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Home My WebLink About01-1431 FX I , ';"''''''''-<'"_~~_cl;M:;_ KRISTIN MUNDORF, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. S 2001 - ~I Ci,,~l~ MICHAEL DUPLER and HAZEL and KENNETH DUPLER, Defendants CIVIL ACTION - LAW CHILD 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 , Esquire, the 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 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 the entry of a temporary or permanent order. FOR THE COURT: Date By Custody Conciliator 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 At 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 ccmference 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, Pennsylvania 17013 (717) 249-3166 1 ~.' -. .~~_.,.,J, M' ~ ...,," ~ " "-~<"'~~t-;"" KRISTIN MUNDORF, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. , 2001..,.. J '/3J MICHAEL DUPLER and HAZEL and KENNETH DUPLER, Defendants CIVIL ACTION - LAW CHILD CUSTODY CUSTODY COMPLAINT 1. The plaintiff is Kristin Mundorf, residing at 1 Boeing Road, Apt. 3, New Cumberland, York County, PA 17070. 2. The first-named defendant is Michael Dupler, residing at 420 Market Street, New Cumberland, Cumberland County, PA 17070. 3. The second-named defendant~ are Hazel and Kenneth Dupler, residing at 426 Market Street, New Cumberland, Cumberland County, PA 17070. 4. Plaintiff seeks custody of the fOllowing child: Amber Rose Dupler, whose date of birth is August 2, 1994, and who presently resides at 426 Market Street, New Cumberland, PA 17070. The child was born out of wedlock. The child is presently in the custody of the Defendants, Hazel and Kenneth Dupler, who reside at 426 Market Street, New Cumberland, PA. The child has lived with the following people at the fOllowing addresses for the periods indicated: Names Hazel Dupler Kenneth Dupler James Daren as above, also with Plaintiff Address 426 Market Street New Cumberland, PA Dates 4/2000 - present as above birth - 4/2000 -... ~~~- ,I , ,J- '. -- -"~--',,,,,~*,,,_: The mother of the child is Kristin Mundorf, who currently resides at 1 Boeing Road, Apt. 3, New Cumberland, PA. She is married. The father of the child is Michael Dupler, who resides at 420 Market Street, New Cumberland, PA. He is not married. 5. The relationship of the Plaintiff to the child is that of mother. The Plaintiff currently resides with the following persons: Name Relationship Douglas Mundorf husband 6. The relationship of the first named Defendant to the child is that of father. The first named Defendant currently resides with the following persons: Name none known 7. The relationship of the second named Defendants to the child is that of paternal grandparents. The second named Defendants currently reside with the following persons: Relationship Name Relationship James Daron Hazel's brother Amber Rose Dupler granddaughter 8. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or any other court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 2 i ~, ~-' >..... - ~~ "~~"'.<- " . 9. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff, until her marriage in April, 2000, was the child's primary caretaker and has continued to play an active role in her life on a daily basis. The child remained in her grandparents' home in order to finish the school year. Plaintiff believes that it would serve the child's best interest to reside with her mother. 10. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, pursuant to the Custody Act, 23 Pa.C.S. 95301 et sea., Plaintiff requests the court to grant her custody of the children. RESPECTFULLY SUBMITTED: '5/& lur Date ( ci~,~ Cindy L. se , Esquire Attorney o. 75899 4810 Derry Street Harrisburg, PA 17111 PHONE (717) 564-1084 FAX (717) 564-5158 - Attorney for Plaintiff 3 .... ;;~"=~"-'"' " '" ~,,l . i ~ "I "~~~ _J - O~".""'~. '-~ ~~<i VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. 3)(,'/61 Date -l~.=-r- l" ,.~~ Kristin Mundorf ' , 4 1 il1~B~~~"jg'~~~~-::;li,jlfuj:h'~';';j;~J;-,~~~!>l\'~~~~- ' .' .to .- ~~ ~'-'~""""'~luliii.il~'11 j- ,'",,,. _.' -._:",~'.I' - ,- - ,~,.,-,,-<"-< -. - ~ . ,-~ " ; ~ -w.. ~ ......, () 9 0 I "'- V' c,) 0 0 0 D. c: -I: :t .,. :g 0 -oti; ::!3: :.:::! """ mm ,"'-' n~i~;? Z:J..J -- f! zr- =-q<n C> (j) ~~ !'.) , - ~~.- -<~ ~:~}~ ~CJ -0 ~O :x- s5;j ~t :p8 ':'? r=srn '- ~ ~ .,... ~ .r:- -< , '''';' ,.;. '. J "&<i.-"_~."" t; KRISTIN MUNDORF PLAINTIFF V. MICHAEL DUPLER AND HAZEL AND KENNETH DUPLER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA 01-1431 CIVILACTIONLAW IN CUSTODY ORDER OF COURT AND NOW, Monday, March 19, 2001 , 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, Mechanicsbnrg, PA 17055 on Thursday, April 19, 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 defme and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR TIlE COURT, By: /s/ Dawn S. Sunday. Esq.btJ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATIORNEY AT ONCE. IF YOU DO NOT HA VB AN ATIORNEY 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 ~~~,,*"'a"~~!)!i..Af.il!!f.ll'l~I~;;:ili.{i-:<!,j4<:d>'!&WIJ1f1~l~~j;:~i'~'J"L1'!ilii:~"1,"-,"!1ii~J,:~-""-~'-~- "~""t".'t~'ill!il:wiiij_ ~s W ~r $ ~n( t'aGJ ~$ ~~~ ~ ~,r- /jr:~~'Pl \fifWF' ' "^' ,\ f[\I'''''~A \ U\oi,t'Pd u. I : ',), ,) (;r\ <1'!"'U.:;";,"!l ," "'J'",Mn'"' .,,"',7hl v ~'-. ~- GU :7 i' ! (, H J 07'" \j'~, ( ,'v (1 if! 10 ..' ',-' ::"U .<~'~ii "~"-'- , ",--.I~ f ~j !1 Ii I' Ii II " i J i "''' /tJ- ?r [ /0 '}(". [' It? ~ f: . - I -, -~ ~--.~ k_. ,_,~ -", , ''"'''';''''(' ~ .. " ^ ," '... KRISTIN MUNDORF, : IN THE OJURT OF OJMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. : NO. 01-1431 CIVIL TERM . . MICHAEL DUPLER and HAZEL and : CIVIL ACTION - LAW KENNETH DUPLER, . . Defendant . IN CUSTODY . OODER OF <XXlRT AND ~, this ~ day of ~V"" , consideration of the attached CUstody Concilia ion Report, and directed as follows: , 2001, upon it is ordered 1. The Mother, Kristin Mundorf, and the Father, Michael Dupler, shall have shared legal custody of Amber Rose Dupler, born August 2, 1994. 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 her health, education and religion. 2. The parties shall equally share having physical custody of the Child with the specific schedule to be arranged by agreement of the parties to accommodate their work schedules. 3. The parties agree that the Child may also continue to reside with her Paternal grandparents, with the specific arrangements to be established by agreement of the parties. 4. The parties shall share or alternate having custody of the Child on holidays as arranged by agreement. 5. During the summer school break, each party shall be entitled to have custody of the Child for three weeks (consecutive or non-consecutive) upon providing at least 2 weeks advance notice to the other party. The party providing notice first under this provision shall be entitled to priority on his or her selection of vacation dates. 6. In the event either party intends to remove the Child from the Commonwealth of pennsylvania for an overnight period or longer, that party shall provide the other party with the address and telephone number where the Child can be contacted. 7. This Order is entered pursuant to an agreement of the parties at a CUstody Conciliation Conference. T/i1e parties may modify the provisions of this Order by llRltual consent. In the absence of llRltual consent, the terms ;,;~ A A ", ~,~ ., ~ l-l c,," ~ of this ~der shall control. cc: . ;"'_l,,,' "., A k~ Cindy L. Koser, Esquire - Counsel for Mother > . Michael Dupler, Father ~ Hazel and Kenneth Dupler, Paternal grandparent J. \ , ~ l?.).tS-O/ f ~~~~~d_~~~kB'1til&ii~1f}iJt~~'=--" 'l!i~,"~,1-~.u ri'r"~ ~c~ ~ ~ ~~cl 1J}~&1 Q\,W'\B3bV'~"8 11, I ~'l ~cl'q H\ \\):1) 1'10" " '.' -0 ("" ~;H'\ ....~, r \ \ \ "~l(- ~." .- \ ",,\.0\,\01"1)..'-"0' ;~\_\ ,,0 V..,,,,.o\ .\(1-\ ,:1 \1,' :J\.,JL~.. ' , .. ~'~jL~m&ill ,- .~ I ~, .. . "~ , , ,- ,-- "-" ^" -""1 , " 0.' ~, ,:" ;i< iltp' ... . KRISTIN MUNDORF, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . NO. 01-1431 CIVIL TERM . : MICHAEL DUPLER and HAZEL and : CIVIL ACTION - LAW KENNETH DUPLER, : Defendant . IN CUSTODY . CUS'l'ODY OCNCILIATIClII SUMMARY REPCRr IN ACCXlIDANCE WITH CUMBERLAND <XXlNTY 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 Amber Rose Dupler August 2, 1994 Mother/Father 2. A Conciliation Conference was held on April 19, 2001, with the following individuals in attendance: The Mother, Kristin Mundorf, with her counsel, Cindy F. Koser, Esquire, and the Father, Michael Dupler and the Paternal Grandmother, Hazel Dupler, who are not represented by counsel in this matter. 3. The parties agreed to entry of an Order in the form as attached. (fpJ c#/ A-/'X) I Date J1..,~ Dawn S. Sunday, Esquire Custody Conciliator