HomeMy WebLinkAbout10-1024a
r
THOMAS P. SABOL, IN THE COURT OF COMMON PLEA F._.. (D
Plaintiff CUMBERLAND COUNTY, PENNSIQ N?t
rT r;;
v
NO. 2010- /OZ CIVIL TE
Co
c R7
_-q?
.
KIMBERLY BOUTELLE,
CIVIL ACTION-LAW -=' a
s C
=7
Defendant IN CUSTODY
a -c
CUSTODY COMPLAINT
1. Plaintiff is Thomas P. Sabol, an adult individual who currently resides at
1417 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania.
2. Defendant is Kimberly Boutelle, an adult individual who presently does not
have a fixed address but has contact with the children and can be served notice of this
action by undersigned counsel.
3. The parties are the parents of two minor children, namely, Rebecca
Sabol, born January 23, 1996 and Ryan Sabol, born February 14, 1997.
The children were born in wedlock.
The children are presently in the custody of Plaintiff at 1417 Walnut
Bottom Road, Carlisle, Cumberland County, Pennsylvania.
During the past five years, the children have resided with the following
persons at the following addresses:
Persons Residences Dates
Thomas P. Sabol 1417 Walnut Bottom Rd October, 2009
Carlisle, Pennsylvania to Present
Kimberly Boutelle 714 Stanwix Circle Apt. 4 November, 2008
Carlisle, Pennsylvania to October, 2009
Kimberly Boutelle 187 Faith Circle November, 2000
Carlisle, PA 17013 to October, 2008
rql ql -;'i &' 0" SPhia'
?etf ykGf
00 X1371-/3 -3
The natural father of the children is Thomas P. Sabol, currently residing at
14717 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania.
He is divorced from the Defendant.
The natural mother of the children is Kimberly Boutelle, who does not
currently have a fixed address.
She is divorced from the Plaintiff.
4. The relationship of the Plaintiff to the children is that of natural father.
The plaintiff currently resides with the following persons:
Names
Paula Lapp
Relationship
Girlfriend
Nicole Rosenthal
Amber Sabol
Rebecca Sabol
Girlfriend's Daughter
Daughter
Daughter
Ryan Sabol Son
5. The relationship of the Defendant to the children is that of natural mother.
The defendant currently resides with the following persons:
Names Relationship
Matthew Boutelle Husband
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.
Plaintiff has no information of a custody proceeding concerning the
children pending in a court of this Commonwealth or any other state.
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
J ,
respect to the children.
7. The best interest and permanent welfare of the children will be served by
granting the relief requested because both parties should have equal access to the
children.
8. 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. All other persons, named below, who are known to have or
claim a right to custody or visitation of the children will be given notice of the pendency
of this action and the right to intervene: none
WHEREFORE, Plaintiff requests your Honorable Court to grant him shared legal
and shared physical custody of the children.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
Date: &A4 A/,-
Michael A. Scherer, Esquire
I.D. # 61974
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in the foregoing Custody Complaint are true
and correct. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities.
Thomas P. Sabol
DATE: ?'
THOMAS P. SABOL IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBEKLAND COUNTY, PENNSYLVANIA
V.
KIMBERLY BOUTELLE
DEFENDANT
• 2010-1024 CIVIL ACTION LAW
IN CUSTODY
ORllF,R OF COURT
AND NOW, Friday, February 12, 2010 _, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. ,the conciliator,
at 4th Floor, Cumberland Cou~_Courthouse, Carlisle on Thursday, March 25, 2010 at 9:00 AM
for aPre-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 Prounds 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/ John j. Mangan, jr., Esg7
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
availahlc to disabled individuals having business before the court, please contact our oftice. 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 SHOUL..D TAKE THIS PAPER "f0 YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
}=ORTI-I E3ELOW TO FIND OUT WHERE YOU CAN GET LEGAL I-IELP.
Cumberland County I3ar Association
3? South I3edford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
r , , ~y
ZfllflFFg !~ ~~!!!:
!p
~~~-=t~
t.; ;,~- ~ „ ~,
ti7 r ~ ~rti~ ~a,F,~