The URL can be used to link to this page

Home My WebLink About05-6247 McNEES WALLACE & NURICK LLC By: Debra Denison Cantor Attorney ID No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 facsimile dcantor@mwn.com Attorneys for Plaintiff MICHELLE D. CALVANELLI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. OS'" - w'1.J7 C.;o;L 1eR-~ IN CUSTODY PHILIP CALVANELLI, Defendant CUSTODY COMPLAINT 1. Plaintiff is Michelle D. Calvanelli, who currently resides at 3911 Cherylbrook Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Philip Calvanelli, who currently resides at 3911 Cherylbrook Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff seeks legal custody and physical custody of the following children: NAME PRESENT RESIDENCE DATE OF BIRTH Courtney M. Calvanelli 3911 Cheryl brook Drive Mechanicsburg, PA 2/25/98 Megan S. Calvanelli 3911 Cheryl brook Drive Mechanicsburg, PA 6/5/02 4. The children were not born out of wedlock. 5. The children are presently in the custody of Plaintiff and Defendant, who reside at 3911 Cherylbrook Drive, Mechanicsburg, PA. 6. For the past five years, the children have resided with the persons at the following addresses: LIST ALL PERSONS LIST ALL ADDRESSES Michelle D. Calvanelli 3911 Cherylbrook Drive Mechanicsburg, PA Philip Calvanelli 3911 Cheryl brook Drive Mechanicsburg, PA 7. The Mother of the children is Plaintiff currently residing at 3911 Cherylbrook Drive, Mechanicsburg, Cumberland County, Pennsylvania. She is married. 8. The Father of the children is Defendant currently residing at 3911 Cherylbrook Drive, Mechanicsburg, Cumberland County, Pennsylvania. He is married. 9. The relationship of Plaintiff to the children is that of Mother. Plaintiff currently resides with the following persons: NAME RELATIONSHIP Courtney M. Calvanelli Daughter Megan Calvanelli Daughter Philip Calvanelli Husband 10. The relationship of Defendant to the children is that of Father. Defendant resides with the following persons: NAME Courtney M. Calvanelli Megan Calvanelli Michelle D. Calvanelli RELATIONSHIP Daughter Daughter Wife 11. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of these children in this or another court. 12. Plaintiff does not know of a person nor 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. 13. The best interest and permanent welfare of the children will be served by granting the relief requested because: (a) Mother has been the children's primary caregiver their entire lives, and is best able to take care of them; and (b) Other reasons which may more fully appear at hearing. 14. Each parent whose parental rights to the children has not been terminated and the person who has physical custody of the children have been named as parties to this action. No other persons are known to have or claim a right to custody or visitation of the children. WHEREFORE, Plaintiff requests the Court to grant her shared legal custody and primary physical custody with rights of partial custody to Defendant. McNEES WALLACE & NURICK LLC By~D ~fif ebra D. Cantor I.D. No. 66378 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 (fax) Dated: December ~ 2005 Attorneys for Plaintiff, Michelle D. Calvanelli VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S. 94904, relating to unsworn falsification to authorities. \V\ J~ll C',J\_)~..JL Dated: ~ 2, '2VV"f"" p ;,q. - 70 - li - ~ 6- - ~ -J ...:t \- - ...:t ~ ~ ~ - -::t -..c.... (~'"' c;~ ~; ~ ~. ., , \ r .. _.~ ---- /---- MICHELLE D. CAL V ANELLI PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 05-6247 CIVIL ACTION LAW PHILIP CAL V ANELLI DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, Decemb~r 08, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. . the conciliator, at 39 West MlI.i~~tree.!t.JYI-".cl1l1nicstJ.I!~~,-J>~17l!5~ on Tuesday, January 03, 2006 at II :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 bc accomplished, to dcline and narrow thc issues to be heard by the court, and to enter into a temporal)' order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds I,)r 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/ Dawn S. Sunday, Esq. Custody Conciliator .tF 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 HA VE 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 C ounly Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 4b/~ iw :$ rrw ~ 50', 6, ~I ,;ch/'.-;: ~ ~tt, J'o' fJ. r; ,~fp? ~/f?~~ -n >>'c-EI ~_~~; : n I."! C - , ':1 .~\ I McNEES WALLACE & NURICK LLC By: Debra Denison Cantor Attorney 10 No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 facsimile dcantorlalmwn.com Attorneys for Plaintiff MICHELLE D. CALVANELLI, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-6247 CIVIL TERM PHILIP CALVANELLI, Defendant IN CUSTODY AFFIDAVIT OF ACCEPTANCE OF SERVICE I hereby accept service of the Custody Complaint in the above matter on behalf of Defendant, Philip Calvanelli. IT.J uire Dated: December i5, 2005 l \",- c RECEIVED MAR 1 7 Z006 MICHELLE D. CALVANELLI Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 05-6247 CIVIL ACTION LAW PHILIP CAL V ANELLI Defendant IN CUSTODY ORDER AND NOW, this 16th day of March,2006 ,the conciliator, having received no request from counsel for either party to reschedule the custody conciliation conference initially set for January 12,2006, hereby relinquishes jurisdiction. FOR THE COURT, ( ~/Cb-L Dawn S. Sunday, Esquire U- Custody Conciliator o {l:j He! I Z lJlJl>l 9DDl "'rilf''''''''>'''' ::ill' '0 Ati'l_Vi\JUI iL',~<::'Q _1I'L:i 3:JU :!Cc{Bll:l