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Home My WebLink About00-00219 ,: .,1., " , :- JAN 1 3 20~ CAROL A. KASSAB, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - CUSTODY PETER P. KASSAB, JR" Defendant NO, JpDO--- d219 ~ ORDER OF COURT L'ill NOW, \\ t'51 on , upon consideration of the attached complaint, it is ilereby directed that the parties an,d their respective counsel appear before~S,~~, the conciliator, at.s:l. "N. ' n the....L day of \-'0.( ,~, aafM., fo a Pre-Hearing Custody Conference. At such co erence, 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. FOR THE COURT, By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the American with Disabilities 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 LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 2 LmERTY AVENUE Carlisle, Pennsylvania 17013 (717) 249-3166 J-If'-6J!J / -;cJ 6tJ / '/f-t:Jty c c. "',~ - ,.,,.. ','. F.,/L.:o"n;:::!"" vr "f, '1:". V, J vc . J!; ,-:nOTl-r,JNOTARY 00 !~" I -"iN 9 PHI I 2: ,?Q C. '-~ I I r, > ,..;f,liJ{:.Rui.. PE:NNil0.~A~J~UN7Y &d- ~ ~ ~ a?J~-~ 7';~~~4~ ~~~4~ '".,", -- !7"~~~IIQ,,~~~ - ~~.~-r- ,1QII!l!!IIIIit - ,~- ~~" _ " ~J~, ,~..~ _ '. L "~- "",-, ,,:.'e'_'"'U'_' _" I~J. . CAROL A KASSAB, Plaintiff v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - CUSTODY PETER p, KASSAB, JR., Defendant : NO. ~ - 2. /C( C0J. 72v.- CUSTODY COMPLAINT 1. The Plaintiff is Carol A Kassab (hereinafter referred to as "Mother"), who currently resides at 4 Ashburg Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2, The Defendant is Peter p, Kassab, Jf. (hereinafter referred to as "Father"), who currently resides at 3940 Brookridge Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff seeks shared legal and physical custody of the following children: NAME PRESENT RESIDENCE DATE OF BIRTH Erin E. Kassab 3940 Brookridge Drive Mechanicsburg, PA 17055 9/13/83 Justin P. Kassab 3940 Brookridge Drive Mechanicsburg, PA 17055 5/11187 4. The children are presently in the custody of the Father who resides at 3940 Brookridge Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. The parties had agreed upon separation for shared equal physical custody but this has not occurred, ,-,', -,' ',;-,G.<o'" ~ . " ~" - ~ " " 5, During the pa.st five years the children have resided with the following persons at the following addresses: DATES ADDRESSES NAME..I;;QFPERSONS IN HOUSEHOLD 1994 - June, 1999 3940 Brookridge Drive Mechanicsburg, PA 17055 Mother, Father and Children June, 1999 - Present 3940 Brookridge Drive Mechanicsburg, PA 17055 Father and Children 6, The Mother of the children is Carol A. Kassab, currently residing at 4 Ashburg Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055, She is married, 7. The Father of the children is Peter p, Kassab, Jr., currently residing at 3940 Brookridge Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. He is married, 8, The relationship of the Plaintiifto that of the children is that of Mother, The Plaintiff currently resides with the following persons: NAME Carol A. Kassab RELATIONSHIP Self 9. The relationship of the Defendant to the children is Father. The Defendant currently resides with the following persons: NAME RELATIONSHIP Peter P. Kassab, Jr. Erin E, Kassab Justin P. Kassab Father Daughter Son 2 ,..., "., "\ '. "-,~" "',~ ,-, I" ' ",,~. "Ti. ~~'.-'~'''' i', ., M" 10. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 11. Plaintiff has no infonnation of a custody proceeding concerning the children pending in any court of this Commonwealth, 12, Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children, 13. The best interest and permanent welfare of the children will be served by granting the relief requested because Plaintiff can provide a stable, loving environment for her children, The children will benefit by involvement with both parents in a structured schedule and environment. The children need contact with Mother and adult supervision, 14, Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, the Plaintiff requests the Court to grant shared legal and physical custody of the children to the Plaintiff. DATE: January l!L, 2000 /// ;;..= S_I~:""i'''' E.,illre 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court l.D, 32317 Attorney for Plaintiff 3 o o CAROL A. KASSAB, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANlA v. CIVIL ACTION - CUSTODY PETER P. KASSAB, JR" Defendant NO. VERJlFICATION I, Carol A. Kassab, hereby certifY that the facts set forth in the foregoing CUSTODY COMPLAINT are true and correct to the best of my knowledge, information and belief I understand that any false statements made herein are subject to penalties of 18 Pa. C,S,A. Section 4904 relating to unsworn falsification to authorities. /~/d/~ ~llrol A. Kassab " Z 1'1 :;:;,. Cl c: m ;: )> m ;U 1'1 m ~ )> l> .. ~ Z ~ );: o ~ iJttlUl-5;: 1'1 ~ C ~ z gi!: 0 z 1"1 1], 'T\ 1Il- r :'! -< ~ "rn~ n r;o I JTl < 111_ en f/l l>!:Ic 1': r l> r " <: o )> 0 9 Z - Ul '" :~~ & o ~ AI ~ " \..N "\ -0 IN <S'l VV' ~ \ ~. 'J < '" Pl ct' ~ e. (") "t).~ !:2n~ z,:XJ .u:,); ~e ~8 :i>2 =< / '~. C) C) '- "'" z o ..,., , :ti 1"i1:1fO :;;;h. dI' ::~~~) (,,-'--n 4"') o;.r; -~ ?- ~ -0 ::J: Ct'? {Jl \D .,". I. '. ".'___.c",_'_ .'-, > '" '- -'-' ~,. - _;..,..",'-'" - '1."" -~' .,. d ." - > . - .,,~ "'-- ,.' - ,",,~_, i>,:',,1 - CAROL A KASSAB, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA' v, : CIVIL ACTION - CUSTODY PETERP, KASSAB, JR., Defendant : NO, 2000-219 ACCEPTANCE OF SERVICE I, Peter P. Kassab, hereby personally accept service and acknowledge receipt of the above-captioned Complaint for Custody, having received said Complaint on the ZJ ...'Oday of January, 2000, ~ {'). . "' . Z In ~ Cl OJ c: ;:: ;J> m ::0 In OJ :Il ;J> r, ;0 )> '" Z " ;J> p ~ r m (Jl ')> '11 ~ C " In 6 3: 0 z " '1J ~ Z '" ~, Ul m r ii -< -I /II '" !< ~ , m '" (Jl )>, !:l c z r :;;: r ~, <- " ;J> 0 Z '.... ~ " ~'-' ,",' . " o ~ I~ r<CI '1>........, 20 ;D>t:: :z :;;; -<:. , , , '. ;(-') <S CJ; '~r1" 1'.;00> ~c: " ",2- n '.".J (".) ~,-~ :::~ '~?(1 (srn -,,-\ ~~ 5:J '< N -' P"; ~.. - l'"" v:> ... '". ~ CAROL A. KASSAB, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 2000-219 CIVIL TERM . : PETER P. KASSAB, JR., . CIVIL ACTION - LAW . Defendant : : CUSTODY CUSTODY CCNCILIATICN SUJIIMARY REPOOT IN A<XXlRDANCE WITH CllMBERLAND COON'lY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Erin E. Kassab Justin P. Kassab September 13, 1983 May 11, 1987 Father Father 2. A Conciliation Conference was held on March 1, 2000, with the following individuals in attendance: The Mother, Carol A. Kassab, with her counsel Barbara Sumple-Sullivan, Esquire and the Father, Peter P. Kassab, Jr., with his counsel, Samuel L. Andes, Esquire. 3. The parties executed a written agreement in May 1999 providing for shared legal and physical custody of the Children. The Father currently resides in the marital residence with the Children and the Mother has had periods of custody, but not on a regular basis. Problems have arisen in the relationship between the Children and the Mother which the parties agree would be best addressed through family counseling. The Mother filed this Custody Complaint in order to obtain more involvement in the Children's lives and to address issues of concern with respect to the Children. 4. It was agreed by the parties and counsel that a Custody Order is not necessary at this time. The parties will select a counselor to provide family counseling and will abide by the counselor's recommendations with respect to initiating the Children's participation in the counseling. 5. Counsel for either party may contact the Conciliator to schedule an additional Conference if necessary. ~ Date tl-[ ;:wo,r:J 2l rO~. d", Dawn S. Sunday, Esquire a- ~ \. Custody Conciliator ~ ~.7-00 p,K~ cc: Barbara Sumple-Sullivan, Esquire - Counsel for Mother Samuel L. Andes, Esquire - Counsel for Father FILED--OFFiCE (!r~ T'Y: 7>:JT!..:(1I<JOTA1RY '-' "'-" ""'.. ",,-'" JT\l 00 M~.R - 7 AI1 9: 53 CUMBERLAND COUNTY PENNSYLVANIA fJ~ ~~~ 15 V) "'" V) ...:l~E-ts. '" ~..a.....o H ~)g~~S:; (l,1...:loO: .w E-tE-t ~ !;:...:l 4-l ; ~ ~~ ~ 5 . "'~ 4-l ~(l,til>< .... lljl-" .w ~'g tif5l . '" '01 oii - 150 l:: (]) ~tfii :.::q .... . -4-l ~>< ~ Hg - III lIJ 5: cw..... r.I.l ~~ == '" " fJ8~~B ~;;:: :> ~I '" == ... ~'~ rJl .- .B Q a rJl ~ =.ut: .c ~ ..- #1ll1!l! '" " E-t l...:l ~ "'~ !5~OH 8 0> . B OH . (l, N() 00: ~~ . ...:l ~ ~~2 ~ (l, """", r' "---.' -~' --- " . '.. MAR - Ii ,lood!:.Y