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HomeMy WebLinkAbout08-1918ROBERT L. BRYNER, SR. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW DAWN RINGEL, : No. 08 - 14 / ? CIVIL Defendant : IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Robert L: Bryner, Sr., residing at 12 Cooper Circle, Cumberland County, Carlisle, Pennsylvania 17015. 2. The defendant is Dawn Ringel, residing at 39 West Locust Street, Cumberland County, Mechanicsburg, Pennsylvania 17055. 3. Plaintiff seeks custody of the following children: Name Present Residence DOB Age Jennifer L. Bryner 12 Cooper Circle 3/15/05 3 years Carlisle, PA The child was born out of wedlock The child is presently in the custody of Robert L. Bryner, Sr., who resides at 12 Cooper Circle, Cumberland County, Carlisle, Pennsylvania. During the past five years, the child has resided with the following persons and at the following addresses: All Persons All Addresses Dates Dawn Ringel 111 Chapel Avenue 3/15/05-7/15/05 Carlisle, PA Dawn Ringel 11 Cooper Circle 7/16/05-3/1/06 Carlisle, PA Robert L. Bryner, Sr. 10 W. Locust Street 3/1/06-6/1/07 Mechanicsburg, PA Robert L. Bryner, Sr. 12 Cooper Circle 6/1/07-Present Carlisle, PA The mother of the child is Dawn Ringel, currently residing at 39 West Locust Street, Mechanicsburg, PA. 4. She is unmarried. The father of the child is Robert L Bryner, Sr., currently residing at 12 Cooper Circle, Carlisle, PA. He is married. The relationship of plaintiff to the child is that of Father. The plaintiff currently resides with the following persons. Name Barbara Bryner Jennifer Bryner Relationship Wife Daughter The relationship of defendant to the child is that of Mother. The defendant currently resides with the following persons. Name Jeff Witmer Lynn DiOrio Mike DiOrio Hans DiOrio Relationship Boyfriend Daughter Son Son 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. The court, term, and number, and its relationship to this action is: Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceeding that has claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief request because: Plaintiff has undertaken and performed the primary parental responsibilities for the child. Plaintiff is best able to provide the care and nurture which the children need for healthy development. Plaintiff desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the children. A Court ordered determination of custody is required to avoid continuing conflict between the parties regarding parental responsibility for custody and support. 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: Name N/A - Address MIA Basis of Claim N/A WHEREFORE, Plaintiff requests this Court grant Plaintiff, Robert L. Bryner, Sr. primary physical custody with agreed upon visitation in Defendant, Dawn Ringel. Respectfully submitted, ROMINGER & ASSOCIATES Date:_a$ hael O. Palermo, Jr., Esqu 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID #93334 Attorney for Plaintiff VERIFICATION 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. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Date: aI (Z- Ro ert L. Bryner, Sr., Pla' ff t :7-7 Q - i r7 T d. j C?1 ?. Z ROBERT L. BRYNER, SR. IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-1918 CIVIL ACTION LAW DAWN RINGEL IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, March 28, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland Coun Courthouse, Carlisle on Monday, April 28, 2008 at 9:30 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/ ac ueline M. Verne Es Custody Conciliator ye__ 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 'T, 4v /'--r r. ?-" iI 3 :r i ?a-1 So-r-11 MAY 1 4 200848 ROBERT L. BRYNER, SR., Plaintiff V. DAWN RINGEL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008-1918 : IN CUSTODY ORDER OF COURT CIVIL ACTION - LAW AND NOW, this 4t?day of ? , 2008, upon consideration of the attached Custody Conciliation eport, it is ordered and directed as follo\?S: I . The Father, Robert L. Bryner, Sr. and the Mother, Dawn Ringel, shall hay c ,hared legal custody of Jennifer L. Bryner, born March 15, 2005. Each parent shall lim c an equal right, to be exercised jointly with the other parent, to make all major non- emer1_1cncy decisions affecting the Child's general well-being including, but not limited to. all decisions regarding her 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 child including, but not limited to medical, dental, religious or school records, the residence address of the child and 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. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and ev aluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certi l icates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with rcgar?l to school pictures, extracurricular activities, children's parties, musical prese»tations, back-to-school nights, and the like. Father shall have primary physical custody of the child. I. Mother shall have periods of partial physical custody every Tuesday and I'ndav Crom 9:30 a.m. to 6:00 p.m. 4. The parties shall have liberal telephone contact with the child. Transportation shall be shared such that the receiving party shall transport. A 6. 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. Counsel for tihc parties may contact the Conciliator for a telephone conference prior to the next ContCrcnce. Another Custody Conciliation Conference is scheduled for August 18, 2008 at 9:30 a.m. BY cc:?'lichael O. Palermo, Jr., Esquire, Counsel for Father ?(rrace D'Alo, Esquire, Mid Penn Legal Services, Counsel for Mother SAt I D$ J. R013ERT L. BRYNER, SR., Plaintiff V. D NN N RINGEL, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-1918 CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following rchort: 1. The pertinent information concerning the Child who is the subject of this liti,-,ation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jennil-er L. Bryner March 15, 2005 Father 2. A Conciliation Conference was held in this matter on May 13, 2008, with fl-ic li)llowing in attendance: The Father, Robert L. Bryner, Sr., with his counsel, Michael O. Palermo, Jr., Esquire, and the Mother, Dawn Ringel, with her counsel, Grace D'Alo, Ea(luire, MidPenn Legal Services. 3. The parties agreed to an Order in the form as attached. '' -o Fl S-?3 Dale heacline M. Verney, Esquire Custody Conciliator AM, 2 0 2008 ROBERT L. BRYNER, SR., Plaintiff V. DAWN RINGEL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008-1918 CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this eda of 4"4_? '2008y ,upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The prior Order of Court dated May 21, 2008 is hereby vacated. 2. Father, Robert L. Bryner, Sr. and the Mother, Dawn Ringel, shall have shared legal custody of Jennifer L. Bryner, born March 15, 2005. 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 her 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 child including, but not limited to medical, dental, religious or school records, the residence address of the child and 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. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 3. Father shall have primary physical custody of the child. 4. Mother shall have periods of partial physical custody every Tuesday and Friday for two hours at times agreed by the parties and such other times as the parties may agree. 5. The parties shall have liberal telephone contact with the child. 3 6. Transportation shall be shared such that the receiving party shall transport. 7. The child shall have no contact with Dwayne Welker or Tonya Witmer. 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. The parties or their counsel may contact the Conciliator for a telephone conference within ninety days from the date of this Order. BY THE Edward E. Guido, J. cc/frobert L. Bryner, Sr., pro se 12 Cooper Circle Carlisle, PA 17015 race D'Alo, Esquire, Mid Penn Legal Services, Counsel for Mother 4 ...? AiINn AUG 2 0 2008 ox ROBERT L. BRYNER, SR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-1918 CIVIL ACTION - LAW DAWN RINGEL, . Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jennifer L. Bryner March 15, 2005 Father 2. A Conciliation Conference was held in this matter on August 18, 2008, with the following in attendance: The Father, Robert L. Bryner, Sr., pro se, and the Mother, Dawn Ringel, with her counsel, Grace D'Alo, Esquire, MidPenn Legal Services. 3. The Honorable Edward E. Guido entered an Order of Court dated May 21, 2008 providing for shared legal custody, Father having primary physical custody and Mother having periods of partial physical custody on Tuesdays and Fridays. 4. The parties agreed to an Order in the form as attached. k-19-OS Date LA? I/ ac eline M. Verney, Esquire Custody Conciliator FIL , - OF TNc n'rrT ROBERT L. BRYNER, SR. RAE COURT OF COMMON PLEAS OF Plaintiff Z??d JA 13 F11 §. T BERLAND COUNTY, PENNSYLVANIA ,CIVIL ACTION - LAW DAWN RINGEL, : No. 08 - 1918 CIVIL Defendant : IN CUSTODY PI'll r o i PETITION TO MODIFY CUSTODY crn? 1. The plaintiff is Robert L. Bryner, Sr., residing at 12 Cooper Circle, Cumberlai -(County, Carlisle, Pennsylvania 17015. > C W 2. The defendant is Dawn Ringel, with an address of P.O. Box 384, Mechanicsburg,' Pennsylvania 17055. 3. Plaintiff seeks to modify the Order regarding custody of the following child: Name Present Residence DOB Age Jennifer L. Bryner 4 5 12 Cooper Circle 3/15/05 3 years Carlisle, PA The child was born out of wedlock The child is presently in the custody of Robert L. Bryner, Sr., who resides at 12 Cooper Circle, Cumberland County, Carlisle, Pennsylvania. On or about May 21, 2008, the Honorable Edward E. Guido entered a Custody Order. Attached as Exhibit "A". Since the entry of said Order, there has been a significant change in circumstances in that: (a) Mother has informed Father that she and her paramour are living in the residence of a man that is unknown to Petitioner. (b) Mother's paramour is living in a pull along trailer on the property of the before mentioned unknown man mother is residing with. (c) Mother routinely fails to appear for her scheduled custody visits; this resulting in further anguish for the child and feelings of abandonment. 70.00 ,t. 441 --2 3GG.? 6. The best interest of the children will be served by the Court in modifying said Order to suspend all partial custody with Mother until Mother can maintain her own residence and show a commitment to the child's' health, safety and welfare. WHEREFORE, Petitioner prays this Court to grant the modification of the custody with primary physical custody in Father with visitation in Mother as the parties can agree. Date; ?Respectfully submitted, ROMINGER & ASSOCIATES Michael O. Palermo, Jr., squire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 93334 Attorney for Plaintiff/Petitioner VERIFICATION I, Robert Bryner, verify that I am the Petitioner and that the statements made in the foregoing Petition to Modify are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to unworn falsification to authorities. Date: Robert Bryner, Petitioner R013F.RT 1.. BRYNER, SR., Plaintiff V. DAWN RINGEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008-1918 : IN CUSTODY ORDER OF COURT CIVIL ACTION - LAW AND NOW, this 21 day of 2008, upon consideration of the attached Custody Conciliation eport, it is ordered and directed as Follo"s: I . The Father, Robert L. Bryner, Sr. and the Mother, Dawn Ringel, shall lim c shared legal custody of Jennifer L. Bryner, born March 15, 2005. Each parent shall hay e 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. al I cecisions regarding her 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 child including, but not limited to medical, dental, religious or school records, the residence address of the child and 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 rccordk and information of reasonable use to the other parent. Both parents shall be em]tlecl to full participation in all educational and medical/treatment planning meetings and eValuations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certi l icates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. Father shall have primary physical custody of the child. . Mother shall have periods of partial physical custody every Tuesday and Frida\ from 9:30 a.m. to 6:00 p.m. 4. The parties shall have liberal telephone contact with the child. Transportation shall be shared such that the receiving party shall transport. 6. This Order is entered pursuant to an agreement of the parties at a Custody CoilclIiLitloll Conference. The parties may modify the provisions of this Order by mutual con,,cw. In the absence of mutual consent, the terms of this Order shall control. Counsel fur lh,_ h?u-ties may contact the Conciliator for a telephone conference prior to the next ConI'Crcncc. Another Custody Conciliation Conference is scheduled for August 18. 2008 at L1.111. BY J. cc: Michael O. Palermo, Jr., Esquire, Counsel for Father Grace D'Alo, Esquire, Mid Penn Legal Services, Counsel for Mother COP 1 her a16.- ,. s_ ? P ROIIERT L. BRYNER, SR., Plaintiff V. D A NN N RINGEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-1918 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following re h<'rt: 1. The pertinent information concerning the Child who is the subject of this limul,ition is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF ,Ie n n i fer L. Bryner March 15, 2005 Father 2. A Conciliation Conference was held in this matter on May 13, 2008, with fl-ic following in attendance: The Father, Robert L. Bryner, Sr., with his counsel, Michael 0. 11111ermo. Jr., Esquire, and the Mother, Dawn Ringel, with her counsel, Grace D'Alo, Esquire. MidPenn Legal Services. 3. The parties agreed to an Order in the form as attached. 5 ?l 3 -o fl Date V acheline MV Esquire Custody Conciliator ROBERT L. BRYNER, SR. IN THE COURT OF COMMON PLEAS OF' PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. DAWN RINGEL DEFENDANT 2008-1918 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, January 19, 2010 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday February. 11, 2010 at 9:30 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 hearinp,. FOR THE COURT, By: /s/ jacgueftne M. Verney, 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 FORTI I 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 ?? ?? ? ? ??? ,?: G ???p ?€?? r ? .__ ??? C'. w ? ?' °?r ,, ? ?o.1C? /?" jrs? /r?-c?C??' `„ ram„ !v 1.-?-?t ;,- ? ?; 0 ROBERT L. BRYNER, SR., : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 2008-1918 CIVIL ACTION - LAW DAWN RINGEL, IN CUSTODY Defendant PRAECIPE FOR ENTRY OF APPEARANCE To Curtis R. Long, Prothonotary: Please enter my appearance on behalf of the Defendant, Dawn Ringel, in the above captioned case. Respectfully submitted, Tessi a/Iolst, Esquire Mi enn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 Date: L, - D M ftl r 4 3 , r; 2s M '' Z f V • O o O cn W ROBERT L. BRYNER, SR., : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2008-1918 CIVIL ACTION - LAW DAWN RINGEL, IN CUSTODY Defendant CERTIFICATE OF SERVICE I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for the Defendant, Dawn Ringel, hereby certify that I have served a copy of the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following date and in the manner indicated below: U.S. First Class Mail, Postage Pre-Paid Michael O. Palermo, Jr., Esquire 155 South Hanover Street Carlisle, PA 17013 Date:') Ll - `u Jes4* Holst, Esquire Mi enn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 MAR 9lu)ti 3 ROBERT L. BRYNER, SR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-1918 CIVIL ACTION - LAW N DAWN RINGEL, awn Defendant : IN CUSTODY _ ORDER OF COURT 4-11 { ern AND NOW, this Rl? day of 1 , 2010, upc X- consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated August 25, 2010 is hereby vacated. 2. Father, Robert L. Bryner, Sr. and the Mother, Dawn Ringel, shall have shared legal custody of Jennifer L. Bryner, born March 15, 2005. 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 her 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 child including, but not limited to medical, dental, religious or school records, the residence address of the child and 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. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 3. Father shall have primary physical custody of the child. 4. Mother shall have periods of partial physical custody every Monday and Thursday from 4:30 p.m. to 6:30 p.m., except for the first Monday of every month. Instead of two hours on the first Monday of every month, Mother shall have partial physical custody of the child on the first Saturday of every month after the first Monday of every month from 9:00 a.m. to 1:00 p.m. 5. Mother shall forfeit her periods of partial physical custody if she is more than fifteen minutes late and fails to contact Father prior to her designated time for partial physical custody. 6. Holidays: A. Thanksgiving shall be alternated such that Mother shall have physical custody of the child from 10:00 a.m. to 6:00 p.m. in odd numbered years. B. Easter shall be alternated such that Mother shall have physical custody of the child from 10:00 a.m. to 6:00 p.m. in even numbered years. C. Christmas shall be shared such that Mother shall always have physical custody of the child on Christmas Day from 12:00 noon to 6:00 p.m. 7. The parties shall have liberal telephone contact with the child. 8. Transportation shall be shared such that the receiving party shall transport. However, Mother shall notify Father where to pick up the child at the conclusion of her period of custody when she picks up the child. In the event Mother does not have a pick up location, she shall be responsible for returning the child to Father's residence. 9. The child shall have no contact with Dwayne Welker or Tonya Witmer. 10. Neither party may take the child out of the state of Pennsylvania without written consent of the other parent or an Order of Court. 11. Mother is encouraged to obtain appropriate housing so that her periods of partial physical custody may take place in a home setting. 12. 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. BY Edward E. Guido, J. cc chael O. Palermo, Jr., Esquire, Counsel for Father Osica Holst, Esquire, Mid Penn Legal Services, Counsel for Mother t f 4y L U JV ROBERT L. BRYNER, SR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-1918 CIVIL ACTION - LAW DAWN RINGEL, Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jennifer L. Bryner March 15, 2005 Father 2. A Conciliation Conference was held in this matter on March 18, 2010, with the following in attendance: The Father, Robert L. Bryner, Sr., with his counsel Michael O. Palermo, Jr., Esquire and the Mother, Dawn Ringel, with her counsel, Jessica Holst, Esquire, MidPenn Legal Services. 3. The Honorable Edward E. Guido entered an Order of Court dated August 25, 2008 providing for shared legal custody, Father having primary physical custody and Mother having periods of partial physical custody, two hours every Tuesday and Friday. 4. The parties agreed to an Order in the form as attached. 3-19-/0 Date ac eline M. Verney, Esquire Custody Conciliator IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT L. BRYNER, SR. Plaintiff V. DAWN RINGEI., Defendant : CIVIL ACTION - LAW : No. 08 - 1918 - CUSTODY -a a -o = ? -n Z .- - i co 1 ?- Guido, J. PETITION TO MODIFY CUSTODY 1. The plaintiff is Robert L. Bryner, Sr., residing at 12 Cooper Circle, Cumberland County, Carlisle, Pennsylvania 17015. 2. The defendant is Dawn Ringel, whose physical address is unknown but receives her mail at P.O. Box 384, Cumberland County, Mechanicsburg, Pennsylvania 17055. 3. Plaintiff seeks to modify the Order regarding custody of the following child: Name Present Residence DOB Age Jennifer L. Bryner 12 Cooper Circle 3/15/05 f years Carlisle, PA The child was born out of wedlock The child is presently in the custody of Robert L. Bryner, Sr., who resides at 12 Cooper Circle, Cumberland County, Carlisle, Pennsylvania. 4. On or about March 22', 2010, the Honorable Edward Guido entered an Order following Conciliation in this matter. Attached as Exhibit "A". 5. Since the entry of said Order, there has been a significant change in circumstances in that: 1 Pursuant to Cumberland County Local Rule 208.3(a)(2) 7D•OD "l- 4 4? /O (a) Mother is without the resources to provide for visitation of the child as she is without gas money to come to visit the child or is without food money when she exercises her visitation with the child. (b) Mother and her paramour are living in a `pop-up' camper on the property of another individual. (c) Mother routinely fails to appear for her scheduled custody visits; this resulting in further anguish for the child and feelings of abandonment. (d) Mother has been given numerous opportunities to find suitable housing and has failed to do so, thereby resulting in periods of visitation that are brief and very uncomfortable for the child. 6. The best interest of the children will be served by the Court in modifying said Order to suspend all partial custody with Mother until Mother can maintain her own residence and show a commitment to the child's' health, safety and welfare. 7. Pursuant to Cumberland County Local Rule 208.3(a)(9), Ms. Ringel was contacted [as undersigned counsel was informed by Mid-Penn Legal Services that they no longer represented Ms. Ringel], and opposes the relief sought herein. WHEREFORE, Petitioner prays this Court to grant the modification of the custody with primary physical custody in Father with visitation in Mother as the parties can agree. Date:-- - 21 a-cq± -- Respectfully submitted, PALERMO AW OFFICES Michael O. Palermo, ., Esquire 17 W. South Street Carlisle, PA 17013 (717) 254-6986 Supreme Court ID # 93334 Attorney for Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT L. BRYNER, SR., Plaintiff V. DAWN RINGEL, Defendant CIVIL ACTION - LAW IN CUSTODY NO: 1918-2008 = Guido, J. VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing 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 R bert Bryner, ., Petitioner ° O MAR ROBERT L. BRYNER, SR., Plaintiff V. DAWN RINGEL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008-1918 CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this day of 2010, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The prior Order of Court dated August 25, 2010 is hereby vacated. 2. Father, Robert L. Bryner, Sr. and the Mother, Dawn Ringel, shall have shared legal custody of Jennifer L. Bryner, born March 15, 2005. 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 her 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 child including, but not limited to medical, dental, religious or school records, the residence address of the child and 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. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 3. Father shall have primary physical custody of the child. 4. Mother shall have periods of partial physical custody every Monday and Thursday from 4:30 p.m. to 6:30 p.m., except for the first Monday of every month. Instead of two hours on the first Monday of every month, Mother shall have partial physical custody of the child on the first Saturday of every month after the first Monday of every month from 9:00 a.m. to 1:00 p.m. D 5. Mother shall forfeit her periods of partial physical custody if she is more than fifteen minutes late and fails to contact Father prior to her designated time for partial physical custody. 6. Holidays: A. Thanksgiving shall be alternated such that Mother shall have physical custody of the child from 10:00 a.m. to 6:00 p.m. in odd numbered years. B. Easter shall be alternated such that Mother shall have physical custody of the child from 10:00 a.m. to 6:00 p.m. in even numbered years. C. Christmas shall be shared such that Mother shall always have physical custody of the child on Christmas Day from 12:00 noon to 6:00 p.m. The parties shall have liberal telephone contact with the child. 8. Transportation shall be shared such that the receiving party shall transport. However, Mother shall notify Father where to pick up the child at the conclusion of her period of custody when she picks up the child. In the event Mother does not have a pick up location, she shall be responsible for returning the child to Father's residence. 9. The child shall have no contact with Dwayne Welker or Tonya Witmer. 10. Neither party may take the child out of the state of Pennsylvania without written consent of the other parent or an Order of Court. 11. Mother is encouraged to obtain appropriate housing so that her periods of partial physical custody may take place in a home setting. 12. 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. BY THE COURT, TRUE COPY F Rom RECORD U lboft nq whwvd. I hm wft sit nV h" feed W_" sea of owl at OWN" Pi ?llU dwaf20.j, _ Edward t . Guido, J. yt,A) oc: Michael O. Palermo, Jr., Esquire, Counsel for Father Jessica.Holst, Esquire, Mid Penn Legal Services, Counsel for Mother ? cuju ROBERT L. BRYNER, SR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-1918 CIVIL ACTION - LAW DAWN RINGEL, Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jennifer L. Bryner March 15, 2005 Father 2. A Conciliation Conference was held in this matter on March 18, 2010, with the following in attendance: The Father, Robert L. Bryner, Sr., with his counsel Michael O. Palermo, Jr., Esquire and the Mother, Dawn Ringel, with her counsel, Jessica Holst, Esquire, MidPenn Legal Services. 3. The Honorable Edward E. Guido entered an Order of Court dated August 25, 2008 providing for shared legal custody, Father having primary physical custody and Mother having periods of partial physical custody, two hours every Tuesday and Friday. 4. The parties agreed to an Order in the form as attached. Date Jacqueline M. Verney, Esquire Custody Conciliator IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT L. BRYNER, SR. Plaintiff V. DAWN RINGEL, Defendant : CIVIL ACTION - LAW No. 08 - 1918 - CUSTODY Guido, J. CERTIFICATE OF SERVICE I, Michael O. Palermo, Jr., Esquire, do hereby certify that I caused a copy of this instant Petition to be served upon the Defendant herein by placing a copy of the same in the United States Mail, postage pre-paid, addressed as follows: Ms. Dawn Ringel P.O. Box 384 Mechanicsburg, PA 17055 SO CERT IED, Wk' it Michael O. Palermo, ROBERT BRYNER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V 2008-1918 CIVIL ACTION LAW 0 ?c 7 DAWN RINGEL LI)r- t ? IN CUSTODY ets ?? r- DEFENDANT ' °?= -"C:) ;. -D -T! ORDER OF COURT w :rte AND NOW, Wednesday, June 08, 2011 , upon consideration of the attached Co mplaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, July 12, 2011 at 1:30 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. 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/ ac ueline M. Verne 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 ,•eell ePy ^911a ?dpj tviled , v ?'Vj f rd l?ed iv Carlisle, Pennsylvania 17013 Oro Telephone (717) 249-3166 b/// Q 3 ROBERT L. BRYNER, SR., Plaintiff V. DAWN RINGEL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008-1918 : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. ORDER OF COURT CIVIL ACTION - LAW MW c .) AND NOW, this 1__4?_Aay of L ?4 / y , 2011, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A Hearing is sched ed in Court Room No. 3 , of the Cumberland County Court House, on the / 9*1 day of A u 6ujr , 2011, at _/: 00 o'clock, #07. M., at which time testimony will be taken. For purposes of this Hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least five days prior to the Hearing date. 2. The Order of Court of the Honorable Edward E. Guido dated March 22, 2010 is hereby vacated. 3. The Father, Robert L. Bryner, Sr. and the Mother, Dawn Ringel, shall have shared legal custody of Jennifer L. Bryner, born March 15, 2005. 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 her 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 child including, but not limited to medical, dental, religious or school records, the residence address of the child and 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. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 4. Father shall have primary physical custody of the child. 5. Mother shall have periods of partial physical custody of the child on alternating Saturdays or Sundays for four hours, provided Mother give Father one week notice of exercising her period of physical custody. 6. Mother shall have liberal telephone contact with the child. 7. Transportation shall be shared such that the parties shall meet at the Bedford Interchange of the Pennsylvania Turnpike. 8. 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. cc: Michael O. Palermo, Jr., Esquire, counsel for Father Dawn Ringel pro se f P.O. Box 384 Ma ?P,CC? Mechanicsburg, PA 17055 IR'll 0KB ROBERT L. BRYNER, SR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-1918 CIVIL ACTION - LAW DAWN RINGEL, Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jennifer L. Bryner March 15, 2005 Father 2. A Conciliation Conference was held July 12, 2011 with the following individuals in attendance: The Father, Robert L. Bryner, Sr., with his counsel, Michael O. Palermo, Jr., Esquire, and the Mother, Dawn Ringel, pro se, by telephone. 3. The Honorable Edward E. Guido previously entered an Order of Court dated March 22, 2010 providing for shared legal custody, Father having primary physical custody with Mother having two (2) hours, two (2) days each week. Father filed for modification alleging that Mother was not exercising her periods of partial physical custody. Subsequent to filing the Petition to Modify, Father relocated to the western part of the state. Counsel for Father has indicated that he will file a Petition to Relocate and asks that the Court consolidate this hearing with the Relocation hearing. 4. Father's position on custody is as follows: Father seeks shared legal custody and primary physical custody and permission to relocate with the child. Father suggests Mother have periods of partial physical custody on alternating Saturdays or Sundays for four hours, provided Mother gives him prior notice. The parties would meet at the Bedford Interchange of the Pennsylvania Turnpike. Father maintains that Mother did not exercise her previous periods of partial physical custody with the child and that Mother is homeless, currently living in a pop-up tent in a friend's back yard in Mechanicsburg. Father seeks permission to relocate to western part of the state where he has already found employment and has family support. 4. Mother's position on custody is as follows: Mother opposes the relocation and seeks shared legal custody and primary physical custody of the child. In the alternative she seeks to maintain the status quo. 5. The Conciliator recommends an Order in the form as attached scheduling a Hearing and modifying the current Order of Court to allow Mother to have periods of partial physical custody for four hours on alternating weekends and for the parties to meet at Bedford Interchange of the Pennsylvania Turnpike. It is expected that the hearing will require one-half day. Date ac eline M. Verney, Esquire Custody Conciliator R COUNTER-AFFIDAVIT REGARDING RELOCATION qA.; G7 This relocation involves the following child: `-<> rv .tea Name Age Date of Birth Address Jennifer Bryner 6 3/15/05 217 Cochran Street Dawson, PA 15428 I have received notice of the proposed relocation and: 1. I do not object to the relocation and I do not object to the modification of the custody order consistent with the proposal for the revised custody schedule as attached to the notice. 2. I do not object to the relocation, but I do object to modification of the custody order, and I request that a hearing be scheduled. a. prior to allowing the children to relocate. b. after the child relocates. 3. I do object to the relocation and I do object to the modification of the custody order, and I further request that a hearing be held on both matters prior to the relocation taking place. I understand that in addition to checking (2) or (3) above, I must also file this notice with the court in writing and serve it on the other party by certified mail, return receipt requested. If I fail to do so within thirty (30) days, of my receipt of the proposed relocation notice, I shall be foreclosed from objecting to the relocation. ?r 4 CD u -r? VERIFICATION REGARDING RELOCATION COUNTER-AFFIDAVIT I verify that the statements made in this Counter-davit 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. r Dawn Ringel, Defendant Date: U / - i - 07c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT L. BRYNER, SR. Plaintiff V. DAWN RINGEL, Defendant CIVIL ACTION - I.AW ;mow No. 08 - 1918 - CUSTODY fe' Guido, J. -- CONFIRMATION OF SERVICE I, Michael O. Palermo, Jr., Esquire, do hereby certify that on July 26, 2011, I served a true and correct copy of the NOTICE REGARDING RELOCATION in the above captioned matter upon the following by Certifibd Mail, return receipt requested, addressed as follows: Dawn Ringel P.O. Box 384 Mechanicsburg, P. Date: l? ¦ Oun0ft Son 1, t, wW 3. AMo ampkis ' ftM 4 N FieetrlaoW Ckwhow Y de0' . ¦ ft t VW none and aftese on the reverse as ;we em rdm the Owd ID YOU. ¦ Mph We and W lhs back of to =499os, ar 411M float N space Pon, a. 1. AM* Addessed to: D,wn e-k n e P.o . ('pox 3 8 ? Mechan<c.sbvr5 , PA 1 ?] oSS C' -i -Orn ?3 p v? CD X . 0 Ap m 0 Add? IL Phwoived by (PFJrksd C. Dale of DalMry D. w deMr4t , lien 1? 01Nes n Yes0 No 7,, ?W: :'°! C3 R g! iNr I _ rrWOU rt Receipt 1kx MwdwxrW D kamd and o C.O.D. 4. g @Mkftd D~ Xkba Fsq 0 Yes 2. ,wae 7010 1870 0002 0922 5895 p#avlowft m so isw P3 Fenn 11, February 2004 Do „W Retam ReoNpt 102US424A-1540 Respectfully submitted, PALERMO LAW OFFICES Michael O. Palermo Jr., Esquire Pa Supreme Court ID #93334 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA -� rM i^n ROBERT L. BRYNER, SR. : CIVIL ACTION - LAW , Plaintiff -<T'" C, V. : No. 08 - 1918 - CUSTODY c DAWN RINGEL, . Defendant : Guido,J. PETITION TO MODIFY CUSTODY/PUBLISH NOTICE 1. The plaintiff is Robert L. Bryner, Sr., residing at 217 Cochran Street, Dawson, Fayette County, Pennsylvania 15428. 2. Plaintiff's Mailing Address: P.O. Box 186, Dawson, PA 15428 3. The defendant is Dawn Ringel, whose physical address is unknown but has a last known mailing address at P.O. Box 384, Mechanicsburg, Pennsylvania 17055. 4. Plaintiff seeks to modify the Order regarding custody of the following child: Name Present Residence DOB Age Jennifer L. Bryner 217 Cochran Street 3115105 8 years Dawson, PA The child was born out of wedlock 5. The child is presently in the custody of Robert L. Bryner, Sr., who resides at 217 Cochran Street, Dawson, Fayette County, Pennsylvania 15428. 6. On August 19, 2011, the Honorable Edward Guido entered an Order following a hearing in this matter. Attached as Exhibit "A". 1 Pursuant to Cumberland County Local Rule 208 3(a)(2) V 3•nn ,,W. Q '614 1b >� 7. Since the entry of said Order, there has been a significant change in circumstances in that: (a) Other than the original court ordered visitation where the Child was to attend a family wedding on Mother's side of the family in 2011, the child has not had any other contact with Mother. (b) Mother has failed to exercise her partial periods of physical custody. (c) Mother has not exercised any telephonic contact with the child. 8. The best interest of the child will be served by the Court in modifying said Order to vest sole physical custody with Father and limiting Mother's custodial periods to those exercised only so much as the parties can agree. 9. Pursuant to Cumberland County Local Rule 208.3(a)(9), Ms. Ringel was contacted regarding the relief sought herein, however, Certified Mail sent to her last known mailing address supra, was returned marked "Box Closed". A copy of the returned mail is attached hereto as Exhibit B. WHEREFORE, Petitioner prays this Court to grant the modification of the custody Order at the above docket with sole physical custody in Father and visitation with Mother as the parties can agree. PERMISSION TO PUBLISH NOTICE OF CONCILIATION CONFERENCE 10. Previous paragraphs are incorporated as if fully set forth herein. 11. Pursuant to Pa.R.C.P. 1930.4(a)(3) service in Domestic Relations matters can be effectuated by Special Order of Court. 12. In the instant matter, Defendant's last known mailing address, a P.O. Box has been closed. There is no known address. 13. While the undersigned will continue using due diligence, including paid for searches of the U.S. Postal Service records, in the event an address cannot be located, permission is requested pursuant to 19 to publish in the Carlisle Sentinel and the Cumberland Bar journal at least two weeks prior to any Conciliation Conference occurring. 14. The undersigned shall file ProofofPublication with the Cumberland County Prothonotary upon publication of the same, but not more than five (5) days prior to the Conciliation Conference. Respectfully submitted, PALERMO LAW OFFICES Date: 14"A-13 Michael O. Pale ,Jr., Esquire 3300 Trindle Road Camp Hill, PA 17011 (717) 635-9591 Supreme Court ID # 93334 Attorney for Plaintiff/Petitioner ROBERT L. BRYNER, SR. , IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA n V. rnca DAWN RINGEL, CIVIL ACTION - LAW =rn -n C-1 -orn Defendant NO. 2008-1918 CIVIL TER (' r44 C3 0 IN RE: CUSTODY = -0 C:)-n C-J =C� Q ORDER OF COURT rc,)n NJ CO AND NOW, this 19th day of August, 2011, after hearing, all prior orders are vacated and replaced with the following: 1 . The Father, Robert L. Bryner, Sr. , and the Mother, Dawn Ringel, shall have shared legal custody of Jennifer L. Bryner, born March, 15, 2005. 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 her health, education, and religion. Pursuant to the terms of 23 Pa.C.S. Section 5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and 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 . Both parents shall be entitled to full participation in all educational and medical treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to, medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school Pictures, extracurricular activities, children' s parties, musical presentations, back-to-school nights, and the like. 2 . Father shall have primary physical custody of the child. Father's relocation to Fayette County, Pennsylvania, is approved. 3 . Mother shall have periods of partial physical custody of the child as follows: A. Every other Sunday from 11 : 00 a.m. until 3 :00 p.m. Said periods of partial physical custody shall be exercised in Bedford, Pennsylvania. The parties shall meet in the parking lot of Ed's Restaurant in Bedford, Pennsylvania, to effectuate the exchange. Father need only wait until noon for mother to show up. If she fails to show for a visit without good cause, we will consider modifying the order to have future visits in Fayette County. B. Mother may visit in Fayette County for up to four hours per day for up to three consecutive days any time she gives father seven days advance notice of her intention to do so. C. Such other times as the parties may agree. 4 . Transportation shall be at Father's expense for the periods of partial physical custody set forth in 3A above. Father shall reimburse mother in cash for her fuel and toll expenses at the conclusion of each visitation. Mother shall be responsible for transportation costs in connection with all other periods of partial custody. 5 . Mother shall have liberal telephone contact with the child. 6. We will consider expanding mother' s periods of partial physical custody once she has obtained suitable housing. 7 . Mother shall be entitled to an extra period of partial physical custody from noon until 6 :oo p-m. on September 17, 2011 . Father shall deliver the child to the location of mother's wedding and pick her up from that location. If said period of partial custody takes place, Father shall be given credit for his expenses, tolls, and gas such that he will not have to pay for the next two periods of partial custody that mother has under 3A above. 8 . This Court shall maintain jurisdiction. By the Court, Edward E. Guido, J. Michael O. Palermo, Jr. , Esquire For the Plaintiff ✓ Dawn Ringel P.O. Box 384 �QPIP.Sn` t' Mechanicsburg, PA 17055 S�a : lfh W-7,41191 Whfi U.S: T'AGE I Michael O.Palermo,Jr., Esq. P G tLL' Palermo Law Offices 13 � 3300 Trindle Road Camp Hill, Pennsylvania 17011 1 fill 111 rox�� � ! 7Cl3,2 3,64❑ Dt3CIQ 2827 483,3 i000 0004 11 SSS-zs t�05s ED Dawn Ringel P.U. Box 384 Mechanicsburg, PA 17055 w .. . CERTIFIED M� >a r ; y s , !i h'. � 'u#<.te .v tIF, AB E TC r6,"zw V, A r" 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT L. BRYNER, SR., CIVIL ACTION - LAW Plaintiff : IN CUSTODY V. = NO: 1918-2008 DAWN RINGEL, : Guido, J. Defendant VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing 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: Robert Bryner, S , etitioner ROBERT BRYNER IN THE COURT OF COMMON PLEAS OF c PLAINTIFF CUMBERLAND COUNTY, PENNSYLVAN -~=� . cn r" '�r•� V. 2008-1918 CIVIL ACTION LAW � �ca DAWN RINGEL IN CUSTODY - f DEFENDANT ORDER OF COURT AND NOW, Friday,April 12,2013 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M.Verney,Esq.,the conciliator, at 4th Floor,Cumberland County Courthouse,Carlisle on Wednesday,May 22,2013 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/ Jacqueline M. Verney, 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 32 South Bedford Street Carlisle, Pennsylvania 1.7013 Telephone (717)249-3166 i�c y i ROBERT L. BRYNER, SR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-1918 CIVIL ACTION - LA:YV !H� ' DAWN (RINGEL) WITMER, -< r Defendant : IN CUSTODY -<> CD ORDER OF COURT 7->C-) , AND NOW, this 14 day of /�� , 2013, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated August 19, 2011 shall remain in full force and effect with the following modifications. 2. Paragraph 3(A) and 4 of the prior Order is replaced with the following: Mother shall have periods of partial physical custody in Fayette County, Pennsylvania provided she give Father 2 weeks prior notice. Custody shall not exceed four hours in any given day. Mother is permitted to take the child away from Father's residence. 3. Mother shall continue to have liberal telephone contact with the child. 4. RELOCATION: No party shall be permitted to relocate the residence of the child which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation or the court approves the proposed relocation. A person proposing to relocate MUST comply with 23 Pa. C. S. § 5337. 5. 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. BY THE C , Edward E. Guido, J. cc: ichael O. Palermo Jr. Esquire Dawn Witmer, pro se 317 Hogestown Road Mechanicsburg, PA 17055 120P1 es Pbu f ROBERT L. BRYNER, SR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-1918 CIVIL ACTION - LAW DAWN (RINGEL)WITMER , Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido,J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jennifer L. Bryner March 15, 2005 Father 2. A Conciliation Conference was held in this matter on May 22, 2013, with the following in attendance: The Father, Robert L. Bryner, Sr., with his counsel Michael O. Palermo, Jr, Esquire and the Mother, Dawn (Ringel) Witmer, pro se. 3. The Honorable Edward E. Guido entered an Order of Court dated August 19, 2011 providing for shared legal custody, Father having primary physical custody and Mother having periods of partial physical custody in Bedford, Pennsylvania and Fayette County, Pennsylvania. 4. The parties agreed to an Order in the form as attached. 2Z-I 3 1/ s Date k1cquone M. Verney, Esquire Custody Conciliator