HomeMy WebLinkAbout10-2815• ?}? FI
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iAr NE ADAMS
ATTORNEY AT LAW g
Attorney I.D. No. 79465,0
17 W. South St.
Carlisle, Pa. 17013 Y L
(717) 245-8508
esgadams®gmail.com
REGINA M. MILLER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. Civil Term
PHILIP T. MILLER, IN CUSTODY
Defendant
CUSTODY COMPLAINT
1. Plaintiff is Regina M. Miller, who currently resides at 830 Burnthouse Road,
Carlisle, Cumberland County, Pa. 17015.
2. Defendant is Philip T. Miller, who currently lives at 230 N. Old Stonehouse
Road, Carlisle, Pa. 17015.
3. Plaintiff is the Mother of the following child and seeks a custody order
regarding the following child:
NAME DOB/AGE ADDRESS
Matthew R. Miller 5/31/2006 (3) 830 Burnthouse Road.
Carlisle, Pa. 17015
Mother and Father were married in 2005 and were divorced in 2009. Mother
currently has primary physical custody of the child.
During the past five years, the child has resided with the following persons and at
the following addresses:
NAME
ADDRESSES
DATES
Regina M. Miller 830 Burnthouse Rd
maternal grandparents Carlisle, Pa. 17013
2005 - present
$174.00 P6 ATTr
&* 5q50
E* ayf aso
The mother of the child is Regina M. Miller. She currently resides at 830
Burnthouse Road, Carlisle, Pa. 17015, with her parents and the child. She is divorced.
The father of the child is Philip T. Miller. He currently resides at 230 N. Old
Stonehouse Road, Carlisle, Pa. 17015. He is divorced.
4. The relationship of plaintiff to the child is that of Mother. The plaintiff currently
resides with her parents and the child.
5. The relationship of defendant to the child is that of Father. The defendant
currently lives with his parents.
6. Plaintiff has not participated as a party or witness, or in another capacity, in
other litigation concerning the custody of the child in this or another court.
Plaintiff has no information of a custody proceeding concerning the child
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 child or claims to have custody or visitation rights with respect to
the child.
7. The best interest and permanent welfare of the child will be served by granting
the relief requested because: The arties separated in 2008 and were divorced in 2009
and have had an informal verbal custody agreement Mother has maintained primary
physical custody of the child since separation Father recently indicated he would be
moving in the near future and Mother is requesting a formal custody Order, which would
specifically provide that she maintain primary physical custody, that the parties share legal
custody, and schedule under which that Father has liberal periods of partial custody of the
child. This request would be in the best interest of the child because it would provide for
the child's safety and stability as well as ensure regular and ongoing contact with both
parents.
8. Each parent whose parental rights to the child has not been terminated and
the person who has physical custody of the child has been named as parties to this
action.
childWHEREFORE, Plaintiff requests the court to enter a custody order regarding the
.
Respectfully submitted,
Date: q t93 /to
, a Adams, Esquire
I. No. 79465
W. South St.
tarlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
VERIFICATION
I verify that the statements made in this Custody 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.
Date: ?? l lzk-
R*g-ina M. Miller, Plaintiff
JUL 0 0 2010
REGINA M. MILLER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
j V, : N0.2010-2815 CIVIL ACTION -LAW
PHILIP '~. MILLER,
'i Defendant .
IN CUSTODY
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ORDER OF COURT ~" `` ~
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A~1D NOW, this 7~' day of July, 2010, the parties having reached a sitecL ', ,;
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agreement, the Conciliator hereby relinquishes jurisdiction in this matter. ~ ~ -<
FOR THE COURT,
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acq ne M. Verney, Esquire, Custody C iliator
. 1
1~ 2 ~
REGINA M. MILLER,
Plaintiff
vs.
PHILIP T. MILLER,
Defendant
3
JUL T,~8 2010
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 10 - 2815
Civil Term
IN CUSTODY
ORDER
AND NOW, this 1 ~"~ day of , 2010, havin reviewed
9
the attached agreement between the parties, it is hereby ORDERED and DECREED
that the stipulation entered by the parties on July 2, 2010, shall be entered and
incorporated into this Order of Court.
HE COURT:
J.
cc: /Jane Adams, Esquire, for mother
/ Philip T. Miller, self-represented
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