HomeMy WebLinkAbout99-00731
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I I. The relationship of the plaintiff to the child is that of a biological father. The plaintiff currently resides with
the following person:
Name Relationship Birthdate
Aaron Davis Son 2/28/94
Bryan Penn Son 8/1 1/86
Brittany Penn Child 1/18/88
12. The plaintiff 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.
13. The plaintiff has no other information ofa custody proceeding concerning the child pending in a Court of this
Commonwealth.
14. Plaintiff 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.
The best interest of the child and permanent welfare of the child will be served by granting the relief requested
because:
The father has demonstrated a pattern of physical and psychological abuse towards the plaintiff, mother and has .
physically assaulted the mother in the presence of the child on numerous occasions resulting in family discord and
dissension.
Thedefelldant's parents while ill the presence of the child accosted plaintiff physically punching plaintiff in
, the face breaking her glasses, bruising her eye, and then proceeded to throw her against the wall bruising her thigh
and her calf.
(c) The father frequently and repeatedly has yelled and screamed at plaintiff, mother using vulgarities and foul
language in the presence ofthe child.
The father has abandoned the marital household.
The father abuses alcohol and ilIicit substances and does so on a daily basis drinking early in the morning and,
continues throughout the day and evening during which time he becomes belligerent, abusive, and hostile toward '
mother and child.
On several occasions the defendant father while supervising the children during mother's brief absence has
passed out as a result of his abuse of alcohol leaving the children unattended and v,ithout adult supervision.
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