HomeMy WebLinkAbout07-6336/.. ,
FRITZNEL PREVAL, IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. No. Civil
MARIE FRANCOIS, CIVIL ACTION - LAW
Defendant
COMPLAINT FOR CUSTODY
1. The Plaintiff is Fritznel Preval, residing at 12 Kingwood drive, Mechanicsburg,
Cumberland County, PA 17055.
2. The Defendant is Marie Francois, residing at 12 Kingwood drive, Mechanicsburg,
Cumberland County, PA 17055.
3. Plaintiff and Defendant are not married.
4. The children who are the subjects of this Petition are Krisnel Preval, born 5/24/99;
Allen Preval, born 11/30/02, Steven Preval, born 11/15/04 and Ashton Preval born April 3, 2006.
5. The Plaintiff is the natural father of Krisnel Preval, Alen Preval, Steven Preval and
Ashton Preval.
6. The Defendant is the natural mother of Krisnel Preval, Alen Preval, Steven Preval
and Ashton Preval..
7. During the past five (5) years the children have resided with the following persons
at the following addresses:
Name Residence Years/Time Spent
Father, Mother 12 Kingwood Dr. 9/06 - present
Mechanicsburg, PA
Father, Mother 269 Elmwood Ave. 1 /04 - 9/06
East Orange, NJ
(Mother & children separated for 1 year)
0. 4
Name Residence Years/Time Spent
Father, Mother 16 Bell St. 2001-1/04
Ilvington, NJ
Mother With friend in 2001-prior
Ilvington, NJ
8. Plaintiff believes that a PFA-like action may have been filed two (2) years ago by the
Defendant in New Jersey which action was later withdrawn by the Defendant.
9. Each parent whose parental rights to the children have not been terminated and the
person who has physical custody of the children has been named as party to this action.
10. Plaintiff does not know of a person not a party to the proceedings who has physical
custody of the children or claims to have custody or visitation rights with respect to the children.
11. The best interest and permanent welfare of the children will be served by granting the
relief requested because the father is in a better position to provide stable support and provide for
the welfare of the children.
WHEREFORE, your Plaintiff requests that he be granted primary physical and legal custody
of the minor children.
Respectfully submitted,
L. Rex Bic y
114 South St.
Harrisburg, PA 17101
717-234-0577
717-234-7832 (fax)
a , "'0
VERIFICATION
I, Fritznel Preval, verify that the statements made in the foregoing Petition are true and
correct to the best of my information, knowledge and belief. I understand that false statements made
herein are made subject to Pa.C.S.A. Section 4904 relating to unworn falsification to authorities.
Date: /°/ L('l" 7
Fritzne Preval
rz,
- t
V
r?
N
N
C?
t'7
?L
-a r
r
FRITZNEL PREVAIL IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. 2007-6336 CIVIL ACTION LAW
MARIE FRANCOIS
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, Thursday, November 01, 2007 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, December 04, 2007 at 1:30 PM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ Dawn S. Sunda Es q.
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
. ))A 1 ( A 7
Joe
r
DEC 0 7 2007 ?r
FRITZNEL PREVAL
Plaintiff
VS.
MARIE FRANCOIS
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2007-6336 CIVIL ACTION LAW
IN CUSTODY
ORDER
AND NOW, this 30th day of November, 2007, the conciliator, being advised by
plaintiff's counsel that plaintiff intends to withdraw the Complaint for Custody in this matter, hereby
relinquishes jurisdiction. The custody conciliation conference scheduled for December 4, 2007, is
cancelled.
FOR THE COURT,
Dawn S. Sunday, Esquire
Custody Conciliator