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Home My WebLink About07-6749 Thomas D. Gould, Esquire ID #36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 CLAUDIA M. COMEFORD, Plaintiff V. ROBERT D. COMEFORD, Defendant C IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. v 7 - 6 7 X19' Cam! `7u.... CIVIL ACTION - LAW CUSTODY ACTION USTODY COMPLAINT TO THE HONORABLE JUDGES OF SAID COURT: 1. The Plaintiff is Claudia M. Comeford residing at 101 November Drive, Apartment #5, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is Robert D. Comeford residing at 2653 Walnut Street, Harrisburg, Dauphin County, Pennsylvania 17113. 3. Plaintiff seeks legal custody and primary physical custody of the following child: NAME PRESENT RESIDENCE DOB Liza A. Comeford 101 November Drive 09/22/99 Camp Hill, PA The child was born in wedlock. The child is presently in the physical custody of Claudia M. Comeford who resides at 101 November Drive, Camp Hill, Cumberland County, Pennsylvania. The child has resided with the following persons and at the following addresses: Person Address Date Mother 101 November Drive 05/07 - present Camp Hill, PA Mother Pennsylvania Apartments 02/07 - 05/07 Harrisburg, PA Mother 3 Harvard Place 06/03 - 02/07 Camp Hill, PA Mother 422 Duke Street 06/02 - 06/03 Enola, PA The mother of the child is Claudia M. Comeford who resides at 101 November Drive, Camp Hill, Pennsylvania 17011. She is single. The father of the child is Robert D. Comeford who resides at 2653 Walnut Street, Harrisburg, Pennsylvania 17113. He is single. 4. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently resides with the following persons: Name Relationship Liza A. Comeford Daughter Gladys Farragut Mother Fernando Farragut Step-father 5. The relationship of Defendant to the child is that of father. The Defendant is currently residing with: Unknown. 2 6. Neither party has 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 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: A. Mother has been the child's primary caretaker B. Father has not been involved in child's life. C. Mother will place her child's best interest before her own. D. Father has been alleged to have had improper physical contact with his daughter. 8. 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. WHEREFORE, Mother requests this Honorable Court to grant her legal custody and primary physical custody of Liza, subject to Father's right to periods of supervised visitation. Respectfully submitted, Thomas D. Gould, Esquire ID #36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 3 VERIFICATION I, CLAUDIA M. COMEFORD, hereby certify that the foregoing CUSTODY COMPLAINT is 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. DATED: Il - 6 -- O C AU COMEFORD aintiff 4 g r-` r.?..r -tl C:;j ? Tl CLAUDIA M. COMEFORD IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ROBERT D. COMEFORD DEFENDANT 2007-6749 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, November 09, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, December 04, 2007 at 9:30 AM 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 pennanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ae ueline M. Verne Es Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 -4z 4?v 0. Ey ?dNnor 6 ? :£ Wd £ I LION LOOZ i . AVIONOr G' d Hl JO 301 a i3 DEC 0 4 2007, ht CLAUDIA M. COMEFORD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2007-6749 CIVIL ACTION - LAW ROBERT D. COMEFORD, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this G' day of Dt W , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. Mother, Claudia M. Comeford, shall have sole legal custody of the child, Liza A. Comeford, born September 22, 1999. 2. Mother, Claudia M. Comeford, shall have sole legal custody of the child. 3. This Order is entered pursuant to the request of Mother at a Custody Conciliation Conference. The parties may modify the provisions of this Order 'by mutual consent. In the absence of mutual consent, the terms of this Order shall control. wu? i`a'vy. 0. &-Z" &r"-, ' J. cc: Thomas D. Gould, Esquire, for Mother Robert D. Comeford, pro se mac ?`?- 2653 Walnut Street Harrisburg, PA 17113 a; ?!?- 3 il L100Z 3Hi CLAUDIA M. COMEFORD, Plaintiff V. ROBERT D. COMEFORD, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :2007-6749 CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Liza. A. Comeford September 22, 1999 Mother 2. A Conciliation Conference was held in this matter on December 4, 2007, with the following individuals in attendance: Mother, Claudia M. Comeford, with her counsel, Thomas D. Gould, Esquire. Father, Robert D. Comeford, although served with notice of the conference, did not appear. 3. Mother requested an Order in the form as attached. Date Jacq line M. Verney, Esquire 14 Custody Conciliator