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HomeMy WebLinkAbout02-3566CABOT L. RESUTA PLAINTIFF MICHELE L. RESUTA DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 02-3566 CIVIL ACTION LAW : : IN CUSTODY ORDER OF COURT AND NOW, Thursday, August 01, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Es~l. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, August 15, 2002 at 10:30 AM 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. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilrov. Esa. ~" Custody Conciliator ' l;' The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available 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. YOU SHOULD TAKE THIS PAPER TO YOUR AWFORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 CABOT L. RESUTA, Plaintiff VS. MICHELE L. RESUTA, Defendant iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAN CIVIL ACTION - LAW NO. 2002- ~,.~'~,(., CIViL ACTION IN CUSTODY SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA COMPLAINT FOR CUSTODY 1. The Plaintiff is Cabot L. Resuta, residing at 218 North 2 Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is Michele L. Resuta, residing at 423 E~ New Cumberland, Cumberland County, Pennsylvania 17070. ' '- 3. The Plaintiff seeks custody of the following children, Cameron Resuta, born March 27, 1995, and Noah Resuta, born May 2, 1999, who resides at 423 Eutaw Avenue, New Cumberland, Pennsylvania 17070. The children were not born out of wedlock. The children are presently in the custody of Defendant, Michele L. Resuta, who resides at 423 Eutaw Avenue, New Cumberland, Pennsylvania 17070 During the past five years, the children have resided with the following persons and at the following addresses: NAME Cabot L. Resuta and Michele L. Resuta Michele L. Resuta Constance Williams (maternal grandmother) ADDRESS 218 North 27th Street Camp Hill, PA 423 Eutaw Avenue New Cumberland, PA FROM/TO March 95 July 21, 2002 July 21, 2002 present The mother of the children is Michele L. Resuta, currently residing at 423 Eutaw SAIDIs ~lq=, I%01aW. R ~, LINDSA¥ S ~ ~ Street Carlisle, PA Avenue, New Cumberland, Pennsylvania. She is married. The father of the children is Cabot L. Resuta, currently residing at 218 North 27th Street, Camp Hill, Pennsylvania. He is married. 4. The relationship of the Plaintiff to the children is that of father. The Plaintiff currently resides by himself. 5. The relationship of the Defendant to the children is that of mother. The Defendant currently resides with the following person(s): the children, Cameron and Noah Resuta, and her mother, Constance Williams. 6. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation concerning the custody of the children in this or another jurisdiction. 7. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of the Commonwealth. 8. The 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. 9. The best interest and permanent welfare of the children will be served by granting the relief requested because: a) The Plaintiff can best provide for the physical and emotional needs of children. 10. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, the Plaintiff requests this Court to grant primary physical custody of the children to the Plaintiff. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff BY:~i ~4j~ ~ J ndsay, E~ 2b-~A/e~ High Street Carlisle, PA 17013 (717) 243-6222 SA/DIS g~ LINDSAY W. High Street Carlisle, PA VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. Date: °'-~_~, 4z_ ' SAIDIS UFF, FLOWE~ ~ LINDSAY W. High Street Carlisle, PA