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Home My WebLink About09-8916Lindsay Gingrich Maclay, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 ]maclay(a)dzmm I;law. com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARK F. KISSINGER, Plaintiff No. 6 V. LAURI A. KISSINGER, Defendant CIVIL ACTION - LAW (In Divorce) NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 Lindsay Gingrich Maclay, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 lmaclay_(aldzmm glaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARK F. KISSINGER, : Plaintiff No. y -?? c,u V. CIVIL ACTION - LAW LAURI A. KISSINGER, : Defendant (In Divorce) COMPLAINT FOR CUSTODY 1. Plaintiff is Mark F. Kissinger, who currently resides at 55 South 39`h Street, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is Lauri A. Kissinger, whose last known address was 55 South 39`h Street, Camp Hill, Cumberland County, Pennsylvania. Defendant's current whereabouts are unknown. 3. Plaintiff seeks primary physical custody of the following children: Name Present Residence Agee Austin Tyler 55 S. 39th Street 11 years Camp Hill, PA 17011 The child was not born in wedlock. Plaintiff adopted the child. Caleb Landon 55S.3 91h Street 9 years Camp Hill, PA 17011 The child was born in wedlock. Sydney Joy 55 S. 39th Street 5 years Camp Hill, PA 17011 The child was born in wedlock. The children are presently in the custody of Plaintiff who resides 55 S. 39`h Street, Camp Hill, Cumberland County, Pennsylvania 17011. During the past five years, the children have resided with the following persons and at the following addresses: Name Address Dates Mark, Lauri, Austin, Caleb & Sydney Lester and Deborah Kissinger Mark, Lauri, Austin, Caleb & Sydney 905 Peachtree Drive Mechanicsburg, PA 17050 55 S. 39`h Street Camp Hill, PA 17011 5/2004-2/2005 2/2005-Present The father of the children is Plaintiff, currently residing at 55 S. 39`h Street, Camp Hill, Cumberland County, Pennsylvania 17011. He is married/separated. The mother of the children is Defendant, whose last current address was 55 S. 39`h Street, Camp Hill, Cumberland County, Pennsylvania 17011. Defendant's current whereabouts are unknown. She is married/separated. 4. The relationship of Plaintiff to the children is that of Father. Besides the children, Plaintiff currently resides with the following persons: None. 5. The relationship of Defendant to the children is that of Mother. Defendant currently resides with the following persons: Unknown. 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. 7. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. 8. 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. 9. The best interest and permanent welfare of the children will be served by granting the relief requested because: A. Plaintiff is the natural Father of Caleb and Sydney and is the adopted Father of Austin. B. Plaintiff remains in the marital residence in the school district where the children are enrolled in school. C. Plaintiff has a warm and loving relationship with the children, which has helped foster their development and growth. D. Plaintiff has in the past, and will continue to provide a stable, loving home environment for the children. E. Plaintiff has in the past and will continue to promote the relationship between the children and Defendant. 10. Each parent whose parental rights to the children have not been terminated and the parent who has physical custody of the children have been name as parties to this action. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order granting the parties shared legal custody of the children and granting Plaintiff primary physical custody of the children with periods of partial physical custody to Defendant on a schedule consistent with the best interest of the children. Respectfully submitted, DALEY ZUCKER MEILTON MINER & GINGRICH, LLC Date: 17-1 3 ?q By: JA4JJ,,ukIk9 + L' dsYGin ' tack, Esqui preme Cou 87954 1029 Scenery Drive Harrisburg, Pennsylvania 17109 Attorneys for Plaintiff VERIFICATION I, Mark F. Kissinger, verify that the statements made in this 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. Section 4904, relating to unworn falsification to authorities. Dated: -70.0-7 Mark F. Kissinger, Plaintiff ,??7 THE 2cog DIL-L 3 i t: +I'I4.40 pp A'CC? 40401 0* Ags MARK F. KISSINGER [N THE COURT OF COMMON PLEAS OF PI_A(NTIFF CUMBERLAND COUNTY, PENNSYLVANIA ~~ 2009-8916 CIVIL ACTION LAW LAURI A. KISSINGER [N CUSTODY D[;FE~:NUANT ORI3F,1't OF COURT" AND NOw', Thursda , January 07,_2010 ,upon consideration of the attached Complaint, _..__ Y _ 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 .Wednesday, February 03,,2010 at 12 00 PM for aPre-}-Iearin~~ Custody Gonferenc~. At such conferr:nce, 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 ~roimds for miry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection firom Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunday~Es Custody Conciliator The Court of Comman 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 a~~ailable to disabled individuals having business before the cou~~t, 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 COnfert,IlCe. OI" heal'u1g. YOU SHOULD TAKE T'H1S PAPER TO YOUR AT°fORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTIi BELOW TO FIND OUT WHERE YUU CAN GET LEGAL HELP. Cumberland County Bar Association 3? South Bedford Street Carlisle, Pe~~lnsylvania 17013 Telephone (717) 249-3166 l~ l~~~d,__ ~ ,~: :`~`r~ ~~~t_tJ"~,,JL~`iv~ ~1 v Lindsay Gingriel~ Maclay, Esquire DAI.~Y ZUCKNR MlsILTON MINER ~ GINGRICH, LLC Z~ + ~ J~ ~ ! ~ ~ `~: 1029 Scenery Drive Harrisburg, PA 17109 (~1~} ds~-4~9s CU~~p -~ ~ ~;;;v ~Y Imaciay~a dzmmglaw com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARK F. IffSSINGER, Plaintiff v. LAURI A, I~SSINGER, Defendant . No. 2009-8916 . CIVIL ACTION -LAW (In Custody) ACCEPTANCE OF SERVICE I, Marlin L. Markley, Jr., Esquire, do hereby accept service of the true and correct copy of the Complaint in C~.~stody on behalf of my client, Lauri A. Kissinger, the Defendant in the above-captioned case, and I certify that I am authorized to do so. Respectfully submitted, Date: r J ~ Z ~'~ ~ " Marli'rt/L, Markley, Jr., Esquire Attoniey I.D. No. 84745 3920 Market Street, Suite 303 Camp Hill, PA 17011 ~~ U ~ LUIU.~ MARK F. KISSINGER Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-8916 CIVIL ACTION LAW LAURI A. KISSINGER Defendant 1N CUSTODY sC-,. o ~ ~+ ~~ ~ ~~ ~- ORDER ~ ~` ~~ 3 GJ AND NOW, this 26th day of January, 2010 ,the conciliator, having received a copy of the Stipulation and proposed Order being submitted by counsel for the parties to resolve all outstanding custody issues, hereby relinquishes jurisdiction. The custody conciliation conference scheduled for February 3, 2010 is cancelled. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator