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Home My WebLink About94-03923 . o - ~ .~ ~ u !~l 10- \('() , I 1:r cr . * II if\al\ I (u~( I'i-I/o Pla.tntUf 'IN THB COURT OF CONNON PLEAS OF ,CUMBBRLAND COUN'1'Y, PENNSYLVANIA , ,CIVIL AC'1'ION - LAW :NO. eN ~r/;;~ CIVIL ,CUSTODY/VISITA'1'ION 19 V ,5"'05",\ (( (l>,~/,( II" Defendant * ORDER or COOK'!' :T.. 1'1 ? ') /Cr AND NOW, th.ts (date)" I /II , upon consideration of the attached complaint, it is hereby directed ha~. the artieB and . their respective counB~l ap ear before ,fiLlJJrf . I rh t ~ , the conciliatof' at 1/ . (1 (..,'~. " ,ll ,,,,,,,s, on the .1;).(\( day of ' . I" ,19 I, at -J?t' ,'1/ M., for a Prehearing Custo y Conference. At such con erence, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the .tssuss 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 prov.tde grounds for entry of a temporary or permanent order. FOR '1'IIE COUR'1' , By' YOU SHOULD 'lAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONB, GO TO OR TELEPHONB THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, FOURTH FLOOR CARLISLE PA 17013 (717)240-6200 . . ':)... 0-. 'f~ ~ \' f~ .M 11 2 57 PH '9~ 1 't I "' i OIlier ", lIll, i; IIlOHOt~~r CU14ii1htNO CPlNn f'(lih~rtVA~IA J '~ "" ~ ~ ~ ~\1;: ~ .. .. -.-f""':: , , ., l.. l'- ' , t-. . Cl l; ~, I'j ... .~ J ! 'j ~ . , , , u. ik ~ ~ ;r~ i l!lGll ; ~ ~ . ~ . ~~~~J ~I II ~~~~ p: ~!~Od f? :i rd; !I~ ~~ . I l> ~ ! ~ t.! ~ ~ ~~ i . .. . .. . t~. . .. . . . 1111'.\ I'll I, '...'01','.1 II .\' ~I i1,.:." 1',(', . . J U L 1 5 mg. I I ~. VINCENT CANDIELLO, ) IN THE COURT OF COMMON PLEAS OF Plaintiff ) CUMBERLAND COUNTY, PENNSYLVANIA ) 'f,', II, v. ) NO. 1/ ~}J j CIVIL t:NM ) SUSAN K. CANDIELJ.(> , ) CIVIL ACTION - LAW Defendant ) CUSTODY ORDER OF COURT You, Susan K. Candiello, Defendant, have been sued in court to obtain shared custody of the childrenl Robert Vincent Candiello, Catherine Celeste Candiello, Noele Marie candiello and Michael Seth Candiel10. You are ordered to appear in person before c; (1I'lllI Ii IJ,J \ t't: 1:)11\ ') 1 1'//" day of ( I 1,1< ,I' II , <,;/ '/r",/;" at ')J ') . ,\I C~liJlR, Pennsylvania, on the 1994, at -~ 0Ic10ck...L:.-.M., for a Pre-Hearing custody , , Conference. At such conference,\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. If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. YOU SHOULD TAKE TillS 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 HSLP. CUMBERLAND COUNTY LAWYER REFERRAL SERVIcE cumberland' County Courthouse . Court Administrator 1 Courthouse Square Carlisle, Pennsylvania 17013 (717) 240-6200 FOR TilE COURT: Date of Order: 7 III 'il/ ~f ,(;); )/ VINCENT CANDIELLO, Plaintiff ) IN THE COURT OF COMMON PLEAS OF ) CUMDERLAND COUNTY, PENNSYLVANIA ) ) NO. ~V. ,,'?.J / CIVIL ~ 7;"... ) ) CIVIL ACTION - LAW ) CUSTODY v. SUSAN K. CANDIELLO, Defendant COMPLAINT FOR SHARED CUSTODY Plaintiff vincent candiello, by and through his counsel, Howett, Kissinger & Miles, P.C., hereby files this Complaint for Shared custody against Defendant, Susan K. Candiello, and in support thereof, reepectfully avers the followingl 1. plaintiff is Vincent Candiello (hereinafter "Father"), who currently resides at 14 Draper circle, Lititz, I,ancaeter County, Pennsylvania, 17543. 2. Defendant is Susan K. candiello (hereinafter "Mother"), who currently res idee at 312 East Meadow Drive, Mechanicsburg, Cumberland county, Pennsylvania, 17055. 3. Father seeks shared legal and physical custody of the following minor childrenl Names Present Addrees Date of Birth Robert Vincent candiello 312 East Meadow Dr. 4/29/78 Mech., PA 17055 catherine Celeste Candiello 312 East Meadow Dr. 12/19/80 Mech., PA 17055 Noele Marie candiello 312 East Meadow Dr. 1/7/85 Mech., PA 17055 Michael Seth Candiello 312 East Meadow Dr. 3/2/88 Mech., PA 17055 The children were not born out of wedlock. The children are presently in the custody of Mother who currently resides at 312 East Meadow Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. During the past five years, the children have resided with the following persons and at the following addresses: Persons Addresses Dates Mother and Father 312 East Meadow Dr. Mech., PA 17055 May 1988 to September 1991 September 1991 to the present Mother 312 East Meadow Dr. Mech., PA 17055 The mother of the children is Susan K. Candiello, who currently resides at 312 East Meadow Drive, Mechanicsburg, cumberland County, Pennsylvania, 17055. She is married. The father of the children is Vincent Candiello, who currently resides at 14 Draper Circle, Lititz, Lancaster county, Pennsylvania, 17543. He is married. 4. The relationship of the Plaintiff to the children is that of natural father. The Plaintiff currently resides with the following person: Names Relationship Fiance' Roseann Er.b 5. The relationship of Defendant to the children is that of natural mother. The Defendant currently resides with the following persons: 2 ~ Robert Vincent Candiello catherine Celeste candiello Noele Marie candiello Michael Seth Candiello RelationshiD son Daughter Daughter Son 6. Father 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. Father has no information of a custody proceeding concerning the children pending in a court of this commonwealth. Father 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 interests and permanent welfare of the children will be served by granting the relief requested because: (a) Father is able to provide a loving environment for the children and has done so throughout their lives: (b) Father is able to provide proper care and supervision for the children: (c) The parties' current informal custody arrangement does not fix a specific custody schedule and Father and Mother at times are not able to mutually agree upon flexible custodial arrangements I 3 (d) It is in the children's best interest to have regular accoss to both parents and to spend as much time as possible with both parents, and (e) It is in the best interests of the children to have a meaningful, ongoing relationship with their natural father. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff Vincent candiello, respectfully requests that this Honorable Court enter an Order: (a) Awarding the parties shared legal custody of the four minor children, (b) Awarding the parties ahared physical custody of the children and naming Mother as primary physical custodian of the children, subject to Father's rights of partial physical custody according to the following schedule: (1) Every other weekend from Friday at 5100 p.m. until Sunday at 8100 p.m., (2) On the Wednesday following the weekend specified in (1) above from 6:00 p.m. until 8100 p.m. (3) For two weeks during the children's summer vacation from school, consecutive or non-consecutive at Father's discretion, (4) Every Father's Day from 10100 a.m. until 8:00 p.m., 4 (4) On Father's birthday from 10100 a.m. until 8100 p.m., (5) On the children's birthdays in alternating years, (6) Every Thanksgiving from 10100 a.m. until 8100 p.m., (7) On Christmas Eve (December 24) from 10:00 a.m. until 9100 p.m. in 1994 and in each even-numbered year thereafter: (8) On Christmas Day from 10100 a.m. until 8100 p.m. in 1995 and in each odd-numbered year thereafter, and (9) At other times as the parties shall from time to time agree. Respectfully submitted, Datel ~ /J1 /1~ I . J . Howett, Jr., Esqu re HOWETT, KISSINGER' MILES, P.C. 130 Walnut street P.O. Box 810 Harrisburg, PA 17108 Telephone: 717/234-2616 Counsel for plaintiff vincent candiello 5 VERIFICATION I, VINCENT CANDIELLO, hereby SWear and affirm that the facts contained in the foregoing COMPLAINT FOR SHARED CU8TODY are true and oorreot to the best of my knowledge, information and belief and are made sUbject to the penalties of 18 Pa.C.S. 84904 relating to unsworn falsifioation to authorities. / " / / .- J / /,,' .JJ/1. ? 1.3 '/ f / ~t (ee( [:1 (!ilu~~(JfI / / VINCENT CANOIELLO Date: SEP 23 199. de, v 'IN THB COURT OF COMMON PLEAS OF ,CUMBBRLAND COUNTY, PBNNSYLVANIA I INO. 3923 - CIVIL - 1994 I I ICIVIL ACTION - CUSTODY VINCBNT CANDIBLLO, PlaintUf SUSAN K. CANDIBLLO, Defendant COURT ORDBR AND NOW, this 2J...J day of ~ -t , 1994, the Conciliator being advised'tiiat the partl{; have reached an agreement, the Conciliator relinquishes jurisdiction. a6 . , "q SEr ZG I 26 lltl t9~ '.l"\I'i :".ll [lilY ! 'Pi .!',;. 'in ff ~'. 'L",