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Home My WebLink About09-4677 DAVID G. KREITZER Plaintiff, V. LOIS A. KREITZER Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09- yG ?7 CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY NOW comes the Plaintiff, David G. Kreitzer, by and through his attorney, Mark F. Bayley, Esquire, and presents the within complaint for custody, representing as follows: 1. The Plaintiff, David G. Kreitzer, is an adult individual residing at 190 Alters Rd., Carlisle, PA 17013. 2. The Defendant, Lois A. Kreitzer, is an adult individual residing at 18 Mountain View Terrace, Newville, PA 17241. 3. Plaintiff seeks custody of the following children: Name Present Residence Age D/OB David Kreitzer 18 Mountain View Terrace 17 7/25/1991 Newville Robert Kreitzer 190 Alters Rd. 16 5/17/1993 Carlisle Cheyenne Kreitzer 18 Mountain View Terrace 9 7/8/2000 Newville 4. The children were not born out of wedlock. 5. The relationship of the Plaintiff to the child is that of natural Father. He is married. 6. The relationship of the Defendant to the children is that of natural Mother. She is married. 7. During the past five years, the children have resided with: Name Address Date David and Lois Kreitzer 18 Mountain View Terrace Birth-4/11/07 Newville David Kreitzer 190 Alters Rd., Carlisle 4/11/07-Present (Robert only) Lois Kreitzer 18 Mountain View Terrace 4/11/07-Present Newville (Cheyenne only) 6/24/09-Present (David only) 8. The Plaintiff has not participated as a party or witness, or in another capacity in other litigation concerning the custody of the children is this or any other Court. 9. Plaintiff has no information of a custody proceeding concerning the children pending in any Court of this Commonwealth or any other state. 10. Plaintiff does not know of a person nor a party to the proceeding who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 11. The best interests and permanent welfare of the children require Plaintiff to have primary physical custody and for Defendant to have specified periods of partial physical custody which may be agreed upon by the parties or otherwise be determined by the Court. WHEREFORE, Plaintiff requests this Honorable Court to schedule a custody conciliation conference. Respectfully submitted, BAYLEY & MANGAN Date: l U ff 7w(- Mark F. Bayley, Es e 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 DAVID G. KREITZER : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW LOIS A. KREITZER : NO. 09- CIVIL TERM Defendant. : IN CUSTODY VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. !._/c?terc? ?9 David Kreitzer, Plaintiff' FILER 20.0 9 JU. - ! 4 Af-I S, . 2 9 r? fi 1 -4 /t ? . 5-6 A-f? DAVID G. KREITZER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-4677 CIVIL ACTION LAW LOIS A. KREITZER IN CUSTODY DEFFNDANT ORDER OF COURT AND NOW, Friday, July 17, 2009 _ upon consideration of the attached Complaint, it is licrchy directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland Coup Courthouse, Carlisle on Thursday, August 20, 2009 at 8_30 AM for a Pre-lieaimi7 Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or i l'this cannot he 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/--- Hubert X. GRro Es Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans ith Disabil ties Act of 1990. For information about accessible facilities and reasonable accommodations a\ ailahlc to disabled individuals having business before the court, please contact our office. All arrangements must he 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 I I,'\%'I?: 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 FILED-_," F s-,£?_ OF TFE PR f"i'ON? TARY 2009 JUL 20 AM 10: i ?2D • D? to i?a-' aD . 1 ? ell David G. Kreitzer, Plaintiff V. Lois A. Kreitzer, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION CIVIL ACTION - Custody No. 09-4677 PRAECIPE TO ENTER APPEARANCE Please enter the appearance of the Family Law Clinic on behalf of Lois A. Kreitzer, the Defendant, in the above captioned matter. August 19, 2009 Rachel Allen Certified Legal Intern 1 Anne d-Fox Ll? Supervi mg Attomey FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 FILED--OFFICE OF TWE PRO T;-'; 'OTARY 2009 AUG 19 A 11: 5 s cukill- AUG 2 4 2009 4 DAVID G. KREITZER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW LOIS A. KREITZER, NO. 2009-4677 Defendant IN CUSTODY COURT ORDER AND NOW, this 2 5 day of August, 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The father, David G. Kreitzer, and the mother, Lois A. Kreizer, shall enjoy shared legal custody of Robert Kreitzer, born May 17, 1993, and Cheyenne Kreitzer, born July 8, 2000. 2. The mother shall enjoy primary physical custody of Cheyenne and the father shall enjoy primary physical custody of Robert. 3. The father shall enjoy partial custody of Cheyenne on a liberal basis as agreed upon between the parties with the understanding that it will be a minimum of two days every two weeks. The mother shall enjoy partial custody of Robert on a liberal basis to be agreed upon by the parties with the understanding that it shall be a minimum of two days every two weeks. The parties shall work between themselves to set up the schedule for partial custody and also defer as appropriate to the schedules of the children and the desires of the children with respect to their desire to visit the other parent. 4. This Order is entered pursuant to an agreement reached by the parties at a Custody Conciliation Conference. In the event either party desires to modify this Order, that party may petition the Court to have the case again scheduled with the Custody Conciliator for a conference. BY THE COURT, Judge cc:Mark F. Bayley, Esquire ,/Rachel Allen, Student Attorney, Dickinson School of Law Family Law Clinic DAVID G. KREITZER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW LOIS A. KREITZER, NO. 2009-4677 Defendant IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Robert Kreitzer, born May 17, 1993, and Cheyenne Kreitzer, born July 8, 2000. 2. A Conciliation Conference was held on August 20, 2009, with the following individuals in attendance: The Father, David G. Kreitzer, with his counsel, Mark F. Bayley, Esquire, and the mother, Lois A. Kreitzer , with her counsel, Student Attorney Rachel Allen of the Dickinson School of Law Family Law Clinic. 3. The parties agree to the entry of an Order in the form as attached. Date: August ;?O '2009 Hubert X. Gilroy, E; Custody Conciliator OF THE R' lft'7WY 2009 AUG 25 IN 12.0 0 ITV =; PENNSYLVAi'VIT'A