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Home My WebLink About06-2856 , 0 TANNER LAW OFFICES, LLC 1300 Market Street, Suite 10 Lemoyne, P A 17043 Phone (717) 731-8114/ Fax (717) 731-8115 Attorney for Plaintiff v. ~ ~ ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SUZANNE SUTCH, Plaintiff JAMES SUTCH, Defendant CUSTODYNISITATION NO. Ole. -dP~b ClA__~8/2..r1 COMPLAINT FOR CUSTODY I. The Plaintiffis Suzanne Sutch, residing at 19 Wineberry Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is James Sutch, residing at 19 Wineberry Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff seeks custody of the following child: ~ Name Present Address Jared Sutch 19 Wineberry Drive Mechanicsburg, PA 17055 7 (D.G.B. 110/2/98) 4. Jared Sutch was not born out of wedlock. 5. The child is presently in the custody of the Plaintiff, Suzanne Sutch and the Defendant, James Sutch, who reside at 19 Wineberry Drive, Mechanicsburg, Pennsylvania 17055. , . 6. During the last five years, the child has resided with the folIowing persons at the fOlIowing addresses: Person( s ): Suzanne Sutch James Sutch Address: 19 Winebeny Drive Mechanicsburg, PA 17055 Dates: ] 996 - Present 7. The mother of the child is Plaintiff, Suzanne Sutch currently residing at 19 Wineberry Drive, Mechanicsburg, Pennsylvania 17055. 8. The father of the child is Defendant, James Sutch, currently residing at 19 Wineberry Drive, Mechanicsburg, Pennsylvania 17055. 9. The relationship of the Plaintiff to the child is that ofrnother. 10. The relationship of the Defendant to the child is that of father. II. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. 12. 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. 13. The best interests and permanent welfare of the child will be served by granting the relief requested. The quality ofthe child's physical, intellectual, moral and spiritual environment would be improved by Plaintiffs increased and continuing involvement in the Child's life. . . WHEREFORE, Plaintiff requests the Court to grant her Primary Physical Custody of the Child. Respectfully submitted, DATE: sin/oc, 7~ Jj. -k~ Tabetha A. Tanner, Esquire Supreme Court J.D. No.: 91979 Attorney for Plaintiff TANNER LAW OFFICES, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 (717)731-8114 ,. . VERIFICATION I verify that the statements made in this custody complaint are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn falsification to authorities. Date: S //7 /()&; ,5;'~~\\ C .:6L S anne Sutch tJ\:L \.) ~ - ~ - )...) C> - Q 0 ,...., G -l ~ c;:':;,) ~ ~ c = ~ ~ "o~. :;:l:: ..... to 1:2 { :P'" ::C::tl - .....: fl"\{- -t: _elm =t (/,") - '")9 -...:), eX) ()c ~:L ::;.~-^f'- ..", ":,,-:- "'T~ k -;>, I~:')B ~~E\~_ :> 2m 'i! c.. .'-> .<-- ~ :~ (,) (;) SUZANNE SUTCH PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-2856 CIVIL ACTION LAW JAMES SUTCH DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, May 26, 2006 , 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 MDJ Manlove, 1901 State St., Camp Hill, PA 17011 on Friday, July 21, 2006 at 2:30 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 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 the conciliator 48 hours prior to scheduled hearinl!. FOR THE COURT. By: Isl Melissa P. Greevy. Esq. Custody Conciliator j!r" 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 (717) 249-3166 ~~ c;z ~ ~ 7(l-o[':9 .~ ~ ~ -4v ?(J-O~'F ~Jp;2 "f!~ ~ -f??; ')o-oE'.> 'i--.nr' " t 'I~. , _ . I'l!'{'i!\ ii\~:\:rH:-i ALNnr), r',-,', ,'::";,::;', ."'1v^J.n:J g G :2 lid DC A tll4 gaOl AWICNv.r'~1 i (i.{o' :JI-/l' ..10 ""t'"'H . 1:;",'J1-J ...., ~ ::J0d.::iu-Q311:l - SUZANNE SUTCH, Plaintiff v. ~ ~ ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW JAMES SUTCH, Defendant CUSTODY /VISITATION NO. 06-2856 CIVIL ACTION LAW CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I served a copy of the Custody Complaint, filed in the above-captioned matter, upon the following person at the following address, via first class mail, postage prepaid, addressed as follows: Mr. Bradley A. Winnick, Esquire The Wiley Group 130 W. Church Street, Suite 100 Dillsburg, P A 17019 Respectfully submitted, Date: {,/;/~()(), ~a. II. ~ Tabetha A. Tanner, Esquire Supreme Court LD. No.: 91979 Attorney for Plaintiff TANNER LAW OFFICES, LLC 1300 Market Street, Suite 10 Lemoyne, P A 17043 (717) 731-8114 -- (") ~~: ....., C".-.::> = "" <- c:: ...cl;:.. o -n ~.,., rnp: rn r--'"' .....r... ,"'. ~ ~ I -.J -0 ~2 ;:') ,~~.~ l'T1 'J ~B .< N N f'V -".., ., Plaintiff S JUL 2 7 2.006~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2856 CIVIL TERM CIVIL ACTION - LAW , ., SUZANNE SUTCH, v. JAMES SUTCH, IN CUSTODY Defendant TEMPORARY ORDER OF COURT AND NOW, this I ~ l' day of I\u~~~ t , 2006, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Leaal Custody. The parties, Suzanne Sutch and James Sutch, shall have shared legal custody of the minor child, Jared Sutch, born November 2, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa. C. S. ~5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child 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 subject to Father's rights of partial custody, which shall be arranged as follows: A. Commencing July 21, 2006, on alternating weekends, from Friday atter school or work until Monday, when the child is returned to school or day care. B. Commencing July 26, 2006, on alternating Wednesdays from after school or work until Thursday morning. C. Commencing August 2, 2006, on alternating Wednesdays from after school or work until 9:15 p.m. (summer schedule) or 8:30 p.m. (school year schedule). D. The parties further contemplate that Father will have additional periods of custody which may fall on other than Wednesday evenings for purposes of mutually agreed upon sports activities or competitions. , " NO. 06-2856 CIVIL TERM The child will continue to participate in his current sports of baseball and soccer. Additional sports or circular activities will be subject to the mutual consent of the parties, which consent shall not be unreasonably withheld. 3. Vacation. Each parent shall be entitled to two non-consecutive weeks of vacation each year, Saturday to Saturday, to include the vacationing parent's custodial weekend. The parties shall provide each other with notice by April 1s 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, prior to departure, the vacationing parent shall provide a telephone number and location where they can be reached during the vacation. 4. Holidavs. The attached holiday schedule shall supercede the regular schedule. BY THE COURT: J. Oist: Tabeth A. Tanner, Esquire, 1300 Market Street, Suite 10, Lemoyne, PA 17043 Bradley A. Winnick, Esquire, 130W. Church Street, Dillsburg, PA 17019 pV /;:; ry t>~ \\:,.)':!~ -.,;,". :',:"'\..L "SA , ~ . Docket No. 06-2856 CIVIL TERM HOLIDAYS AND TIMES ODD EVEN SPECIAL DAYS YEARS YEARS Easter Day From 6pm the evening before the Mother Father holiday to 6pm the day of the holiday Memorial Day From 6pm the evening before the Father Mother holiday to 6pm the day of the holiday Independence Day From 6pm the evening before the Mother Father holiday to 6pm the day of the holiday Labor Day From 6pm the evening before the Father Mother holiday to 6pm the day of the holiday Thanksgiving From 6pm the evening before Mother Father Thanksgiving Day to 6pm on Friday following Thanksgiving Christmas 1st Half From 9am on 12/24 to 3pm on 12/25 Father Mother Christmas 2nd Half From 3pm on 12/25 to 3pm on 12/26 Mother Father New Year's Holiday From 6pm December 31 to 6 pm Mother Father January 1, with the alternating year defined by the year of December 31 Mother's Day From 6pm the evening before the Mother Mother holiday to 6pm the day of the holiday Father's Day From 6pm the evening before the Father Father holiday to 6pm the day of the holiday :279836 ,. , , ., Plaintiff JUL 2 7 2006 IN THE COURT OF COMMON PLEAS OF r CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2856 CIVil TERM CIVil ACTION - LAW IN CUSTODY SUZANNE SUTCH, v. JAMES SUTCH, 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 child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Jared Sutch November 2, 1998 Mother 2. Mother filed a Complaint for Custody on May 18, 2006, seeking primary physical custody of the child. A Custody Conciliation Conference was held on July 21, 2006. Present for the conference were: the Father, James Sutch, and his counsel, Bradley A. Winnick, Esquire; and the Mother, Suzanne Sutch, and her counsel, Tabetha A. Tanner, Esquire. 3. The parties reached an agreement in the form of an Order as attached. Me Issa Peel Greevy, Esq Ire Custody Conciliator 1/;2,IRMh Dat{ I I :279834