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'MR 1 1994),1>
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CHARLES E. PETRIE
3528 BR1SBAN STREET
HARRISBURG. PENNSYLVANIA 17111
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: IN THE COURT OF COMMON PLEAS OF
:CUHBERLAND COUNTY, PENNSYLVANIA
O;c>c[e.~ainti.ff'
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:CIVIL ACTION - LAW
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* :NO. Qs7 CIVIL
1Irr\ hmV D.' oc~'k> Defendant :CUS'l'ODY /VISI-TATION
ORDER OF COURT
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AND NOW, th~s (oate) . " upon cons~derat~on of the
attached complaint, it is hereby directed hat the parties and
their respective counsel appear before '^ rt- I"o~'
the conciliator, at l. r r 1-........,."
on the I ~1h 'day of , , 19"11( , at q /"J( i1 .0 tv}
M.,~ehearing Cus oC/y Conference. At such conference,' J
an effort will be made to resolve the issues in dispute; or if
this cannot be accomplished, to define and narrow the issues to be
heard 'by the court, and to enter into a temporary order. Either
party may bring the child who is the subject of this custody
action to the conference, but the child/children's attendance is
not mandatory. Failure to appear at the conference may provide
grounds for entry of a temporary or permanent order.
19 Cjl/
FOR THE COURT:
By: --:2'/ ~-<7!;. ~~'~--'-A-Csr,
~;g;;;Jy conc1ir:fo~7 ~
YOU SHOULD TAKE THIS PAPER '1'0 YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO 'l'O OR TELEPHONE THE OFFICE
SET FORTH BELOW 'l'O FIND OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRA'l'OR
COURTHOUSE, FOURTH FLOOR
CARLISLE PA 17013
(717)240-6200
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SHANNA L. DIODATO,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs.
NUMBER
9.!r1 ~ /'19y
ANTHONY DIODATO,
Defendant
IN CUSTODY
COMPLAINT FOR CUSTODY
NOW COMES the Plaintiff, SHANNA L. DIODATO, by her attorney,
Charles E. Petrie, and respectfully represents as follows:
1. Plaintiff is SHANNA L. DIODATO, who currently resides at
210 Seventh Street, New Cumberland, County of Cumberland,
Pennsylvania.
2. Defendant is ANTHONY DIODATO, who currently resides at
821 Pear Street, Apartment C, Lemoyne, County of Cumberland,
Pennsylvania.
3. Plaintiff seeks to have custody of ZACHARY ALAN DIODATO,
born December 22, 1992.
The child was not born out of wedlock.
The child is presently in the custody of Plaintiff, SHANNA L.
DIODATO.
Since birth, the child has resided with the following persons
and at the following addresses, From December, 1992, until April,
1993, with Plaintiff and Defendant on Market Street in Camp Hill,
Pennsylvania; from April, 1993, until July 6, 1993, with Plaintiff
and Defendant in GOldsboro, Pennsylvania; from July 6, 1993, with
Plaintiff at 210 Seventh Street, New Cumberland, Pennsylvania.
The mother of the child is SHANNA L. DIODATO, who currently
resides at 210 Seventh street, New Cumberland, Pennsylvania. She
is not married.
The father of the child is ANTHONY DIODATO, who currently
resides at 821 Pear Street, Apartment C, Lemoyne, Pennsylvania.
He is not married.
4. The relationship of the Plaintiff to the child is that of
mother. The Plaintiff currently resides with the child and with
Plaintiff's parents, Harry and Glenda Houser.
5. The relationship of the Defendant to the child is that of
father. He currently resides with his girlfriend, Christine
Koons, and their l-year-old son, Nathan.
6. The 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 in another court.
The Plaintiff has no information of a custody proceeding
concerning the child 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 child or who claims to
have custody or visitation rights with respect to the child.
7. The best interest and permanent welfare of the child will
be served by confirming in Plaintiff custody of the child because
Plaintiff can better care for the child and provide a suitable
environment for the child.
8. Each parent whose parental rights to the child have not
been terminated and the person who has physical custody of the
child have been named as parties to this action.
WHEREFORE, Plaintiff requests the Court to grant to Plaintiff
custody of the child.
Respectfully sUbmitted,
;"'~r~
CHARLES E. PETRIE
3529 Brisban Street
Harrisburg, PA 17111
(717) 561-1939
Attorney for Plaintiff
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
I verify that the statements in the foreyoiny Complaint are
true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. D4904, relating to
unsworn falsification to authorities.
, iJ.\.IL ~ Ij . I OQ l/
D TE I
via..cw.d ,nioo<tL~
SHANNA L. DIODATO