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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KELLY DZIECIOL
Defendant
CIVIL ACTION - LAW
NO 98-1) ,4j"ICIVIL TERM
IN CUSTODY
Vs,
ERICK A. BOOZ
ORDER OF COURT
AND NOW THIS -Ii day of,.. ,Ii'~' , 199, upon consideration of
the attached complaint, it is hereby directed that the parties and their respective
counsel "nnear bp.fnre \\ ;"".. \, ''"''. ( \ \i ,': : '; i , the conciliator, at
~,' ,-\',"\', ,J,! l'>'I,hc, "., .. ',' h ., d f" . 1998 t
;,!'i\"f..;\r-r~-\(("\(r~A-l~'.~,(onte~ ayo I,V',{..,:"\", I a..l.-...:...-\I
A:l'iJI]P,M,, for a Pre-Hearing Custody Conference, At such conference, an effort will be
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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 age five or older may also be present at the conference, Failure to appear at
the conference may provide grounds for entry of a temporary or permanent order.
BY THE COURT,
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BY n \' I. .\'\ .\
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply
with the Americans with Disabilities Act of 1990. For information about accessible
facilities and reasonable accommodations available to disabled individuals having
business before the court, please contact our office, All arrangements must be made at
least 72 hours prior to any hearing or business before the court, You must attend the
scheduled conference or hearing,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OF CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
KELLY DZIECIOL
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
Plaintiff
Vs
CIVIL ACTION - LAW
NO 98- 'J 1'1'\ CIVIL TERM
IN CUSTODY
ERICK A BOOZ
Defendant
COMPLAINT FOR CUSTODY
1, Plaintiff is Kelly Dzieciol, an adult individual, currently residing at 810
Petersburg Road, Carlisle, Cumberland County, Pennsylvania, 17013,
2 Defendant is Erick A 800z, an adult individual, currently residing at 199
Ii 800z Road" Shippensburg, Cumberland County, Pennsylvania, 17257,
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3,
Plaintiff seeks custody of the following child, Ciera Lynn 800z, age 1,
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'l born 8/8/97,
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The child was born out of wedlock,
Ii The child is presently in a shared custody arrangement which the Plaintiff
II Mother finds unsuitable,
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!I During the past five years, or since the child's birth, she has resided with
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the following persons at the following addresses:
(a)
from birth to mid August, 1998 with the parties at 199 Booz Road"
Ii Shippensburg PA,
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from mid August, 1998 to present with the Plaintiff, her mother
(b)
Janet Bosak, step-father Anthony Bosak and her sister Sara Dzieciol at 810 Petersburg
Road" Carlisle, During the times the Defendilnt has her he sometimes has her at his
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home but more often at the homes of his parents or grandmother
The natural mother of the child IS Kelly DZleclol
She is single.
The natural father of the child is Erick A Booz
He is single.
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4,
The relationship of the Plaintiff to the child is that of natural mother,
5, The relationship of the Defendant to child is that of natural father,
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Plaintiff has not participated as a party or witness, or in any other capacity
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in other litigation, concerning the custody of the children in this or in any other Court,
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Plaintiff has no information of a custody proceeding concerning the child
pending in a court of this Commonwealth.
Plaintiff does not know of a person not a party to the proceedings who
has physical custody of the child or claims to have 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) the mother has been the primary caretaker of the child since her
birth, Prior to the parties separation in mid August the father on numerous occasions
declined the opportunity to spend time with the child and left her with the mother or his
family for care,
(b) the father drives a truck during the day and works as a bouncer in
a bar several nights a week, Although he professes to want to spend time with his
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I verify that the statements made In the foregoing Complaint for
Custody are true and correct I understand that false statements tlereln are made
subject to the penalties of 18 Pa C S S 4904, relating to unsworn falsification to
authorities,
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", lIy Dzieciol
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