HomeMy WebLinkAbout00-05398
BETH A. GONDER, for herself,
BETH A. GONDER, guardian for
JENNIFER L. L1TILE, a minor,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUN1Y, PENNSYLVANIA
NATHAN E. STRUNK,
Defendant
: CIVIL AGION-lI\W
IN CUSTODY
NO. 00-5398
CIVIL TERM
CONSENT AND APPROVAL FOR APPEARANCE UNDER Pa,BAR. 322
I hereby consent to the appearance of Jennifer Jones, a Certified Legal Intern under the
supervision of an attorney, In the above-entitled custody proceeding before the Honorable Edward
E, Guido at 10:45 a.m, on August 14, 2000.
Date
6/ IV co
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As the supervising attorney for Jennifer Jones, certified under Pa.B,A.R. 322, I approve of her
appearance on behalf of the above-named client in the above-named proceeding.
Date ~/;'f/OO
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ROBERT E. RAINS
THOMAS M, PlI\CE
Supervising Attorneys
FAiVlILY lI\W CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
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BETH A. GONDER, for herself,
BETH A GONDER, guardian for
JENNIFER L. LITTLE, a minor,
Plaintiff /Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
'397
2000.~ CIVIL TERM
NATHAN E. STRUNK,
Defendant/Respondent
IN CUSTODY
ORDER OF COURT
AND NOW, this '1 ~ay of August
2000, upon consideration of the
attached Petition for Special Relief,
IT IS HEREBY ORDERED that a hearing regarding this Petition for Special Relief is
hereby scheduled for August ~ 2000, at I~ 7ISC;'clock L.m. in Courtroom Number ~ .
Cumberland County Courthouse, Carlisle, Pennsylvania 17013 at which time the parties along
with theirlegal counsel shall appear in person. IJ.. vi" Golloo.) 6~c.t.. S,d~ y~ )""/A1t
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BY THE COURT,
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BETH A. GONDER, for herself,
BETH A GONDER, guardian for
JENNIFER LITTLE, a minor,
Plaintiff/Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
qr
200053 CIVIL TERM
NATHAN E. STRUNK,
Defendant/Respondent
IN CUSTODY
PETITION FOR SPECIAL RELIEF
AND NOW, this 24th day of July 2000, comes the Plaintiff/Petitioner, Beth A. Gonder,
for herself, Beth A. Gonder, guardian for Jennifer L. Little, a minor, by her attorneys, Irwin,
McKnight & Hughes, and makes the following Petition for Special Relief against the
Defendant/Respondent, Nathan E. Strunk:
1.
The petitioner is Beth A. Gonder, for herself, Beth A. Gonder, guardian for Jennifer A.
Little, a minor, an adult individual who resides at 211 "C" Market Street, New Cumberland,
Pennsylvania 17070.
2.
The respondent is Nathan E. Strunk, an adult individual who resides at 33 West Main
Street, Apt. 2-R, Mechanicsburg, Cumberland County, Pennsylvania 17055.
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3.
The petitioner, Jennifer Little, is the natural parent ofKara Michelle Strunk, born
November 19, 1998, age two (2) years. Said child has resided with her since birth.
4.
The petitioner, Beth A. Gonder, is the maternal grandmother of Kala Michelle Strunk.
5.
On Sunday, July 16, 2000, at approximately 2:00 p.m., the respondent came to the
petitioner's home and requested that he be permitted to take Kala Michelle Strunk to his aunts for
a few hours for a short visit. He was to return the child by 8:00 p.m.
6.
Unfortunately, the respondent did not return the child. After a search by the petitioners,
they received a telephone call from the respondent which indicated that he would not return Kala
Michelle Strunk.
7.
The respondent has refused to permit the petitioner to take her child or to return the child
to her.
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8.
The petitioner requests the following temporary custody Order of Court regarding Nathan
E. Strunk as follows:
a. The parties have shared legal custody of Kala Michelle Strunk;
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b. The petitioner, Jennifer L. Little, will have primary custody of
Kala Michelle Strunk.
c. The respondent shall return the child to the petitioner immediately
pending a conciliation hearing with periods of temporary physical
custody to the respondent on alternate weekends and at such times
as set by the parties.
WHEREFORE, the petitioners, Beth A. Gonder and Jennifer L. Little, respectfully
request that this Honorable Court enter an Order against the respondent, Nathan E. Strunk,
requiring him to provide the relief set forth above to said petitioners.
Respectfully submitted,
By:
Date: July 24, 2000
4
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VERIFICATION
The foregoing Petition for Special Relief is based upon information which has been
gathered by counsel and us in the preparation of this action. We have read the statements made
in this document and they are true and correct to the best of our knowledge, information and
belief. We understand that false statements herein made are subject to the penalties of 18 Pa.
C.S.A. Section 4904, relating to unsworn falsification to authorities.
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J IF R L. LITTLE
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BETH A. GONDER
Dat'd"'a e?t{ , 2000
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BETH A. GONDER, for herself,
BETH A GONDER, guardian for
JENNIFER L. LITTLE, a minor,
Plaintiff/Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
'3"7
2000.,', CIVIL TERM
NATHAN E. STRUNK,
Defendant/Respondent
IN CUSTODY
ORDER OF COURT
AND NOW, this 'I ~ay of August
2000, upon consideration of the
attached Petition for Special Relief,
IT IS HEREBY ORDERED that a hearing regarding this Petition for Special Relief is
hereby scheduled for August ~ 2000, at /6.l/S(;'clock A...-.m. in Courtroom Number S- .
Cumberland County Courthouse, Carlisle, Pennsylvania 17013 at which time the parties along
with their legal counsel shall appear in person. () L V ill e. (io,.) 6A.c.I-, SIJr V,) ;"/J"tt
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BY THE COURT,
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BETH A. GONDER, for herself,
BETH A GONDER, guardian for
JENNIFER L. LITTLE, a minor,
Plaintiff/Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
2000-6'39tIVIL TERM
v.
CIVIL ACTION - LAW
NATHAN E. STRUNK.
DefendantJRespondent
IN CUSTODY
ORDER OF COURT
AND NOW, this day of .2000, upon consideration of the
attached petition, it is hereby directed that the parties and their respective counsel appear
before Esquire, the conciliator,
at . on the day of ,
2000 at . 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 this conference may provide grounds
for entry of a temporary or permanent order.
By the Court,
By:
Custody Conciliator
YOU SHOULD TAKE TIDS 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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
1-800-990-9108
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AMERICANS WITH DISABll..ITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities 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 scheduling conference or hearing.
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BETH A. GONDER, for herself,
BETH A GONDER, guardian for
JENNIFER L. LITTLE, a minor,
Plaintiff/Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000.)3 '1fCIVIL TERM
NATHAN E. STRUNK,
DefendantJRespondent
IN CUSTODY
PETITION FOR CUSTODY
AND NOW, this 24th day of July 2000, comes the Petitioners, Beth A. Gonder, for
herself, Beth A. Gonder, guardian for Jennifer L. Little, by her attorneys, Irwin, McKnight and
Hughes, and presents the following Petition for Custody.
L
The petitioner is Beth A. Gonder, for herself, Beth A. Gonder, guardian for Jennifer L.
Little, is an adult individual residing at 211 "C" Market Street, New Cmnberland, Pennsylvania
17070.
2.
The petitioner is Jennifer L. Little, a minor residing at 211 "C" Street, New Cmnberland,
Pennsylvania 17070.
3.
The respondent is Nathan E. Strunk, an adult individual residing at 33 West Main Street,
Apartment 2-R, Mechanicsburg, Pennsylvania 17055.
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4.
The parties are the natural parents of one minor child, namely, Kala Michelle Strunk, age
two (2) years, born November 10, 1998.
5.
Petitioners desires primary physical custody of the child and joint legal custody with
periods of visitation to respondent as can be mutually arranged between the parties.
6.
The best interest of the child requires that the court grant the petitioner's request as set
forth above.
WHEREFORE, petitioner respectfully seeks the entry of an Order of Court seeking
primary physical custody of the child and joint legal custody with periods of visitation to
respondent as can be mutually arranged between the parties.
Respeetfully.submitted,
IRWIN, M
By:
Ma us A. Me . t, III, Esquire
Attorney for Petitioners
Carlisle, Pennsylvania 17013
(717) 249-2353
Supreme Court L D. No. 25476
Date: July 24, 2000
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VERIFICATION
The foregoing Petition for Custody is based upon information which has been gathered
by counsel and us in the preparation of this action. We have read the statements made in this
document and they are true and correct to the best of our knowledge, information and belief. We
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
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BETH A. GOND
Date9 /J fO J {. . 2000
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BETH A. GONDER, for herself,
BETH A GONDER, guardian for
JENNIFER L. LITTLE, a minor,
Plaintiff/Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
d
2000-53 CIVIL TERM
v.
CIVIL ACTION - LAW
NATHAN E. STRUNK,
Defendant/Respondent
IN CUSTODY
ORDER OF COURT
AND NOW, this day of .2000, upon consideration of the
attached petition, it is hereby directed that the parties and their respective counsel appear
before Esquire, the conciliator,
at . on the day of ,
2000 at . 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 this conference may provide grounds
for entry of a temporary or permanent order.
By 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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
1-800-990-9108
--,'Co, ,< ,="~""",,_,, '.. 'N.~,"',"',">" _ ~
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities 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 scheduling conference or hearing.
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BETH A. GONDER, for herself,
BETH A GONDER, guardian for
JENNIFER L. LITTLE, a minor,
Plaintiff/Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000- ~?,91 CIVIL TERM
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C)
IN CUSTODY
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NATHAN E. STRUNK,
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AND NOW, this 24th day of July 2000, comes the Petitioners, Beth A. Gonder, for
herself, Beth A. Gonder, guardian for Jennifer L. Little, by her attorneys, Irwin, McKnight and
Hughes, and presents the following Petition for Custody.
1.
The petitioner is Beth A. Gonder, for herself, Beth A. Gonder, guardian for Jennifer L.
Little, is an adult individual residing at 211 "C" Market Street, New Cumberland, Pennsylvania
17070.
2.
The petitioner is Jennifer L. Little, a minor residing at 211 "C" Street, New Cumberland,
Pennsylvania 17070.
3.
The respondent is Nathan E. Strunk, an adult individual residing at 33 West Main Street,
Apartment 2-R, Mechanicsburg, Pennsylvania 17055.
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4.
The parties are the natural parents of one minor child, namely, Kala Michelle Strunk, age
two (2) years, born November 10, 1998.
5.
Petitioners desires primary physical custody of the child and joint legal custody with
periods of visitation to respondent as can be mutually arranged between the parties.
6.
The best interest of the child requires that the court grant the petitioner's request as set
forth above.
WHEREFORE, petitioner respectfully seeks the entry of an Order of Court seeking
primary physical custody of the child and joint legal custody with periods of visitation to
respondent as can be mutually arranged between the parties.
Respectfully submitted,
IRWIN,
By:
Marc s A. M . t, III, Esquire
Attorney for Petitioners
Carlisle, Pennsylvania 17013
(717) 249-2353
Supreme Court L D. No. 25476
Date: July 24, 2000
~l.-_'
VERIFICATION
The foregoing Petition for Custody is based upon information which has been gathered
by counsel and us in the preparation of this action. We have read the statements made in this
document and they are true and correct to the best of our knowledge, information and belief. We
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
9:~t:~~
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BETH A. GOND R
Date:~, 2000
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BETH A. GONDER, for herself,
BETH A GONDER, guardian for
JENNIFER L. LITTLE, a minor,
PIaintiff/Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
,,*,"
2000- '? CIVIL TERM
v.
CIVIL ACTION - LAW
NATHAN E. STRUNK,
DefendantJRespondent
IN CUSTODY
ORDER OF COURT
AND NOW, this day of .2000, upon consideration of the
attached petition, it is hereby directed that the parties and their respective counsel appear
before Esquire, the conciliator,
at . on the day of
2000 at . 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 defme 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 this conference may provide grounds
for entry of a temporary or permanent order.
By the Court,
By:
Custody Conciliator
yOU SHOULD TAKE TillS 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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
1-800-990-9108
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
11\'
2000- ~ '>) CIVIL TERM
BETH A. GONDER, for herself,
BETH A GONDER, guardian for
JENNIFER L. LITTLE, a minor,
Plaintiff/Petitioner
v.
CIVIL ACTION - LAW
NATHAN E. STRUNK,
Defendant/Respondent
IN CUSTODY
ORDER OF COURT
AND NOW, this day of .2000, upon consideration of the
attached petition, it is hereby directed that the parties and their respective counsel appear
before Esquire, the conciliator,
at . on the day of ,
2000 at . 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 this conference may provide grounds
for entry of a temporary or permanent order.
By the Court,
By:
Custody Conciliator
YOU SHOULD TAKE TillS 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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
1-800-990-9108
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BETH A. GONDER, for
herself, BETH A. GONDER,
guardian for JENNIFER L.
LITTLE, a minor,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NATHAN E. STRUNK,
Defendant
NO. 00-5398 CIVIL TERM
IN RE: CUSTODY
ORDER OF COURT
AND NOW, this 14th day of August, 2000, the
agreement as to custody executed by the parties is hereby
adopted as an order of this Court.
By
Che~
Edward E. Guido, J.
Marcus A. McKnight, III, Esquire
For the Plaintiff
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Jennifer Jones
Robert E. Rains, Esquire
For the Defendant
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BETH A GONDER, for herself,
BETH A GONDER, guardian for
JENNIFER L. LITTLE, a minor,
Plaintiff
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERlAND COUN1Y, PENNSYLVANIA
: CMLAGION-LAW
: IN CUSTODY
NATHAN E. STRUNK,
Defendant
: NO, 00-5398
CIVIL TERM
AGREEMENT ,AS TO CUSTODY
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THIS AGREEMENT, made this 1'1- day of August, 2000, between Beth A Gonder,
for herself, and Beth A Gonder, guardian for Jennifer L. Little, a minor, hereinafter mother, and
Nathan E. Strunk, hereinafter father, concerns the custody of the child: Kayla Michelle Strunk, born
November, 10, 1998.
Mother andJather desire to enter into an agreement as to the custody of the child.
Mother and father agree to the following:
1, The mother and father shall share legal custody of the child.
2. The mother and father shall share physical custody of the child.
3, The mother and father shall exchange custody of the child on Saturdays at noon.
4, Whichever parent has custody of the child on her Birthday, ThanksgMng,
Christmas, and Easter Sunday shall make the child available to the other parent for
a reasonable amount time.
5, The mother shall have custody of the child on Mother's day, and the father shall
have custody of the child on Father's day from 7 :00 a.m. until 8:00 p.m.
6. The mother and father shall be entitled to reasonable telephone access with the
child while the child is in the other's custody,
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7, The parties shall keep one another advised of their current address and telephone
number.
8. The father and the mother will notify each other of all medical care the child
receives while in that parent's care. The father and the mother will notify the other
immediately of medical emergencies which arise while the child is in that parent's
care.
9. Neither parent will do anything which may estrange the child from the other party,
or injure the opinion of the child as to the other parent or which may hamper the
free and natural development of the child's love and respect for the other parent.
10, The parties intend to be bound by the terms of this agreement.
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Nath E. Strunk
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J nifer Little .
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Robert E. Rains
Thomas M. Place
SUPERVISING ATTORNEYS
FAMILY lAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Date:
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