HomeMy WebLinkAbout07-3794CHANDLER A. KAZOR, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
• U 7- 37 ~ y
v. :NO. -2007 CIVIL ACTION LAW
ANISA D. AMES,
Defendant : IN CUSTODY
COMPLAINT FOR CUSTODY
1. The plaintiff is Chandler A. Kazor, residing at 33 Watson Blvd, Apt. B, Pittsburgh,
Allegheny County, Pennsylvania 15214.
2. The defendant is Anisa D. Ames, residing at 236 N. Baltimore Avenue, Apt. 9, Mt. Holly
Springs, Cumberland County, Pennsylvania 17065.
3. Plaintiff seeks custody of the following child:
Name Present Residence DOB Age
Kennedy E. Ames 236 N. Baltimore Avenue 03/22102 5
Apt. 9
Mt. Holly Springs, PA
The child was born out of wedlock.
The child is presently in the custody of Anisa D. Ames, who resides at 236 N. Baltimore
Avenue, Apt. 9, Mt Holly Springs, Cumberland County, Pennsylvania.
During the past five years, the child has resided with the following persons and at the
following addresses:
List All Persons List All Addresses Dates
Anisa D. Ames 236 N. Baltimore Avenue 2/07 -Present
Apt. 9
Mt. Holly Springs, PA
Anisa D. Ames Wichita, Kansas 3/02-2/07
4. The mother of the child is Anisa D. Ames, currently residing at 236 N. Baltimore
Avenue, Apt. 9, Mt. Holly Springs, Pennsylvania 17065.
She is not married.
5. The father of the child is Chandler A. Kazor, currently residing at 6163 Mountain View
Drive, Chambersburg, Pennsylvania 17201.
He is married.
6
7
9.
The relationship of plaintiff to the child is that of father.
The plaintiff currently resides with the following persons.
Name
Jamie N. Kazor
Paige L. Giffin
Relationship
Wife
Stepdaughter
The relationship of defendant to the child is that of mother.
The defendant currently resides with the following persons.
Name
Kennedy E. Ames
Relationship
Daughter
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 but there is a
Custody Order in Kansas.
Plaintiff has no information of a custody proceeding concerning the child pending in a
court of this Commonwealth.
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.
The best interest and permanent welfare of the child will be served by granting the relief
request because:
Plaintiff is capable of performing the primary parental responsibilities for the child.
Plaintiff is best able to provide the care and nurture which the child needs for healthy
development.
A Court Order of custody and structured visitation is desired so that the Plaintiff and the
child may play their schedules accordingly, and so that misunderstandings and unmet
expectations regarding custody and visitation can be avoided, and also so that the child is
not used in a manipulative fashion.
A Court ordered determination of custody is required to avoid continuing conflict
between the parties regarding parental responsibility for custody and support.
10. 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 parties to this action. All other
persons named below, who are known to have or claim a right to custody or visitation of
the child will be given notice of the pendency of this action and the right to intervene:
Name
N/A
Address
Basis of Claim
WHEREFORE, Plaintiff requests this Court grant him primary physical custody with
visitation vested in the mother or agreed upon by the parties.
Respectfully submitted,
ROMINGER & ASSOCIATES
Date: ~ Z-~'~'~
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Michael O. Palermo, r., Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 93334
Attorney for Plaintiff
VERIFICATION
I verify that I am the petitioner and that the statements made in the foregoing Petition 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 tc, anthnrir;ec
Date: ~ "2 ~~ 7
Chandler A. Kazor/Plaintiff
CHANDLER A. KAZOR, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v :NO. -2007 CIVIL ACTION LAW
ANISA D. AMES, ,
Defendant : IN CUSTODY
CERTIFICATE OF SERVICE
I, Michael O. Palermo, Jr., Esquire, attorney for Plaintiff do hereby certify that I this day
mailed a copy of the within Motion upon the following by depositing same in the United States
mail, postage prepaid, at Cazlisle, Pennsylvania, addressed as follows:
Anisa D. Ames
236 N. Baltimore Avenue
Apt. 9
Mt. Holly Springs, Pennsylvania 17065
Date: ~a! ~~
.---
Michael O. Palermo, Jr., ire
155 South Hanover Street
Cazlisle, PA 17013
(717) 241-6070
Supreme Court ID # 93334
Attorney for Plaintiff
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CHANDLER A. KAZOR IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
v.
ANISA D. AMES
DEFENDANT
• 07-3794 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Monday, July 02, 2007 ,upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. ,the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, July 26, 2007 at Z:00 PM
for aPre-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 ale 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 hearing.
FOR THE COURT,
By: /s/ ohn .Man an r. Es .
Custody Conciliator
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
available to disabled individuals having business before the curt, 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 ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YUU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717} 249-3166
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CHANDLER A. KAZOR,
Plaintiff
v.
ANISA D. AMES,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0.07-3794 CIVIL TERM
IN CUSTODY
PRELIMINARY OBJECTIONS OF DEFENDANT TO PLAINTIFF'S COMPLAINT FOR
CUSTODY
AND NOW, comes Defendant, Anisa Ames, by and through her attorneys, MidPenn
Legal Services, and files these Preliminary Objections to Plaintiff's Complaint for Custody and
in furtherance thereof states as follows:
1. This matter has not been presented before any judge in Cumberland County.
2. Plaintiff, Chandler A. Kazor, hereinafter "Father," and Defendant, Anisa
Ames, hereinafter "Mother," are the natural parents of one minor child,
Kennedy E. Ames, born March 22, 2002.
3. On March 1, 2005, the Sedgwick County Court -Family Law Department in
Kansas entered a "Journal Entry of Judgment and Decree of Paternity" in
regard to the minor child, Kennedy Ames. In pertinent part, that document
determined Father's obligation to provide care for Kennedy based on a
paternity determination and determined that Mother should be granted sole
custody and designated Mother as the sole residential custodian of the minor
child with the right to determine the child's physical residence. Father was
deemed obligated to provide child support for the minor child and was granted
periods of partial custody with the child. A copy of the Order and Consent
Agreement is attached hereto and incorporated herein by reference as Exhibit
«A „
4. Based on Father's promise to pay Mother's rent, Mother moved, with the
minor child, to Pennsylvania on a trial basis. She and the minor child have
been in Cumberland County, Pennsylvania for less than six months.
5. Father has never fulfilled his promise to pay Mother's rent and he has
provided no support for the minor child.
6. Since Father elected to move from his home in Franklin County, Pennsylvania
to Pittsburgh, Allegheny County, Pennsylvania, Mother intends to return, with
the minor child, to their home in Wichita, Kansas. Mother's entire extended
family lives in Kansas and she would have extensive financial, emotional,
mental and moral support for herself and the minor child if she returned home.
7. At no time has either party sought to transfer this custody matter to
Cumberland County, Pennsylvania and the Sedgwick County Family Law
Department in Kansas retains jurisdiction over this matter.
8. Father is also subject to a Child Support Order entered on June 11, 2007, in
Cumberland County, Pennsylvania. Only after Mother sought court-ordered
support from Father did he initiate a custody proceeding seeking primary
custody of the minor child. A copy of the Child Support Order is attached
hereto and incorporated herein by reference as Exhibit "B."
9. This matter has been scheduled for a custody conciliation on July 26, 2007,
with Attorney John Mangan.
10. Pursuant to the Uniform Child Custody Jurisdiction Enforcement Act 23
Pa.C.S. § 5421 et seq, this Court should not exercise jurisdiction in this
matter. Jurisdiction of this matter properly remains in Kansas State.
11. Father did not object to the entry of the document as a Kansas Order and
should be precluded from asserting that Cumberland County is the proper
venue to resolve any current custody matters.
12. Mother has contacted Father's attorney, Michael O. Palermo, Jr., Esquire to
determine whether he concurs to the relief requested. Since Attorney Palermo
is presently out of the office, Mother's counsel is unable to determine whether
he does or does not concur with the relief requested.
WHEREFORE, Mother requests that this Court dismiss Father's Complaint for Custody,
based on the fact that Kansas retains jurisdiction over this matter and remains the proper
venue in which to file further proceedings if Father wishes to modify the current custody
order. Mother further requests that this Court stay its July 2, 2007, Order scheduling this
matter for a custody conciliation on July 26, 2007.
y Submitted,
J s~lca Fiolst, Esquire
idPenn Legal Services
401 East Lowther Street
Carlisle, PA 17013
(717) 243-9400 x2514
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CHANDLER A. KAZOR,
Plaintiff
v.
ANISA D. AMES,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0.07-3794 CIVIL TERM
IN CUSTODY
CERTIFICATE OF SERVICE
I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for the Defendant, Anisa
Ames, hereby certify that I have served a copy of the foregoing PRELIMINARY OBJECTIONS
OF DEFENDANT TO PLAINTIFF'S COMPLAINT FOR CUSTODY on the following date and
in the manner indicated below:
U.S. First Class Mail, Postage Pre-Paid
Michael O. Palermo, Jr., Esquire
155 South Hanover Street
Carlisle, PA 17013
Date: ~ ` ~~- ~"
Jessic~lst, Esquire
MidP nn Legal Services
401 E. Lowther Street
Carlisle, PA 17013
(717) 243-9400
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KANSAS LEGAL SERVICES
Attorneys at Law ~" ' "' _
200 N. Broadway, Suite 500
Wichita, Kansas 67202 ; ''„~- - f ~~. =' __ f j,
Telephone: (316) 265-9b81 _
IN TIIE EIGI~TEENTI3 JUDICIAL DISTRICT DISTR~.~T ~QX7~~
SEDGWICK COUNTY, KANSAS
~'AVIILY LAW DEPAiRTlY1E~1T _ .. _._ __ _ _ ...____ ....__ _ ...__.. .
KENNEDY E. ANTES, a minor child,
by and through her mother
ANISA DAWN AMES
Petitioner
and
CHANDLER KAZOR
Pursuant to Chapter 60 of
Kansas Statutes Annotated
Respondent
Case No. ~~ DM 7557
.Jt~URNAL E~iTRY flF JUDG~NT AND ~ECREE OF PATERNITY
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NOW ON THIS '~"' day of ~ L/~.~~-C-~~, 2005 the above-captioned matter
comes on for hearing. The Petitioner appears by Affidavit and by and through her attorney,
Kansas Legal Services. The Respondent does not appear.
WHEREUPON, the Court, after e:camining the file and pleadings herein, finds:
1. That the Petition has been on file for more than si;cty (60) days;
2. That personal service was obtained upon the Respondent;
3. That the Petitioner is the father of the minor child, Kennedy E. Ames, dob 3-22-
O2, with the obligation to provide care of Che minor child.
~. That the statements in the Petition are true
THEREUPON, the Petitioner introduces testimony acid rests and there being no
testimony on behalf of the Respondent, the Court finds:
1. That a new birth certificate shall be issued to reflect that Chandler Kazor is the
father of the minor child, Kennedy E. Ames.
s
04 DM 7557
A. Ames and C. Kazor
2. That the Court finds that the Proposed Parenting Plan is in the best interest of the
minor child. That the Petitioner is a fit and proper person to have custody of the minor child and
should be granted sole custody.
3. That the Petitioner should be designated as the sole residential custodian of the
minor child, with the right to determine the physical residence.
a. The Petitioner and Respondent have been advised that, at
least 30 days prior to changing their residence or removing
the minor child from Kan;;as for more than 90 continuous
days, written notice must be sent by restricted mail, return
receipt requested, to the other parties last known address.
b. The Petitioner and Respondent have also been advised that
failure to provide the notice described in paragraph 6(a)
above, may result in the imposition of sanctions by the
Court, including indirect civil contempt, assessment of
attorney tees and modification of a prior order of child
support or custody.
c. A change of the residence or removal of a child as
described in subsection (a) may be considered a material
change of circumstances which justifies modification of a
prior order of legal custody, residency, child support or
parenting time.
d. A parent entitled to the legal custody or residency of a child
pursuant to K.S.A. 60-1 b 10 shall not be required to give
notice required by this section to-the other parent when the
other parent has beer. convicted of any crime specified in
article 34,35,or 36 of Chapter 1 of the K.S.A. in which the
child is the victim of such crime.
4. That the Respondent shall have reasonable parenting time with the child with
dates and times to be agreed upon by the parties. The first three visits shall occur in the State of
Kansas. The Respondent shall pay for all travel costs associated with his parenting time.
Holiday parenting time shall be as follows: the minor child shall be spend Christmas with
Respondent in odd numbered years, every spring break, and one week during the summer to be
agreed upon bye the parties.
04 DM 7557
A. Ames and C. Kazor
5. That the Respondent is ordered to pay child support as in Court of Common Pleas
of Franklin County, Pennsylvania, case number 85810813.
6. That an income withholding order shall be issued by the Court forthwith. The
income withholding order shall require any payor of income to Chandler Kazor to withhold
income each pay period in necessary and lawful amounts to pay the current support obligation
(and to reduce accrued arrearage).
7. That, until the commencement of the withholding by a payer/employer, the
obligor shall pay all support payments required by the support order. Payments shall be remitted
by the obligor to the Kansas Payment Center on or before the due date specified in the order.
8. That in accordance with K.S.A. 60-1610, wherein child support shall continue
beyond the time the minor child reaches eighteen (18) years of age before completing their high
school education, the support shall not terminate, unless otherwise ordered by the Court, until
June 30 of the school year during which the minor child becomes ~ eighteen (18) years of age, if
said child is attending high school.
9. That the Petitioner shall be entitled to claim the minor child as her dependent for
the purpose and calculation of Federal and State income taxes for the year of 200 and for all
years thereafter until modified by Court Order. That the Court reserves the jurisdiction to
modify the division of the tax exemptions for the minor child at a later date.
10. That the Respondent shall maintain medical insurance on the minor child if
available through his employer and the parties shall share any medical, optometry, dental, or
psychological costs for the minor child not covered by insurance in proportion to their income.
11. That Kansas Legal Services, upon oral motion, requests that the Court allow it to
withdraw as attorney of record for the Petitioner in this action, upon filing of the Paternity decree
in this action.
12. That the Petitioner makes no objection to Kansas Legal Services' motion to
withdraw.
' U4 DM 7557
A. Ames and C. Kazor
IT IS, THEREFORE, BY THE COURT, CONSIDERED, ORDERED, ADJUDGED,
AND DECREED that Kansas Legal Services' motion to withdraw as attorney of record for the
Petitioner in this action is sustained.
IT IS SO ORDERED.
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JUDGE
SUBMITTED BY:
KAtVSAS LEGAL SERVICES
Sullivan, #15498
dr Petitioner
Anisa Dawn Ames, Petitioner
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KANSAS LEGAL SERVICES ::.; ~};~.-~~:•; ~-- ~ -,
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200 North Broadway, Suite 500 ~ ~ ~ ~.~E ~ ~~~
Wichita, Kansas 67202
Telephone: (316) 265-9651 ~ `~ --
IN THE EIGHTEENTH JUDICIAL DISTRICT , .,.
DISTRICT COURT, SEDGWICK COUNTY, ~KA~NSAS 1`, -,;' ~ ::...
FAMILY LAW DEPARTMENT ~ ~ ~ ,, .., .,
K~NNr;llY ~. A1Vl~J, a minor cnila, ny
and through her mother,
ANISA DAWN AMES
CASE NO. 04 DNI 7557
and
CHANDLER K.AZOR
PARENTING PLAN
[X] FINAL (FPP)
This parenting plan is:
[ x ] a plan proposed by Petitioner, Anisa Dawn Ames
I. GENERAL INFORViATION
This parenting plan applies to the following children: Kennedy E. Ames
Children of the Parties as listed in the Petition for Paternity in the above
captioned matter.
II. Legal Custody and Decision Making
[ ] 2.2 Sole Legal Custody.
It is not in the best interests of the child that both parents have equal rights to make
decisions regarding the child. The patent granted sole legal custody has the primary right to decide
matters regarding matters of health, education and welfare in the child's best interests. The parent
not granted sole legal custody may make emergency decisions affecting the health or safety of the
child when the child are in that parent's physical care and control. The grant of sole legal custody
to one parent does not deprive the other parent of access to information regarding the child unless
the court shall so order, stating the reasons for that determination.
[ ] 2.21 Grant of Sole Decision Making to Parent. Sole legal custody should
be ordered to the [X] mother [ ]father for the following reasons:
( ]The other parent is unable to exercise any decision-making authority for the following
reasons: The Respondent is out of State. ~
SCHEDULE A. Residency And Parenting Time
SCHEDULE 1. Other Provisions
r
A. Residency of the minor children of the parties shall be as stated in the Journal Entry
and Decree of Paternity as issued by this Court in this matter.
B . Parenting time with the parent the minor children do not reside with shall be as
follows:
Times and dates as mutually agreed upon by the parties and outlined in the Journal
Entry and Decree of Paternity issued in this matter
DECLARATION FOR PROPOSED PARENTING PLAN
[ ] Does not apply.
[x] (Only sign if this is a proposed parenting plan.) I declare under penalty of perjury under
the laws of the State of Kansas that this plan has been proposed in good faith and that the
statements in this Plan are true and correct.
VIII. ORDER B'~ THE COURT
It is ordered, adjudged and decreed that the parenting plan set forth above is adopted and approved
as an order of this court.
When mutual decision making is designated but cannot be achieved, the parties shall make a good
faith effort to resolve the issue through the dispute resolution process.
If a parent fails to comply with a provision of this plan, the other parent's obligations under the
plan are not affected.
Dated:
Judge
Presented 'oy:
t-ky i
Anita-Da.~vn Ames, Petitioner'
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a ~ Sul ~ rt'~1~948
1~' f . ~ e Petitioner
Y ~ In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
ANI SA D. AME S ) Order Number 0 0 4 4 0 5 2 0 0 7
Plaintiff )
vs. ) PACSES Case Number 8 5 810 4 813
CHANDLER A. KAZOR )Docket Number 0 044 0 5 2 0 07
Defendant ~) Other State ID Number
ORDER OF COURT
Q Final ®Interim ~ Modified
AND NOW, 10TH DAY OF JULY, 2007 ,based upon the Court's
determination that the Payee's monthly net income is $ 1, 4 0 6.03 and the Payor's
monthly net income is $ 1, 0 4 4.61 , it is hereby ordered that the Payor pay to the
Pennsylvania State Collection and Disbursement Unit
TWO HUNDRED EIGHTY AND 00/100
Dollars ($ 2 8 0. o o ) a month payable
NO LATER THAN 07/31/07.
The effective date of the order 'is 0 6 / 11 / 0 7 .
MONTHLY as follows: first payment due
Arrears set at $ 4 5 0.9 9 as of JULY l o , 2 0 0 7 are due in full
IMMEDIATELY. All terms of this Order are subject to collection and/or enforcement by
contempt proceedings, credit bureau reporting, tax refund offset certification, driver's license
revocation, and the freeze and seize of financial assets. These enforcement/collection
mechanisms will not be initiated as long as obligor does not owe overdue support. Failure to
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make each payment on time and in full will cause all arrears to become subject to immediate
collection by all the means listed above.
For the Support of:
Name ~~~th Dates
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KENNEDY EVELYN AMES -=0~~/0~
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Service Type M
Form OE-S 18 Rev. 3
Worker ID 21105
AMES ~• KAZOR PACSES Case Number: 8 5 8104 81.3
The monthly support obligation includes cash medical support in the amount of $250 annually
for unreimbursed medical expenses incurred for each child and/or spouse. Unreimbursed
medical expenses of the obligee or children that exceed $250 annually shall be allocated
between the parties. The party seeking allocation of unreimbursed medical expenses must
provide documentation of expenses to the other party no later than March 31st of the year
following the calendar year in which the final medical bill to be allocated was received. The
unreimbursed medical expenses are to be paid as follows: s~ % by defendant and
43 % by plaintiff. Q Defendant ®Plaintiff Q Neither party to provide medical
insurance coverage. Within thirty (30) days after the entry of this order, the ®Plaintiff
Q Defendant shall submit to the person having custody of the child(ren) written proof that
medical insurance coverage has been obtained or that application for coverage has been made.
Proof of coverage shall consist, at a minimum, of : 1) the name of the health care coverage
provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4)
the address to which claims should be made; 5) a description of any restrictions on usage, such
as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of
the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments;
and 8) five copies of any claim forms.
Other Conditions:
Defendant shall pay the following fees:
Fee Total Fee Descri~ion Payment Frectuencv
$ 0.00 for JUDICIAL COMPUTER FEE Payable at $ 0.00 per ONE TIME
$ 0.00 for GENETIC TEST FEE Payable at $ o . 00 per ONE TIME
$ 0.00 for DOCKET FEE Payable at $ 0.00 per ONE TIME
$ 0.00 for COLLECTION FEE Payable at $ 0.00 per YEAR
`
$ 2 5 . 0 0 for COURT COSTS Payable at $ 0 . 0 0 per MONTH
Page 3 of 4 Form 0E-518 Rev. 3
Service Type M
J Worker ID 211 os
In- the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
PACSES Case Number: 858104813
Docket Number: 0 0 4 4 0 s z o 0 7
Other State ID Number:
Please note: All correspondence must include the PACSES
Case Number.
JULY 10, 2007
SUMMARY OF TRIER OF FACT
Plaintiff Information
Defendant Information
ANISA D. AMES CHANDLER A. KAZOR
Address:
# 9
236 N BALTIMORE
MOUNT HOLLY SPRINGS PA 17065-1223
Employer:
MCKAY ENTERPRISES INC
1564 SPRING RD
CARLISLE PA 17013-1518
Attorney:
Address:
3834 PERRYSVILLE AVE
PITTSBURGH PA 15214
Employer:
Attorney:
® Complaint for Support o 6 / 11 / o ~ D Petition for Modification Filed ~ Other
Reason for Conference: PLAINTIFF FILED FOR THE SUPPORT OF THE PARTIES MINOR
CHILD NAMED BELOW,
Dependent(s)
KENNEDY EVELYN AMES 03 22 02 511-21-0308
Current Order: $ o . o o /per month
Form CM-02Z vI
Service Type M Worker ID 21105
AMES ~• KAZOR
Other Information (continued):
Facts Agreed Upon:
N/A
Facts in Dispute and Contentions with Respect to Facts in Dispute:
N/A
Guideline Amount: $ a 5 ~ , 0 s / MO
DRS Recommended Amount: $ a s ~ , o o / MO + $23/MO OOA
DRS Recommended Order Effective Date: 0 6 / i 1 / o ~
Parties to be Covered by. Recommended Order Amount:
KENNEDY AMES
Guideline Deviation: Q YES or ®NO
Reason for Deviation:
PACSES Case Number: 8 5 810 4 813
t Submitted by: JENNIFER L. GIBBONEY
Date Prepared: JULY 10, 2007
Service Type M
Page 3 of 3
Form CM-022 vl
Worker ID 2 Z 10 5
AMES v• KAZOR PACSES Case Number: 858104813
Summary
Date: JULY 10 , 2 o o ~
Monthly obligation amount selected: $ 2 s ~ . 0 0
Payment frequency: MONTHLY
Obligation amount: $ 2 s7.0 0
Deviation reason: 1. INTERIM ORDER ENTERED
2.
3.
4.
5.
i
Page Z of 2 Form 4E-019
Service Type M Worker ID 21105
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CHANDLER A. KAZOR, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. : N0.07-3794 CIVIL TERM
ANI5A D. AMES, : IN CUSTODY
Defendant
PRAECIPE FOR ENTRY OF APPEARANCE
To Curtis R. Long, Prothonotary:
Please enter my appearance on behalf of the Defendant, Anisa Ames, in the above
captioned case.
Respectfall:~ submitted,
Jessie Molst', Esquire
MidPenn Legal Services
401 E. Louther Street
Carlisle, PA 17013
(717) 243-9400
Date: ~''
- _.
ROBERT E. HAHN, II,
Plaintiff
v.
SHANNON RAE DOYLE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0.03-5407 CIVIL TERM
IN CUSTODY
CERTIFICATE OF SERVICE
I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for the Defendant, Anisa
Ames, hereby certify that I have served a copy of the foregoing PRAECIPE FOR ENTRY OF
APPEARANCE on the following date and in the manner indicated below:
U.S. First Class Mail, Postage Pre-Paid
Michael O. Palermo, Jr., Esquire
155 South Hanover Street
Carlisle, PA 17013
Date:
Jessic~/Hblst; Esquire
MidP nn Legal Services
401 E. Louther Street
Carlisle, PA 17013
(717) 243-9400
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CHANDLER A. KAZOI~,
Plaintiff ~'
v.
ANISA D. AMES,
Defendant
To Curtis R. Long, Protho#~otary:
IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
N0.07-3794 CIVIL TERM
IN CUSTODY
Please enter my appearance on behalf of the Defendant, Anisa Ames, in the above
captioned case.
Respectfully s}~mitted,
Miy1I'enn Legal Services
401 E. Louther Street
Carlisle, PA 17013
(717) 243-9400
Date: ~ ` ~~~ ~`
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CHANDLER A. KAZO ,
Plaintiff
v.
ANISA D. AMES,
Defendant;
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0.07-3794 CIVIL TERM
IN CUSTODY
CERTIFICATE OF SERVICE
I, Jessica Holst, Esgquire, of MidPenn Legal Services, attorney for the Defendant, Anisa
Ames, hereby certify that ~ have served a copy of the foregoing AMENDED PRAECIPE FOR
ENTRY OF APPEARANCE on the following date and in the manner indicated below:
U.S. First Class Mail, Postage Pre-Paid
', Michael O. Palermo, Jr., Esquire
155 South Hanover Street
Carlisle, PA 17013
Date: ~` ~~1' t~- `~~
Jes Hols ,Esquire
M dPenn Legal Services
401 E. Louther Street
Carlisle, PA 17013
(717) 243-9400
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CHANDLER A. KAZOR, IN THE COURT OF COMMON PLEAS OF
PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 07-3794 CIVIL
CIVIL ACTION -LAW
ANISA D. AMES,
DEFENDANT IN CUSTODY
ORDER OF COURT
AND NOW, this 23~d day of July, 2007, upon consideration of the Defendant's
Preliminary Objections to Custody Complaint filed by the Plaintiff,
IT IS HEREBY ORDERED AND DIRECTED that:
1. A Rule is issued upon the Plaintiff to show cause why the relief requested should not
be granted;
2. The Plaintiff will file an answer on or before Friday, August 10, 2007;
3. The Prothonotary is directed to forward said Answer to this Court;
4. A hearing on the matter will be held on Tuesday, August 21, 2007, at 10:00 a.m. in
Courtroom No. 5 of the Cumberland County Courthouse, Carlisle, Pennsylvania.
IT IS FURTHER ORDERED AND DIRECTED that all other proceedings shall be stayed
until further order of court.
By the Court,
~chael O. Palermo, Esquire
Attorney for Plaintiff
J ssica Holst, Esquire
~dPenn Legai Services
Attorney for Defendant
ohn Mangan, Esquire
Custody Conciliator
bas
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M. L. Ebert, Jr., J.
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CHANDLER A. KAZOR, IN THE COURT OF COMMON PLEAS OF
PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-3794 CIVIL
V.
CIVIL ACTION -LAW
ANISA D. AMES,
DEFENDANT IN CUSTODY
ORDER OF COURT
AND NOW, this 6th day of August, 2007, due to a conflict with the Court's schedule, the
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head ~g.scheduled for Tuesday, August 21, 2007, at 10:00 a.m. is continued to Thursday,
. ....
`°~~8eptember 20, 2007 at 1:30 p.m. in Courtroom No. 5 of the Cumberland County Courthouse,
Carlisle, Pennsylvania.
~chael O. Palermo, Esquire
Attorney for Plaintiff
~ssica Holst, Esquire
MidPenn Legal Services
Attorney for Defendant
~dohn Mangan, Esquire
Custody Conciliator a
bas
By the Court,
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M. L. Ebert, Jr., J.
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CHANDLER A. KAZOR,
PLAINTIFF
V.
ANISA D. AMES,
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-3794 CIVIL
CIVIL ACTION -LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 19th day of September, 2007, it appearing that the parties have reached
an agreement and are trying to resolve the issue, at the request of counsel for both parties, the
hearing regarding the Defendant's Preliminary Objections to Custody Complaint set for
Thursday, September 20, 2007, at 1:30 p.m. is hereby cancelled. If the matter cannot be
resolved, either party may petition the Court for the hearing to be rescheduled.
By the Court,
~chael O. Palermo, Esquire
Attorney for Plaintiff
~sica Holst, Esquire
MidPenn Legal Services
Attorney for Defendant
bas
M. L. Ebert, Jr., J
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