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Home My WebLink About00-04782 ~~ "~^ SHERIFF'S RETURN - REGULAR CASE NO: 2000-04782 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLANb JAMIE SHUMBERGER VS RUMMEL KEITH WILLIAM DIEHL , Sheriff or Deputy Sheriff of Cumberland County, Pensyl vania , who being duly sworn according to law, says, the within COMPLAINT - CUSTODY was served upon RUMMEL KEITH the DEFENDANT , at 0820:00 HOURS, on the 6th day of July , 2000 at CUMBERLAND COUNTY PRISON 1101 CLAREMONT ROAD CARLISLE, PA 17013 by handing to KEITH RUMMEL a true and attested copy of COMPLAINT - CUSTODY together with ORDER OF COURT and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.10 .00 10.00 .00 31.10 r'~N'~-t:~ R. Thomas Kline 00/00/0000 Sworn and Subscribed to before BY'~ De \ erif me this j.). It:: day of ~ .:2"VQ A.D. ~R a, '"71",IJP~ -;~ P othonotary ~~ t. ~""".'-, / .... JAMIE SHUMBERGER IN mE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA PLAINTIFF V. KEITH RUMMEL 00-4782 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 12TH day of JULY ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 onthe 6TH dayofEPTEMBE ,2000, at 1:00 PM 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 defme 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 mE COURT, By: Isl Dawn S. Sunday. Esq.tIJ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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 ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 )lI' I i I i I I I I.. ~~I~" ~~"~-~ ~ ~ ~ C,'''''',",,' -.'^ 7-/3.tJ() 7 -I] .t'J,b 7'/3-t?t:'J ~, ' __'0_ _" '" 'c' " -" _ _~ _ - ~ ~ .' "V~ (il" ,~)!' . "';"'.",,''-' , ',"_JiP,J=1( iJO IU!I ,.; l.; ....' -j_ I J [,., ~ 'j' /: r}4' ! ,._ ,.J CU/vi8ERu:'N'; ("J'I,\fIY PENNSY[Vfl}JIK' I W-~,IH~~ X5 /1~~~~ ~~$a;tf~~ , . ~MJ 8Ifll!l,."... _', ,"~~,~~ ,~~~_~~~~tt>N"~lrrnf_~~~~------: ,- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JAMIE SHUMBERGER, Plaintiff v. KEITH RUMMEL, Defendant NO. 06 -4'7P, civil Term 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 , the Conciliator, at on the day of , 2000, at ___.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: 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. 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 the office set forth above. 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. ~ " .-, '-,-., ,"',-', '.'0'-:' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JANIE SHUMBERGER, Plaintiff v. NO. C>O-"'I71'~ Civil Term KEITH RUMMEL, Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, JAMIE SHUMBERGER, by and through her attorney, Maryann Murphy, Esquire, of Legal Services, Inc., and respectfully files this Complaint for Custody, and in support thereof avers as follows: 1. The Plaintiff is JAMIE SHUMBERGER whose current address is P.O. Box 505, New Kingston, Cumberland County, Pennsylvania. 2. The Defendant is KEITH RUMMEL who is currently incarcerated at Cumberland County Prison, 1101 Claremont Road, Carlisle, Cumberland County, pennsylvania. 3. The Plaintiff seeks sole physical and legal custody of the following child: BRANDON RUMMEL, born December 15, 1997 4. The child was born out of wedlock. They currently reside ,- ,,- .,,"" . a ;,""'_ ~ '" with the Plaintiff. 5. During the lifetime of the child, he has resided at the following addresses with the following persons: Time Address With Whom birth-3/98 48 Fickes Rd. Newville, PA Plaintiff/Defendant 3/98-6/98 223 S. Main St. Marysville, PA Plaintiff/Defendant 6/98-11/98 29 B&K Mobile Home Pk. Newport, PA Plaintiff/Defendant 11/98-12/98 29 B&K Mobile Home Pk. Plaintiff 12/98-present P.O. Box 505 New Kingston, PA Plaintiff 6. The father of the child is KEITH RUMMEL. He is single. 7. The mother of the child is JAMIE SHUMBERGER. She is single. 8. The child currently reside with Plaintiff. 9. The Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the child in this or any other Court, except as set forth above. 10. The plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. , -" -.~, """'1 11. The 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. 12. Each parent whose parental rights to the child have not been terminated, and the persons who have physical custody of the child, have been named as parties to this action. There are no other persons known to have or claim a right to custody or visitation of the child and therefore, no further notice of the pendency of this action and the right to intervene shall be given, other than to the parties named herein. 13. The best interest and permanent welfare of the minor child will be served by granting Plaintiff sole physical and legal custody. WHEREFORE, Plaintiff requests this Honorable Court to grant her sole physical and legal custody of BRANDON. Respectfully submitted, n Murphy, Legal Services, 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 LD. # 61900 Attorney for plaintiff rfu , . VERIFICATION I, JAMIE SHUMBERGER, verify that the statements made in the foregoing Custody 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. Sk .- -, 7 ,'~ ""~':"' . ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JAMIE SHUMBERGER, Plaintiff va. : NO. civil Term KEITH RUMMEL, Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Maryann Murphy, Esquire, do hereby certify that on the day of , 2000 I served a true and correct copy of the foregoing Custody Complaint on the Defendant, KEITH RUMMEL, at the address set forth below, by personal service of the Sheriff. Keith Rummel Cumberland County Prison 1101 Claremont Road Carlisle, PA 17013 Respectfully submitted, Maryann' urphy, Legal Services, 8 Irvine Row Carlisle, PA 17013 (717) 540-8600 LD. # 61900 ~ iMi'I(' '~~!I!ll ~F~'m~~~~a.:~"""""."' J 'j~~L-~ r~ 'JblIljI '<'L o c:: s.: vr-', rr~ ~~ zC z--'-' cJ5 S:~ ~(i :;:~ -' ZO ,~-O '-c Z =< ......=<h"\al"'~""' _ ~~M" tl. ':;" ;j 11 L-:> I.::.J :;,1 ~;: .j i c-; , ~::) "':,;; :'~:i () ;~'!5,li )-<.~ ('-, c:5r-n :;..':! 3.J --< ~"'.il :}t s::- - 'I'll ,-" ~ r', . " 4- ~, -"""-.,~: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JAMIE SHUMBERGER, Plaintiff v. : NO. 00 -~7P~ eo; ('t-~ : IN CUSTODY KEITH RUMMEL, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, JAMIE SHUMBERGER, Plaintiff, to proceed in forma pauperis. I, Maryann Murphy, Esquire, of Legal Services, Inc., attorney 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 services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. Vu~ L/rJJ~ fM Maryann urphy, Esquire - ! Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 J.D. # 61900 Attorney for Plaintiff ~ :, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JAMIE SHUMBERGER, Plaintiff : NO. v. : IN CUSTODY KEITH RUMMEL, Defendant AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am JAMIE SHUMBERGER, the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: JAMIE SHUMBERGER Address: P.O. Box 505. New Kin~stown. PA 17072 (b) Social Security Number: 176-68-8402 If you are presently employed, state Employer: EXEL Address: 320 Salem Church Rd.. Mechanicsburg. PA 17055 Salary or wages per month: $963.00 Type of work: labor - ~--'-- _.,--" If you are presently unemployed, state N/A Date of last employment: N/A Salary or wages per month: N/A Type of work: N/A (c) Other income within the past twelve months Business or profession: -0- Other self-employment: -0- Interest: -0- Dividends: -0- Pension and annuities: -0- Social Security benefits: -0- Support payments: -0- Disability payments: -0- Unemployment compensation and supplemental benefits: -0- Workman's compensation: -0- Public Assistance: -0- Other: -0- (d) Other contributions to household support (Wife)(Husband) Name: N/A If your (husband) (wife) is employed, state Employer: N/A -. ~ "' -'j ~.::. ~ ~ ";I <","-_"" ^--- ",~" '/'---':i: Salary or wages per month: N/A Type of work: N/A Contributions from children: -0- (e) Property owned Cash: Checking Account: Savings Account: $.75 $10.00 $20.00 Certificates of Deposit: -O- Real Estate (including home): -0- Motor vehicle: Make Chevv Nova Cost $800.00 Stocks; bonds: -0- Other: -0- Year 1989 Amount owed $400.00 (t) Debts and obligations Mortgage: N/A Rent: $425.00 Loans: $400.00 Monthly Expenses: $1.243.00 (g) Persons dependent upon you for support (Wife) (Husband) Name: N/A -, ' .. Children, if any: Name: Brandon Age: 2 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: i h !fJd , !lIl.8 ~" "''''''~<''''Wlldifigl\i!.~_~~~ii!I'l;,:ilI:'-'-Hl:I_il~.' tI ~,"- _~..d!I "~~"'lIlr (') c: s:. -ern r"'lt-:~; ~~~~; ?:C ~ :E;o ~O :pc Z :z t ~ .... tN V, .. ~ -;-l 1 <:> ':' , " C!. CJ .;~, o ~. ('::: .- , (]'. , '"( -:() --'-1", ,_ -T1 ',':'~L=) >:-5~"n ':-; '"'J:;o<- ~o =< :r;l>>> --~~ ~ - - ... ...-." - -~',-c~ , JAMIE SHUMBERGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : VB. : NO. 00-4782 CIVIL TERM . . KEITH RUMMEL, Defendant : CIVIL ACTION - LAW IN CUSTODY . . ORDER OF ClClURr AND ~, this 3 ot consideration of the attached and directed as follows: day of ()~ Custody Ccnciliation Report, , 2000, upon it is ordered l. The Mother shall have primary physical custody of Brandon Rummel, born December ~5, 1997. 2. After his release from incarceration, the Father shall have four periods of supervised visitation with the Child at the Y.M.C.A. in Carlisle. The parties shall cooperate in contacting the Y.M.C.A. within two weeks of the Father's release from incarceration to schedule the periods of custody under this provision. 3. After the Father has completed the four periods of superviSed visitation at the Y.M.C.A., the Father shall have periods of supervised custody at the residence of the parties' friend, Mary Singer, for eight weeks on Saturdays from lO:OO a.m. until l2:00 noon or at other times arranged by agreement of the parties and the supervising individual. 4. Neither party shall consume alcohol or use illegal drugs during the Father's periods of visitation or partial custody. Both parties shall ensure that all third parties having contact with the Child, including the supervising individual, comply with this provision. 5. The parties and counsel shall attend a second Custody Ccnciliation Conference in the Cumberland County Court House, Jury Assembly Room, with the Ccnciliator, Dawn S. Sunday, Esquire, on December 21, 2000 at 9:30 a.m. 6. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall take all reasonable steps to ensure that third parties having contact with the Child comply with this provision. 7. This Order is entered pursuant to an agreement of the parties at a . .'~ -- ".~-, '"G1 custody Conciliation Conference. The parties lIl3.y modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. cc: Maryann Murphy, Esquire - Counsel for Mother Keith Rummel, Father ~ (\'.f0 0 ~~ _~-O \0 ~ " ! ~,~~ d - ,~,1!I\lI! " .-,--. ~~~~'-~ - ~ <lm~,~ F!! EU -CfFiCE ,y -"r'.', ,." "-I.n Y \.....i. ;'-: - !.i":~_-i\tlil\Jl 0,,--' t"'I^, '\ lU Ult I --,j Pr'1 'J. ?Q .;- '.'"'" ('U' "'. '. ']' -"'", 'TY v 1\'1 ctJ iL_h, ';L! lJU0N PENNSYLVANIA ~I",,~ ~ff~~~~~~m~~lI!I'li'l J_ilI!tlml.~,___ "" - "'-"-~", ~, JAMIE SHUMBERGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . . . vs. : NO. 00-4782 CIVIL TERM : KEITH RUMMEL, Defendant : CIVIL ACTION - LAW : IN CUSTODY CUSTODY ~IATICN SUMMARY REPCRT IN ACCDRDANCE WITH ClJlIIBERLAND COONTY RULE OF CIVIL PROCEDURE 19ls.3-8, the undersigned Custody Conciliator submits the following report: l. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRE!ilTLY IN CUSTODY OF Brandon Rummel December 15, 1997 Mother 2. A Custody Conciliation Conference was held on September l4, 2000, with the following individuals in attendance: The Mother, Jamie Shurnberger, with her counsel, Maryann Murphy, Esquire, and the Father, Keith Rummel, who is not represented by counsel. 3. The parties agreed to entry of an Order in the form as attached. Sf fk~A Date I 9, :kot'J , Da~ Custody Conciliator ," '-',' '" ~.i Ii .. .~ JAMIE SIlUMBERGER, Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA : . . vs. : NO. 00-4782 CIVIL TERM : KEITH RUMMEL, Defendant . . CIVIL ACTION - LAW IN CUSTODY . . ORDER OF CXXJRT AND roi, this ;)~ ~ day of ~ consideration of the attached CUstody Conciliation Report, and directed as follows: , 2000, upon it is ordered 1. The Mother, Jamie Shurnberger, shall have sole legal and primary physical custody of Brandon Rummel, born December lS, 1997. 2. The Father, Keith Rummel, may have contact with the Child only as arranged by agreement of the parties. Edward E. Guido, Jy ~ . f\ 0' L--ot' 0\' 1--' ~ cc: Maryann Murphy, Esquire - Counsel for Mother Keith Rummel, Father . "". ,~. -"", " ~-. {....c \,' :C' :C:)TNW 00 m::c 29 Ail 7: :-;9 ("U"""j' ., ,.. "-'1' v l\il.jt. -i'L/~_!\JL; CL\...i'JTY PENNSYD!i\Nll~ " ",< ~m!!~!W1~!1ll!li~'1l~ .,,~.4_ ,_. I !!~~!!!Il<"'lL ~" " ,~- -. - ~<" -.-, JAMIE SHUMBERGER, : IN THE CXlURT OF CXlMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. : NO. 00-4782 CIVIL TERM : KEITH RUMMEL, . CIVIL ACTION - LAW . Defendant : IN CUSTODY PRIm JUDGE: Edward E. Guido CUSTODY caiCILIATIOO SUMMARY REPCRT IN AccmDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 19l5..3-8, the undersigned CUstody conciliator submits the following report: l. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURREl!ilTLY IN CUSTODY OF Brandon Rummel December l5, 1997 Mother 2. A Custody COnciliation COnference was held on December 2l, 2000, at the Cumberland County Court House Jury Room, with the following individuals in attendance: '!he Mother, Jamie Shumberger, with her counsel, Maryann Murphy, Esquire. The Father, Keith Rummel, did not contact the Conciliator or appear for the Conference. 3. An Order was entered by this Court on October 3, 2000 following the initial COnciliation COnference providing for the Mother to have primary physical custody of the Child and the Father to have, after his release from incarceration, periods of supervised visitation with the Child at the Y.M.C.A., followed by supervised visitation at a friend's home. A second Conference was also scheduled in the Order to review expansion of the Father's custody periods. The Mother advised the COnciliator that the Father never contacted her after the first COnciliation COnference on September l4, 2000 concerning the Child or any other matter. '!he Mother stated that she contacted the Y.M.C.A. to initiate arrangements for visitation but was advised that the Father had not contacted that agency either. '!he Father has not exercised his rights to the periodS of visitation provided in the prior Order dated October 3, 2000. According to the Mother at the first COnference, the Father has had no contact with the Child since at least February 2000. 4. Based upon the representations made by the Mother at the Conference, and the fact that the Father failed to appear at the Conference or contact the COnciliator, the Conciliator recommends an Order in the form as a~~~ed. , f). < ~ ~I ~n (J/~ Date ' Dawn S. Sunday, Esqui CUstody COnciliator