HomeMy WebLinkAbout95-05199
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1 Maryann Murphy, Esquire for mother - Legal Services
2 Father - pro se
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4 DAVID R. KIF.K V JODIE E. KIRK -- NO. 5199 CIVIL 1995
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THE COURT: Now, I understand that you may
7 have an agreement?
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MS. MURPHY: Yes, Your Honor.
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THE COURT: Ms. Murphy, I think the proposal
10 is that you would read it into the record, and then what I
11 can do is have it transcribed and put it in the normal form
12 of a court order.
13
MS. MURPHY: Your Honor, Mr. & Mrs. Kirk
14 have agreed to the following.
15 Custody will be shared legal and shared
16 physical. The shared physical is two weeks on and two
17 weeks off. It begins March 3rd, 2000, with mom having the
18 first two-week period. And dad's first two-week begins
19 March 17th. That's going to be year round, summer and
20 school time.
21 The child's school will remain in the
22 Boiling Springs District. Both parents will give the other
23 the right of first refusal if they need to be away from the
24 child for a period of time where they feel he needs someone
25 with him. The parent who is receiving custody will provide
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1 the transportation.
2 The child's birthday, which is February 3rd,
3 whichever parent does not have custody will still have the
4 opportunity to see him if it is a school day, maybe an
5 hour, an hour and a half. If it is not a school day, for a
6 longer period of time.
7 Memorial Day, 4th of July and Labor Day will
8 just be with whichever parent has that two-week period.
9 Easter and Thanksgiving will alternate each year, with mom
10 having Easter in 2000 and even years, and dad having
11 Thanksgiving in 2000 and even years. And dad's Easter in
12 odd years and mom Thanksgiving in odd years. The hours can
13 be by agreement of the parties unless they are unable to
14 agree, in which case it can be 9:00 to 6:00.
15 Christmas itself will be divided into two
16 periods. Noon Christmas Eve to noon Christmas Day is the
17 first period. And noon Christmas Day to noon December 26th
18 is the second. In even years mom gets the first period.
19 And in odd years dad gets the first period.
20 The rest of the child's school vacation
21 during the Christmas holiday will be equally divided. So
22 that two-week will be suspended during the Christmas
23 holiday.
24 Father's Day will be with father. And
25 Mother's Day will be with mother. And that will begin the
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1 Saturday before the holiday about 6:00 until Sunday at
2 6:00.
3 The child currently is in therapy. Both
4 parents will be involved in the therapy, bringing the child
5 obviously on their weeks.
6 Both parents' names will be with the school
7 and with the doctors so that they will be able to
8 communicate with the professionals. And the parents will
9 communicate with each other, particularly when one parent
10 has the two-week period, to advise the other of what has
11 occurred.
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JUN - 2 ~
David R. Kirk
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY
: PENNSYLVANIA
: No. 95-5199 CIVIL I TERM
: CIVIL ACTION-CUSTODY
vs,
Jodie E, Kirk
Defendant
PETITION FOR MODIFICATION OF TEMPORARY CUSTODY ORDER
ORDER
AND NOW. this day of .1999, upon consideration of the
within petition for modification of temporary custody, a hearing is to be scheduled
for the day of 1999 at o'clock
_M in the Court Room in the Cumberland County
Court House.
All children five and older are also to be present at the hearing.
BY THE COURT
You should tnke this Legal document to your
Lawyer at once. If you do not have a Lawyer
or can not afford one. Telephone the office set
forth below to find out where to get legal help.
Office of the Court Administrator Cumberland County COllrt House
Carlisle, Pa 170 \3 Phone (717) 243-6200
.
d. The residents of both dwellings were and are as follows:
NAME RELATIONSHIP
Andrew David Kirk Son of the Plaintiff and the Defendant
Robert Cockerell Boyfriend of the Defendant
Taylor Cockerell Son out of wedlock
To the Defendant and her boyfriend
e. The Plaintiff hus not participated in any other litigation concerning the
custody of the Child since the Temporary Order of the Court, dated us
11th day of June, 1997, in this or any other state, A true copy of that
order, is attached to this complaint.
f. The Plaintiffhus no other infonnation of any other custody proceedings
concerning the Child, pending in a court, in this or any other state.
g. The Plaintiff does not i..~ow of any person not a party to the proceedings who
hus physical custody of the Cj. 'Id, or claims to have custody or visitation
rights with respect to the Child.
5. To the Honomble Court, it would be in the best interest of the Child, to award
custody to the Plaintiff, He is a caring loving father, who wants the Child to
receive the best Intellectual, Spiritual and Physical up bringing possible,
6. The custodial home is not adequate to provide for the Child:
a. There are no pecrs the Child's own age to internet socially with.
b. There is vel)' little for the Child to do. us go to the play ground or just go over
to a friends house to play, visit or maybe study common school work.
d. The home surroundings are secluded, that the Child could not internet with
a variety of different people or cultures, or business or to buy things on his
own,
e. The Defendant lives in a vel)' ruml, almost mountainous area where there are
log cabins vacation and retirement homes. The Child is not in the main
stream of life, and is inadequately being provided this lor his social
development.
,.
f, The relatives are about a 15-20 min. commute from the dwelling of the Child,
the child visits only when it is in the best interest or convenience of the
defendant
7. The Plaintiffs living environment:
a. A small town of about 10 thousand people, The community has a variety uf
cultures and business, thatlhe Plaintiff can teach and inslructlhe Child un
personal Wid social behaviors, for the Child's development,
b. The Child's peers could visit his home, or at their home, 10 give more
personal social skills.
c, The Child's relations would be only minules uwuy, und Ihc Child could visit
for short or long periods of time without an inconvenience 10 the l'luintifl'
d. The Plainliffplans to stay in the local area for a subslllnlilll wl10llnl of time
because the Child need a stable area 10 have a sense of belonging, und where
the Child's relatives are close or even directly involved ( cousin In the SlIlIIe
school) so the Child would have good home life memories,
8. Time taken to travel and visit other areas than the home llrell,
a. The Child is not taken on vacations or even duy trips 10 stimulute othcr
types of thinking or relieve the stress oflhe daily Ihings Ihllt'Ire required of
parent and child.
b. lbe Child docs not gel 10 participate in a day ellmp Of w~'Ck Clll1lp, 'Ibis is
ne~'lied lor educationlll fun and interaction with peers in a slructured
environment.
e. The only time away from home, is either with the Defendant's muther, which
the mother can only handle 2 or 3 dllYs with Ihe child lit one time,
Or atlhe Plaintitrs mothers residence, The 1'IIIInlll1's lIIother WIIS required
to huve the child from 4 dllYs to up to \/) dllYs lit II time.
9. The interest in the educational needs of the Child are not being met:
a, The Defendant does not take time to internet in the parent teacher
conferences unless there is a problem with the Child's progress.
b. The defendWlt did not attend a Comprehensive Evaluation Conference about
the Child. There were numerous attempts to schedule this meeting but the
defendant did not attend Wld the Plaintiff had to make decisions about the
Child that the Defendant should have donel
c. Recently the Dcfendant was asked to talk with the teachers about the Child's
home work assignments, that were not being completed. On reviewing the
past two years of report cards this has been a trend through out the cntire
time!
d. Thc Child has asked for help in the past with home work, the Defendant only
had excuses of being busy and did not have time, so the Child stopped
askingl
10. The Child WWl\S to live with the Plaintifl':
a. The Plaintiff does take interest in the Child's academic studies.
b. The Plaintiff does see to the needs of the Child.
c. The Plaintiff does take great interest in the Child having good Wld educational
experiences in life.
11. The Plaintiff takes the Child on numerous vacation trips. Just to name a few.
Baltimore's Inner Harbor. ( I WWlt to get a membership at the Science museum.
When we were there last time it was too expensive.) Williamsburg Va., the
Colonial Wld historic part ( I had the child on Wl Educational trip Wld had him
write a short essay on what he saw Wld experienced). we went to
Myrtle Beach South Carolina, it was the first time at about 8 or 9 yr. old the
Child saw the ocean (And we got our feet wet!)
.-1
Wherefore, the PlaintilTrespectfully r~'quests thatlhe Honorable Court enter an
order granling legal and physical custody of the Child, until the Child's 18th
birthday.
With visitation rights reserved for the Defendant of every other weekend and
every other Holiday,
Respeclfully submitted,
Date-=:Jv..UE' \ ) qq~
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By Ov~/f7~
David R. Kirk
DAVID R. KIRK,
PlaintiCC
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACfION . LAW
95.5199 CIVIL
IN CUSTODY
vs,
JODIE E, KIRK.
DeCendant
ORDER
AND NOW, this
II ~
day oC June, 1997. after hearing. it is ordered and directed
that the parties shall share legal custody oC the child, Andrcw David Kirk born February 3, 1987,
Primary physical custody oC said child shall be in his mother, Jodic Kirk, subject to such
periods oC partial custody in the Cather as shall be agreed upon by the parties to include at a
minimum:
1. Every other weekend and one additional weekend every two months,
2. On alternating holidays as the parties shall agree,
3. For Cour weeks during each calendar year, with no more than two weeks to be
consecutive and to be cxercised with sixty days' notice, In thc event the Cather chooses to
exercise thcse periods oC partial custody during the school year, he shall assure the child's regular
school attendance.
BY THE COURT,
David R. Kirk
p, O. Box 384
Mechanicsburg, PA 17055
Jodie E, Kirk
205 East Springville Road
Boiling Springs, r A 17007
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DAVID R, KIRK
PLAINTIFF
: TIlE COURT OF COMMON PLEAS OF
: CUMIlERLAND COUNTY. PENNSYLVANIA
V
JODIE E. KIRK
DEFENDANT
FILE No, 95-5199
: CIVIL ACTION
: CUSTODY
Amendment MEMORANDUM
To the Honorable said court, and to the council for the Defcndant. I David Kirk rctractthe
witness on my behall: excluding Andrew D. Kirk who should ullend the hcuring, but is not bcing
subpoenued to uppear. A true copy of the alluched witness is incorporated hcre in and to this
document. Mr. Kirk will be prescnting only fucts allll documents to substantiate thc
accusations stated in the mcmorandum submilled on or about November 17, 19Q9, and to thc
mcmorandullI submited by council for thc Defendunton Deccmber 2, 1999
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David R, Kirk
DAVID R. KIRK,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
95-5199 CIVIL
IN CUSTODY
JODIE E. KIRK,
Defendant
ORDER
AND NOW, this
'Z.., ~
day of November, 1999, at the request of counsel for
the defendant, hearing in the above captioned malter set for December I, 1999, is continued to
Wednesday, February 9, 2000, at 9:30 a.m. in Courtroom Number 4, Cumberland County
Courthouse, Carlisle, PA.
BY THE COURT,
David R. Kirk
P. O. Box 384
Mechanicsburg, P A 17055
Jodie E. Kirk
205 Enst Springville Road
Boiling Springs, PAl 7007
Ad-
Joan Carey, Esquire
For the Defendant
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SEP 1 4 199~
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION . LAW
NO. 95-5199 CIVIL
IN CUSTODY
DAVID R. KIRK,
Plaintiff
JODIE E. KIRK,
Defendant
COURT ORDER
AND NOW, this I &-tA day of September, 1999, upon considemtion of the attached Custody
Conciliation Report, it is ordered and directed ns follows:
I. A hearing is scheduled in Courtroom No.4 of the Cumberland County Courthouse
on the..!EL day of .1)~"'/l/'''l j, 1999, at I: j/1J..M. at which time testimony will
be taken in the above case. At this hearing, the Father, David R. Kirk, shall be the
moving party and shall proceed initiolly with testimony. Both parties sholl file with
the court and the other party a memorandum setting forth the history of custody in
this case, each parties position on custody, a list of witnesses who will testilY on
beholf of that party and a summary of the anticipated testimony of each witness.
This memorandum sholl be filed at lenst 10 days prior to the mentioned hearing date.
The memorandum filed with the court shall be filed in the Judge's chambers, while
the memorandum going to the other party shall be mailed to the other party.
2. Pending further order of this court, this court's prior order of June I I, 1997 shall
remain in effect.
BY THE COURT,
cc:
David R. Kirk
Jodie E. Kirk
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DAVID R. KIRK,
Plaintiff
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACl'ION . lAW
95.5199 CIVIL
IN CUSTODY
vs.
JODIE E. KIRK,
Defendant
ORDER
AND NOW, this
/I.
day of June, 1997, ufter heuring, it is ordered und directed
that the parties shall share legal custody of the child, Andrew David Kirk born February 3, 1987.
Primary physical custody of suid child shall be in his mother, Jodie Kirk, subject to such
periods of partial custody in the father as shall be agreed upon by the parties to include at a
minimum:
I. Every other weekend and one additional weekend every two months.
2. On alternating holidays as the parties shall agree.
3. For four weeks during each calendar year, with no more than two weeks to be
consecutive and to be exercised with sixty days' notice. In the event the father chooses to
exercise these periods of partial custody during the school year, he shall assure the child's regular
school attendance.
BY THE COURT,
David R. Kirk
P. O. Box 384
Mechanicsburg, PA 17055
A
Jodie E. Kirk
205 East Springville Road
Boiling Springs, PA 17007
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1997
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DAVID R. KIRK,
Plaintiff
V
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:
:CIVIL ACTION - LAW
JODIE E. KIRK,
Defendant
.
.
:NO: 95-5199
:IN CUSTODY
COURT ORDER
AND NOW, this s't'"Ii day of March, 1997,
attached Custody Conciliation Report, it
follows:
1.
upon consideration of the
is ordered and directed as
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A h~ring is scheduled in the above casetlon the 1/ day of
lAl.-Q...... , 1997, at 9:301/.M. at which time testimony will
be eard. At this hearing, the Father, David R. Kirk, shall
proceed initially with testimony. The parties shall file with
the Court a memorandum setting forth the history of custody in
this case, the issues that will be presented to the Court at
this hearing, the witnesses that each party will call at the
hearing, and a summary of the anticipated testimony of each
witness. This memorandum shall bu filed ten (10) days prior
to the hearing date scheduled above.
2. Pending further order of this Court, the following temporary
custody order is entered:
A. The Father., David R. Kirk, and the Mother, Jodie E. Kirk,
shall enjoy shared legal custody of Andrew David Kirk,
born February 3, 1987.
B. The Mother shall-enjoy primary physical custody of the
minor child.
C. The Father shall enjoy periods of temporary physical
custody with the minor child as agreed upon by the
parties.
BY THE COURT,
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J.
c~: David R. Kirk
P. O. Box 384
Mechanicsburg, PA 17055 J..:
Jodie E. Kirk l~
205 East Springvil1e Road
Boiling Springs, PA 17(),ffl.
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DAVID R. KIRK, IIN THE COURT OF COMMON PLEAS OF
Plaintiff ICUMBERLAND COUNTY, PENNSYLVANIA
.
.
V :CIVIL ACTION - LAW
:
JODIE E. KIRK, :NO: 95-5199
Defendant : IN CUSTODY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the
following report I
1. The pertinent information pertaining to the child who is the
subject of this litigation is as follows:
Andrew David Kirk, born February 3, 1987.
2. A Conciliation Conference was held on February 27, 1997, with
the following individuals in attendance:
The Father, David R. Kirk, and the Mother, Jodie E. Kirk.
Both parties appeared without legal counsel and intend to
represent themselves in these proceedings.
3. The parties were previously before Dawn S. Sunday, Esquire, as
the CustodJ' Conciliator in December of 1995. There was no
agreement reached at that Conciliation Conference and, when
the parties did not request a second Conciliation Conference,
the Cona1liator relinquished jurisdiction. The Father has now
petitioned to obtain custody of the parties' minor son.
4. The minor child resides with the Mother. The Mother lives
with her boyfriend and a child of the Mother and her
boyfriend. The Father lives alone.
5. The Father suggests that he should have custody of the minor
child because the child wants to live with him at this time
and because he does not feel the child is getting an
appropriate upbringing in the Mother's home. He cites the
fact that the Mother is living with her boyfriend and is not
married. He also cites a suggestion that the Mother and her
boyfriend make the nine year old take care of the new infant
ch,ild.
6. The Mother agrees that the minor child wants to see more of
his Father. However, Mother cites the fact that the Father
did not show any interest in the child for over seven months
during 1996 when he did not see the child at all. Mother
suggests that the child merely misses his Father and would be
satisfied if Father would have and take advantage of a routine
scheduled visitation. Mother suggests that the minor child is
,
. .
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I verity that the statements made in the attached pleading are true and correct to
the best of my knowledge, information and belife. I understand that false statements
herein are made subject to the penaltics of 18 Pa. C.S.A. 4904, rclating to unsIVorn
falseification of authorities.
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David R. Kirk, Plaintiff
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Andrew David Kirk
February 3, 1987
Defendant/Mother
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DAVID KIRK, . IN THE COURT OF COMMON PLEAS OF
,
plaintiff CUMBERLAND CQUNl'Y, PENNSYLVANIA
vs. : NO. 95-5199 CIVIL TERM
.
.
JODI KIRK, CIVIL ACTION - LAW
Defendant : IN CUS'l'ODY
~ CCNCILlATlm SUMARY REP(Rr
IN AQCXJUII\NCE WI.'l'H ClJ'lBERLlIND ann"i IWLE OF CIVIL l'\lOCBIlURB
1915.3-8, the undersigned Custudy conciliator submits the following report:
1. The relevant information pertaining to the Child who is the subject
of this litigation is as follows:
NAME
-
BIRTHDATE
CURRENTLY IN CUSTODY OF
2. A Conciliation Conference was
following individuals in attendance:
counsel, David A. Rahol Esquire, and
counsel, Keith DeArmond, Esquire.
held on November 29, 1995, with the
The Father, David Kirk, with his
the Mother, Jodi Kirk, with her
3. The Fa.ther filed this petition for primary physical custody of the
Child, who has been in the Mother's custody since the parties separated in
June 1992. The Father stated that he was seeking primary custody because he
believed the fact that the Mother was living with her boyfriend was immoral
and therefore would adversely affect the Child. The Mother replied that she
has been seeking a divorce from the Father so that she could remarry but the
Father refused to consent. There had been some misunderstandings between
the parties which seemed to be resolved at the conciliation Conference. The
parties agreed, at least on a temporary basis, on a schedule of partial
physical custody for the Father. The parties' counsel requeated that this
matter be placed on hold without entry of a temporary order while they
continued to discuss the possibility of obtaining a custody evaluation and
further determine whether there was any need for a hearing in this matter.
Subsequently, the Father's counsel, David A. Rahol Esquire withdrew from
representation of the Father.
4. Having received no cOlTll1unication from either party since December
12, 1995, the conciliator believes no custody order is desired or necessary
in this matter and therefore attaches an Order relinquishing jurisdiction in
this case.
OJ/.J.:J.J 91.1
Date
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Dawn S. Sunday
custody conciliator
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(17) 243-9190 Paca1mIIo 017l243-9941
DEe I 8 1995" (If.
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DAVID KIRK,
plaint! ff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-5199 CIVIL
JODIE KIRK, CUSTODY
Defendant
IN RE: MOTION FOR LEAVE TO WITHDRAW FROM REPRESENTATION
AND NOW, this
20'
ORDER OF COURT
day of
J>(..t~
, 1995
upon consideration of the Within Motion and on motion of David A.
Raho, Esquire, the Motion for Leave to Withdraw from Representation
is granted.
David A. Raho, Esquire
Attorney for Plaintiff
Keith B. DeArmond, Esquire
Attorney for Defendant
Dawn S. Sunday, Esquire
Conciliator
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By the Court,
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DAVID KIRK,
PlAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-5199 CIVIL
v.
JODIE KIRK,
DEFENDANT
CUSTODY
MOTION FOR LEAVE TO WITHDRAW FROM REPRESENTATION
AND NOW, this 15th day of December, 1995 comes Plaintiff's
counsel, David A. Raho, Esquire who files the within Motion and in
support thereof avers the following:
1. David A, Raho, Esquire has not filed a formal praecipe
entering an appearance on behalf of Plaintiff in the above
captioned matter.
2. On October 6, 1995, David A. Raho, Esquire filed a
Complaint for Custody in the above captioned matter.
3. A conciliation conference in this matter was held on
November 29, 1995 before Dawn S. Sunday, Esquire.
4. The parties were unable to agree upon a custody order at
the conciliation conference,
5. Since the date of the conciliation conference,
Plaintiff's counsel has accepted employment in Cambria County and
will no longer be able to represent Plaintiff in the above-
referenced action.
6. Plaintiff's counsel has informed Plaintiff of his intent
to withdraw from representation.
7. Plaintiff's interest is not prejudiced by his counsel's
.
request to withdraw from representation.
WHEREFORE, Plaintiff I s counsel respectfully 1:equests this
Honorable Court to grant this Motion for Leave to Withdraw from
Representation.
Respectfully submitted,
SODUS & VERNEY
By J~ a fh.tuy-
David A. Raho, Esquire
1.0. No. 73198
7 Irvine Row
Carlisle, PA 17013
717/243-9190
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the within
Motion was served upon the following persons by first class U.S.
mail on the 15th day of December, 1995 at the following addresses:
D3.vid Kirk
P.O. Box 364
Mechanicsburg, PA 17055
Keith B. DeArmond, Esquire
2600 Market Street
Camp Hill, PA 17011
Dawn S. Sunday, Esquire
39 West Main Street
Mechanicsburg, PA 17055
Respectfully submitted,
SODUS & VERNEY
ByJr~a~
David A. Raho, Esquire
LD. No. 73196
7 Irvine Row
Carlisle, PA 17013
717/243-9190
Attorney for Plaintiff
SODUS &: VERNEY
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DAVID KIRK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-5199 CIVIL TERM
v.
JODIE KIRK,
Defendant
CIVIL ACTION - CUSTODY
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the
Plaintiff's Complaint for Custody was served upon Jodie Kirk,
Defendant, by certified mail, return receipt requested, on the 12th
day of October, 1995, at the following address:
Jodie Kirk
205 Springerville Road
Boiling Springs, PA 17007
Respectfully submitted,
SODUS & VERNEY
ByJr~ (L ~tw---
David A, Raho, Esquire
1. D, No, 731 9 B
7 Irvine Row
Carlisle, PA 17013
717/243-9190
Attorney for Plaintiff
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AIlanOJI"'Law
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tarIIoIt. -71'" t7013
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During the child's lifetime, Andrew David Kirk has resided
with the following persons and at the following addresses:
fiWlm
David Kirk
Jodie Kirk
David Kirk
Jodie Kirk
Lynn Kirk
Jodie Kirk
Robert Cockerell
Jodie Kirk
Robert Cockerell
Address Da tes
P.O. Box 4 Birth to 5/91
Shermansdale, PA 17090
919 Trindle Road 5/91 to 6/92
Mechanicsburg, PA 17055
328 West Allen street 6/92 to 8/93
Mechanicsburg, PA 17055
205 Springerville Road 8/93 to present
Boiling Springs, PA 17007
The father of the child is the Plaintiff, David Kirk, who
currently resides at P.O. Box 384, Mechanicsburg, Cumberland
County, Pennsylvania 17055.
The mother of the child, is the Defendant, Jodie Kirk, who
currently resides at 205 Springerville Road, Boiling Springs,
Cumberland County, Pennsylvania, 17007.
Plaintiff and Defendant were married on August 30, 1980 in
Mechanicsburg, Pennsylvania.
4. The relationship of the Plaintiff to the child is that of
father. The Plaintiff currently resides alone.
5. The relationship of the Defendant to the child is that of
mother.
The Defendant currently resides with the following
persons:
~
Andrew David Kirk
Robert Cockerell
Relationshio
Son
Boyfriend
6. The Plaintiff has not previously participated as a party
or witness, or in another capacity, in any litigation concerning
custody of the above mentioned child in this court or any other
court.
7. The Plaintiff has no knowledge of any custody proceedings
concerning the above mentioned child pending before a court in this
or any other jurisdiction.
8. The Plaintiff does not know of any person not a party to
this action who has physical custody of the child or claims to have
custody or visitation rights with respect to the child.
9. The best interests and permanent welfare of the child
will be met if custody is granted to the Plaintiff because :
(a) The Plaintiff is a loving, concerned parent who, has
been, and continues to be fully capable of providing for
the emotional and physical needs of his child.
(b) The Plaintiff is a fit parent who can best take care
of his child.
(c) The Defendant is incapable of providing a stable
home environment for the child.
10. 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, Plaintiff respectfully requests that this Honorable
DAVID R. KIRK
PLAINTIFF
: TilE COURT OF COMMON "LEAS OF
: CUMBERLAND COUNTY. PENNSYLVANIA
V
JODIE E. KIRK
DEFENDANT
: FlLF. No. 9!1-~199
: CIVIL ACTION
: CUSTODY
MF.MORANDUM
To the honorable court. I David R. Kirk come before this court to submit a slalcment of
facts on the above captioned casc.
I. On or about or ahout August 1980 thc partics were marricd,
2, On or about February 1989 a child, Andrcw D, Kirk was born,
3. On or about July 1990 the parties did purchnse a homc at919 W.Trindle Rd.
Mechanicsburg, the pa.tics thc child and the Mr, Kirks mothcr resided,
4. On or about June 1992 Mrs. Kirk vacatcd the marital home with Andrew D. Kirk(the
child) on hcr own accord.
5, Mrs. Kirk stated that she was dissotistied with thc was thc relationship wns between
Mr, Kirk and her self, Mrs, Kirk initialed a vcrbul visitation agreemcnt. 6. Mrs, Kirk
retained an apartment in Mechanicsburg with thc (Child).
7. On or about the beginning of 1993 did start cohabitation with a Mr. Cockrell.
8. On or about June 19~3 Mrs. Kirk the Child and Mr. Cockrell moved from
Mcchanicsburg to Boiling Springs. whcrc they rcsided in a small mobile homc,
9. On or about June 1998 Mr. Cockrell purehnsed the prescnt home from his mothcr that
he, Mrs, Kirk und the child now residc.
10, On or aboutJune 1996 Mrs, Kirk bore a child to Mr. Cockrcll out of wcdlock. 11. On
ur uhout Fcbruary 1996 Mr, und Mrs, Kirk hud a dccrcc of Divorcc cntcrcd into the
Cumberland county court house,
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The position of Plaintiff
Mrs. Kirk hns the custodial responsibility for the child Andrew Kirk.
A, intcllectuul
1. Through the Puhlic School System and Ihen using nil life situations to
reinforec thosc learncd skills.
a, The neglect ofthc child's homc work, in school participation, or urmngc 10
provide for the support of the learning process is not fulfilling thllt responsibility.
2. To use IIny public events or exhibits to foster and inspire a desire to learn
more.
II.There is never hccn II special trip for the child's cducational upbringing on
the part of Mrs. Kirk
3, Mrs, Kirk has thc responsibility to round and guide the vision of the child
until he is old enough to provide lor himself.
8, well-being
I. The child has no encoumgement from the adults in the house.
2. Thc is subject to mcntal abuse (in the actions of the adults)
3. The wns and maybe still made to baby sit MR, Cockrells and Mrs. Kirks
progeny.
4. The many places the child stays whcn he is not in school. Does not give the
child a scnse of belonging to a home where the Custodial Parent is.
5, a, The child is left to do mostly what he wants, Unless Mrs, Kirk or Mr.
Cockrell want the child to do something.( tcnd to thc new bornc, feed the pets of
the house. or chores that the adults deem us responsible for Ihe child to do,
c. Preference of the Child,
I, Is to be with thc Mr, Kirk. Mr, Kirk providcs inspimtion for thc child, Ilc also
fosters the concept oftcuching the child tothc best of Mr. Kirks ahility so the child has
bellcr opportunitics than Mr. or Mrs, Kirk do atthc prcscnt time or with in thcre reccnt
past.
2. Thc child has morc opportunitics with Mr, Kirk as hc is computcr oriented and
hns II strong Mllth and Mechanical inheritance. in which Mr. Kirk CWl cncourage in thc
child,
3. Mr. Kirk takc the child places and docs things with him a. To build more
intellectual stimulation b, To just have somc fun and hc children again,
4, The child should be with a pllrentthat will take authority and responsibility for
the child's behavior in school and in socicty
In the lilw statements of fact, it shows that the bcst intercst of the child is not being meet
on the bchalf of Mrs, Kirk. Thesc conditions have bcen going on scnsc thc Ordcr of the
Court on or about June 1997. In that Mr. Kirk did not have enough knowledge to
understand what facts this Ilonomble Court need to be presented. Mr. Kirk prays that this
infonnation is enough to show the situation the child Andrew Kirk is in, That the
Honorable Court will sce that the best interest of the child is in awarding Primary
physical Custody to Mr. Kirk.
.--
David R. Kirk,
Plaintiff
In the Court of Common Pleas of
Cumberland County, Pennsylvania
v,
No. 95-5199
Civil! Term
Jodie E. Kirk,
Defendant
Civil Action. Custody
Mrmor8ndum
Presentation to the Court
And Now comes, the Plaintiff, David R. Kirk by and on his own behalf files a
memorandum and History of custody for the hearing for custody,
1. Plaintiff is David R. Kirk, an adult individual residing at P,O. Bx 384, Mechanicsburg,
Cumberland Country, Pennsylvania, 17055
2, Defendant is Jodie E. Kirk, an adult individual residing at 205 Springville Road,
Boiling Springs, Peansylvania, 17007
3. The Plaintiff seeks custody of the following child:
l!lJuIK Pnsent Residence
,4gc
Andrew David Kirk
205 Springvillo Road
Boiling Springs, Pa 17007
10 years
4. The Defendant has had approximately 4000 hours more per year of quality interaction
with the child than the Plaintiff. The Plaintiff wishes only to have equol amount of the
child, so the child can learn who his father is in character and the way his father thinks,
The child needs to see the characteristics of both of his pare:lts not one most times and the
other in a less amount of time. This is why the Plaintiff, wants the child to reside in sole
custody of the Plaintiff.
5, The Plaintiff only wishes the right to rear the child for the same period of time as the
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Defendant has, r~qh~, 1~,~t..1 0 years: " .' . ..' ' ," .,. ,
~iI"i~drrijile) lfa child'hast\hlricH'al~er to rule all the time. TherMhcfu'lt was Ilrlte for
t~~ i:hll~ 10 tetlre to sleep ~I rllgllt. the mother would have I hour to read the child a
bedtlnle slll/)', and hInd the n~s (feeding, washing clothing, ect, Without sight Of the
mother) of the child. Would this be fair to the child's mental state to have this scenario?
David R. Kirk,
Plaintiff
In the Court of Common Pleas of
Cumberland County, Pennsylvania
v,
No. 95.5199
Civil I Tenn
Jodie E, Kirk,
Defendant
Civil Action. Custody
Memorandum
History of Custody
To the Honorable Court:
Mr. Kirk the Plaintiff a common layman, Representing himself. Comes before this
honorable court, to ask for Judgment on granting the Plaintiff. Sole custody of the child as
the Plaintiff right as the Father of the child. The Plaintiff is a fair and God fearing man, the
statements herein will not show degradation to the Defendant. Only to present what has
nspired in the time from the birth of the child, to show the Plaintiffs rights,
I, In February 1987 when the child was born, The Defendant (as mother) cared for the
child, as agreed by the Plaintiff and the Defendant. The Plaintiff ( as father) would be the
solt; income of the family,
2, There were very distinctive dysfunctional problems that the Plaintiff and the Defendant
had within themselves, The Defendant confronted the Plaintiff with his problems and gave
an ultimatum to correct the Plaintiffs disfunctionnlity or the Defendant would seek
employment and leave the marital home,
3, On or about May 20,1992 the Defendant filed for Domestic Relations nssistance,
Knowing that the Defendant would be leaving the marital home within a short period of
time,
4, On or about June I ,1992 the Defendant did leave the maritol home, Taking the child
with her, The Plaintiff did not have any understanding that he had the right to Claim
custody of the child at this time.
S. In July 1993 the Plaintiff did seek council for custody through the Attomey referral
service. This Attomey told the Plaintiff that because there was no custody order that the
Plaintiff could on one of the weekends that the child was with him. The Plaintiff could just
keep the child and file for custody at that time. The Plaintiff knew this was not right to do,
and didn't pursue this option, chase
6. On or about June 1992 the Defendant permitted her boyfiiend to move into the
Defendants apartment in Mechanicsburg, Where the Defendant and the child had moved
to, from the marital home, The Defendant and her boyfiiend have cohabitated sense.
7. on or about 1994, The defendant the child and her boyfiiend, moved to a small two
bedroom mobile home in Boiling springs where they have resided until the present time.
8, on or about September 1995 the Defendant did become pregnant to here boyfiiend,
Then on or about June 1996 did have a child out of wedlock
9, On or about February 1996 there was a decree of divorce, between the Plaintiff and
the Defendant with relief pending,
10, The Plaintiff has dated only 3 persons from 1993 to 1996 on a continuous bases,
without cohabitation in any of these relationships,
I I. The Plaintiff did not exercise his right to visitation I time for a 6 mouth period in the
5 years that the Plaintiff has had a verbal agreement to visitation. The Plaintiff was
demanded on by his employer to work 10 and 12 hour shifts pre day. While the Plaintiff
was also trying to be his own legol representative, and seek out a paralegal to have court
papers drawn up so as to decrease the cost oflegal servk.es, and representation, The
Plaintiff did explain to the child of9 years old, that tbe Plaintiff would not be able to see
the child for these reasons, The Father and son had a clear understanding,
12, The Plaintiff at the time of the conciliation hearing was self-employed and did not
have a stable schedule. On suggestion of the conciliator the Plaintiff did secure a fuU time
position at $6,50 hour full time through a temporary employment agency, Then to be
hired full time with the Co, after the term with the temporary agency, with a substantiol
pay increase,
Varifcation
I VerilY that the statements made in the attached pleading are true and correct to
the best of any knosrledge, information and belife, I understand that false statements
herein are made subject to the penalties of 18 Pa, C,S.A. 4904, relating to unsworn
falseification of authorities.
Date
David R, Kirk, Plaintiff
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