HomeMy WebLinkAbout97-02650
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4. The relationship of plaintiff to the child Is that of maternal grandmother. The
plaintiff currently resides with the following persons:
Name Relationship
David L. Young Husband
David Young Son
Joshua Young Son
5. The relationship of defendant to the child Is that of mother. The defendant
currently restdes with the following persons:
~ Relationship
Unknown
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 tile relief requested because:
a) Plaintiff provides the child with a home with adequate moral, emotional and
physical surroundings as required to meet the child's needs;
b) Plaintiff is willing to accept custody of the child;
c) Plaintiff continues to exercise parental.type duties and enjoys the love and
affection of the child.
8. Each parent whose parental rights to the child have not been terminated and
the person who has physical cllstody of the child have been named as parties to this
action. All other persons, namcd below, who are known to have or claim a right to
custody or visitation of the child will be given notice of the pendency of this action
and the right to Intervene:
Name Address Basis of Ctaim
NONE
Wherefore, plaintiff requests the court to grant cllstody of the child.
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mdsay Da Baird, Esquire
Attorney for Plaintiff
37 S. Hanover Street
Carlisle, Pennsylvania 17013
(717) 243-5732