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Home My WebLink About98-00967 '+. ... " ~ ~ ~ VI >- VI o ':lo! ~ '- / r { ~ ~ -.. . . .') - '-.J d ~ ...., 0- , 0.. 0-- , ~ .," P 425 99D 917 Postage CcrtlliedFoll Spetial Dolivory FOD ltl Roslric1od Oe~...ory Foe cY. ~ g: Return Roceipt Showing 10 I - Whom & Dllto Dollvorttd . 0 "&. RtIum Rtct1Pl Showf1lJ 10 . '-.. ~ Dale, & Mhsste's ''':1 J,J: ,,;,', g TOTALP'Slag.ll~;"'~ ,$ ,:"7:~ CO '..... IJ. ..-, J M Postmar1o;, or Oillt\. i' '1;:.10.-' ", ;". E .' >;l , o ~'i ~ ,,', ~', u. _, (,:," ~ 1,:;., " .~ . .\, '.,' . '," :-8 '- ," \I I~ Ie 10 I) I.!! ,'" I~ I , I I DR: _Compleleltems 1 andlor 2 for additional HMcel. leomplstlllems 3. 48, and "b. .Pdnt your name and address on the ,ave,... 01 Ihlllorm 10 thai we can return this card to you, _Attach lhl,'onn to the rront 01 the mallplece. Of on the back If 'Pace doH not porm', _Writ,'Rerum Recti/PI Requested" on the mailpllce bMow tht article _The Rltum Receipt Mil show 10 whom the artlde w.. dellY,red and the d delivered. I also wish to receive the following ..Nlces (for en extra fee): _1,-0, 2, 3, ArIlcle Addressed to: cUZA./J/::711 !9pAl 'J?U~fJtne. T liZ-I. -;T?JAJA Y/J./..A- RVE OAmP ;I IU- PIf 17011 Restricted Delivery suit poslmester for fee, 4e. ArIlcle Number p 9'd/5990 9" 4b, SeNlce Type o Registered p( Cerllfted o Expre.. Mell 0 Insured o Rslum Rscelptfor Merchandse 0 COD 7, Oat at 0 Ivery , I I , I ~ ,=> o .. .!! 5, Received By: (Print Name) B, Are.. e's Addre.. (Only /I roque.tad end feels paid) B, Sign X Domestic Return Receipt i ci- J E S: {: ai Ii .... !! , . . . .' .... I:> ~ f'r V) .' Z t..- S~ :::l (" Q~ tll,.'- ( ~i"" p.' , " '.r ,. () :. @:(:, '/l I .' 0:\':': t_, ',; <l 1:"- r;', -- u.. C,""J ~ :) <.:.1 t:.... U ,.... ';~ I' DONALD WAYNE MIKOS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. ELIZABETH ANN RUPPERT, Defendant NO. 98-967 CIVIL TERM IN RE: PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 25th day of February, 1998, upon review of the attached petition for special relief and upon agreement of the parties as indicated here in open court, it is ordered and decreed that Donald Wayne Mikos shall have temporary primary physical custody of the parties' daughter, Katie Nicole Ruppert, born August 18, 1997, pending the conciliation conference to be scheduled in this matter. Mother shall have supervised periods of temporary physical custody as arranged through Cumberland County Children and Youth Services. By the court, ~~ Edward E. Guido, J. Robert P. Kline, Esquire For the Plaintiff ~ (Y"'-lL<-Q,.( :.1/:;'7/ qK , xS,6'. Elizabeth Ann R~~pc~c Pro Se :1fh . ,~.':: ,.1 . "'. ' ;"r -. ," ,J 1" r.' : '- .. " "f "ll" . I' .qj t'.. I ( \j"~ ...tJ t ;1 .~, .) ,- I - "'" . " "J ).":/11 _,' 1_ . _..:_ .1 .~ ....~;:)~~:5. ;JJ"i:J '.9" , I I, .\( ( \ I, ,~ VI' . I . I . ,,~^lof\~. ,if I !' i".... '\' .- ... '~\ .... ~i-~ ".~., "I' 4,J\ DONALD WAYNE MIKOS, Plaintill' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs, NO, qca - ql.!.''7 CIVIL TERM I ELIZABETH ANN RUPPERT, Defendant CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW. this ,.:)l.\ day of \=C\~JC\"'-1 .' 1998, upon consideration of the attached Complaint. it is hereby directed that the parties and their respective c~unsel appear, before t""'n\r-...X"'\'~ ' ,~~,\C\,\ I E':;(\ .. the conciliator, at ,~), NrMl ~'\ H\ch:'x'\\\.~,;,\ P on the _-d1.Q day of \'-'\C\ C( \, , 1998, at q; r 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 THE COURT, By:d!SfiBJJ'L4LsA.ULOCbJ,,\ I(..\~ ' Custody Conciliator (Th~ U TIle Court of Common Pleas of Cumberland County is required by law to 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, 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 OF! ' ' -- -.., TO FIND OUT WHERE YOU CAN GET LEGAL HELP. PLE;;'S~ P/:;C'L J~) -C? C'L.. , ,). C --:CIa llberland County Bar Association 2 Liberty ^ venue Carlisle, Pennsylvania 17013 (717) 249-3166 6. 'Ole nnturnl mother of the child is E1iznbeth Ann Ruppert, currently residing nt the nbove-stnted nddress. 7. TIlc nnturnl fnthcr of thc child is Donuld Wuyne Mikos, currcntly residing nt the nbove-stuted nddress, 8. TIle relntionship of the PlaintilTto the child is that ofnaturnl father, 9. The relationship of the Defendant to the child is that of natural mother. 10, TIle Plaintiff has not participated as a party or in any other capacity, in other litigation concerning the custody of the child in this or any other court, II. PlaintilThas no infonnation of a custody proceeding concerning the child pending in a court of this Commonwealth, 12, The best interests and pernmnent welfare of the child will be served by granting the relief requested because the PlaintilT has the means and ability to provide adequate care and a good home for his daughter, while the Defendant has demonstrated in the six months since the child's birth that she is unable to provide for the child's basic needs, 13. Each parent whose parental rights to the child have not been tenninated and the person who has physical custody of the child have been named as parties to this action. No other persons are known to have or claim to have any right to custody or visitation of the child other than the parties to this action, I" WHEREFORE, PlaintifTrequests your Honorable Courlto grant primary physical custody of Katie Nicole Ruppert to her father, Donald Wayne Mikos, the PlaintifTherein, Respectfully submitted, Iq Fef3 l<t't 2 Date r\~~ ROBERT PETER KLINE, ESQUIRE 331 Bridge Street, Suite 350 Post Office Box 461 New Cumberland, P A 17070-0461 (717) 770-2540 Attorney for Plaintiff / I , I j .. I , , l { VERIFICATION I verify thnt the stntements mnde in the foregoing Custody Complaint arc true and correct. I understand thnt false statements made herein arc subject to the penlllties of 18 PA C.S. 4904 relating to unsworn flllsification to authorities, d, //rlr? Date ~ 1lv. ~_ DONALD WA YN~OS '- ~; Ir; u: .~ , 1- .'.-1:': luf;.1 ~J:~: l.).":;~ :1: [Eu .' .l-~c ~'" r:~;;:~ F ~O Cl ~..'tn I,N 'l;;':~ utr c--J ".'-7 ~l!: c::_~ h-l(O , ?-.:: LJJ r:no.. to.. .:... IJ_ ce ::> 0 VI U '"" RODEItT I-ETEIt IiI,INI~ Atlorney & Counsellor at Law 331 Bridge Street, Sulle 350 Post Olllce Box 461 New Cumberlend, Pennsylvania 17070.0461 (717) 770-2540 (717) 243.5940 fax (717) 770-2553 February 25. 1998 Ms, Elizabeth Ann Ruppert 1126 Ranavilla Avenue Camp Hill. PA 1701 I >- c.. o o Re: Donald Wayne Mikos v. Elizabeth Ann Ruppert Cumberland County No, 98-967 Civil Tcrm Dear Ms, Ruppert: As directed by Judge Guido at Wednesday's hearing, the following is the address and telephone number for Legal Services, Inc.: Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 or (717) 766-8475 In the event that Lcgal Services is unable to help you, the Cumberland County Bar Association has a Lawyer Referral Service and can bc reached at (717) 249-3166. Very truly yours. ROBERT PETER KLINE, ESQUIRE RPK/srf cc: Donald W. Mikos Hon, Edward E, Guido '~' " , ~",.~.' 'if , '0' .,l. '. . . ,~. '(. ,\, r ' - 'I ....4, ... ~~. 'l ' ' ~. ~... . ': ~1'... - /~. ..I ," ~ ,'" "r .,~; ~"J " .., '. -r'",'-"" . ,,~ "', .'1 ~~ . '.J'.,' ~;; . , , , .' " .~ ~.... " . " - " " ,', ' ,.:; ~.~ . , " ( .'tI \t, ", ,"'j, . > " . J ) , oj ~~~, '~... ,'" ,,', '~ ,. \).. .' I ; ! , , . , .,;. .> '" . (' " ," . ,t ',_ I.... . ,.,. J ~ Cl ~: :;;: Co 1,.- 0 ':5,_ Ulr:~ c..V.,: (:,.) ~~; p,::C. :.r= '..1;', ., .r;: -' I.,.... ::;!:;-~ ~r ("-. , . :lC: (") ~ ;;,.. '::lL., N .J :.~~ .-,- -.... -11.1 C::l il::tU U::T U~ r.:: U_ ~\! u.. u.. ~: 0 r/) =) 0' U " , E, TIle mother has allowed the child to reside in a home without heat due to lack of heating oil from time to time, , " >; j 5. Despite the intervention and involvement of Cumberland County Children and Youth Services, the Escape Center, and nurses from the child's pediatrician's office, mother has been unable to rectii)' the problems raised in the paragraphs above and continues to be incapable of providing for the basic needs of the child, In addition, mother has refused offers of additional ~ assistance from these and other agencies, 6. The child's pediatrician, Christina Condon, M,D., has expressed to both the natural father and to his counsel her concerns regarding the care of the child, In addition, at the child's last examination, on February 17, 1998, Dr. Condon indicated to the Petitioner that she had never seen Katie looking that well, On February 17, 1998, Petitioner had had continuous custody of his . ,\ , I daughter since February II, 1998, his longest period oftime exclusively with his daughter to date, j , 7. Based upon the natural mother's inadequacies, the Petitioner has legitimate concerns regarding the health and well-being of his child should she be placed in the custody of the natural mother, 8. Petitioner, with the assistance of his parents with whom he resides, has the means and WHEREFORE, Petitioner, Donald Wayne Mikos, respectfully requests that this honorable ability to provide more than adequate care for his daughter. court enter an order granting to him temporary primary physical custody of his daughter, Katie Nicole I t , Ruppert, pending the custody conciliation conference to be scheduled in this matter, Respectfully submitted, 19 Fee, l'1.'t~ Date r \!Q t y 14 Q . _ ROBERT PETER KLINE, ESQUIRE 331 Bridge Street, Suite 350 Post Office Box 461 New Cumberland, PA 17070-0461 (717) 770-2540 Attorney for Petitioner i. II 6, TIle natural mother of the child is ElizlIbeth Ann Ruppert, currently residing at the above-stated address. 7. TIle natural father of the child is Donald WlIyne Mikos, currently residing at the above-stated address, 8. TIle relationship of the Plaintiff to the child is that of natural father. 9. TIle relationship of the Defendant to the child is that of natural mother. 10. TIle Plaintiff has not participated as a party or in any other capacity, in other litigation concerning the custody of the child in this or any other court, II. Plaintiff has no infonnation ofa custody proceeding concerning the child pending in a court of this Commonwealth. 12. The best interests and pennanent welfare of the child will be served by granting the relief requested because the Plaintiff has the means and ability to provide adequate care and a good home for his daughter, while the Defendant has demonstrated in the six months since the child's birth that she is unable to provide for the child's basic needs, 13. Each parent whose parental rights to the child have not been tenninated and the person who has physical custody of the child have been named as parties to this action. No other persons are known to have or claim to have any right to custody or visitation of the child other than the parties to this action. VERIFICATION 'I.! f' L It, ,/ ,I '/" tf. , I I verify that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 PA C.S. 4904 relating to unsworn falsification to authorities, J. //7 h? Date ~ 12v. ~~ DONALD WA ~OS ~ ~ C"l (:; u~ , .;t ,- '() .. ;:"3 ~~~~ - u.'~~' - ()"'> ~(..,) ;r:: :.- \:t'J .-:: ():'j ~t:, "j" ,4 C' ~,:'jJ1 t ~. ..:,) :.".1 ~';.; i.l~'- I.- _ "'"~ ~L\J r(J ~1, H.U ~: 1.1.1 ~'!JU- \,... - ,'. Ll- (('J ';:) 0 lJ' U ~~ ~~ .... I'j - rj -i J ~ DONALD WAYNE MIKOS, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMOERLAND COUNTY, PENNSYLVANIA vs. : NO. 98-967 CIVIL TERM ELIZABETH ANN RUPPERT, Defendant : CIVIL ACTION - LAW IN CUSroDY . . PRIOO JUDGE: Edward E. Guido CUSTODY CXH:ILIATIOO SlHIARY REPORT IN AccnmANCE WITH CDlBERLANO camy RULE OF CIVIL PROCEIXJRE 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 Katie Nicole Ruppert August 18, 1997 Father 2. A Conciliation Conference was held on March 31, 1998, with the following individuals in attendance: The Father, Donald Wayne Mikos, with his counsel, Robert P. Kline, Esquire, and the Mother, Elizabeth A. Ruppert, with her counsel, Mark W. Allshouse, Esquire. 3. The parties agreed to entry of an Order in the form as attached. fJpf','/ / /91J- Date [Q.<L~ Dawn s. Sunday, Esqulre Custody Conciliator