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HomeMy WebLinkAbout10-2050 THC-Y}?ot,t(J'fAftY 2010 MAR 23 Phi 1: 4 ti KOPE & ASSOCIATES, LLC JULIE A. WEHNERT, ESQ. ATTORNEY I.D. 307900 395 St. Johns Church Road Camp Hill, PA 17011 (717) 761-7573 jwehnert@kopelaw.com 'L - Attorney for Plaintiff DEBRA L. DAVIES, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PA vs. NO. 10 - )-05'6 atv,d fern BRIAN T. FRONTING, CIVIL ACTION - LAW Defendant. IN CUSTODY CUSTODY COMPLAINT AND NOW comes the above-named Plaintiff, DEBRA L. DAVIES, by and through her attorney, JULIE A. WEHNERT, ESQ., and makes the following Complaint in Custody: 1. The Plaintiff is DEBRA L. DAVIES, an adult individual who currently resides at 201 Bosler Ave, Upper Apt., Lemoyne, Cumberland County, Pennsylvania 17043 (hereinafter "Plaintiff' or "Mother"). 2. The Defendant is BRIAN T. FRONTING, an adult individual who currently resides at 19 Brennan St., Bradford, McKean County, Pennsylvania 16701 (hereinafter "Defendant" or "Father"). 3. Plaintiff seeks shared legal and primary physical custody of the following unemancipated child: Giovanni Frontino, born October 30, 2007. The child currently resides with Mother at 201 Bosler Avenue, Upper Apt., Lemoyne, PA 17043. 41?q.00 PA A774 cr-* 5W.01 t P-T4- 4. Giovanni Frontino (hereinafter the "child") was born out of wedlock. 5. During the past three years, the child has resided with the following persons and at the following addresses: PERSONS Debra L. Davies Brian T. Frontino ADDRESSES 144 N. Center Street Bradford, PA 16701 DATES 10/30/07 -12/29/07 Debra L. Davies 144 N. Center Street Bradford, PA 16701 Debra L. Davies 86 '/ Cornen Street Ray Warner (roommate) Bradford, PA 16701 Debra L. Davies 86 Y2 Cornen Street Sara Miller (roommate) Bradford, PA 16701 Debra L. Davies Jason Skaggs 86 Y2 Cornen Street Bradford, PA 16701 Debra L. Davies Jason Skaggs Debra L. Davies 166 Congress Street Bradford, PA 16701 201 Bosler Ave Lemoyne, PA 17043 12/29/07 - 7/2/08 3/08 - 5/08 6/08 -1 /09 8/08 - 2/09 2/28/09 - 3/28/09 3/28/09 - present 6. The mother of the child is Debra L. Davies, residing at 201 Bosler Ave., Upper Apt., Lemoyne, Cumberland County, Pennsylvania 17043. She is unmarried. 7. The father of the child is Brian T. Frontino, residing at 19 Brennan St., Bradford, McKean County, Pennsylvania 16701. He is unmarried. 8. The relationship of Plaintiff to the children is that of Mother. Mother currently lives with the minor child. 2 9. The relationship of Defendant to the child is that of Father. Father currently resides with his girlfriend, Suzey Sherwood, her four children from a previous relationship and his twins with Suzey Sherwood. 10. Plaintiff has not participated as a party in previous litigation concerning the custody of the child. 11. Plaintiff does not know of a person not a party to the proceeding who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 12. Plaintiff is requesting shared legal and primary physical custody of the child. 13. The best interest and permanent welfare of the child will be served by the granting relief requested because: (a) Plaintiff has played the instrumental role in the raising of the child since his birth. As such, the child will benefit from continued physical custody with Plaintiff; (b) Plaintiff is able to provide a stable home and emotional environment for the child; and (c) Plaintiff has the facilities to provide for the care, comfort and control of the child, as well as the intention and desire to do so. 14. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as parties to this action. 3 WHEREFORE, Plaintiff requests that this Honorable Court grant the following relief: Award Plaintiff shared legal and primary physical custody of the child. Respectfully Submitted, Dated: L&O K PE & ASSOCIATES 9- a U9, Jul' A. Wehnert, Esq. 4 VERIFICATION I, Debra L. Davies, the Plaintiff in this matter, have read the foregoing Complaint. I verify that my averments in this Complaint are true and correct and based upon my personal knowledge. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifications to authorities. Dated: ??IU' I Q `L ' ? LPL Debra L. Davies 6 DEBRA L. DAMES IN THE COURT OF COMMON PLEAS OF I'L,AINTIFF CUMBERLAND COUN'T'Y, PENNSYL.~VANIA V. BRIAN T. FRONTING DI:F FNDANT • 2010-2050 CIVIL ACTION LAW IN CUS'~l'OL~Y ORDER OF COURT AND NOW, Wednesday, March 24, 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 County Courthouse, Carlisle on Thursday, May 06, 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. Faihn-e 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, fipecial Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ John J Mangan, _ jr., Esq. 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 NO'T 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 I3ar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 t)F 'Mc Pr F~7NOt~ST ZOiQ MAR 25 PM 1= u6 PE?`dP~1SY'LVAivIA 3 . a S - ~ 6 C~y~ P~.c~-d i ~ ~~~ Man o~,a-n5 t.e... DEBRA L. DAVIES, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. • BRIAN T . FRONTINO, CIVIL ACTION - LAW Defendant NO. 10-2050 CIVIL TERM IN RE: CUSTODY ORDER OF COURT AND NOW, this 10th day of June, 2013, this being the time and place set for hearing on a custody complaint, and the parties having now come to an agreement that they will enter into a custody stipulation that outlines the terms of their agreement, and that counsel for mother shall submit the stipulation to this Court within three weeks of today' s date, this matter is hereby taken under advisement and deferred until this Court receives the custody stipulation by both parties hereto. By the Court, eg-:16A- P-61eC Christylee L. Peck, J. " Julie A. Wehnert, Esquire For the Plaintiff c- r n �. Brian T . Frontino r•n _"n. _� 9 Brennan Street cn�" Bradford, PA 16701 : lfh /12.41iXeL , /0//3/t3