Loading...
HomeMy WebLinkAbout03-0015KETHA M. RANCK, Plaintiff V. PAUL R. RANCK, Defendant IN THE COURT OF COMMON PLEASE CUMBERLAND COUNTY, PENNSYLVANIA C/VIL ACTION-LAW IN CUSTODY PLAINTIFF'S COMPLAINT TO CONFIRM CUSTODY 1. Plaintiff is Ketha M. Ranck, an adult individual currently residing at 126 Beech Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Paul R. Ranck, an adult individual currently residing at 349 Fourth Avenue, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the children, Erica Rhoda Ranck, who was bom on December 27, 1992, and Paul Anthony Richard Ranck, who was bom on December 29, 1995. The children were not bom out of wedlock. Since the children's birth, the children have resided with the following persons at the following addresses for the following periods of time: the children have resided with the parties at Plaintiff's address since their birth. 4. The relationship of the Plaintiff to the child is that of mother. She is married and living separately. The Plaintiff currently resides with the following: Name Erica Rhoda Ranck Paul Anthony Richard Ranck Relationship Daughter Son 5. The relationship of the Defendant to the child is that of father. He is married and living separately. The Defendant currently resides with the following: Name Relationship Unknown 6. The parties have not participated in previous litigation concerning the custody of the child in this court or any court. The Plaintiff has no information ofa custodyproceeding concerning the child pending in any other court. 7. The best interest and permanent welfare of the child will be served by granting custody to Plaintiff because she can provide a stable and nurturing environment for her children. 8. 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 children. WHEREFORE, Plaintiffrequests 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 heating, Plaintiff requests temporary custody. MARTSON DEARDORFF WILLIAMS & OTTO By '~w/d4 ~ Thomas J. Willi~fms, Esquire I. D. No. 17512 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Date: j'~/7~/O L~_ Attorneys for Plaintiff 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 of the 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 of the 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 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. ~ k~ '~, Ketha M. Ranc KETHA M. RANCK PLAINTIFF PAUL R. RANCK DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-15 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, January 09, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, January 29, 2003 at 9:30 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 hearinl~. FOR THE COURT, By: Is~ ]acqueline M. Verney, 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. 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 KETF~AM. RANCK, Plaintiff V. PAUL R. RANCK, Defendant : IN THE CO[~T OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-15 CIVIL TERM : : CIVIL ACTION-LAW : IN CUSTODY PRAECIPE To the Prothonotary: Please enter my appearance~~above-captioned matter on behalf of the Defendant. ~~/~f~~ DATE: Attorney for Pl~iff cc: Thomas J. Williams, Esquire / FEB 1 0 2003 / KETHA M. RANCK, Plaintiff V. PAUL R. RANCK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003-15 CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this 1'2 ~5~ day of Fe ~,, ,2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Ketha M. Ranck, and the Father, Paul R. Ranck, shall have shared legal custody of Erica Rhoda Ranck, bom December 27, 1992 and Paul Anthony Richard Ranck, bom December 29, 1995. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. The Children's legal residence shall be with Mother and they shall continue to attend South Middleton Schools. 2. Mother shall have primary physical custody of the Children. 3. Beginning February 14, 2003, Father shall have periods of partial physical custody as follows: A. Alternating weekends, from Friday after work to Sunday at 1:00 p.m. B. At least two evenings per week from after work to 8:00 p.m. C. Two nonconsecutive weeks during the summer. D. Memorial Day and Labor Day. In the event that these holidays coincide with Father's alternating weekend, his weekend period shall extend to Sunday overnight. 4. The Thanksgiving holiday shall be alternated as agreed by the parties. 5. The Christmas holiday shall be divided into two Blocks. Block A shall be from 12:00 noon on Christmas Eve to Christmas Day at 12:00 noon. Block B shall be from Christmas Day at 12:00 noon to December 26, at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. However, as long as the younger Child still believes in Santa Claus, Father agrees to permit Mother to have Block A. 6. Mother shall always be entitled to physical custody of the Children the week of July 4. 7. Transportation shall be shared as agreed by the parties. 8. Neither party shall remove the Children from the State of Pennsylvania without the prior consent of the other party. The custodial parent shall provide a telephone number and address where the Children will be. 9. This Order is entered pursuant to an agreeme, nt 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. BY THE COURT, cc: Thomas J. Williams, Esquire - Counsel for Mother Elliot A. Strokoff, Esquire - Counsel for Father KETHA M. RANCK, Plaintiff Ve PAUL R. RANCK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 2003-15 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 Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH Erica Rhoda Ranck December 27, 1992 Paul Anthony Richard Ranek December 29, 1995 CURRENTLY IN CUSTODY OF Mother Mother 2. A Conciliation Conference was held in this matter on February 10, 2003. Mother, Ketha M. Ranck, was present with counsel, Thomas J. Williams, Esquire, and Father, Paul R. Ranck, was present with counsel, Elliot A. Strokoff, Esquire. 3. The parties agreed to an Order in the form attac, hed. Date .,Yacqdkline M. Vemey, Esquire Custody Conciliator