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HomeMy WebLinkAbout09-0296CHRISTINA KUCEK Plaintiff V. IAN JONES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Cuh-l ??. , NO. 0'? - -7 96 CIVIL LAW - CUSTODY CUSTODY COMPLAINT 1. The Plaintiff is CHRISTINA KUCEK, an adult individual currently residing at 1784 South Meadow Drive, Mechanicsburg, Cumberland County, PA 17055. She is the subject child's natural mother. 2. Defendant, IAN JONES, is an adult individual currently residing at 1149 Loop Drive, Harrisburg, PA 17112. He is the subject child's natural father. 3. Plaintiff seeks shared legal custody and primary physical custody of the parties' daughter, ALAINA SOPHIA JONES (born 10/29/08). 4. The child has resided with the following persons at the following addresses for the following periods of time: NAME ADD mother, maternal see grandparents mother, father see *except was with mother Mechanicsburg residence from RESS paragraph #1 paragraph #2 and maternal 11/12/08 throe DATE 1/1/09 - present 10/29/08 thru 12/31/08* grandmother at the xgh 11/15/08. 5. The relationship of the Plaintiff to the child is that of the natural mother. She is not married. 6. The relationship of the Defendant to the child is that of natural father. He is not married. 7. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in any Court of this Commonwealth. 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. 8. The best interest and welfare of the child will be served by granting shared legal custody and primary physical custody to Plaintiff, with supervised visitation to Father as Father continues to struggle with drug and alcohol issues and is not currently able to care for the child. 9. Each parent whose parental rights to the child has not been terminated and the persons who have physical custody of the child 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 child, with supervised visits to Father. DATE: 1/16/09 CHRISTINA KUCEK 1784 South Meadow Drive Mechanicsburg, PA 17055 (717) 766-6262 VERIFICATION I hereby verify that the statements made in the foregoing document are true and correct. 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: /40? I CHR STINA KUCEK CM t? -Ti _r N .1 77Z) 4 rn co r It CHRISTINA KUCEK IN. THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-296 CIVIL ACTION LAW IAN JONES IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, January 29, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, March 06, 2009 at 9:30 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/ Hubert X. Gilro Es q. 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 ') Z- 03J 6 Z 14 _L MAR t 0 2009 CHRISTINA KUCEK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW IAN JONES, NO. 2009-296 Defendant IN CUSTODY n COURT ORDER ,r AND NOW, this day of March, 2009, the Conciliator appearing for a conference which was scheduled in the above case and neither of the parties being in attendance at that conference, the Conciliator relinquishes jurisdiction. K?. ubert X. Gilroy, Esquire Custody Conciliator N ?' c c?, -.:? _ --', r ' =? ? = c?? ? Q ??