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HomeMy WebLinkAbout10-1751 uwo?? yohn M.?err 5020 Ritter Road suite 108 MedlBnkSbu[g, PA 17055 Flm ?: 717.766.4008 FAx: 717.766.4066 ERIN KASSAB, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. Q - S1 JEFF GRIGGS, CIVIL ACTION - CHILD CUSTRY w Defendant D r -T7 7 COMPLAINT IN CUSTODY -= C-3 ern 1. Plaintiff is Erin Kassab, an adult individual residing at 715 Allenviewwrive-, Mechanicsburg, Pennsylvania 17055. 2. Defendant is Jeff Griggs, an adult individual residing at 10 Meadow Run Place, Harrisburg, Pennsylvania 17112. 3. The parties are the natural parents of the following minor child: Riley Griggs, born February 16, 2005 (hereinafter, "the child"). 4. The child was born out of wedlock. 5. The child is presently in the custody of Plaintiff, who resides at 715 Allenview Drive, Mechanicsburg, Pennsylvania 17055. 6. During the past five years, the child has resided with the following persons and at the following addresses: Names Addresses Erin Kassab 715 Allenview Drive Scott Smith Mechanicsburg, PA 17055 Erin Kassab 6028 William Drive Carol Kassab Mechanicsburg, PA 17050 Justin Kassab Erin Kassab 1285 Colonial Road Apt. 4 Jeff Griggs Harrisburg, PA 17112 Dates 10/09 - present 2/06 - 10/09 2/05 - 2/06 ,5p 41roo 1P d- A 44'1479 oi?, 8- 7-7k 7. The mother of the child is Plaintiff, Erin Kassab, residing with the child at 715 d ohn A err -.C - Ritter Road suite 108 Medmnicsbur$, PA 17055 PHONE: 717.766.4008 F.: 717.766.4066 Allenview Drive, Mechanicsburg, Pennsylvania 17055. She is not married. 8. The father of the child is Defendant, Jeff Griggs, who resides at 10 Meadow Place Run, Harrisburg, Pennsylvania 17112. He is not married. 9. The relationship of the Plaintiff to the child is that of Mother. The Plaintiff currently resides with the following persons: Name Scott Smith Relationship Paramour 10. The relationship of the Defendant to the child is that of Father. The Defendant currently resides with the following persons: ninr„o Vicky Cooney Relationship Mother 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 the child. 14. 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 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 first five (5) years of the child's life; III b) the child is not being adequately cared for when under the Father's custody. On March 6, 2010, he left the child unattended in his vehicle while meeting with a potential customer for his painting business. The child had to go to the bathroom and urinated in her clothes when the Father did not return for some time. c) The child's Father has repeatedly placed her in his vehicle without using a proper child protective seat while transporting her. On a recent occasion, he had her sitting on the buckle part of the child protective seat. d) the emotional, physical and/or spiritual development of the child will be enhanced by granting primary physical custody of the child to Plaintiff, with Father's visitations limited to conditions of strict supervision. WHEREFORE, Plaintiff requests that the Court grant to her primary physical and shared legal custody of the child, Riley Griggs, and limit Father's periods of visitation to conditions where he can be adequately supervised. Respectfully submitted, N. 9W . e17 90 5020 tatter Road Sutte 108 Medwkslxug, PA 17055 PNom: 717.766.4008 FAx: 717.766.4066 JohrY M. Kerr, Esquire Attorney I. D. # 26414 Law Office of John M. Kerr 5020 Ritter Road Suite 109 Mechanicsburg, Pennsylvania 17055 (717) 766-4008 Attorney for Plaintiff, Erin Kassab Dated: March 11, 2010 VERIFICATION The undersigned, Erin Kassab, hereby 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 contained in the preceding Custody 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. Erin Kassab ERIN KASSAB IN THE COURT OF COMMON PLEAS OF PI...AINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JEFF GRIGGS DEFENDANT 2010-1751 CIVIL ACTION LAW IN CUSTODY 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 Dawn S. Sunday, Esq. the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 _ on Tuesday, April 13, 2010 at 3:00 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 he 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/ Dawn S. Sunda Es q, _ 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) 249-3166 2?; o U 6 ffSl { I 3 ° ? l ? ' I C? ?t'?- . C?,? Mcx?,?ec? tom, ?-ex`Y"