HomeMy WebLinkAbout98-00269
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SAIDIS, GIJIDO,
SHIJFF &
MASLAND
26 W. f1igh SIICCI
Cnrll.~lc, PA
Valentina Brown 2415 108th Avenue 1995 (summer)
Oakland, CA 94603
Chad L. Stambaugh 202 North Street 1996
Harrisburg, PA
Valentina Brown 2415 108th Avenue 1996 (summer)
Oakland, CA 94603
Chad L. Stambaugh 166 West South Street August, 1997 -
Carlisle, PA 17013 JanualY 3, 1998
Valentina Brown 2415 108th Avenue 1997 (Emmme r )
Oakland, CA 94603
Chad L. Stambaugh Harvon Motel January 3, 1998
851 North Hanover Street to present
Carlisle, PA 17013
The mother of the children is Valentina Brown, currently
residing at 2415 lOath Avenue, Oakland, California.
She is married.
The father of the children is Chad L. Stambaugh, residing at
Harvon Motel, 851 North Hanover Street, Carl isle, Cumberland
County, Pennsylvania.
He is not married.
4. The relationship of Plaintiff to the children is that of
mother. The Plaintiff currently resides with the following
persons:
Name
Relationship
Jimmy Brown
husband
5. The relationship of Defendant to the children is that of
father. The Defendant currently resides with the following
persons:
Name
Relationship
Crystal A. Stambaugh
daughter
Vincent A. Stambaugh
son
SAIDIS, GUfI)O,
snm'lI&
MASLAND
26W.lIlghSlrcct
CI\r1j~lc.l'^
6. plaintiff has not participated as a party or witness, or
in another capacity, on other litigation concerning the custody
of the children in this or another court. The court, term and
number, and its relationship to this action is: Not applicable.
plaintiff has no information of a custody proceeding
concerning the chi ldren pending in a court of this Commonwealth.
The court, term and number, and its relationship to this action
is: Not applicable.
Plaint i ff does not know of a person not a party to the
proceedings who has physical custody of the children or claims to
have custody or visitation rights with respect to the children.
The name and address of such person is: Not applicable.
7. The best interest and permanent welfare of the children
will be served by granting the relief requested because the
children have been moved frequently and the home environment is
better with Plaintiff.
8. Each parent whose parental rights to the children have
not been terminated and the person who has physical custody of
the children has been named as a party to this action. All other
persons, named below, who 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:
Name
l:\ddrefls
Basis of Claim
N/A
WHEREFORE, Plaintiff requests the court to grant primary
physical custody of the children to plaintiff due to the frequent
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