HomeMy WebLinkAbout98-03537
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TINA KELLER
IN THE COURT OF COMMON PLEAS
CUMBERLANDCOUNTY, PENNSYLVANIA
Plaintiff
v.
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JOHN R. KELLER
CIVIL ACTION - LAW
IN CUSTODY
Defendant
COMPLAINT FOR CUSTODY
AND NOW, Plaintiff Tina Keller, by and through her attorney, Barbara J.
Patton, Esquire, files a Complaint For Custody against Defendant, John R. Keller, and
in support thE-reof, avers the following:
1. Plaintiff is Tina Keller, Mother, who currently resides at 41
Devonshire Square, Mechanicsburg, Cumberland County, Pennsylvania.
2. Defendant is John R. Keller, Father, who currently resides at 410
South Market Street, Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff seeks custody of the following children:
NAME
Present Address.
AGE
Karissa Keller
41 Devonshire Square
Mechanicsburg, PA
7
Sarah Keller
41 Devonshire Square
Mechanicsburg, PA
1 9 months
4. The child, Sarah Keller, was not born out of wedlock. The child,
Karissa Keller, was adopted by Defendant.
5. The children, Karissa Keller and Sarah Keller, are presently in the
custody of Mother, Tina Keller, who currently resides at 41 Devonshire Square,
Mechanicsburg, Cumberland County, Pennsylvania.
,
:
6. During the past five (5) years, the children, Karissa Keller and Sarah
Keller, resided with the following persons at the following addresses:
Persons
Address
~
Tina Keller
Karissa Keller
Sarah Keller
Earl Lenington
Rebecca Lenington
41 Devonshire Square
Mechanicsburg, PA
June, 1998 to present
Tina Keller
John R. Keller
Karissa Keller
Sarah Keller
40 C West Green Street
Mechanicsburg, PA
September, 1995, to
June, 1998
Tina Keller
John R. Keller
Karissa Keller
4 Marshall Drive
Camp Hill, PA'
October, 1993 to
September, 1995
7. The Mother of the children is Tina Keller, who currently resides at
41 Devonshire Square, Mechanicsburg, Cumberland County, Pennsylvania.
8. The Father of the children is John R. Keller, who currently resides
at 410 South Market Street, Mechanicsburg, Cumberland County, Pennsylvania.
9. The parties are married.
10. The relationship of Plaintiff to the children is that of Mother.
Plaintiff currently resides with the following person:
Person
Relationship
Karissa Keller
Sarah Keller
Earl Lenington
Rebecca Lenington
Daughter
Daughter
Uncle
Aunt
.
11. The relationship of Defendant to the children is that of Father.
Defendant currently resides with the following persons:
Person
None
Relationship
12. Plaintiff and Defendant have not participated as a party or witness,
or in another capacity, in other litigation concerning the custody of the children in this
or another court.
13. Plaintiff and Defendant have no information of a custody
proceeding concerning the children pending in a court of this Commonwealth.
14. Plaintiff and Defendant do not know of a person not a party to the
proceedings who has physical custody of the children or claims to have custody or
visitation rights with respect to the children.
15. The best interests and permanent welfare of the children, Karissa
Keller and Sarah Keller, will be served by granting the relief requested, io.1M 5!J.i5!,
because the Plaintiff Mother has been the children's primary caretaker since birth.
16. Each parent whose parental rights to the children have not been
terminated and the persons who have physical custody of the children have been
named as parties to this action. All other persons, named below, who are known to
have or claim a right to custody or visitation of the children will be given notice of the
pendency of this action and the right to intervene.
Name
Address
Basis of Claim
NONE
VERIFICATION
I, Tina Keller, hereby swear and affirm that the facts contained in the
foregoing Complaint for Custody are true and correct and are made subject to the
penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
Date:
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TINA KELLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 98-3537
CIVIL TERM
JOHN R. KELLER,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NGl, this 5th day of August, 1998, the Conciliator, being
advised by Plaintiff's counsel that the parties have reconciled and there
is no need for a Custody Conciliation Conference, hereby relinquishes
jurisdiction in this case. The Custody Conciliation Conference scheduled
for August 6, 1998 is canceled.
FOR THE COURT,
({2~'7~:ljl-~_ Of~T
Dawn S. Sunday, Esquire 0
Custody Conciliator
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLANDCOUNTY,PENNSYL VANIA
TINA KELLER
v.
NO. 98-3537
JOHN R. KELLER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
PRAECIPE TO WITHDRAW
Please withdraw the Custody Complaint filed in this matter on June 24, 1998,
on behalf of Plaintiff, Tina Keller, in the above captioned matter without prejudice.
I /
Date: R sf cr V
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Barbara J. Patto6>Esquire
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