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Home My WebLink About00-06980 , ~ ~ Idl 'II, :"". - 'JI ., KAREN L. DOTSON PLAINTIFF V, JOSEPH W. DOTSON DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-6980 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 13th day of October, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicshufl~, PA 17055 on the ~ day of November ,2000, at-.!!:OO a.m. for a Pre-Hearing 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 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. FOR THE COURT, ..' , ~ By: Isl Dawn S. Sunday, ES~ Custody Conciliator , The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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 ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR 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 Telephone (717) 249-3166 " r-" ~,~<.~ ""'~---, "~ '~ .,~o>' ~~'v>'~ no, i\:"'T \ b ,,; I U.,; '. 1-'\' \,,;"j 0:::. l,'-' \i-, t:,i:::Hj".;"~' ~.~_,;,::,~i\\iT'{ CLI~\'.'-'"' l"'\/' , ii' ", --~, .-)r~NiL'..,;,\l \In,'>. ' t 1:_\ )' J ~.' /tJ.jb.tJt1 W ~ ~ ~ -4 ~ /iJ/.6.t?t7 '?7~ ~./ ~ dffr,' " /tJ -jJ.?J{) ~ ~ ~ ~' ~ ., ~.- """"-,~".,,,, =~'~~ ' ,..-"~C ~'-' "" - ''''''''''( -'('-"lid ...___.....,., ~11f'!!lfI\!l!f!ft!!!!ll~~~"''ffi' ~,AI, "" ~~ _ ~,~m~""'''','W1U,:"''''_,,,:>t.',-~-, ';',1'''-~~''''\''-~''-'''''''~'_' ~"'''''\'''''_;'=_'''~'''''''\m-~","~::\.'H:I!f'~'l!f'E'<_'W'':!W,O~''I~:::r-'''l~f'!1'A'wq,~ .,' I ," ~'- , I; KAREN L. DOTSON, Plaintiff : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00 - b9Jt) Clu~l T~ JOSEPH W. DOTSON, Defendant : CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Esquire, the Conciliator, at , Pennsylvania, on the day of , 20_ , at o'clock .m. for a Pre- Hearing 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. Either party may bring the child who is subject of this custody action to the conference, but the child's attendance is not mandatory. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent Order. For the Court: Dated: By: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR 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 CARLISL'E, PA 17013 (717) 249-3166 --, ~ - ~ I j ',' '-j- 1l!:$-SL' KAREN L. DOTSON, Plaintiff v. : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. (}O- (A~~ I..u..- JOSEPH W. DOTSON, Defendant : CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTODY AND NOW comes Plaintiff, Karen L. Dotson, by and through her attomey, Nora F. Blair, Esquire, files this Complaint for Custody and in support thereof, avers as follows: 1. Plaintiff, Karen L. Dotson, is an adult individual residing at 108 North Second Street, Wormleysburg, Pennsylvania. 2. Defendant, Joseph W. Dotson, is an adult individual currently residing at 108 North Second Street, Wormleysburg, Pennsylvania, but who will be moving from said residence before the end of October, 2000. 3. Plaintiff seeks primary physical and legal custody of the following minor child: NAME PRESENT ADDRESS DATE OF BIRTH Dillon W. Dotson 108 North Second Street Wormleysburg, PA April 18, 1996 4. The child was born in wedlock. 5. The child is presently in the custody of Karen L. Dotson who resides at 108 North Second Street, Wormleysburg, Pennsylvania. o. " ,: ' , I _.. ~ ,,-< ~-, 6. During the last five years, the minor child has resided with the following persons and at the following addresses: NAMES ADDRESSES DATES Karen L. Dotson Joseph W. Dotson 108 North Second Street Birth to Present Worrnleysburg, Pennsylvania 7. The mother of the minor child is Karen L. Dotson, residing at 108 North Second Street, Worrnleysburg, Pennsylvania. Karen L. Dotson is married, but separated. 8. The father of the minor child is Joseph W. Dotson, cliITently residing at 108 North Second Street, Worrnleysburg, Pennsylvania. Joseph W. Dotson is married, but separated. 9. The relationship of Plaintiff to the minor child is that of mother. 10. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP Dillon W. Dotson Joseph W. Dotson -- will be moving out in October, 2000 Son Husband 11. The relationship of Defendant to the minor child is that of father. 12. The Defendant currently resides with the following persons, but will be living alone by the end of October, 2000: NAME RELATIONSHIP Dillon W. Dotson Karen L. Dotson Son Wife .,~ 1 , .,I-'L _,_', l,;:'_" ~' 13. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of this minor child in this or another court. 14. Plaintiff has no information of a custody proceeding concerning this minor child pending in a court of this Commonwealth or in another state or commonwealth. 15. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the minor child or claims to have custody or visitation rights with respect to the minor child. 16. The best interest and permanent welfare of the minor child will be served by granting the relief requested because Plaintiff has been the primary caregiver for the minor child and will provide a more stable and nurturing environment for the minor child. 17. Each parent whose parental rights to the minor child have not been terminated and the person who has physical custody of the minor child have been named as parties to this action. 1-1 ". h _ , " 'n~ WHEREFORE, Plaintiff requests that Your Honorable Court grant primary physical and legal custody of the minor child to Plaintiff with visitation to Defendant as the parties may agree. Iv -'1 . 0 D y submitted o F. Blair Supreme Court ID #45513 5440 Jonestown Road Post Office Box 6216 Harrisburg, PA 17112-0216 (717) 541-1429 Fax (717) 541-1428 Ii , ~ , "UWlilil..wtl VERIFICATION I verify that the statement made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that the statements therein are made subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. ~M1 t j)~ ~~~"""~~;t""~1."~~'~d~'$o;~;",ilJ-~Ii<r;<,-X'.""",",.~~;"",;j:",,,,,--MlUi~..J!'-iili~Wil~~~~~~~'~" ~ ~ (") C ;:;-.... l)f;~~ m(i', :fi~-~ \..,",,-- -<.' ",.-~ ~l~ ,,~ -::!:'~C: ~CJ Pc Z =< ~,) :...> h' Cl o o c-) '-1 o ~, i"] -['; j:~ '-} ~? C) ~);-'l ):'" ::n -< H~~~__ ,~ I " "'I . "lIi~,' KAREN L. DOTSON, Plaintiff : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-6980 CIVIL TERM JOSEPH W. DOTSON, Defendant : CIVIL ACTION - CUSTODY ACCEPTANCE OF SERVICE I, Joseph W. Dotson, am the Defendant in the above-captioned divorce matter. I have accepted service of the Complaint for Custody as of this the d2 day of 0(' ~ ,ie;t' ,2000. ~;u~ ~ W. Dotson S~I~!if~'l;:llll!fIk.J,~-!t4ld';M:i..~~!~1"-0I'\-~~i'"\!l""'~,"i,",,,':L~'1;,,,, ?,_;A('"',,~",HJ,,""">lli;;;!"~-<oI~~ """"'..~~"""...'"="""''''' _. - ,~"~ ,">~ ^,",,"," ~ ~~~ "~~~ ~. 'r ,~,~-, ,."...1. ,.~ ,_",,~li!lliiIilit..;,,~. ., Dl.;,: 0 0 C) C 0 ""1'1 g: :::r.: -nO:; C) '-'; " mrp <'- , . ZX' -, I '!" Zr- i~~ (I),~: \.0 -<L ~O -0 ;~,~ (~; )>C' -'''- be) ~ ~srn )>c ':=t ~ ",. S:J (Jl -< >-- ~'^ ~ ~~ ~ .. KAREN L. DOTSON, : IN THE COURT OF CXlMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. : NO. 00-6980 CIVIL TERM : JOSEPH W. DOTSON, . CIVIL ACTION - LAW . Defendant : IN CUSTODY aIDER OF <JOORT AND NeW, this 10 consideration of the attached and directed as follows: day of }J~ , Custody Conciliation Report, it 2000, upon is ordered 1. The Mother, Karen L. Dotson, and the Father, Joseph W. Dotson, shall have shared legal custody of Dillon W. Dotson, born April 18, 1996. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have partial physical custody of the Child on alternating weekends from Saturday at 9:00 a.m. through Sunday at 6:00 p.m., beginning Saturday, November 25, 2000, (at 6:00 p.m. due to the Mother's Thanksgiving holiday period of custody). The Father may also have custody of the Child at any other times arranged by agreement of the parties. 4. The parties shall share or alternate having custody of the Child over holidays as follows: A. CIIRISTMAS: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment B, which shall run from Christmas Day at 12:00 noon through December 26 at 12:00 noon. In even numbered years, the Mother shall have custody of the Child during Segment A and the Father shall have custody during Segment B. In odd numbered years, the Father shall have custody of the Child during segment A and the Mother shall have custody during Segment B. B. THANKSGIVING: The parties shall alternate having custody of the Child over the Thanksgiving holiday from Thanksgiving Day at 9:00 a.m. through the following Saturday at 6:00 p.m. The Mother shall have custody over the Thanksgiving holiday in even numbered years and the Father shall have custody in odd numbered years. C. EASTER: The Mother shall have custody of the Child every year on Easter sunday beginning at 8:00 a.m. - ["I' : r -~~'iII\i: ~ D. MFKlUAL DAY/LABOR DAY: The party who has custody of the Child over the weekend immediately preceding Memorial Day and Labor Day under the regular custody schedule shall continue to have custody of the Child through the day of the holiday at 6:00 p.m. E. JULY 4th: The parties shall alternate having custody of the Child from July 4th at 9:00 a.m. through July 5th at 9:00 a.m. The Father shall have custody over the July 4th holiday in odd numbered years and the Mother shall have custody in even numbered years. F. HAI.J:.amEN 'l'RICK-oR-TREAT NIGHT: Each party shall be entitled to have custcidy of the Child from 5:30 p.m. until 8:30 p.m. on each party's community trick-or-treat night. In the event trick-or-treat falls on the same night in both comrmmities, the parties shall alternate having custody of the Child. G. MOTHER'S DAY/FATHER'S DAY: The Mother shall have custody of the Child every year on Mother's Day from 9:00 a.m. until 6:00 p.m. and the Father shall have custody of the Child every year on Father's Day from 9:00 a.m. until 6:00 p.m. H. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. I. In the event the Father's holiday period of custody falls immediately preCeding or following his regular period of custody, the holiday/regular period of custody shall run continuously. 5. Each party shall be entitled to have custody of the Child during each summer vacation for 2 non-consecutive weeks upon providing at least 30 days advance notice to the other party. The party. providing notice first shall be given preference on his or her selection of vacation dates. In the event the Mother schedules a period of vacation custody under this provision during the Father's regular weekend period of custody, the parties shall cooperate in scheduling a make-up period of custody for the Father as soon as possible. 6. The Father shall not use illegal drugs and shall not consume alcohol before or during his periods of custody with the Child. The Father shall ensure that all third parties having contact with the Child comply with this provision. 7. Child. Neither party shall use physical punishment to discipline the 8. The non-custodial parent shall be entitled to have reasonabletelephone contact with the Child. 9. Each party shall ensure that the other party has his or her 1',1 ~ 1 , '~~..~~ .. current address and telephone number on an ongoing basis. 10. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall take all reasonable steps to ensure that third parties having contact with the Child comply with this provision. 11. This order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this order by mutual consent. In the absence of mutual consent, the terms of this order shall control. J. t~ -ff)oJ.l II . / L/ .aQ RK~ cc: Nora F. Blair, Esquire - Counsel for Mother Joseph W. Dotson, Father " __ rl,', ~" ., ",-" ~" -"".=,,,,,~,'~' "."~", ,',~"''--'~ - " ="< ~,"'" """,," l' ~" '~^8" - ~"~" =' "e_ ~<.,'~" T ~C'{\+:CF U! c,' ':jlim no ,,1(:\1 I' v ~..,,; ~ I L~ Ph I: 12 1"'u'r'j','lCn' "L' 1\1'" ('t"U''''fY v 1i'..,I'-1 {';;'_r '-JV'j'Jl PENNSYl.\l,f,NV\ 1~~~Il;il"lim~""'~f"!ffli"j,!;P-'~",,",-""''1'r,'''--'>f'''i''~;;>'-'<lfIP!l~''?i~V'~,'''~_~~'~ffiI';I;,'lIl'~'~1""1""'-;<<" , ,,!Il!lI1J'fi " -" , ,"" "__ d "'" "-..4; KAREN L. rorSON/ : IN THE COURT OF COMMON PLEAS OF plaintiff . CUMBERLAND COUNTY/ PENNSYLVANIA . : vs. . NO. 00-6980 CIVIL TERM . : JOSEPH W. rorSON / : CIVIL ACTION - LAW Defendant : IN CUSTODY CUSTODY caK:ILIATI<XiI SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND 00llN'l'Y 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 Dillon W. Dotson April 18/ 1996 Mother 2. A Conciliation Conference was held on November 7/ 2000/ with the following individuals in attendance: The Mother/ Karen L. Dotson/ with her counsel, Nora F. Blair/ Esquire, and the Father/ Joseph W. Dotson, who is not represented by counsel in this matter. 3. The parties agreed to entry of an Order in the form as attached. Af~ /?" kJolJ Date i2U'~?t Dawn S. Sunday/ Esquire CUstody Conciliator