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HomeMy WebLinkAbout06-0579TONYA S. YEINGST, Plaintiff V. JASON L. YEINGST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-9 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may 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 Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 TONYA S. YEINGST, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006- CIVIL TERM JASON L. YEINGST, CIVIL ACTION-LAW Defendant IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is Tonya S. Yeingst, an adult individual who currently resides at 190 Pine School Road, Gardners, Cumberland County, Pennsylvania 17324. 2. Defendant is Jason L. Yeingst, an adult individual who currently resides at 465 Upper Bermudian Road, Gardners, Adams County, Pennsylvania 17324. 3. Plaintiff and the Defendant have been bonafide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 12,1995, in Mt. Holly Springs, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties as to their current marriage. 6. Plaintiff and Defendant are not in the Armed Forces of the United States. 7. Plaintiff avers that the marriage between the parties is irretrievably broken. 8. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree in divorce. Respectfully submitted, O'BRIEN, BARIC & SCHERER ?av v Michael A. Scherer, Esquire I.D. # 69174 19 West South Street Date: 2.1' 06 Carlisle, Pennsylvania 17013 (717) 249-6873 46 VERIFICATION I verify that the statements made in the foregoing Complaint 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. C )t Q& Tonya S. Yei gst Date: (-,???)-L C TONYA S. YEINGST, Plaintiff V. JASON L. YEINGST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006- CIVIL TERM CIVIL ACTION-LAW IN DIVORCE ACCEPTANCE OF SERVICE AND NOW, this day of , 2006, I, Jason L. Yeingst, Defendant above, hereby accept service of the Complaint filed in the above case pursuant to Pa. R.C.P. 1920.4(e) and acknowledge receipt of a true and attested copy of said Complaint. Jason L. Yeingst -v w w? n 0 car cn c, ?' o (DI TONYA S. YEINGST, Plaintiff vs. JASON L. YEINGST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006- 5/n 9 CIVIL IN DIVORCE ACCEPTANCE OF SERVICE AND NOW, this ?l?5 l4 day of 2006, I, Jason L. Yeingst, Defendant above, hereby accept service of the Complaint filed in the above case pursuant to Pa. R.C.P. 1920.4(e) and acknowledge receipt of a true and attested copy of said Complaint. ®? ? d` ---t '-?: yr, .', rt?1 r .?F. iii J ..? C> `pL S'v TONYA S. YEINGST, Plaintiff V. JASON L. YEINGST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006- CIVIL TERM CIVIL ACTION-LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on January 27, 2006. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of a final decree in divorce without notice. 4. 1 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. 5. 1 understand that I will not be divorced 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. 6. 1 have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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.A. Section 4904 relating to unsworn falsification to authorities. c? Date: May, 2006 o ya S. Yeing t h.) ? ???? ? ? - Ti ?.r" P(? ? .:.' r Y - { T i. _ n;r^ - t?C7 err - < "'La ? ,; .. ??? :n Y TONYA S. YEINGST, Plaintiff V. JASON L. YEINGST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006- 57 f CIVIL TERM CIVIL ACTION-LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on January 27, 2006. 2. Defendant acknowledges receipt and accepted service of the Complaint on January 28, 2006. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. 1 consent to the entry of a final decree in divorce without notice. 5. 1 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. 6. 1 understand that I will not be divorced 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. 7. 1 have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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.A. Section 4904 relating to unsworn falsification to authorities. Date: May S, 2005 T, : s` ,:. G? TONYA S. YEINGST, Plaintiff V. JASON L. YEINGST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-0579 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE 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 Section 3301(c)of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant signed an Acceptance of Service on January 28, 2006. 3. (complete either paragraph (a) or (b).) A. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff on May 3, 2006; and Defendant on May 3, 2006. B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) date of service of the Plaintiffs Affidavit upon the Defendant: N/A 4. Related claims pending: None. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301(d)(1)(i) of the Divorce Code: None. Respectfully submitted, O'BRIEN, BARIC & SCHERER X44 .N_ Michael A. Scherer, Esquire m r`,E; ?` fTlf =. i7- Co -4 `,iJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY %rA STATE OF PENNA. TONYA S. YEINGST, No. 2006 - 0579 Plaintiff VERSUS JASON L. YEINGST, Defendant DECREE IN DIVORCE CIVIL AND NOW, ---"a, /O G , IT IS ORDERED AND DECREED THAT TONYA S. YEINGST , PLAINTIFF, AND JASON L. YEINGST 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; NONE PROTHONOTARY 4? 1 t a? 9© -v -,5q©• l-' S TONYA S. YEINGST, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 2006-0579 CIVIL TERM JASON L. YEINGST, : Defendant : IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Tonya S. Yeingst, by her attorneys, Irwin & McKnight, and presents the following Complaint for Custody. 1. The Plaintiff, Tonya S. Yeingst, is an adult individual with an address of 190 Pine School Road, Gardners, South Middleton Township, Cumberland County, Pennsylvania 17324. 2. The Defendant, Jason L. Yeingst, is an adult individual with an address of 465 Upper Bermudian Road, Gardners, Adams County, Pennsylvania 17324. 3. The parties are the natural parents of four (4) children, namely, Kodi A. Van Meter, born March 12, 1990; Kayla R. Van Meter, born October 25, 1992; Kelli J. Yeingst, born December 26, 1994, and Kayce J. Yeingst, born July 19, 1996. 4. The Plaintiff desires that the parties have shared legal custody of said minor children. 3 5. The Plaintiff desires primary physical custody of the minor children with periods of temporary physical custody to Defendant as the parties can agree. 6. The Plaintiff requests a provision that neither parry will remove the children from the Commonwealth of Pennsylvania without the express written permission of the other party or an Order of Court permitting said removal. 7. The best interests and permanent welfare of the minor children requires that the Court grant the Plaintiffs request as set forth above. WHEREFORE, the Plaintiff, Tonya S. Yeingst, respectfully requests that she be awarded primary physical custody and shared legal custody of Kodi A. Van Meter, Kayla R. Van Meter, Kelli J. Yeingst, and Kayce J. Yeingst, as provided herein, with periods of temporary physical custody to Defendant as provided herein. Respectfully submitted, IRWIN &McKNIGHT By: Marc's A. g II, Esquire Atto or Plaintiff est Pomfret street lisle, Pennsylvania 17 3-3222 (71 - Supreme Court L D. No. 25476 Date: February 2, 2007 4 VERIFICATION The foregoing Complaint for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unworn falsification to authorities. . ?'M V I o ' q4 TONYA E T Date: February 2, 2007 rK__ ?'1 ?4 ...?, ,_r, tip'; ^...1 -. . ?; 3 ?? ct ?? fin' __., ? ??? ? =-? ?? ?? C,.,'"i ? r ? ? . a tia- -..?i TONYA S. YEINGST IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JASON L. YEINGST DEFENDANT 06-0579 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Thursday, February 08, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, March 13, 2007 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR. THE COURT, By: /s/ acqueline M. Verney, Esq__ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 4%?? * -"!- *,O? 4 ? 0-14, e7 ev? -;.P? `?.6' 7 TONYA S. YEINGST, Plaintiff V. JASON L. YEINGST, Defendant MAR 14 2007pN : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006-0579 CIVIL ACTION - LAW : IN CUSTODY JORDER OF COURT AND NOW, this i p' day of -m74-?CA , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Tom shared legal custody of Kodi A. born October 25, 1992, Kelli J. 1 born July 19, 1996. Each parent other parent, to make all major n well-being including, but not lim and religion. Pursuant to the ten all records and information perta medical, dental, religious or schc other parent. To the extent one 1 that parent shall be required to sl within such reasonable time as t( the other parent. Both parents A medical/treatment planning mee Each parent shall be entitled to teacher or authority and copies limited to: medical records, birt report cards. Additionally, each which come from school with re children's parties, musical prese 2. Father shall periods of partial physical ja S. Yeingst and the Father, Jason L. Yeingst, shall have Jan Meter, born March 12, 1990, Kayla R. Van Meter, 'eingst, born December 26, 1994 and Kayce J. Yeingst, shall have an equal right, to be exercised jointly with the )n-emergency decisions affecting the Children's general ited to, all decisions regarding their health, education is of 23 Pa.C.S. §5309, each parent shall be entitled to ning to the children including, but not limited to of records, the residence address of the children and the arent has possession of any such records or information, are the same, or copies thereof, with the other parent make the records and information of reasonable use to all be entitled to full participation in all educational and ings and evaluations with regard to the minor children. ill and complete information from any physician, dentist, ' any reports given to them as parents including, but not certificates, school or educational attendance records or )arent shall be entitled to receive copies of any notices ;ard to school pictures, extracurricular activities, tations, back-to-school nights, and the like. imary physical custody of Kelli, with Mother having as agreed by the parties. 3. Mother shall hav primary physical custody of Kayce, with Father having periods of partial physical custo y as agreed by the parties. 4. Parents shall sha e physical custody of Kodi and Kayla as agreed by the parties. 5. The parties shall s are holidays as agreed. Mother shall have physical custody of the children on Mother's Day and Father shall have physical custody of the children on Father's Day. 6. Transportation sh 111 be shared such that the relinquishing party shall transport. 7. Neither party shall do or say anything, nor permit a third party from doing or saying anything that may estrakige the children from the other parent, injure the opinion of the children as to the other parent, or hamper the free and natural development of the children's love and respect for the other parent. 8. Custody issues shall be discussed only by the parents and shall not include the children or third parties. 9. For tax years 2000 and 2007, Father shall be entitled to claim the three older children and Mother shall be entitled to claim Kayce. 10. This Order is ente ed pursuant to an agreement of the parties at a Custody Conciliation Conference. Theparties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference may be scheduled within 90 days of the date of this Order. BY THE COURT, -,?, •'VIL J. c us A. McKnight, III, Esquire, Co Zselor Mother ason L. Yeingst, pro se 465 Upper Bremudian Road Gardners, PA 17324 1 VINPVA iiASNN?d 19 sZ Wd 61 8Va LODZ hEl ONOH.zOdd, 3HU ?O 901±O- ly TONYA S. YEINGST, Plaintiff V. JASON L. YEINGST, Defendant PRIOR JUDGE: None IN ACCORDANCE' PROCEDURE 1915.3-8, the report: 1. The pertinent this litigation is as follows: NAME Kodi A. Van Meter Kayla R. Van Meter Kelli J. Yeinst Kayce J. Yeingst : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-0579 CIVIL ACTION - LAW IN CUSTODY CUMBERLAND COUNTY RULE OF CIVIL igned Custody Conciliator submits the following concerning the Children who are the subject of DATE OF BIRTH CURRENTLY IN CUSTODY OF arch 12, 1990 shared O tober 25, 1992 shared D cember 26, 1994 Father J ly 19, 1996 Mother 2. A Conciliation Conference was held in this matter on March 13, 2007, with the following in attendanc : The Mother, Tonya S. Yeingst, with her counsel, Marcus A. McKnight, III, Esquire, and the Father, Jason L. Yeingst, pro se. 3. The parties 3-13-o-I Date to an Order in the form as attached. acq ine M. Verney, Esquire Custody Conciliator fJAN $ 8 20 TONYA S. YEINGST, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-0579 CIVIL ACTION - LAW JASON L. YEINGST, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 28th day of January, 2008, neither party having contacted the Conciliator to schedule another conference and more than ninety days have passed since the prior Order of Court, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, IVl U acq eline M. Verney, Esquire, stody Conciliator cr) THE c; 1 TONYA S. (YEINGST) GRIFFIE, Petitioner/Plaintiff V. JASON L. YEINGST, Respondent/Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-0579 CIVIL TERM IN CUSTODY PETITION FOR SPECIAL EMERGENCY RELIEF AND NOW, this 16th day of February, 2011, comes the Petitioner, Tonya S. Griffie, by her attorneys, Irwin & McKnight, P.C., and presents the following Petition for Special Emergency Relief: 1. The Petitioner, Tonya S. Griffie, is an adult individual with an address of 190 Pine School Road, Gardners, South Middleton Township, Cumberland County, Pennsylvania 17324. 2. The Respondent, Jason L. Yeingst, is an adult individual with an address of 734 Pigeon Hill Road, Gaines, Tioga County, Pennsylvania 16921. 3. The parties are the natural parents of two (2) minor children, namely, Kelli J. Yeingst, born December 26, 1994 (age 16), and Kayce J. Yeingst, born July 19, 1996 (age 14). 71), 66 pd a-* 6 ?3? 2 4. The parties are currently governed by an Order of Court dated March 19, 2007, which orders shared physical custody and joint legal custody of said minor children. Said Order of Court is attached hereto and marked as Exhibit "A". 5. Since February 2010, both of said minor children have resided with the Petitioner and attended school in the South Middleton School District. Both children desire to remain in school in the South Middleton School District and with their mother at her home in South Middleton Township. 6. On Monday morning, February 14, 2011, the parties attended a support conference at Cumberland County Domestic Relations where an agreement for the support of said minor children was reached by the parties. 7. On Tuesday, February 15, 2011 the Respondent called both children and threatened to take one or both of the children to Tioga County and remove them from the school district where they have attended school for the past year. 8. The Petitioner filed a petition for primary physical custody of said minor children on February 18, 2011. A Custody Conciliation Conference is scheduled for Monday, March 7, 2011 at 9:30 a.m. before Jacqueline M. Verney, Esq., a copy of said Order is attached hereto and marked as Exhibit "B". 3 9. The Petitioner seeks an Order of Court which provides for the following: a. From the date of Order until March 7, 2011, both Kelli J. Yeingst and Kayce J. Yeingst will remain in the primary physical custody of the Petitioner/Mother, Tonya S. Griffie, and remain residents of Cumberland County attending school in the South Middletown School District. b. The Respondent/Father, Jason L. Yeingst, will cease making telephone calls and/or sending text messages to said minor children which threaten to remove them from school or from the physical custody of the Plaintiff. c. The parties may agree to periods of temporary custody of said minor children with the Respondent until the Custody Conciliation Conference scheduled for March 7, 2011. WHEREFORE, the Petitioner, Tonya S. Griffie, respectfully requests an Order of Court which implements the above and keeps the physical custody of Kelli J. Yeingst and Kayce J. Yeingst in place as it has been for the past year. Respectfully submitted, IRWIN & 11 ,AcKNI,GHT, P.C. By: A. Nf Knioht, III, Esquire 6(TWest Po ret Street Carlisle, Penns 'a 17013-3222 (717) 249-2353 Date: February 16, 2011 Supreme Court I. D. No. 25476 4 EXHIBIT "A" P MAR 1 4 2007 TONYA S. YEINGST, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-0579 CIVIL ACTION - LAW JASON L. YEINGST, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 17Th day of , 2007, upon consideration of the attached Custody Concilia ion Report, it is ordered and directed as follows: 1. The Mother, Tonya S. Yeingst and the Father, Jason L. Yeingst, shall have shared legal custody of Kodi A. Van Meter, born March 1:2, 1990, Kayla R. Van Meter, born October 25, 1992, Kelli J. Yeingst, born December 26, 1994 and Kayce J. Yeingst, born July 19, 1996. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their 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 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. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. Father shall have primary physical custody of Kelli, with Mother having periods of partial physical custody as agreed by the parties. 3. Mother shall have primary physical custody of Kayce, with Father having periods of partial physical custody as agreed by the parties. 4. Parents shall share physical custody of Kodi and Kayla as agreed by the parties. or/ • 5. The parties shall share holidays as agreed. Mother shall have physical custody of the children on Mother's Day and Father shall have physical custody of the children on Father's Day. 6. Transportation shall be shared such that the relinquishing party shall transport. 7. Neither party shall do or say anything, nor permit a third party from doing or saying anything that may estrange the children from the other parent, injure the opinion of the children as to the other parent, or hamper the free and natural development of the children's love and respect for the other parent. 8. Custody issues shall be discussed only by the parents and shall not include the children or third parties. 9. For tax years 2006 and 2007, Father shall be entitled to claim the three older children and Mother shall be entitled to claim Kayce. 10. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference may be scheduled within 90 days of the date of this Order. BY THE COURT, J. cc: Marcus A. McKnight, 111. Esquire. Counsel for Mother Jason L. Yeingst, pro se 465 Upper Bremudian Road Gardners, PA 17324 TRUE RECORD In Test- mr... __ ?t my hand a he staff !a, Pa. Tjj.. a 1.: ,. cz, l o ..? I % TONYA S. YEINGST, Plaintiff V. JASON L. YEINGST, Defendant PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006-0579 CIVIL ACTION - LAW IN CUSTODY 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY N CUSTODY OF Kodi A. Van Meter Kayla R. Van Meter Kelli J. Yeinst Kayce J. Yeingst March 12, 1990 October 25, 1992 December 26, 1994 July 19, 1996 shared shared Father Mother 2. A Conciliation Conference was held in this matter on March 13, 2007, with the following in attendance: The Mother, Tonya S. Yeingst, with her counsel, Marcus A. McKnight, III, Esquire, and the Father, Jason L. Yeingst, prose. 3. The parties agreed to an Order in the form as attached. 3 - Date aine M. Verney, Esquire Custody Conciliator EXHIBIT "B" TONYA S. (YEINGST) GRIFFIE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JASON L. YEINGST DEFENDANT 2006-579 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, - Monday, February 07, 2011 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Monday, March 07, 2011 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. 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/ Jacqueline M. Verne 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) F B 0"? TRUE COPY FROM RECORD i`; ,, ,- In Testimony whereof, i here unto set my hand end the seal of said Cou Carlisle, Pa. Tiffs 9' day at p 20 mumnaWY c ci 4?/l VERIFICATION The foregoing Petition is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. J 4NnY 601F T W -JY- Date: February 16, 2011 r TONYA S. (YEINGST) G FFIE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-0579 CIVIL ACTION - LAW 7 r•. JASON L. YEINGST, F? Defendant : IN CUSTODY ORDER OF COURT AND NOW, this consideration of the attar follows: 1. The prior shall remain in full force parties. 2. Mother shall 3. Father shall 4. This Order is parties may modify the provi mutual consent, the terms of Conciliator within ninety dal -- rv 's} day of 4tPwA , 2011, upon p Custody Conciliation Report, it is ordered and directed as ,rs of Court dated March 19, 2007 and February 16, 2011 effect with the following modifications. primary physical custody of the children. periods of partial physical custody as agreed by the 'Intered pursuant to a Custody Conciliation Conference. The lions of this Order by mutual consent. In the absence of this Order shall control. Either party may contact the s of this Order to schedule another Conciliation Conference. BY THE COURT, 11--4 Kevin A cc: Marcus A. McKnight, I ./Jason L. Yeingst, pro se 734 Pigeon Hill Ro; Gaines, PA 16921 Esquire, A!L P.J. for Mother 3I4I1 bos CD TONYA S. (YEINGST) GI Plaintiff V. JASON L. YEINGST, Defendant PRIOR JUDGE: Kevin A. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006-0579 CIVIL ACTION - LAW : IN CUSTODY P.J. IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, th 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 CURRENTLY IN CUSTODY OF Kelli J. Yeinst December 26, 1994 Mother Kayce J. Yeingst I Tuly 19, 1996 Mother 2. A Conciliation Conference was held in this matter on March 7, 2011, with the following in attendance: The Mother, Tonya S. Yeingst, with her counsel, Marcus A. McKnight, III, Esquire. Father, although aware of the conference, did not attend. 3. The Honorable Kevin A. Hess, P.J. previously entered Orders of Court dated March 19, 2007 and February 16, 2011. The earlier Court Order provided for shared legal custody, Father having primary physical custody of Kelli and Mother having primary physical custody of K yce. The Order of Court dated February 16, 2011 provided for Mother to have p imary physical custody of both children. 4. Mother 5-7-11 Date an Order of Court in the form as attached. J7elineace:lEe M. Verney, Esquire Custody Concilia? At ' tor TONYA S.(YEINGST) GRIFFIE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. : NO.2006-0579 CIVIL ACTION-LAW JASON L.YEINGST, ;5 Defendant : IN CUSTODY rnc; `"�' -C _r ORDER OF COURT CD AND NOW,this 18th day of July, 2013, in that a conciliation conference Fins riot p been requested,the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, r' Jacq line M. Verney, Esquire, Custody anciliator