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Home My WebLink About00-00511 " , , . JAMES D. REIBER, V., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW : CUSTODYNISITATION MICHELLE M. ZEIGLER, Defendant : NO. 00- 5 I J CIVIL TERM ORDER OF COURT AND NOW, -----d-I L..\ ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before \\k\\~, G\\r(}.,\) Esc\ . ,theconciliator,at~ ~~)C~rhlJ, \ \. (() ,((l.J,(~"C on the \\ day of \-Arl.n X\ ,2000, at i1-:':SD olclock, 0. .m., for a Pre-Hearing Custody Conference, At such conference, an effort will be made to r~solve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard ~y the Court, and to enter into a temporary order, All children age five or older may also be present at the co~ference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent :9rder. , , FOR THE COURT: By:_% &JU0.: 1'\( ~j.QnaA. ,C1l. Custody Conciliator U I ( \V') The Court of Common Pleas of Cwnberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. you must attend the scheduled conference or hearing. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Office of the Court Adminislrator Cumberland County Court House, Fourth Floor Carlisle, P A 17013 (717) 240-6200 ~ ;;; . /,() .,p,() ,;( -/o-,()":? ,;}'/o-o,# ,~ -.~ .. HLED-OfRC:. OF fJr;;c:n*[C':I-.,{)TARY 1"0 fr.. Q \ n pi';' I: t; n u ~~u ... . \ 1 ',- >.,f C'\ il\)q~I')1 t,;\.!i") i.~iJ~\Ui~TY ..) "I ',~"~ ,.,... " ,-~ ,", n\_'C'-l\!1\\Q'(l' \ft\i\\1(j, l\j] 'V ~-.I-';'''' M. ~ ~~ ;;! d2u.. 71~ ~ Z . a . {-I~~-<'v #-~ /-&. - "'!'-~"'r , ~ ~~-.,~, ~, ~. """" 1,. __ ~ RJ~"I~~ -- .0_ ~ " . . JAMES D. REIBER, V., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : CUSTODYNISITATION MICHELLE M. ZEIGLER, Defendant : NO. 00- S / I CIVIL TERM COMPLAINT FOR CUSTODY 1. The Plaintiff is James D. Reiber, V., residing at 20 Heather Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Michelle M. Zeigler, residing at 323 North East Streel, Carlisle, qumberland County, Pennsylvania 17013, 3. Plaintiff seeks custody of the following children: NAME RESIDENCE DOB AGE Kelsie D. Reiber Garrett M. Reiber 323 North East Street, Carlisle, P A 323 North East Street, Carlisle, P A 1/15/96 1/14/98 4 years 2 years 4. The children were born out of wedlock. 5. The children are presently in the custody of Michelle M. Zeigler. 6. During their lives, the children have resided with the following persons and at the following addresses: NAME Michelle M. Zeigler and James D. Reiber ADDRESS DATES 51 Nable Drive, Carlisle, P A 1/15/96 to 4/15/96 Michelle M. Zeigler 3454 Spring Road, Carlisle, P A 4/15/96 to 4/15/97 Michelle M. Zeigler and James D. Reiber 323 North East Street, Carlisle, P A 4/97 to 4/98 Michelle M. Zeigler 323 North East Street, Carlisle, PA 5/98 to present " ,~ , ~, _1. ,'- ~"-'f,' 7. The mother of the children is Michelle M. Zeigler, currently residing at 323 North B,ast Street, Carlisle, Pennsylvania. She is unmarried, 8. The father of the children is James D. Reiber, V. currently residing at 20 Heather Drive, Carlisle, Pennsylvania. He is unmarried. 9, The relationship of the Plaintiff to the children is that of Father. The Plaintiff currently resides with the following persons: Brandi J. McAster, girlfriend. 10. The relationship of Ihe Defendant to the children is that of Mother. The Defendant currently resides with lhe following persons: Eric, boyfriend. II. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 12. Plaintiff has no information of a custody proceeding concerning the children pendihg in a court , of this Commonwealth. 13. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 14. The best interest and permanent welfare of the children will be served by granting jhe relief requested for the following reasons: A. A Court Order of custody and structured visitation is desired so that the Plaintiff and the children may plain their schedules accordingly, and so lhat misunderstandings and unm,et , expectations regarding custody and visitation can be avoided, and also so that the children are not used in a manipulative fashion. B. A Court Ordered detennination of custody is required to avoid continuing conflict between the parties regarding parental responsibility for custody and support. _;;.it-"'''''''''''-' -1-- ':, . ' 15. Each parent whose parental rights to the children have not been terminated and the,person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant custody of the children to the Plaintiff and Defendant pending the hearing. Respectfully submitted, l-dJ-DO By:4~u!:(!? Attorney for Plaintiff 50 East High Street Carlisle, P A 17013 Telephone: (717) 258-8558 Supreme Court ill No. 73471 y'~ -~ , ...' . . . ~ . . . . VERIFICATION 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. 1/:J...t/oV 9 J 11 DATE: I I v . ~~4" James D. Reiber, V., Plaintiff --- . ~~-" "..,.,.. ~-- ~_~_4 ,,, -11Ill1li'l!lli1 ---~ "- "'-" C~, L.' ,. -' [1]1 0 C) ~ c 0 :? 'Dt'e: '-- :.:'1 :~~. m,,-\ -'~... ->,:Jj Z:TJ ~,"- c.' ~~ N :-~lB -.' '. ' ~C:: ~ :~:~ (j ""1 )> ~?,;Q Z(j ~~2 1'0 om L. -, ~ "'- :'..'1 =< <J,) :D -< ~ y" . - " . ~ - ~ '; ~ .. ~",y",,-- .,,;-t- ~-",'- ,,"0 '_;',~ _, . '.' I,," , ,- C.~ "."tjo" ;<,,{I~;___ ~ :"\-'..r<---~ -^-~",- .. MAR ! 3 ZOOOV'J JAMESD.REffiER, V, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MICHELLE M. ZEIGLER, Defendant NO. 00-511 CIVIL IN CUSTODY COURT ORDER ~ AND NOW, this z. ~ day of March, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, James D. Reiber, V, and the Mother, Michelle M. Zeigler, shall enjoy shared legal custody of Kelsie D. Reiber, born January 15, 1996 and Garrett M. Reiber, born January 14,1998. 2. The Mother shall enjoy primary physical custody of the minor children. 3. Father shall enjoy periods of temporary physical custody with the minor children as follows: A. On the weekend Father goes off first shift from Friday at 6:00 p.m. until Monday at 6:00 p.m. B. On the Thursday Father goes off second shift from 9:00 am. until 8:00 p.m. C. On Thursday from 4:00 p.m. until 8:00 p.m. when the Father is on night shift. D. At such other times as agreed upon by the parties. 4. The holiday schedule shall be handled as follows: A. Christmas shall be divided between two segments with Segment A being December 24 at Noon until December 25 at Noon and Segment B being December 25 at Noon until December 26 at Noon. The parties shall alternate those segments with Father having Segment A on even years and Segment B on odd years. B. New Year's shall be handled similar to Christmas with the first segment starting December 31 at Noon. Father shall have the first Segment in even years, with the even year for the New Year based upon the year of December 31. ~ F7lEO-OFFICE 0" -",~ .-,. -'^', V-"'()l"ARY !;.. i ~,;,." :"".':1 II i-~; ,1\" 1 h "'..., __,' . "_",\." N) 'Hr;>, 27 P'412: 3t; ;Jl... fir..! I . ,i. .~ v CW.,j8EniJi~O COUNTY PENNSYLVANIA ... !II!lOOI!lIl!_I~~ ~ .; cc: , -~j- ,-,,.;' __"','i~.,'_~~ "'__~L,",,__'" -.,,,I.;i.,..,;,_',,,; ;'. ,-~-'_ . _' '.b C. The Easter and Thanksgiving holiday shall be handled with Father having custody from 11 :00 a.m. until 2:00 p.m. on each day. Mother shall have custody the remainder of the day. D. For the 4th of July, Memorial Day, and Labor Day, the parties shall work out an arrangement between the two of them so that they share equally the times on those holidays. E. The parties shall work out a schedule so that both parents shall have a sufficient amount of time to celebrate the children's birthdays on the children's birthday itself or at a time in close proximity to the birthday. F. Mother shall always have custody on Mother's Day and Father shall always have custody on Father's Day, with the timeframes being from 9:00 a.m. until 9:00 p.m. 5. The non-custodial parent shall pick up the child from the other parent. 6. Both parents shall ensure that they have adequate seatbelt apparatus available for the children when they are picking up the children or delivering the children or at any other times they are transporting the children. 7. Both parties shall provide reasonable telephone access to the other parent with the children. Additionally, both parties shall advise the other parent of their address and phone number in the event either parent has custody of the children and is out of town overnight with the children. Additionally, they shall advise the other parent of the location of where they will be and a phone number where they can be reached in the event of an emergency. 8. This order is entered pursuant to an agreement reached by the parties at a Custody Conciliation Conference. The parties may modify this order as they agree between themselves. Absent any agreement, this order shall control. Additionally, in the event either party desires to modify this order, that party may petition the court to have the case again scheduled with the Custody Conciliator for a Conference. BY THE COURT, ,/Ii Gregory L. Cutler, Esquire Joan Carey, Esquire . D l\_'~ 1,0 \f( Y I}. Q;.t-0 ..,. . . ~." . , . ~._- ,"",",-',d-~,-" ;-,~,-,,-'-, ,",'.f,.. ';'><J~~i.="""",hiii '''''''' __""' _ ,';:,.) - JAMES D. REIBER, V, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW MICHELLE M. ZEIGLER, Defendant NO. 00-511 CIVIL IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Kelsie D. Reiber, born January 15, 1996 and Garrett M. Reiber, born January 14, 1998. 2. A Conciliation Conference was held on March 17, 2000, with the following individuals in attendance: The Father, James D. Reiber, V, with his counsel, Gregory 1. Cutler, Esquire; and the Mother, Michelle M. Zeigler, with her counsel, Joan Carey, Esquire. 3. The parties agree to the entry of an order in the form as attached. 3-t,;t \ f DO DATE 0Yl Hubert X. GilrO); squire Custody Concili tor