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HomeMy WebLinkAbout09-6535 IN THE COURT OF COMMON PLEAS OF COUNTY, PENNSYLVANIA CIVIL ACTION--LAW No. Q Plaintiff V. V'li eR? ?rZC8 C_ Defendant PETITION TO PROCEED IN FORMA PAUPERIS TO THE HONORABLE, THE JUDGES OF THE SAID COURT: The Petition of I_C?urrcn _Cj respectfully represents: 1. I am the (Plaintiff) `sf=_.d-__;,) in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct: (a) Name :La r-Cr-j Address Lp?jc?c?0.C? Soc. Sec. No . r1?? (b) Employment--If you are presently employed, state Employer : n-". Ae- Tl 2X- Qc3 0.C •'KACVk i 11 Address: Salary or wages per month: Type of work: --If you are presently unemployed, state Date of last employment: Salary or wages per month: Type of work: (c) Other income within the past twelve months Business or profession:r?sp- Other self-employment: 0%_? Interest:(IA4 Dividends: rL.(()-- Pension and annuities:fW-4- Social security benefits:-? Support payments : ,(\J? Disability payments : vk(1 I- Workman's compensation:DR Public assistance:(U?)_ Other: kA_)Oc? 0 C . (d) Other contributions to household support Spouse's •Name : ?(l3' If your spouse is employed, state Employer :(\kR Salary or wages per month : ('`1qr Type of work op Contributions from child (ren)ren:"P" Contributions from parents: ?C - Other contributions: (e) Property owned Cash: Checking account:OW e Savings account:RC-0 C Certificates of deposit: e Real estate (including home) r1 Motor vehicle: Make:?,\co e ; Year: Cost: $ Amount owed: Stocks; bonds :?? e Other: (f) Debts and obl;gations Mortgage : {L? Rent : $(AfA Loans : N 11- Other : Q lb1e { __ ? c?h C." Own (g) Persons dependent upon you for support Spouse's Name:: \ i Child(ren), if any: Name (s) and age (s) : (W? Other persons: Name :('k-UA Relationship: 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit 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 to authorities. Date aintiff E' [D r '? r? nF TH c;' : r rTARY 20109 sc-P 29 F''; l cur'' JT I, ??_. r , 7C V?Lli??l-lf'tl? IN THE COURT OF COMMON PLEAS OF THE IT JUDICIAL DISTRICT VS. OF PENNSYLVANIA ,xV,eno' "b Cs+-i-,crl" COUNTY BRANCH . NO. 09. 6 6-8 5- 1 COMPLAINT FOR (CUSTODY) ( ) (V ) 1. The plaintiff is ??d u I LQxUfr-n (?r{1P I residing at na? (Street) (ti t Y-) (Zip Code) (County) M 2. The defendant is Vng?,00C-- 1j 1 residing at tv,),-A nkoe-c,?IA G,Aoe- ("CA -AAC (Street) (City) (ip Code) u,pty) 3. Plaintiff seeks (custody) (Vaitial y) (visi#fiem) of the following child(renj: Name Present Residence Age L? ?,rv c n t-1? T The child (was) (*wm-n4) born out of wedlock. The child is presently in the custody of l iau? 6V?mwp L (Name) who resides scityj (State) 1 of 4 4. 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) Ub Ok 01 -7 u 1eg? 0 t s3ure, -km? 2_ an alsj P ?S t? Q ? ?r?1 (Ju1?CacYCx? b?? -to ?"? - Pmcs}Nns The mother the child is, tjf currently residing at "J 1 a??`a, ?- 06a Qo m C T lK it V ieL ?(M noa She is ((idiom l) (single). The father of the child is &?DW?b J ,nc )6 , currently residing at He is (n a vied) (d eed) (single). 4. The relationship of plaintiff to the child is that of The plaintiff currently resides with the following persons: Dame Relationship 5. The relationship of defendant to the child is that of? Name Relationship C?Qf11P,??1Cl?e iC1C?t?Ch? -1?C'r?fY?t 2 of 4 w 6. Plaintiff (JU&) (has not) participated as a party or witness, or in another capacity, •N in other litigation concerning the custody of the child in this or another court. The court, term and numbers and its relationship to this action is: Plaintiff (etas) ( r information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. The court, term and number, and its relationship to this action is: Plaintiff (4meme) (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. The name and address of'such person is: ( 7.) The best interest and permanent welfare of the child will be served by granting the relief requested because (set forth facts showing that the granting of the relief requested will be in the best interest and permanent welfare of the child: V ?-S voce- b? (A), N . V-Gv"-, 4-Vv- rf)QOCY? In cDre oC ?e r?edS . csN -Cc) C?n 3 of 4 \ ? CGS' a l 15 art ?nc? ? ?(1 C),?S ? ? - cn Whey-, ?v?na der- W ?-?h 1?-en n ? ? hey; C,0- key ??? S -end(S h C?? A V1 u? j?ANA IND Ch'i t& Lt ?c A Ter- - mQq ? CPA e?? 5 1Ze??n ?? C ??-- ?v 4-h-e \\U,-,.Se c,,,co CAC J .N 8. 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 Address Basis of Claim 9, Plaintiff has been advised of the requirement to attend the seminar titled "Education Program for Separated Parents" offered by Penn State. OR o'The parties have previously attended the "Education Program for Separated Parents" program as evidenced by certificates of attendance contained in the official court and/or verification of file to the following referenced case number certificate attached hereto. Wherefore, plaintiff requests the court to grant (custody) (partial custody) (visitation) of the child. ' Attorney for Plaintiff I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.§ ies. 4904 relating to unsworn falsification to aut5aintiff 4of4 ?OF TApy '009 S EP 29 Pll 3: 1 k,r--? T?AC CCOCI-\T (X- PtLRS 0(-' Lwbe-r6-6, N 9S NN SAC LUPNk (-?- C \v t L acT ? C.XN1- - UA 0,-) ?Q\,?.r Pn v \-AQrnrn e?- Vnodke. _T-r\e q! 7"Ancjn oc Loourer, ?Aarnmel ?rec Ae31S lrlrTl?) A M 1Z.r-No6e bE CQ\45C Vanne.Aj, a y J V,noae C ??ac?)c?nd arn;?`3 are cam- ??ec?r ->A \r\ \Zr,ode and ?s c?q>lrem0E' to, \Znod6 Tie - her n ? ??? 5 - c k_ and le 4- q no u-? Ck r\CA- riv wine re She wQS . V nr? ,4h &CS V t ??-1, ?? 1, e Q? k 5 -? On Lr? t i cen C4' ve,r -?Qrc?;l i S tom whQ??- V ? o?eR one-\r,` " The ?? e ? s mr+ 002 pla;? are. I FILE_CO tl.) Trvt?Y 'OF THE F171,11 2009 SEP 29 PIN ?: 20 IN THE COURT OF COMMON PLEAS OF ZOUNTY PENNSYLVANIA ^^ CIVIL ACTION -LAW n A I NAME: '? (NU Iren k-111Cn?a1 NO. ] 6q.._3 Plaintiff V. ,,( NAME: x ! 1ori- "1 kA rNoC_?_e Defendant ORDER AND NOW, this day of ?Qa' upon consideration of the Petition of A (`?? x(f_C-) 0CiTVDP ? (plaintiff) (defendant) to Proceed In Forma Pauperis, it is hereby ORDERED AND DECREED that the (plaintiff) (ant) ?Cl r?rl ?AQ,rnr o f'J may file the r In Forma Pauperis and proceed to the termination of proceedings without payment of filing fees or costs. I / j V LVL J". ?UeS ey net- Tv- - OF THE" p -rHONo3TARy 2009 OCT -2 PM 4: 2 7 P .r LAUREN HAMMEL PLAINTIFF V. KENNETH KNODE DEFENDANT IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA 2009-6535 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Wednesday, October 07, 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 Thursday, October 22, 2009 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/ Huber X. Giko 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 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 FIL??.' +?'rv??C NARY r ? •. 2009 OCT -8 M 1 I* "8 4 r r`! ?urf !?Y copy dLLAo f LAUREN HAMMEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW KENNETH KNODE, ; Defendant NO. 09-6535 CIVIL TERM IN RE: PLAINTIFF'S EMERGENCY CUSTODY PETITION ORDER OF COURT AND NOW, this 9`'' day of October, 2009, upon consideration of Plaintiffs Petition for Emergency Custody Order, a hearing is scheduled for Tuesday, October 20, 2009, at 11:00 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. Lauren Hammel 632 South Enola Road West Fairview, PA 17025 Plaintiff, pro Se ? Kenneth Knode 12517 Stone Creek Ridge Road Huntingdon, PA 16652 Defendant, pro Se rc cO ieg 'n--LtLLL BY THE COURT, 'esley r, Jr., FIIFGL-QFIFE OF THE PPk)T! (-',NOTARY 2009 OC T -9 P 3, 30 W LAUREN HAMMEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW KENNETH KNODE, NO. 2009-6535 Defendant IN CUSTODY ORDER AND NOW, this J day of October, 2009, the Conciliator appearing at the Conciliation Conference scheduled for Thursday, October 22, 2009, at 9:30 a.m. and neither of the parties being in attendance, and the Conciliator being advised that the parties did also not attend a previously scheduled hearing relating to a Petition for Special Relief in this case, the Conciliator relinquishes jurisdiction. 6;?? - wj?l Hubert X. Gilroy, Esquir Custody Conciliator ?l Of TE W, lotj pCS 26 2' 1 CU11$ LAUREN HAMMEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW 09-6535 CIVIL TERM KENNETH KNODE, Defendant IN CUSTODY IN RE: PETITION FOR EMERGENCY CUSTODY ORDER ORDER OF COURT AND NOW, this 20th day of October, 2009, upon consideration of Plaintiff's Petition for Emergency Custody Order in the above-captioned case, and no person having appeared for the hearing scheduled for 11:00 a.m. on today's date, and the Court having waited more than 15 minutes beyond the time scheduled for the hearing to facilitate the appearance of any party, Plaintiff's Petition for Emergency Custody Order is dismissed. -"Lauren Hammel, Pro Se 632 South Enola Road West Fairview, PA 17025 ? Kenneth Knode, Pro Se 12517 Stone Creek Ridge Road Huntingdon, PA 16652 :mae corc" ??/zc??oq By the Court, LAUREN HAMMEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW KENNETH KNODE, Defendant NO. 09-6535 CIVIL TERM IN RE: PETITION FOR SPECIAL RELIEF PURSUANT TO RULE 1915.13 OF THE PENNSYLVANIA RULES OF CIVIL PROCEDURE ORDER OF COURT AND NOW, this 19~' day of March, 2010, upon consideration of Plaintiff s Petition for Special Relief Pursuant to Rule 1915.13 of the Pennsylvania Rules of Civil Procedure, a hearing is scheduled for Friday, March 26, 2010, at 11:15 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, Christopher J. Basner, Esq. 341 Market Street Newport, PA 17074 Attorney for Plaintiff /Kenneth Knode 12517 Stone Creek Ridge Road Huntingdon, PA 16652 Defendant, pro Se rc n A l:~~J t,~ /Yla`f l 1 3 flQ~~~ ~~ J~. Wesley Ole , Jr., ,. s1 n N c~ Q ,~ ~_? rh, ,_ ~_ __ ~. '- _ ~ R~ _,_ -.._ r-~~,: :~ - LO . , t.. -Q ~ ~ `~ '-i ~ ~- °J` ~~" :~ :- Ilii o .„ ~ ~n