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Home My WebLink About08-3316Lenora M. Smith, Esquire Attorney I. D. #: 22607 1205 North Second Street P. O. Box 5154 Harrisburg, PA 17110 (717) 234-1688 RYAN SCOTT KELLER, V. MARVA D. DAVIS , : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. Pf'- 33 /4, Cc; d- 7ZH' :CUSTODY Defendant CUSTODY COMPLAINT AND NOW comes the above-named Plaintiff, Ryan Scott Keller, by and through his attorney, Lenora M. Smith, Esquire, and avers the following: 1. Ryan Scott Keller is an adult individual residing at 1915 Letchworth Drive, Camp Hill, Cumberland County, Pennsylvania. 2. Marva D. Davis is an adult individual residing at 602 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are the natural parents of the minor child, Keira Sage Elizabeth Keller whose date of birth is October 30, 2006. 4. The minor child has lived with the Parties for approximately one (1) year. Thereafter, the child has lived with the father most of the time since the Parties separated. 5. There is no other proceeding in Court in this matter. 6. Since the Parties have separated, Plaintiff has had the child most of the time. Defendant has threatened to take child our of this Court's jurisdiction. 7. The best interest and permanent welfare of the child will be served by granting shared legal custody and primary physical custody of the Plaintiff. WHEREFORE, Plaintiff requests the Court to award the Parties shared legal custody and award primary physical custody to Plaintiff. Respectfully Submitted y Date: May, 2008 BY= 4,A,- 4, " Lenora M. Smith, Esquire Attorney I. D. #: 22607 1205 North Second Street Harrisburg, PA 17102 (717) 234-1688 Attorney for Petitioner, Ryan Scott Keller VERIFICATION I /Ly,? ,v S, ke lle?. , have read the foregoing and hereby affirm that it is true and correct to the best of my personal knowledge, information and belief. This Verification and statement is made subject to the penalties of 18 Pa. C. S. § 4904 relating to unworn falsification to authorities; I verify that all the statements made in the foregoing are true and correct and that false statements may subject me to the penalties of 18 Pa. C. S. § 4904. Date: /??/U F CERTIFICATE OF SERVICE I, Lenora M Smith, Esquire, hereby certify that I have on the day of May, 2008, served a true and correct copy of the within CUSTODY COMPLAINT on the person named below by depositing a copy thereof in the U. S. First Class Mail, postage prepaid, addressed to the following: Marva D. Davis 602 Bosler Avenue Lemoyne, PA 17043 By: _ 4-1- k -> '1 '4 Lenora M. Smith, Esquire Attorney I. D. #: 22607 1205 North Second Street Harrisburg, PA 17102 (717) 234-1688 Attorney for Plaintiff, Ryan Scott Keller l # m = 9.i i .) vl ? -- ..J RYAN SCOTT KELLER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. MARVA D. DAVIS DEFENDANT 2008-3316 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Tuesday, June 03, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Friday, June 27, 2008 at 1:30 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. 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunda Es q. 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 court, 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 YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 A5 AUVl1t , C Z :Zl wa h- W-Ir "RiI r Zoos 01 0 RYAN SCOTT KELLER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2008-3316 CIVIL ACTION LAW MARVA D. DAVIS Defendant IN CUSTODY ORDER OF COURT AND NOW, this 1-1 J? _ day of ?Tv l 1 , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Marva D. Davis, and the Father, Ryan Scott Keller, shall have shared legal custody of Keira Sage Elizabeth Keller, born October 30, 2006. Major decisions concerning the Child including, but not necessarily limited to, her health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in the Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the Child. Neither party shall attempt to alienate the affections of the Child from the other party. Each party shall notify the other of any activity or circumstance concerning the Child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5304, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. 2. The Father shall have primary physical custody of the Child. 3. The Mother shall have partial physical custody of the Child on alternating weekends from Friday at 3:00 p.m. through Sunday at 8:00 p.m. beginning June 27, 2008. In every week, the Mother shall also have custody of the Child on Tuesdays and Thursdays from 3:00 p.m. until 8:00 p.m. 4. Unless otherwise agreed between the parties, the Mother's periods of custody shall take place at the residence of Peggy Alvarado, the maternal aunt, in Lemoyne. The Mother shall use her sister's residence as the home base for overnights and during periods of custody but shall not be limited to remaining at the residence. 5. The parties shall share or alternate having custody of the Child on holidays as arranged by agreement. 6. The parties shall be entitled to have vacation periods of custody with the Child as arranged by agreement. 7. Unless otherwise agreed between the parties, the parent receiving custody of the Child shall be responsible to provide transportation for the exchange of custody. 8. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision. 9. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. cc: nora M. Smith, Esquire - Counsel for Father ,Marva D. Davis - Mother J BY THE COURT, RYAN SCOTT KELLER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2008-3316 CIVIL ACTION LAW MARVA D. DAVIS Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Keira Sage Elizabeth Keller October 30, 2006 Father 2. A custody conciliation conference was held on June 27, 2008, with the following individuals in attendance: the Father, Ryan Scott Keller, with his counsel, Lenora M. Smith, Esquire, and the Mother, Marva D. Davis, who is not represented by counsel in this matter. Both the paternal grandmother and maternal aunt also attended the conference by agreement of the parties. 3. The parties agreed to entry of an Order in the form as attached. a -7f aooef 4?? 06? Date Dawn S. Sunday, Esquire Custody Conciliator