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Home My WebLink About05-2425 ,{II TI A CAfLf}/JI/Ar~ i)LtAIt1TI~F I rJ ({) ~fLr I r &rntArw. PL.=:7K &<< (l.,<:;-fl-c...V\--A.~ Cc;-1f''' I( u, t#;}L(f)'~4d.S- Cli/{[ JCILn{ .s-1t1'V\ v ~ t /Ii( 11-- .y1TJ ,<frtW D I::J:;;:A ~~""\ (2...( V / L Ik- T7 (/..,0- e-v <:;. (V D '1 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 AN ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. OU ARE WARNED THAT IF YOU FAIL TO 00 SO THE CASE HAY PROCEED WI 'HOUT YOU AND A JUDGMENT HAY BE ENTERED AGAINST YOU BY THE COURT W THOU~ FURTHER NOTICE FOR ANY MoNEY CLAIMED IN THE COMPLAINT OR R ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU.. Y LOSS HONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. . YOU 00 OR THE HELP. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO THE TELEPHONE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL / ClJI1BERLAND COUN'I'Y BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE PA 17013 717 249 3166 ~ KATIA CARANNANTE, Plaintiff VS. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. OF ;)LfgS CIVIL TERM SAMUELE CARANNANTE, Defendant : CIVIL ACTION - CUSTODY COMPLAINT OF CUSTODY TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW COMES, the Plaintiff, KATIA CARANNANTE, by and through its attorneys, Coyne & Coyne, P.C., and avers the following in support of this complaint of custody: I. Plaintiff is KATIA CARANNANTE, an adult individual, who currently resides at 4 Oakwood Court, Camp Hill, Cumberland County, Pennsylvania; 2. Defendant is SAMUELE CARANNANTE, an adult individual, who currently resides at 104 Lafayette, Elkton, MD 21921; 3. Plaintiff is the mother of MICHAEL PIa CARANNANTE, born April 7, 2001; 4. Defendant is the father of MICHAEL PIO CARANNANTE; 5. Plaintiff seeks custody of her minor son MICHAEL PIa CARANNANTE 6. The child was NOT born out of wedlock. 7. The child is presently in the custody of the Plaintiff Mother who resides at 4 Oakwood Court, Camp Hill, Pennsylvania. -. 8. For the last five years, the child has resided with the following persons and at the following addresses: Name: Residence: Dates: Katia Carannante 4 Oakwood Court Camp Hill, PA 17011 Early 2005 to Present Katia Carannante and Samuele Carannante Delaware April 7, 2001 to Early 2005 10. The Mother of the minor child is the Plaintiff. II. The Father of the child is the Defendant. 12. The relationship of the Plaintiff to the child is that offather. 13. The relationship of the Defendant to the child is that of father. 14. 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. 15. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. 16. Plaintiff does not know of a person not a party to the proceedings that has physical custody of the child or claims to have custody or visitation rights with respect to the child. 17. Since the child's birth, the child has always resided with the child's mother. 18. The best interest and welfare of the minor child will be served by adopting the parties signed custody agreement which is attached to this document 19. Each parent whose parental rights to the child haye not been terminated and the person who has physical custody of the children have been named as parties to this action. All other persons, 2 . named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendancy ofthis action and the right to intervene: None. WHEREFORE, Plaintiff requests this Honorable Court to adopt the parties custody agreement and grant Plaintifflegal and physical custody of the minor child, MICHAEL PIa CARANNANTE Respectfully submitted, COYNE & COYNE, P.C. Dated: 6'- 11-" c(" LISA MARIE C 3901 Market Street CampHill,PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 A ttorneys for Plaintiff 3 VERIFICATION I, KATIA CARANNANTE, certifY that the statements made in the foregoing document are true and correct to the best of my knowledge, information, and belief and that this verification is subject to the penalties of 18 Pa, C.S, Section 4904, relating to unsworn falsification to authorities. Date S' j/- O!- (p ko.-n'ot 20 hn iA \AD LLt- ~_ KATIA CARANNANTE 4 ("} (;'--~ ~( ~ q- ..... ~. ~ - A.k '-'\ u.J 0 E;' ~ v.) ~ ~ -v ;:>.. ..1) Cf) ~ " =-" <> -J ,...., c::-J ~;.~ -' ~J_" ;-::.>" -<: @ ~~t: ..i- - Ci -n -l :t:-n In?' "::r!\\:~j ::~>~ (~t) .,.~ ", , -: -1', ;,~.-,~ 1") ;_,:-:Sn:1 ...~~ ~-):~ ....... co N -------- - .. ... " KATlA CARANNANTE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. (J f. 2 'pO" CIVIL TERM YS. SAMUELE CARANNANTE, Defendant : CIVIL ACTION - CUSTODY CUSTODY STIPULATION AND AGREEMENT AND NOW, this '2-~f}I day of A- f!?-r L , 2005, the parties, KATIA CARANNANTE, Plaintiff, and SAMUELE CARANNANTE, Defendant, hereby stipulate and agree as follows: I, The Plaintiff, KA TIA CARANNANTE, is the mother of MICHAEL PIO CARANNANTE, born April 7, 2001. 2, The Defendant, SAMUELE CARANNANTE, IS the father of MICHAEL PIO CARANNANTE, born April 7, 2001. 3. The parties are married, 4. From birth, MICHAEL PIO CARANNANTE, resided with his mother, KATIA CARANNANTE and mother has been the primary care taker of the minor child. 5. The Plaintiff and minor child reside at 4 Oakwood Court, Camp Hill, Hampden Township, Cumberland County, Pennsylvania. 6, The parties hereby agree and stipulate that it is in the best interest of MICHAEL PIO CARANNANTE that the mother maintains primary legal and physical custody of MICHAEL PIO CARANNANTE with father to have periods of visitation as the parties may agree. 7. The parties agree that the Plaintiff may travel to and from Italy with the minor child for periods of vacation. 8. The parties hereby stipulate and agree that the Court of Common Pleas of Cumberland County, Pennsylvania is the proper court for jurisdiction and venue concerning this custody matter and the parties waive any and all objections, if applicable, thereto. 1 . . ~ , 9. The parties hereby stipulate and agree that this Agreement shall be incorporated into a Custody Order to be issued by the Cumberland County Court of Common Pleas. 10. The parties hereby stipulate and agree that they have conferred with their own individual legal counsel prior to executing this agreement. 11. The parties may modify this Agreement at any time upon mutual agreement of the parties. WHEREFORE, the parties hereby request that an appropriate Order of Court be entered to reflect the above agreed terms concerning custody of the minor child, MICHAEL PIO CARANNANTE. ,\ K~~,0{ (-1fiOilOIM)iA)~ KATlA, CARANNANTE, Plaintiff ., Witness O '/~__- i. . ..---+1' ,,)I)~(,~J, c .'- L SAMUELE CARANNANTE, Defendant 2 ~ o I RECEIVED MAY 122005, KATIA CARANNANTE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAl'I'D COUNTY, PENNSYL VANIA YS. ; NO. ()i)-J'fJ) CIVIL TERM SAMUELE CARANNANTE, Defendant : CIVIL ACTION - CUSTODY ORDER 'l^ AND NOW, this ~ day of MAY, 2005, upon consideration of the parties' custody stipulation and agreement, dated APRIL 25, 2005, attached hereto and incorporated herein, it is hereby ORDERED that: 1. The Plaintiff, Katia Carannante, shall have sole legal and physical custody of the minor child, MICHAEL PIO CARANNANTE, born April 7,2001; 2. The Defendant, Samuele Carannante, may have periods of visitation with MICHAEL PIO CARANNANTE, upon mutual agreement with Plaintiff; 3. The Plaintiff may travel to and from Italy with the minor child for periods of vacation; and 4. The parties may modifY this Custody arrangement at any time upon mutual agreement of the parties. ~: J. CF: Lisa Marie Coyne, Esquire For Plaintiff Samuele Carannante, Pro Se ~ ~ 5-,11~b{ , L)c... , ,.., r~. '.- 'i,") ..) \.\'\ , '.- \ ,,~1 ,;p\ ~\~U'" ,:..j\..... ~,o ----