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HomeMy WebLinkAbout04-3494 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS COURT DMSION THEODORA TSAROumS, Plaintift' vs. No. Oq-3yq~ GERASIMOS DIONYSATOS, Defendant You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the conrt your defenses or objections to tbe claims set forth agaiD8t you. You are warned that if you fail to do so the case may proeeed witbout you and a judgment may he entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights Important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELlGmLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION Legal Referral Service 32 South Bedford Street Carlisle, PA 17013 (717) 249 3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS COURT DMSION THEODORA TSAROUHIS, Plaintiff VS. No. 0 l../ - < Y ilc:r if GERASIMOS DlONYSATOS, Defendant COMPLAINT FOR CUSTODY 1. The plaintiff is Theodora Tsarouhis, an adult individual that resides at 3537 Logan Street, Camp Hill, 17011, Cumberland County. 2. The defendant is Gerasimos Dionysatos, an adult individual that resides at Kalidonos 12, City of Agrinion, 30100, County of Aitoloakarnania, Country of Greece. 3. Plaintiff seeks (custody)(partial custodyXvisitation) of the following child: Name Marcos Dionysatos Present Residence 3537 Logan Street, Camp Hill, Pennsylvania, 17011 Arz.e 2 The child was not born out of wedlock. The child is presently in the custody of Theodora Tsarouhis, who resides at 3537 Logan Street, Camp Hill, Pennsylvania, 170 II. During the past two years, the child has resided with the following persons and at the following addresses: List All Persons Theodora Tsarouhis List All Addresses 3537 Logan Street, Camp Hill, Pennsylvania, 17011 Dates October 28, 2002 2 The mother of the child is Theodora Tsarouhis, currently residing at 3537 Logan Street, Camp Hill, Pennsylvania, 17011. She is married. The father of the child is Gerasimos Dionysatos, currently believed to be residing at Kalidonos 12, City of Agrinion, 30100, County of Aitoloakarnania, Country of Greece. He is married. 4. The relationship of plaintiff to the child is that of mother. The plaintiff currently resides with the following persons: Name Spiridoula Tsarouhis Relationship Mother 5. The relationship of defendant to the child is that of father. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. The court, term and number, and its relationship to this action is: Plaintiff has no information of a custody proceeding concerning the child 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 child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: a Defendant abandoned the child on February 25, 2004. b. Defendant is currently believed to be unemployed and with no visible means of supporting the child. 3 c. Defendant has no education and no job skills with which to build a foundation to support and care for the child d. Plaintiff is currently with the Cumberland County Domestic Relations Office. e. Plaintiff is currently, and at all relevant times, been the primary provider for the child for every need including but not limited to food, clothing and emotional support. 8. Each parent whose parental rights to the child have not been tenninated and the person who has physical custody of the child 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 child will be given notice of the pendency of this action and the right to intervene: There are no other individuals who are known to have or claim a right to custody of the child. WHEREFORE, plaintiff requests the court to grant sole custody of the child. ~:iH.1~~tuITe - Attorney ID #88513 Attorney for Plaintiff Law Offices of Steckel and Stopp 1036 Main Street POBox 159 Slatington, PA 18080 (610) 767.3861 4 VERIFICATION The wulersigned verifies that the statements made herein are true and correct to the best of his knowledge, information and belief and that he is aware that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. ~~b 6 \~~, ~~:_- t;J -, r:: u_ \_:.:~ ( . \.0 .;:-) o '" , ,~ __I : ~J --, ;::-") ('::,) C--..l ')-. V) ~ ~ LL0) <.J.-.<) ~ 0 4L- :.c ~ ')- ~ QP ~. ~ ---cl ~ -5 ~ Cl- ct. THEODORA TSAROUHIS PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 04-3494 CIVIL ACTION LAW GERASIMOS DIONYSATOS DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, July 22, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hawn S. Sunday, Esq. , the conciliator. at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, August OS, 2004 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 be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. 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 auy and all existingProtcctiou from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 honrs prior to scheduled hearing. FOR THE COURT. By: Isl Dawn S. Sund4Y. Esq. Custody Conciliator mhc 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 illLEPHONE 'mE 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 4~-P $- ~ 4; Arl- -ee.(.. .~ ~ ~ ~/L, At?- e-e-L ~~$ ~~.~ /JO-c::C'-L I. r; : I !!d ZZ '1\1[' "IUQZ 1\' > AUG 1 9 2C04 '!j' '0 THEODORA TSAROUHIS Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLA.ND COUNTY, PENNSYLVANIA vs. 04-3494 CIVIL ACTION LAW GERASIMOS DIONYSATOS Defendant IN CUSTODY ORDER OF COURT AND NOW, this -Z'? day of ~~f , 2004, upon consideration of the attache~onciliation Report, it is ordered and directed as follows: 1. The Mother, Theodora Tsarouhis, shall have primary physical and legal custody of Marcos Dionysatos, born March 30, 2002. 2. The Father, Gerasimos Dionysatos, may have periods of partial custody or visitation with the Child only as arranged by agreement between the parties. 3. The Father may file a request with the Court to scheduk an additional custody conciliation conference to review the custody arrangements. J. L,..--" cciA5emetrios H. Tsarouhis, Esquire - Counsel for Mother Aerasimos Dionysatos, Father ~ ~ O~-:;'4.oi . 20G11 t.US 23 PH ll: , I !",l!!, "'-'I..;I"I':.L;' ir,-,/ ;il THEODORA TSAROUHIS Plaintiff IN THE C01JRT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 04-3494 CIVIL ACTION LAW GERASIMOS DlONYSATOS Defendant 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 Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Marcos Dionysatos March 30, 2002 Mother 2. A conciliation conference was held on August 5, 2004, with the following individuals in attendance: The Mother, Theodora Tsarouhis. The Mother's counsel, Demetrios H. Tsarouhis, Esquire, did not attend the conference. The Father, Gerasimos Dionysatos, who currently resides in Greece did not attend the conference or contact the conciliator, although the Mother represented that the Father was served with notice of the complaint and conference by certified mail with return receipt. 3. At the conference, the Mother stated that the Father left the Mother and Child in the marital residence on February 25, 2004 and departed for Greece without any notice or explanation. According to the Mother, the Father has not requested any contact with the Child, by telephone or otherwise. The Mother indicated that she only learned that the Father had retumed to Greece through his relatives. Since the Father left the country in February 2004, the Mother staled she has been the Child's primary care giver and requested confirmation of primary custody by Courll Order. 4. Based upon representations made by the Mother at the conference and the fact that the Father did not attend or contact the conciliator, the conciliator recommends an Order in the form as attached. -1Jv~r / CI ( ;).ccJif Date Oa. Lc1eu- Dawn S. Sunday, Esquire Custody Conciliator Demetrios H. Tsarouhis, Esquire Law Office of Steckel and Stopp 1036 Main Street P.O. Box 159 Slatington, PA 18080 Gerasimos Dionysatos C/O Nicoletta Serifi Sokrataki 5 AGRINID 30100 Greece t vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW THEODORA TSAROUHIS Plaintiff 04-3494 GERASIMOS DIONYSATOS Defendant 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 Child who is the subject of this litigation is as foIlows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Marcos Dionysatos March 30, 2002 Mother 2. A conciliation conference was held on August 5, 2004, with the following individuals in attendance: The Mother, Theodora Tsarouhis. The Mother's counsel, Demetrios H. Tsarouhis, Esquire, did not attend the conference. The Father, Gerasimos Dionysatos, who currently resides in Greece did not attend the conference or contact the conciliator, although the Mother represented that the Father was served with notice of the complaint and conference by certified mail with return receipt. 3. At the conference, the Mother stated that the Father left the Mother and Child in the marital residence on February 25, 2004 and departed for Greece without any notice or explanation. According to the Mother, the Father has not requested any contact with the Child, by telephone or otherwise. The Mother indicated that she only learned that the Father had returned to Greece through his relatives. Since the Father left the country in February 2004, the Mother stated she has been the Child's primary care giver and requested confirmation of primary custody by Court Order. 4. Based upon representations made by the Mother at the conference and the fact that the Father did not attend or contact the conciliator, the conciliator recommends an Order in the fonn as attached. --PJ.v~ r 1(,.' :J.oclc.f Date LO~. .d-__c~ Dawn S. Sunday, Esquire Custody Conciliator . Demetrios H. Tsarouhis, Esquire Law Office of Steckel and Stopp 1036 Main Street P.O. Box 159 Slatington, PA 18080 Gerasimos Dionysatos C/O Nicoletta Serifi Sokrataki 5 AGRINID30100 Greece