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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SONIA RODRIQUEZ,
Plaintiff
v.
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NO. :LinrlJ- J 75' Cu;z; J~
ALEXIS MACHIN,
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, upon consideration of the attached Complaint, it is
,
tha the parti s ani(i their respective counsel
If' . - (' , the Conciliator, at
on the \~ day
of , 2000, at C\', ~() 0- om., 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. Failure to appear at the Conference
I
may provide grounds for entry of a temporary or permanent Order.
BY THE COURT:
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 TO FIND OUT WH~RE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by
law to comply with the Americans with Disabilities Act of 1990. For
information about accessible facilities and reasonable
accommodations available to disabled individuals having business
before the Court, please contact the office set forth above. 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.
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FiLED-OFFiCE
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SONIA RODRIQUEZ,
Plaintiff
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v.
NO. c2nro. J 7S Ct.U-z1
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ALEXIS MACHIN,
Defendant
IN CUSTODY
COMPLAINT FOR CUSTODY
AND NOW, this
of pAUA.J ~' 2000, comes the
RODRIQUEZ, by and through her attorney, Maryann
'i-'L
10 day
Plaintiff, SONIA
Murphy, Esquire, of Legal Services, Inc., and respectfully files
this Complaint for Custody, and in support thereof avers as
follows:
1. The Plaintiff is SONIA RODRIQUEZ whose current address is
P.O. Box 1039, Carlisle, Cumberland County, Pennsylvania.
2. The Defendant is ALEXIS MACHIN who currently resides at
525 Cherry Court, Carlisle, Cumberland County, Pennsylvania.
3. The Plaintiff seeks primary physical and shared legal
custody of the following children:
AMANDA MACHIN, born February 27, 1991
and
MICHAEL MACHIN, born June 23, 1993
and partial physical and shared legal custody of the following
children:
AMALIA MACHIN, born January 6, 1988
and
ALEXIS MACHIN, Jr., born July 27, 1989
4. The children were born out of wedlock. AMANDA and MICHAEL
currently reside with the Plaintiff at the Shelter in Cumberland
County, Pennsylvania; and AMALIA and ALEXIS Jr. currently reside
with the Defendant at 525 Cherry Court, Carlisle, Cumberland
County, Pennsylvania.
5. During the lifetime of the children, they have resided at
the following addresses with the following persons:
with Whom
Time
Address
birth-1989
1989-1996
1996-12/99
Philadelphia, PA
Harrisburg, PA
525 Cherry Court
Carlisle, PA
P.O. Box 1039
Carlisle, PA
and
525 Cherry Court
Carlisle, PA
Plaintiff/Defendant
Plaintiff/Defendant
Plaintiff/Defendant
12/99-present
Plaintiff
Defendant
6. The father of the children is ALEXIS MACHIN. He is
unmarried.
7. The mother of the children is SONIA RODRIQUEZ. She is
unmarried.
8. Two of the children reside with Plaintiff and two of the
children reside with Defendant. There are no other persons living
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in the households.
9. The 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 any other Court, except as set
forth above.
10, The Plaintiff has no information of a custody proceeding
concerning the children pending in a Court of this Commonwealth.
11, 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.
12, Each parent whose parental rights to the children have
not been terminated, and the persons who have physical custody of
the children, have been named as parties to this action. There are
no other persons known to have or claim a right to custody or
visitation of the children and therefore, no further notice of the
pendency of this action and the right to intervene shall be given,
other than to the parties named herein.
13. The best interest and permanent welfare of the minor
children will be served by granting Plaintiff primary physical and
shared legal custody of AMANDA and MICHAEL, and partial physical
and shared legal custody of AMALIA and ALEXIS Jr.
WHEREFORE, Plaintiff requests this Honorable Court to
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grant her primary physical and shared legal custody of AMANDA and
MICHAEL and partial physical and shared legal custody of AMALIA and
ALEXIS JR.
Respectfully submitted,
n Murphy,
Legal Services,
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
LD. # 61900
Attorney for Plaintiff
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VERIFICATION
I, SONIA RODRIQUEZ, verify that the statements made in
the foregoing Custody Complaint are true and correct. I understand
that false statements herein are made subject to the penalties of
18 Pa.C.S. 4904, relating to unsworn falsification to authorities.
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SONIA RODRIQUE .
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SONIA RODRIQUEZ,
Plaintiff
.
.
:
.
.
VS.
NO,
ALEXIS MACHIN,
Defendant
IN CUSTODY
CERTIFICATE OF SERVICE
I, Maryann Murphy, Esquire, do hereby certify that on the
day of
, 2000 I served a true and correct copy
of the foregoing Custody Complaint on the Defendant, ALEXIS MACHIN
at the address set forth below, by placing a copy of same in the
United States Mail, postage prepaid, certified/restricted delivery.
Alexis Machin
525 Cherry Court
Carlisle, PA 17013
Respectfully submitted,
Maryann urphy, Esquire
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
(717) 540-8600
I.D, # 61900
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SONIA RODRIQUEZ,
Plaintiff
; NO. .;Lnv. J 70 Ci;nJ T..R-<-
v.
: IN CUSTODY
ALEXIS MACIDN,
Defendant
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, SONIA RODRIQUEZ, Plaintiff, to proceed in forma oauoeris.
I, Maryann Murphy, Esquire, of Legal Services, Inc., attorney for the party proceeding in
forma oauoeris, certify that I believe the party is unable to pay the costs and that I am providing
free legal services to the party. The party's affidavit showing inability to pay the costs of litigation
is attached hereto.
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Maryann urphy, Esquire
Legal Services, Inc.
S Irvine Row
Carlisle, PA 17013
(717) 243-9400
J.D. # 61900
Attorney for Plaintiff
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IN THE"COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SONIA RODRIQUEZ,
Plaintiff
; NO. .2....b-vv - /70 ~ T~
v.
: IN CUSTODY
ALEXIS MACHIN,
Defendant
AFFIDAVIT IN SUPPORT OF PETITION
FOR LEAVE TO PROCEED IN FORMA PAUPERIS
1. I am SONIA RODRIQUEZ, Plaintiff in the above matter and because of my financial
condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action
or proceeding.
2. I am unable to obtain funds from anyone, including my family and associates, to pay
the costs of litigation.
3. I represent that the information below relating to my ability to pay the fees and costs
is true and correct.
(a) Name: SONIA RODRIOUEZ
Address: P.O. Box 1039. Carlisle. PA 17013
(b) Social Security Number: 582-31-2095
If you are presently employed, state
Employer: Flvine: J
Address: 1501 Harrisbure: Pike. Carlisle. PA.17013
Salary or wages per month: $1.259.00
Type of work: maintenance
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If you are presently unemployed, state N/A
Date of last employment: NI A
Salary or wages per month: N/A
Type of work: N/A
(c) Other income within the past twelve months NONE
Business or profession: -0-
Other self-employment: -0-
Interest: -0-
Dividends: -0-
Pension and annuities: -0-
Social Security benefits: -0-
Support payments: -0-
Disability payments: -0-
Unemployment compensation and
supplemental benefits: -0-
Workman's compensation: -0-
Public Assistance: -0-
Other: -0-
(d) Other contributions to household support NONE
(Wife)(Husband) Name: N/A
If your (husband) (wife) is employed, state
Employer: N/A
Salary or wages per month: NtA
Type of work: Nt A
Contributions from children: -0-
(e) Property owned
Cash: -0-
Checking Account: -0-
Savings Account: -0-
Certificates of Deposit: -O-
Real Estate (including home): -0-
Motor vehicle: Make Pontiac Pirebird Year 1995
Cost $18.000.00
Stocks; bonds: -0-
Other: -0-
(t) Debts and obligations
Mortgage: -0-
Rent: I am currentlv at the Shelter and do not Dav rent, however. I will need to Dav
Amount owed $10.000.00
Loans:
rent when I move out.
$10,000.00 automobile loan
Monthly Expenses: $750.00
(g) Persons dependent upon you for support
(Wife) (Husband) Name: NtA
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Children, if any:
Name: Amalia Age: 12
Name: Alexis Age: 10
Name: Amanda Age: 9
Name: Michael Age: 6
4. I understand that I have a continuing obligation to inform the court of improvement in
my financial circumstances which would permit me to pay the costs incurred herein,
5. I verify that the statements made in this affidavit are true and correct. 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: ;-jtJ- 00
tw~~fj
SONIA RODRIQEUZ
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SONIA RODRIQUEZ,
Plaintiff
IN TIiE COURT OF CpMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANlA
v
CIVIL ACTION - LAW
ALEXIS MACHIN,
Defendant
NO. 2000-175 CIVIL
IN CUSTODY
COURT ORDER
AND NOW, this \ 3'(t, day of June, 2000, upon consideration of the
Conciliation Report, it is ordered and directed as follows:
attached Custody
1. The Mother, Sonia Rodriquez, and the Father, Alexis Machin, shall enjoy
shared legal custody of Amanda Machin, born February 27, 1991, Michael
Machin, born June 23, 1993, Amalia Machin, born January 6, 1988 and
Alexis Machin, Jr., born July 27, 1989.
2. The parties shall also enjoy shared physical custody of the four minor
children. The arrangement with respect to sharing physical custody shall be
as agreed upon by the parties.
3. In the event either party desires to have this order modified and desires a
more specified physical custody order, that party may petition the Court to
have the case again scheduled with the Custody Conciliator for a
Conference.
BY TIiE COURT,
cc:
Maryann Murphy, Esquire
Legal Services, Inc.
1.
Alexis Machin
525 Cherry Court
Carlisle, P A 17013
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SONIA RODRIQUEZ,
Plaintiff
IN TIiE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CML ACTION - LAW
ALEXIS MACHIN,
Defendant
NO. 2000-175 CIVIL
IN CUSTODY
Prior Judge:
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH TIiE CUMBERLAND COUNTY CIVIL RULE OF' PROCEDURE
1915.3-8(1,), the undersigned Custody Conciliator submits the following report:
1. The pertinent infonnation pertaining to the children who are the subject of this litigation is
as follows:
Amanda Machin, born February 27, 1991, Michael Machin, born June 23, 1993, Amalia
Machin, born January 6,1988 and Alexis Machin, Jr., born July 27,1989.
2. A Conciliation Conference was held on June 9, 2000, with the following individuals in
attendance:
The Mother, Sonia Rodriquez, with her counsel, Maryann Murphy, Esquire; and the Father,
Alexis Machin, who appeared without legal counsel.
3. The parties agree to the entry of an order in the fonn as attached.
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