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HomeMy WebLinkAbout07-3547ROBERT HIPPENSTEEL, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY RENEE HIPPENSTEEL, Defendant. : NO. 07- -jsy7 CIVIL TERM COMPLAINT FOR CUSTODY The plaintiff, Robert Hippensteel, Jr., by his attorneys, the Family Law Clinic, sets forth the following cause of action in custody. 1. The plaintiff is Robert Hippensteel, Jr., residing at 60 Center Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Renee Hippensteel, residing at 56 Main Street, Plainfield, Cumberland County, Pennsylvania 17081. She receives mail at 862 Carlwynne Manor, Apartment B-311, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks primary custody o£ Name Present Residence Age Kayla Hippensteel 56 Main Street 3 years Plainfield, PA 17081 Carlisle, PA 17013 Kloey Hippensteel 56 Main Street 1 % years Plainfield, PA 17081 The children were born in wedlock. The children are presently in the custody of Renee Hippensteel, who resides at 56 Main Street, Plainfield, Cumberland County, Pennsylvania 17081. Since birth, the children have resided with the following persons at the following addresses: Persons Address Dates Renee Hippensteel 56 Main Street February 2007 to present Kadin Greene Plainfield, PA 17081 Robert Hippensteel, Jr. Tim Hippensteel 60 Center Street Carlisle, Pa, 17013 January 2007 to February 2007 Renee Hippensteel 56 Main Street January 2007 Kadin Greene Plainfield, PA 17081 Robert Hippensteel, Jr. 60 Center Street Renee Hippensteel Carlisle, PA 17013 Robert Hippensteel, Jr. 477 Mountain Road Renee Hippensteel Newville, PA 17241 Kadin Greene Tim Hippensteel Robert Hippensteel, Jr. 1244 Creek Road Renee Hippensteel Carlisle, PA 17013 Kadin Greene Tim Hippensteel Robert Hippensteel, Jr. 86 Tip Top Circle Renee Hippensteel Carlisle, PA 17013 Rhonda Harper Kadin Greene Nick Prosper February 2006 to January 2007 July 2005 to February 2006 June 2005 to July 2005 April 2005 to June 2005 Robert Hippensteel, Jr. 373 Sherwood Drive May 2004 to April 2005 Renee Hippensteel Carlisle, PA 17013 Kim Darhower Kadin Greene Tim Hippensteel The mother of the children is Renee Hippensteel. She is divorced. The father of the children is Robert Hippensteel, Jr.. He is divorced. 4. The relationship of plaintiff to the children is that of father. The plaintiff currently resides with the following persons: Name Tim Hippensteel Relationship brother 5. The relationship of defendant to the children is that of mother. The defendant currently resides with the following persons: Name Relationship Kadin Greene son Kayla Hippensteel daughter Kloey Hippensteel daughter 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth, or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: a. Plaintiff has had significant contact with the children for most of the children's lives; b. Plaintiff can provide the children with a stable home and environment with adequate moral, emotional, and physical surroundings as required to meet the children's needs; c. Plaintiff has encouraged contact between Defendant and the children and will continue to do so; d. Plaintiff believes that Defendant will not allow him to see the children in the future without a court order requiring her to do so; e. Plaintiff is willing to accept custody of the children. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody to the child have been named as parties to this action. WHEREFORE, plaintiff requests the court to grant him shared legal and physical custody of the children. Respectfully submitted, Date: ?S? x00-7 Holly O. Vaughn U Certified Legal Intern THOMA M. PLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in this Complaint 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. Robert Hippenste 1, Jr. (Plainti Pop? L?1 `Ij i CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford St. 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. Robert Hippensteel, Jr., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY Renee Hippensteel, Defendant NO. 07- CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Robert Hippensteel, Jr., Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date Respectfully submitte , Holly O. Va hn Certified Legal Intern ROBER INS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ?J ?'? ;I c? .--i ??? ?- .. ??;?. - ` i_ • ? , S ?: } ._j t` ? _ ?,, ^, ? 1 .?- J { ? •-+,?, .. ROBERT HIPPENSTEEL, JR. IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 07-3547 CIVIL ACTION LAW RENEE HIPPENSTEEL IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, June 20, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse,_ Carlisle on Thursday, July 12, 2007 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or pennanent 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/ ac ueline M. Verne Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 N NN" LbZtZ Robert Hippensteel, Jr., Plaintiff V. Renee Hippensteel, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN CUSTODY NO. 07-3547 CIVIL TERM CERTIFICATE OF SERVICE I, Holly O. Vaughn, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Custody Complaint on Renee Hippensteel, residing at 862 Carlwynne Manor, Apartment B-311, Carlisle, PA 17013, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Renee Hippensteel, on the the 19th day of June, 2007 as evidenced by the attached green card. Holly O. aughn Certified Legal I ern Anne ld-Fox, E Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ? d f'f " f co 177 m w ¦ Coto*s`BWA Y I z dfd 3:'A hem 4 h RNIhills Deprwy iedMi ml ¦ Pt(nt your rre m end itetd?sse on the mmm so that we con rbno *wood to you, ¦ Atlaoh V* cord to the bock of the lpim^ or on the font I qms pNrnlb. 1. Argdo Ad d l ' tm c by ( kdawaw ob writUarr+mm It Ylp. 4ww dwywy 1 ih 1. ,X19 ) -7,013 a70 sMal v Pip -. mim 0 Registered } Rehm PAos yt for Msr chandie 0 IroAed MW 0 C.O.D. 4. Reshicted DW w y? (t vft Fee) > Fes 2' A`"Me Number 7005 0390 0003 2632 5607 (1Fwnfs/fram wrv" /a PS Form 3811, February no Dowm ft Askm Item IF' 1025W-M-M-1540 Robert Hippensteel, Jr., Plaintiff V. Renee Hippensteel, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN CUSTODY NO. 07-3547 CIVIL TERM CERTIFICATE OF SERVICE I, Holly O. Vaughn, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Custody Complaint on Renee Hippensteel, residing at 56 Main Street, Plainsfield, PA 17081, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Renee Hippensteel, on the 12th day of June, 2007 as evidenced by the attached green card. 1?ka. I&W Holly O. aughn Certified Legal Intern V Z Mega iesmeyer, Esq. Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 2 i47 L) l;_ f• >? Mom 4 N Rembiclsd IaAWY Is dMI cl ¦ P*tt y ow ttn,r. and a ftem on ttta atiarras so 'we can ratum the card to you. • Aftd Iis oartoto the bw* of the %r w on the *ont if epme psm t. Attaw Added to ka-n.at1?. sed Agent M A"y adMW rtiMmW *wn ftm 17 UYfm k YE$, W*W dAWY 0&*00 below: 0 No a. t wom type Hlwd MOV O Bcpnes M@N o Rspwlered %Retum RmoW for McPCtra vow O (IYe Ked Mot ? C.O.D. 4. R*sbicted DWvery7 (Extra Fee) Yes N O D C N CYN `co c gn> E` -0 On ,5 m 2. ArtloleNunAw 7005 0390 0003 2632 5614 (Tn?rra/e? from aewk?e Ps Form 3811, February 2004 D I M I Main A a IPI 102595-02-M-1540 Robert Hippensteel, Jr., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY Renee Hippensteel, Defendant. : NO. 07-3547 CIVIL TERM CUSTODY AGREEMENT THIS AGREEMENT, made this day of Juh , 2007, between Robert Hippensteel, Jr. ("Father") and Renee Hippensteel ("Mother") concerns the custody of their children: Kayla Hippensteel, born May 10, 2004 and Kloey Hippensteel, born December 10, 2005. Father and Mother desire to enter into an agreement as to the custody of the children. Father and Mother agree to the following. 1. Father and Mother shall share legal custody of the children. 2. Mother shall have primary physical custody of the children. 3. Father shall have periods of partial physical custody of the children in accordance with the following schedule: a. Alternating weekends from Friday to Sunday; b. One day a week on a day the parties mutually agree. 4. Father and Mother will agree upon drop off and pick up times and locations. 5. Father and Mother will agree upon how they will share holidays with children. 6. Each parent may travel with the children out of the state after providing the other parent with written notice two weeks in advance of the planned trip and with the other parent's consent. 7. Father and Mother will notify each other of all medical care the children receive while in the parent's care. Father and Mother will notify the other immediately of medical emergencies which arise while the children are in that parent's care. 8. Neither parent will do anything which may estrange the children from the other party, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love and respect for the other parent. 9. Mother acknowledges that the Family Law Clinic represents only Father's interest in this matter and has given her no legal advice other than that she should seek the advice of legal counsel. 10. The parties intend to be bound by the terms of this agreement and intend for this Agreement to be made an Order of Court. Robert Hippenste , Jr., Plaintiff Renee Hippenste efendant ?a,014. al-1w Holly O. aughn Certified Legal Intern Counsel for Plaintiff XGt?c?AielQ?n?1d- ?el? ROBERTE. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Counsel for Plaintiff FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 Fax (717)243-3639 r-? rv Fll Cl JUL S 0 2001 Robert Hippensteel, Jr., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY Renee Hippensteel, Defendant. : NO. 07-3547 CIVIL TERM ORDER OF COURT AND NOW, this day of -SAY , 2007, upon review of the parties' signed agreement, the custody conciliation conference scheduled for August 14, 2007 before Jacqueline M. Verney, Esq. is cancelled and the following Custody Agreement dated July 10, 2007 is entered as an Order of the Court: 1. Father and Mother shall share legal custody of the children, Kayla Hippensteel, born May 10, 2004, and Kloey Hippensteel, born December 10, 2005. 2. Mother shall have primary physical custody of the children. 3. Father shall have periods of partial physical custody of the children in accordance with the following schedule: a. Alternating weekends from Friday to Sunday; b. One day a week on a day the parties mutually agree. 4. Father and Mother will agree upon drop off and pick up times and locations. 5. Father and Mother will agree upon how they will share holidays with children. 6. Each parent may travel with the children out of the state after providing the other parent with written notice two weeks in advance of the planned trip and with the other parent's consent. 7. Father and Mother will notify each other of all medical care the children receive while in the parent's care. Father and Mother will notify the other immediately of medical emergencies which arise while the children are in that parent's care. 8. Neither parent will do anything which may estrange the children from the other party, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love and respect for the other parent. By the Court, IN\ A, '? ii}} ;. g x.J "? ? r? n z 7 F~ ? `iIt sa y ?? a ?? i t???` lt??l ? ? ii-{.1. ?vn' Robert Hippensteel, Jr., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW IN CUSTODY Renee Hippensteel, Defendant NO. 07-3547 CIVIL TERM CERTIFICATE OF SERVICE I, Holly O. Vaughn, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the July 23, 2007 Order of Court on Renee Hippensteel by depositing on this date a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid, addressed as follows: Ms. Renee Hippensteel 862 Carlwynne Manor Apartment B-311 Carlisle, PA 17013. a '-1-0 a-7 Date Holly O. aughn Certified Legal Intern 714v- (?.' /2'Aa I Anne ald-Fox, E Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ° C7 ca 1A "? 91 . NOV 0 5 2007 ROBERT HIPPENSTEEL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-3547 CIVIL ACTION - LAW RENEE HIPPENSTEEL, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 2nd day of November, 2007, the parties having reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, A acq ine M. Verney, Esquire, s -,, j ?Hi :if_ ROBERT HIPPENSTEEL, JR., Petitioner V. RENEE HIPPENSTEEL, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO: 07-3547 CIVIL ACTION - LAW IN CUSTODY PETITION TO MODIFY CUSTODY 1. Petitioner is Robert Hippensteel, Jr., who resides at 253 West North Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Respondent is Renee Hippensteel, who resides at 311B Carlwynne Manor, Carlisle, Cumberland County, Pennsylvania 17013. 3. On July 23, 2007, the Honorable M. L. Ebert, Jr. entered a Custody Order attached as Exhibit "A". 4. Since the entry of said Order, there has been a significant change in circumstances in that: a) Mother has not been providing proper parental control and support of the minor children. b) Children & Youth Services had to intervene and had voluntarily asked Mother to relinquish her custody of the children to Father for one (1) month. 5. The best interest of the children will be served by the Court modifying said Order. WHEREFORE, Petitioner prays this Court to grant the modification of the Custody Order as follows: Father having primary physical custody of the minor children with mother having periods of visitation. Respectfully Submitted, Rominger & Associates E Date: August 12, 2008 arl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID# 81924 Attorney for Petitioner ROBERT HIPPENSTEEL, JR., : IN THE COURT OF COMMON PLEAS Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO: 07-3 547 RENEE HIPPENSTEEL, : CIVIL ACTION -LAW Respondent : IN CUSTODY VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing Petition 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. Date. 84 ,09 Robert Hippensteel, ROBERT HIPPENSTEEL, JR., Petitioner V. RENEE HIPPENSTEEL, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 07-3547 CIVIL ACTION -LAW IN CUSTODY CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Petitioner, herby certify that I this day served a copy of the within Petition to Modify Custody upon the following by depositing the same in the United States mail, first class, postage prepaid addressed as follows: Renee Hippensteel 311B Carlwynne Manor Carlisle, Pennsylvania 17013 Respectfully Submitted, Rominger & Associates Date: August 12, 2008 K E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID# 81924 Attorney for Petitioner JUL 80 2007 Robert Hippensteel, Jr., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY Renee Hippensteel, Defendant. : NO. 07-3547 CIVIL TERM ORDER OF COURT AND NOW, this day of -S jk , 2007, upon review of the parties' signed agreement, the custody conciliation conference scheduled for August 14, 2007 before Jacqueline M. Verney, Esq. is cancelled and the following Custody Agreement dated July 10, 2007 is entered as an Order of the Court: 1. Father and Mother shall share legal custody of the children, Kayla Hippensteel, born May 10, 2004, and Kloey Hippensteel, born December 10, 2005. 2. Mother shall have primary physical custody of the children. 3. Father shall have periods of partial physical custody of the children in accordance with the following schedule: a. Alternating weekends from Friday to Sunday; b. One day a week on a day the parties mutually agree. 4. Father and Mother will agree upon drop off and pick up times and locations. Exklb4 IA u 5. Father and Mother will agree upon how they will share holidays with children. 6. Each parent may travel with the children out of the state after providing the other parent with written notice two weeks in advance of the planned trip and with the other parent's consent. 7. Father and Mother will notify each other of all medical care the children receive while in the parent's care. Father and Mother will notify the other immediately of medical emergencies which arise while the children are in that parent's care. 8. Neither parent will do anything which may estrange the children from the other party, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love and respect for the other parent. By the Court, Robert Hippensteel, Jr., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION-LAW IN CUSTODY Renee Hippensteel, : Defendant NO. 07-3547 CIVIL TERM CERTIFICATE OF SERVICE I, Holly O. Vaughn, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the July 23, 2007 Order of Court on Renee Hippensteel by depositing on this date a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid, addressed as follows: Ms. Renee Hippensteel 862 Carlwynne Manor Apartment B-311 Carlisle, PA 17013. a '-)'0 o-1 Date 41'". A*( - Holly O. aughn Certified Legal Intern r_?Y,f . . /2"Os' - ?? Anne Wd-Fox, E Supervisin Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 r.C' . 1I?? t,v li;i ?I?u ?J x*• t rCR ROBERT HIPPENSTEEL, JR., Petitioner V. RENEE HIPPENSTEEL, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 07-3547 CIVIL ACTION - LAW IN CUSTODY EMERGENCY PETITION FOR SPECIAL RELIEF AND NOW, comes Robert Hippensteel, Jr., by and through his counsel Karl E. Rominger, Esquire, and avers as follows: 1. Petitioner is Robert Hippensteel, Jr., who resides at 253 West North Street, Carlisle, Pennsylvania 17013. 2. Respondent is Renee Hippensteel, who resides at 311B Carlwynne Manor, Carlisle, Pennsylvania 17013. 3. Petitioner and Respondent are the natural parents of Kayla Hippensteel, born May 10, 2004, and Kloey Hippensteel, born December 10, 2005. 4. Petitioner filed a Custody Complaint on June 18, 2007, and conciliation was scheduled for July 12, 2007. 5. Petitioner and Respondent signed a Custody Agreement which was entered on July 10, 2007, and an Order or Court entered by the Honorable M. L. Ebert, Jr., on July 23, 2007, granting Mother primary physical custody of the minor children with Father have periods of partial physical custody on alternating weekends and one day every week. 6. Since said Order Respondent has not been providing proper parental control and support of the minor children. 7. Cumberland County Children & Youth Services had to intervene and had voluntarily asked Respondent to relinquish her custody of the minor children to Petitioner for at least a period of one (1) month. WHEREFORE, Petitioner prays this Court grant him primary physical custody of the minor children pending conciliation and a full hearing on the matter with Mother having visitation of the minor children as agreed by the parties. Respectfully Submitted, Rominger & Associates Date: August 12, 2008 1 ;ER ominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID# 81924 Attorney for Petitioner ROBERT HIPPENSTEEL, JR., : IN THE COURT OF COMMON PLEAS Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO: 07-3547 RENEE HIPPENSTEEL, : CIVIL, ACTION -LAW Respondent : IN CUSTODY VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing Petition 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. Date: 94-00 Robert Hippensteel, 'it. ROBERT HIPPENSTEEL, JR., : IN THE COURT OF COMMON PLEAS Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. NO: 07-3547 RENEE HIPPENSTEEL, : CIVIL ACTION -LAW Respondent : IN CUSTODY CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Petitioner, herby certify that I this day served a copy of the within Emergency Petition for Special Relief upon the following by depositing the same in the United States mail, first class, postage prepaid addressed as follows: Renee Hippensteel 311 B Carlwynne Manor Carlisle, Pennsylvania 17013 Date: August 12, 2008 Respectfully Submitted, Rominger & Associates E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court 1D# 81924 Attorney for Petitioner N ? ! V • ,' ROBERT HIPPENSTEEL, JR. IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. RENEE HIPPENSTEEL DEFENDANT 2007-3547 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, August 15, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, September 16, 2008 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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/ ac ueline M. Verne Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 5RV gall w'r'?1 ROBERT HIPPENSTEEL, JR., PETITIONER V. RENEE HIPPENSTEEL, RESPONDENT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-3547 CIVIL IN RE: EMERGENCY PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 18th day of August, 2008, upon consideration of Father's Emergency Petition for Special Relief, and the Court noting that a custody conciliation hearing is scheduled in this matter for September 16, 2008, at 10:30 a.m. and that Cumberland County Children and Youth Services has become involved in this case, IT IS HEREBY ORDERED AND DIRECTED that pending the custody conciliation hearing, Father shall be granted primary physical custody of the minor children, Kayla Hippensteel, born May 10, 2004, and Kloey Hippensteel, born December 10, 2005. Supervised visitation of the children with the Mother will be permitted subject to a schedule and conditions established by Cumberland County Children and Youth Services. By the Court, y*k -k U. M. L. Ebert, Jr., J. P Xarl Rominger, Esquire Attorney for Petitioner /enee Hippensteel, Pro Se Respondent CCC&YS - f* S ?? I g f p? bas 90 -? wd $1 SAV Gooz A L 01-42C)-{#311 it ., SFP' 17 2008 ROBERT HIPPENSTEEL, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-3547 CIVIL ACTION - LAW RENEE HIPPENSTEEL, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of S C???Cw?IQ c,? , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated July 23, 2007 and August 18, 2008 are hereby vacated. 2. The Father, Robert Hippensteel, Jr. and the Mother, Renee Hippensteel, shall have shared legal custody of Kayla Hippensteel, born May 10, 2004 and Kloey Hippensteel, born December 10, 2005. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to medical, dental, religious or school records, the residence address of the children and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to- school nights, and the like. 3. Pending Mother obtaining appropriate housing that accommodates the children, Father shall have primary physical custody of the children. Mother shall have periods of partial physical custody as agreed by the parties. ti 4. Once Mother obtains appropriate housing that accommodates the children, the parties shall share physical custody of the children on a week on/week off schedule. The day and time of exchange shall be Sundays at 5:00 p.m. 5. Holidays shall be shared as agreed by the parties. 6. Mother shall have physical custody of the children on Mother's Day and Father shall have physical custody of the children on Father's Day at times agreed by the parties. 7. Neither party may partake in illegal drugs or consume alcohol to the point of intoxication immediately before or during their periods of physical custody. 8. Transportation shall be shared as agreed by the parties. 9. The parties shall have liberal telephone contact with the children. 10. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, M.L. Ebert, Jr., J. Z cc: j?c'arl E. Rommger, Esquire, Counsel for Father -Renee Hippensteel, pro se 862 Carlwynne Manor Apt B311 Carlisle, PA 17013 0,0 P Occ rytti t LCC-L 4/,,X/os ?^7 ?t'? .1r?'i 1 ip?iA `J. V!NV ? 1AS N-3d 90 M Wd 61 83S OCOZ AbViONO"l-LLU?Id ':.Hi JO "HC-CITH P . `? ROBERT HIPPENSTEEL, JR., Plaintiff V. RENEE HIPPENSTEEL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2007-3547 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: M.L. Ebert, Jr., J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kayla Hippensteel May 10, 2004 Father Kloey Hippensteel December 10, 2005 Father 2. A Conciliation Conference was held in this matter on September 16, 2008, with the following in attendance: The Father, Robert Hippensteel, Jr., with his counsel, Michael O. Palermo, Jr., Esquire, and the Mother, Renee Hippensteel, pro se. 3. Prior Orders of Court were entered by the Honorable M.L. Ebert, Jr. dated July 23, 2007 and August 18, 2008, providing for shared legal custody and Father having primary physical custody with Mother having supervised visitation. 4. The parties agreed to an Order in the form as attached. g-??-off Date I/Jacq661ine M. Verney, Esquire Custody Conciliator ROBERT HIPPENSTEEL, JR., Petitioner V. RENEE HIPPENSTEEL, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 07-3547 CIVIL ACTION - LAW IN CUSTODY PETITION TO MODIFY CUSTODY 1. Petitioner is Robert Hippensteel, Jr., who resides at 253 West North Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Respondent is Renee Hippensteel, who resides at 862 Carlwynne Manor, Apt. B311, Carlisle, Cumberland County, Pennsylvania 17013. 3. On September 19, 2008, the Honorable M. L. Ebert, Jr. entered a Custody Order attached as Exhibit "A". 4. Since the entry of said Order, there has been a significant change in circumstances in that: a) Mother has not been providing proper parental control and support of the minor children. b) Children and Youth Services is involved with Mother through another custody matter. 5. The best interest of the children will be served by the Court modifying said Order. WHEREFORE, Petitioner prays this Court to grant the modification of the Custody Order as follows: Father having primary physical custody of the minor children with mother having periods of supervised visitation as agreed by the parties. Respectfully Submitted, Rominger & Associates Date: January 2, 2009 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID# 81924 Attorney for Petitioner ROBERT HIPPENSTEEL, JR., : IN THE COURT OF COMMON PLEAS Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO: 07-3547 RENEE HIPPENSTEEL, : CIVIL ACTION -LAW Respondent : IN CUSTODY VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to unworn falsification to authorities. t Date: I az" 4 Robert Hippensteel, r. ROBERT HIPPENSTEEL, JR., Petitioner v. RENEE HIPPENSTEEL, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 07-3547 CIVIL ACTION - LAW : IN CUSTODY CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Petitioner, herby certify that I this day served a copy of the within Petition to Modify Custody upon the following by depositing the same in the United States mail, first class, postage prepaid addressed as follows: Renee Hippensteel 862 Carlwynne Manor, Apt. B311 Carlisle, Pennsylvania 17013 Respectfully Submitted, Rominger & Associates Date: January 2, 2009 arl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID# 81924 Attorney for Petitioner SEP 17 ZU06 ROBERT HIPPENSTEEL, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-3547 CIVIL ACTION - LAW RENEE HIPPENSTEEL, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of , 2008, upon consideration of the attached Custody Concilia ion Report, it is ordered and directed as follows: 1. The prior Orders of Court dated July 23, 2007 and August 18, 2008 are hereby vacated. 2. The Father, Robert Hippensteel, Jr. and the Mother, Renee Hippensteel, shall have shared legal custody of Kayla Hippensteel, born May 10, 2004 and Kloey Hippensteel, born December 10, 2005. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the children including. but not limited to medical, dental, religious or school records, the residence address of the children and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to- school nights, and the like. 3. Pending Mother obtaining appropriate housing that accommodates the children, Father shall have primary physical custody of the children. Mother shall have periods of partial physical custody as agreed by the parties. e Wt4 1A It wl A Ow 6ult?a 4. Once Mother obtains appropriate housing that accommodates the children, the parties shall share physical custody of the children on a week on/week off schedule. The day and time of exchange shall be Sundays at 5:00 p.m. Holidays shall be shared as agreed by the parties. 6. Mother shall have physical custody of the children on Mother's Day and Father shall have physical custody of the children on Father's Day at times agreed by the parties. 7. Neither party may partake in illegal drugs or consume alcohol to the point of intoxication immediately before or during their periods of physical custody. Transportation shall be shared as agreed by the parties. 9. The parties shall have liberal telephone contact with the children. 10. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, 'f NY L. Ebert, r., J. cc: Karl E. Rominger, Esquire, Counsel for Father Renee Hippensteei, pro se 862 Carlwynne Manor Apt B311 Carlisle, PA 17013 y X A.? . act ROBERT HIPPENSTEEL, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-3547 CIVIL ACTION - LAW RENEE HIPPENSTEEL, Defendant : IN CUSTODY PRIOR JUDGE: M.L. Ebert, Jr., J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kayla Hippensteel May 10, 2004 Father Kloey Hippensteel December 10, 2005 Father 2. A Conciliation Conference was held in this matter on September 16, 2008, with the following in attendance: The Father, Robert Hippensteel, Jr., with his counsel, Michael O. Palermo, Jr.. Esquire, and the Mother, Renee Hippensteel, pro se. 3. Prior Orders of Court were entered by the Honorable M.L. Ebert, Jr. dated July 23, 2007 and August 18, 2008, providing for shared legal custody and Father having primary physical custody with Mother having supervised visitation. 4. The parties agreed to an Order in the form as attached. C, (e - o CI/Y Date acq line M. Verney, Esquire Custody Conciliator _? tt z .. ,_? C_ __ 1 ? ? ? ?? (?,} f ., '1 ,3 ? ;' t ROBERT HIPPENSTEEL, JR. IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. RENEE HIPPENSTEEL DEFENDANT 2007-3547 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, January 12, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Monday, February 09, 2009 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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/ ac ueline M. Verne Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 ??', Telephone (717) 249-3166 VANVAIAS-NrAd )4N n ? ' 1 '01 WV ? ? ? i t? :io FEB 1? o s lose ROBERT HIPPENSTEEL, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-3547 CIVIL ACTION - LAW RENEE HIPPENSTEEL, Defendant : IN CUSTODY TEMPORARY ORDER OF COURT AND NOW, this 1'6 day of V e.,o 2009, upon consideration of the attached Custody Conciliation Report, It is ordered and directed as follows: 1. The prior Order of Court dated September 19, 2008 shall remain in full force and effect with the following modifications. 2. Father shall have primary physical custody of the children. 3. Mother shall have partial physical custody of the children on alternating weekends, from Friday to Sunday at times agreed to by the parties. 4. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Either party may contact the Conciliator within 30 days of the date of this Order to schedule another conciliation conference. BY THE COURT, \ --" LA 4. M.L. Ebert, Jr., J. cc: Karl E. Rominger, Esquire, Counsel for Father Renee Hippensteel, pro se 862 Carlwynne Manor Apt B311 Carlisle, PA 17013 ?iz?v q fu'IMVAIAS,",?Nlf 6 ? ' (i Wd 31 93J 600Z 300-_ C. -GQ u . ^, l ROBERT HIPPENSTEEL, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-3547 CIVIL ACTION - LAW RENEE HIPPENSTEEL, Defendant : IN CUSTODY PRIOR JUDGE: M.L. Ebert, Jr., J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kayla Hippensteel May 10, 2004 shared Kloey Hippensteel December 10, 2005 shared 2. A Conciliation Conference was held in this matter on February 9, 2009, with the following in attendance: Karl E. Rominger, Esquire, Counsel for Father, Robert Hippensteel, Jr. Mother, Renee Hippensteel, did not appear, although served with notice of the conference. 3. A Prior Order of Court was entered by the Honorable M.L. Ebert, Jr. dated September 19, 2008, providing for shared legal custody and shared physical custody. 4. Counsel for Father requested an Order in the form as attached. a g -0 q ?(/( Date a?neM. e y, Esquire Custody Conciliator c? ROBERT HIPPENSTEEL, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-3547 CIVIL ACTION - LAW RENEE HIPPENSTEEL, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 14th day of September, 2009, neither party having requested another conciliation conference and ninety days having passed since the last conference, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, ac Veline M?Ve e y, Esquire, C ody Conciliator OF THE PF'(*lr ^'l'()T PY 2009 SEP 15 A" 9.2 r??