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HomeMy WebLinkAbout87-0083IN THE COURT OF C(iMMON PLEAS OF C[I~BEP~ COUNt, PENNSYLVANIA CIVIL ACTICN - LAW CUSTODY ROBERT L. HAYS and SANDRAK. HAYS, his wife, Plaintiffs EARL W. REIDRI.¥., JR. , Defendant COMPLAINT FOR CUSTODY LAW OFFICES N1ANCKE, LIGHTMAN & WAGNER 2233 NORTH FRONT STREET HARRISBURG, PA. 17110 ROBERT L. HAYS and SANDRA K. HAYS, his wife, Plaintiffs VS EARL W. REIDELL, JR. , De fendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 83 CIVIL 1987 : : CUSTODY ORDER OF COURT AND NOW, this 16th day of June, 1987, this matter having been called for a hearing to show cause why Jacqueline Courtney Reidell, born January 21, 1984, should not be permitted to attend the wedding of her father, Earl W. Reidell, Jr., on June 20, 1987, the petition of the natural father is granted. It further appearing that the maternal grandparents now desire to cancel their vacation plans and there is no longer any impediment to the pattern of visitation which has been heretofore established; inasmuch as said pattern accommodates the attendance of the child at her father's wedding, It is ordered and directed that Earl W. Reidell, Jr., shall have temporary custody of the child, Jacqueline Courtney Reidell, from Friday, June 19, 1987 at 5:00 o'clock p.m. until Saturday, June 20, 1987, at 6:00 o'clock p.m. Barbara F. Stein, Esq. For the Plaintiffs J. Michael Eakin, Esq. For the Defendant :pbl By the Court, Kev~.~\A. Hess, J. JOHN B. MANCKE P. RICHARD WAGNER DOUGLAS B. MARCELLO APRIL L. MCCLAINE WILLIAM T. TULLY BARBARA FLUM STEIN LAW OFFICES MaNCKE, WAGNER & k~ArCEL10 2233 NORTH fRONT STREET HARRISBURG. Pa. 171 10 March 12, 1987 AREA CODE 717 234-7051 The Honorable Kevin A. Hess Judge of Cumberland County Cumberland County Courthouse Carlisle, Pennsylvania 17013 Re: Hays v. Reidell No. 83 Civil 1987, Custody Dear Judge Hess: The above captioned matter has been set for a hearing on March 18, 1987, at 1:30 p.m. Michael Eakin, counsel for the Defendant, has indicated his unavailability, and accordingly, both parties would request that this matter be postponed. Ail parties have been undertaking joint counseling with Dr. Stanley Schneider in an effort to reach a satisfactory resolution, and it is hoped that the same will be accomplished so as to avoid the need for a custody hearing. Should counseling through Dr. Schneider not be successful, I would suspect that either party will be contacting the Court to reschedule this matter. Thank you in advance for your consideration. Respectfully yours, MANCKE, WAGNER & MARCELLO P. Richard Wagner PRW:rm cc: J. Michael Eakin, Esq. Mr. & Mrs. Robert L. Hays ROBERT L. HAYS and SANDRA K. HAYS, his wife, Plaintiffs vs. EARL W. REIDELL, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 83 CIVIL 1987 : CIVIL ACTION - LAW : CUSTODY ORDER OF COURT AND NOW, this /FA day of March, 1987, at the request of counsel for both parties, hearing set for March 18, 1987, at 1:30 p.m. is continued generally. BY THE COURT, P. Richard Wagner, Esquire For the Plaintiffs J. Michael Eakin, Esquire For the Defendant Kevi~. Hess, J. :rlm ROBERT L. HAYS and SANDRA K. HAYS, his wife, Plaintiffs vs. EARL W. REIDELL, JR. , Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODY ORDER OF COURT You, EARL W. REIDELL, JR., Defendant, have been sued in Court to obtain custody, partial custody or visitation of JACQUELINE COURTNEY REIDELL. You are ordered to appear in person in Court Room No. ~, of the Cumberland County Courthouse, Carlisle, Pennsylvania, on F~c~ l~ , 1987, at l.'~ o'clock Temporary custody of the child is hereby vested with the Plaintiff herein subject to reasonable visitation by the Defendant pending further Order of Court. If you have the child in your possession or control, you must appear and bring her to the Courthouse with you. If you fail to appear as provided by this Order or to bring the child, an Order for custody, partial custody or visitation may be entered against you, or the Court may issue a warrant for your arrest. 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. COURT ADMINISTRATOR Cumberland County Courthouse Carlisle, Pennsylvania 17013 Phone: Phone (717) 249-1133 BY THE COURT: Jo ROBERT L. HAYS and SANDRA K. HAYS, his wife, Plaintiffs vs. EARL W. REIDELL, JR., De fendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW CUSTODY COMPLAINT FOR CUSTODY AND NOW come the Plaintiffs, ROBERT L. HAYS and SANDRA K. HAYS, his wife, by and through their Attorneys, MANCKE, LIGHTMAN & WAGNER, and respectfully represent as follows: 1. Plaintiffs are Robert L. Hays and Sandra K. Hays, his wife, adult individuals, residing at 4 Crescent Court, New Cumberland, Cumberland County, Pennsylvania. 2. Defendant is Earl W. Reidell, Jr., an adult individual, currently residing at 4 Crescent Court, New Cumberland, Cumberland County, Pennsylvania, having resided at this address temporarily since reassignment to the Ships Parts Control Center, Mechanicsburg Naval Depot, Mechanicsburg, Pennsylvania, and is subject to possible reassignment at any time. 3. Plaintiffs seek custody of the following child: Jacqueline Courtney Reidell, born January 21, 1984, presently residing at 4 Crescent Court, New Cumberland, Cumberland County, Pennsylvania. The child was not born out of wedlock. The child is presently in the custody of the Plaintiffs herein, who reside at the same address as stated in paragraph 1 above. During the past five years, the child has resided with the following persons and at the following addresses: Plaintiffs, Robert L. Hays and Sandra K. Hays, 4 Crescent Court, New Cumberland, Cumberland County, Pennsylvania, from birth until the present, with the exception of a two-month period of time in May and June of 1986, when the child and the natural mother resided at 211 Market Street, New Cumberland, Pennsylvania. The child resided with the Plaintiffs and natural mother until September 20, 1986, when the natural mother was deceased. Since November 14, 1986, until present, the Defendant has also resided with the Plaintiffs and the child. 4. The mother of the child is Sherri L. (Hays) Reidell, who is deceased, having died on September 20, 1986, in a car accident. She was separated at the time of her demise from the Defendant herein. The father of the child is the Defendant, Earl W. Reidell, Jr., who currently resides at 4 Crescent Court, New Cumberland, Pennsylvania, but is in the military service of the Navy and is temporarily reassigned to the Ships Parts Control Center at the Mechanicsburg Naval Depot, having prior thereto been aboard the USS Carl Sea. 5. The relationship of Plaintiffs to the child is that of natural maternal grandparents. The Plaintiffs currently reside at the address contained in paragraph 1, along with the child, and periodically the Defendant resides at that address. 6. The relationship of Defendant to the child is that of natural father, who currently maintains an address with the Plaintiffs, but periodically spends nights at addresses specifically unknown to the Plaintiffs. 7. Plaintiffs have 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. Plaintiffs have no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. Plaintiffs do not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 8. The best interest and permanent welfare of the child will be served by granting the relief requested, because: (a) Since the birth of the child, the child has resided with the Plaintiffs herein, who are the natural maternal grandparents of the child. (b) The natural mother of the child, who is now deceased, likewise resided with the Plaintiffs herein, along with the child. (c) The natural father, Defendant herein, has not resided since birth with the child, and resided only with his late wife for a period of one week after marriage. (d) The child does not know, nor is she familiar with the Defendant as being her natural father, and is further not accustomed to nor comfortable with the Defendant. (e) The Defendant herein has engaged in conduct indicating a lack of responsbility towards the child, including Dot residing with the child since birth; stopping child support at one point; irresponsibly handling financial affairs; engaging in intoxicants; being incarcerated at one point for the commissions of a crime; and otherwise, during his brief return, exposing the child to persons and environments which are not conducive to the best interest of the child. (f) the Plaintiffs herein have undertaken counselling with the child. It is believed and therefore averred that an evaluation of the child indicates that the best interest of the child is at the present time served by having custody of the child placed with the Plaintiffs. (g) Since return of the natural father, Defendant herein, the child has exhibited severe emotional and traumatic outbursts and further indicated a lack of desire to be with the Defendant while alone. (h) Otherwise, the Plaintiffs herein can serve the best interest and general well-being of the child. 9. Each person whose parental rights of the child have been named in this Complaint. 10. Plaintiffs believe and therefore aver that the Defendant may attempt to unilaterally remove the child from her present residence, which move Plaintiffs have been advised by the counsellor would be extremely detrimental to the present health and well-being of the child. Plaintiffs request the Court to grant temporary leave in the form of custodial rights pending the disposition of this Complaint. WHEREFORE, Plaintiffs request this Honorable Court to enter an Order granting custody of the child to the Plaintiffs, and further granting Plaintiffs temporary leave in the form of custodial rights pending the disposition of this Complaint. RESPECTFULLY SUBMITTED: p~..~ Ri~ch~rd Wagner, Esq. MANCKE, LIGHTMAN & WAGNER 2233 North Front Street Harrisburg, Pennsylvania Phone: (717) 234-7051 ATTORNEY FOR PLAINTIFFS 17110 true and eorrec't, I unders'tand 'that false sta'tement;; he'l.~e:i.l'l ;l'r~ lu~ld(~ :~ubjec'~ '~o :he penalUies of 18 Pa,C,S, § 4904, rela'~ing '~o unsworn fa].sifica~ion to a'u'ghori':ies. In the Court of Common Plea~ of Cumberland County, Pa. No. 83 Civil 1987 In Custody ROBERT L. HAYS and SANDRA K. HAYS, his wife, Plaintiffs, Ye EARL W. REIDELL, JR., Defendant PETITION AND ORDER OF COURT EAKIN & EAKIN ATTORNEYS AT LAW MARKET BCIUARE BUILDING MEP-HANIE:SBURG, PA. 17055 ROBERT L. HAYS and SANDRA K. HAYS, his wife, Plaintiffs, EARL W. REIDELL, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 83 CIVIL 1987 CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this ~ day of ~-c~_~_ , 1987, a Rule is issued upon Plaintiffs to show cause why the child, Jacqueline Reidell, should not be permitted to attend the wedding of her father June 20, 1987, pursuant to a grant of temporary custody. By the Court, ROBERT L. HAYS and SANDRA K. HAYS, his wife, Plaintiffs, EARL W. REIDELL, JR., Defendant : IN THE COURT OF COMMON PLEAS OF ) CUMBERLAND COUNTY, PENNSYLVANIA : NO. 83 CIVIL 1987 CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this ~ day of.. ~.~_ a Hearing on the issue of custody is set for the lO~ day of ~~ , 1987, at ~_. M., in Court Room No. ~ , 1987, ~'~ o'clock, Cumberland County Court House, Carlisle, Pennsylvania. By the Court, / ROBERT L. HAYS and SANDRA K. HAYS, his wife, Plaintiffs, EARL W. REIDELL, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 83 CIVIL 1987 CIVIL ACTION - LAW IN CUSTODY PETITION COUNT I 1. A Complaint for Custody in the above-captioned mat- ter was filed January 14, 1987. 2. The matter was continued generally without Hearing at the request of the parties, anticipating an amicable resolu- tion. 3. The Plaintiffs are the parents of the natural mother of the child; the Defendant is the natural father of the child. The natural mother is deceased. 4. Defendant plans to marry on June 20, 1987. 5. The Plaintiffs, granted temporary custody by the Court without Hearing, have refused to allow Defendant's daughter to attend said wedding. 6. It is in the best interest of the child to be present at the marriage of her natural father. -1- WHEREFORE, Defendant respectfully requests the Court to grant him temporary custody of the child on June 20, 1987. COUNT II 7. The parties have undergone counseling with Stanley Schneider, who is attempting to facilitate a permanent custody situation between the parties and the child. cus to dy. 8. The parties are unable to agree on a schedule of 9. It is in the best interest of the child that her natural father be granted primary physical and legal custody, subject to a reasonable period of transition from the present situation~. 10. It is in the best interest of the child that the parameters of transition be set forth. WHEREFORE, the Defendant respectfully requests your Honorable Court to set a Hearing to establish general parameters for a period of transition of custody. Respectfully submitted, J. Mi~ha'~i ~Eakin Attorney for Defendant -2- I verify that the statements made in the foregoing Petition are true and correct. I understand that false state- ments herein are made subject to the penalties of 18 Pa. C. S. 4904, relating to unsworn falsification to authoritites. Dated: June ~ , 1987 -3- ROBERT L. HAYS and SANDRA K. HAYS, his wife, Plaintiffs vs EARL W. REIDELL, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 83 CIVIL 1987 CIVIL ACTION - LAW CUSTODY IN RE: PETITION FOR TEMPORARY CUSTODY BEFORE THE HONORABLE KEVIN A. HESS, JUDGE JUNE 16, 1987 APPEARANCES Robert & Sandra Hays Barbara Flum Stein, Esq. Earl W. Reidell, Jr. j. Michael Eakin, Esq. Plaintiffs/Respondents For the Plaintiffs Defendant/Petitioner For the Defendant 83 Civil 1987 FOR THE PETITIONER Earl W. Reidell, Jr. INDEX TO WITNESSES DIRECT CROSS REDIRECT 3 10 12 RECRO S S COURT 13 FOR THE RESPONDENT Robert L. Hays 17 24 29 30 Jacqueline Reidell 33 2 83 Civil 1987 THE COURT: The record should reflect I chambers and I understand the issues involved. to go ahead. June 16, 1987 Carlisle, Pennsylvania met with counsel in Mr. Eakin, do you want EARL W. REIDELL, JR. having been duly sworn, accord- ing to law, testified as follows: BY MR. EAKIN: Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. DIRECT EXAMINATION Will you state your full name, please? Earl W. Reidell, Jr. Where do you live, Mr. Reidell? I live at 113 Woerster Avenue, Apartment 6, Harrisburg. Where do you work? I work at Mechanicsburg Ships Parts Control Center. Are you in the Navy? Yes, sir. What is your rank there? I am a Machinist Mate Third Class, E-4, Petty Officer. Do you have a daughter? Yes, I do. 3 83 Civil 1987 Q. What is her name? A. Jacqueline Courtney Reidell. Q. What is her date of birth? A. January 21, 1984. Q. Is the natural mother of the child deceased? A. Yes, she is. Q. And did she die about nine months ago? A. Yes. Q. ao area? A. Q. At the time is it correct that the natural mother and your daughter were living with her mother and father? That' s correct. And is that Mr. and Mrs. Hays, who are here? Yes, sir. And where were you at the time? I was in Norfolk, Virginia. Is that where you were stationed? I was stationed on the U.S.S. Coral Sea. Following the death of the child's mother did you return to this Yes, I did. And have you been seeking to reestablish your ties with your daughter? 4 83 Civil 1987 MS. STEIN: Your Honor, I am going to object to this line of question- It is a leading form of question. Overruled. ing. THE COURT: BY MR. EAKIN: Q. since? A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. Go ahead, are you trying to reestablish ties with your daughter Yes, I have been trying to. Are you planning to remarry? Yes, I am. And to whom are you getting married? Barbara Ann Markowitz. And is that the lady seated to my right? Yes, sir. Is it correct that she is pregnant with your child at the present? Yes, it is. And what date have you selected for the wedding? June 20, 1987. Do you recall when you picked that date? About a month and a half, two months ago. Do you recall when you first alerted Mr. and Mrs. Hays to the date yourself? A. About two or three weeks ago. 83 Civil 1987 Q. Did you do so at a counseling session? A. Yes, I did. Q. And before whom was your counseling session? A. D~. Schneider. Q. Have you been seeing him in connection with the Hays and your daughter for several months? A. Yes, I have. Q. Had you set the date before then? A. Yes, I have. Q. When you told th~n the date what reaction did you get? A. -They told me that I couldn't have my daughter in the wedding because they were planning on going on vacation that week. They were going to vacation when? They said that they were going on vacation from June 18 to the A. 23rd. Q. A. Q. A. Was that the first you had heard about that vacation? No, it wasn't. When had you first heard about that vacation? One night I took Jackie home and they informed me that that Monday following that I wasn't going to be able to pick her up because she had an appointment and for some reason the date of June 20th was separately said that I was not going to have Jack~, and they said I was 6 83 Civil 1987 not going to have Jackie from the 18th to the 23rd. Q. Do you recall when this Monday night was, how long before your session with Dr. Schneider? A. I guess it was about a week, week and a half, two weeks, some- thing like that. Q. Had you set the June 20th date for the wedding at that time? A. It was set before that time. Q. So you had already set the 20th? A. Yes. Q. Was there any discussion between you and the Hays at that point about your getting married? A. Before we talked? Q. I'm talking about this Monday night or so, a week before the session. A. No, I had never said nothing to them about it. Q. Had they said anything to you about your getting married? A. No, they didn't. Q. Had they asked questions about it of you? A. No, they haven't. Q. How did this discussion about the 20th come up? Who said what? A. Well, when it was told to me it was told that I was not going to have Jackie on the 20th. 83 Civil 1987 20th? A. Q. A. Q. A. Q. wedding? A. Q. A. Q. A. Was that date specifically mentioned? Yes, it was. And you had already set that as your wedding date? Yes, it was. But you hadn't told them? No, I didn't. Did you tell them then, that night, when you heard that? No, not that night I didn't. What are your wedding plans? What time is your service on the It's going to be at two o'clock. And where is it going to be? At Olivet Presbyterian Church in Harrisburg. Is there a rehersal for the wedding? Yes, Friday night before, at 6:30. Is it your desire to have your daughter participate in the Yes, it is. In what capacity? What would she do in the wedding? She would be a flowergirl. Have you requested the Hays to allow her to participate? Yes, I did. 8 83 Civil 1987 Q. What was their reaction? A. They said that they already have plans to go away, until they found out what the date was; then they said that I planned it out that it was nine months to the date Sherry died. Q. In other words, her death would be nine months exactly before the wedding? A. Yes. Q. They said that? A. Yes. Q. Did you realize that before? A. Not at the time I didn't, until it was set. Q. Did that have any bearing on your setting the wedding date? A. No. Q. Did the Hays consult you before setting their vacation date? A. No, they didn't. Q. If they were not on vacation would you anticipate having the child during that period anyhow? A. Yes. Q. Did they tell you where they' re going in Virginia? A. No, they just... 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