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Home My WebLink About01-2325 FX HAROLD RrNARD, plaintiff-Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V13. NO. 01-2325 ROBIN L. HINKLE, Defendant-Petitioner : CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, attached Complaint, it is respective counsel appear Conciliator, at hereby before upon consideration of the directed that the parties and their , the on 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 conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. The Court hereby directs the parties to furnish any an all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. For The Court, DATED: By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the American 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 "~'''V>''~~'f ~=. - =r'~~ ~\!c,.Gt:. 03/30 lO~_ 15:05 ~D:I_E(~~L SERVICc:s,irJc. F~)< :71 ?2Ll38CQS P~GE 2 G MidPenn Legal Services S Irvine Row, Cil.rliSI~, PA 1 iOl.1 Phune 717,2.:J-94(){) 1-/lO0-822-521l8 FAX 717,U,.H02b March 30, 2001 Thomas Gould Attorney-at-Law 2 East Main St Shirema.~slown. PA 17011 Dear Mr. Gould: We wish to refer a case involving Harold Rynard. He is a confli.ct for our of lice and is in need of assistance with a custody matter. There are two children, and there is an order which gives him visitation rights. He states the mother, Robin Hinkle (Rynard), is denying him contact. Our office, in conjunction with the Dickinson School of Law at Penn State University, is offering the student Pm 80710 program where student aulstants ate assigned to pro bono attorneys, If you accept this referral, a student assistant will be made available to you. Please let us kno" as soon as pllSslble If you can take this case and whether or not you wish to have a Jaw student assistant. Thank you for your cooperation in ma.lcing the pru borw system a success. Sincerely, MIDPENN LEGAL SERVICES ~'vI.i.., ~(Jp)(,1J-' Dru Hewitt Private Bar Coordinator DH:sw _II T ('I,.... , ;'f_:?'"" ~,_, _, _'.r ,,_ '",' "., ,."" '"~" ~ , - .,~ -~_..~,~ . , " HAROLD RYNARD, Petitioner IN THE COURT OF COMMON PLEAS CtJMBERLAND COUNTY, PENNSYLVANIA v. NO. 99-122 JUVENI~ 01- ~ U C,-,I.:( t~ CIVIL ACTION - LAW L CUSTODY ACTION ROBIN L. HINKLE, Respondent 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 , 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. Either party may bring the children who are the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. For the Court, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU DO NOT THE OFFICE SET CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 240-3166 > . HAROLD RYNARD, Petitioner IN THE COURT OF COMMON PLEAS CUMBERIAND COUNTY, PENNSYLVANIA v. NO. 99-122 .JUVENILE no 01, ;(3d$'~ f-t--, CIVIL ACTION - LAW CUSTODY ACTION ROBIN :10. HImcLE, Respondent PETITION TO MODIFY CUSTODY TO THE HONORABLE JUDGES OF SAJ:D COURT: 1. The Petitioner is Harold Rynard (Father) residing at 103 East Main Street, Apartment #2, Newville, Cumberland County, Pennsylvania 17241. 2. The Respondent is Robin L. Hinkle (Mother) who resides at 28 Lucinda Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. Peti tioner seeks to modify the Order of Court dated November 22, 1999, by granting him additional time with his son, Sean M. Rynard, date of birth 6/26/88, and limiting Mother's time with his other son, Peter J. Rynard, date of birth 1/11/87. A copy of the Order of Court is attached as exhibit A. 4. Since the November 22, 1999 Order, Mother has limited Father's contact with Sean and Father has limited Mother's contact with Peter. 5. Since February 2001, with prior notice to Mother, Peter has been residing in Maine with his adult cousins. A copy of the notice is attached as exhibit B. ~:''lJo"lll!l'I!!h~___?"" c,_,_.'''''-' ,r'_ "",P"'I-" .,,--'- , ' 6. The best interest of the children would be served by granting Father's request because: ao Father needs to have meaningful contact with Sean. b. Peter has emotional problems as a result of his contact with Mother. WHEREFORE, Plaintiff requests this Honorable Court to modify the November 22, 1999 order by increasing Father's contact with Sean and reducing Mother's contact with Peter. T ~ ~ ~ ~ n.;t- ~~ '^ ff~ A:< ~ AJu, ~P<A ~I ~ ~ ~ "" ,oPt) b~/\o fe+rrt>>vl -jlrJ"", L..,.".{ SeJ'v I Le-J , --rtw""", 0. ~W{ 4110/01 Respectfully submitted, ~u2l,~ Thomas D. Gould, Esquire Pro Bono Attorney ID #36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 VERIFICATION I, Harold Rynard, hereby certify that the foregoing PETITION TO MODIFY CUSTODY is 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. CoSo Section 4904 relating to unsworn falsification to authorities. DATED: (:;'0' ';._'~ .'. , ,~, ~'" _, ,,,,___,~ " -"'c~'" ." .' ,~ I!'II-',,, ~ _, .,,~ Harold R nard Plaintif !Petitioner ~~ /, IN THE COURT OF COMMON PLEAS OF CUMBER~~ COu~TY, PENNSYL~~~IA 99 -122 JlTvENILE IN THE ~~TTER OF PETER RYNP~D, born January 11, 1987 IN THE ~~TTER OF SEP~ RYN~~D, born June 26, 1988 ORDER OF COURT ~jD NOW, this 22nd day of November, 1999, after hearing the Court finds that the children are no longer dependent, They are released from the protective supervision of the agency, The parents shall have joint legal custody of Peter Rynard and Sean Rynard with Peter being in the primary physical custody of his father and Sean being in the primary physical custody of his mother. Sean shall visit with the Rynard household on alternating weekends from Saturday morning at 8:30 a.m. until Sunday evening at 6:00 p.m. Peter shall visit with his mother on alternating weekends from Friday at 6:30 p.rn, until Sunday at 6:30 p.m. Pick-up and drop-off for visitation shall occur at the North Middleton Township Police Station. Each parent shall arrive at the pick-up and drop-off appointments early and will give the other Da~ent . at least ten minutes if for some reason a parent is late, This custody arrangement and/or visitation schedule may be modified by further order of court, If either parent wishes a modification, they should proceed .' ....' .,. .... ~nrougn ~ne conCl~la~lon process, Fxhi~:+- A .."- ,." '-" . .'Y'.""'P ""IM.",,, -- '__'. -. r~~' ,"_~_~""~I~,"_ ---__;""T,,.,,,_~__'" . , Ruby D. Weeks, Esquire For CCC&YS Lindsay D. Baird, Esquire For the children By the ,....., ~ - , Edward E. Guido, J. Jacqueline M. Verney, Esquire In- If/Po For the natural mother " M~chael A. Scherer, Esquire Fo~ th~ na~ural rather ..."" .._ .... I,.. _ _ .. prOb~.ion \ CCC&YS :1fh . 1'IIl'-I-" ,~- ,'.--, "-, , Harold M. 'Rynard February 12r 2001 Robin Hinkle 28 Lucinda Drive carlisler Pa. 17013 Dear Ms.Hinkler This letter is to notify you in writing that our son Peter will be spending the remainder of his school year in Maine. During the summer monthsr Peter spent several weeks in Maine and he has expressed his desire to return there. The purpose for this is so that he can receive specialized schooling for the remainder of the school year. Preparations for this schooling have already been made by Vicki Rooney in Mainer who is working in conjunction with the Home School Association in Maine. It is in my opinion as Peter's father that this will provide Peter with opportunities for learning that he does not have here. Although Pete is presently passing his classes herer the school has indicated that he is not working up to his potential. Pete's guidance counselor and teachers have been contacted and they are in agreement that this will be beneficial for Peter. As Petes fatherr this decision has been difficult for mer but I feel that it is in Peter's best interest. This is what Peter desires to do. I will continue to hold legal custody of Peter and remain responsible for him and his actions. I will keep in close touch with his progress and plan to visit as able. Peter has refused to see you in over eight months and indicates to myself and others that he does not wish to see you. I find this unfortunate and I also recognize that his attempts to meet with his siblings have been met with resistance. Peter will be supplied with phone cards on a regular basis so that he can have the means to contact you, Sean and Amelia as he chooses. Peter is expected to depart sometime between the 23-25th of February. You are free to contact Peter or myself for any further details at 717-776-3860. F:]Y~~ J J/ -1- ~x:hi b; t- C3 ?/,,!~~;'<If .. "'I,. , HAROLD RYNARD PLAINTIFF V, ROBIN L HINKLE DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-2325 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, April 27, 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, Mechanicsburg, PA 17055 on Tuesday, May 22, 2001 at 8:30 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. 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. M 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 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 -~"''''~~ ...". ~ - "-1""'1'" . lm~~~'i!I'~~h,";d,",-'_'\I,c;.ti;'_'o,-,,,'_i'iH,.L.4~;.J",,,,,,,".~~'",~o,"",,,,"b,,:,,..'l1.',,.,;' ,,,,,"~,,,-,:-~,, ; ~-'i;_.i6,i:'2L,;(o,,,,;j"'''lJ'',-<.'I',,,~IIi';j~iiilil%i\'''~_~~'~~W~''~'~~~M.lIIlI~ 0: ril~\)~9!!1?S,~ \" , ,....il\\)IhJ"1Y 01 API? 27 p,'j /: LQ ~ {'U'^ " v IIJ,w[:t-,; , -J'~ 'Wl-.,lltJ-\t~u ('nu PENNSYLVANIA NTY , -#~ 1/',;)7-1)1 U. I~ ~ ~ ~ . '/;;17-1)1 ~ ~ Z 1fI' t/-;;.-i'Or C~ ~ ~ 4~~ . "'"'''' " ~h7",,=___"'_'.~~e._.'__~ ~>__,>""<"I<'~n."">k'__C .v_,,_'.. ~",~,~, =.=. -~,,, ~ ~ ."" ,----.", ,--. ,~, '::l'U, ~ !I I' 'I' I II '~ ~l " HAROLD RYNARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, 01-2325 CIVIL ACTION LAW ROBIN L HINKLE, Defendant IN CUSTODY ORDER OF COURT AND NOW, this )cA day of ~ ' 2001, consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: upon L The parties shall schedule a session with Georgi Anderson, LCSW, BCD, RPT-S, in order to reunite the parties' sons Sean and Peter, in a counseling setting, at which neither parent shall be present The Mother agrees to pay the cost of the first session, The cost of any subsequent sessions for Sean and Peter only shall be shared equally between the parties, The parties shall follow any recommendations made by Georgi Anderson with regard to both developing further contact between Sean and Peter and also between the boys and each parent 2. In the event Georgi Anderson recommends termination of the counseling with Peter and Sean, the parties agree that at least 4 additional visits between the boys (with neither parent present) shall take place under the supervision of the Mother's sister, Rita Bruckner, 3, After Sean and Peter have had 4 visits without the involvement of either parent, the parties shall cooperate in scheduling a 3 hour visit for Sean, Peter and the Father. Thereafter contacts between the Father and Sean shall be expanded as appropriate on an ongoing basis, with the specific dates and times to be arranged by agreement ofthe parties, 4, The parties shall cooperate in obtaining reports from Peter's psychiatrist, following his appointment on October 3, 200 L The parties acknowledge that it is their goal to reestablish the relationship between Peter and the Mother, as well as between Sean and the Father. To that end, the parties shall follow any recommendations issued by Peter's psychiatrist concerning initiation of contact between Peter and the Mother. ;~:-T! ,.' ",_,,>,-,"",F_, ~ _ _'_''''~'' , _ .~_ " . ^F_~I"fI'I,' "___4 "~!'" '"""""","'. ~'i" - , .. f 5, Within 90 days of the date of this Order, counsel for either party may contact the Conciliator to schedule an additional Custody Conciliation Conference, if necessary, Edward E. Guido, J. Cc: Thomas D, Gould, Esquire - Counsel for Father Herschel Lock, Esquire - Counsel for Mother j1 . 10~ L f:-al (p,XS . '-In .-f 0.'" ~ ~"'... ""'.~ " "".~d "--~ -""">",.",;0.' ." ,,~ ","~'_'~ ",,',,-,",',-~'<> '"_"0",',,,,,,"_.,,, ''''' "'~ '-"<''''1~'''''''''"''~~o"~",,, __,~, "'~<.".~~ '" ""'lO ~ , t \iiN'i/11ASNN3d ^ ~I'" ,-., '~^"I"v, MNnO,j u'", ,",~:jC.; 1\ I" 9 S :8 ~\V \ (; d3S 10 "Nlr);iG> ' ,",'J. JO l\U, "- r, ---""," 3::)\j:;,.....l~Uj i;j '9l",'! m~"""""",_,_ ,~!f! ~_PMI'!'",p05 ~ ."..~JA'I,ml~~~_....,'M"' .."m:WfflW!-'\J;~"""""".1!,%l".";';fh-;'!''ij,.'''''''''',~''"'fft';o~~m',,'~'ii.'1~Jl~~~~ji'~''1!lil!l!'ffi'!1<?'l!~~ ~ ,"."".",~. - HAROLD RYNARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs, 01,2325 CIVIL ACTION LAW ROBIN L HINKLE, Defendant IN CUSTODY PRIOR JUDGE: Edward E. Guido CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: L The pertinent information concerning the Children who are the subj ects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Peter J, Rynard Sean M, Rynard January 11, 1987 June 26, 1988 Father Mother 2, A Conciliation Conference was held on September 6, 2001, with the following individuals in attendance: The Father, Harold M, Rynard, with his counsel, Thomas D. Gould, Esquire, and the Mother, Robin L Hinkle, with her counsel, Robert G, Radebach, Esquire (for Herschel Lock, Esquire), ~{JIr~ {OJ 0-0"/ Date 3. The parties agreed to entry of an Order in the form as attached, rO~(~? Dawn S, Sunday, Esquire Custody Conciliator reF --" ,'-' _-',~M "_<<!'._"r.' '''', ^.- 'l.I""I; HAROLD RYNARD PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 01-2325 CIVIL ACTION LAW ROBIN L, HINKLE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, Jannary 07, 2002 , 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 Tuesday, Jannary 29, 2002 , the conciliator, 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: Is/ Dawn S. Sunday. Esq. 6V'A. 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 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 >:;'i'~~L,~ f"l'1 ,"' , - ~?ak%iilll!t~f~0dlU,.';i,!i"<;~!";.;:.i!~'l'<,..\.".-."""i"",,,"-!~"--'A; ,,-_,i,,"-:',, /. y~t1,;; / '~;,!J) / f t;':/.,./ " _ "_~C",,_ "r"..-,,,..,_, ,0/., """''''._,v'._ .~, ~.,~"'r,~v,_, n'."_. _,<,-,':',~'-' "~,~,~ .~"(_i,_""~.,"_"'t.",Ji~;ilfo!Will~",_mt.-"'~-'liJ"::lil,,,!:..,,,",4ilS1%MWli~''''"''''''''o:i" ?'.. < ~ .aillll!lliiiilil1liilli!lllllll I ~!! ~': G~~ J!1.N ... 8 p!: '), I-I I II t:,," I. .....1 jll."Y"'---" .' vVW'ILj.\"'Hl I,~.:\\[)'" r"u'.': n ITV , ",.1,,-1 ",\ V \JI\!II PENi~SYlW',NIA w. /~ )n~ ;t Jxd '71~ ~~ # 4 .x/~ /~j" /J-<~ z:;- ~p .."$,,".'~.~d',,~.'r "'~~.'" ",0-, ." .7"_~'~_ ~,,"_ ~d_~.. .,." ., ~ "-~, ~- ,- .~ 4 HAROLD RYNARD, Plaintiff-Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01-2325 ROBIN L. HINKLE, Defendant-Petitioner : CIVIL ACTION - LAW CUSTODY COMPLAINT FOR MODIFICATION OF CUSTODY ORDER AND NOW comes Petitioner, Defendant ROBIN L. HINKLE, by and through her attorney Herschel Lock and files her Complaint for Modification of Custody Order as follows, to wit: 1. The Petitioner, Defendant Robin L. Hinkle, is an adult individual residing at 28 Lucinda Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Respondent, Plaintiff Harold M. Rynard is an adult individual residing at 42 Chestnut Street, Newville, Cumberland County, Pennsylvania 17041. 3. Defendant seeks to confirm primary physical custody of the minor children the subject hereof, Peter J. Rynard (dob 1/11/87) and Sean M. Rynard (dob 6/26/88). The children were not born out of wedlock. The child Sean is presently in the legal custody of Defendant and the child Peter, while in the legal custody of plaintiff, is in the actual physical custody of Defendant. During the past five years the children have resided with the following persons at the following addresses: ~:_n~'lA-'f!'_~". ,'_ _~_ -~ r I'!"'IY,,, ,'- e- PERSON ADDRESS DATE I ~ 1996 Defendant 28 Lucinda Dr. - 1 Carlisle, PA Present 1 t Peter " Defendant 9/98 - 'ji :1 Newville, PA 2/12/01 I Plaintiff's cousin 2/12/01 - (Vickey Rooney) Kittery, ME 7/10/01 I Plaintiff 7/10/01 " Newville, PA 1217 /01 1 ! 12/7/01 t Defendant 28 Lucinda Dr. 1 Carlisle, PA Present , Defendant is the mother of the children and currently 1 ii- ; '! resides at 28 Lucinda Drive, Carlisle, Cumberland County, , ii , I 1 1 1 , \ i :i j 1 I Pennsylvania 17013. She is single. Plaintiff is the father of the children and currently resides at 42 Chestnut Street, Newville, Cumberland County, Pennsylvania. He is married. 4. The relationship of Plaintiff to the children is that of father. He currently resides with his wife, Michelle. 5. The relationship of Defendant to the children is that ; 1 I of father. The Defendant currently resides with her boyfriend Gary Christian as well as with the subject minor children. 6. Neither Plaintiff nor Defendant have participated as 1 a party or witness, or in another capacity, in litigation concerning j il I I the custody of the subject children other than the filed to the above term and number. ..~I'. . I ;; , Neither Plaintiff nor Defendant have information of a custody proceeding concerning the children pending in a court of "'C""~'lr1<lf<;t~,_ _ ~"_' ,-~- ~. Po""" " _ , , this Commonwealth. Neither Plaintiff nor Defendant know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the said children. 7. The best interests and permanent welfare of the said children will be served by modifying the current Order of Court (See Exhibit "A" attached hereto) and confirming Defendant's primary physical custody of them inasmuch as to do so will allow Defendant to continue to provide them with a stable and nurturing environment in which to live, something Plaintiff is unable to do. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child are parties to this action. DATED: I7ItJ/O/ Respectfully Submitted: ~~ oA(~ HERSCHEL LOCK, ESQUIRE ATTORNEY FOR PLAINTIFF 3107 North Front Street Harrisburg, PA 17110 (717) 238-6661 <-,...I!f!i'!iI~" ,,- I-~I , ~ < VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Fa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 12/12/01 ~:/~j ROBIN L, HINKLE ~"",' "-0 ',,5- _ ",<,_ ""',~..~ ^~, ~. :'1 .1 ;:~~ ,I II !, :i i: " If!lllf;!'!!f""",,,," ~ .'.' .. I ~.,. ~ "~ . ~ " ):::l@.fQ. (k (i fY ~' g ~~ J: - ).; () o ~ '~~~'''.n~ ~4!.~"",.~~ ~i1!li%*'~J"'~;~""i"fW, ",,,.,,~:,...',,:,,.~;.,,,.,., ~, <" (') 0 c: 0 -OS: '-' -n mW ", '~ ~n1 of- :1.' n iil~~ tJjC 1') ~ 0 ~~~~ =<:.L !:2C' " )> ~~ ZO :::L': :1>2 ry (-'''')m z: -'" =< r:- ~ CJI + ~i~' ~;ry!F.:r"J'" ~pl'i!!!f"<;""'iil'ffii?'",'I1,i':':;1 r~)?,<!if:~pt'!;-.,,\F1m-'Fn "!<i!!'1l'i'''l\',~~~I$ - . ~ .. ." '. ~' HAROLD RYNARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 01-2325 CIVIL ACTION LAW ROBIN L HINKLE, Defendant IN CUSTODY ORDER OF COURT AND NOW, this a~ day of f~~ r ,2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1, The prior Orders of this Court are vacated and replaced with this Order. 2. The Father, Harold Rynard, and the Mother, Robin L Hinkle shall have shared legal custody of Peter 1. Rynard, born January 11, 1987 and Sean M. Rynard, born June 26, 1988, Each parent shal1 have an equal right, to be exercised jointly with the other parent, to make al1 major non- emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion, Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 3, The Mother shal1 have primary physical custody of the Children, 4, The Father shall have partial physical custody of Sean every Saturday morning from 8:30 a,m, until 11 :00 a,m, The parties shal1 encourage Peter to have the same periods of custody with the Father. The parties shal1 exchange custody of the Child or Children at the North Middletown Police Station, 5, The parties shall obtain counseling for the Children and the parents with Kevin Hel1er at the Stevens Center. The purpose of the counseling shall be to assist in reestablishing the relationship between the Father and the Children and to obtain recommendations with regard to expanding the partial custody schedule for Sean and initiating and expanding the schedule for Peter. An additional purpose for the counseling shal1 be to establish cooperation between the parties to avoid future conflict which is detrimental to the Children, The parties shal1 follow the recommendations of the counselor with respect to the frequency and duration of counseling as well as the participation of each family member, The Mother shall contact the Stevens Center within 7 days to schedule the initial intake, ~~i.l_ ._,~11 ." ."","" ,. _ _",_'.",. _-,~~_ <~H,T~ . . .., .... .. .~ 6, Both parties shall encourage and foster the relationship between the Children and the other parent Edward E. Guido, l cc: Thomas D, Gould, Esquire ~ Counsel for Father Herschel Lock, Esquire - Counsel for Mother ~ ~ .3- () 1- 0;1- C}.-. ,'"'' "'"~f>~,XJIf'i-~~,,~ ''',''~ r"'1' ^ ,_. ~'." ^ "~"< I~ <.U "'< .. .. . . n " i i :1 I ;i , iiiN"if/\lA8NN3d ,UNnC() (]~Vl':1jBV'ln:J ~~'- "!J~'- 61 :8 1~\J I - i:i~\~ 20 .I 'j f,l::Jr " '" -, " \1;;;'J\' '_00' , ;.~,,,..,, . .,' ---'-', ~J8U_ ~0 .J',.) _ 1iUII~~~'njj;'!If._ ~,_.~~J:"'~, .,.~l;, ~ ",.~D. ~""",,,OO:jlPl!".:"'-,*f'<;'i~~,","""'-"'--'-'!il<'WC" ~,,-",,'-' "<;'O":-;'IW;H'"U:;'!'''''''''''''i!<1l'J"",!1''''''""'''',,,'rl''';'''''~'''''-~~ , ... , . HAROLD RYNARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, 01-2325 CNIL ACTION LAW ROBIN L HINKLE, Defendant IN CUSTODY PRlOR JUDGE: Edward E. Guido CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: L The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Peter J, Rynard Sean M, Rynard January 11, 1987 June 26, 1988 Mother Mother 2, A Conciliation Conference was held on January 29,2002, with the following individuals in attendance: The Father, Harold Rynard, with his counsel, Thomas D. Gould, Esquire, and the Mother, Robin L Hinkle, with her counsel, Herschel Lock, Esquire. 3, The parties and counsel agreed that the Conciliator would hold the submission of the Report and proposed Order in this matter until such time as the Conciliator was able to speak with Kevin Heller, the counselor from the Stevens Center and conduct a conference call with counsel. As this has now been accomplished, the Conciliator recommends entry of an Order in the form as attached, to which the parties and counsel have agreed, e~ l1 Date ' dOU d' O~JL~~ Dawn S, Sunday, Esquire Custody Conciliator I I ~'~""'!if1"'O~''W"%'f''N'''"'''''~' II. ,. ~~ ~-