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Home My WebLink About00-01653 , ,~ . ' 1: F:\FILES\DA T AFILE\Gendoc.cur\10045-com.l/tde Created 03/17/00 07:36:36 AM Revised: 1J3/17/0002:17:35PM 10045.1 KRYSTAL B. REID, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000- I to53 CIVIL LAW ELVIS RODRIGUEZ, Defendant IN CUSTODY ORDER OF COURT AND NOW, this..ill day of ~ ("' ,2000, upon consideration ofthe attached Complaint, it is hereby directed that the parties and their respective counsel appear before ;'eel' the conciliator, at~ t.t' ~;" ('( 1ffi1t.e\Vl'\~ (() Cn l~)~-e.... on the \'6 dayof ,2000, at ICl'. 30 o..,m. for a Pre-Hearing Custody Conference. At such conference, an effo 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. FOR THE COURT, By:_?\nO'("'\\ ~ "f,.. ~ \)i1(JF~\ ' Custody Conciliator C ~'J The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act ofl990. Forinformation 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 " , ~,..,,,,,,,,,,,,, 1!III!!I8l!!......,...-,~ - ",' . - ~ F' OF j~l€R'12FFICE , - ,-,'101I-fONOT;lJ/Y 00 MAR 23 P/1 2: 23 CUM81:HUWO COUN PENNSYLVANiA. TY , 3;E-O{) W ~ M~ ~ 4~ 3~I~ ~~ ~ t; dff' r J-~f-CJ?J ~ ~:..... tI-~ .~ - ,~':" '1"~'- ~ lll!!IB1_....... _-,D_.~~~If:J!'1'"~" ~,)IIIU J U.Jl,"__~J__IlllmWii!l!~!lIl!ll!i'l~~Ii'f1'IlI!~_1 ,- .;..-"-! KRYSTAL B. REID, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000- /t53- CIVIL LAW ELVIS RODRIGUEZ, Defendant IN CUSTODY PLAINTIFF'S COMPLAINT TO CONFIRM CUSTODY 1. Plai~tiff is Krystal B. Reid, an adult individual currently residing at 175 Church Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Elvis Rodriguez, an adult individual currently residing 765 East 175th Street, Apt. 37, Bronx, New York 10457. 3. Plaintiff seeks custody of the child, Kacey Eulogia Rodriguez, who was born on November 29, 1996. The child was born out of wedlock. Since the child's birth, the child has resided with the following persons at the following addresses for the following periods of time: Since her birth, the child has resided with the following individuals: a. From November 29, 1996 until November 1, 1999, with the parties; b. From November 1, 1999 to mid-March, 2000, with Plaintiff only; and c. Mid-March, 2000 to the present, with Plaintiff and Todd Rowland. 4. The relationship of the Plaintiffto the child is that of mother. She is single and living separately. The Plaintiff currently resides with the following: Name Relationship Kacey Eulogia Rodriguez Daughter Todd Rowland Friend 5. The relationship of the Defendantto the child is that off ather. He is single and living separately. The Defendant currently resides with the following: Name Relationship Unknown Friend Unknown Friend 1___ ',-",- -"" 6. The parties have not participated in previous litigation concerning the custody of the child in this court or any court. The Plaintiffhas no information of a custody proceeding concerning the child pending in any other court. 7. The best interest and permanent welfare of the child will be served by granting custody to Plaintiff because: She is best able to provide a stable, nurturing and loving envirorunent for her daughter. 8. Plaintiff does not know of any person not a party to these proceedings who claims to have custody or visitation rights with respect to the child. WHEREFORE, Plaintiff requests your Honorable Court to set a time and place for a hearing at which Plaintiff requests the Court to grant her the Custody Order. Pending said hearing, Plaintiff requests temporary custody. MARTSON DEARDORFF WILLIAMS & OTTO By5~M.- ~ ~Vv.1L.,"J- Thomas J. Williarhs, Esquire Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff Date: March 17,2000 . '" VERIFICATION I, Thomas J. Williams, Esquire, counsel for Plaintiff depose and say, subject to the penalties of 18 Pa. C.S.A. Section 4904, that the facts set forth in the foregoing pleading are true and correct to the best of my knowledge; that my client is presently unavailable; that I am authorized to execute this Verification on her behalf, and that I will supplement this Verification in the near future with one executed by my client. Date: March 17, 2000 Th~~;;~ ---- iIillmli:Ii__~_~IIiifiIiI"'iilatJ . 'll&'i\l~illiI4l1ti~M~ " ,,~ . ,'~. "_ilio_~ " ~ j '~_1Il .1 ^ > -1,1111_ ~ ~~ .~" ~' g 0 0 ~( s: :s: . \. -pm "'" ~~i S2cg :;0 ~- It< zr" ~Q' . '""J':> cr.> r~. -.J o' -<2: Ii \<0 .-{ :'2 :r:3:J ~i ()l ~o .... a afJ 0 :;;8 't? z~ 'vi .0 0 R.) 1J iJl ~ N ~ ..0 r:fJ G 0 \0,) 11- ) ---~"--,~" I ~ ~ . - , _-.__-.".1: -. .". . "'';'k ~ .,'. _~ -" "~~~"J ... MAY 1 B 2\~ KRYSTAL B. REID, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW ELVIS RODRIGUEZ, Defendant NO.2000-1653 CIVIL IN CUSTODY COURT ORDER AND NOW, this ;1 Y day of May, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, KrystaI B. Reid, and the Father, Elvis Rodriguez, shall enjoy shared legal custody ofKacey Eulogia Rodriguez, born November 29, 1996. 2. The Mother shall enjoy primary physical custody of the minor child. 3. The Father shall enjoy periods of temporary physical custody of the minor child at such times as agreed upon by the parties. Whenever Father is in Cumberland County area, Father shall be afforded time with the child. Additionally, Father shall have a period of a number of weeks over the summer months with the understanding that Father shall give Mother reasonable notice as to when he intends to exercise visitation. 4. Father shall enjoy reasonable telephone contact with the minor child. 5. In the event Father becomes dissatisfied with the amount of custody that Mother is providing to him, Father may petition the court to have the case again scheduled with the Custody Conciliator for a conference. cc: Thomas 1. Williams, Esquire BY THE COURT, 7~f?pl ..5-dJ,c!). -00 p.t{.3 Elvis Rodriguez 2269 Cincinnatus Avenue Bronx, NY 10473 ~lIi\ti..a;. 1irlli_1IiIiiiliIilII~ ~--...:.. <'"," ~ -'-,= "'"iIiI.. "0> - .-' .. 0'" 'r FILFO--O:l!CE . I: '\j')TI.iiY 00 r'1~'{ /9 Pi'! :1: I, "1 "~ . CrUI\/i::r::nr ,,'-\;["! 1" f 'f I I ,1,--,,--, ,'^'"' ,. -Ii..... _'- l~J\11 T PENI\!SYU/l\;'-l!,/l_ " ~'- " ~. ^ - I - ~-,-" '^ ' ... KRYSTAL B. REID, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ELVIS RODRIGUEZ, Defendant NO.2000-1653 CIVIL IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Kacey Eulogia Rodriguez, born November 29, 1996. 2. A Conciliation Conference was held on May 17,2000, with the following individuals in attendance: The Mother, Krysta1 B. Reid, with her counsel, Thomas 1. Williams, Esquire; and the Father, Elvis Rodriguez, who appeared without counsel. 3. The parties agree to the entry of an order in the form as attached. S~/(7 / ()~ DATE