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Home My WebLink About05-0165 II I! RANDY R. KAUFFMAN, : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PA : NO. 0 -.J.......... / I {.g .;- : CIVIL ACTION - LAW : IN CUSTODY Plaintiff VS. CRYSTAL YVONNE PETERS, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 II RANDY R. KAUFFMAN, : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PA Plaintiff VS. : NO. CRYSTAL YVONNE PETERS, Defendant : CIVIL ACTION - LAW : IN CUSTODY NOTICIA USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion dentro de veinte (20) dias a partir de la fecha en que recibio la demanda y el aviso. Usted debe presentar comparecencia esrita en persona 0 por abogado y presentar en la Corte por escrito sus defensas 0 sus objeciones alas demandas en su contra. Se Ie avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso 0 notificaion por cualquier dinero reclamado en la demanda 0 por cualquier otra queja 0 compensacion reclamados por el Demandante. USTED PUEDE PERDER DINERO, 0 PROPIEDADES U OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE 0 NO CONOCE UN ABODAGO, V A Y A 0 LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA A VERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 11 RANDY R. KAUFFMAN, : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PA Plaintiff VS. : NO. CRYSTAL YVONNE PETERS, Defendant : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY ,I AND NOW, TO WIT, this ?~y of , 005, comes the Plaintiff, Randy R. Kauffman, by and throu 's attorney, Jane M. and files this Complaint of which the followin i 1. Plaintiff is Randy R. Kauffman, an adult individuals residing at 331 5th Street, New Cumberland, Borough of New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant is Crystal Yvonne Peters, an adult individuals residing at 1216 W. Jefferson Street, Plymouth, Indiana 46563. 3. Plaintiff seeks legal custody and primary physical custody with scheduled visits for Defendant with the following children: David Alan Lauffer, age 8, born December 30, 1996 and Allie Louise Lauffer, age 6, born March 9, 1998. 4. The parties never married but lived together from 1995 to 1997. S. The children are presently in physical custody of Plaintiff, Randy R. Kauffman, who resides at 331 5th Street, New Cumberland, Borough of New Cumberland, Cumberland County, Pennsylvania 17070. 6. There is no prior custody order: 7. The children have lived with their mother since September 1997 at 332 5th Street, New Cumberland, Pennsylvania until mother moved to Ebensburg, Pennsylvania September 9, 1998. Mother and children moved to the Indianapolis area in 2001. She married Dale Peters and they have lived in various hotels and motels in the Indianapolis area such as the Waterberry Inn, Inn America and presently the Plymouth Hotel from 2001 to July 4,2004. II The Plaintiff had custody for purpose of visitation every Christmas and five (5) weeks each summer by agreement of the parties. The Plaintiff received the children July 4,2004 and they have been living with him since that date. They are enrolled in Hillside Elementary School, West Shore School District. Defendant has not seen the children since July 4,2004. 8. The relationship of the Plaintiff to the children is that of natural father. 9. The relationship of the Defendant to the children is that of natural mother. 10. The Plaintiff has not participated as a party or as a witness, or in any other capacity, in other litigation concerning the custody of the children in this or another court. 11. The Plaintiff has no information of a custody proceeding concerning the children pending in any other court within the Commonwealth. 12. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 13. The best interest and permanent welfare of the children will be best served by granting the Plaintiff joint legal and primary physical custody of the children with the Defendant having custody for purpose of visitation. Plaintiff has been and is able to provide a good home, stable environment and supervision for the children. Defendant has no adequate facilities to care for the children and no stable home. WHEREFORE, Plaintiff requests your Honorable Court to grant him joint legal custody and primary physical custody of the subject children with reasonable visitation to Defendant. ,spectfully _submitted, ~e M AI~;:qUire ttorney fO~~:tiff Attorney I.D. #07355 148 S. Baltimore Street Dillsburg, PA 17019-0421 (717) 432-4514 II Verification I verify that the statements made in this Petition for custody are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATEf-<~(f ~ ~s--' 6:cv-JR ~ Randy R. Kauffman COMMONWEALTH OF PENNSYLVANIA S.S. COUNTY OF YORK Before me, the undersigned officer, a Notary Public, in and for the said Commonwealth and County, Personally appeared Randy R. Kauffman who, being affirmed according to law, deposes and says that the facts and matters set forth in the foregoing Complaint are true and correct to the best of his knowledge, information and belief tIoov;i.!.;1- Sworn to and subscribed before me this 6 ~ day of.J~ ,2005. >:{lj/ J Notary Public ~~ r NoolnOl Seal - .~. ...~. Hal.o B. A....... ~ PIbIIc My~~~~ltmt MlIrtl9r....."L...;:A.~..... - 1 Y ~ It ~ ~~ ~"~l.:~.r:.:.. cb ;~r~ , _ ___ ... _ !J..-n . -.' . .;.. -~ (-<,'~"':J--' -_..':--,. ">.--~ ',':'. .' .c.~"";,. '.',.~.~--n ..j~" ~.'~ "'-;-~.2'~ 5-"~ ( c::?CS '::\--\ ~~:1 ;-:: : ~.. ~~'::~ J--..3 _<._.-1 ~) VJ . -'1. :-< ---< (.J"\ C' '-, Q C7 ~~:,~ ~ n "', <':'.::J> 0 c: c::.:.::> " CJI .1 -. (- -l J :7..... I-n :;~ rill"'" "':,,:'"' -TJI-n 0 ~:J? e ~ \ .. ~~O :1:;.'" --';''' .-rl () /~: ~ -- ~~? 25 --"-"" ~ ;,:::..... c" Cl c:5 i f1 :;:0: - ., ~ =<! <'.l ):".~ ~~D ......... "'- ........ C", ..< - CA 0 V- I tf " ~ X ()' RANDY R. KAUFFMAN PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V. 05-165 CIVIL ACTION LA W CRYSTAL YVONNE PETERS DEFENDANT IN CUSTODY ORDER OF COURT AND NOW. Friday, January 14, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at DJ Manlove's, 1901 State St., Camp Hill, PA 17011 on Friday, February 11,2005 at II :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. All children age five or older may also be present at the conference. 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 existin'g Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: Isl Melissa P. Greevy, Esq. 'f':~ 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 infonnation about accessible facilities and reasonable accommodations available to disabled individuals having business before the COlll't, please contact our office. All arrangements must be made at least n 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 HA VE 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 S':rcet Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~?~ J;;v :;z ~..?U/ ~G'? ...yZ7-.A/ r .~-# ~r~;r.;>-9:-""d::; .><./ /7/ / ~;;vu-~ k.?2 ~ ~~ 4ji?p /?? /7/,/ "',' ['j ',C' !,..L.l. ':-'1 ~j\jr {:ll\r~7 ,.. ') 11,,', _, '...I,j '". .J,.... ;:j:~l :1:] II RANDY R KAUFFMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF (;UMBERLAND COUNTY, PA VS. NO. 05-165 CRYSTAL YVONNE PETERS, Defendant CIVIL ACTION - LAW IN CUSTODY AFFIDAVIT OF SI:RVICE AND NOW, Ihis 15 ~ day of LJ~AW\:J ,2005 personally appeared Jane M. Alexander, Esquire who swears according to law, that a true and correct copy of a COMPLAINT FOR CUSTODY was caused to be served by certified mail with return receipt requested upon the said, Crystal Yvonne Peters Plymouth Hotel Room 4 1216 W. Jefferson Street Plymouth, Indiana 46563 on Januarv 19. 2005 by leaving the same at the Dillsburg Post Office with postage pre-paid thereon as evidenced by the mailing receipt and reIum receipt hereto attached and made a part hereof Sworn and subscribed before me !bis ,LB:0!: day of -.-J.kJU.-u..--,4f~ , 2005. UL..// '_/L_ / Notary Publ~ Norarlai ScaI ;]' lfIIMa,," ~llIc . "y~~.-r:iOO$ ...... II RANDY R. KAUFFMAN, Plaintiff VS. CRYSTAL YVONNE PETERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO. 05-165 CIVIL ACTION - LAW IN C1USTODY PROOF OF SERVICE I II I LO 1'- C] "" U.S. Postal Service". CERTIFIED MAIL" RE<CEIPT (Domestic Mail Onlyj No Insurance overage Provided) ~ LO m ..n Ordi"6 Io~ I Postage $ m CJ Certified Fee C] Cl Return Reclept Fee U. 75 (Endorsement Required) Cl Restricted Delivery Fee U1 (EndorsemEll'lt ReqUIred) 1'- C] Total Postage & Fees $ 0019 IAN011~05 $3.50 f8.15 \.. ~ g en' 0 &~stl'l YVOMe. ?dus 1'- 1!bio&f.-"';;;:No.:--pT"M'~--"fl<,"".f.--"-~~';;;;--+"''''''''''''--''''''- ~~~.~_~:____.I!J.I..._w...~(';E.~.___~f.M<1.____.....__..___ City, State, Z/P+4 Ply..o....tlo, :LMr,,-_.~ 4(p5("~ . Complete items 1, 2, and 3. Also complete item 4 jf Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front ce permits. 1. Article Addres c'r~~tp.1 y f'1:1ff1o....tt. ~. 4 \ ~\lD vv. ~f-h(s,,\'\ SteLl.:\ f~"'ol,<.th, J:.VldiltlM 446(, '3 2. ArtiCle Number (Copy from ssrvice labeO a Agent a Address.. Dves DNo 3. service Type ~ertified Mail CI Express Mail o Registered 0 Retum Receipt for Merchandise o Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 7004 0750 0003 6354 )Slves 8075 102595-oo.M-0952 PS Form 3811, July 1999 Domestic Return Receipt (--, I.,) , CJ ~,) (,n 'J' --.( :-i'- ""1 HB 1 8 ;'[\11' d- RANDY R. KAUFFMAN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 05-165 CIVIL TERM v. CIVIL ACTION - LAW CRYSTAL YVONNE PETERS, IN CUSTODY Defendant TEMPORARY ORDER OF COURT AND NOW, this z-.f day of February, 2005, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. LeQal Custody. The parties, Randy R. Kauffman and Crystal Yvonne Peters, shall have shared legal custody of the minor children, David Alan Lauffer, born December 30, 1996, and Allie Louise Lauffer, born March 9, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa. C. S. 95309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to, medical, dental, religious or school records, the residence address of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Father shall have temporary primary physical custody of the children. Mother shall have partial custody in Cumberland County, Pennsylvania with the specific times arranged by mutual agreement of the parties and upon one (1) week's notice to Father. 3. This Order is temporary in nature. The parties may deviate from its terms by their mutual agreement. However, in the absence of their mutual agreement, the terms of the Order shall control. This Order is modifiable upon proper petition aft~which a Custody Conciliation Conference will be scheduled in the ord.inary ~e. c;;/ . // ;:> / BY THJ;/COURT: f J. Dist: ,....Jane M. Alexander, Esquire. 148 S. Baltimore Street, Dillsburg, PA 17019 > /rystal Yvonne Peters, 16814 Mill Pond Trail, Plymouth, IN 46563 O:'.l-~5-0-5 ..:J'- :=s & ,z: c.- ~ ~ \l.... ~ fEB 1 8 200: .r/ (Ii RANDY R. KAUFFMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA NO. 05-165 CIVIL TERM v. CIVIL ACTION - LAW CRYSTAL YVONNE PETERS, IN CUSTODY Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF David Alan Lauffer Allie Louise Lauffer December 30,1996 Father March 9,1998 Father 2. Father filed a Complaint for Custody on January 10, 2005. A Custody Conciliation Conference was held on February 11. 2005. Present for the conference were: the Father, Randy R. Kauffman, and his counsel. Jane M. Alexander, Esquire; the Mother, Crystal Yvonne Peters, participated by telephone only. She was not represented by counsel. 3. attached. The parties reached an agreement in the form of a Temporary Order as ?-li/ los D te I ~(k'~E~";" Custody Conciliator :244840