HomeMy WebLinkAbout97-02866
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16. The natural mother of the children is Tracey M. McNeal. currently
residing at the above-stated address.
17. The adoptive father of the children is David S, McNeal, currently residing
at the above-stated address,
18. The relationship of the Plaintiff to the children is that of adoptive father,
19, The relationship of the Defendant to the children is that of natural
mother,
20, The Plaintiff has not participated as a party or in any other capacity, in
other litigation conceming the custody of the children in this or any other court,
21, Plaintiff has no information of a custody proceeding conceming the
children pending in a court of this Commonwealth.
22, The Plaintiff seeks joint legal custody and periods of partial physical
custody of his children,
23, The best interests and permanent welfare of the children will be served
by granting the relief requested because the Plaintiff has maintained a continuous and
ongoing relationship with these children since their young age. when they were
adopted by him.
24, Each parent whose parental rights to the children have not been
terminated and the person who has physical custody of the children have been named
as parties to this action, No other persons are known to have or claim to have any
right to custody or visitation of the children other than the parties to this action,
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