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HomeMy WebLinkAbout99-07251N h 1 Z ELIZABETH K. LONG, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA NO. V. CIVIL ACTION -CUSTODY KEITH A. LONG, Defendants. ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the e?C OL? L the parties and their respective counsel appear before Conciliator. on.the aA day of K la l? aW_ at % , in the CGh ?? ----, for the Pre-Hearing Custody Conference. At such coriference', alt 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 shall also have the option of being present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent Order. For the Court, Date: BY t! o t1YU '1?LlY?' Custody Concilia or m,l 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Court Administrator 4°i Floor, Cumberland County Courthouse Carlisle, PA 17013 al'al /?•??7? ?J?/a'CGG?/c?2r.FL'a? G' // ELIZABETH K. LONG, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. r%9.7xSl ?t KEITH A. LONG, Defendant. : CIVILACTION- CUSTODY NOTICE TO CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your child. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, 23 East Market Street, Cumberland, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICES Court Administrator 4°i Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 ELIZABETH K. LONG, : IN TI4E COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 9 9. 7-2 ?5'/ C'r', ' Te._ KEITH A. LONG, Defendant. : CIVIL ACTION- CUSTODY COMPLAINT FOR CUSTODY Plaintiff, ELIZABETH K. LONG, by and through her attorney Gerald S. Robinson, Esquire, and the law firm of ROBINSON & GERALDO, respectfully requests the following: 1. Plaintiff is ELIZABETH K. LONG, an adult individual and the natural mother who currently resides at 16 Robin Court, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is KEITH A. LONG, an adult individual and the natural father who currently resides at 16 Robin Court, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of Keith A. Long 11 born on August 20, 1999, residing at 16 _i Robin Court, Mechanicsburg, Pennsylvania with Plaintiff and Defendant. The child was not born out of wedlock. 4. The child is presently in the custody of Plaintiff, ELIZABETH K. LONG, and Defendant, Keith A. Long, who currently reside at 16 Robin Court, Mechanicsburg, Pennsylvania. 5. From birth to present, the child has resided at 16 Robin Court, Mechanicsburg, Pennsylvania. 6. The mother of the child is Plaintiff, ELIZABETH K. LONG, currently residing at 16 Robin Court, Mechanicsburg, Pennsylvania. She is married. 7. The father of the child is KEITH A. LONG, whose currently resides at 16 Robin Court, Mechanicsburg, Pennsylvania. He is married. S. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 9. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 10. 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. t 11. The best interest and permanent welfare of the child will be served by awarding custody to Plaintiff. 12. 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 a party to this action. WHEREFORE, the Plaintiff respectfully requests this Honorable Court to grant custody to Plaintiff. Respectfully submitted: ROBINSON & GERALDO By erald S. Robinson, Esquire Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110 (717) 232-3525 Attorney for Plaintiff VERIFICATION I verify that the statements made in this Complaint 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. Elizabet K. L ?g, I< of f CI:RTIFICATEOFSERVICE ,,..,,? I, Gerald S. Robinson, Esquire, do hereby certify that on the 11 day of December, 1999, 1 caused a true and correct copy of the Complaint to be served upon the rullowing individual by certified mail restricted delivery to addressee only by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. Keith A. Long 16 Robin Court Mechanicsburg, PA 17055 Respectfully submitted, ROBINSON & GERALDO By: Gerald S. Robinson, Esquire Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717)232-8525 ELILABETI I K. LANG, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99-7251 Civil KEITH A. LONG, Defendant. : CIVIL ACTION- CUSTODY PROOF OF SERVICE Counsel lift Defendant acknowledged receipt of the Complaint in Divorce filed on December 1, 1999. Proof of service is evidenced by the Acceptance of Service signed by Kristen Cl, Donsen, Esquire attached hereto as Exhibit A. Respectfully submitted, ROBINSON & GERALDO By: Auz Gerald S. Robinson, Esquire Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff ELIZABETH K. LONG, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-7251 KEITH A. LONG, Defendant. CIVIL ACTION- CUSTODY ACCEPTANCE OF SERVICE I, KRISTEN G. DONSEN, ESQUIRE certify that I accepted service of the Complaint in Custody that was filed on December 1, 1999 on behalf of the Defendant, Keith A. Long. Date (ZI2(?l l?l `-? 'Q i Knsten G. Donse , squire 200 North Hanover Street Carlisle, PA 17013 A ELIZABETH K, LONG, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-7251 KEITH A. LONG, Defendant. CIVILACTION- CUSTODY ACCEPTANCE OF SERVICE I, KRISTEN G. DONSEN, ESQUIRE certify that I accepted service of the Complaint in Custody that was tiled on December 1, 1999 on behalf of the Defendant, Keith A. Long. Date 12-1 2,0 l q IG Kristen G. Denser , squire 200 North Hanover Street Carlisle, PA 17013 _ 51-- ELIZABETH K. LONG, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBEIZLAND COUNTY, PENNSYLVANIA v. : NO. 99-7251 Civil KEITH A. LONG, Defendant. : CIVIL ACTION- CUSTODY PROOF OF SERVICE Counsel for Defendant acknowledged receipt of the Complaint in Custody filed on December 1. 1999. Proof of service is evidenced by the Acceptance of Service signed by Kristen G. Donsen, Esquire attached hereto as Exhibit A. Respectfully submitted, ROBINSON S GERALDO By:*-? Gerald S. Robinson, Esquire Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-3525 Attorney for Plaintiff ELIZABETH K. LONG, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-7251 KEITH A. LONG, Defendant. : CIVIL ACTION- CUSTODY ACCEPTANCE OF SERVICE I, KRISTEN G. DONSEN, ESQUIRE certify that I accepted service of the Complaint in Custody that was filed on December 1, 1999 on behalf of the Defendant, Keith A. Long. Date (zi 2 0[ q(' Knsten G. Donse , squir ts 200 North Hanover Street Carlisle, PA 17013 Exhibit ELIZABETH K. LONG, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-7251 Civil KEITH A. LONG, Defendant. CIVIL ACTION- CUSTODY PROOF OF SERVICE Counsel for Defendant acknowledged receipt of the Complaint in Custody tiled on December 1, 1999. Proof of service is evidenced by the Acceptance of Service signed by Kristen G. Donsen, Esquire attached hereto as Exhibit A. Respectfully submitted, ROBINSON & GERALDO By: 9 Gerald S. Robinson, Esquire Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-3525 Attorney for Plaintiff ELIZABETH K. LONG, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-7251 KEITH A. LONG, Defendant. : CIVIL ACTION- CUSTODY ACCEPTANCE OF SERVICE I, KRISTEN G. DONSEN, ESQUIRE certify that I accepted service of the Complaint in Custody that was filed on December 1, 1999 on behalf of the Defendant, Keith A. Long. Date Z 2(? I l l ) 4OOsNorth en G. Donse , sqHanover Street Carlisle, PA 17013 Exhi it•?. VIAY 1 8 200 ELIZABETH K. LONG, Plaintiff VS. KEITH A. LONG, Defendant IN THE COUR'r OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7251 CIVILTERM CIVIL ACTION - LAW ORCyn AND NOW this ) day of 2000, it being reported to the Conciliator that the parties have reached an agreement which makes further proceedings unnecessary, the undersigned Conciliator hereby relinquishes jurisdiction and returns the matter to the Court Administrator. If either of the parties wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, I'ju ?_. AEL L. BANGS Custody Conciliator Gerald S. Robinson, Esquire Bradley L. Griffie, Esquire C^ U, C,• ?'`? it .. ,Cr=? ri'. r-?`; LCa1:?_ L'?' C`? i:' (, ``: ,,,_,i i' ELIZABETH K. LONG, Plaintiff, V. KEITH A. LONG, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7251 CIVIL TERM CIVIL ACTION-LAW CUSTODY PRAECIPE TO DISCONTINUE To the Prothonotary: Kindly discontinue the above action as to all parties, without prejudice, due to the following: ( X ) Agreement by all parties ( ) Failure of plaintiff to appear at conference Respectfully submitted, ROBINSON & GERALDO By: C>?.- t IL erald S. Robinson, Esquire Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717) 232-8525 Attorney for Plaintiff JUL 2 6 20 ELIZABETH K. LONG, ) IN THE COURT OP COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. ) NO. 99-7251 CIVIL TERM KEITH A. LONG, ) Defendant ) CUSTODYNISITATION ORDER AND NOW, this )S tA' day of C&A 2000, it being reported to the Conciliator that the Plaintiff has filed a Praecipe to Discontinue which makes further proceedings unnecessary, the undersigned Conciliator hereby relinquishes jurisdiction and returns the matter to the Court Administrator. If either party wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, ?Y MICHAEL L. BANGS Custody Conciliator Gerald S. Robinson, Esquire Bradley L. Griffie, Esquire ,, } i' ?? „-.., }?. -. _? ?,- .,; "cf .. , _; ,. ;., , ... ;. .