FORM 5.2 Complaint for Custody

IN THE COURT OF COMMON PLEAS

OF __________________ COUNTY, PENNSYLVANIA

PLAINTIFF : No.

v. :

DEFENDANT

: IN CUSTODY

COMPLAINT FOR

[CUSTODY/PARTIAL CUSTODY/VISITATION]

AND NOW, Plaintiff, by and through [his/her] attorney, __________________, Esquire, files a Complaint for

[Custody/Partial Custody/Visitation] against Defendant, and in support thereof, avers the following:

1. Plaintiff is __________________ [``Mother''/``Father''], who currently resides at __________________.

2. Defendant is __________________ [``Mother''/``Father''], who currently resides at __________________.

3. Plaintiff seeks [custody/partial custody/visitation] of the following [child/children]:

Name(s) Present Address(es) Age(s)

_____________ _____ _____________ _____

_____________ _____ _____________ _____

_____________ _____ _____________ _____

_____________ _____ _____________ _____

____

The [child was/was not] [children were/were not] born out of wedlock.

The [child is/children are] presently in the custody of __________________, who currently resides at

__________________.

During the past five years, the [child/children] resided with the following person(s) and at the following

address(es):

Person(s) Address(es) Date(s)

_____________ _____ _____________ _____

_____________ _____ _____________ _____

The mother of the [child/children] is __________________, who currently resides at __________________.

She is [married/divorced/single].

The father of the [child/children] is __________________, who currently resides at __________________.

He is [married/divorced/single].

4. The relationship of Plaintiff to the [child/children] is that of __________________. Plaintiff currently resides

with the following person(s):

Name(s) Relationship

__________________ __________________

__________________ __________________

__________________ __________________

5. The relationship of Defendant to the [child/children] is that of __________________. Defendant currently

resides with the following person(s):

Name(s) Relationship

__________________ __________________

__________________ __________________

__________________ __________________

6. Plaintiff [has/has not] participated as a party or witness, or in another capacity, in other litigation concerning the

custody of the [child/children] in this or another court. The court, term and number, and its relationship to this action is __________________.

Plaintiff [has/has no] information of a custody proceeding concerning the [child/children] pending in a court of this

Commonwealth. The court, term and number, and its relationship to this action is __________________.

Plaintiff [knows/does not know] of a person not a party to the proceedings who has physical custody of the

[child/children] or claims to have custody or visitation rights with respect to the [child/children]. The name and address of such person is __________________.

7. The best interests and permanent welfare of the [child/children] will be served by granting the relief requested

because [set forth facts showing that the granting of the relief requested will be in the best interests and permanent

welfare of the child/children]: __________________.

8. Each parent whose parental rights to the [child/children] has not been terminated and the person(s) who

[has/have] physical custody of the [child/children] 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/children] will be given notice of the pendency of this action and the right to intervene:

Name(s) Address(es) Basis of Claim

_________________ _ _____________ _____ ___________ _______

_________________ _ _____________ _____ ___________ _______

_________________ _ _____________ _____ ___________ _______

WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order granting [custody/partial

custody/visitation] of the [child/children].

Respectfully submitted,

__________________

, Esquire

Attorney for Plaintiff

[Verification]