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HomeMy WebLinkAbout05-2289 v. : IN THE COURT OF COMMON PLEAS OF , : CUMBERLAND COUNTY, PENNSYLVANI,t. : NO.~ .I.l.8'1CIVIL TERM JODY L. KELLER, Plaintiff ROSS M. RICHWINE, Defendant : IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Jody L. Keller, residing at 7 Tanger Road, Boiling Springs, Cumberland C unty, Pennsylvania. 2. The defendant is Ross M. Richwine, residing at 7 Maurice Road, Mt Holly Springs, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following child: Name Present Residence Seth Emory Richwine 7 Tanger Road, Boiling Springs, PA 17007 The child was not born out of wedlock. The child is presently in the custody of Mother. During the past four years, the child has resided with the following person and at the folio address: Person Mike & Jody Keller Jody Richwine & parents Ross & Jody Richwine Ross & Jody Richwine AQe 3 Address 7 Tanger Road, Boiling Springs, PA 17007 115 Sycamore Drive, Mt Holly Spgs, PA 7 Maurice Road, Mt Holly Spgs, PA 410 N. Walnut Street, Mt Holly Spgs, PA The mother of the child is Jody L. Keller residing at 7 Tanger Road, Boiling Springs, PA. She is married. I The father of the child is Ross M. Richwine. residing at 7 Maurice Road, Mt Holly Springs~ PA. He is unmarried. ' 4, The relationship of plaintiff to the child is that of mother. The plaintiff currently resides th the following persons: Name Relationshio Michael Keller Husband Jenna Keller Step-Daughter Kara Keller Step-Daughter Mary Ellen Keller Mother-in-law ~ Seth Richwine Son 5, The relationship of defendant to the child is that of father. The defendant currently resi s with the following persons: Name Pegan Day I I I I 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigatj,.,n concerning the custody of the child in this or another court. r I I Relationship Fiancee . Plaintiff has no information of a custody proceeding concerning the child pending in a courtJ;of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custod of the child or claims to have custody or visitation rights with respect to the child. . 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) Plaintiff can provide the child with a home with adequate moral, emotional and physical I surroundings as required to meet the child's needs; b) Plaintiff is willing to accept custody of the child; c) Plaintiff continues to exercise parental duties and enjoys the love and affection of the ch Id. 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, na d below, who are known to have or claim a right to custody or visitation of the child will be given noti of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE Wherefore, plaintiff requests the court to grant her primary custody of the child. I verify that to best of my knowledge and belief, the statements made in this Complaint ari true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C,S.!l4904 relating to unsworn falsification to authorities. 0 ~ ~(\ ~ ~ '" l:; -.....: fj' "- w ~ \..J Vo, L..,) c:-:\ ~ ~ p ", = C-;::) c.n fi4 =r' hl:rJ r~.- -;-J;"T' _"dO ::~(L, .~;~ ~1~ l..jrn ~~-I :'J:J --< ~ -I'>> ;,::oc. -' , .<:- ;,'!>. ~- --",~ '2 JODY L. KELLER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA V. 05-2289 CIVIL ACTION LAW ROSS M. RICHWINE IN CUSTODY DEFENDANT ORDER OF COURT AND NOW. Wednesday, May 11, 200~_.__,.___, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse,_ Carlisle on Thursday, May 26, 2005 , the conciliator, at 111:30 ,AM for a Pre-Hearing Custody Conference. At such conference, an effort win bc made to resolve the issues in dispute; or if this cannot be accomplished, to detinc and narrow the issues to be heard by the court, and to enter into a temporary order. An children age tive 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 existing Protection from Abuse orders, Special Relief orders. and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: Isl Hubert X; Gi1ro~~.......1__ 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 ~ ~-JI. ......., ~d 4;r~7 5;;' U-y '~ 7 /'(j"v>W :~~ Xl ~Jt> ~9" f;= ;:z ~-=v '~.7 /'79 Jr/' F'/5' , ;..; "'1 .'" "I t.- t~ .~. ,.'::_ S I }, \'!,j SOUZ JODY L. KELLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-2289 CIVIL TERM ROSS M. RICHWINE, Defendant : IN CUSTODY STIPULATION FOR CUSTODY STIPULATION made this J1AII~ day of May, 2005, between Jody L. Keller, hereinafter referred to as Mother, and~ Richwine, hereinafter referred to as Father. WHEREAS, the above-named Mother and Father had born to them the following child on the following date: NAME Seth Emory Richwine BIRTH DATE May 31, 2001 AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the custody of the above-said child and to the partial custody rights of the non-custodial parent: NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and Father hereby stipulate that: 1. The Mother and Father shall share legal custody of the child. 2. The Mother shall have primary physical custody of the child. 3, The Father shall have periods of partial custody as follows: a. every other weekend, b. visits during the week as agreed by the parties, c. two to three weeks during the summer, and d. an equal division of the major holidays. 4. Neither spouses nor fiancees of the parents shall physically discipline the child. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court. Witness: & /. )S9-s 6~? ka:; r~IIer, Mother .~ f~-Y ~ Ross M. Rlc win ,Father ___.v___'_.~_._ (') <--' ~-c:c:, ce,,> <..,-' \.-~) -il ...,,1 '''- h1 ~'.) C~) ('., JODY L. KELLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-2289 CIVIL TERM pA RECEIVED MAY 241005 ROSS M. RICHWINE, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this ZS' day of May, 2005, upon consideration of the attached custody stipulation with respect to the parties' child, Seth Emory Richwine, born May 31, 2001, the terms of the stipulation are entered as an order of court, BY THE COURT, , /lJ J. ~say Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 ~'M. Richwine 7 Maurice Road Mt. Holly Springs, PA 17065 ~ l:' :;'~"^' i] f,--:l lJ '-, ',\ .~ I' RECEIVED JUN 022005::;1 JODY L. KELLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW ROSS M. RICHWINE, Defendant NO. 05-2289 IN CUSTODY COURT ORDER ~F AND NOW, this ]i day of k~ ' 2005, The Conciliator being advised the parties have reached an agreement, the Co iliator relinqUIShes JunsdictIon. a C I '2 ., j ".!j '., ,,',":" - ""I"'I'J7 (;.- i,:i:, ~Ji... Ll ::1)