HomeMy WebLinkAbout10-2669ASHLEY L. DIEHL, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.
_N
RICHARD ELLIOTTE CRAMER, CIVIL ACTION - CHILD CU#ODR&
Defendant
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ohn M.?err
5020 Ritter Road
Suite 108
McCha=Sburg, PA 17055
Priors: 717.766.4008
FAx: 717.766.4066
COMPLAINT IN CUSTODY
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1. Plaintiff is Ashley L. Diehl, an adult individual residing at 110 NorREnola
Drive, Enola, Pennsylvania 17025.
2. Defendant is Richard Elliotte Cramer, an adult individual residing at 1412
Bridge Street, New Cumberland, Pennsylvania 17070, but who receives mail at his sister's
home, whose address is 444 North Street, Lykens, Pennsylvania 17048.
3. The parties are the natural parents of the following minor child: Savannah
Marie Cramer, born February 2, 2004 (hereinafter, "the child").
4. The child was born out of wedlock.
5. The child is presently in the custody of Plaintiff, who resides at 110 North
Enola Drive, Enola, Pennsylvania 17025.
6. During the past five years, the child has resided with the following persons
and at the following addresses:
Names
Addresses
Dates
Ashley L. Diehl
Joshua R. Hamilton
Lexix Hamilton
Taylor Hamilton
Ashley L. Diehl
Ronald J. Diehl, Jr
Amber M. Ledoux
Richard Ledoux
110 North Enola Drive
Enola, PA 17025
667 Cornhill Road
Etters, PA 17319
2/10 - present
8/09 - 2/10
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Ashley L. Diehl 105 Umberto Street 12/04 - 8/09
New Cumberland, PA 17070
7. The mother of the child is Plaintiff, Ashley L. Diehl, residing with the child at
110 North Enola Drive, Enola, Pennsylvania 17025. She is married.
8. The father of the child is Defendant, Richard Elliotte Cramer, who resides at
1412 Bridge Street, New Cumberland, Pennsylvania 17070. He is not married.
9. The relationship of the Plaintiff to the child is that of Mother. The Plaintiff
currently resides with the following persons:
Name
Joshua R. Hamilton
Lexix Hamilton
Taylor Hamilton
Relationship
paramour
paramour daughter
paramour daughter
10. The relationship of the Defendant to the child is that of father. The Defendant
currently resides with the following persons:
Name Relationship
No one other than himself
o5020 Ritter Road
Suite 108
Mechanicsburg, PA 17055
PHONE: 717.766.4008
FAx: 717.766.4066
11. 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.
12. Plaintiff has no information of a custody proceeding concerning the child
pending in a court of this Commonwealth or any other state.
13. 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.
14. Each parent whose parental rights 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.
15. The best interest and permanent welfare of the child will be served by
granting the relief requested because:
a) The Father has little to no contact with the child;
b) The child is terrified of the Father, who failed to call her at Christmas or on her
birthday;
c) The Father has no permanent address and engages in high risk behaviors,
including drugs;
d) The Father has been convicted of many criminal offenses, but, most importantly,
corruption of minors and indecent assault;
e) The child has stability and love in her present environment; and
f) the emotional, physical and/or spiritual development of the child will be enhanced
by granting sole legal and physical custody of the child to Plaintiff.
WHEREFORE, Plaintiff requests that the Court grant to her sole legal and physical
custody of the child, Savanna Marie Cramer.
Respectfully submitted,
W
Gw Office of
ohn M.?err
5020 Ritter Road
Suite l08
MechaniCSbtug, PA 17055
Pftorre: 717.766.4008
FAx: 717.766.4066
Johrf M. Kerr, Esquire
Attorney I.D. # 26414
Law Office of John M. Kerr, Esquire
5020 Ritter Road, Suite 109
Mechanicsburg, Pennsylvania 17055
(717) 766-4008
Attorney for Plaintiff, Ashley L. Diehl
Dated: April 21, 2010