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Home My WebLink About05-0395 " IN mE COURT OF COMMON PLEAS CUMBERLANDCOUNTY.pENNSYLV ANIA CHANDRA L. ULRICH. Plaintiff " " vs. " " NO. OS- Ctu\lY~ " RODNEY A. ROUSH, Defendant " " CMLACTlON-LAW IN CUSTODY .. COMPLAINT FOR CUSTODY AND COMES NOW, CHANDRA L. ULRICH, by and through her attorney, Bradley A. Wmnick, Esquire, of Wiley, Lenox, Colgan & Marzzacco, P.C., and files the instant Complaint for Custody, and in support thereof, avers as follows: I. The Plaintiff is Chandra L. Ulrich, who currently resides at 402 Cocklin Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Rodney A. Roush, who currently resides at 606 W. 2nd Street, Hummelstown, Dauphin County, Pennsylvania 17036. 3. Plaintiff seeks primary physical custody of the following child: Amber G. Ulrich, born on February 24, 2003. The child was born out of wedlock. The child is presently in the physical custody of Plaintiff and Defendant. During the past five years, the child has resided with the following persons and at the following addresses: A. From birth, February 2003 to the present date, January 2005, the child has resided in Mechanicsburg with Plaintiff and Plaintiff s parents, Carolyn and Donald Ulrich, at 402 Cocklin Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 4. The relationship of Plaintiff to the child is that of mother. Plaintiff currently resides with her daughter, Amber G. Ulrich, and her parents, Carolyn and Donald Ulrich. 5. The relationship of Defendant to the child is that of father. Defendant currently resides with a roommate, Christopher, last name unknown. 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 has no infonnation of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or who 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 Plaintiff primary physical custody of the child. 8. 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. WHEREFORE, Plaintiff respectfully requests This Honorable Court to award her primary physical custody of the minor child. By: Respectfully submitted, WILEY, LENOX, COLGAN & MARZZACCO B!frlr.t ~re ID# 13 130 W. Church Street DiIlsburg, PA 17019 (717) 432-9666 Dated: ,I, ~ /0,5' VERIFICATION I, Chandra L. Ulrich, verify that the statements made in this document are true and correct to the best of my knowledge, infonnation, and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. Date: (JI 11.3 105 ~d~ CHANDRA L. ULRICH Plaintiff 7'V \ ~ -- ~ -- ~ ~ ~ I/( () ~ "'" ~ ~. r 4- E ~ "I<:l. -:--- D C>- ~ (' ~>=: ~':!1 <.;..rI :1" '~_ r:-? (}'''; C\ ... r._~ ~;-> " ('., - .f(j -,--I CHANDRA L. ULRICH PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 05-395 CIVIL ACTION LAW RODNEY A. ROUSH DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, January 25, 2005 , upon consideration of the attached Complaint. it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. at DJ Manlove's, 1901 State Sf., Camp Hill, PA 17011 on _.-Er:i~ay, March 04, 2005 , the eonciliator, at 11:30 AM ~"-"'-,"-'- 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 bc hcard 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 the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours pri,~r to scheduled hearinl!. FOR THE COURT. By: Isl Melissa P. Greevy. Esq. o:i-- 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 infonnation about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please ('ontact 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 ~ ~1- ~ f-ItP;J _ * ~ ff-l~ T~"~ ~ f'1n-4JpiJ 5"0 "le( )" (j '1(' / pJ 1f' ( ~ ~\'J , Q7 W:l~ ~\)SL "f' ',~ \\\~ /' .,"::\ ,,'A' -5':) ...'..J.,. CHANDRA L. ULRICH, Plaintiff * * IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYL V ANIA * vs. * * * * * CIVIL ACTION - LAW IN CUSTODY NO. 05-395 Civil Term RODNEY A. ROUSH, Defendant * AFFIDAVIT OF SERVICE I, Sherie A. Minich, being duly sworn, deposes and says that she is an adult and that she served a Custody Complaint on the Defendant, at the Defendant's last known address as follows: Rodney A. Roush, 606 West 2nd Street, Hummelstown, P A 17036, by certified mail, return receipt requested, restricted delivery, on January 18, 2005, and the same was received by him on January 22,2005. The Certified Mail Receipt and PS Form 38111 are attached hereto, marked Exhibit "A" and made a part hereof by reference thereto. Date: January 25, 2005 WILEY, LENOX, COLGAN & MARZZACCO, P.C. ~ By: iliAl~ 1.1 71)it.INf..J .stlrie A. Minich COMMONWEALTH OF PENNSYL VANIA : SS COUNTY OF YORK On this, the 25th day of January, 2005, before me, a notary public, personally appeared Sherie A. Minich known to me or satisfactorily proven to be the whose name is subscribed to the within Affidavit and acknowledged that she executed the same for the purposes therein contained. WITNESS, my hand and notarial seal the day and year aforesaid. c--sl1"1 LLA ~/-t/tD)' NOTARY UBLIC My Commission Expires: ~. "- ~., [;., My C02" Member, r-i;;, '! Seal . '~e~> Notary Public '2011< COunty .,' May 17, 2005 ',,"nOfNotaries Notana.l Seal S. Dawn Gladfelter, Notary Public DWsburg Bom, York County My Commis:::ion Expires May 17, 2005 Member, Penn.5"ylvamaAssoclationoiNotanes fT1 fT1 l'- <<3 ,.; LJ1 fT1 ..c u.s. Postal Service", CERTIFIED MAIL" RECEIPT {Domestic Mall Only; No Insurance Coverag Provided} OFFICIAL PDOtage $ 37 USE Certified Fee \O\ltlG Pill /0 {p Postma'" _ N 1 8 "i005 )_ ~ c:J t:J l'- fT1 c:J c:J Re\Um Red.pt F.. C) (Endorsement Required) C] Restrlcted Delivery Fee Ul (Endorsement Required) l'- c:J ",t . CampIete Items 1, 2, end 3. Also comp1et8 ..... 4 WRestricted Dellveoy ~ desII8d. . PI1nt your name and addlllSS on the I1!Y8I'88 10 _ we can .return ~ card to you. . AIlIlch this card to the back of the rna/IpIeCe, or ..., the front If space petmlts. 1. MIele Addressed to: ~;~ A;Jo~ Hl.J..rnmdsfounJ /J; I7D3(p ''''''':-,.. .:;...,.."..--. '..~.' 2. MIele""'" r---1olloII PS Faron 3$11, r=.bt\J8ty 2004 s. _"JYpo Ilf ~g 0 ElcpnloS Moll O...........~ JlIRo1um_ptlor~h_ o Insured Mall b c..O.O. . 4. _ Oe/III<<Y? (Extm FH) q(Yes 7004 0750 0003 6351 8733 DbmeIttc Return ReceIpt 102S954J2--M-1&4b 1 EXHIBIT "A" <J r; 4".- -0\:",;;1 ri1pl t~f~: ,~;'I.._i "~-"I :'":""..{ ~:,O ;::..,.C: ~ ~:==) "n '- Sc N -c, t~; t''') - vs. * IN THE COURT OF COMMO PLEAS * CUMBERIANDCOUNTY ,PE YLV ANIA * * * NO. 05-395 * * * CIVIL ACTION - LAW * IN CUSTODY CHANDRA L. ULRICH, Plaintiff RODNEY A. ROUSH, Defendant PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly withdraw the Complaint for Custody filed by Plaintiff on January 2 , 2005, and discontinue the above-captioned action. Respectfully submitted, WILEY, LENOX, COLGAN & MA ACCO Dated: .g II' / ()f' Bradley, 'A. innick, Esquire 130 W s hurch Street DiIlsburg, PA 17019 (717) 432-9666 J.D. # 78413 ~ = <J' :::;J; ..... -:::0 N <.-J $2 ~ -r;JC~: r"f\J"-\ ~ Z';c ~~~J., 1-::':\' ~~~, ~. L <' -------------- .". ::t: - - Q, :t,-:-< {"11r: """0,.,... -,,0 (~Q ~-::L ...,~ Q(~ ;::/M ;:j ~!l N VO Plaintiff I I I i MAR 2 B 2005t I IN THE COURT OF COMMoN PLEAS OF CUMBERLAND COUNTY, PE~NSYLVANIA NO. 05-3951CIVIL T~RM CIVIL ACTilON - L1W IN CUSTODY J CHANDRA L. ULRICH, v. RODNEY A. ROUSH, Defendant CONSOLIDATION ORDER . I AND NOW, this 36~ day of March, 2005, it is herebyl ORDE ED that the above captioned action is consolidated with the prior action in this mrtter do keted to No. 05-348 Civil Term. J. Dis!: ./~. Connelly, Jr., Esquire, PO Box 650, Hershey, PA 17033 .-8fadley A. Winnick, Esquire, 130 W. Church Street, Dillsburg, PA 17019 :247038 " . ~ /--~~ 03-31-05 ! 0.111,.." . I I ~...; I .." ,<C, 'I I ,)~. -.. <~ d '_'-;:" ~LU~ FLANAGAN AND ASSOCIATES BY: J. MICHAEL FLANAGAN, Esquire Identification No. 23149 150 East Chestnut Street Lancaster, PA 17602 (717) 397-9444 Attorney~ for De~ ndants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION i ! No. 05-449 Ci~il Term LEROY E. RICHCREEK, JR., WELLSPANC MEDICAL GROUP, WELLS PAN YORK HOSPITAL, and PINNACLE HEALTH Plaintiffs -v- ERIE INSURNCE GROUP T/DIBIA ERIE INSURANCE COMPANY Defendants PRAECIPE JURY TRIAL ~EMAN , i ED I I TO THE PROTHONOTARY: ) Please enter the appearance of Flanagan and Associates on beh~ of Defi ndants, Erie Insurance Group t/d/b/a Erie Insurance Company, in the above-captioned a~tion. A papers may be served at 150 East Chestnut Street, Lancaster, Pennsylvania 17602. By: CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document has be n served by Pirst Class Mail, postage prepaid, upon the following: Dusan Bratic, Esquire Law Offices 101 Office Center Suite A 101 South U.S. Route 15 Dillsburg, PA 17019 Attorneys for plaintiff FLANAGAN AND ASS CIATE Attorneys for Defenda 18 Erie Insurance Group t/d/b/a Erie Insurance Comp y ----' DATE: 3 -j.'9- tJ~ By: J. chael Plana an, Esq ire 'J.D. No. 23149 ~_:.> '-:-~) ~'j'l t;';:; " :j.) -:? -q \~~ f:\ c-,)_ ,_l .. --C" ....~) '.. ()\ ~