HomeMy WebLinkAbout08-5453(~~
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TAMBREY ANNE STRICKLAND,
Plaintiff
vs.
TIMOTHY FRANCIS DOWNEY and,
DANA SHROY,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
. NUMBER: 08 - 5'f53 C iv ~~ Ter -•.,
IN CUSTODY
COMPLAINT FOR CUSTODY
NOW COMES the Plaintiff, TAMBREY ANNE STRICKLAND, by her
attorney, Charles E. Petrie, and respectfully represents as follows:
1. Plaintiff is TAMBREY ANNE STRICKLAND, who currently resides at
25 South Washington Street, Shippensburg, County of Cumberland,
Pennsylvania.
2. Defendants are TIMOTHY FRANCIS DOWNEY, an adult individual
currently residing at Dauphin County Prison, 501 Mall Road, Harrisburg,
County of Dauphin, Pennsylvania; and DANA SHROY, an adult individual
currently residing at 631 Oak Circle, Harrisburg, County of Dauphin,
Pennsylvania.
3. Plaintiff seeks to have rights of primary physical and legal custody
with respect to CONNER PATRICK DOWNEY, born August 2, 2008.
The child was born out of wedlock.
The child is presently in the custody of Plaintiff, TAMBREY ANNE
STRICKLAND.
Since birth the child has resided with the following persons and at the
following addresses: From birth until the present with the plaintiff at
25 South Washington Street, Shippensburg, Pennsylvania.
The mother of the child is DANA SHROY, who currently resides at 631
Oak Circle, Harrisburg, Pennsylvania. She is not married.
The father of the child is TIMOTHY FRANCIS DOWNEY, who currently
resides at Dauphin County Prison, 501 Mall Road, Harrisburg, Pennsylvania.
He is not married.
4. The relationship of the Plaintiff to the child is that of paternal
grandmother. The Plaintiff currently resides with the child and with her
mother, Carol, her daughters, Sarah, age 15, Elizabeth, age 3, and Jennifer,
age 23.
5. The relationship of the Defendants to the child is that of natural
parents. The natural father is currently incarcerated. The natural mother
currently resides with her father, Walt Shroy.
6. 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 in
another court.
The Plaintiff has no information of a custody proceeding concerning the
custody of the child in this or in another court.
Plaintiff does not know of a person not a party to these proceedings who
has physical custody of the child or who 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
confirming rights of primary physical and shared legal custody in Plaintiff.
8. Each parent whose parental rights to the child have not been
terminated and the persons who have physical custody of the child have been
named as parties to this action.
9. The parties have entered into a Stipulation, attached hereto, setting
forth their agreement concerning custody of the minor child.
WHEREFORE, Plaintiff requests the Court enter an Order confirming
rights of primary physical and legal custody in Plaintiff.
Respectfully submitted,
~~~~~
CHARLES E. PETRIE
3528 Brisban Street
Harrisburg, PA 17111
(717) 561-1939
Attorney for Plaintiff
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
I verify that the statements in the foregoing Motion and Complaint are
true and correct. I understand that false statements herein are made subject
to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to
authorities.
i
DATE T BR ANNE STRICKLAND
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6. J .
TAMBREY ANNE STRICKLAND,
Plaintiff
vs.
TIMOTHY FRANCIS DOWNEY and,
DANA SHROY,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NUMBER: v ~- 5`l S 3 ~.~Q `~-e~,~.
IN CUSTODY
MnTinN
NOW COMES the Plaintiff, TAMBREY ANNE STRICKLAND, by and
through her attorney, Charles E. Petrie, and respectfully represents as follows:
1. That Plaintiff is TAMBREY ANNE STRICKLAND, an adult individual
currently residing at 25 South Washington Street, Shippensburg, County of
Cumberland, Pennsylvania.
2. That Defendants are TIMOTHY FRANCIS DOWNEY, an adult
individual currently residing at Dauphin County Prison, 501 Mall Road,
Harrisburg, County of Dauphin, Pennsylvania; and DANA SHROY, an adult
individual currently residing at 631 Oak Circle, Harrisburg, County of
Dauphin, Pennsylvania.
3. That Plaintiff is the paternal grandmother and Defendants are the
natural parents of a minor child, CONNER PATRICK DOWNEY, born August 2,
2008.
4. That the parties have entered into a Stipulation concerning the
matters of custody and visitation with respect to the minor child, and the said
Stipulation is attached hereto.
5. That the parties desire that said Stipulation be entered as an Order of
Court.
WHEREFORE, Plaintiff respectfully requests that Your Honorable Court
enter an Order pursuant to the attached Stipulation.
Respectfully submitted
,~~
CHARLES E. PETRIE
3528 Brisban Street
Harrisburg, PA 17111
(717) 561-1939
Attorney for Plaintiff
TAMBREY ANNE STRICKLAND,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NUMBER: 0 ~` S'~-t S 3 'C,w~ ~'t"-,,..`
TIMOTHY FRANCIS DOWNEY and,
DANA SHROY,
Defendants IN CUSTODY
STIPULATION
AQrREEMENT, made this 15~ day of September, 2008, by and between
TIMOTHY FRANCIS DOWNEY, hereinafter referred to as "Father;" and
DANA 8HROY, hereinafter referred to as "Mother;" and TAMBREY ANNE
BTRICKLAND, hereinafter referred to as ~Cuatodial Parent;"
WITNE88ETH:
WHEREAS, the parties hereto are the natural parents of a minor child,
CONNER PATRICK DOWNEY, born August 2, 2008; and
WHEREAS, the parties have reached an agreement concerning the issues
of custody and desire that this Stipulation be entered as Order by the Court of
Common Pleas of Dauphin County, Pennsylvania;
NOW, THEREFORE, intending to be legally bound, the parties hereby
agree as follows:
1. Custodial Parent, TAMBREY ANNE STRICKLAND, shall have primary
physical and legal custody of CONNER PATRICK DOWNEY, born August 2,
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