HomeMy WebLinkAbout02-4594
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
SCOTT CARDER,
Civil Action At Law---Custody
Plaintiff,
Case No. tJ:/. - -'I~q'l
(7,'u11~
VS.
KATHY MILLER,
Defendant,
COMPLAINT FOR CUSTODY
1. The plaintiff is Scott Carder., residing at 815 Hogestown Road,Mechanicsburg
17050, in the County of Cumberland, Commonwealth of Pennsylvania,
2. The defendant is Kathy Miller, currently residing at 136 North Regency Woods,
Carlisle, 17013 in the County of Cumberland Commonwealth of Pennsylvania.
3. Plaintiff seeks custody of the following child:
Name
Address
Al!e
Kyle S. Carder
same as Mother's
9/1/1992 dob
12 years
4. The child was born outside of wedlock.
5. The child is presently in the custody of Kathy Miller, who resides at 136 North
Regency Woods, Carlisle, 17013 in the County of Cumberland Commonwealth of
Pennsylvania.
6. During the last nine months the child has resided with the Mother at various
addresses' and most recently now at 136 North Regency Woods, Carlisle, 17013 in
the County of Cumberland Commonwealth of Pennsylvania.
7. The biological mother of the child is Kathy Miller, who currently resides at
136 North Regency Woods, Carlisle, 17013 in the County of Cumberland
Commonwealth of Pennsylvania.
8. The mother has been separated from the father since 1994, and is currently unmarried
to the same.
9. The father of the child is Scott Carder and he is currently residing 815
Hogestown Road,Mechanicsburg 17050, in the County of Cumberland,
Commonwealth of Pennsylvania,
10. The father is separated and remains unmarried to the mother.
II. The relationship ofthe plaintiffto the child is that of a biological Father. The
Plaintiff currently resides with the following persons:
Melissa Carder
Relationship
Wife
Name
12. The plaintiff has participated as a party in a proceeding that was commenced by
mother in the State of Virginia on or about, whereupon an Order of Custody was entered
adjudicating the custodial rights of the respective parties.
13. The plaintiff has no other information of a custody proceeding concerning the child
pending in a Court of this Commonwealth to the extent that the Order issued in the State
of Virginia while it remains the only Order entered heretofore relative to the issue of
custody neither party has resided within the State over a one year period prior to the
effective date of this complaint.
14. Plaintiff does not know of a person not a party to the proceedings who has physical
Custody of the child or claims to have custody or visitation rights with respect to the
child.
15. The best interest and permanent welfare of the child will be served
by Granting the relief requested because:
(a) The father can provide a stable, predictable and permanent environment for the
child within which the child will have a sense of stability and predictability with regard
to his residence.
(b) The Mother has a history of frequent relocations which disturb, disrupt and which
disadvantage the child's educational, emotional, and familial lifestyle with his
father as well as those of whom he has become acquainted with during these
periods.
(c) Plaintiff, believes and therefore avers that he can continue to provide a
predictable and stable lifestyle for which, which will be in the best interest of the
child during his formative years and throughout his life.
WHEREFORE, Plaintiff, Scott Carder, respectfully requests for the aforementioned
reasons, that the court grant and award him primary physical custody of the child.
Dated: ? 1/8',/():2.
GREGORYS.HAZLETT
"
VERIFICATION
I verify that the statements made in this Complaint are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
& 4904 relating to unsworn falsification to authorities
Date: 9. l't. D-z:..
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Scott Carder, Plaintiff
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SCOTT CARDER
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANlA
v.
02-4594 CIVIL ACTION LAW
KA TIIY MILLER
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, Monday, September 30,2002 , upon consideration ofthe attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, October 24, 2002 at 1:00 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. 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 hearin~.
FOR THE COURT.
By: Isl
Dawn S. Sunda.y. Esq. t/
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 00 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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SCOTT CARDER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
02-4594
CIVIL ACTION LAW
KATHY MILLER,
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this z...r- day of 0 if. Lr , 2002,
upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The Mother, Kathy Miller, and the Father, Scott Carder, shall have shared legal custody of
Kyle S. Carder, born September 1, 1992. Each parent shall have an equal right, to be exercised jointly
with the other parent, to make all major non-emergency decisions affecting the Child's general well-
being including, but not limited to, all decisions regarding his health, education and religion. Pursuant
to the terms of this paragraph each parent shall be entitled to all records and information pertaining to
the Child including, but not limited to, school and medical records and information.
2. The parties shall share having physical custody of the Child on an alternating weekly basis,
with the exchange to take place each week on Sunday at 6:00 p.m. The alternating weekly schedule
shall begin with the Father having custody of the Child on Sunday, October 27,2002.
3. Unless otherwise agreed between the parties, the Child shall remain enrolled in his current
school district.
4. The parties shall share having custody of the Child on holidays as arranged by agreement.
5. The non-custodial parent shall be entitled to have reasonable liberal telephone contact with
the Child.
6. Neither party shall relocate the residence of the Child outside the Commonwealth of
Pennsylvania without the advance agreement of the other party or Court approval.
7. Neither party shall do or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natural development of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
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8. This Order is entered pursuant to the 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 ofthis Order shall control.
BY THE COURT,
Ad
J.
cc: Kathy Miller, Mother
Gregory S. Hazlett, Esquire - Counsel for Father
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SCOTT CARDER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
02-4594
CIVIL ACTION LAW
KATHY MILLER,
Defendant
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Kyle S. Carder
September 1, 1992
Mother
2. A Conciliation Conference was held on October 24, 2002, with the following individuals in
attendance: The Father, Scott Carder, with his counsel, Gregory S. Hazlett, Esquire, and the Mother,
Kathy Miller, who is not represented by counsel in this matter.
3. The parties agreed to entry of an Order in the form as attached.
Or.f.olxA ~Y, ...l.eo~
Date
t2~.~~ 4~ J~
Dawn S. Sunday, Esquir
Custody Conciliator
Scott Carder
Plaintiff
In the Court of Common
Pleas of Cumberland County
Pennsylvania
vs.
Kathy Miller
defendant
Civil Action Law
case #02-4594
In Custody
.s.tipulation and AgreeJment
1. The Mother, Kathy Miller, and the Father, Scott Carder, shall have shared
legal custody of Kyle S. Carder, born September 1, 1992. Each parent shall have an equal
right, to be exercised jointly with the other parent to make all major non emergency
decisions, affecting the childs general well being including but not limited to, all
decisions regarding his health education and religion pursuant to the terms of this
paragraph, each parent should be entitled to all records and information pertaining to the
child including but not limited to school and medical records and information.
2. The father, Scott E. Carder shall have primary physical custody of minor child,
Kyle S. Carder, with mother, Kathy Miller having periods of primary physical custody.
Those periods of time when mother shall exercise primary physical custody shall be every
other weekend beginning with Friday, November 29, 2002 at 6:00pm and running until
Sunday, December 1,2002 at 6pm. The weekend schedule shall alternate from that point
on.
3. Mother shall also have primary physical custody of minor child for a period of
3 consecutive weeks in the summer, mother shall inform father prior to the end of the
school year in writing, which weeks she will be having, giving at least a week in advance
notice of time period. Father will not disagree to any period of time she will be having in
the summer if notice is given per above agreement. Otherwise both parties must agree.
4. The parties shall share the Christmas holiday, the father shall have the first
part of the holiday in 2002, being from Christmas Eve at 6pm, and running until
Christmas Day at 1 pm. Mother then shall have from 1 pm Christmas Day until the day
after at 6pm. This schedule shall alternate yearly from that point, giving the mother the
first part of the holiday in the year 2003.
5. The parties shall alternate Thanksgiving and Eastl~r yearly, this being the
mother shall have Easter in the year 2003 and the father shaH have Thanksgiving in the
same year, this schedule will alternate yearly then giving the father Easter in 2004 with
the mother having Thanksgiving.
6. Memorial Day and Labor Day shall be given to the parent who has the child
for the weekend mnning into the holiday. The party then shall return child at 6pm on the
day of the holiday.
7. The non-custodial parent shall be entitled to have reasonable liberal telephone
contact with child.
8. Neither party shall relocate the residence of the Child outside the
Commonwealth of Pennsylvania without the advance agreement ofthe other party or
Court approval.
9. Each party shall be notified of phone numbers and addresses to where the
minor child will be residing within 3 days of any changes.
10. Neither party shall do or say anything which may estrange the Child from
other parent.
11. Mother shall have other periods of primary physical custody as agreed upon
by both parties.
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SCOTT CARDER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
vs.
02-4594
CIVIL ACTION LAW
KATHY MILLER
Defendant
IN CUSTODY
AND NOW, this I G, or day of U~- , 2002, hereby ordered
all prior orders are vacated and attached is a stipulation and agreement\ ht..rdw,'-l-t.
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PENNSYLWIN&6.
Scott Carder
Plaintiff
In the Court of Common
Pleas of Cumberland County
Pennsylvania
vs.
Kathy Miller
defendant
Civil Action Law
case #02-4594
In Custody
.s.tipulation and Agreement
1. The Mother, Kathy Miller, and the Father, Scott Carder, shall have shared
legal custody of Kyle S. Carder, born September 1, 1992. Each parent shall have an equal
right, to be exercised jointly with the other parent to make all major non emergency
decisions, affecting the childs general well being including but not limited to, all
decisions regarding his health education and religion pursuant to the terms of this
paragraph, each parent should be entitled to all records and information pertaining to the
child including but not limited to school and medical records and information.
2. The father, Scott E. Carder shall have primary physical custody of minor child,
Kyle S. Carder, with mother, Kathy Miller having periods of primary physical custody.
Those periods of time when mother shall exercise primary physical custody shall be every
other weekend beginning with Friday, November 29, 2002 at 6:00pm and running until
Sunday, December 1,2002 at 6pm. The weekend schedule shall alternate from that point
on.
3. Mother shall also have primary physical custody of minor child for a period of
3 consecutive weeks in the summer, mother shall inform father prior to the end of the
school year in writing, which weeks she will be having, giving at least a week in advance
notice of time period. Father will not disagree to any period of time she will be having in
the summer if notice is given per above agreement. Otherwise both parties must agree.
4. The parties shall share the Christmas holiday, the father shall have the first
part of the holiday in 2002, being from Christmas Eve at 6pm, and running until
Christmas Day at I pm. Mother then shall have from I pm Christmas Day until the day
after at 6pm. This schedule shall alternate yearly from that point, giving the mother the
first part of the holiday in the year 2003.
5. The parties shall alternate Thanksgiving and Easter yearly, this being the
mother shall have Easter in the year 2003 and the father shall have Thanksgiving in the
same year, this schedule will alternate yearly then giving the father Easter in 2004 with
the mother having Thanksgiving.
6. Memorial Day and Labor Day shall be given to the parent who has the child
for the weekend nmning into the holiday. The party then shall return child at 6pm on the
day of the holiday.
7. The non-custodial parent shall be entitled to have reasonable liberal telephone
contact with child.
8. Neither party shall relocate the residence of the Child outside the
Commonwealth of Pennsylvania without the advance agreement of the other party or
Court approval.
9. Each party shall be notified of phone numbers and addresses to where the
minor child will be residing within 3 days of any changes.
10. Neither party shall do or say anything which may estrange the Child from
other parent.
11. Mother shall have other periods of primary physical custody as agreed upon
by both parties.
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SCOT CARDER,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-4594 CIVIL ACTION - LAW
KATH MILLER
n/kla ATHY KEESEMAN,
Defendant
IN CUSTODY
PETITION TO MODIFY CUSTODY
The Petitioner is Kathy M. Keeseman, (hereinafter referred to as
"Moth r"), who is an adult individual residing at 13 Mooredale Road, Carlisle,
Cumb r1and County, Pennsylvania, 17013.
The Respondent is Scott E. Carder, (hereinafter referred to as "Father"),
n adult individual residing at 201 Campbell Road, Newport, Perry County,
Penns Ivania 17074.
The parties are the natural parents of Kyle S. Carder, born September 1,
1992, ( ereinafter referred to as "Child").
The parties are governed by a December 16, 2002 Order of Court,
hereto as "Exhibit A", relative to the custody of the child.
Father has primary physical custody pursuant to the December 16,2002
custod order.
The parties previously shared physical custody of the child when the
parties ived in the Mechanicsburg School District.
At some point, mother relocated and was advised that she would have to
allow fa her to have primary physical custody of the child in order to allow the child to
remain n the Mechanicsburg School District.
The child has always expressed to mother that he did not want to be
primaril in father's custody.
II
,
9. Father does not allow the child to participate in extracurricular activities.
10. Father makes disparaging remarks to the child about mother, which
upset the child and is emotionally damaging the child.
11. The child has expressed to father that he desires to live primarily with
mothe but father refuses to permit the move, even on a trial basis.
12. Mother is remarried and stable and is able to provide a more nurturing and
loving ome for the child than father offers.
13. Despite mother's requests for more time with the child throughout the
year, f ther always resists mother's efforts to spend more time with the child.
4. Mother's phone messages at father's residence are frequently not given to
the chi
If mother were awarded primary physical custody, she would insure child
n effort to have a meaningful relationship with his father.
HEREFORE, mother requests that this Honorable Court grant her primary
physic I custody of the child and grant father liberal periods of partial physical custody.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
~
Michael A. Scherer, Esquire
1.0. # 61974
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
mas.dlr/d mestlc/keeseman,kathy/modify.pet
II
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SCO T CARDER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-4594 CIVIL ACTION - LAW
V.
KATH MILLER
n/k/a THY KEESEMAN,
Defendant
IN CUSTODY
VERIFICATION
I verify that the statements made in the foregoing Petition To Modify Custody are
true a d correct. I understand that false statements herein are made subject to the
penalt s of 18 Pa. C.SA ~ 4904, relating to unsworn falsification to authorities.
Date
,2006
II
SCO CARDER,
Plaintiff
V.
KATH MILLER
n/kla ATHY KEESEMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-4594 CIVIL ACTION - LAW
IN CUSTODY
CERTIFICATE OF SERVICE
hereby certify that on \ IIA.AL fl.. 7fi..- ,2006, I, Andrea M. Barrick, of
O'Brie ,Baric & Scherer, did serve a copy of the Petition to Modify Custody, by first
class .S. mail, postage prepaid, to the party listed below, as follows:
Scott E. Carder
201 Campbell Road
Newport, Pennsylvania 17074
~1D.~
. Andrea M. Barrick, Secretary
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DEe 1 6 2002
S OTT CARDER
Plaintiff
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
02-4594
CIVIL ACTION LAW
THY MILLER
Defendant
IN CUSTODY
AND NOW, this I) .,+h day of ~ 2002, hereby ordered
all prior orders are vacated and attached is a stipulation and agreemen~ he. f<..ew', th
Qde o..n C9f'de~ af COl)..~t .
BY+:T J
IS/' . d. t\bJ
EXHIBIT "A"
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S ott Carder
Plaintiff
In the Court of Cornmon
Pleas of Cumberland County
Pennsylvania
vs.
K thy M.i1ler
defendant
Civil Action Law
case #02-4594
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In Custody
~ulation and Agreement
I. The Mother, Kathy Miller, and the Father, Scott Carder, shall have shared
I custody of Kyle S. Carder, born September 1, 1992. Each parent shall have an equal
ri t, to be exercised jointly with the other parent to make all major non emergency
de isions, affecting the childs general welI being including but not limited to, all
de . sions regarding his health education and religion pursuant to the terms of this
p graph, each parent should be entitled to all records and infonnation pertaini.Qg to the
chi d including but not limited to school and medical records and information.
2. The father, Scott E. Carder shall have primary physical custody of minor child,
Ky S. Carder, with mother, Kathy Miller having periods of primary physical custody.
Th se periods of time when mother shall exercise primary physical custody shall be every
oth r weekend beginning with Friday, November 29, 2002 at 6:00pm and running until
S y, December 1,2002 at 6pm. The weekend schedule shall alternate from that point
on.
3. Mother shall also have primary physical custody of minor child for a period of
3 co secutive weeks in the summer, mother shall infonn father prior to the end of the
sch I year in writing, which weeks she will be having, giving at least a week in advance
noti of time period. Father will not disagree to any period of time she will be having in
the er if notice is given per above agreement. Otherwise both parties must agree.
4. The parties shall share the Christmas holiday, the father shall have the first
part fthe holiday in 2002, being from Christmas Eve at 6pm, and running until
Chri tmas Day at I pm. Mother then shall have from I pm Christmas Day until the day
after at 6pm. This schedule shall alternate yearly from that point, giving the mother the
first art of the holiday in the year 2003.
5. The parties shall alternate Thanksgiving and Easter yearly, this being the
moth shall have Easter in the year 2003 and the father shall have Thanksgiving in the
same year, this schedule will alternate yearly then giving the father Easter in 2004 with
the ther having Thanksgiving.
EXHIBIT "A"
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,
6. Memorial Day and Labor Day shall be given to the parent who has the child
fi r the weekend running into the holiday. The party then shall return child at 6prn on the
d y of the holiday.
7. The non-custodial parent shall be entitled to have reasonable liberal telephone
c ntact with child.
8. Neither party shall relocate the residence of the Child outside the
C rnmonwealth of Pennsylvania without the advance agreement of the other party or
C urt approval.
9. Each party shall be notified of phone numbers and addresses to where the
mi or child will be residing within 3 days of any changes.
10. Neither party shall do or say anything which may estrange the Child from
r parent.
11. Mother shall have other periods of primary physical custody as agreed upon
th parties.
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Date
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Signature of Father
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Date
EXHIBIT "A"
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SCOTT CARDER
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
02-4594 CIVIL ACTION LAW
KA THY MILLER NIKJ A KATHY
KEESEMAN
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW,
Wednesday, Jnly 05, 2006
, upon consideration ofthe attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq.
at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, Aueust 02, 2006
, the conciliator,
at 8:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin!!.
FOR THE COURT,
By: Isl
Dawn S. Sunday, Esq.
Custody Conciliator
~
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangemcnts
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
HA VE AN A HORNEY 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
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SCOTT CARDER
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
02-4594
CNIL ACTION LAW
KATHY KEESEMAN
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this "=1" day of ~....-- , 2006, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
I. The Father, Scott Carder, and the Mother, Kathy Keeseman, shall have shared legal
custody of Kyle S. Carder, born September 1, 1992. Each parent shall have an equal
right, to be exercised jointly with the other parent to make all major non-emergency
decisions affecting the Child's general well-being, including but not limited to all
decisions regarding his health, education and religion. Each parent shall be entitled
to all records and information pertaining to the Child, including but not limited to
school and medical records and information.
2. The Mother shall have primary physical custody of the Child beginning at the
commencement ofthe 2006-2007 school year. The parties shall cooperate in
arranging the timing of the transfer of custody.
3. At such time as primary custody is transferred to the Mother under this Order, the
Father shall have partial physical custody of the Child on alternating weekends from
Friday at 6:00 p.m. through Sunday at 7:00 p.m. The Father's weekend periods of
custody shall be scheduled to coincide with the alternating weekends during which
the Father is not working. The Father may have additional periods of custody with
the Child during the interim weekends, with the specific times to be arranged by
agreement.
4. The parties shall share having custody of the Child during the Summer school break,
with the specific schedule to be arranged by agreement. In the event the parties are
unable to establish a Summer schedule by agreement, the parties may contact the
Conciliator to schedule an additional conference to establish Summer arrangements.
5. The parties shall exchange custody of the Child at the Sheetz store in
Mechanicsburg, unless otherwise agreed.
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6. In even numbered years, the Father shall have custody of the Child over the
Christmas holiday from Christmas Eve at 6:00 p.m. through Christmas Day at 1 :00
p.m. and the Mother shall have custody from Christmas Day at 1 :00 p.m. until
December 26 at 6:00 p.m. In odd numbered years, the Mother shall have custody
during the first part of the Christmas holiday and the Father shall have custody
during the second part.
7. In even numbered years, the Father shall have custody of the Child on Easter and the
Mother shall have custody on Thanksgiving. In odd numbered years, the Mother
shall have custody on Easter and the Father shall have custody on Thanksgiving.
8. The parent who has custody of the Child under the regular alternating weekend
schedule immediately preceding Memorial Day and Labor Day, shall retain custody
through the day of the holiday at 6:00 p.m.
9. Neither party shall relocate the residence of the Child outside of the Commonwealth
of Pennsylvania without the prior agreement of the other party or Court approval.
10. Each party shall notify the other of telephone numbers and addresses where the
Child will be residing within 3 days of any changes.
II. Neither party shall do or say anything which may estrange the Child from the other
parent.
12. The Mother shall promptly share with the Father any report cards, notices of
conferences or other school functions and other school information which the Father
is unable to obtain directly from the school.
13. The prior Order of this Court dated December 16, 2002 is vacated upon the transfer
of primary custody under this Order.
14. 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 agreement. In the absence of agreement, the terms of this Order shall control.
BY THE COURT,
J.
SCOTT CARDER
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
02-4594
CIVIL ACTION LAW
KATHY KEESEMAN
Defendant
IN CUSTODY
Prior Judge: Kevin A. Hess
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
Kyle S. Carder
September 1, 1992
Father
2. A custody conciliation conference was held on August 2, 2006, with the following
individuals in attendance: The Mother, Kathy Keeseman, with her counsel, Michael A
Scherer, Esquire, and the Father, Scott Carder, who is not represented by counsel in this
matter.
3. The parties agreed to entry of an Order in the form as attached.
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Date
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Dawn S. Sunday, Esquire, C stody Conciliator