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Home My WebLink About01-06577 , . ""-~ - ~" i _ ,., - -0 """,-.. '~;M;'H;"6<:'LqN'i; CELESTA SABATINO PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V. 01-6577 CIVIL ACTION LAW MARCUS S. SABATINO DEFENDANT IN CUSTODY ORDER OF COllRT AND NOW, Wednesday, December 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 4tb Floor, Cumberland County Courthouse, Carlisle on Tuesday, January 08, 2002 at 8:30 AM 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 Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Jacqueline M. Verney. Esq. (S)'VI 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 FORTH 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 ,,=~,-, 'c_,,,,''''--'''_''_'''''' _ "~~,,,-,' -. .. 01 nr:r .-' 1..,11....,.. J cu',',<.'.. '. 'lV:O"::'i-:Lf-i'-i'-' '-'f\i :I,r;-'\/ D' ,;,L -,..j ll.....'U '.J! I t cl\l~,ylYNJil\ 'I: ','lQ ~.,~ >" I .. /dl.b'(11 /.,;J -S . tJ I I,:) :f'-o/ w' ~,~ It 4' fi4 71~~~' ~. ~~~ %a? ~ ',JiI!llIU gfjj~"~~-~I~~~'~ ,__,,~~'F/f'~"~ _ ~~\ft~lM~J1f~BiRf,':l'j;'j;1,,"':",",~r':!l'-;;"''':;'<- ,1,,"~_'_"W'O':!;_~j', . --~";~';'~\;!'"-'!""1.",m,",I;;;:'*W#-P-'\'11NtJ~;i~1*~~::fI.i~-= t - -.---,. ,~~- ,-- , I. .-"---",-~,~,",-,, '."-'~;ji&!: , ' . , CELESTA SABATINO, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-&5+1 CIVIL TERM MARCUS S. SABATINO, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this day of , 2001 upon consideration of the attached Petition it is hereby directed that the parties and their respective counsel appear before Esquire, the conciliator, at , Pennsylvania, 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 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 entry of a temporary or permanent order. FOR THE COURT: By: Custody Conciliator YOU SHOULD TAKE TillS 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 HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 1-800-990-9108 ;;:a:: "~ ~."='" - I" "' )',- '''~\lritK . ' " . CELESTA SABATINO, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 200l-~6'77 CIVIL TERM MARCUS S. SABATINO, Defendant : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Celesta Sabatino, an adult individual currently residing at 8 Dogwood Court, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Marcus S. Sabatino, an adult individual currently residing at 8 Dogwood Court, Camp Hill, Cumberland County, Pennsylvania 17011; however he is planning to move to a different residence within Cumberland County in the near future. 3. The Plaintiff is the natural Mother of the child, Deanne Noel Sabatino, born December 23, 1987. 4. The child was born in wedlock. 5. For the past five years, the child has resided with the following persons at the following addresses for the following lengths of time: NAMF Celesta Sabatino Marcus Sabatino Derek Sabatino (brother) ADDRFSS 8 Dogwood Court Newville, PA , DATFS 1995 to present 6. The natural Mother of the child is the Plaintiff, who resides as foresaid. She is married. 7. The natural Father of the child is the Defendant, who resides as foresaid. He is married. ., .' ~o. _, ~ ".'._ ~~_ _ ~,., <_A ~- . H. '.-"'"'...~ "~- ' , j , ,'- ~~,'-,- ,. ~ "'ijiii1J1'tliiflilif,,; 8. The relationship of the Defendant to the child is that of natural Father. The Defendant currently resides with the Plaintiff, the child at issue, and Derek Sabatino, the parties' adult son. 9. The relationship of the Plaintiff to the child is that of natural Mother. The Plaintiff currently resides with the Defendant, the child at issue, and Derek Sabatino, the parties' adult son. 10. The Plaintiff has no information of a custody proceeding concerning the child pending in any Court of this Cormnonwealth. 11. The best interest and permanent welfare of the child will be best served by granting the relief requested as the Plaintiff is better suited to provide a stable envirorunent to foster the child's well being. 12. The Plaintiff does not know of any person not a party to the proceedings who claims to have custody or visitation rights with respect to the child. WHEREFORE, the Plaintiff, Celesta Sabatino, respectfully requests this Honorable Court to enter an Order scheduling the Parties for a Custody Conciliation. Respectfully submitted, /1 ~ ';;;.1-0/ Date: co/-v Thomas S. Diehl, Esquire Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 ~,: "'~ . -........i I., 1 -, -....~ ~~-; " VERIFICATION I verifY that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 9 4904, relating to unsworn falsification to authorities. ~+~~ CELESTA SABATINO, Plaintiff ~~~11 ';~~JMl~~~~.'gk"F?M'~.'iW>~.!h;_;).k~JiL:::il"d-;i!;' '\f,"t\*S~\!i!t~W.Jt~~_~!ii!t!ll!l.~"i<!ltii;\i:~;'-." ~ j~u_fC!,:tiM(ij_t!~~~ -: ,. U"d'. ., U 1:- ~ f\ -p ~ (') C, (~) ~ t c -n ~~: ~~ :..;~! l')CJ CJ n'!j:"i ,~ - , Z;),' .'-- "i;:';';;; ::1) V, ZC-' ,'-> rn ........ (j) j-"' C'~ ~ C> -<::?< <, r' C) ~ ~~~ v ~j~7~ w ~ =" ~7t5 W >C: I)i' Om ::z .:.n ~ =< 55 CD -< " . -" " .. '". __ _ _~_, ~__, _,.,..,~-' ",~_-".__,,"-, ''';'~='_''"~_~_,_w"."",~"." MISLlTSKY AND DII:;HL. NOV 2 8 200] if THOMAS S. DIEHL RICHARD P. MISLlTSKY* ONE WEST HIGH STREET SUITE 208 P.o. Box 1290 CARLISLE, PENNSYLVANIA 17013 (717) 240-0833 KIMBERLY L. HOUGH LEGAL ASSISTANT 14 NORTH MAIN STREET SUITE 550 CHAMBERSBURG, PENNSYLVANIA 17201 (717) 261-0208 REPLY TO: CARLISLE (717) 240-0893 - FACSIMILE FILE No. 01258 November 21, 2001 Terren Dickson Court Administrator's Office Cumberland County Courthouse One Courthouse Square, 3rd Floor Carlisle, P A 17013 RE: Celesta Sabatino v. Marcus S. Sabatino In Custody Scheduling of Custody Conciliation Conference Dear Terren: On November 21, 2001, I filed a Complaint in Custody for the above-captioned matter, however for scheduling purposes, I wanted to give you notice that my client, Celesta Sabatino, is requesting that the Conciliation Conference be scheduled after the Christmas holiday. As you typically receive requests to rush conciliation dates prior to the holidays during this time of the year, I am hopeful that this will not be a difficult request to accommodate. If there is any reason why this matter would have to be scheduled prior to the holidays, please advise me at your earliest convenience. Your attention to the above is greatly appreciated. 7lYY~;~:~ U4lik' Thomas S. Diehl TSD/klh cc: Celesta Sabatino *CERTIFIED AS A CIVIL TRIAL ADVOCATE BY THE NAilONAL BOARD OF TRIAL ADVOCACY A PENNSYLVANIA SUPREME COURT ACCREDITED AGENCY ~ ~h __"__ ......~- "~-~,~" ~__v>'~~._ _ ~, __,,"~_ ~,,,, __ ,~--'~ _F. ~<~'~,'='=~_.."_ , ~_" ,~,~"_"_,..","~,,, '~--'" '~'*-~'," _,_,.,,"_"'''',,",'''' ,'""""",~,,,,=,,-"O-,,,,,,,,,,}.,;;,,,,"""=<"'''''~'''''<''!'''"~%"~'' ~,___ !Ii! ,,"",.- '." CELESTA SABATINO, Plaintiff v. MARCUSS. SABATINO, Defendant AND NOW, this Y ...... ~I - ,_J '--0.;" "Ii'" ,- -, -->'-~---n!f~-~:; > fEe I) 1 2002 W c. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENN'SYL VANIA : NO. 2001-6577 CIVIL TERM ; CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT day of ~ , 200 ~n presentation and consideration of the attached Custody Stipulation and Agreement it is hereby ordered and directed that it be entered as an Order of Court. ~. biehl :/flC1rK lj BY THE COURT, ( J. ( > [' ap.w ~ {);(-/lIj --tt~ I "c ."-".~.- -~ , , . ,.... ~-" .- ~__ ~"""'<> _ '.~"_,_,,,. ~d H,W" . .<,,'~ I :~mm!!~I!~*,1!Sil }~JfJ!lr ,~-- ~_. '''-''-'''n'","' "'~ --~ "O'~_ '<', 0::~ l)~(f .-~ " " '~ )/4 ()y' '111 ....i:; p CUl.l .';/ /. " I :J);:~j-~,.'~, ~ :,', . < 2 C./,j;\lQ' '...... ,-1"., IV 'rll~d;1f~!.{J;V,i), " VIii , ~....~_ i~~~~!!J1_ '~f~lf~1>$wrf:'1!W-<1Ff~)",' A~'1Ci-''''-''';'''~''F'''''*11~~1111"}!$'\;'!'''1~~~>(.~f\RJ:Ti~~r1~~0'i'j']i~~~~_~_n"' ~ "tll< ~ .."' . i "I. '-_0 .~~, -~ ~';';=":"~.1L~Wj,,'i ~ CELESTA SABATINO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001-6577 CIVIL TERM MARCUS S. SABATINO, Defendant : CIVIL ACTION - LAW : IN CUSTODY CUSTODY STIPULATION AND AGREEMENT THIS AGREEMENT AND STIPULATION entered into on the day and year hereinafter set forth, by and between CELESTA SABATINO, hereinafter referred to as "Mother" and MARCUS S. SABATINO, hereinafter referred to as "Father". WHEREAS, the parties are the natural parents of Deanne Noel Sabatino, born December 23, 1987; and WHEREAS, the parties wish to enter into an agreement relative to custody and partial custody of the child. NOW THEREFORE, in consideration of the mutual covenants, promises, and agreements as hereinafter set forth, the parties agree as follows: 1. The Mother and Father shall have shared legal custody of the child. 2. Mother shall maintain primary physical custody of the child with periods of temporary physical custody belonging to the Father at such times as they may mutually agree, but never less than on alternating weeks, from 7:00 p.m. Friday through 7:00 p.m. Sunday. 3. The parties shall have alternating physical custody of the child during the holidays, such as the parties mutually agree. 2 . -'0_ , J <<-', ~'~-'il_1M_;. '. ,.. 4. Transportation of the child shall be shared by the parties such that the party acquiring custody will be responsible for providing transportation. 5. The parties will keep each other advised immediately in the event of serious illness or medical emergency concerning the child, and shall take any necessary steps to ensure that the health and well-being of the child are protected. During such illness or medical emergency, both parties shall have the right to visit the child as often as he or she desires consistent with the proper medical care of the child. 6. The parties shall not do anything that may estrange the child from the other party, or Injure the opinion of the child as to the other party, or hamper the free and natural development ofthe child's love and affection for the other party. 7. The parties may make such alternate arrangements regarding the physical custody of the child so long as they may mutually agree. The parties anticipate regularly varying from the terms of this Stipulation in order to accommodate the schedules of each other and the child. However, ifthe parties cannot reach a mutual agreement, the terms of this Stipulation and Order shall control. 8. Any modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and only if executed with the same formality as this Stipulation and Agreement. 9. The parties desire that this Stipulation and Agreement be made an Order of the Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody of the parties' minor child who has resided in Cumberland County for more than six 3 ~ ~'~, 1'- _J . , '''''-'--'''~~Jl1,'''' ., ". months and shall retain such jurisdiction should circumstances change and either party desires or requires modification of said Order. 10. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable, and that it is not the result of duress or undue influence. II. Each party has had an opportunity to consult independent legal counsel of his or her own selection. Defendant herein specifically acknowledges that he has chosen to proceed in this matter without legal counsel, and furthermore specifically acknowledges that he is aware of his right to consult with counsel before signing the within Agreement, and has voluntarily and freely chosen not to exercise that right. Each party regards the terms of this Agreement as fair and equitable, and each has signed it freely and voluntarily without relying upon any representation other than those expressly set forth herein. IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms hereof set forth their signatures the day and year herein mentioned. JAN 1 8 2002 ~rt:t~ Celesta Saba' 0, Mother DATE ~ ~ 1/21}2(102 DdTE I us S. Sabatino, Father 4 "'" "" t".-J, ,_ -I. _~ ,~ ~ ~~b\;I"" " COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS On this~ay of h'u/A'~ ' 200A.-, before me, the undersigned officer, personally appeared CELE~A SABA 0 known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ---, Notarial Seal Kimberly L. Diehl-Hough. Notary Public Carlisle Boro, Cumberland County My Commission Expires May 5. 2003 COMMONWEALTH OF PENNSYLVANIA COUNTYOF e.u,-fbt.,.(lil'ltA :SS On this 2.. ~ .fI, day of J t\" I.,J Ii"~ ' 200 2-, before me, the undersigned officer, personally appeared MARCUS S. SABA: INO known to me (or satIsfactorIly proven) to be the person whose name is subscribed to the within Agreement and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. . ~pJltI- 1frb.I'J/-CAJ ". tary Public Notarial Seal Shelby A. Minich, Notary Public Camp Hill BOlO, Cumberland County My Commission Expires Aug. 20, 2005 Member. PennsylvanlaAssoclationofNotarles 5 rj"A;i~~-:iJ~~~Mf~~ll.Jjjlf~~!I~~~fiii<~fii;;;"Uj_"''"''i:~''''Tl<-t'_t"c'~;Y,"~'~~!i<~Ifil&ii~timI~_~';';"'!."'~""'"''''-'''~*~~'~ ~'J.. () f,: -0 s:: "11 $;: fi[::~' ~p~;' ~.""'J 2:(") '$:('=) c:: '7 :""1 -' , I" _,,,~ __,"~".'# ,"W ._ ,~_ '" ,~ ~. ,-~ .~ <, e, ~_?_c,_ ,~" -~~,.",." ':~} 0) -- " co r'V C) -;-1 .J:~,~ .:~': (",> C, -." :It ',c' --;l ~:.,J ;..,: ~5ra ~ ',' < -.' -;: ~) ~= -" -" ~. ,- ~ "', - -',-,. -"> " ,,"'.;....."''''' "'Li:Jlitilfiiiiii<,' fEe 0 1 2002 ~ CELESTA SABATINO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2001-6577 CIVIL TERM MARCUS S. SABATINO Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 1st day of February, 2002, the Conciliator being notified that the parties have signed a Custody Stipulation in the above matter, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, k.~ me M. Verney, Esquire, Custod onciliator ~~ ''''lillli],~~I~mm:~~';''''~~li<!,'''"'i-:<'H''t".;'ti'''''~~;''',M'''M!R>;il1ii!;:R'~it,j,"""it~"""~~a'~-' Il.liit.-n ~ >=,~ ~ -~-' .~.~"~"~,,~" '"~" ~, ~",_~_,",~ <""'M'",_"~~,, H""""~,~_" ,>!,","., -, "~". -. , "~, ~ _ . - i- ~~""'-fJiilMjI (") ~~ CD FJ~ ~~~.-- -<;~ r::::-.,': ~(~~ " c. pc:: -7 :'3 -, ~f:_,<'~.,"''''-;'5',_o ~"" _. ,~ , .... ~. ',~,-". f"-J -r'j :;2 -' C) , g -< :':'"'1 f'''-.) ~5 5lj "u. "~<_'li