HomeMy WebLinkAbout07-5405DAVID
. RUDY, IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTYnnPENNSYLVANIA
- L. JUMPER, :CIVIL ACTION -LAW
Defendant :CHILD CUSTODY
NOTICE
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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:
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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
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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
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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