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HomeMy WebLinkAbout09-8066John and Andrea Richardson, : IN THE COURT OF COMMON PLEAS OF Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW Christina Richardson, No. CIVIL ??. ?U 1, Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiffs are John J. and Andrea Richardson who are natural great-grandparents of the minor child, who resides at 214 Key West Boulevard, Carlisle, Pennsylvania, 17013. 2. Defendant is Christina Richardson who is the biological mother of the minor child. Her current address is believed to be 2529 Horsham Road, K-19 Wellington Apartments, Horsham, PA 19044. 3. Plaintiffs file this Complaint pursuant Pa.C.S.A. §5313 and because they are in loco parentis. 4. Plaintiffs seek legal and physical custody of the following child: Name Present Residence DOB Age Seth Richardson 214 Key West Boulevard 7/21/08 14 months Carlisle, PA 17013 The child was not born out of wedlock 5 The child is presently in the custody of Plaintiffs. Moreover, Defendant has visited the child one (1) time since she left the area on or about October 22, 20091. 6. During the child's entire life he has resided with the following persons and at the following addresses: List All Persons John and Andrea Richardson List All Addresses 214 Key West Blvd. Carlisle, PA Dates 7/21/08 - present Christina Richardson 7/21/08 -10-22-09 1 This "visit" was only after great-grandparents got word to Defendant that the child was going to be denied his influenza vaccine - as they were not the child's legal guardians and had no authority to consent to the same. Mother then returned to Southeaster Pennsylvania a few days later without explanation of when or if she would return. 7. During the times listed in paragraph six (6), in which the children resided with plaintiffs, the plaintiffs assumed the role and responsibilities of the children's parents by providing for the physical, emotional and social needs of the child. 8. During the times listed in paragraph six (6), in which the children resided with the plaintiffs, the child's biological father had his parental rights terminated. 9. Plaintiffs have a genuine care and concern for their great-grandson and seek an Order of Court to ensure the Health, Safety and Welfare of the child can continue. 10. The mother of the child is Christina Richardson who is believed to be in Southeastern Pennsylvania, assisting her biological father with child custody issuesz. She is Divorced 11. The father of the child is one, Gage Stiltuer, whose address is unknown, however, see ¶8 supra. He is divorced. 12. The relationship of plaintiffs to the children is that of natural maternal great-grandparents whom the minor child has resided with for his entire life or fifteen (15) months. The plaintiffs currently reside with the following persons. Name Seth Richardson Relationship Great-Grandson 13. The plaintiff's relationship with the children began with the consent of the biological mother, Respondent herein. 14. The relationship of defendant to the child is that of biological mother. 15. The defendant currently resides with the following persons. Name Unknown at this time. Relationship 2 It is specifically believed that Defendant is with her biological Father in an attempt to assist him in obtaining custody in regards to two (2) additional children whom he wished to exercise primary physical custody over. It is believed that Mother may stay in the Southeastern Pennsylvania area to act as a caretaker to these children. 16. Plaintiffs have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiffs have no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiffs do not know of a person or a party to the proceedings that have physical custody of the children and claims to have custody or visitation rights with respect to the children. 17. Plaintiffs believe and aver that they are seeking custody of the minor child to maintain the family household which has been established and to preserve the continued stability of the only household this child has known. They have no desire to estrange the child from Defendant herein. 18. The best interest and permanent welfare of the child will be served by granting the relief request because: Plaintiffs have undertaken and performed the parental responsibilities for the children. Plaintiffs are able to provide the care and nurture which the children need for healthy development in a primary custody situation. WHEREFORE, Plaintiff requests this Court grant Plaintiffs shared legal custody of the child with primary physical custody vested with Plaintiffs, subject to Mother's periods of partial physical custody as agreed upon by the parties. Respectfully submitted, ROMINGER & ASSOCIATES Date: K101f• 9 0 ?- DO l IWA Michael O. Palermo, Jr., Esquire 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 (717) 241-6878 (fax) Supreme Court I.D. # 93334 Attorney for Plaintiffs VERIFICATION We, John R. Richardson and Andrea L. Richardson and Plaintiffs herein and verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. §4904 relating to unsworn falsification to authorities. Andrea L. Richardson, Plaintiff John and Andrea Richardson, : IN THE COURT OF COMMON PLEAS OF Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA vi. CIVIL ACTION - LAW Christina Richardson, No. CIVIL Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Michael O. Palermo, Jr., Esquire, do hereby certify that I served a copy of this Complaint for Custody upon the following by depositing same in the United States mail, Certified -postage prepaid, first class mail, at Carlisle, Pennsylvania, addressed as follows: Christina Richardson K-19 Wellington Apartments 2529 Horsham Road Horsham, PA 19044 Date: oY•?? Respectfully submitted, ROMINGER & ASSOCIATES ";ot-l" Michael O. Palermo, squire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiffs OF THE ff?'TH?INOTARY 2009 NOY 20 FM 12: 41 33