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Home My WebLink About01-06073 } LINDA M. CARL PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 01-6073 CIVIL ACTION LAW CHARLES H. CARL DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, October 30, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cnmberland Connty Conrthouse, Carlisle on Thnrsday, November 29, 2001 at 1:30 PM 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 conrt 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: Isl Jacqueline M. Vernry. Esq. 6Y''^ 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 HA VB 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-!J_4'*-,.[""."l"i1 . . - ,. --,--, -_~~~M:lt..a;'\JUil.'.3~1Jl:J;jfl!1;""-1"llj,""d2,~';~,'''';:''''''''''''''-'-'-"'_'-i_,i. ..,,' .< '-;"':'X",l"'Ji'~-'>'~:",.J.,,~~~llU~ ~l_ ...wg,l1I;!!,<<i;$...!~~~g;.,jf"'$~I_ - r-,' , "''-'f'\I'I'( "j! II "-f I nr,.~t /"1 '..-I"" "I '" ',. Fi'" II' "2 fd I . t.:: (\' it'I/,';:'::': ,-,' ,-. ,'., Jv ",<.,.,1. j--' I !~".,', .' 'J"'. . PEj;Ji~s'yt3:1;4~y~NTY /~:.1/'CJ/ w- t'~ ~ 2't 4- ~ /OJNJ/ '71~ ~_?t; 4" ~o/~- /tJJ/tJ/ ~~~ df ~~. } i1\i"~.!I:1l,U,W,,.,,";_! Im_lI.llt,_I\,U_"ltl,,,!Ji,,M,,,,,,.t,,~lJr_.l.,,,,.,,..,", ,"_,,_ '_'~"_"'" ""~ _ _~__,"' ,,,'" " ,._,,'^"Y,'_'_"'_'"_<'>_""_'~,__~~,,~~_,"",,...-W,_.-"'.", _".,. _~,_~~~. 1<'~ ~~ - v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.O/-~13cIVIL ACTION LINDA M. CARL, Plaintiff CHARLES H. CARL, Defendant IN CUSTODY ORDER OF COURT AND NOW, ,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 ,2001_, at o'clock, .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 grounds for entry of a temporary or permanent order. 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 TillS 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. Office of the Court Administrator Cumberland County Court House, Fourth Floor Carlisle, PA 17013 (717) 240-6200 ;, , -, ';'--c' '~)"" '"''''''''' '~-;'r"R,,: __,~, ":,'_,:r~-,_",!:,-,r,'"i',,,,':,"'i "ry~- --' '"I. ,_" -'_ - . u" ",-"c ',- ,_y ."_ ~I _ ~ , >""~L _ ' ." "" "__'_~ ' " " o LINDA M. CARL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No.tJl-M73 CIVIL ACTION CHARLES H. CARL, Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Linda M. Carl, residing at P.O. Box 95, Plainfield, Cumberland County, Peunsylvania. 2. The defendant is Charles H. Carl, residing at 428 N. 2nd Street, Lykens, Pennsylvania. 3. Plaintiff seeks custody of the following children: Name Danielle M. Carl Derek C. Carl Joey C. Carl Dalton J. Carl Present Residence P.O. Box 95, Plainfield, PA P.O. Box 95, Plainfield, PA P.O. Box 95, Plainfield, PA P.O. Box 95, Plainfield, PA Age 16 14 11 9 One child was born out of wedlock and three ofthe children were not. The children are presently in the custody of Mother who resides at P.O. Box 95, Plainfield, Cumberland County, Pennsylvania. During the past five years, the children have resided with the following persons and at the following addresses: List All Persons List All Addresses Charles and Linda Carl Collierg Avenue, Tower City, P A Linda Carl Collierg Avenue, Tower City, P A Foster care(Danielle Carl) Unknown Linda Carl 437 W. Main St., Elizabethville, P A Linda Carl & Dominic Rattenni Plainfield, P A Dates 97-98 98-99 Jan. 98- Aug. 99 99-2001 2001- Present \:~, -. ,- ;_1:-,,,,,,~,,,?,_'d>',,,, ">~;"-;:~:,/:,);::-,:_""",,e_,.':7""1,""!""_'__'~ ,'.~" "~ ,-, -'",-1' ' 0_ _ - _ ~l -, 1 .)",_".,_~,"__ ~, __ _".., C", ~,-_ ' '. , ., " -~- ~.'. ~ The mother of the children is Linda M. Carl, currently residing at P.O. Box 95, Plainfield, PA. She is married. The father of the children is Charles H. Carl, currently residing at 428 North 2nd Street, Lykens, PA. He is married. 4. The relationship of plaintiff to the children is that of mother. The plaintiff currently resides with the following persons. Name Danielle M. Carl Derek C. Carl Joey C. Carl Dalton J. Carl Dominic Rattenni Relationship Daughter Son Son Son Boyfriend 5. The relationship of defendant to the children is that off ather. The defendant currently resides with the following persons. Name Unknown at this time Relationship 6. Cumberland County Children and Youth currently has a file pending on Danielle M. Cari, who was in foster care from January 1998 to August of 1999. The case was closed and Plaintiff re-opened it. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief request because: Plaintiff has undertaken and performed the primary parental responsibilities for the children for three years. Plaintiff is best able to provide the care and nurture which the children need for healthy development. ';'j,.- - ~ .~', - "',,,,_""_--,, '.'i;"''?__<'; """',' :',_,J_"h'_~","'.-ii"_"c"'_"F~ 1_""""""'- h'-- -'-"><"-. ,- , "'~ - , "' ^ . . " 8. Defendant has recently been released from Schuylkill County Prison where he was incarcerated for a sex offense crime, involving one of the minor children named in this action. WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody in the Mother with no visitation in the Father and Plaintiff respectfully requests that the Father not be allowed to pick the children up at school or any other location. Respectfully submitted, Date: 7~ , Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff I verifY that the statements made in this complaint are true and correct. false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. unsworn falsification to authorities. I understand that 904 relating to Linda M. Carl, Plaintiff ,,",.~- ,,,_~,_",_":""o - "'~" ;",-P"!,~f',_- ',- r.- '-'. -"__";'_'O~" ""~f'"""q.>._._" '.'~_' ~'_~'_~___ _~'_"',~':-<'_""' ,~. , . ~, -". ,. '. -~, ~~ ~ .- - , - " -, - , > LINDA M. CARL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. CIVIL ACTION CHARLES H. CARL, Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Plaintiff do hereby certify that I this day served a copy of the Complaintfor Custody upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Charles H. Carl 428 N. 2nd Street Lykens, PA Ruby D. Weeks, Esquire Children and Youth Services 10 West High Street Carlisle, P A 17013 Karl E. Rominger, Esquire Attorney for Plaintiff Dated: ''',~ ~,'-~-, ,~ .c .~"",;~,~-,P_<~,,-, - . ,,~^--" ,'-'- ~ __"":_+" ',,--,->-'< ,"" ,"'-''f' ",~,,',r__ ,,, - , ~~ - ~ - ~lU 8a .' ,aM,.... ...~.. .,,, ..,... -., ....,.. . "', n, w, ",."......., .'.. ......""'1. fmliIT~U:Tn"'T , ~Ett 8 ~ ~ ~ ~ 1" o c: :;~ -0 .~'=: n.lg~ 2~. 2'~: cn:r> r::s;:'L:" <c:; )> ~O ~c: );: ' C- Z -< o o ("'") -; "-' @ : :::~ - ii~J ~~ r c) ~)~ 6rn 0-< ?f5 -< :n 10 Ilt- .,= ,'., '.,f~ ~.~", .,- ," " '::'1"l' _'<<" _",~"""_~~," ,,~~~_ e_. ". ",,,,,,,,",,..>~e~~' !U~~~~illi'~~~~;_~, ~ ',;~,,-t.,,-r__ ,,-,~JL,,-,,~_,: ,w,e;. ", '_, L '-'-~f' l",~!", ~'~""-'':'7/r__-:~ DEe 04 , LINDA M. CARL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2001-6073 CIVIL TERM CHARLES H. CARL, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this -1L day of ~~ ,2001, upon consideration of the attached Custody Concihation Report, it is ordered and directed as follows: 1. Mother, Linda M. Carl, shall have sole legal custody of Danielle M. Carl, born June 15, 1985, Derek C. Carl, born August 31, 1987, Joey C. Carl, born September 24,1990 and Dalton 1. Carl, born July 10, 1992. 2. Mother, Linda M. Carl, shall have sole physical custody of Danielle M. Carl. 3. Mother, Linda M. Carl, shall have primary physical custody of Derek C. Carl, Joey C. Carl, and Dalton 1. Carl. 4. Father shall have periods of partial physical custody of Derek, Joey and Dalton as follows: A. Any Sunday for a period not to exceed eight (8) hours, provided Father give 14 days prior written notice of the time and date to Mother. B. Such other times as the parties agree. C. It is recommended that another adult accompany Father during his periods of partial physical custody. 5. Transportation shall be shared such that the parties shall meet for pick up and drop off at McDonald's on High Street in Carlisle, Pennsylvania. The parties shall wait thirty (30) minutes beyond the designated time for pick up and drop off to allow for traffic delays. 6. 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 ofthis Order shall control. '"'''''''~i'!...,_~~, , "~ ,~ " ~ cc: Karl E. Rominger, Esquire, counsel for Mother Charles H. Carl, pro se trmJ'W . (\ \ 428 N. 2nd Street ~ r--~ Lykens, P A 17048 , 1'1' 12-11-01 1\ 3 ""!"~':"jjI~~:m:": '''".~, 4 1. d~~~",,jW~,,j/j&~'l!iriM~!Jli!\!1!;li.!mi?&\J.ih~;~~'"'i"'"'''' "_'-i~'_,C." """~"'~b;.'A;-'-"'B-'\"":;_iii'';''J:~tWdllAlJjlli~~1i~l~~''''-'' o j [r~-C 1 PH I: i 7 L;~' '1 f; -- ",',' li V" .",<;-., '. ., -. {",c",U' '~I"'.t 1"',j_--'~~11L/'",j " ij,j' j'~ j '( PE"J\:C:;VJ\/l,,\lff\ j f\VI....'Jr".l U, !!~tiI~l\~:~J~. _ ~__ _~^~, ~,~ ~_ """"""',_" ~,' _, '1_'''''_~+'''',,,~,,'~,,,,,,,~,, "".W,."""...,,_ ,,,_ , _~~_ ~,_, ,.,"""",,~ _~ ~,,", "~y_",,,.,,_ "" ._Oh ~, _,_~_~, ,~ "~ ~ v _ ,,, - DEe W1 LINDA M. CARL Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2001-6073 CIVIL TERM CHARLES H. CARL, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: None 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 Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Danielle M. Carl Derek C. Carl Joey C. Carl Dalton J. Carl June 15, 1985 August 31, 1987 September 24, 1990 July 10, 1992 Mother Mother Mother Mother 2. A Conciliation Conference was held in this matter on December 4,2001. The following people were present at the conference: Mother, Linda M. Carl was present with her counsel, Karl E. Rominger, Esquire. Father, Charles H. Carl was present pro se. 3. The parties agreed to the entry of an Order in the form as attached. Il-~l.f --0' Date ~='!;E~~' Custody Conciliator ""f'!""-'''''''''''~, '1 "'- , , "~ ~ ~ 1l'! '$1_ \ii~~_." rU.]I1ITl. ~ .=JII~ p [l~, _ '1~"l"B'!W1'J>li''':I,,,"""'O~''-};V-''-''1-\'-j''''''Y:',p-,,,,,~PWM,r!!\Q~'l~l/1i~mq._ ,.,.~, . ~.1lI~~"'""'"7',__' fc~f~\',