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HomeMy WebLinkAbout08-7438ANTHONY J. RIFE Plaintiff v. JENNIFER OLSCHEFSKI Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07- '7q3 8 T.?. CIVIL ACTION - LAW CUSTODY/VISITATION COMPLAINT FOR PARTIAL CUSTODY/VISITATION 1. 17025. 2. PA 17356. The Plaintiff is Anthony J. Rife, residing at 213-C Enola Street, Enola, PA, The Defendant is Jennifer Olschefski, residing at 2630 Sandra Avenue, Red Lion, 3. Plaintiff seeks partial custody/visitation of the following child: NAME PRESENT RESIDENCE AGE DOB Dyllan J-A. Rife 2630 Sandra Avenue 1 year old 01/18/2007 Red Lion, PA 17356 The child was not born out of wedlock. The child is presently in the custody of Defendant/Mother, who resides at 2630 Sandra Avenue, Red Lion, PA. During the past five (5) years, the child has resided with the following persons and at the following addresses: NAME Father and Mother RESIDENCE 213-C Enola Street Enola, PA 17025 DATE 08/01/2007 to 08/01/2008 Father and Mother Mother, Cindy Crawford, Maternal Grandmother Norma Paine, Maternal Great Grandmother 3810 March Drive Camp Hill, PA 17011 2630 Sandra Avenue Red Lion, PA 17356 01/18/2007 to 08/01/2007 08/01/2008 to present The mother of the child is Jennifer Olschefski, currently residing at 2630 Sandra Avenue, Red Lion, PA 17356. She is married to Father. The father of the child is Anthony J. Rife, currently residing at 213-C Enola Street, Enola, PA 17025. He is married Mother. 4. The relationship of the Plaintiff to the child is that of Father. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP Himself 5. The relationship of the Defendant to the child is that of Mother. The Defendant currently resides with the following persons: NAME RELATIONSHIP Subject child Cindy Crawford Mother Norma Paine Grandmother 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: A. At the time of separation, the parties amicably agreed to a schedule of visitation, which was incorporated into a notarized document; B. Recently Defendant/Mother has refused to permit Father to visit with his son, as previously agreed upon; C. The agreement of the parties was in the best of the child (although it needs slight modification); D. It is important for the best interest of the child to have a relationship with both Father and Mother; E. A court-ordered visitation schedule is appropriate. 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 a party to this action. WHEREFORE, Plaintiff requests the Court to grant partial custody/visitation of the child. Respectfully submitted, Date: f 2,1[1 /09 chard S. Friedman, Esquire 3820 Market Street Camp Hill, PA 17011 Attorney for Plaintiff VERIM ATION I, Anthony J. Rife, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Complaint for Custody; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. r'laA '/ )e Anthony J. fe Dated: f ot/ I -7 l C-Z "W % ? OD c-5 ri7 f?? oo n, t, ! a f 1"'1 Co -< ANTHONY J. RIFE V. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER OLSCHEFSKI Defendant : NO. 08-7438 CIVIL ACTION - LAW CUSTODYNISITATION PRAECIPE Kindly discontinue the above-referenced action. Respectfully submitted, RICHARD S. FRIEDMAN, P.C. Date. /v J^^ Richard $ (Friedman, Esquire 300 N. ?nd Street, Suite 402 Harrisburg, PA 17101 (717) 234-3441 C.7 r.,,y -- ?? C - ?? ' 7 u ' ?... w ??„ ; ?-; { ?-?r c_ _+- ? . r `- ? ? ,