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SANDRA M. LONG,
plaintiff
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vs.
STEPHEN K, RYDER,
Defendant
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95- (., '/<if' CIVIL TERM
IN CU8TODY
AND NOW, this
e1rl'\
ORnRR OF COURT
day of ~( h......bIJr,
1995, upon
onsideration of the Complaint filed in this matter, it is hereby
and their respective counsel appear before
, the conci liator, at ::;> "I tv. Plt,:n 'S)
,
, Pennsy 1 vania, on Tl.<.6Stky ,the 97 h
199~, at --1 0 :l,c 0' clock 11., m. for a Pre-
irected
that the parties
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ay of
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,
earing Custody Conference. At such conference, an effort will be made
o resolve the issues in dispute: or if this cannot be accomplished, to
efine and narrow the issues to be heard by the Court, and to enter a
emporary order. All children aged five or older may also be present at
he conference. Failure to appear at the conference may provide grounds
or entry of a temporary or permanent order.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
AVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
ORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR, FOURTH FLOOR
CUMBERLAND COUNTY COURT HOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 240-6200
BY
o....v
FOR THE COURT,
d ~)(
CUSTODY CONCILIAT
AlED-OFFlce
OF THE PROTHONOTARY
9S DEe -5 Ail 1/: 57
CUI.ll3EP.!A'JD Cr
PEt~NSYI.V.'IJ'J?~UN1Y
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Sarxlro M. Long
VB. .
Stephen K. Ryder
CASE 00, 95-658
IN CUSTODY
(TRANSFERRAL OF REX:ORDS TO CUMBERLAND COUNTY)
.
<XJBHiEAL'1'II OF P~VANIA
CXllIf1Y OF PERRlC
(Signature on Order of Court attached)
President Judge
I, WM. M. TEMPIEl'ON , Prothonotary of the 41st Judicial
District of the Court of ~ Pleas, Perry County Branch, do hereby
certify that the Attached true copy of the original
Order of Court dated November 09, 1995, to transfer the file to
Cumberland Countv
IN TPSrIIICNY WIII!RmP, I herel.D1to
BUbec:ribe my hand and affix the seal
of the Prothonotary of the 41st Judicial
Perry County Branch, O........--lth of
Pennsylvania this 14th day ofNMDter
A.D., 1995
I, KElm B, QUIGLEY , Judge of the Perry CoImty Court of
~ Pleas - Civil of the ('0..... .,1oIea1th of Pennsylvania, do hereby
certify that, WM. M. TEMPIEl'ON who has given the preceding
certificates, vas the Prothonotary of the said Court of ~ Pleas
41st Judicial District, Perry CoImty Branch of the ('0..... "IWCalth of
Pennsylvania at the time of so doing, and that his attestation is
in due form, and his signatuure thereto is genuine.
Given under my hand this 9th day of November ,A.D., 19.22.-.
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SANDRA H. LONG,
Plaintiff
vs,
)
)
)
)
)
)
)
)
IN THB COURT OF COMMON
PLBAS OF PERRY
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95-658
IN CUSTODY
8TBPHBN K. RYDBR,
Defendant
OIlDBR OF COURT
AND NOW, this <j1J day of tJcJ~~ , 1995, it appearing that the parties bave
agreed tbat tbe proper venue for this case is in Cumberland County, Pennsylvania, and
upon the joint motion of tbe parties for the transfer of tbis case to Cumberland
County, we hereby order as follows:
1, Tbis case is hereby transferred to tbe Court of Common Pleas of Cumberland
County, Pennsylvania.
2. Tbe Prothonotary of this Court shall assemble the record in this case and
forward it directly to the Prothonotary of the Court of Common Pleas of Cumberland
County, upon receipt from Defendant's counsel of a check made payable to the
Prothonotary of Cumberland County in the amount necessary to pay the filing fee for the
transfer of this action to that court.
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SANDRA H, LONG, ) IN THB COUIT OF COHKON
Plaintiff ) PLBAS OF PBRIlY
) COUNTY, PENN8YLVANIA
vs. )
) CIVIL ACTION - LAW
)
8TBPHBN It. IYDBR, ) NO, 95-65S
Defendant ) IN CU8TODY
JOINT IIOTION AND STIPULATION POI TIlANSPBIl OF CASB TO
C100lBRLAHD COUNTY
AND NOW come the above-named parties, by their attorneys, Robert Lieberman for the
Plaintiff, and Samuel L. Andes for the Defendant, who stipulate on behalf of their
clients that the proper venue for this case is Cumberland County, and jointly move the
Court to transfer this case to Cumberland County by executing the proposed order which
is attached to this motion,
WHBRBPOlB, the parties, by their counsel, jointly move this Court to transfer this
case to the Court of Common Pleas of Cumberland County, Pennsylvania,
31 D~ ,{
Date
~~
Robert Liebermall~,
Attorney fQr Pliintiff
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Sail I L. Andes ',,~
Attorney f~r D~endant
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November 7, 1995
1484-1
.-~-_._-
Office of the Prothonotary
PERRY COUNTY COURTHOUSE
P.O. Box 325
New Bloomfield, PA 17068-0325
K;-bttl ~~.f/
m 91ttl~
In rei Long v. Ryder
No. 95-658
To whom it may concern I
Enclosed for filing are an original and two copies of a
Stipulation For Transfer and proposed Order of Court in
connection with the above matter.
Once the document has been signed by the Court, please be
kind enough to return two certified copies in the enclosed
stamped, self-addressed envelope. Thereafter, I assume you will
send the file to the Prothonotary in Cumberland County. Please
send me a copy of your transmittal letter.
Thank you very much.
Very truly y
~(?
ROBERT B. LIEBERMAN
RBL/dmg
CCI Sandra M. Long
Enclosures
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8ANDRA M. LONG, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF PERRY COUNTY,
) PENNSYLVANIA
)
vs ) CIVIl, ACTION - LAW
)
8TEPHEN K. RYDER, ) NO. 95-658
Defendant ) IN CUSTODY
PRELIMINARY OBJECTION
AND NOW comes the above-named Defendant, Stephen K. Ryder, by
his attorney, Samuel L. Andes, and makes the fOllowing Preliminary
Objection, in the form of a Petition Challenging Venue, to
Plaintiff's Complaint.
1. Plaintiff's Complaint identifie~th~Pla~tiff as residing
in York County. ~7:::;
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2. Plaintiff's Complaint states that, ~r flVe years prior to
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the date of Plaintiff's filing, the two;mino~children resided with
--'. N #,
the Defendant in Camp Hill, cumberland~~ou~~, p~nnSYIVania.
3. Although Defendant now resides in Perry County, he has
only resided there with the children since June of 1995.
4. The last county in which the children resided for six
continuous months or more was Cumberland County, Pennsylvania.
5. Venue in this matter is properly in Cumberland County.
WHEREFORE, Defendant moves this Court to dismiss Plaintiff's
',_".,...-..,_..;;iJ'il'. .J.l.H JfIUll~,i~~-i))~d'
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Complaint or, in the alternative, to transfer the Complaint and
this proceeding to Cumberland County, where venue properly lies.
r~~(~~
Sam 1 L. Andes
Attorney for Defendant
I.D. U 7225
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01. BAIIT a.LO,..
SAMUEL L. ANDES
ATTORNBY AT LAW
DaD HOIITIC TWBLFTII RTHBIlT
P. O. uox 108
LBMOYNB, l'BNNHYLVANIA 1704:1
TIU'HO,..
(flf) fGI-Sa,
OAX
Infl fGI-I4:la
:1:1 August 1995
Office of the Prothonotary
Perry County Court House
New Bloomfield, PA 17068
RE: Sondra M. Long vs Stephen K. Ryder
No. 95-658
Ladies/Gentlemen:
Enclosed you will find Preliminory Objections I wish to file
on behalf of the Defendant, Stephen K. Ryder, in the above custody
action.
lag
Sincerely,
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Robert B. Lieberman, Esquire
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Hobert B. J,iebcn1\ln, l::.o;quirc.
P.O. Box 1)81
Ik1rrisburg, P^' 17108-01)81
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IAllDRA H. LOIIG, I IH UI COURT or COJOlOH PLBAS
Plaintiff I PIRAY COUHTY, PIHHIYLVAHIA
I
I CIVIL ACTIOH - LAM
v. I
I HO. 95-658
ITIPBIH K. RYDIR, I
Defendant I IH CUITODY
AFPIDAVIT OP SIRVICI
COHMOInflALTB OP PIHHIYLVAHIA I
I II.
COUHTY OP PIRAY I
Personally appeared before me, a Notary Public, in and for said
Commonwealth and County, ROBERT B. LIEBERMAN, ESQUIRE, who, being duly
sworn according to law, deposes and says:
1. That on July 24, 1995, a Complaint for Custody, was filed on
behalf of the Plaintiff and against Defendant in the above case.
2. That on August 2, 1995, I forwarded, by certified mail,
return receipt requested, restricted delive~, a,~er~fied copy of the
.... \:II 3:
Complaint for Custody, to the Defendant, S~eaEN K. ~ER, 212 Basin Hill
::oz ,.,.
:-00 ffi rT'I
Road, Duncannon, Perry County, Pennsylvaniaj~~s ~id~ced by the sender's
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receipt attached hereto.
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of the Complaint
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That the aforesaid certified copy
Custody, sent to the Defendant, STEPHEN K. RYDER, was delivered on August
5, 1995, as evidenced by the return receipt card signed by the Defendant
and attached hereto.
...
.
4. That to the best of my information and belief, the signature
above Pert 5 of the return receipt card is, in fact, the signature of
Defendant, STBPHBN K. RYDBR.
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ROBBRT B. LIBBBRMAN, Esquire
Attorney for Plaintiff
SWORN TO AND SUBSCRIBBD
I$.'* day
before me this
of Q. t..J..,
c;J~~~ ~l~~
, 1995.
NOTARIAL SEAL
CHERYL L SMITH. Notary Public
Hamsbutg. Dauphin Counry
tJ" ('u:nmission Erclres Acrd 6. 1998
My Commission Expiresl
p'~3S5 80S ~3b
~ Receipt for
Certified Mall
.. No Insurance Coverage P,ovld
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DOMESnC RETURN RECEIPT
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1',0.110.981
IIlrrbhul'Jlo l'tnMJI,"nla 17108-0981
(7171236-1485
August 15, 1995
FIle No.
1484-1
William H. Templeton, Prothonotary
PERRY COUNTY COURTHOUSE
P.O. Box 325
New Bloomfield, PA 17068-0325
In rea Long v. Ryder
No. 95-658
Dear Mr. Templeton I
Enclosed please find an original and one copy of an
Affidavit of Service in connection with the above captioned case.
Please file the original and return a time ,stamped copy to
my office in the enclosed stamped, self-addressed envelope.
Thank you very much.
Very truly yours,
~p .
ROBERT B. LIEBERMAN
RBL/dmg
Enclosures
CCI Sandra H. Long
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SUDKA K. LOHO, I XH THI COURT or COIOIOH PLIAS
I PBRRY COURTY, PBHHSYLVUXA
Plaintiff I
I CXVXL ACTXOH - LAW
v. I HO. ?5"-~d
I
ST.PHIR K. RYDIR, I
Defendant I XH CUSTODY
ORDBR or COURT
You, STEPHEN K. RYDER, have been sued in court to obtain
partial custody, shared custody, custody or visitation of the
children, KELLY N. RYDER and ALICIA J. RYDER.
You are ordered to appear in person at Conference Room
1/ \ , Perry County Courthouse, on ~~\\~~,('_"'~' )~ , 1995,
at ...::J,'.?{\ I\-.M., for a conference.
If you fail to appear as provided by this order an order for
custody, partial custody, or visitation may be entered against
you.
YOU SHOULD TAKE THXS PAPER TO YOUR LAWYER AT OHCB.
XF YOU DO HOT RAVE A LAWYER OR CAHHOT AFFORD ORB,
00 TO OR TELEPHOHE THE OFFXCE SBT FORTH BBLOK
TO FXND OUT WBRE YOU CAR OET LEOAL HELP
Pennsylvania Lawyers Referral Service
Pennsylvania Bar Association
P.O. Box 186
Harrisburg, PA 17108
1-800-692-7375
QB Central Pennsylvania Legal
Services
213A North Front street
Harrisburg, PA 17101
1-800-932-0356
DATED I
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8A11J)RA M. LOIIO, , III THB COURT OF COMMOII PLBAS
I PBRRY COUNTY, PBNII8YLVABIA
Plaintiff ,
I CIVIL ACTIOII - LAK
v. I 110. f/5- ~51'
,
8TBPHBII K. RYDBR, ,
Defendant I III CU8TODY
COMPLAINT FOR CUSTODY
AND NOW, comes the Plaintiff, SANDRA M. LONG, by and through
her attorney, ROBERT B. LIEBERMAN, ESQUIRE and respectfully
represents as follows:
1. The Plaintiff is SANDRA M. LONG, an adult
individual, residing at 265 Cartref Road, Etters, York County,
Pennsylvania.
2. The Defendant is STEPHEN K. RYDER, an adult
individual, residing at 212 Basin Hill Road, Duncannon, Perry
County, Pennsylvania.
3.
The Plaintiff is seeking custody
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212 Basin Hi~!jtoacl> -'
Duncannon, PJ\2=< 176'20 0
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212 Basin Hir.t~oad' ~
Duncannon, PA ~ 11if}0 ~
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Kelly N. Ryder
Alicia J. Ryder
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~he children were born of the marriaqe between Plaintiff And
Defendant.
~he children are presently in the custody of Defendant,
S~EPHBN K. RYDER, who resides At 212 Basin Hill Road, Duncannon,
Perry County, Pennsylvania 17020.
Durinq the past five years the children have lived with
Defendant, STEPHEN K. RYDER and his parents, NANCY RYDER and
HAROLD RYDER at 129 N. 24th Street, Camp Hill, Cumberland County,
Pennsylvania.
~he mother of the children is Plaintiff, SANDRA M. LONG,
currently residinq at 265 Cartref Road, Etters, York County,
Pennsylvania.
The father of the children is Defendant, STEPHEN K. RYDER,
currently residing at 212 Basin Hill Road, Duncannon, Perry
County, Pennsylvania.
4. The relationship of Plaintiff, SANDRA M. LONG, to
the children is that of mother.
5. The relationship of Defendant, STEPHEN K. RYDBR, to
the children is that of father.
6. The Plaintiff has not participated as a party, or
witness, or in another capacity, in other litigation concerning
the custody of the children in this or another court.
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Plaintiff has no information of a custody proceeding
concerning the custody of the children pending in a court of this
Commonwealth or in any other jurisdiction.
Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the children or claims to
have custody or visitation rights with respect to the children.
7. The best interest a and permanent welfare of the
children will be served by granting the relief requested because
the Plaintiff can provide a stable and wholesome home environment
for the children.
8. Each parent whose parental rights of the children
have not been terminated and the person who has physical custody
of the children have been named as parties to this action.
WHBREFORE, Plaintiff requests this Honorable Court to enter
an Order granting her legal and primary physical custody of the
minor children subject to Defendant's rights of partial custody.
Respectfully submitted,
DATED: '7-lg~ 95
By~g.
ROBERT B. LIEBERMAN, ESQUIRE
300 North Second street
Penthouse Suite
P.O. Box 981
Harrisburg, PA 17108-0981
(717) 236-1485
Attorney for Plaintiff
4
.
VERIFICATION
I verify that the statements made in the foregoing Complaint
for Custody are true and correct based upon my personal
knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S.
54904, relating to unsworn falsification to authorities.
DATEDI1-J! ~ 1S-
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SANDRA M. LONG, \
Plaintiff
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ROBERT B. LIEBERMAN
AlTORNEY AT LAW
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P,O, Bo. 981
IIarrbbul1lo Prnnlylvanla 17108.0981
4.J: 0,
(717) 1l6-148$
F1lr No.
July 21, 1995
1484-1
William M. Templeton, Prothonotary
PERRY COUNTY COURTHOUSE
P.O. Box 325
New Bloomfield, PA 17068-0325
In re: Lona v. Rvder
Dear Mr. Templeton:
Enclosed please find an original and two copies of a
Complaint For Custody along with an Order of Court to be filed in
the above captioned matter. Please have the Order of Court
completed by the Judge and return two certified copies to my
office in the enclosed stamped, self-addressed envelope. I have
enclosed a check in the amount of $30.50 for filing fees.
Thank you very much for your cooperation in this matter.
Very truly yo
~8.
ROBERT B. LIEBERMAN
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SANDRA M. LOOG,
plaintiff
IN THE COURT OF WlMON PLEAS OF
CUMBERLAND CClUNTY, PENNSYLVANIA
vs.
NO. 95-6748
CIVIL TERM
STEPHEN K. RYDER,
Defendant
CIVIL ACTION - LAW
CUSTODY
aIDIlR OF CXXJRT
AND NQf, this j /J.. day Of,:JR,Lur.u.a"4-
upon consideration of the attached custody concil~tion summaJY
is ordered and directed as follows:
1. A Hearing is scheduled in Court Room No.2, of the
rland County Court House on the q,u.: day of
,1996, at l,'.\(c:, ~.m. at which time testimony in
be taken. At ~Hearlng, the Mother, Sandra M. Long,
deemed to be the moving party and shall proceed initially with
testimony. COunsel for the parties shall file with the Court and opposing
counsel a memorandum setting forth their position on custody and also
setting forth a list of witnesses who will testify at the Hearing, along
with the anticipated testimony of each witness. This memorandum shall be
filed at least 15 days prior to the Hearing date.
, 1996,
Report, it
2. In the event either party retains an expert for purposes of further
evaluation of the custody situation, the other party shall cooperate with
the expert for purposes of a session of evaluation. Information pertaining
to any expert who is retained or any supplemental report must be provided to
opposing counsel at least 15 days prior to the Hearing date. An expert will
not be pemitted to testify at the Hearing unless a written report is
provided to opposing counsel within the foregoing time frame. The parties
may stipulate to the admission of a prOfessional's written report into the
record in lieu of that prOfessional's testimony.
3. Pending further Order of this Court, the Mother, Sandra M. Long,
and the Father, Stephen K. Ryder, shall have shared legal custody of Kelly
N. Ryder and Alicia J. Ryder, both born November 19, 1983. The Father shall
have primary physical custody of the Children.
4. Pending further Order of this Court, the Mother shall have partial
custody of the Children on alternating weekends, beginning February 2, 1996,
from 3:45 p.m. (after school) on Friday until Sunday at 7:00 p.m. The
Mother shall call the Father's residence between 5:30 p.m. and 6:00 p.m. on
the alternating Friday evenings to confirm that she has picked up the
Children fran school. The Mother shall transport the Children to their
paternal grandparents' home in Camp Hill for exchange of custody on the
alternating Sunday evenings.
5. The parties shall share custody of the Children on holidays as
follows:
. .
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A. Easter - The Mother shllll have custody of the Children on
Easter Sunday from 1100 p.m. until 7:00 p.m. The Mother shall
trsnaport the Children to snd from the paternal grandparents'
home for purposes of exchange of custody.
B. Alternating holidays - The parties shsll have custody of the
Children on an alternating basis on the following holidays:
New Yeara Day, Memorial Day, July 4th, Labor Day and
Thanksgiving Day. The alternating schedule shall begin with
the Mother having custody of the Children in 1996 on Memorial
Day and Labor Day and the Father having custody on July 4th and
Thanksgiving Day. The party who does not have custody on
Thanksgiving Day shall have custody of the Children on the
Friday following Thanksgiving.
C. Mother's Day/Fathllr's Day - The Mother shall have custody of
the Children on Mother's Day every year from 10:00 a.m. until
7100 p.m., if she does not otherwise have custody of the
Children on that weekend, and the Father shall have custody of
the Children on Father's Day every year from 10:00 a.m. until
7100 p.m., if he does not otherwise have custody of the
Children on that weekend.
6. When holidays, not previously identified in this Order, fall on a
Monday following the Mother's weekend custody, the Mother shall retain
custody of the Children through Monday evening at 7:00 p.m.
7. The parties may modify the temporary custody schedule set forth in
this Order by mutual agreement. In the absence of mu~l,agreement, the
provisions of this Order shall control. " //
J.
eel Robert E. Lieberman, Esquire
Samuel L. Andes, Esquire
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SANDRA M. LONG,
Plaintiff
IN THE COURT OF WlMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs.
NO. 95-6748
CIVIL TERM
.
.
STEPHEN K. Rl'DER,
Defendant
aJSlal! <XfiCILIATlOO SlHIARY RBl'CRl'
IN AaDmANCB WI'l'II cnmBRLl\ND <XllIiTl( RIlLE OJ! CIVIL Pl1Oo.... IRE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The relevant information pertaining to the Children who are the
subjects of this litigation is as follows:
NAME
CURRENTLY IN CUSTODY OF
BIRl'HDATE
Kelly N. Ryder
Alicia J. Ryder
November 19, 1983
November 19, 1983
Defendant/Father
Defendant/Father
2. A Conciliation Conference was held on January 25, 1996, with the
following individuals in attendance: The Mother, Sandra M. Long, with her
counael, Robert B. Lieberman, Esquire, and the Father, Stephen K. Ryder,
with his counsel, Samuel Andes, Esquire.
3. The parties to this action were never married and the year of their
separation is disputed. In any event, the Children have resided primarily
with the Father since at least 1988. Until approximately March, 1995, the
Father and ~he Children resided with the paternal grandparents in Camp Hill.
The Father is now married and currently resides with his wife, his wife's
two children ages 9 and 12, a 6 month old child of his current marriage and
the parties' two Children who are the subjects of this litigation. The
Father and his family currently reside in a five bedroom house in Duncannon.
The Mother resides in Etters, York County, in a two bedroom house with her
boyfriend. The Mother filed this petition for primary physical custody.
4. The Mother's position on custody is as follows: The Mother stated
that she believed the Children were in a positive home environment while
residing in the paternal grandparents residence (until approximately June
1995) . ACCOrding to the Mother, the Children have complained to her that
there is a very tense atmosphere in the Father's current household with the
Father and his wife drinking too much and "beating on each other" in front
of the Children. The Mother believes the Children have been involved in
these household fights and reports that they now appear "stressed out" when
they come to her home for periods of custody. The Mother stated that at
least one of the Children has expressed a strong preference to reside with
the Mother. The Mother believes that it would be in the Children's best
interest to reside primarily with her. Finally, the Mother expressed
concern that the Father had not been cooperating in making arrangements for
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her to see the Children and that the Mother has provided all transportation
between Etters and Duncannon to exchange custody.
5. The Father's position on custody is as follows: The Father stated
that the Children have resided with him since 1985 and during the last ten
(10) years, he has been their primary caretaker. One of the Children is
severely handicapped and has special medical needs, for which the Father has
provided the necessary care. The Father believes the Mother is upset
because he has married and established another family. The Father denied
that there has been "beating", physical fighting or any other problems
adversely affecting the Children in the Father's household. The Father
believes that it continues to be in the Children's best interest to reside
primarily with him.
6. The parties were not able to agree on the issue of primary custody
and, therefor, a Hearing will be necessary in this matter. The parties were
able to agree to a temporary custody schedule pending Hearing, which is
reflected in the attached proposed Order.
7. It is anticipated that
approximately one-half day.
InA\.Un... 019 (99(,
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Hearing in this matter will take
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Dawn S. Sunday (J
CUstody Coneiliator
Date
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SANDRA M. LONG,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
STEPHEN K. RYDER,
DEFENDANT
95-6748 CIVIL TERM
ORDER OF COURT
AND NOW, thIs 7th day of February, 1996, the hearing scheduled for May 6,
1996, IS CANCELLED and rescheduled for Thursday, May 9,1996, at 6:45 a.m., In
Courtroom Number 2.
Robert Uebennan, Esquire
For PlaIntIff
Samuel L. Andes, EsquIre
For Defendant
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SANDRA M. LONG,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
STEPHEN K. RYDER,
DEFENDANT
.
.
: 95-6748 CIVIL TERM
ORDER OF COURT
AND NOW, this 1st day of May, 1996, the hearing scheduled for May 9, 1996,
IS CONnNUED. Either party may seek a further hearing date If the case is not
resolved.
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"By the Court,
Robert Ueberman, Esquire
For Plaintiff
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Samuel L. Andes, Esquire
For Defendant
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SAMUEL L. ANDES
ATTORNEY AT LAW
fta5 HORTII TWBLPTII 8TRBBT
P. O. OOX IOU
LBMOYNB, PENNSYLVANIA 17043
T.L.PIIOH.
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30 April 1996
PAX
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The Honorable Edgar B. Bayley
Court of Common Pleas of Cumberland County
Cumberland County Court House
Carlisle, PA 17013
RE: Sandra M. Long vs. Stephen K. Ryder
No. 95-6748
Dear Judge Bayley:
You have a hearing scheduled in the above custody action for 8:45 a.m. on
Thursday, 9 May 1996. The parties have reached agreement for a change in eustody for
the summer which makes that hearing unnecesslU)' and I write to request that you
continue it. If the parties are not able to resolve the remaining questions in the custody
matter by the end of July, however, we will need another hearing some time in early
August. Accordingly, the parties have agreed to requestjoindy that you postpone the
hearing scheduled for 9 May 1996 and schedule it for some time at your convenience
during the first two weeks of August.
The counsel for the parties are now preparing a stipulation which we will present
to you for the entry of an order as soon as the parties have approved and signed it. In the
meantime, we request that you reschedule the hearing and advise us of the time and date.
Thank you for your cooperation.
Sincerely,
8 -'~~
Samuel L. Andes
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cc: Robert B. Liebennan, Esquire
Stephen K. Ryder
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SANDRA M. LONG, ) IN THE COURT OF COMMON
PlaintilT ) PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
vs )
) CIVIL ACTION - LAW
STEPHEN K. RYDER, )
Defendant ) NO, 95-6748 CIVIL TERM
)
STIPULATION AND ORDER OF COURT
AND NOW come the above parties and their counsel, and stipulate and agree to the entry
of an order in this matter as follows:
1. The PlaintilTand Defendant will share legal custody of their minor daughters, Kelly N.
Ryder, born 19 November 1983, and Alicia J, Ryder, born the same date.
2, The DefendantlFather will continue to have primary physical custody from the date of
this order until the Friday following the end of the daughters' current school year in June of 1996,
During that time, the PlaintiffIMother will continue to have temporary or partial custody as she
has enjoyed it up to this time.
3, Commencing on the Friday following the end of the daughters' current school term,
and continuing until further order of this Court or written agreement of the parties, the Mother
shall have primary physical custody of the two daughters and the Father shall have temporary or
partial custody of them on alternating weekends from Friday afternoon until Sunday evening, on
alternating holidays, as the parties may agree. and for other vacation periods as the parties may
agree, The parties anticipate they will be able to agree upon a more precise schedule of partial
custody and, if they cannot, either of them is free 10 petition the court to set a formal schedule.
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4, The parties contemplate that they will be able to reach agreement on the issue of the
daughters' physical custody for the school year commencing in September of 1996 by the end of
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July,
in Court Room No.2 of the Cumberland County Court 110
o'clock
encmg at
m,on
day of
. 1996, at which time the Court will
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S, The parties jointly request the Court to enter this Stipulation as a formal Order of
Court in this maller,
IN WITNESS WHEREOF, the above parties and their counsel have set their hands this
~
.8 day of v:~ 11 .1996
WITNESS:
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Robert B, Lieberman, Esquire
Attorney for~, \h
~ndes. Esquire
Attorney for Defendant
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Sandra M, Long -
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AN NOW, this '29._dayof
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. 1996, the above Stipulation is
BY THE
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hereby approved and entered as our Order in this maller,
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F1LED-DFFiCF.
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