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HomeMy WebLinkAbout06-1741 MICHAEL MCKENNEY, RHONDA L. MCKENNEY, and: BRENT A. MCKENNEY, Plain tiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NUMBER: 01-. /7'1/ ~~.... MELISSA A. MCCOMMON, Defendant IN CUSTODY COMPLAINT FOR CUSTODY NOW COME the Plaintiffs, MICHAEL MCKENNEY, RHONDA L. MCKENNEY and BRENT A. MCKENNEY, pro se, and respectfully represent as follows: 1. That Plaintiffs are MICHAEL MCKENNEY, RHONDA L. MCKENNEY, and BRENT A. MCKENNEY, adult individuals currently residing at 55 Greenmont Drive, Enola, County of Cumberland, Pennsylvania. 2. That Defendant is MELISSA A. MCCOMMON, an adult individual currently residing at 121 Crestview Village, Middletown, County of Dauphin, Pennsylvania. 3. Plaintiffs, MICHAEL MCKENNEY and RHONDA L. MCKENNEY, seek to have rights of primary physical and legal custody with respect to MACKENZIE BRIANA MCCOMMON, born July 5, 2004, and HALLIE JUNE MCCOMMON, born June 25, 2005. The children were born out of wedlock. The children are presently in the custody of Plaintiffs, MICHAEL MCKENNEY and RHONDA L. MCKENNEY. Since birth the children have resided with the following persons and at the following addresses: From birth until the present with Plaintiffs at 55 Greenmont Drive, Enola, Pennsylvania. The mother of the children is MELISSA A. MCCOMMON, who currently resides at 121 Crestview Village, Middletown, Pennsylvania. She is not married. The father of Mackenzie is BRENT A. MCKENNEY who currently resides at 55 Greenmont Drive, Enola, Pennsylvania. The identity of the natural father of Hallie is unknown. Natural Mother engaged in sexual intercourse with several unknown males at a party, resulting in Hallie's conception. Natural Mother has not proceeded to name anyone as Hallie's father in any legal action for child supprt or custody. 4. The relationship of the Plaintiffs to the children is that of paternal grandparents/custodial parents and natural father. The Plaintiffs currently reside with the children. 5. The relationship of the Defendant to the children is that of mother. She currently resides alone. 6. Plaintiff, RHONDA L. MCKENNEY, filed a Complaint for custody docketed to number 06-1399. Said complaint has been withdrawn simultaneously with the filing of this complaint. The Plaintiffs have no information of a custody proceeding concerning the custody of the children in this or in another court. Plaintiffs do not know of a person not a party to these proceedings who has physical custody of the children or who claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by confirming rights of primary physical and legal custody in Plaintiffs, MICHAEL MCKENNEY and RHONDA L. MCKENNEY, because paternal grandparents/ custodial parents can better care of said minor children. 8. Each parent whose parental rights to the children have not been terminated and the persons who have physical custody of the children have been named as parties to this action. 9. The parties have entered into a Stipulation, attached hereto, setting forth their agreement concerning custody of the minor children. WHEREFORE, Plaintiffs request the Court enter an Order confirming rights of primary physical and legal custody in plaintiffs, MICHAEL MCKENNEY and RHONDA L. MCKENNEY. ICHAEL MCKEN Pro Se , ,?Li ;).. I~l.( /J.L~ /' RHONDAL.MCKENNEY Pro Se A.MCKENNEY COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN We verify that the statements in the foregoing Motion and Complaint are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. J-~3-0~ DATE Ju.i 1- r/-1J,..,,~ RHOND L.MCKENNEY MICHAEL MCKENNEY, RHONDA L. MCKENNEY, and: BRENT A. MCKENNEY, Plain tiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. NUMBER: MELISSA A. MCCOMMON, Defendant IN CUSTODY STIPULATION AGREEMENT, made this _ day of , 2006, by and between MICHAEL MCKENNEY and RHONDA L. MCKENNEY, hereinafter referred to as "Custodial Parents;" BRENT A. MCKENNEY, hereinafter referred to as "Father," and MELISSA A. MCCOMMON, hereinafter referred to as "Mother;" WITNESSETH: WHEREAS, MICHAEL MCKENNEY and RHONDA L. MCKENNEY are the paternal grandparents/custodial parents, BRENT A. MCKENNEY is the natural father / custodial parent, and MELISSA A. MCCOMMON is the natural mother of two minor children, MACKENZIE BRIANA MCCOMMON, born July 5, 2004; and HALLIE JUNE MCCOMMON, born June 25, 2005; and WHEREAS, the identity of the natural father of HALLIE JUNE MCCOMMON is unknown; and WHEREAS, the parties have reached an agreement concerning the issues of custody and desire that this Stipulation be entered as an Order by the Court of Common Pleas of Cumberland County, Pennsylvania; NOW, THEREFORE, intending to be legally bound, the parties hereby agree as follows: 1. Custodial Parents, MICHAEL MCKENNEY and RHONDA L. MCKENNEY, shall have primary physical and legal custody of MACKENZIE BRIANA MCCOMMON, born July 5,2004, and HALLIE JUNE MCCOMMON, born June 25, 2005. Said rights of legal custody shall include the right to obtain health insurance coverage and the right to make all decisions and to authorize medical treatment for the minor children, the right to educate the minor children in the public school district of the Custodial Parent, or at such other educational institution as they may deem fit, and to provide a religious upbringing for the child as the Custodial Parent shall deem appropriate. 2. Mother, MELISSA A. MCCOMMON, shall have liberal rights of temporary physical custody of the minor children as the parties shall from time to time agree. 3. Father, BRENT A. MCKENNEY, shall have liberal rights of temporary physical custody of the minor children as the parties shall from time to timeagree. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. JiLl gft .J MICHAEL MCKENNE~ . /51~<pJ(f}ic~<~ '-WITNESS ~lJ~' U ~~\l ~ WITNESSd *U~~~ WITNESS 0v,-,,---- cA ~1 / .A 4 J't-:u, WITNE~S ~ 1 " " ~ '-" \') ,. ~ ",. "0 \'t \ ~ ~ '\ ~ t " '"" , , "'- ~ :~\ ' ~' ~~, ",~ 'i;. .'~ ~ t f ( "'- .~ "-- .'0 V> '(\. :>;\ l.-; 1 MICHAEL MCKENNEY, RHONDA L. MCKENNEY, and BRENT A. MCKENNEY, Plain tiff RECEIVED MAR 2 7 ZO06 BY: f' / IN THE COURT OF COMMON PLEAS of CUMBERLAND COUNTY, PENNSYLVANIA 117 J CIVIL ACTION - LAW vs. MELISSA A. MCCOMMON, Defendant NUMBER: tJ& f }t./I IN CUSTODY - Cq;) AND NOW, this ORDER ~8'~ day of fA~ , 2006, upon consideration of the within Stipulation, it is hereby Ordered as follows: 1. Custodial Parents, MICHAEL MCKENNEY and RHONDA L. MCKENNEY, shall have primary physical and legal custody of MACKENZIE BRIANA MCCOMMON, born July 5, 2004, and HALLIE JUNE MCCOMMON, born June 25, 2005. Said rights of legal custody shall include the right to obtain health insurance coverage and the right to make all decisions and to authorize medical treatment for the minor children, the right to educate the minor children in the public school district of the Custodial Parent, or at such other educational institution as they may deem fit, and to provide a religious upbringing for the child as the Custodial Parent shall deem appropriate. 2. Mother, MELISSA A. MCCOMMON, shall have liberal rights of temporary physical custody of the minor children as the parties shall from time to time agree. 3. Father, BRENT A. MCKENNEY, shall have liberal rights of temporary physical custody of the minor children as the parties shall from time to time agree. J. L I .r ! r'~1 <) AU\-'l':,~,: -\) e.,_ -.,~ \~\nJ r(- ,'1',' c'~ l.... i' .1.'J", :JHl :-20 ..(B-ii:!