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Home My WebLink About08-1965COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CHRISTINA M. CARRERO, ) Plaintiff ) V. ) MANUEL CARRERO, JR., ) Defendant ) No. 6 g- 196 5' e-tv f i 4zr% COMPLAINT FOR CUSTODY 1. Plaintiff is CHRISTINA M. CARRERO, who resides at 103 Miller Street P.O. Box 236, Summerdale, Cumberland County, PA 17093. 2. Defendant is MANUEL CARRERO, JR., who resides at 135 Blandon Avenue, Blandon, Berks County, PA 19510. 3. Plaintiff seeks primary physical custody and joint legal custody of the following children: Name Age Was child born out of wedlock? LILLIAN J. CARRERO 4 years No TRISTAN T. CARRERO 9 months No 4. The children are presently in the custody of Plaintiff who resides at 103 Miller Street P.O. Box 236, Summerdale, Cumberland County, PA 17093. 5. During the past five years, the children have resided with the following persons and at the following addresses: From To Address With whom JAN, 2007 (Still living 103 Miller Street P.O. Box 236 Plaintiff, mother; there) Summerdale, PA 17093 Kenneth Howard England- Grandfather Dolores Ann England- Grandmother Gabrielle Leilani England- Aunt FEB, 2006 JAN, 2007 2925 Kuztown Road Hyde Park Christina Marie Carrero- Apartment #4 mother Reading, PA 19605 Manuel Carrero Jr.- father APR, 2005 FEB, 2006 103 Miller Street Po Box 236 Christina Marie Carrero- Summerdale, PA 17093 mother Kenneth Howard England- grandfather Dolores Ann England- granmother Gabrielle Leilani England- aunt NOV, 2003 APR, 2005 401 Main Street Apartment R Christina Marie Carrero- Blandon, PA 19510 mother Manuel Carrero Jr.- father NO V, 2003 3315 Raymond Street Christina Marie Carrero- Apartment G mother Laureldale, PA 19605 Manuel Carrero Jr. 6. The mother of the children is currently residing at 103 Miller Street P.O. Box 236, Summerdale, PA 17093. She is separated. 7. The father of the children is currently residing at 135 Blandon Avenue, Blandon, PA 19510. He is separated. 8. The relationship of Plaintiff to the children is mother. Plaintiff currently resides with the following persons: Name Lillian J. Carrero Tristan T. Carrero Kenneth H. England Dolores A. England Gabrielle L. England Relationship to Plaintiff child child Father Mother Sister 9. The relationship of Defendant to the children is father. Defendant currently resides with the following persons: Name Relationship to Defendant Manuel A. Carrero Father Isabel Carrero Mother 10. Plaintiff has participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. The court term and number and its relationship to this action are: Name of court: Court Of Common Pleas Of Berks County Docket number: 05-4941-02 Date of last order or hearing: June 8, 2006 Type of case: Custody Name of court: Court Of Common Pleas Of Berks County Docket number: 05-4941-03 Date of last order or hearing: December 1, 2005 Type of case: Protection from Abuse Name of court: Court Of Common Pleas Of Berks County Docket number: 05-4941-01 Date of last order or hearing: June 8, 2006 Type of case: Divorce 11. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. 12. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 13. The best interest and permanent welfare of the children will be served by granting the relief requested because: a: Defendant is mentally and emotionally unstable. b: Defendant is unable to parent minor children. c: Plaintiff has always provided the majority of care and parenting of minor children. d: Plaintiff has had primary physical custody of the children for the preceeding thirteen months due to the fact that Defendant has chosen to be an absent parent. 14. 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. WHEREFORE, Plaintiff requests the Court to grant custody of the children to Plaintiff. a CHRISTINA M. C RO, Plain ff Verification I, CHRISTINA M. CARRERO, Plaintiff, verify that the facts stated in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. Petitioner understands that false statements therein are subject to the penalties of 18 Pa. C.S.A. '4904 relating to unworn falsification to authorities. .tJ ' Date: Z006 CHRISTINA M. C RO, Plaintiff ca fi r co x ..., R E.? ta ?- a CHRISTINA M. CARRERO IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. MANUEL CARRERO, JR. DEFENDANT 2008-1965 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, April 04, 2008 , 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, April 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/ Hubert X. GAro Es q. 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 4" 44V ?0, 7 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHRISTINA M. CARRERO, ) Plaintiff ) V. ) No. MANUEL CARRERO, JR., ) Defendant ) Certificate Of Service I, CHRISTINA M. CARRERO, Plaintiff in the above matter, hereby certify that on MhRc H 218, . 200$ , I mailed a true and correct copy of the Complaint for Custody, by certified mail, return receipt requested, restricted delivery, and another copy of the same document by first class mail, postage prepaid, to: MANUEL CARRERO, JR. 135 Blandon Avenue - PO BOX {(64 Blandon, PA 19510 I certify that (check ALL of the following which are true): Certified mail: [X] The green and white sender's receipt is attached. (ATTACH receipt.) [X] The green recipient's receipt is attached; MANUEL CARRERO, JR. signed the certified mail receipt on Ari 1 7. 2008 (ATTACH receipt.) [ ] The certified mail was returned to me unsigned, with the notation that the certified mail was: [ ] refused [ ] unclaimed { ] other notation: [ ] Neither the certified mail envelope nor the certified mail receipt was returned to me. Regular mail: [ X] The regular mail has not been returned to me. [ ] The regular mail was returned to me, with the notation: I verify that the information in the Certificate of Service is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904, relating to unsworn falsification to authorities. Date: U&J Q ZD0 (Signature) CHRISTINA M. CARRERO STAPLE OR TAPE THE CERTIFIED MAIL RECEIPTS BELOW: (Domestic Provided) Ln sps.com" I For delivery information visit our website at www.u .x M f` Postage $ MER M M Certified Fee C? J? Q Return Reoeipt Fee (Endorsement Required) a f `? Q Restricted Delivery Fee (Endorsement Required) ) & 9 v G ?n N Total Postage & Fees $ S 00 IDS C3 . I3`tieet,iljitNo.: j ?lY ...y. ...-.:_ na Q N or PO Box No. ??Dud +\. I (O ¦ Complete items 1, 2, and 3. Also complete Rem 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse A. Signature X Addresser so that we can return the card to you. ¦ Attach this card ece, nt if or on the.. 1. Article Addressed to: UKUMY B. Received by( pr/ Nerve) C. v v D. Is deliver) edd+ees dilferent from item 1? If YES, enter delivery address below: of Delivery No Chezeu Y v U.i? 1 3. Service Type q Cerdfied Mail O MeA i p . O Registered ? Retum Receipt for Merdwdn 0 Insured mail ? cam ) 1 1 J 4. Restricted DeAvefy7 Oft Fee) Q Yes ' 2. Article Number 7 0 0 6 (Transfer from Service kfto 2150 0003 7345 6573 PS Fotun 301, F.b vwy 2M Denreetl c Reerm nea.pt tee c o c -? o m („!l 1: try f s ^` • 2` C.? fi r' QAY 012008 i CHRISTINA M. CARRERO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW MANUEL CARRERO, JR., : NO. 2008-1965 Defendant : IN CUSTODY COURT ORDER AND NOW, this day of ay , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The mother, Christina M. Carrero, and the father, Manuel Carrero, Jr., shall have shared legal custody of Lillian J. Carrero, born September 15, 2003, and Tristan T. Carrero, born June 12, 2007. 2. The mother shall enjoy primary physical custody of the minor children. 3. The father shall enjoy periods of temporary physical custody of the minor children pursuant to a schedule as worked out between the parties. Father shall attempt to give mother adequate notice as to when he would like to exercise periods of temporary custody. 4. In the event the parties are unable to work out a satisfactory visitation schedule for the father, the father may petition the Court to have the case again scheduled with the Custody Conciliator for a conference at which time a specific schedule shall be put in place with respect to father's periods of temporary custody. BY THE COURT, lt\k A" ?_a Judge cc: Z As. Christina M. Carrero ? Mr. Manuel Carrero, Jr. s1 r.ld8 5 VIW\JJsN .. t$' 9 BH' :10 CHRISTINA M. CARRERO, Plaintiff v MANUEL CARRERO, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-1965 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 children who are the subject of this litigation is as follows: Lillian J. Carrero, born September 15, 2003 Tristan T. Carrero, born June 12, 2007. 2. A Conciliation Conference was held on April 24, 2008, with the following individuals in attendance: The mother, Christina M. Carrero, and the father, Manuel Carrero, Jr. Neither party appeared with counsel. 3. The parties agree to the entry of an Order in the form as attached. Date: April 2008 Hubert X. G' roy, Esquire Custody C nciliator f CHRISTINA M. ENGLAND, formerly CHRISTINA M. CARRERO, MANUEL Re; O, JR., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSXLVA Iff7) = r n zrn c.. c `n M- CIVIL ACTION - LAW cnrr- ! r i NO. 2008-1965 C° IN CUSTODY COURT ORDER vacated 2. % 'SNOW, this day of ;t:i 2011, upon consideration of the attached Custody Report, it is ordered and directed that this Court's prior Order of May 6, 2008, is l replaced with the following Order: The mother, Christina M. England, shall enjoy sole legal and primary physical custody of Lillian J. Carrero, born September 15, 2003, and Tristan T. Carrero, born June 12, 2007. Custody rights of the father, Manuel Carrero, Jr., are hereby suspended pending further Order of this Court. If Mr. Carrero desires to enforce any visitation rights, he is directed to file the appropriate petition after which this case will again be referred to the Custody Conciliator for a conference. BY THE COURT, 1?\? Judge cc: Drew V Mr. l\ Deyo, Esquire nuel Carrero, Jr Mai ?e? 0a 1 '0 CHRISTIN? M. ENGLAND, formerly C RISTINA M. CARRERO, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-1965 MANUEL (ARRERO, JR., IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN :DL 1 ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL RE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the children who are the subject of this litigation is as follows: Lillian J. Carrero, born September 15, 2003 Tristan T. Carrero, born June 12, 2007 2. 3 4. Date: J A Conciliation Conference was held on June 23, 2011, with the following individuals in attendance: The mother, Christina M. England, with her counsel, Drew F. Deyo, Esquire The Father did not appear. Mother related that Father was arrested in February of this year and charged with first degree murder and other numerous charges. The allegations are that he broke into a home and beat an elderly woman to death and seriously injured her elderly spouse. Mr. Carrero is currently incarcerated in the Berks County Prison. Based upon the above, the Conciliator recommends an Order in the form as attached. 2011 Hubert X. Gilroy, Esqu' e Custody Conciliator 4A M. ENGLAND, IN THE COURT OF COMMON PLEAS OF