HomeMy WebLinkAbout04-6104SHANNON QUIGLEY,
Plaintiff
TONY DOLIMPIO,
Defendant
PENNSYLVANIA
CIVIL ACTION - LAW
IN CUSTODY
NO. 04-
custody
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
CIVIL TERM
Address
1924 Market Street
Apt. 3
Camp Hill, PA 17011
Date
8-03 to present
and at the following addresses:
Individuals
Shannon Quigley
The Plaintiff, by and through her attorneys, The Family Law Clinic, sets forth the
following in support of her complaint for Custody:
1. The Plaintiff is Shannon Quigley, residing at 1924 Market Street, Apt. 3,
Camp Hill, Cumberland County, PA 17011.
2. The Defendant is Tony Dolimpio, residing at 52 South 18th Street, Camp Hill,
Cumberland County, PA 17011.
3. Plaintiff seeks custody of the following child:
Name Present Residence Age
Julia Samantha Dolimpio 1924 Market Street 1
Apt. 3 (DOB 2-7-03)
Camp Hill, PA 17011
The child was bom out of wedlock.
The child is presently in the custody of Shannon Quigley, who resides at 1924
Market Street, Apt. 3, Camp Hill, Cumberland County, Pennsylvania.
During the past five years, the child has resided with the following persons
Shannon Quigley 100 Hill Dale Road 2-7-03 to 8-03
Louis Cannell Etters, PA 17319
The mother of the child is Shannon Quigley, currently residing at 1924
Market Street, Apt. 3, Camp Hill, Cumberland County, PA 17011.
She is single.
The father of the child Is Tony Dolimpio, currently residing at 52 South 18th
Street, Camp Hill, Cumberland County, PA 17011.
He is single.
The relationship of Plaintiff to the child is that of mother. The Plaintiff
currently resides with the following persons:
Name
Julia Samantha Dolimpio
5.
currently resides with the following persons:
Name
Kyle Shoemaker
Relationship
Daughter
The relationship of Defendant to the child is that of father. The Defendant
Relationship
Friend
Josh Rhodes Friend
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 conceming 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. Plaintiff is best able to provide the care and nurturing which the child
needs for healthy development;
b. Plaintiff provides the child with a home with adequate moral,
emotional and physical surroundings as required to meet the child's needs;
c. Plaintiff is willing to accept custody of the child;
d. Plaintiff exercises parental duties and enjoys the love and affection of
the child;
e. Plaintiff will encourage child to develop and maintain a strong
relationship with the child's father.
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.
WHEREFORE, Plaintiff requests the court to grant her sole legal custody and
primary physical custody of the child, granting father periods of partial custody at times
mutually agreed by the parties.
Date:
~AL~;~.~LO
Certified Legal In~ee,~q
THOMAS M. PLACE
ANNE MACDONALD-FOX
Supervising Staff Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
Counsel for Plaintiff
VERIFICATION
I verify that the statements made in this Complaint are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
{}4904 relating to unsworn falsification to authorities.
SHANNON QUIGLEY, Plaintiff
Vo
TONY DOLIMPIO,
Defendant
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN CUSTODY
NO. CIVIL TERM
PRAECIPE TO PROCEED IN
FORMA PAUPERIS
To the Prothonotary:
Kindly allow Shannon Quigley, Plaintiff, to proceed in forma pauperis.
I, Alexis C. Falvello, Certified Legal Intem in the Family Law Clinic, attorneys for the
party proceeding in forma pauperis, certify that we believe the party is unable to pay the costs
and that we are providing free legal service to the party.
Date: I[ lq 0q
-A'LE~I~ C. I~VELLO
Certified Legal l~tem
LTnU PZN W^Ls , /
ROBERT E. RAINS
ANNE MACDONALD-FOX
Supervising Attorneys
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Attorneys for Plaintiff
SHANNON QUIGLEY, ·
Plaintiff, '
TONY DOLIMPIO, ·
Defendant. ·
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN CUSTODY
No. CIVIL TERM
CUSTODY AGREEMENT
THIS AGREEMENT, made this ,,~{t~ay of 0cat3~x% 2004, between Defendant,
Tony Dolimpio (Father) and Plaintiff, Shannon Quigley (Mother) concerns the custody of
the parties' child, Julia Samantha Dolimpio, born February 7, 2003.
WHEREAS, Father and Mother desire to enter into an agreement as to the
custody of the children and to have this agreement made an Order of Court, Father and
Mother agree to the following:
1. Mother and Father shall have shared legal custody of the child. Each
parent shall have an equal right, to be exercised jointly with the other parent, to make all
major non-emergency decisions affecting the Child's general well-being including, but
not limited to, all decisions regarding her health, education and religion. Pursuant to the
terms of this paragraph each parent shall be entitled to all records and information
pertaining to the Child, including, but not limited to, school and medical records and
information.
2.
3.
Mother shall have primary physical custody of the child.
Father shall have periods of physical custody of the minor child at times
mutually agreed upon by the parties.
4. Father shall not have the minor child for ovemight visits during his times
of physical custody of the child until he obtains living accommodations that both parties
agree are suitable for the child.
1N WITNESS WHEREOF, the parties intend to be legally bound by the terms of
this agreement and have made it an Order of the Court.
Tony Doli~pio, Defgndant
Thomas lVl/?lace
Robert E. ~ains
Lucy Johnston-Walsh
Anne McDonald-Fox
Supervising Attorneys
Shannon Quigley,
-.A~I e~i s Fal~ellq
Certified Legalklotem
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968