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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
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STATE OF
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STACIA M. FERRARI
Plaintiff
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THIERRY FERRARI
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Defendant
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DECREE
DIVORC..
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AND NOW, .... , ~ ~.1. ~l.. ,<?,1.... , .. ... " 19'"1.1.., it is orciered and
decreed that, " " ., " , " , s:r,~~~~, ,~~, FE,~RARI, , , , , , , ,., " " ", plaintiff,
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are divorced from the bonds of matrimony,
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The court retains jurisdiction of the following claims which have
been raised of record in this action for which a linal order has not yet
been entered;
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Stacia Ferrari
13 Front Street
Boiling Springs, PA 17007
Mar. 1996 - Jul. 1996
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Stacia Ferrari, Martha
Viniciski, Roy Viniciski
Rick Panebaker
11 Front Street
Boiling Springs, PA 17007
Aug. 1996 - Oct. 1996
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Stacia Ferrari, Michelle
Davenport
141 1/1 North Bedford Street
Carlisle, PA 17013
Nov. 1996
Thierry Ferrari
Room 412 Molly Pitcher Hotel
Carlisle, PA 17013
Dec. 1996 - Feb. 1997
Thierry Ferrari
Room 403 Molly Pitcher Hotel
Carlisle, PA 17013
Mar. 1997 - present
The mother of the children is STACIA M. FERRARI, currently residing at P.O. Box
192, 13 Front Street, Boiling Springs, Cumberland County, Pennsylvania, 17007 .
She is married.
The father of the children is THIERRY FERRARI, currently residing at Molly
Pitcher Hotel, Room 403, Carlisle, Cumberland County, Pennsylvania 17013.
He is married.
11. The relationship of the plaintiff to the child is that of mother. The plaintiff
resides with the following persons:
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Relationship
Martha Viniciski
Rick Panebaker
Mother
Son from prior relationship
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12. The relationship of defendant to the child is that of father. The defendant
currently resides with the following persons:
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Relationship
Monroe Ferrari
Son
13. 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,
Plaintiff has no information of a custody proceeding concerning the child pending
in a court of this Commonwealth.
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.
14. The best interest and permanent welfare of the child will be served by granting
the relief requested because:
a) Mother is willing to provide minor child with support, affection, and attention.
b) Mother is able to care for minor child during the day and, consequently, the
minor child would not need to remain in the care of a babysitter as is the current situation.
c) Mother resides with her mother in a safe, clean environment.
d) Father leaves minor child unattended in the fourth floor room at the Molly Pitcher
while he goes downstairs to make phone calls or to drink at a local bar.
IS. Each parent whose parental rights to the children have not bcen terminated and
the person who has physical custody of the children have bcen named as parties to this
action.
VERIFICATION
I verify that the statements made in this Complaint are true and correct to the best of
my personal knowledge and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. fi4904, relating to unsworn falsification to authorities.
Date: J..j. - / . J 99 ?
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Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
STACIA M. FERRARI,
v.
CIVIL ACTION - LAW
IN DIVORCE
THIERRY FERRARI
Defendant.
,
NO. 97- /'/11' CIVIL TERM
AFFIDAVIT SUPPORTING PETITION FOR LEAVE
TO PROCEED IN FORMA PAUPERIS
1. I am the Plaintiff in the above matter and because of my
financial condition am unable to pay the fees and costs of
prosecuting or defending the action or proceeding.
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: stacia M. Ferrari
Address: P.O. Box 192 Boiling Springs, PA 17007
social Security No.: 185-52-8664
(b) Employment
If you are presently employed, state
Employer: Flying J Travel Plaza
Address: Carlisle Pike, Carlisle, PA 17013
Salary or wages per month: $120.00
Type of work: maintenance
If you are presently unemployed, state
Date of last employment: N/A
Salary or wages per month: N/A
Type of work: N/A
(c) other income within the past twelve months
Business or profession: N/A
other self-employment: N/A
Interest: N/A
Dividends: N/A
Pension and annuities: N/A
Social security benefits: $447.00 per month
Support payments: N/A
Disability payments: N/A
Unemployment compensation and supplemental benefits: N/A
Workman's compensation: N/A
public Assistance: $74.00 food stamps
Other: N/A
(d) Other contributions to household support
(Wife) (Husband) Name: N/A
If your (wife) (husband) is employed, state
Employer: N/A
Salary or wages per month: N/A
Type of work: N/A
Contributions from children: N/A
contributions from parents: N/A
Other contributions: N/A
(e) property owned
Cash: N/A
Checking account: N/A
savings account: N/A
certificates of deposit: N/A
Real estate (including home): N/A
Motor vehicle: Make , Year
Cost , Amount Owed $ N/A
Stocks; bonds: N/A
Other: N/A
(f) Debts and obligations
Mortgage: N/A
Rent: $300.00 per month
Loans: N/A
Other: (itemize all other relevant monthly expenses such
as heat, electric, food, medical expenses,
transportation expenses, food not covered by
food stamps when client receives food stamps, etc..)
Transportation: $30.00;
Clothing: $60.00;
Personal necessities: $100.00;
Child care necessities: $40.00;
Food: $30.00
(g) Persons dependent upon you for support
(Wife)(Husband) Name: N/A
Children, if any: N/A
Name: N/A Age: N/A
Other persons: N/A
Name: N/A
Relationship: N/A
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.
p, 336 201 800
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STACIA M. FERRARI,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
: PENNSVLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
THIERRY FERRARI,
Defendant
NO. 97-1718 CIVIL TERM
WAIVER OF NOTICE OF INTENTION TO REOU~ST
ENTRY OF A DIVORCE DECREE UNJ[&B
~3301(ol OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce
without notice.
2. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
3. I understand that I will not be divorced until a divorce
decree is entered by the Court and that a copy of tho decree will
be sent to me immediately after it is flIed with the prothonotary.
I verify that the statements made in this affidavit are true
and correct. I understand that false statements herein ar.e made
subject to the penalties of 18 Pa.C.S. 54904 relating to unsworn
falsification to authorities.
Date:Jl\\~ ..q \ . ClJ
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Stacla Ferrar , Plaintiff
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STACIA M. FERRARI,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
THIERRY FERRARI,
Defendant
: NO. 97-1718
CIVIL TERM
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENIRy'..QE.tl..PJYQRCE.I>...f&F.JlliJ.!N1lli..~
mOl Cel OF TilE DIVORCE CODE
I. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divurced until a divorce decrce is entered by the Court
and that a copy of the decree will be sent to me immediately afte' it is filed with the
prothonotary .
I verify that the statements made in this affidavit are true and correct. 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:TIA I)' It. I r<J7
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Thierry Fe " Defendant
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STACIA H. FERRARI,
Plaintiff, Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
v.
THIERRY FERRARI,
Defendant, Respondent
NO. 97-1718
CIVIL TERM
ORDER FOR SPECIAL RELIEF
AND NOW, this
day of
, 1997, upon
consideration of the attached petition for special relief, it is
hearby ordered that Respondent shall be restrained from removing
minor child, MONROE FERRARI, from the Commonwealth of
Pennsylvania until the issue of child custody has been resolved.
By the court,
j.
STACIA H. FERRARI,
Plaintiff, Petitioner
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
THIERRY FERRARI
Defendant, Respondent
NO. 97-1718 CIVIL TERM
PETITION FOR SPECIAL RELIEF PURSUANT TO RULE 1915.13
Petitioner, STACIA M. FERRARI, by and through her attorneys,
the Family Law Clinic, petitions this court for special relief
pursuant to Pa.R.C.P. 1915.13 for an order prohibiting
Respondent, THIERRY FERRARI from taking the partieD' minor child,
MONROE FERRARI, outside of the Commonwealth of Pennsylvania until
the final disposition of this action, and avers in support
thereof as follows:
1. Petitioner, is the plaintiff in this matter and mother
of the subject minor child, Monroe Ferrari.
2. Respondent, is the defendant in this matter.
3. Minor child, is the subject of this petition and was
born on November 22, 1995.
4. Petitioner was the primary caretaker of the minor child
from birth until December 1996.
5. In December 1996, Petitioner asked Respondent to
temporarily care for the minor child.
6. Petitioner presently resides with her mother, Martha
Viniciski, at 11 Front street, Boiling Springs, Cumberland
County, Pennsylvania, 17007, and is able to care for the minor
child.
STACIA M. FERRARI, : IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
v. CIVIL ACTION - LAW
IN DIVORCE
THIERRY FERRARI .
.
Defendant NO. 97-1718 CIVIL TERM
CERTIFICATE OF SERVICE
I, Scott C. Gottel, Student Attorney, Family Law Clinic,
hereby certify that I have served a true and correct copy of
attached Petition for Special Relief on Defendant, Thierry
Ferrari, residing at Molly Pitcher Hotel, 13 South Hanover
street, Room 403, Carlisle, Cumberland County, Pennsylvania,
17013, by depositing a copy of the same in the united States
Mail, first class, postage prepaid, this
day of
, 1997.
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Plaintiff
:IN TIlE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
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:CIVIL ACTION - LAW
.
;NO. \ I \~ CIVIL
: CUSTODY /VISI-TATION
19q,
* Thi err,! te no.. i
Defendant
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ORDER OF' COURT
AND NOW, this (date) L.j/d~191, upon consideration of the
attached complaint, it is hereby directed that the parties and
their re~p~ctive counsel appear before J::-Dy.Jn~" ,"'f)~-~. ,
,the conc~hator, at 3q "-J, \-1("11" ,\.t__I"\.IT_mJeS __
on the ~'"\ day of ,t lD~ ,1 "1, at :
A. M., for: a Prehearing 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. Either
party may bring the child who is the subject of this custody
action to the conference, but the child/children's attendance is
not mandatory. Failure to appear at the conference 'may provide
grounds for entry of a tempqrary or permanent order.
FOR THE COURT:
BY:~~~Jj ihc~~tJl~'
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.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, FOURTH FLOOR
CARLISLE PA 17013
(717 )240-6200
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STACIA M. FERRARI,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
: CIVIL ACfION - LAW
: IN DIVORCE, CUSTODY
TIIlERRY FERRARI
Defendant.
: NO. 97-1718
CIVIL TERM
ORDER OF COURT
AND NOW, this day of , 1997, upon consideration of the attached
complaint, it is hereby directed that the parties and their respective counsel appear before,
, the conciliator, at , Cumberland County Courthouse,
on the day of , 1997, at m., for a Pre-Hearing Custody Conference. At
such conference, an effort witt 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. Either party may bring the child(ren) who is the subject of this custody action
to the conference, but the child/children's attendance is not mandatory. Failure to appear at the
conference may provide grounds for entry of a temporary or permanent order.
FOR THE COURT:
By:
Custody Conciliator
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.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, 4th Floor
CARLISLE, PA 17013
717/240-6200
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.
STACiA M. FERRARI,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE, CUSTODY
THIERRY FERRARI
Defendant.
: NO. 97-1718
CIVIL TERM
MOTION FOR CUSTODY CONCILIATOR PRE-HEARING CONFERENCE
The Plaintiff, Stacia M. Ferrari, by her allorneys, the Family law Clinic, moves the
court to schedule a Custody Conciliator Pre-Hearing Conference in accordance with Rule
1915.3-1(b) of the Court of Common Pleas of Cumberland County on the issues as brought in
count two of the attached divorce complaint.
Date ~/j2t/71
O&~Y-
THOMAS M. PLACE
Supervising Allorney
FAMILY LAW CLINIC
45 North Pill Street
Carlisle, PA 17013
(717) 243 2968
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.
.
STACIA M. FERRARI,
Plaintiff
: IN TIlE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
THIERRY FERRARI
Defendant.
.
.
: NO. 97-II}Ii"CIVIL TERM
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NOTICE TO DEFEND AND CLAIM RIGHTS
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You have been sued in court. If you wish to defend against the claims ~t forth:,in the ;'/
following pages, you must take prompt action. You are warned that if you fail to do so, the',:
case may proceed without you and a decree of divorce or annulment may be entered ag'iinst:,'
you by the court. A judgment may also be entered against you for any other claim or relief
requested in these papers by the plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available in
the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
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.
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.
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
717/240-6200
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STACIA M. FERRARI,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE
v.
THIERRY FERRARI,
Defendant
: NO. 97-
CIVIL TERM
COMPLAINT UNDER SECTIONS 330t(c) and 330Hdl OF THE DIVORCE CODE
The plaintiff, STACIA M. FERRARI, by her attorneys, the Family Law Clinic, sets
forth the following causes of action:
COUNT 1 - DIVORCE
II
1. Plaintiff is STACIA M. FERRARI, who currently resides at P.O. Box 192, ~
Front Street, Boiling Springs, Cumberland County, Pennsylvania, 17007, since March 2,
1997.
2. Defendant is THIERRY FERRARI, who currently resides at Molly Pitcher Hotel,
Room 403, Carlisle, Cumberland County, Pennsylvania, 17013.
3. Plaintiff and Defendant have been bona fide residents of Cumberland County and
the Commonwealth for at least six months immediately previous to the filing of this
Complaint.
4. The plaintiff and defendant were married on April 8, 1991 at Elkhorn, Wisconsin.
S. Plaintiff and defendant have lived separate and apart since March I, 1996.
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/ 6. There have been no prior actions of divoree or for annulment between the parties.
7. The marriage is irretrievably broken.
8. Plaintiff has been advised that counseling is available and that plaintiff or
defendant may have the right to request that the court require the parties to participate in
counseling.
COUNT II - CUSTODY
9. Paragraphs I through 9 of this Complaint are incorporated herein by reference as
though set forth in full.
10. Plaintiff seeks custody of the following children:
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Present Residence
Date of Birth
Monroe Ferrari
Molly Pitcher Hotel, Room 403
Carlisle, PA 17013
November 23, 1995
The child was not born out of wedlock.
The child is presently in the custody of THIERRY FERRARI who resides at Molly
Pitcher Hotel, Room 403, Carlisle, Cumberland County, Pennsylvania, 17013.
During the past live years, the child has resided with the following persons and at the
following addresses:
Persons
Addresses
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Stacia and Thierry
Ferrari
145 Lincoln SI.
Carlisle, PA 17013
Nov. 1995 - Jan. 1996
Stacia and Thierry
Ferrari
13 Front Street
Boiling Springs, P A 17007
Feb. 1996
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13. 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.
Plaintiff has no information of a custody proceeding concerning the child pending
in a court of this Commonwealth.
Plaintiff does not !mow 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.
14. The best interest and permanent welfare of the child will be served by granting
the relief requested because:
a) Mother is willing to provide minor child with support, affection, and attention.
b) Mother is able to care for minor child during the day and, consequently, the
minor child would not need to remain in the care of a babysitter as is the current situation.
c) Mother resides with her mother in a safe, clean environment.
d) Father leaves minor child unattended in the fourth floor room at the Molly Pitcher
while he goes downstairs to make phone calls or to drink at a local bar.
IS. 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.
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wHEREFORE, Plaintiff requests this Court to enter a decree of divorce dissolving
tl1C marriage, and grant custody of minor child to Plaintiff.
Dale 1///17
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JL~9-/-
THOMAS M. PLACE
ROBERT E. RAINS
KATHERINE C. PEARSON
Supervising Attorney
GAIL R. SHEARER
Stafr Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/240-5204
STACIA M. FERRARI, . IN THE COURT OF COOMON PLEAS OF
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Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
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vs. . NO. 97-1718 CIVIL TERM
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THIERRY FERRARI, . CIVIL ACTION - LAW
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Defendant . IN CUSTODY/VISITATION
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OODER OF CXXlRT
AND toI, this ~ day of --.1 ~t.
upon conaidet'ation of the attached Custody Concihation
ot'det'ed and dit'ected as follows:
, 1997,
Repot't, it is
1.
Fecrad, shall
23, 1995.
The Mothet', Stacia M. Fet't'ad, and the Fathet', Thiet'ty
have shat'ed legal custody of 110nt'oe Fet't'ad, bom Novembet'
2. The Mothet' and Fathet' shall altet'nate custody of the Child on
weekends beginning with the Mothet' having custody the weekend of June 7,
1997. The Fathet', s pedods of weekend custcdy shall begin on Satut'day at
10:00 a.m. and end on Sunday at 8:00 p.m., unless the Mothet' wot'ks on the
following Monday moming, in which case the Fathet' shall t'etain custody
until he t'etut'na the Child to the Mothet"s t'esidenco on his way to wot'k on
Monday at appt'oximately 3:00 p.m. The Mothet"s pet'iods of weekend custody
shall begin on Ft'iday at 3:00 p.m. (ot' befot'e if the Mothet' does not wOt'k
on Friday) and shall end on the Mothet"s next wot'k day when she shall
tt'anspot't the Child to the Fathet"s t'esidence at appt'oximately 7:30 a.m. on
hot' way to wot'k. In the event the Mothet' is scheduled to wot'k on a weekend
dut'ing which she would othet'Wise have custody undet' the altet'nating
schedule, the Fathet' shall have the oPpot'tunity to have custody of the
Child in het' place dut'ing that pet'iod.
3. Dut'ing the week, the Fathet' shall have custody of the Child
dut'ing the Mothet"s hout's of employment and the Mothet' shall have custody
of the Child dut'ing the Fathet"s hout's of employment and ovemight. On
weekdays, when the Mothet' wot'ks, the Mothet' shall tt'anspot't the Child to
the Fathet"s t'esidence on het' way to wot'k at appt'oximately 7:30 a.m. and
the Fathet' shall tt'anspot't the Child to the Mothet"s t'esidence on his way
to wot'k at appt'oximately 3:00 p.m. The Mothet' shall t'etain custody of the
Child on weekdays when she does not wot'k. In the event the Mothet' is
scheduled to wot'k on a weekend dudng which she would othet'Wise have
custody undet' the altet'nating schedule, the Fathet' shall have the
oppot'tunity to have custody of the Child in het' place dut'ing that pet'iod.
4. The t'egulat' weekly custody schedule shall begin with the
Fathet' tt'anspot'ting the Child to the Mothet"s t'esidence on Wednesday, June
4, 1997 at 3:00 p.m. on his way to wot'k.
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A. Christmas: In every year, the Father shall have custody of
the Child on Christmas Eve from 9:00 a.m. until 8:00 p.m. and
the Mother shall have custody of the Child from Christmas Eve
at 8:00 p.m. through Christmas Day.
B. Thanksgiving: The Mother shall have custody of the Child on
Thanksgiving Day in odd numbered years and the Father shall
have custody of the Child on Thanksgiving Day in even
ntlllbered years. The Thanksgiving holiday period of custody
shall begin at 9:00 a.m. and end at 8:00 p.m. on Thanksgiving
Day.
5. The parties shall shar.e or alternate custody of the Child on
holidays as follows:
C. Easter: The Mother shall have custody of the Child every
year on Easter Sunday from 9:00 a.m. until 8:00 p.m.
D. Memorial Day: The Father shall have custody of the Child
every year on Memorial Day from 9:00 a.m. until 8:00 p.m.
E. July 4th: The Mother shall have custody of the Child on July
4th in odd numbered years and the Father shall have custody
of the Child on July 4th in even numbered years. The July
4th holiday period of custody shall begin at 9:00 a.m. and
end after the fireworks if held on the holiday.
F. Labor Day: The Father shall have custody of the Child on
Labor Day in odd numbered years and the 110ther shall have
custody of the Child on Labor Day in even numbered years.
The Labor Day holiday shall begin at 9:00 a.m. and end at
8:00 p.m. on the holiday.
6. Each party shall be entitled to have custody of the Child for
two weeks (consecutive or nonconsecutive) during each year upon providing
two weeks advance notice to the other party. These periods of extended
custody shall be scheduled so as not to interfere with the holiday custody
schedule. The parties agree that, as part of his two week period of
custody under this provision, the Father shall have custody of the Child
from July 10, 1997 through July 16, 1997 for the purpose of taking the
Child to visit the Father's family in wisconsin.
7. Neither party shall remove the Child from the Commonwealth of
Pennsylvania for an overnight period or longer without the prior written
consent of the other party. For purposes of this provision, the Mother is
deemed to have provided sufficient consent for the Father to remove the
Child from Pennsylvania from July 10, 1997 through July 16, 1997, as
specified in paragraph 6.
8. This Order is entered pursuant to an agreement of the parties
at a Custody Conciliation Conference. The parties may modify the