Loading...
HomeMy WebLinkAbout09-0255Joanne Harrison Clough, Esquire Attorney ID No.: 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Plaintiff TAWNA WOOLSTENHULME, Plaintiff v. BRYAN ALLEN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN DIVORCE AND CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Tawna Woolstenhulme, residing at 312 Charles Road, Mechanicsburg, Cumberland County, PA 17050. 2. Defendant is Bryan Allen, residing at 715 Colonial Court, Mechanicsburg, Cumberland County, PA 17050. 3. Plaintiff seeks to confirm custody of the following children: Name Present Address Date-of--Birth Blaine E. Allen 312 Charles Road 8-15-2000 Mechanicsburg, PA Asher T. Alen 312 Charles Road 11-14-2002 Mechanicsburg, PA 4. The children were born out of wedlock. The children are presently in the custody of Plaintiff Mother, residing at 312 Charles Road, Mechanicsburg, PA 17050 and Father at 715 Colonial Court, Mechanicsburg, Cumberland County, PA 17050 on no set schedule. 5. During the past five (5) years, the children have resided with the following persons the following address(es): Name Address Dates a. Plaintiff Mother b. Defendant Father 312 Charles Road Mechanicsburg, PA 715 Colonial Court Mechanicsburg, PA November 10, 2005 to present more than 50% Spring 2006 to present less than 50% c. Mother and Father 312 Charles Road Children's birth date to Mechanicsburg, PA November 10, 2005 6. The mother of the children is currently residing at 312 Charles Road, Mechanicsburg, PA 17050. She is single. 7. The father of the children is currently residing at 715 Colonial Court, Mechanicsburg, PA 17050. He is single. 8. The relationship of Plaintiff to the children is that of natural mother. Plaintiff currently resides with the following person(s): Name Relationship Self Blaise E. Allen Son Asher T. Allen Son 9. The relationship of Defendant to the children is that of natural father . Defendant currently resides with the following person(s):. Name Relationship Self Children during partial Custody 10. Plaintiff has not participated as a party or a witness, or in any other capacity in other litigation concerning the custody of the children in this or any other Court. 11. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 12. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 13. The best interest and permanent welfare of the children will be served by granting the relief requested. a. The children need a consistent custody schedule and stable home environment. Mother is able to better provide the children a consistent schedule and stable home environment. b. The children need a consistent physical custody schedule c. It is contrary to the children's best interest to repeatedly switch households several times each school week. 14. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant her primary physical and shared legal custody of the children. Date: ~ -, ! r ,f , "~ ~~ Respectfully submitted, JOANNE UGH, PC Joanne Heron Clougl Attorney ID No.: 3646 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Plaintiff VERIFICATION I, Tawna Woolstenhulme, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 34904 relating to unsworn verification to authorities. DATE ~I f ~- a~ Ta was Woolstenhulme a ~ ~ Q , ~a ~ ` "S ~ ~ ~.... „ate. a+ ~ ,..t +.r.t ~ \ 1 , N ` «~ ~ `jll ~"? r F T', t e 1. ~ ~.~ ~ `1 N a_ ' ~D ~~ ~~~ .<~, ~ 4 . ,i ~~ ~~ •.a,