HomeMy WebLinkAbout97-05457
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EMORY A. MUNDIS, IV, I IN THE COURT OF WIMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
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VS. I NO. 97-5457 CIVIL TERM
REBECCA L. MUNDIS, CIVIL ACTION - LAW
Defendant . IN CUSTODY
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CUSTOOY o::t<<:ILIATICtI SlHtARY REPOOT
IN ACXXXUlANCB WITfI CDIBERLAND 0XHlY RULE Ol" CIVIL ~
1915.3-8, the undersigned Custody Conciliator submits the following report I
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAM8 Dl\T8 Ol" BIRTII
ClJRRfNl'LY IN CllS'lOOY Ol"
Jessica Victoria Kelley April 17, 1989
(generally known 195 Jessica
Victoria Mundis)
Father
Kevin Martin Mundis August 29, 1990
Father
2. A Conciliation Conference was held on November 6, 1997, with the
following individuals in attendance: the Father, Eniory A. Mundis, IV, with
his counsel, Samuel L. Andes, Esquire, and the Mother, Rebecca L. Mundis,
who appeared at the Conference without legal counsel.
3. The parties agreed to entry of
an ~der in the fotm as attached.
1 , \,."/.'./j,,, .-"ot!LJ,.
Dawn S. Sunday, Esqu re
CUstody Conciliator
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II EMORY A, MUNDIS, IV"
II Plainti iT
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I REBECCA L. MUNDIS,
Ii Defendant
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Ii ORDER OF COURT
Ii AND NOW, this ~ day of ('),'I,(;\:)(J 1- ,1997, upon consideration of the
Ii Complaint tiled in this malter, it is hereby directed that the parties and their respective counsel
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II appear beforeh)\~ JI\ . \, \.. ''i( I'..~.' the conciliator, at ,~ Cf W, Hn I (')
I' ~, I Me-I \'1)\ \Ie (.\.>11 '(j , Pennsylvama, on \ \,. )( . ~, the ~ day of
i ~J\JC"'r<'\bc C , 1997, at lJ ,()l) o'clock u.m. for a Pre-Hearing Custody Conference. At
I such conference, an etTort will be made to resolve the issues in dispute; or if this cannot be
I i accomplished, to define and narrow the issues to be heard by the Com1, and to enter a temporary
II order, All children aged five or older may also be present at the conference, Failure to appear at
II the conference may provide grounds for enlry of a temporary or pennanent order.
[I YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
Ii HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
!I FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 17 - 5-4'7 CIVIL TERM
IN CUSTODY
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COURT ADMINISTRATOR, FOURTH FLOOR
CUMBERLAND COUNTY COURT HOUSE
I COURTHOUSE SQUARE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 240-6200
FOR THE COURT,
BY I U' '>t
CUSTODY CONCILIATOR
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I' REBECCA L. MUNDIS,
II Defendant
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Ii COMPLAINT FOR CUSTODY
I, AND NOW comes the Plaintiff, Emory A. Mundis, IV, by his altorney, Samuel L.
I~ Andes, and makes the following Complaint for Custody:
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il I. The Plaintiff is EmOlY A. Mundis, IV, an adult individual who resides at 36 Riverview
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" Drive, Enola, Cumberland County, Pennsylvania,
2. The Defendant is Rebecca L. Mundis, an adult individual who resides at 176 Cedar
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Ii Lane, Carlisle, Cumberland County, Pennsylvania,
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II 3. The Plaintiff and Defendant are husband and wife, having been married on July 9,
1990 in Linglestown and separated on September 12, 1997,
4. The Plaintiff and Defendant are the natural parents of 2 minor children, as follows:
A. Jessica Victoria Kelley, who is generally known as Jessica
Victoria Mundis, age 8, bom 17 April 1989. Although the Plaintiff is
not this child's biological father, the child has lived with the Plaintiff
and Defendant since she was only weeks old and the Plaintiff stands in
loco Darentis to the child as a result,
B, Kevin Martin Mundis, age 7, born 29 August 1990.
Plaintiff seeks an award of primary custody of the children.
The Plaintiff lives with his parents, Emory A. Mundis, III, and Jean Mundis.
The Defendant lives with the two children,
EMORY A. MUNDIS IV,
PlaintitT
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IN HIE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION" LAW
NO. '17 )"'I.\) CIVIL TERM
IN CUSTODY
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8. The Plaintiff has not participated as a party or in any other way in any litigation
concerning the custody of the children in this or any other COUl1.
The Plaintiff has no infonnation of a custody proceeding concerning the childrr:n in a
Court of this or any other jurisdiction,
Plaintiff knows of no other person not a palty to this action already who has physical
custody of or claims to have custody or visitation rights with the said children.
9, The best interest and pennanent welfare of the children will be served by granting the
relief requested by Plaintiff because he can better provide for the children and their needs,
especially in light of their mother's involvement with a man who is guilty of child molestation and
her exposure to that man.
10, Each parent whose parental rights to the children have not been tenninated and the
person who has physical custody of the children have been named as parties to this action,
!Ii WHEREFORE, Plaintiff requests this Court to grant him custody of the children, Jessica
II Victoria Kelley and Kevin Martin Mundis,
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S ' Andes
Attorney for Plaintiff
Supreme Court ID If 17225
525 N. 12'h Street
Lemoyne, P A 17043
(717) 761-5361
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