The URL can be used to link to this page

Home My WebLink About10-1190I I t DONNA L. SCHORR, Plaintiff vs. SCOTT D. HARDY and JENNIFER KEELEY, Defendant COMPLAINT IN CUSTODY AND NOW comes the Plaintiff, DONNA L. SCHORR, by her attorney, Samuel L. Andes, and makes the following Complaint for Custody: 1. The Plaintiff is DONNA L. SCHORR, an adult individual who resides at 103 Hampden Avenue in Camp Hill, Cumberland County, Pennsylvania. 2. The Defendants are SCOTT D. HARDY, an adult individual who resides 208 West Ridge Road in Dillsburg, York County, Pennsylvania and JENNIFER KEELEY is an adult individual who resides in New Kingstown, Cumberland County, Pennsylvania, and whose mailing address is P.O. Box 473, New Kingstown, PA 17072. 3. The Defendants are the biological parents of a minor child, Isaac Benjamin Hardy, now age 12, born 7 September 1997. 4. Plaintiff is the maternal grandmother of the said child. 5. During the past five years the child has resided at the following locations with the 2010 FFB 22 t71 I I : 0 ,, W,, ,CQUXTV, F COMMON PLI AS?"OV&WBBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. ?0 - 1140 Civi i Ter v% IN DIVORCE following persons: January 2005 to March 2006 Jennifer Keeley Dillsburg, PA March 2006 to June 2006 Scott D. Hardy Dillsburg, PA June 2006 to present Donna L. Schorr 103 Hampden Avenue Camp Hill, PA 6. Plaintiff came into custody of the child as a result of an agreement with the child's parents. The child has resided with Plaintiff, without interruption, since June of 2006 and Plaintiff has been primarily responsible for the care of the child. 7. The Plaintiff has not participated as a party or in any other way in any litigation concerning the custody of the child in this or any other court. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of this or any other jurisdiction. Plaintiff knows of no other person not a party to this action already who has physical custody of or claims to have custody or visitation rights to the said child. 8. Plaintiff seeks an award of legal and physical custody of the child and belelives such an award is in the child's best interest, for the following reasons: A. The child has resided with Plaintiff for three and a half years and Plainitff has provided the security and stability that the child needs during that time. B. The child has special needs, including Asperger's Syndrome and Attention Deficit Disorder, which require special attention, support, and neuturing, which Plaintiff has provided for the child for the past three years. C. Important decisions about the child's education must be made by a responsible party and Plaintiff is the only adult in a position to make those decisions, Plaintiff requires an award of legal custody of the child. 9. Plaintiff believes that both parents agree that the child should be in her legal and physical custody. t ? WHEREFORE, Plaintiff prays this court to award her legal and physical custody of her grandson, Isaac Benjamin Hardy, born 7 September 1997. Samuel L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 $174.OD PO ATT/ C,I?? "I(a3lo ` ail S) q3 .t I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unworn falsification to authorities). Date: a7 - 15-- an /D Donna L. Schorr r- fs- >, ,',SY DONNA L. SCHORR, Plaintiff iDI0 FEB 22 k" 11: 06 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. SCOTT D. HARDY and JENNIFER ) KEELEY, ) Defendant ) STIPULATION CIVIL ACTION - LAW NO. JO Q1) IN DIVORCE AND NOW come the above-named parties, and stipulate and agree as follows: 1. The biological mother of Isaac Benjamin Hardy, born 7 September 1997, is the Defendant Jennifer Keeley whose address is P.O. Box 473 in New Kingstown, Cumberland County, Pennsylvania 17072. 2. The biological father of Isaac Benjamin Hardy, born 7 September 1997, is the Defendant Scott D. Hardy whose address is 208 West Ridge Road in Dillsburg, York County, Pennsylvania 17019. 3. The said child has been in the custody of his maternal grandmother, Donna L. Schorr, since the summer of 2006 and the parties desire that Donna Schorr be awarded both legal and physical custody of the child. 4. The parties all jointly request the Court of Common Pleas of Cumberland County to enter the attached Order awarding Donna L. Schorr legal and physical custody of the child. IN WITNESS WHEREOF the parties hereto have set their hands and seals this 13 day of February 2010. Date: c2-' 3- ?O Date: x-13.10 Date: 2-13-Ic7 I PaX4,Q ?f ? ? Donna L. Schorr JCO&-D WU4? Scott D. Hardy Je fifer Keel COMMONWEALTH OF PENNSYLVANIA ) (SS.: COUNTY OF CUMBERLAND ) On this, the IS day of 2010, before me, a Notary Public, the undersigned officer, personally appeared DONNA L. SCHORR known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that said person executed the same for the purposes therein contained. IN WITNESS WHEREOF, I wof aria( soar Joseph L. Grove, Notary Pi blic silver d'prinp'fwp., Curnberland County my Crtrm 'e,n_" xpi'. 13 -1U 29 ,. r..f t .ffi3 ASSGC?t. .?i P set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA ) ( SS.: COUNTY OF CUMBERLAND ) On this, the 13 day of 2010, before me, a Notary Public, the undersigned officer, personally appeared SCOTT D. HARDY known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that said person executed the same for the purposes therein contained. IN WITNESS WHEREOF, Notary my hand and official seal. hlotariai Seal Ju> ;'r i_. Grove, Nowr I': Silver Siring `fwp., C18 °i:!i-arCounty hqy Cr. a mission Expse4 !` .2073 Nqr,,,, ?,, i'ennsylvania A ? r?aon of Notarl0s COMMONWEALTH OF PENNSYLVANIA ) (SS.: COUNTY OF CUMBERLAND ) On this, the 1-3S day of 2010, before me, a Notary Public, the undersigned officer, personally appeared JENNIFER KEELEY known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that said person executed the same for the purposes therein contained. IN WITNESS WHEREOF, I N my hand and official seal. Notarial ° ! f oseph L. Grove, Noir e l Spring'rwp :,,,v Commission ~~ DONNA L. SCHORR, Plaintiff vs. SCOTT D. HARDY and JENNIFER KEELEY, Defendant ~E~ ~ 4 tolU~ oL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. ~o - l lq o l~ivil ~erw~ IN DIVORCE ORDER OF COURT ~a AND NOW this '~. ~ day of ~ e.~p rJ4r ~ , 2010, upon the Petition of Donna L. Schorr and the written Stipulation of the parties, we hereby order and decree as follows: 1. Legal and physical custody of the minor child, Isaac Benjamin Hardy, age 12, born 7 j' September 1997, is hereby awarded to the Plaintiff, the child's maternal grandmother, Donna L. Schorr. 2. The biological parents of the child, his mother Jennifer Keeley and his father Scott D. Hardy, shall have such periods of temporary physical custody of the child as all three parties may agree. In the event that the parties cannot agree, any party may petition this court to set a schedule of physical custody for the child. BY THE COURT, ~~ J. ~'? "' r_. c~~~ ~.; -*-t _~. ~.~ Distribution: - ~,~; R~ r G~ Samuel L. Andes, Esquire (Attorney for Plaintiff) ~.,~ 525 North 12th Street, P.O. Box 168, Lemoyne, Pa 17043 _ w: ' °4`' ~. ~ .: ~ Mr. Scott D. Hardy (Defendant) '~-- 208 West Ridge Road, Dillsburg, PA 17019 CD~ t ~. ,,n ~ ~ ~~ C ~. Jennifer Keeley (Defendant) ~l~ S"~~ P.O. Box 473, New Kingstown, PA 17072 ~_~ ..,~ -,- ;~_ -y-- , ;_, `'_ ~:; ; ~;,.., .A;