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HomeMy WebLinkAbout07-4431 IN THE COURT OF COMMON PLEAS OF PERRY COUNTY, PENNSYLVANIA OFFICE OF PROTHONOTARY LARRY RUNK II FAMILY COURT #2007-00042 V REBECCA RUNK CERTIFICATION OF DOCKET ENTRIES I, Brenda J. Albright, Prothonotary Of The Court Of Common Pleas Of Perry County , Pennsylvania, Do Hereby Certify That The Following Is A True, Correct And Full Copy Of The Docket Entries In The Above Captioned Case. IN TESTIMONY WHEREOF, I HAVE HEREUNTO SET MY AND A OFFICIAL SEAL OF THE SAID COURT ON THE 4TH DAY OF JUNE, A.D. 2007 ~ PRHQNOy BY DEPUTY # ~~~ ~~~ .~ ~! ~` ~1 ~. ~~ ., Date: 6/2007 41st Judicial District of PA, Perry County Branch Time: 11:41 AM Complete Case History Page 1 of 2 Case: FC-FC-2007-00042 LARRY RUNK II vs. REBECCA RUNK Filed: 2/8/2007 Subtype: FAMILY CUSTODY Physical File: Y Appealed: N Comment: 04/23/07 LIST FOR TRIAL Status History Pending TRANFERRED Judge History Date 2/8/2007 Payments ABOM Plaintiff Name: Address 2/8/2007 5/1 /2007 Judge MORROW, KATHY A. Receipt Date 26513 2/8/2007 RUNK, LARRY II Millerstown Phone: Home: Employer: Litigant Type: Comment: Attorneys KUTULAKIS, JASON P. ESQ Defendant Name: RUNK, REBECCA Address: PA 17062 Work: Reason for Removal Current User: RUTH S Type Amount Civil Filing 97.50 Total 97.50 (Primary attorney) CARLISLE PA 17013 Phone: Home: Work: Employer: Litigant Type: Comment: Attorneys SCHERER, MICHAEL A ESQ (Primary attorney) Hearings From To Judge 3/13/2007 08:30 AM MORROW, KATHY A. Register of Actions 2/8/2007 New Case filed. Complaint Custody & Order filed .Exit to Judge Filing: Complaint Custody Paid by: ABOM Receipt number: 0026513 Dated: 2/8/2007 Amount: $97.50 (Check) SSN: DOB: Sex: Send notices: Y Send Notices SSN: DOB: Sex: Send notices: Y Send Notices Type CUSTODY CONFERENCE MORROW, KATHY A. MORROW, KATHY A. MORROW, KATHY A. CERTIFIED TRUE COPY DEPUTY PROTHONOTARY Date: 6/x`/2007 Time: 11:41 AM Page 2 of 2 Register of Actions 2/12/2007 Order dated 02/09/07 filed. Hearing scheduled. Exit cc to Atty Kutulakis, file. (CUSTODY CONFERENCE 03/13/2007 08:30 AM) 2/13/2007 Order dated 02/09/07, Barbara Wevodau, Esq appointed Guardian Ad Litem. Exit to file, cc to Atty Kutulakis. 3!15/2007 Petition to Transfer Custody Action Pursuant to PA.R.C.P. 1915.2(D) and proposed order/rule filed. Exit to Judge. Ts copies returned to atty. 3/21/2007 Order/Rule dated 03/20/07 filed. "...rule returnable within 30 days of service..." Exit cc to parties on distribution, file. 4/23/2007 Praecipe to List for Non-Jury Trial filed. Exit copy to Court Adm., Dep. Prothy., file. 4/27/2007 PETITION TO MAKE RULE ABSOLUTE & ORDER OF COURT FILED. EXIT TO JUDGE 5/2/2007 Order dated 05/01/07 UPON CONSIDERATION OF THE WITHIN PETITION TO MAKE RULE ABSOLUTE, THE RULE ENTERED IN THIS MATTER ON 03/20/07 IS HEREBY MADE ABSOLUTE AND THIS CUSTODY ACTION SHALL BE TRANSFERRED TO CUMBERLAND COUNTY PURSUANT TO PA R.C.P. 1915.2d, filed. Exit cc to parties on distribution, file. 5/8/2007 Continuing Education Program For Separated Parents Certificate Filed FOR LARRY J RUNK II ON 04/28/07 6/4/2007 File exit to Cumberland County Prothonotary's Office via regular 1st class mail. Exit exemplified record to Cumberland County Clerk of Courts. User: RUTH S CERTIFIED TRUE COPY DEPUTY PROTHONOTARY 41st Judicial District of PA, Perry County Branch Complete Case History Case: FC-FC-2007-00042 LARRY RUNK II vs. REBECCA RUNK MORROW, KATHY A. MORROW, KATHY A. MORROW, KATHY A. MORROW, KATHY A. MORROW, KATHY A. MORROW, KATHY A. MORROW, KATHY A. MORROW, KATHY A. MORROW, KATHY A. MORROW, KATHY A. i ~~ LARRY RUNK, II, IN THE COURT OF COMMON PLEAS OF Plaintiff PERRY COUNTY, PENNSYLVANIA V, NO. FC 2007-42 REBECCA RUNK, IN CUSTODY Defendant ORDER OF COURT AND NOW, this ~ ~ day of , 2007, upon consideration of the within Petition To Make Rule Absolute, the Rule entered in this matter on March 20, 2007 is hereby made absolute; and this custody action shall be transferred to Cumberland County pursuant to Pa.R.C.P. 1915.2(d). BY THE COURT, ~, K y A. Morrow, Judge ~..~. ~ :~awu~~ ~~, (7 U ~ Michael A. Scherer, Esquire 0 ~ ~ O'Brien, Baric & Scherer ~I ~ 19 West South Street `~ Carlisle, Pennsylvania 17013 Jason P. Kutulakis, Esquire Abom &Kutulakis 36 South Hanover Street Carlisle, Pennsylvania 17013 Aa ';". .. ...J ~ ~, C) = N ...~ ~~ p . f ~~ -= rv r Cif ~ c ~ LARRY RUNK, II, IN THE COURT OF COMMON PLEAS OF Plaintiff -PERRY COUNTY, PENNSYLVANIA V. NO. FC 2007-42 REBECCA RUNK, IN CUSTODY ~. -= Defendant PETITION TO MAKE RULE ABSOLUTE - ,-. ~_„ ~~ 1. The Petitioner is the Defendant, Rebecca Runk, who resides at 42 Clay Road, Carlisle, Cumberland County, Pennsylvania (hereinafter "Mother") 17015. 2. The Respondent is the Plaintiff, Larry J. Runk, II, who resides at 32 George Brown Road, Millerstown, Perry County, Pennsylvania (hereinafter "Father") 17062. 3. The parties are the parents of two children: Sarah E. Runk, born February 20, 1993 and Larry J. Runk, III, born July 4, 1994. 4. Michael A. Scherer, Esquire represents Mother. 5. Jason Kutulakis, Esquire represents Father. 6. On or about March 20, 2007, this Honorable Court entered upon Larry Runk, II, a Rule To Show Cause Why this Matter Should Not Be Transferred to Cumberland County Pursuant to Pa.R.C.P. 1915.2(d). 7. The Rule was served on Jason P. Kutulakis, Esquire, counsel for the plaintiff, on March 26, 2007. 8. Thirty (30) days have elapsed since service of the Rule. 9. Plaintiff has failed to show cause why this matter should not be transferred to Cumberland County for the reasons set forth in the petition, including: (a) Mother resides in Carlisle; (b) The children reside with Mother in Carlisle; (c) Undersigned counsel's office is in Carlisle; (d) Father is self-employed in Carlisle and it would be convenient for Father to attend hearings in Carlisle; (e) Father's counsel is from Carlisle; (f) The children attend school in Carlisle and in Newville and their teachers are located in Carlisle and Newville; and, (g) The children are involved in counseling and the counselors are located in Carlisle. 10. Plaintiff's counsel did file a praecipe to list the. case for trial on or about April 20, 2007; however, the praecipe fails to show cause why the matter should not be transferred to Cumberland County. WHEREFORE, undersigned counsel respectfully requests that this Honorable Court make the March 20, 2007, Rule absolute and transfer this matter to Cumberland County, Pennsylvania for the convenience of the parties and witnesses. Respectfully submitted, O'BRIEN, BARK & SCHERER Michael A. Scherer, Esquire I.D. No. 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 mas\Domestic\Ru nklmakeruleabsol ute. pet . + , LARRY RUNK, II, Plaintiff V. REBECCA RUNK, Defendant IN THE COURT OF COMMON PLEAS OF PERRY COUNTY, PENNSYLVANIA NO. FC 2007-42 IN CUSTODY VERIFICATION I verify that the statements made in the foregoing Petition to Make Rule Absolute are true and correct to the best of my knowledge, information and belief. This verification is signed by Michael A. Scherer, Esquire, Attorney for Defendant and is based upon the statements provided by Defendant, as well as documents reviewed by the undersigned as attorney for Defendant. I understand that false statements herein are made subject to penalties of 18 Pa.C.S. §4904, relating to unsworn falsifications to authorities. ~ 'U ~ Michael A. Scherer, Esquire Dated: April 26, 2007 f a LARRY RUNK, II, Plaintiff V. REBECCA RUNK, Defendant IN THE COURT OF COMMON PLEAS OF PERRY COUNTY, PENNSYLVANIA NO. FC 2007-42 IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on April 26, 2007, I, Tina M. Ascani, of O'Brien, Baric & Scherer, did serve a copy of the Petition To Make Rule Absolute by first class U.S. mail, postage prepaid, to the party listed below, as follows: Jason P. Kutulakis, Esquire Abom &Kutulakis 36 South Hanover Street Carlisle, Pennsylvania 17013 ma M. Ascani, Secretary ~,~ m v c ~ n '~ o z a ~ O ~~ ~ ~ ~, ~ ao a ~ ~ c ~ ~ ~ ,~ a, ~ ~ a ~• ~ ~ 00 'ti ~ ° ~ ~ m n ~ ~ n rn v rn ~z cn C N 0 a 0 yN~-~ X. ro d r x n I~ - . ~, __ _. .. ~ ~,~ L , ,, ~ ~ •._ `- ± ~I _ ~ t ,,., ,_ ~, ~^ .~ 0 0 =rot ~~~~ ~. o ~ ~~ c ~' ~ ~. ~ ~ ~ c ~ ~ ~~ ~c cL~ -- ~ v~ ~~~'~ `~ ~ ~o~ °~ n ~~~~ ~~~ ~~~ O ~~ 0 'G rn Z Z Y rn ~~ LARRY RUNK, II, Plaintiff v. REBECCA RUNK, Defendant IN THE COURT OF COMMON PLEAS PERRY COUNTY, PA NO. FC 2007-42 CIVIL TERM CNIL ACTION -LAW IN CUSTODY TO THE PROTHONOTARY OF SAID COURT: PRAECIPE TO LIST CASE FOR TRIAL PURSUANT TO 42 PA C.S.A. 1915.4 and 1915.4-1 Please list the above matter for trial pursuant to Rule 42 PA C.S.A. X1915.4 and X1915.4-1. ABOM & KUTULAHIS, LLP Date: ~ ~ O~J `l Ja n P. Kutulakis, Esquire 3 outh Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney ID No. 80411 Attorney for Plaintiff ~~ -.,_, .m. ~~~ -- c~~a r~ ~~~cao - G-f~'~~n ~7~2 i ,- ~m v LARRY RUNK, II, IN THE COURT OF COMMON PLEAS OF Plaintiff PERRY COUNTY, PENNSYLVANIA v. NO. FC 2007-42 REBECCA RUNK, IN CUSTODY Defendant ORDER OF COURT AND NOW, this ~b _ day of March, 2007, upon consideration of the within Petition, a rule is entered upon the Plaintiff, Larry Runk, II, to show cause, if any there be, why this matter should not be transferred to Cumberland County, Pennsylvania. Said rule returnable within ~ days of service hereof. BY THE COURT, ~l'Qu.,CL~x~~ ~~- Michael A. Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, Pennsylvania 17013 Jason P. Kutulakis, Esquire ~ ~.~ Abom &Kutulakis 36 South Hanover Street Carlisle, Pennsylvania 17013 ~ - / 1 YG ~~ T ~~o~.f e~.~c a.~,~..A a n `~~~ ` ±~~ Cy LARRY RUNK, II, IN THE COURT OF COMMON PLEAS OF Plaintiff PERRY COUNTY, PENNSYLVANIA v• NO. FC 2007-42 REBECCA RUNK, IN CUSTODY Defendant PETITION TO TRANSFER CUSTODY ACTION PURSUANT TO PA.R.C P 1915 2(d) 1. The Petitioner is the Defendant, Rebecca Runk, who resides at 42 Clay Road, Carlisle, Cumberland County, Pennsylvania ("Mother") 17015. 2. The Respondent is the Plaintiff, Larry J. Runk, II, who resides at 32 George Brown Road, Millerstown, Perry County, Pennsylvania ("Father") 17062. 3. The parties are the parents of two children: Sarah E. Runk, born February 20, 1993 and Larry J. Runk, III, born July 4, 1994. 4. Michael A. Scherer, Esquire represents Mother. 5. Jason Kutulakis, Esquire represents Father. 6. On or about February 7, 2007, Father filed a Complaint For Custody in the Court of Common Pleas of Perry County is attached hereto "Exhibit 1." 7. For the convenience of the parties and witnesses, Mother asks that tl~ -, ~~ _ _ --~ case be transferred to Cumberland County because: ~-. ~'~ ~--= - ,~, . __ TM_.._f (a) Mother resides in Carlisle; u~ '- T~, _ . (b) The children reside with Mother in Carlisle; _. (c) Undersigned counsel's office is in Carlisle; ~ a (d) Father is self-employed in Carlisle and it would be convenient for Father to attend hearings in Carlisle; (e) Father's counsel is from Carlisle; (f) The children attend school in Carlisle and in Newville and their teachers are located in Carlisle and Newville; and, (g) The children are involved in counseling and the counselors are located in Carlisle. 8. There is presently a custody provision in a Protection For Abuse Order arising out of a Protection From Abuse case filed by Mother against Father. A copy of the Protection From Abuse Order dated November 20, 2006 is attached hereto as ' "Exhibit 2." 9. On or about November 20, 2006, the Honorable Edgar B. Bayley of the Court of Common Pleas of Cumberland County heard extensive testimony in connection with the Protection From Abuse Order, some of which related to the children, and it would serve the purpose of the judicial economy for Judge Bayley to continue to hear matters arising in connection with this case. 10. Father avers at paragraph 14 of the Complaint For Custody that "The Plaintiff has not participated as a party or a witness, or in another capacity, in other litigation concerning the custody of the children in this or any other court." This allegation is false in light of the custody provision in the Protection From Abuse Order mentioned in the proceeding paragraph. 11. Undersigned counsel has contacted Jason Kutulakis, Esquire and he opposes the transfer in this case. WHEREFORE, for purposes of judicial economy and for the convenience of the parties and witnesses, Mother respectfully requests this custody action be transferred to Cumberland County. I! Respectfully submitted, O'BRIEN, BARK & SCHERER Michael A. Scherer, Esquire I.D. 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 i mas.dir/domestic/runkltransfercustody.pet VERIFICATION The statements in the foregoing Petition To Transfer Custody Action Pursuant To Pa.R.C.P. 1915.2 (d) are based upon information which has been assembled by my attorney in this litigation. The language of the statements is not my own. I have read ': i it the statements; and to the extent that they are based upon information which I have given to my counsel, they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties ~i of 18 Pa.C.S. § 4904 relating to unsworn falsifications to authorities. '~ DATE: ~ Rebecca S. Runk ,. LARRY RUNK, II, Plaintiff v. REBECCA RUNK, Defendant IN THE COURT OF COMMON PLEAS PERRY COUNTY, PA NO. CIVIL TERM CIVIL ACTION -LAW IN CUSTODY You, Rebecca Runk, have been sued in Court to obtain custody, partial custody or visitation of the children. You are ordered to appear in person at the Perry County Courthouse, New Bloomfield, Perry County, Pennsylvania, on the M. for a custody conference. dap of 2007, at If you fail to appear as provided by the Order, an Order for custody, partial custody or visitation maybe 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CENTRAL PENNSYLVANIA LEGAL SERVICES 213A N. Front Street Hanisbvrg, PA 17101 (800) 932-0356 BY THE COURT, J "EXHIBIT 1" . •,~ LARRY RUNK, II, IN THE COURT OF COMMON PLEAS Plaintiff PERRY COUNTY, PA v. NO. CIVIL TERM REBECCA RUNK, CIVIL ACTION -LAW .Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of 2007, is hereby appointed Guardian Ad Litem for the minor children, Sarah Elizabeth Runk, born February 20,1993, and Larry James Runk, III, born July 4,1994. BY THE COURT, J• 2 LARRY RUNK, II, Plaintiff v. REBECCA RUNK, Defendant IN THE COURT OF COMMON PLEAS PERRY COUNTY, PA NO. CIVIL TERM CIVIL ACTION -LAW IN CUSTODY -R NOTI The Court directs that within sixty (60) days after service, both of the parties shall register and attend the program by mailing the pre-printed "Education Program for Separated Parents" registration form, along with a registration fee of $45.00 to the: EDUCATION PROGRAM FOR SEPARATED PARENTS PENN STATE JUSTICE & SAFETY INSTITUTE THE PENNSYLVANIA STATE UNIVERSITY 305 LUBERT BUILDING INNOVATION PAR%AT PENN STATE UNIVERSITY PARK, PA 16802-7009 BY THE COURT, J• 3 OM ~ LITLILAKIS Jason P. Kutulakis, Esquire Atty I.D. #: 80411 36 South Hanover Street Carlisle, PA 17013 LARRY RUNK, II, Plaintiff v. REBECCA RUNK, Defendant IN THE COURT OF COMMON PLEAS PERRY COUNTY, PA NO. CIVII, TERM CIVIL ACTION -LAW IN CUSTODY 1. Plaintiff is the Father, Larry Runk, II, who currently resides at 32 George Brown Road, Millerstown, Perry County, Pennsylvania 17062. 2. Defendant is the Mother, Rebecca Runk, who currently resides at 42 Clay Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. COUNT I -CUSTODY 4. Paragraphs one (1) through three (3) of this Complaint are incorporated herein by reference as though set forth in full 4 5. The Plaintiff seeks custody of the following children: Name Address Sarah Elizabeth Runk 42 Clay Road, Carlisle, Pennsylvania 17013 Larry James Runk, III 42 Clay Road, Carlisle, Pennsylvania 17013 6. Sarah E. Runk and Larry J. Runk, III, were bom in wedlock. DOB February 20, 1993 July 4,1994 7. The children are in the primary custody of the Defendant, residing at 42 Clay Road, Carlisle, Cumberland County, Pennsylvania 17013. 8. During the children's lifetime, they have resided with the following persons and at the following addresses: Name Address Larry Runk, II, & Rebecca Runk 32 George Brown Road Millerstown, Pa 17062 Rebecca Runk 42 Clay Road, Carlisle, Pa 17013 Larry Runk, II 32 George Brown Road Millerstown, Pa 17062 Rebecca Runk 42 Clay Road, Carlisle, Pa 17013 Date Sarah: Birth to 10/21 /05 Larry III: Birth to 10/21 /OS Sarah: 10/21 /05 to Present Larry III: 10/21/05 to 12/25/05 Larry III: 12/25/05 to 10/13/06 Larry III: 10/13/06 to Present 9. The mother and father of the children are currently married. 10. The relationship of Plaintiff to the children is that of Father. 11. The relationship of Defendant to the children is that of Mother. 12. The Plaintiff currently resides alone; however, he did exercise primary physical custody of Larry J. Runk, III, until October 13, 2006. 13. The Defendant currently resides with the following persons: a. The children: i. Sarah E. Runk, age 13, since October 21, 2005; ii. Larry J. Runk, III, age 12, since October 13, 2006. 5 b. Her Parents: i. Rodney and Darlene Hockenberry 14. The 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 any other court. 15. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 16. The 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. 17. The best interest and permanent welfare of the children will be served by granting the relief requested for reasons including the following. a. The Father will be able to ensure for the minor children's safety. b. The Father will be able to provide a stable home for the minor children. c. The minor children have a psychological bond with the Father. d. The Father can provide for the minor children both financially and emotionally. e. The Father will continue to maintain and encourage counseling for the oldest child, Sarah, at Penn State, Hershey Medical Center, Child Psychiatry Department. f. The Father can immediately provide the minor children with the basic day to day necessities. 18. It is believed and therefore averred that the Mother has a drinking problem and has drank an excessive amount when exercising custody of the minor children. 19. Larry J. Runk, III, came home from school in the Spring of 2006, with information regarding "parents and drinking" from a school nurse because he was concerned about his mother's alcoholism. (See Exhibit "A'~ 6 20. It is believed and therefore averred that the .Pennsylvania State Police came to Father's house on December 23, 2006, looking for Mother since her whereabouts had been unknown for approximately twenty-four (24) hours. Trooper Mitchell of the Pennsylvania State Police was the officer involved. 21. It is believed and therefore averred that Mother was significantly intoxicated during the period of time when her whereabouts were unknown. 22. One of the children reported to the paternal grandmother that the Defendant was at a bar and was visibly drunk. 23. It is believed and therefore averred that Mother knew that daughter Sarah had been arrested, along with her 13-year old friend, for underage drinking and never informed Father of the arrest. (See Exhibit "B") a. It is believed and therefore averred that Sarah and her 13-year old friend had taken the friend's mother's car and went for a joy ride through the Wal-Mart parking lot, almost striking an individual who was trying to stop them from driving erratically. 24. 'It is believed and therefore averred that Mother, as a Christmas present for her daughter, Sarah, took her to have her tongue pierced without consulting Father. 25. Since October 2006, Mother has precluded any visitation between the minor children and Father. 26. Mother had arranged for a visit between Father and the minor children on Christmas Day; however, she canceled the visit and refused Father visitation on Christmas Day. 27. It is believed and therefore averred that Mother suffers from bi-polar disorder. 28. It is believed and therefore averred that Mother's family has a family history of bi- polar disorder. 7 29. It is believed and therefore averred that the family physician, Dr. Robert Michelini, believes that Mother self-medicates herself with alcohol as a way to medicate herself for the bi-polar disorder. 30. Father believes it is in the children's best interest for a Guardian Ad Litem to be appointed to represent the needs of the children in the ongoing custody proceeding. 31. Defendant failed to inform Plaintiff of the health and well-being of the children. 32. Defendant failed to take Larry J. Runk, III, for a medical appointment with Dr. Michelini on January 22, 2007. (See Exhibit "C'~ 33. Defendant failed to take Larry J. Runk, III, to a medical appointment with Dr. Page at Susquehanna Surgeons, Ltd., on January 16, 2007. (See Exhibit "D'~ 34. Plaintiff received a voice message that the Defendant failed to take Larry J. Runk, III, for surgery for an abscess. 35. Plaintiff is without any knowledge whatsoever beyond the above-mentioned condition and appointments. 36. .Each parent whose parental rights to the child have not been ternunated has been named as parties to this action. 37. Plaintiff has been advised of the requirement to attend the seminar titled "Education Program for Separated Parents" offered by Penn State. 8 [l/~fEREFORE, the Plaintiff requests that This Honorable Court grant primary physical custody of the children to the Plaintiff/Father and shared legal custody of the children to the both the Plaintiff/Father and Defendant/Mother. DATE ~ J `l d l Respectfully submitted, Aao1-s & KuTUra~s, L.L.P. Jaso P. Kutulakis Su eme Court ID 80411 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaint 9 I, Larry Runk, II, verify that the statements made in this Custody Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date ~ ~' ~ n~ Larry Runk, II 10 ° " n ~ ~-3 - o d ~' C O ~ ~ +j}~, ~ oo A ~ ~ A V ~ h f~0 ~ Q ~ ~ am • n ~ ~ ~ n N O O ~ /] G ~ Y.~.~ rI ~ ~ ^ ^ = n n ~ ~ O ~ ~ a„ c ~• e T oc .f . ~ p Q7 w " C j ~~ ~ a ~ tY ~ ~~ N ~ ~- O ~•, a ~ `" ~ n7 D ~ ~ D 's' o f - ~! a' ~ • ~ ~ S r.~r. ~ a~°~s~ ~~ ~, ov~i' ro C `~ ~D f~ n o ~ ~~ ~ A . ~ ~ ~~ a ~ ~ D ~ O ~ ~ ® o a a ~ a 3 ~ C r "~ ~' • `~' -~r~1 M+j ~ ~. ~ c ~ ~ ~0 y o n ~Q ~D ~ ~: cp ~ O a. ~2' o- ° ~ ~ ~ °: . 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W o v, o '"' ~,~~~ -,, m ~ ~ m m -~0~ (~ ~ N Q- w ~ -h o a ?~ ~ m~~~ ~~s~ ~oQ- 0 ..: ~°~m m ~ ~~~o ~~~~ n~~~~ ~ ~- - o~ ~~ ~SwcNu ~~ ?~ a?o ~ ~ N ~ ~~~•~ ~~ ~ ~ ~~~°: co .~ ~ ~ ~~oa y o ~, oo w -o D NN~~~ ~p.~._ `G `G (D ~ ~ 0- ~ - f~D ~ ~ ~ ~ ~_ ~ (~p to Q~ ~-N ~ O N 0 0.~~ ~~~ ~ N ~p ~ O N ~ N ~ ~ ~' n ? 7 ~ (D Q. ~ r. O ~ N p ~ N• ~: C '~ ~ ~ ~ ~ (D N ~ ~ A 'r ~~^~ ) (~"V g o ~ ~, ~ ~~ ~~ ~~ ~T~ .. ~~ ~ ~ F~ ~ ~ ~' _-~. ~ ~ ~ ~'i ~ T o~ ~~ F~ o ~ ~-~ -~ o o~ ~ ~~- c~ v ~/ 1.~n~, ,` 1`• ~~ ~i ~~',~ • ~ ~'-- . ft'`'n ~.= .. O 3 .~., z z -ro ~ ~~~ ~~~ m ~~ -~ J ` ,. ~ m _ ~ ~ . \1 ~~ ~~ >, ~ ~ rL-+ .Y Y `~ .L-. ~ ~.J~cyO"ON cOUN~ .'C.r ~ Cn ~ O C Y ~ +L,,, '~ O Q. ~ ~_ ~ ~ ~ N ~.Y ~ ~ ~ UL ~= O p L O O ~U O o~F- m yt a•-~ ~+, L N> OL O L O+L. xa p C O ~. t T ~ ~~ N ~-°at c ~~3 0_ oo~•L L~~ O ~ ; 1-+ Y W ~. O)O O O NFL 3 °' ~o~a ~~~~ U~.fl=L CO ~Y .~ OOm'~O 'O~~ >. C L OtLO O L ~ ~ -- 3 ..... w.. t- .~ U ~ O O O N .~ ;d ~ cd >+L ~ ~ N roa~a c~a~~ c -0 N ~ .Q "O C O L O , ~N~~ C ~Q~~ w N N ~CnQ..~~ F-~NCOn s C ` O Qj L C _ ~ ~ O O "'' O O c ~ C'°- ~~Om ,..c~a~= O L U a_ f0 ~ L i N.~t~ ~ ~ 0-N ~ ~ ~O.r NL ~~ C C O~ •~ ~, O N NY-O~fA O > ~ O ~~QON !-'C3~ NL ~`~L -0.~~ O cti ~ O CC~ N t~/J N O N AIL- N J „ 'D• What Can Kids Do? ~+ s i V ! , ~ What Can Kids Do? Here are a few suggestions for you: DO talk about how you feel. You can talk with a safe person in your life - maybe a close friend, relative, school counselor, teacher, minister, or others. Sharing your feelings is not being mean to your family. When you talk to someone, you might feel less alone. Talking to someone about your feelings can help you feel less alone. DO try to get involved in doing enjoyable things at school or near where you live--the school band, softball, Boy or Girl Scouts, or others. Doing these types of activities can help you forget about the problems at home, and you could learn new things about yourself and about how other people live their lives. DO remember that feeling afraid and alone is a normal way to feel when you live with alcoholic pazents. It's confusing to hate the disease of alcoholism at the same time that you love your alcoholic parent. All people have confusing feelings: two different feelings at the same time. This is the way many kids feel about alcoholic parents. DO remember to have fun! Sometimes children with alcoholic families worry so much that they forget how to be "just a kid." If things aze bad at home, you might not have anyone who will help you have fun, but don't let that stop you. Find a way to let yourself have fun. DON'T ride in a caz when the driver has been drinking if you can avoid it. It is not safe. Walk or try to get a ride with an adult friend who has not been drinking. If your pazents are going out to drink somewhere, try not to go with them. If you must get in a car with a drinking driver, sit in the back seat in the middle. Lock your door. Put on your safety belt. Try to stay calm. DON'T think that because your parent is an alcoholic you will be one too. Most children of alcoholics do not become alcoholics themselves. DON'T pour out or try to water down your pazent's alcohol. The plain fact is that it won't work. You have no control over the drinking. You didn't make the problem start, and you can't make it stop. It is up to your parent to get treatment. What your parent does is not your responsibility or your fault. Page 1 of 2 http://www.nacoa.netlcankids.htm z n oi~nn~ -. a, yler geld at at Ames, Inc 11 AM on ber 9th, 2006 k Egresites went at Riv. ' 1 Gardens in j Saturday , -` at thefuner- .~ a ~ ~. ,~" 3~yyo~pe{in~~ .Ltl Chapel-"^~. ryaburg; PA ~e online , rT Ames coin. ~.com/obits fi7 ~ - *s. :;' t 5..1 ~ 1 ~:'~n ~ x. ~- ~.. ~' '~chelle`'~'' son ~ %ryt ` _-~ ~ s Anderson, et,oiaa M. ~: Anderson; :". T,ord ori; , ,. hv. "_' ,. L7TUC%. ous co .nYnds reade'rs' Boiling Springs 11 a m. in Mt.. ~St,.. - The ; .Copnmit .. . . ~: ~ of the; followtn~ services ,~~ ~ "Holly Springs Church of God, 14 : ~ seliool ~ ' ' .~ ~ Fairfield St, Mt Holly Springs, `Thursday _r~~, ,. Attacks " Carolyn Blemlei 'of ~ v~sitatton bne hour prior. , . ' '•`: Nancy • ~~; $; , r , 4 T* s. 1 ~` x -` ~ ~ Fi ~ - - '"~ - :~C ~y, ~ 1 1:1 Y ~~ P. f .+~'C. ' r - Hess. and ~ , t ' f~ ~ - ~xa - ti t ~ Underage ifri~er cited by police: the Dow volunteer Elemeiiti ~' '- 'Ibvo13 year.-old girls whQ;drove a. ]unniy;,SW up and down r ' h ' 1 Hof the Wa1=Martwere released to theirparents but the dn= For 12 at Str f t e ais es: -di ? ~ ver was cited for reckless. endangerment. ' " ,' '~- ~ Carlisle police say;the incident took place`about 9.p m Nov, 11 ~ it ~` Police say the driver took her mother's SW without her permission ~a~ A Wal-Mart employee who pushes carts told police the vehicle near .P ly ran over him Police say no uiluries or property damage occurred. - i t~ ta~~:resp«ss,~,,. ,,~tng instruments of ~.,.~rime and criminal mischief, ~ ~,, and Brandon Hetrick faces one count of receivui$ sto- l `. , ~ ...~ g len property ,, f~?`he :,?'Both were freed on " . .d the ac- • " ~. $10,000-bail and the chit- - ~ , .:;, who noticed dren were placed in the cus- ~horized withdraw- tody of Cumberland County .:stly of $1,000 at'a Children & Youth Services. t ti Endangerment charged '. ti ,;~~• LOWER PAXTON TWP. { A 13 yea= old girl is facing ''< ~:~ . reckless eridan ermenf: '~ `Smoke damages home chazges after a~irobe of a - _ Nov. 18 incident in the Wal- .- A furnace malfunction ' Mazt parking lot. - :.: sent heavy black smoke Police said they were `` ,~ rolling through a home m ~. - ., 'cahed~to` the lox_around 9 " ; the;4400 block of Venus p.m. by, wit~nesses_who.saazd ,' Avenue,in Linglestown at two child;en.were driying a~ ;1030 a.m. Monday, but fire.: , sport utility vehicle and~had officials; said there weie no -:r1VJa.a..~r aav r~cw ruataµa~r ~ t .~i111V1CCC1SIIIc"IB@';,,'~rYi.t~`~.':E~ sl?oPP~,c~$• ;, ' ° ` ~ "An eYectrical solenoid ';The 13-year"-old driver" ~} ~~ melted inside the furnace was found to have taken then ` aad the smoke was pulle `SLTV without her'mother's-~'~'~into the fan aad then:pv errni$siga; police `said: Her '~''throu out the House " passenger; was also 13 '~y:. ~ '-- Lingle~stown; Fire Chic -' Charges; will be handled 'ry Pierich `said. y ~ _° by;Cumbei~and,County;ju ~ `'=' ''-' venile probarionR police. £~ ~ < `'~ , said, ~ ,`' ; £:k° x ,~,a+ ,~;.,`BWATARA~:TW' ~:r ,: ''' ~ ~ ~~ ~ . Accident fro ;~; ~ ~ ~ ss s , ti ~ r (EAST PENNSBORO TWP. ~ '~<4~ v,<, . ~~,f ~ - : s ~ Police`: 2 arrested m burglary *~ ~ ~` ~ntnes~ a . ,~ ~ r-- T __,~ .:,Two mer<were~:arrested ~«'' ..during a burglary~azou~ 1aS. a:m' vacterd:w at REE~~ L F~-MILY ~'I-I CANTER A SERVICE OF HOLY SPIRTI' HEALTH SYSTEM Date: ~ ~ _a ~ ~ 7 ~~ ~ Dear ' On o ~-~ a -0 7 ,you failed to show for your appointment with Dr. Ciccarelli chelini at our Green Hill Family Health Center. Spirit Physician Services defines a failwe to show as failure to present on time for you scheduled appointment or failure to give 24 hours cancellation notice. The system-wide policy for missed appointments within a 12 month time period is as follows: st missed appci_Ttme^t: ~Nrttsn nUtif cat+'Un - no ch:.arge Second missed appointment: $40.00 missed appointment fee Third missed appointment: discharge from care This represents your ~Q First; ( )Second missed appointment within the past t~ months. Please realize that missed appointments make it difficult to respond to the needs of other patients. Robert L. Tecau, DO Medical Director, SPSI Your Partner For Good Health 503 Bridge Street • New Cumberland, PA 17070 (717) 774-8400 • Fax (717) 774-8607 Herita a Medical G ~ r~u~ ._.. Listening, caring, lending. Susquehanna Surgeons, Ltd. George B. Faries, Jr., M.D. 532 North Front Street Michael J. Page, M.D. Wormleysburg, PA 17043 Kenneth W. Graff M.D. Joseph P. Esposito, M.D. Phone (717) 761-4141 • Fax (717) 761-1456 Ronald G. Barsanti, M.D. A. David Froehlich, M.D. Rolando A Casal, M.D. Lisa K. Torp, M.D. MastasIus O. Peter, M.D. William P. Brown, D.O. January 17, 2007 Mr. Larry J. Runk, III 32 George Brown Road Millerstown, PA 17062 Dear Mc Runk: You were scheduled to see poctor page on January 16, 2007 but fazed to keep this appointment. We have documented this as a missed appointment or no-show since you failed to contact us at least 24 hours prior to your sdheduled appointment time. ff you feel that this in error, please contact our office. Missed appointments or no-stlows are a serious ooncem in the continuing course of medical treatment and care. Appointments are sctheduled for a variety of reasons, including ongoing monib~ring of chronic conditions, assessments of an acute condition, investigation of a new problem or for a general comprehensive ftealth review, to name a few A missed appointment can cause a lapse of important tr+eatrnent, ineffitderrt use of tone for staff and physicians, and a missed opportunity for another patient who may have needed an appoinfinent. Due fA the problems a missed appointment causes Heritage Medical Group has adopfied the following policy: • The first missed appantment will generate a letter outlining our policy. • The second missed appointment will generate a charge of $45.00 and a warring letter. • The thirri missed appointment will cause dismissal from our practice. We continually strive to provide optimal medical cane and access to our physicians and staff. We would aPP~te Your assistance. ff you find that you are unable to maintain a scthectuled appointment, please call the office at least 24 hours prior th you appointment fp reschedule to a time that betthr suits your needs. If you have not alre~y rasctleduled your missed appointment, please contact our office at your eari~st convenience so that we can provide you with the optimal care we strive to deliver to all our patients. Sincerely, Thomas. E. Canahan Office Manager Susquehanna Surgeons, Ltd. --~~ Heritage Cardiology Diagnostic Center Heritage Diagnostic Center Heritage Medical Group Laboratory (717) 972-2829 (717) 737-3037 (717) 909-0933 1-86CrHMGDOCS AND NOW, this ~ day of February 2007, I, Jason P. Kutulakis, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Custody Complaint to the Defendant, advised the Defendant that she is requited to attend the "Education Program for Separated Parents" and provided the Defendant with a registration form for the Program, by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Michael Scherer, Esquire O'Brien, Banc & Scherer 19 West South Street Carlisle, PA 17013 Attorney for Defendant Respectfully submitted, Abom & Kutulakis, L.L.P. Jaso P. Kutulakis Sup eme Court ID 80411 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaint 11 Spoon Game Fundraiser All proceeds donated directly to American Cancer Society Obiect: -Take out all opponents by taking their spoon if it is not visible and properly held by a voluntary muscle (mouth, hand, underarm, between knees...) Rules• 1. •Do not disrupt class or upset parents 2. Players must properly hold spoon at all times or risk getting taken out of the game 3. When taken out by another player, you must give up your spoon and you are officially out of the game 4. When you catch someone you must report the catch to Tia Fay and continue catching remaining opponents 5. No violent grabbing or foul-play allowed 6. All players will receive official list of players to take out 7. Tia is in charge of official player list that will be posted outside of Mrs. Ruane's classroom and frequently updated. 8. Tia has the authority to remove players who do not properly follow rules. Please respect all normal school rules F~cceations• Gym class/school sports- spoon is allowed to be held behind ear, in hair or attached to clothing. -Game officially begins 12noon Monday, Feb. 12 and runs 24hours/day until only 1 person remains -$3 donation must be received by Monday moming "Last person remaining will receive prize* Spoon Game Fundraiser All proceeds donated directly to American Cancer Society Obiect: -Take out all opponents by taking their spoon if it is not visible and properly held by a voluntary muscle (mouth, hand, underarm, between knees... ) Rules: 1. Do not disrupt class or upset parents 2. Players must properly hold spoon at all times or risk getting taken out of the game 3. When taken out by another player, you must give up your spoon and you are officially out of the game 4. When you catch someone you must report the catch to Tia Fay and continue catching remaining opponents 5. No violent grabbing or foul-play allowed 6. All players will receive official list of players to take out 7. Tia is in charge of official player list that will be posted outside of Mrs. Ruane's classroom and frequently updated. 8. Tia has the authority to remove players who do not properly follow rules. Please respect all normal school rules Exceptions: Gym class/school sports- spoon is allowed to be held behind ear, in hair or attached to clothing. -Game officially begins 12noon Monday,. Feb. 12 and runs 24hours/day until only 1 person remains -$3 donation must be received by Monday moming *last person remaining will receive prize'` REBECCA RUNK, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. LARRY RUNK, DEFENDANT 06-6207 CIVIL TERM PROTECTION FROM ABUSE ORDER (1) Defendant is Lany Runk. (2) Defendant's date of birth is April 10, 1962. (3) Defendant's social security number is 180-50-0301. (4) Plaintiff Rebecca Runk is the wife of defendant. AND NOW, this 20~h day of November, 2006, following a hearing and finding that defendant abused plaintiff, IT IS ORDERED: (1) Defendant shall not abuse, stalk, harass, threaten or attempt to use physical force that would reasonably be expected to cause bodily injury to the plaintiff. (2) The Sheriff shall maintain custody of the following items of defendant already in his possession: 1. .308 2. .22 semiautomatic Ruger 3. .357 magnum 4. .12 gauge camouflage pump 5. 3 0/.20 gauge break action 6. .22/.20 gauge break action 7. 30-06 brush gun 8. .410 pump action 9. .12 gauge pump 10. (illegal) .30 M1 carbine with four extra 25 round clips 11. old .12 gauge single shot 12. old .12 gauge single shot 13. double barrel .12 gauge break action 14. double barrel .12 gauge break action 15. .300 Remington Magnum bolt action 16. 30-06 with scope "EXHIBIT 2" 17. 30-06 with scope 18. muzzleloader 19. muzzleloader 20. various bows and an'ows 21. any other weapons in Defendant's possession 22. ammunition for nay and all weapons (3) Physical custody of the parties' children Sara Runk and Jimmy Runk shall be with plaintiff, and defendant shall have reasonable periods of partial custody as agreed upon by the parties pending any further order entered in any custody case. (4) Certified copies of this order shall be provided to the Carlisle Police Department and the PA State Police-Carlisle Barracks. (5) This order supersedes the temporary protection from abuse order entered on October 25, 2006. (6) All provisions of this order shall expire on November 19, 2009. NOTICE TO THE DEFENDANT You are notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months in jail. 23 Pa.C.S. §6114. Any consent of Rebecca Runk to return to your residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. §6113. A violation of this Order may subject you to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. §§2261-2262. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiff s residence or any location where a violation of this order occurs or where the • ~~ ~% defendant may be located. If defendant violates this Order, he may be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based on probable cause whether or not the violation is committed in the presence of law enforcement. Subsequent to any arrest, the law enforcement officer shall seize all weapons used or threatened to be used during any violation of this Order. Weapons shalt forthwith be delivered to the Cumberland County Sheriff's Office, which office shall maintain possession of the weapons until further Order of this court, unless the weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. By the Co ~t-- ~" Edgar B. Bayley, Kathleen: N. McKeown, Certified Legal Intern / Family Law Clinic For Plaintiff Michelle L. Sommers, Esquire For Defendant PSP Carlisle Police Department :sal Y ©OP'Y FROM iiE00R~ M1d~~~reo1, ~ hens ui+~sstel~wlt~1~ .and iM d !dd Court~t ~G Tld ~ ornthorMM~- CERTIFICATE OF SERVICE hereby certify that on March ~ ~ , 2007, I, Jennifer S. Lindsay, secretary to Michael A. Scherer, Esquire, did serve a copy of the Petition To Transfer Custody Action Pursuant To Pa.R.C.P. 1915.2 (d), by first class U.S. mail, postage prepaid, to the party listed below, as follows: Jason P. Kutulakis, Esquire Abom &Kutulakis 36 South Hanover Street Carlisle, Pennsylvania 17013 Law Offices O'BRIEN, BARK & SCHERER 19 West South Street Carlisle, Pennsylvania 17013 Robert L. O'Brien David A. Baric Michael A. Scherer Robert J. Dailey Prothonotary Perry County Courthouse Main Street New Bloomfield, Pennsylvania 17068 RE: Larry Runk. II v. Rebecca Runk No. FC 2007-42 Dear Sir or Madam: (717) 249-6873 Fax: (717) 249-5755 Email: mscherer(a~obslaw. com March 14, 2007 '" : ; _.., ~~ - c.~; c~ ib Enclosed for filing please find an original and two copies of a Petition To icy Transfer Custody Action Pursuant To Pa.R.C.P. 1915.2(d) along with extra copies of ~/ the Order and self-addressed stamped envelopes for~mv~nd Plaintiffs counsel. +/ Please file the original Petition of record, time stamp the copies and return them to me once the Order has been signed by a judge. ~ ~' Should you have any questions or require any additiona ~ rmation, please contact me. Very truly yours, O'BRIEN, BARK & SCHERER MAS/jl Enc. cc: Jason Kutulakis, Esq., w/Enc. File Michael A. Scherer mas.d it/domestic/ru nk/prothonotary.ltr . ~~1 LARRY RUNK, II, IN THE COURT OF COMMON PLEAS Plaintiff PERRY COUNTY, PA v. NO. IL TERM . T-c aU U~_ ~ REBECCA RUNK, CNIL ACTION - W Defendant IN CUSTODY You, Rebecca Runk, have been sued in Court to obtain custody, partial custody or visitation of the children. You are ordered to appear in person at the Perry County Courthouse, New Bloomfield, Perry County, Pennsylvania, on the ~ day of ~,Q1,,~~ 2007, at 0 ~M. for a custody conference. If you fail to appear as provided by the 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CENTRAL PENNSYLVANIA LEGAL SERVICES r- 2Z3A N. Front Street `!~' Hartrsburg, PA 17101 cry - (800) 932-0356 ' ;- ., BY THE COURT, J ~ ~* r-- ~- N J. ~~: LARRY RUNK, II, Plaintiff v. REBECCA RUNK, Defendant IN THE COURT OF COMMON PLEAS PERRY COUNTY, PA NO. CNIL TERM CNIL, ACTION -LAW IN CUSTODY ORDER OF COURT ~ AND NOW this ~ day of d/• 2007, . ~ GL~,.~a Q~ is~reby anointed Guardian Ad Litem for the minor children, Sarah Elizabeth Runk, born February 20, 1993, and Larry James Runk, III, born July 4, 1994. BY THE COURT, ,~ °', 2 LARRY RUNK, II, Plaintiff v. REBECCA RUNK, Defendant IN THE COURT OF COMMON PLEAS PERRY COUNTY, PA NO. CNIL TERM CNIL ACTION -LAW IN CUSTODY ORDER AND NOTICE The Court directs that within sixty (60) days after service, both of the parties shall register and attend the program by mailing the pre-printed "Education Program for Separated Parents" ~•e6 registration form, along with a registration fee of $190 to the: EDUCATION PROGRAM FOR SEPARATED PARENTS PENN STATE JUSTICE & SAFETY INSTITUTE THE PENNSYLVANIA STATE UNIVERSITY 305 LUBERT BUILDING INNOVATION PARK AT PENN STATE UNIVERSITY PARK, PA 16802-7009 BY THE COURT, Q. ` G~ J 3 OM ~' LITLIL,AKIS Jason P. Kutulakis, Esquire Atty I.D. #: 80411 36 South Hanover Street Carlisle, PA 17013 LARRY RUNK, II, Plaintiff v. REBECCA RUNK, Defendant IN THE COURT OF COMMON PLEAS PERRY COUNTY, PA ~ ~~-`'~ ._.,,. NO. CNIL TERM ~ ~ ~~~ ' i CNIL ACTION -LAW --, ~~, IN CUSTODY '- - -r, -~; , iv COMPLAINT 1. Plaintiff is the Father, Larry Runk, II, who currently resides at 32 George Brown Road, Millerstown, Perry County, Pennsylvania 17062. 2. Defendant is the Mother, Rebecca Runk, who currently resides at 42 Clay Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. Paragraphs one (1) through three (3) of this Complaint are incorporated herein by reference as though set forth in full. 4 5. The Plaintiff seeks custody of the following children: Name Address Sarah Elizabeth Runk 42 Clay Road, Carlisle, Pennsylvania. 17013 Larry James Runk, III 42 Clay Road, Carlisle, Pennsylvania. 17013 6. Sarah E. Runk and Larry J. Runk, III, were born in wedlock. DOB February 20, 1993 July 4, 1994 7. The children are in the primary custody of the Defendant, residing at 42 Clay Road, Carlisle, Cumberland County, Pennsylvania 17013. 8. During the children's lifetime, they have resided with the following persons and at the following addresses: Name Address Larry Runk, II, & Rebecca Runk 32 George Brown Road Millerstown, Pa 17062 Rebecca Runk 42 Clay Road, Carlisle, Pa 1701.3 Larry Runk, II 32 George Brown Road Millerstown, Pa 17062 Rebecca Runk 42 Clay Road, Carlisle, Pa 17013 Date Sarah: Birth to 10/21 /OS Larry III: Birth to 10/21 /05 Sarah: 10/21 /05 to Present Larry III: 10/21/05 to 12/25/05 Larry III: 12/25/05 to 10/13/06 Larry III: 10/13/06 to Present 9. The mother and father of the children are currently married. 10. The relationship of Plaintiff to the children is that of Father. 11. The relationship of Defendant to the children is that of Mother. 12. The Plaintiff currently resides alone; however, he did exercise primary physical custody of Larry J. Runk, III, until October 13, 2006. 13. The Defendant currently resides with the following persons: a. The children: i. Sarah E. Runk, age 13, since October 21, 2005; ii. Larry J. Runk, III, age 12, since October 13, 2006. 5 b. Her Parents: i. Rodney and Darlene Hockenberry 14. The 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 any other court. 15. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 16. The 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. 17. The best interest and permanent welfare of the children will be served by granting the relief requested for reasons including the following: a. The Father will be able to ensure for the minor children's safety. b. The Father will be able to provide a stable home for the minor children. c. The minor children have a psychological bond with the Father. d. The Father can provide fox the minor children both financially and emotionally. e. The Father will continue to maintain and encourage counseling for the oldest child, Sarah, at Penn State, Hershey Medical Center, Child Psychiatry Department. f. The Father can immediately provide the minor children with the basic day to day necessities. 18. It is believed and therefore averred that the Mother has a drinking problem and has drank an excessive amount when exercising custody of the minor children. 19. Larry J. Runk, III, came home from school in the Spring of 2006, with information regarding "parents and drinking" from a school nurse because he was concerned about his mother's alcoholism. (See Exhibit "A") 6 20. It is believed and therefore averred that the Pennsylvania State Police came to Father's house on December 23, 2006, looking for Mother since hex whereabouts had been unknown for approximately twenty-four (24) hours. Trooper Mitchell of the Pennsylvania State Police was the officer involved. 21. It is believed and therefore averred that Mother was significantly intoxicated during the period of time when her whereabouts were unknown. 22. One of the children reported to the paternal grandmother that the Defendant was at a bar and was visibly drunk. 23. It is believed and therefore averred that Mother knew that daughter Sarah had been arrested, along with hex 13-year old friend, for underage drinking and never informed Father of the arrest. (See Exhibit "B") a. It is believed and therefore averred that Sarah and her 13-year old friend had taken the friend's mother's car and went for a joy ride through the Wal-Mart parking lot, almost striking an individual who was trying to stop them from driving erratically. 24. It is believed and therefore averred that Mother, as a Christmas present for her daughter, Sarah, took her to have her tongue pierced without consulting Father. 25. Since October 2006, Mother has precluded any visitation between the minor children and Father. 26. Mother had arranged fox a visit between Father and the minor children on Christmas Day; however, she canceled the visit and refused Father visitation on Christmas Day. 27. It is believed and therefore averred that Mother suffers from bi-polar disorder. 28. It is believed and therefore averred that Mother's family has a family history of bi- polar disorder. 7 29. It is believed and therefore averred that the family physician, Dr. Robert Michelins, believes that Mother self-medicates herself with alcohol as a way to medicate herself for the bi-polar disorder. 30. Father believes it is in the children's best interest fox a Guardian Ad Litem to be appointed to represent the needs of the children in the ongoing custody proceeding. 31. Defendant failed to inform Plaintiff of the health and well-being of the children. 32. Defendant failed to take Larry J. Runk, III, for a medical appointment with Dr. Michelins on January 22, 2007. (See Exhibit "C") 33. Defendant failed to take Larry J. Runk, III, to a medical appointment with Dr. Page at Susquehanna Surgeons, Ltd., on January 16, 2007. (See Exhibit "D") 34. Plaintiff received a voice message that the Defendant failed to take Larry J. Runk, III, for surgery for an abscess. 35. Plaintiff is without any knowledge whatsoever beyond the above-mentioned condition and appointments. 36. Each parent whose parental rights to the child have not been terminated has been named as parties to this action. 37. Plaintiff has been advised of the requirement to attend the seminar tided "Education Program for Separated Parents" offered by Penn State. 8 WHEREFORE, the Plaintiff requests that This Honorable Court grant primary physical custody of the children to the Plaintiff/Father and shared legal custody of the children to the both the Plaintiff/Father and Defendant/Mother. Respectfully submitted, ABOM & Kt~7'ULAKIS, L.L.P. DATE ~ J 1 Jaso P. Kutulakis Su eme Court ID 80411 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaint 9 I, Larry Runk, II, verify that the statements made in this Custody Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. X4904 relating to unsworn falsification to authorities. 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(~ r~. r~. :..: 0 i~ a~ 3 ~ ~c .. ~ ~~ qq oS Q i ~ ~ .~ ~ ~ v r a °~- ~ ~~ ~~~ .~ .~~ r/ u ~Ll n~ Ili 1 U T m t10 N~ ~.. ~ ~ ~ ~ ~ O m +--~ ~_~ _ (b O~ O N N ~ N Q Y V ~"' ~ +J ~~ _~ CO ~ C ca ~ ~ m .Q o c~ a~ >. °~ 1- ~ ° ~ ~ ° °~ '0~ ,~ ~ ° ' ~~ ~ a ' ~ a~~~ ~ -o ~ ~~ c .coo o~~c ~o Z:co~a i :.c~a~~ ' ° s~~ ~~o ~o~°-o= o~~o ~~oo ~~ ~ o ~ O ~ O C f0 ° f~ C Q O `~ 'C ~ (~ t i Z mro O ~ N ~L w N p~(d" NL ~~ C C U RS 3~o~Q ~~ •~~~ . v l Y C N~ ~~Y~~ ~ ~ (~ o •~;~ ~ , U~~`~~ N '-' O ~ ~ ~ U.Q.--~ ~i ~ ~ N N O O ~ C . - 0 ` L ~ C ~ ~ ~~> O 0 ~~ C > ~ + N >+~ = ro L O~ ~ -C ~ cC , O CC ~ L O , .C N L~ ~ ~ ~ ~a What Can Kids Do? Page 1 of 2 .~ . ~ ~, ~+- ~ ~ ~f What Can Kids Do? Here are a few suggestions for you: DO talk about how you feel. You can talk with a safe person in your life - maybe a close friend, relative, school counselor, teacher, minister, or others. Sharing your feelings is not being mean to your family. When you talk to someone, you might feel less alone. Talking to someone about your feelings can help you feel less alone. DO try to get involved in doing enjoyable things at school or near where you live--the school band, softball, Boy or Girl Scouts, or others. Doing these types of activities can help you forget about the problems at home, and you could learn new things about yourself and about how other people live their lives. DO remember that feeling afraid and alone is a normal way to feel when you live with alcoholic parents. It's confusing to hate the disease of alcoholism at the same time that you love your alcoholic parent. All people have confusing feelings: two different feelings at the same time. This is the way many kids feel about alcoholic parents. DO remember to have fun! Sometimes children with alcoholic families worry so much that they forget how to be "just a kid." If things are bad at home, you might not have anyone who will help you have fun, but don't let that stop you. Find a way to let yourself have fun. DON'T ride in a car when the driver has been drinking if you can avoid it. It is not safe. Walk or try to get a ride with an adult friend who has not been drinking. If your parents are going out to drink somewhere, try not to go with them. If you must get in a car with a drinking driver, sit in the back seat in the middle. Lock your door. Put on your safety belt. Try to stay calm. DON'T think that because your parent is an alcoholic you will be one too. Most children of alcoholics do not become alcoholics themselves. DON'T pour out or try to water down your parent's alcohol. The plain fact is that it won't work. You have no control over the drinking. You didn't make the problem start, and you can't make it stop. It is up to your parent to get treatment. What your parent does is not your responsibility or your fault. http://www.nacoa.net/cank:ids.htm 3/19/2002 tai •~respu~~,µti, .,,wig instruments ox , ~«~'nme and criminal mischie'f', and Brandon Hetrick faces ~ :one count of receiving sto- ~ '~ .~ ien property. ,, ,~~'he $oth were freed_on ,;d the ac- $10,000bai1 and the chil- .a, who noticed dren were placed in the cu&- ~horized withdraw- tody of Cumberland County ~stly of $1,000 at a Children & Youth Services; Endangerment charged~ ~eldatat ,s~'~a ,~ ~ ¢,~~, LOWERPAXTON TWP. ~ " 3mes,'Inc A 13,year old girl is facing r~: ~ ~" it AM on reckless endan erment ~ r j <~=Smoke damages home ber 9th, 2006 charges after a~robe of a k Egi'esites Nov. 18 incident in the Wal- A furnace malfunction meat at Riv,-" M~ Pm'~g lot. • , ,'. .. sent heavy black smoke , ~ Gardens in "'Police: said they were '" • rolling through a home rn ; jSattirday' called tgthe ionaround 9 f ~~, ;; :;the 44.00 block of genus at the planer , ~'~' by ~~esses who said ,",Avenue in Linglestown at . ,, f ~• ~ ~ ; ~ two cluldx~e~n, wexe ~iriviing,a"}o:30 a.m Monday, ;butfire = ~. sport u#~i~wehicle anc~ had officials said there were no .tions ma F'Y nearly hit''a„Wal-Mart e~ ~ inluries:and Drily light dope in loyee wh~.~;vas pushrng' , L j~ ~ smo~ke`daixlage: ~ ~ :ha Chapol ~~ h~PPmB`carts• .: , ~ ~~ ' . "An`eYectrical sole~ioid rysburg, P~~ ~ °;Z'herl3-year,=fold t~lrlve~ melted inside the furnace to online ~ ~ was found to have taken the sand the smoke way pulle +• ~ ~~:~°~`~' °S1:N wathou't he"~~aioth~~'~ ~'into~the fan and then Pb ,rmes.com ; r..pemissio#~i; pohce'sai~.~I~r ~,~throughout the"house,, a.com/obits ~~~ ewer` Vyas also l3 ~~. ~ Linglestown Fire ChiF ~' ~ ,~~, • ~gesw~ll be handled ry Piench said. , . ~ +s, by~~Cumbi'i'iand Count~~u ~ ~`• ~"` ~ vencle prob~hon;~~olrce ~ ~-ti ~ '" " °°~ ~~ ~ WATARA TW' _ ,,,~,,~ said ~~~`'~~ ,~ w ~. •ichetle~ ~ ~ ~ ~ r r son : ~ ~. " NNSe~~ Yrv~. ~. ; . ~ , _ ~ ~ ~_~: ~~~''' Police ~~,,,1daM.~~' ~, ~Z awes ed•in;biiig~ary~~ ~witnes~ . T.ord on'~ ~,. ,Two den were,arr,'es~`~d ;." , uu~,~~. ~~ \ vc duruig a buxglary;arou~ RterdzW at', ~;:~.~:<<~,. a.m: vA 1:15 i,.- h . _ gY •ous con! Je«... .muds re Ts oiltng ~prings: 11, a.m. in Mt. ;~The includin~ . Coxnmiti r ~: of the;fc~~lo~Vin~ services ,~~r: o~ly-Springs Church of God, 14, , ri ~ H .school i ngs; . Sp olly a ~~~aiifield St., Mt. Thur ~ Attucks . ~ s~y~_ ~~,,, ~> ~~.. , ~•~~ ~ p Q ~ ,lemler 'of ~ ltabon bne hour rior. • Nancy ~ ~ board,~St ; . `' ~ ~' ,~~. • `~. x '~ ness .and ?the Dgv-1 ~j~~~r .motel by police. ~Elem' ~ T~vof I3~~,y ~ ~, a"J~mmy" ,SiJV up and down :_ arents but the dri- ase'd to~ heir e ~ p ~of't sl ' ~ For 1 at St.~ J . l e s ai the , ver was cited for reckless ent7angerment. ~ . -dean a i Wass ;. m. Nov 11 'Carlisle police say ahe incident took place',"about 9.p• _ -- " n . "~aumin - `= Police say the driver took her mother's SiN without her permission. tes Pr A Wal-Mart employee who pushes carts told police the vehicle near- : Police say no u~uries or property damage occurred. hi o o Found m. ver ly ran 1 z i .'+ ., - ;.1 f•. EN HILL GRE F.A-MILY ~-I C;~~1TER A SERVICE OF HOLY SPIRIT HEALTH SYSTEM Date: ~ ~ `a ~ ~ 7 ~~ < Dear On Q ~'.~ ~ - 0 7 ,you failed to show for your appointment with Dr. Ciccarelli chelini at ow Green Hill Family Health Center. Spirit Physician Services defines a failure to show as failure to present on time for you scheduled appointment or failure to give 24 hours cancellation notice. --.-.. The system-wide policy for missed appointments within a 12 month time period is as follows: .st :2:ssed appoi_rtri°nt: ~~vritter_ roti~i~•~:tion - no cl~~rge Second missed appointment: $40.00 missed appointment fee Third missed appointment: discharge from care This represents your UQ First; ( )Second missed appointment within the past V months. Please realize that r missed appointments make it difficult to respond to the needs of other patients. Robert L. Tecau, DO Medical Director, SPSI Your Partner For Good Health 503 Bridge Street • New Cumberland, PA 17070 (717) ?74-8400 • Fax (71?) 774-8607 • ~ • • O Heritage Medical Group Listening, caring, leading. Susquehanna Surgeons, Ltd. 532 North Front Street George B. Faries, Jr., M.D. Wormleysburg, PA 17043 Kenneth W. Graf, M.D. Michael J. Page, M.D. Phone 1 761-4141• Fax 7) Ronald G. Barsanti, M.D. Joseph P. Esposito, M.D. (7 ~ (71 761-1456 Rolando A. Casal, M.D. A. David Froehlich, M.D. Anastasius O. Peter, M.D. Lisa K. Torp, M.D. William P. Brown, D.O. January 17, 2007 Mr. Larry J. Runk, III 32 George Brown Road Millerstown, PA 17062 Dear Mr. Runk: You were scheduled to see Doctor Page on January 16, 2007 but failed to keep this appointment We have documented this as a missed appontment or no-show since you failed to contact us at least 24 hours prior to your sd~eduled appointment time. If you feel that this in error, please contact our office. Missed appointments or no~tlow5 are a serious ooncem in the continuing course of medical treatment and care. Appointments are scheduled for a variety of reasons, including ongoing monitoring of chronic condfions, assessments of an acute condition, investigation of a new problem or for a general comprehensive health review, to name a few. A missed appointment can cause a lapse of important treatrnent, ineffirtieent use of time for staff and physicians, and a missed opportunity for another patient who may have needed an appointment Due to the problems a missed appointment causes Heritage Medical Group has adopted the following policy: • The first missed appantrnent will generate a letter outlining our policy. • The second missed appointment will generate a charge of $45.00 and a warning letter. • The third missed appointment will cause dismissal from our practice. We continually strive to provide optimal medical rare and access to our physicians and staff. We would appreciate your assistance. If you find that you are unable to maintain a scheduled appointment, please call the office at least 24 hours prior in you appointment to reschedule to a time that better suits your needs. If you have not already rescheduled your missed appointment, please contact our office at your earliest convenience so that we can provide you with the optimal care we strive to deliver to all our patients. Sincerely, Thomas. E. Callahan Office Manager Susquehanna Surgeons, Ltd. Heritage Cardiology Diagnostic Center Heritage Diagnostic Center Heritage Medical Group Laboratory (717) 972-2829 (717) 737-3037 (717) 909-0933 1-86CrHMG-DOGS www heritagemedgrp.com AND NOW, this ~ day of February 2007, I, Jason P. Kutulakis, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Custody Complaint to the Defendant, advised the Defendant that she is required to attend the "Education Program for Separated Parents" and provided the Defendant with a registration form for the Program, by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Michael Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 Attorney for Defendant Respectfully submitted, Abom & Kutulakis, L.L.P. Jaso P. Kutula.kis Sup eme Court ID 80411 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaint 11 ~~ S D~~~rf'"~ ~ vN09~ ~ ~ ~O ,S 9 / ~. ' ,~ i ~n ~~ r ! ~.. ~ `;,~^~!'l~'`y . M1 7•,J Ari'~ ~~ ~ ~: ~~~ = H1 ~G O OFFICE LOCATIONS CARLISLE OFFICE 1 • ~ (717) 249-0900 LI T LI LA K I S HARRISBURG OFFICE (717) 232-9511 ATTORNEYS AT LAW CHAMBERSBURG OFFICE (717) 267-0900 YORK OFFICE February 6, 2007 (717) 846-0900 Prothonotary Perry County Courthouse Center Square New Bloomfield, PA 17068 Re: Larry Runk II v. Rebecca Runk fn Custody Dear Sir or Madam: Enclosed for filing with your office please find an original and one copy of a Custody Complaint in the above-referenced matter along with the filing fee of $97.50. Kindly timestamp the extra copy and return it to my office in the enclosed, self- addressed, stamped envelope provided for your convenience. Thank you in advance for your anticipated cooperation to this request. J PK/tlf Enclosure cc: Michael Scherer, Esquire Larry Runk, II Very truly yours, © ~~'. A$o &Kutulakis, LLP ~ .~ _ ,~ _ _ ~ .. Jason P. Kutulakis ~_ tv ..._ w Reply To: 36 SOUTH HANOVER STREET CARLISLE, PA 17013 (717) 249-0900 FAx(717) 249-3344 ~n ~ y ~ ~~ a z d O °~ ~ ~ ~ .. .. ~ o H H ,~ °z O ~ .r ~ A C ~ ~ ,~.~ ~ ~ C ~ ~ ~ ~ O ~• a o n coo co ~ ~ ~ ~ ~ o A Q1~ fD ~D~ ~'~f a ao 0 a~ S~ 2 5 d~ r v k..1 LARRY RUNK, II, Plaintiff v. REBECCA RUNK, Defendant AND NOW, this IN THE COURT OF COMMON PLEAS CUMBERLA,NL D COUNTY, PA NO. (;~ ' ~ ~I 3 ~ CNIL TERM CNIL ACTION -LAW IN CUSTODY ORDER OF COURT day of July, 2007, upon consideration for the Petition for Special Relief, it is hereby ORDERED and DIRECTED that a hearing shall be held on the day of , 2007 at .m. in Courtroom Number of the Cumberland. County Courthouse. It is further ordered that Father shall exercise custody on alternating weekends from Friday until Sunday until said hearing, beginning with the first Friday following the date of this Order. BY THE COURT, J~ • ~ ~ 11 >) f LARRY RUNK, II, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA REBECCA RUNK, Defendant NO. ~ 7~ y`f 3 I CNIL TERM CNIL ACTION -LAW IN CUSTODY PETITION FOR SPECIAL RELIEF AND NOW this ~da of ul 2007 comes the Plaintiff La Runk II b an .~- y J y, ~y y d through his counsel Jason P. Kutulakis, Esquire, of Abom & Kutulakis, LLP, and requests this Honorable Court to schedule an emergency hearing on custody, and in support thereof, avers the following: 1. On February 7, 2007, Petitioner filed a Complaint for Custody in the Court of Common Pleas of Perry County. See Complaint attached hereto as Exhibit A. 2. On February 9, 2007, the Honorable Kathy A. Morrow appointed Barbara Wevodau, Esquire as Guardian Ad Litem for the minor children. See Order of Court dated February 9, 2007 attached hereto as Exhibit B. 3. On March 13, 2007 at 8:30 a.m., the parties were scheduled to appear for a Conciliation in the Perry County Court of Common Pleas. See Order of Court attached hereto as Exhibit C. 4. Mother, Rebecca Runk, failed to appear for the Conciliation. 5. On March 21, 2007 a Rule was issued to show cause why the matter should not be transferred to Cumberland County. 6. On Apri120, 2007 undersigned Counsel filed a Praecipe to List for Conciliation and Trial within 45 and 100 days respectively. See attached Exhibit D. 7. On May 1, 2007, the Honorable Kathy A. Morrow issued an Order transferring the matter to Cumberland County. See Order of Court attached hereto as Exhibit E. ,. _ ~ 8. On or about June 4, 2007 the Prothonotary of Perry County transferred the file to Cumberland County. 9. As of July 25, 2007, the Cumberland County Prothonotary has not assigned a docket number as the filing fee has yet to be paid by Defendant pursuant to ~1915.2(d). 10. In October 2005, Wife, Rebecca Runk, left the marital home. 11. In leaving the marital residence, Mrs. Runk took the oldest child, Sarah, to reside with her. 12. During the course of the next year, the younger child, Larry, III, resided in the marital residence with his father, Larry. 13. Between October 2005 and October 2006, the subject minor children regularly lived with and visited Father, Larry Runk. 14. In October 2006, Mother, Rebecca Runk, took both children and moved to reside with hex parents, Rodney and Darlene Hockenberry, at 42 Clay Road, Carlisle, Pennsylvania. 15. Since October 2006, Rebecca Runk has refused to provide visitation between the children and their father, with one exception on February 10, 2007, she permitted a day visit with Father and Jimmy to attend the Sportsmen's Show. 16. The parties appeared and testified before the Support Conference Officer, Michael Rundle, Esquire, on June 4, 2007. 17. At that conference, Rebecca Runk testified that both children suffer from depression, although Larry Runk, III has not formally been diagnosed with depression. 18. Mrs. Runk also testified that the onset of this depression was October 2006, which is coincidentally the time when she removed the children from the marital residence and stopped all contact between Larry Runk and his children. ~~ .r ~ 19. Mother refuses to permit any communication between the children and their father.' 20. Approximately 10 months have elapsed since the children have seen or spoken with their father. WHEREFORE, Petitioner respectfully requests an Emergency Hearing be held to facilitate and direct that the children have immediate visitation with their father. Respectfully submitted, Date: / ABOM & KUTULAKIS, LLP Jas - . Kutulakis, Esquire 36 uth Hanover Street C 'sle, PA 17013 (717) 249-0900 ID #80411 ~ Protection from Abuse Order was entered on November 21, 2006. Said Order placed the children in the physical custody of Mrs. Runk with the Defendant to have reasonable periods of partial custody as agreed upon by the parties. It also should be noted that the children were not protected persons under the Order. The PFA expires November 18, 2009. ,. ,. CERTIFICATE OF SERVICE AND NOW, this ~ day of July, 2007, I, Jason P. Kutulakis, Esquire of ABOM,& KUTULAKIS, LLP, hereby certify that I did serve or cause to be served a true and correct copy of the foregoing Petition for Special Relief by First Class U.S. Mail addressed to the following: Michael A. Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 Larry Runk, II 32 George Brown Road Millerstown, PA 17062 Jaso P. Kutulakis, Esquire ~ ~ v ~ ~ r 1 oM ~ uTU~,~Is Jason P. Kutulakis, Esquire Atty I.D. #: 80411 36 South Hanover Street Carlisle, PA 17013 LARRY RUNK, II, Plaintiff v. REBECCA RUNK, Defendant _. ~ ~~.. v ~.:.~ ~ ~. - rn r ._., ~ a ..~ _ ~ - - ;, IN THE COURT OF COMMON PLFAS; ~ PERRY COUNTY, PA - ~- .~- NO. CIVIL. TERM CIVIL ACTION -LAW IN CUSTODY 1. Plaintiff is the Father, Larry Runk, II, who currently resides at 32 George Brown Road, Millerstown, Perry County, Pennsylvania 17062. 2. Defendant is the Mother, Rebecca Runk, who currently resides at 42 Clay Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff and Defendant have been bona fide residents in the for at least six (6) months immediately previous to the ftling of this Complaint. 4. Paragraphs one (1) through three (3) of this Complaint are incorporated herein by reference as though set forth in full. ~~R~e~l~~ ~ TR ~ ~, 'fir, r Diu ', ~~ 5. The Plaintiff seeks custody of the following children: Name Address DOB Sarah Elizabeth Runk 42 Clay Road, February 20, 1993 Carlisle, Pennsylvania. 17013 Larry James Runk, III 42 Clay Road, July 4, 1994 Carlisle, Pennsylvania 17013 6. Sarah E. Runk and Larry J. Runk, III, were born in wedlock. 7. The children are in the primacy custody of the Defendant, residing at 42 Clay Road, Carlisle, Cumberland County, Pennsylvania. 17013. 8. During the children's lifetime, they have resided with the following persons and at the following addresses: Name Address Date Larry Runk, II, & Rebecca. Runk 32 George Brown Road Sarah: Birth to 10/21 /05 Millerstown, Pa 17062 Larry III: Birth to 10/21 /05 Rebecca Runk 42 Clay Road, Sarah: 10/21 /05 to Present Carlisle, Pa 17013 Larry III: 10/21 /OS to 12/25/05 Larry Runk, II 32 George Brown Road Millerstown, Pa 17062 Larry III: 12/25/05 to 10/13/06 Rebecca Runk 42 Clay Road, Carlisle, Pa 17013 Larry III: 10/13/06 to Present 9. The mother and father of the children are currently married. 10. The relationship of Plaintiff to the children is that of Father. 11. The relationship of Defendant to the children is that of Mother. 12. The Plaintiff currently resides alone; however, he did exercise primary physical custody of Larry J. Runk, III, until October 13, 2006. 13. The Defendant currently resides with the following persons: a. The children: i. Sarah E. Runk, age 13, since October 21, 2005; ii. Larry J. Runk, III, age 12, since October 13, 2006. 5 ~ ~ u ~ • ~ - b. Her Parents: i. Rodney and Darlene Hockenberry 14. The 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 any other court. 15. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 16. The 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. 17. The best interest and permanent welfare of the children will be served by granting the relief requested for reasons including the following: a. The Father will be able to ensure for the minor children's safety. b. The Father will be able to provide a stable home for the minor children. c. The minor children have a psychological bond with the Father. d. The Father can provide for the minor children both financially and emotionally. e. The Father will continue to maintain and encourage counseling for the oldest child, Sarah, at Penn State, Hershey Medical Center, Child Psychiatry Department. f. The Father can immediately provide the minor children with the basic day to day necessities. 18. It is believed and therefore averred that the Mother has a drinking problem and has drank an excessive amount when exercising custody of the minor children. 19. Larry J. Runk, III, came home from school in the Spring of 2006, with information regarding "parents and drinking" from a school nurse because he was concerned about his mother's alcoholism. (See Exhibit "A") 6 i • 1 20. It is believed and therefore averred that the Pennsylvania State Police came to Father's house on December 23, 2006, looking for Mother since her whereabouts had been unknown for approximately twenty-four (24) hours. Trooper Mitchell of the Pennsylvania State Police was the officer involved. 21. It is believed and therefore averred that Mother was significantly intoxicated during the period of time when her whereabouts were unknown. 22. One of the children reported to the paternal grandmother that the Defendant was at a bar and was visibly drunk. 23. It is believed and therefore averred that Mother knew that daughter Sarah had been arrested, along with her 13-year old friend, for underage drinking and never informed Father of the arrest. (See Exhibit "B'~ a. It is believed and therefore averred that Sarah and her 13-year old friend had taken the friend's mother's car and went for a joy ride through the Wal-Mart parking lot, almost striking an individual who was trying to stop them from driving erratically. 24. It is believed and therefore averred that Mother, as a Christmas present for her daughter, Sarah, took her to have her tongue pierced without consulting Father. 25. Since October 2006, Mother has precluded any visitation between the minor children and Father. 26. Mother had arranged for a visit between Father and the minor children on Christmas Day; however, she canceled the visit and refused Father visitation on Christmas Day. 27. It is believed and therefore averred that Mother suffers from bi-polar disorder. 28. It is believed and therefore averred that Mother's family has a family history of bi- polar disorder. 7 29. It is believed and therefore averred that the family physician, Dr. Robert Michelins, believes that Mother self-medicates herself with alcohol as a way to medicate herself for the bi-polar disorder. 30. Father believes it is in the children's best interest for a Guardian Ad Litem to be appointed to represent the needs of the children in the ongoing custody proceeding. 31. Defendant failed to inform Plaintiff of the health and well-being of the children. 32. Defendant failed to take Larry J. Runk, III, for a medical appointment with Dr. Michelins on January 22, 2007. (See Exhibit "C") 33. Defendant failed to take Larry J. Runk, III, to a medical appointment with Dr. Page at Susquehanna Surgeons, Ltd., on January 16, 2007. (See Exhibit "D") 34. Plaintiff received a voice message that the Defendant failed to take Larry J. Runk, III, for surgery for an abscess. 35. Plaintiff is without any knowledge whatsoever beyond the above-mentioned condition and appointments. 36. Each parent whose parental rights to the child have not been terminated has been named as parties to this action. 37. Plaintiff has been advised of the requirement to attend the seminar titled "Education Program fox Separated Parents" offered by Penn State. 8 r • ~ [~/FIEREFORE, the Plaintiff requests that This Honorable Court grant primary physical custody of the children to the Plaintiff/Father and shared legal custody of the children to the both the Plaintiff/Father and Defendant/Mother. Respectfully submitted, AaoNr&KuTULAKIS, L.L.P. DATE y ~ ~ , a Jaso P. Kutulakis Su eme Court ID 80411 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaint 9 ~', ~. ~ -, VFRIFIGATION I, Larry Runk, II, verify that the statements made in this Custody Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 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Here are a few suggestions for you: DO talk about how you feel. You can talk with a safe person in your life - maybe a close friend, relative, school counselor, teacher, minister, or others. Sharing your feelings is not being mean to your family. When you talk to someone, you might feel less alone. Talking to someone about your feelings can help you feel less alone. DO try to get involved in doing enjoyable things at school or near where you live--the school band, softball, Boy or Girl Scouts, or others. Doing these types of activities can help you forget about the problems at home, and you could learn new things about yourself and about how other people live their live-. DO remember that feeling afraid and alone is a normal way to feel when you live with alcoholic parents. It's confusing to hate the disease of alcoholism at the same time that you love your alcoholic parent. All people have confusing feelings: two different feelings at the same time. This is the way many kids feel about alcoholic parents. DO remember to have fun! Sometimes children with alcoholic families worry so much that they forget how to be "just a kid." If things are bad at home, you might not have anyone who will help you have fun, but don't let that stop you. Find a way to let yourself have fun. DON'T ride in a car when the driver has been drinking if you can avoid it. It is not safe. Walk or try to get a ride with an adult friend who has not been drinking. If your parents are going out to drink somewhere, try not to go with them. If you must get in a car with a drinking driver, sit in the back seat in the middle. Lock your door. Put on your safety belt. Try to stay calm. DON'T think that because your parent is an alcoholic you will be one too. Most children of alcoholics do not become alcoholics themselves. DON'T pour out or try to water down your parent's alcohol. The plain fact is that it won't work. You have no control over the drinking. You didn't make the problem start, and you can't make it stop. It is up to your parent to get treatment. What your parent does is not your responsibility or your fault. http://www.nacoa.net/cank:ids.htm Page 1 of 2 3/19/2002 • ~ .at~resp«ss,r,., .. ,A~iing instruments ai ,•:frime grid criminal mischief, ~'_ and Brandon Hetrick -faces ,` ~ one count of receiving sto- ~ 4; ., len property. ; ~ ,, f .. he ,Both were freed on - -d the ac- $10,000-bail and the chrl .a, who noticed dren were placed in the cus- _chorized withdraw- tody of Cumberland County .qtly of $1,000 at'a . Children & Youth Services. ~~,Kme. Endangerment charged ` ` ~ geld at at : ,: LOWER PAXTON TWP. { Ames, Inc A 13-year-old girl is facing 11 AM on reckless eadair~ement Smoke damages home ber 9th, 2006 ' charges after a probe of a ~ ~` k Egresites Nov. 18 incident in the Wal- A furnace malfunction meat at ltiv - Mart parking lot. < sent heavy black smoke 1 Gardens in ' Polrceaaid they were ~ rolling through a home m ;' 3 Saturday` - called to;,the lobaround 9 ` , ..._ 'the~4400 block of Venus . . at the Tuner - p•m. by vvitnesses_who said . Avenue, in Linglestown at , ,~, ' two child;en we~•e driving a* ;. 10:30 a.m, lVionday, but fire • bons lnay sport utilifyvehicle and~had , .." officials'sard there were no° . .: 3ope in nearly krit"a Wal-Mart em- .; ~ inlurres `and only lrght ; ; 2 . ha Chapel ~ ployee who was pushing , ~ : smoke damage:: ,. . rysburg, PA shopping carts. ;._ ~ The 13-year-old driver' ~ ' ~ "Att electrical solenoid melted inside the furnace to online = was found to have. taken the, .~, and the smoke was pulle + SUV wrthout her mother's `into the fan and then.~v ~mes.com. permission, police Bard. Her ~ throu out the"liousex" gh .corn/obits , - passengef'was also 13..'. ~ :. , Linglestown Fire ChiF • ~ ~ ' Chazgeswill be-handled ry Pierich said. ` , '~' - 4; hyCumberl and County ju _, venile probation, police " ichelie ~' said. a ~ ~: .: SWATARA TW' - ~ ~ ; '~ 4~ , . ~ ~ ~ ~ ~ . A ident or SOt1 ~ ~~ :, ~ '~ 1EAST PENNSBORO TWP. cc .,pr ~ ' `~ ~~Mn ~:~ i 2 ar ' ' t d m k Police f r e s e burglary ~'' witne~~ ~'Anderson;~ . ~ d' T,ord on` - '.Two men were arrested w' " ,during a burglary arou , ~~ by ~ `laS,a.m: vA.aterd:w at ' : "" ., L`" gyms..: ous coy EXHIBIT . * The 'Seg.... .nrnds reacie'rs,` Boiling Springs: 11 a m. in Mt. ~,': f f ' ~ s '` ~ :Holly Springs Church of God, 14 ' o the ollowm seivtce Thursday > >, ; _, Fairfield St.; Mt: -Holly. Springs; ~• Nancy Carolyn Blemler 'of ~ visitation one hour prior. - _ ~; 1 - ~.; ~ 1 ,, ,. _ .. .Underage ,driver, cued by police, L' ;. ~; '- , Tbvo 13-yeaz-old girls who drove a "3immy",,;SiJV up and down i :~ the`aisles of the Val-Mart vuere released to theirparents but the dri= '' ver was cited for reckless endangerment. Carlisle police say;the incident took place about 9 p:m. Nov: ,11. `` Police say the driver took her`mother's SUV without.her permission. ': A Wal-Mart employee who pushes carts told police The vehicle near- , ly ran over him. Police .say no injuries or property damage occurred. . ;. school + Attucks board, S: For': at St:~ dean c Protes Fount' T' • ,. ', ~~ GREEN HILL FAMQY HEAtiTH CENTER A SERVICE OF HOLY SPIRIT HEALTH SYSTEM Date: 0 ~ `~ ~. -O 7 ~a-~c-~-~~ ~ < ~c~,z./c%!~ Dear ~~~~ On Q f -.~ .~ - 4 7 ,you failed to show for your appointment with Dr. Ciccarelli chelini at our Green Hill Family Health Center. Spirit Physician Services defines a failure to show as failure to present on time for you scheduled appointment or failure to give 24 hours cancellation notice. The system-wide policy for missed appointments within a 12 month time period is as follou,~s: •' 1 ~a~JJ...s wppCi at1:i:. .L. ~r~' ~ ~ S.d~. : '~ ~ ~~~i' Second missed appointment: $40.00 missed appointment fee Third missed appointment: discharge from care This represents your ~jQ First; ()Second missed appointment within the past V months. Please realize that r missed appointments make it difficult to respond to the needs of other patients. Robert L. Tecau, DO Medical Director, SPSI Your Partner For Good Health 503 Bridge Street • New Cumberland, PA 17070 (717) 774-8400 • Fax (717) 774-8607 EXHI~T ` r ~ • ~ ~ ~,~, Heritage Medical Grou p Listening, caring, leading. Susquehanna Surgeons, Ltd. 532 North Front Street George B. Faries, Jr., M.D. Wormleysburg, PA 17043 Kenneth W. Graf, M.D. Michael J. Page, M.D. Ronald G. Barsanti M.D. Joseph P. Esposito, M.D. Phone (717) 761-4141 • Fax (717) 761-1456 Rolando A. Canal, M.D. A. David Froehlich, M.D. Anastasius O. Peter, M.D. Lisa K. Torp, M.D. William P. Brown, D.O. January 17, 2007 Mr. Larry J. Runk, III 32 George Brown Road Millerstown, PA 17062 Dear Mr. Runk: You were scheduled to see Doctor Page on January 16, 2007 but failed to keep this appointment. We have documented this as a missed appointment or no-show since you failed to contact us at least 24 hours prior to your scheduled appointment time. If you feel that this in error, please contact our office. Missed appointments or no-shows are a serious concern in the continuing course of medical treatment and care. Appointments are scheduled for a variety of reasons, including ongoing monitoring of chronic conditions, assessments of an acute condition, investigation of a new problem or for a general comprehensive health review, to name a few. A missed appointment can cause a lapse of important treatrnent, ineffiaent use of time for staff and physicians, and a missed opportunity for another patient who may have needed an appointment. Due to the problems a m~ appointment causes Heritage Medical Group has adopted the following policy: • The first missed appointment will generate a letter outlining our policy. • The second missed appointment will generate a charge of $45.00 and a warning letter. • The third missed appointment will cause dismissal from our practice. We continually strive to provide optimal medical care and access to our physicians and staff. We would appreciate your assistance. ff you find that you are unable to maintain a scheduled appointment, please call the office at least 24 hours prior to you appointment to reschedule to a time that better suits your needs. If you have not already rescheduled your missed appointment, please contact our office at your earliest convenience so that we can provide you with the optimal care we strive to deliver to all our patients. Sincerely, Thomas. E. Callahan Office Manager Susquehanna Surgeons, Ltd. i ' EXI-IIBIT Heritage Cardiology Diagnostic Center Heritage Diagnostic Center Heritage Medical Group Laboratory (717) 972-2829 (717) 737-3037 (717) 909-0933 1-86CrHMG-DOGS wwwheritaQemedQm rnm ' r a AND NOW, this ~ day of February 2007, I, Jason P. Kutulakis, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Custody Complaint to the Defendant, advised the Defendant that she is required to attend the "Education Program for Separated Parents" and provided the Defendant with a registration form for the Program, by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Michael Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 Attorney for Defendant Respectfully submitted, Abom & Kutulakis, L.L.P. Jaso P. Kutulakis Sup erne Cow.-t ID 80411 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaint 11 LARRY RUNK, II, Plaintiff v. REBECCA RUNK, Defendant IN THE COURT OF COMMON PLEAS PERRY COUNTY, PA NO. CIVIL TERM CNIL ACTION -LAW IN CUSTODY ORDER OF O TRT AND OW, this ~ ~ day of ~C C1' `rG ' , 2007, (f ~. ~~~~- ~ 1~ ~~~ is Hereby appointed Guardian Ad Litem for the minor children, Sarah Elizabeth Runk, born February 20, 1993, and Larry James Runk, III, born July 4, 1994. BY THE COURT, J~ _~' ~~ fir; ~~.3(1 ~ ~r1 _ f_-.M_ 2 ~ ~ r ~ , i r LARRY RUNK, II, Plaintiff v. REBECCA RUNK, Defendant IN THE COURT OF COMMON PLEAS PERRY COUNTY, PA NO.~C ~~`n~ C~ L TERM CIVIL ACTION -LAW IN CUSTODY You, Rebecca Runk, have been sued in Court to obtain custody, partial custody or visitation of the children. You are ordered to appear in person at the Perry County Courthouse, New Bloomfield, Perry County, Pennsylvania, on the ~ day of ~ 2007, at U ' 3y ~ M. for a custody conference. If you fail to appear as provided by the 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. r- `, ca c~_, L~..7 i, r.> - ~_ t.., BY THE COURT, 6~T/~ G~ ,~eR ~ o ~=cJ J ~ 1~ DEPUTY PROTHO OTARY CENTRAL PENNSYLVANL4 LEGAL SERVICES 213A N. Front Street Harrisburg, PA 17101 (800) 932-0356 ~ ~ i ~ LARRY RUNK, II, Plaintiff v. REBECCA RUNK, Defendant IN THE COURT OF COMMON PLEAS PERRY COUNTY, PA NO. FC 2007-42 CNIL TERM CNIL ACTION -LAW IN CUSTODY TO THE PROTHONOTARY OF SAID COURT: PRAECIPE TO LIST CASE FOR TRIAL PURSUANT TO 42 PA C.S.A. 1915.4 and 1915.4-1 Please list the above matter for trial pursuant to Rule 42 PA C.S.A. X1915.4 and X1915.4-1. ABOM & KUTULAHIS, LLP Date: ~ ~j,~~ ~~ O " Ja n P. Kutulakis, Esquire 3 outh Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney ID No. 80411 Attorney for Plaintiff .- r~s r ; r ~, r ~• ~, I r ag ; r-,r...~.... ~`~~ IN THE COURT OF COMMON PLEAS OFD` ~ ~j "~~ LARRY RUNK, II, _ E_,~; 7 Plaintiff PERRY COUNTY, PENNSYLVANIA=~J ~ __ t~ ,=r ., - s. {, V. NO. FC 2007-42 ~ _ ; '' REBECCA RUNK, IN CUSTODY Defendant ORDER OF COURT AND NOW, this ~ day of , 2007, upon consideration of the within Petition To Make Rule Absolute, the Rule entered in this matter on March 20, 2007 is hereby made absolute; and this custody action shall be transferred to Cumberland County pursuant to Pa.R.C.P. 1915.2(d). BY THE COURT, ~~ " ` ~ 2'x.1 thy A. orrow, Ju ge ~a~r lt/ i ~ - ~6AL~ ' ~lJ~c"'~ ~~~ ~O~ i7o6~ ~ y ,c~~'~~Yr Michael A. Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, Pennsylvania 17013 Jason P. Kutulakis, Esquire Abom &Kutulakis 36 South Hanover Street Carlisle, Pennsylvania 17013 ~~~ ~~_; ~:: ~.._ ~~ CERTIFIED TRUE COPY ~!EPUTY PROTHONOTARY LARRY RUNK, II, Plaintiff IN THE COURT OF COMMON PLEAS OF PERRY COUNTY, PENNSYLVANIA ; _, • .~- NO. FC 2007-42 IN CUSTODY :-` ~.::, V. REBECCA RUNK, I~ Defendant PETITION TO MAKE RULE ABSOLUTE __.~ 1. The Petitioner is the Defendant, Rebecca Runk, who resides at 42 Clay Road, Carlisle, Cumberland County, Pennsylvania (hereinafter "Mother") 17015. 2. The Respondent is the Plaintiff, Larry J. Runk, II, who resides at 32 George Brown Road, Millerstown, Perry County, Pennsylvania (hereinafter "Father") 17062. 3. The parties are the parents of two children: Sarah E. Runk, born February 20, 1993 and Larry J. Runk, III, born July 4, 1994. 4. Michael A. Scherer, Esquire represents Mother. 5. Jason Kutulakis, Esquire represents Father. 6. On or about March 20, 2007, this Honorable Court entered upon Larry Runk, II, a Rule To Show Cause Why this Matter Should Not Be Transferred to Cumberland County Pursuant to Pa.R.C.P. 1915.2(d). 7. The Rule was served on Jason P. Kutulakis, Esquire, counsel for the plaintiff, on March 26, 2007. 8. Thirty (30) days have elapsed since service of the Rule. ;~ . 9. Plaintiff has failed to show cause why this matter should not be transferred to Cumberland County for the reasons set forth in the petition, including: (a) Mother resides in Carlisle; j~ (b) The children reside with Mother in Carlisle; (c) Undersigned counsel's office is in Carlisle; (d) Father is self-employed in Carlisle and it would be convenient for Father to attend hearings in Carlisle; (e) Father's counsel is from Carlisle; (f) The children attend school in Carlisle and in Newville and their teachers are located in Carlisle and Newville; and, (g) The children are involved in counseling and the counselors are located in Carlisle. 10. Plaintiffs counsel did file a praecipe to list the case for trial on or about April 20, 2007; however, the praecipe fails to show cause why the matter should not be transferred to Cumberland County. WHEREFORE, undersigned counsel respectfully requests that this Honorable Court make the March 20, 2007, Rule absolute and transfer this matter to Cumberland County, Pennsylvania for the convenience of the parties and witnesses. Respectfully submitted, O'BRIEN, BARK & SCHERER Michael A. Scherer, Esquire I.D. No. 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 mas\DomesticlRunklmakeruleabsol ute.pet ~, ~: e,. • • LARRY RUNK, II, Plaintiff V. REBECCA RUNK, ;, Defendant IN THE COURT OF COMMON PLEAS OF PERRY COUNTY, PENNSYLVANIA NO. FC 2007-42 IN CUSTODY VERIFICATION I verify that the statements made in the foregoing Petition to Make Rule Absolute are true and correct to the best of my knowledge, information and belief. This verification is signed by Michael A. Scherer, Esquire, Attorney for Defendant and is based upon the statements provided by Defendant, as well as documents reviewed by the undersigned as attorney for Defendant. I understand that false statements herein are made subject to penalties of 18 Pa.C.S. §4904, relating to unsworn falsifications to authorities. Michael A. Scherer, Esquire Dated: April 26, 2007 ' ; ; !; „~~ M !~ LARRY RUNK, II, Plaintiff ~' V. ~! REBECCA RUNK, :' Defendant IN THE COURT OF COMMON PLEAS OF PERRY COUNTY, PENNSYLVANIA NO. FC 2007-42 IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on April 26, 2007, I, Tina M. Ascani, of O'Brien, Baric & Scherer, did serve a copy of the Petition To Make Rule Absolute by first class U.S. mail, postage prepaid, to the party listed below, as follows: Jason P. Kutulakis, Esquire Abom &Kutulakis 36 South Hanover Street Carlisle, Pennsylvania 17013 ina M. Ascani, Secretary ` ~ ~ ..~ r a CERTIFICATE OF SERVICE AND NOW, this ~_ day of June, 2007, I, Jason P. Kutulakis, Esquire of ABOM & KUTULAKIS, LLP, hereby certify that I did serve or cause to be served a true and correct copy of the foregoing Petition for Special Relief by First Class U.S. Mail addressed to the following: Michael A. Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 Larry Runk, II 32 George Brown Road Millerstown, PA 17062 Jas . Kutulakis, Esquire 4 r~ *v F_ ~ _~ -,; _. ,, O -n ^^\ - f- r - s. ~R C £ ~_~ ' { ~; ' .~ /~`) ~f _, z) VJ ,_~ ~. i ~ ^` -, (~(. ra A `~ v, LARRY RUNK, II, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. REBECCA RUNK, Defendant 07-4431 CIVIL IN RE: PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 315` day of July, 2007, upon consideration of the Petition for Special Relief filed by the Plaintiff, IT IS HEREBY ORDERED AND DIRECTED that: 1. A rule is issued upon the Defendant to show cause why the Plaintiff is not entitled to the relief requested; 2. The Defendant will file an answer to this petition on or before August 13, 2007; 3. The Prothonotary will forward said answer to this Court; 5. A hearing on the matter will be held on Wednesday, August 15, 2007, at 2:00 p.m. in Courtroom No. 5 of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, son P. Kutulakis, Esquire Attorney for Plaintiff ichael A. Scherer, Esquire Attorney for Defendant bas ~~ M. L. Ebert, Jr., ~~ ~~J\ V 'J~~'dA`11,5^~~v~~ OS ~~ 6~d 1 ~ ~~lt' ~~OZ ~dio-~o~.o~d ~~. ~o ~~~ i~ LARRY RUNK, II, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 4431 CIVIL ACTION LAW IN CUSTODY V. REBECCA RUNK, Defendant ANSWER TO PETITION FOR SPECIAL RELIEF 1-3. Admitted. 4. Admitted. Father failed to serve Mother with notice of the custody action and Mother had no idea that a conciliation was scheduled. Thus, she was not in attendance for the conciliation. 5-10. Admitted. 11. Denied. Larry, III, moved with Mother in October, 2005 from the marital residence. 12. On December 25, 2005, Larry, III, returned to the marital residence to visit Father and Larry, III, stayed at the marital residence until October 13, 2006, at which time Father kicked Larry, III, out of his home. 13. Denied. Sarah only visited with Father a few times and Larry, III, visited with Father one time while he was not living with Father. 14. Denied. Mother moved from the marital home with both kids in October, 2005. 15. Denied. See New Matter. 16. Admitted. 17. Admitted. 18. Denied. Mother believes the children's issues began while in the marital residence. 19. Denied. See New Matter. 20. Denied. See New Matter. NEW MATTER 21. The oldest child, Sarah, has severe emotional issues, including anorexia and depression. 22. Sarah is enrolled in specialized education through Manito for emotional support. Sarah is presently being treated at the Hershey Eating Disorder Clinic for her eating disorder. Mother, Sarah and Larry, III, receive in-home counseling services on a regular basis. Perry County Children and Youth Services previously advised Mother that she should limit Father's contact with the children to supervised visits. See attached Children and Youth correspondence. 23. Father previously requested a supervised visit with Larry J. Runk, III, and Mother agreed to allow that to occur. 24. Father has not set up any additional supervised visits with the children despite Mother's agreement to said visits. 25. The children, in Mother's opinion, suffer from various emotional issues because of the prior lifestyle experienced by them in the marital residence. 26. Father had a recent visit with the children during which visit he made vulgar remarks to the children about Mother. 27. Larry, III, called Father on the telephone recently and when Father did not want to discuss Mother and what Mother was doing the call with Larry, III, ended. 28. Much of the delay regarding the filing in Perry County is attributable to Father; Father filed the action in Perry County despite the fact that all of the parties have substantial ties to Cumberland County. 29. When undersigned counsel requested the matter be transferred to Cumberland County, Father opposed the transfer. 30. Despite Father's opposition to the transfer, it took undersigned counsel a great deal of time to have the matter moved to Cumberland County. 31. Father did not pay Mother any child or spousal support until very recently. 32. Mother did not have the funds with which to pay the filing fee in Cumberland County and, as a result, Cumberland County would not schedule any matters until the fee was paid. 33. Father, at all times, is believed to have had the ability to pay the filing fee which would have enabled the action to move forward in Cumberland County. 34. This matter is not suitable for emergency relief because there is no emergency as Father has been offered supervised visits with the children from the outset of undersigned counsel's involvement in this case. 35. The issues in this matter are complicated and it is not believed that the issues can be resolved in an emergency hearing. 36. It is believed that a conciliation is necessary in order to fully discuss and negotiate this matter as believed that a custody conciliation will enable the parties to move forward in establishing contact between Father and children. 37. Mother requests that a guardian ad litem be appointed for the children in order for the children to have an advocate to express their points of view. WHEREFORE, Mother respectfully requests that the request for emergency relief be denied, that the matter be referred to a custody conciliation and that a guardian ad litem be appointed for the children. Respectfully submitted, O'BRIEN, BARK & SCHERER c Michael .Scherer, Esquire I.D. No. 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Defendant mas\Domestic\Ru n k\special relief.ans LARRY RUNK, 11, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007 - 4431 REBECCA RUNK, CIVIL ACTION LAW Defendant IN CUSTODY VERIFICATION I verify that the statements made in the foregoing Answer to Petition for Special Relief are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsifications to authorities. Rebecca Runk Dated: August ~ , 2007 LARRY RUNK, 11, Plaintiff V. REBECCA RUNK, Defendant IN THE COURT OF COMMON PLEAS OF PERRY COUNTY, PENNSYLVANIA NO. FC 2007-42 IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on August 10, 2007, I, Tina M. Ascani, of O'Brien, Baric & Scherer, did serve a copy of the Answer to Petition for Special Relief by first class U.S. mail, postage prepaid, to the party listed below, as follows: Jason P. Kutulakis, Esquire Abom &Kutulakis 36 South Hanover Street Carlisle, Pennsylvania 17013 Tina M. Ascani, Secretary ti .~ c,"~~ ~> <- `' n>>r ~ j 'C~ 1T »~Cj' l a. _~_ .,_ ... ~~ i tp ~J LARRY RUNK, II, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. REBECCA RUNK, Defendant 07-4431 CIVIL IN RE: PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 15th day of August, 2007, upon consideration of Plaintiff's Petition for Special Relief and the Defendant's Answer and New Matter thereto and after consultation with Counsel and Guardian Ad Litem, IT IS HEREBY ORDERED AND DIRECTED that 1. The Father will be granted visitation with the children at the home of the Paternal Grandmother, Lorretta Runk between the hours of 12:00 noon on August 18, 2007, until 4:00 p.m. on Sunday, August 19, 2007. The Father shall not stay overnight at the Paternal Grandmother's home. 2. Both Father and Mother are specifically directed to make no derogatory comments regarding the other party to the children or in their presence. 3. Both Parties shall attend the conciliation scheduled for 11:00 a.m. on August 21, 2007 before Custody Conciliator John Mangan, Esquire. By the Court, ~ason P. Kutulakis, Esquire Attorney for Plaintiff Michael A. Scherer, Esquire Attorney for Defendant Court Administrator - dAs '~IS~d`l ~l~queline M. Verney, Esquire Guardian Ad Litem ~-' ~ ~~ M. L. Ebert, Jr., f` S I,~~ I ~ ~ff5 { h '{i ~~ 8S ~~ ~~~d '~ i ~E~~ lOfll ~ti~b'lU~~,u~.~~~~ ~M.i ~C3 3~~~~--~~ll~ LARRY RUNK, II, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. REBECCA RUNK, Defendant 07-4431 CIVIL IN RE: PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 15th day of August, 2007, upon consideration of the Plaintiff's Petition for Special Relief, the Defendant's Answer thereto and the Defendant's Motion to Quash Subpoena, IT IS HEREBY ORDERED AND DIRECTED that: 1. At the request of both parties, Jacqueline M. Verney, Esquire is appointed Guardian Ad Litem for the Children. 2. The Motion to Quash Subpoena is DENIED and the Children shall appear for the hearing currently scheduled for 2:00 p.m, this date. However, the Children will not testify at the hearing but will confer with the Guardian Ad Litem. 3. The sole issue to be considered at the hearing on the Petition for Special Relief is the need for an emergency visitation schedule pending custody conciliation in this matter. 4. A custody conciliation hearing shall be scheduled before a Custody Conciliator as soon as possible. son P. Kutulakis, Esquire Attorney for Plaintiff ichael A. Scherer, Esquire Attorney for Defendant Court Administrator - lips B~IS ~9'1 Jacqueline M. Verney, Esquire Guardian Ad Litem V By the Court, M. L. Ebert, Jr., J. ~,~ ~1~~' ~' ;n~n',~ 3 ~ ~; .:~ L} ~ ~~i ~&~`~ ~ 1 Jtt ~QDL ~t~~-~-;"~' i~~ ;r-~1~11~ ~~i1.~_. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND REBECCA RUNK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA v. N0. 07-4431 CIVIL TERM LARRY RUNK, II, CIVIL ACTION -LAW Defendant IN CUSTODY AFFIDAVIT OF SERVICE TRAVIS MacRAE, being .duly sworn according to law deposes and says that I am a competent adult, and that on _ ~ y ~ J 5 ~ ~ 3 ~ Z Q~ ~, 2007, at ~ ~ ~3 ?M., I personally served Sarah Runk at _ `(~ < <~ Y ~ d ~- ~ Cumberland County, Pennsylvania with a true and correct copy of the Subpoena to Attend and Testify dated August 15, 2007, issued in the above-captioned matter. DATE T S MacRAE COMMONV~IEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this, the _~~~ day of ~ ~ , 2007, before me, the undersigned officer, personally appeared ~~~ ,known to me to be the person whose name is subscribed to the within instrument and that she executed same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. ...._.. _ JAl~!• 8- I~a14l1~ N TAR`S' PUBLIC ~-ata~ae Hoeor (~eLetaiar/ ~ t~aam~too ~. Jnb ~t, soio .....:,.....:. _ ~.~...a.,,,..~...,.~Y,...: ..~--- •~ ~~'4.§ r ~ ~` CERTIFICATE OF SERVICE AND NOW, I, Jason P. Kutulakis, Esquire, of ABOM & KUTULAKIS, LLP, hereby certify that I did serve or cause to be served a true and correct copy of the foregoing AFFIDAVIT OF SERVICE via first class mail addressed as follows: Mi~IZUel AScheter, Es~uine ~Brierg Ba-~ic & Sd~r 19 WestSotd~h Street C,colisl~ PA 17013 Date: ~ ~1 f ~ ~ Jaso P. Kutulakis c.} ~ o ~ ~ ~~ ~, ' ~~~ ~ - R ~> -ri~~ _. _~.~ t=- [~ ~~ i .~ ../ CERTIFICATE OF SERVICE AND NOW, I, Jason P. Kutulakis, Esquire, of ABOM & KUTULAKIS, LLP, hereby certify that I did serve or cause to be served a true and correct copy of the foregoing AFFIDAVIT OF SERVICE via first class mail addressed as follows: Mi.ctiaielA~icherer; Esgcarre O'Brier~ Bcn-ic & ~ 19 WestSauf3a Sd~+et Cw~isl~ PA 17013 Date: l 5 ~ ~ Jaso P. Kutulakis c' C~ 7 Y. Cw~ ~ ~ y-C`. ' .. CI C.J`~ l{ C„ '~ ' ~ ~ ? 'S ::-, t ~ G3'` } COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND REBECCA RUNK, Plaintiff v. LARRY RUNK, II, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA N0.07-4431 CIVIL TERM CIVIL ACTION -LAW IN CUSTODY AFFIDAVIT OF SERVICE TRAVIS MacRAE, being duly sworn according to law deposes and says that I am a competent adult, and that on ~ ~~ - ~ 3 ~ od ~" 2007, at ~ ~ Z ~.M., I personally served Larry Runk, III at ~~ C fa y ~a~,d Cumberland County, Pennsylvania with a true and correct copy of the Subpoena to Attend and Testify dated August 15, 2007, issued in the above-captioned matter. DATE T VIS MacRAE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this, the =~ day of ~u , 2007, before me, the undersigned officer, personally appeared ~%a,/ ~,S ~ ~~`~.~.-- ,known to me to be the person whose name is subscribed to the within instrument and that he executed same for the purpose therein contained. IN WITNESS ~ ~.~-!1~ ~~Qemedrtea ~ ~- ~ I have hereunto set my hand and official seal. 'ARY PUBLIC ....., ~;~~ ,~Atfi1~'~~vt L~ra-s~dma0 ~ eteii~n.~'i~ ~~i:1 LARRY RUNK, II IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 07-4431 CIVIL ACTION LAW REBECCA RUNK IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, August 15, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, August 21, 2007 at 11:00 AM for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ohn .Man an r. 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 ,~ f `t~ _ ~ ~ G~ ~ p ., SI ~ P~ ~, y~ a jam' ~ ~ ~ ~~ ~~ ;~ ~ ~ ~ °y~ y~'~ 3 ~~ ~l~w ~ r~ {l„«. ~~ a ~_„-~ LARRY RUNK, II, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-4431 CIVIL REBECCA RUNK, DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 29~' day of August, 2007, upon consideration of the attached Custody Conciliation Report, IT IS ORDERED AND DIRECTED that: 1. This Order is entered pursuant to a Custody Conciliation Conference. A Custody Hearing is hereby scheduled for Monday, November 26, 2007 at 9:00 a.m. in Courtroom No. 5 of the Cumberland County Courthouse, Carlisle, Pennsylvania. For purposes of the hearing, the Father shall be deemed the moving party and shall proceed initially with testimony. Counsel for the parties and children shall file a memorandum with the Court and opposing counsel setting forth each party's position on custody, a list of the witnesses who are expected to testify and a summary of the anticipated testimony of each witness. These memoranda shall be filed at least 10 days prior to the hearing. 2. The Mother, Rebecca Runk and the Father, Larry Runk, II, shall enjoy shared legal custody of Sarah E. Runk, born February 20, 1993 and Larry James Runk, III, Born July 4, 1994. The parties agree that major non-emergency decisions concerning the children's health, welfare, education and religion shall be made by them jointly, after discussion and consultation with the other, with a view toward obtaining and following a harmoniously policy in the children's best interest. 3. The Mother shall have primary physical custody of the Children. 4. The Father shall have partial physical custody of the Children as follows: There shall not be unsupervised contact between Sarah Runk and Father at this time pending a recommendation from the family counselor for such unsupervised contact to commence. Partial custody between Father and Sarah Runk should be held at paternal grandmother's residence one weekend per month from Saturday 9:00 a.m. until Sunday 8:00 p.m. on the second weekend of the month. Paternal grandmother shall ensure that all interaction between Father and Sarah be appropriate. Father's visitation with Larry Runk, III, should be every other weekend at Father's residence from Friday 6:00 p.m. until Sunday 6:00 p.m. Furthermore, the Father shall have additional partial custody of his children as the parties may mutually agree upon. 5. The Father and Sarah shall facilitate becoming involved in therapeutic family counseling. Upon the recommendation of the counselor, Father is authorized to have unsupervised contact with Sarah Runk. The parties have agreed to select a neutral family counselor. The cost of this counseling, after any appropriate payment through insurance for the parties, shall be split equally between the parties. 6. Sarah Runk shall engage in individual counseling. 7. Transportation: The non-custodial parent shall pick up and transport the children unless the parties mutually agree to some alternative. 8. Telephone contact between Children and the non-custodial parent shall be liberal as agreed upon between the parties. Should the parents not agree on a telephone schedule, the custodial parent shall facilitate telephone contact between the non-custodial parent and the Children at 8:30 p.m. 9. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 10. Mother and Father shall not engage in any disparaging language with the Children that would negatively affect the Children's love and affection for the other parent. To the extent possible, Mother and Father shall not allow any disparaging conversation by third parties regarding the other parent. 11. In the event of a medical emergency, the custodial parent shall notify the other parent as soon as practicable after the emergency is handled. By the Court, 1~, M. L. Ebert, Jr., J. son Kutulakis, Esquire ~rlichael Scherer, Esquire ,ktcqueline Verney, Esquire (~ vJohn Mangan, Esquire ~ O ~i .~ Orb a 'mss-,~, ~.~~ r... ~ -~;~~~ ~~ s2 ~~d 6Z ~~~ t00Z ~t~aca~~~t~u~~~.~:~~; ~~. 3a L'~ .... ~6~`8~ LARRY RUNK, II; Plaintiff vs. REBECCA BUNK, Defendant Prior Judge: M. L. Ebert, J. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07-4431 Civil Term ACTION IN CUSTODY .COURT ORDER AND NOW, this day of August, 2007, upon consideration of the attached Custody Conciliation: Report,. it is ordered and directed that: 1. This Order is entered pursuant to a Custody Conciliation Conference. A Custody Hearing. is hereby .scheduled on day of , 2007 at amlpm in Courtroom number in the Cumberland County Court of Common Pleas, Carlisle, PA 17013. 2. The Mother, Rebecca Runk, and the Father, Larry Runk, II, shall enjoy shared legal custody of Sarah E: Runk, born February 20, 1993 and Larry James Runk, III; born July 4, 1994. The parties agree that major non-emergency decisions concerning the children's health, welfare, education and religion shall be made by them jointly,;after discussion and consultation with the other, with a view towazd obtaining and following a harmoniously policy in the children's best interest. 3. The Mother shall have primary physical custody of the Children. 4. The Father shall have partial physical custody of the Children as follows: There shall not be unsupervised contact between Sazah Runk and Father at this time pending. a recomnieadation from the family counselor for such unsupervised contact to commence. Partial custody between Father and Sarah Runk should be held at: paternal grandmother's residence one weekend per month from Saturday 9:00 am until Sunday 8:00 pm on the second weekend of the month. Paternal grandmother~shatl ensure that all interaction between Father and Sarah be appropriate. Father's visitation with Larry Runk III should be every other weekend at Father's xsidence from Friday 6:00 pm until Sunday 6:OOpm. Furthermore, the Father shall have additional partial custody of his children as the parties may mutually agree upon. 5. The Father and-Sarah shall facilitate becoming involved in therapeutic family counseling. Upon the recommendation of the counselor, Father is authorized to have unsupervised. contact with Sarah Runk. The parties have agreed to select a neutral family counselor. The cost of this counseling, after any appropriate .payment through insurance for the parties, shall be split equally between the parties. ... ... 6. Sarah Runk shall engage.: in individual counseling. 7. Transportation; The non-custodial parent shall pick up and transport the children unless the parties mutually agree to some alternative. 8. Telephone contact between Children and the non-custodial parent shall be liberal as agreed upon between the parties.. Should the parents not agree on a telephone schedule, the custodial parent shall facilitate telephone contact between the non- custodial parent and the Children at 8:30 pm. 9. Durng;any periods: o~ custody or visitation, the parties shall not possess or use controlled substances or consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 10. Mother and Father shall not engage in any disparaging language with the Children that would negatively affect the Children's love and affection for the other:parent. ` To the extent possible, Mother and Father shall not allow any disparaging. conversation by third parties regarding the other parent. 11. In the. event of a medical emergency, the custodial parent shall notify the other parent as soon as practicable after the emergency is handled. Distributian• Jason Kutulaks, Esq. Michael Scherer, Esq. Jacqueline Verney, )/sq. John J. Mangan, Esq. BY THE COURT, J. .... ,., - . LARRY RUNK, IT, Plaintiff vs. REBECCA RUNK, Defendant Prior Judge: M. L. Ebert, J. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07-4431 Civil Term ACTION IN CUSTODY CONCILIATION CQNFER,~NCE 3UNI11~ARY REP08T IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF FROCEDURE 1915`.3=8(B), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who aze the subject of this litgation`is as follows: Sarah E. Runk, bom February 20, 1993, currently in the shazed primary physical custody of Mother Larry James Runk, III, bom July 4, 1994, currently in the primary physical custody of Mother 2. A Conciliation Conference was held on August 21, 2007 with the following individuals iri attendance: The Mother,.Rebecca.Runk, with her counsel, Michael Scherer, Esq. The Father, Larry Runk, II with his counsel, Jason Kutulakis, Esq. The Guardian Ad Ltem, Jacqueline Verney, Esq. 3. Father's position on custody is as follows: The Father seeks primary physical custody of the children. Father asserts that he has seen his children approximately one time since October 2006 and that Mother has refused to permit contact`between.hlm and the children. Father alleges that Larry J. Runk ITI had lived with him in Perry County until October of 2006 when a disagreement arose between Father and son. At such time, Mother assumed primary custody of Larry Runk III. Sarah Runk has been primarily been with Mother since`2005. Father alleges that Mother has unaddressed mental health issues and alcohol issues. Father is willing to participate in family counseling with. Sarah and Larry. Father asserts that primary physical custody with hun would be in his children's best interest. 4. :Mother's position is as follows: The Mother seeks continuation of her having primary physical custody of both children. Mother denies mental health/substance abuse problems. Mother denies preventing contact between Father and children and alleges that she encourages the children to be in contact with Father.. Mother alleges that the children do not want to have extensive unsupervised contact with Father. Mother acknowledges that Sazah i `'s 'i w 4 1 '1, { 4 ~~,. ..,• . .has mental health issues and that she has had Sarah in some counseling. Mother is willing to continue with Sarah's counseling and have the children participate with family counseling with Father. Mother asserts that Father has been requested to participate in family counseling but has declined to do so. Mother alleges that Father has some anger management issues and conveys inappropriate. information to children in regazd to Mother. Mother asserts that primary physical custody with her would be in her children's best interest. 5. The Guardian Ad Litem's position is as follows: The Guazdian has had discussions with the children. Sarah has significant mental health issues and relationship issues with Father. The Guardian Ad Litem recommends that Sarah pursue `her individual counseling and family counseling with Father. Telephone contact should be as liberal as possible between the children and .Father. 'T'here should not be unsupervised visitation between Sarah and Father at this time.. Visitation between Father and Sarah Runk should be held at :paternal grandmother's-residence one weekend per month from Saturday 9:00 am until Sunday- 8:00 pm on the second weekend of the month. Paternal grandmother :shall ensure that all interaction between Father and Sarah be appropriate. Father's visitation with Larry Runk III should be every other weekend at Father's residence from Friday 6:00 pm until Sunday 6:OOpm. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and entering' an Order of Court granting Mother and Father shazed legal custody and Mother having primary physical custody with Father having partial physical custody as outlined in the proposed Order. It is expected that . the Hearing will require one day. 7. Thie proposed recommended Order may contain a requirement that the parties file a pre=trial memorandum with the Judge to whom the matter has been assigned. Date: August 22, 2007 Jo J. angan, Esquire C ody Conciliator i„ `a• LARRY RUNK, II : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :2007-4431 CIVIL ACTION -LAW REBECCA RUNK, . Defendant : IN CUSTODY ORDER OF COURT AND NOW, this ~ I~ day of S ~- ~ 1 ~w~`0 t,~' , 2007, upon consideration of the attached letter from Sarah's Psychiatrist and Psychologist, and the recommendation of the Guardian ad litem, the provision in the Order of Court dated August 29, 2007 requiring Sazah to have supervised visitation with her Father with paternal grandmother being the supervisor is hereby suspended pending further Order of Court. Father may have supervised visitation with Sarah provided a professional supervisor can be agreed to by the parties. BY THE COURT, M.L. Ebert, Jr., J. cc: Jason Kutulakis, Esquire, Counsel far Father Michael Scherer, Esquire, Counsel for Mother~~~u~.~ 4= o ~~ 6 ~ Jacqueline M. Verney, Esquire, GAL ~;~ b'Z ~qlY~ C.N~!~rs 6 ~' _~ L- d3 t~Qt t~-v a ~ 5~106> ~`G07/iHU 09:32 AM ~. ~~~~ M M . ^ ~~ aYY ~~ g R ~a .~ w ~$ : ~~. ~ ~ ~ ~ .~ , ~ ~ ~~. ~~. ~ w ~~ .~ . ~~~ ~ ~ ~_ ~~ a ~~~ ~ ~~~ ~~~ ~~a~ ~~~~. ~ ~ ~ ~~ ~ N• ~ ~~ ~ •~ ~~~ ~ ~ °d-~ ~~m~~ ~~~ ~~~ ~ ~ ~~~ -~d~~ ~ ~~ ~~. ~~;~ a ~~. ~.~ ~~ ~~~4 :~ ~. ~ ~~ ~~~ .~~ ~~ ~~~: ~~~ ~~ m ~~~ ~ ~~~~ ~~ ~~~ 1 #~ g O ~~ ~ ~ ~~ P. 002 `` ti'_ ', { r ti. 4. 1~~ ABOM CSZ' j~LTTLILAKIS Jason P. Kutulakis, Esquire Attorney LD. #: 80411 36 South Hanover Street Cazlisle, PA 17013 (717)249-0900 Larry Runk, II, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 2007-4431 CIVIL TERM Rebecca Runk, Defendant CIVIL ACTION -LAW CUSTODY MOTION FOR CONTINUANCE AND NOW, this 16TH day of November, 2007, comes the plaintiff, Larry J. Runk, II, by and through his attorney, Jason P. Kutulakis, Esquire, of ABOM ~ KUTULAKIS, LLP., who respectfully requests This Honorable Court to continue the Custody Hearing scheduled on November 26, 2007, in the above-captioned matter and in support thereof avers the following: 1. This Honorable Court issued an Order scheduling a Custody Hearing for November 26, 2007 at 9:00 a.m. 2. On November 16, 2007, Plaintiff, Larry J. Runk, II, notified undersigned counsel that he has retained new counsel, said counsel being Joseph D. Buckley, Esquire. 3. Undersigned counsel has contacted Michael Scherer, Esquire and Jacqueline Verney, Esquire. Attorney Scherer and Attorney Verney have indicated their concurrence with this request. WHEREFORE, Plaintiff, Larry J. Runk, II, respectfully requests This Honorable Court to continue the hearing currently scheduled for November 26, 2007. Respectfully submitted, M&KUTULAKIS, L.L.P. Date t ~ -- ((p ' ~ Jas n P. Kutt~Jakis, Esquire 36 .Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Defendant ID# 80411 CERTIFICATE OF SERVICE AND NOW, this 16`h day of November, 2007, I, Shannon L. Freeman, of ABOM FS KUTULAKIS, LI,P, hereby certify that I did serve a true and correct copy of the foregoing Motion for Continuance by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Michael Scherer l9 W. South Street Carlisle, PA 17013 .~acqueline Yerney 44 South Hanover Street Carlisle, PA 17013 Larry Runk 32 George Brown Road Millerstow n, PA 17062 Respectfully submitted, ABOM&KUTULA.XIS, L.L.P. Date // - /(Q - (5 ~ Shannon L. Freeman '~ -v © O :~ ~~ ~,- ' c~ GJ ' ~ ~ n~?i f " - r ~l ~ ` ~ ~ ~~ as ~ ..i _^`F {- ~ f.~,y?~t ...~+ ~v NOV Y 82DD7~D Larry Runk, II, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PA v• NO.2007-4431 CIVIL TERM Rebecca Runk, :CIVIL ACTION - LAVU Defendant :CUSTODY ORDER OF COURT S~ AND NOW, this z ~ day of November, 2007, upon consideration of the Plaintiff's Motion for Continuance, the Motion is hereby GRANTED. The custody hearing in this matter is rescheduled for ~Q-~.~, / 4 200 ~ at /~~ 3 ~ ,~ .M. in Courtroom # ~ . ~• Distribution: ~n P. Kutulakis, Esquire ~ph D. Buckley, Esquire Michael Scherer, Esquire ~cqueline Verney, Esqu ~1J~hK BY THE COURT, ~,.~ ~;ll:~$ . ~ `~. OM ~ LITLILAKIS Jason P. Kutulakis, Esquire Attorney I.D. #: 80411 36 South Hanover Street Carlisle, PA 17013 (717)249-0900 Runk II, IN THE COURT OF COMMON PLEAS Larry ~ :CUMBERLAND COUNTY, PA Plaintiff : NO. 2007-4431 CIVIL TERM v. Rebecca Runk, :CIVIL ACTION -LAW Defendant :CUSTODY MOTION FOR CONTINUANCE AND NOW, this 16TH day of November, 2007, comes the plaintiff, Larry J. Runk, II, throu h his attorney, Jason P. Kutulakis, Esquire, of ABOM ~ KU7'ULAKIS, LLP., who by and g ctfull re uests This Honorable Court to continue the Custody Hearing scheduled on respe y q er 26 2007, in the above-captioned matter and in support thereof avers the following: Novemb , 1. This Honorable Court issued an Order scheduling a Custody Hearing for November 26, 2007 at 9:00 a.m. . On November 16, 2007, Plaintiff, Larry J. Runk, II, notified undersigned counsel 2 that he has retained new counsel, said counsel being Joseph D. Buckley, Esquire. 3. Undersigned counsel has contacted Michael Scherer, Esquire and Jacqueline Verney, Esquire. Attorney Scherer and Attorney Verney have indicated their concurrence with this request. WHEREFORE, Plaintiff, Larry J. Runk, II, respectfully requests This Honorable Court to continue the hearing currently scheduled for November 26, 2007. Respectfully submitted, M&KIITULAKIS, L.L.P. Date I ~ - ~ (p - y Jas n P. Kut~J.akis, Esqu e 36 .Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Defendant ID# 80411 .. CERTIFICATE OF SERVICE AND NOW, this 16`h day of November, 2007, I, Shannon L. Freeman, of ABOM ~ KUTULAKIS, LLP, hereby certify that I did serve a true and correct copy of the foregoing Motion for Continuance by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Michael Scherer l9 W. South Street Carlisle, PA 17013 ,~acqueline Verney 44 South Hanover Street Carlisle, PA 17013 Larry Runk 32 George Brown Road Millerstow n, PA 17062 Respectfully submitted, ABOM&KvTULAxrS, L.L.P. Date / - - Shannon L. Freeman ~ ~ C' ~ ~ ~,., - ~, Ul _~, j ,-, `~ t. ~, . ~ - ~ -~ ~. 1 -. '~~ ~-~.} `;j ~ ~ "CL7 LARRY RUNK, II, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 2007-4431 CIVIL ACTION-LAW REBECCA RUNK, : IN CUSTODY PRIOR JUDGE: M.L. Ebert, Jr., J. MOTION TO CONTINUE CUSTODY HEARING AND NOW, comes Jacqueline M. Verney, Esquire, court-appointed Guardian ad litem for Sarah Runk and Larry Runk, III and presents this Motion to Continue Custody Hearing and in support thereof represents the following: 1. A Custody Hearing is scheduled before the Honorable M.L. Ebert, Jr. on March 14 2008 at 10:30 a.m. 2. The Guardian ad litem is scheduled to be on vacation from March 5-15, 2008. The vacation arrangements have been prepaid. 3. Counsel for Father, Joseph D. Buckley, Esquire and counsel foY~ Mother, Michael A, Scherer, Esquire do not oppose this Motion for Continuance. WHEREFORE, the Guardian ad litem requests this Honorable Court grant her Motion to Continue Hearing and reschedule it to a later date. Respectfully submitted, L_ ~ , acq line M. Verney, Esquire #2316 44 South Hanover Street Carlisle, PA 17013 (717)243-9190 Guardian ad litem CERTIFICATE OF SERVICE I, Jacqueline M. Verney, Esquire, hereby certify that a true and correct copy of the attached Motion to Continue Custody Hearing was served upon the following by placing the same in the United States mail, postage prepaid, on the date indicated: Joseph D. Buckely, Esquire 1237 Holly Pike Carlisle, PA 17013 Michael A. Scherer, Esquire 19 West South Street Carlisle, PA 17013 Date o~ '~(~ ~ ~ ~ ~ acq line M. Verney, Esquire #231 44 South Hanover Street Carlisle, PA 17013 (717)243-9190 Guardian ad litem for children C3 C. ~~ ~ ~~` _. ~„ . ~ ~~ ~' c. o f .• LARRY RUNK, II, Plaintiff v. REBECCA RUNK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4431 IN CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of Larry Runk, the Plaintiff in this matter: Joseph D. Buckley, Esquire Supreme Court I. D. # 38444 1237 Holly Pike Carlisle, PA 17013 (717) 249-2448 Thank you. Date: January 31, 2008 CERTIFICATE OF SERVICE I, Joseph D. Buckley, Esquire, do hereby verify that I have served a copy of the foregoing Praecipe For Entry Of Appearance upon the persons indicated below, which service satisfies the requirement of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States mail, first-class postage prepaid as follows: Jason P. Kutulakis, Esquire Abom & Kutulakis, LLP 36 S. Hanover Street Carlisle, PA 17013 Michael Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 Jacqueline M. Verney, Esquire 44 South Hanover Street Carlisle, PA 17013 Date: / 2~ ~ ° ~ c~ c~ t ~3] ^C .~::: ~ (N,~ ~~ ~;~ ~ ~~ ~ ~ ~.... ~.{ ~ ~ .` FEB 0 5 2008 LARRY RUNK, II, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V• : No. 2007-4431 CIVIL ACTION-LAW REBECCA RUNK, : IN CUSTODY PRIOR JUDGE: M.L. Ebert, Jr., J. ORDER OF COURT AND NOW, this ~~' day of ~Q-~~Cc,.- , 2008, upon consideration of the Guardian ad litem's Motion to Continue Custody Hearing, the Motion is GRANTED. The custody hearing in this matter is rescheduled for ~~~ . ~.-e- ~'3 , 2008 at ~-'~O A . m. in Courtroom No. 5. BY THE COURT, Joseph D. Buckley, Esquire Michael A. Scherer, Esquire Jacqueline M. Verney, Esquire ~t»i~~i `1'~~ J ~'~~i t~.J ~5 ' ~ ~1tA ~.. g~,~, $OOZ ~~~~~~~ 1~~~`~ .. ,- ~~ FEB 01 2008 (~ AUTHORITY TO PAY COURT APPOINTED COUNSEL 1. COURT ^ District Justice l~ommon Pleas ^ Appellate ^ Other ~~_ 2. VOUCHER N~ 12 811 3. FOR (D.J., C.P., APPELLATE) 4. AT (CITY/STATE) 5. BUDGET CODE c p ~ Ca2Lf sl£, ,~ 6. IN TH E CASE OF 7. CHARGE/ RDON CITATION) S. ^ PETTY OFFENSE /~ fC, u N fir! vs /Q u N~ G U S TG D O FELONY ^ MISDEMEANOR 9. PROCEEDINGS (Describe briefly) 11. PERSON REPRESENTEO 12. CIVIL DOCKET NO. / / A' /t~ a ~ ,L (/I yyr ~ TV/ r~.~. C~-u s J 1 ^ Oelendent • Adult 2 ^ Delendant -Jurenila ~ /,~ V 7 l ~ ~ ~ . / r~ !J ~ n/S ~~ l 3 ^ Appellant a ^ Appellee 13. CRIMINAL DOCKET NO. _ 5 ^ Habeas Petitioner ti ^ Material Witness 10. PERSON REPR ESENTED (Full Name) 7 O Parolee Charged With Violation e ^ Probationer Charged With Violation 14. APPEALS DOCKET NO. /~r L,~22 1` U N 9 ~ Other. t:. ~.r. /or/t"t~-, lir. t~uJ rGr~~ 16. NAME OF ATTORNEY/PAYEE ANO `~ Appt Date MAILINr annal=cc / /Y`• ~- . ~ g ~12-T ~j2 J , Jacqueline M. Verney, Esquire NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE 44 South Hanover Street Carlisle, Pa. 17013 17. TELEPHONE No. 18. SoC~Al.sl:cualrrn,o oAewlvo ~?t7 - aY3 - 940 (97-va -y'9d3 CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOUP.S GATES AMOUNTS CLAIMED a. Arraignment and/or Plea Multiply rate r hour times total ~ b. Preliminary Hearing hours to obt "In Court" com• sensation. E ~ total below. .. c Motions and Requests .. ~ "T'I _T ._-. d Bail Hearings `j f'~"1 ~ t C ~ O n. Sentence Hearings ^ ! : s~~ I r ~ Z f. Trial ~~ ~ ,~; ~ ` -- g. Revocation Hearings ~, ~-~ 7 _ ` 0~ ' h. Juvenile Hearings J ii " .~ ^~ i. Appeals Court T,~ OTALII~'Z:OURTfOf111p. N Other 1Specify on additional sheets) -~ ~ N TOTAL HOURS 9 X $55 PER HOUR - $ 20. a. Interviews and conferences r ~' ~ 3 g r ~ a~ Multiply rate per hour times total b. Obtaining and reviewing reeorda hours. Enter total "Out of Court" ~ Compensation below. O ~ c Legal research and brief writing H~ O O d. InvesCgative and other work (Spealy on additional sheets) 20A. TOTAL OUT OF COURT COMP. TOTAL HOURS ~ r S X $45 PER HOUR ~ $ oC ~ ~ U 21 ~ ITEMIZATION OF REIMBURSABLE EX PENSES AMT PER ITEM Mile a $.44 per mile x W ~- O 21A. TOTAL ITEMIZED EXP. - = s ~ 22. CERTIFICATION OF AT70RNEY/PAYEE 23. l3RAND TOTAL CLAIMED Has compensation and/or reimbursement for work In this sass proviously been applied for4 ^ YES Q NO = s as .fv If yes were you paid? ^ YES t~NO If ea b whom w re ld7 H hT , y , y e you ps ow muc Has the person represented paid any money to you, or to your knowledge anyone else, In connection with the matter for 24. DEDUCT. PRIOR PYMTS. which you were appointed to provide repr ~}tatfon9 ^ YES Cd'f'tb /t( yes, give details on additional sheets e~ : S ' ' I swear or affirm the truth or correctness ~ s Ja - - ~l • U~.t o? - / -b P 25: NET AMOUNt CLJIIMED of the above statements Signature of Attomay/Payee Date m s °?a ,rp ~ 2g.nr•onuvEO Furl PAYMENr Signature of JudQ@ - ~ ~ O 27. AMT. APPROVED ~ -Date: =: ~~ , S Copy 1 -Mail to Court Administrator at completion of service r ~ ., ~ `; LAW OFFICE OF JACQUELINE M. VERNEY 44 SOUTH HANOVER STREET Carlisle, PA 17013 Invoice submitted to: Cumberland County Court Administrat 1 Courthouse Square Carlisle PA 17013 In Reference To:Runk v. Runk: court appointed GAL fro custody matter Invoice #16810 Professional services Hrs/Rate Amount 1/23/08 Runk v. Runk: calls from/to mother 0.20 9.00 45.00/hr 1/29/08 Runk v. Runk: emails to/from 0.30 13.50 Buckley, Esq 45.00/hr __ __ -- For professional services rendered 0.50 $22.50 Previous balance $126.00 12/29/07 Payment - thank you ($126.00) ---- -- -- Balance due $22.50 ' Q C_ ° -*~ -~ , -•rs ~; ~ _~4 C!, CD ?'~. 4~ ~ ~:.. Y j ~ - ~ ~ ~ 3 C"CT r~w ~..F ate. R ~~""a ~~ LARRY RUNK, II, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-4431 CIVIL REBECCA RUNK, DEFENDANT IN CUSTODY IN RE: STATUS CONFERENCE ORDER OF COURT AND NOW, this 7th day of February, 2008, upon verbal request of Counsel for the Plaintiff and with the concurrence of Counsel for Defendant and the Guardian Ad Litem, IT IS HEREBY ORDERED AND DIRECTED that a status conference will be held in chambers of Courtroom No. 5 of the Cumberland County Courthouse, Carlisle, Pennsylvania on Friday, February 15, 2008, at 8:30 a.m. to discuss possible contempt issues. By the Court, ~~ M. L. Ebert, Jr., J. ~seph Buckley, Esquire Attorney for Father lichael Scherer, Esquire Attorney for Mother ~cqueline Verney, Esquire, GAL bas ~ ~, _:C~~ }' ~, r ~Q ;~ ,~ ~,- a3~ $00~ ~'w~~ ~-~. 34 LARRY RUNK, II IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :2007-4431 CIVIL ACTION REBECCA RUNK Defendant PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF CUSTODY AND VISITATION ORDER AND NOW, this ~~ day of February, 2008, comes. Petitioner, Plaintiff Larry Runk, II, by and through his attorney, Joseph D. Buckley, Esquire and Petitions this Court as follows: 1. That on August 29, 2007, the Honorable Judge M.L. Ebert, Jr, entered an Order awarding Plaintiff shared custody and visitation of the minor children James Runk, III and Sarah Runk. (A true and correct copy of the Order is attached to this petition and marked as Exhibit "A"). 2. By Order dated September 7, 2007, the Honorable Judge E.L. Ebert, Jr. entered a modification of said Order. (A true and correct copy of the Order is attached to this petition and marked Exhibit "B"}. 3. Plaintiff/Petitioner has scheduled or attempted to schedule counseling for himself and his children and Respondent has refused to permit the children to attend counseling. 4. Petitioner has requested and demanded custody and visitation of his children in compliance with the Court's Order, he has not had custody or visitation with his children for many months. t G ~ 5. Respondent, Defendant Rebecca Runk, has willfully failed to abide by the order in that: a. She has refused to permit telephone conversations between petitioner and his children as provided by the Order. b. She has refused to contact and seek approval from respondent relative to the well being of the children as provided by the Order. c. She has refused to allow the children to participate in counseling with petitioner as provided by the Order. d. She has refused to deliver the child James Runk, III to petitioner for visitation as provided by the Order. e. She has refused to permit petitioner from seeing his child Larry Runk, III as provided by the Order. f. She has refused to permit petitioner from seeing his children as provided by the Order. g. She has informed petitioner that irrespective of the Court's Order or direction given her by any attorney including her own she will refuse to comply with the Court's Order. WHEREFORE, Petitioner requests that the Respondent be held in contempt of Court. Petitioner further requests that this Court direct Respondent to immediately relinquish custody of the child Larry Runk, III for visitation with Petitioner, to permit liberal telephone contact between Petitioner and his children and to deliver the children to counseling with Petitioner. fully submitted, # 3 8444 Attorney for the Plaintiff 1237 Holly Pike Carlisle, PA 17013-4435 JoeBLaw@aol.com (717) 249-2448 r , VERIFICATION I, Larry Runk, II, Petitioner in the foregoing matter verify that I have read the foregoing Petition for Contempt and the statements made therein are true and correct to the best of my knowledge and belief. I understand that false statements made herein are subject to the penalties of Title 18, Section 4904 relating to unsworn statements to authorities. Date: February 7, 2008 LARRY K, II EXHIBIT «A» ~If ,~'' 1 1 :: ..r~~ .rM1 / ~~ .. +A.~` ~~ .' fdlf~rC ry ~ `~r;; LARRY RUNK, II, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANI V. NO. 07-4431 CIVIL REBECCA RUNK, DEFENDANT IN CUSTODY ORDER OF COURT ~wM ;,,,~,r ,.., ~„ >J ., . . h~ ~ ..: ~~ ". ~~ AND NOW, this 29th day of August, 2007, upon consideration of the attached Custody Conciliation Report, IT IS ORDERED AND DIRECTED that: 1. This Order is entered pursuant to a Custody Conciliation conference. A Custody Hearing is hereby scheduled for Monday, November 26007 at 9:00 a.m. in Courtroom No. 5 of the Cumberland County Courthouse, Carlisle, Pennsylvania. For purposes of the hearing, the Father shall be deemed the moving party and shall proceed initially with testimony. Counsel for the parties and children shalt file a memorandum with the Court and opposing counsel setting forth each party's position on custody, a list of the witnesses who are expected to testify and a summary of the anticipated testimony of each witness. These memoranda shat! be filed at least 10 days prior to the hearing. 2. The Mother, Rebecca Runk and the Father, Larry Runk, II, shall enjoy shared legal custody of Sarah E. Runk, born February 20, 1993 and Larry James Runk, Ill, Barn Juty 4, 1994. The parties agree that major non-emergency decisions concerning the children's health, welfare, education and religion shall be made by them jointly, after discussion and consultation with the other, with a view toward obtaining and following a harmoniously policy in the children's best interest. 3. The Mother shat! have primary physical custody of the Children. 4. The Father shall have partial physical custody of the Children as follows: There shall not be unsupervised contact between Sarah Runk and Father at this time pending a recommendation from the family counselor for such unsupervised contact #o commence. Partial custody between Father and Sarah Runk should be held at paternal grandmother's residence one weekend per month from Saturday 9:00 a.m. until Sunday 8:00 p.m. on the second weekend of the month. Paternal grandmother shall ensure that all interaction between Father and Sarah be appropriate. Father's visitation with Larry Runk, ill, should be every other weekend at Father's residence from Friday 6:00 p.m. until Sunday 6:00 p.m. Furthermore, the Father shat! have additional partial custody of his children as the parties may mutually agree upon. 5. The Father and Sarah shall facilitate becoming involved in therapeutic family counseling. Upon the recommendation of the counselor, Father is authorized to have unsupervised contact with Sarah Runk. The parties have agreed to select a neutral family counselor. The cost of this counseling, after any appropriate payment through insurance for the parties, shalt be split equally between the parties. 6. Sarah Runk shalt engage in individual counseling. 7. Transportation: The non-custodial parent shall pick up and transport the children unless the parties mutually agree to some alternative. 8. Telephone contact between Children and the non-custodial parent shall be liberal as agreed upon between the parties. Should the parents not agree on a telephone schedule, the custodial parent shall facilitate telephone contact between the non-custodial parent and the Children at 8:30 p.m. 9. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 10. Mother and Father shalt not engage in any disparaging language with the Children that would negatively affect the Children's love and affection for the other parent. To the extent possible, Mother and Father shall not allow any disparaging conversation by third parties regarding the other parent. 11. In the event of a medical emergency, the custodial parent shall notify the other parent as soon as practicable after the emergency is handfed. By the Court, M. L. Ebert, Jr., J. Jason Kutulakis, Esquire Michael Scherer, Esquire Jacqueline Verney, Esquire TRUE CrFY fR^~ R~t;~Rp John Mangan, Esquire hand M T stimcny whzr;;of, 1 hers unto set my ~ e ~ said urt . arlisle, Pa. of.. .. ~:..; Q~ ..~,.~ T .... ~ ~ , EXgIBIT «B~~ LARRY RUNK, II : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :2007-4431 CIVIL ACTION -LAW REBECCA RUNK, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 7~' day of ~a~~ , 2007, upon consideration of the attached letter from Sarah's Psychiatrist and Psychologist, and the recommendation of the Guardian ad litem, the provision in the Order of Court dated August 29, 2007 requiring Sarah to have supervised visitation with her Father with paternal grandmother being the supervisor is hereby suspended pending further Order of Court. Father tnay have supervised visitation with Sarah provided a professional supervisor can be agreed to by the parties. BY THE COURT, T M.L. Ebert, Jr., J. cc: Jason Kutulakis, Esquire, Counsel for Father Michael Scherer, Esquire, Counsel for Mother Jacqueline M. Verney, Esquire, GAL F~1~~. t ll~f'd lib[ ~ tai ~ ~ C~ple, ~a. ~+~ ~ ~~ r ~« CERTIFICATE OF SERVICE I, Joseph D. Buckley, Esquire, do hereby verify that I have served a copy of the foregoing Petition for Civil Contempt for Disobedience of Custody and Visitation Order upon the persons indicated below, which service satisfies the requirement of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States mail, first- class postage prepaid as follows: Michael Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17Q 13 Jacqueline M. Verney, Esquire 44 South Hanover Street Carlisle, PA 17013 Date: t'1LLV111G~' 1V1 L11G 1 1GL111L111 d 9~ p, cr''.~ ~` ~, -n ~ ~,~ t~ -,-t~' --- N ~ -' i'~ .. 5 ~ ~ ~ .~. -_ ~ FEB d 5 2008 ~, ..• LARRY RUNK, II, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V, : No. 2007-4431 CIVIL ACTION-LAW REBECCA RUNK, : IN CUSTODY PRIOR JUDGE: M.L. Ebert, Jr., J. ORDER OF COURT AND NOW, this ~~' day of ~~~~~~s-- , 2008, upon consideration of the Guardian ad litem's Motion to Continue Custody Hearing, the Motion is GRANTED. The custody hearing in this matter is rescheduled for .~;~~, , ~_¢„ /~ , 2008 at ~'~~ A . m. in Courtroom No. 5. / Joseph D. Buckley, Esquire ,Michael A. Scherer, Esquire Jacqueline M. Verney, Esquire ~1 ~~~08 ~if'~ BY THE COURT, ~~ ~~ v~~r- ~~' ~ ~ ~~ ~b~~~~~~ ~~~~~~ ~ ~ LARRY RUNK, II, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 2007-4431 CIVIL ACTION-LAW REBECCA RUNK, : IN CUSTODY PRIOR JUDGE: M.L. Ebert, Jr., J. MOTION TO CONTINUE CUSTODY HEARING AND NOW, comes Jacqueline M. Verney, Esquire, court-appointed Guazdian ad litem for Sarah Runk and Larry Runk, III and presents this Motion to Continue Custody Hearing and in support thereof represents the following: 1. A Custody Hearing is scheduled before the Honorable M.L. Ebert, Jr. on March 14 2008 at 10:30 a.m. 2. The Guardian ad litem is scheduled to be on vacation from Mazch 5-15, 2008. The vacation arrangements have been prepaid. 3. Counsel for Father, Joseph D. Buckley, Esquire and counsel for Mother, Michael A, Scherer, Esquire do not oppose this Motion for Continuance. WHEREFORE, the Guardian ad litem requests this Honorable Court grant her Motion to Continue Hearing and reschedule it to a later date. Respectfully submitted, L_ acq line M. Verney, Esquire #2316 44 South Hanover Street Carlisle, PA 17013 (717)243-9190 Guardian ad litem „ .. CERTIFICATE OF SERVICE I, Jacqueline M. Verney, Esquire, hereby certify that a true and correct copy of the attached Motion to Continue Custody Hearing was served upon the following by placing the same in the United States mail, postage prepaid, on the date indicated: Joseph D. Buckely, Esquire 1237 Holly Pike Carlisle, PA 17013 Michael A. Scherer, Esquire 19 West South Street Carlisle, PA 17013 Date ~ -`~ ~ ~ ~ _ V~- acq line M. Verney, Esquire # 44 South Hanover Street Carlisle, PA 17013 (717)243-9190 Guardian ad litem for children ~S r~: r_' ~ ~ ' - Cx7 t7Z ~? ~ -fv' : , ~ ~ .C-- -y,. ~ C ~ `~ 4 ~..~ a ' " ~~' ~ ~ ~, . G . ~ . :° .. to v LARRY RUNK, II, Plaintiff v. REBECCA RUNK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4431 IN CUSTODY VERIFICATION OF ACCEPTANCE OF SERVICE I, Michael Scherer, attorney for Rebecca Runk, hereby verify that I received a true and correct copy of the foregoing Petition for Civil Contempt for Disobedience of Custody and Visitation Order and that I accept service of said petition on behalf of my client. Date Michael Scherer, Esquire Attorney for Defendant O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 ~F3 r ~''~ '"rl Cx3 -~ C.J"i _ - ~."e - , t, , 3 ...i.. _ •-i ~ - tom.! ~~ ~ ~a~ 2f v ~ n1 ~ 1 ~~•' LARRY RUNK, II IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA v. REBECCA RUNK DF.,FFNDANT • 2007-4431 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NUW, Friday, February 15, 2008 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. ,the conciliator, at 4th Floor, Cumberland Coin Courthouse, Carlisle on Tuesday, March 25, 2008 at 2:00 PM for aPre-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/ John J. Mangan t. Esc~y, ~,~ ___ Custody Conciliator _ .I~iT~ 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 ~, ~ nom' ~ •~ ~o-~sr-~ `-~, ~ ~~~ z ~i~i ,wr~"51ft:``s ti. l ~VI ~V~ J ~ 4~~ VvY~ ~t~~>li~ln't~.J~.::vCi.~ '~~ ~~ LARRY RUNK, II, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-4431 CIVIL REBECCA RUNK, DEFENDANT IN CUSTODY IN RE: STATUS CONFERENCE ORDER OF COURT AND NOW, this 15th day of February, 2008, after status conference in the above captjoned case and the Court noting that a full custody hearing in this matter is now scheduled for June 13, 2008, IT IS HEREBY ORDERED AND DIRECTED that the children in this case, Sarah E. Runk, dob: 2/20/93 and Larry James Runk, III, dob: 7/04/94 shall participate in counseling with their father in the offices of Albert R. Hooke, Suite 38, Northwood Office Center, 2215 Forrest Hills Drive, Harrisburg, PA. The following schedule shall be adhered to: February 22, 2008 5:00 PM - Mr. Runk and his son, Jimmy February 27, 2008 5:00 PM - Mr. Runk and his daughter, Sarah March 5, 2008 5:00 PM - Mr. Runk and his son, Jimmy March 12, 2008 5:00 PM - Mr. Runk and his daughter, Sarah March 26, 2008 5:00 PM - Mr. Runk and those persons determined by the counselor. IT IS FURTHER ORDERED AND DIRECTED that if the son desires at any time to resume visitation with his Father, the schedule outlined in the Court's Order of August 29, 2007 shall be adhered to. IT IS FURTHER ORDERED AND DIRECTED that the Mother shall provide transportation of the children to the offices of Albert R. Hooke for each scheduled counseling session. By the Court, '~` M. L. Ebert, Jr., J. /Joseph Buckley, Esquire Attorney for Father /Michael Scherer, Esquire Attorney for Mother 1/J'acqueline Verney, Esquire, GAL bas a~is~o8 --1-~~ .iy 6 ~ ~ ~y;., t x, ij ~~~~ r - t ~'t, f~-, '~ f i tJ V 1 '~ ~(3 ~ ~ Ci3~ IiUU~ LARRY J. RUNK, II, Plaintiff v. REBECCA S. RUNK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 4431 CIVIL ACTION LAW IN CUSTODY DEFENDANT'S ANSWER TO PLAINTIFF'S PETITION FOR CONTEMPT AND DEFENDANT'S PETITION FOR CONTEMPT AND NOW, comes Rebecca S. Runk, by and through her attorney, Michael A. Scherer, Esquire, and respectfully responds to the Plaintiff's Petition for Contempt as follows: 1. Admitted. 2. Admitted. 3. Denied. Defendant is not aware that Plaintiff scheduled any counseling sessions for the children nor will she refuse to permit the children to go to counseling. 4. Denied. Plaintiff saw his son as recently as Christmas. Admitted to the extent that the parties' daughter has consistently refused to see her father. 5. Denied, in that: a. The children may speak with their father on the telephone any time they like. b. Father has never been concerned about legal custody issues in the past and as such mother takes responsibility for attending to the childrens' needs. c. The children do not want to participate in counseling with their father. d. Mother has not forced Jimmy to go with his father, but would like Jimmy to go with his father according to the Order of Court. e. Mother has not forced either child to go with their father, but would like both children to go with their father according to the Order of Court. f. That statement is not true. DEFENDANT'S PETITION FOR CONTEMPT AND NOW, comes Rebecca Runk, and avers that Larry Runk is in violation of this Honorable Court's Order dated August 29, 2007, in that: 6. Father repeatedly disparages Mother and the parties daughter, Sarah, in front of and to the parties son, "Jimmy" Runk. 7. Father verbally laments the failed relationship with Mother to Jimmy, making Jimmy uncomfortable and unwilling to see his father. 8. Father refers to Mother in a derogatory fashion to Jimmy which makes Jimmy feel badly and causes Jimmy not to want to spend time with his father. 9. Father asks Jimmy questions about his Mother, thereby putting Jimmy in the middle of the parties' situation and causing Jimmy to feel awkward and making him feel as though father is really only interested in Jimmy as a means to find out information about Mother. 10. Father previously kicked Jimmy out of his residence forcing Jimmy to go live with his Mother. 11. In the Fall of 2007, Jimmy was anxious to begin seeing his Father again after not seeing him for ten months. 12. After numerous visits with his Father, Jimmy decided he did not wish to see his Father any longer. 13. Mother has in no way interfered with Jimmy's ability to spend time with his Father or his ability to contact his Father; nor has she interfered with Father's ability to contact Jimmy. WHEREFORE, Mother respectfully requests that this Honorable Court find Father in contempt of the August 29, 2007 Order for Father's disparaging remarks against Mother. Respectfully submitted, O'BRIEN, BARK & SCHERER Date: Z ~ 2 T . y~ ~~/~ Michael A. Scherer, Esquire I.D. No. 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Defendant VERIFICATION I verify that the statements made in this Answer to Plaintiff's Petition For Contempt and Defendant's Petition For Contempt are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsification to authorities. Date: ~ - a (~ Rebecca S. Runk CERTIFICATE OF SERVICE I hereby certify that on February 22, 2008, I, Andrea M. Garrick, of O'Brien, Baric & Scherer, did serve a copy of Defendant's Answer to Plaintiff's Petition for Contempt and Defendant's Petition for Contempt, by first class U.S. mail, postage prepaid, to the parties listed below, as follows: Joseph Buckley, Esquire 1237 Holly Pike Carlisle, Pennsylvania 17013 Jacqueline M. Verney, Esquire 44 South Hanover Street Carlisle, Pennsylvania 17013 Andrea M. rick r' ,~ x3 ~ f 5~~' ~ ~ ~ . ~~ ~ i 1. .-~-t ' ~ ~ ., ) -^C} C ~ ~~ ,~~ yr l " ~ ~ 5~ UlA~R 89 20~,,,„, LARRY RUNK, II, 1N THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 07-4431 Civil Term REBECCA RUNK, Defendant :ACTION IN CUSTODY Prior Judge: M. L. Ebert, Jr., J. COURT ORDER AND NOW, this S~ 31 day of Mazch, 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: 1. The prior Order of Court dated February 15, 2008 shall remain in full force and effect with the modifications as follows. 2. The Children and Father shall continue to participate in counseling in the offices of Albert R. Hooke, Suite 38, Northwood Office Center, 2215 Forrest Hills Drive, Harrisburg, PA. Mother shall also participate upon the recommendation of the counselor. The third counseling session is scheduled for Mazch 26, 2008 and there shall be at least two more sessions subsequent. 3. The Mother, Rebecca Runk, and the Father, Larry Runk, II, shall enjoy shared legal custody of Sazah E. Runk, born February 20, 1993 and Larry James Runk, III, born July 4, 1994. The parties 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 regazding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each pazent 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 of the other pazent. To the extent one pazent has possession of any such records or information, that parent shall be required to shaze the same, or copies thereof, with the other pazent within such reasonable time as to make the records and information of reasonable use to the other parent. 4. The Mother shall have primary physical custody of the Children. 5. Should Larry James Runk, III request to resume visitation with Father, the schedule outlined in the Court Order dated August 29, 2007 shall be adhered to. 6. Telephone contact between Children and the non-custodial pazent shall be liberal as agreed upon between the parties. Should the parents not agree on a telephone schedule, the custodial parent shall facilitate telephone contact between the non- r ~• custodial pazent and the Children at 8:30 pm. 7. Mother and Father shall not engage in any disparaging language with the Children that would negatively affect the Children's love and affection for the other parent. To the extent possible, Mother and Father shall not allow any disparaging conversation by third parties regazding the other parent. The parties are directed to not discuss marital or custodial litigation issues with the Children. 8. Father's Petition for Contempt is hereby held in abeyance. 9. A status update conciliation conference is hereby scheduled for Apri128, 2008 at 9:00 am at the Cumberland County Court of Common Pleas, Cazlisle, PA 17013. BY THE COURT, ~;_9~ Distribution: /Joseph Buckley, Esq. /Michael Scherer, Esq. /Jacqueline Verney, Esq. /John J. Mangan, Esq. 1 '~l~oZ./ Ug `"~ p .{ 1 ~~ ~~ ~~'~ f - ~l~~~ ~~~Z (^ i r _~ LARRY RUNK, II, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 07-4431 Civil Term REBECCA RUNK, Defendant : ACTION IN CUSTODY Prior Judge: M. L. Ebert, Jr., J. 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 children who are the subject of this litigation is as follows: Sarah E. Runk, born February 20, 1993, currently in the primary physical custody of Mother Larry James Runk, III, born July 4, 1994, currently in the primary physical custody of Mother 2. A Conciliation Conference was held on August 21, 2007 and an Order of Court was issued August 29, 2007 and a modified Order was issued September 7, 2007. A status conference was held and an Order was issued on February 15, 2008. Father filed a Petition for Contempt and a Conciliation Conference was held on March 25, 2008 with the following individuals in attendance: The Mother, Rebecca Runk, with her counsel, Michael Scherer, Esq. The Father, Larry Runk, II, with his counsel, Joseph Buckley, Esq. The Guardian Ad Litem, Jacqueline Verney, Esq. 3. The parties agreed to the entry of an Order in the form as attached. Date: 3~~ >~~ ~ ~__ Jo J angan, Esq ' e ustody Conciliato P~; APR ~ 1 ~00~ -. ~ AUTHORITY TO PAY COURT APPOINTED COUNSEL t. COURT ~ ^ District Justice 8'Common Pleas ^ Appellate ^ Other 2. VOUCHER N~ 12 815 3. FOR (D.J., C.CAPPELLATE) ~~~~ 4. AT (CITY/STATE) 5. BUDGET CODE c 2l-~ s L~ _/ d_ 6. IN THE CASE OF 7. CHARGE/OFFENSE (PURDON CITATION) e. ^ PETTY OFFENSE u ~ ~ vs /~, (,t ~1J ~ C~ T~ ~ ^ FELONY ^ MISDEMEANOR 9. PROCEEDINGS (Describe briefly) 11. PERSON REPRESENTED 12. CIVIL DOCKET NO. GL~ n // PL£1k~ /ll /~£1/ ~l 1 ^ Defendant • Adult 2 ^ Defendant•Juvenile ~oU,,, ` r' `f 1 fos y G n ~„~~ N~ ~~G/ /~~rr~~ ~jaf~~ iY, I ! 3 ^ Appellant a ^ Appenee 13. CRIMINAL DOCKET NO. 5 ^ Mabeas Petitioner ti ^ Material Witness 10. PERSON REPRESENTED (Full Name) 7 ^ Parolee Charged With Violation g ^ Probationer Charged With Violation 14. APPEALS DOCKET NO. j,R-~A-t+ ~Gc~IL L,A-~/tZiN~f ~un/e(; 9 ^ Other ~ - I / ~ ,n, _ ~ ~ a f° -~ ( ~i•.(, S L ~ c 16. NAME OF ATTORNEY/PAYEE AND Appt Date MP ~ ~ -~ ~ - ' -"~"~ o A I~Y~D . L . ~ l3 £~2 ~ r ~~- ~ -T Jacqueline M. Verney, Esquire NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE 44 South Hanover Street Carlisle, Pa. 17013 17. TELEPHONE No. 18. soCIALSECURiTrr,o oal:iNNo ZI~I ~y$-Rrgv lGf'7-yz -~YoJ CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOUP.S DATES AMOUNTS CLAIMED a. Arraignment and/or Plee Multiply rats per hour times total b. Preliminary Hearing houro to obtain "In Court" com• penaation Enter total below c Motions and Requests . . d Bail Hearings ~ O e. Sentence Hearings V Z f. Trial g. Revocation Hearings h. Juvenile Hearings i. Avpeals Court 19A TOTAL IN COURT COMP. L Other (Specify on additional sheets) TOTAL HOURS $ ~ ~ = X $55 PER HOUR `~ ` 20. a. Interviews and conferences 3 a.~ o p Multiply rate per hour times total a b. Obtaining and reviewing records • .3 3 d ~ hours. Enter total "Out of Court" compensation below O ¢ c Legal research and txief writing . t- 7 ~ ~ d. Invesdgatlve and other work (Specify on additional sheets) 20A. TOTAL OUT OF COURT COMP. TOTAL HOURS = r ~ X $45 PER HOUR = $ `~ `~ ' O ~ 21. ITEMIZATION OF REIMBURSABLE EXP ENSES AMT. PER ITEM Milage $.44 per mile x w x ~' O 21A TOTAL ITEMIZED EXP. "~ = s 22. CERTIFICATION OF ATTORNEY/PAYEE 23. GRAND TOTAL CLAIMED Has compensation and/or reimbursement for work In this ease proviously been appllsd }or7 ^ YES f3''I~ D>J : = 3 ~ If yes, were you paid? ^ YES f7~N0 If yes by whom wsro ou eld? How m h? • , y g uc Has the person represented paid any money to you, or to your knowledge anyone else, In connection with the matter for 24. DEDUCT. PRIOR PYMTS. which you were appointed to provide repres tatlon? O ES l3'1~0 If s, give defaila on ad itional sheets ~ ~ = S ~~ 1 swear or affirm the truth or correctness ' ~ `0 ~ M V 25: NET AMOUNT CLAIMED of the above statements Signature of Attorney/Pe es Dats =s 34.pd 26 naawuvE u ruu Signature of II 27. AMT. APPROVED nAYME NT y Judg@ - -Dsts: 7 /' O~ s f 2/ -~ Copy 1 -Mail to Court Administrator at completion of service h LAW OFFICE OF JACQUELINE M. VERNEY 44 SOUTH HANOVER STREET Carlisle, PA 17013 Invoice submitted to: Cumberland County Court Administrat 1 Courthouse Square Carlisle PA 17013 In Reference To:Runk v. Runk: court appointed GAL fro custody matter Invoice #16931 Professional services Hrs/Rate Amount 3/25/08 Runk v. Runk: review contempt 0.80 36.00 complaint & file-.3; attend 45.00/hr conciliation conference-.5 For professional services rendered 0.80 $36.00 / Previous balance 3/31/08 Payment - thank you Balance due $181.50 ($181.50) $36.00 cF- ~~'_, ri ~ ~~~~" ~ ~;'` t d c ~"3 p Fey ~ + ~ ~ ' ~+ `• ~ ~ JUN 0.2008 AUTHORITY TO PAY COURT APPOINTED COUNSEL ~~ t~. COURT r ^ District Justice l9~Common Pleas O Appellate ^ Other 2. Vt UCOHER ~ ^ ~ ^ N L L 3. FOR (D.J., C.P., APPELLATE) ` cP 4. AT (CITY/STAY) < ~ c ~ 5. BUDGET CODE " ~2 <5 ~ ~- am- is/a~a -GCS,? 0 6. IN TH CASE OF /~ "~ ~ n1 K ~L 7. CHARGE/OFFENSE (PURDON CITATION) ` 8. ^ PETTY OFFENSE vs /~, t,L N ~ lc 5 z o ~ O FELONY ^ MISDEMEANOR 9. PROCEEDINGS (Describe brielly) M~.aT w~ G~t~tis~s 11. PERSON REPRESENTED 12. CIVIL DOCKET NO. /n~~ ((~~ i-t'~"t' ~~D ~v ~ G t ~ ~ ia-"~ ~tl1-i Cd i~1 '}, t O Defendant-Adult 2 ^ Oefendant • Juvenile 2 d G ~ - ~ 4 •~ ~~T1 , ` `L 1/!G w C ~' 2lL-~ 5 -hRoAn {-Fi:ILS(~Ly /~1~. ! 3 ^ Appellant 4 O AOpellee 13. CRIMINAL DOCKET NO. R <L / ! f_ W ~ ~, ~+-~T C ~ S To ~ O ~ ~/Z Y ~r 5 ^ Habeas Petitioner 6 ^ Material Witness 10. PERSON REPRESENTED (Full Name) 7 ^ Parolee Charged With Violation 9 ^ Probationer Charged With Violation 14. APPEALS DOCKET NO. s ~ other ~~ ~ / nI C- t~.5 T~ L~ Y 16. NAME OF ATTORNEY/PAYEE AND Apot Date ~•e+++~ir_ nnnoece pp. ~ Jacqueline M. Verney, Esquire ~- ' ,~ NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE 44 South Hanover Street Carlisle, Pa. 17013 17. TELEPHONE No. te. soclAESECUatrrr,o oftEwr,o ~tt--i-ay3- ~9o t9?_~rz-4q~3 CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOURS GATES AMOUNTS CLAIMED a. Arraignment and/or Plea Multiply rats per hour times total b. Preliminary Hearing hours to obtain "In Court" com• psnaation Enter total b l C. Motions and Requests . e ow. d Bail Hearings ~ O e. Sentence Hearings U 2 f. Trial g. Revocation Hearings h. Juvenile Hearings i. Appeals Court 19A TOTAL IN COURT COMP. 4 Other (Specify on additional sheets) TOTAL HOURS y X $55 PER HOUR $ ~ 20. a Interviews and conferences ~ f / ~- ~ Multipy rats pe- hour times total ~ b. Obtaining and reviewing records hours. Enter total "Out of Court" com ti l O ~ a Legal research and brief writing pensa on be ow. H~ Q ~ d. Investigative and other wak (Specify on adritonal sheets) 20A TOTAL OUT OF COURT COMP. TOTAL HOUR$ _ `, ~ X $45 PER HOUR a S 7. ~ • .5~ 21 • ITEMIZATION OF REIMBURSA8LE EXP ENSES AMT. PER ITEM Mils $.44 per mile x W ~ O 21A TOTAL ITEMIZED EXP. _: ~ 22. CERTIFICATION OF ATTORNEY/PAYEE 23. GRAND TOTALS~LAIMED Haa compensation and/or reimtwrse~°nt for work In this case proviously been applied fofT ^ YES t'~ O : s ~ (Q jU If yes, were you paid? ^ YES -Q NO If yes by whom wsro you peid7 How muchT , Has the person represented paid any money to you, or to your knowledge anyone else, In connection with the maKer for 24. DEDUCT. PNIOR PYMTS. which you were appointed to provide repr ntatfon? OYES O If a, give details on additional she~s ' s ~ 1 swear or affirm the truth or correctness l '~ V of the above Statements 8ignaturo of Attomay/Payee Data 25: NET AMOUNT CL/11MED ~ S ~I / ,$~J / `C 2g nFPgUVEU rur+ n~vn+ENr Sgnature of ~ Gate' ` Judge $ '~ A ~ 2T =MT. ~PR~ VF~,~ `'`(J • V 1 ` s J Copy 1 -Mail to Court Administrr~or at completion of service ° c o ~ ~ _ ~~' r ~ --" ~ ~ ~- ~ tx9 ., LAW OFFICE OF JACQUELINE M. VERNEY 44 SOUTH HANOVER STREET Carlisle, PA 17013 Invoice submitted to: Cumberland County Court Administrat 1 Courthouse Square Carlisle PA 17013 In Reference To:Runk v. Runk: court appointed GAL fro custody matter Invoice #17071 Professional services 5/5/08 Runk v. Runk: review letter from Hershey-.l; call to Mother-.1 5/6/08 Runk v. Runk: meet w/ clients 5/8/08 Runk v. Runk: conciliation conference 5/12/08 Runk v. Runk: review draft Custody Order-.l; call from Mangan, Esq-.l For professional services rendered Previous balance Balance due .,- /Rate Amount 0.20 / 9.00./ 45.00/hr 0.30 13.50 45.00/hr 1.00 45.00/ 45.00/hr 0.20 9.00 45.00/hr 1.70 _- -$76.50 $14 ~,,,,/ 7~ . Sa 'JUN 101008 LARRY RUNK, II, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 07-4431 Civil Term REBECCA RUNK, Defendant :ACTION IN CUSTODY Prior Judge: M. L. Ebert, Jr., J. COURT ORDER ~ti AND NOW, this « day of May 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: 1. All prior Orders of Court aze hereby VACATED, Father's Petition for Contempt is voluntarily withdrawn and DISMISSED and the previously scheduled custody hearing scheduled for June 13, 2008 is CANCELLED. 2. Legal Custody: The Mother, Rebecca Runk, and the Father, Lazry Runk, II, shall enjoy shared legal custody of Sazah E. Runk, born February 20, 1993 and Larry James Runk, III, born July 4, 1994. The parties 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 regazding 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 of the other pazent. To the extent one pazent has possession of any such records or information, that parent shall be required to shaze the same, or copies thereof, with the other pazent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. Physical Custody: The Mother shall have primary physical custody of the Children subject to Father's physical custody as follows: a. Father shall have physical custody of the Children pursuant to the Children's desire/request to resume physical custodial periods with Father. Father shall have periods of physical custody of Sazah upon the recommendation of Sazah's counselor/therapist that said periods would be in the Child's best interest. b. The custodial exchange location shall be by mutual agreement. In the absence of agreement, the exchange location shall be at the Cazlisle Police station on Lincoln Street. 4. Holidays: Father shall have physical custody of the Children during any and all holidays as mutually agreed upon and both pazents shall give due respect to the Children's desire/request to spend physical custodial time during the holidays with Father. 5. Telephone contact between Children and the non-custodial pazent shall be liberal as agreed upon between the parties. Should the pazents not agree on a telephone schedule, the custodial parent shall facilitate telephone contact between the non- custodial pazent and the Children at 8:30 pm. All reasonable efforts shall be made by the custodial parent to facilitate said telephone contact with the Children. 6. Mother and Father shall not engage in any disparaging language with the Children that would negatively affect the Children's love and affection for the other pazent. To the extent possible, Mother and Father shall not allow any disparaging conversation by third parties regarding the other pazent. The parties are directed to not discuss marital or custodial litigation issues with the Children. 7. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 8. In the event of a medical emergency, the custodial parent shall notify the other pazent as soon as practicable after the emergency is handled. 9. 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. BY THE COURT, J. distribution: /J~~seph Buckley, Esq. /Michael Scherer, Esq. Jacqueline Verney, Esq. /John J. Mangan, Esq. ~~i~~o8 ~~ *J{i~~'~rt~#I.~hl~'~~c? ,, ZZ ~£ ~d I 1 NI1~' 8001 A~`~. 3~i'~~-Ci ii ~ ~0 • ^ LARRY RUNK, II, Plaintiff vs. REBECCA RUNK, Defendant Prior Judge: M. L. Ebert, Jr., J. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07-4431 Civil Term ACTION IN CUSTODY CONCII,IATION 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 children who aze the subject of this litigation is as follows: Sarah E. Runk, born February 20, 1993, currently in the primary physical custody of Mother Larry James Runk, III, born July 4, 1994, currently in the primary physical custody of Mother 2. A Conciliation Conference was held on August 21, 2007 and an Order of Court was issued August 29, 2007 and a modified Order was issued September 7, 2007. A status conference was held and an Order was issued on February 15, 2008. Father filed a Petition for Contempt and a Conciliation Conference was held on Mazch 25, 2008 and an Order was issued Mazch 31, 2008. A status update conference was held on May 8, 2008 with the following individuals in attendance: The Mother, Rebecca Runk, with her counsel, Michael Scherer, Esq. The Father, Larry Runk, II, with his counsel, Joseph Buckley, Esq. The Guazdian Ad Litem, Jacqueline Verney, Esq. 3. The parties agreed to the entry of an Order in the form as attached. Date: ~ / ~ ~~~ ~~ John gan, Esq ' Cus ody onciliator LARRY RUNK, II, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYI,YANIA, C„' y °3 v. i7 ? CIVIL ACTION - LAW r? ca Ca - ^I 3 - 2007 - 4431 CIVIL TERA-1> NO ?Q REBECCA RUNK, . Defendant/Respondent IN CUSTODY D Cj ? PETITION FOR MODIFICATION OF CUSTODY AND NOW comes the Plaintiff/Petitioner, Larry Runk, II, by his attorneys, Irwin & McKnight, P.C., and presents the following Petition for Modification of Custody. The Petitioner, Larry Runk, II is an adult individual with an address of 32 George Brown Road, Millerstown, Perry County, Pennsylvania 17062. 2. The Respondent, Rebecca Runk, is an adult individual with an address of 42 Clay Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of two (2) children, namely, Sarah Elizabeth Runk, born February 20, 1993, and Larry James Runk, III, born July 4, 1994. 4. The parties are currently governed by custody Orders of Court dated August 29, 2007, and February 15, 2008, copies of which are attached hereto and marked as Exhibit "A". 5. The children were in the primary custody of the Mother who resides at 42 Clay Road, Carlisle, Pennsylvania 17013. -70Mw°`l? o ut, 9?5?.-MD 6. The parties' daughter, Sarah Elicabeth Runk, has lived primarily with Father since November 15, 2010. 7. During the children's lifetime, they have resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Larry Runk II and 32 George Brown Road Sarah: Birth to 10/21/05 Rebecca Runk Millerstown, PA Larry III: Birth to 10/21/05 Rebecca Runk 42 Clay Road Sarah: 10/21/05 to Present Carlisle, PA 17013 Larry III: 10/21/05-12/25/05 Larry Runk, II 32 George Brown Road Larry III: 12/25/05-10/13/06 Millerstown, PA Rebecca Runk 42 Clay Road Larry III: 10/13/06 to Present Carlisle, PA 17013 8. The Petitioner seeks custody of the following child: Sarah Elizabeth Runk. 9. Name Present Address Date of Birth Age The best interest and permanent welfare of Sara Elizabeth Runk will be served by granting the relief requested for reasons including the following: a. Stable environment. b. The Probation Office agrees that the best interest of Sarah at this time would be to reside with Father. 10. The best interests and permanent welfare of the minor child requires that the Court grant the Petitioner's request as set forth above. 4 WHEREFORE, Plaintiff/Petitioner, Larry Runk, II, respectfully requests that he be awarded primary physical custody and shared legal custody of Sara Elizabeth Runk, as provided herein, with periods of temporary physical custody to Defendant/Respondent as provided herein. Respectfully submitted, IRWIN & McKNIGHT, P.C. By: Marc s A. Mc ig II, Esquire Attom y for Plaiihff 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court I. D. No. 25476 Date: December 27, 2010 5 EXHIBIT "A" r i .X e `V .0 1 LARRY RUNK, II, IN THE COURT OF COMMON PLEAS OF '"w ?• P PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA °•? f." V. NO. 07-4431 CIVIL REBECCA RUNK, DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 29th day of August, 2007, upon consideration of the attached Custody Conciliation Report, IT IS ORDERED AND DIRECTED that: 1. This Order is entered pursuant to a Custody Conciliation Conference. A Custody Hearing is hereby scheduled for Monday, November 26007 at 9:00 a.m. in Courtroom No. 5 of the Cumberland County Courthouse, Carlisle, Pennsylvania. For purposes of the hearing, the Father shall be deemed the moving party and shall proceed initially with testimony. Counsel for the parties and children shall file a memorandum with the Court and opposing counsel setting forth each party's position on custody, a list of the witnesses who are expected to testify and a summary of the anticipated testimony of each witness. These memoranda shall be filed at least 10 days prior to the hearing. 2. The Mother, Rebecca Runk and the Father, Larry Runk, II, shall enjoy shared legal custody of Sarah E. Runk, born February 20, 1993 and Larry James Runk, III, Born July 4, 1994. The parties agree that major non-emergency decisions concerning the children's health, welfare, education and religion shall be made by them jointly, after discussion and consultation with the other, with a view toward obtaining and following a harmoniously policy in the children's best interest. 3. The Mother shall have primary physical custody of the Children. 4. The Father shall have partial physical custody of the Children as follows: There shall not be unsupervised contact between Sarah Runk and Father at this time pending a recommendation from the family counselor for such unsupervised contact to commence. Partial custody between Father and Sarah Runk should be held at paternal grandmother's residence one weekend per month from Saturday 9:00 a.m. until Sunday 8:00 p.m. on the second weekend of the month. Paternal grandmother shall ensure that all interaction between Father and Sarah be appropriate. Father's visitation with Larry Runk, III, should be every other weekend at Father's residence from Friday 6:00 p.m. until Sunday 6:00 p.m. Furthermore, the Father shall have additional partial custody of his children as the parties may mutually agree upon. 5. The Father and Sarah shall facilitate becoming involved in therapeutic family counseling. Upon the recommendation of the counselor, Father is authorized to have unsupervised contact with Sarah Runk. The parties have agreed to select a neutral family counselor. The cost of this counseling, after any appropriate payment through insurance for the parties, shall be split equally between the parties. 6. Sarah Runk shall engage in individual counseling. 7. Transportation; The non-custodial parent shall pick up and transport the children unless the parties mutually agree to some alternative. 8. Telephone contact between Children and the non-custodial parent shall be liberal as agreed upon between the parties. Should the parents not agree on a telephone schedule, the custodial parent shall facilitate telephone contact between the non-custodial parent and the Children at 8:30 p.m. 9. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 10. Mother and Father shall not engage in any disparaging language with the Children that would negatively affect the Children's love and affection for the other parent. To the extent possible, Mother and Father shall not allow any disparaging conversation by third parties regarding the other parent. 11. In the event of a medical emergency, the custodial parent shall notify the other parent as soon as practicable after the emergency is handled. By the Court, -? ?_a ``l M. L. Ebert, Jr., J. Jason Kutulakis, Esquire Michael Scherer, Esquire Jacqueline Verney, Esquire John Mangan, Esquire TRUE COPY FROM RECORD In Ti stimony whereof, i here urto set my hand an a se said urt arlisle, Pa. Q T ...f d of.. u..; .......I LARRY RUNK, II, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-4431 CIVIL REBECCA RUNK, DEFENDANT IN CUSTODY IN RE: STATUS CONFERENCE ORDER OF COURT AND NOW, this 15th day of February, 2008, after status conference in the above captioned case and the Court noting that a full custody hearing in this matter is now scheduled for June 13, 2008, IT IS HEREBY ORDERED AND DIRECTED that the children in this case, Sarah E. Runk, dob: 2/20/93 and Larry James Runk, III, dob: 7/04/94 shall participate in counseling with their father in the offices of Albert R. Hooke, Suite 38, Northwood Office Center, 2215 Forrest Hills Drive, Harrisburg, PA. The following schedule shall be adhered to: February 22, 2008 5:00 PM - Mr. Runk and his son, Jimmy February 27, 2008 5:00 PM - Mr. Runk and his daughter, Sarah March 5, 2008 5:00 PM - Mr. Runk and his son, Jimmy March 12, 2008 5:00 PM - Mr. Runk and his daughter, Sarah March 26, 2008 5:00 PM - Mr. Runk and those persons determined by the counselor. IT IS FURTHER ORDERED AND DIRECTED that if the son desires at any time to resume visitation with his Father, the schedule outlined in the Court's Order of August 29, 2007 shall be adhered to. IT IS FURTHER ORDERED AND DIRECTED that the Mother shall provide transportation of the children to the offices of Albert R. Hooke for each scheduled counseling session. By the Court, M. L. Ebert, Jr., J. Joseph Buckley, Esquire Attorney for Father Michael Scherer, Esquire Attorney for Mother Jacqueline Verney, Esquire, GAL bas a $. ? ry hand VERIFICATION The foregoing document is based upon information, which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to aut] Date: 1.2,` 17` 10 LARRY RUNK, II IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2007-4431 CIVIL ACTION LAW Ca M r-0 REBECCA RUNK M00 =-n IN CUSTODY xM-- DEFENDANT G3 7) > CrJ C) ORDER OF COURT AND NOW, _ Wednesday, December 29, 2010 upon consideration of the attached omplaint, ,' it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at____ _ 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, February 03, 2011 at 9:00 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/ ohn . Man-an, r. 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 ??0101? YQ / Carlisle, Pennsylvania 17013 r Telephone (717) 249-3166 VA ll?-P