ACTION IN CUSTODY

ACTION IN CUSTODY COURT OF COMMON PLEAS OF LEHIGH COUNTY, PA DOCKET NO. 2024-FC-0582 NOTICE TO JAMES SANTIAGO Madeline Baez-Caban and Sean Ross have filed an Amended Complaint for Custody in Lehigh County Court of Common Pleas against Yessenia Rivera and James Santiago. A Custody Complaint has been filed against you, JAMES SANTIAGO, to obtain sole legal and sole physical custody of the following minor child, to wit: Y.L.R. (age 12). A Custody Conference has been scheduled for December 2, 2025, at 9:00 a.m. at the Lehigh County Courthouse, 455 West Hamilton Street, 4th Floor, Room 423, Allentown, Pennsylvania, 18101. If you wish to defend, you must enter a written appearance personally or by an attorney and file your defenses or objections in writing with the Court. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you without further notice of the relief requested by the Petitioners. You may lose rights to Y.L.R. that are 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. lawyer referral service of the lehigh county bar association 1114 W. Walnut Street Allentown, PA 18102 (610) 433-6204 AMENDED COMPLAINT FOR CUSTODY COMES NOW the Plaintiff, MADELINE BAEZ-CABAN AND SEAN ROSS, by and through their attorneys, Kylie J. Cloonan, Esquire and Ian M. Richetti, Esquire and Crosson & Richetti LLC, and hereby submits the instant Complaint in Custody, respectfully representing as follows: 1. The Plaintiffs are MADELINE BAEZ-CABAN AND SEAN ROSS (hereinafter "Plaintiffs", adults individuals residing at 480 Lisa Court, Allentown, Lehigh County, Pennsylvania 18104. 2.The Defendant(1) is Yessenia Rivera (hereinafter "Mother"), an adult individual residing at 316 ½ N. Jefferson Street, Allentown, Lehigh County, Pennsylvania 18103. 3. The Defendant(2) is James Santiago (hereinafter "Father"), an adult individual residing at 263 Ramsey Avenue, Chambersburg, Franklin County, Pennsylvania 17201. 4. Plaintiffs seek sole legal custody and sole physical custody of the following one (1) minor child, to wit: Y.L.R. (age 12). 5. The one (1) minor child was born out of wedlock. 6. The child is presently in the custody of Madeline Baez-Caban and Sean Ross who reside at 480 Lisa Court, Allentown, Lehigh County, Pennsylvania 18104. 7. During the past five years, the child has resided with the Plaintiffs, at 480 Lisa Court, Allentown, Lehigh County, Pennsylvania 18104. 8. The child has resided in the Commonwealth of Pennsylvania and the County of Lehigh for at least six (6) months prior to the filing of this Complaint. 9. The relationship of Plaintiffs to the child is that of caretakers and parent figures since child's birth. 10. The relationship of Defendant(1) to the child is that of Mother. 11. The relationship of Defendant(2) to the child is that of Father. 12. The Mother currently resides with her mother Guadalupe Cortez, and her two other children. 13. It is unknown who Father resides with. 14. Plaintiffs have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 15. Plaintiffs do not know of a person not a party to the proceedings who has physical custody of the child or claims to have custodial rights with respect to the child. 16. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. The child has resided with the Plaintiffs her whole life and developed a parent/child relationship with them. 17. 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. 18. Plaintiffs have attached their Criminal Record/Abuse History Verification forms required pursuant to Pa. R.C.P. No. 1915.3-2. WHEREFORE, Plaintiffs, MADELINE BAEZ-CABAN AND SEAN ROSS, respectfully requests the court to grant them sole legal custody and sole physical custody. Kylie J. Cloonan, Esquire Crosson & Richetti LLC 609 W. Hamilton St., Suite 301 Allentown, PA 18101 October 31 2025 LSOM0397650