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HomeMy WebLinkAbout03-2605 KELAH N. ST AHNER, Plaintiff, v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW JASON S. STARNER, Defendant. . . ./ : 2003 - 0<'05 CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE AND CUSTODY AND NOW, comes the Plaintiff, KeJah N. Stamer, by and through her attorneys, Irwin, McKnight & Hughes, and files this Complaint in Divorce against the Defendant, Jason S. Starner, representing as follows: I . The Plaintiff is KeJah N. Stamer, an adult individual residing at 263 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. The Defendant is Jason S. Starner, an adult individual currently residing at 32 West Main Street, New Kingston, Cumberland County, Pennsylvania 17072. COUNT I - DIVORCE PURSUANT TO SECTIONS 3301(c} AND 3301(d) OF THE DIVORCE CODE 3. The averments of paragraphs one (1) through two (2) of this Complaint are made a part hereof and incorporated herein by reference. 4. The Plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. Springs, Pennsylvania. 5. The Plaintiff and the Defendant were married on December 23,2000 in Mt. Holly 7. Pursuant to the Divorce Code, Sections 3301(c) and 3301(d), the Plaintiff avers as 6. There have been no prior actions of divorce or for annulment between the parties. the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 8. The Plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the Parties to Participate in counseling. 9. There is one (I) child bom to this marriage; namely, Tristan S. Starner, bom May 30, 2002, age 11 months. 10. Pursuantto the Divorce Code, Sections 330 I (c) and 330 I (d), the Plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. WHEREFORE, the Plaintiff respectfully requests judgment dissolVing the marriage between the two parties. COUNT II - CUSTODY 11. The avennents of Paragraphs one (I) through ten (10) of this Complaint are made a part hereof and incorporated herein by reference. 12. The parties' minor child is presently in the custody of Plaintiff. 13. Plaintiff desires primary physical custody with periods of temporary physical custody for Defendant. 14. The best interests and pennanent welfare of the child requires the Court grant the Plaintiff's request as set forth above. 15. Plaintiff has no infonnation of a custody proceeding concerning the child pending in a court of this Commonwealth or any other location. 16. Plaintiff does not know of a Person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. WHEREFORE, the Plaintiff respectfully requests that an Order of Court be entered granting her primary physical custody of the parties' minor child, Tristan S. Stamer. Respectfully submitted, IRWIN, McKNIGHT & HUGHES Dated: S-I/-o~ ebecca R. Hughes, Esquire Supreme Court J.D. No. 67212 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 By- VERIFICATION - The foregoing dOCUment is based upon infonnation which has been gathered by my counsel and me in the jlreparation of this action. I have read the statements made in this dOCUment and they are true and correct to the best of my knowledge, infonnation and belief I 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. -7 ~AH:~ARNER Date: ..5-/ 1-0 ~ - , 2003 -- :.::; J u. ("') o 0 ...::J" Lr.: i:= z ;;? ..... '-)~ -) ~ .~ 5: L...I ::..J :~:~~ ci.l ct :> :5 <J ..t~_ Cl- (") I ~ q 1=' :,.. o ;! ~~ Vl ~-ld ~ cj':J ~- -..3 <.J..Q :f:. <:1 tJ · ...... -tj ~ ~ KEHLAH N. STARNER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 03-2605 CIVIL ACTION LAW JASON S. STARNER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, June 06, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, July 01, 2003 at 2:30 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be rnade 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 ternporary order. All children age five or older may also be present at the conference. Failure to appear at the conference rnay provide grounds for entry of a ternporary 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 hearinf;l. FOR THE COURT. By: Isl Jacqueline M. VernlO" Esq. v Custody Conciliator The Court ofComrnon Pleas ofCurnberland County is required by law to cornply with the Americans with Disabilites Act of 1990. For inforrnation about accessible facilities and reasonable accornrnodations available to disabled individuals having business before the court, please contact our office. All arrangernents rnust be made at least 72 hours prior to any hearing or business before the court. You rnust attend the scheduled conference or hearing. YOU SHOULD TAKE TIHS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Curnberland County Bar Association 32 South Bedford Street Carlisle, permsylvania 17013 Telephone (717) 249-3166 -p~r~~~~~.u'~ [09."7 .~ 1- ~~u, [(/.".? jz? $ /~ ~ rr U/.?1 \IIf\I'VAlASNN:Jd I I ~I(\("^ """, ,'" ,~r"\ln'" t\,c.: .' "J. I - '.' :.'-<,.,:>~v. V i !:i :z ~ld 9 - Hnr 80 IU"I"" ' ^u iJ _I\~:j 'il,~,'i 'Le,',","',; 3:JU:iCHJJ1!..1 , '::0 KELAH N. STARNER, Plaintiff JU~2003 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2003-2605 CIVIL TERM JASON S. STARNER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this =f' day of q~ ,2003, upon consideration of the attached Custody Conciliati6n Report, it is ordered and directed as follows: 1. The Mother, Kelah N. Stamer, and the Fath(:r, Jason S. Stamer, shall have shared legal custody of Tristan s. Starner, born May 30, 2002. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. Mother shall have primary physical custody of the child. 3. Father shall have periods of supervised visitation, with Mother as the supervisor as follows: A. Beginning July 6, 2003 every Saturday and Sunday from 5:00 p.m. to 7:00 p.m. at Mother's home. In substitution for July 5,2003, Father shall have supervised visitation with the child as aforesaid on July 7, 2003 from 5:00 p.m. to 7:00 p.m. 4. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modifY the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for July 29, 2003 at 10:30 a.m. BY THE COURT, < /);,L J. cc: Rebecca R. Hughes, Esquire, Counsel for othej ,c _ LJ Jason S. Starner, pro se 7 - I 3 P.O. Box 332, New Kingstown, PA 17072 C!o,~ ~ 'v'lN\l^lASNN3d HNrCC: n:~ni:tj;:i\'~m 9'1 :8 H\I \3- -mf 1,0 ^H~j.ctK>\lJJ ,],-li :JO 3::l1:J:'CHJ3li:J JUL 0 2 2003 KELAH N. STARNER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : 2003-2605 CIVIL TERM JASON S. STARNER, Defendant : CIVIL ACTION - 11.A W : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Tristan S. Starner May 30, 2002 Mother 2. A Conciliation Conference was held in this matter on July 1, 2003, with the following individuals in attendance: The Mother, Kelah N. Starner, with her counsel, Rebecca R. Hughes, Esquire and the Father, Jason S. Starnl~r, pro se. 3. The parties agreed to the entry of an Order in the form as attached. /-//~o3 Date l1_~.__.L~ 9h.~ ~Verney,ES~ Custody Conciliator KELAH N. STARNER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JASON S. STARNER, Defendant : NO. 2003-2605 CIVIL TERM : IN CUSTODY PRIOR JUDGE: Kevin A. Hess, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Tristen S. Starner May 30, 2002 Mother 2. A Conciliation Conference was held July 29,2003 with the following individuals in attendance: The Mother, Kelah N. Starner, with her counsel, Rebecca R. Hughes, Esquire, and the Father, Jason S. Starner, pro se. 3. The Court previously entered an Order of Court on July 7, 2003 awarding the parties shared legal custody, with Mother having primary physical custody and Father having two hours of supervised physical custody every Saturday and Sunday. 4. Mother's position on custody is as follows: Mother seeks shared legal and primary physical custody with a phased in period of supervised custody for Father. Once Father learns to care for the baby appropriately, she would be more comfortable extending the supervised periods to unsupervised and possibly overnight if Father had a an appropriate residence. In addition, Mother objects to Father smoking in the baby's presence and using profane language. She has also observed Father feeding the baby with dirty hands. 5. Father's position on custody is as follows: Father seeks shared legal custody and partial physical custody on an alternating weekend schedule. Father indicates he expects to obtain his own apartment soon instead of living with his mother. He claims Mother smokes in the baby's presence also. He maintains that he is capable of caring for the baby without supervision. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and granting the parents shared legal custody, Mother primary physical custody and Father having two-hour supervised visits twice per week. It is expected that the Hearing will require one half day. 1-30-0) Date CL_. J.. A. v{ &t~q~;;;-M~ey, Esq~ Custody Conciliator I JUL 3 u Z003 ~ KELAH N. STARNER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JASON S. STARNER, Defendant : NO. 2003-2605 CML TERM : IN CUSTODY ORDER OF COURT AND NOW, this ~ day of au ~ ,2003, upon consideration of the attached Custody Conciliatiorl'Report, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. 'I ,of the Cumberland County Court House, on the .;(.5w{ day of ((},rl-.J...!v A ./ , 2003, at /,'.3 () . o'clock, jJ . M., at which time testimony will be taken. For purposes of this Hearing, the Mother shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the Order of Court dated July 7, 2003 shall remain in effect with the following modification: 3. Paragraph 3 of the prior Order shall be deleted and replaced with the following: Father shall have periods of supervised visitation, with Mother as the supervisor as follows: beginning August 4 and 5, 2003 every Monday and Tuesday evening from 6:00 p.m. to 8:00 p.m. 4. Paragraph 4 is deleted in its entirety and replaced with the following: the parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, ./7/1 J. Ke . c~ca R. Hughes, Esquire, counsel for Mother ,Jason S. Starner, pro se > P.O. Box 332 New Kingstown, P A 17072 ~~ R(s 01.05 -03:> \)1Nvt:1ASNN3d }J_rlr;~,."~ ,'-':,'j::~:':';::i~,"!nC) 2 ~j :Z :,,' '- :~, - ~il~ [:0 :(] KELAH N. STARNER, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CML ACTION - LAW JASON S. STARNER, Defendant. : 2003 - 2605 CIVIL TERM : IN DIVORCE PETITION TO wrTHDRA W 1. On or about April, 2003, the plaintiff in this matter, Kelah N. Starner, retained the services of Irwin, McKnight & Hughes to represent her interest in various marital matters including but not limited to support, pate:rnity, divorce and custody. 2. Through the present, Rebecca R. Hughes, Esquire, has represented the plaintiff, Ms. Starner, in various hearings relative to the above-mentioned issues. 3. On or about July 29, 2003, a custody conciliation was held before Conciliator Jacqueline M. Verney, Esquire, and no agreement was reached; the defendant was unrepresented. As of this date, there has been no notification that the defendant has retained counsel. 4. A hearing date for a full custody hearing has been set for October 23,2003 before The Honorable Kevin A. Hess. S. On or about August 27, 2003, due to serious lmd continuous health problems, Rebecca R. Hughes, Esquire, counsel for the plaintiff, consulted a neurosurgeon who advised her to have extensive surgery done on her back in the very near future which, if unattended, can leave permanent nerve damage as well as other problems. 6. To date, the surgery has not been scheduled, however, due to the current physical condition of counsel for the plaintiff, continued representation of this case, particularly through a full custody hearing and the time necessary for preparation, cannot be accomplished in a manner which is necessary to zealously represent the plaintiff. 7. Because of the physical problems of counsel fol' plaintiff, as well as other reasons, counsel for plaintiff is temporarily, if not permanently quitting the practice of law, and in the interim, leaving the current fIrm at which she is practicing. 8. Therefore, due to the physical disability of Rebecca R. Hughes, Esquire, and the change of the firm in which she is doing limited legal work, Rebecca R. Hughes respectfully requests that she be granted leave to withdraw from this case. 9. The date of the hearing is October 23,2003, which allows the plaintiff 5 weeks to obtain a new attorney, and also additional time for the new attorney to request a continuance of the hearing date. WHEREFORE, Rebecca R. Hughes, Esquire, respectfuIly requests that this Honorable Court grant her permission to withdraw from the continued representation of this case. Respectfully submitted, IRWIN, McKNIGHT & HUGHES ~~ Rebecca R. Hughes, Es uir 60 West Pomfret Street Carlisle, PA 17013 717-249-2353 Supreme Court I.D.: 67212 Date: September 16, 2003 (') L ~LJ ~~r C,-1' ~." c/:, C.:J _/ ,-, c.,; :-n ," J r:; " :(~~ . /. )> ;:'~.J "-., (:) r) ~ i- I v. SEP 1 9 2003 'f{ : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW KELAH N. STARNER, Plaintiff, : 2003 - 2605 CIVIL TERM JASON S. STARNER, Defendant. : IN DIVORCE ORDER OF COURT AND NOW, this 22..! day of ~1oc..W ,2003, upon consideration of the attached Petition to Withdraw, Rebecca R. Hughes, Esquire, is granted leave to withdraw from the above- captioned case effective immediately. By '" eo",,, J ,~ J. 'Pi rt l.o.: ~ , ".-:;C\ ","\ '",\\C:::,\j\\::~'-'!~\IV \:!~,!~?\:~!,".i:~.",.:. ' ,"\"".' ~G ('I d.J" \.'\\ ~,u - \ :l\\ ' ' " . ~~o (, ~ ~ ~ " " KELAHN. STARNER, Plaintiff v. JASON S. STARNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 2003-2605 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in Divorce and Custody that was filed in this matter. Date: lOf'l..;L~") :J;;~ Michael J. Ha ,Esquire Attorney LD. No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorneys for Plaintiff F:\User Fold~r\Firm Docs1Gendocs200313323-1 ,praecipereinstate,complaint_wpd (') \? (1-, !.! ^-'" (D c:~ I'::"> () -1'1 _v o :->) ---I .........) p< , . ~ KELAHN. STARNER, I Plaintiff vs. JASON S. STARNERl Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-2605 CIVIL CIVIL ACTION - LAW ORDER Z-'3.4 day of October, 2003, after hearing, the existing custody order in this case is further odified to provide that: 1. Commend g with the first day of November 2003, in addition to weekday visitation allowed by our order August 5, 2003, the defendant shall have partial custody of Tristan S. Starner, born May 30, 002, every weekend. Said weekend period of partial custody may be exercised outside the orne of the mother and without her supervision, commencing at 11 :00 a.m., for a period of fo r hours on the first weekend, adding an additional hour each succeeding weekend so that the fa her will have eight hours during the last weekend of November. Weekend custody shal be exercised on either a Saturday or a Sunday as the parties shall agree and, if they cannot agr e, on Sunday. 2. The foregoi g eight-hour weekend partial custody shall continue until such time as the defendant has his own dwelling or is otherwise able to provide suitable sleeping arrangements for the child, after whi h this matter may be relisted for conciliation unless the parties can agree as to how to modify th s order. It is expected that any modification would implement a schedule of alternating weeken s of custody in the father the first four of which such weekends would be exercised from Saturd y evening until Sunday evening with alternating weekend custody, thereafter, from Frida evening until Sunday evening. ~[ .' ~ ..... ~'?l\\:"\lil<S;'\?'L?d ',vnJ ."-d[/ l '.. ':'~'J 3. The father ~hal1 have partial custody of Tristan on Christmas day of2003 from 2:00 p.m. until 7:00 p.m. 1jhereafter, the parties shall alternate major holidays as they shall agree and, if they cannot agree, ~ey may request conciliation on this issue:. BY THE COURT, Michael Hanft, Esquir For the Plaintiff K~,"~d- :r\m f ~i'f)) Lfl6 ~ .A_ R~5 10-:<4 -a3 .)1ison S. Starner Pro Se Defendant IN THE COURT OF COMMON PLEAS o CUMBERLAND COUNTY, PENNSYLVANIA KELAH N STARNER, Plaintiff No. 2003-2605 v. CIVIL ACTION - LAW JASON S.STARNER, Defendants IN DIVORCE/CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH F PENNSYLVANIA SS. COUNTY OF CUMB RLAND Sean M. Shultz being sworn according to law, deposes lmd says that he is a competent adult over 18 years of age; t at he served a copy of the Complaint in this action upon Defendant, Jason S. Starner, by personally anding him a true and correct copy thereof and informing him of its content at the Cumberland Count Courthouse on October 23,2003, at 1:30 P.M. Deponent furth r avers that at the time of such service, the Plaintiff identified herself to the deponent. :;;:'jv1~ Sean M. Shultz, Deponent Sworn to and subscrib d before me this 28th da of October, 2003. i 0 0 - , Co> ..., 0 -'1 n ;.r;:o -f . r- f;; N va :;.."~ W 0 15 . ... :e-d ; -0 :x ~~ - .. ~ r=- C -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA KELAH N. STARNER, No. 2003-2605 Plaintiff CIVIL ACTION - LAW v. JASON S. STARNER, IN DIVORCE/CUSTODY Defendant AFFIDAVIT OF CONSENT STATE OF PENNSYLVANIA ) : SS. ) COUNTY OF CUMBERLAND 1. 3,2003. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on June 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I verify that the statements made in this affidavit 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. Date: 2 - 21... - 0'-1 ,2004 Y.J-l ~~"- ~I-;;b N. Starner Sworn to and subscribed before me this D/.fp /J; day of Fe.b,"",v' I' 2004. ~)fL.Q~-- Noi:hyJublic COMMONWEAL Ti'i OF PENNSYLVANIA\ - NlM<IIllllll \ MIrY M. PIlGe. NctI8rY PubiC ScUtt ~ '!Ifjp., wrWlallllCa<JI\.Y MIl ~... I . :1\ EllIIftIIiUQ. 18, 2007 Momt>or, PenMytvonlo "".....-. Of__ (.~ r-.' ,;'::'_:.1 <,-:-,) :!',: ('- -,.j ~"." .-\ - -~. :1--1 <- ~"l CQ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA KELAH N. STARNER, No. 2003-2605 Plaintiff CNIL ACTION - LAW v. JASON S. STARNER, IN DNORCE/CUSTODY Defendant AFFIDAVIT OF CONSENT STATE OF PENNSYLVANIA ) : SS. ) COUNTY OF CUMBERLAND 1. 3,2003. A Complaint in divorce under Section 330 1( c) of the Divorce Code was filed on June 2. The marriage of Plain tiff and Defendant is irretrievably broken and ninety days have elapsed from the date offiling and service ofthe Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. 4. I have been advised ofthe availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I verify that the statements made in this affidavit 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. Date: t'W. 2..0 ,2004 (1. J'\t1lo>.~~./ J~~ S~;;~#UF Sworn to and subscribed before me this Zfl~l of f{!~)2004. ~u~,~:;z.\;,~~a"d'~2004"J2J']'ffM.Wpd No1anaI Seal I Dolly M. Housel. Notary Pubfic South Middleton Twp., Cumberland County My Commission Expires Sept. 24. 2006 Member. PeMsylvarna Association Of Notaries ~, c;~., ~ (~) .~h ,J (J\ 0:; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA KELAH N. STARNER, No. 2003-2605 Plaintiff CIVIL ACTION - LAW v. JASON S. STARNER, IN DIVORCE/CUSTODY Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 3. I understand that I wil1 not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. Date: 2-zc...-oy Y:.-L.J. Jrr- ~ . ~~ .i.;'lili N. Starner ~,' .-:~:.:) .-~ ":::.') ...... ."J;;..:" -\.~ ....,,,.. ....-~ - ;.~ " ,..;-\ (..'; c<::;. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA KELAH N. STARNER, No. 2003-2605 Plaintiff CIVIL ACTION - LAW v. JASON S. STARNER, IN DIVORCE/CUSTODY Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alirnony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. Date: 2.)2D 104- ~~2r~ F\User FolderlFirm DocsIGendocs2004\3323-1 waiver.nol. wpd U-1 c; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KELAH N. STARNER, Plaintiff v. CIVIL ACTION - LAW NO. 2003-2605 JASON S. STARNER, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: hand delivery on October 23,2003. 3. Date of execution of the Plaintiffs Affidavit of Consent required by Section 3301 (c) of the Divorce Code; February 26,2004; by the Defendant; February 20,2004. 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice in S330 1 ( c) Divorce was filed with the Prothonotary: March 1, 2004. Date Defendant's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: March 1, 2004. Date: S _/_0 t./ Attorneys for Plaintiff F:\User FolderIFhm DocsIGendocs2004\3323-lpraecipe wpd _.~.~ >J --'I ell c'; . . .. . . . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF KELAH N. STARNER, Plaintiff VERSUS ,TA.<:rN S S'T'AR!Iw.R , Defendant . AND NOW, DECREED THAT AND PENNA. No. 2003-2605 DECREE IN DIVORCE ~ 4.."* .... J , 2004 , IT IS ORDERED AND KBLAH N. STARNER _, PLAINTIFF, JASOO S. STARNER , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; lJo fJf. By THE COURT: / . . /l JJ... J. . . PROTHONOTARY . III II II . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ Z ~1#' ~/;r/..h . f ~ 7/:.7/ 7- ~1Y ~l ~J/?r/ .ft. F . ."!. ... 'll-".'. ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA KELAH N. STARNER, Plaintiff No. 03-2605 v. IN DNORCE JASON S. STARNER, Defendant PETITION TO MODIFY CUSTODY AND NOW, this J4"~day of September, 2006, comes the Petitioner, KelahN. Starner, by and through her attorneys, Knight & Associates, P.C., and files the following Petition to Modify Custody and in support thereof avers as follows: 1. The Petitioner is Kelah N. Starner, an adult individual residing at 200 McLand Road, Mt. Holly Springs, Pennsylvania 17065. 2. The Respondent is Jason S. Starner, an adult individual residing at 848 Baltimore Pike, Gardners, Pennsylvania 17324 3. Petitioner seeks a modification of the Orders of Court dated July 7,2003 and October 23,2003, copies of which are attached hereto and made a part hereof and is marked as Exhibit "A." Name 4. The Parties are the natural parents of the following minor child: Present Residence Age Tristan S. Starner 200 McLand Road, Mt. Holly Springs, P A 4 Tristan was not born out of wedlock. Tristan is presently in the physical custody oftbe Petitioner. During the past five years Tristan has resided with the following persons and at the following addresses: .. a. From birth to February of2003 with the parties at 32 West Main Street, New Kingston, Pennsylvania; b. From February 2003 to May 24, 2005 with Petitioner at 263 Plaza Drive, Boiling Springs, Pennsylvania; c. From May 24, 2005 to January of2006 with Petitioner at 200 McLand Road, Mt. Holly Springs, Pennsylvania; d. From January of 2006 to June 1, 2006 with Petitioner and Petitioner's boyfriend, Brian Cigic at 200 McLand Road, Mt. Holly Springs, Pennsylvania; and e. From June 1,2006 to present with Petitioner at 200 McLand Road, Mt. Holly Springs, Pennsylvania. The mother of Tristan is the Petitioner, Kelah N. Starner, who resides at 200 McLand Road, Mt. Holly Springs, Pennsylvania. The father of Tristan is the Respondent, Jason S. Starner, who resides at 848 Baltimore Pike, Gardners, Pennsylvania. 5. The relationship of Petitioner to Tristan is that of mother. She is single and currently resides with Tristan. 6. The relationship of the Respondent to Tristan is that of father. He is single and currently resides with his mother, Donna Starner. 7. The Petitioner has previously participated in litigation concerning custody of the above-named child in this Court at the above-referenced docket. An Order of Court was entered on July 7,2003 and on October 23,2003. Said Orders are cited in Paragraph 3 above and are attached hereto as Exhibit "A" and by reference incorporated herein. The Petitioner has no knowledge of any custody proceedings concerning the custody of Tristan pending before this or any other Court. The Petitioner does not know of a person not a party to the proceedings who has physical custody of Tristan or claims to have custody or visitation rights with respect to Tristan. 8. Respondent was arrested and was incarcerated due to drug-related charges. 9. Respondent repeatedly places Tristan in dangerous situations, for example, by driving Tristan around without a car seat. 10. Petitioner requests the following changes be made to the July 7,2003 and October 23,2003 Custody Order: a) Petitioner requests sole legal custody of Tristan; and b) Petitioner requests that Respondent have supervised visitation with Tristan one night during the week. 11. Each parent whose parental rights to Tristan have not been terminated and the person who has physical custody of Tristan have been named as parties to this action. There are no other persons who are known to have or claim a right to custody or visitation of Tristan. 12. The best interests and permanent welfare of Tristan will be met if the custody order is modified as requested because: a) The Petitioner is a fit parent who can take care of Tristan; b) The Petitioner can provide Tristan with a home with adequate moral, emotional and physical surroundings as required to meet the his needs; c) The Petitioner has primary custody of Tristan; and d) . The Petitioner continues to exercise parental duties and responsibilities and enjoys the love and affection of Tristan. 13. To the best of Petitioner's knowledge, Respondent is not represented by counsel in this matter. A copy of this Petition was sent to Jason S. Starner at 848 Baltimore Pike, Gardners, Pennsylvania 17324. WHEREFORE, the Petitioner respectfully requests Your Honorable Court modify the Custody Orders dated July 7,2003 and October 23,2003 as requested. Respectfully submitted, ean M. Shultz: e Attorney ill No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorneys for Petitioner VERIFICATION I verify that the statements made in the foregoing Petition to Modify are true and correct to the best of my knowledge, information and belief. 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. ~. O~ 2rl-~~~ Ke N. Starner F:IUSeT FoJderlFinn DocsIGendocs200613323-2pet.modify. wpd Exhibit "A" JUL 0 2 2003 KELAH N. STARNER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2003-2605 CIVIL TERM JASON S. STARNER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this ~ day of ,2003, upon consideration of the attached Custody Conciliation Re ort, it is ordered and directed as follows: t 1. The Mother, Kelah N. Starner, and the Father, Jason S. Starner, shall have shared legal custody of Tristan s. Starner, born May 30, 2002. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. Mother shall have primary physical custody of the child. 3. Father shall have periods of supervised visitation, with Mother as the supervisor as follows: A. Beginning July 6, 2003 every Saturday and Sunday from 5:00 p.m. to 7:00 p.m. at Mother's home. In substitution for July 5, 2003, Father shall have supervised visitation with the child as aforesaid on July 7, 2003 from 5:00 p.m. to 7:00 p.m. 4. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for July 29,2003 at 10:30 a.m. BY THE COURT, IS} ~ C ~ J. cc: Rebecca. R. Hughes, Esquire, Counsel for Mother Jason S. Starner, pro se P.O. Box 332, New Kingstown, PA 17072 JUl 0 2 2003 KELAH N. STARNER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2003-2605 CIVIL TERM JASON S. STARNER, Defendant : CIVIL ACTION - LA W : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT t IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTL Y IN CUSTODY OF Tristan S. Starner May 30, 2002 Mother 2. A Conciliation Co1)ference was held in this matter on July 1,2003, with the following individuals in attendance: The Mother, Kelah N. Stamer, with her counsel, Rebecca R. Hughes, Esquire and the Father, Jason S. Starner, pro se. ., j. The parties agreed to the entry of an Order in the form as attached. ;../ I --0 3 Date a. cq eline M. Verney, Esquire Custody Conciliator KELAH N. STARNER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-2605 CIVIT.. CML ACTION - LAW JASON S. STARNER, Defendant ORDER AND NOW, this z..'3.-4 day of October, 2003, after hearing, the existing custody order in this case is further modified to provide that: 1. Commencing with the first day of November 2003, in addition to weekday visitation allowed by our order of August 5, 2003, the defendant shall have partial custody of Tristan S, Starner, born May 30,2002, every weekend. Said weekend period of partial custody may be exercised outside the home of the mother and without her supervision, commencing at 11 : 00 a.m., for a period of four hours on the first weekend, adding an additional hour each succeeding weekend so that the father will have eight hours during the last weekend of November. Weekend custody shall be exercised on either a Saturday or a Sunday as the parties shall agree and, if they cannot agree, on Sunday.. 2. The foregoing eight-hour weekend partial custody shall continue until such time as the defendant has his own dwelling or is otherwise able to provide suitable sleeping arrangements for the child, after which this matter may be relisted for conciliation unless the parties can agree as to how to modify this order. It is expected that any modification would implement a schedule of alternating weekends of custody in the father the first four of which such weekends would be exercised from Saturday evening until Sunday evening with alternating weekend custody, thereafter, from Friday evening until Sunday evening. 3. The father shall have partial custody of Tristan on Christmas day of2003 from 2:00 p.m. until 7:00 p.m. Thereafter, the parties shall alternate major holidays as they shall agree and, if they cannot agree, they may request conciliation on this'issue. BY THE COURT, Michael Hanft, Esquire F or the Plaintiff ~ "- /-J d- KeY Hess, J. Jason S. Starner Pro Se Defendant :rlm IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KELAH N. STARNER, Plaintiff No. 03-2605 v. IN DIVORCE JASON S. STARNER, Defendant CERTIFICATE OF SERVICE AND NOW, this ~day of September, 2006, I, Sean M. Shultz, Esquire, hereby certify that I have this day served the following with a copy of the foregoing Petition to Modify Custody by first class, United States Mail, postage pre-paid, addressed as follows: Jason S. Starner 848 Baltimore Pike - Gardners, Pennsylvania 17324 Respectfully submitted, & ASSOCIATES, P.C. Sean M. Shultz, Esquire Attorney I.D. No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorney for Petitioner KELAH N. STARNER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNS YL VANIA v. 03-2605 CIVIL ACTION LAW JASON S. STARNER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, September 19, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, October 17, 2006 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. 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 hearin2. FOR THE COURT. By: /s/ Jacqueline M. Vemey, Esq. Custody Conciliator r- The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Oisabilites 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 A TTORNEY AT ONCE. IF YOU DO NOT HA VE 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 , p? ~ p ~ ~ 4? v-oe-f; . ~ ~ ~ ~"" '117 ae-6 ~y?~~flJ 'W-<7t'-O '1INv'^lASNN3d )J.NnC(\ (1~.!\f1}J38WnO 10 :0\ W~ 02 d3S 900Z ABV10NOH10Sd 3Hl :10 381:!~o-a311::J " ~ , ' i'l\ ~ KELAH N. STARNER, Plaintiff : IN THE COURT OF COMMON -itiAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2003-2605 CIVIL TERM JASON S. STARNER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 2'1 day of O~~ ,2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated August 5, 2003 and October 23,2003 are hereby vacated. 2. The Mother, Kelah N. Starner, and the Father, Jason S. Starner, shall have shared legal custody of Tristan S. Starner, born May 30, 2002. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa.C.S. ~5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 3. Mother shall have primary physical custody of the child. 4. Father shall have periods of partial physical custody every Sunday from 11 :00 a.m. to 7:00 p.m. 5. Father shall have a five-hour block of time with the child on Thanksgiving Day and Christmas Day at times agreed by the parties. ',il!\lv/\\,.l,S!\IN 3d }Jj"{rtr' ~ ,"'f' ,'4< '--"~n:) " ,,'," I' "",'" ',",' '<" \ \\...'" ' . i ., ;,"_ ' -. i::~1 i:] 0 :6 pi\! OS 1:)0900l Atl\;il0\\i\}-,1.Ujd 3Hl :10 3~i\~j~tC}~{1:.1l1~j 6. Father shall have physical custody of the child on the Saturday before Mother's Day from 11:00 a.m. to 7:00 p.m. instead of his Sunday time period on Mother's Day. 7. Father shall be responsible for all transportation 8. Neither party may partake in illegal drugs or consume alcohol to the point of intoxication immediately before or during their periods of custody. 9. The parties shall utilize an age and weight appropriate car seat for the child. 10. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms ofthis Order shall control. BY THE COURT, .,?J cc~~ M. Shultz, Esquire, Counsel for Mother .,...hfson S. Starner, pro se 848 Baltimore Pike Gardners, PA 17324 J. ~ KELAH N. STARNER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2003-2605 CIVIL TERM JASON S. STARNER, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Kevin A. Hess, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Tristan S. Stamer May 30, 2002 Mother 2. A Conciliation Conference was held in this matter on October 24, 2006, with the following individuals in attendance: The Mother, Kelah N. Stamer, with her counsel, Sean M. Shultz, Esquire and the Father, Jason S. Stamer, pro se. 3. The Honorable Kevin A. Hess entered Orders of Court dated August 5, 2003 and October 23,2003 providing for shared legal custody, with Mother having primary physical custody and Father having every Monday and Tuesday, supervised by Mother for two hours in the evening and every Sunday from 11 :00 a.m. to 7:00 p.m. The Order anticipated going to alternating weekends once Father obtained his own dwelling or suitable sleeping arrangements for the child. Father asserted he had adequate sleeping arrangements, but Mother would not agree to overnights. Father was advised to file a Petition to Modify to request overnights. 4. The parties agreed to the entry of an Order in the form as attached. 10 - ;) l{ ./o~ Date ~j,(.~ . cq ine M. Verney, Esquire I Custody Conciliator *• r s Kelah N. Pross, : IN THE COURT OF COMMON PLEAS OF F/K/A Kelah N. Starner : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION-LAW IN CUSTODY Jason Starner , Defendant NO. 2003-2605 CIVIL TERM PRACIPE TO WITHDRAW AND ENTER AN APPEARANCE TO THE OFFICE OF THE PROTHONOTARY: PLEASE withdraw my appearance as attorney of record for the Petitioner, Ms. Kelah Pross, at the above captioned docket. Re ectfully submitt d by, C'7 Sean M. Shultz, Esq. M rT Sadis, Sullivan, and Rogers 26 West High Street -0 3>c-, = _ Carlisle, PA 17013 =C) r; 717-243-6222 Fax: 717-243-6486 Dated: PLEASE enter my appearance as attorney of record on behalf of the Petitioner, Ms. Kelah Pross, at the above captioned docket. Respectfully submitted by: McKenzi lark Certified Legal Intern { ti Tim S Sup rvising Attorney COMMUNITY LAW CLINIC 371 West South Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 Dated: %/D S' /-0(3 Kelah Pross, : IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner OF CUMBERLAND COUNTY, -1,:1, LT- _ : PENNSYLVANIA r v. : CIVIL ACTION - LAW : IN CUSTODY Mr. Jason Starner, = Defendant/Respondent : No. 2003-2605 CIVIL TL ?I PETITION TO CONFIRM RELOCATION PURSUANT TO PA R.C.P. 1915.17 AND NOW, this day of October 2013, pursuant to Rule 1915.17 of the Pennsylvania Rules of Civil Procedure, comes the Petitioner, Ms. Kelah Pross, by her attorneys, the Community Law Clinic, seeking to confirm the relocation of the minor child, Tristan S. Starner, born May 30, 2002. In support of her Petition to Confirm the Relocation, Petitioner avers the following: 1. Petitioner is Ms. Kelah Starner, who currently resides at 200 McLand Road, Mt. Holly Springs, PA 17065. 2. Respondent is Mr. Jason Starner, who currently resides at 152 2nd Street Apt. 1 Highspire, PA 17034 3. Petitioner is the biological mother of the Tristan S. Starner, hereinafter, the Child. 4. Respondent is the biological father of the Child. 5. The Child was born within wedlock. 6. Mother has been the primary caretaker of the Child since his birth. 7. The Child resides with Petitioner at 200 McLand Road, Mt. Holly Springs, PA 17065. 8. Child has been a resident of Cumberland County, PA for his entire life. 9. A Custody Order signed by the Honorable Judge Hess was entered in this docket on October 27, 2006, (see Exhibit A). 10. Under the October 2003 Custody Order a. Petitioner and Respondent have shared legal custody of the Child b. Petitioner has primary physical custody of the Child c. Respondent has partial physical of the Child every Sunday from 11:00 AM to 7:00 PM. 11. Petitioner is moving to Las Vegas, NV with the Child. 12. Petitioner's husband, Stephen Pross, is in the United States Air Force, and has been assigned to Nellis Air Force Base, located in Las Vegas, NV 13. Respondent received the Notice of Relocation and the Counter-Affidavit on September 7, 2013, (see Exhibit B). 14. Earlier notice was impossible because Petitioner's husband only learned of his assignment in the middle of August. 15. Respondent signed and returned the Affidavit of Consent on September 24, 2013, (see Exhibit C). 16. Respondent does not object to the relocation and agrees to the custody schedule set forth in the attached proposed order. WHEREFORE, the Petitioner, Ms. Kelah Pross respectfully requests that this Honorable Court confirm the relocation of the Child, Tristan S. Starner and enter the proposed Custody Order. Respectfully submitted, 1 `Dat McKenzie rk Certified Legal Intern Timothy ..-''' Supervis 5�g Attorney COMMUNITY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013-2899 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing Petition to Confirm the Relocation are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: Io - 15 i .3 -P� Kel Pross, Petitioner V KELAH N. STARNER, : IN THE COURT OF COMMON PL AS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2003-2605 CIVIL TERM JASON S. STARNER, : CIVIL ACTION-LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW,this 2 day of OcGu-- , 2006,upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated August 5, 2003 and October 23, 2003 are hereby vacated. 2. The Mother,Kelah N. Starner, and the Father, Jason S. Starner, shall have shared legal custody of Tristan S. Starner,born May 30, 2002. Each parent shall have an equal right,to be exercised jointly with the other parent,to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including,but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information,that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician,dentist,teacher or authority and copies of any reports given to them as parents including,but not limited to: medical records,birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities,children's parties,musical presentations, back-to-school nights,and the like. 3. Mother shall have primary physical custody of the child. 4. Father shall have periods of partial physical custody every Sunday from 11:00 a.m. to 7:00 p.m. 5. Father shall have a five-hour block of time with the child on Thanksgiving Day and Christmas Day at times agreed by the parties. 6. Father shall have physical custody of the child on the Saturday before Mother's Day from 11:00 a.m. to 7:00 p.m. instead of his Sunday time period on Mother's Day. 7. Father shall be responsible for all transportation 8. Neither party may partake in illegal drugs or consume alcohol to the point of intoxication immediately before or during their periods of custody. 9. The parties shall utilize an age and weight appropriate car seat for the child. 10. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, Kevin A. -ss, J. cci,g4 M. Shultz, Esquire, Counsel for Mother son S. Starner, pro se 848 Baltimore Pike Gardners, PA 17324 C54. * 40 KELAH N. STARNER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2003-2605 CIVIL TERM JASON S. STARNER, : CIVIL ACTION-LAW Defendant : IN CUSTODY PRIOR JUDGE: Kevin A.Hess, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Tristan S. Starner May 30, 2002 Mother 2. A Conciliation Conference was held in this matter on October 24, 2006, with the following individuals in attendance: The Mother, Kelah N. Starner, with her counsel, Sean M. Shultz,Esquire and the Father, Jason S. Starner,pro se. 3. The Honorable Kevin A. Hess entered Orders of Court dated August 5, 2003 and October 23, 2003 providing for shared legal custody, with Mother having primary physical custody and Father having every Monday and Tuesday, supervised by Mother for two hours in the evening and every Sunday from 11:00 a.m. to 7:00 p.m. The Order anticipated going to alternating weekends once Father obtained his own dwelling or suitable sleeping arrangements for the child. Father asserted he had adequate sleeping arrangements, but Mother would not agree to overnights. Father was advised to file a Petition to Modify to request overnights. 4. The parties agreed to the entry of an Order in the form as attached. /0 - - � Date cq ine M. Verney, Esquire d • Custody Conciliator - * ' , ' . . OF ?ht.: ^"". .~ . - 'im,UM|! SENDER:COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY , ■-Complete items 1,2,and 3.Also complete item 4 N Restricted Delivery is desired. liSiMrir �'i :Agent • Print your name and address on the reverse 'i Addressee so that we can return the card to you. B. -eceived by(Printed erne) C.C. D. -,of AO/ IM Attach this card to the back of the mailpiece, ° 7 >! or on the front if space permits. 0 N D. Is delivery address different from item 1? 0 Yes 1. Article Addressed to: If YES,enter delivery address below: ii No 'Orn ST Jso ari)er Iii hspirzi PA / 031.-/ 3. Service Type „2rCertified Mail 0 Express Mail ,'Registered OF- Pletum Receipt for Merchandise 0 Insured Mail 0 C.O.D. 4. Restricted Delivery?(Extra Fee) 'Yes 2. (Transfer Number 7010 1060 0001 1046 7446 (trans from service label) PS Form 3811,February 2004 Domestic Return Receipt 102595.42-M-154 UNITED STATES POSTAL SERVICE First-Class stages Fees Paiil LISPS Permit No.G-10 • Sender: Please print your name, address, and Z1P+4 in this box • on-71-7--)6L/2/J Zi/ o Lo [� fni G 3'71 es/-- SaLik Sree f a.rr/i s/e1 P,4 7/20/ - a a2 7 11 jj uli,1,jiiht..1.1iiiiilr41is1113.1.11 ,111..11.11 x111.111 11r lL L O °LW L 'N 7.. ` . ,, G in 'al a N 876 m E �o; N c b E e 1,2 o N o N ao 00- d E ` y O o= W �_ E o c(1).>,,, r N :ee 41 O 05 m ai `� ac o -O N 8-2 ai o.2 2=a)� co Q. m 3 `ei�] m A >` o NaNNU • O- e Ili 3 O �' A Nat �N oE0l"o wE 0Ea s n w 0 1 Qo=. _ "� �O • T ❑ 2Uallo i0 NO-c r $ LU v �� C) li)111 m N C u.121 ONNNO di 4304 a U N 52 a oa� 13 aapas, m oad t cr c ',• 3 .c 'omx ;? m ° ii `m N 0 o.12 J a ii EU'.,•al NM N cn U 2. � M i'`¢a� 2Eg >w 0 '� N� N ° • 4 ' w a o E u. m m mg m N o } 6 >o E:. 0- N a v W g a m� I LL " Imo .. ▪ T o No ! Um o o▪ flI QOO E 'N i p :-o a N- 7yc No_o a q LL K-Emc a vo m22 N v~ 2m mg;EN0• z8 CnU.tp V ¢o yo N ti � (1)b v v m m sav c y 2.,..,—z. m ( I a w 003 w y 'vr o i3 E a a 8 o oz> ��cc.rot LL om w�2 0- 9hihL 9h0T TOED 090T °TOL Kellah Pross, : IN THE COURT OF COMMON PLEAS OF F/K/A Kelah N. Starner : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • v. : CIVIL ACTION—LAW : IN CUSTODY Jason Starner, Defendant. : NO. 2003-2605 CIVIL TERM COUNTER-AFFIDAVIT REGARDING RELOCATION This proposal of relocation involves the following child: Name Age Currently residing at: Tristan Starner 11 200 McLand Road Mt. Holly Springs, PA 17065 I have received a notice of proposed relocation and (check all that apply.) 1. (/ I do not object to the relocation. 2. V I do not object to the modification of the custody order consistent with the proposal for modification set forth in the notice. 3. () I do not object to the relocation, but I do object to the modification of the custody order. 4. () I plan to request that a hearing be scheduled by filing a request for hearing with the court: a. () Prior to allowing Tristan to relocate b. ( ) After the child relocates. 5. () I do object to the relocation. 6. () I do object to the modification of the custody order. I understand that in addition to objecting to the relocation or modification of the custody order above, I must also serve this counter-affidavit on the other party by certified mail, return receipt requested, addressee only, or pursuant to Pa.R.C.P No. 1930.4, and, if there is an existing custody case, I must file this counter-affidavit with the court. If I fail to do so within 30 days of my receipt of the proposed relocation notice, I understand that I will not be able to object to the relocation at a later time. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 (relating to unsworn falsification to authorities).)/I 4.110 DATA .I f NATURE Kelah Pross, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY Mr. Jason Starner Defendant : NO. 2003-2605 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Kelah Pross, Plaintiff/Petitioner, to proceed in forma pauperis. The Community Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date /O/1 7/ l3 A.�i.� 4 McKenzie Cam. Certified Legal Intern Timoth . rth, Esq. Supervising Attorney COMMUNITY LAW CLINIC 371 West South Street Carlisle, PA 17013 717-243-2968 • Kelah Pross, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY Mr. Jason Starner Defendant : NO. 2003-2605 CIVIL TERM 11 PRAECIPE TO PROCEED IN FORMA PAUPERIS s R y da 1 TO THE PROTHONOTARY: 0 Kindly allow Kelah Pross, Plaintiff/Petitioner, to proceed in forma pauperis. The Community Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date 16/! 7/ l 3 1.�i.fr McKenzie Cl„, Certified Legal Intern Timoth . rth, Esq. Supervising Attorney COMMUNITY LAW CLINIC 371 West South Street Carlisle, PA 17013 717-243-2968 Kelah Pross : IN THE COURT OF COMMON PLEAS OF Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION—LAW : IN CUSTODY Mr. Jason Starner , Defendant. : NO. 2003-2605 - ~' m ;L .--> • ORDER OF COURT r- == �" AND NOW, this Z2 day of October, 2013, it is ordered as follows: 1. The prior Orders of Court dated August 5, 2003, October 23, 2003, and October 27, 2006 are hereby vacated. 2. Plaintiff, Kelah Pross, hereinafter Mother is relocating to Las Vegas,NV with Tristan S. Starner, hereinafter Child. 3. The relocation shall take place on or sometime after October 17, 2013. 4. Mother and Child shall reside at Nellis Air Force Base. 5. Mother's husband, Mr. Stephen Pross, is in the Air Force and has been assigned to serve there. 6. The individuals who shall reside at the new address with Mother and Child are as follows: a. Stephen Pross, aged 23 b. Lorix Starner, aged 4 c. Maysileigh Pross, aged 6 weeks 7. Child shall attend school at Carrol M. Johnston Middle School in the Clark County School District. 8. Mother and Father shall share legal custody of the child. 9. Mother shall have primary physical custody of the child. Father shall have periods of partial physical custody of the child. 10. Father shall have custody of the Child for two consecutive weeks during the school's summer recess. 11. Mother and Father shall alternate custody during the school's Thanksgiving break and winter recess. On odd numbered years, Father shall have custody of the Child during the Thanksgiving break and Mother shall have custody of the Child during the winter recess. On even numbered years, Mother shall have custody of the child during the Thanksgiving break and Father shall have custody during winter recess. 12. Mother and Father shall each pay an equal share of the cost of transporting the Child for custody exchanges. 13. Mother and Father will notify each other of all medical care the Child receives while in the parent's care. Mother and Father will notify the other immediately of medical emergencies that arise while the Child is in that parent's care. 14. 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. 15. Neither party shall be permitted to relocate the residence of the children which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the children consents to the proposed relocation or the court approves the proposed relocation. A person proposing to relocate must comply with 23 Pa.C.S. §5337. BY THE COURT • . 4/ K; in A. Hess J. CO �ES fri tcL c..41 f)164t)a l aGJ�� ,C K. i�a..oss lO/ /i3 1 Kelah Pross, : IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner : OF CUMBERLAND COUNTY, Cs __ : PENNSYLVANIA c v. : CIVIL ACTION - LAW : IN CUSTODY L Mr. Jason Starner, _ Defendant/Respondent : No. 2003-2605 CIVIL TES PETITION TO CONFIRM RELOCATION PURSUANT TO PA R.C.P. 1915.17 AND NOW, this day of October 2013, pursuant to Rule 1915.17 of the Pennsylvania Rules of Civil Procedure, comes the Petitioner, Ms. Kelah Pross, by her attorneys, the Community Law Clinic, seeking to confirm the relocation of the minor child, Tristan S. Starner, born May 30, 2002. In support of her Petition to Confirm the Relocation, Petitioner avers the following: 1. Petitioner is Ms. Kelah Starner, who currently resides at 200 McLand Road, Mt. Holly Springs, PA 17065. 2. Respondent is Mr. Jason Starner, who currently resides at 152 2nd Street Apt. 1 Highspire, PA 17034 3. Petitioner is the biological mother of the Tristan S. Starner, hereinafter, the Child. 4. Respondent is the biological father of the Child. 5. The Child was born within wedlock. 6. Mother has been the primary caretaker of the Child since his birth. 7. The Child resides with Petitioner at 200 McLand Road, Mt. Holly Springs, PA 17065. 8. Child has been a resident of Cumberland County, PA for his entire life. • 9. A Custody Order signed by the Honorable Judge Hess was entered in this docket on October 27, 2006, (see Exhibit A). 10. Under the October 2003 Custody Order a. Petitioner and Respondent have shared legal custody of the Child b. Petitioner has primary physical custody of the Child c. Respondent has partial physical of the Child every Sunday from 11:00 AM to 7:00 PM. 11. Petitioner is moving to Las Vegas,NV with the Child. 12. Petitioner's husband, Stephen Pross, is in the United States Air Force, and has been assigned to Nellis Air Force Base, located in Las Vegas, NV 13. Respondent received the Notice of Relocation and the Counter-Affidavit on September 7, 2013, (see Exhibit B). 14. Earlier notice was impossible because Petitioner's husband only learned of his assignment in the middle of August. 15. Respondent signed and returned the Affidavit of Consent on September 24, 2013, (see Exhibit C). 16. Respondent does not object to the relocation and agrees to the custody schedule set forth in the attached proposed order. WHEREFORE, the Petitioner, Ms. Kelah Pross respectfully requests that this Honorable Court confirm the relocation of the Child, Tristan S. Starner and enter the proposed Custody Order. Respectfully submitted, /(`i� /0 3 Dat McKenzie rk Certified Legal Intern Timothy Ste.•'� Supervis' g Attorney COMMUNITY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013-2899 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing Petition to Confirm the Relocation are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: lb - is - 13 Kel Pross, Petitioner V KELAH N. STARNER, : IN THE COURT OF COMMON PL EVAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2003-2605 CIVIL TERM JASON S. STARNER, : CIVIL ACTION-LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW,this 21- day of OvaLu- , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated August 5, 2003 and October 23, 2003 are hereby vacated. 2. The Mother,Kelah N. Starner, and the Father, Jason S. Starner, shall have shared legal custody of Tristan S. Starner,born May 30,2002. Each parent shall have an equal right,to be exercised jointly with the other parent,to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health,education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information,that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician,dentist,teacher or authority and copies of any reports given to them as parents including,but not limited to: medical records,birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 3. Mother shall have primary physical custody of the child. 4. Father shall have periods of partial physical custody every Sunday from 11:00 a.m. to 7:00 p.m. 5. Father shall have a five-hour block of time with the child on Thanksgiving Day and Christmas Day at times agreed by the parties. 6. Father shall have physical custody of the child on the Saturday before Mother's Day from 11:00 a.m. to 7:00 p.m. instead of his Sunday time period on Mother's Day. 7. Father shall be responsible for all transportation 8. Neither party may partake in illegal drugs or consume alcohol to the point of intoxication immediately before or during their periods of custody. 9. The parties shall utilize an age and weight appropriate car seat for the child. 10. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent,the terms of this Order shall control. BY THE COURT, Kevin A. -ss, J. cci,S4 M. Shultz, Esquire, Counsel for Mother son S. Starner,pro se 848 Baltimore Pike Gardners, PA 17324 ' / 10 KELAH N. STARNER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2003-2605 CIVIL TERM JASON S. STARNER, : CIVIL ACTION-LAW Defendant : IN CUSTODY PRIOR JUDGE: Kevin A. Hess, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Tristan S. Starner May 30, 2002 Mother 2. A Conciliation Conference was held in this matter on October 24, 2006, with the following individuals in attendance: The Mother, Kelah N. Starner, with her counsel, Sean M. Shultz,Esquire and the Father,Jason S. Starner,pro se. 3. The Honorable Kevin A. Hess entered Orders of Court dated August 5, 2003 and October 23, 2003 providing for shared legal custody, with Mother having primary physical custody and Father having every Monday and Tuesday, supervised by Mother for two hours in the evening and every Sunday from 11:00 a.m. to 7:00 p.m. The Order anticipated going to alternating weekends once Father obtained his own dwelling or suitable sleeping arrangements for the child. Father asserted he had adequate sleeping arrangements, but Mother would not agree to overnights. Father was advised to file a Petition to Modify to request overnights. 4. The parties agreed to the entry of an Order in the form as attached. Date cq ine M. Verney, Esquire d Custody Conciliator rt,7- F LED--OFh.,, Or Tur- 2006 OCT 30 01 9: 0 4 CUMEL 4L COUNTY PENNSYLVANIA - 1`i 1«;,.. SENDER:COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY o- •-Complete items 1,2,and 3.Also complete A. Signature • item 4 if Restricted Delivery is desired. X • Print your name and ad dress on the reverse f�1, O Agent Addressee so that we can return the card to you. � • Attach this card to the back of the mailpiece, or on the front if space permits. rEELEMID.,7. I 1. Article Addressed to: D. Is delivery address different from item 1? ❑Yes If YES,enter delivery address below: ieTilo TOs©r) �'tai-rner /g., and$free- hp/. / /-41 hs,thi o1 PA / o3),-/ 3. Service Type Certified Mail ❑Express Mail .,'Registered O ietum Receipt for Merchandise ❑Insured Mail ❑C.O.D. 4. Restricted Delivery?(Extra Fee) ,Yes _ 2. 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Starner : CUMBERLAND COUNTY,PENNSYLVANIA Plaintiff v. : CIVIL ACTION—LAW : IN CUSTODY Jason Starner, Defendant. : NO. 2003-2605 CIVIL TERM COUNTER-AFFIDAVIT REGARDING RELOCATION This proposal of relocation involves the following child: Name Age Currently residing at: Tristan Starner 11 200 McLand Road Mt. Holly Springs, PA 17065 I have received a notice of proposed relocation and (check all that apply.) 1. (/ I do not object to the relocation. 2. V I do not object to the modification of the custody order consistent with the proposal for modification set forth in the notice. 3. () I do not object to the relocation,but I do object to the modification of the custody order. 4. () I plan to request that a hearing be scheduled by filing a request for hearing with the court: a. () Prior to allowing Tristan to relocate b. ( ) After the child relocates. 5. () I do object to the relocation. 6. () I do object to the modification of the custody order. I understand that in addition to objecting to the relocation or modification of the custody order above, I must also serve this counter-affidavit on the other party by certified mail, return receipt requested, addressee only, or pursuant to Pa.R.C.P No. 1930.4, and, if there is an existing custody case, I must file this counter-affidavit with the court. if I fail to do so within 30 days of my receipt of the proposed relocation notice, I understand that I will not be able to object to the relocation at a later time. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 (relating to unsworn falsification to authorities). l3 tido DA I(NATURE r /