HomeMy WebLinkAbout98-01856
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KATHRYN E. COGLEY,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO . -!u. / l' y (. d;,,') 7~~,_
v.
SCOTT R. COGLEY,
Defendant
CIVIL ACTION - CUSTODY
COMPLAINT FOR CUSTODY
1, The Plaintiff is KATHRYN E, COG.LEY, who presently resides
at 1619 Wyndham Road, Camp Hill, Cumberland County, Pennsylvania
17011.
2, The Defendant is SCOTT R, COGLEY, who presently resides
at 308 Blacksmith Road, Camp Hill, Cumberland County, Pennsylvania
17011 .
3. Plaintiff seeks custody of the following children:
Name
Devon Rae Cogley
Present Address
1619 Wyndham Road
Camp Hill, PA 17011
&rn
10 years
old
Drew Scott Cogley
1619 Wyndham Road
Camp Hill, PA 17011
7 years
old
The aforementioned children were not born out of wedlock.
The children are presently in the custody of Plaintiff.
During the past five (5) years, the children have resided with
the following persons at the following addresses:
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Plaintiff and
Defendant
Mdress
308 Blacksmith Road
Camp Bill, PA 17011
J2a!: e s
from birth to
03/31/98
04/01/98 to
present
Plaintiff,
1619 Wyndham Road
Camp Hill, PA 17011
'l'he mother of the children is Plaintiff, currently residing at
1.619 Wyndham Road, Camp Hill, Pennsylvania 17011.
She is married,
The father of the children is Defendant, currently residing at
308 Blacksmith Road, Camp Hill, Pennsylvania 17011,
He is married,
4, The relationship of Plaintiff to the children is that of
mother. The plaintiff currently resides with the children,
5. The relationship of Defendant to the children is that of
father, The Defendant currently resides by himself,
6, Plaintiff has not participated as a party or witness, or
in another capacity, in other litigation concerning the custody of
the children in this or another court.
Plaintiff has no information of a custody proceeding concern-
ing the children pending in a court of this Commonwealth.
Plllinti ff does not know of a person not a party to the
proceedings who has physical custody of the children or claims to
have custody or visitation rights with respect to the children.
7. The best interest and permanent welfare of the children
will be served by granting the relief requested because Plaintiff
has always been the primary caretaker of the children,
8. Each parent whose parental rights to the children have
not been terminated and the person who has physical custody of the
.children have been named as parties to this action.
2