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HomeMy WebLinkAbout08-6972 WALTER BRAITHWAITE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. MARIA DESLOSANGELOS OLIVER BERRAL BRAITHWAITE, Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Walter Braithwaite, an adult individual, residing at 62 Chelsea Lane, Carlisle, Cumberland County, Pennsylvania 17015. 2. The Defendant is Maria Deslosangelos Oliver Berral Braithwaite, an adult individual, residing at 1818 West Highland Street, Allentown, Lehigh County, Pennsylvania 18104. 3. Plaintiff seeks custody of the following child: Name Present Residence Date of Birth Walter William Braithwaite 62 Chelsea Lane, Carlisle, PA 17015 December 19, 2000 The child was not born out of wedlock. SAIDIS, >IOWER & ANDS" .ntnwvEis.,?TUw 26 West High Street Carlisle, PA The child is presently in the custody of Father who resides at 62 Chelsea Lane, Carlisle, Cumberland County, Pennsylvania 17015. During the past five years, the child has resided with the following persons and at the following addresses: Name Plaintiff Plaintiff and Defendant Address 62 Chelsea Lane, Carlisle, PA 62 Chelsea Lane, Carlisle, PA Dates November 2007 to present September 2007 to November 2007 Plaintiff and Defendant 4 Rockwell Court, Carlisle, PA March 2007 to September 2007 Plaintiff and Defendant 108 Fairfield Dr., Barto, PA 19504 Birth to March 2007 The mother of the child is Defendant, currently residing at 1818 West Highland Street, Allentown, Pennsylvania 18104. She is married. The father of the child is Plaintiff, currently residing at 62 Chelsea Lane, Carlisle, Cumberland County, Pennsylvania 17015. He is married. 4. The relationship of Plaintiff to the child is that of Father. 5. The relationship of Defendant to the child is that of Mother. 6. 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. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff can best provide for the child's spiritual, physical and emotional welfare. 8. 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. WHEREFORE, Plaintiff requests the Court to grant legal and primary physical SAII)IS, LEND AY AMID- il5•AT-UW 26 West High Street Carlisle, PA custody of the child. FL7R & LI Carol J. Lindsay, Fs ID No. 44693 26 West High She, Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsifications to authorities. Walter Braithwaite Date: SAII)IS, DOWER & LINDSAY 26 West High Street Carlisle, PA (? N r.:3 ? r- -m t7l Ci7 Q?p' s ` 's ..J C :M? ? rim e WALTER BRAITHWAITE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-6972 CIVIL ACTION LAW MARIS DESLOSANGELOS, OLIVER BERRAL BRAITHWAITE IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, December 03, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, January 09, 2009 at 1:00 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. 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/ john. Man an r. 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 Rd I- 3 i "I