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Home My WebLink About05-2783 JOHN T. RYAN, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. 0-'" ;} 7 J^..:i C~ 7h-.. ANITA L. RYAN, Defendant : CIVIL ACTION - LAW : IN CUSTODY NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are serve, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. 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 COUNT BAR ASSOCIA TION 32 S, BEDFORD STREET CARLISLE, P A 17013 (717) 249-3166 A VISO USTED HA SlOO DEMANDADO/A EN CORTE. Se usted desea defenderse de las demandas que se prsentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y A vi so radicando personalmente 0 por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya, Se Ie advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fall por cualquier suma de dinero reclamada en la demanda 0 cualquier otra reclamacion 0 remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Used puede perder dinero 0 propiedad u otros derechos importantes para usted, USTED DEBE LLEV AR ESTE DOCUMENTO A SU ABOGADO INMEDIA T AMENTE. SI USTED NO TIENE UN ABOGADO 0 NO PUEDE P AGARLE A UNO, LLAME 0 VA Y A A LA SIGUlENTE OFICINA P ARAA VERIGUARDONDE PUEDE ENCONTRAR AS 1ST EN CIA LEGAL. CUMBERLAND COUNT BAR ASSOCIATION 32 S, BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 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 Aet of 1990, For information about assessable facilities and reasonable accommodations available to disable individuals having business before the Court, please contaet 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, CUMBERLAND COUNT BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 JOHN T. RYAN, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA ~ NO. 05 ~ PL ? g,j C~ re-- ANITA L. RYAN, Defendant : CIVIL ACTION - LAW : IN CUSTODY PETITION TO CONFIRM CUSTODY I, The Plaintiff is John T. Ryan, an adult individual who resides at 6 Oak Drive, Newville, Cumberland County, Pennsylvania, 17241. 2. The Defendant is Anita L. Ryan, an adult individual who resides at 323 N, E Street, Carlisle, Cumberland County, Pennsylvania, 17013. 3. The Plaintiff seeks to confirm custody of the following children: Name Date of Birth Age Jaren A. Ryan Elijah T. Ryan 8/27/97 12/23/99 7 5 The children are primarily in the physical custody of their Father, who resides at the address above. The children were born in wedlock. 4, The Mother of the children is Anita L. Ryan, currently residing at 323 N, E Street, Carlisle, Cumberland County, Pennsylvania. Her marital status is divorced, 5, The Father of the children is John T. Ryan, currently residing at 6 Oak Drive, Newville, Cumberland County, Pennsylvania, 6. The relationship of the Plaintiff to the children is that of Father. 7. The relationship of the Defendant to the children is that of Mother. Plaintiff has not participated as a party or witness or in another capacity in other litigation concerning the custody of the children in this or another Court. Plaintiff has no information of the custody proceedings of 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 children or claims to have custody or visitation rights with the children. 8, The best interest and permanent welfare of the children will be served by granting the relief requested because: a. Plaintiff has been the primary care giver of the children and has provided the children with consistent and loving care, b. The children have primarily resided with Plaintiff since the parties divorce was finalized on 5/7/03. c, Plaintiff is willing and able to continue to provide proper care and supervision of the children. d, Plaintiff can provide a stable and loving environment to the children. 9, Each parent whose parental rights of the ehildren have not been terminated and the person who has physical eustody of the children have been named as parties to this action, There are no other persons who are known to have a claim or right to custody or visitation in this matter. . WHEREFORE, Plaintiff requests the Court to confirm primary physical custody of the children to the Plaintiff with liberal partial physical custody to Defendant. Respectfully Submitted, /~Ov\.~ Y:k!C4 'A~~ Marianne E, Rudebusch, Esquire 4711 Locust Lane Harrisburg, PAl 7109 (717) 657-0632 rd. No, 63522 Dated: C;-/1& / (K I ( . JOHN T. RYAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. ANITA L. RYAN, Defendant : CIVIL ACTION - LAW : IN CUSTODY VERIFICATION I verif'y that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C,S.A. Section 4904 relating to unsworn falsification to authorities, BY~~' Jo Ryan /'? ~~ Date: S /...14 /0 r / / , '-... ~, ~. ~ ~ .......... "- '- ~ Ct., ~ CA. \ , ~ ~ ~ ~ \ \ ~ ~ ~ ~ ~ C) ~,'::; () " c:... -Tl <....J"' -.. ---1 ~- f':~f?~ ", -.... C-.i-, f'-,.' --' .1 " u., JOHNT,RYAN PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v, 05-2783 CIVIL ACTION LAW ANITA L. RYAN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, June 06, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, July 05, 2005 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/ Dawn S_ Sundav. Esq. Custody Conciliator r 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 betore 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 17013 Telephone (717) 249-3166 ~~ ~ ~ ~ 50.(-'7 -/lip :2 ~/ ~lL., 5(7 L 'f ~ P ~ ~~V' 'p?; S'Oc-'} \fIN<i^lASNN=Jcl MNno~: '1'.;(:'2".t;'iir.CJ cs:\ \old L - NnnOOZ A!:NIONOH.LOl:id 3Hl :lO 3JI:l:\()-(l311:l RECEIVED JUL 15 2005 ~ ~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHNT. RYAN vs. 05-2783 CIVIL ACTION LAW ANITA 1. RYAN Defendant IN CUSTODY ORDER OF COURT AND NOW, this l& day of ~ , 2005, consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: upon 1. The Father, John T. Ryan, and the Mother, Anita L. Ryan, shall have shared legal custody of Jaren A. Ryan, born August 27,1997, and Elijah T, Ryan, born December 23,1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 2. Until such time as the Mother changes to an all daytime work schedule, the parties shall continue to share having physical custody of the Children under the following rotating biweekly schedule: During Week I, the Mother shall have custody ofthe Children from Monday morning through Wednesday between 5:00 p.m. and 6:00 p.m., the Father shall have custody from Wednesday between 5:00 p.m. and 6:00 p,m. through Saturday at 8:00 a.m" and the Mother shall have custody from Saturday at 8:00 a,m. through Monday between 5:00 p,m. and 6:00 p.m, During Week II, the Father shall have custody of the Children from Monday after work between 5:00 p.m. and 6:00 p,m. through Wednesday at 7:00 a.m., the Mother shall have custody from Wednesday at 7:00 a,m. through Friday between 5:00 p.m. and 6:00 p.m., and the Father shall have custody of the Children from Friday between 5:00 p.m, and 6:00 p.m. through Monday morning. 3. At such time as the Mother changes to an all daytime work schedule, the parties shall implement a shared physical custody schedule on an alternating weekly basis, with the exchange to take place each week on Friday evening between 5:00 p.m. and 6:00 p.m. when the Father is receiving custody and on Friday after school, when the Mother is receiving custody. 4. The parties shall share having custody of the Children on holidays as arranged by agreement. 5. Each party shall be entitled to have extended periods of custody for vacation each year as arranged by agreement between the parties. 6. In the event either party is unavailable to provide care for the Children during his or her period of custody for an overnight period or longer, that parent shall first contact the other parent to offer the opportunity to provide care for the Children before contacting third party caregivers. 7. The parties agree that neither party shall use corporal punishment to discipline the Children. Both parties shall ensure that third parties having contact with the Children during his or her periods of custody comply with this provision, 8. 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 ent the absence of mutual consent, the terms of this Order shall control. /" , cc: .Aiarianne E. Rudebusch, Esquire - Counsel for Father ,..xeith O. Brenneman, Esquire - Counsel for Mother J 'T' c-.J ~ ~ - 4:. <P "':.~ '{", "~J \..1..1>';' :Co (.)(~'\ n:::';q.:' ;a 'L- -'-' " r~""'~' c1' 'be ~(j: - WU- __I ......Jl.tJ '."i tc~ ;2, ..r.> ",,';" '6 = ~:J ~ (.) T Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHNT. RYAN vs. 05-2783 CNIL ACTION LAW ANITA 1. RYAN Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I, The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF J aren A. Ryan Elijah T. Ryan August 27, 1997 December 23,1999 MotherlFather MotherlFather 2. A conciliation conference was held on July 5, 2005, with the following individuals in attendance: The Father, John T. Ryan, with his counsel, Marianne E, Rudebusch, Esquire, and the Mother, Anita 1. Ryan, with her counsel, Keith O. Brenneman, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ...L.L Otdoot:) Date -- - - - d !1.~~_J\-~ Dawn S, Sunday, Esquire Custody Conciliator Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, PA 17109 717-657-0632 Id. No, 63522 Attorney for Plaintiff JOHN T. RYAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2005-02783 ANITAL. RYAN, Defendant : CIVIL ACTION - LAW : IN CUSTODY AGREEMENT FOR THE MODIFICATION OF CUSTODY ORDER THIS AGREEMENT is made and entered into between JOHN T. RYAN and ANITA L. RYAN, hereinafter referred to as Father and Mother. The parties are the natural parents of Jaren A. Ryan, born 8/27/97 and Elijah T. Ryarl, born 12/23/99. The parties are divorced and desire to make arrangements for the custody of their two children. It is therefore agreed as follows: 1. The parties shall share legal custody of the children. 2. Mother shall have primary physical custody of the children. 3. Father shall have periods of partial physical custody every other weekend from Friday at 6:00 p.m. until Sunday at 6:00 p.m. with seven (7) days notice to Mother. 4. The parties shall share the holidays of Easter, Memorial Day, July 4th, Labor Day, Thanksgiving and Christmas as per their agreement. 5. Each party shall have the children for two weeks during the summer vacation with 60 days written notice to the other party. 6. These provisions modifY the Custody Order dated 7/19/05. IN WITNESS WHEREOF, and intending to be bound hereby, the parties have signed and sealed this Agreement on the S""-day of ~OI'{""'b.fr,2005, at Harrisburg, Pennsylvania. In the presence of: ;;( / ~f?v ~~nL ~if\ (SEAL) WITNESS (SEAL) . - (') r--> ~ = ('~ <'" c.n < ~:n (/) 1"1 -0 f1'p.- N -om :u9 ...0 ~~~ () -0 ~',l' ~T! ..i -;1 ; , ::K ''',0 <::= ~ (jrf1 -I S! 0 ~ CO -< I~ RECEIVED SEP 3 0 1005 l' Marianne E, Rudebusch, Esquire 4711 Locust Lane Harrisburg, PA 17109 717-657-0632 Id, No, 63522 Attorney for Plaintiff JOHNT.RYAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO. 2005-02783 ANITA L. RYAN, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this ~ day of c9L;.~, 2005, it is hereby ORDERED that the attached Agreement for the Modification of Custody Order is entered as an Order of this Court. BY THE-COURT: J. ) (, led" ~ J~"^J,,'7 6)T,Q ocr I ~ /J06C KrlIW Marianne E, Rudebusch, Esquire 4711 Locust Lane Harrisburg, PA 17109 717-657-0632 Id, No. 63522 Attorney for Plaintiff JOHN T. RYAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2005-02783 ANITA L. RYAN, Defendant : CIVIL ACTION - LAW : IN CUSTODY AGREEMENT FOR THE MODIFICATION OF CUSTODY ORDER THIS AGREEMENT is made and entered into between JOHN T. RYAN and ANITA L. RYAN, hereinafter referred to as Father and Mother. The parties are the natural parents of Jaren A. Ryan, born 8/27/97 and Elijah T. Ryan, born 12/23/99. The parties are divorced and desire to make arrangements for the custody of their two children. It is therefore agreed as follows: I. The parties shall share legal custody of the ehildren. 2. Mother shall have primary physical custody of the ehildren. 3. Father shall have periods of partial physical custody every other weekend from Friday at 6:00 p.m. until Sunday at 6:00 p.m. with seven (7) days notice to Mother. 4. The parties shall share the holidays of Easter, Memorial Day, July 4th, Labor Day, Thanksgiving and Christmas as per their agreement. 5. Each party shall have the children for two weeks during the summer vacation with 60 days written notice to the other party. 6, These provisions modifY the Custody Order dated 7/19/05, IN WITNESS WHEREOF, and intending to be bound hereby, the parties have signed and sealed this Agreement on the jdh,day of _<:yo,k"hEr,200S, at Harrisburg, Pennsylvania. In the presence of: , ~t~ df6v :!ffli'n T. Ryan ;7 (SEAL) ~c;..1 ~th (SEAL) ~~ n ('~ ~. ; , / ~~;. :~ '." ....., g <.f' en "" -u N \..D o -11 :;:I ["nfn -Om "")CJ 2~~~ (~ .:~~ r)l =\ '~ ''0 :< -0 2~ Cd C') CO