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Home My WebLink About06-5596 ROBERT E. OTT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Defendant : CIVIL ACTION - LAW : NO. tJ t. . S S 9<- : IN CUSTODY CIVIL TERM v. ANITA K. OTT, COMPLAINT FOR CUSTODY 1. Plaintiff is Robert E. Ott, an adult individual currently residing at 9 Meadow Ridge Drive, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant is Anita K. Ott, an adult individual currently residing at 265 Waynesboro Pike, Fairfield, Adams County, Pennsylvania. 3. The parties are the natural parents of one child, namely, Emily Elizabeth Ott, born February 9, 1998. The child was not born out of wedlock. 4. For the past five (5) years, or since the child's birth, the child has resided with the following persons at the following addresses for the following periods of time: NAME ADDRESS DATES Robert E. Ott Wesley E. Ott (brother) Anita K. Ott (on and oft) 9 Meadow Ridge Drive Shippensburg, P A February 2006 to present Robert E. Ott Wesley E. Ott (brother) Anita K. Ott 9 Meadow Ridge Drive Shippensburg, P A birth to February 2006 The natural mother of the child is Anita K. Ott who resides as aforesaid. She is married. The natural father of the child is Robert E. Ott who resides as aforesaid. He is married. 5. The relationship of the Plaintiff to the child is that of natural father. The Plaintiff currently resides with his son, Wesley E. Ott and the child at issue. 6. The relationship of the Defendant to the child is that of natural mother. Defendant currently resides with her paramour, James Lehman. 7. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the child. 8. Plaintiff has no information of any custody proceedings concerning the child pending in any Court of this Commonwealth. 9. It is in the best interest and permanent welfare of the child to grant the relief requested because: a) Plaintiff is the prImary custodian of the parties' child and can adequately provide for the child's day to day needs; b) Defendant has abandoned the family; c) Plaintiff can provide a stable household for the child. 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 child. WHEREFORE, Plaintiff requests your Honorable Court to schedule Custody Conciliation Conference followed by a hearing at which time he should be granted primary physical custody of the child. Respectfully submitted, '\1,(\ ^ ,",1'\ h '\l, \\ 1'\ I\'\. n f\ - d 11'\ I ~ 0 ^ Hannah Herman-Snyder, Esqui e Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 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: <1- GJve> lo t2bI- C ~A- ROBERT E. OTT, Plaintiff ~~ ;\J a~~ \>.il ~ Y -- --- Q..; ~ o <:::" -C) ~:.:~ rn!\\ ;~.'il'- ,Il-_,c"'- r-:> ~ o~ <.() \," -0 f'--' cY" C' ~ :1-n \\' f'" -cl \"'1"\ -JJO C),b ~....,": ......-r. -;:-;; ~;~')J ,i:'(<:I '~ ~.... <:.0 ',2:. ~, :;.!I-- is .' (..,) 0" ROBERT E. OTT PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 06-5596 CIVIL ACTION LAW ANITA K. OTT 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 Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, November 02, 2006 at 9:30 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 penn anent 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 lacqueline M. Vemey, Esq. ~ 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 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 -~~fr "':~ ~ <V,ro/ . #P.? ~ ~~ '10 ['-0/ ~-~ -fp f! ~ ~ -r'7j Vf'(]/ 80 :8 Hd 8- 130 saOl ." 'lr" '\' ,'", i -'LII .:In 1\, ;-4"-' , '."i ,,,",' "'!U jru. ..I \..,IV \,): J~,,"",. L,.~",.I....~ , :J::';!j::lO--G:iltl ROBERT E. OTT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LA W ANITA K. OTT, Defendant : NO. 06-5596 CIVIL TERM : IN CUSTODY PRAECIPE Please withdraw the Complaint for Custody previously filed m the above captioned case on September 26, 2006. DATE: ~ (j- .,) - G It J*~~ahH;rm~-S;Yd;r,- ~;!~ r\ Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 C) ~;: ., r--.:> c;;:> c::") 0"' C (:"')~ o --0 .-1 ::C" r~~~ "H"" <....-.' w ~! ,..' 1 . 'I _~~_ ~,...j ~ .... ,'~J- :."::~~' . '/';> "'J.J =< .~ f'':; NOV 0 2 2006 ROBERT E. OTT, Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2006-5596 CIVIL ACTION - LA W ANITA K. OTT, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 2nd day of November, 2006, being advised that the Plaintiffhas withdrawn the complaint, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, stody Conciliator v'!f\\0/\~lAS;-..!t 'f:Jd Ii' ,,-,'" ,- " ,'" '-""'-'~I(\'" ^ i'H ;:.,;:.' :,' ;:-! ~'L'\r I';J SO :6 H~ S- I\ON 900l