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Home My WebLink About04-4079HEATHER N. RAKERS Plaintiff MARK BENJAMIN GRINDBERG Defendant : IN THE COURT OF COMMON PLEAS : : CUMBERLAND COUNTY, PENNSYLVANIA .. .. : No. Oq- ._ : CIVIL ACTION - CUSTODY . COMPLAINT FOR CUSTODY AND NOW, comes Petitioner, Heather N. Rakers, by and through her attorney, Mark A. Mateya, and respectfully represents: 1. The Plaintiff is Heather N. Rakers, an adult individual, who resides at 415 Greason Road, Carlisle, PA 17013. 2. The Defendant is Mark B. Grindberg, an adult individual residing at 1426 Bradley Drive, Apartment 1 313, Carlisle, PA 17013. 3. Plaintiff seeks custody of the following child: Betty Lou Grindberg age 3 weeks, present address is 415 Greason Road, Carlisle, PA 17013; date of birth, July 20, 2004. 4. The child was born out of wedlock. 5. The child is presently in the custody of Heather N. Rakers, who resides at 415 Greason Road, Carlisle, PA 17013. 6. During the past four (4) weeks the child has resided with the following persons at the following addresses: a. Heather N. Rakers and Mark B. Grindberg at 1426 Bradley Drive, Apartment 1313, Carlisle, Pa 17013. b. Heather N. Rakers, her brother Randy Lee Rakers and her father Randall Francis Rakers at 415 Greason Road, Carlisle, PA 17013. 7. The mother of the child, Heather Rakers, is currently residing at 415 Greason Road, Carlisle, PA 17013, and she is single. 8. The father of the child is Mark Grindberg, who is currently residing at 1426 Bradley Drive, Apartment 1 313, Carlisle, PA 17013 and he is single. 9. The relationship of the Plaintiff to the child is that of natural mother. The Plaintiff currently resides with her brother and father. 10. The relationship of the Defendant to the child is that of natural father. The defendant currently resides alone. 11. The 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 any other Court. 12. Plaintiff has no information of a custody proceeding concerning the child pending in any Court of this Commonwealth or any other state. 13. Plaintiff does not know of a person not a party to the proceeding who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because: i. Plaintiff is the mother of the child; ii. Defendant is a risk to flee, as he is originally from Alabama and has resided within the Commonwealth for less than three years. iii. Defendant has used illegal and illicit substances and has a drug abuse problem, making him unfit to parent his child. iv. Defendant has made threatening remarks to Plaimiff and is a danger to his child. WItEREFORE, Plaintiffrequests this Honorable Court to grant custody of the child to Plaintiff. Respectfully submitted, Mark A. Mateya Attorney I.D. No. 78931 P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 Attorney for Plaintiff VERIFICATION I, Heather N. Rakers, verify that the facts set forth in the foregoing COMPLAINT FOR CUSTODY are tree and correct to the best of my knowledge, information, and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. VERIFICATION I, Heather N. Rakers, verify that the facts set forth in the foregoing COMPLAINT FOR CUSTODY are tree and correct to the best of my knowledge, information, and belie£ I understand that false statements herein are subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. DATED: C--'~///--~5'/c'V9/ HEATHER N. RAKERS : PLAINTIFF : V. MARK BENJAMIN GRINDBERG : DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-4079 CIVIL ACTIONLAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, August 19, 2004 , 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 Tuesday, September 14, 2004 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. All children age five or older may also be present at the conference. 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/ ]acqueline M. Verney. Esq. Custody Concilialor mhc 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 ~II-1E 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 HEATHER N. RAKERS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2004-4079 CIVIL TERM _. MARK BENJAMIN GRINDBERG,: CIVIL ACTION - LAW Defendant : : IN CUSTODY ORDER OF COURT AND NOW, this ~4'~ ~~ day of _, 2004, upon consideration of the attached Custody C a Report, it is ordered and directed as follows: 1. The Mother, Heather N. Rakers, and the Father, Mark Benjamin Grindberg, shall have shared legal custody of Betty Lou Grindberg, bom July 20, 2004. 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. 2. Mother shall have primary physical custody of the child. 3. Father shall have periods of supervised visitation beginning September 18, 2004, every Saturday from 10:00 a.m. to 6:00 p.m. Father's mother, Deborah Shreve shall be the supervisor. 4. Mother shall be responsible for all transportation. Drop off and pick up shall be at Deborah Shreve's home unless otherwise agreed hy the parties. 5. Neither party shall use illegal substances or drink to the point of intoxication immediately before or during their custodial periods. 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. Another Conciliation Conference is scheduled for October 13, 2004 at 8:30 a.m. kkA. Mateya, Esquire, Counsel for Mother ~/Mar~ljea~ia~tGcriondurtberg, pro se Mechanicsburg, PA 17055 HEATHER N. RAKERS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, pENNSYLVANIA V. : 2004-4079 CIVIL TERM : MARK BENJAMIN GRINDBERG,: CIVIL ACTION - LAW Defendant : 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 report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME Betty Lou Grindberg DATE OF BIRTH July 20, 2004 CURRENTLY IN CUSTODY OF Mother oncthation Conference was held in this matter on September 14, 2004 2. A C ' ' - ......... ~-- 15I Rakers, with her counsel, Mark with the following in attendance: II~e tvtomer, Fteautct · A. Mayeya, Esquire, and Father, Mark Benjamin Grindberg, pro se. 3. The parties agreed to the Order as attached Date Custody Conciliator HEATHER N. RAKERS, Plaintiff Ve : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2004-4079 CIVIL TERM ,. MARK BENJAMIN GRINDBERG,: CIVIL ACTION - LAW Defendant : : IN CUSTODY ORDER OF COURT AND NOW, this l~ ~day of ~n~'~ ,2004, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated September 20, 2004 is hereby vacated. 2. The Mother, Heather N. Rakers, and the Father, Mark Benjamin Grindberg, shall have shared legal custody of Betty Lou Grindberg, born July 20, 2004. 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. 3. Mother shall have primary physical custody of the child. 4. Father shall have periods of partial physical custody beginning November 13, 2004, every Saturday from 10:00 a.m. to 6:00 p.m. 5. Transportation shall be shared such that the parties shall meet at McDonald's in Carlisle located next to the Point Mall. 6. Neither party shall use illegal substances or drink to the point of intoxication immediately before or during their custodial periods. 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. Another Conciliation Conference is scheduled for Tuesday, February 1, 2005 at 8:30 a.m. Jo cc.~vlark A. Mateya, Esquire, Counsel for Mother ~ark Benjamin Grindberg, pro se 103 West Portland Street Mechanicsburg, PA 17055 NOV 0 9 2004 HEATHER N. RAKERS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .. : 2004-4079 CIVIL TERM .. MARK BENJAMIN GRINDBERG,: CIVIL ACTION - LAW 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 Betty Lou Grindberg DATE OF BIRTH July 20, 2004 CURRENTLY IN CUSTODY OF Mother 2. A Conciliation Conference was held in this matter on November 9, 2004 with the following in attendance: The Mother, Heather N. Rakers, with her counsel, Mark A. Mateya, Esquire, and Father, Mark Benjamin Grindberg, pro se. 3. The Honorable Edward E. Guido entered a prior Order of Court dated September 20, 2004 providing for shared legal custody, with Mother having primary physical custody and Father having supervised visitation every Saturday from 10:00 a.m. to 6:00 p.m. The parties agreed to the Order as attached Date ~erne/~;, Custody Conciliator HEATHER N. RAKERS Plaintiff IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2004-4079 CIVIL ACTION - CUSTODY MARK BENJAMIN GRlNDBERG Defendant PETITION TO WITHDRAW APPEARANCE AND NOW comes MARK A. MATEY A, Esquire pro se,pursuant to Pa.R.C.P. No. 1012(b) and respectfully represents: I. Petitioner is Mark A. Mateya, Esquire, counsel for the Plaintiff in the above- referenced action. 2. Plaintiff is an adult individual presently residing at 415 Greason Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. Defendant in the above-referenced action is Mark Benjamin Grindberg, presently residing at 24 Pheasant Court, Mechanicsburg, Cumberland County, Pennsylvania 17055. 4. Petitioner was notified bye-mail on January 12, 2005, that the Plaintiff no longer needed the services of Petitioner in the above-referenced action. 5. Withdrawal of appearance by Petitioner will not materially affect the interest of Plaintiff action. Date: WHEREFORE, Petitioner requests leave to withdraw his appearance in the above-captioned M~M~~~ Attorney ID No. 78931 P.O. Box 127 Boiling Springs, P A 17007 (717) 241-6500 ll/'Jfoc::; Counsel for Plaintiff CERTIFICATE OF SERVICE I, Mark A. Mateya, Esquire, hereby certify that I have served a copy of the Petition for Withdrawal of Appearance, on the following person(s) by depositing a true and correct copy of the same in the United States Mail, first class, postage prepaid, at Boiling Springs, Cumberland County, Pennsylvania addressed to: Heather N Rakers 415 Greason Road Carlisle P A 17013 Mark Benjamin Grindberg 24 Pheasant Court Mechanicsburg P A 17055 U-G, Mark A. Mateya, Es Ire P.O. Box 127 Boiling Springs, PAl 7007 (717) 241-6500 DATED: \ feJ ID~ I I Attorney for Plaintiff c~ r<J c::::> . ~..n -'1 p'i loO I CO C) -11 I...{) 0) FEB 0 1 2005~~ HEATHER N. RAKERS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2004-4079 CIVIL TERM MARK BENJAMIN GRINDBERG,: CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT 7;" ,..~ AND NOW, this' day of ~ ,2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. The prior Order of Court dated November 10,2004 is hereby vacated. 2. The Mother, Heather N. Rakers, and the Father, Mark Benjamin Grindberg, shall have shared legal custody of Betty Lou Grindberg, born July 20, 2004. 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. 3. Mother shall have primary physical custody ofthe child. 4. Father shall have periods of partial physical custody of at least 8 hours per week as agreed by the parties. 5. Transportation shall be shared such that the parties shall meet at McDonald's in Carlisle located next to the Point Mall. 6. Neither party shall use illegal substances or drink to the point of intoxication immediately before or during their custodial periods. 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. cc~ather N. Rakers, pro se 415 Grayson Road j~arlisle, PA 17013 yMark Benjamin Grindberg, pro se , 103 West Portland Street Mechanicsburg, PA 17055 ~ ~{)~ O'}:r:3 J. L ~:{) UV 11- GId gOJZ iU\'j.Ci'ij,' 'IJ~iJ 3dl :iG ::;::'\1::bC;-.CEllH ----- FEB 0 I 2LI>,' +tf'. HEATHER N. RAKERS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2004-4079 CIVIL TERM MARK BENJAMIN GRINDBERG,: CIVIL ACTION - LAW 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 Betty Lou Grindberg July 20, 2004 Mother 2. A Conciliation Conference was held in this matter on February 1,2005 with the following in attendance: The Mother, Heather N. Rakers, pro se and Father, Mark Benjamin Grindberg, pro se. 3. The Honorable Edward E. Guido entered a prior Order of Court dated November 10, 2004 providing for shared legal custody, with Mother having primary physical custody and Father having supervised visitation eVI~ry Saturday from 10:00 a.m. to 6:00 p.m. 4. The parties agreed to the Order as attached ^ I --- ;<. - -O!J Date ~~~.v~ acq ine M. Verney, Esquire Custody Conciliator FES 0 9 2005~~ c w HEATHER N. RAKERS Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. . : NO. 2004-4079 : CIVIL ACTION - CUSTODY MARK BENJAMIN GRlNDBERG Defendant ORDER II.JJM rr'() J ~ AND NOW this L:- day of _ y.-v - 0 , 2005, upon consideration of Petitioner, Mark A. Mateya, Esquire's Petition to Withdraw as Counsel for Plaintiff; IT IS HEREBY ORDERED AND DECREED that Petitioner Mark A. Mateya's Petition to Withdraw Appearance on behalf of the Plaintiff in the above-referenced action is granted. ~ Y THE COU ~ J. ~ oc?-lt./ -05 \\ ..n(J (J,\~,,\JdJ"'l\"O \' ",;" ~"..\\~ 'i-\\ ~!~ . ~::.-) -