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Home My WebLink About94-02730 >- " - .JJ d & \ 1 . 1 f! ,-I ~I I _I '_ I di , 01 nlj ri (Qi v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA NO, 94-,v30CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CHRISTOPHER P. MARKLEY. Plaintiff BILLIE JO (ELLIS) KANE, Defendant ORDER OF COURT AND NOW, this ak.! {ray of (\I'\t"\. '/ ,1994, upon consideration of the attached , Petition, it is hereby directed that the parties and their resDective( counsel ap.Pear,.1Jefore . 0'\ Lith iloli' ,~b. lo, [ow' .,~r- \-\t.\. 'oat }. (" \(D~! ' Esquire. Custody Conciliator on 7f h of 7", If ' 199..!:!, at g;1J~flt., 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. FOR THE COURT, By, --;(f.J$J~ tt;. Custody Conciliator YOU SHOULD TAKE TmS 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. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17103 (717) 240-6200 HAl Zf I 19 Pn '9~ .. H.: ~ ,...' '",," .\hl i. " .," Il . I, ... ~ \ t I.~ S. ::.. Name Present Residence Age v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-J.7,3/) CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CHRISTOPHER P. MARKLEY, Plaintiff BILLIE JO (ELLIS) KANE, Defendant PETITION FOR PARTIAL CUSTODY COMES NOW, Plaintiff, CHRISTOPHER p, MARKLEY, by and through his attorney, James J, Kayer, Esquire and avers as follows: I. Plaintiff is Christopher p, Markley, an adult individual whose current mailing address is Post Office Box 557, Ml. Jackson, Virginia 22842, 2. Defendant is Billie Jo (Ellis) Kane, an adult individual who resides at 522 Highland Court, Cumberland County, Pennsylvania 17013, 3, Plaintiff seeks custody of the following child: Amanda Jo Ellis, 522 Highland Court, Carlisle, Pennsylvania 17013, born January 21, 1987, The child was born out of wedlock, The child is presently in the custody of Billie Jo Kane, who resides at 522 Highland Court, Carlisle, Pennsylvania, During the past five years, the child has resided with the following person(s) at the below addressees): Billie Jo Ellis, mother; and Bill and Auzine Ellis, maternal grandparents, at 1105 Spring Garden Street, Carlisle, PA 17013, from birth until August, 1992; Billie Jo Ellis, mother; and Bill and Auzine Ellis, maternal grandparents, at 3582 Ritner Highway, Newville, PA 17241, from August 1992 until August, 1993; Billie Jo (Ellis) Kane and Everette Kane, 129 South Railroad Avenue, Frackville, PA 17931, August 1993 until January 1994; and Billie Jo (Ellis) Kane and Everette Kane, 522 Highland Court, Carlisle. PA 17013, January 1994 until the present, 4, The mother of the child is Billy Jo (Ellis) Kane, currently residing at 522 Highland Court, Carlisle, PA 17013, She is married. 5, The father of the child is Christopher P. Markley, whose current mailing address is Post Office Box 557, Mt, Jackson, Virginia 22842, He is married. 6, The relutionship of Plaintiff to the child is that of father, The Plaintiff currently resides with his wife and child, 7, The relationship of the defendant to the child is that of rnother. The Defendant currently resides with her husband, Everette Kane, and Arnanda Jo Ellis, 8. 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 another court. Plaintiff has no inforrnation of a custody proceeding concerning the child pending in a court of this Commonwealth, 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 because the Plaintiff, Christopher p, Markley, has been denied all access to the child, Plaintiff seeks to establish a regular visitation schedule and telephone access with the child. 10, Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child have been named as parties to this action, All other persons, names below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of th is action and the right to intervene: Name Address Basis of Claim None WHEREFORE, Plaintiff requests the court to grant custody of the child to Plaintiff. VERIFICATION OF PLEADINGS I verify that the statements made in this document 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. CJ,A,~~L~ ,~ ~::Jr- Date S:;:z;:z. - 7f ~ . \ "l::l' .;:' ~ ":J'" en ~~ Cl :J - .-:':: 0 ~ 'f~~}';7 \J) 0 \ I.i) M II) \ \ri .-. . 0 . -::T , ::r- N " " - :(0- , ~ l"""> , .~. ...... ., - ~ J ~, ~ - ~ M 0 '"' - '::*- -\\ . -r~ (:J\.J c::;l vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94-2730 CIVIL TERM IN CUSTODY CHRISTOPHER P. MARKLEY, Plaintiff BILLIE 10 (ELLIS) KANE, Defendant AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO Pa. R.C.P. 1920.4(a)(I)(II) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. I, James J. Kayer, Esquire. being duly sworn according to law, deposes and says that he is the attorney for plaintiff, CHRISTOPHER P. MARKLEY, and that he did serve a true and correct copy of the Order of Court and Petition For Partial Custody that was filed in the above matter, by U.S. Mail, postage prepaid, certified, restricted delivery, return receipt requested, unto the Defendant, BILLIE 10 KANE, on June II, 1994. The receipt form is attached hereto as Exhibit. A .. -1 I, I '"/4 '[.K S.om 10 "'" ,,"""iI,'" before ro, fu. ~." of J"~. \994. ~~O~~~ Olary Pu IC NOTARIAL SEAL DENISE SNIDER. N01ARY PUBLIC CARLISLE BORO. CUMBERLAND COUNlY MY COMMISSION EXPIRES OC1. 28. \996 Mlmbtr. PlRMylYI.il AuldlU.. .t NIII"'I , " .u.a.CII'O:I_71' EXHIBIT "A" , r t t:; , ~'i(~~_~ ;- '" r:' .,_t_... ~t~,,: ~~~>: ~; '., };~. b"',, 1-. "'.". (" .; r{~~:::' ~J~::' ..:;',:'.: '!'.- . '~" ' ~;: :';" ".I;! ' :.;<..-,!, :$,>> \- ,_01 > '.,.~ .; '':t~ '-;'""'<'. {'. ~' "" JUL 15 1994 dJv CHRIS'l'OPHER P. MARKLEY, Plaintif:f : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v . . :NO. 2730 - CIVIL - 1994 . . BILLIE JO (ELLIS) KANE, Defendant . . :CIVIL ACTION - CUS'l'ODY ro~TO~~ ' 11 ~ AND NOW, this LL.. day of v , 1994, the Conciliator having convened a Conference tf is matter and then learning that the case was reassigned to the other Custody Conciliator in Cumberland County because of this Conciliator's potential conflict, the undersigned Conciliator relinquishes jurisdiction in this case. (/}tlf- KJ Hubert x. Gilroy, squire Custody Concilia or ; l!J ~ , -., ,;\ 1.6 I." rr c r i lrr I' .; <. ,) . I i . -1UJ ~l'fUloL. I-'ll!~ Aue 18 1994 ci~ CHRISTOPHER P. MARKLEY, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND ) COUNTY, PENNSYLVANIA vs ) ) CUSTODY/VISITATION BILLIE JO (ELLIS) KANE, ) Defendant ) NO. 94-2730 CIVIL ORDER OF COURT AND NOW, this 15th day of August 1994, it being reported to the conciliator that the parties have reached an agreement which makes further proceedings unnecessary, the undersigned conciliator hereby relinquishes jurisdiction and returns the matter to the Court Administrator. If either of the parties wishes further proceedings in this action, they should petition the Court anew. 1 L. Andes Custody Conciliator ~ ! CI"lI ~~ - a ..f ~... t t..;r. u, t~ :;:}"'. ... (,,)z'-;r ~<.')O"'l ~ I... ':I~'>" en -~ . .;:~ . I ~ .. t ("O'"l : ...1,": "" .. .-'. ,. " ~ :~,v t,,) => ...,