The URL can be used to link to this page

Home My WebLink About00-03621 '" - ~ .", ,," - \ - ^'T _ .' ',_ .",., ',-.,':,' - "~<'-'; -',:--,,,, , '"' <, " , , .::1~~~::::~::.::~::"-::~::.X:::~a."?,;:':~!::.::~~:'::-~:'x,)::.:<>"~~':K.::::~::C<>.3e;r~:+::~;;::;~::!~;::):C!:;:':::!at:<:)~::!::7;~::eC::~":Kt~::.::!~;J;-~::C!~~{Cc_i~M~':e;~r~!::+}~J~:~:+~~!::C!r:::~:+::!ft~X+I<.M3. ~ ---- $~ ~ ~ y ~ ~ ~ ~ . .~~< ~ IN THE COURT OF COMMON PLEAS I ~ i i OF CUMBERLAND COUNTY ~ k~~ ~ "'.-' w ~." ~.~ ~ ;",' ~ ~.~ ~.; ~ ~.~ ~ ~.S ~ ~.~ ~, ~ ~ ~~~ ~ ~t ,', ~ ~ >.,,' ~ ~.~ ~.~ ~ . ~.~ ii a ~.~ a ~.~ ~ ~.~ ~.~ ~ ~.~ ~ ;:; ~ ~ ';.,' ~ ~~ ~.~ ~ ~~~ ~ ,'" STATE OF i ~." PENNA. >,.", ~ ~.~ I ~ ;.~ l'- ;..~ ~ ~ * ~.~ ~ t ~.~ >"" j ~.~ ~ ~ ~ Bi ~O;~ ~ ........ J)~~~1\.. .~.,... ~FI J:N.E:lIA~.T. ~....................... . ...l'lainti.f f.. ........".......,... N O. .....QO'~.3.621. ..................19 Versus WALTER D. RHINEHART, nuuUUn.n ..uuu_uu__ _pu__.uu," '.u.nunuu.. mP~t:~!ldarl:t.. DECREE IN D I V 0 R C E,;teJ"O~f'~' AND NOW, ...(?~...~.......,~...., it is ordered and decreed that. .. .. . P.a,:r;;tfl, .~,. R~:i,I)~)1.a.:r;t. . ... . .. . .. . .. . .. . . .., plaintiff, and. . . .~~~.t,e:J;. P.'. ,I3-~~.~e:l:1~:r-.t, . . . . . . . . . . . . . . . . . . . . . . . . , . . , . " defendant, are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; .' ;..s ~ '".; None .. ,......................................................... .............., w ~.~ ~ a ~.~ ~~ ~ ~. 8 .'^. ~' ~ ~.~ ~ N. . ~ ~ II .. l________~~_____~~_~ Prothonotary 1$. ~.~ ;., ~ ~ ~.~ J. ~ \.~ ;:.; ~ ~ '.~ Attest, ..~ ~ ~.I ~~ ;:.::.::()::.x ::.::.:.':: :::.::.:( :::~::.::<>,::.::.': ".::.:"': x.:<::~.::.::< :::.::.::~:' . /l1 s:&? A:J 6" ?9::f , _",,,,.,,-,~,""_ "."_~ .._,.~,>,.. ""'J;,_~."_'),:,~i" '",' ',"-, ',", "~, , ~~ < ~"'-' ,.._". ~'"~,~"~ - '< " .' {b/ t!'~ ~ ~(X X:' 7r~~~.~ - - ."--' r.~ '0:"" -<>' ";' JI ,'~_ ,,' _., __ . ~_ 'J.",--,,,~ "",' .," ~'~~~ __ ~. ~,-,- -""" .,~~ ' ~ ," ~ - > ,~ "", ',' -, "' .,,' '_ .,-.' c.;"' ',0,"" ._. -' ,~ "'o;',,;',;:,',~'" '.c. '.' -' .-""0 ~,,,.~.-', i-.'.,";~"'~, DARLA M. RHINEHART, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN CUSTODY WALTER D. RHINEHART, Defendant : NO. 00-3621 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 330l(c) of the Divorce Code. 2. Date and manner of service ofthe complaint: June 19, 2000, by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. 3. Date of execution of the Affidavit of Consent required by Section 3301 ( c) of the Divorce Code: by the plaintiff, September 29,2000; by the defendant, September 29,2000. 4. Related claims pending: none. 5. Date plaintiffs Waiver of Notice in !}3301(c) Divorce was filed with the pronthonotary: September 29, 2000. Date defendant's Waiver of Notice in !}330l(c) Divorce was filed with the pronthonotary: September 29,2000. Date: September 29,2000 ~~Q ;jy~ih1~ Me! 'e Walz Scaringi ~LID2. T MAS M. P 1\CE ROBERT E. RAINS TERI L. HENNING Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 Attorney for Plaintiff ~~.'-' ~ ,". -- ~ ~ . "~M ',; '-'(' ~",'..,.~ .'- '-", ~ , '~j 0 C.l 0 C 0 ""1"1 :;;:: U'> _"I ""00.:: ~1 .; -'l rllf7i -0 Z""""-; ,.-:> ___,'.'1-\ zc: -_:,~-~~, ~2~ '.1:.' !2,C :P" ':'..l':-i. ~:=) ;-0 2>c' ~l': --,~ ...'") ;So - -~- ~..., - ,_, I" )>c;: ::::i Z; .:.11 ~ =< f..o , .' '" " " ~" "".o^",.,_,c"",.,,_'c;..ii_.';' .' '.", "',~,. ','.",- ;"';;:-,,,,^, ,.';.1'.--'--, .~ <--1M:'" DARLA M. RHINEHART, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE, CUSTODY : NO, oO-?ioJICIVIL TERM WALTER D. RHINEHART, Defendant 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 of 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, 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 CLAIM 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, PA 17013 (717) 249-3166 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. ". ,<,"~:",-::~,,~"-,;.. ."'''''-'.-' . ~~ ".-'-" ,"~,~:~'";..::-".",,,:.: ,'" -" ~,,-" , DARLA M. RHINEHART, Plaintiff v, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : DIVORCE, CUSTODY, WALTERD. RHINEHART, Defendant : NO. 00- a'.2/CIVIL TERM COMPLAINT The plaintiff, Daria M. Rhinehart, by her attorneys, the Family Law Clinic, sets forth the following cause of action: COUNT!. DIVORCE UNDER 23 Pa.C.S. SECTION 3301(c). 3301(d). AND 3301(a)(6) OF THE DIVORCE CODE I. Plaintiff is Daria M. Rhinehart, who currently resides at 65 Parker Road, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is Walter D. Rhinehart, who currently resides at 234 Apt. C, North Baltimore Avenue, Mount Holly Springs, Cumberland County, Pennsylvania 17065. 3. Plaintiff and defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and defendant were married on September 17, 1989, in Franklin County, Pennsylvania. 5. Plaintiff and defendant have lived separate and apart since March II, 2000. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff avers that defendant, in violation of his marriage vows under the laws of the Commonwealth of Pennsylvania, has offered such indignities to the person of the 'I! plaintiff, his injured and innocent spouse, as to render the condition of the plaintiff intolerable, and life burdensome. 9. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. WHEREFORE, plaintiff requests the court to enter a decree in divorce dissolving the marriage. COUNT II. CUSTODY 10. Plaintiff repeats and realleges paragraphs one through eight. 11. Plaintiff seeks custody of the following children: Name Present Address Date of Birth Nathan Walter Rhinehart 65 Parker Road, Newville, PA 17241 Kaitlyn Elizabeth Rhinehart 65 Parker Road, Newville, PA 17241 The children were not born out of wedlock. July 2, 1992 Jan. 20, 1995 The children are presently in the custody of plaintiff, Daria M. Rhinehart, who resides at 65 Parker Road, Newville, Cumberland County, Pennsylvania 17241. During the past five years, the children have resided with the following persons and at the following addresses: Persons Addresses Dates WalterD. Rhinehart 65 Parker Road, Newville, P A 17241 65 Parker Road, Newville, P A 17241 Birth to present Birth to March 11, 2000 Daria M. Rhinehart The mother of the children is Daria M. Rhinehart, currently residing at 65 Parker Road, Newville, Pennsylvania. She is currently married to the defendant. The father of the children is Walter D. Rhinehart, currently residing at 234 Apt. C, North Baltimore Avenue, Mt. Holly Springs, Pennsylvania. He is currently married to the plaintiff. 12. The relationship of the plaintiff to the children is that of mother. The plaintiff currently resides with the following persons: Name Relationship Nathan Walter Rhinehart Son Kaitlyn Elizabeth Rhinehart Daughter 13. The relationship of defendant to the children is that of father. The defendant currently resides alone. 14. 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 another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 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. 15. The best interest and permanent welfare of the children will be served by granting the relief requested because: a) Plaintiff has been primary caretaker of the children since birth; b) Plaintiff is better able to provide a home with adequate moral, emotional and physical surroundings for the children, whose best interests would be served by an award of primary physical custody to the plaintiff. 16. 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. " >'1-"- " ,.' ..;'-"f~i ," -"'" ",,' ,,,,,> '-l-i^'.', ""'~"" ~>,';'-., '~"""_''''''_' . _ ~'^" h Co, WHEREFORE, plaintiff requests the court to grant her custody of the children. Date rolq/co I I m~])~ ~ Kfuahie D. Walz Student Attorney J~~t~ ROBERT E. RAINS Supervising Attorney DONALD MARRITZ Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717/240-5204 VERIFICATION I verifY that the statements made in the foregoing Complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. Date: &-/ S' OZJ {1AJ?- '/)1. "RJJrrt;hrAAk Daria M. Rhinehart __V,',.__ _';"~_':""""",",:;,,"-,- "'-"K '''-"-'''''''''-... "." ," " ~~,~=_.'A~ _ -",' "", ,.~, l:!:l'l1irl'-U' '>,-- 0, 0, ,,/,' "/'''<''',/,' ~" - - ~;<,,'- ,.", -~,~' ~, H ~ .'1 ~~ ~ ~ .1 8 'V~O'h, , C) ~-; -c f~~': n'''T' ";:'-'!T ~~: !,...::C) ~~i -'"::':(-" Pc -7 ~ I '0"' 0 "'" 'I C~ C.:' ,-) --"") " (Ji :Ji:'.. ::~. ) r\ -..j '--"' k~;~~ ~-,! .:0 -< '0 - --, "'~'",. ,) - "'_' C;y.;,:" '", "'''-'';';''' - ,'-,~,_~",' ".''."".'. ,'-,'i(,''''_'' "'_~_ DARLA M. RHINEHART, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW WALTERD. RHINEHART, Defendant : NO. 00- ?k').l CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow DarIa M. Rhinehart, Plaintiff, to proceed in forma pauperis. I, Melanie D. Walz, Certified Legal Intern in the Family Law Clinic, for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. ~D~ Certified Legal Inte ROBERT E. THOMAS M. PLACE Supervising Attorney DONALD MARRITZ Staff Attorney THE F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 .~'- " " " .'." ., ' ,.-,;:~" '<~ <' _.-.'. ~.,.,';,,,' "' '" "::~:_,~{,;,;;~L,; ,,'. __ " ", DARLA M. RHINEHART, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW WALTERD. RHINEHART, Defendant :NO.OO- 3f..JI CIVIL TERM AFFIDAVIT SUPPORTING PRAECIPE FOR LEAVE TO PROCEED IN FORMA PAUPERIS I. I am the plaintiffin the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs oflitigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: DarIa M. Rhinehart Address: 65 Parker Road, Newville, P A 17241 Social Security No.: 208-50-5307 (b) Employment If you are presently employed, state Employer: Carlisle War College Address: Jim Thorpe Road, Carlisle, PA 17013 Salary or wages per month: Average Net monthly income of $678.06 Type of work: Custom Framer ( c) Other Income Support payments: Support Order dated June 6, 2000 gives $134.59 in current support obligation. (d) Other contributions to household support None. ",..,-" ,~ - _'J> " '-~-', ,,", "- - ,,_,'. -c'___ ,-_:~",~:,(~,,~::~;g;,~~ ' . --,''.':,.'. 'c" - ""'--1 (e) Property owned Cash: $0 Checking account: $126 Savings account: $25 Real estate (including home): None Motor vehicle: Monthly payment of $150 (f) Debts and obligations Mortgage: None Rent: None Maintenance on House: $60 Electric: $89 Gas: $13 Telephone: $112 Sewer: $12 Food not covered by stamps: $108 Clothing/shoes/jackets: $40 Gas (for car): $130 monthly Auto Repairs: $45 (average monthly) Auto Insurance: $21 Household purchases: $24 Barber/ Hairdresser: $15 (g) Persons dependent upon you for support Children: Name Nathan W. Rhinehart Kaitlyn E. Rhinehart Date of Birth 7/2/92 1/20/95 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit 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 (, -/5' 00 w<- ;ff>. <Khf"-RJ,~ DarIa M. Rhinehart ~........ ~~~ ,~,~ -,-~ 1, ~< '''',' """" _".....;".,m " ;-, -~~-u~;C'>:"--r~_, "-:: --~ ' -""";,,,.' 't ~ """'.' (') C ~ ::;,,- "'tJCCJ fllfTr -':;;0",'1 ~~~ ~C~J ~;>>() "7 (~. ~c= :z: =< ~ ~ '" ~ I....~ ...... "10 ," -', o C) (,~ S::: -i~ C\ h--. '.:'1 , ~__ c:;. ;.. -~-1 ~f~1 ~ ~, ~ '0 , , , ',~.;,_, ,,-,,',r^ ~ "',0' ",,' ,;--",,'.,'- '-.~ ';:':"'-,'>';.1" '';r'\''''~ ,,~ .;,~ ---:"":;'~;;>!/-"~' "': ',',,,<',, '.".,,1 ," ""___W~', DARLA M. RHINEHART, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY WALTERD. RHINEHART, Defendant : NO. 00-3621 CIVIL TERM AFFIDAVIT OF CONSENT I. A Complaint in Divorce under ~3301(c), ~3301(d), and 3301(a)(6) of the Divorce Code was filed on June 15, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a fInal decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affIdavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. Date 9- ~s-. cV We yYJ 12h,~cvJ:::;1 DarIa M. Rhinehart, Plaintiff _ni".~J, , , l.,"jj ,0..0 '.~''-<.~"'"'''' _ ,;.~. ~' . , ~ ~, , , ~~ '," '" iiaiii" 0 C" 0 C C, ;'1 g en "U no ,'1 men -" Z:IJ 1''' ~'.{l? z"" ~~E ,1:) ",C) !;2C ?:;; '" ":;'-t ~o --,= '~J(~; -0 - nfT1 ::Pc - " ~ Z :n "'" ~ :0 (;:) -< ,',", "., __~'''''"-;':'__J.;,..,,' .'_'_''"".',''.:'~~>),' <l';'" C '''''' . ,,;,-.";'__;c,{~o./,:.>- ., DARLA M. RHINEHART, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY WALTERD. RHINEHART, Defendant : NO. 00-3621 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c), ~330l(d), and 3301(a)(6) of the Divorce Code was filed on June 15, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a fInal decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements rnade in this affidavit 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 q-22 -00 "". """'"" " ,~ """".:'-i?,arlJti:ailli&- ~~"" "",V""",,,,,,,,. .',.,.,. "~ '~~. . ~ '''I' ~ I (') C-,'"")- () C 0 " s: t/) .., -om rq .' " n"IP; -0 Z:J:' N tJ~~ zr- (/):1.2: '.0 -<..:::::., !<,C :r.-.... (:5;Q ~-. 3: e" :-~":M -0 )>c .. l~ .'.-, Z U1 >' =< :D c::> -< -, -" . '. c"~.',,," '.' ~.; ,. . "'__4"C"'" --, ',.~ -- 5,~.';;';.;'< ,-,->, C'h ,~, .0'~'i8,.;,i DARLAM. RHINEHART, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY WALTERD. RHINEHART, Defendant : NO. 00-3621 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER l:i3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a [mal decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to rne immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. *4904 relating to unsworn falsification to authorities. Date: 9- orS.oo We.. '-/?? ?h(~ . DarIa M. Rhinehart, Plaintiff - .. ~- "it!, "All '~r'''-'-'''' ;;""",,.- ~.." ;<""-H ~ - -, ',' j- (') c: s:: "TIcc n1P: ~~ -<L; kC:; 2:0 ""'0 Pc ~ ~. -, '" '" ~ hi f...";:) c U') ;"'(1 -0 t'V '.c p -;-. fTi ',~j ~-~) ':-:~() --!-f', ,,""J" '')~- 7(~) ~=:.:- ,"T': U , --4 ~ .JJ -< ~...." -~ - - ":.n J~ __ L' ,-- _" ',","e' :.'.~~c ,'",C{, j-^,",;;~,'iZ.';:':J,".;",,',,:,,;:,,',',:;__"0,'>; "'J'_;;"',. 4-j..-",k: ;~it._ DARLA M. RHINEHART, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY WALTERD. RHINEHART, Defendant : NO. 00-3621 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DNORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a fmal decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me inunediately after it is filed with the prothonotary. I verify that the staternents made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 114904 relating to unsworn falsification to authorities. Date: 9 -22. DO '0 ~;..".~;..:.;~~"'-..... "-- .>~' '~,',- ',;". "',; -, ,;;,,,,:,, "";'.. , , " - "~; . "", 'i ""''liiIII () c:o c:: a c) "'oS: ~'; ) U'. r-<) 111fT:; "'1 >--" "0 , " ::) 7'-<_--' /-" ",:; G-I):!:',,, :,;'] t.:i ::<: .. ~ ~.n- r-.:::f', ~~;/-<S _t__, ;E:-("I ::~-<.'" .>i'~ ~~~ / " -~ ;so - ""- -.. .. ..::: -, -, '-'7 3:i -< '- --< ::; ~~~< "..~ . """ ".', ~,-C.,: c;--;, ,<.." ,(i,,':, ',;'.',',',,',," ';;"'''''\;04",'"_,,-__,, ~-- ~"~, '~"'i;j'i I ! , ,! DARLA M. RHINEHART, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA .' i! "I v. : CIVIL ACTION - LAW : IN CUSTODY WALTERD. RHINEHART, Defendant : NO. 00-3621 CIVIL TERM CERTIFICATE OF SERVICE I, Melanie Walz Scaringi, hereby certify that I am serving a true and correct copy of the plaintiff s Affidavit of Consent and Waiver of Notice of Intention to Request Entry of a Divorce Decree under 93301(c) of the Divorce Code, the defendant's Affidavit of Consent and Waiver of Notice of Intention to Request Entry ofa Divorce Decree under 93301(c) of the Divorce Code, the Praecipe to Transmit Record, and the Vital Statistics form, on the defendant, Walter D. Rhinehart, at 234 Apartment C, North Baltimore Avenue, Mt. Holly Springs, Pennsylvania 17065, by depositing the same in the United States mail, First Class, postage prepaid, on the 29th day of September, 2000. Dated: ~, N. C\ 1 2f.::clJ iU~-l j/J~lM&- Melanie Walz Scaringi Certified Legal Intern Family Law Clinic 45 North Pitt Street Carlisle, PA 17013-2899 (717) 243-2968 Counsel for DarIa M. Rhinehart i1i1It: 6i<". '~'."'d~,'."." ~~ ~.,~~. ~ ",,~:;,.-.L'_"._:i8i' r'j .- ~----- ';'-,-"i"-"""' '~O""""'" ""."",,,. 0<, L ',." ,'~. ..' , " .......... 8 0 q 0 '"tJ~ 0:> " [11,0;:,:' t'rl ~:t:. <:J , 2:( !\.) Co.,:..- . !j'~::: ;:S~'__' ',0 .'-'~, ! ~I...._.. :c". -'-=-iC) .. ;ZO ~.,. ~~?- ,?fj :so - ~ - i.5n7 (J1 b! <;:, ::J;J "'" . ,. , '" ~ -- '~, y; ",' '.-i,: , DARLA M. RHINEHART, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW : DIVORCE, CUSTODY, WALTERD. RHINEHART, Defendant : NO. 00-3621 CIVIL TERM VERIFICATION OF SERVICE Understanding that the making of any false statement would subject me to the penalties of 18 Pa. C.S. !l4904 (relating to unsworn falsification to authorities), the undersigned verifies that I, Melanie D. Walz, mailed a true copy ofthe Complaint for Divorce and Custody and a copy of the In Forma Pauperis request on the Defendant by placing the same in the U.S. Mail, certified no. Z 338 765 548, restricted delivery, return receipt requested, postage prepaid, on the 15th day of June, 2000 addressed as follows: Walter D. Rhinehart 234 Apt. C North Baltimore Ave. Mt. Holly Springs, P A 17065 Sender's receipt no. Z 338 765 548 is attached hereto and incorporated by reference. On the 19th day of June, 2000, green return receipt no. Z 338765 548 was delivered to the Family Law Clinic, bearing the signature of Walter D. Rhinehart. The return receipt is attached hereto and incorporated by reference. dJ2d ~V~ Mel 'e&.Walz Certified Legal Intern F AMIL Y LAW CLINIC 45 N. Pitt St. Carlisle, P A 17013 717-243-2968 Dated: June 19,2000 "~''''' , "',P), , ,,', "_0'." ., .';:' ,~ " .0" ". '., ".. ~"" .' , '." ""o,.o""''''i '" ,.. ,..". , (') .:;:) () C c:::> ~.~ . i :s: '- :-j -on:.~ ?:~ ' -1' [lJ[T; ~~ z~,. ZC; ,.0 (/)",-;;,: -<-" \<c' 'V ~O ~..,,,,- -'. -=c:: N _.-,;~ r,'j >'C <-) --{ Z G) J'> :2 (T\ ~ '-_ "0 ,~,,-"' ," - . '~'."" . Z 338 765 548 ." c. 0;( 0 '8 0, ';"""",, i TOTAlP~&Fe.'._. C") Postmark or Date""'''''''''''' E ~ ~ . c~~piefe it~m~":r2';- ,- scfEoi'np ete item 4 if Restricted Delivery is desired. . Print YOLlr name and address on the reverse so that we can return the card to you. - .. Attach Wis card to the back of the mail piece, or on the front if space permits. 1. Article Addressed to: lAJru+tr D. ((htltfLllr+- ~bLj {i-{7L C . . , NDrth ~ll.\HfYlu(t frvt. M+ .lffil~ tpn ~ fA- nDlil?' o Agent 0. Addressee . Is deliveiy address, different from item 1? 0 Yes II YES. enteili.'REC!I,f . REQUESTED " 3.'~e < o ReglSter'ed". 0 Return Receipt for Merchandise Diu -'1 " . ., lit '. 10259S--99-M-1789 ~ ~ . . "C"'", '.v,,~ , ,,"~ ""\0,.1<"",,;.,. '," ,.'-,",.--,;,', ~! 7. ',)l~': n--;I" -~, -;::: f'~ ~~ '~ ~'.iIliiiIIi'~ " II: .-~::- W 0\ ~' CD -< , , , " , ',' c, . . It .;,- ..' DARLA M. RHINEHART, Plaintiff . .'''r "", ",.,.. '.'" '.' _ ",", ',' ,,0) '" ~".<' ~, ,,', , I ""I '0.:;"." ," ~ , ., : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY WALTER D. RHINEHART, Defendant : NO. 00-3621 ORDER OF COURT CIVIL TERM AND NOW, this 11""'" day of ~ ' 2000, upon presentation and consideration of the attached agreement, it is hereby ordered and decreed that the attached agreement is made an Order of the Court. This Order shall remain in force unless and until modified by further Order of the Court. ~J. f\ . ~O ~~~, \~~ 0 ~~ " " I,. ,. . .. '<4 -<..~-, .>)",. '.' _'0'" . ,", v CF ,.'" 00 f',IIt: I 1 3: O.} CUM8EHl)-/\0 COUNrr PENNSYLVANIA '" ,~~"':'<~:"'" .,1 "l,._41.: m' '. ~nm~ .. ,~, .,~~~ , . -, ~', ~~ ."'T"(" ~-- ,&., .. ,. .' " , DARLA M. RHINEHART, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY WALTERD. RHINEHART, Defendant : NO. 00-3621 CIVIL TERM CUSTODY AGREEMENT TillS AGREEMENT, made this _ day of , 2000, between DarIa M. Rhinehart, hereinafter Mother, and Walter D. Rhinehart, hereinafter Father, concerns the custody of the children: Nathan W. Rhinehart, born July 2, 1992, and Kaitlyn E. Rhinehart, born January 20, 1995. Mother and Father desire to enter into an agreement as to the custody of the children. Mother and Father agree to the following: I. Mother and Father shall share legal custody of the children. 2. Mother shall have primary physical custody of the children. 3. Father shall have partial physical custody of the children at such times as the parties have mutually agreed to in advance. 4. The parties intend to be bound by the terms of this agreement. Father acknowledges that he has been informed that the Family Law Clinic only represents Mother in this matter and that the Family Law Clinic has given him no legal advice other than to seek his own counsel, which he has chosen not to do. ",' .;-~,'~ '~-";,~--~'._'" '~'-;"'"" \', " . \4 ". ~ . .' , IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms hereof, set forth their hands and seals the day and year first written above. (hJr-- yT/. rKh,~~ DarIa M. Rhinehart , II '.1 ~ ~ ;[J~~t/S~~~0Aj~ Certified Legal Intern 1(Jd{,~ THOMAS PLACE ROBERT E. RAINS Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Counsel for DarIa M. Rhinehart ';"v' , '.~~> ~. , ~ < ,.,,', linn ., ...~~,.... '"~~ ',,-. "' '1[jlfjJjJ . r '.,' , "","'^'," " -.; '<~ ." ", .1 ,,,",C',,,",,,,, P :0:$," OJ?' ~. r, i%<:C" ;:s5':' :;;; e.' fIe) [} 2q ''Si " '- I,:) C':) <::::, "'" .~ ~) -- c./.; :!J .<: ","", "'0"''''''''1 . -, (:) ',-, ':"i " }'8 :~J_;~) _.,j-'" (S:'/~7 -::'1 . 5] " ~