HomeMy WebLinkAbout97-06837
5. The parties wcre ablc to rcsolvc the counseling issucs. Ilowever, as the Futher wus sceking a
complctc revcrsal of the custodial schedule so that he would huve primary custody and the Mother
would hllvc partial custody during July lInd August and the Mother's willingncss to adjustthc schedule
wus limited to lIn additional evcning during altenJuting wecks, no lIgrccmcnt was tinlllizcd at thc
conferencc and it will be necessury to schedulc a hearing.
<I. The Father's position on custody is us follows: The Fathcr indicatcd that he will be leaving
thc area lor approximately sevcntcen weeks of basic military truining in mid-September lInd thcrcfore
requestcd that his pcriods of custody with thc Child be substantially expand cd in July and August 2005
prior to his dcpurture. Spccifically, thc FlIther secks primary custody ofthc Child during that time with
periods of wcekcnd custody during altcmating wecks for thc Mothcr in addition to hcr onc wcek of
vacation. The Fathcr bclieves that it is imp0l1ant that hc havc thc opportunity to spend this additional
time with thc Child in light of his upcomiug cxtcndcd absence from thc urea during which he fccls he
will havc very limited contact. The FlIther indicatcd that the Child does well and is happy during his
periods of custody with the Father and oftcn wants to stay ut thc cnd of those pcriods. On the
graduation issue, the Fathcr proposcs thai his parcnts bc pcrnlitted to bring the Child to Arizona lor the
ceremony aftcr whieh thc Fathcr would be available to provide care for thc Child.
7. Thc Mothcr's position on custody is as follows: The Mother does not bclieve it would be
best for the Child to change the custody schedule during thc two months before the Fathcr's dcparture
for military training. According to the Mothcr, thc Chi Id has cxpressed u strong preference to be in thc
Mother's custody, wherc hc has friends to play with during the duy. The Mothcr cxpressed concern, as
she had in thc prior conference, that thc Father Icaves the Child with the Father's parents during much
of the Father's periods of custody and does not take advantage of the time hc currently has with the
Child. The Mother expressed a desire to accompany the Child to Arizona for the graduation ceremony,
after which she would transfer custody to the Father.
8. The conciliator submits an Order in the fom! as attached scheduling a hearing to address the
issues of the custody schedule for the months of July and August 2005 and also the arrangements for
the Father's military graduation ceremony in November. Counsel requested that at leust four hours be
allotted for the scheduling of the hearing. It is also requested that the hearing be expcdited due to the
immediate nature of the Father's request for additional periods of custody.
~l"1 ~ ~r-/}OOS"_
Date
~&
Dawn S. Sund"y, Esquire
Custody Conciliator
.
j .
I . ..
I
!
i
I
i
I
i
I
I
.,
7. This Ordcr is cntcred pursuant to lInllgrcemcnt of the Pllrties lit u custody conciliation
confercncc. Thc PlIrlies may modify the provisions of this Order by mutulll consent. In thc abscncc of
mutulIl conscnt, thc tcrms of this Ordcr shall control. y
BYTH'COURT, )' /'
\..-lAI.-_
Edgar B. Bayley J,
ce: ~~erry, Esquire - Counscl for Mother
..reannc B. Costopoulos, Esquire. Counsel for Fathcr
~
05~ .31'~ o.s
1/
,. "
..
, <::>
rr; i,'~ i'!:
"
,.
" , (}) ,
( "
I '.,"-
,
(
,
ii " ~'J
.""-
,
l.-~' U! -
".
.... '-
l.r_ ,r,
( :> L ,
" , ..
"~ '.~)
. '
no circumstance shall the child be absent from school lor II period in exccss ofthrce (3)
days. Father or his mother shall inform Mothcr of the time and place of Father's
graduation as well as the dates and times the child will be picked up and dropped oft' at
leastthrce (3) weeks in advance of departing to attend the ceremony.
4, Father shall be responsible lor any costs associated with the counseling set forth in
paragraph 5 of the prior Order of this Court dllted MlIY 31,2005. If the parties cannot
agree on a counselor, Father shall provide Mother with a list of live (5) counselors within
a twenty (20) mile radius of Mothcr's residcnce from which Mother shall select one
counselor with whom the parties will participate in counseling to address concerns which
have arisen with regard to the ability to cooperate and maintain civility in order to
promote the Child's interests.
BY THE COURT:
Hon. Edgar B. Bayley
provision, schedule chllnges dcaling with Father's drill weekends and military
leave, and a directive for the parties to participate in counseling. This Order is
attached hereto liS Exhibit B.
6. Although not fully addressed on May 25, 2005, the date of the custod)"
conference, since Mother's counsel having to attend another proceeding for which
he was running late, Father made an oml request for additional custody over the
summer since he is to begin basic training in the fall and will not see the ehild for
several weeks. Fathcr agrced to submit a proposal to Mothcr through counsel.
7. Fathcr's counsel faxcd a lettcr on May 27, 2005 containing Father's request to
essentially !lip-flop thc current schcdule for the summer of 2005 only. In
addition, Father asked that his family be perl11itted to take the child with them to
Father's basic training graduation ceremony in the fall of 2005. Father also
provided thc names of two counselors in an etTort to get started on the new
counseling provision contained in thc May 31, 2005 Order. See fax - Exhibit C.
8. On June 2, 2005, Mother's counsel informed Father's counsel that Mother did not
agree with Father's summer custody proposal and she would only agree to tmde
some weekends such that Father would have most of the weekends ill July.
Mother's counsel also informed Father's counsel that although Mother agreed
fundamentally with permitting the child to attend thc gradulltion ceremony, she
wanted to wait until closer to the cercmony to discuss the details. Unfortunately,
once Father leaves for basic tmining he will bc without recourse if Mother latcr
rescinds her vague acquiescence for the child to attend the cercmony. Therefore,
.
B. THANKSGJVING: In evcry ycar thc Mother shall havc custody of the Child
on Thanksgiving Day f'rom 9:00 urn until 2:30 pm and the Fathcr shall huve
custody from 2:30 until <):00 pm.
C. NEW YEARS: The New Ycars holiday shall run from New Years Eve at
5:30 pm through New Years Day at 5:30 pm. Thc Mothcr shall havc custody of
the Child over thc New Y cars holiday in odd numbered years and the Father
shall havc custody in evennumbcred ycars. For purposes of this provision, the
entire New Years holiday shall bc deemed to fall in the samc ycar as New Yeurs
Eve.
D. MOTHER'S DA Y I FATHER'S DAY: In every year, thc Mothcr shall have
custody ofthc Child f'or the entire Mothcr's Day weekend and the Fathcr shall
have custody of the Child cvcry year for the entirc Father's Oayweckend from
Friday 6:00 pm through Sunday at6:30 pm. In the event a party misscs a
weckend period of custody undcr this provision, thcre shall be a make up
weckend for that party eithcr immcdiately preccding.or following the holiday so
that each party has two consccutive wcckend periods of custody.
E. EASTER: The party who has custody of thc Child undcr the alternating
weckend schedule ovcr Easter, shall huve custody of the Child on Easter Day
until 2:30 pm and the othcr party shall have custody from 2:30 pm until
9:00 pm.
F. JULY 41": The party who has custody of thc Child under the rcgular custody
schedule shall have custody of the Child on the July 4'11 holiday.
G. PARENT'S BlRTHDA YS: The Mother shall have custody ofthc Child every
ycar on her birthday (J anuary 9) from 5:30 pm until 8 :30 pm and the Father shull
have custody of the Child cvery year on his birthday (June 26) from 5:30 pm
until 8:30 pm. In the cvent thc Mother's period of birthday custody falls on the
Father's regular period of partial custody on Tuesday, the Fathcr's custody
pcriod shall automatically be rcscheduled to the following Wednesday. In the
evcnt the Mothcr's period of birthday custody falls on the Fathcr's rcgularly
scheduled weekcnd period of custody, the Mother shall have custody of the
Child for the entire weekend and the Father's weekend shall be reschedulcd to
the immediately following weekend. Thc alternating weekend schedule shall
continue thereafter unaffectcd by the adjnstment which will result in each party
having two consecutive weekcnd periods of custody.
H. CIIlLD'S BlRTHDA Y: In evcnnumbcred years, the Father shall have a
period of custody on the Child's birthday (May 14) from 5:30 pm unli18:30 pm
and in odd numbered years, the Mother shall have a period of custody wilh the
Child on the Child's birthday from 5:30 pm until 8:30 pm.
I. In the event uny period of holiday or birthdllY custody Iillls on a wcckday und
is schedllled to begin ut 5:30 pm, the bcginning time for thc period ofellstody
shall be adjustcd to 6:00 pili.
J. The holiday custody schedule shall supercede lOld take precedence over the
regular custody schcdule.
6. Unless otherwise agreed betwecnthe purties, custody exchangcs shall take place inside
Nell's Supermarket on Spring Road in Carlisle. In the evcnt Nell's Market is c10scd due to a holiday
or other circumstances, the partics shall exchunge custody inside the Carlisle Wal-Marl.
Both parties shall ensure that there ure no third parties present (or on the premises) during the
exchanges of custody. The partics shall conduct all exchanges of custody in a cooperative and civil
manner in order to promote the best interest of the Child. Each party shull notify the other in the event
that he or she will be more than 15 minutes late for an exchange of custody.
7. Both parties shall abide by all laws regarding appropriate child restraint in motor vehicles.
8. The Mother shall be entitled to have custody of the Child for one uninterrupted weck each
year upon providing at least 30 days advance wrillen notice to the Father. When the Mother's period of
extended custody under this provision is scheduled during the Father's regular weekend period of
custody, the Father shall have a make-up period of weekend custody during the weekend immediately
preceding the Mother's selected period of custody. The Father shall have extended periods of custody
with the Child during the summer each yelll' with the specific arrangemcnts to be established by
agrecment of the parties.
9. In the event either party intends to rcmove the Child from Penn3ylvania for all ovenjight
period or longer, the party shall provide advance wrillen notice to the other party of the address and
telephone number whcre the'Child can be contacted.
10. The parties shall arrange for the Child to have one counseling session with Georgi
Anderson to address issues raised by the Father with respect to the conl1ict experienced by the Child in
the custody situation. The Father shall be responsible to schedule the appointment during the Father's
custodial period. In event the counselor is not available during the Father's period of custody, the
Mother shall schedule the session during her cllstodial tillle. The Father shall be responsiblc for all
costs of the counseling.
II. The parties agree that discipline of the Child shall be the sole responsibility of the parents
and that unrelated third parties, such as the Father's friend, April, shall not discipline the Child.
12. Neither party shall do or say anything which may estl'llnge the Child frorn 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 otht;r parent. Both parties shall ensure that third pa..ties having contact
with the Child cOlllply with this provision.
..."
EXHIBIT B
NOV 0 2 200' Jlr
CHRISTINE L. SHERIFF,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
97-6837
CIVIL ACTION L.A W
MARK W. RUMMEL,
Defendant
IN CUSTODY
ORnER OF COURT
AND NOW, this 6~ day of ViJ1J.-aJ........ , 2001,
upon consideration ofthc allachcd Custody Conciliation Rcport, it is ordcred and directcd as follows:
1. The prior Orders of this Court datcd February 27, 2001 and October 22,2001 arc vacated
and replaced with this Order.
2. The parties shall promptly initiate counseling for the Child with a professional selected by
agreement of the parties. The purpose of the counseling shall be to evaluate the Child's adjustment to
the custody situation focusing on the parents' respective allegations of alienation of the Child's
affections and also to obtain recommendations concerning the Child's best interests. All costs of
counseling which are not reimbursed by insurance coverage shall be shared equally between the
parties. Both parties shall ensure that there arc no third partics present at the time of the counseling
sessions unless specifically requested by the counselor.
3. The Mother, Christine L. Sheriff, and the Father, Mark W. Rummel, shall have shared legal
custody of Christian T. Sheriff, born May 14, 1997. Each parent shall have an equal right, to be
exercised jointly with the other parent, to make all major non-emergency decisions <Iffecting the
Child's general well-being including, but not limited to, all decisions regarding his health, education
and religion. The parties shall cooperate in sharing all information pertaining to the Child al'd shall
communicate directly with regard to issues coneeming the Child.
4. The Mother shall have primary physical custody of the Child.
5. The F<lther shall have parti<ll physical custody of the Child on alternating weekends from
Friday at 6:00 p.m. through Sunday at 6:30 p.m., beginning October 12,2001. In <Iddition, the Father
shall have custody every Tuesday Irom 6:00 p.m. until 8:30 p.l11. The Father may also have custody at
any additional times as <Irranged by agreement of the parties.
6. Thc purties shall share lJI' alternate huving custody of the Child on holidays us follows:
A. illRISTMAS: The Christmas holiday shall be divided into Segment A, which shall
run from Christmas Eve at 12:00 noon through Christmas Day ,It 12:00 noon, lInd Scgment
B, which shull run from Christmas D,IY at 12:00 noon through Deccmber 26 lit 12:00 noon.
Thc Father shall have custody of the Child during Scgment A in odd numbered years and
during Segment B in even numbered yeurs. The Mother shall have custody of thc Child
during Scgment A in even lHllnbered yems and during Segment B in odd numbered years.
B. T1IANKSGIVIN,..g: In odd numbered yeurs, the Father shall have custody of the Child
on Thanksgiving Day from 8:00 u.m. until 9:00 p.m. and in even numb,:red years, the
Mother shall have custody of the Child on Thanksgiving Day from 8:00 u.m. until 9:00 p.m.
C. NEW YEARS: The New Yeurs holiday shull run from New Ycars Eve at 5:30 p.m.
through New Years Day at 5:30 p.m. The Mother shall have custody of the Child over the
New Years holiday in odd numbered years and thc Fathcr shall havc custody in even
numbcred years. For purposes of this provision, the entire New Years holiday shall be
dcemcd to fall in the same yeur as New Years Eve.
D. MOTHEI~'S DA Y/JlATHER'S DAY: In evcry year, thc Mother shall havc custody of
the Child on Mother's Day from 9:00 a.m. until 8:00 p.m. and the Father shall have custody
on Father's Day from 9:00 a.m. until 8:00 p.m.
E. MOTHER'S 81 RT IJI)A Y/FATIIER'S DIRTlIIlA Y: The Mothcr shull havc custody
of the Child cver yeur on her birthduy (January 9) from 5:30 p.m. until 8:30 p.m. und the
Father shall havc custody of the Child cvcry year on his birthday (June 26) from 5:30 p.m.
un,il 8:30 p.m. In the cvcnt the Mothcr's pcriod of birthday custody fulls on the Father's
regular pcriod of partial custody on Tuesday, the Father's custody pcriod shall
automatically be rescheduled to thc following Wedncsday. In the cventthe Mother's pcriod
of birthday custody falls on thc Father's rcgularly schcdulcd weekend period of custody, the
Mother shall have custody of the Child for the entire weekend and the Father's weekend
shall bc rcscheduled to the immcdiately following wcekend. The alternating weekend
schedule shull continue thcreafter unaffected by the adjustment which will result in each
party having two consccutive weckend periods of custody.
F. CIIILD'S l)lnTlJl)A Y: In even numbered years, the Father shull have a period of
custody on thl; Child's birthday (May 14) from 5:30 p.m. until 8:30 p.m. and in odd
numbered years, the Mother shall have a period of custody with the Child on the Child's
birthday from 5:30 p.m. unlil 8:30 p.m.
O. In the event any period of holiday or birthday custody falls on u weekduy und is
scheduled to begin at 5:30 p.m., the beginning time for the period of custody shall be
adjusted to 6:00 p.m.
..
H. Thc holiday custody schedule shall supersedc und take preccdence over the regulllr
custody schedulc.
7. Unlcss otherwise agrecd hetweenlhe parties, ull custody exchanges shalltakc placc inside
the building of the Carlislc Police Department. Both partics shall cnsure that there arc no third partics
prcscnt during the exchanges of custody. The parties shall conduct all exchanges of custody in 1I
coopcrativc and civil manncr in ordcr to promotc the bcst intcrests of the Child. Each party shall
notify the othcr party in the evcnt he or she will bc morc than 15 minutes late for an exchange of
custody.
8. Both parties shall abide by all laws regarding appropriate child rcstraint in motor vehicles.
9. The Mothl;r shall be entitlcd to have custody of the Child lor one uninterrupted week each
ycar upon providing at least 30 days advance writtcn notice to the Father. When the Mother's period
of extended custody undcr this provision is scheduled daring the Father's rcgular weekend period of
custody, the Father shall have a makc-up pl~riod of weekend custody during the weekcnd immediately
preccding thc Mother's selectcd period of custouy. The Father shall havc cxtended periods of custody
with thc Child during the sUlllmer cach year with the spccil1c arrangements to bc established by
agreement of the parties.
10. In the event either party intends to remove the Child from Pennsylvania for an ovcmight
period or longer, the party shall provide advancc written notice to the other party of the address and
telephone number where thc Child can bc contactcd.
II. Neither parent shall do or say anything which llIay cstrange the Child fromthc other parent,
injurc the opinion of the Child as to the other parent, or hamper the free and natural devclopment of the
Child's love and rcspect for thc other parcnl. Both parties shall cnsure that third parties having contact
with thc Child comply with this provision.
12. This Ordcr is entcred pursuant to an agrecmcnt of the parties at a Custody Conciliation
Conference. The partics may modify the provisions of this Order in writing by mutual conscnt. In the
absence of mutual consent, thc terms of this Ordcr shull control.
/
BY mE COURT, ,I
,./
.I r ;wA
\
J.
Edgar B. Baylcy,
cc: Dirk E. Berr)I, Esquirc Counselli.w Mothcr
Jeanne B. Costopoulos, Esquire .. Counsel for Father
'_"4,(",-)
-
,,}"'t.iL.J.....-L .
II. () (..01
c)-.
III\wp,'I\jdtl,dlA:.'./lcrlrr,cu.
10. Each parent whose parental rights to the child have not been terminated and
the person who has physical custody of the child has been named as parties to this action. No
other persons are known to have or claim a right to custody or visitation of the child.
WHEREFORE, the Plaintiff requests this Court to grant her custody of the
child to the Plaintiff.
Respectfully submitted,
FLOWER, MORGENTHAL, FLOWER & LINDSAY
Attorneys for Plaintiff
"-C. 5L ~0'04
~' . a es D. Flower, Jr.
1 East High Street
. artis/e, PA 17013
(717) 243-5513
1.0. No. 27742
Date: 1;)- l 0-91
4
:tf
1,_ J
,-.) 11_ -
(~ ('r ,!d'
, . I' i"
IJ~ ('I) (r
1..(1 (()
~ ,..) .. 11- ~.S
\.() .~
.J 0:
, UQ C
I
,
,"
I'
),'.i
"",;:~1,!i';ir.':}'~;t:j?!)/::r:?\~~,:/\:~?~;~;:~:~};~J\ ,.
I, -'.1',_ ;'--1 ,," I I ,ii, I 'i. '\ 'r,' 'I H,\'l~
~i' ,,-, II) ~ III \ " ", I, '., d ,I'" ,I
,,'f ",' ,',Ill '" Il " .,', j , ;II, ' 1", , \ j '~i'" .~t tJ
,\1,', ,'! l' : '; 't' 1,1, ,'I; I ( , ",II" ",: ',I. 'i :~:,' "\' ~t:' \ I
.,'/:>,1_ _,', "1."1, ftt 1 . " i, ,I:", '1\ \ '/ 'c' ~,..' ' -I ,'1'\;';;','1'.
"",':-"'-"H'- --'", I ']" I" ", "r"ln4\/'/"lj"'/ /
:'-)I':II'i,I"'.'.",-,,,,,, ,I l"I" I" ""'1' ;"/
1'- ,,~(, 11. j: ) 1 '!1 " "l' 'Jl' I t '\11 L " ',,' ,
' I"~ -,-,.; -I" -', ~ - I ' ,,' ~ , " 'II I '~l t ,Il'u 'j \ "" '11
; I, __, "I',. ,1' : ;' '____, ,d !' '" .1' IJ, 'I. 1_ 1 1" j 1 \', ~ I i,l '
'T ,," -,,'-'-_:', =:.<1," '_ I ' 1'1 'I "'. 1\ ,I , ,~
"',', 'I': ", \, '--;;- ,I,' i!':\ ,j,: L!'l p .' H 'l II r, I' " "'J'~J
,-;':-1,,::," '\'''':1,' '-'\;i_ il'; 'J'~' ,:,'.1' 'dl ,l 'i,'11 , III ;:,', '1.i j j-"
,I;IL',-_l'" -- ',~I ,-fl,'--" I" /'t'I' \If' 1:I'tII;"~d,tjl~llj
:,', II.' 1, ,'/, 1-' "-'1'1, . ,J, 'I 11'1 i'l
.. , " _/' ,I, 1 I' ./j/ ;,,1,~; ',", Ii I /jL:.\' ~,Jd~t~
,;J .-:', . - ,...1'1:-" ',1.". !t':-I;'--':/; ,p.r!('!.I/jf
,1 - ': i~: !'-';~{ft'_ ,:--i-; ;'~,~-i -:::::;\, ,;_I.', ::,~:~:;j:~:~;ti-;{:~'~::~;s iN ~~1~}l:\~ '~2
",' ], .'j' "I:',' 1 ': '(I C', "d'~"'l:',j f1'f"'/l';'~'-~I\-d!'11
.' :', ~'; : J;i:":';-'J:(ti~t;:,:';,/~i,':;;i{;j:':~!~i(I;;'t
, ,- _-,I ",I""f' -111"'~I'fI--"h!{r1~-'
.' ',I :~ "H:'::;li'~:I\:;:;):;':::\~\';::!;l;';:;:Y;I~~j.
;, '.' ~I'"I,t-';'"d '."-".,[:\)-1,>1., '.lh,Jj'4f4J'il;'\~'\'tfrli_
, t" ".;:I,_-~-::-,'-; ,\ i_:/ '" j: >~' ::,:;'>:~, !,~t::~\SI::~,li:,: (,:.'.t;; n(~\:'_:~?V- -1;>-1
"ft;";(I\' "I' - "('1_1 j,,-','-- \1('''' ""--="-'1"-lIj''-1j
,::r ," "I'''' 1 :':'I":~}",)i,:~,,;~,i'}:;;~:;:j{~\~{;,\[:
I nil . -I" I ,_ J ,_",_ /'\ -!,~\.-" '
,:;- :/': 'i :-_~ {;_i:"\l;~rf:; l~r!i/'~(iI,V;}J~~l
,: '~.,~-: 11'-_:_ ,,~V\-j I~L --:;-1 f'-"l:'~~!-':!
I',
I'; 1,'I__i",
" ,I,,:
','_ I-,,!_, ,'-,I;
_',': I'i'h'
'!"'\'
1-,"
',-,il
,
,-.,,,
,,'
"'-',-,
,:_-'-'
'1i_'I',-,-
,'));,',"
11
"#,f;f~~l;~;;,>' ,:'"
-~"""["")'!-"""" IL,,;,, '
fi.~%,i;;i2",::',;: :".'( "i.' , ..1.
-i--:Y/l;N,'} :,! I '-Ij!l ~,
~.. \'(~ r :"\" i l( ,.f" -' ":1, "
(~!-'_L~";(,I;-',::.ll,l-, -I' II
'I]I'I,c"_;"'I"Jil\ d." ,,\ I
y;N;;;;I-\~;;;: .\~:---i\ ,~'"i;:'t':' f,~' d -', I .'_.'
'w,\","-"j', ,- - 1)' 'I; I, ~\'Fi 'I
~~;::;:.,i;,:;~:':':::\":""" ',"
,,~;-fijh .,:-Y' -'l\!l_ 1_ _;.' , I, ,_,
I~'t);~:_;_";\1;J-_;:.'-..\ ;'~~, ;'1': ;' _....~. :',', I'
. ;ifJ:'!,,,:.':':"::\!.::' ': 'i, ,I"
'~;~:ti:,i~:i/:}H},'~:!,;,:"::"!, I 'I,'
',;. "
'\il',
,
'iI:
;01_,',
I,"~
I"
l' ~,i
"1:",-,,,1;
,.,,'.'\:
,
""j'
, ,)\
1',",\,
','
"
(,'.il
'I
"
"
"I --t, ,I'
, "
i,I"l',",:, "
" IJ ,j
.,
.I
'I,.
,,'1
_J'
, ,<11"
'"
"
I,'"
'1 L'
!l'; "
"11' i'l
, " "
, "
, ,
'l"h, !'
i J:-r,~,
~Ii,<
.Ii,
,T,
,;1,"
l -i~h\l{ !~\'~\\I~jirt r;};\i" ':-)
\ tl/~, 1 I, ,- f; f.v':' '; ','- ',- , J,
J.tf~!:~ff(;",!::
'_'[-:i' ,.,\ '~Il'_"'" , :' \, _, 1'1_1 , ' I' ,I '
- t~.~\'; (11 '''I;l' , ,(!I'
I!~;t!f!~(?~:},t\,,~::,::' (" "
J ~\ ,'(-,t- \ ,'.I;' .-:_;_ \ Illl J \:~' 'j \ ,j- ,', , ,I "
I "'h::'1'.-"---,,L,i ql \,.II-,
'Inn 1':,.",: ;, !~t \ ,. " 1 1'1'
IIY,~!~t'(i_} ;-:.\ _,_IJI_ ': _
~1t,;1j:~~ 'f-!{t;;:;:-!:i',:-'- 'I _- _I,- '~.',
t'll,,, ,,__< ,JL_" -_,-co,
, ;1'1'.1.'1':'_ ,- L',: \-'_1;, _;-'.
',I'-'---':'\-;l--!;/''',,'-,-,-;'
, "1'1' - " .- -'--" ] \
-~-- ,!_J, ~'d!! ij\;::,~,{,ij:_\:,_:; :;~
\i"f_'_lc,I'I,I),I;t'i -_,_
j-'_- ,It-Wl!'.__!'_"!:,'_";"
NM-i:;;-".lf"p-:- '1''-, 'I'
f~f:i:;/)\!(jl,~\i;:',', '" H'
\ , ~ \' "lj1l'\-;' . --,'- -, "f - \ -, ,-, , , 'I
I,:!~~ltl,- _i 'J1i \'i' !-~> , 'I ", ,-'
h ,i'-l"['Y '1-10-.", _'t-_,,;
-',:IV"-':II \j: -,'I
iP;!'_~__I'--- -I'll', ", ";'I! "
JfJ1IW1'!-!., ;_\',1'\ iil,;'!;
'-'-"'1',,-j\;jIo- \,- 1
11.!h1 !~' '';1\_', I-'.j
'f~hl""!:~', '\'1,11
. )nA~";-~i\I,'~-" _t ,', ':11
,"-
" ,
I.. \1:!
,
:Ii"
'I"" "
'-"'-'10, '-,!.\
\I'
,
'"
,
,
, '
"
,,"J,,"
,,":\',.',\1'1
i."1
"'f:::"://:'
I~': ~'\- {!
- \'~!
"1'.-',
'\ 'II
-,I"
'"
"i,
':1
"1,'
. ,
'\1'
>
"
I:,
,1",
,
,
, ,
;!1:
,
'"
',,1,:1,
I'
--J,\" !
'jt,'
't,_;"
1,1'
I
, , 1\
, 'I"~ "
" , ,
, ,
" ,
, , ,
, , , ,
"i "
"
,
,
, I,
: , ,
,
,,, " ,
,.,' " .';
" ,
; r "
, , " "
, " " "
", ,I
, ,
~ I I ,
"-'-,
-:,_'li
II!"
,
.,i\
"
"
,
"
, 'i
"
"
:',
il!,i:
'i i'\'I,
;;ll,
"
, '
,
,
, "
"fl,,_,
;"
"
'I \':" ~
"I,
ti'
," ,'i',
,
"
, d. I
, "
'1,li
", '
'j' " '1;..\/
'I:: '/I"
\1 ,_\_1,
,
'I,-t
;" 'I_"l",
'"I,;/Ij>,
\ ",I
I;'
',.
"-"
',I.
,
" L !
I "1-:
1" "
1;,,1'
"
,
"
'/-\
,"
;-,l
. '
, ,
"
,\ l
",'
'I ')'
"
I'
,-t,
'I <'
:'
'.
, ,'_ _I~ -j i: ;; -' ) "
'~ '''1''4 '
" . '_\:' \'..I.h l
,
, "
" ,
,
'I I, , , ,
I'
'"
"
.. "
'-', "
{ ;i
~ :,~
';/'\1
;1)"-1'
, ~."'..".,
-r.............
p. ~ ." .l. ','
~,. ,,'.
~ ' ,
,
,\;'f
-Id _'
"
, I
,
, "
MARK W. RUMMEL,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
i
I
I
I
I
I
I '
! ..
I
I
I
r
,.
I.
V.
: IN THE comn OF COMMON I'LEAS OF
: CUMBERLAND COUNTY,I'ENNSYL VANIA
: NO. 97.6837 CIVIL TEI~M
CHRISTINE L, SHERIFF,
Plaintiff
ClISTODY STIPULATION
AND NOW, comes Christine I. Sheriff, Plaintiff and Mark W. RUlIImel,
Defendant, and enter the following Custody Stipulation:
1. The Mother, Christine L. Sherifl~ and the Father, Mark W. Rummel, shall have shared
legal custody of Christian T. Sheriff, born May 14, 1997.
2. The Mother shall havc primary physicul custody of the child.
3. Father shall have the following periods ofpartiul physical custody:
a. Evcry Tuesday from 5:30 p.m. to 8:30 p.m., except when Christmas andlor
Christmas Eve falls on a Tuesday.
b. Alternating Saturdays from 9:00 a.m. to I :00 p.m., except when Christmas and/or
Christmas Eve falls on a Saturday.
c. Evcry December 26 from 5:30 p.m. to 8:30 p.m.
d. Such other times as the parties agree.
4. Father shall be responsible for transportation.
5. In the evcntthat Father will be morc thanliftccn minutes late for pick up or drop ofT,
he shall so notify Mother.
.tIr:tl ,)\",'
ow
,g
(~
>: 1.0 ')...
n, !-
,'.'i ~<,.
11.,r~ I.,)',J
(Ie., ,-= ':.J:?
-"{ , rj :j
~~ - ", '--
('jl;:, .-5.
'!' '.' ,"'") :((1)
(':Ii N ,."
~;_J,l fJ' ;-
;t. '")',0
I, ".0: ~t~n..
i .....)
". '3
0 <:.:> u
CHRISTINE L. SHERIFF,
plaintiff
: IN THE CXlIJRT OF cnIMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
VB.
NO. 97-6837 CIVIL TERM
.
.
MARK W. RUMMEL,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
auJER OF <XlURT
.-
AND toi, this 1:11-- day of ,(1)/ uH , 2001, upon
consideration of the at~-CUstody conci~;-;port, it is ordered
and directed as follows:
1. The prior Order of this Court dated October 23, 2000 is vacated
and replaced wi th this Order.
2. The Mother" O1ristine L. Sheriff, and the Father, Mark W. Runmel,
shall have shared legal custody of Christian T. Sheriff, born May 14, 1997.
Each parent shall have an equal right, to be exercised jointly with the
other parent, to make all major non-emergency decisions affecting the
Child 's general well-being including, but not limited to, all decisions
regarding hie health, education and religion.
3. The Mother shall have primary physical custody of the Child.
4. The Father shall nave partial physical custody of the Child every
Tuesday fran ,5:30 p.m. until 8:30 p.m., beginning !;'ebruary 20, 2001, and on
alternating weekends fran !;'riday at 5:30 p.m. through saturday at 5:30
p.m., beginning March 2, 2001. The Father may also have custody at any
additional times as arranged by agreement of the parties.
5. The parties shall share or alternate having custody on holidays as
follows:
A. CHRIS'l'MAS: In every year, the Father shall have custody of
the Child fran Christmas Eve at 5:30 p.m. through Christmas
Day at 9:00 a.m. and the Mother shall havo custody iran
Christmas Day at 9:00 a.m. through December 26 at 5:30 p.m"
B. NEW YEARS: In every year, the ~lother shall have custody of
the Child on New Years Day from 9:00 a.m. until 3:00 p.m. and
the !;'ather shall t~ve custody from 3:00 p.m. until 8:30 p.m.
C. 'l'fIANX8GIVINGI In every year, the !;'ather shall have custody of
the Child on ThanksgiVing Day fran 9:00 a.m. until 3:00 p.m.ÿand the Mother shali have custody on ThanksgiVing Oay
beginning at 3:00 p.m.
....
D.
HOl'IIER'S Ill\Y/FA'1'lIIlR'S DAY: In every year, the Mother shall
have custody on Mother's Day and the Father shall have custody
of tho Child on Father'B Day frcm 9:00 a.m. until 4:00 p.m.
E.
HOl'IIER'S BIRTlIIll\Y/[A'1'lIER'S BIRTIIIlI\Y: The Mother shall have
custody of the Ch ld every year ori her birthday (January 9)
from 5:30 p.m. until 8:30 p.m. and the Father shall have
custody of the Child every year on the Father's birthday (June
26) from 5:30 p.m. unt:il 8:30 p.m. In the event the Mother's
period of birthday custody falls on the Father's regular
period of partial custody, the parties shall schedule a
make-up period of custody for the !;'ather by agreement.
F.
CflILD'S BIRTlIIll\Y: In even numbered years, the !;'ather shall
have a period of custody on the Child's birthday (May 14) from
5:30 p.m. until 8:30 p.m. and in odd numbered years, the
Mother shall have a period of custody with the Child on the
Child's birthday from 5:30 p.m. until 8:30 p.m.
G. The holiday custody schedule shall supersede and take
precedence over the regular custody schedule.
6. The Mother shall be entitled to have custody of the Child for 1
uninterrupted week each year upon providing at least 30 days advance
,.rritten notice to the !;'ather. The Mother's period of custody under this
provision in 2001 shaU run fran May 12 through May 20. When the Mother's
period of extended custody under this provision is scheduled during the
!;'ather's regular weekend perica of custody, the !;'ather shall have a makeup
period of weekend custody during the weekend irrrnediately preceding the
Mother's selected period of custody.
During the sumner 2001, the Father shall haVE! 3 periods of
extended custody with the Child which shall run fran Thursday at 5:30 p.m.
through Sunday at 5:30 p.m. upon providing 30 days advance written notice
to the Mother. The !;'ather shall schedule his periods of custody under this
provision to coincide with his regular weekend periods of custody.
Summer custody arrangements for summer 2002 and continuing
thereafter shall be arranged by agreement of the parties.
7. The Father shall be responsible for providing transportation for
all exchanges of custody, unless otherwise agreed between the parties.
Also unless otherwise agreed, the parties shall exchange CllStody at the
corner of North pitt Street and C Street in Carlisle. The Mother shall
ensure that the maternal grandparents remain in their residence dudng all
exchanges of custody. The !;'ather shall notify the Mother in the event he
will be more than 15 minutes late for an exchange of custody.
8. Both parti'ils shall ensure that the Child is transported in a car
seat at all times. During exchanges of custody, the !;'ather shall be
responsible to put the Child in and out of the car S'ilat in the E'ather's
car.
9. Neither p<,rty shall do or say anything which may estrange the
i'j"";c
t ' ,;" in'{
,
, ,
'. .(.., t,l
, IJ,,\ . ,
\' \ . \ I .
0\ ~r'
'., \.:1.iUtH'{
'\)1.)'" '.' ," 1.01111
C \j,j.'':':'"I''-','-'it'h'\N'\
f'b"'" .
tJ '/3 01 &~/ C'~ /J"" g ~d/ ~~~~..?
lj'I..Jt?/ ~ ~Jta.:or/ z "4 dh-'~
9' ./] 0/ A . /1 ...z, ,:7
",,;f MM-lfd ;ti ~ ~
CHRISTINE L. SHERIFF,
Plaintift7Respondent
v.
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No, 97-6837 CIVIL TERM
MARK W. RUMMEL,
, DefendantPetitioner
CIVIL ACTION - AT LAW
: CUSTODY
AMERICANS WITIl DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law ~o comply with the
Americans with Disabilities Act of 1990, For infonnation 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.
BY THE COURT:
Dale
1.
.
D.
Marum I S D^Y/FA'l'Hl'J\' S D^ '{:
~ ':'~";::>.iy en Mothet"'s Day
at t/h~ :.,i10:: on Father.ln L\.\y
In 8VQ"C"1 'y'tJut:' , ~fll2 Mothot." shall
and the !;'athe:- sh.lll have custcc,'
trcm 9:00 il.lll. until 4:00 p.m.
t.:. ManIER'S BIRTElDAy/r,'^TIIER'S BIR'l'ElDAY: Tile ~lothQr shall haw,
custody =~ the Ciiild evory YQar cn he!." bi:-thday (January 9)
f:-om 5:::~ p.m. until 8: 30 p.m. and tho l"ath':Jr shall have
custody =: the Child every year on the Fathet" ';. bi:-thday (Jun"
26) frcr.: 5:30 p.m. until 8:30 p.m. In the eV-Jnt the Mothet"'s
P'!dcd c: bir-thday custcdy talls cn the c'ather's regula:
pedcd -" partial custody, the pclt"ti,;!S shall schedule a
make-up p.edod ot custody tor the <'ath,"::" by agt"eement.
E'. CBILD'S 8:ffi'l'IIDAY: In even numeet"ed years, the Fathet" shall
~a~e a pedod ~~ c~s~ody en the Ch.Ud's birthday (May 14) f:-cr
:l:.;<J f-.;". untl.J. d:...JG f)_II;. d!1G In cdJ nurnb.:::.::-,,;:d j..-ear:s, cn~:
Mothe1: snall have a pedo:J of custociy with tho ChUd cn th"
Child's ::i:"thday f!:"cm 5:30 p.m. L:''1~il B:30 p.ni.
G. The hclicay custcxiy schedule shall supe1:seda and take
p~eceden~~ ove~ th~ regular custody" schedule.
6. Th<: ~Ioth<:::" s.~all be entitled to have cust~dy of t.l'~ Child f::1: :
unintet"t"1.:ptee week ,;ac.l yea:- upon pt"oviding at least 30 days advance
written notice to t,1,; :'athe1:. The Mothot"'s p1doci of custo:iy under u'lis
p~ovi.sion in 2001 sha':l :-:C:1 ::-:(;1 ~1ay 2.~ ~l-1=~I':::;-' tolay :'J. tV~'l'~:1 t:,~ ::;::,~= t 2
peciC<: (jf ex-canced c"':,Si:cdy L:ndez: this provision is scheduled during c.'te
Father' I s :-e-;1ular ''';..;-:9ke:lc pe:-icd of cusc.oay, the Father: shall have a makeup
periee of weeken:: C1.:.s-::xiy du:ing the weekend immediately p:-eceding t.h~
~Io;:he:" loS selected r....ecix of custcdy.
Du=ing c...,e .s'..:.~re!': 2001, th~ ?:It....,e= shall have .... ,ge=ieds c::
extenae:: custody v.'i~1 :.1-2 Child which shall run frail Thursday at 5:30 p.;r,.
c.."=-;Jugh Sunday at j: 3: ;J.In. L1;)cn pcoviding 30 days advance 'written noti'=2
:8 th~ l~lo~~:'. Th~ ?.:::1S:: shall sche':.h.:l'2 his i?2r.iods of cU.'=itcdy unde:- t~i;;
:J:-:Jvision to coincide ",Id:., his t'e-~ula:: weekend pe:-iccs of cuscody.
SUJT':m,==-
::h~'~:9;'1f:e~ ~:la.Ll
C:':Si:::':;Y a==3ngerrencs ::0:-
::.~ a..==~nqec by a.]reem'9:lt '-d..
sun1i1€:- 2',X::
::110 ~ar:-.:i~.s.
=.ilC
CC,l':ln'.Jl~::
:;T~ ?~::1.a:" 3,.,=..2.1 be :-ii;s:xmsible :~r: p::'::Jvicirrd t:-anspo::tat:icn .0:........
2.11, 2X:::'3...:::.:.3 ~f C!.1~:::-::/, 'xlss.:: iJche!:""'..;isa agreec betweogn the p:l:'::"SE.
,;150 unless o:Jle~...i3'= a::::e9c, tn'9 ;2=:l~S shall exchange custody at th:
c:::-ne:- ::f :::;:-::~1 ?i.:: 5::':,:.;:: an:: : .3t;:'~"~: i:; ;~,,=:-l':':':;~-:J. Th,;? NQthe:- sha.l~
9:l.SiJ:"':? :."1::: :'.10: ii,~'i :::=:-,~ :;::~;:::;;c::1n':3 :'"-:::'J2:n i;; :h,=:.:- r.9sid~nc~ du:,in:: 2.2.:
~;.;::"-,.:.~;:,:: :;'
',~'i..l.l. tY.~ ~t:::--:: :.13.'-, ,.,.: ,--:-,::-:"'::'2,;
,,~-
.,
-"- - ~ .. -- ._,
:lC :'':'''::', :'.T~ .;:::.-S:.~:":1
. .
.;::':':;'1a..'1'~:'? ::: ::.;s:,::cy.
:',~le e';-=:1: ,-.~
.- .
~ - .... -, -,
, - -., -~ -., '--.-
3-55.:
::~:::. ;:a=:::,:::s .s-:.:lll ~.~~.::u::'? ::."12: ;:;'12 .:hild i,;;
:.ime~.
::..: :"ir/~
eX2;i.~n;;e.3
c:u::"3:.::d:;!
c::an:pJ::-:e':: ,trl a. -=.::.:-
:"..1-9 :~\:J1-::::- shall ;::-J
:'~-2a:: ir: "t:-,-a Fathe=- I oS
~ . :
ca.:-.
:'9s;:>.Jil..si:::;1.:- '-v :'jIJ',: :.::.-s ::lil.=: in J.:l:~ CU~::3: :::'1:: c.:::=
:';.,E:;,T:~'::
~l:'l~.-:::!':i:J:' "',._'_" :-;-"o(':!.'! ,;:;..:-::'::".3.,"~-2 __I'::
.'
.'
Child frcm the other: ,:ar:cnt, injuz:-c ::he oJ;linion oi the Child as :::> the
other parent,. ot: hamper: the ire<:! ane natural dovelopncnt of the .:.,ild '13
love and resJ;lOct for: the other: F.1re:-.:. Both p;icties shall enSL:.:'i: that
thitti parties having contact with the a,ild comply with this provision.
10. '!his Order is entered pursuant to an agreement of the parties at a
Custcdy COnciliation Conference. The parties may modify the provisions of
this Order by mutual ccnsent. In the absence of mutual consent, the terms
of this Order shall con~rol.
EiY THE O::URT,
~
. ,.yiJ. Ani;,' ,.
cc: Jacqueline M. Verney, Esquire - CO~3el fOt" Mother:
Johnna J. Kopecky, Esquir:e - Counsel for: Father:
- ~ .
~
-:'11)" COD'( (ReM r<.i.CORD
l., r. h" .. I h'" '"t" ;31 my hJod
In T'l",~"n'f \"""'0 ",' .' .,
i <;:;' 111\".'1 ~ ... . "" <,
and ph seal of SJid ~ur t ':-(~'ble, pa'41" .', '
ih' 17 rj 0, .t,,~.....,...., ,','" ..
Is. .../.!-.....
. /, ," "'"'.;. ,,:..J1i}.tr./J. .
I. . LU.J. ...,...... Pl:~hor.ota''1 '
~ rlf
ii; '"~ ~ .S;)
... tr. ,n
I"~~ ..... \
~..(.) t~ ::) .... ~
I"'" :L: \";)~'.J
,,1.( : u.. l.J~ ~
j" . !.~:~ ~ ...,:)
f,~ ~ r- "t ,'n ~
, ,'\/ --
'.j". , , ,1 --- -
C. iib
I "
(,.: /H.L. , ''\:
II. ." (~ ~
',. ,. d
~- ., \I) ~
.
CHRISTINE L. SHERIFF,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO, 97-6837
CIVIL TERM
MARK W. RUMMEL,
Defendant,
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this day of , 2001, upon
con$ideration of Ihe allached complaint, it is hereby directed Ihal the parties and their
respective counsel appear before , the conciliator, at
on the day of , 2001,
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. All
children age five or older may also be present atlhe conference. Failure 10 appear atlhe
conference may provide grounds for entry of a temporary or permanent order.
BY THE COURT:
By:
Cuslody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply wilh
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 contaCI our office. All arrangements must be made al least 72 hours
prior to any hearing or business before Ihe court. You must allend the scheduled
conference or hearing.
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
, .
CHRISTINE L. SHERIFF,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-6837
CIVIL TERM
MARK W. RUMMEL,
Defendant,
: CIVIL ACTION. LAW
: IN CUSTODY
PETITION FOR MODIFICATION OF PARTIAL
CUSTODY OR VISITATION ORDER
The Petitioner, Christine L. Sheriff, respectfully repre,ents that on February 27,
2001 an Order of Court was entered for Partial Physical Custody and Visitation, a true and
correct copy of which is attached.
I, This Order should be modified because:
a. The existing holiday schedule does not adequately distribute custody
between the parents. Specilically, the existing Order prevents the mother
from ever having a Christmas morning with the Child or a mid-day
Thanksgiving dinner with the Child.
b. The parties are unable to reach agreement on makeup periods of custody
following Christine's birthday as envisioned in paragraph five E (5E).
The existing schedule does not have sufficient flexibility in the individuals
that are specifically authorized to pick up or drop off Christian to allow
for the routine schedule changes of normal living,
c, The existing Order requires that the maternal grandparents remain in
the residence during all exchanges of custody, This provision was a petty
restriction that has 110 basis in the conduct of the grand parents or in
benefit to the Child,
d. Thc cxisting Custcdy Ordcr docs not contain sullicicnt rcstrictions for
unrclated third partics who arc currcntly vcrbally assailing and
disparaging thc mother at thc scenc of the custody transfer.
2, Tile PClitioner/mother, Christine Sherift: respectfully requcsts that paragraphs
two, thrcc and four of the Order dated February 27, 200 I rcmain unchangcd. Pctitioner
seeks modifications and/or additions to paragraphs five through nine of the aforesaid order:
a, Thanksgiving: Each parent will alternate custody from 8 a,m,
Thanksgiving morning until 8 p,m, Thanksgiving evcning every other
year,
b, Christmas: Each parent will have alternating periods of custody on
Christmas Evc and Christmas, on an every other ycar basis.
Alternatively, the father may have custody on Christmas Eve from 8 a.m,
until 8 p,m, every ycar if'this arrangcment is prcferablc to altcrnating
ycars of Christmas Eve/Christmas custody,
c, Thc parcnts will altcrnatc New Y cars Evc/New Years custody cvcry
other year with the custody period bcing from 5:30 p.m, New Years Evc
until 5:30 p,m, New Years Day.
d, Mothcrs birthday: Everything from paragraph five E (5E) from the
February 27, 2001 Order would be incorporated in its entirety with the
exception of thc last clause which reads "thc parties shall schedulc a
makeup period of custody for the father by agreement." This clause
should be rcplaccd with the clause, "if for any reason the mothcr's
birthday should fall on a day that would normally be the father's partial
custody period, the father's partial custody would automatically be
scheduled for the following day.
e, In the event either parent is unable to deliver Christian to the pickup or
drop-ofT destination, such parent will notifY the other parent as soon as
possible as to the change in person dropping ofT or picking up Christian,
Such alternate individuals for drop oil' or pickup will be limited to (I)
relatives of either parent or (2) any third party individuals that are
mutually agreeable to both parents.
f No restrictions on presence or participation of either maternal or paternal
grandparents with regard to drop ofTs, pickups, visitation or performing
as allernates in the event that a parent is unable to be present at the
required time,
g. Third parties that are unrelated to either parent, new spouses of either
parent, new girl tTiends, or boyfriends of either parent are required to
remain inside their respective vehicles and remain silent throughout the
custody transfer, unless the third party is preapproved as acceptable
transfer alternate by both parents.
WHEREFORE, Petitioner, Christine L. Sheriff, respectfully requests that this
Honorable COllrt maintain the status quo regarding primary custody and modifY the existing
Custody Order as indicated above because it will be in the best interest of the Child.
Law Office of James K. Jones
~--
J.5Irk E, Berry, Esquire .
Attorney for Petitioner
7 Irvine Row
Carlisle, PA 17013
(717) 240-0296
- ------
2"-
\..
,... In ?-; cij
,,1.; t" 00
I'~ -, ~~~ ~~ L ~ ...).
\)1'
, ,. .," ,J;:: - -
,:':.. ');1 &
, , ~
,..) ',;/)
, , , ~ ~
'!"" ~
(1.. 'ii) ~
u_' 1 .
<" '.
, , .~j
I~ (.)
CHRISTINE L. SHERIFF,
Plaintillll>ctitioncr
: IN THE COURT OF COMMON PLEAS OF
'CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-6837
CIVIL TERM
MARK W. RUMMEL, : CIVIL ACTION - LAW
Defendalll/Respondent : IN CUSTODY
fETmON FOR CIVIL CONTE~PT FO~
DISOBEDIENCE OF PARTIAL CUSTODY ORDER
AND NOW comes Christine L. Sherin; by and through her counsel, Dirk E. Berry,
Esquire, respectfully avers as follows:
I, That on February 27,2001, the Honorable Edgar B. Bayley, Judge, entered an
Order awarding Petitioner Primary Physical Custody of Christian T. Sheriff, date of birth
May 14, 1997, with the Respondent having Partial Physical Custody every Tuesday from
5:30 p.m. until8JO p,m. and on alternating weekends from Friday at 5:30 p,m. through
Saturday at 5:30 p.m. Additionally, the parties had agreed to various custody arrangements
that varied by holiday,
2. Paragraph nine (9) 1)1' the aforesaid order states, "Neither party shall do or say
anything which may eslrange the Child from the other parent, injure the opinion of the Child
as to the other parent, or hamper the free and natural devel(\pment of the Child's love and
respect for the other parent. Both parties shall ensure that third llarties having contact with
the Child comply with this provision".
], During the recent custody transfers, father's new girlfriend, whose name, upon
information and belief, rnay be Campbell, has exited father's vehicle and verbally' assailed
and disparaged Petitioner in front of Chrislian, The father, Mark Rummel, appears to have
made no allempt to stop or discourage his girlfriend from verbally abusing and disparaging
Christine SherifT during these cuslody transfers,
I,
CHRISTINE L. SHERIFF,
Plaintitf/Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: NO. 97-6837
CIVIL TERM
MARK W. RUMMEL, : CIVIL ACTION - LAW
Defendant/Respondent : IN CUSTODY
CERTIFICA TE OF SERVICE
I, Dirk E, Berry, Esquire, do hereby certitY that on this day I served the Petition for
Civil Contempt for Disobedience of Partial Custody Order by first-class mail, postage pre-
paid, upon the following persons:
Jeanne Costopoulos
1400 N, Second Street
Harrisburg, PA 17102
The Law Office of James K. Jones, Esquire
Date:
q-/3 -0/
.~
Dirk E': Bell y, Esq
Attorney for Petitioner
7 Irvine Row
Carlisle, PA 17013
(717) 240-0296
---::;
~@
55
,... 1/) ~
.,... B "
,,: ~'.~
I, ~ ~'I-.J
11: _7 :-).~ .';t-
, (.) ---.! '"<'S ~
~\.: )"J ~
li" (.:- . ~; I. ~
oj' I'")::". ~
; . -
r"" .'11) . """*
r:; I,': ti\
n. i (~] '6 ~
L.'.' 10_
(Jl
II ~:J
c' 0 (.)
H0
s5
:>- ..:r
~ M ~
....-
lll':') ..
- 3~
( ) "...: -
f{~. :'l:; .)7
(') '- ">: '''f
., (". q::'i
6" In -.~
':.1 ' - ..
)
a-i.: .... i::J~
I. Ll
1.1, 0 :q
;:.:
0 - a
0
(I. The parties shall share or alternate having custody of the Child on holidays as lallows:
A. Q.lli!STMAS: The Christmas holiday slwll be divided into Segment A. which
shall rUII from Christmas Eve at 12:00 nooll through Christmas Day at 12:00 nOOIl, aud
Segment 13, which shall run Irom Christmas Day at 12:00 uoonthrough December 26 ut
12:00110011. The Father shall have custody of the Child during Segment A ill odd
numbered years and during Segment B ill even numhered years. The Mothcr shall have
custody of the Child during Segment A ill even lIumbered years alld durillg Segment B
in odd lIumbered years.
B. TIIANKSGIVING: In odd numbered years, the Father shalllulVe custody of the
Child 011 Thanksgiving Day from 8:00 a.m, until 9:00 p.l11. and in cvennumbered years,
the Mother shall have custody of the Child on Thanksgiving Day from 8:00 a.m. until
9:00 p.m,
C. NF.W YF.AnS: The New Years holiday shall run from New Years Eve at 5:30 p.m.
through New Years Day at 5:30 p.l11. The Mother shall have custody of the Child over
the New Years holiday in odd numbered years and the Father shall have custody in even
numbcred yeurs. For purposes of this provision, the entire New Year~ holiday shall be
deemed to fall in the same year as New Years Eve.
D. MOTlIER'S OA Y/FATIIER'S I)A Y: In every year, the Mother shall have
custody of the Child on Mother's Day from 9:00 a.m. until 8:00 p.m. and thc Father
shall bave custody on Father's Day from 9:00 a.m. until 8:00 p.m.
E. MOTJIER'S nIHTUOAY/FATIIER'S IJIRTlIDAY: The Mothcr shall have
custody of thc Child evcry year on her birthday (January 9) from 5:30 p.m. until 8:30
p.m. and the Father sh<11l have custody of the Child cvcry year on his birthday (June 26)
from 5:30 p.m. until 8:30 p.l11. In the event the Mother's pcriod of birthday custody
falls on thc F<1ther's regular period of partial custody on Tuesday, the Father's custody
period shall automatically be reschedulcd to the following Wcdnesday. In the event thc
Mothcr's period of birthday custody falls on the Father's regularly scheduled weekend
period of cuslvdy, the Mother shall have custody of the Child for the entire weekend
and the Father's weekend shall be rescheduled to thc immcdiately following weekend.
The alternating we,~kend schedule shall continue thercafter unaffected by thc adjustmcnt
which will result in each party having two consecutivc weckend pcriods of custody.
F. CIIlLD'S II IH.TI ill.i\ Y: In even numbered years, thc Fathcr shall have a period of
custody on thc Child's hirthday (May 14) from 5:30 p.m, until 8:30 p.m. and in odd
numbcred ycars, the Mother shall have a period of custody with the Child on thc Child's
birthday Irom 5:30 p.m, until 8:30 p.m.
G. In the cvcnt any pcriod of holiday or birthday custody falls on a wcckday amI is
schcduled to begin at 5:30 p,m" the beginning timc for the period of custody shall bc
adjustcd to (,;{)O p.m.
H. The holiday custody schedule shall supersede and take precedence over the regular
custody schedule.
7. Unless otherwise agreed between the parties, all custody exchanges shall take place inside
the building of the Carlisle Poliee Department. Both parties shall ensure that there arc no third parties
present during the exchanges of custody. The parties shall eonduet all exchanges of el1stody in a
cooperative and civil nHlnncr in order to promote the best interests of the Child. Each party shall
notify thc other party in tl1\: event he or she will be more than 15 minutes late for an exchange of
custody.
8. Both parties shall abide by all laws regarding appropriate child restmint in motor vehicles.
9. The Mother shall be entitled to have custody of the Child for one uninterrupted week each
year upon providing at least 30 days advance written notice to the Faiher. When the Mother's period
of extended custody under this provision is scheduled during the Father's regular weekend period of
custody, the Father shall have a make-up period of weekend custody during the weekend immediately
preceding the Mother's selected period of custody. The Father shall have extended periods of custody
with the Child during the summer each year with the speci fie arrangements to be establishcd by
agreement of the parties.
10. In the event either party intends to remove the Child from Pennsylvania for an overnight
period or longer, that party shall provide advance written notice to the other party of the address and
telephone number where the Child can be contacted.
II. 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 ensure that third parties having contact
with the Child comply with this provision.
12. This Order i. entered pursuant to an agreement of the parties at a Custody Conciliation
Conference. The parties may modify the provisions of this Order in writing by nllltual consent. In the
absence of mutual consent, the terms of this Order shall control.
/
BY TIlE COUi /
.;/ {
u ._...uu_~~......J-~-'--4-._..___u__.__
Edgar B. Baylc.y, '---- J.
cc: Dirk E. Berry, Esquire ,Counsel for Mother
Jeanne n. Costopoulos. Esquire Counsel for Father
. ,
C"fL~ '}.......f...,.t / \,. oJ J.o/
0...
fC. c:' ....
(r. I;:::;
.' /.
~? ~f) :J .of
L'.\' ()::-;
\.~-,~ <- .-" )"
..... ~~\ .
,.' ,..... -, "':~.1
.~...-
1 ('~\ "0)
C ,..; :\ ,I ..~
" t. .~-
~.,. 1\'lJ
,I, C'I 1>-
(.J .
I' ~j
t.) C,) U
1:'1 (,1'1"':'1 FICF
C. T' " " """'r."rIY
.j- , ' ." ':,1, r.
03 NOV -5 Pi! I: fie
CUMA::,' ,,"'" /', 'IJ'l'rv
."."" "'.. \..., I.,
PENI'lSYLWINIA
II'S'?!] Ovt. ('tC~.)l~ :6 4 .&&tp
//..sY'3 '7Wt:.. ""'~l.<dv z{ --4 c'~
)('5"()J Co/t? ~ -d- 4 ~~,
CHRISTINE L. SHERIFF,
Plaintill'
. IN THE COURT OF COMMON Pl.EAS OF
. CUMBERLAND COUNTY, PENNSYLVANIA
v.
. NO. 97-6837
CIVIL TERM
MARK W. RUMMEL,
Defendant
. CIVIL ACTION - LAW
. IN CUSTODY
P.E1'ITlON.F.ORMQDU'ICAT.lQN.Of.A.CIJSTIlliY_ORDER
I, The Petition of Christine L. Sheriff, Mother/Plaintiff respectfully
represents that on November 5, 2001, an Order of Court was entered for primary and
partial custody, a true and correct copy of which is attached.
2.
a.
This Order should be modi tied because the child has enjoyed
minor modifications to his holiday custody sehedule, for approximately one and one-half
years, by agreement of the parents.
b. However, by letter dated September 9, 2003 Father notified
Mother that he was unilaterally rescinding all verbal agreemeJJls.
c. Client seeks to formalize the parties' previous agreements,
regarding holiday periods, whkh would result in the following changes to the November
5, 200 I order:
Thanksgiving: Amend the time frame to read 9:00 a.m. to 6;00 p.m.
Mllther'.lLllaylEllther.'.s..DJQ.; Amend the Mother's Day/Father's Day schedule
such that the custodial parent (who would have had the child from 9:00 a.m, to 8:00
p.m. on their respective Mother's Day/Father's Day) will instead have the child the
entire weekend with drop off time, for Father's weekend, being 6:00 p.m. on Friday
evening and the child returning Sunday at 6:30 p.m.; and on MOlher's Day the child will
remain with Mother the entire weekend.
l'ollce..Statlun: The parents have used North Middletown Police Station since
November of 2002, instead of the Carlisle Police StatiOll, as indicated in the November 2,
2001 Order. Mother requests that Order be amended to read that the Norlh Middletown
Police Station will be the custody exchange location.
Ell.ster: The parr,nts will alternate custody on Easter day utilizing either the
Mother's Day/Father's Day time frames or the Thanksgiving time frames on an every
other year basis. Custody is modified such that each school year one parent has the
Thanksgiving holiday and the olher parent will have the Easter holiday.
Fourth of .July: Custody on the Fourth of July will follow the normal schedule.
regardless of whelher it falls on a week day or a weekend.
WHEREFORE, Petilioner/Mother Christine L. Sheriff respectfully requests that
this Honorable Court modify the existing Order for custody and parlial custody because
II will be in the best interest of the child.
JJ~/r?
Dirk E. Berry, Esquire
Attorney for Plaintiff/Mother
7 Irvine Row
Carlisle, PA 17013
(717) 240-0296
B. THANKSGIVING: In every Yl'"r the Mother sh,,1I h"ve custody of the Child
on Th"nksgiving D"y from <):00 mil until 2:30 pm "nd the F"ther slmlllmve
custody from 2:30 until 9:00 pm.
C. NEW Y~ARS: The New Ye"rs holid"y slmll run from New Years Eve at
5:30 pm through New Ye"rs Day at 5:30 pm. The Mother shall have custody of
the Child over the New Ye"rs holiday in odd numbered ye"rs and the Father
shall have custody in even numbered years. For purposes of this provision, the
entire New Years holiday shall be deemed to ftlll inlhe s"mc year as New Years
Evc.
D. MOTHER'S DA Y I FATHER'S DA Y: In every year, the Mother shall h"ve
custody of tile Child for the entire Mother's Day weekend and the F"ther shall
Imve custody of the Child every year for the entire Fathcr's D"y weekend from
Friday 6:00 pm through Sunday at 6:30 pm. In the event a party misses 1I
weekcnd period of custody under this provision, there shall be a make up
weekend for that party either immediately preceding or following the holiday so
that each party has two consccutive weckend pq,riods of custody.
E. EASTER: The party who has custody of the Child under the alternating
weekend schc,dule over Easter, shall have custody ofthc Child on Easter Day
until 2:30 pm and the other party shall have custody from 2:30 pm until
9:00 pm.
F. JULY .4111: The party who has custody of the Child under the regular custody
schcdule shall have custody of the Child on thc July 4'11 holiday.
G. EARENT'S BIRTHDAYS: Thc Mothcr shall have custody ofthc Child every
year on her birthday (January 9) from 5:30 pm until 8:30 pm and the Father shall
have custody of the Child every year on his birthday (June 26) from 5:30 pm
until 8:30 pm. In the event the Mother's period of birthday custody falls on the
Father's regular period of partial custody on Tuesday, the Father's custody
period shall automatically be reschcduled to the following Wednesday. In the
event the Mother's period of birthday custody falls on the Father's regularly
scheduled weekend period of custody, the Mother shall have custody of the
Child for the cntirc wcekend and the Father's weekend shall be reschcduled to
the immediately following weekend. The alternating weekend schedule shall
continue thereafter ulHlffected by the adjustment which will result in each party
having two consecutive weekend periods of custody.
H. CHILD'S BIRTHDA Y: In even numbered years, the Father shall have a
period of custody on the Child's birthday (May 14) from 5:30 pm until 8:30 pm
and in odd numbered years, the Mother shall have a period of custody with the
Child on the Child's birthday from 5:30 pm until 8:30 pm,
I. In thc event any pcriod of holiday or birthday custody Illlls on a wcckday and
is sehedulcd to begin at 5:30 pm, the beginning time for the period of custody
shall bc adjustcd to 6:00 pm.
J. Thc holiday custody schcdule shall supcrccde and take prcccdcnce ovcr the
regul(\r custody schcdule.
6. Unless othcrwise agrccd bctwecnthe parties, custody exehangcs shalltakc place inside
Nell's Supel111al'ket on Spring Road in Carlisle. Inthe evcnt Nell's Markct is closcd due to a holiday
or other circumstances, the partics shall exchange custody inside the Carlisle Wal-Mart.
Both parties shall cnsure thatthcre arc no third parties present (or on the prcmises) during the
exchanges of custody. The partics shall conduct all cxchanges of custody in a coopcrative and civil
manner in ordcr to promote thc bcst interest of the Child. Each party shall notify the other in the cvent
that hc or she will bc more than 15 minutcs late for an exchange of custody.
7. Both partics shall abide by all laws regarding appropriate child rcstmint inl11otor vebicles.
8. The Mother shall bc cntitlcd to have custody of the Child for one uninterrupted wcek each
year upon providing at lcast 30 days advance written notiec to the Fathcr. When the Mother's period of
extended custody undcr this provision is sehedulcd during thc Father's regular weckend pcriod of
custody, the Fathcr shall have a make-up period of weekcnd custody during the wcckcnd immediately
prcccding thc Mother's selected pcriod of custody. The Father shall havc extcndcd pcriods of custody
with the Child during the summcr caeh year with the spccific arrangcments to be established by
agrcemcnt of thc p;\rties.
9. In the evcnt either party intends to remove the Child from Pennsylvania for an ovemight
pcriod or longcr, thc party shall provide advance written notice to thc other party of the addrcss and
telephone numbcr whcrc the Child can be contactcd.
10. Thc partics shall arrangc for the Child to have onc counscling session with Georgi
Anderson to addrcss issucs raised by the Father with respect to the conflict experienccd by the Child in
the custody situation. The Father shall be rcsponsible to schedule thc appointmcnt during the Father's
custodial period. In cvent the counsclor is not availablc during the Father's period of custody, the
Mothcr shall schedule the session during her custodial timc. Thc Father shall be responsiblc lor all
costs of thc counseling.
11. The parties agrec that disciplinc of the Child shall bc thc solc rcsponsibility of the parcnts
and that unrclatcd third partics. such as the Fathcr's fricnd, April, shall not diseiplinc the Child.
12. Ncither party shall do or say anything which may cstrangc the Child from the other parent,
injure the opinion of the Child as to the othcr parent, or hamper the free and natural development of the
Child's love and respect for thc other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
(~ \I rrV
RECEIVED APR 2 9 zoof S
CHRISTINE L SHERIFF,
PlalntlfflPetltloner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97. 6637
CIVIL TERM
MARK W, RUMMEL,
DefendanURespondant
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this day of .2005, upon
consid';ration of the allached complaint, it is hereby directed thatlhe parties and their
respective counsel appear before __._____.___, the conciliator, at
on the _ ,-- day of , 2005, at
_ _.m., for a Pre-Hearing Custody Conference. At such conference, an effort will
be made to resolve Ihe issues in dispute: or if this cannot be accomplished, to define and
narrow the issues 10 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 althe
conference may provide grounds for enlry of a temporary or permanent order.
BY THE COURT:
By:
Custody Conciliator
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 10 disabled individuals having business before
the court, please conlact our office. All arrangements must be made at least 72 hours
prior to any hearing or business before the court. You mustallend the scheduled
conference or hearing.
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 (lET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. Bedford Street
Carlisle, PA 1701J
(717) 249-3166
6. The parties shall share or ulternale having cllstody oCthe Child on holidays as follows:
A. CHRISTMAS: Thc Christmus holiday slmll be divided into Segment A, which shall
run Crom Christmas Eve at 12:00 noon through Christnms Day ut 12:00 noon, und Segment
B, which shall nlll from Christmas Day at 12:00 noon through December;26 ut 12:00 noon.
The Futher shall have custody of the Child during Segment A in odd numbered years und
during Segment B in even numbered yeurs. The Mother shall have custody of thc Child
during Segment A in even numbered years and during Segment B in odd numbered years.
B. THANI,SGIVING: In odd llllmbered years, the Father shall have custody of the Child
on Thanksgiving Day from 8:00 a.m. until <):00 p.m. .lIld in even numbered years, the
Mother shall have custody of the Child on Thanksgiving Day from 8:00 a.m. until <):00 p.m.
C. NEW YEARS: The New Years holiday shall run from New Years Eve at 5:30 p.m.
through New Years Day at 5:30 p.m. The Mother shall have custody of the Child over the
New Years holiday in odd numbered years and the Father shall have custody in even
numbered years. For purposes of this provision, the entire New Years holiday shall be
deemed to fall in the same year as New Ycars Eve.
D. MOTHER'S DA Y/FATlmR'S ()A Y: In every ye.lr, thc Mother shall have custody of
the Child on Mother's Day from <):00 a.m. until 8:00 p.m. and the Fathcr shall have custody
on Father's Duy Irom <):00 a.m. until 8:00 p.m.
E. MOTIIER'S D1RTIIDA Y/F'ATHER'S IIIRTHDA Y: The Mother shall have custody
of the Child ever year on her birthday (January <)) from 5:30 p.m. until 8:30 p.m. and the
Father shall have custody of the Child every year on his birthday (June 26) from 5:30 p.m.
until 8:30 p.l1I. In the evcntthe Mother's period of birthday custody falls on the Father's
regular period of partial custody on Tuesday, the Father's custody period shall
uutomatically bc rescheduled to the following Wednesday. In the event the Mother's period
of birthday custody falls on the Father's regularly scheduled weekend period of custody, the
Mother shall havc custody of the Child for the entire weekend and the Father's weekend
shall be rescheduled to the immediately following weekend. The alternating weekend
schedule shall continue thcreafter unaffected by the adjustment which will result in each
party having two consecutive weekend periods of custody.
F. CIIILD'S D1RTII()A Y: In even numbered years, the Father shall have a period of
custody on the Child's birthday (May (4) from 5:30 p,m. until 8:30 p.m. and in odd
numbered years, the Mother shall have a period of custody with the Child on the Child's
birthday from 5:30 p.m. until 8:30 p.rn,
G. In the evcnt any period of holiday or birthday custody falls on a weekday and is
scheduled to begin at 5:30 p.m., the beginning time for the period of custody shall be
adjusted to 0:00 p.m,
H. The holiday custody schedule shall supcrsede und takc preccdcnce over the regular
custody schedule.
7. Unless otherwise agreed between the parties, all custody exchanges shall take plaee inside
the building of the Carlisle Police Department. Iloth parties shall ensure that there ure no third parties
present during the exchanges of custody. The purties Sh.lll conduct all exchanges of custody in a
cooperative and civil manner in ordcr to promote the bcst interests of thc Child, Each party shall
notify the other party in the event he or she will be 1II0re thun 15 minutes lute for un exchange of
custody.
8. Both purties shall abide by ulllaws regurding appropriate child restraint in motor vehicles.
9. The Mother shull be entitled to have custody of the Child for one uninterruptcd week c~ch
yeur upon providing ut leust 30 duys udvunce wrillcnnlltice to the Futher. When thc Mother's period
of extended custody undcr this provision is schcduled during the Father's regulur weekend period of
custody, the Father shull have u make-up period of weekend custody during the weekend immediutcly
preceding the Mother's selected period of custody. The Futher sh,lll have extended periods of custody
with the Child during the summer euch yeur with Ihc specific arrangelllents to be established by
agreement of the parties.
10. In the e.vent either purty intends to remove the Child li'Dlll I'ennsylvunia for un overnight
period or longer, the party shall provide udvance wrillcn notice to thc other purty of the uddress and
telephonc numbcr where the Child cun be contuctcd.
II. Neither parent shall do or suy unything which muy estrange the Child from the other parent,
injure the opinion of the Child us to the other purcnt, or humper the free and natural development of the
Child's love and respect for the other purcnl. Both parties shull ensure thatthinl purties having contuct
with the Child comply with this provision.
12. This Order is entered pursuunt to un ugrcelllcnt of the purtics at a Custody Conciliution
Conference. The purties I11UY modify the provisions of this Order in writing by mutuul consent. In the
absence of mutual consent, the terms of this Ordcr shull control.
BY THE COURT,
_111-i~,,-_d..J..47J l!L'f
tdgur B. Bayley, J.
cc: Dirk E. Berry, Esquire Counsel for Mother
./eunne B, Cos!opoulos. Esquire Counscl ",r Father
..,)
~ . , -.'f.
, . ~.,<- 'II J ,;J J
I. '.J"""_':"1~ _ \ _ ~(')~"'(l'k(A-' ._._~
--~I"'I!..'" .lJ.... h.lu&~.,.JJJ~.
"Ir,:M;:r.'ar(
~~
,~
~
~
it 1.0 ~
i:~ <'oJ >-
~J~-=j .. ~; ~
f ).1'5 )~~ .....
l....,.r.: :I: '" ~
.1,., ~' .">- ,~. -I'
Cl6 :-) ."j i ,.J '''1
~~ r-
N "J "I "
<>:: ,,~ .....
~ -
, !,"! j
t, v, ._'.'n.. ~ 5
l;.~.. ,OJ'
"" ,..)
N U .".
"
c'; \wp51 \jdfjnJocs\sberiff .cus
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97 - CIVIL TERM
CHRISTINE L. SHERIFF,
Plaintiff,
MARK W. RUMMEL,
Defendant.
IN CUSTODY
COMPLAINT FOR CUSTODY
1. The Plaintiff is CHRISTINE L. SHERIFF, residing at 134 "C" Street, Carlisle,
Pennsylvania 17013.
2. The Defendant is MARK W. RUMMEL, residing at 582 North Middleton
Road, Carlisle, Pennsylvania 17013.
3. The Plaintiff seeks custody of the her son, CHRISTIAN T. SHERIFF, born
May 14,1997, residing with her at 134 "C" Street, Carlisle, Pennsylvania 17013.
The child was born out of wedlock. The child is presently in the custody of
CHRISTINE L. SHERIFF, who resides at 134 "C" Street, Carlisle, Pennsylvania 17013, where the
child has resided his entire life.
The mother of the child is CHRISTINE L. :SHERIFF, currently residing at 134 "C"
Street, Carlisle, Pennsylvania 17013. She is unmarried.
The father of the child is Defendant, MARK W. RUMMEL, currently residing at 582
North Middleton Road, Carlisle, Pennsylvania 17013. He is unmarried.
2
~ IT-
~~ftp .~ ~1ft'"/ (f'Jj. e/
. ~:2 ~ ~~ (jef(.co/
b~ ~r~ 4e? n
~iz;p~~~~ I..t?~.t"/
",..,
(., .;,' .,,,,
.'. ,.
(': 'i.'
~,..., L,j
~ _~ c,_ j
~
,
CHRISTINE L. SHERIFF, : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. : NO. 97-6837 CIVIL TERM
: CIVIL ACTION - LAW
MARK W. RUMMEL, :
Defendant : IN CUSTODY
ORDER OF COORr
AND NrM, this 2'1 day of ~, ~~
consideration of the attached Custody con~1 Report,
directed as follows:
, 1998, upon
it is ordered and
1. The Mother, Christine L. Sheriff, and the Father, Mark W. Rummel,
shall have shared legal custody of Christian T. Sheriff, born May 14, 1997.
2. The Mother shall have primary physical custody of the Child.
3. Beginning January 27, 1998, the Father shall have custody of the
Child at the Mother's residence on four consecutive Tuesdays from 6:00 p.m.
until 7:30 p.m.
4. The parties agree that at the conclusion of the four week schedule
set forth in the preceding paragraph, it is the parties' intention to reach
an agreement on the gradual expansion of the Father I s periods of custody
with the Child in accordance with the Child's best interests. In the event
the parties are unable to reach an agreement as to ongoing custody
arrangements, counsel for either party may petition the Court to have this
matter relisted for an additional CUstody Conciliation Conference.
5. 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 agreement. In the absencE' of mutual agreement, the
terms of this Order shall control.
.~
cc: James D. Flower, Jr., Esquire - Counsel for Mot
Johnna J. Deily, Esquire - Counsel for Father
J.
BY THE
{! ~ "h1J..t
~7~1i
{!~1.
'"'l\.~<f()
~'!2 :Ot l'~\! L? lfJi tlS
)..H~ICd\j;-L:.;..J:b :JO
3~ljjO-O:rll.j
CHRISTINE L. SHERIFF,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
vs.
: NO. 97-6837 CIVIL TERM
:
MARK W. RUMMEL,
Defendant
: CIVIL ACTION - LAW
CUSTODY
CUSTODY CCJilCILIATICti SUMMARY REl'(Rr
IN ACCORDANCE WITH cnmERLAND <XXINTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator subnits the following report:
1. The pertinent infoz:mation concerning the Child who is the subject
of this litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Christian T. Sheriff
May 14, 1997
Plaintiff/Mother
2. A Conciliation Conference was held on January 20, 1998, with the
following individuals in attendance: The Mother, Christine L. Sheriff,
with her counsel, James D. Flower, Jr., Esquire,. and the Father, Mark W.
Rummel, with his counsel, Johnna J. Deily, EsquirE!.
3.
The parties agreed to entry of i!:~~.n the form as
JIl/Iu.r(j;;'/ 19'1Y' ~~
. I Dawn S. Sunday, Esqul.
Custody Conciliator
attached.
Date
SHERIFF'S RETURN - REGULAR
CASE NO: 1997-06837 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SHERIFF CHRISTINE L
VS.
RUMMEL MARK W
MICHAEL BARRICK , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being dull' sworn according
to law, says, the within COMPLAINT - CUSTODY
upon RUMMEL MARK W
defendant, at 1502:00 HOURS, on the 23rd day of December
1997 at 582 NORTH MIDDLETON ROAD
CARLISLE, PA 17013 ,CUMBERLAND
was served
the
County, Pennsylvania, by handing to MARK W. RUMMEL
a true and attested copy of the 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
18.00
3. 10
.00
2.00
$23.10
So answers: .,~
;;P",2/ .
h' Q".c;"~;''"'<: - ~
R. Thomas lJ.ne, erJ.
FLOWER MORGENTHAL F~ER
12/29/ 1997 h~?f'
by ~~-/3
j epu y erJ.
Sworn
this
and subscribed to before
~. ~
oUr - day of
'17 A. D.
me
19
,
~ "'1>' ~ '/'n",". /
I ro honotary)
A ~"T>
,
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 97-6837 CIVIL TERM
CHRISTINE L. SHERIFF,
Plaintiff
MARK W. RUMMEL,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
ASSIGNED JUDGE: EDGAR B. BAYLEY
ORDER OF COURT
AND NOW, this Z) day of O~, 2000, the attached
Custody Stipulation is hereby made an Order of Court.
"((,COUR> /
Edgar B. Bayley
1.
,,~ ,..'
..,.,>j .
.'
..,1
'+'
CHRISTINE L. SHERIFF,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 97-6837 CIVIL TERM
MARK W. RUMMEL,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
CUSTODY STIPULATIOlI!
AND NOW, comes Christine L Sheriff, Plaintiff and Mark W. Rummel,
Defendant, and enter the following Custody Stipulation:
1. The Mother, Christine 1. Sheriff, and the Father, Mark W. Rummel, shall have shared
legal custody of Christian T. Sheriff, born May 14, 1997.
2. The Mother shall have primary physical custody of the child.
3. Father shall have the following periods of partial physical custody:
a. Every Tuesday from 5:30 p.m. to 8:30 p.m., except when Christmas and/or
Christmas Eve falls on a Tuesday.
b. Altemating Saturdays from 9:00 a.m. to 1 :00 p.m., except when Christmas and/or
Christmas Eve falls on a Saturday.
c. Every December 26 from 5:30 p.m. to 8:30 p.m.
d. Such other times as the parties agree.
4. Father shall be responsible for transportation.
5. In the event that Father will be more than fifteen minutes late for pick up or drop off,
he shall so notifY Mother.
WITNESS: IAA. VfA. .1'
~..~L-
lI-yt"~+
STINE L.
~~~.
~~L
SAIDIS
SHU!'liJ:lOWER
&.~lJSAY
....h__.,...,....fJiIN
16W.Bich_
CuIlsIe, PA
II
CHRISTINE L. SHERIFF,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
C~~ERLAND COUNTY, PENNSYLVANIA
v.
MARK W. RUMMEL,
CIVlCL ACTION - LAW
Defendant
NO. 97-6837
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 , 2001 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. All children age
five or older shall also be present at the conference. Failure
to appear at the conference may provide grounds for entry of a
temporary or permanent order pending further Order of Court.
The child shall remain with Plaintiff.
FOR THE COURT,
BY:
Custody Conciliator
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.
YOU SHOULD TAKE THIS PAPER TO YOUR IJ\,WYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONl~, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHEE~ YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
"'.
SAlOIS
:IllJfB.!!OWER
& UI'IuSAY
"".....</F.ISo.(I".1AW
Z6W.H1Bh_
CarllsIe, PA
II
i CHRISTINE L. SHERIFF,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMEIERLAND COUNTY, PENNSYLVANIA
v.
MARK W. RUMMEL,
CIVIL ACTION - LAW
Defendant
NO. 97-6837
IN CUSTODY
PETITION FOR MODIFICATION OF CUSTODY
AND NOW, comes the Petitioner, Mark W. Rummel, by and
through his attorneys, Saidis, Shuff, Flower & Lindsay and aver
as follows:
1. The Plaintiff is Christine L. Sheriff who currently
resides at 134 C Street, Carlisle, Pennsylvania.
2. The Defendant is Mark W. Rummel, who currently resides
at 582 North Middleton Road, Carlisle, Pennsylvania.
3. The parties are the natural parents of one child,
Christian T. Sheriff, born May 14, 1997.
4. The parties previously entered into a custody
stipulation which was subsequently entered by Order of Court on
October 23, 2000; a copy of said stipulation is attached hereto,
made a part hereof and marked as Exhibit "An.
5. The Defendant has expressed to the Plaintiff that he
desires additional periods of physical custody with his son, and
the Plaintiff has refused to give him additional time.
6. Specifically, he has requested the following:
A. Each Tuesday and Thursday evening from 5:30 p.m.
until 8:30 p.m.
B. Alternating Saturdays from 9:00 a.m. until 7:00
p.m. ;
C, Alternating Christmas Eve and Christmas morning;
SAlOIS
;~tl-OWER
&UI'IuSAY
......__.3"A..IAIV
26 W. BJch Street
CarlIsIe,PA
II
D. Alternating holidays throughout the year.
WHEREFORE, Defendant respectfully requests Your Honorable
Court to grant him periods of partial physical custody as stated
above.
squire
VERIFICATION
I verify that the statements made in this Petition 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.
Dated: of V ,1.1:'>01
~ / "~.-.'~'." .~.~;:.~. .
../,:~~, ...,o_'~~~ ----~__,
J r.k vi.~u" --
,// ,,/,.,..
,/ /,/
..
t.
~:-~:__'l- \,4" ;.-:.~.~- --,:,
CHRISTINE L. SHERIFF,
Plaintiff
: IN THE COURT OF' COMMON PLEAS OFr.
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 97.6837 CIVIL TERM
MARK W. RUMMEL,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
ASSIGNED JUDGE: EDGAR B. BAYLEY
AND NOW, this
ORDER OF COURT
13 day of ~-' 2000, the attached
Custody Stipulation is hereby made an Order of Court.
BY THE COURT:
'i.!l.i&~J. &/1
--. . .--"~
<::HRISTINE L. SHERIFF,
Plaintiff
: IN THE COURT OF COMMON PLEAs OF
: CUMBERLANIl COUNTY, PENNSYL VANIA
V.
: NO. 97.6837 CIVIL TERM
MARK W. RUMMEL,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
CUSTODY STlPULATIQ~
~~
::.i~
J:<C.
AND NOW, comes Christine 1. Sheriff, Plaintiff and Mark W. RummeI7~
".- ~~
;;:~
Defendant, and enter the following Custody Stipulation:
()
S~
0 -
'- ': ~1
=:>
"
--i .-
\;) "
-
r<.:
. ;;!
:--..;:.
. D :=1
-,
~<
I. The Mother, Christine L. Sheriff, and the Father, Mark W. Rummel, shall have shared
legal custody of Christian T. Sheriff, born May 14, 1997.
2. The Mother shall have primary physical custody of the child:
3. Father shall have the following periods of partial physical custody:
a. Every Tuesday from 5:30 p.m. to 8:30 p.m., except when Christmas and/or
Christmas Eve falls on a Tuesday,
b, Alternating Saturdays from 9:00 a.m. to 1 :00 p.m., ex.cept when Christmas and/or
Christmas Eve falls on a Saturday,
c. Every December 26 from 5:30 p.m, to 8:30 p.m.
d. Such other times as the parties agree.
4, Father shall be responsible for transportation.
5. In the event that Father will be more than fifteen minutes l,ate for pick up or drop off,
he shall so notify Mother,
~"'-,..-
l~7:":~~,
~~--_._-_..
;,"'""-~~'t,tEi-";;;,:;:'-_:"-~~"-,,:
WITNESS:
~.
"~v=r
~-L:
~y-j '7~-~
~-
-
,-
-
~. ;l~,:;;-;:t~~;. ' y""'~ ,~
_~~~-::::.:::...L;>--=--=:7-:~ :.....~=_
c--;--.-
1'> ".
~--
0 0 c'
.'
c -;",
~ <--
-un; ;-; "T"!
92'-'
_ij N ~.,.'1
Zl~:,,~ . ,---,
(f)I!~: (...J -'1"
~Cc.. ;".::"}
:-~;!,
.-,-) ""t1 ',- -ft
~c: ..".,., . )(~)
.....
>2 (jl"n
Z ::t:J
=<! 'U
(T\ '<
;&
~~,,~ ..
CHRISTINE L. SHERIFF
PLAINTIFF
V.
MARK W. RUMMEL
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
97-6837 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COlJRT
AND NOW, this 25th day of January, 2001, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, E.q. , the conciliator,
at 39 West Main Street, Mechanic.burg, PA 17055 on the 20th day of February ,2001, at 11:00 a.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.
FOR TIlE COURT,
By: Isl
Dawn S. Sunday. ~
Custody Conciliat ..:
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 an'angements
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 THIS 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
4/~'>f;t7 ~ 11'"1'11 H:{ 7
k?)1 ~ ~ /if:~! T?Jj~If,
f~ it!' 'fZ /'fT'''''' J/;p 1'1
~);-\~1d
"i~;!.K).l;;rt ~3?1~~\,;J
\\,fj.iJ
1& -:&"'."\" \ c;)
" ~- ",
'IA U
~s..\ ~,,,
jeJ'b{ !
IV be' /
kl,or '/
,f)
CHRISTINE L. SHERIFF,
plaintiff
: IN THE (XlURT OF <XlMMOO PLEAS OF
: CUMBERLAND COONTY, PENNSYLVANIA
:
vs.
: NO. 97-6837 CIVIL TERM
.
.
MARK W. RUMMEL,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
CRDBR OF COORT
AND tnt, this till- day of W~
consideration of the attached CUstody Conciliation Report,
and directed as follows:
, 2001, upon
it is ordered
1. The prior Order of this Court dated october 23, 2000 is vacated
and replaced with this order.
2. The Mother, Christine L. Sheriff, and the Father, Mark W. RUllUlIel,
shall have shared legal custody of Christian T. Sheriff, born May 14, 1997.
Each parent shall have an equal right, to be e:~ercised jointly with the
other parent, to make all major non-emergency decisions affecting the
Child's general well-being including, but not limited to, all decisions
regarding his health, education and religion.
3. The Mother shall have primary fX1ysical custody of the Child.
4. The Father shall have partial physical custody of the Child every
Tuesday from 5:30 p.m. until 8:30 p.m., beginning I'ebruary 20, 2001, and on
alternating weekends from Friday at 5:30 p.m. through Saturday at 5:30
p.m., beginning March 2, 2001. The Father may also have custody at any
additional times as arranged by agreement of the p<irties.
5. The parties shall share or alternate having custody on holidays as
follows:
A. CBRISTHAS: In every year, the FathE!r shall have custody of
the Child from Christmas Eve at 5:30 p.m. through Christmas
Day at 9:00 a.m. and the Mother fmall have custody from
Christmas Day at 9:00 a.m. through December 26 at 5:30 p.m.
B. NEW YEARS: In every year, the Mothe,r shall have custody of
the Child on New Years Day from 9:00 a.m. until 3:00 p.m. and
the Father shall have custody from 3:00 p.m. until 8:30 p.m.
c. 'l'BANKSGIVING: In every year, the Fath,er shall have custody of
the Child on Thanksgiving Day from 9:00 a.m. until 3:00 p.m.
and the Mother shall have custody on Thanksgiving Day
beginning at 3:00 p.m.
D. IV.1'tfJSK' S DAY/FATHER' S DAY: In eVE!ry year, the Mother shall
have custody on Mother's Day and thE' Father shall have custody
of the Child on Father's Day frem 9:00 a.m. until 4:00 p.m.
E. IV.1'tfJSK'S BIRTIlD1lY/FATHER'S BIRTfIDA~l: me Mother shall have
custody of the Child every year or, her birthday (January 9)
frem 5:30 p.m. until 8:30 p.m. and the Father shall have
custody of the Child every year on the Father's birthday (June
26) frem 5:30 p.m. until 8:30 p.m. In the event the Mother's
period of birthday custody falls on the Father's regular
period of partial custody, the parties shall schedule a
make-up period of custody for the Father by agreement.
F. CHILD'S BIRTBDAY: In even numbered years, the Father shall
have a period of custody on the Child's birthday (May 14) from
5:30 p.m. until 8:30 p.m. and in odd numbered years, the
Mother shall have a period of custcldy with the Child on the
Child's birthday from 5:30 p.m. until. 8:30 p.m.
G. me holiday custody schedule shi!ll supersede and take
precedence over the regular custody schedule.
6. The Mother shall be entitled to have custody of the Child for 1
uninterrupted week. each year upon providing al: least 30 days advance
written notice to the Father. The Mother's peri.od of custody under this
provision in 2001 shall run frem May 12 through May 20. When the Mother's
period of extended custody under this provision is scheduled during the
Father's regular weekend period of custody, the F,ather shall have a makeup
period of weekend custody during the weekend immediately preceding the
Mother's selected period of custody.
During the surrmer 2001, the Father shall have 3 periods of
extended custody with the Child which shall run fl~em Thursday at 5:30 p.m.
through Sunday at 5:30 p.m. upon providing 30 days advance written notice
to the Mother. The Father shall schedule his periods of custody under this
provision to coincide with his regular weekend periodS of custody.
SUllIIler custody arrangements for sumner 2002 and continuing
thereafter shall be arranged by agreement of the pa.rties.
7. The Father shall be responsible for providing transportation for
all exchanges of custody, unless otherwise agre.Kj between the parties.
Also unless otherwise agreed, the parties shall ,exchange custody at the
corner of North pitt Street and C Street in Carlisle. The Mother shall
ensure that the maternal grandparents remain in their residence during all
exchanges of custody. The Father shall notify thE! Mother in the event he
will be more than 15 minutes late for an exchange of custody.
8. Both parties shall ensure that the Child is transported in a car
seat at all times. During exchanges of custody, the Father shall be
responsible to put the Child in and out of the car seat in the Father's
car.
9. Neither party shall do or say anything which may estrange the
Child from the other parent, injure the op1.m.on of the Child as to the
other parent, or hamper the free and natural developnent of the Child's
love and respect for the other parent. Both parties shall ensure that
third parties having contact with the Child comply with this provision.
10. 'lhis order is entered pursuant to an agreement of the parties at a
CUstody Conciliation Conference. The parties ma:y modify the provisions of
this order by llRltual consent. In the absence of llRltual consent, the terms
of this order shall control.
/
~
(I~.\pf\-O\
~ ^ 9,J--1
o \2-'{r
Edgar B. Ba}~ey,
J.
cc: Jacqueline M. Verney, Esquire - Counsel for M,:>ther
Johnna J. Kopecky, Esquire - Counsel for Fath,er
r'
~ r! .
"/
\/{
C. ./
\- ' (~
"<""
~<,.::(o
'I,
"'~;/;~
,"
, '
, c-~.
;,;-
"<.y,..
/,....
C"
'-"/
"J,)
'L
CHRISTINE L. SHERIFF, : IN THE COURT OF o:JMMON PLEAS OF
Plaintiff . CUMBERLAND C<XlNTY, PENNSYLVANIA
.
:
vs. . NO. 97-6837 CIVIL TERM
.
:
MARK W. RUMMEL, : CIVIL ACTION - LAW
Defendant : IN CUSTODY
PRIm JUDGE: Edgar B. Bayley
CUST<DY <niCILIATIal &NARY REPCRT
IN ACXXRDANCE WITH CDmERLAND <XUI'l'Y RULE OF CIVIL PROCEOORE
1915.3-8, the undersigned CUstody Conciliator sutKnits the following report:
1. The pertinent information concerning thEl Child who is the subject
of this litigation is as follows:
NAME
Drd'E OF BIRTH
aJRRml'Ly IN CUST<DY OF
Christian T. Sheriff
May 14, 1997
Mother
2. A CUstody Conciliation Conference was he,ld on February 20, 2001,
wi th the following individuals in attendance: The Mother, Christine L.
Sheriff, with her counsel, Jacqueline M. Verney, Esquire, and the Father,
Mark W. RUltIl\el, with his counsel, Johnna J. Kopecky, Esquire.
3. 'lhe parties agreed to entry of an order in the form as attached.
~~dl. ,-MJf
Date '
IU<~~O/?J
Dawn S. Sunday, Esquire
CUstody Conciliator
CHRISTINE L. SHERIFF,
PlaintifflRespondent
: TIffi COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: No. 97-6837 CIVIL TERM
MARK W RUMMEL,
DefendantPetitioner
: CIVIL ACTION - AT LAW
: CUSTODY
ORDER OJ( COITR1:
AND NOW, this
day of
,2001, upon
consideration of the attached complaint, it is hereby directed that the parties and their respective
counsel appear before
" conciliator, at
on the
day of
,2001, at _ o'clock _: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 hellrd 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 TIffi COURT:
BY:
Custody Conciliator
.
CHRISTINE L. SHERIFF,
PIaintift7Respondent
: THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: No. 97-6837 CIVIL TERM
MARK W. RUMMEL,
DefendantPetitioner
: CIVILACTION-ATLAW
: CUSTODY
PETITION FOR MOnOOCATION.flE..A
PARTIAl, C'lTSTODV OR VTSITA TI01IJ ORnER
AND NOW COMES the Petitioner, Mark W. Rumme~ by lUld through his attorney, Jeanne B.
Costopoulos, Esquire, and files the following petition, respectfully n:presenting as follows:
1. The petition of Mark W. Rummel respectfu1ly represents that on February 27, 2001, an
Order of Court was entered for partial custody/visitation, a true and I~orrect copy of which is attached
as Exhibit A.
2. This Order should be modified because:
( a) Petitioner is the natural father of the child.
(b) Petitioner has established a relationship with the child.
( c) Petitioner desires to continue exercising parental duties and enjoys the love and
affection of the child.
(d) The child should be pennitted to enjoy the love, affection, and emotional
support which can be provided by his natural firther.
(e) The child would benefit from continued custody with his natural father.
CHRISTINEL. SHERIFF,
Plaintifi7R.espondent
: THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: No. 97-6837 crVIL TERM
MARK W RUMMEL,
DefendantPetitioner
: CIVIL ACTION - AT LAW
: CUSTODY
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 infonnation about l\C(lessible facilities and reasonable
accommodations available to disabled individuals having business bc~fore the court, please contact our
office. AU 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.
BY THE COURT:
Date
J.
(f) Petitioner believes, and therefore avers, that Respondent has not been acting in the best
interests of the child in that:
(1) Respondent often arrives late for the drop off of child during
Petitioner's periods of partial custody;
(2) Respondent is attempting to alienat<e the child by making disparaging
remarks about Petitioner; and
(3) Respondent refuses to provide Petitioner with child's Social Security
Number, medical information, etc.
WHEREFORE, Petitioner requests that the Court modifY the existing Order for partial
custodylvisitation, granting primary custody of Christian T. Sheriff to Petitioner, because it will be in
the best interest of the child.
Respectfully submitted,
Date:
q/;/ZM!
ht _______
~stopoulos, Esquire
ATTORNEY FOR PETlTIONER
1400N. Second Street
Harrisburg, PA 17102
(717) 221-0900
Supreme Ct. ID No. 68735
CHRISTINEL. SHERlFF,
Plaintifr7Respondent
: THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: No. 97-6837 CIVIL TERM
MARK W. RUMMEL,
DefendantPetitioner
: CIVIL ACTION - AT LAW
: CUSTODY
VF.RTFlr.A nON
I, Mark W. Rummel, hereby verity that the statements made in the foregoing Petition for
Modification of a Partial Custody or Visitation Order 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: y0"~{
S"",,",o #iF~<
,c'
....-:>
C3RISC::;::", L. SHERIFF,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND CCONTY, PENNSYL VANLA.
:
vs.
NO. 97-5837
CIVIL TER'1
t'I."RK W. RUMMEL 1
Defendant
CIVIL ACTION - LAW
IN CUSTODY
CRDER OF a:xJRT
. _ AND OCW, this 27 ~t day of &b,1J Q_I l! .
c;onS~G,,!:"a1:~on of w,e aeead,'C{J Cuseex'! Conc~llatlorl "eJ~'
~~d directed as follows:
1 20011 u90n
it is ordered
1. The prior Order of this Court dated O:otober 23, 2000 is vacated
fu~d r2?laced with this Order.
,
2~ The Mother, Christine L. Sheriff, and tJ1E~ Father, Mark Ii;. Rw:-:r:el,
shall ha<,,-e shared legal custody of Christian T. Sheriff, born May 141 1997.
Ec.c.l-:1 parent shall have an equal right, tc Ce eXE::-cised jointly w-it.."i t.h.e
ot.'1er ;<,rentl to make all major non-emergency decisions affecting the
C./--tild's general h~ell-being i.nclucin;- ( But not limitec co, all decisions
regardin~ his health, education and religion.
3.. The Mother shall ha.ve prj..mar-)" ?hysic2.1 C";.1stGdy :::f t.,e C~ilc..
4.. The Father shall have par-t:i21 'physical custody of the Child every
T~esday =~cm 5:30 p.m. until 8:30 p.w., begiTh~in~ ?e~ru2ry_20, 2001, ~d on
al;:ernadn:;, weekends from Friday at 5:30 I?m. thl:ough Saturday at 5:30
f).IT'.1 Oe:;,inning March 2, 2001. The Father may also have custody at any
a.ccitiona2. times as arrangeC by agreement of tIle parties.
.").
~71e
,98-r-::ies
-
Sh2J..l sh2!:"e o!:" ~ 1 t.err:3te" h27i~,s
C'..1st:)~:/
'-,.....1'; ,.::;......~
.......--.....'-'-.!->
:..5
=G..!...:.:::)"wS:
A. CE:RIS'll'1AS: In every yea=-, the Fatne!:" shall have custody v'':'
the c..~ild frcrn Christme.s Eve at 5:30 p..m. through Christ.l12..S
Day at 9:00 a..iT.. and ':...~e :"1:;ither she.Ll have CUST:cCY f:-:Jm
Chris~"7ias D=.y a't :;':00 2.IT'.. ~hrou9'h Decerrber 26 2.t 5:30 ~..rr:.
::.. N:Elil YEARS: ~~ -eV'2:-Y ye=.::" the t'1oth~!:" :=:;n2.11 ;'12Ve C'..1stxy 0:
the Child C[1 New' Years Day iran 9:00 a..m.. t.:L."1til 3:00 ?m. 2Jl-j
t.'r1e Father s.~all have Cl.lStXY from 3:00 ?m.. l1.'ltil .8: 38 p.m.
~
~-
THANKSGIVING: In ever)" year, t.'1e Fat..~e!:"
the Child on Thanksgivin~ Day frcrr. 9:00
and t.he f<lomer shall have eustoey
j)egi~~in; at 3:00 p.lli.
shall have ces~8dy of
a.m.. wntil 3:CC'
cn Thanksgivin;I2y
D.
MOTHER I S DAY/FATflER' S DAY:
have c:.:.s:ody on Mother-' s Day
ot 1::'1e ::::-Jild on Father-' s Day
In every year-, the Mother- shall
and the Father shall have custoOv-
fr-om 9:00 a.m. until 4:00 p.m. .
E. MOTHER'S BIRTHDAY/FATHER'S BIRTHDAY:: The Mother shall have
custody of the Child every year- on her- birthday (January 9)
fr-om 5:3J p.m. until 8:30 p.m. and the Father- shall have
custody of the Child every year on th.e Father I s birthday (June
26) fr-om 5:30 p.m. until 8:30 p.m. In the event the Mother-'s
pedod ~_ bir-J1day custody falls on the E'ather I s regula:-
period of partial custody, the parties shall schedule "-
make-uO' ;;er-iod of custody for- the Father by agr-eement.
F. CIITI.D'S BIRTHDAY: In even numbered year-s, the Pather- shall
have a ?eriod of cus~ on the Child's birthday (May 14) from
5:30 p.::.;. until 8:30 p..in. and in cx3d numbered years, t:.ne.
Mother shall have a period of custody with the Child on' the
Child's jirthday fr-om 5:30 p.m. ~~til 8:30 p.m.
G_ The holiday custody schedule shall supersede and take
precedence over- the r-egular custody sd1edule.
6. The Mother s.~>all be entitled to have custody of the Child for l
uninterruj?ted week each year upon pr-oviding at least 30 days advance
written notice to 1:.'1e Father. The Mother's period of custody under- 1:.'lis
provision in 2001 shell run from May 2.2 t.."1rough May 20.. Whe.rl th~ .!'j.:)th2:" f ~
period of extended c.:.s;:ody under- this provision is scheduled during 1:.'1e
Father's regular weekand period of custody, the Patner- shall have a makeup
per-iod of weekend ct:stody during the wee.l(:end immediately pr-eceding 1:.'1e
Mother1s selected period of custody.
During ehe S'.::rrner 2001, the Father shall have 3 !;l8riods 0:
exeanaec custody "ieh ::.'1e Child which shall run frcm Thursday at 5:30 j?m.
ch~ough sunday at 5:30 ".m. u;:>on providing 30 days advance written notice
~~ L~e Mo~'e~_ The ==~~er shall schedule his periods of cu~tody under t~lS
.?;:":)vision to coincide ~~-ith his regular weekend p:riods or custody.
SUl1iner-
~h~~e=ft2~ s~all
c~stoCy~ a=rangements for
be ~2ngec by agreement of
summer 2002
tile ?=3-rties..
eDO
cont:~n:..ll.::.q
, . ?he ?at~'le= ~~;::'1 be responsible for: l?!:"ovidi.ng transpc:lrtaticn :::~
cl2. excha,.:.ges of cus~:;cy( unless other-wise agreed between the pc.rties.
;.~so unless othervdse agreec, the parties shall excjange custody at the
CQr:ne~ of Nc:-::h ?itt S'::-?2t and C st~eet ir: C2rlisle. The Mother shall
enstJ.!:'e th2:: ':.:'12 IT:e.:.e::::=l gr2.nC?2rents :-emain in thei':" residence during =.1':'
-=xc'.h2.I1?-=s :::=
-.------
-....----..
:~;':;; ?=.':...~''1e:c Sh22.2.
:lo::ify -:"'"1e :<:)Lhe~ i::1 "U~e event :-.-:=
'",-ill be rr:.:J~e than ~5 ::::.:-::..::e5 l=-t~ :2::' 2.."": exchange of ::'.lstOdy.
s. ~,::=h ;?=::L:ies :::'2.11 S""lS~e t.'1at the C.h.ild is transported in a C2.'"'
S2at: a::: 2..11 -cimes. ::.:.:-in; exch2l1ges c:: cUSt.OCYl (:.~e Fa-the.:- shall ::s
=esponsible to pu-: t..:'-le 2:'1il:5 in a1'1C out of t..i1e ca~ seat in -t.~e Father 1 s
ca.!."".
~~ei t.~e::-
:;2:;-:-.-
~-:::: r ;
,..;;-, O~
S2~/
any'-~.hi!1g
,,;;-uco-'1 r;-",y
est:!:'ange
.;
Child from the other parent, wJure the opwwn of the Child as ::0 the
other parent,. ox:: hamper the free anC natural development of the C.'1ild 's
love and respect for: the other par-e:".::. Both parties shall ens!:::e that
third parties having contact with the Child comply with this provision.
10. This Order is entered pul:"suant to an agr,aement of the parties at a
custody Conciliation Conference. The parties may modify the pl:"ovisions of
this Ordel:" by mutual consent. In .the absence of mutual consent, the tenns
of this Order shall control.
BY THE O::URT,
N&{JfnL i! An!/'
Edgac. . Bayley, J.
cc: Jacqueline M. Verney, Esquire - Counsel for Mother
Johnna J. Kopecky, Esquire - Counsel for Father
:,,:,:".
<'
~ -
~ 0'-,
t \:j
,
~. ~
~
'\
-- ~
C'
~ ~
v
CJ
Q
~; :~,~
-ocr; '-'tJ
~~;';i} I
Z\'l'~ ._.i
<:::2>.
!cu
~8.
~c:
:z
~
"5
::~I
-0
::x
r;-?
.'.1"1
r.v
..~;
()
--,::on
"
~
~
-
CHRISTINE L. SHERIFF
PLAINTIFF
V.
MARK W. RUMMEL
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
97-6837 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW,
Thursday, September 13, 2001
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before' Dawn S. Sunday, Esq.
at 39 West Main Street, Mechanicsburg, PA 17055 on Wedn',"day, October 10, 2001
, the conciliator,
at 10:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
ifthis 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.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/
Dawn S. Sund"y. Esq.~.^
,.
Custody Conclliator
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 THIS 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
~.$-- ~ ~ ~
~ $.. -;? "" '"''
~ 1i!-:2;2 ~ ~ "<:>1'/,.
- .~,> iZ- ~ ~ h /C'u-t!
JJ.Nrit.JlIQ~~~~i!~no
1l"J :l Hd S I d3S 10
At!V1C:<'v'if>~-'>"j:::_li.:1
::(}j'r,',}"^,_J...;,.
, :;()
-
CHRISTINE L. SHERIFF,
Plaintiff,
v.
MARK W. RUMMEL,
Defendant,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL V ANlA
: NO. 97-6837
CIVIL TERM
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this day of , 2001, 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 , 200 1 ,
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. All
children age five or older may also be present at the con~erence. Failure to appear at the
conference may provide grounds for entry of a temporary or permanent order.
^
~'~;.'
BY THE COURT:
By:
Custody Conciliator
Cumberland County is required by law to comply with
;Il Act of 1990, For information about accessible facilities
. available to disabled individuals having business before
All arrangements must be made at least 72 hours
before the court, You must attend the scheduled
THIS PAPER TO YOUR LAWYER AT ONCE. IF
OR CANNOT AFFORD ONE, GO TO OR
FORTH BELOW TO FIND OUT WHERE YOU
lND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
CHRISTINE L. SHERIFF,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 97-6837
CIVIL TERM
MARK W. RUMMEL,
Defendant,
: CIVIL ACTION - LAW
: IN CUSTODY
PETITION FOR MODIFICATION OF PARTIAL
CUSTODY OR VISIT A TION ORDER
The Petitioner, Christine L. Sheriff, respectfully represents that on February 27,
2001 an Order of Court was entered for Partial Physical Custody and Visitation, a true and
correct copy of which is attached.
1. This Order should be modified because:
a. The existing holiday schedule does not adequately distribute custody
between the parents. Specifically, the existing Order prevents the mother
from ever having a Christmas morning with the Child or a mid-day
Thanksgiving dinner with the Child.
b. The parties are unable to reach agreement on makeup periods of custody
following Christine's birthday as envisioned in paragraph five E (5E).
The existing schedule does not have suflkient flexibility in the individuals
that are specifically authorized to pick up or drop off Christian to allow
for the routine schedule changes of normalliving.
c. The existing Order requires that the maternal grandparents remain in
the residence during all exchanges of custody. This provision was a petty
restriction that has no basis in the conduct of the grand parents or in
benefit to the Child.
d. The existing Custody Order does not contain sufficient restrictions for
unrelated third parties who are currently verbally assailing and
disparaging the mother at the scene of the custody transfer.
2. The Petitioner/mother, Christine Sheriff, respectfully requests that paragraphs
two, three and four of the Order dated February 27,2001 r,emain unchanged. Petitioner
seeks modifications and/or additions to paragraphs five through nine of the aforesaid order:
a. Thanksgiving: Each parent will alternate custody from 8 a.m.
Thanksgiving morning until 8 p.m. Thanksgiving evening every other
year.
b. Christmas: Each parent will have alternating periods of custody on
Christmas Eve and Christmas, on an every other year basis.
Alternatively, the father may have custody on Christmas Eve from 8 a.m.
until 8 p.m. every year if this arrangement is preferable to alternating
years of Christmas Eve/Christmas custody.
c. The parents will alternate New Years Ev~:/New Years custody every
other year with the custody period being from 5:30 p.m. New Years Eve
until5:30 p.m. New Years Day.
d. Mothers birthday: Everything from paragraph five E (5E) from the
February 27,2001 Order would be incorporated in its entirety with the
exception of the last clause which reads "the parties shall schedule a
makeup period of custody for the father by agreement." This clause
should be replaced with the clause, "iffor any reason the mother's
birthday should fall on a day that would normally be the father's partial
custody period, the father's partial custody would automatically be
scheduled for the following day.
e. In the event either parent is unable to deliver Christian to the pickup or
drop-off destination, such parent will notify the other parent as soon as
possible as to the change in person dropping off or picking up Christian.
Such alternate individuals for drop off or pickup will be limited to (I)
relatives of either parent or (2) any third party individuals that are
mutually agreeable to both parents.
f No restrictions on presence or participation of either matemal or paternal
grandparents with regard to drop offs, pickups, visitation or performing
as alternates in the event that a parent is unable to be present at the
required time.
g. Third parties that are unrelated to either parent, new spouses of either
parent, new girl friends, or boyfriends of ~~ither parent are required to
remain inside their respective vehicles and remain silent throughout the
custody transfer, unless the third party is preapproved as acceptable
transfer alternate by both parents.
WHEREFORE, Petitioner, Christine L. Sheriff, resp~~ctfully requests that this
Honorable Court maintain the status quo regarding primary custody and modify the existing
Custody Order as indicated above because it will be in the best interest of the Child.
Law Office of James K. Jones
~~~
-
Dirk E. Berry, Esquire
Attorney for Petitioner
7 Irvine Row
Carlisle, P A 17013
(717) 240-0296
----------
VERIFICA nON STATEMENT
I verify the statements made in this Petition are true and correct, to the best of my
knowledge and belief I understand that false statements herein are made subject to
'.
penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities.
--':)pe ),:,},c;h^?J
Dae
~~~~f~~
CHRISTINE L. SHERIFF,
Plaintifl7Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 97-6837
CIVIL TERM
MARK W. RUMMEL, : CIVIL ACTION - LAW
DefendantJRespondent : IN CUSTODY
CERTIFICA TE OF SERVICE
I, Dirk E. Berry, Esquire, do hereby certifY that on this day I served the Petition for
Civil Contempt for Disobedience of Partial Custody Order by first-class mail, postage pre-
paid, upon the following persons:
Jeanne Costopoulos
1400 N. Second Street
Harrisburg, PA 17102
The Law Office of James K. Jones, Esquire
Date:
r- /J-O/
/f;-/ ~?
--LSi27 ../
Dirk E. Berry, Esquire
Attorney for Petitioner
7 Irvine Row
Carlisle, PA 17013
(717) 240-0296
.../
-
(') C'
~:; ~()
~ -U~'-' ,-"
-J<:::::, ~. Q;i, '"0
it ~S'-
, v"
~ ~ ~L. r'C)
- ~c: ~
- B ~ :;;;\.... c- ,l'i",
"" ~ c:: ':,-~
:z ..:,.,.
.,..l. ~ ~:o
0<) (J1 -<
~
'"\
--2
CHRISTINE L. SHERlFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNfY, PENNSYLVANIA
PLAINTIFF
V.
MARK W. RUMMEL
DEFENDANT
97-6837 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW,
Tuesday, September 18, 2001
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective cOlUlsel appear before Dawn S. Sunday, Esq.
at 39 West Maiu Street, Mechanicsburg, PA 17055 on Thur:iday, October 18, 2001
. the conciliator,
at 10:30 a.m.
for a Pre-Hearing Custody Conference. At such conference, an effort wi1l 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 grolUlds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all exisling Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours ~lfior to scheduled hearing.
FOR THE COURT.
By: Isl
Dawn S. Sund,ty. Esq.tJ/?
Custody Conc iliator
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 THIS 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 COlUlty Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
47~-?!j ~ ~ /~.oC'&
-fr ~ ~ p ~ 17::H( ~~ /{J'Qc>-IJ
i:;f P ~~~ -T9 /(/'-01:'0
_, \iIN\iI\lAS~~N3d
All\inO~) n\I:\:'I:..r~,:1:Mn'~
. ,."1,/,,,...)
oz:(; ['.r.l Ii)"'" 'r'
" .,1 Lf CL:lv I ,~
!.U1iU.:: i'
CHRISTINE L. SHERIFF,
PlaintifVpetitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 97-6837
CIVIL TERM
MARK W. RUMMEL, : CIVIL ACTION - LAW
DefendantlRespondent : IN CUSTODY
NOTICE AND ORDER TO APPEAR
Legal proceedings have been brought against you alleging you have willfully
disobeyed an order of court for partial custody.
If you wish to defend against the claim set forth in the following pages, you may but
are not required to file in writing with the court your defens{\s or objections.
Whether or not you filed in writing with the court your defenses, or objections, you
must appear in person in court on ,2001, at
.m. in Courtroom , of the Cumberland county Courthouse, High and
Hanover Streets, Carlisle, Pennsylvania.
IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT
FOR YOUR ARREST.
If the court finds that you have willfully failed to comply with its order for partial
custody, you may be found in contempt of court and committled to jail, fined or both.
YOU SHOULD TAKE TIDS 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 LffiERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
BY THE COURT:
J.
CHRISTINE L. SHERIFF,
PlaintifflPetitioner
: IN THE COURT Of COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-6837
CIVIL TERM
MARK W. RUMMEL, : CIVIL ACTION - LAW
DefendantlRespondent : IN CUSTODY
PETITION FOR CIVII, CONTEMPT FOR
DISOBEDIENCE OF PARTIAL CUSTODY ORDER
AND NOW comes Christine L. Sheriff, by and through her counsel, Dirk E. Berry,
Esquire, respectfully avers as follows:
1. That on February 27,2001, the Honorable Edgar B. Bayley, Judge, entered an
Order awarding Petitioner Primary Physical Custody of ChriS1lian T. Sheriff, date of birth
May 14, 1997, with the Respondent having Partial Physical Custody every Tuesday from
5:30 p.m. until 8:30 p.m. and on alternating weekends from Friday at 5:30 p.m. through
Saturday at 5:30 p.m. Additionally, the parties had agreed to various custody arrangements
that varied by holiday.
2. Paragraph nine (9) of the aforesaid order states, "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 ensure that third parties having contact with
the Child comply with this provision" .
3. During the recent custody transfers, father's new girlfriend, whose name, upon
information and belief, may be Campbell, has exited father's vehicle and verbally assailed
and disparaged Petitioner in front of Christian. The father, Mark Rummel, appears to have
made no attempt to stop or discourage his girlfriend from verbally abusing and disparaging
Christine Sheriff during these custody transfers.
4. Accordingly, the father has failed to insure that third parties having contact with
the Child comply with the provisions of the February 27, 2001 order as set forth in
paragraph two (2) above.
WHEREFORE, Petitioner respectfully requests this Honorable Court to hold the
Respondent in Contempt of Court for violation of the February 27, 2001 Order.
~-:5
Di E. Berry, Esquire
Attorney for P~:titioner
7 Irvine Row
Carlisle, PA 17013
(717) 240-0296
VERIFICA nON STATEMENT
I verifY the statements made in this Petition are true: and correct, to the best of my
knowledge and belief I understand that false statements h(~rein are made subject to
penalties of 18 Pa. C.S. ~ 4904 relating to unswom falsification to authorities.
V / c9, c9()(, J
Dat
~~~1.~,Sfr~
. stine L. Sheri
CHRISTINE L. SHERIFF,
Plaintif.llpetitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 97-6837
CIVIL TERM
MARK W. RUMMEL, : CIVIL ACTION - LAW
Defendant/Respondent : IN CUSTODY
CERTIFICATE OF SERVICE
I, Dirk E. Berry, Esquire, do hereby certifY that on this day I served the Petition for
Civil Contempt for Disobedience of Partial Custody Order by first-class mail, postage pre-
paid, upon the following persons:
Jeanne Costopoulos
1400 N. Second Street
Harrisburg, P A 171 02
The Law Office of James K. Jones, Esquire
Date:
q-13 -01
~&?~
--::::::.
Attorney for Petitioner
7 Irvine Row
Carlisle, P A 17013
(717) 240-0296
~
-
;;;:-
..,.\:j
c<>
<0
9-~
~ ~
~........-.=>
~ ~
~ f\
~
o
C
-E
~)'r:'::
\1'\\ "
2.
~'(
')":>' C"
&C)
-;Y'C
_.~
~
::2.
<;:)
ef)
-"
.u
<.-,":'
-':.'J
.,
..,......
<:.
-.
,1\
CHRISTINE L. SHERIFF,
Plaintifflpetitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 97-6837
CIVIL TERM
MARK W. RUMMEL, : CIVIL ACTION - LAW
DefendantlRespondent : IN CUSTODY
TO THE PROTHONOTARY
WITHDRAW OF CONTEMPT P1ETITION
Please withdraw Plaintifflpetitioner, Christine L. Sheriffs PETITION FOR CIVIL
CONTEMPT FOR DISOBEDIENCE OF PARTIAL CUSTODY ORDER, filed September
13, 2001, in the above captioned matter, pursuant to the agreement reached at the
conciliation conference, held before Dawn Sunday, Esquire, on October 10, 2001.
A:1~?
--
-
Dirk E. Berry, Esquire
Attorney for Plaintiff
7 Irvine Row
Carlisle, PA 17013
(717) 240-0296
~ 0 0
"n
0
~OJ n nn
& -I ,=
<'f,Tr
U1 :"il.::J
~"'; ~;<)
~-
;;:::0 "'" ~-- 'j r
~O :!i: ;;:2;
)>0 - ~'-n.1
- C)
~ w 1>!
.s::- ~
CHRISTINE L. SHERIFF
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
97-6837
CIVIL ACTION LAW
MARK W. RUMMEL
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this .-LJ- day of ('?~ ' 2001, upon
consideration ofthe attached Custody Conciliation Report, it is ordered and directed as follows:
Order.
1. The prior Order of this Court dated February 27, 2001 is vacated and replaced with this
2. The parties shall promptly initiate counseling for the Child with a professional selected by
agreement of the parties. The purpose of the counseling shall be to evaluate the Child's adjustment to
the custody situation focusing on the parents' respective allegations of alienation of the Child's
affections and also to obtain recommendations concerning the Child's best interests. All costs of
counseling which are not reimbursed by insurance coverage shall be shared equally between the
parties. Both parties shall ensure that there are no third parties present at the time of the counseling
sessions unless specifically requested by the counselor. The parties shall follow the recommendations
of the counselor with respect to either or both parties participation in counseling and also any
recommendations issued by the counselor concerning the promotion of the Child's best interests.
3. The Mother, Christine L. Sheriff, and the Father, Mark W. Rummel, shall have shared legal
custody of Christian T. Sheriff, born May 14, 1997. Each parent shall have an equal right, to be
exercised jointly with the other parent, to make all major non-emergency decisions affecting the
Child's general well-being including, but not limited to, all decisions regarding his health, education
and religion. The parties shall cooperate in sharing all information pertaining to the Child and shall
communicate directly with regard to issues conceming the Child.
4. The Mother shall have primary physical custody of the Child.
5. The Father shall have partial physical custody of the Child on altemating weekends from
Friday at 6:00 p.m. through Sunday at 6:30 p.m., beginning October 12, 2001. In addition, the Father
shall have custody every Tuesday from 6:00 p.m. until 8:30 p.m. The Father may also have custody at
any additional times as arranged by agreement ofthe parties.
6. The parties shall share or alternate having custody of the Child on holidays as follows:
A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which
shall run from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and
Segment B, which shall run from Christmas Day at 12:00 noon through December 26 at
12:00 noon. The Father shall have custody of the Child during Segment A in odd
numbered years and during Segment B in even numbered years. The Mother shall have
custody of the Child during Segment A in even numbered years and during Segment B
in odd numbered years.
B. THANKSGIVING: In odd numbered years, the Father shall have custody of the
Child on Thanksgiving Day from 8:00 a.m. until 9:00 p.m. and in even numbered years,
the Mother shall have custody of the Child on Thanksgiving Day from 8:00 a.m. until
9:00 p.m.
C. NEW YEARS: The New Years holiday shall run from New Years Eve at 5:30 p.m.
through New Years Day at 5:30 p.m. The Mother shall have custody of the Child over
the New Years holiday in odd numbered years and Ihe Father shall have custody in even
numbered years. For purposes of this provision, the entire New Years holiday shall be
deemed to fall in the same year as New Years Eve.
D. MOTHER'S DAY/FATHER'S DAY: In every year, the Mother shall have
custody of the Child on Mother's Day from 9:00 a.m. until 8:00 p.m. and the Father
shall have custody on Father's Day from 9:00 a.m. until 8:00 p.m.
E. MOTHER'S BIRTHDAY/FATHER'S BIRTHDAY: The Mother shall have
custody of the Child every year on her birthday (January 9) from 5:30 p.m. until 8:30
p.m. and the Father shall have custody of the Child (:very year on his birthday (June 26)
from 5:30 p.m. until 8:30 p.m. In the event the Mother's period of birthday custody
falls on the Father's regular period of partial custody on Tuesday, the Father's custody
period shall automatically be rescheduled to the following Wednesday. In the event the
Mother's period of birthday custody falls on the Father's regularly scheduled weekend
period of custody, the Mother shall have custody of the Child for the entire weekend
and the Father's weekend shall be rescheduled to th,e immediately following weekend.
The alternating weekend schedule shall continue thereafter unaffected by the adjustment
which will result in each party having two consecutive weekend periods of custody.
F. CHILD'S BIRTHDAY: In even numbered years, the Father shall have a period of
custody on the Child's birthday (May 14) from 5:30 p.m. until 8:30 p.m. and in odd
numbered years, the Mother shall have a period of custody with the Child on the Child's
birthday from 5:30 p.m. until 8:30 p.m.
G. In the event any period of holiday or birthday custody falls on a weekday and is
scheduled to begin at 5:30 p.m., the beginning time for the period of custody shall be
adjusted to 6:00 p.m.
H. The holiday custody schedule shall superse<k and take precedence over the regular
custody schedule.
7. Unless otherwise agreed between the parties, all custody exchanges shall take place inside
the building of the Carlisle Police Department. Both parties shall ensure that there are no third parties
present during the exchanges of custody. The parties shall conduct all exchanges of custody in a
cooperative and civil manner in order to promote the best int~:rests of the Child. Each party shall
notify the other party in the event he or she will be more than 15 minutes late for an exchange of
custody.
8. Both parties shall abide by all laws regarding appropriate child restraint in motor vehicles.
9. The Mother shall be entitled to have custody of the Child for one uninterrupted week each
year upon providing at least 30 days advance written notice to the Father. When the Mother's period
of extended custody under this provision is scheduled during th(: Father's regular weekend period of
custody, the Father shall have a make-up period of weekend custody during the weekend immediately
preceding the Mother's selected period of custody. The Father shall have extended periods of custody
with the Child during the summer each year with the specific arrangements to be established by
agreement of the parties.
10. In the event either party intends to remove the Child from Pennsylvania for an overnight
period or longer, that party shall provide advance written notice to the other party of the address and
telephone number where the Child can be contacted.
11. 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 ensure that third parties having contact
with the Child comply with this provision.
12. 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 in writing by mutual consent. In the
absence of mutual consent, the terms of this Order shall control.
'.../'
J.
Edgar B. Bayley,
cc: Dirk E. Berry, Esquire - Counsel for Mother \
Jeanne B. Costopoulos, Esquire - Counsel for Father ~,~ / \:J..;J. "J-o/
Cf-.
~
~-
t.__,',
,';Os"
\)..-~t)
Lo'~ ,.,
\';..,-,
~
C-~ ~4
(f'; OD%t.
;;;-. -/)
< {'),.y,..,
',c'- '!"'".%:
cY '~~t.-
'-'. 'l;:\~
"~ \<~~
l('"'"" '"~
o ~
-c;
'"'\
C;'>
,-."
\:)
CHRISTINE L. SHERIFF
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
vs.
97-6837
CNIL ACTION LAW
MARK W. RUMMEL,
Defendant
IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Christian T. Sheriff
May 14, 1997
Mother
2. A Custody Conciliation Conference was held on October 10, 2001, with the following
individuals in attendance: The Mother, Christine L. Sheriff, with her counsel, Dirk E. Berry, Esquire,
and the Father, Mark W. Rummel, with his counsel, Jeanne B. Costopoulos, Esquire.
3. The parties agreed to entry of an Order in the form as attached. The parties agreed at the
Conference that all issues raised in each party's Petition for Modification and the Mother's Petition for
Contempt were resolved.
{)c h fxA
} &, ;}-ao /
rOJ~~
Dawn S. Sunday, EsqUIre
Custody Conciliator
Date
NOV 0 2 2001 J~
CHRISTINE L. SHERIFF,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
97-6837
CNIL ACTION LAW
MARK. W. RUMMEL,
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this S~ day of U~ ,2001,
upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Orders of this Court dated February 27, 2001 and October 22, 2001 are vacated
and replaced with this Order.
2. The parties shall promptly initiate counseling for the Child with a professional selected by
agreement of the parties. The purpose of the counseling shall be to evaluate the Child's adjustment to
the custody situation focusing on the parents' respective alle:gations of alienation of the Child's
affections and also to obtain recommendations concerning the Child's best interests. All costs of
counseling which are not reimbursed by insurance coverage shall be shared equally between the
parties. Both parties shall ensure that there are no third parties present at the time of the counseling
sessions unless specifically requested by the counselor.
3. The Mother, Christine L. Sheriff, and the Father, Mark W. Rummel, shall have shared legal
custody of Christian T. Sheriff, born May 14, 1997. Each parent shall have an equal right, to be
exercised jointly with the other parent, to make all major non-emergency decisions affecting the
Child's general well-being including, but not limited to, all decisions regarding his health, education
and religion. The parties shall cooperate in sharing all information pertaining to the Child and shall
communicate directly with regard to issues concerning the Child.
4. The Mother shall have primary physical custody ofthe Child.
5. The Father shall have partial physical custody of the Child on alternating weekends from
Friday at 6:00 p.m. through Sunday at 6:30 p.m., beginning October 12, 2001. In addition, the Father
shall have custody every Tuesday from 6:00 p.m. until 8:30 p.m. The Father may also have custody at
any additional times as arranged by agreement ofthe parties.
6. The parties shall share or alternate having custody of the Child on holidays as follows:
A. CHRISTMAS: The Christmas holiday shall b,~ divided into Segment A, which shall
run from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment
B, which shall run from Christmas Day at 12:00 noon through December 26 at 12:00 noon.
The Father shall have custody of the Child during Segment A in odd numbered years and
during Segment B in even numbered years. The Mother shall have custody of the Child
during Segment A in even numbered years and during Segment B in odd numbered years.
B. THANKSGIVING: In odd numbered years, the Father shall have custody of the Child
on Thanksgiving Day from 8:00 a.m. until 9:00 p.m. and in even numbered years, the
Mother shall have custody of the Child on Thanksgiving Day from 8:00 a.m. until 9:00 p.m.
C. NEW YEARS: The New Years holiday shall IUn from New Years Eve at 5:30 p.m.
through New Years Day at 5:30 p.m. The Mother shall have custody of the Child over the
New Years holiday in odd numbered years and the Father shall have custody in even
numbered years. For purposes of this provision, the entire New Years holiday shall be
deemed to fall in the same year as New Years Eve.
D. MOTHER'S DAY/FATHER'S DAY: In every year, the Mother shall have custody of
the Child on Mother's Day from 9:00 a.m. until 8:00 p.m. and the Father shall have custody
on Father's Day from 9:00 a.m. until 8:00 p.m.
E. MOTHER'S BIRTHDAY/FATHER'S BIRTH!!AX: The Mother shall have custody
of the Child ever year on her birthday (January 9) fi'om 5:30 p.m. until 8:30 p.m. and the
Father shall have custody of the Child every year on his birthday (June 26) from 5:30 p.m.
until 8:30 p.m. In the event the Mother's period of birthday custody falls on the Father's
regular period of partial custody on Tuesday, the Father's custody period shall
automatically be rescheduled to the following Wednesday. In the event the Mother's period
of birthday custody falls on the Father's regularly sch,~duled weekend period of custody, the
Mother shall have custody of the Child for the entire weekend and the Father's weekend
shall be rescheduled to the immediately following weekend. The alternating weekend
schedule shall continue thereafter unaffected by the adjustment which will result in each
party having two consecutive weekend periods of custody.
F. CHILD'S BIRTHDAY: In even numbered years, the Father shall have a period of
custody on the Child's birthday (May 14) from 5:30 p.m. until 8:30 p.m. and in odd
numbered years, the Mother shall have a period of custody with the Child on the Child's
birthday from 5:30 p.m. until 8:30 p.m.
G. In the event any period of holiday or birthday custody falls on a weekday and is
scheduled to begin at 5:30 p.m., the beginning time for the period of custody shall be
adjusted to 6:00 p.m.
H. The holiday custody schedule shall supersede and take precedence over the regular
custody schedule.
7. Unless otherwise agreed between the parties, all cus.tody exchanges shall take place inside
the building of the Carlisle Police Department. Both parties shall ensure that there are no third parties
present during the exchanges of custody. The parties shall conduct all exchanges of custody in a
cooperative and civil manner in order to promote the best interests of the Child. Each party shall
notify the other party in the event he or she will be more than 15 minutes late for an exchange of
custody.
8. Both parties shall abide by all laws regarding appropnlate child restraint in motor vehicles.
9. The Mother shall be entitled to have custody of the Child for one uninterrupted week each
year upon providing at least 30 days advance written notice to the Father. When the Mother's period
of extended custody under this provision is scheduled during the Father's regular weekend period of
custody, the Father shall have a make-up period of weekend custody during the weekend immediately
preceding the Mother's selected period of custody. The Father s.hall have extended periods of custody
with the Child during the summer each year with the specific arrangements to be established by
agreement ofthe parties.
10. In the event either party intends to remove the Child from Pennsylvania for an overnight
period or longer, the party shall provide advance written notice to the other party of the address and
telephone number where the Child can be contacted.
II. Neither parent 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 ensure that third parties having contact
with the Child comply with this provision.
12. 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 in writing by mutual consent. In the
absence of mutual consent, the terms of this Order shall control.
BY THE CQBRT,
.'
,.
UAA
\
1.
Edgar B. Bayley,
cc: Dirk E. Berry, Esquire - Counsel for Mother
Jeanne B. Costopoulos, Esquire - Counsel for Father T.4 ~
1I_()(..OI
9-.
....
V;~JV/\lt\Sf\,IN:?d
I L"n~r '" I."~'''n''
,,,_ :\1/'),) ',-':",;,'~~ 1\)
II ;:1 "
"
"In
,lj,:if I'.'
,
NOV 0 2 2001 3lr
WILLIAM L. SUNDAY
DAWN S, SUNDAY
Attorneys - at - Law
39 West Main Street. Ste. 1
Mechanlcsburg. PA 1 7055-6230
Phone (71 7) 766-9622
Phone (71 7) 766-969B
Fax (717) 795-72BO
November 1,2001
Cumberland County Court House
Court Administrator's Office
ATTN: Taryn Dixon
One Courthouse Square
Carlisle, PA 17013
RE: Christine L. Sheriffvs. Mark W. Rummel,
Docket No. 97-6837, In Custody
Dear Taryn,
A Conciliation Conference was held in the above-referenc:ed matter on October 10, 2001 after
which a Conciliation Report and agreed upon Order were forwarded to your office. The Order was
signed by Judge Bayley on October 22. The Order provided for the parties to initiate counseling for
the Child and obtain recommendations from the counselor concerning the advisability of the parties'
participation in counseling and promotion of the Child's best interests in light of the parties' respective
allegations of alienation of the Child's affections. It was my understanding that the parties agreed at
the Conference to follow the recommendations of the counselor on those issues.
I received a request from Dirk Berry, counsel for the Mother, to delete the last sentence of
paragraph 2 requiring the parties to abide by the counselor's recommendations. Mr. Berry does not
believe the parties agreed to be bound by the counselor's recommendations. Jeanne Costopoulos,
counsel for the Father, indicated that it was her understanding that the parties had agreed to abide by
the counselor's recommendations. However, Ms. Costopoulos advised that her client agreed to
amendment of the Order to delete the sentence in question.
In light of the highly contentious nature of this custody matter, and in an effort to avoid further
conflict between the parties as they initiate counseling for the Child, I am enclosing an amended Order
for Judge Bayley's consideration. It is identical to the previous Order which he signed on October 22,
2001 with the exception of the following sentence from paragraph 2 which has been deleted: "The
parties shall follow the recommendations of the counselor with respect to either or both parties'
participation in counseling and also any recommendations issued by the counselor concerning the
promotion of the Child's best interests."
I am enclosing additional envelopes addressed to counsd for each party for forwarding of the
Order. Please call me if you have any questions.
Sincl~rely,
D+i~
DSS/cg
cc: Dirk E. Berry, Esquire - Counsel for Mother
Jeanne B. Costopoulos, Esquire - Counsel for Father
CHRISTINE L. SHERIFF,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-6837
CIVIL TERM
MARK W. RUMMEL,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this day of , 2003, 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 , 2003,
at _.m., for a Pre-Hearing Custody Conferf:nce. 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:
By:
Custody Conciliator
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.
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
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
CHRISTINE L. SHERIFF,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-6837
CIVIL TERM
MARK W. RUMMEL,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
PETITION FOR MODIFICA nON OF A CUSTODY ORDER
1. The Petition of Christine L. Sheriff, Mother/Plaintiff respectfully
represents that on November 5, 2001, an Order of Court was entered for primary and
partial custody, a true and correct copy of which is attached.
2.
a.
This Order should be modified because the child has enjoyed
minor modifications to his holiday custody schedule, for approximately one and one-half
years, by agreement of the parents.
b. However, by letter dated September 9, 2003 Father notified
Mother that he was unilaterally rescinding all verbal agreements.
c. Client seeks to formalize the parties' previous agreements,
regarding holiday periods, which would result in the following changes to the November
5, 2001 order:
Thanksgiving: Amend the time frame to read 9:00 a.m. to 6:00 p.m.
Mother's DlQ'lFather's Day: Amend the Mother's Day/Father's Day schedule
such that the custodial parent (who would have had the child from 9:00 a.m. to 8:00
p.m. on their respective Mother's Day/Father's Day) will instead have the child the
entire weekend with drop off time, for Father's weekend, being 6:00 p.m. on Friday
evening and the child returning Sunday at 6:30 p.m.; and on Mother's Day the child will
remain with Mother the entire weekend.
Police Station: The parents have used North Middletown Police Station since
November of 2002, instead of the Carlisle Police Station as indicated in the November 2,
2001 Order. Mother requests that Order be amended to read that the North Middletown
Police Station will be the custody exchange location.
Easter: The parents will alternate custody on Easter day utilizing either the
Mother's Day/Father's Day time frames or the Thanksgiving time frames on an every
other year basis. Custody is modified such that each school year one parent has the
Thanksgiving holiday and the other parent will have the Easter holiday.
Fourth of .July: Custody on the Fourth of July will follow the normal schedule,
regardless of whether it falls on a week day or a weekend.
WHEREFORE, Petitioner/Mother Christine L. Sheriff respectfully requests that
this Honorable Court modify the existing Order for custody and partial custody because
it will be in the best interest of the child.
It d~r./
~y, Esquire
Attorney for Plaintiff/Mother
7 Irvine Row
Carlisle, PA 17013
(717) 240-0296
VERIFICATION
I verify that the statements made in this Defendant's Answer to Petition for Modification
of a Custody Order are true and correct to the best of my knowledge 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.
(!;ed7/J10~>> I i6
hristine L.:~ riff
CHRISTINE L. SHERIFF,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-6837
CIVIL TERM
MARK W. RUMMEL,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
CERTIFICATE OF SERVJ!CE
I, Dirk E. Berry, Esquire, do hereby certify that on this day Petitioner's
Petition for Modification of a Custody Order was served by First Class Mail, postage
pre-paid upon the following persons:
Jeanne Costopoulis, Esquire
5000 Ritter Road, Suite 202
Box 779
Mechanicsburg, P A 17055
Date:
/0-3,)-03
/~Ap
~.ry, EsqUIre
Attorney for Plaintiff
7 Irvine Row
Carlisle, PA 17013
(717) 240-01296
.--/
?i;>(:)-&q.
fI= ~ ~
~ ~ &
~ ~
1
(') 0 0
<;; W -n
~& 0 -\
C) ~1~~ ;;9
L;.: ..-.
t{;t I..) n'il
~. 0 uy
~( '~:~ (:,
- -0 i.,': ::r~
:!?( :::,:; ('_1":1.J
~(" ".q
:Ps:,. y? ~l
.-1
::~. W "1>-
::0
0 -<
CHRISTINE L. SHERIFF
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
V.
97-6837 CIVIl. ACTION LAW
MARK W. RUMMEL
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, Wednesday, November 05, 2003 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, December 04, 2003 at 8:30 AM
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.
The court hereby directs the parties to furnish any and all exislling Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours Ilrior to scheduled hearing.
FOR THE COURT.
By: Isl
Dawn S. Sunday. Esq.
Custody Conciliator
I /
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 faciliti'es 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 THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TEl.EPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Str,eet
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
.t/,.~Ip ~ ~ ~ F:o-S-J(
~ fJ-P p:- ~ ~ [:0-5-/(
~ P <j: ~~,J - ~ ['o.F/(
V1NV^"t18NN3d
I 'Nn"") ~'''~, '-""Aln"
f\J. . ,l}" :JHf7 !'.:::itfn v
95:f Hd s- I\ON W
AtJV1W,:'>,-:C", oJO
3Ji::J~o-{h-ii,~'i
.... ""''''IJ.,j
CHRISTINE L. SHERIFF,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
97 -683 7
CIVIL ACTION LAW
MARK W. RUMMEL
Defendant
IN CUSTODY
ORDER
AND NOW, this ~ day of '0 Q,etk""-. , 2003,
consideration of the attached Custody Conciliation Report, it is ordered and directed as foIlows:
upon
1. The prior order of this Court dated November 5, 2001 is vacated and replaced with this
Order.
2. The Mother, Christine L. Sheriff and the Father, Mark W. Rummel, shaH have shared legal
custody of Christian T. Sheriff, born May 14,1997. Each parent shaH have an equal right, to be
exercised jointly with the other parent, to make all major non-emergency decisions affecting the
Child's general well-being including, but not limited to, all decisions regarding his health, education
and religion. Pursuant to the terms of this paragraph each parent shaH be entitled to aH records and
information pertaining to the Child including, but not limited to, school and medical records and
information.
3. The Mother shall have primary physical custody of the Child.
4. The Father shaIl have partial physical custody of the Child on alternating weekends from
Friday at 6:00 pm through Sunday at 6:30 pm. In addition, the Father shaH have custody every
Tuesday from 6:00 pm until 8:30 pm and at any additional times as arranged by agreement between
the parties.
5. The parties shall share or alternate having custody of the Child on holidays as follows:
A. CHRISTMAS: The Christmas holiday shall be divided into Segment A,
which shall run from Christmas Eve at 12:00 noon through Christmas Day at
12:00 noon, and Segment B, which shall run from Christmas Day at 12:00 noon
through December 26 at 12:00 noon. The Father shaH have custody of the Child
during Segment A in odd numbered years and during Segment B in even
numbered years. The Mother shaH have custody of the Child during
Segment A in even numbered years and during Segment B in odd numbered
years.
B. THANKSGIVING: In every year the Mother shaH have custody ofthe Child
on Thanksgiving Day from 9:00 am unti12:30 pm and the Father shaH have
custody from 2:30 until 9:00 pm.
C. NEW YEARS: The New Years holiday shaH run from New Years Eve at
5:30 pm through New Years Day at 5:30 pm. The Mother shaH have custody of
the Child over the New Years holiday in odd numbered years and the Father
shall have custody in even numbered years. For purposes of this provision, the
entire New Years holiday shaH be deemed to fall in the same year as New Years
Eve.
D. MOTHER'S DAY / FATHER'S DAY: In every year, the Mother shall have
custody ofthe Child for the entire Mother's Day weekend and the Father shaH
have custody of the Child every year for the entire Father's Day weekend from
Friday 6:00 pm through Sunday at 6:30 pm. In the event a party misses, a
weekend period of custody under this provision, there shall be a make up
weekend for that party either immediately preceding or foHowing the holiday so
that each party has two consecutive weekend periods of custody.
E. EASTER: The party who has custody of the Child under the alternating
weekend schedule over Easter, shaH have custody of the Child on Easter Day
until 2:30 pm and the other party shall have custody from 2:30 pm until
9:00 pm.
F. JULY 4th: The party who has custody of the Child under the regular custody
schedule shall have custody of the Child on the July 4th holiday.
G. PARENT'S BIRTHDAYS: The Mother shall have custody of the Child every
year on her birthday (January 9) from 5:30 pm until 8:30 pm and the Father shaH
have custody of the Child every year on his birthday (June 26) from 5:30 pm
until 8:30 pm. In the event the Mother's period of birthday custody falls on the
Father's regular period of partial custody on Tuesday, the Father's custody
period shall automatically be rescheduled to the following Wednesday. In the
event the Mother's period of birthday custody falls on the Father's regularly
scheduled weekend period of custody, the Mother shaH have custody of the
Child for the entire weekend and the Father's weekend shaH be rescheduled to
the immediately foHowing weekend. The alternating weekend schedule shaH
continue thereafter unaffected by the adjustment which will result in each party
having two consecutive weekend periods of cllstody.
H. CHILD'S BIRTHDAY: In even numbered years, the Father shall have a
period of custody on the Child's birthday (May 14) from 5:30 pm unti18:30 pm
and in odd numbered years, the Mother shaH have a period of custody with the
Child on the Child's birthday from 5:30 pm until 8:30 pm.
I. In the event any period of holiday or birthday custody falls on a weekday and
is scheduled to begin at 5:30 pm, the beginning time for the period of custody
shall be adjusted to 6:00 pm.
J. The holiday custody schedule shall supercede and take precedence over the
regular custody schedule.
6. Unless otherwise agreed between the parties, custody exchanges shall take place inside
Nell's Supermarket on Spring Road in Carlisle. In the event Nel1's Market is closed due to a holiday
or other circumstances, the parties shall exchange custody inside the Carlisle Wal-Mart.
Both parties shall ensure that there are no third parties present (or on the premises) during the
exchanges of custody. The parties shall conduct all exchanges of custody in a cooperative and civil
manner in order to promote the best interest of the Child. Each party shall notify the other in the event
that he or she will be more than 15 minutes late for an exchange of custody.
7. Both parties shall abide by all laws regarding appropriate child restraint in motor vehicles.
8. The Mother shall be entitled to have custody of the Child for one uninterrupted week each
year upon providing at least 30 days advance written notice to th,~ Father. When the Mother's period of
extended custody under this provision is scheduled during the Father's regular weekend period of
custody, the Father shall have a make-up period of weekend custody during the weekend immediately
preceding the Mother's selected period of custody. The Father shall have extended periods of custody
with the Child during the summer each year with the specific arrangements to be established by
agreement ofthe parties.
9. In the event either party intends to remove the Child from Pennsylvania for an overnight
period or longer, the party shall provide advance written notice to the other party of the address and
telephone number where the Child can be contacted.
10. The parties shall arrange for the Child to have one counseling session with Georgi
Anderson to address issues raised by the Father with respect to th,e conflict experienced by the Child in
the custody situation. The Father shall be responsible to schedul,~ the appointment during the Father's
custodial period. In event the counselor is not available during the Father's period of custody, the
Mother shall schedule the session during her custodial time. The Father shall be responsible for all
costs of the counseling.
11. The parties agree that discipline of the Child shall be the sole responsibility of the parents
and that unrelated third parties, such as the Father's friend, April, shall not discipline the Child.
12. 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 ensure that third parties having contact
with the Child comply with this provision.
13. 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.
/
Edgar B. Bayley
J.
cc: Dirk E. Berry, Esquire - Counsel for Mother
Jeanne B. Costopoulos, Esquire - Counsel for Father
~ _.. d.'" / ~ .J!,.!),)
f ~ ,.~ a<
cr.
,.-."
1'~
.C)
d.,._",.
r-) --{"
fc~
1..L~
- ,..-
Yo
60:
wo_
~::dt.LJ
U-;:s
u..
()
(~.j
L.L..-
~:~"i
,-"
...
.:~~;~
,~;::Z
'-')1'1
~~) fi.
..2:
:;:)
Q
(...)
Ld
=
.,...,
=
=
C.....
CHRISTINE L. SHERIFF,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
97-6837
CIVIL ACTION LAW
MARK W. RUMMEL
Defendant
IN CUSTODY
Prior Judge: Edgar B. Bayley
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Christian T. Sheriff
May 14,1997
Mother
2. A Conciliation Conference was held on December 4, 2003, with the following individuals in
attendance: The Mother, Christine L. Sherriff, with her counsel, Dirk E. Berry, Esquire, and the Father,
Mark W. Rummel, and his counsel, Jeanne B. Costopoulos, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Qu.!"," /:)1/1 f( J-fJo"
o~
Dawn S. Sunday, Esquire
Custody Conciliator
Date
CHRISTINE L. SHERIFF,
Plaintiff/Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97 - 6837
CIVIL TERM
MARK W. RUMMEL,
DefendantlRespondant
: CIVIL ACTION - LAW
: IN CUSTODY
PETITION FOR MODIFICATION OF A CUSTODY ORDER
AND NOW comes Christine L. Sheriff, natural mother of the subject child, by her
attorney, Dirk E. Berry, Esquire, and respectfully avers as follows:
I. The petition of Christine L. Sheriff, mother of the subject child, Christian T.
Sheriff, born May 14, 1997, respectfully represents that on November 5, 2001, an Order of
Court was entered for Custody, a true and correct copy of which is attached.
2. This Order should be modified because:
a. Paragraph 2 of the Order has ceased to be timely. By mutual consent,
confirmed by the parties' inaction with regard to this paragraph, the provisions contained
therein have never been acted upon. The time when this provision may have been
appropriate has passed.
b. Upon information and belief, father has often delegated custody, during his
partial custody periods, to various "baby sitters," or other "custodians," resulting in Christian
spending extended periods of time without the company of either parent.
WHEREFORE, Petitioner, Christine 1. Sheriff, respectfully requests this Honorable
Court modify the existing Order by deleting/vacating paragraph 2 and granting mother,
Christine 1. Sheriff, a right of first refusal for custody of Christian during father's partial
custody periods in the event that father will not be with the child for extended period( s),
because it will be in the best interest of the child.
Respectfully submitted,
LAW OFFICE OF DIRK BERRY, ESQ.
.d:l~
----------
Dirk E. Berry, Esquire
Attorney for Petitioner
44 S. Hanover St.
Carlisle, P A 170 J3
(717) 243-4448
VERIFICATION
I verify that the statements made in this Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. e.S. ~ 4904 relating to
unsworn falsification to authorities.
/ '
'/ / / ')('. ;'~
I ) .... 1
. / /
Date
i.1i .I./-h"11 C 2?L'/})( t!
( v I .
Christine L Sheriff .
NOli {J 2 2001 Jff'
CHRISTINE 1.. SHERIFF,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYl. VANIA
vs.
97-6837
CIVIL ACTION l.A W
MARK W. RUMMEL,
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this S<!: day of IU-w..,..,~ , 2001,
upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Orders of this Court dated February 27, 2001 and October 22, 2001 are vacated
and replaced with this Order.
2. The parties shall promptly initiate counseling for the Child with a professional selected by
agreement of the parties. The purpose of the counseling shall be to evaluate the Child' s adjustment to
the custody situation focusing on the parents' respective allegations of alienation of the Child's
affections and also to obtain recommendations concerning the Child's best interests. All costs of
counseling which are not reimbursed by insurance coverage shall be shared equally between the
parties. Both parties shall ensure that there are no third parties present at the time of the counseling
sessions unless specifically requested by the counselor.
3. The Mother, Christine 1.. Sheriff, and the Father, Mark W. Rummel, shall have shared legal
custody of Christian T. Sheriff, born May 14, 1997. Each parent shall have an equal right, to be
exercised jointly with the other parent, to make all major non-emergency decisions affecting the
Child's general well-being including, but not limited to, all decisions regarding his health, education
and religion. The parties shall cooperate in sharing all information pertaining to the Child and shall
communicate directly with regard to issues concerning the Child.
4. The Mother shall have primary physical custody of the Child.
5. The Father shall have partial physical custody of the Child on alternating weekends from
Friday at 6:00 p.m. through Sunday at 6:30 p.m., beginning October 12, 2001. In addition, the Father
shall have custody every Tuesday from 6:00 p.m. until 8:30 p.m. The Father may also have custody at
any additional times as arranged by agreement of the parties.
6. The parties shall share or alternate having custody of the Child on holidays as follows:
A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall
run from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment
B, which shall run from Christmas Day at 12:00 noon through December 26 at 12:00 noon.
The Father shall have custody of the Child during Segment A in odd numbered years and
during Segment B in even numbered years. The Mother shall have custody of the Child
during Segment A in even numbered years and during Segment B in odd numbered years.
B. THANKSGIVING: In odd numbered years, the Father shall have custody of the Child
on Thanksgiving Day from 8:00 a.m. until 9:00 p.m. and in even numbered years, the
Mother shall have custody of the Child on Thanksgiving Day from 8:00 a.m. until 9:00 p.m.
C. NEW YEARS: The New Years holiday shall run from New Years Eve at 5:30 p.m.
through New Years Day at 5:30 p.m. The Mother shall have custody of the Child over the
New Years holiday in odd numbered years and the Father shall have custody in even
numbered years. For purposes of this provision, the entire New Years holiday shall be
deemed to fall in the same year as New Years Eve.
D. MOTHER'S DAY/FATHER'S DAY: In every year, the Mother shall have custody of
the Child on Mother's Day from 9:00 a.m. until 8:00 p.m. and the Father shall have custody
on Father's Day from 9:00 a.m. until 8:00 p.m.
E. MOTHER'S BIRTHDAY/FATHER'S BIRTHDAY: The Mother shall have custody
of the Child ever year on her birthday (January 9) from 5:30 p.m. until 8:30 p.m. and the
Father shall have custody of the Child every year on his birthday (June 26) from 5:30 p.m.
until 8:30 p.m. In the event the Mother's period of birthday custody falls on the Father's
regular period of partial custody on Tuesday, the Father's custody period shall
automatically be rescheduled to the following Wednesday. In the event the Mother's period
of birthday custody falls on the Father's regularly scheduled weekend period of custody, the
Mother shall have custody of the Child for the entire weekend and the Father's weekend
shall be rescheduled to the immediately following weekend. The alternating weekend
schedule shall continue thereafter unaffected by the adjustment which will result in each
party having two consecutive weekend periods of custody.
F. CHILD'S BIRTHDAY: In even numbered years, the Father shall have a period of
custody on the Child's birthday (May 14) from 5:30 p.m. until 8:30 p.m. and in odd
numbered years, the Mother shall have a period of custody with the Child on the Child's
birthday from 5:30 p.m. until 8:30 p.m.
G. In the event any period of holiday or birthday custody falls on a weekday and is
scheduled to begin at 5:30 p.m., the beginning time for the period of custody shall be
adjusted to 6:00 p.m.
H. The holiday custody schedule shall supersede and take precedence over the regular
custody schedule.
7. Unless otherwise agreed between the parties, all custody exchanges shall take place inside
the building of the Carlisle Police Department. Both parties shall ensure that there are no third parties
present during the exchanges of CLlstody. The parties shall conduct all exchanges of custody in a
cooperative and civil manner in order to promote the best interests of the Child. Each party shall
notify the other party in the event he or she will be more than 15 minutes late for an exchange of
custody.
8. Both parties shall abide by all laws regarding appropriate child restraint in motor vehicles.
9. The Mother shall be entitled to have custody of the Child for one uninterrupted week each
year upon providing at least 30 days advance written notice to the Father. When the Mother's period
of extended custody under this provision is scheduled during the Father's regular weekend period of
custody, the Father shall have a make-up period of weekend custody during the weekend immediately
preceding the Mother's selected period of custody. The Father shall have extended periods of custody
with the Child during the summer each year with the specific arrangements to be established by
agreement of the parties.
10. In the eyent either party intends to remove the Child from Pennsylvania for an overnight
period or longer, the party shall provide advance written notice to the other party of the address and
telephone number where the Child can be contacted.
II. Neither parent 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 ensure that third parties having contact
with the Child comply with this provision.
12. 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 in writing by mutual consent. In the
absence of mutual consent, the terms of this Order shall control.
BY THE COURT,
J,j C13'~ t3
Ect'gar B.' ayley,
/3,-<-,4;
()
J.
cc: Dirk E. Berry, Esquire - Counsel for Mother
Jeanne B. Costopou]os, Esquire - Counsel for Father
'. :.~.~:)
E ... '.".~." . ,
1'-,--: :I'f!:-' " '-11, I, c.:JPoI
::'~Jf~_:~~-
F:C't10t:f}a.fy
CHRISTINE L. SHERIFF,
Plaintiff/Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97 - 6837
CIVIL TERM
MARK W. RUMMEL,
DetendantlRespondant
: CIVIL ACTION - LAW
: IN CUSTODY
CERTIFICATE OF SERVICE
I, Dirk E. Berry, Esquire, do hereby certify that on this day Mother's Petition for
Modification of Custody was served by first class mail, postage pre-paid upon the
following person:
Jeanne B. Costopoulos, Esquire
5000 Ritter Road, Suite 202
Mechanicsburg, P A 17055
Date:
Y-2-7- Dr
Jtt~~ --
Dirk E. Berry, Esquire
Attorney for Petitioner
44 S. Hanover St.
Carlisle, PA 17013
(717) 243-4448
('~ ,-.0 (~
"'"
C c:;::;> -n
, .:::.1'\
= ~ ~ :P"" :::1
~ -1:' _.L-'"'\"1
;:'(J j"'nf:::!
_1'10-'
~ (',) ~-~(~?
......, -.l
., Iv
c-.. ~ -::) (_~.::;,~1_1
u- ... ::j: ';;;.~ C)
:-')rn
-l:: '-", ---::;1
<::; ...,...,:.
<:::;; t....J '::~J
'2, 0-' '-'"
~-
CHRiISTINE L. SHERIFF
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
97-6837 CIVIL ACTION LAW
I
!
MA~K W. RUMMEL
I DEFENDANT
I
,
IN CUSTODY
ORDER OF COURT
A D NOW,
Wednesdar, May 04, 2005
, upon consideration of the attached Complaint,
it is here y directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. . the conciliator,
at 9 West M_~~"-_Street, Mechanicsburg, PA 17055 on __~ednesday, Mav 25, 2005 ~_ at 12:30 PM
for a Pre Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute: or
ifthis ca not be accomplished. to define and narrow the issucs to be heard by the court, and to enter into a temporary
order. A I ehildren age five or older may also be present at the conference. Failure to appear at the conference may
provide rounds for entry of a temporary or penn anent order.
T e court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special elief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: -.is!..
Dawn S. Sunday, ~_
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
avai able to disabled individuals having business before the court, please contact our office. All arrangements
mus be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
coni rence or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HA E AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE 'rHE OFFICE SET
FO TH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedl{}[d Strect
Carlisle, Pennsylvania 17013
Telephone (717) 249-3 166
1j.~~ ;'?-~~". ~~ ...fr.2Y-.F
7?~I~p V .:.2 .Pt/7??H/ i>~U; >>py
4~bi!? ;2 1'777)1/ ~/-;{/_ 0/.>,1;'
<:;., '-"11"
....::..(.. .,.;
k.-
,........ 'i.ll,l ('nil?
::'l ,'\,:;,.Jl)\.,...
~ :, " ~:~ ~_~1\1l ::0
U:-J Ib
-
RECEIVED MAY 27 2005 ~
CHRISTINE L. SHERIFF
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
97-6837
CIVIL ACTION LAW
MARK W. RUMMEL
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this:?l day of ,A Al,~ , 2005,
consideration of the attached Custody Conciliation Report,it is ordered ~d directed as follows:
upon
1. The prior Order ofthis Court dated December 15, 2003, shall continue in effect as modified
by this Order.
2. In the event either party is unavailable to provide care for the Child during his or her period
of custody for an overnight period or a period in excess of eight hours, that party shall first contact the
other parent to offer the opportunity to provide care for the Child. during the period of unavailability
before contacting third party caregivers.
3. The parties shall adjust the alternating weekend schedule to ensure that the Mother has
custody of the Child during the Father's military drill weekends :and the Father has make-up weekend
periods of custody in exchange.
4. The parties shall cooperate in scheduling extensive lib'~ral periods of custody for the Father
during his periods of military leave when the Father is deployed or in training.
5. The Mother, Father and Father's girlfriend shall participate in counseling with a professional
selected by agreement between the parties. The purpose of the counseling shall be to address concerns
which have arisen with regard to the ability to cooperate and maintain civility in order to promote the
Child's interests.
6. The Mother's Day holiday period of custody shall tah precedence over the Child's birthday
period of custody.
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 CQ.URT,
Edgar B. Bayley J.
cc: ~~rry, Esquire - Counsel for Mother
~e i-Costopoulos, Esquire - Counsel for Father
~
Q5~ 31'~ OS
o
N
u_
C"!
u"
..,.-
1'-
;::
:.J
,.-)
'..<!
~-
...r::;:
"c>
C:::l"
C?
c..J
o
-
.
CHRISTINE L. SHERIFF
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
97-6837
CNIL ACTION LAW
MARK W. RUMMEL
Defendant
IN CUSTODY
Prior Judge: Edgar B. Bayley
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Christian T. Sheriff
May 14, 1997
Mother
2. A conciliation conference was held on May 25, 2005, with the following individuals in
attendance: The Mother, Christine L. Sheriff, with her counsel, Dirk E. Berry, Esquire, and the Father,
Mark W. Rummel, with his counsel, Jeanne B. Costopoulos, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
J.. (; ;) (')(1 <)
I
a_-<I,-~
Dawn S. Sunday, Esquire
Custody Conciliator
---
CHRISTINE L. SHERIFF,
Plaintiff
: THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 97-6837 CIVIL ACTION - LAW
MARK W. RUMMEL,
Defendant
: IN CUSTODY
TO THE HONORABLE EDGAR B. BAYLEY, .JUDGE OF SAID COURT:
nRFRNnANT'S PRTTTTON FOR SPRCl AI. RF.I .IF.F
FOR MOnIFWATTON OF SITMMRR CITSTOnV SCHRnIa,F.
AND NOW, the Defendant, Mark W. Rummel, by and through his attorney, Jeanne B.
CostopouIos, Esquire, avers the following in support of this Petition:
I. Petitioner, is Mark W. Rummel, Defendant above, hereinafter referred to as Father.
2. Respondent is Christine L. Sheriff, Plaintiff above, hereinafter referred to as Mother.
3. There is one dependent child from the relationship of Mother and Father, namely
Christian T. Sheriff, born May 14,1997, hereinafter referred to as the Child.
4. The parties have been subject to an Order of Court dated December 15, 2003
which essentially provides Mother with primary custody and Father with partial
custody in the form of alternating weekends from Friday at 6:00 p.m. through
Sunday at 6:30 p.m. and Tuesday evenings from 6:00 p.m. until 8:30 p.m. This
order is attached as Exhibit A.
5. Upon Mother's petition, the parties recently attended a conciliation conference on
May 25, 2005, before Dawn S. Sunday, Esquire. An Order of Court was
subsequently entered on May 31, 2005, containing certain modifications to the
December 15, 2003 Order, including the addition of a "right of first refusal"
---
provision, schedule changes dealing with Father's drill weekends and military
leave, and a directive for the parties to participate in counseling. This Order is
attached hereto as Exhibit B.
6. Although not fully addressed on May 25, 2005, the date of the custody
conference, since Mother's counsel having to attend another proceeding for which
he was running late, Father made an oral request for additional custody over the
summer since he is to begin basic training in the fall and will not see the child for
several weeks. Father agreed to submit a proposal to Mother through counsel.
7. Father's counsel faxed a letter on May 27, 2005 containing Father's request to
essentially flip-flop the current schedule for the summer of 2005 only. In
addition, Father asked that his family be permitted to take the child with them to
Father's basic training graduation ceremony in the fall of 2005. Father also
provided the names of two counselors in an effort to get started on the new
counseling provision contained in the May 31,2005 Order. See fax - Exhibit C.
8. On June 2, 2005, Mother's counsel informed Father's counsel that Mother did not
agree with Father's summer custody proposal and she would only agree to trade
some weekends such that Father would have most of the weekends in July.
Mother's counsel also informed Father's counsel that although Mother agreed
fundamentally with permitting the child to attend the graduation ceremony, she
wanted to wait until closer to the ceremony to discuss the details. Unfortunately,
once Father leaves for basic training he will be without recourse if Mother later
rescinds her vague acquiescence for the child to attend the ceremony. Therefore,
Dated:
-
Father is seeking that a detailed provision now be included in the order so it is
clear at graduation time under what conditions the child will attend the ceremony.
9. Lastly, Mother rejected both counselors Father had suggested due to the fact that
"no one had ever heard of either of them". Since Father agreed to pay for the
counseling, he believes Mother should not have the authority to veto all of his
suggestions and that Mother be required to select a counselor from a list of five to
be submitted by Father.
WHEREFORE, Father respectfully requests this Honorable Court to modi/)' the
May 31, 2005 Order of Court such that Father is granted primary custody for the summer
of 2005, subject to partial custody by Mother, that a provision be added to the order
addressing the child's attendance at Father's basic training graduation ceremony, and that
Mother select one counselor from a list of five to be submitted by Father.
{It; /tJr
Respectfully submitted,
~ ~
%anne B. Costopoulos, Esquire
ATTORNEY FOR DEFENDANT
5000 Ritter Road, Suite 202
Mechanicsburg, P A 17055
Phone: (717) 790-9546
PA Supreme Ct. ill No. 68735
CHRISTINE L. SHERIFF,
Plaintiff
: THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
: No. 97-6837 CIVIL ACTION - LAW
MARK W. RUMMEL,
Defendant
: IN CUSTODY
VRRTFTCATTON
I, Mark W. Rummel, hereby verify that the statements made in the foregoing petition are
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.
s;~m~
W. e
Date: .s ~lAl\l e~
CHRISTINE L. SHERIFF,
Plaintiff
: THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 97-6837 CIVIL ACTION - LAW
MARK W. RUMMEL,
Defendant
: IN CUSTODY
CF.RTIFWA TF OF SFRVlCF.
I, Jeanne B. CostopouJos, Esquire, hereby certify that this day I served a copy of the
attached Petition upon the persons, and in the manner, indicated below, which service satisfies the
requirements of the P A Rules of Civil Procedure, by depositing a copy of the same with the United
States Post Office at Mechanicsburg, Pennsylvania, through first class mail, prepaid, and addressed
as follows:
Dirk Berry, Esquire
44 S. Hanover Street
Carlisle, P A 17013
Dated:
G 4;;,;'
BY: eanne B. Costopoulos, Esquire
ATTORNEY FOR DEFENDANT
5000 Ritter Road, Suite 202
Mechanicsburg, P A 17055
Phone: (717) 790-9546
P A Supreme Ct. ID No. 68735
EXHIBIT A
CHRlSTINE L. SHERIFF,
Plaintiff
Dre 122003
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
/~@~~y
>
~..""F
~
vs.
97-6837
CIVIL ACTION LAW
MARK W. RUMMEL
Defendant
IN CUSTODY
ORDER
AND NOW, this ISE:- day of /2. ""< {i.. , , 2003, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
L The prior order of this Court dated November 5, 2001 is vacated and replaced with this
Order.
2. The Mother, Christine L. Sheriff and the Father, Mark W. Rummel, shall have shared legal
custody of Christian T. Sheriff, born May 14,1997. Each p;l1'ent shall have an equal right, to be
exercised jointly with the other parent, to make all major non-emergency decisions affecting the
Child's general well-being including, but not limited to, all decisions regarding his health, education
and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and
information pertaining to the Child including, but not limited to, school and medical records and
information.
3. The Mother shall have primary physical custody ofthe Child.
4. The Father shall have partial physical custody ofthe Child on alternating weekends from
Friday at 6:00 pm through Sunday at 6:30 pm. In addition, the Father shall have custody every
Tuesday from 6:00 pm until 8:30 pm and at any additional times as arranged by agreement between
the parties.
5. The parties shall share or alternate having custody of the Child on holidays as follows:
A. CHRISTMAS: The Christmas holiday shall be divided into Segment A,
which shall run from Christmas Eve at 12:00 noon through Christmas Day at
12:00 noon, and Segment B, which shall run from Christmas Day at 12:00 noon
through December 26 at 12:00 noon. The Father shall have custody of the Child
during Segment A in odd numbered years and during Segment B in even
numbered years. The Mother shall have custody of the Child during
Segment A in even numbered years and during Segment B in odd numbered
years.
~
B. THANKSGIVING: In every year the Mother shall have custody of the Child
on Thanksgiving Day from 9:00 am until 2:30 pm and the Father shall have
custody from 2:30 until 9:00 pm.
C. NEW YEARS: The New Years holiday shall run from New Years Eve at
5:30 pm through New Years Day at 5:30 pm. The Mother shall have custody of
the Child over the New Years holiday in odd numbered years and the Father
shall have custody in even numbered years. For purposes of this provision, the
entire New Years holiday shall be deemed to fall in the same year as New Years
Eve.
D. MOTHER'S DAY / FATHER'S DAY: In every year, the Mother shall have
custody of the Child for the entire Mother's Day weekend and the Father shall
have custody of the Child every year for the entire Father's Day weekend from
Friday 6:00 pm through Sunday at 6:30 pm. In the event a party misses a
weekend period of custody under this provision, there shall be a make up
weekend for that party either immediately preceding,or following the holiday so
that each party has two consecutive weekend periods of custody.
E. EASTER: The party who has custody of the Child under the alternating
weekend schedule over Easter, shall have custody of the Child on Easter Day
until 2:30 pm and the other party shall have custody from 2:30 pm until
9:00 pm.
F. mLY 4th: The party who has custody of the Child under the regular custody
schedule shall have custody of the Child on the July 4th holiday.
G. PARENT'S BIRTHDAYS: The Mother shall have custody of the Child every
year on her birthday (January 9) from 5:30 pm until 8:30 pm and the Father shall
have custody of the Child every year on his birthday (June 26) from 5 :30 pm
until 8:30 pm. In the event the Mother's period of birthday custody falls on the
Father's regular period of partial custody on Tuesday, the Father's custody
period shall automatically be rescheduled to the following Wednesday. In the
event the Mother's period of birthday custody falls on the Father's regularly
scheduled weekend period of custody, the Mother shall have custody of the
Child for the entire weekend and the Father's weekend shall be rescheduled to
the immediately following weekend. The alternating weekend schedule shall
continue thereafter unaffected by the adjustment which will result in each party
having two consecutive weekend periods of custody.
H. CHILD'S BIRTHDAY: In even numbered years, the Father shall have a
period of custody on the Child's birthday (May 14) from 5:30 pm until 8:30 pm
and in odd numbered years, the Mother shall have a period of custody with the
Child on the Child's birthday from 5:30 pm until 8:30 pm.
1. In the event any period of holiday or birthday custody falls on a weekday and
is scheduled to begin at 5 :30 pm, the beginning time for the period of custody
shall be adjusted to 6:00 pm.
J. The holiday custody schedule shall supercede and take precedence over the
regular custody schedule.
6. Unless otherwise agreed between the parties, custody exchanges shall take place inside
Nell's Supermarket on Spring Road in Carlisle. In the event Nell's Market is closed due to a holiday
or other circumstances, the parties shall exchange custody inside the Carlisle Wal-Mart.
Both parties shall ensure that there are no third parties present (or on the premises) during the
exchanges of custody. The parties shall conduct all exchanges of custody in a cooperative and civil
manner in order to promote the best interest of the Child. Each party shall notify the other in the event
that he or she will be more than 15 minutes late for an exchange of custody.
7. Both parties shall abide by all laws regarding appropriate child restraint in motor vehicles.
8. The Mother shall be entitled to have custody of the Child for one lUlinterrupted week each
year upon providing at least 30 days advance written notice to the Father. When the Mother's period of
extended custody under this provision is scheduled during the Father's regular weekend period of
custody, the Father shall have a make-up period of weekend custody during the weekend immediately
preceding the Mother's selected period of custody.'The Father shall have extended periods of custody
with the Child during the summer each year with the specific arrangements to be established by
agreement of the parties.
9. In the event either party intends to remove the Child from Pennsylvania for an overnight
period or longer, the party shall provide advance written notice to the other party of the address and
telephone number where the'Child can be contacted.
10. The parties shall arrange for the Child to have one counseling session with Georgi
Anderson to address issues raised by the Father with respect to the conflict experienced by the Child in
the custody situation. The Father shall be responsible to schedule the appointment during the Father's
custodial period. In event the cOlUlselor is not available during the Father's period of custody, the
Mother shall schedule the session during her custodial time. The Father shall be responsible for all
costs of the counseling.
II. The parties agree that discipline of the Child shall be the sole responsibility of the parents
and that unrelated third parties, such as the Father's friend, April, shall not discipline the Child.
12. 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 ensure that third parties having contact
with the Child comply with this provision.
13. 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,
Ii ~ is. l3'fr
E gar B. yley ,J.
cc: Dirk E. Berry, Esquire. Counsel for Mother
Jeanne B. Costopoulos, Esquire - Counsel for Father
TRUE COPY FROM RECORD
~n T.~lI'ii'~WJf'" "," .w III - "
" ,"" "",,;t8rt"". .era l.mlo sst my !':Oll<!
dn~ iI'li slE-' Itl sa\(l Coun at ,,:,:;,~ .':....'k"
TlUJ -- " " ^ WW'.'=', n..
y ~_JU'l" "L" ~ ~ JUD--3
--
CHRISTINE L. SHERIFF,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANlA
vs.
97-6837
CNIL ACTION LAW
MARK W. RUMMEL
Defendant
IN CUSTODY
Prior Judge: Edgar B. Bayley
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCED URE 1915.3-8, 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
CURRENTLY IN CUSTODY OF
Christian T. Sheriff
May 14, 1997
Mother
2. A Conciliation Conference was held on December 4, 2003, with the following individuals in
attendance: The Mother, Christine L. Sherriff, with her counsel, Dirk E. Berry, Esquire, and the Father,
Mark W. Rummel, and his counsel, Jeanne B. Costopoulos, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Date
Ql.O....,. 61-1 S>-:).{)O ~.
o~
Dawn S. Sunday, Esquire
Custody Conciliator
EXHIBIT B
.;.
-P"/
RECEIVED MAY 2 7 2Oll.5~
..
CHRISTINE L. SHERlFF
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
97-6837
CNIL ACTION LAW
MARK W. RUMMEL
Defendant
IN CUSTODY
ORDER OF COURT
1. The prior Order of this Court dated December 15, 2003, shall continue in effect as modified
by this Order.
, 2005, upon
is ordered and directed as follows:
AND NOW, this 31 day of
consideration of the attached Custody Conciliation Report, .
2. In the event either party is unavailable to provide care for the Child during his or her period
of custody for an overnight period or a period in excess of eight hours, that party shall first contact the
other parent to offer the opportunity to provide care for the Child during the period of unavailability
before contacting third party caregivers.
3. The parties shall adjust the alternating weekend schedule to ensure that the Mother has
custody of the Child during the Father's military drill weekends and the Father has make-up weekend
periods of custody in exchange.
4. The parties shall cooperate in scheduling extensive liberal periods of custody for the Father
during his periods of military leave when the Father is deployed or in training.
5. The Mother, Father and Father's girlfriend shall participate in counseling with a professional
selected by agreement between the parties. The purpose of the counseling shall be to address concerns
which have arisen with regard to the ability to cooperate and maintain civility in order to promote the
Child's interests.
6. The Mother's Day holiday period of custody shall take precedence over the Child's birthday
period of custody. '
7. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions ofthis Order by mutual consent. In the absence of
mutual consent, the terms ofthis Order shall control.
BY THE COURT,
cc: Dirk E. Berry, Esquire - Counsel for Mother
Jeanne B. Costopoulos, Esquire - Counsel for Father
,
TRUE COpy FROM RECORD
In Testimony whereof, I hefe unto set my hand
;nd the..~~t. aid coou;~..~:..~~rliS~'.:8~. . <;)..5
. .. ..... .. '" . .... . ~
othonotary
CHRISTINE L SHERIFF
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
97-6837
CIVIL ACTION LAW
MARK W. RUMMEL
Defendant
IN CUSTODY
Prior Judge: Edgar B. Bayley
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report;
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Christian T. Sheriff
May 14, 1997
Mother
2. A conciliation conference was held on May 25, 2005, with the following individuals in
attendance: The Mother, Christine L. Sheriff, with her counsel, Dirk E. Berry, Esquire, and the Father,
Mark W. Rummel, with his counsel, Jeanne B. Costopoulos, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Dat~
J-Ct d('){l')'
,
iJJ~
- -
- ~ ~
Dawn S. Sunday, Esquire '
Custody Conciliator
West Shore (717) 790-9546
East Shore (717) 221-0900
JEANNE B. COSTOPOULOS, ESQUIRE
The Executive Offices at Rossmoyne
5000 Ritter Road, Suite 202
Mechanicsburg, PA 17055-6922
E-mail: jbclega/@lloLcom
Facsimile: (717) 790-6019
May 27, 2005
Dirk Berry, Esquire
44 S. Hanover Street
Carlisle, PA 17013
VIA FACSIMILE NO. 243-1447 - HARD COPY WILL NOT FOLLOW
Re: Christine L. Sheriffv. Mark W. Rummel; Custody No. 97-6837
Dear Dirk:
The following counselors are hereby suggested by my client to perform the
counseling set forth in the new order:
Christine M. Piety, 551 S. Hanover Street, Carlisle, 241-4207
Deborah L. Snelson, 2 Tyler Court, Carlisle, 249-1033
Please advise at your earliest convenience if either of these people would be
acceptable to your client.
My client is also requesting that the current schedule be flip-flopped during the
summer months (from the day after school is out until a week before school resumes)
such that my client has primary custody and your client has alternating weekends and
Tuesday evenings throughout the summer months. Since the babysitting provision would
still be in effect, your client would also spend each day with the child while my client is
at work. This would maximize my client's time with the child prior to his being gone due
to his military obligations. My client is also requesting a provision be added to the order
providing for my client's family to take the child with them to my client's basic training
graduation ceremony.
Please advise as to your client's position regarding by June 2, 2005. If an
agreement cannot be reached, I plan to file a petition for special relief on June 3, 2005 so
the court can address the situation.
cc:
Mark Rummel
~
eanne B. Costopoulos, EsqUire-
~t.P
,-
- J
~ ~
~ ~
~
(') "'"
C::~ ~
C =
~<; <J<
~"f'f; <-- :r!
s;."'" c:: rn~
._'.rl :or.:
"7"--- I ::g.
~~~ ':'=': CT' ~~("j
r.< CJ -r "r.
::;~ r-.' ". G:!.l
-
z..! -- ,,0
'/:.::- c} 9 c5rn
:Pc __1
-.7 .""
~ ..., ':0
0 '-<
CHRISTINE L. SHERIFF
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
97-6837
CIVIL ACTION LAW
MARK W. RUMMEL
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Wednesday, June 08, 2005
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq.
at 39 West Main Street, Mechanicsburg, PA 17055 on Friday, June 24, 2005
, the conciliator,
at 9:00 AM
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 penn anent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: /s/
Dawn S. Sunday, Esq.
Custody Conciliator
--Y
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 THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HA VE 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
~.~ ~ ~ ~;; 5o'fr~
~F~~~So6'9
~ ~p-~~P05l/~"o/
\1; !\J \//\1)., s: r'-"! r,} -~ ( j
I I i\tr:nr'I"-' ,;::;-,""^'nl'"\
I\.W ~ 1'..1,. _ !'._"i'-Y"~l Iv
8 Z :2 Hd 6- Nnr soaz
AuV10hlCiillOtld 3Hl :10
30U:iO-0311:l
CHRISTINE L. SHERIFF,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
MARK W. RUMMEL,
DEFENDANT
97-6837 CIVIL TERM
ORDER OF COURT
AND NOW, this --6:::l=--day of June, 2005, the petition of Mark W.
Rummel to treat the current petition to modify the summer custody schedule will not be
dealt with on an emergency basis. This petition is referred to conciliator Dawn S.
Sunday, Esquire, for an expedited review.
By the/ Court,
/".
A.~./1. I IJJqIO~
Dirk Berry, Esquire . ~ ,,,...,...l.!.Ld
For Plaintiff
Jeanne B. Costopoulos, Esquire - CbptJ ~~.1 u/q ItS
For Defendant
-'\
~
Dawn S. Sunday, Esquire
Custody Conciliator
Court Administrator
:sal
\:;';:~\\':"/~! .,~\(~\~r-'J'~! ~.~
I Il\ +(,\;:.,,'.." ; I: ;,~,:,':: ~~:\~::l\In"
i\~.tj \;, (\..)...~\ ,<' ~-'!- ~ :.' '~l IV
S (; :2 h!d 6- !lOr soal
H!\W'"jh,!U"'.'" I J (\l,J.J ::111 :10
/\U ~ _..\jl, j L:..,j\.,.Jd -J"1
3JU~O-03l::l
RECEIVED JUN 2920051
d---
,
CHRISTINE L. SHERIFF
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
97-6837
CNIL ACTION LAW
MARK W. RUMMEL
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this 5 tL day of
consideration of the attached Custody Conciliation Rep rt, it is
, 2005, upon
rdered and directed as follows:
1. A Hearing is scheduled in Court Room No. 'J.. of the Cumberland County
Courthouse on the 'Jd- day of ~ ,2005, at ~ ill o'c1ock~. m., at which
time testimony will be taken. For purp ses 0 the hearing, the Fa1:hdr, Mark W. Rummel, shall be
deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties shall
file with the Court and opposing counsel a memorandum setting forth each party's position on custody,
a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated
testimony of each witness. These memoranda shall be filed at least ten days prior to the hearing date.
2. Within ten days of the date ofthis Order, the parties shall select the counselor pursuant to
Provision 5 of the May 31, 2005 Order and within the same time period, shall contact the selected
counselor's office to schedule the initial counseling session. Th,:re shall be a minimum of at least two
counseling sessions.
J.
cc: Jeanne B. Costopoulos, Esquire - Counsel for Father
Dirk E. Berry, Esquire - Counsel for Mother
~u4 ~ 7- p,S:tJS
q.....
rk
'5
~5
~\
~~
'6
r-
("')
f2
!i
I,{)
I
~
......,
~
~
~
7-
::::>.0:
~;:!z
"..J .6:.
::.:.1:::-"-
'!~
JZ
_~::_'2:'
~..ii~
~
-0
CHRISTINE L SHERIFF
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
97-6837
CIVIL ACTION LAW
MARK W. RUMMEL
Defendant
IN CUSTODY
Prior Judge: Edgar B. Bayley
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Christian T. Sheriff
May 14, 1997
Mother
2. A conciliation conference was held on June 24, 2005, with the following individuals in
attendance: The Mother, Christine L. Sheriff, with her counsel, Dirk E. Berry, Esquire, and the Father,
Mark W. Rummel, with his counsel, Jeanne B. Costopoulos, Esquire.
3. This Court previously entered an Order in this matter on December 15, 2003, under which
the Mother has primary physical custody of the Child and the Father has partial custody on alternating
weekends and Tuesday evenings. An additional Order was entered recently on May 31, 2005
following a conciliation conference which provided modifications to the Order in light of the Father's
upcoming military training, and also included counseling and a right of first refusal in the event of
unavailability of one of the parents.
4. The Father filed this Petition for Modification seeking substantially increased custodial time
with the Child in July and August 2005 prior to the Father's scheduled departure for military training.
In his petition, the Father also sought to address issues regarding his military graduation ceremony and
the counseling provided in the May 2005 Order.
5. The parties were able to resolve the counseling issues, However, as the Father was seeking a
complete reversal of the custodial schedule so that he would have primary custody and the Mother
would have partial custody during July and August and the Mother's willingness to adjust the schedule
was limited to an additional evening during alternating weeks, no agreement was finalized at the
conference and it will be necessary to schedule a hearing.
6. The Father's position on custody is as follows: The Father indicated that he will be leaving
the area for approximately seventeen weeks of basic military training in mid-September and therefore
requested that his periods of custody with the Child be substantially expanded in July and August 2005
prior to his departure. Specifically, the Father seeks primary custody of the Child during that time with
periods of weekend custody during alternating weeks for the Mother in addition to her one week of
vacation. The Father believes that it is important that he have the opportunity to spend this additional
time with the Child in light of his upcoming extended absence from the area during which he feels he
will have very limited contact. The Father indicated that the Child does well and is happy during his
periods of custody with the Father and often wants to stay at the end of those periods. On the
graduation issue, the Father proposes that his parents be permitted to bring the Child to Arizona for the
ceremony after which the Father would be available to provide care for the Child.
7. The Mother's position on custody is as follows: The: Mother does not believe it would be
best for the Child to change the custody schedule during the two months before the Father's departure
for military training. According to the Mother, the Child has expressed a strong preference to be in the
Mother's custody, where he has friends to play with during the day. The Mother expressed concern, as
she had in the prior conference, that the Father leaves the Child with the Father's parents during much
of the Father's periods of custody and does not take advantage of the time he currently has with the
Child. The Mother expressed a desire to accompany the Child to Arizona for the graduation ceremony,
after which she would transfer custody to the Father.
8. The conciliator submits an Order in the form as attached scheduling a hearing to address the
issues of the custody schedule for the months of July and Augu.st 2005 and also the arrangements for
the Father's military graduation ceremony in November. Counsel requested that at least four hours be
allotted for the scheduling of the hearing. It is also requested that the hearing be expedited due to the
immediate nature of the Father's request for additional periods of custody.
,I.JY1 t::.
Date
.;) 7 rioo S
,
~L4
Dawn S. Sunday, Esquire
Custody Conciliator
CHRISTINE L. SHERIFF,
PLAINTIFF
V.
MARK W. RUMMEL,
DEFENDANT
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
97 -6837 CIVIL TERM
ORDER OF COURT
AND NOW, this
~
day of July, 2005, IT IS ORDERED:
(1) The prior custody order shall continue in effect as modified by this order for
the summer of 2005.
(2) Between July 10, 2005 and August 21, 2005, the father shall have Christian.
His mother shall have him on alternating weekends starting on Friday, July 22nd, from
Fridays at 6:00 p.m. through Sundays at 6:30 p.m., and every Tuesday from 6:00 p.m.
until 8:30 p.m.
(3) Christian shall be with his father at Ft. Jackson, South Carolina, when he
graduates from basic training, and for such period that he is on leave before proceeding
to a duty station in Arizona. The mother may take Christian to South Carolina, deliver
him to the paternal grandmother and pick him up from the paternal grandmother. If the
mother does not choose to take Christian to South Carolina for this purpose, he shall be
taken there by his paternal grandmother.
/'
By "Cc)~rt,
(l
Edgar B.
/
~l\\\\,,;C.t',
f'j,.." ....
,.",,~',';i'~C{)
o~ : \ \\tl g- \\\\ ~Q~'1.
~)jri\Cii';Q\:.J.(j:;\d '3\-\i. ?O '
. - ;;)\j:\(rC\j\\:~
-'
..
-
"
"
..
-
.
CHRISTINE L SHERIFF,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
MARK W. RUMMEL,
DEFENDANT
"17-
: ~-6837 CIVIL TERM
ORDER OF COURT
~
AND NOW, this ~day of December, 2005, the father, Mark W. Rummel, is
granted visitation with Christian 1. Sheriff, born May 17, 1997, effective after school
Monday, December 19, 2005 through Monday, January 2, 2006, at 4:00 p.m. Mother
shall have the child Christmas Day at noon until December 26, 2005 at noon.
It shall be father's responsibility to get the child to and from school during his
periods of visitation.
~"~
~/ /
B~.l~urt, /.;/
I' ~
~'~~
Dirk Berry, Esquire
For Plaintiff
t
Edgar B. Bayley, J.
Jeanne B. Costopoulos, Esquire
For Defendant
:sal
L-
,cP
\~ \ \..0
t'
,':J
..0
-------
------