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\~CT 2 2 1997
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TARA K. JOHNSON,
Plaintiff
VS.
IN TIlE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
NO. Civil, 1997 - j-St1 4 (}l.~L
CIVIL ACTION. LAW
CUSTODY
TANYA MILLETlCS,
Defendant
AND NOW, th;, J1 ~.Y of ClctoOO, 1997, """n .............
and consideration of the within Petition to Confinn Custody, it is hereby Ordered that
primary physical custody of the minor child, Jalorra Ashli Jarrett, born May 25,1991,
shall be in Plaintiff, Tara K. Johnson, with partial custody for purposes of visitation in
the Defendant, Tanya MiIletics, to be mutually agreed upon between the parties.
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BY THE COURT:
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NO. q'l. ',fvl/ Civil, ~ Uu-
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TARA K. JOHNSON,
Plainti If
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
TANYA MILLETICS,
Defendant
CIVIL ACTION.LA W
CUSTODY
CO~Pi"AINT TO CONFIR~ CUSTOQY
AND NOW, this
Day of October, 1997, comes the Plaintiff,
Tara K. Johnson, by her attorney, Diane M. Rupich, Esquire, and respectfully requests
the fOllowing:
1. The Plaintiff is Tara K. Johnson, an adult individual, who currently resides at 486
Berkshire Lane, Mecbanicsburg, Cumberland County, Pennsylvania 17055.
2. The Defendant is Tanya Milletics, an adult individual, who currently resides at P.O.
Box 307, Landisburg, Pennsylvania 17040.
3, The relationship of Plaintiff and Defendant is that of sistero.
4. The Defendant is the natural mother of one child; namely:
Jalorra Ashli Jarrett, born May 2.5, 1991.
.5. The natural father of Jalorra Ashli Jarrett is Darwin Jarrett, whose wbereabout8 are
unknown and who has not been involved in the nurturing and raising of bis daughter
since she was two weeks old.
6.. The minor child, Jalorra Ashli Jarrett, has resided with the Plaintiffsinc:c March
of 1997.
7. The Plaintiffhas the minor child enrolled in the Cwnberland Valley School District
where she attends first grade, as of August of 1997.
8. The Defendant believes that it is in the best interest of her daughter that she remain
with the Plaintiff, at this time. See Exhibit "A" attached hereto being the consent of
the Defendant.
-2.
9. The Plaintiff respectfully requests your Honorable Court to enter an Order granting
her primary physical custody of her niece.
10. There has been no prior action for custody or visitation of the minor child in this
or any other jurisdiction.
II. The Court of Common Pleas of Cumberland County has full jurisdiction in this
matter as the minor child and the Plaintiff reside in Cumberland County.
WHEREFORE, Plaintiff, Tara K. Johnson, by her attorney, Diane M.
Rupich, Esquire, prays your Honorable Court to grant her primary physical custody of
the minor child, Jalom Ashli Jarrett.
BY:
Respectfully submitted,
~'ytl~~
Diane r-.{ Rupi , squire
1017 N. Front Street
Harrisburg, Pa. 17102
(717) 232-9724
1.0. No. 07056
.3-
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4. Jalorra Ashli JllI1'ett has been in the custody of Tara K. Johnson since March of
1997, and she has started the flJ'llt grade in the Cumberland Valley School District.
5. The natural father of Jalorra Ashli Jmrrett is Darwin Jarrett; however. I do not know
where Darwin Jarrett is residing as he has had no contact whatsoever with Jalorra or
myself since she was two weeks old.
6. I understand that my sister, Tara K. Johnson, is need of a Court Order granting her
custody of my daughter, Jalorra Ashli Jarrett, for medical insurance purposes. My
sister, Tara K. Johnson, is employed by P.H.E.A.A.
7. I hereby confinn my desire that Jalorra Ashli Jarrett remain in the custody, care and
control of my sister, Tara K. Johnson, and I hereby consent to an Order of Court being
entered indicating the same.
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8. I do not desire that a specific visitation arrangement be set forth in the Court Order,
as my sister and I have worked together since March of 1997, and I have never been
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denied visitation with my daughter.
9. I understand that my rights as natural mother arc not affected in any way by
agreeing to this custody arrangement at this time.
10. I undl:rstand that if my circumstances should change in the future. and I should
desire to obtain custody of my daughter. that I may have to petition the Court for
custody.
IN WITNESS WHEREOF. I have hereunto set my band and seal the day and year
rust above written.
'~";'w.~ ,Ct .?"...~J'..~
Witness
~rl'"'~ c?rJJtLtJ.~ (SEAL)
Tanya . )elics. Defendant
I verify that the statements made in this
COMPLA I NT FOR CUSTODY . are true lUld correct. I understand that false
stal4.'I1lents herein are made subject to the penalties of 18 Pa. e.s. Section 4904 relating
to unsworn falsification to authorities.
Date: OCTOBER 1, 1997
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