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Home My WebLink About06-5556 .. v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA NO. C>l.. - SS'S'- Ci()~L ~ €IL"Yl. PATRICIA A. RUMMEL, Plaintiff HARRY E. RUMMEL, Defendant CIVIL ACTION - LAW IN CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following 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 of divorce or annulment may be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown ofthe marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'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 LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE P A 17013 (717) 249-3166 Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. U sted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y pueda entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. U sted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE EST A DEMANDA A UN ABOGADO IMMEDIA T AMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, V A Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRIT A ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE PA 17013 (717) 249-3166 .. v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. Dl.. - 6' d u (, C!.t CJ J.... ~ 'CI2...">1 CIVIL ACTION - LAW IN CUSTODY PATRICIA A. RUMMEL, Plaintiff HARRY E. RUMMEL, Defendant COMPLAINT FOR CUSTODY AND NOW, comes the above-named Plaintiff, PATRICIA A. RUMMEL, by her attorney, Mark A. Mateya, Esquire, and seeks to obtain full custody of MEGAN RUMMEL and ABIGAIL RUMMEL. I. Plaintiff is PATRICIA A. RUMMEL, an adult individual who currently resides at 1882 Rachel Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. All legal papers may be served on Plaintiff by service on her Attorney, Mark A. Mateya, Esquire with a mailing address of P.O. Box 127, Boiling Springs, Pennsylvania 17007. 3. Defendant is HARRY E. RUMMEL, an adult individual who currently resides at 6018 Candlestick Drive, Harrisburg, Dauphin County, Pennsylvania 17112. 4. Plaintiff seeks full physical custody of MEGAN RUMMEL, born September 8, 1996, and ABIGAIL RUMMEL, born May 5, 1998, who currently reside with Plaintiff at 1882 Rachel Drive, Carlisle, Cumberland County, Pennsylvania 17013. 5. The children MEGAN RUMMEL, and ABIGAIL RUMMEL (hereinafter "Children) were born in wedlock. 6. The children are presently in the custody of Plaintiff at 1882 Rachel Drive, Carlisle, Cumberland County, Pennsylvania 17013. 7. During the past five years the children have resided with the following persons at the following addresses: A. From Birth to November 2005 at 1882 Rachel Drive, Carlisle, Cumberland County, Pennsylvania 17013, with Plaintiff and Defendant; B. From November 2005 to the present with Plaintiff. 8. The Father of the child, Harry E. Rummel, is currently residing at 6018 Candlestick Drive, Harrisburg, Dauphin County, Pennsylvania, and he is divorced. 9. The Mother of the child, Patricia A. Rummel, is currently residing at 1882 Rachel Drive, Carlisle, Cumberland County, Pennsylvania 17013, and she is divorced. 10. The relationship of the Plaintiff to children is that of natural mother. 11. The relationship of the Defendant to children is that of natural father. 12. The Plaintiff has not participated as a party or a witness, or in any other capacity, in ~ other litigation concerning the custody of the children in this or another Court. 13. Plaintiff has no information ofa custody proceeding concerning the children pending in a Court of this Commonwealth or any other state. 14. Plaintiff does not know of a person not a party to this custody proceeding who has physical custody of the children or claims to have custody or visitation rights with respect to the child. 15. The best interests and permanent welfare of the children will be served by granting the relief requested because: a. Plaintiff is the mother of the children. b. Plaintiff has been the primary caregiver of the children since their birth. c. Plaintiff can continue to provide a stable home for the children. d. Plaintiff can continue to provide financially for the children. e. Plaintiff assists the children with their schoolwork; f. Plaintiff can provide for the children emotionally; g. Plaintiff assists the children with their extra curricular activities; and ... h. Plaintiff will foster a healthy relationship between the children and Father. WHEREFORE, the Plaintiff requests this Honorable Court to grant custody grant custody according to the attached Custody Stipulation and Agreement reached by Mother and Father. Respectfully submitted, ili~.~ Mark A. Mateya Attorney I.D. No. 78931 P.O. Box 127 Boiling Springs, P A 17007 (717) 241-6500 Dated: q~lo ~ Attorney for Plaintiff VERIFICATION I, Patricia A. Rummel, verify that the facts set forth in the foregoing Complaint for Custody are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are subject to the penalties of 18 Pa. c.s. 94094, relating to unsworn falsification to authorities. DATED: q /; 3/0& / I WtwlOJ=r! g~pL Patricia A. Rummel ~ (:) --- r:J -- ~ ~ \t:- . C> \) - \ -0 lfJ ~ )J '\) ~ - ..,-- --t..... o C -7 ~;-. \J r::~~_{ f!'~: " ~:(,. rr~, '~"'('''' (; ');;.l':C_~_i :;~~7.- <.;, :r'"C Lc :1 ~ ~ c:-? ~ ~~ !:J :9. Pi. ',' "'r' N r) 6 N ~ -(', ....'C -n :-:) (') Zrn 9 ~ -0 :J: C,.,) ., ~ c.> PATRICIA A. RUMMEL PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-5556 CIVIL ACTION LAW HARRY E. RUMMEL DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, September 27,2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, October 13. 2006 , the conciliator, 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 hearinf!. FOR THE COURT. By: Isl Hubert X Gilro 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 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 17013 Telephone (717) 249-3166 -~ ~-# ~ ~ ~ ~kJ'6~./? , ~ :!' ~ ~h: 'JiJ'.p~ P ~ ~ :J!~~? f'P 1iJ.~.p V,!t'"JVt\ll,Si'\!N::3d A l' 'nr/- r1'!~';"~~\4:iHifinO ~ ..... 1\4 1 ;.'....i .. ' '. ," ; . _ _.,' ~ 9 D :2 ~ld 62 dJS 900l I \-i'if (\ \:\'1; ,i I ('He! 3Hl :JO ^;...J \ _~r~i "':' , .~~:::~~ ;~~I"'l,l :C!j:il,ru:J 1o.:J PATRICIA A. RUMMEL, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-5556 HARRY E. RUMMEL, Defendant CIVIL ACTION - LAW IN CUSTODY STIPULATION REGARDING CUSTODYNISITATION Plaintiff PATRICIA A. RUMMEL, hereinafter referenced as "Mother," and Defendant HARRY E. RUMMEL, hereinafter referenced as "Father," hereby agree to the following terms in an Order defining custody and partial custody rights and responsibilities in relation to MEGAN RUMMEL, born September 8, 1996, and ABIGAIL RUMMEL, born May 5, 1998 hereinafter referred to as "Children." WHEREAS, the parties desire the provisions of the present Custody Stipulation and Agreement to be approved by Your Honorable Court and entered as a Court Order with the same force and effect as though said Order had been entered after Petition, Notice and Hearing. NOW, THEREFORE, with the foregoing incorporated by reference, and intending to be legally bound, and in consideration of the mutual promises and agreements contained here, the parties agree as follows: 1. Mother and Father will share legal custody of the children as defined in 23 Pa. C.S.A. ~5302. All decisions affecting the children's growth and including but not limited to medical treatment, education and religious training, are major decisions which Mother and Father shall make jointly after discussion and consultation with each other. 2. As provided in 23 Pa. C.S.A. ~5309(a), each parent shall have full and complete access to the children's mental, dental, religious and school records. This includes the names, addresses and telephone numbers of all medical and other providers. 3. Mother shall have primary physical custody of the children subject to periods of partial physical custody with the Father as follows: A. Each Wednesday after school until 9 PM; B Every other weekend; Weekends are defined as Friday after school until Sunday at 6:00 p.m. C. One additional school-day evening with Father, as Father's schedule permits, subject to the following: a) that mother does not already have plans for the time requested by Father, and b)Father gives mother 48 hours notice prior to exercising additional time under this paragraph. D. At such other times as the parties mutually agree. E. Holidays: 1. The parties agree to alternate custody of the children on holidays, as follows: Each of the following holidays shall be split into two parts: Part A beginning after school the day before the holiday, or at 6 PM when school is not in session, until noon on the holiday; Part B will run from noon on the holiday until 9:00 PM of the holiday. This schedule shall apply to Easter, Fourth Of July, Thanksgiving, Christmas, and New Year's Day. In even numbered years, Father shall have Part A of Fourth of July and Christmas and Part B of Easter, Thanksgiving and New Year's Day. In odd numbered years, Father shall have Part A of Easter, Thanksgiving and New Year's Day and Part B of Fourth of July and Christmas. Ineven numbered years, Mother shall have Part A of Easter, Thanksgiving and New Year's Day and Part B of Fourth of July and Christmas. In odd numbered years, Mother shall have Part A of Fourth of July and Christmas and Part B of Easter, Thanksgiving and New Year's Day. 2. The entire Christmas vacation shall be split into two equal parts, with Mother and Father sharing custodial time equally. The party enjoying Part A, as described above, shall enjoy the first half of the Christmas vacation and the party enjoying Part B, as described above, shall enjoy the second half of the Christmas vacation, subject to paragraph 1 above. 3. Mother shall enjoy custody of the children on Mother's Day and Father shall enjoy custody of the children on Father's Day. 4. Children's birthday: Mother and Father agree to permit reasonable contact with the non-custodial parent during each of the children's birthdays. F. Vacation: Father and Mother shall each be entitled to exercise two uninterrupted weeks of vacation time, each week to be counted as seven consecutive days with the Children, each year. The parent wishing to exercise their weekes) of vacation custodial rights (either consecutively or non-consecutively) must request their vacation time in writing to the other party at least thirty (30) days in advance. The parent having vacation custodial rights shall provide the non-custodial parent with a telephone number where the children may be reached during the vacation. G. The Holiday schedule shall prevail in the event of a conflict between regular custody schedule and the Holiday schedule. 4. The parties each grant to the other the right of first refusal to care for the children, should he or she be unable to care for the children for his or her custodial time, such that the party would be forced to engage a babysitter. 5. The parties agree that the parent gaining custody will provide transportation. 6. The parties shall have reasonable telephone and e-mail contact with the children while in the other's custody. 7. Neither party shall make any disparaging remarks regarding the other party in the presence of the children. Additionally, neither party shall permit third persons to make disparaging remarks concerning the other party in the presence of the children. 8. The parties may modify this agreement by their mutual agreement. In the event of a disagreement between the parties as to a modification of any portion of this agreement, the Agreement as written herein shall prevail. Both parties are free to file a petition to modify this agreement at any time. 9. The parties hereto acknowledge that they have had the opportunity to consult an attorney prior to executing this Agreement. Father is unrepresented. Mother's attorney is Mark A. Mateya, Esquire. 10. The parties hereto agree that this Agreement shall be recorded and incorporated into an Order enforceable by the Court. 10/ U/O!/ I ' Date ~trjJfj(L)dI J24J1~ L PATRICIA A. RUMMEL J(Mf~ I- &~S 10/&/0& Date I I Date HARRY E. RUMMEL Date Witness COMMONWEAL TH OF PENNSYLVANIA SSe COUNTY OF DAUPHIN On this 6th day of October, 2006, before me the undersigned authority, personally appeared PATRICIA A. RUMMEL known to me to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purpose therein contained. IN WI1NESS WHEREOF, I have hereunto set my hand and seal. ~WUL ~UV~ I otary Public My Commission Expires: NOTARiAl SEAL JAMIE R. BRINKMAN, NOTARY PUBUC CITY Of HARRISBURG, DAUPHIN COUNlY MY COMMISSION EXPIRES DEC. 7, 2008 Witness ID/~ lOb J1 t: HARR~UMMEL Date /0 J LP 1C4J ~o. nlf1M Witness Date / D i. Co / ;u;vG ~~ COMMON ALTH OF PENNSYLVANIA NOTARIAL SEAL CORY LEE BAKER, Notary Public City of Harrisburg, Dauphin County My Commission Expires Oct. 6, 2009 !-.) C.:.:J ~.~:.;; (') 11 --\ -r: -n rnfc,:-:: C"I :~;"" r.~) en (,. "" ./ OCT 1 7 2006 l\ PATRICIA A. RUMMEL, Plaintiff f.})g. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-5556 HARRY E. RUMMEL, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, this ~ day of O'-'"o\,.u , 2006, upon presentation of the within Child Custody Stipulation and Agreement, entered into by the parties on October 6, 2006, a copy of which is attached as "Exhibit A", IT IS HEREBY ORDERED that the terms and provisions of the same are hereby approved and incorporated by reference in the present Order of Court, as fully as though, and with the same force and effect as if such Order had been entered after Petition, Notice and Hearing. BY THE COURT, L- J. VIN\!/\lASNN3d I I Nnn'-l \;lL(:;c]IN,n'" ^-J.. . 1.~'- ".- .' ",-..",.,. ~t' lj. V 80 :~ Hd 02 1:)0 9DOl Al..l\.Il0" .r,' 'I fl.' 'd "'Hi -'0 OV. j\lIJr1..LIJO:J ;;j 30!:1:-l0-G31lj OJ P :ir- PATRICIA A. RUMMEL, Plaintiff IN THE COURT OF COMMON PLEA~ OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW HARRY E. RUMMEL, Defendant NO. 06-5556 IN CUSTODY COURT ORDER AND NOW, this ~ day of October, 2006, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. ~ x!y, Esquire Custody Conciliator Q ~ r-,;) c:;;:l c::> er- e:::> (;'") -' ~ :;1..,., 01 f':" -01:2 ..:) c.r,1 ~~~.?j. (;~) .~- ~. c..:> o ~'>1" .~ ~::.: .....~ (',:, ~~l\~Yt E::; ~ - - o --