HomeMy WebLinkAbout10-2487KEVIN HART, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. ?d qr
CHRISTINE FINKENBINDER,
Defendant CIVIL ACTION - LAW
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CUSTODY
COMPLAINT FOR CUSTODY
Plaintiff, Kevin :Kart, by and through his attorney Kristopher T. Smull, ksquke,
and the law firm of ROBINSON & GERALDO, respectfully requests the following:
1. Plaintiff is Kevin Hart, an adult individual and the natural Father who
currently resides at 9181 Fort Robinson Road, Ickesburg, Perry County, Pennsylvania
17037.
2. Defendant is Christine Finkenbinder, an adult individual and the natural
Mother who currently resides at 1109 Pheasant Drive North, Carlisle, Cumberland
County, Pennsylvania 17013.
3. Plaintiff seeks partial physical and shared legal custody of Rylee S. Hart,
born on March 14, 2001, currently residing at 1109 Pheasant Drive North, Carlisle,
Cumberland County, Pennsylvania 17013 with Mother. The child was born out of
wedlock.
4. The child is presently in the custody of Mother, who currently resides at
1109 Pheasant Drive North, Carlisle, Cumberland County, Pennsylvania 17013.
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5. During the past five years, the child has resided with the following persons
and at the following addresses.
a. For approximately the past two (2) years with Mother, her husband,
Jeremy Finkenbinder, Paige Little (husband's daughter); Hunter Finkenbinder
(Mother's son); and Leah Finkendbinder (Mother's daughter) at 1109 Pheasant
Drive North, Carlisle, Cumberland County, Pennsylvania 17013.
b. Prior to the above period, with Mother, her husband, Jeremy
Finkenbinder, Paige Little (husband's daughter); and Hunter Finkenbinder
(Mother's son), at an unknown address in Carlisle, Cumberland County,
Pennsylvania 17013.
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.
7. Plaintiff has no information of a custody proceeding concerning the child
pending in a court of this Commonwealth.
8. 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.
9. The best interest and permanent welfare of the child will be served by
awarding shared legal and partial physical custody to Father.
10. 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 a party to this
action.
WHEREFORE, the Plaintiff respectfully requests this Honorable Court to grant
shared legal and partial physical custody of the child to Plaintiff.
Respectfully submitted,
ROBINSO GERALDO
Date: April 9, 2010 By:
Kris pher . Smul , Esquire
Attorney I.D. No. 69140
2505 North Front Street, 2nd Floor
P.O. Box 5320
Harrisburg, Pennsylvania 17110
(717) 232-8525
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.
Section 4904, relating to unworn falsification to authorities.
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Kevin Hart