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Home My WebLink About05-0348 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA. NO. O~ -JL{p C!.1~l T~ RODNEY A. ROUSH, Plaintiff CHANDRA ULRICH Defendant CML ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY L The Plaintiff is Rodney A. Roush, residing at 606 West 2nd Street, Hummelstown, Dauphin County, Pennsylvania, 17036. 2. The Defendant is Chandra Ulrich, at 402 Cocklin Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff seeks partial custody of the following child: NAME PRESENT RESIDENCE D.O.B. Amber Grace Ulrich 402 Cocklin Street Mechanicsburg, P A February 24, 2003 The child was born out of wedlock. The child is presently in the custody of Defendant, Chandra Ulrich, who resides at 402 Cocklin Street, Mechanicsburg, Cumberland County, Pennsylvania. During the past five years, the child has resided with the following persons and at the following addresses: NAME RESIDENCE DATE Chandra Ulrich (Mother) Donald and Carolyn Ulrich (Maternal Grandparents) 402 Cocklin Street Mechanicsburg, PA Birth - present The mother of the child is Chandra Ulrich, currently residing at 402 Cocklin Street, Mechanicsburg, Cumberland County, Pennsylvania. She is single. The father of the child is Rodney A. Roush, currently residing at 606 West 2nd Street, Hummelstown, Dauphin County, Pennsylvania. He is single. 4. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons: Suzanne M. Weiss RELATIONSHIP Girlfriend NAME Christopher Schertzer Roommate 5. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the following persons: NAME RELATIONSHIP Amber Grace Ulrich Daughter Donald and Carolyn Ulrich Maternal Grandparents 6. 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 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. 7. The best interest and pennanent welfare of the child will be served by granting the relief requested. 8. Each parent whose parental rights to the child have not been tenninated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, the Plaintiff, Rodney A. Roush, requests the court to grant him partial custody rights to the minor child, Amber Grace Ulrich. JAMES, SMITH, DIETTERICK & CONNELLY LLP Date: \ \ \ 1\ oS- VERIFICATION I verifY that the statements made in this Pleading 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: JfHJ, il , >}..cu;>(; ~J:;2 Rodney A. Roush /[ 10 n "'i4 t ~ """- ....... ,-, ,"'C:'_' .- . \:;..i'1 '-. ~ ~-:: \; Cr) >J 0 ...,,'.. -- ...c:. ~ ,-,""\ ......) ~ -t') -- tf' --JJ -..... (.) f ~~ c.) J--" j 0; ~ ...c ~ RODNEY A. ROUSH PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 05-348 CIVIL ACTION LA W CHANDRA ULRICH DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, January 21, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear bcforc Melissa P. Greevy, Esq. . the conciliator, at DJ Manlove's, 1901 State St., Camp Hill, PA 17011 on l'I.j<l'IX,-.~.~.r:ch 04, 2005 at 11:30.AM for a Pre-Hearing Custody Conference. At such conference, an effort will be rrmde to resolve the issues in dispute; or if this cannot be accomplished, to detlne 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 pennanent order. The court hereby directs tbe parties to furnisb any and all existing Protection from Abuse orders, Special Relief orders, and Custodv orders to the concillator 48 bours prior 10 scbeduled bearine:. FOR THE COURT. By: Isl Melissa P. Greevy. Bsq. 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 infonllation 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 A TTORNEY AT ONCE. IF YOU DO NOT HA VE 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 4ww<frl 'I ~ 4; J/l-hf../ _ rfp ~ ~?JJj!1L-, frJ- h~ / Ml ftp?~ ~ fI1J 5V'/lel ': '..... .. --: ,:'.' " .~, _.,) ot" ,'";, .. - - ~Hl ~o ":;':,.'. ~\ :iG"'O:Jld - , ;..1"1..11 "' () 0nOl: , '((I ;J f'l\ . Defendant IN THE COURT OF COMMO PLEAS OF CUMBERLAND COUNTY, PE NSYLVANIA NO. 05-348!CIVIL T RM CIVIL AdlON - L W IN CU~TODY RODNEY A. ROUSH, Plaintiff v. CHANDRA ULRICH, ORDER OF COURT AND NOW, this 10Jt#. day of March, 2005, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and direct d as foil ws: 1. Leqal Custody. The parties, Rodney A. Roush and Cha dra Ulri h, shall have shared legal custody of the minor child, Amber Grace Ulrich, born Fe ruary 24 2003. Each parent shall have an equal right, to be exercised jointly with the oth r paren , to make all major non-emergency decisions affecting the child's general well-being inclu ing, but not limited to, all decisions regarding her health, education and religion. ursuan to the terms of 23 Pa. C. S. 95309, each parent shall be entitled to all records and .nformat n pertaining to the child including, but not limited to, medical, dental, religious r school records, the residence address of the child and of the other parent. To the e tent on parent has possession of any such records or information, that parent shall be equired to share the same, or copies thereof, with the other parent within such reasonabl time a to make the records and information of reasonable use to the other parent. 2. Phvsical Custodv. Mother shall have primary physidl custo y subject to Father's rights of partial custody which shall be arranged as follows: 1 I Effective March 20, 2005, each Sunday from 10:~0 a.m. t 4:00 I I B. Effective March 22, 2005, each Tuesday and Th~rsday e ening from 5:00 p.m. to 8:00 p.m. ' A. p.m. C. Effective June 12, 2005, each Sunday from 9:0 a.m. t 5:00 p.m. D. Effective September 10, 2005, Father's weekend custodi I time shall be expanded to begin Saturday at 4:00 p.m. until Sund at 5:0 p.m. each week. I , I E. Effective January 6, 2006, Father's weekend ~ustodia time schedule shall be modified by commencing his weekend time as Friday t 5:00 p.m. and continuing until Sunday at 5:00 p.m. on alternating we kends. , I . -' . NO. 05-348 CIVIL TERM 3. Holidavs. The parties shall share or alternate the m~jor holi ays by their mutual agreement. J. Dis!: l,le!ln J. Connelly, Jr., Esquire, PO Box 650, Hershey. PA 17033 L..~ley A. Winnick, Esquire, 130 W. Church Street, Dillsburg. PA 17019 ~, c:-:\ -OS 03-5 ,'" )'.L\::'"';;:' ':'J I 0 : II 14'11 I S ~{~IH SCDZ !~, ~.I I . MAR Z 8 200~ f'r'. ~ Plaintiff IN THE COURT OF COMM N PLEAS OF CUMBERLAND COUNTY, P NNSYLVANIA NO. 05-34~ CIVIL T RM CIVIL ACtiON - L W IN CU~TODY RODNEY A. ROUSH, v. CHANDRA ULRICH, Defendant CUSTODY CONCILIATION SUMMARY REPOR IN ACCORDANCE WITH CUMBERLAND COUNTY RULE 0 CIVIL ROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following r port: 1. The pertinent information concerning the child who i the s bject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN HE CU TODY OF Amber Grace Ulrich February 24, 2003 Mother 2. Father filed a Complaint for Custody on January 1 ,2005. A Custody Conciliation Conference was held on March 18, 2005. Present for the onferen e were: the Father, Rodney A. Roush, and his counsel, John J. Connelly, Jr., Esquire; the Mother, Chandra Ulrich, and her counsel, Bradley A. Winnick, Esquire. 3. The parties reached an agreement in the form of an Ord ~ .:l/~J loC; Date :247039