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Home My WebLink About07-0763 MICHAEL L. SA V AGEAU, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL VANIA v. . : NO.: O^f - 1[1.3 C;,-,~CT~ ANA SA V AGEAU, Defendant CIVIL ACTION - LAW IN CUSTODY CUSTODY COMPLAINT AND NOW, comes the Plaintiff, Michael L. Savageau, by and through his attorney, Melanie L. Erb, Esquire and the law firm ofScaringi & Scaringi, P.C., who files this Custody Complaint and avers as follows: 1. Plaintiff, Michael L. Savageau, an adult individual, is the biological father of the subject minor children and is currently residing at 460 Sumner Road, Carlisle Barracks, Carlisle, Cumberland County, Pennsylvania. 2. Defendant, Ana Savageau, an adult individual, is the biological mother ofthe subject minor children and is currently residing at 110 E. Willow Street, Carlisle, Cumberland County, Pennsylvania. 3. The subject minor children are CHRISTOPHER SA V AGEAU, born March 28, 1992, and JESSICA SA V AGEAU, born December 1, 1998. 4. The children have resided in Cumberland County for a period of at least six months prior to this Complaint. 5. Plaintiff seeks partial physical custody and shared legal custody of the subject minor children. 6. The subject minor children were not born out of wedlock. 7. The subject minor children are presently in the physical custody of Mother, Ana Savageau, at 110 E. Willow Street, Carlisle, Pennsylvania, and have resided there since March 2005. During the children's life, the subject minor children have resided with the following persons and at the following addresses: ADDRESSES 110 E. Willow St. Carlisle, P A 17013 PERSONS Mother DATES January 29, 2007 - present 110 E. Willow St. Carlisle, PAl 7013 Mother Father March 2005 - Jan. 29, 2007 Fort Gordon Georgia Mother Father November 200l-March 2005 The Mother of the subject minor children is Ana Savageau, who is residing at 110 E. Willow Street, Carlisle, Cumberland County, Pennsylvania. She is married to the Father of the subject minor children. The Father of the subject minor children is Michael L. Savageau, who is residing at 460 Sumner Road, Carlisle Barracks, Carlisle, Cumberland County, Pennsylvania. He is married to the Mother of the subject minor children. 8. The relationship of the Plaintiff to the subject minor children is that of biological father. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP NONE 9. The relationship of the Defendant to the subject minor children is that of biological mother. The Defendant currently resides with the following persons: NAME Christopher Savageau Jessica Savageau RELATIONSHIP Son Daughter 10. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the subject minor children in this or another court. Plaintiff has no information of a custody proceeding concerning the subject minor children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceeding that has physical custody of the subject minor children or claims to have custody or visitation rights with respect to the subject minor children. 11. The best interest and permanent welfare of the subject minor children will be served by granting the relief requested because Mother has been and continues to be the primary caregiver for the minor children and the natural bond between mother and children should be preserved. 12. Each parent whose parental rights to the subject minor children have not been terminated and the person who has physical custody of the subject minor children have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the subject minor children will be given notice of the pendency of this action and the right to intervene: NONE WHEREFORE, PlaintitT, Michael L. Savageau, respectfully requests this Honorable Court to grant to Plaintiff partial physical custody and shared legal custody of the subject minor children. Respectfully submitted, M . rb, Esquire A orney LD. No. 84445 Scaringi & Scaringi, P.C. 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 (717) 657-7770 Attorney for Plaintiff VERIFICATION I, Michael L. Savageau, verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. S4904, relating to unsworn falsification to authorities. 7!J~ h J--~- .- Michael L. Savageau ~ I<b rUC<7-- 2=07 Date AJ (:) ~ ~ ~ ;j (..... ,....." ... j 0:;;.'::> ~:~ C~:) C~) . -- -...., D -~ '\ ........... ,.., Q \) "" t> c:.' '1 I \:) )J CO e;; f'- ~ -:;:1 C.) .. f :..1 .,,- .1 ~ C.) -,~-,.,. :J.., CO .< ~ .. #'....~ . MICHAEL L. SA V AGEAU PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V, 07-763 CIVIL ACTION LAW ANASAVAGEAU DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, February 16,2007 , upon consideration of the attached Complaint, it is hereby directed that patties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, March 16,2007 at 3:00 PM 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 entcr into a temporary ordcr. 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: Isl fohn.f. Mangan, Jr., Esq. pt/ 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 infonnation 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 HA VE 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 Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 -~~~~~~~ ~ ~ -:z ~. ~'"":? (t? <e'~ ~.j:-, r 72 ~ -~ _ ~ Cc?Qc>_C' - 1"'9 (c? - Oc-. (' \..<1 NV^lASNN3d 'i I r. '''t :"T,Q8IAlnD AiNnO.) :. ...... '.<, ~ 2 :E Wd 02 83.:1 LOOl " 'i"'ld :Jl-U. :10 Ab'V'lONUr-! u5;::n1:l 3al~jO- u:J I MICHAEL L. SA V AGEAU, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYL VANIA v. : NO.: 07-763 ANA SA V AGEAU, Defendant : CIVIL ACTION -LAW : IN CUSTODY PRAECIPE TO WITHDRAW COMPLAINT AND DISCONTINUE ACTION TO THE PROTHONOTARY: On February 8, 2007, the above-captioned Custody Complaint was filed with the Prothonotary's office, Cumberland County Courthouse, Carlisle, Pennsylvania. Kindly withdraw the said Custody Complaint and discontinue action. Respectfully submitted, Date: I PA I #84445 SCARINGI & SCARINGI, P.c. 2000 Linglestown Road, Suite 106 Harrisburg, P A 17110 (717) 657-7770 Attorney for Plaintiff ~ c:::> --' ..,., rn co N a:> -0 ::J: ~ -t :1;;:n n'L: -om. c:-O"'{ 2ql- -- , -';.....-n r',.o-)_ 'c__ (') >'::\11 o cc:;'; "PO ~ 0,) ., o c...J