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HomeMy WebLinkAbout04-1681LAW OFFICES OF EDWARD J. MIMNAGH EDWARD J. MIMNAGH, ESQUIRE Attorney I.D. No. 87860 203 West Caracas Avenue Hershey, PA 17033 Telephone No. (717) 534-2600 Attorney for Plaintiff JOSHUA D. BLOSSER, Plaintiff STEPHANIE A. McFADDEN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. ~/- : : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Joshua D. Blosser residing at 406 5th Street, Summerdale, Cumberland County, Pennsylvania. 2. Defendant is Stephanie A. McFadden, residing at 7 North Ben Hogan Drive, Etters, York County, Pennsylvania. 3. Plaintiff seeks custody of the following child: Nallle Deanna M. Blosser Present Address 7 North Ben Hogan Drive Etters, PA Age 17 months (D.O.B. 10/26/02) 4. The child was bom out of wedlock. The child is presently in the custody of Defendant who resides at 7 North Ben Hogan Drive, Etters, Pennsylvania. 5. During the past five (5) years, the child has resided with the following persons at the following address(es): Name Address Dates Don Blosser Tina Blosser Joshua Blosser Stephanie McFadden Stephanie McFadden Paula Maxwell Glen Maxwell 403 5th Street Summerdale, PA 7 North Ben Hogan Drive Etters, PA Birth until February, 2004 February, 2004 to present Relationship Parents The relationship of Defendant to the child is that of mother. Defendant currently resides with the following persons: Name Deamaa M. Blosser Paula Maxwell Glen Maxwell Melanie (last name unknown) Relationship Daughter Mother Step-father Sister resides with the following persons: Name Donald and Tina Blosser Melanie (last name unknown) 6. The mother of the child is currently residing at 7 North Ben Hogan Drive, Etters, York County, Pennsylvania. She is single. 7. The father of the child is currently residing at 403 5th Street, Summerdale, Cumberland County, Pennsylvania. He is single. 8. The relationship of Plaintiff to the child is that of father. Plaintiff currently 10. Plaintiffhas not participated as a party or a witness, or in any other capacity in other litigation concerning the custody of the child in this or any other Court. l 1. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 12. Plaintiff does not know of a person not a patty to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 13. The best interest and permanent welfare of the child will be served by granting the relief requested. 14. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. Date: April 15, 2004 WHEREFORE, Plaintiffrequests the Court to grant him custody of the child. By: Attorney I.D. No. 87860 203 West Caracas Avenue Hershey, PA 17033 Telephone No. (717) 534-2600 Attorney for Plaintiff VERIFICATION I, Joshua Donald Blosser, verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. JOSHUA DONALD BLOSSER JOSHUA D. BLOSSER PLAINTIFF V. STEPHANIE A. MCFADDEN DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : 04-1681 CIVIL ACTION LAW : : IN CUSTODY ORDER OF COURT AND NOW, Wednesday, April 28, 2004 , 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, Mechaniesburg, PA 17055 on Wednesday, May 19, 2004 at 8:30 AM 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 chikh'en age five or older may also be l~resent at the conference. F.aiIurc to al~pear 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. Sunday, Esq, reno Custody Concilial:or The Court of Common Pleas of Cumberland County is required by law to comply w/th 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