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Home My WebLink About00-02774 . 'x____,,' ,,,_;,c WILLIAM A. REIGLE, II Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. OC> - 0l-?7r : CIVIL ACTION - LAW : CHILD CUSTODY Cru~l'T~ KIMBERLY A. REIGLE Defendant ORDER AND NOW, this q day of ~"\ ' 2000, in consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel, shall appear before mW(\ S l ~ ' the Conciliator, on the ~ day of ~ 0(\ ,2000, at .iL..Q..,m., at:5'1 W, \--\(1\ (\ ,-S\-, ) ~ \ ~ for a Pre-Hearing Custod onference. 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 and older may also be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT: By: I$J'fuffi ~., ~J.1N\J'~, Custody Conciliator ( ') 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, Date: CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717)249-3166 g ;,""".."<"-~,,,,," "'"'"""""" , , 5' /6 cf)tJ ,5~/b -c??7 S' -/6 - CJ.&1 " 'RW~JIIIlI -, ~" I ....".' .~ ..._~- =~ - -'- FlLED-QfACE fir- T,:e: ':""'~"~U(vln"'ARY ,),- ,r :~.. i , "~.' I ) i'-..J' l -,-.l I, , nOM~VliO' OJ.lj:1R \...... fL" It" ~ ..... r' 1"'-' ~." ,. io. (~~'~II'~TV L"P-:'-'"i' ~-\Jl' I J_ I if V 'I\;H./l.-..1 ,L.," 1.1 ,-".,,,, PENNSYLV;ANI,c\ wt~~z,df ~ ~~z1f(, ~'~~~df'~ C' . IWmm~rJIf1\l!f~Bm~~~ .,.," .~ ~ JiJ;i~" , e- -~-, ;"~&-_:: ,- - " i l.l~ WILLIAM A. REIGLE, II Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. KIMBERLY A. REIGLE Defendant : CIVIL ACTION - LAW : CHILD CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of marriage, you may request marriage counseling, A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO ANY OF THEM. 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 Telephone: (717) 249-3166 ~- -;" WILLIAM A REIGLE, II Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. ~_ :<77(j ~ I~ KIMBERLY A REIGLE Defendant CIVIL ACTION - LAW CHILD CUSTODY COMPLAINT FOR CHILD CUSTODY AND NOW comes the Plaintiff, William A Reigle, by and through his attorney, Kristin R. Reinhold, Esquire, and respectfully requests this Honorable Court award him custody of the subject minor children, and in support thereto, avers the following: I. Plaintiff is William A Reigle, II, an adult individual residing at 122 State Street, Middletown, Dauphin County, Peunsylvania. 17057. 2. Defendant is Kimberly A Reigle, an adult individual residing at 1602 Louisa Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. The subject children are Shane Michael Reigle, born June 19, 1990, and William A Reigle, III, born July 26,1988. 4. The relationship of the Plaintiff to the subject minor children is that of natural father. - '''''~ n,' j~' . - .'"- " -"I 5. The relationship of the Defendant to the subject minor children is that of natural mother. 6. The minor children have resided at the following addresses, in the custody of the following individuals: A. From 1993 to August 1996, the subject minor children resided at 902 Hickory Avenue, Middletown, Dauphin County, Pennsylvania, with both parents. B. From August 1996 to August 1999, the subject minor children resided at 902 Hickory Avenue, Middletown, Dauphin County, Pennsylvania, with mother. C. From August 1999 to present, the subject minor children have resided at 1602 Louisa Lane, Mechanicsburg, Cumberland County, Pennsylvania, with mother. 7. There have been no prior actions for custody of the subject minor children in this or any other jurisdiction. 8. The Plaintiff is not aware of the existence of any other individuals who have any type of claim whatsoever regarding the custody of the subject minor children. '''',-, " ~--", - ,""_~-_O- ^' ,_, ~ 9, The Plaintiff believes and therefore avers that he is much better able to meet the needs of the subject minor children than the Defendant. 10. The Plaintiff believes and therefore avers that it is in the best interest of the subject minor children that they be placed in his legal and physical custody. WHEREFORE, Plaintiff requests this Honorable Court award him custody of the subject minor children. Date: 5);;; I 0 0 / I /~" Attorney for Plaintiff - A F F I D A, V I T I, ~/~//~~ J.f~/~, hereby certify that the aforegoing is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Dated: 5-07 .OD ;;4~~ ~+Lr' "' ---~- - - '. , ""J ,. .. ) .. .. ... WILLIAM A. REIGLE, II, : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. . NO. 00-2774 CIVIL TERM . . . . CIVIL ACTION - LAW . KIMBERLY A. REIGLE, . . Defendant . CUSTODY . ORDER OF COORT AND I!DIJ, this ~4 day of ~ consideration of the attached Custody Concilia and directed as follows: , 2000, upon it is ordered 1. The Father, William A. Reigle, II, and the Mother, Kimberly A. Reigle, shall have shared legal custody of William A. Reigle, III, born July 26, 1988, and Shane Michael Reigle, born June 19, 1990. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 2. The Mother shall have primary physical custody of the Children. 3. The Father shall have partial physical custody of the Children on alternating weekends from Friday at 6:00 p.m. through Sunday at 6:00 p.m., beginning July 7, 2000. In addition, the Father shall have custody of the Children every Wednesday from 5:00 p.m. through 8:00 p.m., beginning July 5, 2000. The parties shall cooperate in adjusting this partial custody schedule to provide additional periods for the Father as arranged by agreement. 4. The parties shall share or alternate having custody of the Children on holidays as follows: A. CIIRISTMAS: In every year, the Father shall have custody of the Children on Christmas Eve from 5:00 p.m. until 11:00 p.m. and the Mother shall have custody of the Children from Christmas Eve at 11:00 p.m. through Christmas Day at 6:00 p.m. The Father shall also have additional periods of custody with the Children over the Christmas school break as arranged by agreement. B. THANKSGIVING: In even numbered years, the Father shall have custody of the Children on Thanksgiving Day from 12:00 noon until 6:00 p.m. and in odd numbered years, the Mother shall have custody of the Children on Thanksgiving Day from 12:00 noon until 6:00 p.m. C. EASTER: In even numbered years, the Mother shall have custody >-. - " =~-, ~ ~ ,,. .... <. of the Children on Easter Sunday from 12:00 noon until 6:00 p.m. and in odd numbered years, the Father shall have custody on Easter Sunday from 12:00 noon until 6:00 p.m. D. MONDAY HOLIDAYS: In the event a Monday holiday falls immediately after the Father's regular pericd of weekend custody, and the Father does not work on the holiday, the Father's period of weekend custoay shall be extended through the Monday holiday at 6:00 p.m. E. MOTHER'S DAY/FATOER'S DAY: The Mother shall have custody of the Children every year on Mother's Day from 12:00 noon until 6:00 p.m. and the Father shall have custody of the Children every year on Father's Day from 12:00 noon until 6:00 p.m. F. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 5. Each party shall be entitled to have an uninterrupted period of custody with the Children every year during the summer school break for a 10 day period from Friday through Sunday upon providing at least thirty (30) days advance notice to the other party. The party providing notice first under this provision shall be entitled to preference of his or her selection of vacation dates. 6. All exchanges of custody shall take place at the Turkey Hill store in New cumberland, unless otherwise agreed between the parties. 7. 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, J. /' co: Mark T. Silliker, Esquire - Counsel for Father Charles E. Petrie, Esquire - Counsel for Mother ~ ~ ~ / ,/,,0 \; ~v * l"";':-"~'.' .,' ", ........:..~"--~~ "'~=IIiI6Ii~~il~ri;i,~.t~~iliiilKlillII:iBliiIIlIl. , "" ,'<;,- " "'~1l:ilMhd ". ~ , ... -'I ,1 i, I ~ c~ l-i- Ii' -0 ~ g ()t "'r b ""~,~. L " .. r , WILLIAM A. REIGLE, II, : IN THE CDURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . NO. 00-2774 CIVIL TERM . : . CIVIL ACTION - LAW . KIMBERLY A. REIGLE, . . Defendant : CUSTODY CUSTODY CCI'lCILIATIQiI SUJIIMl\RY REPCRr IN ACCDRDANCE WITH CUMBERLAND CXXINTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUS'roDY OF william A. Reigle, III Shane Michael Reigle July 26, 1988 June 19, 1990 Mother Mother 2. A Conciliation Conference was held on June 28, 2000, with the following individuals in attendance: The Father, William A. Reigle, II, with his counsel, Mark T. Silliker, Esquire, and the Mother, Kimberly A. Reigle, with her counsel, Charles E. Petrie, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date ~ J-1 , d-oD~ ~- Dawn S. Sunday, ESqu~ Custody Conciliator