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
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nF TH c;' :
r rTARY
20109 sc-P 29 F''; l
cur''
JT I,
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,
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 .
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-Cc) C?n 3 of 4 \ ?
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a
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art ?nc? ? ?(1 C),?S ? ? -
cn Whey-,
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u? j?ANA
IND Ch'i t&
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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
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arn;?`3 are cam- ??ec?r ->A \r\ \Zr,ode and
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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
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