HomeMy WebLinkAbout94-00072
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unl M. FILl: AAd
c.'IIEJl.YL A. SMI'llI,
plaintitf,
I IN 'mI axJR'1' or ~ PIW or
, CUMBlJUJ\ND CXlM1'Y, PDlNSYL~IA
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CIVIL ACTION - LAW
00. 7,), CIVIL 199t'
MICHELLI!: 1Mtf,
Detendant
IN CUS'lOOY
CXJoIPLAINr FOR CUS'J:OOY
1. Plaintiffs a~e LEON M. FILE, natural tat her and CHERYL A.
SMI'llI, paternal grAlldrother adult indlviduals, currently residing at 900 South
Humor Street, Enola, Pennsylvania, 17025.
2. Defendant is MICHELIE HlMI, an adult individual whoee preeent
rseidence is unknown.
3. Plaintiffs seeks custody of the following child: ZACHARY
MICHAEL FILE, age 2.
The child was born out of wedlock.
The child is presently in the custody of LEON M. rILE and CHERYL
A. SMI'llI the nAtural father and paternal grAlldrother, who resides at 900 South
Humor Street, EnoJ.a, Pennsylvania, 17025.
txIring the past five years, or !Iince the child' 9 birth, the child
has resided with the following parsons at the following addresses:
(a) Cheryl A. Smith, Mary File, paternal great-gr8l'llirother,
Richard File, paternal grand uncle and U!On File, at 900 South H\lIOOr Street,
Enola, Pennsylvania, 17025.
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(b) From birth until November, 1992, Zachary lived at several
different locatione wi.th his lllltural ITOther, Michelle Humn.
The nAtural ITOther of the child is MICHELLE 1Mtf, whose current
residence is unknown.
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She is not J1wu:ried.
Thll natural father of the child is I.iXl'l FlIE, curnntly re.id.I..nq
at 900 South Humor Street, Enola, Pennsylvania, 17025,
He is not rrarried.
4. The relationship of the Plaintiffs to the child are natural
father and paternal grandrother. The plaintiffs currently resides with the
following parsons:
(a) Cheryl A, Smith, Loon M. File, Maxy File, Richard File,
Zachary File;
5. The relationship of the Defendant to the ch.\.1d is that of
natural rrother. The Defendant' e current residence and parsons that she
resides with are unknown,
6. Plaintiffs have not participated as a party or witneslll, or in
any other capacity in other litigation, concerning the custody of the children
in t,his Ot' in any other Court.
Plaintiffs have no information of. a custody proceeding concerning
the child pending in a court of this Cat1OOnwealth.
Plaintiffs do not know of a person not a party to the proceeciin9B
who has physical custody of the child oc claims to have custody or visitation
righte with respect to the child.
7. The best interest and parmanent welfare of the child will be
served by granting the relief requested because:
(4) for 4 period in excess of a year the child has been raised by
hj,s paternal granarother !lI\d father,
(b) the natural rother h8l!l I11llintained contact with her child and
calls weekly and exercJ.ges part.lal physical custody once or twice a ronth
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