HomeMy WebLinkAbout10-2602IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
AMANDA THORSON,
Plaintiff
V.
RONNIE MITCHELL,
Defendant
CIVIL ACTION
MC), !o -j- 6 D 1
CUSTODY
COMPLAINT FOR CUSTODY
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1. The plaintiff is Amanda Thorson who currently resides at 325
W. Ridge Street, Carlisle, Pennsylvania, which is in Cumberland County,
Pennsylvania.
2. The defendant is Ronnie Mitchell who currently resides at 623
Oxford Street, Harrisburg, Pennsylvania, which is in Dauphin County,
Pennsylvania.
3. The plaintiff is seeking custody of the following children:
Name Residence Age
Shyla Mitchell
Ronnie Mitchell II
325 W. Ridge Street
Carlisle, PA 17013
325 W. Ridge Street
Carlisle, PA 17013
The children were born out of wedlock.
4
DOB - 3/19/06
2
DOB - 4/9/08
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The children are under the age of five. During the children's lives, the
children have resided with the following persons and at the following
address:
(List all Persons) (List all Addresses) ,(Dates)
Amanda Thorson and 325 W. Ridge Street 7/08 - present
Aaliyah Torres Carlisle, PA 17013
Amanda Thorson and 439 First Street birth - 7/08
Aaliyah Torres Carlisle, PA 17013
The mother of the children is Amanda Thorson.
She is single.
The father of the child is Ronnie Mitchell
He is single.
4. The relationship of plaintiff to the children is that of mother.
The plaintiff currently resides with the following persons other than
the children named in this custody action: Aaliyah Torres (DOB 8/8/2000)-
daughter of Amanda Thorson to a previous relationship.
5. The relationship of defendant to the children is that of father.
The defendant currently resides with the following person:
No one.
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 children will be
served by granting the relief requested because:
Plaintiff is willing and able to perform the primary parental
responsibilities for the children.
Plaintiff is in the best position to provide the care and nurture which
the children need for healthy development.
Plaintiff has been the primary caregiver for the children since their
birth.
8. Each parent whose parental rights to the children have not been
terminated and the person who has physical custody of the child have been
named as parties to this action.
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WHEREFORE, plaintiff requests the court to grant her custody of the
minor children.
submitted,
,grheri D. Coover, Esquire
Attorney ID 92385
44 S. Hanover Street
Carlisle, PA 17013
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
AMANDA THORSON, CIVIL ACTION
Plaintiff
V.
RONNIE MITCHELL, CUSTODY
Defendant
VERIFICATION
I verify that the statements made in this Complaint are true and
correct. I understand that false statements herein are made subject to
penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to
authorities.
Amanda Thorson
Date: U-,?U- /o