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Home My WebLink About00-02109 :- ..,.-~~ i.. I - > m,~" SHERIFF'S RETURN - REGULAR CASE NO: 2000-02109 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BOTTS CHARLES E VS SCOTT SUSAN E BOTTS BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - CUSTODY was served upon BOTTS SCOTT SUSAN E the DEFENDANT , at 0020:24 HOURS, on the 12th day of April 2000 at CUMBERLAND COUNTY PRISON 1101 CLAREMONT ROAD CARLISLE, PA 17013 by handing to I !; SUSAN E. BOTTS-SCOTT a true and attested copy of COMPLAINT - CUSTODY together with ORDER OF COURT and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.10 .00 10.00 .00 31.10 ~~,t:~ R. Thomas Kline Sworn and Subscribed to before 04/13/2000 . BARBARA SUM~mN ~ By: 11 , , Deputy Sherlff me this /!?~ day of ()~.;Lbv-U A.D. UC) . .,... 0, ~Lli,./. A!I~ Prothonotary I '>~--'IH__""~' ~-- ^__,'__'~..' _ ,0'""'," '. ,. ~,__... ,_ '_"''''_~,' ~"~"~,.'-",-,'''''"-,O'.;W..,'' rP"",~_,."".", ""-"'iii',; v. CIVIL ACTION - CUSTODY I a' I f i , ~ f i ! ! M ! " i I ! I CHARLES E. BOTTS Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA SUSAN E. BOTTS SCOTT, Defendant : NO. 60 - ./(t09 CI<J:L ~>'l ORDER OF COURT AND NOW, this t/" day of ~ 2000, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before PtlrvAJ 5. 5vAJDlly fs'l' , the conciliator, at ~1 IAJ JlAJ'r/IJ 5 r: ;tlEcHA/J, (Sb~ , on the ~day of ~ ' 2000, at ~ t.M. for a Prehe . g Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children five or older may all be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: ~ I i I BY: 7J1ll4lP >- <;;,...~A'f F.,~ Custody Conciliator (~ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, FOURTH FLOOR CARLISLE, PA 17013 (717) 240-6200 a '''C.,'.', .1;-' '''~'''''-''",'~,,";::d-''.lC-''-,h''-.;j;'.~~'L'~' '",,' " ',~ "', ;,~c.-_..,,,,,,-,_;;,~,~:;,,,.,,,,,."<n~' ., " ,. ~~ b ~ ~-rl?' ~ (/0';/-/1' ,--J:& ~ ~ ~&, ~CJ-JJ:h- ~-~p '~~ ~~,nJ 071lff \lINVf\:lASNN3d ~, , ~I '~"V,,"" II~JnrlrJ' ''"::' '.+',,' " ".; I\J. ! \',~ ,_ ....1 ,,' .~,--, "'i"' .-" I" I i. \ld~ 00 I!(.. Ov :,;,0 a :.10 )~]L"", "'l-'",.;,','\_"Y," _ ,,,n ,..",<, " "~,,_, . "'~,' ,_," "" "",,',>,-"',,' ,," ~, ~,~, . ~ R .' ...... .. .... ,.. . '''.- ..,' -~ -,-- ';."- ., --~'.. ,,, .-", '~ "~"",""'-- -e"-. ,,",." . ,~'~. -,--- '.""',_"""~,,,,,c,,, '""_~,~" ,0-""", C'", '"~, '" . ,_ ~i:;i I'". l' ~~ ~ Icr.,. !i ~ !,;!, \~ ~f r,i i ~ h~ !~ 11 ! 'f ..','. ~i... , I , Ie I~ f ~.;.'. t~, if ~.'..' ~ ~".. ~ ~ ~ '1 i CHARLES E. BOTTS Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANlA v. CIVIL ACTION - CUSTODY SUSAN E. BOTTS SCOTT , Defendant NO. (}1.) - oZlo'1 ~ /~ COMPLAINT FOR CUSTODY 1. Plaintiff is CHARLES E. BOTTS, who is presently residing at 312 S. State Road, Marysville, Perry County, Pennsylvania 17053. 2. Defendant is SUSAN E. BOTTS SCOTT, is presently incarcerated Cumberland i , County Prison, but whose home address is 404 Walnut Street, Boiling Springs, Cumberland County, 'j i pennsylvania 17007. " R 3. Plaintiff seeks shared legal custody and partial physical custody ofthe following child: NAME ADDRESS DOB Cheri Lee Botts 404 Walnut Street Boiling Springs, PA 5/6/86 , , ~ The child was not born out of wedlock. The child has not lived in Dauphin County since 1994. It is unknown as to who presently has custody of the child. Father believes that the child is presently residing at 404 Walnut Street, Boiling Springs, Cumberland County, Pennsylvania. ~j . ,,-, ~ ;,- ," ~",,,,;; "..,,;.,, I~--",.""",>,,,,,,; ,,'~___, ""f~:';,,,,-,___,-_,,,,,,,,,,,,",. ""~" ,."_''ii;"-'~5_<c-,,,, "':~<r';""I" "~<=~' ~,~:: I" I: " W1 " I !~ k( During the past five (5) years, the child has resided with the following persons and at the following addresses: PERSONS ADDRESSES DATES Mother and Boy Friend, Mike 404 Walnut Street Boiling Springs, P A 1999 to Present Mother and Michael Scott 16 East Hunter Road Carlisle, P A ~: fi I ]997 to 1999 . I; Father and Sandra J. Botts 7 A Suzanne Drive Duncannon, P A 1994 to 1997 ,. i '!-~ w ~ The mother of the child is Susan E. Botts Scott, who is presently incarcerated at Cumberland , ,. "1 'I ~ ::1 " r" ,9 II !I ~ II II County Prison but whose home address is 404 Walnut Street, Boiling Springs, Cumberland County, Pennsylvania 17007. The Father of the child is Charles E. Botts, currently residing at 312 S. State Road, Marysville, Perry County, Pennsylvania 17053. The parties were divorced from each other. I 4. The relationship of the Plaintiff to that of the child is that of Father and resides with the following persons: NAME RELATIONSHIP Sandra J. Botts Spouse 5. The relationship of the Defendant to the child is that of Mother. Defendant is currently -2- c, ,',..... ~ "', =",,,,, I~_', , , ,,-;.,~ " ,,'~ k' ,'- -"O>"""-i'''_<<''k''~''''';,.l'o'l-;''~i~~W-~-',.,;:-,-_,^" ',,,-"_"- i..;--~t: ,,'t,'.-, -. incarcerated in Cumberland County Prison. When she is home, she resides with the following persons: NAME RELATIONSHIP Mike Cheri Lee Botts Boy Friend of Defendant Parties' daughter 6. Mother is presently incarcerated in Cumberland County Prison for DUI offenses, Father has no exact knowledge as to how long she will be incarcerated but believes it will be to may, 2000. 7. From August of1993 until August of 1997, Father had primary custody of the child. 8. An argument occurred between Father and child on July 22, 1997. During this argument, the child called Mother. Mother requested that Peny County Children and Youth Services to intervene. A copy of the caseworker's letter concerning her visit to the home is marked as Exhibit "A", attached hereto and incorporated by reference herein. 9. Father disputed the characterization ofthe argument as supported by the letter from CYS. Father avers that Mother exploited a situation wherein Father was attempting to discipline the child and the child, seeking more freedom, turned to Mother. 10. Up until this time, Father was the only parent who provided the child support and structure. While in Father's primary care, the child received all A's and B's. She was active in cheerleading and softball and was excelling academically and socially. -3- "",';-", t'. j ri [1 ~ 11 I:: " f , I I I ,. I ~ -I I I I f r.; . ~ ~ .1 ;1 J " I ~ II 'I I I .".', < '" '0' .' , '" , .' ," " ~. '-i_""-'",-,,,- ~", ,"',~b .'d.."",,"'.' ,', '.- , '" . '-1.<;'" It 11:, (; I"~ I:; t~ k, t 11. Without prior notice to Father or his counsel, Mother filed an Emergency Petition for Special Relief and an Order was entered wherein primary custody was transferred to Mother on J~- fJ r, ~I~ x ,~ ~ ~ f~ ~ . 1 ,11 A ~ August 5, 1997. A copy of the August 5, 1997 Order is marked as Exhibit "BOO, attached hereto and incorporated by reference herein. 12. After a conciliation conference, an Order was entered wherein, inter alia, the parties were to immediately commence mediation. A copy of the September 10, 1997 Order is marked as '';' Exhibit "C", attached hereto and incorporated by reference herein. 13. From the time the child was transferred to Mother, Father's contact was blocked. ii' :,; ,~ t' ~ ~ ~ I l Mother did not encourage Father's relationship but rather encouraged the rift between Father and daughter. 14. After unsuccessful mediation and considering the child's age and desire to maintain her new unstructured lifestyle, Father realized that he could not maintain his relationship with his daughter without Mother's encouragement and the child's desire. 15. Reluctantly, Father agreed to the entry of the Order dated December 16, 1997 wherein his partial physical custody was to be initiated by the child and consented to by Mother. A copy of the Order is marked as Exhibit "D, attached hereto and incorporated by reference herein. -4- , - ~' ,,~ . , c ,,'-~, '--~ -"I ,..~, ;,"'i." - " > 0,;;"" ,-" '-'..,,, ._,' ',',0- ~ , " "CO,. '. <--,,-.",^;"";--~ ,'. ',., "",g,~""",,,,""'r"';'k.,,r". ,~" $"_ ;,,,,~,,,,-_,;(.':" ~;", ,-, 16. Since the entry of this Order, Father has had little or no contact with his daughter. Mother has not encouraged the father/daughter relationship. 17. After Father learned that Mother was incarcerated, he attempted to reestablisH contact with the child but Mother has refused. 18. The parties have participated in litigation concerning the custody of the child in the Court of Common Pleas of Dauphin County. The current Order for Custody was entered on December 16, 1997 to Docket No. 2825 S 1993. 19. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 20. Plaintiff does not know of a person not a party to the proceedings who has physical custody ofthe child or claims to have custody or visitation rights with respect to the child. 21. The best interest and permanent welfare of the child will be served by granting the relief requested because Father desires to reestablish his relationship with the child. Mother has not encouraged the child's relationship with Father. 22. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. -5- '0' " . M r' ti 11 [. f ~; fc , ~ ! rr: i , ~i ~ I i I , & g i' ~ l'i ~ , oj [~ UI ~ 'it- ~ " ~ " , " ~ I ~ 'l I " ,,,,.- "," ."':>+-lh<r.""'. -,<,:._~', "'-""'-~.--',' ,:;?< ,'"' ';',,-~;:'. ,'.- ,:1.:.. ,,-:C_\"';;";'-" ,~"< \,,,,,,';".s'k-~,.,--'~,,~~'W*"Ek'~">T,"",,_~ d~"" ~"-"""-"'''<< ." . , ';i,c I~ ~~ ,,- (': ~,i ": 1;,i ! WHEREFORE, the Plaintiff requests the Court to grant him specified periods of partial "'!1 l~ 11 ll" ~ ~ physical custody of the child. Dated: APril+, 2000 -6- ~ Respectfully submitted, ~ 'jl ;~ 1 l ~1 I ~ ~ Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 Supreme Court No. 32317 Attorney for Plaintiff '11 " I I I ~ o EXHIBIT "A" '_h'" , ; "',.i, ~~~ """ . .. :(~" l,,: , " I"; I'"~ I:' I' "", , ~ '\: ;.' ,i,j , r'-' q ,,,, ~: : ::;: f~: fi lJ { ,;<, ,-, i:,: l~i I": I;: ~j ,,, I,;: I~ ~,I fl.~ i.i :J t' pi I.' l,! fA ~ H " ,) ii ii , " m I' d tl rj I!j 1...1, , J I lJ I' Ii ~ " M II " ~ I' II I " I I i I I I I " ,-, cd ,,', ' o . ADMINISTRATOR LORI DRESSlER LOWER PERRY COUNTY CHILDREN AND YOUTH SERVICES *' I i' f,:' : "~ COUNTY COMMISSIONERS MARK K. KELLER JOHN J. AMSLER EDWARD R. KENNEDY p;j 1" , P.O. BOX 123 RHINESMITH BUILDING NEW BLOOMFIELD, PA 17068 TELEPHONE (717) 582.2131 EXT. 212 '7' I,(~ I'~ ~: 1.-,' I.,...'. ~1 " ,~ L.., lij I: r:; " ii August 22, 1997 >, (,: :,) , ", Cheri showed me her face where she said she had been struck by her father. There was no visible injury. i~j i< "~j f: ~ i1 n " l;, r! ri ,.-I ;..1 ti rn t~ I " I} fA lj ,'1 i IJ !'i i I' I \j I i , I ! Atty. Barbara Sample-Sullivan 549 Bridge St. New Cumberland, PA 17070 Dear Atty: ,Sample-Sullivan: This letter is in response to a phone call I had with your paralegal, Lisa, on August 14, 1997. I received a referral that Cheri Botts had been hit by her father, Charles Botts, on July 22, 1997 with unknown injuries. I responded and visited the Charles Botts' resid~nce within an hour of receiving the call. I spoke to both Charles and Cheri that night. As Charles was r~luctant to let me in his home, I approached him closely and did not smell any alcohol on his breath. Cheri was in the room when I told her father about the allegations our agency had received. After he denied hurting her, she spoke up and contradicted him by saying that he did. She did not appear fearful of her father and continued to say she wanted to go live with her mother. If you need further information, please contact me. ~Si~ce~el~~iJ /fi4- oan Wertz Caseworker JW:ss ) "-~'"'~"'-"'-""~_... ~.l c EXHIBIT "B" . ~ - ,'^,' " 1., ie (, ii' i :~ >,,: "" oj" " ','; , ;!j 'i" i; 'll !~1 \-~; ~;1 ,,~ ii~) :~! ;ii l,~i t'! ~; I ~~ [~ ~:1 ~~I , f:i m ~1 ,: I' i~i p,! rJ ~ ! ,~ I ~ " q l ~ ~ ij 1, W I I I , , I I I ;" \-1,. ,.~ ,. " ,- / C \ ~ CHARLES E. BOITS, Plaintif!7Respondent, : IN THE COURT OF COMMON PLEAS OF : DAUPHIN COUNTY, PENNSYLVANIA v. : NO. 2825 S 1993 SUSA.N" E. BOITS SCOIT, Defenclant/Petitioner : CIVIL ACTION - LAW : CEJLD CUSTODY ORDER OF COURT AND NOW, this 5 J day of O. _ ...J- ,1997, upon consideration of the , Emergency Petition for Special Relief, it is hereby ordered that Petitioner, Susan E. Botts Scott, shall have primary physical custody of her daughter, Cheri Lee Botts, until hearing on this matter. Respondent Charles E. Botts shall enjoy periods of temporary physical custody on alternating weekenqs from Friday at 6:00p.m. until Sunday at 6:00p.m. to begin August 29, 1997 after the child bas begun attending 6th grade at South Middleton School District and liberal telephone contact with the child. BY THE C01JRT ;sfJ..~ d d/~ I J. _____ 0..t:.:!>-~~:,;~~,,; 's a ~.'.:,~~:~:,(, ~;:,r~';ct ~::e:i~\"'O\ ~(~ 0n~0"J.\ '.' -. I ' n::,. ! "c. Lr\iilhl/!LL\.J 1....1 f ''''--''~\~ r-J , (.J LI-.--~ ~,';....j".~/,--) - J '-.. "~~~- ---: ' - ....""'ry f;ol~n;~)('u\'a ~ "M ., Ii: " )i: if J[ !t ic i! , (, 1[' ,; It] i~ ~j ,- i~~ "I iil ~:1 1~1 I" 1\ III " ~ ~ ~ jj j;{ jj j,-; fi i~ U !. ol 'J " ;j f-' ~ 11 t! ~ i ;1 fl i " ,~ I ! I I' , ~ I ! I I I , .'- :-", -'----""~- o ,~, ~' , " .',<' , "",--,~~-~~....;' EXHIBIT "e" . p-",--,:;",.,-, c..~ <'~ " '. ._" - "', . ,~ .,--........---:.1.-...-. I~ I. tf ;., 1( "i ti " '"', [: r:: i,:~ 1~ ~4 re' j~ (; .. t{ t:i I' I'; If [~ " r~ \~ ;~ I~ ~ r,. 1 ;% '* ~ ';;; f& fr .J ~ t} I I.. I , 1 ~ ! ! I ~ I , i ~" ~ "I ""'-' ,'0 , ,...,- ~' ~ '" ".-' i~~ r" ~ ' 'i I' 1:,; o . t' <~ ",0 ,:" (: ~ d ;;} I,,"' ~~ "j, CHARLES E. BOTTS, Plaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA ".' ~;! l1f ,', ~~ n t+ v. NO. 2825 S 1993 tj ~ ~J l'\' 11 ~1 1ft I!l ~t .1' tt tr r~ H Ii b ~J ti: !~ " SUSAN E. BOTTS SCOTT, Defendant CIVIL ACTION - LAW CHILD CUSTODY TEMPORARY ORDER OF COURT do, of ~fh'l1~,bd , L997, the parties having appeared for a Custody Mediation Conference, AND NOW', this )0+/1 , represented by counsel, and having further reached agreement with regard to the best interests of the subject minor child, Cheri Lee Botts, born May 6, 1986, IT IS HEREBY ORDERED AND DECREED as follows: 1.. The parties shall have shared legal custody of the . '-' (\ !~ " " R ~ ~ j \~ T , ! subject minor child. They shall consult with each other relative to all important decisions concerning the subject minor child, including such matters as health, education, and religion. 2. Defendant, Susan E. Botts Scott, shall have primary physical custody of the subject minor child. 3. Plaintiff, Charles E. Botts, shall have partial periods of physical custody for purposes of visitation, as per the following schedule: a. Father shall be entitled to visitation every Friday after school until Saturday afternoon at r "" ". " , " ~. k ' "", ,;,.. ,,_'~ ,..' >--;.,-:: . '.--",-" '-'.,. . ,~J ' . " (l) if: ! . ',I" ( :i' ;ii I::: ii :~l 4:00 p.m. The parties shall equally divide transportation such that Father shall pick the child up from school Friday afternoon, and Mother shall pick the child up from Father's home Saturday afternoon at 4:00 p.m. The parties shall refrain from any type of communication during the Saturday afternoon exchange. Father shall take whatever steps are necessary to ensure that the subject minor child is ready at the appointed time. !I\ it:'1 ii- ii;:: :j~ j!,~ 1',' ;:1 t"i ig !~ L\ i-,; I'J 'i; ~i '.' Ii; ,;, rl 4. The parties have agreed to immediately begin custody mediation under th'e direction of Dr. Elliot Riegler. The fl r1 (~'l i~1 !,~ i!'i ~G II i! I,' ~j \~ I ~~ "~ !~ l~ t1 11 II f ~ \t 'I :': purpose of Dr. Riegler's services shall be to address the underlying issues which exist, including alleged child abuse. Dr. Riedler shall also attempt to improve the ability of the parties to communicate, and make decisions in a manner consistent with the best interests of the subject minor child. It is envisioned that Dr. Riegler will meet with Mother and child, and thereafter Father. It is further envisioned that much of the counseling shall involve the relationship between the Father and child. In any event, the parties are directed to extend their complete cooperation unto Dr. Riegler. After insurance reimbursement, the parties shall each pay for the cost of their own services with Dr. Riegler, and the parties shall equally divide the costs of the minor child's services with Dr. Riegler. 5. This case may be reconciliated at any point in the future, upon telephonic request of the attorney for either party to the Custody Mediator, Mark T. Silliker. ," ... ,c-.... ':~;~.',~,::~,::~',- .-~-i-,;-} ;:"'>,~ .-', ~.' " ~ I. 'j' '", ",' ~ , ~:f.~ ::-,,:,'.- i~i'--~--;'-::-, '. " ".""." - ~--'-- ,.: ~ " c . (, "1" 6. This is temporary in nature. It is acknowledged (~ that Father has specifically reserved his right to seek "-'; ~,', ;:, additional periods of visitation, or custody, at a future date if he should desire. I:}: ii f< ", BY THE COURT: l?l ,., <i-I '...'..1 e! I';-i \c3, ~~ ~\ Vlo-inSe(~ !c. kji ~;i ~1j I:! f.~i "li .~i Iii i~ :~i i~ iJ Ii ~I' I ,ii i'tl 1:1 ;'i ~I ~l q ~...._N_CJ:]~-:- . ~ --, -. . .~ . J-, ~ ~ .~. tAt=O,'-j0rf'\n ~C:, a I n-c.(""".,...ll (\,-:.r-","'.f I :' ';, ;J ,0 ,/. ....,(.j"......~.,~ '-"::'" . th,l:;~~ ~~; ~J .(':~,~::~~, :~:'.~>~. ~-~~Fv.,~-C ~ .': h f~ '''0 f!gH1a; ~;J~ri, 1 \ l...._~. I 'i' . i .. \ \, - ( ,. /-r" rJ-'U/;..bV pif~6~i~~:=~~ . II ~ (,I II .1 ~l II i ~ ~ ,I I I I I 1 I I I _..~'"""'~.- t -, .."~.,j'-~~~.,.",, ,.;.....,_:';..:..:.,_ " o " , .," > .' ~,~,,,,"'''"~''''''',,~",,,,,,,", EXHIBIT "0" ~-;". '.,,"'" . ,-' J '", i i" i< :ii " ,-: kJ (Ij 'I 'I !I Iii I i ~ il ~ 11 ( r ~ r~ I ! , .w . , '~ . ,,~, ,"" ' . -~ . ,0; _~_.' c . CHARLES E. BOTTS, Plaintiff IN Th~ COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA v. NO. 2825 S 1993 SUSAN E. BOTTS SCOTT, Defendant CIVIL ACTION CUSTODY ORDER OF COURT AND NOW, thiS/),# day of j7cz..,- n..;!,?/ ,1997, the parties having appeared for a Custody Mediation Conference, represented by counsel, and having further reached agreement with regard to the best interests of the subject minOr child, Cheri Lee Botts, born May 6,.. 1986, IT IS HEREBY ORDERED AND DECREED as follows: 1. Defendant Susan E. Botts-Scott shall have legal and physical custody of the subject minor child. 2. Plaintiff Charles E. Botts shall be entitled to reasonable rights of partial custody, with the exact details to be subject to the agreement and consent of the parties. 3. In the way of further clarification, Father has stated that he is available to spend time with daughter whenever daughter should desire, dependant upon Mother's consent. All arrangements shall be initiated by daughter. It is acknowledged that Father loves his daughter very much, and is saddened by the current state of their relationship. However, he feels that this custodial arrangement will be int he best interests of all concerned, at this time. ~' '-,-, ,',", i~ 1-' I i " i~ ",- r' :-~ .. "~ . I ,] ~ k" .~ ! Iii i i I I H ffl 11 ;,j H I i I I I , ij I , ~ I I I I I ".'.,j,,, '" ' c . ,e ,~; I"~ parties to this order shall not possess or use any controlled if r~ Iii 1& :$ !; 4. Dur ing any per iod of cus tody or visitation the substance, neither shall they consume alcoholic beverages to the ~, 'I ,Ii "' '~" t . I ~ '1 R [ 'I ~ point of intoxication. the parties shall likewise assure, to the extent possible, that other household members and guests comply with this prohibition. BY THE COURT: ~1-h8~4.M ~k/~ J. /~~/z;~:~?~ \ ~\2:'ii:.,.\.,~."~~~.':'?~::" ' ~'.~--:~" ..", ~~. ~ ';.;-"':~'\:~:-'; ';~::;i2.\ I"". ..-.;:. t:..~-2 ,:; ti:E~-:-,i . \ i "' \ ~.._.:-~~~,:-;~0-~Y .",.,.;.',.\,;.,..'.......7 ""'~ . oJ....<''" e . CHARLES E. BOTTS Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - CUSTODY SUSAN E. BOTTS SCOTT, Defendant : NO. VERIFICATION I, CHARLES E. BOTTS, hereby certifY that the facts set forth in the foregoing COMPLAINT FOR CUSTODY are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A Section 4904 relating to unsworn falsification to authorities. CHARLES E. BOTTS ~ ....~~""',~ , H (1 I :1 f4j.t ........ ........ '.' "':::::::::::}\:}:?:. . ..- '~, ',- -^, ~" CHARLES E. BOTTS Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA , . . '~""~~,~'''~''''-''''''''''''~ ~~ -="~.' " c~I"""'-",'~"""',~,,"~ ,=',='-~" W".'" J- "'c~""'~" '~ ~ ~ " I I I" , I I I ~ l I :~ ! , I i l I I , v. CIVIL ACTION - CUSTODY SUSAN E. BOTTS SCOTT, Defendant : NO. VERIFICATION I, CHARLES E. BOTTS, hereby certify that the facts set forth in the foregoing COMPLAINT FOR CUSTODY are true and correct to the best of my knowledge, information and belief I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. ;7 lAll.All/ L- 4~ CHARLES E. BOTTS ".~=~-~,," ~ , I ,,. , c' ~ - - _..1oH'L, , , i CHARLES E. BOlTS/ . IN THE COURT OF OOMMON PLEAS OF . plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 00-2109 CIVIL TERM . . . SUSAN E. BOlTS SCOTT, . CIVIL ACTION - LAW . Defendant : CUSTODY ,~ ,. I , I i. , i. ORDER OF COORT i'~ , 2000, upon it is ordered V: I' AND~, this "3) f" day of mra consideration of the attached Custody Concilia on Report, and directed as follows: !~ 1. All prior Custody Orders are vacated and replaced with this Order. " ;~' 2. The Mother shall have primary physical custody of the Child. I';, ~ t. , j ~ 11 r I', J ~ ri 3. The Father shall be entitled to have reasonable and regular periods of partial custody with the specific dates and times to be a=anged between the Father and the Child at the initiation of either the Father or the Child. 4. Neither party shall consume alcoholic beverages to the point of intoxication or use any controlled substance during his or her periods of custody with the Child. The parties shall ensure that other household members and guests comply with this prohibition. 114- ~~ .5-3/-00 "R Kg ~i l , ~ ~ i, t' , I I I ~ , I [ i , , 5. The parties and their counsel shall attend an additional Custody Conciliation Conference in the office of the Conciliator, Dawn S. Sunday, Esquire, on July 19, 2000, at 3:00 p.m. BY THE COURT, J. CC: Barbara Sumple-Sullivan, Esquire - Counsel for Father Lisa M. Greason, Esquire - COunsel for Mother i!ili~",J-!;; " I,w~ ,',-' .,..- j', ,,-', _~i.bIlilflJ!t!'i2ir ""~~~ili'~lB \fINV^lASNN3d ^.l.NDOJ ON\f1l:E\8V'lm 1't::\I j,l1;l \ S k~W no . L'./i'ON"'J"^,, ' , ",i' :\0- N:J,V.!.. Ul1..l,,~)dO....l' ,1 38U:iQ-(\31\;l - ""' "rilll UHiIIiI . ''iiNlW1lIilIlii1illlllli ~':' ,'';'' '",,,,, '~ ^ ". ,~ ""," " "-""'~-~. ~ ~.-- -. >~ ""' CHARLES E. BOl'l'S, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND C<XJNTY, PENNSYLVANIA . . . vs. . NO. 00-2109 CIVIL TERM . : SUSAN E. BOl'l'S SCOTT, . CIVIL ACTION - LAW . Defendant . CUSTODY . CUSTODY <nK:ILIATICtiI SUMMARY REPCRT IN ACCORDANCE WITH CUMBERIJINI) CClUNTY. RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned CUstody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Cheri Lee Botts Mother May 6, 1986 2. A conciliation COnference was held on May 25, 2000, with the following individuals in attendance: The Father, Charles E. Botts, with his counsel, Barbara Sumple-Sullivan, Esquire, and the Mother, Susan E. Botts Scott, with her counsel, Lisa M. Greason, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ~ ,-)/0, ~?J Date . 0 ' ra,~ Dawn S. Sunday, Esquire CUstody Conciliator '1 ~ ..,"''''', i"' I", " , , ):~ ;l,' l' I';' ~i f" I:," ~,,,' ~~ ,'" :t i~ i~ . ~~' !~, i jl~ 11 Ii Ii ,. ~ ,!; I" I: J; I,~ I~ 11 ii, w; l\: :5' " " ~" I JUL 2 4 ZOO~ CHARLES E. BOTrS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 00-2109 CIVIL TERM . . . . CIVIL ACTION - LAW . SUSAN E. BOTTS SCOTT , : Defendant . IN CUSTODY . I'" ',:" ,~' i ,,', j", I:' H l'~ ' ,. ;t aIDER OF <XXlRT f!1 'j' AND Nai, this 18th day of July, 2000, the Conciliator, being ii' advised by Plaintiff's counsel that the parties have resolved all 1" in this case. The CUstody Conciliation Conference scheduled for July 19, iti I': II,i IP [1'1 " IJ outstanding custody issues by agreement, hereby relinquishes jurisdiction 2000, is canceled. i!~ ii~ F" ji,; k If' >, FOR THE COURT, ~7 CUstody Conciliator ',i-:l.1~rMal "hiiC~_~~~::li\i;Iifll~ ~:.J.~,~} ,C ~'"r,,'c, ,., ,~,",' "~"e,, ,~'<,~ -'C"", " , ~ ~I.. I., ~-..,"' ,-'.. 1iiIIIiiiorli-........ ,~ , , "h' . ~ 0'.' ,",~.... -"'" 0 <::) 0 C 0 , <' -or-Y nltf 2':r: N 0~~ C;", r:: r~ , ....'-, 2~ ~- ,> C) -"," Z s> c 9? c z .:.n 5;; --I ::D -< -< ~