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HomeMy WebLinkAbout10-2570 2010 APR 20 AM 10: 39 Melanie L. Erb Attorney for Plaintiff 2132 Market Street Camp Hill, PA 17011 merb e dcdlaw.net 717-975-9446 DARREN L. DEHOFF, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. . NO.: 10- x5'10 Div i CTe m REBECCA A. DEHOFF, Defendant : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, Darren L. Dehoff, by and through his attorney, Melanie L. Erb, Esquire and Dethlefs-Pykosh Law Group, LLC, who brings this Complaint for Custody and avers as follows: 1. Plaintiff is Darren L. Dehoff, an adult individual currently residing at, 1072 East Canal Road, Dover, York County, Pennsylvania, 17315. 2. Defendant is Rebecca A. Dehoff, an adult individual who is believed to be currently residing at 615 Herman Ave., Lemoyne, Cumberland County, Pennsylvania. ?17Q.DO PQATrq cry 871(0 ? a4a?s3 . 3 (a). Plaintiff seeks shared legal and primary physical custody of the minor children Katelynn Dehoff, born April 29, 2000, Stephanie Dehoff, born October 3, 2004, Chloe Dehoff, born November 6, 2005 and Mark Dehoff, born April 23, 2007. 3(b). The children were not born out of wedlock. The children are presently in the custody of Defendant, Rebecca A. Dehoff, III who resides at 615 Herman Ave., Lemoyne, Cumberland County, Pennsylvania. Her relationship to the minor children is that of Mother. For the past five years, the children have resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Unknown since June 2008 Rebecca Dehoff 480 Mt. Airy Rd. #13 Darren Dehoff Lewisberry, PA 17339 3(c). The mother of the children is Rebecca A. Dehoff, currently residing at 615 Herman Ave., Lemoyne, Cumberland County, Pennsylvania. She is currently married to, but separated from the Plaintiff. The father of the children is Darren L. Dehoff, currently residing at 1072 East Canal Road, Dover, York County, Pennsylvania. He is currently married to, but separated from Defendant. 4. The relationship of Plaintiff to the children is that of Father. The Plaintiff currently resides with the following persons: Name Relationship Gene and Charlotte Smith Parents 5. The relationship of Defendant to the children is that of Mother. The Defendant currently resides with the following persons: Name Relationship Brenda Swanger Mother 6(a). Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 6(b). Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because the bond between Plaintiff/Father should be restored and maintained. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children has been named as a party to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene: NONE. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an Order scheduling a custody conciliation conference Respectfully Submitted, la . Er , squire PA I . No. 84445 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 (717) 975-9446 Attorney for Plaintiff VERIFICATION I, DARREN L. DEHOFF, verify that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. DARREN L. DEHOFF DATE O DARREN L. DEHOFF IN THE COURT OF COMMON PLEAS OF r~L,AmTrFF CUMBERLAND COUNTY, PENNSYLVANIA. V. • 2010-2570 CIVIL ACTION LAW REr3ECCA A. DEHOFF DriFfiNDANT IN CUSTODY ORllER OF COURT AND NOW, Wednesday, June 30, 2010___ ,upon consideration of the attached C=omplaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator, at 4th Fioor, Cumberland County Courthouse, Carlisle on Thursday, August O5, 2010 at 9:30 AM for a Prc-f-fearing 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 Custod~~ orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy, Esq.~pl _ Custody Conciliator 'The ('-Dort of Common. Pleas of Cumberland County is required by law to comply with the Americans ~o ith Uisabilites Act of 1990. For information about accessible facilities and reasonable accommodations a~ ailahlc 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 OF~CE ~T ~ FOR"I~Fi BF,LOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. C ~, ~ Cumberland County Bar Association ~_~, ~ !~• 3~ • t 0 Cup . co ~ Mok t es~ ~"~~. 32 South Bedford Street ~ ' . ca ~ c~ ~d ~ ~b• c~ ?c'a Carlisle, Pennsylvania 17013 ~ ~'. ~- ~~. ~,,, F ~• ~ • `~ ~~ C~2.. ~,~ `~ ,~~ Telephone (7 17) 249-3 166 D ~'> :~:. ' Sri i NOV 10 2010 DARREN L. DEHOFF, IN THE COURT OF COMMON PLEAS OF C) Plaintiff CUMBERLAND COUNTY, PENNSYIIRAI%A ?-n , rn6i a rn--- , vs. CIVIL ACTION -LAW z: -? ?,Y-, r ? REBECCA A. DEHOFF, : ?D cn --4 C) N0.2010-2570 <o -0 o? Defendant IN CUSTODY P n :9 n CDrn i. un COURT ORDER NOW, this I J? day of November, 2010, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The father, Darren L. Dehoff, and the mother, Rebecca A. Dehoff, shall enjoy shared legal custody of Katelynn Dehoff, born April 29, 2000, Stephanie Dehoff, born October 3, 2004, Chloe Dehoff, born November 6, 2005, and Mark Dehoff, born April 23, 2007. 2. The mother shall enjoy primary physical custody of the minor children. 3. The parties shall employ Interworks in Harrisburg for purposes of handling this case with the cost to be paid for by the father. Interworks shall facilitate father having supervised visitation with the minor children pursuant to a schedule arranged by Interworks. 4. All counselors or evaluators or other professionals for the mentioned minor children are hereby authorized to share with Interworks any information they have obtained concerning the minor children as that may be relevant to these custody proceedings. 5. Another custody conciliation conference is scheduled for Tuesday, February 3, 2010, at 9:30 a.m. BY THE COURT, 'v? ?a V Judge cc: ?Christopher Walker, Certified Legal Intern (Dickinson School of Law Penn State Uversity Family law Clinic Melanie Erb, Esquire tss mu-'u .7 DARREN L. DEHOFF, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW REBECCA A. DEHOFF, NO. 2010-2570 Defendant IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The Custody Conciliator conducted a telephone conference with the attorneys for the parties on November 5, 2010, and, based upon that telephone conference, recommends an order in the form as attached. Date: November r , 2010 Hubert X. Gilroy, Custody Concilia a DARREN L. DEHOFF, Plaintiff VS. REBECCA A. DEHOFF, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW - = --& M n=? NO. 2010-2570 IN CUSTODY co F Ec-) COURT ORDER day of February, 2011, upon consideration of the attached AND NOW, this Custody Conciliation Report, this Court's prior Order of November 15, 2010, shall continue in place subject to the following: 1. Legal counsel for the parties shall continue to work with Mr. Bowman at Interworks of Harrisburg with respect to arranging supervised visitation which shall be at least once a week for a minimum of three hours. It is understood that these sessions shall be attempted to be scheduled on Saturday. However, if Interworks is not available on Saturday, a session may be scheduled during the week and both parties are directed to accommodate the scheduling of those sessions. 2. The parties shall meet again for a custody conciliation on Thursday, March 17, 2011, at 9:30 a.m. At this conference and in the event the visitations outlined above have gone well, the issue of eliminating supervision restrictions for visitation and the issue of expanding the visitation time shall be addressed. 3. Legal counsel shall work with Mr. Bowman and obtain a current report in writing to submit to the Conciliator at the conciliation conference scheduled above, in which report Mr. Bowman may suggest his findings relative to the visitations that have taken place and his recommendation, if any, he has relative to whether supervised visitation should be continued and, if not, what type of visitation he may recommend. 4. Counsel for the Mother shall provide counsel for the Father with information concerning the options with respect to Father attending parenting classes, which options shall address the financial considerations involved in those classes. That matter may be addressed at the conciliation conference scheduled above subject to Father's agreement and financial ability. BY THE COURT, ?o, ?-a M. L. Ebert, Jr., Judge cc: jMelanie Erb, Esquire Mp??? Sarah Stoner, Certified Legal Intern oPi? 41141( KA DARREN L. DEHOFF, Plaintiff VS. REBECCA A. DEHOFF, Defendant Prior Judge: The Honorable M. L. Ebert, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2010-2570 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The Conciliator conducted a second conciliation conference on February 3, 2011. Present were the Father with his counsel and Mother's counsel was there with Mother being available via telephone. 2. The Conciliator and the Attorneys spoke with Mr. Thomas Bowman who works with Interworks of Harrisburg and has been facilitating some supervised visitation with the Father over the past few months. Based upon these discussions with Mr. Bowman and the discussions the Conciliator had with legal counsel, the Conciliator recommends an Order in the form as attached. Date: February 2011 Flubert X. Gilr , Esquire Custody Co iliator r DARREN L. DEHOFF, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW REBECCA A. DEHOFF, NO. 2010-2570 - - Defendant IN CUSTODY Prior Judge: The Honorable M. L. Ebert, Jr. cw -z? COURT ORDER? AND NOW, this day of March, 2011, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that the prior Orders of Court are vacated and replaced with the following Order: The father, Darren L. Dehoff, and the mother, Rebecca A. Dehiff, shall enjoy shared legal custody of Katelynn Dehoff, born April 29, 2000, Stephanie Dehoff, born October 3, 2004, Chloe Dehoff, born November 6, 2005 and Mark Dehoff, born April 23, 2007. 2. The mother shall enjoy primary physical custody of the minor children. 3. The father shall enjoy periods of temporary physical custody of the minor as follows: A. On every Friday from 5:00 p.m. until 8:00 p.m. and on every Saturday from 1:00 p.m. until 6:00 p.m. Exchange of custody shall take place at the McDonald's at the Cedar Cliff Mall unless the parties agree upon another location. Both parties may bring individuals with them to the exchange of custody for purposes of monitoring the exchange to insure there are no problems between the parties. 2- 4. The parties shall continue to discuss with each other providing father with times of custody on major holidays. In the event the parties are unable to reach an agreement on a holiday schedule, legal counsel for the parties may contact the Custody Conciliator directly to schedule a telephone conference at which time the Conciliator may, as appropriate, file a modified Order with the Court to address the holiday schedule. BY THE COURT, \?o? M. L. Ebert, Jr., Judge cc: ?Melanie Erb, Esquire , IeJ Sarah Stoner, Certified Legal Intern CO., Ma 31.,U /I I 0Kb DARREN L. DEHOFF, Plaintiff VS. REBECCA A. DEHOFF, Defendant Prior Judge: The Honorable M. L. Ebert, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO. 2010-2570 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. A Conciliation Conference was held on March 17, 2011. This is approximately the third or fourth time the Conciliator has been involved in the case over the past six months or so. The parties agree to the entry of an Order in the form as attached. Date: March 16 '2011 4 a:, Hubert X ilroy, Esquire Custod Conciliator