HomeMy WebLinkAbout10-2444CORY M. MILLER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW C7 ;
IN CUSTODY -t ;c,
TIFFANY J. ENGEL,
Defendant. :NO. 10- ay44 CIVIL TERM IT
COMPLAINT FOR CUSTODY -- ?:
The plaintiff, Cory M. Miller, by his attorneys, the Family Law Clinic, sets forth the
following cause of action in custody.
1. The plaintiff is Cory M. Miller, residing at 129 Bungalow Road, Enola, Cumberland
County, Pennsylvania 17025.
2. The defendant is Tiffany Engel, residing at, 328 Third Street, West Fairview,
Cumberland County, Pennsylvania 17025.
3. Plaintiff seeks shared legal and partial physical custody of-.
Name
Chase Michael Miller
Present Residence
328 Third Street
West Fairview, PA 17025
Age
2 years, 4 months
DOB: 11/10/07
The child was born out of wedlock.
The child is presently in the custody of Tiffany Engel, who resides at 328 Third Street,
West Fairview, PA 17025.
During the past five years, the child has resided with the following persons at the
following addresses:
Persons Address Dates
Tiffany Engel 328 Third Street, 11/10/07-
West Fairview, Present
Pennsylvania 17025
Marlon Engel 328 Third Street, 11/10/07-
West Fairview, Present
Pennsylvania 17025
Brandon Engel 328 Third Street, 11/10/07-
West Fairview, Present
Pennsylvania 17025
Kaylee Dayhoff 328 Third Street, 11/2009-
West Fairview, Present
Pennsylvania 17025
The mother of the child is Tiffany Engel.
She is single.
The father of the child is Cory M. Miller.
He is single.
4. The relationship of plaintiff to the child is that of father. The plaintiff currently resides
with the following persons:
Name Relationship
Robin Bolash Plaintiff's mother
Dillon Zinicola Plaintiff's brother
Delaney Parker Plaintiff s sister
5. The relationship of defendant to the child is that of mother. The defendant currently
resides with the following persons:
Name Relationship
Marlon Engel Defendant's father
Brandon Engel Defendant's brother
Kaylee Dayhoff Defendant's daughter
6. Plaintiff has 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.
Plaintiff has no information of a custody proceeding concerning the children pending in
a court of this Commonwealth, or any other state.
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.
7. The best interest and permanent welfare of the child will be served by granting the
relief requested because:
a. Plaintiff is able to provide the child with a stable home and environment with
adequate moral, emotional, and physical surroundings as required to meet the
child's needs;
b. Plaintiff is willing to accept partial physical custody of the child.
c. Plaintiff desires to become more involved in the child's life and build a stable
relationship.
8. Each parent whose parental rights to the children have not been terminated and the
person who has physical custody to the child have been named as parties to this action.
WHEREFORE, plaintiff requests the court to grant him shared legal custody
and partial physical custody of the child, with the mother having primary of physical
custody.
Date: o 1(o
Respectfully submitted,
Kar . Wilson
Certified Legal Intern
Ao?w THOM S M. PLACE
ROBERT E. RAINS
ANNE MACDONALD-FOX
MEGAN RIESMEYER
Supervising Attorneys
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
I 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.C.S. § 4904 relating to
unsworn falsification to authorities.
Cor . Miller, Plaintiff
CORY M. MILLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN CUSTODY
TIFFANY J. ENGEL,
Defendant NO. 40-aqqq CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS - ?'
TO THE PROTHONOTARY: _
Kindly allow Cory Miller, Plaintiff, to proceed in forma pauperis.
The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies
that we believe the party is unable to pay the costs and that we are providing free legal service to
the party.
Date
Respectfully submitted,
Kare Wilson
Certified Legal Intern
J s/I %
ROBERT E. RAINS o
THOMAS M. PLACE
ANNE MACDONALD-FOX
MEGAN RIESMEYER
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968