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LESLIE M. SITES,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-1I/:J.. CIVIL TERM
TIMOTHY L. DITZLER, SR.,
Defendant
CUSTODY ORDER
AND NOW, this -1:JL day of --l<.Vt .,}" L
, 1995, upon
consideration of the parties' Consent Agreement, the following
Order is entered with regard to custody of the parties' child
Timothy L. Ditzler, Jr., born September 30, 1993:
1. The plaintiff, hereinafter referred to as the mother,
and the defendant, hereinafter referred to as the father, will
share legal custody of the child.
2. The mother will have primary physical custody of the
child.
3. The father will have partial physical custody of the
child every other weekend from Friday at 6:00 p.m. until Sunday
at 6:00 p.m..
4. The father will have custody of the child from 12:00
p.m. on Christmas Eve until 12:00 p.m. on Christmas Day and the
mother will have custody of the child from 12:00 p.m on Christmas
Day until 12:00 p.m. December 26 each year.
~. The parties will alternate custody of the child on
Easter and Thanksgiving each year, with the father having custody
of the child on Easter in 1995.
6. The mother will have the child on Mother's Day, and the
father will have the child on Father's Day each year.
,.
7. The father will have custody of the child on the
child's birthday in 1995 and every other year thereafter.
8. The mother will have the child on her birthday,
November 1, and the father will have the child on his birthday,
May 8 each year.
9. The father will have the right to partial custody of the
child for two non-consecutive weeks each summer. The father will
notify the mother by June 1 of each year when his periods of
summer custody will take place.
10. The mother and father, by mutual agreement, may vary
from this schedule at any time.
11. The mother and father will notify each other of all
medical care the child receives while in that parent's care.
Each parent will notify the other immediately of medical
emergencies which arise while the child is in that parent's care.
12. Neither party shall do anything which may estrange the
child from the other parent, or injure the opinion of the child
as to the other parent or which may hamper the free and natural
development of the child's love or respect for the other parent.
By the Court,
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v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95- '" ~ CIVIL TERM
LESLIE M. SITES,
Plaintiff
.
.
TIMOTHY L. DITZLER, SR.,
Def..mdant
CONSENT AGREEMENT
This Agreement is entered on this ~f
1995, by the plaintiff, Leslie M. Sites, and
day of hhrwy
the defendant,
Timothy L. Ditzler, Sr. The plaintiff is represented by Joan
Carey of Legal Services, Inc.; the defendant is unrepresented but
is aware of his right to have an attorney.
The plaintiff, hereinafter referred to as the mother, and
the defendant, hereinafter referred to as the father, agree that
the following be entered as an order of court regarding custody
of their child Timothy L. Ditzler, Jr., born september 30, 1993:
1. The mother and the father will share legal custody of
the child.
"
2. The mother will have primary physical custody of the
child.
3. The father will have partial physical custody of the
child every other weekend from Friday at 6:00 p.m. until sunday
at 6:00 p.m..
4. The father will have custody of the child from 12:00
p.m. on Christmas Eve until 12:00 p.m. on Christmas Day and the
mother will have custody of the child from 12:00 p.m on Christmas
~
Day until 12:00 p.m. December 26 each year.
5. The parties will alternate custody of the child on
,
Easter and Thanksgiving each year, with the father having the
child on Easter in 1995.
6. The mother will have the child on Mother's Day, and the
father will have the child on Father's Day each year.
7. The father will have custody of the child on the
child's birthday in 1995 and every other year thereafter.
B. The mother will have the child on her birthday,
November 1, and the father will have the child on his birthday,
May 8 each year.
9. The father will have the right to partial custody of the
child for two non-consecutive weeks each summer. The father will
notify the mother by June 1 of each year when his periods of
summer custody will take place.
10. The mother and father, by mutual agreement, may vary
from this schedule at any time.
11. The mother and father will notify each other of all
medical care the child receives while in that parent's care.
Each parent will notifY the other immediately of medical
emergencies which arise while the child is in that parent's care.
12. Neither party shall do anything which may estrange the
child from the other parent, or injure the opinion of the child
as to the other parent or which may hamper the free and natural
development of the child's love or respect for the other parent.
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WHEREFORE, the parties request that an Order of Court be
entered to reflect the above terms.
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sl e M. sites, Plaintiff
Z; /
B1l. Carey
Attorney for Plaint ff
LEGAL SERVICES, INC.
a Irvine Row
Carlisle, pa 17013
LESLIE M. SITES, IN THE COURT OF COMMON PLEAS OF
Plaintiff .
.
. CUMBERLAND COUNTY, PENNSYLVANIA
.
v. .
.
. NO. 95-1/I~ CIVIL TERM
.
TIMOTHY L. DITZLER, SR.,
Defendant .
.
COMPLAINT FOR CUSTODY
1. The plaintiff is Leslie M. s~tes, residing at 1548 West
Penn Street, carlisle, Cumberland County, Pennsylvania 17013.
2. The defendant is Timothy L. Ditzler, Sr., residing at
1207 pine Road, Carlisle, Cumberland county, Pennsylvania 17013.
3. The plaintiff seeks custody of the following child:
Name
Timothy L. Ditzler, Jr.
Present Residence
154B West Penn Street
Carlisle, PA 17013
Age
1
The child was born out of wedlock.
The child is presently in the custody of Leslie M. sites,
who resides at 1548 West Penn street, Carlisle, pennsylvania.
During the child's lifetime, he has resided with the
foll~wing persons and at the following addresses:
Name
Plaintiff, Defendant,
Leroy sites, Keitha
Hiett, Sarah stewart and
Laurie sites
Plaintiff, Defendant,
Jim Ditzler, Monica
Ditzler, and Jimmy
Ditzler
Plaintiff and Defendant
Addreso
5945 Blue
Enola, PA
Mountain Trail
17025
Date
Birth - 2/94
1207 pine Road
Carlisle, PA 17013
2/94 - 9/94
Plaintiff
154B West Penn Street
carlisle, PA 17013
154B West Penn Street
Carlisle, PA 17013
9/94 - 1/95
1/95 - present
The mother of the child is Leslie M. Sites, currently
residing at 154B West Penn street, carlisle, Pennsylvania.
She is single.
The father of the child is Timothy L. Ditzler, Sr.,
currently residing at 1207 Pine Road, Carlisle, Pennsylvania.
He is single.
4. The relationship of plaintiff to the child is that of
mother.
The plaintiff currently is residing with the child.
5. The relationship of defendant to the child is that of
father.
The defendant currently resides with the following persons:
Name
Jim Ditzler
Monica Ditzler
Jimmy Ditzler
Relationship
Father
Mother
Brother
6. The 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.
7. The plaintiff has no information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
8. The plaintiff does not know of a person not a party to
the proceedings who has physical custody of the child or claims
to have custody or visitation rights with respect to the child.
9. The best interest and permanent welfare of the child
will be served by granting the relief requested because the
mother has been the primary caretaker of the child and can
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providE for his needs.
10. 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, the plaintiff requests this Court to grant
primary physical custody of the child to the plaintiff with
partial custody in the defendant every other weekend from Friday
at 6:00 p.m. until Sunday at 6:00 p.m., and any other times that
may be mutually agreed upon by the parties.
Respectfully submitted,
J, /0
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( oan Carey r-
Attorney for Plaintiff
LEGAL SERVICES, INC.
a Irvine Row
CarliSle, PA 17013
(717) 243-9400
The above-named Plaintiff, Leslie M. Sites, verifies that
the statements made in the above Complaint are true and correct.
Plaintiff understands that false statements herein are made
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subject to the penalties of 18 Pa. C.S. 54904, relating to
unsworn falsification to authorities.
Date:
;;.. /'/- y.s ...
~J~t 0 ;71. Sf -X/h
Leslie M. Sites, Plaintiff
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LESLIE M. SITES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
v.
CUMBERLAND COUNTY. PENNSYLVANIA
NO. 95- III;)" CIVIL TERM
TIMOTHY L. DITZLER,
Defendant
PRAECIPE TO PROC~EP IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow. Leslie M. Sites, Plaintff, to proceed in forma
pauperis.
I, Joan Carey, attorney for the party proceeding in forma
pauperis, certify that I believe the party is unable to pay the
costs and that I am providing free legal services to the party.
The party's affidavit showing inability to pay the costs of
litigation is attached hereto.
oan Carey
Attorney for Plain iff
LEGAL SERVICES, INC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
LESLIE M. SITES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-
CIVIL TERM
TIMOTHY L. DITZLER,
Defendant
AFFIDAVIT IN SUPPORT OF PETITIO~
EOR LEAVE TO PROC~~1L-IN FORMA PAU~~
1. I am the plaintiff in the above matter and because of my
financial condition am unable to pay the fees and costs of
prosecuting, defending. or appealing the action or proceeding.
2. I am unable to obtain funds from anyone, including my
family and associates, to pay the costs of litigation.
3. I represent that the information below relating to my
ability to pay the fees and costs is true and correct.
(a) Name:
Lesl ie M. Si tes
Address:
154B Penn Street
Car 1 i s 1 e ,-E...A..-l 7013
Social Security Number: _ 168-56-4044
(b) If you are presently employed, state
Employer: None
Address: __-HLA
Salary or wages per month: _N/A
Type of work: ___-..l!LA____
If you are presently unemployed, state
Date of last employment: _...J_aDJHtt:Y-1jI95
Salary or wages per month: _$..5..L9.....QQ_
Type of work: _Ca~JU:
(c) Other income within the past twelve months
Business or profession: ~xa~~1Lmo.
Other self-employment: ~LA
Interest: ~LA
Dividends: N/A
Pension and annuities: __~A
Social Security benefits: N/A
Support payments: N/A
Disability payments: ~jA
Unemployment compensation and
supplemental benefits: ~jA
Workman I S compensat ion: N/ A
Public Assistance: __~~JL6.0Qjm9.
Other: ~LA
(d) Other contributions to household support
(Wife)(Husband) Name: N/A
If .,your (husband) (wife) is employed, state
Employer: ~LA
Salary or wages per month: ~A
Type of work: ~/A
Contributions from children: -tlLA
(e) Property owned
Cash: __Nonlt__________,__
Check; n9 Account : "fI!()ll..e.
Savings Account :.jJor}!l....__.____________
Certificates of Deposit: ~Sllie
Real Estate (including home): NOQe
Motor vehicle: Make None
Cost
Stocks; bonds: _None
Other: None
(f) Debts and obligations
Mort gage: .ligne
Rent: None
Loans: -.N911,e___..
Monthly Expenses: Electric~~20.0Q~~$45.00.
Groceries -$50.00. Teleph9~~_~.OO. pable - ~JL.
--!.ash - $9.l-QQ........QJothinQ---=J1L.....9_Q.I_ci91lrettes - $80.00
Diapers - $32.00
(g) Persons dependent upon you for support
(Wife) (Husband) Name: None
Chi ldren, if any:
Name: Tim9thY__I...._Dj,L~r. Jr. Age: 1 Yr.
4. I understand that I have a continuing obligation to
inform the court of improvement in my financial circumstances
which would permit me to pay the costs incurred herein.
5. I verify that the statements made in this affidavit are
true and correct. I understand that false statements herein are
Year
Amount owed
'. . . .../ .. - ..:..."",-;c .., r ~ j) t :' , " ',' ...., . "
made subject to the penalties of 18 Pa. C.S. 4904. relating to
unsworn falsification to authorities.
Date: .3 -{- IJ{
_;J . -
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Leslie M.
.jr'f:-,
Sites. Plaintff
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APR 2 8 2004 ~.
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PlaintifT
: IN THE COURT or COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
LESLIE M. SITES,
V. : NO. 95 - ] 112 Civil Tcrm
TIMOTHY L. DITZLER, SR. : IN CUSTODY
Dcfendant
ORDER
AND NOW, this 36 ,{ ~ day of ~ r I' '; { ,2004, having rcvicwcd thc auachcd
agrccmcnt betwecn the parties doted April 27, 2004. it is hereby ORDERED and DECREED that
the agrecment shall be cntercd os on ORDER of Court.
cc:
Janc Adams, Esquire, for Mother
Timothy L. Ditzlcr, luthcr
",."pLW ')1 ....:..u {'I. () 'I
RLED-OmCE
OF THe PROTI,lmiOTNiY
2001dl.~Y -3 PI'; 3: 07
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LESLIE M. SITES,
PlaintilT
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 95 - 1112 Civil Term
TiMOTHY L. DITZLER, SR.
. Dcfendunt
: IN CUSTODY
STIPULATION AND AGREEMENT
This Stipulation and Custody Agrccment is made thisj)7~y of (:)(12-; L ,2004,
by and between LESLIE M. URY, fonnerly known as LESLIE M. SITES, (Hercinal\er referred
to us "Mother"), of Mcchanicsburg, Pcnnsylvania, und TIMOTHY L. DITZLER, SR.,
(Hercinuncr referrcd to as "Father"), of Carli sic, Pennsylvuniu;
WHEREAS, Mother and Father are the natural parents of one minor child, numely,
Timothy L. Ditzlcr, Jr., dute of birth, September 30. 1998.
WHEREAS, Mother und Father have reached an ugrcement relative to the futurc care,
custody, and visitation of their child, the tcnns of which agrecment both partics dcsire to set forth
in the prcsent Stipulation and Custody Agrcement, and; the Plaintiffis representcd by Jane
Adams, Esquirc, und Defendant is unrcprcscnted but is aware of his right to his own allomcy;
WHEREAS, Mother and Father desire the provisions of the present Stipulation and
Custody Agreement be approved by thc Honorable Court of Common Pleas of Cumberland
County and entercd as u Court Ordcr, with the sume lorce und ellcct us though suid Order had
bcen cntered after Petition, Notice and Heuring.
NOW THEREFORE, the parties, intending to be legnlly bound. and in consideration of
.
the mutual promises and ngreements contnined herein, hereby ngree liS follows:
1. Lcenl Custody. Mother shull huve solc legul custody of the child. Legul custody
mcuns thc purcnt hus the right to control und mnke decisions of irnportunce in the life of their
child, including edueutionul, medicul, und religious dccisions.
As soon us prnctieublc uner thc rcceipt by mother, copies of the child's school schcdules,
report cards, and similur itcms shull be provided to the litther. Mother shull notify fitther ofuny
mcdical, dental, opticul und other uppointments of 1\ child with heulthcnre providers, sufficiently
in advance thercof.
2. Physical Custody. I'rimary Physical Custody of the child, us thuttenn is defined in
thc custody uct, shull.bc with Mother. Mother hus notilicd fnther thut shc intcnds to move to
Wyoming with the child on approximutely May 1,2004. Mother's husbund, Michael Ury, hus
extended family in Wyoming. Futher is in agreemcnt with this rclocntion und consents to Mother
and child moving to Wyoming.
3. Partlnl Custody. PI\I'~ial physical custody is the right to tuke possession ofa child
awuy from the custodial purent for u certuin pcriod of time. Fathcr shull have liberal pcriods of
partiul physicul custody liS thc purtics mutunlly IIgree. Futher's periods of custody shull not
interfere with the child's schooling.
4. Onl!olnl! l~clutionshllJ. Neither purty shull ullempt to undcnnine the mutuullovc und
ulTcction that the child muy huve lor the other purent und neither purent shull. in the present of
c
the child muke uny dispurnging or negutive remurks concerning the other purent. Eueh purty shull
confer with the other on ulll11ullers ofil11pOrlllllCe reluting to the child's heulth, l11uil1lenunee, ul1d
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education with a view toward obtaining and following a harmonious policy in the child's
education and socinladjustl11cnt. Each party agrces to keep the other infol111ed of his or her
rcsidcncc and telephone number to fucilitate cOl11municlltion concerning the wclfilre of the child
und visitation period. Each purty ugrees to supply the nllme, IIddress. und tclcphone numbcrs of
any pcrson in whose cure the child will be in for u period in excess offbrty.eight (48) hours,und
for cuch person or cntity which mllY provide duycure Ibr the child.
.
5. Illness of the Child. Emcrgcncy dccisions regarding the child shull be madc by the
parent then having custody. However, in thc cvent of any emergency or serious illness of the
child at any timc, uny party then having custody of the child shull communicutc with thc other
party by telcphonc or uny othcr means practicable, informing the othcr party of the nature ofthc
illness or cmergency, so the other parent clln bccomc involved in the decision making proccss as
soon as possible. The tcrm "serious iIIncss" as used herein shull mean any disubility which
confines thc child to bed for a period in exccss of sevcnty.two (72) hours and which places thc
child undcr the direction of aliccnsed physiciun. During such illness, each party shull have thc
right to visit the child as often liS he or she desires, consistent with the medical care of the child.
6. B1ndin!! ~ffect und Modification of Order. This Agreement and all of its tenns
and conditions shall extend to und be binding upon the purties hereto und their respective heirs,
personal representatives, nnd ussigns. Thc partics ure free to modify the tel111S of this Agreement
but in order to do so both purties must be in complete ugreementto IIny new tcrms. TllIItmellns
both parties must consent on whutthe new temlS of the custody urrungement or visitution
sehedule shall be.
7. Governln!! LillY. This Agreement shall be gOl'erncd und controlled by the
laws of Pennsylvania.
8. Enforcement. The parties agree that this Agreement may be odopted os on Order of
Court without the necessity 01'0 Court hearing.
9. Entire Al!reement. This Agreement contuins the entire understunding between the
parties concerning the subjeetmuller hereol: und no representutions. inducements. promises or
ogreemcnts, omlor otherwise, not embodied herein shall be of ony force or elreet. This
Agreement supersedes any and all prior agreements, wrillen or oml, between the parties hereto
relating to the subjeci mailer ofthis Agreement.
IN WITNESS WHEREOF, the parties huve hereto duly executed the present Stipulation
and Custody Agreement the day and year first above written.
W;!:~
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LESLIE M. URY, Mother
Wilne s
c
COMMONWEALTII OF PENNSYLVANIA )
):ss
COUNTY OF CUMBEIlLAND )
On Ihis, Ih:2;l t~~y of )..)P~ i L ,2004, befoN me,lhe undersigned officer, personally
appeared LESLIE M. UIlY, known 10 me, (or salislaelorily proven) 10 be Ihe person whose name Is subscribed 10
the wilhin instrument, and acknowledged Ihal he/she executed Ihe slime lor Ihe purposes therein eonlained.
IN WITNESS WIIEREOF, I heree hal~~lInd offici~ea
lory Public
My eomlnlssion expires:
SEAL
-;- '2'~ d" .k ~" _ CC}:b
TIMOTHy ITZLER, SR., Father ... ness
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NOTARIAL SfJL
~elUDu4S, NolDly Puttc
Carthlo Boro, CurnllMril ~
I/.y Ccmmits!oll Elpirm Sept O. 2004
COMMONWEAL TII OF PENNSYL VANIA )
):ss
COUNTY OF CUMllER~ND . )
On this,the'2J day of I)O{2.1 L ,2004, before me, the undersigned officer, personally
appeared T1MOTIIY I.. DITZLER, SI( known to me, (or salisfaetorily proven) to be the person whose name is
subscribed to the within instrument, and acknowledged that hclshe executed the same for the purposes therein
eomalned.
IN WITNESS WI/EIlEDF,1 her'
y commission expires:
SEAL
NO~ SE.IL
JANE E. ADA/AS, Nolaly PutIl
Cariblo 8oro, CutnbetIri Clu1lw
I.Cy CommlSIlori ElIjllret Sept. o. zoo.
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