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HomeMy WebLinkAbout02-5052 REGINA BURNS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO.2002- YoS.2- CIVIL ACTION - LAW KEITH NEILL, Defendant IN CUSTODY PLAINTIFF'S COMPLAINT TO CONFIRM CUSTODY 1, Plaintiff is Regina Burns, an adult individual currently residing at 216 West Coover Street, Mechanicsburg, Cumberland County, Pennsylvania, 2, Defendant is Keith Neill, an adult individual currently residing at 5022 East Trindle Road, AI, Mechanicsburg, Cumberland County, Pennsylvania. 3, Plaintiff seeks custody of the child, Keegan Eli Neill, who was born on June 22, 2002. The child was born out of wedlock. Since the child's birth, the child has resided with the following persons at the following addresses for the following periods of time: From his birth, Keegan resided with both parties until the parties separated. From that time on, Keegan has resided with Plaintiff. 4. The relationship of the Plaintiff to the child is that of mother. She is single and living separately. The Plaintiff currently resides with the following: Name Relationship Keegan Eli Neill Son 5, The relationship ofthe Defendant to the child is that off ather. He is single and living separately. The Defendant currently resides with the following: Name Relationship Unknown at this time. 6. The parties have not participated in previous litigation concerning the custody ofthe child in this court or any court. 7. The Plaintiffhas no information of a custody proceeding concerning the child pending in any other court. 8. The best interest and permanent welfare of the child will be served by granting custody to Plaintiff because: She is best able to provide a stable and nurturing environment for her son, 9. Plaintiff does not know of any person not a party to these proceedings who claims to have custody or visitation rights with respect to the child, WHEREFORE, Plaintiff requests your Honorable Court to set a time and place for a hearing at which Plaintiff requests the Court to grant her the Custody Order. Pending said hearing, Plaintiff requests temporary custody. MARTS ON DEARDORFF WILLIAMS & OTTO By /"'l. r ~ Thomas J. Will' Ten East High reet Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: October 16, 2002 VERIFICATION The foregoing Complaint to Confirm Custody is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language ofthe document is that of counsel and not my own, I have read the Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content ofthe document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa, C.S, Section 4904 rdating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. ~~;/Y'('^-.~ A A/V\~ egl a Burns '*' ~ 0 '----" C ;'<i ~ t J . ',~ ~ ~-J ,-; '- '- '" '" .. <::> "" ~ '" '->> 0 C. l-J t' ~ (" :....) ....) ~ , <J I ~-3 :,..:> ~J ", (,,) -< ,~ECE'VEL OCi 11 2802 p.!'-r"'~:!:- REGINA BURNS PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 02-5052 CIVIL ACTION LAW KEITH NEILL DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, October 23, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective cOurlsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, November 12, 2002 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Jacqueline M. Vern~y. Esq. y Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland COurlty Bar Association 2 Liberty Avenue Carlisle, Permsylvania 17013 Telephone (717) 249-3166 ~ ~'l' ~p ~ ~ 4-k7 .-iJ; ~ /~~ ~-.o~ ~ fp ~ ~-w' 4/oV I-"~ f 1, ,}7e ~I ~r7. Je>. Of C"ogt?. r7/ 11 \, 't;jN~'I1I{<:;, .r\i./ w7t,."'; ~~.vi \/;\!~7-1 -, ""'n'/:'ic.;",')", ..." . . '::r'',j/ tiJ U!::i :,(' !I . '-' i'i,~1 8?J.JD' .... ""?r )J:t:l; :"', (, Ul .;.'...."., NOV 1 3 2002 ~ REGINA BURNS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2002-5052 CIVIL TERM KEITH NEILL, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this...1!1- day of.\' ." 1 , 2002, upon consideration of the attached Custody co~t is ordered and directed as follows: 1. The Mother, Regina Bums, and the Father, Keith Neill, shall have shared legal custody of Keegan Eli Neill, born June 22, 2002. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Mother shall have primary physical custody of the Child. 2. 3. A. B. C. D. 4. 5. Father shall have periods of partial physical custody as follows: Beginning November 13,2002 and continuing every Wednesday thereafter from 6:00 p.m. to 8:00 p.m. Beginning November 23 and 24, 2002 and alternating weekends thereafter, two hours on Saturday and Sunday from 3:00 p.m. to 5:00 p.m. Thanksgiving Day from 5:00 p.m. to 9:00 p.m. Christmas Day from 5:00 p.m. to 9:00 p.m. Transportation shall be shared as agreed by the parties. Father shall not call Mother's home after 10:00 p.m. 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. The parties shall return to another Conciliation Conference on January 22, 2003 at 10:30 a.m. J. cc: Thomas J. Williams, Esquire, Counsel for Mother Nora F. Blair, Esquire, Counsel for Father M . ~ II-/S'- 0,,2.... I~ 4-. '. V7:\f\.,z:tn"l .... .".{ / \_'f'..:;,;t, I -'~"';i \IV-rd .~J 'I 1,-./, "" r7:r:;':~...' --',' ,'t,~ ,.....,,,", ~-~<'/llv i. I :nl ....ij' -'I J Ii 0/1 ~"'{l , .J.,J REGINA BURNS, Plaintiff : IN THE COURT OJr COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2002-5052 CIVIL TERM KEITH NEILL, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Concilia1tor 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 CUSTODY OF Keegan Eli Neill June 22, 2002 Mother 2. A Conciliation Conference was held in this matter on November 12, 2002, with the following individuals in attendance: The Mother, Regina Bums, with her counsel, Thomas J. Williams, Esquire and the Father, Keith Neill, with his counsel, Nora F. Blair, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. 11-/5-0;)- Date J g-</k~ ~""'Y. E"Iuire. Custody Conciliator REGINA BURNS, Plaintiff V. KEITH NEILL, Defendant ,JAN 7 6 2DD3 t : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 2002-5052 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 16th day of January, 2003, the Conciliator being notified that the parties are satisfied with the current Order of Court, the Conciliator hereby relinquishes juriSdiction in this matter. FOR THE COURT, ody Conciliator 0 0 ..~J C c...~ 'Tl .'-.. -;:%',:r: ...7~ , r, ,;,C Z,:l, N .'", ..' he (f:!.F 0-' .:',ft-) ~?~~I ? 'Zc-. :> \ -".- ;-".1...-' $2- C? _~~I;'n ;,,-\ -7 .,..... ~ -- ~ ,0 ...:.