Sample Pleading: Complaint For Custody

*Sample Complaint For Custody (name
redacted):

COMPLAINT FOR CUSTODY

NOW COMES the Plaintiff by his attorney, Todd
W. Elliott, Esquire and files this Complaint for
Custody as follows:

1. Plaintiff is currently resides at 89 Verlest
Lane, Burgettstown, PA 15021, in Washington
County.

2. Defendant currently resides at 750 Route 18,
Aliquippa, PA 15001, in Beaver County.

3. Plaintiff seeks partial custody of the following
child:

Name: Present Residence: Age:
Child, 750 Route 18 4 years.
Aliquippa, PA 15001

The child was born out of wedlock.

The child is presently in the custody of
Defendant, who currently resides at 750 Route
18, Aliquippa, PA 15001, in Beaver County.

During the past five years, the child has resided
with the following persons and at the following
addresses:

Theresa Rattenni, 3828 Green Garden Road
birth to Child, and Aliquippa, PA 15001 10/2004

The mother of the child is the Defendant, who
currently resides at 750 Route 18, Aliquippa, PA
15001, in Beaver County. She is not married to
the Plaintiff.

The father of the child is the Plaintiff, who
currently resides at 89 Verlest Lane,
Burgettstown, PA 15021, in Washington County.
He is not married to the Defendant.

4. The relationship of the Plaintiff to the child is
that of father. The Plaintiff currently resides with
the following persons:

Name: Relationship:

himself.

5. The relationship of the Defendant to the child
is that of mother. The defendant currently resides
with the following persons:

Name: Relationship:

daughter.

6. Plaintiff has not participated as a party or
witness, or in another capacity, in another
litigation concerning the custody of the child in
another court. The court, term and number, and
its relationship to this action is: N/A.

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
the proceedings who has physical custody of the
child or claims custody or visitation rights with
respect to the child.

7. The best interest and permanent welfare of
the child will be served by granting partial
custody of the child to the plaintiff, because the
child should maintain close contact with both
parents.

8. Each parent whose parental rights to the child
have not been terminated and the persons who
have 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 to have a right to custody or visitation of
the child will be given notice of the pendency of
this action and the right to intervene.

NAME: ADDRESS: BASIS OF CLAIM: N/A.

WHEREFORE, Plaintiff respectfully requests the
court to grant partial custody of the child to
Plaintiff.

Respectfully submitted:

Attorney Todd W. Elliott, Esq.