Loading...
HomeMy WebLinkAbout10-2070 OF THEE R-ED-011TICE n F? AP THOMAS D. GOULD, ESQUIRE 2 EAST MAIN STRET 1_ ?? SHIREMANSTOWN, PA 17011 Z L0IQ M(??iR 24 P (717) 731-1461 CHRISTOPHER M. HALECKY, IN THE FPCOVAT/JPF COI?lON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO . /D o?0 719 CIVIL TERM TAMMY L. HALECKY, CIVIL ACTION - LAW Defendant CUSTODY ACTION ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Esquire, the Conciliator, at on 2010, at _.M., 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. For the Court, The court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disability 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 LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 179.0& Pot- 32 S. BEDFORD STREET JJ CARLISLE, PA 17013 (717) 240-3166 ,?* a39 v5' CHRISTOPHER M. HALECKY, IN THE COURT OF COMMON PLEAS Plaintiff 'CUMBERLAND COUNTY, PENNSYLVANIA V. NO. J® -:10 '76 CIVIL TERM TAMMY L. HALECKY, CIVIL ACTION - LAW Defendant CUSTODY ACTION CUSTODY COMPLAINT TO THE HONORABLE JUDGES OF SAID COURT: 1. The Plaintiff is Christopher M. Halecky residing at 202 South Stoner Avenue, Shiremanstown, Cumberland County, Pennsylvania 17011. 2. The Defendant is Tammy L. Halecky who is currently .residing at 107 Ellesmere Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff seeks joint legal custody and primary physical custody of the following children: NAME PRESENT RESIDE NCE DOB Joseph Halecky 107 Ellesmere Lane 11/13/1998 Mechanicsburg, PA Maria Halecky 107 Ellesmere Lane 10/02/2000 Mechanicsburg, PA Theresa Halecky 107 Ellesmere Lane 09/15/2002 Mechanicsburg, PA Jonathan Halecky 107 Ellesmere Lane 09/30/2005 Mechanicsburg, PA The children were born in wedlock. The children are presently in the physical custody of Tammy L. Halecky who is currently staying at 107 Ellesmere Lane, Mechanicsburg, Pennsylvania. The children have resided with the following persons and at the following addresses: Person Address Date Mother 107 Ellesmere Lane 03/18/2010 Mechanicsburg, PA Present Mother & Father 202 S. Stoner Avenue 7 years Camp Hill, PA The mother of the children is Tammy L. Halecky who is currently living at 107 Ellesmere Lane, Mechanicsburg, Pennsylvania. She is married. The father of the children is Christopher M. Halecky who resides at 202 S. Stoner Avenue, Shiremanstown, Pennsylvania 17011. He is married. 4. The relationship of Plaintiff to the children is that of Father. The Plaintiff currently resides with the following persons: None 5. The relationship of Defendant to the children is that of mother. The Defendant currently resides with the following persons: Nance Thomas Sangrey Aimee Sangrey Joseph Halecky Maria Halecky Theresa Halecky Jonathan Halecky Marilyn Ingalls Relationshi» Father Mother Son Daughter Daughter Son Grandmother 2 6. Except fox, a PFA filed by Defendant on March 19, 2010, neither party has participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 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. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: A. Plaintiff has been the primary caretaker of the children for many years. B. Plaintiff can provide a stable and loving home. C. Plaintiff has been a significant part of his children's life. D. Defendant, due to her Multiple Sclerosis and other significant health issues, is unable to independently care for the children. E. Plaintiff will encourage regular and meaningful contact between Defendant and the children. 8. Each parent whose parental rights to the children has not been terminated and the person who has physical custody of the children have been named as parties to this action. 3 WHEREFORE, Plaintiff requests this Honorable Court to grant him joint legal custody and primary physical custody of the children, subject to Defendant's periods of visitation at times determined to be in the children's best interest. Respectfully submitted, Thomas D. Gould, Esquire ID #36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 VERIFICATION I, Christopher M. Halecky, hereby certify that the foregoing CUSTODY COMPLAINT is 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 unsworn falsification to authorities. DATED: -:MaLi I to 2.&a 0) NAaW Christopher M. alecky Plaintiff 4 CHRISTOPHER M. HALECKY, Plaintiff vs. TAMMY L. HALECKY, Defendant PRAECIPE FOR ENTRY OF APPEARANCE To The Prothonotary, n c - N E2 az? W O C. :1 `i. 17 7 - Kindly enter the appearance of Debra R. Mehaffie, Esquire, and the law firm of Scaringi & Scaringi, P.C. on behalf of the Defendant Tammy L. Halecky, in the above-captioned custody action. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 10-2070 CIVIL LAW IN CUSTODY Respectfully Submitted, r? Date: S,CARINGI & SCARINGI, P.C. J w WbTa R.1dlehaf ie, 1?,squi e Pa. I.D. No. 90951 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 (717) 657-7770 office (717) 657-7797 facsimile debra!@scaringilaw.com CHRISTOPHER M. HALECKY, Plaintiffs vs. TAMMY L. HALECKY, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PF,NI~ISYLVANIA N0.2010-2070 CIVIL ACTION - L.AW IN CUSTODY ORDER r AND NOW, this ~ day of May, 2012, the above case being previously assigned to the Conciliator and there being no activity on this case for a period of six months or more, the Conciliator relinquishes jurisdiction. 1 ~ ~ ~ ~ ,~ ,~ ~ ~~' L ~k~ ; Hubert X:. Gilroy, esquire Custody Conciliator