HomeMy WebLinkAbout01-05805
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Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 0/- SPoS" GOlL 'T~
CIVIL ACTION - LAW
TANYA KELLER,
v,
RANDY KELLER,
IN CUSTODY
Defendant.
ORDER
AND NOW, this day of ,2001, upon
consideration of the attached Complaint, it is hereby directed that the parties and their respective
counsel appear before , the Conciliator, at
, on , the day
of , at o'clock _,m" for a Pre-Hearing
Custody Conference, At such conference, an effort will be made to resolve the issues in dispute;
or ifthis cannot be accomplished, to define and narrow the issues to be heard by the Court, and to
enter into a temporary Order. All children age five or older may also be present at the conference,
Failure to appear at the conference may provide grounds for entry of a temporary or permanent
Order.
FOR THE COURT,
By
Custody Conciliator
YOU SHOULD TAKE TIDS PAPER TO YOUR LAWYER AT ONCE, IF
YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, 4TH FLOOR
CARLISLE, P A 17013
(717) 240-6200
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Plaintiff,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO: 01- .{"'POS Go~[Y~
T ANY A KELLER,
v,
: CIVIL ACTION - LAW
RANDY KELLER,
Defendant.
COMPLAINT TO CONFIRM CUSTODY
AND NOW, comes your Plaintiff, Tanya Keller, by and through her
attorneys, Mancke, Wagner, Hershey & Tully, and files the following Complaint to
Confirm Custody:
1, The Plaintiff, Tanya Keller, is an adult individual currently residing at
1227 Trindle Road, Carlisle, Cumberland County, Pennsylvania.
2, The Defendant, Randy Keller, is an adult individual currently residing at
99 WoIfes Bridge Road, Carlisle, Cumberland County, Pennsylvania.
3, Plaintiff and Defendant were married June 15, 1994,
4, The parties separated approximately the third week of September of 200 1 ,
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5, The parties are the natural parents of Allison Keller, born September 13,
1994. The Plaintiff is the natural mother of Allison, and the Defendant is the natural
father of Allison.
6, The child was born during wedlock; and has resided with the parties up
until separation at 1227 Toodle Road, Carlisle, Cumberland County, Pennsylvania,
home of the mother,
7, Since separation, separation in the fonn of the father leaving the marital
home, the child has remained with the Plaintiff, her natural mother,
8, Plaintiff knows of no other party having an interest in the custody or
partial custody of Allison,
9, Plaintiff believes and therefore avers that it is in the best interest of Allison
to confirm primary custody of Allison in the Plaintiff.
10, Plaintiff believes that Defendant should have periods of partial custody.
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WHEREFORE, Plaintiff prays this Court to grant primary custody of Allison
unto Plaintiff subject to periods of partial custody in Defendant.
Respectfully submitted,
Mancke, Wagner, Hershey & Tully
By
/' P. Richard er, Esquire
, 3103
2233 North Front Street
Harrisburg, P A 17110
(717) 234-7051
Attorneys for Petitioner
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VERIFICATION
I verify that the statements made in the foregoing
document are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Fa.C.S,
Section 4904, relating to unsworn falsification to authorities.
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TANYA KELLER
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
01-5805 CIVIL ACTION LAW
RANDY KELLER
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Friday, October 12, 2001
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective cmIDse! appear before Melissa P. Greevy, Esq.
at 214 Senate Avenne, Suite 105, Camp Hill, PA 17011 on Wednesday, November 14, 2001
, the conciliator,
at 12:30 PM
for a Pre-Hearing Custody Conference, At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference, Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The conrt hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR TIlE COURT,
By: Isl
Melissa P. Greevy. Esq. ~f\I\.
Custody Conciliator I
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
alvailable to disabled individuals having business before the court, please contact our office. All arrangements
lnust 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
1-IA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE 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
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CUMBERLAND COUNTY
PENNSYlVANIA
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T ANY A KELLER,
Plaintiff,
v,
RANDY KELLER,
Defendant.
AND NOW, this S"'" day of
, ,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO: cJl~ 5f05 a;I
: CIVIL ACTION - LAW
ORDER
(J c.h low"
, 2001, upon Petition of
Tanya Keller, natural mother of Allison Keller, born September 13,1994, custody of
Allison is hereby temporarily awarded to the mother pending.Dljt"'''"'egfthe ~g'u:t .
flr5eeet:iH3gg as it relates te eMstoay of Adlis8B. pc...eJ..",-, .fi,~ ~
Father shall have reasonable periods of partial custody, pending further Order
of Court,
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TANYA KELLER,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
Plaintiff,
v,
: NO: ~ 1- Qga6- CiX.f)
: CIVIL ACTION - LAW
RANDY KELLER,
Defendant.
EMERGENCY PETITION FOR CONFmMATION OF CUSTODY
AND NOW, comes your Petitioner, Tanya Keller, by and through her
attorneys, Mancke, Wagner, Hershey & Tully, and files the following Emergency
Petition for Confirmation of Custody:
1, Your Petitioner, Tanya Keller, is an adult individual currently residing at
1227 Toodle Road, Carlisle, Cumberland County, Pennsylvania,
2, The Respondent, Randy Keller, is an adult individual currently residing at
99 Wolfes Bridge Road, Carlisle, Cumberland County, Pennsylvania.
3, Petitioner and Respondent were married June 15, 1994,
4, The parties separated approximately the third week of September of 200 1 ,
5, The parties are the natural parents of Allison Keller, born September 13,
1994,
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6, The child was born during wedlock; and has resided with the parties up
until separation at 1227 Toodle Road, Carlisle, Cumberland County, Pennsylvania,
home of the mother.
7 , Since separation, separation in the fonn of the father leaving the marital
home, the child has remained with the Petitioner, her natural mother.
8, On October 2, 2001, Petitioner and Respondent engaged in an argmnent
that led to an altercation.
9, The Petitioner herein anticipates that the Respondent is going to attempt to
file a PF A, and seek temporary innnediate custody of Allison, despite the fact that
Allison has been residing with the Petitioner herein since the time of separation,
10, Petitioner believes and therefore avers that it is in the best interest of
Allison to confinn primary custody of Allison in the Petitioner, pending outcome of
any further proceedings in custody and/or the anticipated protection from abuse
proceeding, which Petitioner believes Respondent may be filing,
11, Petitioner believes that Respondent should have periods of partial
custody pending outcome and/or resolution of the above matters,
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WHEREFORE, Petitioner prays this Court to grant immediate temporary
primary custody of Allison unto Petitioner pending outcome of proceedings in this
custody matter as well as the anticipated PF A matter.
Respectfully submitted,
Mancke, Wagner, Hershey & Tully
p, Richard Wa , Esquire
LD, #23
North Front Street
Harrisburg, PAl 7 I 10
(717) 234-7051
Attorneys for Petitioner
Date: I tJ/ LfjcJ }
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VERIFICATION
I verify that the statements made in the foregoing
document are true and correct, I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unsworn falsification to authorities.
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5805
TANYA KELLER,
vs.
Defendant
CIVIL ACTION - LAW
CUSTODY
RANDY KELLER,
ORDER TO RELINQUISH JURISDICTION
AND NOW, this 10th day of November, 2001, the Conciliator, having been notified by
counsel for the Petitioner that the parties have reconciled, hereby relinquishes jurisdiction of
the above-referenced custody matter.
FOR THE COURT,
Melissa Peel Greevy, Esquire
Custody Conciliator
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