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Home My WebLink About10-0372F!LcG -W`: Barbara Sumple-Sullivan, Esquire NOTARY Supreme Court #32317 ?Q (Q JH? i 4 ?. 2 549 Bridge Street New Cumberland, PA 17070 iA (717) 774-1445 JOHN G. CALAI TGES, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -CUSTODY MARILYN D. CALAITGES, Defendant NO. 10 37A C CUSTODY COMPLAINT 1. The Plaintiff is John G. Calaitges (hereinafter referred to as "Father"), who currently resides at 435 Bridge Street, New Cumberland, Cumberland County, Pennsylvania. 2. The Defendant is Marilyn D. Calaitges (hereinafter referred to as "Mother"), who currently resides at 1004 Baythorn Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff seeks an Order of shared legal custody and partial physical custody of the following children: NAME PRESENT RESIDENCE Kelsey A. Calaitges 1004 Baythorn Drive Mechanicsburg, PA John D. Calaitges 1004 Baythorn Drive Mechanicsburg, PA The children were not born out of wedlock. DATE OF BIRTH May 12, 1992 September 29, 1995 J17q.00 PD flYr4 etv gq_gq P_T*a3( 308 The children are presently in the custody of Mother who currently resides at 1004 Baythorn Drive, Mechanicsburg, Cumberland County, Pennsylvania. During the past five years, the children have resided with the following persons at the following addresses: NAMES OF PERSONS ADDRESSES DATES Mother, Father and children Mother and children 1004 Baythorn Drive Mechanicsburg, PA 1004 Baythorn Drive Mechanicsburg, PA 2005-December, 2006 January, 2007-present The Mother of the children is Marilyn D. Calaitges, currently residing at 1004 Baythorn Drive, Mechanicsburg, Cumberland County, Pennsylvania. She is separated from Father. The Father of the children is John G. Calaitges, currently residing at 1624 Green Street, Harrisburg, Dauphin County, Pennsylvania. He is separated from Mother. 4. The relationship of the Plaintiff to that of the children is that of Father. The Plaintiff currently resides with the following persons: NAME John G. Calaitges RELATIONSHIP Self 2 5. The relationship of the Defendant to the children is Mother. The Defendant currently resides with the following persons: NAME Marilyn D. Calaitges Kelsey A. Calaitges John D. Calaitges RELATIONSHIP Self Daughter Son 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 7. The Plaintiff has no information of a custody proceeding concerning the children pending in any court of this Commonwealth or any other state. 8. Plaintiff does not know of a person not a parry to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 9. The best interest and permanent welfare of the children will be served by granting the relief requested because Father desires an Order establishing regular periods of partial physical custody with the children. Father also requests to have immediate counseling commenced between he and his children in an effort to strengthen the relationships between the children and Father. 3 10. 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, the Plaintiff requests the Court to grant shared legal custody and periods of partial physical custody of the children to the Plaintiff. DATE: January 13, 2010 Bar Tara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Plaintiff 4 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JOHN G. CALAITGES, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -CUSTODY MARILYN D. CALAITGES, Defendant NO. VERIFICATION I, John G. Calaitges, hereby certify that the facts set forth in the foregoing CUSTODY COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. Dated: 3 ? o G. CAL T 4HN JOHN G. CALAITGES IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. MARILYN D. CALAITGES DEFENDANT 2010-372 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, January 19, 2010 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, February 11, 2010 at 8:30 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 he 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 ueline 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 TO ` i RsF' `,1 j , ,? lD X20 c?,?_y , , la FltfD-OFFICE OF THE € ROTHONOTARY Barbara Sumple-Sullivan, Esquire Supreme Court #32317 20 10 FEB -8 AM 9: 57 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 CU V53'' " , 4L) I, l.)UNTY rr_rV I 140T _vr'Sk,% JOHN G. CALAITGES, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -CUSTODY MARILYN D. CALAITGES, Defendant NO. 2010-372 ACCEPTANCE OF SERVICE I, Samuel L. Andes, Esquire, hereby accept service and acknowledge receipt of the above- captioned Custody Complaint on behalf of Defendant, Marilyn D. Calaitges, having received said Complaint on the ;Z day of'2010. S 1 L. Andes, squire P.O. Box 168 Lemoyne, PA 17043 Attorney for Defendant Supreme Court ID No. 17225 717-761-5361 FE8232010~ JOHN G. CALAITGES, Plaintiff v. MARILYN D. CALAITGES, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2010-372 CIVIL ACTION -LAW Defendant : IN CUSTODY r,,, n ~+ v _ _..F_I ~Y D ^.(' t ~ ~, ORDER OF COURT`,,' ~ ~.4 k.._ ~ . _ -;-; AND NOW, this ~? da of ~~~ S ~ > ~ ~ ~~'~~~ y ~ , 2010, ultoii~ .. .~~ consideration of the attached Custody Conciliation Report, i is ordered and dire~d a~' follows: 1. The Father, .lohn G. Calaitges and the Mother, Marilyn D. Calaitges, shall have shared legal custody of Kelsey A. Calaitges, born May 12, 1992 and John D. Calaitges, born September 29, 1995. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to medical, dental, religious or school records, the residence address of the children and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent ~•.vithin such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to fiill participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to- school nights, and the like. 2. Mother shall have primary physical custody of the children. Father shall have the following periods of partial physical custody of John: A. Beginning February 24, 2010, every Wednesday from 5:00 p.m. to 8:00 p.m. B. Two weekends per month as follows: 1. March 6 and 7, 2010, March 20 and 21, 2010, April 10 and 11, 2010, Saturday from 9:00 a.m. to 8:00 p.m. and Sunday from 9:00 a.m. to 7:00 p.m. 2. Apri124, 2010 overnight from Saturday at 9:00 a.m. to Sunday at 7:00 p.m. C. April 17, 2010 from 9:00 a.m. to 8:00 p.m. 4. Each party steal l have two non-consecutive weeks in the summer provided they give the other party 60-days prior notice. Said weeks shall coincide with the parties' regularly scheduled weekend. 5. 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 Custody Conciliation Conference is scheduled for April 27, 2010 at 9:30 a.m. BY THE COURT, - ; ~ l ~~ f ~J / J. cc: ~arbara Sumple-Sullivan, Esquire, Counsel for Father ./Samuel L. Andes, Esquire, Counsel for Mother ~.fJ~~4.5 rn,~tl£CL Z~~t, ~ tO ~~ JOHN G. CALAITGES, Plaintiff V. MARILYN D. CALAITGES, Defendant PRIOR JUDGE: None IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2010-372 CIVIL ACTION -LAW IN 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 Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY 1N CUSTODY OF Kelsey a. Calaitges May 12, 1992 Mother John D. Calaitges September 29, 1995 Mother 2. A Conciliation Conference was held in this matter on February 22, 2010, with the following in attendance: The Father, John G. Calaitges, with his counsel, Barbara Sumple-Sullivan, Esquire, and the Mother, Marilyn D. Calaitges, with her counsel, Samuel L. Andes. Esquire. 3. The parties agreed to an Order in the form as attached. Date: v2 ' ~a -1 Z? .~,~,...~ f ~l , acq line M. Verney, Esquire Custody Conciliator FEB 15 IUIU ~., ~ TAMAZINE T. BROOKS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. No. 10-406 CIVIL ACTION LAW SEAN M. BROOKS, IN CUSTODY Defendant ORDER OF COURT AND NOW this z .~' ~' day of February 2010, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. Legal Custodv: The Mother, Tamazine T. Brooks, shall have sole legal custody of Izabella V. Brooks, born 08/23/2006. The Mother shall have the right to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. 2. Physical Custodv: Mother shall have primary physical custody of the Child subject to Father's physical custody/visitation as the parties mutually agree. 3. The Father shall have telephone contact with the Child as agreed to by Mother. 4. Holidays: The parents shall arrange the holiday schedule as mutually agreed upon. 5. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. 6. During any periods of custody or visitation, the parties shall not possess or use illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 7. This Order shall not preclude Father from asserting his custodial rights when/if Father deems it appropriate by filing a Petition for Modification. 8. This Order is entered pursuant to 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. ~'~ r Z •:~I `'~ ~? ~~.~O;~l ^,, Di~'bution: ~~~St~Y Wolf, Esquire ~i'Se Brooks, 110 Renee Place, Staten Island, New York 10314 ohn J. Mangan, Esquire Co ~fdS ~'ldlls:~ aJ~.~f~v `~ TAMAZINE T. BROOKS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ~, No. 10-406 CIVIL ACTION LAW SEAN M. BROOKS, IN CUSTODY Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Izabella V. Brooks 08/23/2006 Primary Mother 2. A Conciliation Conference was held with regard to this matter on February 24, 2010 with the following individuals in attendance: The Mother, Tamazine Brooks, with her counsel, Stacy Wolf, Esq. The Father, Sean Brooks, did not appear. 3. The undersigned recommends the entry of an Order in the form as attached. Date Jo J. gan, Esquire C tod Conciliator Barbara Sumple-Sullivan, Esquire NOV 0,15 201 Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JOHN G. CALAITGES, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -CUSTODY r, rri -Z. `a- MARILYN D. CALAITGES, Defendant NO. 2010-372 - f' ct? ' ORDER ADOPTING STIPULATION OF PARTIES r; AND NOW, to wit, this 7fi day of ?Jo y , 2010, upon consideration of the attached Stipulation for Custody and on motion of Barbara Sumple-Sullivan, Esquire, counsel for Plaintiff, John G. Calaitges, and Samuel L. Andes, Esquire, counsel. for Defendant, Marilyn D. Calaitges, it is hereby ordered, adjudged and decreed that the terms, conditions and provisions of the attached Stipulation for Custody are adopted as an Order of Court. BY THE COURT,