HomeMy WebLinkAbout99-00943
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IN RE: )
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EDWARD ALLAN KEPNER, JR. )
and KELLEY ANNE KEPNER, both )
minors )
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 9 9. <) Y 3 tail r;.......
COMPLAINT FOR CHILD CUSTODY
AND NOW come Helen M. Caswell and Darlene L. Gump, Petitioners herein,
by their attorney, Samuel L. Andes, and petition the Court to confirm custody of the
above-named minors in them, based upon the following:
1. The Petitioner Helen M. Caswell is an adult individual who resides at 23
Maple Drive in Mechanicsburg, Cumberland County, Pennsylvania. She is the
maternal grandmother of the children who are the subject of this action.
2. The Petitioner Darlene L. Gump is an adult individual who resides at 101
Lynnwood Court in Camp Hill, Cumberland County, Pennsylvania, She is the
maternal aunt of children who are the subject of this action.
3. There is no Respondent in this action because there is no party having an
interest in the custOdy of the minor child other than the two Petitioners.
4, Petitioners seek an award of legal and physical custody of two minor
children, Edward Allan Kepner, Jr., age 14, born 22 September 1984, and Kelley
Anne Kepner, age 10, born 4 May 1988.
I 5. Since 1991, the said children have resided at the following locations with
I the follOWing persons: