HomeMy WebLinkAbout05-2983
HARVEY MONROE SHULER, III : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. O S - oZ?IP.3 ?f u • l
ROBIN M. RONEMUS-SHULER, : CIVIL ACTION - LAW L
Defendant
IN CUSTODY
COMPLAINT FOR CUSTODY
AND NOW, comes your Plaintiff, Harvey Monroe Shuler, III, by and through his
attorneys, Mancke, Wagner & Spreha, and files the following Complaint:
Your Plaintiff is an adult individual having an address of 30 Meadow Brook
Road, Carlisle, Cumberland County, Pennsylvania.
2. Defendant, Robin Shuler, is an adult individual having as an address 4
Central Boulevard, Camp Hill, Cumberland County, Pennsylvania.
The parties are the natural parents of Heather M. Shuler, born September 25,
1998.
4. The child was born during wedlock.
5. The Plaintiff is the father of the child; Defendant is the natural mother of
the child.
6. Plaintiff is aware of no other person who has a claim to custody or partial
custody of the child.
7. The child has resided with the Defendant at the address contained in
Paragraph 2 for approximately nine months; prior thereto with Plaintiff and Defendant for
a short period of time; prior thereto with the Defendant at the address contained in Paragraph
2 giving jurisdiction to Cumberland County.
8. Plaintiff was the subject to an agreed upon PFA, wherein primary physical
custody of the child was awarded to the Defendant herein, subject to partial physical custody
supervised at the Carlisle YWCA in the Plaintiff.
9• Plaintiff believes and therefore avers it is in the best interest of the child to
grant unto Plaintiff shared legal custody and periods of partial custody which are not
necessary to be supervised and which can be accomplished by the Plaintiff.
10. Plaintiff believes he is capable of caring for the needs of the child during any
periods of partial custody.
WHEREFORE, Plaintiff requests the Court to grant his relief in the form of granting
Petitioner shared legal custody and partial physical custody of the daughter Heather.
Respectfully submitted:
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
ID #23103
VERIFICATION
I verify that the statements made in the foregoing
document 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.
?J
DATE: 5-.2,3-05
s?
rnr-.
(? G 'ice
a j
HARVEY MONROE SHULER, III IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
ROBIN M. RONEMUS-SHULER
DEFENDANT
05-2983 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Wednesday, June 15, 2005 , 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 DJ Manlove's, 1901 State St., Camp Hill, PA 17011 on Friday, August 05, 2005 at 9:00 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/ Melissa A GreevyEsq.
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
VIN`,SI ;SNN-lc
!Pal %ino
L sZ qd 91 NA N01
'a Jo
HARVEY MONROE SHULER, III
Plaintiff/Petitioner
V.
ROBIN M. RONEMUS-SHULER
Defendant/Respondent
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
NO: 05-2983
CIVIL ACTION - LAW
IN CUSTODY
PETPCION FOR INTER U4 L
AND NOW, comes Harvey Shuler, by and through his attorneys, Mancke, Wagner
& Spreha, and files the following Petition for Interim Relief:
1. The Petitioner is the Plaintiff in the above-captioned custody action.
2. The Respondent, is the Defendant in the above-captioned custody action.
3. The parties appeared for a custody conciliation on Friday, August 5, 2005, at
9:00 a.m. concerning the Complaint that Petitioner filed for custody of his daughter,
Heather, bom September 25, 1998.
4. Petitioner has not seen his daughter since April of 2005.
5. At the time of the custody conference, the Respondent herein would agree only
to periods of supervised visitation at the YWCA in Carlisle, Cumberland County,
Pennsylvania, which said schedule would, by virtue of the Petitioner's work schedule,
permit only a Monday afternoon for a one (1) hour period of visitation with his daughter.
10. Petitioner believes and therefore avers that it is in the best interests of the
parties that a custody evaluation be undertaken involving the underlying custody
complaint filed by the Petitioner.
11. Petitioner believes and therefore avers that pending the outcome of that
custody evaluation, he should be awarded periods of partial custody without supervision,
which currently is one (1) hour per week at the YWCA.
12. Petitioner further respectfully requests the Court to award a partial distribution
of the aforementioned Morgan Stanley to pay for the custody evaluation by the parties.
WHEREFORE, Petitioner prays this Court to grant the relief as requested in the
form of the following:
A. Ordering the parties to undergo a custody evaluation;
B. Provide a period of partial custody outcome of the custody evaluation;
C. Direct that the Morgan Stanley account be utilized for purposes of fees
associated with the aforementioned evaluation; and
-3-
VERIFICATION
I verify that the statements made in the foregoing
document 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:
?? ? c
(?(? N C. cJl -`t
/J r
' ^
v , ? ? ';
i1-?
?.
`
_-
;'?;
,-?_-. v0
r_?
U?
RECEIVED AUG 23 VMr
HARVEY MONROE SHULER, III, IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 05-2983 CIVIL TERM
V.
CIVIL ACTION - LAW
ROBIN N. RONEMUS-SHULER,
IN CUSTODY
Defendant
HESS, J. ---
ORDER OF COURT
AND NOW, this ?2Jr day of August, 2005, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. The parties shall submit themselves and their minor child to an independent
custody evaluation to be performed by Stanley Schneider, Ed. D. The parties shall sign all
necessary releases and authorizations for the evaluator to obtain medical, psychological,
and chemical dependency information pertaining to the parties. Additionally, the parties
shall extend their full cooperation in completing this evaluation in a timely fashion and in the
scheduling of appointments.
2. A brief hearing is scheduled in C urtroom Number 4 of the Cumberland
County Courthouse, on the -Vt?l_ day of , 2005, at 3 %OZ)
o'clock P .M., at which time testimony will be to en. The purpose of the hearing will be to
hear Father's request for an advancement in equitable distribution on the parties' Morgan
Stanley account to fund the costs of the custody evaluation with reservation of the right to
argue re-allocation of the expenses of the custody evaluation between the parties. Counsel
for the parties or the parties pro se shall file with the Court and opposing counsel/party a
memorandum setting forth each party's position, and a summary of the anticipated
testimony of each witness. These memoranda shall be filed at least ten days prior to the
hearing date.
BY THE COURT:
J.
Dist: Shaubut C. Walz, 111, Esquire, 341 Market St., Newbort, PA 17074-1509
P. Richard Wagner, Esquire, 2233 North Front St., Harrisburg, PA 17110 ?? Yl w
Dr. Stanley Schneider, Guidance Associates, 412 Erford Road, Camp Hill, PA 17011 S. 14 b 1
HLED -O°TICE
OF THE FF0T-`K,0'ARY
2005 AUG 29 f`??4 10: 50
CU, Y
RECEIVED AUG 23 700tJ'
HARVEY MONROE SHULER, III,
Plaintiff
V.
ROBIN N. RONEMUS-SHULER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-2983 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the child who is the subject of this
litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF
Heather M. Shuler September 25, 1998 Mother
2. Father filed a Complaint for Custody on June 9, 2005. A Custody Conciliation
Conference was scheduled on August 5, 2005 with the following individuals in attendance:
the Father, Harvey M. Shuler, III, and his counsel, P. Richard Wagner, Esquire; the Mother,
Robin N. Ronemus-Shuler, and her counsel, Judith Walz, Esquire. Mrs. Walz represented
Mrs. Shuler at the conference. However, at the upcoming hearing, Mrs. Shuler will be
represented by Shaubut C. Walz, III, Esquire.
3. Father's position on custody is as follows: Father's counsel recites a lengthy
and volatile history of the parents' relationship with breakups, allegations of drug abuse,
allegations of violence and conflict interspersed with several reconciliation attempts. At
present the Father has not seen the child since April 2005. Counsel does not view the
court's interventions as having been helpful in the past. Rather, he finds that litigation tends
to "stir the pot" of their ongoing conflicts. Father denies that he is using drugs. He reports
that he has been abstinent for one year. He also points out that his ex-wife does not have
any concerns about the partial custody periods he enjoys with their children other than
concerns with regard to how Father's new spouse treats the children. Father would like to
resume periods of partial custody pending a custody evaluation. The evaluation is thought
to be needed to address the parents' chronic conflict and the ongoing impact on the child. It
is hoped that the recommendations of the evaluator will assist the parties in addressing the
child's emotional needs. Father agreed that Mother's allegations regarding substance
abuse be addressed as to both of them as part of an overall custody evaluation. Father
would like to return to an alternating weekend partial custody schedule during the period of
the custody evaluation. With regard to the expenses related to the custody evaluation,
NO. 05-2983 CIVIL TERM
Father proposes to be allowed to take an advancement from the parties' Morgan Stanley
account with the understanding that this would be credited to him in distribution and that
each party would reserve the right to make their arguments regarding the allocation of the
fees associated with the custody evaluation. Father cannot afford to advance the counsel
fees from his income because he is netting $2,650.00 per month prior to his child support
obligation. It appears that one of the differences in the parties' approach to the problems
that they are experiencing is that Father is taking a longer term view with regard to the
parties' conflict and its impact on the child. In addition, Father's counsel recognizes that the
issues that challenge this couple are not likely able to be fully addressed or resolved by
further litigation in the absence of clinical intervention.
4. Mother's position on custody is as follows: Mother reports that the child's
school performance has improved since the parties separated. The child was apparently
doing poorly and had risked failing prior to separation. Mother claims that the child has
bounced back academically the last few months of the last academic year. Mother thinks
that the reuniting of Father and the child should be accomplished through supervised
visitation initially because the child's last interaction with Father was during the conflict and
altercation between the parties which immediately preceded the Protection From Abuse
Order which is in place until November 2006. Mother points out that Father has not elected
to participate in the supervised visitation program provided at the Carlisle YWCA as
indicated in the PFA which is docketed to 05-2983. Mother claims that Father uses cocaine
and she believes that he started using drugs again about March 2005. She also reports that
the child has been fearful at night and has expressed wonder as to whether Father is
coming for her when she hears noises in the night. Mother objects to the use of Morgan
Stanley monies as an advancement to pay the evaluation costs because she does not
believe the evaluation is necessary and because, although the funds in this account are
presently held in both parties' names, the original source of the funds was her inheritance
which she later converted into a joint investment account. Mother does not believe that she
can participate in the cost of the evaluation because she is employed making about $10.00
per hour. For domestic relations purposes, her presumed earning capacity is approximately
$1,650.00 net per month. Mother proposed that Father participate in supervised visits for
approximately 8 weeks to see how it goes. She attributes all of the problems to Father's
alleged use of cocaine and his alleged abuse.
5. Issues upon which the parties agree: Father will initiate supervised visitation
at the Carlisle Y two times per week as provided in the PFA. The parties will participate in a
custody evaluation.
6. Issues upon which the parties do not agree: The source of funding for the
evaluation and whether or not Father could obtain an advancement against the Morgan
Stanley account for purposes of funding the evaluation understanding that both parties have
the right to argue how the advancement should be allocated as between them in the
custody litigation.
NO. 05-2983 CIVIL TERM
7. The Conciliator recommends that the parties be granted a 45-minute hearing
to address the funding of the custody evaluation. The parties will participate in supervised
visits at the YWCA.
a /010S
Date
'Cluj Peel Greevy, Esquire
Custody Conciliator
MPG:ead:256400
RECc"; ?C " r?C51?
HARVEY MONROE SHULER, III IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff/Petitioner
v.
ROBIN M. RONEMUS-SHULER
Defendant/Respondent
NO: 05-2983
CIVIL ACTION - LAW
IN CUSTODY
RDER
AND NOW, this ,.;?O4day of 4?? , 2005, upon Petition of
Harvey Shiner, a hearing is set for the _L j M day of j alte?m.641,/ , 2005, at
?; 6C) o'clock -,,I m. in Courtroom No. V of the Cumberland County Courthouse,
One Courthouse Square, Carlisle, Pennsylvania, to show cause why, if any, the Petition
for Relief in the form of requesting an interim period of partial custody and a custody
evaluation should not be granted.
C.
C?
BY THE COURT:
6s :G WV I z d3s SGOI
Kdvjo^?Gra a4d m do
33U40--a3llj
NOV 0 R 10)5
HARVEY MONROE SHULER, III,
Plaintiff
IN THE COURW: OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-2983 CIVIL TERM
V.
ROBIN N. RONEMUS-SHULER,
Defendant
HESS, J. ---
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 3~' day of November, 2005, upon consideration of the
attached Custody Conciliation Summary Report, it is hereby ordered and directed as
follows:
1. The parties will contact the Carlisle YWCA Visitation Program at the number
provided to them at the time of the Conference and schedule and attend four (4) supervised
visits prior to the hearing on November 18, 2005. In the event that Father is going to be
delayed in his arrival time due to traffic or mechanical problems, Father will contact the
YWCA to inform them of such delay.
BY THE COURT:
Dist:
I vin A. Hess, J.
dith : Walz, III, Esquire, 341 Market St., Newport, PA 17074-1509
P ichard Wagner, Esquire, 2233 North Front St., Harrisburg, PA 17110
BOA
10, :3 WV "i- AGN 3007
HARVEY MONROE SHULER, III,
Plaintiff
V.
NOV 0 3 611,1)
IN THE COURT OF
CUMBERLAND COL
NO. 05-2983 CIVIL TERM
CIVIL ACTION - LAW
ROBIN N. RONEMUS-SHULER,
Defendant
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
VAN IA
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the child who is the subject of this
litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF
Heather M. Shuler September 25, 1998 Mother
2. The parties convened for their second Custody Conciliation on October 27,
2005 which was scheduled at the request of Father's counsel because the supervised visits
that had been contemplated in this Court's Order of August 25, 2005 ended after three (3)
visits. Present for the Conference were: the Father, Harvey M. Shuler, III, and his counsel,
P. Richard Wagner, Esquire; the Mother, Robin N. Ronemus-Shuler, and her counsel,
Judith T. Walz, Esquire.
3. Father's position on custody is as follows: Father reports that he has had no
further visits in September or October because the child was enrolled in Brownies on the
one night of the week which he could participate in supervised visits at the Carlisle YWCA.
Father would like to discontinue the supervised visits and proposes that he have three (3)
weekends out of four (4) from Fridays after school or work, until Monday when the child is
returned to school.
4. Mother's position on custody is as follows: Mother would like the supervised
visits to continue at this time. She is not agreeable to even very brief periods of
unsupervised partial custody. She will not agree to the weekend periods of custody Father
proposed above. Mother also points out through correspondence between counsel, Father
was informed that Brownies meetings were only on the second and fourth Mondays.
Accordingly, Father could have continued supervised visits on the days when the child did
not attend Brownies. She once again points out that Father has also had the opportunity to
. _ 16
NO. 05-2983 CIVIL TERM
have contact with the child through supervised visits for several months prior to the last
Conciliation, as they were specified in the PFA.
5. Conciliator Observations: The parties have been ordered to participate in a
custody evaluation. This has not begun because of the dispute regarding the sharing of the
costs associated with the evaluation. A hearing is scheduled for November 18, 2005 at 2:30
p.m. before Judge Hess. At that time, Father would like to have the Court enter an Order
with regard to an interim schedule. It is noted that these parties have had a high conflict
relationship which places the child in danger in at least an emotional sense. While it is
necessary for the Court to enter an Order providing structure in order for the child to be able
to see her Father, it is also quite clear that therapeutic family counseling is needed for this
family. However, despite the allegations of the significant assets available to the parties, it
appears that the issue of unreimbursed costs of treatment continues to be a roadblock. The
Conciliator also notes that the Carlisle YWCA Visitation Program in which the parties have
participated in the past will not be continuing to accept new clients after January 1, 2006.
The parties have agreed to participate in four (4) visits prior to the November 18, 2005
hearing.
ll-- -D?
Date
Peel Greevyf Esquire
Custody
:261885
ROBIN RONEMUS-SHULER,
Plaintiff
V
HARVEY SHULER, III,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
. CIVIL ACTION - LAW
NO. 05-5929 CIVIL TERM
IN DIVORCE
HARVEY MONROE SHULER,III, . IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V
C IL ACTION - LAW
:6^0. 05-2983 CIVIL TERM
ROBIN N. RONEMUS-SHULER IN CUSTODY
Defendant
IN RE: CUSTODY AGREEMENT
ORDER OF COURT
AND NOW, this 18th day of November, 2005, in
accordance with the agreement of the parties, as announced in
open court and in their presence, the following order of court
is entered:
Primary physical custody of the parties' daughter,
Heather, born September 25, 1998, shall be vested in mother
subject to periods of partial custody in father as follows:
1. Commencing Saturday, November 19, and Sunday,
November 20, 2005, for a period of two hours each day, from
9:30 a.m. until 11:30 a.m.
2. On Saturday, November 26, and Sunday, November 27,
2005, for a period of four hours each day, from 9:30 a.m. until
1:30 p.m.
3. On Saturday, December 3, and Sunday, December 9,
2005, for a period of six hours each day, from 9:00 a.m. until
3:00 p.m., and continuing each week thereafter until such time as
the custody evaluator or the parties or through court order
extends the period of time to overnight.
5424-2005 & 2983-2005 CIVIL TERM
As it relates specifically to Saturday, December 3,
2005, since Mrs. Shuler has purchased tickets for the Nutcracker,
the anticipated time on the 3rd of December will be 9:00 a.m.
until noon, however, that might be earlier so that mom has the
opportunity to take the child to a Brownie program before the
Nutcracker. Whatever difference there is in the six hours, it
will be made up on Sunday, December 4, 2005.
Pickup and delivery is to made at the McDonald's on
the Carlisle Pike near K-Mart. On all occasions, Harvey Shuler
will be accompanied by his sister, whose full name is Michelle
Swartz. For the first four visits they will also include Mr.
Shuler's children to his prior marriage. The idea is to reunite
them and at the same time give some degree of comfort level to
the reintroduction by Heather to Dad.
The parties agree that they will, in order to
implement the court's directive, by an order of August 25, 2005,
will submit themselves and the minor child to an independent
custody evaluation to be performed by Dr. Schneider. The cost
for the evaluation by Dr. Schneider shall be paid from a joint
account that the parties maintain with Morgan Stanley. The
parties will execute whatever documents are necessary to comply
with the court order, but no other proceeds except what is
necessary to pay Dr. Schneider and/or Guidance Associates will be
removed from that account without written consent of both parties
or further court order.
The payment of the Guidance Associates fees will be an
issue to be addressed in the divorce proceeding so that the wife
has the opportunity to ask for a reclaiming of any or all of that
fee payment from that account.
5929-2005 & 2983-2005 CIVIL TERM
P. Richard Wagner, Esquire
For Harvey Shuler
Shaubut C. Walz, III, Esquire
Judith T. Walz, Esquire
For Robin N. Ronemus-Shuler
By the Court,
bg
HARVEY SHULER, III,
Plaintiff,
V.
ROBIN N. RONEMUS-SHULER,
Defendant.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO: 05-2983 CIVIL TERM
CIVIL ACTION -LAW
IN CUSTODY
PETITION FOR CONTEMPT
AND NOW, comes your Petitioner, Harvey Shuler, III, by and through his attorneys,
Mancke, Wagner & Spreha, and files the following Petition For Contempt:
1. Your Petitioner, Harvey Shuler, III, hereinafter referred to as "Husband," is the
Defendant in the above-captioned divorce matter.
2. The Respondent, Robin Ronemus-Shuler, hereinafter referred to as "Wife," is the
Plaintiff in the above-captioned divorce matter.
3. On November 18, 2005, an Order was entered providing certain terms and conditions
regarding custody, a copy of said Order is attached hereto, incorporated herein by reference, and
marked as Exhibit A.
4. Pursuant to the Order of November 18, 2005, the parties agreed to submit themselves
to a Dr. Schneider evaluation, with the cost to be paid from a joint account with Morgan Stanley.
5. Despite the provisions of that Order, the Wife herein has refused to and continues to
refuse to make payment for Dr. Schneider's evaluation.
6. As a result, Husband has been denied increased time with his child, all without reason.
7. Wife has paid certain other personal bills and refused to make payment consistent with
the Order.
WHEREFORE, Petitioner requests this Court to find the Wife/Respondent in contempt.
Respectfully submitted,
Mancke, Wagner & Spreha
Mchard Wagner, Esquire
I.D. #23103
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorneys for Petitioner/Husband
Date: $ /D D ?v
-2-
,-, - f
VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 P&C.S.A. Section
4904, relating to unworn falsification to authorities.
DATE:
.
ROBIN RONEMPS-SHULER,
Plaintiff
V
HARVEY SHULER, III,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PZfMsYLV NIA
CIVIL ACTION - LAW
NO. 05-54-24 CIVIL TERM
IN DIVORCE
HARVEY MONROE SHULER,III, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V
CIVIL ACTION - LAW
NO. 05-2983 CIVIL TERM
ROBIN N. RONEMUS-SHULER IN CUSTODY
Defendant
IN RE: CUSTODY AGREEMENT
ORDER OF COURT
AND NOW, this 18th day of November, 2005, in
accordance with the agreement of the parties, as announced in
open court and in their presence, the following order of court
is entered:
Primary physical custody of the parties' daughter,
Heather, born September 25, 1998, shall be vested in mother
subject to periods of partial custody in father as follows:
1. Commencing Saturday, November 19, and Sunday,
November 20, 2005, for a period of two hours each day, from
9:30 a.m. until 11:30 a.t.t.
2. On Saturday, November 26, and Sunday, November 27,
2005, for a period of four hours each day, from 9:30 a.m. until
1:30 p.m.
3. On Saturday, December 3, and Sunday, December 4,
2005, for a period of six hours each day, from 9:00 a.m. until
3:00 p.m., and continuing each week thereafter until such time as
the custody evaluator or the parties or through court order
extends the period of time to overnight.
-11q -
r
5424-2005 & 2983-2005 CIVIL TERM
As it relates specifically to Saturday, December 3,
2005, since Mrs. Shuler has purchased tickets for the Nutcracker,
the anticipated time on the 3rd of December will be 9:00 a.m.
until noon, however, that might be earlier so that mom has the
opportunity to take the child to a Brownie program before the
Nutcracker. Whatever difference there is in the six hours, it
will be made up or. Sunday, December 4, 2005.
Pickup and delivery is to made at the McDonald's on
the Carlisle Pike near K-Mart. On all occasions, Harvey Shuler
will be accompanied by his sister, whose full name is Michelle
Swartz. For the first four visits they will also include Mr.
Shuler's children to his prior marriage. The idea is to reunite
them and at the same time give some degree of comfort level to
the reintroduction by Heather to Dad.
The parties agree that they will, in order to
implement the court's directive, by an order of August 25, 2005,
w}11 submit themselves and the minor child to an independent
custody evaluation to be performed by Dr. Schneider. The cost
-6 0
,- for the evaluation by Dr. Schneider shall be paid from a joint
r1.` account that the parties maintain with Morgan Stanley. The
rV -J parties will execute whatever documents are necessary to comply
't?? rpr with the court order, but no other proceeds except what is
rneccssary to pay Dr. Schneider and/or Guidance Associates will be
removed from that account without written consent of both parties
or further court order.
The payment of the Guidance Associates fees will be an
issue to be addressed in the divorce proceeding so that the wife
has the opportunity to ask for a reclaiming of any or all of that
fee payment from that account.
5424-2005 & 2983-2005 CIVIL TERM
By the Court,
P. Richard Wagner, Esquire
For Harvey Shuler
Sraubut C. Walz, III, Esquire
Judith T. Walz, Esquire
For Robin N. Ronemus-Shuler
:bg
? YY((a S:'{A iSwl '?'
r4 .1 t`!V 4. (•.:J 4: it.'i?I ICY
5 `S.u a .1 4?..'.?i;NV Y,
Prothono
n C=
c
Cr%
j 4
co ...)
?C
HARVEY SHULER, III IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
ROBIN N. RONEMUS-SHULER
DEFENDANT
05-2983 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, August 22, 2006 , 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 MDJ Manlove, 1901 State St., Camp Hill, PA 17011 on Friday, September 29, 2006 at 12:30 PM
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/ Melissa P. Gree Es . uk?
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
-!2 ?o d
,?? 4*,w 2
d
W!(C' F`nl(tj
L Z ,0114V I - dDS 90DI
?t? i'LC FIiO d 3H JO
HARVEY SHULER, III,
Plaintiff
V.
ROBIN N. RONEMUS-SHULER,
Defendant
--P 2006
M `l
IN THE COURT OF COMMOA-3vi= - "i
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-2983 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
ORDER TO RELINQUISH JURISDICTION
AND NOW, this day of , 2006, the Petitioner having notified
the Conciliator that the basis of his contempt petition has been resolved by a payment by
the Defendant, the Conciliator hereby relinquishes jurisdiction of this matter. The
conciliation Scheduled for September 29, 2006 is CANCELLED.
FOR THE COURT:
Melissa Peel Greevy, Esquire
Custody Conciliator 11
:283987
Dist: Judith T. Waltz, Esq. (Fax 567.6994)
P. Richard Wagner, Esq. (Fax 234.7080)
rn'? 1,?, ?.,,???,..i..?
e# ?`i 11?+ ?'???
??,
?..?
i i °,? 19.
-?, ?:-,
HARVEY SHULER, III,
V.
Plaintiff,
ROBIN N. RONEMUS-SHULER,
Defendant.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO: 05-2983 CIVIL TERM
CIVIL ACTION -LAW
IN CUSTODY
PETITION FOR CONTEMPT
AND NOW, comes your Petitioner, Harvey Shuler, III, by and through his attorneys,
Mancke, Wagner, Spreha & McQuillan, and files the following Petition For Contempt:
L Your Petitioner, Harvey Shuler, III, is the natural father of one (1) child, Heather, born
September 25, 1998.
2. Respondent, Robin N. Ronemus-Shuler, is the natural mother of the aforementioned
child.
3. On November 18, 2005, an Order was entered providing certain terms and conditions
regarding custody, which required the parties to submit themselves to an independent custody
evaluation to be performed by Dr. Schneider, with the cost to be paid from a joint account. A
copy of said Order is attached hereto, incorporated herein by reference, and marked as Exhibit A.
4. On or about September 8, 2006, as a result of a Petition filed by the Petitioner herein,
the Court directed that the money as set forth in the November 18, 2005, Order should be paid
from the account maintained by the parties. A copy of said Order is attached hereto, incorporated
herein by reference, and marked as Exhibit B.
5. The issue of the adjudication of contempt as a result of the September 8, 2006, Order
was generally continued.
6. Although the Order of November 18, 2005, required the payment for Dr. Schneider to
come from a joint account, no such payment was made because the Respondent would not
cooperate in making said payment, necessitating the Petition filed by the Petitioner that resulted
in the Order of September 8, 2006.
7. The payment was made for the custody evaluation, however, on February 16, 2007, the
custody evaluator wrote to the parties indicating that the Respondent herein has not cooperated
with the evaluation since October 4, 2006.
8. Petitioner believes and therefore avers that the Respondent is in contempt of court for
the following reasons, and has engaged in a course of contemptuous conduct designed to frustrate
the custodial rights of the Petitioner herein as follows:
A. the Order of November 18, 2005, required an independent custody evaluation by
Dr. Schneider to be paid from a joint account;
B. no payment was made as a result of the lack of cooperation by the Respondent,
necessitating a Petition For Contempt; and
C. the Petition For Contempt was heard the 8`' of September, 2006, whereupon the
issue of contempt was continued generally.
-2-
9. Despite the August 25, 2005 Order directing the parties to submit to an independent
custody evaluation, Respondent has not cooperated as reflected in the February 16, 2007, letter
from Dr. Schneider, a copy of which is attached hereto, incorporated herein by reference, and
marked as Exhibit C.
10. Petitioner believes and therefore avers that the conduct of the Respondent is designed
to frustrate his custodial rights with his daughter, and that the Respondent has not been
cooperating herein by design.
11. As a result of this Petition, the Petitioner herein as incurred costs to file the Petition
that generated the September 8, 2006 Order, and costs to prepare this Petition and attendance at
hearing in the amount of $1,000.00 for which Petitioner seeks a repayment from the Respondent.
-3-
WHEREFORE, Petitioner requests the Court to grant relief in the form of finding the
Respondent in contempt, sentencing her as a result fo the contempt, directing that she pay the
sum of $1,000.00 to the Petitioner herein, and otherwise promptly and diligently comply with the
Court Orders as it relates to custody.
Respectfully submitted,
Mancke, Wagner, Spreha & McQuillan
P. Richard Wagner, Esquire
I.D. 421103
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorneys for Husband/Petitioner
Date:
-4-
VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section
4904, relating to unsworn falsification to authorities. 7
DATE:^i
A- 4
A?
L ,J
ROL PONEMUS-SHULER,
Plaintiff
V
HARVEY SHULER, III,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PEN1,1SYLVANIA
CIVIL ACTION - LAW
NO. 05-5424 CIVIL TERM
IN DIVORCE
HARVEY MO?1ROE SHULi R, III, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V
CIVIL ACTION - LAW
NO. 05-2983 CIVIL TERM
ROBIN TAI. RONEMUS-SHULER IN CUSTODY
De --n(: Nnt
IN RE: CUSTODY AGREEMENT
ORDER OF COURT'
AND NOW, this 18th day of November, 2005, in
accordance, with the agreement of the parties, as announced in
open tour and -_n their presence, the following order o-f court
?s entered:
Primary physical custody of the parties' daug'-it,=,r,
Meat :e:r, born September 25, 1998, shall be vested in mother
sub ect to periods of partial custody in father as follows:
1. Commencing Saturday, November 19, and Sunday,
Novi ,br 2t), 2005, for a period of two hours each day, from
2. On Saturday, November 26, and Sunday, November 2?,
200 `,, fo.r a period of i-our -l-iours each ddy, from 9:30 a.m. until
1 . J '.) P.
)_ltu_-day, Del-°Il1b I , 1 1C1 U?1 day, L 'e cc--- inh
r
/C0 a period o sip, riour_s each day, from 9: GO a.m. t nt.il
P.rn. , and c.ontinuinq each week thereafter until such time as
the custody evaluator or the parties or t1rlrough court crder
e,-tends the period of time to overnight.
54<<'-2005 & 2983-2005 CIVIL TERM
As it relates specifically to Saturday, December 3,
2005, since Mrs. Shuler has purchased tickets for the Nutcracker,
the ?_r=cipated time on --he 3rd of December will be 9:00 a.m.
until noon, however, that might be earlier so that mom has the
opportunity to take the child to a Brownie program before the
Nutc_,'acker. Whatever difference there is in the six hours, it
? - made u,,,., n Sunday, Decembe7- a, 2
_0?' .
Pickup arid delivery is to made at the McDonald's on
th'` Carlisle Pike near K-Mart. On all occasions, Harvey Shuler
will be accompanied by his sister, whose full name s Michelle
Swartz. For the first four visits they will also include Mr.
Shuler's children to his prior marriage. The idea is to reunite
the.r. a.nd at the same time give some degree of comfort level to
the reintroduction by Heather to Dad.
The parties agree that they will, in order to imp__emerit the court's directive, by an order of August 25, 2005,
wall _Submit themselves and the minor child to an independent
custody evaluation to be perforated by Dr. Schneider. The .cost
r oI Il ?VaLuatlon nY Ur. -Sc n'e1.?er Ls._ a
iczi_' lJC p i;l L_ OP1 )iJ?ii?
--rat the parties maintain witl: Morgan S',anley. The
par ses wil' execute whatever documents are necessary to comply
the court order, but no other proceeds except what is
l 1; to ?;,iy Di-. Schnc,id!?r -ndi c r c,1.,1<.? aI"ICL '
t? .? ti OC?_at Will 1J
r. rer,?oved from that account without written consent of both parties
or further court order.
The payment of the Guidance Associates fees will be are
II ss'_e to be addressed in the divorce proceeding so that the wife
hay the opportunity to ask for a reclaiming of any or al-1 of that
fee payment from that account.
5424-21005 & 2983-2005 CIVIL TERM
By the Court,
Kevin A Hess, J.
P. Richard Wagner, Esquire
For Harvey Shuler
Wa , y`.Ti., 'Li squirG
Judith T. Walz, Esquire
For Robin N. Ronemus-Shuler
.hg
w-" N
j" O
Prothono
ROBIN RONEMUS-SHULER,
Plaintiff
V.
HARVEY SHULER, III,
Defendant
IN THE COURT OF
CUMBERLAND COUNT
NO. 05-5424 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
ORDER OF COURT
N P'L E A S OF
ENNSYLVANzA
h 1..°l
AND NOW, this 8th day of September, 2006, upon
consideration of the Defendant's Petition for Conte^.pt, it :is
hereby ordered and directed as -follows:e S"-a77. sign the necessary documentat4on to
have an addi ti onal $25,000,00 disbursed from the 'organ Stanle-_;
account = be placed in-o the escrow acco-ant created b,r and used
for the purposes delir_eated in our order of February 10, 200??.
Those documents shall be delivered to h-.lsband' s co-_-nsel
that time frame.
The issue of ?%-,_-ether fur_d s from t_.e escrc
account were ?mproper'_y used to pay -,rife's persc ial bills shal1
be -reserved for resolution by the Master.
3 . The _ssue of ether ',,,life s h a I I be ad?udicated --ii
contempt s1--all be con._in- ed generally.
WO
By the,
_;?' d,ard E. Guido, J.
S=?_aabu? C. -?,;alz, III, Esquire
Judith T. v, _z, Esquire
For Robin N. Ronemus-Shuler
P. Richard Wagner, Esqui re -
r or Harvey Shuler -.
sr s•
EEXHIBIT
1
GUIDANCE ASSOCIATES OF PENNSYLVANIA
412 Erford Road, Camp Hill, PA 17011 (717) 7:32-2917; FAX: (717) 732-5375 Stanley E. Schneider, Ed.D.
20 Briarcrest Square, Suite 205, Hershey, PA 17033 (717) 533-4312 Director
February 16, 2007
Judith T. Walz, Esq.
Walz 1- Walz
341 Market. Street
Newport. PA 17074
RE: Harvey M. Shuler, III v. Robin M. Ronemus Shuler
Dear Attorney Walz:
This letter is in response to your letter dated January 23, 2007.
Regarding the status of the evaluation, I am currently waiting for Robin to complete and return
questionnaires given to her on October 4, 2006. I am also waiting for Robin to schedule an
MMPI-2.
Should you have further questions, please do not hesitate to contact me.
< ' Sincerely,
C„
J
Stanley . Schneider, Ed.D.
Psychologist
c: Richard P. Wagner, Esq.
Harvey Shuler
Robin Ronemus-Shuler
/? 4,Gl
s
HARVEY SHULER, III IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
05-2983 CIVIL ACTION LAW
ROBIN N. RONEMUS-SHULER
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Thursday, March 08, 2007 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, April 11, 2007 at 12:00 PM
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/ Dawn S. Sunday, Esq. 1A
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
4?7
hl-
! JI V _ ? J `O-?lA
n. « 4
t I.
'"!0 0 l J '11 M' J LHZ
N`~ SAY 14 2007, 0
HARVEY SHULER, III IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 05-2983 CIVIL ACTION LAW
ROBIN N. RONEMUS-SHULER
Defendant IN CUSTODY
ORDER OF COURT
'? MM
AND NOW, this / day of f ?? , 2007, upon
consideration of the attached Custody Conciliation Report, i is ordered and directed as follows:
1. Based upon the Mother's acknowledgement and agreement that she did not comply in a
timely manner with the prior Order of this Court dated November 18, 2005 requiring the parties to
participate in a custody evaluation, the Mother is found to be in contempt of that Order, with no further
sanctions, other than this finding, to be imposed.
2. The parties shall cooperate in effectuating the recommendations of the custody evaluator,
Stanley Schneider, Ph.D in a timely manner.
cc.2th chard Wagner, Esquire - Counsel for Father
T. Walz, Esquire - Counsel for Mother
Edward E. Guido J.
Aviv i U ,y;, ` ",:
'Hi
1 1 ~
HARVEY SHULER, III
Plaintiff
VS.
ROBIN N. RONEMUS-SHULER
Defendant
Prior Judge: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
05-2983
CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Heather Shuler September 25, 1998 Mother
2. A custody conciliation conference was held on May 11, 2007 with the following individuals
in attendance: the Father, Harvey Shuler, with his counsel, P. Richard Wagner, Esquire, and the
Mother, Robin N. Ronemus-Shuler, with her counsel, Judith T. Walz, Esquire.
3. The parties agreed to entry of an Order in the form as attached resolving the Father's
Petition for Contempt.
Date Dawn S. Sunday, Esquire
Custody Conciliator
HARVEY M. SHULER, III,
PLAINTIFF
V.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA,
ROBIN M. RONEMUS-SHULER, NO. 2983 " a S
DEFENDANT CIVIL ACTION - LAW
IN CUSTODY
PETITION FOR CONTEMPT OF COURT ORDER
TO THE HONORABLE JUDGE EDWARD E. GUIDO:
NOW comes Petitioner, Robin M. Ronemus-Shuler, Mother of the subject minor child,
Heather M. Shuler, and Harvey M. Shuler, III, Father of the subject minor child, by Mother's
attorney, Judith T. Walz, of Walz & Walz, Attorneys at Law, P.C., and respectfully represents as
follows:
1. Petitioner Robin M. Ronemus-Shuler, Mother, is an adult individual residing at 4 Central
Blvd., Camp Hill, Pennsylvania.
2. Respondent, Harvey M. Shuler, III, Father, is an adult individual residing at 510 Shuler
Road, Shermans Dale, Pennsylvania.
3. The subject child is Heather M. Shuler, a female child, age nine (9) years, born
September 25, 1998.
4. By Order of Judge Guido dated May 16, 2007, the parties to the custody action were
ordered to cooperate in effectuating the recommendations of the Custody Evaluator,
Stanley Schneider, Ph.D. in a timely manner. A copy of said Order of Court is attached
hereto, made a part hereof, and marked Exhibit "A"
5. Soon after the Order the Petitioner and Respondant worked out a verbal arrangement
following the recommendations of the Custody Evaluator; however a Stipulation to a
Consent Custody Order was contemplated by the parties and their attorneys. Neither
attorney represented that he or she was to prepare the same.
6. On August 30, 2007, P. Richard Wagner, Attorney for the Father, sent
Petitioner/Mother's attorney, Judith T. Walz, a letter demanding confirmation within
seven (7) days from the date of the receipt of his letter that the recommendations be
effectuated by way of a Stipulated Court Order, with a warning that a Petition for
Contempt would be filed as it relates to custody.
7. On September 5, 2007, Petitioner/Mother returned a letter to P. Richard Wagner,
Attorney for Father, enclosing a Proposed Stipulated Consent Custody Petition together
with a proposed Consent Custody Order. In the cover letter, Mother's attorney warned of
filing a Contempt proceeding if Father did not respond. She also requested suggestions
for changes in the wording of the proposed Stipulated Custody Order, if Father so
desired. The same seven day response time was given to Father that Father gave to
Mother. A copy of the Proposed Stipulated Consent Custody Petition and Order are
attached hereto, made a part hereof and marked Exhibit "B"
8. There was no response by Attorney Wagner or his client to Petitioner/Mother's Stipulated
Custody Order.
9. On September 19, 2007, Mother's Attorney sent another request to Father's attorney for a
response to the Proposed Custody Stipulation that Mother's Attorney sent to Father's
Attorney September 5, 2007. In this request, Mother's Attorney pointed out that she
called Father's Attorney and left a message with his secretary that she wanted to discuss
the case: both Custody and Divorce; and that Father's attorney talk with Mother's
attorney because Mother was trying to work it out. She warned that without a response
from Husband's Attorney she may Petition the court for assistance. A copy of the
correspondence between and from Attorneys is attached hereto, made a part hereof, and
marked Exhibit "C"
10. No response has been forthcoming from Father and/or his attorney.
11. Petitioner/Mother has been billed for legal fees of $320.00 for the filing of this Petition
for Contempt, $80.00 for the follow up letter to P. Richard Wagner, Esquire, asking for a
response and is anticipating a bill for legal fees for attendance of a hearing on Contempt
in the estimated sum of $640.00.
WHEREFORE, Petitioner/Mother prays for a finding of Contempt on Father's part, payment
of Petitioner/Mother's legal fees by Father; and requests that the proposed Consent Custody
Petition and Order that Mother has asked for Father to sign or offer changes thereto which
will allow Father to sign, be made into an Order of Court.
Date: A 7
Respectfully submitted,
dith T. Walz, ID 06349
Walz & Wa1z, Attorneys at Law, P. C.
341 Market Street,
Newport, PA 17074
(717) 567-6993
I, ROBIN NL RONENWS-SHULER, verify that the statements made in this Petition are true and
correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
§4904, relating to unworn falsification to authorities.
Date. ` a 1-7 /0 7 (A ? Q ?G-?&A
RO M.RONE SHULER
MAY 14 W,
HARVEY SHULER, III IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 05-2983 CIVIL ACTION LAW
ROBIN N. RONEMUS-SHULER
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this day of A 2007, upon
consideration of the attached Custody Conciliation Report, i is ordered and directed as follows:
1. Based upon the Mother's acknowledgement and agreement that she did not comply in a
timely manner with the prior Order of this Court dated November 18, 2005 requiring the parties to
participate in a custody evaluation, the Mother is found to be in contempt of that Order, with no further
sanctions, other than this finding, to be imposed.
2. The parties shall cooperate in effectuating the recommendations of the custody evaluator,
Stanley Schneider, Ph.D in a timely manner.
cc: 'chard Wagner, Esquire - Counsel for Father
dith T. Walz, Esquire - Counsel for Mother
Edward E. Guido J.
HARVEY M. SHULER, III,
Plaintiff
V.
ROBIN M. RONEMUS-SHULER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
PENNSYLVANIA
05-2983
CIVIL ACTION - LAW
:CUSTODY
ORDER
AND NOW, this day of 2007 upon consideration of within Petition
for Consent Custody Order, it is Ordered and Decreed that the Petition for Consent Custody
Agreement by the Parties, Robin M. Ronemus-Shuler and Harvey M. Shuler, III, with regard to
their daughter, Heather M. Shuler, a minor, is hereby adopted as an Order of Court.
BY THE COURT:
J.
I
HARVEY M. SHULER,III,
Plaintiff
V.
ROBIN M. RONEMUS-SHULER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
PENNSYLVANIA,
05-2983
CIVIL ACTION LAW, IN CUSTODY
PETITION FOR CONSENT CUSTODY ORDER
AND NOW comes ROBIN M. RONEMUS-SHULER, Mother of the subject minor
child, HEATHER M. SHULER, and HARVEY M. SHULER, III, Father of the subject minor
child, by Mother's attorney, Judith T. Walz, and Father's Attorney, P. Richard Wagner, and
respectfully represent as follows:
1. Petitioner ROBIN M. RONEMUS-SHULER, Mother, is an adult individual residing at 4
Central Blvd, Camp Hill, Pennsylvania.
2. Petitioner HARVEY M. SHULER, III, Father, is an adult individual, residing at 510
Shuler Road, Shermans Dale, Pennsylvania.
3. Petitioners are the parents of HEATHER M. SHULER, a female child, age eight (8)
years, born September 25, 1998.
4. Petitioners have agreed to a Consent Custody Order as listed below with regard to the
custody and visitation rights of the Mother and Father of said child.
5. Petitioners acknowledge that they have a right to a hearing before the Judge. Petitioners
mutually agree to waive this right.
6. Petitioner ROBIN M. RONEMUS-SHULER is represented by Judith T. Walz, Attorney
at Law.
7. Petitioner HARVEY M. SHULER, III is represented by P. Richard Wagner, Attorney at Law.
WHEREFORE, Petitioners pray Your Honorable Court for an Order as follows:
(a) Mother, Robin M. Ronemus-Shuler, is granted shared legal and primary
physical custody of the child HEATHER M. SHULER;
(b) Father, Harvey M. Shuler, III, is granted shared legal and periods of partial
physical custody of the child, with the schedule as set forth below:
(i) Father shall have the child every other weekend from 6:00 P.M. on
Friday until 6:00 P.M. Sunday evening.
(c) The parties shall share physical custody for New Years' Day, Memorial
Day, Fourth of July and Labor Day as set forth below:
(i) The night before the holiday beginning at 6:00 P. M. until 6:00 P.M.
the following day.
(ii) Mother and Father shall alternate the aforementioned arrangement
every other year and the holidays within the year so for example,
Father shall have Memorial Day in 2007, Mother shall have Fourth
of July 2007, Father shall have Labor Day 2007 and Mother shall
have New Year's Day 2008; then Mother shall have Memorial Day
2008, Father shall have Fourth of July 2008 and so forth, alternating
the four holidays, holiday to holiday, year to year.
(d) The Christmas schedules are as set forth below:
(i) Mother shall have custody in 2007 on December 24, 2007, from
9:00 A.M. through Christmas Day at 3:00 P.M. This shall be
known as segment "A".
(ii) Father shall have custody in 2007 on Christmas Day at 3:00 p.m.
through December 26, at 6:00 P.M. This shall be known as
Segment "B".
(iii) Mother shall have segment "A" in odd numbered years and father
shall have Segment "A" in even numbered years and mother shall
have Segment "B" in even numbered years and father shall have
Segment "B" in odd numbered years.
(e) The Easter Holiday schedules are as set forth below:
(i) Mother shall have custody in 2008 from 4:00 p.m. Easter Eve to
3:00 p.m. Easter Day. This shall be known as Segment "A".
(ii) Father shall have custody in 2008 from 3:00 p.m. Easter Day to
8:00 p.m. Easter Day, if school the next day or 6:00 p.m.
Monday, if no school. This shall be known as Segment "B".
(iii) Mother shall have Segment "A" in even numbered years and
father shall have Segment "A" in odd numbered years and
mother shall have Segment "B" in odd numbered years and
father shall have Segment "B" in even numbered years.
(f) The Thanksgiving Holiday schedule is as set forth below:
(i) Even years, Mother has custody of the child Thanksgiving Eve at
6:00 P.M. to Friday immediately following Thanksgiving Day at
6:OOPM; Father has custody from the Friday at 6:00 P.M.
following the holiday until Sunday at 6:00 P.M.
(ii) Odd years, Father has custody of the child Thanksgiving Eve at
6:00 P.M. to Friday immediately following Thanksgiving Day at
6:00 P.M.; Mother has custody from the Friday at 6:00 P.M.
following the holiday until Sunday at 6:00 P.M.
(g) Mother shall have custody on the entire weekend of Mother's Day.
(h) Father shall have custody on the entire weekend of Father's Day.
(i) During Summer vacation:
1. Father shall be entitled to summer vacation periods during which he has
scheduled time off from work and is planning to spend quality time with
the subject child and shall have physical custody of the child for seven
(7) consecutive days during the months of June, July and August. The
seven (7) consecutive days shall include Father's regular weekend
custody period. VVUle Father enjoys his seven consecutive days with
the child, Mother is entitled to one overnight visit starting at 6:00 P.M.
and ending on the following day at 8:00 P.M. Father shall notify Mother
by February 15d` of each year of his preference of weeks so that the
child's summer camp period can be scheduled by the deadline of
February 15''. Any weeks sought with notifications after February 15ffi
shall be subordinate to the child's scheduled summer camp, girl scout
camp, and other such scheduled activities. Mother, too, is entitled to
three uninterrupted periods of vacation which she must also schedule by
February 15th of each year.
2. Father's every other weekend custodial periods may be extended to
Monday evening until 6:00 P.M. in the event that Father is off from
work and able to spend personal quality time with his daughter on said
Monday extensions.
0) The parties agree that all holiday schedules shall override the regular custody
schedule.
(k) In the case of medical emergencies involving the child, the parent in
custody must make reasonable efforts to notify the other parent of said emergency.
(1) The parties agree to be courteous in all dealings by and between the parents.
Neither parent shall make disparaging remarks, nor allow a third party to make
disparaging remarks about the other parent in the presence of the child. Each parent
shall respect the other parent's right to have a frequent, ongoing and substantial
relationship with the child. Neither party shall do or say anything, nor allow a third
party to do or say anything that would alienate the child from the affections of the
other parent. Each parent agrees to keeping the child's living arrangements
"predictable" but if something unexpected or unavoidable comes up, each shall give
each other as much notice as possible.
(m). Each parent shall have reasonable telephone access to the child when the
child is in the care of the other parent.
(n). Each parent shall keep the other parent informed as to his or her address and
telephone numbers, including cell numbers. If either parent is taking the child
r
from his or her home for more than twenty-four (24) hours, whether for vacation or
otherwise, that parent shall inform the other parent of a telephone number where
the child can be reached in case of an emergency.
(o) Each parent shall be responsible for making sure that the child's belongings
are returned in the same condition as presented and in a timely manner.
(p) Father agrees that when he has his periods of partial physical custody that
Father is "On-Duty" and shall not leave his daughter unattended or alone with
Harvey M. Shuler, II, "Pappy" or with Caroline Shuler "Mimi" and shall
accompany his daughter on all horse-back riding making sure she wears her
protective gear, including a helmet; shall not take his daughter on motorcycle rides
or in his tractor-trailer without prior, express written agreement of Mother.
(c) Pick-up and Drop off shall be at the McDonald's on the Carlisle Pike,
Mechanicsburg unless agreed otherwise.
(r) Both parents agree that it is in the best interests of their daughter to be
involved in social, church related, civic and school activities and that she will be
expected to attend all the events that are associated with said activities. To that
end, both parents agree that the custodial parent who has the child at the time when
the events that are associated with said activities is occurring shall make every
effort to get the child to said event even if the event occurs during his/her custodial
period.
(s) Mother and Father may make permanent modifications to the Order by
mutual written agreement. Further, Mother and Father may make temporary
modifications to the Order by mutual oral agreement. Permanent modifications to
the Order made in writing and signed by both parties shall be treated as part of the
Court Order as if already included therein. Temporary, oral, mutual modifications
of the Order may be made but if they are not in writing and signed by both parties,
the modifications shall not become part of the Order as if already in the Order.
I, ROBIN M. RONEMUS-SHULER, verify that the statements made in this Petition for
Consent Custody Order are true and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities.
Date:
ROBIN M. RONEMUS-SHULER
I, HARVEY M. SHULER, III, verify that the statements made in this Petition for Consent
Custody Order are true and correct. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities.
Date:
HARVEY M. SHULER, III
Date: .2007
Date: 12007
Respectfully submitted,
Judith T. Walz Attorney
For Robin M. Ronemus-Shuler
P. Richard Wagner, Attorney
For Harvey M. Shuler
I
LAW OFFICES
MANCKE, WAGNER, SPREHA & MCQUILLAN
2233 NORTH FRONT STREET
JOHN B. MANCKE HARRISBURG, PA 17110 PHONE (717) 2347051
P. RICHARD WAGNER FAX (717) 2347080
EDWARD F. SPREHA, JR.
BRYAN M. MCQUILLAN
August 30, 2007
Judith T. Walz, Esquire
Walz & Walz
341 Market Street
Newport, PA 17074
Re: Shuler
Dear Judy:
On May 16, 2007, Judge Guido entered an Order that the parties shall effectuate the
recommendations of Dr. Schneider. To that end, please accept this letter as notification that if
we do not have confirmation from your client within seven (7) days from the date of the receipt
of this letter that the recommendations shall be effectuated by way of a Stipulated Court Order,
we will file again another Petition For Contempt as it relates to custody.
Your attention is appreciated.
PRW/dks
cc: Mr. Harvey Shuler
W LZ & W L q
ATTORNEYS AT SLAW, PoC
Judith T. Walz, Esquire
Shaubut C. Walz, III, Esquire
P. Richard Wagner, Esquire
Mancke, Wagner, Spreha & McQuillan
2233 North Front Street
Harrisburg, PA 17110
Dear Rich:
CERTIFIED MAIL
RE: Shuler v. Shuler,
341 Market Street
Newport, PA 17074
Tel. 717-567-6993
Fax 717-567.6994
September 5, 2007
I enclose herewith a proposed Petition for Consent Custody Order, together with the proposed
Order. If you have any suggestions for changes in wording, please let me know. I think that the
parties have already been operating under most of the language since the entry of the Order.
Please accept my letter as notification to you that if we do not have confirmation from your
client within seven (7) days from the date of the receipt of this letter that the recommendations
shall be effectuated by way of a Stipulated Court Order, we will file a Petition for Contempt as it
relates to Custody.
Your attention is appreciated.
Very truly yours,
J~ i?TWalz
Cc: Robin Ronemus-Shuler
Enclosure: Proposed Petition for Consent Custody and Order
J
4
If, •
C
C3
N
to postage $
?' Cctitied Fee
O
0 RAM pequ ed)
?rdo
"eRea°ireal
E
r-1 t nd'
M --Ml Postage & Fees
Lnl
C3
r
¦ Goiii?e;it:ens 1, 2, and 3..'Also"complete
item 4 tf Restricted Delivery is desiried.
¦ Print your name and address on the reverse
so that we can return the card to you.
• Attach this card to the back of the tnallpiece,
or on the front if space permits.
„o
y rstma*
.. Ei M?>rlfP,i,Nare
... ¢?omm
_. mma N•
a es Z
-a
r?
l
` `
4? ?• N t
fA
O
A. ig dRt?(O?xy ^i- ?° r s t °?r
Agent
X + Addressee MV V G. Date of Dalivory
D. Is delivery dnmlt}tom ttem 11 ? Yes
If YES, erit delivery address below: ? No
r
3. Service Type
J(CeMW,Mail ?ExpressMail
? Registered ? Return Recelptfor Merdw dise
? insured man ? C.O.D.
4. Restricted Del[Very/1(Extra Fee) ? Yes
i Article Number 7005 3110 0004 0824 0825
{frarrster from serNce labeo
PS Fonn,3811, August `2,0011. Domestic Return Receipt tozsa5-0z M tsao
1. Article Addressed to:
?1o,>RC ,s ?rrha.?m
" (?1??-ice ?rcn? 5tr,e?
R 1-7110
A LZ & 1 ?.L Z y
ATTORNEYS A AT l JL LAW. P0,!''1
Judith T. Walz, Esquire
Shaubut C. Walz, III, Esquire
September 19, 2007
P. Richard Wagner, Esquire
Mancke, Wagner, Spreha & McQuillan
2233 North Front Street
Harrisburg, PA 17110
RE: Shuler v. Shuler
Dear Rich:
341 Market Street
Newport, PA 17074
Tel. 717-567-6993
Fax 717-567-6994
I called you last Friday and left a message with your secretary that I wanted to discuss the above-
referenced case with you but I have not yet heard back from you.
I also sent you two letters addressing the issues of custody and other issues. Although I wanted
to talk to you before I left, I am now leaving for Turkey and will return in the middle of October.
I would appreciate it if you could give me a response to the property issues (appraisals, rents,
bills etc.) and report to me anything you desire to change in the draft of the Consent Custody
Order.
On that regard, the parties have been operating under this type of proposal since Schneider gave
his recommendation.
I would also appreciate it if you would talk to me before you file anything because I am trying to
work it out with you.
If I don't get a response from you by the time I get back I am considering filing a Petition for
Interpretation of Order instead of a Petition for Contempt because that causes these parties to be
agitated.
I hope to hear from you when I return. Thank you.
Very truly yours,
C Judith T. Walz
P.c. Robin Ronemus-Shuler
'--
i7l
-a rn
? f ..:ti
HARVEY M. SHULER, III IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
ROBIN M. RONEMUS-SHULER
DEFENDANT
2005-2983 CIVIL ACTION LAW
. IN CUSTODY
ORDER OF COURT
AND NOW, Wednesday, December 26, 2007 _,upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, January 24, 2008 at 10:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: /s/ Dawn S. Sunda Es q.
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
-)" xttv
VlNVMkSNN3d
OS .1 bid LZ 030 LOOZ
Afi l i; i t d ?Hl 40
r
FEB 012008 #,I
HARVEY M. SHULER, III IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 2005-2983 CIVIL ACTION LAW
ROBIN M. RONEMUS-SHULER
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this S*day of E4n!?A--? , 2008, upon
consideration of the attached Custody Conciliation Report, it is ord ed and directed as follows:
1. The Father, Harvey M. Shuler, III, and the Mother, Robin M. Ronemus-Shuler, shall have
shared legal custody of Heather M. Shuler, born September 25, 1998. Major decisions concerning the
Child including, but not necessarily limited to, her health, welfare, education, religious training and
upbringing shall be made jointly by the parties after discussion and consultation with a view toward
obtaining and following a harmonious policy in the Child's best interest. Neither party shall impair the
other party's rights to shared legal custody of the Child. Neither party shall attempt to alienate the
affections of the Child from the other party. Each party shall notify the other of any activity or
circumstance concerning the Child that could reasonably be expected to be of concern to the other.
Day to day decisions shall be the responsibility of the parent then having physical custody. With
regard to any emergency decisions which must be made, the parent having physical custody of the
Child at the time of the emergency shall be permitted to make any immediate decisions necessitated
thereby. However, that parent shall inform the other of the emergency and consult with him or her as
soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and
full information from any doctor, dentist, teacher, professional or authority and to have copies of any
reports or information given to either party as a parent as authorized by statute.
2. The Mother shall have primary physical custody of the Child.
3. The Father shall have partial physical custody of the Child in accordance with the following
schedule:
A. During the school year, the Father shall have custody of the Child on alternating
weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m., with the exception that the Father's
weekend periods of custody shall be extended through Monday when the Father is not working and is
able to spend personal time with the Child. When the Child has school on the Monday of the extended
weekend, the period of custody shall end in the morning when the Father transports the Child to
school. When the Child does not have school on the Monday of an extended weekend, the Father's
period of custody shall end at 6:00 p.m.
3
r
B. During the summer school vacation, the Father shall have custody of the Child for
three (3) non-consecutive weeks,. the Mother shall have custody of the Child for three (3) non-
consecutive weeks and during the remaining four (4) weeks of the school break, the parties shall share
having custody with the Father having custody of the Child from Friday at 6:00 p.m. through Monday
at 6:00 p.m. and the Mother having custody from Monday at 6:00 p.m. through Friday at 6:00 p.m.
each week. In the event the Father is unable to obtain custody of the Child on a Friday by 8:00 p.m.,
the parties shall exchange custody on the following Saturday morning at 9:00 a.m. The Father shall
provide advance notice to the Mother in the event he is unable due to his employment to pick up the
Child at the 6:00 exchange time. The school year custody schedule shall resume one week before the
first day of school. The Father shall notify the Mother by February 15 of each year of his selection of
the three (3) week periods so that the Child's summer camp schedule can be established by the
deadline of February 15. The Mother shall notify the Father by February 20 of each year of her
selection of the three (3) week periods. Each party shall schedule her or his three week periods to
include that party's regular alternating weekend. In the event a party fails to provide the required
notice under this provision, that parent's selection of summer custody weeks shall be subject to the
consent of the other party as to the weeks selected.
4. The parties shall share or alternate having custody of the Child on holidays as follows:
A. Christmas: The Christmas holiday shall be divided in to Segment A, which shall
run from Christmas Eve at 9:00 a.m. through Christmas Day at 3:00 p.m., and Segment B, which shall
run from Christmas Day at 3:00 p.m. through December 26 at 6:00 p.m. In even-numbered years, the
Father shall have custody of the Child during Segment A and the Mother shall have custody during
Segment B. In odd-numbered years, the Mother shall have custody of the Child during Segment A and
the Father shall have custody during Segment B.
B. Thanksgiving: The Thanksgiving holiday shall be divided into Segment A, which
shall run from the Wednesday before Thanksgiving at 6:00 p.m. through the Friday following
Thanksgiving at 6:00 p.m., and Segment B, which shall run from the Friday after Thanksgiving at 6:00
p.m. through the following Sunday at 6:00 p.m. In even-numbered years, the Father shall have custody
during Segment A and the Mother shall have custody during Segment B. In odd-numbered years, the
Mother shall have custody of the Child during Segment A and the Father shall have custody during
Segment B.
C. Easter: The Easter holiday shall be divided into Segment A, which shall run from
the Saturday before Easter at 4:00 p.m. through Easter Sunday at 3:00 p.m., and Segment B, which
shall run from 3:00 p.m. until 8:00 p.m. on Easter Sunday, or until 6:00 p.m. on the Monday following
Easter if there is no school. In even-numbered years, the Father shall have custody of the Child during
Segment A and the Mother shall have custody during Segment B. In odd-numbered years, the mother
shall have custody of the Child during Segment A and the Father shall have custody during Segment B.
D. New Years, Memorial DU, July Fourth, Labor Day: The holiday periods of
custody for New Years, Memorial Day, July Fourth and Labor Day shall run from the evening before
the holiday at 6:00 p.m. through 6:00 p.m. on the day of the holiday. In even-numbered years, the
Father shall have custody of the Child for New Years and July Fourth and the Mother shall have
custody for Memorial Day and Labor Day. In odd-numbered years, the Mother shall have custody of
the Child for New Years and July Fourth and the Father shall have custody for Memorial Day and
Labor Day. For purposes of this provision, the entire New Years holiday shall be deemed to fall within
the same year as New Years Day.
r
E. Mother's Dav/Father's Day: In every year, the Mother shall have custody of the
Child for the entire Mother's Day weekend and the Father shall have custody of the Child for the entire
Father's Day weekend.
F. The holiday custody schedule shall supersede and take precedence over the regular
custody schedule.
5. Unless otherwise agreed between the parties, exchanges of custody at the beginning of the
Father's periods shall take place at the McDonald's on the Carlisle Pike in Mechanicsburg and at the
end of the Father's periods of custody, at the Turkey Hill on Route 114 in Mechanicsburg.
6. The non-custodial parent shall be entitled to have reasonable telephone contact with the
Child.
7. The parties agree to be courteous in all dealings between them. Neither parent shall make
disparaging remarks, nor allow a third party to make disparaging remarks about the other parent in the
presence or hearing of the Child. Each parent shall respect the other parent's right to have a frequent,
ongoing and substantial relationship with the Child. Neither party shall do or say anything, nor allow a
third party to do or say anything, that would alienate the Child from the affections of the other parent.
8. Each parent shall keep the other parent informed as to his or her current address and
telephone numbers, including cell phone numbers. In the event either parent removes the Child from
his or her residence for an overnight period or longer, that parent shall notify the other parent of the
telephone number where the Child can be reached in the event of an emergency.
9. Each parent shall be responsible for returning the Child's belongings in the same condition
as presented and in a timely manner.
10. The parties agree that it is in the Child's best interest to be involved in social, church-
related, civic and school activities and that she will be expected to attend the events associated with
those activities. The parties shall consult with each other before enrolling the Child in
activities/programs. The custodial parent shall ensure that the Child attends all regularly scheduled
activities.
11. The parties shall engage in a course of therapeutic family counseling with a professional to
be selected by agreement between the parties and counsel. The parties shall attend a minimum of four
(4) joint sessions, unless otherwise recommended by the counselor. The parties shall cooperate in
sharing information concerning applicable insurance coverage for the counseling.
12. In the event the parties are unable to establish the details of the summer custody schedule
by agreement within the parameters set forth in this Order, counsel for either party may contact the
conciliator to schedule an additional custody conciliation conference for that purpose.
13. This Order is entered pursuant to an agreement of the parties. The parties may modify this
Order by written mutual agreement. In the absence of written mutual agreement, the terms of this
Order shall control.
cc:" Richard Wagner, Esquire - Counsel for Father
Vidith T. Walz, Esquire - Counsel for Mother
.
?01
Edward E. Guido J.
!(' , ; Yf
L C 0 Wd S- 83.E BQOZ
t ai ?zHl ?O
301J t--Mllj
HARVEY M. SHULER, III
Plaintiff
VS.
ROBIN M. RONEMUS-SHULER
Defendant
Prior Judge: Edward E. Guido
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2005-2983 CIVIL ACTION LAW
IN CUSTODY
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Heather M. Shuler
September 25, 1998
Mother
2. A custody conciliation conference was held on January 24, 2008, with the following
individuals in attendance: the Father, Harvey M. Shuler, III, with his counsel, P. Richard Wagner,
Esquire, and the Mother, Robin M. Ronemus-Shuler, with her counsel, Judith T. Walz, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Date Dawn S. Sunday, Esquire
Custody Conciliator