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HomeMy WebLinkAbout96-02475 ~ J J '..., " > ~ ...- I' . ..) 0- . ~ " \ \ , , WIU,IAN O. REAClAN, II, IN THE COURT OF ClMION PLEAS OF Plainti ff CUMBERLAND cotM'Y, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 96-2475 CIVIL 1992 RfXHNA L. MlMCA , Defendant CUSTODY CONSFNI' AGREEMENT This Agreement Is entered on this /=t"a day of ~~ I... 1997, by the plaintiff, WilliaM G. Reagan, II, hereinafter referred to as the father and the defendant, Regina L. Mumma, hereinafter referred to as the mother. The father is represented by Johnna Deily of Saidis, Guido, Shuff and Maslandj the mother is represented by Joan Carey of Legal Services, Inc. The father and the mother agree to the entry of the follOWing CUstody Order vacating the Order of Court entered October 7, 1996, and enter the fOllOWing Order regarding custody of their children, Kyle W. Reagan (ooB:OS/21/91) And William G. Reagan (ooB: 07/07/93): I. The father and mother will have shared legal custody of the children. 2. The mother will have primary physical custody of the children. 3. The father will have partial custody of the children every other weekend from Friday at 6:30 p.m. to Sunday at 6:30 p.m. and will also have weekdays during the summer months when the children are out of school until one week before the school year besins. 4. The parties will have custody of the children on holidays as follows: a. ~ The Christmas holidays will be divided into Segment A, ~ >- f:) .. lJ' ,.. ..' (" ,c {S! " ~ll' " , f1: c , . ' " (rJ, 1.,1' " , l.JI'" , " U I " ,. , .. , , ( '- . I.', d r; " 'ib " ~5"j' ,~ J ,1 (I. ,r. ..) l): .. " :, \,.9 ~~ j ~ r" ~ I .! A, ~ \J ,~ ,7 ,~ ,~ :::: <-'.t. ?'- tr 3 ~ 3 ~,~ ~l~~ j '.... J9. (>J ~ 'J ~j ~ I)- :3 if ,( ..PC) --1' ~ ~ ~ tV d 1; t. j q ci '~J./ ~ .(' ~ o .... w'" W-oe ~ ~ 11'\ iJl- If'\ ;1:-'1' ,,0:;"" - ,,' :: ..IN ~~~ ~w~ ... o ..... . ~ ::= Ijj-::i u 0 .... to: 1.1-0 -< ... ~ i:l o ~ ~ ~~5 ..1....1. ;:J Q:; . . The mother MhLll1 have cUMtody of the children llurlllll ~el/.menl ^ III even numbered years Ilnd durin!! Sel/.ment 1\ In ",hl numhen'd Yl'/II'H, The fathl'r Mhull flllve cUMtody of the dli Idn!n durlnl! ~cllml'nt ^ In odd numbered yellrs Ilnd durinl! ~egml'rtt 1\ In eVl'n num'",rl',1 Yl'lIr.s. b. Ihill1l5.mUY1n&. The Thllrtk:;givlng holldllY :;hllll 'lL'/oIIII llJl the Wel!twsdLlY before Thllnksgivlng lit 7:00 p,m, LllIlI end on the MO'IlIIlY following Thunksgiving lit 7:00 p.m. The mother slulll hllvl' CUlitlll\Y of the chi Idren ,)ver the Thllnksglvlnll hulldllY In the l'ven numhun!ll yellrs LInd the fllther Mhall have custudy uf th'~ children over thll Thanksgiving hol iday in odd numberel\ yeIHS. C. Mother'M DIIYL.E!!lh~L1i..lll!Y-,- The mother stull I hLlve cllstlllly L1f the children every yenr on mother's day ,Hill the fllthl'r I!hLll1 hlIVII custody of the chi Idren every yellr on Fllther'l! !lilY, d. RemuinlnR U9l.li!.!!.Y1L. The mothllr Ilnd fllther ,slmll hllVl' custody or the children on an alternating bush on the followln/ol hllllduYIi: New Years, Easter, MlImorial Day, July 4th, und Lubor Day. '!'tIll period of custody shall begin on the cveninl/. hefore tho holiday lit 6:30 p.m. and end on the holiday at 7:00 p.m, The alternatlnll schedule shall begin wI th the (ather havIng cUllhllly of tho children on New Years In 1997. S. Both the mother and father shall ellch h/IVl' Cllstlllly of thll children for two consecut ive uninterrupted wech dllrinl/. the summer of eVllry Y0l1r upon providing thirty (30) days notice to the ottl<'r pllrty. 6. The party receiving custody of the children shull provide transportat Ion during the exchange of cll,stody. WILLIAM G. REAGAN. II, Plaintiff IN TIlF. COlJRT OF rl>MMclN PU,IS OF v. CI!MllF.RJ .ANn COIMY, I'ENNSYI. VAN I A CIVIL ACTION - l.AW .., , ., 'r REGINA L. MUMMA. Defendant NO, 96-247,~ CIVl/, 1<)92 ." CUSTODY '.. I CONSENT AGRErMf.~ This Agreement is entered on this _I ::ra. dllY of ~et..~ L . . " :{'\ :1 .'. ,I ,Ill " :".1 ..;.. father and the defendant, Reginll L. Mummll. hereirlllfllrr ((.ferred to 1111 the 1997, by the plaintiff, Willillm G. Rellglln, II, herelnnfter rC!ferred to 1111 the I .. ~ MlISland; the mother is represented by JOlin Cllrey of l.eglll SerVicell, Inc, mother. The father is represented by ./ohnrlll Old Iy of Snldls, GUido, Shuff and Order vacating the Order of Court entered OCloher 7, I <)'/r, , IInd enter the The father and the mother agree to the "ntry of the (01 lowing CUlltody fOlloWing Order regarding custody of their chi Jdren, "ylll W. Rellglln (DOB:08/21/9I) and William G. Reagan (DOB: 07/07/<J.1): I. The father and mother will h/lve shllred lugtl/ custody of the children. 2. The mother will have primary Physical CUlltlMJyof the children. 3. . The father will have partial custody of the children every other weekend from Friday at 6:30 p.m. to SundllY lit 6:.10 p.m. IInd wi II IIlso hnve weekdays during the summer months when the chi Idfl'n lire out of school until one week before the school yell I' begins. follows: 4. The pllrties wi II have CU,'tody of IlllI children Oil hol idays as which wi II begin on Decemher 24 III 12:00 noon Ilnd end on Christmas a. !:.'bristmlls. The Christmn,s holldny.s will he divided into Segment A, The mother of the ~hildren is Regina L. Mumma. address unknown, She IS unmarried. The lather oflhe ~hlldrenls WI ilium G, Reugan.lI, eurrelllly residing ut222 B Street, Carlisle. PA 170 IJ, fie Is married. 4, The relationship of the Pelilioner to Ihe ~hlldren is thut of grandmother, The Petitioner currently resides with the follmving persons: John Andrevves. lian~c, Kyl: W, Reagan, grandson and William G, Reagan, grandson, 5, The relalionship of the Co-Respondellls to the ~hildren is that of mother and IOlher, The Co- Respondents ~urrently resides with the following persons: Regina l.. Mummu currently resides with Tim Graham and Wllllum G, Reugun, (( currently resides with lIeuthcr. girlfriend, 6, Petitioncr hus not purticipatcd as a party or witness, or in anothcr cupa~lty, in other litigation concerning the custody of thc chlldrcn in this or anothcr court, 1I0vvcver, Petitioncr has information of a castody proceeding concerning Ihe children pcndlng in a Court of this Comlllonwealth, namely Cumberland County, docketed at #96-2475, (See copy alla~hcd us Pctitioner's Exhibit "A") 7, Pp.titloner docs not know of a person not a party to thc pro~ecdings who has physical custody of the ehildren or claims to have custody or visitation rights with respect to the children, 8, The best Interest and permanent wellore of the ~hlldren will bc served by granting the relief requested for the 'following reasons: A, Petitioncr has undert(lkcn and performed thc primary parcntal responsibilities for each of the children; und B, Petitioner is be5t ablc to prov idc the ~nrc und nurHu'c vvhich Ihe ~hildren need for health development; and C. Petitioner desires to maintain thc family household vvhich has becn cstablished. and the continued stublllty ofthc household is in the best intcrcst ofthc ~hildrcn. WILLIAN O. R!AOAN. ", IN 1lfE COURT OF ClMtON PLEAS OF PlaInt I rr CUMBERLAND cowrY, PENNSYLVANIA v. CIVIL AcrlON - LAW NO. 96-247.5 CIVIL 1992 RtXlINA L. ~, Defendant CUSTODY CONSEm' AGREDIENT This Agreement Is entered on this rrn day of ~~ - 1997, by the plaintiff, William G. Reagan, II, hereinafter referred to as the father and the defendant, Regina L. MUmma, hereinafter referred to as the mother. The father is represented by Johnna Deily of Saidis, Guido, Shuff and Masland; the mother Is represented by Joan Carey of Legal Services, Inc. The father and the mother agree to the entry of the following Custody Order vacating the Order of Court entered October 7, 1996, and enter the follOWing Order regarding custody of their children, Kyle W. Reagan (008:08/21/91) and William G. Reagan (008: 07/07/93): I. The father and mother will have shared legal custody of the chi Idren. 2. The mother will have primary physical custody of the children. J. The father will have partial custody of the children every other weekend from Friday at 6:30 p.m. to Sunday at 6:30 p.m. and will also have weekdays during the summer months when the children are out of school until one week before the school year begins. 4. The part ies wi I I have custody of the chi Idren on holidays as follows: a. ~ristmas. The Christmas holidays will be divided into Segment A, i>,?, ..., .~ " ,. .,'\ t. ~c '" ..' p" .., n, , , , I (,', ~\ , .. t'l: (.....: ""::,"-; fC ~I i , illJ f~ C.: 'j(1... .;..; ,,' ~ I'ti .~ , eJ. lJ ~~ \N ".- IX) 11- ~: ~~ I '. I.t I~ : c.:1 +- ( I ~.. ' . f ~ ,: I., '.- ,. .-, d. r i ~ . I' ::-::i I' CJ Cl " iil I;.,' ("; ._.1 1"; i.i.:.' ...' 'II:.; I Cl 'L dJ7I L' (....> "~l fl. u (i'; ..1 <J. 0 . The mother ~hllll have custody of the chi Idren during Segment A in even numbered years /Ind durin!! Segment II in mId numbered yellr~. The fllther shill I hllve custody of the chi Idren during Segment A in odd numbered yeMs IInd ,luring Segment II In even numbered years. b. T.hilllk~Jl..i..Y.iD&_ Tlw Thllnksglving hol iday shall hegin on the Wltdm,sday before Thanksgiving at 7:00 P,In. (\rid end on the Monday follOWing Thllnksgiving lit 7:00 p.m. Tho mother shllll have custody of thtl chi I<lren over the TlllInk,sgivlng hol idny in thtl even numbertld years and the father shal I 11Ilvc custody of the chi Ielren over the Thanksgiving holiday in mid numbered yellrs. c. MQJb~L';L!1!IYLfllthe.r'_~,nl!Y... The mother Sh'lll havtl custody of the children every yellr on mother's day nnd the fllther shall havtl custody of the chi ldren every yenr on Fnther' s Day. d. Re!!l!!inio&.lI..9Jh!1!Y'i, The mother llnd fllther shall have custody of the children on an alternnting bnsis on the fOllowing holidays: New Years, Easter, Mtlmorinl Day, July 4th, and Labor Day. The period of custody shall begin on the evening before the holiday at 6:30 p.m. ami end on the holiday at 7:00 p,m. The alttlrnating schedule sha1,1 begin with the father tuwing custody of the childrtm on New Venn, in 19'17, 5. Both the mother nnel father shall ellch have custody of the children for two consecut ivc uninterrupted weeks during the summer of every year upon providing thi rty (30) elnys not ice to the other pnrty, 6. The PlIJ'ty receiving custody of the chi Idren shall provide transportation durin!! the exchangt' of ('ustody. . . , .. ~ Day lit II :00 lI.m., und Segment II, which wi II hegln on Christmus Duy at II :00 lI.m. Ilnd end on Dccemhc!' 26 nt 12:00 noon. The mother wi II hllve ~'ustody of the chll,lrl'll during Scgmcnt A in even numbered Yl'/lr,~ /Hili during Ilegml'nt II in odd numhcre,l yellrs, The fnther wi II hllve custody of the chi Idren during Segment A in odd numbln'ed yellrs Ilnd ,Iur i ng S"gment II in eVl'n numhered yellrs. b. TJ.!l!l1ISNU.Y.ilUh The Thunksglving hol idllY wi I I begin on the Wednesday before Thllnksgivinl! lit 7:00 p,m. Ilnd end on the MondllY fol lowing Thllnksgivlng lit 7:00 p,lII. The mother wi II hllve custody uf the children OVer the Thllnksgivlng hol idllY in thc even numbered Yl'a!'s and the fllthl'r wi II h/lve custody of the chi Idren over the Thanksgiving hol idllY in ,uM nUlllhere,1 yellrs, C. Mother's O/lv/ ~'IlUI!!L~.5_.D!!.Y.-,- The mother will hllve custody of the chi ldren every yelll' un mother's dllY Ilnd the fllther wi I I have custody of the chi Idren I'Vl'ry y,'ar on FllttJ('r's OilY. d. Remll in illiLlli2lidays , The mother /lnd fllth"r wi II hl\ve custody of the chi Idren on,," Illternatlng basis on the following holidays: New Years, Fllster, Memorl,tI Ouy, .July 4th, and Labor OIlY. The pcriml of custody wi I I begin on ttll' evening bdore the hoJ idllY ut 6:,10 (l.m, and end on the holillay Ill. 7:00 (l,m. The Illternuting schedull' shall begin with thl' fllth!'r having custody of the chi Idrell on Nl'''' Y""r~ in lCJ97, 5, Both th" nKlthcr Ilnd fathl'r wi II l'ach huVf.' custody of the children for two cOllsecut Ivc unintcrruptl'd ...eeks during tt", summer of every yellr upon p rov I rl i ng t h i rt Y ()O) dllYs nil t i ce tll t hI' II t he I' pll rt Y , Ii, The (lllrty l'I,,'eiving cu.,tody of thtl chi Idren wi II provicle . .' -- WILLIAM G. REAGAN, II, Plaintiff . IN THE COURT OF ro1MON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V8. NO. 96-2475 CIVIL TERM REGINA L. MUMMA, Defendant CIVIL ACTION - LAW IN CUSTODY auJI!R OF CXlRl' AND NClif, thi8 ~. day of 0,1-,10-___ con8ideration of the attached Custody Conciliation and directed a8 follow8: , 1996, upon Report, it i8 ordered 1. The prior Order of thi8 Court dated May 14, 1996 is vacated and replaCed by this Order. 2. The Father, William G. Reagan, II, and the Mother, Regina L. Mumma, shall have shared legal and physical custody of Kyle W. Reagan, born AugU8t 21, 1991 and William G. Reagan, born July 7, 1993. 3. The parties shall have shared physical custody of the Children on an alternating weekly schedule, with the exchange of custody to take place every Friday at 6:30 p.m., begimling with the Father having custody on October 4, 1996. 4. The non-custodial party each week shall have custody of the Children from Wednesday at 5:30 p.m. until the following Thursday, beginning with the Mother having this period of custody on October 2, 1996. It shall be the responsibility of the party having custody of the Children on Thursday morning to take the Children to school, daycare or the Father's residence as appropriate. 5. The parties shall have custo.Jy of the Children on holidays liS follows: A. Christmas. The Christmas holidays shall be divided into Segment A, which shall begin on December 24 at 12:00 noon and end on Christmas Day at 11:00 a.m., and Segment B, which shall begin on Christmas Day at 11:00 a.m. and end on December 26 at 12:00 noon. The Mother shall have custody of the Children durill':! Segment A in even numbered years and during Segment B in odd numbered year8. The Father shall have custody of the Children during Segment A in odd numbered years and during Segment B in even numbered years. B. Thanksgiving. The Thanksgiving holiday shall begin on the I'/ednesday before Thanksgiving at 7:00 p.m. and end on the Monday following Thanksgiving at 7:00 p.m. The Mother shall have custody of the Children over the Thanksgiving holiday in even numbered years and the Father shall have custody of the Children over the Thanksgiving holiday in odd numbered years. C. Mother's Day/Father's Day. The Mother shall have custody of . -, WILLIAM G. REAGAN, II Plaintiff IN THE COURT OF COOMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VIS. NO. 96-2475 CIVIL TERM REGINA L. MUMMA, Defendant CIVIL ACTION - LAW : IN CUSTODY PRIeR JUIlGB: Kevin A. IIess aJS'1OOY CXR:ILIATIOO Sll'IMARY Rmm IN ACaJUlANCB WITH CUlBBRLAND CXUll'Y RULE Of' CIVIL ~'WlJRB 1915.3-8, the undersigned CUstody Conciliator submits the f?llowing report: 1. The pertinent information concerning the Children who are the Bubjects of this litigation is as follows: NAME BIR'l'IIDATE <:tJRIlmrLy IN CUS'lOOY Of' Kyle W. Reagan William G. Reagan August 21, 1991 July 7, 1993 Plaintiff/Father Plaintiff/Father 2. A Conciliation Conference was held on October 2, 1996 with the following individuals in attendance: The Father, William G. Reagan, II, with his counsel, Johnna J. Deily, Esquire, and the Mother, Regina L. Murruna, with her counsel, Joan Carey, Esquire and Matt McClenahen, legal intern. 3. The parties agreed to the entry of an Order in the form as attached. Ock~ Date oJ. I 11(, , (QJ~JL~-JI Dawn S. Sunday, Esqu r Custody ConciJ.iator WILLIAM G. REAGAN, II, Plaint Iff IN THE COURT OF COMMON Pl.EAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 96-2475 CIVIL TERM REGINA L. MUMMA, De tendant IN CUSTODY Q,~QJ:8.0F..C;:QVRJ AND NOW, upon consideration of the attached complaint, It is hereby directed that the parties and their respective counsel appear before n "L,.,) ----'~~:lL_J....~.J.~'nb.t!'the conci 1 lator, at.'..:J~'L_~'._I~q,,\ ',I ,'v~" ),.", ~n the ..da:\__ day of..C.:J.d.<.,lxf., 1996, at I.tgyl .m., 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 of a temporary or permanent order. order. Failure to appear at the conference may prOVide grounds for entry By the Court, .D"'''-lL..J__~_ ) ..J..,u~I.'.!."L,L!..1- II Custody Conefl iator'/ (><;;11" 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. COURT ADMINISTRATOR, 4th FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 240-6200 &'1fRICANSWITH_DI~ElII,..uU'SAc;:r 9f..1999 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable aCCommodations available to disabled individuals having business before the court, please contact 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. , I legal representation and she believed that she was agreeing to a short-term arrangement necessitated by her distance from the father and her work schedule. 7. On May 14, 1996, an Order of Court was entered for primary physical and partial physical custody liS set forth in B stipulation, true and correct copies of which are attached. 8. Since May, 1996, Legal Services, Inc. has tried to negotiate a custody schedule which would maximize the children's contact with both parents. In spite of the mother's understanding that she would be able to see the children at times other than those in the stipulated schedule, the father has been unwilling to expand the mother's contect. 9. The father has not acted in the chi ldren's best interests by denying them reasonable contact with their mother, and has refused to expand her time with the children despite hi5 agreement to do so. 10. The mother feels that it is in the children's best interest to return them to her primary care for reasons including, but not 1 imited to the fOllOWing: a. The mother had been the Children's primary caretaker from their births through Apn1 1996, when she arranged with the father to have the chi ldren on a temporary basis due to her work schedule. b . The mo the r is the par t y who can be s t r 1.1 c ; 1 1 tilt e the children's contact with the other parent. c. The mot he ( ha" prov i ded enl! can cont lnue to prov i de SAlDIS, GUIDO, SHUFF " MASLAND 26 w, Hip 5.... C.rllIl" PA WILLIAM G. REAGAN, II, Plaint.i.ff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-2475 CIVIL TERM vs. REGINA L. MUMMA, Defendant IN CUSTODY STIPULATION FOR CUSTODY AND NOW, comes the Plaintiff, William G. Reagan, II, and the Defendant, Regina L. Mumma who hereby stipulate as follows: (1) Plaintiff is William G. Reagan, II, an adult individual who currently resides at 82 Linda Drive, Lot 50, Mechanicsburg, CUmberland County, Pennsylvania. (2) Defendant is Regina L. Mumma, an adult individual who currently resides at 131 A East Green Street, Mechanicsburg, CUmberland County, Pennsylvania. (3) The parties are the natural mother and natural father of Kyle W. Reagan born 8/21/91 and William G. Reagan born 7/27/93. (4) The parties agree that they shall enjoy joint legal custody of the two children. (5) The parties further agree that primary physical cUBtody at this time will be with the Plaintiff, subject to periods of partial physical custody by the Defendant as follows: (a) Every other weekend from Saturday at 5:00 p.m. until Monday evening at 6:00 p.m.; and (b) Alternating holidays, at times to be mutually agreed upon between the parties; and (c) The parties further agree that on weekends where the Plaintiff works, the Defendant will have the first -11 .. .. ~. (~ " j" c:::. , u ,( ~ " '._, (\ .... ., ~. j f: , , I;:! <..J, , ~ ,) J' [1' . I .,1 ['I" (' . :IJ .~. l I '-" , \ ) ,. U (J ,:,, , , -.II' WI~~IAM G. REAGAN, II, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA - NO/jlr- ~V I) CIVIL TERM vs. REGINA L. MUMMA, Defendant IN CUSTODY AND NOW, ORDER OF COURT IV\, 'I '(), 1"1 l.. , upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Onl,L\(1 .s ~>Jn(\o.l.l. t:'...:tb' the conciliator, at _~CI W r.\c\\n ~-,\., 1YIu:..h, ~A the L:)l/~day of J" p( , 1996, at /.::~" /) .m., for a Pre-Hearing Cuatody 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 ~(also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, I I SAlOIS, GUIIIO, I SHUFF'" I MASLAND 'II 26 w, Hiah StJ'tCI . Carli~lc:. PA II I , I By: /) I, ,II) .J" ...l~1 ( "~'I Custody Concil:rator V (--?Jlp-j 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 OET LEOAL HELP. OFFICE OF THE COURT ADMINISTRATOR ONE COURTHOUSE SQUAR~ CARLISLE, PA 17013 (717) 240-6200 on SAIDIS, GUIDO, i SHUFF'" I MASLAND 26 W. Hilh Sll'fel ("1lI1i1l!t.PA Persons Addresses Dates Regina Mumma 131A E. Green St. Mechanicsburg,PA from September 1995 until April 7, 1996 from April 7, 1996 to the present william Reagan 5 Orchard View Trailer Pk Gardners, PA 17324 The mother of the children is Regina Mumma who currently resides at 131 A East Green Street, Mechanicsburg, PA. She lives alone. 4. The father of the children is the Plaintiff. He currently resides with his wife, Tammy Reagan, her daughter Shannon Hudson, and the subject children. 5. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the following persons: none. 6. Plaintiff has not participated as a part or witness, or in another capacity, on other litigation concerning the custody of the children in this or another court. The court, term and number, and its relationship to this action is: Not applicable. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. The court, term and number, ~nd its relationship to this action is: Not applicable. Plaintiff does not know of a person not a party to tha proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. The name and address of such person is: Not applicable. 7. The best interest and permanent welfare of the child will be served by granting the relief requested, as the SAIDIS, GUIDO, SHUFF & MASLAND 26 W. High Street Carlisle, PA II WILLIAM G. REAGAN, II, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO .crt -.2... '!J5- CIVIL TERM REGINA L. MUMMA, Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW COMES the Plaintiff, William G. Reagan, II, by and through his attorneys Saidis, Guido, Shuff & Masland respectfully avers the following in support of his Petition: 1. The Plaintiff is William G. Reagan, II, an adult individual residing at 5 Orchard View Trailer Park, Gardners, Cumberland County, Pennsylvania. 2. The Defendant is Regina L. Mumma an adult individual residing at 131 A East Green Street, Mechanicsburg, Pennsylvania. 3. The Plaintiff seeks custody of the following children, Kyle W. Reagan born 8/21/91 and William G. Reagan born 7/27/93 and their present address is with him. The children were born out of wedlock. The children are presently in the custody of the Plaintiff, William G. Reagan, who currently resides at 5 Orchard View Trailer Park, Gardners, PA. During the past five years the children have resided with the following people at the following addresses: Persons Addresses Dates Both parties "A" Street Carlisle, PA from birth until September 19, 1995 SAIDIS, GUIDO, SHUFF & MASLAND 26 W. High Street Carlisle, PA II Persons Addresses Dates Regina Mumma from September 1995 until April 7, 1996 131A E. Green St. Mechanicsburg,PA william Reagan 5 Orchard View Trailer Pk Gardners, PA l7324 from April 7, 1996 to the present The mother of the children is Regina Mumma who currently resides at 131 A East Green Street, Mechanicsburg, PA. She lives alone. 4. The father of the children is the Plaintiff. He currently resides with his wife, Tammy Reagan, her daughter Shannon Hudson, and the subject children. 5. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the following persons: none. 6. Plaintiff has not participated as a part or witness, or in another capacity, on other litigation concerning the custody of the children in this or another court. The court, term and number, and its relationship to this action is: Not applicable. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. The court, term and number, and its relationship to this action is: Not applicable. 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. The name and address of such person is: Not applicable. 7. The best interest and permanent welfare of the child will be served by granting the relief requested, as the ,?) >1. ...,,-- :0 r-(; 'r7 f€ ~ ( 7) o(z:,3~ )/ I (Jo1// 'Iv ~p [J if) ZZZg-tvZ (L I Ll 3NOHd tJOL I 'YNN3d '3,SI1~Y:) 1.33~J's HDlH 'M. 9Z 09, XOll '0 'd ONV'ISVW l' OOHl~ 'SIOIVS S3:)lddO M.Y, li.OOLSLD MOd .LNDi'IdW:lJ ~UEp1.18JeC1 '<IWWClW . 'I ';iNI::ffi{ 'SA :Jn~1IE!ld 'II 'NiBWli .~ WVI'I'IIM li.GOLSLD NI Wl!3.L 'IIl\I;:J . ou VINVl\'Ili.SNNad 'x.LNll(X) ~ ,,0 SWId NCX\IWCXl dO ,LWl(X) 3HJ, NI , "~1 I t, . ".'" Ii'" ::; / ,'.~ ,'. " -,;I I WILLIAM G. REAGAN, II, Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA : vs. : CIVIL ACTION - LAW NO. 96-2475 REGINA L. MUMMA, : Defendant : ORDER OF CXXJRT AND ~, this l4th day of May, 1996, the Conciliator being advised by Plaintiff's counsel that all custody issues have been resolved by agreement, hereby relinquishes jurisdiction in this case. (~M~,~ Dawn S. Sunday, E 1re Custody Conciliator SAIDIS, GUIDO, SHUFF & MASLAND 26 W. High Street Carlisle, PA II WILLIAM G. REAGAN, II, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA .~ vs. No.qfo-;l.{7j CIVIL TERM REGINA L. MUMMA, Defendant IN CUSTODY ORDER OF COURT AND NOW, Me,,-"/ ~ I I 'l"l (" , upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before DaLlX1 S. Svl'ldD.\..{, t:~ 'I conciliator, at Sq U), rY\o.\1'l '3\-. I m~. ~R on the the IJI/~day of J,^M , 1996, at /o,'3i'j). .m., 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 ~iialso be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: 0 c,..<A1), ~~<771--(~5<( Custody Concil' ator ~~ 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. OFFICE OF THE COURT ADMINISTRATOR ONE COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-6200 ~~ ~, .?2. /7irt?w1 4k,J ~t? w' /,- .;;.;;;; r;z. /f7'1:7t-f/ ~u.. ?.p" 0/5 ~0 ~.rz ~714/ ~ . T'T? ?t" 0/'5' It" ", . t .<., , , - -'- :1::1 SAIDIS, GUIDO, SHUFF & MASLAND 26 w. High Street Carlisle. PA WILLIAM G. REAGAN, II, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 96-2475 CIVIL TERM REGINA L. MUMMA, Defendant IN CUSTODY STIPULATION FOR CUSTODY AND NOW, comes the Plaintiff, William G. Reagan, II, and the Defendant, Regina L. Mumma who hereby stipulate as follows: (1) Plaintiff is William G. Reagan, II, an adult individual who currently resides at 82 Linda Drive, Lot 50, Mechanicsburg, Cumberland County, Pennsylvania. (2) Defendant is Regina L. Mumma, an adult individual who currently resides at 131 A East Green Street, Mechanicsburg, Cumberland County, Pennsylvania. (3) The parties are the natural mother and natural father of Kyle W. Reagan born 8/21/91 and William G. Reagan born 7/27/93. (4) The parties agree that they shall enjoy joint legal custody of the two children. (5) The parties further agree that primary physical custody at this time will be with the Plaintiff, subject to periods of partial physical custody by the Defendant as follows: (a) Every other weekend from Saturday at 5:00 p.m. until Monday evening at 6:00 p,m.; and (b) Alternating holidays, at times to be mutually agreed upon between the parties; and (c) The parties further agree that on weekends where the Plaintiff works. the Defendant will have the first SAIDIS, GUIDO, SHUFF & MASLAND 26 W. High Street Carlisle. PA opportunity to enjoy a period of partial custody with the children; Plaintiff will give Defendant 24 hours notice of his intentions as to the non-custodial weekend; and (d) The parties further agree that additional periods of partial custody by the Defendant will be provided, as long as the Defendant gives Plaintiff 48 hours notice of her intention to exercise visitation, and as long as the Defendant does not have anything else planned for the children. (6) The parties desire that this Agreement be evidenced by an Order of Court. WHEREFORE, the parties hereto request Your Honorable Court to enter an Order for custody pursuant to the Stipulation as set forth above. . ~Jha~.- W~tness ~.. ~..Jl;' ~ZZ- william G. Reagan, II ~;J otiLL: -~. Witness L. Mumma SAIDIS, GUIDO, SHUFF & MASLAND 26 W. High Street Carlisle, PA Ii WILLIAM G. REAGAN, II, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 96-2475 CIVIL TERM REGINA L. MUMMA, Defendant IN CUSTODY ORDER AND NOW, this I 'f . tnay , 1996, upon day of consideration of the attached Stipulation, it is hereby ordered and directed that the parties shall share legal custody of Kyle W. Reagan (D.O.B. 8/21/91) and William G. Reagan (D.O.B. 7/27/93). It is further ordered that the Petitioner, William G. Reagan, II, shall have primary physical custody of said children, subject to periods of partial physical custody by the Defendant, Regina L. Mumma, as set forth in the attached Stipulation. BY THE COURT, /)// J. WILLIAM G. REAGAN, II, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 96-2475 CIVIL TERM REGINA L. MUMMA, Defendant IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER The defendant, Regina L. Mumma, avers the following by and through her attorney, Joan Carey of Legal Services, Inc.: 1. The defendant, REGINA L. MUMMA, hereinafter referred to as the mother, is an adult individual residing at 131A East Green Street, Mechanicsburg, PA 17055. 2. The plaintiff, WILLIAM G. REAGAN, II, hereinafter referred to as the father, is an adult individual residing at 82 Linda Drive, Mechanicsburg, PA 17055. 3. The parties are the natural parents of Kyle W. Reagan, date of birth August 21, 1991, and William G. Reagan date of birth, July 27, 1993. 4. On May 8, 1996, a complaint for custody was filed by the father, and a conciliation conference was scheduled for June 12, 1996. 5. Before the scheduled date of the conciliation conference, the parties agreed on May 14, 1996, to a stipulation for custody granting the plaintiff primary physical custody, the defendant partial physical custody, and the parties shared legal custody. 6. The mother agreed to the stipulation for custody without SAIDIS, GUIDO, SHUFF & MASLAND 26 w, High SIrtC\ Carlisle. PA WILLIAM G. REAGAN, II, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-2475 CIVIL TERM v. REGINA L. MUMMA, Defendant IN CUSTODY ORDER AND NOW, this I '{ . , 1996, upon day of rna,., consideration of the attached Stipulation, it is hereby ordered , and directed that the parties shall share legal custody of Kyle W. \ -;; Reagan (D.O.B. 8/21/91) and William G. Reagan (D.O.B. 7/27/93). It is further ordered that the Petitioner, William G. Reagan, II, 1 ! shall have primary physical custody of said children, subject to ! periods of partial physical custody by the nefendant... Regina L. ! i! I II ! :[ Mumma, as set forth in the attached Stipulation. BY THE COURT, .4;/ J. TRUE COpy FRO,\--t RECORD In Testimony v/hereof, I here unto set my hand and the seal of said Court at Carlisle, Pa. i Th' 7/1'1':' /3. ~( IS ...,.!!,-(........... day. Of.U~<<,. ..~......, 19...!!?. ..J ., ~: / l~ ),7 ......,..,..,'7ir<.;....t:pr~:~~;r':;p..- SAlOIS. GUIDO. SHUFF & MASLAND 26 W, High S_t Carlisle. PA WILLIAM G. REAGAN, II, Plaintiff IN THE COURT OF COMMON PLEAS bF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-2475 CIVIL TERM vs. REGINA L. MUMMA, Defendant : IN CUSTODY STIPULl'~TION FOR CUSTODY AND NOW, comes the Plaintiff, William G. Reagan, II, and the Defendant, Regina L. Mumma who hereby stipulate as follows: (1) Plaintiff is William G. Reagan, II, an adult individual who currently resides at 82 Linda Drive, Lot 50, Mechanicsburg, CUmberland County, Pennsylvania. (2) Defendant is Regina L. Mumma, an adult individual who currently resides at 13~ A East Green Street, Mechanicsburg, Cumberland County, Pennsylvania. (3) The parties are the natural mother and natural father of Kyle W. Reagan born 8/21/9~ and William G. Reagan born 7/27/93. (4) The parties agree that they shall enjoy joint legal custody of the two children. (5) The parties further agree that primary physical custody at this time will be with the Plaintiff, subject to periods of partial physical custody by the Defendant as follows: (a) Every other weekend from Saturday at 5:00 p.m. until Monday evening at 6:00 p.m.; and (b) Alternating holidays, at times to be mutually agreed upon between the parties; and (e) The parties further agree that on weekends where the Plaintiff works, the Defendant will have the first AlDIS, GUIDO, SHUFF & MASLAND 26 W, High Street Carlisle, PA , ;) (! ! i opportunity to enjoy a period of partial custody with the . children; Plaintiff will give Defendant 24 hours notice of his intentions as to the non-custodial weekend; and (d) The parties further agree that additional periods of partial custody by the Defendant will be provided, as 'i long as the Defendant gives Plaintiff 48 hours notice of her intention to exercise visitation, and as long as the Defendant does not have anything else planned for the children. i I by I I , I (6) The parties desire that this Agreement be evidenced an Order of Court. WHEREFORE, the parties hereto request Your Honorable Court I to enter an Order for custody pursuant to the Stipula~ion as set forth above. ~rC~ Witness ~.-:m.. ~ ~r1- William G. Reagan, II ~w)q;;~ ----~ Witness L. Mumma D~;'. !!t~ ~. 0~, r:i~ 2::,'.' f~c C ~,. C) c 10 L,.j o ""'-:1 .~ .'~71 :: r!l -~9 '-)0 '::~::n ;; (') (jrn --t ~ -< j') 1 "J t (,7\ -'i':~ "J :::> .;:- WILLIAM G. REAGAN, II, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 96-2475 CIVIL TERM REGINA L. MUMMA, Defendant IN CUSTODY , ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before I1-vll S', S:"y",bt"the conciliator, at -:<4 0, I"')ctlt,')f ~~.IlI(~n45 the M day of -CJctol:xy , 1996, at tlW.4, .m., 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. By the Court, 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. COURT ADMINISTRATOR, 4th FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUmberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact 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. 4r~t. ," 0/ ~ Mp 9N't "'T?0 p rrr?~,q' ~tL-~- oj- 0 r X ~ fif'~?1/ I#; 'r; ~6 illl} \-,',I\r"I.',"1 r'-':\I~I~r:I ,',"';':1\,;/\":-11,',' -; I " .,', ~. __ - .....J ;',' , :': r.:,""'~\l,^'r)'l . " i 'I :2 lU 0 I Ij'P ~,- "..; U . ;J ~;t,l N:NJ....'I....' ,,' , .'.,-, 'f\JI'-'"\_! ,,'j ",: .-:,) ~"I:I '0 '.' .....J, j ;I", ~ -Ojll:l WILLIAM G. REAGAN, II, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 96-2475 CIVIL TERM REGINA L. MUMMA, : CIVIL ACTION - LAW Defendant : IN CUSTODY OODER OF CXXJRT AND ~, this 'r consideration of the attached and directed as follows: day of Ou-. /,.<- , 1996, upon Custody Conciliation Report, it is ordered 1. The prior Order of this Court dated May 14, 1996 is vacated and replaced by this Order. 2. The Father, William G. Reagan, II, and the Mother, Regina L. Mumma, shall have shared legal and physical custody of Kyle W. Reagan, born August 2l, 1991 and William G. Reagan, born July 7, 1993. 3. The parties shall have shared physical custody of the Children on an alternating weekly schedule, with the exchange of custody to take place every Friday at 6:30 p.m., beginning with the Father having custody on October 4, 1996. 4. The non-custodial party each week shall have custody of the Children from Wednesday at 5:30 p.m. until the following Thursday, beginning with the Mother having this period of custody on October 2, 1996. It shall be the responsibili ty of the party having custody of the Children on Thursday morning to take the Children to school, daycare or the Father's residence as appropriate. 5. The parties shall have custody of the Children on holidays as follows: A. Christmas. The Christmas holidays shall be divided into Segment A, which shall begin on December 24 at 12:00 noon and end on Christmas Day at 11:00 a.m., and Segment B, which shall begin on Christmas Day at ll:OO a.m. and end on December 26 at l2:00 noon. The Mother shall have custody of the Children during Segment A in even numbered years and during Segment B in odd numbered years. The Father shall have custody of the Children during Segment A in odd numbered years and during Segment B in even numbered years. B. Thanksgiving. The Thanksgiving holiday shall begin on the Wednesday before Thanksgiving at 7:00 p.m. and end on the Monday following Thanksgiving at 7:00 p.m. The Mother shall have custody of the Children over the Thanksgiving holiday in even numbered years and the Father shall have custody of the Children over the Thanksgiving holiday in odd numbered years. C. Mother's Day/Father's Day. The Mother shall have custody of the Children in every year on Mother's Day and the Father shall have custody of the Children in every year on Father's Day. D. Remaining holidays. The parties shall have custody of the Children on an alternating basis on the following holidays: New Years, Easter, Memorial Day, July 4th, and Labor Day. The period of custody shall begin on the evening before the holiday at 6:30 p.m. and end on the holiday at 7:00 p.m. The alternating schedule shall begin with the Father having custody of the Children on New Years in 1997. 6. Each party shall have custody of the Children for two consecutive uninterrupted weeks during the summer of every year upon providing thirty (30) days advance notice to the other party. 7. The party receiving custody of the Children under this Order shall provide transportation for the exchange of custody. 8. 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. BY THE COURT, cc: Johnna Deily, Esquire - Counsel for laintiff Joan Carey, Esquire - Counsel for Defendant /IlL J. f'....&,4.',~~ ID/7/% -1/- ..0 f' WILLIAM G. REAGAN I II : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 96-2475 CIVIL TERM REGINA L. MUMMA, : CIVIL ACTION - LAW Defendant : IN CUSTODY PRIOR JUDGE: Kevin A. Hess CUSTODY CXl!1CILIATICJ!I SUlMARY REPORT IN ACCORDANCE WITH CUMBERLAND CCUlTY RULE OF CIVIL PROCEDURE 19l5.3-8, the undersigned Custody Conciliator submits the following report: l. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME BIRTHDATE CURRtNl'LY IN CUSTODY OF Kyle W. Reagan William G. Reagan August 21, 1991 July 7, 1993 Plaintiff/Father Plaintiff/Father 2. A Conciliation Conference was held on October 2, 1996 with the following individuals in attendance: The Father, William G. Reagan, II, with his counsel, Johnna J. Deily, Esquire, and the Mother, Regina L. Mumma, with her counsel, Joan Carey, Esquire and Matt McClenahen, legal intern. 3. The parties agreed to the entry of an Order in the form as attached. OcJ.obvi Date cJ. I 91~ , IJh~71 Dawn S. Sunday, Esquir Custody Conciliator . WILLIAM G. REAGAN, II, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 96-2475 CIVIL 1992 REGINA L. MUMMA, Defendant CUSTODY ORDER OF COURT AND NOW this z...Z vi day of ])". l.v' , 1997, the Order of Court entered October 7, 1996 is vacated and upon consideration of the parties' Consent Agreement, the following Order is entered with regard to custody of the parties' children, Kyle W. Reagan (DOB:08/21/91) and William G. Reagan (DOB: 07/07/93) : 1. The plaintiff, William G. Reagan, II, hereinafter referred to as the father and the defendant, Regina L. Mumma, hereinafter referred to as the mother shall share legal custody of the children. 2. The mother shall have primary physical custody of the children. 3. The father shall have partial custody of the children every other weekend from Friday at 6:30 p.m. to Sunday at 6:30 p.m. and shall also have weekdays during the summer months when the children are out of school until one week before the school year begins. 4. The parties shall have custody of the children on holidays as follows: a. Christmas. The Christmas holidays shall be divided into Segment A, which shall begin on December 24 at 12:00 noon and end on Christmas Day at 11:00 a.m., and Segment B, which shall begin on Christmas Day at 11:00 a.m. and end on December 26 at 12:00 noon. The mother shall have custody of the children during Segment A in even numbered years and during Segment B in odd numbered years. The father shall have custody of the children during Segment A in odd numbered years and during Segment B in even numbered years. b. Thanksgiving. The Thanksgiving holiday shall begin on the Wednesday before Thanksgiving at 7:00 p.m. and end on the Monday following Thanksgiving at 7:00 p.m. The mother shall have custody of the children over the Thanksgiving holiday in the even numbered years and the father shall have custody of the children over the Thanksgiving holiday in odd numbered years. c. Mother's Day/ Father's Day. The mother shall have custody of the children every year on mother's day and the father shall have custody of the children every year on Father's Day. d. Remaining Holidays. The mother and father shall have custody of the children on an alternating basis on the following holidays: New Years, Easter, Memorial Day, July 4th, and Labor Day. The period of custody shall begin on the evening before the holiday at 6:30 p.m. and end on the holiday at 7:00 p.m. The alternating schedule shall begin with the father having custody of the children on New Years in 1997. 5. Both the mother and father shall each have custody of the children for two consecutive uninterrupted weeks during the summer of every year upon providing thirty (30) days notice to the other party. 6. The party receiving custody of the children shall provide transportation during the exchange of custody. 7. The mother and father, by mutual agreement, may vary from this schedule at any time, but the Order shall remain in effect until further order of court. By the Court, Johnna Deily Attorney for Plaintiff A Joan Carey Attorney for Defendant WILLIAM G. REAGAN, II, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 96-2475 CIVIL 1992 REGINA L. MUMMA, Defendant CUSTODY CONSENT AGREEMENT This Agreement is entered on this 17"P- day of ~~~ 1997, by the plaintiff, William G. Reagan, II, hereinafter referred to as the father and the defendant, Regina L. Mumma, hereinafter referred to as the mother. The father is represented by Johnna Deily of Saidis, Guido, Shuff and Maslandj the mother is represented by Joan Carey of Legal Services, Inc. The father and the mother agree to the entry of the following Custody Order vacating the Order of Court entered October 7, 1996, and enter the following Order regarding custody of their children, Kyle W. Reagan (DOB:08/21/91) and William G. Reagan (DOB: 07/07/93): 1. The father and mother will have shared legal custody of the chi ldren. 2. The mother will have primary physical custody of the children. 3. The father will have partial custody of the children every other weekend from Friday at 6:30 p.m. to Sunday at 6:30 p.m. and will also have weekdays during the summer months when the children are out of school until one week before the school year begins. 4. The parties will have custody of the children on holidays as follows: a, Christmas. The Christmas holidays will be divided into Segment A, which will begin on December 24 at 12:00 noon and end on Christmas . . Day at 11:00 a.m., and Segment B, which will begin on Christmas Day at 11:00 a.m. and end on December 26 at 12:00 noon. The mother will have custody of the children during Segment A in even numbered years and during Segment B in odd numbered years. The father will have custody of the children during Segment A in odd numbered years and during Segment B in even numbered years. b. Thanksgiving. The Thanksgiving holiday will begin on the Wednesday before Thanksgiving at 7:00 p.m. and end on the Monday fOllowing Thanksgiving at 7:00 p.m. The mother will have custody of the children over the Thanksgiving holiday in the even numbered years and the father will have custody of the children over the Thanksgiving holiday in odd numbered years. c. Mother's Dav/ Father's Dav. The mother will have custody of the children every year on mother's day and the father will have custody of the children every year on Father's Day. d. Remaining Holidays. The mother and father will have custody of the children on an alternating basis on the following holidays: New Years, Easter, Memorial Day, July 4th, and Labor Day. The period of custody will begin on the evening before the holiday at 6:30 p.m. and end on the holiday at 7:00 p.m. The alternating schedule shall begin with the father having custody of the children on New Years in 1997. 5. Both the mother and father will each have custody of the children for two consecutive uninterrupted weeks during the summer of every year upon providing thirty (30) days notice to the other party. 6. The party receiving custody of the children will provide transportation during the exchange of custody. 7. The mother and father, by mutual agreement, may vary from this schedule at any time, but the Order will remain in effect until further order of court. WHEREFORE, the parties request that an Order of Court be entered to reflect the above terms. ...., ~#/. '..1...- ..i!J ~~.d William G. Reagan, I, Plaintiff / C ' J ---~ R,:;J:LMu Dfd eglna . mma, e en ant & Masland r ~ ~y Attorney for Defendant LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 __,--:.~0:.<'~~S;\ f:" ,\\\\11 ,>' . , f<;f~-;:' \ ~'; ,i.,' > "," , '" ,.__.....~:' \../j ~>.' i.. \. " , ,., ''''-"'- \ \ "."~"",,, -- ,"\' \\ ' -- ',\\ \Y \\ \\ 'I \ \9S)1 '{, i 1\ \ \ ! \ ....\\11 - II, .' I \ \", \ \' _J..<' , \\ ~~\ '. _-"- " :.J \'~ l-. -.-". _..- - ~:.>- c") -,.~, I -, ,J :;i _ J LINDA K. MUMMA Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, REGINA LEE MUMMA WILLIAM G, REAGAN, II Co-Respondents CIVIL ACTION - LAW CUSTODY NO, 96-2475 CIVIL TERM 192Z CERTIFICATE OF SERVICE (j /) f( I hereby certifY that on this date, t1 70 , 1998, a copy of the Petition for Emergency Relief and Petition for Modification of Custody was served to the following person by Hand Delivery at I :00 PM: Regina Lee Muuma Address unknown \"D C} :::~) Tl C) --, 'Tj ,") :D 1'1'1 ..... .. ,- "-;.- In ~C:~ :,^, '.::;CJ rf) <=> , 2~ .::iC) .,--' -,', <' -.J ~,.2?5 ~;;~... . _:,;. "ccO r:-? :jr'n :;;"""c": c-< ...<. ~ =< OJ -< LINDA K, MUMMA Petitioner REGINA LEE MUMMA WILLIAM G, REAGAN, II Co-Respondents v, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : CUSTODY : NO. 96-2475 CIVIL TERM 1992 PETITION FOR MODIFICATION OF CUSTODY 1. The Petitioner is Linda K, Mumma, residing at Lot #13 Tapeworm Road, Shermansdale, PA 17090, 2, The Co-Respondents are Regina Lee Mumma, address unknown and William G, Reagan, II, residing at 222 B, Street Carlisle, PA 17013, 3. Petitioner seeks custody of the following children: NAME Kyle W, Reagan William G, Reagan RESIDENCE DaB AGE Lot # 13, Tapeworm Road, Shermansdale Lot #13, Tapeworm Road, Shermansdale 8/21/91 7/27/93 7 yrs, 2 mths, 5 yrs, 3 mths, The children were born out of wedlock. The children are presently in the custody of Linda K, Mumma, During their lives, the children have resided with the following persons and at the following addresses: NAME Linda K. Mumma Regina Mumma Regina Mumma Regina Mumma and William Reagan Regina Mumma and William Reagan Regina Mumma and William Reagan ADDRESS Lot # 13 Tapeworm Road, Shermsansdale, P A Homeless; residing in vehicle Green Street, Mechanicsburg, P A DATES 09/98 to present 08/98 to 09/98 08/96 to 08/98 Pitt Street and A Street, Carlisle, P A 08/95 to 08/96 James Wilson Safe Harbor, Shelter, Carlisle 11194 to 08/95 Green Street, Mechanicsburg, P A 06/92 to 11/94 The mother of the children is Regina L. Mumma, address unknown, She is unmarried, The father of the children is William G, Reagan, II , currently residing at 222 B Street, Carlisle, PA 17013 , He is married, 4, The relationship of the Petitioner to the children is that of grandmother, The Petitioner currently resides with the following persons: John Andrewes, fiance, Kyle W, Reagan, grandson and William G, Reagan, grandson, 5, The relationship of the Co-Respondents to the children is that of mother and father. The Co- Respondents currently resides with the following persons: Regina L. Mumma currently resides with Tim Graham and William G, Reagan, II currently resides with Heather, girlfriend, 6, Petitioner 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, However, Petitioner has information of a custody proceeding concerning the children pending in a Court of this Commonwealth, namely Cumberland County, docketed at #96-2475, (See copy attached as Petitioner's Exhibit "A") 7, Petitioner does not know ofa 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, 8, The best interest and permanent welfare of the children will be served by granting the relief requested for the following reasons: A, Petitioner has undertaken and performed the primary parental responsibilities for each of the children; and B, Petitioner is best able to provide the care and nurture which the children need for health development; and C, Petitioner desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the children, D, A court ordered determination of custody is required to avoid continuing conflict between parties regarding parental responsibility for custody and support, E, Co-Respondent, Regina L. Mumma is erratic, and her boyfriend's abusive behavior poses a threat of harm to the children. F. Co-Respondent, Regina L. Mumma is currently homeless and living in an automobile, G, Co-Respondent, Regina L. Mumma frequently abuses alcohol and is therefore unreliable as custodian of the children, 8, Each parent whose parental rights to the children have not been terminated and the person who has physical custody ofthe children have been named as parties to this action, 9, Additional averments supporting Petitioner's request for temporary or special relief: A. Petitioner continues to maintain the same family household for the children that has been maintained since September 13, 1998. The Co-Respondents have moved from the family residence into an automobile, B, The continuing welfare of the children will be assured if temporary custody is awarded to the Petitioner pending the hearing on this petition subject to such partial custody for purposes of visitation as may be mutually agreed between the parties, WHEREFORE, Petitioner requests the Court to grant custody ofthe children to Petitioner subject to structured partial custody by the co-Respondents pending the hearing, R~porrbmi"'< (h M- By \~ 'M1lX Paul Brad~~ t' Esquire Attorney for Petitioner 50 East High Street Carlisle, PAl 70 13 Telephone: (717) 258-8558 Supreme Court ID No, 71786 COMMONWEALTH OF PENNSYLVANIA ) : SS, COUNTY OF CUMBERLAND ) I verifY that the statements made in the foregoing 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:~ LINDA K. MUMMA, Plaintiff , Fj L-E. COPl-1 - WILLIAM G. REAGAN, II, Plaintiff IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 96-2475 CIVIL 1992 REGINA L. MUMMA, Defendant CUSTODY ORDER OF COURT AND NOW this ~Z '" day of Du..Lv- , 1997, the Order of Court entered October 7, 1996 is vacated and upon consideration of the parties' Consent Agreement, the following Order is entered with regard to custody of the parties' children, Kyle W. Reagan (ooB:08/21/91) and William G. Reagan (ooB: 07/07/93): 1. The plaintiff, William G. Reagan, II, hereinafter referred to as the father and the defendant, Regina L. Mumma, hereinafter referred to as the mother shall share legal custody of the children. 2. The mother shall have primary physical custody of the children. 3. The father shall have partial custody of the children every other weekend from Friday at 6:30 p.m. to Sunday at 6:30 p.m. and shall also have weekdays during the summer months when the children are out of school until one week before the school year begins. 4. The parties shall have custody of the children on holidays as follows: a. Christmas. The Christmas holidays shall be divided into Segment A, which shall begin on December 24 at 12:00 noon and end on Christmas Day at 11:00 a.m., and Segment B, which shall begin on Christmas Day at 11:00 a.m. and end on December 26 at 12:00 noon. PETITIONER'S EXHIBIT "A" Page 1 The mother shall have custody of the children during Segment A in even numbered years and during Segment B in odd numbered years. The father shall have custody of the children during Segment A in odd numbered years and during Segment B in even numbered years. b. Thanks~ivin~. The Thanksgiving holiday shall begin on the Wednesday before Thanksgiving at 7:00 p.m. and end on the Monday following Thanksgiving at 7:00 p.m. The mother shall have custody of the children over the Thanksgiving holiday in the even numbered years and the father shall have custody of the children over the Thanksgiving holiday in odd numbered years. c. Mother's Day/ Father's Day. The mother shall have custody of the children every year on mother's day and the father shall have custody of the children every year on Father's Day. d. Remainin~ Holidays. The mother and father shall have custody of the children on an alternating basis on the fOllowing holidays: New Years, Easter, Memorial Day, July 4th, and Labor Day. The period of custody shall begin on the evening before the holiday at 6:30 p.m. and end on the holiday at 7:00 p.m. The alternating schedule shall begin with the father having custody of the children on New Years in 1997. 5. Both the mother and father shall each have custody of the children for two consecutive uninterrupted weeks during the summer of every year upon providing thirty (30) days notice to the other party. 6. The party receiving custody of the children shall provide transportation during the exchange of custody. PETITIONER's EXHIBIT -A" Page 2 . , 7. The mother and father, by mutual agreement, may vary from this schedule at any time, but the Order shall remain in effect until further order of court. By the Court, ~,~.L A Johnna Deily Attorney for Plaintiff Joan Carey Attorney for Defendant ):2../.1 .'l.. (C) '1. ..3,'6' . PETITIONER'S EXHIBIT "A" Page 3 WILLIAM G. REAGAN, II, Plaintiff IN TIlE COURT OF CQ1.MlN PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 96-2475 CIVIL 1992 REGINA L. MUMMA, Defendant CUSTODY CONSENT AGREEMENT This Agreement is entered on this rra.. day of ~~ - 1997, by the plaintiff, William G. Reagan, II, hereinafter referred to as the father and the defendant, Regina L. Mumma, hereinafter referred to as the mother. The father is represented by Johnna Deily of Saidis, Guido, Shuff and Mas land; the mother is represented by Joan Carey of Legal Services, Inc. The father and the mother agree to the entry of the following Custody Order vacating the Order of Court entered October 7, 1996, and enter the following Order regarding custody of their children, Kyle W. Reagan (ooB:08/21/91) and William G. Reagan (DOB: 07/07/93): 1. The father and mother will have shared legal custody of the children. 2. The mother will have primary physical custody of the children. 3. The father will have partial custody of the children every other weekend from Friday at 6:30 p.m. to Sunday at 6:30 p.m. and will also have weekdays during the summer months when the children are out of school until one week before the school year begins. 4. The parties will have custody of the children on holidays as follows: a. Christmas. The Christmas holidays will be divided into Segment A, transportation during the exchange of custody. 7. The mother and father, by mutual agreement, may vary from this schedule at any time, but the Order will remain in effect until further order of court. WHEREFORE, the parties request that an Order of Court be entered to reflect the above terms. '..... ~~A' '.. f___ ~ L4'~....~ 1'("' William G. Reagan, 11, Plaintiff / C,-t Regimf'L. :2 ~ ------ Mumma, Defendant ~~~/ )ban Carey (J Attorney for Defendant LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 John a ei ly. Att ney fo Plaintiff Saidis, Guido, Shuff & Masland 26 W. High Street Carlisle, PA 17013 PETITIONER's EXHIBIT "A" Page 6 LINDA K, MUMMA Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, REGINA LEE MUMMA WILLIAM G, REAGAN, II Co-Respondents CIVIL ACTION - LAW CUSTODY NO, 96-2475 CIVIL TERM 1992 CERTIFICATE OF SERVICE I hereby certify that on this date, 0 Ci T 21 , 1998, I mailed a copy of the Petition for Modification of Custody to the following person at the following address by First Class U.S, Mail, postage prepaid: William G, Reagan, II 222 B Street Carlisle, P A 17013 \(2 Paul Bradfor Orr, Esquire . , LINDA K. MUMMA Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, REGINA LEE MUMMA WILLIAM G, REAGAN, II Co-Respondents CIVIL ACTION - LAW CUSTODY NO, 96-2475 CIVIL TERM 1992 CERTIFICATE OF SERVICE I hereby certifY that on this date, , 1998, 1 mailed a copy of the Petition for Modification of Custody to the following person by Hand Delivery: Regina Lee Mumma ADDRESS UNKNOWN Paul Bradford Orr, Esquire , . 0 ,..0 0 ,= 0) "<1 -:;':" c::> ,-l :,""') r - ." --I ~nr= ;',) --,1,1 ':10 CD ( _1(1.) .,J --i! ,", i--) ., '~ ::'5 1'-' =rn 0 ,.'-' ~j -,' ::0 -< co -< LINDA K, MUMMA Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, REGINA LEE MUMMA WILLIAM G, REAGAN, II Co-Respondents : CIVIL ACTION - LAW : CUSTODY : NO, 96-2475 CIVIL TERM 1992 ORDER OF COURT AND NOW, -ll-I rl- , 191rg , upon consideration of the attached Petition to ModifY Custody, it is hereby directed that the parties arid their respective counsel appear before \::x;.""-<\ 5:" ,~{\d,CJ0-..lt Fc,q, _ ,the conciliator, at ::)9 W" \---Ioui 0\.. ~~ i 9A on the \ day of tJeC e"'N\rx- (' ,199]L, at 3, o'clock, ~,m" 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, FOR THE COURT: By: ~ \ WI ~, ~'ljfV\clo\j I ~ . Custody Conciliator t T,:b,') The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact 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 LA WYER 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, Office of the Court Administrator Cumberland County Court House, Fourth Floor Carlisle, PA 17013 (717) 240-6200 ",~y~ r/J1/~ *(",// (~~) - h ~ ~141' ~t; .Yo- C'// Pj;7 #P~ ~~~-/1l Jp' c:'-// ~ \/j;i\!;/I\lJ.'s\!N=.~ A 1,l\rri('\'-", r" 1-';' ,::"~_:' ...... ,[ 0,_."...1 ".r,'.,-,-:I "...'.;CIt,'\.'......1"'I. ," 'c _,:'C:I<: ~J SO:F; lId 2-11011 8G ,\,tiVIG<,;(<_",'. .." , - "',~') l..J..VU::J "-.,-' I jO 30d:!Q-o::nl:i " SAlOIS, SHUFF & MAS LAND ATrORNEY5"AT.LAW 26 W, High Street Carlisle. PA WILLIAM G. REAGAN, II, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. REGINA L. MUMMA, Defendant NO, 96-2475 Civil 1992 CUSTODY PETITION FOR MODIFICATION AND NOW comes the Petitioner, William G. Reagan, by his attorneys, Saidis, Shuff & Masland and respectfully avers the following in support of this Petition for Modification: 1. petitioner is William G. Reagan, II, an adult individual residing at 224 B Street, Carlisle, Pennsylvania. 2. The Respondent is Regina L. Mumma, whose last known address is with her mother in Perry County. 3. On or about December 22, 1997, the parties entered into an agreed Order for shared physical and legal custody of the two boys, Kyle and William; a copy of said Order is attached hereto, made a part hereof and marked as Exhibit "A". 4. Presently, it appears that the children may be in the custody of their maternal grandmother, Linda Mumma, in Perry County. According to the grandr.lother, she has had custody since September 1, 1998 with no word from their mother. 5. Also according to the grandmother, the Respondent is attempting to sign off her legal and physical custody rights to her mother. 6. Apparently, she has had the boys living in a car, sleeping outside, not feeding them, not allowing them to attend SAID IS, SHUFF & MASLAND A1TORNEYS'AT-LAW 26 W, High Street Carlisle, PA school, and is living with an abusive boyfriend, Further, the Respondent lost her job and is unable to support the children, WHEREFORE, the petitioner respectfully requests Your Honorable Court to enter an Order granting him primary physical custody of the children at this time until a determination is made as to the whereabouts of the mother and whether she will have visitation and/or periods of partial physical custody. Respectfully submitted, SAIDIS, SHUFF & MAS LAND .7 By' ,WILLIAM G. REAGAN, II, Plaint iff IN ThE COURT OF COMMON PLEAS OF ':(lMBERLAND COUNTY, PENNSYLVANIA v. :IVIl ACTION - LAW \0. %<:475 CIVIL 1992 REGINA L. MUMMA, Defendant :lJST(IDY ORDER _~J' lXllJR1: AND NOW this .,;;l.J.....ol day of {).LC'c~);"A~! 1997" the Order of Court entered October 7, 1996 is vacated and upon <;~'IIS iderat ion of the part ies' Consent Agreement, the fOllowing Order is ent"red with regard to custody of the parties' children, Kyle W. Reagan (OOll:1)8/~!1I91) and Wi 11 iam G. Reagan (OOB: 07/07/93) : 1. The plaintiff, William G_ b~agan, II, hereinafter referred to as the father and the defendant, Regina 1.. MU'1ma, hereinafter referred to as the mother shall share legal custody of t'll: ch lldren. 2. The mother shall have primary physical custody of the children. 3. The father shall have parr )a] Gusiody of the children every other weekend from Friday at 6:30 p.m. to Sunday at 6:30 p.m. and shall also have weekdays during the summer months wher the children are out of school unti I one week before the school year begin, 4. The parties shall have Gu,t:Ddy of the children on holidays as follows: a. Christmas. The Christmas holidays shall be divided into Segment A, which shall begin on December 24 at 12: 00 noon and end on Christmas Day at 11 :00 a.m., and Segment B, which shall begin on Christmas Day at 11 :00 a.m. and 'md In December 26 at 12:00 noon. } ~,-",.,"~ The mother shall have custody of the children during Segment A in eve~ numbered years and during Segment B in odd number~d years. The father shall have custody of the children during Segment A in odd numbered years and during Segment B in even numbered years. b. Thanksgiving. The Thanksgiving holiday shall begin on the Wednesday before Thanksgiving at 7:00 p.m. and end on the Monday following Thanksgiving at 7:00 p.m. The mother shall have custody of the children over the Thanksgiving holiday in the even numbered years and the father shall have custody of the children over the Thanksgiving holiday in odd numbered years. c. Mother's Day/ Father's Day. The mother shall have custody of the children every year on mother's day and the father shall have custody of the children every year on Father's Day. d. Remaining Holidays. The mother and father shall have custody of the children on an alternating basis on the following holidays: New Years, Easter, Memorial Day, July 4th, and Labor Day. The period of custody shall begin on the evening before the holiday at ,..,...,.,.,.." ";,, ",6:30p.m. and,end on the holiday at 7:00 p.m. The alternating .i~~>::~J,~h~f~;!~~l'};;:~,X{.:;;,\:;~:;::.:.'i~~;t.:~~;X!i.,'.~;\,",j,;,:" ",.'-",,::_:.:.,:.. . ',"'" ''',' .' ,,' 'schedule shall begin with the father having custody of the children on New Years in 1997. 5. Both the mother and father shall each have custody of the children for two consecutive uninterrupted weeks during the summer of every year upon providing thirty (30) days notice to the other party. 6. The party receiving custody of the children shall provide transportation during the exchange of custody. ~ .-" - - " ~..H n Jl,--=. '.. "'-, '.'-~",- .,'''.... ..d,....,"...,....,.,.., ,. .."",.,..... 7. The mother and father, by mutual agreement, may vary from this schedule at any time, but the Order shall remain in effect until further order of court. By the Court, l.sl~u... ~ Kevin A. Hess, Judge Johnna Deily Attorney for Plaintiff Joan Carey Attorney for Defendant TRUE COpy FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said Court at Carlisle, Pa. This ,.dA~ day oL~~ 19.9,/1.. ~ r. -'OX....J,':'c"."........... .....\!!o....I..l:J.~ . ............ . . of) n . Pro honotary -rulIJIf" If - . , '" ,-, ... ",.i .....- '.' WILLIAM G. REAGAN, II, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA l . () :1 , -11 u_1 _..I v. CIVIL ACTION - LAW ,~ REGINA L. MUMMA, Defendant - -- ~ , ;: ~,~j .--~ (~) c -~1 ~,;~~ -\1'1 :': ) ::::',-\ NO. 96-2475 CIVIL 1992 CUSTODY CONSENT AGREEMENT This Agreement is entered on this / Tn day of Dea...m~ [..,J <--,-, =< 1997, by the plaintiff, William G. Reagan, II, hereinafter referred to as the father and the defendant, Regina L. Mumma, hereinafter referred to as the mother. The father is represented by Johnna Deily of Saidis, Guido, Shuff and Maslandj the mother is represented by Joan Carey of Legal Services, Inc. The father and the mother agree to the entry of the following Custody Order vacating the Order of Court entered October 7, 1996, and enter the following Order regarding custody of their children, Kyle W. Reagan (ooB:08/21/91) and William G. Reagan (DOB: 07/07/93): 1. The father and mother will have shared legal custody of the children. , " , ." 2. '., The IIIOther"wi 11 '~,," ~j;i;;}:3;f'i~'The:"father''Wif 1 have primary physical custody of the children. have partial custody of the children every other weekend from Friday at 6:30 p.m. to Sunday at 6:30 p.m. and will also have weekdays during the summer months when the children are out of sch@Ol until one week before the school year begins. 4. The parties will have custody of the children on holidays as fol lows: a. Christmas. The Christmas holidays will be divided into Segment A, which will begin on December 24 at 12:00 noon and end on Christmas Day at 11:00 a.m., and Segment B, which will begin on Christmas Day at 11:00 a.m. and end on December 26 at 12:00 noo~. The mother will have custody of the children during Segment A in even numbered years and during Segment B in odd numbered years. The father will have custody of the children during Segment A in odd numbered years and during Segment B in even numbered years. b. Thanksgiving, The Thanksgiving holiday will begin on the Wednesday before Thanksgiving at 7:00 p.m. and end on the Monday following Thanksgiving at 7:00 p.m. The mother will have custody of the children over the Thanksgiving holiday in the even numbered years and the father will have custody of the children over the Thanksgiving holiday in odd numbered years. c. Mother's Day/ Father's Day. The mother will have custody of the children every year on mother's day and the father will have custody of the children every year on Father's Day. d. Remaining Holidays. The mother and father will have custody of the children on an alternating basis on the following holidays: New"Years, Easter, Memorial Day, July 4th, and Labor Day. The ;'".''Il'.,''5iii,'l/lii' .;itf":'"r;':'i,:' ;(r~,'~J"f;;t,;1f,r~l!;:("'~" .,,':-',~,,; , "'period of custody wi 11 begin on the evening before the holiday at 6:30 p.m. and end on the holiday at 7:00 p.m. The alternating schedule shall begin with the father having custody of the children on New Years in 1997. 5. Both the mother and father will each have custody of the children for two consecutive uninterrupted weeks during the summer of every year upon providing thirty (30) days notice to the other party. 6. The party receiving custody of the children will provide transportation during the exchange of custody. . 7. The mother and father, by mutual agreement, may vary from this schedule at any time, but the Order will remain in effect until further order of court. WHEREFORE, the parties request that an Order of Court be entered to reflect the above terms. ~#... '..r/ ~ c...t:''1"~ 17" William G. Reagan, I, Plaintiff /...; /(-; -:2 __ U-- Regina L. Mumma, Defendant ~~/ Joan Carey () Attorney for Defendant LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 >- c' c= sz lJ, . i.~ .-..., __:_;,,:1' UJq (.)"/ O~=-, :tr.:. C) ~. ff~L: 0- (~\ :.J C)~:.) cO if? c,n: uJl...L C-.J ~l'; ..... U-~.:.-. <" f~:~ ~.: CO " U, CO :5 0 0' 0 SAlOIS, SHUFF & MAS LAND ATI'ORNEVS'AT'UW 26 W, High Street Carlisle. PA ILLIAM C. REAGAN, II plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. EGINA L. MUMMA, Defendant CIVIL ACTION - LAW NO. 96-2475 Civil '"Blt2 IN CUSTODY ORDER OF COURT AND NOW, II Ja jq<?" upon consideration of the attached Petition for Modification, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esquire, the conciliator, at 39 W. Main Street, Mechanicsburg, Pennsylvania, on ___1C}/ \ 19~ at '7' r""'\ ,::) , v\::> ?m, for a Pre-Hearing Custody Conference. At such an effort wlll be made to resolve the issues in conference, 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 shall also be present: at the conference. Fa,', Lure t,o appear at the conference may provide grounds for entry :::If a temporary or permanent order. FOR THE COURT: By: _c:}S'm \ 'K\..~.1\ 1I~ Custody Conciliator l ,) 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. OFFICE OF THE COURT ADMINISTRATOR ONE COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-6200 ,~.~.!? ~w~ Jp-(:'ll ,~~;l r1:7F1/ ~tL, * L,jl ~ P ~ r~lV ~ -;r.p ~6- r.11 \;'i(.j\f/\!}S'i\ ,~r\J~Jd 'L' [,Inl.....,') /H :\.'-~'" '--;;'""'" 'dn....... I\. I ".-J' ._' ',,:=!':)'~f'0 ~o (' 'I' Z ""8 'j :IJ hd - r.0r" "0 AbV10>J:)ti.~_iv<,;:':; .10 3J:J30-Q:Jli:i LINDA K, MUMMA Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW REGINA LEE MUMMA WILLIAM G, REAGAN, II Co-Respondents : NO. 96-2475 CIVIL TERM 1992 : CUSTODY PETITION FOR EMERGENCY RELIEF 1. The Petitioner is Linda K, Mumma, is the natural grandmother of the two children at the center of this custody proceeding, 2, Co-Respondent, Regina Lee Mumma, is the natural mother of the two children at the center of this custody proceeding, 3, Co-Respondent, William G, Reagan, II, is the natural father of the two children at the center of this custody proceeding, 4, Petitioner, on this same date, has filed a request for a Custody Conciliation Conference in reference to the custody of her two grandchildren, Kyle W, Reagan age seven years and William G, Reagan age five years, (A copy of the Custody Complaint is attached hereto and marked as Petitioner's Exhibit "A") 5, Petitioner alleges that Co-Respondent, Regina L. Mumma, Petitioner's daughter and mother of the two children at the center of this custody proceeding, is unable to care for the children as she is, and has been, living out of her automobile since late August 1998, 6, Petitioner received from Co-Respondent Regina L. Mumma a voluntary transfer of custody by way of a document dated September 13, 1998, (See attached as Petitioner's Exhibit "B") 7, Petitioner has enrolled both children in the Perry County school system and they appear to be doing well at the present time, 8, Petitioner asserts that Co-Respondent, Regina L, Mumma and her current boyfriend, Tim Graham pose a threat to the minor children due to their unstable, abusive, and substance abusing lifestyle, Furthermore, as stated above, Co-Respondent, Regina L. Mumma and her current boyfriend, are living out of their automobile at various locations throughout Cumberland County, 9, Sunday evening, October 25,1998, Co-Respondent, Regina L. Mumma contacted Petitioner and demanded that she return the two minor children to Co-Respondents's custody, Petitioner refused, 10, Petitioner is concerned that the Co-Respondent, Regina L. Mumma will attempt to take the minor children from their home or from their school and therefore respectfully request that the Court enter a temporary Custody Order granting Petitioner temporary custody of both minor children until such time that a hearing on this matter can be established, WHEREFORE, Petitioner respectfully requests that the Court enter an Xes Parte Order granting to Petitioner temporary, primary physical custody of both children subject to temporary visitation to Co- Respondent, William Q, Reagan, II, on alternating weekends, between now and the date of any future custody hearing in order to lend some stability to this volitile situation, - aul Bradford Orr, Esquire Attorney for Petitioner 50 East High Street Carlisle, P A 17013 Telephone: (717) 258-8558 Supreme Court ID No, 71786 Respect 16/21/ q'i< By: COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) I verifY that the statements made in the foregoing 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:~ LINDA K, MUMMA, Plaintiff .. F/l.E Cop!.! < " . - WILLIAM G. REAGAN, II, Plaintiff IN '1lIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 96-2475 CIVIL 1992 REGINA L. MUMMA, Defendant CUSTODY ORDER OF COURT AND NOW this z..Z'" day of ;p". ~ , 1997, the Order of Court entered October 7, 1996 is vacated and upon consideration of the parties' Consent Agreement, the following Order is entered with regard to custody of the parties' children, Kyle W. Reagan (ooB:08/21/91) and William G. Reagan (OOB: 07/07/93): 1. The plaintiff, William G. Reagan, II, hereinafter referred to as the father and the defendant, Regina L. Mumma, hereinafter referred to as the mother shall share legal custody of the children. 2. The mother shall have primary physical custody of the children. 3. The father shall have partial custody of the children every other weekend from Friday at 6:30 p.m. to Sunday at 6:30 p.m. and shall also have weekdays during the summer months when the children are out of school until one week before the school year begins. 4. The parties shall have custody of the children on holidays as follows: a. Christmas. The Christmas holidays shall be divided into Segment A, which shall begin on December 24 at 12:00 noon and end on Christmas Day at 11:00 a.m., and Segment B, which shall begin on Christmas Day at 11:00 a.m. and end on December 26 at 12:00 noon. PETITIONER'S EXHIBIT "A" Page 1 The mother shall have custody of the children during Segment A in even numbered years and during Segment B in odd numbered years. The father shall have custody of the chi ldren during Segment A in odd numbered years and during Segment B in even numbered years. b. Thanksj(iviM. The Thanksgiving holiday shall begin on the Wednesday before Thanksgiving at 7:00 p.m. and end on the Monday following Thanksgiving at 7:00 p.m. The mother shall have custody of the children over the Thanksgiving holiday in the even numbered years and the father shall have custody of the children over the Thanksgiving holiday in odd numbered years. c. Mother's Dav/ Father's Dav. The mother shall have custody of the children every year on mother's day and the father shall have custody of the children every year on Father's Day. d. Remainin~ Holidays. The mother and father shall have custody of the children on an alternating basis on the following holidays: New Years, Easter, Memorial Day. July 4th, and Labor Day. The period of custody shall begin on the evening before the holiday at 6:30 p.m. and end on the holiday at 7:00 p.m. The alternating schedule shall begin with the father having custody of the children on New Years in 1997. 5. Both the mother and father shall each have custody of the children for two consecutive uninterrupted weeks during the summer of every year upon providing thirty (30) days notice to the other party. 6. The party receiving custody of the children shall provide transportation during the exchange of custody. PETITIONER'S EXHIBIT -An Page 2 7. The mother and father, by mutual agreement, may vary from this schedule at any time, but the Order shall remain in effect until further order of court. By the Court, Johnna Deily Attorney for Plaintiff ~,(!.:..... ,~L J:J..f ~ 2. (q '1. u .J,.f' , If Joan Carey Attorney for Defendant PETITIONER'S EXHIBIT "A" Page 3 OONSENT AGREEMENT This Agreement is entered on this / '7 "A day of ~cJ.-rrJk L 1997, by the plaintiff, William G. Reagan, 11, hereinafter referred to as the father and the defendant, Regina L. Mumma, hereinafter referred to as the mother. The father is represented by Johnna Deily of Saidis, Guido, Shuff and Mas land; the mother is represented by Joan Carey of Legal Services, Inc. The father and the mother agree to the entry of the following Custody Order vacating the Order of Court entered October 7, 1996, and enter the following Order regarding custody of their children, Kyle W. Reagan {DOB:08/21/91} and William G. Reagan (DOB: 07/07/93): 1. The father and mother will have shared legal custody of the chi Idren. 2. The mother will have primary physical custody of the children. 3. The father will have partial custody of the children every other weekend from Friday at 6:30 p.m. to Sunday at 6:30 p.m. and will also have weekdays during the summer months when the children are out of school until one week before the school year begins. 4. The parties will have custody of the children on holidays as follows: a. Christmas. The Christmas holidays will be divided into Segment A, transportation during the exchange of custody. 7. The mother and father, by mutual agreement, may vary from this schedule at any time, but1he Order will remain in effect until further order of court. WHEREFORE, the parties request that an Order of Court be entered to reflect the above terms. '.... ~#" '-~~ ..i!J 1.;tP.- -"""f: 4 William G. Reagan, 11, Plaintiff c/ ,-t. Regina' L. -;2, ~ --- Mumma, Defendant ~@U~? )6an Carey { Attorney for Defendant LEGAL SERVICES, INC. a Irvine Row Carlisle, PA 17013 John a ei Iy, Att ney fa Plaintiff Saidis, Guido, Shuff & Mas land 26 W. High Street Carlisle, PA 17013 PETITIONER's EXHIBIT "A" Page 6 September 13, 1998 I Regina Lee Mumma on this 13th day of September 1998 give temporary custody of my sons Kyle William Reagan and William Gene Reagan to my mother Linda K. Mumma to make whatever Heal th and Educational Decisions need to be made in there best interest until I can provide housing, food and their basic needs in a stable home environment. /,~~ ~na Mumma L Linda Mumma Sv~~~J Notary / - ' Notarial S..' SYlan fI, Zlilhtmoy.r, Nollly Public Oent.. iwp" 1"lI"\I COunlV MV ClItI\t1I1S410n tb~ltll. AIl~1 aa, 1002 Mem~.I, ~",lSrMI~" ~_lllilll1 Of Noll"", PETITIONER'S EXHIBIT "B" LINDA K. MUMMA Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, REGINA LEE MUMMA WILLIAM G, REAGAN, II Co-Respondents CIVIL ACTION - LAW CUSTODY NO. 96-2475 CIVIL TERM 1992 CERTIFICATE OF SERVICE I hereby certify that on this date, serV'~ , 1998, IIlllliled a copy of the Petition for Petition of Emergency Relief to the following person by Hand Delivery: Regina Lee Mumma ADDRESS UNKNOWN Paul Bradford Orr, Esquire LINDA K, MUMMA Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, REGINA LEE MUMMA WILLIAM G, REAGAN, II Co-Respondents CIVIL ACTION - LA W CUSTODY NO, 96-2475 CIVIL TERM 1992 CERTIFICATE OF SERVICE I hereby certifY that on this date, 0 (j -r L-- 1 ,1998, I mailed a copy of the Petition for Emergency Relief to the following person at the following address by First Class U,S, Mail, postage prepaid: William G, Reagan, II 222 B Street Carlisle, PA 17013 Paul Bradford Orr, Esquire ...0 <:) CO ,-I " c:> ::-:.~ f~--, ;.-J Ii -11 --I - ,- / N , rn V! IX> -...., <::) r:: ,"',1. --:iCJ 'D or-,i ..li:.: i-~:) :J] -- '-(') ):.~ , r~? ~Sfn '.~~ '.... .._~ ':J 55 -< 0 -< LINDA K, MUMMA Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW REGINA LEE MUMMA and WILLIAM G, REAGAN, II Co-Respondents : NO, 96-2475 CIVIL TERM !!!!lilt : CUSTODY ORDER OF COURT AND NOW (Jw..".. '/'-', 1998, upon consideration of the attached Emergency Petition to Modify Custody, it is hereby directed that the parties and their respective counsel appear before this Honorable Court, at a hearing scheduled for $'tld"J on the I ~ day of ~~/!./ , 1998, at 9.' dl.J o'clock, "- ,m" Cumberland County Courthouse, Courtroom Number Lf , Carlisle, Pennsylvania, Furthermore, upon review of the attached Emergency Petition for Custody, it is hereby directed that Petitioner, Linda K, Mumma, shall have primary physical custody ofthe Co-Respondent's children, Kyle W, Reagan, age seven years and William G, Reagan, age five years until such time as the Emergency Custody hearing is conducted, Co-Respondent, William G, Reagan, II, shall have partial periods of physical custody on alternating weekends until such time as the Custody hearing is conducted, BY THE ~_~URr: . J. By: 0(t. .1/ !C,-, J, ( "P'>>, ">?O;C ~ ') . IT Vob'02r~ . 3 \>>'11' II '0\ ~ 'Q.I n:;.Qj'! r"{J.DW JJO ~V ~ J~l{)~ ~LJ~ ..}'~.'\-.If\l}. (~NN3d '!:l\'{,l], ,,-, . I _1'(1"'\1"') ,....,-..,..., (~\j.fl("l:J~)({: Iv JJ.Ni iU", ,. '" ' ,.. , 8(; :'] ~iJ 82 DO 8S ^1:lV10NGrllOtl~ :.lHi 30 381:l:\o-oall:! LINDA K. MUMMA, Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs, CIVIL ACTION - LAW REGINA LEE MUMMA and WILLIAM G, REAGAN, II, Co-Respondents 96-2475 CIVIL IN RE: PETITION FOR SPECIAL RELIEF ORDER AND NOW, this /3 .. day of November, 1998, on agreement of the parties, our order of October 28, 1998, is V ACA TED conditioned on the mother, Regina Lee Mumma, continuing to reside with her mother, Linda K. Mumma, or, in the alternative, on the mother's obtaining suitable housing agreeable to all of the parties. BY THE COURT, Paul Bradford Orr, Esquire For the Petitioner ,qL Joan Carey, Esquire For Regina Lee Mumma Johnna Deily, Esquire For William G, Reagan II :rlm ~~.<L II /11a /9 8 . .,.i i'. --,'~ ~ \ DEe - 7 199ft! '\-i WILLIAM C. REAGAN, II Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : vs. NO. 96-2475 CIVIL 1992 : REGINA L. MUMMA, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF CXXJRT AND ~, this 1st day of December, 1998, the COnciliator, being advised by counsel for Plaintiff, Defendant and Petitioner maternal grandmother that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction in this case. The CUstody Conciliation COnference scheduled for December 1, 1998 is canceled. FOR THE COURT, &~~ Dawn S. Sunday, Esquire d CUstody COnciliator cc: Johnna J. Deily, Esquire - Counsel for Father (JJJ~ ~).J ,:2/S/qy Joan Carey, Esquire - Counsel for Mother --r r' Paul B. err, Esquire - Counsel forllB<ternal grandmother ., .: ~ '_ 'I, ,.. ._.Li l... .) , /\~. ,- :"J .,.',' J 'L.l