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CONSTANCE P. BRUNT
AITOR.'/F.Y AT tAW
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RICKY D. TOMJaNSON and . IN THE COURT OF COMMON PLEAS OF
.
LYNDA K. TOMJaNSON, : CUMBERLAND COUNTY, PENNSYLVANIA
.
.
Plaintiff . CIV4 ACTION - LAW
.
v. . &'1 - I ell ;}.
. --
. No. civil ~ ( -4' trlV\-
.
LISA E. TOMJaNSON, .
.
.
.
Defendant . IN CUSTODY
.
ORDER OF COURT
AND NOW, this ~ day of I~}'> J\ \ L-.
, 1994, upon
consideration of the Complaint for Custody and Joinder filed herein,
IT IS HEREBY ORDERED AND DECREED that the Plaintiffs, RICKY D.
TOMKINSON and LYNDA K. TOMKINSON, are granted primary custody of
Justin David Tomkinson, born February 23, 1994.
BY THE COURT:
Ilct-,~I e. ~
J.
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CUMt:., :'.\1,0 C('U~TY
I'EHhYLYA,"A
,
r
RICKY D. TOMJaNSON and
LYNDA K. TOMJaNSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
l}4-,Q I~
No. civil 1994
v.
LISA E. TOMJaNSON r
Defendu.nt
IN CUSTODY
COMPLAINT AND JOINDER TO CONFIRM CUSTODY
AND NOW, come the PlaintiffS, RICKY D. TOMKINSON and LYNDA K.
TOMKINSON, by and through their attorney, CONSTANCE P. BRUNT,
ESQUIRE, and respectfully represent as follows:
1. The Plaintiffs are RICKY D. TOMKINSON and LYNDA K.
TOMKINSON, adults residing at 2010 Lenox Street, Camp Hill,
CUmberland County, Pennsylvania.
2. The Defendant is LISA E. TOMKINSON, a minor child
residing at 2010 Lenox Street, Camp Hill, Cumberland County,
Pennsylvania. She is the daughter of Plaintiffs, RICKY D. TOMKINSON
and LYNDA K. TOMKINSON.
3. The Plaintiffs are seeking custody of the following
child:
~
Residence
~
Justin David Tomkinson
2010 Lenox street
Camp Hill, PA 17011
6 weeks
The child was born out of wedlock.
The child is presently in the custody of the Plaintiffs,
RICKY D. TOMKINSON and LYNDA K. TOMKINSON, and the Defendant, LISA E.
TOMKINSON, who all presently reside at the above address.
Since the child's birth, he has resided with the following
persons at the following addresses:
a. 2/23/94 - Present
2010 Lenox street
Camp Hill, PA 17011
with mother, LISA E. TOMKINSON
and maternal grandparents,
RICKY D. and LYNDA K. TOMKINSON
The mother of the child is Defendant, LISA E. TOMKINSON,
who is the minor daughter of the Plaintiffs and who resides with
them. She is unmarried.
The father of the child is unidentified.
4. The relationship of Plaintiffs, RICKY D. and LYNDA K.
TOMKINSON, to the child is that of maternal grandparents.
5. The relationship of Defendant, LISA E. TOMKINSON, to
the child is that of mother.
6. The Plaintiffs have not participated as a party or
witness or in any other capacity in any other litigation
concerning the custody of the child in this or any other
jurisdiction.
The Plaintiffs have no information of a custody
proceeding concerning the custody of the said child pending in a
court of this Commonwealth or in any other jurisdiction.
The Plaintiffs do 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 parties believe that it is in the best
interests of the subject minor child to be placed in the primary
custody of his maternal grandparents, with whom his mother and he
reside. The mother of the subject child, LISA E. TOMKINSON, is
17 years old and a junior in high school. Further, it is
necessary for the grandparents to be designated as the primary
custodians of the minor child in order to provide medical
insurance coverage for him.
8. Each identified parent whose parental rights of the
child have not been terminated and the person who has physical
custody of the child have been named as parties to this action.
WHEREFORE, the Plaintiffs, RICKY D. TOMKINSON and LYNDA
K. TOMKINSON, respectfully request this Honorable Court to enter
an order, in the proposed form attached hereto, granting primary
custody of the said child to the Plaintiffs, RICKY D. TOMKINSON
and LYNDA R. TOMKINSON.
Respectfully submitted,
DATED: r/,/1'/,
~:~
CONSTANCE P. BRUNT, ESQUIRE
Attorney I.D. #29933
3901 North Front Street
Harrisburg, PA 17110
(717) 232-7200
Attorney for Plaintiffs
VERIFICATION
I verify that the statements made in the foregoing
Complaint to Confirm custody 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.
DATED: 117/1'1
~ D. CT~~
RICKY . TOMKINSON, Plaintiff
:!
Plaintiff
RICKY D. TOMJaNSON and : IN THE COURT OF COMMON PLEAS OF
LYNDA K. TOMJaNSON, . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
plaintiff : CIVIL ACTION - LAW
v. .
.
. No. Civil 1994
.
LISA E. TOMKINSON, :
.
.
Defendant . IN CUSTODY
.
JOINDER
"1.1 12...'0
AND NOW, this ~ day of ~
, 1994, I, LISA
E. TOMKINSON, following review of the attached Complaint do hereby
join in the prayer of the PlaintiffS, RICKY D. TOMKINSON and LYNDA K.
TOMKINSON, and request this Honorable Court to enter an Order
granting primary custody of my minor Child, JUSTIN DAVID TOMKINSON,
to the plaintiffs, RICKY D. TOMKINSON and LYNDA K. TOMKINSON.
.I .-;;-- .
~ 1 rf>>1/~1
LISA E. TOMKINSON, Defendant
SWORN TO AND SUBSCRIBED
before me this 1f"-- day
of ~ ' 1994.
&~-I-
NOTARY PUBLIC
My commission expires:
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