HomeMy WebLinkAbout09-0227DANIEL BRICKER, §
Plaintiff §
v. §
LARRAINE MORTON, §
Defendant §
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
COMPLAINT FOR CUSTODY
AND NOW, comes the Plaintiff, Daniel Bricker, by his attorney, Tanner Law Offices,
LLC, and represents as follows:
1. Plaintiff, Daniel Bricker, is an individual currently residing at 409 Berkshire
Road, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. Defendant, Larraine Morton, is an adult individual currently residing at 27
Mountain View Terrace, Newville, Cumberland County, Pennsylvania 17241.
3. Plaintiff seeks custody of the following child:
Name Present Address Age
Dakota Morton 409 Berkshire Road 10
Mechanicsburg, PA 17055 (D.O.B. 6/14/97)
4. 'The child was born out of wedlock.
5. The child is presently in the custody of the Plaintiff, Daniel Bricker, who
resides at 409 Berkshire Road, Mechanicsburg, Pennsylvania 17055.
6. During the last five years, the child has resided with the following persons at
the following addresses:
Persons : Address: Dates:
Plaintiff 409 Berkshire Rd. 12/24/2008-present
Paternal Grandmother Mechanicsburg, PA 17055
Defendant 27 Mountain View Terrace 9/2008-12/24/2008
Skye Newville, PA 17241
Faith Wilson
Rose Marie
Marlena Gibbs
Shante Gibbs
Mackalya Gibbs
Defendant 27 Mountain View Terrace 6/2006-9/2008
Fred Gibbs Newville, PA 17241
Skye
Faith Wilson
Rose Marie
Marlena Gibbs
Shante Gibbs
Mackalya Gibbs
Defendant Betsy Nelson Trailer Park 6/2005-6/2006
Skye
Faith Wilson
Rose Marie
Defendant Plaza Drive 1998-6/2005
Boiling Springs, PA
7.
8.
9.
10.
The mother of the child is Defendant, Larraine Morton, currently residing at 27
Mountain View Terrace, Newville, Cumberland County, PA 17241.
The father of the child is Plaintiff, Daniel Bricker, currently residing at 409
Berkshire Road, Mechanicsburg, Cumberland County, PA 17055. He is single.
The relationship of the Plaintiff to the child is that of father.
The relationship of the Defendant to the child is that of mother. The Defendant
currently resides with the following persons:
Name Relationshiu
Skye Child
Faith Wilson Child
Rose Marie Child
Marlena Gibbs Child
Shante Gibbs Child
Mackayla Gibbs Child
11. Plaintiff has not participated as a party in other litigation concerning the
custody of the child in a court of this Commonwealth or any other state.
12. Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the child and claims to have custody or visitation rights
with respect to the child.
13. 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.
14. The best interests and permanent welfare of the child will be served by granting
the relief requested. The quality of the child's physical, intellectual, moral and
spiritual environment would be improved by Plaintiff s continuation as primary
care giver for the following reasons:
A. Defendant's boyfriend, Fred Gibbs is currently incarcerated for
sexually abusing his 12 year old daughter who also lives with
Defendant.
B. Defendant has indicated that upon Mr. Gibbs' release from
prison within the next six (6) months, she will take him back into
her home with minor children.
C. Dakota is very uncomfortable around Mr. Gibbs.
D. Defendant lives in a three (3) bedroom trailor with six (6) minor
children, not including Dakota.
E. Dakota is doing very poorly in Defendant's school system.
F. Plaintiff can provide a more stable environment for Dakota.
G. Plaintiff can provide more attention and assistance with regard to
Dakota's educational needs.
WHEREFORE, Plaintiff requests the Court to grant him Primary Physical Custody
of the Child.
Respectfully submitted,
y~~~ A. ~~~~..
Tabetha A. Tanner, Esquire
Supreme Court I.D. No.: 91979
Attorney for Plaintiff
TANNER LAW OFFICES, LLC
1300 Market Street, Suite 10
Lemoyne, PA 17043
(717) 731-8114
~..
VERIFICATION
I verify that the statements made in this Complaint for Custody are true and correct.
I understand that false statements made herein may subject me to penalties of 18 Pa.C.S.
§4904 relating to unsworn falsification to authorities.
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aniel Bricker
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