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BOBBIE JO MUNDT,
Plaintiff
vs.
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 94 - 6523 CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
RODNEY ALLEN MUNDT,
Defendant
AND NOW,
PROTECTIVE ORDER
~
this ~ day of December, 1994, upon consideration
of the Consent Agreement of the parties, the following Order is
entered:
1. The defendant, RODNEY ALLEN MUNDT, is enjoined from
physically abusi~g the plaintiff, BOBBIE JO MUNDT, or from
placing her in fear of abuse.
2. The defendant, RODNEY ALLEN MUNDT, is hereby excluded
from the premises located at 200 North Frederick Street, Apt. 2,
Mechanicsburg, Pennsylvania. The defendant is hereby notified
that if he resides in the plaintiff's domicile contrary to this
order, he may be in indirect criminal contempt which is
punishable by a fine not to exceed $1,000 and/or by a sentence of
up to six months in jail and any other appropriate punishment.
Consent of the plaintiff to the defendant's resumption of
residence with the plaintiff shall not invalidate this Order.
The defendant shall seek modification (change) of this Order
before resuming residence in the plaintiff's domicile.
3. The defendant, RODNEY ALLEN MUNDT, is ordered to stay
away from any residence the plaintiff may establish for herself
in the future.
4. The defendant is ordered to refrain from having any
contact with the plaintiff, except for the purpose of
facilitating periods of partial custody, including, but not
limited to, entering the plaintiff's place of employment,
harassing or stalking the plaintiff, and harassing the
plaintiff's relatives.
5. This Order shall remain in effect for a period of one
year.
6. The Mechanicsburg Police Department will be provided
with a copy of this Order by attorneys for plaintiff and may
enforce this Order by arrest for indirect criminal contempt
without warrant upon probable cause that this Order has been
violated, whether or not the violation is committed in the
presence of the police officer. In the event that an arrest is
made under this section, the defendant shall not be taken to jail
but shall be taken without unnecessary delay before the Court
that issued the Order. When that Court is unavailable, the
defendant shall be arraigned before a district justice who shall
set bail according to the provisions of Chapter 4000 of the
Pennsylvania Rules of Criminal Procedure (23 PS section 6113).
By the Court
d-~(Ll f& //
H i: ld E. Sheely, '0:
BOBBIE JO MUNDT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
vs.
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 - 6523 CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
RODNEY A~LEN MUNDT,
Defendant
CUSTODY ORDER
AND NOW, this ~day of December, 1994, upon consideration
of the parties' Consent Agreement, the following Order is entered
with regard to custody of the parties' children, ECHO and DESTINI
MUNDT.
1. The plaintiff, hereinafter referred to as the mother,
will have primary physical and legal custody of the children.
2. The defendant, hereinafter referred to as the father,
will have partial custody of the children, according to the
following schedule:
a. Every Saturday from 10:00 a.m. until 5:00 p.m.
until the father establishes a residence with overnight
accommodations for the children.
b. Every other weekend from Friday at 5:00 p.m. until
Sunday at 5:00 p.m. conditioned on the father having a
residence with overnight accommodations.
c. Any other times which are mutually agreed upon by
the parties.
3. The mother and father, by mutual agreement, may vary
from this schedule at any time.
4. The mother and father will notify each other of all
emergency medical care the children receive while in that
parent's care.
S. Neither party shall do anything which may estrange the
children from the other parent, or injure the opinion of the
children as to the other parent or which may hamper the free
and natural development of the children's love or respect for the
other parent.
By the court,
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arold E. Sheely, J.
BOBBIE JO MUNDT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 - 6523 CIVIL TERM
PROTECTION FROM ABUSE
AND CUS'lODY
vs.
RODNEY ALLEN MUNDT,
Defendant
CONSENT AGREEMENT
This Agreement is entered on this --L- day of December,
1994, by the plaintiff, BOBBIE JO MUNDT, and the defendant,
RODNEY ALLEN MUNDT. The plaintiff is represented by Joan Carey,
of Legal services, Inc.; the defendant is unrepresented but is
aware of his right to have an attorney. The parties agree that
the fOllowing may be entered as an Order of Court.
1. The defendant, RODNEY ALLEN MUNDT, agrees to refrain
from abusing the plaintiff, BOBBIE JO MUNDT, or from placing her
in fear of abuse.
2. The defendant agrees not to have any contact with the
plaintiff, except for the purpose of facilitating periods of
partial custody, including but not limited to, entering the
plaintiff's place of employment.
3. The defendant agrees not to harass or stalk the
plaintiff or harass the plaintiff's relatives.
4. The defendant agrees to stay away from the residence
located at 200 North Frederick street, Apt. 2, Mechanicsburg,
Pennsylvania.
5. The defendant agrees to star away from any residence the
..
Plaintiff may establish for herself in the future.
6. The defendant, although entering into this Agreement,
does not admit the allegations made in this Petition.
7. The defendant understands that the Protective Order
entered in this matter shall be in effect for a period of one
year.
8. The defendant understands that this Order will be
enforceable in the same manner as the Court's prior Temporary
Protective Order entered in this case.
9. The defendant and the plaintiff agree to the entry of
an Order regaruing custody of their children, ECHO and DESTINI
MUNDT:
a. The mother will have primary physical and legal
custody of the children.
b. The father will have partial custody of the
child every other weekend from Friday at 5:00 p.m. until
Sunday at 5:00 p.m. if he has overnight accommodations for
the children; otherwise, the father will have every Saturday
from 10:00 a.m. until 5:00 p.m.
c. The mother and father, by mutual agreement, may
vary from this schedule at any time but the Order shall
remain in effect until either party petitions to have it
changed.
d. The mother and father agree that each will notify
the other of all emergency medical care the children receive
while in that parent's care.
'.
.
e.
The parties realize that their children's well
being is paramount to any differences they might have
between themselves. Therefore, they agree that neither
party will do anything which may estrange the children from
the other parent, or injure the opinion of the children as
to the other parent or which may hamper the free and natural
development of the children's love or respect for the other
parent.
WHEREFORE, the parties request that Orders of Court be
entered to reflect the above terms.
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Plaintiff
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Rodney A. Mundt, Defendant
tj
o n carey
Attorney for Pla
LEGAL SERVICES,
8 Irvine Row
carlisle, PA 17013
(717) 243-9400
CORRECTION:
Previous Image
Refilmed to Correct
Possible Error
,
VS.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 - ~ Sol ~ CIVIL TERM
PROTECTION FROM ABUSE
: AND CUSTODY
BOBBIE JO MUNDT,
plaintiff
RODNEY ALLEN MUNDT,
Defendant
TEMPORARY PROTECTIVE ORDER
AND NOW, this 1.5111 day of November, 1994, upon presentation
and consideration of the within petition, and upon finding that
the plaintiff, BOBBIE JO MUNDT, temporarily residing at 1110
Cocklin street, Mechanicsburg, Cumberland County, Pennsylvania,
is in immediate and present danger of abuse from the defendant,
RODNEY ALLEN MUNDT, the following Temporary Order is entered.
The defendant, RODNEY ALLEN MUNDT, now residing at 200 N.
Frederick street, Apt. 2, Mechanicsburg, cumberland county,
Pennsylvania, is hereby enjoined from physically abusing the
plaintiff, BOBBIE JO MUNDT, or placing her in fear of abuse and
is excluded from the residence located at 200 North Frederick
street, Apt. 2, Mechanicsburg, Cumberland County, Pennsylvania, a
residence which is leased solely by the plaintiff. The defendant
is hereby notified that if he resides in the plaintiff's domicile
contrary to this Order, he may be in indirect criminal contempt
which is punishable by a fine not to exceed $1,000.00 and/or by a
sentence of up to six months in jail and any other appropriate
punishment. Resumption of co-residence on the part of the
plaintiff and defendant shall not nullify the provisions of the
Court Order directing the defendant to refrain from abusing the
plaintiff.
Temporary custody of ECHO and DESTINI MUNDT is hereby
awarded to the plaintiff, BOBBIE JO MUNDT.
The defendant is ordered to refrain from having any contact
with the plaintiff including, but not limited to, entering the
plaintiff's place of employment, harassing or stalking the
plaintiff, and harassing the plaintiff's relatives.
This Order shall remain in effect until a final order is
entered in this case. A hearing shall be held on this matter on
the J.1,CcJday of November, 1994, at /),: j{) fl.m. in Courtroom
No. / , cumberland county courthouse, carlisle, pennsylvania.
The plaintiff may proceed in forma DauDeris pending a
further order after the hearing.
The Cumberland county Sheriff's office shall attempt to make
service at the plaintiff's request, but service may be
accomplished under any applicable rule of civil Procedure.
This Order shall be docketed in the office of the
prothonotary and forwarded to the Sheriff for service. The
prothonotary shall not send a copy of this order to defendant by
mail.
The Mechanicsburg Police Department will be provided with a
copy of this Order by attorneys for plaintiff. This Order shall
be enforced by any law enforcement agency where a violation
occurs by arrest for indirect criminal contempt without warrant
upon probable cause that this Order has been violated, whether or
BOBBIE JO MUNDT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 -
CIVIL TERM
vs.
PROTECTION FROM ABUSE
AND CUSTODY
RODNEY ALLEN MUNDT,
Defendant
NOTICE
You have been sued in court. It you wish to defend against
the claims set forth in the following pages, you must take action
promptly after this Petition, Order and Notice are served, by
appearing personally or by attorney at the hearing scheduled by
the Court and presenting to the Court your defenses or objections
to the claims set forth against you. You are warned that if you
fail to do so the Court may proceed without you, and a judgment
may be entered against you by the Court without further notice
for any money claimed in the Petition or for any other claim or
relief requested by the plaintiff. You may lose money or
property or other rights important to you.
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, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
grabbed the plaint if by her shirt and threw her ~cross the room,
causing her to fall to the floor. The defendant ran to the
plaintiff, grabbed her by the shirt, picked her up and while
holding onto her shirt, threw her back and forth across the room.
After several minutes of this, the shirt ripped and the plaintiff
fell to the floor. An uncle who had been watching television
intervened. The plaintiff left the residence and returned later.
The plaintiff was seen and treated at the seidle Memorial
hospital's First Care Center and suffered pulled ligaments in her
ankle, a sprained thumb, and bruising.
b. In or around September 1994, the defendant pushed the
plaintiff, grabbed her by the shirt, tore the plaintiff's shirt
and bra off of her, and threw her to the ground. The plaintiff
got up, attempted to cover herself, and ran inside the apartment.
c. In or around August 1994, the defendant chased the
plaintiff to the basement, threw her around the basement several
times, and pushed and shoved her, causing bruising, cuts, and
scratches to her arms, back, and knees.
d. In or around July 1994, the defendant picked up the
plaintiff and attempted to push her into the car. The plaintiff
got away and ran, but the defendant grabbed her and again
attempted to push her into the car. The plaintiff freed herself
and ran to the house, but the defendant followed and pushed her
into the wall from behind, causing her to fall into the wall and
scrape her elbow. The defendant then spit in the plaintiff's
face approximately ten times.
e. On approximately a monthly basis, the defendant has
abused the plaintiff in ways including, but not limited to, the
following: pointing fingers in her face, raising his hand as if
to hit her, placing her in fear of imminent serious bodily
injury, hit the plaintiff in the face with an open hand, breaking
her nose, slapping her, pushing her down the stairs, and grabbing
the plaintiff and throwing her around.
5. On approximately November 8, 1994, the plaintiff and her
two children left their residence at 200 N. Frederick street,
Mechanicsburg, Cumberland county, pennsylvania in order to avoid
further abuse.
6. The plaintiff believes and therefore avers that she will
be in immediate and present danger of abuse from the defendant
should she return to the home with her children without
defendant's exclusion, and that she is in need of protection from
such abuse.
7. The plaintiff desires that the defendant be restrained
from entering her place of employment, having any contact with
her, harassing or stalking the plaintiff, and harassing the
plaintiff's relatives.
B. TEMPORARY CUSTODY
8. The plaintiff seeks temporary custody of the following
children:
~
Present Residence
~
ECHO MARIE MUNDT
1110 Cocklin street
Mechanicsburg, PA
5 yrs.
DESTINI LEE HUNDT
same location
1 yr.
The oldest child was born out of wedlock, the youngest was
not.
The children are presently in the custody of BOBBIE JO
HUNDT, who resides at 1110 Cocklin street, Hechanicsburg,
Pennsylvania.
During the past five years, the children have resided with
the fOllowing persons and at the following addresses:
plaintiff
Addresses
200 N. Frederick st.
Hechanicsburg, PA
1110 Cocklin street
Hechanicsburg, PA
The mother of the children is BOBBIE JO HUNDT, currently
Dates
8/89 - 11/8/94
~
plaintiff & defendant
11/8/94 - present
residing at 1110 Cocklin street, Hechanicsburg, Pennsylvania.
She is married.
The father of the children is RODNEY HUNDT, currently
residing at 200 N. Frederick street, Hechanicsburg.
The plaintiff currently resides with the following persons:
~
ECHO HUNDT
DESTINI HUNDT
SUSAN
RelationshiD
daughter
daughter
friend
9. The plaintiff has not previously participated in any
litigation concerning custody of the above mentioned children in
this or any other Court.
10. The plaintiff has no knowledge of any custody
proceedings concerning these children pending before a court in
this or any other jurisdiction.
11. The plaintiff does not know of any person not a party
to this action who has physical custody of the children or claims
to have custody or visitation rights with respect to the
children.
12. The best interests and permanent welfare of the
children will be met if custody is temporarily granted to the
plaintiff pending a hearing in this matter for the following
reasons:
a. The plaintiff is a fit parent who can best taks
care of her children.
b. The defendant has shown by his abuse of the
petitioner that he is not an appropriate role model for the
children.
C. EXCLUSIVE POSSESSION
13. The home from which the plaintiff is asking the Court
to exclude the defendant is rented in the name of BOBBIE JO
MUNDT.
14. The plaintiff currently has no place to stay with her
children except the marital home, and the defendant has family
and friends in the area with whom he can stay.
15. The plaintiff desires possession of the apartment so as
to give the greatest degree of continuity to the lives of the
children, to allow her oldest child to continue her education at
her school, and to continue the children's school and social
activities.
D. LOSSES
16. The plaintiff asks for attornsy fees to be paid to
Legal Services, Inc. pursuant to the Protection from Abuse Act.
E. STATUS TO PROCEED IN FORMA PAUPERIS
17. The defendant is employed at Winding Hill Window
Cleanlng and has an hourly salary of approximately $6.00.
lB. The plaintiff currently receives public assistance in
the amount of $116.00 per month.
19. The plaintiff does not have funds available to pay the
fees for filing and service.
WHEREFORE, pursuant to the provisions of the "Protection
from Abuse Act" of october 7,1976,23 P.S. Section 6101 g.t .wm.,
as amended, the plaintiff prays this Honorable Court to grant the
fOllowing relief:
A. Grant a Temporary Order pursuant to the "Protection from
Abuse Act:"
1. Requiring the defendant to refrain from abusing the
plaintiff or placing her in fear of abuse.
2. Requiring the defendant to refrain from having any
contact with the plaintiff, including, but not limited to,
restraining the defendant from entering the plaintiff's
place of employment, harassing or stalking the plaintiff,
and harassing the plaintiff's relatives.
3. Granting temporary custody of the minor children
to the plaintiff.
4. Granting possession of the apartment located at 200
N. Frederick street, Mechanicsburg, to the plaintiff to the
exclusion of the defendant pending a final order in this
matter.
5. Ordering the defendant to stay away from any
residence the plaintiff may in the future establish for
herself.
B. Schedule a hearing in accordance with the provisions of
the "Protection from Abuse Act," and, after such hearing, enter
an order to be in effect for a period of one year:
1. Requiring the defendant to refrain from abusing the
plaintiff or placing her in fear of abuse.
2. Requiring the defendant to refrain from having any
contact with the plaintiff, including, but not limited to,
restraining the defendant from entering the plaintiff's
place of employment, harassing or stalking the plaintiff,
and harassing the plaintiff's relatives.
3. Granting possession of the apartment located at 200
N. Frederick street, Mechanicsburg, to the plaintiff to the
exclusion of the defendant.
4. Ordering the defendant to stay away from any
residence the plaintiff may in the future establish for
herself .
5. ordering the defendant to pay attorney fees to
Legal Services, Inc., pursuant to the Protection From Abuse
Act.
The plaintiff further asks that this Petition be filed and
served without payment of costs, pending a further order at the
hearing, and that a copy of this Petition and Order be delivered
to the Mechanicsburg police Department as the Police Department
with jurisdiction to enforce this Order.
The plaintiff prays for such other relief as may be just and
proper.
COUNT II
CUSTODY UNDER PENNSYLVANIA CUSTODY LAW
20. The allegations of Count I above are incorporated
herein as if fully set forth.
21. The best interests and permanent welfare of the
children will be served by confirming custody in the plaintiff as
set forth in Paragraph 12 of the Petition.
WHEREFORE, pursuant to 23 P.S. Section 5301 g.t ~., and
other applicable rules and law, the plaintiff prays this
Honorable Court to award custody of the minor children to her.
The plaintiff prays for such other relief as may be just and
proper.
Respectfully submitted,
(/~/t -4-
Joan Ca ey
Philip c. Briganti
Attorneys for Plaintiff
LEGAL SERVICES, INC.
B Irvine Row
Carlisle, PA 17013
(717) 243-9400
BOBBI JO MUNDT,
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS OF
RODNEY ALLEN MUNDT,
Defendant
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 94-6523 CIVIL TERM
MOTION FOR CONTINUANCE
The plaintiff, by and through her attorney, Joan carey of
Legal Services, Inc. states the following:
1. On the 15th day of November, 1994, the plaintiff filed a
Protection From Abuse action and the court entered a Temporary
protective Order and scheduled a hearing for the 23rd day of
November, 1994.
2. Legal Services has been in contact with the defendant who
is not contesting the matter and wishes to execute a Consent
Agreement making a hearing unnecessary at this time.
3. The plaintiff and defendant are in the process of
finalizing the terms of the agreement and signing the agreement,
but the defendant has asked Legal Services for additional time
beyond the hearing date of November 23, 1994 to complete this
process.
4. The plaintiff is not opposed to a continuance of the
hearing if the Temporary Protective Order remains in effect pending
further Order of Court after receipt of the signed Consent
Agreement.
,
DODDlE JO MUNDT
PLAINTIFF
IN TilE COURT OF COMMON PLEAS OF
CUMBERI.AND COUNTY, PENNSYLV AN/A
v.
94-6523 CIVIL ACTION LAW
RODNEY ALLEN MUNDT
DEFENDANT
IN CUSTODY
O/UlF.n OF ('01 InT
AND NOW, Monday, December 16,2002 ,upon consideration of the attached Complaint,
it is hereby dircctcd that parties and their respective counsel appear beforc Melissa p, Greevy, Eoq. , the conciliator,
at 301 Market Street, Lemoyne, PA 17043 On Monday, January 20, 2003 at 1:00 PM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannol be accomplished, to define and narrow the issues to be heard by the court, and to enter into a tcmporary
order. All childrcn age five or older may also be present at the conference. Failure to appear at the conlerence may
provide grounds for entry of a temporary or permanent order.
The court herehy directs the parties to furnIsh any and all existIng ProtectIon from Ahuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing,
FOR THE COURT,
By: 101
Melissa P. Greev~. Esq. y
Custody Conciliator U
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 10 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 I'APER 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.
Cumberland County Bar Association
2 Liberty A venue
Cnrlisle, Pennsylvnnill 17013
Telephone (717) 249-3166
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BOBBIE JO MUNDT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 94 - 6523 CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
RODNEY ALLEN MUNDT,
Defendant
CONSENT AGREEMENT
This Agreement is entered on this --L- day of December,
1994, by the plaintiff, BOBBIE JO MUNDT, and the defendant,
RODNEY ALLEN MUNDT. The plaintiff is represented by Joan Carey,
of Legal Services, Inc.; the defendant is unrepresented but is
aware of his right to have an attorney. The parties agree that
the following may be entered as an Order of Court.
1. The defendant, RODNEY ALLEN MUNDT, agrees to refrain
from abusing the plaintiff, BOBBIE JO MUNDT, or from placing her
in fear of abuse.
2. The defendant agrees not to have any contact with the
plaintiff, except for the purpose of facilitating periods of
partial custody, including but not limited to, ente~ing the
plaintiff's place of employment.
3. The defendant agrees not to harass or stalk the
plaintiff or harass the plaintiff's relatives.
4. The defendant agrees to stay away from the residence
located at 200 North Frederick street, Apt. 2, Mechanicsburg,
Pennsylvania.
5. The defendant agrees to stay away from any residence the
Exhibit A
Plaintiff may establish for herself in the future.
6. The defendant, although entering into this Agreement,
does not admit the allegations made in this Petition.
7. The defendant understands that the Protective Order
entered in this matter shall be in effect for a period of one
year.
B. The defendant understands that this Order will be
enforceable in the same manner as the Court's prior Temporary
Protective Order entered in this case.
9. The defendant and the plaintiff agree to the entry of
an Order regarding custody of their children, ECHO and DESTINI
MUNDT:
a. The mother will have primary physical and legal
custody of the children.
b. The father wil~ have partial custody of the
child every other weekend from Friday at 5:00 p.m. until
Sunday at 5:00 p.m. if he has overnight accommodations for
the children; otherwise, the father will have every Saturday
from 10:00 a.m. until 5:00 p.m.
c. The mother and father, by mutual agreement, may
vary from this schedule at any time but the Order shall
remain in effect until either party petitions to have it
changed.
d. The mother and father agree that each will notify
the other of all emergency medical care the children receive
while in that parent's care.
~
~
BOBBIE JO MUNDT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 - 6523 CIVIL TERM
vs.
PROTECTION FROM ABUSE
AND CUSTODY
RODNEY ALLEN MUNDT,
Defendant
CUSTODY ORDER
AND NOW, this --'Lbtday of December, 1994, upon consideration
of the parties' Consent Agreement, the fOllowing Order is entered
with regard to custody of the parties' children, ECHO and DESTINI
MUNDT.
1. The plaintiff, hereinafter referred to as the mother,
will have primary physical and legal custody of the children.
2. The defendant, hereinafter referred to as the father,
will have partial custody of the children, according to the
following schedule:
a. Every Saturday from 10:00 a.m. until 5:00 p.m.
until the father establishes a residence with overnight
accommodations for the children.
b. Every other weekend from Friday at 5:00 p.m. until
Sunday at 5:00 p.m. conditioned on the father having a
residence with overnight accommodations.
c, Any other times which are mutually agreed upon by
the parties.
3. The mother and father, by mutual agreement, may vary
from this schedule at any time,
.'
I, I verify that the statements made in
this complaint are true and correct. I understand that
false statements herein are made subject to the penalties of
18 Pa.c,S. S 4904, relatinq to unsworn falsification to
authorities.
DATE: l~o"l.ll~
ATTORNEY FOR
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BOBBIE JO MUNDT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
RODNEY ALLEN
MUNDT,
Defendant
NO. 94-6523 CIVIL TERM
ORDER OF COURT
AND NOW, this 61h day of December, 2002, upon consideration of Defendant's
Petition lor Special and Emergency Reliel~ a hearing is scheduled for Tuesday, December
17, 2002, at 3:30 p.m., in Courtroom No. I, Cumberland County Courthouse, Carlisle,
Pennsylvania.
BY THE COURT,
, / ~ . ~ .(>/ l
J. WCsley Oler, Jr., J.
'Bobbie Jo Singiser
272 Orebanic Street
Apt. 3
Dillsburg, PA 17019
Plaintiff, Pro Se
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, Gail Guida Souders, Esq.
503 North Front Street
Harrisburg, P A 1710 I
Attorney lor Defendant
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BOBBIE JO MUNDT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 - 6523 CIVIL TERM
vs.
PROTECTION FROM ABUSE
AND CUSTODY
RODNEY ALLEN IfUNDT,
Defendant
CONSENT AGREEMENT
This Agreement is entered on this --L- day of December,
1994, by the plaintiff, BOBBIE JO MUNDT, and the defendant,
RODNEY ALLEN MUNDT. The plaintiff is represented by Joan Carey,
of Legal Services, Inc.; the defendant is unrepresented but is
aware of his right to have an attorney. The parties agree that
the following may be entered as an Order of Court.
1. The defendant, RODNEY ALLEN MUNDT, agrees to refrain
from abusing the plaintiff, BOBBIE JO MUNDT, or from placing her
in fear of abuse.
2. The defendant agrees not to have any contact with the
plaintiff, except for the purpose of facilitating periods of
partial custody, including but not limited to, entering the
plaintiff'S place of employment.
3. The defendant agrees not to harass or stalk the
plaintiff or harass the plaintiff'S relatives.
4. The defendant agrees to stay away from the residence
located at 200 North Frederick street, Apt. 2, Mechanicsburg,
Pennsylvania,
5. The defendant agrees to stay away from any residence the
Exhibit A
Plaintiff may establish for herself in the future.
6. The defendant, although entering into this Agreement,
does not admit the allegations made in this Petition.
7. The defendant understands that the Protective Order
entered in this matter shall be in effect for a period of one
year.
8. The defendant understands that this Order will be
enforceable in the same manner as the Court's prior Temporary
Protective Order entered in this case.
9. The defendant and the plaintiff agree to the entry of
an Order regarding cuatody of their children, ECHO and DESTINI
MlJNDT:
a. The mother will have primary physical and legal
custody of the children.
b. The father will have partial custody of the
child every other weekend from Friday at 5:00 p.m. until
Sunday at 5:00 p.m, if he has overnight accommodations for
the children; otherwise, the father will have every Saturday
from 10:00 a.m. until 5:00 p.m,
c. The mother and father, by mutual agreement, may
vary from this schedule at any time but the Order shall
remain in effect until either party petitions to have it
changed.
d. The mother and father agree that each will notify
the other of all emergency medical care the children receive
while in that parent's care.
BOBBIE JO MUNDT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
.
.
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 94 - 6523 CIVIL TERM
vs.
PROTECTION FROM ABUSE
AND CUSTODY
RODNEY AL~EN MUNDT,
Defendant
CUSTODY ORDER
~
AND NOW, this --lL oay of December, 1994, upon consideration
of the parties' Consent Agreement, the following Order is entered
with regard to custody of the parties' children, ECHO and DESTINI
MUNDT.
1. The plaintiff, hereinafter referred to as the mother,
will have primary physical and legal custody of the children.
2. The defendant, hereinafter referred to as the father,
will have partial custody of the children, according to the
following schedule:
a. Every Saturday from 10:00 a.m. until 5:00 p.m.
until the father establishes a residence with overnight
accommodations for the children.
b. Every other weekend from Friday at 5:00 p.m. until
Sunday at 5:00 p.m. conditioned on the father having a
residence with overnight accommodations.
c. Any other times which are mutually agreed upon by
the parties.
3. The mother and father, by mutual agreement, may vary
from this schedule at any time.
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MAR 0 4 ZOO] ~
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-6523 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
BOBBIE JO MUNDT,
v.
RODNEY ALLEN MUNDT,
Defendant
Q.BPER OF COURT
AND NOW, this ~ day of March, 2003, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. This Court's Order of December 6,1994 Is VACATED.
2. Leqal Custody. The parties, Bobble Jo Mundt and Rodney Allen Mundt, shall
have shared legal custody of the minor children, Echo Mundt, born August 23, 1989, and
DesUni Mundt, born May 2, 1993. 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 Pa. 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 of tho
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.
3. Physical Custody. This Order confirms the physical custody arrangement
which the parties have been following since December 6, 2002:
A. Mother has primary physical custody of Destin!.
B. Father has primary physical custody of Echo.
C. In recognition of the children's need to spend time together, the
parties agree that the children shall be together on alternate weekends in
accordance with the following schedule: To commence the weekend of March
1, 2003, the children shall be together for Father's custodial weel(end; To
commence the weekend of March 8, 2003, the children shall be together for
Mother's custodial weekend.
.~
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-6523 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
BOBBIE .)0 MUNDT,
v.
RODNEY ALLEN MUNDT,
Defendant
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 conceming the children who are the subject of this
litigation Is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN THE CUSTODY OF
Echo Mundt
Destini Mundt
August 23, 1989
May 2,1993
Father
Mother
2. A Custody Conciliation Conference was held on February 25, 2003 pursuant
to Father's Petition to Modify filed on December 6, 2002. Present for the conference were:
the Mother, Bobble Jo Mundt Singlser, and her counsel, Nora F. Blair, Esquire; the Father,
Rodney Allen Mundt, and his counsel, Gail Guida Souders, Esquire.
3. In light of this strained relationship between Mother and Echo, the parties hLlvo
agreed that Mother and Echo will participate In counseling together to utilize professional
assistance to address the division and distress In that relationship at this time.
Both parties acknowledged that they have difficulty In communicating and decision
making In an effective fashion together as parents. To their credit, and in spite of their
frustration level, these parents have agreed to seek the assistance of a third party to
address this concern for the best interest of their children. Among the topics of concern cmd
for discussion will be the weight to be afforded to a child's preferences and the
distinguishing between the role of parents and adolescents In decision-making.
dk/()3
Datll
The parties reached an agreement In the form of an Order as attached.
LlOQu ~----.
Melissa Peel Greevy, Esquire
Custody Conciliator
4.
:210365
,.
BOBBIE 10 SIN{jISUt
I'L\INlIH'
IN TIIF l'lJUIU OF COM~10N PLEAS OF
CUt\IIlI'RI.ANIJ COUNTY. PFNNSYI.VANIA
v,
94-6523 CIVIL AlTION LA W
RODNEY ALLEN MUNDT
IN CUSTOI>Y
11IH'NIMNT
OIWEH OF COllin
ANI> NOW.
We~ncsll.y,Oeloher 26, 2005,
_' upon ~llllsid~ralilll1 ()f Ih~ utti.ll.:lwd l'tHllplaiI11.
it is hereby direcled Ihal parties and Iheir respective counsel appear bel'ure l\1ell... ", Greevy. E"I. . the coneilialor,
at.._J\1~J~~.~I~ve~~,!~OtSI.t.SI., Can.lp~II!I,!',\ 170!L on Frld~r,~.cemher 02,~005..___, ' , alll.:OO__AI\1
for a Prc-H":ilring Cllsto~ty Conli:rl.:m:c. At slIch conti:rcllcc. an effort will he made III resolve the issues in dispute; or
i I' Ihis Cllnnnt be accomplished. to define lInd narrow Ihe issues to be heard by the coun. llnd 10 enler inln II temporary
order. All children aJ,te live or older mllv also be presenl althe conference. Failure 10 appear lIllhe conference m'I\'
provide grounds ti,r entry of a tempomry or permanenl order.
Th. court hercl>)" directs the pnrtles to rurnlsh un)' and all existing Protection rrom Ahuse orders,
SpecInl neu.r orders, and Custod\' orders to the conclllutor -IH hours prior to scheduled hearln\!.
FOR TilE COURT.
Ill': _lsl,_..__Melil!!i!l-'>.!J;!~'l.y,gl!.q" ,..II~
Custody Conciliator P"
The Court or Common Pleas ol'Cumberland County is rcquired by law to comply with the Amerkans
\vith Oisabilitcs Act of I')l)O. Fur information about accl:ssihlc facilitks ;mJ n:asnnahk ~II.:COlllm(llhl1iol1s
availahlc to disabled individuals having husillcss hcftlfC thc cuurt, ph:asc I.:ontacl OUI' oflicc, All arrangcments
must be made at least 72 hours prior to any hearing or business beIilre the court. You must attend Ihe scheduled
confercncc or hcaring,
YOU SIIOULD TAKE TillS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
IIA VE AN ATTORNEY OR CANNOT AFFORD ONE, (iO TO OR TEl.l'l'llONF TilE OFFICE SET
FORTII BELOW TO FIND OUT WIIERE YOU CAN (,ET LF<iAL IIELI'.
Cumherland Coullty Bar AsslIciation
J2 Soulh Iledlilnl Slreel
Carlisle. Pennsylvania 17111.1
Telephone 17171 2~l)-.11 6h
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RECEIVED
or.r 20 LUUS
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BOBBIE JO SINGlSER,
(formerly Bobbie Jo Mundt)
Plaintiff
: IN THE COURT OF COMMO
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN CUSTODY
RODNEY ALLEN MUNDT,
Defendant
: NO. 94-6523 CIVIL TERM
ORnER OF COURT
AND NOW, this day of ,2005, upon consideration of the attached
complaint, it is hereby directed that the parties and their respective counsel appear before,
, the Concililltor, at ' on the day of
,2005, at m., 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 llnd 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.
FOR THE COURT:
By:
Custody Conciliator
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 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 MAYBE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES TI-IA T MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberlllnd County Bar Association
32 South Bcdford Street
Carlisle, PA 17013
AMERICANS WITH DlSADlLlTmS ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disllbilities Act of 1990. For information about accessible fllcilities and
reasonable acCommodlltions available to disabled individuals having business before the court,
please contuct our oflice. All arrangements must be made lltleust 72 hours prior to any hell ring
or business before the court. You must uttend the scheduled conference or hearing.
..
MAR n ,1 7~Jnl it
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-6523 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
BOBBIE JO MUNDT,
v.
RODNEY ALLEN MUNDT,
Defendant
ORDER OF COURT
AND NOW, this (, e:. day of March, 2003, upon consideration of the attached
Custody Conciliation Summary Report, It Is he'eby ordered and directed as follows:
1. This Court's Order of December 6, 1994 /s VACATED.
2. Leaal Custodv, The parties, Bobble Jo Mundt and Rodney Allen Mundt, shall
have shared legal custody of the minor children, Echo Mundt, born August 23, 1989, and
Destlnl Mundt, born May 2, 1993, 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 Pa. C. S. 95309, 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 of Ihe
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 caples thereof,' with the other parent
within such reasonable time as to make the records and Information of reasonable use to
the other parent.
3. Phvslcal Custodv. This Order confirms the physical custody arrangement
which the parties have been following since December 6, 2002:
A. Mother has primary physical custody of Destln!;
B. Father has primary physical custody of Echo.
C. In recognition of the children's need to spend time together, the
parties agree that the children shall be together on alternate weekends In
accordance with the following schedule: To commence the weekend of March
1, 2003, the children shall be together for Father's custodial weekend; To
commence the weekend of March 8, 2003, the children shall be together for
Mother's custodial weekend.
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FILW,Cl,iCE
OF n'r: [-';:'1' ,~,~I')T^ny
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2005 OCT 19 PII 2: 27
CtH,'.-,:, '~~_;~,:ry
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LA W
: IN CUSTODY
BOBBIE 10 SINGlSER,
(formerly Bobbie Jo Mundt)
Plainti ff
RODNEY ALLEN MUNDT
Defendant
: NO. 94-6523 CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
Kindly allow Bobbie Jo Singiser, Plaintiff, to proceed in forma pauperis.
The Family Law Clinic, allameys lor the party proceeding in forma pauperis, certifies
that we believe the party is unable to pay the costs and that we are providing free legal service to
the party.
Date / {) Is- los-
. I f
atlileen O'Connor
Certified Legal Intern
iYJf. ~
ROBERT E. RAINS
THOMAS M. PLACE
ANNE MACDONALD-FOX
LUCY JOHNSTON-WALSH
Supervising Allorneys
FAMILY LAW CLINIC
45 North Pill Street
Carlisle. PA 17013
717-243-2968
,"{
AI.ED-O~"FICE
OF lHE PROTHONOTARY
20051lOV 10 PH 3: 52
CUMlb1L!,j';D COUNlY
PENNSYlVt,NlA
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DEe 0 tJ ~
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-6523 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
BOBBIE JO SINGISER,
v.
RODNEY ALLEN MUNDT,
Defendant
OLER, J. no
ORDER OF COURT
AND NOW, thl3 ~ day of December, 2005, upon consideration of the
attached Custody Conciliation Summary Report, it is hereby ordered and directed as
follows:
1. This Court's Order of March 6,2003 is VACATED.
2. Leaal Custodv. The parties, Bobbie Jo Singiser and Rodney Allen Mundt,
shall have shared legal custody of the minor children, Echo Mundt, born August 23, 1969,
and Destlni Mundt, born May 2, 1993. Each parent shall have an equal right to be
exercised jointly with the other parent, to make all 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 Pa. 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 of 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.
3. Phvsical Custodv. Mother has primary physical custody of the children
subject to Father's rights of partial custody, which shall be arranged by mutual agreement of
the parties.
BY THE COURT:
Olst:
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~thleen O'Connor. CLl. Family Law Clinic. 45 North Pitt Street. Carlisle. PA 17013
'A1~" 00 '''"'' ''""' 'MO. Moo","'"',,," "'"
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Plaintiff
DEe 0 II 2005
IN THE COURT OF COMMON PLEAS d}
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-6523 CIVIL TERM
BOBBIE JO SINGISER,
v.
RODNEY ALLEN MUNDT,
CIVIL ACTION - LAW
IN CUSTODY
Defendant
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 THE CUSTODY OF
Echo Mundt
Destini Mundt
August 23, 1989
May 2,1993
Mother
Mother
2. A Custody Conciliation Conference was held on December 2, 2005 in
response to a Petition to Modify Custody Order filed by Mother on October 19, 2005. The
last Order entered In this matter was March 6, 2003. Present for the conference were: the
Father, Rodney Allen Mundt did not attend; the Mother, Bobble Jo Singiser, f/kJa Bobbie Jo
Mundt, and her counsel, CLI Kathleen N. O'Connor and Anne MacDonald-Fox, Esquire.
3. Mother's Position on Custodv: Mother produced a Proof of Personal Service
Indicating that Father had been served on November 19, 2005. The Proof of Service has
been filed with the Court. Mother reports that Echo has lived with her since May 2003 and
that the parties have not followed the Order entered in March 2003. Mother further reports
that Echo wants to stay with her. The girls are presently seeing the Father every other
weekend for one or two days. Ms. O'Connor, the Dickinson Family Law Clinic Intern,
reports that Father did not respond to their attempts to resolve the matter without a Custody
Conciliation Conference. Accordingly, they filed the Petition herein seeking an Order
confirming the status quo.
4. Father's Position on Custodv: Is unknown because Father failed to attend the
conciliation conference. The Conciliator's office received no indication as to whether Father
was attending, nor did counsel, on Father's behalf, contact the Conciliator's office seeking a
continuance.
BOBBIE JO SINGISER,
(formerly Bobbie Jo Mundt)
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
: IN CUSTODY
RODNEY ALLEN MUNDT,
Defendant
: NO. 94-6523
CIVIL TERM
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, you may
lose rights of custody and visitation of your child,
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 S, Bedford St.
Carlisle, P A 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 Act of 1990, For information about accessible facilities and
reasonable accommodations avail 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.
.'
BOBBIE JO SINGISER,
(formerly Bobbie Jo Mundt)
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: CIVIL ACTION - LAW
: IN CUSTODY
RODNEY ALLEN MUNDT,
Defendant
: NO, 94-6523
CIVIL TERM
PETITION TO MODIFY CUSTODY ORDER
I. The petition of Ms. Bobbie Jo Mundt Singiser, by her attorneys, the Family Law Clinic,
respectfully represents that on March 6, 2003, an Order of Court was entered for custody of Echo
Mundt, born August 23, 1989, and Destini Mundt, born May 2, 1993, a true and correct copy of
which is attached, Under the existing Order, Rodney Allen Mundt (hereinafter "Father"), has
primary physical custody of Echo, and Bobbie Jo Mundt Singiser (hereinafter "Mother") has
primary physical custody ofDestini, Mother is to have physical custody of both children on
alternate weekends,
2, This Order should be modified because:
a, The parties have not followed the March 6, 2003 Order, for some time,
b, Echo has been living with Mother since May 2003,
c, Echo, who is sixteen years old, has expressed a de:sire to continue to live with Mother.
d, Modifying the Order of Court dated March 6, 2003 would be consistent with the current
status quo and would foster the children's need to continue to spend time together.
WHEREFORE, Petitioner asks that the Court modifY the existing Order for Custody and
grant Mother primary physical custody of Echo Mundt because it will be in the best interest of both
children,
Date: 10 /J- lor
I I
&~
Kathleen O'Connor
Certified Legal Intern
~Jfe~
mOMAS M, PLACE
ROBERT E, RAINS
LUCY JOHNSTON-WALSH
ANNE M<\CDONALD-FOX
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
(717) 243.3696
Fax: (717)243-363
VERIFICATION
I verify that the statements made in this petition are true and correct to the best of my
personal knowledge and belief. I understand that false statements herein are subject to the
penalties of 18 Pa, C,S, ~ 4904 relating to unsworn falsification to authorities,
Date: II-S - O,S
~~;#
Bobbie Jo Singi
MAR 0 4 Z003 ~
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 94-6523 CIVIL TERM
BOBBIE JO MUNDT,
v,
CIVIL ACTION - LAW
RODNEY ALLEN MUNDT,
IN CUSTODY
Defendant
ORDER OF COURT
r.
AND NOW, this t ~ day of March, 2003, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1, This Court's Order of December 6, 1994 is Vj\CATED,
2, Leaal Custodv, The parties, Bobbie Jo Mundt and Rodney Allen Mundt, shall
have shared legal custody of the minor children, Echo Mundt, born August 23, 1989, and
Destini Mundt, born May 2, 1993, 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 Pa, C, S, S5309, 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 of 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.
3. Physical Custody, This Order confirms the physical custody arrangement
which the parties haye been following since December 6, 2002:
A. Mother has primary physical custody of Ds!stinL
B, Father has primary physical custody of Echo.
C, In recognition of the children's need to sptmd time together, the
parties agree that the children shall be together on alternate weekends in
accordance with the following schedule: To commence the weekend of March
1, 2003, the children shall be together for Father's custodial weekend; To
commence the weekend of March 8, 2003, the children shall be together for
Mother's custodial weekend,
NO. 94-6523 CIVIL TERM
4, Should either parent be incapacitated or unavailable to exercise their role as
the primary custodial parent of a child subject to this Order, the other parent will assume
primary physical custody of said child.
5, Counselina, In recognition of the strain that exists in the relationship between
Mother and Echo, Mother and Echo will participate in counseling together.
6, Co-Parentina, The parties tu this Order shall participate in co-parent
'counseling to assist them in opening a respectful dialogue that will allow them to participate
cooperatively in the necessary decisions they must make as parents of two teenage
children, The cost of this counseling which are not reimbursed by health insurance shall be
shared between the parties on a pro rata net income basis with the net income ratio
determination being that same ratio as is used by the Domestic Relations Office, If needed,
counsel for the parties will assist them in identifying affordable resources to participate in
this undertaking,
BY THE COURT:
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Dist: Nora F, Blair, Esquire, 5440 Jonestown Road, Harrisburg, PA 17112
Gail Guida Souders, Esquire. 503 N, Front Street, Harrisburg, PA 17101
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BOBBIE JO SINGISER,
(formerly Bobbie Jo Mundt)
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN CUSTODY
RODNEY ALLEN MUNDT
Defendant
: NO, 94-6523 CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
Kindly allow Bobbie Jo Singiser, Plaintiff, to proceed in forma pauperis.
The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies
that we believe the party is unable to pay the costs and that we are providing free legal service to
the party.
Date / /) Is / oS-
, I I
Res eCfullYSu&/~
athleen O'Connor
Certified Legal Intern
fUji~ ~
ROBERT E, RAINS
THOMAS M, PLACE
ANNE MACDONALD-FOX
LUCY JOHNSTON-WALSH
Supervising Attorneys
I' AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
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BOBBIE JO SINGlSER
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLV ANIA
v,
94-6523
CIVI I. ACTION LA W
RODNEY ALLEN MUNDT
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
_______~!~_!l_~_~~_~y.~,.Q"~!~~_~~~~!}_~9~ ._ _~____, UpOll consideration of the attached ('olllplaint,
it is hereby directed that parries and their respective counsel appear before Melissa p, Greevy, Esq.
, the conciliator,
at
MDJ Manlove's, ]901 State_~t.,_CalTlP _flill,l';\ 17011 on
December
2005
at ]]:00 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issLles 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 hcrehy directs thc parties to furnish any and all existing Protcction from Abuse orders,
Sllerial Relief orders, and Custody orders to the conciliator 48 hours prior to schcduled hearing,
FOR THE COUR'r,
By:..-i~
Melissa 1". Greevy, Es,q.____~
Custody Conciliator (-1"
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
availahle to disabled individuals having business before the court, please contact our o ffi Ct.:: , All arrangcJ11t.::nts
must he 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 VI' AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WilERI' YOU CAN GET LEGAL liEU',
Cumberland County Bar Association
32 South lledtiJl'd Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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BOBBIE JO SINGISER,
(formerly Bobbie Jo Mundt)
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION-LAW
v.
: NO, 94-6523 CIVIL TERM
RODNEY ALLEN MUNDT,
: IN CUSTODY
Defendant
WITHDRAWAL AND ENTRY OF APPEARANCE
TO THE PROTHONOTARY OF SAID COURT:
PLEASE withdraw my appearance as attorney of record for the Petitioner, Bobbie
Jo Mundt, at the above captioned docket.
Dated: /J ~ Zr-J,vur
I
of, Blair, Esq,
5440 Jonestown Road
P,O, Box 6216
Harrisburg, PA 17112
PLEASE enter my appearance as attorney of record on behalf of the Petitioner,
Bobbie Jo Singiser, at the above captioned docket.
!-~
Katie O'Connor
Certified Legal Intern
1f#t', ~~
ROBERT RAINS
THOMAS M, PLACE
LUCY JOHNSTON-WALSH
ANNE MACDONALD-FOX
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, PAl 7013
717-243-2968
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BOBBIE JO SINGISER,
(formerly Bobbie Jo Mundt)
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
: IN CUSTODY
RODNEY ALLEN MUNDT,
Defendant
: NO. 94-6523
CIVIL TERM
CERTIFICATE OF SERVICE
I, Kathleen O'Connor, Certified Legal Intern, Family Law Clinic, hereby certifY that I
served a true and correct copy of a Withdrawal and Entry of Appearance on Mr. Rodney A,
Mundt, residing at 792 Old Silver Spring Road, Mechanicsburg, Pennsylvania 17055, by
depositing a copy of the same in the United States mail on November 10,2005. Service was
complete upon mailing,
~-fiQ:'
Kathleen 0' onnor
Certified Legal Intern
7~~
ROBERT E. RAINS
THOMAS M, PLACE
LUCY JOHNSTON- WALSH
ANNE MACDONALD-FOX
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
(717) 243-2968
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BOBBIE 10 SINGISER,
(formerly Bobbie Jo MlU1dt)
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: CIVIL ACTION - LAW
: IN CUSTODY
RODNEY ALLEN MUNDT,
Defendant
: NO. 94-6523
CIVIL TERM
CERTIFICATE OF SERVICE
I, Angelica L. Revelant, Certified Legal Intern, Family Law Clinic, hereby certify that I
served a true and correct copy of the October 26, 2005 Order of Court to appear for conciliation
on Rodney Mundt, residing at 793 Old Silver Spring Road, Mechanicsburg, Pennsylvania, by
personal service by handing a copy of the Order of Court to Mr. Mundt at his residence on the
19th day of November, 2005 at 5:15 p.m, This date is at least (10) days before December 2,
2005, the scheduled date of conciliation,
~{IA..KLf/(/~
Angeli Revelant ,
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Robert E, Rains
Thomas M, Place
Lucy Johnston-Walsh
Anne MacDonald-Fox
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
(717) 243-2968
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 94-6523 CIVIL TERM
BOBBIE JO SINGISER,
v,
CIVIL ACTION - LAW
RODNEY ALLEN MUNDT,
Defendant
IN CUSTODY
OLER, J. ---
ORDER OF COURT
AND NOW, this ~ day of December, 2005, upon consideration of the
attached Custody Conciliation Summary Report, it is hereby ordered and directed as
follows:
1, This Court's Order of March 6, 2003 is VACATED,
2. Leqal Custody. The parties, Bobbie Jo Singiser and Rodney Allen Mundt,
shall have shared legal custody of the minor children, Echo Mundt, born August 23, 1989,
and Destini Mundt, born May 2, 1993, Each parent shall have an equal right to be
exercised jointly with the other parent, to make all 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 Pa, C, S. 95309, 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 of 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.
3, Physical Custody, Mother has primary physical custody of the children
subject to Father's rights of partial custody, which shall be arranged by mutual agreement of
the parties,
BY THE COURT:
Dist: ~Ieen O'Connor, ClI, Family Law Clinic, 45 North Pitt Street, Carlisle, PA 17013
:;ro~~ey Allen Mundt, 793 Old Silver Spring Road, Mechanicsburg, PA 17055
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Plaintiff
DEe 0 lJ 2005
IN THE COURT OF COMMON PLEAS ~
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 94-6523 CIVIL TERM
BOBBIE JO SINGISER,
v,
CIVIL ACTION - LAW
RODNEY ALLEN MUNDT,
IN CUSTODY
Defendant
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:
DATE OF BIRTH
CURRENTLY IN THE CUSTODY OF
NAME
Echo Mundt
Destini Mundt
August 23, 1989
May 2, 1993
Mother
Mother
2, A Custody Conciliation Conference was held on December 2, 2005 in
response to a Petition to Modify Custody Order filed by Mother on October 19, 2005, The
last Order entered in this matter was March 6, 2003, Present for the conference were: the
Father, Rodney Allen Mundt did not attend; the Mother, Bobbie Jo Singiser, flk/a Bobbie Jo
Mundt, and her counsel, CLI Kathleen N, O'Connor and Anne MacDonald-Fox, Esquire,
3. Mother's Position on Custody: Mother produced a Proof of Personal Service
indicating that Father had been served on November 19, 2005, The Proof of Service has
been filed with the Court. Mother reports that Echo has lived with her since May 2003 and
that the parties have not followed the Order entered in March 2003, Mother further reports
that Echo wants to stay with her. The girls are presently seeing the Father every other
weekend for one or two days, Ms, O'Connor, the Dickinson Family Law Clinic Intern,
reports that Father did not respond to their attempts to resolve the matter without a Custody
Conciliation Conference, Accordingly, they filed the Petition herein seeking an Order
confirming the status quo,
4, Father's Position on Custody: Is unknown because Father failed to attend the
conciliation conference, The Conciliator's office received no indication as to whether Father
was attending, nor did counsel, on Father's behalf, contact the Conciliator's office seeking a
continuance,
.. \.
NO. 94-6523 CIVIL TERM
5, The Conciliator recommends the Order in the form as attached, which will be
mailed to Father at the address where he was personally served with the notice of this
conciliation conference,
1J-/r/06
Date
clr264506
Melissa Peel Greevy, squire
Custody Conciliator