HomeMy WebLinkAbout10-2468f I -L -
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P. Richard Wagner, Esquire
Attorney ID No. 23103
Mancke, Wagner & Spreha
2233 North Front Street
Harrisburg, PA 17110
Telephone (717) 234-7051
Fax (717) 234-7080
Attorney for Plaintiff
KELLI GALLAGHER, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO: 10 - 014(6 Olivi t Term
DAVID LaTORRE,
Defendant : CIVIL ACTION - CUSTODY
COMPLAINT FOR CUSTODY
AND NOW, comes the Plaintiff, Kelli Gallagher, by and through her attorneys,
Mancke, Wagner & Spreha and files the following Complaint For Custody:
1. The Plaintiff, Kelli Gallagher, is an adult individual currently residing at 66
Drexel Place, New Cumberland, Cumberland County, Pennsylvania.
2. The Defendant, David LaTorre, is an adult individual having as an address
2304 N. 2nd Street, Harrisburg, Dauphin County, Pennsylvania.
3. The parties are the natural parents of one children, Gus, born September 10,
1999.
4. The child was born during wedlock.
5. For the last five years, the parties have had a shared legal and shared
physical custody arrangement with their son, Gus.
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6. From approximately 2005 to approximately November 2007, the Defendant,
the natural father above, lived in Locust Lane, Harrisburg, Dauphin County; from
approximately November 2008 to the present, he has resided with his current wife,
Jessica Myers, at the address contained in paragraph 2 above.
7. The natural mother from approximately 2006 through 2007, lived at 498
Hoffman Drive, Harrisburg, Dauphin County, Pennsylvania; from approximately
September 2007 to July 2009 in Wormleysburg, Pennsylvania; and from July 2009 to
the present at the address contained in paragraph 1 above.
At all times relevant hereto the parties have shared physical custody of Gus.
8. Plaintiff is aware of no other party ascertaining a claim or a right to custody or
partial custody of the son, Gus.
9. Plaintiff believes and therefore avers that it is in the best interest of Gus to
continue the shared legal and shared physical custody arrangement of their son, Gus.
WHEREFORE, Plaintiff requests the Court to enter an Order granting her
request to confirm shared physical and shared legal custody of their natural child, Gus
LaTorre.
Ily Submitted,
P tci5"ard Wagner, Esquire
Attorney ID No: 23103
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Date: Attorney for Plaintiff
VERIFICATION
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.A. §4904,
relating to unsworn falsification to authorities.
Date: l-?
KELLI GALLAGHER,
PLAINTIFF
V.
DAVID LaTORRE,
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10-2468 CIVIL
IN RE: CONTINUANCE OF CUSTODY HEARING
ORDER OF COURT
AND NOW, this 10t" day of September, 2010, due to the illness of counsel
for Plaintiff and with concurrence of counsel for Defendant,
IT IS HEREBY ORDERED AND DIRECTED that the hearing will now be
held on Thursday, October 14, 2010, at 9:00 a.m. and Monday, October 18, 2010
at 1:30 p.m. in Courtroom No. 2 of the Cumberland County Courthouse, Carlisle,
Pennsylvania.
By the Court,
ARchard Wagner, Esquire
Attorney for Plaintiff
? Carol Lindsay, Esquire
Attorney for Defendant
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M. L. Ebert, Jr.,
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KELLI GALLAGHER,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF.
CUMBERLAND COUNTY, PENNSYLVANIA
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DAVID LATORRE, ~
Defendant NO. 10-2468 CIVIL TERM ~~'-; ~°
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IN RE : CUSTODY ~'~' r*,~
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AND NOW, this 18th day of October, 2010, t~i~ '~'
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parties having reached an agreement in the above-captioned
matter, the existing custody order in this case is modified
as follows:
1. The mother, Kelli Gallagher, and the father,
David LaTorre, shall have shared legal custody of their son,
Michael Gustavo LaTorre, born September 10th, 1999.
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2. The parties will share physical custody of the
child on the following schedule:
In Week 1 Gus will be with the Mother from
Thursday after school until Saturday morning at 10:00 a.m.
and in Week 2 Gus will be with the Mother from Thursday
after school until Sunday at 4:00 p.m. At all other times
Gus will be with his father. This schedule will commence
the week of October 25th and will be a school year schedule.
In the event that Mr. LaTorre wishes to have a
weekend with his son, he will schedule that weekend on the
Week 1 schedule and Ms. Gallagher will then have Gus early
evening on Sunday into Monday morning.
In addition, in the event that school is off on
Monday after Mother's weekend; that is, after the Week 2
schedule, then Mother may keep the child overnight until
Monday at 4:00 p.m.
3. In the summertime the parties will share
custody of Gus on an equal basis, the precise nature of
which will be recommended by Dr. Kasey Shienvold taking into
account Gus's age. In addition Dr. Shienvold will meet with
Gus and the parents three times a year to monitor any change
in Gus's situation, but the parties have agreed that for at
least a year there will be no change in this present
custodial arrangement.
4. In even-numbered years, Mother will have
custody of Gus on Christmas Eve at 4:00 until Christmas Day
at 3:00 p.m. and father will have custody of Gus on
Christmas Day at 3:00 p.m. until December 26th at 3:00 p.m.
In odd-numbered years, Father will have the first block of
time and Mother will have the second block of time.
5. Father will have custody of Gus after school
on the Wednesday before Thanksgiving to 3:00 p.m. on
Thanksgiving Day, and Mother will have custody of Gus on
Thanksgiving Day at 3:00 p.m. until Friday at 3:00 p.m.
By the Court,
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M. L. Ebert, Jr.,
Richard Wagner, Esquire
For the Plaintiff
~ol J. Linsday, Esquire
For the Defendant
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