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at 27 N. Humer Street. Eno1a, Pennsylvania.
He is married.
4. The relationship of plaintiff to the child is that of
mother.
5. The relationship of defendant to the child is that of
father.
The plaintiff currently resides with the fOllowing persons:
~
Re1ationshio
Robert L. Longo, Jr.
Robert Longo, Sr.
son
husband
6. 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. Plaintiff has no information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
8. 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
.ill be served by granting the relief requested because:
a. The father agrees that it would be in the best
interest of the child and would ensure stability for
the child if the mother has primary physical custody
should the parties separate.
b. There has been a history of the father removing
the child from the mother's custody, ~reating a
situation which endangered the child.
c. The father has received in-patient psychiatric
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6, The father has told the mother that ifshe tries to initiate any contact with
the children he will flee the state to an undisclosed location.
7, The father is putting the children in danger and not acting in the children's
best interest for reasons including, but not limited to, the following:
a) Behaving violently toward the children and exhibiting suicidal behavior
which has resulted in in-patient psychiatric care in the past and out-patient
psychiatric care which he has discontinued against the recommendation of
his doctors. The defendant's psychiatric history was the basis for the
supervised visitation only in this Court's order of June 20, 1996, The
behavior has continued sporadically since that time such that the mother
has had to monitor his behavior toward the children on an ongoing basis.'
b) Violating the court order which gives the mother primary physical and
legal custody of Robert Longo Jr, and gives the father supervised
visitation only, by taking the children out of Cumberland County and
refusing to return them, and refusing to let the mother have any contact
with them, and threatening to take the children out of the state to an
unknown location if the mother tries to make contact with the children,
c) Removing the children from the mother's custody, creating a situation
which endangered the children, because the father had discontinued both
his mental health medications and the out-patient therapy prescribed by his
doctors. The father's instability causes the mother to fear for the safety of
the children,
8, The father is in contempt of a prior court order, entered by this court on
June 20, 1996, by his deliberate acts which have prevented the mother from exercising
legal and physical custody of Robert Longo Jr.
9, The mother is the person who can best provide for the children for reasons
including, but not limited to, the following:
a, The mothcr is presently able to provide for the children by giving the
childrcn a safe, nurturing cnvironment and providing for their
emotional, physical, medical and educational needs,
b, The mother can provide a safc and compliant home environment for
these children,
e, The mother is the parent most capable of facilitating contact between
the children and the non-custodial parent.
10, The mother requests that the Court grant primary physical and legal
custody of the children to her and allow the father supervised visitation only,
II, Without this Court's intervention, the children could be in danger of
irreparable harm,
WHEREFORE, Petitioner respectfully requests the following:
a, That the Court immediately rcmove the childrcn from danger by
granting custody of Philip Longo to the mother and ordcring the father
to comply with the Junc 20, 1996 order of this court granting the
mother primary legal and physical custody of Robert Longo Jr..
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VIOLET ), \.ONGO
PLAINTIFF
IN Till: COllRT OF COMMON PLEAS OF
('lIMIlUU,AND COUNTY. PI:NNSYLV ANIA
V,
1)6-3441 CIVIL A<.TION LAW
RODERT I., \.ONGO, Sit
IlHENIlANT
IN CUSTODY
OIUlEl{ OF COIlnT
AND NOW. Wedne.d!1. Oetober 08,J003__,_,___, upon consideration of the allaehed Complaint,
it i1; hereby directed that parties and their respective counsel appear helilre JaequeUlle,I\!._"e~ney" Es,q.__. the conciliator.
at 41b Floor, Cumberland County Courthouse, Carll,le on Thursday, November 06, 2003 at 10:30 AM
fill' a Pre-lIeuring Custody Conference, At such conference, an efll,rt will be made to resolve the issues in dispute; or
if this cannot be aeellmplished. to de line and narrow the issues to he heard by the court, and to enter into a temporary
order, All children a~e live or older may also be present at the conference, Failure to appear at the conference may
provide groonds IiII' entry of u temporary or permanent order,
The court hereby dIrects Ihe Ilarlle. 10 furnish any and all exl.llnlll'roleellon from Ahuse orders,
Special Relief order., and Cuslody orden 10 Ihe conelllalor 4S honn prior 10 sehednled hearlnl!.
FOR TilE COURT,
By: /,/
Jacquelille M. Verlll:y...EJ.q,
Custody ConciliatOl'
L
'1l1e Court of Common Pleas of Cumberland County is required hy law to comply with the Amerieuns
with Disabilites Act of ll)l)ll, For information about aeeessihle tacilities and reasonahle accommodations
available to disabled individuals having business hclill'e the court. plcase contact nul' ornee, All arrungements
must be made at least 72 hours prior to any he:lring or husiness bclilre the enurt. You must allend the scheduled
conference or hearing,
YOU SIIOULD TAKE TillS PAPER TO YOllR ATroRNI:Y AT ONCE, IF YOU DO NOT
IIAVE AN ATI'ORNEY OR CANNOT AFFORD ONE, (iO TO OR TELEI'1I0NE TilE OFFICE SET
FORTII BELOW TO FIND OUT WIIERE YOll CAN <iF!' IHiAL IIELI',
('umh.'rlallll ('ounty Ilur I\>sodation
31 Snuth Iledli>nl Street
Cill'hsle,l'ellllsyl\'ania 170\J
Telephone (717) 2-1')-.11 (,(,
The father of the child is Robert L. Longo Sr., currently residing at 16 West Willow
Street, Shamokin, West Cumberland County, Pennsylvnnia 171172, He is married,
4, The relationship of plain tin' to the ehild is that of mother, The plaintiffcurrently
resides with the following persons:
Nnme Relationshill
Violet Wnters mother
Robert K, Waters Sr, father
5, The relationship of defendant to the child is that of father, The defendant currently
resides with the following persons:
Name Relationshill
Unknown to plaintifi
Philip Longo son
Robert Longo Jr. son
6, The plaintiff has not participated as a party in other litigation concerning the custody of
the child, Philip Longo, in this court, The plaintiff has participated in custody litigation
concerning Robert Longo Jr. in this court under this docket number,
7, The plaintiff has no infonnation ofa 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 pernlanent welture of the child will be served by grunting the
relief requested for reasons ineluding, but not limited to the following:
a) By previous order of this court dated June 20, 1996, the mother, Violet Longo,
has primary physical and legal custody of Robert Longo Jr. There is no custody
order coneerning Philip Longo, The father, Robert Longo Sr" has removcd the
children from Cumberland County, where they resided until August 11,2003 and
has taken them to Shamokin, Pennsylvania without infonning the mother or
gelling her agreement.
b) The father is not acting in the child's best interest for reasons ineluding, but not
limited to, the following:
i) Behaving violently toward the child and exhibiting suicidal behavior
which has resulted in in-patient psychiatric care in the past and out-patient
psychiatric care whieh he has discontinued against the recommendation of
his doctors,
ii) Taking the child out of Cumberland County and refusing to return him,
changing his schools, and refusing to let the mother have any contact with
him since August II, 2003, and threatening to take the ehild out of the
state to an unknown loeation if the mother tries to make contaet with the
child,
iii) Violating the court order which gives the mother primary physical and
legal custody of Robert Longo Jr., with the father having supervised
visitation only, and removing the child from the mother's custody in the
past, thereby creating a situation which endangered the child,
d). The mother is the person who can best provide for the child for reasons including,
but not limited to, the following:
i) The mother is presently able to provide for the child by giving the child a
nurturing environment and providing for his emotional, physical, medical and
educational needs,
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VIOLET J. LONGO,
Plaintill'
IN TIlE COURT OF COMMON PLEAS OF
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CUMBERLAND COUNTY, PENNSYLVANIA
ROBERT L. LONGO, SR,
NO. 96.3441
CIVIL TERM
De/cndant
CUSTODY
j'F.TITION FOI~ SPECIAL RF.UF.F Pl1l~SIJANT TO pA R.C,P, 1915,13
Defendant/Pelitioner Robert L. Longo, Sr., by his allorneys, the Family Law Clinic, avers the
following in SUpport of his Petition lor Special Relief:
I. Defendant/Petitioner is Robert L. Longo, Sr. (hereinaOer "Father"), residing at16 West
Willow Street, Shamokin, Northumberland County, Pennsylvania, 17872.
2. Plaintiff/Respondent is Violet J. Longo (hereinafter "Mother"), residing at 356 Hummel
Street, Harrisburg, Dauphin County, Pennsylvania, 17104.
3. The parties arc the natural parents of Robert L. Longo, Jr., born June 2, 1994 and Philip
L. Longo, born July 16, 1996.
4. On October 1,2003, Mother filed a Petition for Special Reliefand Contempt of Court. A
true and correct copy of mother's Petition for Special Relief is attached and marked
"Exhibit A."
5. Based on averments Contained in Mother's petition, this Court entered an order on
October 3, 2003, granting Mother primary physical and primary legal custody of Robert
L. Longo, Jr. and Phillip L. Longo and directing that Father rcturn the children to
Mother's custody, The October 3,2003 Order of COUrt provided only supervised
visitation tor Falher at times agreed upon by the parties" A true and correct copy ofthc
I' 'I ,.
behaving violently toward the children und exhibiting suicidul behuvior which resultcd in both
in-paticnt and out-patient psychiatric care, Mother ullegcd that Futher had discontinued
trcatment against the recommendation of his physicians. Mother exaggeratcd the extent of
Fathcr's psychiatric trcatment. Fathcr received psychiatric treatmcnt tor a brief period in 1996.
He tollowed the recommcndations of his trcating physicians, was relcascd from their cllrc within
a few months and hils not necdcd psychiatric trcatmcnt sincc that time. Fathcr has ncver actcd
violcntly toward his childrcn.
e) Mothcr has bccn trcatcd rcccntly tor deprcssion and has refuscd to take thc medication
prescribed to hcr for this condition. Mothcr has bchaved violcntly toward the children, using
e::cessive physical force to discipline them.
7. The October 3,2003 Ordcr of Court also conlirmcd a prior order of this Court, cntered
June 20, 1996, in which Violet J. Longo was granted primary physical custody and legal
custody of Robert L. Longo, Jr. "should the partics separate." A true and correct copy of
this June 20, 1996 order is allached and marked as "Exhibit E."
8. At the time thc June 20, 1996 order was signcd, Mother, Father, and the child were still
living together as an intact family at 27 North Humer Strcet, Enola, Cumberland County,
Pennsylvania. The parties continued to live together for seven years aner the June 20,
1996 Order was establishcd, as is evidenced by Mother's own averment in hcr Complaint
lor Custody liIed Octobcr 1,2003, a truc and corrcct copy of which is attached and
marked as "Exhibit F." Mother uOllndoncd thc child on August 13,2003 and then used
that abandonment as thc "triggcring event" to seck conlinnution und cnforccment of the
conditional Ordcr cnlercd sevcn ycurs curlicr,
9. Fathcr belicves and thcrefore uvcrs lhul delivcring thc childrcn to Mother's primary
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custody could placc thc childrcn in dangcr of harm and would not bc in their best
intcrest. Fathcr is thc parcnt who can bcst providc for thc children for rcusons including,
but not limitcd to, thc /ollowing:
(a) Mother is currcntly living with hcr parcnts, Violct Watcrs and Robcrt K. Watcrs,
Sr. Fathcr bclievcs and thercforc avers that the children havc bccn physically
abuscd in the past by Mothcr and hcr parcnts.
(b) Thc childrcn arc currcntly cnrollcd in school in the Shamokin School District.
Thcy havc adjusted to thcir ncw school and arc doing wellthcre. Mothcr resides
in Dauphin County, whcrc the childrcn have not attcndcd school. Fathcr belicves
that cnrolling the childrcn in schoolthcrc would disruptthc childrcn in thc middle
of the schooltcrm.
(c) Father has bcen primary carctaker ofthc childrcn since Mother Icn them at their
paternal grandmother's homc on August 13,2003. Father has providcd a stable
and nurturing cnvironment for the childrcn since Mothcr Icft the family in August.
(d) Father has becn providing, and can continue to provide for his children by giving
thcm n salc, nurturing environment and providing for their emotional, physical,
mcdical and educational needs.
(e) Father has becn, and will continue to be, the parent most capable of facilitating
contact between the children and the non-custodial parent.
10. Without intervention from this Court, the children Robert L. Longo, Jr. and Philip L.
Longo could be in dangcr of irreparublc harm.
11. Mother's Complaint for Custody hus been schedulcd tor Concilintion belore the Custody
Conciliutor on Novcmbcr 6, 2003 at 10:30 n.m. A truc copy of thc Ordcr schcduling thut
Conciliation is attachcd as "Exhibit G."
12. Father requcsts thc following rclief:
a) That thc Court vacate thc Ord:r of Court cntercd Octobcr 3, 2002 and thc Ordcr of
Court dated June 20, 1996.
b) That thc Court dircct thut Plaintiffs Complaint lor Custody tilcd Octobcr 1,2003 nnd
Dcfendant's Countcrelaim tilcd contcmporancously with this Pctition be nddresscd jointly nt the
Conciliation Conferencc schcdulcd for Novcmbcr 6,2003.
13. Mother is rcprescnted in this matter by Jonn Carey, Esquire and Jcssica Diamondstone,
Esquire ofMidPcnn Legal Serviccs. Pursuant to Local Rule 206-2 (c), Dcfendant's
counsel has sought lhe concurrencc of Plaintiffs counsel in this pctition. Plaintiffs
counscl does not concur.
WHEREFORE, Defendant/Petitioner Robert L. Longo, Sr. respectfully requests that the
Court vacate the prior Ordcrs in this matter and direct that the Plaintiff's Complaint for Custody
filed October 1,2003 nnd the Defendant's Counterclaim for Custody filed October 14,2003 be
addressed at the Conciliation Conference scheduled for November 6, 2003.
Respectfully Submitted,
'~(~>'- "'t\. \A.~ J.-v~"-
Tracic N. Wesner
Ccrtilied L cgallntern C'
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Anne - cDonald-Fox
Supervising Attorney
Family Law Clinic
45 N. Pitt Strcct
Carlislc, PA 17013
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(" Thl: t:lthcr has told the mothcr thai if she trics to initiatc any contact with
the childrcn hc willllcc thc state to an undiscloscd local ion.
7, Thc 1;lther is pUlling thc childrcn in dangcr and not acting in the childrcn's
bcst intercst t,'r rcasons inclllding, butnotlimitcd to, thc f(jllowing:
a) Ilchaving violently toward thc childrcn and cxhibiting suicidal behavior
whkh has resllltcd in in-paticnt psychiatric carc in the (last and ollt-paticnt
psychiatric carc which hc has discontinllcd against the rccommcndation of
his doctors, The dclcndant's psychiatric history was thc basis lor the
supervised visitation only in this Court's [Jrdcrof Junc 20,1996. The
bchavior fms continucd sporadically sincc thaltimc such that the mother
has had to monitor his behavior toward the childrclI on all ongoing basis.
b) Violating the court ordcr which givcs the mother primary physicul ami
legal cuslody of Robert Longo Jr. and gives the futher supervised
visitation only, by taking the children oul of Cumberland County and
refusing to return them, and refusing to let the mother have uny eonlaet
with them, und threatening to take the childrcn out of the state to an
unknown location jfthc mothcr tries to make contact with the children.
e) Removing the childrcn from the mother's cllstody, crcating a situation
which endangered thc childrcll, bccallsc the fathcr had discontinucd both
his mcntal health medications and thc Ulll-paticnt therapy prescribed by his
doctors. Thc 1;lthcr's illstability causcs thc mothcr to lcar lor thc safcty of
thc childrcn.
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8, The lillhcr is in contcmpt of a prior court ordcr, cntcrcd by this court on
Junc 20, 1996, by his dclibcrate ucts which havc prevcnted the mother from excrcising
Icgalund physical custody of Robcrt Longo Jr.
9. Thc mother is thc pcrson who can bcst provide tor th..: childrcn for rcasons
including, but notlimitcd tn, thc tilllowing:
a, The nlDthcr is prcsently ablc to prnvidc tllr the children by giving the
childrcn a satc, nurturing cnvironment and providing for their
emotional, physical, mcdical and cdueationalnecds.
b, The mol her can provide a sate and compliant home environment for
thest: ehildrcn.
c, The mother is the parcnt most capable of facilitating contact between
the childrcn und the non-custodial parent.
10. The mother requests that the Court grant primary physical and legal
custody of the children to her and allow the f.1ther supcrvised visitation only.
II. Without this Court's intervention, the children could be in danger of
irrepurable ham!.
WHEREFORE, Pctitioncr respectfully rcquests the following:
a. That lhe Court immcdiately remove thc children from danger by
granting custody of Philip Longo to the mother and ordering 1I1l' futhcr
to comply with the June 20, 19l)6 ordcr of this court granting the
muther primary Icgal and physical custody of Robcrt Longo Jr..
.,' ':. .-
VERIFICATION
Thc aLove-naJllcd PLAINTIFF, Violct J. l.ongo, vcritics thatlhc statemcnts made in the
almve COll1plninl For Custody arc lrlle nnd corrcct. PlaintilT 1I11dcrstands that tillsc statcll1ents
hcrein IIn: lI1ude suhjecllothc pcnaltics of I II Pa, C.S, !H'Jll'I, relaling tllUlISWllfll falsiticatiolllll
authorities,
Date: )0'- 01- 03
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Rc\'ilcd 19!9 .
j . " THIS LEASE WITNESSETH, Th.1
as Lusor. hereby LUlIes to __
HARK A. R051Nl
ROBERT LONGO
hcrein;Jfler referred fa
hereinafter re(erred to.. Tenanl('), (or Ihe Term o( -L.Y!.lar cummencin~ un 110, ~
day oj August 2~ and endln~ on Ihe 5th doy 01 August 2--4
Ihe (ollowlne apanmentln iI. pruenl condillon arla.JiJ..Llnw 51.. 5homnk In < Po"~ Counly, ra,
Illhe rent of S . 275 <.00 per~~r.I~enlro Ii. paid in ononlhIY14l1>1VWmVlIlS, withuul demand, in
adtance, In rh. aonOunl o( S __27 ~ lOa , payable lhe (irsl day o( .E.a~
and on ..,h and every monlh there.n" durine 'Ih. Icrm lJ! ""Y "newallhe,eu(,
Th. T,o,"II.) (anh" '~IC" 10 P"lo'm, (ully ob.y .O~ ,ompl, ",", "II II" """",""e" luk" "~ul,,,,,,,,, ,"d I,,,,, "I ,II ;ouo,",
,u,hu,,,i.., bo,,~ 01 om,,,", ICI.ILO; 10 ..,~ PlCm"u, 0' Ih. impI""",,,,,, II,,, "", '" '" I,", '''' ,,,,,''',, """ 1,,,",,, "," ,,, '''e '" "",uPI, '"
,u((er 01 p"ml' '0' p'"on 0' bo~y 10 Ult or occupy, Ih. ..i~ premi.n, ,,, ,'''' 1''''' Ih",,,I, I,,, ,'''y I""p"" I" "'" '" "..1.11'''" ,,( ,"v I"",
IIIlYI, or ordlnlnu, whether federal, Sialc Or munieipII, durina Ihe l~rrlll1j ~~Id Icil\c.
Ten'"'I') I~IC" 10 P'Y' ",urtly ~'PO..I in Ih. .mOUO' o( I , pnor I.' occup,o,)' o( Ih,
IP.lnmen!. Th, '''umy d'po'illh.1I be h.l~ by Leuor or hlla~'ol, ," ""UIII,\' I", Ih, p,,,n"'1I 0' "II "'" "O~ <lIh" ""OOun,. au, I''',n
T.nnlnUI) 10 L.uor, 0' hi. '1'01, (or Ihe Ten.nlll) per(orm"n'." or'he,,,.,, ""~ '~"n., .ny ~.m'a" '"usc~ 10 Ih, 'p"flln,nl 0' ,n)o'h"
P'fI of L"""'l propen) by Ten,olll), hll (,mily, Ind/or IU,,", T.n'''''I.) un~""'nd, .nd 'a"" Ih" Ih. IC'U,", dep,,,n ma, 11<11 h,.
'pph'd II ronl or II.inll .ny olher .mou", du. (rom T.n.nl(') 10 L.hn" ""'h,,", L"hO", nr uieol'l wrillen eonlCnl, '"01 Ih" ,h. m"""hl,"
UlU ...ill be paid u,ch mOl\lh. lnciudinn Ihe I_II monlh or rhe Icue lcrm,
II i. (onh.ral"'d Ih" i(..i~ T.nln'(l) 'hili "mo," or "pro.. o'deel''''"n in"nlonn In "move any o(lh. 100~1 'nd 'h'II,,, (ro"" (h,
promi..., 0' i( Ih. T.nlnl(,) Ih.1I permillny jud;menllo be 'n""d U~'IoI" Ihe "i~ reo,"nll') or mak,"n ",icnmem (0' II" b,n.(n n/
".dilon ollhoold Iny blnkloplCY proecedinill b. becun by Oral.inu "oi~ r,nUnl('), Ih, "n' (ur ,h, (ull "rill .h,1I b"om, imm'~",,,y ~u.
~nd collectible,
^ del"minini o(lh.lCrm, or Ih. "'''PI Orren, ,(Ie, d'(.uh. 0' ,('co jUolam,"" 0' alle",ceul,on, ,h,1I nOI d,p"" Ih, L.llO' or 0111"
IClion 'I,iolllh. Tenanl (orpom..ion or (0' renl, 0' (o'd.m'i'" Th, L",,", muy UIC 'he "medies herein Cov'n oelhose p","ib'd b)' I,w.
or bOlh, and Ih. Lmo, or ^I'nl m,y .n"" "' "'ill, 10 in'p"llh. p"mi"" 10 ,,~, 01 "n~ p'''on. on .",id prop",)', '''~inc 1<1 re!ll 0'
pur~hJJe, m.lke repJ.iu and pOSt nOljces or "To Lei" and "For Sale."
/(Ih. p"mi."" Iny lim. b. d",".d or ,Iosed.lhe Lwo, mly "II" by (0"'. wilho", li"billlY 10 pro",ulion or "",on Ih".(or, ".;"
Ih. p"mi.",.. ^I.n, orlhe T.n.n,. (or InY un"pi,ed ponion o( Ihe "I'm a'ld ,''CO" Ih, "'II Ih",ror "n~ "Pply II on Ih" L'""e
The L",ollhall nOI be ".bl. (0' any injury 0' ~.macc '0 any pmon Ort" >ny p,openy "" "ny lim. on .,lio prem.." 0' buli~ine (rol1l "ny
cause wh""'r which OIlY Iti" (rom 'he use oreondilion or said pICmi". "I' huil~in~ ,,, r,n!ll ie. I "mon, oe (rom W"", rain or .now wlll'h
m,y i..k iOlO, illue Or now (rom any por, o("id build in;. 0' (rom 'h, p'p" "I' pllllllhinc nl Ihe "1I11e, '" ("'III ""Y IlIh" pi"" UI'~U"r!", ur
(,0m In)' olhcr cause, during said term or any Icncwallhcreor.
NOTE - The (ollowioa condilion. or Iny rul" adopled (orth. poem;'" "re 10 b, un~""oll~ "' pall o( I h, aen""'I...."
I. T.oanfl'IP""'o u.olh. apallmen' only.. 'hc p.non'l residence IIIT,,"nl(.) und hi., her 'Ih,irehli~rcn. und nUl 'u "uicn I hi. Ie",e
or 'ubi.. Ihl Ip.rtm.OI. T.n.nlll) Ilrm nO'lo .h" no, make additiunl ,,, Ihe "pallm,nl. ilS p.inl or ilS ""UI" 'nd "ppli,nCe> wi'hou,
L...o~, or II.n,', wrill.n eOIl"nt. Tenlnl(') 'a"" nOllo do 0' permil uny 'el or p,octi" injuriou"o Ihe buildinc or which m.y b,
un'....on.bl. or dinurbina 10 Ih. olher ",id.nlS. a' do In) Ict.or p.nnil '")' Uct whieh may .((", Ihe in.oran" on Ih, buil~in~.
2. T.n"'(l) '1""IOu"due ca" in 'he use orth..p.nm.OI "od Ih. "PI,'iBlle" Ihcr.in, and "II olher pOIlU olL",o,'. P'Op"'Y. 10 ~i\",
nOII",o L",oror 'I.nl O(lh. n..d ror"P.i, Ihereo(. Ind 10 p.y(orall "pBi,>!o Ihe 'punmenl, ilS ,0nICIlUund 10 'II olh" p",,, o(L",,,,',
or 11'0'" prop.ny whi'h arc n.....i..led by Ihe ll<k or..re on Ihe pall on.nanH.I, Otemb", ofTI'''nl(') r.mil,. 0' hi. vis;lurs,
J. L...o, or 'ionl or ony person 'Ulho,iud by Leuo,. .h,1I huve Ih, ';~h, Iu ""er "p"",",,,, VI """'n,bl, IiI"" 10 inspocI, Ot"k,
"p.irs aod Iher"ion. II nced.d, 10 en(o"elhi, I..", und, ,(Ie, nOliee osrlc",';"", ill" i, yi"'n, '" .how "" "llaI'n,ClII 10 Plu'pccliv< r",idn",
4. Thi.l..."o.(.rs no rilhllon T.n.OI(,) IU Ult, (or any purpo", any uf 110" 1" "P''')'"J L","r ulh,r I h,,, I he in"fI"r o( th, 'panu"OI
h"eby le...d. ""PI Iho waiks and rO.dw.y, 'nd ro.dwuy. a.inine",e"," 111"""0 a"" ,",h "'h" or.a., il a"y,", Leuo, Ill"Y, (ro," 'illl' 10
lime, d"ilnm (o"he use oflh. relid,nu, IYh"llh. use by Tenanl(,I of un)' ul II" pOlli"" II( L'"or', proP'flY i. pC/milled, ilsh.1I be" bj",
'0 the rulCJ and reaulations cslabliJhc:d by Ll:s~or.
5. No animals shalJ be kept on or aboUl Ihe: premiscs,
6, 1!~!~.nl(l) shaJJ rail to PlY rent. or ",,,,, ^'........_.
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VIOLET J. LONGO,
IN TIlE COURT OF COMMON PLEAS OF
Plainlilf
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO, IJ6 - 3441
CIVIL TERM
ROBERT L. LONGO SR"
Dcfcndant
: CUSTODY
COMPLAINT FOR C,USTODY
1. The plaintiff is Violet J. Longo, residing ut356 Hummel Strcct,lIarrisburg, Duuphin
County, Pcnnsylvania 17104.
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2. The defendant is Robert L. Longo Sr., rcsiding nt 16 West Willow Strc~~i~liam~~in, ,-r;
~.~'; r-:~ ' --, ,"i 17;
Wcst Cumberland County, Pcnnsylvania 17872 g:'/.,' ..L ':':S
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3. Thc pluintiff sceks custody of the following child:
Philip Longo
16 Wcst Willow Strcct,
Shamokin, West Cumbcrland
County, Pcnnsylvaniu 17872
Thc child Philip Longo was not born out of wedlock.
The child has becn in the clIstody uf thc fathcr, who rcsidcs at 16 Wcsl Willow Strect,
Shalllokin, Wcst Cumhcrlnnd COllnty, Pcnnsylvania 17X72 l;incc thc lilthcr rcmovcd the childrcn
Irum thc mothcr's custody on Augllst 11,2(0).
During Philip Longo's Iifctime hc has residcd with thc IillIowing pcrsons and atthc
fullowing addrcsscs:
Violct Longo
(mothcr)
Robert Longo Sr.
(Iillhcr)
27 North Ilumcr Strcct
Enola, Cnmhcrland
('ouuty, Pennsylvania
7/1(jj1)(i. X/I 110.1
Thc mothcr orthe ehild is Violet 1. Longo, currcntly rcsid!ngaJ.J~b IJIUI\lIId Sll'.;~t;;"..'-,,:;
1 ' ~~' .1', " I,,;' -, '," 'I 1 ,"," ' - . " '
,.
lIarrisburg, Ilauphin (\lunty, Pcnnsylvania 1710.1.
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Shc is marricd,
EXHIBIT
'I "O~ OlQ':>~
1'~'~n'~'..4y~
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Thc fathcr ofthc child is Robcrl L. Longo Sr., currcntly rcsiding atl6 Wcst Willow
Strect, Shumokin, Wcst Cumbcrland County, pcnnsylvania 17H72. Ilc is marricd.
4. Thc relationship of plaintiff to lhc child is tlmt of moth cr. The plaintiffcurrently
rcsidcs with thc following persons:
Numc
Rc1ationship
Violct Watcrs
mothcr
Robcrt K. Waters Sr, ththcr
5. TIll' rclutionship of dcfcndantto thc child is that of father. Thc defcndunt currcntly
rcsides with the following pcrsons:
Nume Relationship
Unknown to plaintiff
Philip Longo son
Robert Longo Jr. son
6. Thc plaintiffhus not purticipated us u purty in othcr litigation concerning the custody of
thc child, Philip Longo, in this court. Thc plaintiff has participatcd in custody litigation
concerning Robert Longo Jr. in lhis courlundcr this docket numbcr.
7. Thc plaintiff has no inlilTlllationofa custody procccding conccrning the child pcnding
in a court of this Conllnonwcallh.
H, Thc plainti IT dnes nol know of a pcrsllnnot a party tothc procccdings who has
physical custody of thc child or claims to havc custlllly or visitation rights with rcspcclto the
child,
I). Thc hest inlcrcsl allll pcrmancnt welfare uf thc child will he scrvcd by granting the
relicfrcl\ucstcd lilr rcaSllns incllllling, hul nllllimitcd tothc following:
a) By prcvious mdcr nfthis courl datcd June 20, I')l)("thc muthcr, Violet Longo,
has primary physkal and Icgal CUSllllly of Rllhcrl Lungo Jr. Thcre is no custody
,.... ~ ,
I'I.AINTIFF
IN TilE COURT OF COMMON Pl.EAS OF
CUMBERl.AND COUNTY,PENNSYLVANIA
VIOLET J. LONGO
V.
96-3441 CIVIL ACTION LAW
ROBERT L. LONGO, SR.
DEFENDANT
IN CUSTODY
OHllIm OF COllltT
AND NOW,
Wednesdny, October 08, 2003 __' upon considcrution ofthc 1I1Iached Complaint,
it is hereby directcd thut partics nnd thcir rcspectivc counscl appc,n' beforc J.~cqucll,!~. M._~e...n.y,.~s(I,"_.., Ihe concilintm.
at 4tb Floor, Cumberlnnd County Courtbouse, Corll,l. on _:r~.!'!sdoy, Novemb.r 06, 2003 ut )0:30 AM
lilr 0 Pre-Heuring Custody Conti:renec. At such confcrence, an ertilrt will hc made to resolvc thc issues in disputc: or
if this cunnot be ueeomplishcd, to de line uml nurrow thc issues to be beard hy lhe court, und to entcr into u temporury
ordcr. All childrcn UIlC Iivc or oldcr mllY ulso he prcsent at the eonli:rcncc, Failure to appcar atthc eonfercncc mllY
pruvide grounds lilr entry of utcmporury or pcnnanent onler. ,'1
(" '.... '
The court hereby dlreels the partie, to furnish nuy IInd 1111 e:d,tluIl1'rntectloll frol1l/\liuse orders,
Slleclol Relief orders, and Costody orders IlIlhe cOllclllatll1' 4K hllllrs prior to scheduled h+~:~'I;IIl' .\
FOR TilE COURT.
L1y: ..J!.L-1acfJudiwulLIlc.rlll:y..Esq.
Cuslody Conciliutor
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'111C CourtofCommonPlens nfCull1berlnnd Counly is rcquircd by Inw to comply wilh the Americllns
with Disubililcs Act ,If 19')0. I'or intill'lllation nbout necessihlc '"cilitics ami rcusonuble uceommodations
availablc to disubled individuuls having husiness bclill'c thc courl, plensc contact our office, All arrangcmcnts
must be mudc nt Ieust 72 hours prim 10 nny hcaring or busincss heli're thc court. You musl attcnd the schcduled
confcrencc or hcaring,
YOU SIlOtll.D TAKE TillS PAPER TO YOUR ATlURNEY AT ONCE, IF yOU DO NOT
HAVE AN ATWRNEY OR CANNOT AFFORD (INE, GO TO OR TELEPIIONE TIlE OFFICE SET
FORTIIIIELOW TO FIND OUT WIIERE YOU CAN tjET LEGAl. liEU'.
CU111hcrl:1I101 Coullty liar A"lIClallllll
.\~ Soulh Ilcollill'll SIred
Carli,k.Pcllllsyl\'ania 17ilIJ
Tekphllnc (717) ~4'J-.ll (,(,
EXHIBIT
.
,
VIOLET J. LONGO,
Plaintill'
IN THE COURT 01' COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96 - 3441 CIVIL TERM
v.
ROBERT 1" LONGO, SR,
Dcfcndunl
CUSTODY
ANSWER TO COMPI.AINT FOR CUSTODY AND COUNTERCl.AIM
I, Admitted.
2. Admittcd in purt and dcnied in purt. The nvcrmcnt is dcnied to thc cxtcnt thut it
asscrts that Dclcndantlivcs in Wcst Cumbcrland County. Delcndant rcsidcs at 16
Wcst Willow Strcct, Shnmokin, Northumbcrland County, Pcnnsylvaniu, 17872,
3. Admittcd in purl and dcnicd in part. Thc avcrmcnt is denied to thc extcnt thut it
asscrts that Philip Longolivcs in Wcst Cumbcrlund County. Philip Longo rcsidcs
at 16 West Willow Strccl, Shumokin, Northumberlnnd County, Pcnnsylvanin,
17872.
Thc avermcnt is also dcnied to thc extcnt that it asserts that Defendant
rcmovcd the children from the mothcr's custody on August 13,2003. On that
date, Mothcr Icft the children ut their patcrnal grandmothcr's residencc, went to
the storc to purchasc cigarcttcs, nnd ncvcr returncd,
The avermcnt is also dcnied 10 thc extcnt that it asserts that Philip Longo
rcsided nt 27 North Humer Strcet, Enola, Cumbcrland County, Pcnnsylvania from
7/16/96 to 8/11/03. During Philip Longo's Iifctime hc has rcsidcd with the
following pcrsons and atthc following addrcsscs:
Ordcr of Court was cstublishcd upon considcflltion ofPlaintitl's
Pctition for Spccial Relict: That Ordcr uddresscd custody of both
Robert 1.ongo, Jr, and Philip Longo. Dclcndunt dcnics thut hc has
rcmovcd thc childrcn Irom CUlllocrlund County, The avemlcnt
is ulso dcnicd tothc cxtent thnt thc childrcn rcsidcd in
Cumhcrlund County until August 13,2003, Thc childrcn lived in
Pcrry County from Oclobcr 3, 1998 until August 7, 2003 und
thcn in Northumbcrlund County trom August 7, 2003 to thc
prcscnt. The uvenncnt is lilrthcr dcnicd tll thc cxtcnt thnt it
usscrts thut Dclcndanttook thc children to Shumokin without
inlorming thc molhcr or obtuining hcr ugrccmcnt. Both pnrtics
und thc childrcn movcd 10 Shumokin, Pennsylvunin on August 7,
2003. Both Plaintiff nnd Defcndnnt signed u lease to rent the
rcsidcncc on Wcst Willow Strect, Shamokin, Northumbcrland
County, Pennsylvania (sec "Exhibit B," nuached).
ii) Dcnied. Spccilicnlly,
i) Delcndunt hns nevcr behnved violently towurd the children, nor
hus hc cxhibited suicidal bchavior in front of the children.
Delcndant ncknowlcdgcs thnt hc reccived in-patient psychiutric
carc approximntely six to seven ycnrs ugo. lie nlso ndmits thnt
hc has rcceived Ollt-paticnl psychintric cure in thc past.
Ilowcvcr hc discontinucd such cnre scverul ycnrs ngo nt the
.
As indicatcd in Plaintill's own Compluint, Plaintiff and Defcndant
continucd to live together until August 13, 2003, ovcr sevcn ycnrs
alter thc conditional ordcr wns entcred (sec "Exhibit E" attachcd).
d) Dcnicd. Spcciticully,
i) Dcfcndant bclieves nnd thereforc avcrs tlmt the mother is
not prcsently able to providc n snfc and nurturing cnvironment for thc
childrcn, Mothcr abandoned the children whcn she Icft him ntthc
children's paternal grandmothcr's homc to go to the store nnd never
returned. MOlhcr suflcrs from depression and has bcen prescribcd
mcdication (Zoloft) to trcat her illness. Howevcr, she docs not take the
prcscribed medication, and Dclcndant bclievcs that she lacks the stability
to adequately care for the childrcn. Mother currently residcs with her
parents, and Mothcr nnd the children's maternal grandparents have been
physically abusive to the parties' children in the pnst (see "Countcrclaim")
ii) Denied.
10. Delcndant docs not deny that PlaintilT requests that the Court order the relief
listed in subparagrnphs "a" through "d." Howevcr, Defcndant asserts that the
relief requestcd in not in the best intercst of the childrcn.
11. Admitted.
.
thc children currcntly rcsidc in Pcrry County, and sincc PlainliO'has choscn to tilc
her Compluint for Custody in Cumhcrlund County, Dclcndant agrccs to wnivc the
vcnue issuc, to withdraw his Complaintl'Jr Custody in Northumhcrlund County,
nnd to Iitigatc thc custody mallcr in Cumbcrlnnd County undcr this dockct
numbcr. Dclcndant also notcs tlmtthc avermcnts containcd in Plnintifl's
Complaintl,Jr Custody IiIcd Octobcr 1,2003 hnvc not bcen veri tied by Plaintiff,
22. Defcndant hllS inlormation of n custody procccding conccrning thcsc children
pcnding in nnothcr court of this Commonwclllth, On Scptcmbcr 4, 2003,
Dcfcndantliled a Complainllor Custody pro sc in the Court of Common Plens of
Northumbcrland Counly, Civil Term, Dockct numbcr 03-1251. Thc nction is
currcntly pending with n concilintion conlcrcnce schedulcd on Octobcr 14,2003.
However, as noted in parugraph 21 of this document, Defendant is willing to
withdraw the Septcmbcr 4, 2003 Complnint for Custody so that thc cuslody
mailer may proceed in Cumberland County,
23. Dcfendant docs not know of' n person not n purty to the proccedings who has
physical custody of the childrcn or c1nims to hnve custody or visitation rights with
respcct to the childrcn.
24. The bcst intercsts and permanent welfnre ofthc childrcn will best bc servcd by
granting the relief requestcd lor reasons including, but not limited to, those sct
forth bclow:
n. PlnintilTabundoncd the childrcn nttheir matcrnal grandmothcr's residence
on August 13, 2003, nnd shc has not secn them sincc. Shc spoke with
b. Dcfcndunt by telcphonc on Scplcmbcr 3, 2003 and adviscd him that shc
did not intcnd to relurn home to lhe filmily's rcsidence nt 16 West Willow
Strcet in Shumokin, Norlhulllbcrland County, Pcnnsylvanin.
c. Plaintifl'currcntly rcsidcs with hcr parcnls, Violet Waters und Robcrt K.
Watcrs, Sr. Dc/cndant bclicvcs and thcrc/ore avcrs thnt PlaintifT and hcr
parcnts hnvc becn physically abusivc to both children in thc pust. Plaintiff
hns bccn trcUlcd rcccntly for deprcssion, but is not taking thc medicntion
prescribcd by hcr physician.
d. De/cndant bclicves nnd thcrcforc avcrs that thc children arc nfraid of thcir
mother and mnternal grandparents.
e. Plaintill'lacks ercdibility in asserting her claim/or primary physicnl
custody, since she misreprcsenlcd to this Court thc tactual circumstnnces
involved in thc childrcn's move to Nonhumberland County and provided
an inaccurate addrcss for the children lor thc pcriod thcy rcsided in Perry
County from Octobcr 1998 to August 2003.
f. Dc/endant is thc pcrson who cun best provide for the childrcn for reasons
including, but notlimitcd to, thosc set forth bclow:
i) Defcndant has been and is ablc to providc a nurturing nnd loving
environment for both children whilc also providing for their
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physicnl, emotional and cducational needs. lie hus been the
children's primary carctukcr since Plaintilfmovcd from the
lamily rcsidcnce in Shamokin on August 13,2003.
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ii) Thc childrcn arc currently cnrolled in school in the Shnmokin
Arca School District, wherc thcy arc doing wcll,
iii) Delcndunt hus bccn uctivc in cnsuring thutthc childrcn rcccivc a
good cducution, und hc intcnds to llbtnin psychl1logicul
counscling for thc childrcn to help thcm dcul with thc brenkup of
thc family.
iv) Delcndunt is the parcntthut can best facilitutc n rclntionship
bctwcen thc children und their mothcr.
25. Defcndant Robcrt L. Longo, Sr" rcquests thnt the court ordcr thc following:
a. Grunt the purtics shared Icgnl custody of Robert L. Longo, Jr. and Philip
L. Longo.
b. Grnnt Defendant primary physical custody of the two children.
c. Upon proofofPlaintitrs compliance with the plan prescribed by hcr
physicians for treatment of hcr dcpression, grant PlaintW' partial custody
of the children at times mutually ngrccable to thc parties.
d. Prohibit Plaintiff from exercising partinl custody of thc childrcn at the
home of their mnternal grnndpurents.
26, Each parent whose pnrcntnl rights to the children huve not becnterminutcd und
the person who has physical custody of thc childrcn has been named us partics to
this action,
VIOLET J. LONGO,
IN TIlE COURT OF COMMON PLEAS OF
PIa in rifl'
CUMBERLAND COUNTY
PENNSYLVANIA
vs,
No. 96-3441
CIVIL TERM
RODERT L, LONGO SR.
Dctcndant
IN CUSTODY
I'ETITION FOn SPECIAL nELlEI>' AND CONTEMI'T OF CounT
Petilioncr, Violct 1. Longo, by and lhrough her counsel, Joan Curey and Jessica
Diamondstone of MidPenn Legal Services, statcs the following:
I. Pctitioncr, the above-named Plaintiff, hereinaftcr rcferred to as the molher
is Violct J. Longo, residing lit 356 Hummel Strcct, Harrisburg, Duuphin County,
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Pennsylvania 17104. "t' c':'
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2. Respondent is the above-numed Defendant, Robcrt L. Longo Sr., U; I'
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hercinafter referred to as the father, who residcs atl6 West Willow Strect, Shamti1do;
~~ ~-"';.
West Cumber/and County, Pennsylvania 17872 =<
3. The above-numed defcndunt is lhe naturnl fathcr of Robert L Longo Jr.
bom June 2,1994, and Philip Longo bom July 16, 1996.
4. By prcvious order of this Court, Juuc 20, 1996, the mother, Violct J.
Longo, has primary physical and legal custody of Robcrt L. Lougo Jr. Therc is no
cuslody ordcr conccrning Philip Longo.
5. Thc tlllhcr, Robert L. Longo Sr., has removcd thc children from
Cumbcrland County, whcre thcy residcd until August I I, 2003 ,lIld has takcn them to
Shall1okin, Pcnnsylvania.
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6. Th~ fathcr has told th~ mothcr that ifshc trics to initiate any contact with
thc childrcn hc willllcc thc statc to anundisclnscd location.
7. Thc fathcr is putting thc children in danger and not acting in thc children's
best intcrcst for rcasons including, but not limitcd to, thc following:
a) Bchaving viol~ntly lowurd the childrcn and exhibiting suicidal behavior
which has resulted in in-paticnt psychiatric carc in thc past und Ollt-patient
psychiutrie cure which hc has discontinucd aguinst the rccommendation of
his doctors. The dcfcndant's psychiatric history was the busis for thc
supervised visitation only in this Court's order of June 20, 1996. The
bchavior has continued sporadicully sin~c that timc such that the mother
has had to monitor his bchavior toward thc childrcn on an ongoing basis.
b) Violating thc court order which gives the mother primary physical and
lcgal custody of Robert Longo Jr. and gives the father supervised
visitalion only, by taking the children out of Cumberland County and
refusing to rcturn them, and refusing to Ict the mothcr have any contuet
with thcm, and threatcning to tuke thc children out of the state to an
unknown location if the mothcr trics to make contact with the children.
c) Removing the childrcn from the mothcr's custody, creating a situation
which cndungcrcd thc childrcn, bccausc thc fathcr had discontinued both
his mcntal h~alth mcdications und thc out-paticntthcrapy prcscribed by his
doctors. Thc Illlhcr's instahility causcs thc mothcr to Icar for thc safcty of
thc childrcn,
8. The lathcr is in contempt of a prior court orucr, entered by this court on
June 20, 1996, by his delibcrate acls which have prevented the mothcr from excrcising
legal and physicul cuslody of Robcrt Longo Jr.
9. Thc mothcr is thc pcrson who ean bcst provide for the childrcn for reasons
including, but nol limitcd to, thc following:
a. Thc mothcr is prcscntly uhlc to providc tor the childrcn by giving the
childrcn a safe, nurturing cnvironmcnt and providing for their
cmotional, physical, mcdical und cducationul nceds,
b. Thc mother can providc a safe and compliant home environment for
these childrcn.
c. The mother is the parcntmost capable of facilitating contact between
the childrcn anu the non-custodial parent.
10. Thc mother requcsts thut the Court grant primary physicul and legal
custody of the children to hcr and ullow the father supcrvised visitation only.
11. Without this Court's intervention, the children could be in danger of
irrcparablc haml,
WHEREFORE, Petitioner rcspcctliJlly requests the following:
a. That the Court illlmediately rcmove the childrcn from danger by
granting custody of Philip Longo 10 thc mother and ordering the fathcr
10 comply with thc Junc 20, 19% order of this court granting the
mother primary Icgal and physical custody of Robert Longo Jr..
VERIFICATION
The ubuvc-numcd PLAINTIFF, Violl't J. Longo, vcrities that the stutcments mude in thc
above Complaint For Custody urc truc nnd cnrrcct. Pluintiff understands thatlhlse statemcnts
herein llrc madc subjcct to thc pcnallics of III Pu. C.S. ~4l)04. rclating to unsworn Ihlsitication to
authoritics,
Date:)O '.01- 03
d <1 J I-
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Violet 1. Itbngo 1/
THIS LEASE WITNESSETH, That HARK A. ROSIN! horoinal.or relorrtd.o
.. L...ar, htroby L..... to ROBERT LONGO
herelnall.r ref.rred 10.. T.nanl(.), for Ihe Ttrm of -L.1.\lar common'in~ un II". 7th
"a.> aj August _ . 2~ and ond/n~ an tho 5th doy 0/ ~~ 2--4_
the fallaw/ll~ aparrment/n II. pr"onl ,ondlllon atlJLwJ..tolJ St.. ShAmokln. Pa. County, r.,
.Ith. r.nt o(S":" 275.,00 per~~Ph.nlto~. paid IlIlllOllthIY~">lXKra"K~, without dem.nd, in
ad".n,e, In Iho amount of S __2.l.5.Loo , pay.ble lhe n"t d.y of F.,1~h Hnru.L
and on each and every month th"eoner durln~ "he term u, allY rellmallhereuf.
The Ten'nI(') lunhor 'K"" 10 porlolm. lully ob.y .nd enmply ,,,II, "II !I" ",0);,,'1""'. ,uk" "~Ul",,,,,,, ,n~ I".. u, ,II ''""','
,ulhomi... boOl~ of om",., ",..ina 10 ..id p"miSCI, Orlh, Imp,,,,,,,,,,,,, !I"",,,, '" '" !I", "'" !I,,,,,,,, a""'''"h" '"'' I" "w '" ""up)', <or
.,ller 0' permit .ny pe..on or body.o use 0' O"upy, Ihe ..Id p"nli.", '" ,"'y I'"" Ih'''"I, I", ,"'y I""P"" '" uw '" ""1"",,, of 'ny I"",
111111.11, or ordinance, whClher FederAl, SIIIC or municipal. during Ihe lerml,f )Jid 11:;1)10:.
Tenam(.) '1""'0 pay · lCoun.y depo"'ln 'h. 'mounl ol S , prior 10 o'Cupun,y of,h.
ap..nmenl, The ",u,I,y depo.il .hall be held by Ltllo, 0' hisaKenl, "",u.lly Iur Ihe p,'yn",u or "II rer" and other umoum, d" 1I.,n
Tenna,,"(.) 10 tCllor. or hi.aa.n" lor Ih. T.nanl(l) pcrld,m<cn,. Oflhol,,,,.. .nd '""nl! .ny ~ama~.. 'aUICd 10 .h. apanmen' or an}' O'her
pa" of t:'''''r'. p,op,"!, by Ten'nl"), hi. (,mBy, .nd/o, IU,,", Ten''''I>) und"'land. .nd '"'0<' Ih" Ihe mUIII}' d'po,n m.y nOI ho.
.pplied u ren, or alainll .ny olher 'mou", due flam T.n.nt(.) 10 t'M" ";lh"uI I.",,"r'. or ulenl'. wr;lI.n <onlenl, .noJ Ihallh. mU"'hl}'"
rem wiU be paid eacn monlh, includina lhe liut month or tho ICIJ: Icrm
II i, funher .11"d 'h'l i( .aid Tenanl!') .h.1I remove or .."... 0' d,,','" un Inlenloon In "nIO.O .ny 0(, he loodl.nd 'hUl"" frum fI"
prcmll... or if 'h. Tenan.(.) .h,jJ perml' any jUdamenl 10 b. 'n"red uK';'''' Ihe Ia;d T,,,.nl(.) ur m,k,.n all;~nmenl ror Ihe ben'"1 nl
'redilOll orshould .ny ban',upleY P'O"edin/ll be b'"un by 0' al,in>l .,doJ T,nUnl('), Ih, ,<'" fnrl h, (ull Ie"n .h.1I ""um. ;01 m,o;'''ely duo
.and cIJUer.liblc,
^ delermininl M'h"erm, Orthe re"ipI or "nl . II or def.ul" oraller jn.IWOlonl, u, "ler" ceu,,,,", >h,1I nOI d<priv< "" I.'"or of 01 h"
a"ion 'I.inll Ih. Tenanl lor pOIlCllion 0, lor "nl, or (oroamal'" Th.I.'.<<nl m.y Ule 1110 "medi.. her.ln a,ven art hale P""',bed by la",
or bOth, and Ihe tellor Or ^I'", m.y ""er, al will. 10 in'p"llh. pICml"., 10 lake UJ "no pmon. on ,aid p,ope"!,, "",na 10 IOnl 01
purchuc, molxc repairs and pOll nOlkes of "To Let" and "For Sale,"
Ifth. pr.mise." any lim. bo d...nod orclolCd.lh. twor may ""er b, fore., IV;I"OUI l;ahBny.o p,o",uI;on 0' "OIon Iherefor, "-I,,
Ihe premi.es,.. ^Ienl oflh. Tenanl, lorany un"pired ponion Ollh, '''10 .nd "CO,,, Ih, lonl Ihcrdor and upplY;1 nn Ih" t.....e.
The tes.orshaU no. be Uable lor any Injury ordamaa'IO any person ur 10 '"y prup'rlY HI .ny lim. On .aid p"mim or huBdln~ lrom an}
,"Use wh""er which may arise lrom 'he Use orcondilion ol..id p"m;.,o'; nr huBdin~ n, Irn", ice Ih<renn, o,flum wo"" 'oln Or .now wh'oh
may leak inlo, illue orOow lrom any pari orlOid buiidln", 0' lrom Ih, pIP<' '" pl""'hin~ ,,' 11,< 'an1O, "rlII"n uny "'h,, 1",1" ur "UUllcr. ur
(rom an)' olher cause, durina uid Wm or any I cncw6I1 thereof,
NOTE - The followinl eondllion. or .ny rul.. .dopted (0' Ihe plOmi", u" 10 bo ono""o"o u, pUrl of III. ~enerull.olUC:
I, T.nanl's .;r'''IO Ule Ihe ap.rlm.nl only .'Ihe personal "'id,n" ", T,n.nil.) and hi'/her Ilh,lrchlldlOn, .nd nOI 'u 'lSi~n. hi> 10""
Or .ublel'he .pa"men,. Ten.nl!.) '1"" nOllo .lter nor mak. .ddilluns In Ih. Uparlmenl. ill painl or ill r."ur.. ond .ppllan", wi,houl
t...o~. or .aen,'. w,l"en eonsenl. Ten.nl(') 'I"es nOI 10 do or perm" uny ." or pro"i" injullous,o Ihe build in" or whieh m.y be
unleasonabl. or dillurblnllo 'h. olher ".idenll, or do .ny.C\, 0' perm;1 un)' '''Which muy .rle.. Ihe in>Ul.n" on Iho build,ni,
2. Ten.nl(,) alrees'o use duo"re In Ihe use o(lhcap.llm.n, end Iheap"I;;""" IhCle;n, and.1I olhor PM" O(Lwor'. properly, 10 i''''
no,I,,,o tes.ororal.nl O(lh. need (or rep.ir Ihcrco(, .nd 10 pay lnr.1I rcpu,,, 'a .hcap.llm'nI. ill eon "Ill. and '0.11 Olher paru orL...,,(,
or alen". propony whleh .rc ncceuila"d by Ihe lack ol "" Cn Ihe purl or Tenanl(S), nlCmber. 0''1'''0'''(,) f'mll)', or hi. v;.i,"".
J. tcu,ror .,.nl or .ny person 'Ulhoriled by teuor, 'h.1I h,,, Ih< "~hl 10 ""er apOl'm,nl" rcu"'n.hle I;n", 10 In.p"" nlak,
rep.i.. and alt"alion. u needed, 'a ,nlorecthi.I"... .n~. .ller nolice "fl"',II'''''iu" i. ~ivcn, '" .how I hcap''''nl''" I 0 pI "'pe",vc ro.I~",,,
4, Thi.1e..cconl." no 'ilh" on T.n.nl(,) 10 use. for .ny purpu... uny uflll, p,upmy ul I.".ur UI h,r Ih.u Ih, ;m,,;or u(lho ap.,.",<O!
hereby le..ed, ""P'lh.walk..nd rO'dway,ond ro.dw,y. K.inin~ ac,"" III<I'"n ;"'~ .u,h ",IIOr """, if '"y,,, LClIor muy, lrom II",. 10
,im" desil.a"fo"h. use ofth. resid'nll, Wh,n .h. Ule by Ten.nl(,) M.ny uII", PO'II"n ol L<hor" P,uporly i. pC/milled, il.h.1I b'.ubj",
'0 the Illlc.s and rei\llaliolU cstablished by LChor,
j, No Infmab shall bt kepi on or about lhe: prcmius.
6. IfT.n.n,(.) .hall (.1I '0 p'y ronl. or .ny o'her.um., 10 tOllor whenlluo, or ,,,.11 do(.nll in any olhCl PlOv;,ion, o[llI;,'e"o, or 'hall
"movaora".mpllo remov, hi> POlles.lon. lrom 'h. premi... b.lo" p,y;!!" 1'1 Lwor ollrenl duolo Ihcc!!d Oflhe 'ea" IClm, twor of hi,
licnl. In addilion 10 all other remediu providcrl by law, may:
A, dl.sc~nlInuc utility scrvice provid~d by owner,
S, lerminalc Ihis I(Uti ,
C. briPlln laion to reCOVer Poucssion or Ihe prcmisCJi
D. brinlan ."ion.o reeoverrhe whok bul.nce ofthcrem .n.rolher """~" dlle """under, or wh"",r kiud 'nd lIalore, "~Clher w!!h
.ny and aU ,onsequ.nlial d.m'les ""00) by 'renanl!,) derault, inclo~ln" ,oo.on.ble ,"olney. (ces uno COull 'Os/.,
Th. T.n.nlllso ...pre..ly wai.es 10 'ho L",otlho ben.r., o(p,ovi.ion. ofThol.,ndlord nnd T.n.nl 10" o( 19$1 rel"ina.o NOIr"""
Quil.lOd rOn.luabl. eon.ld"..ion, eoven.." und alre" '0 vaea", "010" f,om 'nd del;", up pOII"'ion O(lhe aid preml,,, al any lime
upon recclv/nl'h;ny day.' no,i".o 10 do, in whi,h '1U"ho teuor or hi.llIiKn.may ''''nler .nd lake pOlleulon Ihmol, (See, JOI. 69 P. S.
2JO.JOI)
Snow Rlimoval
Trash Removal
Upkel!p !olf Grounds
^" ri,h.. a"d li..~i1;li.. IIm;n liVen '0 u, impo... upon e;lher 01. he P"'Io'" h.. "0, .hull ""n~ Iu !I" h""... "UIUI', 'om'nl",,, "r<,
.u,e:..o" and ...iln. oflueh pany, I(lh. saiJ Tenanl(') (",ilh 'onSCn' oflh. I.e>>.r) .h.1I '""Iin''';n PU"''';UII of '''d prem"" a(ICr lh,
"piralion of'h, term O('hi, leue. or any "n,wallhmol, 'hen Ihi.a~rcen""1 ,1"11 b"om, 100me~,,,,'Y oper,,;\,O on a mOntl,,"o-monlh
buiJ.
IN WITNESS WHEREOF, The pa"ies herClo 1C',heir hand and ''''''hll
SEAtED AND DELIVERED IN TilE PRESENCE OF
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EXHIBIT
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at 27 N. Humer street, Enola, ponnsylvania.
He is O1Iarr1ed.
4. The relationship of plaintiff to the child is that of
mother.
5. The relationship of defendant to the child is that of
father.
The plilintLff currontly resides with the following persons:
U.nma
Relationship
Robert t.. Longo, Jr.
Robert Longo, Hr.
son
husband
6. PlaLntitt has not participated as a party or witness, or
in anothor cnpilcLty, in other litigation concerning the custody
of the chLld in thLs or another court.
7. I'lnintLtr has no information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
8. PlaLntiff does not know of a person not a party to the
proceedingo 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:
iI. The father agrees that it would be in the best
interest of. the child and would ensure stability for
the child if the mother has primary physical custody
should the parties separate.
b. There has been a history of the father removing
the child from the mother's custody, creating a
situation which endangered the child.
c. The father has received in-patient pSYChiatric
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VIOLET J. LONGO,
Plaintitl.
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
NO. 96 - 3441 CIVIL TERM
v.
ROBERT L. LONGO, SR,
Dctcndnnt
CUSTODY
ClISTOI)V AGIlF.F.MENT
TIllS AGREEMENT, l11udc this 1" day of Dcccmbcr, 2003, bctwccn Robert L. Longo,
Sr. ("Fnther"),llnd Violct J. Longo ("Mothcr"), concerns the custody of their children: Robcrt L.
Longo, Jr. nnd Phillip L. Longo (collectively "the childrcn"), born June 2, 1994 and July 16,
1996 respcctively.
Father nnd Mother dcsire to entcr into an agrcement as to thc custody of the children.
Father nnd Mothcr agree to the following:
1. Father nnd Mother shall sharc legal custody of the children.
2. Father shall have primary physical custody of the children.
3. Mothcr shall have supervised visitation with the children once a weck nt the
YWCA of Grenter Harrisburg, 1101 Market Street, Harrisburg, Dauphin County,
17103. These visits will take place at a timc mutually agreeable to the partics nnd
thc YWCA ofGreatcr Harrisburg. In the altcmntive, Mothcr shall have
supcrvised visitation with thc children once a week at n timc and locntion
mutually agrecd upon by thc parties.
4. If Mothcr cannot bc prcsent lor a prcnrrangcd supcrvised visitation, she must
contact tuther approximatcly six (6) hours prior to thc timc ofthc visitation.
5. Fathcr nnd Mothcr also agrce to mcct with Dr. Laura Grennlcc, or nnothcr
Iiccnscd doctor of psychology or psychiatry ns ngrccd upon by thc pnrlics, to
discuss co-parenting and othcr issues. Thc partics ugrcc to mect with Dr.
Grecnlec twicc: oncc with Mother und Fnther only, und oncc with Mothcr, Fnther
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~5 2004
VIOLET J. LONGO,
Plaintiff
v,
: IN TIlE COURT OF COMMON PLF.AS OF
: CUMBERLAND COUNTY, PF.NNSYL VANIA
: NO. 1996-3441 CIVIL TERM
ROBERT L. LONGO, SR.,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COlJRT
AND NOW. this 4th day of March, 2004, ninety (90) days having past and no
party has requested another conciliation contcrence, the Conciliator hcrcby relinquishes
jurisdiction in this malter.
FOR THE COURT,
~~ JI. V~
dy Conciliator
7. On or about Christmas 01'2003, mothcr informcd fathcr ofhcr intcntion to tilc for
divorce nnd since thuttimc, Hither has rcfu:;cd to comply with lhc Ordcr.
8. Thc fnthcr hns willfully disobcycd thc Ordcr in wnys ineluding, but not limited, to
the following:
a, Fathcr has dcnied mothcr visitution with the childrcn since Christmas
2003.
!J, Futher has dcnicd mothcr's telephone contnct with thc childrcn sincc
Christmus 2003.
6. The father is not acting in thc children's bcst interest for rcasons including, but
not limited to, thc following:
a. Thc father's continunl alienation of the motber interferes with thc
appropriate and henlthy mother/son relationship that is imperntive to thc
children's emotional dcvclopmcnt nnd wcll-being.
b. Father encourages the children to believe that the mothcr has intentionally
abandoned them and no longer wishes to sec them.
c, Father cncouragcs thc childrcn to distance themselvcs from the mothcr.
7. The mother is entitled to pcriods ofvisitntion with the childrcn for rcasons
including, but notlimitcd to, the following:
a. Prior to the Dcccmber 2003 Ordcr, mother had primnry physicul custody
of the children.
b. The mothcr lovcs nnd hus cnred for the children and prescnts no dnnger to
the childrcn.
c. The mothcr wants to work cooperutively with tl>c fathcr in order to give
the childrcn the bcnetit of huving lwo parents involvcd in thcir livcs.
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VIOLET J. LONGO,
Plaintiff
vs.
ROBERT L. LONGO,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CUSTODY
COMPLAINT FOR CUSTODY
1. The plaintiff is Violet J. Longo, residing at 27 N.
Humer Street, Enola, Cumberland County, Pennsylvania 17025.
2. The defendant is Robert L. Longo, currently residing at
27 N. Humer Street, Enola, Cumberland County, Pennsylvania 17011.
3. Plaintiff seeks custody of the following child:
Name ~resent Residencp Aqe
Robert L. Longo, Jr. 27 N. Humer Street 1 1/2 yrs.
Enola, PA
The child was born out of wedlock.
The child is presently in the custody of Violet Longo, who
resides at 27 N. Humer Street, Enola, Pennsylvania.
During the child's lifetime, the childl has resided with the
following persons and at the following addresses:
Name
plaintiff
defendant
Address
27 N. Humer Street
Date
birth - 3/21/96
defendant
plaintiff
plaintiff &
defendant
unknown
27 N. Humer Street
Enola, PA
same location
3/21/96 - 3/25/96
3/25/96 - 3/30/96
3/30/96 - present
The mother of the child is Violet Longo, currently residing
at 27 N. Humer Street, Enola, Pennsylvania.
She is married.
The father of the child is Robert Longo, currently residing
at 27 N. Hu~er Street, Enola, Pennsylvania,.
He is married.
4. The relationship of plaintiff to the child is that of
mother.
5. The relationship of defendant to the child is that of
father.
The plaintiff currently resides with the following persons:
~ame Re~
Robert L. Longo, Jr.
son
Robert Longo, Sr. husband
6. 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. Plaintiff has no information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
8. 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:
a. The father agrees that it would be in the best
interest of the child and would ensure stability for
the child if the mother has primary physical custody
should the parties separate.
b. There has been a history of the father removing
the child from the mother,s custody, creating a
situation which endangered the child.
c. The father has received in-patient psychiatric
treatment at Holy Spirit's mental health facility, and
is currently residing at the marital residence.
10. Each parent whose parental rights to the child has not
been terminated and the person who has physical custody of the
child has been named as parties to this action.
WHEREFORE, the plaintiff requests this Court to grant
primary physical and legal custody of the child to the plaintiff
and supervised visitation in the defendant at times and places to
be agreed upon by the parties should the parties separate.
Respectfully submitted,
orney for
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
The above-named plaintiff, VIOLET LONGO, verifies that
the statements made in the above Complaint are true and correct.
The plaintiff understands that false statements herein are made
subject to the penalties of 18 Pa. C.S. section 4904, relating to
unsworn falsification to authorities.
Violet ~go, plain~ff
VIOLET J. LONGO, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :
: CUMBERLAND COUNTY, PENNSYLVANIA
:
v. : CIVIL ACTION - LAW
ROBERT L. LON~O, S~. : NO. 9~- ~,¥"// ~ 7--~
Defendant:
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Violet J. Longo, Plaintiff, 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.
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
VIOLET J. LONGO,
Plaintiff
V.
ROBERT L. LONGO, SR.
Defendant
IN THE COURT OF COMMON PLEAS OF
:
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
:
: NO. 96-
AFFIDAVIT IN SUPPORT OF PETITION
FOR LEAVE TO PROCEED IN FORMA PAUPERIS
matter and because of
fees and costs of
action or proceeding.
1. I am the plaintiff in the above
financial condition am unable to pay the
prosecuting, defending, or appealing the
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: Violet Longo
Address: 27 N. Humer Street
Enola, PA 17025-2005
Social Security Number: 167-58-8736
(b) If you are presently employed, state
Employer: N/A
Address: N/A
my
(c)
Salary or wages per month: N/A
Type of work: N/A
If you are presently unemployed, state
Date of last employment: 1995
Salary or wages per month: $151.90
Type of work: Kennel care
Other income within the past twelve months
Business or profession: $250.00 until 1/96
Other self-employment: None
Interest: None
Dividends: None
Pension and annuities: None
Social Security benefits: None
Support payments: None
Disability payments: None
Unemployment compensation and
supplemental benefits: None
Workman's compensation: None
Public Assistance: None
Other: None
(d) Other contributions to household support
(Wife (Husband) Name: N/A
If your (husband) (wife) is employed, state
Employer: N/A
Salary or wages per month: N/A
Type of work: N/A
Contributions from children: N/A
(e) Property owned
Cash: None
Checking Account: $49.99
Savings Account: None
Certificates of Deposit: $286.00
Real Estate (including home): None
Motor vehicle: Make None Year
Stocks; bonds:
Other: None
Cost
None
Amount owed
(f)
Debts and obligations
Mortgage: None
Rent: $360.00/mo.
Loans: None
Monthly Expenses: Electric-S137.00, Oi1-$22.00
Telephone-S30.00, Car insurance-S38.00, Gas-160.00
Groceries/miscellaneous-$200.0Q, Diapers-S63.00
(g)
Persons dependent upon you for support
N/A
(Wife) (Husband) Name:
Children, if any:
Name: Robert Lonqo, Jr. Age: 22 mos.
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 made ~ubject to the penalties of 18 Pa. C.S. 4904, relating
to authorities.
'~o unswor~ falsification
Violet L~g~), Plaintiff
VIOLET J. LONGO,
Plaintiff
ROBERT L. LONGO, SR.,
Defendant
: NO. 96-
:
: CUSTODY
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL TERM
This Agreement is entered on this day of June, 1996,
by the plaintiff, Violet J. Longo, and the defendant, Robert L.
Longo, 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.
WHEREAS: The father, who was threatening suicide and who
had guns in his possession, removed the child from the mother's
custody for an extended period of time, causing the mother to
fear for the child's safety.
WHEREAS: The father received in-patient psychiatric
treatment at Holy Spirit Mental Health facility, and has been
released and is undergoing out-patient counseling.
WHEREAS: The parties agree that it is in the best interest
of the child and would ensure stability for the child if the
mother has primary physical custody should 'the parties separate.
1. The mother and father agree to the entry of a Custody
Order regarding their child, Robert Longo, Jr., which provides
for the following should the parties separate:
a. The mother will have primary physical and legal
custody of the child.
CONSENT AGREEMENT
b. The father will have superw[sed visitation with the
child at times and places to be agreed upon by the
parties.
5. The parties realize that their child's well being is
paramount to any differences they might have between themselves.
Therefore, they agree that 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.
WHEREFORE, the parties request that an Order of Court be
entered to reflect the above terms.
Violet ~ngo, Plaintiff
Ca
Attorney for C/
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, Pa 17013
(717) 243-9400
Robert ~.ongo~De~da~t
VIOLET J. LONGO,
Plaintiff
ROBERT L. LONGO,
Defendant
SR.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CUSTODY
CUSTODY ORDER
AND NOW, this ~ day of June, 1996, upon consideration
of the parties, Consent Agreement, the following Order is entered
with regard to custody of the parties, child, Robert L. Longo,
Jr.:
1. The plaintiff, VIOLET J. LONGO, hereinafter referred to
as the mother, shall have primary physical and legal custody of
the child should the parties separate.
2. The defendant, ROBERT L. LONGO, SR., hereinafter
referred to as the father, shall have supervised visitation with
the child at times and places to be agreed upon by the parties.
3. 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~f~r/~he other parent.
By the coU~t,~ /
VIOLET J. LONGO,
Plaintiff
VS.
ROBERT L. LONGO SR.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
PENNSYLVAN£~
No. 96-3441 CIVIL TERM
IN CUSTODY
PETITION FOR SPECIAL RELIEF AND CONTEMPT OF COURT
Petitioner, Violet J. Longo, by and through her counsel, Joan Carey and Jessica
Diamondstone of MidPenn Legal Services, states the following:
1. Petitioner, the above-named Plaintiff, hereinafter referred to as the mother
is Violet J. Longo, residing at 356 Hummel Street, Harrisburg, Dauphin County,
Pennsylvania 17104.
2. Respondent is the above-named Defendant, Robert L. Longo Sr.,
hereinafter referred to as the father, who resides at 16 West Willow Street, Shamokin,
West Cumberland County, Pennsylvania 17872
3. The above-named defendant is the natural fiather of Robert L Longo Jr.
born June 2, 1994, and Philip Longo born July 16, 1996.
4. By previous order of this Court, June 20, 19'96, the mother, Violet J.
Longo, has primary physical and legal custody of Robert L. Longo Jr. There is no
custody order concerning Philip Longo.
5. The father, Robert L. Longo Sr., has removed the children from
Cumberland County, where they resided until August 11, 2003 and has taken them to
Shamokin, Pennsylvania.
6. The father has told the mother that if she tries to initiate any contact with
the children he will flee the state to an undisclosed location.
7. The father is putting the children in danger and not acting in the children's
best interest for reasons including, but not limited to, the fbllowing:
a) Behaving violently toward the children and exhibiting suicidal behavior
which has resulted in in-patient psychiatric care in the past and out-patient
psychiatric care which he has discontinued against the recommendation of
his doctors. The defendant's psychiatric history was the basis for the
supervised visitation only in this Court's otrler of June 20, 1996. The
behavior has continued sporadically since that time such that the mother
has had to monitor his behavior toward the children on an ongoing basis.
b) Violating the court order which gives the mother primary physical and
legal custody of Robert Longo Jr. and gives the father supervised
visitation only, by taking the children out of Cumberland County and
refusing to return them, and refusing to let ~Ihe mother have any contact
with them, and threatening to take the children out of the state to an
unknown location if the mother tries to make contact with the children.
c) Removing the children from the mother's custody, creating a situation
which endangered the children, because the: father had discontinued both
his mental health medications and the out-patient therapy prescribed by his
doctors. The father's instability causes the mother to fear for the safety of
the children.
8. The father is in contempt of a prior court order, entered by this court on
June 20, 1996, by his deliberate acts which have preventer[ the mother fi.om exercising
legal and physical custody of Robert Longo Jr.
9. The mother is the person who can best provide for the children for reasons
including, but not limited to, the following:
a. The mother is presently able to provide :['or the children by giving the
children a safe, nurturing environment and providing for their
emotional, physical, medical and educatJ[onal needs.
b. The mother can provide a safe and compliant home environment for
these children.
c. The mother is the parent most capable of facilitating contact between
the children and the non-custodial parent.
10. The mother requests that the Court grant primary physical and legal
custody of the children to her and allow the father supervised visitation only.
1 I. Without this Court's intervention, the childre:n could be in danger of
irreparable harm.
WHEREFORE, Petitioner respectfully requests the following:
a. That the Court immediately remove the cl~tildren from danger by
granting custody of Philip Longo to the mother and ordering the father
to comply with the June 20, 1996 order of this court granting the
mother primary legal and physical custody of Robert Longo Jr..
b. That the Court prohibit the father from :removing the children from
Cumberland County.
c. That the Court hold Robert Longo Sr. in contempt of the June 20,
1996 order of this Court.
Petitioner also requests any other relief this court deems just and proper.
Respectfully submitted,
Jessica Diamondstone
Attorneys for Plaintiff/Petitioner
MidPenn Legal Services
8 Irving Row
Carlisle, PA 17013
VERIFICATION
The above-named PLAINTIFF, Violet J. Longo, verifies that the statements made in the
above Complaint For Custody are true and correct. Plaintiff understands that false statements
herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to
authorities.
Date:
Violet J. ~6ngo P'
VIOLET J. LONGO,
VS.
ROBERT L. LONGO SR.,
Plaintiff
Defendant
: 1N THE COURT OF COMMON PLEAS OF
:
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 96-3441 CIVIL TERM
: CUSTODY
ORDER OF COURT
AND NOW, thi~;~'tt/~aYof _(~_~ 2003, upon consideration of the Petition For
Special Relief, the following order is entered regarding custody of Robert L. Longo Jr. bom June
2, 1994, and Philip Longo bom July 16, 1996:
1. Primary physical and legal custody of Robert Longo is confirmed in Violet J.
Longo, hereinafter referred to as the mother, pursuant 'to this Court's order of June 20,
1996.
2. Violet J. Longo shall have primary physical and legal custody of Philip Longo.
3. Robert L. Longo Sr. shall return the children to the plaintiff's custody within four
hours of receipt of this order.
4. Robert L. Longo Sr. shall be enjoined frorn removing the children from the
mother's custody.
5. The father shall have the right to supervised visitation at the Y.W.C.A., through
their supervised visitation program, in Carlisle, Pennsylvania, at times agreed upon by the
parties.
~an Carey, Attorney at Law
Jessica Diamondstone, Attorney at Law
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
,,~obert L. Longo Sr., pro se defendant
16 West Willow Street
Shamokin, Pennsylvania 17872
/
Violet J. Longo,
Plaintiff,
V.
Robert L. Longo Sr.,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND .COUNTY, PENNSYLVANIA
:
: NO. 96-3441 CIVIL TERM
:
: IN CUSTODY
PRAECIPE TO PROCEED IN FORMA iPAUPERIS
To the Prothonotary:
Kindly allow, Violet J. Longo, Plaintiff, to proceed in forma pauperis.
I, Jessica Diamondstone, attorney for the party proceeding in forma pauperis,
certify that ! believe the party is unable to pay the costs and that I am providing free
legal services to the party.
Joan Carey '~
Jessica Diamond~,~tone
Attorneys for Plaintiff
MidPeun Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
VIOLET J. LONGO,
Plaintiff
VS.
ROBERT L. LONGO SR.,
Defendant
: IN THE COURT OF COMMON PLEAS OF
:
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 96 - 3441 CIVIL TERM
:
: CUSTODY
COMPLAINT FOR CUSTODY
1. The plaintiff is Violet J. Longo, residing at 356 Hummel Street, Harrisburg, Dauphin
County, Pennsylvania 17104.
2. The defendant is Robert L. Longo Sr., residing at 16 West Willow Street, Shamokin,
West Cumberland County, Pennsylvania 17872
3. The plaintiff seeks custody of the following child:
Philip Longo 16 West Willow Street, 7 years
Shamokin, West Cumberland
County, Pennsylvania 17872
The child Philip Longo was not bom out of wedlock.
The child has been in the custody of the father, who resides at 16 West Willow Street,
Shamokin, West Cumberland County, Pennsylvania 17872 since the father removed the children
from the mother's custody on August 11, 2003.
During Philip Longo's lifetime he has resided with the following persons and at the
following addresses:
Violet Longo 27 North Humer Street 7/16/96 - 8/11/03
(mother) Enola, Cumberland
Robert Longo Sr. County, Pennsylvanfia
(father)
The mother of the child is Violet J. Longo, currently residing at 356 Hummel Street,
Harrisburg, Dauphin County, Pennsylvania 17104.
She is married.
The father of the child is Robert L. Longo Sr., currently residing at 16 West Willow
Street, Shamokin, West Cumberland County, Pennsylvania 17872. He is married.
4. The relationship ofplaintiffto the child is that of mother. The plaintiff currently
resides with the following persons:
Name
Violet Waters
Robert K. Waters Sr.
Relationship
mother
father
5. The relationship of defendant to the child is that of father. The defendant currently
resides with the following persons:
Name Relationship
Unknown to plaintiff
Philip Longo son
Robert Longo Jr. son
6. The plaintiff has not participated as a party in other litigation concerning the custody of
the child, Philip Longo, in this court. The plaintiffhas participated in custody litigation
concerning Robert Longo Jr. in this court under this docket number.
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 for reasons including, but not limited to the following:
a) By previous order of this court dated June 20, 1996, the mother, Violet Longo,
has primary physical and legal custody of Robert Longo Jr. There is no custody
order conceming Philip Longo. The father, Robert Longo Sr., has removed the
children from Cumberland County, where they resided until August 11, 2003 and
has taken them to Shamokin, Pennsylvania without informing the mother or
getting her agreement.
b) The father is not acting in the child's best interest for masons including, but not
limited to, the following:
i) Behaving violently toward the child and exhibiting suicidal behavior
which has resulted in in-patient psychiatric care in the past and out-patient
psychiatric cam which he has discontinued against the recommendation of
his doctors.
ii) Taking the child out of Cumberland County and refusing to return him,
changing his schools, and refusing to let the mother have any contact with
him since August 11, 2003, and threatening to take the child out of the
state to an unknown location if the mother tries to make contact with the
child.
iii) Violating the court order which gives the mother primary physical and
legal custody of Robert Longo Jr., with the father having supervised
visitation only, and removing the child from the mother's custody in the
past, thereby creating a situation which endangered the child.
d). The mother is the person who can best provide for the child for reasons including,
but not limited to, the following:
i) The mother is presently able to provide for the child by giving the child a
nurturing environment and providing for his emotional, physical, medical and
educational needs.
ii) The mother is the parent who can best facilitate contact between the child and
the other parent, and can provide a stable home environment for the child.
10. The mother requests that the court order the following::
a. Grant her primary physical and legal custody of Philip Longo.
b. Enjoin the father from relocating the child out of Cumberland County.
c. Order the father to return the child to her.
d. Grant the father supervised visitation only.
11. 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 ]her primary physical and legal
custody of Philip Longo, and find the father in Contempt of a prior order entered by this Court
on June 20, 1996. Confirm the custody of Robert Longo Jr., in the mother pursuant to this
Court's order of June 20, 1996. Plaintiff further requests any other relief that is just and proper.
Respect fully s~)bmitted,
Joan L~rey
Jessica Dimnondstone
Attorneys fix Plaintiff
Mid Penn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9'400
~OLET J. LONGO
PLA~FF
V.
ROBERTL. LONGO, SR.
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
96-3441 CIVIL ACTION LAW
:
: iN CUSTODY
ORDER OFCOURT
AND NOW, Wednesday, October 08, 2003 ., upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before J_.2acqueline M. Verney, Esq. _, the conciliator,
at 4th Floor, Cumberland Count~ Courthouse, Carlisle on Thursday, November 06, 2003 at 10:30 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 permanent 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 hearing.
FOR THE COURT,
By: /s/ ]acqueline M. Verney, 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 information 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
}lAVE 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 Sm:et
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
VIOLET J. LONGO,
Plaintiff
V.
ROBERT L. LONGO, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-3441 CIVIL TERM
CUSTODY
ORDER OF COURT
AND NOW, this //46/tday of October, 2003, upon consideration of the Defendant's
Petition for Special Relief, this court hereby orders the following:
1. The Order of Court dated October 3, 2003 and the Older of Court dated June 20, 1996
are hereby vacated.
2. Plaintiff's Complaint for Custody filed October 1, 2003 and Defendant's Answer and
Countemlaim filed October 14, 2003 shall be addressed at the Pm-Hearing Conference scheduled
for November 6, 2003 at 10:30 a.m. before Custody Conciliator Jacqueline Vemey. All parties
and their respective counsel appear shall appear for the Pre-Hearing conference as scheduled.
VIOLET J. LONGO,
Plaintiff
V.
ROBERT L. LONGO, SR,
Defendant
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96 - 3441 CIVIL TERM
CUSTODY
ANSWER TO COMPLAINT FOR CUSTODY AND COUNTERCLAIM
Admitted.
Admitted in part and denied in part. The averment is denied to the extent that it
asserts that Defendant lives in West Cumberland Coanty. Defendant resides at 16
West Willow Street, Shamokin, Northumberland County, Pennsylvania, 17872.
Admitted in part and denied in part. The averment is denied to the extent that it
asserts that Philip Longo lives in West Cumberland County. Philip Longo resides
at 16 West Willow Street, Shamokin, Northumberland County, Pennsylvania,
17872.
The averment is also denied to the extent that it asserts that Defendant
removed the children from the mother's custody on August 13, 2003. On that
date, Mother left the children at their paternal grandmother's residence, went to
the store to purchase cigarettes, and never returned.
The averment is also denied to the extent that it asserts that Philip Longo
resided at 27 North Humer Street, Enola, Cumberland County, Pennsylvania from
7/16/96 to 8/11/03. During Philip Longo's lifetime he has resided with the
following persons and at the following addresses:
Robert L. Longo, Sr.
(Father)
Violet J. Longo
(Mother)
27 North Humer Street,
Enola, Cumberland
County, Pennsylvania
07/16/96 - 10/03/98
Saine
122 North Market Street,
Dnncannon, Perry
County, Pennsylvania
10/03/98 - 08/07/03
Same 16 West Willow Street, 8/07/03 - Present
Shamokin, Northumberland
County, Pennsylvania
Admitted.
Admitted in part and denied in part. The averment is denied to the extent that it
asserts that an individual unknown to Plaintiff resides with Defendant. Only
Robert L. Longo, Jr. and Philip L. Longo live with Defendant.
6. Admitted in part and denied in part. The averment is denied to the extent that it
asserts that Plaintiff has participated in custody litigation concerning Robert
Longo, Jr. only. Plaintiff filed a Petition for Special Relief for custody of both
Philip L. Longo and Robert Longo, Jr., and an Order of Court addressing that
petition was established on October 3, 2003 (see "Exhibit A,' attached).
7. Admitted.
8. Admitted.
9. Admitted in part and denied in part. The averment is denied to the extent that it
asserts that the best interests of the children will be served by granting the relief
plaimiff requested. Specifically,
i) The averment is denied to the extent that it asserts that there is no
custody order concerning Philip Lo:ago. On October 3, 2003, an
Order of Court was established upon consideration of Plaintiff's
Petition for Special Relief. That Order addressed custody of both
Robert Longo, Jr. and Philip Longo. Defendant denies that he has
removed the children from Cumberland County. The averment
is also denied to the extent that the children resided in
Cumberland County until August 13, 2003. The children lived in
Perry County from October 3, 1998 until August 7, 2003 and
then in Northumberland County from August 7, 2003 to the
present. The averment is further denied to the extent that it
asserts that Defendant took the children to Shamokin without
informing the mother or obtaining her agreement. Both parties
and the children moved to Shamokin, Pennsylvania on August 7,
2003. Both Plaintiff and Defendant signed a lease to rent the
residence on West Willow Street, Shamokin, Northumberland
County, Pennsylvania (see "Exhibit B," attached).
ii) Denied. Specifically,
i) Defendant has never behaved violently toward the children, nor
has he exhibited suicidal behavior in front of the children.
Defendant acknowledges that he received in-patient psychiatric
care approximately six to seven years ago. He also admits that
he has received out-patient psychiatric care in the past.
However he discontinued such care several years ago at the
recommendation of his physicians who advised him that he no
longer needed treatment.
ii) Defendant did not unilaterally take the children out of
Cumberland County. The parties and their two children moved
from Enola, Cumberland County, Permsylvania to Duncannon,
Perry County, Pennsylvania in October 1998. The children
attended school in the Susquenita Sch~ool District in Perry County
through June 2003 (see "Exhibit C," attached). On August 7, 2003,
Plaintiff, Defendant, and their two children moved to Shamokin,
Northumberland County, Pennsylvania, where the children are
currently enrolled in school. Plaintiff' abandoned the children at
his paternal grandmother's residence on August 13, 2003, when
she left to go to the store and never returned. Defendant has not
refused to allow the mother contact with the children, nor has he
threatened to take the children out of state to an unknown location.
iii) As previously stated, Defendant did not remove the children
from the mother's custody. At the time Mother abandoned the
children, Father was not aware of the existence of the 1996 Order
of Court concerning Robert Longo, Jr. The 1996 Order was
established while the family remained intact, apparently in
contemplation of the parties' separation (see "Exhibit D" attached).
As indicated in PlaintiW s own Comp[aim, Plaintiff and Defendant
continued to live together until August 13, 2003, over seven years
after the conditional order was entered (see "Exhibit E" attached).
d) Denied. Specifically,
i) Defendant believes and therefore avers that the mother is
not presently able to provide a safe and nurturing environment for the
children. Mother abandoned the children when she left him at the
children's patemal grandmother's home to go to the store and never
returned. Mother suffers from depression and has been prescribed
medication (Zoloft) to treat her illness. However, she does not take the
prescribed medication, and Defendant believes that she lacks the stability
to adequately care for the children. Mother currently resides with her
parents, and Mother and the children's maternal grandparents have been
physically abusive to the parties' children in the past (see "Counterclaim")
ii) Denied.
10. Defendant does not deny that Plaintiffrequests that lhe Court order the relief
listed in subparagraphs "a" through "d." However, Defendant asserts that the
relief requested in not in the best interest of the children.
11. Admitted.
COUNTERCLAIM
12. The foregoing paragraphs 1 through 11 are incorporated as if fully stated herein.
13. Defendant is Robert L. Longo, Sr., residing at 16 West Willow Street, Shamokin,
Northumberland County, Pennsylvania, 17872.
14. Plaintiffis Violet J. Longo, residing at 356 Hummel Street, Harrisburg, Dauphin
County, Pennsylvania 17104.
15. Defendant Robert L. Longo, Sr., seeks primary physiical custody and shared legal
custody of the following children:
Name Address Age
Robert L. Longo, Jr. 16 West Willow Street 9
(DOB 6/2/94) Shamokin, Northumberland
County, Pennsylvania, 17872
Philip L. Longo Same 7
(DOB 7/16/96)
16. The children were not bom out of wedlock.
17. The children are presently in the custody of Defendant, who resides at 16 West
Willow Street, Shamokin, Northumberland County, Pennsylvania, 17872.
18. During the past five years, the children have resided 'with the following persons
and at the following addresses:
Robert L. Longo, Sr.
(father)
Violet J. Longo
(mother)
Same
27 North Humer Street,
Enola, Cumberland
County, Pennsylvania
122 North Market Street,
Duncannon, Perry
County, Pennsylvania
06/02/94 - 10/03/98
10/03/98 - 08/07/03
Robert L. Longo, Sr.
Violet J. Longo
(until 8/I 3/03)
16 West Willow Street,
Shamokin, Northumberland
County, Pennsylvania
8/07/03 - Present
The mother of the children is Violet J. Longo, currently residing at 356 Hummel
Street, Harrisburg, Dauphin County, Pennsylvania 1'7104.
She is married.
The father of the children is Robert L. Longo, Sr., currently residing at 16 West
Willow Street, Shamokin, Northumberland County, Pennsylvania, 17872.
He is married.
19. The relationship of Defendant to the children is that of father.
Defendant currently resides with the following persons:
Name Relationship
Robert L. Longo, Jr. Son
Philip L. Longo Son
20. The relationship of Plaintiff to the children is that of mother.
Plaintiff currently resides with the following persons:
Name Relatiouship
Violet Waters Mother
Robert K. Waters, Sr. Father
21. Defendant has participated as a party in litigation conceming the custody of both
children in this court under this docket number. Defimdant also filed a Complaint
for Custody pro se in the Court of Common Pleas of Northumberland County in
September 4, 2003. Defendant believes and therefore avers that Perry County is
the correct venue for this custody action. However, since neither the parties nor
the children currently reside in Perry County, and since Plaintiffhas chosen to file
her Complaint for Custody in Cumberland County, Defendant agrees to waive the
venue issue, to withdraw his Complaint for Custody in Northumberland County,
and to litigate the custody matter in Cumberland County under this docket
number. Defendant also notes that the averments contained in Plaintiff's
Complaint for Custody filed October 1, 2003 have not been verified by Plaintiff.
22. Defendant has information of a custody proceeding concerning these children
pending in another court of this Commonwealth. On September 4, 2003,
Defendant filed a Complaint for Custody pro se in the Court of Common Pleas of
Northumberland County, Civil Term, Docket number 03-1251. The action is
currently pending with a conciliation conference scheduled on October 14, 2003.
However, as noted in paragraph 21 of this document, Defendant is willing to
withdraw the September 4, 2003 Complaint for Custody so that the custody
matter may proceed in Cumberland County.
23. Defendant does not know ora 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.
24. The best interests and permanent welfare of the children will best be served by
granting the relief requested for reasons including, but not limited to, those set
forth below:
a. Plaintiff abandoned the children at their maternal grandmother's residence
on August 13, 2003, and she has not seen them since. She spoke with
b. Defendant by telephone on September 3, 2003 and advised him that she
did not intend to remm home to the family's residence at 16 West Willow
Street in Shamokin, Northumberland County,, Pennsylvania.
c. Plaintiff currently resides with her parents, Violet Waters and Robert K.
Waters, Sr. Defendant believes and therefore avers that Plaintiff and her
parents have been physically abusive to both children in the past. Plaintiff
has been treated recently for depression, but is not taking the medication
prescribed by her physician.
d. Defendant believes and therefore avers that the children are afraid of their
mother and maternal grandparents.
e. Plaintiff lacks credibility in asserting her claim for primary physical
custody, since she misrepresented to this Court the factual circumstances
involved in the children's move to Northumberland County and provided
an inaccurate address for the children for the period they resided in Perry
County from October 1998 to August 2003.
f. Defendant is the person who can best provide for the children for reasons
including, but not limited to, those set forth below:
i) Defendant has been and is able to provide a nurturing and loving
environment for both children while also providing for their
physical, emotional and educational needs. He has been the
children's primary caretaker since Plaintiff moved from the
family residence in Shamokin on A agust 13, 2003.
ii) The children are currently enrolled !in school in the Shamokin
Area School District, where they are doing well.
iii) Defendant has been active in ensuring that the children receive a
good education, and he intends to obtain psychological
counseling for the children to help them deal with the breakup of
the family.
iv) Defendant is the parent that can best facilitate a relationship
between the children and their mother.
25. Defendant Robert L. Longo, Sr., requests that the court order the following:
a. Grant the parties shared legal custody of Robert L. Longo, Jr. and Philip
L. Longo.
b. Grant Defendant primary physical custody of the two children.
c. Upon proof of Plaintift?s compliance with the plan prescribed by her
physicians for treatment of her depression, grant Plaintiff partial custody
of the children at times mutually agreeable to the parties.
d. Prohibit Plaintiff from exercising partial custody of the children at the
home of their maternal grandparents.
26. Each parent whose parental rights to the children have not been terminated and
the person who has physical custody of the children has been named as parties to
this action.
WHEREFORE, the Defendant requests this Court to gr~mt him shared legal and
primary physical of Robert L. Longo, Jr. and Philip Longo. Defendant requests any other
relief that is just and proper.
Respectfully submitted,
Tracie N. Wesner
Certifie.I Itegal Intern
Thomas, M. Place
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
VERIFICATION
I verify that the statements made in this Answer and Counterclaim are true and
correct to the best of my personal knowledge and belief. I understand making a false
statement would subject me to the penalties of 18 Pa.C.S. Se. ction 4904, relating to
unswom falsification authorities.
Date:
Robert L. Longo, Sr. P' '
VIOLET jr. LONGO,
VS.
ROBERT L. LONGO SR.,
Plaintiff
Defendant
: IN THE COLrRT OF COMMON PLEAS OF
:
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 96-3441 CIVIL TERM
:
: CUSTODY
ORDER OF COURT
AND NOW th' ~_V~ -- -- ~ --
, ~s.~k~_ day of (~0_~)~)~ 1~ 2003, upon consideration of the Petition For
Special Relief, the following order is ~nter---~d regard-/ng custody of Robert L. Longo Jr. born June
2, 1994, and Philip Longo born Jnly 16, 1996:
1. Primary physical and legal custody of Robert Longo is confirmed in Violet J.
Longo, hereinafter referred to as the mother, pursuant to this Court's order of June 20,
1996.
2. Violet J. Longo shall have primary physical and legal custody of Philip Longo.
3. Robert L. Longo Sr. shall return the children to Ihe plaintiff's custody within four
hours of receipt of this order.
4. Robert L. Longo Sr. shall be enjoined from removing the children from the
mother's custody.
5. The father shall have the right to supervised visitation at the Y.W.C.A., through
their supervised visitation program, in Carlisle, Pennsylwmia, at times agreed upon by the
part/es.
Joan Carey, Attorney at Law
Jessica Diamondstone, Attorney at Law
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
Robert L. Longo Sr., pro se defendant
16 West Willow Street
Shamokin, Pennsylvania 17872
By the Court,
'r~ ...... ,. .nc,~et, I here unto set m
~ Protffonota~
VIOLET J. LONGO,
Plaintiff
VS. :
:
ROBERT L. LONGO SR. :
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
PENNSYLVANIA
NO. 96-3441 CWtL TERM
IN CUSTODY
PETITION FOR SPECIAL RELIEF AND CONTEMPT OF COURT
Petitioner, Violet J. Longo, by and through her counsel, Joan Carey and Jessica
Diamondstone of MidPenn Legal Services, states the following:
1. Petitioner, the above-named Plaintiff, hereinafter referred to as the mother
is Violet J. Longo, residing at 356 Hummel Street, Harrisburg, Dauphin County,
Pennsylvania 17104.
2. Respondent is the above-named Defendant. Robert L. Longo Sr.,~
hereinafter referred to as the father, who resides at 16 West Willow Street, Sham~Q;i
West Cumberland County, Pennsylvania 17872
3. The above-named defendant is the natural father of Robert L Longo Jr.
bom June 2, 1994, and Philip Longo born July 16, 1996.
4. By previous order of this Court, June 20, 1996, the mother, Violet J.
Longo, has primary physical and legal custody of Robert L. Longo Jr. There is no
custody order concerning Philip Longo.
5. The father, Robert L. Longo Sr., has removed the children from
Cumberland County, where they resided until August 11, 2003 and has taken them to
Shamokin, Pennsylvania.
6. The father has told the mother that if she tries to initiate any contact with
the children he will flee the state to an undisclosed location.
7. The father is putting the children in danger and not acting in the children's
best interest for reasons including, but not limited to, the following:
a) Behaving violently toward the children and exhibiting suicidal behavior
which has resulted in in-patient psychiatric care in the past and out-patient
psychiatric care which he has discontinued against the recommendation of
his doctors. The defendant's psychiatric history was the basis for the
supervised visitation only in this Court's order of June 20, 1996. The
behavior has continued sporadically since that time such that the mother
has had to monitor his behavior toward the: children on an ongoing basis.
b) Violating the court order which gives the mother pr/mary physical and
legal custody of Robert Longo Jr. and gives the father supervised
visitation only, by taking the children out of Cumberland County and
refusing to return them, and refusing to let the mother have any contact
with them, and threatening to take the children out of the state to an
unknown location if the mother tries to make contact with the children.
c) Removing the children from the mother's custody, creating a situation
which endangered the children, because the father had discontinued both
his mental health medications and the out-patient therapy prescribed by his
doctors. The father's instability causes the mother to fear for the safety of
the children.
8. The father is in contempt of a prior court order, entered by this court on
June 20, 1996, by his deliberate acts which have prevented the mother from exercising
legal and physical custody of Robert Longo Jr.
9. The mother is the person who can best provide for the children for reasons
including, but not limited to, the following:
a. The mother is presently able to provide for the children by giving the
children a safe, nurturing environment and providing for their
emotional, physical, medical and educational needs.
b. The mother can provide a safe and corapliant home environment for
these children.
c. The mother is the parent most capable of facilitating contact between
the children and the non-custodial parent.
10. The mother requests that the Court grant primary physical and legal
custody of the children to her and allow the father supervised visitation only.
11. Without this Court's intervention, the children could be in danger of
irreparable harm.
WHEREFORE, Petitioner respectfully requests the fi)llowing:
a. That the Court immediately remove the children from danger by
granting custody of Philip Longo to the mother and ordering the father
to comply with the June 20, 1996 order of this court granting the
mother primary legal and physical custody of Robert Longo Jr..
b. That the Court prohibit the father from removing the children from
Cumberland County.
c. That the Court hold Robert Longo Sr~ in contempt of the June 20,
1996 order of this Court.
Petitioner also requests any other relief this court deems just and proper.
Respectfully submitted,
Jessica Diarnondstone
Attorneys for Plaintiff/Petitioner
MidPenn Legal Services
8 Irving Row
Carlisle, PA 17013
VERIFICATION
The above-named PLAINTIFF, Violet J. Longo, verifies that the statements made in the
above Complaint For Custody are true and correct. Plaintiff understands that false statements
herein are made subject to the penalties of 18 Pa. C.S. §490,4, relating to unswom falsification to
authorities.
Date: JO'- o / - o 3
Violet J. ,~n[,° F
THIS LEASE WITNESSETH, That __Mu~_RK A. RO,q[NI
as Lessor, hereby Leases to ~ __ ROBERT LONGO hereinafter referred to
h~reinafter referred to as Tenant(s), for the Term of _1
day o/ August __ 2003 .... · commencing on Ire __ 7t~__
--- -- · ---, and ending on the_ 5th - t/au o/' August 2--4.
the following apartment in its present condition al 12~Wt lJ..c:tl, g__5.l~. SJl.~kt ~.a.
at the rent ors ' 275_~_000 i~ONTH~ ~ County, Pa.
· ~ per ?~r. l<ent to be paid in montl~ly~aRm~;, without demand, in
advance, in the amount of $__Z75
-- ~ , payable the first d:~y of .Each ~. __
and on each and every month thereafter during 'the term or any renewal thereof. '
T~nant(s) agrees Io pay a security deposit in the amount of $
pan. o/Lessor s properly by Tenant si, 's f~:,!:.) pcrf,Orm~ n ~ of the ~ ..... and against u ny damae s ea. ....... o,her .noun s a ue tron
rent will be nad ca~h --'~"i'ff ,~m~r ~moum due from Tenant(s) to Lessor -.;,, ;-}a~ds, and agrees that Ihe security dc,,osh ma-y -
....... ma, InCmdmg the lasl mon h of ha lea.se term." .-.,mm ~-cssor s or agent's wriHen conse , and~hat th.e
premises, or if the Tenant(s) shall permit any judgment lo be ~ntered against the sa d 'Feuant(s) or make an assignment far tile benefit oJ'
creditors or should any bankruptcy proceedings be begun by or against sitid Tenant(s), the rurl( for the full term shall become im mcdiulcly duc
The L~ssor sba no be ruble rot an>, injury or damage o any perso o,' ~ any properly at any llme on st,id premises or building from any
NOTE -- The following conditioa~ or any rules adopted for tile premises are to bc understood as part of the genera/ Lea~e:
to the rules a~d regulations established by Lessor.
5. No animals shall be kept on or about Ire premises.
VIOLET J. LONGO,
Plaintiff
Vo
ROBERT L. LONGO, SR.
Defendant
AND NOW, this
IN THE COURT OF COMMON PLEAS OF
CUMBERlaND COUNTY, PENNSYLVANIA
:
: CUSTODY
CUSTODY ORDER
day of June, 1996, upon consideration
of the parties' Consent Agreement, the following Order is entered
with regard to custody of the parties' child, Robert L. Longo,
Jr.:
1. The plaintiff, VIOLET J. LONGO, hereinafter referred to
as the mother, shall have primary physical and legal custody of
the child should the parties separate.
2. The defendant, ROBERT L. LONGO, SR., hereinafter
referred to as the father, shall have supervised visitation with
the child at times and places to be agreed upon by the parties.
3. 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 hampe~ the free and natural
development of the child's love or respect for the other parent.
By the Court,
Jo
VIOLET J. LONGO, :
Plaintiff :
: NO. 96-
ROBERT L. LONGO, SR., :
Defendant : CUSTODY
CONSENT AGREEMENT
This Agreement is entered on this
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL TERM
by the plaintiff, Violet J. Longo, and the defendant, Robert L.
Longo, 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.
WHEREAS: The father, who was threatening suicide and who
had guns in his possession, removed the child from the mother's
custody for an extended period of time, causing the mother to
fear for the child's safety.
WHEREAS: The father received in-patient psychiatric
treatment at Holy Spirit Mental Health facility, and has been
released and is undergoing out-patient counseling.
WHEREAS: The parties agree that it is in the best interest
of the child and would ensure stability for the child if the
mother has primary physical custody should the parties separate.
1. The mother and father agree to the entry of a Custody
Order regarding their child, Robert Longo, Jr., which provides
for the following should the parties separate:
a. The mother will have primary physical and legal
custody of the child.
__ day of June, 1996,
b. The father will have supervised visitation with the
child at times and places to be agreed upon by the
parties.
5. The parties realize that their child's well being is
paramount to any differences they might have between themselves.
Therefore, they agree that 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.
WHEREFORE, the parties request that an Order of Court be
entered to reflect the above terms.
. .-'~/ / ,~ /
Violet ~ngo, Plai~{tiff
,/'/Joan Carey
'~ Attorney for
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, Pa 17013
(717) 243-9400
'Robert I~ongo ~f.,De~da~
VIOLET J. LONGO, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :
: CUMBERLAND COUNTY, PENNSYLVANIA
vs. :
: NO.
ROBERT L. LONGO, :
Defendant : CUSTODY
following persons
Name
plaintiff &
defendant
defendant
plaintiff
COMPLAINT FOR CUSTODY
1. The plaintiff is Violet J. Longo, residing at 27 N.
Humer Street, Enola, Cumberland County, Pennsylvania 17025.
2. The defendant is Robert L. Longo, currently residing at
27 N. Humer Street, Enola, Cumberland County, Pennsylvania 17011.
3. Plaintiff seeks custody of the following child:
Name Present Residence Aqe
Robert L. Longo, Jr. 27 N. Humer Street 1 1/2 yrs.
Enola, PA
The child was born out of wedlock.
The child is presently in the custody of Violet Longo, who
resides at 27 N. Humer Street, Enola, Pennsylvania.
During the child's lifetime, the child has resided with the
and at the following addresses:
Address Date
27 N. Humer Street birth - 3/21/96
27
unknown
N. Humer Street
Enola, PA
same location
plaintiff &
defendant
The mother of the child
at 27 N. Humer Street, Enola,
She is married.
The father of the child is Robert Longo,
3/21/96 - 3/25/96
3/25/96 - 3/30/96
3/30/96 present
is Violet Longo, currently residing
Pennsylvania.
EXHIBIT
currently residing
at 27 N. Humer Street,
He is married.
4.
mother.
5.
father.
Enola, Pennsylvania.
The relationship of plaintiff to the child is that of
The relationship of defendant to the child is that of
6. 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. Plaintiff has no information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
8. 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:
a. The father agrees that it would be in the best
interest of the child and would ensure stability for
the child if the mother has primary physical custody
should the parties separate.
b. There has been a history of the father removing
the child from the mother's custody, creating a
situation which endangered the child.
c. The father has received in-patient psychiatric
Name Relationship
Robert L. Longo, Jr. son
Robert Longo, Sr. husband
The plaintiff currently resides witlh the following persons:
treatment at Holy Spirit's mental health facility, and
is currently residing at the marital residence.
10. Each parent whose parental rights to the child has not
been terminated and the person who has physical custody of the
child has been named as parties to this action.
WHEREFORE, the plaintiff requests this Court to grant
primary physical and legal custody of the child to the plaintiff
and supervised visitation in the defendant at times and places to
be agreed upon by the parties should the parties separate.
Respectfully submitted,
~n Carey
Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
The above-named plaintiff, VIOLET LONGO, verifies that
the statements made in the above Complaint are true and correct.
The plaintiff understands that false statements herein are made
subject to the penalties of 18 Pa. C.S. section 4904, relating to
unsworn falsification to authorities.
Violet L~go;-"plain~ff
/
VIOLET J. LONGO,
Plaintiff
V.
ROBERT L. LONGO, SR,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96 - 3441 CIVIL TERM
CUSTODY
AFFIDAVIT OF SERVICE
I, Mary Claycomb-Kulp, hereby certify that I served defendant/petitioner's Answer and
Counterclaim by hand ~telivering a true and correct copy to the office of plaintiff's attorney, Joan
Carey, Esquire, at Mid Peun Legal Services, 8 Irving Row, Carlisle, PA 17013, on Tuesday,
October 14, 2003.
' I~la~y C~'comb-I~p
Certified Legal Intern
Family Law Clinic
45 North Pitt Street
Carlisle, PA 17013
VIOLET J. LONGO,
Plaintiff
V.
ROBERT L. LONGO, SR,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96 - 3441 CIVIL TERM
CUSTODY
CUSTODY AGREEMENT
THIS AGREEMENT, made this Ist day of December, 2003, between Robert L. Longo,
Sr. ("Father"), and Violet J. Longo ("Mother"), concerns the custody of their children: Robert L.
Longo, J?. and Phillip L. Longo (collectively "the children"), born June 2, 1994 and July 16,
1996 respectively.
Father and Mother desire to enter into an agreement as to the custody of the children.
Father and Mother agree to the following:
1. Father and Mother shall share legal custody of the children.
2. Father shall have primary physical custody of the children.
3. Mother shall have supervised visitation with the children once a week at the
YWCA of Greater Harrisburg, 1101 Market Street, Harrisburg, Dauphin County,
17103. These visits will take place at a time mutually agreeable to the parties and
the YWCA of Greater Harrisburg. In the alternative, Mother shall have
supervised visitation with the children once a week at a time and location
mutually agreed upon by the parties.
4. If Mother cannot be present for a prearranged supervised visitation, she must
contact father approximately six (6) hours prior to the time of the visitation.
5. Father and Mother also agree to meet with Dr. Laura Grennlee, or another
licensed doctor of psychology or psychiatry as agreed upon by the parties, to
discuss co-parenting and other issues. The parties agree to meet with Dr.
Greenlee twice: once with Mother and Father only, and once with Mother, Father
10.
and the children present.
Mother and Father agree to continue the Custody Conciliation scheduled before
Jacqueline M. Verney, Esquire on Tuesday, December 2, 2003 at 3:30pm for a
period of at least ninety (90) days.
Mother shall be entitled to reasonable telephone access with the children while the
children are in Father's custody.
The parties shall keep one another advised of their current address and telephone
numbers.
Neither parent will do anything which may estrange the children from the other
party, or injure the opinion of the children as to the other parent or which may
hamper the free and natural development of the children's love and respect for the
other parent.
The parties intend to be bound by the terms of this agreement and intend for this
Agreement to be made an Order of Court.
Robert L. Longo, Sr?
I I-'L o3 Date
Tracie N. Wesner
Certified Legal Intern
Robert E. Rains, Esquire
SUPERVISING ATTORNEYS
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
V o/n'
Date
Jessica'Diamondstone, E~uire
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
VIOLET J. LONGO, :
Plaimiff :
V.
ROBERT L. LONGO, SR,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96 - 3441 CIVIL TERM
CUSTODY
O~RDER
AND NOW, this [~'~-day of ~
Agreement is approved and emered as an Order of Court.
2003, the attached Custody
BY THE CO~t~I~.
VIOLET J. LONGO,
Plaintiff
V.
ROBERT L. LONGO, SR.,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 1996-3441 CIVIL TERM
:
: CIVIL ACTION - LAW
:
: IN CUSTODY
ORDER OF COURT
AND NOW, this 4th day of March, 2004, ninety (90) days having past and no
party has requested another conciliation conference, the Conciliator hereby relinquishes
jurisdiction in this matter.
FOR THE COURT,
mey, Esq~dy Conciliator
~OLETJ. LONGO,
Petitioner~laintiff
ROBERTL. LONGO,
Re~ondent/Defmdant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
No. 96-3441 Crv~ TERM
IN CUSTODY
PETITION FOR CONTEMPT AND MODIFICATION
Petitioner, Violet Longo, by and through her counsel, Jessica Diamondstone of
MidPenn Legal Services, states the following:
1. Petitioner/Plaintiff, hereinafter referred to as the mother, resides at 356 Hummel
Street, Harrisburg, Dauphin County, Pennsylvania 17104.
2. Respondent/Defendant, hereinafter referred to as the father, resides at 16 West
Willow, Shcmokin, Northumberland County, Pennsy][vania 17872.
3. Thc above-named parties are the natural parents of Robert L. Longo, Jr., born
June 2, 1994 and Phillip L. Longo, born July 16, 1996.
4. The current Custody Order, attached as Exhibit "A" and incorporated herein by
reference, is dated December 3, 2003. The Order, in pertinent part, grants the
mother periods of supervised visitation once per week and reasonable telephone
contact with the children while they are in the father's custody. It also
admonishes both parties to refrain from any actions that would estrange the
children from either parent.
5. The December 3, 2003 Custody Order was entered upon agreement of both
parties.
6. From December 3, 2003, until Christmas of 2003, both parties complied with the
Order.
7. On or about Christmas of 2003, mother informed father of her intention to file for
divorce and since that time, father has refused to comply with the Order.
8. The father has willfully disobeyed the Order in ways including, but not limited, to
the following:
a. Father has denied mother visitation with the children since Christmas
2003.
b. Father has denied mother's telephone contact with the children since
Christmas 2003.
6. The father is not acting in the children's best interest for reasons including, but
not limited to, the following:
a. The father's continual alienation of the mother interferes with the
appropriate and healthy mother/son relationship that is imperative to the
children's emotional development and well-being.
b. Father encourages the children to believe that the mother has intentionally
abandoned them and no longer wishes to see them.
c. Father encourages the children to distance themselves from the mother.
7. The mother is entitled to periods of visitation with the children for reasons
including, but not limited to, the following:
a. Prior to the December 2003 Order, mother had primary physical custody
of the children.
b. The mother loves and has cared for the children and presents no danger to
the children.
c. The mother wants to work cooperatively with the father in order to give
the children the benefit of having two parents involved in their lives.
d. For their mental health and well-being, the children need to resume
contact with their mother and to know that their mother has never had any
intention or taken any action to abandon them.
e. Without this Court's intervention, the children are at risk of being harmed
from being denied contact with their mother.
8. The father is represented by Attorney Anne MacDonald-Fox.
9. The mother's counsel has contacted Attorney MacDonald-Fox, who does not
concur with the relief requested in this Petition.
WHEREFORE, Petitioner respectfully requests the following:
a. That this Court find the Respondent in contempt of the existing
December 3, 2003, Court Order.
b. That this matter be scheduled for a conciliation to establish terms
for a modified order establishing a visitation schedule for
Petitioner.
c. That the Court immediately grant Petitioner periods of
supervised visitation with her counselor, Dr. Greenlee, as
supervisor.
d. That the Court order Respondent to allow Petitioner reasonable
telephone contact with the children.
e. Any other relief this court deems just and proper.
Respectfully suh. mitted
'-"J'~essi a D/iimondstone
Attorney for DefendantJ Petitioner
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
VERIFICATION
The above-named Plaintiff, Violet J. Longo, verifies that the statements made in the
above Petition are true and correct. Plaintiff understands that fa][se statements herein are made
subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities.
Date:
Violet J. L~i~go, Plainffff
VIOLET J. LONGO, :
:
Plaintiff :
V. :
ROBERT L. LONGO, SR, :
:
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96 - 3441 CIVIL TERM
CUSTODY
ORDER
AND NOW, this 3r'J day of~, 2003,
Agreement is approved and entered as an Order of Court.
the attached Custody
BY THE COURT:
In I'~,slimom/ w!' ,. ,f: I ' ~-
-. ~.~.,~ ~io sst my hand
VIOLET J. LONGO, :
Plaintiff :
ROBERT L. LONGO, SR, :
:
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96 - 3441 CIVIL TERM
CUSTODY
CUSTODY AGREEMENT
THIS AGREEMENT, made this 1st day of December, :2003, between Robert L. Longo,
Sr. ("Father"), and Violet J. Longo ("Mother"), concerns the custody of their children: Robert L.
Longo, Jr. and Phillip L. Longo (collectively "the children"), born June 2, 1994 and July 16,
1996 respectively.
Father and Mother desire to enter into an agreement as to the custody of th ldre~.
Father and Mother agree to the following: -'
1. Father and Mother shall share legal custody of the children.
2. Father shall have primary physical custody of the children. ~'.
3. Mother shall have supervised visitation with the children once a week at the
YWCA of Greater Harrisburg, 1101 Market Street, Harrisburg, Dauphin County,
17103. These visits will take place at a time mutually agreeable to the parties and
the YWCA of Greater Harrisburg. In the alternative, Mother shall have
supervised visitation with the children once a week at a time and location
mutually agreed upon by the parties.
4. If Mother cannot be present for a prearranged supervised visitation, she must
contact father approximately six (6) hours prior to the time of the visitation.
5. Father and Mother also agree to meet with Dr. Laura Grennlee, or another
licensed doctor of psychology or psychiatry as agreed upon by the parties, to
discuss co-parenting and other issues. The parties agree to meet with Dr.
Greenlee twice: once with Mother and Father only, and once with Mother, Father
and the children present.
Mother and Father agree to continue the Custedy Conciliation scheduled before
Jacqueline M. Verney, Esquire on Tuesday, December 2, 2003 at 3:30pm for a
period of at least ninety (90) days.
Mother shall be entitled to reasonable telephone access with the children while the
children are in Father's custody.
The parties shall keep one another advised of their current address and telephone
numbers.
Neither parent will do anything which may estrange the children from the other
party, or injure the opinion of the children as to the other parent or which may
hamper the free and natural development of the children's love and respect for the
other parent.
10.
The parties intend to be bound by the terms o£this agreement and intend for this
Agreement to be made an Order of Court.
! t. % , 't~C,/-'
Robert L. Longo, Sr.0' ' - :
[[-7--6-, 0_$ Date
Viol[et J. lP6ngo
/2 'a I - o..~ Date
Tracie N. Wesner
Certified Legal Intern
Ann~'~c D onald-F 0x,~guire
Thomas M. Place, Esquire
Robert E. Rains, Esquire
SUPERVIS~G ATTORNEYS
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Jessica Diamondstone, Esi~uire
MidPenn Legal Services
8 Irv/ne Row
Carlisle, PA 17013
(717) 243-9400
VIOLET L. LONGO,
Plaintiff/Petitioner
VS.
ROBERT L. LONGO,
Defendant/Respondent
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-3441 CIVIL TERM
CUSTODY
CERTIFICATE OF SERVICF
I, Jessica Diamondstone, Esquire, of MidPenn Legal Services, attorney for the
Plaintiff, Violet L. Longo, hereby certify that I have served a copy of the foregoing
Petition for Contempt and Modification on the following date and in the manner
indicated below:
U.S. First Class Mail, Postage Pre-Paid
Anne MacDonald-Fox, Esquire
Family Law Clinic
45 North Pitt Street
Carlisle, PA 17013
MidPenn Legal Services, Inc.
Datei:~
Jessieff Diarfiondstone, Esqui~.
MidPem~ Legal Services
8 Irvine Row
Carlisle, PA 17013
VIOLET L. LONGO
PLAINTIFF
V.
ROBERT L. LONGO
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
96-3441 CIVIL AC, TION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Friday, June 25, 2004 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear betbre Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, July 20, 2004 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 permanent 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 hearing.
FOR THE COURT,
By: /si .Iacqueline M. Verney, Esq.
Custody Conciliator
mhc
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites Act of 1990. For information about accessihle 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 betbre the court. You must
attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN A'ITORNEY 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
.~0 _SC. P