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Home My WebLink About05-1826 CHRISTINA L. REIBER, Plaintiff : IN THE COURT F COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2005- \~d-~IVIL TERM BRYAN L. SEEGER, Defendant IN DIVORCE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the folJowing pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may Jose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlis]e, Pennsylvania] 70]3. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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. CHRISTINA L. REIBER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 'f~ 2005- / CIVIL TERM BRYAN L. SEEGER, Defendant IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c) OF THE DIVORCE CODE NOW comes the Plaintiff, Christina L. Reiber, by her attorney, Marcus A. McKnight, ill, Esquire, and files this Complaint in Divorce against the Defendant, Bryan L. Seeger, representing as follows: 1. The Plaintiff is Christina L. Reiber, an adult individual residing at 1811 Waggoners Gap Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Bryan L. Seeger, an adult individual residing at 6959 Wertzville Road, Enola, Cumberland County, Pennsylvania 17025. 3. The Plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The Plaintiff and the Defendant were married on July 10, 2004. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Pursuant to the Divorce Code, Section 330l(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 7. The Plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the Plaintiff demands judgment dissolving the marriage between the two parties. Respectfully submitted, Mar s 19 t, A rney for Plaintiff/' est Pomfret Professional uilding 60 est Pomfret Street Carlis, nsylvania 17013- 222 (717) 249-2353 Supreme Court LD. No. 25476 By: Date: April 6, 2005 VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Cnn(~'I?~ IAlT CHRISTINA L. REIBER Date: April 6, 2005 CHRISTINA L. REIBER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2005- CIVIL TERM BRYAN L. SEEGER, Defendant IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: April 6, 2005 C rl ()TG1if=D': 'K fL \ fSD - CHRISTINA L. REIBER P -4 n -p c' ~ 7' ..-.., :;.1~ f tl 4J C> ~ l.rt -.... C> ,... "'J R.J --.(j , Ii" ~.:-.. ()J <:J --" & -( ft- ~ r-' = C:-;;:J <J' ;t>'" .." :;;<.;> I --J Si4 ~.." n1p :9(11 ('5, ~ .,.i {~~'-~ ~, ~i' c) J....-> i (jrn / 'Co. J :~o .< -n -- r:;> tJl N - CHRISTINA L. REIBER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION. LAW 2005 .I~~ CIVIL TERM BRYAN L. SEEGER, Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Christina L. Reiber, by her attorneys, Irwin & McKnight, and presents the following Complaint for Custody. l. The Plaintiff is Christina L. Reiber, an adult individual residing at 1811 Waggoners Gap Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Bryan L. Seeger, an adult individual residing at 6959 Wertzville Road, Enola, Cumberland County, Pennsylvania 17025. 3. The parties are the natural parents of one (1) minor child, namely Bailey E. Seeger, born October 29, 2003. - 4. The Plaintiff desires primary physical custody of the minor child, Bailey E. Seeger, and joint legal custody with periods of visitation to Defendant as can be mutually arranged between the parties. 5. The best interests and permanent welfare of the minor child requires that the Court grant the Plaintiff's request as set forth above. WHEREFORE, Plaintiff, Christina L. Reiber, respectfully requests that she be awarded primary physical custody and shared legal custody of the minor child, Bryan L. Seeger, as provided herein, with periods of temporary custody to Defendant as provided herein. Respectfully submitted, IRWIN & McKNIGHT By: Date: April 6, 2005 VERIFICATION The foregoing Complaint for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. -01 n ( [it! rno{.l~\ & i Q Q A CHRISTINA L. REIBER Date: April 6, 2005 ~0 . \C- ~> .~. ""~~ ~ -c ~ ~..-.c:.... -.0 c:::. - ."'" --W c:--- '" ,,,. ~ ,., 1"" ~ ~. .,.--. ---.;- ,..., ~ = "" <J' ". ~ -'(' fl::.'"l:!1 :;;0 -o~ I :,>1 -..l !:::'~L ~~ -r-i ..., ;~:-~~ -(-ern r:-: c_) --\ ~ -,.,,.. en ~ c...:> CHRISTINA L. REIBER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 05-1826 CIVIL ACTION LAW BRYAN L. SEEGER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW. _ Wednesd~April.!1..~005.___.___, upon consideration of the attached Complainl, it is hereby direeled that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, April 28, 2005 . the conciliator, at 9:30 AM ^--- for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispule; or if this cannot be accomplished, to define and narrOW the issues to be heard by lhe court, and to enter inlO a temporary order. All children age five or older may also be present at the conference. Failure 10 appear at the conference may provide grounds for entry of a temporary or pennanenl 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 Gilrov. Esq. Custody Conciliator ~-- The Court of Common Pleas of Cumberland County is required by law 10 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 HA VE 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 170 I 3 Telephone (717) 249-3166 1 W J,.ftt><. II ~ ~ k,7 {f f' ) _ -vl - 5i? ,-,1 h _ J71P -t /PiT'.-.mI th/p;; f;:l.:$I17 ~/7HI' ft? ;t "{r""" M" . rY 5" S/,7 '1 7::.:7 \.1-1 ,,\ . j __, -' ~".J c: \JI; \:~ Z .----------- CHRlSTINA L REIBER Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW BRYAN L SEEGER Defendant : NO. 2005-1826 CIVIL TERM ACCEPTANCE OF SERVICE On behalf of Bryan L Seeger, I accept service of the Divorce and Custody Complaints and certify that I am authorized to do so YOFFE & YOFFE, P_c. Date: April 11, 2005 By I Jeffrey N. Yof e, Esquire Attorney for Bryan L Seeger 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 jyoffe@verz'zon.net ~> c_~,' ,-~-~) C,)', -;" -'~ ,n \_~:~- c~, (! ---- CHRISTINA L REIBER Plaintiff . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LA W BRYAN L SEEGER Defendant . NO 2005-1826 CIVIL TERM RESPONSE TO COMPLAINT AND COUNTERCLAIM L RESPONSE TO COMPLAINT I. Admitted. 2 Admitted. 3. Admitted. 4. No response required. 5. Denied. Bailey is more closely bonded to Bryan L Seeger and therefore it is in the best interests of Bailey that he reside with Bryan L Seeger. II COUNTERCLAIM 6. Paragraphs I through 5 above are incorporated herein. 7. Bailey has more closely bonded with Bryan L Seeger as compared with Christina L Reiber. 8. It is in Bailey's best interests that Bryan L Seeger be awarded primary physical custody and shared legal custody. WHEREFORE, Bryan L Seeger requests that the Court award to him primary physical custody of Bailey and shared legal custody. YOFFE & YOFFE, P.c. effrey N. Yof e, Esquire Attorney for Bryan L Seeger 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 jyoffe@verizon.net CHRISTINA L. REIBER Plaintiff . IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW BRYAN L. SEEGER Defendant : NO. 2005-1826 CIVIL TERM CERTIFICATE OF SERVICE The undersigned certifies that a copy of the foregoing was served on Marcus A. McKnight, III, Esq. on the date indicated below. Service was accomplished bye-mail at the address indicated and by 1st class U.S. mail at the address indicated. Marcus A. McKnight, III, Esq. 60 West Pomfret Street Carlisle, PAl 7013-3222 mmcknight@imhlaw.com YOFFB & YOFFE, PC Date: April 15, 2005 l Ie eyN. Yaffe, Esquire Attorney for Bryan L. Seeger 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ill No. 52933 jyojJe@verizon.net . VERIFICATION I hereby state that I am an adult individual who is authorized to make this verification and that the facts set forth in the foregoing Complaint are true 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. g4904 relating to unsworn falsification to authorities. Dated: ~? --" ~ Bryan L. Seeger - ' r~".) ", C) ~:), .'", l ., 1 _ ~,.:'-. CHRISTINA L. REIBER, Plaintiff RECEIVED MAY 0 2 2005~ pf'- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW BRYAN L. SEEGER, Defendant NO. 2005-1826 IN CUSTODY COURT ORDER AND NOW, this ~ day of May, 2005, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. A hearing is scheduled in Cou~ Room No. ...2.- of the Cumberl~d Co~nty Courthouse on the h<fJ. day of (-/(.1.'1<1' , 2005, at Cfo(] M...m. At this hearmg, the mother shall be the moving ,fJarty 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 to testify 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, the following temporary Custody Order is entered: a. The mother, Christina L. Reiber, and the father, Bryan L. Seeger, shall enjoy shared legal custody of Bailey E. Seeger, born October 29,2003. b. The father shall enjoy physical custody of the minor child as follows: i. On alternating weekends from Friday at 5:30 p.m. until Monday morning at 5:45 a.m. when father shall deliver the child back to mother or designated babysitter as agreed upon by the parties. ii. On the evenings mother is working at Bon Ton during the week, father shall have custody of the minor child from 5:30 that evening until 5:45 a.m. the following morning. If there is a week when mother is uot working, the parties shall communicate with each other and arrange at least one night where father has overnight time with the child consistent with this time frame. iii. The mother shall have physical custody of the child at times when father does not have custody. c. The parties may modify this physical custody arrangement as they agree. Absent an agreement, the Order shall control. d. In the event the parties and their attorneys feel a second Custody Conciliation would benefit the situation and perhaps eliminate the need for the hearing which is scheduled in this case, the attorneys for the parties have the ability to contact the Conciliator again to schedule another Conciliation Conference which may be in person or over the telephone. e. Neither party shall consume alcohol when they have custody of the minor child. /'/ BY THE couRT; \.. r / ,/./ \JfA / / Judge ;' cc:.Jeffrey N. Yoffe, Esquire /. ~arcus A. Mcknight, llI, Esquire 05 ()& -05 I~ h:'::1d -. ~~. prothonotiil'Y,./ c..-~? 'i1:~ ';?~?\:::: ..~\~....,... \,..1..-,i j ~~~\\-: v-y '1:';, ~ i.~ ..:r.: ;,..:".... ,j') " .,.... '~1 \,:t:, '2~ , " <0) LJ - ------------- CHRISTINA L. REIBER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW BRYAN L.fSEEGER, Defendant NO. 2005-1826 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: Bailey E. Seeger, born October 29,2003. 2. A Conciliation Conference was held on April 28, 2005, with the following individuals in attendance: Mother, Christina L. Reiber, with her counsel, Marcus A. Mcknight, III, Esquire, and father, Bryan L. Seeger, with his counsel, Jeffrey N. Yoffe, Esquire. 3. The parties separated this past December. Since that time, mother has had primary custody. However, the father asserts that he was seeking primary custody or additional time with the minor child and that the mother did not accommodate the father's requests. Father is seeking primary custody of the child, and mother is also seeking primary custody. The situation is such that the father works from 6:00 a.m. until 5:30 p.m. each weekday, and mother works a modified schedule which includes some weekends and some evenings during the week. 4. The parties are unable to reach an agreement and a hearing is required. The Conciliator recommends an Order in the form as attached, but the Conciliator notes that his recommendation is not intended to prejudge the case and is based solely on limited information the Conciliator has received at the Conciliation Conference. J ..-'d..-'()~ DATE CHRISTINA L. REIBER, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. BRYAN L. SEEGER, DEFENDANT 05-1826 CIVIL TERM ORDER OF COURT AND NOW, this ~ ~ day of June, 2005, upon agreement of the parties, the following order is entered: (1) All prior custody orders are vacated and replaced with this order. (2) Christina L. Reiber and Bryan L. Seeger, shall have joint legal custody of Bailey E. Seeger, born October 29, 2003. (3) The mother and father shall share physical custody of Bailey in alternating weeks with exchanges occurring on Sundays at 7:00 p.m. (4) The mother and father shall make arrangements between themselves for holidays and at such other times as they agree in the best int",rest ot7y,/ BY)he Court, .. / ,,/ I ~ \ ~arcus A. McKnight, III, Esquire For Plaintiff ~ / ~ffrey N. Yoffe, Esquire For Defendant :sal S 8 :2 hld 81 ,me SOOl l\tfV'J.O~<C:LLUtJd 3Hl dO 3~)t3:1()-D3ltJ -