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HomeMy WebLinkAbout06-3227ROXANNE KUSER, Plaintiff VS. IN THE COURT OF CUMBERLAND CC NO. Q(o - .3.2, RICHARD KUSER, JR., : CIVIL ACTION- AT Defendant NOTICE TO DEFEND AND CL, You have been sued in court. If you wish to defer following pages, you must take prompt action. You are war may proceed without you, and a decree of divorce, or annuli court. A judgment may also be entered against you for any papers by the Plaintiff. You may lose money or prope including custody or visitation of your children. When the ground for the divorce is indignities or you may request marriage counseling. A list of marriage the Prothonotary at the Cumberland County Courthouse, IF YOU DO NOT FILE A CLAIM FOR LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE YOU MAY LOSE THE RIGHT TO CLAIM ANY OF QON PLEAS OF PENNSYLVANIA ?i urC. ?E2Yr? W- IN DIVORCE RIGHTS against the claims set forth in the that if you fail to do so, the case may be entered against you by the claim or relief requested in these or other rights important to you, breakdown of the marriage, is available in the Office of Pennsylvania. , DIVISION OF PROPERTY, ANNULMENT IS GRANTED, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD OFFICE SET FORTH BELOW TO FIND OUT WHERE CUMBERLAND COUNTY BAR A'' 32 SOUTH BEDFORD STP CARLISLE, PA 17013 (717) 249-3166 GO TO OR TELEPHONE THE CAN GET LEGAL HELP. TION ROXANNE KUSER, Plaintiff VS. RICHARD KUSER, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Q- :NO. CIVIL ACTION- AT AW- IN DIVORCE DIVORCE COMPLAIN The Plaintiff, Roxanne Kuser, by and through her attrneys, The Law Offices of Patrick F. Lauer, Jr., makes the following Complaint in Divorce: COUNT I-NO FAULT DIVORCE--§§ 301(c) or 3301(d) 1. The Plaintiff, Roxanne Kuser, is an adult individual currently residing at 177 Ashford Road, Enola, Cumberland County, Pennsylvania, 17025. 2. The Defendant, Richard Kuser, Jr., is an adult 'ndividual currently residing 247 N. Enola Road, Enola, Cumberland County, Pennsylvania 1702 . 3. The parties have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this complaint. 4. The parties were married on May 15, 1993 in ewville, Pennsylvania. 5. There have been no prior actions of divorce o for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised that counseli g is available and that the Plaintiff may have the right to request that the court require the partie to participate in counseling. 8. This action is not collusive. WHEREFORE, the Plaintiff requests this Honorable Court enter a decree of Divorce in this matter. Dater C Respectfully Shana M. Pugh, Law Offices of 2108 Market Stj Camp Hill, Pem ID# 200952 1 ick F. Lauer, Jr., LLC , Aztec Building vania 17011 (717) 763-1800 ROXANNE KUSER, Plaintiff VS. RICHARD KUSER, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION- AT LAW- IN DIVORCE VERIFICATION I verify that the statements made in this Complaint false statements herein are made subject to the penalties of 18 falsification to authorities. 6 Date: '4-.,2-o true and correct. I understand that C.S. § 4904, relating to unswomI Roxanne Kuser T'1 1T Vi M T-I *? a o `5 N 4 N -mac ROXANNE KUSER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2006-3227 CIVIL TERM RICHARD KUSER, JR., Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Defendant, Richard Kuser, Jr., by his attorneys, Irwin & McKnight, and presents the following Complaint for Custody. 1. The Defendant, Richard Kuser, Jr., is an adult individual with an address of 247 North Enola Road, Enola, Cumberland County, Pennsylvania 17025, and is the Defendant in a divorce action docketed at No. 2006-3227 Civil Term. 2. The Plaintiff, Roxanne Kuser, is an adult individual with an address of 177 Ashford Road, Enola, Cumberland County, Pennsylvania 17025, and is the Plaintiff in a divorce action docketed at No. 2006-3227 Civil Term. 3. The parties are the natural parents of two (2) children, namely, Ryan R. Kuser, born July 12, 1995, and Matthew L. Kuser, born March 9, 1998. 4. The Defendant, Richard Kuser, Jr., desires that the parties have shared legal custody of the minor children, Ryan R. Kuser and Matthew L. Kuser. 5. The Defendant, Richard Kuser, Jr., desires primary physical custody of the minor children, Ryan R. Kuser and Matthew L. Kuser, with periods of temporary physical custody to Plaintiff, Roxanne Kuser, as the parties can agree. 6. The best interests and permanent welfare of the minor child requires that the Court grant the Defendant's request as set forth above. WHEREFORE, the Defendant, Richard Kuser, Jr., respectfully requests that he be awarded primary physical custody and shared legal custody of Ryan R. Kuser and Matthew L. Kuser, as provided herein, with periods of temporary physical custody to Plaintiff, Roxanne Kuser, as provided herein. Respectfully submitted, IRWIN f Bv: Date: June 13, 2006 Ma*us A. McKnight, , Esquire Attorney for Plaintiff 60 West Pomfret Street Pennsylvania 170 -3222 (717) 249- Supreme Court I. D. No. 25476 VERIFICATION The foregoing document 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. e'9A..- -L - RICHARD KUSER Date: G- (Z- 0?, W? V/ O U? - T CIO .r. r 777 ?Ary C) T7 -- -i ROXANNE KUSER, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2006-3227 CIVIL TERM RICHARD KUSER, JR., Defendant IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE To Curtis R. Long, Prothonotary: Please enter my appearance on behalf of the defendant, RICHARD KUSER, JR., in the above captioned case. Respectfully submitted, IRWIN & eet By*Attomey l Rt, I;I, squirc ia 170 13 defen Date: June 13, 2006 ROXANNE KUSER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2006-3227 CIVIL TERM RICHARD KUSER, JR., Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached Praecipe for Entry of Appearance was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Shana M. Pugh, Esq. The Law Offices of Patrick F. Lauer, Jr., L.L.C. 2108 Market Street Camp Hill, PA 17011 IRWIN & McKNIGHT / By: Marc A. McKnight, II quire 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Date: June 13, 2006 . , ?? ^a ?? - ?? - ?r -?, -Y ?. <_ _ -? ftl ?,_ l ...? L3 i ) .=? ?f7 ? ;'} f 1 t?z tT7 J _^? -+ rv .a r.> < ROXANNE KUSER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. RICHARD KUSER, JR. DEFENDANT 06-3227 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, June 16, 2006 , 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 Thursday, July 13, 2006 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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/ Jacqueline M. Verney, Esq. PIK 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 ? y .c Orl Ol ; clr 9 0Z 5 ROXANNE KUSER, Plaintiff V. RICHARD KUSER, JR., Defendant 1L X- ,I \,7 ?:.? J JUL ' 2.006 : IN THE COURT OF COMMON PLSpOF t' : CUMBERLAND COUNTY, PENNS NO. 2006-3227 CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT k 0- AND NOW, this ? day of , 2006, upon consideration of the attached Custody Con filiation Report, it is ordered and directed as follows: 1. The Father, Richard Kuser and the Mother, Roxanne Kuser, shall have shared legal custody of Ryan R. Kuser, born July 12, 1995 and Matthew L. Kuser, born March 9, 1998. 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 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. The parents shall have shared physical custody as agreed. 3. 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. Counsel for either party may contact the Conciliator to request another conference within ninety days of the date of this Order. ccdarcus A. McKnight, III, Esquire, Counsel for Father ?b a M. Pugh, Esquire, Counsel for Mother A ? 1^ a'0 0 J. L' y 55.E P111 6V JGoz ?:?er ? ;i-IL 10 ROXANNE KUSER, Plaintiff V. RICHARD KUSER, JR., Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006-3227 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 CURRENTLY IN CUSTODY OF Ryan R. Kuser July 12, 1995 shared Matthew L. Kuser March 9, 1998 shared 2. A Conciliation Conference was held in this matter on July 13, 2006, with the following in attendance: The Father, Richard Kuser, Jr., with his counsel, Marcus A. McKnight, III, Esquire, and the Mother, Roxanne Kuser, with her counsel, Shana M. Pugh, Esquire. The parties agreed to an Order in the form as attached. -,y-o? Date 4?'? /Q, V/A? acq line M. Verney, Esquire Custody Conciliator ROXANNE KUSER, PlaintifVRespondent V. RICHARD KUSER, JR., DefendanVPetitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2006-3227 CIVIL TERM IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW comes the Petitioner, Richard Kuser, Jr., by his attorneys, Irwin & McKnight, and presents the following Petition for Modification of Custody. 1. The Petitioner, Richard Kuser, Jr., is an adult individual with an address of 247 North Enola Road, Enola, Cumberland County, Pennsylvania 17025, and is the Defendant in a divorce action docketed at No. 2006-3227 Civil Term. 2. The Respondent, Roxanne Kuser, is an adult individual with an address of 177 Ashford Road, Enola, Cumberland County, Pennsylvania 17025, and is the Plaintiff in a divorce action docketed at No. 2006-3227 Civil Term. 3. The parties are the natural parents of two (2) children, namely, Ryan R. Kuser, born July 12, 1995, and Matthew L. Kuser, born March 9, 1998. 4. The Petitioner, Richard Kuser, Jr., desires that the parties have shared legal custody of the minor children, Ryan R. Kuser and Matthew L. Kuser. A copy of the Custody Conciliator's Order of Court and Report dated July 18, 2006, is attached hereto and marked as Exhibit "A". 5. The Petitioner, Richard Kuser, Jr., desires primary physical custody of the minor children, Ryan R. Kuser and Matthew L. Kuser, with periods of temporary physical custody to Respondent, Roxanne Kuser, as the parties can agree. Since the last conciliation, the Respondent, Roxanne Kuser, has attempted to take her own life. She is consistently refusing to take custody of the minor children. 6. The best interests and permanent welfare of the minor child requires that the Court grant the Petitioner's request as set forth above. WHEREFORE, the Petitioner, Richard Kuser, Jr., respectfully requests that he be awarded primary physical custody and shared legal custody of Ryan R. Kuser and Matthew L. Kuser, as provided herein, with periods of temporary physical custody to Respondent, Roxanne Kuser, as provided herein. Respectfully submitted, IRWIN & McKNIGHT By: Ma cus AIM night, III, Esquire AttbLaay-faf Plaintiff 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Date: August 23, 2006 Supreme Court I. D. No. 25476 EXHIBIT "A" ROXANNE KUSER, : IN THE COURT OF COMMON PL iAS?OF ?,n?? Plaintiff : CUMBERLAND COUNTY, PENNS -VA1aTA `R V. : NO. 2006-3227 CIVIL ACTION - LAW RICHARD KUSER, JR., Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of , 2006, upon consideration of the attached Custody Con iliation Report, it is ordered and directed as follows: 1. The Father, Richard Kuser and the Mother, Roxanne Kuser, shall have shared legal custody of Ryan R. Kuser, born July 12, 1995 and Matthew L. Kuser, born March 9, 1998. 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 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. The parents shall have shared physical custody as agreed. 3. 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. Counsel for either party may contact the Conciliator to request another conference within ninety days of the date of this Order. B)e-THE COURT, J. cc: Marcus A. McKnight, III, Esquire, Counsel for Father Shana M. Pugh, Esquire, Counsel for Mother fft0ftAft IMPINVII 9 JUL 2 0 2006 MWIN & WKNIGHT TRUE COPY FROM REV! RD In T.,sthony whereof, ) here ur'tf r.iy hand an`he s?Jaj.?Y Qf Court at Car 's1?, Pa. ?y Th(s/....../......... day ?f .. l l ROXANNE KUSER, Plaintiff V. RICHARD KUSER, JR., Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-3227 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 CURRENTLY IN CUSTODY OF Ryan R. Kuser July 12, 1995 shared Matthew L. Kuser March 9, 1998 shared 2. A Conciliation Conference was held in this matter on July 13, 2006, with the following in attendance: The Father, Richard Kuser, Jr., with his counsel, Marcus A. McKnight, III, Esquire, and the Mother, Roxanne Kuser, with her counsel, Shana M. Pugh, Esquire, 3. The parties agreed to an Order in the form as attached. Date acq line M. Verney, Esquire Custody Conciliator VERIFICATION The foregoing document 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. RJ. ) euto RICHARD KUSER, JR. Date: 8-- zIr 0 Q? W r°q V' C ,J- N c-3 N U'S N CJi art ,.TJ ?- 4i -G ROXANNE KUSER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. RICHARD KUSER, JR. DEFENDANT 06-3227 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Wednesday, August 30, 2006 , 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, September 26, 2006 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/ Jacqueline M. Verney, Esq. i1 WI 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 V ?,V'100 ` -Nd dl Z£ -01 !4V I - QlS 9col AtNIO vG; i_C 4d ; it a0 -?rq_i,n-C311? i 2 6 2006 ROXANNE KUSER, : IN THE COURT OF COMMON PEEA?`-- -, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-3227 CIVIL ACTION - LAW RICHARD KUSER, JR., Defendant IN CUSTODY ORDER OF COURT AND NOW, this _jeday of , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated July 18, 2006 shall remain in full force and effect with the following modifications and additions. 2. Paragraph 2 shall be deleted in its entirety and replaced with the following. Father shall have primary physical custody. Mother shall have periods of partial physical custody as follows: A. Beginning October 6, 2006 alternating weekends from Friday to Sunday at times agreed by the parties. B. Everyday from after school or on days off from school until Father is home from work. C. Such other times as the parties agree. 3. Thanksgiving shall be shared such that Mother shall always have physical custody of the children from 9:00 a.m. to 3:00 p.m. and Father shall always have physical custody from 3:00 p.m. to 9:00 p.m. 4. Christmas shall be divided into two blocks. Block A shall be from 12:00 noon on Christmas Eve to 12:00 noon on Christmas Day. Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in even numbered years and Block B in odd numbered years. Father shall have Block A in odd numbered years and Block B in even numbered years. 5. Easter shall be shared such that Mother shall always have physical custody of the children from 9:00 a.m. to 3:00 p.m. and Father shall always have physical custody of the children from 3:00 p.m. to 9:00 p.m. 6. Mother shall always have physical custody of the children on Mother's Day and Father shall always have physical custody of the children on Father's Day both at times as agreed by the parties. 7. 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. J. cc*A s A. McKnight, III, Esquire, Counsel for Father ana M. Pugh, Esquire, Counsel for Mother A "l? l }I ' v. Jd ` -tr V1 3 :6 VIV R dlS 90OZ tF :f vi: -I 0-,',J' ?Hi ?O ROXANNE KUSER, Plaintiff V. RICHARD KUSER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006-3227 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. 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 CURRENTLY IN CUSTODY OF Ryan R. Kuser July 12, 1995 shared Matthew L. Kuser March 9, 1998 shared 2. A Conciliation Conference was held in this matter on September 26, 2006, with the following in attendance: The Father, Richard Kuser, Jr., with his counsel, Marcus A. McKnight, III, Esquire, and the Mother, Roxanne Kuser, with her counsel, Shana M. Pugh, Esquire. 3. The Honorable Edward E. Guido entered a prior Order of Court dated July 18, 2006 providing for shared legal custody and shared physical custody as agreed by the parties. 4. The parties agreed to an Order in the form as attached. q .a ? -b Date A - " acq eline M. Verney, Esquire Custody Conciliator ROXANNE KUSER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 06-3227 Civil Term RICHARD KUSER, JR., : CIVIL ACTION- AT LAW- IN DIVORCE Defendant NOTICE TO THE DEFENDANT IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH-IN THIS AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY (20) DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER § 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on April 14, 2006, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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 falsification to authorities. Date: -ago - 40,1 n,?n o e Roxanne Kuser, Plaintiff ("'} L ??-.> Z' =:a ?7 ?a ?'- ; , _' ? ? . . ? ? ? ,? i ' h? ,,.? ,?: < <+` ? 7 , , ? - _ G? .?' ROXANNE KUSER, Plaintiff vs. RICHARD KUSER, JR., Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION- AT LAW- IN DIVORCE AFFIDAVIT OF SERVICE I, Marlin L. Markley, Esquire, verify the Complaint in Divorce has been served upon the Defendant's Attorney, Marcus McKnight, III indicated above by first class, certified mail #7002- 2410-0002-0986-4810, return receipt requested, prepaid postage, pursuant to the requirements of Pa. R.C.P. 1930.4. r Gon*bb MM 1, 2, and & Also complete Mem 4 if Restricted Delivery Is desired. ¦ Point your name,and address on the reverse so that we can return the card to you. ¦ Attach this cans to the back of the mallpiece, or on the front if space permits. 1. Adicle Addressed Marcus IM0?x??ht? ? Pool Fret Sireet ?ixliSle, t?A i?o?3 X X Agriat C. Date of D*4wy Na "L& I M 5-5`64 D. Is delivery address dIlferent from kern 1? ? Yes if YES, enter delivery address below: ? No 01 13 Express Mail 0 Registered 0 Insured Mail ? CAD. 4. Restricted Delivery? (Extra Fee) ? Yes 2. AAkb *Avti.r ( 7002 2410 0002 0986 481 IM?riar# swr?o.rla PS Form 3811, F xU Y 2004 00"Netlc Moue, IMor 1 ?tse?sae ? Respectfully Submitted, Date: '.5 / bl Mai n L arkley, Esquire Law O ices of Patrick F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717)763-1800 r-A W: 4 { RlE 0i. __ 20101 l'?Y -4 F11 2: 53 CUiJ; ROXANNE KUSER, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2006 - 3227 CIVIL TERM RICHARD KUSER, JR., Defendant. IN DIVORCE ACCEPTANCE OF SERVICE I, RICHARD KUSER, JR., the defendant in the above-captioned divorce action, hereby verify that I accepted service of the Complaint in Divorce filed under Sections 3301(c) or 3301(d) of the Divorce Code on or about June 8, 2006. Date: May 3, 2010 RICHARD KUSER, JR. COMMONWEALTH OF PENNSYLVANIA : SS: COUNTY OF CUMBERLAND On this, the 3rd of May 2010, before me, the undersigned officer, personally appeared RICHARD KUSER, JR., known to me to be the person whose gamp is subscribed to the above instrument and acknowledge that he executed same for th? purp es erein con?ained. COMMONWEALTH OF PENNSYLVANIA Notarial seal Martha L. Noel, Notary Public Carlisle torn, Cumberland Courtly CommFasign Exphea Sepli. 18, 4-011 eNelrl tq Was