The URL can be used to link to this page

Home My WebLink About99-05200r?- `,,ti ,?,. <-,;a -, 1 L .? KAREN L. DOTSON, Plaintiff VS. JOSEPH W. DOTSON, Defendant AND NOW, attached complaint, it their respective counse . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY NO. yr Sam ?(f? ORDER OF COURT 1999, upon consideration of the directpA th#t tt;p parties and ?L day of {Y ?otr?' r , 1999, a ?.m. •f or a r e -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: IJL 6acQ ,' x 1( 4 Custody Concilia r l 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 by made at least 72 hours prior to any hearing or business before the court. You must attend scheduled conference or 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 CARLISLE, PA 17013 717-249-3166 ..hri\;?.?I,:i ...?,?? L. DOTSON, Plaintiff VS. H W. DOTSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY NO. N O T I C E TO D E P E N D You have been sued in court. If you wish to defend against e claims set forth in the following pages, you must take action thin twenty (20) days after this complaint and notice are rued, by entering a written appearance personally or by attorney d filing in writing with the court your defenses or objections the claims set forth against you. You are warned that if you it to do so the case may proceed without you and a judgment may entered against you by the court without further notice for any ney claimed in the complaint or for any other claim or relief quested by the Plaintiff. You may lose money or property or her rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE CE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE PA 17013 717-249-3166 Mary A.' Etter Dissinger, squire Attorney for Plaintiff L. DOTSON, Plaintiff Vs. H W. DOTSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY NO. y9 s.zr 62? Ti. COMPLAINT FOR CUSTODY 1. Plaintiff is Karen L. Dotson, residing at an undisclosed location in Dauphin County, Pennsylvania. Defendant is Joseph W. Dotson, residing at 108 North 2nd t, Wormleysburg, Cumberland County, Pennsylvania. Plaintiff seeks custody of the following child: Present Residence Age W. Dotson Undisclosed location in 3 Dauphin County, PA 4. The child was not born out of wedlock. 5. The child is presently in the custody of Plaintiff who resides at an undisclosed location in Dauphin County, Pennsvlvania. During the past five years, the child has resided with the lowing persons at the following addresses: s Addresses Date L. Dotson 108 North 2nd Street Birth to W. Dotson Wormleysburg, PA 8/18/99 Karen L. Dotson Undisclosed location in Since Dauphin County, PA 8/19/99 7. The mother of the child is Karen L. Dotson who currently resides at an undisclosed location in Dauphin County, Pennsylvania. 8. She is married to Joseph W. Dotson. 9. The father of the child is Joseph W. Dotson who currently resides at 108 North 2nd Street, Wormleysburg, Cumberland County, Pennsylvania. He is married to Karen L. Dotson. The relationship of Plaintiff to the child is that of mother. Plaintiff currently resides with the minor child, Dillon W. 12. The relationship of Defendant to the child is that of father. The Defendant currently resides alone. 13. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 14. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 15. 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. The best interest and permanent welfare of the child will be ved by granting the relief requested because Plaintiff has been primary caretaker since birth and has been responsible for viding a stable and nurturing environment in which to raise the ld. 17. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: None. WHEREFORE, Plaintiff requests the Court to grant custody of child to Plaintiff. Respectfully Submitted: DISSINGER i DISSINGER By;/!u . ?C-V??--moo (° Mary A. Etter Diss ng6k, Esquire Attorney for Plaintiff Supreme Court I.D. 127736 28 North 32nd Street Camp Hill, PA 17011 717-975-2840 VERIFICATION I, Karen L. Dotson, verify that the statements made in the Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 54904 relating to unsworn falsification to authorities. Karen L. Dotson, Plaintiff C, i cn U 'J n n FF :?H 2 ;OZv N ;5 z z w z }a °N° O f1 W V y U Z O Fw E C ww? a -H Q f0 UO o ry 41 ra Q [ >4 Z ? Sw Q ms i a 0.'Q E -' 5 y x h Y Un 2'6 199?'-. 1 KAREN L. DOTSON, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA Vs. CIVIL ACTION - CUSTODY JOSEPH W. DOTSON, Defendant NO. 99-5200 AFFIDAVIT OF MAILING COMMONWEALTH OF PENNSYLVANIA . ss .. COUNTY OF CUMBERLAND Mary A. Etter Dissinger, Esquire, the attorney for Plaintiff, being duly sworn according to law, says that she mailed by certified, restricted mail, return receipt requested, a true and correct copy of Plaintiff's Complaint for Custody in this action to the Defendant at his residence, and that Defendant did receive same as evidenced by the signed receipt attached hereto as Exhibit "An Mary A. Etter Dissinger,Es Attorney for Plaintiff 28 North 32nd Street Camp Hill, PA 17011 717-975-2840 Sworn to and subscribed before me this _21-" day of, : anT:,o?L r 1999. A Notary Public CAE0IENE ? C°mP Ni to'o, ??^,A?bAc MY romnYrian Eyler AprE >D, 2001 1 n• t? 0 u 3 a T N O Complete Memo I Milo, 2 for additional Nruices. C 1 also wish to receive the follow- Ing services (for an extra fee): omplete hem 3,4a, WW 4b. C Print your name aM addreea on the mom of this to= w that wa car, alum INS card to you. OMamMp tNa fom to the from of the maMyisce, or on the back If apace does rwl ' 1. ? Addressee's Address E KResbicled Delivery owrbe Realm RecaiPf Repueefe wthemaepiwebelowthe,W number. C The Retum Receipt will show to whom the adicle wee delivered end me date - "y delivered. . Article Addressed to: 4a. Article Number l ' ln W , _7?ofsoLj Tose 7 7 S ? P 40 oOMCe ' ? / d 8 f'/,Ili -2A9 Sfreet 13 Registered d(Certilled 1 n y A4 10Y'M?e siw ?ExpressMail ?Insured ? ? ,/ /7DU? 7 J RetumReceiptforMeichandieo ?COD 7. Date of Delivery t a° Race ved By: (Pont Name) 11 u. Addressee's Address PaPfifrequested and c fee Is paid) R O U. p ?Sov F 1025e5n938-00=3 EXHIBIT "A" ? ,Y '" ' ° ' S ??? ?,?. Y a F?.: ?_ b? •rn '- l:J a, ?.? ?zz z L: 1`l. f,1 Cf' ? 1 ? ? r OCT 19 KAREN L. DOTSON, Plaintiff VS. JOSEPH W. DOTSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-5200 CIVIL TERM CIVIL ACTION - CUSTODY ORDER AND NOW this {4, day of_QC t&,&- 1999, it being reported to the Conciliator that the parties have reached an agreement which makes further proceedings unnecessary, the undersigned Conciliator hereby relinquishes jurisdiction and returns the matter to the Court Administrator. If either of the parties wishes further proceedings in this action, they should petition the Court anew. cc: Mary A. Etter Dissinger, Esquire Mr. Joseph W. Dotson 108 North Second Street Wormleysburg, PA 17043 FOR THE COURT, MICHAEL L. BANGS Custody Conciliator C Co u.,o ' 'Q 3 - > cn - U3 Jz Ott; U in E LL ? O rn ? U