HomeMy WebLinkAbout05-4482
AUG-30-2005 rUE 01:40 PM HANDLER HENNING
FAX NO. 7172333029
P. 02
TERRY DUDLEY,
Pia intiff
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
~ NO. Of: - /.j4~ C;u~L~~
v.
SHERRY GUFFEY,
Defendants
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in
the following pages, you must take action within twenty (20) days after this Complaint and
notice are served, by entering a written appearance personally or by attorney and filing in
writing with the Court your defenses or objections to the claims set forth against you. You
are warned that jf you fail to do so the case may proceed without you and a judgment may
be entered against you by the court without further notice for any money claimed in the
complaint or for any other claim or relief requested by the Plaintiff. You may lose money
or property or other rights important to you.
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
2 Liberty Avenue
Carlisle, PA 17013
Telephone 717-249-3166 or 800-990-9108
By
W Scott Henn
1.0.32298
1300 Linglestown Road
Harrisburg, PA 17110
(717) 238-2000
Attorney for Plaintiff
ROSENBERG, LLP
.'
Plaintiff
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. OS - Aj4P~ CL;"IL~~
TERRY DUDLEY,
v.
SHERRY GUFFEY,
Defendants
COMPLAINT
AND NOW, comes the Plaintiff, Terry Dudley and makes the within Complaint
and requests the following:
1. The Plaintiff, Terry Dudley, resides at 5 Dartmouth Court, Cumberland
County, Mechanicsburg, Pennsylvania.
2. The Defendant, Sherry K. Guffey, resides at 4115 Old Gettysburg Road,
Cumberland County, Camp Hill, Pennsylvania
3. Plaintiff seeks custody (temporary) of the following child:
Jonathan Tyler Guffey
4. The child is presently in the custody of the Plaintiff, Terry G. Dudley, who
resides at 5 Dartmouth Court, Mechanicsburg, PA. (See Custody Agreement attached
as Exhibit A).
5. During the past five years, the child has resided with the following persons
and at the following addresses:
(a) Sherry Guffey, Melinda Guffey, 6 Cherry Street, Cordova, AL, dates
resided 1999-2001;
(b) Sherry Guffey, Melinda Guffey, Terry Dudley, 5 Dartmouth Court,
Mechanicsburg, PA, dates resided 11/01 - 03/02;
(c) Robert Miller & Barbara Tolan, 105 Darr Avenue, Carlisle, PA (Foster
Parents). Dates resided, summer 2002 to June 2003.
(d) Robert Miller & Barbara Tolan, 105 Darr Avenue, Carlisle, PA (Foster
Parents), dates resided, 7/2003 - 8/2004.
(e) Sherry Guffey, 4115 Old Gettysburg Road, Camp Hill, PA, dates resided
8/2004 - 8/2005.
6. The mother of the child is Sherry K. Guffey, currently residing at 4115 Old
Gettysburg Road, Camp Hill, PA.
7. She is divorced.
8. The .father of the child is unknown.
9. The relationship of Plaintiff to the child is that of Aunt.
10. The Plaintiff resides alone.
11. The relationship of the Defendant to the child is that of Mother.
12. The Defendant currently resides alone.
13. The best interest and welfare of the child will be served by granting the
relief request because:
(a) Defendant is currently battling a lifelong addiction that is preventing
her from providing a consistent stable environment for said child, Jonathan Tyler
Guffey.
WHEREFORE, Plaintiff requests the court to grant custody of Jonathan Tyler
Guffey to Terry G. Dudley.
Respectfully submitted,
rt .- c9.. q ~;)..oo 5
DATE
HANDLER, HE
W. Scott ennl
I.D. #32298
1300 Linglestown Road
Harrisburg, PA 17110
717-238-2000
Attorney for Plaintiff
Plaintiff
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. OS - 44f?d-. c.-1L>-,tr~
TERRY DUDLEY,
v.
SHERRY GUFFEY,
Defendants
CUSTODY AGREEMENT
11-.
AND NOW, this 30' -day of July, 2005, it is agreed by and between Terry
Dudley, Plaintiff and Sherry Guffey, Defendant, that the Court enter a custody
determination and Order that Terry Dudley have legal/temporary custody of the child,
Jonathan Tyler Guffey.
It is further agreed by and between the parties that:
(a) Visitation will be as agreed upon by both parties;
(b) Plaintiff, Terry Dudley will have full rights to all medical decisions, access
to medical records, school decisions and access to school records;
(c) Defendant, Sherry Guffey will provide Plaintiff with all medical information
(names and telephone numbers), insurance information (copy of insurance card),
Social Security Number and any other pertinent information vital to the care of said
child, Jonathan Guffey, at the time of the physical transfer of custOd~ of chil~)
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TERRY DUDLEY,
Plaintiff
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05 - .L;4P~ C,~.:l '-r ~
v.
SHERRY GUFFEY,
Defendants
ORDER
AND NOW, this 4 day of ~ f * . ' 2005, upon presentation of the
foregoing agreement, it is hereby ordered that Terry Dudley shall have temporary/legal
custody of the child, Jonathan Tyler Guffey.
It is further ordered that:
(a) Visitation will be as agreed upon by both parties;
(b) Plaintiff, Terry Dudley will have full rights to all medical decisions, access
to medical records, school decisions and access to school records;
(c) Defendant, Sherry Guffey will provide Plaintiff will all medical information
(names and telephone numbers), insurance information (copy of insurance card),
Social Security Number and any other pertinent information vital to the care of said
child, Jonathan Guffey at the time of the physical transfer of custody of child.
BY THE COURT:
Date:
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