HomeMy WebLinkAbout02-4574LARRY A. KAUFFMAN,
Plaintiff,
SANDRA J. KAUFFMAN,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
CUSTODY/VISITATION
COMPLAINT FOR CUSTODY
Plaintiffis LARRY A. KAUFFMAN, whose current address is P. O. Box 512,
Plaintiff seeks shared legal and temporary physical custody of:
Name: Kyla Marie Kauffman, Date of Birth: September 24, 1993
Present
Residence: 159 Cedar Lane, Carlisle, Cumberland County, Pennsylvania
Kyla M. Kauffman (hereinafter referred to as "the Child") was born during the marriage of
the parties. Plaintiffand Defendant were lawfully married on July 30, 1993.
5. The Child presently resides with Sandra J. Kauffman, Plaintiffherein, at 159 Cedar
Lane, Carlisle, Cumberland County, Pennsylvania.
From 1997 until August 25, 2002, the Child lived at 159 Cedar Lane, Carlisle,
Cumberland County, Pennsylvania, with her mother, father and half-brother, Daniel K. Fishel.
of this action.
4.
New Kingston, Cumberland County, Pennsylvania 17072.
2. Defendant is SANDRA J. KAUFFMAN, whose current residential address is 159
Cedar Lane, Carlisle, Cumberland County, Pennsylvania 17013.
Plalntiffis the Father and Defendant is the Mother of the Child who is the subject
From August 25, 2002, to present, the Child lived at 159 Cedar Lane, Carlisle,
Cumberland County, Pennsylvania, with her mother and half-brother, Daniel.
8. Plaintiffhas no information of a custody proceeding concerning the Child pending
in a court of this Commonwealth, with the exception of a Temporary Protection from Abuse
Order wherein Defendant was awarded temporary custody of the child. A Final Protection of
Abuse Order is pending which does not include a provision for custody.
The best interests and permanent welfare of the Child will be served by the relief
requested.
10.
Plaintiffhas not participated as a party, witness or in another capacity or in other
litigation concerning the custody of the Child in this or another Court, except as mentioned in
Paragraph 8 above.
11. Defendant currently lives with her daughter, Kyla, and her son, Daniel.
12. Plaintifflives with a friend, Forrest Carbaugh.
WHEREFORE, Plaintiff respectfully requests that the court grant him shared legal and
temporary physical custody of his daughter, Kyla Marie Kauffman.
Respectfully submitted,
GOLDBERG, KATZMAN & SHIPMAN, P.C.
Paul J~]gsp~ito, Esquire
320 Market Street, Post Office Box 1268
Harrisburg, PA 17108-1268
(717) 234-4161
Attorneys for Plaintiff
85037.1
VERIFICATION
I verify that the statements comained in the foregoing COMPLAINT FOR
CUSTODY are tree and correct to the best of my knowledge, information and belie£ I
understand that false statements contained herein are made subject to the penalties of 18 Pa.C.S.
Section 4904 relating to unswom falsification to authorities.
LARRY A. KAUFFMAN
PLAINTIFF
SANDRA J. KAUFFMAN
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
02-4574 CIVIL ACTION LAW
:
: IN CUSTODY
ORDER OF COURT
AND NOW, Wednesday, September 25, 2002 , 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 301 Market Street, Lemoyne, PA 17043 on Monday, October 28, 2002 at 8:30 AM
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 al~pear at the conference may
provide grounds for entry of a temporary or pexmanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Sl~eeial Relief orders, and Custody orders to the conciliator 48 hours l~rior to scheduled hearing.
FOR THE COURT,
By: /s/
Melissa P. Greevy, Esq,
Custody Conciliator
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 heating.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE 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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
LARRY A. KAUFFMAN,
IN THE COURT OF COMMON PLEAS
Plaintiff,
V.
SANDRA $. KAUFFMAN,
Defendant.
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-4574
CIVIL ACTION - LAW
CUSTODY/VISITATION
PRAECIPE TO DISCONTINUF,
TO ~ PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA:
Kindly withdraw the Complaint for Custody filed by Plaintiff and mark the docket
"Discontinued."
Date: October 1, 2002
GOLDBERG, KATZMAN & SHIPMAN, P.C.
arket ~treet
Post Office Box 1268
Harrisburg, PA 17108-1268
Supreme Court ID g25454
(717) 234-4161
Attorneys for Plaintiff
OCT ~L 5 200;~
LARRY A. KAUFFMAN,
Plaintiff
V,
SANDRA J. KAUFFMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-4574 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
ORDER TO RELINQUISH JURISDICTION
AND NOW, this 10t' day of October, 2002, counsel for the Plaintiff having filed a Praecipe to
Discontinue this action on October 2, 2002, the Conciliator hereby relinquishes jurisdiction of the
above captioned matter.
FOR ~H~~T:
Me--Ti'ssa Peel Greevy, Esquire
Custody Conciliator
:163775