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HomeMy WebLinkAbout08-3473Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-7200 cpbruntO-CPBru ntLaw.com Attorney for Plaintiff GEORGANNA L. STEVENS, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. CIVIL DEBORAH L. KEELEY, 08 - 34'73 eivaTerm Defendant IN CUSTODY NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 1-800-990-9198 717-249-3166 Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 c p b ru n tgD-C P B ru ntLaw. c o m Attorney for Plaintiff GEORGANNA L. STEVENS, Plaintiff V. DEBORAH L. KEELEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW e79-,59 73 NO. CIVIL IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, GEORGANNA L. STEVENS, by and through her attorney, CONSTANCE P. BRUNT, ESQUIRE, and respectfully represents as follows: 1. The Plaintiff is GEORGANNA L. STEVENS, residing at 16 Salt Road, Enola, Cumberland County, Pennsylvania 17025. 2. The Defendant is DEBORAH L. KEELEY, residing at 16 Salt Road, Enola, Cumberland County, Pennsylvania 17025. 3. The Plaintiff is seeking primary legal and physical custody of the following child: Name Residence ft e Casey Elizabeth Stevens 16 Salt Road 8 Enola, Pennsylvania 17025 The child was born out of wedlock to Defendant, DEBORAH L. KEELEY, and an unknown father. No paternity has been established, and there is no father named on the child's birth certificate. Further, no putative father has been identified or has come forward to claim paternity of the child. The child is presently in the physical custody of Plaintiff, GEORGANNA L. STEVENS, and Defendant, DEBORAH L. KEELEY, both of whom reside at 16 Salt Road, Enola Cumberland County, Pennsylvania. For the past five (5) years the child has resided with the following persons and at the following addresses: (a) From birth to the present 16 Salt Road Enola, PA 17025 With Plaintiff and Defendant The mother of the child is Defendant, DEBORAH L. KEELEY, residing at 16 Salt Road, Enola, Pennsylvania, 17025. She is presently single. The father of the child is unknown. -2- 4. The relationship of Plaintiff, GEORGANNA L. STEVENS, to the child is that of maternal grandmother. 5. The relationship of Defendant, DEBORAH L. KEELEY, to the child is that of natural mother. 6. The Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the child in this or any other court. Plaintiff has no information of a custody proceeding concerning the custody of the said child pending in a court of this Commonwealth or any other state. 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. 7. It is in the best interest of the minor child to be in the primary legal and physical custody of Plaintiff, her maternal grandmother, who is best able to provide a wholesome and stable environment for her. Defendant, who is the natural mother, suffers from severe Attention-Deficit/Hyperactivity Disorder, making it difficult for her to maintain employment and to function effectively and appropriately in daily life. Although she is legally competent, due to her disability, Defendant is unable to provide proper care and supervision for the minor child, as a result of which she and the child have -3- resided with Plaintiff, the maternal grandmother, continuously since the child's birth. The Plaintiff serves as the primary caregiver and source of financial support for the child and wishes to continue to do so in order to ensure that she thrives. 8. Each known parent whose parental rights of the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests the entry of an Order of Court granting her primary legal and physical custody of the minor child, pursuant to the terms of the Stipulation for Entry of an Order of Court signed by both parties and filed simultaneously with this Complaint. Respectfully submitted, DATED: (o clw 4 CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID # 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 FAX (717) 232-0255 cp b ru ntCa? C P B ru nt Law. co m Attorney for Plaintiff -4- VERIFICATION I verify that the statements made in the foregoing Complaint for Custody 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. DATED: 6/Slob CANNA L. STEVENS, Plaintiff 0 -? a O D - <- Q0 n wr, Y IC , K Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cpbrun CPBruntLaw.com Attorney for Plaintiff GEORGANNA L. STEVENS, Plaintiff V. DEBORAH L. KEELEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW • 0? ? ag73 NO. CIVIL T IN CUSTODY STIPULATION OF THE PARTIES FOR ENTRY OF ORDER OF COURT AND NOW, come the parties, Plaintiff, GEORGANNA L. STEVENS, and Defendant, DEBORAH L. KEELEY, stipulate and agree to the entry of the proposed Order Of Court attached hereto. *9in NNA L. STEVENS Defen dant, pro se 61?IA4 CONSTANCE P. BRUNT, ESQUIRE Attorney for Plaintiff Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-7200 cpbrunttMCPBruntLaw.com Attorney for Plaintiff GEORGANNA L. STEVENS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. CIVIL DEBORAH L. KEELEY, t9_ 3y73 6, f 4e%- Defendant IN CUSTODY NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 1-800-990-9198 717-249-3166 Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cpbruntPCPBruntLaw.com Attorney for Plaintiff GEORGANNA L. STEVENS, Plaintiff V. DEBORAH L. KEELEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CIVIL IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, GEORGANNA L. STEVENS, by and through her attorney, CONSTANCE P. BRUNT, ESQUIRE, and respectfully represents as follows: 1. The Plaintiff is GEORGANNA L. STEVENS, residing at 16 Salt Road, Enola, Cumberland County, Pennsylvania 17025. 2. The Defendant is DEBORAH L. KEELEY, residing at 16 Salt Road, Enola, Cumberland County, Pennsylvania 17025. 3. The Plaintiff is seeking primary legal and physical custody of the following child: Name Residence Age Casey Elizabeth Stevens 16 Salt Road 8 Enola, Pennsylvania 17025 The child was born out of wedlock to Defendant, DEBORAH L. KEELEY, and an unknown father. No paternity has been established, and there is no father named on the child's birth certificate. Further, no putative father has been identified or has come forward to claim paternity of the child. The child is presently in the physical custody of Plaintiff, GEORGANNA L. STEVENS, and Defendant, DEBORAH L. KEELEY, both of whom reside at 16 Salt Road, Enola Cumberland County, Pennsylvania. For the past five (5) years the child has resided with the following persons and at the following addresses: (a) From birth to the present 16 Salt Road Enola, PA 17025 With Plaintiff and Defendant The mother of the child is Defendant, DEBORAH L. KEELEY, residing at 16 Salt Road, Enola, Pennsylvania, 17025. She is presently single. The father of the child is unknown. -2- 4. The relationship of Plaintiff, GEORGANNA L. STEVENS, to the child is that of maternal grandmother. 5. The relationship of Defendant, DEBORAH L. KEELEY, to the child is that of natural mother. 6. The Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the child in this or any other court. Plaintiff has no information of a custody proceeding concerning the custody of the said child pending in a court of this Commonwealth or any other state. 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. 7. It is in the best interest of the minor child to be in the primary legal and physical custody of Plaintiff, her maternal grandmother, who is best able to provide a wholesome and stable environment for her. Defendant, who is the natural mother, suffers from severe Attention-Deficit/Hyperactivity Disorder, making it difficult for her to maintain employment and to function effectively and appropriately in daily life. Although she is legally competent, due to her disability, Defendant is unable to provide proper care and supervision for the minor child, as a result of which she and the child have -3- resided with Plaintiff, the maternal grandmother, continuously since the child's birth. The Plaintiff serves as the primary caregiver and source of financial support for the child and wishes to continue to do so in order to ensure that she thrives. 8. Each known parent whose parental rights of the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests the entry of an Order of Court granting her primary legal and physical custody of the minor child, pursuant to the terms of the Stipulation for Entry of an Order of Court signed by both parties and filed simultaneously with this Complaint. Respectfully submitted, DATED: 61cl w l / CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID # 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 FAX (717) 232-0255 ccpbrunt@CPBruntLaw.com Attorney for Plaintiff -4- VERIFICATION I verify that the statements made in the foregoing Complaint for Custody 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. DATED: 6/s/"? *GAINONA L. STEVE NS, Plaintiff 0 C7 "3 o° °Tj U; cY rii 3 rn - ?? ? 17 -:4 QUN 0 9 2008 Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cpbruntOCPBruntLaw.com Attorney for Plaintiff GEORGANNA L. STEVENS, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. CIVIL DEBORAH L. KEELEY, 69-3473 0,ivt L lerM Defendant IN CUSTODY ORDER OF COURT AND NOW, this fu day of 008, upon Stipulation of Plaintiff, GEORGANNA L. STEVENS, and Defendant, DEBORAH L. KEELEY, filed herein, IT IS HEREBY ORDERED and DECREED that primary legal and physical custody of the minor child, CASEY ELIZABETH STEVENS (DOB: 5/2/2000) is hereby granted to Plaintiff, GEORGANNA L. STEVENS, subject to Defendant's partial physical custody of the child as the parties shall agree from time to time. chi w -? cv ? ?: `? ,? U ? Qom ,?, ? .. ?a + ?? ,?!, ? ? ? < { cn ,_, _ r ?? ? -? ?? ? iZ c? a 0 N Distribution To: ,ATTORNEY FOR PLAINTIFF: Constance P. Brunt, Esquire Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 FAX (717) 232-0255 cgbrunt CPBruntLaw.com DEFENDANT, Pro se: 6eborah L. Keeley 16 Salt Road Enola, PA 17025 (717) 732-2285 I'Ls rn?t P _2_ Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717)232-7200 FAX (717) 232-0255 cobrun!"PBruntLaw.com Attorney for Plaintiff GEORGANNA L. STEVENS, Plaintiff V. DEBORAH L. KEELEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW : NO. 08 - 3473 CIVIL TERM : IN CUSTODY ACCEPTANCE OF SERVICE I, DEBORAH L. KEELEY, Defendant in the above-captioned action, hereby acknowledge receipt of a true and correct copy of the Complaint for Custody filed on June 6, 2008, on behalf of Plaintiff and accept service of the said Complaint. DATED: A6zk DEBORAH L. KEEL , Defend nt t`-: ?, - ? ?.. ?, ? -c7 ?" _ r}?`' t ! -? :...? ? ? ? "7 t -?"' [ .._.! -•C