HomeMy WebLinkAbout98-01446
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Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION.LAW
; 98- / </ <{ (, CIVIL TERM
: IN CUSTODY
LILLIE A, BROWN,
v
TAREKA L. ANDERSON,
Respondent
PETITION FOR CUSTODY
1, The Petitioner Is Lillie A. Brown, a member of the Armed Services of the United States,
residing in 38 PSBDET Unit 26525, Box #0, Kltzingen, Germany APOAE 09225 pursuant to
Military Orders,
2, The Respondent is Tareka L. Anderson residing at 128 North Pitt Street, Carlisle, Cumberland
County, Pennsylvania 17013,
3, Petitioner seeks shared legal and primary physical custody of the following child:
NAME PRESENT RESIDENCE ~
Asia Symone McNeal 128 N, Pitt Street, Carlisle, Pennsylvania 2 months
The child was born to Respondent, a single minor.
The child is presently in the custody of Respondent.
During the past two (2) months child has resided with Respondent at 128 N, Pitt Street,
Carlisle, Pennsylvania,
The father of the child Is Jason N, McNeal., whose address is 701 Clovemont Road, Titusville,
Florida, He is presumed single,
4. The relationship of Petitioner to the child Is that of maternal gr6ndmother. The Petitioner is a
member of the Armed Forces stationed In the Federal Republic of Germany, She is a single
woman,
5, The relationship of Respondent to the child is that of Mother, The Respondent currently
resides with the following:
Mary E, Brown - Grandmother
Asia Symone McNeal - Daughter
6. Petitioner 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.
Petitioner has no information of a custody proceeding concerning the child pending in a court
of this Commonwealth,
Petitioner 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 the relief
requested because the Petitioner is best able to provide for the welfare of the child,
,".
.
8. Each parent whose parental rights to the child have not been terminated and the person who
has physical custody of the child have been named as parties to this Action. All other persons,
named 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 RELATIONSHIP ADDRESS
Jason N, McNeal Father 701 Clovemont Road, Titusville, FL
WHEREFORE, the Petitioner respectfully requests the court to grant custody of the child.
~~ ~d-
Attorney for Petitioner
I verify that the statements made In this Petition are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa, C.S. {j4904 relating to
unsworn falsification to authorities,
~ Ol!f}.VU[YJ
IIhe A, Brown, Pelilioner
WITH THE UNITED STATES ARMED FORCES)
AT Ki I-z.inqer'l, 0e,rra{)Lj )
I, the undersigned, certify that I am a duly commissioned, qualified, and authorized notary
public, Before me personally, within the territorial limits of authority, appeared
Lillie A, Brown, who is known by me to be the person who is described herein. whose name is
subscribed to , and who signed this Stipulation for Custody as Petitioner, and who, having been
duly sworn, acknowledged that this Instrument was executed after Its contents were read and
duly explained, and that such execution was a free and voluntary act and deed for the uses and
purposes herein set forth.
Subscribed, sworn to and acknowledged before me by lillie A. Brown, the Petitioner,
who Is known to me to be eligible for Legal Assistance under the rovislons of 10 USC {j1044b
or regulations of the Department of Defense, on as ' This acknowledgment
Is executed in my official capacity under the authority grante by Title 10, United States Code,
Section 1044jf.'which also states that no seal is required on this acknowledgment.
5 .
, SH~~'~
SGT, USA
LEGAL NeD