HomeMy WebLinkAbout99-00938
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LAW OFFICES OF
1013 MUMMA ROAD, SUITE 100, LEMOYNE, PENNSYLVANIA 17043
.MAR .. 5 199~'
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GATES &-ASSOCIATES, P.C.
MAHLON J. KANN
VB.
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY
PENNSYLVANIA
DESIRE NICHOLE MILLIRON,
Defendant
NO. 1'4- tJ 3 g (}.-0~
ACTION FOR CUSTODY
ORDER
AND NOW, this Joth day of
(I?zc.o rch
, 1999, upon
consideration of the attached motion, it is hereby directed that
the parties and their respective counsel appear before
f\I\'lc..kc-1 L &lYl':J" f~ ' the conCiliator, at
60~ 5.IR"ll.$\., C(<""j1H~\l on the -9:::>IU day of
~x'\\ ,1999, at 3 or> o'clockn.m., for the
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Pre-Hearing Custody Conference. At such confer.ence, 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 ~~~ 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,
Dated: ':<-10-'19 BY: ~~.,/_g~~_
Custody Conciliator 1~
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.
OFFICE OF THE COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE, FOURTH FLOOR
CARLISLE, PENNSYLVANIA 17013
(717) 240-6200
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Jasmine Christine Kann is presently in the custody of the
Plaintiff, Mahlon J. Kann, who resides at 12 South Filbert Street,
Apt. C-12, Mechanicsburg, PA 17055.
4. Since the child's birth the child has resided with the
following persons at the following addresses:
PERSONS
Plaintiff, Defendant
ADDRESSES
12 South Filbert Street
pATES
6/25/98 - 9/98
Apt. C-12, Mechanicsburg, PA
Plaintiff
12 South Filbert Street
9/98 to Present
Apt. C-12, Mechanicsburg, PA
5. The Mother of the child, is the Defendant, JASMINE NICHOLE
MILLIRON, who currently resides at 312 Market Street, Lemoyne,
Cumberland County, PA 17043.
The Mother is single.
6. The Father of the child is the plaintiff, Mahlon J. Kann,
who currently resides at, 12 South Filbert Street, Apt. C-12,
Mechanicsburg, PA 17055.
The Father is single.
7. The relationship of the Plaintiff to the child is that of
natural Father. The Plaintiff currently resides with the following
persons:
NAME
Jasmine Christine Kann
RELATIONSHIP
Daughter
8. The relationship of the Defendant, Desire Nichole Milliron
to the child is that of natural Mother. The Defendant currently
resides with the following person:
NAME
Michael White
RELATIONSHIP
Paramour of Defendant
9. The Defendant-petitioner 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.
10. The best interests and permanent welfare of the child
will be served by granting the relief requested because:
A. Plaintiff has been the primary caretaker of his
daughter since her birth;
B. Plaintiff has demonstrated a loving, continuous
and strong interest in his daughter and desire to be a
caring and responsible father to his daughter;
C. plaintiff has demonstrated the ability to
provide his daughter with a stable and secure physical,
3
emotional and financial environment;
E. Defendant has not demonstrated any interest in
providing the stable and secure, physical, emotional and
financial her daughter needs, since her birth;
F. Plaintiff believes it is in the best interests
of his daughter to have a meaningful, ongoing secure and
predictable relationship with both her natural parents.
11. Each parent whose parental rights to the child have not
been terminated and the persons who have physical custody of the
child have been named as parties to this action.
WHEREFORE, Plaintiff, MAHLON J. KANN, respectfully requests
this Honorable Court to enter an Order:
A. Awarding Plaintiff Full Legal Custody of his
minor daughter, Jasmine Christine Kann;
B. Awarding Plaintiff primary physical Custody of
his minor daughter, Jasmine Christine Kann;
C. Awarding Defendant Partial physical
Custody of the parties' minor child for such liberal and
regular visitation as can be arranged and agreed upon by
the parties.
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MARLON J. KANN,
PLAINTIFF
VS.
DESIRE NICROLE MILLmON,
DEFENDANT
AND NOW, this 1 f ~ay of
: IN TRE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 99-938
: ACTION FOR CUSTODY
tr1
, 1999, upon consideration of
the attached Stipulation for Agreed Order of Custody, the attached agreement is approved with
the same effect as though incorporated at length herein,
Susan Kay Candiello, Esquire
Gates & Associates, PoC,
1013 Mumma Road, Suite 100
Lemoyne, P A 17043
Attorney for Plaintiff
Desire Nichole Milliron
312 Market Street
Lemoyne, PA 17043
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