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Home My WebLink About06-3788 . , .'--- TREV A D. CAIRO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. . . j : NO. 2006- 37([ ~ WARREN E. CAIRO, Defendant : CIVIL ACTION - LAW : IN CUSTODY NOTICE 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 For Custody and Notice are served, by entering a written appearance personally or by attorney and filing in writing with a court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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 Street Carlisle, Pennsylvania 17013-3302 (717) 249-3166 SNELBAKER & BRENNEMAN, P. C. By: lht~ Attorneys for Plaintiff LAW OFFlCES SNELBAKER & BRENNEMAN, P.C, . . d LAW OFFICES SNELBAKER & BRENNEMAN. P .C. TREV A D. CAIRO, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006- 3 7 V f ~ TLv<- Plaintiff v. WARREN E. CAIRO, Defendant CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY PlaintiffTreva D. Cairo, by her attorneys, Snelbaker & Brenneman, P. C., hereby avers the following: I. Plaintiff is Treva D. Cairo, an adult individual residing at 303 Walnut Lane, Carlisle, Pennsylvania, 17013. 2. Defendant is Warren E. Cairo, an adult individual residing at 14 Bellview Road, Marysville, Pennsylvania, 17053. 3. Plaintiff seeks custody of the following children: NAME PRESENT RESIDENCE AGE Heather K. Cairo 303 Walnut Lane, Carlisle, PA II (D.O.B. 1/19/95) Warren E. Cairo, Jr. 303 Walnut Lane, Carlisle, PA 7 (D.O.B. 10/12/98) The children named above named were not born out of wedlock. The children named above are presently in the custody of Plaintiff at her residence as indicated in Paragraph 1, above. During the last five (5) years, the children subject to this custody action resided with , . , 'A the following persons and at the following addresses: PERSONS ADDRESSES DATES Treva and Warran Cairo 6280 Carlisle Pike Mechanicsburg, P A Birth to 01/2002 Treva, Brian Hiltz and Bates Family 686 Cumberland Point Cir. Mechanicsburg, P A 01/2002 to 02/2002 Treva and Brian Hiltz 301 Cherry Street Hummelstown, P A 02/2002 to 12/2002 Treva, Brian Hiltz, Rocky and Marie Yeingst 3400 Carlisle Spring Rd. Carlisle, P A 01/2003 to 01/2003 Treva, Brian, Brianna and Lakota Hiltz 303 Walnut Lane Mechanicsburg, P A 01/2003 to present The mother of the children is Plaintiff Treva D. Cairo, who is currently residing at the address indicated in Paragraph I, above. She is married. The father of the children is Defendant Warren E. Cairo, who is currently residing at the address indicated in Paragraph 2, above. He is married. 4. The relationship of Plaintiff to the children is that of mother. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP Heather K. Cairo Warren E. Cairo, Jr. Brian Hiltz Brianna Hiltz Lakota Hiltz daughter son boyfriend daughter of boyfriend son of boyfriend LAW OFFICES SNELBAKER 8: BRENNEMAN. P.C. -2- .' . 5. The relationship of Defendant to the children is that of father. The Defendant currently resides with the following persons: NAME RELATIONSHIP Patsy Marra Joey Marra Justin Marra girlfriend son of girlfriend son of girlfriend 6. Plaintiff has not participated as a party in other litigation that involved custody of the parties' children. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to these 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 children will be served by granting the relief requested because Plaintiff has been the primary caretaker and has had primary physical custody of the children since their birth. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody ofthe children have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene: None. WHEREFORE, Plaintiff Treva D. Cairo requests this Court to grant Plaintiff primary LAW OFFICES SNELBAKER & BRENNEMAN, P.C. -3- .' . LAW OFFICES SNEL8AKER & BRENNEMAN, P .C. physical custody of the parties' children. Date: July 3, 2006 SNELBAKER & BRENNEMAN, P. C. I~ By: Keith O. Brenneman, Esquire 44 West Main Street Mechanicsburg, P A 17055 (717) 697-8528 Attorneys for Plaintiff Treva D. Cairo -4- . . , . LAW OFFICES SNELBAKER & BRENNEMAN, P .C. VERIFICATION I verify that the statements made in the foregoing Custody Complaint 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 unsworn falsification to authorities. .Jr" Ilk ~ '2 t111 C. Date: - l "l ~JJ~ ~ !-', R ~ ' _~J CJ ex" '"n \-.. :::;:1 c:: ....... i~'" hi ~ k1 , -'-I ~ (.,.) ~. " ~ t'" - --..., - r<, .n y j",,: -< ~ L ..., TREV A D. CAIRO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2006- 378~ WARREN E. CAIRO, Defendant : CIVIL ACTION - LAW : IN CUSTODY MOTION TO APPROVE AGREEMENT FOR CUSTODY Plaintiff Treva D. Cairo by her attorneys, Snelbaker & Brenneman, P. C., submits this Motion and in support thereof states the following: 1. Plaintiff in this action is Treva D. Cairo, an adult individual residing at 303 Walnut Lane, Carlisle, Pennsylvania 17013. 2. Defendant in this action is Warren E. Cairo, an adult individual residing at 14 Bellview Road, Marysville, Pennsylvania 17053. 3. The parties are the natural parents of Heather K. Cairo, age 11 and Warren E. Cairo, Jr., age 7. 4. The parties have reached an Agreement For Custody, the original of which is attached hereto and incorporated by reference herein as "Exhibit A". 5. Pursuant to the parties' Agreement For Custody, the parties agree that the Agreement shall become part of and incorporated into an Order of Court. WHEREFORE, Plaintiff Treva D. Cairo requests this Court to issue an Order approving the Agreement For Custody and incorporating same into the Order of Court. SNELBAKER & BRENNEMAN, P. C. LAW OFFICES SNELBAKER & BRENNEMAN. P.C. ~ Date: July 3, 2006 BY: Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, P A 17055 (717) 697-8528 Attorneys for Plaintiff Treva D. Cairo '4 .. . . . . IJ,W OFFICES SNELBAKER & BRENNEMAN, P,C. TREV A D. CAIRO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2005- WARREN E. CAIRO, Defendant CIVIL ACTION - LAW IN CUSTODY AGREEMENT FOR CUSTODY THIS AGREEMENT is made and entered into between Treva D. Cairo (hereinafter 'Mother")::md W=en E. Cairo (hereinafter "Father"). WHEREAS, Treva D. Cairo and Warren E. Cairo are the natural parents of Heather K. airo, bomJanuary 19,1995 and WarrenE. Cairo, Jr., born October 12.1998; WHEREAS, Father and Mother desire to make arrangements for the custody of their two hildren and have reached an agreement with respect to the custody arrangement for their two 'hildren. It is therefore agreed between the Father and Mother as follows: 1. Father and Mother shall have shared legal custody of Heather K. Cairo and Warren E. airo, Jr. Each parent shall have an equal right, to be exercised jointly with thc other parent, to ake all major non-emergency decisions affecting the children's general well-being, including, ut not limited to, all decisions regarding their health, education and religion. 2. Mother shall have primary physical custody of Heather K. Cairo and Warren E. airo, Jr. 3. Father shall have custody of Heather K. Cairo and Warren E. Cairo, Jr. every weekend omrnencing at 6:00 p.m. on Friday to Sunday at 8:00 p.m. EXEIBIT A "c. . . LAW OFFICES SNELBAKER 8: BRENNEMAN, P,C. 4. Father shall have such other periods of physical custody ofthe children as the parties hall mutually agree. 5. The parties may modify the provisions of this Agreement with respect to the physical ustody of their two children by mutual consent; however, in the absence of mutual consent, the erms of this Agreement shall control. 6. The parties agree that this Agreement and the custody arrangement specified for their hildren in this Agreement shall become part of or incorporated in an Order of Court. IN WITNESS WHEREOF, :nte!lding to be leg31ly bOllnv hef..by, the p"rties have signed his Agreement on the date set forth below beneath their signatures. ITNESS: d.~ourl B C.<) 1s;J Tre a D. Cairo Date: '6 -1."/ -0'5 (SEAL) Ubtc{;tJ (SEAL) Date: ~. 1., - oS -2- . .- LAW OFFICES SNELBAKER & BRENNEMAN, P.C. CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Motion to be served upon the person and in the manner indicated below: FIRST CLASS MAIL. POSTAGE PREPAID. ADDRESSED AS FOLLOWS: Warren E. Cairo 14 Bellview Road Marysville, P A 17053 ,/~ Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 W. Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Treva D. Cairo Date: July 3, 2006 "'" (~, c~ \ 0) ......,.~, -.- r<' ./ C', .".... LAW OFFICES SNELBAKER Be BRENNEMAN, P.C. I).- RECEIVED JUl 05 Z006v' () TREV A D. CAIRO, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006- 37~8 Plaintiff v. WARREN E. CAIRO, Defendant CNIL ACTION - LAW IN CUSTODY ORDER AND NOW, this 17ft, , 2006 upon consideration of ~JI day of the Motion To Approve Agreement For Custody and the parties' Agreement For Custody, the Agreement For Custody attached to the foregoing Motion as "Exhibit A" is hereby APPROVED and said Agreement For Custody is incorporated by reference into this Order. BY THE COURT: J. ,." ,- b:,: ':.J ..~:-' - -.,. '"- '-~- a L- :=. ~ <-") ,_.-:;-). 2.~:~; ~" ~i ~t 'P~t - ,tJ