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Home My WebLink About02-1352VINCENT KIEHL, VS, EMILY GRIPPIN, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. - CIVIL TERM CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Vincent Kiehl, residing at 1418 Holly Pike, Carlisle, Cumberland County, PA. 2. The Defendant is Emily Grippin, Jr., residing at 304 West College Street, Enterprise, AL. 3. The Plaintiff seeks custody of the following child: Name Present Residence Age Jonah Darr 304 West College Street, Enterprise, AL 7 years The child was born out of wedlock. The child is presently in the custody of Emily Grippin, who resides at 304 West College Street, Enterprise, AL. 4. During the child's lifetime, he has resided with the following persons and at the following addresses: Name Address Emily Grippin 304 West College Street, Enterprise, AL The mother of the child is Emily Grippin, currently residing at 304 West College Street, Enterprise, AL. The father of the child is Vincent Kiehl, currently residing at 1418 Holly Pike, Carlisle, PA. He is not married. 4. The relationship of Plaintiff to the child is that of Father. 5. The relationship of Defendant to the child is that of Mother. The Defendant currently resides with the following persons: Name Relationship Emily Grippin Mother Ryan Grippin Current or former husband 6. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or any other court. 7, The Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. The Plaintiff 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. 9. The best interest and permanent welfare of the child will be served by granting the relief requested, 10. Each parent whose parental rights to the child have not been terminated has been named as parties to this action. WHEREFORE, the Plaintiff requests that this Court grants liberal visitation of the child to him, Respectfully submitted, Aborn & Kutulakis, L.L.P. Date: ~-' '~/J ,2002 Ja~r~ P, K'utulakis, Esquire I,D, #80411 8 South Hanover Street, Suite 1204 Carlisle, PA 17013 717-249-0900 Attorney for Plaintiff VINCENT KIEH_L , Plaintiff EMILY GRIPPIN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERM CUSTODY VERIFICATION I verify that the statements made in the foregoing Complaint for Custody are tree and correct. I understand that false statements herein are made subject to the penalties 18 Pa, CS. 24904, relating to unsxvom falsifications to authorities. Da~e -- Vincent ~ie~"- VINCENT KIEHL, Plaintiff VS. EMILY GRIPPIN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERI,AND COUNTY, : PENNSYLVANIA CUSTODY CERTIFICATE OF SERVICE I, Jason P. Kumlakis, Esquire, hereby certify that on this 19th day of M~ch, 2002, a tree and correct copy of the within CUSTODY COMPLAINT was served upon Defendant by Certified United States Mail, First Class, postage pre-paid, addressed as follows: Emily Grippin 304 West College Street Enterprise, AL 38330 Jain P. Kumlakis VINCENT KIEHL : : PLAINTIFF : V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-1352 CIVIL ACTION LAW EMILY G1LIPPIN DEFENDANT : 1N CUSTODY ORDER OF COURT AND NOW, Monday, March 25, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , thc conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, April 26, 2002 at 10:30 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 thc 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 thc conference may provide grounds for entry ora 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/ Hubert X. Gilrov. Esa. 'v,n,- Custody Conciliator ' O' 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 heating 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 VINCENT KIEHL, Plaintiff v EMILY GRIPPEN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 02- 1352 CIVIL : IN CUSTODY COURT ORDER AND NOW, this ~) day of /Ja,_k0~, ( , 2002, the conciliator being advised that the parties have reached an agreement, the conciliator relinquishes jurisdiction. BY THE COURT, JUN ] 3 2002 VINCENT KIEHL, Plaintiff V EMILY GRIPPEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02 - 1352 CIVIL IN CUSTODY COURT ORDER AND NOW, this day of /~'~'~ ,2002, the concilia!or.b.e, ing advised that the parties have reached an agreemedt, the conciliator relinquishes jurisdiction. BY THE COURT, VlNVA'IXSNN3d ,LLNFIOD QNbqLq.~RflO AbrVJ.ONOH.LOWd ~HJ. qO