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Home My WebLink About10-2791'? Any 2010 PR% 2 7 AH 8: 42 tr ?0 is'.?t 15?if' t rl7q, Qd ®d a:?y pr'jKf Constance P. Brunt, Esquire A V 1173 Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cpbrunt@CPBruntLaw.com Attorney for Plaintiff EMILY E. ENDRIZZI, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. JQ- ?Q? Cam'^l CHRISTIAN A. ENDRIZZI, Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, EMILY E. ENDRIZZI, by and through her attorney, CONSTANCE P. BRUNT, ESQUIRE, and respectfully represents as follows: 1. The Plaintiff is EMILY E. ENDRIZZI, residing at 1209 N. 2"d Street, Apt. 8, Harrisburg, Dauphin County, Pennsylvania 17102. 2. The Defendant is CHRISTIAN ENDRIZZI, residing at 120 N. 25th Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Plaintiff is seeking shared legal and partial physical custody of the following children: Name Residence qge Isabelle Endrizzi 120 N. 25th Street 4 Camp Hill, PA 17011 Benjamin Endrizzi 120 N. 25th Street 2 Camp Hill, PA 17011 The children were born of the marriage between Plaintiff and Defendant. The children are presently in the custody of CHRISTIAN A. ENDRIZZI, residing at 120 N. 25TH Street, Camp Hill, Cumberland County, Pennsylvania 17011. For the last 4 years, the children have resided with the following persons and at the following addresses: (a) From birth through August, 2009 140 Ridgewood Drive Millersburg, PA 17061 With Plaintiff and Defendant (b) From August, 2009 through the present 120 N. 25th Street Camp Hill, PA 17011 With Defendant and Jolie Marsicano (paternal grandmother) The mother of the children is Plaintiff, EMILY E. ENDRIZZI, residing at 1209 N. 2ND Street, Apt. 8, Harrisburg, Dauphin County, Pennsylvania 17102. Plaintiff is presently married to Defendant. The father of the children is Defendant, CHRISTIAN A. ENDRIZZI, residing at120 N. 25th Street, Camp Hill, Cumberland County, Pennsylvania 17011. Defendant is presently married to Plaintiff. -2- 4. The relationship of Plaintiff, EMILY E. ENDRIZZI, to the children is that of natural mother. 5. The relationship of Defendant, CHRISTIAN A. ENDRIZZI, to the children is that of natural father. 6. The Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the children in this or any other court. Plaintiff has no information of a custody proceeding concerning the custody of the said 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 respect to the children. 7. The relief requested by Plaintiff is in the best interests of the children, because the Defendant has unreasonably restricted the Plaintiffs access to the children and has otherwise attempted to estrange the children from their mother. 8. Each parent whose parental rights of 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, Plaintiff requests the entry of an Order of Court providing for the shared legal and partial physical custody of the said minor children for Plaintiff on a -3- schedule affording her reasonable access to and contact with the children. Respectfully submitted, DATED: 7/(() /%2 CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID # 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 FAX (717) 232-0255 cpbrunt@CPBruntLaw.com Attorney for Plaintiff -4- VERIFICATION I verify that the statements made in the foregoing Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATED: -'`- EMILY E. D I Plaintiff ~1l.ED-~..~°l~;E ZEI10 SAY I Z PM 2~ 5~ i~NPv~YI.V~;ti1lA Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cpbrunt~CPBru ntLaw. com Attorney for Plaintiff EMILY E. ENDRIZZI, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CHRISTIAN A. ENDRIZZI, CIVIL ACTION -LAW NO. 10-2791-CIVIL Defendant IN CUSTODY AFFIDAVIT OF SERVICE I, STEVEN BEAR, do hereby certify that I did serve on Defendant, CHRISTIAN A. ENDRIZZI, a true and correct copy of the Complaint For Custody filed on April 27, 2010, in the above-captioned matter by personally delivering to CHRISTIAN A. ENDRIZZI, at i 'clock ~.m. at his place of employment at Baker's Restaurant, 515 North U.S. 15, Dillsburg, Pennsylvania. TEVEN BEAR . ~ ~ t 'JUL 2 6 2010 ~. FIB ~~; _,~ - ,r ~I_tr ~ ~''s~L, 2Q{0 J~~~ 27 ~5`~ I~~ ~u F~- ~ , __~ .i~:~~, Constance P. Brunt, Esquire Supreme Court ID 829933 Beaufort Profesalonal Center 1820 Linglestown Road Harrisburg, PA 17110 (717)232-7200 FAX (717) 232-0255 cabrunt~CPBruntLaw.com Altomey for PlalntMf EMILY E. ENDRIZZI, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CIVIL ACTION -.LAW NO. 10-2791 CIVIL TERM CHRISTIAN A. ENDRIZZI, Defendant IN CUSTODY RULE TO SHOW CAUSE AND NOW, this ~ day of __~ , 2010, upon consideration of the Petition For Leave To Withdraw As Counsel filed by CONSTANCE P. BRUNT, ESQUIRE, in the above-captioned matter, A Rule is hereby issued on Plaintiff, EMILY E. ENDRIZZI, and Defendant, CHRISTIAN A. ENDRIZZI, to show cause, if any they have, why CONSTANCE P. BRUNT, ESQUIRE, should not be granted leave of Court to withdraw as counsel for said Plaintiff. Rule returnable ~~ days after service by mail. BY THE COURT: Distribution to: ~~ PLAINTIFF: DEFENDANT: Emily E. Endriai nthony L. DeLuca 1209 N. 2nd Street, Apt. 8 113 Front Street Harrisburg, PA 17102 Boiling Springs, PA 17007 (717) 379-5309 (717) 258-6844 FAX: (717) 258-3902 anthonvldeluca@earthlink.net Attorney for Defendant Constance P. Brunt, Esquire Supreme Court ID # 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 FAX: (717) 232-0255 cgbrunt@CPBruntLaw.com r ~tfs' m~~~ 7/~ ~~tU ~~ -2- RD- u-n- CE `G Tf ?nTAW ALA 25 PM 3: 4b CUt PNvS&ANIIAA Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cpbrunt@CPBruntLaw.com Attorney for Plaintiff EMILY E. ENDRIZZI, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. 10-2791 CIVIL TERM CHRISTIAN A. ENDRIZZI, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, CONSTANCE P. BRUNT, ESQUIRE, do hereby certify that on this 30th day of July, 2010, 1 served a true and correct copy of the Rule to Show Cause issued on July 27, 2010, in the above-captioned matter by depositing same in United States mail, first class postage prepaid, in the Post Office at Harrisburg, Pennsylvania, addressed as follows: Emily E. Endrizzi 1209 N. 2nd Street, Apt. 8 Harrisburg, PA 17102 Plaintiff Anthony L. DeLuca, Esquire 113 Front Street Boiling Springs, PA 17007 ,Attorney for Defendant CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID # 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 FAX (717) 232-0255 cpbrunt@CPBruntLaw.com -2- Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cpbrunt@CPBruntLaw.com Attorney for Plaintiff OF THE Pl- " ",a s,?Tr Y 10 AUG 3! AM 8' 55 CUMLL.. ,? ?JwjNN PENNSYLVANIA AUG " 6 2010 EMILY E. ENDRIZZI, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. 10-2791 CIVIL TERM CHRISTIAN A. ENDRIZZI, Defendant IN CUSTODY RULE ABSOLUTE `'A AND NOW, this 17% day of WM Q'„kJ 1- 2010, upon consideration of the attached Petition To Make Rule Absolute, IT IS HEREBY ORDERED AND DECREED that the Petition For Leave To Withdraw As Counsel is granted, and Constance P. Brunt, Esquire, is granted leave to withdraw her appearance in this matter as counsel of record for Plaintiff. co c es ert1 2 A'Zct 04 e. -f- 4"y 61 ?'?'ti.c ly eA-X ,,, 2Zt' BY THE COURT: J. Distribution to: PLAINTIFF: FOR DEFENDANT: Emily E. Endrizzi 1209 N. 2nd Street, Apt. 8 Anthony L. DeLuca, Esquire Harrisburg, PA 17102 113 Front Street (717) 379-5309 Boiling Springs, PA 1;7007 (717) 258-6844 FAX: (717) 258-3902 anthonyldeluca@earthlink.net Constance P. Brunt, Esquire Supreme Court ID # 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 FAX: (717) 232-0255 cpbrunt@CPBruntLaw.com -2- I FlLED-a?'?-?'r, u`t4TY r ajq,1, LVAN,P, Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cpbru ntCDCPBruntLaw.com Attorney for Plaintiff EMILY E. ENDRIZZI, Plaintiff V. CHRISTIAN A. ENDRIZZI, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO. 10-2791 CIVIL TERM : IN CUSTODY PRAECIPE To: David D. Buell, Prothonotary Pursuant to the Rule Absolute entered in the above matter on August 30, 2010, please withdraw my appearance as counsel of record for Plaintiff. Respectfully submitted: /ri- CONSTANCE P. BRUNT, ESQUIRE Supreme Court I.D. No. 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 FAX (717) 232-0255 cpbrunt -CPBruntLaw.com -1- CERTIFICATE OF SERVICE 1, CONSTANCE P. BRUNT, ESQUIRE, do hereby certify that on the r oG day of J?-???' , 2010, 1 served a true and correct copy of the foregoing Praecipe by depositing same in the United States Mail, first-class postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Emily E. Endrizzi 1209 N. 2nd Street, Apt. 8 Harrisburg, PA 17102 Plaintiff Anthony L. DeLuca 113 Front Street Boiling Springs, PA 17007 Attorney for Defendant CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID # 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 FAX (717) 232-0255 cpbruntCcD-CPBruntLaw. com -2-