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Home My WebLink About10-1447LEEANA I. GURAK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. lU? -7 61`111 ohn M. err 5020 fW" Road State 108 MecharWsbug, PA 17055 PwoNE: 717.766.4008 FAx: 717.766.4066 Defendant c s T 3 o C up r. , r° COMPLAINT IN CUSTODY -: r 1. Plaintiff is Leena I. Gurak, an adult individual residing at 1225 dir&urg w TODD R. GURAK, CIVIL ACTION - CHILD CUST?PY ,?, Circle, New Cumberland, Pennsylvania 17070. 2. Defendant is Todd R. Gurak, an adult individual residing at 313 Lewisberry Road, New Cumberland, Pennsylvania 17070. 3. The parties are the natural parents of the following minor child: Sophia Gurak, born September 21, 2006 (hereinafter, "the child"). 4. The child was not born out of wedlock. 5. The child is presently in the custody of Plaintiff, who resides at 1228 Edinburg Circle, New Cumberland, Pennsylvania 17070. 6. During the past five years, the child has resided with the following persons and at the following addresses: Names Addresses Dates Leeana I. Gurak Amanda Norkitis Devon Norkitis Leeana I. Gurak Todd R. Gurak Amanda Norkitis Devon Norkitis 1228 Edinburg Circle 3/1/10 - present New Cumberland, PA 17070 313 Lewisberry Road 10/08 - 3/1/10 New Cumberland, PA 17070 Leeana I. Gurak 313 Lewisberry Road 8/06-10/08 Todd R. Gurak New Cumberland, PA 17070 Amanda Norkitis p? 41'-71o6?` tf llo -1S ,&,e ,rt 9 38,21 y Devon Norkitis Danielle DonBullian 7. The mother of the children is Plaintiff, Leeana I. Gurak, residing with the child at 1228 Edinburg Circle, New Cumberland, Pennsylvania 17070. She is married. 8. The father of the children is Defendant, Todd R. Gurak, who resides at 313 Lewisberry Road, New Cumberland, Pennsylvania 17070. He is married. 9. The relationship of the Plaintiff to the child is that of Mother. The Plaintiff currently resides with the following persons: Name Relationship Amanda Norkitis Daughter Devon Norkitis Daughter 10. The relationship of the Defendant to the child is that of father. The Defendant currently resides with the following persons: Name Relationship No one other than himself 11. 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. 12. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 13. 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 90!=. err the child. V 5020 Ritter Road 14. Each parent whose parental rights to the child have not been terminated and Suite 109 MechaNCSbtug, PA 17055 Ftiom: 717.766.4008 FAx: 717 766 4066 the person who has physical custody of the child have been named as parties to this . . action. 15. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) the Plaintiff Mother has lived continuously with her child for the last 3 1/2 years; b) the child is being adequately cared for under the present arrangement; c) the emotional, physical and/or spiritual development of the child will be enhanced by granting shared physical custody of the child to Plaintiff. WHEREFORE, Plaintiff requests that the Court grant to her shared physical and shared legal custody of the child, Sophia Gurak. Respectfully submitted, Ye. gv John M. Kerr, Esquire Attorney I. D. # 26414 Law Office of John M. Kerr, Esquire 5020 Ritter Road, Suite 109 Mechanicsburg, Pennsylvania 17055 (717) 766-4008 Attorney for Plaintiff, Leeana I. Gurak Dated: March 1. 2010 9 law Office of 0; n M.err 5020 Mer Road state 108 Mechanksburg, PA 17o5s Ptlo»: 717.766.4008 FAx: 717.766.4066 VERIFICATION The undersigned states that she is the Plaintiff in the foregoing custody action and, as such, is authorized to execute this Verification, and that any factual statements in the preceding Complaint are true and correct to the best of her knowledge, information and belief. She understands that any false statements are subject to the penalties prescribed at 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. 0 'd""k Leeana I. Gurak LEEANA I. GURAK IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. TODD P, GURAK DEFENDANT 2010-1447 CIVIL ACTION LAW IN CUSTODY ORDF,I2 OF COURT AND NOW, Monday, March 08, 2010 _, ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Snnday, Esq. ,the conciliator, at 39_West Main Street, Mechanicsbur , PA 17055 on Wednesday, April_07, 2010 at 10:30 AM for aPre-Hearing Custody Conference. At such conference, an effort will be made to riaolve 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 ali 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/ Dawn S. Sunda Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by Taw to comply with the Americans with Disabilites Act of 1)90. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our ofCce. All arrangements must he made at least 7? hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOL;I..D TAKE TH1S PAPER. TO YOUR A'T'TORNEY AT ONCE:. 1F YOU DO NO"T HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO UR TELEPHONE'. THE OF>~1CE SET FORT}i BELOW TO FIND OUT WHERE YOU CAN GET LEGAL I-[ELP. Cumberland County Bar Association 32 South Bedl~~rd Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ,r FfLEL~-~iFi~iC~ ~.~r TF:r~ ~~;~~~n~rJ~ARY 1~-OMAR-~ ~~~~~ 45 CUMr.: ~'t~~ ~ ~ 9 ~ /o ~~- C~ ,~~,,.,~, ~- ~;~ ~~