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Home My WebLink About00-06952 I , I j, - --- , ,'~ - '" f"if,",', , DOMINIC J, SARAGO PLAINTIFF v. TINA J. STETI.ER DEFENDANT IN 1HE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-6952 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 16th day of October, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberlaud Couuty Courthouse, Carlisle on the 30th day of November , 2000, at 9:30 a.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 tempor:iuy 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: Isl Hubert X. Gilroy. Esq.1J5 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 HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FOR1H BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~ ~~ , ~ " - .. ~ ._,,~ '" (~r - 1 ,- ni') r1(' > ,h l.'\.. \1:._,[ ''''' n. """-", ,]. tv .. ","',:',." ,1:,_;-' C'("'J~~TV (.'>JlVit:;t.J-l:_f'~'; \~) '~~' I I PENi\jSYLV/\Nli\ )O-/v'CJtJ 4/ ~ ~ # ~ ~ .~e::' /1~ ~ d /t) ~.t1J# ~ ~ ~ -fI-.:&4 ~ 6f~ Ii I I I :'.~ , ~"~<, ~ , JM~~~4 "__IJlil.!~,l~ --""'~"-c>"" O~",,~"='''''''!.-'''''''_~~~1:.~ ~ft!!J!"1_IF,~~~t,~'(';1f"~'-:~!i""'~_:_"'"'_,^" ."_n~",: ' , "',,~' "'Mil" ~" " " '~ --I ,[ . ' ~,'~. ",,;., '- - "-!IIliftti'i~" DOMINIC J. SARAGO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff VS. No. 00- 1...9~ C,uJ Cy-~ TINA J. STETLER Defendant CIVIL ACTION -- CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before the conciliator, at on the day of , 19---, at ,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,,!1 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 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, 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 ASSOCIA nON LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 "'" ". , . , .j,""" ~. ,lilllilliliil.%y, , ' DOMINIC J. SARAGO . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff vs. No. C>o- G.9S.:L Cu.:J ~ TINA J. STETLER Defendant CIVIL ACTION -- CUSTODY COMPLAINT FOR CUSTODY AND COMES NOW, DOMINIC 1. SARAGO, by his attorney, Timothy 1. Colgan, Esq., and files the following Petition: 1. Plaintiff, DOMINIC J. SARAGO, resides at 640 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania since August 1997. 2. Defendant, TINA J. STETLER, resides at an unknown address in Dauphin County since September 2000. 3. Plaintiff and Defendant are the natural parents of two minor children, Breanna N. Sarago, d.o.b. 4/19/95, and AndreaM. Sarago, d.o.b. 1/9/98. 4. The children were born out of wedlock. 5. The children are presently in the care and custody of the Plaintiff 6. Since the birth of the children, the children resided with Plaintiff and Defendant at 329 South Washington Street, Mechanicsburg, Cumberland County, Pennsylvania from November 1994 to August 1997. From August 1997 until present, the children have resided with Plaintiff and Defendant at Plaintiff's address. 7. There are no court orders establishing custody or visitation. , ~-, , . lUI!ili#W#4; , . 8. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 9. 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. 10. The best interest and permanent welfare of the children will be served by granting the relief requested herein. WHEREFORE; Plaintiff requests the Court enter an Order granting primary physical custody and shared legal custody of the minor child to Plaintiff Dated: /0 -?-bo Respectfully submitted, li'~ Timothy 1. Co . uire WILEY, LENOX, COLGAN & MARZZACCO, P.C. 1 South Baltimore Street Dillsburg, PA 17019 (717) 432-9666 J.D. #77944 S:ICLlENTSICOLGAMSARAGOICOMPLAIN.WPD ~"- " . .~.;o-~:,,;. ,(~1lJ:i _Itid . . VERIFICATION I, DOMINIC J. SARAGO, verifY that the statements made in this document are true and correct to the best of my knowledge, information, 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: 10-3- .;lODO ~illti j~C/ Plaintiff S:ICLlENTSICOLGAMSARAGOICOMPLAlN.WPD 1 u ~-~~ ' - ~elOOiWlliWd . , IN THE COURT OF COMMON PLEAS YORK COUNTY PENNSYLVANIA DOMINIC J. SARAGO, Plaintiff * * NO. 00-6952 vs. * * * CIVIL ACTION - DIVORCE * TINA J. STETLER, * Defendant * AFFIDAVIT OF SERVICE I, Michele A. Reneker, being duIy sworn, deposes and says that she is an aduIt and that she served the Complaint for Custody with regard to the above-referenced matter to the defendant's last known address by both regular and restricted delivery, certified mail on November 9, 2000. The certified mail return receipt dated November 10, 2000 is attached hereto as Exhibit A. WILEY, LENOX & COLGAN, P.C. 77Z<<u,{J~ Michele A. Rene r By: 1 South Baltimore Street Dillsburg, PA 17019 (717) 432-9666 Date: November 14,2000 "'" c.. "-1-" I' ---.[.-" . . . ",- ., ",,',; ---~, , . ,-, "oj' ,0",--' . c-,,,< c u::. ){ I CER11f 'i' J "\~A"l IlE f u I, I (Domestic Mall Only: No 'I1SlJrfnce l.,.UV17'L'tI..... ~ ) .-'l rn .-'l I"- o Postage $ I"- ..n ...Q CertIfied Fee [J'"" Return Receipt Fee o (Endorsement Required) o Restricted Delivery Fee CJ (Endorsement Required) o Total Postage & Fees ru ru rn tr tr CJ I'- ""-,C ,'" ,.'_'.... . . Completelrems 1, 2, aml3. /!(lso-WlPplete item 4 if Restricted D~livery,1!aesired. . Print your name a~dressl5!nti. reverse , "~o JJiaj; _,w.e can return the card to you. '*_ ' Attach"'this card to the back of the mailpiece, or on the front if s~ace permits. 1. Article }\ttrlressed to: J;~;}'1t~~f~ rn (dd JefoWI1 /):J , /70S7 x D. Is delivery address different from item 1? If YES, enter delivery address below: o Agent D Addressee ' DYes o No t~, i?, 3. ~e~e Type )X'"certlfied Mail D Registered o Insured Mail o Express Mail o Return Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number (Copy from service labeO 7oc;,q ..:Je2ctJQ cooQ(P/P7C1 If/- '1/ PS Form SIl11 , July 1999 Domestic Return' Receipt 102595.0G-M-G952 """ I ^". @@:t; " Die i) 1 2ooobl) DOMINIC J. SARAGO, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TINA J. STETLER, Defendant NO. 2000 - 6952 CIVIL IN CUSTODY COURT ORDER AND NOW, this {,tv- day of ~ .2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Dominic 1. Sarago, and the Mother, Tina 1. Stetler, shall enjoy shared legal custody ofBreanna N. Sarago, born April 19, 1995; and Andrea M. Sarago, born January 9, 1998. 2. The Father shall enjoy primary physical custody of the minor children. 3. The Mother shall enjoy periods of temporary physical custody of the minor children at such times and under such circumstances as agreed to by the Father. 4. In the event the Mother is dissatisfied with the amount of temporary custody provided by the Father or in the event the Mother desires to in any way modify this Order, Mother may petition to have the case again scheduIed with the Custody Conciliator for a conference. 1. Tina J. Stetler 214 Nissley Street Middletown, P A 17057 t.rrp';(l) 4U IJ.-/'-OO 1?XS cc: Timothy J. Colgan, Esquire ~ Ii II il 'i II il Ii " I' ii ,il 'i !~ !~ :.'~. 11 !'l :'1 I !!l , :':! i I :::! " "'" .."",'"'' , ~ " l?'Wl~fl!lli' 3i!lF~ ~ r~('pl""~ ,'I r:\ \~<U(\ 1'.;J...~,....hr:l\J rl\ ,l<:-~";'_r;T,,,I\~~j\f"\.l"\l ,":\-1-\',:.,. .. ~" ".,' "'1:\ ':l ~r-~ ~).::J- ..... _ . t Ciu Gte - . ,_, "eN ,,__, .( hi"i\ \ C\JM6ER\)'J~~~'i*~1 PENN;:>\'" ';' .~ :",7-~"YJ/,__'~;,.~"7 ,_ i~~V J!f.il!'''1l'';>i':'.fJj.'<ffi';f~i'"1~~N,~W~_~_~~~M1i,f!!'-,'1>R~ - " I". , ,"" ",,--~--J' , )"....'""<Iliid~' ~,' ~ DOMINIC J. SARAGO, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIIVIL ACTION - LAW TINA 1. STETLER, Defendant NO. 2000 - 6952 CIVIL IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CML RULE OF PROCEDURE 1915 .3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Breanna N, Sarago, born April 19, 1995; and Andrea M. Sarago, born January 9, 1998. 2. A Conciliation Conference was held on November 30, 2000, with the following individuals in attendance: Timothy J. Colgan, Esquire, the attorney for the Father, Dominic J, Sarago. The Father did not appear and the Mother, Tina 1. Stetler, did not appear. Attorney Colgan indicated that Father has custody and Mother is no longer living with the children. In light of the fact that the parties did not appear and Attorney Colgan related to the Conciliator the current situation, the Conciliator recommends an Order in the form as attached. ~ DATE Hubert X. Gilroy, Esquire Custody Conciliator