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HomeMy WebLinkAbout97-06982 ~ ,~ ~ I' c \,. ,~ , . ~') cj ~ ct- ,""" r.:. 0- ,~ ,I jl J,'I !,f , " " " " I.' 'I \ i } . f f ,,/' ,,'/ .L " " ,I , , , ;' ,I I " I j ,; , KELLIJO K. WERT Plaintill' . IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 97-'-1 J.LCivil Term ROBERTO RaMO Delendant : CIVIL ACTION LAW -- IN CUSTODY COMPLAINT FOR PRIMARY CUSTODY AND VISITATION AND NOW, this 18th day of December, 1997, comes Plaintiff, KELLlJO K. WERT, by and through her attorneys, Martson, Deardorff, Williams & Otto, and files the following Complaint for Primary Custody and Visitation and in support thereof avers as follows: I. The PlaintilT is KELLlJO K. WERT, an adult individual residing at 105 A West North Street, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is ROBERTO RaMO, an adult individual residing at 614 North Hanover Street, Apartment 2, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintilf seeks primary custody and visitation of the following child: lillInl: Plesent Residence 105 A West North Street Carlisle, PA 17013 .Ail: I 1/2 Roberto Romo. Jr. Date of Birth: April 5, 1996 The child was born out of wedlock. The child is presently, and always has been, in the physical and legal custody of Plaintiff. In addition to the child's present address, during the past five years, the child has resided with Plaintiff at the following addresses: 105 A West North Street, Carlisle, PA The mother of the child is the Plaintiff, who resides at 105 A West North Street, Carlisle, PA. The father of the child is Defendant. who resides at 614 North Hanover Street, Carlisle, PA. 4. The relationship of PlaintilT to the child is that of mother. The PlaintilT currently resides with the child. 5. The relationship of the Defendant to the child i3 that of the father. The Defendant currently lives alone. 6. PlaintilThas not participated as a party or witness, or in any other capacity. in other litigation concerning the custody of the child in this or another court. The Plaintiff ha, no information of a custody proceeding concerning the custody of the child in this or any other court. The PlaintilT 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 permanen\ welfare of the child will be served best by granting the relief requested because: a) The PlaintilThas had shared physical and legal custody of the child si'lce the child's birth; b) The PlaintilT provides the child with a home with adequate moral. emotional and physical slmoundings as required to meet the child's needs; c) The PlaintilTis. and has always been. willing to accept custody of the child~ and d) The Plaintift' continues to exercise parental duties and responsibilities and enjoys the love and alTection of the child. e) The Defendant has not had any contact with the child for a number of months. 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. There are no other persons who are known to have or claim a right to custody or visitation of the child. ~\ ~ r") I " ~ , ~ I, I ) '. I ~ ,II 'I:) , , ,1 , I ~ " , :'-) ",.J 1,.1 . f :.1 ( ~, , I, I LEGAL SERVICES, INC. 8 Irvine Row Curll5le, Penn5ylvanla 17013 (717) 243.9400 Fux (717) 243-8026 We5t Shore (717) 766-8475 y,an..11n F"lII UM Cbambcnburllo 'cnl>>)t~IIIi111~1 (117).2.64..5354, 4'A5.W~lnllonS.lllcI Ckllylbuta. PCIII\I)i~uU. IUU (7171'j4.7fllJ December 10, 1997 Mi~hael Hanft, Esquire Martson, Deardorff, williams & otto 10 East High street Carlisle, PA 17013 Dear Mr. Hanft: We greatly appreciate your willingness to represent Kelly Jo Wert. If you have any questions concerning these cases, or if we may be of assistance, please do not hesitate to call us. For example, our office has a wide range of resource materials, a variety of case pleadings, such as sample in-!2rma ~auDeris forms, and staff available to help you. Although we are glad to assist you in any way possible, the final responsibility for this case must rest with you. We are confident that you will give this case the same high quality of service that you give to cases taken for remuneration. If this client has other legal problems, either now or at a later date, which are not related to the matter we are referring to YOIl on a lU:Q l2.QD.Q basis, refer the client back to Legal services, Inc. so that we can determine if the client is eligible for continued representation and roferral without oharge. We requl~st that you complete and return to us, at the completion of these cases, the enclosed Attorney Final Case Disposition and Evaluation forms. When you do so, your name will be sent in to the Pennsylvania Bar Association and after you have completed two ~ R2nQ cases, you will receive a discount coupon for PBl seminars, video tapes or audio tapes. Thank you again for your generosity and help in making the R[Q QQnQ system a succesS. sincerely, , " LEGAL SERVICES, INC. b w-- ~JILUJ ttL Dru Hewitt private Bar coordinator Enclosure SERVlNG AOAMS. CUMBERLANO. FRANKl.IN AND FUL1'ON COVNTDIS . (~FEB 2 0 1998 - KELLIJO K. WERT, : IN THE COURT OF COMMON PLEAS OF Plaint.iff :CUMBERLAND COUNTY, PENNSYLVANIA . . V :CIVIL ACTION - LAW . . ROBERTO ROMO, :NO: 97-6982 CIVIL TERM Defendant :IN CUSTODY COURT ORDER AND NOW, this "2-1. - day of February, 1998, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Kellijo K. Wert, and the Father, Roberto Romo, shall enjoy shared legal custody of the minor child, Roberto Romo, Jr., born April 5, 1996. 2. The Mother shall enjoy primary physical custody of the minor child. 3. The Father shall enjoy periods of temporary physical custody of the minor child at such times as agreed to by the parties. 4. In the event the Father is dissatisfied with the amount of temporary custody provided to him, Father may petition the Court to have the case again scheduled for a conference with the Custody Conciliator. BY THE COURT, --,-,. /~J /1 J. cc: Michael J. Hanft, Esquire Roberto Romo 614 North Hanover Street Apartment 2 Carlisle, PA 17013 ,.; m~.U .lJ).'IlqJ'. - L 'V>l.i..~ ..A . i! . .- v IIN THE COURT OF COMMON PLEAS OF ICUMBERLAND COUNTY, PENNSYLVANIA I ICIVIL ACTION - LAW KELLIJO K. WERT, Plaintiff . . ROBER~'O ROMO, Defendant INOI 97-6982 CIVIL TERM I IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVI.L RULE OF PROCEDURE 1915 .3-8(b), the undersigned Custody Conciliator submits the following reportl 1. The pertinent information pertaining to the child who is the subject of this litigation is as followsl Robert Romo, Jr. born April 5, 1996. 2. A Conciliation Conference was held on February 12, 1998, with the following individuals in attendancel The Mother, Kellijo K. Wert, with her attorney, Michael J. Hanft, Esquire. The Father, Robert Rmno, did not appear at the Conference. Father had not picked up the certified mail sent to him concerning service of the notice of the Conference. Howevel.", Attorney Hanft re.lated to the Conciliator that notice of the Court Order scheduling the Conference was sent to Mr. Romo by regular mail. Ms. Wert related to the Conciliator that she has had some conversation with Mr. Romo and that he acknowledged receiving notice and was aware of the Conciliation Conference. Ms. Wert further indicated that Mr. Romo is exercising periods of temporary custody with the minor child and that she simply desires a Court Order to confirm hel' status as primary custodian. 3. The Conciliator recon~ends an Order in tte form as attachea. ;))10!C;f? OATS