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Home My WebLink About00-03087 ',I!';" 'd' .,',. ",' ';;.", , MICHAEL J. BRONCHIK, JR, PLAINTIFF V, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA BERNADETTE A. STONE DEFENDANT 2000-3087 CIVIL ACTION LAW IN CUSTODY GUY W, STONE, ADDITIONAL DEFENDANT: ORDER OF COURT AND NOW, this 23rd day of May ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear beforeHubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberlaud Couuty Courthouse, Carlisle on the 17th day of August , 2000, at 9:30 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, FOR THE COURT, By: Isl Hubert X. Gilroy. 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 TillS PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO NOT HA VB 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 . . , '"'" , "'-I > -~ ~".~ '. ',~-,-~~,,~-'-'- '/.. " '~,',,~ , -,"-, , _ . FllED"""FICE 0" T"~ l)i"'~ I d'IT; ."!-;UIHONOTAAY 00 MAY 30 PH 2: 28 CUMe~8UWD COUNTY PENNSYLvANIA 5;30OC M- ~ Ht~ ~ 4 ~ 530'&~ Y/~ ~$1I{~adf/~ 6-30.00 ~~ ~ #.~~- , ,- ,'. ' ~ ~- "'" ,~~ " , "___. --~7_, ""_,, ~: _ >, ':J! ._,,,,~w.'l!_~._ l,.,,,,,,,,,,,.,...,ttif'~ > ~" :,:"~,, -~!' ~"';;"1''''"'''"'1. -""'" "' 11.1" ~' r, '" ~-, ,," _, ,_L',_. . '__ _ '~ _,";"" _" , " -',:''''',;_::,.;, I " MICHAEL J, BRONCHIK, JR., Plaintiff, vs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 2000- 30t>7 BERNADETTE A. STONE, Defendant. IN CUSTODY vs, GUY W. STONE, Additional Defendant. ORDER OF COURT AND NOW, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before , Esquire, the Conciliator, on the day of , 2000, at o'clock .m" in , Cumberland County, Pennsylvania, 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 shall also be present at the Conference, Failure to appear at the Conference may provide grounds for the entry of a Temporary or Permanent Order, FOR THE COURT, By Custody Conciliator Date: 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 JI .~ , " '-,_ ~ 'C' ,,- ;,;~, - -_ ~,,~id fj ;~ t:j '" AMERICANS WITH DISABILITIES ACT OF 1990 '['I ; .i ~ " ~ ~f Ii 11 lj i;i F 11 11,,1 " , The Court of Common Pleas of Cumberland County, Pennsylvania, 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 our office, All arrangements must be made at least 72 hours prior to any hearing or business before the Court. BY THE COURT: Date: J, II "~ .. , ;,' -- ,',';<;-'~ '-,--..--'n,;,,-, -- ~ --Ii;',; " J . J " MICHAEL J, BRONCHIK, JR., Plaintiff, vs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 2000 - 36 f7 ~ T-,,-,--- BERNADETTE A. STONE, Defendant. IN CUSTODY vs, GUY W. STONE, Additional Defendant. COMPLAINT FOR CUSTODY 1, The Plaintiff is MICHAEL J. BRONCHIK, JR., residing at 102 Ian Drive, Mt. Holly Springs, Cumberland County, Pennsylvania. 2, The Defendants are BERNADETTE A. STONE, residing at 1112 Dorchester Avenue, Woodlawn, Maryland, and GUY W. STONE, 3926 Banks Road #1, Cincinnati, Ohio, 3. The Plaintiff seeks custody of the following child, KRYSTAL A. STONE, aged 15 years, who resides weekends with BERNADETTE A. STONE and JOE ELlZONDA at 1112 Dorchester Avenue, Woodlawn, Maryland, and weekdays with SHIRLEY BERGER, at 103-L Governor Court, Glen Burnie, Maryland. The child was not born out of wedlock, The child is presently in the custody of BERNADETTE A. STONE, who resides at 1112 Dorchester Avenue, Woodlawn, Maryland, .... Of,,"!:,,-,' ^ ,,^-- ,,' <,--", "' ~ ~o,-' .. ,,~, ' ., -- , ~ -" ~:f, During the past five years, the child has resided with MICHAEL J. BRONCHIK, JR. and BERNADETTE A. STONE, at the following addresses: June 1995 to October 1995: Traveling, with a mailing address of 102 Ian Drive, Mt. Holly Springs, PA 17065 October 1995 to September 1996: Main Street, Newville, PA 17011 September 1996 to June 1997: One South High Street, Newville, PA 17241 June 1997 to November 1998: Traveling, with a mailing address of 102 Ian Drive, Mt. Holly Springs, PA 17065 December 1998 to January 1999: 2820 Hinsdale Drive, Baltimore, Maryland 21230 January 1999 to September 1999: 3026 Mallview Avenue, Baltimore, Maryland 21230 September 1999 to April 4, 2000: 41 Miller's Gap Road, Enola, PA 17025 The mother of the child is BERNADETTE A. STONE, currently residing at 1112 Dorchester Avenue, Woodlawn, Maryland, She is single, The father of the child is GUY W. STONE, currently residing at 3926 Banks Road #1, Cincinnati, Ohio. He is single, 4, The relationship of the Plaintiff to the child is that of one who has stood in loco parentis, The Plaintiff currently resides with CATHY M. BRONCHIK, his wife, and MICHAELJ. BRONCHIK, III, his son, - -~~ ~I ,_',_ [' ~, __, C_, -,-,~ _0 , -'I I 5, The relationship of the Defendant BERNADETTE A. STONE to the child is that of Mother, The Defendant currently resides with JOE ELlZONDA, her boyfriend. 6, The relationship of the Defendant GUY W. STONE to the child is that of Father. The Defendant currently resides,with GINGER (last name unknown), his girlfriend, 7. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation concerning the custody of the child in this or another jurisdiction, 8, The Plaintiff has no information of a custody proceeding concerning the child pending in a court of the Commonwealth, 9, The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child, 10. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) The Plaintiff can best provide for the physical and emotional needs of the child, b) Defendant Mother left her children, without arranging for their care, before taking up residence with her new boyfriend, whom she met through the Internet. c) Defendant Mother has never provided a stable home for her daughter, d) Defendant Father has a history of drug use and has not been involved in his daughter's life during the past five years, L"_ .- - ~ ' " 1iiiYiili1",,-j j , I I " I I I I I I , I I I ~ rJ I " ~ e) Plaintiff, with Defendant Mother's consent, assumed the status and performed the obligations of a parent to the subject child, KRYSTAL A. STONE, during the past five years, f) The subject child, KRYSTAL A. STONE, expresses a preference .to live with Plaintiff MICHAEL J. BRONCHIK, JR. and his wife, KATHY M. BRONCHIK, and their son, MICHAEL J. BRONCHIK, m. 10. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action, WHEREFORE, the Plaintiff requests this Court to grant primary physical custody of the child to the Plaintiff. Respectfully submitted, FLOWER, FLOWER & LINDSAY Attorneys for Plaintiff By ~ Thomas E. Flower, ""- 11 East High Street Carlisle, PA 17013 (717) 243-5513 1.0, No, 83993 Date:_f't ~ 2-enrtJ -, -.<"-.. ,--'. " , n_'. '_,' \ _,' - ~~ii :j :, . 'I Ii I . ,I , ?/&.~tJA- Michae . onchik, ' I j I I il 'I I II il " " Ii Ii Ii ,. .. II I' I ;1 I :1 , I I I , I I I I I I I VERIFICATION I, MICHAEL J. BRONCHIK, JR., the, undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C,S, 9 4904, relating to unsworn falsification to authorities, Date: S II f/t;(} ..ru' " ,r~ :-C 0i""" \j~ ,,~ ~,~q~,~""""--,, ^. '~"'-'",- --<c.' ,~ . ~~iII'" , "Iimti_IlJili.'" ~""",' "~ "~. + " fIT ," ...., ,,--' """-"'Cd< ,." o ?f i~ ~ :::>.C~ :e. C.l L. Z -' -< , ~,--~. ..'" '" '" l! o Cl o -n ~. --.... :'o~ .-1 ~1~;JJ ,'"- :gr~n' :~~ ;~;- T-H.i ~ii a"" -< ]'V ;E: .-.l,;i"-~ -< (~ v ;i:> .. j . ~ ... -<: ~ v, :r> -J: v- a 'C 0 d g d t t r ~ 1 -.. - ~ ", .' -"-""- ;. '", ;. ~,; ~-"Y."", - f ' . ",-"" ~,-, -,- ;,,' _" ,'- ~ ,,;,.-~,,.., ,,) oJ",~ >".-'(,~- '. -'""",- ",'," ~ ;[ _ 0 ." "~;: AUG 2 4_fJIJ MICHAEL 1. BRONCHIK, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW BERNADETTE A. STONE, Defendant NO. 2000 - 3087 CIVIL IN CUSTODY COURT ORDER AND NOW, this;>'{ 9' day of August, 2000, the Conciliator being advised that the above case has been handled through custody litigation in Maryland and the Plaintiff desires to withdraw the action, the Conciliator relinquishes jurisdiction. BY THE COURT, aU- ,.,"'" ~. :9liliIiIIIIl!I!iilb. <~~!lIi_~Jrb':1i!i!lll.~" Tt.......-''''''''''...~1Je#l!l!IrMl!tI~~_ ~ 11IIII -'=" .=., , o;;~.;.. ~v_ ~ ,,( r~.-~~ .~ ',,"" .' h, ~~ - () C) Cl C 0 " -.-.:-:. ::::~ -j -OCU ~:: -':-:; :!J rniT'. G') '....- Z:::} r<~ ~rT1 ~r:;,- ;~l6. (J,/.!__.. (.1'. -<.c, ~c> ~.".. ;~~ >C' ::2': bO 9 --ITl )>c 9 ~ .w ~ ~~~