HomeMy WebLinkAbout10-1675
JANE ADAMS
ATTORNEY AT LAW
Attorney I.D. No. 79465
17 W. South St.
Carlisle, Pa. 17013
(717) 245-8508
esgadams@gmail.com
DENNIS J. JOHNSON,
Plaintiff
vs.
KRISTY SHELLY,
FILED--OFFICE
OF THE PRo.r anlbTgRy
2010 MAR 10 Aft 9: 13
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. Civil Term
IN CUSTODY
Defendant
CUSTODY COMPLAINT
1. Plaintiff is Dennis J. Johnson, who currently resides at 518 S. West St.,
Carlisle, Cumberland County, Pennsylvania, 17013.
2. Defendant is Kristy Shelly, who currently lives at 503 N. Lincoln Street
Palmyra, Dauphin County, Pa. 17078.
3. Plaintiff is the Father of the following child and seeks a custody order
regarding the following child:
NAME
DOB/AGE ADDRESS
Cierra Renae Johnson 12/9/04 518 S. West St., Carlisle, Pa. 17013
Mother and Father were never married. Father currently has primary physical
custody of the child.
During the past five years, the child has resided with the following persons and at
the following addresses:
NAME
Dennis J. Johnson
Nicole Linn (girlfriend)
Daymion Scott, 5
ADDRESSES
518 S. West St.
Carlisle, Pa. 17013
DATES
5/14/09 - present
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Kristy Shelly unknown address March '09 - May '09
Dan (boyfriend) Hershey, Pa.
Kristy Shelly Country Manor Estates 2005 - March '09
Tobin (boyfriend) Carlisle, Pa.
The mother of the child is Kristy Shelly. She currently resides in Palmyra, with
her boyfriend and his parents. She is married.
The father of the child is Dennis J. Johnson. He currently resides at 518 S. West
St., Carlisle, Pa. 17013. He is not married.
4. The relationship of plaintiff to the child is that of Father. The plaintiff currently
resides with his girlfriend and her son.
5. The relationship of defendant to the child is that of Mother. The defendant
currently lives with her boyfriend and parents.
6. 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.
7. The best interest and permanent welfare of the child will be served by granting
the relief requested because: In May 2009, Father assumed primary custody of the child.
There is no prior custody Order. The child is doing well in his care and is receiving
services in the home. Father is requesting a court Order which confirms that he will retain
primary _physical custody, and provides for shared legal custody and periods of partial
physical custody for Mother.
8. Each parent whose parental rights to the child have not been terminated and
the person who has physical custody of the child has been named as parties to this
action.
WHEREFORE, Plaintiff requests the court to enter a custody order regarding the
child.
Date: 3Islro
Respectfully submitted,
Iar e A dams, Esquire
No. 79465
W. South St.
lisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
VERIFICATION
I verify that the statements made in this 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.
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Date: alawl to Dennis J. Jo s , Plaintiff
I
DENNIS J. JOHNSON IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYI..,VANIA
V.
2010-1675 CIVIL ACTION LAW
KRISTY SHELLY
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Tuesday, March 16, 2010 upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, April 22, 2010 at 8:30 AM
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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: /s/ John b Mangan, fr., Esq? -
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 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-')166
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