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HomeMy WebLinkAbout08-3727JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff SUSAN L. INGRAM, Plaintiff vs. KRISTEN KUMLER and JACOB C. KUMLER, Defendants THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 0 F - 31.2 -7 CA!;-0 TiN- CIVIL ACTION - AT LAW GRANDPARENT CUSTODY AND NOW, comes Plaintiff, Susan L. Ingram, by and through her attorney, Jeanne B. Costopoulos, Esquire, and avers the following in support of this Complaint in Custody: 1. Plaintiff, Susan L. Ingram (Grandmother hereinafter), is an adult individual currently residing at 892 Hawthorn Avenue, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant, Kristin Kumler (Mother hereinafter), is an adult individual currently residing at 119 W. Green Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Defendant, Jacob C. Kumler (Father hereinafter), is an adult individual currently residing at 1024 E. Lisburn Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 4. There is one (1) dependent child from the relationship between Defendants, namely Kathryn Olivia Kumler, born August 14, 2005 (the child hereinafter). 5. The child was born out of wedlock. The Defendants were married in 2006. Defendants are currently living separate and apart. 1 6. Since birth, it is believed the child has primarily resided at the following locations with the following people: Mother 119 W. Green Street Mechanicsburg, PA 17055 Early spring 2008 to present Mother Father Mother Mother's parents Mother's three siblings 119 W. Green Street Mechanicsburg, PA 17055 311 W. Lisburn Road Mechanicsburg, PA 17055 Spring 2006 to early spring 2008 birth to spring 2006 7. Grandmother is the natural paternal grandmother of the child and she currently resides at 892 Hawthorn Avenue, Mechanicsburg, Cumberland County, Pennsylvania, 17055. Grandmother resides with her fiance, L. William Grottola, and her two adult sons, Michael Kumler and Zachary Kumler. 8. Mother is the natural mother of the child and she currently resides at 119 W. Green Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. It is believed Mother resides alone with the subject child. 9. Father is the natural father of the child and he currently resides at 1024 E. Lisburn Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. Father currently resides with his father, Richard M. Kumler, his step-mother, Shirley Kumler, his brother Shane Kumler, and his two step-brother's, Joshua Kelly, and Jacob Kelly. It is also believed Father has partial custody of the subject child on alternating weekends. 10. Grandmother has not participated as a party or a witness, or in any other capacity in other litigation concerning the custody of the child in this or any other Court. 2 11. Grandmother has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 12. Grandmother does not know of a person not a parry to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 13. The best interest and permanent welfare of the child will be served by granting rights of partial custody to Grandmother because: a) Grandmother loves the child and has a relationship with the child. b) The child enjoys the love and affection provided to her by Grandmother. C) The bond between Grandmother and the child should be kept intact. 14. 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. WHEREFORE, Plaintiff, Susan L. Ingram, respectfully requests this Honorable Court to grant her periods of partial custody with her granddaughter. Respectfully Submitted: By: -? . JE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff Date: 3 VERIFICATION I, Susan L. Ingram, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. 2 G? Date: Sus .Ingram 4 ?? ! rj I?:7 Q LV ?'S C1 oc p,? .. - ? , r SUSAN L. INGRAM IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-3727 CIVIL ACTION LAW KRISTEN KUMLER AND JACOB C. KUMLER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, July 01, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, August 01, 2008 at 9:30 AM 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 Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Hubert X. Gilroy, Ks T. 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 64yw,--*,t- /?V?A?v Via, f -? r3 ?J LI A SUSAN L. INGRAM, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 08-3727 Civil Term KRISTEN KUMLER and JACOB C. KUMLER, CIVIL ACTION - AT LAW Defendants GRANDPARENT CUSTODY PRAFC'IPE TO WTTIIDRAW CQMPLAUVF-?,/ TO THE PROTHONOTARY: Please mark Plaintiff s Complaint in Custody filed on June 23, 2008 discontinued and withdrawn. RESPECTFULLY SUBMITTED: By: JEANN , B. COSTOPOULO , QUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff Date: / ' c"? ?' ;;? t ?? ? 9 rri ?' a;tJ c"_ - "? C - N h3 :.??, ? •. o?c. o 7 4 SUSAN L. INGRAM, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW KRISTEN KUMLER and JACOB C. KUMLER NO. 2008-3727 Defendant GRANDPARENT CUSTODY COURT ORDER AND NOW, this -9 day of July, 2008, the Conciliator being advised the Plaintiff has withdrawn Complaint in Custody, the Conciliator relinquishes jurisdiction. Hubert X. Custody ( Esquire ?.. rn firs r a co rv