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Home My WebLink About00-05038 ROY WILLIAM BOLTON IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF V. BRENDA KAY COSTELLANO 00-5038 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 20th day of July , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear beforeMelissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 3rd day of August , 2000, at 1:00 PM 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. 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. FOR THE COURT, By: /s/ Melissa P. Greevy, E 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 lh;? ? ?Vhi :I r c? ?: x?r:.emm?nw,?r?mwr;??raem??:m?:win f.r, x.wimms?a ._ ROY WILLIAM BOLTON, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Vs. BRENDA KAY CASTELLANO, Defendant NO. 2000-roaP Civil Term CIVIL ACTION-LAW ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the Conciliator, on , the day of , 2000 at m. in the office of said conciliator located at 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 the entry of a temporary or permanent order. FOR THE COURT: Date: BY: Custody Conciliator 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. Court Administrator Cumberland County Court House One Court House Square Carlisle, Pa. 17013 (717) 240-6200 ROY WILLIAM BOLTON, Plaintiff VS. BRENDA KAY CASTELLANO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000 - 66b 3 F ?t Civil CIVIL ACTION - LAW COMPLAINT TO CONFIRM CUSTODY AND NOW, this 18t' day of July, 2000, comes the Plaintiff, Roy William Bolton, by his attorney, Arthur K. Dils, Esquire, and respectfully requests the following: 1. The Plaintiff is Roy William Bolton, an adult individual, who currently resides at c/o Rena and William Burk, 2704 Lisburn Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant, Brenda Kay Castellano, is an adult individual, who currently resides at 8132 Seventh Avenue No., Birmingham, Alabama 35206. 3. The Plaintiff and Defendant were married in June of 1983, and as a result of said marriage; one child was born namely: Chasity Lynn Bolton, born May 11, 1984 in Raleigh, N.C. 4. The Plaintiff and Defendant were divorced on May 9, 1986. 5. Since 1986, the minor child has been in the custody of the Defendant, and has resided in Columbus Georgia since 1989. 6. Two weeks ago, the Defendant sent to the minor child to reside with the Plaintiff, and the minor child has resided with the Plaintiff at the address listed above since that time. 7. The Plaintiff is employed by the United States Army and as a result of said employment, he works in Wiesbaden, Germany, for approximately eleven months out of the year. -2- 8. The Plaintiff is scheduled to return to Germany on August 6, 2000, at which time, his daughter, Chasity Lynn Bolton, will be returning to Germany with him and will be attending tenth grade at HH Arnold High School in Wiesbaden, Germany. 9. The Defendant is agreeable with the Plaintiff having primary physical custody of his daughter, and a consent indicating the same has been forwarded to the Defendant this date. 10. At the time of the divorce between the parties, it is believed that custody was placed in the Defendant, Brenda Kay Castellano. 11. The Court of Common Pleas of Cumberland County has jurisdiction in this matter as the minor child currently resides in Cumberland County, Pennsylvania. WHEREFORE, the Plaintiff, Roy William Bolton, by his attorney,' Arthur K. Dils, Esquire, respectfully requests that an Order be entered granting him primary -3- physical custody, and indicating shared legal custody and liberal visitation to be agreed upon between the parties. BY: Arthur K. Dils, Esquire 1017 North Front Street Harrisburg, PA. 17102 (717) 232-9724 I.D. No. 07056 -4- Respectfully submitted, VERIFICATION The undersigned, Arthur K. Dils, Esquire, hereby verifies and states that: He is the attorney for Roy William Bolton. 2. He is authorized to make this verification on their behalf. This verification is made by counsel pursuant to Pa. R.C.P., Rule 1024(c). 4. The statements set forth in the foregoing Complaint to Confirm Custody are true and correct to the best of his knowledge, information and belief. 5. He is aware that false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904, rela ' g to uns orn falsi cation to authorities. Arthur K. Dils, Esquire Date: July 18, 2000 ROY WILLIAM BOLTON, Plaintiff VS. BRENDA KAY COSTELLANO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 00-5038 CIVIL ACTION - LAW AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN Personally appeared before me, a Notary Public, in and for said Commonwealth and County, Arthur K. Dils, Esquire, who being duly sworn deposes and says that a true and correct copy of the Complaint for Custody has been served upon the Defendant, Brenda Kay Costellano, 8132 Seventh Avenue. No., Birmingham, AL 35206, by First Class, United States Mail, Certified No. Z 569 114 954. Attached hereto is the return receipt card executed by Brenda Kay Costellano dated August 7, 2000 evidencing receipt o sa e. Arthur K. Dils, Esquire Sworn and subs ed to before mhis day of N M4m t& ate, v y Pubs HWH&M ?upWn CavMy, PA [m:r m 9i ,t Eap?as?s Pte. 28, 2 / a % SENDER: V :Complete items 1 and/or 2 for additional services. I also wish to receive the w :Complete items 3, 4a, and 4b. following services (for an E 0 • Print your name and address on the reverse of this form so that we can return this extra fee): card to you. j -Attach this tone to the front of the mailpiece, or an the back if space does not permit. y -Write-Return Receipt Requested-on the malplece below the article number. M :The Return Receipt will show to whom the article was delivered and the date delivered. 3. Article Addressed to: 4a o, 7G . jV 413 W at I _?? ? Z W 5. Received : (Print Name) 8. J g 0 er 6. n : (Address orAg ? PS orm 3811. December 1994 1. ? Addressee's Addre 2. ? Restricted Delivery Consult postmaster for fee. mbar Ipe ER-Certified al ? Insured :iptfor Merdhandise ? COD iv0 71 _f0 Ix rn N w m h No a ? N O r w Q 3 ?> r r o Zy Q O OZ W W W z xa ¢ r - ° oz a zm o? •- K 2 N O r W P W Z Q 0 K 2 LL Z 2 W 6 O ox Z00 00 oa Q 2 ?' 0 N O W S WQ 3 ?> r r1 Q Z O, h z W W W z mm ? r - a °zm N o ? 2 • to 00 0zN a Ln ? N M a) m J-1 m U td N a) G' N N M ?1 r-I ri Lq oo pq p, It AUG 11 2 ROY WILLIAM BOLTON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2000-05038 BRENDA KAY CASTELLANO. : CIVIL ACTION - LAW Defendant : CUSTODY ORDER OF COURT AND NOW, this t g day of 2000, upon consideration of the attached Custody Conciliation Report and the agr ment of the parties dated July 25, 2000, it is ordered and directed as follows: 1. The Mother, Brenda Kay Castellano, and the Father, Roy William Bolton, shall share legal custody of the minor child. Mother and Father are required to contact the other parent to discuss all major decisions concerning their daughter including, but not limited to, religion, education and medical decisions. 2. Father shall have primary physical custody of the minor child, Chastity Lynn Bolton, born May 11, 1984. 3. Mother shall have liberal 'visitation With the minor child as mutually agreed upon by the parties. 4. Cumberland County Court of Common Pleas shall retain jurisdiction in this matter. BY THE COURT, Dist: Arthur K. Dils, Esquire, 1017 N. Front Street, HarrisbVg, PA 17102 Brenda Kay Castellano, 3132 7th Street North, Birmingham, AL 35206 rt ?-I ? r -?!U`CARY 00 R[jr I5 ru111I i3 CUV,Bi?RUV` D COUNTY PENNSYLMAPI?A *?, t r ROY WILLIAM BOLTON, Plaintiff vs. BRENDA KAY CASTELLANO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-05038 : CIVIL ACTION - LAW : CUSTODY 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 Chastity Lynn Bolton May 11, 1984 Father 2. A Conciliation Conference was held on August 3, 2000, with the following individuals in attendance: The father, Roy William Bolton, and his counsel, Arthur K. Dils, Esquire; the Mother did not attend. 3. Roy William Bolton, appeared with his counsel Arthur K. Dils, Esquire and presented a signed and notarized agreement of the parties with regard to custody of the minor child. It is deemed that the parties agreed to the Order in the form as attached. aWV-0 4iellel 2Gr-eevy Custody Conciliator