HomeMy WebLinkAbout96-05469
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CBRISTOPBBR S. ltLBIN.
Plaintiff
v.
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I
I
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IN THB COURT or COIOlON PLBAS
CUMBBRLAND COUNTY. PBNNSYLVANIA
NO. 'i',~ "'/ C. tJ c,,,,,.J r:u-...-
OLD I. ltLBIN.
Defendant
CIVIL ACTION - CUSTODY
COMPLAINT rOR CUSTODY
AND NOW comes the Plaintiff, Christopher S. Klein, by and
through his attorneys, Mancke, Wagner, Hershey & Tully, and files
the following complaint for custody:
1. The Plaintiff, Christopher S. Klein, is an adult
individual currently residing at 149 Ewe Road, Mechanicsb1:lrg,
CUmberland County, Pennsylvania 17055.
2. The Defendant, Helen I. Klein, is an adult individual,
with a current mailing address of P.O. Box 1594, Mechanicsburg,
CUmberland County, PA 17055.
3. The Plaintiff and the Defendant were married on February
16, 1929, and a divorce action is currently Pending in CUmberland
County, docketed to No. 96-5108.
4. Unto the marriage there was born one child, Joseph Robert
Klein, born October 9, 1992.
5. The child wa. born in wedlock.
6. The Plaintiff is the natural father of the child,
residing at the address contained in Paragraph 1 above.
The Defendant is the natural llIOther of the child, with a
mailing addre.. as contained in Paragraph 2 above.
7. The child has lived at the following addresses and with
the following persona in the last five 15) years:
.......;........-.....-
(a) From October 9, 1992 to November 14, 1994, in
Frankfurt, Germany, with Mother and Father;
(b) From November 14, 1994 to May 6, 1995, at 149 Ewe
Road, Mechanicsburg, Pennsylvania, with Father's
parents, Leslie A. Edwards and John M. Edwards;
(c) From May 6, 1995 to June 15, 1995, at 149 Ewe Road,
Mechanicsburg, pennsylvania, with Mother, Father,
and Father's parents, Leslie A. Edwards and John M.
Edwards;
(d) From June 15, 1995 to June 20, '1995, at 400 High
Street, West Fairview, pennsylvania, with Mother
and Father;
(e) From June 20, 1995 to October 1, 1995, at R.R. 11,
Box 910 B, Landisburg, Perry County, Pennsylvania,
with Mother's sister, Deborah Patton;
(f) From October 1. 1995 to March 15, 1996, at 400 High
Street, West Fairview, Pennsylvania, with Father
and, on occasion, Mother;
(g) Prom March 15, 1996 to April 25. 1996, at 6441
Carlisle Pike, Mechanic.burg. PA with Father and,
on occasion. Mother;
(h) From April 35. 1996 to May 11, 1996, at R.R. '1.
lox 910 8. Landiaburg. Perry County, pennaylvania,
with Mother and Mother'S elater. Deborah Patton;
(il From May 11, 1996 to May 3D. 19'6, at 6441 Carllsle
pike, Mechanic.burg, PA with Father and. on
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