HomeMy WebLinkAbout98-01065
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DA VlD R. WARRICK,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
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CIVIL ACTION - LAW
NO. 98- I DLJ: CIVIL TERM
HELEN V. WARRICK,
Defendant
IN CUSTODY
PETITION FOR CUSTODY
AND NOW, come the plaintiff, David R. Warrick, by and through his attorneys, IRWIN,
McKNIGHT & HUGHES, ESQUIRES, and files this Petition for Custody making the following statement:
I. The plaintiff, David R. Warrick, is an adult individual residing at 177 Oak Hill Road,
Carlisle, Cumberland County, Pennsylvania 17013.
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2. The defendant, Helen V. Warrick, is an adult individual residing at 177 Oak Hill Road,
Carlisle, Cumberland County, Pennsylvania 17013,
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3. The parties were married on February 14, 1992, and are anticipating a physical separation
in the very near future,
4. The parties are the natural parents of two (2) minor children, namely David L. Warrick,
born January 23, 1991, and William R. Warrick, born March 25,1993,
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5. The plaintiff believes, and therefore avers, that it is within the best interest of the minor
children that he have primary physical custody for the following reasons:
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n, TIle defcndant oncn leavcs thc minor children nlone with their two step-
brothers, ages twelve (12) nnd eight (K);
b. TIIC defcndant has shown violcnt behavior towards thc minor childrcn;
c, TIle defcndant has consistcntly shown hcr unwillingness to spend any length of
time with the minor childrcn.
6. The plaintiff believcs nnd thercforc avcrs that he is ablc to provide a morc stable home life
for the minor children, nnd believes that this is within their best interest nnd pennnnent welfare.
WHEREFORE, the plaintiff, David R. Warrick, respectfully requests that he be grnnted primary
physical custody of the minor children.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
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Rebecca R. Hughes, Esqui
60 West Pomfret Street
Carlisle, PA 17013
717-249-2353
Supreme Court 1.0. No: 67212
Attorney for the plaintiff,
David R. Warrick
Dated: February 24 1998
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