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Home My WebLink About00-02105 "'1......- "<= ,~~~...'"'""'" ~ ~' . '" . " ~" ..r '. PAUL 1. COSTA, Plaintiff vs. : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. Co - .:lIDS CiULlY~ : CIVIL ACTION - AT LAW : CUSTODY ANGELA ZA YDON COSTA, Defendant ORDER OF COURT And now, this /0 rl>. day of !If' r < / , 2000, upon consideration of the attached Complaint, it is hereby directed that the above parties and their respective counsel appear before~ 5: SvAli>A1 ' Esquire, the conciliator, located at 5'''1 W. M If I A.J ~ T. , JA~ e I1ANI (<; gue 0 ' Pennsylvania, on the ;:ls-':.n day of (YYll If ' 2000, at q~.b PI .m. 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 be present at the conference. Failure to appear at the conference may provide grounds for the entIy of a temporary or pennanent order. FOR THE COURT: By: '/)r!~JJ <5". f.-...aIAy Ps'1 Custody Conciliator ' {'J;1- 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 Liberty Avenue Carlisle, PA 17013 (717)249-3166 r: 1/ It/- c:c) ~-/O-4::5 .i/-IP't/t' i;.); -<, , . I I I ,~^ - ,<. iIIIii r>,':';:..$':S -"",,\,'-/ . ~.'t"""_,' \,.",~ \!\\F\\~'\ ~'\\,y,:~).. (\\,..: '.,'<'.J ,'- '.-' . . t~ (0) I,', r\. <_\' V{i' ,-'{ .,nll,;,,1 "~\",' \..)VJ ".\:"\ p,;"c! Ih,\I~, I' I'l.~ ,;),~ .....,..1\\ ",...\'\\\' C'J\~\?~~\,\'j \ -~ I ck ~, \ $ .'..-' -,n ",.11, \jU i~" w- ~~ m~-ii;- d/ ~ ~$4~ ~ ~ $ df~ -~ "",",~,~J!L.~~ _" '"'T ~1I!I5\1,~., ~, '_ _~U~'w.f!IIIl!'I1I'~ijI!M!'~_~f!WI';I!l!ll'ffl~r"'1i'C1~"%1'r~'W';~'-!"Pi"lj(V""'!~'~",",I:,~!ll'l~if'I'I'UFll''f'l""~!!i'i'!.,;~j"-,,,-IJi;.,llifff>mf!'"j!l"tfi'''iF;l'RjljfPJt:c,; i' - '''''~ ~~ ~~~-- "~. <- -~ !:\r',,~ PAUL 1. COSTA, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. ANGELAZAYDONCOSTA, Defendant : CIVIL ACTION - AT LAW : CUSTODY AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans 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. BY THE COURT: Date: 1. ", .~~ .~- ~_I ~ ., ~ -- - , - - ;',~ PAUL 1. COSTA, Plaintiff vs. : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. (;1J - ~/ 0 S GJ '1--lt.-- : CIVIL ACTION -AT LAW : CUSTODY ANGELAZAYDON COSTA, Defendant COMPLAINT IN CUSTODY AND NOW, the Plaintiff, Paul 1. Costa, by and through his attorney, Jeanne B. Costopoulos, Esquire, makes the following Complaint in Custody: 1. The Plaintiff, Paul 1. Costa, is an adult individual who currently resides at 501 Huth Road, Cheektowaga, New York, 14225. 2. The Defendant, Angela Zaydon Costa, is an adult individual who is currently residing at 612 Somerset Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The parties have one dependent child, namely Sabrina Y. Costa (DOB 4/25/92). 4. The Plaintiff seeks primary of the following child: Name Present Residence ~ Sabrina Y. Costa 612 Somerset Drive Mechanicsburg, PA 17055 8 (4/25/92) The child, Sabrina Y. Costa, is presently in the custody of her mother, Defendant, Angela Zaydon Costa, at 612 Somerset Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055, where she has lived with Defendant since April of 1999. Prior to that time, Plaintiff and Defendant resided together with the child at 612 Somerset Drive, Mechanicsburg. -~ '~ <WI ~~ 0_ __ ~_.l . . "" - ''"''.~,u~n'~Il,'_I_;, . Plaintiff was divorced from Defendant on March 20, 2000. The child was not born out of wedlock. 5. The relationship of the Plaintiff to the child is that of natural father. Plaintiff currently resides at 501 HuthRoad, Cheektowaga, New York, 14225. The relationship of the Defendant to the child is that of natural mother. Defendant currently resides at 612 Somerset Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 6. Plaintiffhas 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 does not know of a person not a party to the proceedings who has physical custody of any of the child or claims to have physical custody or visitation rights with respect to the child. 8. . The best interests and permanent welfare of the child will be served by granting the relief requested because: (a) Plaintiffis the natural father of the child. (b) Plaintiff has established a relationship with the child, which should be maintained. (c) Plaintiff desires to exercise parental duties and to enjoy the love and affection of the child. (d) The child should be permitted to enjoy the love, affection, and emotional support which can be provided by hernaturaI father. (e) The child would benefit from maintaining a relationship with her naturaI father. 9. Each parent whose parental rights to the child have not been tenninated and the person who has pbysical custody of the child have been named as parties to this action. No other persons are ~, ~~ <~~ ~- " ~ "~'f~ . known to have or claim a right to custody or visitation of the child to be given notice of the pendency of this actiO)1 and the right to intervene. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an order granting to him partial physical and shared legal custody of his daughter. RespectfulIy submitted, .eB. Costopoulos, Esquire A ORNEY FOR PLAINTIFF 1400 N. Second Street Harrisburg, PA 17102 (717) 221-0900 Supreme Ct. ID No. 68735 '" ,~~ -. ~ . ~~ -" ~ ~.......... ' ~_I '" j---_~I'"',,- . PAULJ. COSTA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. ANGELAZAYDON COSTA, Defendant : CIVIL ACTION - AT LAW : CUSTODY VERIFICATION I, Paul J. Costa, hereby verifY that the statements made in the foregoing Custody Complaint are true and correct to the best of my knowledge, infonnation, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities. Date: 3-:2. 7 -(30 Signature: V 7 ~ Paul J. Costa " ~ - - -.~.-~. ~.~~~ ,.-.- " "-~",,,-,",~,,,-; , , PAUL J. COSTA, Plaintiff . IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-2105 CIVIL TERM : ANGELA ZAYOON COSTA, Defendant : CIVIL ACTION - LAW : CUSTODY ORDER OF <XXlRT ANDJDq, this 14' day of /;;" - upon consideration of the attached Cust dy Conciliation ordered and directed as follows: , 2000, Report, it is 1. The prior Order of this Court dated April 30, 1999 is vacated and replaced with this Order. 2. The Mother, Angela Z. Costa, shall have primary physical and sole legal custody of Sabrina Y. Costa, born April 25, 1992. 3. The Father, Paul J. Costa, shall be entitled to have supervised visitation with the Child at the Y.W.C.A. in Carlisle, with the paternal grandmother present, as arranged between the parties and the Y.W.C.A. personnel. The Father shall be responsible for all costs of visitation under this provision. 4. Counsel for either party may contact the Conciliator within 90 days of the date of this Order to schedule an additional Custody Conciliation Conference if necessary. Edward E. Guido, ~4U ~ -1-00 ~I'<~ cc: Jeanne' B. Costopoulos, Esquire - Counsel for Father Maryann Murphy, Esquire - Counsel for Mother I!l~.'" >'~.Jc,., 1Att!ill2i~~iIIlI!:illIi~~/o,.~~!ill~J~j1~llil*!"-'~_iI ..: ..,,~ ~ '. -iIili!!llliiilllllli~ ~17~&tU% e I O;\Ip?,~.:?<i '01 A/it v3<9flrt. ~o. /".. D .J~t;1i ". '(1)1' a JQ6(*~(~ .... .. V '~W7!JIfJ..~. - I' - ~. - ~ = - ~- ." '~~,. - " . l...I.... I_~- -~~,..,y ~. ~-= """""01'.."...; , . PAUL J. COSTA, . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . . . . vs. . . NO. 00-2105 CIVIL TERM . . ANGELA ZAYDON COSTA, Defendant . . CIVIL ACTION - LAW CUSTODY . . PRIOR JUDGE: Edward E. Guido CUSTODY CXl\ICILIATICIiI SUMMARY REPCRT IN ACXXJIDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Sabrina Y. Costa April 25, 1992 Mother 2. A Conciliation Conference was held on May 25, 2000, with the following individuals in attendance: The Father's counsel, Jeanne' B. Costopoulos, Esquire, and the Mother, Angela Z. Costa, with her counsel, Maryann Murphy, Esquire. The Father, Paul J. Costa, is currently incarcerated in the Cumberland County Prison awaiting preliminary arraignment in connection with an incident involving this custody matter, and did not attend the Conference. 3. The Conciliator recommends an Order in the form as attached based upon the representations and agreement of counsel for both parties at the Conference. Date ~ (fu kJ€JrJ . jJM~ Dawn S. Sunday, Esquire Custody Conciliator '~