HomeMy WebLinkAbout95-06395
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ROLAND WILLIAMS, JR. I
plaintiff
IN THE COURT OF COMMON PLEAS OF
v.
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-6395 CIVIL TERM
CUSTODY
TARA L. RITTENHOUSE,
Defendant
PETITION FOR SPECIAL RELIEF. ANSWER. , COUNTERCLAIM
The Defendant, Tara Rittenhouse, by and through her
attorney, Joan carey of Legal services, Inc., represents the
following:
1. The plaintiff, Roland Williams, Jr., hereinafter
referred to as the father, resides at 3815 Trindle Road, camp
Hill, cumberland county, Pennsylvania.
2. The defendant, Tara L. Rittenhouse, hereinafter referred
to as the mother, resides at 2198A old Philadelphia pike,
Lancaster, Lancaster county, Pennsylvania.
3. The parties are the parents of Joshua Nathaniel Lee
Williams born December 18, 1993.
4. A complaint for custody and Petition for special Relief
was filed by the father in the above-captioned matter on November
9, 1995, and an IX parte order was entered granting the father
primary physical custody of the child.
5. A conciliation conference has been scheduled for
December 21, 1995, at 9100 a.m. before Michael Bangs.
6. By agreement of the partiee the mother had the child in
her care every other weekend and holidays since July 1995. The
child has been solely in the mother's car since September, 1995.
7. The mother has concerns about the father's ability to
care for the child for reasons including, but not limited to, the
following:
a. On approximatelY september 9, 1995, when the mother
came to pick up the child from the father's residence,
the father was intoxicated and the child was drinking
beer from the bottle which was on the floor. The
mother left with the child and took him to st. Joseph'S
hospital because she noticed that the child smelled of
alcohol, acted intoxicated, had scars on the backs of
his legs and back, was extremely dirty, had raw
genitals from sitting in a dirty diaper, and a large
lump on his forehead.
b. The mother feels that the father has a serious drug
and alcohol problem.
c. The child is HIV positive and needs regular monthly
checkups. The mother was told by Hershey Medical
Center that the father did not bring the child to his
appointments regularly.
d. The father failed to provide for the child's
developmental developing an age appropriate vocabulary
for the child and proper dental hygiene
e. The father did not provide adequate sleeping
conditions for the child and had no regular schedule
for him.
f. The child had scars on his legs and back from
being hit with a ruler. The mother noticed several
bruises and lumps on the child at times when she would
pick up the child.
8. The mother feels that the child would be harmed by
removing him from her care for reasons inclUding, but not limited
to, the following:
a. Since the child has lived with the mother, the
medical condition of the child who is HIV positive, has
stabilized and currently has improved.
b. The mother has established a stable environment for
the child which includes a regular schedule for the
child'S eating and sleeping.
c. The mother is at home to care for the child during
the day.
d. The mother and child are involved with the
Lancaster Aids Project to ensure that the child's
medical needs are met.
9. The father has not enforced this Court's order of
November 1995, which granted him custodY1 he has not picked up
the child nor had any contact with the child or the mother.
10. The father initiated the custody action after she had
filed for sUPport1 since the support issue was generally
continued, the father has not pursued custody.
WHEREFORE, the plaintiff requests that this court vacate the
Order of November 9, 1995, and enter a Temporary custody order
ROLAND WILLIAMS, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-6395 CIVIL TERM
v.
CUSTODY
TARA L. RITTENHOUSE,
Defendant
ANSWER , COUNTERCLAIM
The defendant, Tara L. Rittenhouse, hereinafter the mother,
by and through her attorney, Joan Carey of Legal Services, Inc.,
answers the Petition (or special and Emergency Relief filed by
the plaintiff, Roland williams, Jr., hereinafter the father I
1. Admitted.
2. Admitted in part. Denied in part. The mother does not
have information sufficient to respond as to the father's
averment. The mother specifically denies that she was keeping
her whereabouts from the father. Furthermore, the mother gave
the father her phone number prior to moving into her residence in
September 1995, and the father also knew the whereabouts of the
mother's relatives but never asked the mother or the mother's
relatives for the address. since at least mid-November 1995, the
~other has been receiving communication from the father's
attorney at her residence at 219BA Old Philadelphia pike,
Lancaster, Pennsylvania.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted in part. Denied in part. The first three
months of the child's life was spent with Betty Magaro, the
maternal great-grandmother. The child did live with the father
from approximately three months of age to eighteen months old.
The mother also saw the child every other weekend and on holidays
since July 1995.
7. Admitted.
8. Admitted in part. Denied in part. The mother is HIV
positive but does not have AIDS.
9. Admitted.
10. Admitted. It is further stated that the mother has
continued the child's medical care, inclUding regular medications
and appointments at Hershey Medical Center, and that the Child's
condition has improved while in the mother's care, inClUding
increased T-cell count and weight gain.
11. Admitted. It is further stated that the mother had
be.n having regular overnight periods of partial custody with the
child since approximately J"uly 1995. On September 9, 1995,
during one of the mother's scheduled weekends, when the mother
picked up the child she immediately took the child to the
emergency room Of St. Joseph's Hospital because of the oondition
in which she found the ohild.
12. Admitted. It is further stated that the mother SPoke
with the father shortly after September 9, 1995, and that the
father agreed that she not return the child. When the mother
planned to mOVe to a new residence, she informed the father of
her phone number. The father has made no attempt to see or
communioate with the child.
13. Admitted in part. Denied in part. It is denied that
the mother promised to return the child. The communication
between the mother and father consisted of one phone call by the
mother to the father in which he told the mother to keep the
child.
14. Admitted in part. Denied in part. It is speoifically
denied that the mother refuses to tell the father the child's
whereabouts. To the best of the mother's knowledge, the father
has the addre.. and phone number and has not contacted her or the
child.
15. Admitted.
16. Admitted.
17. Admitted. It is further stated that on November 16,
1995, the support matter was continued generally until the
re.olution of the custody matter.
18. Admitted.
19. Admitted in part. Oenied in part. It is admitted that
the father ha. insurance coverage. It is denied that the father
ha. been the sole provider for the child's well-being. It is
further stated that the mother has provided for the well bsing of
the child inclUding availing herself of services provided by the
Lanoaster Aids project and continuing the child's medical
treatment at Hershey Medical Center.
20. Denied. To the best of the mother's knowledge, the
child slept on a couch and had a bedroom in a storage room whioh
Pursuant to 51024(c)(2) of Penneylvania Rules of civil
Procedure, Joan carey, of Legal Services, Inc., verifies that the
statements made in the above Petition, Answer end counterclaim
are true and correct to the best of my knowledge. To my
knowledge, the defendant is in Lancaster county and therefore out
of this Court's juriSdiction, and her verification cannot be
obtained within the time necessary to file this Petition, Answer
and counterclaim. I have sufficient information to verify the
above pleadings based upon telephone conversations with the
defendant. The undersigned understands that false statements
herein are made subject to the penalties of 1B Pa. C.S. 54904,
relatinq to unsworn falsification to authorities.
Date,
,. .1./.k / 9~~
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J n carey
Attorney for Defendant
LEGAL SERVICES, INC.
8 Irvine Row
carlisle, pa 17013
(717) 243-9400
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Tara L. Rillenhouse . IN TIlE COURT OF COMMON PLEAS OF
PlalntifT . CUMBERLAND COUNTY, PENNSYLVANIA
.
v. . NO. ((.5 - (Q?/i 5
.
Roland Williams Jr. .
Defendant . CIVIL ACTION. LAW
PETITION FOR SPECIAL AND EMERGENCV RELIEF PURSUANT
TO THE PROVISIONS QIo' RULE 1915.13 QIo'TIIE
PENNSLV ANIA RULES OF CIVIL PROCEDURE
AND NOW, this 31st day of October, 1996, comes Tam L. Rillenhouse, represented by self, who
motions this Court for Special and Emergency Relief. In support of this petition, the following is
alleged:
I. PlaintifT is Tara L. Rillenhouse, an adult individual, presently residing at 2198 A Old
Philadelphia Pike, Lancaster, Lancaster County, Pennsylvania 17602.
2. Defendant Is Roland Williams, an adult individual, residing at 3815 Trindle Road, Camp
Hill, Cumberland County, Pennsylvania 17011.
3. Plalnliff, Tara L. Rlllenhouse Is the mother of subject.
4. Defendant, Roland Williams Jr. Is the father of said child.
5. The subject of this Petition for Special and Emergency Relief Is Joshua Nathaniel Lee
Williams, social security number 196-74.0452, D.O.n. 12/18/93.
6. On the 6th day of Febmary. 1996, following a hearing of the merits, a custody order was set
forth by the Honorable Edgar B. Bayley, J..
7 Sold order Is filed as 95-6395 CIVIL TERM In the Cumberland County Court of Common
Pleas.
8. Custody was awarded to both parties as equal and shared physical custody of Joshua as
follows:
(a) Each parent shall have Joshua on alternate weeks with the exchange occurring each
Sunday at 5:00 p.m.. The mothers first week shall begin at 5:00 p.m., Sunday, Februsry 18, 1996.
(b) Notwithstanding, In 1996, the mother shall have Joshua from 9:00 a.m. December
24 through noon on Christmas day, and the father shall have him from noon on Christmas day
through 5:00 p.m. December 26, with this schedule alternated each year thereafter.
(c) The father shall deliver Joshua to the mothers home, or any place of her choice, at
the end of each period of his physical custody, and the mother shall deliver Joshua to the fathers
home or any place of his choice, at the end of each period of her physical custody.
(d) The father shall not consume any alcohol during the entire periods of his physical
custody with Joshua.
9. In this Civil Action Roland Williams, Jr. was represented as the Plaintiff, by David T. Kluz,
Esquire.
10. Tara L. Rlllenhouse was represented as the defendant, by Joan E. Carey, Esquire.
II. On Sunday, October 27.1996, Joshua was returned to his mothers home for her period of
physical custody.
12. Roland Williams, Jr. transported Joshua arriving at npproxhnately 5:45 p.m..
13. Allhough it is stated by the plaintiff that Joshua Is nonnally very quiet and withdrawn after
returning from his visit with his father, Joshua appeared to be more in need of allentlon than usual.
14, 11 was not until Monday, October 28, 1996 that the plaintiff and her husband Thomas O.
RJllenhouse, who will hereby be referred to os Joshua's step-falher, noticed bruises covering Joshua 's
bUllocks, right thigh and hip.
I S. Pictures of these bruises were token and Joshua was tfnnsp0l1ed to Lancaster County
Children snd Youth,
16. A report was taken by Phyllls Ezard of that agency and more pictures were taken.
17. Pictures, a report, snd on evaluation was faxed to Cumberland County Children and Youth
as It was delennined the location of the alleged abuse.
18. Phyllis Ezard questioned Joshua os 10 the nature of the bruises and was lold "De Dc beat my
all.".
19. May the Court be advised that during the custody hearing 95.6395 Civil Tenn it wal
establilhed by both parents and the paternal grandmother, Wlllelle Manning, Roland's mother, that
JOlhua refers to his father as De De,
20. The recipient of this report at Cumberland County Children and Youth was Kelly Miller.
21. The case of alleged abuse was filed under report number 21.0004352 and reported to the
Pennsylvania Deportment of Public Welfare.
22. On Tuesday, October 29, 1996, Joshua was lakento Red Rose Pediatric Associates and seell
by Dr. Margaret A. Reiley, 0.0.. A report was mode as follows:
(0) Shored custody with father
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ROLAND WILLIAMS, JR.,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
TARA RITTENHOUSE,
DEFENDANT
95-6395 CIVIL TERM
9RDER OF COURT
AND NOW, this 6th day of February, 1996, following a hearing on the merits, IT
IS ORDERED:
(1) All prior custody orders are vacated and replaced with this order.
(2) The lather, Roland Williams, Jr., and the mother, Tara Rittenhouse, shall
have shared legal custody of their son Joshua WIlliams, bcm December 18, 1993.
(3) The mother and father shall have shared physical custody of Joshua as
follows:
(a) Each parent shall have Joshua on alternate weeks with the
exchange occurring each Sunday at 5:00 p,m. The mother's f1l'11t
week shall begin at 6:00 p.m.. Sunday, February 18, 1996.
(b) Notwithstanding, In 1996, the mother shall have Joshua from 9:00
a.m. December 24 through noon on Christmas day, and the father
shall have him from noon on Christmas day through 5:00 p.m.
December 26, with this schedule alternated each year thereafter.
(4) The father shall deliver Joshua to the mother's home, or any other place of
her choice, at the end of each period of his physical custody, and the mother shall
deliver Joshua to the father's home, or any other place of his choice, at the end of
ROLAND WILLIAMS, JR.
Plllntlff
)
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION. LAW
NO. 96-6396 CIVIL TERM
CUSTODY NISIT A TION
VI.
TARA BANKS (RITTENHOUSE)
Dlflndlnt
ORDER
AND NOW, thll ~~ _ dlY of ""~, 199~ a helrlng II
Ichedulld on thl 5U. day of ~, JjJ.... IHl \ b ' , 1996, at ..JQ.:ll-
~.m.. In Court Rcom Number 2 of the Cumberllnd County Court Houae, Clrlllll,
Plnnlylvlnll.
Plndlng furthlr Order of Court, It Ippelrlng thlt the plrtl.. havI relched In
agrllment on In Intarlm bill I for cUltody of the minor child, JOlhul N. L.
Wlllllma, d.o.b. 18 December 1993, which Ichedule w.. dictated In thalr pr..ancI
Ind Ipproved by them end their co un lei, It II hereby ordered end dlrectld el
followa:
1. The Order of 9 November 1996 II vlceted.
2. The plrtl.. Ihall Ihlrelegal cUltody of the minor child.
3. PhYllcal cUltody of the minor child will be II followl:
A. Mother will have the child on elternltlng weekend I
blglnnlng on Friday at 8:00 e.m. until the following TUllday et
4:00 p.m. Thl. Ilternltlng weekend Ichedule will begin on
FrldlV, 29 December 1996.
B. Mother will hive the child on Ilternltlng MondlV
through TueldlV on the welkl following the long waekend
Ichedule beginning It 8:00 I.m. on Mondav until 4:00 p.m. on
TUlldlV. Thll Ilternltlng Ichldula will begin on Mondav, 8
Jlnulry 1898.
C. The drop-off Ind pick-up placa for Mother'l parlodl
of cUltodv with the child will occur It the plternll
grlndmothlr'l hOUII, tha plternal grlndmother baing Wlllltt.
Mlnnlng.
D. Flther will hive cUltodv of thl minor child It all
othlr tlmal.
4. The plrtl.. hl"e agre.d to Ihlre the Chrlltmll holldlV. In
1896, Flthar will hive the child frcm Chrl.tm.. Eve through 10:00
I.m. on Chrlltml' DIV Ind Mothlr will have the child from 10:00
I.m. on Chrl.tm.. DIV until 10:00 a.m. on 26 Decamber.
.
6. The Plaintiff's position on custody Is as follows: Plaintiff esserts that he
hed primary custody of the child essentially since the child's birth. The child was
born while the Mother was Incarcerated. The child Is HIV positive as well as the
Mother. Father had the child according to him until September of 1996 at which
time Mother refused to return the child to him. Various court orders were obtained.
Father believes that Mother Is not stable enough to take care of tha child on a
regular and consistent basis.
6. The Dafendant's position on custody Is as follows: Defendant believes
that she should have primary custody of the child. She Indicates that her drug and
alcohol problams are bahlnd her and that she has established a new life. She also
asserts, which Father does not contest, that Father had a drug and alcohol problam
as well. Mother Indicated that she took the child from Father because the child
was In a poor physical state. She believes that the Father has not gotten control of
his drug and alcohol problem and as a result, the child Is neglected.
7. Need for separate counsel to represent child: None requested.
8. Need for Independent psychological evaluation or counseling: None
requested and the Conciliator does not believe It Is necessary.
9. A hearing In this matter Is expected to take one day.
2
..... ---.
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ROLAND WILLIAMS JR. I IN THE COURT OF COMMON PLBAS OF
Plaintiff I CUMBBRLANO COUNTY, PENNSYLVANIA
I
v. I NO.
I
TARA L. RITTENHOUSE I
Defendant I CIVIL ACTION - LAW
PII'rI'l'IOII fOR Sp.cIAL &IID .....fUI...., ...r.Iar PDRSDAII'l'
'l'O'IIm PIIOVISlnMa or RDLI& 1115.13 OP '11m
p._atLVAllIA RDLI&S or CIVIL p-aDUD
AND NOW, thiB
day of November, 1995, coaea Roland
Willi... Jr., by hiB attorney David T. Klu., who aotion. this Court
for Speoial and Baergenoy Relief. In lupport of the petition, the
following ia alleged I
1. Plaintiff ia Roland Willi..., an adult individual,
pra.ently residing at 3815 Tdndle Road, Camp Hill, Cwaberland
County, Pennaylvania 17011.
2. Defendant il Tara L. Rittenhoule, an adult individual,
having a re.idence located at an unknown addresl in Lanca.ter
County, Pennaylvania.
3. Plaintiff believes and therefore avera that the
Defendant, Tara L. Rittenhouse il the same Tara Bankl who i. the
aother of hia child.
4. The subjeot of this Petition for Special and Baergenoy
Relief il Joshua Nathaniel Lee Williams, aocial security nuaber
196-74-0452, D.O.B. 12/18/93.
5. The child, JOlhua N.L. Williams, 18 the offlpring of Tara
Banks [Rittenhoule) and Roland Williams Jr.
, ....l'....
6. At aU time8 8ince the child was relea8ed from the
hospital after birth, Roland William8 has been either responsible
for the cU8tody of the child or the custodial caretaker of the
child.
7. Plaintiff believes and therefore aver8 that the child is
Huaan I..unodeficiency Virus (HIV) positive and that the child has
been HIV positive since birth.
B. Plaintiff believe8 and therefore aver8 that the natural
~ther Tara Bank8 [Rittenhouse) i8 HIV p08itive or has AIDS, and
has been HIV positive or has had AIDS 8ince before the child was
born.
9. At the time of the birth of the ohild, the mother Tara
Banks [Rittenhouse) was incarcerated on pr08titution charqes.
10. The ohild is under care of dootors at the Hershey Medical
Center who have pre8cribed various medioines which mU8t be
adainistered reqularly to the child. Failure to provide propo8ed
medical care oan be expected to cause a medical emergency to the
child.
11. Plaintiff and Defendant aqreed on or about September 9,
1995, that the Defendant could have overnight visitation of the
child, and ths mother obtained the ohild on that date.
12. Plaintiff has not seen nor heard from the child since.
2
13. Plaintiff has had limited disoussion with the Defendant
at an unknown location in Lanca.ter County with regard to regaining
custody of hi. son, during which convereationl the Defendant
promised to return the child to the Plaintiff.
14. Defendant has failed to return the child to the
Plaintiff, refules to tell Plaintiff where the child il located and
has sought a Support Order through the Lanca.ter County Do...tic
Relations Office.
15. Plaintiff wa. .erved with a URESA Complaint in Support,
allegedly filed by Tara L. Rittenhouse .eeking payment for expense.
in raising the child from Roland William..
16. This Complaint is entered into the dockets of Cuaberland
County at DR 24,691 and at No. 1349 Support 1995.
17. A hearing 11 scheduled before Michael R. Rundle on
Noveaber 16, 1995 at 10145 a.m. in Carlisle, penn.ylvania, pursuant
to the order of court appended al an exhibit.
18. Plaintiff is employed with Pennlylvania Power' Light,
and es an employee of P P . L has inlurance coverage for him.elf
and hi. dependentl, inoluding Joshua N.L. Williaml.
19. At all time. sinoe the birth of the child Roland Williams
ha. provided for the well being of the child, including providing
exten.ive medical insurance.
3
20. When the child was spirited away from his residenoe at
3518 Trindle Road, the child had his own bedroom, clothes, toys and
day oare schedule as well as support offered by the extended family
of Roland Williams.
21. Jurisdiction and venue over the custody of the child lies
in the Court of Common Pleas of Cwnberland County because the
child's only legal residence since birth has been 3518 Trindle
Road, Camp Hill, Cumberland County, Pennsylvania.
22. A Complaint in Custody seeking an award of custody is
being filed contemporaneously with this Petition.
23. Plaintiff avers that the best interests of the child will
be ..t by granting him custody.
WHBRBFORB, Plaintiff Roland Williams seeks from this court.
1. An t.mediate ex parte temporary order of custody in favor of
Roland Williams,
2. An order directing the release of the address of Tara L.
Rittenhouse so that Plaintiff can ensure service of this
Petition and the Complaint in Custody,
3. A scheduling of a hearing whereby the faots of this matter can
be fully developed, or alternatively,
4. The scheduling of a custody conoiliation.
Respectfully submitted,
Date.
II It 19\-
, I .
David T. 1 z,
1.0. . l800S
212 Locust Street, Suite 404
Harrisburg, PA 17101
(717) 238-8183
Attorney for Plaintiff
4
WRI.ICA"I~
I, pnT~~ WILLIAKS, verify that the stat...nt~ made in the
foregoing document are true and correct to the best of my
knowledge. I understand that falee stat8lllents herein are ..de
subject to the penalties of 18 Pa. C.S. I 4904, relating to unsworn
falsification to authorities.
Date. /1- OF- 7("
jljL~.J
Roland Williami
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ROLAND WILLIAMS JR.,
Plaintiff
v.
.
.
.
.
.
.
.
IN THE COURT OF COMMON PLBAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. (i'l) _ L",J)C'(r: ( . I...
.) ,'ll\l '-4.I.n(\,
TARA BANKS [RITTBNHOUSB),
Defendant
CUSTODY/VISITATION
rllllDLMII'l' 1'0. CUB'I'OOI'
AND NOW, co..s Roland Willi..s Jr., by his attorney, David T.
Klua, and respectfully repre.ents as follows.
1. The Plaintiff, Roland Willi..s Jr., is an adult
individual, pre.ently residing at 351B Trindle Road, Caap Hill,
Cuaberland County, Pennsylvania 17011.
2. The Defendant, Tara Bank. [Rittenhouse), is an adult
individual, presently re.iding at an unknown address in Lancaster
County, Pennsylvania.
3. Plaintiff aeeka cuatody of the following child.
-
Joshua Nathaniel
Lee Williama
Present ...i_nee
unknown
11III
D.O.B.
23 mo.
12/1B/U
The afore..ntioned minor child waa born out of wedlook.
The aforementioned child is preaently in the phyaical cuatody
of Tara Banka [Rittenhou.e).
Sinoe birth, the child haa resided with the following peraona
and at the following addrease..
11II
ADDRlBB
2nd , Verbeke Street
Harrisburg, PA
DAUB
birth -
1/1/94
Betty Maynard
(grandmother)
The mother of the child ie Tara Banks, currently reeiding at
an unknown addrese in Lancaeter County, Pennsylvania.
Her marital statue 11 unknown, but Plaintiff believee and
therefore avers that ehe ie married.
The father of the child 11 Roland Williue Jr., currently
residing at 3518 Trindle Road, Camp Hill, CUlIlberland County,
Pennsylvania.
He is single.
4. The relatione hip of the Plaintiff to the child 11 that of
natural father. The Plaintiff doee not currently reBids with
anyone.
5. The relationship of the Defendant to the child is that of
natural mother. Plaintiff hae no knOWledge with wholl the Defendant
reeidee.
6. The Plaintiff hae not participated ae a party or witness,
or in any other capacity, in other litigation concerning the
custody of the child in thie or any other Court.
Plaintiff hae no information of a ouetody proceeding
concerning the child pending in a Court of this Commonwealth.
Plaintiff doee not know of a penon not a party to the
proceedinge who hae physioal oustody of the ohild or claims to have
custody or vieitation rights with respect to the child.
7. The beet intereet and permanent welfare of the child will
be eerved by granting the relief requested herein, to witl oustody
to the Plaintiff/father.
SHERIFF'S OFFICE
..
&0 NORTH DUKE STIIEtT. I.ANCASHR I'[NNSYIVANIA 1/1lt12 . 1717) ZU9 8200
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PROCESS RECEIPT, Bnd AFl'IDAVIT OF RETURN &1 "'1'1 '" Ihlo """' -.. 1'/1>1 01 """ .....,.,. Do no! - ony .......
TP:"~~~~~---ROLAND WILLIAMS, JR. ------r' i:~~~~~~llrl;
3 OEFENOANli6i--- . .. "'1'1 01 WIUl 01\ COMPLAINt . ----
TARA L. RITTENHOUSE ORDER, COMPLAINT AND__PE_T~TI~!~
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THERE ARE NO DATES ON TilE ORDER FOR A CONCILIATION CONFERENCE,
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11. BEND NOTlCE OF SEAVICE COPY TO NAME AND ADDRESS BELOW: (This 'fel mUll be compleled It noUee II '0 be m.ned)
DAVID T. KLUZ. ESQ AT SAME; 212 LOCUST ST., SUITE 404, HARRISBURG, PA 17101
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EMERGENCY RECORD. ., . .".
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Jii.'iQslER, PA 17104
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WILLIAMS, JOSHUA
3518 TRINDLE RD ArT 2 .
. CANP HILL PA -
OOBI 12/18/98 ACCTa L~~34G1777
BUSOUEHANNOCI< EMERGENCY A
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FAMILY lilSTORY
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TIME SEEN ___
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TARA L. RITTENHOUSE.
Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION - LAW
V,
ROLAND WILLIAMS. JR"
Defendant
NO. 95-6395 CIVIL TERM
ORDER OF COURT
AND NOW, this 25th day of November. 1996. this
motter hoving been called for 0 heoring this dote pursuant to on
order entered on November 4, 1996. the heoring is continued and
is reset for 1:30 p,m,. Thursday, Januory 2. 1997, in Courtroom
No.2, Cumberlond County Courthouse. Carlisle, Pending that
hearing. the current order of October 28. 1996. sholl remoin in
full force and effect,
By the Cou t.
Joan Corey. EsqUire
For Pet! t!oner
(~1
I'. J'. 1t,.
'''''''~.......A
Roland Williams, Jr..
3815 Trindle Road
Camp Hill. PA 17011
Pro se
.,
.
:prs
'"
TARA L. RITTENHOUBE,
Plaintiff
IN THE COURT OF COMMON PLEAB OF
CUMBERLAND COUNTY, PENNBYLVANIA
NO, 96-6396 CIVIL TERM
IN CUBTOOY
v.
ROLAND WILLIAMB, JR.,
Defendant
ORDER FOR CONTINUANCE
AND NOW, this
'2...,
day of December, 1996, upon
consideration of ths attached Motion for Continuance, the he.ring
scheduled for January 2, 1997, 3:30 p.m., in Courtroom No.2 of
the Cumberland County Courthouse, Carllsle, Pennsylvania, hal
been reecheduled to January 23, 1997, at B:46 a,m.
The plaintiff, Tara L. Rittenhouee, shall have primary
physical custody and ths Order of October 28, 1996, lu.pending
the cUltody rlghts of the defendant, Roland Williams, Jr.,
remains in effect pending further order of Court.
By the court ';Jl
/
Joan carey
Attorney for Plaintlff
./
fLJ.....,~ )II/''',L IJ )7-1&
Roland Will isms, Pro Be
3816 Tri ndle Road "")'p. ~ ,rr L /) J 1 fC,
Camp Hill, PA 17011
,
.
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-6396 CIVIL TERM
IN CUSTODY
TARA L. RITTENHOUSE,
Plaintiff
ROLAND WILLIAMS, JR.,
Defendant
MOTION FOR CONTINUANCE
The plaintiff, Tara L. Rittenhouse, by and through her
attorney, Joan Carey of Legal Services, Inc. states the
following:
1. The defendant, Roland Williams, Jr., sent a letter to
the court requesting ~.ood tests for the purpose of determining
paternity.
2. The plaintiff and the defendant agree to continue the
hearing scheduled for January 2, 1997, to January 23, 1997, at
8:46 a.m. to afford the defendant time to schedule and get the
results from a blood test.
3. The defendant understands and agrees that he will
arrange and pay for all of the blood testing and the plaintiff
agrees to cooperate in making herself and the child available for
such tests.
WHEREFORE, the plaintiff requests that an Order for
continuance be entered and the hearing be re-schedUled for
January 23, 1997, at 8:46 a.m. The plaintiff also requests that
pending further Order of Court the child remain in her custody,
i5; In ~;
c:::
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'.
TARA L. RITTENHOUSE, : IN THE COURT OF COMMON PLEAS OF
plaintiff :
: CUMBERLAND COUNTY, PENNSYLVANIA
v. :
: NO.95-6395 CIVIL TERM
ROLAND WILLIAMS, JR., 1
Defendant : CUSTODY
OUD .oa COIft'IIIUUC.
AND NOW, this ~J day of January, 1997, upon consideration
of the attached Motion for continuance, the hearinq scheduled in
the above captioned case for the 23rd day of January, 1997, at
8145 a.m. by this court's Order of December 27, 1996, is hereby
continued qenerally.
This Order is entered without prejudice to either party to
reque.t a he.ring.
The Order of December 27, 1996, qranting the plaintiff
pri..ry physical custody of Joshua Nathaniel Lee Williams
(008 12/18/93) and the Order of October 28, 1996, which suspended
the custOdy rights of the defendant remain in effect pendinq
further Order of Court.
..j/
).
By the co,tt, /
/
Judge
Edga
Joan carey Up-U" "wI':.. 1U.....,......!~
Attorney for Plaintiff IIlUff 7 .1.....
Roland Williams, Pro
3815 Trindle Road
Ca.p Hill, PA 17011
Se .
_ t~) 11'~vJ
'/Ll//n - ,..-
"
"0'l'10. .0. COIll'IIIUUC.
The plaintiff, Tara L. Rittenhouse, moves the Court for an
Order continuing generally the hearing in the above-captioned
case on the grounds thatl
1. Based on the request of the defendant, Roland William.,
for blood testing for purposes of determining the issue of
paternity, the court by Order of December 27, 1996, rescheduled
the hearing which had been scheduled for January 2, 1997, to
Janusry 23, 1997.
2. The blood testing has been scheduled for Maroh 25,
U97, at the Cumberland County Domestio Relations Office who has
agreed to provide for the testing with the understanding that the
defendant will pay for it. The parties understand that the
results of the test will be available within approximately six to
sight weeks from March 25, 1997.
3. The parties agree that the hearing be generally
continued without prejudice to either party to request that the
hearing be re-scheduled.
4. The plaintiff requests that the Order of December 27,
1996, whioh granted her primary physioal custody of the child and
the order of Ootober 28, 1996, which suspended the defendant's
oustody rights remain in full force and effeot.