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Home My WebLink About04-1535 ODELIT PRITCHETT Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. RANDALL CRAIG PRITCHETT, Defendant - /' NO. 04 - 15.jj CIVIL TERM CUSTODY COMPLAINT FOR CUSTODY I. The plaintiff is Ode lit Pritchett. Plaintiff's permanent residence is 1715 English Drive, Mechanicsburg, PA 17055. 2. The defendant is Randall Craig Pritchett, residing at 13 Big Horn Avenue, Mechanicsburg, P A 17055 3. The plaintiff seeks custody of the following children: Name Lucas Pritchett Present Residence 1715 English Drive Mechanicsburg, P A Age 07/09/90 DOB, 13 years old. Lex Pritchett 1715 English Drive Mechanicsburg, P A 02/24/95 DOB, 8 years old Kai Pritchett 1715 English Drive Mechanicsburg, P A 11125/96 DOB, 7 years old 4. The children, Lucas Pritchett, Lex Pritchett and Kai Pritchett, were not born out of wedlock. 5. The children are presently in the custody of the mother, who resides at 1715 English Drive, Mechanicsburg, PA 17055. 6. During Lucas Pritchett's lifetime, he has resided with the following persons and at the following addresses: Name Address Date Odelit Pritchett (mother) Randall Pritchett (father) 6511 23'd Street Lubbock, TX Birth - Springl92 Odelit Pritchett (mother) 8004 Meadowbrook Dr. Gerald Garro (grandfather) Watauga, TX Haydee Garro (grandmother) Ode1it Pritchett (mother) Randall Pritchett (father) Lex Pritchett (brother) Odelit Pritchett (mother) Randall Pritchett (father) Lex Pritchett (brother) Odelit Pritchett (mother) Randall Pritchett (father) Lex Pritchett (brother) Kai Pritchett (brother) Randolph Pritchett (grandfather) Jeanie Pritchett (grandmother) Odelit Pritchett (mother) Randall Pritchett (father) Lex Pritchett (brother) Kai Pritchett (brother) Odelit Pritchett (mother) Lex Pritchett (brother) Kai Pritchett (brother) North Richland Hills, TX Millersburg, P A 13 Big Horn Avenue Mechanicsburg, P A 1715 English Drive Mechanicsburg, P A 1715 English Drive Mechanicsburg, P A Spring/92 - Spring/93 Spring/93 - 8/95 8/95 - 8/96 8/96 - 6/98 6/98 - 4/03 4/03 - present 7. During Lex Pritchett's lifetime, he has resided with the following persons and at the following addresses: Name Odelit Pritchett (mother) Randall Pritchett (father) Lucas Pritchett (brother) Odelit Pritchett (mother) Randall Pritchett (father) Lucas Pritchett (brother) Address North Richland Hills, TX Millersburg, P A Date Spring/93 - 8/95 8/95 - 8/96 Odelit Pritchett (mother) Randall Pritchett (father) Lucas Pritchett (brother) Kai Pritchett (brother) Randolph Pritchett (grandfather) Jeanie Pritchett (grandmother) Odelit Pritchett (mother) Randall Pritchett (father) Lucas Pritchett (brother) Kai Pritchett (brother) Odelit Pritchett (mother) Lucas Pritchett (brother) Kai Pritchett (brother) 13 Big Horn Avenue Mechanicsburg, P A 8/96 - 6/98 1715 English Drive Mechanicsburg, P A 6/98 - 4/03 1715 English Drive Mechanicsburg,PA 4/03 - present 8. During Kai Pritchett's lifetime, he has resided with the following persons and at the following addresses: Name Address Date Odelit Pritchett (mother) Randall Pritchett (father) Lucas Pritchett (brother) Lex Pritchett (brother) Randolph Pritchett (grandfather) Jeanie Pritchett (grandmother) Odelit Pritchett (mother) Randall Pritchett (father) Lucas Pritchett (brother) Lex Pritchett (brother) Odelit Pritchett (mother) Lucas Pritchett (brother) Lex Pritchett (brother) 13 Big Horn Avenue Mechanicsburg, P A 8/96 - 6/98 1715 English Drive Mechanicsburg, P A 6/98 - 4/03 1715 English Drive Mechanicsburg, P A 4/03 - present 9. The mother of the children is Ode lit Pritchett, currently residing at 1715 English Drive, Mechanicsburg, P A 17055. 10. She is and remains married to the defendant. II. The father of the children is Randall Pritchett, currently residing at 13 Big Horn Avenue, Mechanicsburg, PA 17055. 12. He is and remains married to the plaintiff. 13. The relationship of plaintiff to the children is that of mother. 14. The plaintiff currently resides with the following persons: Name Relationship Lucas Pritchett Son Lex Pritchett Kai Pritchett Son Son IS. The relationship of defendant to the children is that of father. 16. The defendant currently resides with the following persons: Name Relationship Randolph Pritchett Father Jeanie Pritchett Mother 17. The plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody ofthe children in this or another court. 18. The plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 19. The plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 20. The best interest and permanent welfare of the children will be served by granting the relief requested for reasons including, but not limited to the following: a) The mother has provided for the children's emotional, physical, educational, and medical needs including establishing a stable home environment for them, and she can continue to provide for the children. b) The mother has a stable job and can provide a stable home environment for the children. c) The mother is the parent most capable of ensuring contact and communication between the children and the non-custodial parent. d) The father has not acted in the best interest of the children in ways including but not limited to the following: i) The father has suffered from a drug addiction causing him to be incapable of providing for the children's emotional, physical, educational or medical needs on a full.time basis. ii) The father has not been employed for over one year and cannot provide financially for the children on a full-time basis. iii) The father has taken little initiative to contact or see the children since the time he and the mother were separated in April 2003. 21. The mother requests that the court order the following: a. Grant her primary physical and legal custody of the children. b. Grant the father periods of partial custody at times mutually agreed upon by the parties. 22. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, the plaintiff requests this Court to grant her primary physical and legal custody of the children. Plaintiff further requests any other relief that is just and proper. Respectfully submitted, I oun Cur~j If'l... V~. Jessica Diamondstone Attorneys for Plaintiff Mid Penn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 VERIFICATION The above-named PLAINTIFF, odelit Pritchett, verifies that the statements made in the above complaint For Custody are true and correct. plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.s. ~4904, relating to unsworn falsification to authorities. Date: '1-9-D~ )JolJJ e-Jr~aJ Odelit pritchett ODELlT PRITCHETT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN1Y PENNSYL VANIA vs. No. 04- CIVIL TERM RANDALL CRAIG PRITCHETT, Defendant IN CUSTODY AFFIDAVIT OF SERVICE BY MAIL I, Jessica Diamondstone, do hereby swear that I served Randall Craig Pritchett with a Complaint For Custody and a Petition for Special Relief on 1Ip/,'/ /2- ,2004 by certified mail, return receipt, restricted delivery, to the person and address below: Randall Pritchett 13 Big Horn Avenue Mechanicsburg, P A 17055 I, Jessica Diamondstone, verify that the statements made in this Affidavit of Service 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 falsification to authorities. Date: /2 -4:v. j '24:If SigMrure --/~ ""--.;...;,,;,~~ l~/;;;"'enn ' ''3.or:. 8 ;r1in~ f=t,YN 1'-'Jf';:'!P-::~ -;7"n 13 .ItJ,I'01',' . ' (""7\ ,}:"l~~~O:!()'-) l' ':r;':"')~),;,"C8 ~l-1..'\) "-'-'- , '. ~-.-..----- ODELlT PRITCHETT, Plaintiff IN THE COURT OF COMMON PLEA:) Qf CUMBERLAND COUNTY. PENNSYLVANIA v. NO. 04- ! ~ 1 -.- 'J CIVIL TERM RANDALL CRAIG PRITCHETT, Defendant CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Odelit Pritchett, PlaintifC to proceed in Conna pauperis. I, Jessica Diamondstone, attorney for the party proceeding in forma pauperis, certifY that I believe the party is unable to pay the costs and that I al\1 providing free legal services to the party. " - .'1 .,/:",,,- ".",'; ,,,,/;::",.' " ,,~, Jj/' 4.... .'.'" I /r-j" '- .,.,,' -----L_~~~.___. Jessica Diamondstone Attorneys j(\r Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ... " ~ , . (\~, "-_n 1..:. '> ':.::) c.....:.;. ,/ :;h ODELIT PRITCHETT PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 04-1535 CIVIL ACTION LAW RANDALL CRAIG PRITCHETT DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, April 16, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, May 20, 2004 at 9:30 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. 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. The court hereby directs the parties to furnish any aud all existin'g Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinj!;. FOR THE COURT. By: Isl Hubert X. Gilroy, F.sq. Custody Conciliator mhc 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 Stred Carlisle. Pennsylvania 17013 Telephone (717) 249-3166 .~~# ~~~ he7.oe-;, .~ :z:~ ~ .~t:l. V/:S~ ::s 7 :7- ~"'Y ~,~ ,4Clc7l"'.fi \/;,,'\:\//\'1 Ait\'nC<~,\ SI :f;":1 02 t'dV tluaz "':,--i -.IV VINV/\l)\~)i\lt{jd '[Mnt'''''' ,-" "-'CI '-"-'1'1'(1'\ A..." .(";" '",<.,,-,. ",,> _ h..J Sf :8 Hd S I Nnr ~naz N1VWNOH.LOI:kJ 3Hl ::10 3:)13:10-03113 -- JUN 1 4 2004~ ODELIT PRITCHETT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW RANDALL CRAIG PRITCHETT, Defendant NO. 2004 - 1535 IN CUSTODY COURT ORDER AND NOW, this ~day of June, 2004, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The mother, Odelit Pritchett, and the father, Randall Craig Pritchett, shall enjoy shared legal custody of Lucas Pritchett, born July 9, 1990, Lex Pritchett, born February 24, 1995, and Kai Pritchett, born November 25, 1996. 2. Mother shall enjoy primary physical custody of the minor children. 3. Father shall enjoy liberal times of temporary custody with the minor children at such times as agreed upon by the parties. 4. On major holidays, the parties shall share or split custody of the minor children pursuant to a schedule arranged between the parties. 5. Mother and father shall notify the other parent with respect to any and all medical emergencies, educational issues or social issues that normally should be shared with the other parent. 6. Neither party shall make any disparaging comments concerning the other parent to the children which would in any way estrange the children from the other parent. 7. This Order acknowledges that the parties have agreed that mother may relocate out of the Commonwealth of Pennsylvania and take the children with her without further Order of this Court. Under such circumstances, it is anticipated that the parties themselves would work out an arrangement for father to exercise periods of temporary custody with the children. In the event the parties are unable to work out such an arrangement for temporary custody, this Court will retain jurisdiction on that issue. It is understood that mother would not relocate before August 1, 2004. 8. This Order is entered pursuant to an agreement reached by the parties at a custody conciliation conference. In the event the parties desire to modify this order, they may petition the Court at any time to have the case again scheduled for a conference with the Custody Conciliator. BY THE COURT, J cc: Jessica Diamondstone, Esquire Susan K. CandieUo, Esquire Randall C. Pritchett ~~.4. (,_/{,_tJ<1 c;L o JUN 1 4 2004 j ODELlT PRITCHETT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW RANDALL CRAIG PRITCHETT, Defendant NO. 2004 - 1535 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 childrlm who are the subject of this litigation is as follows: Lucas Pritchett, born July 9, 1990, Lex Pritchett, born February 24, 1995, and Kai Pritchett, boru November 25, 1996. 2. A Conciliation Conference was held on June 4, 2004, with the following individuals in attendance: The mother Odelit Pritchett, with her counsel, Jessica Diamondstone, Esquire, and the father, Randall Craig Pritchett, who appearedl without counsel. However, Attorney Susan K. Candiello did contact the Conciliator via telephone at the time of the conference and indicated that she had been counselling Mr. Pritchett. 3. The parties indicated that they have an agreement 011 custody, and the Conciliator recommends the Court sign the attached Order in accordance with that agreement. tel rr f if V. DATE Hubert X. Custody