FORM 5.12 Petition to Modify Order of Custody [Relocation]

IN THE COURT OF COMMON PLEAS

OF __________________ COUNTY, PENNSYLVANIA

PLAINTIFF : No.

v. :

DEFENDANT

: IN CUSTODY

PETITION TO MODIFY ORDER OF CUSTODY

Plaintiff, by and through his/her attorney, __________________, Esquire, files a Petition to Modify Order of

Custody, and in support thereof, avers as follows:

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

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

3. The parties hereto are the parents of the following minor [child/children]: __________________, who currently

reside(s) at __________________.

4. On __________________, 20______, the Court entered an Order of Custody, granting Plaintiff primary physical

and legal custody of the parties' [child/children], and granting Defendant partial physical custody of the parties'

[child/children]. A true and correct copy of this Order is marked Exhibit ``A,'' and attached hereto and made part thereof.

5. Plaintiff intends to relocate with the [child/children] outside the jurisdiction of this Court [state specifics as to proposed timing and location].

6. Plaintiff considers [himself/herself] to be living in an environment surrounded by people [he/she] knows solely through his/her] now-estranged spouse. Plaintiff has no close friends or family in the area, and Plaintiff is experiencing considerable feelings of loneliness due to [his/her] isolation from friends and family [provide details].

7. Plaintiff's intended move will allow [him/her] to re-establish a network of family and friends.

8. Plaintiff's desire to move is motivated by the need for security and support from family and friends.

9. Plaintiff has secured gainful employment [provide details].

10. Plaintiff has located appropriate housing, and has determined that there are appropriate schools for the [child/children].

11. Plaintiff intends to remarry and his/her new spouse is employed outside the jurisdiction.

12. Plaintiff's intended move with the [child/children] will substantially enhance the quality of [his/her] life and that of [his/her] [child/children].

13. Plaintiff is not seeking to deny Defendant access to the [child/children] or to interfere with [his/her] relationship with the [child/children].

14. Plaintiff recognizes that as a result of the move, a modified partial custody schedule is necessary.

15. The best interests and welfare of the [child/children] will be served by a modification of the Court's Order.

WHEREFORE, Plaintiff respectfully requests that this Honorable Court modify its Order as follows: (specify requested modification)

Respectfully submitted,

__________________

, Your Name

Date:______

[Verification]