HomeMy WebLinkAbout02-3997MARC S. RENAULT and
TARA C. RENAULT,
Plaintiffs
V
KEITH EVERETT YOUNG, SR. and
TOMEKA BRATCHER,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02 - ~qqq CIVIL ACTION- LAW
1N CUSTODY
COMPLAINT
Plaintiffs, Marc S. Renault and Tara C. Renault, by their attorneys, Broujos & Gilroy,
P.C., sets forth the following:
1
Plaintiffs Mark S. Renault and Tara C. Renault are adult individuals residing at 223 South
College Street, Carlisle, Cumberland County, Pennsylvania.
2
Defendant Tomeka Bratcher is an adult individual residing at 1700 North 28th Street,
Philadelphia, Philadelphia County, Pennsylvania 19121.
3
Keith Everett Young, Sr. is an adult individual who's last known mailing address was 446
Freemont Street, Lancaster, Pennsylvania 17604.
4
Defendants are the natural parents of Keith Everett Young, Jr., born October 22, 1989.
5
The minor child Keith Everett Young, Jr. is currently in the physical custody of the
Plaintiffs in that the Defendants have delivered custody of the minor child to them.
6
The Plaintiffs have no blood relationship to the minor child but have been acting as the
minor child's guardians for approximately the past six weeks during which time the minor
child has resided with the Plaintiffs at the current address in Cumberland County.
7
The minor child previously resided with the Defendant Father in the Lancaster area for
approximately 6 months, and prior to that with the Defendants Mother in the Philadelphia
area.
8
The Plaintiffs have not participated as a party or witness, or in any other capacity in any
other litigation concerning the custody of this child.
9
The Plaintiffs have no information of a custody proceeding concerning the child pending in
a court of this Commonwealth or in any other state.
10
The Plaintiffs do not know of a person not a part of this proceeding who has physical
custody of the child or claims to have custody.
11
The best interest of the permanent welfare of the child would be served by granting the
Plaintiffs custody of the child.
12
Each parent who's parental rights to the child have not been terminated and the persons
who have physical custody of the child have been named the parties in this case.
WHEREFORE, Plaintiffs request this Honorable Court to grant them custody of the minor
child Keith Everett Young, Jr.
Respectfully submitted,
H~ Esquire
Attorneyfdr Plaintiffs
Broujo~/& Gilroy, P.C.
4 North Hanover Street
Carlisle, PA 17013
(717) 243-4574
Supreme Court ID No. 29943
MARC S. RENAULT and
TARA C. RENAULT,
Plaintiffs
KEITtl EVERETT VOUNG, SR. and
TOMEKA BRATCHER,
Defendants
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 02-3q~r{ CIVIL ACTION - LAW
: IN CUSTODY
COURT ORDER
l
AND NOW this ~.~"~kclay of August, 2002, upon consideration of the attached Petition
for Emergency Relief, and it appearing that the Defendant Mother Tomeka Bratcher
agrees that the Plaintiffs may have custody of the minor child and it appearing further that
the Defendant Father cannot be located, it is ordered and directed as follows:
Mark S. Renault and Tara C. Renault shall enjoy legal and physical custody of
Keith Everett Young, Jr., born October 22, 1989.
°
The Mother, Tomeka Bratcher, and the Father, Keith Everett Young, Jr., shall
enloy liberal periods of visitation with the minor child at such times as thc parties
agree.
In thc event the Defendant Mother or Defendant Father desires at any point to
have this order modified, either party may petition this court to have the order
modified at which time thc case shall be immediately referred to a custody
conciliator.
Counsel for the Plaintiffs shall serve a copy of this order upon the Defendants by
regular and certified mail at the Defendants last known address.
o
There shall be no requirement for this case to be referred to a conciliator for a
custody conciliation conference unless a party to this action files another petition
requesting such a custody conciliation conference.
BY THE COURT,
I~dga~.- Bayl~y
CC'
Hubert X. Gilroy, Esquire
Tomeka Bratcher
1700 North 28th Street
Philadelphia, PA 19121
Keith Everett Young, Sr.
446 Freemont Street
Lancaster, PA 17604
TRUE COPY FROM RECORD
in Testimom/wh~reoL I here unto set my hand
and the s~sl p1 said Cougar Carlisle. Pa.
MARC S. RENAULT and
TARA C. RENAULT,
Plaintiffs
KEITH EVERETT YOUNG, SR. and
TOMEKA BRATCHER,
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 02- CIVIL ACTION - LAW
: IN CUSTODY
PETITION FOR SPECIAL RELIEF
Petitioners, Marc S. Renault and Tara C. Renault, by their attorneys Broujos & Gilroy,
P.C. set forth the following:
1
Petitioners have filed a custody complaint at the above captioned term and number
seeking Custody of Keith Everett Young, Jr., born October 22, 1989.
Petitioners have physical custody of the minor child and have had physical custody of him
in Cumberland County since on or about July 2, 2002.
3
Physical custody of the minor child was delivered to the Petitioners by the Defendant
parents.
4
Defendant Father, Keith Everett Young, Sr., was incarcerated in Lancaster County and,
despite efforts by the Petitioners, Mr. Young cannot be located at this time.
5
Defendant Mother, Tomeka Bratcher, resides in Philadelphia and has signed a Stipulation
attached hereto and marked Exhibit "A" whereby the Mother agrees that the Petitioners
shall be given custody of the minor child. The Petitioners also joined in that Stipulation.
6
Petitioners need to register the minor child for school and desire an emergency custody
order giving them custody so they may register the minor child for school which they
understood was the intent of the parents at the time custody was delivered.
7
Petitioners request your honorable court to enter an order as attached.
WHEREFORE, Petitioners request your Honorable Court to grant them custody of the
minor child Kejth Everett Young, Jr., born October 22, 1989.
Respectfully submitted,
Broujos & Gilroy, P.C.
4 North Hanover Street
Carlisle, PA 17013
(717) 2434574
Supreme Court ID No. 29943
MARC S. RENAULT and
TARA C. RENAULT,
Plaintiffs
v
KEITH EVERETT YOUNG, SR. and
TOMEKA BRATCHER,
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 02- CIVIL ACTION- LAW
:
: IN CUSTODY
STIPULATION
The parties enter into this Stipulation with respect to the custody of Keith Everett Young,
Jr., born October 22, 1989. The Mother, Tomeka Bratcher, and the Father, Keith Everett
Young, Sr., agree that the attached Order may be signed by the court so that Marc S.
Renault and Tara C. Renault are granted custody of Keith Everett Young, Jr., born
October 22, 1989 subject to the Mother and Father reserving periods of liberal visitation
with the minor child and subject to the parents ability to have this order modified upon
their request.
WITNESS ,.
~6fii~e ka Bratcher /
Date
Keith Everett Young, Sr.
Marc S. RenaUlt ' v
Tar~ C. a
Date
Date
Date