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HomeMy WebLinkAbout04-5166 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. J4- :5'//. (. (W 'fL- CRAIG A. SLEDZINSKI, Plaintiff PATRlCIAL. POTTS, Defendant CIVIL ACTION - LAW CUSTODY COMPLAINT FOR CUSTODX AND NOW, this 14th day of October, 2004, comes Plaintiff, Craig A. Sledzinski by and through his attorney, Joanne Harrison Clough, and respectfully avers as follows: 1. Plaintiff is Craig A. Sledzinski, residing at 940 Myerstown Road, Gardners, Cumberland County, PA, 17324. 2. Defendant is Patricia L. Pott, residing at Apt. 9208, ]~rinceton Avenue, Camp Hill, Cumberland County, PA, 17011. 3. Plaintiff seeks shared physical and shared legal custody of the following children: Name Present Address Date-of-Birth Chelsea E. Sledzinski Apt. 9208, Princeton Ave 09-22-99 Camp Hill, P A 17011 Dalton 1. Sledzinski Apt. 9208, Princeton Ave 04-17-02 Camp Hill, PA 17011 4, The children were born out of wedlock The children are presently in the custody of Defendant, residing at Apt. 9208, Princeton Ave, Camp Hill, Cumberland County, PA 17011. 5. During the past five (5) years, the children have resided with the following persons at the following address: Name Address Dates Patricia L. Potts Apt 9208, Princeton Ave, Camp Hill, 07/04 to PA 17011 present Patricia L. Potts 940 Myerstown Rd, Gardners, 02/04 Craig A Sledzinski PA 17324 to 07/04 Patricia L. Potts 71 Spruce Lane, Dillsburg, 1999 to * Craig A Sledzinski PA 17019 02/04 * Patricia L. Potts Pennville Apts. 2002-2003 Williamsport, P A 6. The Plaintiff, Craig A Sledzinski, is the natural fathl~r of the children and is currently residing at940 Myerstown Road, Gardners, Pa 17324. He is single. 7. The Defendant, Patricia L. Pott, is the natural mother of the children is currently residing at Apt. 9208, Princeton Ave, Camp Hill, PA 17011. She is single. 8. The relationship of Plaintiff to the children is that of natural father. Plaintiff currently resides with the following persons: Name Relationship self 9. The relationship of Defendant to the children is that: of natural mother. Defendant currently resides with the following persons: 2 Name Chelsea E. Sledzinski Dalton J. Sledzinski Relationship daughter son 10. Plaintiff has not participated as a party or a witness, or in any other capacity in other litigation concerning the custody of the children in this or any other Court. II. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 12. Plaintiff does not know of any other person not a party to the proceedings whom has physical custody of the children or claims to have custody or visitation rights with respect to the children. 13. The best interest and permanent welfare of the children will be served by granting the relief requested because: a. Plaintiff father loves the children and it is in their best interest that he have regular frequent periods of substantial physical custody with their children. b. Plaintiff loves the children and desires to conltinue to care and provide for them and desires to continue to assure the children have regular access to their father. c. Plaintiff believes it is in the best interest and permanent welfare of the children that the children's relationship with each parent be maintained, preserved, and enhanced. 3 14. 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, Plaintiff requests the Court to grant the parties shared legal and shared physical custody of the children and grant any other relief this Court deems appropriate Respectful1y submitted, Joanne Harrison Clough, PC \ , Date: b-\''J - a,-\ dW ~ Joanne Harrison Clou Attomey ill No,: 364 24 N, 32nd Str~:et Camp Hill, PA 17011 (717) 737-5890 Attomey for Ptaintiff squire 4 VERIFICATION I, Craig A. Sledzinski, hereby verify and state that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C,S. 34904 relating to unsworn verification to authorities, DATE: \ t -I 7-. -0--{ crn6,I,!..-j/+~ ~ p:: ~ ~ --- - C> - ~ ~ 0() ---c:, "- ~ ~ .3'- () s:~- 'f~) 9 "> C'::'::;) C-" ~- CJ C':. -I .t;'~ 2:'"'' . , -, CRAIG A. SLEDZINZSKI PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V. 04-5166 CIVIL ACTION LAW PATRICIA L. POTTS DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, OctOber 20, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Monday, November 15, 2004 at 1:30 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 a,ge 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 fnrnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 honrs prior to scheduled hearine:. FOR THE COURT. By: /s/ Mehssa P. Greevy, Esq. 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 Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3 I 66 ~ ,~ '7- Pcp -V"Y ~7hO (J(',(j! -h' ~ ~ hO ilr!.r;1 ~ f;;:t7 1- rp 'pi"., ~ .;M? /?t:J.e7e'0/ 91 :;~ :',:1 02 1.~:iO t1GJl CRAIG A. SLEDZINSKI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - IN CUSTODY PATRICIA L. POTTS, Defendant : NO. 2004- 5166 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Patricia L. Potts, through her attorneys, the Family Law Clinic to proceed in forma pauperis. The Family Law Clinic, attorneys 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. THE F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 ~:.: l ).:: " " ,"':c( .>"c:" ~~ (') f;: : ~ : L r-..:l C..:> =:> J;- ("""J .") i .....~ ot:'~;,~ <_..} ....::: ~ -~~~ r-, 1""-' CO'" " , . -f". ('~ ::\ rl'~ v w CRAIG A. SLEDZINSKI, Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - IN CUSTODY PATRICIA L. POTTS, Defendant : NO. 2004- 5166 CIVIL TERM PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of the Family Law Clinic on behalf of the Defendant, Patricia L. Potts, in the above captioned matter. Respectfully Submitted, \ /) ~/! I 1 ,(II) ~": '~\ 1AJd/6 "'-. THOM~l. ACE ROBE~UlRAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 r~}/:~, C) c- .... 1',) c::::, C:::) -l;.- ::::::: c, ~ ,-" '--'" -1/ f\) -r:. -., i'\.J (",; NOV 1 2 2004 'P- iQ t5 CRAIG A. SLEDZINSKI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW : CUSTODY PATRICIA L. POTTS, Defendant : NO. 04-5166 CIVIL TERM ORDER OF COURT AND NOW, NO V$mbuc. J4 ;.dtJ~pon consideration of the attached Answer to Complaint for Custody and New Matter, it is directed that the issues raised in Defendant's New Matter be addressed at the conciliation confen::nce scheduled before Melissa Greevy, the custody conciliator, on Monday, November 15,2004 at 1 :30 P.M. at 301 Market Street, Lemoyne, P A 17043. FO ~ A ~D ~"\ By: J. '. .: :1rl }J}.!;-'t'~{' ':~~) 22 :! I ~,;~1 8\ AmPiuGl I.:i'\.j-!-:,~ ;:..i;-~~~-Jcd 3'~~i ~ ~;.,:.;:lJ--.03-~~:~ 1,t"". ;:.\) CRAIG A. SLEDZINSKI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No.04-5166 CIVIL TERM v. PATRICIA L. POj:TS, Defendant CIVIL ACTION - LAW CUSTODY DEFENDANT'S ANSWER TO COMPLAINT FOR CUSTODY AND NEW MATTER Defendant, Patricia L. Potts, by her attorneys, the Family Law Clinic, hereby responds to Plaintiffs Complaint for Custody as follows: 1. Admitted. 2. Admitted in part and denied in part. Defendant is Patricia L. Potts; however, she resides at 2109 Princeton Avenue, Apt. 5, Camp Hill, Cumb(~rland County, Pennsylvania, 17011. 3. Admitted in part and denied in part. Admitted that Plaintiff is seeking custody. Denied that children reside at Apt. 9208, Princeton Ave., Camp Hill, P A. Defendant resides with the children at 2109 Princeton Avenue, Apt. 5, Camp Hill, Cumberland County, PA, 17011. 4. Admitted in part and denied in part. Defendant admits that the children were born out of wedlock and that they reside with defendant. Defendant denies that the children reside at Apt. 9208, Princeton Ave., Camp Hill, Cumberland County, P A 17011. Children reside with Defendant at 2109 Princeton Avenue, Apt. 5, Camp Hill, Cumberland County, PA 17011. 5. Admitted in part and denied in part. Defendant admits that the children resided with the listed persons; however, denies that the children lived with her at Apt. 9208, Princeton Ave., Camp Hill, P A 17011. Children have resided with Defendant from July 2004 until present at 2109 Princeton Avenue, Apt. 5, Camp Hill, P A 17011. 6. Admitted. 7. Admitted in part and denied in part. Defendant admits that she is the natural mother of the children and that she is single. Defendant denit:s that she resides at Apt. 9208 Princeton Ave., Camp Hill, P A 17011. Defendant resides with children at 2109 Princeton Ave., Apt. 5, Camp Hill, PA 1701 I. 8. Admitted. 9. Admitted. 10. Denied. Plaintiff, Craig Sledzinski, signed a Stipulation for Custody, which was made an Order of Court by the Honorable Richard K. Renn, Docket No. 2000 SU 02218- 03, in the Court of Common Pleas of York County, Pennsylvania, May 8, 2000, granting full legal and primary physical custody of Chelsea Sledzinski to Defendant, Patricia Potts. The above referenced order is attached to this petition, marked as Exhibit A. 11. Denied, see paragraph 10 above. 12. Admitted. 13. Legal conclusion, but if deemed factual, is denied as follows: a. Admitted that Plaintiff loves the children, denied that it is in the children's best interests that Plaintiff have frequent periods of substantial physical custody at this time due to Plaintiff's violent behavior and inappropriate conduct with children. b. Admittted. c. Denied. Defendant denies that it is in the children's best interests for the Plaintiff to have frequent periods of substantial physical custody of the children at this time due to concerns about Plaintiffs violent behavior and inappropriate conduct with the children. 14. Admitted. NEW MATTER Jurisdiction 15. The Pennsylvania General Assembly recently enacted the Uniform Child Custody Jurisdiction and Enforcement Act, repealing the Uniform Child Custody Jurisdiction Act. The new 23 Pa. C. S.9547l addresses and incorporates intrastate application. 16. Pursuant to 23 Pa. C. S. 95310, Plaintiff should have filed a Petition to Modify the York County Order, dated May 8, 2000. 17. Pursuant to 23 Pa. C. S. 95471 and 5424 (d), the Court of Common Pleas of Cumberland County and the Court of Common Pleas of York County should communicate to appropriately transfer jurisdiction to Cumberland County, as parties no longer reside in York County. Best Interests of the Children 18. Defendant believes and therefore avers that it is not in the children's best interest to grant the relief requested due to Plaintiffs violent behavior and inappropriate conduct with the children. WHEREFORE, Defendant requests that: Cumberland County Court of Common Pleas communicate with York County Court of Common Ple:as to transfer the venue of this custody action to Cumberland County; that the custody conciliation scheduled for November 15, 2004, address issues raised by Defendant in m~w matter; and that the Court grant Defendant primary physical custody of the children, with supervised visitation for Plaintiff. Respectfully Submitte , l Date:~ O~ I... r~ <l.ucy J Anne cDonald-Fox Robert E. Rains Thomas M. Place Supervising Attorneys FAMIL Y LAW CLINIC 45 N. Pitt Street Carlisle, P A 17013 (717) 243-2968 VERIFICA nON I, Patricia L. Potts, hereby verify and state that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. ~ 4904 relating to unsworn verification to authorities. Date: \~~ d.~ Patricia L. Potts . ' . \\ SXh\P\t uA P A TRI CIA 1. POTTS, Plaintiff IN 1HE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA v. NO. CRAIG SLEDZINSKI, Defendant CIVIL ACTION - LAW CUSTODY STIPULATION FOR CUSTODY AND NOW, this day of , 2000, without any admission or acknowledgment of the allegations in the Complaint by the Defendant, and without any findings by the Court, the parties have agreed as fGllows: 1. The Plaintiff, Patricia 1. Potts, shall have legal custody and primary physical custody of the minor child, Chelsea Sledzinski. 2. Defendant, Crnig Sledzinski, shall be entitled to periods of physical custody as agreed to by the parties. 3. The effective date for the beginning of this custody schedule shall be immediately upon the execution of this Stipulation. 4. The parties waive the requirement ofPa.R.C.P. {i1915.7 regarding presentation of this Stipulation in open court. 5. ";The parties hereto desire that this Stipulation for Custody be entered as an Order of Court. WHEREFORE, Plaintiff and Defendant respectfully request your Honorable Court to enter the accompanying ~ourt Order concerning the custody of the minor child. ~11{ESSES: ~ ~4U1J(. JJ- ~)/w v. IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYL V ANJA NO. 2600.su.., ();;;)/ g --(J 3 PATRICIA L. POTTS, Plaintiff f CRAIG SLEDZINSKI, Defendant CIVIL ACTION - LAW CUSTODY ORDER (:) ~ c:::l . " c; :J.: c o ;:po. rl -< c: -< ';-;: ;;~. o~ .'. ;:.J::::::; C> -:1:, ?' ::i _::_~ ~" "'"DO ~ :-::Pl J> C -"" ~>c.; , :WOO, pursuant to the e~ ~e ~ (J1 :;:: S that the terms of the attached Stipulmon ~ AND NOW, this ~ day of attached Stipulation, the Court ORDERS AND D For Custody shall be entered as an Order of Court. BY THE COURT: p/J~~ t:. f~ rll) J. CERTIFI~ . ~ mthe~~C4mm~I'''~I. ~ this dllYof .2od~~ ~ ~ Stacia N. Gates, Protbaootal1 (') c- ,_." ..,''''-e. -""..., '" 1'-0 <:::';) e:') o of} -~ ::r. '. flit''''' ''1,T'1 "I'j l;J ~~! () (, '-" :'.J "" t, I ) f n - . -~ N -0 f') C.I j.......J -,...... CRAIG A. SLEDZINSKI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-5166 CIVIL TERM v. CIVIL ACTION - LAW PATRICIA L. POTTS, IN CUSTODY Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the children who are t,he subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Chelsea E. Sledzinski September 22, 1999 Mother Dalton J. Sledzinski April 17, 2002 Mother 2. A Custody Conciliation Conference was held on November 15, 2004 following Father's filing of a Complaint for Custody on October 14, 21004. A previous Order of Court has been entered with respect to the oldest child in the York County Court of Common Pleas docketed to 2000-SU-02218-03. Judge Rehn's Order of May 8, 2000 incorporated the parties' Stipulation for Custody into an Order of Court. Father's attorney will prepare a Stipulation for the parties to consent to the transfer of jurisdiction from York County Court of Common Pleas to Cumberland County Court of Common Pleas, as the parties no longer reside in York County and have voluntarily consented to jurisdiction in Cumberland County. Present for the conference were: the Father, Craig A. Sledzinski and his counsel, Joanne Harrison Clough, Esquire; the Mother, Patricia L. Potts, and her counsel, Jennifer Smitrovich, CLI, from the Family Law Clinic of the Pennsyllvania State University, and her supervising attorney, Lucy Johnston-Walsh, Esquire. 3.. The parties reached an agreement in the form ~er as attached. !1/rl!(J1 ~JIV 1fu ~ Date Melissa Peel Greevy, Esquire Custody Conciliator :239409 Plaintiff NOV 2 9 1004 f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-5166 CIVIL TERM CIVIL ACTION - LAW r , !/ v CRAIG A. SLEDZINSKI, v. PATRICIA L. POTTS, IN CUSTODY Defendant ORDER OF COURT / ~~.,.", AND NOW, this Jt" day of tJs.6Nber, 2004, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Leaal Custody. The parties, Craig A. Sledzinski and Patricia L. Potts, shall have shared legal custody of the minor children, Chelsea E. Sledzinski, born September 22, 1999, and Dalton J. Sledzinski, born April 17, 2002. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa. C. S. 95309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to, medical, dental, religious or school records, the residence address of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Mother shall have primary physical custody of the minor children subject to Father's rights of partial custody which shall be arranged as follows: A. Commencing November 19, 2004, on alternating weekends from Friday at 5:00 p.m. until Sunday at 5:00 p.m. B. On Tuesday and Thursday evenings from 5:00 p.m. until 8:00 p.m. However, in the event that Father does not have to work on Tuesday or Thursday, his custodial time for these days would be expanded to begin at 1 :00 p.m. and continue through 8:00 p.m. C. At such other times as the parties may agree. 3. TransDortation. The party receiving custody shall provide transportation incident to the custodial exchange. .. NO. 04-5166 CIVIL TERM 4. Holidavs. The following holiday schedule shall take precedence over the regular schedule. A. Mother's Dav I Father's Dav. Mother shall have custody on Mother's Day. Father shall have custody on Father's Day. B. Christmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 24th at 3:00 p.m. until December 25th at 3:00 p.m. Segment B shall be from December 25th at 3:00 p.m. until December 26th at 3:00 p.m. Iln even-numbered years, Mother shall have Segment A and Father shall have Segment B. In odd- numbered years, Father shall have Segment A and Mother shall have Segment B. C. Thanksaivina. The parties will alternate the Thanksgiving holiday commencing with Father having custody for Thanksgiving 2004. Unless otherwise agreed, the Thanksgiving holiday shall be from the Wednesday preceding the holiday at 5:00 p.m. until Thanksgiving Day at 5:00 p.m. D. Other Holidavs. The parties shall share or split the following additional holidays by their mutual agreement: Easter, Memorial Day, Independence Day and Labor Day. 5. Vacation. Each parent shall be entitled to one (1) week of custody during each of the months of June, July and August. In the event that the parent elects to work during these vacation weeks, the other parent shall have first right of refusal for custody during that parent's work hours. The parties shall provide each other with at least a thirty (30) day notice of their planned vacation time. In the event that the parties have arranged conflicting schedules for vacation, the party first providing written notice to the other party shall have choice of the vacation week. Additionally, the vacationing parent shall provide a telephone number and location where they can be reached during the vacation. 6. Relocation. Neither party shall relocate from a distance greater than they presently reside from the other parent, in the absence of 60 days notice of their intended relocation. The 60-day notice provision is intended to provide the parties with an opportunity to resolve changes needed in the custodial schedule, and failing an agreement, to file the proper documents with the Court to resolve the matter of the relocation. . . . NO. 04-5166 CIVIL TERM 7. The parties shall participate in co-parent Gounseling at Father's expense. Counsel for the parties shall work out arrangements to identify a provider promptly and calls to arrange such services shall be made no later than November 19. 2004. BYT J. '\ Dist: ~nne Harrison Clough, Esquire, 24 N. 32ND Street, Camp Hill, PA 1'7011 ~nnifer Smitrovich, GLI, Family Law Clinic, 45 North Pitt Street, Carlisle, PA 17013 .Jd1'cy Johnston-Walsh, Esquire, Family Law Clinic, 45 North Pitt Street" Carlisle, PA 17013 ~ \I ,,0 q \~D~ ~ . '.... ., . ~o\ ~v YORK COUNTY COURTHOUSE ()l..t - S' J~L Ct'u d. ~ 07/13/05 PAGE: 1 CIVIL ACTION DOCKET POTTS, PATRICIA L VS. CASE NO: 2000-SU-002218-Y06 YK FILING DATE: 05/05/00 JUDGE: Y03 SLEDZINSKI, CRAIG PARTY TYPE LITIGANT PARTY NAME ---------------------------------------- ATTORNEY PLAINTIFF DEFENDANT FOR CIVI FOR CIVI POOl POOl D001 BICKLEY, L REX POTTS, PATRICI;~ L SLEDZINSKI, C~~IG DATE FEE/AMOUNT -------- ------------------------------------------------------ --------------- 07/05/05 00093 00222 *ORDER TRANSFERRING CASE TO ANOTHER COUNTY CT FOR TRANSFER OF VENUE TO CUMBERLAND COUNTY BY RENN JUDGE 05/03/05 00079 00350 *JOINT PETITION FOR TRANSFER OF VENUE W/CERT OF SVC 05/19/04 00072 00058 *CASE INACTIVE PER LOCAL RULE 6036 05/10/00 00059 0466 ORDER OF COURT STIPULATION FOR CUSTODY SHALL BE ENTERED AS AN ORDER OF COURT BY THE CT RICHARD KRENN J 05/05/00 00056 0241 ACCEPTANCE OF SERVICE OF COMPLAINT 05/05/00 00056 0241 STIPULATION FOR CUSTODY 05/05/00 00056 0241 COMPLAINT IN CUSTODY ACTION 23.25 GRANTS JOINT PETITION THE COURT RICHARD K 82.00 TOTAL NUMBER OF ENTRIES: 7 REQUESTED BY: YR1 ******* END OF REPORT ******* f"...~J>>........~cIl'tlle~~~il'Jses&:..~l'eiIIIIt1riidc ... \ ~ ~~ )1\..\(\ AJl20Ds::... J. ~ c:::: (.l(l Fame'!" '5. h'(~, 'Prm'hmi~ ..- ,---- () <:,::, ,..., <= ~ <- c ,-- , 3 - o ",",1 -I ;:C-n rnp: -rJ],; -"C;; ;:~,<:? r~ -t', ';~\~~. cD ~~ -1,~ '!? J;"' w :-~ .- - v. : IN THE COURT OF COMMON PLEAS : YORK COUNTY, PENNSYLVANIA : NO'~a1)~~1_ ~ ()/ 3 -I Q3 ,--:-CIVlL_AC_TION - LAW : CUSTODY CRAIG A. SLEDZINSKI, Plaintiff '----PA:'fRleiAL-:-P8T-TS;--- Defendant ORDER OF COURT 9-<-'-i-' ,2005, upon review of the Joint Petition for Transfer of Venue, this Court directs that the Prothonotary of York AND NOW, this 5~ I day of County transfer the case and all documents associated with the file to Cumberland ......> 0 = -1'\ c- = .,., c: <..n n 1:.-:) '- ", -<c=) c c> ,- c::'- -r, ;:o:t> I -0 AI U1 ;0 a ~n ~ ::;:! .~YPl ~ t3 ;"~":;;:: -4 = t.',) rrJ :- -i .-~'-' ~.."" ~ .' -'.~ ,-"' County, docketed at 2004-$166. J. N 'l;~ j 'l! .. .J-i' l~ I, ~. ...",- 186090930222 CRAIG A. SLEDZINSKI, Plaintiff v. : IN THE COURT OF COMMON PLEAS : YORK COUNTY, PENNSYL VANIA . 01 ~O u:.. -:2 ; NO. SU 0221S.,lB' i''(J C/ PATRICIA 1. POTTS, Defendant : CIVIL ACTION - LAW : CUSTODY ORDER OF COURT AND NOW, this day of ,2005, upon review of the Joint Petition for Transfer of Venue, this Court directs that the Prothonotary of York County transfer the case and all documents associated with the file to Cumberland County, docketed at 2004-5166. BY THE COURT: J. "n -r;:'-r"'\ ;;; ':,.t~<, ....-\ r->"", :~~h ~, ~ (; <- '" c:: C> ~ "'1 I -0 W ~ --l :g :x: ...;;.. S~ - 0 .. --l f'\l :t:" ";:"" ?J c::> ~ v. : IN THE COURT OF COMMON PLEAS : YORK COUNTY, PENNSYLVANIA : ;L()()cJ : NO. SU 02218;l6?2J3 CRAIG A. SLEDZINSKI, Plaintiff PATRICIA 1. POTTS, Defendant CIVIL ACTION - LAW CUSTODY c,. C-, Cr- -<C? 0- ?~"f: -~ JOINT PETITION FOR TRANSFER OF VENUE 1. The Petitioner is Craig A. Sledzinski. He is an adult individual who is currently residing at 940 Myerstown Road, Gardners, Cumberland County, Pennsylvania. He will henceforth sometimes be referred to as "father." 2. The Respondent is Patricia 1. Potts. She is an adult individual who is currently residing at 2109 Princeton Avenue, Apt. 5, Camp Hill, Cumberland County, Pennsylvania. She will henceforth sometimes be referred to as "mother." 3. On or about May 8, 2000, the Honorable Richard K. Renn entered an Order regarding Custody of the parties' minor child. A true and correct copy of the Order is attached hereto marked as "Exhibit A" and made a part hen:of. 4. It is noted that neither the child nor either of the parties reside in York County. It is further noted that Mother and child have not resided in York County since 2003. It is also noted that Father has not resided in York County since the end of 2003. Father now resides in Cumberland County. 5. Your Petitioner has filed a Complaint for Custody in Cumberland County. The action is docketed at 04-5116. 6. Both parties agree Cumberland County i~~&?mfflS6unty ofthe children and agree to have the York County action transferred to Cumberland County, Pennsylvania. WHEREFORE, Petitioner requests your Honorabh: Court enter an Order directing the above referenced action be transferred by the Prothonotary of York County, Pennsylvania to Cumberland County and the instant action be consolidated with the ongoing action in Cumberland County. I I/., 105 ~ '0 ennifi r . Smitrovic:h, Certifie Lucy Johnston-Walsh Supervising Attomey Family Law Clinic 45 N. Pitt Street Carlisle, P A 17013 (717) 243-2968 Counsel for Patricia L. Potts ~ Joannt: Harrison Clough, q Joanm: Harrison Clough, P. Attomey ID No. 36461 24 N. 32nd Street Camp Hill, PA 17011 (717) 737-5890 ouns<el for Craig Sledzinski ~' ~~~ e al Intem Respectfully Submitted, ~ /' S r\~-OJ Date 1530~O /9Q35'O CRAIG A. SLEDZINSKI, Plaintiff : IN THE COURT OF COMMON PLEAS : YORK COUNTY, PENNSYLVANIA v. : NO. SU 02218-03 P A TR1CIA 1. POTTS, Defendant CIVIL ACTION - LAW CUSTODY VERIFICATION I verify that the statements made in the foregoing Petition for Transfer of Venue are true and Correct. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. S 4904 relating to unsworn falsification to authorities. --6~ ~ ~~r\ Craig A. SIedzinski ) ~'\~'\)") Date I verify that the statements made in the foregoing Petition for Transfer of Venue are true and Correct. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. 9 4904 relating to unswom falsification to authorities. I/~/O.s D{te I ~ 153090190350 VERIFICATION I, ~ ~u.: ., A S \ c, ~z,", '1 sli..; . hereby verify and state that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subje:ct to the penalties of 18 Pa. C,S. 34904 relating to unsworn verification to authorities. DATE: <;, \ \i -0\ k~~~l 15~090 190350 CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Petition for Transfer of Venue upon Patricia L. Potts by depositing same in the United States Mail, first class, postage pre-paid on the In k day of ~ , 200~f{om Camp Hill, Pennsylvania, addressed as follows: -0' :/ Jennifer M. Smitrovich, Certified Legal Intern Lucy Johnston-Walsh Supervising Attorney Family Law Clinic 45 N. Pitt Street Carlisle, PA 17013 717-243-2968 JOANNE HARRISON CLOUGH, P.C. ~ Joanne Harrison Clough, E Attorney ill No. 36461 24 N. 320d Stn~et Camp Hill, PA 17011 (717) 737-5890 -- 15J090 790350 5 c, ,..., .''1 = -~ C,~ = Z-S c:: c.n c <- ,." --<c'} c:: (::'1 ::::: -'1 0-.- I ~,:) ;OJ::'" W ...", :?" c:> -l n -0 :!? rn ..". (5 -- P-''i.'' 0 .~ - -; ., -l 1"'"1 .::- :?' ?::J c:> ~ ~ PENNSTATE ~ The Dickinson . School of Law Family Law Clinic A service to the community by students from The Dickinson School of Law of The Pennsylvania State University The Dale E Shughart . Community Law Center 45 North Pitt Street Carlisle, PA 17013 Office: 717-243-2968 or 717 -243-8034 Fax: 717-243-3639 June 1,2005 Pamela S. Lee York County Judicial Center 45 North George Street York,PA 17401 Re: Sledzinski v. Potts No SU 02218-03 c c~ o -<t,- 0-./ :::oJ> ;;:;r-- .:of";;.~ "":;'t~ -.;,.' ~ --j /'T1 ~ _..\,J Dear Ms. Lee: Enclosed please find the following document: 1. Fully executed Joint Petition for Trllnsfer of Venue in the above referenced case. Please file the Joint Petition for Transfer of Venue in this action and return the two stamped copies in the stamped, self-addressed envelopll enclosed. If there are any fees associated with filing this document please call me at the Clinic. Thank you for your cooperation in this matter. Enclosures '1-........... 153090 HI0350 The Dickinson School of Law of The Pennsylvania State University ~ ;~; z:: 2j ~ :;; ::::: (.':) I -:1 W -u :';.'1 -0 C) ~ :::;! - a - -". .. 2; ..t::"- :::-1 <:::> ;;; -< An Equal Opportunity University OS/27/05 ~K COUNTY COURTHOUSE PAGE: 1 CIVIL ACTION DOCKET POTTS, PATRICIA L VS. CASE NO: 2000-SU-002218-Y03 YK FILING DATE: 05/05/00 JUDGE: Y03 SLEDZINSKI, CRAIG PARTY TYPE LITIGANT PARTY NAME ATTORNEY PLAINTIFF DEFENDANT FOR CIVI FOR CIVI POOl POOl DOOl BICKLEY, L REX POTTS, PATRICIA L SLEDZINSKI, CRAIG DATE FEE/AMOUNT -------- ---------------------------------------_._--------~---- --------------- 05/19/04 00072 00058 *CASE INACTIVE PER LOCAL RULE 6036 05/10/00 00059 0466 ORDER OF COURT STIPULATION FOR CUSTODY SHALL BE ENTERED AS AN ORDER OF COURT BY THE CT RICHARD K REtW J 05/05/00 00056 0241 ACCEPTANCE OF SERVICE OF COMPLAINT 05/05/00 00056 0241 STIPULATION FOR CUSTODY 05/05/00 00056 0241 82.00 COMPLAINT IN CUSTODY ACTION TOTAL NUMBER OF ENTRIES: 5 REQUESTED BY: LRP ******* END OF REPORT ******* ...................- W~'m60474 ~ . PATRICIA L. POTTS, Plaintiff v. CRAIG SLEDZINSKI, Defendant -t'- AND NOW, this 8' day of ORDER M~ IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA NO.1.~Q(l..J.U. oaal'b'-b3 o ~ o .." :c, n o I~ o :Po -< c: -< :;; 0." ::r:)~ 0 :A-- -00 "'0 ~c:: -:x (j1 ......." rT1 ,- G U1 :;~ CD ::t.) -< CIVlL ACTION - LAW CUSTODY ",.. ;T~ ':~, ::.;,;) ,2000, pursuant to the entry of the attached Stipulation, the Court ORDERS AND DIRECTS that thl~ terms ofthe attached Stipulation For Custody shall be entered as an Order of Court. \ \, J. 132090 5~0466 / v, IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYL VANIA NO. Z.c:J::X::) .5:.....) OZ-Z-\.~- c:,~ PATRICIA 1. POTTS, Plaintiff CRAIG SLEDZINSKI, Defendant CIVIL ACTION - LAW CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth int the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a an Order may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose rights important to you, including custody or visitation of your children, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAW REFERRAL SERVICE 137 E. Market St. York,PA 17401 (717) 854-8755 Cl (:) ..., (:) ..., n :::It n ~ -<0 ;po Cl;U -< c: """1;:.... 0:;:0 I ::,(-) ;;0--1 "" ";I':~:.,., ~:r: ::><. -00 ~ ..;:("'1 :pC: (5D Z {/) W 0 f'T1 - GoO :P- ut ;n -< 132090590400 PATRlCIA L. POTTS, Plaintiff IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYL VANIA v. Cl 8 ~ :s, ('''} n ;rao -<g -C f;;:::J 0--) t -Jri ::0 ~ <.It 7-, ,n :::-::: -.,-" .~~< =-00 5 :;:M )>c. .. 00 Vl fY!j -z ,.." Ti" ~ c..I '" '" ~ Plaintiff is Patricia L. Potts, an adult individual currently residing at 42 Genesis NO. CRAIG SLEDZINSKl, Defendant CIVIL ACTION - LAW CUSTODY COMPLAINT FOR CUSTODY 1. Court, Middletown, Dauphin County, Pennsylvania 17057. 2. Defendant is Craig Sledzinski, an adult individual currently residing at 71 Spring Lane, DiIlsburg, York County, Pennsylvania 17019. 3. The parties are not married. 4. The parties are the natural parents of the child who is the subject of this Petition, namely, Chelsea E. Sledzinski, who was born September 22, 1999 at the Hershey Medical Center, Hershey, Pennsylvania. 5. During the past five years the child has resided with the following individuals at the following addresses for the following periods of time: NAME ADDRESS DATE The Parties: Patricia 1. Potts and Craig Sledzinski 71 Spring Lane DilIsburg, P A 9/22/99 - 4/20/00 Patricia 1. Potts 42 Genesis Ct. 132090 59046fddletown, PA 4/20/00 . Present 6 Plaintiff has not participated as a party Of witness or in any other capacity in any litigation concerning custody of the child. 7. Plaintiff has no infofmation of any custody proceedings concerning the children pending in any Court of this Commonwealth. 8. Plaintiff does not know any person not a party to these proceedings who claims to have custody or visitation rights with respect to the children. 9. The best interest and permanent welfare of the child will be served by granting the relief requested because the parties hereto have agreed that the attached Stipulation and Order are in the parties and the child's best interest. WHEREFORE, Plaintiff requests your Honorable Court to grant the relief requested and enter and Order htoorporating the terms and conditions of attached Stipulation. Respectfully submitted, 1. Rex Bic ey 121 So St. Harri. urg,PA 17101 (717) 234-0577 (717) 234-7832 Attomey for Plaintiff 132090590466 VERIFICATION I, Patricia L. Potts, verifY that the statements made in the foregoing Complaint are true and correct to the best of my information, knowledge and belief I understand that false statements made herein are made subject to Pa.C.S.A.~4904 relating to unsworn falsification to authorities. Date:~ r-=VO~'I~~ Patricia 1. Potts 1 J2090 590466 PATRlCIA 1. POTTS, Plaintiff IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYL VANIA v. NO. CRAIG SLEDZINSKl, Defendant CIVIL ACTION - LAW CUSTODY ACCEPTANCE OF SERVICE I Craig Sledzinski hereby acknowledge that I have received a true and correct copy of the Complaint. Date: 1-") I-Of> 7/ J/,.",/ Address /):dJr/1 f; /} ()/7 I 132090590466 PATRlCIA L. POTTS, Plaintiff IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA v. NO. CRAIG SLEDZINSKl, Defendant CIVIL ACTION - LAW CUSTODY ORDER AND NOW, this ~"#f. day of md , ::WOO, pursuant to the entry of the attached StipulatioR, the Court ORDERS AND DIRECTS that the ierm~ofthe attached Stipulation For Custody shall be entered as an Order of Court. BY THE COURT: /~..~ r..-.. ~/;! /J / ,.~~..p. .-.>7'- J./'"", ,,"""."':w.:::. ....-'-~- ..- ~....," '" ~"':::;:-l::;:U~. J. 13lO90 590466 PATRICIAL. POTTS, Plaintiff IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA v. NO. CRAIG SLEDZINSKI, Defendant CIVIL ACTION - LAW CUSTODY STIPULATION FOR CUSTODY AND NOW, this day of , 2000, without any admission or acknowledgment of the allegations in the Complaint by the Defendant, and without any findings by the Court, the parties have agreed as follows: I. The Plaintiff, Patricia 1. Potts, shall have legal custody and primary physical custody of the minor child, Chelsea Sledzinski. 2. Defendant, Craig Sledzinski, shall be entitled to periods of physical custody as agreed to by the parties. 3. The effective date for the beginning of this custody schedule shall be immediately upon the execution of this Stipulation. 4. The parties waive the requirement ofPa.R.C.P. ~1915.7 regarding presentation of this Stipulation in open court. 5. The parties hereto desire that this Stipulation for Custody be entered as an Order of Court. WHEREFORE, Plaintiff and Defendant respectfully request your Honorable Court to enter the accompanying Court Order concerning the custody of the minor child. @ PATRlCIA1. POTTS, Plaintiff IN THE COURT OF COMMON PLEAS OF YORK. COUNTY, PENNSYL VANIA v. NO. Zf.X:J::) S-U -o:s CRAIG SLEDZINSKl, Defendant CIVIL ACTION - LAW CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth int the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a an Order may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose rights important to you, including custody or visitation of your children. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAW REFERRAL SERVICE 137 E. Market St. York,PA 17401 (717) 854-8755 - ::;; o ." ::z n .. ,~ -c I en " -<0 c:: 0::0 ::0-4 :Xz -0 c) P pC:: ::z (/) ClO rT1 .. W W r:;; .,,:n '" '"(J 7~~ .~< ::c-I'" .::..0 z (:J -...; 1:l' ;0 -< 120090560241 / \/ PATRlCIA1. POTTS, Plaintiff IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYL VANIA v. NO. 'ZCCD~ C)Z.-2......\ b ~O2:, . ~~ Q -tl :z ,,;, :&:at' ,'n -< ::2-:0 I 'r.... CJ1 t"_-~ ..~;:~l -2:11' .::1< ::I::S.gj cp 2; - > Plaintiff is Patricia 1. Potts, an adult individual currently residing at 42 ~ne~ CIVIL ACTION - LAW CUSTODY n -<2 O:;:u ::0-1 ~::r: ;;2 Ul "., CRAIG SLEDZINSKl, Defendant COMPLAINT FOR CUSTODY I. Court, Middletown, Dauphin County, Pennsylvania 17057. 2. Defendant is Craig Sledzinski, an adult individual currently residing at 71 Spring Lane, Dillsburg, York County, Pennsylvania 17019. 3. The parties are not married. 4. The parties are the natural parents of the child who is the subject of this Petition, namely, Chelsea E. Sledzinski, who was born September 22, 1999 at the Hershey Medical Center, Hershey, Pennsylvania. 5. During the past five years the child has resided with the following individuals at the following addresses for the following periods of time: NAME ADDRESS DATE The Parties: Patricia 1. Potts and Craig Sledzinski 71 Spring Lane Dillsburg, P A 9/22/99 - 4120/00 Patricia 1. Potts 42 Genesis Ct. Middletown, P A 4/20/00 - Present 126090560241 6 Plaintiff has not participated as a party or witness or in any other capacity in any litigation concerning custody of the child. 7. Plaintiff has no information of any custody proceedings concerning the children pending in any Court of this Commonwealth. 8. Plaintiff does not know any person not a party to these proceedings who claims to have custody or visitation rights with respect to the children. 9. The best interest and permanent welfare of the child will be served by granting the relief requested because the parties hereto have agreed that the attached Stipulation and Order are in the parties and the child's best interest. WHEREFORE, Plaintiff requests your Honorable Court to grant the relief requested and enter and Order incorporating the terms and conditions of attached Stipulation. Respectfully submitted, 1. Rex Bic ey 121 So St. Harri, urg,PA 17101 (717) 234-0577 (717) 234-7832 Attorney for Plaintiff 126090560241 VERIFICATION I, Patricia 1. Potts, verif'y that the statements made in the foregoing Complaint are true and correct to the best of my information, knowledge and belief I understand that false statements made herein are made subject to Pa.C.S.A.S4904 relating to unsworn falsification to authorities. Date:~ ~o~',~~ Patricia 1. Potts 126090560241 PATRICIA L. POTTS, Plaintiff IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA v. NO. CRAIG SLEDZINSKI, Defendant CIVIL ACTION - LAW CUSTODY STIPULATION FOR CUSTODY AND NOW, this day of , 2000, without any admission or acknowledgment of the allegations in the Complaint by the Defendant, and without any findings by the Court, the parties have agreed as follows: I. The Plaintiff, Patricia 1. Potts, shall have legal custody and primary physical custody of the minor child, Chelsea Sledzinski. 2. Defendant, Craig Sledzinski, shall be entitled to periods of physical custody as agreed to by the parties. 3. The effective date for the beginning of this custody schedule shall be immediately upon the execution of this Stipulation. 4. The parties waive the requirement ofPa.R.C.P. ~1915.7 regarding presentation of this Stipulation in open court. 5. The parties hereto desire that this Stipulation for Custody be entered as an Order of Court. WHEREFORE, Plaintiff and Defendant respectfully request your Honorable Court to enter the accompanying Court Order concerning the custody of the minor child. WITNESSES: ~ '%-;lJ( <-M- PATRlCIA1. POTTS, Plaintiff IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYL VANIA v. NO. CRAIG SLEDZINSKl, Defendant CIVIL ACTION - LAW CUSTODY ACCEPTANCE OF SERVICE I Craig Sledzinski hereby acknowledge that I have received a true and correct copy of the Complaint. Date: r.") I-Of> d,-- ~~. CRAI4 SLEDZ Kl 7/ J'p,,"! .L"~7" Address /):dJr/1 f; I /} 0/9 126090560241 CRAIG A. SLEDZINSKI/JESSICA SLEDZINSKI :IN THE COURT OF COMMON PLEAS Plaintiffs V. PATRICIA L. POTTS Defendant COMPLAINT FOR MODIFICATION OF CUSTODY ORDER AND NOW, this day of July 31, 2012, comes Plaintiff, Craig A. Sledzinski, and spouse, Jessica S. Sledzinski, representing themselves to avers as follows: 1. The plaintiffs are Craig A. Sledzinski, and Jessica S. Sledzinski, residing at 940 Myerstown Road, Gardners, Pa. Cumberland County, 17324. 2. The defendant is Patricia L. Potts, residing at 500 Geneva Drive, Apt. H5, Mechanicsburg, Pa. Cumberland County, 17055 3. The plaintiffs seek a modification of custody consisting of the new matter of split custody of the following children: : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-5166 C-) C CIVIL ACTION- CUSTODY MODIFCAT 'r -ri 4. C: rv.,s c? r Name Present Address Date-of-Birth Chelsea E. Sledzinski 940 Myerstown Rd. 09-22-99 Dalton J. Sledzinski Gardners, Pa. 17324 500 Geneva Dr. Apt. H5 04-17-02 Mechanicsburg, Pa. 17055 3. The plaintiffs seek that the previous order of shared physical/ legal custody of Chelsea E. Sledzinski be transferred to an order of primary physical custody to Craig A. and Jessica S. Sledzinski. Chelsea E. Sledzinski initiated this request to both parties in May of 2012. At this i s? vd Pct A4-? 7 736 time, the matter of custody regarding Dalton J. Sledzinski shall remain in effect as the previous order; shared physical and legal custody between only Craig A. Sledzinski, and Patricia L. Potts. 4. The children were born out of wedlock. The children are presently in the custody of Patricia L. Potts, who resides at 500 Geneva Dr. Apt. H5, Mechanicsburg, Pa. 17055. 5. During the past 5 years the children have resided with the following persons and at the following addresses: Name Address Dates Patricia L. Potts 500 Geneva Dr. Apt. H5 12/09- Mechanicsburg, Pa. 17055 Present Patricia L. Potts 2109 Princeton Ave. 02/04- Camp Hill, Pa. 17011 12/09 The mother of the children is Patricia L. Potts, currently residing at 500 Geneva Dr. Apt. H5, Mechanicsburg, Pa. 17055. She is single. The father of the children is Craig A. Sledzinski, currently residing at 940 Myerstown Rd. Gardners, Pa. 17324. He is married to Jessica S. Sledzinski. 5. The relationship of plaintiff, Craig A. Sledzinski, is that of natural father. The relationship of plaintiff, Jessica Sledzinski, is that of step-mother. The plaintiffs currently reside with the following persons: Name Relationship Levi Sledzinski Son of Craig and Jessica Sledzinski Chelsea Sledzinski Daughter of Craig A. Sledzinski 6. The relationship of the defendant to the children is that of natural mother. The defendant currently resides with the following persons: Name Dalton Sledzinski Relationship Son 7. The plaintiff(s) has not participated as a party or witness, or in another capacity, in other litigations concerning the custody of the children in this or another court. 8. Plaintiff(s) have no information of a proceeding concerning the child pending in a court of this commonwealth or any other state. 9. Plaintiff(s) does not know a person part of the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the children. 10. The best interests and the permanent welfare of the child, Chelsea E. Sledzinski, will be served by granting the relief requested because: A. Child does not have a healthy relationship with the defendant. There have been allegations made by child that she and the defendant were having verbal and physical altercations on a regular basis, escalating in the months prior to child volunteering to leave the home. B. Plaintiff(s) have dates and times upon request where phone calls took place concerning the details of these fights. Defendant at one point asked the plaintiff(s) to take Chelsea out of her home due to her inability to get control/ respect from child. The first phone call to the plaintiffs did not result in any decision at that time. The child, Chelsea Sledzinski also made 2 phone calls asking the plaintiffs to come and get her out of home. The 2"d phone call resulted in father coming to pick her up at approximately 10:30 pm. on Thursday May 24th. The defendant, Patricia L. Potts, was in agreement at that time that she should leave the home. When father arrived at the defendant's home, child was waiting outside alone with her clothing in trash bags. Her mother helped put her belongings in the bags. C. Plaintiffs, Craig and Jessica Sledzinski, have been together for 8 years and married for 3 years. Father works full-time and Jessica is a stay-at-home mother to their son, Levi Sledzinski and also for Chelsea Sledzinski at this time. Jessica is also an online student for medical transcription. Jessica is scheduled to graduate in spring of 2013 and plans to work from home, so there is always a parent at home and available for the children. Plaintiffs are able to provide a healthy, stable, and more relaxed home atmosphere for the child in which custody is sought. Both plaintiffs are able to give the stability that the adolescent is in need of. Father plays the role of provider and disciplinarian, while step-mother takes on the role of care taker and teaching responsibility in the home. The household atmosphere consists of regular meals, family activities, taking care of family pets, chores, teaching responsibility and positive reinforcement. Athletics are a core focus in the children's activities, which have always been in both households. D. In the opinion of both plaintiffs and Chelsea Sledzinski, the defendant has a history of extreme outbursts of rage and vulgarity with anger management issues. Defendant cannot demonstrate self-control with her temper and anger. Therefore, the children are being affected by this behavior and are exhibiting the same type of behavior. The demeanor of the defendant has been a problem as long as the children were born, however; since the defendant moved to Geneva Green Apartments, her drinking habits increased, per what the children have said and also noticeably to plaintiffs. The defendant also joined several dating websites and was focusing on finding a companion. According to Chelsea, some evenings that she would go out on dates or have company at the home, her mother would end up drinking too much and drama would normally occur. There allegedly was one occasion in which the defendant was drinking and passed out on the floor while one the children had a guest staying the night. These are some of the contributing factors that have caused the lack of respect and fighting with her mother. On the evening that Chelsea left the home, there was a confrontation between Chelsea and Dalton while the defendant was not home, and once the defendant arrived home with her friend, in which she was dating, the fight continued and eventually a phone call was made by Chelsea stating that she wanted to leave. Plaintiff, Craig Sledzinski and defendant, Patricia Potts, spoke and defendant gave Craig permission to take Chelsea from the home. From the past and presently there have been ongoing problems communicating effectively with the defendant. Between attempting to talk on the phone, or in person, defendant controls the conversation. If plaintiffs try to express an idea that she does not agree with, typically then the defendant starts a raging rant and will hang up/ kick you out of her home without any resolve. This communication problem makes co-parenting very difficult among the two families. E. While residing in the defendant's home, Chelsea and her brother Dalton were having some intense fighting with one another. At times both children were left at home alone and these fights would also occur during these times. With no adult supervision or no one to intervene, these altercations could result in either child being injured, and is not a safe environment for either child. The siblings do at times, get along very well, but when a fight erupts the situation can be more intense/aggressive than the normal sibling quarrels. Since being separated they are missing each other. In the result, the time that they do spend together during week-end visits have been more peaceful and enjoyable for both children. F. Daughter admitted that she was feeling depressed in mothers household, and felt embarrassed by her mother's behavior. Daughter also admits that her behavior in mother's household was not acceptable. She allegedly used bad language, acted defiant towards mother and brother. She expresses that she felt her brother always got his way and was favored by mother. Chelsea is open to and wanting to get some counseling for all the issues with the defendant. However, per conversation with Jessica Sledzinski and Patricia Potts; Patricia was completely against the idea of family counseling. Once custody is established, plaintiffs would like Chelsea to see a family counselor with or without her mother, preferably with her mother and brother to try to encourage building a healthier relationship. G. In the past 2 months of leaving the defendants residence, daughter, Chelsea Sledzinski, seems very happy and relaxed in her new home environment. Plaintiffs have not had any issues with violence, bad language, or disrespect. Chelsea is of legal age to decide which parent she would like to reside with full-time. After giving daughter some time to make sure she wanted to make a permanent move, her decision is that she would like be in the custody of the plaintiffs. Due to the Plaintiffs residence being in the Carlisle school district, it was agreed between defendant and plaintiffs that she shall remain in Mechanicsburg school district. Plaintiffs are actively in process of relocating. Should custody and housing not be established by the start of the 2012-13 school year, Chelsea can stay with grandparents, John Sledzinski and Judy Palm on South Market Street, Mechanicsburg, Pa. 17055 during school week or with mother if necessary until custody and residency is changed. Wherefore, plaintiffs request the court to grant custody modification of the child, Chelsea Sledzinski. Respectfully Submitted, Self- Rep resdnted / Plaintiff(s) VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. 4909 relating to unsworn falAfication to authorities. x Planitiff(s) I %f Date CRAIG A. SLEDZINSKI, JESSICA S. IN THE COURT OF COMMON PLEAS OF SLEDZINSKI PLAINTIFF PENNSYLVA} & CUMBERLAND COUNTY --+ , MW =fn a C= -? "' <?' 2004-5166 CIVIL ACTION LAW i " < ? PATRICIA L. POTTS IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, August 06, 2012 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, September 05, 2012 at 1:311 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in disp te; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temp rary 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/ Jaequeline M. Verney, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Amer cans 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 S eG?Z??IS??, Cr8 aer-x 1 c a ?s . r T'q e f e j? ?oe N- k/eo? J- 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 plIf 93 00? Lea g?? /? 2 CoP? CRAIG A. SLEDZINSKI and : IN THE COURT OF COMMON PLEAS OF JESSICA SLEDZINSKI, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : N0.2004-5166 CIVIL ACTION -LAW FATRICIA L. POTTS, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 7~ day of S t.~~ . , 2012, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Order of Court dated May 16, 2000 is hereby vacated. 2. The Father, Craig A. Sledzinski and the Mother, Patricia L. Potts, shall have shazed legal custody of Chelsea E. Sledzinski, born September 22, 1999 and Dalton J. Sledzinski, born April 17, 2002. Each parent shall have an equal right, to be exercised jointly with the other pazent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regazding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each pazent shall be entitled to all records and information pertaining to the children including, but not limited to medical, dental, religious or school records, the residence address of the children and the other pazent. To the extent one pazent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other pazent within such reasonable time as to make the records and information of reasonable use to the other pazent. Both pazents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor children. Each pazent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cazds. Additionally, each pazent shall be entitled to receive copies of any notices which come from school with regazd to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. The children shall continue to attend Mechanicsburg School District schools. 3. Mother shall have primary physical custody of Dalton and Father shall have primary physical custody of Chelsea. The children shall alternate weekends from Friday at 5:00 p.m. to Sunday at 5:00 p.m. such that the siblings shall spend every weekend together. In addition, Mother shall have physical custody of Chelsea overnight every Wednesday from after school to Thursday morning when she will be responsible for getting her to school and Father shall have physical custody of Dalton every Thursday from after school to Friday morning when he will be responsible for getting him to school. 4. Holidays: A. Christmas shall be divided into two Blocks. Block A shall be from 12:00 noon on Christmas Eve to 12:00 noon on Christmas Day at 12:00 noon. Block B shall be from 12:00 noon on Christmas Day to 12:00 noon on December 26. Mother shall have physical custody of the children for Block A in even numbered years and Block B in odd numbered years. Father shall physical custody of the children for Block A in odd numbered years and Block B in even numbered yeazs. B. All other holidays shall be shazed as agreed by the parties. C. Each pazent shall be entitled to two non-consecutive weeks of vacation in the summer, provided they give the other parent 14 days prior notice. 5. Transportation. Transportation shall be shared such that the receiving party shall transport. 6. Neither parry may consume alcohol to the point of intoxication or use illegal drugs immediately before or during their period of physical custody. 7. Neither party shall do nor permit a third party to do, or say anything that would estrange the Children from the other parent, injure the opinion of the Children as to the other pazent, or hamper the free and natural development of the Children's love and respect for the other pazent. 8. RELOCATION: No party shall be permitted to relocate the residence of the children which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the children consents to the proposed relocation or the court approves the proposed relocation. A person proposing to relocate MUST comply with 23 Pa. C. S. § 5337. 9. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, J. c~ Craig Sledzinski, pro se ~ ~ ~ ~ 940 Myerstown Road c Gazdners, PA 17324 y I ~~, / Patricia L. Potts, pro se ~~ -~ ~"" 500 Geneva Dr. Apt HS ~ ~ ~ '~' Mechanicsburg, PA 17055 ~~ ~ ; ~° ~~ = ~p /i~ ~ CRAIG A. SLEDZINSKI and JESSICA SLEDZINSKI, Plaintiffs V. PATRICIA L. POTTS, Defcndant PRIOR JUDGE: None IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2004-5166 CIVIL ACTION -LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who aze the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Chelsea E. Sledzinski September 22, 1999 Father Dalton J. Sledzinski April 17, 2002 Mother 2. A Conciliation Conference was held in this matter on September 5, 2012, with the following in attendance: The Father, Craig A. Sledzinski, pro se (step mother, Jessica S. Sledzinski is not a proper party), and the Mother, Patricia L. Potts, pro se. 3. The Honorable Judge Renn of York County previously entered an Order of Court dated May 16, 2000 providing for shared legal custody, Mother having primary physical custody and Father having alternating weekends. 4. The parties agreed to an Order in the form as attached. Date: / _S ~~ 1. acq line M. Verney, Esquire Custody Conciliator