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Home My WebLink About02-2453 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 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 judgement 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 grounds 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 Cumberland County Courthouse, I Courthouse Square, 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 WEIGLE & ASSOCIATES, P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET _ SHIPPENSBURG, PA 17257-1397 ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY L. LOW, Civil Action -- Law Plaintiff v. No. 002. - 2. 4S3 BRUCE S. LOW, Defendant In Divorce COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, comes the above named Plaintiff, Amy 1. Low, by and through her attorneys, Weigle & Associates, P,C" and Richard 1. Webber, Jr" Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff, Amy 1. Low, is an adult individual presently residing at 206 South Queen Street, Shippensburg, Cumberland County, Pennsylvania 17257, since June 2000, 2, Defendant, Bruce S, Low, is an adult individual presently residing at 615 Westover Road, Shippensburg, Franklin County, Pennsylvania 17257, since February 16,2002, 3, The Plaintiff and Defendant are nationals and citizens of the United States of America, and both have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of the Complaint in Divorce, 4, The Plaintiff and Defendant were married on January 3, 1998, in Shippensburg, Pennsylvania, 5, There have been no prior actions of divorce or for annulment between the parties, 6, Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. 8. The parties have lived separate and apart since February 16,2002. WEIGLE & ASSOCIATES, p.c. - ATTORNEVS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397 # 9. The Plaintiff requests the court to enter a decree of divorce, WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony and for such other and further relief to which Plaintiff shall be entitled, WEIGLE & ASSOCIATES, P.C, By: ( ~/l'~~ Richard 1. Webber, Ir" Esqui Attorney for Plaintiff Attorney ID #49634 126 East King Street Shippensburg, PA 17257 Telephone 717-532-7388 WEIGLE & ASSOCIATES. Re. ~ ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 , VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce 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. Dated: 5-7 ~ O~ Am~ WEIGLE & ASSOCIATES, RC. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 . , ,~ " ~ ~ , ~ ~ ~ ~ ~ \ ~, o ~ "'-- -oL1:1 t:;:! L~.', "'-- ....~. ZC_, (II :t' -<""~ t2CJ ~(~~ be., >c z ~ '-'''''''''''.4>0.;''''. % ~ ~ :'.:t .-. P"' f:~ ~ ~ :~~;C? o ~.,~ CJ. ',: :+1 5; ~"? (,~ cSf 5 ,._\ ;:, :5S 'e) -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY L. LOW, CIVIL ACTION - LAW Plaintiff, v. NO. 0 J.. J. '-1..53 BRUCE S. LOW, Defendant. IN CUSTODY COMWLMNTFORCUSTODY 1. The Plaintiff is Amy 1. Low, presently residing at 206 South Queen Street, Shippensburg, Cumberland County, Pennsylvania 17257, 2, The Defendant is Bruce S, Low, presently residing at 615 Westover Road, Shippensburg, Franklin County, Pennsylvania 17257, 3. Plaintiff seeks custody of the following child: NAME Christian Scott Low PRESENT RESIDENCE 206 South Queen Street Shippensburg, Pennsylvania 17257 AGE 3 Y, years DOB 9-25-98 The child was not born outside the bonds of matrimony. The child is presently in the custody of Amy 1. Low, Plaintiff, who resides at 206 South Queen Street, Shippensburg, Pennsylvania 17257. During the past five years, the child has resided with the following persons and at the following addresses: NAME ADDRESS DATE Amy 1. Low 206 South Queen Street June 2000 to Shippensburg, P A 17257 present Amy 1. Low and 206 South Queen Street June 2000 to Bruce S, Low Shippensburg, P A 17257 February 16,2002 Amy 1. Low and 237 West King Street 9-25-98 (DOB) to Bruce S, Low Shippensburg, P A 17257 June 2000 WEIGLE & ASSOCIATES, RC. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 The mother of the child is Amy L. Low, currently residing at 206 South Queen Street, Shippensburg, Pennsylvania 17257. She is currently married to the Defendant. The father of the child is Bruce S. Low, currently residing at 615 Westover Road, Shippensburg, Pennsylvania 17257, He is presently married to the Plaintiff, 4, The relationship of Plaintiff to the child is that of mother. The Plaintiff currently resides with the following persons: NAME None RELATIONSHIP 5, The relationship of Defendant to the child is that of father, The Defendant currently resides with the following persons: NAME James Low Sarah Low Timothy Low RELATIONSHIP Father Mother Brother 6, Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth, Plaintiff does not know of a person, not a party to the proceedings, who has physical custody of the child or claims to have custody or visitation rights with respect to the child, 7, The best interest and permanent welfare of the child will be served by granting the relief requested because: A. Plaintiff has been the primary caretaker of the child since birth; and B, Plaintiff is better able to care for the needs of the child, 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action, All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: WEIGLE & ASSOCIATES, p.e. _ ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 NAME None ADDRESS BASIS OF CLAIM WHEREFORE, Plaintiff requests the Court to grant shared legal custody and primary physical custody of the minor child to the Plaintiff, subject to reasonable partial custody for Defendant.. WEIGLE & ASSOCIATES, P,C, By: 7~~'~~ Richard 1. Webber, Jr., Esquire Attorney for Plaintiff I.D.#49634 126 East King Street Shippensburg, P A 17257 Telephone 717-532-7388 WEIGLE & ASSOCIATES, RC. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257N1397 VERIFICATION I verify that the statements made in the foregoing Complaint for Custody 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, Dated: 'S~l-()l-- ~L WEIGLE & ASSOCIATES, RC. _ ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 \~ -.... ~ i\~ ~. w ~ 2 s: -oC;J !:pLl': zP~ Cf) ;.,~: r:c"'. <::" ,,' J-~ ,~c' ~C) :Pc .'/ ::::< -< ~ , , ~ \ . ~ C N ;::l: "'" _...: o 'n :.~.::! :\,\::0 r- ._,-,:,'-,., :jC) '<~C) ~L~H ~;::~o Qi-n ,...-( "" ::0 -< N C> "'" ::K '2 N lJ' AMY L. LOW IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA PLAINTIFF v, 02-2453 CIVIL ACTION LAW BRUCE S. LOW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 23, 2002 , 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 Wednesday, June 26, 2002 at 11:30 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 TIlE COURT, By: Isl Jacqueline M. Verne:y. 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 TIllS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ?:/ ~b ~~ ~ (~hC:~ . ~? ~ OHil' ~k;' et::2~l"-,9 ~ ~ ~ ~P:P~'~'/'9 e't7-fte';,9 'iINV^lASNN3d JJ.Nn08 C~,l'(IlHj8Y'lm i I :'1 l-!d "lG ^~H ZO }.,tjV1C~{,I:~/;. ; ~() jJL::L:'<)-!~..j j :~'~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY L. LOW, Plaintiff Civil Action -- Law v. No. 02-2453 Civil BRUCE S. LOW, Defendant In Divorce AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS I Patricia A. Frey, being duly sworn according to law, deposes arid says that on May 24, 2002'~' true arid attested copy of Notice to Defend and Claim Rights with Complaint in Divorce attache were served upon the DefendarIt, Bruce S. Low. Manner of service: by mailing the same postage paid certified mail, addressee only, arid return receipt requested, at Shippensburg, PennsylvarIia, addressed a~ follows: I Bruce S. Low 615 Westover Road Shippensburg, P A 17257 The return receipt signed by the DefendarIt is evidence of delivery to him arid is attached heretq as Exhibit "A." Sworn to arid subscribed before me this~day of May, 2002. ~'-" x' i l'?J" PATRICIA A. FREY - J2-k~~.a. _ t.. - T Crrf+JL Notary Public ",~,)\"~""ifrY'I"11 .'c,\~..~;. 1'0""'0, " .... -:."~.l~.... .... _'. ~"-:;.. ~~'{/':::.; "';~;\'<:;:~~\. ".:: 'u '\}~~ .,;. ; ~,: '~:'.= - '. '. .,!",:,,':':~._r ,. '" ..~.~ ' Notarial Seal Patrlcla L Tome, Notary Public ShIooensburg 8oro, Cumberland County MY Commission Expires June 7, 2004 ~. ..-'. ~'~I~S1i..:~ ASSOCIATES. p.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY L. LOW, Civil Action -- Law Plaintiff No. 02-2453 Civil v. BRUCE S. LOW, Defendant In Divorce m ::r r"'l ::r n Retum Receipt Fee C (Endorsement Required) o Reatrlcted Delivery Foe o (Endorsement Required) 0257 05 Postmark Hero m ::r m II"" $1. $0.00 o r"'l LI'I N OS/22/2002 Total Pool8ge .. Foo. . Compl8t8 1t11m11, 2, III'lCI 3. AIIIo ...0. ".,!ble Item 411 Re8trlcted Delivery Is desired, . PrInt your name and address on the reverse 10 that we can return the card to you. . Attach this card to the baCk of the mallplece, or on the front 11 space permits, 1, ArtIcle AddraHd to: 0, Is delivery ~ dIIIer8nt from Item 1? If YES. enter deI'-Y add.... below: R>ru.ce. s. Low Co I 5 ().)e~Ciu er f2J ~"'l~~en4u,,",\,P A (1)~51 2, ArtIcIe__ ~---...., PS Form 3811, ...... 2001 LW -7537 '1001- aSI 0- ca:>1- 4143- 93'13 3, SeMce 1YPe ;if" CertIfIed Mall CI ExpnI8ll Mall CI ReglstllnlCl .JiQ1leturn Recalpt for Marchandlae C1lnsul8d Mall CI C,Q,O. 4, Restricted 0eIivel'y? (eJdra Fee) eon-tIc Return Receipt ~1_ EXHIBIT "A" WEIGLE S: ASSOCIATES. Poc. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257~1397 , 8 ..,; n:1J 6:; . 1," ~~' 05':~ r''''' _~L.' ?(-, ;2;{; ....._~ :<! <::; "v :J: ::~ ~ :::....) a p f") ?~ --:',. -- .. JUL 1 1 20~ !) AMY L. LOW, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2002-2453 CIVIL TERM BRUCE S. LOW, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 11 th day of July, 2002, the Conciliator being notified that the parties have signed a Custody Stipulation in the above matter, the Conciliator hereby relinquishes jurisdiction in this matter, FOR THE COURT, ~. ~. r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMYL. LOW, CIVIL ACTION - LAW Plaintiff, v. NO. 02-2453 BRUCE S. LOW, Defendant. IN CUSTODY PETITION FOR ENTRY OF AGREEMENT AND NOW comes the Petitioner, Amy L. Low, by and through her attorneys, Weigle & Associates, P.C., and Richard L. Webber, Jr., Esquire, and files this Petition pursuant to Pa. R.C.P. No. 1915.7, averring the following: 1. Petitioner is Amy L. Low, who resides in Franklin County, at 12385 Mongul Hill Road, Shippensburg, Pennsylvania 17257. 2. Respondent is Bruce S. Low, who resides in Franklin County, at 615 Westover Road, Shippensburg, Pennsylvania 17257. 3. The Petitioner and Respondent are natural parents of Christian Scott Low, born September 25, 1998. 4. The parties entered into an Agreement regarding custody of the child. Said Agreement is attached hereto and incorporated by reference herein. 5. The best interest of the child would be served by the entry of an Order of Court reflecting the terms of the Agreement. WHEREFORE, Petitioner requests your Honorable Court to approve the attached Agreement and enter it as an Order of Court. Respectfully submitted, _..~ n....--"d ~ Richard L. Webber, Jr., Es ire Attorney for Petitioner Attorney ID #49634 126 East King Street Shippensburg, P A 17257 7127-532-7388 WEIGLE & ASSOCIATES, P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 I verify that the statements made in this Petition are true arid 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. Dated: ~ \ J-sjO& . aJ2 Amy L. Low WEIGLE & ASSOCIATES, P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397 V!NVt\lASNN3d ,UNnOO ONVll:E\8I^ln~ i'Jl:;:2 Hd IllOr20 AtN10hOrhOdd 3Hl :10 3:JH::.o-Q3l\:l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY L. LOW, CIVIL ACTION - LAW Plaintiff, v. NO. 02-2453 BRUCE S. LOW, Defendant. IN CUSTODY ORDER OF COURT NOW, this 11. d day of tillS"" , 2002, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: 1. Bruce S. Low ("Father") and Amy L. Low ("Mother") shall have shared legal custody of the child, Christian Scott Low, born September 25, 1998, hereinafter referred to as "the child," and pursuant to this grant of shared legal custody, each parent shall have equal access to all pertinent information and reports that may be generated by medical, educational, psychological and other professionals who may work with their child, Each parent shall discuss major decisions affecting the child's well being in the areas of medical, educational, emotional, spiritual, social, and material needs with the opposite parent. 2, Father shall exercise physical custody as follows: A. On weekdays that Mother works, from 2:00 P.M. to 11:30 P,M.; and B. On alternating weekends. 3. Mother shall exercise custody at all other times except as set forth in paragraph 2 above and paragraphs 4 and 6 below. 4. The parties shall cooperate in arranging for a sharing of custody on major holidays, on the parties' birthdays and on the child's birthday. 5. This Agreement is based on the assumption that Mother works the 3:00 to 11 :00 shift for four (4) weekdays per week. It is, therefore, contemplated that Father will have the child on four (4) weekdays per week, unless otherwise agreed. In the event that the workshift of either party changes, the parties agree to attempt to establish a modified weekday schedule. 6. Father and Mother shall each be entitled to one (1) week of vacation with the child as agreed by the parties. The vacation weeks shall take precedence over the normal custody schedule. WEIGLE & ASSOCIATES, P.c. _ ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 VINV/\lASNN3d AlNnU) C"'.'ilYJQ'J'n8 ^" (' III -'I L'r'H/-~' 'jU :c.. re: (, ::.J llJU At!VJ.Ci'~j';'_J' :JC 3~~'~:LYJ.~-n~ -:l~ 7. The Father and Mother agree that if a child is away overnight from the child's primary residence, the other parent will be advised as to an address and phone number where the child can be reached. Further, either parent may have reasonable telephone contact with the child when not in the calling parent's custody. 8. The parties will notify and consult with the other party immediately III cases of medical emergencies that occur while the child is in their custody. 9. Father and Mother agree to assure the child attends activities scheduled for the child during periods of partial custody, such as but not limited to school events, activities and outings, swimming and other such lessons, birthday and other parties to which the child is invited by his friends. 10. Such other exercises of partial custody may be scheduled thereafter as the parties may agree upon with due deference and respect to the child's interest, schedule and ultimate welfare. 11. Neither party shall do anything which may estrange the child from the other parent, or injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's love or respect for the other parent. By the Court, J. WEIGLE & ASSOCIATES, P.c. - ATTORNEVS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY L. LOW, CML ACTION -- LAW Plaintiff v. NO. 02-2453 CIVIL BRUCE S. LOW, Defendant IN CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND Patricia A. Frey, being duly sworn according to law, deposes and says that on August 22, 2002, a true and attested copy of Stipulation and Agreement with Order of Court dated August 12, 20002 attached were served upon the Defendant, Bruce S. Low. Manner of service: by mailing the same postage paid, certified mail, addressee only, and return receipt requested, at Shippensburg, Pennsylvania, addressed as follows: Bruce S. Low 615 Westover Road Shippensburg, P A 17257 The return receipt signed by the Defendant is evidence of delivery to him and is attached hereto as Exhibit "A." p~ A:;~ PATRICIA A. FREY' Sworn to and subscribed before me this 27th day of August, 2002. (;-Jo-htri'l1 !? . N<YttI:ry..Public (e,'Y'(J fL ~', ,:': (~ ..- --. ,.w' '_", Notarial Seal Patricia L. Tome, Notary Public Shlppensburg 8oro, Cumberland County My Commission Expires June 7, 2004 '. ,~; "/:- :~~.:~~~::S ~~~~-:,-. - .' _~:-l'\f:,..,?:.J ~,'\,~"_,,,~ ..~~~~ 'WEIGLE & ASSOCIATES. P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY L. LOW, CIVIL ACTION -- LAW Plaintiff v. NO. 02-2453 CML BRUCE S. LOW, Defendant IN CUSTODY 1lO ..J:I l"- I\J .-'l RLW Postage $ $0.83 e Low ~,,~ 0257 ::r Certified Fee 05 U"I Postmark m Return Receipt Fee He", e (Endorsement Required) $3... I e Reetricted Delivery Fee e (Endorsement Required) 08/20/2002 ~ Postage a Fee. $ $8.38 . Complete It8ms 1, 2, and 3, AIeo 1... f t item 4 if Restricted DelIvery Is desired, . Print your name and addr8es on the nlV8I'S8 so thet we can return the card to you, . Attach this card to the back of the mallplece, or on the front if space pennlts, 1. Article ~ to: 3. S4IJIIfoe lyPe ~ CertIfIed M811 [J ExprMa Mall [J RegIa\llled [J Relum ~pt for Merchandlee [J Ineured Mall [J C.O,D, 4, RIetrtcWd DelIvery? ~ Fee) 2. ArtIcle Humber (1/'8nsrer frOm IIervICflI8t*) PS Form 3811, August 2001 7. 1530 t tI/tJ /L f:j"*' ....... ....,. 2768 102595-01.!A.25Ol\ EXHIBIT A WEIGLE & ASSOCIATES. P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 (") c 0 ~ r" -q s :=- '-j ")G'; "' [;-;rc-' ;;') ..- 'T1 Z--.,. -'1~ - ~""..' Zt~ ~''t..) :-, in (j),_l_.'; I..C "):: ($;!'~" " .~ ~:~; :t., ~,~~ 'to ~?:: ~-'-, CSrn ........J -.,.. -,-1 ~ ~ >- en :0 -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY L. LOW, Civil Action -- Law Plaintiff v. No. 02-2453 Civil BRUCE S. LOW, Defendant In Divorce AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on May 20, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing 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. 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. Dated: .2 Co ~\. () <. ~)eiJ BruceS.Low,Defendant WEIGLE & ASSOCIATES. P.c. - ATTORNEVS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 (') &; :-O(i.' D)cr ~.;~~1 C/) 5" -<'.C' r-' -'-., <<::...-c:~' ~ ilfj -". ::3 , :S3 r,-" a N c:::> ("") ......, I o -II r; :::::: , ' $ --<;: , . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY L. LOW, Civil Action -- Law Plaintiff v. No. 02-2453 Civil BRUCE S. LOW, Defendant In Divorce WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) AND ~ 3301(d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of 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 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. 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. Dated: ;;2 Co 6I2f r: 02 ~S~ Bruce S. Low, Derenrnmt WEIGLE & ASSOCIATES. RC. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 0 C) 0 c: f'-.) ,1 ?: Q ,/ ffi G~ " -.., --" fT~' -4 "? ~-I ~--;1 ""-,~ I 2: c (~~} CO <, '- ;:s ,-, C -, -"-~~ .)% -(I "T, >- .Z ' ~ ~,( C:~i N 5> C.. -'[ 2: :L' -I :0 -< f,-' -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMYL. LOW, Civil Action -- Law Plaintiff v. No. 02-2453 Civil Defendant In Divorce (") Q C~. ;......1 -<:'. lJ!..~ Q:1L ~C f _c' (7, BRUCE S. LOW, .,- ).~:..: ,~.,_ *"0 WAIVER OF NOTICE OF INTENTION TO RlWUEST ENTRt~ A::'; .. DIVORCE DECREE UNDER 6 3301(c) AND 6 3301(d) OF THE DIVOi<<iE OOmE~ :;i J) :<. ...... (.n :":::::J -< 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce df:cree 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 falsification to authorities. II/;h'2 I ( Am~ Dated: WEIGLE & ASSOCIATES, P.c. - ATTORNEVS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 IN THE COURT OF COMMON PI..EAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY L. LOW, Civil Action -- Law Plaintiff v. No. 02-2453 Civil BRUCE S. LOW, 1. o K~ ~~- _.~ "'00 '~ 1'\1 " -/~. ~-' ~?~ ;,-~ ~~:~ -. --::: S~'-- "_.~ A complaint in divorce under g 3301(c) of the Divorce Code was filed on Ma:0~f}j,20Qi 77("'.:-_ .. -"7 . " The marriage of Plaintiff and Defendant is irretrievably broken and ninety da~ haf€ elapsed from the date of filing and service of the Complaint. Defendant In Divorce AFFIDAVIT OF CONSENT \ CT" 2. 3. I consent to the entry of a final decree of divorce after Sl~rvice of notice of intention to request entry of the decree. 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. g 4904 relating to unsworn falsification to authorities, /(/)/ !oz / I ~1L~. ~, Plaintiff Dated: II WEIGLE & ASSOCIATES, P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 IN THE COURT OF COMMON PJLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY L. LOW, Civil Action -- Law Plaintiff v. No. 02-2453 Civil BRUCES.LOW, Defendant In Di'Vorce 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. Grounds for divorce: irretrievable breakdown under ~ 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: May 24, 2002, by mailing postage paid, certified mail, addressee only, and return receipt requested at Shippensburg, Pennsylvania. 3. Date of execution of the affidavit of consent required by ~ 3301(c) of the Divorce Code: by Plaintiff, November 1,2002; by Defendant, September 26,2002. 4. Related claims pending: None 5. Date Plaintiffs Waiver in ~ 3301(c) Divorce was filed with the prothonotary: November 6, 2002 Date Defendant's Waiver of Notice in ~ 3301(c) Divorce was filed with the prothonotary: October 4,2002 WEIGLE & ASSOCIATES, P.C. ~~/~../~ Richard L. Webber, Jr.,~uire Attorney for Plaintiff Attorney ID #49634 126 East King Street Shippensburg, P A 17257 Telephone (717)532-7388 WEIGLE & ASSOCIATES. P.c. _ ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 0 0 C) ~ N I <""- -- '"'1:10:' 0 fTlrr ..~ Z:U Z 1-.' 0):' 1'0 -/ . ~C: -0 ~-;C.:; "'C 1') :."..> >c-=: --~ -7 -> ~- N :::"';"1 -j ~ ::<: -, - NOV 1 2 2002 '( ~~ ~w ~~ ~r:L ~,~~-~ ":~.~ ~ t, .'\..." \ '~~~ ('f) (.~. JI -eCJ- (.e. J I BRUCE S, LOW Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v, AMY L. LOW Respondent NO, 02-2453 CIVIL ACTION LAW IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER NOW COMES, the Defendant/Petitioner, BRUCE S, LOW, pursuant to 1915,1 et seq, of the Pennsylvania Rules of Civil Procedure to petition this Honorable Court to modify the order entered in the above-captioned matter on October 23, 2000, In support of this petition, Petitioner asserts the following: 1. Petitioner, BRUCE S. LOW, is an adult individual residing at 4513 Florence Avenue, Mechanicsburg, Cumberland County, Pennsylvania, 2, Respondent, AMY L. LOW, now known as, AMY L. PENSINGER, is an adult individual residing at 119 North Penn Street, Shippensburg, Franklin County, Pennsylvania, 3, The subject child of this action is CHRISTIAN SCOTT LOW, date of birth, September 25, 1998, 4, Petitioner is the minor child's natural father. 5, Respondent is the minor child's natural mother. 6, On August 12,2002, an order was entered into by agreement that vested RespondentIMother with primary physical custody of the minor child and vested Petitioner/Father with partial physical custody, 7, Since the entry of this order, circumstances have changed such that the best interests of the minor child would be served by vesting Petitioner/Father with additional time with the minor child, including summers, 8, Petitioner/Father also desires a more detailed holiday schedule now that the minor child is older. WHEREFORE, Petitioner/Father respectfully requests that this Honorable Court enter an order modifying the order entered on August 12,2002 such that Petitioner/Father would have more time with his son, Respectfully submitted: Date: 2, ;J -D~; t<\ttomey for P itioner/Father Barbara Wevodau, Esq, Supreme ID 85673 26 East Main Street P,O, Box 459 New Bloomfield, P A 17068 (717) 582-8883 VERIFICATION I verify that the statements made in the attached CUSTODY 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, Date: jJ-o~ /dAi ~.~/ BRUCE S. LOW Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v, AMY 1. LOW Respondent NO, 02-2453 CIVIL ACTION LAW IN CUSTODY CERTIFICATE OF SERVICE I, BARBARA WEVODAU, ESQUIRE, hereby certify that, on this date, a true and correct copy of the foregoing Petition for Modification was served upon AMY 1. PENSINGER, Respondent in the above-captioned matter, by mailing a copy of said Petition from the New Bloomfield Post Office via first class mail postage prepaid to the following address: Amy 1. Pensinger 119 North Penn Street Shippensburg, P A 17257 Date: 3 :J.- -os"" Barbara 1. Wevodau, Esq, Supreme Court ID # 85673 26 East Main Street P,O, Box 459 New Bloomfield, P A 17068 (717) 582-8883 AMERICANS WITH DISABILITIES ACT OF 1990 The Perry County Branch of the Court of Common Pleas for the 41st Judicial District 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 my 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, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA AMY L. LOW, CIVIL ACTION - LAW Plaintiff, v. NO. 02~2453 BRUCE S. LOW, Defendant. IN CUSTODY ORDER OF COURT , 2002, upon consideration of the within NOW, this I~+h day of Stipulation and Agreement, it is hereby ordere 1. Bruce S, Low ("Father") and Amy L. Low ("Mother") shall have shared legal custody of the child, Christian Scott Low, born September 25, 1998, hereinafter referred to as "the child," and pursuant to this grant of shared legal custody, each parent shall have equal access to all pertinent information and reports that may be generated by medical, educational, psychological and other professionals who may work with their child, Each parent shall discuss major decisions affecting the child's well being in the areas of medical, educational, emotional, spiritual, social, and material needs with the opposite parent. 2. Father shall exercise physical custody as follows: A, On weekdays that Mother works, from 2:00 P,M, to 11:30 P,M,; and B. On alternating weekends, 3. Mother shall exercise custody at all other times except as set forth in paragraph 2 above and paragraphs 4 and 6 below. 4, The parties shall cooperate in arranging for a sharing of custody on major holidays, on the parties' birthdays and on the child's birthday. 5. This Agreement is based on the assumption that Mother works the 3:00 to 11 :00 shift for four (4) weekdays per week, It is, therefore, contemplated that Father will have the child on four (4) weekdays per week. unless otherwise agreed, In the event that the workshift of either party changes. the parties agree to attempt to establish a modified weekday schedule, 6. Father and Mother shall each be entitled to one (I) week of vacation with the child as agreed by the parties. The vacation weeks shall take precedence over the nonnal custody schedule. ',- "', <;;-,- KING STRee' SH)PPC:',S,,-,L;'~ 7. The Father and Mother agree that if a child is away overnight from the child's primary residence, the other parent will be advised as to an address and phone number where the child can be reached, Further, ei!her parent may have reasonable telephone contact with the child when not in the calling parent's custody, 8. The parties will notify and consult with !he other party immediately m cases of medical emergencies that occur while the child is in their custody. 9. Father and Mother agree to assure the child attends activities scheduled for the child during periods of partial custody, such as but not limited to school events, activities and outings, swimming and other such lessons, birthday and other parties to which the child is invited by his friends, 10, Such other exercises of partial custody may be scheduled thereafter as !he parties may agree upon with due deference and respect to the child's interest, schedule and ultimate welfare, I]. Neither party shall do anything which may estrange the child from the other parent, or injurc thc opinion of thc child as to the other parent or which may hamper the free and natural development of thc child's love or respect for the other parent. By the Court, J. Ii :i , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY L. LOW, CIVIL ACTION - LAW Plaintiff, v. NO. 02-2453 Defendant. IN CUSTODY 0 c; C \'., .. !:M' ,-- n"': " ,,- I - GJ Z ?::< I ::'< .....j g: ..-:.;.. 2":: l, .. ~; C. c: z :..) ::;:I .;:- C.') Tl o.j BRUCE S. LOW, ;,--, .]':0;-/ STIPULATION AND AGREEMENT , ,:;-:::::; ,,-,M ~:~ -7') =< This Stipulation and Agreement is made this day of , 2002, by and between Amy L. Low of 12385 Mongul Hill Road, Shippensburg, Franklin County, Pennsylvania 17257, (hereinafter referred to as "Mother") and Bruce S, Low of 615 Westover Road, Shippensburg, Franklin County, Pennsylvania] 7257, (hereinafter referred to as "Father"), I. Father and Mother are the natural parents of Christian Scott Low, born September 25, 1998, hereinafter referred to as "the child", 2, The child was not born out of wedlock, 3, No prior custody action has bcen filcd with the Court, 4. None of the parties know of any person nol a party to the proceedings who has physical custody of the child, or claims to have custody or visitation rights with respect to the child, 5. Neither of the parties has participated as a party or a witness or in another capacity in other litigation concerning the custody of the child in lhis or another court, 6. Neither of the parties has information of a custody proceeding concerning the child pending in a court of this commonwealth or any other state, 7. During the last five years, the child has resided with the following persons and at the following addresses: NAME Amy L. Low ADDRESS 12385 Mongul Hill Road Shippcnsburg, Pennsylvania 17257 Franklin County DATE June 29, 2002 to present ,'uln,-,r' AMY L. LOW, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff, v. NO. 02-2453 BRUCE S. LOW, Defendant. IN CUSTODY PETITION FOR ENTRY OF AGREEMENT AND NOW comes the Petitioner, Amy L. Low, by and through her attorneys, Weigle & Associates, P,C" and Richard L. Webber, Jr., Esquire, and files this Petition pursuant to Pa. R,C.P. No, 1915.7, averring the following: I. Petitioner is Amy L. Low, who resides in Franklin County, at 12385 Mongul Hill Road, Shippensburg, Pennsylvania 17257. 2, Respondent is Bruce S, Low, who resides in Franklin County, at 615 Westover Road, Shippensburg, Pennsylvania 17257. 3, The Petitioner and Respondent are natural parents of Christian Scott Low, born Scptember 25, 1998, 4, The parties entercd into an Agreement regarding custody of the child, Said Agrcement is attached hereto and incorporated by reference herein. 5. The best interest of the child would be served by the entry of an Order of Court ref1eeting ,he tr:nns of the Agreement. WHEREFORE, Petitioner requests your Honorable Court to approve the attached Agreement and enter it as an Order of Court, Respectfully submitted, ...---J rL ~.d Richard L. Webber, Jr., Es Attorney for Petitioner Attorney ID #49634 126 East King Street Shi ppensburg, P A 17257 7127-532-7388 r verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C,S, Section 4904 relating to unsworn falsification to authorities, Dated: 1 \ ,:]-S lea. , C!I10 Amy L. Low II ',i -'f' 'AST KING STReET SHIPr""'~"':' ~ P lr( ?0 ~ I\) it- IT 0 - ~ ~ ~~r 13 f ------ rt - ...- -- PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLY ANIA BRUCE S. LOW v. 02-2453 CIVIL ACTION LAW AMY L. LOW DEFENDANT IN CUSTODY ORDER OF COlJRT AND NOW, Thursday, March 17,2005__, 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"c::,..,~herla.n~(:~IIlltyc::o...r~~o,!s,e,t::~rlisl... on __....1"!esday, April 12, 2lJll.5_ at 10:30 AM for a Pre. Hearing Custody Conterence. At such conference, an effort wil1 be made to resolve the issues in dispute; or if this cannot be accomplished, to dennc and narrow the issues to be hcard by the court, and to enter into a temporary order. All children age five or older may also be present at the eonIerence. Failure to appear at the conference Olav 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:~~cquelint?_MXemty, E"-q'----rH.~ Custody Conciliator r/ The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Oisabilites Act of 1990. For infonnation about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our oflice. All arrangements must be made at least 72 hours prior to any bearing 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 Bedti)rd Street Carlisle, Pennsylvania 170 I 3 Telephone (717) 249.3166 .~.. / cd J5yp ~. /,.;.,'7/ 147 "PI' \#,:,7<-1771 (r" .. . '. L, "'~ /~,,,,'d)l t 11"1" t ;? /1.,1.... ,/llJ oJ' e I. r' ~. ~~'rF ;J' p C 'PP~ {/." 7.' 'I - - BRUCE S. LOW, Plaintiff L\ RECEI ED APR 22 21m ; 1 : IN THE COURT OF COMMON PLEAS 0 : CUMBERLAND COUNTY, PENNSYL VA V. : NO. 2002-2453 CIVIL TERM AMY L. (LOW) PENSINGER, Defendant : CIVIL ACTION - LA W : IN CUSTODY ORDER OF COURT AND NOW, this 'Z r. day of (-tr:1 , 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated August 12,2002 is hereby vacated. 2 The Father, Bruce S. Low and the Mother, Amy L. (Low) Pensinger, sha I have shared legal custody of Christian Scott Low, born September 25, 1998. Each pare t shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. This means all medical and educational information shall be provided to both parents. 3. Mother shall have primary physical custody of the Child. 4. Father shall have the following periods of partial physical custody: A. Saturday, April 23, 2005 from 9:00 a.m. to Sunday April 24 at 7:00 p.m. B. Thereafter, alternating weekends from Friday at 5:00 p.m. to Sunday at 7:00 p.m. except that Father will skip the first weekend in May and substitute that weekend for the weekend of May 13,2005. Father's regular alternating weekends shall resume on May 20,2005. C. In the event that Father's weekend falls on Memorial Day or Labor Day weekend, Father's period of partial physical custody shall extend to Monday at 4:00 p.m. D. Such other times as the parties agree. 5. Christmas shall be divided into two blocks. Block A shall be from Christmas Eve at II :00 a.m. to Christmas Day at II :00 a.m. Block B shall be from Christmas Day at 11 :00 a.m. to December 26 at 11 :00 a.m. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. . -- RECEIVED APR 22 2005 6. Father shall have physical custody ofthe Child on Father's Day. Mother shall have physical custody of the Child on Mother's Day, both from 9:00 a.m. to 7:00 p.m. 7. The parties shall alternate the following holidays: Thanksgiving and Easter from 9:00 a.m. to 9:00 p.m. Father shall have Thanksgiving in odd numbered years and Easter in even numbered years. Mother shall have Thanksgiving in even numbered years and Easter in odd numbered years. 8. Father shall have two non-consecutive weeks in the summer of2005, provided he give Mother 30 days prior notice. In 2006 and thereafter, Father shall be entitled to three non-consecutive weeks in the summer, one each in the months of June, July and August, provided he give Mother 30 days prior notice. Summer weeks shall ru from Friday to Friday and may coincide with Father's regular alternating weekend. 10. Neither party shall do, nor permit any third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as t the other party, or may hamper the free and natural development ofthe Child's love or affection for the other party. 9. Transportation shall be shared such that the returning party shall transpo unless otherwise agreed by the parties. 11. The parties shall keep each other advised immediately relative to any emergencies, medical or otherwise, concerning the Child and shall further take any necessary steps to ensure that the health and well being of the Child is protected. Duri g such illness or medical emergency, each party shall have the right to visit the Child as often as he/she deems consistent with the proper medical care of the Child. 12. In the event that the Child is away overnight from the Child's primary residence, the other parent will be advised as to an address and telephone number wh e the Child may be contacted. Further, both parents shall have liberal telephone contac with the Child. 13. Father agrees not to hinder the Child's attendance at scheduled activiti s during his period of partial physical custody. Father may forfeit his partial physical custody if he is unable to abide by this provision. The parties shall discuss the sched ling of extracurricular activities. 14. This Order is entered pursuant to an agreement of the parties at a Cus dy Conciliation Conference. The parties may modify the provisions of this Order by m tual consent. In the absence of mutual consent, the terms of this Order shall control. - BY THE COURT, c~ara L. Wevodau, Esquire, Counsel for F ther .)HChard L. Webber, Esquire, Counsel for Mother J J. - BRUCE S. LOW, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANI V. : 2002-2453 CIVIL TERM AMY L. (LOW) PENSINGER, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Kevin A. Hess, 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 Child who is the subject ofthi litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY 0 Christian Scott Low September 25, 1998 Mother 2. A Conciliation Conference was held in this matter on April 21, 2005, ith the following individuals in attendance: Father, Bruce S. Low, with his counsel, Barb a Wevodau, Esquire and Mother, Amy L. (Low) Pensinger, with her counsel, Richard Webber, Esquire. 3. The Honorable Kevin A. Hess previously entered an Order of Court d ted August 12,2002 providing for shared legal custody, with Mother having primary physical custody and Father having custody during Mother's work hours and alternat ng weekends. 4. The parties agreed to the entry of an Order in the form as attached. 4 - J".,;z -0 6 Date