Loading...
HomeMy WebLinkAbout94-01125 c.J ~ ~ I~ ~ v... ~ -- ~ it 1 ~~ ~ .,..:. ~ 6 = ;.;,... .~ - ::r l.; , = , Q '<. _-r ", -0 " .. . \r) ~ :r ' ~ ' "0 M \I) 9 ~ \r) V) ,I. eT> . :~~ ''& '::f. n: ;:-;0 ~ ,. :,;)0 = o a~ ...:1>1 Poll) Z$a:>< OrzlO ~Pog o .11) u~8 r.-Z 001 o E-<UZ P: 0 8~0~ U U rzl .0: =rzl...:l E-<~~ ZOH HUU ... '" '" .... r.- o . Z rzl ! 'tl J:: III . Ul 'H 'H ..... .jJ J:: ..... III .... Po . o Z gj H Z rzl . II)P: rzl ZH =Z Orzl ~II) . . ~ "l .... , 0 ..J Z ~ <>-0 1-< :t<1= W_ 1-11I~~WZ ZOO<j:< ~Z:::~Ul>: ",,-0<...- c:<:....lUIll....>- O~:;!i:i!:2~ :Ec:<:Z~XZ wQOI-W ci:::lllI=UlC. ~O~<~~ ? ....l '" .... Ul o IJ.... ....- ....l < ;l IJ.. < U 'tl J:: III H H . Ul .jJ J:: III 'tl J:: QJ 'H QJ o :>< o o E-< II) o U P: o r.- E-< Z :s ~ U . Ul > . rzl ~Z o .11) rzlZ o 0::;: ~rzl ~~ , , , . ... ... ... .... ... N ... .... N....Ir...tf) ....<N... N:I: ... ... I- ,... OZ~"" ",Wci>- wl.:1W< 3: "'3: Ul 0000 ..J::E-l~ u.. . LLo....l ci~cij lIlWlllO Wl.:1W", ::EO::E< ~"'~U ---- X ---- ',' c;\wp.lIUDPIRDOCSlSeNII!II.CUS Plaintiffs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY NO, II ~ s- CI'V' I OF 1994 JOHN SENIER and JOANNE N. SENIER, vs, ROLAND E, LANE, II, and MARY ANNE MUNSON, Defendants, AND NOW, upon consideration of the attachep Petition, it Is hereby directed that the parties and their respective cowser appear before .J;;I~(-r"" 'j.... &, I (Of t: , Esquire, the Conciliator, on the I ..s r day of 11 pr 1 / . 1991J! at ~ " ~ o'clock L,m., in l..f th nO<(' r J rn b, (0. (a.J.d h,<<5,. , Cumberland County, Pennsylvania, for a pre-hearing custody conference. At such conferance, 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 ~also be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a Temporary or Permanent Order. BY THE COURT, ~;"if.1:J.l.fIJJ stody Concill or r Date: ';?-q -'1 1/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWVER AT ONCE. IF YOU DO NOT HAVE A LAWVER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator, Fourth Floor Cumberland County Court House Carlisle, Pennsylvania 17013 (717) 240-6200 H~R 9 4 23 .H '9~ '" G ~ '" .)'. . ,~.;" c:..'-, L r '..,Tt . ~ ',,,:, '....;. '. :. c:'wp.lIUDPJRIXlCS\SJ!Io/II!ll.cuS .. JOHN SENIER and JOANNE N. SENIER, Plaintiffs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY vs. NO, I U5" {,V/ / OF 1994 ROLAND E. LANE, II, and MARY ANNE MUNSON, Defendants, 1. The Plaintiffs are JOHN SENIER and JOANNE N. SENIER, adult individuals residing at 4602 Chestnut Avenue, Camp Hill, Pennsylvania, 17011. 2, The Defendants are ROLAND E. LANE, II, residing at 19-B Glenwood Drive, Camp Hili, Cumberland County, Pennsylvania 17011, and MARY ANNE MUNSON, residing in San Antonio, Texas, with mailing address at p, O. Box 160353, San Antonio, Texas, 78246-0353. 3, Plaintiffs seek custody of AMY J. LANE, who presently resides with Plaintiffs at 4602 Chestnut Avenue, Camp Hill, Cumberland County, Pennsylvania, and is 17 years of age, 4. The child was not born out of wedlock, 5. The child is presently in the custody of Plaintiffs who reside at 4602 Chestnut Avenue, Camp Hill, Pennsylvania, 6, During the past five years, the child in question, AMY LANE, has resided with the fOilowing persons and at the following addresses: The child in question has resided with Plaintiffs since on or about January 1, 1994; The child in question resided with her natural father, 2 c:\wpJIUDPIRDOCSISPllII!It,CUS .' ROLAND E. LANE, II, and his wife, DIANE E. LANE, at 19.8 Glenwood Drive, Camp Hili, Pennsylvania, since on or about December 16, 1991, until on or about January 1, 1994; For the remainder of the five year period and until December 16, 1991, the aforesaid child resided with her natural mother, MARY ANNE MUNSON, at 2709 Woodbury Street, San Antonio, Texas 78217. 7, The mother of the child Is MARY ANNE MUNSON, currently residing at p, O. 80x 160353, San Antonio, Texas 78246-0353, She is married, 8. The father of the child Is ROLAND E. LANE, II, currently residing at 19-8 Glenwood Drive, Camp Hili, Pennsylvania 17011, He Is married. 9, Plaintiffs are not related to the child, Plaintiffs currently reside only with the child in question, and their daughter, ANDREA SENIER. 10. Plaintiffs have not participated as a party or witness or In any other capacity in other litigation concerning the custody of the child in this or another Court, Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth, 11. 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, 12. The best interest and permanent welfare of the child will be served by granting the relief requested for the following reasons: 3 -- c:\~IUDPIIUlOCalSEHlllll,CUS .. a. There Is an existing Custody Order filed to No. 80.CI.10802, In the District Court of Bexer County, Texas, granting primary physical custody of the child in question to the natural father, ROLAND E, LANE, II, as of December 19, 1991, To the best of Plaintiff's knowledge there has been no subsequent Custody Order pertaining to the child In question In this or any other Court, A copy of said Court Order, and accompanying pleading, is attached hereto as exhibit "A", b, Prior to the Order of December 17, 1991, the child in question was In the custody of her natural mother, MARY ANNE MUNSON. c, The child In question Is 17 years of age, and has expressed a preference to reside with the Plaintiffs until she reaches the age of majority. The natural father, ROLAND E. LANE, II, consents to his daughter's wishes, and a copy of said Consent Is attached hereto as exhibit "C", d. The child in question Is 19 years of age, and has expressed a preference to reside with the Plaintiffs until she reaches the age of majority. The natural mother, MARY ANNE MUNSON, consents to her daughter's wishes, and a copy of said Consent Is attached hereto as exhibit "B", e. Plaintiffs are willing and able to take on the responsibilities of parenting the child In question, until such time as she reaches the age of majority, 4 c:'~IUDPIRDOCS\SI!Il1IlR,cua : 13, 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, WHEREFORE, Plaintiffs request the Court to grant custody of the child, FLOWER, MORGENTHAL, FLOWER & UNDSAY Attorneys for the Plaintiffs "1- ames D. FI er, Jr., Esqulr 11 East High Street Carlisle, PA 17013 (717) 243-5513 1.0, #2n42 5 c:1.,.'IUDPJIlOOCS\SENIIlR.CUS ~ " JOHN SENIER, Plaintiff In the above captioned action, hereby verify that the statements made In the within Instrument are true and correct to the best of my knowledge, Information and belief. 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, .dP ~/ ~ / John Senler Date: .?Z//'7h"J" / / 6 c:'~IUDPIRllOCS\SI!NII!Il.CUS JOHN SENIER and JOANNE N, SENIER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY Plaintiffs, vs. OF 1994 NO. ROLAND E, LANE, II, and MARY ANNE MUNSON, Defendants, ~ I, MARY ANN MUNSON, am the natural mother of AMY J. LANE, presently age 17, and consent to transfer of custody of my daughter to JOHN SENIER and JOANNE N. SENIER. ;r(~~~ Date: /' /f;b 91 8 o:\wp.ll UDPIRDOCSISlllIlnR,CUS JOHN SENIER and JOANNE N, SENIER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. CUSTODY Plaintiffs, vs, OF 1994 NO, ROLAND E. LANE, II, and MARY ANNE MUNSON, Defendants, CQNS.ENI I, ROLAND E. LANE, II, am the natural father of AMY J. LANE, presently age 17, and consent to transfer of custody of my daughter to JOHN SENIER and JOANNE N. SENIER. ;?~~/ !: X~ Jr Roland E. Lane, III Date: 7/(a,1c1t 7 , /?91- , 7 . COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND In the Court of Common Pleas of Cumberland County, Pennsylvania No. 1125 Civil Term 1994 Order of Court and Complaint for Custody John Senier and Joanne N. Senier VS Roland E. Lane, II and Mary Anne Munson Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, says that on March 16, 1994 at 1:43 o'clock P.M., E.S.T., he served a true copy of the within Order of Court and Complaint for Custody, in the above entitled action, upon the within named defendant, to wit: Roland E. Lane. II, by making known unto Roland E. Lane, II, at 19-B Glenwwod Drive, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copy of the same. R. Thomas Kline, Sheriff, who being duly sworn accordign to law, says that he served the within Order of Court and Complaint for Custody, in the fOllowing manner: The Sheriff mailed one of the within named defendants. to wit: Mary Ann Munson, a notice of the pendency of the action, by certified mail to her last known address at P.O. Box 160353, San Antonio, Texas 78246-0353. This let~er was mailed under the date of March 14, 1994. Unopened letter was returned to the Cumberland County Sheriff's Department on April 04. 1994 with reason marked "Addressee Unknown." Unopened letter is hereto attached. Sheriff '5 Docketing Serv ice Surcharge Certified Costs: 18.00 8.40 4.00 Mail 2.52 32.92 So Answers: Pd. by Atty. 4-04-94 BY Sworn and Subscribed to Before Me This ~ 1994.A.D. '\ Pr . . ..~+-11 t CY iiJ- , I ( .~ . . - - MAY t 6 5\'/lll JOHN SENIER AND JOANNE N. SENIER, PlaintiUs v ROLAND E. LANE, II, AND MARY ANNE MUNSON, DeEendants :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA . . :NO. 1125 - CIVIL - 1994 . . . . :CIVIL ACTION - CUSTODY ,,/ COURT ORDER ( 7 1 I ~ ";~~ AND NOW, this day oE ) /', 1994, upon consideration oE the attached Custody Concilia on Report, it is ordered and directed as Eollows: 1. John Senier and Joanne N. Senier shall have legal and physical custody oE Amy J. Lane, born January 18, 1977. 2. The natural parents oE Amy J. Lane shall enjoy custody with Amy at such times as agreed upon and arranged by the parties. 3. This Order is entered pursuant to the attached Custody Conciliation Report and pursuant to a representation that the natural parents agree with this Order. In the event either party at any time in the Euture desires to modiEy this Order, that party may petition the Court to have the case again scheduled with the Custody Conciliator. 4. PlaintiEE's counsel is directed to serve the natural parents with a copy oE this Order and the Custody Conciliation Report, said service to be made by regular mail. 7[.;~~'g~ I V' cc: James D. Flower, Jr., Esquire , '"....\ ' ~:!.: H~r II II os PH '9~ ", '11"11;: 'ilD~~ dr.)" ."",it,." .',r.,. : : - .;;}.'.~ r ; t . ~ . . . ,. , ,', ., "'... . . :NO. 1125 - CIVIL - 1994 , -' .' JOHN SENIER AND JOANNE N. SENIER, PlaintiUs V ROLAND E. LANE, II, AND MARY ANNE MUNSON, Defendants :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA . . . . :CIVIL ACTION - CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the Eollowing report: 1. The pertinent inEormation pertaining to the child who is the subject oE this litigation is as follows: Amy J. Lane, born January 18, 1977. 2. A Conciliation ConEerence was held on April 29, 1994, with the Eollowing individuals in attendance: The PlaintiEEs, John and Joanne N. Senier, with their counsel, James D. Flower, Jr., Esquire. Also present was the child, Amy J. Lane. 3. The Seniers have no blood relationship or relationship by marriage to Amy J. Lane. The DeEendants are Amy's parents. Amy has been living with the Seniers since January oE 1994. This living arrangement is with the consent oE the parents and with the consent oE Amy who is 17 years old. Attached to the Complaint Eiled in this case are consents oE the parents whereby they consent to the Seniers having custody oE Amy. The Seniers require a Custody Order Eor insurance, school and other purposes. 4. It appears that the Seniers should be given custody at this time. The parents have agreed by signing a consent. Also, the parents have accepted service oE the notice oE the Conciliation Hearing and did not attend the Hearing. 5. The Conciliator recommends an Order in the Eorm as attached. ~ DATE Hubert x. Gilroy, Es Custody Conciliator ~. ....... ~ ."..-.-.. , *' COUNTY OF CUMSI!:RLAND Office of lbe Sheriff I Court House Square Carlisle, Ponnsylvanla 17013 "e I Ul)c:lo;m~d R f ~~e teed For.....ord.-' Ull~~ ___..' 'rig E . left no J...._ ><P"Od p 'vnl'Ordi..... ostOqe Du '... p-- ~ II? - ~-.~"..-...---- - "-12 ..::.... ~-- .,. -. ...... - ..."7: 1 :- --. ; ;'-" ....f - , '.... '-. '1 ,...,. ..' , ....i 1~' ~: I.. ~ary Anne on P.O. 16 53 Anton , Texas i: , , . HE1Uill~ l;;;C~~}i' n'::CUfSfED "" ca...._ .~ 76246-"353 . .. ... ~ LAWO~F1CL5I, FLOWER, MORGENTHAL, FLOWER &. LINDSAY A PROFESSIONAL CORPORATION II EAST HIGH STREET, CARLISLE, PENNSYLVANIA 11013-3016 , i - . -- ....--.... MAR 9 1994d" Plaintiffs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY JOHN SENIER and JOANNE N, SENIER, vs, NO, JI J.S- C iv,'l OF 1994 ROLAND E. LANE, II, and MARY ANNE MUNSON, Defendants, T AND NOW, upon consideration of the attached Petition, it Is hereby directed that the parties and their respective counsel appear before I-J .... b I. r + }{ . r; ," r 0 'I ESf i . Esquire, the Conciliator A on the c7116 t day of ~ p r;~ ' 1'9~ at 8.'.30 o'clock-lL,m"in LJ/J.. 1='/",,( Cuml . COvrthllI1SQ.. . Cumberland County, Pennsylvania, '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 IssuesJ,9,.l;le heard by the Court, and to enter Into a Temporary Order. All children age five or older siI;l8I1 also be present at the Conference, Failure to appear at the Conference may provide grounds for the entry of a Temporary or Permanent Order, BY THE COURT, "J I ')./ll1..lU,..I. X, Ittl/J7/' /''''0' Custody Conciliator Date: 3 ' <}.. q'l YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator, Fourth Roar Cumberland County Court House Carlisle, Pennsylvania 17013 TAUr: C0!)Y FROM RECORD (717) 240-6200 In T, :.':, .. '1,! i,";,' ,;":,, '~~I my hand . I '.. . '.' . ,.... ,~ \ ," ,:"'~.. ('-" a"o I .~.~'. '. ._: ~~~:1;1...... fu. . TillLi.~~_.. '." .:.J!,/YLl&:r- 1.:.!l:L_ 7J e' "iYJ /'-'^^. c U J.l .~f.:!.__.____ ~ Prl;th'~'.,.uy , , ...;,~,,.,;,;,;;,.;.- ','~ ~:3, dwp5II1DPIRJlOCSISI!NU!R,CUS . Plaintiffs, IN THE COURT OF COMMON PLEAS OF CUMBERlAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY JOHN SENIER and JOANNE N. SENIER, vs. NO. OF 1994 ROlAND E, lANE, II, and MARY ANNE MUNSON, Defendants, 1. The Plaintiffs are JOHN SENIER and JOANNE N. SENIER, adult individuals residing '3t 4602 Chestnut Avenue, Camp Hill, Pennsylvania, 17011, 2. The Defendants are ROLAND E. LANE, II, residing at 19-B Glenwood Drive, Camp Hill, Cumberland County, Pennsylvania 17011, and MARY ANNE MUNSON, residing in San Antonio, Texas, with mailing address at P. 0, Box 160353, San Antonio, Texas, 78246-0353, 3, Plaintiffs seek custody of AMY J. LANE, who presently resides .with Plaintiffs at 4602 Chestnut Avenue, Camp Hill, Cumberland County, Pennsyivania, and is 17 years of age, 4, The child was not born out of wedlock. 5. The child is presently in the custody of Plaintiffs who reside at 4602 Chestnut Avenue, Camp Hili, Pennsylvania. 6. During the past five years, the child in question, AMY LANE, has resided with the following persons and at the following addresses: The child in question has resided with Plaintiffs since on or about January 1, 1994; The child in question resided with her natural father, 2 ---..,...",:"""-.,,,., - ""'.-'--"','- ,....' '~'.".-, ,,'wpJl UOPIIlJlOCSIII!HIIlIt.l'US ROLAND E. LANE, II, and his wife, DIANE E. LANE, at 19-8 Glenwood Drive, Camp Hill, pennsylvania, since on or about December 16,1991, until on or about January 1,1994; For the . remainder of the five year period and until December 16, 1991, the aforesaid child resided with her natural mother, MARY ANNE MUNSON, at 2709 Woodbury Street, San Antonio, Texas 78217, 7. The mother of the child is MARY ANNE MUNSON, currently residing at p, 0, Box 160353, San Antonio, Texas 78246-0353, She Is married. 8. The father of the child Is ROLAND E. LANE, II, currently reSiding at 19-B . Glenwood Drive, Camp Hili, Pennsylvania 17011. He Is married. 9, Plaintiffs are not related to the child. Plaintiffs currently reside only with the child In question, and their daughter, ANDREA SENIER, 10, Plaintiffs have not participated as a party or witness or In any other capacity In other litigation concerning the custody of the child in this or another Court, Plaintiff has no Information of a custody proceeding concerning the child pending In a Court of this Commonwealth, 11. 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, 12. The best interest and permanent welfare of the child will be served by granting the relief requested for the following reasons: 3 c:'wp.llIlDP1JlllOCSlSeNlER,CUS , a, There Is an existing Custody Order filed to No. 80-CI-10802, in the District Court of Bexar County, Texas, granting primary physical custody of the child In question ' to the natural father, ROLAND E. LANE, II, as of December 19, 1991. To the best of Plaintiff's, knowledge there has been no subsequent Custody Order pertaining to the child in question in this or any other Court, A copy of said Court Order, and accompanying pleading, is attached hereto as Exhibit "A", b. Prior to the Order of December 17,1991, the child in question was In the custody of her natural mother, MARY ANNE MUNSON. c, The child in question is 17 years of age, and has expressed a preferenca to reside with the Plaintiffs until she reaches the age of majority. The natural father, ROLAND E. LANE, II, consents to his daughter's wishes, and a copy of said Consent is attached hereto as Exhibit "C", d, The child in question is 19 years of age, and has expressed a preference to reside with the Plaintiffs until she reaches the age of majority. The natural mother, MARY ANNE MUNSON, consents to her daughter's wishes, and a copy of said Consent is attached hereto as Exhibit "B", e, Plaintiffs are willing and able to take on the responsibilities of parenting the child in question, until such time as she reaches the age of majority. 4 .".,llllurlIUlOClllIIHIDA,CUI '. 13, Each parent whose parental rlghts 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, WHEREFORE, Plaintiffs request the Court to grant custody of the child, FLOWER, MORGENTHAL. FLOWER & LINDSAY Attorneys for the Plaintiffs By 5 L~ . "'w;IIIlDP/IlDOCS\SIlHII!II,CUS '. ~ I, JOHN SENIER, Plaintiff In the above captioned action, hereby verify that the statements made in the within instrument are true and correct to the best of my knowledge, Information and belief. 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. ~/ ~.;(~ ~ / John Senler Date: .;?//'Th..,. I / ~ I ~ 6 c. <:I..;.lIUDPlllDOCSlSl!NIl!R,CUS " JOHN SENIER and JOANNE N. SENIER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY Plaintiffs, vs. NO, OF 1994 ROLAND E. LANE, II, and MARY ANNE MUNSON, Defendants. .co.NS.ENI I, MARY ANN MUNSON, am the natural mother of AMY J. LANE, presently age 17, and consent to transfer of custody of my daughter to JOHN SENIER and JOANNE N. SENIER. ;r{~=~ Date: / S' te.b 91 8 . . '"IWP)IVDPlIU)()CS\SI!IIII!R,CUS " JOHN SENIER and JOANNE N, SENIER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY Plaintiffs, vs, NO. OF 1994 ROLAND E, LANE, II, and MARY ANNE MUNSON, Defendants. .co.NSENI . I, ROLAND E. LANE, II, am the natural father of AMY J. LANE, presently age 17, and consent to transfer of custody of my daughter to JOHN SENIER and JOANNE N. SENIER. !?~~/ !: ;(~ /1 Roland E. Lane, III Date: 7Jttl/lclt 7; If?1- , 7 , , . .