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HomeMy WebLinkAbout08-0661t? In the Court of Common Pleas of Cumberland County, Pennsylvania CHARLES BRIAN REINARD, Case Number: Plaintiff, DIV: o2- G41 vs ANGELA MARIE GROUP, Defendant. DISCLOSURE FROM NON-LAWYER I, CHARLES BRIAN REINARD, certify that K. Nicole Jenkins, explained to me that she is not an attorney who is a member in good standing of any Bar and that she CANNOT: 1) give me legal advice; 2) tell me what my legal rights or remedies are; 3) represent me in court; or 4) tell me how to testify in court. This non-lawyer further explained to me that she CAN ONLY: 1) help me fill out court approved forms 2) ask me questions to fill in the form(s); and 3) show or explain to me how to file the form(s). I can read English I cannot read English, but this disclosure was read to me by { name } in { language } Dated: -1 1 Signature of y CHARLES BRIAN REINARD K. Nicole Jenkins, Non-Lawyer Address: Legal Aid National Services, Inc, 875 South Colorado Boulevard, Suite 672 Denver, Colorado 80246 (866) 565-7188 In the Court of Common Pleas of Cumberland County, Pennsylvania CHARLES BRIAN REINARD, Case Number: Plaintiff, DIV: vs ANGELA MARIE GROUP, Defendant. SUMMONS: PERSONAL SERVICE ON AN INDIVIDUAL To: ANGELA MARIE GROUP 114 Amy Drive Carlisle, PA 17013 IMPORTANT A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached complaint/petition with the clerk of this court, located at: 1 Courthouse Square, Carlisle, PA 17013 A phone call will not protect you. Your written response, including the case number given above and the names of the parties, must be filed if you want the Court to hear your side of the case. If you do not file your written response on time, you may lose the case, and your wages, money, and property may be taken thereafter without further warning from the Court. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may call an attorney referral service or a legal aid office (listed in the phone book). If you choose to file a written response yourself, at the same time you file your written response to the Court, you must also mail or take a copy of your written response to the party serving this summons at: Charles Brian Reinard, 85 Regency Woods North, Carlisle, PA 17015 Copies of all court documents in this case, including orders, are available at the Clerk of the Circuit Court's office. You may review these documents, upon request. You must keep the Clerk of the Circuit Court's office notified of your current address. Future papers in this lawsuit will be mailed to the address on record at the clerk's office. THE STATE OF PENNSYLAVANIA TO EACH SHERIFF OF THE STATE: You are commanded to serve this summons and a copy of the complaint in this lawsuit on the above-named person. DATED: CLERK OF THE CIRCUIT COURT By: Deputy Clerk 2 In the Court of Common Pleas of Cumberland County, Pennsylvania CHARLES BRIAN REINARD, Plaintiff, Case Number: n `-' DIV: 0 F_ G G / l..C.I1 J- ??-- vs ANGELA MARIE GROUP, Defendant. COMPLAINT FOR CUSTODY 1. The plaintiff is CHARLES BRIAN REINARD, residing at 85 Regency Woods North, Carlisle, PA 17015, Cumberland County. 2. The defendant is ANGELA MARIE GROUP, residing at 114 Amy Drive Carlisle, PA 17013, Cumberland County. 3. Plaintiff seeks CUSTODY of the following children: • Cole Tyler Reinard, residing at 85 Regency Woods North, Carlisle, PA 17015, Cumberland County, whose date of birth is October 6, 2001; • Brian Edward Reinard, residing at 85 Regency Woods North, Carlisle, PA 17015, Cumberland County, whose date of birth is September 10, 2004. r The children were born out of wedlock; however, the plaintiff is named on the birth certificate and has had a continual relationship and has been acting in the capacity of the children's father since birth. The plaintiff is the biological father of the children. The children are presently in the custody of plaintiff, CHARLES BRIAN REINARD, who resides at 85 Regency Woods North, Carlisle, PA 17015, Cumberland County. During the past five years, the children have resided with the following persons and at the following addresses: The child, Cole Tyler Reinard, previously resided with the plaintiff at 151 South West Street, Carlisle, PA 17013 from August 1, 2001 until June 1, 2002. The child, Cole Tyler Reinard, currently resides with the plaintiff at 85 Regency Woods North, Carlisle, PA 17015, Cumberland County and has since June 1, 2002. The child Brian Edward Reinard has resided with the plaintiff at 85 Regency Woods North, Carlisle, PA 17015, Cumberland County, his entire life, since September 10, 2004. The mother of the children is ANGELA MARIE GROUP, currently residing at 114 Amy Drive Carlisle, PA 17013, Cumberland County. 2 She is single. The father of the children is CHARLES BRIAN REINARD, currently residing at 85 Regency Woods North, Carlisle, PA 17015, Cumberland County. He is single. 4. The relationship of plaintiff to the children is that of Father. The plaintiff currently resides with the following persons: Name Relationship Cole Tyler Reinard Son Brian Edward Reinard Son 5. The relationship of defendant to the children is that of Mother. It is unknown at this time as to who resides with the defendant. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 3 f Plaintiff does not know of a person not a party to the proceedings that has physical custody of the children or claims to have custody or visitation rights with respect to the children. The best interest and permanent welfare of the children will be served by granting the relief requested because the plaintiff is a stable part of the children's lives, is the fit and proper parent to continue to take care of the children on a day-to-day basis, and the plaintiff will ensure the children maintain a good and quality relationship with defendant. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene: ANGELA MARIE GROUP, currently residing at 114 Amy Drive Carlisle, PA 17013, Cumberland County WHEREFORE, plaintiff requests the court to grant CUSTODY of the said children to plaintiff. r G Plaintiff/ Pro Se CHARLES BRIAN REINARD 4 I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 1904 relating to unsworn falsification to authorities. T1 Plaintiff/ Pro Se CHARLES BRIAN REINARD CERTIFICATE OF SERVICE I HEREBY CERTIFY, a true and correct copy of the foregoing has been furnished by special process server or sheriff of this county to ANGELA MARIE GROUP, residing at 114 Amy Drive Carlisle, PA 17013 this day of January 2008. Charles Brian Reinard 85 Regency Woods North Carlisle, PA 17015 (717) 525-2272 Plaintiff/ Pro Se In the Court of Common Pleas of Cumberland County, Pennsylvania CHARLES BRIAN REINARD, Case Number: Plaintiff, DIV: vs ANGELA MARIE GROUP, Defendant. UNIFORM CHILD CUSTODY JURISDICTION AND ENFORCEMENT ACT (UCC JEA) AFFIDAVIT I, CHARLES BRIAN REINARD, the Plaintiff in this case, being sworn, certify that the following statements are true: 1. There are two children subject to this proceeding. 2. The name of the oldest child is COLE TYLER REINARD. 3. The date of the oldest child's birth is October 6, 2001. 4. The oldest child is a male. 5. The oldest child's present address is: 85 Regency Woods North, Carlisle, PA 17015, Cumberland County. 6. The oldest child currently resides with the father, CHARLES BRIAN REINARD. 7. The name of the youngest child is BRIAN EDWARD REINARD. 8. The date of the youngest child's birth is September 10, 2004. 9. The youngest child is a male. 10. The youngest child's present address is: 85 Regency Woods North, Carlisle, PA 17015, Cumberland County. 11. The youngest child currently resides with the father, CHARLES BRIAN REINARD. In regards to COLE TYLER REINARD: D ates (From/To) 10/06/01 Address (including city and state) where child lived Name and present address person child lived with Relationship to child (birth) to 06/01/02 151 South West Street, Carlisle, PA 17013 Charles BrianReinard, 85 Regency Woods North, Carlisle, PA 17015 and Father and Mother 06/01/02 t 85 Angela Marie Group, 114 Amy Drive Carlisle, PA 17013 o Present Regency Woods North, Carlisle, PA 17015 Charles Brian Reinard, 85 Regency Woods North, Carlisle, PA 17015 and Angela Marie Group, 114 Amy Drive Carlisle, PA 17013 Father and Mother until separation, then remained with Father at this address. In regards to BRIAN EDWARD REINARD: Dates Address (including city and (From/To) state) where child lived 9/10/04 85 Regency Woods North, (Birth) to Carlisle, PA 17015 Present Name and present address Relationship person child lived with to child Charles Brian Reinard, 85 Father and Regency Woods North, Carlisle, Mother until PA 17015 and separation, Angela Marie Group, 114 Amy then remained Drive Carlisle, PA 17013 with Father at this address. 7. I HAVE NOT participated as a party, witness, or in any capacity in any other litigation or custody proceeding in this or any other state, concerning custody of a child subject to this proceeding. 8. I HAVE NO INFORMATION of any custody proceeding pending in a court of this or any other state concerning a child subject to this proceeding. 9. I DO NOT KNOW OF ANY PERSON not a party to this proceeding who has physical custody or claims to have custody or visitation rights with respect to any child subject to this proceeding. 10. I acknowledge that I have a continuing duty to advise this Court of any custody, visitation, child support, or guardianship proceeding (including dissolution of marriage separate maintenance, child neglect, or dependency) concerning the child(ren) in this state or any other state about which information is obtained during this proceeding. CERTIFICATE OF SERVICE I HEREBY CERTIFY, a true and correct copy of the foregoing has been furnished by special process server or sheriff of this county to ANGELA MARIE GROUP, residing at 114 Amy Drive Carlisle, PA 17013 this day of January 2008. arles Brian Reinard 85 Regency Woods North Carlisle, PA 17015 (717) 525-2272 Plaintiff/ Pro Se ?? 4 -? ? c? '?l ?rr?r A ? ? ? 9r ? ;? ? -- o ?,?_. ? '' r? :?? a SHERIFF'S RETURN - REGULAR CASE NO: 2008-00661 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND REINARD CHARLES BRIAN VS GROUP ANGELA MARIE KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - CUSTODY was served upon l^1 TlP TTn 'A MrN= T T/T 7T D TV the DEFENDANT , at 0852:00 HOURS, on the 5th day of February 2008 at 13 N HANOVER STREET CARLISLE, PA 17013 by handing to ANGELA M GROUP a true and attested copy of COMPLAINT - CUSTODY together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge all-110F 4 So Answers: ;- 18.00 r,/?srf i? ?'.,?-d' 4.80 .58 10.00 R. Thomas Kline .00 33.38 02/07/2008 CHARLES BRIAN REINARD Sworn and Subscibed to before me this of By. day A. D.