HomeMy WebLinkAbout99-06978'?
RICHARD & LISA EMORY IN T'H E COURTOF COMMON PLEAS OF
PLAIN'riFF : C'UMBIiRLAND COUNTY, PENNSYLVANIA
V. 99-6978 CIVIL AC'T'ION LAW
BRYAN & DANINE RAMMEL
IN CUSTODY
DITENDANI'
ORDER OF COURT
AND NOW, Friday, May 09, 2003 , upon consideration ol'the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, June 13, 2003 at 8:30 AM
for a Pre-Flearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR TILE COURT.
By: /sl Hilbert X. Gilroy. Esq. i.
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 SI IOULD TAKE TI [IS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOTAFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW 'f0 FIND OUT WHERE YOU CAN GETLEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle. Pennsylvania 17013
Telephone (717) 249-3166
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RICHARD and LISA EMORY, : IN THE COURT OF COMMON PLEAS OF
Plaintiffs, : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO - 99-6978 CIVIL TERM
BRYAN and DANINE RAMMEL, : IN CUSTODY
Defendants
ORDER OF COURT
AND NOW, 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 2003,
at _ .m., for a Pre-Hcaring 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. 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.
By the Court,
Date:
Custody Conciliator
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
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166 OR (800) 990-9108
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,
Pease 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.
RICHARD and LISA EMORY,
Plaintiffs,
V.
BRYAN and DANINE RAMMEL,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO - 99-6978 CIVIL TERM
IN CUSTODY
PETITION FOR MODIFICATION
Petitioner, Danine Rammel, by and through her counsel, Joan Carey of MidPenn
Legal Services, states the following:
1. Petitioner is the above-named Defendant, hereinafter referred to as the
mother, who currently resides at 205 Geary Avenue, 2nd Floor, New Cumberland,
Cumberland County Pennsylvania.
2. Respondents are the above-named Plaintiffs, Richard and Lisa Emory,
hereinafter referred to as the maternal uncle and aunt, who reside at 1161 Elm Street,
New Cumberland, Cumberland County, Pennsylvania.
3. The above-named petitioner is the biological mother of Matthew Rammel,
born March 24,1998 and the above-named respondents are the maternal uncle and aunt
of Matthew Rammel, born March 24,1998.
4. A custody order was entered on November 23,1999, which granted the
maternal uncle and aunt sole legal and physical custody of Matthew Rammel. A copy
of the order is attached and incorporated herein by reference.
5. The mother wishes to modify the November 23,1999 custody order for
reasons including the following:
a). At the time of the 1999 custody order, the mother was unable to
provide for Matthew; therefore, she asked her brother and his wife
to care for Matthew.
b). The mother is in a position to provide for the emotional, physical,
medical, educational and spiritual well-being of all of the children
and currently has custody of three (3) of her children: Brandon
Payne, born July 12,1993, Danielle Payne, born May 22,1992 and
Bryan Rammel, born October 17,1994
6. The maternal uncle and aunt are not acting in the child's best interests for
reasons including the following:
a). The maternal uncle and aunt are attempting to alienate the child
from his mother. The child's best interests will not be served if he
is further prevented from enjoying the parent/child relationship he
once had with his mother from his birth on March 24, 1998 to
November 23,1999, and continued to have with him prior to 2001,
when the maternal uncle and aunt kept the child from her.
b). The maternal uncle and aunt are further attempting to alienate the
child from his mother by informing the child that they in fact are
his natural father and mother.
c). During 2000 and 2001, cared for Matthew at various times,
including when he was with the maternal grandmother. In 2001,
Matthew lived with the mother and his siblings for approximately
three (3) weeks when the aunt asked her to take the child because
she was unable to handle him. By agreement, the mother returned
the child to the maternal uncle and aunt's custody.
d). Thereafter, the maternal uncle and aunt promised that the mother
could spend time with his mother and siblings, but when the
mother would attempt to make arrangements, the maternal uncle
and aunt would refuse.
d). The maternal uncle and aunt are keeping the child from deepening
his relationship with his mother and his siblings.
7. The mother requests that the Court modify its order of November 23,1999
to grant her periods of partial custody, increasing to primary custody within a
reasonable time.
WHEREFORE, Petitioner requests that the court schedule a conciliation
conference and grant her periods of partial custody, increasing to primary custody
within a reasonable time.
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Petitioner also requests any other relief this court deems just and proper.
Respectfully submitted,
IINm?,•J
an Carey
Attorney for Defendant/ Petitioner
8 Irvine Row
Carlisle, PA 17013
RICHARD and LISA EMORY, : IN THE COUR
" "?Plalntiffs'" : CUMBERLANI
V. : NO Ii Av?f
BRYAN and DANINE RAMMEL, : IN CUSTODY
Defendants
COMMON PLEAS OF'-,-.
UNTY `PENNSYLVANI,MLTERM'-
v
ORDER OF COURT
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?.??6!,; :,..VJ,.vP.'?.?.r:•'rir ? r -,<:- • ' '• `- itS/t ?{ +.?1. YES..
-AND NOW,-tliis 3 day ofNovemh 6r, 1939, upon presents
Stipulation, it is Ordered and Directed as follows
Richard and Liss Emory shall have sole legal and, ppysical custody of,.,.the child,
Matthew Rammel, born March 24, 1998; pursuant to the, Stipulation entered into
between the parties.
BY THE COURT,
-LSL Q:.
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TWE copy FPOdA RECOrZ0
In Testi:n.ny-.ae:rri, ' r,•rr un!o s•:t ray hand
and the seal cf s3id Court at Cerlisle, Pa.
This .... a,?3..^..' day of.......zu :..., 19..1
a- Prothonotary
VERIFICATION
We verify that the statements made in the foregoln? on e, "e d
;correct. I understand that false statements herein are made su to the penalties of
,18 Pa C S §4904 relating to unswom falsification to authorities x aL, :.3: ,
11-11 q9
Date
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Date
Lisa Emory, maternal aunt
Bryan Rammel, natural father
Rammel, natural
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8. The parties hereto consent to the entry of a Court Order evidencing their
Intent to transfer full legal and physical custody of the child from Bryan and Danine
Rammel to the Plaintiffs, Richard and Lisa Emory.
Respectfully, Submitted
TURO,.Li4W OFFICES -_------- -
Date' s:. Ron Turo, Esquire
__ __ _... .__ - °32?South-Bedford Street
Carlisle, PA 17013
(717) 245-9688
i ,; - Attorney for Plaintiffs
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and LISA EMORY, : IN THE COURT OF COMMON PLEAS OF
Plaintiffs, : CUMBERLAND COUNTY, PENNSYLVANIA
V.
BRYAN and DANINE RAMMEL,
Defendants
NO - 99-6978 CIVIL TERM
: IN CUSTODY
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Danine Rammel, Plaintiff, to proceed in forma ap uperis.
I, Joan Carey, attorney for the party proceeding in forma pauperis, certify that I
believe the party is unable to pay the costs and that I am providing free legal services to
the party.
Joan Carey
Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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RICHARD and LISA EMORY,
Plaintiffs
V.
BRYAN and DANINE RAMMEL,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.99- 64-1? CIVILTERM
IN CUSTODY
ORDER OF COURT
AND NOW, this ZZ,?G day of November, 1999, upon presentation of the within
Stipulation, it is Ordered and Directed as follows:
Richard and Lisa Emory shall have sole legal and physical stody of the child,
Matthew Rammel, born March 24, 1998, pursuant to the Stipulation entered into
between the parties.
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BY THE COURT.
RICHARD and LISA EMORY, : IN THE COURT OF COMMON PLEAS OF
Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-CIVIL TERM
V.
BRYAN and DANINE RAMMEL, : IN CUSTODY
Defendants
STIPULATION
1. Richard Emory is an adult individual currently residing at 1611 Elm Street,
New Cumberland, Cumberland County, Pennsylvania.
2. Lisa Emory is an adult individual currently residing at 1611 Elm Street,
New Cumberland, Cumberland County, Pennsylvania.
3. Danine Rammel is an adult individual currently residing in Carlisle,
Cumberland County, Pennsylvania.
4. Bryan Rammel is an adult individual currently residing in Carlisle,
Cumberland County, Pennsylvania.
5. Bryan and Danine Rammel are the parents of Matthew Rammel, born
March 24, 1998 who is currently residing with the Plaintiffs.
6. The Plaintiffs, Richard and Lisa Emory, are adult individuals who are the
maternal uncle and aunt of Matthew Rammel and who have been the primary custodian
of the child for the majority of his life.
7. The Defendants, Bryan and Danine Rammel, by entering into this
Stipulation, hereby give full legal and physical custody of the child, Matthew Rammel, to
the Plaintiffs, Richard and Lisa Emory.
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8. The parties hereto consent to the entry of a Court Order evidencing their
intent to transfer full legal and physical custody of the child from Bryan and Danine
Rammel to the Plaintiffs, Richard and Lisa Emory.
Date
Respectfully Submitted
TURO LAW OFFICES U`/
Ron Turo, Esquire
32 South Bedford Street
Carlisle, PA 17013
(717) 245-9688
Attorney for Plaintiffs
e?
VERIFICATION
We verify that the statements made in the foregoing Stipulation are true and
correct. I understand that false statements herein are made subject to the penalties of
18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
II-II-99
Date
rI-rI'?'?I
Date
- Q9
Date
Date
Lisa Emory, maternal aunt ( I -P,
'IAA y"
Bryan Rammel, natural father
CIJ n I\Cl 1L' Y C
Danine Rammel, natural mother
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RICHARD AND LISA EMORY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v : CIVILACTION-LAW
BRYAN AND DANINE RAMEL, : NO. 4`r -(,W7 CIVIL
Defendant : IN CUSTODY
COURT ORDER
AND NOW, this 3U0 day of ?.e.c , 2003, the conciliator being
advised the parties have reached n agreement, the conciliator relinquishes jurisdiction.
BY THE COURT,
Hubert X. Gilroy
Custody Conciliar
G
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