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HomeMy WebLinkAbout07-5405DAVID . RUDY, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTYnnPENNSYLVANIA - L. JUMPER, :CIVIL ACTION -LAW Defendant :CHILD CUSTODY NOTICE claims set this Comp attorney a~ forth again you and a j any money Plaintiff. ' child costa YOU HAVE BEEN SUED IN COURT. If you wish to defend against the Forth in the following pages, you must take action within twenty (20) days after aint and Notice are served, by entering a written appearance personally or by d filing in writing with the Court your defenses or objections to the claims set st you. You aze warned that if you fail to do so the case may proceed without udgment may be entered against you by the Court without further notice for claimed in the Complaint or for any other claim or relief requested by the you may lose money or property, or other rights important to you, including dy, or child visitation. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH B LOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT MAY BE THAT M~ FEE OR r G A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE ,BLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES Y OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED ~ FEE. CUMBERLANDCOUNTY LAWYER REFERRAL SERVICE 2 Liberty Avenue Cazlisle, Pennsylvania (717) 249-3166 AVISO LISTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defende a de las demandas que se presentan mas adelante en las siguientes paginas, debe tomaz ac ibn dentro de los pr6xirnos veinte (20) dins despu~s de la notificaciGn de esta Demand y Aviso radicando personalmente o por medio de un abogado una compare encia escrita y radicando en la Corte por escrito sus defenses de, y objeccionnes a, las de andas presentadas aqui en contra suya. Se le advierte de que si usted fella de tomaz ac ibn como de describe anteriormente, el caso puede proceder sin usted y un fallo por cualq ier soma de dinero reclamada en la demanda o cualquier otra reclaznaci6n o remedio olicitado por el demandante puede ser dictado en contra suya por la Corte sin mas avis adicional. Usted puede perder dinero o propiedad u otros derechos importantes paza uste . LISTED DEBE LLE~IAR ESTE DOCUMENTO A SU ABOGADO INMED TAMENTE. SI LISTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIG ENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERC DE COMO CONSEGUIER UN ABOGADO. SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOG O, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFO CION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 2 Liberty Avenue Carlisle, Pennsylvania (717) 249-3166 DAVID M. RUDY, v. IN THE .COURT OF COMMON PLEAS Plaintiff CUMS'ERLAND COUNTY, PENNSYLVANIA L. JUMPER, CIVII, ACTION -LAW Defendant CHII.D CUSTODY COMPLAINT FOR CffiLD CUSTODY AND NOW comes the Plaintiff, David M. Rudy, by and through his ,Mark T. Silliker, Esquire, and respectfully requests this Honorable Court award him custody of the subject minor child, and in support thereto, avers the following: 1. Plaintiff is David M. Rudy, an adult individual residing at 630 Gates Lane, E$~ola, Cumberland County, Pennsylvania. 17025. 2. Defendant is ;Amanda L. Jumper, an adult individual residing at 2 White birch Lane, Mechanicsburg, Cumberland County, Pennsylvania. 17050. 3. The subject child is Ella Raelynn Rudy, born November 16, 2005, in County, Pennsylvania. 4. The relationship of the. Plaintiff to the subject minor child is that of natural father. 5. The relationship of the Defendant to the subject minor child is that of natural mother. 6. The minor child has resided at the following addresses, in the custody of the f llowing individuals: a. Birth -April., 2006, the subject minor child resided at 630 Gates Lane, Enola, Cumberland County, Pennsylvania, in the care and custody of the natural mother and the natural father. b. Apri12006 - On or about August 1, 2007 the subject minor child resided with Mother and Father at 630 Gates Lane, F~ola, Cumberland County, Pennsylvania. During this period the parties also occasionally resided together at 2 White Birch Lane, Mechanicsburg, Cumberland County, Pennsylvania. c. Since on or about August 1, 2007, theparties have divided custody on an equal basis, with the child residing with Father half the tone at 630 Gates Lane, Enola, Cumberland County, Pennsylvania, and residing with Mother half the time at 2 White Birch Lane, Mechanicsburg, Cumberland County, Pennsylvania. 7. There have been no prior actions for custody of the subject minor child in this o any other jurisdiction. 8. The Plaintiff is not aware of the existence of any other individuals who have any type of claim whatsoever regarding the custody of the subject minor child. 9. The Plaintiff believes and therefore avers that he is much better able to meet the needs of the subject minor child than the Defendant. 10. The Plaintiff'believes and therefore avers that it is in the best interest of the su~ject minor child that she be placed in his legal and physical custody. 11. Father feels he can provide a better home environment and upbringing than can ~1+iother. As a result, he would respectfully: request this Honorable Court grant him primary custody of the subject minor child, subject to reasonable, liberal, and indeed frequent ~ights of partial custody unto Mother. WHEREFORE, Plaintiff David M. Rudy respectfully requests this Court awazd him primary physical custody of the subject minor child. Respectfully submitted, THE LAW OFFICES OF SILLIKER & REINHOLI ~Oiazk T. Silliker, Esquire 5922 Linglestown Road Harrisburg, PA 17112 (717)671-1500 I.D. No. 33671 Attorney for David M. Rudy AFFIDAVIT I, ~i ~ /~~ ,hereby certify that the aforegoing is true and correc to the best of my knowledge, information and belief. I understand that false are made subject to the penalties of 18 Pa. C. S. 4909 relating to unswom falsifications to authorities. Dated: ~\ f ~ o e ~' ~ ~' ~ ~- ~.° +- ,-.~' r-? C7 ~' gs cl> -c~~,, ~~ i ~~ [~~"J 1 ~~ G ~, DAVID M. RUDY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. AMANDA L. JUMPER DEFENDANT 07-5405 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, September 14, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, October 19, 2007 at 8:30 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 ale 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: /sJ Hubert X. Gilto 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 ~~~ '~~" ~ ~~~r~~~' ~'~" ~'~ ~~~~~ GP~~~~~ ~Qi '6 ~ofhl•6 ~ 2 ~ 1007 DAVID M. RUDY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION -LAW AMANDA L. JUMPER, N0.2007-5405 Defendant IN CUSTODY COURT ORDER AND NOW, this Z t' day of October, 2007, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The mother, Amanda L. Jumper, and the father, David M. Rudy, shall enjoy shared legal and shared physical custody of Ella Raelynn Rudy, born November 16, 2005. 2. Physical custody shall be shared equally between the parties pursuant to a schedule as agreed upon by the parties. 3. The parties shall also share all holidays and other events equally with respect to physical custody pursuant to a schedule agreed upon by the parties. 4. In the event either party desires to modify this Order and the parties cannot agree upon a modification, either party may petition the court to have the case again scheduled with the Custody Conciliator for a conference. cc: ~rk T. Silliker, Esquire ~ss Amanda L. Jumper DV TiiL~ !'~A7T7lT { ' ~ ~ ~ 5Z ~ Q ~tt~7L ~. HEIDI J. HINTON, Plaintiff v STEVEN SCOTT HINTON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.1995-4036 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Ella Raelynn Judy, born November 16, 2005. 2. A Conciliation Conference was held on October 19, 2007, with the following individuals in attendance: The father, David M. Rudy, with his counsel, Mark T. Silliker, Esquire, and the mother, Amanda L. Jumper, who appeared without counsel. 3. The parties agree to the entry of an Order in the form as attached. Date: °"~ X. Gilroy, Esquire Custody Conciliator