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Home My WebLink About05-6317 LORI-BETH SALUTI , Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : IN CUSTODY GREGORY T, BRYETT , Defendant. : NO. ()')-f.;3t7 CIVIL TERM NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court, If you wish to defend against the claims set forth in the following pages, you must take prompt action, You are warned that if you fail to do so, you may lose rights of custody and visitation of your child, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER 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 32 S. Bedford St. Carlisle, P A 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations avail 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. LORI-BETH SALUTI , Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v, GREGORY T. BRYETT , Detendant. : CIVIL ACTION - LAW : IN CUSTODY :NO. CIVIL TERM COMPLAINT FOR CUSTODY The plaintiff, Ms, Lori-Beth Saluti, by her attorneys, the Family Law Clinic, sets forth the following cause of action in custody, 1, The plaintiff is Ms, Lori-Beth Saluti, residing at 8 East Orange Street, Shippensburg, Cumberland County, Pennsylvania 17257, 2, The defendant is Mr. Gregory T, Bryett, residing at P,O, Box 139, Bridgewater, Plymouth County, Massachusetts 02324, 3, Plaintiff seeks primary custody of: Name Hailey Beth Bryett The child was born out of wedlock. Present Residence 8 Orange Street Shippensburg, P A 17257 Age 7 The child is presently in the custody of Lori-Beth Saluti, who resides at 8 East Orange Street, Shippensburg, Cumberland County, Pennsylvania, 17257. During the past five years the child has resided with the following persons at the following addresses: Persons Lori-Beth Saluti (mother), Courtney Saluti (half-sister), Lori-Beth Saluti (mother), Courtney Saluti (half-sister), Gregory T, Bryett (father), Lori-Beth Saluti (mother), Courtney Saluti (half-sister), Gregory T. Bryett (father), Address 8 East Orange Street Shippensburg, P A 17257 8 East Orange Street Shippensburg, P A 17257 355 Baltimore Road Shippensburg, P A 17257 Dates August 18 2005 - Present March 2003 - August 18,2005 September 2002 - March 2003 Lori-Beth Saluti (mother), Courtney Saluti (half-sister), Gregory T. Byrett (father). 56 Humphrey Street New Bedford, MA 02745 March 2000 - March 2003 The mother of the child is Lori-Beth Saluti, currently residing at 8 East Orange Street, Shippensburg, Cumberland County, Pennsylvania 17257, She is married but separated from her husband who is not the father of Hailey Beth Bryett. The father of the child is Gregory T. Bryett. He is single, 4. The relationship of plaintiff to the child is that of mother. The plaintiff currently resides with the following persons: Name Lori-Beth Saluti Courtney Saluti Relationship Mother Half-sister 5, The relationship of defendant to the child is that of father. The defendant currently resides alone, 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court, Plaintiff has no information of a custody proceeding concerning the children 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 children or claims to have custody or visitation rights with respect to the children, 7, The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Plaintiff has been the child's primary caretaker for all of the child's life; b, Plaintiff provides the child with a stable home and environment with adequate moral, emotional, and physical surroundings as required to meet the child's needs; c, Plaintiff has permitted contact between Defendant and the child and will continue to encourage a relationship between the child and the Father. d. Plaintiff is willing to accept custody of the child. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody to the child have been named as parties to this action, WHEREFORE, plaintiff requests the court to grant her shared legal custody and primary physical custody of the child, with the father having periods of partial custody, Respectfully submitted, Date: .' c '('C- .J/ "..) / .~-' J<t. i /1 it r") I ,,/.J.k {\" l ',j - -' Sarah Rubright Certified Legal Intern ~(~ tN~- U)t~l THO i\S . . PLACE ROBERT E, RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys THE F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 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. 9 4904 relating to unsworn falsification to authorities. WC.)\J- -'-(O~J.J,-),~f.L1h ,-X.\.._' Lori-Beth Saluti 1-1 -n v t:~~ '..:::::/ ,-, -it ,-j I c \'._;' ~ LORI-BETH SALUTI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION. LAW : IN CUSTODY : NO. 05- [.314 CIVIL TERM GREGORY T. BRYETT Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Ms. Lori-Beth Saluti, Plaintiff, to proceed in forma pauperis, The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date / Z/ ~/OS , ii..' /'_ (', \"--f " , i/ /;U \" T Sarah L. Rubright Certified Legal Intern I) 1()r/ ,CJ! ;;;:^' G<-r1 /1~'ccK-b L " BElfl:, RAINS THOMAS M, PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Supervising Attorneys F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 . LORI-BETH SALUTI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v, : CIVIL ACTION - LAW : IN CUSTODY GREGORY T, BRYETT, Defendant. :NO, CIVIL TERM CUSTODY AGREEMENT THIS AGREEMENT, made this _ day of , 2005, between Lori- Beth Saluti, hereinafter Mother, and Gregory T. Bryett, hereinafter Father, concerns the custody of their child: Hailey Beth Bryett, born June 20, 1998. Mother and Father desire to enter into an agreement as to the custody of the child, Mother and Father agree to the following: I. Mother and Father shall share legal custody of the child. All decisions affecting the child's growth and development shall be considered major decisions and shall be made by the parents jointly, after discussion and consultation with each other, and with the view towards obtaining and following the child's best interests which decisions shall include, but not limited to, all medical and dental treatment, religious upbringing, education, scholastic or athletic pursuits, and other extracurricular activities, 2, Mother shall have primary physical custody ofthe child, 3. Father shall have periods of partial physical custody ofthe child. 4, Father will call in advance before the child is permitted to go to Father's residence, 5, Mother and Father will agree upon all transportation arragnements, . 6. Mother and Father will agree upon which holidays child will spend with each parent. 7. Mother and Father will notifY each other of all medical care the child receives while in the parent's care, Mother and Father will notify the otheT immediately of medical emergencies which arise while the child is in that parent's care, 8, Neither parent will do anything which may estrange the child from the other party, or injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's love and respect for the other parent. 9, Father acknowledges that the Family Law Clinic represents only Mother's interest in this matter and has given him no legal advice other than that he should seek the advice of legal counsel. 10, The parties intend to be bound by the terms of this agreement and intend for this Agreement to be made an Order of Court. .. \,--()\,- \~j t h ,,~L Lori-Beth Saluti, Plaintiff J~~~ Gregory T, Bryett, Defendant %~'1b ~,/ '/- A ,,-, 0A.;jlt'orr Sara u fig Certified Legal Intern Counsel for Plaintiff r'dl..l (./' /~C~' 'c/zk~ ,\ 'ROrWR E, RAINS THOMAS M, PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Counsel for Plaintiff FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 Phone (717)243-2968 Fax (717)243-3639 ---- , .,:' ".,' :, ....::} !J LORI-BETH SALUTI, Plaintiff DEe 1 2 2005 r/ './11 , (-il \/ : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ... v ." VI. : CIVIL ACTION - LAW : IN CUSTODY : NO, ()S~{,31? CIVIL TERM GREGORY T. BRYETT, Defendant. ORDER OF COURT AND NOW, this --1t..{ tr'-- day of ~ ,2005, the attached Custody Agreement is approved and entered as an Order of Court. ~"L &0~) ,\ -03 \d- _\'1 "..i ,,,. I', " r d) : \ .~ ,-',l '-, 1,1.. _ _.._~_.~-