HomeMy WebLinkAbout09-8907PATRICK J. WOLFKILL, :1N THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V. :CIVIL ACTION - LAW
:CUSTODY
DAPHNE I. WOLFKILL,
Defendant :NO. "6 7 cum
COMPLAINT FOR CUSTODY
AND NOW comes the Plaintiff, Patrick J. Wolfkill, who, by and through his
attorneys, Elizabeth S. Beckley, Esquire, Charles O. Beckley, II, Esquire, and Beckley &
Madden, of Counsel, files this Complaint for Custody, in which he avers that:
1. Plaintiff, Patrick J. Wolfkill, is an adult individual residing at 500
Deanhurst Avenue, Camp Hill, Cumberland County, Pennsylvania 17011.
2. Defendant, Daphne I. Wolfkill, is an adult individual who, upon
information and belief, resides at 142 S 30"' Street, Apartment 6, Camp Hill, Cumberland
County, Pennsylvania 17011.
3. Plaintiff seeks primary physical and joint legal custody of the following
child:
Name
Date of Birth
Residence
Harrison F. Wolfkill 1/16/2003
The child was not born out of wedlock.
Father
The child is presently in the custody of his father, Patrick J. Wolfkill, the Plaintiff
herein, who resides at 500 Deanhurst Avenue, Camp Hill, Pennsylvania 17011.
4. During the past five years, the child has resided at the following addresses
with the individuals indicated:
Persons living with children
Mother and Father
Address
500 Deanhurst Avenue
Camp Hill, PA 17011
Dates
birth -11/13/2009
1
Father
500 Deanhurst Avenue 11/13/2009 - present
Camp Hill, PA 17011
5. Plaintiff is the Father of the child and he currently resides with the child at
500 Deanhurst Avenue, Camp Hill, Pennsylvania 17011. He is married to Defendant.
6. Defendant is the Mother of the child and, upon information and belief,
currently resides with her minor daughter, Abigail Wenger, at 142 S. 30'' Street,
Apartment #6, Camp Hill, Pennsylvania 17011. She is married to the Plaintiff.
7. The relationship of Plaintiff to the child is that of Father. The Plaintiff
currently resides with the following persons:
Name
Harrison F. Wolfkill
Relationship
Son with Defendant
8. The relationship of defendant to the child is that of Mother. The
Defendant currently resides with the following persons:
Name
Abigail Wenger
Relationship
Daughter from a previous marriage
9. Plaintiff has not 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 has no information of a custody proceeding concerning the child
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 child or claims to have custody or visitation rights with respect to
the child.
10. The best interest and permanent welfare of the child will be served by
granting the relief requested because: Plaintiff has been an active and involved parent
since the child's birth and has been the primary caretaker since the parties' separation.
11. Each parent whose parental rights to the child have not been terminated
and the person who has physical custody of the child have been named as parties to this
2
action.
WHEREFORE, Plaintiff requests that the Court grant him primary physical
custody and joint legal custody of the parties' minor child.
DATED:
of Counsel
BECKLEY & MADDEN
212 North Third Street
P.O. Box 11998
Harrisburg, PA 17108
(717) 233-7691
3
Respectfully submitted,
VERIFICATION
I, Patrick J. Wolfkill, hereby verify that the statements made in the foregoing
document 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 18 Pa. C. S.
Section 4904, relating to unsworn falsification to authorities.
DATED:
Patrick J. olfkill
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PATRICK J. WOLFKILL IN THE COURT OF COMMON PLEAS OF
PL..nrNTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
2009-8907 CIVIL ACTION LAW
DAPHNE I. WOLFKILL
IN CUSTODY
DI?F}=,NDANT
ORDF,R OF COURT
AND NOW, Thursd~, January 07, 2010 ,upon consideration o'f the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. ,the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, February 04, 2010 _ at __9:00 AM
_.. _
for a Prc-}learin~~ Custod} Conference. At such con(~orence, an ~ffart ~~ill he made to resolve the is5u~s in dispute; ur
if this cannot be accomplished, to define and narrow the issues to he heard by the court. and to enter into a temporary
order. Failure to appear at the conference may provide Prounds for entry of a temporar~° 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.
FOK THE COURT,
By: /s/ _ Dawn S. Sunda, Es _
- -- -- -
Custody Conciliator
"fhe Court of Common Pleas of Cumberland County is required by la~~~ to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
availahle to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any bearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD "TAKE THIS PAPER TO YOt1R ATTOKNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE OFFICE SET
FORTEi BELOW TO FIND OU"I' WEIERE YOU CAN CiET LECidAL I~iF.LP.
Cumberland County Bar Association
32 South Bedt~'~rd Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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