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Home My WebLink About95-05296 I I I 1 1 . :!j .. i i I I I i j I i i , j ! ; ! 1f :!!.... ::s ~S'~ tt ....~~~~ ~la, z~ !:! z...> en... . ~~!j;i ~G ~ > !;j .... fa ~ . Vl < lil ..:l Po. Z o .~ o U t.- O Eot D: ::l o U lil :t Eot Z .... < .... Z < > ..:l >< Vl Z Z lil Po. . >< Eot Z ::l o U Q Z < ..:l 0: lil III !i >< Q o Eot Vl ::l U ..:l < .... Eot 0: < Po. D: o t.- Eo< Z H < ..:l Po. :I: o U . o Z .... .... ..-1 +J C . ..-1 Z 10 lil..... ..:lPo. Eot .... lil N ~ 0: Q o o ~ . > ,7 \ ;'f1 'C' 1) ';) ~ +J C 10 'tJ C Q) .... . Q) ZQ lil ..:l Eot .... lil N Z < Vl ::l Vl It)l\ ~ t;~ ~ ~~~ l>ZZ ... OZ Z c:~ . a:'" ... .Q ~ zgr::: !:! iC S:;) ~ _Ill s:: ...~ tit ~ C(~ ~ t (,~) '7T9{ 7TJ ~+jJ (, S5.PJsoc 1:;0 ;/ , r'T (\ ro .' V" , '\."1 '}J .}.I>"' WOODROW ZEITLBN, . IN TIlE COURT OF COMMON PLEAS . Plaintiff . OF CUMBERLAND COUNTY, PENNSYLVANIA . . j)f~ (? L t\~ " 1 L-t./t,,- . NO. 1Q v. . . . . SUSAN ZEITLEN, . CIVIL ACTION - LAW . Defendant . . ORDER OF COURT AND NOW, this ~ day of october, 1995, upon consideration of the attached complaint, it is hereby directed that th~ gartie~ and their respective counsel appear. before .c \"cU'..1 L ~.,r.5 1:.;.,. the conciliator, at oj . 6't\.. .51. ",I fA , on the \' [.., t-h'u day of (\/W(-' r , 1995, at H., for a P~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. Either party may bring the child who is the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. BY THE COURT: ~: <<~J Custody Conciliator 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 TIlE OFFICE SET FORTH BELOW TO FIND OUR WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, FOURTH FLOOR CARLISLE, PA l70lJ (717) 240-6200 . --".~,,-~,-- -.-- .." <:no ~ - -:--- ~ : :c: G... ,. ~ .:z- "'J "'J >- <.> = /0./;) .95 Ctd . ~ 1f1~ ~ 4 ~ /0 -/;)?S 714 ,.,a:tb -z, dLf! /OA~'~ ~~~Jl. /'}~~p WOODROW ZEITLER, . IN TlIB COURT OF COMMON PLEAS . plaintiff . OF CUMBERLAND COUNTY, PENNSYLVANIA . . . v. . NO. . . . SUSAN ZEITLER, . CIVIL ACTION - LAW . Defendant . . COMPLAINT FOR PARTIAL CUSTODY 1. The Plaintiff is Woodrow zeitlen, residing at 1026-900 Box Shores Drive, Destin, Florida 3254l. 2. The Defendant is Susan zeit1en, residing at 148 Walnut Street, Lemoyne, Pennsylvania l7043 3. Plaintiff seeks partial custody of the following children: NIme Present Residence Age Asher Joel Zeitlen Ivy Brinn Zeitlen l48 Walnut Street, Lemoyne, Pa. l48 Walnut Street, Lemoyne, Pa, 16 13 4. The children were not born out of wedlock. 5. The children are presently in the custody of Susan Zeit1en who resides at l48 Walnut street, Lemoyne, Pat 6. During the past five years, the children have resided with Susan Zeitlen at 148 Walnut Street, Lemoyne, Pat 7. The mother of the children is Susan Zeit1en, currently residing at 148 Walnut street. She is divorced. 8. The father of the children is Woodrow Zeit1en, currently residing at Box 1026-900 Gulf Shores Drive, Destin, Florida. lie is divorced. 9. The relationship of plaintiff to the children is that of father. The plaintiff currently resides alone. 10. The relationship of defendant to the children is that of mother. The defendant currently resides with the following perso~s. HlllIe Relationship Asher Joel zeitlen Ivy Brinn zeitlen son daughter 11. Plaintiff has participated as a party or witness, or in another capacity, in other Ii tigation concerning the custody of the children in this or another court. The court, term and number, and its relationship to this action is: Dauphin County Court of Common Pleas, No. 3685 S 1983. The last action taken in said litigation was on August l2, 1992 in which the late Honorable Judge Schaffner Ordered that Asher and Ivy Zeitlen would not be ordered to visit their father in prison. This action bears no relationship to the instant petition as Plaintiff is no longer incarcerated and the venue in the prior case is not proper as the children have resided in Cumberland County for more than ten years. 12. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 13. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 14. The best interest and permanent welfare of the children will be served by granting the relief requested because the children have been unable to establish a meaningful relationship with plaintiff due to his legal problems and have been deprived of parental love and affection from their father. 15. 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, Plaintiff requests the court to grant partial custody of the children under the terms and conditions which it deems to be appropriate including but not limited to visits at Plaintiff's residence in Florida for which he shall bear all travel expenses. Respectfully SUbmitted, DATE: ~Jt3" 9'9 S re e J, Rosen, Esquire A torney for Plaintiff l101 Front Street Harrisburg, pa 17102 ID I 10625 (717) 234-4583