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Home My WebLink About06-3861 Lori K. Serratelli, Esquire Pa. Supreme Court 10 No. 27426 Serratelli, Schiffman, Brown and 2080 Linglestown Road Suite 201 Harrisburg, Pennsylvania 17110 Telephone (717) 540-9170 Fax (717) 540-5481 Attorney For Plaintiff Calhoon, P.C. JANETTE A. LINE, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 0(.. - 3PC.( ~;ui.L ~€fl..h-.t CIVIL ACTION - LAW l CHRISTOPHER A. KARLSEN, Defendant CUSTODY CUSTODY COMPLAINT TO THE HONORABLE, THE JUDGES OF SAID COURT: 1. The Plaintiff is Janette A. Line, who currently resides at 125 Northgate Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is Christopher A. Karlsen, whose current address is unknown, but whose parents reside at 291 South Locust Point Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff seeks primary physical custody and legal custody of the parties' one (1) minor child, Xavier R. Karlsen, born May 18, 2005. 4. The child was born out of wedlock. 5. The child is currently in the custody of the Janette A. Line, Plaintiff, who resides at 125 Northgate Drive, Camp Hill, , Cumberland County, Pennsylvania. 6. Since the child's birth, the child has resided with the following persons and at the following addresses: Persons Address Dates Janette A. Line Greta Guilday (maternal grandmother) 125 Northgate Drive Camp Hill, PA Birth to Present 7. The father of the child is Christopher A. Karlsen, whose current address is unknown, but whose parents reside at 291 South Locust Point Road, Mechanicsburg, Cumberland County, Pennsylvania. 8. The relationship of Plaintiff, Janette A. Line, to the child is that of mother. The Plaintiff currently resides with Greta Guilday, Plaintiff's mother. 9. The relationship of Defendant to the child is that of father. It is not known with whom the Defendant currently resides. 10. Plaintiff has not participated as a party, witness, or otherwise in litigation concerning the custody of the said child. 11. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 12. 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. 13. The best interests and permanent welfare of the child , will be served by granting the relief requested because the Plaintiff is the mother of the child and primary physical custody and legal custody will foster the parent/child relationship. 14. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff respectfully prays that Your Honorable Court award primary physical custody and legal custody of the child to the Plaintiff. Respectfully submitted, qb;A.rl!!fif!!f:1f!:{!J~ SERRATELLI, SCHIFFMAN, BROWN' CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717)540-9170 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: [Pi ~n/OI 0 I I , iAYI.tiip a 01 h Q Jaifet te A. Line -fA.. :d ~ ~ ~ t\.. {) - ~ 0) "'0 ~ ~ l~t n U ';;j c;--" =-~ Pi -- o _..' C') C) r JANETTE A. LINE PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 06-3861 CIVIL ACTION LAW CHRISTOPHER A. KARLSEN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW. Wednesday, July 12,2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicshur2, PA 17055 on Tuesday, AU2ust 22, 2006 at 10:00 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 existing Protection from Abuse orders. Special Relief orders. and Custody orders to the conciliator 48 hours prior to scheduled hearin2. FOR THE COURT. By: Isl Dawn S. Sunday, Esq. Custody Conciliator tpj 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 TH]S PAPER TO YOUR ATTORNEY AT ONCE. ]F YOU DO NOT HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO F]ND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania ] 70 13 Te]ephone (717) 249-3]66 ~'~-P~ ~ "V ..w;z rp >-.-~ ,~h ~ /~~,,:v 4v-.p1(} ,\ \ :'" \\1. .. \ \ Z \ . , 1(7 elL :/'UZ C:/-L 1a. elL ':,..\ iR!T.CEIVEI) BySE, 3 2006 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JANETTE A. LINE vs. 06-3861 CIVIL ACTION LAW CHRISTOPHER A. KARLSEN Defendant IN CUSTODY ORDER AND NOW, this 12th day of Sentember.2006 , the conciliator, being advised by counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction. FOR THE COURT, Df2s~ Custody Conciliator \yl :\\ r) ~,,:;L