HomeMy WebLinkAbout01-6378TARA L. BILGER,
CORY L. REINEMAN,
Plaintiff
Defendant
: 1N THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: No. - 77 Go
: CIVIL ACTION LAW- IN CUSTODY
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in
the following pages, you must take action within twenty (20) days after this Complaint and Notice
are served, by entering a written appearance personally or by attorney and filing in writing with the
Court your defenses or objections to the claims set forth against you. You are warned that if you
fall to do so the case may proceed without you and a judgment may be entered against you by the
Court without further notice for any money claimed in the Complaint or for any other claim or
relief requested by the Plaintiff. You may lose money or property, or other fights important to you,
including child custody, or child visitation.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT
ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET
LEGAL HELP.
COURT ADMINISTRATOR, FOURTH FLOOR
Cumberland County Courthouse
One Courthouse Square
Carlisle, Pennsylvania 17013-3387
(717) 240-6200
Document #.. 216179.1
TARA L. BILGER,
CORY L. REINEMAN,
Plaintiff
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
No. Ol-
: CIVIL ACTION LAW- IN CUSTODY
AVISO PARA DEFENDER Y RECLAMAR DERECHOS
USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas
expuestas en las pgtginas siguientes, debe tomar acci6n con prontimd. Se le avisa que si no se
defiende, el caso puede proceder sin usted y decreto de divorcio o anulamiento puede ser emitido en
su contra por la Corte. Una decisi6n puede tambi6n ser emitida en su contra por cualquier otto queja
o compensaci6n reclamados por el demandante. Usted puede perder dinero, o propiedades u otros
derechos importantes para usted.
Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio,
usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales estfi disponible en
la oficina del Prothontary, en la Dauphin County Court of Common Pleas, Front and Market Streets,
Harrisburg, Pennsylvania.
SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL,
HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE
DIVORCIO O ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A
RECLAMAR CUALQUIERA DE ELLOS.
USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO
TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA
ABA JO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL.
COURT ADMINISTRATOR, FOURTH FLOOR
Cumberland County Courthouse
One Courthouse Square
Carlisle, Pennsylvania 17013-3387
(717) 240-6200
Document #: 219183.1
TARA L. BILGER,
CORY L. REINEMAN,
Plaintiff
Defendant
1N THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. d:)l - l 39av o
CIVIL ACTION LAW - IN CUSTODY
COMPLAINT IN CUSTODY
AND NOW, this ~_ day of November, 2001, comes the Plaintiff, Tara Bilger, by her
attorney, Steven C. Courmey, Esquire and Metzger Wickersham Knauss & Erb, P.C. and files the
within Complaint for Custody:
1. The Plaintiff is Tara Bilger, an adult individual currently residing at 318 E.
Garfield Street, Shippensburg, Cumberland County, Pennsylvania 17257.
2. The Defendant is Cory L. Reineman, an adult individual whose current address is
1084 Mayapple Drive, Shippensburg, Cumberland County, Pennsylvania 17257.
3. The Plaintiff and Defendant are not married.
4. Plaintiff seeks primary legal and physical custody of the minor child:
Name Present Address D.O.B.
Gage Andrew Reineman 11/21/96
With Plaintiff and
Defendant
Plaintiff and Defendant are the natural parents of the above mentioned minor child.
The minor child was not born out of wedlock.
5. The minor child is presently in the shared custody of Plaintiff and Defendant on a
week on and a week off basis.
Document #.- 219183.1
During the past five (5) months, the minor child has resided with the following persons at
the following addresses:
Name
Tara Bilger
Mother
Cory L. Reineman
Father
Address
318 E. Garfield Street
Shippensburg, PA 17257
1084 Mayapple Drive
Shippensburg, PA 17257
Date
2/01 to date
Apprx. 1997 to date
Relationship
Husband
7. The relationship of Defendant to the child is that of natural father. The
Defendant currently resides with the following persons:
Name Relationship
Self
8. Plaintiff has not participated as a party or witness, or in any other capacity in any
other litigation concerning the custody of the children in this or another Court.
Plaintiff has no information of a custody proceeding concerning the child pending in a
Court of this Commonwealth.
Plaintiff does not know ora person not a party to the proceedings who has physical
Document #: 219183. l
currently resides with the following persons:
Name
Wayne Bilger
The father of the child is Defendant who resides at 1084 Mayapple Drive, Shippensburg
Pennsylvania 17257. The mother of the minor child is Plaintiff, who resides at 318 E. Garfield
Street, Shippensburg, Pennsylvania 17257.
6. The relationship of Plaintiff to the child is that of natural mother. The Plaintiff
custody of the minor child or claims to have custody or visitation with respect to the minor child.
9. Pursuant to the parties' Property Settlement Agreement, the parties agreed to share
legal and physical custody of their son, Gage Andrew Reineman. The arrangement provided that
each parent's period of physical custody would run during alternating seven (7) day periods
commencing each Friday at those times mutually agreed upon by the parties. During the
custodial parent's week, the non custodial parent may have one (1) day of evening period of
visitation with the child.
10. The best interest and permanent welfare of the minor child will be served by
granting the relief requested because:
a. Plaintiff, Tara Bilger, is in the best position, both financially and
emotionally, to provide stability and custody for the minor child.
b. Plaintiff is in the best position to provide a stable, responsible
environment for the raising of the minor child.
c. Plaintiff is more stable, more capable of providing the proper parental
care, and can better provide for the physical and emotional needs of the
minor child.
d. Plaintiff has been the primmy caretaker of the minor child since his birth.
e. Plaintiff is not employed and can care for the child while the Defendant is
at work whereby alleviating the need for daycare.
11. Each parent whose parental rights to the minor child has not been
terminated and the person who has physical custody of the minor child has been named as parties
to this action.
Document #: 219183.1
WHEREFORE, Plaintiff, Tara Bilger, requests the Court to grant her prima~ physical
and legal custody of the minor child.
Dated:
METZGER,~AUSS & ERB, P.C.
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorneys for Plaintiff
Document #: 219183~1
VERIFICATION
I verify that the statements made in the foregoing COMPLAINT IN CUSTODY are true
and correct to the best of my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn
falsification to authorities.
Tara L. Bilger
Document #.. 219183,1
CERTIFICATE OF SERVICE
I, Steven C. Courtney, Esquire, of the law firm ofMetzger, Wickersham, Knauss & Erb, P.C.,
hereby certify that I served a true and exact copy of Complaint for Custody with reference to the
foregoing action by first class mail, postage prepaid this~/1~)
day of November, 2001, on the following:
Cory L. Reineman (via certified mail)
1084 Mayapple Drive
Shippensburg, PA 17257
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Stex, en
Document #: 219183.1
'['ARA L. BII,GER
PI.AINTII+
CORY L. REINEMAN
I) EI:ENI)ANT
IN THE ('OURT OF COMMON PI,F, AS OF
(,UMBERI,AN] ('OUNI'Y~ PIiNNSYI,VANIA
01-6378 CIVII, AC I'ION
IN( [ SI OI)'~
ORDER OF COI!RT
AND NOW, Wednesday, November 21, 2001 , upon consideration of the attached ( omplaint,
it is hereby directed that parties and their respectixe counsel appear befi>rc _~n S. Sui29~~ [Sfl.~ thc conciliator,
at 39 West ¢~ain Strce~' M~chanicsburg,~A
tbr a Pre-llearing Cuslody Contkrcncc. At such conl~rencc, an eltra1 ~xill be made to resolve the issues in dispute; or
if this cmmot bc accomplishcd, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age live or okler may also bc presen~at the conference. Failure to appcar at the conference may
provide grounds fi)r cntry ufa temporary or permanent order.
The conrt hereby directs ~he parties in furnish any ami all existing Protection tkom Abuse orders,
Special Relief orders, and Custody orders ~o ihe conciliatnr 48 ho~rs prior to scheduled heariug.
FOR TIt
By: _(st .... Daw~.t S_.~unday,,.Esq? '~, '~_ \ .......
Cuslody Cnnciliator
The Court of Common }'leas of ( umberhmd County is required by law to comply with the Americans
with Disabilites Act of 1990. For infommtion about accessible facililies and reasonable accommodations
available to disabled individuals having busi:ness before the court, please contact our ol~fice. All arrangements
must be made at lcast 72 hours prior to m~y hum-rog or business before the court. You rnnst atlond the
scheduled conl'crcnce or hearing.
YOU SHOULD TAKF~ 'Ellis PAPER TO Yt)UR ATTORNEY AT ON£E. 1F YOU DO NOT
ttAVI'; AN ATI'ORNEY OR CANNOT AFFORD ONF,, GO TO OP, ~1 ELEPHONF, THt:; OFFICE SET
I,'ORTtt BEI,OW TO FIND OUI WIlE[hE YOU CAN GET I,EGAI, HELP.
Cumberland County Bar Association
2 I,iberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
TARA L. BILGER,
CORY L. REINEMAN,
Plaintiff
Defendant
: 1N THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: No. 01-6378
:
: CIVIL ACTION LAW - IN CUSTODY
AFFIDAVIT OF SERVICE
I, Steven C. Courtney, counsel for Plaintiff, hereby certify that a tree and correct
copy of the Complaint for Custody and Order was served upon the following, by certified mail,
return receipt and regular mail on November 28, 2001.
Cory L. Reineman
1084 Mayapple Drive
Shippensburg, PA 17257
Date:
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Steven C. Courtney, Esquire
I.D. No. 74669
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Plaintiff
Document #: 221590.1
TARA L. BILGER,
CORY L. REINEMAN,
Plaintiff
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: No. 01-6378
:
: CIVIL ACTION LAW - IN CUSTODY
AFFIDAVIT OF SERVICE
I, Steven C. Courmey, counsel for Plaintiff, hereby certify that a tree and correct
copy of the Order of the Court and Complaint for Custody was served upon the following, by
certified mail, return receipt and regular mail on December 6, 2001.
Cory L. Reineman
1084 Mayapple Drive
Shippensburg, PA 17257
Date: December 13, 2001
METZGER, W~CKE~USS & ERB, P.C.
I.D. No. 74669
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Plaintiff
Document #: 222790.1
· Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delive~ is desired.
· Print your name and address on the reverse
so that we can return the card to you.
· Attach this card to the back of the mailpiane,
[] ~ddressee
1 item 17 Oyes
If YES, enter delive~ address below: [] No
[] Insured Mail [] C.O.D.
PS Form 3811, July 1999 Domestic Return Receipt
[] Express Mail
{~l~m Receipt for MemhandiSe
TARA L. BILGER,
Plaintiff
VS.
CORY L. KEINEMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-6378 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this ~1~ day of ~ ., 2002,
upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The parties shall engage in a minimum of 6 counseling sessions (unless released earlier by
the counselor) with a professional to be selected by agreement of the parties and counsel. The purpose
of the counseling shall be to assist the parties in establishing sufficient communication and cooperation
to enable them to effectively co-parent their Child. The parties shall follow the recommendations of
the counselor with respect to the frequency of the sessions and the involvement, if necessary, of third
parties in the counseling. All costs of counseling which are not reimbursed by insurance coverage
shall be shared equally between the parties. The parties shall select and contact the counselor within
10 days of the date of the Custody Conciliation Conference to schedule the first counseling session.
2. The Father, Cory L. Reineman, and the Mother, Tara L. Bilger, shall have shared legal
custody of Gage Andrew Reineman, bom November 21, 1996. Each parent shall have an equal right,
to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the
Child's general well-being including, but not limited to, all decisions regarding his health, education
and religion. Both parties shall have equal access to all records pertaining to the Child, including
medical and school records.
3. The parties shall share having physical custody of the Child on an alternating weekly basis
as follows:
A. Beginning Friday, March 8, 2002, and continuing on alternating weeks thereafter,
the Mother shall have custody from Friday morning before the Father goes to work through the
following Friday between 5:30 p.m. and 6:00 p.m., when the Father is off work. During the
Mother's custodial weeks, the Father shall have a period of custody with the Child from
Tuesday after work through Wednesday morning before work.
B. Beginning Friday, March 15, 2002, and continuing on alternating weeks thereafter,
the Father shall have custody from Friday after work through the following Friday morning
before work. During the Father's custodial weeks, the Mother shall have custody on Monday
through Wednesday mornings when the Father shall transport the Child to the Mother's
residence before work, until the beginning of the Head Start Program to which the Mother shall
transport the Child. In addition, the Mother shall have custody from Wednesday after Head
Start through Thursday, when the Mother shall transport the Child back to the Head Start
Program.
4. The parties shall share having custody of the Child on holidays as follows:
A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which
shall nm from Christmas Eve at 2:00 p.m. through Christmas Day at 2:00 p.m., and Segment B,
which shall nm from Christmas Day at 2:00 p.m. through December 26 at 2:00 p.m. The
Mother shall have custody of the Child during Segment A in even numbered years and during
Segment B in odd numbered years. The Father shall have custody of the Child during Segment
A in odd numbered years and during Segment B in even numbered years.
B. THANKSGIVING: The Thanksgiving holiday shall be divided into Segment A,
which shall nm from the Wednesday before Thanksgiving at 2:00 p.m. through Thanksgiving
Day at 2:00 p.m., and Segment B, which shall run from Thanksgiving Day at 2:00 p.m. through
the Friday after Thanksgiving at 2:00 p.m. The Father shall have custody of the Child during
Segment A in even numbered years and during Segment B in odd numbered years. The Mother
shall have custody of the Child during Segment A in odd numbered years and during Segment
B in even numbered years.
C. EASTER: In every year, the Father shall have custody of the Child on Easter
Sunday from 8:30 a.m. until 12:30 p.m., and the Mother shall have custody from 12:30 p.m.
until 6:00 p.m.
D. MOTHER'S DAY/FATHER'S DAY: The Mother shall have custody of the Child
every year on Mother's Day and the Father shall have custody of the Child every year on
Father's Day with the specific times for exchanges to be arranged by agreement of the parties.
E. MEMORIAL DAY: The Mother shall have custody of the Child every year over
the Memorial Day holiday with the times to be arranged by agreement of the parties.
F. JULY 4T': The Father shall have custody of the Child every year over the July 4th
holiday with the specific times to be arranged by agreement of the parties.
G. The holiday custody schedule shall supersede and take precedence over the regular
custody schedule.
5. Each party shall be entitled to have custody of the Child for up to 2 non-consecutive weeks
each summer for vacation upon providing at least 30 days advance notice to the other party. Each
party shall schedule vacation periods of custody to include his or her regular weekend periods of
custody. The party providing notice first of a selection of vacation dates under this provision shall be
entitled to preference on his or her selection.
6. In the event either party intends to remove the Child fi:om his or her residence for an
overnight period or longer, that party shall provide advance notice to the other party of the address and
telephone number where the Child can be contacted.
7. Neither party shall do or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natural development of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
8. This Order is entered pursuant to an agreement of the parties at 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.
c¢;~.Sf~ven C. Courtney, Esquire - Counsel for Mother
~l~arylou Matas, Esquire - Counsel for Father
TARA L. BILGER,
Plaintiff
VS.
CORY L. REINEMAN,
Defendant
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-6378 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
follows:
NAME
Gage Andrew Reineman
CIVIL
The pertinent information concerning the Child who is the subject of this litigation is as
DATE OF BIRTH
November 21, 1996
CURRENTLY IN CUSTODY OF
Mother/Father
2. A Conciliation Conference was held on March 5, 2002, with the following individuals in
attendance: The Mother, Tara L. Bilger, with her counsel, Steven C. Courtney, Esquire, and the
Father, Cory L. Reineman, with his counsel, Marylou Matas, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Date
Dawn S. Sunday, Esquire~f
Custody Conciliator
TARA L. BILGER,
CORY L. REINEMAN,
Plaintiff
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: No. 01-6378
:
: CIVIL ACTION LAW- IN CUSTODY
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in
the following pages, you must take action within twenty (20) days after this Complaint and Notice
are served, by entering a written appearance personally or by attorney and filing in writing with the
Court your defenses or objections to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
Court without further notice for any money claimed in the Complaint or for any other claim or
relief requested by the Plaintiff. You may lose money or property, or other rights important to you,
including child custody, or child visitation.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT
ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET
LEGAL HELP.
COURT ADMINISTRATOR, FOURTH FLOOR
Cumberland County Courthouse
One Courthouse Square
Carlisle, Pennsylvania 17013-3387
(717) 240-6200
Document #: 234846.1
TARA L. BILGER,
CORY L. REINEMAN,
Plaintiff
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
..
..
: No. 01-6378
:
: CIVIL ACTION LAW- IN CUSTODY
AVISO PARA DEFENDER Y RECLAMAR DERECHOS
USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas
expuestas en las pfiginas siguientes, debe romar acci6n con prontimd. Se le avisa que si no se
defiende, el caso puede proceder sin usted y decreto de divorcio o anulamiento puede ser emitido en
su contra por la Cone. Una decisi6n puede tambi6n ser emitida en su contra por cualquier otra queja
o compensaci6n reclamados por el demandante. Usted puede perder dinero, o propiedades u otros
derechos importantes para usted.
Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio,
usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales estfi disponible en
la oficina del Prothontary, en la Dauphin County Court of Common Pleas, Front and Market Streets,
Harrisburg, Pennsylvania.
SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL,
HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE
DIVORCIO O ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A
RECLAMAR CUALQUIERA DE ELLOS.
USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO
TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA
ABA JO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL.
COURT ADMINISTRATOR, FOURTH FLOOR
Cumberland County Courthouse
One Courthouse Square
Carlisle, Pennsylvania 17013-3387
(717) 240-6200
Document #: 234846.1
TARA L. BILGER,
Vo
CORY L. REINEMAN,
Plaintiff
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
..
._
: No. 01-6378
:
: CIVIL ACTION LAW- IN CUSTODY
Order in that:
PETITION TO MODIFY CUSTODY ORDER
AND NOW, this 1_~ .~. day of~, 2002, comes the Plaintiff, Tara Bilger, by
her attorney, Melissa L. Van Eck, Esquire and Metzger Wickersham Knauss & Erb, P.C. and
files the within Petition to Modify:
1. Petitioner is Tara Bilger, natural mother of one minor child, Gage Andrew
Reineman (d.o.b. 11/21/96).
2. Respondent is Cory L. Reineman, natural father of one minor child, Gage Andrew
Reineman (d.o.b. 11/21/96).
3. On March 12, 2002, a Custody Order was entered providing for the custody of the
minor child. A tree and correct copy of the Custody Order is attached hereto and incorporated
herein and marked as Exhibit "A".
The best interest of the minor child would be served by the Court modifying the
ao
bo
Document #: 234846.1
Plaintiff, Tara Bilger, is in the best position, both financially and
emotionally, to provide stability and custody for the minor child.
Plaintiff is more stable, more capable of providing the proper parental
care, and can better provide for the physical and emotional needs of the
minor child.
Plaintiff has been the primary caretaker of the minor child since his birth.
d. Plaintiff is not employed and can care for the child while the Defendant is
at work whereby alleviating the need for daycare.
e. The minor child will be starting Kindergarten at Nancy Grayson
Elementary School in the fall and Plaintiff can provide a more stable
environment in providing the child's educational well being.
5. Mother respectfully requests that the Court Order by modified granting shared
legal custody, primary physical custody to Mother and partial physical custody to Father.
WHEREFORE, Petitioner, Tara Bilger, respectfully requests this Honorable Court to
grant the modification of the Custody Order as set forth above.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Dated:
Melissa L*. ;qan EcL Esquire
Attorney I.D. No. 85869
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorneys for Plaintiff
Document fl,: 234846.1
VERIFICATION
I verify that the statements made in the foregoing PETITION TO MODIFY CUSTODY
ORDER are tree and correct to the best of my knowledge, information and belief. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to
unswom falsification to authorities.
Tara L. Bilger
Document #: 234846.1
CERTIFICATE OF SERVICE
I, Melissa L. Van Eck, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C.,
hereby certify that I served a tree and exact copy of Petition to Modify Custody Order with reference to
the foregoing action by first class mail, postage prepaid this ~0r~tay of~~ 2002, on the
following:
Marylou Matas (via certified mail)
200 North Hanover Street
Carlisle, PA 17013
Attorney for Defendant
Cory L. Reineman
Date: June ~ ,2002
METZGER, WICKERSHAM, KNAUSS & ERB
Melissa IL. ;gan E~k; Esquire
Attorney Id. 85869
3211 North Front Street
PO Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Plaintiff
Tara L. Bilger
Document #: 234846.1
TARA L. BILGER :
:
PLAINTIFF
:
V.
IN THE cOURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-6378 CIVIL ACTION LAW
CARY L. REINEMAN
DEFENDANT : IN CUSTODY
AND NOW, Wednesday, June 12, 2002 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear bcfore Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Monday, July01,2002 at 1:00 PM
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 ora temporary or permanent order.
The court hereby directs the parties to furnish any and aH 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/
Damn S. Sunday. Esq.
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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
AUG 0
TARA L. BILGER,
Plaintiff
VS.
CARY L. REINEMAN,
Defendant
:IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANLA
:
: NO. 01-6378 CIVIL ACTION LAW
:
: IN CUSTODY
.ORDER OF COURT
AND NOW, this 31st day of July, 2002, the Conciliator, being advised by counsel that all
custody issues have been resolved by agreement, hereby relinquishes jurisdiction. The Custody
Conciliation Conference scheduled for August 6, 2002 is canceled.
FOR THE COURT,
Custody Conciliator
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