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Home My WebLink About98-06381 ~, ~ () ~. VJ ~' N \,,, -\.. "' ~ ( \. ~ - - ,~ - v ....... : 0.. 'Y) -.j I ' ~: ~l ,I ~l , The mother of the child in [)r,fendillll, Tanya Yohe, currently renidinCj at 2181 StiJlhollflC Hollow Hoad, Shippenubul'Cj, Pennsylvania, She is not married, The father of the child in Plaintitf, Tony E, Rotz residing at 107 West Burd Street, Shippensburg, Pennsylvania, He is not married, 4, The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons: Name Relationship Nicole Mathna fiancee 5, The relationship of Defendant to the child is that of mother, The Defendant currently resides with the following persons: Name Relationship Ronald and Judy Yohe parents 6, The parties previously entered into an agreement for custody by Court Order dated February 8, 1999, which is attached hereto and marked as Exhibit "A", 7 . The best interest and permanent welfare of the child will be served by granting Plaintiff primary physical custody as the child has been with his mother sporadically, and is in good care when the Defendant is living with her parents; however, Defendant has a history of drug use, has had several run-ins with the law and may be on the verge of being arrested for her participation in a robbery, Further, the Plaintiff has an r'Htabljnhl',i h()~l.'~ w,ith bin fidn('/:"~ and i~ ~ti,:,. 1'1 If"..i,!,> wann, Ht.1b},' "...1''' 1'01 the chi ]d, WIIl-:flEFOkE. Pl..intiff te'lU0HtH the r.OtlJ't I" 'P'ol"l Phi"l iff pt'imary pllynical C:UfiLody uf the' chi lei Hubjecl t (! pt.tje1d:; l,j partial physical cu~;tody in tb._~ D("ft~llddnt, p)"f)';id,,-:'d s".~ in L't~nidil1g with tH.::"l" pal'ent:n. 'j/> , / - .-, . /Y-- J-::'-X'-__.____ ecky,"E{;qu'lire Street 1'/013 Pliduliff '. r:Ea 5 19;;' ~ ,- TONY E. ROTZ. Plaintitl' IN THE COl.:'RT OF CO~!."(ON PLEAS OF CUMBERLAND COu1.TY. PENNSYLVANIA v CIVIL ACTION. LAW TA..'lYA YOHE. Defendant NO. 93 . 6381 ClY1L IN CUSTODY COURT ORDER A..'ID NOW, this 3..o...day of February, 1999, upon conside:':ltion of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father. Tony E. Rotz. and the Mother. Tanya Yohe, shall enjoy shared legal custody of the minor child Nicholas Paul Yohe. born October 14. 1995. 2. The Mother shall enjoy primary physical custody of the minor child. 3. The Father shall enjoy periods oftcrnporary physical custody as follows: A. Each weekend from Friday evening until Sunday evening at time agreed upon by the parties. except for the Ylother shall have the right [0 have the child for 6 weekends each year upon at least 2 weeks notice to the Father. B. One weeknight per week until the next morning at times agreed upon by the parries. C. On those weekends when Father is working and Father gives Mother advance notice, Father shall be able to substitute his weekend time for 2 full days, including overnights. during the week at such times as agreed upon by the parties. D. Tne parries shall share custody of the child on :he following holidays at mutually agreed upon times: Easter, Memorial Day. July 4". Labor Day and Thanksgiving Day. ..... '-. li . r. r , M. Father may make arrangements to have a custody evaluation petformed by a professional agreed upon by the parties. Father shall pay for the costs of this evaluation. However, the evaluation shall be an independent evaluation and the results of the evaluation may be shared with counsel for both parties. Mother shall cooperate with such evaluation and make the child and other necessary interested parties available for any of the evaluation sessions, Upon the conclusion of that evaluation and in the event at that time that either party desires to have this order modified. that party may petition the Court :0 have the case again referred to the Custody Conciliator for a Conference. " BY THE COURT, ~s/1~ c..... ~ 1. cc: Joan Carey, Esquire Thomas Diehl, Esquire \' -....... ....... ...... :-0.... _. . .~. ~"..,1, - ':.... ...~~ .......,. 'M"'" ?:-:i.. '__. ::.:.:Jt....d-,., '? "r'7 - ~U .' ........ _......_.-=:r.:......>l.,..(~ ,.~~ f) u-.-:-............_ ,z~ ?;.;::~ccr,f"/ TONY E. ROTl, I'lairllitl' IN TilE COURT OF COMMON ('LEAS OF CUMBERLAND COUNTY, I'ENNSYL VANIA v CIVIl. ACTION - LA W TANY A YOI IE, Defendant NO.IJH.ft3HI CIVIL IN CUSTODY COURT ORDER AND NOW, this f ~ day of February, 1999, upon eonsiderat:on of the attached Custody Conciliation Report, it is ordered and directed as follows: I. The Father, Tony E. Rotz, and the Mother, Tanya Y ohe, shall enjoy shared legal custody of the minor child Nicholas Paul Yohe, born October 14, 1995, 2. The Mother shall cnjoy primary physical custody ofthe minor child. 3, The Father shall cnjoy periods of temporary physical custody as follows: A. Each weekend from Friday evening until Sunday evening at time agrecd upon by the parties, except for the Mother shall have the right to have thc child for 6 wcekends each year upon at least 2 weeks notice to thc Fathcr, B. One weeknight per week until the next morning at times agreed upon by the parties, C. On those weekcnds whcn Father is working and Fathcr gives Mother advance notice, Father shall be able to substitute his weekend time for 2 full days, including overnights, during thc week at such times as agreed upon by the parties. D, The parties shall share custody of the child on the following holidays at mutually ab'1'eed upon times: Easter, Memorial Day, July 4''', Labor Day and Thanksgiving Day. I .) cc: Joan Carey, Esquire Thomas Diehl, Esquire M. Fathcr may makc arrangcmcnts 10 havc a custody cvaluation pCrftlOllcd hya protessional agrccd upon hy thc partics, Fathcr shall pay tt,r thc costs of this cvaluation. /lowcvcr, thc cvaluation shall hc an indcpcndcnt CVUlualion and thc rcsults of thc cvuluation may hc sharcd with counscl fl)r hoth partics. Mothcr shall coopcralc with such cvaluation and make the child and other neccssary intercstcd partics availahlc for any of Ihe c\'uluation scssions. Upon thc conclusion of thai evaluation and in thc cvcnt at thai time that either party desircs to have this order modi lied, that party may petition the Court to have the case again referred to the Cuslody Conciliator for a Conference. BY THE COURT, 4\t-. // /04 C.ttf".,.,~~ ~},9/9q.- / .A.1i' J, TONY E. ROTZ, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA I'laintiO' v, CIVIL ACTION - LAW T ANY A A. YOHE, NO, 98.6381 CIVIL IN CUSTODY Defendant AFFIDAVIT OF SERVICE AND NOW, this ,)'/"'day of (j/I, ( , 1999, comes Karen L. Goshorn, Secretary to Thomas S. Diehl, Esquire, Attorney for Plaintiff, and states that she mailed a certified and true copy of a Complaint for Divorce to the Defendant, Tanya A, Yohe, at 2181 Stillhouse Hollow Road, Shippensburg, Pennsylvania, by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating service was made on December 2, 1998. / " I t (Ie . f\ II ~J it ( ~ ,7-1 l' .r//'~ I. Karen L. Goshorn Secretary to Thomas S. Diehl, Esquire GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A J 70 13 (717) 243-5551 Sworn and subscribed . .{ to before me this d7!:!J. day of t2p.t.J ' 1999. /?Ju~flm LiMi-L~>,-, NOTARY LIC Notarial Seal Robin J. Goshorn, Notary Public CalUsle Bora, Curnberlanij Coun~ My Commission Expires Apr. 17. 2 03 I " i "" D -' .' '~l '~1 G ~~ .. "OUI .. m f'-~ '.-11 'z:J2 I .~J ...._.C. (..~ '.:{~ 0>.-':'. -< J'~4 -', C:O ~O .- ~c:C) ~--rn __:: f'l 9, '.. ::JJ ::q Iv -<; ~ ,. . ., - ". ." . . , .' "'-~ :. -" '~, .. . :'; f: ~ 1/lt.4S' &;I. fo/r!.~.;u4 t 4 ~ If . Ie, f'r '-ffi"k., ~;~;/ -j;,:~ / / ./k f(' ~I'j' ~at/ ~ ,J ..sd.t..)? ~ TONY E ROTZ. Plaintifl' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL'I ANI A CIVIL ACTION. LAW vs, TANYA S. YOHE, Defendant NO. '1J'-f,?,j/ CIVIL TERM IN CUSTODY PETITION FOR CUSTODY I. PlaintilT is Tony E, Rotz, an adult individual currently residing at 47 Richard Avenue, Shippensburg, Cumberland County. Pennsylvania, 2, Defendant is Tanya Yohe, an adult individual currently residing at 2181 Still house Hollow Road, Shippensburg, Franklin County. Pennsylvania, 3, The PlaintilT and Defendant are the natural parents of one child, Nicholas Paul Yohe, born October 14, 1995. The child was born out of wedlock, Since the child's birth, the child has resided with the following person at the following addresses: ~ 1.; ~. NAME ADDRESS DATE Tanya Yo he 2181 Stillhouse Hollow Rd. Birth to 4/98 Ronald Y ohe Shippensburg, P A Judy Y ohe Tanya Yohe 2181 StillhouseHollowRd. 3/98 to 7/27/98 Tony Rotz and 47 Richard Ave. Shippensburg, PA Tony Rotz 47 Richard Ave, 7/27/98 to 10110/98 Lanna Varner Sluppensburg, P A Jerry Varner Esther Rotz Tanya Yohe 2181 Slillhouse lIollow Rd, 10/10/98 to prcscnt Shippcnsburg, P A The natural mother of thc child is Tanya Y ohc. who residcs as aforesaid, She is single, The natural father of the child is Tony E. Rotz, who residcs as aforcsaid. He is single, 4, The relationship of the Plaintin. to the child is that of natural fathcr, The PlaintifT currently resides with Nicolc Johnston, 5, The relationship of thc Dcfendant to the child is that of natural mothcr, The Defendant currently rcsides with hcr parcnts, Ronald and Judy Y ohc. 6, Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the child, 7. Plaintiff has no information of custody proceeding concerning the child pending in any Court of this Commonwealth, 8. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) The Plaintiff is more capable of providing a stable atmosphere in which the rear the children; and (b) the Plaintiff is desirous of maintaining shared legal custody of the children and establishing appropriate periods of partial or temporary custody of the children with Mother. 9, Plaintiff does not know of any person not a party to the proceedings who claims to have custody or visitation rights with respect to the child. t,;J I .":" . ~-. WHEREFORE. l'laintin'rcqucsts your Honorable Court to cntcr an Ordcr granting t :. I ') ! primary physical custody with the Plaintil1' and cstablishing a schcdulc of temporary GRIFFIE ASSOCIATES j~ A (01) physical custody with Ihe Dclcndant Rcspectfully submittcd, Thomas S. Diehl.. Esquirc Attorney for Plaintiff 200 North Hanover Strcct Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 $ ,;.* .~ VEIUFICATION I verify thatthc statemcnts made in thc foregoing doculllcntllfe true and correct. understand that falsc statcmcnts hcrcin madc arc subjcct to thc pcnaltics of I g PA.C.S, Section 4904 rclating to unsworn falsification to authorities, Date: / (). rJ.. - '1 <g ~-T.-<.r ~ -K'r" TONY E, Rop"l ~ " ,-, ; , :.) ;, ; - " " ~, :.", J C.. 1 ' "\1 , " f';.) , , " , .. :.;:1 (], -<. ',JU! ~ 1 ?ODJ/fJ TONY E. ROll. I'laintill' 1:'IiIIIU'OI 'R I 01- ('O~I\H IN I'I.EAS OF ('l1\IJII:RI.ANIl ('Ol 'NI Y. I'ENNSVI.V ANIA \ CIVIL AnioN - 1.,\\\' TANYA YOIlE, Ikl~nd;l11t NO, I)X . (,.1X I CIVIL IN 1'llS n lilY r!)11In..llRlll'J~ AND NOW. this _~_ day or_,jJ~f-.c""_~___' 2001. upon consilkration or thc attachcd Custody Conciliation Rcport. il is ordcrcd al,d dircclcd as 1l]lIows: ), This court's prior ordcr of Fchruary 8. 19119 is \'Healcd. 2, Thc Fathcr. Tony E. Rotz. and thc Mothcr. Tanya Vohc, shall cnjoy sharcd Icgal custody or Nicholas I'aul Y ohc, horn Octohcr 1-1. 11)1)5. J. Thc Fathcr shall cnjoy primary physical custody or thc minor child, -I. Thc Mothcr shall cnjoy partial physical custody orthc minor child as 1(]lIows: A. On altcnmting wcckcnds Irom Friday at -1:00 p.m. until Sunday at 6:00p.m, B. Atlcasttwo (2) cvcnings a \\wk Irom4:00 p.m. until 8:00p.m.. with at least onc or thcsc cvcnings hcing an ovcrnight. Thc days shall hc arrangcd hclwccn thc partics, C. Two non-consccutivc unintclTuptcd wccks in thc summcr. D. Sharcd holidays. attimcs 10 hc agrccd upon hy thc partics. " 5. The Mothcr shall always havc custody on Mother's Day and thc Fathcr shall always havc custody on Fathcr's Day, thc timcs to he mutually agrccd upon by thc parties. 6. Mother's custody as sct I(]rth abovc whcrc it is ovcrnight is contingcntupon Mothcr cxcrcising ovcrnight custody at hcr parcnts' home. II' mothcr is not ahlc to cxcrcise ovcrnight custody at hcr parcnts' homc, Mothcr's pcriods or custody as outlincd abovc shall hc Iimitcd 10 during the day with Mothcr relurning thc child 10 Fathcr lor thc ovcl11ight. This provision may he modificd hy agrcemcnt or thc partics. In thc cvcnt Mothcr is scrving a prison scntcncc. Fathcr agrces to cooperatc with Mother's parcnts to cnsurc thatthc minI1\' child has an opportunity I(lr visits wilh thc Mothcr at prison. f :ri! ,;' :h ~' ,'/1 ~t 7. Trallsl~'rlaliollli'r c\dlall~c lIrcusII~I~ shall 1,<: shar.'d hCIII...'uIIK'l'al1ics. ll. Thc parlics a~r.'c Ihal Ihis ClIlIlI shallrclainjurisdiclion. I). This onkr is clllcrcd l'ulSnalll II' an a~rcclm'lII rcach,'d hy Ih., parlk's al a cuslod~ concilialion conli:rcncc. Inlh., CI"1I1 eilhcr part~ dcsircs 10 lIlodil~ Ihis ordcr. Ihal pal'l~ lIlay l'c1ilion Ihc coun 10 haw thc casc a~ain schcdulcd II ilh thc cuslody concilialor li.r a conlcrcllc,', IIY Till: COURT, ",:~-('L~:_-.Al::ll.=-. ._______.1. KClill i\. I less cc: Johnna.l. Kopccky. Esquirc JOlin Curcy. Esquirc / ~ 61 0' ,y ~lI;~ 10NY 1',.IWlt, I'lailllill' IN 1111'('()(;RI("('(I~I\f(I;\lf'lh\S('" ('l1:\ll1l:I(I.ANIl ('01 ':'Ii I Y.I'I'NNSYI.V ANIA ('IVII. :\{"1I0N -I..\\\' . j I'M"; Y A YOIII', IlL",'ld""1 :'1:0. 91( - (,.\x I ('1\'11, IN (.(,S lOllY I'rior Judgc: Kcdll A. Ilcss ~l!!\)( lUA III IN ('( INFI:RI'N('1' Sl JMMARY RI'I'()I( l IN i\(,(,()RDAN(,E \\'1111 TilE ('l IMIIERI.^ND ('OUNTY CIVIl. IWI./.: OF I'R()(,ElllJRE 1915,,\-1((0). thc undcrsigllcd ('uslolly Conciliator suomits thc li,lIowillg report: I. Thc pcrtinclll in/imnation pcrtaining 10 thc chilli who is thc su~iccl or this litigation is as 1.,lIows: Nicholas Paul Yohc. oorn Octoocr 14. 1995. 2. A Conciliation Conlercncc was hcIt! on July 19.2001. with thc 1.,lIowing individuals in attcnt!ancc: Thc Mother, Tanya Yohe, with her counsel. Joan Carey. Esquire: and the Father, Tony E, Rolz. wilh his counsel. Johnna J. Kopecky. Esquire, ), The parties agrec 10 (he cnlry or an order in Ihe Ibrnl as attached. ~ 7 /3tF! O( DATE Iluoert X. Gilroy, Esquir Custody Conciliator