HomeMy WebLinkAbout95-01971
BRIAN E. NOLL,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v,
NO,
TRACEY J. NOLL,
Defendant
CIVIL ACTION - CUSTODY
PETITION FOR SPECIAL RBLIBI
plaintiff by his attorney, Thomas H, Kutz, Esquire,
seek special relief under pennsylvania Rule of Civil procedure
1915,13 and avers as follows:
1. plaintiff Father has a permanent residence of 444
sioux Drive, Mechanicsburg, cumberland county, Pennsylvania.
2. Defendant Mother has a permanent residence of 444
sioux Drive, Mechanicsburg, cumberland county, pennsylvania.
3, The parties are the parents of Brandon E. Noll,
born April 28, 1992.
4, plaintiff and Defendant have resided together with
their son from the time of his birth until the time of the filing
of this petition.
5. Plaintiff and Defendant have been equal caretakers
and nurturing parents for their son.
6. on various occasions during the past several months
Plaintiff and Defendant have experienced marital difficulties.
7, on various occasions during the past several months
Defendant has repeatedly threatened to remove herself and
parties' son from the marital home at 444 souix Drive,
Hechanicsburg to an undisclosed location.
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(2) from october, 1994 to present, at 444 sioux Drive,
Hechanicsburg, cumbsrland county, pennsylvania, with Plaintiff
and Defendant.
The mother of the child is the Defendant, TRACEY J, NOLL
whose current address is 444 sioux Drive. Hechanicsburg,
cumberland County, Pennsylvania, She is presently married to
plaintiff,
The father of the child is the Plaintiff, BRIAN E. NOLL,
whose current address 444 Sioux Drive, Hechanicsburg, Cumberland
county, Pennsylvania, He is presently married to Defendant.
4,
The relationship of Plaintiff to the child is that
father. The Plaintiff currently resides with his
of biological
child.
5, The relationship of Defendant to the child is that
of biological mother, The Defendant currentlY resides at the
marital home with her daughter,
6. plaintiff has not participated as a party or
witness, or in another capacity, in other litigation concerning
the custody of the child in this or another court.
Plaintiff has no information of a custody proceeding
concerning the child pending in a court of this comulonwealth.
plaintiff does 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,
child will be
The best interest and permanent welfare of the
served by granting the relief requested because:
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