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Home My WebLink About04-0730SUE ANN SHEETS, Plaintiff V. RICHARD DITZLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 04- ~.~5 CIVIL TERM COMPLAINT FOR CUSTODY The plaintiff, Sue Ann Sheets, by her attorneys, the Family Law Clinic, sets forth the following action for shared legal and partial physical custody of her daughter Rachel Ditzler, bom 8/02/94. In support of her complaint, Plaintiff states the following: I. The plaintiffis Sue Ann Sheets, ("mother") residing at 391 Easy Road, Carlisle, PA 17013. 2. The defendant is Richard Ditzler, ("father"), residing at 94 Betty Nelson Trailer Court, Carlisle, PA 17013 3. Mother seeks partial physical custody and shared legal custody of the following child: Name Rachel Ditzler Present Residence 94 Betty Nelson Court Carlisle, PA 17013 Rachel Ditzler, hereinafter "Child" was bom out of wedlock. Date of Birth August 2, 1994 Child is presently in the custody of Richard Ditzler, who resides at 94 Betty Nelson Court, Carlisle, PA 17013. During the past five years, Child has resided with the following persons and at the following addresses: Persons Sue Ann Sheets, Danielle Sheets(sibling) Samuel Sheets(sibling) Richard Ditzler, Hope Ditzler(wife) Shelby Ditzler(child) Jeremy Ditzler(child) Jonathan Ditzler(child) Address 377 Pine Oak Lane, Carlisle, PA Dates 8/94 until 7/01 94 Betty Nelson Trailer Court, Carlisle, PA 17013 7/01 until present 6. A juvenile dependency action occurred in July of 2001 regarding Rachel Ditzler, the Name Relationship Hope Ditzler Wife Shelby Ditzler Son Jonathan Ditzler Son Jeremy Ditzler Son with the following persons: The mother of the Child is Sue Ann Sheets, currently residing at 391 Easy Road, Carlisle, PA 17013. She is single. The father of the Child is Richard Ditzler, currently residing at 94 Betty Nelson Court, Carlisle, PA 17013. He is married. 4. The relationship of the plaintiff to the child is that of mother. Mother resides with the following persons: Name Relationship Dylan Sheets Son 5. The relationship of the defendant to the child is that of father. Father currently resides minor child, subject to this complaint. The court placed the child with the father and the dependency action was discontinued. 7. Mother does not lmow of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation fights with respect to the children. 8. The best interest and permanent welfare of the children will be served by granting the relief requested because: a. Mother had primary physical custody of child from birth until July, 2001. b. Mother has had regular visits with the child from August 2003 until December 2003. c. Father has not allowed mother to regularly visit the child since December 2003. d. Father has only permitted the mother to visit the child on one occasion since December 2003. e. It would be in the child's best interest to enjoy regular and continuing contact with the mother. 9. Each parent whose parental fights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Mother requests the court grant shared legal custody of the child, and partial physical custody of the child to the mother. Date: 2~-I°1 ~0~ Jaso C Ev~ans~n'~ C~egal Intern ANNE, MACDONALD-FOX LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, Pa 17013 717/243-2968 VERIFICATION I verify that the statements made in this Custody Complaint are true and correct to the best of my personal knowledge 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. Sue Ann Sheets, Plaintiff SUE ANN SHEETS, Plaintiff RICHARD DITZLER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN CUSTODY, DIVORCE : : NO. 04- 73~) CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPER/S Kindly allow Sue Ann Sheets, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date ~ - [ q - Oq Respectfully submitted, THO~. PLXCE ~ ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243 -2968 SUE ANN SHEETS PLAINTIFF V. RICHARD DITZLER DEFENDANT IN THE COURT Ot7 COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-730 CIVIL ACTION LAW iN CUSTODY ORDER OF COURT AND NOW, Tuesday, February 24, 2004 , upon con;sideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear beibre Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, March 25, 2004 at 1:00 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. All children aae five or older may also be present at the conference. Failure to avl>ear 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 hearinlz. FOR THE COURT, By: /s/ Dawn S. Sunday. 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 betbre 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 Stree! Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 .-',?/XX,X:;~LOZ.~d EH1 JO SUE ANN SHEETS Plaintiff /N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNS yL VANIA R/CHARD DITZLER Defendant ~CIVIL ACTION LAW- CUSTODY : : NO. 04-730 CIVIL TERM VERIFICATION OF SERVICE Understanding that the making of any false statement Would subject The Family Law Clinic to the penalties of 18 Pa C S §4904 (relating to unsworn falsification to author/ties), the tmders~gned verifies that Jason C Evans maded a true copy of a CustOdy Complaint to the Defendant by placing the same in the U.S. Mail, certified no. 7002 0860 0001 5847 8349, restricted delivery, return receipt requested, postage prepaid, on the 21 st day addressed as fo/lows: of February, 2004 R/chard Ditzler 94 Betty Nelson Trailer Court Car/is/e, PA 17013 Sender's receipt no. 7002 0860 0001 5847 8349 is attached hereto and incorporated by reference. On the 8 day of September, 2003, green return receipt no. 7002 0860 0001 5847 8349 was delivered to the Family Law Clinic, bearing the signature Richard Ditzler and incorporated by reference. Ced/fled Legai Intern FAMILy LAW CLINIC 45 N. Pitt St. Dated:~ Car/isle, PA I7013 ~ 717-243-2968 . · Complete items 1,2, and 3. Nso complete " item 4 if Restricted Delivery is desired. ~ print your name and address on the reverse , e can return the card to you. . , so that w. - .... ~-~ck of the rnailp~eCe, or on the front if space permits. D. 's detiveq If yES, enter delivery [3 Agent [3 ] No postage SUE SHEETS, Plaintiff RICHARD JEREMY DITZLER, Defendant IN THE COURT OF COMMON PLEAS OF CLrMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 95-2085 CIVIL TERM SUE ANN SHEETS, Plaintiff RICHARD DITZLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, pENNSYLVANIA CIVIL ACTION - LAW NO. 04-730 CIVIL TEKM ORDER OF COURT AND NOW, this 12th day of April, 2004, upon consideration of Plaintiff's Petition To Amend Caption, the custody cases at the above numbers are consolidated at No. 95- 2085 Civil Tenn. All proceedings shall be filed and docketed at the consolidated docket number. BY THE COURT, J~W~s[ey Oler, ~ J. Family Law Clinic 45 S. Pitt Street Carlisle, PA 17013 Attorney for Plaintiff