HomeMy WebLinkAbout97-02252
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birth of the ehild. Mother has a ehild from a previous maITiage who is 8 years old, The eUITent
schedule provides for Mother having the minor child who is the subject of this custody action at
the same lime that she has her other child. Essentially they are alternating every weekend and
sharing the weeks. Mother wants to change this schedule to provide that the minor ehild not go
back and forth overnight during the week. She believes thllt the child needs stability and that the
moving bllek and forth is not in his best interest. She also believes thllt the Father's living
arrangement whereby he lives in a one bedroom apartment is not suitable in that the Father and
the child share the same room, although they have diITerent beds. She also believes that the
Father has in the past manipulated their rclationship and that as a result, he will manipulate the
relationship between Mother and son, Mother also is soon to be remaITied and her work
schedule will change such that shc will be able to be with the child more often and therefore she
believes that the child should be with her over nights during the week.
6, The Defendant's position on custody is as follows: Father believes that the CUITent
custodial aITangement is fine, He wants to maintain a regular and consistent contact with his son,
7. Need for separatc counsel to represent child(ren): Ncither party requested.
8, Need for independent psychological evaluation or counseling: None requested and the
Conciliator docs not believe any is necessary,
9. A hearing in this matter is expected to lake one-hlllf day.
10, Olher mlltters or comments: The CUITent schedule that the parties are operating under
was based upon thcir respective work schedules and the respective schcdule that the Mother has
with her other child who is 8 years old, Mother expeets to be working part-time shortly and is
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LAW CF'F'ICES OF' .JAMES A.. MILLER
111 Lacu.T IftUT, IlUlT&loa. H......Ultllo... l'JIDI 171'7J aa"IIA'
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5. The relationship of Defendant to the child is that of father. The Defendant
currently resides with the following persons: N/A.
6, Plaintiff has not participated as a party or witness, or in another capacity,
in other litigation concerning the custody of the child in this or another court. Plaintiff
has no information of a custody proceeding concerning the child pending in a court of
this Commonwealth,
Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the child or claims to have custody or visitation rights with respect
to the child.
7. The best interest and permanent welfare of the child will be served by
granting the relief requested.
8. Each parent whose parental rights to the child has not been terminated
and the person who has physical custody of the child has been named as parties to this
action. All other persons, named below, are known to have or claim a right to custody
or visitation of the children will be given notice of the pendency of this action and the
right to intervene: N/A
WHEREFORE, Plaintiff requests the court to grant custody of the minor child.
\
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James A. 'Ier, Esquire
Attorne r Plaintiff
12 cust Street, Suite 100
arrisburg. Pennsylvania 17101
(717) 236-5161
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