HomeMy WebLinkAbout87-0043DOUGLAS M. VARNER,
Plaintiff
V
KATHLENE H. VARNER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. ~3 CIVIL 1987
:
: CUSTODY
:
ORDER
YOU, KATHLENE H. VARNER, Defendant have been sued in court to
obtain custody of Douglas M. Varner, Jr.
You are ordered to appear in person in Courtroom No.
of the Cumberland County Courthouse, Carlisle, Pennsylvania
on the ~o~ day of ~~ , 1987, at ~'~ W.M. for a
hearing.
If you fail to appear as provided by this order, an order for
custody, partial custody or visitation may be entered against
you or the court may issue a warrant for your arrest.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
717 - 249-1133
/ DATE /
BY THE COURT,
DOUGLAS M. VARNER,
Plaintiff
V
KATHLENE H. VARNER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. ~3 CIVIL 1987
:
: CUSTODY
:
COMPLAI~ IN CUSTODY
Plaintiff, Douglas M. Varner, by his attorneys, Broujos,
Gilroy & Houston, P.C., sets forth the following:
1
Plaintiff, Douglas M. Varner, is an adult individual residing
at R.D. 2, Box 112, Shippensburg, Cumberland County,
Pennsylvania.
2
Defendant, Kathlene H. Varner, is an adult individual residing
at 7712 Molly Pitcher Highway, Shippensburg, Franklin County,
Pennsylvania.
3
Plaintiff and Defendant were married on October 18, 1985.
4
Plaintiff and Defendant are the natural parents of Douglas M.
Varner, Jr., born July 28, 1986.
5
Since the minor child's birth, the minor child has resided
with the Plaintiff and Defendant at Plaintiff's current
address of R.D. 2, Box 112, Shippensburg, Pennsylvania along
with the Plaintiff's natural mother, Jennie Carbaugh, the
Plaintiff's stepfather Samuel Carbaugh and Plaintiff's sister
Samantha Carbaugh.
6
On January 1, 1987, Defendant left Plaintiff's home and has
advised the Plaintiff that she does not intend to return.
7
At the time the Defendant left the Plaintiff's home, Defendant
left the minor child with the Plaintiff's mother, Jennie
Carbaugh.
8
Plaintiff's mother Jennie Carbaugh has provided the primary
care for the minor child since the birth of the minor child.
9
Plaintiff has not participated as a party or witness or in any
other capacity in other litigation concerning the custody of
the child in this or in any other court.
10
Plaintiff has no information of a custody proceeding concern-
ing the child pending in a court of this commonwealth.
11
Plaintiff does not know of a person not a party to the pro-
ceedings who has physical custody of the child or claims to
have custody or visitation rights with respect to the child.
12
Each parent whose parental rights to the child have not been
terminated and the person who has physical custody of the
child has been named as parties to this action.
13
The best interest and permanent welfare of the child will be
served by granting the Plaintiff custody of the minor child.
Plaintiff plans to continue the status quo in that Plaintiff's
mother, Jennie Carbaugh, will continue to be the primary care-
taker for the minor child.
WHEREFORE, Plaintiff respectfully requests your Honorable
Court to grant him custody as set forth above.
Hubert X Gil~roy,
Esquire ~.
Attorney for Plaintiff
Broujos, Gilroy & Houston, C.
4 North Hanover Street
Carlisle PA 17013
717-243-4574
COMMONWEALTH OF PENNSYLVANIA :
:
COUNTY OF CUMBERLAND :
I verify that the statements in the foregoing pleading are
true and correct. I understand that false statements herein
are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DOUGLAS M. VARNER
DOUGLAS M. VARNER,
Plaintiff
V
KATHLENE H. VARNER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. ~ CIVIL 1987
:
: CUSTODY
:
COMPLAINT IN CUSTODY
Plaintiff, Douglas M. Varner, by his attorneys, Broujos,
Gilroy & Houston, P.C., sets forth the following:
1
Plaintiff, Douglas M. Varner, is an adult individual residing
at R.D. 2, Box 112, Shippensburg, Cumberland County,
Pennsylvania.
2
Defendant, Kathlene H. Varner, is an adult individual residing
at 7712 Molly Pitcher Highway, Shippensburg, Franklin County,
Pennsylvania.
3
Plaintiff and Defendant were married on October 18, 1985.
4
Plaintiff and Defendant are the natural parents of Douglas M.
Varner, Jr., born July 28, 1986.
5
Since the minor child's birth, the minor child has resided
with the Plaintiff and Defendant at Plaintiff's current
address of R.D. 2, Box 112, Shippensburg, Pennsylvania along
with the Plaintiff's natural mother, Jennie Carbaugh, the
Plaintiff's stepfather Samuel Carbaugh and Plaintiff's sister
Samantha Carbaugh.
6
On January 1, 1987, Defendant left Plaintiff's home and has
advised the Plaintiff that she does not intend to return.
7
At the time the Defendant left the Plaintiff's home, Defendant
left the minor child with the Plaintiff's mother, Jennie
Carbaugh.
8
Plaintiff's mother Jennie Carbaugh has provided the primary
care for the minor child since the birth of the minor child.
9
Plaintiff has not participated as a party or witness or in any
other capacity in other litigation concerning the custody of
the child in this or in any other court.
10
Plaintiff has no information of a custody proceeding concern-
ing the child pending in a court of this commonwealth.
11
Plaintiff does not know of a person not a party to the pro-
ceedings who has physical custody of the child or claims to
have custody or visitation rights with respect to the child.
12
Each parent whose parental rights to the child have not been
terminated and the person who has physical custody of the
child has been named as parties to this action.
13
The best interest and permanent welfare of the child will be
served by granting the Plaintiff custody of the minor child.
Plaintiff plans to continue the status quo in that Plaintiff's
mother, Jennie Carbaugh, will continue to be the primary care-
taker for the minor child.
WHEREFORE, Plaintiff respectfully requests your Honorable
Court to grant him custody as set forth above.
Hubert X. GiTroy, Esquire
Attorney for Plaintiff
Broujos, Gilroy & Houston,
4 North Hanover Street
Carlisle PA 17013
717-243-4574