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HomeMy WebLinkAbout05-6282 DENNIS J. KELLEHER, IV, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2005- t;;!, f..2.. CIVIL TERM JUDITH P. TREFFINGER, Defendant CIVIL ACTION-LAW IN CUSTODY COMPLAINT FOR CUSTODY I. Plaintiff is Dennis J. Kelleher, IV, an adult individual, residing at 132 Partridge Circle, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Judith P. Treffinger, an adult individual, residing at 6 Stewart Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the parents of one minor child: Genna M. Kelleher, born April 25, 1988. The child was born in wedlock. The child is presently in the custody of Plaintiff at 132 Partridge Circle, Carlisle, Pennsylvania. During the past five years, the child has resided with the following persons at the following addresses: Persons Residences Dates Judith and Henry T reffinger 6 Stewart Drive Carlisle, Pennsylvania 17013 October, 2000 to October 20, 2005 Dennis J. Kelleher, IV 132 Partridge Circle Carlisle, Pennsylvania 17013 October 20, 2005 to present The natural father of the child is Dennis J. Kelleher, IV, residing at 132 Partridge Circle, Carlisle, Cumberland County, Pennsylvania. The natural mother of the child is Judith P. Treffinger, residing at 6 Stewart Drive, Carlisle, Cumberland County, Pennsylvania. She is married to Hemy Treffinger. 4. The relationship of the Plaintiff to the child is that of natural father. The Plaintiff currently resides with the following persons: Names Genna M. Kelleher Relationshio Daughter 5. The relationship of the Defendant to the child is that of natural mother. The Defendant currently resides with the following persons: Names Henry Treffinger Relationshio Husband 6. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning the custody of the child in this or in any other Court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 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. 7. 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 parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene. NONE. WHEREFORE, Plaintiff requests your Honorable Court to grant him shared legal and primary physical custody ofthe child. Respectfully submitted, ORRffi~ B~uER David A. Baric, Esquire I.D. 44853 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 dab.dir/domestic/kelleher/complaint. pld VERIFICATION I verify that the statements made in the foregoing Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. TC /2-/2-/0 ,;- DATI':: L __ ~ . ~<L~&?- De~lelier, IV '-J ~ ~~1 1\:' -- "\~ \ .J,! '\ 'l. \ '~1- \ <:: .....-\ C(' i::\ . . DENNIS J. KELLEHER, IV PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 05-6282 CIVIL ACTION LA W JUDITH P. TREFFINGER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, December 14, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor,,~~'!I1J,er:land CO'!!'ty Courthouse, C~!lisle_ on u..,...I~.esday, January 17,2006 at 8:30 AM for a Pre-Hcaring Custody Conference. At sllch conference, an effort will be made to resolve the issues in dispute; or if this cannot bc 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 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 Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: IsI Tacqueline M. Verney, E~ . i \,,' Custody Conciliator ~ The Court of Common Pleas ofCul11berland County is required by law to comply with the Americans with Disabilites Act of 1990. For infonnation about accessible facilities and reasonable accommodations available to disabled individuals having business bel'lre the coul1, 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 con ference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VE 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 32 SOllth Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 .~~-Ir-:~~ 5</5/('1 ~~,~ ~ ~~-f7'5/('!/ ~~ ~~44;P-/'9S-(/'5/C"1 .' .. . "j '," ; "- l.-'-.) ',; ...." . ~ > DENNIS J. KELLEHER, IV, Plaintiff V. JUDITH P. TREFFING R, Defendan J t : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2005-6282 CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this I ~ t'1day of ~ .,2006, upon consideration of the attac ed Custody ConciliatIOn Repo ,It IS ordered and directed as follows: l. The Father Dennis J. Kelleher, IV and the Mother, Judith P. Treffinger shall have shared legal cu tody of Genna M. Kelleher, born April 25, 1988. Each parent shall have an equal right, 0 be exercised jointly with the other parent, to make all major non-emergency decisions ffecting the Child's general well-being including, but not limited to, all decisions re arding her health, education and religion. I. Mother sh I have the following periods of physical custody: A. Beginn ng February 13, 2006, two overnights every week Monday throug Thursday, consecutive or non-consecutive, unless Genna refuses r opposes overnights. B. Such ot er times as the parties and Genna agree. 2. Father shal have physical custody of the child at all other times. 3. This Order' s entered pursuant to an agreement of the parties at a Custody Conciliation Conference. he parties may modify the provisions of this Order by mutual consent. In the absence 0 mutual consent, the terms of this Order shall control. B)'THE COU I / 1. cc: David A. Baric, Esquir , Counsel for Father . . Lindsay D. Baird, Esqu re, Counsel for Mother .~ ~ ;J. N_Of., ~ Gt .n I,,; t .() i;.i \ I r"1j ~pO- ; I r...;':\- l;uUi. ~,Hl '::::1 ,('/'" ,....; ~~\ ........1 ~ .. DENNIS J. KELLEHER, tv, Plaintiff . V. JUDITH P. TREFFINGE Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 2005-6282 CIVIL ACTION - LAW : IN CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDAN E WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, e undersigned Custody Conciliator submits the following report: 1. The pertine t information concerning the Child who is the subject of this litigation is as follows: NAME Genna M. Kelleher DATE OF BIRTH CURRENTL Y IN CUSTODY OF April 25, 1988 Father 2. A Concili ion Conference was held in this matter on February 9, 2006, with the following in atte dance: The Father, Dennis J. Kelleher, IV, with his counsel, David A. Baric, Esquire, d the Mother, Judith P. Treffinger, with her counsel, Lindsay D. Baird, Esquire. 3. The parti s agreed to an Order in the form as attached. ,;( -1-{)~ Date ac eline M. Verney, Esquire Custody Conciliator