HomeMy WebLinkAbout02-4361
SEP 1 2 2062
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
JOSEPH J. SAS~,
Petitioner
:
V.
:
Docket No. (J~-Y3lR J
Civ; 1
:
:
:
JAMI N. _~_A,~~=-~ILL~~,
:
CIVIL ACTIO~ - LAW
VIS11')\'rrO~
Respondent
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow Pro Se Petitioner Joseph J. Sasa, to proceed
in Forma Pauperis.
Petitioner is unable to pay the costs. His affidavit showing
the inability to pay the cost of litigation is attached hereto.
i I
, \
,/ l<'.. jL_
lo~h ~. ~~sa:-~;~;;;~
SCI Coal Township
1 Kelley Drive
Coal Township, Pa. 17866
Pro Se Petitioner
dated: SEPTEMBE~ 10, ~vv~
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
JOSEPH J. SASA,
PETITIONER
:
:
Docket No.
Qd.,lJ3&/
Ciu; )
:
:
:
V.
:
:
:
CIVIL ACTION - LAW
VISITATION
JAMI N. SASA-MILLER,
RESPONDENT
:
AFFIDAVIT
I am the Petitioner in the above matter and because of my financial
=ndition, am unable to pay the fees and costa of prosecuting the action.
I am unable to obtain funds from anywne, including my family and
associates, to pay the cost of litigation.
I represent that the information below relating to my ability to pay
the fees and costs is true and correct:
(a) Name: Joseph J. Sasa
Address: state Correctional Institution @ Coal Township
1 Kelley Drive
Coal Township, pennsylvania 17866-1021
Social security Number: 174 - 70 - 1479
(b) Employment:
Employer: None-petitioner is incarcerated
i1ddress: n/ a
Salary or wages per month: n/a
Type of Work: n/a
(c) Other income within the past twelve months: n/a
Business or profession: n/a
Other self-employment: n/a
Interest: n/a
-!".)c
Dividems: n/a
Pension and annuties: nl a
Support payments: n/ a
Disability payments: n/a
Unemployment compensation and supplemental benefits: n/a
Workman's compensation: nla
Public assistance: n/a
Other: n/a
(d) Other =ntributions to household support: n/a
Spouse Name: Jami n. Sasa-Miller
Contributions fran parentslfamily: none
Other =ntributions: none
(e) Property owned: none
(f) Debts and obligations: n/a
(g) Persons dependent upon you for financial support: n/ a
I understand that I l:1ave a continuing obligation to inform the court of
improvement in my financial circumstances which would permit me to pay the costs
incu=ed herein.
I verify that the statements made in this affidavit are true and correst. I
understand that false statements herein are made subject to the penalties of
18 Pa.C.S. <; 4904, relating to unsworn falsification to authorities.
'\
I
1 I
i)' '
MI )J-
rlasa
'\ i~L
Jose!ph ,J.
Petitioner
Dated: September 10, 2002
JOSEPH J. SASA,
Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
JAMI N. SASA-MILLER,
Respondent
02-4361 CIVIL
AND NOW, this
ORDER OF COURT
(~
day of September, 2002, the motion for
plaintiff to proceed in forma pauperis, IS GRANTED. Plaintiff need not pay the filing fee
or any service fee. The complaint is referred to conciliation.
Joseph J. Sasa, CF-1778
SCI Coal Township
1 Kelley Drive
Coal Township, PA 17866
Jami N. Sasa-Miller
2561 Valley Road
Marysville, PA 17053
~~y:.o~
:prs
"
'/
';/;: ;'.l\i'r~i.\S:\:N 3d
;\_U-,;(-':C~C: '''J~ ":I,'\n8
):, :1]\
.
t.
d3S ;~D
II".
i\C
-,
JOSEPH J. SASA
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
02-4361 CIVIL ACTION LAW
JAM! N. SASA-MILLER
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, Wednesday, September 25, 2002 , upon consideration ofthe attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, P A 17055 on Wednesday, October 16, 2002 at 8:30 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 hearin2.
FOR THE COURT,
By: Isl
Dawn S. Sunday, Esq.
Custody Conciliator
~(/
~
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 ATTORNEY 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
f;v"~r~ ~ ~/ -eo-ce.!;
-~~~~ ~ ~ n -eo-l.el;
VlNVAlASNN3d
AlNnoo 01\Jlfl8:;8~no
c'J:8 Wd Ll d3S 20
AlNlONOi-..L(i:,c. ;~:JO
3JI::l:IO-<lJijl
JOSEPH J. SASA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
02-4361
CNIL ACTION LAW
JAMI MILLER,
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this '-1t day of ~ ' 2002,
upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
I. The Mother shall have primary physical and legal custody of Taylor R. Sasa, born March
16,2001.
2. The Father shall have a period of supervised visitation with the Child every two months in
the visitation facility at the prison where the Father is currently incarcerated. The Mother shall
promptly notify the Father by mail of the date and time for the first visit, which shall be scheduled to
take place within 2 weeks ofthe date of the Custody Conciliation Conference.
3. The Father shall forward sufficient payment to the Mother in advance of each visit to pay
for the cost of gas for transportation of the child to the facility in Shamokin, Pennsylvania.
4. In the event the Father forwards payment to the Mother to cover the costs of opening a post
office box to enable the Father to correspond with the Child, the Mother shall cooperate in setting up
the post office box for the Father's use.
5. The Mother shall accept telephone calls from the Father to the Child which are made at the
Father's expense.
6. Neither party shall do or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natural development of
the Child's love and respect for the other parent. Both parties shall ensure that third parties having
contact with the Child comply with this provision.
7. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation
Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
(
Edgar B. Bayley,
J.
cc: Joseph J. Sasa, Father
John Hyams, Esquire - Counsel for Mother
~
,~ //-ot{-62--
q~.
'7/lr,~\f/\lJ ~,S\: I {~d
~ !" I""" r-, (...
Ai.!\: I .
nn"
.1 'V
. l.' .-)
L.V'r.,
....) "'f'
,- LU" G.)
JOSEPH J. SASA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
02-4361
CIVIL ACTION LAW
JAMI N. MILLER,
Defendant
IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Taylor R. Sasa
March 16,2001
Mother
2. A Conciliation Conference was held on October 16, 2002, with the following individuals in
attendance: The Mother, Jami N. Miller, with her counsel, John M. Hyams, Esquire. The Father,
Joseph J. Sasa, who is currently incarcerated at the state prison in Shamokin, Pennsylvania,
participated in the Conference by telephone.
{)e:I-v ~ ~?I ~'~.J-
Date
3. The parties agreed to entry of an Order in the form as attached.
~,.J/I.
Dawn S. Sunday, Esquir7
Custody Conciliator
JOSEPH J. SASA,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: 02-4361 CIVIL ACTION - LAW
JAMI N. MILLER,
Defendant
: IN CUSTODY
PI ,A INTIFF'S PF,T1TION TO MonlFV C'ITSTOnV
AND NOW, the Plaintiff, Joseph J. Sasa, by and through his attorney, Jeanne B.
Costopoulos, Esquire, avers the following in support of this Petition:
1. Petitioner, Plaintiff above, is Joseph J. Sasa (hereinafter referred to as Father), an adult
individual currently residing at 6 Marshall Drive, Apt. J-13, Camp Hill, Cumberland
County, Pennsylvania, 17011.
2. Respondent, Defendant above, is Jami N. Hiner, fonnerly Jami N. Miller, an adult
individual currently residing at 4220 Locust Lane, Harrisburg, Dauphin County,
Pennsylvania, 17053.
3. The parties are the natural parents of one daughter, namely Taylor R. Sasa, born March
16,2001.
4. Following an agreement between the parties regarding custody of the child reached at a
Conciliation Conference held before Dawn S. Slmday, Esquire, an Order of Court was
entered by the Honorable Edgar B. Bayley on November 4, 2002 (Exhibit A).
5. The November 4, 2002 Order was entered at a time when Father was incarcerated. He
is now released from jail and would like to begin a phase-in custody schedule designed
to reacquaint him with his daughter at a pace which takes into consideration of her
comfort level.
current Order of Court such that he is granted partial physical custody of his daughter on a routine
basis.
Dated:
r;; ;(;5
-
e B. Costopoulos, Esquire
A ITORNEY FOR PLAINTIFF
5000 Ritter Road, Suit,: 202
Mechanicsburg, PA 17055
Phone: (717) 790-9546
P A Supreme Ct. ill No. 68735
JOSEPH J. SASA,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: 02-4361 CIVIL ACTION - LAW
JAMIN. MILLER,
Defendant
IN CUSTODY
VF.RTFTCATION
I, Joseph J. Sasa, hereby verifY that the statements made in the foregoing petition are true
and correct to the best of my knowledge, information, and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn
falsification to authorities.
Date:
R\~\ \c}oos
/J
(! J II
Signature: \L",-,) I l
JOSfJ'H J. SASA
JOSEPH 1. SASA,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: 02-4361 CIVIL ACTION - LAW
JAMI N. MILLER,
Defendant
: IN CUSTODY
CRRTTFTCATF, OF SRR'acE
I, Jeanne B. Costopoulos, Esquire, hereby certifY that this day I served a copy of the
foregoing petition upon the person, and in the manner, indicated below, which service satisfies the
requirements of the P A Rules of Civil Procedure, by depositing a copy of the same with the United
States Post Office at Mechanicsburg, Pennsylvania, through first class mail, prepaid, and addressed
as follows:
Jami Hiner
4220 Locust Lane
Harrisburg, P A 17053
BY:
~ ----
~e B. Costopoulos, Esquire
ATTORNEY FOR PLAINTIFF
5000 Ritter Road, Suite 202
Mechanicsburg, P A 17055
Phone: (717) 790-9546
P A Supreme Ct, ID No. 68735
Dated:
fJ;;5
.
JOSEPH J. SASA,
Plaintiff
'IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
02-4361
CIVIL ACTION LAW
JAM! MILLER,
Defendant
IN CUSTODY
ORDER OF comq
AND NOW, this tj. day of ~. ltU~J.'{~ ' 2002,
upon consideration of the attached Custody Conciliation Report,. it is ordered .and directed as follows:
1. The Mother shall have primary physical and legal custody of Taylor R. Sasa, born March
16,2001.
2. The Father shall have a period of supervised visitation with the Child every two months in
the visitation facility at the prison where the Father is cUlTently incarcerated. The Mother shall
promptly notify the Father by mail of the date and time for the first visit, which shall be scheduled to
take place within 2 weeks of the date of the Custody Conciliation Conference.
3. The Father shall forward sufficient payment to the: Mother in advance of each visit to pay
for the cost of gas for transportation of the child to the facility in Shamokin, Pennsylvania.
4. In the event the Father forwards payment to the Mother to cover the costs of opening a post
office box to enable the Father to correspond with the Child, the Mother shall cooperate in setting up
the post office box for the Father's use.
5. The Mother shall accept telephone calls from the Father to the Child which are made at the
Father's expense.
6. Neither party shall do or say anything which may e:strange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natural development of
the Child's love and respect for the other parent. Both parties shall ensure that third parties having
contact with the Child comply with this provision.
7. This Order is entered pursuant to an ag:r;eement of the parties at a Custody Conciliation
Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
{
,~
J.
BY THE CO .'
Edgar B. Bayley,
cc: Joseph J. Sasa, Father
John Hyams, Esquire - Counsel for Mother
~
.~ j/-o5-6~
qa-.
..' ., 'f _.,,'" _..- ," (.~r'-""I:-,.r.;. i
...,"":'..-~. ';'~'- (;<I'.....t..'\.( ~...f.!l<".:. "~.l""''''...r~~("".
:,1 'i~:~~,r;'J~',;_,.~. ".;,~. i:~':',".~';;::;::;~ :~r~:.,.,:
......j 'l"~-"'~;";-:{ !.,'~' .l._,~,.~'j. t.._~: ';:.\ .......-~.,...-.... .
(.l!.~ 1, "~"'..:fto,I ~ " . . - ..'.
n;~;;;~-!.".; _. -, I
P!'rJ~h:,,:;'(.:<.~,~y
'----
JOSEPH J. SASA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANI.4-.
vs.
02-4361
CIVIL ACTION LAW
JAMI N. MILLER,
Defendant
IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits tile following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
!;;:URRENTL Y IN CUSTODY OF
Taylor R. Sasa
March 16,2001
Mother
2. A Conciliation Conference was held on October 16, 2002, with the following individuals in
attendance: The Mother, Jami N. Miller, with her counsel, John M. Hyams, Esquire. The Father,
Joseph J. Sasa, who is currently incarcerated at the state prison in Shamokin, Pennsylvania,
participated in the Conference by telephone.
3. The parties agreed to entry of an Order in the form as attached.
Od-Zl ~ .::11' ;J.,'::\',.::L. ~:.. j?
Date . Dawn S. Sunday, Esquir:cr
Custody Conciliator
7"'-
'f:::
-
~
~
~
N
o
-q:
00
-c
~
~
0'
~
-0
~
o
<II
T
--u
o
<;;
~
V'
o
f" ~
">
r;:-;)
(;'"::)
C,J'
(/)
In""
:-.'
o
"
:.;:i
fii:D
r--
m
l?
C)
:U
>,)
;:3rn
::;:!
.."
:.:<
'..J
I
t,,J
::>-,..
~:..)
JOSEPH J. SASA
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COlJ"TY, PENNSYLVANIA
V.
02-4361
CIVIL ACTION LAW
JAMI N. MILLER
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Thursday, September 08, 2005
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawu S. Suuday, Esq.
at 39 West Maiu Street, Mechanicsburl(, PA 17055 on Thursday, October 13, 2005
, the conciliator,
at 10:00 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 deline and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age live or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or penn anent 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 priOJr to scheduled hearing.
FOR THE COURT,
By: /s/
Dawn S. Sunday, Esq.
Custody Conciliator
y
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with DisabiJites Act of 1990. For infoonation 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 ATTORNEY AT ONCE. IF YOU DO NOT
HA VE 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
~~irv .~ ~ ~ 5?:J6.p
- ~ ~ ~ ~5c?-6-f
~~~~~p'n 5G7o~
Al}lf:('(' -"':,1'.J::O
I S :Z G - ci:j:; SGOZ
^b\J~D>',i'~"'''L;C:,\J 3Hl :10
3~)lj:\(J--Cj:n:~,~
.
~
II_IB..{)~{ ?-
JOSEPH J. SASA
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
02-4361
CIVIL ACTION LAW
JAMI N. MILLER
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this Z -2-- day of ~ ~ , 2005,
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
upon
I. The prior Order of this Court dated March 4,2002 is vacated and replaced with this Order.
2. The Mother, Jami Hiner, formerly Miller, shall have primary physical and legal custody of
Taylor R. Sasa, born March 16,2001.
3. The parties shall schedule a consultation with Anthea Stebbins or other professional selected
by agreement to obtain guidance in preparation of the Child for reintroduction of the Father after an
extended absence. The Father shall be responsible for all costs under this provision.
4. Beginning on the first Saturday after the consultation with Anthea Stebbins or other
professional, the Father shall have custody ofthe Child on alternating Saturdays from 9:00 a.m. until
II :00 a.m. and, during the alternating interim weeks, on a weekday evening for a minimum of one
hour to be scheduled at the Mother's convenience.
5. On Christmas Eve 2005, the Father shall have custody of the Child for a period oftime as
arranged by agreement between the parties.
6. The parties and counsel shall attend an additional custody conciliation conference in the
office of the conciliator, Dawn S. Sunday, on Tuesday, January 24,2006 at 10:00 a.m.
7. Neither party shall do or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natural development of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
.
8. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms ofthis Order shall control.
BY THE COURTJ!
1 ,~"
.J.
cc: Jeanne B. Costopoulos, Esquire - Counsel for Fathej"
Lawrence J. Rosen, Esquire - Counsel for Mother
(( J i-f))'
~.~
~.
1
"
S~; ":" Pd ZZ
, 'v
J('
_J
.
.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JOSEPH J. SASA
vs.
02-4361
CIVIL ACTION LAW
JAMI N. MILLER
Defendant
IN CUSTODY
Prior Judge: Edgar B. Bayley
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Taylor R. Sasa
March 16, 2001
Mother
2. A custody conciliation conference was held on November II, 2005, with the following
individuals in attendance: The Father, Joseph J. Sasa, with his counsel, Jeanne B. Costopoulos,
Esquire, and the Mother, Jami N. Hiner (formerly Miller), with her counsel, Lawrence J. Rosen,
Esquire.
3. The parties agreed to entry of an Order in the form as attached.
No~~ /.) ~OS
Date
~4~
Dawn S. Sunday, Esquire
Custody Conciliator
JAN 2 /) 20Ub r
~
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
JOSEPH J. SASA
vs.
02-4361
CNIL ACTION LAW
JAMI N. MILLER
Defendant
IN CUSTODY
ORDER
AND NOW, this 24th day of January.2006 , the conciliator, being advised by both
parties and plaintiffs counsel that the custody conciliation conference scheduled for today, January 24,
2006 is no longer necessary, hereby relinquishes jurisdiction.
FOR THE COURT,
UJc&r-
Dawn S. Sunday, Esquire U
Custody Conciliator
\-{)i\',-li\-; f,(>-"::' ,( ':~d
, ". '(-;~:.' . '.;.~:'''rl''
!\..U \:, ~: , ~ '-if"'. oJ
9 I : mnt 18 NVr900l
"'/1'.""..' ,."., :lHl' '0
(\1:1' VJ\url.:.Uow..J :1
3:J1:J:IQ-G311:l
JOSEPH J. SASA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
02-4361 CIVIL ACTION - LAW
JAMI N. MILLER,
Defendant
IN CUSTODY
PLAINTIFF'S PETITION TO MODIFY CUSTODY
AND NOW, the Plaintiff, Joseph J. Sasa, by and through his attorney, Jeanne B.
Costopoulos, Esquire, avers the following in support of this Petition:
1. Petitioner, Plaintiff above, is Joseph J. Sasa (hereinafter referred to as Father), an adult
individual currently residing at 46 Tory Circle, Eno1a, Cumberland County,
Pennsylvania, 17025.
2. Respondent, Defendant above, is Jami N. Hiner, formerly Jami N. Miller, an adult
individual currently residing at 4220 Locust Lane, Harrisburg, Dauphin County,
Pennsylvania, 17053.
3. The parties are the natural parents of one daughter, namely Taylor R. Sasa, born March
16,2001.
4. Following an agreement between the parties regarding custody of the child reached at a
Conciliation Conference held before Dawn S. Sunday, Esquire, on November 11, 2005,
an Order of Court was entered by the Honorable Edgar B. Bayley on November 22,
2005. (See Exhibit A - Order and Custody Conciliation Summary Report).
5. Father desires to increase his custodial time with the child. He first attempted to make
arrangements directly with Mother, but she has been unreasonable and controlling about
the situation.
6. Father is seeking to modify the November 22, 2005 Order. More specifically, he seeks
shared legal custody and increased periods of partial physical custody as follows:
a. Alternating weekends from Friday afternoon through Sunday evening.
b. One to two evenings during the week.
c. Shared holidays.
d. Two non-consecutive weeks of vacation per year.
WHEREFORE, Defendant Father respectfully requests this Honorable Court to modify the
current Order of Court such that he has shared legal custody and expanded partial physical custody
as set forth more specifically above.
RESPECTFULLY SUBMITTED:
BY: ~. ____ _,
Jeanne B. Costopoulos, EsquIre
P A Supreme Court LD. No. 68735
MARIA P. COGNETTI & ASSOCIATES
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Telephone: (717) 909-4060
Fascimile: (717) 909-4068
ATTORNEY FOR PLAINTIFF
DATE:
tu(s/~-6
JOSEPH J. SASA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
02-4361 CIVIL ACTION - LAW
J AMI N. MILLER,
Defendant
IN CUSTODY
VERIFICATION
I, Joseph J. Sasa, hereby verify that the statements made in the foregoing document are
true and correct to the best of my knowledge, information, and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. g 4904, relating to unsworn
Jos
falsification to authorities.
Date:
IO/3/~
Signature:
JOSEPH J. SASA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
02-4361 CIVIL ACTION - LAW
JAMI N. MILLER,
Defendant
IN CUSTODY
CERTIFICATE OF SERVICE
I, Jeanne B. Costopoulos, Esquire, hereby certify that this day I served a copy of the
foregoing petition upon the person, and in the manner, indicated below, which service satisfies the
requirements of the P A Rules of Civil Procedure, by depositing a copy of the same with the United
States Post Office at Camp Hill, Pennsylvania, through first class mail, prepaid, and addressed as
follows:
Lawrence J. Rosen, Esquire
1101 North Front Street
Harrisburg, P A 17102
BY:
eanne B. Costopoulos, Esqmr
P A Supreme Court I.D. No. 68735
MARIA P. COGNETTI & ASSOCIATES
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Telephone: (717) 909-4060
Fascimile: (717) 909-4068
ATTORNEY FOR PLAINTIFF
{ofl !Zd1p
DATE:
-----
EXH\B\T A
--
. I" _l/ I!j j
WO
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CU1'vfBERLAND COUNTY, PENNSYLVANIA
JOSEPH J. SASA
vs.
02-4361
CNIL ACTION LAW
JA1\ll N. MILLER
Defendant
IN CUSTODY
ORDER OF COURT
AND NO\V, this .) ~] day of A.lJ ULn1. /u.r, 2005, upon
consideration of the atLlcheu Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Order of this Court dated March 4, 2002 is vacated and replaced with this Order.
2. Thet\lother, Jami Hiner, formerly Miller, shall have primary physical and legal custody of
Taylor R. Sas~l, born March 16,2001.
3. The parties shall schedule a consultation \vith Anthea Stebbins or other professional selected
by agreement to obtain guidance in preparation of the Child for reintroduction of the Father after an
extended absence. The Father shall be responsible for all costs under this provision.
4. Beginning on the first Saturday after the consultation with Anthea Stebbins or other
professional, the Father shall have custody of the Child on altemming Saturdays from 9:00 a.l11. until
11 :00 a.l11. and, during the a.lternating interim weeks, on a weekday evening for a minimum of one
hOllr to be scheduled at the Mother's convenience.
5. On Christmas Eve 2005, the Father shall have custody of the Child for a period of time as
mranged by agreement bd\veen the parties.
6. The panies and counsel shall attend an additional cllstody conciliation conference in the
oftice of the conciliator, Dawn S. Sunday, on Tuesday, January 24, 2006 at 10:00 a.m.
7. Neither party shall do or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natural development of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision. .
s. This Ordcr is entered pursuant to an agreement of the parties at a custody conciliation
conference, The panics may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall controL
BY THE COURT,
1)1 f' ri.
Ed gqT
~-f(f
cc: Jeanne' B. Cosropoulos, Esquire - Counsel felf Father
Lawrence J. Rosen, Esquire - Counsel for l'vlother
"'J"'!~r' ,r'~
ij ti~~ ~J :~'-' i: ~n, jl~j'tl r.:"~'" ,r...., ~ r' _ll
. i... '.........UJ. I !,~'\.,.4..'.',-.1..r "._"':.!:} ~ ",.(/;,l:.rr'"'r\D
:", } ",'H,..' ... ., . S ,'ldH'4 n,t:;~nD
.. ....,...~'''-'JiJ~}i:fiJ~t 'iil~d'~2';nvd 1 ;....,.,;,...,.., ,,'.
, -'." ,,"'i,1 eo [Sl\"'t'i ~., ill ''''w ",...>Pl_'"
..:-<.1 ~r~j \':~~',:d '~~i' <-,' "'.'l::'~' . ...... Htl ic.-:C;~ 1ft, 'kwVu
.'. . ] ')"'''''. ,)'.'.:~.c..'. j<Pli11'r r:J"I." Pa
',,'.'::a~" ,a.a. ~J .;)~>
'" \ \ I - "/.. ') ~J() C~
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JOSEPH 1. SASA
VS.
02-4361
CNIL ACTION LAW
JAlvll N. MILLER
Defendant
IN CUSTODY
Prior Judge: Edgar B. Bayley
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE \VITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Taylor R. Sasa
March 16,2001
Mother
2. A cllstody concjliation conference was held on November 11, 2005, with the following
individuals in attendance: 'The Father, Joseph J. Sasa, with his counsel, Jeanne B. Costopoulos,
Esquire, and the Mother, Jami N. Hiner (formerly l\/filler), with her counsel, Lawrence J. Rosen,
Esquire.
3. The parties agreed to entry 0 f an Order in the forn1 as attached.
No~bu-- /.)~ CkJo5
Date
~hy
Dawn S. Sunday, Esquire
Custody Conciliator
t::J (:) ~
~ ~ (y
.
I' r-~)
D c l,~:':' 0
" ':.d
........ C.'~ -n
~ ~ D- C) -I
C - 'J ..,-
~ --1 .~;'j iTI
~ f! I 'll
C-, f-<~
(
, {".-)
~7 ..'
~ .-~
~ " .7:- r-(,
ro.? ' )
:=:;
C,) r:>-
::::J
~ 1..0 .<
JOSEPH J. SASA
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
02-4361 CIVIL ACTION LAW
JAMI N. MILLER
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Wednesday, October 11, 2006
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq.
at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, November 09, 2006
, the conciliator,
at 12:30 PM
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: Isl
Dawn S. Sunday, ESq.A,?l/
oJ
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For infonnation 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 ATTORNEY 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
~ i? $- ~ ~ 10'1/-01
~fp:; ~'VH ~Jh r(J~.Jl(]1
.~ ~:z ~A0.j!p 10./1-0/
. \fiNV;\lASNN3d
Al.Nnc:,'! ""n8V\\n~
B S :01 t~V II 13090Ul
AtlV10NCH.LOtid 3Hl :10
:n~~O-031tl
"'
NOY 15 2000 ~ '}-
JOSEPH J. SASA
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
02-4361
CNIL ACTION LAW
JAMI N. MILLER
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this "'"Vo day of ~_~ ' 2006, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
Order.
1. The prior Order of this Court dated November 22, 2005 is vacated and replaced with this
2. The Mother, Jami Hiner, formerly Miller, and the Father, Joseph J. Sasa, shall have shared
legal custody of Taylor R. Sasa, born March 16,2001. The parties shall consult with each other in
making all major non-emergency decisions concerning the Child's welfare including, but not limited
to, her health, religion and education. The parties shall have equal access to all information concerning
the Child including, but not limited to, school and medical information and records.
3. The Mother shall have primary physical custody ofthe Child.
4. The Father shall have partial physical custody ofthe Child in accordance with the following
schedule: Beginning on Saturday November 25, 2006, the Father shall have custody ofthe Child on
alternating weekends from Saturday at noon until Sunday at 6:00 p.m. After having overnight periods
of custody for four weekends, the Father's weekend periods of custody shall be expanded to run from
Friday at 6:00 p.m. through Sunday at 6:00 p.m. beginning Friday January 19,2007. Beginning
Thursday November 16, 2006 the Father shall have custody of the Child on Thursdays preceding the
Mother's weekends from 5:00 p.m. until 7:00 and on Tuesdays preceding the Father's weekends from
5:00 p.m. until 7:00 p.m. The parties shall arrange for the Mother to visit the Father's place of
residence prior to the first overnight period under this provision.
5. The parties shall share having custody of the Child on holidays as follows:
A. Thanksgiving: The Father shall have custody of the Child on Thanksgiving Day from
10:00 a.m. to 3:00 p.m. and the Mother shall have custody beginning at 3:00 p.m. and continuing for
the remainder of the day.
. ....
B. Christmas: The Father shall have custody of the Child on Christmas Eve from noon
until 8:00 p.m., the Mother shall have custody from Christmas Eve at 8:00 p.m. until Christmas Day at
3:00 p.m., and the Father shall have custody on Christmas Day from 3:00 p.m. until 8:00 p.m.
C. Easter: The Father shall have custody of the Child from Saturday at 6:00 p.m.
through Easter Sunday at 3:00 p.m. and the Mother shall have custody from Easter Sunday at 3:00
through the remainder of the holiday.
D. Mother's Day! Father's Day: The parties shall equally share having custody of the
Child on Mother's Day and Father's Day as arranged by agreement.
E. The holiday custody schedule shall supersede and take precedence over the regular
and vacation custody schedules.
6. Each party shall be entitled to have a one week period of vacation custody with the Child in
2007 and two nonconsecutive weeks beginning in 2008 and continuing thereafter. The parties shall
provide each other with at least 30 days advance notice for periods of custody under this provision.
The party providing notice first shall be entitled to preference on his or her selection of vacation dates.
Each party shall schedule periods of custody under this provision to include his or her periods of
regular weekend custody.
7. Neither party shall do or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natural development of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
8. Unless otherwise agreed, the Father shall provide transportation for exchanges of custody.
9. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions ofthis Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
Edgar B. Bayley 1.
cc: Jeanne B. Costopoulos, Esquire - Counsel for Father \ If ~d-O ._~ u (I~ ~
Lindsay Gingrich Maclay, Esquire - Counsel for Mother I - , u..,.. ..;
2UEG f<;:~:/ 20
p~..j
. II
!... ,..,
I . ,.1'!
r-,; i,
V......i~
. "fill
JOSEPH J. SASA
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
vs.
02-4361
CNIL ACTION LAW
JAMI N. MILLER
Defendant
IN CUSTODY
Prior Judge: Edgar B. Bayley
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Taylor R. Sasa
March 16, 2001
Mother
2. A custody conciliation conference was held on November 13, 2006, with the following
individuals in attendance: The Father, Joseph J. Sasa, with his counsel, Jeanne B. Costopoulos,
Esquire, and the Mother, Jami N. Hiner (formerly Miller), with her counsel, Lindsay Gingrich Maclay,
Esquire.
3. The parties agreed to entry of an Order in the form as attached.
jV~ I~ ;J-dOt.P
Date
D~-
Custody Conciliator