HomeMy WebLinkAbout95-05573
JOHN D. FARNBR, I IN THB COURT OF COMMON PLBAS OF
Plaintiff I CUMBBRLAND COUNTY, PENNSYLVANIA
I No. 'n-, ~'I"'J Ct~ 7j.-
vs. I
I
IRENE R.M. SMITH, I CIVIL ACTION - AT LAW
Defendant I CUSTODY
COMPLAINT FOR CUSTODY
The Plaintiff, John D. Farner, through his attorneys, Ths Law
Offices of Patrick F. Lauer, Jr., files this Complaint for Custody
against the Defendant, Irene R.M. Smith, and in support thereof,
avers the followingl
1. The Plaintiff is John D. Farner, an adult individual and
the natural Father, who currently resides at 43 Peachy Ann Drive,
Newville, Cumberland County, Pennsylvania 17241.
2. Ths Defendant is Irene R.M. Smith, an adult individual and
the natural Mother, whose current whereabouts are unknown.
3. The Plaintiff seeks custody of the following child I
tiAIn!!.
Tammy Jo Smith
Present Address
Unknown
&u!.
14
(Dec. 6, 1980)
The ohild wae born out of wedlock.
The ohild is presently in the custody of Irene R.M. Smith,
whose current whereabouts are unknown.
4. During the past five years, the child resided with the
following persons and at the following addresses I
H.!In2
Address
Dates
John D. Farner and
Irene R.M. Smith
Irene R.M. Smith
and others?
Lees Cross Roads
Cumberland County
Whereabouts
Unknown
until
1991
since
1991
The Father of the child is John D. Farner, who currently
resides at 43 Peachy Ann Drive, Newville, Cumberland County,
Pennsylvania 17241.
The Mother of the child is Irene R.M. Smith, whose current
whereabouts are unknown.
The Father is currently single. The Mother's marital status
is unknown.
5. The Plaintiff has not participated as a party or witness,
or in another capacity, in any other litigation concerning the
custody of the child in this or another court.
The Plaintiff has no information of a custody proceeding
concerning the child currently pending in any court of this
Commonwealth.
The Plaintiff does not know of a person not a party to theDe
proceedings, who has physical custody of the children or claims to
have physical custody or visitation rights with respect to the
children.
6. The best interests and permanent welfare of the child will
be served by granting the relief requested because I
a). The Plaintiff can provide the child with a home
with adequate moral, emotional, and physical surroundings
as required to meet the child's needs I
b). The Mother has refused, without reason, to
permit the Plaintiff visitation with his daughter.
c) .The child should be permitted to enjoy the love,
affection, teachings, and experience offered by her fatherl
7. Each parent whose parental rights to the child have not
been terminated and the person who has physical custody of the
children have been named as parties to this action. All other
persons, namsd 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 I
lilll!m
Address
Basis of Claim
NONE
WHEREFORE, the Plaintiff respectfully requests that this
Honorable Court enter an Order granting oustody, partial custody,
or visitation of the child to the Petitioner and natural Father,
John O. Farner.
Date I \\l\\l,\~o)'
,",~bmitt.d'
Matthew J. shelman, Esquire
Law Office of Patrick F. Lauer, Jr.
2108 Harke. Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
10* 72655 Tel. (717) 763-1800
JOHN D. FARNER, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
VS. I No.
I
IRENE R.M. SMITH, I CIVIL ACTION - AT LAW
Defendant I CUSTODY
VERIFICATION
I, John D. Farner, state that I am the Plaintiff in the
above-captioned case and that the facts set forth in the above
Custody Complaint are true and correct to the best of my
knowledge, information, and belief.
I realize that false
statements herein are subject to the penalties for unsworn
falsification to authorities under 18 Pa. C.S. S 4940.
~()~- --
ohn O. Farner
Datel 10-)6-/195
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