HomeMy WebLinkAbout96-03529
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ROBERT W, SMALL III,
Plaintiff
IN THE COUR1' OF' COMMON PLEAS Of'
CUMBERLAND couwry, PENNSYLVANIA
CIVIL ACTION - LAW
vs,
JILL J. SMALL,
NUMBER
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Def.endant
CUSTODY
COMPLAINT FOR CUSTODY
NOW COMES the Plaintiff, ROBERT W. SMALL III, by his
attorney, Charles E. Petrie, and respectfully represents as
follows:
1. Plaintiff is ROBERT W. SMALL III, who currently resides
at 6060 Boas Street, Apt. 1010, HarriSburg, County of Dauphin,
Pennsylvania.
2. Defendant is JILL J. SMALL, who currently resides at an
address unknovtn to Plaintiff in the County of Cumberland,
Pellnsyl vania.
3, Plaintiff seeks to have rights of primary physical
custody with respect to ALEXIS BRIANNA SMALL, born August 18,
1994; and ROBERT WESLEY SMALL IV, born October 5, 1992.
The children Were not born out of wedlock.
The children are presently in the custody of Plaintiff,
ROBERT W. SMALL III.
Since birth, the children have resided with the following
persons and at the fOllowing addresses: F'rom Robert's birth
until January, 1993, with both parents at 10 Vioro Boulevard,
Apt. 37-C, State College, Pennsylvania; from January, 1993, until
March, 1994, with both parents in Belletere Apartments,
MechanicBburg, Penn,~y1vania/ from March, 1994, until March, 1996,
with both parents and AlexiB, born August, 1994/ at 124 Collage
Hill Road, 8nola, PennBylvania/ from March, 1996, until June 14,
1996, with Defend,'lnt at 124 College Hill Road, Enola,
Pennsylvania; from ,rune 14, 1996, until the present with
Plaintiff at 660 Boas street, Apartment 1010, Harrisburg,
Pennsylvania.
The mother of the children is JILL J. SMALL, who currently
resides at an address unknown to Plaintiff in Pennsylvania. She
is married.
The fa ther 0 f the children is ROBERT W. SMALL" II I, who
currently resides at 660 Boas Street, Apartment 1010, Harrisburg,
Pennsylvania. He is married.
4. The relationship of the Plaintiff to the children is
that of father. The Plaintiff currently resides with the
children.
5. The relationship of the Defendant to the children is
that of mother. She currently resides with a person or persons
unknown to Plaintiff.
6. The Plaintiff has not participated as a party or
witness, or in another capacity, in other litigation concerning
the custody of the children in this or in another court.
The Plaintiff has no information of a custody proceeding
concerning the custody of the children in this or in another
court.
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CHARLES E. PETRIE
ATTOttM!V AT LAW
3~28 ORIS BAN STREET
HARRISBURG, PENNSYLVANIA 17111
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