HomeMy WebLinkAbout07-2876Hubert X. Gilroy, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
I.D. 29943
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MARGARET K. MCHUGH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
JOSEPH J. MCHUGH,
Defendant
CIVIL ACTION LAW
N0.2007 - 01- g7(. ct~~) ~crn
IN CUSTODY
PLAINTIFF'S COMPLAINT FOR CUSTODY
1. Margaret K. McHugh, Plaintiff is an adult individual currently residing at 118 Parker
Street, Carlisle, Cumberland County, Pennsylvania.
2. Joseph J. McHugh, Defendant is an adult individual whose address is 116 Pine Tree
Drive, Newville, Cumberland County, Pennsylvania, and is currently residing at Allenwood Federal
Correctional Complex in White Deer, Pennsylvania.
3. Plaintiff seeks custody of the child, Aedan K. McHugh, who was born on May 12,
1995. The child was born during the parties' marriage. Since the child's birth, the child has resided
with the following persons at the following addresses for the following periods of time:
4. The relationship of the Plaintiff to the child is that of Mother. She is married and
living separately. The Plaintiff currently resides with the following:
Name Relationship
Aedan Son
5. The relationship of the Defendant to the child is that of Father. He is married and
living separately. The Defendant currently resides with the following: Defendant is in prison at
Allenwood Federal Correctional Complex in White Deer, Pennsylvania.
6. The parties have not participated in previous litigation concerning the custody of the
child in this court or any court.
7. The Plaintiff has no information of a custodyproceeding concerning the child pending
in any other court.
8. The best interest and permanent welfare of the child will be served by granting
custody to Plaintiff because: she can best provide a stable and nurturing environment for her son.
9. Plaintiff does not know of any person not a party to these proceedings who claims to
have custody or visitation rights with respect to the child.
WHEREFORE, Plaintiff requests your Honorable Court to sign an Order consistent with the
Stipulation and Proposed Order filed simultaneously with this Complaint.
MARTSON L~A~V OFF~ES
By
Huli~ Gilroy, Esquire
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
Date: May 14, 2007
VERIFICATION
I, Hubert X. Gilroy, Esquire, of the firm of MARTSON DEARDORFF WILLIAMS OTTO
GILROY & FALLER, attorneys for Plaintiff Margaret K. McHugh, in the within action, certify that
the statements made in the foregoing Complaint for Custody 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.
Hube .Gilroy, Esquire
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F:\FILES\DATAFILE\General\Currrnt\11635\ 11635.5[ryulation
Created: 9120104 0:06PM
Revised: 4/24/07 11:06AM
Hubert X. Gilroy, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
I.D. 29943
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MARGARET K. MCHUGH,
Plaintiff
PENNSYLVANIA
v
JOSEPH J. MCHUGH
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
CIVIL ACTION LAW
. NO. ~ ~ ~' ~Ss'J (o c ~ u ~ I -~ cry
STIPULATION
Legal counsel for the parties hereby agree and stipulate that the Court may sign the
attached Custody Order.
Manson Law
DATE: Apri124, 2007
By// (~
Hubert X.
Attorney 1
Martso~
;I(roy, Esquire
Plaintiff
~rdorff Williams Otto Gilroy & Faller
10 East igh Street
Carlisle, PA 17013
(717) 243-4574
~~
DATE: 7i 2007
By h
Michael A. Scherer, squire
Attorney for Defendant
O'Brien, Baric & Scherer
19 West South Street
Carlisle, PA 17013
(717) 249-6873
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F:\FILES\DATAFILE\General\Current\I163S11635.Custody Order
Creazed: 9/20/04 0:06PM
Revised: 5/14/07 0:26PM
Hubert X. Gilroy, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
I.D. 29943
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MAY 18 20071'
MARGARET K. MCHUGH,
Plaintiff
v.
JOSEPH J. MCHUGH,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2007 - ~Q'~ (,
IN CUSTODY
ORDER
CIVII. ACTION LAW
AND NOW, this l1,Rdday of I~ ay 2007, upon consideration of the attached
Stipulation signed by legal counsel for the p iesart , it is ordered and directed as follows:
1. The father, Joseph J. McHugh, and the mother, Margaret K. McHugh, shall enjoy
shared legal custody of Aedan K. McHugh, born May 12, 1995.
2. The mother shall enjoy primary physical custody of the minor child.
3. The father shall enjoy periods of temporary physical custody of the minor child at
such and under such circumstances as agreed upon by the parties.
3. This Order shall be deemed to be sufficient authority for the mother to obtain a
passport for the minor child without the signature of the father.
4. This Order may be modified at anytime, and any party who desires a modification of
this Custody Order may Petition the Court to have the case scheduled for a
conference with a Custody Conciliator.
cc: ~-Iubert X. Gilroy, Esquire
~chael A. Scherer, Esquire ~
BY THE COURT,
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