HomeMy WebLinkAbout96-05255
}
..
'"
"
-
....
~
~
'v,
"'1
.. '"'
'.. '^
., ..,
I
!
!
t
...t
0-
.~
:;
ii,
"'.'
ROBEaT L. aINOLIa, JR., I IN THB COURT 0.. COMMON PLUS
I CUMBERLAND cowrn, PEnSYLVAIIIA
PlaiDUff I
I
Y. . NO. 96- 5:155 CIVIL TERM
.
I
OIORODI M. POTICHlR, . CIVIL ACTION - LAN
.
I
Defen4&1l~ I CUSTODY ACTION
ORDIR 0.. COURT
AID ION, upon consideration of the attached complaint, it is
the parties and their respective counsel
hereby directed that
appear before 0, """
55.-..,1"",
,
~" Lu M....,f\ "i1 ~1,~(.\C.~1\~' !lj,~""-:J on the
;'>'1'" day of _fYt \"."1 , 1996, at q.CD /L.N., for a Pre-Hearing
. ESQuire,
the Conciliator, at
Custody Conference. At such conference, an effort will be _de to
resolve the iSBues in dispute; or if this caIlIlot be accomplished,
to define and narrow the iasues to be heard by the court, and to
en~er into a tuporary order. Either party I14Y bring the child who
is the subject of this custody action to the conference, but the
children's .~tendance 1s not ~nd.tory. Failure to appear at the
conference ..y provide ground. for elltry of a t-.porary or
perll8Den~ order.
ror}he Court
_Lr .....It....~..l d......A;."A ~. I
V.
",..,,11. ,)
o. ".. I
YOU IJIOUU) TAD 'nIlS 'APIIl TO 'fOO1l LAN'lD AT ~. If YOU DO
lOT Oft .l LANYU OIl CJ~ An'ORD 0111, 00 TO OIl nLlnon TU
OffICI 1ft I'OITII ULOW TO rum out walal YOU CAlI caT LlO.lL DLP.
orF tCl or ftII COOat AJ)M 1.1 STlATOIl
COURUlOUSl, U'tI fLOOfl
CAlLlSLI, PA 11011
e'l') 2&0-6200 err 1200
ROBERT L. RIHOLBR, JR. : IX THB COURT OF COMNOH PLEAS
: CUMBBRLAJlD COUIITY, PIDDISn.VAlfIA
Plaintiff :
: 96-5~55 CIVIL URM
v. : HO.
:
OBORGDB M. POTICHBR, : CIVIL ACTION - LAN
.
.
Defendut . CUSTODY ACTIOJI
.
CUSTODY COMPLAIIIT
TO THB IIOIIC,\DallLB JUDGES OF SAID COURT:
1. The Plaintiff is Robert L. Ringler, 3r. who resides at
417 Lafayette Street, Enola, Cumberland County, Pennsylvania 17025.
2. The Defendant is Georgene M. Poticher, whose last know
addre.. is 301 Walnut Lane, Carlisle, Pennsylvania 17013.
3. Plaintiff seeks joint legal custody and periocla of
partial physical custody of the following child:
UII
--D'l' --IDDCB
Rlcol. Mari. Poticber
]01 Walnut Lane
IlGI
1/3/86
Carlisle, PA 17013
Th. child was born out of wec:tlock.
The child is presently in the physical custody of Ceorv-- N.
Potlcber at 301 Walnut Lane, Carlisle, PA 17013.
During the past year, the child has resided with the following
persons and at the following addresses:
Per.on.
Mother & second
child
Mother & Boyfriend
& second child
Addr.....
301 Walnut Lane
Carlisle, PA 17013
301 Walnut Lane
Carlisle, PA 17013
Date.
1/96 - present
unknown
The moth.r of the child is Georgene M. Poticher, who
currently i. living at 301 Walnut Lane, Carlisle, Pennsylvania.
She ie .ingle.
Th. fath.r of the child is Robert L. Ringler, Jr. who
reside. at 417 Latay.tte Street, Enola, Pennsylvania.
H. ie single.
4. Th. relation.hip of Plaintiff to the child is that of
fath.r. The Plaintiff currently resides with tbe following
persons:
...
Arlene' Robert Sr., Ringler
..bUon.hlp
Parents
5. The relationship of Defendant to the child i. that of
~tber. The Defendant currently re.ides with the following
person.:
...
UftItnown
"laU_.hl,
Second child
6. .eitber party u. participated .. e party or WitD....
or 1n another capac1ty, 1n other litigation concern1ft9 the
cu.tody of tbe cbild 1n tb1. or uotber court.
2
Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the child or claims to
bave custody or visitation rights with respect to the child.
7. The best interest and permanent welfare of the child
will be served by granting the relief requested because:
A. Plaintiff wishes to participate in the primary
care of the child throughout her life.
B. plaintiff can provide a stable environment.
C. plaintiff can provide a loving home.
D. Defendant has refused to allow Plaintiff regular
times of partial custody with his daughter.
8. Each parent whose parental rights to the child has not
been terminated and the person who has physical custody of the
child has been named as parties to this action.
NBIRIPORB, Plaintiff requests this Honorable Court to
grant him shared legal and liberal periods of partial physical
custody of his child at specific times consistent with his work
schedule.
_ Respectfully aubaitted,
--,'
Michael I. Travis
10 177399
2 I. MaiD Street
Shlreunatown, PA 17011
(717) 1]1-1461
rax 161-1914
)
>;0:}~~!;{'~~~~\~7~
"'_f'
'.
,
ROBERT L. RINGLER, JR., : IN THE <XIURT OF ~ PLEAS OF
Plaintiff . CUMBERLAND COUNTlC, PENNSYLVANIA
.
:
VS. . NO. 96-5255 CIVIL TERM
.
.
.
GfXlRGENE M. POl'ICIIER, : CIVIL ACTION - LAW
Defendant . IN CUS'roOy
.
aulI!R (p CDm'
MID tot, this U ~y of , 1996, upon
consideration of the at~CUstody Cone it is ordered
and directed as follows:
l. The Mother, Georgene M. Poticher, and the Father, Robert L.
RiB3ler, Jr. , shall have shared legal custody of Nicole Marie Poticher,
born January 3, 1986.
2. The Mother shall have pt"imary physical custody of the Olild.
3. The Father shall have partial physical custody of the Olild on the
followiB3 Saturdays fran 11:00 a.m. until 5:00 p.m.: Noveat:ler 2, 1996,
NoYeIltler 16, 1996 and Noventler 30, 1996. Thereafter, beginniB3 OeoelItler
13, 1996, the Father shall have custody of the Olild on alternatiB3
weekends from Friday at 7:00 p.m. t.hrou9h Sunday at 2:00 p.m.
4. 'l'he Father shall have custody of the Olild on holidays u follows:
A. !wry '1'Ilanka9iviB3 Day from 10:00 a.m. until 3:00 p.m.
B. Every Olrietmas Day fran 3:00 p.ll. until 8100 p.ll.
c. Every faater Sunday fran 8:00 a.lI. until 1:00 p.m.
D. Every father'. Day.
5. TIle I'IotIlotr: shall haw custody of the Olild every yNr on MOther'.
Illy.
6. 'l'he Fathel: shall haft cuetody of the Olild on ,.....i.l DIIy llI1d
f..IIbcc DIIy in __ IUItlecId yeara llI1d on July .cth in odd ~ed )'HI'I.
The Mothec' 8hall haw cuatody of the Child on fIlewxial Day llI1d t.abol- DIIy in
odd rut.-.d yMn and on July .cth in _ nUltland yeara.
1. Tht Fat.hK Ilhall haft custody of the Child WriB3 the IlDlth of
AIqJe~ in every yNr, .~ thet the Child w11 be ntt1.1rMd to the
~'. cuatody at 'ewt tnn. "'yt prior to the ~iMitq of the lllI:hool
}'Mt'. 'h MJ.... n11 haw . ....,.,Ird fiH'lod of cuatcdy 'lUll the Chtld
.
ROBERT L. RINGLER, JR., . IN THE <XIURT OF ~ PLEAS OF
.
Plaintiff . CUMBERLAND COUNTlC, PENNSYLVANIA
.
.
.
VS. . NO. 96-5255 CIVIL TERM
.
.
.
GEXlRGENE M. POl'IOlER, . CIVIL ACTION - LAW
.
Defendant . IN CUSTODY
.
0lS'l'00Y <XH:lLIA'l'ICIf SlRlARY RF.P(RT
IN AaDU:lt\HCB wrra ~ CXUft.'lt RllLB (P CIVIL I'R(. .... 'RB
1915.3-8, the undersigned CUstody Conciliator submits the followiB3 report:
1. The pertinent information concerniB3 the Olild who is the subject
of this litigation is as follows:
MMB
BIR1'HDAm
aJlRBN'1'LY IN Q,,$:lu.lX (P
Nicole Marie Poticher
January 3, 1986
Defendant/l'lother
2. A Conciliation Conference was held on October 29, 1996, with the
followiB3 individuals in attendance: The Father, Robert L. RiB3ler, Jr.,
with his counsel, Itichael Travis, Ellquire. Although the I'lother did not
attend the Conciliation Conference, the Father's counsel stated that she
had contacted his office pt"ior to the Conference to explain her proposal
for partial custody. The Mother is not r9pt"9S8flted by counsel.
3. The Father's position on custody is as follows: The Father stated
that the parties never married and separated pt"ior to the Olild's birth.
The Father indicated that the I'lother had brought the Olild to see him over
holidays and on weekends before the Father went into the Arrrrf. AccordiB3
to the FatMr, about four years ago, the Mother stowed bciB3iB3 the Olild
to see him and the lut time the FatheC' saw the Ollld was at Olristlllils time
about two years ago. The Father stated that he had spoken with the Olild
on tM tel~1lI a couple of times this year. The Father feels this lack
of nqular contact with tM Ollld OYer the put four years resulted from
the Mother'a uncoopIIraUveneaa and failure to suwort the relationship
bet_ him and hia now ten year old daughter. In any event, the rather
_Ita to have a reqular partial custody acMc1.II. whereby ha can eeUblillh
his relationship with Nicole. The Father indicated hia williD:JnHa to
cooperate with the MotheC' in following an QB30ing custody ~t.
~ile the Father was ~r to eUblish an alternatiB3 weekend custody
8d'Iedule AS 110OI'I as possible, ha understood the i~ of ~ing a
custOOy schadd. gnduaUy and with flexibility in ordtr to Mtve the
Child'. beet interut in the pcoceu.
4. The te('llll of . \.C op::.e'ld CUstody Ccdltr were establlahed at the
Conf.~ in the 111" ,tIC>> of the !'lot.her. The Cl:Jnc:iliatOl" dillCU8Md the
~.ed custody ~u with the MothK by tel~..... on the day
following the OonfenPl'lC'lt and the I'lother 119~ to entry of an ~