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Home My WebLink About01-0039 FX ,i"i'; '" ,',I, "-; ",-",', ~, -I~', ""c"", .>'",;" ,,'.__ ___''^'". _",,", "-'" ,~ '~~i LISA K. CARNS Plaintiff COURT OF COJMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. Of - S'39 Cio~(L~ STEVEN MARSHALL Defendant CIVll, ACTION-LAW IN CUSTODY ORDER OF COURT You, Steven Marshall, have been sued in court to obtain custody of the children, : Alexis, Jameson and Chase Marshall, You are ordered to appear in person at Location on , at (Day and Date) , .M., for (Time) [] a conciliation or mediation conference. [] a pretrial conference. [] a hearing before the court. If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. 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. Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 717-240-6200 J, , "" -.", """.--~,.--, , 0_,1".:',,'. ~',', " .,.~.,..' - ' :~-',.,i.ti;,,;.I;';,,~" . 0,'_"~ =__" "0 " c.:...,,' ;, "v. ""~".~' .',"~, .' AMERICANS WIrnmSABILITIES 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 scheduled conference or hearing. BY THE COURT: Date: J. CC: Michael J. Kane , Plaintiff COURT OF C0Ml\10N PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LISA K. CARNS v. : NO. OJ. S 39 C!..iuJ J~ STEVEN MARSHALL Defendant CI~ ACTION-LAW IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Lisa K. Karns who resides at 231 Lincoln St., Enola, Cumberland County Pennsylvania 17025 2. Defendant is Steven Marshall, who resides at 695 Salem Road, Lot Ill, Etters York County, Pennsylvania 17319. 3. Plaintiff seeks Custody of Name Present Address Age Alexis Kristine Marshall 231 Lincoln St., Enola, PA 4 Chase Douglas Marshall 231 Lincoln St., Enola, P A 7 Jameson Thomas Marshall 231 Lincoln St., Enola, P A 7 The children were born out of wedlock The children are presently in the custody of Lisa K. Carns, who resides at: 231 Lincoln St., Enola, Cumberland County Pennsylvania 17025 During the past five years the children have resided with the following persons an at the following addresses: Alexis: Plaintiff and Defendant 131 N. 15th Street, Camp Hill, PA 17011 Birth to Aug. 1999 j t Jameson and Chase: Plaintiff 2713 Market St. Camp Hill, PA 17011 1-1-95 to 4-1-96 Plaintiff and Defendant 131 N. 15111 St. Camp Hill, PA 17011 4-1-96 tp 8-1-99 Plaintiff 231 Lincoln St. Enola 8-1-99 to present Plaintiff 900 Allison Ave. Mechanicsburg, P A June 1, 1996 to present The mother of the child is Plaintiff; Lisa K. Karns who resides at 231 Lincoln St., Enola, Cumberland County Pennsylvania 17025 The mother is married The father of the child is Defendant, Steven Marshall, who resides at 695 Salem Road, Lot Ill, Etters York County, Pennsylvania 17319. The father is not married. 4. The relationship of Plaintiff to the children is that of Mother. The Plaintiff currently resides with the following persons: Name Relationship Scott Carns Husband 5. The relationship of Defendant to the children is that of Father. Defendant currently resides with the following persons: Name Relationship None 6. Plaintiff brought a protection from abuse action against defendant on March 1, 1994. in Perry County, pennsyvania. The Docket Number is unknown. It is unknown whether any orders regarding any of the children was entered at that time. iil "~, ','-"'" " - ,," '.. ", ';..',"y' " ., '" .,," .., ',.c,I'"". ',:_;.,,~,;j' '".'1,. ",';'d~' ."_, 0" -''~'~,:,. ",,. ;;." 'I ! f Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth 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 interests and permanent welfare of the child will be served by granting the relief requested because: Since birth, the children have resided with Plaintiff. Plaintiff and Defendant lived together until August, 1999, at which time their relationship ended. The children continued to reside with Plaintiff who has maintained primary physical custody. Though Defendant has engaged in regular visitation of the children since the end of the parties' relationship, Plaintiff has been the primary care giver to the children and has been the party primarily responsible for decision making in their lives. Plaintiff seeks to have formal court approval investing her with legal and physical custody while maintaining Defendant's entitlement to regular visitation. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Petitioner requests that the Court modify the existing Order for Shared Custody and grant Petitioner full legal and physical custody of the child. ~t~;t~. 46215 Kane and Mackin, LLP 3300 Toodle Rd. Camp Hill, PA l701l (717) 214-3700 Attorney for Petitioner <. L~ <<. 0" '"' " ~ +. .< " .~, """' ~., "OX' ,.' ~. ,;"'''I:,;~~,,;,,:,',; ~ ".,~ ~''" " "' '. " ",.;';~''''''',.'",. L;, VERlFICATION I veri1)r that the statements made in this Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 P. S. ~ 4904 relating to unsworn falsification to authorities. d~3{~ {- I Ii - 01 Date GJ FI, .c::D-O~F:CE OF . ".... F'~':(,~):-i-<X"!OTARY OI.JW26 A/1/0:23 CUMSfJiU,ND COLMY PENNSYLVANIA t/K/o. s--O -t".60 '-- ..t".OO- ~* -.!1.s:-0 SO ' p~ 4IJy C/::;;/L I (R.3 f<:JL 16(".; d. 7 I I ~ ~r . ,/ , ~ :O:j,,; LISA K. CARNS PLAINTIFF V. STEVEN MARSHALL DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-539 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 31ST day of January, 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliat at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 6th day of March ,2001, at11:00 a.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: Isl Melissa P. Greevy. Esq(f7 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 THIS 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 , 1'3/-t!-Y /3/0/ /3/-(1/ - M~",""4> "I~! ,~~-''''''''''"'' " > - > '-, -1 "'~~~", ~ "< " "'~~'.' ..,.-,~ ,,-.~ el\ r:(l...rl~fJ('.F : ll...\;=-~__~~,l, ',)..\;rj'"r'f;QV O~ r'>::,);r-',.):\\. \r\ill '% 01 JI'\N 3\ PH I.: 2\ CUIViBE.hLINO COUNTY PENNSYLW,N!A Itd tlfl/y #<Jt/ ~!-/?r; ,t:u<e. '7lc;:;t;~ //1~/ Z dj/T' (~,MtJ/ d a1 ~ ~I-""'-' . l,.bf1I1H ~~" ~ =dI1~~lJiHi~'IWW'l$'i?l'ii~;"'''~'!'I'""i''''''''''''A>",,';1(."I'''''''"~1''f!'ig''!!'i!~!l'!i'~!'l~f,"'!C~'_!g~i~n"'''''.~~ '. :1-, . ;" , .. 1 LISA K. CARNS Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLV ANlA v. . : NO. 01-539 STEVEN MARSHALL . Defendant : CIVIL ACTION-LAW : IN CUSTODY DISCONTINUANCE TO THE HONORABLE, THE JUDGES OF SAID COURT: Pursuant to Pennsylvania Rule of Civil Procedure 229, Plaintiff, hereby discontinues the above-action. Respectfully submitted, KANE AND MACKIN, LLP Dated: :2. 5' -0 I By: \U....e.-Lc.R Y'- <-- Michael J. K , Esquire Attorney ill No. 46215 3300 Trindle Road Camp Hill, P A 17011 (717) 214-3700 Counsel for Plaintiff -'",,- ","<' , , -'P~_>"_'" 1.---0-'''''; _ " -,- - _,,'_I-'_h.,_ -.;"',, .'-_._--"~-,,, .'"',C';-::',":- -',.,-; ,_ <' . L CERTIFICATE OF SERVICE I, MichaelI. Kane, do hereby certify that, on the IJ .4. day of r ebY'uc.. ~ ' 2001 I placed a true and correct copy of: PLAINTIFF'S DISCONTINUANCE in the United States Mail, first class postage prepaid, and addressed to: Mr. Steven Marshall 695 Salem Road, Lot 111 Etters, Pennsylvania 17319. Jll\~ ,,-o~k Michael 1. . ane OF' 01 FE8-G P!ll:b? CUI'~!:8tHu.\!";J COUNTY PENNSYLvi\NiA ~ 'I I . w _' i LISA K. CARNS, vs. STEVEN MARSHALL, Plaintiff Defendant ",or_J - _,' I _,_ -- '(~d"~"'~'''''.l'' 0,__',~_' .~j::~ t8 1 2 2001 j //; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-539 CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this 6th day of February, 2001, it appearing that the Plaintiff has discontinued the above-referenced custody action, the Custody Conciliator hereby relinquishes jurisdiction of this matter. D'" .J/ % L Meli a Peel Greevy, Esquire Custody Conciliator