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Home My WebLink About05-4403 LARRY E. OTT, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW : NO. 05 -,<{"fo ~ : IN CUSTODY CIVIL TERM SAMANTHA A. MILLER, Defendant COMPLAINT FOR CUSTODY I. Plaintiff is Larry E. Ott, Jr., an adult individual currently residing at 17 Short Lane, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant is Samantha Miller, an adult individual currently residing at 90 Oak Drive, Orttanna, Adams County, Pennsylvania. 3. The parties are the natural parents oftwo (2) children, namely, Lauren Marie Ott, born January 16, 2002, and Carolynn Morgan Ott, born October 11, 2004. The children were born out of wedlock. 4. For the past five (5) years, or since the children's birth, the children have resided with the following persons at the following addresses for the following periods oftime: NAME ADDRESS DATES Samantha A. Miller 90 Oak Drive May 2005 to Steve Miller Ortanna, P A Present Joan Miller Larry E. Ott, Jr. 17 Short Lane December 2005 to Samantha A. Miller Shippensburg, PA April 2005 NAME ADDRESS DATES Samantha Miller 90 Oak Drive September 2004 Steve Miller Ortanna, P A December 2004 Joan Miller Larry E. Ott, Jr. 3585 Chambersburg Road June 2002 to Samantha A. Miller Biglerville, P A September 2004 Larry E. Ott, Jr. 4515 Chambersburg Road January 2002 to Samantha A. Miller Biglerville, P A June 2002 KimOtt The natural mother of the children ]s Samantha A. Miller who resides as aforesaid. She is single. The natural father of the children is Larry E. Ott, Jr. who resides as aforesaid. He is single. 5. The relationship of the Plaintiff to the children is that of natural father. The Plaintiff currently resides alone. 6. The relationship of the Defendant to the children is that of natural mother. Defendant currently resides with her parents, Steve and Joan Miller, and the children at issue. 7. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the children. 8. Plaintiff has no information of any custody proceedings concerning the children pending in any Court of this Commonwealth. 9. It is in the best interest and permanent welfare of the children to grant the relief requested because: a) The parties have always equally shared the role of caretaker for the children; b) Defendant lives in housing which is inadequate and unsafe for the children. c) Defendant has shown an inability to provide for the financial, physical and emotional needs of the children; 10. 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. WHEREFORE, Plaintiff requests your Honorable Court to schedule Custody Conciliation Conference followed by a hearing at which time he should be granted shared physical custody of the children. Respectfully submitted, i\J(\ nT\J\ h '\,\ ~11 ",-,\!,. -;;\{Y' '~111 Hannah Herman-Snyder, Esqm e Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verifY that the statements made in the foregoing document 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 falsifications to authorities. DATE: ~ /Q5 /05 I / L:i::HOir,~: eft -k 4\ ~ f'\ .... - -- l>' ,..J ..{') "" \' ~ .J\ v \ - - - U' Q\ C) c- ....., ~~:':; ;::g o "T' -..... :J:-n ~ rnp -)iIl --;]~..1 ;-'1.1.. "1(>) :0-- r,.) O"~ :.':> ;;-~~ i:~:; ;-'{I :;-, ~".. :.,::1 ..< LARRY E. OTT, JR. PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V. 05-4403 CIVIL ACTION LAW SAMANTHA A. MILLER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, August 30, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueliue M. Verney, Esq. . the conciliator. at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, September 22, 2005 at 10:30 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 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 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 tbe conciliator 48 hours prior to scheduled hearin!!. FOR THE COURT, By: /s/ Jacqueline M. Verney, ESQ. ,_.y' 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 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 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 (7 I 7) 249-3 166 . ~~ jp "~ 1'P'V1I ~ 3(?-/[:$ ~ W :; ~ ~J.< .J?-/[:3 ~- ~ fiv 'JZ /&->17>>' ~ -P9 y;?'/E'.g, kLNr'"\C"" SO :Z Hd I S ~,ri'l SGOZ ^tiV1Ci<GU.(.~:'Jd 3Hl jO 381.:-1::,[:-0:11H -5RECEIVEO SEP 162005 LARRY E. OTT, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2005-4403 CIVIL TERM SAMANTHA A. MILLER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 16th day of September, 2005, the Conciliator, having been advised that the parties have reached a stipulated agreement, hereby relinquishes jurisdiction in this matter. FOR THE COURT, ody Conciliator ~ "". wQ Qt) ~~ ~'IJ IS 'B ..0 ..:;r i!> ~ c.- 0" - c: '-;'/ ':'.'><C '~~'& ~)? ,~\~ , ~j \.J.-i "(10- :< {3 fu c/> ~ vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW LARRY E. OTT, JR., Plaintiff SAMANTHA A. MILLER, Defendant : NO. 05-4403 CIVIL TERM : IN CUSTODY PRAECIPE TO THE PROTHONOTARY: Please withdraw and discontinue the Complaint for Custody filed in the above captioned action. DATE: C\ - I 3 - () "i i\l"'''J\/\ h ').II" "'0" . x\""e'~ Hannah Herman-Snyder, Esq re Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street (717) 243-5551 (800) 347-5552 o c ", ""Oft- ;_~;I": ;2: U) ;..:::;: ?;(.~ '~( . j:;-c.: Z :;: ...., "'" = """ (/) Cd N o ~ ~~ -0,..., ~D"1 00 .CO'-'" :r: ....p -::O..~. ...!.J ~~ ~ ;e: :~ 5: <? ..0