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HomeMy WebLinkAbout95-01559 : , , '. BUFFIE L. GEARIIART, Plaintilr : IN TilE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA VS, ; NO, q (, 1\'\"', Cu'i.J' : CIVIL ACTION - LAW - l.iv~ " '1 I. ., MICHAEL R, RIliER, Defendant : IN CUSTODY COMPLAINT FOR CUSTODY I, The Plaintilr, Butlie L. Gearhart, is an adult individual who currently resides at 400 South York Street, Apartment B. Meehanicsburg, Cumberland County, Pennsylvania, 17055, 2, The Defendant. Michael R. Riller, is an adult individual who currently resides at 45B Meadowbrook Court. New Cumberland, Cumberland County. Pennsylvania. 17070, 3, Plaintiff seeks custody oflhe following child: Name Danielle D, Riller Present Residence 400 S, York Street, Apt. B, Mechanicsburg, PA Age 2 years The child was born out of wedlock, The child is presently in the custody of the Plaintilr, Butlie L, Gearhart. who resides at 400 South York Street, Apartment B, Mechaniesburg, Pennsylvania, During the past five years the child has lived with the lollowing persons and at the following addresses: PlaintiITfMother & Defendant/Father 8B Richland Lane 10/18/93-2/94 Camp lIill. PA Plaintitli'Mother & Defendant/Fnther 45B Meudowhrook Court 2/94-9/94 New Cumberland, PA Pluintilr/Mother. Nate Genrhurt & Jason Unpleby 400 S, York Street, Apt. B Meehllniesburg, PA 9/94-Present '. The Mother of the child is Bullie L. Gearhart, currently residing at 400 South York Street, Apartment B. Mechanicsburg, Pennsylvania, She is single, The Father of the child is Michael R. Ritter. currently residing at 458 Meadowbrook Court, New Cumberland, Pennsylvania. He is single, 4, The relationship ofPlaintilTto the child is that of Mother, The Plaintitl' currently resides with the child, the Plaintitl's older brother and a friend, 5, The relationship of the Defendant to the child is that of Father, It is unknown whether the Defendant resides with anyone or alone, Plaintiff has no information ofa custody proceeding conceming the child pending in a court of this Commonwealth, The Plaintiff docs not know of a person not a party to the proceedings who has physical custody oCthe child or claims to have custody or visitation rights with respect to the child, 7, The best interests and permanent wellitre of the child requires that primary physical and legal custody of the child be given to the PlaintifT/Mother with p.:riods of reasonable supervised visitation be given to the DefendantJFather as detennined by the Court, WHEREFORE, Plaintin: Bullie L, Gearhart, respectfully requests that she be awarded primary legal and physical custody of the subject minor child as provided herein, . '. Respectfully submilled. .~ I. / Dale:~"; :(i ,\ /~-fT{. I 13y:-L.~~)~ _ Keith 13, DeArmond, Esquire ^llomey for I'laintilT I.D, 1/ 58878 2800 Market Street Camp Hill, l'^ 17011 (717) 730-9394 I '. VI~IUFI(',\TION , !' 1: ! I, Ihe undersigncd, do hereby verily Ihnt the slnlel11enls I11nde in Ihe foregoing instnlll1cnl arc Irlle nnd correct to thc best of my knowledge, information and bclie[ (understand that statcmcnts hcrcin arc mndc subjeclto the Jlenalties of 18 I'n. C. S, Scetion4904, rclating to unsworn Iillsilicntion to llllthnrities. ~_.~Q,J'lOJLL Dalc: ~ b .:) 'T I I CfC1 Ll ,. ..\ lJ'" I"l -0 cr ~ C1 ~ .~~.~ ,. :r .. ~ ~ In en " = -~ ;.;' N o " ~ , . <:D r- r.~ ... ., ::1:~ ..; " I also wish to receive tho following .ervlces (for en extra fo.l: " 0 Addr.....'. Addr... j\ ~\ Ill: i' ~: a:[ 1\ a:' III 1; ai 7. Ooto oAPR.l1 1995 i! >' 8, Addro....'. AddronlOnly II r.quo.,od o!ll .nd f.. III p.ldl ;a' r:: l'ti E DER: , :a . complet. itlm. , .ndlor 2 tOf edditlonll .'Nle... 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PENALlY FOR PRIVATE USE TO AVOJD PAYMENT OF POSTAGE, S300 I ) I I I i I I I I I I I I I I I , " I Print your nama, addrass and ZIP Code hare · l\ · vet1r MOl) J i :beIlRI1IOI1J.. ~gCO#~9f. e./t711 (J )/IU/ .PIt /1011 . . I ~ ., ,- , r'o , Lr1 <::rl' :;- ~ ::.01: ,..., "" cO '" >- -. :::.:: :,f"" ~~ ~~~~ .... ~ ~ fi' :I.s .. ~ ~I~I .... ~~ ~:. r: ~ ;. I'" '... _ 1::0. .- '" E::: '::." "hU I~ - 5i 'Jj",~ ~ ~:.; , J: ._ . . ~B rJ ' I .:l l" OJ g>< . "1 t '" . :- ... 'e'....:: ~~ " ~ ~ t 0 Ii! .f: -E ~ .~ ~r~ :::: n ::= C"\-E . ;;l r.1"'i.,.,.!: . l>: ~ .... ~ ~ ~ ~ ~ ~ i'Ei ~ , . --------~~_. , " " ~ ~. ~ - " . BUFFIE L. GEARHART, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . vs. : NO. 95-1559 CIVIL TERM : CIVIL ACTION - LAW MICHAEL R. RITl'ER, Defendant CUSTODY ORDER OF CXXIRT c/' /" ;-; AND NOW, this ~ day of ;\I\<L~ , 1995, upon consideration of the attached custody Conciliation Report, it is hereby ordered and directed as follows: 1. The Mother, Buffie L. Gearhart, shall have legal custody and primary physical custody of Danielle D. Ritter, born October 18, 1993. 2. The Father, Michael R. Ritter, shall enjoy liberal periods of visitation with the Child to be scheduled by mutual agreement of the parties. The Father's periods of visitation shal1 be supervised either by the Mother or the Father's parents. 3. The Mother shall be responsible for transporting the Child to and from periods of supervised visitation with the Father. 4. In the event either party desires to modify this Order, that party may petition the Court to have the case again scheduled with the Custody Conciliator for a Conference. BY THE: COURT, cc: Michael R. Ritter Keith DeArmond, Esquire ,lch~~/ f-:. ~fis----J. (nt.) ~.-"''::ii. ~~ /.J.ofr:'>e, J. c.~ (Y'~ S/q!QS, ~,(j>, " ~ BUFFIE L. GEARHART, . IN THE COURT OF COMMON PLEAS OF . Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA : vs. CIVIL ACTION - LAW . . MICHAEL R. RITl'ER , . NO. 95-1559 CIVIL TERM . Defendant/Petitioner CUSTODY i ' CUSTODY COOCILIATIOO StJoIMJ\RY REPrnT IN Ac:x:au>ANCE hrm ctJ1BERLAND CXXNl'Y RULE OF CIVIL PROCEDURE 19l5.3-B, the undersigned custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY OF Danielle D. Ritter october 18, 1993 Mother/plaintiff 2. A Conciliation Conference was held on April 27, 1995, with the following individuals present: The Mother, Buffie L. Gearhart, with her counsel, Keith B. DeArmond, Esquire. The Mother's counsel presented a Return-Receipt Card indicating that the Father, Michael R. Ritter, had been notified of the Conciliation date and time. 3. The Child was born out of wedlock and the parties are not currently married to each other. The Child has continuously resided with the Mother since the Child's birth on october 18, 1993. The Father also lived with the Mother and Child from the date of the Child's birth until Septerrber 1994. 4. The Mother requested sole legal custody and primary physical custody of the Child. According to the Mother, the Father, who is on 5.5.1. due to his adult attention deficit disorder, is unable to maintain employment and has minimal caregiving and parental skills. The Mother stated that the Father has not demonstrated a sustained interest in the Child and only sees the Child when the Mother takes the Child to the Father's residence for visitation. The Mother has facilitated contact between the Father and the Child by taking the Child to see her Father every other day when possible and at least weekly. The Mother stated that she would be willing to continue with very liberal visitation with the Father as 10ng as the visitation is supervised by either the Mother or the Father's parents. Finally, the Mother stated that she would be responsible for transporting the child because the Father does not have a drivers license or a car. The Mother based her request for sole legal custody on her claim that the Father has not shown an interest in participating in decisions affecting the Child and the Father has refrained from becoming I I r aufficiently involved in the Child's life to be prepared to participate in thoae decisiona. 5. Based on the foregoing information provided by the Mother and the fact that the Father, despite notice, failed to attend the Conciliation Conference, the Conciliator recommends an Order in the form aa attached. (O~rtdi"1(J Dawn S. Sunday Custody Conciliator ,-,/;;) /er s- Date '