HomeMy WebLinkAbout07-4228IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Christina Rohrbach, Docket No. ~ ~ .. y ~~ ~
Plaintiff
vs.
David Foz, Civil Action -Law
Defendant Action In Custody
COMPLAINT FOR CUSTODY
1. The Plaintiff is Christina Rohrbach, who resides at 115 Wheatfield Lane, Shermans Dale,
Perry County, Pennsylvania 17090. The Plaintiff is the Maternal Grandmother of the child.
2. The Defendant is David Fox, who resides at 212 Second Street, Enola, Cumberland
County, Pennsylvania 17025-3205.
3. Plaintiff seeks primary physical custody of the following child:
Name Present Residence ,A~e_
Baby Boy Aubil 212 Second Street 2 mos.
aka Anthony James Aubil Enola, PA 17025-3205 (DOB: 4/29/07)
4. The child was born out of wedlock.
5. The child is currently in the custody of David Fox, who resides at 212 Second Street,
Enola, Cumberland County, Pennsylvania 17025-3205.
6. During the past five (5) years, the child has resided with the following persons at the
following addresses:
Persons
Defendant and family
Addresses
212 Second Street
Enola, PA 17025-3205
Dates
June 19, 2007 -Present
7. The Mother of the child, Jennifer Aubil, passed away on 4/29/07.
8. The relationship of the Plaintiff to the child is that of Maternal Grandmother. The
Plaintiff currently resides with the following persons:
Name Relationship
Scott Linsenbach Fiance
Samantha Wright Stone Daughter
10. The relationship of the Defendant to the child is that of Father. The Defendant currently
resides with the following persons:
N me
Paula Fox
James Fox
Jessica Fox
Miranda Fox
Tosha Fox
Unknown
Unknown
Keyonna Fox
Relationship
Mother
Father
Sister
Sister
Sister
Sister
Sister
Niece
11. 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.
12. Plaintiff has no information of a custody proceeding concerning the child pending in a
Court of the Commonwealth or any other state.
13. 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.
14. The best interest and permanent welfare of the child will be served by granting the relief
requested for all of the foregoing:
a. Plaintiff is best able to provide for the educational, psychological, spiritual,
emotional and physical needs of the child.
b. Plaintiff is best able to promote and encourage the child to have a productive
relationship with the Father.
c. It is in the child's best interest that the Plaintiff take an active and appropriate role
in the child's life.
d. It is in the child's best interest that the Plaintiff be permitted to provide the child
with the care, supervision and stability that is necessary for the child's physical and emotional
development.
15. Each parent whose parental rights to the child have not been terminated and the person
who has physical custody of the child has been named as parties to this action.
WHEREFORE, the Plaintiff, Christina Rohrbach, respectfully requests this Honorable
Court grant her primary physical custody of the child with Defendant to have periods of partial
custody.
Respectfully Submitted,
By: ~~~9-rn ~/l, 1 n~~n~
Nicole M. Werner, Esquire
Nealon Gover & Perry
101 South Duke Street
York, PA 17401
(717) 852-7888
Date: 7~j (a~
VERIFICATION
I, Christina Rohrbach, verify that the statements made in the foregoing Custody
Complaint are true and correct. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities.
Date:~~~~
'sting Rohrbach
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