HomeMy WebLinkAbout94-01625
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MAY , 6 S4 d,,,-
LINDA HUN'l',
Plaintiff
:IN 'l'HE COUR'l' OF COMMON PLEAS OF
:CUMBERLAND COUN'l'Y, PENNSYLVANIA
v
.
.
:NOS. 94~1625 AND 90-4404
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.
.
LEE KBESEHAN, JR.,
Defendant
.
.
:CIVIL AC'l'ION - CUSTODY
COUR'l' ORDER
AND NOW, this ,t.'" day of r1?~ , 1994, upon consideration of
the attached Custody Conciliation Report, it is ordered and
directed as follows:
1. A Hearing is scheduled in Courtroom No. 4 of the Cumberland
County Courthouse on 'l'hursday, July 14, 1994, at 9:30 A.M.
at which time testimony will be taken in this case. At
this Hearing, the Father, Lee Keeseman, Jr., shall be the
moving party and shall proceed initially with testimony.
Council for the parties shall file with the Court and
opposing council a Memorandum setting forth each party's
position on custody and also setting forth a list of
witnesses that will be called to testify at this Hearing
along with a summary of the anticipated testimony of each
witness. 'l'his Memorandum shall be filed at least ten days
prior to the Hearing date.
2. Pending said Hearing, this Court's prior Order of April 14,
1994, shall remain in effect subject to the following
modifications:
A. Each party shall be afforded at least one week of
summer vacation with the minor children which time
shall be provided to the other party in writing at
least thirty days prior to the week the party wants
a specific period of vacation.
B. 'l'ransportation shall be handled by the non-custodial
parent picking the children up either at the babysitter
or at the Riverside Store in Shermansdale pursuant to
the prior Order.
C. Pending the Hearing, Father shall have the child on
Memorial Day from 9 A.M. until 7 P.M. and Mother shall
have the child on July 4th from 9 A.M. until 7 P.M.,
unless agreed otherwise by the parties.
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3. 2'he Mother shall have custody of the mlnor chl1dren on
Mother's Day from 9 A.M. untl1 8 P.M. and the Father shall
have custody of the mlnor chl1dren on Father's Day for the
same tlme frame. In 11ght of the current Custody Order,
the Father's time ln June on Father's Day on Sunday shall
be ln 11eu of hls one Sunday day of custody durlng the
month, and Father shall be afforded one Sunday durlng the
day of custody ln May to make up for the Mother's Day that
Mother wl11 have the chl1dren durlng the day on Sunday.
Father shall have custody durlng the day on May 1 and on
June 19 ln accordance wlth thls Order.
BY 2'HE COUR2',
,/
44
cc:
Robert J. Mulderlg, Esqulre
Joan E. Carey, Esqulre
Judge evln A. Hess
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: IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:
:NOS. 94-1615 AND 90-4404
:
. -
.
LINDA HUNT,
Plaintiff
LEE KEESEHAN, JR.,
Defendant
.
.
:CIVIL ACTION - CUS'l'ODY
PRIOR JUDGE: JUDGE KEVIN A. HESS
CONCILIATION CONPBRENCB SUHHARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the
following report:
1 . The pertinent information pertaining to the children who
are the subject of this litigation is as follows:
Nicole M. Keeseman, born February 16, 1989, and Devin L.
Keeseman, born August 6, 1990.
2. A Conciliation Conference was held on April 28, 1994, with
the following individuals in attendance:
The Mother, Linda Hunt, with her counsel Joan Carey,
Esquire, and the Father Lee Keeseman, Jr., with his
counsel, Robert Mulderig, Esquire.
3. The parties are at odds with respect to a permanent Custody
Order. The older child will be starting school in September.
The Mother lives in Perry County and the Father lives in
Carlisle. The Father desires to maintain primary custody
of the minor children and the Mother desires the same. A
Hearing is required. The parties were able to reach an
agreement to modify the temporary Order which was previously
issued by the Court.
4. The Conciliator recommends an Order in the form as attached.
SlrO/N
7JATE
06>> ~
Hubert X. Gilroy, Es uire
Custody Conciliator
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LINDA L. HUNT,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PBNNSYL VANIA
NO. 94 - 1625 CIVIL TERM
Plaintiff
v.
LEE D. KBBSEMAN, JR.,
Defendant
.
.
: PROTECTION FROM ABUSE AND CUSTODY
PROTECTIVE ORDER
AND NOW, this 1'," day of April, 1994, upon consideration of the consent agreement
of the parties made in open court, the following Order is entered:
1. The defendant, Lee D. Keeseman, Jr., is enjoined from physically abusing the
plaintiff, Linda L. Hunt, and/or from placing her in fear of abuse.
2. The defendant is enjoined from having any direct or indirect contact with the
plaintiff including, but not limited to, telephone and written communications, except for the
limited purpose of facilitating custody arrangements.
3. The defendant is ordered to refrain from harassing and stalking the plaintiff.
4. The defendant is prohibited from entering the plaintifrs place of employment.
5. The defendant is ordered to stay away from the plaintifrs residence located at
Lupfer's Grove, P.O. Box 14, Shermans Dale, Perry County, Pennsylvania, which the parties
have never shared.
6. The defendant is ordered to stay away from any residence the plaintiff may in the
future establish for herself.
7. This Order shall remain in effect for a period of one year.
8. The Pennsylvania State Police at the Newport Barracks in Perry County shall be
,
provided with a certified and registered copy of this Order by the plaintiff and may enforce this
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Order by arrest for Indirect criminal contempt without warrant upon probable cause that this
Order has been violated, whether or not the violation is committed in the presence of the police
officer. In the event that an arrest is made under this section, the defendant shall be taken
without unnecessary delay before the court that issued the order. When that court is unavailable,
the defendant shall be taken before the appropriate district justice. (23 P.S. I 6113).
By the Court,
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LINDA L. HUNT,
IN THE COURT OF COMMON PLEAS OF
Plaintiff
v.
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 - l62S CIVIL TERM
LEE D. KEESEMAN, JR.,
Defendant
.
.
: PROTECTION FROM ABUSE AND CUSTODY
LINDA L. HUNT,
IN THE COURT OF COMMON PLEAS OF
Plaintiff
v.
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 90 - 4404 CIVIL TERM
LEE D. KEESEMAN, JR.,
Defendant
CUSTODY IVISITA TION
TEMPORARY CUSTODY ORDER
AND NOW, this 1'1" day of April, 1994, upon consideration of the parties' Consent
Agreement, the following Order is entered with regard to custody of the parties' children, Nicole
Michelle Keeseman and Devin Lee Keeseman.
I. The plaintiff, Linda L. Hunt, shall have custody of the children from each
Thursday at S:OO p.m. until Sunday at 8:00 p.m.
2. The defendant, Lee D. Keeseman, Jr., shall have custody of the children from
each Sunday at 8:00 p.m. until Thursday at S:OO p.m. However, during the week beginning on
the second Sunday of every month, the defendant's period of custody shall extend from Sunday
at 8:00 a.m. until Thursday at S:OO p.m.
3. The defendant shall be responsible for transporting the children to and from the
Riverside Store in Shermans Dale, Perry County, Pennsylvania, where the above-stated custody
exchange shall take place.
-'
4. The mother and father shall notify each other of all medical care the children
receive while in that parent's care. Each parent shall notify the other immediately of medical
emergencies which arise while the children are in that parent's care.
S. Neither party shall do anything which may estrange the children from the other
parent, or injure the opinion of the children as to the other parent or which may hamper the free
and natural development of the children's love or respect for the other parent.
6. This Temporary Custody Order shall remain in effect pending any Order which
may be entered fonowing the parties' Pre-Hearing Custody Conference, which is scheduled for
April 28, 1994.
By the Court,
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LINDA HUNT,
Plalntur
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
.
.
: CIVIL ACTION. LAW
: NO. <<04 CIVIL 1990
LEE KEESEMAN, JR.,
Defendant
.
.
: CUSTODY/VISITATION
ORDER OF COURT
AND NOW, thIa
day of
, 1994, upon review of the
attached Petition for Speclal ReUef, It is ordered and directed that the Mother, LInda L. Hunt, ahaIJ return
the children, Nicole M. Keeseman, born February 16, 1989; and Devin L. Keeaeman, born August 6, 1990,
to their residence at 47 Betty Nelson Court, Carlisle, Pennsylvania. A Custod,y Complaint has been flied
,J.
In this C8lIe and the Father, Lee Keeseman, Jr., is awarded temporary physical custody of the children
pending..Ltl ...hllRe aCth. Ilfthl) ~...u~t;;'lJul.~hae' I:,fII1'~ ~ t:/ C#CW'Ioo.
BY THE COURT,
,
....
LINDA HUNT,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION. LAW
NO. 4404 CIVIL 1990
CUSTODYNISITATlON
v.
LEE KEESEMAN, JR.,
Defendant
PETlTION FOR SPECIAL RELIEF
AND NOW, comes the Defendant, Lee KeeseJ1lllI1, Jr., by and through his attorney, Robert J.
Mulderlg, Esquire, and requests the following speclal rellef:
1. Petitioner (Defendant) is Lee KeeseJ1lllI1, Jr., an adult Individual currently residing at 47
Betty Nelson Court, Carlisle, Cumberland County, Pennsylvania.
2. Respondent (plalntlfl) is Linda Hunt, an adult individual whose mailing address is P.O. Box
14, Shermans Dale, Perry County, Pennsylvania.
3. Petitioner has flied seeking CU8tody of his children, Nicole M. KeeseJ1lllI1, born February 16,
1989; and Devin L. KeeseJ1lllI1, born August 6. 1990, currently residing at P.O. Box 14, Shermans Dale, Perry
County, Pennsylvania.
4. The children resided with Petitioner and Respondent from February of 1989 until October
of 1989 at Petitioner's residence, 47 Betty Nelson Court, Carlisle, Cumberland County, Pennsylvania.
6. In October of 1989, Respondent leR the household leaving Nicole M. Keeseman with
Petitioner until December of 1989.
6. In December of 1989, Respondent returned to Petitioner's residence and llved with him and
the child until October of 1990 at which time she leR leaving both Nicole Keeseman and Devin L. Keeseman
In the CU8tody of Petitioner.
7. Respondent flied a Complaint for Custody on December 21, 1990.
8. On January 14, 1991, by agreement of the parties, Petitioner WII8 awarded primary physical
CU8tody of the minor children. A copy of the Order is attached hereto 88 Ellhiblt .A..
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9. On May 81, 1991, Respondent med 8 Petition for Contempt and Modlflcatlon, and
conciliation conference W8lI BCheduled for June 18, 1991.
10. The parties resolved their custody dIllpute orally and no conciliation conference with held.
11. On November I, 1991, Respondent moved back in with Petitioner and the children at 47
Betty Nelson Court, CarUale, Cumberland County, Pennsylvania.
12. On July 15, 1992, Respondent withdrew a Petition for Contempt and Modification action and
the January 14, 1991 Order W8lI vacated by agreement of the parties.
18. Rellpondent continued to live with Petitioner and the children untU October, 1998 when she
moved to Perry County, leaving the children with Petitioner.
14. Petitioner continued to be primary caregiver of the children until March 21, 1994.
15. On March 21, 1994, Respondent, without any prior contact with Petitioner, went to the
da,ycare center, CarUale Earl,y Education Center, where Petitioner had thP. children enroUed and removed
said children from the Center and took them to Perry County.
16. Rellpondent refuses to return the children to their home.
WHEREFORE, Petitioner respectfull,y requests this Court to order the Respondent to return the
children to the home in which they have resided for their entire lives until the custod,y conclllatlon can be
scheduled and held before the Custody Conciliator.
Respectfully submitted,
LAW OFFICES OF RON TURO
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.
Robert J.
82 Sout edford Street
CarUale, PA 17018
(717) 245-9688
Attorney for Petitioner
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VERIFICATION
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING PETITION FOR
SPECIAL RELIEF ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE
STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA C.S. 4904
RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES.
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LINDA L. HUNT,
IN TIlE COURT OF cotoM>N PLEAS OF
Plainti ff
v.
CUMBBRLAND COI.lm'Y, PENNSYLVANIA
NO. 94 -lb.,l~IVIL TERM
LEE D. KEESEMAN, JR.,
Defendant
PROTECTION FROM ABUSE AND CUSTODY
1'IlMPORARY PROTECl'IVE ORDER
AND NOW, this )/~daY of March, 1994, upon presentation and consideration
of the within Petition, and upon finding that the plaintiff, Linda L. Hunt, and
her minor children, now residing at Lupfer's Grove, P.O. Box 14, Sheraans Dale,
Perry County, Pennsylvania, is in immediate and present danger of abuse from the
defendant, Lee D. Keeseman, Jr., the following Temporary Order is entered.
The defendant, Lee D. Keeseman, Jr., now residing at 47 Betty Nelson
Trailer COurt, Carlisle, CUmberland County, Pennsylvania, is hereby enjoined from
physically abusing the plaintiff, Linda L. Hunt, or placing her in fear of abuse.
The defendant is ordered to stay away from the plaintiff's residence
located at Lupfer's Grove, P.O. Box 14, Shermans Dale, Perry COunty,
Pennsylvania, a residence which to which the plaintiff moved to avoid abuse,
which is not owned or leased by the defendant.
The defendant is ordered to refrain from having any direct or indirect
contact with the plaintiff, including but not limited to, telephone and written
communications, except for the limited purpose of facilitating custody
arrangements.
The defendant is enjoined from harassing and stalking the plaintiff and and
from harassing the minor children.
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The defendant is enjo~i?L~ e'n~~i:lk the plaintiff's place of employment
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and the day care facilities of the mino~ .~jldren.
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Temporary custody of Nicole M. Keeseman and Devin L. Keeseman, is hereby
awarded to the plaintiff, Linda L. Hunt.
The defendant is hereby notified that if he violates this Order, he may be
in indirect criminal contempt which is punishable by a fine not to exceed
$1,000.00 and/or by a sentence of up to six IIOnths in jail and any other
appropriate punishment.
This Order shall remain in effect until a final order is entered in this
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case. A hearing shall be held on this matter on the ~ day of April, 1994, at
/;00 /J .m., in Courtroom No.L, CUmberland County Courthouse, carlisle,
,
PeMsylvania.
The plaintiff may proceed in fonas pauPeris pending a further order after
the hearing.
The CUmberland County Sheriff's Department shall attempt to make service
at the plaintiff's request, but service may be accomplished under any applicable
rule of Civil Procedure.
The appropriate police departments will be provided with certified copies
of this Order by the plaintiff's attorney. This Order shall be enforced by any
law enforcement agency where a violation occurs by arrest for indirect criminal
contempt without warrant upon probable cause that this Order has been violated,
whether or not the violation is committed in the presence of the police officer.
In the event that an arrest is made under this section, the defendant shall be
taken without unnecessary delay before the court that issued the order. When
that court is unavailable, the defendant shall be taken before the appropriate
district justice. (23 P.S. g 6113).
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LINDA L. HUNT,
IN 1lIE COURT OF CXM<<>N PLEAS OF
Plaintiff
v.
CUMBERLAND COUNTY, PENNSYLVANIA
11tJ.:JS'
NO. 94 - CIVIL TERN
PROI'ECTION FROM ABUSE AND CUSTODY
LEE D. KIlESEMAN, JR.,
Defendant
NOTICE
You have been sued in court. If you wish to defend against the claias set
forth in the following pages, you must take action promptly after this Petition,
Order and Notice are served, by appearing personally or by attorney at the
hearing scheduled by the Court and presenting to the Court your defenses or
objections to the claims set forth against you. You are warned that if you fall
to do so the Court may proceed without you, and a judgment may be entered against
you by the Court without further notice for any money claimed in the Petition or
for any other claim or relief requested by the plaintiff. You may lose money or
property or other rights important to you.
YOU SIKlULD TAKE TflIS PAPER TO YOUR LAWYFR AT a<<::E. IF YOU DO I<<>T HAVE A
LAWYFR OR CANNOO' AFFORD ONE, 00 TO OR 'l'ELEPHONE 1lIE OFFICE SET FOR'I1I 8IlLOlJ TO
FIND our WfII!RE YOU CAN GBT LOOAL HELP.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURnlOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
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LINDA L. HUNT,
IN 11IE COURT OF CXMK>N PLEAS OF
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Plaintiff
v.
CUMBERLAND COUt<<Y, PENNSYLVANIA
''''~S-
NO. 94 - CIVIL TERM
PROTECTION FROM ABUSE AND CUSTODY
LEE D. KEESEMAN, JR.,
Defendant
PETITIa./ FOR PROl'ECTIVE ORDER
AND CUSTODY
RELIEF UNDER 11IE PROl'ECTIa./ PJQ( ABUSE
ACT, 23 P.S. ! 6101 et seq.
A. ABUSE
1. The plaintiff is an adult individual whose permanent address is
Lupfer's Grove, P.O. Box 14, Shermans Dale, Perry County, Pennsylvania, 17090.
2. The defendant is an adult individual residing at 47 Betty Nelson
Trailer Court, Carlisle, Cumberland County, Pennsylvania, 17013.
3. The defendant is the father of the plaintiff's children.
4. Since approximately March, 1988, the defendant has attempted to cause
and has intentionally, knowingly, or recklessly caused bodily injury to the
plaintiff and by physical menace has placed the plaintiff in fear of imminent
serious bodily injury. This has included but is not limited to the following
specific instances of abuse:
a. On or about March IS, 1994, the defendant threatened the
plaintiff telling her he would have some one "take care" of
her which she interpreted as a threat to her life.
b. On or about November 19, 1993, the defendant grabbed the
plaintiff by her throat, threw her into the bathtub, kicked
her about her legs, grabbed her by her arms, pushed and shoved
her about, punched her about her face and head, and pulled her
hair. The defendant then threw his wallet at the plaintiff,
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hitting her on the nose with it, threatened to make her part
of the wall and told her he would kill her. The plaintiff
sustained bruising and swelling about her body from her head
to her legs as a result of this incident.
c. on or about August 8, 1990, two days after the birth of the
parties' second child, the defendant struck the plaintiff
across the face with the back of his fist.
d. Since approximately March, 1988, the defendant has abused the
plaintiff in ways including, but not limited to, threatening
her with physical violence, threatening to kill her, throwing
dishes and food at her, pushing and shoving her, including
during both of her pregnancies, slapping and punching her,
pulling her hair, and kicking her.
S. In or about late November, 1993, the plaintiff left her residence at
47 Betty Nelson Trailer Court, Carlisle, CUmberland COunty, Pennsylvania, in
order to avoid further abuse.
6. The plaintiff believes and therefore avers that she is in immediate
and present danger of abuse from the defendant and that she is in need of
protection from such abuse.
7. The plaintiff desires that the defendant be prohibited from having
any direct or indirect contact with the plaintiff, inciuding, but not limited to,
telephone and written communications, except for the limited purpose of
facilitating custody arrangements.
8. The plaintiff desires that the defendant be enjoined from harassing
and stalking the plaintiff, and from harassing the minor children.
9. The plaintiff desires that the defendant be restrained from entering
her place of employment and the day care facllltlos of the minor children.
10.
The plaintiff desires that the defendant be ordered to stay
away from her current residence at Lupfer's Grove, P.O. Box 14, Shermans Dale,
Perry County, Pennsylvania, ond ony other residence she MY establish for
herself.
B. STA11JS TO PIItnOlIl IN MlRMA PAUPBRIS
11. The plaintiff Is currently unemployed.
12. The plaint Iff does not have funds available to pay the fees for
filing and service of this lowsult.
C. TIM'ORARY CUSTODY
13. The plalntllf seeks temporary custody of the following children:
NIB
fIusent Rcsidence
A8!l
Nicole Michelle Keesemnn
Lupfer's Orove
Shermans Dale. PA
S years old
0.0.8. February 14, 1989
3 years old
D.O.B. August 6, 1990
Devin Lee Keesemnn
Lupfer's Orove
Shermons Dale, PA
The children were born Oul of wedlock.
The children are presently In the custody of the plaintiff, Linda L. Hunt,
who resides al Lupfer's Orove, P.O. Box 14, Shermans Dsle, Perry County,
Pennsylvsnis.
During lhe pasl five years the children hsve resided with the following
persons and at the following addresses:
NIB
Addresscs
DIlW!
March 21, 1994
to the present
Plaintiff and her
roollllllllte, Angela
McCI intock
I.upfer's Orove. P.O. Box 14
Shermnns Dale, PA
Defendant and his 47 Betty Nelson Trailer Court
girlfriend, Llnelle Farner Carlisle, PA
Mid-February, 1994
to March 21, 1994
lfIIIIl
Addresses
47 Betty Nelson Trailer Court
Carlisle, PA
Defendant and his 47 Betty Nelson Trailer Court
girlfriend, Bobby Jo Hess Carlisle, PA
Defendant
Defendant
47 Betty Nelson Trailer Court
Carlisle, PA
Plaintiff and defendant 47 Betty Nelson Trailer Court
Carlisle, PA
Defendant
47 Betty Nelson Trailer Court
Carlisle, PA
Richwine Road
Shermans Dale, PA
Plaintiff, her cousins,
Toni and Rodney Turner,
their children, Shane,
Shannon, Shawn, Josh and Amy
Plaintiff
47 Betty Nelson Trailer Court
Carlisle, PA
Plaintiff and defendant 47 Betty Nelson Trailer Court
Carlisle, PA
Plaintiff and defendant
Rt. 641
Carlisle, PA
822 Richwine Road
Shermans Dale, PA
Plaintiff, her parents,
Alton and Ruth Richwine,
and her sister, Sharon Hunt
Plaintiff and defendant
Rt. 641
Plainfield, PA
DlWl.ll
late January, 1994
to mid-February, 1994
Decelllber, 1993
to late January, 1994
late November, 1993
to December, 1993
November, 1991
to late November, 1993
late November, 1990
November, 1991
October 31, 1990
to late November, 1990
August 6, 1990
to October 31, 1990
June, 1990
to August S, 1990
December, 1989
to June, 1990
OCtober 31, 1989
to December, 1989
February 14, 1989
to OCtober 31, 1989
The mother of the children is Linda L. Hunt, currently residing at Lupfer's
Grove, P.O. Box 14, Sherlllllls Dale, Perry County, Pennsylvania.
She is single.
The father of the children is Lee D. Keeseman, Jr., currently residing at
47 Betty Nelson Trailer Court, Carlisle, CUmberland County, Pennsylvania.
He is single.
,'....".,.
The plaintiff currently resides with the following persons:
Hua
Re lat 100000hip
her daughter
her 30n
her roollllllllte
Nicole Michelle Keeseman
Devin Lee Keeseaan
Angela McClintock
14. The plaintiff plaintiff knows of no custody action pending in this
or any other county. The plaintiff had filed a Complaint for CUstody on December
21, 1990 (No. 4404 Civil 1990 - CUmberland County Court of Common Pleas) and a
CUstody Order was entered on January 14, 1991. The Court entered an Order on
July 16, 1992, vaclltlng Its Order of Janullry 14, 1991.
I~. The plaintiff doos not know of any person not a party to this action
who has physical custody of the children or claims to have custody or visitation
rights wi th rusllUcl to the children.
16. Tho best Inlerests and permanent welfare of the children will be let
If custody Is temporarily granted to the plaintiff pending a hearing in this
11I8 tt e r because I
a. The plaintiff is a fit parent who can best take
care of the children.
b. The defendant has not acted in the children's best
Interest by refusing the IIIOther regular contact with the
children In ways including traumatizing them by telling
them their IIIOther was dead.
WIIEREPORB, pursuant to the provisions of the "Protection from Abuse Act"
of October 7, 1976, 23 P.S. g 6101 g1 ~., as amended, the plaintiff prays this
Honorable Court to grant the following relief:
A. Grant a Temporary Order pursuant to the "Protection from Abuae
Act:"
"
,
'.
1. Ordering the defendant to refrain froll abusing the
plaintiff or placing her in fear of abuse;
2. Ordering the defendant to refrain froll having any direct
or indirect contact with the plaintiff including, but not
limited to, telephone 11ud written communications, except to
facilitate custody arrangements;
3. Ordering the defendant to refrain from harassing and
stalking the plaintiff and from harassing the plaintiff's
family and the minor children;
4. Prohibiting the defendant from entering the plaintiff's
place of employment and school and the day care facilities of
the minor children;
S. Ordering the defendant to stay away from the residence
located at Lupfer's Grove, P.O. Box 14, Shermans Dale, Perry
County, Pennsylvania, which the parties have never shared;
6. Ordering the defendant to stay away from any residence
the plaintiff may in the future establish for herself, and
7. Granting temporary custody of the minor children to the
plaint iff.
B. Schedule a hearing in accordance with the provisions of the
"Protection from Abuse Act," and, after such hearing, enter an order
to be in effect for a period of one year:
1. Ordering the defendant to refrain froll abusing the
plaintiff or placing her in fear of abuse.
2. Ordering the defendant to refrain from having any direct
or indirect contact with the plaintiff including, but not
'~....~...c'" .' '-",.~ /c-,c<"
"
limited to, telephone and written communications, except to
facilitate custody arrangements.
3. Ordering the defendant to refrain from harassing and
stalking the plaintiff and from harassing the plaintiff's
family and the minor children.
4. Prohibiting the defendant from entering the plaintiff's
place of employment and school and the day care facilities of
the minor children.
S. Ordering the defendant to stay away from the residence
located at Lupfer's Grove. P.O. Box 14, Shermans Dale, Perry
County, Pennsylvania, which the parties have never shared.
6. Ordering the defendant to stay away from any residence
the plaintiff may in the future establish for herself.
7. Ordering the defendant to pay all costs of filing and
service of this lawsuit and attorney's fees to Legal Services.
Inc.
The plaintiff further asks that this petition be filed and served without
payment of costs, pending a further order at the hearing. and that certified
copies of this Petition and Order be delivered to the appropriate police
departments with jurisdiction to enforce this Order.
The plaintiff prays for such other relief as may be just and proper.
16.
set forth.
COUNT II
CUSTODY UNDER PENNSYLVANIA CVSTODY LAW
The allegations of Count I above are incorporated herein as if fully
17. The best interest and permanent welfare of the children will be
served by confirming custody in the plaintiff as set forth in Paragraph 16 of the
Petition.
'MIEREFORE, pursuant to 23 P.S. 8 5301 n SQ., and other spplicable rules
and law, the plaintiff prays this Honorable Court to award custody of the minor
children to her.
The plaintiff prays for such other relief as may be just and proper.
Respectfully submitted,
(~~, ~intiff
LmAL SERVICES, INC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
L.
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The above-nued plaintiff. Linda L. Hunt. verifies that the statell8nts lIIIde
in the above Petition are true and correct. The plaintiff understands that false
statellents herein are l18de subject to the penalties of 18 Pa. C.S. II 4904
relating to unsworn falsification to authorities.
1
.
.
Date:AuJ...:J~1199Cf
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8
SHERIFF'S RETURN
ca+1ONWEI\LTH OF PENNSYLVANIA I
COUNl'Y OF ClMBERLAND
In The Court of Common Pleas of
Cumberland County, pennsylvania
No. 94-1625
Temporary Protective Order
protection From Abuse and Custody
Linda L. Hunt
VS
Lee D. Keeseman Jr.
Harry King
, ~i)t)t" Deputy Sheriff of
Cu1lberland County, Pennsylvania, who being duly swom according to law, says,
that he served the within Temoorarv Protective Order protection From Abuse
and Custody
upon r.F!P D. K"F!seman ,lr. . the defendant, at 5:05 o'clock
p.M. EST /~le. on the
day of
April
. 19 94at
04
Thp Cl1mhF!rlanrl Countv Courthouse. Sheriff's Dept.
One Courthouse Square. Carlisle
Pennsylvania, by handing to Lee D. Keeseman. Jr.
. Cumberland County.
a true and attested copy of the Temoorarv
Abuse and
and at the same tllne directing his
Protective Order Protection FrQm
Custody
attention to the contents thereof and
the "Notice to Plead" endorsed thereon.
Sheriff's COStSI
Docketing
Service
Affidavit
Surcharge
?~~~
14.00
3.36
2.00
19.36
R. Thanas Kline. Sheriff
~~
by'/ , ,
----'&
De t Sh i
Swom and subscribed to before me
this f ~
day of {It,. l'
qL.\ _ I~~S-
'Pro-l-, Ordor
19_ Ii<( A.D.
'-.-l.k_ C 'nt~;t?.., ~ oJj:r..
, I I "7 f
Prothonotary
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