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HomeMy WebLinkAbout09-8000JEREME J. RUBENDALL, Plaintiff V. MADYLENE J. RUBENDALL, Defendant The children are presently in the custody of Madylene J. Rubendall who resides at 213 Key West Blvd, Carlisle, Cumberland County, Pennsylvania. COMPLAINT FOR CUSTODY 1. The plaintiff is Jereme J. Rubendall, residing at 20 Winchester Gardens, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Madylene J. Rubendall, residing at 213 Key West Boulevard, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks custody of the following child: Name Present Residence DOB Age Lillian M. Rubendall 213 Key West Blvd. 5/5/2003 6 years Carlisle, PA Danelle G. Rubendall 213 Key West Blvd. 12/16/2005 3 years Carlisle, PA The child Lillian M. Rubendall was born out of wedlock and the child Danelle G. Rubendall was not born out of wedlock. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 09 - ?"V CIVIL TERM IN CUSTODY During the past five years, the children have resided with the following persons and at the following addresses: List All Persons List All Addresses Jereme J. and Madylene J. 7073 Carlisle Pike, Lot 222 Rubendall Carlisle, PA 17013 Madylene J. Rubendall 213 Key West Blvd. Carlisle, PA 17013 Dates 2003-2006 2006- Present 4. The mother of the children is Madylene J. Rubendall, residing at 213 Key West Blvd., Carlisle, Cumberland County, Pennsylvania . She is married. 5 6 The father of the children is Jereme J. Rubendall , currently residing at 20 Winchester Gardens, Carlisle, Cumberland County, Pennsylvania. He is married. The relationship of plaintiff to the child is that of Father. The plaintiff currently resides with the following persons. Name Himself Relationship The relationship of defendant to the child is that of Mother. The defendant currently resides with the following persons. Name Relationship Lillian Rubendall Daughter Danelle Rubendall Daughter 7. 8. 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. 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 parry to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. The best interest and permanent welfare of the children will be served by granting the relief request because: Plaintiff has undertaken and performed the primary parental responsibilities for the children. Plaintiff is best able to provide the care and nurture which the children need for healthy development. A Court Order of custody and structured visitation is desired so that the Plaintiff and the children may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the children are not used in a manipulative fashion. 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 responsibility for custody and support. Plaintiff continues to maintain the same family household for the children that has been maintained since birth. WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody subject to partial custody by the Defendant. Respectfully submitted, Date: 117 Lo ? G Vincent M. Monfredo, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 206671 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. Jereme J. Rubendall, Plaintiff, I 41EII-0 ;Rm . PR T %oq- iMAn, 2 NOY 17 FM 3= S 1 014?llxw Gr ?o?o 5v ??? ?337?0 JEREME J. RUBENDALL IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. MADYLENE J. RUBENDALL DEFENDANT 2009-8000 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, November 23, 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 Monday, December 28, 2009 at 10:00 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 entrv 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/ John . Mangan, r. 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 17013 Telephone (717) 249-3166 2009 NOV 23 PH 1: 41 ..Vr+ ,1, I/ ° ? 11 ? ' Gee