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HomeMy WebLinkAbout01-1953 FX APR 0 5 lDD1tfJ TIMOTHY J. DeANGELO Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs : CIVIL DIVISION - LAW DANA M. DeANGELO Defendant : NO. 01-1953 CIVIL : IN CUSTODY ORDER OF COURT FOR SPECIAL RELIEF AND NOW, this _ day of April, 2001, it is ordered that the child Hunter Timothy DeAngelo shall remain in the marital household with the Father at 414 S. Pitt Street, Carlisle, P A, until order of court after conciliation conference. BY THE COURT: 1. c: John H, Broujos, Esquire Dana M. DeAngelo, Defendant F, , ' - ~ " ,,< I . APR 0 a 2001 fjJ TIMOTHY J. DeANGELO Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs : CIVIL DIVISION - LAW DANA M. DeANGELO Defendant : NO. 01-1953 CIVIL : IN CUSTODY ORDER OF COURT FOR SPECIAL RELIEF AND NOW, this ~ day of April, 2001, it is ordered that the child Hunter Timothy DeAngelo shall remain in the marital household with the Father at 414 S. Pitt Street, Carlisle, P A, until order of court after conciliation conference, BY THE COURT: J. c: John H. Broujos, Esquire Dana M. DeAngelo, Defendant ,'," " -. " ~- "-,~ " ""' 1,,,' . I "r, ,< . TIMOTHY J. DeANGELO Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs : CIVIL DIVISION - LAW DANA M. DeANGELO Defendant : NO. ol-I'1!)5 c..(VIl.--- : IN CUSTODY ORDER OF COURT FOR SPECIAL RELIEF AND NOW, this _ day of April, 200 I, it is ordered that the child Hunter Timothy DeAngelo shall remain in the marital household with the Father at 414 S. Pitt Street, Carlisle, P A, until order of court after conciliation conference. BY THE COURT: J. ,..JWW~ J. ~ , ," - "',' o .. TIMOTHY J. DeANGELO Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA YS : CIVIL DIVISION - LAW DANA M. DeANGELO Defendant : NO. 0)-1'1'03 G(VIL- : IN CUSTODY ORDER OF COURT FOR SPECIAL RELIEF AND NOW, this _ day of April, 2001, it is ordered that the child Hunter Timothy DeAngelo shall remain in the marital household with the Father at 414 S. Pitt Street, Carlisle, P A, until order of court after conciliation conference, BY THE COURT: 1. "~ .~ 1,;'- r. "I - II 'r I" -~ . TIMOTHY J. DeANGELO Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs CIVIL DIVISION - LAW ; NO. 01- 19.r0 CIO~ L I~ : IN CUSTODY DANA M. DeANGELO Defendant ORDER OF COURT AND NOW, this _ day of ,2001, it is hereby directed that the parties and their respective counsel appear before , Conciliator, at ,PA , on the_day of ,2001, at o'clock _,m., for a Pre-hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this carmot 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'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. CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 ;-'~ llllf "! ., ~ ".. .....".., I< '" . -I" ~ " " . .' (.. 't~~.-."t ," .... .n;''f-f1':f_!rtf'l'!fl''', TIMOTHY J. DeANGELO Plaintiff t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs CIVJlL DIVISION - LAW : NO. 01- IC;S..3 C./~: l DANA M. DeANGELO Defendant : IN CUSTODY ORDER OF COURT AND NOW, this _ day of , 2001, it is hereby directed that the parties and their respective counsel appear before , Conciliator, at ,PA o'clock _,m., , on the _ day of ,2001,at for a Pre-hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this carmot 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'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. CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA /7013 (717) 249-3166 \,,', f , I{'~ . ,-"f_~ - I~ , .. . TIMOTHY J. DeANGELO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs : CIVIL DIVISION - LAW DANA M. DeANGELO Defendant : NO. 0 1- \ ~ 3 : IN CUSTODY NOTICE You have been sued in Court, If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are wamed that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff, You may lose money or property or other rights important to you, 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 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 <"""""., ^~- II" , , . . i TIMOTHY J. DeANGELO Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs : CIVIL DIVISION - LAW DANA M. DeANGELO Defendant : NO. : IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, by and through his attorney John H, Broujos ofBroujos & Gilroy, P.C., and avers as follows: 1. Plaintiff is Timothy J, DeAngelo an adult individual residing at 414 S, Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Dana M. DeAngelo an adult individual residing at 414 S, Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks custody of the child Hunter Timothy DeAngelo residing at 414 S, Pitt Street, Cumberland County, Pennsylvania 17013. . Hunter DeAngelo was born August 28,1996, . The Child was not born out of wedlock. . The Child is presently in the shared custody of Plaintiff and Defendant at their residence at 414 S, Pitt Street, Carlisle, Cumberland County, Pennsylvania, . During the past four years, the Child has resided with the following persons and at the following addresses: Person Address Dates Both parents Both parents State College, P A 414 S. Pitt St., Carlisle, PA 17103 August 28, 1996 - May, 1997 May, 1997 - present '"'W'''~"-'''''j'',,,_,, 1.1-r -""'"!""I . ,~ . The Mother of the Child is DanaM. DeAngelo currently residing at 414 S, Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013, . Plaintiff and Defendant were married June 15, 1996 at Carlisle, Pennsylvania. . The Father of the Child is Timothy 1. DeAngelo, currently residing at 414 S, Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 4. The relationship of Plaintiff to the Child is that of Father, 5. The relationship of Defendant to the Child is that of Mother. 6. The 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. 7. Plaintiff has no information of a custody proceeding concerning the Child pending in a Court of this Commonwealth. 8. 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 of visitation rights with respect to the Child, 9. Each parent who has parental rights to the Child which have not been terminated and the person who has physical custody of the Child are parties to the action, 10. The best interest and permanent welfare of the Child will be served by granting to Plaintiff primary physical custody of the Child. 11, For no reason, Defendant has threatened to move from the marital home and to take the child with her. Defendant has increasingly remained away from the house for long periods of time, unaccounted for, particularly in the evenings. "'i""'l~Pl~ ""', " ,~ I' , ,-. . WHEREFORE, Plaintiff requests this Court: to grant custody of the Child to Plaintiff. John ,Broujos, EIre ey for Plaintiff BROUJOS & GILROY, P,C. 4 North Hanover Street Carlisle, Pennsylvania 17013 717/243-4574; 717/766-1690 FAX# 717/243-8227 Date: April4, 2001 ..''',,,,,[,,,,,,,,,>,,,,>~- ~,...- ~" ~" 1." - ~ e,', I , I ~ I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. Date: ~~:> '...... '.:. . ,.,,,,,-,,,,,,,,,,,,"""'~-~ "1 I u, ~_". ~~1ffilf'1!Im;~l,~ '""' -- -, '''~*'" ~-., ~,~ ,~~~ .~.~~ ." CJ ;E1OI "'<:) .-.::1 ;:,' c...:' r:- ....J ~ 1~!Q'~~~'~!!~-f!:t~W.""~'-'01;f{'-"'~"-'-'-""i'-T-;''i\l'''':'''''')(''''''~-:lW'ji?-~~~~!lffl>,lii,,~,JM'f""';1'~4Il'1fIi!ilI!Il'lll;I~~~ ~ o c: <:--'" ~l~; ~~C: ___~ ( r >~~ -.- =< TThJOTHYJ.DEANGELO PLAINTIFF V. DANA M. DEANGELO DEFENDANT IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-1953 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, April 05, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cnmberland County Courthouse, Carlisle on Wednesday, April 25, 2001 at 3:30 p.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 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 Abnse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled heariug. FOR THE COURT, By: Isl Jacqueline M. Verney. Esq,b'7 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 TIllS 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 FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 .. ,.' \'. '-., <',- - -~ ~,~I.--~ ~'I -rf ~(l ~ _~~"w.v>f(l! _.,,1l!l'll'llml1Mlll ~ ~-" '.-,' > ~~~ ~ ~ ~U-, l' ~~-n \/''''''l'S'I'I-'...I . i:\~V/\ ,1\, ! '.'\::h... ~! \)n(l"') ('""1\ ",j'--I;--'::2:/lf1'"') J ""e' \:.. ',--",," _ __ .." ~ ",_ i C:6 ('; '.'["/11-' ..' v_'> '"',~ 'iI- " ! .,' ',""'~' ',,-, -1-'1 :'-.J'. ,J .~,~~, ",~~.,-" ,~ /Cl - 1/ f; lo-Pj-/; /rJ-1J '/1 ~ _"!I!~;'!II'f'$!l"""H""I""'''fO,-,,,,~,,,-,,O'"'''''''''''"1'_''W-'!Il;1'~~~J!1I!~_",;-'"'w"r""'lf;\""l11~I';llllJ!l!!f!'lllfJ"!-l!t1iIllhl""F' F:\FILES\DA T AFILE\Gendoc,cur\ I 0312-pra,2/tde Created: 04/09/0110:51:55AM R,vised: 04/09i'l1111:10:08AM ~ TIMOTHY J, DeANGELO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-1953 CNIL ACTION - LAW DANA M, DeANGELO, Defendant IN CUSTODY PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTS ON DEARDORFF WILLIAMS & OTTO on behalf of Defendant in the above matter. MARTS ON DEARDORFF WILLIAMS & OTTO By t~~~ \fVJl~t'- Thomas J. Willi , Esqmre Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant Dana M. DeAngelo Dated: April9, 2001 :- ,"'= ~ ,,"-"'" If 1 '''I ~ 'I I, ~-~. I( ~,:f.?,. '<-;,,:;:, , \ :; . ,"~ .. CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certifY that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: John H, Broujos, Esquire BROUJOS & GILROY, P.C. 4 North Hanover Street Carlisle,PA 17013 MARTSON DEARDORFF WILLIAMS & OTTO ~eE1d' ~ Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: April9, 2001 I' 11 ~~ ;,~ '.~~ !lIWI!III~ -~"' ___e ~ .o~' ~~ = "~ " .. "I ~! ~ J~ m"",!~I~~61i16_'~"'!""f..~~~I~?"'''';l''''~!'''''''''i*H~lf''_f~~'!;I:!II>lI~~~~~'_~_'!n!MOO!imrl!-f~liIIlif'l1' F: \FILBS\DA T AFILE\Gendoc.cur\10312-ans.2 Created: 04109/01 10:50:00 AM Revised: 04/0"'01 11:15:21 AM TIMOTHY 1. DeANGELO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-1953 CIVIL ACTION - LAW DANA M. DeANGELO, Defendant IN CUSTODY DEFENDANT'S ANSWER TO PETITION FOR SPECIAL RELIEF AND NOW, comes the Defendant, Dana M. DeAngelo (hereinafter "Mother"), by and through her attorneys, MARTS ON DEARDORFF WILLIAMS & OTTO, and answers Plaintiffs Petition for Special Relief as follows: 1-3. Admitted, 4-5. Denied that Mother has threatened to take the child and move from the marital household; however, the parties are divorcing and eventually wi1llive separately, so a decision regarding custody of the child will have to be made. The balance of the averments are admitted. WHEREFORE, Defendant requests Your Honorable Court to deny Plaintiffs Request for Special Relief. Date: April 9, 2001 MARTS ON DEARDORFF WILLIAMS & OTTO By -rL;d WJLo~i"'" Thomas J, Willi , EsqUlre Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Defendant Dana DeAngelo --:'~:~~1"'-"' ,..,~ , 1,r,;r '"'1r~"""!"~1 I! 1 I . ~,. VERIFICATION The foregoing Answer to Request for Special Relief is based upon information which has been gathered by my counsel in the preparation ofthe lawsuit. The language ofthe document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties ofl8 Pa, C.S, Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. 97~ 9}O~fk Dana DeAngelo / ;~~( 1'":',,-. - ~-- I I", CERTIFICATE OF SERVICE I, Tricia D, Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Answer to Petition for Special Relief of Defendant was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: John H. Broujos, Esquire BROUJOS & GILROY, p,e. 4 North Hanover Street Carlisle, P A 17013 MARTS ON DEARDORFF WILLIAMS & OTTO CS1i;iie[J. ~~ Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: April9, 2001 ''''''.1 ;,;1 -';'.~.....~ w _ I" ,- ,! ',~ '1""1- ,- , ., '..~~~'~ -..... ~"'411"'", ~ ~",~ ~, ~I"""'i'" ~_V~"' '~,_ ~ ~ CJ (::1 () C -q '- 7;:C'> --I -;"J ~~ -) ITI -- -:-:') -7 ;~ , - . ~~ " c:) ,- .....-, :-i; _. '-,;-- . :)> C__, r.~.) ,---;; .,;,. ::;2 :::) :.D C..) -< f1: '_~!'T'_ ., ,~.,~!,~,"_,~"-W"jj,!,H""~l"':'\"-~:"n-,'4;14IP~-f"!Vjl~_~~OI~!lI:\!!!iWllf1,~!;;~~t~~ ~>~'" 7172431807 MD\~O PAGE 03/U.j F:\flLl!S\D^i^,llJj\~c!<<.(.W'.I031~.~ti, l:tdf. Cr~l:.d: (WQ9l011Q'l;'~AM R",-iJ;~d. ~4iO! 08:05:I~ AM o . TIMOTHY J. DeANGELO, Plaintiff DI THE COURT OF CQMMON PLEAS OF CuMBERLAND COUNTY,PENNSYLV AJ\TJA v. NO, 01-1953 CML ACTION. LAW DANA M, DeANGELO, Defendant IN CUSTODY STIPULATION FOR CUSTODY AND NOW, comes the parties, Timothy J. DeAngelo and Dana M. DeAngelo, who hereby stipulate and agree as follows: I. The parties shall share equally the legal and physical custody oftbe child, Hunter T. DeAngelo, bomAugust 28.1996. Z Father has custody ofHumer from Saturday at 3:00 p.m. until 8:00 p.m, 011 Tuesday, except that every othClr week Father's c\lstody shall end on Wednesday rooming at the start of day care. 3, MotileI' has custody ofRunter from Tuesday at 8 :00 p.m. until 3 :00 p,m. on Sat>.miay. except that every other week Mother's custody shall start on W <!:<!nesday after day care. 4. It is the intention of the parties in dividing ClIstody that each will have half ofthe total custody, be.lug seven out of every fourteen days. by alternating weeks so that each parent has three days of physical custody one week and four days the next 5. Transportation shall be divided equally, In the absence of an agreement to the contrary, the parent having custody will transport the child to the other parent. 6. The parties request the court to enter an order in accordance with this stipulation WL linO~~~ Timothy. All . @n111 fl, f), ~1.~ Dana M. DeAngelo d' W.lL-, , ", ~ , 0 '" -.. - . IllIlR'IiI!MilJ~>~~.-"._<r;l)TW;li!!llW"~"IliI>'~t"Ii!iII/1,',..~~'f1'e""'-""""'W:'f~"'"- "'r:'",',- ~ (') 0 0 c: "f1 :-:;: "" --'. -ot.e' " ~rj;Q mE' Xi Z.J" f' '. ,-. zr" .' ~(J:i:':) , ~~2 -, '~(=) f<C .. .-t-,''T, "'c "'::r-"'i'l ...;.',", .. -J ~_. z....:! 68 >i:! r:-::) -" Z <...' ~> =< :b c..:> -< 1E"("""'" , .,./: h/EL APR 2 5 2001 ~~ n\"v M-"~',-U'Ii'C,~T'Hji-\"'",""'.'V'l'n"'N1'!"r~'>"~-"',1"I"'"mJl!!!t~-lQ~~~fl;<' .-,..- ..-)> "-''',,- }r," F:\FILES\DATAFILE\Gendoc.cur\I0312-ord,lItde Created: 04/2410109:15:14AM ~evised: 04/2'S/OI03:13:43PM t TIMOTHY 1. DeANGELO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-1953 CIVIL ACTION - LAW DANA M. DeANGELO, Defendant IN CUSTODY ORDER , AND NOW, this ~... day of ~, 2001, upon consideration of the attached Stipuluation, it is hereby Ordered and Directed that the parties shall share physical and legal custody of the parties' son, Hunter T. DeAngelo, born August 28, 1996, as follows: 1. The parties shall share equally legal and physical custody of the child, Hunter T. DeAngelo, born August 28, 1996, 2. Father has custody of Hunter from Saturday at 3:00 p.m. until 8:00 p.m,on Tuesday, except that every other week Father's custody shall end on Wednesday morning at the start of day care, 3, Mother has custody of Hunter from Tuesday at 8 :00 p.m. unti13 :00 p.m, on Saturday, except that every other week Mother's custody shall start on Wednesday after day care. 4. It is the intention of the parties in dividing custody that each will have half of the total custody, being seven out of every fourteen days, by alternating weeks so that each parent has three days of physical custody one week and four days the next. 5. Transportation shall be divided equally. In the absence of an agreement to the contrary, the parent having custody will transport the child to the other parent. ,1. ~ ~ ~.()\ \.;~.o o ~ < I:" '1-""'" I,! ~~~=~~~ ~ ~. ,~ ' ~..._,"''''','' -~>' ,','_,^', '" ",~"_M"_~'" _~<" ",'".,,_"W'-',,",~'" ,~ -"~'~-"""'.;<C.;-."" ~,,'~', ,,--~,,',,,~"=~ .."~ ~~ II f VINVAlASNN3d ALNnOCI Of~\fltEJ8f"lno 01 :8 h'V ;l-A~~~IO II',""",,, ' \ ,I n-., ,', ,0'1_,.....,. ,,-, ::0 nIT. ~,~~ ".."..~~,~ , IR_m":I!iflJ~",,!,q_,,, ~ 1 n _iBfilffi!'~f!l'''M<'\I-'''tn;jw~~<~~R,'!dc~'f~';f~.~~I!fiQ~~~~. ~~~'7"'~~"r;',':,,", ^_ J)ij~JJI ~ TIMOTHY J. DeANGELO, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs CIVIL DIVISION - LAW DANA M. DeANGELO Defendant : NO. : IN CUSTODY NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are wamed that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you, 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, PENNSYLVANIA 17013 (717) 249-3166 ,,-;:.!~ , '"" "~Ihr' T_ . TIMOTHY J. DeANGELO Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs : CIVIL DIVISION - LAW : NO. 0/- /9:,3 (!wJ. -r~ DANA M. DeANGELO Defendant : IN CUSTODY c:- C,'" '--' "".. COMPLAINT FOR CUSTODY \_,' AND NOW, comes the Plaintiff, by and through his attorney John H. Broujos ofB~~~jos &. _"'-i' Gilroy, P,C., and avers as follows: '.) -< 1. Plaintiff is Timothy 1. DeAngelo an adult individual residing at 414 S. Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Dana M. DeAngelo an adult individual residing at 414 S. Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks custody of the child Hunter Timothy DeAngelo residing at 414 S, Pitt Street, Cumberland County, Pennsylvania 17013, . Hunter DeAngelo was born August 28, 1996, The Child was not born out of wedlock. . The Child is presently in the shared custody of Plaintiff and Defendant at their residence at 414 S. Pitt Street, Carlisle, Cumberland County, Pennsylvania. . During the past four years, the Child has resided with the following persons and at the following addresses: Person Address Dates Both parents Both parents State College, P A 414 S. Pitt St., Carlisle, PA 17103 August 28, 1996 - May, 1997 May, 1997 -present -'''C<<''f-''-"""""",,"''~ ,,,,", ..~I"~_, e~ . . . The Mother of the Child is Dana M, DeAngelo currently residing at 414 S. Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. . Plaintiff and Defendant were married June 15, 1996 at Carlisle, Pennsylvania. . The Father of the Child is Timothy J. DeAngelo, currently residing at 414 S. Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 4. The relationship of Plaintiff to the Child is that of Father. 5, The relationship of Defendant to the Child is that of Mother, 6. The 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. 7. Plaintiff has no information of a custody proceeding concerning the Child pending in a Court of this Commonwealth, 8. 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 of visitation rights with respect to the Child, 9. Each parent who has parental rights to the Child which have not been terminated and the person who has physical custody of the Child are parties to the action. 10, The best interest and permanent welfare of the Child will be served by granting to Plaintiff primary physical custody of the Child, 11. For no reason, Defendant has threatened to move from the marital home and to take the child with her. Defendant has increasingly remained away from the house for long periods of time, unaccounted for, particularly in the evenings, , )"""""f"f-""",,,,~~~" . WHEREFORE, Plaintiff requests this Court to grant custody ofthe Child to Plaintiff, , Broujos, E ey for Plaintiff BROUJOS & GILROY, P.C, 4 North Hanover Street Carlisle, Pennsylvania 17013 717/243-4574; 717/766-1690 FAX# 717 i243-8227 Date: April 4, 2001 :;:~~"!?'I' ~ '. .' '-- I T-! 'I .. . I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. Date: ~~.~ " .. ~ TIMOTHY J. DeANGELO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs : CIVIL DIVISION - LAW DANA M. DeANGELO Defendant NO. 01-1953 CIVIL IN CUSTODY REQUEST FOR SPECIAL RELIEF AND NOW, comes the Plaintiff, by and through his attorney John H. Broujos ofBroujos & Gilroy, P .C" and avers as follows, in relation to the Complaint for Custody filed April 3, 2001: 1, Plaintiff is Timothy 1. DeAngelo an adult individual residing at 414 S. Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 2, Defendant is Dana M. DeAngelo an adult individual residing at 414 S. Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks custody of the child Hunter Timothy DeAngelo residing at 414 S. Pitt Street, Cumberland County, Pennsylvania 17013. 4, Since the parties live in the same household and since Defendant has threatened to take the child and move from the marital household, Plaintiff requests the Court to maintain the status quo by directing that the Child remain with the Father in the marital household, where the Mother resides now, at 414 S, Pitt Street until conciliation conference and order of court. !~"'~~""~- ,. ,[ 1_'" o. . ~ 5. Otherwise, either party could upset the status quo by taking the child and moving to another location, county, or state. Plaintiff seeks only to keep the child in the household where both parents live now, because of the threat of Mother to move and take the child. WHEREFORE, Plaintiff requests this special relief. Re.spectfull.}:bmi:tted' ~) ,\i. .' ~/' H. BrouJos, EsqUIre Attorney for Plaintiff BROUJOS & GILROY, P,C. 4 North Hanover Street Carlisle, Pennsylvania 17013 717/243-4574; 717/766-1690 FAX# 717/243-8227 Date: April 4, 2001 'j!'~"'-::~",I' ,. ~,~'.... aL~ IF ^n, . . I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. Date: 17 (U-,-( '-f, '2.-0"'1 ~~~ , (-# -.'.:"""""'t"~""'%1I~~, ,~ '.~ .~,.~. ~~ ,~ zV "" '~~,. '".~~, '''A' ~~ ~ - ~ 'N_""W.'_'~^' "'~~" .- 0 (::::J {~ ~ ~ ~ ~ .~ ;; ~~; :~ '^, "U ;::z; ~ ~ -- I C"-) -- -,. ~. (S ~ -<" -{. C:.: I::: 'C .J:::' '"'"" i~8 ~ <;- ~ ::< -~ ......... -0 -<: oc- t :) ~ (<>. 0- _~""'_I!Jlll_~~ ;',~~I'!IlI~[f!I~'IW*\lI1l!i'~'('-~"*'_"~E%'-'~'""!i'i-"--;""",,n'__'c';",_:",,'-;"'i'),''!'',w1,~,,''''1'''!'''''';wrn;~;:ll'~'-f~;I''r1''ffl'':'!~"i''':iI'1'~''_1<l'I!l'l'~~'!_~!J!f\li(.!ll TIMOTHY J. DeANGELO, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs CIVIL DIVISION - LAW IN CUSTODY o !f ~D z :;! ,.,. -'(;I ;:;C) I c) DANA M. DeANGELO NO. 01-1953 CIVIL Defendant .r:- () :~ -,,," -'''' . "T, REQUEST FOR SPECIAL RELIEF ~:,;?~~ ;jr-"1 ~ ..,.. AND NOW, comes the Plaintiff, by and through his attorney John H, Broujos ofBroujos & Gilroy, P.C., and avers as follows, in relation to the Complaint for Custody filed April 3, 2001: 1. Plaintiff is Timothy J. DeAngelo an adult individual residing at 414 S. Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013, 2, Defendant is Dana M, DeAngelo an adult individual residing at 414 S, Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 3, Plaintiff seeks custody of the child Hunter Timothy DeAngelo residing at 414 S. Pitt Street, Cumberland County, Pennsylvania 17013. 4, Since the parties live in the same household and since Defendant has threatened to take the child and move from the marital household, Plaintiff requests the Court to maintain the status quo by directing that the Child remain with the Father in the marital household, where the Mother resides now, at 414 S. Pitt Street until conciliation conference and order of court. --~I""""1,...".,.,~"""c__,",,,_~". ~ . ~ "-~''''"'I' ~ , - ~~'~I ,,~ , , -=""-- 5, Otherwise, either party could upset the status quo by taking the child and moving to another location, county, or state, Plaintiff seeks only to keep the child in the household where both parents live now, because of the threat of Mother to move and take the child, WHEREFORE, Plaintiff requests this special relief, Respectfully srbmi \\ ',~ ' \i , , H, Broujos, EsqUIre Attorney for Plaintiff BROUJOS & GILROY, P,C. 4 North Hanover Street Carlisle, Pennsylvania 17013 717/243-4574; 717/766-1690 FAX# 717/243-8227 Date: April4, 2001 ,~ 1 ""r=" , _ '-f"" ~_, I'r'~._" " - - r verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. Date: Apr,'r '-f, 1.-00( ~~/ -","f~"';~l'''''''''''''''''I''''' ~~ 1.-'1 ~ . , , / t'-,\ /',' '. 't,.,. , TIMOTHY DeANGELO, Plaintiff __,,!-7.- . JUN 2 820~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL VANIA V. : NO.2001-1953 CIVIL TERM DANA M. DeANGELO, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 28th day of June, 2001, the Conciliator being notified that the parties have reached an agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, ~.u ody Conciliator '7,1Wt<l!l'~,"""",",,, 11'-' "I , r -