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HomeMy WebLinkAbout08-4678Jeannie Siegfried, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vi. : CIVIL ACTION - LAW IN CUSTODY Eugene Siegfried, Defendant : NO. 08- y? CIVIL TERM COMPLAINT FOR CUSTODY The plaintiff, Jeannie Siegfried, by her attorneys, the Family Law Clinic, sets forth the following cause of action in custody. 1. The plaintiff is Jeannie Siegfried, residing at 116 North Fayette Street, Shippensburg, Cumberland County, Pennsylvania 17257. 2. The defendant is Eugene Siegfried, residing at 74 Cortland Circle, Shippensburg, Franklin County, Pennsylvania 17257. 3. Plaintiff seeks primary custody of: Name Present Residence Age Andrew Marlin Siegfried 116 North Fayette Street, 11 Shippensburg, PA 17257 Adam David Siegfried 116 North Fayette Street, 9 Shippensburg, PA 17257 The children were born in wedlock. The children are presently in the custody of Jeannie Siegfried, who resides at 116 North Fayette Street, Shippensburg, PA 17257 During the past five years the children have resided with the following persons at the following addresses: Persons Kristina Siegfried Dawn Roberts Jeannie Siegfried Address 116 North Fayette Street, Shippensburg, PA 17257 Dates 2/1/2007 - Present Kristina Siegfried 74 Cortland Court 8/1/2003- 2/1/2007 Matthew Siegfried Shippensburg, PA 17257 Eugene Siegfried Jeannie Siegfried The mother of the children is Jeannie Siegfried. She is married. The father of the children is Eugene Siegfried. He is married. 4. The relationship of Plaintiff to the children is that of mother. The Plaintiff currently resides with the following persons: Name Relationship Kristina Siegfried Daughter Adam Siegfried Son Andrew Siegfried Son Dawn Roberts Roommate 5. The relationship of Defendant to the children is that of father. The Defendant currently resides with the following persons: Name Matthew Siegfried Relationship Son 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 concerning the children pending in a court of this Commonwealth, or any other state. Plaintiff 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: a. Plaintiff has been the children's primary caretaker for all of the children's lives; b. Plaintiff provides the children with a stable home and environment with adequate moral, emotional, and physical surroundings as required to meet the children's needs; c. Plaintiff has permitted contact between Defendant and the children and will continue to do so; d. Plaintiff is willing to accept custody of the children. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody to the children have been named as parties to this action. WHEREFORE, Plaintiff requests the court to grant her shared legal custody and primary physical custody of the children, with the father having periods of partial custody. Date: ?-> q 1 .2 Respectfully submitted, MICHAEL LIGHTFOOT Certified Legal Intern A&ZGZ:?? ANN MACDONALD- X MEGAN RIESMEYER Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. "- kANNIE SI ED, Plaintiff f^J l' ? r? ?? _) `_? - . ?IJ ?] - ?sw ? 'T.1 - ,? .?' -'(?a G .. - -t ?? pi_• -c Jeannie Siegfried, Plaintiff V. Eugene Siegfried, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY NO. 08- `? 7P CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Jeannie Siegfried, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date l Res 2,v,ect lly sub itt d, Michael Lightfoot Certified Legal Intern LD-FOX ANNE =RISNIEYER MEGASupervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 - 71 2aa -! C? tyrI ,i?, ..31 ?77 JEANNIE SIEGFRIED IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-4678 CIVIL ACTION LAW EUGENE SIGFRIED IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, August 08, 2008 , 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 Thursday, September 04, 2008 _ at 10:30 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 permanent 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/ , jacqueline M. Verney, Esq. 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 9-v" 1av? *v 61 .z wd $- my gooz M'd1 N3 ' )t IOW 3HI 3U 301 Lgo-00 Jeannie Siegfried Plaintiff V. Eugene Siegfried Defendant To the Prothonotary: IN TBE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY : NO. 08 - 4678 CIVIL TERM Please withdraw the Custody Complaint filed on August 4, 2008 in the above ca tioned matter. P .? d Date k Michae 4Lighoot Certified Legal Intern NMEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 t_ NO K K Cn- . . SFP Q 4 2008 JEANNIE SIEGFRIED, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008-4678 CIVIL ACTION - LAW EUGENE SIEGFRIED, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 4"' of September, 2008, being advised that the Plaintiff has filed a Praecipe to Withdraw Custody Complaint, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, Iv`? acq ine M. Verney, Esquire, Custod onciliator m .. h? 1-4 f" r .