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Home My WebLink About00-02694 __ , '~c _ ~,"" _, _" ,.___" ,,~ " -"J"_,' '"",~ ~_', - "-, -"_,, "';""'- ""c '<"-.d' , KIMBERLY A. REIGLE, Plain tiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. NUMBER: 1J7J - ;If. q'f CIVIL TERM WILLIAM A. REIGLE, JR., Defendant CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby direc~ed that the parties and their respective counsel appear before 1\.J\y.,-\- 'f,... G\\ro-..J \ v:~, , the conciliator, at-\'c-c.u,-\'In \=\CuMlrrrll'hcHQ (1l~.1(,. \ " on the~ day of ~-'1 ' 2000, at ~ S.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. BY THE COURT: ~t ^-~~~r,:~l~ 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. COURT ADMINISTRATOR, 4th Floor CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 240-6200 ;1 'In~ fILED-OffiCE OF THE PPDTHONOTARY nro. !'~Il~'{ -5 PM 2: 51.; ..... . ,I e'l" I' ,"".",' ,", I"O'U"'Y 1 1'\ '1""~':'''I.J'.''\'\ ) V\ l\l ~ V 1/'.11-,_,. L;L.- PENi\!SYlY,IINII', j'5~-m W. {~ .M~ ~ 4 /bTu.< y;5',Cfltf 7f~ /#~ ''Z, ~. ..?: s~: 0 tJ c~ ~ ';-u-. 7f'.~ # ' , . .-- ",'-,' ,,---- j,," ",~i ~:.~- ~ ' KIMBERLY A. REIGLE, Plain tiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. WILLIAM A. REIGLE, JR., Defendant NUMBER 111) - 21. q 1/ (',,;,.;1, 7;._ CUSTODY COMPLAINT FOR CUSTODY NOW COMES the Plaintiff, KIMBERLY A. REIGLE, by her attorney, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is KIMBERLY A, REIGLE, who currently resides at 1602 Louisa Lane, Mechanicsburg, County of Cumberland, Pennsylvania. 2. Defendant is WILLIAM A. REIGLE, JR., who currently resides at 122 State Street, Lot 2, Middletown, County of Dauphin, Pennsylvania. 3. Plaintiff seeks to have rights of primary physical custody with respect to WILLIAM AWOOD REIGLE, III, born July 26, 1988; and SHANE MICHAEL REIGLE, born June 19, 1990. The children were not born out of wedlock. The children are presently in the custody of Plaintiff, KIMBERLY A. REIGLE. During the past five years the children have resided with the following persons and at the following addresses: From April, 1995, until March, 1996, with both parents at 902 Hickory Avenue, Middletown, Pennsylvania; from March, 1996, until April, 1999, with plaintiff at 902 Hickory Avenue, Middletown, Pennsylvania; from April, 1999, until June 4, 1999, with plaintiff - 0 ^__, '" _~ '" '~ M'<< '-' '~,," ," '" ,~,_",,> '_',n ..,_ ",', '~~- C.':;'" .c;""~:'<'~, '~ -"" in New Kingston, Pennsylvania; from June 4, 1999, until the present with plaintiff at 1602 Louisa Lane, Mechanicsburg, Pennsylvania. The mother of the children is KIMBERLY A. REIGLE, who currently resides at 1602 Louisa Lane, Mechanicsburg, Pennsylvania. She is not married. The father of the children is WILLIAM A. REIGLE, JR., who currently resides at 122 State Street, Lot 2, Middletown, Pennsylvania. He is not married. 4. The relationship of the Plaintiff to the children is that of mother. The Plaintiff currently resides with the children and with her finance, Christopher. 5. The relationship of the Defendant to the children is that of father. He currently resides alone. 6. The 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 in another court. The Plaintiff has no information of a custody proceeding concerning the custody of the children in this or in another court. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the children or who claims to have custody or visitation rights with respect to the children. .. ,~ .',0>-'- ~"=",,~"~"_,,:,~,,", _<",,' -':.'"' 7. The best interest and permanent welfare of the children will be served by confirming custody in Plaintiff because Plaintiff can better care for the children and Plaintiff has been the primary caregiver for the children. 8. 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 enter an Order confirming custody in Plaintiff. Respectfully submitted, C.L1J~~~~ CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff ._0<____ ~,_ _ ~,~'^ '''",~ -- COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I verify that the statements 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. Section 4904, relating to unsworn falsification to authorities. ~ "J,'i, ;)000 DA E Ai .~ [:,~ ["'\..1 U , r::: ~~~ " ~"d , '- ' ~- r, ,'~ , ~'^-' , ,. .::> 'J) ~. " '.j.. "! ~ ~ cj - ~ ~ g j ~ It:, l~ $ IV " \ '" 'Il ' 6? \" I ,-. . . "~, .~ "'_'-'.c .,,-~, ,~ ..,_ "o~'~~' '~ ' _ ""."~",C';" , "'7'--"~ , ~ '!" '~ ~ ., 'If'' 3j .'!'1"'<"'''' ,WR'. 'h' ~,""-~".,",."~",,, ,,'~~-^ ,,,),,.,,'. - ~-,- '", ,"'';, ",,,, . ,,~ :~: JUN - 6 2~\ KIMBERLY A. REIGLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA v CML ACTION - LAW WILLIAM A. REIGLE, Defendant NO. 2000 - 2694 CML IN CUSTODY COURT ORDER ~r AND NOW, this I day of J ~/l-I:~ , 2000, the Conciliator being advised that the above captioned case is also before Attorney Dawn Sunday for a Conciliation Conference under Docket No. 2000 - 2774, and the parties desiring to appear before Attorney Sunday on June 28, 2000, this Conciliator relinquishes jurisdiction. BY THE COURT, Hubert X. Gilroy, Esquire Custody Conciliator KIMBERLY A. REIGLE, Plaintiff vs. WILLIAM A. REIGLE, Defendant ~, I '_ ~ , '"' - . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: 00-2694 CIVIL TERM IN CUSTODY PRAECIPE TO WITHDRAW Please withdraw the above referenced matter filed May 5, 2000. June 30, 2000 d...~t;,~ CHARLES E. PETRIE 3528 Brisban Street Harrisburg PA 17111 (717) 561-1939 Attorney for Plaintiff "-',-,," ~ '" - ~~'I -"'" .L....~I._'IllliiiiiiUlMiilll~ - ~~ "~~~ >. "" ..........~'ft..-.>" ~~ "'''''''JW~_II' '.1 I , 1lIl'l<'-"'......... ""~ (") 0 0 C 0 s: ""';'1 "'001 S: ::;:1 n1n'1 ~ j':.):1:::D 2::0 r- ZC I ;~i~ (JJ .,2' VI -<L !;20 ". ','" """i ~O :x: ~."::": -f! =C1 ~~'~ Pc:: '-' Z --. =< )> 'D ::n -< ". .,~