HomeMy WebLinkAbout04-2568KAY CONKLIN,
P)~intffi',
ROBERT McGRAFF,
Defendant.
: 1N THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
No: Oq- o2gt. J
CIVIL ACTION - LAW
: 1N CUSTODY
COMP!,AiNT UNDER THE GRANDPARENTS VISITATION ACT
AND NOW, comes hhe Plaintiff, Kay Conldin, by and through her attorneys,
Mancke, Wagner & Spreha, and files the following Complaint Under the Grandparents
Visitation Act:
1. The Plaintiff, Kay Conklin, is an adult individual residing at R.D. #2, Box 596,
New Bloomfield, Perry County, Pennsylvania.
2. The Defendant, Robert McGraff, is an adult individual residing at 1431
Timberbrook Drive, Mechanicsburg, Cumberland County, Pennsylvania.
3. The Defendant, Robert McGraff, is the natural father of Molly Katlin McGraff,
bom July 29, 1998.
4. The Defendant, Robert McGraff, is the primary custodian of the
aforementioned Molly McGraff; the natural mother is Tabitha McGraff Kinch, having as
an address 4216 North Progress Avenue, Harrisburg, Dauphin County, Pennsylvania.
5. The Plainliffhas been an active participant in the life of the child; the child
having been bom while the natural mother was residing at the home of the Plaintiff, the
child remained at the Plaintiff's home after birth for a period of throe (3) months,
thereafter offand on for a five (5) year period for periods of time as long as one (1) year.
6. Plainfiffbelieves and therefore avers that she has been, and continues to desire
to be an active part of Molly Kaflin McGraff's life.
7. Plaintiffhas sought a schedule, but has been unable to confirm a schedule with
either the primar~ custodian, the Defendant herein, or the natural mother of the child.
8. Plaintiffbeheves and therefore avers that it is in the best interest of the child to
grant the Plaintiff, the maternal grandmother of the child, periods of partial custody, at
least one (1) Saturday evening per month and one (1) Wednesday or Friday evening when
Molly is not in school.
9. Plaintiff believes that the Defendant, Robert McGraff, has been the primapj
custodian of Molly for a period of at least the last five (5) years at the address of 1431
Timberbrook Drive, Mechanicsburg, Cumberland County, Pennsylvania.
10. The best interests of the child, Molly, would be served by granting unto the
Plaintiff herein periods of partial custody as set forth above, pursuant to the provisions of
the Grandparent Visitation Act.
WHEREFORE, Plaintiffrequests this Court to grant the relief as requested.
Respectfully submitted,
Mancke, Wagner & Spreha
B~quire
I.D. #23103
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorneys for Plaintiff
V~RIFICATION
I 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.
KAY CONKLIN
PLAINTIFF
V.
ROBERT MCGRAFF
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
04-2S68 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Friday, June 11, 2004 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear be~bre Dawn S. Sunday, Esq. ~ the conciliator,
at 39 West Main Street, Meehaniesbur§, PA 17055 on Monday, July 12, 2004 at 12:00 PM
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. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry ora 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: Is/ Dawn S. Sunday, Esq. rate
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 tax/rog 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
V!NV^gASNN3cl
O0 :g N~I '11
~OUJO~W
JUL 1 6 2004
KAY CONKLIN
VS.
ROBERT MCGRAFF
Plaintiff
Defendant
IN THE COUI~ OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
04-2568 CIVIL ACTION LAW
IN CUSTODY
ORDER.
AND NOW, this 9xl~ day of Jui¥~ 2004 , the conciliator, being advised by plaintiff's
counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes
jurisdiction. The Custody Conciliation Conference scheduled for July 12, 2004 is cancelled.
FOR THE COURT,
Dawn S. Sunday, esqui
Custody Conciliator