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HomeMy WebLinkAbout99-04341 (2) i ii Prothonotary of Cumberland County Cumberland County Courthouse Carlisle PA 17013 -. , f ? ,I c ?? ll b Ms. Angela Riegle 40 E. Lowther Street Carlisle PA 17013 hl,m,,.lor 21 1.... HICUVYu 1/UlaevlC lYVV 15 VY/Ub/VV REIGLE RETURN TO SENDER -1 MOVED LEFT NO ADDRESS UNABLE TO FORWARD n •~^oi •~ ?•'?????r.? II IIIIIIIIIIIIIIIIII?IIIII IIIII?III IIIII III lI111III 1. ANGELA RIEGL.E. Respondent/Plaintiff v. RANDY I.. RIEGLE, Petit i oner/Defendant IN TILE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-4341 CIVIL ACTION-LAW CUSTODY AND NOW, this 3 day of 2000, it is hereby ORDERED and DECREED that the attached Stipulation is hereby entered as an Order of Court. BY THE COURT: r7 1 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of s°,id Co?uq at farllsle, Pa. Th 3 a+- day of._, -zov-0 Prothonotary ANGELA RIEGLE, IN THE COURT Or COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 99-4341 RANDY L. RIEGLE, CIVIL ACTION-LAW Defendant CUSTODY CUSTODY STIPUI.A*I*ION AND NOW, this CI'" day of 2000, with regard to the best interests of the minor child, Cody David Riegle, bom June 28, 1992, the parties agree as follows: The parties shall share legal custody of the minor child, Cody. They shall consult with each other relative to all important decisions concerning the subject minor child, including such matters as health, education and religion. 2. Randy L. Riegle (hereinafter "Father") shall have primary physical custody of the minor child. 3. Angela Ricglc (hereinafter "Mother") shall have partial physical custody of the minor child during the limes that the parties agree. 4. This custody stipulation will be reviewed one year from the date of this stipulation. Witness Angela ieglc 0 r- ` Walaacss Ran Y L. R 6g lc --I ppy Q P Be, DENISE MILLER L n Ct a p? /o.r?n7 r,? _?r My I hereby certify that a true and correct copy of the attached document was served on the person below by depositing in the U.S. Mail, First Class Postage on this day: Ms. Angela Riegle 40 E. Lowther Street Carlisle, PA 17013 Respectfully submitted, By: qey_-? Emily Long Hoffman, Esquire Sup. Ct. ID N 66307 105 North Front Street P.O. Box 11475 Harrisburg, PA 17108 (717)233-1112 Date: 7/19/00 • M ?q R?r_ 3kr Plaintiff V. " QX'V?y L. R;c'11?efendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. q1 LA1 CIVIL 19 q9 CUSTODY VISITATION ORDER OF COURT And now, this _11a 4V , upon consideration of the attached complaint, it is hereby directed that the above parties and their respective counsel appear before 1?. (1 S .?nc 10 Esquire, the conciliator, at \ CC \ , Pennsylvania, on the I day of C , 1999, at 00 A. P.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 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: By: Zmo\? d l Custody Conciliator f n? 1 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. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 90 a? a F ?C 1° ANGELA RIEGLE, V. : IN Tf>E COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA RANDY L. RIEGLE, Defendant : CIVIL DIVISION - CUSTODY :NO. 99 -,93H/ CIVIL TERM IN CUSTODY ORDER OF COURT You, Randy L. Riegle, have been sued in Court to obtain custody of the child: Cody David Riegle. You are ordered to appear in person at on , at _.M., for ? a conciliation or mediation conference. ? a pretrial conference. ? a hearing before the court. If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. 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 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 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. BY THE COURT: Date: d ANGELA RIEGLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - CUSTODY NO. CIVIL TERM RANDY L. RIEGLE, Defendant IN CUSTODY COMPLAINT FOR CUSTODY I . Plaintiff is Angela Riegle, an adult individual currently residing at 40 East Louther Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Randy L. Riegle, an adult individual currently residing at 253 South Front Street, Steelton, Dauphin County, Pennsylvania. 3. The Plaintiff is the natural Mother of the child, Cody David Riegle, born June 28, 1992. 4. The child was not born in wedlock. 5. In the past five years, the child has resided with the following persons at the following addresses for the following periods of time: NAME Angela Riegle, Doug Auger Angela Riegle, Audrey Auger ADDRESS 40 East Louther Street Carlisle, PA 17013 105 Heberling Newville, PA 17241 DATE Feb 99 - present Jun 96 - Feb 99 Angela Riegle, Randy Riegle 29th & Derry Streets Summer 95 - Jun 96 Harrisburg, PA 17100 b. The natural mother of the child is Angela Riegle, who resides as aforesaid. She is not married. 7. The adoptive father of the child is Randy L. Riegle, who resides as aforesaid. He is not married. 8. The relationship of the Plaintiff to the child is that of natural Mother. The Plaintiff currently resides with the child and her boyfriend, Doug Auger. 9. The relationship of the Defendant to the child is that of adoptive Father. The Defendant currently resides with his girlfriend, Robin. 10. The Plaintiff has no information of a custody proceeding concerning the child pending in any Court of this Commonwealth. 11. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) The Plaintiff is better suited to provide a stable environment to foster the child's well being; b) The Plaintiff is more apt to not hamper the custodial periods of the other , party. 12. The Plaintiff does not know of any person not a party to the proceedings who claims to have custody or visitation rights with respect to the child. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order scheduling the Parties for a Custody Conciliation. Dated: It 5 ?? `1 Attorney for the Plaintiff 401 East Louther Street, Suite 103 Carlisle, PA 17013 (717) 240-0833 (717) 249-2407 - FAX VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unswom falsifications to authorities DATE: ? -I LI - R -( p ANGE RIEGL J"- r- C= :< n \ ?6 ty :. I 1 I.h W 01910. 1II: Thomas S. Umhl 401 K"I I.(Inllll'r SUvel, Suite 103 Curlv,le, Pmmxglcunw. 17013 JUL 19 1,999 I 4? Ill,hnno(7171240A811 F. 1S 11191119.1107 OCT 0 5 199 ANGELA RIEGLE, Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 99-4341 IN CUSTODY VS. RANDY L. RIEGLE, Defendant ORDER OF COURT AND NOW# this 30th day of September, 1999, the Conciliator, having received no contact from counsel for either party to reschedule the Custody Conciliation Conference originally set for September 1, 1999, hereby relinquishes jurisdiction. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator CP ?: tl_ ? ? , I :'" ' i - t-)' l "1 ? ?:: ? .. - ?_ ? '. ? ? i 1 Gl ?(i ? ?> ANGELA RIEGLE IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. RANDY L. REIGLE 99-4341 CIVIL ACTION LAW DEFENDANT IN CUSTODY AND NOW, this 23rd day of May , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear befordMellssa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill PA 17011 on the 15th day of June 2000, at 9:15 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. FOR THE COURT, By: /s/ \ Custody Conciliator A, 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 FI - ,:?,?r I Li'-.'?i.v... ?;'l I' ? ^ • ? ? .??5• GYM ?G?- C? . ?"?/ ?i G?s? 5?%y` ANGELA RIEGLE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 99-4341 RANDY L. RIEGLE, CIVIL ACTION-LAW Defendant CUSTODY You, Angela Riegle and Randy L. Riegle, are ORDERED to appear in person before , Custody Conciliator, at on at - o'clock _.m. for a Custody Conciliation 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, at the request of either attorney or party, be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. 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 1-800-990-9108 Date: ANGELA RIEGLE, Respondent/Plaintiff V. RANDY L. RIEGLE, Petitioner/Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-4341 CIVIL ACTION-LAW CUSTODY AND NOW, comes Respondent/Defendant, Randy L. Riegle, by and through his attorney, Emily Long Hoffman, and in support of his Petition avers as follows: Petitioner/Defendant is Randy L. Riegle (hereinafter "Father") who has resided at 1354 Viscaya Drive, Port Charlotte, Florida 33952 since July 1999. 2. Respondent/Plaintiff is Angela Riegle (hereinafter "Mother") who has resided at 40 E. Lowther Street, Carlisle, Pennsylvania 17013. 3. Father seeks physical custody of the parties' minor child, Cody. 4. Mother filed a Complaint for Custody in July of 1999 but the parties never attended a conciliation conference, thus, there is no custody order currently in effect. 5. The child currently resides with his Mother, Angela Riegle, and his half-siblings, Zach, age 12, Lindsay, age 10, and Nathanial, age 2. 6. Father seeks primary custody for the following reasons: a. Mother leaves the children unsupervised for long periods of time; b. The minor child has sustained numerous injuries while in the care of his Mother; c. The minor child was held back in school one year possibly because Mother moved several times in one year; d. Mother makes derogatory comments about Father in front of the children; e. Mother has not allowed the Father to see the child since May of 1999. 7. The best interest and permanent welfare of the child will bE served by granting the relief requested. WHEREFORE, Plaintiff requests the Court to grant him custody of the child. Respectfully submitted, BY: i EMILY L. HOFFMAN, ESQUIRE Supreme Court I.D.# 66307 105 North Front Street Post Office Box 11475 Harrisburg, PA 17108-1475 (717) 233-1112 Attorney for Plaintiff DATED: 5/19/00 84151-1 Upon my personal knowledge, information, and belief, 1, Emily Long Hoffman, due to my client's unavailability and time constraints, verify, on behalf of my client, Randy L. Riegle, that the facts averred and statements made in the foregoing document are true and correct to the best of my knowledge. I understand that false statements or Averments therein made will subject me to the criminal penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. BY: Plu - Emily Long o fman Date: 5 1 l l I p v I hereby certify that a true and correct copy of the attached document was served on the person below by depositing in the U.S. Mail, First Class Postage on this day: Ms. Angela Riegle 40 E. Lowther Street Carlisle, PA 17013 Respectfully submitted, By: ?Lfl tt-A(- Emily Long Hoffman, Esquire Sup. Ct, ID # 66307 105 North Front Street P.O. Box 11475 Harrisburg, PA 17108 (717)233-1112 Date: 5/19/00 MAY 2 3 200 ANGELA RIEGLE, IN THE COURT OF COMMON PLEAS Respondent/Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 99-4341 RANDY L. RIEGLE, CIVIL ACTION-LAW Petitioner/Defendant CUSTODY AND NOW, this a?,S t-Aday of M,1 7 , 2000, it is hereby ORDERED and DECREED that a hearing is scheduled for the 1A *A day of r yU Al , 2000, at -,3 d o'clock A . m. in Courtroom # -7 at the Cumberland County Courthouse, Carlisle, Pennsylvania, to review Defendant's Petition for Special Relief. .t` X,A& d ,E - C64.-do J. .J?c?L "UQ 'K KS ?r i? . ..? i.) ANGELA RIEGLE, IN THE COURT OF COMMON PLEAS Respondent/Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 99-4341 RANDY L. RIEGLE, CIVIL ACTION-LAW Petitioner/Defendant CUSTODY AND NOW, this day of 2000, it is hereby ORDERED and DECREED that Defendant shall have custody of the minor child, Cody Riegle, from June 17, 2000 until July 23, 2000. Plaintiff will see that the child is on the correct flight on June 17, 2000, as pre .manged by Father, and Mother shall pick up the child from the airport on July 23, 2000. J. ANGELA RIEGLE, Respondent/Plaintiff v RANDY L. RIEGLE, Petitioner/Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-4341 CIVIL ACTION-LAW CUSTODY PETITION FOR SPECIAL F LIEF FOUFSTINT INTERIM RELIEF PENDING OUTCOME OF STODY CONCILIATION CONE .RFNC_F. ?n AND NOW, comes Respondent/Defendant, Randy L. Riegle, by and through his attorney, Emily Long Hoffman, and in support of his Petition for Special Relief avers as follows: 1. Petitioner/Defendant is Randy L. Riegle (hereinafter "Father") who resides at 1354 Viscaya Drive, Port Charlotte, Florida 33952. 2. Respondent/Plaintiff is Angela Riegle (hereinafter "Mother") who resides at 40 E. Lowther Street, Carlisle, Pennsylvania 17013. 3. The parties do not have a custody order although Father has filed for a conciliation conference. 4. The parties reached a verbal agreement earlier this year that Father would have summer visitation with the minor child of the parties, Cody Riegle, born June 28, 1992, to be exercised at his home in Florida. 5. Father's attorney sent Mother's attorney a custody stipulation based on the verbal agreement so that their would be no problems regarding Father's summer visitation. A copy of the stipulation is attached hereto as Exhibit "A". ,:i 5. Mother refuses to sign the stipulation because she wants daily phone calls. 6. Mother is very negative about Father to the child and Father is concerned about the negative effect the nightly calls will have on the child. 7. Mother has stated that if he does not agree to her terms, she will not allow the child to visit with him this summer. 8. It is in the best interests of the child to visit with his Father. 9. Father desires that Mother put the child on the correct flight on June 17, 2000, as pre- arranged by Father, and that Mother pick up the child from the airport on July 23, 2000. WHEREFORE, Father requests that this Honorable Court grant Father visitation with the minor child from June 17, 2000 to July 23, 2000. Res ctfully submitted, Emily Long Hoffman, Esquire Sup. Ct. ID # 66307 105 North Front Street Harrisburg, PA 17108 (717)233-1112 Date: 5/19/00 Upon my personal knowledge, information, and belief, 1, Emily Long Hoffinan, due to my client's unavailability and time constraints, verify, on behalf of my client, Randy L. Riegle, that the facts averred and statements made in the foregoing document are true and correct to the best of my knowledge. I understand that false statements or Averments therein made will subject me to the criminal penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. BY: Emily Long Hoffman Date: ,`I ( Q J t UJ I hereby certify that a true and correct copy of the attached document was served on the person below by depositing in the U.S. Mail, First Class Postage on this day: Ms. Angela Riegle 40 E. Lowther Street Carlisle, PA 17013 Respectfully submitted, By: Emily Lon Hoffinan, Esquire Sup. Ct. ID # 66307 105 North Front Street P.O. Box 11475 Harrisburg, PA 17108 (717)233-1112 Date: 5/19/00 ANGELA RIEGLE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA No. 99-4341 RANDY L. RIEGLE, CIVIL ACTION-LAW Defendant CUSTODY AND NOW, this day of 2000, with regard to the best interests of the minor child, Cody David Riegle, born June 28, 1992, the parties agree as follows: The parties shall share legal custody of the minor child, Cody. They shall consult with each other relative to all important decisions concerning the subject minor child, including such matters as health, education and religion. 2. Angela Riegle (hereinafter "Mother") shall have primary physical custody of the minor child. Randy L. Riegle (hereinafter "Father") shall have partial physical custody of the minor child during the following times: a. For the summer of 2000, from June 17, 2000 until July 23, 2000. 4. Mother is entitled to one phone call from the child per week and Father will have the minor child call Mother from the airport as soon as his flight lands in Florida at the beginning of the visit. 5. Father will enroll the minor child in speech therapy and see that the child attends the classes and will provide Mother with progress reports. Witness Angela Riegle Witness Randy L. Riegle 2. R EMILY LONG HOFFMAN ATTORNEY AT LAW 105 NORTH FRONT STREET P. O, BOX 11475 HARRISBURG, PA 17108-1475 255 MARKET STREET MILLERSBURG. PA 17061 X717) 233.-22 1112 OI7) 802.4244 FAX(717) 234.2234 June 1, 2000 a mail: hoffmana0apia.nat The Honorable Edward E. Guido Cumberland County Courthouse 1 Courthouse Square Carlisle PA 17013 Re: Angela Riegle v. Randy L. Riegle No. 99-4341 Civil Action-Law - Custody Dear Judge Guido: I represent Petitioner Randy L. Riegle in the above matter. My client lives in Florida and, therefore, we would respectfully request that Your Honor allow us to use telephone testimony in the hearing scheduled for June 12, 2000, at 9:30 a.m, to review my client's Petition for Special Relief concerning summer visitation with his son. I would appreciate your consideration of my request. Si ely, Emily Long Hoff n Enclosure d, ? °d MAY 2 3 29, ANGELA RIEGLE, IN THE COURT OF COMMON PLEAS Respondent/Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 99-4341 RANDY L. RIEGLE, CIVIL ACTION-LAW Petitioner/Defendant CUSTODY AND NOW, this o?J day of InA ll , 2000, it is hereby ORDERED and DECREED that a hearing is scheduled for the /A *A day of V u N E , 2000, at 91*3 d o'clock ?. m. in Courtroom II 3r at the Cumberland County Courthouse, Carlisle, Pennsylvania, to review Defendant's Petition for Special Relief. ZWLr.Ard A5. C&C.,d j J. In Tcslinnvq !, I h r: 1ai+u srl my hand and the qm II:1 siid Court at Carlisle, Pa. Thi° ......fX(r.. o . 1!..1 rothonota ANGELA RIEGLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. 99-4341 CIVIL TERM CIVIL ACTION - LAW RANDY L. RIEGLE, Defendant IN CUSTODY IN RE: VISITATION ORDER OF COURT AND NOW, this 12th day of June, 2000, it appearing to the Court that a custody action is pending and set to be scheduled for conciliation, and it further appearing that an interim order is necessary pending said conciliation, it is hereby ordered and directed as follows: 1. The parties shall have joint legal custody of their child, Cody, born June 28, 1992. 2. Mother shall have primary physical custody of said child. 3. Father shall be entitled to partial physical custody of the child from June 29, 2000, to August 10, 2000. Said partial physical custody shall be accomplished, and subject to the terms, as follows: a. Father shall send a round trip ticket to mother, either physically or electronically, on or before June 20, 2000. Father will use his best efforts to book a direct flight from Harrisburg to Tampa or Orlando. In the event that he is unable to book a direct flight to either one of those airports, he may book a direct flight from Baltimore to Tampa or Orlando. b. Father shall be responsible for the costs of the air transportation. Mother shall be responsible for delivering the son to and from the airport. C. Father will make the child available to receive phone calls from mother each Sunday, Tuesday, and Thursday from 8:00 p.m. to 8:30 p.m. Father shall also have the child call mother each Friday between 8:00 p.m. and 8:30 p.m. In the event that there is a scheduling conflict so that the child is not available for one of the phone calls, father shall notify mother at least 24 hours in advance and make alternate arrangements for another phone call. If the converse is true, mother shall do the same. d. Father shall have the child call from the Orlando or Tampa Airport to advise mother that his flight has safely arrived. e. In the event that the child needs medical attention while in father's partial physical custody, father shall contact mother immediately to notify her of said situation. 4. This is an interim order, and shall not in any way affect the rights of either party to litigate the current custody matter which is pending before the conciliator. This Court shall retain jurisdiction. By the Court, Emily Hoffman, Esquire 105 North Front Street Harrisburg, PA 17108-1475 Angela Riegle 40 East Louther Street Carlisle, PA 17013 mae Edward E. Guido, J. .. '?'Ill`.Ill Ii: 26 lJ?.c _L. :J ':Vi1V11 ANGELA RIEGLE, Respondent/Plaintiff V. RANDY L. RIEGLE, Petitioner/Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-4341 CIVIL ACTION-LAW CUSTODY AND NOW, this .3,'* day of? 2000, it is hereby ORDERED and DECREED that the attached Stipulation is hereby entered as an Order of Court. BY T;;; J. r; . $ ,?,. ANGELA RIEGLE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 99-4341 RANDY L. RIEGLE, CIVIL ACTION-LAW Defendant CUSTODY AND NOW, this Cl rn day of i1ti? , 2000, with regard to the best interests of the minor child, Cody David Riegle, born June 28, 1992, the parties agree as follows: 1. The parties shall share legal custody of the minor child, Cody. They shall consult with each other relative to all important decisions concerning the subject minor child, including such matters as health, education and religion. 2. Randy L. Riegle (hereinafter "Father") shall have primary physical custody of the minor child. 3. Angela Riegle (hereinafter "Mother") shall have partial physical custody of the minor child during the times that the parties agree. 4. This custody stipulation will be reviewed one year from the date of this stipulation. i'Danoin 2S 124b Witness Angela iegle Witness Randy L. P gle t x,01 P 0, DENISE MILLER y6 0'dd dr-0 7 n COMMOSION NUMBER _ IA y c CCIS90462 A, L/ fu?'• vndo MY COMMISSION EXPIRES CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the attached document was served on the person below by depositing in the U.S. Mail, First Class Postage on this day: Ms. Angela Riegle 40 E. Lowther Street Carlisle, PA 17013 Respectfully submitted, (/ `t (? -- By: Emily Long Hoffman, Esquire Sup. Ct. ID # 66307 105 North Front Street P.O. Box 11475 Harrisburg, PA 17108 (717)233-1112 Date: 7/19/00 ,-, ?;: ? ? _; ?. °:> ?? ANGELA RIEGLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. RANDY L. RIEGLE, NO. 99-4341 CIVIL TERM Defendant CUSTODY ACTION ORDER OF COURT AND NOW, this 2No day of AUGUST, 2001, a Custody Stipulation was hereby entered, effective June 29, 2000, for the minor child, Cody David Riegle, born June 28, 1992. Upon the request of Petitioner/Defendant Randy Riegle a custody review is scheduled for THURSDAY. AUGUST 23, 2001, at 9:30 a.m. before Hubert X. Gilroy, Esquire. The review will be held on the 4TH Floor of the Cumberland County Courthouse, Carlisle, Pa. 17013. All parties concerned are to have the appropriate witnesses available. By the Edward E. Guido, J. Angela Riegle 320 Third Street West Fairview, Pa. 17025 Randy L. Riegle 497 Ricold Terrace Port Charlotte, Fla. 33954 914-235-0726 cu}u ?; /nc.,e?r? ?F- 3 of l Ql/ri - lli9:q CLI, P NNSVZ?414U,`py To: The Court of Common Pleas Un berww GXIrq, Pbaeyivada From: Randy and Robin Riegle Dale: 07/18/01 Re: Custody review(99-4341) We have had custody of Cody Riegle for I I months and it has been a great pleasure to have been with him and watch him grow into a changed person. We love Cody very much and only want the best for him. Please find attached progress reports from Cody's school here in Florida and his reports from Pennsylvania. Cody improved almost 75% in school since he was with us, and always tried so hard. He had speech twice a week and was in ESE for reading and spelling. At the last meeting we had at the end of school with the all his teachers, and specialist who did all the testing. Informed us that because of all the moving that his mother did is one of the reasons he is behind in school. During the time we have had him he has stayed healthy and has had a happy and safe structure environment. He has been happy and loves having his own room and he got to play sports for the first time in his life and he did great with a trophy to show for it. We would like to mention a few things about Cody's visit with us. When he arrived he had a small sport bag that we got him with 3 shorts and shirts with one long pair of pants no shoes but sandals. Cody's grandmother Evelyn Lebo which is Randy Riegle's mother hadjust bought him a ton of clothes just before we had gotten custody of him. But none of them showed up along with his brand new shoes and his mother kept promising Cody she would send them but we are in June of 2001 and we still did not receive the package. The one problem we kept having with Cody's mother was she kept promising so much to Cody and never kept any of them. For example, when she moved into the new house with her new husband that Cody would have the biggest room and she got him a lot of stuff for Christmas. His mother had promised that he would go home for Christmas and 5 days before Christmas she had called and told him he would not be going up. The problem with this is we were are the one's who had to see him cry and deal with explaining why she had pulled what she did at the last moment. But, it did not end there she promised to send him his Christmas gifts and they also have not arrived. She then promised him he could come up at the end of January and again Cody was disappointed he did not go. Than we did not hear from Angie Riegle until the end of February, and she promised again Cody he could come up for Spring Break. But a week before spring break she had called and started making excuses and Cody's father informed her she was to find a way because she was not going to disappoint July 18, 2001 him again. During his visit, his mother was suppose to spend time with him and do some fun things but she worked most of the time. We kept in constant contact with Cody and he was happy to be with his sister and younger brother and we are glad he got to visit. He did get to see his grandmother and stay over night, but come to find out from Cody he spent the night with other people and he was not sure who they were. During the time Cody had been with his father and I his mother had gotten married again but she is no longer with him he has since moved out. During Cody's visit when he was at the house that his mother lived there where many other people living there. When Cody did stay there he slept on the floor or in the same bed with his sister or where ever he could find a spot. But this was after the promise his mom made that he had his own room and the biggest. Cody's oldest brother who he looked up too was not living there which we are not sure why. One of the reason's Cody came to live with us was because his mother needed to try and get her life together. But this has been going on for years she has the same patterns over and over. During the time Cody has been here we have found out about what has been going on while he was living with his mother. As the school records indicated Cody's mother moved the children 6 times in one year and the next year three times this has been one of the problems with Cody and why he is so behind in school. She has constantly put Cody in danger by leaving him home with a I I year old to watch along with 2 other children. She has been with different people who have been abusive to her and the children have been there to witness this. There are police reports of problems that have existed. Another reason Ms Riegle let Cody come here was because of her last live in they had a fight and she would not let him pick up his son which is the youngest of 4. He than returned with a gun and with the children there and threaten her the police came. She was asked to move out because the landlord was tired of all the fights and the problems going on in her apartment. Cody was constantly getting hurt and the stories she had told us what happened was not true, because Cody had told the DR here locally what really happened. During his school physical you can imagine our surprise that his mother was not with him during any of the accidents he had and what Cody had told the Dr was totally different. We are glad that we found out, but our concerned that he was not being watched by an adult but by a I I year old all the time. During this past year we feel her situation has not changed enough and we are really concerned about Cody's well being. We would love to keep Custody of Cody if the court will allow this. As the records show not only is he doing great in school but he feel's secure with us, and his never let alone. Cody has falling in love with my wife's family and has enjoyed his time here. We hope the courts could see it to let him stay with us. Because his life is what should matter to all parties involved. We our able to support Cody and make sure he is loved and a much needed education in the same school and able to have a happy child hood with lots of July 19, 2001 We our able to support Cody and make sure he is loved and a much needed education in the same school and able to have a happy child hood with lots of family, friends therefor him. We will always make sure he has contact with his mother and siblings and plenty of visitation. If Angie Riegle can show the courts and us that she is ready to take Cody. We would like proof in writing from her these are the stipulation we are hoping to secure our fears. 1. We would like a list of all parties living in the home and what each person's status is in the home with names. 2. A name and number of the babysitter with license number if they have one. 3. Where she is working now and can she truly support Cody and with only one income since we found out she is alone again. 4. We would feel better to know that he will be safe and taking care of. 5. That all education needs for Cody are met this can be done by the school. We are asking if it is possible she be monitored by social services for a period of time to make sure that Cody is happy and feels safe. But we our only asking if the court feels that Cody should be returned to his mother we would like it if these stipulation are permissible. Cody will be on vacation in Pennsylvania from July 17, 2001 until August 8a', 2001. He is all ready enrolled at the school he attenuated last year here in Florida and they will be returning August 13, 2001. But we did promise he could go and visit, but there was a problem and he was picked up by his grandmother. We did not hear and could not reach Cody's mother for 4 weeks. The worst pail is that June 28 was Cody's birthday not one phone call or a card was received as promised to him from his mother. We are very concerned, because when we finally got a hold of Angela Riegle on July 15, She informed us that She is without a car, and she has been in and out of the hospital again and is no longer married and has no long distance available on her phone. We are with hope that the court finds that it would be in Cody's best interest to keep him here with us here in Florida. Especially from the last phone call with her having no transportation and being ill she has enough with three children, and bringing back Cody would add on when we are capable of taking care of him. Thank you for your time in this matter and hope to hear from you soon. Sincerely, Randy and Ro in Riegle, P.S. We do not have an attorney and this case is up for review and this is why we are writing this letter. If there is another way to handle this please let us know. 3 AN H Glen 8-1475 M233H12 0171 ANGELA RIEGLE, Respondent/Plaintiff V. RANDY L. RIEGLF, Petitioner/Defendant u? 4... ...,....ice .a .'.t0 JUL 2 g IN TIIE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-4341 CIVIL ACTION-LAW CUSTODY AND NOW, this .3/.a1' day of 2000, it is hereby ORDERED and DECREED that the attached Stipulation is hereby entered as an Order of Court. BY TI IE COURT: ANGELA RIEGLE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. No. 99-4341 RANDY L. RIEGLE, Defendant CIVIL ACTION-LAW CUSTODY CUSTODY STIPULATION AND NOW, this cl" day of _jUnA_ 2000, with regard to the best interests of the minor child, Cody David Riegle, born June 28, 1992, the parties agree as follows: 1. The parties shall share legal custody of the minor child, Cody. They shall consult with each other relative to all important decisions concerning the subject minor child, including such matters as health, education and religion. 2. Randy L. Riegle (hereinafter "Father") shall have primary physical custody of the minor child. 3. Angcla Ricgic (hercinafIcr "Mother") shall have partial physical custody of the minor child during the times that the parties agree. 4. This custody stipulation will be reviewed one year from the date of this stipulatio WitncSS /' u? Wetness •?'PY r, DENISE MILLER CoY 94*" "UMNEn Cl,nno?rt CLe? o Angela iegle Ran y L. RfEglc -Al - 1st Trimester 2nd Trimest er 3rd Trimeste r PE RFOR MAN CE PE RFOR MAN CE I PROG RESd PE RFOR MAN CE PROG R v 6 5 E A student's rating is marked with a 'G c Z check (!). U (here is no check fora t a ' = i d. was component, the componen not evaluated during the trimester. V Q y v > a{ Q a q -J M y Y '? Q Y y W V COMPONENTS ¢ G 9 z a ? 0. z ? v. n. a z a .a Confidence and self-direction A_ Self-control ?C'yt Approach to learning E Interaction with others I 1,A L Conflict resolution V Listening 0 Oral communication t/ a Literature and readin ? ?.? Written communication S ellin Mathematical thinking B t Algebraic thinking (patterns) E Number concepts and operations s Geometry and atial relations / Measurement Probability and statistics (graphing) _ i; Observin and investiatin Questionin and redictin 5 ur Ex lainin and forming conclusions OTHER BASICS O Outstanding I Improving Tr imest er S Satisfactory N Needslmprovement 1st 2nd 3rd ART ' Behavior/attitude MUSK Behavior/attitude COMPUTER Behavior/attitude PHYSICAL EDUCATION Sportsmanship/attitude ! =Area or lAncem YOUR CHILD IS RECEIVING THE Trimest er FOLLOWING SERVICES: 1st 2nd 3rd Exceptional Student Education Speech/Language Math Support Title I Support Readin /Writin Su ort Academic [m rovement Plan AIP YOUR CHILD'S PROGRESS COULD BE HELPED BY: 1st 2nd 3rd Arriving at school on time Beira reared forBein reared for class (homework and materialsand materials Continuing practice at home with adult so ision Ravin vour duld N school every stair--aH day Readin ro vour duld ever day END OF SCHOOL YEAR Your child is below grade level in ? Reading ? Writing ? Mathematics Academic Improvement Plan (AIP) ? Year 1 ? Year 2 Grade placement for School year: Promoted ? Promoted with AIP ? Promoted with Good Cause ? Retained MIS #9031.790 rev. 5/2000 Distribution: White - School, Cmary/Pink/Goldenrod - Parent tiMl IEP Meeting Date: 04 of Pe 3 Charlotte my Pu lic ch ols - Exceptional Student Education Goal pages exterM through leas ANNUAL GOALS AND SNORT-TERM INSTRUCTIONAL OBJECTIVES/BENCHMARKS Present Level of Educational Performance for Bated Upon Student Is Able (3 Measurable Annual Goal: Annual goals and short-term objectives or benchmarks must relate to meeting the student's needs resulting from the student's disability In ways that enable the student to be involved in and progress In the general curriculum and to meeting each of the student's other adu student' nsultlnq from the isablll 7 r s ty read . Cod (? 1 o n r boo/ The student's progress towards annual goals and the extent to which progress toward the objectives/benchmarks is sufficient to enable the student to achieve the annual goal by the end of the year will be reported to the parents each grading period. 'code/date progress: '(SP) Sufficient Progress to master Annual Goal or (IP) Insufficient Progress to master Annual Goal Assigned Instructional Duties for this Goal: Respo911 Itt1,,.tnAy.(rl0/yde planning, ?fe?me?r/?J do_ eymeriting student performance, consulting. Lead Teacher/staff IICC/A1CC6t''ffTT?? Other'- i3RF? TIIIeIOneain nl ale nisi Oe ef61e T;Nele..:u.. .a e.. , e.. Short-Term Instructional Objectives/Benchmarks ----- --- - ------ ----- Evaluation Plan Schedule Criteria Procedures Results' ?.? Cod wit '50un }rirr,e y aeoz dlerwhan ln?-fs words I k50*K1.) D(l`/° ?A?rl? QS AP 4 S l Wes fe s e 4h 7a ''"' r '? I r F Wode%etle results of Objectives based on the evaluation schedule): (M) Mastered (AP) Adequate Progress (LP) Limited Progress Whne: Pnnclpay5fudent Racems Yellow ESE Pink ParewGuaroan Gold ESE Teacher (copy for odor teacnels) Rev. 7.00 MIS. 9013-42 f,. wr Charlotte County Public Schools 1 Liberty Elementary School Thomas Gifford, Principal pp (941)255-7515 Wyk M 'C r/ a (rrn„ i r? F0 ?r 1 -LY Narrative Student: Cody R i pg l n Grade: 2 School Year:. 2000-01 Ist Trimester. odj I.5 o yeo I_ C en-? 4o have 1'n Class, ,: E L&Or A-5 herd very cla.? ! Con ?inue?-? wOrh w? Ali h„y, a4- hom& on I-5eadi n?3 and ,5pellin2g Onj .5en-lPn0e 5 ruCtu/LJ 2nd Trimester: li, 3rd Trimester. (,?O CLJ. t,Z UV,-LC-k)Ll,(„,, CAC, V T I (T r CUT I r de a0 I,t'2?1_Cl?? `t?/lc. ?aj Bedand u? m , a'm Pad` n- tr e 111 fJ. d. <?? crt-? emu- t r t.? Y 0 is ,s , 1k ANGELA RIEGLE, Respondent/Plaintiff V. RANDY L. RIEGLE, Petitioner/Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-4341 CIVIL ACTION-LAW CUSTODY ORDER (AddAND NOW, this L day of 2004, it is hereby ORDERED and DECREED that a hearing is scheduled for the A! day of /A 4c a _ -t 2001, at o'clock A. m. in Courtroom #y? at the Cumberland County Courthouse, Carlisle, Pennsylvania, to review Defendant's Petition for Special Relief. B e Court: Edward E. Guido I. •r +? o ?J L? V1?J i L7i?-`.?: ? s ?? ANGELA RIEGLE, Respondent/Plaintiff V. RANDY L. RIEGLE, Petitioner/Defendant AND NOW. this ORDERED and DECREED that: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-4341 CIVIL ACTION-LAW CUSTODY ORDER day of 2001, it is hereby Angela Riegle is in contempt of this Court's Order dated July 31, 2000; Angela Riegle shall release Cody to Randy L. Riegle on August 15, 2001, or August 16, 2001, at the time and date as set forth by Randy Riegle, or at any other time as set forth by Randy Riegle; Angela Riegle shall reimburse Randy L. Riegle an amount equal to $780.00 within 15 days of this Order. By the Court: Edward E. Guido J. ANGELA RIEGLE, Respondent/Plaintiff V. RANDY L. RIEGLE, Petitioner/Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-4341 CIVIL ACTION-LAW CUSTODY PETITION FOR SPECIAL RELIEF REQUESTING EMERGENCY RELIEF, AND NOW, comes Respondent/Defendant, Randy L. Riegle, by and through his attorneys, Hoffman Long LLP, and in support of his Petition for Special Relief avers as follows: 1. Petitioner/Defendant is Randy L. Riegle (hereinafter "Father") who resides at 497 Ricold Terrace, Port Charlotte, Florida 33954. 2. Respondent/Plaintiff is Angela Riegle (hereinafter "Mother") who resides at 320 3rd Street, West Fairview, PA or 448 State Street, West Fairview, PA. 3. Father has primary custody of the minor child pursuant to this Honorable Court's Order dated July 31, 2000. 4. Mother refuses to return the child to Father. Father bought a plane ticket and Mother refused to put the child on the plane last week, thus, Father lost $130 in the purchase of that ticket. 5. The child is scheduled to begin school on August 13, today, in Florida. 6. Mother is in contempt of this Honorable Court's Order. 7. Father is able to fly into Harrisburg on August 15, or August 16, as a friend has given him a free ticket. 8. Father will still have to buy his son's ticket which will be approximately $150. 9. Father has incurred attorney fees and costs and expenses in the approximate amount of $780 to date in enforcing this Order. 10. Father desires that this Honorable Court require Mother to release the child to Father. 11. The police will not enforce the custody order without an Order requiring them to do so. WHEREFORE, Father requests that this Honorable Court adjudge Mother in contempt and require her to release the child to Father on August 15 or August 16 and pay costs and expenses in the amount of $780.00. Respectfully submitted, Emily Lon offman, Esquire Sup. Ct. 1D # 66307 105 North Front Street Harrisburg, PA 17108 (717)233-1112 Date: 8/13/2001 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the attached document was served on the person below on this day by faxing and mailing a copy by U.S. First Class mail addressed as follows: Angela Riegle 320 3rd Street West Fairview, PA 17025 Respectfully submitted, By: Emily Long offman, Esquire Sup. Ct. ID # 66307 105 North Front Street P.O. Box 11475 Harrisburg, PA 17108 (717)233-1112 Date: 8/13/2001 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the attached document was served on the person below on this day by faxing and mailing a copy by U.S. First Class mail addressed as follows: Angela Riegle 448 State Street West Fairview, PA 17025 Respectfully submitted, By: Emily Long Hoffman, Esquire Sup. Ct. ID # 66307 105 North Front Street P.O. Box 11475 Harrisburg, PA 17108 (717)233-1112 Date: 8/13/2001 v? ?T :J. ANGELA RIEGLE, Respondent/Plaintiff V. RANDY L. RIEGLE, Petitioner/Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-4341 CIVIL TERM CIVIL ACTION - LAW CUSTODY IN RE: PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 22nd day of August, 2001, after hearing, the Petition for Special Relief is denied. Our custody order of June 12, 2000, shall replace the stipulated order of Julv 31, 2000, pending further order of this Court. It appears to the Court that a custody conciliation is scheduled for tomorrow. If the parties are not able to reach an agreement, we will schedule a hearing at the earliest possible date. Father is entitled to have custody of the child from this point and shall return the child right after lunch tomorrow, August 23, 2001. He may pick the child up at the mother's home. He is further directed to bring the child to the custody conciliation scheduled for tomorrow. By the Edward E. Guido, J. Emily Hoffman Long, Esquire Attorney for Petitioner/Defendant Angela Riegle 320 Third Street West Fairview, PA 17025 Respondent/Plaintiff, Pro se s rs ,; Ct>> . ?'r ^(UG ? 9 7ili) i ANGELA RIEGLE, IN THE COURT OF COMMON PLEAS OF Plaintiff ('LIMBERLAND 000NI'Y. PENNSYLVANIA : CIVIL ACTION - LAW RANDY L. RIEGLE, NO. 99 - 4341 CIVIL Defendant IN CUSTODY COURT ORDER AND NOW, this 39? day of August. 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: All prior custody orders entered in this case are vacated. 2. The Mother. Angela Riegle, and the Father. Randy L. Riegle, shall enjoy shared legal custody of the minor child, Cody David Riegle, bom June 28, 1992. The fact that the parties share legal custody of the minor child empowers the parties to obtain from all medical, school and other agencies dealing with the child any and all records pertaining to the child. 3. The Mother shall enjoy primary physical custody of the minor child. 4. Father shall enjoy, physical custody with the minor child as follows: A. During the summer months f'or a period of six (6) consecutive weeks, with the start and ending time to be arranged between the parties. B. During Spring Break from school for the entire spring break timetrame, with the times of exchanges to be agreed upon by the parties. C. Over the Christmas holiday in the year 2001, from December 26'h through the day before the child returns to school or at some other mutually agreeable time of exchange of custody. Both parties shall enjoy reasonable telephone and e-mail contact with the minor child when the child is in the custody of the other parent. Furthermore, the sister of husband's wilb shall have the ability to have periodic phone contact with the minor child. 6. Mother shall ensure that the child is, if authorized by the school district, enrolled in the appropriate IIP(ESC) classes in school. 7. The parties may modify the schedule as they agree without further order of this court. However, absent an agreement between the parties, this order shall control. 8. In the event either party desires to modify this order, that party may petition the court to have the case again scheduled with the custody conciliator for a conference. BY TF OUR'f ,I. Edward E. Guido cc: Angela Riegle 320 Third Street West Fairview, PA 17025 Randy Riegle 497 Ricold Terrace Port Charlotte, Ff. 33954 -,; ., I ? ?, j i i vl i ? . I ?.. _.. .__ '..;ciY ?.1'CI ;iCjY.? ?.'.`J ?%\ ANGELA RIEGL.E, Plaintiff v RANDY L. RIEGLE, Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO.99-4341 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: Cody David Riegle, born June 28, 1992. 2. A Conciliation Conference was held on August 23. 2001. with the following individuals in attendance: The Mother, Angela Riegle; and the Father, Randy L. Riegle. Both parties appeared without counsel. 3. The parties agree to the entry of an order in the form as attached. 119-7101 4?vl &Z-2-1 DATE Hubert X. Gilr. . Esquire Custody C ciliator SEP 01 2008 ANGELA REIGLE, IN THE COURT OF COMMON PLEAS Plaintiff, OF CUMBERLAND COUNTY, PENNSYLVANIA V. No. 99-4341 Civil Action - Law RANDY L. REIGLE, In Custody Defendant. AND NOW, this 14th day of August, 2000, the Conciliator, being advised by Plaintiffs counsel that all custody issues have been resolved by Stipulation of the parties, hereby relinquishes jurisdiction in this case. FOR THE COURT, Melissa Peel Greevy, Esquire Custody Conciliator ?;: ? ?? ,? ;.i ?: ?; ANGELA GREEN Plaintiff V. RANDY L. RIEGLE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4341 CIVIL TERM CUSTODY ACTION ORDER OF COURT AND NOW, this 18"" day of OCTOBER, 2005, we will treat the attached letter as a petition to modify custody. The Court Administrator is directed to schedule the matter for a conciliation conference. By the , Edward E. Guido, J. u, ngela Green 24 Maple Avenue Crestview Village Middletown, Pa. 17057 )Tandy L. Riegle 407 South Market Street Millersburg, Pa. 17061 Court Administrator ro' :sld IF- '! (.... lu Clerk or court One courthouse square CadW PA 17013 Attn: Judge Guido Office Randy Riegle Case N 994341 407 South MaAret Street MillenbuM PA 17061 Phone: (717) 692-2374 In August of 2001, I cane to PA from Florida to attend a court summons that was to create an agreement between myself and my son's mother Angela Green Tice agreement was to ensure that my son is raking care of and I was able to see him at the allotted times that was put in the agreement. The agreement was also set that my son's mother would not keep moving him out of his school district and making him even further behind in school. The agreement was signed and agreed among each party. Since this time. I have moved back to PA and my son's mother has broken the agreement over and over again, and I am asking the counts for their help. I am not sure where to start or how 1 go about getting a new court date to have Angela Green found in contempt because she his broken most of the agreements that was stated in the court documents. Frrst, let me begin by saying it was very hard for me to be separated from my son while I was in Florida, but due to my wife's mother's illness we had no choice but to move. The sad news was my mother-in-law pass in 2004 and we moved back to PA in June of 2014. After the courts gave custody back to Angela Green I did not see Cody for three years because every time we got a plane ticket to get hint she made excuses why we oould not have him It has been a great relief since I have been back to be able to see Cody, but a lot of concerns have come about in the last year and I think it is time to take control and make it right for my son. Let me name a few things that I am conceaned about. First of all, Angela Moved Cody out of the school District again and lie is not doing well in school at all. 1 have kept in touch with the new school and made sure he was put into spacial classes because lie can not read beyond a 4" to 5°' level. Because of the move, his older brother and sister moved back with their fattier because they did not litre the new school and the place they are living which is in a trailer park with no mom to play safely. Because of the area Cody does not go out and make friends he sits in the house and watches Wall day. Another concern, is that his mother is without a car and with Cody's medical problems we are concerned if there was an emergency bow would she get him to a DR., because they live miles away from anything close. Bceause of her car problems Cody was not able to attend his reading Sommer program that was to be for his benefit. When I called to ask him how he liked the program that is when he told me Oral his mother's car was broke down again and he did not go. There has been a few times we call and the phone has been disconnected and that is another concern. Angela is able to work but bas a problem keeping a job for long periods of time. I have ask numerous times for her to gel Cody into a Dentist, but it has been at least 2 }tars since be has been there and he needs to see one now. 1 have even offered to take him if he did not have a way there. The list could goes on and on about my concern's with my son. I would like to have custody of my son, but I know the courts parer dun the child stay with the mother. But I know in my heart that my wife and 1 could give him a loving secure and happy borne. Please let me know what I need to do in order to get another court date mid have the agreement up-dated. 1 appreciate your time in this natter and hope to hear from you soon. Randy w le / ? A/( ,P./ i rx.?t", (/ ,)-/ /)I " A (_ C-0.. 2 '?. /- V I L L'? V/ iA ? tk.- 5 -A ?.. C Ana 1IARRI56URG P-A 171 < S 07 OCT 2005 Pm 2 T Co ?r? ?d rv?i h - ' C) c) r, ANGELA GREEN IN TIII: C'OUK 1 01: CONTMON PLEAS 01: PLAINTIFF cuNlll{Rl.:wl) C'OUNT'Y. P[:NNSYLVANIA V. RANDY L. RIEGLE DEFENDANT 99-4341 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW. Monday, ctober 24, 2005 _ , upon consideration ol'the attached Complaint. it is hereby directed that parties and their respective counsel appear belbre Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday. December 01, 2005 tit 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an ellbrt will he made to resolve the issues in dispute; or i f this cannot be accomplished, to define and narrow the issues to he heard by the court, and to enter intoa temporary order. All children ?ge live or older may also be present at the conference. Failure to appear at the conl'crcnce may provide grounds for entry ol'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 e.8 hours prior to scheduled hearing. FOR THE COURT. Hy: _/s/ Hubert X. _Gilroys Esq. tl 1?_ -- Custody Conciliator }}J11 The Court of C'ontnton Pleas of Cumberland County is required by law to comply with the Americans with Disabilitcs Act of 1990. For information about accessible ]Facilities and reasonable accommodations available to disabled individuals having business belbre the court. please contact our office. All arrangements must be matte at least 72 hours prior to any hearing or business heloic the court. You must attend the schedule(] conference or hearing. YOU SHOULD TAKE PHIS PAPER TO YOUR Al I ORNI:Y A'f ()NC'E. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO T-O OR T ELEPHONL "fHE OFFICE SGT FORTH BELOW TO FIND OUT WIIFRE YOU CAN GET LE(iAl. IIEI.P. Cumberland Counts Bar Association 32 South Redbird Street C'ar'lisle. Penns0cania 17013 'I elephone (7) 17) 249-3 166 Ti._ .. u.n? le -d5 61rf 141elcel Ku ya %?c t 1 " I PtiFCEIVED nCT 1 y 2005 ANGELA GREEN IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. RANDY L. RIEGLE, NO. 99-4341 CIVIL TERM Defendant CUSTODY ACTION ORDER OF COURT AND NOW, this 18TH day of OCTOBER, 2005, we will treat the attached letter as a petition to modify custody. The Court Administrator is directed to schedule the matter for a conciliation conference. By Edward E. Guido, J. Angela Green 24 Maple Avenue Crestview Village Middletown, Pa. 17057 Randy L. Riegle 407 South Market Street Millersburg, Pa. 17061 Court Administrator :sld PiQ( DEC z G ZU05? ANGELA GREEN (formerly : IN THE COURT OF COMMON PLEAS OF ANGELA RIEGLE), : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v CIVIL ACTION - LAW RANDY L. RIEGLE, NO. 99-4341 Defendant IN CUSTODY COURT ORDER AND NOW, this po day of December, 2005, upon consideration of the attached Custody Conciliation report, it is ordered and directed that this Court's prior Order of August 30, 2001 is vacated and replaced with the following Order: 1. The mother, Angela Green, and the father, Randy L. Riegle, shall enjoy shared legal custody of Cody David Riegle, born June 28, 1992. In conjunction with the shared legal custody arrangement, both parties are able to obtain all medical, school and information from any other agency dealing with the child and any and all records pertaining to the child. 2. The mother shall enjoy primary physical custody of the minor child. 3. The father shall enjoy periods of temporary physical custody of the child as follows: a. On alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m. b. At such other times as agreed upon by the parties. 4. Major holidays shall be alternated between the parties to start on New Year's Day. Mother shall have New Year's Day 2006. The following holidays shall be alternating thereafter: Easter, Memorial Day,4ily 0, Labor Day,?Ianksgiving and Christmas. y L2 _ _. ' 5. For Christmas 2005, father shall have custody of the minor child from after school on Thursday, December 22"" until December 301, during which time father may take the child to Florida for a vacation. 6. During the summer months, father shall have custody of the minor child for six consecutive weeks. The start time shall be one week after the child ends school unless the parties agree to a different start time. 7. Mother shall insure that the child is, if authorized by the applicable school district, enrolled in the appropriate IEP (ESC) classes in school. 8. During the Spring Break, father shall also have custody for the entire Spring Break time frame, with the times to be agreed upon by the parties. 9. Both parties shall keep the other parent advised at all times with respect to their phone number and current mailing address, and neither party shall relocate without advising the other parent at least 30 days in advance. 10. Neither parent shall smoke when they have custody of the minor child, and both parents' shall endeavor to insure that the child is not exposed to anyone who smokes. i 1. This Order is entered in recognition of the fact that mother was not in attendance at the Conciliation Conference. In the event mother desires to have this Order modified or otherwise disagrees with the terms of this Order, mother may petition the Court to have the case again scheduled with the Custody Conciliator for a Conference. The Conciliator at that Conference could address all issues de Novo. 12. Both parties shall have reasonable telephone contact with the minor child, with mother affording father at a minimum phone contact with the minor child on Wednesday and Sunday evenings at 8:00 p.m. unless another time is agreed upon by the parties. 13. In the event mother is not available to take care of the child for a period of more than five hours during the time when mother has custody, mother should contact father and give father the opportunity to provide childcare for the minor under those circumstances. cc: Debra R. Mehaffie, Esquire Angela Green ?? - US A e ea ?Z v? a ?C ti Judge Edward E. Guido to ?/? FlLED-o iCc Of THE PROTH'NOTARY 2005 DEC 22 fal110: 4 7 Cute; ! l' ANGELA GREEN (formerly ANGELA RIEGLE), Plaintiff v RANDY L. RIEGLE, Defendan. Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-4341 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: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Cody David Riegle, born June 28, 1992. 2. A Conciliation Conference was held on December 20, 2005, with the following individuals in attendance: The father, Randy L. Riegle, with his counsel, Debra R. Mehaffle, Esquire. The mother, Angela Green, did not appear. A conference was scheduled on December 16's but was cancelled because of weather. A written notice was sent to mother concerning the rescheduling of the conference for December 20'", and father suggested at the Conciliation Conference that mother acknowledged to him that she was aware of the Conference. 3. The father was living in Florida back in 2001 when the existing Order was entered. He has since relocated back to Pennsylvania and is enjoying a period of time with the minor child, generally alternating weekends. Father wants an Order specifically allowing him to take the child to Florida over the Christmas Holiday and an Order setting forth specific periods of time for the father to have custody of the minor child. Father related to the Conciliator that the mother was in agreement to allow the father to take the child to Florida. 4. Based upon the above, the Conciliator recommends an Order in the form as attached. (? i DATE Hubert X. GiYoy, Esquire Custody Co11ilfator vifi JAN 0 6 IDD6 ANGELA GREEN, IN THE COURT OF COMMON PLEAS T Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA -v- No. 99-4341 RANDY L. RIEGLE, CIVIL ACTION-LAW Defendant CUSTODY ORDER AND NOW, this 901 day of 2006, it is hereby ORDERED and DEGREED that the attached Stipulation is hereby entered as an Order of Court. - BY THE COURT: J. c/ ( n O\ ,5 C; Th_ , 17y 2C:?o JA'i 1 0 i, 1 9: 07 ? y` 1.^./28!2885 18:14 7175611616 ANGELA GREEN, pwrrtiff -V- RANDY L RiEGLE, Defendant RI18ERT S MIRIN ESQ PAGE 83/84 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY. PENNSYLVANIA No. 994341 CIVIL ACTION-LAW CUSTODY CUSTODY STIPULATION AND NOW, this o40 day of k -ern 6 PQ 2005, with regard to the best intetcsts of the minor child, Cody David Riegle, born June 28, 1992, the parties a3ree as follows: The Father, Randy L. Riegle and the Mother, Angela Green shall share legal custody of their minor child, Cody David Riegie. They shall consult with each other relative to all iroporiam decisions concerning the subject minor child, including such matters as health, education and religion. The fact that the parties share legal custody of dw mirror child empowers the parties to obtain from all medical, school and other agencies dealing with the child any and all records pertaining to the child. 2. Father shall have primary physical custody of the minor child. 31 Mother shall enjoy periods of physical custody with the minor child during such rimes that the parties agree. 4. It is the intent of the parties that this custody stipulation be entered as an Odder of Court is Cumberland County and that all prior custody orders entered in this case be d. Witness Angela m t Randy L. 'ogle 12/2e/28N5 18:14 7175611616 ROBERT S KIRIN EM PAGE 84/84 COMMONWEALTH OF PENNSYLVANV, SS. COUNTY OF DAUPHN On the day of 2005, before me, a Notary Public in and for the Commonwealth of Pennsylvania, the undersigned officer gy appeared ANGELA GREEN, known to me (or satisfactorily Proven) to be one of the Parties executing the foregoing instrument. and she acknowledges the foregoing instrument to be her free act and deed IN WITNESS WHEREOF. I have hereunto set my hand and notary seal the day rod year first above written. Notary Public COMMONWEALTH OF PENNSYLVANTA COUNTY OF DAUPHIN as. si On the al day of a 2005, before tire, a Notary Public in and for the Commonwealth of Pennsylvania, the unddragacd officer, personally appeared. RANDY L, REIGLE, 'mown to roc (Dr satisfactorily proven) to be one of the parties execufing the foregoing instri men t. and he acknowledges the fiore instrument to be his free act and deed gniag IN WTNESS WHEREOF, I have hereunto set my hand and notary seal the day card .car first Wme written. . I V D)onalo - •: eyer,JO,NOtary PUblic L Member.Penoi a AeiabonofNotaries C MMONWEALTH OF PENNSYLVANIA AIOWry pubjiC NotarialSeal lllerob,Coro, Dauphin County Comm ?. • Explros Aug. 27, 2009 r q 00 N H uj( -•, .. , W L u) LL. ? v N U IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ANGELA GREEN, CIVIL ACTION-LAW Plaintiff CUSTODY V. RANDY L. RIEGLE, NO. 99-4341 Defendant CERTIFICATE OF SERVICE 1, Debra R. Mehaffie, hereby certify that on January 11, 2006, a true and correct copy of the foregoing Order of Court dated January 9, 2006 and Custody Stipulation on behalf of Defendant Randy L. Riegle was served upon the following by first class mail, postage prepaid: Angela Green 3288 Powells Valley Road Halifax, PA 17032 LAW OFFICES OF ROBERT S. MIRIN -Debra R. Mehaffie, Esquire 2515 North Front Street Harrisburg, PA 171 10 (717) 909-9900 I.D. No. 90951 O o U N 6ree-n vs. kie jle- QJl `rt1:A)5 Cu-5` 0dy pr,dr fo /Q -1 li>- OS- La Ce- A04- sc4nnect , r ANGELA GREEN Plaintiff V. RANDY L. RIEGLE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4341 CIVIL TERM CUSTODY ACTION ORDER OF COURT AND NOW, this 18TH day of OCTOBER, 2005, we will treat the attached letter as a petition to modify custody. The Court Administrator is directed to schedule the matter for a conciliation conference. By tW Edward E. Guido, J. t,Angela Green 24 Maple Avenue Crestview Village Middletown, Pa. 17057 ,,?andy L. Riegle 407 South Market Street Millersburg, Pa. 17061 Court Administrator J lo'?g o5 :sld n 4 v , Clerk of Court One courthouse square Carlisle, PA 17013 Randy Riegle Cane # 994341 407 South Market Street Millersburg, PA 17061 Phone: (717) 692-2374 Attn: Judge Guido Office in August of 2001,1 came to PA from Florida to attend a court summons that was to create an agreement between myself and my son's mother Angela Green. The agreement was to ensure that my son is taking care of and I was able to see him at the allotted times that was put in the agreement. The agreement was also set that my son's mother wood not keep owing him out of his school district and making him even farther behind in school. The agreement was signed and agreed among each party. Since this time, I have moved back to PA and my son's mother has broken the agreement over and over again, and I am asking the courts for their help. I am not sure where to start or bow I go about getting a new cart due to hove Angela Green found in contempt because she has broken most of the agreements that was stated in the court documents. First, let rue begin by saying it was very lard for me to be separated from my son while I was in Florida, but due to my wife's mother's illness we had no choice but to move. The sad news was my mother-in-law pass in 2(X)4 and we moved back to PA in June of 2004- After the courts gave custody back to Angela Green I did not see Cody for three years because every aline we got a plane ticket to get him she made excuses why we could not have lum It has been a great relief since I have been back to be able to see Cody, but a lot of concerns have come about in the last year and I think it is time to take control and make it right for my som het me name a few things flat I am concerned about. First of all, Angela Moved Cody out of the school District again and he is not doing well in school at all- I have kept in touch with the new school and made sure he was put into special classes because he can not read beyond a 4m to 5m level. Because of the move, his older brother and sister moved back with their father because they did not tike the new school and the place they are living which is in a trailer park with no room to play safety. Because of the area Cody does not go out and make friends he sits in the horse and watches TV all day. Another concern, is that his mother is without a car and with Cody's medical problems we are concerned if there was an emergency how would she gel him to a DR., because they live miles away from anything close. Because of her car problems Cody was not able to attend his reading summer program that was to be for his benefit. When I called to ask him how he liked the program that ins when he told me that his mother's car was broke down again and he did not go. There has been a few times we call and the phone has been disconnected and that is another concern. Angela is We to work but has a problem keeping a job for long periods of time. I have ask numerous times for her to get Cody into a Demist, bur it has been at least 2 years since he has been there and he needs to see one now. I bave even offered to take him if he did not have a way tyre. The list could goes on and on about my concern's with my son. I would like to have custody of my son, but I know the courts perfer that the child stay with the mother. But 1 know in my heart that my wife and I could give him a loving,secure and happy home. Please let me know what I need to do in order to get another court date and have the agreement updated. I appreciate your time in this matter and hope to hear from you soon. Sinq?kely, ? ? Randy Riec ?: ,. !\^?,? ? ?\\ -\? `A `. r{ 1: 4 ?. ?\ y i? ti ??i \. ?? C? 1 \_r ? V ?? ,. ^? 1 ' `^ ? ?/ \?. ?? k `\ n. \\I,X\\\\ V r` ? r l +\`? Y f? ?\ - U i ??.. i.J+ ???? d ?' p? Qp ? {'.% `01?` Wh? L' 1r? f ?.. y ??q M y\? `./O h ?1 r' r 41 ANGELA GREEN IN "THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND C'OUN"I'Y, PENNSYt_VANIA V. 99-4341 CIVIL. ACTVON LAW RANDY L, RIF.GLE IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, October 24, 2005 upon consideration of the attached Complaint. it is hereby directed that parties and their respective counsel appear before Hulbert X. Gilroy, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, December 01, 2005 at 8:30 AM for a Pte-Hearin , Custod} Conference. At such conference, an effort will be made to iesolVe the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the coup, and to enter into It temporary order. All children ate 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/ Hubert X. Gilroy F,sg. tl ?11__ Costodv 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 availahle to disabled individuals having business before the court, please contact our off ice. All arrangements must be made at least 72 hours prior to any hearing or business belorc the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER 1-0 YOUR ATTORNEY A I ONCF. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH 13ELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ?,Yrj f C nr ????` 40) .Svc S£' . ??? l ? -C'EIVED } nf'T i y 2005 ANGELA GREEN IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. RANDY L. RIEGLE, NO. 99-4341 CIVIL TERM Defendant CUSTODY ACTION ORDER OF COURT AND NOW, this 18TH day of OCTOBER, 2005, we will treat the attached letter as a petition to modify custody. The Court Administrator is directed to schedule the matter for a conciliation conference. By the Edward E. Guido, J. Angela Green 24 Maple Avenue Crestview Village Middletown, Pa. 17057 Randy L. Riegle 407 South Market Street Millersburg, Pa. 17061 Court Administrator :sld Ucl a CUU51;-, ANGELA GREEN (formerly : IN THE COURT OF COMMON PLEAS OF ANGELA RIEGLE), : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v CIVIL ACTION - LAW RANDY L. RIEGLE, NO. 99-4341 Defendant IN CUSTODY COURT ORDER AND NOW, this 40 day of December, 2005, upon consideration of the attached Custody Conciliation report, it is ordered and directed that this Court's prior Order of August 30, 2001 is vacated and replaced with the following Order: 1. The mother, Angela Green, and the father, Randy L. Riegle, shall enjoy shared legal custody of Cody David Riegle, born June 28, 1992. In conjunction with the shared legal custody arrangement, both parties are able to obtain all medical, school and information from any other agency dealing with the child and any and all records pertaining to the child. 2. The mother shall enjoy primary physical custody of the minor child. 3. The father shall enjoy periods of temporary physical custody of the child as follows: a. On alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m. b. At such other times as agreed upon by the parties. 4. Major holidays shall be alternated between the parties to start on New Year's Day. Mother shall have New Year's Day 2006. The following holidays shall be alternating thereafter: Easter, Memorial Day, 71y 4`"; Labor Day enksgiving and Christmas. r 5. For Christmas 2005, father shall have custody of the minor child from after school on Thursday, December 22°" until December 30', during which time father may take the child to Florida for a vacation. 6. During the summer months, father shall have custody of the minor child for six consecutive weeks. The start time shall be one week after the child ends school unless the parties agree to a different start time. 7. Mother shall insure that the child is, if authorized by the applicable school district, enrolled in the appropriate IEP (ESC) classes in school. 8. During the Spring Break, father shall also have custody for the entire Spring Break time frame, with the times to be agreed upon by the parties. 4. Both parties shall keep the other parent advised at all times with respect to their phone number and current mailing address, and neither party shall relocate without advising the other parent at least 30 days in advance. 10. Neither parent shall smoke when they have custody of the minor child, and both parents' shall endeavor to insure that the child is not exposed to anyone who smokes. 11. This Order is entered in recognition of the fact that mother was not in attendance at the Conciliation Conference. In the event mother desires to have this Order modified or otherwise disagrees with the terms of this Order, mother may petition the Court to have the case again scheduled with the Custody Conciliator for a Conference. The Conciliator at that Conference could address all issues de Novo. 12. Both parties shall have reasonable telephone contact with the minor child, with mother affording father at a minimum phone contact with the minor child on Wednesday and Sunday evenings at 8:00 p.m. unless another time is agreed upon by the parties. 13. In the event mother is not available to take care of the child for a period of more than five hours during the time when mother has custody, mother should contact father and give father the opportunity to provide childcare for the minor under those circumstances. cc: Debra R. Mehaffie, Esquire Angela Green - OS 0¢ /J a ed I 3., j5 Judge Edward E. Guido 11 t °t •Qf ',? ZV ??? ???1 ?,?v7.C'i, ?1l';''cd ?Hi ?G ANGELA GREEN (formerly ANGELA RIEGLE), Plaintiff v RANDY L. RIEGLE, Defendant Prior Judge: Edward E. Guido : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-4341 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: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Cody David Riegle, born June 28, 1992. 2. A Conciliation Conference was held on December 20, 2005, with the following individuals in attendance: The father, Randy L. Riegle, with his counsel, Debra R. Mehaffie, Esquire. The mother, Angela Green, did not appear. A conference was scheduled on December 16' but was cancelled because of weather. A written notice was sent to mother concerning the rescheduling of the conference for December 20', and father suggested at the Conciliation Conference that mother acknowledged to him that she was aware of the Conference. 3. The father was living in Florida back in 2001 when the existing Order was entered. He has since relocated back to Pennsylvania and is enjoying a period of time with the minor child, generally alternating weekends. Father wants an Order specifically allowing him to take the child to Florida over the Christmas Holiday and an Order setting forth specific periods of time for the father to have custody of the minor child. Father related to the Conciliator that the mother was in agreement to allow the father to take the child to Florida. 4. Based upon the above, the Conciliator recommends an Order in the form as attached. DATE Hubert X. Gi oy, Esquire Custody Co iliator ..?.?GVt?L?= i(.l. ii ?Y 1•JV?lCyr? ANGELA 232EEE Y, Plaintiff -S'- R-kNdDY L RIEGLE, Defawaht 711 1 PAM O V@4 TN THE COURT OF COly MON PLEAS CUMBERLAND C UN i Y. P gNSYLV ANIA acs ar3_FlAI CIVIL ACTIO -LAW CUSTODY AUDI' &TIPEiL40N AND NOL3r, this .2dth day of tA?Vernbe`P, ?. 2003. with regard to the beat interests of the minor child, Cody David Riegle, born I.me 28, !992 the Mies agrec as f.;llaurs. P_ The Father, Randy L Riegle and the Mother, Angela Greer. shall share !CVJ = *ody of their trrinar child, Cody David Riegle. They shall consuit with each other relative to all important decisions concerning the subject mit2or child, mccludmg such Rmtters as heahh, education and religion. The fact that the parties share legal custody of e minor child eaisower the parties to obtain fi-om all medical, school &nd other trcies dealing with the child any and all recoi s pawtaining to the child. 2. Father shall have primary physical custody of the mirror child. __ Mothar shall enjoy periods cf physical custody witch the wkirior child during such res that the panics agree, Ft is the intent of the panics that thiQ ey=dy stipul.r;icn be ertffed as an Order of Court in Cumberland County and that all p=rior custody orders e"Imed in this case be *tr!ess Angela G ' dy u .--'2- -'. 14 71"' 55;26"5 .?'=^ ? fIMIN, Z rWM 24104 G Gault Y OF DALTMIN 53- On the day of -. 2W>3 , bzfore me, a -Notary Pablic in and for the Comm -wCalth of. mw,lvaria, the ,undersi of =, :textsally zppeared.4NMLA GREEN, ltro-wn to me (pr satisfitatorily proven) to be oue of the parties exceu(mg the foregoing instmmert, Ana she acknowledges the foregoing mm"j imettt to nP her frm act and geed W WITNESS VMMOF, I have hereunto set my hard and notary seal the day v d -vw fist above written. NVotarj Nrublra iv?fONATALTH OF PENNI SYLVANIA LYn-OF CAL'PIiIN ss' on a 1st day of I c.e . , L Q Y ?> 2005, heiore rte, a Notary Public to wid for the Commonwealth of Pennsylvania, slxf' t t officer, ai1N ArrPATWNDY L. REIGLE, k w-r. to ze (u; saiits-awtoriiy pmwea) to be otto ofthe parties executing the fmvgoirg instrument. and he acltthrwied the smug instrument to be his flee act and deed. l 'viT'3ES?S W fIFREG}F. t hsve hertiustc get my hand and notary seat the ciao and ;+c&r 6TV above written. L r COMMONWEALTH OF PENNSYLVANIA Notari Notarial Seal Donalo :ever, Jr., Notary Public Millersb- -oro, Dauphin County My Commh. ^ Expires Aug. 27, 2009 Member, Penna.. -. *a Association of Notaries C. C? JAN 0 6 2006 ANGELA GREEN, IN THE COURT OF COMMON PLEAS f Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA -v- : No. 99-4341 RANDY L. RIEGLE, CIVIL ACTION-LAW Defendant CUSTODY ORDER AND NOW, this 0 day of 2006, it is hereby ORDERED and DEGREED that the attached Stipulation is hereby entered as an Order of Court. BY THE COURT: U L. to :6 0 ; ?- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ANGELA GREEN, Plaintiff CIVIL ACTION-LAW CUSTODY V. RANDY L. RIEGLE, Defendant NO. 99-4341 CERTIFICATE OF SERVICE I, Debra R. Mehaffie, hereby certify that on January 11, 2006, a true and correct copy of the foregoing Order of Court dated January 9, 2006 and Custody Stipulation on behalf of Defendant Randy L. Riegle was served upon the following by first class mail, postage prepaid: Angela Green 3288 Powells Valley Road Halifax, PA 17032 LAW OFFICES OF ROBERT S. MIRIN -die ra R. Mehaffie, Esquire 2515 North Front Street Harrisburg, PA 17110 (717) 909-9900 I.D. No. 90951 _ r -t C,_ 7