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HomeMy WebLinkAbout03-0595SUSAN M. KEPPLEY, Plaintiff V. TEDDy j. KEPPLEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .. : CIVIL ACTION _ LAW CUSTODY/VISITATION NO. 03-..~c~ CIVIL TERM COMPLAINT~FOR CUSTODY 1. Thc Plaintiff is Susan M. Kcppley, residing at 338 East Garfield Street, Shippcnsburg, Pennsylvania 17257. 17013. 2. The Defendant is Teddy J. Keppley, residing at 147 South East Street, Carlisle, Pennsylvania 3. Plaintiff seeks custody of the following children: Theodore j. Keppley RESIDENCE 147 South East Street, Carlisle, PA 17013 The child was born out of wedlock. _DO 09/03/87 15 yrs. 4 months. The child is presently in the custody of Defendant/Father. During his life, the child has resided with the following persons and at the following addresses: ADDRESS Susan M. Keppley & DA__TE~SS Teddy J. Keppley 147 South East Street, Carlisle Aug. 1996 - present 7. The mother of the child is Susan M. Keppley, currently residing at, 338 East Garfield Street, Shippensburg, Pennsylvania 17257. She is married. 8. The father of the child is Teddy J. Keppley, currently residing at 147 South East Street, Carlisle, Pennsylvania 17013. He is mart/ed. 9. The relationship of the Plaintiff to the child is that of mother. The Plaintiff currently resides with the following persons: Tummy Runyan, friend/roommate. 10. The relationship of the Defendant to the children is that of Father. The Defendant currently resides with the following persons: Not known. 11. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 12. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 13. 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. 14. The best interest and Permanent welfare of the children will be served by granting the relief requested for the following reasons: A. A Court Order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unmet exceptions regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion B. A Court Ordered determination of custody is required to avoid continuing conflict between the parties regarding parental responsibility for custody and support. 15. Each parent whose parental fights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiffrequests the Court to grant shared custody of the child to the Plaintiff and Defendant, and part/al custody awarded to the Plaintiffpending the hear/ng on this petition. By:~ Attorney for Plaintiff 50 East High Street Carlisle, PA 17013 Telephone: (717) 258-8558 Supreme Court ID No. 71786 VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of Pa. C.S. § 4904, relating to unsworn falsification to authorities. usan M. Keppley / SUSAN M. KEPPLEY PLAINTIFF TEDDY J. KEPPLEY DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-595 CIVIL ACTION LAW ~CUSTODY ORDER OF COURT AND NOW, Thursday, February 20, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jaequeline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, March 12, 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 hearing. FOR THE COURT. By: /s/ Jacqueline M. Verney, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Di.sabilites 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 ATFORNEY OR CANNOT AFFORD ONE, GO 'FO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 I'IAR 1 3 2003 SUSAN M. KEPPLEY, Plaintiff TEDDY J. KEPPLEY, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2003-595 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this {~ day of I~£q ,-, L~- ,2003, upon consideration of the attached (~ustody Concihat~oh'Repo~t, it is ordered and directed as follows: 1. The Mother, Susan M. Keppley, and the Father, Teddy J. Keppley shall have shared legal custody of Theodore J. Keppley, bom September 3, 1987. 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. 2. Father shall have primary physical custody of the Child. 3. Mother shall have periods of partial physical custody as follows: A. Beginning March 16, 2003, alternating Sundays from 12:00 noon to 4:00 p.m. B. Such other times as the parties agree. 4. Christmas shall be divided into two Blocks. Block A shall run from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall run from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Father shall always have Block A. Mother shall always have Block B. 5. Thanksgiving shall be shared by the parties. Mother shall have physical custody of the Child from 9:00 a.m. to 3:00 p.m. and Father shall have physical custody of the Child from 3:00 p.m. to 9:00 p.m. 6. Mother shall be entitled to one week with the Child in the summer, provided it does not conflict with the Child's work schedule or activities. Mother shall provide 30 days prior notice of the exercise of this provision. 7. Transportation shall be shared such that Father will deliver the Child to Mother at the start of her custodial period and Mother shall return the Child to Father at the conclusion of her custodial periods. 8. Neither party shall consume alcoholic beverages to the extent of intoxication while the child is in their custody. 9. 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. BY THE COURT, cc: Paul Bradford Orr, Esquire, Counsel for Mo~er" Michael A. Scherer, Esquire, Counsel for Father ~ SUSAN M. KEPPLEY, Plaintiff V. TEDDY J. KEPPLEY, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 2003-595 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY 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 conceming the Child who is the subject of this litigation is as follows: NAME Theodore J. Keppley (T.J.) DATE OF BIRTH September 3, 1987 CURRENTLY IN CUSTODY OF Father 2. A Conciliation Conference was held in this matter on March 12, 2003, with the following individuals in attendance: The Mother, Susan M. Keppley, with her counsel, Paul Bradford Orr, Esquire and Father, Teddy J. Keppley, with his counsel, Michael A. Scherer. Esquire. 3. The parties agreed to the entry of an Order in the form as attached. Date ~ q ~ine M. Vemey, Esquire Custody Conciliator