HomeMy WebLinkAbout96-01346
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EUGENE W. GRAMM, . IN THE COURT OF COMMON PLEAS
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plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
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: CLL'J ~r1996
vs. . No. 'II.' / -j "I,
.
:
BRENDA SHAFFER, .
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Defendant : CIVIL ACTION - CUSTODY
COMPLAIn POR
PARTIAL CUSTODY/VISITATIOM
1. The plaintiff is EUGENE W. GRAMM, an adult individual
living at 627 Hoot OWl Road, (Monroe Township), Boiling Springs,
Cumberland County, PA 17007.
2. The Defendant is BRENDA SHAFFER, an adult individual,
living at 106 Mountain Road, (Middlesex Township), Carlisle,
Cumberland County, PA 17013.
3. The plaintiff is seeking partial custody and visitation
of DAVID LEE SHAFFER (d.o.b. August 15, 1981), a child born out of
wedlock to whom the above parties are the biological parents, and
to whom Defendant has consistently refused Plaintiff visitation.
4. plaintiff has always acknowledged paternity of the child.
5. Defendant has refused to accept plaintiff's continuing
offer of support and has improperly and unlawfully justified her
refusal to permit visitation premised on this refusal to accept
support.
6. Upon knowledge and belief, the child is afflicted with
neuro-cognitive injury or illness and requires intensive medical
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attention and treatment.
7. Upon knowledge and belief Defendant' 8 financial and
social circumstances are such that the child's needs are not fully
addressed.
8. Plaintiff has not participated as a party or witness or
in another other capacity in other litigation in any jurisdiction
concerning partial custody and/or visitation of the child and
Plaintiff has no knowledge of any such proceeding in any other
jurisdiction.
9. Plaintiff is actiITely concerned about the welfare and
well-being of his son and wishes to participate in all aspects of
his maturation and development. Therefore, it is averred the best
interests and permanent welfare of the child DAVID LEE SHAFFER will
be served and enhanced by granting the relief requested.
10. Neither parent's parental rights have been terminated.
WHEREFORE, Plaintiff EUGENE W. GRAMM, biological father of
DAVID LEE SHAFFER, respectfully requests that This Honorable Court
grant partial custody and visitation.
RESPECTFULLY SUBMITTED,
BY
DATEll~ I L( (tz~ V
Glace, Esqu re
& GLACE
h Front Street
12027
Har is urg, PA 17108-2027
(717) 232-0511
I.D. .23933
2
PlorHOHOr....,
CtlMBEIlLAND COUNH
CAIlLISLE. PA 1701l
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LAWRENCE E. WELKER
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EUGENE W. GRAMM, I IN THE COURT or COMMON PLEAS
plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
vs. I No. of 1996
I
BRENDA SHAI'rER, I
Defendant I CIVIL ACTION - CUSTODY
COlQ01.Aln rOR
PAR~IAL CU8~ODY/V181~A~10.
1. The plaintiff is BUGENB W. GRAMM, an adult individual
living at 627 Hoot OWl Road, (Monroe Township), Boiling springs,
Cumberland County, PA 17007.
2. The Defendant is BRENDA SHAI'FBR, an adult individual,
living at 106 Mountain Road, (Middleaex Township), Carliale,
Cumberland County, PA 17013.
3. The plaintiff is seeking partial custody and visitation
of DAVID LBB SHAI'FER (d.o.b. August 15, 1981), a child born out of
wedlock to whom the above parties are the biological parents, and
to whom Defendant has consistently refused Plaintiff visitation.
4. plaintiff has always acknowledged paternity of the child.
5. Defendant has refused to accept Plaintiff's continuing
offer of support and has improperly and unlawfully justified her
refusal to permit visitation premised on this refusal to accept
support.
6. Upon knowledge and belief, the child is afflicted with
neuro-cognitive injury or illness and requires intensive medical
1
attention and treatment.
7. Upon knowledge and belief Defendant's financial and
social circumstances are such that the child's needs are not fully
addressed.
8. Plaintiff has not participated as a party or witness or
in another other capacity in other litigation in any jurisdiction
concerning partial custody and/or visitation of the child and
Plaintiff has no knowledge of any such proceeding in any other
jurisJiction.
9. Plaintiff is actively concerned about the welfare and
well-being of his son and wishes to participate in all aspects of
his maturation and development. Therefore, it is averred the best
interests and permanent welfare of the child DAVID LEE SHAFFER will
be served and enhanced by granting the relief requested.
10. Neither parent's parental rights have been terminated.
WHEREFORE, Plaintiff EUGENE W. GRAMM, biological father of
DAVID LEE SHAFFER, respectfully requests that This Honorable Court
grmnt partial custody and visitation.
RESPECTFULLY SUBMITTED,
BY
DATEll~ 12-( (CZCZ V
Glace, Esqu re
& GLACE
h Front Street
12027
Har is urg, PA 17108-2027
(717) 232-0511
1.0. .23933
2