HomeMy WebLinkAbout01-2043 IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHARLES A. SATTERLY
Plaintiff, ~ CIVIL ACTION- LAW
VS.
·
BARBARA A. SATTERLY '
Defendant. ' IN CUSTODY
COMPLAINT FOR CUSTODY
1. The Plaintiff is Charles A. Satterly, an adult individual, presently residing at 1553 Mainsvil e
Road, Shippensburg, Franklin County, Pennsylvania 17257.
2. The Defendant is Barbara A. Satterly, an adult individual, presently residing at 150 Rustic Drive,
Shippensburg, Cumberland County, Pennsylvania ! 7257.
3. Plaintiff seeks custody of the following child:
NAME PRESENT RESIDENCE AGE
Cory A. Satterly 150 Rustic Drive 9 years
Shippensburg, pA 17257
The child was not born out of wedlock.
The child is presently in the custody of Barbara A. Satterly, who resides at 150 Rustic Drive,
Shippensburg, Cumberland County, Pennsylvania 17257
During the past five years, the child has resided with the following persons and at the following
addresses.
NAME ADDRESS DATE
Char/es A. Satterly and 1553 Mainsville Road 1991 - 1997
Barbara A. Satterly Shippensburg, PA 17257
Barbara A. Satterly 219 Meadow Drive 2/1997 - 2/1998
Shippcnsburg, pA 17257
·
WEIGLE, PERKINS & ASSOCIATES _ ATTORNEYS AT LAW 126 EAST KING STREET -- SHIPPENSBURG, P/k 17257-1397
Barbara A. Satterly 150 Rustic Drive 2/1998- Present
Shippensburg, PA 17257
The mother of the child is Barbara A. Satterly, currently residing at 150 Rustic Drive,
Shippensburg, Cumberland County, Pennsylvania 17257. She is divorced.
The father of the child is Charles A. Satterly, currently residing at 1553 Mainsville Road,
Shippensburg, Franklin County, PA 17257. He is divorced.
4. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the
following persons:
NAME RELATIONSHIP
Nicole M. Satterly Plaintiff s daughter from another relationship
Deirdre L. Satterly Plaintiff's daughter from another relationship
5. The relationship of Defendant to the child is that of mother. The Defendant currently resides
with the following persons'
NAME RELATIONSHIP
Cory A. Satterly Son
Nancy Fomey Defendant's Mother
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.
Plaintiff has no information of a custody proceeding concerning the child pending in a court of
this Commonwealth.
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 the parties currently do not have a regular schedule for the exercise of
Plaintiff' s rights of partial custody.
8. Each parent whose parental rights to the child have not been terminated 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'
WEIGLE, PERKINS & ASSOCIATES -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
NAME ADDRESS BASIS OF CLAIM
None
WHEREFORE, Plaintiff requests the Court to grant both shared legal and shared physical
custody of the minor child to the Plaintiff and Defendant.
WEIGLE, PERKINS & ASSOCIATES
David P. Perkins, Esquire
Attorney for Plaintiff
I.D.//34342
126 East King Street
Shippensburg, PA 17257
Telephone 717-532-7388
WEIGLE, PERKINS & ASSOCIATES -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
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. 4~04, relating to
unsworn falsification to authorities.
.
Dated:/~/~~fi ~.<~ ,~~/ . .
CHARLES A. SAT~ER~Y
WEIGLE, PERKINS & ASSOCIATES -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
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CHARLES A. SATTERLY : IN THE COURT OF COMMON PLEAS OF
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
V.
BARBARA A. SATTERLY
: 01-2043 CIVIL ACTION LAW
DEFENDANT
: IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, April 17, 2001 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, May 24, 2001 at 9:30 a.m.
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 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/ HubertX. Gilroy, 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 heating.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
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 Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHARLES A. SATTERLY · CIVIL ACTION- LAW
Plaintiff, ·
vs. : NO. 2001-02043
BARBARA A. SATTERLY :
Defendant. : IN CUSTODY
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA ·
· SS
COUNTY OF CUMBERLAND ·
Rhonda R. Wolford, being duly sworn according to law, deposes and says that on April 24, 2001,
tree and attested copies of Complaint for Custody together with Order of Court were served upon the
Defendant, Barbara A. Satterly. Manner of service: by mailing the same postage paid, certified mail,
addressee only, and return receipt requested, at Shippensburg, Pennsylvania, addressed as follows:
Barbara A. Satterly
150 Rustic Drive
Shippensburg, PA 172857
RHONDA R. WOLFORD
Sworn to and subscribed before
me this 25th day of April, 2001.
Notary Public
,.
· """ "; ;" ' ?.~'-...~ Notarial Seal
· ' '~: ' Patricia L. Tome, Notary_ Public
-.~,- - ' .... Shippe_ nsburg Boro, Cumberland County
~"-.-: .:.~.' .... My Commission Expiros June 7, 2004
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'WE'IGI2E.~'PEI~klNS'' --'' :'-:: "~---- & ASSOCIATES -- ATTORNEYS AT LAW- 126 EAST KING STREET- SHIPPENSBUR6, PA 17257-1397
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHARLES A. SATTERLY · CIVIL ACTION- LAW
Plaintiff, '
vs. · NO. 2001-02043
BARBARA A. SATTERLY '
Defendant. · IN CUSTODY
PROOF OF SERVICE
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Pl~ !7257
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r--1 Certified Fee $ :L. ?1"!
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Return Receipt Fee $1. ~0 Here
1::::3 (Endorsement Required)
1::::3 Restricted Delivery Fee
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I:~ Total Postage & Fees $ $7.1-5 04/23/2001
..13 [ Recipient's Name (Please Print ~learly) (to be completed by mailer)
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· Print your name and address on the reverse .... - '
so that we can return the card to you. C. Signature
· Attach this card to the back of the mailpiece,
or on the front if space permits. Addressee
1. Article Addressed to: No
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4. Restricted Deliver? (E~m F~) ~Ye~'
PS Form 3811, July 1999 ~mestic Return Receipt 102595-~-M-0952
WEIGLE, PERKINS & A55OCIATE5 -- ATTORNEYS AT LAW -- 126 ~5m KING STREET -- 5HIPPENSBURG, PA 17257-1397
CHARLES A. SATTERLY, · IN THE COURT OF COMMON PLEAS OF
·
Plaintiff · CUMBERLAND COUNTY, PENNSYLVANIA
v · NO. 01 - 2043 CIVIL ACTION- LAW
BARBARA A. SATTERLY, ·
Defendant · IN CUSTODY
COURT ORDER
AND NOW, this ~' Yta day of June, 2001, the Conciliator being advised that the parties have
reached an agreement, the Conciliator relinquishes jurisdiction.
BY THE COURT,
Hubert X. Gilroy, Esqup~e
Custody Conciliator/
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHARLES A. SATTERLY ' CIVIL ACTION- LAW
Plaintiff, .
vs. ' NO. 2001-02043
BARBARA A. SATTERLY .
Defendant. ' IN CUSTODY
STIPULATION AND AGREEMENT
This Stipulation and Agreement is made this ~ '~ ~ day of May, 2001, by and between
Charles A. Satterly, of 1553 Mainsville Road, Shippensburg, Franklin County, Pennsylvania,
(hereinafter referred to as "Father") and Barbara A. Satterly, of 150 Rustic Drive, Shippensburg,
Cumberland County, Pennsylvania, (hereinafter referred to as "Mother").
1. Charles A. Satterly and Barbara A. Satterly are the natural parents of Cory A. Satterly, bom
May 3, 1991, hereinafter referred to as "the child".
2. Charles A. Satterly has initiated a child custody action in the Court of Common Pleas of
Cumberland County and the parties are currently subject to a temporary Order of Court and
Directive for Conciliation with a pre-hearing custody conference scheduled for Thursday,
May 24, 2001, at 9'30 a.m.
3. The parties desire to continue generally the pre-hearing custody conference scheduled for
May 24, 2001.
4. The parties have reached an agreement with regard to the custody of the child, Cory A.
Satterly, and desire to reduce their agreement to an Order of Court.
NOW THEREFORE, the parties intending to be legally bound and waiving their fight to be
present when this Agreement and Order are presented and executed hereby stipulate and agree that
the Court may enter the following Order of Court in the above-captioned case:
ORDER OF COURT
NOW, , 2001, upon consideration of the within
Stipulation and Agreement, it is hereby ordered as follows:
WEIGLE, PERKINS & ASSOCIATES --ATTORNEYS AT LAW- 126 EAST KING STREET- SHIPPENSBURG, PA 17257-1397
1. Charles A. Satterly and Barbara A. Sattefly shall have shared legal custody of
the child, Cory A. Satterly, bom May 3, 1991.
2. Charles A. Satterly and Barbara A. Satterly shall have shared physical custody
of the child, Cory A. Satterly.
3. Father and Mother shall share all educational and medical information
concerning the child and shall keep the non-custodial parent advised with
respect to any medical emergencies.
By the Court,
Je
The parties further agree that, in procuring this Agreement, there has been no fraud,
concealment, overreaching, coercion, or other unfair dealing on the part of the other.
IN WITNESS WHEREOF, the parties, intending to be bound by the terms and conditions of
this agreement, execute this Agreement by signing below.
·
Witness
Respectfully submitted
WEIGLE, PERKINS & ASSOCIATES
David P. Perkins, Esquire
Attorney for Plaintiff
Attorney I.D. #34342
126 East King Street
Shippensburg, pA 17257
Telephone 717-532-7388
WEIGLE, PERKINS & ASSOCIATES -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
I verify that the statements made in this Stipulation and Agreement 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 unswom falsification to authorities.
C~AR~,L~ A. S~TTERLY
I verify that the statements made in this Stipulation and Agreement 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 falsification to authorities.
WEIGLE, PERKINS & ASSOCIATES --ATTORNEYS AT LAW -- 126 EAST KING STREET- SHIPPENSBURG, PA 17257-1397
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHARLES A. SATTERLY · CIVIL ACTION- LAW
Plaintiff, ·
vs. ' NO. 2001-02043
BARBARA A. SATTERLY ·
Defendant. · IN CUSTODY
.ORDER OF COURT
'~J~~ "'~O , 2001, upon consideration of the within Stipulation and
NOW,
Agreement, it is hereby ordered as follows'
1. Charles A. Satterly and Barbara A. Satterly shall have shared legal custody of the child,
Cory A. Satterly, bom May 3, 1991.
2. Charles A. Satterly and Barbara A. Satterly shall have shared physical custody of the child,
Cory A. Satterly.
3. Father and Mother shall share all educational and medical information concerning the child
and shall keep the non-custodial parent advised with respect to any medical '
By the Court,
.~.
.
Jo
WEIGLE, PERKINS & ASSOCIATES -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397