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Home My WebLink About06-0616 SHANDA REBECCA PALMER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06- & I r.. CIVIL TERM TIMOTHY LERUE PALMER Defendant CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Shanda Rebecca Palmer, hereinafter referred to as Mother. Mother is currently involved in a Protection From Abuse matter against Defendant and wishes to keep her address confidential. 2. Defendant is Timothy Lerue Palmer, hereinafter referred to Father. Father resides at 213 North College Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. Mother seeks primary physical custody ofthe minor children: Name Jedaiah Palmer Present Residence confidential Age 2/1/00 D,Q,B. -6 years old Caleb Palmer confidential 9/28/01 D.O.B, 4 years old The children, Jedaiah and Caleb were born during the parties' marriage, The children are presently in the custody of Mother. During his lifetime, J edaiah has resided with the following persons and at the following addresses: Name Address Date Shanda Palmer Timothy Palmer Timothy Palmer II Delonte Palmer (alternating weekends) 309 W, Ridge Street Carlisle, P A 17013 birth - 2/01 Shanda Palmer Timothy Palmer Timothy Palmer II Delonte Palmer (alternating weeks) 213 N, College Street Carlisle, PA 17013 2/01 - 9/01 213 N. College Street Carlisle, PA 17013 9/01 - 11/05 Shanda Palmer Timothy Palmer Timothy Palmer II Delonte Palmer (alternating weeks) Caleb Palmer Shanda Palmer Caleb Palmer Shanda Palmer Caleb Palmer confidential 11/05 - 12/05 confidential 12/05 - present During his lifetime, Caleb, has resided with the following persons and at the following addresses: Address 213 N, College Street Carlisle, P A 17013 Date birth - 11/05 Name Shanda Palmer Timothy Palmer Timothy Palmer II Delonte Palmer (alternating weeks) Jedaiah Palmer Shanda Palmer Jedaiah Palmer Shanda Palmer Jedaiah Palmer confidential 11/05 - 12/05 confidential 12/05 - present 5. Mother currently resides with the following persons: Name Jedaiah Palmer Caleb Palmer Relationship Son with Father Son with Father 6. It is believed that Father lives with the following persons: Name Timothy Palmer II Relationship Son from prior relationship Delonte Palmer (alternating weeks) Son from prior relationship 7. Mother has not participated as a party or witness, or in another capacity, in other custody litigation concerning the custody of the children in this or another court. By agreement of the parties during negotiations to resolve a Protection From Abuse matter, Mother has primary custody of both children, Father exercises periods of visitation on Sundays for an hour following church services, Additionally, up to two times per week, Father is permitted to go to ledaiah's school to eat lunch with him. 7. Mother has no information of a custody proceeding concerning the children pending in a court of this Commonwealth, 8, Mother does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 9. The best interest and permanent welfare of the children will be served by granting the relief requested for reasons including, but not limited to the following: a, Since the children were born, Mother has provided for the children's emotional, physical, educational, financial and medical needs, b. Since the children were born, Mother has been the parent primarily responsible for their daily care and has been the parent primarily responsible for dealing with school activities, medical appointments, WIC appointments and other such acti viti es, c. Mother has a stable home environment that is safe and appropriate for the daily care of the children, d. Mother has immediate and extended family in the local area and they are willing to provide assistance and support for Mother in providing for the children's needs. e, Mother is willing to communicate with and work cooperatively with Father to co- parent the children and will encourage father/child relationships with both children. 10. Father has not acted in the children's best interests in ways including but not limited to the following: a, Father is currently subject to a Temporary Protection From Abuse Order entered on December 1,2005. The Order is on behalf of Mother and both children. b. Father has demonstrated or threatened physical violence when the children have been within eyeshot or earshot, creating an unsafe and unhealthy environment for the children. c. Father has used excessive physical discipline towards the children and Mother fears that if left to care for the children on a daily basis, Father may resort to such discipline again to maintain control and order in the home, d. Despite an Order prohibiting contact unrelated to custody issues, Father continues to contact Mother to discuss their relationship and pressure her to reconcile. Moreover, Father uses the oldest son to send unwanted and prohibited letters to Mother, 12, Every person with rights to custody or having actual physical custody of the children has been named as parties to this action, WHEREFORE, Mother requests this Court to grant her the following relief: 1. Mother and Father shall share legal custody of the children. 2. Mother shall have primary physical custody of the children. 3, Father shall have periods of partial custody as follows: a, Alternating weekends from Friday evening until Sunday evening. b. One evening per week from 4:00 p.m. until 9:00 p.m. 4. The non-custodial parent shall have reasonable telephone contact with the children while they are with the other parent. 5. Establish an appropriate holiday schedule so that both parents can spend time with the children during various holidays. 6. Any other reliefthis Court finds just and equitable, /// c-/ Jes ca olst, Esquire Mi enn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 VERIFICATION The above-named PLAINTIFF, shanda palmer, verifies that the statements made in the above complaint For custody are true and correct. plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904, relating to unsworn falsification to authorities. Date: 1-d,~-iJlo lhc\'~ 'foln'V!.? shanda Palmer SHANDA REBECCA PALMER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06- CNIL TERM T~OTHYLERUEPALMER Defendant CUSTODY AFFIDAVIT OF SERVICE BY MAIL I, Jessica Holst, do hereby swear that I served counsel for Timothy Lerue Palmer, Nathan / Wolf, Esquire, with a Complaint For Custody On;1!J1/I(U? 3/ ,2006 by mail to the person and address below: J Nathan Wolf, Esquire 37 South Hanover Street - Suite 201 Carlisle, Pennsylvania 17013 I, Jessica Holst, verify that the statements made in this Affidavit of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C.S. Section 4904 relating to unsworn falsification to authorities. l Date: / ,1) 1(11(/1<1</ J/ ~UD{{7 / / ' Signature: / / <. / / , i J / (:-) ,.., ~--'."J ;,~::.. CJ.... c_ o .,.., ...., ~"T1 li-rp CQ ", ('J -; .'.~f~ , ) :-1 ~t1 -<. ."-,"" ~ (....) ~.~ -~ r,') C. c SHANDA REBECCA PALMER Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06- {../ fa CIVIL TERM TIMOTHY LERUE PALMER Defendant CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Shanda Rebecca Palmer, Plaintiff, to proceed in forma pauperis. I, Jessica Holst, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. 1 / /, r"T/' //' .,.,./1 - 'Je~cairolst, Esquire MldPenn Legal Services 40 I East Louther Street Carlisle, PA 17013 (717) 243-9400 o c:;: ,-, <= c::., ~.J"'" o " --, :T::n nlr- -ryCr. ":,10 {j,J., ..1-.......- f:~.-. "~~O ;.c".m "') ;;;;! ~~ '- :c- ~ 0.) ~ '-0 G' SHANDA REBECCA PALMER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 06-616 CIVIL ACTION LAW TIMOTHY LERUE PALMER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, Februaryll,2..-..2I!.Il.L_,______, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberlaud Couuty Courtbouse, Carlisle 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/ Hybe1't X Gilrov. Esq. Custody Conciliator --tfL 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 omee. 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 HA VE 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'/-9 ';fTy' . ~ .?~ C ~, ~_ . /v' <::. ( ~(77k?/ ;? /7tl:17W o/~ 90 r r . 5;X t, /fFml/ #~.p?J '7/" r (" v';\"r1r'ltCI'il"--' . ! I ~\ In':~~ ;,' '~,~' ,'';'i' ':i.:Jrj """ " " . ,-".~", .__ ',', .', - \'-"i~i )...) 10 :21 ~J,d s- 81:1 900l Il-i'~'1 IV"" . ,. , , ~ r,~'i_~,-,)...J"'i-,I"';"""I :..:.\\__1\ JO ,;'~<i : .~:- ""_.:'. ...I. .J.. -l :l.,,:"J-Ci:.il:~ SHANDA REBECCA PALMER Plaintiff : IN THE COURT OF COMMON PLEAS OF v. : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06- (p I ~ CIVIL TERM TIMOTHY LERUE PALMER Defendant : CUSTODY ACCEPTANCE OF SERVICE I accept service of the Complaint for Custody. I certify that I am authorized to accept service on behalf of defendant. /-P ;;;rp~ Date .! ~T/../ <' () , /?t'I//W>'-)T.) t~I'/' L. OJ Mail ng Address ,r '" /I; I"; c /).r I, , ,> (,.,Nt<. , . , , /'<"/1/)) r'-"" r::;. C'J k';"-" C) ~n ::;1 rl-;--'-; 'r"= ::;::;:7--1, :.:':,'(' ~<, (-" ...,., ~'.i CC? , co ,c." , ~: /< "''len ~,~~ ;:~~ c,,) \D , '\ C rf.. APE? 0 4 20('6 t' SHANDA REBECCA PALMER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 06-616 CIVIL TERM TIMOTHY LERUE PALMER, Defendant CUSTODY CUSTODY AGREEMENT AND ORDER AND NOW, this .Mbday of ~ ,2006, the following Order is entered by consent of the parties with regard to custody of the minor children: Jedaiah Palmer, born February I, 2000, and Caleb Palmer, barn September 28,2001. I. Shanda Palmer, hereinafter referred to as Mather, and Timothy Palmer, hereinafter referred to as Father, shall share legal custody of the children. Each parent shall have an equal right, to be exercised jointly with the ather 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. Each parent shall be entitled to all records and information pertaining to the children, including, but not limited to, medical, dental, religious or schaal records. 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 ather parent within such reasonable time as to make the records and information of reasonable use to the ather parent. 2. Mather shall have primary physical custody ofthe children. 3. Father shall have periods of partial custody according to the following schedule: . a. On alternating weekends from Monday evening until Wednesday evening. Father's custodial period with Jedaiah will begin on Monday afternoon after school between 2:30 pm. and 3:00 p.m. Father's custodial period with Caleb will begin on Monday between 9:30 a.m. and 10:00 a.m. b. Every Saturday from 8:30 a.m. until 2:00 p.m. c. At other such times as the parties may agree. 4. For the custodial periods on alternating Mondays through Wednesdays, Father shall pick- up Jedaiah after school and Mother will drop off Caleb to Father. On Wednesday, Mother will pick up the children from Father's home. On Saturday, Mother shall provide all transportation for the children. 5. The parties shall alternate the following holidays: New Year's Day, Memorial Day, Independence Day and Labor Day. Father shall have New Year's Day and Independence Day in even years Mother shall have them in odd years. Mother shall have Memorial Day and Labor Day in even years and Father shall have them in odd years. 6. Mother shall have custody ofthe children on Mother's Day from 9:00 a.m. until 5:00 p.m. Father shall have custody of the children on Father's Day from 9:00 a.m. until 5:00 p.m. 7. The parties shall share the following holidays: Easter and Thanksgiving. Father shall have the children from 9:00 a.m. until 3:00 p.m. on those holidays. Mother shall have the children from 3:00 p.m. until 9:00 p.m. on those holidays. 8. The Christmas holiday shall be divided into two segments, Segment One being from December 24 at noon until December 25 at noon, and Segment Two being from December 25 at noon until December 26 at noon. The parties shall alternate custody with the minor children on the two segments of Christmas, with Mother having the first segment and Father having the second segment in 2006. 9. Father shall have reasonable contact with the children by telephone, written correspondence or email. In deference to the existing Protection From Abuse Order, entered on February 6, 2006, Father shall not have any contact with Mother except as it pertains to matters regarding custody of the children. Telephone contact regarding custody is appropriate between the hours of9:00 a.m. and 8:00 p.m. 10. Mother and Father agree that each shall notify the other immediately of medical emergencies that arise while the children are in that parent's care. I I. Neither party shall do anything which may estrange the children from the other parent, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love or respect for the other parent. Both parties shall provide the children with a "safety zone" by discouraging third parties from making negative remarks about either parent when the children are within earshot. 12. The parties may modify the schedule in the event they reach an agreement between themselves. Absent an agreement, the custody schedule set forth above shall control. L B , ' -" ")"" r-:-: ,. < , c-.' C) . . This Order is entered pursuant to the consent of the parties: ~~zbvk 12j)QUlIllL- Shand a Rebecca Palmer, Plaintiff v Jessie I, squire MidP nn Legal Services 401 ast Louther Street Carlisle, PA 17013 (717) 243-9400 "\ MR li 7 2005 SHANDA REBECCA PALMER, Plaintiff il3Y .~-,-s: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v : NO.06-616 CIVIL ACTION - LAW TIMOTHY LERUE PALMER, Defendant IN CUSTODY ORDER t-" AND NOW, this 'I day of April, 2006, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. -ll " r-, SHANDA REBECCA PALMER, Plaintiff vs. TIMOTHY LERUE PALMER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA c? c No. 06 - 616 Civil Term rnW CIVIL ACTION - LAWr IN CUSTODY r N a? NOTICE OF PROPOSED RELOCATION r ro AND NOW, this \qT_ day of July 2011, comes Plaintiff, Shanda Rebecca Palmer, now known as Shanda Leer, by and through her attorney, Jane Adams, Esquire, and provides notice of her proposed relocation to Defendant, Timothy Lerue Palmer, under 23 Pa.C.S. §5337 of the Domestic Relations Code. 1. Address of intended new residence: 1525 Oakadia Drive East, Clearwater, Florida, 33764. 2. Mailing address of intended new residence: Same. 3. Names and ages of individuals in the new residence, including individuals who intend to live in the new residence: Shanda Leer, Craig Keckler, Elisha Leer, Caleb Palmer, Jedaiah Palmer. 4. The home telephone number of the intended new residence if available Unavailable at this time; contact number is cell phone, (717) 440-3387. 5. The name of the new school district and school: Oak Grove Middle School and Plum Elementary School, Pinellas County School District. 6. The date of the proposed relocation: August 15, 2011. 7. The reasons for the proposed relocation: Lifestyle choice. 8. The proposal for a revised custody schedule. Mother to have primary custody, with Father to have block of time over summer and holidays. _F mF rCD (-) 9. Any other information deemed appropriate. None. I verify that the statements made in this Notice are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. '-?L4X46' &M- Shanda Leer, Plaintiff Respectfully submitted, Date: °7 -W y ^ 0t11 l'"?? LAXATfer a e Adams, Esquire I. No.79465 1 West South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF SHANDA REBECCA PALMER, Plaintiff vs. TIMOTHY LERUE PALMER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 06 - 616 Civil Term CIVIL ACTION - LAW IN CUSTODY COUNTER-AFFIDAVIT REGARDING RELOCATION NOTICE: If you do not file with the court an objection to the proposed relocation within thirty (30) days after receipt of this notice, you will be foreclosed from objecting to the relocation. This proposal of relocation involves the following child: Name Act- ee Date of Birth Address Jedaiah Palmer 11 2/1/00 26 Water Road. Dillsburg, Pa. 17019 Caleb Palmer 9 9/28/11 26 Water Road Dillsburg, Pa. 17019 I have received notice of the proposed relocation and: 1 1. 1 do not object to the relocation and I do not object to the modification of the custody order consistent with the proposal for the revised custody schedule as attached to the notice. _ 2. 1 do not object to the relocation, but I do object to modification of the custody order, and I request that a hearing be scheduled. a. prior to allowing the children to relocate. b. after the child relocates. _ 3. 1 do object to the relocation and I do object to the modification of the custody order, and I further request that a hearing be held on both matters prior to the relocation taking place. I understand that in addition to checking (2) or (3) above, I must also file this notice with the court in writing and serve it on the other party by certified mail, return receipt requested. If I fail to do so within thirty (30) days, of my receipt of the proposed relocation notice, I shall be foreclosed from objecting to the relocation. VERIFICATION REGARDING RELOCATION COUNTER-AFFIDAVIT I verify that the statements made in this Counter-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 falsification to authorities. LL--- ?-A? Timothy L ue Imer, Defendant Date: 7- )y- @01 SHANDA REBECCA PALMER, IN THE COURT OF COMMON PLEAS r, c Plaintiff CUMBERLAND COUNTY, PENNSYLVANKk _- vs. mcr; :_ M No. 06 - 616 Civil Term ;?M:21 r M r' '"Urn co c? (D ' TIMOTHY LERUE PALMER, n:: CIVIL ACTION - LAW - C2 Defendant IN CUSTODY- C)-r9 r.a <? 1 ORDER OF COURT AND NOW, this a' Day of , 2011, the following Order is entered by consent of the parties with regard to the custody of their minor children: Jedaiah Palmer, born February 1, 2000, and Caleb Palmer, born September 28, 2011. 1. Legal Custody. Shanda Palmer, now known as Shanda Leer, hereinafter referred to as Mother, and Timothy Palmer, hereinafter referred to as Father, shall share legal custody of the children. 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. 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. To the extent that 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. In event of a medical or other emergency, the parent then having physical custody of the child shall make any decisions, and then shall notify the other parent as soon as practicable after the emergency is handled. 2. Physical Custody. Mother shall have primary physical custody of the children. Father shall have periods of partial physical custody of the children as follows: a. Father shall have a block of time with the children over the summer, to commence approximately one week after school ends and to end approximately two weeks before school begins in the fall. b. Father shall have a block of time with the children over Thanksgiving, and/or Christmas, and during the children's Easter break, as the children's school vacation schedule allows. c. Other times as the parties agree. d. The parties shall share transportation. 3. Reasonable Contact. Each party shall have reasonable telephone contact with the children when in the physical custody of the other party, by telephone, written correspondence, e-mail or Skype. Reasonable contact means contact approximately once every one to two days. 4. Relocation. Mother has notified Father that she intends on relocating to Florida, pursuant to the requirements in 23 Pa. C.S.A. 5537c. By signing this stipulation, Father specifically indicates that he consents to Mother's proposed relocation. SL-? TP i 5. Disparaging Remarks. Neither party shall do anything which may estrange the children from the other parent, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love or respect for the other parent. Both parties shall provide the children with a "safety zone" by discouraging third parties from making negative remarks about either parent when the children are within earshot. 6. Mutual Consent to Modification. The parties may modify the schedule contained in this stipulation and Order in the event that they reach an agreement between themselves. Absent an agreement, the custody schedule set forth above shall control. 8. Governing Law. This Agreement shall be governed and controlled by the laws of Pennsylvania. SL'-T TP This Order is entered pursuant to the consent of the parties: WITNESS: Wi ess Date: 7-/q-000 ?"" -?'. "4) 4i?" ?/ 7 Hess I j"tX"(dA - Shanda Leer, Mother f/k/a Shanda Palmer r Timothy L. Palmer: Father Date: `?-?y- a01( SO ORDERED THIS 7 DAY OF cc: T mothy Palmer, Defendant Jane Adams, Esquire, for Plaintiff t Es ry, ? ? 7 28?r? BY THE COURT: , 2011. J. -:5Z- SL C TP i NATHAN C.WOLF,ESQUIRE ip �� F� f tj�'r• ATTORNEY ID NO.87380 j 4 10 WEST HIGH ET CARLISLE PA 1013 �7 241-4436 FOR DEFENDANT U ! J_(� ATTORNEY f SHANDA LEER (F/K/A : IN THE COURT OF COMMON PLEA P��/, ' �t' SHANDA PALMER) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION- LAW TIMOTHY L. PALMER : NO. 2006—0616 CIVIL TERM Defendant : IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW comes the Defendant, Timothy L. Palmer, by and through his attorney, Nathan C. Wolf, Esquire, and files this petition for modification of custody, respectfully representing as follows: 1. The plaintiff is Shanda Leer, formerly known as Shanda Palmer, an adult individual residing at 6 North Chestnut Street, Dillsburg,York County,Pennsylvania 17019. 2. The defendant is Timothy L. Palmer, an adult individual residing at 130 Meals Drive, Carlisle, Cumberland County,Pennsylvania 17013. 3. The plaintiff and defendant are the natural parents of two minor children,namely. Jedaiah Palmer,born February 1,2000 and Caleb Palmer born September 28, 2011. 4. The children are presently the subject of an Order for Custody issued July 27`h, 2011 by the Honorable Edward E. Guido which was the result of Mother's request to relocate with the children to Florida which request was consented to by Father. A true and correct copy of the order of which modification is sought is attached hereto as Exhibit"A." 5. On or about January 11,2013,Mother returned from Florida and moved with the children to Dillsburg,Pennsylvania. 6. Father wishes to modify custody to expand the periods of partial physical custody that he has with the children now that they are back in the Commonwealth of Pennsylvania and to ensure that there is a clearly-defined schedule maximizing Father's time with the children. 7. The children have expressed a desire to have additional time with Father which Father desires cannot accommodate of due to Mother's unwillingness to modify the Order. 8. The best interest and permanent welfare of the children will be served by granting the relief requested because it will avoid any unmet expectations by either party and because it will ensure the children are able to have the maximum amount of time to spend with Father. 9. The best interests and permanent welfare of the children would be served by this Court issuing an Order modifying the Order of Court of July 27, 2011. WHEREFORE, Defendant Timothy L. Palmer., prays this Honorable Court modifying the Order of Court as requested herein along with any additional relief as the Court deems appropriate. Respectfully submitted, WOLF &WOLF ttorneys at Law Dated: May 2013 BY: Ke, 7SO13 olf, Esquire 10 W treet Carli Supreme Court I.D. No. 87380 (717) 241-4436 Attorney for Defendant This Order is entered pursuant to the consent of the parties: WITNESS: W' ess Shanda Leer, Mother f/k/a Shanda Palmer Date: 7— r ness Timothy Oalmer, ather Date: `�-►y-aO1 I 7 � SO ORDERED THIS DAY OF , 2011. BY THE COURT: J. cc: Timothy Palmer, Defendant Adams,.Esquire, for Plaintiff SL T (� P 7 �8�rr NATHAN C.WOLF,ESQUIRE ATTORNEY ID NO.87380 10 WEST HIGH STREET CARLISLE PA 17013 (717)241-4436 ATTORNEY FOR DEFENDANT SHANDA LEER (F/K/A : IN THE COURT OF COMMON PLEAS OF SHANDA PALMER) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION-LAW TIMOTHY L. PALMER : NO. 2006—0616 CIVIL TERM Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Nathan C. Wolf, Esquire, attorney for Defendant, do hereby certify that I have served a copy of the foregoing Petition for Modification of Custody upon the following individual by postage prepaid mail, addressed as follows: Jane E.Adams,Esquire 17 West South Street Carlisle,PA 17013 (Counsel of Record for Plaintiff) Respectfully submitted, an C.Wo quire Attorney De de Date: May�, 2013 SHANDA LEER F/K/A SHANDA PALMER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY,PENNSY.LVANI.A V. 2006-616 CIVIL ACTION LAW -cs� Z3 rrl GO ;�t m � Fri TIMOTHY L. PALMER . IN CUSTODY r— DEFENDANT CZ)-,I -a- } ORDER OF COURT ' AND NOW, Tuesday,May 14,2013 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before _Hubert X.Gilroy,Esq. , the conciliator, at 4th Floor,Cumberland County Courthouse,Carlisle on Friday,June 07,2013 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/ Hubert X. Gilroy, Esq.,,/ Custody Conciliator lu 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 Cap �� 32 South Bedford Street b ES f7ZAt 6.�-V Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 tj A41 14 . at