HomeMy WebLinkAbout01-5378KEITH D. JOHNSON,
Plaintiff
JOEL N. BRYAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - AT LAW
FOR CUSTODY
COMPLAINT FOR CU~TOD¥
The Plaintiff, Keith D. Johnson, by and through his attorney,
The Law Offices of Patrick F. Lauer, Jr., files this Complaint for
Custody against the Defendant, Joel N. Bryan, and in support
thereof, avers the following:
1. The Plaintiff is Keith
D. Johnson, an adult individual
Fairfield
and the natural Father, who currently resides at 4
Street, Apt. #1, Newville, Cumberland County, Pennsylvania 17241.
2. The Defendant is Joel N. Bryan, an adult individual and
the natural Mother, who currently resides at 224 B Street,
Carlisle, Cumberland County, Pennsylvania 17013.
3. The Plaintiff seeks custody of the following child:
Name Present Residence Age
Jarrod S. Johnson 4 Fairfield Street 5 month
Apt. #1 (March 21, 2001)
Newville, PA 17241
The child was born out of wedlock.
The child is presently in the custody of his mother, Joel N.
Bryan, who resides at 224 B Street, Carlisle, Pennsylvania.
During the past five years, the child resided with the
following persons and at the following addresses:
Name
Joel N. Bryan,
Bill, Heather,
Jules and Harley
Address Dates
224 B Street 3/21/01
Carlisle, PA 17013 9/2/01
Keith D. Johnson 4 Fairfield St., Apt.
Newville, PA 17241
#1 9/2/01 -
present
(birth)
The Father of the child is Keith D. Johnson, currently
residing at 4 Fairfield Street, Apt. #1, Newville, Pennsylvania
17241.
He is single.
The Mother of the child is Joel N. Bryan,
at 224 B Street, Carlisle, Pennsylvania 17013.
She is single.
4. The relationship of the plaintiff to the
natural Father.
persons:
Name
~one
5.
natural Mother.
persons:
Name
Bill
Heather
Jules
currently residing
child is that of
The plaintiff currently resides with the following
Harley
Relationship
The relationship of the defendant to the child is that of
The defendant currently resides with the following
Relationship
Friend
Friend
Friends Child
Friends Child
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
will be served
(a)
(b)
(c)
(d)
best interests and permanent welfare of the child
by granting the relief requested because:
Plaintiff is the natural Father of the child.
Defendant has not made an effort to accommodate
Plaintiff spending time with the child, including
purposely not disclosing to him when she was going
into labor.
Defendant's family lives in the state of Missouri
and defendant has expressed her desire to take
child and move to Missouri.
Plaintiff's parents and Defendant's
live near Plaintiff and have expressed
be an active part of the child's life.
step-mother
a desire to
8. 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. No other persons
are known to have a right to or have claimed to have a right to
custody or visitation of the child.
WHEREFORE, Plaintiff respectfully requests this Honorable
Court to enter an Order granting to him custody of his child.
Date:
Respec
Matthe~
~ J. Eshc~man, Esquire
Law Of 2~ces of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Penns~,lvania 17011-4706
PA Supreme Ct. ID No. 72655
Phone: (717) 763-1800
KEITH D. JOHNSON,
Plaintiff
V.
JOEL N. BRYAN,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: No.
:
: CIVIL ACTION - AT LAW
: FOR CUSTODY
VERIFICATION
I, Keith D. Johnson, state that I am the Plaintiff in the
above-captioned case and that the facts set forth in the above
Complaint for Custody are true and correct to the best of my
knowledge, information, and belief. I realize that false
statements herein are subject to the penalties for unsworn
falsification to authorities under 18 Pa. C.S. § 4940.
Date: g//~, /. Johnson
KEITH D. JOHNSON,
Plair~ff
$OEL N. BRYAN,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 01-5378
CIVIL ACTION - AT LAW - CUSTODY
TO THE PROTHONOTARY:
Kindly mark the above-~oned matte~ settled and dismissed with prejudice.
ysub '
~Ma~w ~Eo~' k~.~eer,
2108 Market Street, Aztec Building
Camp I-Fill, Pennsylvania 170114706
IElq, 72655 Td. (717) 763-1800