HomeMy WebLinkAbout10-2201Katie J. Maxwell, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
I.D. 206018
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
RE?TAp
i :C. FRO7 .,. ,1 ri Vt V
2010 MAR 31 Phi 12: Z4
`,JUNTY
PENN,': 'LVf?NiA
BOBBIBORRERO,
V.
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2010- aa1D O'Ni 1
CIVIL ACTION - LAW
ANTONIO BORRERO,
Defendant
: IN CUSTODY
PLAINTIFF'S COMPLAINT FOR CUSTODY
1. Plaintiff is Bobbi Borrero, an adult individual currently residing at 32 Trine Avenue,
Mount Holly Springs, Cumberland County, Pennsylvania.
2. Defendant is Antonio Borrero, an adult individual currently residing at 406 North Pitt
Street, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff seeks custody of the children:
Antonio Borrero, Jr., born September 21, 2006
Ciarah Borrero, born February 14, 2008
Isaiah Borrero, born September 23, 2009
4. Since the children's birth, the children have resided with the following persons at the
following addresses for the following periods of time:
Time Period Persons Location
2/24/10 to present Plaintiff 32 Trine Avenue, Mt. Holly Springs, PA
4/09 to 2/24/10 Plaintiff & Defendant 32 Trine Avenue, Mt. Holly Springs, PA
8/08 to 4/09 Plaintiff & Defendant 28 Mill Street, Apt. #1, Mt. Holly Springs, PA
8/07 to 8/08 Plaintiff & Defendant 7 East Street, Apt.#1, Mt. Holly Springs, PA
9/21/06 to 8/07 Plaintiff, Defendant, 106 North Baltimore Ave., Mt. Holly Springs, PA
Bob Weidner, Jr, (grandfather)
Linda Weidner (grandmother)
J.1'1q.00 p o A-rt l
G? 2a33
?A7a8
5. The relationship of the Plaintiff to the children is that of Mother. She is married and
living separately. The Plaintiff currently resides with the following:
Name Relationship
Antonio Borrero, Jr. Son
Ciarah Borrero Daughter
Isaiah Borrero Son
6. The relationship of the Defendant to the child is that of Father. He is married and
living separately. The Defendant currently resides with the following:
Name Relationship
Unknown who Father is residing with, if anyone.
7. The parties have not participated in previous litigation concerning the custody of the
children in this court or any court.
8. The Plaintiff has no information of a custody proceeding concerning the children
pending in any other court.
9. The best interest and permanent welfare of the children will be served by granting
shared custody to the parties.
10. Plaintiff does not know of any person not a party to these proceedings who claims to
have custody or visitation rights with respect to the child.
WHEREFORE, Plaintiff requests your Honorable Court to set a time and place for a hearing
at which Plaintiff requests the Court to grant Plaintiff the Custody Order. Pending said hearing,
Plaintiff requests temporary shared custody.
MARTSON LAW OFFICES
By tZV?4 A n
Katie J. Max , Esquir
10 East Hi S reet
Carlisle, P 013
(717) 243-3341
Attorneys for Plaintiff
Date: !Yt ABC ,? f a ?l , 0 / Lei
. ft.
VERIFICATION
The foregoing Complaint for Custody is based upon information which has been gathered
by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and
not my own. I have read the Complaint and to the extent that the document is based upon
information which I have given to my counsel, it is true and correct to the best of my knowledge,
information and belief. To the extent that the content of the document is that of counsel, I have
relied upon counsel in making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to criminal penalties.
Oil '601-VA A??
Bob Borrero