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LON C. SHREVE,
Plaintiff
IN rHE COURT OF COMMON PLEAS
: CUMBERLAND COUNry, PENNSYLVANIA
CIVIL AcrlON - CUSrODY
v.
JUDlrH LYNN SHREVE,
Defendant
NO. ~5.3318
PRE-TRIAL MEMORANDUM OF DEFENDANT. JUDITH L. SHREVE
I. STATEMENTOFPOSlrION:
Defendant is the natural Mother of the minor children. Angela N. Shreve (born April 10,
1985) and Stephanie D. Shreve (born March 24, 1986). Defendant contests transfer of primary
custody from her custody to that of the Father. Defendant feels the best interest of the children
will be preserved by maintaining the status quo. rhe children have lived with their Mother since
their birth. rhey have friends, extended family and other strong ties to this area. Mother is able
to foster a good relationship between them and their Father. rhe children are enrolled in
Cumberland Valley School District, an excellent school district known for its academics as well as
extracurricular activities. Both ehildren are doing well in this academic environment and
participate in school related activities. Mother does not believe that Father's environment is
stable. Father has numerous teenagers. especially boys, who are either adopted or foster children.
rhe environment, while it might be attraetive to the teenage girls, is not significantly better than
Mother can provide. Mother indicates that since improvement in her employment and her new
position as a realtor, she is better able to care for the children's needs. Mother also is more willing
to allow the children flexibility in determining church attendance in the Harrisburg area as a social
basis for the children, which church activities they had been participating in at their Father's.
. .
'.
II. L1sr OF WlrNESSES:
1) Defendant- Ms. Shreve will testifY as to the history of the custody relationship;
personal background; living arrangements of the children and her
relationship with them; their school involvements and academics;
her concerns about the ehildren living with their Father and
concerns about his household composition. Defendant will testifY
that she does not feel that the move would be in the best interest of
the children at this phase of their life. She will also testifY that she
does not believe the children are currently motivated for the move.
2) Ann Farrell. Maternal Grandmother. Mrs. Farrell will testifY as to the home
environment of the children, the Defendant's relationship with
them, her own relationship to them. She will also advise of her
view on the inappropriateness of uprooting the children at this time
in their lives.
3) Kelly Umstead- Niece ofthe Defendant - She will testifY as to her relationship with
the girls, their home environment with their Mother, the girls'
relationship with their Mother.
4) Julie Roller- Friend - Ms. Roller will confirm the parenting of the Defendant, as
well as the relationship of the Defendant and the children.
5) Lon Shreve- As of Cross.
III. CONCLUSION:
Defendant requests that no ehange in primary eustody of the children occur.
Dated: April 17, 2000
Barbara Sumple-Sullivan, Esquire
Attorney for Defendant
549 Bridge Street
New Cumberland, P A 17070-1931
(717) 774-1445
Supreme Court I.D. No. 32317
2
LON C. SHREVE,
Plaintiff
IN rHE COURr OF COMMON PLEAS
: CUMBERLAND COUNry, PENNSYLVANIA
: CIVIL AcrION - CUSTODY
v.
JUDIrH LYNN SHREVE,
Defendant
: NO. 95-3318
CERTIFICATE OF SERVICE
I, DARBARA SUMPLE-SULLIV AN, ESQUIRE, do hereby certilY that on this date, I
served a true and correct copy ofthe Pre-Trial Memorandum of Defendant, Judith L. Shreve,
in the above-captioned matter upon the following individual(s), by United States First Class mail
as follows:
James D. Flower, Jr., Esquire
Flower, Flower & Lindsay
11 East High Street
Carlisle, PA 17013-3016
DATE: April 17,2000
arbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, P A 17070-1931
(717) 774-1445
Supreme Court I.D. 32317
Attorney for Defendant
~'1: ~
APR 1 8 ZOllO f1?
'"
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-3318 CIVIL TERM
CIVIL ACTION
IN CUSTODY
LON C. SHREVE,
Plaintiff,
JUDITH LYNN SHREVE,
Defendant.
fREHEARlNG M.EMORANDUM
PLAINTIFF FATHER'S POSITION
This case involves a Custody Petition for Angela N. Shreve, born April 10, 1985,
now fifteen years old, and Stephanie D. Shreve, born March 24, 1986. currently fourteen years
old. The chlldren's father, Lon C. Shreve, has requested primary physical custody of his two
daughters In response to their repeated requests to him over a period of several years that he
do so. Although the children clearly love both of their parents, in their mother's household they
experience Instability, Inconsistency, and lack of medical, dental and eye care attention. She
was casual about getting them clothes and shoes. Their mother tended not to be sensitive to
their desires to be involved in extra-curricular activities and to want to be transported to and
from those activities. In 1996 their mother failed to properly supervise them with a paramour.
who sexually abused both children.
The chlldren's father's early history reflects prior instability and a difficult
upbringing. In most recent years, it reflects a strong stable marriage between Plaintiff Lon C.
Shreve and his wife, Dixie L. Shreve. He has strong religious orientation, and a great interest
in children, including foster care experience and, over the last few years, the adoption of
several teenage boys, the most recent of which was the adoption of Daniel E. Gregor, II, the
hearing concerning which occurred before the Honorable Kevin A. Hess. on April 17, 2000. In
contrast to their mother's home, their father and his wife have helped them catch up on eye
care and dental needs (which were serious as illustrated by numerous cavities that each girl
had) and have provided them with a loving, stable environment. The children both enjoy their
father's church and the rural environment in Perry County. They appreciate the fact that their
father and his wife do not drink, use drugs or smoke.
At the conciliation conference in September of 1999, the parties agreed that
counsel would meet with the children (Defendant was at that time represented by Joan Carey.
Esquire, of Legal Services) to discuss their preferences in an attempt to resolve this matter. At
that hearing, the girls quietly but consistently expressed their preference to live with their
father. We believe that the preferences of these two girls. age fifteen and fourteen, are very
important in this proceeding. The girls certainly do not want to hurt their mother's feeling, but
we submit that their preference has been consistent over an extended period of time, and we
would ask the Court to set aside ample time for an in depth conversation with them.
WITNESSES
1. Plaintiff Lon C. Shreve and his wife, Dixie L. Shreve: Plaintiff and his wife
will testify as to the history of the custody relationship, their personal backgrounds, the
relationship they presently have with the children and with the adoptive children in their home,
the home environment and activities, the concems the children have expressed to them about
their mother, and the motivation for pursuing this change of custody.
~
2. Teresa Lanza: Teresa Is the Adoption Coordinator for Common Sense
Adoption Services, an adoption agency Involved in the recent adoption of Daniel E. Gregor. II
by the Shreves. She can authenticate the Adoptive Family Profile and Adoptive Home
Supervisory Reports which, In detail, discuss the family situation of the Shreves and can
respond to questions concerning the home study.
3. Plaintiff may also call the following witnesses:
a. April Manley, the sister of Dixie L. Shreve, who can discuss the
ability and desire of her sister and brother-In.law to parent children.
b. Mildred Hostler, Dixie L. Shreve's mother, who can testify
concerning how the Shreves have dealt with some very difficult foster children, and the
changes that have occurred in those foster children in their care.
c. Robin Kepner, head of the nursery ministry at the Shreves' church,
who has worked with Lon and Dixie in the nursery and can discuss their interaction with
children.
d. Victoria Parson, friend of the Shreves, who can also testify to the
interaction of the Shreves with children and their method of discipline.
e. Pastor Frank Nemeth, Jr., the youth pastor of the Shreves' church,
who will testify concerning the youth group and the Shreve family's interaction with it.
EXHIBITS
Plaintiff identifies the following exhibits, but reserves the right to Identify
additional exhibits prior to hearing:
1. Child Protective Services Investigation report concerning sexual abuse of
Stephanie D. Shreve by Lonnie J. McRorey, dated March 1, 1996.
2. Child Protective Services Investigation report concerning sexual abuse of
Angela N. Shreve, by Lonnie J. McRorey, dated March 1, 1996.
3. Adoptive Family Profile of Common Sense Adoption Services dated
August 25, 1999, Adoptive Home Supervisory Report of Common Sense Adoption Services
dated September 28. 1999, Adoptive Home Supervisory Report of Common Sense Adoption
Services dated November 19, 1999, and Adoptive Home Supervisory Report of Common
Sense Adoption Services dated January 20, 2000.
4. Dental records of the girls, If available.
Respectfully submitted,
FLOWER, FLOWER & LINDSAY
Attomeys for Plaintiff
James D. F r, Jr.
11 East High Street
Carlisle, PA 17013
(717) 243-5513
1.0. #27742
.__-'. - I., _, _. _ _,..!:T,.~ -=-'~_',".; . TO .~~.,", .~ _",: ~ -'.!.'~"-"'" '-r _ ~~_"" ~'.:
LON C. SHREVE,
Plaintitl'
IN rHE COURr OF COMMON PLEAS
: CUMBERLAND COUNTY. PENNSYLVANIA
v.
Civil Action - Custody
JUDlrH LYNN SHREVE,
Defendant
NO. 95-3318
PRAECIPE TO WITHDRAW APPEARANCE
Please withdraw my appearance on behalf of Judith Lynn Shreve in the above-captioned
matter. .
Dated:
matter.
Dated:
Respectfully submitted.
(l ~
~, Esquire
Legal Services. Inc.
8 Irvine Rowe
Carlisle, PA 17013
(717) 243-9400
PRAECIPE TO ENTER APPEARANCE
Please enter my appearance on behalf of Judith Lynn Shreve in the above-captioned
Barbara Sumple-Sullivan, Esqu
Attorney for Defendant
549 Bridge Street
New Cumberland. P A 17070-1931
(717) 774-1445
Supreme Court I.D. No. 32317
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, BARBARA SUMPLE-SULLIVAN
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ADORESS C1nclud. Str.lt. Cllf. St.t.. Zip Cod.)
COUNTY
BIRTHOATE
.... I DD
rt
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PLAINTIFF'S
EXHIBIT
,(~
O Chock. this block If . . ct'u. ,
CHILD PROTECTIVE SERVICE INVESTIGATION REPORT for studont .bulo
(TIUe 23 Pe. C.S.A. Chapter 631 l!J Chock this block to' child abuso
INSTRUCTIONS: S.nd ani copy of thl. campllt.d form to ChlldLln. . Abu.. RI.I.t,y. D.p.rlmlnt of Public W.II.r., L.l'lco Lad".. 3rd fir,. P.O. BolC 2G75
H.nl.bur" PA 17105 wUhln ~O dlY' of the "Cllpt of '1'1 ani "part of lu.p.et.d .bU.I, Pl.... typ. or Pflnt, U.. on. form p.r Incld.nl,
j't~S':;~, ~}
A. DATE OF INCIDENT
REGISTER NUMBER
21-04147
n I .
Shreve An ela
ADDRESS (lnclud. suut. City. Stat.. Zip Codl'
115 S. Wash!n ton Street Mechanicsbur
PA 17055
Cumberland
206-70-6268
"
65
.It. fit.
. n I'
Shreve Judith
ADORESS Il'lclud. Su..'. C Iy. Stlt., Zip Codl
184-52-6413
COUNTY
115 S. Washin ton Street Mechanicsbur
0, BIOLOGICAL/ADOPTlVE FATHER (L'lt, Flnl. Middle tnlll.1t
Shreve Lon C.
ADDRESS Include Su..,. C ty. Stlt., Zip Code
PA 17055
Cumberland
SOCIAL SECURITY NO.
164-54-5720
COUNTY
60
1112 State Road Duncannon PA 17020
t Ir t In u c
Perr
"Iney
SOCIAL SECURITY NO.
RPE
L E .It. lit.
den t.
"
72
McRore Lonnie J.
ADOPESS Includ. Str.". City. St.t.. Zip Cod.
CUTberland Count Prison 1101 Clararont Rd. Carlisle PA 17013 Cumberl and
G. FAMILY HOUSEHOLD COMPOSITION (DO NOT COMPLETE FOR STUDENT ABUSE)
I NAME (Las~ FI..~ Inltl.O RELATIONSHIP TO VICTIM NAME (Las~ FI..~ InlUaO
Shreve Ste hanie Sister
RELATIONSHIP TO VICTIM
A. TYPE OF ABUSE/NEGLECT
1. Physlc'l InJu'los
o I Burns/Scalding 08
02 Fractures 07
03 Skull Fractures 08
04 Subdural HematorN 09
05 Bruises 10
< -:: '~~';~ :~>';~':::; ,:~ '- .::
Welts/Ecchymosis
Lacerations/Abrasions
Punctures/Bites
Brain Damage
Poisoning
11 Asphyxiation/Suffocation
12 Internal Injuries/Hemorrhage
13 Dismemberment
1. Sprains/Dislocations
15 D,ugs/Alcohol
c:!!J Drowning
l.!:J Othor
02. Mental InJu'les 100 NOT COMPLETE FOR STUDENT ABUSE)
3. Se.u.1 Abuse 0' exploitation
lJIJ Rape [}I] Incest
~ Statutory Ripe [!Uoevilte Sexual Intercourse
00 Sexual Assault
o Promoting Prostitution
~ Po,nogrophv
4. Physlc.1 Nogloct 100 NOT COMPLETE FOR STUDENT ABUSE)
888 Malnutrition rzB'I Lack ~f Supervision rzB'I Medical Neglect (resulling
L::...J (,osult,ng In a phvslcal L::...J In a phvslcal condition)
27 Failure to Thrive condition)
5. Immlnont Risk 100 NOT COMPLETE FOR STUOENT ABUSE) ~ PhVSlcal Inju,y @!] Soxual Abuso 0' Exploitation
B. OESCRIBE lliE INJURIES/CONOITIONS CHECKED ABOVE . f r 1 r the all e ed
~etrator asked the chi 1 d to touch and kiss hi 5 peni s. alleged perpetrator 5 owe
the child pornographic material on several occasions.
GOtho'
)004(14
ommonwca 0 cnnsy vania
cpar men 0 U Ie e arc
cv 418 . Ill!)!)
III. CPS SERVICES (DO NOT COMPLETE fOR STUDENT AaUSEl
A. WAS CHilD ALLEGEDLY ABUSED WHILE IN A "CHILD CARE SERVICE" (IS d.fln.d by CPSLl. DYES IX] NO
Ii. WAS CH!LD REMOVED FROM THE ALLEGED ABUSIVE SETTING? (includ.s move by ..It. O9oncy. othorsl (]J YES ONO
C WERE LAW ENFORCEMENT OFFICIALS NOTIFIED OF THIS REPORT7 (CY 104 ..ntl (]J YES o NO
D. SERVICES PLANNED OR PROVIDED: (Pl.... ch.ck th. .pproprl.t. blocks. (Abbr.vl.Uons: PL.PllIln.d, PR.Provld.d. IIld
PERP.P.rp.trator).
CHILD PARENT PERP. CHILD PARENT PERP.
PL/PR PL/PR PLlPR PL/PR PL/PR PL/PR
I>AI Ixw II ~ I ~~ IX9\' I .'1 Couns.llng ~ ~ Hom.mak.r/C.elak.r S.rvlces
EG ~ ~ R.I....I to S.II-H.,p 1>>lIIx:tO'j ~ InstrucUon .,d Educ.tlon lor
Group Par.nthood
~ ~ ~ Referr,l to Intra-agency ~ Em.rg.ncy M.dlc.1 Car.
S.rvlc.s
IX~ IXMlI ~ I !(J)(I Ul Ref....1 to Community ~~~Other
S.rvlces
PL/PR
~ Multidisciplinary T.am o No Servlc.s Plann.d or Provld.d
ClSe Review
~. .' ':., . . .... . ..IV. CASE STATUS ..... .
o PENDING JUVENILE COURT ACTION (Upd.t.d II 0 r~~0!N9 X~IMIN~~_a:;,~lJ.RT A.~T~o.N. ,I 0 FOUNDED (Court Flndlng-
A. CY 4B requlr.d wh.n court acUon compl.t.dl B. ~~I:~'~~;'~I,~~,ri.qUlr.d when court C. specl'y below)
I tl m reI .
I]) INOICA TED 1.[!] Medl",,1 Evidence 2.00 CPS InvesUg.Uon 3'1]) Perpetr.tor IE. 0 UNFOUNDED
D. (It checked, answer 1. 2. or 3) Admission
PLEASE EXPlAIN IN DETAIL THE BASIS FOR lliE CASE STATUS YOU CHECKED AND SPECIFY CRIMINAL ACTION.
The child remained consistent, credible, and concise throughout the interviewing process
that the allegations were true. The perpetrator admitted to the allegations
WAS THERE A RELIGIOUS BASIS FOR CHILD'S CONDITION? (Applicable only If E Is ch.ckedl OYESONO
DID lliE CHILD DIE AS A RESULT OF llilS INCIDENT OF ABUSE/NEGLECT? (Appllc.ble only II C or 0 I. checkeell DYES [!) NO
, .."-' '. -' V. FACTORS.CONTRIBunNG TO'ABUSE.;(COMPLETE FOR FOUNDED OR INDICATED REPORTS'ONLVI :'.'
Plene check as many as thr.e flctors and rank them In order of relevance r 1. being most relev.nt). Evidence must exist to
confirm the selection of the bctor(s) which appelrs to contribute to .buse,
o SUBSTANCE ABUSE 'INCLUDES DRUGS. CHEMICALS. ALCOHOL. ETC,)
o STRESS (DUE TO FINANCIAL PROBLEMS. UNEMPLOYMENT. DIVORCE. ETC.'
o MI.ROINAL PARENTAL SKILLS OR KNOWLEDGE IlNCLUDES UNREALISTIC EXPECTATIONS. LIMITED KNOWLEDOE OF CHILDHOOD DEVELOPMENT, ETCI
o VULNERABILITY OF CHILD (DUE TO CHILD'S AGE. PHYSICAL LIMITATION. DEVELOPMENTAL DELAYS, ETC.I
o SEXUAL DEVIANCY OF PERPETRATOR (BASEO ON A DIAGNOSIS OR CRIMINAL CONVICTION!
o ABUSE BETWEEN PARENT FIOURES (HISTORY OF FIOHTINO BETWEEN PARENTS OR PARENT SUBSTITUTES)
o INSUFFICIENT FAMILY/SOCIAL SUPPORT CSUCH AS FAMILY AND FRIENDS UNAVAILABLE TO HELP WITH FAMILY OR PERSONAL NEEDS1
I 0 IMPAIRED JUDOEMENT ,OF PERPETRATOR tCAUSED BY PHYSICAL. MENTAL OR EMOTIONAL LIMITATIONS'
o PERPETRATOR ABUSED AS A CHILD
COVlfTY W"[A[ "IUSE OCC\lAIUD IIWl:SlIOAlIlIO COUNTY CHILDLlNE USE ONLY
r.llmhprl.nd Cumberland CODE CtuIDl.lNt waR.IA
COUNTY "GENCY WOR.<<A A.
Audra Barbour B.
C:OUHn AC[HCY SUfI[AVISOA c.
Dianne Rupp D.
I "AU rOAU COU"UUD E.
I I 4 I - I ?lql-1916 r.
AGr 7
..
PLAINTIFF'S
EXHIBIT
7
O Check 'his block it . report
lor student abuII
IX] Check thl. block lor child abu.e
INSTRUCTIONS: S.nd on. copy at 'hi. campl.l.d form to ChlldLln. . Abu.. R.gII"", Ceplt.mlnt of Public W,lf.,., L.neo LOdg.. 3,d Fir" P,O. 8011II 2.'15
H'''''burg. PA 17101 wllhln 3Q d.y. .f Ih. ,.celp. ot In 0,.1 '.porl of .u.peet.d .bu... Pi.... IVp. 0' prlnl, U.. on. 'o,m ,., Incld.nl.
CHILD PROTECTIVE SERVICE INVESTIGATION REPORT
(Title 23 Pa. C.S.A Chepler 63)
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A. DATE OF INCIDENT
bet\om1 6/1194-12/31/95
Of CHIL UN.... F "'.
Shreve Ste hanie
ADORESS !lnclud. 5UU'. City. St.t., Zip Cod.1
115 South Washtn ton Street Mechanicsbur
.It. "', . n I .
PA 17055
Cumberland
206-70-6273
A
Shreve Judith
ADDRESS Includ. Stru.. C tY. Sill" Zip Cod.
115 South Washin ton Street Mechanicsbur
0, BIOLOOICAL/ADOPTlVE FATHER (L.... First. Mlddl. Inlll.U
Shreve Lon C.
ADORESS Includ. SU"'. City. 51"', Zip Cod.
PA 17055
Cumberland
SOCIAL SECURITY NO.
164-54-5720
COUNTY
1112 State Road Duncannon PA 17020
t ., I In u c
P rr
glncy
SOCIA SECURITY NO,
ADORESS C1nclud. Stru.. Cltr. Stl'I, Zip Cad..
COUNTY
BIRTHOATE!
MIll I DD I n
McRore Lonnie J.
ADOP 55 Include St,.... C Iy, Stl'l. Zip Cod.
IXIM 0- fotlther's Pararour
CO TV
yy
72
E.... fit. dd. n t .
Curberland Count Prison 1101 Clararont Road Carlisle PA 17013 Cumberl and
FAMILY HOUSEHOLD COMPOSITION (00 NOT COMPLETE FOR STUDENT ABUSE)
NAME (LIIL FlrsL Initial) RELATIONSHIP TO VICTIM NAME (LasL FlraL Initial)
Shreve An ela Sister
RElATIONSHIP TO VICTIM
A. TYPE OF AaUSE NEGLE
1. Physico' Injuries
01 Burns/Sc.lding
02 Fr.ctures
03 Skull F"ctures
o. Subduul Hem.lom.
05 Bruises
,,' , , -', '~,: .
T
00 Wells/Ecchymosis 11 Asphvxiation/Su' focation EE Drowning
0' llcer.tions/Abraslons " In'orn.1 Injurles/Hemorrtwge 17 Other
00 Punctures/Biles 13 Dismemberment
o. Brain Damage ,. Sprains/Dislocations
10 Poisoning .. OrugslAlcohol
02. Ment., InJurle. (DO NOT COMPLETE FOR STUDENT ABUSEI
3. Sexual Abuse or Exploitation
~ RJpe IJIJ Incest
~ C3t.ltulorv Ripe ~Oevllte Soxual Intercourso
lID Soxual A...ull
~ Promoting Prostitution
00 Pornography
4. Phy.lcal Neglect (DO NOT COMPLETE FOR STUDENT ABUSE)
888 M.lnutrition r-;a-1llck ~f Suporvlslo~ r-;;-1 Medical Neglect (rosultlng
. . ~ (resulting in J phvslcll L.....=..:....J in I physic.1 condition)
I 27 FaIlure to Thnve condition).
5. Imminent Risk (DO NOT COMPLETE FOR STUOENT ABUSEI I3il Physicol Injury @!J Sexual Abuse or Exploitation
B. DESCRIBE THE INJURIES/CONDITIONS CHECKEO ABOVE AccordinQl:o the referral source the alle ed
-Dfr.petrator as.k.e.lL.t.lJLcl1ild to touclLl1mLki5.LW.S_J1cnisJ The i'1l.c.!l~~Jlgrpetra~ r di itall
penetrated the child's vaQina and performed oral sex on the chIld. The allege perpe ra or
showed the child orno raohic material on several occasions.
00thar
00046'"
ommonwea 1 0 cn"!'ty Vant.l
r.vartmcn 0 U Ie narc
CY 48 . 619~
. -'-
'.
III. CPS SERVICES 100 NOT COMPLETE FOR STUOENT ABUSE!
A. VI. AS CHI::D ALLEGEDLY ABUSED WHILE IN A "CHILD CARE SERViCe" lIS d.lin.d by CPSLI. DYES lKJ NO
B: WAS .CHILD REMOVED FROM THE ALLEGED ABUSIVE SETTING? lincluda. mova by ..If, ag.ncy. othar.l [J YES o NO
C. WERE LAW ENFORCEMENT OFFICIALS NOTIFIED OF THIS REPORT? (CY 104 ..ntl [J YES o NO
D. SERVICES PLANNED OR PROVIDED: IPI.... ch.ck tho appro~rlat. block.. IAbbravlatlon.: PL'Plannad, PR'Provldad. and
PERP.Parpetretor).
CHILD PARENT PERP. CHILD PARENT PERP.
PLIPR PLIPR PLIPR PLIPR PLIPR PLIPR
I)!l)( I~ I ~ ~ Counseling ~ ~ Homermker/Caretak.er Servlclll
~ ~ ~ Rele"al to Selt-Help IX'lII~ I EG In.tructlon end Education lor
Group P.anthood
~ ~ ~ R,f.rral to Intra-Igency ~ Emergency Medlcll Car,
Services
IXllll~ I ~ ~ Ret."al to Community ~~~Oth.r
Services
PLIPR
~ Multidisciplinary Team o No Services Planned or Provided
Case Review
. . \, \' . ,... . '..IV. CASE STATUS . ' "... ..,..'.. .\ .'
PENDING JUVENILE COURT ACTION IUpdoted II 0 PENDIJI!l,i ~!:IIMINAL ...uURT ~_':TI.u..N tl 0 FOUNOED (Court Finding-
A. 0 CY 48 required when court action completeell B. (Uf,~~e~o~~' 4~JeqUlred when COUlt C. speclly below)
ICt! n m lete .
[]I INDICATED l{KI Medical Evldenc. 2.00 CPS Investigation 3'[]I ~J::.r~~~~ IE. 0 UNFOUNDED
D. X IIf ch.cked. answer '. 2. or 3)
PLEASE EXPLAIN IN DETAIL lliE BASIS FOR THE CASE STATUS YOU CHECKEO AND SPECIFY CRIMINAL ACTION.
The child remained consistent, credible, and concise throughout the interviewing process
that the allegations were true. The perpetrator admitted to the allegations.
WAS THERE A RELIGIOUS BASIS FOR CHILD'S CONDITION? (Applicable only II E Is checkedl OYESONO
DID lliE CHILD OlE AS A RESlA. T OF llilS INCIDENT OF ABUSEINEGLECT7 (Applicable only II C or D Is checked) o YES IX) NO
",...... .. ,.' V.' FACTORS.CONTRIBUTlNG'TO ?ABUSE;lCOMPlETE\FOR;FOUNOED'ORINDICATED REPORTS',ONLV)",:.\'. .' .
Pr.,se check u rmny as three fletars and rank them In order of rerevM1ce ("1. being most relevanO. Evidence must exist to
confirm tho selection of the flctor(s) which .ppears to contribute 10 Ibuse.
o SUBSTANCE ABUSE (lNCLUOES DRUGS, CHEMICALS. ALCOHOL. ETC.)
o STRESS IDUE TO FINANCIAL PROBLEMS, UNEMPLOVMENT. DIVORCE, ETC.I
o MARGINAL PARENTAL SKILLS OR KNOWLEDGE flNCLUDES UNREALISTIC EXPECTATIONS, LIMITED KNOWLEDGE OF CHILDHOOD DEVELOPMENT, ETCI
o VULNERABILITY OF CHILD (DUE TO CHILD'S AGE, PHYSICAL LIMITATION, DEVELOPMENTAL DElAVS, ETC.I
o SEXUAL DEVIANCY OF PERPETRATOR fBASED ON A DIAGNOSIS OR CRIMINAL CONVICTION)
o ABUSE BETWEEN PARENT FIGURES (HISTORY OF FIGHTING BETWEEN PARENTS OR PARENT SUBSTITUTESI
! o INSUFFICIENT FAMILY/SOCIAL SUPPORT (SUCH AS FAMILY AND FRIENDS UNAVAILABLE TO HELP WITH FAMILY OR PERSONAL NEEDS)
o IMPAIRED JUDGEMENT .OF PERPETRATOR (CAUSED BY PHYSICAL. MENTAL OR EMOTIONAL L1MITATlONSI
o PERPETRATOR ABUSED AS A CHILD
COUNty WH[R[ A'US[ OCCURRED IINVEStlGAtlHG CQUHTY CHILDLINE USE ONLY
Cumberland Cumberland CODE CHILOLl/lilE WORl.tR
COUNTY AG[Nt, WDRl[R A.
Allnrrt Rarbour B.
COUNTY AC(/IiIC' SUPERVISOA c.
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^~^ Common Sense Adoption SeI"Vices
Shreve, page I
" non.profit ogency
ADOPTIVE FAMILY PROFILE
,
This family has beell studied as all adoptive resource for children with special needs through the
Pennsylvania Statewide Adoptioll NellVork. Unless othenvise amended, this report is to be solely
used for identifYing placements for children in COUllly custody within the state of Pennsylvania.
Name:
Address:
Phone:
Contacts:
3/10/98
3/17/98
4/1198
4/8/98
4/15/98
6/9/98
8/89 - 6/99
8/16/99
8/16/99
8/16/99
-
Lon and Dixie Shreve
RD #1 Box 107
MiIlerstown, PAl 7062
717-589-3147
Adoption rraining
Adoption rraining
Couple interview
Interview with Dixie at home
Interview with Lon at home .
Interview with Lon and Dixie
Supervision of Kevin and Jason's placement
Interview with family in home
Interview with Dixie
Interview with Lon
INTRODUCTION
Lon and Dixie are experienced parents of birth children, foster ehildren and adopted children.
rhey each have ehildren from prior relationships and together they have parented foster children
between the ages of children 7 to 17. Currently, the children in their family inelude Lon's two
daughters (ages 13 and 14>. and the couples' two adopted sons (ages 14 and 17). The Shreves
have remarkable insight into teens and teen issues and seem to have the gift of working with
teens. Dixie states that they have known for a long time that parenting teens is something they
are good at and they finally dccided it was time to follow through and provide help for other
children. Their goal is to provide a home where a child can feel loved and aceepted, as well as a
place where children ean be taught skills for living in this complex world. They aehieve these
goals with a focus on the future, an understanding of the conflicts that adopted teens face, and
with the support of their faith.
Having been foster parents, the Shreves have experienced the children from the system
first hand. They believe that foster parenting is a great investment but something that they
quickly found was not for them. Lon and DiXi~ggled with returning children to what they
~
.........
Primr a",,,,,rr,,, (or Sl4IttM'iJt ~dopr;Dn NttltV,l
5021 East Trlndlo Road. Mochanlcsburg, PA 17055.3622 .800-445.2444/717.766.6449. Fax: 717.768.8015
..., ~....~'n....~..,._...,,-....;._.;.,.
PROSPECTIVE ADOPTIVE MOTHER
Dixie Lee (Hostler) Shreve was born on November 3, 1949 to Sherman and Mildred (Kiner)
Hostler in Mechaniesburg, P A. She is the second oldest of seven children in her family.
Shreve, page 2
believed were unfit birth homes when the county so required. They dcsired to playa part in the
child's Iifc as long as the child necded or wanted them there. Although bcing foster parents was
hard for them, thcy belicve that all adoptive parents would be more prepared if they foster
, parented f11'5t. Dixie comments, "You don't 1eam anything from these kids on good days: you
leam it on bad days." Thc Shreves have enjoyed the adoption training that they have participated
in through this ageney and have found that mueh of the information has been very familiar to
them.
Lon and Dixie are open to adopting a sibling group of up to six ehiIdren of any gender
and any age. They believe siblings should be kept together and are prepared to take as many as
room will allow. They are willing to consider medically needy children, even children who have
. AIDS or terminal illnesses. They would also consider children with physical disabilities if they
could obtain funding to make their home handicapped aceessib1e. Lon and Dixie are open to
children with moderate mental disabilities including Down's Syndrome. They are supportive and
even encourage contact with birth family members if such contaet is benefieial for the ehild.
Currently, they are interested in adopting Danny, a I3-yr. old child, who needs an adoptive
family.
Family and eMldl/ood: Dixie remembers her childhood home in rural Perry County as always
being busy, especially with seven children in the family. She lived in low income housing which
provided very little living space and all five of the girls in her family slept not only in the same
room but also in the same bed! Dixie remembers that they had no heat in their bedroom but kept
warm with the quilts her mother made for them. The boys also shared a room and her parents
had a room of their own. Although her home was always crowded and her parents never had a
lot of money: Dixie states that neither bothered her. She does remember getting teased at school
for not having "fashionable clothes," which has stayed with her ever since. She has a sensitive
spot for this matter with foster ehildren who have come into her home, and has always made sure
that they are dressed appropriately. In addition, Dixie states that her parents were always willing
to eare for people in need and would often take people into their home to help them. Dixie feels
that this is the origin of her desire to help others.
Dixie's childhood playmates were her siblings. She describes herself as close to all of her
siblings and feels that "there is always something that family members can give to you." Her
mother, Mildred, is now in her early 70's and lives in Newport where Dixie was raised. Her
mother was a "house mom" who didn't even drive until she was SO! Dixie's oldest brother,
Sherman, Jr., is now 53. He currently lives in Montana where he owns a gas station. He is also
married and has two boys and three girls. Her sister, Stephanie was 47 when she passed away
two years ago from her third stroke. She had Downs Syndrome, as does her son- who is in his
mid 20's. He was adopted by Dixie's sister Ruth and currently lives in a residential facility.
Ruth is now 46 and lives in Florida with a birth son. She has a job that Dixie describes as
Shreve, page 3
similar to a physical therapist assistant. She is in the process of getting a divorce. A younger
brother, Mark, is 4S and lives in Duncannon where he works for Bethlehem Steel in
management. He has four children, two who are his stepchildren. Dixie's sister Kathy is 42 and
works for the Hershey Creamery. She has two boys, one 19 and the other 2 I years old. Her
'husband died in October last year from cancer. Finally the youngest sibling, April, is 38 and has
been married for 20 years. She has a 20-year-old son and is a waitress.
Dixie does not remembers her mother using hitting as discipline but she does recall her
father getting out the belt and hitting her and her siblings. Although she does believe in
disciplining a child who has been disobedient, she does not believe in hitting. Dixie states, "If
you hit and yetteaeh not to hit, what is that saying to a child?"
One negative memory that Dixie has from her childhood was her father's drinking
problem. Dixie states that her mother shielded her and the other children from him because he
would beeome very mean when he wasn't drinking, as he was experiencing withdrawals. Dixie
states that due to the strain on his body because of his alcoholism, her father died twelve years
ago at age sixty-four ora heart attack. Dixie admits that she has struggled with alcohol in the
past, and that she used to drink when she became depressed. She recognized that she drank as an
excuse to get away from her problems and, four years ago, after realizing that she could very
easily fall into the same patterns as her father, Dixie quit drinking. She has learned from her own
experiences the part alcohol can play in the life of a depressed individual and feels that she eon
use this to help others from making the same mistakes that she did.
Educmion: Dixie states she was very rebellious in school and quit in the middle of ninth grade.
This came after failing fourth, sixth and eighth grades. She was married and pregnant at the time
she quit school and her husband was in the service. Twelve years later, after three children, a
divorce and second marriage, Dixie went to night sehooI and completed her GED. After her
second divorce she started part-time at Harrisburg Area Community College in Nursing. At this
point she was living with her mother and working a night shift at a nursing home, so she was
only able to take 2 courses at a time. She found school to be very diffieu1t for her, especially
because it had been so long since she had been in school. She diseontinued her education when
Lon's giris came to live with them for the summer, having found that it was too taxing to parent
the children and go to sehool.
Employment: Dixie has held many jobs over the years, including working at a dress faetory and
owning her own pizza shop. She built and ran the latter during four years of her second
marriage, but left it all when she got a divoree. When she attended school for her nursing degree,
she worked at a nursing home, and when she married Lon, she went into foster care full time as
her primary responsibility. Currently Dixie delivers papers for the Harrisburg Patriot to about
220 families in her community. She has considered that if they adopt very small ehi1dren, she
would like to stop a paper route to be available to make the children her top priority.
Activities and Relationsllips: Dixie states her most important activities are with her church and
she attends Bible studies there and frequently helps with the youth program. She also enjoys
quilting, gardening, canning and baking, and much of her time is now spent on their remodeling
,
\
Shreve, page 4
project. Dixie believes that her activities will not drastieally change when she adopts, but that
she will become busier!
Dixie states that her most important relationship is with God and that Lon and the
children come next.
,
C/.aracter/st/cs: Dixie is a Caueasian woman with brown hair and brown eyes and is in her late
forties. She stands 5 feet 3 inehes tall and weighs 140 pounds. Dixie expresses a compassionate
and selfless nature. She describes herself as practical, realistie, conservative and organized. She
also thinks that she is a worrier and tends to take things more to heart than Lon does, but notes
that this is a way that they complement each other. Lon describes her as "hard-headed" and very
. vocal, but also as the most caring woman he has ever met! He feels that she is sineere,
charitable, and giving, even to the point of sacrificing her own desires.
Health: Dixie's medical reference states that she is in good health and that she is free from any
communieabIe or infectious diseases and is able to raise an adopted child. This reference is
signed by Dr. Harry V. Pfautz, (License #05000612-L) of Dun cannon. PA, and is dated March 4,
1998. She reports that she rarely sees the doetor for health coneems. She is a non-smoker and
she does not consume alcoholic beverages.
Other: Dixie has two previous marriages. She quit high school while in the ninth grade to marry
Laird Roger Bonn and she was expecting her first child. They were married just before Mr.
Donn, who was in the military, was sent to Vietnam. Dixie explains that when he came baek after
the war she became pregnant and had a second child with him. However, the relationship
became abusive and the marriage ended in divoree on August 21, 1973.
Dixie remained single for the next five years. During that time she beeame pregnant with
another daughter, whom she placed for adoption at birth.
She married Horace W. Fritz in 1977 and he is the father of her fourth child. Dixie states
that Mr. Fritz was a good provider but that he was very non-communicative, focused on his
work, and that they laeked a personal relationship. Dixie states that after being unhappy for
most of the 15 years of their marriage she requested her husband join her for eounse1ing. He
refused and they were divorced on April 9, 1992.
PROSPECTIVE ADOPTIVE FArnER
Lon Charles Shreve was born in Youngstown, Ohio, on July 3,1960. He is the second oldest of
five born to his mother and the youngest of two born to Vernon Alva and Nora Mae (McPheron)
Shreve. In addition, Lon had three half siblings from his mother's third husband and a foster
sister.
Family alld Childhood: Lon was raised in South Florida near Pompano Beach until he was 10
years old. Significant in Lon's life is that he grew up not knowing his father, as he left when
Lon's mother was 6 months pregnant with Lon. Lon, as an adult, did meet his father briefly but
his father died shortly after that meeting.
Shreve, page 5
Lon remembers his mother as being very caring and giving, taking people into her home
who needed shelter. His family never had a great deal of money and Lon recalls going to school
for weeks with the same pair of pants. He also remembers his mother going without the things
that she wanted so that the children could have what they needed.
, His mother remarried when Lon was 3 or 4, and at age 10, his mother and stepfather sold
their house in Florida and bought a 22-aere horse farm in MiIlersburg. Lon remembers raising
hogs to make money and also mising chickens, geese and cows. He also recalls walking Y. a
mile to meet the bus! They even had an outhouse which they used, although the house had
running water. Lon described their lifestyle as "similar to the Amish,"
When his mother divorced for the second time, they sold all oflheir horses and rifles and
his mother worked nights to provide for the ehildren and to keep the farm. During that time, Lon
remembers the older ehildren taking eare of the younger and states, ''Times get tough, but you
don't give up, you work harder." His mother was able to keep the farm where she lived until the
children moved out, at which time she moved into town and has remained there ever since.
Lon remembers being disciplined as a child by his first step father. He describes this
discipline as being borderline abuse, as he would wateh his stepfather make the paddle and tape
it up (he broke it every time he used it so he needed to make a new one each time). Other times
his stepfather would make him hold his arms up until he would be in extreme pain. Lon states
that this physiea1 and psycho10giea1 abuse is the reason behind his different approaches to
discipline. His second step father was the closest Lon ever had to a father, as he was very kind
hearted. Lon reports that this step father never had to hit, as he was a six foot four inch, 320
pound logger and truck driver whose presence alone demanded obedienee!
Lon states that he was a diffieult child and by the age of8 he skipped sehooI almost one
third of the year. Lon describes himself as being "wild" by age seventeen. He feels this was in
part due to the fact that he had no male supervision and a ''big attitude". His mother and her third
husband were getting married, and Lon was "running with a bad kid from Philadelphia who was
on probation." He recalls that he wasn't typieally overly rebellious on his own but with the
. influence of a troubled friend Lon got into a great deal of trouble. Lon was caught and convicted
for robbery, burglary and retail theft, all within a six-week period of time. He reports that the
burglary took place when he and his mend broke into a carnival shed and stole several eases of
soda. When the mend Lon was with as ajoke pulled an unloaded pistol on kids who were
hitchhiking and stole their baekpack and supply of gum he was eaught and charged with armed
robbery. The retail theft oceurred when Lon filled his car up with gas and drove off without
paying. Lon reports that he had in total about 14 charges against him, although he was only tried
for three. Most of the charges were dropped before his case actually came to trial. Lon pled
guilty for all charges, knowing he had made a mistake. He even remembers the judge telling him
that it didn't matter whether the gun was loaded or ifhe stole gum or the faet that it was all a
joke, his actions still required consequences. His was given a 1-5 year sentence, 6months of
which were served in Dauphin County Prison and 6 months in Lebanon County Prison; he then
served four years on probation.
Lon states the turning point in his life from his rebelliousness and hard-headedness came
as the door shut behind him at the prison and he realized the finality of what he had done. Lon
found jail to be a place where he had no control over his own life and he often thought of the
Shreve, page 6
freedom that he eould have on the outside. His first daughter was born while he was in jail, a
ehild he hadn't even known about until shortly after her birth. Lon believcs that all oflhese
experienccs arc inva1uablc when raising children, especially children from the system. Lon
recognizes that often telling a ehi1d a consequence docs not mcan much to them because the ehild
, has not experienced it. Hc knows that he can offer the credibility needed when telling a child
what the consequences of rebellious actions are really Iikc. Lon desires to attempt to prevent
children from negativc repercussions by sharing his experiences with them, recognizing that
somc will still need to learn the lesson for themselvcs.
Lon's full brother, Keith, died this past spring after a battle with caneer. Hc was single.
Lon has always had a closc relationship with his brother and a few years ago, Keith and Lon
. spent a Christmas with their natural father. Shortly after that visit his father died and Lon reports
that he never really knew his father. His birth father did not even know of his existence until Lon
was 13 years old and they met for the first time when Lon was 16.
Lon has three half siblings from his mother's second marriage. Bill, is in his 30's and
lives in Indiana where he works in a foundry. He is married and has four children. Seott and
Jane are twins and both 28 years old. Scott is a Computer Network Specialist in HalifaX' and is
married with two children, whilc Jane lives in Middletown with her husband and two children.
Lon talks with Bill and Scott frequently and usually has eon tact with Jane at family gatherings.
Lon's second stepfather, George Lehman, died fivc years ago. Lon reports that when he
was older this man was a father figure to him. He brought threc childrcn to his marriage:
Carolyn who is in her late 30's and has one daughter; Linda who is also in her 30's and has two
daughters; and Rhonda who is in her 40's and has onc son. All live nearby. Lon secs
Caroline regularly as they attend the same church. He has no contaet with Linda but he secs
Rhonda at family gatherings.
In addition to his siblings, there is a friend of the family who is as close to Lon as a sister.
Lon's stepsister Linda had a friend also named Linda. When her mother passed away from
caneer Lon's family took her in. She is eurrenlly married and has two ehildren and Lon secs her
mostly at family functions.
Education: Lon went to elementary school at Cresthaven Elementary in Florida before moving
to Millersburg. When his family first came to Pennsylvania, Lon went to five different schools
before finally attending Millersburg Area Middle School. He went to Millersburg Area High
School until his junior year, when he was arrested on several charges. He completed his GED in
Lebanon County Prison in 1978, and actually graduated before the rest of his senior elass. At
that point in his life, Lon realized that he might as well take control and complete his education,
instead of wasting his time away. After release from prison, Lon attended the Thompson
Institute for Exeeutive Data Management. After 1 Y. terms, there was a frecze on all loans and
grants for eollege and for funding reasons Lon was unable to complete his degree. Lon left the
Institute with a 3.0 average.
Lon feels very strongly about the importance of education, and recognizes that he had the
ability to do far more than he accomplished, but he never really applied himself. Although at the
time he was happy to get by, he now wishes that he had worked harder. Lon has encouraged his
daughters to apply themselves as he recognizes that their only hope for college are their grades
Shreve, page 7
and the possibility of scholarships. He has used a reward system with both of them.
Employment: Lon's first job was working in fast food at Hardee's, and his first job out ofschool
was working as an auto mechanie. His primary motivation to pursue this position was to leam
, about cars for himself so that he could do his own repairs and save some money. He drove a
delivery truck for Kess1ers for 4 Va years, and at many points in his life has held two or three jobs
at a time. Lon states that he tries to look at jobs practically and has worked in restaurants
because he gels'the benefit of a free meal as welll At one point he had his own painting
business. Lon believes that "Idle hands will find trouble" and that much of his spare time in the
past has been working to keep him out of such trouble.
On the other hand, Lon's last job had him working twelve to thirteen hour shifts with no
holidays off, whieh he found difficult when helping to raise his two daughters. For this reason,
in September of 1998 Lon began working as an Assistant Manager for the Mid-Atlantic for ACE
Distributors. He took a $6000 pay eut so that he could spend more time with his family, and he
felt that this was worth it. Lon was laid off from ACE in 1999.
He was unemployed until June 1, 1999 when he began his current position as a resource
manager for Intellimark in Meehanicsburg. Lon works 8 to 5 and feels he eams a good wage.
The one down side of the job is that he has an hour commute to the job.
Activities and Relationships: Lon spends much of his time offwith his children. He likes to take
them to auetions, yard sales, fishing, and to the equestrian camp where the girls take riding
lessons. Many times he and Dixie go eamping at state parks or to a Christian camp in Halifax.
Lon and Dixie spend time together walking, sometimes with their dogs, and other times on trails
and around their community. Lon also loves to do yard work.
In the area of relationships, Lon places God flJ'St and then his wife and children. He also
enjoys family get-togethers and holidays, and is very active in his chureh. Lon deseribes that
they participate in activities at the church three evenings a week, and enjoy assisting the youth in
their bake sales.
Characteristics: Lon is a Caueasian man with hazel eyes and brown hair in his late thirties who
is 5 feet, 6 inches tall and weighs 225 pounds. He describes himself as hard headed and quiek
tempered, although he is vocal and not physical. He believes that as the husband and father he is
primarily responsible for his family, and takes the role of the ultimate diseiplinarian. He also
states that he is caring, good with ehi1dren, and little kids "take"to him. He also said that he has
a good sense of humor. Dixie deseribes him as "goofy" and states that nothing ever bothers him.
She said that Lon takes everything with "a grain of salt," and that he does not get "worked up
about things." Although Lon takes a very "laid back" attitude about life, he remains alert and
attentive as to where he can make an impact.
Healtl,: Lon's medical reference states that his health is good. It also reports that he is free from
any communicable or infectious diseases and is able to raise an adopted child. l'his reference is
signed by Dr. Harry V. Pfautz (License #05000612-L) of Duncannon, PA, and is dated Mareh 4,
1998. At the age of four, Lon became blind in his left eye through an aecident with a seam
Shrevc, pagc 8
rippcr.
Lon also reports that his health is good. As a child hc reports having severc bouts with
asthma and bronchial pncumonia. Now hc typically gels bronchitis oncc a ycar and he
periodically has an asthma attack that is treated with medication. In addition, Lon reports that hc
, has diabetes but that it is controlled with oral medication and by his diet.
Otl,er: Lon's first child, Suzanna, was born while hc was in prison. When she was ninc months
old hc brought her and her mother to Pennsylvania "to try to changc my Iifc and do right by my
child." Thc relationship with Suzanna's mother was a "mess" and Lon found it difficullto get a
job that could support a child. His daughter's mother left and began dating another man who
cventual1y got into a fight with Lon. Hc was alienated from his daughtcr for I I ycars until hc
was abIc to 10catc her again. Suzanna's mother is not supportivc of him having a relationship
with Suzanna so Lon has not had much contact with her.
Lon was manied oncc prcvious1y to Judith Lynn Farrell. After seven ycars ofmaniagc
they were divorecd on May 1,1989. At thc time shc had been ha~ing another relationship with a
man and had requcsted a divoree. Finally shc becamc pregnant to her boyfriend and at that timc
Lon agreed to thc divorec. Lon describes this period oftimc in his lifc as having bcen very
difficult. In trying to deal with thc issues ora failed maniage, Lon began to revert to his teCDagc
ways. He began to drink heavily and was arrested on a DUI charge in June of 1989. At that time
his license was revoked and he served three months in jail. He then worked at Hardecs to payoff
his $1000 tine.
He states in his autobiography, "When I fma1\y came out of my hole I dceided that never
again wi1\ I make cxcuses for my actions but that I needed to start to set examples of positive
behavior for my daughters to fo1\ow." His ex-wife has since become agreeable to Lon having
visitation with their two daughters every other weekend and split holidays. She has also a1\owed
the girls to spend the summer with their father. In addition, Lon pays support for the girls and
has them on his medieal insurance. He becomcs frustrated that many timcs his ex-wife is not
cooperative or responsible with the girls, yet hc takcs his responsibility to them very seriously.
Lon driver's license was suspended for five years after he was arrested for driving on his
suspended license following the DUI. Lon explains that he was required to pay ehild support
during his probationary timc and in order to meet that requirement he needed to drive to work.
He was caught on more than one occasion and each time the length of suspension was increased.
Sinee his maniage to Dixie, Lon statcs that she been his driver. Last year Lon's driving
privilegcs were reinstated. Dixie states that she is glad the burden of driving for Lon has been
removed from her shouldersl
COUPLE
Lon and Dixie were manied on February 20, 1994 at the Faith Christian Center in Liverpool, P A.
This is the second maniage for Lon and the third marriage for Dixie.
Marital History: Lon and Dixie mct in 1992 when Dixie was in college pursuing a degree in
nursing. She workcd thc third shift at a hospital and would go to a local restaurant, where Lon
Shreve, page 9
was the manager, for dinner. Over a sixth month period of time Lon asked her out on dates,
whieh she declined due to hcr impending divoree from her second husband. Finally, Dixie
ceased going to the establishment. Four to five months later they ran into each other in a club,
and Lon asked her out again. At this point, Dixie had completed her divorce and was more ready
'to date. She accepted under the condition that she drive and meet him at work (she was living
with her mother at the time and did not know if she eould trust him to know where she lived).
About a year and a half after their first date they were married at Faith Christian Center in
Newport, Pennsylvania.
Dixie reported that the decision to many Lon was a difficult one. This was primarily due
to the faet that Lon had two young children from his previous marriage who he still paid child
. support for and had visits with. Dixie stated that it was not a light deeision for her to make and
that she needed to consider if she was ready to have young children again now that all of her kids
were grown up and out of the house.
The Shreves feel that the biggest strength in their relationship is their faith in God. They
believe that this faith provides them with a love for and sensitivity to children. Lon believes that
his own sense of humor keeps a good balanee to Dixie's practicality and organization. Dixie
slates that "his strength helps me in my weakness."
The Shreves state that they didn't faee any major surprises upon getting married, as they
went through extensive premarital counseling with their pastor. The most diffieult problem that
they have faced in their marriage was actually beginning the marriage itself! Dixie found herself
starting all over again at age 44, a time in her life when she felt she should just be settling into a
routine. She commented that "everybody loses in divorce" and that she had lost all of the
security and stability that had eome from living in a marriage. She found it tiring to have to learn
new things about a new husband and to mesh together her strong will again with that of another.
This ine1uded big things such as finances in addition to the little differences that come with any
marriage. Lon and Dixie often found that their ways of doing things clashed, but that if they did
not focus on every issue they could make progress.
Lon compares the challenges faced in a new marriage to that of foster children entering a
new home. Each time a foster child would enter their home, the child was an "outsider" who
needed to beeome aeeustomed to new rules, new people and differing ways of doing things. In
addition, the children, like Lon and Dixie, would bring the baggage from their past with them
into the new home. In this way the Shreves express an understanding and awareness of the fears
and frustrations of children in the foster care system.
Activities and Relationships: Parenting is a time consuming activity for the Shreves but aside
from that the Shreves enjoy taking walks together along the country road that they live on.
Occasionally they travel to Harrisburg and visit City Island. Lon and Dixie also enjoy spending
time with their two dogs, numerous neighborhood cats, and three rabbits.
Lon and Dixie are also very active in their chureh, participating in services and Bible
studies, and helping with their very active youth group. When talking about the ehallenges they
have faeed in their lives they state they "would not be able to do it if it would no,! be for God
helping us". They spend a good deal of their free time with the church and have found church
activities to be a healthy and safe community activity for the children to participate in.
Shreve. page 10
The Shreves spend time with their families on special occasions. Typically they travel to
his mother's house for Christmas Eve, her mother's house Christmas Day moming. and to see
Lon's younger children Christmas Day night. On New Years Eve they attend a candlelight
service at their church.
,
Roles and Responsibf/ities: Typically in their home, Dixie does the housework and balances the
checkbook and Lon does the outside work and the maintenance. They have found that they
complement each other in that Dixie is a wonderful organizer while Lon procrastinates I Dixie
reports that in most issues where they disagree she defers to him and states that "it wouldn't do
any good to argue with him, he's hard-headed." They don't dwell on their disagreements and
. feel that there is not anything that is so important to cease their communication over. They also
pray for forgiveness when they hurt each other or treat the other in a way that is disrespectful.
Both feel that they have and will continue to share in the parenting responsibilities and
they take these responsibilities very seriously. All of the major decisions about the children are
made by both of them. Because of the children's history, Lon and Dixie do not leave the boys
and girls together unsupervised. Lon spends one-on-one time with the boys teaching them and
focusing on their issues and Dixie with the girls. Lon tells the ehildren that his goal is to get
them ready for adulthood and because they arc not coming to him as infants he doesn't have
much time with them to teaeh them. As a result, he tells them, they may feel he is tough on
them. He admits that indeed he is tough on them but for their own good. During the summer,
Kevin was eneouraged to get a job, which he did. The other children each day had a list of
chores that they were expected to accomplish. Lon and Dixie arc not shy about addressing issues
such as dating, drugs, and sex. In fact, the children know in detail what Lon and Dixie feel is
aeceptable behavior during a date.
Religioll: Dixie reports that she has always attended church and her faith has a large role in her
life. The church is an important part of her family's life and although Dixie recognizes that not
all children will follow the same faith, she is committed to having children participate in family
aetivities, which includes chureh.
Lon had a religious conversion experience during his time in prison. He reports that he
participated in a Bible study in prison and grew in his faith. However, he knew that when he was
released he would be tempted to return to the same destructive lifestyle. Lon reports that he did
struggle for quite a while until he began dating Dixie. With Dixie's support Lon has been able to
leave the destructive behaviors of his youth in the past.
Lon states that he does not have all of the answers, but he does desire to set an example
for his children by going to ehureh. He reports their children are expected to attend ehurch with
them but of course, what they believe is up to them. Lon desires for them to minimally be
exposed to his faith and states that "what they choose to believe is their business."
Values and Goals: Both Lon and Dixie feel that they "ran in the other direction" for so long that
they can now e1ear1y see where they made their mistakes. rhey believe that their lasting values
have come from a changed moral structure. They have found that conflict in their lives lessens
as they follow the guidelines that they believe God has set forth in the Bible. Some of these
"",;,
Shreve, page I I
principles arc honoring parents and the role of the husband and wife. The Shreves believe that
the wife submits to the husband, but that the husband loves his wife. This has set up a structure
for their marriage in which neither is belittled and conflict is minimized.
, With children, Lon and Dixie desire to break the cycle that has been set forth in the
children's lives. They believe that if children don't have any stability they will produce the same
behaviors as their parents. Their goal with children from the system is to provide that stability
and teaching, with the hope that in some small way they will have made a little difference in the
life of a child.
Dixie has had a great deal of experience with fosler children who have had learning
disabilities and feels it is important for a ehiId to finish what they start. She emphasizes the
. effort a child puts forth rather tllan the actual status they achieve. Dixie states that if she has to
'learn to tutor a ehiId at home to help them in their educational growth, she will learn what she
needs to assist theml Dixie is saddened when she thinks about how much she wants for a child,
recognizing that many times the ehi1d will not be able to or want to aehieve as much.
CHILDREN
Dixie and Lon have a total of seven children from prior relationships and two by adoption. Lon's
children are Suzanna, Angela and Stephanie. Dixie's children are Karl, Cindy, Coanne, and
Alice. Together, they have adopted Kevin and Jason. Currently, only the four youngest ehildren
live in their home.
Dixie's children by birth:
Karl Bonn (DOB 8/13/67) lives with his paramour in Newport and currently has two ehildren.
He works in construction. Dixie expresses that she sees Karl infrequently and describes their
relationship as distant. She states that this is because he is involved with drugs and aIeoho1 and
he knows she disapproves of this.
Cindy Bonn (DOB 8/2/68) lives in SummerdaIe and supports herse1flhrough buying and selling
products at flea markets. She has one daughter who lives primarily with the girls' father and his
wife. Dixie deseribes her relationship with Cindy as "cool" and states that Cindy visits her
periodically and almost on an as needed basis. Sometimes they don't see each other for two
months and other times they see each other several times a month.
Coann Moore (DOB 8//3/72) was born to Dixie between her first and second marriage. When
Coann was born Dixie was already struggling to raise two children and so she planned for
Coann's adoption at birth. At the age of 18 Coanne located and contacted Dixie. She now lives
in nearby Camp Hill. Dixie states that she was comfortable with the decision she made for
Coann and still is. She slates Coann was adopted by a good family, remains connected to them,
and is doing well. She hears from Coann oceasionally.
Alice Fritz (DOB /0/29/77) is the only child from Dixie's second marriage. Dixie calls Alice her
"alternative child," who was the rebellious, independent, headstrong one in the family. She
currently lives with her boyfriend in Lebanon. Dixie also describes Alice as a pleasure and a
very good kid. She states that they have a good relationship and Alice calls frequently and is her
birth child with whom she has the closest relationships. Aceording to Dixie, Alice thinks their
adoption plans are "wild" and she gets along with Kevin and Jason.
Shrevc, pagc 12
Lon's children by blrt',:
Suuznna Bunch (DOB 10/1178) was born while Lon was in prison and whilc therc is some
question as to his paternity, Lon has not taken any aetion to confirm it. Suzanna lives in North
· Carolina and is married. Lon last saw her when shc was a year old. Thcy havc had somc contact
in thc past but Suzanna's mother has discouraged this.
Angela Shreve (DOB 4/10/85) and her younger sister, Stephanic, havc in the past lived with Lon
and Dixic cvery othcr weekend, half of every holiday, and for two wecks during thc summer.
Howcvcr, this past summer thcy spent in entircty with the Shreves. Angie is known as thc
ta1kativc onc. Shc is entering thc ninth gradc this year and says she "kinda likes" school. Shc
enjoys the chureh youth group at the Shrcves' ehureh and gets along well with the other kids.
Hcr grcatest conccrn about bringing more kids into the family is that shc may havc to share her
bedroom, as shc does now. Dixic calls this a selfish reason but Angela knows that onec
renovations are donc shc will havc her own room. at least as long as thcy don't adopt more girls
Stepl,anle Shreve (DOB 3/24/86) will bc entering the 811I grade this year and states that for thc
most part shc likes school. Shc is describcd as quict and very artistie. Shc also enjoys thc chureh
youth group and is eonsidcring becoming involved in cheer leading. Stephanie and
Angic havc asked to stay permanently with Lon and Dixie. Stephanic states that shc likes that
her Dad teaches her things and that when shc is with her Dad shc ean get things like dental care,
hair cuts and clothing whcn shc needs them. She also likes that no onc at the Shreves uses drugs
or alcohol, unlikc at her mother's home.
Lon and Dixic arc hoping that thc girls' mother will allow them to stay with them;
however, if needed, at thc girls' request, Lon will be petitioning thc court for full eustody of the
children. The girls both talk of Dixie as a mother figure, although they usually call her Dixie.
Lon Qnd Dixie's adopted cllildren:
Kevin (DOB 4/15/82) is an artieulate 17 year old who, along with his younger brother, was
adopted in June aftcr a six month pIaeement. Kevin will be entering thc 1111I grade this year and a
three-year vo-tech program for auto mechanics. Because Kcvin does not havc enough credits to
graduatc next year hc will repeat the 1211I grade and be able to complete the vo.tech program.
Kcvin's time with thc Shreves has not been without diffieulty. There are many issues that Kevin
and Jason eomc with, ine1uding the rejection ofthcir birth mother. Kevin says that having been
in foster care sincc 1996 he is used to ehange. Howevcr, he states getting used to the Shreves'
church and living in a Christian home was really hard for him. Kcvin states that Lon and Dixie
are "pretty mueh everything you'd want" in a parent and he states that hc can see by the way Lon
and Dixie act that they want to help kids. Dcspite the challenges they have faced together Kevin
is happy in his home. He still has trouble obeying all the rules but he states that he knows thcy
are in his best interest and for his own good. He states that he was surprised but happy that the
Shreves encourage him to have contaet with his birth family. Kevin seems sentimental as he
talked about their plans to attend the first night ofthe Perry County fair, as they did a year ago on
. his first visit with the family, in celebration oftheir anniversary together. Kevin says he
welcomes the adoption of more kids in the family and views them as another person to play
football and wrestle with.
.....-.r ",. ...,._
Shreve, page 13
Jason (DOB 5/8/85) is entering the 8th grade. He, like his brother. is an artieulate child. He
deseribes having a hard time adjusting to the family rules but states that Lon and Dixie treat the
kids fairly and he especially likes the rewards they get for good behavior. like a trip to the ice
, cream parlor. He describes the family as "nice". He says that initially he didn't want to be
adopted because he was angry at his birth parents but now he's okay with it. He too states that
the "Christian thing" was the hardest thing to get used to.
In addition to these children, the Shreves have parented seven foster children ranging in age from
7to 17.
Reasons and attitudes regarding adoption: rhe Shreves see adoption as the way to fulfill their
'mission to help ehi1dren. They have found in foster parenting that their reward from the children
has come from such things as receiving a letter thanking them for all they have done or seeing
the improvement in a child's life. Dixie and Lon stress that they desire to adopt children to help
teach, encourage, and provide a loving and safe home. Dixie states in her autobiography, "It
would be a great honor to otTer myself as a mother to a child who desperately needs one." Lon
states, "I feel that if! can be there to help just one kid from making some of the mistakes 1 made,
then somehow all of the things I've experieneed would not be in vain. God has given us a large
house, many rooms and a lot oflove. We just seek to share it anywhere and anyway we can."
Having been foster parents, the Shreves have experienced the children in the system first
hand. They believe that foster parenting is a great investment but something that they quickly
found was not for them. Lon and Dixie struggled with returning children to what they believed
were unfit birth homes when the county so required. They desired to playa part in the child's
life as long as the child needed or wanted them there. Although being foster parents was hard for
them, they believe that all adoptive parents would be more prepared if they foster parented first.
Dixie commented, "You don't learn anything from these kids on good days: you learn it on bad
days." The Shreves have enjoyed the training that they have partieipated in through this agency
and found that much of the information has been very familiar to them.
Lon and Dixie had many experiences with the needs of the foster ehildren that they have
had in their home. One little girl, Ashley, had ADUD and a mental health diagnosis. The school
had threatened to kick her out so they had her transferred to Newport to a special education
program in their sehoo1 system. Because of Lon and Dixie's patience with her, Ashley was able
to succeed in sehool. Michael was another foster child in their care. When he entered their home
he was earning all D's and F's, but when he left their care he was featured in a foster parents'
gazette published by the county for his great strides academieal1y. This has left the Shreves
feeling good about all that they have accomplished educationally with their foster ehildren.
Lon and Dixie will consider sibling groups, male or female, of any age. They would love
to keep sibling groups together, and are prepared to take as many as room will allow. They are
willing to consider medically needy ehildren, even ehildren who have AIDS or terminal illnesses.
They would also eonsider ehildren with physical handicaps if they could obtain funding to make
their home handicapped accessible. Lon and Dixie are open to children with n;1oderate mental
disabilities ine1uding Downs Syndrome. They will consider visitation with birth family if it is
construetive for the child. In addition they are willing to consider children with a moderate
Shreve, pagc 14
degrcc oflcgal risk. Thc onc limitation the Shreves have slated is their inability to aceept a child
with a proven history of selling rues.
Discipline Polley: The Shreves believc thatthcy ean eorrect children without intlieting pain.
, Both Lon and Dixie believe that parcnts have to take control and teach their children. They
belicvc in correcting ehi1dren only for deliberate disobediencc and that many times the mistakes
that children makc arc not worthy of corrcction but simply a part of learning. Forms of
correction can inc1udc privilegc restrictions, such as restricting phonc usagc for tcenagers or timc
outs for younger children. Thcy givc ehildren an explanation for the eorreetion, and remind thc
children that they discipline beeause they earc and want to teach them, not simply to punish
. them. With their foster children in thc past they have set easy ground rules and madc eertain that
'thc children knew thc eonsequences of their actions. They will cven statc to a child about the
correction, "I havc to (restrict phonc use, timc out, etc.) becausc I promised it to you." They
don't belicvc in threatening their childrcn. At one point, Dixie attended a program at Holy Spirit
Hospital with her sister on children with ADHO. They were taught to givc two-minute timc outs
to childrcn and with older kids to cxp1ain why. Neither Lon nor Dixic would usc their parents'
way of disciplinc and belicve that children will respect them for correcting them. In addition to
consequcnces for misbehavior, thc Shreves give consequences for good behavior and thc family
may all go to thc local iec cream parlor on a day that cveryonc has been on good behavior.
Home: Thc Shreves live in a doubIc housc in Millerstown. They eurrent1y livc in half ofthc
housc whilc thc other half is undergoing major renovations. Their living spacc consists of a
living room, kitchen and a bathroom on thc first floor, and three bedrooms upstairs. Currently,
Lon and Dixic havc onc room, the girls share a room and thc boys share the third room. Thc attic
is ncaring the completion of its renovation and when compIetc (within thc next 6 weeks) thc boys
will bc sharing that Iargc room.
Thc half ofthc homc that is not being lived in is also undergoing renovations. When thc
renovations are eompleted, thcy will havc a total of five bedrooms and two baths plus a family
room and a fonna1 dining room.
Thc home has a modemte sized backyard with room to play. They are currently having a
swimming pool installed with the hope of being able to make use of it beforc the end ofthc
summer. They also own an adjoining lot that is vacant.
Thcy Shreve home also includes a Coeker Spaniel named Toby, an intimidating but
gent1c St. Bernard named Lilly, sevem1 cats and three rabbits, and a fcw chiekens.
Community: The Shreves live in a rural farming community in MiIlerstown, P A. Their town is
vcry safe with a low crime rate and very close knit due to its size. County fairs are held nearby
and the town itself ineludes a bowling alley and a skating rink in nearby in Marysvillc. A state
park is not more than six miles from their home. It has a pool and trails for hiking and biking.
Newport is a few miles away and has a speeial needs class in the sehoo1 system for children with
ADHD. Children can be bused from Millerstown to Newport to participate in ~he progt'l'm.
Millerstown is very rural, and Dixie reports that there really is not a lot of aetivity around.
Dixie states that one child who was placed in their care complained because "there were no
i
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,
Shreve, page 1 S
lights and he could not see if he tried to run away'"
Flnane!al Resource: The Shreves own thcir home. They are paying a mortgage of $828 on their
, home, the two unit rental property next door, and the adjoining vacant lot. All of which was
purchased for $66,000. Lon estimates their monthly expenses, ineluding mortgage, at about
$3000. The highest ofthose expenses include $ I 200 for groceries, car payments of$450, and
$100 for fuel. Lon also pays $400 a month in child support to his daughter's mother.
Their ineome includes S700 a month from the next door rental units and Lon's salary is
$35,000. In addition to this both Lon and Dixie have paper routes for whieh they earn S600 a
week. Currently, Dixie receives about S I 35 a week for providing day care serviees for four
. children. This will drop when school begins and she will only be providing after school day care
for one ehi1d. The Shreves also will receive subsidy for Kevin and Jason until the boys reach the
age of 18. Lon also owns a rental property in Duneannon valued at S65,ooO. From that unit he
has a monthly income of S550, the same amount as his mortgage on the ,home.
Using the figures given above, the Shreves' income appears to be sufficient to meet their
expenses.
Other Resources: Lon and Dixie have a health insurance policy through Health America.
Lon and Dixie have very supportive family members who will help them ifneeded with
any child in their home.
They have attended many trainings including the Department cf Agriculture's IO-week
mentoring programs, training from this ageney on topics such as Creative Parenting,
Understanding Attachments, Duilding Family Support Systems, and rips for Aeeessing
Educational Rights. Foster care trainings that they have attended included topics such as behavior
management, parenting for higher self esteem, sexual abuse, separation and placement, and
enhaneing se1f-eoneept of children. They Shreves also have tapes and books on different child
care concerns. The local library and school systcm has also been of aid to the Shreves with their
foster children.
Comments from this agency's training staff included, "Dixie and Lon have had such a
variety of experiences they were able to give a personal story which matched each vignette.
They were able to affirm the faet that meeting the child's needs makes a big differenee when
looking at managing a child's behavior." In addition staffstated, "They really helped
supplement what we had," and "Dixie shared stories about her children, and people appreciated
that very much."
Referenees: Four personal references were received for Lon and Dixie Shreve. All references
were positive.
Dixie's sister, April Manley wrote, "Dixie and her husband care very mueh for the
welfare of children. I feel that they would be a blessing to any child that needs a family to love
them."
Dixie's mother, Mildred Hostler commented that she had observed bollt Lon and Dixie in
situations with some very difficult foster children, and writes, "All situations were resolved with
patience and love." She states that, "I have S(len foster children mellow and grow in their eare."
Shreve, page 16
In addition, Mrs. Hostler speaks of the structure of their home: "The rules that they lay down in
their home arc just and ean be observed by even the most difficult children."
A third reference came from Robin Kepner, the head of the nursery ministry at their
church. Robin works with both Lon and Dixie in the nursery and states, ''They are great with the
, small ehildren. 1 wish you could see the delight in the eyes of these ehi1dren as these two get
down on the floor with them and play." She also states, ''They possess a rare and special kind of
love for ehildrcn. They have a kind of patience that can only be described as a calm endurance
without comp1aint....They are not passive parents, but rather the type of parents that are always
involved in the activities of their children. At ten o'clock, if you would ask them where their
children are, they would tell you."
Victoria Pearson, a friend oflhe Shreves, wrote, "I find them to be a wann, friendly and
loving eoupIe. 1 have witnessed them on many occasions with children of all ages. As a matter
offaet, you rarely see them without children. 1 witnessed them turn bad, drug using, alcoholic
kids into respectful kids that are a joy to be around by using just the right amount of discipline
mixed with a lot of love. I believe they would be wonderful parents for children of any age."
Foster Care Reference: A verbal referenee was reeeived from Jennifer Rose ofPeny County
Children and Youth, regarding the Shreves former foster parenting. Ms. Rose commented on
how well Dixie worked with the teenage girls, that she was a good listener and tried to give good
directions, and that the girls were open with her. Ms. Rose reported that the Shreves had "dealt
positively with children who were truant, involved in drugs and from the street." Ms. Rose did
raise some concerns about the Shreves. Mueh of the concerns revolved around Dixie's
understanding of her own limits and boundaries. For example, Dixie had an unlicensed day care
center in her home and cared for more than the state regulations allowed for her status. Perry
County claims that they addressed this issue with Dixie and that she was not compliant. In
addition, Ms. Rose stated that a foster child had reported that the Shreves were experieneing
marital difficulties, to the point that the child stated they were thinking about getting a divorce.
Another eoncem raised was the lack of cooperation that Perry County felt they received fiom the
Shreves with seheduling medical appointments for some of the foster children. When these
uncomfortable issues were addressed, Ms. Rose did not find Dixie very "approachable," and she
felt that the Shreves "challenged authority."
This agency discussed these issues and requested that Lon and Dixie meet with us to
address them. We have always found the couple to be approachable, and this instance was no
different. The Shreves seemed open and honest when each issue was brought up. We discussed
their knowledge of their own limits and boundaries, especially in reference to the day care eenter.
Dixie acknowledged that she was unaware of the regulations, and when informed, she told
several of the mothers that she could no longer care for their children. It became so difficult for
her to turn needy mothers away that she finally e10sed down her day care center. Dixie reports
being uncertain of how she will learn her boundaries with the children she adopts, but knows that
it will require a constant watchfulness on her part and trust in our agency to assist her in this
process. Most importantly, Dixie demonstrated a respect oflhe boundaries that the state
imposed, knowing that it was for the health and welfare ofthe children. .
Regarding the marital difficulties, Lon described a foster child who had lived in their
Shreve, page 17
home. Alaina was sixteen, and was often particularly friendly with Lon. Dixie belicved that
Alaina was flirting with Lon, and found it inappropriate, while Lon did not sec that there was
anything wrong with her behavior. rhis caused conflict between the couple. One particular day,
thc argument over A1aina's behavior arosc, and Lon took Alaina's side as opposed to that of his
, wife. Any foster child might have perceived this situation as "marital conflicts." When asked
how the Shreves resolved this situation they stated that they talked about Alaina's behavior.
After realizing that thc foster ehild had been manipulative in trying to divide them for her own
gain, they learned that, "even if the other person is wrong, you can't side with the children,
especially in front of them." rhis valuable lesson was found useful with every other child they
have eared for from thc system. They now know that they must talk with one another before
defending a child.
. In reference to their lack of cooperation with the ehildren's medical appointments, Lon
eou1d remember a time when AlBina (who had been pressed by the agency to get a job) first
started working, Perry County ealled to request that she attend a doctor's appointment. A1aina,
recognizing that she might be fired if she missed a day of work, asked ifthc appointment eou1d
be changed. Upon finding that it could not be changed because of the time constraint in fulfilling
thc requirement, AlBina refused the appointment and got into a "screaming match" over the
phone. Dixie and Lon defended her in thc reasoning she had for her refusal. In this way they
appeared non-compliant.
The Shreves acknowledged that they became frustrated with the way that the children are
handled within the system, although they recognize that they need to have respect for those
whosc job it is to help the kids. They also desire with all of their hearts to do what is best for the
children. They fccI that when that has involved advocating for the children's needs, they
understand that they have "stepped on a fcw toes," and appeared to be uncooperative. But as Lon
states, "They gave us kids that no one would take, and we managed them well." Despite Perry
County's concerns, the Shreves left foster eare as an approved family.
Documents: The Shreves have copies of their birth certificates, marriage license, divoree
decrees, autobiographies, and medical and personal reference letters on file. Also on file are the
Shreves' child abusc clearances dated 4/27/99 which indieate no reeord for either applicant. Also
on filc are their criminal record clearances. Dixie's is dated4/23/99 and indicates no record.
Lon's is dated 4/26/99 and indieatcs a criminal record. Specifically, Lon was arrested on 7/18/78
for Robbery and pled guilty. In addition, he was arrested on 7/28/78 for Burglary and on 3/21180
for Retail Theft, to both of which he also p1cd guilty. Finally he was arrested on 6/7/89 for DUI
of Alcohol or Controlled Substance. He pled guilty to this charge as well. For the DUI, Lon
driver's license was revoked and was imprisoned for two days. He later had 90 days added to his
driving suspension for driving with a suspended license. For the other eharges, Lon served 12
months split between Dauphin County and Lebanon County Prisons was on parole for an
additional four years.
Shreve, pagc 18
ASSESSMENTS AND RECOMMENDATIONS
Thc Shreves havc had many lifc cxpericnccs that have given them a great deal of understanding
of the troubled teens. They are expericnced parents, foster parents, and adoptive parents and
, havc much to offer children. They provide a strueturcd environment for ehildren and aim to teach
their children to be independent adults. Thcy teach their children life skills and they also offer
support to thcir children after they reach thc age of 18. Thc Shreves havc a desire to parent
children who need a home. They are open to children of any gender and agc and bceause thcy
belicvc siblings should be kept together whcn possib1c, they are prepared to takc as many
chi1drcn as room will allow. They are willing to consider medically needy children, including
childrcn who have AIDS or terminal illnesses. They would also eonsider children with
. handicaps ifthey could obtain funding to make their homc handicapped accessible. Lon and
Dixie arc open to children with moderate mental disabilities including Downs Syndrome. Thcy
will support visitation with birth family members whcn it is constructive for thc child.
Common Sense Adoption Services is a Pennsylvania licensed adoption agency, licimsi
#3509890, located in Mechanicsburg, Pennsylvania. U. S. A. The license is granted in
accordance with the Public Welfare Code 1967, P. L. 31 and is renewed annually. This agency
provides post-placement services.
Date of approval: June 23, 1998 Study written by Allison Stine and approve by Wendy Tibbetts.
Date of update: August 25, 1999
Respectfully submitted,
~ald~1'rr
Teresa J. Lanza. M.S. W.
Adoption Coordinator
Approved by,
Eri . J. Chick
Associate Director
.
L filE COpy
LV^ Common SenseAdoptioll Services
A non.prv/itogt.cy
ADOPTIVE HOME SUPERVISORY REI'ORT
CHILD'S NAME:
Daniel (Danny) Edward Gregor, II
FAMILY:
Lon and Dixie Shreve
RD I, Box 107
Millerstown, PA 17062
PHONE:
DATE OF VISIT:
DATE OF REPORT: .
(717) 589-3147
September 23 1999
September 28, 1999
INTRODUCTION .
This is the first supervisory report for Danny Gregor who was placed in the homc of Lon
and Dixic Shreve by Clinton County Childrcn and Youth for purposc of adoption on August 21,
1999. The partics signed an adoption assistance agreement and on September 22 the Shreves
liled a Report of Intent to Adopt in Cumberland County.
. The Shreves, who are in their late 30's and 40's, have parenting and foster care
rxperience. Their home currently includes adopted sons, Kevin, age 17, and Jason, age 14.
Danny has joined the family' after numerous foster eare placements and a residential placement.
Danny is not yet legally freed for adoption but the process of voluntary termination is underway
and anticipated to'be complete within a few months.' .
This report summarizes a home visit that S.eptember 23,1999 and phone conversations
that have occurred throughout the placement. During the visits all family members wcre present,
with the exception of Lon.
FAMILY ADJUSTMENT
The Shreves are experienced with the adjustment that occurs when a ncw membcr joins
their family. They have expresscd to Danny that, during the short time they have until he is an
adult, they will try to teach him all he needs to know to bc successful as an adult. They tell
Danny that he does not have to live with them and that it is his choice to live with them. Bu!,
thcy add, no matter how difficult it may be, thcy will never ask him to leave.
Lon and Dixie continue to work with Danny rcgarding their cxpcctations and the house
mles. rhings like wearing his pants around his waist, instead oflowered on his hips, is typical of .
thc struggles thcy have had. TIlere has only been one major incidcnt of defiance. It seems that..
Dixie was ab1c to earn Danny's respect through that and no incidcnts of cxtrcme defiancc have
becn repcated.
Lon and nixies' expericnce with parenting and foster parenting has becn instrumcnta1 in
hclping thcm understand Danny. rhey are very wc1coming of him, dcspite his shQrtcomings and
seem to instinctively know which issucs to ig~and which to tackle. They have been brushing
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PLAINTIFF'S
EXHIBIT
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off the story telling that Danny has been doing and focusing on other issues. Danny's
talkativeness is one issue that concerns the Shreves. It is gelling him into trouble at school and
he seems to use it to avoid having to hear something he does not want to hear. rhe Shreves are
struggling with this but have noted that some progress has been made since Danny's initial
placement.
Lon and Dixie express a fondness for Danny and are welcoming and excepting of him.
Kevin and Jason have also been welcoming of Danny. They have a similar history so they are
understanding of where Danny is coming from. They often share their clothing with Danny.
The most bothersome thing for them is Danny's persistent talking and at times the boys avoid
Danny because of it.
CHILD'S ADJUSTMENT
Danny adjustment to the Shreve home has been relatively uneventful. This has been
aided by the fact that the Shreve's expectations are realistic for a child with Danny's background.
Danny states that living with the Shreves means that he "has to give up drinking, smoking and
swearing". He states that he has not decided yet iflhat is something he ean do. On the other
hand, Danny states that "staying in one place" having a "normal life" and having "more things"
arc the benefits ofliving with the Shreves. .
Danny is enrolled in school at Greenwood High School. rhe Shreves anticipate that they
will have some struggles with the sehoo1 district personnel, who the Shreves slate were unhappy
the first time they adopted ehi1dren with special education needs. The Shreves are receiving
services from Cumber1andIPerry County MH/MR. Currently, they have a team of mobile
therapists. However, Dixie reports that she's not really sure that they are needed.
Dixie reports that Danny's biggest area of need is for him to be quiet and listen rather
than talking eonstantly. Dixie states that Danny's constant talking is not only causing problems in
school but begins to alienate him from other children. Jason and Kevin are also annoyed by this
and try to avoid him. Dixie also states that Danny questions and disagrces with every single rule
they have. However, she does not note this as a major issue and states that she is starting to
make some progress in this area as well. Dixie is considering implementing a behavior
management chart to help Danny in these areas. His consequence will be to have an earlier
bedtime, something she has found to be motivational for teens his age.
Danny has had phone contact and a visit with his birth father. Danny seems to have
accepted that his father cannot parent him. Danny says that his birthfather views adoption as
something he has to do, not something he wants to do. The Shreves have expressed to Danny
and his birth father that they support continued contact.
Danny has applied to work at McDonalds. He has bcen hired and will be starting shortly.
Dixie states that she doesn't know if it will work but that Danny deserves the ehange to try.
Danny also has chores at home. He is expected to keep his room clean and he is on a rotating
schedule for feeding the pets and doing the dishes. Danny allends church with the Shreves
Wednesday evening and twice on Sundays. He seems to cnjoy church.
Dixie reports that Danny has a good appetite and has been healthy. He does have trouble
sleeping and often has trouble gelling to sleep. When this happens he has trouble gelling up in
the morning.
He states that things are going well. When asked what he thought he needed to work on,
Danny responded "my temper". Dixie tells Danny that she is very pleased with how he is doing
and she tells him that what he is experieneing would be hard for any kid. Danny has talked ubout
going to u school dance und to the Sports Emporium. There are some of the activities he and his
brothers earn for good behavior.
SUMMARY AND RECOMMENDATIONS
This placement is progressing remarkably well. The Shreves, and Dixic in particular,
have what appears to be an unending souree of patience with Danny. The Shrcves appear to have
realistic expeetations for Danny and genuine affection. It is the recommendation of this agency
that this pIaeement eontinue. This agency will continue to supervise this placement and provide
or assist in loeating any needed services to support this placement.
Respectfully submitted,
-L~7
Adoption Coordinator
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FILE CO?Y
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A IIem'profit IIftl'Q'
ADOPTIVE HOME SUPERVISORY REPORT
CIULD'S NAME:
Daniel (Danny) Edward Gregor, II
FAMILY:
Lon and Dixie Shreve
RD 1, Box 107
Millerstown, PA 17062
PHONE:
DATE OF VISIT:
DATE OF REPORT:
(717) 589-3147
Oetober21" and November 10'h, 1999
November 19, 1999
INTRODUcrlON
This is the second supervisory report for Danny Gregor who was placed in the home of
Lon and Dixie Shreve by Clinton County Children and Youth for the pwpose of adoption on
August 21, 1999. The parties signed an adoption assistance agreement and on September 22M
the Shreves filed a Report of Intent to Adopt in Cumberland County.
This report summarizes home visits that occurred on October 21" and November 10111
1999 and phone conversations that have oecurred during the past two months. During the visits
all family members were ,fresent, with the exception of Lon. A separate meeting was held with
Lon on November the 11 .
FAMILY ADJUSTMENT
The Shreves express a genuine fondness for Danny. Dixie appears to have unending
patience with Danny, often mentioning his past as the cause of some of Danny's more annoying
behaviors, such as constant talking or arguing of a senseless point. Lon states that considering
Danny's problems he is doing well and that they are pleased with him. Lon states that Danny
often tries to push limits with him but that Danny stops when Lon "puts his foot down". Lon
states that Danny is "nothing they didn't expect" but that he knew in the first ten minutes of
meeting him that Danny would be challenging.
The Shreves have requested services to help them deal with some of Danny's behaviors.
They have a team of two mobile therapists who began coming to the home once a weck in
October. They began by encouraging the Shreves to give Danny choices, rather than constantly
repealing directives to him. In the beginning of November, they increased home visits to two
times a week and also reeommended a psychiatric evaluation, based on some concerns at school
and at home.
The Shreves arc rmding that Danny's excessive talking is problematic and not "normal".
They are beginning to wonder if there is a neurological basis for this. They also have not found
PLAINTIFF'S
EXHIBIT
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the mobile therapist to be effective in addressing this problem. As a result, the Shreves are
supportive of the request for a psyehiatric evaluation in hopes of impacting this problem.
The Shreves initially found that Danny was "gung ho" about the adoption but he has
since expressed some hesitation about wanting to be adopted. His doubts seem strongest after
contact with his birth father, although he has difficulty verbalizing concrete concems. The
Shreves express that they understand that there are a lot of conflicting emotions for older
children in adoption and they appear to appropriately not take Danny's wavering personally.
Dixie attended a support group meeting in October and found it was helpful. She has also
done some reading in the area of Attention Deficit Disorder and Conduct Disorder, with the hope
of gaining some insights for working with Danny.
Kevin and Jason fluctuate between getting along with Danny and tolerating him. Jason
continues to share some of his clothing with Danny. Danny's constant talking is one factor that
causes the boys to sometimes avoid Danny. Beeause of Danny's poor sleeping habits, Danny has
. been moved to a separate bedroom to avoid disturbing his brother' sleep. Lon's daughters have
had some weekend visits and reportedly have also been tolerating or getting along with Danny.
CHILD'S ADJUSTMENT
Dixie repol1ll that the first IEP meeting in October was more positive that she had
anticipated and that it seemed as iflhe staffliked Danny. She was told at the time that he was
doing average work in his special education placement but that he was talking too mueh. By
November the sehoo1 has requested that Danny have a psychiatric evaluation to be evaluated for
Attention Deficit and Hyperactivity Disorder and for mood swings. Dixie has scheduled an
appointment; however, February was the earliest time available. At the schools request, in the
interim, she took him to her family doctor who recommended Danny try a no sugar diet for two
weeks to see if that made a difference. In mid November, Danny began a trial of Ritalin. The
Shreves report that they have seen some improvements and there were less angry outbursts
reported at sehoo1.
In late October, the sehoo1 reported to the Shreve's an incident in which Danny
"threatened to kill everyone". The Shreves felt the school was really working with Danny by
dealing with this in the classroom. One of the problems they are finding is that Danny would
come into confliet with other children in the class. Additionally, Danny does struggle with the
work and often gets frustrated. There has been some discussion regarding whether an I.U.
placement might be more appropriate for him.
Danny's appetite has been reported as healthy. rhey have had some improvement in his
sleeping habits since he has been taking Ritalin. Socially, Danny has been very active with the
Shreve's church. He attends the youth group and reports that he enjoys the church activities.
Danny has also applied and been offered a part-time position at McDonalds. His first day he was
trained on the cash register. Before he left they told him the next time he came back they were
moving him up to e1eaning trays.
Dixie reports that Danny has expressed enthusiasm about being adopted and having a
home so he doesn't have to move. However, when asked directly by this caseworker, Danny
states that it is "okay" living with the Shreves. He seems hesitant to express a strong feeling,
positive or negative. He expresses that he is still getting to know them and that he doesn't yet
know ifit will work out for him to be adopted by the Shreves. However, he has no concrete
concerns or negative statements regarding his family. It is possible that Danny is hesitant to fully
commit himself to being a member of the family until he is sure that it will happen and he won't
be rejected.
SUMMARY AND RECOMMENDATIONS
This p1aeement is progressing well, despite the difficulties that the family is
experieneing. Also, despite the challenges that have been presented, the Shreves continue to
express a commitment to parenting Danny. It is the recommendation of this agency that this
placement continue. This ageney will eontinue to supervise this placement and provide or assist
in loeating any needed services to support this placement.
,
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Respectfully submitted,
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Adoption Coordinator
1:::0. fiLE COPl
6.V^ Common Sense A.doptioll Services
A non.profit.,,"'>'.
ADOPTIVE HOME SUPERVISORY REPORT
CHILD'S NAME:
Daniei (Danny) Edward Gregor,lI
FAMILY:
Lon and Dixie Shreve
RD I, Box 107
Millerstown, PA 17062
PHONE:
DATE OF VISIT:
DATE OF REPORT:
(717) 589-3147 .
December 20, 1999 and January 18, 2000
January 20, 2000
INTRODUCTION.
This is the third supervisory report for Danny Gregor who was placed in the home of Lon
and Dixie Shreve by Clinton County Children aDd Youth for the purpose of adoption on August
21,1999. The parties signed an adoption assistance agreement and on September 22ld the
Shreves filed a Report oflntent to Adopt in Cumberland County. On January 12, 2000, Danny
appeared in court for a case review: Also at that time, a petition for voluntary termination of
parental rights submitted by Danny's birthfather was granted by the court.
This report summarizes home visits that occurred on December 20th and January 18th and
phone conversatioas that have occurred during the past two months. During the visits all family
members were present, with the exception of Kevin, the Shreve's eldest adopted son.
FAMILY ADJUSTMENT
The Shreves continue to express their commitment to Danny, despite having had'
difficulties the past fe\:V months. Danny has been expelled from school and is attending
altenlative classes, evenings twice a week. The Shreve's have been making an effort to be as
cooperative as possible with the school. The school is requesting psychiatric evaluations and
approva1.before he return to his classroom setting and the Shreve's have been working to get this
accomplished. . .
As a r!lsu1t of the school situation, Dixie is spending a good deal more time with Danny.
She notes that-the holidays wereparlicu1ar1y hard on Danny and that he has been disappointed by
sporatic contact by his birth father. The Shreve's reported that Danny's negative behaviors
worsened around the holidays bulth~t they had anticipated this would happen. Both Lon and
Dixie are able to put Danny's behaviors in perspective with his past experience and express an
acceptance of him despite his limitations. .
The Shreves are consulting with a psychiatrist now and continue to have a therapeutic
support staff aide visit the home regularly. The Shreve's fcltthe need for additional supports but
to date have not found the psychiatrist to be particularly helpful. Additionally, they feel that
PLAINTIFF'S
EXHIBIT
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Danny would benefit more from individual counseling by a therapist but Danny is refusing this
service.
On a more positive note, the Shrcves are noticing thatthcy have made some impact with
Danny. He has cried a few times and they perccivc that expression of cmotion as a sign that he
is attaching to them. Additionally, one time when Danny became upset with Lon hc wrote Lon a
letter about his grievances. Lon wrote back and Danny responded with another letter. The
Shreves felt that writing, rather than talking, may have been a more effective way to
communicate with Danny.
The Shreves have been discussing adoption with Danny. Danny sometimes expresses
wavering feelings about the topie. The Shreves express that it is a scary step for them as well
and that they don't know how it will turn out but despitc their uncertainty, thcy were moving
forward with the adoption. Lon and Dixie state that they know the weeks before an adoption
hearing are particularly stressful for older kids and that they anticipate the stress may affect
Danny's behavior. Nonetheless, they are ready to move forward.
Kevin, as of early this month, is no longer living in the Shreve's home. According to Lon
and Dixie, Kevin is still hoping for thc opportunity to live with his birth family and has chosen
not to live with the Shreves. They express that they welcome him back and have been
attempting to maintain a relationship with Kevin. Kevin's departure seemed to upset Danny;
however, Danny will likely benefit from seeing the Shreve's commitment to their children
expressed in this situation. Danny and Jason have been getting along rather well, to cveryone's
surprise and pleasure. In Jason's words, they are "getting along very well".
CIllLD'S ADJUSTMENT
Danny had a psychiatrie evaluation on December 27th. Medications have been
prescribed. Danny has been taking the medication for three weeks now but reports that he does
not notice a difference. The Shreve's report that over the holidays and prior to the court hearing,
Danny was very moody and had very fluctuating behavior. They note that only now his behavior
is becoming more stable; however, they are unsure if it is the medication or the reduced stress
that is resulting in the improvements.
. Danny continues to attend several hours of alternative school, twice a week. It is
anticipated that he will enter a partial hospitalization program t1us month, prior to returning to his
previous school placement. Currently, the school, in consultation with the Shreves, is
eonsidering two programs. According to Dixie, the goal for t1us p1acemcnt would be to address
Danny's anger issues and teach lum anger management.
As indicated previously, the past few months were difficult for Danny. December 3rd was
his 16th birthday, followed by thc Christmas holiday, and the court hearing and tcrmination of
parental rights early in January. In addition to this, was Danny's expulsion from school. Danny
expressed that he cnjoyed celebrating his birthday and the holiday with the Shreve's. He has had
contact with his birth father, birth grandmother, and former foster family and he spent several
days with his birth father over the Christmas holiday. While the contact with his birth family is
desired by Danny, it also seems to come with conflict and disappointment and the results are
often not optimal for Danny.
Danny does secm to have acccpted the fact of his birth father's tcrmination of parental
rights, as this is something he has been coming to terms with for a long time. Howcver, the
hearing was stressful. TIle Shreve's report seeing a deterioration of behaviors three days prior to
the hearing.
One spccifie incident of eonccm occurred on January 71h. Danny became agitated and ran
away from home. Lon camc home from work and they contacted the police, crisis intervention
and the county. They found Danny at a neighbor's housc and took him to the hospital for an
evaluation. The Shreves described Danny's behaviors as very agitated and his thinking as
illogical. TIley wonder if the stress of the past month triggered the event. Danny was evaluated
by a psychiatrist and given a sedative to calm him before he was released. rhe Shreves have
also deseribed times when Danny's thought seems out of touch with reality. On one occasion he
claimed to see UFO's and on another day he pretended to be a doctor for the entire day. rhe
Shreves, though obviously concemed about Danny, seem to have taken this in stride and
continue to express that they are committed to him. They also continue to seek support from the
psychiatrist to address these issues.
Danny has been physically healthy. Dixie proudly reports that he has gained 23 pounds
since he moved in with them. Dixie also reports that the medication Danny is taking seems to
have improved his sleeping habits. Danny is being monitored by his psychiatrist for the
medication and routine blood work is being done.
Danny appcars to be attaehed to the Shreves. He calls them Mom and Dad now and gets
along well with Jason. However, Danny continues to express some hesitancy about being
adopted. He has been assured that this is a normal feeling. He bas been prepared for the
adoption hearing and has been told that he will be asked by the judge on that day if he consents
to the adoption.
SUMMARY AND RECOMMENDATIONS
This placement has been most challenging the past few months. The Shreves are
commendable in their ability to accept Danny and to remain committed to him despite the
challenges that are present. It is the recommendation of this agency that this placement proceed
toward fmalization. This agency will continue to supervise this placement and provide or assist
in locating any needed services to support this placement before and after the finaliZlltion of the
adoption.
Respectfully submitted,
0=t:':ff<-
Adoption Coordinator
LOO C. SHREVE, . IN THE CXJURT OF CXlMMON PLEAS OF
.
Plaintiff . CUMBERLAND CCllJN'lY, PENNSYLVANIA
.
.
.
vs. . NO. 95-3318 CIVIL TERM
.
.
.
JUDITH LYNN SHREVE, . CIVIL ACTION - LAW
.
Defendant . IN CUSTODY
.
aIDER OF CXlURT
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AND tOi, this /I.-rA day of !/,rl.'ilClA1J- , 2000, upon
consideration of the attached Custody Conciliatiorll Report, it is ordered
and directed as follows:
1. A Hearing is scheduled in CoJ,lrt Room # i , of the
Cumberland County Court House, on the ,;('Ju, day of () 1-0/0 I .L, ,
2000, at 9: -30 o'Clock, -!1-.m. at which time testimony will be taken.
For purposes of this Hearing, the Father, Lon C. Shreve, shall be deemed to
be the moving party and shall proceed initially with testimony. Counsel
for the parties shall file with the Court and opposing counsel a Memorandum
setting forth each party's position on custody, a list of witnesses who are
expected to testify at the Hearing and a sunmary of the anticipated
testimony of each witness. These Memoranda shall be filed at least 10 days
prior to the Hearing date.
2. Pending further Order of Court or agreement of the parties,
the prior Order of this Court dated August 15, 1995 shall continue in
effeet.
BY THE CXJURT,
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Barbara Sumple Sullivan, Esquire - Counsel for Mother f\ KS
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LON C. SHREVE , . IN THE CX)URT OF <XlMMON PLEAS OF
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Plaintiff . CUMBERLAND COONTY, PENNSYLVANIA
.
:
vs. . NO. 95-3318 CIVIL TERM
.
.
.
JUDITH LYNN SHREVE, . CIVIL ACTION - LAW
.
Defendant . IN CUSTODY
.
PRIeR JUDGB: Kevin A. Hess
~ CXH:ILIATlON SlMIARY REPCRT
IN ACOaIDl\NCE Wl'l'II aKlERLAND anmc RULE Of! CIVIL PIl() ."" -IRE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
DATE Of! BIRTH
alRRmTLY IN ~ Of!
Angela N. Shreve
Stephanie D. Shreve
April 10, 1985
March 24, 1986
Mother
Mother
2. A Conciliation Conference was held on February 9, 2000, with the
following individuals in attendance: The Father, Lon C. Shreve, with his
counsel, James D. Flower, Jr., Esquire, and the Mother, Judith Lynn Shreve,
with her counsel, Barbara Sumple Sullivan, Esquire.
3. This Court previously entered an Order in this matter on August
15, 1995 under which the Mother had primary physical custody of the
Children and the Father had a schedule of partial physical custody. In
August 1999, the Father filed a Petition for Modification seeking primary
physical custody of the Children. At the Conciliation Conference in
September 1999 the parties agreed that counsel would meet with the Children
and then conduct a Conference with the parties in an effort to resolve the
primary custody issue. The parties were not able to resolve this matter
informally and a second Conference was held, again on the issue of primary
custody of both Children. The parties were not able to reach an agreement
and it will be necessary to schedule a Hearing.
4. The Father's position on custody is as follows: The Father stated
that he filed the Petition for primary Custody at the request of the
Children, who are 13 and 14 years old. ACCOrding to the Father's counsel,
the Children indicated their preference to live with the Father during the
meeting after the first Conciliation Conference. The Father believes the
Children's reasons for wanting to live with him at this time are reasonable
and believes it would be in the Children's best interests to transfer
primary physical custody.
5. The Mother's position on custody is as follows: The Mother
indicated that the Children are not expressing to her a strong preference
to live with the Father. The Mother indicated that the girls are now
,n.
settled in high school, have made friends, and are getting good grades.
The Mother does not believe it would be in the Children's best interest to
transfer primary custody.
6. The Conciliator recoomended to the parties that they obtain a
custody evaluation in order to resolve the primary custody issue. However,
the Mother indicated that she is not able financially to contribute to the
evaluation and the Father stated that he was not willing to pay the entire
cost because he believes the Mother will request a Hearing even after the
evaluation is completed.
7. The Conciliator recoomends an order in the form as attached. It
is expected that the Hearing will require at least one-half day.
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Date Q'
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Dawn S. Sunday, Esqu r
Custody Conciliator
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LOllI C. SHREVE,
Plaintiff
: IN THE COURT OF ca1MOlII PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs.
: NO. 95-3318
CIVIL TERM
JUDITH LYNN SHREVE,
Defendant
: CIVIL ACTIOlII
IN cusrooy
amm op (XlJRT
AND tuf, this I $"' day of (.l"/~''''' 1995, upon consideration of
the attached CUstody Conciliation Report, it is hereby ordered and directed
as follows:
1. The Father, Lon C. Shreve, and the Mother, Judith Lynn Shreve,
shall have shared legal custody of Angela N. Shrevo, born April 10, 1985 and
Stephanie D. Shreve, born March 24, 1986.
2. The Mother shall have primary physical ~"~tody of the Children.
3. The Father shall have partial physical custody of the Children as
follows:
A. The Father shall enjoy partial physical custody of the Children
on alternating weekends, beginning August 4, 1995, from Friday
evening until Sunday evening, at times to be arranged by mutual
agreement of the parties.
B. During weeks following weekends during which the Mother had
physical custody of the Children, the Father shall enjoy
partial physical custody of the Children on one weekday
evening, the specific times and days to be scheduled by mutual
agreement of the parties.
C. The Father shall have extended periods of partial physical
custody of the Children during the remainder of the Slllll1l8r,
1995 to be arranged by mutual agreement of the parties.
4. Each party shall have two weeks of expanded physical custody of the
Children (not necessarily consecutive weeks), each summer upon thirty (30)
days notice to the other party.
5. The parties shall share physical custody of the Children on
holidays as follows:
A. Christmas:
The Father shall have physical custody of the Children on
Christmas Eve in every year and the Mother shall have physical
custody of the Children on Christmas Day, beginning by 9:00
a.m. Christmas moring, in every year.
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B. Thanksgiving:
The Father shall have physical custody of the Children on
Thanksgiving in every year until 4:00 p,m. and the Mother shall
have physical custody of the Children on Thsnksgiving in every
year beginning at 4:00 p.m.
C. EASTER:
The Father shall have physical custody of the Children on
Easter until 3:00 p.m. in even numbered years and beginning at
3:00 p.m. in odd numbered years. The Mother ahall have
physical custody of the Children on Easter until 3100 p,m. in
odd numbered years.
D. other Holidays:
The Mother shall have physical custody of the Children on
Memorial Day and Labor Day in even numbered years snd on July
4th in odd numbered years. The Father shall enjoy physical
custody of the Children on July 4th in even numbered years and
on Memorial Day and Labor Day in odd numbered years.
E. Mother's Day/Father's Day:
The Mother shall have physical custody of the Children on
Mother's Day in every year and the Father shall have physical
custody of the Children on Father's Day in overy year,
6. only persons with a driver's license shall transport the Children
by motor vehicle. The Father shall be responsiblo to arrange transportation
for his scheduled periods of partial custody under this Order,
7. If child care is required due to the Mother's absence for a
significant period of time, the Mother shall notify the Father to make
arrangements for the Father to have physical custody of the Children during
her absence. If the Father deelines, the Mother shall make other child care
arrangements.
BY THE COURT,
cc:
Gary Lysaght, Esquire
L. Rex Biekley, Esquire
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Loo C. SHREVE, . IN THE COURT OF CQI1MON PLEAS OF
.
plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
VS. . NO. 95-3318 CIVIL TERM
.
:
JUDITH LYNN SHREVE, . CIVIL ACTIoo
.
Defendant . IN CUSTODY
.
aJS'l'OOY CXH:ILIATICfi stMlARY REPmT
IN AOCDml\NCE wrm aJmERLAND axHl.Y RULE OF CIVIL PQ(Jo '" -IRE
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. The pertinent information pertaining to the Children who are the
subjects of this litigation is as follows:
NAME
BIRTHDATE
CURRENTLY IN CUsroDY OF
Angela N. Shreve
April 10, 1985
Mother/Defendant
Mother/Defendant
Stephanie D. Shreve
March 24, 1986
2. A Coneiliation Conference was held on August I, 1995, with the
following individuals in attendance:
The Father, Lon C. Shreve, with his counsel, Gary Lysaght, Esquire,
and the Mother, Judith Lynn Shreve, with her counsel, L. Rex 8ickley,
Esquire.
3. The parties agreed to the
attached.
hvr'AU,f 7 /9 c; r;-
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entry of an Order in the form as
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Dawn s. sunday, Esquire
CUstody Conciliator
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1350 FISHING CREEK VALLEY ROAO
HARRISBURG. PENNSYLVANIA 17112
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
LON C. SHREVE, NO. 95 - 3318
Plaintiff
v.
CIVIL ACTION - LAW
JUDITH LYNN SHREVE,
Defendant
CUSTODY
PLAINTIFFS ANSWER TO DEFENDANTS NEW MATTER
5. Denied. Plaintiff has no knowledge to form a belief or truth to
Defendants averment. By way of further response it Is specifically denied that
Plaintiff Is able to maintain regularly scheduled visitation with the children
because Defendant Is refusing to permit visitation of the children.
6. Denied. Defendants averment Is a legal conclusion to which no
response Is necessary.
7(a). Denied. Plaintiff has no knowledge to form a belief or truth to
Defendants averment. By way of further response, strict proof Is demanded.
(b). Denied. Plaintiff has no knowledge to form a belief or truth to
Defendants averment. By way of further response, strict proof Is demanded.
(c). Denied. It is specifically denied that Plaintiff has been incarcerated
within the last year.
8. Denied. Plaintiff has no knowledge to form a belief or truth to
Defendants averment and strict proof is demanded.
RESPECTFULLY SUBMITTED:
G
1.0. o. 183
1350 Fishing Creek Valley Road
Harrisburg, PA 17112
(717) 599 - 5320
ATTORNEY FOR PLAINTIFF
Date: 1~f{"'('
,
VERlFICAnON
Subject to the penalties of 18 Pa. C.S.A. at 4904 relating to unsworn
falsification to authorities, I hereby verify that the statements made In the
foregoing document are true and correct to the best of my Information and belief.
Date: ~ ", Jl1 S
LddfAJ~
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
LON C. SHREVE,
Plaintiff
No. 95-3318 CIVIL TERM
vs.
CIVIL ACTION - LAW
JUDITH LYNN SHREVE,
Defendant
CUSTODY
ANSWER TO RULE, NEW MATTER & PETITION
FOR TEMPORARY CUSTODY
AND NOW, comes Judith Lynn Shreve, above captioned Defendant,
and Ann Farrell, maternal grandparent, by and through their
attorney, L. Rex Bickley, Esquire, and respectfully answers
Plaintiff's Petition for Special Relief and Rule as follows:
1. Admitted.
2. Admitted.
3. Admitted in part and denied in part. It is admitted that
Judith Lynn Shreve is temporarily leaving Pennsylvania. She will be
returning to Pennsylvania toward the end of August after completing
an Arthur Murray Dance Studio training program. By way of further
answer, upon her return to Pennsylvania, she will be employed by
the Arthur Murray Dance School located in Lemoyne, CUmberland
County, Pennsylvania as set forth in a contract which is marked
Exhibit "A", attached hereto and incorporated herein. It is denied
that she is permanently leaving the jurisdiction of this Court.
the Defendant will be placing the children in the temporary care of
her parents for approximately two (2) months. The suggestion that
her parents are elderly is purely subjective and the implication
contained in Paragraph 4 that she will be retrieving the children
and removing them from the jurisdiction of pennsylvania is denied.
WHEREFORE, Defendant hereby requests that this Honorable Court
dismiss Plaintiff's Petition for Special Relief.
l
~:
NEW MATTER
5. Defendant is not removing the children from the
jurisdiction of the Court of Common Pleas of CUmberland County and
consequently the Plaintiff shall be able to maintain his
alternating weekend of scheduled vacation.
6. Consequently, the relief sought by the Plaintiff is
unnecessary.
7. The welfare of the children would not be served by
granting the Plaintiff general custody of the children at this time
because of the following:
a) The Plaintiff is pursuing this matter primarily
because the Defendant, Judith Lynn Shreve, sought and obtained
child support for her children for the first time from the
Plaintiff several months ago and the Plaintiff is acting in a
purely vindictive manner.
b) Although the Plaintiff's motor vehicle license is
presently suspended and will be suspended for years to come, he
still operates a motor vehicle on a regular basis.
c) The Plaintiff, within the last year, has been
incarcerated.
8. The welfare of the children would be better served if
they remained with those individuals with whom they have
established a close and regular relationship since birth.
WHEREFORE, Defendant hereb}" requests that this Honorable Court
dismiss Plaintiff's Petition for Special Relief.
PETITION FOR TEMPORARY CUSTODY
9. AND NOW, comes Ann Farrell, mother of the Defendant,
Judith Lynn Shreve and maternal grandmother of the minors who are
the subject of this Petition who joins on her own behalf and on
behalf of her husband and Judith Lynn Shreve and hereby request
that this Court grant her, Ann Farrell, temporary custody of Angela
Shreve and Stephanie Shreve and in support thereof avers the
following.
10. The maternal grandmother is in excellent health and
works.
11. The maternal grandfather, although in a wheelchair, is
otherwise in good health.
12. Both maternal grandparents have cared for and are
prepared to care for the children over the next two months.
13. The children would prefer to live with their maternal
grandparents.
14. Judith Shreve, mother of the two children, believes and
therefore avers that it would be in the best interest of the
children to remain with her parents.
15. The least disruptive disposition at this time would be to
allow the children to remain with their mother and the maternal
grandparents and to allow the Plaintiff to exercise rights of
visitation presently in place.
WHEREFORE, Defendant prays this Honorable Court dismiss
Petition for Special Relief filed by the Plaintiff and also
requests that this Court grant Ann Farrell temporary custody of the
two minor children.
ley , Esquire
121 So Street
Harr burg, PA 17101
(717) 234-0577
Attorney for Judith Shreve
and Ann Farrell
'.,
VERIFICATION
I, Judith Lynn Shreve, verify that the statements made in this
Answer, New Matter and Petition are true and correct to the best of
my information, knowledge and belief. I further understand that
false statements made herein are subject to the penalties of 18 Pa.
C.S. 54904 relating to unsworn falsification to authorities.
Date:
{P1v/?5
, ~
:;t'utCtA ~ J/wve
ITH LYNN SHR
,-.".'
..
VERIFICATION
I, Ann Farrell, verify that the statements made in this
Answer, New Matter and Petition are true and correct to the best of
my information, knowledge and belief. I further understand that
false statements made herein are subject to the penalties of 18 Pa.
C.S. 54904 relating to unsworn falsification to authorities.
Date:
~ /;1,), l'l'/
I I
~ 7# ~~d"
ANN FARRELL _
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Personnel
Training
Agreement
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.j I S I 1/ (,ta----E-'1.kCpCI.se.s-IJ. ~ JLQh.w/{JcK ",,"",,,,,,,,,.... ,'" ^",,,,, M,,".,' I ",,,,,,." 11."" SI,,"'"
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. hCll:illilflt' IdclII:d hI",' '"^rI1hnll''',
WIII:IU:^S. Stutlillln.n ind~'lwllth:llt hmhll:a\ 1"'I.Ullurlt'lIlily,tundlll'l\1I1l ^Ith MUfllIY 1;1.aIH,IIl\\'dlJ.lUte Studiu ulld" iI hilltehi", ur.ub.hllnthi", hlllll^,llnu MUIfOlY
IIIIClllIllillnlll, 11ll:" Illt'ldnllllc, ,c:fCfllt'lllll It\ "I'llulehi.u,", "lii~h SlIIdiu i. lI\tlKilllrd ....hh ulhcf ^,thur MIlIIII)' 1"i1uellilcd 1)1I11'~ Sludin. ill urjuul ulhc. 111""(1; ,"d
WIII!ltl:^S. F..lln:hitllr hilt c"ltlludnl .lUd "lIlllilllll'llll urtOlIIll.lIce tlllll' 1IllllUlltO)' III de\elul' 1111I1 illW,IIIIU it\ frllllehitcn IIIclllI,,1I III ICllehillU dllll~'ill~ 5&11I1 rlllCllli'l1l
rlltfllllllue IIlld (llellillc IIIr Ihc ^llInu MUIIII)' UlI:thlld, IUld ,Iutliut .lIId hOl' Ilc\'cllll"tlOIlltI nlilhli\llI'lllll~lh'I'.b III iUIIIII&;lillll LllU..II01llhe ^,tllllI MII"a)' M.'llnldllll 11I11IIK!iulI ill
1>1Init'illll, ,,'hith lue n"lutili/it'tI b)',ollmrclillll'. alld I" a C1llltit'qllcllte h..tllll.linellII 1I001i1lllWiM Iqllll..lillll 1111 cundlldiull..lltlllllknitina; d..un: Iludimul t1w hi,l"'ll t:hllftl.tcI, 1l11i1
WIII:ItI:AS.lhlllC ..hulue nlll 11Illlilill' ,,'ilbthe Ili\lillelh'collIIl \Illi'IIlC ^llhlll MU"II)' ~h:lh.khullll\llutliOllI iIlIJ""tOinU.U(lCf.lilllllll rrl-C(tluIU,.lIIdtIOlIl~C\IC'p\.hercillllhCf
fdit'IIN hl'l "Arlhul Murfay Mit'thntl.... ncetl e"lellli\'e I,ainins illlhc A'lhm MUI...Y M...II""b hdllle 1111;;)' \:i111(III~'f Ihe ellllllll)' IIf Ihe SludilllU IIllame h"IIULlllr Ul in OIIlCl
ea(liK'ilicl;lInd
WIII:ltl:AS,llune IIoh,1 afe IUlllilillr .dlh Ihe ullilllle IlIId diltllll'lhe ^lllnu ~tllll;l)' Melhutb lIec,1 o;llUlilluina: II"jlliulI ill the ^,lhuI MIIIIII)' Melllulb 1I1l\! illllllleliulI inlh...
Iilletl dUll" ttc(l' IU thilllhc)' can clllllilllle hi 1M: (Illllhlycd hy till: MUlli,,; 111111
WIII:IU!AS,llaillilllJ illlhc Allliur MIIIIII)' M~'IIIIId. "i11Il"'l'enilolle Ih... SllIIliu hi e"I""d lillnilkOlll1 ,U1I111lllh III limc.1II11l\"')'. aud eliit'll:)'; iUld
W 111:ll EAS, Sludil) i, willinG III IrllillIIlId inllrucl ^rrlkill1laml rruviJc ctmlillllillG II i1illinU IIml illllrllctiulI ur ,cllelllcr PIllI fU'lher Iruiuill>>,lI'iUrrwr,illlc:,IU Ihe
^rrlicillll Ulllalit'd illlIl\'~ rruvideJ Arpli"11lI1 htlllml 1111 rfmililllllo ClIllllilinlll, 1I11111elll ktiml' ul Ihi.. uG"'."lIIL'lIll!1lJ lull)' CUllIl,liIO. wilh 1111111: III hl:f\:iIlIlClcr IIIU\'iJ('J~
IIl1d
WIIIHU!AS. Arrlicllllt h, ulIlh:r 111) ItS,,1 irurcdill1('1I1 hi CIIIC'r iullllhi.. ^ltlcClIIenl illld ia Iwl 11Ie',,"'"11)' l:1lI1111l)'C'll h)' ....lIl1chi\ur (If ItII)' ulllI:r Arlhur Murrny
Frllnchi",J Olln~"C' Sludln
NOW, TlIl!IttFOIU!, Studlu .lId Allldiellnlllllfce al lullml.\;
I. 111ill alluf the hutaoina .reillll\ 11m! replit'~nlllliulI\ lire IIUC IIml IIIC mlllle II 1'1111111 Ihi. ^Il'C'l:lIIelll,
1. ^ppliunl'A tmpln)'melll by Slulliu 1111111 "",in
I, ^,lu.n Ap(llJr.nl lur t:'nphl,menl.nd ClIlllinuctl Ilf IlIIlher Iftlining. a\ ul Ihe: Ilale 01 Ihil .1;1"III...nl,
h. ^, tll In Ap(lllClnl fur Tnlnlnl.I1' 111I11I n Ihe ^pplicnlllfini\hn hi. inililll Irllin;n" which hc IIs'cn hlllllll~IIII"'e IInd eumplele ...ithin thlee ll) 1lI11111hl Ifllm the dah:
hereol, AIIII h, deemed 'I,,~liried 10 wu'''' b)' Sludl". '
J. SlUdio aBltCll1I (lrul'hl~ ^(lrIiClIlIlllaininl and ill\lfmlillu In Ihe ^ftllllf MUffa)' M(lhlkll,l) ^(I(llicanl "ill he: 'I\Mlified hi be emrlll)'td by Ihe Studio 1I.11 dance in.lluel"r.
lredllill, inlC'fvicwer,(tlIl11KIIII. .1II'Crvi.uI ,lIIl1nal\cr III In IUl;h tllher cupaciI)' IIr tll(lIlC'i1iu:lI Slmllll dnh':!lo ^(lrli,olllllllg,it'C'\ In at\.'f(ll illld under;" \udl 1IIIIIIIIIIInd Inllruit'lion
IIl1d lIevtlle "'(I(lliunl" bc1.t etrlllll IhClcln, I',iur In Ihe lime Ihlll AlllllltlIlIl fllr 1rallllll& 1.111I1IIifi..tI hi "'III !.,Irlliuinll mil)' hi: 1(llIIilloll,'d dther PlIIII)' "' ill wlilinSlIllIlIY lime wilhulIl
rrill' ntllice al Sludlo\ Orlllln. Kellaldlcu III AprllclIlIl'allle\'iml\ Irainillll. SI\lIlill",i11 r,u..i,lc ^(lpli~olllll wilh 1II1illi"a: IUltl ,01ll11illllluG lIi1illillll by hllllilhill' illptIVI\i"n, ",illen
1I1i11t'llillt.IlOO ;"MiliulIlIlllr n:frClher CUUI~I!lf illllfllctllln, utlbc Slmlilllllil)' Ik~IlII1it't:e\\tll)'. III1Ie"'''hlillltOi: "ilh Ih.. ^lIhur Mllml)' Melll,,,t\.
... Whr.n~ullliricd 10 wnl'" hythe Sludiu, A(I(llicanl'l wUfk Ihllll be ill II c"IMdl)' a, a dillll:e h"tfUl:11I1, 'rcdolli\I, illlit'l\'iC'"u,culIlIlClnr, "1I'C1Vi\tlf,lllilna,cr III ulhc,wi\(, II'
Sludio ilia)' bnlll lime lu limc determine. AIIIIIIClul lur t:lllr1oJlllcnlaGlit'CI hi lemain inlhe Iludiu'lemlllll)' itntllu "tllk fur Sludlll fllr II pcriotluf IIIle )'car 110m IlIe dale ^rrlkalll'l
em(llu)'n1enll:omrneIlCCl. ^llpllcanl furTralnlnla"eCllu remllill in Sludill\ it'm(llll)' fur a pclil"tu' lIine 11I1I1I1h, IlIlIn IlIedllle un \lohi(l! il bdelClluillw h)'the SluoJiu Ihal ^(I(lliunl
ha, llltblactlllil)' enmplelN II1Iininllllnd is tlUllliJied III ....lIlL. ^(I(llicllnIIlCletllu 'it'rvt in 1111)' ,ueh cilrllcitit, Cldll\I\'c1y lur SllIdiu '"ld devlltc hia lime Illld hell dlo'lllo III(h
em(llo)'lClcnl. ^ppliealll 1I;'l:e, Ihlll I'(lm Ihe dale helelll IUld thfPlIllhllullhe lerm uUhi. ^Grit'eIllCIII ;lIId Ihe' h~rm III .\llI1lielllll'l ,elallll"Ihir 1I11t1 elll(lII1)'1IIit'1I1 wllh Studiu, ^(ll'lielllll
will nol tlifeetl)' 01 indifeell)' enlil;e in hu,IlIe.. al' dlln<< in,truclor ur tellcher, aco;epI elll(lIIl)'1I1it'nl in tin)' cllrilt:ilY ,,'hillloc\'er in IllY danL"C' 1c1,ool III 'Iudiu. darn:c lu. hife 01
cllmrcnsalion in In)' nllnner"ivc uhihilinns, in'lruelilllll tI' lectuf1:sll1 dllncinG in illl)' lurm \lihllhoC\'er,lulicil hll\inen fUI ^pplicllnlllr IIn)'onl: c1~ In any mllnnCf fellllin~ III
dllncin'llrdlllee lenonl.dance lCf\'icC'1 llldanit'c Inllrllctilln' ffllm In)'unc, Of hll\'e allY it'onlmcrdaldClllillll,ellnlrael tlr ,elllllan,hir ill ,c'rcellodilndll' "ith an)O (IC'ICII1, filln III
etllrOralilln uct(ll 101, nn behal( nl, Of IIllhe dir"lllln 01 Sludio. ^llrlielllll ao:!.nu"lcdc" tblll a(lrliclInl hll' relld ItI been .dvilcd ul Ihe Allhur MUHiI)' l~rllllehilCd 5<lIuoll ul
Ollncin."Sludinl'uliC')' MIIIIIlIII" Inr enl(lIIl)'CC'1,"d ....iIl \:01111'1)' 'ull)' "ilb IlIme.
S. Slutliu willllni," Iludit'lIh III ^p(lliclull,luunll whclllhe)' alc lI\o.lilllhlc (Ill hl\I.llelilltl, 'olI"hu the Sllldill dcelll' ^rlllitOlIlllll"oIliIiClI hi ill'lllIct, 11uI illU Ihe lerm U, CIIIIIIII)'IIIit'III.
^p(llieont a,n:cS 10 fem!er ICrvices bereum!er un In boudy and/ur lellon arlMlillllllClll bll\l\ at IUdllillle tll tliI)' Ilnd 1111 ,u\:h dll)'11l1 Studin III")' dhtl'!.
6. Studio Ihall (la)' A(I(llieanl lor Arplieanl'lUf\'it'csllln empl'l)'ce ,nd ^rrliunt ,1'0111 Iit'"pt III lull rl)'menl IUI all cmplu)'CclCfl'iccs Ihe hourl)'or leuon I.u&hl rain and
eommiuion fain a, IdvllCd b)' Ihe Sludiu Ind III Kt fllllh In the wIllIen pOlm(lhlel iutttd b" Sludin, cntltltd "ril)roU". ....hleh hill been m.IIlJc I\'aililble 10 ^r(lllunl by Sludlo OIlId ",ill
remain IIvsll.blc al all lullue Ilnlcl IlIr in'rectlon hy ^(I(llicalll. NlltwilhJlandins IIn)' r' J..i,iulllhel'tlll it'lJIllllillit'd In Ihe conlnU)', the Inlill it'nnlrcnllllinn (loIid IlIlhe A(I(llicanl .hall
he nOlle.. Ihlln Ihe lIIinimum n"ed h)' II1IY lederill.llllte ur luclIl minimulll "'lIlte !;tW Ill(llicllhlt !tl.udl it'mplll)'rc. II i\c"rrcnl)' IIndCl,hll"llInd aSlecd Ihal In lIt1C\'enllhOlIl any
cumptn'lllilln ofllny IUlm be (laid hi Appllclnt for Tullllll&lol tuillinS IIctivilic\ (llil,f 10 Ihe time ..'hell ^prliu1I1 h qmllirit'd .lIId dimlit'tI h)' Sludio ItI,,'u,k. hlltrtlel, urdifccl,
7. Termination 01 ^(I(llieanl's I!mrlu)'menl: Our in, thc peliod nl ^rl,~:":)nl'\ ";'lplll)'lnCIlI ilnd ill 1111 limn hc,nllel, SluJilllllll)'diKhlllSe "rrliean, Ind/Ilr lerminlle Sludio',
lelationJhi(l \~ith ^r(llicllnl whcre ^p(lliealll\ f1Clloln'lIl1t'e 1\ not 10 Ihe ulilllltOlion IlISllIIlin. ilml ^p(llkllnl a;'it'e.I!l;lllucbdeci,hlll ,hllll be finlll.1Id bindin., At Iheu(lI'lIllulI ul
^(lplkUl\t" initial lerm 01 em(llllynlclIl,lhi. ^,Itemcnl ,hllll be lIUIllIlI;llkllll)'e,\lentkd :lnd ('Ilnlhlllit'd rur hi.w"!.I)' I'llilld. unkuor llnlilmmillalcd h)' 1*11 (2) "'ceb wlillCn "!llict
IlIIm eilhel rllrl)' llllhc IIlh", (lany It)' legi'lelN ,Ir ,....lllfin!lIl.1ilur IlIltel\l"'. ;Ullllhi. AlthoCIIII:1I11hllll ~U\'Cl1llhc IClaliulI\hir helw~~1I SluJiu ..nd A(I(llic..nt. Nulifiulinn tlr
imnlctliille I'tSiSllllill1l .Il;all be dit'CIIIN Siven hy ^rplk.ullln SlOoJill \hulIloJ ^rllliellnl f..illu 1((11111111 .III!. Olio ICh~..luktlllllllllY Ih,c(' cllll\Ceull\'\: lIa)'l. Shllultl A(I(lIi':iUII'1
relilliun.hir ur e,"(llu)'llIcnt willi Ihe Sludiu he illtellUrltd/letlllinllled flllllllilllc lulime h)' lIclillln III dlhcf Ihe '\(lrli"illllIII Ihe SIUtlillllllJ ^prlicant lull1o"luellll)' 'Cllt" \ his
rclO\lilll1\hir nr elllpld)'menl wllh Ihe Sludio Ihil ^aICClllC'nllhilllllelivale tu rull 'U1"e ilnd erlit"1 andlh..Ult"\(lnlhc rdlllhllnhir lIel"'"1I SllIdiu IInd ^rrlic.l1Il. An)' rcfit'lcne~' IiCltin
In Ihe"lermlnllllun or ^rplieant\ cmpln)'ment",hnll include Ihc e'''(lifilliun ullhit' IC'1II111 ^(lpli\:lIl1t\leI;lllllll\hir am.I/11I ~nlrlll)'melll" ilh Sludi"a' "e1I"1 all nllier ICllItillalll1R
n' lueh Iclllilln\hi(lnntl/ur em(lltl)'lItcnl, 'olI"hc:thel Ihe IC'fIllinilliulIl\ C'au\C'd hy ^(lrlieanl III b)' Slullillo
II. Urml Ihe ICflllinaliun Ilf Arrllealll\ cm(llu)"lIIellt, ^prliranl Ih;lU ""Iit'IIt1er III SllIdiu all naillit" Ilf 1i,1', inclmlingdllplirale !i\II,lIr MlIle\.lIdd,tlltlllnd (lhnne 1111mbit'll ul
'ludcnh.l1nd InlnlCf '11I11ellll and IIllllulelit'nncefnin>>c.r.1llinC. rlll'(lecli\e Ilf fUllller ,llIIlelll' tlrlbe SllIdillln rUl"",iun "' under Ihe nmlrnl ul ^(llllit:.1nl,lilccthcl ,,'ilh 1111 fll,llI'
and 1"l1Id, IIf Stutllu III ^pl'!iCIUlI\ rn"t"llInm lUulc. ^pr1icill\t\cunllullllltl 111111111111 u"lht'ilme.ur all)'Olllhc IJllIe, 1m ^rrlkillll'IIl"'1I benefil mll1lhcllit'llllIIenl 1If (lruhllhlc
tlcllimcnlul SllIdiu. l'riurll),II(llIlIllnd allcr l(rmllli\lh1nul ^rrlit:alll\eOllllu)'lIlellt,el.'T(llln clIRll(cliun .'ilh tll( rendelillllul ^Pllli."illIl'.ICI\'io:nil. (I,uvidttJ hercin, ^r(llil'ilnl
,hall nllt Ult IIny hllnrmalillntllUnlt'I\ICtlln Ihi\ 1'.fll,II(lh rut ;In)' rlllrUlC, int:lm1inl!., hili lIullimilelllll,lhe \ulieilllliun III (mllllllcU II' \Uldenh "I Slllllillllr Frilnt:hi\l" ,'II \cII.liIlW
ilnnUUlleCIlIt'nl.. 1III1Ieh CII\lulUCn Iff .tllllcnll rc,:udinll ^111,!l"1I111'1 ,uh\lOII"e'nl L"llIrIU)'IlICIII. il all)'. Villlalilln u, IhC' C1l\'tlllllll h('fcilltlllllll'lIl1lC ctllllilk,"blc, alld iIlC(lOI,..hl.:,
tllImll~c In Ihe SluoJilllllld 1:'lIl1ehl.tll IInd it is alt'"" lhallhi\ l'lII""idCfilhlell;llllol):C,uf al1l1lldclellllim:tI ill11l1unl, ",jllllt'CflIC ill In", nflra.le \tit"Cll, tl,"1:lllil)'. l'lItlemill!. II..m;alle,
fCrUI.uill". anti (I."lllte IIf Ihe ^rthul Mlllla)' mcUII!d1 ami (I"f\.-alm" h-cilll)O, IIl1li.mall)' ill\d inlrll1l1lilUlIIII)' Illlht' tlt:llilucnlllllhe Slu.lillllUtl r,lll\elli,lIf.
9. ^rrliit'nl\llIe!.lIl1wIL,j~C' Ihal hOllltOhi"lr ,ulIl Slutlin lI"on Ifll1rll(llIlY ,i,h,\ in 1I1ltlllllllUdl ,,( th~'IlII1ICfitllllll.1 illl"llllillilllllll1W IIf "cftilller le\'\:ilIClllu ^I'rlkant IIn.ICllhil
^,p.,ce,m:ul.III rallicular, anJ \lrilhllllllimhinlt Ihc I)'(IC nl infllrlllalltlu",hieh 1\ (llIl(lricllll)',\:III\hdclllioll ill"11If IIl11lc \CUit't iIlIlIlIU'it'. ^p(lhCalll..dllu"ktl~n Ihllllhe ulliqllC 0111.1
1II\Iinelhe ^lllulf P-ohlffll)' lIIC'1hud\ 11\ In dllnt:\:.. .lCllI.lca\:hilla;, in",luc1illllIlIICt:huilllln.lIII1ILeliIlS ledlllillllu 1I11i1 tI(IC'lIliunllllmf\.~"IIIC\, nlllllC~, alMIC\\C\. (lIIIUK' nlllllht:I\,
rldefen~n IIlul ah,ihti(~ uf o.ludcnll',eU\hlln(f Ihll. (llichl' infllllll"lillll, :lI1d ulhel U1""~lt, "hil-II StlUliu !la\ IlC'\"nlfC'flllillC't1 h)' II,anehi"llllI ilt:lluhe and u~,\:ulI\lilllle rfllplicllll)'
Illllllm"'IlIll. cunllllcllllilllllhtlmtllllfll :1f1,I/m 1111011." \t\:1.:h 1I11e' "1'wln:lnllnfllllllOlh.IU"I, ^pl'liellllt IlIIlhe. ilfLlIU"lcdl~\ tlllll \lleh l'IIlIit'&;'ltd IlIluflllllllun "ill be: "~\'C;lkd III
^rrliCIIllt in cunlidclln:dlllillS hi, Ir"illill.alltl empln)'lIIclIl 1Iit'1"'lllIdl.'l, ~"Idy IUllhc IIIIIPU\it' ul e"..hlinG ^I'rli~'lIlIlltlllru\ide \(f\'i~"1:1 hrICUlld(, IIl1d illldi,lIlcc IIrllll'\I'rlit:ilIU"
lllltlCflilLinp illlhi, ^ltlCC'lIlCnl.
'1^, ^rlllicalllllltICC'llhllll"llhdllllnlllhc lerm ol..ntl nllCf Ihe IClmillillilll1l1f ^nlllic;ItI,',elll!'luvnwn'. fal ^r"liUlll \h;llll'lolIC\'C'llt 1111\' uflll" ""'lrrlc.llt'fI1~"':lI!I'" 1\' I'"''
1~lltc~ (lit'lllIn, li"~ UI e'lllil,yeu'((lII") ill Ihe ,,"Ii"tll): "UIII"' III loht:' h,lI~ilnO\\ III Sluoli',IIIIl.I/UI1:.;Ul..hi\l11 ill lI,cnl\!: III ll.hlU" 101 ~Iq" 0111.1 ill\llu:'lilllllllll)'l'rt)') Inlllher emrl")"I t,'1
SlIIdUI'olI"luIIC\lUlIC' ,lIt.h IllIUflUllllulI hu Ihe "llt."IOllItfll ,lllh,' Sllh!ltt. itlllllhl ^rl,ht'lllll \h.II1IlI1II1\1oo .111)' IIllhc 1'lIllit'choll h,IIIlln.ltilln III ~'ullnl'"li,," "'Ih tin)' hmintn III \(111111(.
Illhu Ihan ill (t1nn('('~lttll 'olI"ilh Iltll I'tnllt'linB III ^(llllkilnl', ....I..icn it\ (lfU\'idttl hl'lCin,
IlI1d
I'lmlL.tl,llUS,\
tllo^," I'. 9t
EXHIBIT "A"
"
A 'III. ^rl,!lnlll "li't'" Iholl bulh ,hUh,U. Ihe I"rlll III .Il.! "Ill" Ihl:' Itlll1llllllltlllll' ^rr1il:lIll1\ cnllllu~IIICIII M"d 'u, . ",,'Iud ul 111I01)) ,)'r.ut
QiO Ihrrul'", ^llrli~lIl1t ,111&11'11I1 di'l"\"lly II' illilill:~II)'~ hili" ldu,dly 0.' I" il nWlllb", lIr 'IIY.bul~IIt" "',lInllllllll", uv 'u)' 1111I.1'~lnllnlllllll.lllln In Ihe
\'11)' In ..hi,,, ShtJiu il 1.,,'lIl\'.J i1nll/llf ".llun M 11Id"" ull.-"oly-I"C' US) Ruin hum Sllkhll,,,III,hcw, i. ,ltIllU" "'..
9l', II i, hnlhu 11111''''''. ill. U'l'ilfldC' Hn\'llIlIll hr,clIllll\'"lhilllllullIlhC' ICflUh.llliUII HI IlIi. ^CltC'lIIC'nllllld 11I1)'~'IC'mllll".lIl1'ltnf Iuk! ul ^rl""'oIlll\ 1C'loIllIln.,I.IlI',"',llh Sunllu,
IInd rllf II rc,iu.J III I"'U(~) )'('11" IIWfl',dtff, ^rl'IH.'lInl thilll 111I1 \'1I111I'C1t 11' Irl foull ill rol'lI,u1rh '1A ~"'JII.ilh(l\,c IlIllII lite Illnll-.n,uf .ny ~Ihrf. ^,lllIU "'llIn)' I rillll:h'\f,ll~..me
SIIIJillllnllC'r ul'C',illinn")' SludlllUf ..lJili;llrd "illl SlluJilll"lht Cil)'. ('lIunl)',11' "'C'lfUl,"lllo1l1 MU'II l.n"~ll\h,^~lllllr MIUf.Y hanchl",J Sllhlin"IC' 1t1C1I1C'd III VlIIIII,1II 1.001Iill', IIr
r"'C'lIlt.rhe(2'1 IIl1lnllllmuW Sllllliu, "hll'hnrrIJr/i'I:IC'lIlrr. A'lhnl htfdn.a 'lu,lill."ollllhatrd ';"llhSIUdlll .hllll hn:ludc.n1 ^~lhlll MU'~'1 Flan.tlll"'d Iblln ~Itllhll "Imh
SluJiu III Iln)' ".alllln.., .1I~'LhIlMu ill SllIllinl.urh '1l~'LhlllJrlllllldlnllllllr.ll'lll unt.tlll"l" "c~'L Inlrll"l 1~llhrn~ur ItU'l'4l1ll1un 1I~'I~lII'lhe SI~dllll h;l' an 1II1!'nl iI' IIn
InJh'illual r'lllllirlllr. rilllnC', III \lnl'lllUMr, Ihrlrllrf\udl 'h,dhultltf hllldln~ allra\1II nnr~I,III" '11J~:1111tclnI1llIhrra\C uf iI rmrll'lIl1un 1I~11I11IIi1 ,"dl if ,ludlUlu, ii' I
flilndli\fr 111 Sllh'''''.Il1dli\C'C' 1111,1" 1111 Allhul MUHa)' hillll:lu'" ur 'Uh.rfllndu,c fll' .uch "lfill.lItd 'lllOhn,
'}II. IlIlhr r\tnl 1I1i11 illI)'I'tIIl1l ,1I001I1illll i1IIY (lfll\'i\illll ill riHllItUlI"" l'A,IJU. tIf '1ellll'C' IIl11ril\UlIOIhle 11\ In lime II' luu.lhcl'u,...n.UlI ,1I..IlIC'fIlain tllfll'<<'oIl1lr lIlh.f the rUlIIl
\Iudl d~'ltrmint "h"l i\ ftJ\un.lhl" Ulll! tllr'l"\, '111:11 rru\i,illn ill iI ltilUIII;!hlt f.l\hilln 1\ 11111I1I>llllIn, \Cllrr, IIIC'J, "'id Ullltl.j\t.
10, ^rrli,.ltlll ,11'111 nrh'r, II' .Ito~.ti",.. 'Ifl.., II""""";"I'!IIIII'I '!'I"ll":III", 1'1"I,I,'~III1'nl hlll,1 '\ntoli~';UlIIIIII III alhrlli\l' fill hll,in!.'~. f1111pn'I",I" h,ninlt he'tfl IUflll(JlYI'unnr\'h',I
_lIh Sludlll. Flllln'hl\lIr,,,")' AIIIIl., MII".I)' Ifilluhi\C'd 1101111"1' SlUlhn 1'1 S,hnlll UlllII)' ",IiOlllnu Ihffrnl. hlll,1 AI.rhl.....1 nm in lun'III,I"IIa:llllIIlhC' AllIn., MllllilY nn:lh"d U,.11
Itaclllnllllll~ Alllinr MuftllY 'It It. ur i1'OI'I)' ntllr, "'01.' ";lri',IIi" IlIllht 110111I1' urSlUlhn ~,ul:U1 r,.llIdli,,11 III '\rllli"oIlll""lIl1tln'lillll ,,'illt IIf C'lIlfllu)'llltllllnllll' A'lliltl MUlI;I)'
1)'\ltm.
1 f, ^prlil'lInl rlllml"" III1lJ \'''"1f0l\'1\ lIulI" holll'flli/t ,,'ilh '1lhll'lIh Hf 1111I'1'C'l"1i\'t \lIlIltllh IIrtht' SllIIliil iwd 11111 In ;I((t'111 U1uniC'l.llIilIII.a1I1i1Ii1l1lel'l. II' Ihlll"'" ".Ihl': fill
^rplil'lInl',an""lhl dlllin'llIt' Irllll IIr'tllr "",I In' illl(lillll'II'''1I (~I H'.I" tlrlrllhe lC'flll IIllhl, "111111"".
J1A. Thll ^.mmtnl ,hIli ttc drtIllI'IllIlIhllllllllL"ltll)' lu",.nllrtJ hi ilk'llflltlllllr pll "k'h SIUllill ,ule, 11111 '1'8111011111n, IIt,cill h)' rl,lue IIr ^pplittlnl'll'llfllillucd tlllrlll)'llI.:n.
hC'ltllllllfr. .1111 lit _ilhllUI r""linllulI' I'lhldllYlIlrllllulf ill r.l\C' III tllll,IIl)lIIrlll hUllllillK' Illlirn~ II' IIrrlllrliillt. "illllbc l..nM: rllln Iond tf(n1 .. ir lilt)' "'err rUlll.1I1C'11 hr'rin,
11. !hudil)ur It,Jnl,nrf filII)' rhuhl"arh, mnl.PlI 1e','ulIl Arllli':1I111. IInd Sllldillnllll/m I-"lIn,'hi,ullIlay fUlntr II'. ^1'rliulll\ IlItltlC. rllllllllll&lrli, mlll'.lld 'tL"lIl1lill'\ ill
ennn"llun _itll A'II.." MII".Y IId"tlli\11I1 11111.1 rllblil'il)' h)' Sllllliu 111111/,1, f:fIUll'hiuu,1I1 il. 'lIh\idiilllC', Ind .lIilialn. whelhtlll bedil"lly II' indiln:t1)', .ml "'llrlhtl il hi' fur .ht
laIc or d.ntr !runnl, dllm..- wr"inl, r'"dll"11 or IIIM"rl....
It Arr1kanl htlth)' .1l.'Lnllltltdan IIIJII:'lIn,'hl,"r IIwn' "rf!;llIllfillltlllillh IIn.1 """ll'c fllarLI ,,'IIkh.,t lirtn",d In SIIII"n (ur 11\1' In rUllntdllln "illllh "11C'lIllulI. Arplir.1111
(ulllrr III.'Ln",.-ltd,.., Ihlllll" Iradrllllu1t, ",,,'ke IIIl1lh lI1ld ClllltI_iIlIlUlII'illlC'III"rkwilh 1I1r Iht eulil\irt p'lIJl('f1)' ur ':nndliulr. ArrlM;alll .hilll nlll. dUfin. II.e Itfm _I(
Arplltanl\ tmrlll)'nltnl.llli1in In)' u(lhe IllItltntalL, III ""riLe mOl,L. ullln)' IInd 1111 ",Ullt\ rnn(llIin,ly .Imilil' 11IC'ltlll. ellt'\'pl in ~U1d;llk'C wilh Sllhlill" ir..I'lh:llun., 1I1'4111 0111.1
aflt' Itlminatlnn IIr Applirll"t'1 tntrhl)'lfIfnl, Aprlit.nl ar'rt. fal Indilrunlinlle inuntlJllIltly 1111 ulili/aliun IIrlht Uadtmarh Ind lI',,,ke IIl1l1h lUll' (Ii) Ihal he Ihlllllllllll\l' 1111)'
IIll1er Iflfllr,!,:"L nr w,,,jn ntlt,L Ihlllmi,IIllnlrl)' IlIlIn)' flt'''UlIllr tfllil)' lIull Arplka'll il 'IiII rmplu)'ttl by ur ,'lIl11ln'l"d In an)' WII)' wilh Sludlu 01 rrllnl.'hi.ut.
l~. Arrlil'lInllleLlln" INI" IIIlIlla) I,'rllnchi'nr .._lIlcur)',illht, In; IIl1lfllillin,aid., maIllIOll., 'yllllhu",.. t\iIllL, IInllllllltl..,lllrn mOllr,lalt. mill,. pJmlllllllfphl,I"IlIll, IIntllillt
dlll",lnlt'; III111illlllld/II' lIudill's'i\llilllllillrfi..I\; .lIId Ifllrllit\ 11"'11 illlhe nrtfilliun u( Slllllilllllll' "C,III"!ldlh'll Malttinl."J. (II) Sllldin I, lIullllllhtlf IIy r'llrn:hi'"r III "'I\' Ihe
l'nrYII,hle'd Mlllrrial, In 1'U1lllllk'lllIll .illl ii, 11111'101111111' IIl1d fl') 'Udll'UII)'fia:hl,,,t M,lltti"l, Itl,' rrnrill,'lllu ^rrlkllnl illl,aininn aud IUtn..hle hillllll 'tndtllC'"I~"(, hC'frunJrr.
Arr1itllnl ,hllll nullllVC' Iht ,1,III.rilhrr dUlin, Iht I",m IIrlti. rmr1n)'lIltlllll' IhC'll'lIrlrr.lurllll)'.lihn.llIpc.llr '"II"klUl''' nr Il'ifS"'llIhll' In IIn)' m..lu",r.ehllr, in 1'-11 u, "hll"'.IIII' ur
Ihe C"r),i'"In1 M.ltrl.11 111 IC1 lilt Iht Cnr)',i,hlN Mllltli.ll, III ('Italr IIny _IIIL Ihlll il luh\lallllally ,intil." Iu .ueh l"f1r)'IIShltd Mlllr,lul.. "rullltlllllllllllun lIt Arplklllll"
rnlplll)'mrnl. ^rplicOlnl ,11l1l1 sufttnde".. SlUdill all,"dl Cur)lilllllN MIlIr,ial., "idrn. fill1l,rrrfllduclluu"lllll',u\Cmhkd millel illl, in JIlI\\('\\iunllr until" Ihtcunfrulllr ArrllL"ilnl
and ,11:"1 nulll'" Ihr '1II11e. AIIl"ur)'II,hlC'd MIIIl',i.d. alld ,'upit, IIr Itrflkhll'lllIu, Ihrftlll \"..lIlrlll;!;n nllllllimr, II... t.dll.;"" r'"Jl('lly 1I( I-'rlllll'lli\n"
I'. lht l'ilIltt. Ilt'ftln Ie',"IFni,t IlIiI' i"rrolrll..lC' injlll)' "'ill le\l.1I111 SllhliulIlIllfur r:'lIn~"i'lIIllt IIK'r\'tlllu( iI hfC';I~'" "I IIIi. "'J;'trlllrnl")' ^rrli"lInl ilnllllClte 111111;11 .lIrh C'\tul
Sludio .nd/llr 1~llIn,:hi.nr ,hllllllttnllllC'd. ill udllililln 10 I1l1ulhtr 1~'lIlrllit\ hlld Jillllat."\ 111I11 __jlllnlll 11IIIh", rrunr nl Illnlltl.")',,, imlllt"illll'JilIIlIIJt.lulfll illlmt'llilllt Injunc'!""IU
'tlllpln Ih,. \'lnlaliUIl htlrll(lIy ^rrlkllnl.n.11I1I rculIIlIllelill, rur "' ",ilb him. ArrlKun. ,111111 ray allrll\I" fra.lIllllhlr i1ll1l1nr)'ll", 1IK1l1thrl rlrcn"" rilkllll innlllrd h) SllIlliu
IInd/o, r,.nehi.ur in rnrllrrin'llli, A"n'mrnlur IInYllrlhl' Irlln, lhrfrnr. hUlhrr. Arrli"lInl.,rrn In rus'lI ruJrlil)' lIf Jl("(llrlll..nn: 111'",1 in IlIch 'e'a,unllhlt IInllllllll ii' SllIdiulllilY
III Iny limt rhluite.
16. JllllllrMJ hy Ihr 11"'lin hrrtlllllllllll~ "lIll1turlraillinCIlli&lr,i;l1 IIn.J Ihe in.lnH:lilln lInll ,uJl(',,'hinn nlallt nllil..hle In Allplir;lnl (OIl tU~flb Ihl',um IIrr.llllllllllilnll fhC'
fJunJ,rd (12.5011.011) nulli,", Mild Ar,..lirlllll hr,(hy i1'ftn lu rilY hi Sltlllin "'1.'11 i11111111111 nl i. rllui\'illtnlln SUhlill\ iI,'IUlIldIlRlllCC" ullbe "111I u(U,5110,')lI, "hil.'hn-rr it G'talrr.lu
rilrtl.lI)'comrrn'i< Slwlll (IIIIIIC' rlIlI or \l1I'h I.ainin, 1II11'l'li:d\ IInll in\lnlt'linll tInll Arrli~'anl h,,\ hC'"..illldrli""ftd luSIUllin:l dtmud nllle III r\'rllllille in Ihe 11111I u(U.51lO,no
In nidrntt Ihe minimlllll u( lurh IlIdl'hlttllK'\.. 1'lIwner, ir Applicanl.hull f'l'lfu.1It IInd I"lIm,..ly (ully .ilh 1111 lhe Itlmlllrlhi'.'h'fflltnl.lIlld IlK' 1""121 ~ar I"II\Tnanllht,rllflu.
Ihtll "rnn luth full Jl(',rlllmllnfC' 11II..1 cllmrlilln'~ SlltdilJ aCf"" hH:an'TlllluJ di\tlla'le Ihe null'. ()lIlhco 1I1hC', hallll.ll",h IlUlt ,hall he dut 11111.1 Plly..hlC' IIrnn delllitlld '1lUnwillC illlY
drr.ull undr, fit hteah ur nlln'pc'f(ufln:II",~ u( IIny II( Iht lellll' IInd cllndiliunl Ilrlllil ^Illrtl,lrnl h)' Aprlirllfll.
17. In IlIco cVC'nl jll"irhd lIelllln I, ntn'''lIf)' (IIr Iht InlC'rprl:lillilln III rn(II,n:nlrnl.., Ihe rw,'i\lulI' \II cunnallh cunlainnl hClein, lai" jlhllri:!llKlilln ,IIall hi' m..inIOlinC'\J IlIlht
enllll. urlhr l'"unl)' IoInd Iht Slalt IhillllK' SIlI.lin i. 1'\('lIll'll in,lhe \anlt 'liru1ilIN.1\ Ihco rla~~uf ~1(fIIman~'C. and Ihe r1l1lin 'K'lth)'cnnK'lllln 1'C'"unlll jllli\dicllIlII..nd H'lllle in
'ucllrlltllm.
U. All prunutlll\ ..,,'\I ill iUl)' ~IIJlo'r .IIall illduJt: illl ~..II.I~.n.lIl1d 1111 """I. illlht ,ina:lIll1l1UllIhtl \h,,1I include 11Il' 1'111.011 ud .'ire 'Tn... _hCM"'" Ihco ^11l'fllltlllsn f'l'flllih.
19, The rrn"j,illntuf Ihi, I\81"lIIrfll ale \t\'t'lahlt.lllln)' jm1a:tmrfllll'I'UIIII Illllrr ,hallllrd;ut lIny rlm'i,illn IIf rrn,i.innt u(lhis ^crrtllltnlln\'lIlid IIr 1Il1tnrllr'C'l'lIhlc,lht ulllC'l
pfP\'I.iun, shall nnl he arrmed Ille.rh)' lInd .hOlIl,tmllln ill 11111 rlll\'1:' 1111" tlrrl.'l.
20. Thi, A"rrnltnl .halJ Inu't hllhl' htnrfil n(.he IlC'i,.. Itru'\C'nlali\"'1, "lr",\\ul1l1nll a\\itn. lIt ArI11ic;IIII.lhe lIei... ,tr,nrnlllfi""" .lt~'rn"'" and 1I\"~n' III SllIdiDllnllln
^nhur Murrll)' Inltlnlliun..l. Jnc, and ill 'Urn""'" lIr anitnl.
%I, TIII~ Ar.Rf.I:MF.NT IS ~,^,lf: IIV ^NIl ~1l1.l:I,\' RI:Tln:I:N TIll: III:IIW/ NAMI:Il llWNI:Il 01' STIIIIIO ANIl AI'rU/"ANT. ANIl Arl'U/"ANT
llNn.:nSTANOS ANO AGII.:.:''t TlIAT Afll'I.ICANT SlfAtI.IIA".: NO flWIJTS ANn SIIAI.I. NOT ASS.:UT ANY (".ArMS 01: ANV HAlllfl.: \\,IIATSOt:Vt:1I
Ae:AINsT ARTlUI" MURRAV INn:IINATIONAI..IN('.. In:RI:IN In:n:llln:n Tn AS "J:flAN(.'msou-. OR ITS O,.....IC.:IIS. nlltF.CTOIIS 011 t:MrI,OVU:'t;
UNO.:R OR OY VlltTlIF. 0I:T1I15 AGR":t:,.U:NT 011 OTlU:II\\'IS.:. AI'N.ICANT J,'lIl1T1u:n AGln:t:,t; TIIATTln: rJlOVISfONS. IIF."TIII(,.IONS, 1'1I0MISt:,t;
ANIl COVENANTS TIIt:nt:IN MAn.: OV Arrl.IC'AN'r 1'0 STlIllln Ant: MAnt: OV SAm AI'rU('ANT I"UII Tin: nt:NJ:I,'IT 01.' AIITlllIfI "'"II1IAV
INn:nNA TIUNA I.. INC'. AS A TIIIII n rAIITV n.:NU'ICI,\ IIV AS \\'.:1.1.. ANn AIITIIIlII MIlIIltA \'INn:IINA TfONA I.. fNe. SIIAtI.IIA \'t: 'nu: IIIGlllTO blllNe:
ANV Arl'IIftI'IIIAn: U:(iAI.ACTInN UIII.:(:'tl.V '\(iAINSTS,\ln .\I'I'U('.'NTIN OIlln:n Tn 1.:NJUlN ANY VIUJ.Al'IIIN U111'IIJU:AU:N.:n VlIlI.Al"IUNHI.'
ANV OI:TIII:: l'IIOVfSIONSllU:,.,TIIIC710NS,I'1I0MIS.:.t; ANn (:O\'.:N.\NTS 0'" TIlt: St\1U AI'I'I.f"ANT ,\S STATfn lu:nt:IN.
lJ. TillS Ar.JU:UU:NTMA v nr.CANct:I.I..:n "\' MAII.lNe: HlI rn:un:IIINr: \VIIITn:N NUlnU'ATlON TO C'ANn:I, Tilt: M:Rt:I:,.n:NTTO nU:STllIlfU
MANAra:n \VIlIUN TIIIU:.: DlISINJ:.t;S 1)..\\'1' 1:11n,.. 'nu: rMn: (W TIllS Alall:UIJ:NT,
IN WITNt1's \\'U.:Ut:IW.lIl1'lliI'lltllk!fl'ln Im\l" h\'I"IIIIII"1 "'III,,'lt 11011111, .1Il11 "'lll"
Arl':~"7i(.._..
fll:ANl"un" IIAN"I~!ll\IIIU'
.. FOR V Al.lIE R ECEIVEIl. nndemallll.)rrurni.elnl...yTlI.oTholl.allol Fh'e III1I1o1reol nnllar<
($2.500,00) 10 ,\. <.::. \J(~~_-"!~n:!'!ly~r,- oI/h/:. all Alnll IIR M 11llllA \'" FllANCIIISEIl IlANCE STIIIlIO OF
.L..e^"R.'{fl/t.,_td, 'W/6tdl\ltIl.Ctf.al ih rrincirle "lace inlhe alllll'ecilY.lI'i1hnlll inlere'I,)n ense,"il ,hnll he hrollghl [nr
Ihe collection hereor, or Ihe !l:Imc hns In he cnllccll'd uJlllllclt.:m:Ull.l Or:lll ;llInUu.')'. In 1'1:1)' rC:lsnnnhle ulforncy's rees :Inti
inlcrc~llhcreu[1(ln rur mnkinn such cnllCCliulI. This Nnlc shull hc lIc~nliahlc [1url\u:lllt In [1nr:ll;r:ll,h 1_(, nr Ihis l'crsunnl'l
Training Agreemem, anol inlere,i shalll;e "ayahle al ;he rnaxirnllrnlall'[1I1 rule n[ in,ere'll'errnilleol hy arr/knhle IIsllry
I:lw~. now or herc:l((cr emlclel'. when lIel11:1I111 shall In' 111:1111' fur raYll1cnl.
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WITNES~:
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dlllt'I'" ^"IItu, ",_".,. .-"lKhiwd U.1Irt S,IttlIP
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A.Jd""n'SllIoliol
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
LON C. SHREVE,
Plaintiff
NO. 95.3318
v.
CIVIL ACTION - LAW
JUDITH LYNN SHREVE,
Defendant
CUSTODY
ORDER
AND NOW this 1'1" day of July 1995, after consideration of Plaintiffs
Petition for Special Relief and Defendants answer to Rule to Show Cause, It Is
hereby Ordered that 8 heeRRg 13e h..ld VII 1116
day of
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Date:
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AnOANEY AT LAW
1350 FISHING CREEK VALLEY ROAD
HARRISBURG, PENNSYLVANIA 17112
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. qS- 33/g ~"vlit;tt!It"''\.
v.
CIVIL ACTION. LAW
JUDITH LYNN SHREVE,
Defendant
CUSTODY
ORDER
.
AND NOW this 20 day of June 1995, after consideration of the
foregoing Petition for Special Relief It Is hereby Ordered that the children shall
not be removed from the jurisdiction of this Court. oft Iii fur:tber Order:ed tl:lat tile
plalflUff ahall h6yg 16"_1)01017 ",u~ludy orth~ GhildrsA. '~A88Ia ~I. St:lrS-J8 sRd
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BY THE COURT:
Date:
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
LON C. SHREVE,
Plaintiff
NO.
v.
CIVIL ACTION - LAW
JUDITH LYNN SHREVE,
Defendant
CUSTODY
PETITION FOR SPECIAL REUEF
AND NOW comes Lon C. Shreve, by and through his attorney, Gary
Lysaght, Esquire and respectfully Petitions this Honorable Court to grant Special
Emergency Relief for Custody. In support of this Petition, plaintiff avers the
following:
1. On this day Issues of Custody of the minor children, Angela N. Shreve
and Stephanie D. Shreve have risen.
2. A Complaint for Custody has been filed however, a hearing has not yet
been held on that matter.
3. Defendant, Judith Lynn Shreve Is leaving this Courts Jurisdiction to the
State of California on June 24, 1995.
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4. Defendant, during her absence Is placing the children In the care of the
elderly maternal grandparents until such time that she will retrieve the children.
WHEREFORE plaintiff prays your Honorable Court to grant him temporary
custody of the children and Order that the children not be taken out of the this
Courts Jurisdiction until such time a hearing Is held on the matter.
RESPECTFULLY SUBMITTED:
~
1.0. o. 39183
1350 Fishing Creek Valley Road
Harrlsburg, PA 17112
(717) 599 - 5320
ATTORNEY FOR PLAINTIFF
, . ,
VERIFICATION
Subject to the penalties of 18 Pa. C.S.A. at 4904 relating to unsworn
falsification to authorities, I hereby verify that the statements made In the
foregoing document are true and correct to the best of my Information and belief.
Date: ~ 1'1, /99.5"
~~
LOn C. Shreve
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JUL I" 1995
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1350 Fishing Creek Velley Road
Harrlsburll. Pennsylvania 17112
(717) 599-5320
Teletax (717) 599.5821
July 12, 1995
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Lawrence E. Welker, Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
--------
-
RE: Shreve v. Shreve
No. 95 -3318 Custody
Dear Mr. Welker:
Enclosed for filing Is the original and three (3) caples of an Order for a Hearing
and Plaintiffs answer to Defendants New Malter In the above referenced action.
Please time stamp two caples and return same in the self addressed stamped
envelope prOVided herein.
Your attention is appreciated.
c;Jtr 41- ~J/~ ~ ~~~~ 7~~
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GARY L YSA~~T
ATTORNEY A~ALLEY ROAD
13&0 FISHING C~~:YLVANIA 17112
HARRISBURG. PE
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANI....
LON C. SHREVE,
Plaintiff
NO. .fJ.5"33/( ~~
v.
CIVIL ACTION - LAW
JUDITH LYNN SHREVE,
Defendant
CUSTODY
ORDER OF COURT
You, Judith Lynn Shreve, defendant, have been sued In court to obtain
custody of the children: Stephanie D. Shreve and Angela N. Shreve.
You are ordered to appear In person at ~("1 W, M...'." ,51, ,f\Ir't' h"" I "'~
on Jv..c,), I ,at~o'clock 1.m.,for
v--; conciliation or mediation conference.
a pretrial conference.
a hearing before the court.
If you fail to appear as provided by this order, an order for custody, may
be entered against you or the court may Issue a warrant for your arrest.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU CANNOT AFFORD ONE I GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
OFFICE OF THE COURT ADMINISTRATOR
4TH FLOOR CUMBERLAND COUNTY COURTHOUSE
CARLlSLE, PA 17013
(717) 240 .6200 ,
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~HE COURT:
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
LON C. SHREVE,
Plaintiff
NO.
v.
CIVIL ACTION - LAW
JUDITH LYNN SHREVE,
Defendant
CUSTODY
COMPLAINT FOR CUSTODY
1. The plaintiff Is Lon C. Shreve, residing at1112 State Road,
Duncannon, Perry County, Pennsylvania 17020.
2. The defendant Is Judith Lynn Shreve, residing at 115 South
Washington Street, Mechanlcsburg, Cumberland County, Pennsylvania 17055.
3. Plaintiff seeks Custody of the following children:
Name
Present Address
A;e.
Angela N. Shreve
115 South Washington Street,
Mechanlcsburg, PA
Stephanie D. Shreve 115 South Washington Street
Mechanlcsburg, PA
The children were not born out of wedlock.
4/10/85
3/24/86
The children are presently In the custody of their natural mother Judith
Lynn Shreve I who resides at 115 South Washington Street, Mechanlcsburg,
Cumberland County, Pennsylvania 17055.
Plaintiff and defendant are the natural parents of the children.
Plaintiff and defendant were married on December 1,1984 but have since
divorced on Aprl17,1988.
..."-'...~'-
4. Plaintiff has participated as a party In other litigation concerning the
custody of the children In this court. However, pursuant to their divorce the
Plaintiff and Defendant entered a Legal Separation and Property Settlement
Agreement which Is attached as Exhibit "A."
Plaintiff has no Information of a custody proceeding concerning the
children 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 children or claims to have custody or visitation
rights with respect to the children.
5. Each parent whose parental rights to the children hsve not been
terminated and the person who has physical custody of the children have been
named as parties to this action.
COUNT I
6. The best Interest and permanent welfare of the children will be served
by granting the relief requested because:
7. Plaintiff has temporary physical custody of the children for the
purposes of visitation.
8. Plaintiff Is remarried and has established permanent residency In Perry
county.
9. Plaintiff Is gainfully employed.
10. On June 22,1995 defendant intends to place the children In the care
of the elderly maternal Grandparents while moving to the state of California with
her paramour.
11. Plaintiff avers that he is entitled to physical custody of his children,
while the defendant is unable to care for them.
RESPECTFULLY SUBMITTED:
~~{ t
Gary ag~re
1.0. No. 39183
1350 Fishing Creek Valley Road
Harrisburg, PA 17112
(717) 599 - 5320
ATTORNEY FOR PLAINTIFF
12. Plaintiff wishes to maintain a continual relationship with his children
which would be greatly harmed If the defendant removes the children from
Pennsylvania.
WHEREFORE, plaintiff respectfully requests this Honorable Court to
grant him custody of the children.
L-,
VERIFICATION
Subject to the penalties of 18 Pa,C,S,A, at 4904 relating to unswom
falsification to authorities, I hereby verify that the statements made in the
foregoing ducument are true and correct to the best of my information and belief.
DATE: ~ 1'1, J '19 S-
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Lon C. Shreve
LEGAL BE?ARATJON AND
PROPERTY UETTLEMENT
AlInEEMEN~'
IIIS AlIREEMEIIT, made on this the -d3 day of
p~~ , 19~,
BY AND BE'fWEEN:
JUDITH LYNN SHREVE, hereinafter referred
to as the "WIFE",
A
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LON C. SHREVE, hereinafter referred to
es the "HUSBAND"
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WHEREAS, HUSBAND AND WIFE were lawfully marrIed on the
1st day of December 1984, in Lewisberry, York County, Pennsylvania;
nd
WHEREAS, the parties have two (2) children born to their
~'rriage, STEPHANIE D. SHREVE (dob 3/24/86) and ANGELA N. SHREVE
(dob 4/10/85); and
WHEREAS, the HUSBAN" and WIFE ~esire to be legally separated
.
nd subsequently divorced and, therefore, to determine their rights,
.nd obligations, growing out of their mutual relationship; and
WHEREAS, the parties desire to reduce Bald rights, obligations
nd understandings to writing.
NOW, THEREFORE, Lhe parties hereto, intending to, be legnl y
jl>.,und hereby, agree as 1'01 Lows:
I
Ex.\'ibi f " A"
1st. LIVING SEPARATE and APART - It shall be lawful for
~ach party at all times hereafter to live separate and apart
from each other at such place or places as he or she may from
time-to-time choose or deem fit, and for each to see whomever
of the opposite sex as each may choose.
2nd. FREE FROM INTERFERENCE - Each party shall be free
(rom interference. authority and control of the other, as fully
as if he or she were single or unmarried, except as may be
necessary to carry out the provisions of this Agreement, except
as otherwise provided for herein. Neither party shall molest or
attempt to molest the other, or compel the other to cohabitate
with the other. or in any way harass or malign the other, or in
any other way interfere with the peaceful existence, separate
and apart from the other.
3d. ~IUTUAL RELEASE - Subject to the provisions of this
Agreement, each does for himself. or herself, and his or her
heirs, executors and assigns, release and discharge the other
from all causes of action, claims, rights, or demands whatsoeyer
in law or equity, inCluding inheritance rights, which either of
the parties ever had, or now has against the other, except any
or all causes for breach of any provisions of this Agreement.
4th. CHILD SUPPORT AND CUSTODY - WIFE to have legal and
physical custody of the two childreni HUSBAND to continue to hAve
liberal visitation and temporary custody rights, consistent with
each parties respective work schedules and in the best interests
of the children. Parties acknowledge that given the HUSBAND's
current salary level of approximately $225 net a week, and other
f!nancial obligations towards the house and certain Joint debts,
that it is impossible at this time for him to pay child support
and that the better course of action is to come current on and
keep up payments for which he is responsible.
5th. MOTOR VEHICLES - Both parties agree that each is
~htitled to retain vehicles currently titled in their respective
individual names, and hereby waive any marital property rights in
said vehicle(s) of the other. Specifically:
WIFE owns a 1982 Datsun, unencumbered, and HUSBAND
o~ns a 1970 Oldsmobile and two Kawasaki motorcycles, 1982 and
1~83, also unencumbered. HUSBAND also owns a 1977 Ford Truck.
which has been pledged as collateral for the AVCO loan (see
.
Paragraph 11th) along with various other Items of personalty now
In possession of both parties.
6th. MAJOR MEDICAL COV~~ - HUSBAND agrees to be re-
sponsible for major medical coverage for himself and for the two
children. WIFE Is to be responsible for her own coverage. HUSDAN
agrees to notify WIFE if coverage through his employer (at his
erpense) is not available. Both parties agree it is of utmost
Importance that the children have major medical coverage and If
said coverage Is not available as an employer paid benefit, the
parties will share equally In the cost of providing such coverage.
7th. DIVISION OF PERSONAL PROPERTY - All items of
personalty have been divided between the parties to their
mutual satisfaction.
8th. REAL ESTATE - WIFE is to deed over her one-half (~)
Interest in the marital residence known as 112 State Road,
Duncannon, Perry County, Pennsyvlanla, In exchange for a promls-
sory note for ONE THOUSAND ($1,000.00) DOLLARS payable with
I>>terest at the rate of SIX (6%) per cent a year, no later than
t~~ (2) years from the date of execution. Said note to be
recorded in the Perry County Courthouse. HUSBAND agrees to make
and keep current on mortgage payments to the first mortgagee,
Harris Savings and Loan, and to ind~mnify and hold harmless the
.
WIFE with respect to any liability.
HUSBAND hereby acknOWledges WIFE's payment of TWO THOUSAND
($2,000.00) to Mr. & Mrs. Hayberger toward a second mortgage on
the property. Accordingly, HUSBAND agrees to be responsible for
the balance of that obligation, estimated to be $861.23 at this
tIme, including interest charges and costs associated with a
Writ of ExecutIDn filed on August 5, 1988.
9th. SPOUSAL SUPPORT, ALIMONY AND DIVORCE PROCEEDINGS _
Both parties waive whatever rights either may have to
spousal support, alimony and/or retirement benefits. Both
further agree to execute consent decrees to a no-fault divorce
pursuant to 8ection 201(c) of the Divorce Code of 1980, which
has been filed as Docket N 1078 Civil 1988 in the Cumberland
County Courthouse. instituted by the WIFE, contemporaneOUSly
with this Agreement.
10th. FEDERAL INCOME TAX EXEMPTIONS - The parties have
filed individual 1988 Federal and State Income Tax Returns.
Starting with the 1989 return, HUSBAND shall claim STEPHANIE
as an exemption. and WIFE shall claim ANGELA as an exemption.
each year.
11th. JOINT AND INDIVIDUAL DEBTS _
A. HUSBAND acknoledges the following debts
in his name alone. for which the WIFE has no responsLbility.
1. AVCO, Approximate balance of TWO
THOUSAND ($2,000.00) DOLLARS - monthly payments of $103.00.
2. TWO MID~PENN BANK LOANS - approximate
balances of $450.00 and $1,700.00.
3. NEWBERRY TOWNSHIP, York County - approxi-
mate balance of $700.00 for back taxes on a mobile home lot.
11th. JOINT AND INDIVIDUAL DEBTS (Cont'd):
B. Both parties agree to the following arrangements
regarding Joint obligations:
1. HUSBAND to be responsible for any and all
miscellaneous and minor debts, such as utility bills and other
"house charges" not specifically enumerated in this Agreement.
2. As to the Sears Account (approximate
balance of $2,200.00), the WIFE shall make minimal payments of
$25.00 per month for a maximum of six (6) months upon which time
the HUSBAND shall be individually and totally responsible.
3. As to the Household Finance Account
(approximate balance of $2,000.00), the WIFE shall make monthly
payments of $75 per month for a maximum period of twelve (12)
months; HUSBAND to pick up all payments thereafter.
~. As to the DAFCU account (approximate
.
balance of $~,OOO.OO); the WIFE shall pay $150 a month for a
maximum of eighteen (16) montha. HUSBAND to be responsible for all
payments thereafter.
5. HUSBAND agrees an intent and willingness
to pick up responsibility for Numbers 2, 3, and ~ above sooner
Lhan the maximum times Indicated, if possible. consistent with
his financial ability to do so.
13th. COURT CONFIRMATION - HUSBAND and WIFE hereto agree
that the provisions of this Agreement may be confirmed by a Court
cf competent Jurisdiction upon the application of either party
of this Agreement and that it shall survive any subsequent
divorce action between the parties.
"
14th. LEGAL ADVICE - Each party acknowledges that he or
she has received or has been afforded the opportunity to
secure independent legal advice from counsel of his or her
choice. Each acknowledges to fully understand the facts and
obligations. each party acknowledges and accepts that this Agree-
ent. under the circumstances, is fair and equitable, and that it
iu being entered into freely and voluntarily, and that the
xecution of this Agreement is not the result of any duress or
undue influence and that it is not the result of any collusion
r improper or illegal agreement or agreements.
.
15th. FUTURE OBLIGATIONS - Both parties hereto agree not
to incur any debts, or charge any items to each other or each
ther's accounts now or in the future.
16th. UREAcn - If either party breaches any provision of
this Agreement, the other party shall have the right, at his or
her option, to sue for damages for such breach. The party
breaching this Agresment shall be responsible for the payment of
all legal fees and costs incurred by the other in enforcing his or
~r legal rights under this Agreement, or seeking such other remedy
or relief as may be available to him or her.
17th. LAW OF AGREEMENT - This Agreement shall be construed
under the laws of the Commonwealth of Pennsylvania.
18th. ENTIRE AGREEMENT - This Agreement contains the entire
understanding between the parties with respect to matters
specifically discussed herein, and there are no representations,
warranties. covenants or undertakings with respect to matters
specifically discussed herein other than those expressly set
forth.
19th. MODIFICATION AND WAIVER - A modification or waiver
of any of the provisions of this Agreement shall be effective only
if made in writing and executed with the same formality as in
this Agreement. The failure of either party to insist on said
performance of any of the provisions of this Agreement shall not
be construed as a waiver of any subsequent default of the same
or similar notice.
t
20th. SUCCESSORS IN INTEREST - The terms. provisions, and
onditions of this Agreement shall be binding upon any and all of
he heirs, executors, administrators, successors and assigns of
ither of the parties hereto.
21st. AGREEMENT NOT TO BAR DIVORCE PROCEEDINGS - This
greement shall remain in full force and effect unless and until
it is terminated either by mutual written consent of both parties.
or to the extent it is appropriately terminated by the death of
either party under the terms of this Agreement. The failure ot
either party to insist upon strict performance of any of the pro-
visions of this Agreement shall not be construed as a waiver of any
subsequent default of the same or similar nature. In the event
that the marriage of the parties hereto is terminated by the divorc .
this Agreement shall nevertheless remain full force and etfect, an
shall survive such decree and shall not in any way be affected
.
thereby, except as provided for herein. The parties intend to
secure a mutual consent, no-fault divorce pursuant to the term8 of
Section 201(c) of the Divorce Code of 1980 (as filed in the Cumber
land County Courthouse, Docket N 1078 CIVIL 1988). The parties
agree that the terms of this Agreement shall be incorporated for
the purpose of enforcement only, but not merge, as part of any
decree, Judgment or order of separation or divorce.
"','~'"
IN WITNESS WHEREOF, the parties hereto have hereunder set thei
SUBSCRIBED and sworn to
HalIIIIIStII,.
Donald 8, owen. HolllybWnd . 'lilt/
!Qlp"""'oTownaNp.C~ a~ 1882
101, Commllllon E,,*" ,w., .
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h~nds and seals the day and year first above written, to this and
9 pages of this Agreement, intending to be legally bound hereby.
WITNES~~aliS(L
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BEFORE ME, the undersigned authority, personally appeared
UDITH LYNN SHREVE. known to me to be the person whose name is sign
subscribed to the foregoing instrument. and upon oath acknOWledge t
she executed the foregoing document for the purposes and considerat
therein expressed.
N
My
. 19
Subscribed and sworn to on the
OMMONWEALTH OF PENNSYVLANIA
COUNTY OF c..tl1~
NoIIItoISIII
Donald 8, OwIl1, Nolary IWc
Eat PlnIlIboIo TOWNlip, Cumberllnd ........,Iy
MyCommilllon Eri*MNov. 24. 1392
. lItmw. ....../hllilllaxtdonol NoIuiet
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF (!c.,iHcl~
Expires:
)
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BEFORE ME, the undersigned authority, personally appeared
LON C. SHREVE, known to me to be the person whose name is signedl
subscribed to the foregoing instrument, and upon oath acknowledge t at
he exeucted the foregoing document for the purposes and consideration
therein expressed.
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LON C. SHREVE,
Plalnllff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-3318 CIVIL TERM
CIVIL ACTION
IN CUSTODY
vs.
JUDITH LYNN SHREVE,
Defendant.
ORDER OF COURT
AND NOW, upon consideration of the attached Petition, It Is hereby directed that
the parties and their respective counsel appear before , Esquire,
the Conciliator. on the (4~ da pf ,1999. at
\ \ o'clock ~,m., in \,J, . .
Cumberland County, Pennsylvanla, for a pre-hearing custody conference. At su conference,
an effort will be made to resolve the issues In dispute; or if this cannot be accomplished I 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 shall also be present at the Conference. Failure to appear at the Conference
may provide grounds for the entry of a Temporary or Permanent Order.
BY THE COURT,
c-t<f\h'i'f\. .k." J\}\~l ~.
Custody Conciliator (\1:>,'1
Date: '51.:::ll.\\qQ
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
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County. Pennsylvania. Is required by law to comply with the
Americans with Disabilities Act of 1990, For Infonnatlon 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,
BY THE COURT:
Date:
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LON C. SHREVE,
Plalntiff,
vs,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-3318 CIVIL TERM
CIVIL ACTION
IN CUSTODY
JUDITH LYNN SHREVE,
Defendant.
AND NOW, comes Plaintiff LON C. SHREVE, through his Attomeys, FLOWER,
MORGENTHAL, FLOWER & LINDSAY, and avers the following:
1, The Plaintiff Is LON C. SHREVE, an adult Individual, residing at R. D. #1,
Box 107. Miilerstown, PA 17062,
2. The Defendant Is JUDITH LYNN SHREVE, an adult Indivldual, residing at
309 Hogestown Road, Mechanicsburg, Pennsylvania 17055.
3. The original custody Complaint In this matter was filed by Plaintiff on June
20, 1995, seeking custody of the two children of the parties. ANGELA N. SHREVE, born April
10, 1985, presently age 14 years, and STEPHANIE D. SHREVE, born March 24, 1986.
presently age 13 years.
4. The most recent Order of Court In this matter dated August 15, 1995, is
attached hereto as Exhibit "A", and grants shared legal custody of the children to the parties
with Defendant JUDITH LYNN SHREVE. having primary physical custody.
-
5. Plaintiff believes that circumstances have changed and that It Is now In the
best Interests of the children for him to have primary physical custody of them for the following
reasons:
A. Plaintiff Is more able to provide a safe and stable environment for
the children: and
B. Defendant neglects the children's medical I dental and vision needs.
WHEREFORE, Plaintiff requests that the Court's Order be modified to award him
primary physical custody of the children.
FLOWER, FLOWER & LINDSAY
Attomeys for Plaintiff
..
James D. Flower, Jr.
11 East High Street
Carlisle I PA 17013
(717) 243-5513
I.D. #27742
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I, LON C. SHREVE, Petitioner hereln, hereby verify that the statements made In the
within Instrument are true and correct to the best of my knowledge, Information and belief. I
understand that false statements herein are made subject to the penalties of 18 Pa,C.S, Section
4904, relating to unswom falsification to authorities.
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Lon C. Shreve
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Loo C. SHREVE,
Plaintiff
VIS.
IN THE OOURT OF CXXolMON PLEAS OF
CUMBERLAND CClUNTY, PENNSYLVANIA
NO. 95-3318 CIVIL TERM
CIVIL ACTIoo - LAW
IN cusrooy
JUDITH LYNN SHREVE,
Defendant
PRIeR JtIDGE: Kevin A. HesII
QBIalY ~LIATICN SlNlARY REPCRT
IN ACXXlUlANCB w.rm aJlBBRLAND CXXM'Y RULE OI!' CIVIL (IR::....ulRB
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAHB
DA'l'B OI!' BIR'm
aIRRIlNl'Ly IN QBIalY OI!'
Angela N. Sht'eve
Stephanie D. Shreve
April 10, 1985
March 24, 1986
Mother
Mother
2. A Conciliation Conference was held on Septeaber 22, 1999, with the
following individuals in attendance: The Father, Lon C. Shreve, with his
counsel, James D. Flower, Jr., Esquire, and the Mother, Judith Lynn Shreve,
with her counsel, Joan carey, Esquire.
3. Thi8 Court previously entered an Order dated August 15, 1995
providing for the Mother to have primary physical custody of the Children
and the Father to have partial physical custody. The Father filed this
Petition to modify the existing Custody Order to enable the Father to have
primary physical custody of the Children.
4. It was agreed at the Conference by the parties and counsel that
the best approach would be for counsel to meet initially with the Children,
ages 13 and l4 and thereafter to have a four-way Conference with the
parties and counsel to further discuss the issues and hopefully reach an
agreement. In the event the parties are unable to resolve the outstanding
custody issues through the foregoing process, counsel for either party may
contact the Conciliator to schedule an additional Conference.
5. The prior order dated August 15, 1995 will continue in effect
pending an agreement of the parties or further Order of Court and therefore
it is not necessary to enter an additional Order at this time.
(O~ JJ~
Dawn S. Sunday, Esqu re
Custody Conciliator
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Date .
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cc: James D. Flower, Jr., Esquire - Counsel for Father
Joan Carey, Esquire - Counsel for Mother
C~<<">-(ll~ Cf/?Jo/'l"J.
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IN THE CXXlR'l' OF tnolMctl PLEAS OF
CUMBERLAND CXltlN'n, PENNSYLVANIA
NO. 95-3318 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
LON C. SHREVE,
Plaintiff
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Po"D&,\ufa.t'y 's oa;'r...e
6ep-f.30, /qq'1
va.
JUDITH LYNN SHREVE,
Defendant
CUSTODY COOCILIATION
SUMMARY REPORT
WlIIllIm 1.. ilunbllp
mllwn iI. ilunbllp
l!Illornrp. .at ,1f.lIW
39 Wesl Main Strcel
Mcchanicsburg. PA t 7055
vs,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - CUSTODY
LON C. SHREVE.
Plaintiff
JUDITH LYNN SHREVE,
Defendant
95-3318 CIVIL
IN RE: MOTION FOR MODI FICA TION OF CUSTODY ORDER
ORDER
1,-,
AND NOW, this .;) day of June. 2000, following hearing and careful
considemtion of the testimony adduced, the court being satisfied that it continues to be in the
best interest of the children that they be with their mother during the school year, but that more
time with their father is appropriate, our order of August 15, 1995. is modificd to provide that
from one week after the end of school until one week before the beginning of the fall session of
school, custody of Angela N, Shreve and Stephanie D. Shreve shall be in their father subject to
rights of partial custody in the mother every other weekend from Friday evening until Sunday
evening and for such time as would be necessary to take the children on a summer vacation.
As with all other provisions of the existing custody order, the schedule of custody during
the summer may be modified by agreement of the parties. The defendant shall be given a
reasonable period of time within which to comply with this order,
BY THE COURT,
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James D. Flower, Jr., Esquire
For the Plaintiff
Barham Sumple-Sullivan, Esquire
For the Defendant
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