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HomeMy WebLinkAbout08-5495RANDY E. RAGER :IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V, :CIVIL ACTION -CUSTODY TAMMY A. RAGER NO. d?? s? 5 Gam ` f c-rn1 Defendant CUSTODY COMPLAUSTi 1. The Plaintiff is Randy E. Rager (hereinafter referred tp as "Father"), who currently resides at 29 East Locust Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Tammy A. Rager (hereinafter referred to as "Mother), who currently resides at 195 Beagle Club Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks shared legal and primary physical custody of the following child: NA PRESENT RESIDENCE DATE OF BIRTH Kailyn R. Rager 195 Beagle Club Road 05/09/2005 Carl 1ste, RA c@7013 4. The child is presently in the custody of Mother who is currently residing at 195 Beagle Club Road, Carlisle, Cumberland County, Pennsylvania. 5. During the past three years. The child has resided with the following persons at the following addresses: 05/09/2005 -08/2005 195 Beagle Club Road Carlisle, Pa 17013 NAMES OF PERSONS IN HOUSEHOLD Mother, Father, Brothers: Camren and Damen 08/2005-07/30/2006 11995 Beagle Club Road Mother, Father Brothers: Carl iSt e,, PA t1013 Camren and Damen and Step-Brother Joshua Taormina 07/31/2006-10/2006 779 Erford Road Mother, Father, Ellen Coleman Camp Hill, Pa 17011 Scott Coleman,Scott Fingerhoot Tyler Coleman., Drew Coleman, and Samantha Coleman 10/2006-01/31/2007 107 October Drive Mother, Father, Step-Brother Apt. 6 Joshua Taromina Camp Hill, Pa 17011 02/01/2007-05/2007 107 October Drive Mother, and Step-Brother Apt. 6 Joshua Taromina Camp Hill, Pa 17011 05/2007-08/2007 195 Beagle Club Road Carlisle, Pa 17013 08/2007-10/2007 195 Beagle Club Road Carlisle, Pa 17013 10/2007-01/2008 195 Beagle Club Road Carlisle, Pa 17013 Mother, Step-Brother Joshua Tammina, and Scott Coleman Mother and Scott Coleman Mother, Scott Coleman and Step-Brother Joshua Taromina 10/2008-Present 195 Beagle Club Road Mother and Scott Coleman 6. The Father of the child is Plaintiff who is currently residing at 29 East Locust Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 7. The Mother of the child is Defendant who is currently residing at 195 Beagle Club Road, Carlisle, Cumberland County, Pennsylvania, 17013. The parties are currently separated from each other. 8. The relationship of the Plaintiff to that of the children is that of Father. The Plaintiff currently resides with the following persons: NAME Randy E. Rager Ellen M. Coleman RELATIONSW Self Friend Tyler R. Coleman Friend's Son Drew M. Coleman Samantha Coleman Gino Coleman Julianna Coleman Friend's Son Friend's Daughter Friend's Son Friend's Daughter 9. The relationship of the Defendant to the child is Mother. The Defendant currently resides with the following persons: Scott Coleman 3A A-t l:i?11: Paramour 10. 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. 11. The Plaintiff has no information of a custody proceeding concerning this child pending in any court of this Commonwealth. 12. The best interests and permanent welfare of the child will be served by granting the relief requested because Plaintiff can provide a stable, loving, nurturing environment for the child. Defendant has a history of erratic behavior, instability and neglect and is not an appropriate role model for the child. 13. Each person in whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, the Plaintiff requests the Court to grant shared legal and primary custody of the child to the Plaintiff. Date: September 15, 2008 Randy E. Rager 29 East Locust Street Mechanicsburg, PA 17055 (717)635-0509 RANDY E. RAGER JN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - CUSTODY TAMMY A. RAGER :NO. Defendant VAC T? ION I, Randy E. Rager, hereby certify that the facts set forth in the foregoing CUSTODY COMPLAINT are true and correct to the best of my knowledge, information, and belief. I understand that any false statements made herein are subject to penalties of the 18 Pa. C.S.A. Section 4909 relating to unsworn falsification to authorities. DATED: < / ` D!/ e?z RANDY E. GER r? ?rn --? ti? ., r- ? _-? ? ? :-?,+£-?r? - a r- . „ ,. ,,... • .`.F -r -+*+.. RANDY E. RAGER Plaintiff V. TAMMY A. RAGER Defendant JN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNYSLVANIA :DOCKET NO. - Jr y S :CIVIL ACTION-LAW :IN CUSTODY MYE&TY AFFIDAVIT 1. I Randy E. Rager am the DEFENDANT in a divorce matter, and because of my financial condition I am unable to pay the fees and costs of prosecuting or defending this action or proceeding. 2. I am unable to obtain funds from anyone, including family and associates, to pay the costs of litigation. 3. 1 represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: Randy E. Rager Address: 29 East Locust Street Mechanicsburg, PA 17055 Social Security Number: 193-54-4274 EMPLOYMENT: (b) Employer: Kinderman's Auto Repair 2530 Walnut Street Harrisburg, PA 17104 % Salary or Wage per month: $1,800.00 Type of Work: Auto Mechanic Other income for the last 12 months: None ( c ) Cash: $20.00 Checking: -$700.00 Savings Account: $5.00 Motor Vehicle Make: None since totaled in accident in June of 2008 ( f ) Debts and Obligations: Rent: $450.00 Loans: $750.00 Child Support: $660.00 (Court Ordered) ( g ) Persons dependent upon me for support: Child: Kailyn R. Rager 3 4. I understand that I have a continuing obligation to inform the Court of improvements in my financial circumstances which would permit to pay the costs incurred herein. 5. I verify that the statements in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa C.S.A. 4909 relating to unsworn falsification to authorities. Date: ?? Petitioner: 1 C rte; m rn t -p ?l co SFP 17 2008 RANDY E. RAGER JN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY PENNSYLVANIA V. :CIVIL ACTION-LAW :1N CUSTODY TAMMY A. RAGER :DOCKET NO. g- S??9S Defendant ORDER AND NOW this 5 ` day of ,2008, upon consideration of the foregoing 'a,eu 1C*0 Petition it is o e mg ee m fir: BY THE COURT: ,c. /, OZ ;g MV ZZ d3S 8001 3Hl ICJ K) ?3 3 1 H RANDY E. RAGER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. TAMMY A. RAGER DEFENDANT 2008-5495 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, February 03, 2009 , 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 Monday, March 02, 2009 at 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/ ac ueline M. Verne Es q, jkA Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street 'Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 wirv -71 ,t,S„Nri? h o :1 Wd t- 93? filet 9W 341 -jo 00 MAR 2 3 200, RANDY E. RAGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-5495 CIVIL ACTION - LAW TAMMY A. RAGER, Defendant : IN CUSTODY TEMPORARY ORDER OF COURT AND NOW, this 2 y' day of , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. Mother, Tammy A. Rager shall have sole legal custody of Kailyn R. Rager, born May 9, 2005. Mother shall provide all information concerning the child's medical, educational and religious matter to Father in a timely matter. 2. Mother shall have primary physical custody of the child. 3. Father shall have supervised visitation with the child in a therapeutic setting. Mother shall arrange to have therapeutic family counseling for the child and Father. There shall be at least 6 family counseling sessions. Visitation may be extended if the counselor recommends additional time and whether they need to be supervised. Father shall sign a release with his individual counselor so that the family counselor may have access to Father's records. Father shall also provide a letter to opposing counsel from his counselor indicating the extent of his counseling. 4. Father shall have liberal telephone contact with the child. 5. Neither party may consume alcohol to the point of intoxication or use illegal drugs immediately prior to or during their period of contact with the child. The parties shall insure that third parties abide by this provision to the extent possible. In no event shall the child be transported in a vehicle while the driver is under the influence of alcohol or illegal drugs. 6. Kailyn shall have no contact with Ellen Coleman. 7. Father is specifically restricted from having in his possession any gun while he is in contact with the child. `1 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 y ? $??i?^IV ? t F ? n . ?aza6i ?? ?? -1113 consent. In the absence of mutual consent, the terms of this Order shall control. Another Custody Conciliation Conference is scheduled for June 19, 2009 at 8:30 a.m. BY THE COURT, J. ccdy E. Rager, pro se / 29 East Locust Street ?echanicsburg, PA 17055 azbaza Sumple-Sullivan, Esquire, Counsel for Mother r f- ''F, RANDY E. RAGER, Plaintiff V. TAMMY A. RAGER, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008-5495 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 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 Kailyn R. Rager May 9, 2005 Mother 2. A Conciliation Conference was held in this matter on March 19, 2009, with the following in attendance: The Father, Randy E. Rager, pro se and the Mother, Tammy A. Rager, with her counsel, Barbara Sumple-Sullivan, Esquire. 3. The parties agreed to an Order in the form as attached. Date acq ine M. Verney, Esquire Custody Conciliator RANDY E. RAGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-5495 CIVIL ACTION - LAW TAMMY A. RAGER, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 14th day of September, 2009, neither party having requested another conciliation conference and ninety days having passed since the last conference, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, . ac line M. Verney, Esquire, C tody Conciliator OF TH 2009 SEP 15 1i"1 .:• 2 ", CUM