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HomeMy WebLinkAbout01-5805TANYA KELLER, RANDY KELLER, Plaimiff, Defendant, 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: O/- CIVIL ACTION - LAW ORDER AND NOW, this X'" day of oor-~o- ,2001, upon Petition of Tanya Keller, natural mother of Allison Keller, bom September 13, 1994, custody of Allison is hereby temporarily awarded to the mother pending~-te~,,~e of the ce,'_"t- Father shall have reasonable periods of partial custody, pending further Order of Court. BY THE COURT: V!NV,~.'IASNN-~d TANYA KELLER, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. :NO: Defendant. RANDY KELLER, : CIVIL ACTION - LAW EMERGENCY PETITION FOR CONFIRMATION OF CUSTODY AND NOW, comes your Petitioner, Tanya Keller, by and through her attorneys, Mancke, Wagner, Hershey & Tully, and files the following Emergency Petition for Confirmation of Custody: 1. Your Petitioner, Tanya Keller, is an adult individual currently residing at 1227 Trindle Road, Carlisle, Cumberland County, Pennsylvania. 2. The Respondent, Randy Keller, is an adult individual currently residing at 99 Wolfes Bridge Road, Carlisle, Cumberland County, Pennsylvania. 3. Petitioner and Respondent were married June 15, 1994. 4. The parties separated approximately the third week of September of 2001. 5. The parties are the natural parents of Allison Keller, born September 13, 1994. 6. The child was bom during wedlock; and has resided with the parties up until separation at 1227 Trindle Road, Carlisle, Cumberland County, Pennsylvania, home of the mother. 7. Since separation, separation in the form of the father leaving the marital home, the child has remained with the Petitioner, her natural mother. 8. On October 2, 2001, Petitioner and Respondent engaged in an argument that led to an altercation. 9. The Petitioner herein anticipates that the Respondent is going to attempt to file a PFA, and seek temporary immediate custody of Allison, despite the fact that Allison has been residing with the Petitioner herein since the time of separation. 10. Petitioner believes and therefore avers that it is in the best interest of Allison to confirm primary custody of Allison in the Petitioner, pending outcome of any further proceedings in custody and/or the anticipated protection from abuse proceeding, which Petitioner believes Respondent may be filing. 11. Petitioner believes that Respondent should have periods of partial custody pending outcome and/or resolution of the above matters. WHEREFORE, Petitioner prays this Court to grant immediate temporary primary custody of Allison unto Petitioner pending outcome of proceedings in this custody matter as well as the anticipated PFA matter. Respectfully submitted, squir"~ff233 North Front Street e Harrisburg, PA 17110 (717) 234-7051 Attorneys for Petitioner Date: /d//~//~ j VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. TANYA KELLER, RANDY KELLER, Plaintiff, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAw : IN CUSTODY ORDER AND NOW, this day of ,2001, 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 , , at o'clock __.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. 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 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. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 TANYA KELLER, RANDY KELLER, Plaintiff, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :No: Vt-- : CIVIL ACTION - LAW COMPLAINT TO CONFIRM CUSTODY AND NOW, comes your Plaintiff, Tanya Keller, by and through her attorneys, Mancke, Wagner, Hershey & Tully, and files the follow/ng Complaint to Confirm Custody: 1. The Plaintiff, Tanya Keller, is an adult individual currently residing at 1227 Trindle Road, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant, Randy Keller, is an adult individual currently residing at 99 Wolfes Bridge Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant were married June 15, 1994. 4. The parties separated approximately the third week of September of 2001. 5. The parties are the natural parents of Allison Keller, bom September 13, 1994. The Plaintiff is the natural mother of Allison, and the Defendant is the natural father of Allison. 6. The child was bom during wedlock; and has resided with the parties up until separation at 1227 Trindle Road, Carlisle, Cumberland County, Pennsylvania, home of the mother. 7. Since separation, separation in the form of the father leaving the marital home, the child has remained with the Plaintiff, her natural mother. 8. Plaintiff knows of no other party having an interest in the custody or partial custody of Allison. 9. Plaintiff believes and therefore avers that it is in the best interest of Allison to confirm primary custody of Allison in the Plaintiff. 10. Plaintiff believes that Defendant should have periods of partial custody. WHEREFORE, Plaintiff prays this Court to grant primary custody of Allison unto Plaintiff subject to periods of partial custody in Defendant. Respectfully submitted, Mancke, Wagner, Hershey & Tully P. Ri~ Esquire 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Petitioner Date: -3- I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. TANYA KELLER : PLAINTIFF V. RANDY KELLER DEFENDANT : 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-5805 CIVIL ACTION LAW 1N CUSTODY F T AND NOW, Friday, October 12, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greev~, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on Wednesday, November 14, 2001 at 12:30 PM 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/ Melissa P. Greevy. 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 heahng. YOU SHOULD TAKE TI-IlS 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 DISC 0 ? ~O01v~) TANYA KELLER, Plaintiff : : vs. : NO. 01-5805 : : CIVIL ACTION - LAW Defendant : CUSTODY RANDY KELLER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORDER TO RELINQUISH JURISDICTIO~ AND NOW, this 10th day of November, 2001, the Conciliator, having been notified by counsel for the Petitioner that the parties have reconciled, hereby relinquishes jurisdiction of the above-referenced custody matter. FOR THE COURT, Melis~a Peel Gr vy Custody Conciliator