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HomeMy WebLinkAbout94-07017 r FRED D. RISSINGER, II, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA va. NO. 94- ~(~~-] CIVIL TERM MICHELLE MARIE RISSINGER, CIVIL ACTION - CUSTODY OF Defendant MINOR CHILD ORDER OF COURT AND NOW, this upon consideration directed that the before ~r~wn 5 °~.~_ of the att ~art~es end on the ky n day or o'clock M. for a Pre- ea conference, an effort will be dispute; or if this cannot be the issues to be heard by the temporary order. Either part subject of this custody action attendance ie not mandatory. may provide grounds for entry day of ~ ~fmb~" , 1994, ached Compla nt, t s hereby their respective counsel appear Esquire, the conciliator, at IFc~gtii~)!jw/ , Penns lvania, c.nw•~• , 199~~ at ~~ r ng ustody Conference. At such made to resolve the issues in accomplished, to define and narrow court, and to enter into a y may bring the child who is the to the conference, but the child~a Failure to appear at the conference of a temporary or permanent order. 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. OFFICE OF THE COURT ADMINISTRATOR ONE COURTHOUSE SQUARE CARLISLE, PA 17013-3387 (717) 240-6200 FOR THE COURT, ey_ ~.,. ,.u• t •tS~i. Custody Conc 1 a r uw arnc~n S NEL OAKER e eRENNEMAN ~'~e;:. ;a;;1'9~I ,~.~~~ /,~ •~1 f~~ 6 ~ ,J ~ . ibC~ xc ~4 Q-Cc. /..Ln 1 •~ FRED D. RISSINGER, II, Plaintiff vs. MICHELLE MARIE RISSINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94- CIVIL TERM CIVIL ACTION - CUSTODY OF MINOR CHILD COMPLAINT FOR CUSTODY OF MINOR CHILD AND NOW, comae the Plaintiff, FRED D. RISSINGER, II, by his Attorneys, SNELBAKER & BRENNEMAN, P.C., and avers the following cause of action: 1. The Plaintiff herein is FRED D. RISSINGER, II, an adult individual, who resides at 400 West High Street, West Fairview, Cumberland County, Pennsylvania 17025. 2. The Defendant herein is MICHELLE MARIE RISSINGER, an adult individual, who resides at 4 Weat Beale Avenue, Apartment ,~4, Enola, Cumberland County, Pennsylvania 17025. 3. Plaintiff seeks custody of the following child: a e TYLER ADAM RISSINGER Present Residence 4 West Beale Avenue Enola, PA 17025 The child was not born out of wedlock. B9e 1+ years The child is presently in the custody of Defendant at her residence as indicated in Paragraph 2 above. During the last five (5) years, the child resided with the uw orricce $NEL OAKER following persons and at the following addressee: e BRENNEMAN . 1 Persons (i) Plaintiff and Defendant Addresses 824 Erford Road Camp Hill, PA 17011 Dates Birth to August 1993 (2) Plaintiff and 400 West High Street August 1993 to Defendant West Fairview, PA 17025 November 19, 1994 (3) Defendant 4 Wast Beale Avenue November 19, 1994 Enola, PA 17025 to Present The mother of the child is MICHELLE MARIE RISSINGER, Defendant herein, currently residing at 4 West Beale Avenue, Apartment ,~4, Enola, Pennsylvania 17025. Sha is married. The father of the child is FRED D. RISSINGER, II, currently residing at 400 West High Street, West Fairview, Pennsylvania 17025. He is married. 4. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons: None. 5. The relationship of Defendant MICHELLE MARIE RISSINGER to the child is that of mother. Said Defendant currently resides with the following persons: a e TYLER ADAM RISSINGER son 6. Plaintiff has not participated as a party or witness, or uw arricce SN EI.~AKER e BRENNEMAN in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the Relationship -2- f ~ ~ I~ 1 proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because the child will have a permanent and stable home (which Plaintiff provides and will continue to provide) which cannot be provided by Defendant who ie unable to properly care for the child. e. Each parent whose parental rights to the child have not bean terminated and the person who has physical custody of the child have been named as parties to this action. All other persona, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: None. WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant him custody of TYLER ADAM RISSINGER. SNELBA & B N MAN, P.C. By ~ ,act-~~C~ R o and C. Snelbaker 44 West Main Street Mechanicsburg, PA 17055-0318 Telephone: 717-697-8528 Attorneys for Plaintiff uw orricEs S NEL UAK Efl O BRENNEMAN -3- :.,• u ~ - I hereby 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. $4904 relating to unsworn falsification to authorities. Fred D. es nger, II (Plaintiff) Dated: December 14 , 1994 ~,w o..~«a I, SNELOAKER BRENNEMAN ;; -~, 's~~- ,y ~, r` ~` FRED D. RISSINGER, II, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ~• N0. 94-7017 CIVIL TERM MICHELLE M. RISSINGER, CIVIL ACTION - LAW Defendant IN CUSTODY AND NOW, this day of , 1996, upon Motion oP counsel for Fred D. Rissinger, II, it is hereby ORDERED and directed that the parties participate in a Custody Conciliation Conference to be conducted by Dawn S. Sunday, Esquire. BY THE COURT: LAW OfIIC EE SNELBANEN Q BNENNEMAN FRED D. RISSINGER, II, Plaintiff v. MICHELLE M. RISSINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0. 94-7017 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY AND NOW, this ~~h day of ~I~L"~" , 199 u on ~~ P consideration of the attached compla nti , it is hereby directed that the parties and their respective counsel appear before tJO,,r:~1 `~C.~lr~rt.i1 ~.•i] , the conciliator, at ~ - ~~I D~~~T.~ , Pennaylvan a, on the 11 day of hc.i~ , 199 , at 1,GL~o~clock ~.M. for a Pre-Hear ng Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or iP 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 aqe 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: .,ri1 ial.,,.. (~tii. ~~ Custody Conc 1 to The Court of Common Pleas of Cumberland County is required by law to comply with the Americana with disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. 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 uwa..i~.s OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. SNELB~EER a OFFICE OF THE COURT ADMINISTRATOR aRENN[MRN COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 II (717) 240-6200 ri fly ~"' ~. ~.1 _ _ I i /r' I ~~ r•~ 4 1~~1 III 1~~• ..~ 1 1 •, .. ..~ ~; ._... ..1~ ~ i FRED D. RISSINGER, II, Plaintiff v. MICHELLE M. RISSINGER, Defendant TO THE HONORABLE EDGAR B. BAYLEY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-7017 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY MOTION FOR CUSTODY CONCILIATION CONFERENCE AND NOW, comes the Plaintiff, Fred D. Rissinger, II, by and through his attorneys, Snelbaker & Brenneman, P. C., and moves your Honorable Court to order the parties to attend and participate in a Custody Conciliation Conference and states the following in support thereof: 1. Thia case and a companion case of Michelle M. Rissinger, Petitioner v. Fred D. Rissinger, II, Respondent, docketed to No. 94-5057 Civil Term were scheduled for a hearing on April 13, 1995. 2. By Order of Court dated April 12, 1995, upon petition of Fred D. Rissinger, II for a continuance, the hearing was continued to be relisted by either counsel. 3. To date, neither party has relisted the matter for uw orrmu 6NElBpKER BRENNEM~N hearing. 4. it is believed that it would be in the best interests of the child and the parties that this matter be referred to Dawn S. Sunday, Esquire for a Custody Conciliation Conference in an effort to attempt to reach a mutually acceptable custody arrangement or to narrow the issues for the Court. Counsel for both parties have agreed to refer this matter back to a Custody Conciliation Conference. WHEREFORE, Fred D. Riesinger, II respectfully requests your Honorable Court to order and direct that Dawn S. Sunday, Esquire conduct a Custody Conciliation Conference in this matter. Respectfully Submitted, SNELBAKER & BRENNEMAN, P. C. Phil p H. pare, Esqu re 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Movant Fred D. Rissinger, II . February 7, 1996 uw orncu $N[LB~KER e $R[NN[MRN -2- ~FRTIFTCATE OF SERVICE I, PHILIP H. SPARE, ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the foregoing Motion to be served upon the person and in the manner indicated below: EjRST GLASS MAIL POSTAGE PREPAID ADDRESSED AS FOLLOWS: P. Richard Wagner, Esquire Mancke, Wagner, Hershey & Tully 2233 N. Front Street Harrisburg, PA 17110 ~L'~i Philili H. Spare, Esquire SNELBAKER & BRENNEMAN, P. C. 44 West Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Movant Fred D. Kissinger, II Date: Fehrunry 7, 1996 uw orricea SNEL 9AKER a BRENNEMAN ~ ~ W W J.~ ~ L~' ~ 8 Wz ` ~ ~ ~ ~ ( V N ~~ W ~ O H U LLLLL < <~ ~ F 4 H ~ ~ a ~ l ~ F -1f] ~ (IIII t S ~(, ~ ' p? ~~3 ~~ Z ~ ' ~ ~ ~ ~~jj O ~ m N ~~y n 'yr 7 J V a :fj{ ,;~ FRED D. RISSINGER, II, Plaintiff va. MICHELLE M. RISSINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-7017 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AMID NOW, this ~~ 1'" day of , 1996, upon consideration of the attached Custody Co c 1 at on~Report, 1t is ordered and directed as follows: 1. The Mother, Michelle M. Kissinger, and the Father, Fred D. Kissinger, IIr shall have shared legal and physical custody of 'Pyler Adam Riasirger, born March 14, 1993. 2. The parties shall share physical custody of the Child on a weekly basis, with the exchange of custody taking place every Friday after daycare. The non-custodial parent shall have partial custody of the Child each week from Tuesday afternoon after daycare until Wednesday morning before daycare. The shared physical custody schedule shall begin with the Father having custody of the Child on Friday, March 22, 1996. 3. The parties shall share or alternate custody of the Child on holidays ae arranged by mutual agreement. 4. Each party shall have one uninterrupted week of custody each summer to be taken during one of the weeks when the daycare provider is closed for vacation. 5. The Mother shall have custody of the Child every year on Mother's day and the Father shall have custody of the Child every year on Father's day. 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the terms of this Order by mutual agreement. In the absence of mutual agreement, the provisions of this Order shall control. 7. If either party determines that the shared custody arrangements are not in the Child's hest interests after following the schedule outlined above for a period of two months, either party may contact the Custody Conciliator to schedule an additional Conciliation.Co(:fer~nce if necessary. BY THE COURT, ' ~ 1, ~~ ; ragar n. nayiFy(( uuvy cc: Phililp H. Spare, Esquire _ L~~,-,~.n,~,iL, ~.~A(q~ ~ P. Richard Wagner, Esquire _. _,..: .,~ ~;~ I i ;:;~ ~ (l .. .. 6'RED D. RISSINGERr IIr Plaintiff va. MICHELLE M. RISSINGERr Defendant . PRICK JUDGE: Bdgar B. Bayley IN THE COURT OF COMMDN PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-7017 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY OQ~ICILIATION SUMMARY REPORT IN AOCDRDANCE WITH ClP4Iffi2LAPID COUNTY RULE OF CIVZL PROCEDVi2E 1915.3-B, the undersigned Custody Conciliator submits the following report: 1. The relevant information pertaining to the Child who ie the subject of this litigation ie as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY OF Tyler Adam Riaeinger March 14, 1993 Defendant/Mother 2. A Conciliation Conference was held on March 19r 1996r with the following individuals in attendance: The Father, Fred D. Riaeinger, Ii, with his counsel, Philip H. Spare, Esquire, and the Mother, Michelle M. Kissinger, with her counsel, P. Richard Wagner, Esquire. 3. The first Custody Conciliation Conference was held in this matter on January 12, 1995. The parties were unable to agree on primary custody at that time and a Hearing was scheduled accordingly. The Hearing was continued indefinitely and the parties had this matter relieted with the Conciliator in an attempt to resolve all custody issues by agreement. 4. At the second Conciliation Conference (March 19, 1996) the parties agreed to entry of an Order in the form as attanched. (~~~~~ Date dawn S. Sundayr Esqu re Custody Conciliator -~ ti= r ~~~._.... -.+ z + + ~. `~° 4 ~~ t .. a - 37 r.~ as ~ _ •: _ 7 '_ ~ :'y; y_i +4^. ..;. ~. ~L } .L i/ .~ ~. ~. S; /) ~`~~,„ t+ t~i t F s~<i~'. { > ° i ~ + R +- + ~,i + t t' 3> j a+ i~~'"~+~'~ P sl~ ,may P ~ Z a tr r~ h x a +'i. ~ }T~ # ~~a ~.~'Itt ~ 5~ t ~* ~ `~ '~ '~f~P'X 3i 7C+ ~..1 4 ~.t~~~'j`~~''W~j~~A_ ++Z F - ~ ~ +t~I,} ~4i~^~it'~~'af d'e`w ,~'- e+4~seat-3+k+is rlq ,~4 S,j '~ u t r~ _s. < < r 'trc+~' ~I ti~~~#~y~ r'~ rC y~ )~ { Y~ { T~ ~i5 th? ~f~ f -~t i~.. ` f a *ytl C 1 q } f .t ~ Si '+~ f i ~ k 4 # 1'~~''ii~~t~~. ~ ate Fi H F F _ ~ irx~ ``+~xxz.x~~ r~ SI T 1 htF 'Y k{ 3 1 / f at ~t~ a~+$ 3 #' a~~ jj1 7 t Y t t{ '7 1"+~ 4 L ~l-+i' w ttn a ~ 1 f ~+ i a~4F ~ ~.~.~+y ~ ro x .i 7~~ai~~ ~; SwF ~.~ ~*'„~IFt~~~l~tX 1. ~( Sid' R ( d ~ i[ tt ~ t ~++' Y^rixza +t r+~ i r ky ; +a .• ' a' t" - ~` r ~ a * !t~ ~ ~a ~ {~, - , ++ty .at ~*g *S+i 4t?S'. 9, e.1y ~i ~~?<.r. ~~. .. }~~ JUN ;~ ~~°~ ~ ~ ~ y~. ,h "' FRED D. RISSINGER, II, IN THE COURT OF COMMON PJ.EAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94-7017 CIVIL TERM MICHELLE M. RISSINGER, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER AND NOW, this ~ day of r~ , 1999, upon consideration of the~aCtached Petit `on for Modification, it is hereby directed hat ~th ~p reties and air respective counsel appear before ''''7'"'-' ~6 , Esquires the conciliator, a «~f Pennsylvan a, on the .~'~ day of t 99, at ) o~clock ~.M. for a Pre-Hearing Custo y Conference. At sut chi 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 Por entry of a temporary or permanent order. FOR THE COURT, By: t ~ ~ ~ ~ ~c,~C ~~. wz. Custody Conc ator ~~~~~ tew nrr¢ce SNEC RIIK E R. BRENNCM1IAN 6 51•4RE 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 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 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 ..., FRED D. RISSINGER, II, Plaintiff v. MICHELLE M. RISSINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-7017 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY prnINTIFF'S PETITION FOR MODIFICATION OF CUSTODY ORDER 1. The Petitioner Fred D. Risainger, II, Plaintiff, respectfully represents that on April 1, 1996 an Order of Court was entered for shared legal custody and physical custody of the parties' son, Tyler Adam Rissinger, born March 14, 1993. A copy of the April 1, 1996 Order of Court and related Custody Conciliation Summary Report dated March 26, 1996 are attached hereto as Exhibit "A". 2. The existing Order of Court should be modified because: (a) The child will be beginning first grade at Susquenita Elementary School in Duncannon, Pennsylvania for the 1999-2000 school year. (b) During the 1998-1999 school year the child was enrolled in the kindergarten program at Susquenita in Duncannon, Pennsylvania. (c) During the time periods when Mother had custody of the child, the child did not attend kindergarten on a regular and continuing basis to the child's educational detriment. (d) For the time period of in or about August, 1998 through January, 1999, the child was with Father almost exclusively. ~Aw orncn SNELOAKER. BRENNEMAN b SPARE ~,. , ,; (e) Mother is not a proper role modal for the child due to her numerous arrests for criminal activity. (f) Mother's living arrangements, life style and working environment are not conducive to the child's best interest. (g) Based upon information and belief, Plaintiff avers that Mother is currently incarcerated at the Dauphin County Prison in Harrisburg, Pennsylvania. (h) Father can and does provide a stable, wholesome and healthy environment for the child. WHEREFORE, Petitioner-Plaintiff, Fred D. Riseinger, II, respectfully requests that your Honorable Court modify the existing Order to grant Father legal custody and primary physical (custody with reasonable visitation to Mother because it will be din the best interests of the child. Respectfully Submitted, SNELBAKER, HRENNEMAN & SPARE, P. C. uw orrice SNELOAKEq. BRENNEMAN a SPARE Hy: p p Sp re, Esqu re Pa. Sup eme Ct. ID #65200 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Date: June 25, 1999 Fred D. Rissinger, II -2- pF FRED D. RISSINGERs Its Plaintiff va. MICHELLE M. RISSINGERs Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLPND CCUNTYr PENNSYLVANIA N0. 94-7017 CIVIL TERM CIVIL ACTION - LAW IN CUSRCIDY CRDEit OF 00[IIiT AND NOWT this ~`~ day of ~ZJa.~ r 1996, upon consideration of the attached Custody Conc cation Report, it is ordered and directed as follows: 1. The Mother, Michelle M. Kissinger, and the Father, Eyed D. Kissinger, Its shall have shared legal and physical custody of Tyler Adam Kissinger, born March 14, 1993. 2. The parties shall share physical custody of the Child on a weekly basis, with the exchange of custody taking place every Friday after daycare. The non-custodial parent shall have partial custody of the Child each week from Tuesday afternoon after daycare until Wednesday morning before daycare. The shared physical custody schedule shall begin with the Father having custody of the Child on Friday, March 22, 1996. 3. The parties shall share or alternate custody of the Child on holidays as arranged by mutual agreement. 4. Each party shall have one uninterrupted week of custody each sunnier to be taken during one of the weeks when the daycare provider is closed for vacation. 5. The Mother shall have custody of the Child every year on Mother's day and the Fathec shall have custody of the Child every year on Father's day. 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the terms of this Order by mutual agreement. In the absence of mutual agreements the provisions of this Order shall control. 7. If either party determines that the shared custody arrangements are not in the Child's best interests after following the schedule outlined above for a period of two months, either party may contact the Custody Conciliator to schedule an additional Conciliation Conference if necessary. ,.j BY THE COURTS ~ ~'~ (G~i..C %W k1C~.,~' . Cc ~ 2 ~ fiu~.., n: f!~~" cc: Philip H. Spare, Esquire P. Richard Wagner, Esquire u / C.~i,rta~. 73. ~w,.~.., Edgar B. ayleys Judge ~- sx~ilsrr n FRED D. RISSINGERr IIr Plaintiff Vs. MICHELLE M. RISSINGERr Defendant PRIOR JODGE: Edgar 8. Bayley IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUD1TYr PENNSYLVANIA N0. 94-7017 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY OODICII.IATICN SUMMARSC REPCR'1.' IN AOOOR!]ANCE WITB C[77BII2LArID CO(Nl'7! RULE OF CSYIL PRO(R~[[IIiE 1915.3-Br the undersigned Custody Conciliator submits the following report: 1. The relevant information pertaining to the Child who ie the subject of this litigation is as follows: NAME BIRTHRATE CURRENTLY IN CUSTODY OF Tyler Adam Kissinger March 14, 1993 Defendant/Mother 2. A Conciliation Conference was held on March 19, 1996, with the following individuals in attendance: The Father, Fred D. Kissinger, Ii, with his counsel, Ph111p H. Sparer Esquire, and the Mother, Michelle M. Kissinger, with her counsel, P. Richard Wagner, Esquire. 3. The first Custody Conciliation Conference was held in this matter on January 12, 1995. The parties were unable to agree on primary custody at that time and a Hearing was scheduled accordingly. The Hearing was continued indefinitely and the parties had this matter relisted with the Conciliator in an attempt to resolve all custody issues by agreement. 4. At the second Conciliation Conference (March 19r 1996) the parties agreed to entry of an Order in the form as attached. i'Y)a.~ rl~ ~,7 [o E l 9 9l~ Date Dawn S. Sunday, Esqu re Custody Conciliator I verify that the statements made in the foregoing Petition are true and correct. I understand that false statements herein fare made subject to the penalties of 18 Pa. C.S. S49o4 relating to uneworn falsification to authorities. Fred R nger, II Date: L%S/99 LAW OfllC as SNELBAKER. BRENNEMAN a SPARE i ;. I, PHILIP H. SPARE, ESQiIiRE, hereby certify that I have, on the below data, caused a true and correct copy of the foregoing Petition to be served upon the person and in the manner indicated below: P. Richard Wagner, Esquire Mancke, Wagner, Hershey & Tully 2233 North Front Street Harrisburg, PA 17110 C~~/~ Ph p pare, Esqu re SNELBAKER, BRENNEMAN & SPARE, P. C. 44 West Main Street P. O. HoX 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Petitioner Fred D. Riesinger, II Date: 6/,,?~~ uw arrices II ' S NELOAKER. BRENNEMAN Ni SPARE -7 I ~~yy p W ~ M. 1C~ H .i ~~ 1.1 zz O ` aNNi A, v1 Q p a~ O ~ C ~N ."~ ~ N •.-i ~~ py a N a ~ a a ~ o ~ ~a ~~~322 ~~ ~ ~ a ~ ~ ~ E AUG 1 1 1999(J,~~ ~ FRED D. RISSINGERr IIr Plaintiff vs. MICHELLE; M. RISSINGERr Defendant IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTYr PENNSYLVANIA NO. 94-7017 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDffi2 OF OOU[t'P AND NOW, this 1` day of ~ ~~/ r 1999, upon consideration of the atta ed Custody Conc at on eportr t s ordered and directed ae follows: 1. The prior Order of this Couct dated April lr 1996 is vacsted and replaced with this Order. 2. The Fatherr Fred D. Risaingerr II, shall have sole legal and primary physical custody of Tyler Adam Kissinger, born March 14r 1993. 3. The Mother shall have visitation or periods of partial custody with the Child as agreed upon and arranged between the parties. 4. In the event the Mother objects to the custody arrangements set forth in this Order, the Mother may Petition the Court for an additional Custody Conciliation Conference upon her release from incarceration. BY TAE COURTr i . cc: Philip H. Sparer Esquire - Counsel for Father ` n~.~. 8/~~'qq. Michelle M. Rieaingerr Mother - "f"`°J ,,b,~ ~~ i', ' .~: ; ~,, ,. ~_ ~' .. ~ ; ~, ;, ,,. ~; , ` , .,. ~ ~ , -~ - - --- ~ D FRED D. RISSINGER, II, Plaintiff va. . MICHELLE M. RISSINGEP., Defendant PRIQt JUDGE: Edgar 8. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-7017 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTOCiY OCNCILIATICtJ SUMMARY RF.PC[ZT IN ACCOfiQAN(~ WITfI C[lIDERLADID CC{Nl'Y RLQ.E OF CMG PItOC~URE 1915.3-e, 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 BIIrl'H C[&tRFIT1LY IN CUSR~Y OF Tyler E. Riaeinger March 14, 1993 Father 2. A Conciliation Conference was held on August 3, 1999, with the following individuals in attendance: The Father, Fred D. Rieainger, II, with his counsel, Philip H. Spare, Esquire. The Mother, who is believed to be currently incarcerated, did not attend the Conference and was not represented by counsel in this matter. 3. The Father filed this Petition for Modificatiai of the prior Order of this Court dated April 1, 1996, providing for shared physical custody of the Child. The Father stated that the Child resided exclusively with him from August 1998 through January 1999 and thereafter, when the parties returned to a shared custody arrangement, the Child rarely attended Kindergarten during the weeks in which he was in the custody of the Mother. The Father stated that in June, one of the Mother's friends contacted the Father by telephone to advise that he should not exchange custody of the Child that week because the Mother was in jail. The Father later confirmed with the Dauphin County Prison and the Mother's probation officer that the Mother was then in the Dauphin County Prison for a parole violation with other charges pending. According to the Father, the Mother has not contacted the Father or the Child since that time. 4. The Father's counsel served the Custody Petition on the Mother at the Dauphin County Prison by both regular and Restricted Certified mail, the receipt for which was signed by a prison official on July 19, 1999. The Conciliator received no contact fran the Mother, or other person on her behalf, prior to or during the scheduled Conciliation Conference. 5. eased upon the representations made by the Father and his counsel at the Conciliation Conference and the fact that the Mother neither attended the Conference nor contacted the Conciliatory the Conciliator recommends an Order in the form as attached. Date Dawn S. Sundayr Esqu re Custody Conciliator MICHELLE M. RISS[NGER PLAINTIIT v. FRED D. RISSINGER,11 DEFENDANT IN'I'llti COURT OI~ COMMON I'LF:AS OF CUMBERLAND COUNTY, PENNSYLVANIA . 94-7017 CIVIL ACTION LAW . IN CUSTODY AMF.NDF.D ORDER OF C'OUR'T AND NOW, this 20th day of October , 2000, the original Order of Court is amended as follows: It is hereby directed that the parties and their respective counsel appear bel'areDawn S. Sunday, Esq. ,the conciliator, at 39 Weat Maln Street, MecltenlcsburQ, PA I70S5 on lltc 14th day of November , 2000, at3:00 p.m. for aPre-Hearing Custody Conference. At such conl'crcnce, nn 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. hnilurc to appear at the conference may provide grounds for entry of n temporary or permanent order. FOR THE COUR"F, By: 1s/ Ddwn S Sn»dav, 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. Far 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'1'HIS 1'APER'f0 YOUR A'I-I'ORNEY AT ONCE. 1F YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFhORD ONE, GO'I'O OR'fELEPFIONE T}iE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL IIELI'. Cumberland Cowuy Bur Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 '1'elephonc (717) 249-31(G UO OCT 2) AM IU: ,S4 cu~ti~~;IriV~~UV-Y MICHELLE M. RISSINGER IN'I'llli C'OUR"1' OI~ COMMON PLEAS OF PLAINTIFF C'UMBI3RLAND COI1N'I'Y, PENNSYLVANIA V. FRED D, RISSINGER, 1[ • 9.1-7017 C'IVII. AC"PION LAW DEPENDANT IN CUSTODY )RU 'R OF )URT AND NOW, this 10th day of October , 21100, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S, Sundry, Esq. ,the conciliator, at 39 West Mrln Street, llfechrnlcsburR, PA 17055 on the 4th day of November , 2000, at 3:00 p.m. for a Prc-Flaring 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 ut the conf'ercncc. I'ailurc to appcnr al the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: /s/ Dawn S. Srrrrday, Esg,~ 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 reasonnblc 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'fAKE THIS PAPBR'1'O YOUR A"1'1'ORNEY AT ONCE. IF YOU DO NOT F{AVE AN ATTORNEY OR CANNOT AFFORD ONE, GO "I'O OR'I'ELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WF[ERE YOU CAN GGI' LEGA[. HELP. Cumberland County Bur Association 2 Liberty Avauc Carlisle, Pennsylvania 17013 'T'elephone (717) 249-31GG r '-- . ; ..l' ~p ~ ,, acr , 3 ~:J L~+ THE COL1tT OF CO~L~fO~: PLEAS OF CUMMBERLAND MirhallP M Risalnagr _ PLAL~ITIFF v. Fr d D Kissinger. II DEFEDiDAi~JT COL",v I'`c', PEV~'SYZ4:-~.~+Z~1 CIY'IL - ACTION -Y751T.YTIOv ~, moo: 9N- 7vi 7 of ORDER OF THE COLT~T You, FraA D Ri asinQer ITT defrndant. have been sued in court to obtaitt visitation of the child(ren) You are ordered to appear in person on day of at _\~I. fora (conference) (hearing). You are further ordered to bring «ith you the child(ren): If you fail to appear u provided by this order or bring the child(ren), an order for ~isitadon may ' be entered against you or the court may issue a warrant Y'or your arrest. 1'OL; SHOULD TAI:E THIS PAPER TO ~C'OL-R L.aWYER AT ONCE. IF YOi; DO SOT HAVE A LAWYER OR CAv~iOT .-1FFORD O~'E, GO TO OR TELEPHOtv'E THE OFFICE SET FORTH BELOW' TO FLV'D OL'1" WARE YOti C,A~ GET LEGAL HELP. dame Address Telephone Kumber BY-THE COL7tT: Date. 1N ThfE COURT OF COMMON PLEAS OF _~l1~fHEl;LBNjL-- CUUN'I't', PbTNSYLVANIA Michelle M. Rissinaer PI.AIN'I7T'F v. ... CIVIL -ACTION -VISITATION NO: `1 u~7yl I OF COMPL:IIN7' FOR VISITATION 1. Thaplaintiffis Michet to M. Rissinaer ,residing at 451 FulleRonAvenue, ~rprl n RiaaingyL, II DEFENDANT Cambridge Springs, Crawford County, Pennsylvania. 2. 'I'hedefeadantie Fred D. Rissinaer, II .residing at 24 S_ Market St. (Street) ~tmr nnpn, PA 77020 Perry County (City) (Zip) (County) 3. The plaintiff seeks visitation of Ute following child(ren): NAME PRESENT RESIDENCE 29 S. Market St. AGE The child (was) (vas not) born aut of wedlock. The child is presently in the custody of.Fred n. Rissinaer, iI who resides at (Name) 29 S. Market Street, Duncannon, PA 17020 (Street) (City) (State) During the past five years, the child has resided with the following persons at the following addresses: Name -Famed--O-rILiasinge r- Addresses 4 Umherto Ave. 213 Lincoln Ave. $27 Michelle Ct. 2g S Market St. N. Market St. Dates 1998-1999 1997-19 8 1996-1997 _2_000 1999 The mother of the child is Michelle M. Kissinger ,currently residing at 451 Fullerton Avenue, Cambridge Springs, Pennsylvania 16403. She is (married) (divorced) (single). ~5 The father of the child is Frey D _ Ri v_eing~r ~ I I ,currently residing at 29 S. Market Street, Duncannon, PA 17020 He is (married) (divorced) (single). 4. The relationship of the plaintiff to the child is that of mother. The plaintiff is currently incarcerated at the State Correctional Institution at Cambridge Springs, Pennsylvania in the county of Crawford, where she is serving a sentence of from ~ ~ t F ~ a a to ~ / t ~ / n 2 . ~. The relationship of the defendant to the child is that of Father .The defendant currently resides with the following persons: Name Relationship Wife Step-Son 6. Plaintiff (has) (has not) participated as a party of witness, or in another capacity, in other litigation conceming the custody of the child in this or another court. Thr court, term, and number and its relationship to this action is: P~aintiff (has) (has no) information of a custody proceeding conceming the child pending in a court of this Commonwealth. The court, term, and number, and its relationship to this action is:_ Plaintiff(knows) (does not know) ofa person not a party to the proceedings who has physical custody of the child or claims to have custody or visitations rights with respect to the child. The name and address of such person 7. Thr best interest and permanent welfare of the child will br sen•rd by granting requested relief because: I hav i d o main n contact with Tvler, I do have vi vi i-anon riq~,g, >• have had shared lectal and uhysical custody of Syter „Writ my in a r a ion, and y~t_._have been denied any type of . contact with Tyler. 8. Each parent whose patcmal rights to the child hove not been terminated and the person who has physical custody of the child have been named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the; pendency of this action and the right to intervene: Name Address Basis of Claim r FrpA f]_ Ri aal ngoar_ TI Z,QR_ Ma rkaf Ahrra c~h Wherefore, plaintiff requests the court to bunt visitation of the child. Plai tits' - 1 verify that the statements made in the Complaint are true and correct. 1 understand that false statements herein are made subject to the penalties of I S Pa C.S. r,+ 4903 relating to unstvorn falsification to authorities. ~,~e o Q ~ ~fY1. Q, t n_rx .ma.Q~. Plain t~.f- LV THE COLRT OF CO~Ly,IO~ PLE.aS OF CUMMBERLAND COL'VTY, PENtiS~ZVA~ Michelle M. lYlssinger s CIVIL - ACTIOir -~7SITATION Pt.~TIFF v. Fred D. Rissincter. II T+O: ~/-~V~ OF DEFE~~D.-~.~T :1PPLICATIOV TO PROCEED ~; F(~g.~(,~ p,~i'PERIS TO: THE HONOR.-IBI.E Ji.~G£ OF THE .~8O4 r. COURT SOW' CO~ffS THE Plaintiff, Michelle M. Kissinger ,and respcctfully represrnts the folioaing: 1. That your plaintiff is incarcerated at the State Correctional Institution at Cambridge Springs, Pertrtsclvania. ?. That plaintiff is unable to pay cost of filing this action. 3. That the only moneys that plaintiff receives is that of prison wages. ~. Plaintiff has only R t S _ n o on his prison account. 5. Plaintiff does not oan any real estate, stocks, or bonds. Plaintiff has neither a checking nor sa~in¢s account. 6. Plaintiffs Social Security number iv 195 52 0825 ,` 7. PLvntilf's family is unable to advance un[o her any moneys to help pa}• these costs. R~REFORE, the plaintiff prays this Honorable Court to issue an order lcttittg him proceed in this action as an indigent party. Respectfulh~ submitted ~FFID.~~T'[' OF I~1~IirE~Cl' ~ ~. ~ .a~'D V0~4', [his l.P ~ , day of ~om~"t, r~ ,before me the undersigned authority, personalty appeared Mi rhnl 1 a M _ Ri aai_npPr ,who being duly sworn to law, deposes and swears that she is the plaintiff in the foregoing action and that the facts sot forth are true and correct to the best of her I:noaledge, infontiadon and belief. :1t3'iant 777 Sworn and subscribed to before me ttris T~O~_day of~c,~~~~. ~(Z in she t;uunty of Crawford. State of Pennsv(vania. ,~,~ry sdat'~ ~~ • ta•: ~}(~~baExPlree~ac•17,2 Ot • .~ IN THE COURT OF COPIMON PLEAS OF CUMBERLAND COUNTY, PA CRIMINAL DIVISION COMMONWEALTH OF PENNSYLVANIA VS. Docket No.N 9 ~l- 7v~~ Minhnlla M RiaSinLJBr -- Defendant IN FORPIA PAUPGRIS STATEPIENT Defendant, __Michelle M. Rissin4er states under penalties provided by 18 Pa. C.S.A. § 4904 (unsworn falsification to authorities) that: 1. I am the defendant in the above action and because of my financlal con- dition I am unable to pay the following fees and costs. 2. Ply responses to the questions below relating to my ability to pay the fees and costs are true and correct, (A) Are you presently employed? YES NO (1) If the answer is YES, state the amount of your salary or wages per month and give the name and address of your employer. R a - _o .Mortal Fa _i li Y~ Main rtan- 74 nPr hn„r (2) If the answer is NO, state the date of your last employment and the amount of salary ur wages you received. (8) Ilave you received ~oithin the past 12 months any income from a business profession or other form of self-employment, ur in the form of rent payments, interest, dividends, pensions, annuities, social security benefits, support payments ur other source'? YES \0 If the answer is YES, describe each source of income, and state the amount received from each during the past 1' months. (C) Do you have a checking ur savings account? YES NO If the answer is YES, state the total amount of each accowiC. , '~` Page d2 (D) List the persons, if any, who are dependent on you for support and state their relationship to you. (E) List all your debts and obligations: X90.440 in fines, costs and restitution 3, I understnnd that a false statement or answer to any question in this verified statement will subJect me to the penalties provided by law (misdemeanor of the second degree), D~ndant ~` AFFIDAVIT Before me, the undersigned authority, personally appeared Michelle M. Rissin4er who being duly sworn according to law, deposes and says that she is the Petitioner in the foregoing IN FORMA PAUPERIS STATEh1ENT and that the facts set forth therein are true and correct to the best of her knowledge, information and belief, SWORN TO AND SUBSCRIBED BEFORE ME THIS Lc ~Y\ DAY OF ~ , .I_ , ~ l~J 1 , o1C~. ' {~7,~~}~ryn~9~eTrw'tLn'Mx' lty ~~i:_~_ \ y'~Ommislel~~Plf~o Dec.~1 2001 ..•, , F ' ; i , ~. ~ :~ - , ,-., ;., r, ~-.:_~~. F orr~~ /bU ~, ~ ~' ~C~O~`, ~m~ti~ ,~-~.~ ~~c i~9 ~~~ , 4A ~ ~ ~~, 3 ~p \ ~ ~ ~Dv~ ,~ ~`~. ~ ~ ~ dew ~-~a,o ~n~h.Qd,_~c9 -tom ~ ~~ ~~~ cn mQ~llm ~O,,m v~ ~ ~~n ~ ~ E~~ ~" `~, o.~ ~i'~I - ~~~i~- `~Ico l~ 5~.~ c\o~s ~.~-,-~c~ ~.~~mn c9-~ taw ~ ~.~ o.- ~~ -~~ .~.~~~ ~o ~~~~ . . 4 4, ..« ,~ i ~_~ : , ~, ~,, cam ~~ ~.~~~.e~ ~~ ~cs~n o~~s~~x.~:.~-~ W~ sue, . `~ ~Gmk `emu UYl ~C~l.~-.0-!YLCc~ 1 ~-~C4RL1 O.m ~ ~~se~,~.~o~-~ru ~ 1, f 5~-~- c~ m. ~' ~ F~ ~a i ~~~ f ~~~t~-- ~l ~~ ~~ /h Ua3 _ _ '''""^ "~ " °"" COMMONWE TH P NSYLVANIA ~' ~ ~! ~ , ~ ,, a, DEPARTMENT OP CORRECTIONS EPELULJIED lAGLI1IF.! AHD PRODRAM9 STATE CO TITUTION aarrnar A. suRD, Pn. v E71EClJf"i DEPITfr aECnEtAnr WIWAM ~. WOlre P U AT CA INGS su ER rmIOENT lutlwbn Awnw AOOnr AI RpYr Caalbl0p~ EPNnp, M 1M011 tal To BupRnrnertl T~MlAaw ~t{JM6/00 The Cambridge Springs Correctional Institution For women is a minimum/medium security level prison for female offenders. It is the mission of the Parenting Program of Cambridge Springs Correctional Institution to strengthen the bonds between inmate mothers and their children. We teach inmate mothers parenting skills and educate them to the developmental stages of children so as to increase their understanding of their role and responsibility to their childrer. and to the community. We provide counseling and assist in matters concerning custody issues, placement of childrer in programs and agencies and communication with children and/or the caregiver of the children. [n addition our parenting program provides enhanced visits for each inmate mother who has no record of restrictions. Inmate mothers have three visiting areas where they may visit with their children. Those areas are the visitinc room for the general population, the outside visiting area that is available during spring/summer season, and the parenting unit. The visiting room has swell-equipped playroom area for all children. The outside area has picnic tables to sit at for snacks and meals that may be purchased from the vending machines in the visiting room. Outside play equipment is provided (i.e. balls, ring toss, hoola-hoops, etc.) with which the parent and child/children may play. The parenting unit at Cambridge Springs is a modular unit designed to provide a safe, secure home environment for the incarcerated mother to have one-on-one time with her child/children. Any inmate in the general population, who does not have any restrictions, may use the unit for a visit. At no time are incarcerated mothers shackled or handcuffed in the presence of then children during visits at the facility. In addition either the Parenting Director or the Parenting Counselor supervises visits. Enhanced visits are allowed on Fridays, Saturdays, and Sundays. During regular visiting hours the mother may bring her child/children back to the parenting unit. A functional kitchen is used to prepare snacks and refreshments for visits. A large dining room area is used for group snacks and planned activities. A comfortable living room setting allows mothers to watch videos, play board games or pnt together puzzles with their children. A toddler room is specifically designed for mothers with younger children that includes a playpen, racking chair, baby swing and rocking cradle. Also a children's table is provided for toddlers to finger paint or play with play dough, both are popular activities among the younger children, A teen room is provided with board games and another television set and VCR to watch videos that are more appealing to older children. [t should be noted that Cambridge Springs Correctional Institution also provides classes in Parenting Skills, Child Development and support groups called Parents Anonymous. In addition we are also incorporating a "Mom's Story Time" program that provides the inmate mother the opportunity to be videotaped reading a book to their child. Should you need any additional information please contact Ms. Janeen Christ, Parenting Program Director, SC[-Cambridge Springs, 451 Fullerton Avenue, Cambridge Springs, PA 16403. Phone (814)398-5400. O ~ £a ~ W ~ •H [ il H ~ ~~a ~ ~~ ri~ ' ~ H ~ h g a E g~ r',~ i ~a Na ~ [~ti¢ a c ~ ~ ~~a ~ ~ 'a ~ ~' ~ ~ ~3,~ o ` ~ ~ ~ r~,~, ~~ v ,~aan~' MICHELLE M. RISSINGER~ Plaintiff vs. FRED D. RISSINGERi II, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-7017 CIVIL TERM CIVIL ACTION - LAW IN CUSTOCY CE2DF.R OF COURT AND NOW, this L ~ day of ~ ~ 2000, upon consideration of the attached Custody Conc 1 at on Reports t is ordered and directed as follows: 1. The prior Grder of this Court dated August 11, 1999 shall continue in effect. 2. The Mother shall be entitled to have telephone contact with the Child at least 1 time per month rn the first Sunday of the month at 8:00 p.m., provided that the Mother pays the Father for the coat of the telephone call in advance. The Father shall provide to the Mother copies of the billings fran the telephone canpany reflecting the charges the Father has incurred on an ongoing basis. The Father shall not deny telephone contact between the Mother and the Child so long as the Mother is paying all coats of the telephone charges in advance due to her inability to place non-collect calla from the correctional facility where she is currently incarcerated. 3. The Father shall ensure that the Child reaponds~ at least on a monthly basis, to letters received from the Mother. 4. The Father shall provide the Mother with copies of the wild's report card9 dating back to the beginning of first grade and continuing on an ongoing basis. 5. The Father shall notify the Mother either directly or through the Child's maternal grandmother of any medical emergencies or major medical treatment received by the Child. ~~ BY THE CCURT, / ~~ nuya~ o. ocy.icy^~ .~ w. cc: Michelle M. Rieainger, Mother ~ ~ ~~ ~~"""" Philip H. Spares Esquire - Counsel for Father I'_ 2.00 RXg s'. ,.. ,= Z~. ~~ . ,,:. ,;, ;_:: ~>> MICHELLE M. RISSINGER, Plaintiff Va. . FRED D. RISSINGER, II, - Defendant PRICK ,7[IDGE: Edgar B. Bayley IN THE ODURT OF OCMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-7017 CIVIL TERM CIVIL ACTION - LAW IN CUSTOCY C[JSTODY OONCILIATICN SUMMARY REPORT IN AOOC(tBANCB WPPEI CIlIDERLMID OOIITP7t RULE CF CML P%7CBaIAtB 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 ie as follows: NAME BATE OF BIIrlH QiiRENPLY IN CU31~DS( OP Tyler S. Kissinger March 14, 1993 Father 2. A Conciliation Conference wa.s held on November 19, 2000, with the following individuals in attendance: The Father, Fred D. Kissinger, iI, with his oounael, Philip H. Spare, Esquire, and the Mother, Michelle M. Risainger, who currently is incarcerated in the Cambridge Springs State Correctional facility, but participated in the Conference by telephone. 3. The parties agreed to entry of an Order in the fot~n as attached. A1r1W~~n,bG, /S,~o~ Date Daim S. Sunday, Eaqu re Custody Ccnciliator FRED D. RISSINGER,11 IN'I"III! COI1R 1' UI' ('(Ih1MON I'LIiAS OI' PLAIN'I'll'F : ('IIMHI'RI.ANO('OIINI'Y, I'IiNNSYLVANIA v. : 94-7017 ('IVII. A(' 170N I.AW M[CHELLG M. RISSINGFik D[iPGNDAN"I' : IN l'l 1Sf01)'i Sl812ERl1LCS1Lli'1 AND NOW, _ Wedne~J~y, t)cluber 2Jt 2001_ ,upon cunsidrruliun of the uttuuhrd Complaint, it is hereby directed (hut parties and their respective counsel appear before _ _pawn Y. Sunday, tsq. ,the conciliator, at 39 Wed Maln Srreet, Mechanlnburg,l'A 1705 un I'uaday, November 20, 2001 pt 1:00 PM for o Pre•Flearing Custody Conference. At such conlerence, un efl'orl will he mule W resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the rssucs In hr heard by the coati, and to cnler into o temporary order. All chiWrcn age live or older may also he pascal nl the nml'crcnce. Failure to appear ut the conference may provide grounds for entry of a lcntporary or pennnncnt order. The court hereby directs the parties hr furnish any uud all exlsling 1'rnlectlon from Abusa orders, Special Relief orders, and Custody orders to the conclllalor 4g hours prior to scheduled hearing. POR'I'llh. COIIIt'I', I )y: -~`~ " ------Dawn. S,. Stut(lay, ~sq,. ;'r',.L ('usludy Cancilinutt I The Courl of Common 1'leus ol'('wnhcrlund County is nyuired by low to comply with the Americans with Disabilites Act of 1990. For inliunmtion nlwul nccessihlc IitcdiUes and reasonable accommodations uvoilable to disabled individuals having business beline the court, please conluct our offiw• All arrangements must be mode at Icust 72 hours prior to any hcuring or business bclitre the court, Yau must intend the scheduled conference or hcuring. YOU SIIOl11.D'I'AKIi'I'lllti I'AI'lilt'I'O 1'(I1IR A'I'I'ORNIiY A'I'ONCIi. IF YOU DO NO'f IIAVIi AN A'1'1'OILNIiY Olt CANNO"1' AhhURU t )NI', (iO'I'OUR'I'lil.lil'110NG'1'1lfi OFFICG SHT hOR'1'll 1)CLOW'I'O FIND Oll'I' \VI IIiRIS YOl l ('AN (il'.'I' I.If(iAl. I llil.l'. ('untlrrrlund ('nunly Ilur Association I Jhcrly Avenue (luhsle, I'cnnsylvuniu 1701) 7elephune 1717- 249-J IGG ,;-;r ~uU~~`Y CU~,~.P`,,S~~l'~~lA~ ~ ~ ~ ~~ ,tom ~.~o /O ~7~/D/ LLN ' l '`r.2~ ~ ~~~~ /c' :,7y0/ ~/~ _ ~I ~,~ OCT ~9 2001 FRED D. RISSINGER, II, IN'1'FII? COUR'P OF COMMON Plaintiff I'L1?A5 OP CUMMIIERLAND , COUNTY, PENNSYLVANIA ve. No. 94-7017 Civil Action-Law MICHELLE M. RISSINGER, Defendant Cuotody Y'ou, Fred D. I(issinger, Gave been sued in Court to modify custody Orders for the child: 'fylcr 1~. Kissinger, You an ordered to appctr in person ;u On , at o'clock _.M., for a conciliation or uusliatiuu runfercncc. a pretrial conferanee. a hearing before the Court. If you fail to appt~tr as provided by this Order, an order for custody, partial custody or visitation maybe entered ati~ainst you ur the Court may issue a warrant for your arrest. YOU SHOULD 'T'AKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse, 4'h Floor CarBslc, PA 17013 (717) 240-6200 AMIsRICAN5 WPI'li DISAIIILI'1'IFS ACI' The Court of Common Plans of Cumberland County is required by law to comply with the Americans With Disabilities Act of 1990. l~or information about accessible facilities and rctso~table 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 heating or business before the Court. You must attend the scheduled conference or hearing. 13Y '1'I-IL COURT: Date: r PRED D. RISSINGGR, II, Plaintiff ve. MICHELLE M. RISSINGER, Defendant IN'I'HG COURT OF COMMON PLEAS OF CUMMSERLAND COUNTY, PENNSYLVANIA No. 94-7017 Civil Action-Law Custody NOW COMI?S the Ucfcndant abuvc-natncd, Michelle M.Kissinger, by and through her attorney, Keith I:. Kendall, I?sq., to petition the Court to modify the custody orders currently in effect in the above-captioned matter, and in support thereof, avers the following. 1. The petition of Michelle Kissinger respectfully represents that o» Auhntst 1t, 1999, and November 21, 2000, Orders of Court were entered for telephone and mail eorrespondcttcc visitation with her san, "1'ylcr Kissinger. 2. 'I'hcsc Orders should be modified because: a. Petitioner has been grtntecl pcc-relrtse from the incarceration that uecessitatecl the limited contact granted in the prior ocdecs; b. Petitioner currently resides within the community, at a "halfway house" located at 2901 North Sixth Street, I Iarrisburg, Dauphin Comuy, Pennsylvania, ]7110; c. Petirioner desires to renew persona) contact with her sou, to the maximum extent pcnnitted by her pre-relc:tsc limitations; :uu1 d. Petitio»cr's rcyucsts for personal visits with her sun have been denied by Respondent, through counsel, unless Petitioner complies with onerous and unnecessary conditions for such visit, unilaterally imposed by Kespondeut, and not contemplated within any existing Order of this Court. 3. 'T'his matter has been previously conciliated by Dawn S. Sunday, Iisq., who is familiar with the backC,KOUnd in this matter. WIIIsRisFORI~., Petitioner requests that the Coutt order conciliation as to the foregoing issues, and that an Order therc~aftcr be entered, that provides for the I'etitioncr's renewal of keyuent and regular contact with her sou. Date: / ~ ~ 7 D - .._-_ Keith Li. Kendall, Gsy. Kcidt Kendall, I'.C. 4409 North Front Street I Iarrisburg, PA 17110 Supreme Court ID No. 42910 I verify that the statcmetiits made in this Petition Cor Modification arc true and correct. f understand that false statements herein are made subject to the penalties of 18 Pa.C.5. §4904, relating to unswont falsification to authorities. Date: ~~~ 1 '1 ~ UI ~1;~ .Q ~F ~;1~^~TZ~ ~t~. - ~ hfichelle M. Rissintinr, Petitioner ~ m ~~ ~ CV ~4 ~ c.] p ~. ~ `-~ ~i ~L . ,, ~ _ L O i~ ~ ,~ U ~. c '~`- O~ .~ ~ _ F~- ~Q ~ 1 _ J~ ~) ~~~ ~7 zzy$ [[yy w W U ~ H~ ~ ~ O 6 ~ C aq ~ o W4 `a ~ N,~ w ~& ..]WW ~~ "y ~R~ GPa. ~ pl w~ ~ E ~ N ~ 3 ~~ A ~ ~ a ~ I~UU :~ 0 LUQD ``~ . FRED D. RISSINGER, II, Plaintiff vs. MICHELLE M. RISSINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94-7017 CIVIL ACTION LAW IN CUSTODY ORDER OF COUR'P AND NOW, this ~{"~ day of ~1,~ ;~.ext^ 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The parties, through counsel, Shull contact Guidance Associates, or other professional selected by agreement, to discuss the procedures and costs involved in obtaining counseling for the purpose of reestablishing contact between the Mother and the Child. The parties shall cooperate in following the recommendations ofthe counselor with respect to scheduling the necessary sessions. 2. The parties agree that the Mother shall contact the Child by telephone on a regular basis each week between 6:00 p.m. and 8:30 p.m. on Sundays and Wednesdays and at any other times when the Child is available. BY THE Edgar B. Bayley, ' J. cc: Philip H. Spare, Esquire -Counsel for Father / Keith E. Kendall, Esquire -Counsel for Mother C~`°' 1~-5-~I ~ S ~/ O` ~. l ~, ~ FRED RISSINGER, II, Plaintiff vs. MICHELLE M. RISSINGER, Dcfcnd:mt PRIOR JUDGE: Edgur D. Daylcy IN 'fHE COURT OF COMMON PLEAS OF CUMDERLAND COUNTY, PENNSYLVANIA 94.7017 CIVIL AC'f10N LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITFI CUMDF.RLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: ]. The pertinent information conccming the Child who is the subject of this litigation is as follows: NAME DATF. OF DIRTH CURRENTLY IN CUSTODY OF Tyler S. Rissingcr March 14, 1993 Father 2. A Conciliation Conference was held on November 20, 2001, with the following individuals in atlendancc: The Father, Fred D, Rissingcr, with leis counsel, Philip H. Sparc, Esquire, and the Mother, Michelle M. Rissingcr, with her counsel, Keith E. Kendall, Esquire. 3. The putties ugrced to entry of an Order i~n the forni as attached. ~Uu~cn lvn aL r D oo / '~'C~....~~-l~.-cQ6s.N Date Dawn S. Sunday, Esquire Custody Conciliator IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FRED D. RISSINGER, II., ) Plaintiff ) v. ) MICHELLE M. RISSINGER, n/k/a ) MICHELLE M. QUIGLEY, ) Defendant ) NO. 94-7017 CNIL TERM CNIL ACTION -LAW IhT CUSTODY/VISITATION STIPULATION FOR AGREED UPONnCUSTODY ORDER THIS STIPULATION is entered into this ~~~ aY of , 2007, by and between FRED D. RISSINGER, II., ("Father"), of Dauphin County, Pennsylvania and MICHELLE M. QUIGLEY, ("Mother"), of New Castle County, Delaware; WITNESSETH: WHEREAS, the parties, former husband and wife, are the biological parents of Tyler A. Rissinger, age 14, born March 14, 1993; WHEREAS, on December 5, 2001, a modified custody order was entered by the Court of Common Pleas of Cumberland County, Pennsylvania, at the above-captioned action number, which remains in effect; WHEREAS, Father presently resides in Dauphin County, Pennsylvania; WHEREAS, Mother presently resides in New Castle, Delaware; WHEREAS, the parties are desirous of entering into this instant Stipulation to modify the terms of their existing custody order so as to specifically settle and resolve the issues of legal and physical custody of their child without the necessity of formal court intervention; N WHEREAS, it is the intention of the parties to have this Stipulation entered an Order of Court in the Court of Common Pleas of Cumberland County; NOW, THEREFORE, in consideration of the premises, and of the mutual promises, covenants and undertakings hereinafter set forth, Mother and Father, each intending to be legally bound hereby, covenant and agree as follows: Leal Custody. The parties shall share legal custody of their minor child, legal custody being defined as the right to make major decisions affecting the best interests of the child, including, but not limited to, medical, religious, moral, educational and general parenting decisions. The parties agree to discuss and consult with one another with a view towards adopting a harmonious policy calculated to promote the child's best interests. Each party shall have the right to be kept informed of the child's educational, social, moral and medical development. Each party shall be entitled to full and complete records and information concerning the child from any doctor, dentist, teacher, treatment institution or similar authority and to have copies of all reports, notices or other communication given to either parent. To effectuate the parties' intent in this regard, each party agrees to execute any and all documents necessary upon presentation thereof to facilitate the exchange of information to the other parent directly from the appropriate doctor, dentist, teacher, treatment institution or similar authority. Each parent shall notify the other of any matter relating to the child which could reasonably be expected to be of significant concern to the other. Day-to-day decisions shall be the responsibility of the parent then having physical custody. The parent having physical custody of the child at the time of any emergency shall have the right to make any immediate decisions necessitated thereby but shall inform the other parent of that emergency and consult with him or her as soon as possible. 2 2. Physical Custody. The parties agree they shall share physical custody of the minor child pursuant to a schedule that the parties may, from time to time, agree upon in accordance with the child's best interest, considering the child's physical, intellectual, and emotional well being, and his educational and recreational activities. Mother shall be deemed the physical custodian of the child during the academic year, and the child shall attend school in the school district of Mother's residence. 3. Holidays. For all holidays, the parties agree to share physical custody of the child pursuant to a schedule that the parties may, from time to time, agree upon considering the best interests of the child, including his scholastic activities. 4. Transportation. Transportation for all custody exchanges shall be by mutual agreement of the parties. 5. Telephone/Address. Each party shall keep the other apprised of his or her telephone number and address. Each party shall be entitled to reasonably telephone privileges with the child at least one time per day, while the child is in the custody or control of the other party. 6. Notification. If either parentis going to be away overnight with the child from his or her residence for two consecutive overnights or longer, that parent shall provide notice to the other parent as to the location of the child and a number where they can be reached. Notice shall be given at least forty-eight (48) hours in advance of the overnight travel. 7. Entry of Court Order. The parties agree the terms and provisions of this Stipulation shall be entered as an Order of Court, the cost of which shall be shared equally. 3 IN WITNESS WHEREOF, the parties hereto set their hands and seals on the dates of their acknowledgments. rtness Witn~ ~ Fre D. Rissinge , II Mic lle M. Quigley 4 •~.~ -- ~ -i-i _ ~ _ - ~-,' i-~~~ --.5 t,- G:J - .. __ _' ~-i _ ~...~ sl '~ 4:,~ - r .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FRED D. RISSINGER, II., Plaintiff v. MICHELLE M. RISSINGER, n/k/a MICHELLE M. QUIGLEY, Defendant AND NOW, this ~~ day of ,upon consideration of the parties' Stipulation for Agreed Upon Custody Order, attached hereto and incorporated herein by reference, it is hereby ORDERED and DECREED that the terms- and conditions of said Stipulation are hereby made an Order of Court. NO. 94-7017 CNIL TERM CIVIL ACTION -LAW IN CUSTODY/VISITATION BY Distribution: `\ ~onald T. Kissinger, Esquire, P.O. Box 810, Harrisburg, PA 17108 ~~D f~ ed D. Rissin er II. 231 Cabin Road L ens PA 17048 g yk , .c~Y" c~ ~ . h~mP~ >.. try ~ ~ ~~_ ~ J., a ,- ~~ ~ -M-.~_ _ ~- I,.T,,, tom,,, '2-,, t^.„ {~ -..~