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Home My WebLink About01-5339FAITH A.E. IMLER, Plaintiff CHRISTOPHER SPENCER, K. KRISTOPHER KAN-E, & CHARLENE L. KANE Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - AT LAW FOR CUSTODY OO~PLAXNT FOR CUSTOD¥ The Plaintiff, FAITH A.E. IMLER, by and through her attorney, The Law Offices of Patrick Lauer, Jr., files this Complaint for Custody against the Defendants, CHRISTOPHER SPENCER, K. KRISTOPHER KANE, and CHARLENE L. KANE, and in support thereof, avers the following: 1. The Plaintiff is Faith A.E. Imler, an adult individual and the natural mother, who currently resides at 1061 Oyster Mill Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendants are Christopher Spencer, an adult individual and the natural Father, who currently resides at RD 1, Hesston, Huntingdon County, Pennsylvania 16647, and K. Kristopher and Charlene Kane, Uncle and Aunt, who currently reside at P.O. Box 8, Oakland Mills, Juniata County, Pennsylvania 17076. 3. The Plaintiff seeks custody of the following child: Name Present Residenc~ Age Christopher 1061 Oyster Mill Road 10 Logan Spencer Camp Hill, PA 17050 (February 13, 1991) The child was not born out of wedlock. The child is presently in the custody of his mother, Faith A.E. Imler, who resides at 1061 Oyster Mill Road, Camp Hill, Pennsylvania. During the p~st following persons and at the following addresses: _Name Faith A.E. and William Imler K. Kristopher and Charlene Kane, and Their two children Address 1061 Oyster Mill Road, Camp Hill, Pennsylvania P.O. Box 8, Oakland Mills, Pennsylvania five years, the child resided with the Dates 8/01-current 9/96-8/2001 The Father of the child is Christopher Spencer, residing at RD 1, Hesston, Pennsylvania 16647. He is single. currently The Mother of the child is Faith A.E. Imler, currently residing at 1061 Oyster Mill Road, Camp Hill, Pennsylvania 17011. She is married. 4. The relationship of the plaintiff to the child is that of natural Mother. The plaintiff currently resides with the following persons: Ns/Re William Imler 5. The relationship of the defendant, the child is that of natural Father. resides with the following persons: Relationship Husband Christopher Spencer, to The defendant currently Name David & Barbara Forem~n Relationship Friend The relationship of the defendants, K. Kristopher and Charlen Kane, to the child is that of Uncle and Aunt. The defendants currently resides with the following persons: Name Brian J. Kane peanne C. Kane Relationship Son Daughter 6. Plaintiff has participated as a party in other litigation concerning the custody of the child in another court. The court, term and number, and its relationship to this action is: Court of Common Pleas of Juniata County, No. 376 of 1996, prior custody order, and Court of Common Pleas of Dauphin County, No 845 S 1995, Divorce. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have physical custody or visitation rights with respect to the child. 7. The best interests and permanent welfare of the child will be served by granting the relief requested because: (a) Plaintiff is the natural Mother of the child. (b) The child currently resides with Plaintiff. (c) Plaintiff and Defendants have agreed to the terms and conditions set forth in the attached Stipulation. 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. No other persons are known to have or claim a right to custody or visitation of the child to be given notice of the pendency of this action and the right to intervene. WHEREFORE, Plaintiff respectfully requests this Court to enter an Order granting to her custody of her accordance with the Stipulation of the parties. Honorable child in Respectfully submitted, ~Marlin L. Markley, Esquire Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 PA Supreme Ct. ID No. 84745 Phone: (717) 763-1800 ATTORNEY FOR PLAINTIFF FAITH A.E. IMLER, Plaintiff v. : No. : CHRISTOPHER SPENCER, : K. KI%ISTOPHER KANE, & : CHARLENE L. KANE : Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - AT LAW FOR CUSTODY VERIFICATION I, Faith A.E. Imler, state that I am the Plaintiff in the above-captioned case and that the facts set forth in the above Complaint for Custody are true and correct to the best of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S. ~ 4940. Faith A.E. Imler Date FAITH A.E. IMLER, Plaintiff Vo CHRISTOPHER SPENCER, K. KRISTOPHER KANE, & CHARLENE L. KANE Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVkNIA : : : CIVIL ACTION - AT LAW : FOR CUSTODY : : STIPULATION WHERF2~S, the subject of this stipulation for custody is the Plaintiff's and Defendant's, Christopher Spencer, child, namely Christopher Logan Spencer, born February 13, 1991; and WHEREAS, the parties wish to enter into an agreement relative to custody, partial custody, and visitation of the child; and WHEREAS, it is in the best interest of the child that this Court decide the matter because the child and his mother live in Cumberland County, Pennsylvania, it is the desire of both parents and all parties involved that mother in Cumberland County, and the Child continue his in cumberland County, thus giving this Court jurisdiction; THEREFORE, this //F% day of &~.~/~ the child continue to live with his education consideration of the mutual hereinafter set forth, and parties agree as follows: 1. Father and Mother the Child, Christopher Logan Spe'ncer. 2. The Mother, Faith A.E. Imler, physical custody of the Child, subject to shall share jointly legal custody of shall have primary periods of partial 2001, in covenants, promises, and agreements as intending to be legally bound, the physical custody in Father as follows: the parties. 3. This stipulation may only consent of Mother and Father. 5. It is the intention and undersigned parties that this of court, without requiring pursuant to Rule 1915.7. as mutually agreed upon by be altered by the mutual desire of each of the Stipulation be confirmed as an order their presence before the court, Faith A.E. Imler ~nristop~er Sp~cer Charl%ne Kane ~ FAITH A.E. IMLER, Plaintiff CHRISTOPHER SPENCER, K. KRISTOPHER KANE, & CHABLENE L. KANE De f endant s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. I- : : CIVIL ACTION - AT LAW : FOR CUSTODY : : CONSENT ORDER AND NOW, this ~ day of ~ consideration of the above-captioned matter, consisting of two written consent of the parties, 2001, upon attached Stipulation of the parties in the pages and bearing the AND upon direction of this court that the parties need not be present before the court in order to incorporate their Stipulation into a consent order, IT IS ORDERED that said Stipulation is incorporated herein by reference as if set forth in full and approved as a Consent Order pursuant to Pennsylvania Rule of Civil Procedure, Rule 1915.7· BY THE C~/~ FAITH A.E. IFLLER, Plaintiff CHRISTOPHER SPENCER, K. KRISTOPHER KANE, & CHARLENE L. KANE Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : : CIVIL ACTION - AT LA~ : FOR CUSTODY : : ~TIP~LATION WHEREAS, the subject of this stipulation for custody is the Plaintiff's and Defendant's, Christopher Spencer, child, namely Christopher Logan Spencer, born February 13, 1991; and WHEREAS, the parties wish to enter into an agreement relative to custody, partial custody, and visitation of the child; and WHEREAS, it is in the best interest of the child that this Court decide the matter because the child and his mother live in Cumberland County, Pennsylvania, it is the desire of both parents and all parties involved that the child continue to live with his mother in Cumberland County, and the Child continue his education in Cumberland County, thus giving this Court jurisdiction; THEREFORE, this //F% day of &~/~A ¢~ 2001, in consideration of the mutual covenants, promises, and agreements as hereinafter set forth, and intending to be legally bound, the parties agree as follows: 1. Father and Mother shall share jointly legal custody of the Child, Christopher Logan Spe'ncer. 2. The Mother, Faith A.E. Imler, shall have primary physical custody of the Child, subject to periods of partial physical custody in Father as follows: the parties. 3. This stipulation may only consent of Mother and Father. 5. It is the intention and under§igned parties that this Stipulation be of court, without requiring their pursuant to Rule 1915.7. as mutually agreed upon by be altered by the mutual Faith A.E. Imler desire of each of the confirmed as an order presence before the court, 'rfSristopher Sp~cer Charlene Kane ~