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HomeMy WebLinkAbout03-0777KRYSTINE A. MUNDIS, PLAINTIFF, V. DALE C. MUNDIS, DEFENDANT. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO: 0~ 777 CIVIL : IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, Krystine A. Mundis, by and through her attomeys, Irwin, McKnight and Hughes, Esquires and files this Petition for Custody, making the following statement: 1. The Plaintiff in this action is Krystine A. Mundis, an adult individual residing at 236 McKnight Street, Carlisle, Pennsylvania 17013. 2. The Defendant in this action is Dale C. Mundis, an adult individual residing at 428 North East Street, Carlisle, Pennsylvania 17013. 3. The parties were married on June 1, 1991, and one child was bom of this marriage: Sullivan H. Mundis, bom March 8, 1998. 4. The parties separated on August 15, 2001 and divorced on January 29, 2003. 5. The parties reside in Cumberland County, Pennsylvania. 6. The Plaintiff avers and therefore believes that the best interest of the child would be served if she is granted primary physical custody with periods of partial physical custody to the Defendant. WHEREFORE, the Plaintiff, Krystine A. Mundis, respectfully requests that this Honorable Court grant primary physical custody of the parties' minor child to Plaintiff, with periods of partial physical custody to the Defendant. Respectfully submitted, IRWIN, McKNIGHT & HUGHES B y: .~~~~ 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Attorney for Plaintiff Krystine A. Mundis Date: February ~ I , 2003 VERIFICATION The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: February 21 ,2003 KRYSTINE A. MUNDIS, PLAINTIFF, Ve DALE C. MUNDIS, DEFENDANT. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO: CIVIL : : IN CUSTODY CERTIFICATE OF SERVICE I the undersigned hereby certify that on thisc~/c'5'4-day of February, 2003, a copy of the foregoing document was served by first-class, postage prepaid United States mail in Carlisle, Pennsylvania upon the following: Dale C. Mundis 428 North East Street Carlisle, PA 17013 ~ .~.IRWIN, McKNIGHT & HUGHES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRYSTINE A. MUNDIS, : Plaintiff : CIVIL ACTION - LAW : v. : IN CUSTODY : DALE C. MUNDIS, : No. 03-777 Defendant : TO THE PROTHONOTARY: Please enter my appearance on behalf of the Defendant, Dale C. Mundis, in the above- captioned matter. Date: HANFT & KNIGHT, P.C. Attorney I.D. No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorneys for Plaintiff F:\User Folder~Firm Docs\Gendocs2003X307 l- 1.prae.wlx:i KRYSTINE A. MUNDIS PLAINTIFF DALE C. MUNDIS DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-777 CIVIL ACTION LAW IN' CUSTODY ORDER OF COURT AND NOW, Thursday, February 27, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, March 21, 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 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. 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/ I-Iubert X. Gilroy, Esq. La Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business befi)re 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 ItELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 170 l 3 Telephone (717) 249-3166 KRYSTINE A. MUNDIS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : V : DALE C. MUNDIS, : Defendant : CIVIL ACTION - LAW NO. 03 - 0777 CIVIL IN CUSTODY' COURT ORDER AND NOW, this ~ day of March, 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The Mother, Krystine A. Mundis, and the Father, Dale C. Mundis, shall enjoy shared legal custody of Sullivan H. Mundis, born March 8, 1998. 2. The Mother shall enjoy primary physical custody of the minor child. e The Father shall enjoy periods of temporary physical custody of the minor child as follows: On alternating weekends from Friday evening at 4:30 p.m. until Monday morning when he shall deliver Sullivan to Mother, daycare, or school as the parties agree. On the Thursday following Father's weekend during the evening from 4:30 p.m. until 7:00 p.m. Following Mother's weekend on Monday and Wednesday evening from 4:30 p.m. until 7:00 p.m. D. At such other times as agreed upon by the parties. e The parties shall proceed with their existing arrangement on sharing holidays and also accommodating each other for vacation time with Sullivan as appropriate. Both parties shall enjoy reasonable telephone contact with the minor child when he is in the custody of the other parent. 0 The parties may modify this order by agreement of the parties. Absent any agreement between the parties, the terms of this order shall control. In the event either party desires to modify this order, that party may petition the court to have the case again scheduled for a custody conciliation conference with the conciliator. CC: Rebecca R. Hughes, Esquire Michael J. Hanft, Esquire Je KRYSTINE A. MUNDIS, Plaintiff V DALE C. MUNDIS, Defendant Prior Judge: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03 - 0777 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the child who is the subject of this litigation is as follows: Sullivan H. Mundis, born March 8, 1998. 2. A Conciliation Conference was held on March 21, 2003, with the following individuals in attendance: The Mother, Krystine A. Mundis, with her counsel, Rebecca R. Hughes, Esquire; and the Father, Dale C. Mundis, with his counsel, Michael J. Hanft, Esquire. The parties agree to the entry of an order in the form as attached. Hubert X. Gilroy, E~s ire Custody Conciliator/ !