HomeMy WebLinkAbout06-5818
MEREDITH 1. DeWALT,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
NO. 06- 5<6' I <r
CNIL ACTION - LAW
DREW D. DeWALT,
Defendant
IN CUSTODY
PLAINTIFF'S COMPLAINT FOR CUSTODY
1. Plaintiffis an adult individual currently residing at 20 1 Oak Drive, Mt. Holly Springs,
Cumberland County, Pennsylvania.
2. Defendant is an adult individual currently residing at 236 Ridge Hill Road, Mechanicsburg,
Cumberland County, Pennsylvania.
3. Plaintiff seeks custody of the children:
Michaela J. DeWalt - born January 24,2001
Brayden S. T. De Walt - born September 29,2002
Erika E. De Walt - born December 6, 2003
The children were born in wedlock.
4. Since the children's birth, the children have resided with the following persons at the
following addresses for the following periods of time:
The children have resided with the parties at 236 Ridge Hill Road, Mechanicsburg,
P A, since their births. On October 1,2006, the children and the Plaintiff moved
to the Plaintiff's current address.
5. The relationship of the Plaintiff to the children is that of mother. She is married and living
separately. The Plaintiff currently resides with the following:
Name Relationship
Thomas 1. Williams Father
Barbara 1. Williams Mother
Michaela J. DeWalt Daughter
Brayden S.T. DeWalt Son
Erika E. DeWalt Daughter
-
6. The relationship of the Defendant to the children is that offather. He is manied and living
separately. The Defendant currently resides with the following:
Name
Bradley S. DeWalt
RelationshiI2
Son
7. The parties have not participated in previous litigation concerning the custody of the children
in this court or any court.
8. The Plaintiffhas no information of a custody proceeding concerning the children pending
in any other court.
9. The best interest and permanent welfare ofthe children will be served by granting custody
to Plaintiffbecause: she can best provide a stable and nurturing environment for her children.
10. Plaintiff does not know of any person not a party to these proceedings who claims to have
custody or visitation rights with respect to the children.
WHEREFORE, Plaintiff requests your Honorable Court to set a time and place for a hearing at
which Plaintiff requests the Court to grant Plaintiff the Custody Order. Pending said hearing, Plaintiff
requests temporary custody.
MAR1~ORFF WILLIAMS & OITO
By
J ennifl r . Spears, Esquire
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Plaintiff
Date: October 4, 2006
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VERlFICA TrON
The foregoing Complaint fur Custody is based upon infonnation which has been gathered bymy
counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own.
I have read the Complaiut and to the extent that the document is based upon infnonation which I have given
to my counsel, it is true and correct to the best of my knowledge, information and belief To the extent that
the coutent of the document is that of couosel, I have relied upon couosel in making this verificatiou.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to uuswom fulsification to authorities, which provides thatifI make knowingly false avennents, I
may be subject to criminal penalties.
F: \FILESIDA T AFILEIGeneral\Current\ I 0568,2, Cuscom
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Meredith DeWalt
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F: IFILESIDA T AFlLE\Genera~Current\ I 0568, 2, pra
Created 9/20/04 0:06PM
Revised: 10/9/06 242PM
Jennifer L. Spears, Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
J.D. 87445
10 East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Plaintiff
MEREDITHl. DeWALT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 06-5818
CIVIL ACTION - LAW
DREW S. DeWALT,
Defendant
IN CUSTODY
PRAECIPE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please withdraw the custody complaint filed in this matter.
DEARDORFF WILLIAMS & OTTO
By I
J enn fer L. Spears, Esquire
10 East High Street
Carlisle, P A 17013
(717) 243-3341
~
Date: October 9,2006
Attorneys for Plaintiff
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