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Home My WebLink About10-1987Lori K. Serratelli, Esquire Pa. Supreme Court ID No. 27426 Serratelli, Schiffman, Brown and Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, Pennsylvania 17110 Telephone (717) 540-9170 Fax (717) 540-5481 Attorney For Plaintiff ! e pp, )F T? o? h" 2010 MAR 19 PM 3: 37 cum V ;4,r,?1Y ERICA SACKLER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLANDG COUNTY, PENNSYLVANIA VS. NO. (D CIV1?'rLot 1 CIVIL ACTION - LAW THOMAS M. CARLO, Defendant CUSTODY CUSTODY COMPLAINT TO THE HONORABLE, THE JUDGES OF SAID COURT: 1. The Plaintiff is Erica Sackler, who currently resides at 410 Linwood Street, New Cumberland, Cumberland County, Pennsylvania 17070. 2. The Defendant is Thomas M. Carlo, who currently resides at 315 West loth Street, New Cumberland, Cumberland County, Pennsylvania 17070. 41'74.0 o PA A Trf ev.`# 401q,79 a39a 10 3. Plaintiff seeks primary physical and legal custody of the parties' one (1) minor child, Sarah Carlo, born April 30, 2004. 4. The child was born out of wedlock. 5. The child is currently in the custody of the Plaintiff who resides at 410 Linwood Street, New Cumberland, Cumberland County, Pennsylvania. 6. During the past five years the child has resided with the following persons and at the following addresses: Persons Address Dates Erica Sackler 410 Linwood Street April 2009 to Sarah Carlo New Cumberland, PA Present Samuel Sackler Erica Sackler Sarah Carlo Samuel Sackler 439 Market Street New Cumberland, PA May 2008 to April 2009 Erica Sackler Thomas M. Carlo Sarah Carlo Samuel Sackler Matthew Carlo Jeremy Carlo 315 West loth Street New Cumberland, PA Birth to to May 2008 7. The father of the child is Thomas M. Carlo, who currently resides at 315 West 101h Street, New Cumberland, Cumberland County, Pennsylvania. 8. The relationship of Plaintiff, Erica Sackler, to the child is that of mother. The Plaintiff currently resides with, the subject minor child, and Samuel Sackler (Plaintiff's son). 9. The relationship of Defendant to the child is that of father. The Defendant currently resides alone. 10. Plaintiff has not participated as a party, witness, or otherwise in litigation concerning the custody of the said child. 11. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 12. 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. 13. The best :interest and permanent welfare of the child will be served by granting primary physical and legal custody of the child to Plaintiff. 14. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff respectfully prays that Your Honorable Court award primary physical and legal custody of the child to the Plaintiff. Respectfully submitted, L K. Serratelli, Esquire eV RATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717)540-9170 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penal ti 18 Pa. C.S. Section 4904, relating to unsworn falsific ion to authorities. 3/////o Date: Erica Sackler i ERICA SACKLER IN "THE COURT OF COMMON PLEAS OF PLAINTIFF C'UMBERLANU COUNTY, PENNSYL.,VANIA ~' 2010-1987 CIVIL ACTION LAW THOMAS M. CARLO IN CUSTODY DF~,FENDANT ORDER OF COtJRT AND NOVI~', Wednesday, March 24, 2010 upon consideration of the attached Complaint, __ _-.__, it is hereby directed that par~lies and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator-, at 4th Floor, Cumberland County Courthouse, Carlisle on _ Tuesday, April 27, 2010 at 8 30 AM for aPre-Hearing Custody Conference. At slrch conference, an effort will be made to resolve the issues in dispute; or if this cannot he accomplished, to detinc and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear' at the conterence nay provide grounds for entry of a temporary or permanent order. "I'he 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 I~he Court of Common Pleas of Cumberland County is required by law to comply with the Americans w°ith Disabilites Act of 1990. For inforn~ation about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our oftice. All arrangements must be made at least 72 ~1oln'S prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD "TAKE THIS PAPER ~~FO YOUR ATTORNEY AT ONCE. 1F YOU DO NO'T HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO "I'O OR'I~EL.EPHONE THE OFFICE SET FOR~I~I-i BELOW 1"O FIND OUT WI-iERE YOEJ CAN GET LEGAL HELP. Cumberland County Bar Association 3? South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3 I66 +3'~ ~ '~IV+ ~.' I fVW.. tJf Tt-':e~ ~'~t7T6t~''fARY 20~i 0 lIAR 25 P~! i ~ v2 cur~~~-~~~~~~~:~ J~,;;u;~~ P~NP~~SY~.VA~4~ 3.02 S • 1 ~ /U ofi c-~ t~ ~~~ ~ OQ~•-• 3 • ~s • r o ~~ ~a~ed '«n Vec•~~ ~ t~. .