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ROBERT L. SHEARER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBE~D CO., PENNSY~V~IA J
NO. 1'1 - ?('13 () ~ L4. e_. lL-,V'..-
vs.
KIMBERLY L. MORRIS,
Defendant
IN CUSTODY
CIVIL ACTION - LAW
ORDER OF COURT
You, KIMBERLY L. MORRIS, Defendant, have been sued in Court to
obtain custody, partial custody or visitation of the children, Kira
M. Shearer and Kalie M. Shearer.
You are ORDERED t.o appear in person at Cu~tody Conciliation
2. q W t''\c. '.., <,~. M~ 1,...,. I <~b~').
Office, CumdJeYla.ua Cuuuly C""....:LCli6""'cn::, SnlS SS\lrtn""'LUtt:: !qua.L'WI
o.:,LliB'le, Pennsylvania on Oc \-' C}L.J . ' 1995 at
<6': 'W o'clock a.m./p.m. for:
~ a 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, partial custody or visitation may be entered against you or
the Court may issue a warrant for your ar~eAt.
YOU SHOULD TAKE THIS PAPER TO Y.JUR 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 Lawyer Referral Service
Court Administrator
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA l70l3
(717) 240-6200
~r
:i( THB COURT I
Date of orderl--.::1'V J')I
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ROBERT L, SHEARER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
NO.
IN CUSTODY
CIVIL ACTION - LAW
vs.
KIMBERLY L. MORRIS,
Defendant
COMPLAINT FOR CUSTODY
NOW COMES Plaintiff, Robert L. Shearer, by his attorneys,
Purcell, Krug & Haller, and files the following Custody Complaint:
l. The Plaintiff is Robert L. Shearer, an adult individual
residing at l67 Old Town Road, Gardners, Cumberland County,
Pennsylvania.
2. The Defendant is Kimberly J. Morris, an adult
individual residing at 302 North State Road, Allandale, Illinois
624l0.
3. Plaintiff seeks custody of the following children:
~ Present Residence Date of Birth/Aae
Kira M. Shearer l67 Old Town Road July 7, 1984
Gardners, PA l7324 Age 11
Kalie M. Shearer l67 Old Town Road April 7, 1987
Gardners, PA l7324 Age 8
4. The children were not born out of wedlock.
5. The children are presently in the custody of Plaintiff,
residing at 167 Old Town Road, Gardners, Cumberland County,
Pennsylvania, where they have resided for the past 8 years with their
parents until August, 1993, after which Plaintiff has had sole
custody,
6. The father of the children is Plaintiff, Robert L.
Shearer. The Plaintiff and Defendant were married on January 20,
1984 and divorced on May l6, 1994.
7. The mother of the children is Defendant, Kimberly J.
Morris.
8. Plaintiff has not participated as a party or witness,
or in another capacity, in other litigation concerning the custody of
the children in this or another court.
9. Plaintiff has no information of a custody proceeding
concerning the children pending in a court of this Commonwealth.
lO. 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.
ll. The best interests and permanent welfare of the
children will be served by granting the relief requested. The
Plaintiff is far more capable of providing for the needs of the
children.
WHEREFORE, the Plaintiff requests the court to grant him custody
of Kira M. Shearer and Kalie M, Shearer.
By
re
Datel ~~~~.:J.';l,lliqS-
.- ICrug,
826
1719 North Front Street
Harrisburg, PA l7102
(717) 234-4178
2
VBRIFICA'rIOR
I, ROBERT L. SHEARER , cmIlKU the Plaintiff. in the
within action, hereby verify that the facts contained in the
foregoing CUSTODY COMPLAINT are true and correct to the
best of my knowledge, information and belief. I understand that
false statements made herein are subject to the penalties of l8 Pa.
C.S. Section 4904, relating to unsworn falsification to authorities.
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DATE: 9 / ').. J J 7 S-
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CASE NO: 1995-0509J P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SHEARER ROBERT L
VS.
MORRIS KIMBERLY
PHtLlP BAUGHMAN
______________.____., :-.L(..;fJif '-'f r'.'r';Jt....::L.;-11fr '':'1
CUM8ERL..-AND C,r:unt.y. P~:?nn:,::,'l','anl:j. wt~(' ~~~'l~-I';; -1')1", >""('r:-: ..'-(_'l)rrjlng
t.o l;.)w, says,
tho? "llhHI CSIMP,LAEfI__---':..USIQ:::(
"'~3
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upon. MORRIS KIMBERLY L
t. h'C'
ljefendant., at ::2~0:(,iZl HOURS, C'n the ~;jth rj~.,. '~:f ':~I:-t~~_:.:b~~r __.._____.
1995 al
148 OLD TOWN ROA~_____._________.__,__._______ ___ _____
GARDNERS. PA 17324
:""MFEELAJIL__ _
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5herlfi's Costs:
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ROBERT L. SHEARER,
Plaintiff
IN THE COURT OF C()o\MCX'l PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 95-5093
CIVIL TERM
vs.
CIVIL ACTION - LAW
cuSTODY
KIMBERLY L. MORRIS,
oefendant
.
.
cxxJRr ooDER
l\ND tOI, this I ~~ \\ day of I,\t.c..i",,~\-V"
consideration of the attached custody conciliation Report,
ordered and directed as follows:
, 1995, upon
it is hereby
l. The Mother, KintlerlY L. Morris, and the Father, Robert L. Shearer,
shall have shared legal custody of Kira M. Shearer, born July 7, 19B4 and
Kalie M. Shearer, born April 7, 19B7.
2. The Father, Robert L. Shearer, shall have primary physical custody
of the Children.
3. The Mother shall have liberal partial physical custody of the
Children, as the Children'S schedules permit, upon providing a minimum of
twenty-four hours advance notice to the Father. The parties shall continue
to cooperate with each other in accomodating the Mother'S availability for
,.,,,,, "",todY. """,,"" <he .._ ,hall oot bo -''''' '" "",,,,, '"
forego previously scheduled arrangements for the Children upon receiving
notice from the Mother.
4. The Mother shall also have partial physical custody of the Children
for six weeks, not necessarilY consecutive weeks, each summer to be arranged
by ""... ..,......t of "" "',,,... "" ",<he< ,hall oct "...1 .i'" <he
Children by truck. during her periods of partial custody except for the
exchange of custody unless otherwise agreed by the parties.
5.
followS:
The parties shall share custody of the Children on holidays as
A.
ChristmaS _ the Children I s ChristmaS vacation shall be divided in
half with the first half, "segment A", beginning on the first day
of school vacation and the second half, "segment B", ending on the
daY before school resUl1l8S. The Mother shall have custody during
"segment A" in odd n1.lllCered years and during "segment B" in even
n1.Jlbered years. The Father shall have custody during "segment B"
in odd n1.lllCered years and during "Segment A" in even nUlltlered
years.
B. Thanksgiving _ The Mother shall have custody of the Children on
'l't\arlkS9iving nay, every year from 9:00 a.m. until 3:00 p.m.
C. Easter _ The Mother shall have custody of the Children on Easter
Sunday, every year. from 9:00 a.m. until 3:00 p.m.
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