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Home My WebLink About07-7735NORMAN FROMM, Plaintiff V. DANIELLE TEDESCO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 67- 1-135 0ivi (T?M CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Norman Fromm, who currently resides at 1823 Elm Street, New Cumberland, Cumberland County, Pennsylvania 17070. 2. The Defendant is Danielle Tedesco, who currently resides at 274 Walton Street, Lemoyne, Cumberland County, Pennsylvania 17043. 3. The Plaintiff seeks custody of the following child: Name: Hannah Marie Tedesco Date of Birth: October 9, 1997 Address: 274 Walton Street, Lemoyne, Cumberland County, Pennsylvania 17043 4. The child was born out of wedlock. 5. The child is presently in the custody of Mother, Danielle Tedesco, who resides at 274 Walton Street, Lemoyne, Cumberland County, Pennsylvania 17043. 6. During the child's lifetime, she has resided with the following persons and at the following addresses: Name Address Date Danielle Tedesco 274 Walton Street Birth to present Lemoyne, PA 17043 7. The mother of the child is Danielle Tedesco, who resides at 274 Walton Street, Lemoyne, Cumberland County, Pennsylvania 17043. 8. Mother of the child, Danielle Tedesco, is not married. 9. The father of the child is Norman Fromm, who currently resides at, 1823 Elm Street, New Cumberland, Cumberland County, Pennsylvania. 10. Father of the child, Norman Fromm, is not married. 11. The relationship of Plaintiff to the child is that of Father. 12. The relationship of Defendant to the child is that of Mother. 13. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or any other court. 14. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 15. The Plaintiff does not know of a person or 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 for reasons including the following: a. The Defendant has been the primary caregiver of the minor child since her birth. Defendant has: i. Planned and prepared meals; ii. Bathed, groomed and dressed the child; iii. Purchased, cleaned and cared for the child's clothing; iv. Arranged medical care, including trips to physicians; V. Arranged alternative daycare; vi. Put the child to bed nightly, attended the child in the middle of the night, and awakened the child in the morning. b. The child should have an opportunity to develop a bond with her Father. C. Plaintiff is able to provide a stable environment for the child. d. Plaintiff desires to ease into a relationship with the child, getting to know her once again over a period of time. e. The child has two half sisters, Brinlee and Taylor, whom she does not know very well, if at all. It would be in the best interest of the child to establish and develop a relationship with her half sisters. f. In the near future all three girls will be attending the same school. g. Father desires for all three girls to get to know one another before they begin attending the same school. h. It is unknown what, if any, information Mother is giving to the child about her Father. i. Father desires to reintroduce and reestablish a relationship with the child himself. 17. Each parent whose parental rights to the child have not been terminated has been named as parties to this action. WHEREFORE, the Plaintiff requests that this Court order gradual periods of visitation and partial custody to Father. Respectfully submitted, AaOM & KUTULA"S, L.L.P. DATE 2- 1 D Kara W. Haggerty, E; Supreme Court ID N 36 South Hanover Sti Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff VERIFICATION I, NORMAN FROMM, verify that the statements made in this Custody Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date FROMM CERTIFICATE OF SERVICE AND NOW, this Z1 day of December 2007, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Custody Complaint, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Charles E. Petrie, Esquire 3528 Brisban Street Harrisburg, PA 17111 Respectfully submitted, ABOM&KUTULA"S, L.L.P. vff(a 0 11-? Kara W. Haggerty, Esqui Supreme Court ID No. j`8 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff 1 1 na C7 J 1`r C:l - r, NORMAN FROMM IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2007-7735 CIVIL ACTION LAW DANIELLE TEDESCO IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, December 27, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, January. 24, 2008 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 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/ ac ueKne M. Verne 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 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ;?"???,• ,??? ' °? d"°?„y, ? ,?F'?;, C'? ,?'`<'.- - tom. e' O C :11 WV ! C 330 LDOZ l.Wl.UNUHW =4d 3HI J0 A JAN 2 8 2008 NORMAN H. FROMM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VL : CIVIL ACTION - LAW DANIELLE M. TEDESCO, : NO. 2004-4745 CIVIL TERM Defendant IN CUSTODY NORMAN FROMM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VI. /0. 2007-7735 CIVIL ACTION - LAW DANIELLE TEDESCO, . Defendant : IN CUSTODY ORDER OF COURT AND NOW, this `: day of ? 2008, upon confideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The above dockets are hereby consolidated. 2. The prior Order of Court dated January 3, 1997 is hereby vacated. 3. Mother, Danielle Tedesco, shall have sole legal custody of Hannah Marie Tedesco, born October 9, 1997. 4. Mother shall have primary physical custody of the child. 5. The parties shall cooperate with family counseling between Father and child with Deb Salem. Mother shall contact Deb Salem within 10 days of the date of this Order to schedule family counseling. Father shall be responsible for cost of counseling not covered by insurance. 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for Thursday, April 24, 2 t 8:30-am A 1 ?q,0 0 Edgar B. Bayley, V v too cc: Kara W. Haggerty, Esquire, Counsel for Father Charles Petrie, Esquire, Counsel for Mother NORMAN H. FROMM, Plaintiff V. DANIELLE M. TEDESCO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2004-4745 CIVIL TERM : IN CUSTODY NORMAN FROMM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-7735 CIVIL ACTION - LAW DANIELLE TEDESCO, Defendant : IN CUSTODY PRIOR JUDGE: EDGAR B. BAYLEY, P.J. CUSTODY CONCILIATION SUMMARY REPORT 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 Hannah Marie Tedesco October 9, 1996 Mother 2. A Conciliation Conference was held January 24, 2008 with the following individuals in attendance: The Father, Norman H. Fromm, with his counsel, Kara W. Haggerty, Esquire, and the Mother, Danielle M. Tedesco, with her counsel, Charles E. Petrie, Esquire. 3. The Honorable President Judge, Edgar B. Bayley previously entered an Order of Court dated January 3, 2005 at Docket number 2004-4745 providing for shared legal custody, Mother having primary physical and Father having periods of partial physical custody. 4. The parties agreed to an Order in the form as attached. Date ac eline M. Verney, Esquire Custody Conciliator NORMAN H. FROMM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW DANIELLE M. TEDESCO, : NO. 2004-4745 CIVIL TERM Defendant : IN CUSTODY NORMAN FROMM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-7735 CIVIL ACTION - LAW 0' DANIELLE TEDESCO, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 14`h of September, 2009, neither party having requested another conciliation conference and ninety days having passed since the last conference, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, I? Jac line M. Verney, Esquire, C ody Conciliator e? Mt fr0mm6mrg duel - cP /s i4m 9 : a y &4nd'idnd ?Gu