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HomeMy WebLinkAbout10-1386? ^ T !i f-i j-?= tf^ ;RY 20f0FFB 2; N 2: 28 G 4R SONDRA L. ROHM, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW DARRYL RAY OTT, SR., No. 2010 - D3 Y6 CIVIL Defendant IN CUSTO Y COMPLAINT FOR CUSTODY 1. The plaintiff is Sondra L. Rohm, residing at 1833 Ritner Highway, Apt. 1, Shippensburg, Cumberland County, Pennsylvania 17257. 2. The defendant Darryl Ott, residing at 1069 Big Plum Run, Lock Haven, Clinton County, Pennsylvania 17745. 3. Plaintiff seeks custody of the following child: Name Present Residence DOB Age Darryl Ray Ott, Jr. 1833 Ritner Highway, Apt. 1 10/9/05 4yrs old Shippensburg, PA 17257 The child was born out of wedlock The child is presently in the custody of Mother, residing at 1833 Ritner Highway, Apt. 1, Shippensburg, Cumberland County, Pennsylvania 17257. During the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Sandra Rohm 1833 Ritner Highway, Apt. 1 2005-present Shippensburg, PA 17257 1838 Molly Pitcher HWY, Apt. B Shippensburg, PA 17257 9, /79. 0j ?? ? yes 115 Fairfield Street Newville, PA 17241 Lot 6 Woods Road Shippensbrug, PA 17257 4. The mother of the child Sondra Rohm, residing at 1833 Ritner Highway, Apt. 1, Shippensburg, Cumberland County, Pennsylvania 17257. She is not married. The father of the child Darryl Ray Ott, Sr., residing at 1069 Big Plum Road, Lock Haven, Clinton County, Pennsylvania 17745. It is unknown is Darryl Ray Ott, Sr. is married or unmarried. 5. The relationship of plaintiff to the child is that of Mother. The plaintiff currently resides with the following persons. Name Relationship Darryl Ray Ott, Jr. Son 6. The relationship of defendant to the child is that of Father. The defendant currently resides with the following persons. Name Relationship Unknown 7. 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. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. 8. The best interest and permanent welfare of the child will be served by granting the relief request because: A Court Order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. Plaintiff desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the child. A Court Ordered determination of custody is required to avoid continuing conflict between the parties regarding responsibility for custody and support. WHEREFORE, Plaintiff requests this Court grant Plaintiff full primary physical custody subject to structured partial custody by the Defendant. Respectfully submitted, Rominger & Associates Date: / Karl . Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Sondra Rohm 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 unworn falsification to authorities. /So a L. Rohm, Plaintiff SONDRA L. ROHM IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 2010-1386 CIVIL ACTION LAW DARRYL RAY OTT, SR. IN CUSTODY D}:FF•,NDANT ORDER OF COURT AND NOW, Thursd~March 04, 2010 ___ _ ___, upon consideration of the attached Complaint, it is hereb}~ directed that pa--ties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator, at 4th Floor ,Cumberland County Courthouse, Carlisle on Friday, March 26, 2010 at 9:30 AM for aPre-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 he heard by the court. and to enter into a temporary order. Failure to appear at the; conference may provide Prounds 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. Bv: /s/ Hubert X. Gslro Es . 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 infor-nation 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 hotu~s prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOLIL,D TAKE THIS PAPER TO YOUR A"h'I'ORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNO"I' AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTI-1 BELOW TO FIND OUT WI-IERE YOU CAN GE"I' LEGAL l-[ELP. Cumberland County Bar Association 3? South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~7fi T E p~41~'~AR1' 2014 MAR -t, PM t~: ~g A~'~d1~°St'LVi~~'V~4 ~ 3~~/-~~ ~~~~, ~~.