HomeMy WebLinkAbout06-0198AUTUMN L. STEPLER,
Plaintiff
V.
MATTHEW S. STEPLER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-198
CIVIL ACTION - LAW
IN DIVORCE and CUSTODY
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims
set forth in the following pages, you must take prompt action. You are
warned that if you fail to do so, the case may proceed without you and a
Decree of Divorce or annulment may be entered against you by the Court. A
judgment may also be entered against you for any other claim or relief
requested in these papers by the plaintiff. You may lose money or property
or other rights important to you, including custody or visitation of your
children.
When the ground for the divorce is indignities or irretrievable
breakdown of the marriage, you may request marriage counseling. A list of
marriage counselors is available in the Office of the Prothonotary at the
Cumberland County Courthouse, Carlisle, PA 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013-3302
Telephone: (717) 249-3166
[1\divASTEPLER,AUTUM9-330_CcrDbcust
AUTUMN L. STEPLER,
Plaintiff
V.
MATTHEW S. STEPLER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. "'Qn - ?7'r
CIVIL ACTION - LAW
IN DIVORCE and CUSTODY
COMPLAINT IN DIVORCE UNDER 3301(c)or 3301(d)
1. The Plaintiff in this action is AUTUMN L. STEPLER, an adult
individual, who currently resides at 1845 Hunter- Drive, Mechanicsburg,
Cumberland County, Pennsylvania, 17050.
2. The Defendant in this action is MATTHEW S. STEPLER, an adult
individual, who currently resides at 1845 Hunter- Drive, Mechanicsburg,
Cumberland County, Pennsylvania, 17050.
3. Both the Plaintiff and the Defendant have been bona fide
residents of the Commonwealth of Pennsylvania for at least six (6)
months immediately previous to the filing of this complaint.
4. The Plaintiff and Defendant were lawfully joined in marriage
on September 16, 1995, in Boiling Springs, Pennsylvania.
5. There have been no prior actions of divorce or for annulment
between the parties hereto in this or any other jurisdiction.
6. The Plaintiff avers as the grounds upon which this action is
based is that the marriage between the parties hereto is
irretrievably broken.
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«..u. FPF,PLc ?ni;TUMN afrofsecvice
AUTUMN L. STEPLER,
Plaintiff
V.
MATTHEW S. STEPLER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-198
CIVIL ACTION - LAW
IN DIVORCE and CUSTODY
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA)
) SS:
COUNTY OF CUMBERLAND )
I, ELIZABETH B. STONE, of Stone LaFaver & Shekletski, attorneys
for the plaintiff hereby certify that I served the Complaint in
Divorce in the above captioned matter on the defendant, MATTHEW S.
STEPLER, at 1845 Hunter Drive, Mechanicsburg, Pennsylvania 17050, by
United States Certified Mail, postage prepaid, return receipt
requested, restricted delivery, on January 14, 200.6,, as evidenced by
the attached Certified Mail return receipts.
ELIZA$L?TH B. STONE
SWORN TO AND SUBSCRIBED
before me this lb \?k day
of January i--2006.
Notary Pubjic
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
KATHLEEN KEIM, Notary Public
New Cumberland Boro. Cumberland Co.
My Commission Expires Dec. 5, 2006
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¦ Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
¦ 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 mailpiece,
or on the front if space permits.
1. Article Addressed to:
TA ?Uiivk \r
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A. Received by (Please Print Clearly) I S. Date of Delivery
C. Si nature
13 Agent
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D. Is delivery address diff 'fem- Yes
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If YES, enter delivery as
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3. Srce Type
M Certified Mail ? press Mail
? Registered Vurn Receipt for Merchandise
? Insured Mail ? C.O.D.
4. Restricted Delivery? (Extra Fee) Yes
2. Article Number (Copy from service label) "i 3?V
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PS Form 3811, July 1999 Domestic Return Receipt
102595-004-0952
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7. The Plaintiff avers that two children, ASHLEY MARIE STEPLER
and CHEYENNE MONTGOMERY STEPLER, have been born of this marriage.
8. The Plaintiff has been advised that counseling is available
and that the Plaintiff may have the right to request that the court
require the parties to participate in counseling.
9. The Plaintiff requests the court to enter a decree of
divorce.
COUNT I - CUSTODY
10. Paragraphs one (1) through nine (9) are incorporated herein
by reference as though fully set forth at. length.
11. The Plaintiff in this action is AUTUMN L. STEPLER, an adult
individual, who currently resides at 1845 Hunter Drive, Mechanicsburg,
Cumberland County, Pennsylvania, 17050.
18. The Defendant in this action is MATTHEW S. STEPLER, an adult
individual, who currently resides at 1845 Hunter Drive, Mechanicsburg,
Cumberland County, Pennsylvania, 17050.
19. Plaintiff seeks primary physical custody of ASHLEY MARIE
STEPLER and CHEYENNE MONTGOMERY STEPLER, who resides with the
Plaintiff, at 1845 Hunter Drive, Mechanicsburg, Cumberland County,
Pennsylvania, 17050. ASHLEY MARIE STEPLER is nine (9) years of age
having been born on January 19, 1996. CHEYENNE MONTGOMERY STEPLER is
five (5) years of age having been born on August 13, 2000. The
children were not born out of wedlock.
-2-
The children are presently in the custody of their mother, the
Plaintiff above-named.
The Plaintiff seeks majority physical cus-ody of the children.
Plaintiff agrees to shared legal custody of the minor children with
the Defendant enjoying partial physical custody.
During the past five years, the children have resided with the
following persons and at the following addresses:
NAME ADDRESS DATES
Plaintiff & Defendant 1845 Hunter Drive 01/19/96 to
Mechanicsburg, PA 17050 Present
The mother of the children is the Plaintiff, AUTUMN L. STEPLER,
an adult individual, who currently resides at 1845 Hunter Drive,
Mechanicsburg, Cumberland County, Pennsylvania, 17050.
The father of the children is the Defendant, MATTHEW S. STEPLER,
an adult individual, who currently resides at 1845 Hunter Drive,
Mechanicsburg, Cumberland County, Pennsylvania, 17050. He is married
to the Plaintiff.
20. The relationship of Plaintiff to the children is that of
mother. The Plaintiff currently resides with the following persons:
NAME RE:1ATIONSHIP
CASSIE MCQOISTON Daughter
Minor children, ASHLEY MARIE STEPLER Daughters
and CHEYENNE MONTGOMERY STEPLER
Defendant, MATTHEW S. STEPLER Husband
-3-
21. The relationship of Defendant to the children is that of
father. The Defendant currently resides with the following persons:
NAME RELATIONSHIP
Same as above
22. 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 tr_is Commonwealth.
Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the minor children or claims
to have custody or visitation rights with respect to the children.
Plaintiff consents to the jurisdiction of Cumberland County.
23. The best interest and permanent welfare of the minor
children will be served by granting the relief requested because:
A. The children have resided with their mother since birth
who have provided a continuous loving relationship with the children;
B. The mother is able to provide a stable home and extended
family environment for the children allowing the children opportunity
to spend time with the children's father consistent with a schedule
the parties have arranged between themselves.
-4-
24. Each parent whose parental rights to the children have not
been terminated and the person who has physical custody of the
children has been named as parties to this action.
Plaintiff respectfully requests that this Court grant
the Plaintiff majority physical custody of the children with shared
legal custody to the Defendant, giving the Defendant partial physical
custody.
STONE LaFAVER
By z 1101, ? /I
E zab one, Esquire
up Cour ID #60251
4 ridge treet, P.O. Box E
ew Cumb :Land, PA 17070
Telepho 17-774-7435
Attor s :for Plaintiff
-5-
_I
V E R I F I C A T I O N
Autumn L. Stepler states that she is the Plaintiff named in the
foregoing instrument and that she is acquainted with the facts set
forth in the foregoing instrument; that the same are true and correct
to the best of her knowledge, information and belief; and that this
statement is made subject to the penalties of 18 Pa. C.S.A. §4904
relating to unsworn falsification to authorities.
Autumn L. epler
Date: C'-
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AUTUMN L. STEPLER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
MATTHEW S. STEPLER
DEFENDANT
06-198 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Friday, January 20, 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's,1901 State St., Camp Hill, PA 17011 on Thursday, February 23, 2006 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/ Melissa P. Gree. t y, Esq_ ry?
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. '(on 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
FORTII 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
9r7 F_'.
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AN IN
AUTUMN L. STEPLER,
Plaintiff
PGR I i ?N6
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IN THE COURT OF COMNtOfV--rPf€A3?
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-198 CIVIL TERM
V.
MATTHEW S. STEPLER,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
Bq ORDER OF COURT
S
AND NOW, this day of March, 2006, upon concurrence of counsel and
because the parties con Inue to reside in the same residence, this matter is continued. It is
hereby directed that the parties and their respective counsel appear before Melissa Peel
Greevy, Esquire, the Conciliator, at 1901 State Street, Camp Hill, Pennsylvania 17011
on the 5th day of May, 2006 at 10:30 a.m. for a Custody Conciliation 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 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 OURT
Melissa Peel Greevy, Esquire
Custody Conciliator
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, 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
Dist: Elizabeth B. Stone, Esq., 414 Bridge Street, P. 0. Box E, New Cumberland, PA 17070
William Tully, Esq., 3964 Lexington Street, Suite B, Harrisburg, PA 17109
:272114
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AUTUMN L. STEPLER,
Plaintiff
V.
MATTHEW S. STEPLER,
Defendant
NO. 2006-198 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 children who are the subject of this
litigation is as follows:
NAME
DATE OF BIRTH
Ashley Marie Stepler January 19, 1996
Cheyenne Montgomery Stepler August 13, 2000
CURRENTLY IN CUSTODY OF
Mother and Father
Mother and Father
2. Mother filed a Divorce Complaint on January 11, 2006, seeking primary
physical custody and shared legal custody. The original Custody Conciliation Conference
had been scheduled for February 23, 2006. However, upon concurrence of counsel, the
matter was continued due to an emergency situation which made the Plaintiff unavailable.
The matter was rescheduled for March 24, 2006. Attending the counsel were: the Mother,
Autumn L. Stepler, and her counsel, Elizabeth B. Stone, Esquire; the Father, Matthew S.
Stepler, and his counsel, William T. Tully, Esquire. At the time of the conference, both
parties were residing together in the marital home and separation had not occurred. Neither
party had imminent plans to leave the marital home. Accordingly, the conference was
continued to May 5, 2006 at 10:30 a.m. to allow the parties and their counsel to have further
opportunity to prepare for separation or for the Court to rule on a possible Petition for
Exclusive Possession of the Marital Residence. An Order rescheduling the Conciliation
Conference its attached.
Date:
Melissa Peel Greevy, Esquire
Custody Conciliator
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:272114
RECEIVED MAY 1 6 AUTUMN L. STEPLER, IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
MATTHEW S. STEPLER,
Defendant
NO. 06-198 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
INTERIM ORDER OF COURT
AND NOW, this day of May, 2006, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. Legal Custody. The parties, Autumn L. Stepler and Matthew S. Stepler, shall
have shared legal custody of the minor children, Ashley Marie Stepler, born January 19,
1996 and Cheyenne Montgomery Stepler, born August 13, 2000. 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 health, education and religion. Pursuant to the terms of 23 Pa.
C. S. §5309, each parent shall be entitled to all records and information pertaining to the
children including, but not limited to, medical, dental, religious or school records, the
residence address of the children and of the other parent. To the extent one parent has
possession of any such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent.
2. Physical Custody. The parties shall share physical custody of the children in
accordance with the following schedule:
Until the 2005/2006 school year ends, the physical custody schedule shall be as
follows:
A. Father shall have custody on May 5, 2006 until May 6, 2006.
B. Father shall have custody on May 12, 2006 after school until 9:00 a.m.
on May 14, 2006.
C. Effective May 26, 2006, Father shall have custody on alternating
weekends from Friday after school until Sunday at 6:00 p.m.
D. Commencing May 8, 2006, Father shall have custody each Monday
and Wednesday from after school until 8:00 p.m.
E. When Father does not have custody, Mother shall have custody.
NO. 06-198 CIVIL TERM
After the 2005/2006 school year ends, the interim summer physical custody schedule
shall be as follows:
A. Mother shall have temporary primary physical custody. Father shall
have custody on alternating weekends from Friday morning until
Monday morning and on Wednesdays until 8:00 p.m. By mutual
agreement of the parties, Father's Wednesday periods of physical
custody may be extended to overnight to become an overnight period of
custody.
B. During the summer 2006 school recess, Father shall be the alternative
to a daycare provider during Mother's work hours. The parties
recognize that this arrangement has been put in place as a result of
Father's temporary medical disability following a motor vehicle accident
on March 31, 2006.
C. Mother will make reasonable efforts to coordinate the weekend
custodial schedule with Cassie's weekend custody schedule.
3. Vacation. The parties recognize that Mother has six weeks of vacation each
year. Each parent shall be entitled to up to one week each summer school recess for
purposes of summer vacation with the children. At Mother's option and upon reasonable
notice to Father, Mother may extend her custodial weekends by up to two days or longer, as
the parties may agree.
4. Transportation. The parent receiving custody shall provide transportation
incident to the custodial exchange.
5. Holiday Schedule.
A. Christmas. The Christmas Holiday shall be divided into Segment A,
which shall run from Christmas Eve at 12:00 noon through Christmas
Day at 12:00 noon, and Segment B, which shall run from Christmas
Day at 12:00 noon through December 26 at 12:00 noon. The Mother
shall have custody of the children during Segment A in even numbered
years and during Segment B in odd numbered years. The Father shall
have custody of the children during Segment A in odd numbered years
and during Segment B in even numbered years.
B. Thanksgiving. In even numbered years, the Father shall have custody
of the children on Thanksgiving Day from 9:00 a.m. until 8:00 p.m. and
in odd numbered years, the Mother shall have custody of the children
on Thanksgiving Day.
NO. 06-198 CIVIL TERM
C. New Years. In even numbered years, the Father shall have custody of
the children from New Years Eve after work through New Years Day at
8:00 p.m. and in odd numbered years, the Mother shall have custody of
the children on New Years Eve through New Years Day at 8:00 p.m.
For purposes of this provision, the entire New Years holiday shall be
deemed to fall in the same year as New Years Eve.
D. Easter. The Easter holiday shall run from the Friday before Easter at
6:00 p.m. through Easter Sunday at 8:00 p.m. The Mother shall have
custody of the children over Easter in even numbered years and the
Father shall have custody over Easter in odd numbered years.
E. Memorial Day/July 4th/Labor Day_. In odd numbered years, the Father
shall have custody of the children on the Memorial Day and Labor Day
weekends from Friday at 6:00 p.m. through Monday at 8:00 p.m. and
the Mother shall have custody over the Independence Day holiday from
July 3?d at 6:00 p.m. until after the fireworks on July 4th. In even
numbered years, the Mother shall have custody of the children on the
Memorial Day and Labor Day weekends from Friday at 6:00 p.m.
through Monday at 8:00 p.m. and the Father shall have custody over
the Independence Day holiday from July 3rd at 6:00 p.m. until after the
fireworks on July 4th
F. Halloween Trick-Or-Treat Night. The Father shall have custody of the
children for trick-or-treat night in even numbered years and the Mother
shall have custody of the children for trick-or-treat night in odd
numbered years at times to be arranged by agreement of the parties. If
each party's community schedules trick-or-treat night on different
evenings, each party shall be entitled to have custody of the children on
his or her community's trick-or-treat night.
G. Mother's Day/Father's Day. The Mother shall have custody of the
children every year on Mother's Day and the Father shall have custody
of the children every year on Father's Day at times to be arranged by
agreement of the parties.
H. The holiday custody schedule shall supersede and take precedence
over the regular custody schedule.
6. During any period of custody or visitation, the parties to this Order shall not
possess or use controlled substances, neither shall they consume alcoholic beverages to
NO. 06-198 CIVIL TERM
the point of intoxication. The parties shall likewise ensure, to the extent possible, that the
other household members and/or house guests comply with this prohibition.
7. Each party shall sign the appropriate authorization to release confidential
information from their therapist to their attorney so that counsel may have the opportunity to
verify their client's participation in assessment and/or treatment, as well as their compliance
with the recommended care program.
8. The Custody Conciliation Conference shall reconvene on Friday, August
11, 2006 at 9:00 a.m. at the office of the Custody Conciliator, Melissa Peel Greevy,
Esquire, 1901 State Street, Camp Hill, PA 17011. This Conference may be cancelled by
the MUTUAL agreement of the parties if communicated to the Conciliator in writing by
August 3, 2006.
Dist: ?,VVilliam T. Tully, Esq., 3964 Lexington Street, Suite B, Harrisburg, PA 17109
l./__zabeth B. Stone, Esq., 414 Bridge Street, P. O. Box E, New Cumberland, PA 17070
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AUTUMN L. STEPLER,
Plaintiff
MCP ? 2Q96
IN THE COURT OF COMNTO1n?L?A?OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-198 CIVIL TERM
V.
MATTHEW S. STEPLER,
Defendant
IN CUSTODY
TEMPORARY ORDER OF COURT
AND NOW, this day of Se e e_,2006, upon consideration of the
attached Custody Conciliation Summary Report, it is hereby ordered and directed as
follows:
1. Legal Custody. The parties, Autumn L. Stepler and Matthew S. Stepler, shall
have shared legal custody of the minor children, Ashley Marie Stepler, born January 19,
1996 and Cheyenne Montgomery Stepler, born August 13, 2000. 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 health, education and religion. Pursuant to the terms of 23 Pa.
C. S. §5309, each parent shall be entitled to all records and information pertaining to the
children including, but not limited to, medical, dental, religious or school records, the
residence address of the children and of the other parent. To the extent one parent has
possession of any such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent.
2. Physical Custody. Physical custody of the children shall be arranged as
follows:
A. Father shall have custody on alternating weekends from Friday after school
until Sunday at 7:00 p.m., commencing September 15, 2006.
B. Father shall have custody on alternating Mondays from after school until 8:00
p.m., commencing September 25, 2006.
C. Each Wednesday Father shall have custody until Thursday morning, when the
children are returned to their Mother, who will care for them until the school
bus comes.
CIVIL ACTION - LAW
D. When Father does not have custody, Mother will have custody.
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NO. 06-198 CIVIL TERM
3. Summer Custodial Schedule. The parties will share custody of the children on
alternating weeks during the summer school recess, commencing with the first Sunday that
school is out. Custody shall be exchanged on Sundays at 6:00 p.m. The summer schedule
shall end the Sunday immediately preceding the commencement of school.
4. Holiday Schedule. The following holiday schedule shall supercede the regular
schedule:
A. Christmas. The Christmas Holiday shall be divided into Segment A, which
shall run from Christmas Eve at 12:00 noon through Christmas Day at 12:00
noon, and Segment B, which shall run from Christmas Day at 12:00 noon
through December 26 at 12:00 noon. Mother shall have custody of the
children during Segment A in even numbered years and during Segment B in
odd numbered years. Father shall have custody of the children during
Segment A in odd numbered years and during Segment B in even numbered
years.
B. Thanksgivinq. In even numbered years, Father shall have custody of the
children on Thanksgiving Day from 9:00 a.m. until 9:00 a.m. the day after. In
odd numbered years, Mother shall have custody of the children on
Thanksgiving Day.
C. New Years. In even numbered years, Father shall have custody of the
children from New Years Eve after work through New Years Day at 8:00 p.m.
and in odd numbered years, Mother shall have custody of the children on New
Years Eve through New Years Day at 8:00 p.m. For purposes of this
provision, the entire New Years holiday shall be deemed to fall in the same
year as New Years Eve.
D. Easter. The Easter holiday shall run from the Friday before Easter at 6:00
p.m. through Easter Sunday at 8:00 p.m. Mother shall have custody of the
children over Easter in even numbered years and Father shall have custody
over Easter in odd numbered years.
E. Memorial Day/July 4th/Labor Day . In odd numbered years, Father shall have
custody of the children on the Memorial Day and Labor Day weekends from
Friday at 6:00 p.m. through Monday at 8:00 p.m. and Mother shall. have
custody over the Independence Day holiday from July 3rd at 6:00 p.m. until
after the fireworks on July 4tn. In even numbered years, Mother shall have
custody of the children on the Memorial Day and Labor Day weekends from
Friday at 6:00 p.m. through Monday at 8:00 p.m. and Father shall have
custody over the Independence Day holiday from July 3rd at 6:00 p.m. until
tn
after the fireworks on July 4
NO. 06-198 CIVIL TERM
F. Halloween Trick-Or-Treat Night. Father shall have custody of the children for
trick-or-treat night in even numbered years and Mother shall have custody of
the children for trick-or-treat night in odd numbered years at times to be
arranged by agreement of the parties. If each party's community schedules
trick-or-treat night on different evenings, each party shall be entitled to have
custody of the children on his or her community's trick-or-treat night.
G. Mother's Day/Father's Day. Mother shall have custody of the children every
year on Mother's Day and Father shall have custody of the children every year
on Father's Day at times to be arranged by agreement of the parties.
5. During any period of custody or visitation, the parties to this Order shall not
possess or use non-prescribed controlled substances, neither shall they consume alcoholic
beverages to the point of intoxication. The parties shall likewise ensure, to the extent
possible, that the other household members and/or house guests comply with this
prohibition.
6. Each party shall sign the appropriate authorization to release confidential
information from their therapist to their attorney so that counsel may have the opportunity to
verify their client's participation in assessment and/or treatment, as well as their compliance
with the recommended care program.
7. The Custody Conciliation Conference shall reconvene on Friday,
December 15, 2006 at 9:00 a.m. at the office of the Custody Conciliator, Melissa Peel
Greevy, Esquire, 1901 State Street, Camp Hill, PA 17011. This Conference may be
cancelled by the MUTUAL agreement of the parties if communicated to the Conciliator in
writing by December 1, 2006.
BY THE COURT:
C--,-
J.
Dist:
li eth B. Stone, Esquire P. O. Box E New lumberland, PA 17070
illiam T. Tully, Esquire, 3964 Lexington Street, Suite B, Harrisburg, PA 17109
- 14,
4
AUTUMN L. STEPLER,
Plaintiff
V.
MATTHEW S. STEPLER,
Defendant
NO. 06-198 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
Ashley Marie Stepler January 19, 1996
Cheyenne Montgomery Stepler August 13, 2000
Mother
Mother
2. The parties were scheduled for their third Custody Conciliation Conference on
September 15, 2006. Present for the conference were: the Mother, Autumn L. Stepler, and
her counsel, Elizabeth B. Stone, Esquire; the Father, Matthew S. Stepler and his counsel,
William Tully, Esquire.
3. The parties reached an agreement in the form of an Order as attached and the
agreement was premised on the parties returning for a review of how the plan is working.
The parties agreed to return in mid-December.
Date
S E P 2 1 2006
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Melissa Peel Greevy, Esquir
Custody Conciliator
283499
DEC 18 2006
AUTUMN L. STEPLER, :
Plaintiff
V.
MATTHEW S. STEPLER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-198 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
ORDER
AND NOW, this L?-kday of December, 2006, pursuant to agreement of the parties,
Custody Conciliation Conference presently scheduled for December 15, 2006 at 9:00 a.m. is
canceled. The Conciliator relinquishes jurisdiction of this matter.
FOR THE COU
B
Issa Peel Greevy, Esquire
Custody Conciliator
Dist.: Elizabeth B. Stone, Esquire, P. O. Box E, New Cumberland, PA 17070
William T. Tully, Esquire, 3964 Lexington Street, Ste B, Harrisburg, PA 17109
Taryn Dixon, Court Administrator, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013
288642
9? : I I tIT 61 010 90+OZ
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fl\div\STEPLER,AUTUMN-aff&waiver
AUTUMN L. STEPLER,
V.
IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-198 CIVIL
MATTHEW S. STEPLER, : CIVIL ACTION - IN DIVORCE and CUSTODY
Defendant
AFFIDAVIT OF CONSENT
1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on January 11, 2006,
and served January 14, 2006.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing the complaint and service of the complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to request
entry of the decree.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or
expenses if I do not claim them before a divorce is granted.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or
expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorce until a divorce decree is entered by the court and that a
copy of the decree will be sent to me immediately after it is filed with the Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifica-
tion to authorities. C?
Or a3. o
Date A L. STE laintiff
fl \div\S TE P LER,A UTUMN-aff&wai ver
AUTUMN L. STEPLER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 2006-198 CIVIL
MATTHEW S. STEPLER, : CIVIL ACTION - IN DIVORCE and CUSTODY
Defendant
AFFIDAVIT OF CONSENT
1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on January 11, 2006,
and served January 14, 2006.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing the complaint and service of the complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to request
entry of the decree.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or
expenses if I do not claim them before a divorce is granted.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or
expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorce until a divorce decree is entered by the court and that a
copy of the decree will be sent to me immediately after it is filed with the Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifica-
tion to authorities. I
a o
Date MATTHEW S. STE LER, Defendant
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AUTUMN L. STEPLER,
PLAINTIFF
V.
MATTHEW S. STEPLER,
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL DIVISION
NO. 2006-198 CIVIL TERM
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information to the court for entry of a divorce
decree:
1. Ground for divorce:
Irretrievable breakdown under §3301(c)
330f (d)(1) of the Divorce Code. (Strike out inapplicable section).
2. Date and manner of service of the complaint: January 14, 2006 via U.S. certified
mail, postage prepaid, return receipt requested, restricted delivery
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by §3301(c) of the
Divorce Code:
by Plaintiff 01/23/08 ; by Defendant 01/23/08
(b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce
Code:
(2) Date of filing and service of the Plaintiff's affidavit upon the respondent:
4. Related claims pending: All claims settled
5. Complete either (a) or (b).
(a) Date and manner of service of the notice of intention to file praecipe to
transmit record, a copy of which is attached:
(b) Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: 4 f o 9
Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: t1dX1 Q?
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
AUTUMN L. STEPLER
PLAINTIFF
NO. 2006-198 CIVIL
VERSUS
MATTHEW S. STEPLER
DEFENDANT
DECREE IN
DIVORCE
AND NOW, Z !7, ,J0 200S, IT IS ORDERED AND
DECREED THAT AUTUMN L. STEPLER , PLAINTIFF,
AND MATTHEW S. STEPLER DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
BY THE COURT
PROTHONOTARY
,V4?-