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Home My WebLink About06-2578 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'IY, PENNSYLVANIA ClVlLACflON - LAW RYAN REIDELL, Plaintiff . . v. : : NO. 0 (, . -2.5'1 i c.;;JJ;.- : NATALIE REPMAN, Defendant : IN CUSTODY NOTICE TO DEFEND You, Natalie Repman, Defendant, have been sued in Court to obtain custodyofKolby Neaves Reidell, YOU SHOULD TAKE THIS PAPER TOYOURLAWYERATONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACf OF 1990 The Court of Common Pleas of Cumberland Countyis 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 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, PA 17013 (717) 249-3166 1-800-990-9108 Maryann Murphy, Esquire PMB 246 4902 Carlisle Pike Mechanicsburg, PA 17050 (717) 730-0422 INUlE COURT OF COMMON PLEAS OF CUMBERLAND COUN'IY, PENNSYLVANIA CIVIL AcrION . LAW RYAN REIDELL, Plaintiff . . . . : v. ot, _ ,;J~? f c;;J 7'"u- : NO. . . NATALIE REPMAN, Defendant : : IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, RYAN REIDELL, by and through his attorney, Maryann Murphy, &quire, and respectful1yfiles this Complaint for Custody, and in support thereof avers as follows: 1, The Plaintiff is RYAN REIDELL who resides at 604 Erford Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is NATALIE REPMAN who currently resides at 227 Gettysburg Street, Dillsburg, York County, Pennsylvania 17019. 3. The Plaintiff seeks shared legal and prinlluy physical custody of the following KOLBY NEA YES REIDELL, born September 5, 1998 The child was born out of wedlock. He currently resides with the Plaintiff, During the lifetime of the child, he has resided at the following addresses with child: 4. 5. the following persons: TIme Address With Whom birth-1999 Hampden Township Plaintiff and Defendant Mechanicsburg, P A 1999-2002 E. Pennsboro Township Plaintiff and Defendant Camp Hill, PA 2002-2003 Dillsburg, P A Defendant and her husband 2003-March 2006 Dillsburg, P A Defendant, her husband and their child March 2006-present 604 Erford Road Plaintiff and his parents Camp Hill, PA 6, The father of the child is RYAN REIDELL. He is single. 7. The mother ofthe child is NATALIE REPMAN. She is married. 8. The child currently resides with the Plaintiff. 9. The Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the child in this or any other Court, except as set forth above. 10, The Plaintiff has no information of a custodyp~ing concerning the child pending in a Court of this Commonwealth or any other Court. 11. The Plaintiff does 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, 12. Each parent whose parental rights to the child have not been terminated, and the persons who have physical custody of the child, have been named as parties to this action. There are no other persons known to have or claim a right to custody or visitation of the child and therefore, no further notice of the pendency of this action and the right to intervene shall be given, other than to the parties named herein. 13. The best interest and permanent welfare of the minor child will be served by granting Plaintiff shared legal and primary physical custody. WHEREFORE, Plaintiff requests this Honorable Courtto grant him shared legal and primary physical custody of KOLBY NEA YES REIDEll., born September 5, 1998, Respectfully submitted, L~~~~' PMB 246 4902 Carlisle Pike Mechanicsburg, PA 17050 (717) 730-0422 I.D. # 61900 Attorney for Plaintiff VERIFICATION I, RYAN REIDELL, verify that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S, 4904, relating to unsworn falsification to authorities, ~R~ RYAN REIDELL , ~~~ j~ ~~ ~ ~ ~ o ~ ~ f; $ i~;~~ ~'~:, ~ ~~ ~~! ~ Q-a 'PC: ~ ~ ~ ~ ~ RYAN REID ELL PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-2578 CIVIL ACTION LAW NATALIE REPMAN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 11, 2006 , 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, Mechanicsburl!, PA 17055 on Thursday, June 01, 2006 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin!!. FOR THE COURT. By: /s/ Dawn S. Sunda Es 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 infonnation 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 ~-#P~~~.l ~'5/J .~ ;Z ~ ~~ ?17-5/y ~ b' ~ ~ ....v ~ -PJ "7(/-5/,5' \lINVA1AS~,lf,!3d A1Nncn '",~,j:::tW'>lnO 6 i:: :8 Hd S I Wl900l AtlV10NOHlOcd 3Hi :lO 3:J!:J:lO--(B11::l ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVILACDON - LAW R.YAN RmDEIL, Plaintiff v. : NO. Dh-~5'195 (1At . . . . NATAUE KHPMAN, Defendant . . : IN CUSTODY NOTICE TO DEFEND You, Natalie Repman, Defendant, have been sued in Court to obtain custody ofKolby Neaves Reidell. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYERAT ONCE. IF YOU 00 Nor HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO EUGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 AMERICANS WITH DISABILITIHS ACF OF 1990 The Court of Common Pleas of Cumberland County is required by lawtocomplywith 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 SHOULD TAKE THIS PAPER TO YOUR LAWYERATONCE. IF YOU 00 Nor 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, PA 17013 (717) 249-3166 1-80<>-99<>-9108 .. .... Maryann Murphy, Esquire PMB 246 4902 Carlisle Pike Mechanicsburg, P A 17050 (717) 730-0422 IN'IHE COURT OF COMMON PLEAS OF CUMBERLAND COUN'IY, PENNSYLVANIA CIVlLACI10N - LAW RYAN REIDELL, Plaintiff . . . . v. . . : NO. 06-2578 Civil . . NATALIE REPMAN, Defendant . . : IN CUSTODY AMENDED COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, RYAN REIDELL, by and through his attorney, Maryann Murphy, Esquire, and respectfully files this Amended Complaint for Custody, and in support thereof avers as follows: 1. The Plaintiff is RYAN REIDELL who resides at 604 Erford Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is NATALIH REPMAN who currently resides at 227 Gettysburg Street, Dillsburg, York County, Pennsylvania 17019. 3. The Complaint for Custody was filed on May 5, 2006. 4. The original Complaint incorrectly states the child's name as Kolby Neaves Reidell. The correct name of the minor child involved in this action is KOBY NEAVES REIDHLL. 5. Plaintiff hereby incorporates by reference all other averments contained in the original Complaint for Custody. - , WHEREFORE, Plaintiff requests that the Complaint for Custody, filed on May 5,2006, be amended to accurately reflect the minor child's name as KOBYNEA VFS REIDELL. Respectfully submitted, bJ:;/~/~ A. PMB 246 0 4902 Carlisle Pike Mechanicsburg, P A 17050 (717) 730-0422 J.D. # 61900 Attorney for Plaintiff ...... VHIUFICATION I, RYAN REIDELL, verify that the statements made in the foregoing Amended Custody Complaint are tme and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. ~~ RYAN REIDELL .... (") ~ ~,. r---.'l <= = c:;ro -rfP' s:;; -< N N o -n ~-n n1r= -urn ;1?,C[ 'c--; (.J ~'C ::r~l '~~E) ~5rn ~ ~ =< -0 -~... w .. N Plaintiff --..------ J l! " ..,~..- "C' ,-;,,-~uL)1 JUN 0 7 2006 I_-'-_='-e~~"LJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RYAN REIDELL vs, 06-2578 CIVIL ACTION LAW NATALIE REPMAN Defendant IN CUSTODY ORDER OF COURT AND NOW, this ,.3~ day of consideration ofthe attached Custody Conciliation , 2006, upon eport, it is ordered and directed as follows: 1, The Mother, Natalie Repman, and the Father, Ryan Reidell, shall have shared legal custody of Co by Neaves Reidell, born September 5, 1998, Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion, Pursuant to the terms ofthis paragraph each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information, 2, The Father shall have primary physical custody ofthe Child, 3, The Mother shall have liberal periods of visitation with the Child, with the specific times and dates to be arranged by agreement between the parties. The Mother's periods of custody with the Child shall be supervised by the Child's paternal grandparents, Larry and Gloria Reidell, the Father, or another adult familiar to the Child mutually selected by agreement between the parties, At such time as the Mother provides documentation from her psychologist/psychiatrist confirming that supervision is no longer necessary, the Mother shall have liberal periods of partial custody with the Child, without supervision, with the specific times and dates to be arranged by agreement between the parties, 4, Each party shall ensure that the other party has his or her current address and telephone number, 5, The non-custodial parent shall be entitled to have liberal and reasonable telephone contact with the Child. 6. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion ofthe Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision, . .. " 7, The Mother may file a petition requesting the scheduling of an additional custody conciliation conference to review the custodial arrangements set forth in this Order, if necessary, 8. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. J, cc: Maryann Murphy, Esquire - Counsel for Father Natalie Repman, Mother ~ ~ ~ -/3-0(, ~.~ !'-j ::'!'\r!J 9 Z : 11 Uti 8 I Hnr- 9GDl ^8VI0i\U:U~)l,d :3H1 :10 3~)I-1.'{)-{Enlj .. ;. , RYAN REIDELL Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, 06-2578 CIVIL ACTION LAW NATALIE REPMAN 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: 1, The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Coby Neaves Reidell September 5, 1998 Father 2, A custody conciliation conference was held on June 1, 2006, with the following individuals in attendance: The Father, Ryan Reidell, with his counsel, Maryann Murphy, Esquire. The Mother, Natalie Repman, did not attend the conference or contact the conciliator, According to the Father's counsel, the Mother received personal service of notice of the Father's complaint and scheduling of the conference, 3, The Father indicated at the conference that the Mother is not at this time able to provide primary care for the Child although the Father desires that the Mother continue to be involved in the Child's life, 4, Based upon the representations made by the Father at the conference and the fact that the Mother did not attend or contact the conciliator, the conciliator recommends an Order in the form as attached, which reflects the fact that the Mother may file a petition for the scheduling of an additional custody conciliation conference to review the custodial arrangements if she desires. ~ ,1). ~ODlD I ,U&7 Dawn S. Sunday, Esquir Custody Conciliator Date ... # RYANREIDELL :='~Ei\!~ ~ ~~:" ? (\ "i'.~5 " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. 06-2578 CIVIL ACTION LAW NATALIE REPMAN Defendant IN CUSTODY ORDER OF COURT AND NOW, this 5"" day of ~ ordered and directed as follows: ~ , 2006, it is The prior Order of this Court dated June 13,2006, is amended to reflect the ~orrect spelling of the Child's name as Koby Neaves Reidell, born September 5, 1998. Edward E. Guido J, cc: ~ann Murphy, Esquire - Counsel for Father V'atalie Repman, Mother \ I ~ ~ 50: & <) (' 'f/I j(,.. 'U " .,' ... ~ " (,