HomeMy WebLinkAbout96-01334
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12, The relationship of Defendant to the child is that of mother,
The Defendant currently resides with Christopher A, Toddes and Daniel
Christopher Toddes,
13, Plaintiff has not participated as a party or witness, or in
another capacity, in other litiqation concerninq the custody of the child
in this or another court,
Plaintiff has no information of a custody proceedinq concerninq
the child pendinq in a court of this Commonwealth.
Plaintiff does not know of a person not a party to the
proceedinqs who has physical custody of the child or claims to have
custody or visitation riqhts with respect to the child.
14. The best interest and permanent welfare of the child will be
served by qrantinq the relief requested because Christopher A. Toddes has
been the primary caretaker of Daniel since his birth.
15. Each parent whose parental riqhts 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,
WHEREFORE, Plaintiff requests the court to qrant custody to him
of Daniel Christopher Toddes,
YOFFE , YOFFE, P.C<<
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/JEf'FRE N, YOl'FE, ESQUIRE
. Attorney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill. PA 17011
(717) 975 -1838
Attorney ID No, 52933
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DOROTHBA LIN BAILBY, I IN THE COURT OF COMMON PLEAS or
PlaintUf I CUMBERLAND COUNTY, PENNSYLVANIA
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V. I NO. 1996-1344 CIVIL TERM
I
ARID B. BAILBY, I
Defendant I CIVIL ACTION - LAW
PRAECIPE TO DISCONTINUE
TO THE PROTHONOTARY:
Please discontinue the above-captioned matter.
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Richard L. Webber, Jr" squire
Attorney for plaintiff
366 Green Spring Road
F.O, Box 40
Newville. PA 17241-0040
phone (717) 776-6566