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HomeMy WebLinkAbout09-862810 Margaret M. Simok, Esquire SCARINGI & SCARINGI, P.C. 2000 Linglestown Road; Suite 106 Harrisburg, PA 17110 717-657-7770 Margaret&Scaringilaw. com SUZANNE E. FLATHMANN, Plaintiff V. JOHN C. FLATHMANN, Defendant :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA 0 q . 9( .2 8 Cc t 'T,+.- -NO. CV CU :CIVIL ACTION - LAW :CUSTODY ACTION COMPLAINT FOR CUSTODY 1. Plaintiff is Suzanne E. Flathmann, residing at 1200 King's Circle, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Defendant is John C. Flathmann, whose current residence is unknown to Plaintiff. 3. Plaintiff seeks primary custody of Dylan Reid Flathmann (DOB: May 31, 1994) and Alana Christine Flathmann (DOB: October 20, 1995.) The children were not born out of wedlock. The children are currently in the custody of Plaintiff who resides at 1200 King's Circle, Mechanicsburg, Pennsylvania. During the past five years the children have resided with the following persons at the following addresses. Persons Address Dates Suzanne E. Flathmann 1200 King's Circle All of past 5 years John C. Flathmann Mechanicsburg, PA The Mother of the children is Suzanne E. Flathmann, currently residing at 1200 King's Circle, Mechanicsburg, Pennsylvania. She is married.. The Father of the children is John C. Flathmann, whose current residence is unknown to Plaintiff. He is married. 4. The relationship of Plaintiff to the children is that of Mother. Plaintiff currently resides with the two children. 5. The relationship of Defendant to the children is that of Father. It is unknown with whom Defendant currently resides. 6. Plaintiff has not participated as a parry or witness, or in another capacity, in other litigation concerning the custody of the children in this or another Court, except for a Protection from Abuse action which was entered December 3, 2009, to Docket No. 2009-8308 in Cumberland County. 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 the Mother can provide a safe and stable environment for the children. 8. Each parent whose parental rights to the children have not been terminated and the person who is believed to have physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff requests the Court grant Plaintiff primary physical custody of the children with periods of partial physical custody for Defendant. Respectfully Submitted: Dater Margare M. Simok, Esquire SCARINGI & SCARINGI, P.C. 2000 Linglestown Road; Suite 106 Harrisburg, PA 17110 Supreme Court ID No. 89633 717-657-7770 Attorneys for Plaintiff VERIFICATION I verify that the statements made in the Custody 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. b , J?, Date tSuzanIhE. Flathmann, Plaintiff TILED JF i r a' 2059 DEC ! 5 FI-! 2: 2 ! C if !NrlY 4I19.0O PD 'l l C?. to 30(0 a-=z ot0a SUZANNE E. FLATHMANN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-8628 CIVIL ACTION LAW JOHN C. FLATHMANN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW. Monday, December 21, 2009 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, January 21, 2010 at 8:30 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: _ Isl _Jacqueline M. Verne Es Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabiiites 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) 249-3 166 FLED-- 1,)l _ av ?r THE ' I` ?'AMY, 1009 DEC 2D Pf i2. 0 U is • as os y?? .w?.- ? ? ''?/? SUZANNE E. FLATHMANN, Plaintiff V. JOHN C. FLATHMANN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2009-8628 CIVIL ACTION -LAW c-~ • fV IN CUSTODY ._ , . ORDER OF COURT AND NOW, this 23`d day of July, 2010, having no contact with the parties for more than ninety days, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, acq line M. Verney, Esquire, Custod onciliator Pea :-~ ,~_ . r,z c; N 0 ~~ _-, ;'.-~ Emily Long Hoffman, Esquire Sup. Ct. ID. 66307 255 Market St. Millersburg, PA 17061 (717) 979-8849 Attorney for Plaintiff Suzanne E. Flathmann Plaintiff vs. John C. Flathmann Defendant PRAECIPE TO WITHDRAW AS COUNSEL To the Prothonotary: Kindly withdraw my appearance in the above-captioned action. Respectfully submitted; DATE: `7 - 10 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 2009 8628 CIVIL ACTION BY: Margaret ffi. Simok, Esquire Sup. Ct. I.D. 2000 Linglestown Road Harrisburg PA 17110 PRAECIPE TO ENTER APPEARANCE Kindly enter my appearance in the above-captioned action. DATE: - C 84151 Respectfully submitted, l? BY: r-- Emily Long offman, Esquire 255 Market Street Millersburg, PA 17061 Counsel for Plaintiff c_ ('ilfT! 14? (j'y r 61 J? 6,