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The relationship of the Plaintiffs to the child is that of
custodial parents. the Plaintiffs currently reside with the
child.
5. The relationship of the Defendant to the child 15 that
of mother. she currently resides with Dawn Woof.
6. The Plaintiffs have not participated as a party or
witness, or in another capacity, in other litigation concerning
the custody of the child in this or in another court.
The Plaintiffs have no information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
Plaintiffs do not know of a person not a party to these
proceedings who has physical custody of the child or who claims
to have custody or visitation rights with respect to the child.
7. The best interest and permanent welfare of the child
will be served by confirming in Plaintiff custody of the child
because Plaintiffs can better care for the child and provide a
suitable environment for the child,
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, except for the
father of the child whose identity remains unknown.
WHEREFORE, Plaintiffs request the court to grant to
Plaintiffs custody of the child.
Respectfully submitted
~ L{iif,~ -
CHARLES E. Petr e
3529 Brisban Street
Harrisburg, PA 17111
(717) 561-1939
remain unknown to Affiant also attended the party. Affiant
became heavily intoxicated and engaged in sexual relations with
an unknown male at the party, Affiant did not leave the party
prior to engaging in sexuql relations with the unknown male.
Affiant did not discover her pregnancy until several weeks later,
at which it was too late to obtain a list of the male party
attendees.
IN WITNESS WHEREOF, I have hereunto set my hand and seal
this 25th day of August, 1994.
-..4 A 1<' ~- tin .:;6( ....-zt' .... ~~J
BR'riiOA K. NT;;WMAN'
SWORN AND SUBSCRIBED
BEFORE ME this 25th
day of AUGUST, 1994.
~ (];J,/
UBLIC
NOT AGIAL SEAL
KELLY Ft PEn~lE. Netllr,! PublIc
P[t"!~MO eO'J. C.)'Jf~n,(! c.)U'~1'1
My C<)mrrHiJ!IC" !!'L.~~:' ..',If' ;:7 1IN7