HomeMy WebLinkAbout01-5316SCOTT CARL,
LORI CARL,
Plaintiff
V.
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
CUSTODY
COMPLAINT FOR CUSTODY
1. The Plaintiff is Scott Carl, social security number 166-684368, who currently
resides at 10 Addams Street, Enola, Cumberland County, Pennsylvania 17025.
2. The Defendant is Lori Carl, social security number 170-70-0045, who currently
resides in Perry County, Pennsylvania with the maternal grandmother at an undisclosed location.
3. Plaintiff seeks custody of the minor child, Mason Carl, age two, who currently
resides with the mother and Maternal Grandmother in Perry County at an undisclosed location.
4. The child was bom out of wedlock.
5. The child is presently in the custody of the Defendant, Lori Carl.
6. During the child's lifetime the child has resided with the following persons and at
the following addresses:
Maternal Grandmother and Perry County, PA Late July 2001 to Present
Lori Carl
Scott and Lori Carl 10 Addams Street Birth to Late July 2001
Enola, PA 17025
The relationship of Plaintiff to the child is that of natural father.
The relationship of Defendant to the child is that of natural mother.
Plaintiff has not participated as a party or wimess, or in another capacity, in other
litigation concerning the custody of the child in this or another court.
10. Plaintiff has no information of a custody proceeding concerning the child pending in
a court of this Commonwealth.
11. 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.
12. The Plaintiff/Father seeks primary custody for the following reasons:
a. The father has been actively involved in raising the child since birth;
b. The father's parents have provided significant assistance in raising the child;
c. The mother has unilaterally terminated any contact with the child as a result
of marital dispute;
13. Each parent whose parental rights to the child have not been terminated and the
person who has physical custody of the child have been named as parties to this action.
WItEREFORE, the Plaintiff, Scott Carl, respectfully requests this Court to grant primary
physical and legal custody of the child to the Plaintiff, or in the alternative, shared custody as
dictated by Court Order.
Respectfully submitted,
Austin F. Groga ~Esq~t{re
Attorney for Plafntiff
24 North 32"~ Street
Camp Hill, PA 17011
(717) 737-1956
ID # 59020
VERIFICATION
I, Scott Carl, verif3, that the statements made in the foregoing Custody Complaint are tree and
correct to the best of my knowledge, information, and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to
authorities.
SCOTT CARL