HomeMy WebLinkAbout10-4066~I~E':~-~: "::ai~-
2Dl0 J~~~t I ~ F~ ~ 2~ 49
C~i~,r :c~~~
TOMMY A. REPMAN, JR. , : IN THE COURTH~~~~sI1~N PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. CIVIL ACTION -LAW
. N0.2010 - ~Olol~ CIVIL TERM
BRITTANY L. ELLIS,
Defendant IN CUSTODY
COMPLAINT FOR CUSTODY
AND NOW comes the Plaintiff, Tommy A. Repman, Jr., by his attorneys, Irwin &
McKnight, P.C., and presents the following Complaint for Custody.
1. The Plaintiff, Tommy A. Repman, Jr., is an adult individual with an address of 332 Pine
Grove Road, Gardners, Cumberland County, Pennsylvania 17324.
2. The Defendant, Brittany L. Ellis, is an adult individual with an address of Betty Nelson's
Trailer Park, 12 John Drive, Carlisle, Cumberland County, Pennsylvania 17015.
3. The parties are the natural parents of one (1) child, namely, Isaac N. Repman, born May
7, 2008.
4. The Plaintiff, Tommy A. Repman, Jr., desires that the parties have shared legal custody of
the minor child, Isaac N. Repman.
5. The Plaintiff, Tommy A. Repman, Jr., desires shared physical custody of the said minor
child, Isaac N. Repman, with periods of physical custody to Defendant, Brittany L. Ellis, as the
parties can agree.
f~9•o0~d.
~~ ~/D9f 3
6. The Defendant, Brittany L. Ellis, is the natural mother of Toby A. Ellis, born March 15,
2006. The natural father of said minor child is currently incarcerated in the Commonwealth of
Pennsylvania prison system and has not had physical custody of said child. The Plaintiff,
Tommy A. Repman, Jr., has been the custodial father of the minor child, Toby A. Ellis, since he
was one (1) year old.
7. The Plaintiff, Tommy A. Repman, Jr., desires partial custody of said minor child, Toby
A. Ellis, as the parties can agree.
8. The best interests and permanent welfare of the minor children, Isaac N. Repman and
Toby A. Ellis, requires that the Court grant the Plaintiff's request as set forth above.
WHEREFORE, the Plaintiff, Tommy A. Repman, Jr., respectfully requests that he be
awarded primary physical custody and shared legal custody of Isaac N. Repman as provided
herein, with periods of temporary physical custody to Defendant, Brittany L. Ellis, as provided
herein. Plaintiff also respectfully requests that he be awarded temporary physical custody of Toby
A. Ellis as provided herein.
Respectfully submitted,
IRWIN & 1V~KNIGI-~ P.C.
By: ~ ~
Marcu A. McKnig I, Esquire
Attorney for Plaintiff
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Date: June 15, 2010 Supreme Court I. D. No. 25476
4
VERIFICATION
The foregoing document is based upon information, which has been gathered by my
counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section
4904 relating to unsworn falsification to authorities.
~Uv
T MY A. PMAN, JR.
Date: ~ .. `~ ~ ~ ~ Q
•~ > , V
'JUL 0 6 2010
TOMMY A. REPMAN, JR., IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY,
PENNSYLVANIA
v. ,
CASE NO.10-4066
BRITTANY L. ELLIS, .
Defendant :CUSTODY
ORDER
AND NOW, this ~~day of ~ l 2010, upon presentation and
consideration of the attached Stipulation and Agreement and upon agreement of the
parties, it is hereby ordered and decreed that the following stipulation is entered as an
Order effective this date.
4f~
Distribution List:
~azcus A. McKnight, III, Esquire (Attorney for Plaintiff)
Irwin & McKnight, P.C., West Pomfret Professional Building, 60 W. Pomfret Street,
Cazlisle, PA 17013
~heri D. Coover, Esquire (Attorney for Defendant)
44 S. Hanover Street, Carlisle, PA 17013
n
' `'M1cY
_ i __ r
' -{;i~~
~>
~ rrl ~=~
A_ ,~
~r .~