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HomeMy WebLinkAbout01-6140STEVEN A. FIORINO, Plaintiff VICKI L. FIORINO Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA iNO. I~-'' (~1~0 CIVIL TERM : : CIVIL ACTION - CUSTODY : COMPLAINT FOR CUSTODY 1. Plaintiff is Steven A. Fiodno, an adult individual whose residence is at 520 Chestnut Street, Apt 2, Mount Holly Spdngs, Cumberland County, Pennsylvania. 2. Defendant is Vicki L. Fiodno, an adult individual whose residence is at 310 Chestnut Street, Mount Holly Spdngs, Cumberland County, Pennsylvania. 3. Plaintiff seeks partial custody of his child Samantha Nicole Fiodno, bom July 21, 1992, currently residing at 310 Chestnut Street, Mount Holly Spdngs, Cumberland County, Pennsylvania in accordance with the following schedule: a. Every other weekend from Fdday at 6:00p.m. through Sunday at 6:00p.m. b. One full week, dudng summer school vacation. The parties shall give 30 days written notice of the week or chosen. c. Alternating holidays from 8:00a.m. to 6:00p.m. The holidays shall be New Year's Day, Memorial Day, 4th of July, Labor Day and Thanksgiving Day, with the father having custody on Thanksgiving Day, 2001. d. The parties shall altemate the Christmas holiday. The father shall have custody of the child from noon Christmas Eve until noon Christmas Day in odd numbered years and the mother shall have this period in even numbered years. The mother shall have custody of the child from noon Christmas Day until noon December 26 in odd numbered years and the father shall have this period in even numbered years. Mother shall have physical custody from 8:00a.m. until 6:00p.m. on Mother's Day and Father shall have physical custody from 8:00a.m until 6:00p.m. on Father's Day. 5. addresses: Name Parents Parents Parents Parents The child is presently in the custody of Defendant. Since the children's births, the children have resided at the following Address 310 Chestnut St. Mt. Holly Springs, PA 109 N. Baltimore Ave. Mt. Holly Springs, PA 8151 New Jersey Blvd. Ft. Myers, FL 33912 North Meadows Lane Hiawassee, GA Dates 9/01 to present 7/01 - 9/01 5/99 - 7/01 10/95 - 5/99 6. The relationship of the Plaintiff to the children is that of natural father. 7. The relationship of the Defendant to the children is that of natural mother. 8. The Plaintiff has not participated as a party or in any other capacity, in other litigation concerning the custody of the child in this or any other Court. 9. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 10. The best interest and permanent welfare of the child will be served by granting the relief requested because the Plaintiff has a close relationship with the child. 11. Each parent whose parental dghts to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. Not other persons are known to have or claim to have any right to custody or visitation of the child other than the parties to this action. WHEREFORE, Plaintiff requests your Honorable Court appoint a custody conciliator to mediate this case. Respectfully Submitted TURO LAW OFFICES Date Robert 28 South Pitt Street Carlisle, PA 170'13 (717) 245-9588 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date/ Steven A. Fiorino STEVEN A. FIORINO, Plaintiff VICKI L. FIORINO Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0~- ~ 15to CIVIL TERM CIVIL ACTION - CUSTODY ORDER ANDNOW, this )~'~ dayof ~-~C.')~' . 2001, based on the attached Petition, it is hereby ordered that neither Plaintiff nor Defendant may remove the child, Samantha Nicole Fiodno, from the Commonwealth of Pennsylvania without prior permission of this Court, pending a Custody Conciliation. ~.c. C~'~ ~',/'/C.~m c~c,~ ~ ~,~ ~ BY THE COURT, STEVEN A. FIORINO, Plaintiff VICKI L. FIORINO Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA r :NO. 0~- ~'/~/~ CIVIL TERM CIVIL ACTION - CUSTODY PETITION FOR SPECIAL RELIEF AND NOW comes the Plaintiff, Steven A. Fiorino, by and through his attorney, Robert J. Mulderig, Esquire, and file the following Petition for Special Relief: 1. Plaintiff is Steven A. Fiorino, an adult individual whose residence is at 520 Chestnut Street, Apt 2, Mount Holly Springs, Cumberland County, Pennsylvania. 2. Defendant is Vicki L. Fiorino, an adult individual whose residence is at 310 Chestnut Street, Mount Holly Springs, Cumberland County, Pennsylvania. 3. On this date Plaintiff has filed a Complaint seeking custody of his child, Samantha Nicole Fiorlno, to the above docket number. 4. Plaintiff believes and therefore avers that based on statements made by the Defendant to him, she is likely to remove the child from the jurisdiction of this Court once she is served with the Custody Complaint. WHEREFORE Petitioner respectfully requests this Court to issue an Order that pending a Custody Conciliation that neither party may remove the child from the Commonwealth of Pennsylvania without prior permission of the Court. Respectfully Submitted TURO LAW OFFICES Robert J M~l'dedg, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff SHERIFF'S RETUPlq CASE NO: 2001-06140 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CLrMBERLAND FIORINO STEVEN A VS FIORINO VICKI L - REGULAR SH3IAFNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - CUSTODY was served upon FIORINO VICKI L the DEFENDANT , at 1315:00 HOURS, on the 30th day of October at 310 CHESTNI3T STREET 2001 MT HOLLY SPRINGS, PA VICKI L FIORIN0 a true and attested copy of COMPLAINT PETITION FOR SPECIAL RELIEF AND ORDER by handing to - CUSTODY together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.90 Affidavit .00 Surcharge 10.00 .00 31.90 Sworn and Subscribed to before me this ~ ~-~ day of 7~c~ ~ .2~g9[ A.D. ~-tfrothonotary, , So Answers: R. Thomas Kline 10/31/2001 ROBERT J MULDERIG Deputy Sheriff STEVEN A. FIORINO PLAIN HI?F V. VICKI L. FIORINO DEFENDANT 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 01-6140 CIVIL ACTION LAW : : 1N CUSTODY AND NOW, Thursday, November 15, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jaequeline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, December 05, 2001 at 10:30 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 bc 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: /s/ .[acqueline 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 HAVE 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 STEVEN A. FIORINO, Plaintiff VICKI L. FIORINO Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 0~.- ~,l~-/O CIVIL TERM : CIVIL ACTION - CUSTODY PRAECIPE TO THE PROTHONOTARY: Please seffle, withdrawand discontinue the above-captionedmatter on behalf of the Plaintiff. Date Respectfully Submitted TURO LAW OFFICES 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff STEVEN A. FIORINO, Plaintiff V. VICKI L. FIORINO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : : NO. 2001-6140 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this l0th day of December, 2001, the Conciliator being notified that the parties have reconciled, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, flacq~eline M. Verney, Esquire, Cu~'dy Conciliator