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HomeMy WebLinkAbout01-0027 August 1999 to October 1999: With mother and father, Maternal Grandfather, Dave Riccio at 1145 Apple Drive, Apt 145, Mechanicsburg, PA. October 1999 to February 11, 2000: With mother and father at 42 East Locust Street, Mechanicsburg, PA. February 11, 2000 to March 6, 2000: With mother and father at 23 Village Court, Mechanicsburg, PA. March 6, 2000 to present: With mother at 202 East Portland Street, Mechanicsburg, PA. 4. The mother of the child is Amanda Riccio residing at 202 East Portland Street Mechanicsburg. She is not married. 5. The father of the child is Matthew T. Baum, residing at 121 East Simpson Street, Mechanicsburg, Cumberland County, PA, 17055. He is not married. 6. The relationship of Plaintiffto the child is that of father. The Plaintiff currently resides with the following person(s): Name Tina Baum Relationship Paternal Grandmother 7. The relationship of the defendant to the child is that of mother. The Defendant currently resides with child and the following person(s): Name Relationship None 8. 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 another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 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. 9. The best interest and permanent welfare of the child will be served by granting shared legal custody of the child to the both parties and partial physical custody to the Plaintiff. In this manner the child may be enriched by healthy relationships with each parent. 10. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, names below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Address Basis of Claim Name None WHEREFORE, Plaintiffrequests the court to grant custody of the child to Plaintiff. Respectfully submitted, James:,t. Kayer, ]ESklU'~' Atto ~rp~ ~y for Pl~nti~lY Kay~r~& Brow~ 4 E. ~Iberty Ayenue Carlisle, PA 17013 Superior Ct. I.D. 50838 Kayer,and Bi'own A Professional Cc~rporation Liberty Loft · 4 E. Liberty Avesue · Carlisle, PA 17013 (717) 243-7922 MATTHEW BAUM PLAINTIFF V. AMANDA RICCIO DEFENDANT 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-27 CIVIL ACTION LAW IN CUSTODY ORDER OFCOURT AND NOW, this 5th day of January ,2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Meehaniesburg, PA 17055 on the 6th day of February ,200l, at 1:00 p.m. 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: is/ Dawn S. Sunday. Custody Conciliato~ 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 MATTHEW BAUM, Plaintiff AMANDA RICCIO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO.~00~'- C~~/ CIVIL TERM : CIVIL ACTION - LAW : : IN CUSTODY AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO Pa. R.C.P. 1920.4(a)(1)(ii) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS, I, James J. Kayer, Esquire, being duly sworn according to law, deposes and says that he is the attorney for plaimiff, MATTHEW BAUM, and that he did serve a true and correct copy of the Petition for Custody that was filed in the above matter, by U.S. Mail, postage prepaid, certified with restricted delivery, return receipt requested, unto the Defendant, AMANDA RICCIO on January 3, 2001. The receipt form is attached hereto as Exhibit "A". Jar~t J. Sworn to and sgl~cribed bqfore me this Notary Public t . NOTARIAL SEAL Vickie J. Group, Notary Public rough of Carflsle, County of Cumberland y Commission Expires Aug. 30, 2004 MATTHEW BAUM, Plaintiff vs. AMANDA RICCIO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-27 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY consideratic~ of the attached Custody Conciliatzon Report, and directed as follows: , 2001, upon it is ordered 1. The Father, Matthew Baum, and the Mother, Amanda Riccio, shall have shared legal custody of Cainan Riccio-Baum, born September 9, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. The Father shall have a minimum of 4 periods of supervised visitation with the Child at Parent Works or other supervising agency selected by agreement of the parties. The parties shall cooperate in scheduling the first session of supervised visitation as soon as possible. 3. The Father shall continue in his course of counseling with Michael Kline until such t/me as his release by recommendation of the counselor. The Mother shall follow the reco~aendations of the counselor with respect to her participation in joint counseling with the Father. The Father shall sign any releases or authorizations necessary for the Mother or her counsel to obtain information from the Father's counselor with respect to the Father's attendance at and progress in the counseling sessions. 4. After the Father has completed the supervised periods of visitation provided in this Order, if the parties are not able to reach an agreement as to ongoing custody arrangements, counsel for either party may contact the Conciliator to schedule an additional Custody Conciliation Conference. cc: BY THE COURT,~//j. James J. Kayer, Esquire - Counsel for Father MATTHEW BAUM, Plaintiff vs. AMANDA RICCIO, Defendant : IN THE ODURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-27 CIVIL TERM : : CIVIL ACTION - LAW : IN CUSTODY //I ACCG~DANCE ~ ~ ~ ~ OF CIVIL P~O~-~-~{E 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: Cainan Riccio-Baum September 9, 1998 Mother 2. A Conciliation Conference was held on February 6, 2001, with the following individuals in attendance: The Father, Matthew Baum, with his counsel, James J. Kayer, Esquire, and the Mother, Amanda Riccio, with her counsel, Nick Smith, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Dawn S. Sunday, Esquired Custody Conciliator