HomeMy WebLinkAbout94-06761
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Defendant and Luling, Texas 1989 to
Sherri Edwards 10/12/92
(defendant's wife)
Defendant Lul ing, Texas 10/12/92 to
6/93
Defendant, Ruth Bastrop, Texas 6/93 to
and Charles 6/94
Edwards (Defendant's
parents)
Plaintiff, 1011 Harrisburg pike 6/94 to
Defendant, and Apartment A 11/12/94
Alison Clair Carlisle, PA
(plaintiff's
daughter)
Plaintiff and 1011 Harrisburg Pike 11/12/94 to
Alison Clair Apartment A present
Carl isle, PA
The mother of the children died on October 12, 1992.
The plaintiff currently resides at 1011 Harrisburg Pike,
Apartment A, Carlisle, Pennsylvania.
She is married but has filed for divorce and expects the
divorce to be finalized in the near future.
The father of the children is currently incarcerated in the
Cumberland County Prison, Carlisle, Pennsylvania.
He is a widower.
4. The plaintiff stood in the place of the children's
mother since June 1994. The plaintiff currently resides with the
fOllowing persons:
N~mQ
Alison Clair
Miranda Edwards
Delinda Edwards
Rebecca Edwards
R~l~~j~n~h1p.
daughter
dependent
dependent
dependent
5. The relationship of defendant to the children is that of
father. The defendant is currently incarcerated in Cumberland
County Prison. Carlisle, Pennsylvania.
6. The plaintiff has not participated as a party or
witness, or in another capacity, in other litigation concerning
the custody of the children in this or another court.
7. The plaintiff has no information of a custody proceeding
concerning the children pending in this or any other court
8. The plaintiff does not know of a person not a party to
the proceedings who has physical custody of the children or
claims to have custody or visitation rights with respect to the
children.
9. The best interest and permanent welfare of the children
will be served by granting the relief requested because she is
the best person to make sure that the father has access to tho
children and she want to provide stability for the children.
10. The father's parental rights to the children have not
been terminated and the person who has physical custody of the
children has been named a party to this action.
WHEREFORE, the plaintiff requests this Court to grant
primary physical custody of the children to the plaintiff with