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Home My WebLink About00-02775 . \ " ~ - '~,,' , ROSEMARY CRUZ AND, RONALD P. PRIEST, Plaintiffs Vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO. 2000-.:n7S'Civil Term DANIELLE TUCCI, Defendant CIVIL ACTION-LAW ORDE~ OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respl,lctive counsel appear before t:f)\~lf\ S ,S f'\r\o:-- ?-' the Conciliator, on \...)0. , the &\ day of '-~{\~ , 2000 at q' '-So Q.m. in the office of said conciliator located at '--.J, \-, \A' PIA for a pre-hearing custody conference. At such onference, 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 may provide grounds for the entry of a temporary or permanent order. FOR THE COURT: Date: SL~\ at) BY: Custody Conciliator ~\ ~ ~ . FILED-OfRCE OF THE "POTHONOTARY 00 M~Y lEi Pli 3: 2.0 C ,W'-"JL''''I' r '"'iJ\'1V UI'l1o~:t\ 4\i"l;..;' I.A) 14 I PENNSYLVAN\J\ ~ 5/(,.()t) fal ~ ,~ ~ ~ ~/6'Co 7l~~hd#" 5-/t.t:J~ ~ /?t~~ Z, ~~~ , III'_~, ~_ ~, ~"-'-ry "--~ " " l~IIJl~'wm~~.;lft~!!/~~f!r'~~~!I! .-- 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 WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Court House One Court House Square Carlisle, Pa. 17013 (717) 240-6200 ,_,_ 0"'" -~' '-'~ , > - -~ "~~, , - l _, "'''' _ ~ ROSEMARY CRUZ AND RONALD P. PRIEST, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. NO. 2000 - ;,2" 77$ d;;;t ~ DANlELLE TUCCI, Defendant CIVIL ACTION - LAW COMPLAINT FOR PARTIAL CUSTODY PURSUANT TO GRANDPARENT VJ:SlTATION ACT. 23 fa. C.S.A. 5301 AND NOW, this J/i) Day of May, 2000, comes the Plaintiffs, Rosemary Cruz and Ronald P. Priest, by their attorney, Diane M. Rupich, Esquire, and respectfully requests the following: 1. The Plaintiffs, Rosemary Cruz and Ronald P. Priest, adult individuals, who currently reside at 4254 Heather Road, Elizabethtown, Dauphin County, Pennsylvania 17022. 2. The Defendant, Danielle Tucci, is an adult individual, who currently resides at 324 S. Enola Drive, Enola, Cumberland County, Pennsylvania 17025. - ,",'..-" .jlll~", 3. The Defendant and Scott Persing, the Plaintiffs' son, are the natural parents of two children, born out of wedlock; namely: Natalie Renee Persing, born July 21, 1999; and TylerJoseph Persing, born January 17, 1997. 4. The Plaintiffs are the paternal grandparents of said minor children. 5. Plaintiffs believe that the Defendant has Court Ordered primary physical custody of the minor children. 6. The Plaintiffs' son, the natural father, does not have Court Ordered partial custody and does not exercise any partial custody rights with his children. 7. The Defendant and the Plaintiffs' son had resided together until approximately the Spring of 1999. -2- -- , _;"" '_"0 '__0 8. The Plaintiff, Rosemary Cruz, was the day care provider for the minor child, Tyler Joseph Persing, every day and said minor child would spend at least one overnight per week at the Plaintiffs' home until approximately the spring of 1999. 9. After the Defendant and the Plaintiffs' son separated, the Plaintiffs continued to visit with Tyler every other weekend from Friday until Sunday and at least once or twice a week, and when the minor child, Natalie Renee Persing was approximately two or three months old, the Defendant permitted Natalie Renee Persing to be included in the grandparents' periods of visitation/partial custody. 10. Approximately one month ago, the Defendant arbitrarily and for no reason, stopped all contact whatsoever between the Plaintiffs and the minor children. 11. There is a strong bond between the minor children and the Plaintiffs, the paternal grandparents. -3- -. ,,-~, "~ ":' 12. It is in the best interests of the minor children that they be permitted to continue their contact with the Plaintiffs. 13. There has been no prior action between Defendant and the Plaintiffs herein; however, Plaintiffs believe that there may be a prior action between the Defendant and their son, Scott Persing. 14. The Court of Common Pleas of Cumberland County has jurisdiction in this matter, as the Defendant and the minor children reside in Cumberland County, Pennsylvania. WHEREFORE, Plaintiffs, Rosemary Cruz and Ronald P. Priest, respectfully pray your Honorable Court to grant them visitation/partial custody with their grandchildren. BY: iane M. RUplC squire 1017 N. Fro treet Harrisburg, Pa. 17102 (717) 232-9724 I.D. No. 71873 -4- "" - . .-~'-~;':'..~<".,,' ,. , VERIFICATION I verify that the statements made in this &p'n ;O.LA/ /'J 7 are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C.S. Section 4904 relating to unsworn falsification to authorities. ,J\~~ ,eoiirntf'+/ZI & ' Date: S t7--oV - , - - .':'''~~d_ , 0- -'--"< ~-'4' VERIFICATION I verify that the statements made in this (!g;m,;:J,hM//VT are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. If t7krx I tV (j {J/U-OQt {(Ol'!ltL D Po plC/Cf/ Date: S-Ol$ - , ~",;~ Cet/6 ..,:. 1e1t::S-f In the Court of Common Pleas of Cumberland County, Pennsylvania VS. VP;?/J/b//6 ~c<<' No. 02JaJ-,.2?/?? Civil. 19 ~ M~~tJ//tYft7~' ~/l5e ,}U//?,'LJr&4{.AJ -#;e.." ~/J?r:>~//tT- -G/t' ~;4ffJ)P4/U#1- U'3"//7-9.h,oN p/~7J ~/<./' /..kJ/YjI /0. ~tJ ,0/7 /fa/' bhd/'+; To Prothonotary r:f- tdj / Y: ,;Mod 19 ~/ne. ~4/~Alt ey for Plaintiflj" (' 7/7)2.3 247<Z~ .::z;p -# ~/ f'Z5 k~~ ~"' """"""",."~"_,~~'~'__lo",,,,,,~ _.~ ~@"....~ oIlliiliI,IjjU:IIiiili:....- '.'YfAF1Y 00 .JUL I i3 Hi 2: 09 '" 'I'" '~'" " l"'I"\'j'o\IT'Y , 'U"I "'i"l~ll 1-,."-1 ~ I ,l j'i V 1\ L._,.. (-. "L) '''''' PENNSYLVANiA --,,<,"- ,~~, ~ ~ .~" _~L~,...___, ~~~ ,'=~ , - ._-~-= ~.... - ~ -" '"''''''' ..~ .- No. Term. 19 _ vs. PRAECIPE Filed 19_ , Atly. Jr' ~ ~ ~ ,,'. . Jihi:J , '"' - ~ .. ROSEMARY CRUZ and, RONALD P. PRIEST, Plaintiffs : IN THE COURT OF CXlMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . . . vs. : NO. 00-2775 CIVIL TERM : I;>ANIELLE TUCCI, Defendant . . CIVIL ACTION - LAW IN CUSTODY : CUSTODY <nlCILIATICN SUMMARY REPCRr IN Acx:nIDANCE WITH CUMBERLAND COON'J.'l!' RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. subjects The pertinent information concerning the Children who are the "" of this litigation is as follows: NAME DATE OF BIRTH aJRRENTLY IN CUSTODY OF Natalie Renee Persing Tyler Joseph Persing July 22, 1999 January 17, 1997 Mother Mother 2. A Conciliation Conference was held on July 18, 2000, with the following individuals in attendance: The paternal Grandparents, Rosemary Cruz and Ronald Priest, with their counsel, Diane M. Rupich, Esquire, and the Mother, Danielle Tucci, with her counsel, Joseph J. Dixon, Esquire. 3. After reading a statement on behalf of the paternal Grandparents, Plaintiffs I counsel advised that the Grandparents I Complaint for Partial Custody was being withdrawn. The parties were encouraged to resolve the conflicts concerning the Children with the assistance of counseling or mediation if necessary. 4. As the Plaintiffs are withdrawing their Complaint, no further action is necessary. L. I.. I CJ" ~) Da~ Dawn S. Sunday, Esquire Custody Conciliator cc: Diane M. Rupich, Esquire - Counsel for Plaintiffs Joseph J. Dixon, Esquire - Counsel for Mother o \/" <\ }"'~