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Home My WebLink About05-0989 DOUGLAS E. SHAND Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. OS- - 9139 {!/ C>~ l /'€1<-l LISA M. SHAND, Defendant :CUSTODY COMPLAINT FOR CUSTODY } AND NOW this If? day of February, 2005, comes Plaintiff, Douglas E Shand, by and through counsel, Lawrence 1. Rosen, Esquire, and offers the following averments in support of the within Complaint: I. Plaintiff is Douglas E. Shand residing at 5 I" Avenue, Wormleysburg, PA 2. Defendant is Linda Kirby residing at 125 Altoona Avenue, Enola, PA 17025 3. Petitioner seeks custody of the following children: NAME Douglas E. Shand, Jr. Ryan James Shand PRESENT ADDRESS 125 Altoona Ave., Enola, PA 125 Altoona Ave., Enola, Pa AGE 16 9 Douglas E. Shand, Jr. and Ryan James Shand were not born out of wedlock.. The children are presently in the physical custody of Defendant who resides at 125 Altoona Avenue, Enola, PA 17025. During the past five years, the children have resided at/with: Oct, 04 - Present April, 03 - Oct, 04 Prior to April, 03 125 Altoona Ave., Enola, PA State St., West Fairview, PA 20 Corsatt St., Enola, PA Defendant, Josh Diener Defendant, Josh Diener Plaintiff and Defendant The mother of the children is Lisa M. Shand who currently resides at 125 Altoona Avenue, Enola, PA 17025. She is not married. The Father of the children is Douglas E. Shand who currently resides at 5 1 " Avenue, Wormleysburg, PA He is not married. 4. The relationship of Plaintiff to the children is that of father. Plaintiff currently resides with Terrie Bryce. 5. The relationship of Defendant to the children is that of mother. Defendant currently resides with Josh Diener. 6. Plaintiff 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. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff 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. 7. The best interests and permanent welfare of the children will be served by granting the relief requested because the children are best served by having a regular opportunity to visit with their father. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody ofthe children have been named as parties to this action. WHEREFORE, Plaintiff requests the court to grant him shared legal and periods of partial physical custody of the minor children, Douglas E. Shand, Jr. and Ryan James Shand. Respectfully submitted: KREVSKY & ROSEN, P.C. By: nce J. Rosen, Esquire 1101 orth Front Street Harrisburg, PA 17102 ID# 10625 (717) 234 4583 DOUGLAS E. SHAND, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. LISA M. SHAND Defendant :CUSTODY I, DOUGLAS E. SHAND, hereby verify that the information contained in the foregoing Complaint for Custody is true and correct to the best of my knowledge, information and belief. I also understand that false statements made herein are subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. DATE: 2-1 (01 t) S" ~E~~ , DOUGLAS E. SHAND, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. LISA M. SHAND, Defendant :CUSTODY CERTIFICATE OF SERVICE r- AND NOW, this ~ day of February, 2005, I, Kami Cramer, for the law firm of Krevsky & Rosen, P.C., hereby certify that I have this day served a copy of the Complaint in the above-captioned matter, by U.S. FIRST CLASS CERTIFIED MAIL on the following: LISA M. SHAND 125 AL TOONA AVENUE ENOLA, P A 17025 t~c1~ Krevsky & Rosen, P.C. 1101 North Front Street Harrisburg, PA 17102 (717) 234-4583 -{q. () ::::. T{ ~ -- \) o ~ o ~ C> w -0 V( o ~ E --L , \, t_';),. S_~-\ n --~ 9 -,- -'f1 ~ :._\ \~}. '-, I~,~", :t) -, -- .- (n o^", ,:":'.l I"~ PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA DOUGLAS E. SHAND v. 05-989 CIVIL ACTION LA W LISA M. SHAND DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, ___.__ Wednesday, March 02,-~005__._, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa p, Greevy, Esq. , the conciliator, at OJ Manlove's, t901 State St" Camp Hill, P~701~ on Friday, March 18,2005 ------------.--.---..---"-- at 11:30 AM ---- for a Pre-Hearing Custody Conference. At such (:on/erence, 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 cnter into a tcmporary order. All children age live or older may also be present at the conference. Failure to appear at the conference mav 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: Isl Melissa P. Greevy, Esq. Custody Conciliator f 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 ofl1ce. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conterence or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR A HORNEY 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 Telepbone (717) 249-3166 ~. ~ -? ~JW ~Jrl ('.f" .~ ~ ~ 0/11, 9~[ ~/ fr%~tiPlP11 5'?d V!i0i',:,!F"11(:' 'L'" }J.NnC(~ I ~~~\2..~~~ ~~;~:t~;;J S"I:J:' 1.1' v ,,0 Z- (l\fP Cil,'7 ~.1... l,j-.. ~_.._..~,w_....-..-._--_...-"'" - " Plaintiff MAR 2 8 200\cf IN THE COURT OF COMMO PLEAS OF CUMBERLAND COUNTY, PE NSYLVANIA NO. 05-9891CIVIL T RM , I CIVIL AClIlON - L W I IN CUhODY i DOUGLAS E. SHAND, v. LISA M. SHAND, Defendant ORDER OF COURT AND NOW, this 3t,t'"' day of March, 2005, upon conside ation of the attached Custody Conciliation Summary Report, it is hereby ordered and direct d as foil ws: 1. Leaal Custodv. The parties, Douglas E. Shand and Lisa M. Sha d, shall have shared legal custody of the minor children, Douglas E. Shand, Jr., bor Decem er 30, 1988, and Ryan James Shand, born March 20,1995. Each parent shall hav an equal right, to be exercised jointly with the other parent, to make all major non-emerge cy decis ons affecting the children's general well-being including, but not limited to, all de isions r garding their health, education and religion. Pursuant to the terms of 23 Pa. C. . 95309 each parent shall be entitled to all records and information pertaining to the children incl ding, but not limited to, medical, dental, religious or school records, the residence a dress the children and of the other parent. To the extent one parent has possession 0 any su h records or information, that parent shall be required to share the same, or co ies the eof, with the other parent within such reasonable time as to make the record and i formation of reasonable use to the other parent. 2. Phvsical Custodv. Mother shall have primary physical ustody. Father shall have rights of partial custody which shall be arranged as follows: A. Effective March 26, 2005, each Saturday commen ing at 1 :00 a.m. B. At such other times as the parties may agree. 3. Reasonable Telephone Contact. Both parties shal have he right to reasonable telephone contact with the children during the oth r party' period of custody/visitation. The children may initiate a telephone call to the non-cus odial parent upon their request. Neither party shall interfere with the other party's teleph ne contacts with the children. Each party shall make all reasonable efforts to pr mptly r turn calls or messages left by the other party regarding the children. ... NO. 05-989 CIVIL TERM i I 4. Father and the boys shall participate in therapeutic i family ounseling to address the estrangement which exists in their relationship. Mother ~hall giv her voice of support to Father's efforts to work on reconciling and developing a h~althY rei tionship with the boys. . BYTH J. Dis!: ~wrence J. Rosen, Esquire, 1101 N. Front Street, Harrisburg, PA 17102 ~a M. Shand, 125 Alloona Avenue, Enola, PA 17025 :\0 ()~:J li\t,..."-,, '\;..:'." ' 10 iW) ,<L\'lD~'~~)> ,ror i :',.,l,;::: I A \n n~ f..";,'"'- ::, Q'Jh ...U'JG 'J -" " 1.\),:.;' ::.,.-1..!. ~1 '(~-J~H ,. 1;"'.'1 ,: 11_' ", -. , ~~ Plaintiff MAR 2 B 20Uit IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PEN SYLVANIA NO. 05-989 qlVlL TE CIVIL ACTI?N - LA i IN CU~ODY . DOUGLAS E. SHAND, v. LISA M. SHAND, Defendant CUSTODY CONCILIATION SUMMARY REPOR IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL P 1915.3-8, the undersigned Custody Conciliator submits the following r port: 1. The pertinent information concerning the child who i the litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN HE CU TODY OF Douglas E. Shand, Jr. Ryan James Shand December 30,1988 March 20,1995 Mother Mother 2. Father filed a Complaint for Custody on February 2 ,2005. A Custody Conciliation Conference was held on March 18, 2005. Present for the confere ce were: the Father, Douglas E. Shand, and his counsel, Lawrence J. Rosen, Es uire; th Mother, Lisa M. Shand, participated pro se. 3. attached. The parties reached an agreement in the form of a Tempo ary Order as .3L /05 Melissa Peel reevy, E quire Custody Conci iator Date :247044