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HomeMy WebLinkAbout06-1936 TODD M. HOCKLEY, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 6~-192b CIVIL TERM STEPHANIE FRANKENFIELD, : CIVIL TERM - CUSTODY Defendant CUSTODY COMPLAINT I. Plaintiff is Todd M. Hockley, currently resides at 28 E. Pomfret St., Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Stephanie Frankenfield, whose last known address is 6115 Abbotts Bridge Road, Apt 1007, Duluth, Georgia, 30097-5751. 3. Plaintiff is the mother of the following child and seeks custody of the following child: NAME DOB/AGE ADDRESS Todd Hockley 4/14/96 (9) 28 E. Pomfret St. Carlisle, Pa. 17013. Mother and Father never married. Father currently has primary physical custody of the child. During the past five years, the child has resided with the following persons and at the following addresses: NAME ADDRESSES DATES Todd Hockley Kendall Darr Makhyla Hockley (2) Makenzie Hockley (9 mo) 28 E. Pomfret St. Carlisle, Pa. 17013 August 2004 - present. Stephanie Frankenfield Unknown Address 2001 - August 2004. The mother of the child is Stephanie Frankenfield. She is not married. The father of the child is Todd M. Hockley, and he currently resides at 28 E. Pomfret St., Carlisle, Pa. 17013. He is not married. 4. The relationship of Plaintiff to the children is that of Father. The persons that the Plaintiff currently resides with are: his girlfriend, Kendall Darr, and their two children, Makhyla Hockley (2) and Makenzie Hockley (8 months). 5. The relationship of Defendant to the child is that of Mother. The persons that the Defendant currently resides with are unknown. 6. Phintiff 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 other than as follows: There is currentlv a custody order in Dauphin County, Pennsylyania. a COPy of which is attached as Exhibit A. Plaintiff's counsel is in the process of filing for a transfer ofiurisdiction since no parties currently reside in Dauphin County. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a party to the proceedings who has physical custody of the child or anyone who claims to haye custody or yisitation rights with respect to the child. 7. The best interest and permanent welfare ofthe child will be served by granting the relief requested because: In August 2004. the parties agreed that the child could reside with Father. which was a substantial modification from the prior custody order in Dauphin County. Father is seeking an updated Order which reflects the arrangement that has been in place for approximately a year and a half. Father believes it would be in the best interest of the child to confirm this arrangement in a court order as this will provide stability to the child's life. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff requests the court to grant custody of the child. Respectfully submitted, _^O'__" Date: 4/5/\0 J e Adams, Esquire .D. No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF STEPHANIE FRANKENFIELD, Plaintiff, IN THE COURT qF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA v. No. 5061 CV 2002 CU TODD HOCKLEY, CIVIL ACTION - CUSTODY "" (;:;:;:;> , ',.J Defendant. ORDER OF COURT AND NOW, this 1- day o~ 20~ a Custody Conciliation g Conference having been convened and the parties having reached an agreement regarding the best interests of the subject minor Todd Hockley Jr., born April 14, 1994, IT IS HEREBY ORDERED AND DECREED as follows: I. The parties will share joint legal custody of the subject minor child. The parties agree that major decisions concerning their child, including, but not necessarily limited to, the child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party. Each party shall notify the other of any activity or circumstance concerning their child that could reasonably be expected to be of concern to the parent then having physical custody. With regard to any emergency decisions, which must be made, the parent having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, 1 teacher, professional or authority and to have copies of any reports givep to either party as a parent. 2. Plaintiff shall have primary physical custody ofthe subject minor child. 3. Defendant shall be entitled to periods of partial custody, pursuant to the following schedule: a) Defendant shall have partial custody on alternating weekends from Friday at 5:00 PM until Sunday at 5:00 PM. 4. The parties shal1 alternate the fol1owing holidays from 10:00 AM until 8:00 PM beginning with Plaintiff on Easter 2003: . Easter; . Memorial Day; . Independence Day; . Labor Day; . Thanksgiving; . Christmas Eve at noon until Christmas Day at noon; and . Christmas Day at noon until December 26 at noon. 5. Plaintiff shal1 have custody of the minor child on Mother's Day from 10:00 AM to 8:00 PM and Defendant shall have custody of the minor child on Father's Day from 10:00 AM to 8:00 PM. 2 6. Defendant shall be entitled to fourteen (14) days ofunint.errupted custody of the minor child subject to thirty (30) days notice to the other party. 7. In the event there is a conflict between the weekend and holiday schedule, the holiday schedule shall take precedence and be the binding schedule. 8. The parties will share in the responsibility of transporting the child for custody changes by picking up the child at the commencement of their custody period. 9. Both parties shall refrain from making derogatory comments about the other party in the presence of the minor child. The parties shall likewise, assure to the extent possible, that other household members and guests comply with this prohibition. 10. During any period of custody or visitation, the parties to this Order shall not possess or use any controlled substances; neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and guests comply with this prohibition. BY THE COURT: ~_? 1 ""I')fi. . ~ , IIlllllil~ Ci1\\\y U\it tha tc,r~go\l1~ ~ ~ :.and "COrillOOt COllY 1\ ~ .rilll' ~;,) ~.~JAJ__ PtoUi\ll'lotarv Orodc1 )J~ J. 3 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. ~4904 relating to unsworn falsification to authorities. Date: 3';;)y (1;" 6 , ;;}1m .n '-todd M. Hockley, Plaintiff - 0 t\...J ~ 1- l c l~" .) ....... ,.,:, ,-', ....... '.'; -,"j "'-.J ';!.- :-::;'J .......... 90 () - \,-, ~ , :{J ..c:: () "- Gv ......... ---u ~ IJ'- ~ ( b .. -< L) +- ~- TODD M. HOCKLEY PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA v. 06-1936 CIVIL ACTION LA W STEPHANIE FRANKENFIELD IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, April 06, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , tbe conciliator, at 4th Floor, Cumberland County~our!hous_e, C.rl~~ on Tuesday, MaL0b10_~_""__"_" at .1,~AM for a Pre-Hearing Custody Conference. At sllch conference, an effort will be made to resolve the issues in dispute; or if this cannot be aecomplishcd, to detine 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 prescnt 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 tbe conciliator 48 bours prior to scheduled hearinl!. FOR THE COURT. By: /s/ Tacqueline M. Verney. E~"~ Custody Conciliator V The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infon11ation about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our oftlce. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled con fcrence 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 Soulh Bedford Street Carlisle. Pennsylvania 17013 Telephone (717) 249-3166 -70'{ ./7 /)o-Lh 70 L fi ~ d,.,.,'1J frl'J - f""'f' p.hJ ..;Pr t ff~' '1)!'W" ~tl.J;v 5- I'V,polf lYohl . f71 ii, ' ,~ j !... 6(;:? ( . _. v ' ..,--i f.- \I.n..! '"'"\'"17 '. (,c, J 'J~Jt:J TODD M. HOCKLEY, Plaintiff - JUN 0 2 2UO~ : IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYL VANIA v. : No. 2006-1936 STEPHANIE FRANKENFIELD, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this S'''' day of <I~ ,2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Todd M. Hockley, shall have sole legal custody of Todd Hockley, born April 14, 1996. 2. Father shall have primary physical custody of the child. 3. Mother shall have periods of supervised visits as agreed by the parties. 4. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, ~//i. J. c~e Adams, Esquire, Counsel for Father . L,/5tephanie Frankenfield, pro se.l . 306 East Maiden Street '" Apt 3 Washington, PA 15301 "h {j~ O\9lY \'il;VV/\'1J\SNrEld il\ln'-"'~, ;'""'~'A1n""" iI, I~ ".,,' , ')1"1, V "7F: :2 /'ld S- Nnr gOOl I uhlOJ,!'}j :Ju'l' -in I\Ch. , 'C" ..n. --v ?:J/:'::Cj'{J31/:f '~iiillt;31:k~>i~S5t~~:l(W;;:ti;i::13t:(i'];Y~:'~ifJ;i'Y .".,.:H>' !, j,..p. , "" I