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HomeMy WebLinkAbout02-0864LORI RANCK, Plaintiff V. CHRISTOPHER RANCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0'Z - A. L/ ?J Ul 1. L IN CUSTODY COMPLAINT FOR CUSTODY The plaintiff is Lori Ranck, residing at 8117 Upperstrausburg Road, Pleasant Hall, Pennsylvania 17246. 2. The defendant is Christopher Ranck, residing at 25 Town Mills, Shippensburg, Pennsylvania 17257. 3. Plaintiff seeks custody of the following child: Name Present Residence Age Brianna Ranck Both listed above 3 years in paragraphs 1 and 2. The child was born out of wedlock. The child is presently in the custody of Christopher four days a week and every other weekend, who resides at 25 Town Mills, Cumberland County, Pennsylvania and Lori three days a week and every other weekend who resides at 8117 Upperstrausburg Road, Franklin County, Pennsylvania. During the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Kathy and George Jones and 8117 Upperstrausburg Road Jan. 2001 to present the Plaintiff Pleasant Hall, PA 17246 (Three (3) days a week and every other weekend) Defendant Chris Ranck and Lori Ranck 25 Town Mills Shippensburg, PA 17257 25 Town Mills Shippensburg, PA 17257 Jan. 2001-present (four (4) days a week and every other weekend) Birth to Jan 2001 The mother of the child is Lori Ranck, currently residing at 8117 Upperstrausburg Road, Pleasant Hall, PA. 4. She is not married. The father of the child is Christopher Ranck, currently residing at 25 Town Mills, Shippensburg, PA. He is not married. The relationship of plaintiff to the child is that of mother. The plaintiff currently resides with the following persons: Name Relationship George and Kathy Jones Father and Mother of Plaintiff 5 6 7 The relationship of defendant to the child is that of father. The defendant currently resides alone. 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 children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party 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 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 child needs for healthy development. WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody in the Mother with liberal visitation in the Father as agreed to by the parties. Respectfully submitted, ROMINGER & BAYLEY Date: Z - ( g _ 6--t Mark F. Bayley, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 87663 Attorney for Plaintiff LORI RANCK IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. CHRISTOPHER RANCK Defendant NO. IN CUSTODY 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 unworn falsification to authorities. o10 / C;?. Lori Rank, Plaintiff LORI RANCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. CHRISTOPHER RANCK, Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Lori Ranck, do hereby certify that I this day served a copy of the Complaint for Custody upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Christopher Ranck 25 Town Mills Shippensburg, PA 17257 OA Mark F. Bayley, Esquire Attorney for Plaintiff Dated: February 18, 2002 rC3 r7 G> C*j 1? > k0 '- c. F '.r w; o O [[ m _ >Ln 2 A V n ° ?) 0 co 3 00 ul 155 SOUTH HANOVER STREET CARLISLE, PENNSYLVANIA 17013 LAW OFFICES 717.241.6070 • 800.734.2132 • FAX: 717.241.6878 ADVOCACY - ADVICE - ANSWERS law@romingerlaw.com www.romingerlaw.com LORI RANCK IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 02-864 CIVIL ACTION LAW CHRISTOPHER RANCK DEFENDANT IN CUSTODY AND NOW, Thursday Febru 21, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy Esq. the conciliator, at 4th Floor Cumberland County Courthouse Carlisle on Friday March 22, 2002 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. 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/ Hubert X Gilroy. 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 iNJ, ? eon. e -eo scw. e 40osr. LA eAY 012002 LORI RANCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW CHRISTOPHER RANCK, : NO. 02 - 864 CIVIL Defendant : IN CUSTODY COURT ORDER AND NOW, this a a day of 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Lori Ranck, and the Father, Christopher Ranck, shall enjoy shared legal and shared physical custody of Brianna Marie Ranck, born July 31, 1998. 2. The physical custody arrangement shall be handled as the parties have done over the past year with the Mother having the child on every Wednesday and Thursday evening over night and the Father having the child every Sunday, Monday and Tuesday evening over night. The parties shall also alternate custody of the minor child on weekends pursuant to their existing schedule. 3. When Father is working and has custody of the minor child and Mother is not working and available to provide care for the minor child, the parties shall make arrangement such that Mother shall provide care while the Father is at work. 4. The parties shall submit themselves to joint counseling to address some communication issues between the parties and to also address current issues relating to the minor child. Costs of this counseling shall be split equally between the parties for any costs not reimbursed by insurance. 5. The parties may modify the custody arrangement in this Order as the parties agree between themselves. However, absent an agreement, this Order shall control. .s b'iNVAIAS? N1 I ?1f?r,r?, na, - r M I 0 !,j,; ?'_ 1 , s;,! Gib 6. This Order is a temporary order in the nature that the parties desire to work under this Order for a period of time and desire to reserve the option of petitioning the court to have the case again scheduled with the custody conciliator for a custody conciliation conference. BY THE COURT, ,/? ? ? / ? J. cc: Mark F. Bayley, Esquire _ rmo? 51310aa. Thomas S. Diehl, Esquire -j . ZP, LORI RANCK, Plaintiff v CHRISTOPHER RANCK, Defendant Prior Judge: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 02 - 864 CIVIL : IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Brianna Marie Ranck, born July 31, 1998. 2. A Conciliation Conference was held on April 26, 2002, with the following individuals in attendance: The Mother, Lori Ranck, with her counsel, Mark F. Bayley, Esquire; and the Father, Christopher Ranck, with his counsel, Thomas S. Diehl, Esquire. 3. The parties agree to the entry of an order in the form as attached. S ( laz it DATE Hubert X. G, Esquire Custody Co uator LORI RANCK , : IN THE COURT OF COMMON : PLEAS, CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff vs CIVIL ACTION - LAW CHRISTOPHER RANCK, NUMBER: 2002 - 864 CIVIL, TERM Defendant IN CUSTODY To the Prothonotary: PRAECIPE Please enter my appearance on behalf of the above-captioned Defendant Christopher Ranck. Dated: June 18, 2002 k Sally J. V , squire Attorney for Defendant 9974 Molly Pitcher Hwy. Shippensburg, PA 17257 C) 0 y _ iry ? ' ' C- -' y c? i rn i _ 1 r ? 7 .3 N -< JUN 1 7 2002` LORI RANCK, Plaintiff v CHRISTOPHER RANCK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LA` : NO. 02 - 864 CIVIL : IN CUSTODY COURT ORDER AND NOW, this /G-q day of June, 2002, upon consideration Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Courtroom No. 4 of i Courthouse on the,26- 5i day of , at which time testimony will be tak*en in the above c Mother, Lori Ranck, shall be the moving party and s testimony. Counsel for the parties shall file with counsel a memorandum setting forth the history of issues currently before the court, a list of witnesses w at the hearing and a summary of the anticipated tc This memorandum shall be filed at least five (5) dad hearing date. the attached Custody Cumberland County 002 at /.3d-/s0-M- e. At this hearing, the 11 proceed initially with he court and opposing a.stody in this case, the will be called to testify imony of each witness. prior to the mentioned 2. Pending further order of this court, this court's order of May 3, 2002 shall remain in effect. 3. In the event Father retains counsel, Father's new counsel should contact counsel for the Mother immediately to advise him h is in the case. In the event Father is not going to retain coup VF h er hould write directly to Mother's attorney and advise f t fa .17 cc: Mark F. Bayley, Esquire Thomas S. Diehl, Esquire Christopher Ranck 25 Town Mills Road Shippensburg, PA 17257 Kevin A. vj," A L --) ? -?Z I- J. 0 ur cn i i ;. n L., } L U 0 C\l j o v LORI RANCK, Plaintiff v CHRISTOPHER RANCK, Defendant Prior Judge: Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAN NO. 02 - 864 CIVIL IN CUSTODY IN ACCORDANCE WITH THE CUMBERLAND CO CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. Shortly after the last custody conciliation conference in this case which was held on April 26, 2002, counsel for the mother notified the conciliator that the Mother had reconsidered her position and that she wants to have a hewing. Mother is seeking primary physical custody rather than the shared type of arrangement which is in effect pursuant to the May 3, 2002 Order. 2. The conciliator scheduled a conference call with legal course for the parties on June 12, 2002. Upon calling Attorney Diehl, the conciliator w advised that Attorney Diehl no longer represents Mr. Ranck. No other attorney contacted the conciliator with respect to new representation, nor was Mother's attorn contacted by any legal counsel on behalf of Mr. Ranck. 3. The conciliator recommends an order in the form as oa - ?/(3/ (0 DATE Hubert X. Gilroy Custody ConcijW LORI RANCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY,! PENNSYLVANIA V. CHRISTOPHER RANCK, Defendant 02-0864 CIVIL TERM ORDER OF COURT AND NOW, this 18th day of June, 200, after consultation with counsel, defendant's petition ?or emergency relief is resolved as follows: 1. Neither party shall remove the ?hild from the Commonwealth of Pennsylvania for more than 48 hours without further Order of Court. 2. Any party taking the child outs de the Commonwealth of Pennsylvania for less than 48 ho rs shall notify the other party of his or her plans, including time of return. In all other respects, Judge Hess's 2002 shall remain in full force and effect. By tination and order of May 3, Edward E. ouido, J. Mark Bayley, Esquire For the Plaintiff Sally J. Winder, Esquire For the Defendant it VIN A7ASNN"d -,r, j tie :R IN izfirrZO a?11±?.F??:31?3 LORIRANCK, vs : IN THE COURT OF COMMON : PLEAS, CUMBEI?LAND COUNTY, : PENNSYLVANIA Plaintiff CIVIL ACTION - AW : NUMBER: 2002 - CMUSTOPHER RANCK, IN CUSTODY Defendant ORDER OF COURT 864 CIVIL TERM AND NOW, this day of June, 2002, upon consid ration of the within Petition for Emergency Order in Custody, and upon Motion of Sall J. Winder, Esquire, counsel for Christopher Ranck, it is ORDERED AND DIRECTED, that, 1. The minor child, Brianna M. Ranck shall remain within a jurisdiction of the Court and shall not be taken outside the Commonwealth of Pennsylvania. 2. Primary physical and residential custody of Brianna M. Ranck is awarded to Father, Christopher Ranck. 3. Mother, Lori Ranck, shall not exercise shared physical custody of the minor child, Brianna M. Ranck, unless she shall be in strict compliance with this Order and the May 3, 2002 Order of this Court. i N s??. _? J. %tll?? LORIRANCK, Plaintiff vs CHRISTOPHER RANCK, Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA i CIVIL ACTION - LAW : NUMBER: 2002 - 964 CIVIL TERM IN CUSTODY PETITION FOR EMERGENCY ORDER IN CUSTODY COMES NOW, the Defendant, Christopher Ranck, by and t Sally J. Winder, Esquire, and does request this Honorable Court enu Ex Parte Order for primary Custody in Defendant based upon the fo. 1. Defendant, Christopher Ranck, is the natural father o Ranck, born July 31, 1998. 2. Following a Custody Conciliation Conference held Order was entered awarding shared physical and legal custody of t for a majority of the time to be spent with Defendant Father. A co] marked Exhibit "A" attached hereto and incorporated herein. 3. Since the entry of the May 3, 2002 Order, Plaintiff dissatisfied with the provisions of the Order and has told Father Court to gain full custody of the child; however, Father has scheduling any further Court action. 4. Defendant Father learned from a third party on Frid the Plaintiff Mother was planning on leaving and moving to Texas 19, 2002, when Defendant Father brought the child to her for her through Thursday period of partial custody. his counsel, an immediate and Brianna Marie 26, 2002, an child which allows of that Order is has been she is going to go to no Order or notice , June 14, 2002, that Wednesday, June evenmg 5. Defendant Father confronted Plaintiff Mother on Friday, June 14, 2002, asking her whether she was planning to take Brianna anywhere this week. Plaintiff Mother was defensive and evasive finally telling Defendant Father that she was just going on vacation but refusing to say where she was going, where she was (staying, or when she was planning to return. 6. Based upon the information related to Father from other persons, Father believes that Mother is intending to take the child out of the jurisdiction of this Court and abscond with the child leaving him no address, phone number, or method of contacting her or the child. 7. Father is further fearful Mother will leave the jurisdiction of the Court and that he will then have no means of serving her with any further process concerning custody or partial custody as she is evasive and refused to provide him any details as to where the child would be or the date of return from this "vacation." 8. If the Court does not immediately enter an Order req firing the child stay in the Commonwealth of Pennsylvania, Father believes that Mother 11 take the child, leave the jurisdiction of the Court and Father will not see the child and will not know the whereabouts of the child. WHEREFORE, Defendant prays this Honorable Court enter an Order requiring that the child, Brianna M. Ranck, stay in the Commonwealth of Pennsylvania. and further that Father Christopher Ranck is awarded primary physical and residential custody of the child under the existing Custody Order until any further order of thi Court and that Mother comply strictly with the provisions of the May 3, 2002, Or r until any further Order of Court. Respectfully submitted. Ai/? Sally J. W der, Attorney for Defendant VERIFICATION I verify that the statements made in this Petition are true a personal knowledge and belief I understand that false statement; penalties of 18 Pa. C.S. Section 4904, relating to unworn falsific Date: G -17-0.2 id correct to the best of my herein are made subject to the ition to authorities. CHRISTOPHER r mAy Y T'2002 r LORI RANCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW CHRISTOPHER RANCK, : NO. 02 - 864 CIVIL Defendant _ : IN CUSTODY COURT ORDER AND NOW9 this ? day of , 20029 ,Pon consideration of the attached Custody Conciliation Report, it is rdered and directed as follows: 1. The Mother, Lori Rank, and the Father, Christopher Rank, shall egioy shared legal and shared physical custody of Brianna Marie Rank, born July 31, 1998. 2. The physical custody arrangement shall be handled as the parties have done over the past year with the Mother having the child on every Wednesday and Thursday evening over night and the Father having, the ctWd every Sunday, Monday and Tuesday evening over night. The Pwdes shall also alternate custody of the minor child on weekends pursuant to their eldsting schedule. 3. When Father is working and has custody of the min Dr child and Mother is not working and available to provide care for the minor child, the parties shall make arrangement such that Mother shall provide re while the Father is at work. 4. The parties shall submit themselves to joint co eling to address some communication issues between the parties and to dso address current issues relating to the minor child. Costs of this coups g shall be split equally between the parties for any costs not reimbursed b insurance. 5. The parties may modify the custody agree between themselves. Howeve control. - 6. This Order is a temporary order in the nature that the parties desire to work under this Order for a period of time and desire reserve the option of petitioning the court to have the case again scheduled with the custody conciliator for a custody conciliation conference. II BY THE COURT, cc: Mark F. Bayley, Esquire " Thomas S. Diehl, Esquire TRUE COPY FRO RECORD In Tastimony whereof, I here . do 89 my bw and the aeal of said Court at CarIjW, Pa. ird ay ? ? ?,I n o ? c° rv nl ri -C W G a rl r-n _t( dirt iz? { Jun 18 02 08:42a LORIRANCK, Plaintiff vs CHRISTOPHER RANCK, Defendant To the Prothonotary: : IN THE COURT OF COMMON : PLEAS, CUMBERLAND COUNTY, : PENNSYLVANIA CIVIL ACTION - LAW NUMBER: 2002 - 864 CIVIL TERM IN CUSTODY PRAECIPE Please withdraw my appearance on behalf of the ptioned D ndant Christopher Ranck. Dated: June 18, 2002 p.2 Thomas S. Diehl, Esquire One West High Street Suite 208 Carlisle. PA 17013 7 J f 7) .^. C.7 LORI RANCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW CHRISTOPHER RANCK, : NO. 02-864 CIVIL Defendant : IN CUSTODY IN RE: MOTION FOR CONTINUANCE ORDER AND NOW, this 2 S~ day of September, 2002, following telephone conference with counsel, our hearing set for September 26, 2002, is continued generally. This matter is remanded to the custody conciliator on the issue of the nature of child care during the father's workday. The parties should also attempt to resolve the issue of primary physical custody when the child begins school. In the event the parties cannot resolve either issue, it is anticipated that the conciliator's order will contain the usual provision for a hearing before the court. BY THE COURT, /Mark F. Bayley, Esquire For the Plaintiff Sally J. Winder, Esquire For the Defendant Hubert X. Gilroy, Esquire Custody Conciliator 7 o o :rlm Y"r4'VAI sSv ?,?n? Su:tl 9odeo LORI RANCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER RANCK Defendant : CIVIL ACTION-LAW : NO. 02-864 IN CUSTODY MOTION TO WITHDRAW AS COUNSEL COMES NOW the undersigned counsel and for his Motion to Withdraw as Plaintiffs Counsel in this matter states to the Court as follows: Plaintiff originally hired undersigned counsel to represent her in a custody proceeding in January of 2002. 2. The Plaintiff has accumulated an outstanding bill with the undersigned attorney in the amount of $1,250.00, which balance remains unpaid despite repeated requests for payment; the last payment was made on June 21, 2002. 3. Plaintiff has failed to provide the undersigned attorney with necessary filing fees in order to advance her litigation. 4. Undersigned counsel cannot adequately represent the Plaintiff without proper payment of legal and filing fees. 5. The Court previously ordered a custody conciliation which has not yet been scheduled; therefore, neither party will be prejudiced by the withdrawal of the undersigned attorney. 6. The undersigned attorney has paid the Prothonotary for the latest unpaid filing fee out of his own pocket upon the filing of this motion. WHEREFORE, the undersigned attorney respectfully requests that this Court grant his Motion to Withdraw as Counsel in the above captioned matter. Respectfully submitted, -7; Mark F. Bayley, Esquire 155 S. Hanover St. Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D.# 87663 VERIFICATION I verify that the statements made in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S., Section 4904, relating to unworn falsification to authorities. Date: 10-21-02 Mark F. Bayley, Esquire PROOF OF SERVICE I HEREBY VERIFY that I have served the foregoing document upon Plaintiff and upon counsel of record by depositing one (1) true and correct copy thereof in the United States Mail, postage prepaid, addressed as follows: Lori Ranck 6114 White Church Rd. Shippensburg, PA 17257 Date: 10-21-02 Sally J. Winder, Esquire 9974 Molly Pitcher Highway Shippensburg,PA 17257 Attorney for Defendant k/ Mark F. Bayley, Esggjr? C - . . Na 5 Ci7 : :lE C 1 Fri N y' c: LORI RANCK IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 02-864 CIVIL ACTION LAW CHRISTOPHER RANCK DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, October 23, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, November 08, 2002 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. 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/ Hubert X. Gilroy, 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 q?? -,44 -*A- ,e*? 4v, Xz, awAa"kv Eu .c CIA PG iju ' 7 &o- £r- of C?O- cif - o/ ro-ce-ol SEP 2 6 2002 LORI RANCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW CHRISTOPHER RANCK, : NO. 02-864 CIVIL Defendant IN CUSTODY IN RE: MOTION FOR CONTINUANCE ORDER AND NOW, this Z S` day of September, 2002, following telephone conference with counsel, our hearing set for September 26, 2002, is continued generally. -. ltd js aided to the custody conciliator on the issue of the nature of child care during the father's d Wo*&y jThe parties should also attempt to resolve the issue of primary physical custody when the child begins school. In the event the parties cannot resolve either issue, it is anticipated that the conciliator's order will contain the usual provision for a hearing before the court. BY THE COURT, `. ' 1 Keel} A. Hess, J. Mark F. Bayley, Esquire For the Plaintiff Sally J. Winder, Esquire For the Defendant Hubert X. Gilroy, Esquire Custody Conciliator Am ?, \ °? V ^ LORI RANCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION-LAW : NO. 02-864 CHRISTOPHER RANCK Defendant : IN CUSTODY RULE TO SHOW CAUSE AND NOW, this Z 3 `t day of ettl v6-_. , 20 V ? ,upon consideration of the foregoing petition, it is hereby ordered that: 1. A rule is issued upon the Plaintiff, Lori Ranck, to show cause why the Plaintiffs Attorney is not entitled to the relief requested; 2. The Plaintiff shall file an answer to the petition within twenty (20) days of service upon her; Or a- &-d se "'?1 6L G? 3. The petition shall be decided under Pa. R.C.P. 206.7; a ococ .m. in eom., e um Uoum 6. Attorney. Notice of the entry of this order shall be provided to all parties by the Plaintiffs BY THE COURT, l 0_/1 W V 2 VNVAIkSNN3d m.?!nno r°;:(,"4-?q,PtinO ?? 00 Z ??<l €'? iJD ZO 6V_4?2 LORI RANCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION-LAW NO. 02-864 CHRISTOPHER RANCK, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Plaintiff, do hereby certify that I this day served a copy of the Rule to Show Cause upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Lori Ranck 6114 White Church Rd. Shippensburg, PA 17257 Sally J. Winder 9974 Molly Pitcher Highway Shippensburg, PA 17257 Attorney for Defendant Dated: 10/24/02 Mark F. Bayley, Esquire Attorney for Plaintiff v o - v cc c? -_- ^.z t C to - Noll 13 2W v LORI RANCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW CHRISTOPHER RANCK, : NO. 02 - 864 CIVIL Defendant : IN CUSTODY COURT ORDER AND NOW, this day of November, 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Courtroom No. 4 of the Cumberlanda my Courthouse on the QM day of X11 , , at 3 $.M. At this hearing, the Father, Christopher Ranck, shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the court and opposing counsel a memorandum setting forth the history of custody in this case, the issues currently before the court, each parties position on these issues, a list of witnesses who will be called to testify at the hearing and the summary of the anticipated testimony of each witness. This memorandum shall be filed at least five (5) days prior to the mentioned hearing date. 2. Pending further order of this court, this court's orders of May 3, 2002 and June 18, 2002 shall remain in effect. BY THE COURT, 29 J. A. Hess cc: Mark F. Bayley, Esquire Sally J. Winder, Esquire L? ,: n? -' .. -. ?' ???( V b? ? „ fir.,„ .1iJ d?..i,l.: LORI RANCK, Plaintiff v CHRISTOPHER RANCK, Defendant Prior Judge: Kevin A. Hess : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 02 - 864 CIVIL : IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Brianna Marie Ranck, born July 31, 1998. 2. A Conciliation Conference was held on November 8, 2002, with the following individuals in attendance: The Mother, Lori Ranck, with her counsel, Mark F. Bayley, Esquire; and the Father, Christopher Ranck, with his counsel, Sally J. Winder, Esquire. 3. The parties were before the conciliator earlier this year at which time an agreement was reached and implemented in the May 3, 2002 custody order. Mother then petitioned to modify custody, but reconsidered her petition in light of the fact that the minor child is not starting school until September 2003. Mother then withdrew that request but, in the meantime, the matter had been scheduled for a custody conciliation conference by Judge Hess. Father now asserts that he should be the primary custodian because he feels Mother is not properly caring for the child when she has custody of the minor child. The conciliator is not able to sort this issue out in light of the fact that the parties agreed last May but now apparently cannot agree on the day of the week. 4. The conciliator recommends the entry of an order in the form as attached. l 6-? D ATE 44v?-?? Hubert X. Gilr , Esquire Custody CopEiliator LORI RANCK, Plaintiff V. CHRISTOPHER RANCK Defendant AND NOW, this .?'='' : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. 02-864 IN CUSTODY ORDER day of , 20 ° z , Plaintiffs counsel, Mark F. Bayley, Esquire, is authorized to withdraw as counsel from the above captioned matter. Counsel shall do so by Praecipe to the Prothonotary. C.°Pie9 d '' 11 k-5 to,. Dtf J BY THE COURT, } r Lf: IJJ ?-: N r?'Q Cv ? J G (; LD C o`v LORI RANCK, Plaintiff V. CHRISTOPHER RANCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-864 IN CUSTODY PRAECIPE TO WITHDRAW AS COUNSEL TO THE PROTHONOTARY: Kindly withdraw my appearance for the Plaintiff in the above captioned case as authorized in the Court Order of December 2, 2002. Mark F. Bayle quire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 87663 Attorney for Plaintiff Date: (? i ?, c c? co -?i''/ .: l \ ' Cr• -? .?.? .?. .. o l f w i LORI RANCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW CHRISTOPHER RANCK, NO. 02-864 Defendant IN CUSTODY ORDER OF COURT AND NOW this _ day of 2003, upon presentation and consideration of the within Petition for Continuance, the hearing on the Plaintiff's Complaint for Custody previously scheduled in this matter for Friday, March 28, 2003, at 9:30 a.m., is hereby continued to di , the 1 q ? day of , 2003, at a-.m., in Courtroom No. ? of the Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania. cc: /Marylou Matas, Esquire Attorney for Plaintiff /Sally J. Winder, Esquire Attorney. f?o?r Defendant C R? ©4-Oq -03 BY THE COURT, J .l . LORI RANCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V CIVIL ACTION - LAW NO. 02-0864 CIVIL TERM CHRISTOPHER RANCK, IN CUSTODY Defendant IN RE: PETITION FOR CUSTODY ORDER OF COURT AND NOW, this 19th day of June, 2003, after hearing, the court takes this matter under advisement, and counsel are requested to submit written proposals for an order in this case. The current order shall remain in full force and effect, but with the understanding that the child will be enrolled in the Shippensburg School District for kindergarten. By the Court, Kevi A. Hess, J, ?ylou Matas, Esquire For the Plaintiff ally Winder, Esquire J For the Defendant : bg [ 1?` I?11S NV OSNN?U4Yf1? zr, q 'd8 6Z Nnr £0 ?0 LORI RANCK, now known as LORI WELSH, Plaintiff V. CHRISTOPHER RANCK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-864 CIVIL ACTION - LAW IN CUSTODY TO THE PROTHONOTARY OF SAID COURT: PRAECIPE FOR WITHDRAWAL OF APPEARANCE Please withdraw my appearance on behalf of the Plaintiff, Lori Ranck, now known as Lori Welsh, in the above-captioned matter. SAIDIS, FLOWER & LINDSAY Date: A16L J& - Marylo tas, Esquire 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney ID 84919 PRAECIPE FOR ENTRY OF APPEARANCE Please enter my appearance on behalf of the Plaintiff, Lori Welsh, in the above-captioned matter. ABONI & KUTULAKIS, L.L.P. Date:'5Iq+ ( W Michelle L. Sommer squire 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney ID 93034 ti CERTIFICATE OF SERVICE AND NOW, this C;P? day of May, 2008, I, Michelle L. Sommer, Esquire of ABOM & KUTULAKIS, LLP, hereby certify that I did serve or cause to be served a true and correct copy of the foregoing Praecipe for Withdrawal and Entry of Appearance by First Class U.S. Mail addressed to the following: Marylou Matas, Esquire 26 West High Street Carlisle, PA 17013 Lori Welsh 187 Rustic Drive Shippensburg, PA 17257 Christopher Ranck 1877 Johnson Road Chambersburg, PA 17201 ? - 1 Michelle L. Somme , squire C'S `v ZZ ---r 7 -, rv .:? OM & &U UL AKIS Michelle L Sommer, Esquire Attorney I.D. No.: 93034 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 LORI RANCK, now known as LORI WELSH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 02-864 CHRISTOPHER RANCK, CIVIL ACTION - LAW Defendant IN CUSTODY TO THE HONORABLE JUDGE, KEVIN A. HESS: AND NOW, comes the Petitioner, LORI RANCK, who through marriage is now known as LORI WELSH, by and through her attorney, Michelle L. Sommer, Esquire, of ABOM & KUTuLAKis, L.L.P., and respectfully petitions for modification of custody, and in support thereof avers the following: 1. Petitioner is Lori Welsh, Plaintiff, who currently resides at 187 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania. 2. Respondent is Christopher Ranck, Defendant, who currently resides at 1877 Johnson Road, Chambersburg, Franklin County, Pennsylvania. 3. A Court Order based upon a Custody Conciliation Report was signed by judge Kevin A. Hess, on May 3, 2002, wherein the parties share legal and physical custody of Brianna Marie Ranck, born July 31, 1998. (A Copy of the Court Order is attached hereto as `Exhibit A'). 4. A Court Order was signed by judge Kevin A. Hess, on July 18, 2003, declaring that the minor child would be enrolled in the Shippensburg School District. (A Copy of the Court Order is attached hereto as `Exhibit B?. COUNT I - MODIFICATION FOR CUSTODY 5. Paragraphs one (1) through four (4) of this Complaint are incorporated herein by reference as though set forth in full. 6. This Agreement should be modified because: a. During the time period of November/December 2006 until March 2008 the Mother had been exercising primary custody of the minor child. i. Father had the minor child every other weekend from Friday night until Monday morning. b. Father no longer lives in Cumberland County, since February/March 2007; he relocated to Chambersburg, Franklin County. c. Father insisted in March 2008 to return to the original May 2002 Court Order regarding custody even though he lives approximately 25 to 30 minutes away. i. Due to his relocation to Chambersburg, Father now drops the minor child off at Mother's home prior to school at 5:00 a.m. ii. Due to his relocation to Chambersburg, Father requires the child to wake-up at 4:30 a.m. in order to get ready for school and for the drive to her Mother's home in Shippensburg. d. Currently, the parties do not have a holiday schedule and as a result, Father does not believe that holidays should be alternated to take precedent over the normal visitation schedule. i. On or about May 11, 2008, Father would not allow the minor child to spend the entire day with her Mother on Mother's Day since it was his weekend; however, he did agree to allow Mother to have the child early agreeing to exchange custody on Mother's Day at 3:00 p.m. e. Based on the recent physical, emotional and psychological changes in the child, Mother is requesting that custody be modified to provide her with primary physical custody in order to keep the child in a more stable routine. WHEREFORE, the Petitioner requests that this Court modify the existing Order to grant primary physical custody of the child to the Petitioner/Mother because it will be in the best interest of the minor child, Brianna Marie Ranck. DAB C? Ir°2?Og Respectfully submitted, ABom&KoTUIAKis; L.L.P. 6 A A1,011 ?. mno Michelle L. Somm , Esquire Supreme Court ID 93034 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Petitioner I, LORI A. WELSH, verify that the statements made in this Petition for Modification of Custody are true and correct to the best of my knowledge, information, and belief. 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 LORI A. WELSH i 2002 LORI RANCK, : IN THE COURT OF COMMON PLEAS O.ir Plaintiff : CUMBERLAND COUNTY, PENNSV?,VAT?'IA V CIVIL ACTION - LAW CHRISTOPHER RANCK, : NO. 02 - 864 CIVIL Defendant : IN CUSTODY I OURT ORDER i Id, AND NOW, this 3 day of _Zy ?Q_???? , 2002, upon consideration of the attached Custody Conciliation Report, it is` rd? ered and directed as follows: 1. The Mother, Lorl Ranck, and the Father, Christop er Ranck, shall en oy shared legal and shared physical custody of Brianna trie Ranck born J?Ily 31, 1998. 2. The physical custody arrangement shall be handled as the parties have dq-Jne over the past year with the Mother having the child orb every Wednesday ? d Thursday evening over night and the Father having t e child every Sundry, Monday and Tuesday evening over night. The pa es shall also altern?te custody of the minor child on weekends pursuant to th 'r existing schedule. i 3. When Father is working and has custody of the minor hild and Mother is rot working and available to provide care for the minor Child, the parties shall make arrangement such that Mother shall provide care while the Father is: at work. 4. The parties shall submit themselves to joint counseling to address soi e communication issues between the parties and to also laddress current issu relating to the minor ch11d. Costs of this counseling) shall be split equa ly between the parties for aay costs not reimbursed by insurance. f 5. The parties may modify the custody arrangement in this Order as the parti agree between themselveg. However, absent an agreement, this Order shi 1 control. .i EXHIBIT "A" b. This Order is a temporary order in the nature that the parties desire to work under this Order for a period of time and desire to reserve the option of petitioning the court to have the case again scheduled with the custody conciliator for a custody conciliation conference. BY THE COURT, a J. cc: i Mark F. Bayley, Esquire Thomas S. Diehl, Esquire TRUE COPY FROM RECORD ?n TesOmony wherid, i there unto set my hane and the of said Court at Orlisla, Pa. Thl flt dw ?? • PA?ttMOnotsry Page 1 of 1 LORI RANiCK, Plaintiff CHRISTOPHER .RANCK, 17tlenrtant Prior Iedgr. IN THE COURT OF COMMON PLEAS OF CUM$ERLANFi CoUNTY, pENNS LVANIA CIVIL ACTION - LAW NO, 02 - 964 CIVIL IN CUsT01}Y +CQp&MjA'1 QN CONFERENCE %JMl4FARY RIFT IN A?CC?oRDANCE wrm THE CUNWERLAND COUNTY CIVIL UTAE OF PROCEDURE 1.915.34(b), Me undersigned Cunady Condliaaar snbnds the Fcl}wing rellom 1. lu pew inimustim pertaidat to the cbiid who Is the muNect of Ob Ittl is as follows: Brianaa Maas Ran* bores July 31, 1198. 2. A Cow Coulbiremce •w bald an April 26,20!Q2, Y46 the in attendanim The M;odie r, Lail Rands, with ber co msel Mot F. BeFiey, Es**v; and The Fatima, ClwiMpber Raak, nilb his off, 'lbmW S. Did* EmMm ''. LCD RI RANCK, Plaintiff vs. CF.'RISTOPHER RANCK, Defendant IN THE COUR ' OF COMMON PLEAS OF CUMBERLAN:) COUNTY, PENNSYLVANIA CIVIL ACTIOl` - LAW NO. 02-864 CI` IL IN CUSTODY IN RE: MOTION FOR COP TINUANCE ORDER AND NOW, this 19 day of July, 2003, after hearing, and consideration of the test, mony adduced, the court fi--ding that Brianna has adj fisted to the current custody arra igement which maximizes her time with both parents the motion of the defendant, Chr stopher Ranck, for primary custody is DEFIED. The court adopts neither proposal of the partes and the existing custody arrangement shall contint a in effect but with the understanding that 3rianna will be enrolled in the Shippensburg schools. BY I PIE COURT, Mar lou Matas, Esquire For t to Plaintiff Sall} J. Winder, Esquire For t ie Defendant :rlrn ?. ?/ Kev' A. Hess, J. TRUE. CO n Testimony vvhr An he seal of sa EXHIBIT "B" 7 r FROM RECORD bf, 1 here unto set my hand Court2l Cafli3je, Pa, LORI RANCK, now known as LORI WELSH, Plaintiff V. CHRISTOPHER RANCK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-864 CIVIL ACTION - LAW IN CUSTODY The undersigned hereby certified that on this date, a true and correct copy of the foregoing Petition for Modification of Custody was served by first class mail to the following: Christopher W. Ranck 1877 Johnson Road Chambersburg, PA 17201 Respectfully submitted, Abom & KutulakisL.L.P. Dated: ajLjog im bnuv Michelle L. Sommer, squire 1 - Attorney ID No. 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for the Petitioner o . ?, .?- ? ?, :? ?, ?? ? ????? ?? ? ?? LORI RANCK N/K/A LORI WELSH IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER RANCK DEFENDANT 2002-864 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, June 10, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, July 11, 2008 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/ Hubert X. Gilroy, Esq. ,ii? Custody Conciliator fj' 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 C I --Z Wd 11 Nnf, onz A L7 1 JUL 15 2008 LORI RANCK N/K/A LORI WELSH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CHRISTOPHER RANCK, Defendant Prior Judge: The Honorable Kevin A. Hess CIVIL ACTION - LAW NO. 2002-864 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Brianna Marie Ranck, born July 31, 1998 2. A Conciliation Conference was held on July 11, 2008, with the following individuals in attendance: The mother, Lori Ranck, who appeared with her counsel, Michelle Sommer, Esquire, and the father, Christopher Ranck, with his counsel Robert Dailey, Esquire. 3. The parties are working under an Order from 2002. The Mother wants to modify the Order as a result of some issues with the Father getting the child up very early in the morning on weekdays. There are also some other reasons the Mother desires to modify the Order. There was some discussion at the conciliation conference with respect to a potential settlement but the parties were unable to reach an agreement. A hearing is required. 4. The Conciliator recommends an Order in the form as attached. Date: July , 2008 al X?z Hubert X. Croy, Esquire Custody nciliator LORI RANCK, Plaintiff VS. CHRISTOPHER RANCK, Defendant AND NOW, this IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 02-864 CIVIL : 1N CUSTODY MOTION FOR CONTINUANCE ORDER day of July, 2003, after heating, and consideration of the testimony adduced, the court finding that Brianna has adjusted to the current custody arrangement which maximizes her time with both parents, the motion of the defendant, Christopher Ranck, for primary custody is DENIED. The court adopts neither proposal of the parties and the existing custody arrangement shall continue in effect but with the understanding that Brianna will be enrolled in the Shippensburg schools. ~,l~arylou Matas, Esquire For the Plaintiff ~ally J. Winder, Esquire For the Defendant :rlm BY THE COURT, Hess, J. LORI RANCK N/K/A LORI WELSH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW CHRISTOPHER RANCK, NO. 2002-864 Defendant IN CUSTODY COURT ORDER AND NOW, this / day of July, 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Courtroom No. 4 of the Cumberland County Courthouse on the 14-a day of - &WA«) , 2008 at / 136 _d! . m. At this hearing, the Mother shall be the moving parry and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a Memorandum setting forth the history of custody in this case, the issues currently before the Court, a list of witnesses who will be called on behalf of each party and a summary of the anticipated testimony of each witness. This Memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, this Court's prior Order of May 3, 2002, shall remain in effect. 3. The Court will address at the hearing the creation of a holiday schedule. Pending further Order of this Court on that issue, major holidays shall be alternated with the parties alternating the upcoming holidays of Labor Day and Thanksgiving with the Father having custody on Labor Day and Mother having custody on Thanksgiving unless the parties agree otherwise. 4. In the event legal counsel for the parties feel that another custody conciliation conference may aid in reaching an amicable resolution of this case, legal counsel may contact the Custody Conciliation directly to schedule a conference in advance of the hearing scheduled above. cc: -cheIle L. Sommer Esquire Robert J. Dailey, Esquire 0-6 I F-s /-Ma P- -1 1/? BY THE COURT, N ' CV-) s? 13.- ? ".-? ..may C-' N ? OM C'SC' tITULAKIS Michelle L Sommer, Espire Attorney I. D. No.: 93034 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 LORI RANCK n/k/a LORI WELSH : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. CHRISTOPHER RANCK, Defendant : CIVIL ACTION - LAW NO. 2002-864 IN CUSTODY THIS CUSTODY STIPULATION AND AGREEMENT entered into the day and year hereinafter set forth, by and between LORI WELSH, (hereinafter referred to as "Mother") and CHRISTOPHER RANCK, (hereinafter referred to as "Father"). WHEREAS, the parties are the natural parents of one child, namely BRL4MVA MARIERANCI, born July 31, 1998 (hereinafter referred to as "Child"); WHEREAS, Mother filed a Petition for Modification of Custody on or about June 4, 12008; WHEREAS, on July 18, 2008 an Order was entered following a Custody Conciliation; WHEREAS, Mother filed a Petition for Modification of Custody asking for shared l legal and primary physical custody on June 4, 2008; 2 WHEREAS, the parties currently wish to enter into a Custody Stipulation and Agreement relative to legal and physical custody of their Child; and NOW THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth, the parties stipulate and agree as follows: 1. Legal Custody: a. The parties will share joint legal custody of BRrANNA MARIE RANCK The parties agree that major decisions concerning their Child, including, but not necessarily limited to, the Child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the Child's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the Child. Each party agrees not to attempt to alienate the affections of the Child from the other party. Each party shall notify the other of any activity or circumstance concerning their Child that could reasonably be expected to be of concern to the other. Day-to-day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions, which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as 3 soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. Mutual agreement should be made, in advance, regarding the following matters: enrollment or termination in a particular school or school program, advancing or holding the Child back in school, authorizing enrollment in college, authorizing their Child's driver's license or purchase of an automobile, authorizing employment, authorizing Child's marriage or enlistment in the armed forces, approving a petition for emancipation, authorizing foreign travel, passport application or exchange student status. 2. Primary Physical Custody: a. Mother shall have primary physical custody of the Child with Father having partial physical custody as follows: i. During the School Year: 1. Father shall pick up the Child from Mother's residence Friday when the Child gets off the school bus. Mother shall pick up the Child from Father's residence Sunday at 7:00 p.m. 2. Custody will be determined by the Saturday of each month even though custody will begin on Friday evening for Father. 4 a. Father will have custody of the Child for three weekends per month, the 1st, 2nd and 4th weekend of every month. b. Mother will have custody of the Child the 3rd weekend each month and if there happens to be 5 weeks in the month she will also have the 5th weekend as well. 3. The parties further agree that Father will have custody of the Child every Wednesday evening from after school until 7:30 p.m. a. Father shall be responsible for transportation to and from Mother's house on Wednesday evening. ii. During the Summer School Break: 1. Father will have custody of the Child every other weekend from Friday when Father gets off work until Sunday at 7:00 p.m. a. Father will pick up the Child at Mother's residence when he gets off work on Friday and Mother shall pick up the Child at Father's residence Sunday at 7:00 p.m. 2. Father will have four weeks of full custody each Summer; one week each month of June, July and August and an extra week 5 during the month of his choice as long as they are not consecutive weeks. b. The parent with physical custody during any given period of time shall communicate in a prompt fashion with the other parent concerning the i i. well-being of the Child, and shall appropriately notify the other parent of any changes in health or educational progress. Each parent shall execute any and all legal authorizations so that the other parent may obtain information from the Child's schools, physicians, psychologists, or other individuals concerning her progress and welfare. c. Right of First Refusal: i. In the event either party is unavailable, with the exception of work by either parent, to provide care for the Child during his or her period of custody for four (4) hours or more, that parent shall contact the other parent to offer the opportunity to provide care for the Child during the custodial parent's unavailability before contacting third party caregivers or step-parent. 3. Holidays: a. The parties shall alternate the following holidays with the period of physical custody beginning at 9:00 a.m. until 7:00 p.m. on the day of the holiday: i. Labor Day: 6 1. Father shall have even-numbered years and Mother shall have odd-numbered years with Father beginning in 2008. ii. Memorial Day: 1. Mother shall have odd-numbered years and Father shall have even-numbered years with Mother beginning in 2009. iii. 4`' of July: 1. Father shall have odd-numbered years and Mother shall have even-numbered years with Father beginning in 2009. iv. Thanksgiving: 1. Mother shall have even-numbered years and Father shall have odd-numbered years beginning with Mother in 2008. v. Easter: 1. Father shall have odd-numbered years and Mother shall have even-numbered years beginning with Father in 2009. b. Christmas: i. The Christmas Holiday shall be divided into two blocks. 1. Block A: From 9:00 a.m. Christmas Eve until 2:00 p.m. Christmas Day. 2. Block B: From 2:00 p.m. Christmas Day until 7:00 p.m. on December 26t'. ii. Mother shall have Block A on even-numbered years and Block B on 7 odd-numbered years. Father shall have Block A on odd-numbered years and Block B on even-numbered years. c. Mother's Day: i. Mother will have physical custody of the Child on Mother's Day from 9:00 a.m. until 7:00 p.m. d. Father's Day: i. Father will have physical custody of the Child from 9:00 a.m. until 7:00 p.m. e. The holiday schedule shall take precedence over the regular custody schedule. 4. Should either party have the Child spend overnight at a place other than their primary residence (including all vacations), the other parent will be given the address and phone number of where the Child can be reached. 5. Telephone Contact: a. Each parent shall be entitled to reasonable telephone contact with the Child, which shall not be excessive, as well as daily contact via e-mail with the Child when in the custody of the other parent. 6. The parents shall organize ways for their Child to maintain her friendships, extracurricular activities, and other special interests, 'regardless of which household she may be in. It is also suggested that toys, clothes, etc. not become matters of contention. Major gifts should be discussed and 8 coordinated between the parents. 7. Each parent will exercise care in screening babysitting/Child care providers. The telephone numbers of these providers will be provided to both parents. Parents should provide one another with a phone number and address where the Child may be contacted at all times whenever reasonably possible. This principle applies to situations such as vacations and overnights with friends. Each parent should be promptly and politely responsive to the other parent's telephone calls. 8. The parents shall permit and support the Child's access to all family relationships. Special family events such as weddings, family reunions, family gatherings, funerals, graduations, etc. shall be accommodated by both parties with routine visitations resuming immediately thereafter. Each parent shall have the option of proposing time or date variations to the other parent when special recreational options or other unexpected opportunities arise. Each parent must confer with the other parent before arranging regularly occurring extracurricular activities for the Child which might interfere with regular visitation. 9. During any period of custody or visitation the parties to this Order shall not possess or use any controlled substance, nor shall they consume alcoholic beverages to the point of intoxication, nor smoke cigarettes inside the residence or vehicle. The parties shall likewise assure, to the extent possible, 9 that other household members and/or houseguests comply with this prohibition. 10. Neither parent shall permanently relocate if the relocations would necessitate a change in the visitation schedule or if the relocation would result in a change of school for the Child or exceed a fifty (50) mile radius without a minimum notice of ninety (90) days to the other parent. The ninety (90) day notice is designed to afford the parents an opportunity to renegotiate the custodial arrangements or to have the matter listed for a Court hearing. For the Child's welfare, neither parent should consider moving very far from the other until the Child has reached adulthood. 11. No Conflict Zone: a. Each parent agrees not to attempt to alienate the affections of the Child from the other and will make a special conscious effort not to do so. Both parents shall establish a no-conflict zone for their Child and refrain from making derogatory comments about the other parent in the presence of the Child and, to the extent possible, shall not permit third parties from making such comments in the presence of the Child whether the Child is sleeping or awake. Each parent shall speak respectfully of the other whether it is believed the other reciprocates or not. Each parental figure shall refer to the other by the appropriate role name such as Mom, Dad, your grandmother, etc. Each parent should agree to refrain from 10 encouraging the Child to provide reports about the other parent. Communication should always take place directly between parents, without using the Child as an intermediary. Each parent should encourage their Child to send the appropriate holiday cards to the other parent. 12. The parties desire that this Stipulation and Agreement be made an Order of Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody of the parties' minor Child, who has resided for at least the past six (6) months in Cumberland County, Pennsylvania. 13. The parties stipulate that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other party. 14. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is not the result of any duress or undue influence. 11 IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year hereinafter mentioned. WITNESSETH: " ?k'- &WO q- 5 vx DATE ?z .a- LORI WELSH DATE _? -Yj. 4-1k CHRISTOPHER RANCK 12 --OMMONWEALTH OF PENNSYLVANIA SS. -OUNTY OF CUMBERLAND -?h On this day of , 2008, before me, the undersigned officer, personally appeared LORI WELSH, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that she executed the same for the purposes therein contained. h NOTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA Notarial Seal Shannon L. Freeman, Notary Public Carlisle Boro, Cumberland County My Commission E)ires April 7, 2009 Member, Pennsylvania Association of Notaries COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On this day of 2008, before me, the undersigned officer, personally appeared CHRISTOPHER RANCK, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that he executed the same for the purposes therein contained. NOTARY PUBLIC rAmanda ONWEALTH OF PENNSYLVANIA NolOrlel SOW L. Bernhisel, Notary Public Carlisle Boro, Cumberiand County 13 y CorrdV*m °n E>cphres April 17, 2010 Member, Pennsylvania Association of Notaries f"-' ? .t {? ^? :"I "'i ??x ?? ? ? Y? J, SFP 0 U `6',?8 6 LORI RANCK n/k/a LORI WELSH IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. CIVIL ACTION - LAW CHRISTOPHER RANCK, NO. 2002-864 Defendant IN CUSTODY AND NOW this ° ` day of r 2008, the attached Modified Custody Stipulation and Agreement is hereby made an Order of Court. istribution: ichelle L. Sommer, Esquire, For the Plaintiff Ebert J. Dailey, Esquire, For the Defendant ')) ,, F-S Mgt LL BY THE COURT, . ? ? ` =?' r ?- ?? ? ?? ? ? ?? ??' c,?