FORM 5.4 Preliminary Objections to Complaint for Custody

IN THE COURT OF COMMON PLEAS OF

__________________ COUNTY, PENNSYLVANIA

CIVIL ACTION-LAW

PLAINTIFF

CI No. -

vs

DEFENDANT

PRELIMINARY OBJECTIONS TO COMPLAINT FOR

CUSTODY PURSUANT TO PA. R.C.P. 1915.5

AND NOW, Defendant, __________________, files Preliminary Objections to Plaintiff's

Complaint for Custody pursuant to Pa. R.C.P. 1915.5, and in support there of, avers the

following:

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

__________________.

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

_________________.

3. The parties hereto are spouses, having been married on ____ __________, at _ _,

____ ______. [City and State]

4. The parties are the parents of the following minor [child/ children], who currently reside(s) at

__________________ __________________.

5. On __________________, 20______, Defendant was served with a Complaint for Custody

in the above-captioned matter.

6. Defendant believes, and therefore avers, that said Complaint was not brought in a county of

proper venue on the following ground(s):

[state ground(s), examples include the following]

A. The county in which the instant action was brought was not the home county of the

[child/children] at the time of the commencement of the proceeding;

WHEREFORE, Defendant respectfully requests that this Honorable Court enter an Order

granting the Preliminary Objections and dismissing the Complaint.

Respectfully submitted,

Date:______

[Verification]