HomeMy WebLinkAbout07-6909ANGELA M. GROUP, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
2007 - 6 90 CIVIL TERM
CHARLES B. REINARD,
Defendant IN CUSTODY
COMPLAINT FOR CUSTODY
AND NOW comes the Plaintiff, Angela M. Group, by her attorneys, Irwin & McKnight,
and presents the following Complaint for Custody.
1.
The Plaintiff, Angela M. Group, is an adult individual with an address of 85 Regency
Woods North, Carlisle, Cumberland County, Pennsylvania 17013.
2.
The Defendant, Charles B. Reinard, is an adult individual with an address of 85 Regency
Woods North, Carlisle, Cumberland County, Pennsylvania 17013.
3.
The parties are the natural parents of two (2) children, namely, Cole T. Reinard, born
October 6, 2001, and Brian E. Reinard, born September 10, 2004.
4.
The Plaintiff, Angela M. Group, desires that the parties have shared legal custody of the
minor children, Cole T. Reinard, and Brian E. Reinard.
5.
The Plaintiff, Angela M. Group, desires primary physical custody of the said minor
children with periods of temporary physical custody to Defendant, Charles B. Reinard, as the
parties can agree.
6.
The best interests and permanent welfare of said minor child requires that the Court grant
the Plaintiff's request as set forth above.
WHEREFORE, the Plaintiff, Angela M. Group, respectfully requests that she be
awarded primary physical custody and shared legal custody of minor children, Cole T. Reinard,
and Brian E. Reinard as provided herein, with periods of temporary physical custody to
Defendant, Charles B. Reinard, as provided herein.
By:
Respectfully submitted,
IRWIN & McKNIGHT
McKnight, III, Esquire
60 West Porn et Street
rli sylvania 17013-3222
(717) 249-2353
Supreme Court I. D. No. 25476
Date: November 14, 2007
VERIFICATION
The foregoing Complaint for Custody is based upon information which has been gathered
by 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 authorities.
0-A'dfiq-"
'ANGELA M. GROUP
Date: November 14, 2007
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ANGELA M. GROUP IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
CHARLES B REINARD
2007-6909 CIVIL ACTION LAW
DEFENDANT IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, November 20, 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 Wednesday, December 12, 2007 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. 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
10
FEB 0 7 2008 ??
ANGELA M. GROUP, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 07 - CIVIL ACTION LAW
CHARLES B. REINARD, IN CUSTODY
Defendant
ORDER OF COURT
AND NOW this day of February, 2008, upon consideration of the attached Custody
Conciliation Report, it is Ordered and Directed as follows:
Legal Custody: The Father, Charles Reinard, and the Mother, Angela Group, shall have shared
legal custody of Cole T. Reinard, born 10/6/2001 and Brian E. Reinard, born 9/10/2004. The
parties shall have an equal right to make all major non-emergency decisions affecting the
Children's general well-being including, but not limited to, all decisions regarding their health,
education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled
to all records and information pertaining to the Children including, but not limited to, medical,
dental, religious or school records, the residence address of the Children and of the other
parent. To the extent one parent has possession of any such records or information, that parent
shall be required to share the same, or copies thereof, with the other parent within such
reasonable time as to make the records and information of reasonable use to the other parent.
2. Physical Custody: The Mother shall have primary physical custody subject to Father's partial
physical custody as follows:
a. Commencing 2/8/08, Father shall have physical custody of the Children on alternating
weekends from Friday 4:00 pm until Monday morning.
b. Father shall have every Wednesday from after the Child/ren's school lets out until Thursday
morning.
c. Commencing in March 2008, Father shall have every Monday and Wednesday for
overnight custody periods while Mother is attending school.
d. Father shall continue to be Brian's day time care-giver while Mother is working.
e. Father shall have additional periods of physical custody as the parties may agree.
3. The parties shall share transportation for the exchanges.
4. Holidays: Major holidays with the Children shall be alternated between the parents pursuant
to the attached holiday schedule or as mutually agreed upon.
5. Neither party may say or do anything nor permit a third party to do or say anything that may
estrange the Children from the other party, or injure the opinion of the Children as to the other
party, or may hamper the free and natural development of the Children's love or affection for
the other party. To the extent possible, both parties shall not allow third parties disparage the
other parent in the presence of the Children.
6. In the event of a medical emergency, the custodial party shall notify the other party as soon as
practicable after the emergency is handled.
7. Telephone Contact: Telephone contact between the Children and the non-custodial parent
shall be reasonable and liberal as agreed upon between the parties.
8. Each parent shall have two non-consecutive weeks (i.e. no more than seven days in a row) of
vacation per year with the Children. The requesting parent shall give the other parent 30 days
advance notice of the requested time and this vacation week shall supersede the regular
physical custody schedule. In the event the parties schedule conflicting vacations, the party
first providing written notice shall have the choice of vacation. Prior to departure, the parties
will provide each other with information regarding the intended vacation destination and a
telephone number at which they can be reached during their vacation. The parties may expand
this vacation time by mutual agreement.
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:
?Charles Reinard, 85 Regency Woods North, Carlisle, PA 17015
?Marcus McKnight, III, Esquire
hn J. Mangan, Esquire
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ANGELA M. GROUP, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
• EpQ?
V. No. 07 -.6969 CIVIL ACTION LAW
CHARLES B. REINARD, IN CUSTODY
Defendant
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
The pertinent information pertaining to the Children who are the subject of this
litigation is as follows:
Name Date of Birth Currently in the Custody of
Cole T. Reinard 10/6/2001 Mother and Father
Brian E. Reinard 9/10/2004 Mother and Father
2. A Conciliation Conference was held with regard to this matter on February 7, 2008
with the following individuals in attendance:
The Father, Charles Reinard, pro se
The Mother, Angela Group, with her counsel, Marcus McKnight, III, Esquire.
3. The parties agreed to the entry of an Order in the form as attached.
Date:
John M an, Esquire
Cus donciliator
HOLIDAYS AND
SPECIAL DAYS TIMES EVEN
YEARS ODD
YEARS
Easter Day 13 Half From 8 am the Saturday before
Easter until 8 am Easter Sunda Father Mother
Easter Da 2° Half From 8 am Easter Sunda until 8 m Mother Father
Memorial Da From 9 am until 9 m Mother Father
Independence Da From 9 am until 9 m Father Mother
Labor Da From 9 am until 9 m Mother Father
Halloween From one hour before trick or
treating to one hour after trick or
treating Father Mother
Thanksgiving 1 S
Half From 8 am Thanksgiving Day to 2
m on Thanksgiving Da Father Mother
Thanksgiving 2n
half From 2 pm on Thanksgiving Day to
noon the day after Thanksgiving Da Mother Father
Christmas 1 S Half From 8 am 12/24 until 8 m 12/24 Father Mother
Christmas 2n Half From 8 am on 12/25 until 8 m 12/25 Mother Father
New Year's From 6 pm 12/31 until noon January
1St (with the 12/31 year to control the
even/odd determination) Mother Father
Mother's Da From 9 am until 9 m Mother Mother
Father's Da From 9 am until 9 m Father Father
ANGELA M. GROUP, II IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
W7- 490q
V.
2-99 -C?% CIVIL ACTION LAW
CHARLES B. REINARD
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Wednesday, April 01, 2009 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, May 05, 2009 at 10:00 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
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
OF TTft AFIY
2009 APR -? Lip: e
V?UU?iiY
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ANGELA M. GROUP, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
2007 - 6909 CIVIL TERM
CHARLES B. REINARD,
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this l?h day of 2009, it is hereby Ordered that the
Custody Hearing in the above-captioned matter scheduled for Wednesday, July 22, 2009 at 2:00
p.m. has been continued. Counsel for the Defendant has agreed to the Continuance and the
Plaintiff's counsel will proceed with rescheduling of said Custody Hearing.
By.
M. L. Ebert, Jr. Ju e
cc: 4a'ne Adams, Esq.
Counsel for Defendant
Marcus A. McKnight, III, Esq.
Counsel for Plaintiff
1
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ANGELA M. GROUP, II,
Plaintiff
vs.
CHARLES B. REINARD,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
`404
No. 07 - 6969 Civil Term
IN CUSTODY
MOTION TO MAINTAIN CURRENT SCHOOL DISTRICT
AND NOW, comes Petitioner, Charles B. Reinard, by and through his counsel,
Jane Adams, Esquire, and petitions the Court as follows:
1. Charles B. Reinard, Defendant/Petitioner, (hereinafter referred to as
"Father"), is the Defendant in the above-captioned matter, and is an adult individual
currently residing at 85 Regency Woods N., Carlisle, Cumberland County,
Pennsylvania, 17013.
2. Angela M. Group, Plaintiff/Respondent, (hereinafter referred to as "Mother") is
the Plaintiff in the above-captioned matter, and recently moved to Hanover from her
prior address at 114 Amy Drive, Carlisle, Cumberlaind County, Pennsylvania, 17013.
Mother has not provided Father with a current address.
3. The parties are the natural parents of two children, namely:
Cole Tyler Reinard, born October 6, 2001; and
Brian Edward Reinard, born September 10, 2004.
4. The parties are subject to an Order of Court dated May 13, 2009 whereby the
parties share legal and physical custody.
5. A hearing is currently set for September 2, 2009, due to Mother's recent move
and desire to enroll the children in a different school district, in Adams or York County.
6. This hearing was originally set for July 22, 2009. Mother's counsel requested
a continuance due to a scheduling conflict.
s
7. Father's counsel, out of courtesy, agreed to the continuance, but requested
that this matter be scheduled before the start of school in August 2009, as the school
district is currently an issue that the parties cannot agree upon.
8. The children attended Cumberland Valley School District during the 2008-
2009 school year. School is scheduled to start on August 26, 2009 for the 2009 -
2010 school year.
9. The older child, Cole, age seven, was in first grade and did well at
Cumberland Valley School District. The younger chile, Brian, age four, is scheduled to
attend full-day kindergarten in Cumberland Valley.
10. The older child Cole, recently participated in the following services in
Cumberland Valley School District: reading clinic services, twelve 75-minute summer
classes, speech and language clinician services (to monitor fine motor skills).
11. It is believed that Mother has registered the children in a school district close
to Hanover, in York or Adams County without notifying Father or asking for his consent.
Father shares legal custody and does not agree that the children should attend a
different school district.
12. The hearing is currently scheduled for September 2, 2009, over a week after
school is scheduled to start. Father's counsel again requested this be rescheduled
before the start of school but was advised by the Court that no earlier dates were
available.
13. Father is anticipating that the parties will not be able to agree on where the
children should start school in August. Therefore, he is requesting an Order providing
that the status quo be maintained and that the children will attend their current school
district, Cumberland Valley, pending the hearing and further Order of court.
14. It is in the best interest of the children to maintain their current school district
until further testimony can be presented, as the current school district can and has
adequately provided services for the children.
15. It is believed and averred that the best interest and permanent welfare of the
children will be promoted by relief requested in this Motion, as it will provide for the
stability, and education of the children.
16. This matter was previously assigned to Judge Ebert.
17. It is assumed that Mother does not agree with the relief requested as such
issue is central to the controversy at hand and it is believed that she has already
registered the children in a new school district without Father's consent.
WHEREFORE, Plaintiff requests the court to enter an order directing that the
children will stay in their current school district pending further hearing and/or Order.
Respectfully submitted,
Date: fD 6??/D9 ne Adams, Esquire
. No. 79465
17 W. South St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR FATHER
VERIFICATION
I verify that the statements made in this Petition are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
iti
Date: (? harles . Reinard, Petoner
CERTIFICATE OF SERVICE
AND NOW, this June 17, 2009, I, Jane Adams, Attorney for Charles B. Reinard,
hereby certify that a copy of Defendant's MOTION has been duly served upon the
Plaintiff's Counsel by placing such in the custody of the United States Postal Service,
via certified mail, postage pre-paid addressed to:
Marcus McKnight, Esquire
60 W. Pomfret St.
Carlisle, Pa. 17013
ATTORNEY FOR PLAINTIFF
J ne Adams, Esquire
I . No. 79465
17 W. South St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR FATHER
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ANGELA M. GROUP IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
CHARLES B. REINARD, NO. 07-6909 CIVIL
IN RE: CUSTODY
ORDER OF COURT
AND NOW, this 23rd day of June, 2009, the hearing in the above
captioned matter will now be held on Monday, August 17, 2009, at 2:00 p.m. in
Courtroom No. 5 of the Cumberland County Courthouse, Carlisle, Pennsylvania.
By the Court,
M. L. Ebert, Jr., J
Marcus McKnight, Esquire
Attorney for Plaintiff
Jane Adams, Esquire ;, ,y,,. C-4 3- ?y
Attorney for Defendant
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ANGELA M. GROUP IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
CHARLES B. REINARD,
DEFENDANT NO. 07-6909 CIVIL
IN RE: CUSTODY
ORDER OF COURT
AND NOW, this 24th day of August, 2009, upon consideration of the Father's
Motion to Maintain Current School District, the Pre-Hearing memorandums filed by the
parties and after hearing,
IT IS HEREBY ORDERED AND DIRECTED:
1. LEGAL CUSTODY: The Mother, Angela Group, and the Father, Charles
Reinard, shall enjoy shared legal custody of Cole T. Reinard, born 10/06/01 and Brian
E. Reinard, born 9110/04. Major decisions concerning their children, including, but not
necessarily limited to, the children's health, welfare, education, religious training and
upbringing shall be made by them jointly, after discussion and consultation with each
other, with a view toward obtaining and following a harmonious policy in the children's
best interest. Each party shall not impair the other party's rights to shared legal custody
of the children. Each party shall not alienate the affections for the children from the
other party. Each party shall notify the other of any activity or circumstance concerning
their children that could reasonably be expected to be of concern to the parent then
having physical custody. With regard to any emergency decisions that must be made,
the parent having physical custody of the children at the time of the emergency shall be
permitted to make any immediate decisions necessitated thereby. However, that parent
shall inform the other of the emergency and consult with him or her as soon as
thereafter possible. Each party shall be entitled to complete and full information from
any doctor, dentist, teacher, professional or authority and to have copies of any reports
given to either party as a parent.
2. SCHOOL DISTRICT: For the 2009 - 2010 school year, the children shall
attend the South Western School District.
3. PHYSICAL CUSTODY:
A. School Year:
a. MOTHER: Mother shall have physical custody of the children
from 8:00 p.m. Sunday evening to 2:30 p.m. Friday afternoon. When Monday is a
school holiday, Mother's period of custody will begin on Monday evening at 8:00 p.m.
Mother shall provide transportation for pick up the child at the Father's home on the
Sunday/Monday night exchanges.
b. FATHER: Father shall have custody of the children each week
from Friday at 2:30 p.m. until Sunday at 8:00 p.m. When Monday is a school holiday
Father's period of custody will be extended until 8:00 P.M. Monday evening. Father
shall provide transportation for pick up the children each Friday at 2:30 p.m.
B. Summer:
a. FATHER: Father shall have custody of the children each week
from Wednesday at 9:00 a.m. until Sunday at 9:00 p.m. Father shall provide
transportation for pick up of the children at Mother's home on the Wednesday morning
exchanges.
b. MOTHER: Mother will have custody of the children from 9:00
p.m. on Sunday evening until 9:00 a.m. on Wednesday. Mother shall provide
transportation for pick up of the children at the Father's home on Sunday evening.
C. Vacation:
Each party will be granted two continuous weeks of vacation.
Father will provide notice of his requested dates to Mother on or before May 14, 2010.
Mother will then choose her two weeks of vacation and provide notice to Father on or
before May 31, 2010.
D. Holidays:
Holidays with the children shall be alternated between
parents pursuant to the following holiday schedule or as mutually agreed.
HOLIDAY TIMES EVEN ODD
YEARS YEARS
Easter Day 1St half from 8 am the Saturday Father Mother
before Easter until 8 am
Easter Sunday
Easter Day 2nd half from 8 am Easter Sunday Mother Father
Until 8 pm
Memorial Day from 9 am until 9 pm Mother Father
Independence Day from 9 am until 9 pm Father Mother
Labor Day from 9 am until 9 pm Mother Father
Halloween from one hour before Father Mother
trick or treating to one
hour after trick or treating
Thanksgiving on Thanksgiving Day from Father Mother
1 st half 8 am until 2 pm
Thanksgiving from 2 pm Thanksgiving Day Mother Father
2nd half until noon the day after
Christmas 1St half from 8 am Dec. 24 until Father Mother
10 am Dec. 25
Christmas 2nd half from 10 am Dec. 25 until Mother Father
8 pm Dec. 26
New Years from 6 pm 12/31 until noon Mother Father
January 1 (with the 12/31 year
to control the even/odd
determination)
Mother's Day from 9 am until 9 pm Mother Mother
Father's Day from 9 am until 9 pm Father Father
4. TELEPHONE CONTACT: Telephone contact between the children and the
non-custodial parent shall be reasonable and liberal as agreed upon by the parties.
5. NONAILENATION: Neither party may say or do anything nor permit a third
party to do or say anything that may estrange the child from the other party, or injure the
opinion of the child as to the other party, or may hamper the free and natural
development of the child's love or affection for the other party. To the extent possible,
both parties shall not allow third parties to disparage the other parent in the presence of
the children.
6. MODIFICATION: The parties may modify the provisions of this Order by
mutual consent. In the absence of mutual consent, the terms of this Order shall control.
By the Court,
M. L. Ebert, Jr., J.
Marcus McKnight, Esquire
Attorney for Plaintiff
/Jane Adams, Esquire
Attorney for Defendant
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ANGELA M. GROUP, II,
Plaintiff
vs.
CHARLES B. REINARD,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 07 ?9Cq Civil Term
IN CUSTODY
MOTION FOR RECONSIDERATION
AND NOW, comes Petitioner, Charles B. Reinard, by and through his counsel,
Jane Adams, Esquire, and petitions the Court for reconsideration of the Order entered
in the above-captioned matter:
1. Charles B. Reinard, Defend ant/Petitioner, (hereinafter referred to as
"Father"), is the Defendant in the above-captioned matter, and is an adult individual
currently residing at 85 Regency Woods N., Carlisle, Cumberland County,
Pennsylvania, 17013.
2. Angela M. Group, Plaintiff/Respondent, (hereinafter referred to as "Mother") is
the Plaintiff in the above-captioned matter, and recently moved to Hanover from her
prior address at 114 Amy Drive, Carlisle, Cumberland County, Pennsylvania, 17013.
3. The parties are the natural parents of two children, namely:
Cole Tyler Reinard, born October 6, 2001; and
Brian Edward Reinard, born September 10, 2004.
4. The parties are subject to an Order of Court dated August 24, 2009, which
provides Mother with primary physical custody of the children.
5. Prior to the entry of this Court Order, the parties had equally shared physical
custody.
6. The August 24, 2009 Order provides Father with only two nights per week,
during the school year, as opposed to three or four provided in the prior Order.
7. Father is requesting additional time with the children, as he believes a more
shared arrangement is in the best interest of the children, and has been followed by the
parties for approximately the past year and a half.
8. Prior to this change of custody, Father was the primary daycare provider for
both children since he does not work during the day and the children had never
attended daycare.
9. Since the hearing, Father has been required to "rebid" his job shift, and he will
now be working starting at 9:00 p.m. instead of 6:00 p.m.
10. Since Mother currently has physical custody during the week, the younger
child, Brian Edward Reinard, stays with Mother from Sunday through Friday but cannot
attend school in the South Western School District due to the cutoff date.
11. Mother has now enrolled the younger child in daycare all day on Tuesday,
Wednesday and Friday. Mother is off every Tuesday and has still enrolled the child in
daycare. Mother has to be at work at 7:00 a.m. on Wednesday and Friday so it is
anticipated that the child would be at daycare for approximately 8-10 hours a day on
Tuesday, Wednesday, and Friday.
12. Father is off during the ten-hour days that Mother has enrolled the child in
daycare and could be spending quality time with his child, since the child cannot attend
school.
13. The Order provides that an exchange is made with the children 8:00 p.m.
Sunday evening, when Mother is to pick up the boys after work at Father's home. It is
anticipated that the children would return to Mother's home and not get to sleep until
well after 9:00 p.m. on a school night.
14. Father is also asking the Court to reconsider the bond that the children have
with their half-brother, Kalain Reinard, age 14, who resides in Father's home.
15. Subsequent to the hearing, Father became aware of some charges in Step-
father's prior criminal record which made him concerned; Father does not believe it
would be in the best interest of the children to reside in the home with Step-father
primarily.
16. For the reasons herein stated, Father is requesting this Honorable Court
reconsider its decision and grant him primary custody.
17. In the alternative, Father is requesting an Order that provides that:
(a) the children remain with Father Sunday evening through Monday
morning, until school starts, so that the children are not required to travel
past 8:00 p.m. on a school night.
(b) that Father be granted additional periods of physical custody with
Brian during the week, since Father has always been the primary daycare
provider and it would not be in Brian's best interest to be in daycare
twenty to thirty hours a weekend instead of in Father's care.
(c) that Father have primary physical custody with the children during the
summer.
(d) that Father's periods of physical custody be extended to Tuesday
morning, when there is no school on Monday.
(e) provides any such other relief as may be appropriate and in the best
interest of the children.
18. It is believed and averred that the best interest and permanent welfare of the
children will be promoted by relief requested in this Motion, as it will provide for ample
and consistent contact with both parents.
19. This matter was previously assigned to Judge Ebert.
20. Mother does not agree with the relief requested.
.t
WHEREFORE, Plaintiff requests the court to reconsider the Order entered in this
matter.
Respectfully submitted,
Date: 9 / i /a 9
dafie Adams, Esquire
I . No. 79465
7 7 W. South St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR FATHER
a
VERIFICATION
I verify that the statements made in this Petition are true and correct. I
understand that false statements herein are made subject to the penalties of 18
Pa.C.S. §4904 relating to unsworn falsification to authorities.
Date: 4' 05
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20,09 ". FM i2: 0 J
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ANGELA M. GROUP IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
CHARLES B. REINARD,
DEFENDANT NO. 07-6909 CIVIL
IN RE: CUSTODY
ORDER OF COURT
AND NOW, this 24th day of September, 2009, upon consideration of Defendant's
Motion for Reconsideration;
IT IS HEREBY ORDERED AND DIRECTED that the Motion for Reconsideration
is DENIED.
By the Court,
*?t QAA\
M. L. Ebert, Jr., J.
?M
arcus McKnight, Esquire
Attorney for Plaintiff
Jane Adams, Esquire
Attorney for Defendant
bas
(26F "s "a'
FLEE
OF THE P 1 DAIRY
2009 SEP 24 H '1k: ' ,
MCD C_
Mary A. Etter Dissinger '
Attorney for Petitioner
Supreme Court ID #27736
28 N. 32nd Street
Camp Hill , PA 17011
(717) 975-2840 - Phone
(717) 975-3924 -Fax
ANGELA M. GROUP, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
VS .
CIVIL ACTION - CUSTODY
CHARLES B. REINARD,
Defendant NO. 07-6909
PETITION TO MODIFY CUSTODY
1 . Petitioner is Charles B. Reinard residing at 898 Sandy Hollow
Road, New Bloomfield, Perry County, Pennsylvania.
2 . Respondent is' Angela M. Group, now known as Angela M.
Bradshaw, residing at 421 B South Center Street, York County,
Pennsylvania.
3 . The parties are 'the parents of Cole T. Reinard (DOB 10/06/01)
and Brian E. Reinard (DOB 9/10/04) .
4 . The parties share legal and physical custody of the children
pursuant to a Court Order dated August 24 , 2009 . (A copy of
the Order is attached as Exhibit "A" . )
5 . The Court Order provides :
A. During the school year:
1 . Respondent has physical custody of the children
from 8 : 00 p.m. Sunday evening to 2 : 30 p.m. Friday
afternoon; when Monday is a school holiday,
Respondent ' s period of custody will begin on
Monday evening at 8 : 00 p.m.
2 . Petitioner has custody of the children each week
from Friday at 2 : 30 p.m. until Sunday at 8 : 00 p.m.
When Monday is a school holiday, Petitioner ' s
period of custody will be extended until 8 : 00 p.m.
Monday evening.
B. During the summer:
1 . Petitioner has custody of the children each week
from Wednesday at 9: 00 a.m. until Sunday at 9: 00
p.m.
2 . Respondent has custody of the children from 9: 00
p.m. on Sunday evening until 9 : 00 a.m. on
Wednesday.
C. Each party has two (2) continuous weeks of vacation
and alternating holidays .
6. Petitioner seeks to modify the current Order because:
A. Both children wish to reside with the Petitioner;
B. The children' s grades and attendance are less than
satisfactory;
C. The children' s hygiene and nutrition are neglected by
Respondent;
D. The children are subjected to emotional and, in some
instances, physical abuse in Respondent ' s home; and
E. The best interests of the children would be served by
them residing primarily with Petitioner who is able to
better meet their physical and emotional needs as well
as academic needs .
WHEREFORE, Petitioner requests the Court to modify custody
and award him primary physical custody.
Respectfully Submitted:
DISSINGER AND DISSINGER
Mary Etter Dissinger
Attorney for Petitioner
Supreme Court ID # 27736
400 South State Street
Marysville, PA 17053
(717) 957-3474 - Phone
(717 ) 957-2316 - Fax
ANGELA M. GROUP IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
CHARLES B. REINARD,
DEFENDANT NO. 07-6909 CIVIL
IN RE: CUSTODY
ORDER OF COURT
AND NOW, this 24th day of August, 2009, upon consideration of the Father's
Motion to Maintain Current School District, the Pre-Hearing memorandums filed by the
parties and after hearing,
IT IS HEREBY ORDERED AND DIRECTED:
1. LEGAL CUSTODY: The Mother, Angela Group, and the Father, Charles
Reinard, shall enjoy shared legal custody of Cole T. Reinard, born 10/06/01 and Brian
E. Reinard, born 9/10/04. Major decisions concerning their children, including, but not
necessarily limited to, the children's health, welfare, education, religious training and
upbringing shall be made by them jointly, after discussion and consultation with each
other, with a view toward obtaining and following a harmonious policy in the children's
best interest. Each party shall not impair the other party's rights to shared legal custody
of the children, Each party shall not alienate the affections for the children from the
other party. Each party shall notify the other of any activity or circumstance concerning
their children that could reasonably be expected to be of concern to the parent then
having physical custody. With regard to any emergency decisions that must be made,
the parent having physical custody of the children at the time of the emergency shall be
permitted to make any immediate decisions necessitated thereby. However, that parent
EXHIBIT
"All
shall inform the other of the emergency and consult with him or her as soon as
thereafter possible. Each party shall be entitled to complete and full information from
any doctor, dentist, teacher, professional or authority and to have copies of any reports
given to either party as a parent.
2. SCHOOL DISTRICT: For the 2009 —2010 school year, the children shall
attend the South Western School District.
3. PHYSICAL CUSTODY:
A. School Year:
a. MOTHER: Mother shall have physical custody of the children
from 8:00 p.m. Sunday evening to 2:30 p.m. Friday afternoon. When Monday is a
school holiday, Mother's period of custody will begin on Monday evening at 8:00 p.m.
Mother shall provide transportation for pick up the child at the Father's home on the
Sunday/Monday night exchanges.
b. FATHER: Father shall have custody of the children each week
from Friday at 2:30 p.m. until Sunday at 8:00 p.m. When Monday is a school holiday
Father's period of custody will be extended until 8:00 p.m. Monday evening. Father
shall provide transportation for pick up the children each Friday at 2:30 p.m.
B. Summer:
a. FATHER: Father shall have custody of the children each week
from Wednesday at 9:00 a.m. until Sunday at 9:00 p.m. Father shall provide
transportation for pick up of the children at Mother's home on the Wednesday morning
exchanges.
b. MOTHER: Mother will have custody of the children from 9:00
p.m. on Sunday evening until 9:00 a.m. on Wednesday. Mother shall provide
transportation for pick up of the children at the Father's home on Sunday evening.
C. Vacation:
Each party will be granted two continuous weeks of vacation.
Father will provide notice of his requested dates to Mother on or before May 14, 2010.
Mother will then choose her two weeks of vacation and provide notice to Father on or
before May 31, 2010.
D. Holidays:
Holidays with the children shall be alternated between
parents pursuant to the following holiday schedule or as mutually agreed.
HOLIDAY TIMES EVEN ODD
YEARS YEARS
Easter Day 1St half from 8 am the Saturday Father Mother
before Easter until 8 am
Easter Sunday
Easter Day 2"d half from 8 am Easter Sunday Mother Father
Until 8 pm
Memorial Day from 9 am until 9 pm Mother Father
Independence Day from 9 am until 9 pm Father Mother
Labor Day from 9 am until 9 pm Mother Father
Halloween from one hour before Father Mother
trick or treating to one
hour after trick or treating
Thanksgiving on Thanksgiving Day from Father Mother
1St half 8 am until 2 pm
Thanksgiving from 2 pm Thanksgiving Day Mother Father
2nd half until noon the day after
Christmas 1St half from 8 am Dec. 24 until Father Mother
10 am Dec. 25
Christmas 2nd half from 10 am Dec. 25 until Mother Father
8 pm Dec. 26
New Years from 6 pm 12/31 until noon Mother Father
January 1 (with the 12/31 year
to control the even/odd
determination)
Mother's Day from 9 am until 9 pm Mother Mother
Father's Day from 9 am until 9 pm Father Father
4. TELEPHONE CONTACT: Telephone contact between the children and the
non-custodial parent shall be reasonable and liberal as agreed upon by the parties.
5. NONAILENATION: Neither party may say or do anything nor permit a third
party to do or say anything that may estrange the child from the other party, or injure the
opinion of the child as to the other party, or may hamper the free and natural
development of the child's love or affection for the other party. To the extent possible,
both parties shall not allow third parties to disparage the other parent in the presence of
the children.
6. MODIFICATION: 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,
`k—�, .
M. L. Ebert, Jr., J u
Mu
A
Marcus McKnight, Esquire
Attorney for Plaintiff
Jane Adams, Esquire
Attorney for Defendant
bas
VERIFICATION
I, Charles B. Reinard, verify that the statements made in the
foregoing document are true and correct . I understand that false
statements herein are made subject to the penalties of 18 Pa. C. S.
§4904 relating to unsworn falsification to authorities .
C les . Reinard,
Defendant/Petitioner
Mary A. Etter Dissinger
Attorney for Plaintiff
Supreme Court ID #27736
28 N. 32nd Street
Camp Hill, PA 17011
(717) 975-2840 - Phone
(717) 975-3924 -Fax
ANGELA M. GROUP, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
VS .
CIVIL ACTION - CUSTODY
CHARLES B. REINARD,
Defendant NO. 07-6909
CERTIFICATE OF SERVICE
I, Mary A. Etter Dissinger, Esquire, hereby certify that on
the date set forth below I served a true and correct copy of the
Petition to Modify Custody upon Angela M. Group and Marcus A.
McKnight, III, Esquire, the attorney for Angela M. Group, by First
Class United States mail addressed as follows :
Irwin & McKnight, P.C.
ATTN: Marcus A. McKnight
West Pomfret Street
Carlisle, PA, 17013
Date:
Mary Etter Dissinger /
ANGELA M. GROUP IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
2007-a6909 CIVIL ACTION LAW
CHARLES B,REINARD
IN CUSTODY
DEFENDANT
C--)
C-3 CD
-Z
ORDER OF COURT -4
AND NOW, Friday,July 12,2013 upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before John J. Mang'an,Jr Esq.,,the conciliator,
at 4th Floor,Cumberland County Courthouse,Carlisle - on-Friday,August 09,2013 10:30 AM
for a Pre-Hearing Custody Conference, At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished,to define and narrow the issues to be heard by the court, and to enter into a temporary
order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders,and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ john-1 Marz an -fr. Eso.\Il
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabifites 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
led Carlisle, Pennsylvania 17013
Telephone (717)249-3166
Mow
M
G
ANGELA M. GROUP, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
c C
V. No. 07 - 6909 CIVIL ACTION LA a.
ern
CHARLES B. REINARD, IN CUSTODY7_
Defendant {of
Prior Judge: M.L. Ebert, Jr.,J cv
ORDER OF COURT A"
-C cil
AND NOW this day of September 2013,upon consideration of the attached Custody
Conciliation Report, it is Ordered and Directed as follows:
I. Absent written agreement otherwise and pending hearing, the prior Order dated August 24,
2009 shall remain in full force and effect.
2. A pretrial conference with the assigned Judge is hereby scheduled in the above case on the
A 91`day of 2013 at in in courtroom number 2 of the Cumberland County
Courthouse. The parties are directed to proceed with filing a pretrial statement with the Court
and the other party consistent with the Pennsylvania Rule of Civil Procedure 1915.4-4.
3. This Order is entered pursuant to a Custody Conciliation Conference. A Custody Hearing is
hereby scheduled on the ICt-h - day of`1�c U_P_� , 2013 at µ.m in Courtroom
numbero2.in the Cumberland County Court of Common Pleas, Carlisle, PA 17013 at which
time testimony will be taken in regard to the physical custody for the subject Child. For
purposes of this hearing, the Father shall be deemed to be the moving party and shall proceed
initially with testimony.
4. Relocation. The parties are advised that neither party shall hereafter relocate the child or
children if such relocation will significantly impair the ability of a non-relocating party to
exercise his or her custodial rights unless (a) every person who has custodial rights to the
child/children consents to the proposed relocation or(b) the court approves the proposed
relocation. The party seeking relocation must follow the procedures required by 23 Pa.C.S.
§5337.
5. 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.
D*stribution:
✓Mary Dissinger, Esq.
arcus McKnight, III, Esquire
�.ohn J. Mangan, Esq ire
� er ?
g/i,2 _
ANGELA M. GROUP, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 07 - 6969 CIVIL ACTION LAW
CHARLES B. REINARD, IN CUSTODY
Defendant
Prior Judge: M.L. Ebert, Jr., J
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL 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:
Name Date of Birth Currently in the Custody of
Cole T. Reinard 10/6/2001 Mother and Father
Brian E. Reinard 9/10/2004 Mother and Father
2. A Conciliation Conference was held with regard to this matter on February 7, 2008, an Order
was issued February 11, 2008, a Conciliation Conference was held May 05, 2009, an Order
issued May 13, 2009, an Order issued August 24, 2009 and a conference was held August 20,
2013 with the following individuals in attendance:
The Father, Charles Reinard, with his counsel, Mary Dissinger, Esq.
The Mother,Angela Group, with her counsel, Marcus McKnight, III, Esquire.
3. Mother's position on custody is as follows: Mother requests the status quo with her having
primary custody during the school year. In response to Father's allegation about her husband's
alcohol issues, Mother denies this. Mother reports that the Children's grades are pretty good
and they are doing well in school. Mother questions the ability of Father to get the kids to
school given his and his wife's work schedule. Mother has further concerns about supervision
when Father is working. Mother still lives in Hanover and Father has relocated to New
Bloomfield; the parents are about an hour apart. Each parent reports that the other manipulates
the Children.
4. Father's position on custody is as follows: Father would requests primary custody of the
Children during the school year. Father has concerns about Mother's new husband and alcohol
issues. Father has concerns about school attendance issues,hygiene issues for the Children,
grade issues and has further concerns about Mother's husband's temper. Father reports that the
Children want to primarily live with him.
5. The Conciliator recommends an Order in the form as attached scheduling a Hearing and
entering an Order of Court regarding custody as outlined. It is the Conciliator's belief that this
would be in the Children's best interest. It is expected that the Hearing will require one whole
day
6. The 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:
Jo J. Mangan, Esquire
Custody Conciliator
2U3SEP ( 7 Ai 9: C7
Mary A. Etter Dissinger SUF18ERLI i co: r`:'a Y
Attorney for Defendant PENNSYLVANIA
Supreme Court ID #27736
400 South State Road
Marysville, PA 17053
(717) 957-3474 - Phone
(717 ) 957-2316 -Fax
ANGELA M. GROUP, • IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs . •
• CIVIL ACTION - CUSTODY
CHARLES B. REINARD,
Defendant NO. 07-6909
MOTION TO RESCHEDULE CUSTODY PRE-HEARING CONFERENCE
AND NOW, comes Mary A. Etter Dissinger, Esquire, attorney for
Charles B. Reinard and requests the Court to reschedule the Pre-
Hearing Conference. In support of, the motion avers as follows :
1 . Petitioner is Mary A. Etter Dissinger, Esquire, counsel for
Charles B. Reinard, the Defendant .
2 . Petitioner and her husband have been scheduled for a vacation
during the week of September 25, 2013, and as a result of
that, will not be available for a Pre-Trial Conference
scheduled for September 25, 2013 .
3 . Petitioner respectfully requests that the Pre-Trial
Conference be rescheduled to November 8, 2013, at 8 : 30 a.m. .
4 . Marcus McKnight, III, counsel for Angela M. Group does not
oppose this motion.
WHEREFORE, it is respectfully requested that the Pre-Trial
Conference scheduled for September 25, 2013, at 3 : 30 p.m. be
rescheduled to November 8, 2013, at 8 : 30 a.m. .
Respectfully Submitted:
DISSINGER AND DISSINGER
Mary A. Etter Dissinger
Attorney for Defendant
Supreme Court ID # 27736
400 South State Street
Marysville, PA 17053
(717) 957-3474 - Phone
(717) 957-2316 - Fax
Mary A. Etter Dissinger
Attorney for Plaintiff
Supreme Court ID #27736
400 South State Road
Marysville, PA 17053
(717) 957-3474 - Phone
(717) 957-2316 -Fax
ANGELA M. GROUP, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs . ••
CIVIL ACTION - CUSTODY
CHARLES B. REINARD,
Defendant NO. 07-6909
CERTIFICATE OF SERVICE
I, Mary A. Etter Dissinger, Esquire, hereby certify that on
the date set forth below, I served a true and correct copy of the
foregoing document upon Marcus A. McKnight, III, Esquire, the
attorney for Angela M. Group, by First Class United States mail
addressed as follows :
Marcus A. McKnight, Esquire
Irwin & McKnight, P.C.
60 West Pomfret Street
Carlisle, PA, 17013-3222
Date: V/7
Mary A. Etter Dissinger, Esq.
K
ANGELA M. GROUP, IN THE COURT OF COMMON PLEAS
Plaintiff/Respondent OF CUMBERLAND COUNTY,
PENNSYLVANIA
VS .
CIVIL ACTION - CUSTODY
CHARLES B. REINARD,
Defendant/Petitioner NO. 07-6909
q ORDER OF COURT
AND NOW, this 1 day of September 2013, the Pre-Hearing
Conference in the above matter scheduled for September 25, 2013,
at 3: 30 p.m. is hereby scheduled for November 8, 2013, at 8 : 30
a.m. .
BY THE COURT:
By:
M.L. Ebert, Judge
Di ribution:
Marcus McKnight, Esq. Irwin & McKnight, P.C. , 60 West Pomfret -St. , Carlisle,
Per'-17013-3222
,//Mary A. Etter Dissinger, Esq. , 400 S. State Rd. , Marysville, PA 17053
tKcs' �
4/1-3
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Mary A. Etter Dissinger
Attorney for Defendant r ";`�.<<tk
Supreme Court ID #27736 r , ; E � ,# g
400 South State Road
Marysville, PA 17053
(717) 957-3474 - Phone
(717) 957-2316 - Fax
ANGELA M. GROUP, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs . •
CIVIL ACTION - CUSTODY
CHARLES B. REINARD,
Defendant NO. 07-6909
MOTION TO PRODUCE CHILDREN TO TESTIFY IN CHAMBERS ON
NOVEMBER 19, 2013
AND NOW, comes Mary A. Etter Dissinger, Esquire, counsel for
Charles B. Reinard and requests the Court to direct that the
children be present at the Custody Hearing for purposes of
testifying in chambers, and in support of the motion avers as
follows :
1 . Movant represents the Defendant, Charles B. Reinard.
2 . Defendant Reinard is one of the parents of the two (2)
minor children that are the subject of the pending
custody action which is scheduled for hearing before
the Honorable Judge Ebert .
3 . The Honorable Judge Ebert has presided over this case
in the past and heard testimony of the children in
chambers .
4 . To avoid hearsay objections, Defendant proposes that
the children, again, meet in chambers with the Judge so
he may converse with them, or examine them in chambers
as to whether or not their reasons for wishing to
relocate to father' s home primarily are well reasoned
and with adequate foundation and in their best
interest .
5 . A copy of this Motion and proposed Orders have been
provided to Marcus McKnight, Esquire, counsel for
mother and he objects/does not objects/has not
, responded.
WHEREFORE, Movant respectfully requests that the children be
directed to be present solely to testify in chambers on November
19, 2013 .
Respectfully Submitted
DISSINGER & DISSINGER
By: -2;4k,-1
Mary A. Etter Dissinger
Attorney for Defendant
Supreme Court ID #27736
400 South State Road
Marysville, PA 17053
(717) 957-3474 - Phone
(717) 957-2316 - Fax
r
Mary A. Etter Dissinger
Attorney for Defendant
Supreme Court ID #27736
400 South State Road
Marysville, PA 17053
(717) 957-3474 - Phone
(717) 957-2316 - Fax
ANGELA M. GROUP, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
. PENNSYLVANIA
vs . •
. CIVIL ACTION - CUSTODY
CHARLES B. REINARD,
Defendant NO. 07-6909
CERTIFICATE OF SERVICE
I, Crystal E. Kissinger, Paralegal for Mary A. Etter
Dissinger, Esquire, hereby certify that on the date set forth
below, I served a true and correct copy of the foregoing document
to Marcus McKnight, attorney for Plaintiff, Angela M. Group, by
First Class United States mail addressed as follows :
Marcus McKnight, Esquire
60 West Pomfret Street
Carlisle, PA 17013-3222
/1
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Date.- :���/. _ �& '! !���
ry-r al E. Kissinge
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C� f� ' ° ,A1COUNTY , PENNSYLVANIA
Plaiiff .�
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:efiendant :
: CIVIL ACTION - CUSTODY
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, hereby swear or affirm,
subject to penalties of law including 18 Pa. C .S. §4904 relating
to unsworn falsification to authorities tht :
1 . I and/or another adult living iri my household have or
have not been convicted , pled guilty or no contest to the
following crimes in Pennsylvania or any other jurisdiction, as
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Sex offender non-
la E3 compliance with
registration
requirements, statute,
court order, probation El 0
or parole, or other
requirements under 18
Pa. C.S.A. §3130 and
42 Pa. C.S. §9785. 2;
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Concealing death of a
.3g{, C3 child; El ED .•
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Prostitution and
related offenses; 0 .
0
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Corruption of minors
. or unlawful contact
0 I 0
with a minor;
2. I and/or another adult living in my household have
I
present and/or past history of violent or abusive conduct
including the following :
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A finding of abuse by a
Children & Youth Agency Ei
0
or similar agency in
Pennsylvania or similar
statue in another
urisdiction
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COMMONWEALTH OF PENNSYLVANIA
I9-k c7
COUNTY OF 'flAUf3tti`N •
3
2d 17266-SLG-LIZ, H Ja2uTssTG 1 Ja2OissT0 WIJi7t. : II 6102 LI 400
i •
•
On this the 1 day of ` � , 2015, before me,
a Notary Public, the undersigned officer, personally appeared
CinCartQ ` j ✓ + ►'\C'L4,-C, , Known to me or
satisfactorily proven to be the person presenting this
affidavit , and acknowledged that they executed the same for the
purposes therein contained .
IN WITNESS WHEREOF , I have hereunto set my hand and
official seal.
My om s s ' . !try-
111�►f� -'fir
Notary Public
COMMONWEALTH OF PENNSYLVANIA
NOT RIM.S AL
DANIELLE R SCHOONOVER
Notary Public
MARYSVILLE BORO,PERRY COUNTY
My Commission Expires Jun 14,2017
4
E 'd 26E-SL6-GTL WO .aa utsstQ .aa2uissta Wd917 : TT 6102 Li 400
Mary A. Etter Dissinger
Attorney for Defendant
Supreme Court ID #27736
400 South State Road
Marysville, PA 17053
(717) 957-3474 - Phone
(717) 957-2316 - Fax
ANGELA M. GROUP, IN THE COURT OF COMMON PLEAS
Plaintiff • OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs . •
CIVIL ACTION - CUSTODY
CHARLES B. REINARD, •
Defendant • NO. 07-6909
CERTIFICATE OF SERVICE
I, Crystal E. Kissinger, Paralegal for Mary A. Etter
Dissinger, Esquire, hereby certify that on the date set forth
below, I served a true and correct copy of the foregoing document
to Marcus McKnight, attorney for Plaintiff, Angela M. Group, by
First Class United States mail addressed as follows :
Marcus McKnight, Esquire
60 West Pomfret Street
Carlisle, PA 17013-3222
_
Date: / s Lls / I i'
• tal E. Kissino -
THE PRO f ROiGO ;AF ,
Mary A. Etter Dissinger �IaiJ H 8: 43
Attorney for Defendant C1JMii EF:ZL ?W C UNTY
Supreme Court ID #27736 PENNSYLVANIA
400 South State Road
Marysville, PA 17053
(717) 957-3474 - Phone
(717) 957-2316 - Fax
ANGELA M. GROUP, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
. PENNSYLVANIA
vs .
. CIVIL ACTION - CUSTODY
CHARLES B. REINARD,
Defendant NO. 07-6909
Order
AND NOW, this 21�� day of O to\OLir , 2013, the
parties are directed to bring Cole T. Reinard and Brian E.
Reinard to the Custody Hearing on November 19, 2013, at 9 : 30
a.m. . The party having physical custody of the children on the
day of hearing shall provide a babysitter to supervise them in a
conference room during the hearing.
BY THE COURT:
1\111k. a4(
J.
D' tribution:
y A. Etter Dissinger, Esq. , 400 S. State Rd. , Marysville, PA 17053
Marcus McKnight, Esq. , 60 W. Pomfret St. , Carlisle, PA 17013-3222
CC 1''
,la �„s//3
ANGELA M. GROUP IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVAN.A
V. rtF i
M"L'T
CP)t
CHARLES B. REINARD, 3>
DEFENDANT NO. 07-6909 CIVIL ID; -
- r
IN RE: CUSTODY
ORDER OF COURT
AND NOW, this 14th day of January, 2014, upon consideration of the Father's
Motion to Maintain Current School District, the Pre-Hearing memorandums filed by the
parties and after hearing,
IT IS HEREBY ORDERED AND DIRECTED:
1. LEGAL CUSTODY: The Mother, Angela Group, and the Father, Charles
Reinard, shall enjoy shared legal custody of Cole T. Reinard, born 10/06/01 and Brian
E. Reinard, born 9/10/04. Major decisions concerning their children, including, but not
necessarily limited to, the children's health, welfare, education, religious training and
upbringing shall be made by them jointly, after discussion and consultation with each
other, with a view toward obtaining and following a harmonious policy in the children's
best interest. Each party shall not impair the other party's rights to shared legal custody
of the children. Each party shall not alienate the affections for the children from the
other party. Each party shall notify the other of any activity or circumstance concerning
their children that could reasonably be expected to be of concern to the parent then
having physical custody. With regard to any emergency decisions that must be made,
the parent having physical custody of the children at the time of the emergency shall be
permitted to make any immediate decisions necessitated thereby. However, that parent
shall inform the other of the emergency and consult with him or her as soon as
thereafter possible. Each party shall be entitled to complete and full information from
any doctor, dentist, teacher, professional or authority and to have copies of any reports
given to either party as a parent.
2. SCHOOL DISTRICT: The children shall attend the West Perry School
District.
3. PHYSICAL CUSTODY:
A. School Year:
a. FATHER: Father shall have primary physical custody of the
children beginning Sunday, March 2, 2014.
b. MOTHER:
(1) Mother shall have partial physical custody of the children
on alternating weekends from Friday at 7:30 p.m. until Sunday at 8:00 p.m. beginning
March 14, 2014. Father will provide transportation to and from the Mother's home for
these visits.
(2) Additionally, Mother will have partial physical custody of
the children from after school on Wednesday until 9:00 p.m. Mother will be solely
responsible for providing transportation for the Wednesday night visits.
B. Summer:
Father shall have custody of the children each week from Thursday
at 8:00 p.m. until Monday at 8:00 p.m. Mother shall provide transportation of the
children to Father's home on Thursday evenings. Father shall provide transportation to
Mother's home on Monday evenings.
C. Vacation:
Each party will be granted two continuous weeks of vacation.
Father will provide notice of his requested dates to Mother on or before May 14 of each
even year. Mother will then choose her two weeks of vacation and provide notice to
Father on or before May 31 of each even year. In odd numbered years Mother will
choose first by May 14. Father will then respond by May 31.
D. Holidays:
Holidays with the children shall be alternated between
parents pursuant to the following holiday schedule or as mutually agreed.
HOLIDAY TIMES EVEN ODD
YEARS YEARS
Easter Day 1St half from 8 am the Saturday Father Mother
before Easter until 8 am
Easter Sunday
Easter Day 2nd half from 8 am Easter Sunday Mother Father
Until 8 pm
Memorial Day from 9 am until 9 pm Mother Father
Independence Day from 9 am until 9 pm Father Mother
Labor Day from 9 am until 9 pm Mother Father
Thanksgiving on Thanksgiving Day from Father Mother
1 st half 8 am until 2 pm
Thanksgiving from 2 pm Thanksgiving Day Mother Father
2nd half until noon the day after
Christmas 1St half from 8 am Dec. 24 until Father Mother
10 am Dec. 25
Christmas 2nd half from 10 am Dec. 25 until Mother Father
8 pm Dec. 26
New Years from 6 pm 12/31 until noon Mother Father
January 1 (with the 12/31 year
to control the even/odd
determination)
Mother's Day from 9 am until 9 pm Mother Mother
Father's Day from 9 am until 9 pm Father Father
4. TELEPHONE CONTACT: Telephone contact between the children and the
non-custodial parent shall be reasonable and liberal as agreed upon by the parties.
5. DRUGS AND ALCOHOL: During any period of custody or visitation, neither
party shall possess or use any controlled substance, or consume alcoholic beverages to
the point of intoxication in the presence of the children. The parties shall likewise
assure that other household members and/or guests comply with this provision.
6. NONAILENATION: Neither party may say or do anything nor permit a third
party to do or say anything that may estrange the child from the other party, or injure the
opinion of the child as to the other party, or may hamper the free and natural
development of the child's love or affection for the other party. To the extent possible,
both parties shall not allow third parties to disparage the other parent in the presence of
the children.
7. RELOCATION: No party shall relocate the child if such relocation will
significantly impair the ability of the non-relocating party to exercise his or her custodial
rights unless (a) every person who has custodial rights to the child consents to the
proposed relocation or (b) the court approves the proposed relocation. The party
seeking relocation must follow the procedures required by 23 Pa. C.S. §5337.
8. MODIFICATION: 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,
�*'"'-t-q
M. L. Ebert, Jr., J.
✓ Marcus McKnight, Esquire
/Attorney for Plaintiff
,/Mary Etter Dissinger, Esquire
Attorney for Defendant
bas
C
Y
�.ry1
ANGELA M. GROUP, IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNS V,�NIA_.
r�r�; c_.
V. -
CHARLES B. REI NARD, V
DEFENDANT NO. 07-6909 CIVIL
ORDER OF COURT
AND NOW, this 14th day of January, 2014, after hearing in the matter, pursuant
to 23 Pa.C.S.A. §5323(d) the Court states the following reasons in support of the
Custody Order issued in this case:
1. Both parents will encourage and permit frequent and continuing contact
between the children and the other party.
2. Both parties are capable of performing parental duties on behalf of the
children.
3. At this time, the need for stability and continuity in the children's education,
family life and community life will best be served by Father having primary custody.
4. Both children expressed a well-reasoned preference to be in their Father's
primary physical custody. These children, age 12 and 9 are concerned about Mother's
new husband's use of alcoholic beverages.
5. Father is more likely to attend to the daily physical, emotional, developmental,
educational and special needs of the children.
6. At the present time, the parties live approximately 51 miles from each other.
This distance between the homes does not make 50/50 custody feasible.
7. The level of conflict between these parties is moderate, but the Court finds
that they are capable of cooperating when necessary.
A
8. Mother's new husband admits having several prior driving under the influence
charges and that while he was attending Alcoholics Anonymous, he no longer attends.
The children did voice various concerns regarding Jamie Bradshaw's drinking habits.
By the Court,
M. L. Ebert, Jr., J.
✓Marcus McKnight, Esquire
Attorney for Mother
✓ Mary Dissinger, Esquire
Attorney for Father
ICS �
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