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Home My WebLink About00-06545 ... DEBRA 1. KECK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-6545 CIVIL TERM :SANDY A. KECK, Defendant : CIVIL ACTION--LA W : CUSTODY AMENDED CERTTFICA TE OF SERVICE I, Dirk E. Berry, Esquire, do hereby certifY that on this day the Complaint in Custody was served by first-class mail upon the following persons: Wayne Shade, Esquire 53 W. Pomfret St. Carlisle, P A 17013 Dak: 1-2, - Db ~:lg dirk E. Berry, Esquire Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 --- ~------ Hi., -"-" I ,"'"", - .-_"o'_~_" ." ~ .-~" .-"....;.....- ""',d" "L', . . "'d", " ~< I '., ,,,,,,,'''',,,,=,,,,' "'" --, ...,- "~ .. 8 c;, ';~ a ~- "" (/) ; -Of]] tV'] 'I'. !l!fn <:J 1j2J ::0 6'55.;:' N :,0"8 co ."-", i '" ".. ~,;- 5;; C::c' "0 '" :::;;: ~~~ ~j ;;;Eo :sO ~y 61'11 ~ ~ :::< to -< , , .~' < ~>:::iSro(- . DEBRA J. KECK PLAINTIFF V. SANDY A. KECK DEFENDANT IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 00-6545 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 29 day orEPTEMBE~ , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on the 2ND day o@VEMB~ 2000, at 10:30 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. FOR TIlE COURT, By: Isl Hubert X. Gilroy. Esq.tfJ 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 hearing. YOU SHOULD TAKE TIllS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 I,' ., I:.: :J ili I' i~ If.I' iJ Ii II gl.... " ~ ~ t . ...... ,_, , '.c. _~ _ ~ . "_ , "' -_ _ "Mo. "0' _ ~ ,...,,~- "-, , <"./i 00 0[',""; -;:,.. 'V, ". OQ .. -- r1'1 ,j. .... CUM8EHLi,NcJ COUNTY PENNSYLVANIA ID'd.'Q? 6vf,~ ~~ 4 ~ /tJ<2.0{) ~ ~ ~~~ 'IJ-~ /tJOiOtf ~~~il~#_ "~~~-" -...~.' .,.,,",. -'-'~ "","'~_ 4>. ~. ~_!W[~~~~_*;f!IP """""'""'" - ~~ilfmii'l-~~~W1_,~_ :'~~<'!r'f;..';m~4flW':?j<.Wf!"~\?N'if'l_~t;;;:iffiff'!" .,,, _ ,,~". li , " - ~,~"-',",_, -- ,Cc.i' _-,,:J,,_, ;,::-,-',j .,'," , . C>-d .., ~,- . DEBRA 1. KECK, Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO.,(b-GQ4S CIVIL TERM SANDY A. KECK, Defendant : CIVIL ACTION--LA W : CUSTODY ORDER OF COURT AND NOW, this day of , 2000, 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 , 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 the conference may provide grounds for entry of a temporary or permanent order. BY THE COURT: By: Custody Conciliator 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 ;md 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 LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE mE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 ~,..'""" L' '_ .~ --- "'~ "'0 "'" _," Cot'"" ,,~ "-,' , -',-'''--' ,,-,--, " - " - ,:,-" -" ~-'~'" -, ~--~ DEBRA J. KECK Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 0-0- (,6"11>" CIVIL TERM SANDY A. KECK Defendant : CIVIL ACTION -- LAW : CUSTODY COMPLAINT IN Cl JSTODY I. The Plaintiff is DEBRA J. KECK, residing at 120 Irish Gap Road, Newville, Cumberland County, Pennsylvania 17241. 2. The Defendant is SANDY A. KECK, residing at 405 High Mountain Road, Shippensburg, Cumberland County, Pennsylvania 17257. 3. Plaintiff seeks partial physical custody of the following child: NAME PRESENT RESIDENCE AGE Jeremiah S. Keck 405 High Mountain Rd. Shippensburg, P A 17257 The child was born in wedlock. Date of birth December 14,1982. 17 yrs. The child is presently in the custody of Defendant. During the past five years, the child has resided with the following persons and at the toll"wing addresses: PERSONS ADDRESS DATE birth to 9/18/99 Debra and Sandy Keck 405 High Mountain Rd. Shippensburg, P A 17257 Sandy Keck same 9/18/99 to present The mother of the child is Plaintiff. She is unmarried. Plaintiff and Defendant were divorced on April 4, 2000. The father of the child is Defendant. He is unmarried. Plaintiff and Defendant were divorced on April 4, 2000. ., '- '---;:~__.t 4. The relationship of Plaintiff to the child is that of natural mother. The Plaintiff :urrently resides with Tony Sennett, her fiancee. 5. The relationship of Defendant to the child is that of natural father. The Defendant currently resides with the child, Jeremiah S. Keck. 6. Plaintiff has not participated as a party or witness, or in any other capacity, in other htigaiton concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a wurt of this Commonwealth. However, the parties entered into a Property Settlement and Separation Agreement pursuant to their divorce action which provides as follows: ARTICLE 5: CHILDREN and 5.01: CUSTODY: The parties shall have shared legal custody of their son, Jeremiah Shane Keck, born December 14, 1982, as contemplated by 23 Pa.C.S. ~5302. Primary physical custody of said child shall be in husband subject to reasonable rights of partial physical custody of wife as the parties hereto may from time to time agree. 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. 7. The best interest and permanent welfare of the child will be served by granting the rdief requested for the following reasons: (a) Father has deliberately impeded the child's continuing relationship with his mother by refusing the reasonable requests of the mother for partial physical custody ofthe child and by withholding consent to the reasonable requests ofthe mother such that there is no agreement as contemplated in the Property Settlement and Separation Agreement; '-"L"_ <'0 ~, , ~L __ ,,_~" - i " ~ -.-, . ~. .--' ~." "i.- .,- (b) Father has utilized this tactic to virtually deny all contact between Mother and son such that Mother and son have lost all confidence that Father will ever agree to any reasonable request of Mother for partial physical custody of her son; and (c) Court directed partial physical custody for the mother is in the best interest of the child because it will allow the mother and child to continue to further their pre-existing relationship without undue interference from Father. 8. Each parent whose parental rights 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. There are no persons known to have or claim a right to custody or visitation of the child. WHEREFORE, Plaintiff requests the Court to grant partial physical custody of the child. Respectfully submitted, jQ:J5Z Dirk E. Berry, ~qmre Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013-3019 (717) 240-0296 - .------. __.'_'e;" "n;_~"_' ".,,- ._~ :- : ',._' - :-1- ~-' ~_ .0:),' 0--"'- "--, -. ,- -e" ~ , - - : - - - ";.'>- . I VERIFY THAT THE STATEMENTS MADE IN THIS COMPLAINT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S. g4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. ~ -d 1fL~1f DEBRA 1. KECK ,--,,"'-- ~- [ "I': ~i ~: . t @ (") <::> 0 c: 0 -'1 ~ (/) --1 Q 8 -Oee Pl i.-;~:D ?0 fT'ler! -0 -^-.. Z:u N :.Qt:!3 ~ ZS:: m -~~ I ~ ~ ~~:: i ~CJ " ! -~ "'l:>,~ ~. Rc') I ~ ~ z' --!:..-- fn ~ ~ )>0 c- o ~ c: ~ I -+:- 1; ~ -0 --< J:"' -< I i I I ~ b ,,- " ~ . '"" ,,~~ '""~~'I/~'- DEBRA 1. KECl(, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. CIVIL TERM MICHAEL R. SABELLA, Defendant CIVIL ACTION--LA W CUSTODY CERTIFICATE OF SERVICE I, Dirk E. Berry, Esquire, do hereby certifY that on this day the Complaint in Custody was served by first-class mail upon the following persons: Wayne Shade, Esquire 53 W. Pomfret St. Carlisle, PA 17013 Dflte: r-2..-h- OD diL~ ~ . Dirk E. Berry, Esquire Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 o <2 0 _~ en ':So- r'f1 -0 (ie, --0 '-E:.t}:, N %C;. 0" '!2.?: r:;;u ~ z.o ~9 y...... ~ --D ~ "" .' \?, .-..... '-:'-'-" .,..~ . '\'r1. ~i:. ':~iA 9\ -"- "" --- -:z. ,p ,>-', , , -'-"-; .2,. '0 ;".c'" _ ,;.",',:, :.;,' ." _',' '., ".",. ,-- , ~'.-_ . ,. ,'< '", x' .#> . . OEBRAJ.KECK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00-6545 CIVIL : CIVIL ACTION--LA W 'ANDY A. KECK, Defendant : IN CUSTODY AMENDED CERTIFICATE OF SERVICE I, Dirk E. Berry, Esquire, do hereby certify that on this day the Complaint in Custody was .'"rved by fIrst-class mail upon the following persons: Sandy A. Keck 405 High Mountain Rd. Shippensburg, P A 17257 Dctc: 10 -2~-O 0 ,/fAJ7 rnrk E. Berry, Esquire Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 - '" -iliIIM ~ , "",,.::,.:.;,,-;; ~ """,,,d,',"" ,", -. . ,,'"'c '" 0 c:; , ~':;~ ,.....; -~ . c) -'1:; r'T' C~ lTi i, -/ 4_ ;~._.) C7 r ~~ L (} r; '...-' ";:-~, <:." Z ~.._" (j );> c: ~ L, ::> :~ (hl , >' .' c.;; ,~~ - ,~ I I .... .~ ,--._, _"-,r '"",' _ ,.., ;.-. '-,' " ,_ 70' >-">cC-,,<d',.;.. ----1"; "'. DEBRA 1. KECK, Plaintiff NOV 0 6 ZOODtJlI IN 1HE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW SANDY A. KECK, Defendant NO. 00-6545 CIVIL IN CUSTODY COURT ORDER J.4\ AND NOW, this? day of November, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Sandy A. Keck, and the Mother, Debra 1. Keck, shall enjoy shared legal custody of Jeremiah S. Keck, born December 14, 1982. 2. The Father shall enjoy primary physical custody of the minor child. 3. The Mother shall enjoy periods of temporary physical custody of the minor child as follows: A. On alternating Sundays from 1 :00 p.m. until 6:00 p.m. B. On one evening every other week from 5:00 p.m. until 7:30 p.m., the particular evening to be worked out between the parties. C. At such other times as the parties may agree. 4. Father shall encourage the minor child to visit his Mother at a minimum schedule as outlined in this Order, and Father shall not discourage the minor child in any way maintaining a relationship with his Mother. 5. Mother's periods of custody with the minor child shall not be exercised at the Mother's home. Additionally, Mother's periods of custody with the minor child shall be limited to visits between the Mother and the child and not include Mother's boyfriend unless the child expresses a willingness for of contact. J. Sandy A. Keck 405 High Mountain Road Shippensburg, P A 17257 LapUb -f)cJl JI-W-OD R~~ cc: Dirk Berry, Esquire ./ !~ , " .~ . " - """ . -'-<~'" " ., ,'" " ("C' ,'I !:::i;_iL:D-O.'::FICE "." " ','", 'rT' RY , '. I "->;~..h~)IAf 00 NO\! - 7 AM 10: 34 CUi'\i1Bt:HLtNO COUNTY PENNSYL\)~'lJiA '~-'~--'-- ~ . ,- ~" - - .......~~ ."~--. . " DEBRA J. KECK, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW SANDY A. KECK, Defendant NO. 00-6545 CML IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Jeremiah S. Keck, born December 14, 1982. 2. A Conciliation Conference was held on November 2, 2000, with the following individuals in attendance: The Mother, Debra J. Keck, with her counsel, Dirk Berry, Esquire; and the Father, Sandy A. Keck, who appeared without counsel. 3. The parties agree to the entry of an order in the form as attached. '- !/~~/I)!J DA E ' Hubert X. Gilroy, Esq . Custody Conciliator