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Home My WebLink About02-5540ABRICANS WITH DISABILITIFIS ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations 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. TYLER R. KINNEY, Plaintiff V. CINDY KINNEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION - AT LAW l FOR CUSTODY CO[eLAINT FOR CUSTODY The Plaintiff, Tyler R. Kinney, by and through his attorney, The Law Offices of Patrick F. Lauer, Jr., files this Complaint for Custody against the Defendant, Cindy Kinney, and in support thereof, avers the following: 1. The Plaintiff is Tyler R. Kinney, an adult individual and the natural Father, who currently resides at 6 Buttonwood Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Cindy Kinney, an adult individual and the natural Mother, who currently resides at 2391 East River Road, Moraine, Ohio 45439. 3. The Plaintiff seeks custody of the following child: Name Present Residence AAe Garth M. Kinney 6 Buttonwood Drive 9 years Carlisle, PA 17013 (April 22, 1993) The child was not born out of wedlock. The child is presently in the custody of his father, Tyler R. Kinney, who resides at 6 Buttonwood Drive, Carlisle, Pennsylvania. During the past five years, the child resided with the following persons and at the following addresses: Name Tyler Kinney, Sherri Shadle, Jonluke shadle Cindi Kinney, Stephen Kinney, Sarah Kinney Tyler Kinney, Cindi Kinney, Address Dates 6 Buttonwood Drive 9/2002 - Carlisle, PA 17013 present 8557 White Cedar Drive 4/2002 - Apartment 309 9/2002 Miamisburg, OH 45342 48 Chapman Street Birth - Prequise Isle, ME 04768 4/2002 The Father of the child is Tyler R. Kinney, currently residing at 6 Buttonwood Drive, Carlisle, Pennsylvania 17013. He is single. The Mother of the child is Cindy Kinney, currently residing at 2391 E. River Road, Moraine, Ohio 45439. She is single. 4. The relationship of the plaintiff to the child is that of natural Father. The plaintiff currently resides with the following persons: Name Sherri Shadle Jonluke Shadle Relationship fiancee fiancee's son 5. The relationship of the defendant to the child is that of natural Mother. The defendant currently resides with the following persons: Name Relationship Unknown 6. Plaintiff has participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Custody action in the State of Maine docketed at PRE-FM-02-061. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interests and permanent welfare of the child will be served by granting the relief requested because: (a) Plaintiff is the natural Father of the child. (b) The child currently resides with the plaintiff. (c) Defendant requested, and Plaintiff accepted, that the child should reside with plaintiff. (d) The child's school grades were poor while residing with the Defendant, the child's grades have improved since residing with Plaintiff. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. No other persons are known to have a right to or have claimed to have a right to custody or visitation of the child. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an Order granting to him primary physical custody of his child. Respectfully submitted, MaCrliMafkley, Esquire Law 0 f ces of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 PA Supreme Ct. ID No. 84745 Phone: (717) 763-1800 Date: //- ! -._2 OOZ TYLER R. KINNEY, Plaintiff V. CINDY KINNEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA . No. CIVIL ACTION - AT LAW FOR CUSTODY VERIFICATION I, Tyler R. Kinney, state that I am the Plaintiff in the above-captioned case and that the facts set forth in the above Complaint for Custody are true and correct to the best of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S. § 4940. Ty er R. Kinney Date: J0-/D-04 ('?AJ 4 //U. S'O - ?c? ply e-* sit 2.li- /3700 TYLER R. KINNEY IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. CINDY KINNEY DEFENDANT • 02-5540 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Friday, November 22, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Wednesday, December 18, 2002 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: Is/ Melissa P. Gr=,_&g. U 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 County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 U jjj? aqoTpo?bTARY 02 WV 22 PM 32- 25 CU??'`NTY u•a?-a-? Gam- ?. ?6 TYLER R. KINNEY, Plaintiff V. CINDY KINNEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 02-5540 CIVIL ACTION - AT LAW FOR CUSTODY CONSENT ORDER Z AND NOW, this day of 200PA-upon consideration of the attached Stipulation of the parties in the above-captioned matter, consisting of two pages and bearing the written consent of the parties, AND upon direction of this court. that the parties need not be present before the court in order to incorporate their Stipulation into a consent order, IT IS ORDERED that said Stipulation is incorporated herein by reference as if set forth in full and approved as a Consent Order pursuant to Pennsylvania Rule of Civil Procedure Rule 1915.7. BY THE COUR j J. Distribution: -Marlin Markley, Esq., 2108 Market St:., Camp Hill, PA 17011 a? R s ti `-` L JAN 21 2203 TYLER R. KINNEY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 02-5540 CIVIL TERM V. CIVIL ACTION - LAW CINDY KINNEY, IN CUSTODY Defendant ORDER TO RELINQUISH JURISDICTION AND NOW, this 16`h day of January, 2003, the counsel for the Plaintiff and the Defendant personally having requested a thirty (30) day continuance on December 17, 2002, and the Conciliator having received no further request for the Custody Conciliation Conference to reconvene, hereby relinquishes jurisdiction of the above captioned matter. FOViss l Greevy, Esq uire Custody Conciliator :200190 n c w m tz ? _? .. -Fi