HomeMy WebLinkAbout07-6989ANITA OTT, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. DOCKET NO. CIVIL TERM
ROBERT E. OTT,
Defendant IN CUSTODY
COMPLAINT
1. Plaintiff is Anita Ott, who currently resides at 6546 Pullhook Lane, Fayetteville,
Franklin County, Pennsylvania 17222.
2. Defendant is Robert E. Ott, who currently resides at 9 Meadow Ridge Drive,
Shippensburg, Cumberland County, Pennsylvania 17257.
3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth
for at least six (6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on May 22, 1993, in Chambersburg,
Franklin County, Pennsylvania.
COUNT I - CUSTODY
5. Paragraphs one (1) through four (4) of this Complaint are incorporated herein by
reference as though set forth in full.
6. The Plaintiff seeks custody of the following child:
Name Address DOB
Emily Ott 6546 Pullhook Lane 02/09/1998
Fayetteville, PA 17222
9 Meadow Ridge Drive
Shippensburg, PA 17257
7. The child was born in wedlock.
8. The parties presently share physical custody of the minor child.
9. During the child's lifetime, she has resided with the following persons and at the
following addresses:
Name Address Date
Robert and Anita Ott 9 Meadow Ridge Drive Birth to February 2006
Shippensburg, PA 17257
Anita Ott 6546 Pullhook Lane February 2006 to present
Fayetteville, PA 17222
Robert Ott 9 Meadow Ridge Drive February 2006 to present
Shippensburg, PA 17257
10. The mother of the child is Plaintiff, Anita Ott, who currently resides at 6546
Pullhook Lane, Fayetteville, Franklin County, Pennsylvania.
11. The father of the child is Defendant, Robert Ott, who currently resides at 9 Meadow
Ridge Drive, Shippensburg, Cumberland County, Pennsylvania.
12. The mother and father of the child are currently married.
13. The relationship of Plaintiff to the child is that of Mother.
14. The relationship of Defendant to the child is that of Father.
15. The Defendant currently resides alone.
16. The 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 any other court.
17. The Plaintiff has no information of a custody proceeding concerning the child
pending in a court of this Commonwealth.
18. The 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.
19. The best interest and permanent welfare of the child will be served by granting the
relief requested for reasons including the following:
a. The Mother has been a primary caregiver of the minor child since her birth.
She has:
i.Planned and prepared meals;
ii.Bathed, groomed and dressed the child;
iii.Purchased, cleaned and cared for the child's clothing;
iv.Arranged medical care, including trips to physicians;
v.Arranged alternative daycare;
vi.Put the child to bed nightly, attended the child in the middle of the night, and
awakened the child in the morning.
b. The child has a psychological bond with her Mother and Father.
C. Mother is able to provide a stable environment for the child.
20. Each parent whose parental rights to the child have not been terminated has been
named as parties to this action.
21. Mother believes it would be in the best interest of the child for the parents to
participate in co-parenting counseling to improve communication between the parties.
WHEREFORE, the Plaintiff requests that This Honorable Court enter an Order granting
plaintiff custody of the minor child.
D Respectfully submitted,
DATE II 20 l
ABom & KUTULA"s, L.L.P.
Kara W. Haggerty
ID No. 86914 v
36 South Hanover Street
Carlisle, PA 17013
(717) 249-0900
Attorney for Plaintiff
VERIFICATION
I, ANITA OTT, verify that the statements made in this Divorce Complaint are true and
correct to the best of my knowledge, information, and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to
authorities.
Date '?z
ANITA OTT
ANITA OTT,
Plaintiff
V.
ROBERT E. OTT,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:DOCKET NO. CIVIL TERM
IN CUSTODY
i,?,",CERTIFICATE OF SERVICE
2007, I, Kara W. Haggerty, Esquire, hereby
AND NOW this 20 ? day of I y0 -V,
Y
certify that I did serve a true and correct copy of the foregoing Complaint for Custody on the
Defendant by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid,
addressed as follows:
By First-Class Mail:
Robert E. Ott
9 Meadow Ridge Drive
Shippensburg, PA 17257
Kara W. Haggerty
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ANITA OTT
PLAINTIFF
V.
ROBERT E. OTT
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
• CUMBERLAND COUNTY PENNSYLVANIA
07-6989 CIVIL ACTION LA I
IN CUSTODY
ORDER OF COURT
AND NOW, Tuesda
it is hereb b November 27, 2007
y directed that upon consideration of the attached
parties and their respective
at 4th Floor, pective counsel a Complaint,
Cumberland Coun Courthouse
for a Carlisle on appear before Hubert
Pre-Hearing X. Gilroy, Esq. , the conciliator,
_____Frida,
if this cannot be accom 1 Conference. At such conference y, December 2g, 2007
Custody an effort will be made to res issl ei s in at '9 AM
p shed, to define and narrow the olve the
order. All children a dlSpute; or
issues to be hear
providee five or older d by the court, and to enter into a temporary
grounds for entry may also be present at the conference.
ry of a temporary or Failure to a The court hereby permanent order. ppear at the conference may
y directs the parties to furnish an
Special Relief orders, and Custod y and all existing
Y orders to the conciliator 48 protection from Abuse orders,
hours prior to scheduled hearing.
FOR THE COURT,
By' /s/ Hubert
X. Gilro Es ,
Custody Conciliator
with Disa il
The ites Actor Common Pleas of Cu
1990. For information County is required b y law to
available to disabled ind Navin comply
about accessible facilities and reasonable
wlth the Americans
must be made at least 72 g business before the court, accommodations
conference or hearing, hours prior to an please contact our officeAlividuals any hearing or business before the coin-t,
must attend the scheduled
YOU SHOULD TAKE THIS PAPER you
HAVE AN ATTORNEY OR
TO Y
FORTH BELOW Tp FINDR CANNOT AFFO OUR ATTORNEY AT ONCE. NE, OUT WHERE YO? ON GE ? TO OR TELEPHONE THE YOU DO NOT
LEGAL HELP. OFFICE SET
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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ANITA OTT,
PLAINTIFF
V.
ROBERT E. OTT,
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2007-6989
: IN CUSTODY
ANSWER TO COMPLAINT FOR CUSTODY AND
COUNTERCLAIM
AND NOW comes Defendant, Robert E. Ott, by and through his attorney, Hannah
Herman-Snyder, Esquire, and the law firm of Griffie & Associates, and avers as follows:
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
COUNT I - CUSTODY
5. Defendant's responses to Paragraphs one (1) through four (4) of the Complaint
are incorporated herein by reference as if set forth in their full text.
6. Admitted in part. Denied in part. It is admitted that the Plaintiff seeks custody of
Emily Ott. It is further admitted that Emily Ott resides at 9 Meadow Ridge Drive,
Shippensburg, PA, 17257 and that her date of birth is February 9, 1998. It is
denied that she also resides at 6546 Pullhook Lane, Fayetteville, PA, 17222,
although she is there for periods of partial custody with Plaintiff.
14. Admitted.
15. Admitted.
16. Admitted.
IT Admitted.
18. Admitted
19. Denied. It is denied that the best interest and permanent welfare of the child will
be served by granting the relief requested for the reasons including the following:
a. It is denied that Mother has been the primary caregiver of the minor child
since her birth. It is averred that Father has maintained primary physical
custody of the child since February 2006, at which time the parties
separated. It is further averred that prior to the parties separation, they
shared equally in parenting duties as set forth below, however, since
Father has maintained primary physical custody, said parenting duties
have been performed primarily by him.
i. It is denied that Mother planned and prepared meals. It is averred
that Father plans and prepares the majority of the meals since the
parties' separation.
ii. It is denied that Mother has bathed, groomed, and dressed the
child. It is averred that Father has primarily bathes, grooms, and
dresses the child since the parties' separation.
iii. It is denied that Mother purchased, cleaned and cared for the
child's clothing. It is averred that Father primarily purchases,
cleans and cares for the child's clothing since the parties'
separation.
iv. It is denied that Mother arranged medical care, including trips to
the physicians. It is averred that Father primarily arranges medical
care, including trips to the physicians since the parties' separation.
V. It is denied that Mother arranged alternative daycare. It is averred
that Father primarily arranges alternative daycare since the parties'
separation,
vi. It is denied that Mother put the child to bed nightly, attended the
child in the middle of the night, and awakened the child in the
morning. It is averred that Father primarily puts the child to bed
nightly, attends the child in the middle of the night and awakens
the child in the morning since the parties' separation.
b. Admitted.
C. Denied. It is denied Mother is able to provide a stable environment for the
child. It is averred that Mother and her paramour, James Leaman, with
whom she resides, constantly fight and provide quite an unstable
environment for the child.
20. Admitted.
21. Mother's beliefs can neither be admitted or denied.
WHEREFORE, the Defendant requests this Honorable Court deny Plaintiffs request for
custody of the minor child.
COUNTERCLAIM
22. Paragraphs one through twenty (1-21) are incorporated herein as if set forth in
their full text.
23. It is in the best interest and permanent welfare of the child to grant the relief
requested because:
a. Defendant has been and continues to be the primary custodian of the
parties' child from the time the parties separated through the present, with
the parties having shared responsibilities prior to that time.
b. Plaintiff has shown an inability to provide for the physical or emotional
needs of the child.
C. The child attends school in the Shippensburg School District, now being in
fourth grade, and has expressed her wishes to continue to attend school in
said school district.
d. Defendant can provide a stable household for the child.
e. The child has expressed her desire to reside with Defendant on a primary
basis.
WHEREFORE, Defendant requests your Honorable Court to schedule a Custody
Conciliation Conference, followed by a hearing, at which time he should be granted primary
physical custody of the child.
1') - 1q- (A1
Date
Respectfully submitted,
Hannah Herman-Snyder, Esqui
Attorney for Defendant
GRIFFIE AND ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4904, relating to unsworn falsifications to authorities.
DATE:- /2 3 -10 ROBERT E. OTT
c
pan - ?
ROBERT E. OTT IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
2007-6989 CIVIL ACTION LAW
ANITA K. OTT
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Thursday, December 27, 2007 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, January 23, 2008 at 1:30 PM
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. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ Jacqueline M. Verney, Esq.
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
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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ANITA OTT,
Plaintiff
v
ROBERT E. OTT,
Defendant
JAN 0 2 20084'')
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
NO. 2007-6989
IN CUSTODY
COURT ORDER
AND NOW9 this 2A day of January, 2008, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
1. The mother, Anita Ott, and the father, Robert E. Ott, shall enjoy shared legal custody
of Emily E. Ott, born February 9,1998.
2. Physical custody shall be handled pursuant to a schedule generally along the lines as
the parties have employed over the past year. It is anticipated that both parents will
communicate with each other with respect to arranging a schedule that provides each
parent with liberal periods of physical custody of the minor child. Father shall notify
Mother each week when he receives his work schedule so that the parties may work
out an arrangement for physical custody during the upcoming week. The parties shall
exchange telephone numbers, and also ensure that the other parent knows where they
may be reached so that they can communicate on the scheduling of a custody
arrangement. Communications between the parties shall be limited only to matters
relating to custody and exchange of custody and there shall be no discussions on other
unrelated issues.
3. Legal counsel for the parties shall have a telephone conference with the Custody
Conciliator on Friday, February 29, 2008 at 8:30 a.m. At that time, there will be
discussion with respect to whether a modification needs to be implemented on the
Custody Order. Additionally, if either party desires a hearing before the Court at
time, the Conciliator may recommend that this case be scheduled for a hearing before
the Court.
4.
In the event there are any major issues that require immediate attention by the Court,
counsel for either party may contact the Conciliator directly to schedule another
conciliation conference as needed.
cc: Kara W. Haggerty, Esquire
Hannah Herman-Snyder, Esquire
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M.NFI r YYA 10
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ANITA OTT,
Plaintiff
v
ROBERT E. OTT,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2007-6989
IN CUSTODY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF
PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following
report:
1. The pertinent information pertaining to the child who is the subject of this litigation
is as follows:
Emily E. Ott, born February 9,1998
2. A Conciliation Conference was held on December 28, 2007, with the following
individuals in attendance:
The mother, Anita Ott, with her counsel Kara W. Haggerty,Esquire, and the father,
Robert E. Ott, with his counsel Hannah-Herman Snyder, Esquire.
3. The parties agreed to the entry of an Order in the form as attached.
Date: /) --V -- U `7 a?'-x )'?
Hubert X. Gilroy, Esq
Custody Conciliator
ANITA OTT, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v
ROBERT E. OTT,
Defendant
: NO. 2007 - 6989 CIVIL TERM
IN CUSTODY
CIVIL ACTION - LAW
PRAECIPE FOR ENTRY OF APPEARANCE/WITHDRAWAL
TO THE PROTHONOTARY:
Please enter the appearance of Jane Adams, Esquire, as Attorney of record for
Robert E. Ott, Defendant in the above-captioned matter.
o.,e
Respectfully Submitted:
? a Adams, Esquire
1 W. South St.
Carlisle, Pa. 17013
(717) 245-8508
Please withdraw the appearance of Hannah Herman-Snyder, Esquire, as
Attorney of record for Robert E. Ott, Plaintiff in the above-captioned matter.
Respectfully Submitted:
Date: (?l ?6
e an nyder, Esquire
H nover t.
Carlisle, Pa. 17013
(717) 243-5551
_, co
ANITA OTT,
Plaintiff
vs.
ROBERT E. OTT,
Defendant
JUL 2 9 20086,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2007-6989
IN CUSTODY
COURT ORDER
AND NOW, this LO? day of , 2008, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed that this Court's prior Order of January 3, 2008, is
vacated and replaced with the following Order:
1. The mother, Anita Ott, and the father, Robert E. Ott, shall enjoy shared legal custody
of Emily E. Ott, born February 9, 1998.
2. The parties shall share physical custody of the minor child on a week on/week off
basis with the exchange and time being Mondays after school unless agreed
otherwise by the parties.
3. Holidays shall be handled as follows:
A. Christmas shall be divided into two blocks. Block A shall be from
December 24th at noon thru December 25th at noon with Block B being from
December 25th at noon thru December 26`h at noon. Mother shall have Block
A and Father shall have Block B in even years with the parties alternating
thereafter.
B. Easter and Thanksgiving shall be shared by the parties with the days being
divided as the parties may agree.
C. The parties shall alternate custody on New Year's Day, Memorial Day, July
4th, Labor Day and Halloween (which shall be the night scheduled for trick-
or-treat). Mother shall have Labor Day, 2008, with the parties alternating
thereafter.
D. Mother shall always have custody on Mother's Day and Father shall always
have custody on Father's Day.
E. The parties agree to equally share the day of the child's birthday.
3
F. The parties agree to allow the non-custodial parent a period of time on that
parent's respective birthday.
r
4. Each party shall be entitled to two weeks of vacation with the child during the
summer break which weeks may be scheduled consecutively. The parties will give
the parent notice by May ? of each year. The parties shall provide each other with
their itinerary including, but not limited to, dates, times, specific address or location,
land line telephone number and other contact information.
5. Unless agreed otherwise by the parties, the child shall continue to attend the
Shippensburg Area School District.
6. Based upon an agreement of the parties, the Father shall maintain health insurance
coverage for the child and the parties shall equally share in the out-of-pocket
expenses incurred for medical purposes for the child. The parties further agree that
neither party shall file a complaint for support with the Cumberland County
Domestic Relations office or otherwise, and the parties shall share all out-of-pocket
expenses for the child. This paragraph is subject to the standard law relating to
support obligation.
7. Neither parent shall do anything which may estrange the child from the other party,
injure the opinion of the child as to the other party, or which may hamper the free
and natural development of the child's love and affection for the other party.
8. The parties may modify this Order as they agree. Absent an agreement, this Order
shall control. In the event either party desires to modify this Order, they may
petition the Court to have the case again scheduled with the Custody Conciliator for
a conference.
COURT,
Edward E. Guido, Judge
cc: ane Adams, Esquire
,,Xara Haggerty, Esquii
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ANITA OTT,
Plaintiff
vs.
ROBERT E. OTT,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2007-6989
IN CUSTODY
Prior Judge: The Honorable Edward E. Guido
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF
PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report:
1. The pertinent information pertaining to the child who is the subject of this litigation is as
follows:
Emily E. Ott, born February 9, 1998
2. A Conciliation Conference was held on July 17, 2008, with the following individuals in
attendance:
The mother, Anita Ott, who appeared with her counsel, Kara W. Haggerty,
Esquire, and the father, Robert E. Ott, with his counsel, Jane Adams, Esquire.
3. The parties agreed to an entry of an Order in the form as attached.
V?-
Date: July , 2008 a?
Hubert X. roy, Esquire
Custody nciliator
ANITA OTT
PLAINTIFF
V.
ROBERT E. OTT
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2007-6989 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Wednesday, September 29, 2010 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, October 26, 2010 at 8:30 AM
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. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ Jacqueline M. Verney, Esq.
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.
19 /`0 Cumberland County Bar Association -?
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C?.. n 32 South Bedford Street
Carlisle, Pennsylvania 17013 -;, C3?
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36 South Hanover Street ~ r ' ~ a ~ ~'~' ~ ~ t
Carlisle, PA 17013
(717)249-0900
ANITA OTT, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. :DOCKET NO. CIVIL TERM
. ~aD7 s G Qb~
ROBERT E. OTT,
Defendant IN DIVORCE
AFFIDAVIT OF SERVICE
I, Kara W. Haggerty, Esquire, hereby certify that I did serve a true and correct copy of the
Petition for Modification of Custody, upon the Defendant, by depositing, or causing to be
deposited, same in the U.S. mail, certified, restricted delivery, postage prepaid, on Robert E. Ott, at
Carlisle, Pennsylvania, addressed as follows:
9 Meadow Ridge Drive
Shippensburg, PA 17257
Return card acknowledging receipt on September 29, 2010, is attached as Exhibit "A".
Date: ~
ABOM & SUTULAKIS, LLP
~•
Kara W. Haggerty, squire
36 South Hanover Street
Carlisle, PA 17013
(717)249-0900
Attorney for Plaintiff
I.D. No: 86914
~,QNMp1eAi+lbart~s 1, 2, artd3. Also complete
~ a n weed ~rery ~ desired.
t lihht your name and address on the reverse
so that we can return the card to you.
i /Ukac~t this card to the back of the malipiece,
01' On the front ff space permits.
f. Article Addressed tos
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D. Is delNery address dfRererrt from Item 1? L] Yes
H YE$, enter delivery address below: ^ No
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4. Restricted Delfirery? (Extra Fee) ^ Yes
2. ArtidetJumber ~oyo a29~ ooao 6471 5107
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EXHIBIT `A"
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ANITA OTT, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY,PENNSYLVANIA
V. :2007-6989 CIVIL ACTION -LAW
ROBERT E. OTT, ~ c' a
~''
Defendant : IN CUSTODY r~: ~ ~ ,.~,~ -*~
~~ rv c~°
ORDER OF COURT ~ ~ -T -°T,
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AND NOW, this
day of r , 2010, upon ~ ~
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The prior Order of Court, dated August 4, 2008 shall remain in full force
and effect with the following addition.
2. The parties shall cooperate with a custody evaluation performed by Dr.
Lehman. The costs shall be divided as agreed by the parties.
3. 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. Another
Conciliation Conference may be scheduled at the request of either party.
B E COUR ,
Edward E. Guido, J.
cc: bra W. Haggerty, Esquire, Counsel for Mother
Jane Adams, Esquire, Counsel for Father
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OCT 2 6 2010
ANITA OTT, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY,PENNSYLVANIA
V. :2007-6989 CIVIL ACTION -LAW
ROBERT E. OTT,
Defendant : IN CUSTODY
PRIOR JUDGE: Edward E. Guido, J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY 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
Emily E. Ott February 9, 1998 shazed
2. A Conciliation Conference was held in this matter on October 26, 2010,
with the following individuals in attendance: The Mother, Anita Ott, with her counsel,
Kaza W. Haggerty, Esquire, and the Father, Robert E. Ott, with his counsel, Jane Adams,
Esquire.
3. The Honorable Edward E. Guido previously entered an Order of Court
dated August 4, 2008 providing for shared legal and shazed physical custody on a week
on/week off basis.
4. The parties agreed to an Order in the form as attached.
/0-o1~n~lri
Date
,~
acq line M. Verney, Esquire
Custody Conciliator
&U ULAKIS 1113 APR 1 '
Jason P.Kutulakis,Esquire �; �l�'�
Attorneyl.D.#: 80411 RL��#0 CGUYL+.jb,
2 West High Street �� st 1
Carlisle,PA 17013 `
(717)249-0900
ANITA OTT, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY,PA
V. NO. 2007-6989
ROBERT E. OTT, CIVIL ACTION -LAW
Defendant IN CUSTODY
PETITION TO MAKE RULE ABSOLUTE
AND NOW, this 16th day of April, 2013, comes Petitioner,Jason P. Kutulakis, Esquire of
ABOM &KUTULAKIS, LLP who respectfully avers the following:
1. On January 29, 2013, Jason Kutulakis, Esquire, filed a Petition to Withdraw as Counsel in
the above-captioned matter.
2. A Rule to Show Cause was issued on February 5, 2013, upon the Respondents to show
why Kara W. Haggerty, Esquire, and the law firm of Abom & Kutulakis, LLP, should not
be permitted to withdraw as counsel for Plaintiff, Anita Ott. However, we did not receive
a certified copy of the Court Order until March 20, 2013.
3. On March 20, 2013, a copy of Order of Court was sent to Plaintiff, Anita Ott and Jane
Adams, Esquire, counsel for Defendant.
4. More than twenty (20) days have elapsed and Plaintiff, Anita Ott and Jane Adams,
Esquire, counsel for Defendant have failed to file a response to the Order of Court with the
Rule to Show Cause.
5. Undersigned counsel is unaware of any objections to Kara W. Haggerty, Esquire, and
Abom & Kutulakis, LLP's Motion to Withdraw having been filed in this matter as of the
filing of the instant Motion.
WHERERFORE, undersigned counsel respectfully requests this Honorable Court grant
his request to withdraw as counsel in this matter.
Respectfully submitted,
ABOM &KUTULAKIS, L.L.P.
Date
Jas n P. K
2 West High Street
Carlisle, PA 17013
(717) 249-0900
Attorney ID No. 80411
e a
CERTIFICATE OF SERVICE
AND NOW, this 16th day of April, 2013, I, Sally Evans of ABOM & KUTULAKIS,
L.L.P., hereby certify that I did serve or cause to be served a true and correct copy of the
foregoing Petition to Make Rule Absolute by First Class U.S. Mail addressed to the following:
Jane Adams,Esquire
17 West South Street
Carlisle,PA 17013
Attorney for Defendant
AND
Anita (Ott) Leaman
6546 Pullhook Lane
Fayetteville,PA 17222
Sally Evans
3
ANITA OTT, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PA
v. NO. 2007-6989
ROBERT E. OTT, •
CIVIL ACTION -LAW
Defendant IN CUSTODY rri 7-1
Ill 77
2Z-7:;411 :7.'3 Frl
co
r
`-)
, •
ORDER OF COURT ,--)
AND NOW, this/ 70lay of/21,00/6 , 2013,upon consideration of the
Motion to Make Rule Absolute, said Motion is hereby GRANTED. Kara W. Haggerty, Esquire
and Abom&Kutulakis, L.L.P. are hereby granted leave to Withdraw as Counsel for the above-
, named Plaintiff, Anita Ott.
BY THE COURT:
Edward E. Guido, J.
Distribution:
Jason P. Kutulakis, Esquire
v Jane Adams, Esquire 141a'lle
,/ Anita (Ott) Leaman fi
6546 Pullhook Lane 41181 0
Fayetteville,PA 17222