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HomeMy WebLinkAbout99-06293 S c r . s H idF ? 0.r tty.• frr'' f ,? , . y Is d f k ? eI Y' or y 1. r y ,. > A a dZ'o- I .3' 3 ? yy?? ? v? AP tr ? l S n, ? i ? % •? 4 n 4 M ?y 1 -t t t f ?? ?:g 'Y $Y t f+?.. y L ' XN?Jr r 1NY' * ? J 1w. .`iY I 't ty:i . ?R ty'r " k f : 1 I p . a F}? t ? .. rv :4 t 1?. f ; yy?? - R y s i s CORRIE E. SARACINA IN THE COURT OF COMMON PLEAS OF Plaintiff' : CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION -LAW NO. CIVIL TERM JERRY J KELLEY `?9-(oa93 Defendant IN CUSTODY AND NOW THIS _r?, day of ?r atr?her , 1999, upon consideration of the attached complaint,'! is hereby directed that the parties and their respective counsel appear before S, Ae , ,at on the '9_ day of 1`?Cern?c , 199 at =, JP.M., for a Pre- caring 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 BY THE COURT, BY nUtf?LCC? cA. _?\>?mC ll? YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF 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 C.? .: a`i %l .11` is ?/?: •f+7 Cz? ??.? ??? ???? CORRIE E. SARACINA Plaintiff Vs. JERRY J. KELLEY Defcndant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. CIVIL TERM 92-c?a?s IN CUSTODY COMPLAINT FOR CUSTODY Plaintiff is Corrie E. Saracina, an adult individual, currently residing at 15 Church Road, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Jerry J. Kelley, an adult individual, currently residing at 934 Route 910, Cheswick, Pennsylvania 15024. 3. Plaintiff seeks custody of the following child: James P. Kelley, age 1, born 3/30/1998. The child was born out of wedlock. The child is presently in the primary and exclusive custody of the plaintiff. The natural mother of the child is Come E. Saracina. She is single. The natural father of the child is Jerry J. Kelley. He is single. 4. The relationship of the Plaintiff to the child is that of natural mother. The plaintiff currently resides with the following persons: James W. Saracina (father), Minks A. Saracina (mother), and James P. Kelley (son). 5. The relationship of the Defendant to the child is that of natural father. He resides with: unknown. 6. Plaintiff has not participated as a party concerning the custody of the child in this Court. Plaintiff has no information ofa custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know ofa 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: The child has lived in the care of his mother since birth, with no contact with the father for over a year. The last time that the father saw the child was on or about May of 1998, the last contact the mother had with the father was on or about July of 1998. 8. 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. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene. NAME ADDRESS BASIS OF CLAIM None WHEREFORE, Plaintiff requests your Honorable Court to: A) grant full legal and physical custody of the child to the plaintiff; B) grant such other relief as is just and in the best interest of the child, Respectfully submitted, Robert L. O'Brien, Esquire O-BRIEN, BARIC lot SCHERER 17 West South Street /? Carlisle, PA 17013 Date: 2a: 2 r-,14 /99q (717) 249-6873 !l x: ! A f: J; J I verify that the statements made in the foregoing Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of IS Pa. C.S. § 4904, relating to unswom falsification to authorities. ?rli?rir ?, ?a ? ?t CORRIE E. SARACINA DATE: 19q ?.? V CJ L 9 00 T4 -4 m v 0 C T l 5 199N? CORRIE E. SARACINA Plaintiff Vs. JERRY J KELLEY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99.06293 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this 13tttday of ot, - , 1999, upon consideration of the plaintiffs Motion for Order of Special Service upon defendant Jerry J. Kelly pursuant to Pa.R.C,P.§430(a), and it appearing to the Court that the plaintiff has made a good faith effort to locate and serve the defendant in the regula course, it is hereby ORDERED that said motion is granted, and service upon the defendant Jerry J. Kelly is to be made by publication one time in a local newspaper and one time in the Cumberland Law Journal. CC BY?/TTHHEEEC, By / -, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT RAVE 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 A A, CORRIE E. SARACINA : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW NO. 99-06293 CIVIL TERM JERRY J. KELLY Defendant IN CUSTODY Notice to Jerry J. Kelly You have been named as a defendant in a civil action instituted by plaintiff Corrie E. Sarcina against you in this Court. Plaintiff Corrie E. Sarcina requests in the Complaint full legal and physical custody of the child James P. Kelly. You are hereby notified to plead to the complaint in this case, of which the above is a brief summary, within twenty days from , 1999. If you wish to defend, you must enter a written appearance personally or by attorney and file your defenses or objections in writing with the Court. You are warned that if you fail to do so, the case may proceed without you and ajudgment may be entered against you without further notice for the 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 OF 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 ,; -0 CORRIE E. SARACINA Plaintiff' Vs. JERRY J KELLEY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-06293 CIVIL TERM IN CUSTODY MOTION OF PLAINTIFF FOR ORDER OF SPECIAL SERVICE AND NOW, comes Plaintiff, Come E. Saracina, by and through her attorneys, O'Brien, Baric & Scherer, and files the within motion and, in support thereof, sets forth the following: Come E. Saracina is an adult individual, currently residing at 15 Church Road, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Plaintiff and Defendant have a child, James P. Kelley, born out of wedlock on March 30, 1998. 3. Plaintiff last saw Defendant on or about May of 1998. 4. Plaintiff last had contact with the Defendant on or about July of 1998. 5. In a letter dated July 2, 1998 Plaintiff retained Harold S. Irwin, III, Esquire to obtain custody of the above named child. A copy of the letter is attached as Exhibit "A". 6. On or about July of 1998 Harold S. Irwin, III, Esquire sent a copy of a Stipulation Agreement by regular mail to the Defendant. No response was made by the Defendant. A copy of the Stipulation Agreement is attached as Exhibit "B". 7. On or about June of 1998 Plaintiff initiated an action for support of the above named child. 8. A support conference in the Domestics Relations Section in Carlisle on August 13, 1998 was ordered by the Honorable J. Wesley Oler, Jr. J. A copy of the Order is attached as Exhibit "C". i 4 *1 9. On August 13, 1998 an Order to Appear for Genetic Testing on September 15, 1998 was order by Michael R. Rundle, Esquire, Special Counsel. A copy of the Order is attached as Exhibit "D". 10. In a letter dated December 2, 1998 another conference was scheduled at the Domestic Relations Section on December 17, 1998 to discuss the results of the genetic testing. A copy of the letter is attached as Exhibit "E". The Defendant did not appear at this conference. 11. An Order of Court was issued on January 6, 1999 by the Honorable J. Wesley Oler Jr. J. for another support conference at the Domestic Relations Section in Carlisle on February 4, 1999. A copy of the Order is attached as Exhibit "F". The Defendant did not appear at this conference. 12. An Order of Court - Reschedule A Conference was issued on February 7, 1999 by the Honorable J. Wesley Oler, Jr. J. for another support conference at the Domestic Relations Section in Carlisle on February 24, 1999. A copy of the Order is attached as Exhibit "G". The Defendant did not appear at this conference. 13. Another Order of Court was issued on May 1], 1999 by the Honorable J. Wesley Jr. J. for another support conference at the Domestic Relations Section in Carlisle on June 15, 1999. A copy of the Order is attached as Exhibit "H", 14. By letter dated May 24, 1999 the Plaintiff was notified that the support conference originally scheduled for June 15, 1999 had been canceled because the Defendant's mail had been returned by the post office. A copy of the letter is attached as Exhibit "I". 15. On or about September of 1999 the Plaintiff received another Order of Court to appear for a support conference, the Plaintiff in turn withdrew her petition for support . A 4, 16. In an Order dated August 2, 1999 the Honorable J, Wesley Oler, Jr. J. dismissed the matter without prejudice due to the Plaintiff's request. A copy of the Order is attached as Exhibit "i". 17. The Plaintiff filed a Complaint in custody to the above caption on or about October 14, 1999. A copy of the Complaint is attached as Exhibit "V. 18. Plaintiff acquired the defendants last know address through the Domestic Relations Office of Cumberland County, Pennsylvania. 19. On or about October 14, 1999 the Plaintiff's attorney, Robert L. O'Brien, sent a letter by regular mail to the Postmaster at Cheswick, Pennsylvania. A copy of the letter is attached as Exhibit "L". 20. Service was attempted at the defendants last know address of 934 Rt.10, Cheswick, Pennsylvania, 15024. Service of the complaint in custody was attempted by regular first class mail, and certified mail. A copy of the mail receipt is attached as Exhibit "M". 21. Service upon the defendant at the defendants last know address was unsuccessful. A response has been received by the defendants father at the last known address. 22. A letter dated October 25, 1999 was sent to the Defendants father by Robert L, O'Brien requesting help in locating the Defendant. A copy of the letter is attached as Exhibit „N„ 23. Defendants father does not know where his son is, and declines helping the plaintiff in finding the defendant. 24. No response to the complaint in custody was ever filed by the defendant. 25. An Order dated October 22, 1999 was issued by Dawn S. Sunday Esquire scheduling a Pre-Hearing Custody Conference on December 8, 1999. A copy of said Order is attached as Exhibit "0". A a 26. In order to obtain custody of the child in the above captioned matter the plaintiff must effectuate service of the Custody Complaint on defendant, Jerry J. Kelley. WHEREFORE, Plaintiff, Come E. Saracina, respectfully moves this Court to enter a special order of court to effectuate service of the Custody Complaint upon defendant, Jerry J. Kelley and service to be made by publication of the Custody Complaint directed to defendant, Jerry J. Kelley to be published in accordance with Pa.R.C.P. 430(b)(1). O'BRIEN, BARIC & SCHERER Robert L. O'Brien IDN44853 17 West South Street Carlisle, PA 17013 (717) 249-6873 ,, fWdmwciduncins.mot A 4. a VERIFICATION I va* that the =mob made in the foregoing Moron of QMidi6far Ortkr of SpmW Savim are true and mem I wd uoM that false gatanmb haein are made atiect to the pa>Wdm of 18 Pa C.S. § 4904, relating to um vom falsification to authoritim darri2 e. t.tT,!QL'l/?D . Cortie E Saacum DATED: 1-1-f1-49 uwoFFIciea of HAROLD S; /RAY/N, /// ArroRlver.Ar LA w HITNER HOUSE, SUITES 201 and 202 35 EAST HIGH STREET HAROLD S.IRWIN. II I CARLISLE, PENNSYLVANIA 17013 717-2136= HEATHER A. BARBOUR PHW Www.cenpenn.com,4rWrV 717-2 43 -9200 JOHN D. BARANSYJ a-mail: invinlaW@epix.not GAY L.IRWIN FACWLE PARALEGALS July 2, 1998 Dear Corrie: Thank you very much for your confidence in retaining me to represent you in your current legal matter. We look forward to working with you. This letter outlines the terms upon which we would be willing to represent you. We look forward to working with you, if these terms be acceptable. Experience has taught me that the attorney - client relationship functions best when both parties are fully aware of the scope of the representation and their respective obligations. The purpose of this letter is to set forth in writing the arrangements concerning our services and fees so that we may avoid any misunderstandings. Our fee in this case will be a minimum of $375.00, plus costs. This amount will pay for all time up to the amount of time covered by that amount, based upon the hourly rate for those persons providing services to you as listed below. Fees will depend primarily upon the time, effort and work product expended on your behalf, consideration of the issues and difficulties involved, and the results achieved on your behalf. You will be billed for all time expended in your case. I maintain time records which you may periodically review upon request. You may also request an Itemized bill at any time. It is to be understood that during the course of the representation, my time will be kept at the prevailing rate for the person performing the service based upon intervals of 2.0 tenths of an hour. 1 try to have the work done at the level which will be the most efficient in terms of rates and costs to you. My present rate is $125.00 per hour, except for time in court before a judge which is billed at the rate of $150.00 per hour. The rate for paralegals who may assist me in your case is $65.00 per hour. We may also confer about this case with Dale F. Shughart, Jr., Esquire, another attorney located here at this office and whose rates are the same as mine. at The time charged includes not only meeting with you and court appearances, but also such activities as drafting and reviewing court documents and correspondence, Law Offices of Harold S. Irwin, 111 Foe Agreement July 20 19*8 Page Two telephone conversations with you, opposing counsel and other parties, time spent with witnesses, legal research and travel. Please understand that all hourly rates charged to my clients may be increased on an annual basis. In addition to the charges for professional services, you will be responsible for promptly advancing to the firm or reimbursing me for all of our out-of-pocket expenses such as charges for long distance telephone calls, postage, filing fees paid to the court, experts, appraisals, investigative and witness fees, travel expenses, computerized legal research, transcripts of proceedings, telecopies and photocopies. In order to make the costs for these items clear, these expenses are separately itemized on my statements. We will be sending you monthly statements as your case proceeds containing a description of how we have been spending my time on your behalf. We reserve the right to charge interest and/or to terminate our attorney-client relationship if you do not pay the fees or expenses and costs within thirty (30) days of billing. This policy is enforced as we do no think it is fair to ask clients who pay their bills when due to finance the legal costs of others who are delinquent. The firm requires and the client agrees to pay the initial retainer for our legal services in the amount of the minimum fee of $375.00, plus $50.50 court costs, payable as follows: $250.50 in advance (PAID JULY 1, 1998) and $175.00 on or before August 1, 1998. The retainer Is equal to the minimum fee and Is therefor non-refundable. If the time required to handle your current legal matters exceeds that covered by this retainer, then we may require an additional retainer to be advanced before proceeding with your case. You will also need to advance to me any necessary court costs prior to our filing any documents with the Court. The scope of our representation generally will be limited to representing you in your custody proceeding. Unfortunately, it is virtually impossible to estimate for you the total amount of time that will have to be devoted to your case. That will depend upon a variety of factors, primarily upon whether hearings or a trial will be necessary, the time and effort required, the nature and complexity of the issues involved and the degree of cooperation afforded by the other party in this case. Similarly, we cannot guarantee the results that will be obtained, particularly since no one can predict what a court may do in a particular case. Cases of this kind require that your attorney be as familiar as possible with all of the facts bearing on the issues, regardless of how trivial you may believe them to be. Therefore it is essential that you share all even remotely relevant facts with us. We will attempt to keep you closely advised of the progress of your case and provide you Law Offices of Harold E. Irwin, III F« Ayreenwat Jot* 2, 19/6 Fag* Three with copies of most correspondence, pleadings and other relevant materials. You should never hesitate to ask us questions, which we always welcome. We understand that in matters of this nature, urgent circumstances may arise which may necessitate your talking to me immediately. We have made a strong commitment to respond to your inquiries as soon as possible. Our paralegals may be working with us on this matter and you should always feel free to contact them. However, understandably there are occasions when we are not immediately available because of our commitments in other cases. If the staff cannot help you immediately, we will attempt to get back to you as soon as possible. . You have the right to terminate our services at any time, for any reason. As stated above, we reserve the right to terminate our representation upon your failure to pay fees and reimbursable expenses within thirty (30) days of billing. We also reserve the right to terminate the relationship immediately in the event that cause exists under the Pennsylvania Rules Professional Conduct which govern attorney's behavior to terminate our relationship for any reason, upon thirty (30) days written notice to you. We hope that this letter adequately expresses our arrangement concerning our services, fees and costs. If it does, please sign the enclosed copy of this letter in the space provided and return it to us together with a check for the retainer requested, unless previously paid. Of course, should you have any questions or comments about this letter or the arrangements discussed above, please do not hesitate to give us a call. We look forward to working with you in this matter. yours, S. I have read the above retainer letter and agree-to-ttiie terms set forth therein concerning my legal representation in this matter by the Law Offices of Harold S. Irwin, Ill. Date: CORRIE E. SARACINA t i 04 81!91413 Fri F HAROLD S. IRWINO life ESQUIRE ATTORNEY ID NO. 22920 20 EAST HIGH STREET OARLISLE PA 17012 (717) 2130000 ATTORNEY FOR PETITIONER CORRIE E. SARACINAO Petitioner v. JERRY J. KELLEY, Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY9 PENNSYLVANIA CIVIL ACTION . LAW NO. :CUSTODY ORDER OF COURT AND NOW, this day of , 1998, upon presentation and consideration of the attached stipulation and agreement and upon agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. BY THE COURT, J. CORRIE E. SARACINA, Petitioner V. .FERRY J. KELLEY] Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. :CUSTODY THIS STIPULATION AND AGREEMENT entered Into this id day of 1998, by and between JERRY J. KELLEY (hereinafter referred to as "Father") and CORRIE E. SARACINA (hereinafter referred to as "Mother"). NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, the parties are the natural parents of a minor child, namely James P. Kelley (born March 30,1998); and WHEREAS, the parties wish to enter into an agreement relative to the custody and visitation of the child. W, NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: 1. The mother shall have legal custody of the child. 2. The mother shall have primary physical custody of the child. 3. The father shall enjoy periods of visitation with the child at the mother's residence from time to time as the parties may mutually agree. 4. The parties will keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to ensure that the health, welfare and well being of the child is protected. 5. The parties shall do nothing that may estrange the child from the other parent or injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's love or affection for the other parent. 6. 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 of this agreement. 7. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 8. The parties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the parties' minor child and shall retain such jurisdiction should circumstances change and either party desire further or require further modification of said Order. IN WITNESS WHEREOF, the parties hereto, Intending to be legally bound by the terms hereof, set forth their hands and seals the day and year herein set forth. WITNESSETH: Date: Date: JERRY J. KELLEY (SEAL) (SEAL) CDRRIE E. SARACINA COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY :SS: PERSONALLY APPEARED BEFORE ME, a notary public, this _ 1998, JERRY J. KELLEY, known to me (or satisfactorily day of 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 have hereunto set my hand and official seal. A . Notary Public i COMMONWEALTH OF PENNSYLVANIA , COUNTY OF CUMBERLAND :SS: PERSONALLY APPEARED BEFORE ME, a notary public, this 1998, CORRIE E. SARACINA, known to me (or satisfactorily day) 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 have hereunto set my hand and official seal. r Notary Public i In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION CORRIB B. SARACINA Plaintiff VS. JERRY J. KELLEY Defendant Docket Number PACSES Case Number ) Other State ID Number 00530 S 1998 944100185 You, CORRIB ELIZABETH SARACINA plaintiff/defendant of 43 LIBERTY DR, MOUNT HOLLY SPRINGS, PA. 17065-1024-43 are ordered to appear at cumBsRLAND co DRs 13 NORTH HANOVER STREET, CARLISLE, PA. 17013 before a conference officer of the Domestic Relations Section, on AUGUST 13, 1998 at 9: ooAM for a conference, after which the conference officer may recommend that an order for support be entered. You are further required to bring to the conference: I. a true copy of your most recent Federal Income Tax Return, Including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income and Expense Statement attached to this order as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. pra:f of medical coverage which you nuy have, or may have available to you 6. information relating to professional licenses 7. other: r, Form CM-508 Service Type M Worker ID 21200 SARACINA V. KELLEY PACSES Case Number 944100185 If you fail to appear for the conference or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court shall enter an order establishing paternity. BY THE COURT: Date of Order: 9 f / a-] Dl,-,. W JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP: CUMBERLAND CO BAR ASSOCIATION 2 LIBERTY AVE CARLISLE PA 17013-3300-02 (717) 249-3166 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 at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference. Service Type M Page 2 of 2 Form CM-508 Worker ID 21200 r. , Exhibit D DR 27,696 PACSES 944100185 CORRINE ELIZABETH SARCINA. : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA VS : DOMESTIC RELATIONS SECTION : CIVIL ACTION • SUPPORT JERRY L KELLEY, DEFENDANT : NO. 530 SUPPORT 1998 ORDER TO APPEAR FOR GENETIC TESTING THE DEFENDANT HAS NOT ACKNOWLEDGED PATERNITY OF THE CHILD, JAMES PERRIN KELLEY, BORN ON MARCH 30, 1998 IN NEW LONDON, CT TO CORRINE ELIZABETH SARCINA THE PARTIES AND THE CHILD ARE ORDERED TO APPEAR FOR GENETIC TESTING ON SEPTEMBER 15, 1998, AT 9:45A.M. AT THE CUMBERLAND COUNTY DOMESTIC RELATIONS SECTION, 13 NORTH HANOVER STREET, CARLISLE, PENNSYLVANIA 17013 AND TO STAY UNTIL EXCUSED. IF THE DEFENDANT FAILS TO APPEAR FOR GENETIC TESTING AS ORDERED, THE COURT WILL ENTER AN ORDER FINDING THAT DEFENDANT IS THE FATTIER OF THE CHILD. IF THE PLAINTIFF FAILS TO APPEAR OR FAILS TO MAKE THE CHILD AVAILABLE FOR TESTING AS ORDERED, THE COURT MAY ENTER AN ORDER DISMISSING THE PATERNITY ACTION WITHOUT PREJUDICE. BY THE COURT, GEORGE E. HOFF?ER. PRESIDE JUDGE DATE: 13Y <g 1--1) clk MICHAEL R. RUNDLE, ESQUIRE SPECIAL COUNSEL 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 who have been ordered to appear for genetic testing, please contact our oMce. All arrangements must be made at least 72 hours prior to the scheduled genetic tests. You must s ar for the genetic testing. = re a% q e- 6 6L 1 • . NOTICE TO PLAINTIFF IN A PATERNITY ACTION: THE TOTAL COST OF THE PATERNITY GENETIC TESTING FOR THREE PERSONS IS $192.00. THIS COST WILL BE ADVANCED BY THE CUMBERLAND COUNTY DOMESTIC RELATIONS SECTION. IF THEIDEFENDANT IS EXCLUDED AS A POSSIBLE BIOLOGICAL FATHER OF YOUR CHILD BY THE BLOOD GROUPING TESTS. THE COSTS OF THESE TESTS MAY BE ASSESSED AGAINST YOU BY THE COURT. I ACKNOWLEDGE RECEIPT OF A COPY OF THIS NOTICE THIS DAY OF Lug 1 19 ? . (?)m0 0. g 1 nQL PLAINTIFF DR O a-11 (qq v/ I I Exhibit E J aW:? $Ws gym= U `J DOMESTIC RELATIONS SECTION CUMBERLAND COUNTY, PENNSYLVANIA 13 NORTH HANOVER STREET P.O. BOX 320 CARLISLE, PENNSYLVANIA 17013 RICHARD K. BETTS. DIRECTOR LARRY L MILLER. ASST. DIRECTOR December 2. 1998 Corrie Saracina 43 Liberty Drive Mt. Holly Springs, PA 17065 Re: Samcina v. Kelley DR 27,696 Dear Ms. Samcina: Please find enclosed the results of the paternity blood grouping tests conducted on all parties of the above referenced case. The results indicate a 99.99% probability of patemity. A conference to discuss the blood test results has been scheduled with Mr. Kelley in our office on December 17, 1998 at 11:15 a.m., with Michael R. Rundle, Esq., Special Counsel. You do ?Q,( have to attend this conference. If Mr. Kelley acknowledges paternity of your child, James, at this conference, a hearing will be scheduled with a Conference Officer to determine the amount of child support. The Conference Officer will notify you by mail of this date. If Mr. Kelley continues to deny paternity of James at this conference, a paternity trial will be scheduled. Our office will notify you by mail of the exact date if this occurs. Thank you for your cooperation. Sincerely, t b? nnif . Gibboney Legal Assistant JLG/ Enclosure Mjj`r , PATERNITY EVALUATION REPORT Mother CORRIE E. SARACFNA Child JAMES J. KELLEY Alleged Father JERRY KELLEY Client Case N DR27696 Location Carlisle, FA Mother Child 2 3 Laboratory ID Race 001707165 001707173 001872266 Father 4 D6SI32/PAC424 3.18 3.18 __ HAEM 2.65 2.78 2.78 5 D,7S( A^i41"? t. T ' 8.,455 518 9.00 a vY A ?/' 7 ?,{ -tt? t f ,f 7T r , AYL?7 ? „y,t(tr sly i ? . '., 17.1 1)'}Y. ?ta? ( :}f, •.. . ' / Index OB 'SOP e99 99%,? ?COMB*i 16TA tctyrTY I" 1:'11,637 to 1 i CONCLUSIONS: The alleged father, JERRY KELLEY, cannot be excluded as the biological father of JAMES J. KELLEY. Based on the above genetic testing results, the probability of paternity is 99.99% as compared to an untested random man of the North American Caucasian population. (Prior Probability - 0.5) I the undersigned Director, upon being sworn on oath, do depose and state that I read the foregoing report on the analysis of genetic specimens from the above-named individuals, signed by myself, and that the?la?c?t?s and results therein are true and correct. Director Sworn to and Subscribed before me this - 9 _ day of l ?GIL? ,19 at Nashville, Tennessee. r Not r Public, Sfare of Te nessee My commission expires L? 21 •lCfQ Caucasian 9/15/98 9/15/98 Caucasian 10/27/98 Laboratory Case Number: 8260005•A Account: PA021 Specimens Collected AIR PARK CENTER III • 1400 DONEtSON PIKE. SUM A•15 NASNVtU.r:, TN 3711? - 161513605000 0 r'Ax (615) 1UM) 1E.1 nyd' -j J Q•ry ` . t Y l _t/'e'i( n ?i'?.7i .7 .ti •d;' D2S44/YNH24 2.34 2.34 3.04 4.45 HAEIII 1.81 1.61 1.61 FahlbN F In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION CORRIS E. SARACINA Plaintiff VS. JERRY J. KELLEY Defendant Docket Number PACSES Case Number Other State ID Number You, CORRIE ELIZABETH SARACINA 43 LIBERTY DR, MOUNT HOLLY SPRINGS, PA. 17065-1024-43 are ordered to appear at CUMBERLAND CO DRS 13 NORTH HANOVER STREET, CARLISLE, PA. 17013 00530 S 1998 944100185 plaintiff/defendant of before a conference officer of the Domestic Relations Section, on FEBRUARY 4, 1999 at 10:30AM for a conference, after which the conference officer may recommend that an order for support be entered. You are further required to bring to the conference: 1. a true copy of your most recent Federal Income Tax Return, Including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income and Expense Statement attached to this order as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M Form CM-508 Worker ID 21204 SARACINA V. KELLEY PACSES Can Number: 944100185 If you fail to appear for the conference or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court shall enter an order establishing paternity. BY THE COURT: Date of Order: - lo- ?I ?. Id,4? &A,'-t ?- r G YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP: CUMBERIJM CO BAR ASSOCIATION 2 LIBERTY AVE CARLISLE PA 17013-3308-02 (717) 249-3166 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 at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference. Page 2 of 2 Form CM-508 Service Type M Worker ID 21204 Ethibit G In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION CORRIE E. SARACINA ) Docket Number 00530 S 1998 Plaintiff ) VS. ) PACSES Case Number 944100185 JERRY J. KELLEY ) Defendant ) Other State ID Number ORDER OF COURT RFCrH D fT F A Oh'F^RFCF You, CORRIE ELIZABETH SARACINA plaintiff/defendant of 43 LIBERTY DR, MOUNT HOLLY SPRINGS, PA. 17065-1024-43 are ordered to appear at CUMBERLAND CO DRS 13 NORTH HANOVER STREET, CARLISLE, PA. 17013 before a conference officer of the Domestic Relations Section, on the 24TH DAY OF FEBRUARY, 1999 at to :30AM for a conference, after which the conference officer may recommend that an order be entered. This date replaces the prior conference date of FEBRUARY 4, 1999 You are further required to bring to the conference: 1. a true copy of your most recent Federal Income Tax Return, Including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income and Expense Statement attached to this order as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. Information relating to professional licenses 7. other: t NUMI' THIS NOTICE FOR YOUR INFORMATION ONLY. YOUR PRESENCE IS,NOT;. REQUIRED. Form CM-513 Service Type M WorkerlD 21200 SARACINA V- KELLEY PAMES Case Number. 944100185 If you fail to appear for the conference or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. BY THE COURT: Date of Order: WESLEY OLER. JR. JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. EF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP: CUMBERLAND CO BAR ASSOCIATION 2 LIBERTY AVE CARLISLE PA 17013-3308-02 (717) 249-3166 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 at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference. Form CM-513 Service Type M Worker 1l) 21200 Exhibit H In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION CORRIE B. SARACINA Plaintiff VS. JERRY J. KELLEY Defendant Docket Number PACSES Case Number Other State ID Number You, CORRIE ELIZABETH SARACINA 43 LIBERTY DR, MOUNT HOLLY SPRINGS, PA. 17065-1024-43 are ordered to appear at cumBERLAND CO DRS 13 NORTH HANOVER STREET, CARLISLE, PA. 17013 before a conference officer of the Domestic Relations Section, on JUNE 15, 1999 00530 S 1998 944100185 plaintiff/defendant of at 9: ooAM for a conference, after which the conference officer may recommend that an order for support be entered. You are further required to bring to the conference: 1. a true copy of your most recent Federal Income Tax Return, Including W-2s, as riled, 2. your pay stubs for the preceding six (6) months, 3. the Income and Expense Statement attached to this order as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. Information relating to professional licenses 7. other: ?(ou ne ems- ko+- a p p Qu r- I Service Type M if , f Y1 ?`(? eye I „ Form CM-508 Worker ID 21204 SARACINA V- KELLEY PACSFS Cue Number: 944100185 If you fail to appear for the conference or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court shall enter an order establishing paternity. BY THE COURT: Date of Order: ! i m Pp},, JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP: CUMBERLAND CO EAR ASSOCIATION 2 LIBERTY AVE CARLISLE PA 17013-3308-02 (717) 249-3166 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 at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference. Page 2 of 2 Form CM-508 Service Type M Worker ID 21204 Exhibit I In the Court of Common Pleas of CUMBEW AND County, Pennsylvania DOMESTIC RELATIONS SECTION P.O. BOX 310, CARLISLE, PA. 17013 Phone: (717) 2406225 MAY 24, 1999 Fax: (717) 2406248 Plaintiff Name: coRRla E. sARAcimA Defendant Name: JBRRY J. KELLEY Docket Number: 00530 S 1998 PACSES Case Number: 944100185 Other State ID Number: Please ames AO cerrtapomdente mat indode the PACSES Cue Number. CORRIH ELIZABETH SARACINA 43 LIBBRTY DR MOUNT HOLLY SPRINGS PA 17065-1024-4 Dear coRRIE ELIZABETH SARACINA The Q Appointment or ® Conference or O Hearing or O Exception Argument or Q Genetic test originally scheduled for im is, 1999 , has been cancelled. The defendant's mail has been returned by the post office. Sincerely, CHARLES CAROTHERS Form CM-015 Service Type M Worker lD 21200 Exhibit J In the Court of Common Pleas of CUM33ERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION CORRIE E. SARACINA Plaintiff VS. JERRY J. KELLEY Defendant Docket Number 00530 S 1998 PACSES Caw Number 944100165 Other State ID Number AND NOW, to wit on this 2ND DAY OF AUGUST, 1999 IT IS HEREBY ORDERED that the (j) Complaint for Support or Q Petition to Modify or Q Other filed on June 30, 1998 in the above captioned matter is dismissed without prejudice due to: Q The Complaint or Petition may be filed within one year from date hereof. Service Type M upon written application of the petitioner, if BY THE COURT: WESLEY JR., ' K JUDGE Form OE-506 Worker ID 21504 Exhibit K CORRIE E. SARACINA : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. : CIVIL ACTION -LAW : NO. CIVIL TERM JERRY J KELLEY yq - Uq 3 Defendant : IN CUSTODY AND NOW THIS day of 1999, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before at on the day of___, 1999 at A.M./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 BY THE COURT, BY YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF 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 CORRIE E. SARACINA Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Vs. JERRY J. KELLEY Defendant : CIVIL ACTION - LAW : NO. CIVIL TERM : IN CUSTODY COMPLAINT FOR CUSTODY i. Plaintiff is Come E. Saracina, an adult individual, currently residing at 15 Church Road, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Jerry J. Kelley, an adult individual, currently residing at 934 Route 910, Cheswick, Pennsylvania 15024. 3. Plaintiff seeks custody of the following child: James P. Kelley, age 1, born 3/30/1998. The child was born out of wedlock. The child is presently in the primary and exclusive custody of the plaintiff. The natural mother of the child is Come E. Saracina. She is single. The natural father of the child is Jerry J. Kelley. He is single. 4. The relationship of the Plaintiff to the child is that of natural mother. The plaintiff currently resides with the following persons: James W. Saracina (father), Minka A. Saracina (mother), and James P. Kelley (son). 5. The relationship of the Defendant to the child is that of natural father. He resides with: unknown. 6. Plaintiff has not participated as a party concerning the custody of the child in this 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: The child has lived in the care of his mother since birth, with no contact with the father for over a year. The last time that the father saw the child was on or about May of 1998, the last contact the mother had with the father was on or about July of 1998. 8. 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. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene. NAME ADDRESS BASIS OF CLAIM None WHEREFORE, Plaintiff requests your Honorable Court to: A) grant full legal and physical custody of the child to the plaintiff; B) grant such other relief as is just and in the best interest of the child. Respectfully submitted, Robert L. O'Brien, Esquire - O'BRIEN, BARIC 6t SCHERER 17 West South Street Carlisle, PA 17013 Date; 1999 (717) 249.6873 I verify that the statements made in the foregoing Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. CORRIE E. SARACINA DATE: b or I N /q9 ATTACHMENT,r2 Postmaster CHESWICK PA 15024 _ City, State, ZIT Codc . Date:ornA`R --Ur 1999 Request for Change of Address or Boxholder Information Needed for Soria of Legal process Please furnish the new address or die name and street address (if a boxholder) for the following: I'll Address: 934 R g10 CHEESSWTCK PA 15074 NOTE: Tho Dunn and last known address urn ragweed fore -------- baote of address information. The name, if known, and post office box address are required for boxholder information. vided Accord CFR boxholder Informatirmali710 r eo(or Prosviding change of iLh address oforrmation( a is wiw f with 39CFR 265.6(4)(1) and ved in accordance (2) and corresponding Administrative Support Manual 352.44. and b. 1. capacity of 2. Stalule or acting pro so server, attorney, party representing himself): gulation that empowers the to serve r exeOP' a eo P Process (not required when requester is an attorney or a party rpontion WIGS pro se must cite 3. The names of all koouv pnrtics to the 4. The court in which Wo case has born or will be heard: OUR F r`r1MMN DiFAS r1- (`. AFRI'A 5. The decd etr1or other tdeottfyf1 ing number If one has been issu«L TY, PENNSYLVANIA 6• The capacity Tn wltielt Wis individual is to be served (e.g. defendant or witness): WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER TNFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENAL'T'IES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF TIIE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (I-Mr: 18 U.S.C. SECTION 1001). I certify that the above information is true and that will be used solely for the addrav Information is needed and service ofliegal process in connection with actual or prospective litigation. 'a O'BRIEN, BAR IC b SCHERER 17 WEST SOUTH STREET " Signature Agdr= r ROBERT L. O'BRIEN CARLISLE, PENNSYLVANIA 17013 Printed Nune City, St¦ IPZto Code FOR POST OFFICE USE ONLY BOXHOLDER'S POSTMARK --No change of address order on rile. NEW ADDRESS or . Not known at address given NAME and STREET ADDRESS _, Moved, left oo forwarding address. No such address Z 013 324 572 I US PaW Swim Receipt for Certified Mail No In u arM COWWO PmAdA ewuw $ 0.3 3 Cw"Fw /, y0 IkwWD*mYF" 1'1 Exh?b;f N Law Offices O'BRrEN, Br(NC d SCHERER 17 Wert South Street Carlisle. Pennsylvania 17013 Robert L. O'Brien DmdA. Boric Mtchael A. Scherer October 25, 1999 Jerry G. Kelley 934 Route 910 Cheswick, Pennsylvania 15024 Re: Jerry J. Kelley Dear Mr. Kelley: (717)119.6873 Fax (717)119.3753 E-mail: obs®obs/aw,com direct: robrien®obslaw, com I represent Corrie Saracina and we are attempting to locale the father of her eon, Jerry J. Kelley. In response to papers that were sent to a Mr. Kelley at this address, my office received a call stating that they had reached the father of Jerry J. Kelley. I have left several messages on your answering machine, and have not had a response. I have enclosed a self-addressed stamped envelope and would appreciate It if you would provide me with the address and any other information you may have about the whereabouts of your son. Very truly yours, O'BRIEN, BARIC & SCHERER Robert L. O'Brien, Esquire RLO/af Enc. cc: C,orcje Saracina ile do.didlettersisaracina.llr ?g z Exh'?bi+ a m - CORRIE E. SARACINA IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. : CIVIL ACTION -LAW : NO. CIVIL TERM JERRY J KELLEY C?q - Wa93 Defendant : IN CUSTODY AND NOW THIS c0,2 day of 40?4 , 1999, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear ,at W. on before -<<_ S. `:Lde., f 4r the S day of Q&epla , 641999 at 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 conferenco. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order BY THE COURT, BY YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF CANNOT AFFORD ONE, GO TO OR TunimIONII'1'1If: 01--nCE. SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL I If-LP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249.3166 TRUE CJi'Y f;:' ^"r nRD and Iha seal cl rn my hand Fa. This c' ....G*n. ,y of Prolh0n413nt/ .. U? ?C7 7, f t i m to i' W n U ? h W ? > J m r 7 ? J V 4 .0 • •• 4 NOV _ • • ?Nf ., I ' Richard J. Pierce COURT ADMINISTRATOR a'??s:v 99??93 j!q .1 4?4 #4,j - Jerry J. Kelley nw ?, e e r .nr r.lt 1 ...y n-•1'?'^_ .1'yYcn r. r+ 1 S I 44 t r i F 5 CORRIE E. SARACINA, Plaintiff Vs. JERRY J. KELLEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA N0. 99-6293 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 1-34. day of , 2000, upon consideration of the attached Custody oncil ati Report, t is ordered and directed as follows: 1. The Mother, Corrie E. Saracina, shall have sole legal and primary Physical custody of James P. Kelley, born March 30, 1998. 2. The Father, Jerry. J. Kelley, may have visitation or partial Physical custody of the Child only as agreed upon and arranged by agreement between the parties. BY THE COURT, . cc: Robert L. O'Brien, Esquire - Counsel for Mother Jerry J. Kelley, Father TRJF Cony F^^,?4 Fi r.'•P.U In ?;: r, .; E. r, unto set rr; hard and tba tarkle, Pa, ut too ?. P othonotary 4 I CORRIE E. SARACINA, Plaintiff vs. JERf:Y J. KELLEY, Defendant PRIOR JUDGE: J. Wesley Oler, Jr. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6293 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITM CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned custody conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTn CURRENTLY IN CUSTODY OF James P. Kelley March 30, 1998 Mother 2. A Conciliation Conference was held on January 4, 2000, with the following individuals in attendance: The Mother, Corrie E. Saracina, with her counsel, Robert L. O'Brien, Esquire. The Father did not attend the Conference or contact the Conciliator. 3. Due to difficulty in locating the Father, the Mother's counsel obtained an Order from this Court dated November 13, 1999 permitting service by publication one time in a local newspaper and one time in the Cumberland Law Journal. The Mother's counsel provided documentation confirming proper publication of notice. 4. The Mother stated at the Conference that the Father has had no contact with the Child since may 1998, when the Child was 2 months old. 5. Based upon the foregoing, the Conciliator recommends an order in the form as attached. 6. It should be noted that although a copy of the proposed order and Report for the Father are attached, the Mother has no information as to the Father's whereabouts. The Mother's counsel had attempted service at the address of Mr. Kelley's father but was advised that he had no contact with Mr. Kelley whatsoever and threatened legal action if he were contacted again. ?G.hvd?wf .? ?OC)C! Date Dawn S. Sunday, Esquire C- Custody Conciliator CORRIE E. SARACINA, Plaintiff vs. JERRY J. KELLEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6293 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW# this lsi? day of 3 Z-'17 -j v , 2000, upon consideration of the attached custody Conc 1 ation Report, it is ordered and directed as follows: 1. The Mother, Corrie E. Saracina, shall have sole legal and primary physical custody of James P. Kelley, born March 30, 1998. 2. The Father, Jerry J. Kelley, may have visitation or partial physical custody of the Child only as agreed upon and arranged by agreement between the parties. BY THE COURT, cc: Robert L. O'Brien, Esquire - Counsel for Mother Jerry J. Kelley, Father Jr., 1-/3-00 RX3 z i :11111V C I We'r 00 CORRIE E. SARACINA, Plaintiff VS. JERRY J. KELLEY, Defendant PRIOR JUDGE: J. Wesley Oler, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6293 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPCRT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF James P. Kelley March 30, 1998 Mother 2. A Conciliation Conference was held on January 4, 2000, with the following individuals in attendance: The Mother, Corrie E. Saracina, with her counsel, Robert L. O'Brien, Esquire. The Father did not attend the Conference or contact the Conciliator. 3. Due to difficulty in locating the Father, the Mother's counsel obtained an order from this Court dated November 13, 1999 permitting service by publication one time in a local newspaper and one time in the Cumberland Law Journal. The Mother's counsel provided documentation confirming proper publication of notice. 4. The Mother stated at the Conference that the Father has had no contact with the Child since May 1998, when the child was 2 months old. 5. Based upon the foregoing, the Conciliator recommends an order in the form as attached. 6. It should be noted that although a copy of the proposed order and Report for the Father are attached, the Mother has no information as to the Father's whereabouts. The Mother's counsel had attempted service at the address of Mr. Kelley's father but was advised that he had no contact witty Mr. Kelley whatsoever and threatened legal action if he were contacted again. jcetvra,4 S. mood Date Dawn S. Sunday, Esquire Custody Conciliator zp? £A W ? ? ? ? a k g g 5 O e I ' 8E • ? •L ? CW v] t? t o . O ?M yRL ??. w JAN 10 2000rcl