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HomeMy WebLinkAbout08-6500JAMES KAUFFMAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 0Q - G?Uv ?.c,n.Q JENNA KAUFFMAN, CIVIL ACTION - LAW Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is James Kauffman, who currently resides at 1335 Lutztown Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is Jenna Kauffman, who currently resides at 12 Hickory Court, Boiling Springs, Cumberland County, Pennsylvania. 3. The Plaintiff seeks custody of the following children: Name: Tyler Kauffman Date of Birth: September 27, 1996 Address: 12 Hickory Court, Boiling Springs, Cumberland County, Pennsylvania Name: Kendall Kauffman Date of Birth: October 21, 1999 Address: 12 Hickory Court, Boiling Springs, Cumberland County, Pennsylvania 4. The children were born during wedlock. 5. The children are presently in the custody of Jenna Kauffman, who resides at 12 Hickory Court, Boiling Springs, Cumberland County, Pennsylvania. 6. During the children's lifetime, they have resided with the following persons and at the following addresses: Name Address Date James and Jenna Kauffman 508 Hillcrest Drive, Birth - September 2001 Carlisle, PA James and Jenna Kauffman 12 Hickory Court, September 2001 - October 16, Boiling Springs, PA 2008 7. The mother of the children is Jenna Kauffman, who resides at 12 Hickory Court, Boiling Springs, Cumberland County, Pennsylvania. 8. Mother of the children, Jenna Kauffman, is married, but separated. 9. The father of the children is James Kauffman, who currently resides at 1336 Lutztown Road, Mechanicsburg, Cumberland County, Pennsylvania. 10. Father of the children, James Kauffman, is married, but separatetd. 11. The relationship of Plaintiff to the children is that of Father. 12. The relationship of Defendant to the children is that of Mother. 13. The Plaintiff currently resides with the following persons: Plaintiff lives alone 14. The Defendant currently resides with the following persons: Tonya Poole, friend 15. The 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 any other court. 16. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 17. The Plaintiff does not know of a person or 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. 18. The best interest and permanent welfare of the children will be served by granting the relief requested for reasons including the following: a. The Father has been a primary caregiver of the minor children since their birth. Father has: 1• Planned and prepared meals; ii. Bathed, groomed and dressed the children; iii. Purchased, cleaned and cared for the children's clothing; iv. Arranged medical care, including trips to physicians; V. Arranged alternative daycare; vi. Put the children to bed nightly, attended the child in the middle of the night, and awakened the children in the morning. b. The children have a psychological bond with Father. C. Father is able to provide a stable environment for the children. d. Father is self-employed with a very flexible work schedule. e. Mother's employment requires her to work late at least one night per week. Father is available to exercise custody at that time. 19. Each parent whose parental rights to the children have not been terminated has been named as parties to this action. WHEREFORE, the Plaintiff requests that this Court grant primary physical custody of the children to the Defendant with partial physical custody granted to the Plaintiff on alternating weekends, one night per week and such other times as the parties may from time to time agree. Respectfully submitted, DATE 16 3I De) ABom&KoTUTAKi,S L.L.P. Kara W. Haggerty, Esquire Supreme Court ID No.(8LI 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff VERIFICATION I, JAMES KAUFFMAN, verify that the statements made in this Custody Complaint 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. 4904 relating to unsworn falsification to authorities. A/00 Date JAM S KAUFFMAN CERTIFICATE OF SERVICE AND NOW - i s j C s day of October 2008, I, 2008, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Custody Complaint, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, First- class mail, postage prepaid addressed to the following: Jenna Kauffman 12 Hickory Court Boiling Springs, PA 17007 Respectfully submitted, ABom&KUTOIAKI,S L.L.P. Kara W. HaggertyTEui r Suprem e Court ID 36 South Hanover treet Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff v ? cz, C A) O! 7 co JAMES KAUFFMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JENNA KAUFFMAN DEFENDANT 2008-6500 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Thursday, November 06, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at _ 4th Floor, Cumberland County Courthouse, Carlisle on Monday, December 08, 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. 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/ ohn . Man an r. Es q. 10 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 1 kWR w}; .i? f L : I I I L- AON 8001