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Home My WebLink About01-7154 FX ~ ~~"""'-~- -.'"- .....~_~I~. ~~ '>-~" ~ -, ,~~}I",' ~............ ." ~~I"-~'~ ._1 ''lilli ~" ,J &J~!f>fif_;..~"'~>_'", ... MELINDA S. LEBLANC, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : CUSTODYNISITATION JOSEPH A. RAZZANO, L, Defendant : NO, 01- 07154 CIVIL TERM AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYL VANIA ) COUNTY OF CUMBERLAND ) AND NOW, this 281h day of December, 2001, I, Gregory L. Cutler, attorney for Melinda LeBlanc, Plaintiff, in the above-captioned action, hereby swear that I have served a true copy of the Custody Complaint, executed by the Plaintiff in the above-captioned matter, upon the Defendant by depositing the same in the U.S. Mail, postage prepaid, certified, return receipt requested. The original return receipt card signed on December 26,2001 indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. LAW OFFICES OF PAUL BRADFORD ORR Dated: /;)/dv!oJ Gre ry . Cutler, Esquire Attorney for Plaintiff 50 East High Street Carlisle, P A 17013 (717) 258-8558 LD, # 73471 By: "~, ,~ """"",,,I ~~ - .....' ."~.-."" -I ". .. \~-''""'~& , h>-;jti~ii/;e~,,, ~ '- . .tollliJilllitelllmis 1, :1, Sfld3" Mia "oml!iilll~ item 4 il Restricted Delivery is desired" . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back 01 the mallpisce, or on the front if space permits. 1. Article Addressed to: ~~pr\A. e4LXAN~\ 1 ~1 (, I3A '1 A\j~t\\\Jf T~\"IS ~1'iH,~) Dd153 3. Service Type 'p( Certified Mail [J Express Mail o Aegistered )!f Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted DeJivery? (Extra Fee) 0 Yes 2. =;;r:~~/~1 1~~L\~1l1 ~\~lAY.~3~ PS Fo"" 3811, March 2001 Domestic Roturn Receipt -- 102595-0't-fijt. 1~4 EXHIBIT "A" -,l~eiJ:~~;'j~~bi!;;,}'M1." .rJj<'", -1l;;..fb;'''''''"''''..~:Ii$""jC;"",;'''~~O!Hi,",'."f",,,<.,b,'~~~>ig,,,'''.i'''::&:tWt'i';'-d''c_J!;'':'~",'''-''-~~~~Ii!#.,_~liml'i~.H'''J!",_~~ii!i<~''''~~I~wA,;L~~> =-=-,~~" . - 0 C;::, c: '5:: C1 -001 mi:p (>"1- Z~, c-; -.- Z~ '-'" CIJ,<" -....::' ~~< " - (", ~-~ '-- >c ""'" ., :;r; ( ,-" ~C S? :'7i.Q Pc 0'11 Z o--i :;! :.,,> ;;,~ '0 ::0 .< !~LiLU 1 -- -~ ^~-" 2>J_~~~ . ~ ~~ <~"~ -I," .~ ' "__" _ ~ 1 .~~/_"" . MELINDA S. LEBLANC PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 01-7154 CIVIL ACTION LAW JOSEPH A. RAZZANO, I DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, Jauuary 08, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueliue M. Veruey, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, February 06,2002 at 1:30 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 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 hearing. FOR TIlE COURT, By: Isl Jacqueline M. Verney. Esq.~^, 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 TIIE 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 ,;:i",~oi.c;'Y Ii'!' ,b-., .-, 'c~.~."":,i"".",, ,)"".2",-,,~, ;,,,:,,,j..,,,,",,,, ",-,",,,' '.'l;-,"-," .<,;]~:r..>i;""'i>m.m."t>r:-.,ooIll~~::.'#tJ.l1M~e~~C~""-f..1ol>",""~r"ll;~~;;@J.cil0i>';::i!_';i1C,,:r.m:l':I1Ir "c . ~':'~ fJ,~ ~~? er?},/ .~ 1- n:?w ':~ 0/. j,( /.-trY r:? ~ ~!?u/4 - rJ 'C"tJ,j-l " Vii~lil\lASNN3d .AJj~nc() cl\r~rJl:JqiA!nl") ,,-,.,,-.' ~f 'V . I ., I ., 'L, !!d Ow. lO,]'c--!f' 7f'l C !~, J I ,.,;,.1 AH~J:.L(:, 'I,'" ,~r) ~ ! :'1 , ~ 'il. -- ,<_ "',~~v'. -. ~ ---^ " '-' =>- '=""L . "~ ,~~- ~ ,-- '-,1- .., "H .'..'-, ~ -~ -"0' MELINDA S. LEBLANC, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CML ACTION - LAW : CUSTODYMSITATION : NO. 01_7/.N CML TERM JOSEPH A. RAZZANO, L, Defendant ORDER OF COURT AND NOW, ,2001, 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 ,2001, at o'clock, _,m., for a Pre-Hearing Custody Conference. At such conference, an effurt 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. 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 di$abled 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 Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 ,,""-~- - 'L ~ ..~ ~'M """1.... MELINDA S. LEBLANC, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CML ACTION - LAW : CUSTODYNISITATION : NO. 01- 7/1 CML TERM JOSEPH A. RAZZANO, I., Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is Melinda S. LeBlanc, residing at 18 Clouser Road Spur, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Joseph A. Razzano, I., residing at 896 Bay Avenue, Toms River, New Jersey 08753, 3. Plaintiff seeks custody of the following children: NAME RESIDENCE DOB AGE Joseph A. Razzano, II. 18 Clouser Road Spur, Mechanicsburg 5-30-99 2 yrs. 6 mnths. 4. The child was born out of wedlock. 5. The child is presently in the custody of Melinda S. LeBlanc. 6, During his life, the child has resided with the following persons and at the following addresses: NAME ADDRESS DATES Melinda S. LeBlanc 18 Clouser Road Spur, Mechanicsburg Birth to Present Joseph A. Razzano, I 18 Clouser Road Spur, Mechanicsburg Birth to 1/1/0 I 7. The mother of the child is Melinda S. LeBlanc, currently residing at 18 Clouser Road Spur, Mechanicsburg, Pennsylvania 17055. She is unmarried. 8. The father of the child is Joseph A. Razzano, I, currently residing at 896 Bay Avenue, Toms River, New Jersey, 08753, He is unmarried, "" ~- , -~ , l~,,~~' '''''''"''_hl""",_''''';, 9. The relationship of the Plaintiff to the child is that of Mother. The Plaintiff currently resides with the following persons: Richard 1. LeBlanc, son; Joseph A. Razzano, II, son; and John P. Mumper, boyfriend, 10. The relationship of the Defendant to the children is that of Father. The Defendant currently resides with the following persons: Christina Razzano, mother and Anthony Razzano, father. 11. 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. 12. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 13. 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 children will be served by granting the relief requested for the following reasons: A. Plaintiff has undertaken and performed the primary parental responsibilities for the child; and B. Plaintiff is best able to provide the care and nurture which the child needs for healthy development; and C. A Court Order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unruet exceptions regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion D. Plaintiff desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the child. E. A Court Ordered detennination of custody is required to. avoid continuing conflict -. ---~_.~ - '. -'. '.'~~ -C_Ilir_"L'; between the parties regarding parental responsibility for custody and support. F. Defendant's erratic and abusive behavior poses a threat of harm to the child. G. Plaintiff continues to maintain the same family household for the child that has been maintained since May 1, 1999. The Defendant has moved from the family residence into his parent's residence. H. Defendant and Defendant's family threatens Plaintiff with physical harm over the phone and threatens to remove the child from the Plaintiff's care without her pennission. 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant custody of the children to Plaintiff pending the hearing. Respectfully submitted, J'J/()/)O I By:!:' ili 0 ' Cutler, Esquire Attorney for Plaintiff 50 East High Street Carlisle, P A 17013 Telephone: (717) 258-8558 Supreme Court ID No. 73471 i{ .- --,~ COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) - ~ Ie -'~ O-llS~:< ~ .- -. .d-!' ~-:~r.< .'" I verify that the statements made in the foregoing Complaint 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: /~1;{J 1 YJjy.,Lc(!JL1 ~,i, ,.-;- ,,.- " ',d_",,,-'_"";f~,. ,""_i,c-j'<' ;<;;,,' ,,-\,-~," p..,,,,~>)-,,.,< '";",,,"""~;,"""f.,,1;~,''-<';;;'~'-'~~ 'M- ,,_, ~L _blili'-ilili..~~f...W~!;;,,%~~,\'iIL'1.i1~_Illli- p ""'" () 0 p 0- ~f () F ~ 0 -,., 0 i r<j :Y;: '-. '77";::; . N ,~ ~ -- ~ 8 -< . =?8 ~ ~c::i ~o '" ii~~"; f, >>8 ::J:: ::-';:iR f! ~ ry (S,f1 0 ~-j -'" r'0 ::J;J -< ~ 1I,.,I!!,,,-,.UL! UPJl J ~~~"_ ~..- .,",.__","",.Ii~rn"=_'"""""""%"d''''''''-;''''O~''''~'''*",,,,, ~."",,"~," ~," "'. _ ._.. ,""'N'*,,,' ~". ~,' ~,,,,,! "'v," ',~_-'.", ","".,>"".-.,,,,,,~,,,-,,,,- Melinda S, LeBlanc, Plaintiff Vs, Joseph A, Razanno, Defendant "W" ',< I ,=-".~" ,-, "_~""~_""o""''-,'",,^', '--'''c-'-' ." ,/,'" __'__"""j~~ : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : CUSTODY I VISITATION : NO. 01-7154 CIVIL TERM PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY OF SAID COURT: Please enter the appearance of Carol L Cingranelli, Esquire, on behalf of the Defendant in the above-captioned case. /a---n".ux-,,-{} ~ D ) " Respectfully Submitted, TURO LAW OFFICES !k ~- Carol L Cingranelli, Esq e Turo Law Offices 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 ID #47958 .Wi ,-, - "" ,,",'''do ;:I'--"~ .L I. ",c..> L-'"" ~w,<,' "'-;'~liW~~ CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Praecipe for Entry of Appearance upon Gregory L. Cutler, Esquire, by depositing same in the United States Mail, first class, postage pre-paid on the /~ of ~ ' 2002, from Carlisle, Pennsylvania, addressed as follows: Gregory L. Cutler, Esquire 50 East High Street Carlisle. PA 17013 TURO LAW OFFICES ''-! II ;~~~~w..l@#.i;l:!llii!iH$ifu!I~f'~1:.i!i-\;l1&^''''~;~lWi!~;,;;-i;;!!iiii:iu;.j(;,~;, ~'j'>'dj.-t."-''''''''_1lii:",^",,-i'''lI,~~~_&.jjM''' ~l~"",,;,';'; ,--_",J~~,-""k,;;, J1J.",J;J",J".",,~ c')'UIic~J,:~J,A't~..~.: _:"~:,,.~~..Lr~_',;T) ,~,'~"'7'!'~" ~x' ", ',',<,'X_""" "","~J!L,W')]" tJ ~,~.... ._" ", ',' _,r,~ Pr~"'~'.'."'""-"'''''" .....~\ "" M!:llill!IWT- (") c:' -;=c.. ....., :':.~, Vr-' rnif: ~S~' ~~': ?~~ ~ r::. s 8lj 11"_ r"''-> j'\.~' "r~ ~_r"" :: o 9 "-::: -=" =< ", ..~ . ,~< - ,-- -., r'~~" ~~<iJ!iI'" , ' "- FEB 2 1 ZOOZ Ui MELINDA S. LeBLANC, Plaintiff V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 2001-7154 CIVIL TERM JOSEPH A. RAZZANO, I, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this ~ day of f~ ,2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: L The Mother, Melinda S. LeBlanc, and the Father, Joseph A Razzano, I, shall have shared legal custody of Joseph A Razzano, II, born May 30, 1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion, 2. Mother shall have primary physical custody of the child, 3. Father shall have periods of partial custody as follows: A 10 consecutive days every month at times agreed by the parties, 4. The parties shall alternate the Christmas holiday on the following schedule: from Christmas Eve to New Year's Eve, Mother shall have physical custody in even numbered years; Father shall have physical custody in odd numbered years, 5. The parties shall alternate the Easter holiday on the following schedule: from Good Friday to Easter Monday. Father shall have physical custody in even numbered years; Mother shall have physical custody in odd numbered years, 6. The parties shall share transportation as the parties agree. 7, This Order is entered pursuant to the agreement of the parties at a Custody Conciliation Conference, The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. ." . .. q;(g;;~gOry L Cutler, Esquire, Counsel for Mother '} /Caro] L Cingranelli, Esquire, ~ounse] for Father [1opk.9 f)a.:ll.ed.... L Ok:a.oZ l K~~ I' " --, J~ l -, ... 0' <, jjllliii\u~~~:;, J. _. .1, .,', '"""""",,;,...,~; " MELINDA S. LeBLANC, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2001-7154 CIVIL TERM V. JOSEPH A. RAZZANO, I Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Joseph A. Razzano, II May 30, 1999 Mother 2. A Conciliation Conference was held in this matter on February 20, 2002, with the following individuals in attendance: The Mother, Melinda S. LeBlanc, with her counsel, Gregory L, Cutler, Esquire and the Father, Joseph A, Razzano, I, with his counsel, Galen Waltz, Esquire for Carol 1. Cingranelli, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. d. - d-.d-. -o.;.l, Date ~~L~ cquel eM. Verney, Esquire Custody Conciliator