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ElARLaOSHEA and PRISCILLA aOSHEA, : IN TIlE COURT OF COMMON PLEAS OF
Plaintiff's : CUMBERI.AND COUNTY, PENNSYLVANIA
v,
: CIVIL ACTION - LAW
: CUSTODYIVISITATJON
: NO. 98- /~,-j~ CIVIL TERM
PHELlCIA ANN aOSHElA,
Defendant
.c.oMPI~AINT I<'OR CUSTODY
I,. The Plaintiffs are Earl Goshea and Priscilla Goshea, residing at 928 Gobin Street,
Carlisle, PA 17013,
2, The Defendant is Phelicia Ann Goshea, residing at 928 Gobin Street, Carlisle, PA
17013,
3, Plaintiffs seek custody of the following child:
NAME
RESIDENCE
lllill
AGE
Sierra Alexis Goshea
928 Gobin Street
Carlisle, PA 17013
9/24/97
6 months
The child was born out of wedlock,
The child is presently in the custody ofPhelicia Ann Goshea.
During her life, the child has resided with the following persons and at the following '.
addresses:
NAMI\
ADWSs
DATE~
Phelicia Ann Goshea,
Earl Goshea & Priscilla
Goshea
928 Gobin Street
Carlisle, PA 17013
9/24/97 to the present
The mother of the child is Phcllcla Ann Goshca, currently residing at 928 Gohln Street,
CIII'lIsle, PA, She Is unmanled,
The f'uther of the child Is Mark Kcrscy, currcnt address Is unknown, (Bclleved to bc in
New York City), lie Is unmarried,
4, The relationship of the Plaintiffs to the (:hild is that of grandparents, The Plaintiffs
currently residc with the following persons: Phelicia Ann Goshea and Sierra Alexis Goshea
5, The relationship of the Defendant to th,; child is that of mother, The Defendant
currently resides with the following persons: Earl Goshea, Priscilla Goshea and Sierra Alexis
Goshea,
6, Plaintiffs have 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.
Plaintiffs have no Information of a custody proceeding concerning the child pending in a
court of this Commonwealth.
Plaintiffs know of a person not a party to the proceedings who has potential claims of
physical custody of the child 01' claims to have custody or visitation rights with respect to the
child, The name and address of such person is: Mark Kersey, addre,s unknown,
The child's mother has been named as party to this action, The child's father has had no
involvement with regard 10 the child since the child's birth, pays no child support, and has never
visited the child, The father's address is unknown and, therefore, father is not named as a party
to this action,
COMMONWEALTH OF PENNSYLVANIA )
: SS,
COUNTY OF CUMBERLAND )
I vcrify that thc statcmcllts Illadc ill thc fbrcgoing Complalnt<\re truc and cOI'rect. I
ullderstllnd that falsc statcmcnts hcrcin 11l'C Illade sllhjcclto thc penalties of 18 PlI,C,S, ~4904.
relllting to unsworn fillsifkatiollto authorities,
DATE: J17t~"I~
@/I'0 ,,'~Q ;:. if .()--1,.
Priscilla Goshea, Plaintiff
/ 7. / f f y-
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