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Home My WebLink About09-5966John W. Purcell, Jr., Esquire ID #29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell@pkh.com TIMOTHY S. DUNDORF and IN THE COURT OF COMMON PLEAS CAROL A. DUNFORF, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs ` c ?- 'f c<n1 NO. Q ?- 579 v. EDWARD R. KNISLEY and CIVIL ACTION - LAW DAWN K. KNISLEY, IN CUSTODY COMPLAINT AND NOW, come the Plaintiffs, Timothy S. Dundorf and Carol A. Dundorf, by their attorney, John W. Purcell, Jr., Esquire, who aver as follows: 1. The Plaintiffs are Timothy S. Dundorf and Carol A. Dundorf, adult individuals, with an address of 2020 Valley Street, Enola, Cumberland County, Pennsylvania 17025 2. Defendant Dawn K. Knisley is an adult individual, with an address of 256 North Enola Drive, Apartment C, Enola, Cumberland County, Pennsylvania 17025. 3. Defendant Edward R. Knisley is an adult individual currently residing at the Lebanon County Prison, 730 East Walnut Street, Lebanon, Lebanon County, Pennsylvania 17042. 4. The relationship of Defendant Dawn K. Knisley to the minor child is that of natural mother, who currently resides with her daughter, Tasha Kinsley, 20. 5. The relationship of Defendant and Edward R. Knisley to the minor child is that of natural father, who resides with unknown persons as he is currently incarcerated in the Lebanon County Prison. 6. The relationship of Plaintiffs to the minor child is that of unrelated parties. The Plaintiffs currently reside with the following persons: Amy Dundorf, 16, and Amanda Dundorf, 14, their daughters. 7. The Plaintiffs seeks custody of the following child: Name Present Residence Age Bradley A. Knisley 2020 Valley Street, Enola, PA 17025 16 8. Bradley A. Knisley, born February 13, 1993, is presently in the custody of the Plaintiffs, who reside at 2020 Valley Street, Enola, Cumberland County, Pennsylvania 17025. Since birth, the child has resided with the following persons and at the following address(es): Child Name Address Date Bradley A. Knisley 21 Shady Lane Enola, PA 17025 Bradley A. Knisley 4045 HCR Box 1 Shell Knob, MO 9. The parties have stipulated to the change of custody, as it would be in the best interest of Bradley to reside with the Plaintiffs due to the exigent circumstances of the Knisley family. Stipulations of the parties are attached hereto. 10. Both Defendants have stipulated to the change in custody, knowing that custody may revert back to them once the dire circumstances have changed. 11. The Plaintiffs have 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. 2 STIPULATION I, Dawn K. Knisley, being the natural mother of Bradley A. Knisely, hereby stipulate to the entry of an Order transferring custody of my son to Timothy and Carol Dundorf. I further authorize Timothy and Carol Dundorf, or either one of them, to make appropriate decisions concerning my son, Bradley A. Knisley, including enrolling him in appropriate schooling, providing medical services and making medical decisions as if I had made them for him. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. 41?- i',v? IQZ? I Dawn K. Knisley Date: 1-3 _( l VERIFICATION I, Timothy S. Dundorf, hereby verify that the facts contained in the foregoing Complaint in Custody are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Timothy S. undorf Date: F113),31 VERIFICATION I, Carol A. Dundorf, hereby verify that the facts contained in the foregoing Complaint in Custody are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. &tldlc?sl Carol A. D orf Date: r niF I p, J Y{ iC ('t 1 y sal- L009 .,42 VVit? _ ..? St i .1 $ lus. 5o PD AT" cit:o .2399 3 0 a300aQ TIMOTHY S. DUNDORF AND CAROL A. IN THE COURT OF COMMON PLEAS OF DUNDORF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-5966 CIVIL ACTION LAW EDWARD R. KNISLEY AND DAWN K. KNISLEY IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, Sepiember 11, 2009 , 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, October 09, 2009 at 8:30 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, Es q. I'm 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 HLED-.4 "ICE OF Thr R-K-T1 i`?M?? TARY 2009 SEE 14 AN 10: 06 p 1 o..mt" {?J.?tru?dC ?t ?°Pr •na?L4cC. 40 bew r TIMOTHY S. DUNDORF and CAROL A. DUNDORF, Plaintiff vs. EDWARD R. KNISELY and DAWN K. KNISELY, Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C VIL ACTION - LAW N .2009-5966 CUSTODY AND NOW, this day of the attached Stipulations signed by the Deft , upon consideration of , it is ordered and directed as follows: 1. Timothy S. Dundorf and Carol A. Dundorf shall have sole legal and sole physical custody of Bradley A. Knisley, bon February 13, 1993. 2. Consistent with this Order of Custody, the Dundorf s, either one of them or both of them, may make appropriate decisions concerning Bradley A. Knisley to include enrolling him in an appropriate sch oling, provision of medical services and related decisions that an individual who has sole legal custody may make. 3. The father, Edward R. Knisley, and he mother, Dawn K. Knisely, shall enjoyperiods of visitation with the minor child at such times and under such circumstances as agreed upon by the parties. 4. In the event either party desires to modify this Order, that party may petition the Court to have the case again cc: hn W. Purcell, Jr., Esquire Dawn K. Knisley Mr. Edward R. Kn)isle?y ? ES rYt?, l l?d? /D !ol U?r ?t'Y1 2--- P TIMOTHY S. DUNDORF and CAROL A. DUNDORF, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. EDWARD R. KNISELY and DAWN K. KNISELY, Defendant IN ACCORDANCE WITH THE PROCEDURE 1915.3-8(b), the undersigned CIVIL ACTION - LAW ). 2009-5966 CUSTODY ERLAND COUNTY RULE OF CIVIL y Conciliator submits the following report: 1. A Custody Complaint was filed lin the above matter but the parties submitted Stipulations signed by all parties. I Pursuant to those Stipulations, the Conciliator recommends an Order in the form l s attached. Date: September 1? V , 2009 /44 ert X. Gilr , Esquire Custody Co iliator FILED-011 iiCE OF THE PRr! T ±. ) ' VARY 2009OCT -6 ASS 9: 5 9