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Home My WebLink About00-04780 "~ ""1,,'1 . .. r.] Ii RACHELLE L. KING IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF V. WILLIAM E. KING, JR. 00-4780 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 12TH day of JULY ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. . the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on the 6TH day ofEPTEMBE ,2000, at 11:00 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. FOR THE COURT, By: Isl Dawn S. Sunday. Esq. tp 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 rei I "~ ~.~~ " ," ","!r_~"'l!'.l~~_~_ /-/J .t?C} 7/3~ 7-1.3 .,tJ,{} , ~~ :->' ,"-"~, "-.".' "," -. -<--, ~-~, .-p~' Ou JUL \ 3 r-,. r')".l /. .)'-..1 ,(,;.-\ .\ "\1'{ ,. ,-. [" \ ~ '\'>:. 1 c_.r_',_'j ,,~\1\ I ....I'-~U CUtJi~~NNsYC)!N~\^ M.~~ ;2.~~ 7l~~~~: ~/U~ ~~AJ~ ../ ,~, ''__0"""" ~~r, _._.."......,. . _.~"'V#l~!l'.&I!!/!',\'l:@I~~"~~~'flll~l~ ~ ,~~._i'Ii1~,~IWIl,~!i"'_"-- _,~ "" ,"--,,~~- ", " . . .:it, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RACHELLE L. KING, Plaintiff v. NO.OO - /..f1fC> ~~ WILLIAM E. KING, JR., Defendant IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the Conciliator, at on the day of , 2000, at ___.m., for a Pre-Hearing Custody Conference. At such Conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court and to enter into a temporary Order. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent Order. BY THE COURT: Custody Conciliator 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, PA 17013 (717L 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact the office set forth above. 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. ~, '~ ~"- "'- ,~ ' """". IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RACHELLE L. KING, Plaintiff v. NO. 00 - '-I7PO Wd~ WILLIAM E. KING, JR., Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, RACHELLE L. KING, by and through her attorney, Maryann Murphy, Esquire, of Legal Services, Inc., and respectfully files this Complaint for Custody, and in support thereof avers as follows: 1. The Plaintiff is RACHELLE L. KING whose current address is 915 willcliff Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is WILLIAM E. KING, JR. whose current address is 62505 East Brightwood Loop. Brightwood, Clackamas County, Oregon. 3. The Plaintiff primary physical and legal custody of the following child: CHELSEA KING, born March 30, 1993 4. The child was born out of wedlock. 4'~ .' -',- "'^ " U"-"', "''',:" 5. Plaintiff currently resides with the minor child and the child's half-sister_ 6. Defendant currently resides with his parents. 7. During the lifetime of the child, she has resided at the following addresses with the following persons: Time Address birth-1996 39551 S.E. Dubarko Ct. Sandy, Oregon 1996-1997 Gresham, Oregon 1997-1998 Vancouver, Washington 1998 (6 months) 39551 S.E. Dubarko Ct. Sandy, Oregon 1998-11/99 Phoenix, Arizona 11/99-present 915 willcliff Drive Mechanicsburg, PA With Whom Plaintiff/Defendant Plaintiff's mother and her husband, and Plaintiff's brother Plaintiff/Defendant Plaintiff/Defendant Plaintiff/Plaintiffs mother and her husband, and Plaintiff's brother Plaintiff Plaintiff 8. The father of the children is WILLIAM E. KING, JR. He is married to Plaintiff. 9. The mother of the children is RACHELLE L. KING. She is married to Defendant. 10. Plaintiff has not participated as a party or witness or in any other capacity, in other litigation concerning the custody of the child in this or any other Court, except as set forth above. 11. The Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth or in any other State. 12_ The 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_ 13. Each parent whose parental rights to the child have not been terminated, and the persons who have physical custody of the child, have been named as parties to this action. There are no other persons known to have or claim a right to custody or visitation of the child and therefore, no further notice of the pendency of this action and the right to intervene shall be given, other than to the parties named herein. 14. The best interest and permanent welfare of the minor child will be served by granting Plaintiff primary physical and legal custody of CHELSEA. WHEREFORE, Plaintiff requests this Honorable Court to ".' --=,"'",-'~ - ,'" grant her primary physical and legal custody of the minor child. Respectfully submitted, Maryan Murphy, Legal Services, 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 LD. # 61900 Attorney for Plaintiff - , ~~, VERIFICATION I, RACHELLE L. KING, verify that the statements made in the foregoing Custody 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. " l ~ , ,'. ~ "- "..,~ . "," '"","",. :1 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RACHELLE L. KING, Plaintiff v. NO. () OJ - ~~, WILLIAM L. KING, JR., Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Maryann Murphy, Esquire, do hereby certify that on the day of , 2000 I served a true and correct copy of the foregoing Complaint in Custody on the Defendant, WILLIAM L. KING, JR. at the address set forth below, by placing a copy of same in the united States Mail, postage prepaid, certified/restricted delivery. william L. King, Jr_ I 62505 East Brightwood Loop Brighrlwood, Oregon 97011 1 Respectfully submitted, Maryann urphy, Legal Services, 8 Irvine Row Carlisle, PA 17013 (717) 54D-8600 LD_ # 61900 ~ ,~, -~i~l.mi~l!1~~Pi~~"- "'l~fIf";""'''''' .,~ . lMIIioUIU'U hI!! H'~ ..... (") C <" ,,--" nli+~ ~'?~ ~is <:"-" ).-;:.:,.-.. 2j:-.;- ~',--' -C 2: ~ :1;6f/!Ei'ilnnJ!i1I~j"~ , '"'. "C~! C":') C'~ '-- l) ->; , <..i'i :r.~ ::r:: W Ul -t ~ .. (.., '" , "" ~ i~ ~ ~ " ",~-,' ~-~,'. ~'" , ,~, ' ' , ~ ; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RACHELLE L. KING, Plaintiff : NO_ (J)O-.t.!~o ~~ v. : IN CUSTODY WILLIAM E. KING, JR_, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, RACHELLE L. KING, Plaintiff, to proceed in forma pauperis. I, Maryann Murphy, Esquire, of Legal Services, Inc., attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. Marya Murphy, EsqUl e Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 J.D. # 61900 Attorney for Plaintiff I~ ~'- ";,-,,,', j..ii IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RACHELLE L. KING, Plaintiff : NO. 0 () - ~ 1ivwL. r:, i:l .;, v_ : IN CUSTODY :1: i: WILLIAM E. KING, JR., Defendant ,',,' AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am RACHELLE L. KING, the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: RACHELLE L. KING Address: 915 WillcliffDrive. Mechanicsburg. PA 17055 (b) Social Security Number: 542-13-9746 If you are presently employed, state N/A Employer: N/A Address: N/A Salary or wages per month: NI A Type of work: NI A ; . "'~. - -.' ~ ~ If you are presently unemployed, state Date of last employment: 9/99 Salary or wages per month: $1.400.00 Type of work: Recentionist (c) Other income within the past twelve months Business or profession: -0- Other self-employment: -0- Interest: -0- Dividends: -0- Pension and annuities: -0- Social Security benefits: -0- Support payments: -0- Disability payments: -0- Unemployment compensation and supplemental benefits: -0- Workman's compensation: -0- Public Assistance: -0- Other: $400.00 from her mother (d) Other contributions to household support (Wife)(Husband) Name: N/A If your (husband) (wife) is employed, state Employer: N/A . " " ~- .-~ I-j " i ~ Salary or wages per month: N/A Type of work: N/A Contributions from children: -0- (e) Property owned Cash: $2.00 Checking Account: -0- Savings Account: -0- Certificates of Deposit: -0- Real Estate (including home): -0- Motor vehicle: Make Nissan Pathfinder Year 1991 Cost $16.000.00 Amount owed $13.900.00 Stocks; bonds: -0- Other: -0- (t) Debts and obligations Mortgage: -0- Rent: -0- Loans: $320.00 per month Monthly Expenses: unable to pay any bills/ unemployment due to birth ofbabv (g) Persons dependent upon you for support (Wife) (Husband) Name: N/A .'. u"i . Children, if any: Name: CHELSEA Age: 7 Name: HANNAH Age: 2 months j i , 5. I verify that the statements made in this affidavit are true and correct. I understand that Ii I': Ii II i'! :1 -:i 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date: ~Jy3-DD f?add6Y:u</ RACHELLE L. ~O ~jj4 iIjIj~lllIilJilj;!liJil~lil!~W~ Moi8l.ilMf, ,'.N'-'" ~- C) CJ r:~ C C'..:i <?' -0 IT! ~- ::J (llrr! f= Z':u zr- I ~g~ Lr; kCi ~... ~C) ....','~ ~. ~C; \.) C ~~i<q Z W ~~ --"4 :J.J -< en -< ~",~"" - ~lTf1. ~b~.' ti: ~ RACHELLE L. KING, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : ~'s. . NO. 00-4780 CIVIL TERM . . . . CIVIL ACTION - LAW . WILLIAM E. KING, JR., Defendant : IN CUSTODY ORDER OF COURT ANn ~, this 6th day of September, 2000, the Conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction in this case. The Custody Conciliation Conference scheduled for September 6, 2000 is canceled. FOR THE COURT, cO~-_,. A.L-.A~T Dawn S. Sunday, Esquire f Custody Conciliator l,,,,,,,,",," I~~IM ~, ~ ~, ~." . ~:F;) 1,-,' t-.,,,,, .il-< ,J"",,, ;?: CUi\'it.'_j~.:.. ~CUNTY FENNSYLV/\i\]IA ~,'_'" ~~ ,~"'~~Q-'W!il\1ffi~!l'~!I!~;jl ~- )1'. ~,,?10P ':8 " - l'.o1. - "~ d''''''- ~ l....lo:l . I IN THE COURT OF COMMON PLE'1S OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RACHELLE L. KING, Plaintiff No. 00-4780 Civil Term v. WILLIAM E. KING, JR., Defendant IN CUSTODY ORDER OF COURT AND NOW, this 1",,<; It, day of >(' \~ ~ cJ r ,2000, upon consideration of the attached Stipulation for Entry ofa Custody Order, IT IS HEREBY ORDERED AND DECREED that custody of the minor child CHELSEA KING, born March 30,1993, is awarded as follows: L MOTHER shall have primary physical and legal custody of the minor child. 2. FATHER shall have partial physical custody of the minor child by mutual agreement of the parties. It is acknowledged by the parents that a regular partial custody schedule for FATHER is difficult because he resides in Oregon_ MOTHER shall work with FATHER in planning time for him to spend with the minor child. 3_ MOTHER shall inform FATHER of important events in the minor child's life so that he can be involved in the child's development 4. Each parent shall give support to the other in their role as parent and shall take into account the concerns of the other for the physical and emotional well-being of the child. 5. It shall be the express duty of each parent to uphold the other parent as one whom the child should respect and love. ~, , ,pqr- ~ ,~"U61= ....." ,'~, i~iUI)-'rJ~FICE (,-_',,'!:' -,"~. -V" "" r ~, , , · ,'}c):-!OTARY 00 SEP 2 7 i~ril j(); s 3 CUM8EHU~\iD COUNlY PENNSYLVANIA ~ ~_.-IlI'l!~Ill~,lI,\lli~1!~~iR-'''!i;;m!''''~J$~'-~:l<''Yl1mf!f.!iT'~l'~!iI~!/!!!''ffl;:;m:;~'miI1-q, .-" ~ -~~ ~ ... ";"'''*oi;', b '~,. 'S \; 6. Each parent shall provide the other with a current telephone number and address for contact There shall be reasonable telephone access between the child and both parents.. 7. This Order shall replace and supercede any and all prior Custody Orders, and shall remain in full force and effect until further Order of Court. BY THE COURT: .~ f' ~OO \! 0\ ~~ .~~ , > ~J -, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RACHELLE L. KING, Plaintiff No. 00-4780 Civil Term v. WILLIAM E. KING, JR., Defendant IN CUSTODY STIPULATION FOR ENTRY OF CUSTODY ORDER RACHELLE L. KING (hereinafter referred to as "MOTHER"), and WILLIAME. KING, JR. (hereinafter referred to as "FATHER"), desiring to amicably settle and resolve all outstanding issues concerning custody with respect to CHELSEA KING, born March 30, 1993, the minor child involved in this action, hereby stipulate and agree to the entry of an Order of Court awarding custody of CHELSEA as follows: 1. The parents agree that MOTHER shall have primary physical and legal custody of the minor child. 2. The parents agree that FATHER shall have partial physical custody of the minor child by mutual agreement ofthe parties. It is acknowledged by the parents that a regular partial custody schedule for FATHER is difficult because he resides in Oregon. MOTHER agrees to work with FATHER in planning time for him to spend with the minor child. 3 _ MOTHER agrees to inform FATHER ofimportant events in the minor child's life so that he can be involved in the child's development. 4. Each parent agrees to give support to the other in their role as parent and to take into account the concerns of the other for the physical and emotional well-being of the child. - -'. ,'" .f;\, ';0; ~:} ,.\~~ 5. It shall be the express duty of each parent to uphold the other parent as one whom the child should respect and love. 6. Each parent shall provide the other with a current telephone number and address for contact. The parents agree that there shall be reasonable telephone access between the child and both parents.. 7. The parents agree that this Agreement shall be submitted to the Court of Common Pleas of Cumberland County for approval and for entry of an Order awarding custody as set forth herein, and the parents hereby request that this Honorable Court enter such an Order. IN WITNESS WHEREOF, the parties have executed this Stipulation for Entry of a Custody Order on the date indicated below. Q-/3-60 Date ~<;Z w~~,,~L- WILLIAM E. KING, JR. I B.q -CO Date Witness (') 0 (') c:: 0 i:J ~. -off; en :';::! nlr-' m ~11:J;i z' --u z:V N Cij5;; -;)81 :,[] 0 -.;.,.~.. ,'--, i ~o V ~;j~ ~Q :J'i: c5 ~:~ ;pO .c- ~m c z 0 '>:! :< ::D UJ -< ":"'-2l!M~tt=~~=""'":;$~~~~~i!!tf~~:ftf? .~!ilii,,.,,,,",,,-",,,,,,,.~w ~-':':":.LLH - .~ ,-:~/I ~p7 7 - ,"~. 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