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HomeMy WebLinkAbout94-07141 ---- , , . , 'l.-.:..-_~.,~, RANDI-BRUCE THICKEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94- CIVIL TERM SHALON LEE GHEEN, Defendant CIVIL ACTION - CUSTODY OF MINOR CHILD COMPLAINT FOR CUSTODY OF MINOR CHILD AND NOW, comes the Plaintiff, Randi-Bruce Thickey, by his attorneys, Snelbaker & Brenneman, P. c., who states the following cause of action: 1. The Plaintiff herein is Randi-Bruce Thickey, an adult individual residing at 327 Walnut L~ne, carlisle, Cumberland County, Pennsylvania, 17013. 2. The Defendant herein is Shalon Lee Gheen, an adult individual who resides at 23 West Baltimore street, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff seeks custody of the following child: HAMl:I Slade Alan Thickey PRESENT RESIDENCE 327 Walnut Lane, Carlisle Cumberland County, Pennsylvania 17013 l&E 7+ months Slade Alan Thickey was born out of wedlock. LAW U'''CE6 SNELDAKER Slade Alan Thickey is presently in the custody of Plaintiff . eREr~rIEMAN at his residence as indicated in Paragraph 1, above. LAW O'PICr:S SNEL13AKER o BRENNEMAN 6. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the following persons: NAME RELATIONSHIP Diane Hoffman Aunt of mother 7. Plaintiff has not participated as a party or witness or in any other capacity in other litigation noncerning custody of the child in this or any other court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 8. The best interest and permanent welfare of the child will be served by granting the relief requested because the child needs a permanent and stable home which Plaintiff can and will provide, which is not being provided or can be provided by Defendant. 9. 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. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: None. -3- RANDI-BRUCE TRICKEY, plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . v. : NO. 94- CIVIL TERM . . SHALON LEE GHEEN, Defendant CIVIL ACTION - CUSTODY OF MINOR CHILD COMPLAINT FOR CUSTODY OF MINOR CHILD AND NOW, comes the Plaintiff, Randi-Bruce Thickey, by his attorneys, Snelbaker & Brenneman, P. C., who states the following cause of action: 1. The Plaintiff herein is Randi-Bruce Thickey, an adult individual residing at 327 Walnut Lane, Carlisle, Cumberland county, pennsylvania, 17013. 2. The Defendant herein is Shalon Lee Gheen, an adult individual who resides at 23 West Baltimore street, Carlisle, CUmberland county, Pennsylvania, 17013. 3. plaintiff seeks custody of the following child: HAME PRESENT RESIDENCE Pm: Slade Alan Thickey 327 Walnut Lane, Carlisle Cumberland County, Pennsylvania 17013 7+ months Slade Alan Thickey was born out of wedlock. LAw O,,.CII Thickey is presently SNELilAKER Slade Alan in the custody of Plaintiff ft BRf:UNEMAN at his residence as indicated in Paragraph 1, above. LAW O"ICII SNELlJA.KER 6 BREtlNEMAN 6. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the following persons: r:w.u; RELATIONSHIP Diane lIoffman Aunt of mother 7. Plaintiff has not participated as a party or witness or in any other capacity in other litigation concerning custody of the child in this or any other court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 8. The best interest and permanent welfare of the child will be served by granting the relief requested because the child needs a permanent and stable home which Plaintiff can and will provide, which is not being provided or can be provided by Defendant. 9. 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. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: None. -3- RANDI-BRUCE TRICKEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94- CIVIL TERM SHALON LEE GHEEN, Defendant CIVIL ACTION - CUSTODY OF MINOR CHILD COMPLAINT FOR CUSTODY OF MINOR CHILD AND NOW, comes the Plaintiff, Randi-Bruce Thickey, by his attorneys, Snelbaker & Brenneman, P. C., who states the following cause of action: 1. The Plaintiff herein is Randi-Bruce Thickey, an adult individual residing at 327 Walnut Lane, CarliSle, Cumberland County, Pennsylvania, 17013. 2. The Defendant herein is Shalon Lee Gheen, an adult individual who resides at 23 West Baltimore Street, CarliSle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff seeks custody of the following child: lWm PRESENT RESIDENCE ME Slade Alan Thickey 327 Walnut Lane, Carlisle Cumberland County, Pennsylvania 17013 7+ months Slade Alan Thickey \~as born out of wedlock. LAW o"lcn Slade Alan Thickey is presently in Plaintiff SNEL3AKER the custody of . BAEUNEMAN at his residence as indicated in Paragraph 1, above. LAW' QP'P'ICU SNELDAKER . BRttlNIMAN 6. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the following persons: HAm: RELATIONSHIP Diane Hoffman Aunt of mother 7. Plaintiff has not participated as a party or witness or in any other capacity in other litigation concerning custody of the child in this or any other court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 8. The best interest and permanent welfare of the child will be served by granting the relief requested because the child needs a permanent and stable home which Plaintiff can and will provide, which is not being provided or can be provided by Defendant. 9. 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. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: None. -3-