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Home My WebLink About02-0879JOSEPH WILLIAM GOCHENAUR, Plaintiff JENNIFER ANN CROUSE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY NO. CUSTODY COMPLAINT 1. The plaintiff is Joseph William Gochenaur, residing at 727 Old Silver Springs Road, Mechanicsburg, Cumberland County, PA 17055. His home telephone number is (717) 691-8975. 2. Defendant is Jennifer Ann Crouse, residing at 9C Baltimore Street, Dillsburg, York County, PA 17019. Her home telephone number is (717) 432-4451. 3. Plaintiff seeks custody of Brock Joseph Gochenaur, age 5, who resides with Defendant in Dillsburg. 4. The child was born out of wedlock. The child is presently in the custody of Defendant. 5. Since birth, the child has resided with the following persons and at the following addresses: Persons Plaintiff and Defendant Defendant Addresses 10 Old York Rd, New Cumberland 10 Old York Rd, New Cumberland Dates 1/97 to 6/97 6/97 to 1/00 Defendant and William Zimmerman Defendant Defendant Mill Rd., Mechanicsburg Locust St., Mechanicsburg 9C Baltimore St., Dillsburg 1/00 to 6/00 6/00 to 9/01 9/01 to present The mother of the child is defendant Jennifer Ann Crouse, currently residing at 9C Baltimore Street, Dillsburg, York County, PA 17019. She is single. 7. The father of the child is plaintiff Joseph William Gochenaur, currently residing at 727 Old Silver Springs Road, Mechanicsburg, Cumberland County, PA 17055. He is single. 8. The relationship of Plaintiff to the child is that of Father. Plaintiff currently resides with the following persons: Name Tara Falk Tyler Hollinger Relationship Girlfriend Son of Girlfriend The relationship of Defendant to the child is that of Mother. Defendant currently resides solely with Brock. 10. 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. 1 1. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state, -2- 1 2. 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. 1 3. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff has the resources to care for Brock. Plaintiff's job is such that Plaintiff can care for Brock. Defendant is unemployed and has no resources to care for Brock. Plaintiff is concerned for the well-being and safety of Brock. Plaintiff has reason to believe that domestic violence is occurring in Defendant's home between Defendant and Defendant's boyfriend. In addition, domestic violence has occurred in the home in the past between Mother and William Zimmerman while Brock was in the home. Further, since Brock's birth, Defendant has denied Plaintiff and Defendant's family the opportunity to see and care for Brock. Plaintiff is open to providing Defendant and her family liberal visitation. 1 4. Each parent whose parental rights to the child have not been terminated and that person who has physical custody of the child have been named as parties to this action. WHEREFORE, pursuant to the Custody Act, 23 Pa. C.S. §5301, et seq., Plaintiff requests the Court grant him custody and such other relief as the Court deems just. Dated: February 19, 2002 McNEES WALLACE & NURICK LLC Pamela L. Purdy I.D. No. 85783 100 Pine Street P.O. Box1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorney for Plaintiff -4- VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4901 relating to unsworn falsification to authorities. 7~-/~--- Date JoSeph William Gochenaur (717) 691-8975 Phone Number CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Jennifer Ann Crouse 9C Baltimore Street Dillsburg, PA 17019 Pa~n~la L. Purd~ Of Counsel for Defendant Joseph William Gochenaur Dated: February 19, 2002 $OSBPH WILLIAIVl GOCHENAUR PLAINTIFF V. JENNIFER ANN CROUSE DEFENDANT : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 02-879 CIVIL ACTION LAW : : IN CUSTODY AND NOW, Tuesday, February 26, 2002 , 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, Meehanieshurg, PA 17055 on Tuesday, March 19, 2002 at 12:30 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 be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may prov/de grounds for entry ora 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. Sunday. Esa, 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 heating. 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 JOSEPH WILLIAM GOCHENAUR, Plaintiff JENNIFER ANN CROUSE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY NO. 02-879 AFFIDAVIT OF SERVICE To: Prothonotary: Cumberland County Court of Common Pleas I hereby certify that true and correct copies of the Custody Complaint and Order of Court were served on Defendant, Jennifer Ann Crouse by Daniel Ryan by personal hand to hand service on March 12, 2002. The notarized Affidavit of Service, dated March 13, 2002 is attached hereto as Exhibit "A". McNEES, WALLACE & NURICK LLC By Pamela L. Purdy I.D. No. 85783 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 237-5479 Attorney for Plaintiff Dated: Exhibit A AFFIDAVIT State of Pennsylvania ) County of Dauphin ) SS: Before me the subscriber personally appeared Daniel P. Ryan to me known, who being duly sworn according to law, doth depose and say that at 8:20 PM on March 12, 2002, I served a copy of a Custody Complaint filed on February 20, 2002 in the matter of Joseph William Gochenaur v. Jennifer Ann Crouse, Cumberland County Court of Common Pleas Civil Action - Custody No. 02-879 To Jennifer Ann Crouse by serving same to Ms. Crouse in person at her residence, which is located at 9C N. Baltimore St., Franklintown, PA 17323. and further depondent sayeth not. Sworn and subscribed before me this /~ day of ~.~ 2002 Nota~ P'~b~ic / Daniel P. Ryan 5235 N. Front St. Harrisburg, PA 17110 Notarial Se. al Wendy M. Livingston, Notary Public Susquehanna lXvv., Dauvhin Coumy My Commission Expires Oct. 24, 2005