HomeMy WebLinkAbout02-4511SCOTT SAILHAMER,
Plaintiff
V.
ELIZABETH SAILHAMER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002- y 5• 11
CIVIL ACTION- LAW
IN CUSTODY
COMPLAINT
1. Plaintiff is Scott Sailhamer, who currently resides at 224 Roxbury Road,
Shippensburg, Cumberland County, Pennsylvania.
2. Defendant is Elizabeth Sailhamer, who currently resides at 1312 Hade Road, St.
Thomas, Pennsylvania 17252.
3. Plaintiff seeks custody of the child, Brooke Victoria Sailhamer, who was born on
December 31, 1996. The child was bom out of wedlock. Since the child's birth, the child has resided
with the following persons at the following addresses for the following periods of time:
4. The relationship of the Plaintiff to the child is that of father. He is married and living
separately. The Plaintiff is currently living alone when he is not exercising custody of the child.
5. The relationship of the Defendant to the child is that of mother. She is married and
living separately. It is unknown who Defendant is residing with other than the minor child when she
is exercising custody.
6. The parties have not participated in previous litigation concerning the custody of the
child in this court or any court.
7. The Plaintiffhas no information ofa custody proceeding concerning the child pending
in any other court.
8. The Plaintiff wishes to have an Order entered documenting the parties' existing
agreement of custody.
9. Plaintiff does not know of any person not a party to these proceedings who claims to
have custody or visitation rights with respect to the child.
WHEREFORE, Plaintiff requests your Honorable Court to set a time and place for a hearing
at which Plaintiff requests the Court to grant him the Custody Order. Pending said hearing, Plaintiff
requests temporary custody.
MARTSON DEARDORFF WILLIAMS & OTTO
BY -J- r"744-? Vyr- -
Thomas J. Willi s, Esquire
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Date: September 18, 2002 Attorneys for Plaintiff
VERIFICATION
The foregoing Custody Complaint is based upon information which has been gathered by my
counsel in the preparation of the lawsuit. The language of the document is that of counsel and not
my own. I have read the document and to the extent that it is based upon information which I have
given to my counsel, it is true and correct to the best of my knowledge, information and belief. To
the extent that the content of the document is that of counsel, I have relied upon counsel in making
this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to criminal penalties.
- zi ?? -, -?- -? , _-? Scott Sailhamer ?/`'1.
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SCOTT SAILHAMER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
• 02-4511 CIVIL ACTION LAW
ELIZABETH SAILHAMER
DEFENDANT IN CUSTODY
ORDER OF COURT
AND NOW, Wednesday, September 25, 2002 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, October 10, 2002 at 9:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ Hu rt X Gilroy, s, P
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our office.
All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must
attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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F:\FILES\DATAFILE\Ce doo.cur\10612-aff.sercom/tde
Created: 09/18/02 10:06:28 AM
Revised: 10/11102 02:46:38 PM
10612.1
SCOTT SAILHAMER,
Plaintiff
V.
ELIZABETH SAILHAMER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002-4511 CIVIL ACTION - LAW
IN CUSTODY
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF CUMBERLAND
SS.
I hereby certify that a copy of the Complaint in Custody was mailed to Defendant Elizabeth
Sailhamer at 1312 Hade Road, Chambersburg, PA 17201 on September 27, 2002, by certified mail,
restricted delivery, return receipt requested.
Attached is the Post Office return receipt signed "Elizabeth Sailhamer" and dated September
30, 2002.
Thomas J. Will' s, Esquire
Sworn to and subscribed
before me this // day of
October, 2002.
Cary Public
NOTARIAL SEAL
TRICIA D. ECKENROAD, Notary Public
Carlisle P,,ro., Cumberland County
M .Comrnssion Expires Ott. 23, 2004
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item 4 if Restricted Delivery is desired.
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so that we can return the card to you.
¦ Attach this card to the back of the mailpiece, B. Receiv by (Prin ad Name) C. D e f Deli ry
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1. Article Addressed to: (
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PS Form 3811, August 2001 Domestic Return Receipt 102595-02-M-0835
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Created: 09/18/02 10:06:28 AM
Revised: 09/30/02 04:33:59 PM
10612.1
SCOTT SAILHAMER,
Plaintiff
V.
ELIZABETH SAILHAMER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002- 4511 CIVIL ACTION - LAW
IN CUSTODY
ACCEPTANCE OF SERVICE
I, Elizabeth Sailhamer, Defendant in the ;above action, accept service of the Custody
Complaint and certify that I am authorized to do so.
'0-I' -oz.
Date
--t
Defendant or Au orized Agent
J ?r
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OCT 17 2002
",A m\Ir
NOV 2 7 2002 t
SCOTT SAILHAMER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v : CIVIL ACTION - LAW
ELIZABETH SAILHAMER, : NO. 02 - 4511 CIVIL
Defendant : IN CUSTODY
COURT ORDER
AND NOW, this Z 71 day of L-11 11 , 2002, upon consideration
of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The Father, Scott Sailhamer, and the Mother, Elizabeth Sailhamer, shall
enjoy shared legal and shared physical custody of Brooke Victoria Sailhamer,
born December 31, 1996.
2. Physical custody shall be handled with a 2 week on / 2 week off type of
arrangement. The parties may modify that arrangement as they agree.
3. The parties will also work between themselves with respect to sharing or
alternating custody on major holidays, the child's birthday and other
important days such as Mother's Day and F'ather's Day. The parties shall
also be entitled to vacation time with the child conditioned upon the parties
providing each other with reasonable notice.
4. The parties may modify the custody arrangement as they agree. Absent an
agreement, this Order shall control. In the event either party desires to
modify this order, that party may petition the court to have the case again
scheduled with the custody conciliator for a conference.
cc: /Mark F. Bayley, Esquire 7
/ Thomas J. Williams, Esquire
BY THE COURT,
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SCOTT SAILHAMER,
Plaintiff
v
ELIZABETH SAILHAMER,
Defendant
Prior Judge:
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 02 - 4511 CIVIL
IN CUSTODY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF
PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following
report:
1. The pertinent information pertaining to the child who is the subject of this litigation
is as follows:
Brooke Victoria Sailhamer, born December 31, 19%.
2. A Conciliation Conference was held on November 21, 2002, with the following
individuals in attendance:
The Father, Scott Sailhamer, with his counsel, Thomas J. Williams, Esquire; and the
Mother, Elizabeth Sailhamer, with her counsel, Mark F. Bayley, Esquire.
3. The parties agree to the entry of an order in the form as attached.
l Ua - 4J -
DATE Hubert X. Gilroy, %uire
Custody Conciliar
FTI LES' DATAFILE1G-d- curt10612.sn2/tde
Created. 12/22/97 101424 AM
Revised: 02/18/U3 09: 11,13 AM
10612.1
SCOTT SAILHAMER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
ELIZABETH SAILHAMER,
Defendant
NO. 2002-4511
IN CUSTODY
STIPULATION
CIVIL ACTION - LAW
AND NOW, comes the parties hereto, by and through their attorneys of record, and hereby
request the Court to adopt the following Stipulation as an amendment to the Custody Order dated
December 2, 2002:
1. The regular, alternating two week periods of custody shall include any holidays
contained therein with the exception of Thanksgiving and Christmas, which shall be as follows:
a. THANKSGIVING. On odd numbered years, Mother will have the child on
Thanksgiving Day from 9:00 a.m. until 3:00 p.m., and Father shall have the
child on Thanksgiving Day from 3:00 p.m. until 9:00 p.m. This will be
reversed on even numbered years.
b. CHRISTMAS: On odd numbered years, Mother shall have the child from
9:00 a.m. on December 24 until 9:00 a.m. on December 25, and Father shall
have the child from 9:00 a.m. December 25 until 9:00 a.m. December 26.
This shall reverse on even numbered years. .
C. The Thanksgiving and Christmas Holidays as above described shall take
precedence over, and be in addition to, the regular custody schedule and shall
not create any "make-up time" against the regular custody schedule.
2. Neither party shall make derogatory statements about the other, or the family of the
other, in the presence of Brooke, nor permit anyone else to make sure statements in her presence.
ROMINGER & BAYLEY
By
Mark Pyle y, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Attorneys for Defendant
Date:
MARTSON DEAPOORFF WILLIAMS & OTTO
By j pizj_?_
Thomas J. Will s, Esquire
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
Date: 3/ 2 c it 0-3
c7 c,?:
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%ECE1 VEL
MAR 2 0 2003
4 n\A/r
F:\FILES\DATAFILE\General\Doc nts\10612sti2
Created: 01/03/03 11.48:15 AM
Revised: 03124/03 10:18:28 AM
SCOTT SAILHAMER,
Plaintiff
V.
ELIZABETH SAILHAMER,
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002-4511 CIVIL ACTION - LAW
Defendant : IN CUSTODY
ORDER
AND NOW, this day of 2003, at the request of both
parties, acting through their attorneys of record, the attached Stipulation is hereby adopted as an
amendment to the Order issued on December 2, 2002. Except as modified by this Stipulation, the
Order of December 2, 2002, shall remain the same.
BY THE COURT,
J. Wesley Oler,
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Thomas J. Williams, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
I.D. 17512
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
SCOTT A. SAILHAMER IN THE COURT OF COMMON PLEAS OF
Plaintiff CUSTODY COUNTY, PENNSYLVANIA
V.
NO. 2002-4511
CIVIL ACTION - LAW
ELIZABETH ERB, f/k/a
ELIZABETH SAILHAMER,
Defendant IN CUSTODY
PLAINTIFF'S PETITION TO MODIFY OF CUSTODY
1. Plaintiff is Scott A. Sailhamer (herein, "Father"), an adult individual currently
residing at 224 Roxbury Road, Shippensburg, Cumberland County, Pennsylvania.
2. Defendant is Elizabeth Erb, formerly know as Elizabeth Sailhamer (herein, "Mother),
an adult individual currently residing at 662 Walnut Bottom Road, Leesburg, PA
3. Father seeks to modify the Custody Order with regard to Brooke Victoria Sailhamer,
who was born on December 31, 1996.
4. Father currently resides with Lori Duncan and his daughter, Brooke Sailhamer.
5. Mother currently resides with her husband, Gary Erb, their son, Levi Erb, and on a
part-time basis, Gary Erb's two daughters, Courtney and Alexi Erb.
6. Since the previous Custody Order dated March 28, 2003, which modified the previous
Order of December 2, 2002, copies of each attached hereto as Exhibit "A" and Exhibit "B",
respectively, the parties have been equally sharing custody on an alternating bi-weekly basis.
7. On or about February 15, 2009, Brooke was removed from Mother's residence by the
Pennsylvania State Police at the request of Children & Youth Services based on a report from the
Big Spring School District; however, Brooke has recently resumed the alternating bi-weekly
schedule as per the Court Order of March 28, 2003.
8. Father is requesting primary custody of Brooke as she is not being adequately
nurtured at the residence of her Mother and step-father, and occasionally suffers physical and
emotional abuse at Mother's residence.
9. This case was previously conciliated by Hubert X. Gilroy, Esquire; however, Mr.
Gilroy is now affiliated with Father's counsel's firm and a new Conciliator needs to be appointed
to this matter.
MARTSON LAW OFFICES
Thomas J. Willi , Esquire
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
Date: ,,? 3 6 ) 01
F:\FILES\DATAFILE\General\Docuro nts\10612.sti2
Created: 01/03/03 11:4815 AM
Revised: 03/24/03 10:18:28 AM
MAR 2 6 2003 t'
SCOTT SAILHAMER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2002-4511 CIVIL ACTION - LAW
ELIZABETH SAILHAMER,
Defendant IN CUSTODY
ORDER
AND NOW, this ? Et' day of 2003, at the request of both
parties, acting through their attorneys of record, the attached Stipulation is hereby adopted as an
amendment to the Order issued on December 2, 2002. Except as modified by this Stipulation, the
Order of December 2, 2002, shall remain the same.
BY THE COURT,
1. Wesley Oler, Ir., J.
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Protfioroftrv
EXHIBIT "A"
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IIN,12 1 .
SCOTT SAILHAM ER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2002-4511 CIVIL ACTION - LAW
ELIZABETH SAILHAMER, :
Defendant IN CUSTODY
STIPULATION
AND NOW, comes the parties hereto, by and through their attorneys of record, and hereby
request the Court to adopt the following Stipulation as an amendment to the Custody Order dated
December 2, 2002:
1. The regular, alternating two week periods of custody shall include any holidays
i contained therein with the exception of Thanksgiving and Christmas, which shall be as follows:
a. THANKSGIVING. On odd numbered years, Mother will have the child on
Thanksgiving Day from 9:00 a.m. until 3:00 p.m., and Father shall have the
child on Thanksgiving Day from 3:00 p.m. until 9:00 p.m. This will be
reversed on even numbered years.
b. CHRISTMAS: On odd numbered years, Mother shall have the child from
9:00 a.m. on December 24 until 9:00 a.m. on December 25, and Father shall
have the child from 9:00 a.m. December 25 until 9:00 a.m. December 26.
This shall reverse on even numbered years.
C. The Thanksgiving and Christmas Holidays as above described shall take
precedence over, and be in addition to, the regular custody schedule and shall
not create any "make-up time" against the regular custody schedule.
2. Neither party shall make derogatory statements about the other, or the family of the
other, in the presence of Brooke, nor permit anyone else to make sure statements in her presence.
ROMINGER & BAYLEY
By J
Mark 4yley, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Attorneys for Defendant
Date:
MARTSON DEARDORFF WILLIAMS & OTTO
By Thomas J. Will s, Esquire
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
Date: 3! 2-el 03
i
NOV 2 7 200 N
SCOTT SAILHAMER,
Plaintiff
v
ELIZABETH SAILHAMER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 02 - 4511 CIVIL
: IN CUSTODY
COURT ORDER
AND NOW, this 15day of bee e t-AOe R , 2002, upon consideration
of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The Father, Scott Sailhamer, and the Mother, Elizabeth Sailhhamer, shall
enjoy shared legal and shared physical custody of Brooke Victoria Sailhamer,
born December 31, 19%.
2. Physical custody shall be handled with a 2 week on / 2 week off type of
arrangement. The parties may modify that arrangement as they agree.
3. The parties will also work between themselves with respect to sharing or
alternating custody on =jor holidays, the child's birthday and other
important days such as Mother's Day and Father's Day. The parties shall
also be entitled to vacation time with the child conditioned upon the parties
providing each other with reasonable notice.
4. The parties may modify the custody arrangement as they agree. Absent an
i agreement, this Order shall control. In the event either party desires to
modify this order, that party may petition the court to have the case again
scheduled with the custody conciliator for a conference.
BY THE COURT,
Dal J.
I 1?s
JS
cc: Mark F. Bayley, Esquire
Thomas J. Williams, Esquire TRUE COPY FROM REMRD
In Testimony whereof, i here unto set my hand
end seal of se' rt KGB r/i1is* Pe.
7 .. .. .....'1?1.:.: ..4-1 r
I?OIlplrry
EXHIBIT "B"'
SCOTT SAILHAMER,
Plaintiff
v
ELIZABETH SAILHAMER,
Defendant .
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 02 - 4511 CIVIL
IN CUSTODY
Prior Judge:
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF
PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following
report:
1. The pertinent information pertaining to the child who is the subject of this litigation
is as follows:
Brooke Victoria Sailhamer, born December 31, 1996.
2. A Conciliation Conference was held on November 21, 2002, with the following
individuals in attendance:
The Father, Scott Sailhamer, with his counsel, Thomas J. Williams, Esquire; and the
Mother, Elizabeth Sailhamer, with her counsel, Mark F. Bayley, Esquire.
3. The parties agree to the entry of an order in the form as attached.
i l iii o2 4 1 Q??/
DATE Hubert X. Gilroy, wire
Custody Concilia
VERIFICATION
The foregoing Complaint for Custody is based upon information which has been gathered
by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and
not my own. I have read the Complaint and to the extent that the document is based upon
information which I have given to my counsel, it is true and correct to the best of my knowledge,
information and belief. To the extent that the content of the document is that of counsel, I have
relied upon counsel in making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unworn falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to criminal penalties.
/)co4ttA. Sailhamer
. . . .
CERTIFICATE OF SERVICE
I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams Otto Gilroy &
Faller, hereby certify that a copy of the foregoing Petition to Modify Custody Order was served this
date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed
as follows:
Mark F. Bayley, Esquire
155 South Hanover Street
Carlisle, PA 17013
MARTSON LAW OFFICES
y
ncia D. Eckenroad
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: apl?t '-301' M?
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SCOTT A. SAILHAMER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
2002-4511 CIVIL ACTION LAW
ELIZABETH ERB FWA ELIZABETH
SAILHAMER IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Monday, May 04, 2009 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, June 12, 2009 at 2:30 PM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: /s/ John J. Mangan,,&, Esq pf _
Custody Conciliator T
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
?F Ti-! PF, r RY
2889 MA Y -5 FM 3:
CUM
JUN 1 '5 200911
SCOTT A. SAILHAMER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. :2002-4511 CIVIL ACTION - LAW
ELIZABETH ERB, f/k/a
ELIZABETH SAILHAMER, : IN CUSTODY
Defendant
ORDER OF COURT
AND NOW, this f 6 A day of 7,t n e _ , 2009, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The prior Orders of Court dated December 2, 2002 and March 28, 2003
shall remain in full force and effect.
2. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control. Another
Conciliation Conference shall be held on Monday, August 17, 2009 at 9:30 a.m.
cc: Thomas J. Williams, Esquire, Counsel for Father
ark F. Bayley, Esquire, Counsel for Mother
BY THF, COURT.
SCOTT A. SAILHAMER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. :2002-4511 CIVIL ACTION - LAW
ELIZABETH ERB, f/k/a
ELIZABETH SAILHAMER, : IN CUSTODY
Defendant
PRIOR JUDGE: J. Wesley Oler, Jr., J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Brooke Victoria Sailhamer December 31, 1996 shared
2. A Conciliation Conference was held in this matter on June 12, 2009.
Father, Scott A. Sailhamer, was present with his counsel, Thomas J. Williams, Esquire,
and Mother, Elizabeth Erb, was present with her counsel, Mark F. Bayley, Esquire.
3. The Honorable J. Wesley Oler, Jr. previously entered Orders of Court
dated December 2, 2002 and March 28, 2003 providing for shared legal and shared
physical custody on a two week on/two week off schedule.
4. The parties agreed to the entry of an Order in the form as attached.
6-IS?o9
Date
Nl
61acqVeline M. Verney, Esquire
Custody Conciliator
FLED-,Dr'-?i('E
?
Or THE p T,?RI?
2009 JUN 17 Ali 11: 3 9
AUG -i d 2009
SCOTT A. SAILHAMER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2002-4511 CIVIL ACTION - LAW
ELIZABETH ERB, f/k/a
ELIZABETH SAILHAMER, : IN CUSTODY
Defendant
ORDER OF COURT
AND NOW, this 17" day of August, 2009, being advised that the parties are
satisfied with the prior Orders of Court, the Conciliator hereby relinquishes jurisdiction in
this matter.
FOR THE COURT,
i
cq ne M. Verney, Esquire, Custody Co iliator
CF ?HF PP'OTHO 3TAPY
2009 AUG 18 FPS 2.4 a
CUM ; a JUN Y
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
SCOTT SAILHAMER,
Plaintiff
NO. 2002-4511
V.
ELIZABETH ERB,
Defendant
To the Prothonotary:
CIVIL ACTION LAW
IN CUSTODY
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Please withdrawal my appearance on behalf of Scott Sailhamer in the above captioned matter.
Date: '~r
Thomas J. illiams, Esquire
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Please enter by appearance on behalf of Scott Sailhamer in the above captioned matter.
Date: ~ . Z ~ - ~.,
Michae A. Scherer, Esquire
19 West South Street
Carlisle, PA 17013
(717) 249-6873