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HomeMy WebLinkAbout02-1450KEVIN HOVET, Plaintiff KIM I. VAN ALKEMADE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002- I~/gO CIVIL ACTION - LAW IN CUSTODY COMPLAINT Plaintiffis Kevin Hovet, who currentlyresides at 241 East King Street, Shippensburg, Cumberland County. 2. Defendant is Kim I. Van Alkemade, who currently resides at 241 East King Street, Shippensburg, Cumberland County. 3. Plaintiff seeks custody of the child, Alexandria Van Alkemade Hovet, who was bom on July 17, 1992. The child was not born out of wedlock. Since the child's birth, the child has resided with the parties. 4. The relationship of the Plaintiff to the child is that of father. He is married and living with Defendant, though they have been legally separated since August 27, 2001. The Plaintiff currently resides with the following: Name Relationship Kim I. Van Alkemade Wife Alexandria Van Alkemade Hovet Daughter The relationship of the Defendant to the child is that of mother. She is married and living with Plaintiff, though they have been legally separated since August 27, 2001. The Defendant currently resides with the following: Name Relationship Kevin Hovet Husband Alexandria Van Alkemade Hovet Daughter 6. The parties have not participated in previous litigation concerning the custody of the child in this court or any court. 7. The Plaintiff has no information of a custody proceeding concerning the child pending in any other court. 8. The best interest and permanent welfare of the child will be served by granting custody to Plaintiff because: he can provide a stable and nurturing environment for his daughter. 9. Plaintiff does not know of any person not a party to these proceedings who claims to have custody or visitation rights with respect to the child. WHEREFORE, Plaintiff requests your Honorable Court to set a time and place for a hearing at which Plaintiff requests the Court to grant him the Custody Order. Pending said hearing, Plaintiff requests temporary custody. Date: March 25, 2002 MARTSON DEARDORFF WILLIAMS & OTTO Thomas J. W l~iams, Esquire Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff VERIFICATION The foregoing Custody Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is tree and correct to the best of my knowledge, infottxxation and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Kevin Hovet KEVIN HOVET : : PLAINTIFF : V. KIM I. VAN ALKEMADE DEFENDANT : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-1450 CIVIL ACTION LAW IN CUSTODY AND NOW, Tuesday, April 02, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, May 02, 2002 at 9:30 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 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/ [acaueline M. Vernev. Esa. 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 heating or business before the court. You must attend the scheduled conference or heating. 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 C) C: KEVIN HOVET, Plaintiff KIM I. VAN ALKEMADE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-/~..~9 CIVIL ACTION - LAW IN CUSTODY ATTORNEY'S ACCEPTANCE OF SERVICE I, Carol J. Lindsay, Esquire, attorney for Defendant Kim I. Van Alkemade in the above-captioned action, hereby accept service of the Custody Complaint in the above action on : ../~tS~(..~ 7~ ~ 7AY/'~ ~ on her behalf and certify that I am authorized to do so. MARTSON DEARDORFF WILLIAMS & OTTO Carol J. Lindsa)~g/~;.$~'u~r,- x 26 West High St~et Carlisle, PA 17013 Attorneys for Defendant SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA KEVIN HOVET, VS. KlM I. VAN ALKEMADE, PLAINTIFF DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002- 1450 ClVlL TERM IN CUSTODY 1992. 2. 3. Alexandria. 4. STIPULATION FOR CUSTODY OF THE PARTIES The parties hereto stipulate as follows: They are the parents of Alexandria Van Alkemade Hovet, born July 17, The parties will no longer be residing together as of May 15, 2002. Effective May 15, 2002, the parties will share legal custody of their child, Klm I. Van Alkemade, hereafter Mother, shall have primary physical custody of the child and Kevin Hovet, hereinafter Father, shall have partial custody of the child as follows: A. On alternating weekends from Friday late afternoon or evening until Sunday late afternoon or evening. B. For three weeks during the summer. Mother shall custody of the child for three uninterrupted weeks in the summer as well. The parties shall provide each other with notice as to the dates they intend to exercise their vacation time in the summer at least 60 days prior to the vacation. SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA 5. The parties will alternate the major holidays of Memorial Day, Fourth of July, and Labor Day. The parties will share custody of the child on the Thanksgiving break from school in a manner acceptable to both of them. 6. Mother will have custody of the child from the day school is out for the Christmas vacation until 10:00 a.m. on Christmas Day, and Father will have custody of the child on Christmas Day at 10:00 a.m. until New Year's Day at 10:00 a.m. 8. Order of Court. - ~ewn Hovet Date At such other times as the parties can agree. The parties intend for the terms of this Stipulation to be entered as an Klm I. Van Alkemade ~at~~ 2 SAIDIS SHUFF, FLOWER & LINDSAY ATTOR/~YS*AT.LAW 26 W. High Street Carlisle, PA KEVIN HOVET, vs. KlM I. VAN ALKEMADE, PLAINTIFF DEFENDANT : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2002- 1450 ClVIL TERM : : IN CUSTODY ORDER OF COURT AND NOW THIS ~' -~/ DAY OF f'Y'~/ , 2002, upon consideration of the within STIPULATION FOR CUSTODY OF THE PARTIES, the terms of the said stipulation are hereby made an Order of Court. BY THE COURT,