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Home My WebLink About09-4596 KEVIN R. BEIDEL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW CHRISTA L. BEIDEL, NO. 09- '159 (- CIVIL TERM Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Kevin R. Beidel, an adult individual currently residing at 8 Mel Ron Court, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Christa L. Beidel, an adult individual currently residing at 730 Bloserville Road, Newville, Cumberland County, Pennsylvania. 3. The parties are the natural parents of two (2) children, namely, Skyler R. Beidel, born May 27, 1995, and Brooke K. Beidel, born December 1, 1999. The children were not born out of wedlock. 4. For the past five (5) years, or since the children's birth, the children have resided with the following persons at the following addresses for the following periods of time: NAME ADDRESS DATES Mother 730 Bloserville Road June 6, 2009 to Newville, PA 17241 Present Mother and Father 730 Bloserville Road Birth to Newville, PA 17241 June 6, 2009 r The natural mother of the children is Christa L. Beidel, who resides as aforesaid. She is married. The natural father of the children is Kevin R. Beidel, who resides as aforesaid. He is married. 5. The relationship of the Plaintiff to the children is that of natural father. The Plaintiff currently resides with his parents, Charles and Edna Beidel. 6. The relationship of the Defendant to the children is that of natural mother. The Defendant currently resides with the children at issue. 7. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the children. 8. Plaintiff has no information of any custody proceedings concerning the children pending in any Court of this Commonwealth. 9. It is in the best interest and permanent welfare of the children to grant the relief requested because the children will benefit from a relationship with both parties, who have both been involved with parenting since the birth of the children. 10. Plaintiff does not know any person not a party to these proceedings who claims to have custody or visitation rights with respect to the children. WHEREFORE, Plaintiff requests your Honorable Court to schedule a custody conciliation conference, followed by a hearing, at which time he should be granted shared legal and physical custody of the children. Respectfully submitted, n NA 6-t?_? L 1 1U? ?aAN - .,A Hannah Herman-Snyder, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: S Jay 2ce,? )z? - fY I KEVIN R. BEIDEL, Plaintiff tom. ? ?? .•i. rd , t f G s 5n 6A--" °10" „1 .;7 -7,JJ4/ KEVIN R. BEIDEL IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-4596 CIVIL ACTION LAW CHRISTA L. BEIDEL IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, July 15, 2009 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, August 18, 2009 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ john . Man an r. Es q. ILA 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 t OF '? c: r;, ?1rrdY 2009 jul fir; l?. c •?i V 7M1b `7-/G -OS' ice, ??? ???-? ? ?? ???? _ KEVIN R. BEIDEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTA L. BEIDEL, Defendant CIVIL ACTION -LAW NO. a7?457k CIVIL TERM IN CUSTODY AFFIDAVIT OF SERVICE I, Hannah Herman-Snyder, Esquire, counsel of record for Plaintiff, state that a true copy of a Custody Complaint was sent to Defendant, Christa L. Beidel, at her address of 730 Bloserville Road, Newville, Pennsylvania, by certified mail, restricted delivery. A copy of said receipt is attached hereto indicating service was made on July 25, 2009. Hannah Herman-Snyder, Esqui Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 OW L OM Lz la ws" *am OMM MNWM fII?bM J? Sworn and subscribed to before me this day U.S. Postal Service CERTIFIED MAIL,,., RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at www-urns rn-7 m ? Postage $ r-1 Certified Fee E3 Return Receipt Fee C3 (Endorsement Required) C3 Restricted Delivery Fee C3 (Endorsement Required) CD eP» -s n 1a trn. CO 111111 to C3 Total Postage & Fees i Er ent o h!-ll&ffL------- _ : e 1 C3 treef, Apt. o.; - ---------------- Iti or PO Box No. t City, pie: ZIP-- --3Q LP.Se_rVt.!-t o . ewvi-/le PS Fo-i 3800 A,?cjult r. See Reverse for lnstructlor),?, ¦ Complete Items 1, 2, and 3. Also complete Item 4 if Restricted Delivery 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 mailpiece, or on the front if space permits. A. Signature xcXV,, B. Received by ( 1. Article Addressed to: n C/I ri sla- 6elde l lead 7.3D sYkser ville Mewvllle D. Is delivery address diffe t f d?*A..-OIf YES, enter delivery add below 3. Service Type 1111 Certified Mail ? Express Mail E3 Registered )m Return Receipt for Merchandise ? Insured Mall ? C.O.D. 4. Restricted Delivery? (Extra Fee) F( Y. 2. Article Number 7009 0080 0001 8043 6596 (Transfer from service label) PS Form 3811, February 2004 domestic Return Receipt 102595-02-M-1540 ; r Tk ..... t',Y 2OIJnr J',E 2 PAS ?;7 Nov 012009 KEVIN R. BEIDEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 09-4596 CIVIL ACTION LAW CHRISTA L. BEIDEL, IN CUSTODY Defendant Prior Judge: J. Wesley Oler, Jr., J. ORDER OF COURT AND NOW this I r 1 day of November 2009, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. All prior Orders of Court entered in this matter are hereby VACATED and replaced with this Order. 2. Legal Custody: The Father, Kevin R. Beidel, and the Mother, Christa L. Beidel, shall have shared legal custody of Skyler R. Beidel, born 05/27/1995 and Brooke K. Beidel, born 12/01/1999. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. Physical Custody: Mother and Father shall share physical custody of the subject Children on a week on/ week off schedule as follows: a. Commencing Sunday 11/01/09, Mother shall have physical custody of the Children from Sunday 8:00 pm until the following Sunday at 8:00 pm. b. Commencing 11/08/09, Father shall have physical custody of the Children from Sunday 8:00 pm until the following Sunday at 8:00 pm. During Father's custodial week, Mother shall have physical custody of the Children Wednesday from after school until 8:00 pm. For this Wednesday, Mother shall provide the transportation by picking the Children up after school and return the Children to Father's residence at 8:00 pm. C. For the Sunday exchanges, the non-custodial parent shall pick the Children up from the custodial parent's residence. d. Mother and Father shall have additional physical custody of the Children at such other times as the parties may mutually agree. 4. Counseling: The parties are strongly encouraged to engage in individual and/or therapeutic family counseling (co-parenting) with a mutually-agreed upon professional as necessary or proper for the Child/ren and/or the family. The cost of said counseling, after appropriate payment through insurance, shall be split equally between the parties. 5. Both parents shall continue to engage in educational courses in order to adequately address any medical conditions of the Children. (i.e. Brooke's diabetic condition) as necessary or proper. 6. The non-custodial parent shall have liberal telephone/email/text contact with the Children on a reasonable basis. 7. Holidays: Thanksgiving: Mother shall have physical custody of the Children on Wednesday before Thanksgiving at 3:00 pm until Thursday 3:00 pm. Father shall have physical custody from Thursday 3:00 pm until Friday 3:00 pm. Christmas: Mother shall have physical custody from 3:00 pm on 12/24 until 3:00 pm 12/25. Father shall have physical custody 3:00 pm on 12/25 until 3:00 pm 12/26. Easter: Mother shall have from Saturday before Easter Day at 3:00 pm until Easter Sunday 3:00 pm. Father shall have physical custody Easter Day 3:00 pm until Monday 3:00 pm. Mother and Father shall have physical custody of the Children for Mother's and Father's Day from 9:00 am until 8:00 pm respectively on their days. 8. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Children. 9. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 10. Each parent shall have one uninterrupted week of vacation with the Children per year. Each parent shall schedule said week of vacation during their regular physical custodial week. The requesting parent shall give the other parent 30 days advance notice of the requested time. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. 11. During any periods of custody or visitation, the parties shall not possess or use illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 12. A status conference is hereby scheduled for Tuesday January 05, 2010 at 1.30 Dm with the assigned conciliator at the Court of Common PleasCarlisle PA 17013 13. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. By the Court, J f , J. D' tribution: _,z an Wolf, Esquire /Iannah Herman-Snyder, Esquire /John J. Mangan, Esquire L" mat LCL /l A-4 ?Oq KEVIN R. BEIDEL, Plaintiff V. CHRISTA L. BEIDEL, Defendant Prior Judge: J. Wesley Oler, Jr., J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 09-4596 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Skyler R. Beidel 05/27/1995 Mother and Father Brooke K. Beidel 12/01/1999 Mother and Father 2. A Conciliation Conference was held with regard to this matter on August 21, 2009, an Order was issued September 1, 2009 and a status conference was held October 26, 2009 with the following individuals in attendance: The Mother, Christa L. Beidel, with her counsel, Nathan Wolf, Esq. The Father, Kevin R. Beidel, with his counsel, Hannah Herman-Snyder, Esq. 3. The parties agreed to the entry of an Order in the form as attached. c 47 Date John . M gan, Esquire Cust dy Conciliator OF THE 101NO 'ARY 2009 NOY -4 PH 2: 25 t1M6 .J._ .'l.{VI {