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Home My WebLink About06-5578 A Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA AMBER CONNORS vs. Defendant CIVIL ACTION - CUSTODY NO. 01.- SS'l1' e/~.:L'-rk",\ BRIAN ROTT NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the cla~s set forth against you. You are warned that if you fail to do so the case may proceed without you and the court may enter a decree of divorce or annulment against you. A judgment may also be entered against you for any other cla~ or relief requested in these papers by the plaintiff. You may lose money or property or other rights ~portant to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the first floor in the Cumberland County Courthouse, Carlisle Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 .. . AMBER CONNORS Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. Defendant CIVIL ACTION - CUSTODY NO. Ot- - 6~rP C.,(.;J.../~ BRIAN ROTT COMPLAINT IN CUSTODY Plaintiff, Amber Connors, by and through her attorney Gail Guida Souders, respectfully avers the following counts through Civil Procedure Rule 1915.15 (a): 1. The Plaintiff is Amber Connors, (hereinafter "Mother") residing at 811 Valley Street, Enola, PA 17025. 2. The Defendant is Brian Rott (hereinafter "Father") residing at 102 Lincoln Street, Enola, PA 17025. 3. Plaintiff seeks primary physical and legal custody of the following child: Name Present Residence Catelyn Shumaker 811 Valley Street Enola, PA 17025 D.O.B. June 24, 2003 The child was born out of wedlock. 4. The child is presently in the custody of the Father who is residing at unknown address. 5. During the past five years, the child has resided with the following persons and at the following addresses: Names Brian Rott Residences unknown address Dates 9/18/06 to present Ambers Connors 413 Pitt Street David Connors Jr. Enola, PA 17025 Alyssa Connors 1/04-9/06 . Austin Connors Natalie Connors Catelyn Shumaker Amber Connors Laura Chest John Chest Sean Chest 19 Cassatt Street Enola, PA 17025 June 24, 2003- January 2004 6. The mother of the child is Amber Connors, residing at 811 Valley Street, Enola, PA 17025. She is married. 7. The father of the child is Brian Rott, residing at 102 Lincoln Street, Enola, PA 17025. He is unmarried. 8. The relationship of the Plaintiff to the child is that of mother-child. The child was currently living with the mother until September 18, 2006. 9. The relationship of the Defendant to the child is that of father-child. The child is currently with the Father. 10. The best interest and pe~anent welfare of the child will be served by granting the relief requested because: a. Child has been with Mother since birth. b. Father has only been part of child's life for the past year and half. c. Mother has always provided for child financially. d. Father took child from Mother and has not pe~itted Mother to see child. e. Mother has always facilitated a relationship between child and Father unlike Father. f. Child has a half-sister that she always being with in the same home. . , .., g. Mother will be better able to continue to provide a nurturing and stable environment for child. 11. Each parent whose parental rights to the child have not been te~inated, and the person who has physical custody of the child, have been named as parties to this action. WHEREFORE, the Plaintiff requests the court to grant her pr~ry physical custody and legal custody of her child. A Gail Guida Souders Attorney for the Plaintiff Guida Law Offices 111 Locust Street Harrisburg, PA 17101 (717) 236-6440 Supreme Court ID# 68740 - . .. . I, Amanda Connors, verify that the statements made in this Complaint in Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. ~ 4904, relating to unsworn falsification to authorities. ~ mtfuA (1C5YVYU5W AMBER CONNORS ~~--- ATT RNEY FOR PLAINTIFF DATE: g- 22-cip ";;::) (J ~ it- 7' ::::: 1\- ).J - 8 0 ~ ~ ~ -- c: C-~ ~ ~ cr- ~ ~:;;-. ..-\ ~ - ~~t-r- (ft :J:..,., r1~~- ~:--~ r..... . . 11'\ po -:1" -oJ .t:..........,.' . -.,m 2' N ;py (/' (,}'I -J::. ~ ~:~.~, '::;)\Q ~ -r: -~.; ~~~~: -0 ~:; CO::. :i: W (SfD ..-I 7:'. "'1>- ~ -...I t'-) ':0 " :..< -- 0' AMBER CONNORS PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-5578 CIVIL ACTION LAW BRIAN ROTT DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, October 02, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. at 39 West Main Street, Mechanicsburg, fA 17055 on Tuesday, October 31,2006 , the conciliator, at 9:00 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 the conciliator 48 hours prior to scheduled hearin2. FOR THE COURT. By: Isl Dawn S. Sunday, Esq. Custody Conciliator p 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 ~ jp % ~ ~ '10-[:0/ _~ ~ ~ ~ 10-['-0/ ~$r Jz ~~'T9 '1oco/ SO :S !,Id 8- 1:)0903l I u\Jlr" ,,'.: \, (-'I' I :JH1 :10 ^Ov. V:\\),I_J)UG ....u 3JH:KrG3lI:l NOV 0 J 2006 ",'i C) AMBER CONNORS Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 06-5578 CNIL ACTION LAW BRIAN ROTT Defendant IN CUSTODY ORDER OF COURT AND NOW, this 3fG day of ~ 0\& t.V\\ 'a V( , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Amber Connors, and the Father, Brian Rott, shall have shared legal custody of Catelyn Shumaker, born June 24,2003. 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 her health, education and religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 2. Pending the follow-up custody conciliation conference and further Order of Court or agreement of the parties, the parties shall share having physical custody of the Child on an alternating weekly basis, with the exchange to take place every week on Sunday at noon. The non-custodial parent shall have custody of the Child every week from Wednesday at 9:00 a.m. through Thursday at 9:00 a.m. The alternating weekly schedule shall begin with the Father having custody on Sunday, November 5,2006. 3. The parties shall share having custody of the Child on holidays as arranged by agreement. 4. Each parent shall be entitled to have custody of the Child for vacation each year for a reasonable period or periods upon providing at least 30 days advance notice to the other parent. 5. The parties and their counselor a party pro se shall attend a follow-up custody conciliation conference in the office ofthe conciliator, Dawn S. Sunday, on January 4,2007 for the purpose of reviewing the custody schedule. " 6. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions ofthis Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, ,~~~ .' "J~"\' C,,~,,':1,,\ \j'rN\ i \ ,/\.~:r' '\.1 .....,.;...... , ,_, ,_,..-'~\r"\f"\ l \' 'r r ,,", ' ..,.;__--IV,\I \.oJ I"J..\';' "--' ' ' " ' \ S :0 \\~ r,- ~G" ~~~t ,',,,.1'\ "'I 'C. , \:;'c\d ?,'r\l. ~O {\.Q" _\-,:...~.; \;;..j'c.q\..\ ::>) \:j _:. \,) \". ~ ,.:1 1- AMBER CONNORS Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 06-5578 CIVIL ACTION LAW BRIAN ROTT Defendant IN CUSTODY Prior Judge: None 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 t he subject of this litigation is as follows: CURRENTLY IN CUSTODY OF NAME DATE OF BIRTH Catelyn Shumaker June 24, 2003 Mother 2. A Custody Conciliation Conference was held on October 31, 2006, with the following individuals in attendance: The Mother, Amber Connors, with her counsel, Gail Guida Souders, and the Father, Brian Rott, who was not represented by counsel in this matter. 3. The parties agreed to entry of an Order in the form as attached. lJo~ I ~~ Date ( Da~ Custody Conciliator Plaintiff JAN 18 2D07 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA AMBER CONNORS vs. 06-5578 CNIL ACTION LAW BRIAN ROTT Defendant IN CUSTODY ORDER AND NOW, this 2ND day of January, 2007, the conciliator, being advised that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction. The custody conciliation conference scheduled for January 4, 2007 is cancelled. FOR THE COURT, ()~/ Dawn S. Sunday, Esquire Y Custody Conciliator 'ill\j\fl\lASNN3d I I Nn,...r, "1' '"P'i '''''-''Mr\'' I\J.. it..) ,,,,' ~"'!' ,:'~~:-:::~j~1f tv 9 I :6 WI L I Nvr LOOl Ab"\flOI~OH.LOHd 3Hl :K) 381.:1~n{J31I:l