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HomeMy WebLinkAbout03-6291Heather L. Patemo, Esquire LD, #87506 GOLDBERG, KAIZMAN & SHiPMAN. P.C 320 Market Street P. O. Box 1268 Hanishurg, PA 17108-1268 (717) 234-416I;(717)234-4161 (facsimile) Counsel for Plaintiff MARY T. LONG, Plaintiff LORRAiNE C. CARRAI, Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. O,_,~ - 60 ~q t CUSTODY/VISITATION NOTICE TO DEFEND YOU HAVE BEEN SUED 1N 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 may be entered against you by the Coud without further notice for any money claimed in the Complaint or for any other claim or 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH iNFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 GOLDBERG, KATZMAN & SHIPMAN, P.C. Heather L. Patemo - I.D. #87506 Attorneys for Plaintiff 320 Market Street, P.O. Box 1268 Hamsburg, PA 17108-1268 (717) 234-4161 MARY T. LONG Plaintiff, LORRAINE C. CARRAI Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CiVIL ACTION - LAW CUSTODY/VISITATION COMPLAINT FOR CUSTODY 1. Plaintiff is MARY T. LONG, who currently resides at 115 East Ridge, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is LORRAINE C. CARRAI, who currently resides at 600 Big Spring Road, Newville, Cumberland County, Pennsylvania. 3. Plaintiff seeks primary legal custody and primary physical custody of: Name: Aeryiona Abagail Carrai, bom October 30, 1996 Present Residence: 115 East Ridge, Carlisle, Cumberland County, Pennsylvania The child was bom out of wedlock. 4. The child presently resides with Mary Long, Plaintiff herein, and her husband John Long at 115 East Ridge, Carlisle, Cumberland County, Pennsylvania. For the past five years, the child has lived with the following persons and at the following addresses: 7/03 - present 115 East Ridge Carlisle, Pennsylvania with Plaintiff and Plaintiff's husband, John Long 5/03 - 7/03 15 East King Street Apartment #9 Shippensburg, Peimsylvania with Defendant 8/02 - 5/03 115 East Ridge Carlisle, Pennsylvania with Plaintiff and John Long 9/01 - 9/02 2041 Martins Way Martinsburg, West Virginia with Defendant 1/01 - 9/01 161 North College Street, # 1 Carlisle, Pennsylvania with Defendant, Jene Thomas and John Keller 1997 - 1/01 600 Big Spring Road Newville, Pennsylvania with Defendant and maternal grandfather, Edward B. Carrai The mother of the child is LORRAINE C. CARRAI, defendant herein, who currently resides at 600 Big Spring Road, Newville, Cumberland County, Pennsylvania. She is not married. The father of the child is Diaunta S. Evans, who is believed to reside at 160 North Pitt 2 Street, Carlisle Pennsylvania. He has had no contact with the child, nor made any effort to contact the child since birth. 5. The relationship of Plaintiff to the child is that of maternal grandmother. Plaintiff currently resides with the child and husband John Long at 115 East Ridge, Carlisle, Cumberland County, Pennsylvania. 6. The relationship of Defendant Lorraine C. Carrai to the child is that of mother. Defendant currently resides with her father, Edward B. Carrai. 7. The best interests and permanent welfare of the child will be served by granting the relief requested. 8. Plaintiff has not participated as a party, witness or in another capacity or in other litigation concerning custody of the child in this or another court. 9. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child are aware of this action. 10. The parties have agreed that Plaintiff shall have primary legal and physical custody of the child, Aeryiona Abagail Carrai. 11. This Complaint is accompanied by the parties' Stipulation for Entry of Custody Order which they respectfully request that this Honorable Court approve, thereby implementing their agreement. 3 WHEREFORE, Plaintiff respectfully requests that the court grant her primary legal and physical custody of the child, Aeryiona Abagail Carrai. Respectfully submitted, ~MAN, P.C. /Hv~ather L Pat~rffo, Esquire I.D. # 87506 320 Market Street, P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorneys for Plaintiff VERIFICATION I verify that the statements contained in the foregoing COMPLAINT FOR CUSTODY are true and correct to the best of our knowledge, information and belief. I understand that false statements contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworu falsification to authorities. Date: ,2003 MARY T. LO~ GOLDBERG, KATZMAN & SHIPMAN, P.C. Heather L. Paterno - I.D. #87506 Attorneys for Plaintiff 320 Market Street, P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 MARY T. LONG Plaintiff, LORRAINE C. CARRAI Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CUSTODY/VISITATION STIPULATION FOR ENTRY OF CUSTODY ORDER AND NOW, this'-"~ ~ day of November 2003, the parties agree and stipulate to the following custody order: 1. Plaintiff, MARY T. LONG, shall have primary physical custody of the child, AERYIONA ABAGAIL CARRAI. Plaintiff shall have primary legal custody of the child. Mother, LORRAINE C. CARRAI, shall have temporary custody of the child from time to time as the parties shall mutually agree. }/le~ither L3Fatemo, Esquire ~}oldberg, Katzman & Shipman, P.C. -"320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Plaintiff MARY T. I~DNG, Plaintiff STATE OF PENNSYLVANIA COUNTY OF DAUPHIN SS: On this, the,~1] ~ day of November, 2003, before me, the undersigned officer, personally appeared MARY T. LONG, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the Stipulation for Entry of Custody Order for the purposes therein contained. 1N WITNESS WHEREOF, I hereunto set my hand and official seal. STATE OF PENNSYLVANIA COUNTY OF DAUPHIN otary Public SS: On this, the c~]~'~- day of November, 2003, before me, the undersigned officer, personally appeared LORRAINE C. CARRAI, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the Stipulation for Entry of Custody Order for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. (J ' Notary Public Heather L. Patemo, Esquire I.D.//87506 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P. O Box 1268 Ha~Hsburg, PA I7108-1268 (7 ] 7) 234-416 ]; (7 ] 7) 2344 16 l (~csimile) Counsel for Plaintiff MARY T. LONG, Plaintiff LORRAINE C. CARRAI, Defendant 1N THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. O,..¢ - C2 CUSTODY/VISITATION NOTICE TO DEFEND 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 may be entered against you by the Couti wi{hout further notice for any money claimed in the Complaint or for any other claim or 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 GOLDBERG, KATZMAN & SHIPMAN, P.C. Heather L. Patemo - I.D. #87506 Attorneys for Plaintiff 320 Market Street, P.O. Box 1268 Hamsburg, PA 17108-1268 (717) 234-4161 MARY T. LONG Plaintiff, LORRAINE C. CARRAI Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. CUSTODY/VISITATION COMPLAINT FOR CUSTODY 1. Plaintiff is MARY T. LONG, who currently resides at 115 East Ridge, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is LORRAINE C. CARRAI, who currently resides at 600 Big Spring Road, Newville, Cumberland County, Pennsylvania. 3. Plaintiff seeks primary legal custody and primary physical custody off Name: Aeryiona Abagail Carrai, bom October 30, 1996 Present Residence: 115 East Ridge, Carlisle, Cumberland County, Pennsylvania The child was bom out of wedlock. 4. The child presently resides with Mary Long, Plaintiff herein, and her husband John Long at l 15 East Ridge, Carlisle, Cumberland County, Pennsylvania. For the past five years, the child has lived with the following persons and at the following addresses: 7/03 - present 115EastRidge Carlisle, Pennsylvania with Plaintiffand Plaintiffs husband, John Long 5/03 - 7/03 15EastKing Street Apartment #9 Shippensburg, Pennsylvania with Defendant 8/02 - 5/03 115 East Ridge Carlisle, Pennsylvania with Plaintiff and John Long 9/01 - 9/02 2041 Martins Way Martinsburg, West Virginia with Defendant 1/01 - 9/01 161 North College Street, #I Carlisle, Pennsylvania with Defendant, Jene Thomas and John Keller 1997 - 1/01 600 Big Spring Road Newville, Pennsylvania with Defendant and maternal grandfather, Edward B. Carrai The mother of the child is LORRA1NE C. CARRAI, defendant herein, who currently resides at 600 Big Spring Road, Newville, Cumberland County, Pennsylvania. She is not married. The father of the child is Diaunta S. Evans, who is believed to reside at 160 North Pitt Street, Carlisle Pe~msylvania. He has had no contact with the child, nor made any effort to contact the child since birth. 5. The relationship of Plaintiff to the child is that of maternal grandmother. Plaintiff currently resides with the child and husband John Long at 115 East Ridge, Carlisle, Cumberland County, Pennsylvania. 6. The relationship of Defendant Lorraine C. Carrai to the child is that of mother. Defendant currently resides with her father, Edward B. Carrai. 7. The best interests and permanent welfare of the child will be served by granting the relief requested. 8. Plaintiff has not participated as a party, witness or in another capacity or in other litigation concerning custody of the child in this or another court. 9. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child are aware of this action. 10. The parties have agreed that Plaintiff shall have primary legal and physical custody of the child, Aeryiona Abagail Carrai. 1 I. This Complaint is accompanied by the parties' Stipulation for Entry of Custody Order which they respectfully request that this Honorable Court approve, thereby implementing their agreement. 3 WHEREFORE, Plaintiff respectfully requests that the court grant her primary legal and physical custody of the child, Aeryiona Abagail Carrai. Respectfully submitted, ~MAN, P.C. I.D.~ 87506 320 Market Street, P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorneys for Plaintiff VERIFICATION I verify that the statements contained in the foregoing COMPLAINT FOR CUSTODY are true and correct to the best of our knowledge, information and belief. I understand that false statements contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to m~sworn falsification to authorities. Date: ~0'7_~ ..~0] ,2003 GOLDBERG, KATZMAN & SHIPMAN, P.C. Heather L. Patemo - I.D. #87506 Attorneys for Plaintiff 320 Market Street, P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 MARY T. LONG Plaintiff, LORRAINE C. CARRAI Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CiVIL ACTION - LAW No. CUSTODY/VISITATION ORDER OF COURT AND NOW, this [_O .~. day of D~.~ ¢ ..~ ~:~), 2003, upon review of the parties' Stipulation, it is hereby ordered that: 1. Plaintiff, MARY T. LONG, shall have primary physical custody of the child, Aeryiona Abagail Carrai. 3. time to time as the parties shall mutually agree. Plaintiff, MARY T. LONG, shall have primary legal custody of the child. Mother, LORRAINE C. CARRAI shall have temporary custody of the child from BY THE COURT: GOLDBERG, KATZMAN & SHIPMAN, P.C. Heather L. Paterno - I.D. #87506 Attorneys for Plaintiff 320 Market Street, P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 MARY T. LONG Plaintiff, LORRAINE C. CARRAI Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CUSTODY/VISITATION STIPULATION FOR ENTRY OF CUSTODY ORDER AND NOW, this~'~c.J. ~ day of November 2003, the parties agree and stipulate to the following custody order: 1. Plaintiff, MARY T. LONG, shall have primary physical custody of the child, AERYIONA ABAGAIL CARRAI. 3. time to time as the parties shall mutually agree. ~oldberg, Katzman & SITlpman, P.C. '~320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Plaintiff Plaintiff shall have primary legal custody of the child. Mother, LORRAINE C. CARRAI, shall have temporary custody of the child from MARY T. IdlDNG, Plaintiff STATE OF PENNSYLVANIA COUNTY OF DAUPHIN SS: On this, the,~. } 5~ day of November, 2003, before me, the undersigned officer, personally appeared MARY T. LONG, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the Stipulation for Entry of Custody Order for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. STATE OF PENNSYLVANIA COUNTY OF DAUPHIN SS: On this, the ,~J~' day of November, 2003, before me, the undersigned officer, personally appeared LORRAINE C. CARRAI, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the Stipulation for Entry of Custody Order for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ,~Y A. Ms.h, Nc~ PUI~Jo MY Cc~,s~'on ~ms Sel~ 17, L~08