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Home My WebLink About06-5290 r '. ORIG. Nichole M. Staley O'Gorman, Esquire PA Atty. ID No. 79866 PURCELL, KRUG & HALLER 1719 N. Front Street Harrisburg, PA 17102 Telephone: (717)234-4178 Email: nstalev@pkh.com CHRISTOPHER J. POLLOCK Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. Olr5",Q() Civl/-rerM IN CUSTODY CIVIL ACTION - LAW TRACY LEE POLLOCK, Defendant COMPLAINT FOR CUSTODY AND NOW COMES Plaintiff, Christopher J. Pollock, by his attorneys, Purcell, Krug & Haller, and files the following Custody Complaint: 1. Plaintiff is Christopher J. Pollock, an adult individual who currently resides at 3225 Meadow Lane, Harrisburg, Dauphin County, Pennsylvania 17109. 2. Defendant is Tracy Lee Pollock, an adult individual who currently resides at 245 Regal View Drive, Carlisle, Cumberland County, Pennsylvania 17015. 3. Plaintiff seeks shared legal and physical custody of the following children: Name Present Residence Date of Birth/Aae Kevin C. Pollock 245 Regal View Drive Carlisle, PA 17013 11/30/91 (age 14) { Kelly M. Pollock 245 Regal View Drive Carlisle, PA 17013 12/01/91 (age 14) 4. The children were not born out of wedlock. 5. The children are presently in the custody of Defendant, Tracey Lee Pollock. 6. During the past fourteen years, the children have resided with the following persons at the following addresses: Name Address Dates Tracy Lee Pollock 245 Regal View Drive Carlisle, PA 17013 7/24/06 to Present Tracy Lee Pollock and Christopher J. Pollock 245 Regal View Drive Carlisle, PA 17013 1991 to 7/3/06 7. The mother of the children is Defendant, Tracy Lee Pollock. Mother is married to, but separated from, the Plaintiff, Christopher J. Pollock 8. The father of the children is Plaintiff, Christopher J. Pollock. Father is married to, but separated from, the Defendant Tracy Lee Pollock. 9. 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. 10. Defendant was awarded primary physical custody of the children pursuant to a PFA order docketed to No. 064350. Plaintiff has no other information of a custody proceeding concerning the children pending in a court of this Commonwealth. 11. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 12. The best interests and permanent welfare of the children will be served by granting the relief requested. '. '. '. WHEREFORE, the Plaintiff respectfully requests this Honorable Court to grant him shared physical and shared legal custody of the minor children. PURCELL, KRUG & HALLER Date: ~ rl6 O~ '. , VElUFICA'rION I, Christopher J. Pollock , Plaintiff in the within action, hereby verify that the facts contained in the foregoing Complaint in Custody are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa. e.s. Section 4904, relating to unsworn falsification to authorities. DATE: .4~ I 5€.f O~ ....., ' , " ".J; d''''- ~~S= -"'-:?> - -~ g ~:E.~ S &~ ~ ~ 04 l~ ~ " " "C:-,. . \ ~ ",i.' " '\ e (') c: :;:::'"'. !.-"" r--> (.-,::::1 = 0"" (/) r--"-; ~ -"? .... ~ .-l :t:""T'1 nlpt :q~ .) ~:? <2{:' L ---r, ':.:~~ ,-:) ...\ ~ r;-? .t:" N CHRISTOPHER J. POLLOCK PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA v. 06-5290 CIVIL ACTION LAW TRACY LEE POLLOCK DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, September 14, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at MDJ Manlove, 1901 State St., Camp Hill, PA 17011 on Friday, October 20, 2006 at 2:30 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 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 hearin2;. FOR THE COURT. By: Isl Melissa P. Greevy, Esq. ---tJ-i14-- Custody Conciliator r' 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 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 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~ Jr' -? IIf7"W ~ '10511; ~1 ~ ~ 7?1f!/t- ? (/ -,'ii- b ~() jt& 1- ~ ~...pJ /jr?j'/-/J \. ':1 . -) l'.\ (^~, ~ ~ i" :,") . ~ ,J ~~" l . .. - Nichole M. Staley O'Gorman, Esquire PA Atty. ID No. 79866 PURCELL, KRUG & HALLER 1719 N. Front Street Harrisburg, PA 17102 Telephone: (717)234-4178 Email: nstaley@pkh.com CHRISTOPHER J. POLLOCK Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5290 TRACY LEE POLLOCK, Defendant IN CUSTODY CIVIL ACTION - LAW AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I, Nichole M. Staley O'Gorman, Esquire, Attorney for the Plaintiff, Christopher J. Pollock, in the above action, hereby swear and affirm that on the 18th day of September, 2006, I sent, by certified mail, return receipt requested, restricted delivery, a Complaint for Custody to the Defendant, Tracy Lee Pollock. The Return Receipt Card signed by the hereto as Exhibit "A". Sworn and subscribed to before me this ~(stay of ~ ,2006. {1_~ & j, Jz Not LTH OF PEN Notarial Seal Angela S. Shaffer, Notary Public , City Of Harrisburg, Dauphin COUlIIly My Commission Expires Jan. 12, 2008 Meml:.~r. Pennsylvania Associa',ion Of Notaries ~ .. ..- 2. Article Number 1111111111 mlIU~ ~._-- ,-,~,.!.~-,.,~,.,.......,:.~.,.~..,,,-,, .,. 1liW1- 3.u. 116&fA 3lQ7 ma 3. Service Type CERTIFIED MAIL 4. Restricted Delivery? (Extra Fee) 1. Article Addressed to: Tracy Lee Pollock ::.45 Regal View Drive Carlisle, P A 17013 Pollock v. Pollock PS Form 3811, July 2001 Yes NMSO Domestic Return Receipt EXHIBIT "A" o AjlIlnI g-A'ddressee DYes DNo (') c -,-,S': ~,) 1"'r.... [1' Vr, :,2(;; ;;.2 0. r:'" <"~ ::E; C' ,;('_.....-.i ~I...) .Y" ~:; ~ r-..) = = CT" (/') f'T1 -0 N N o ." ~ mE :gt9. 06 ~:B ~~ ~ ~ -0 ::::3: ~ (J1 , \- Nichole M. Staley O'Gorman, Esquire PA Atty. ID No. 79866 PURCELL, KRUG & HALLER 1719 N. Front Street Harrisburg, PA 17102 Telephone: (717)234-4178 Email: nstaley@pkh.com CHRISTOPHER J. POLLOCK Plaintiff vs. TRACY LEE POLLOCK, Defendant TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-5290 : IN CUSTODY : CIVIL ACTION - LAW PRAECIPE Please mark the above-captioned action discontinued and ended. Date: October 19, 2006 PURCELL, KRUG & HALLER , , CERTIFICATE OF SERVICE I, CA THI LEIGH MCADAMS, an employee of the law firm of Purcell, Krug & Haller, counsel for Plaintiff, hereby certify that the foregoing Praecipe was served upon the following via first-class, postage prepaid mail on October 19, 2006 on: Melissa P. Greevy, Esquire MDJ Manlove 1901 State St. Camp Hill, PA 17011 Timothy Colgan, Esquire The Wiley Group 130 W. Church Street Dillsburg, PA 17019 ~ ~ ~ 1J7~ Cathi Leigh cAdams (') f'...:I c:::> ~ c: c::::> s:- O"' dJm 0 ~~ rn n .z.. ~:r:,: ....., -i"r" Vs'l: ~? -<~2 U) ~C~ O( . ::t:Io ~.:;::J .~ ::l>r.... ?~:n Z(-~ :x ~~ )> -' C C5 0 7 ~ =t w ::0 C" -< ~( CHRISTOPHER J. POLLOCK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5290 CIVIL TERM v. CIVIL ACTION - LAW TRACY LEE POLLOCK, IN CUSTODY Defendant ORDER TO RELINQUISH JURISDICTION AND NOW, this 25th day of October, 2006, Plaintiff having discontinued his Complaint for Custody by Praecipe dated October 19, 2006, the Conciliator hereby relinquishes jurisdiction of the above captioned matter. :285607 Melissa Peel Greevy, Esquire Custody Conciliator u:> to (."J - ';>"0 cc: %~, (~s:.<~ u,t...l- :::.:I,. , tC:c. t- u-- o -.- a :.~ c? _-N"" - .....P c:::> c::> (,"...J -' o .... vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5290 Nichole M. Staley O'Gorman, Esquire PA Atty. ID No. 79866 PURCELL, KRUG & HALLER 1719 N. Front Street Harrisburg, PA 17102 Telephone: (717)234-4178 Email: nstaley@pkh.com CHRISTOPHER J. POLLOCK Plaintiff TRACY LEE POLLOCK, Defendant IN CUSTODY CIVIL ACTION - LAW PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of Nichole M. Staley O'Gorman, Esquire in the above-captioned matter. Date: (r (7ilt PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Christopher J. Pollock, pro se, in the above- captioned matter. Date: I~JJDU O? 2 g U t::D r1}rT'i ..<- "::.~~:' Zt (J) <t, .~~'~ !<:c_, 1; ,;-: ~\ ,j Ps L 3 ... ....., c:;::) c:;::) c:r> o f'T1 (""") I ~ ~:D nl,- "'O,m :09 06 =r1.. ---n g~ ~ ?Q :..c::: -0 ::E .r:- '0 o -.J