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HomeMy WebLinkAbout02-1430Peter A. Garcia Attorney at Law P. O. Box 850 Trenton, New Jersey 08625 PA Attorney Number: 49969 Attorney for VANESSA ANN T~SSONE IN THE MATTER OF: ANNE E. BARTLETT JOHN D. BARTLETT CARRIE E. BARTLETT :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION LAW :No. CIVIL 02 -/v3o :VERIFIED COMPLAINT IN CUSTODY 1. The plaintiff is VANESSA ANN ~SSONE residing at 20 Cedar Wood Drive, Waltham, MA. 2. The defendant is DAVID P. BARTLETT, JR. residing at 206 A. Marshall Road Carlisle Barracks, Carlisle, PA 17013. 3. Plaintiff seeks temporary custody of the following children: ANNE E. BARTLETT, age 3, residing at 206 A. Marshall Road, Carlisle Barracks, Carlisle, PA 17013, JOHN D. BARTLETT, age 5, residing at 206 A. Marshall Road, Carlisle Barracks, Carlisle, PA 17013, CARRIE E. BARTLETT, age 8, residing at 206 A. Marshall Road, Carlisle Barracks, Carlisle, PA 17013. The children were not bom out of wedlock. The children presently are in the custody of their father, DAVID P. BARTLETT, JR. who resides at the above the referenced address. The mother of the children, SUZANNE T. BARTLETT, is deceased. She was married to DAVID P. BARTLETT, JR. until the time of death which concurred on or about 20 March 2002. 4. The plaintiff, VANESSA ANN TJ~SSONE is the sister of the decedent, SUZANNE T. BARTLETT, and is the aunt of the children in paragraph three referenced above. 5. The defendant, DAVID P. BARTLETT, JR., is the biological father of the children referenced in paragraph three above. 6. The plaintiff has not participated as a party or wimess or in any other capacity in any other litigation concerning the custody of the minor children in this or any other court. 7. The best interest and permanent welfare of the children will be served by granting temporary custody to the plaintiff, VANESSA ANNE TESSONE. 8. The plaintiff and defendant have signed a consent order which is hereto attached and incorporated hereto by reference as if part of the complaint. WHEREFORE, the plaintiff requests this court to grant temporary custody of the children to the plaintiff; A. The parties have consented to temporary custody being granted. B. The consent order is hereto attached and is incorporated as part of this complaint. WHEREFORE, the plaintiff further demands any other such relief as the court may deem equitable and just. DATE: PETER A. GARCIA, Esquire Attorney at Law State of Pennsylvania Pro Bono Counsel for the Plaintiff I verify that the statements made in this complaint are tree and correct. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Plaintiff Peter A. Garcia Attorney at Law P. O. Box 850 Trenton, New Jersey 08625 PA Attorney Number: 49969 Attorney for VAN-ESSA ANN TESSONE IN THE MATTER OF: ANNE E. BARTLETT JOHN D. BARTLETT CARRIE E. BARTLETT :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA : :CIVIL ACTION LAW-IN CUSTODY :CUSTODY CONSENT ORDER On this, 22nd day of March 2002, upon consideration of the attached verified complaint. It is hereby directed that temporary custody of ANNE ELIZABETH BARTLETT, JOHN DAVID BARTLETT, and CARR~ ELI~ABv~Tr~I' BARTLETT, is hereby granted, to the children's aunt, Ms. Vanessa Ann TCssone, who resides at 20 Cedar Wood Drive, Waltham, MA, until 1 July 2002, at which time it will expire unless extended by the mutual consent of the parties. This consent order allows Vanessa TCssone to make all decisions concerning the health, education, and welfare of the above referenced children, as if she were the natural parent. All decisions will be made in the best welfare and interests of the children. This temporary custody is being offered voluntarily by the natural father, DAVID P. BARTLETT, JR. of the above referenced children. Date: p¢~,¢c¢/ 23 -~o~ ~- DAVID P. BARTLETT, JR. / (Natural Father-Current Custodian) Date: Date: VANESSA ANN TI~SONE (Aunt - Temporary Uustodian) t tile Court ~__~ - ~te Honorable Peter A. Garcia Attorney at Law P. O. Box 850 Trenton, New Jersey 08625 PA Attorney Number: 49969 Attorney for VANESSA ANN TESSONE IN THE MATTER OF: ANNE E. BARTLETT JOHN D. BARTLETT CARRIE E. BARTLETT :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION LAW-IN CUSTODY :No. CIVIL 0~ [~3D :CUSTODY CONSENT ORDER On this, 22nd day of March 2002, upon consideration of the attached verified complaint. It is hereby directed that temporary custody of ANNE ELIZABETH BARTLETT, JOHN DAVID BARTLETT, and CARRIE ELI,Z&ABvF~kTftJ, BARTLETT, is hereby granted, to the children's aunt, MS. Vanessa Ann T~one, ~vho resides at 20 Cedar Wood Drive, Waltham, MA, until 1 July 2002, at which time it will expire unless extended by the mutual consent of the parties. This consent order allows Vanessa T~§sone to make all decisions concerning the health, education, and welfare of the above referenced children, as if she were the natural parent. All decisions will be made in the best welfare and interests of the children. This temporary custody is being offered voluntarily by the natural father, DAVID P. BARTLETT, JR. of the above referenced children. DAVID P. BARTLETT, JR. (Natural Father-Current CustodianJ Date: VANESSA ANN T~P~SONE (Aunt - Temporary Custodian) Date: For the Court The Honorable IN THE COURT OF COMMON PLEAS OF THE 39t~ JUDICIAL DISTRICT OF PENNSYLVANIA CUMBERLAND COUNTY BRANCH Vanessa A. Tassone, VS. David P. Bartlett, Jr., ) Plaimiff, ) ) ) ) ) Defendant, ) Civil Action - Law No. F.R. # 2t9 d,2, -/,~..~ dj Cllstody STIPULATION AND AGREEMENT between Vanessa A. Tassone of 1091 Edgewood Avenue, Rochester New York 14618, hereinafter referred to as "Vanessa" and David P. Bartlett, Jr. of Marshall Road, Army War College, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as "David." 1. David is the natural father of three children, Caroline E. Bartlett, bom December 17, 1993, John D. Bartlett, bom July 6, 1996, and Anne E. Bartlett, bom September 29, 1998, hereinafter referred to as "the children." 2. The children's natural mother, Suzanne T. Bartlett, is deceased. 3. Defendant, Vanessa A. Tassone, is the maternal aunt of the children. 4. None of the parties know of any 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. 5. The parties are currently subject to a Consent Order dated March 22, 2002, a copy of which is attached hereto, incorporated herein and marked as Exhibit "A." 6. During the last five years, the children have resided with the following persons and at the following addresses: Name David P. Bartlett, Jr. and Suzanne T. Bartlett Address Marshall Road, Army War College Carlisle, Pennsylvania Date From 1996- 3/19/02 Vanessa A. Tassone 1091 Edgewood Avenue Rochester, NY 14618 3/20/02 - Present 7. Plaintiff, Vanessa, is represented by Lynn Y. MacBride, Esquire with regard to this matter. 8. Defendant, David, is represented by Steven Chucala, Esquire with regard to this matter. 9. The parties have reached an agreement with regard to the custody of the children and desire to reduce their agreement to an Order of Court. NOW THEREFORE, the parties intending to be legally bound and waiving their right 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, ., 2002, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: 1. Vanessa A. Tassone ("Vanessa") shall have legal and physical custody of Caroline E. Bartlett, born December 17, 1993, John D. Bartlett, bom July 6, 1996, and Anne E. Bartlett, bom September 29, 1998 (hereinafter "the children"). 2. David P. Bartlett, Jr. ("David") shall have partial physical custody of the children as Vanessa and David may from time to time mutually agree. 3. The costs of this proceeding have been paid by Vanessa. By the Court Jo The parties fu~er 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: Vanessa A. Tassone 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. Vanessa A. Tassone I verify that the statements made in this Stipulation and Agreement are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 1063654 · . artlett, Jr. ~ Peter A. Garcia Attorney at Law P. O. Box 850 Trenton, New Jersey 08625 PA. Attorney Number: 49969 Attorney for VANESSA ANN TESSONE IN THE MATTER OF: ANNE E. BARTLETT JOHN D. BARTLETT CARRIE E. BARTLETT :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION LAW-IN CUSTODY :No. CIVIL O~- :CUSTODY CONSENT ORDER On this, 22nd day of March 2002, upon consideration of the attached verified complaint. It is hereby directed that temporary custody of ANNE ELIZABETH BARTLETT, JOHN DAVID BARTLETT, and CARRW. EL ~I~ZAt~. ~,~H BARTLETT, is hereby granted to the children's aunt, Ms. Vanessa Ann T~sonV~vho resides at 20 Cedar Wood Drive, Waltham, MA, until 1 July 2002, at which time it will expire unless extended by the mutual consent of tl~e parties. This consent order allows Vanessa T~ssone to make all decisions concerning thc health, education, and welfare of the above referenced children, as if she were the natural parent. All decisions will be made in the best welfare and interests of the children. This temporary custody is being offered voluntarily by the natural father, DAVID P. BARTLETT, JR. of the above referenced children. DAVID P. BARTLETT, JR. ~/ (Natural Father-Current Custodian) Date: VANESSA ANN TI~SSONE (Aunt - Temporary Custoaian) Date: -/¢I~ ~. /zgoz, /2 //5/ (~ ' ~. ...... Fo(the ~Cou~ .... - The Honorable Peter A. Garcia Attorney at Law P. O. Box 850 Trenton, New Jersey 08625 PA Attorney Number: 49969 Attorney for VANESSA ANN ~I~SSONE IN THE MATTER OF: :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA ANNE E. BARTLETT :CIVIL ACTION LAW JOHN D. BARTLETT :No. CML__ CARRIE E. BARTLETT :VERIFIED COMPLAINT IN CUSTODY 1. The plaintiffis VANESSA ANN T~SSONE residing at 20 Cedar Wood Driv~i Waltham, MA. 2. The defendant is DAVID P. BARTLETT, IR. residing at 206 A. Marshall Road Carlisle Barracks, Carlisle, PA 17013. 3. Plaintiff seeks temPorary custody of the following children: ANNE E. BARTLETT, age 3, residing at 206 A. Marshall Road, Carlisle Barracks, Carlisle, PA 17013, JOHN D. BARTLETT, age 5, residing at 206 A. Marshall Road, Carlisle Barracks, Carlisle, PA 17013, CARRIE E. BARTLETT, age 8, residing at 206 A. Marshall Road, Carlisle Barracks, Carlisle, PA 17013. The children were not bom out of wedlock. The children presently are in the custody of their father, DAVID P. BARTLETT, JR. who resides at the above the referenced address. The mother of the children, SUZANNE T. BARTLETT, is deceased. She was married to DAVID P. BARTLETT, JR. until the time of death which concurred on or about 20 March 2002. 4. The plaintiff, VANESSA ANN TflSSONE is the sister of the decedent, SUZANNE T. BARTLETT, and is the aunt of the children in paragraph three referenced above. 5. The defendant, DAVID P. BARTLETT, JR., is the biological father of the children referenced in paragraph three above. 6. The plaintiff has not participated as a party or witness or in any other capacity in any other litigation concerning the custody of the minor children in this or any other court. 7. The best interest and permanent welfare of th9 children will be served by granting temporary custody to the plaintiff, VAI~SSA'ANNE TESSONE. 8. The plaintiff and defendant have signed a consent order which is hereto attached and incorporated hereto by reference as if part of the complaint. WHEREFORE, the plaintiffrequests this court to grant temporary custody of the children to the plaintiff; A. The parties have consented to temporary custody being granted. B. The consent order is hereto attached and is incorporated as part of this complaint. WHEREFORE, the plaintiff further demands any other such relief as the court may deem equitable and just. DATE/~,~c9/~ 5',a c/?Oc~ PETER A. GARCIA, Esquire Attorney at Law State of Pennsylvania Pro Bono Counsel for the Plaintiff I verify that the statements made in this'complhiht are true and correct. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unswom falsification to authorities. Plaintiff IN THE COURT OF COMMON PLEAS OF THE 39t~ JUDICIAL DISTRICT OF PENNSYLVANIA CUMBERLAND COUNTY BRANCH Vanessa A. Tassone, VS. David P. Bartlett, Jr., ) Plaintiff, ) ) ) ) ) Defendant, ) Civil Action - Law Uo.F.P..# 1 /3tO Custody ORDER OF COURT NOW,_ '~ ~a_~_~ ,, {_! ~ , 2002, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: 1. Vanessa A. Tassone ("Vanessa") shall have legal and physical custody of Caroline E. Bartlett, born December 17, 1993, John D. Bartlett, born July 6, 1996, and Anne E. Bartlett, born September 29, 1998 (hereinafter "the children"). 2. David P. Bartlett, Jr. ("David") shall have partial physical custody of the children as Vanessa and David may from time to time mutually agree. ~ 3. The costs of this proceeding have been paid by Vanessa. By t~e Court