. 15. Neither party shall do or say anything or permit a third party to do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Each party shall encourage a meaningful relationship with the other party. Both parties shall provide the children with a "safety zone" by discouraging third parties from making negative remarks about either parent when the children are within earshot. 16. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions ofthis Order by mutual consent. In t absence of mutual consent, the terms of this Order shall control. BY THE COURT, .' ..... .:r 9 ~ - - '8 u-- ~ /,\~ ;~~ ---------- cc: Jessica Diamondstone, Esquire, Counsel for Mother > '" Mark Garman Shuey, pro se C-~ ~ ;J - i:Y o~ 1919 Enfield Street CampHiIl,PA 17011 ~. DAWN CELESTE SHUEY, Plaintiff FES 1 0 2005 ~ {f~ : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2004-6473 CIVIL TERM MARK GARMAN SHUEY, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edgar B. Bayley, 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: L The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Harmah Elizabeth Shuey Jacob Garman Shuey Evan Winston Shuey May 1, 1989 September 26, 1993 April 12, 1996 Mother Mother Mother 2. A Conciliation Conference was held in this matter on February 10, 2005, with the following individuals in attendance: The Mother, Dawn Celeste Shuey, with her counsel, Jessica Diamondstone, Esquire, Mid Penn Legal Services. Father was not present although he received notice of the conference. 3. The Honorable Edgar B. Bayley entered an Order of Court dated October 24,2003 in a PFA matter at Docket No. 2003-5413. Said Order included a custody provision. The PF A expires April 24, 2005. 4. Mother requested an Order in the form as attached. J.-I()~O~ Date L__~~ M ~~/ ~,f. Verney, Esquire Custody Conciliator