HomeMy WebLinkAbout09-6757TAMI S. FOUST, THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. : No 09- G 76_7
RICHARD L. FOUST, CIVIL ACTION - AT LAW
Defendant CUSTODY
COMPLAINT IN CUSTODY
AND NOW, comes Plaintiff, Tami S. Foust, pro se, and avers the following in support of
this Complaint in Custody:
1. _ Plaintiff, Tami S. Foust, is an adult individual currently residing at 809 W. Trindle Road,
2°d Floor, Mechanicsburg, Cumberland County, Pennsylvania, 17055.
2. Defendant, Richard L. Foust, is an adult individual currently residing at 3605 Franklin
Avenue, Mechanicsburg, Cumberland County, Pennsylvania, 17050.
3. There is one (1) dependant child from the marriage of the parties, namely Richard L.
Foust, II, born September 21, 1993.
4. The parties are married, but have been separated since September 7, 2008. The child was
not born out of wedlock.
5. The child is currently in the custody Richard L. Foust, residing at 3605 Franklin Avenue,
Mechanicsburg, Cumberland County, Pennsylvania, 17050.
6. The child has resided at the following locations with the following people:
Tami S. Foust -Plaintiff 228 E. Main Street 12/05 - 12/06
Mechanicsburg, PA 17055
Tami S. Foust - Plaintiff 3605 Franklin Avenue 12/06 - 9/08
Richard L. Foust - Defendant Mechanicsburg, PA 17050
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Richard S. Foust -Defendant 3605 Franklin Avenue 9/08 to present*
Mechanicsburg, PA 17050
*During the month of August, 2009, Plaintiff and Defendant shared custody of the child
equally.
7. Plaintiff is the natural mother of the child and she currently resides at 809 W. Trindle
Road, 2nd Floor, Mechanicsburg, Cumberland County, Pennsylvania, 17055.
8. Defendant is the natural father of the child and he currently resides at 3605 Franklin
Avenue, Mechanicsburg, Cumberland County, Pennsylvania, 17050.
9. The best interest and permanent welfare of the child will be served by granting Plaintiff
shared legal and shared physical custody for the following reasons:
a. The child desires a shared custody schedule.
b. Plaintiff and the child have a strong mother and son bond.
c. Both parties reside in the same school district.
d. The child has performed poorly in school while in Defendant's primary 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 child in this or any other Court.
11. 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 party to the proceedings who has physical
custody of the child or 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
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who has physical custody of the child have been named as parties to this action.
WHEREFORE, Plaintiff, Tami S. Foust, respectfully requests this Honorable Court to
grant her shared legal and physical custody of the parties' son.
By
Respectfully Submitted:
TAMI S. FOUST, pro se
809 W. Trindle Road, 2"d Floor
Mechanicsburg, PA 17055
Telephone: (717) 525-2907
Date:
3
I or
VERIFICATION
I, Tami S. Foust, 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.A. §4904 relating to unsworn
verification to authorities.
Date: 1 U-11 -(:)9 ?a
Tami S. Foust
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