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HomeMy WebLinkAbout07-4080JOSEPH ANTHONY BARTOLO, PLAINTIFF vs. RUTH A. KELLER, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ©~ - `~~pd CIVIL TERM CIVIL ACTION -LAW IN CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment maybe entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Defendant(Petitioner. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle PA 17013 (717) 249-3166 1-800-990-9108 JOSEPH ANTHONY BARTOLO, PLAINTIFF vs. RUTH A. KELLER, :CIVIL ACTION -LAW DEFENDANT : IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, JOSEPH ANTHONY BARTOLO, by and through his counsel, Susan Kay Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P.C., and files this Complaint for Custody upon a cause of action of which the following is a statement: 1 • The Plaintiff (hereinafter sometimes referred to as "Father") is JOSEPH ANTHONY BARTOLO, who currently resides at 2506 Warren Way, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. The Defendant (hereinafter sometimes referred to as "Mother") is RUTH A. KELLER, who currently resides at 502 North Baltimore Avenue, Mount Holly Springs, Cumberland County, Pennsylvania, 17065. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. d7- yoga CIVIL TERM 3. Plaintiff seeks Shared Legal and Primary physical Custody of the following child: Name Present Residence Date of B~rt6 ANTHONY JOHN BARTOLO 2506 Warren Way Mechanicsburg, PA 4• The child was born out of wedlock. November 14, 2004 5. The child is presently in the custody of the Plaintiff, who resides at 2506 Warren Way, Mechanicsburg, Cumberland County, Pennsylvania, 17050 6. Since birth the child has resided with the following persons at the following addresses: PERSONS ADDRESS DATES Plaintiff and Defendant Plaintiff and Defendant Plaintiff Plaintiff and Defendant (Shared Physical Custody) Plaintiff Plaf ntf ff and Defendant (Shared Physical Custody) Cazlisle, PA Pittsburgh, PA Mechanicsburg, PA Mechanicsburg, PA Mount Holly Springs, PA Mechanicsburg, PA Mechanicsburg, PA Mount Holly Springs, PA Birth to Mazch, 2005 Mazch, 2005 to August, 2005 March, 2006 to October, 2006 October, 2005 to Mazch, 2007 Mazch, 2007 to May, 2007 May, 2007 to Present 7. The Mother of the child is the Defendant, Ruth A. Keller, who currently resides at 502 North Baltimore Avenue, Mount Holly Springs, Cumberland County, Pennsylvania, 17065. 8. The Father of the child is the Plaintiff, Joseph Anthony Bartolo, who currently resides at 2506 Warren Way, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 9. The relationship of the Defendant, Ruth A. Keller, to the child is that of the Natural Mother. Mother resides at 502 North Baltimore Avenue, Mount Holly Springs, Cumberland County, PA 17065. 10. The relationship of the Plaintiff, Joseph Anthony Bartolo, to the child is that of the Natural Father. Father currently resides at 2506 Warren Way, Mechanicsburg, Cumberland County, PA 17050. 11. The 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. 12. Plaintiff has not participated as a party in any prior custody agreement concerning the custody of the child in any other court in Pennsylvania, 13. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth at this time. 14. The best interests and permanent welfare of the child will be served by granting the relief requested because: A• Father has always been the primary care giver for his son; B• Father provides health care insurance for his son and has taken his son to every medical check up or treatment he has ever needed. Mother refuses to and has never taken the child for any medical care or treatment; C• While in Mother's care the child was sprayed with bleach fn his eyes, Mother did nothing but call Father resulting in a delay in obtaining treatment for the child. The child was temporarily blind for two (2) weeks; D• While in Mother's caze the child was allowed to climb up on the counter and put his hand on an open hot burner on the stove, resulting in first and second degree burns to his hand. Again, Mother did nothing but call Father, once more resulting in a delay in treatment for the child; E• Mother frequently consumes alcohol while the child is in her care has a beer miester sitting in her kitchen and alcohol within the child's view and reach; F• Mother has frequently called Father to come to take the child, stating she could not handle him and did not want him. Mother complains the child does not behave, but when with Father and in the day caze Father uses, his son behaves without any problems and in fact, the day care employees comment he is a wonderful little boy; G• When with Father his son drinks from a cup and is potty trained• When with Mother the child drinks from a bottle and wears diapers; H• When with Mother the child's bedroom is in a laundry room, sal, cramped, and extremely dirty (as is Mother's home). In the event of a fire, there would be no way to get to the young child out of the burning home if he were in his bedroom/laundry room; 1• The child frequently comes from the care of Mother extremely d~3'~ with severe diaper rashes; J: The child gets nasty blisters on his feet from running about outside without any shoes or socks on; K• The child frequently comes to Father with bruises all over his ~dy, on occasion the bruise is in the shape of a hand; L• Mother and her boyfriend, Steven Hasenbein, constantly smoke in the presence of the child; M• Mother recently telephoned Father to share she and her boyfriend had just gotten rickets to see Genesis, the tickets were $1,400.00. Mother frequently calls Father stating she does not have money to buy diapers and asks Father for money; N• Mother called Father July 2, 2007, stating to Father she could not handle the child and had locked herself in her bedroom with her headphones on while the child screamed and pounded on the door for three (3) hours when she finally came out and grabbed the child, slapped him across the face, asking him if he was done crying and called the Father to come get him; ~-• Father greatly fears for the safety and well-being of his child while in the care and at the home of Mother. 15. Each parent whose parental rights 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. R'HEREFORE, Plaintiff, JOSEPH ANTHONY BARTOLO, requests this Hono Court award the Plaintiff, JOSEPH ANTHONY BARTOLO and the Defendant rable KELLE S 'RUTH A• R, HARED LEGAL CUSTODY of the parties' minor child, ANTHONY JOHN BARTOLO and .the Plamt~ff, JOSEPH ANTHONY BARTOI.O, PRIMARY PHY CUSTODY and the Defendant RUTH A, KELLE p SICAL Ry ~TI~ PHYSICAL. CUSTODY of the minor child, ANTHONY JOHN B~1'OLO. Respectfully submitted, LAt~V FIRM OF SUSAN KAY CANDIBLLO, P.C. Dated: July ~, 2007 Susan Kay C Counsel for f' inti PA LD. #649 8 4010 Glenfinnan place Mechanicsburg PA 17055 (717) 724-2278 VERIFICATION The undersigned hereby verifies that the facts averred in the foregoing document are and correct to the best of her knowledge, information, and belief. This verification is true subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification made to authorities. DATED: tj ~~ J EP ANTHONY B O "~ .a P OO '~- C~ c_N-.a-.a C~ C':" ~'=~ 'il ,.~ _ ~... qg ,, 93 ~ ~ rn _ ,. ~ ~ - tti7 r i_3 b ~ -' ~ ~~J i7 0 * _ JOSEPH ANTHONY BARTOLO IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. RUTH A. KELLER DEFENDANT • 07-4080 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, July 13, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, August 23, 2007 at 8:30 AM for aPre-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: _ /s/ Hubert X. Gllro Es . 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 oftice. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 _~~ ~~` -~~/~ ~~" ?~ ~ J~ _ I ..1hr d_~"j_('2 ~l'~~~ .`11_1;',.. ,_, ,. t.! i• SHERIFF'S RETURN - REGULAR CASE NO: 2007-04080 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BARTOLO JOSEPH ANTHONY VS KELLER RUTH A SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - CUSTODY was served upon KELLER RUTH A the DEFENDANT at 0948:00 HOURS, on the 13th day of July 2007 at 502 NORTH BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA 17065 by handing to RUTH KELLER a true and attested copy of COMPLAINT - CUSTODY together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.76 Postage .41 Surcharge 10.00 .00 $Jia/~7 (,~,, 34.17 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline i 07/16/2007 SUSAN KAY CAN LLO r By: Deputy Sheriff of A.D. R .ti DEC~'t9B~ V JOSEPH ANTHONY BARTOLO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION -LAW RUTH A. KELLER, N0.2007-4080 Defendant IN CUSTODY COURT ORDER AND NOW, this ~Z ~ day of December, 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The father, Joseph Anthony Bartolo, and the mother, Ruth A. Keller, shall enjoy shared legal and shared physical custody of Anthony John Bartolo, born November, 14, 2004. 2. Physical custody shall be handled with the parties attempting to reach a general shared physical custody arrangement. However, at a minimum, the schedule shall be as follows: A. The father shall have the minor child from Wednesday through Thursday of every week consistent with the schedule the parties have already implemented. B. The father shall have the minor child from Friday through Monday morning consistent with the schedule the parties have implemented. C. Mother shall have custody of the minor child during other times. 3. The parties may work between themselves to modify or coordinate the above custody arrangement. It is anticipated the parties will communicate with each other for the benefit of the child to arrange a general shared physical custody situation. __ .. _ _~ • ~- court to have the case again scheduled with the Custody Conciliator for a conference to consider modification of this custody order. BY THE COURT, .4~(~ Judge 4. Both parties shall be entitled to at least one week of vacation with the minor child as long as reasonable notice is provided. Additionally, the parties shall work between themselves with respect to coordinating custody on holidays, birthdays, etc. as they may agree. 5. In the event the above schedule becomes unworkable, either party may petition the cc: ~san Kay Candiello, Esquire Ruth A. Keller J .., JOSEPH ANTHONY BARTOLO, Plaintiff v RUTH A. KELLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2007-4080 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Anthony John Bartolo, born November 14, 2004. 2. A Conciliation Conference was held on December 7, 2007, with the following individuals in attendance: The father, Joseph Anthony Bartolo, with his counsel, Susan Kay Candiello, Esquire, and the mother, Ruth A. Keller, who appeared without counsel. 3. The parties agree to the entry of an Order in the form as attached. Date: ~-~ L~ v G ~. Hubert X. Gilroy squire Custody Conciliator w..~ sa~oa~~ JOSEPH ANTHONY BARTOLO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION -LAW RUTH A. KELLER, N0.2007-4080 Defendant IN CUSTODY COURT ORDER AND NOW, this 7 ~ day of ~ 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed s follows: A hearing is scheduled in Court Room No. 4 of the Cumberland County Courthouse on the ~ y*~ day of , 2008 at ~~ m. At this hearing, the father shall be the moving party and shall roceed initiall wifh testimon .Counsel for the Y Y parties shall file with the Court and opposing counsel a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, the Order of December 12, 2007 shall remain in effect subject to the following clarification: A. The time for father's periods of temporary custody under paragraph 2(B) of the Order is clarified to note that father's time from Friday through Monday is on an alternating weekend schedule. BY THE COURT, cc: `Susan Kay Candiello, Esquire /Carol J. Lindsay, Esquire Judge vin A. Hess 1.~0 ti ~.S mS~ ~c~._. al~~~~S ~~ E"ii...Gi +. "+~_. _ ~F Ti-1F "~ " ~ "~ ~ '~ ~ ,~~Y 208 FHB _~ A~ ! i ~ ~ C~~i1} ,_iJ~Yf ;~ f _~ JOSEPH ANTHONY BARTOLO, Plaintiff v RUTH A. KELLER, Defendant Prior Judge: Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2007-4080 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Anthony John Bartolo, born November 14, 2004. 2. A Conciliation Conference was held on January 25, 2008, with the following individuals in attendance: The father, Joseph Anthony Bartolo, with his counsel, Susan Kay Candiello, Esquire, and the mother, Ruth A. Keller, with her counsel, Carol J. Lindsay, Esquire. Date 3. The parties were before the Conciliator this past September at which time an agreement was reached and Judge Hess signed an Order dated December 12, 2007. Father is now dissatisfied with that Order and is seeking additional time. The parties are unable to reach an agreement and a hearing is required. 4. The Conciliator recommends an Order in the form as attached. ~~a~--og Hubert X. Gilroy, Esqu' e Custody Conciliator ( '~ JOSEPH ANTHONY BARTOLO, PLAINTIFF vs. RUTH A. KELLER, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-4080 CIVIL TERM CIVIL ACTION -LAW IN CUSTODY PRAECIPE FOR WITHDRAWAL OF COMPLAINT AND NOW, comes the Plaintiff, JOSEPH ANTHONY BARTOLO, by and through his counsel, Susan Kay Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P.C., and requests to Withdraw the Complaint Custody Modification in the above matter Without Prejudice. Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO, P.C. Dated: May 1, 2008 \~~t Susan Kay Candiello, sqi Counsel for Plaint' PA I.D. #64998 4010 Glenfinnan Place Mechanicsburg PA 17055 (717) 724-2278 C"'.~ ^,~ ~~ ~, }-~ ~~ ~ ; ~,-: c €.n ` ;,~ TM; -,; ry t~,~ .. .. . _a . JOSEPH ANTHONY BARTOLO, PLAINTIFF vs. RUTH A. ICELLER, DEFENDANT (7 _N IN THE COURT OF COMMON PL~S ~,;. ~-. OF CUMBERLAND COUNTY, -, ~ ~ ' _ PENNSYLVANIA - `"' N NO. 07-4080 CIVIL TERM ~ `~ . =- rv :CIVIL ACTION -LAW .'4 ~' IN CUSTODY -.~ PETITION FOR I!VIODIFICATION OF CUSTODY ORDER AND NOW, comes the',Plaintiff, MATTHEW AUDETTE, by and through his counsel, Susan Kay Candiello, Esquire, and files this Petition for Modification of Custody Order upon a cause of action of which the following is a statement: 1. The Plaintiff is JOSEPH ANTHONY BARTOLO who currently resides at 160 BrynWay, Mt. Wolfe, Pennsylvania, 17347. 2. The Defendant i$ RUTH A. KELLER, who currently resides at 45 Brian Drive, Carlisle, Cumberland County, Pennsylvania, 17015. 3. Plaintiff seeks Fwll Legal Custody and Primary Physical Custody of the following child: Name Present Residence Date of Birth ANTHONY JOHN BARTOLO 45 Brian Drive November 14, 2004 Carlisle, PA 4. The child was born out of wedlock. 5. The child is pres$ntly in the Primary Physical custody of Defendant who resides at 45 Brian Drive, Carlisle, PA, '17013. ~70.OO ~ D A'TT"/ ~~r f x-0(0 a39a5? ~7 ~~ r} r~ ~~r~r 6. During the past five (5) years, the child has resided with the following persons at the following addresses: Names Address Dates Plaintiff and Defendant Carlisle, PA Birth to March, 2005 Plaintiff and Defendant Pittsburgh, PA March, 2005 to August, 2005 Plaintiff ~ Mechanicsburg, PA March, 2006 to October, 2006 Plaintiff and Defendant Mechanicsburg, PA October, 2006 to March, 2007 (Shared Physical Custody) Mount Holly Springs, PA Plaintiff Mechanicsburg, PA March, 2007 to May, 2007 Plaintiff and Defendant Mechanicsburg, PA May, 2007 to 2008 (Shared Physical Custody) Mount Holly Springs, PA Plaintiff and Defendant Carlisle, PA 2008 to Present Mt. Wolfe PA 7. The mother of the child is Defendant whose current address is 45 Brian Drive, Carlisle, PA 17015. 8. Plaintiff and Defendant have never been married. 9. The father of the child is Plaintiff, who currently resides at 160 BrynWay, Mt. Wolfe, PA, 17347. 10. Defendant is married. Defendant currently resides with her husband, Steven Hasenbein, her daughter to another father, Laney Keller, and a new baby, Peyton Hasenbein. 11. Plaintiff is married. Plaintiff resides with his wife, Jodie Bartow and their daughter, Danielle Bartolo. 12. Plaintiff has participated as a party in a prior custody agreement concerning the custody of the child in this court. The court, term and number, and its relationship to this action are as follows: the court was Cumberland County, the docket number is 2007-4080, the result was a custody order which is attached hereto and made a part hereof as Exhibit "A". 14. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth at this time. 15. 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. 16. The best interest and permanent welfare of the child will be served by granting the relief requested because: A. Plaintiff is a disabled veteran and a stay at home Father. B. Father takes time to read and be active and involved with his son. Father avid son are very, very close. Recently, the child has expressed extreme behaviors when he must leave his Father. C. Father is extremely concerned his son is not able to even spell his own name is experiencing other types of learning difficulties. D. Over all the child has recently been demonstrating negative behaviors, using derogatory language, cursing, being more aggressive, even to the point of extreme temper tantrums when he cannot bel, with his Father. E. The child'.has woken up with nightmares while in Father's care, sharing with Father examples of nightmares which are the same as the child experiences with his Step-Father who primary activity with the child is to play violent video games in the presence of and with the child. F. Mother has a young daughter at home who has behavioural and learning problems and who demonstrates similar extreme temper tantrums. Mother also has a new baby. G. Father does not believe Mother has taken the time or will take the time to interact with the child in a positive manner to assist the child with his difficulties and move forward in a positive manner with learning; H. Father believes he can provide an focused, stable, safe, nurturing environment more conducive to helping his son progress in educational and life skills; Father dries not wish to keep Mother from the child, Father supports regular visitation with Mother, but, strongly believes, the child wild have more opportunity and encouragement to learn and become the best he is able to be in Father's care; J. Father believes it is in his son's best interest to be with Father increasedjtime given how close he is with his son, the time he can devote solely to his son and the psychological needs his son is demonstri~ting. 17. Each parent whose parental rights to the child have not been terminated and the person who has physical cujstody of the child have been named as parties to this action. WHEREFORE, Plaintiff, JOSEPH ANTHONY BARTOLO, requests this Honorable Court continue Shared Legal Custody between the parties, and grant him PRIMARY PHYSICAL CUSTODY, with PARTIAL PHYSICAL CUSTODY in the Defendant, RUTH A. KELLER, of the minor chid, ANTHONY JOHN BARTOLO. Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO, P.C. Dated: March 19, 2010 ~.usan Kay Candiello, Counsel for Plaint' PA LD. # 64998 4010 Glenfinnan e Mechanicsburg PA 17055 (717)724-2278 VERIFICATION The undersigned hereby verifies that the facts averred in the foregoing document are true and correct to the best of her knowledge, information, and belief. This verification is made subject to the penalties of 18 P~. C.S.A. §4904 relating to unsworn falsification to authorities. DATED: ~~ D - ~ ~ JOB ANTHONY BA~T~9L0 JOSEPH ANTHONY BARTOLO, PLAINTIFF vs. RUTH A. KELLER, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-4080 CIVIL TERM CIVIL ACTION -LAW IN CUSTODY ORDER AND NOW, this day of 2010, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before the conciliator, at on the day of , 2010, at -o'clock _ .m., for the 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 shall also be present at the conference. Failure to appear at the conference may provide for entry of a temporary or permanent order. FOR THE COURT, BY: Custody Conciliator YOU SHOULD TAKE ')[PHIS 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 OUP' WHERE YOU CAN GET LEGAL HELP. Court Administrator Fourth Floor, Cumberland County Courthouse 1 Courthouse Square Carlisle PA 17013 ((717) 240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Plus of Cumberland County is required by law to comply with the Americans with Disabilities Act of x,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 ade at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. EXHIBIT "A" ~~ ~~z~ JOSEPH ANTHONY BARTOLO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAi~TD COUNTY, PEN~TSYLVAI~IIA v CNIL ACTION -LAW RUTH A. KELLER, N0. 2007-4080 Defendant IN CUSTODY COURT ORDER AND NOW, this ~ day of~ 2008, upon consideration of the attached Custody Conciliation Report, it is ordere ,and directed follows: A hearing is scheduled iii Court Room No. 4 of the Cumberland County Courthouse on the _~'~-day of , 2008 at ~ m. At this hearing, the father shall be the moving party and shall roceed initially testimony. Counsel for the parties shall file with the Court and oppo ing counsel a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses~who will be called to testify on behalf of each party and a summary of the anticipated testim~ny of each witness. This memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order o$this Court, the Order of December 12, 2007 shall remain in effect subject to the following clarification: A. The time for fatner's periods of temporary custody under paragraph 2(B) of the Order is clarified to note that father's time from Friday through Monday is on an alternating weekend schedule.. ,' . BY THE COURT, udge Kevin A. Hess cc: Susan Kay Candiello, Esquire Carol J. Lindsay, Esquire •.a . _ ~,. ~ ... .c._; ,~.~,... ._.~. D'~C 14 ?F~; , , JOSEPH ANTHONY BAR!TOLO, Plaintiff v RUTH A. KELLER, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2007-40$0 IN CUSTODY COURT ORDER AND NOW, this 12-~ day of December, 2007, upon consideration of the attached Custody _-.-.. Conciliation Report, it is ordered and directed as follows: 1. The father, Jaseph iAathony Bartolo, and the mother, Ruth A. Keller, shall enjoy shared legal and shred physical custody of Anthony Jahn Bartolo, born November, 14, 2004. 2. Physical custody shill be handled with the parties attempting to reach a general shared physical custody arrangement. However, at a minimum, the schedule shall be as follows: A. The father shall have the minor child from Wednesday through Thursday of i every week consistent with the schedule the parties have ah~eady implemented. B. The father shall have the minor child from Friday through Monday morning consistent:. wit the: schedule ;the parties have :implemented. C. Mother shall have custody of the minor child during other times. 3. The parties may wor~ between themselves to modify or coordinate the above custody arrangement. It is anticipated the parties will communicate with each other for the benefit of the child to~ arrange a general shared physical custody situation. 4. Both parties shad be entitled to at least one week of vacation with the minor child as long as reasonable notice is provided. Additionally, the parties shall work between themselves with I, respect to coordinating custody on holidays, birthdays, etc. as they may agree. 5. In the event the j above schedule becomes unworkable, either party may petition the court to have thecase again scheduled with the Custody Conciliator for a conference to consider modification of this custody order. BY THE COURT, s Judge cc: Susan Kay Candi~ello, Esquire Ms. Ruth A. Keller T1~t1fi COPY :~R~1 R.E~O~Zd to T imony whereof,-1 here un`~ ~t mY hand ar+ t e sea of s~ - r arlisle, Pa. `r~~'.., Y ~. .. day f......_ ...... i.eu~ntaN. JOSEPH ANTHONY BARTOLO IN THE COURT OF COMMON PLEAS OF PLA[NT[FF CUMBERLAND COUNTY, PENNSYLVANIA ~~' 2007-4080 CIVIL ACTION LAW RUTH A. KELLER IN CUSTODY DEFENDANT ORDER OF COURT AN}) NOW. Friday, March 26, 2010 ___ _ ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator, at 4th Floor ,Cumberland County Courthouse, Carlisle on Thursday, Apri129, 2010 at 8:30 AM for aPre-l~-lea-mg 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. 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/ Hubert X. Gilroy, Esq. ,~~ _____ Custody Conciliator ~ --- The Court of Common Pleas of Cumberland County is required by law to comply with t11e 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 TH1S PAPER TO YOUR ATTORNEY AT ONCE. IF YOUtf~O N~'T •-- HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFI~E Sly ' F<)RTII BELOW' TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ~~ ('p~ ~~~u~mberland County Bar Association ~ ,'~.~: ~ z 3 ' vZ ~ • ~ ~ `~' ~~ 32 South Bedford Street `- ~~~~~ _,•~ -~,.-~ `-~; ~~ (~,~~~~~ Carlisle, Pennsylvania 17013 ~.;-"" 4=~~`~ ~•~-~-' ~-' Telephone (717) 249-3166 ~ ~:~ n~ ~+~ j . 02 Cv • (6 N 0-F; cL mow ~ ~~ '~ =~ r -_ ~-~ . 3 ~ acs ~ t o c~~ ~1ac~.~1 ~ n G'~\co~S -~i 1 ~ . JOSEPH ANTHONY BARTOLO, Plaintiffs vs. RUTH A. KELLER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-4080 CIVIL ACTION -LAW IN CUSTODY ORDER AND NOW, this ~'~ ~ day of May, 2012, the above case being previously assigned to the Conciliator and there being no activity on this case for a period of six months or more, the Conciliator relinquishes jurisdiction. ~,y~. Hubert ~. Gilroy, Esquire Custody Conciliator , . _~ , - .-, ' ..~ 1 - . .. C.:.`) .. T .. ._ !.l