HomeMy WebLinkAbout06-2847
DAVID L. RYDER, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: CIVIL ACTION - LAW
: CUSTODYNISITATION
MONICA J, BARNHART,
Defendant
: NO, 06-~ CIVIL TERM
COMPLAINT FOR CUSTODY
I. The Plaintiff is Dave L. Ryder, Jr., residing at 541 Newville Rd., Shippensburg,
Cumberland County, Pennsylvania 17257.
2, The Defendant is Monica J. Barnhart, residing at 560 South Main Street,
Chambersburg, Franklin County, Pennsylvania 17201.
3. Plaintiff seeks custody of the following children:
NAME
RESIDENCE
DOB
AGE
Tristan Jov Ryder
541 Newville Rd.. Shiooensburg. PA 08/23/96
9 yrs. 9 months
Caleb Lyle Ryder
541 Newville Rd.. Shiooensburg. PA 06/07/98
7yrs.ll months
4. The children were not born out of wedlock.
5. The children are presently in the custody of the Father, David L. Ryder, Jr.
6. During their life, the children have resided with the following persons and at the
following addresses:
NAME
ADDRESS DATES
Father
541 Newville Rd., Shippensburg July 1998 to Present
Mother and Father
541 Newville Rd., Shippensburg July 1998 to Aug.2004
7. The mother of the child is Monica J. Barnhart, currently residing at 560 South Main
Street, Chambersburg, Pennsylvania 17201. She is unmarried.
8. The father of the child is David L. Ryder, Jr., currently residing at 541 Newville Rd,
Shippensburg, Pennsylvania 17257. He is unmarried.
9. The relationship of the Plaintiff to the children is that of Father. The Plaintiff
currently resides with the following persons: Stacy Allen (girlfriend), Kyle Allen (girlfriend's
son), and Jeff Sites (girlfriend's son),
10. The relationship of the Defendant to the children is that of Mother. The Defendant
currently resides with the following persons: Unknown adult male (boyfriend) arrl infant
female child.
11. 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.
12, Plaintiff has no information of a custody proceeding concening the children pending
in a court of this Commonwealth.
13. 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 respect to the chila-en.
14. The best interest and permanent welfare of the children will be served by granting the
relief requested for the following reasons:
A. Plaintiff has undertaken and performed the primary parental responsibilities
for the children; and
B. Plaintiff is best able to provide the care and nurture which the children need
for healthy development; and
C. Plaintiff desires to maintain the family housemld which has been established,
and the continued stability of the household is in the best interest ofthe children.
D. Children have been, and wish to continue, their enrollment in the Cumberland
County School System at James Burd Elementary School, Shippensburg, Pennsylvania.
15. Each parent whose parental rights to the children have not been terminated and the
person who has physical custody of the children has been named as parties to this action.
R
Paul Bradford Orr, Esquire
Attorney for Plaintiff
50 East High Street
Carlisle, PA 17013
Telephone: (717) 258-8558
Supreme Court ID No. 71786
WHEREFORE, Plaintiff requests the
subject to structured partial custody by the Defi
VERIFICATION
I 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.
DATEo,'j-/L'126 <<~
David I. Ryder, ., e" er
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DAVID L. RYDER, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: CUSTODYNISITATION
MONICA J. BARNHART,
Defendant
: NO. 06-2847
CIVIL TERM
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF CUMBERLAND )
AND NOW, this 23rd day of May, 2006, I, Paul Bradford Orr, attorney for David L. Ryder,
Jr., Plaintiff, in the above-captioned action, hereby swear that I have served a true copy of the
Custody Complaint, executed by the Plaintiff in the above-captioned matter, upon the Defendant
by depositing the same in the U.S. Mail, postage prepaid, certified, return receipt rEquested.
The original return receipt card signed by Monica J. Barnhart on May 22, 2006, indicating
service was effected, is marked Exhibit "A", attached he
Dated: S
and made a part hereof.
By:
Paul Bradfor' rr, squire
Attorney for Plaintiff
50 East High Street
Carlisle, PA 17013
(717) 258-8558
I.D. #71786
/"
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EXHIBIT "A"
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DAVID L. RYDER, JR.
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
06-2847 CIVIL ACTION LAW
MONICA J. BARNHART
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Friday, May 26, 2006
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, June 27, 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 hearin2.
FOR THE COURT,
By: Isl
ac ueline M. Veme 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 17013
Telephone (717) 249-3166
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DAVID L. RYDER, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 2006-2847 CIVIL ACTION. LAW
MONICA J. BARNHART,
Defendant
: IN CUSTODY
ORDER OF COURT
AND NOW, this 'l "\ '" day of l' v \
consideration of the attached Custody Conciliation Re
follows:
, 2006, upon
rt, it is ordered and directed as
1. The Father, David 1. Ryder, Jr. and the Mother, Monica J. Barnhart, shall
have shared legal custody of Tristan Jay Ryder, born August 23, 1996 and Caleb Lyle
Ryder, born June 7, 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
Children's general well-being including, but not limited to, all decisions regarding his
health, education and religion, Pursuant to the terms ofPa,C.S, ~5309, each parent shall
be entitled to all records and information pertaining to the children including, but not
limited to medical, dental, religious or school records, the residence address of the
children and the other parent. To the extent one parent has possession of any such
records or information, that parent shall be required to share the same, or copies thereof,
with the other parent within such reasonable time as to make the records and information
of reasonable use to the other parent. Both parents shall be entitled to full participation in
all educational and medical/treatment planning meetings and evaluations with regard to
the minor children, Each parent shall be entitled to full and complete information from
any physician, dentist, teacher or authority and copies of any reports given to them as
parents including, but not limited to: medical records, birth certificates, school or
educational attendance records or report cards, Additionally, each parent shall be entitled
to receive copies of any notices which come from school with regard to school pictures,
extracurricular activities, children's parties, musical presentations, back-to-school nights,
and the like.
The parents agree that the children are to attend Shippensburg School Distrcit
schools.
2, Beginning Sunday, July 23, 2006, the parties shall have shared physical
custody of the children on a week on/week offbasis with Father having the first week,
The day and time of exchange shall be Sundays at 12:00 noon.
,
3. Transportation shall be shared such that the parties shall exchange custody
at the Sheetz in Green Village on Route II,
4, Holidays:
A, Thanksgiving shall be shared such that Mother shall always have
physical custody of the children from 9:00 a.m. to 3:00 p.m. and
Father shall always have physical custody of the children from 3:00
p,m. to 9:00 p.m,
B. Christmas shall be divided into two Blocks. Block A shall be from
12:00 noon on Christmas Eve to 12:00 noon on Christmas Day, Block
B shall be from Christmas Day at 12:00 noon to December 26 at 12:00
noon. Father shall always have physical custody ofthe children for
Block A and Mother shall always have physical custody of the
children for Block B,
C. Mother's Day/Father's Day. Mother shall have physical custody of
the children on Mother's Day from 9:00 a,m. to 5:00 p.m, Father shall
have physical custody of the children on Father's Day from 9:00 a,m.
to 5:00 p,m.
5, 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
consent. In the absence of mutual consent, the terms of this Order shall control. Another
Custody Conciliation Conference is scheduled for October 30, 2006 at 9:30 a.m,
BY THE COURT,
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J.
cc: Paul Bradford Orr, Esquire, Counsel for Father
Michael J. Connor, Esquire, Counsel for Mother
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DAVID L. RYDER, JR.,
Plaintiff
JUll 9 200~
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 2006-2847
CIVIL ACTION - LAW
MONICA J. BARNHART,
Defendant
: IN CUSTODY
PRIOR JUDGE: None
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 Children who are the subject of
this litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Tristan Joy Ryder
Caleb Lyle Ryder
August 23, 1996
June 7,1998
shared
shared
2. A Conciliation Conference was held in this matter on July 18, 2006, with
the following in attendance: The Father, David L. Ryder, Jr., with his counsel, Paul
Bradford Orr, Esquire, and the Mother, Monica J. Barnhart, with her counsel, Michael J.
Connor, Esquire.
3,
The parties agreed to an Order in the form as attached.
7-/K'tJ1r>
Date
~~:~~
Custody Conciliator
NOV 18 2006 fit
DAVID L. RYDER, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
V.
: NO. 2006-2847 CIVIL ACTION - LAW
MONICA J. BARNHART,
Defendant
: IN CUSTODY
I
~ER OF COURT
,
,
,
AND NOW, this 28th day o~November, 2006, the parties having advised the
,
I
Conciliator that they are satisfied with the current Order of Court, the Conciliator hereby
I
I
relinquishes jurisdiction in this ma~er.
I
,
FOR THE COURT,
Conciliator
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL, ACTION - LAW
DAVID L. RYDER, JR,
Plaintiff
v.
MONICA J. BARNHART,
Defendant
No.
06- -7017
elej
Petition for Contempt
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1. Petitioner is Defendant, MONICA J. BARNHART, who currently resits anl9C
Black Gap Road Lot 122, Fayetteville, Franklin County, PA 17222.
2. Respondent is Plaintiff, DAVID L. RYDER, JR, who currently resides at 543
Newville Road, Shippensburg, Cumberland County, PA 17257.
3. Petitioner and Respondent are the natural parents of the following child:
Name Age
CALEB L. RYDER 16 years
4. A custody order was entered on 2005, in the Cumberland County Court of
Common Pleas. A copy of the custody order is attached.
5. Respondent has willfully violated the custody order, as follows: the father did not
meet me on July 6th and July 20th to meet me at designated place of dropoff. Father was
notifued both times and never responded or showed up with my son Caleb.
WHEREFORE, Petitioner respectfully requests that this Court find Respondent in
contempt of Court.
Date: I [01 001 `I
021
00 3001,7
Petition for Contempt Pale 3 of 5
Verification
I, MONICA J. BARNHART, Defendant, verify that the facts stated in the foregoing
Petition are true and correct to the best of my knowledge, information and belief. Petitioner
understands that false statements therein are subject to the penalties of 18 Pa. C.S.A. §4904
relating to unsworn falsification to authorities.
Date: ?Si(9Id-O\t4
,4(... el\Jko,----
MONICA J. B
„„ki.4--
T, Defendant
Petition for Contempt Page 4 of 5
Davi L Rjckr3c IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PA
Vs No. at 04-gv, CIVILAEF013 —,
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MOn I Cr", j 6akfr\ka4 , •
. CIVIL ACTION - LAW -1-1
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Defendant •
. IN CUSTODY
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CRIMINAL RECORD / ABUSE HISTORY VERIFICATION
zcD
0(11Ca 60t,Onhaet , hereby swear or affirm, subject to penaltrO, ofc_n
law including 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities that:
1. Unless indicated by my checking the box next to a crime below, neither I nor any other
member of my household have been convicted or pled guilty or pled no contest or was
adjudicated delinquent where the record is publicly available pursuant to the Juvenile
Act 42 Pa.C.S. § 6307 to any of the following crimes in Pennsylvania or a substantially
equivalent crime in any other jurisdiction, including pending charges:
Check
all that
apply
Crime
18 Pa.C.S. Ch. 25
(relating to criminal
homicide)
r— 18 Pa.C.S. §2702
(relating to aggravated
assault)
18 Pa.C.S. §2706
(relating to terroristic
threats)
r— 18 Pa.C.S. §2709.1
(relating to stalking)
17 18 Pa.C.S. §2901
(relating to kidnapping)
Self Other Date of Sentence
household conviction,
member guilty plea, no
contest plea or
pending charges
18 Pa.C.S. §2902 ET
(relating to unlawful
restraint)
fT 18 Pa.C.S. §2903 IT ri
(relating to false
imprisonment)
ET 18 Pa.C.S. §2910 ET
(relating to luring a
child into a motor
vehicle or structure)
18 Pa.C.S. §3121 IT fl
(relating to rape)
18 Pa.C.S. §3122.1
relating to statutory
sexual assault)
18 Pa.C.S. §3123 FT
(relating to involuntary
deviate sexual
intercourse)
18 Pa.C.S. §3124.1
(relating to sexual
assault)
FT 18 Pa.C.S. §3125 .17
(relating to aggravated
indecent assault'
18 Pa.C.S. §3126 IT
(relating to indecent
assault)
18 Pa.C.S. §3127
(relating to indecent
exposure)
fl
D. 18 Pa.C.S. §3129
(relating to sexual
intercourse with animals)
fl 18 Pa.C.S. §3130
(relating to conduct
relating to sex
offenders}
18 Pa.C.S. §3301 fl
(relating to arson and
related offenses)
fl 18 Pa.C.S. §4302
(relating to incest)
18 Pa.C.S. §4303 fl
(relating to concealing
death of child)
fl 18 Pa.C.S. §4304
(relating to endangering
welfare of children)
18 Pa.C.S. §4305
(relating to dealing
in infant children}
fT 18 Pa.C.S. §5902(b)
(relating to prostitution
and related offenses)
n
fl 18 Pa.C.S. §5903 fl E
(c) or (d)
(relating to obscene
and other sexual materials
and performances)
18 Pa.C.S. §6301
(relating to corruption
of minors)
18 Pa.C.S. §6312 E E
(relating to sexual
abuse of children)
18 Pa.C.S. §6318 (-I
(relating to unlawful
contact with minor)
18 Pa.C.S. §6320 f
(relating to sexual
exploitation of children)
23 Pa.C.S. §6114
(relating to contempt for
violation of Protection
order or agreement)
Driving under the
influence of drugs
or alcohol
fl
r Manufacture, sale, 7
delivery, holding,
offering for sale or
possession of any
controlled substance or
other drug or device
2. Unless indicated by my checking the box next to an item below, neither I nor any other
member of my household have a history of violent or abusive conduct including the
following:
Check Self Other
all that household
apply member
A finding of abuse by a Children & Youth r E
Agency or similar agency in Pennsylvania
or similar statute in another jurisdiction
Abusive conduct as defined under the FI f
Protection from Abuse Act in
Pennsylvania or similar statute in
Date
another jurisdiction
Other: f! fl
3. Please list any evaluation, counseling or other treatment received following conviction
or finding of abuse:
4. If any conviction above applies to a household member, not a party, state that person's
name, date of birth and relationship to the child :
5. If you are aware that the other party or members of the party's household has or have a
criminal / abuse history, please explain:
1 verify that the information above is true and correct to the best of my knowledge
information or 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.
nnl Cb, S rnho,K--f -
Printed Name
i
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DAVID L. RYDER, JR,
Plaintiff
v.
MONICA J. BARNHART,
Defendant
)
)
) No a ,2g9? ea,„")
)
Certificate Of Service
I MONICA J. BARNHART, Defendant in the above matter, hereby certify that on
0 O3 U St I r e i g , I mailed a true and correct copy of the Petition for
Contempt, by certified mail, return receipt requested, restricted delivery, and another copy of the
same document by first class mail, postage prepaid, to:
c
DAVID L. RYDER, JR -v 3
543 Newville Road z m27Mom, ,
Shippensburg, PA 17257 u' Tura-,
I certify that (check ALL of the following which are true):
Certified mail:
[X] The green and white sender's receipt is attached. (ATTACH receipt.)
[ ] The green recipient's receipt is attached; DAVID L. RYDER, JR signed the certified mail
receipt on (ATTACH receipt.)
The certified mail was returned to me unsigned, with the notation that the certified mail
was: [ ] refused
[ ] unclaimed
[ ] other notation:
Neither the certified mail envelope nor the certified mail receipt was returned to me.
CD
nom:.
Zt
[]
Regular mail:
[]
[]
The regular mail has not been returned to me.
The regular mail was returned to me, with the notation:
Certificate of Service Page 1 of 3
I verify that the information in the Certificate of Service is true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904, relating to
unsworn falsification to authorities.
Date: .81(191 11A
STAPLE OR TAPE THE CERI1F IED MAIL RECEIPTS BELOW:
U.S. Postal Servicer.
CERTIFIED MAILTM RECEIPT
(Domestic Mail Only; No Insurance Coverage Provided)
For delivery information visit our website at www.usps.come
•
Postage
Certified Fee
Retum Receipt Fee
(Entorsement Required)
Racted Delivery Fee
(Endorsement Required)
Tole! Postage & Fees
$3.330
$2.70
$5.05
$11.54
J
10 .
Postmark
Here
08/06/2014
e
Sent To
Street, Apt No.;
or PO Box No.
City, State, ZIP+4
PS Form 3800, August 2006
See Reverse for Instructions
GREEN RECEIPT WITH DAVID L. RYDER, JR'S SIGNATURE
Certificate of Service Page 2 of 3
DAVID L. RYDER, JR. IN THE COURT OF COMMON PLEAS OF
PLAINTIFF
V.
MONICA J. BARNHART
DEFENDANT
AND NOW,
CUMBERLAND COUNTY, PENNSYLVANIA, =-
2006-2847 CIVIL ACTION LAW -vim ...L--- = -;
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IN CUSTODY c�
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ORDER OF COURT 3'
Friday, August 08, 2014 , upon consideration of the attached Complaint, it is
hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, August 27, 2014 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. 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.
You must file with the Court a verification regarding any criminal record or abuse history regarding you and
anyone living in your household on or before the initial in-person contact with the court (including, but not limited to,
a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition.
No party may make a change in the residence of any child which significantly impairs the ability of the other party
to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and
Pa.R.C.P. No. 1915.17 regarding relocation.
FOR THE COURT,
By: /s/ Jacqueline M. Verney, 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.
I Cumberland County Bar Association
/�1'�% l 32 South Bedford Street
Carlisle, Pennsylvania 17013
cz.5 jj' el4 Pis Telephone (717) 249-3166
ry p
DAVID L. RYDER, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2006-2847 CIVIL ACTION -LAW
MONICA J. BARNHART, C__
r-
Defendant IN CUSTODY =� r~;'
-<D
ORDER OF COURT c c - 3
A r, _
AND NOW, this day ofy g s� , 2014, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. Mother's Petition for Contempt is hereby dismissed.
2. The prior Order of Court dated July 24, 2006 is hereby vacated.
3. The Father, David L. Ryder, Jr. and the Mother, Monica J. Barnhart, shall
have shared legal custody of Caleb Lyle Ryder, born June 7, 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 of
Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to
the child including, but not limited to medical, dental, religious or school records, the
residence address of the child and the other parent. To the extent one parent has
possession of any such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent. Both parents shall be
entitled to full participation in all educational and medical/treatment planning meetings
and evaluations with regard to the minor child. Each parent shall be entitled to full and
complete information from any physician, dentist, teacher or authority and copies of any
reports given to them as parents including, but not limited to: medical records, birth
certificates, school or educational attendance records or report cards. Additionally, each
parent shall be entitled to receive copies of any notices which come from school with
regard to school pictures, extracurricular activities, children's parties, musical
presentations, back-to-school nights, and the like.
4. Father shall have primary physical custody of the child.
5. Mother shall have periods of partial physical custody as agreed by the
parties.
6. RELOCATION: No party shall be permitted to relocate the residence of
the child which significantly impairs the ability to exercise custody unless every
individual who has custodial rights to the child consents to the proposed relocation or the
court approves the proposed relocation. A person proposing to relocate MUST comply
with 23 Pa. C. S. § 5337.
7. This Order is entered pursuant to a Custody Conciliation Conference. The
parties may modify the provisions of this Order by mutual consent.
BY THE COURT,
J.
cc' Monica J. Barnhart, pro se
198 Black Gap Road Lot 122
Fayetteville, PA 17222
Paul Bradford Orr, Esquire, Counsel for Father
l prJ1es 1 Lfr—L
DAVID L. RYDER, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2006-2847 CIVIL ACTION - LAW
MONICA J. BARNHART,
Defendant : IN CUSTODY
PRIOR JUDGE: M. L. Ebert, Jr., J.
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 Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Caleb Lyle Ryder June 7, 1998 Father
2. A Conciliation Conference was held in this matter on August 27, 2014,
with the following in attendance: The Father, David L. Ryder, Jr., with his counsel, Paul
Bradford Orr, Esquire. The Petitioner, Mother, Monica J. Barnhart, did not attend.
3. The Honorable M. L. Ebert, Jr., previously entered an Order of Court
dated July 24, 2006 providing for shared legal custody and shared physical custody.
Mother filed a Petition for Contempt, but did not attend the Conference.
4. Father requested an Order in the form as attached.
� 7
Date gacWline M. Verney, Esquire
Cus ody Conciliator