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Home My WebLink About00-06137 -~ " " "'--,~. , - !'l;l'l...m,' RONALD L. BRUCE PLAINTIFF V. FLORINDA M. BRUCE DEFENDANT IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 00-6137 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 11th day of September ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. ,the conciliator, at 214 Senate Avenue, Suite 105, Camp HiD, PA 17011 on the 11th day of Octoher ,2000, at 10:00 a.m. 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 Melissa P. Greevy. Esq\ Custody Conciliator (/I The Court of Common Pleas of Cwnberland 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 THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE 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 " " ,. II !i 'I r. r [I, ~~,"11:: ...... ~ " ~." T'-'"- - - . "'" "'" (() <cr.,') I'.' ......... u:._.! 1 '-I ; J2: r~ 6 Ci ii",.j;.~'__ ", ", ,. UIVik:, "nl /.",J:; (\ ",; fr-I't..v' f-,c.:-' ~ " .....-' ,J',-)Ul\i -"t:I~NSYLVAi\J!J\ j C/-13.0tJ ~-(~ ~ ~ 4~- f-/.3.0C' ~ ~ Z~- ;'13'G?O~ ~ ~a#~ " 'liW'~""".",,,>,. ~< ..-""",..~~.!!\_''''~~e~'j:,'~n_-",;O:''~Va:w'IJilVll",,",,~'1!1~:W?.!''J:i-)J~0N'~''!'iic="""'t">l1ilfin~;;r;~ - " '< __,c"__'._.<- -- _-,,~_, oL,_,':;:-~ ..~--,::;.:~~~-" -", ,'1,;;;'_ ~,' -"p- ,-<", )t",- ,-',':"".; ~-: '-"'''0''-' fl\cust\lconcilr.ord SEP RONALD L. BRUCE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. ;IOOO -lu 13'1 FLORINDA M. BRUCE, Defendant CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this day of , 2000, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before the Conciliator, at on the , 2000, day of at ___.M., 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: Custody Conciliator 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, PA 17013 Telephone: (717) 249-3166 "'llii~ 82~~ - -' -~ <",' - - '""'-"-~' - ,- '-j J";, "--'---'-'" ~"",,--. -' ~' - ''[(Ii fJ\cust\~custdy.not RONALD L. BRUCE, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV~rIA NO. tltJ-(,I.3? ~ ~ FLORINDA M. BRUCE, Defendant CIVIL ACTION LAW IN CUSTODY NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following complaint, you must take action within twenty (20) days after the complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed against you and a judgment may be entered against you by the Court without further notice for any money claimed in the com- plaint or for any other claim or relief requested by the plaintiff. You may lose money or property, or other rights 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 .,-,,-' __ ,_'" ";:.'r"'" ',-,-- ,'0-"--- ,', _ '~ '-':'::",- ,;; :'~ ~";_:..;,-".:- '.> """"'II$;, f~\cust\h~ce.com\8-00 RONALD L. BRUCE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION CUSTODY FLORINDA M. BRUCE, Defendant NO. (}().&13'1~-r.u- COMPLAINT FOR CUSTODY 1. The plaintiff is RONALD L. BRUCE, an adult individual, residing at 47 West Main Street, New Kingstown, Cumberland County, Pennsylvania 17072. d.' ',__ , 2. The defendant is FLORINDA M. BRUCE, an adult individual, residing at 1590 Route 17K, Montgomery, New York 12549. 3. Plaintiff seeks shared legal custody and partial physical custody of LUIS L. BRUCE, who is one (1) year of age having been born on October 9, 1998, and CHRISTINA M. BRUCE, who is seven (7) years of age having been born on June 18, 1993. The children were not born out of wedlock. The children are presently in the custody of the defendant who resides at 1590 Route 17K, Montgomery, New York 12549. During the past five years, the children have resided with the following persons and at the following addresses: -1- 1 ..l , i - -, - . ---',--'-',-._,,'-.',- '"""' --,;-,-"",,.., ',,:. > NAME Ronald L. Bruce and Florinda M. Bruce ADDRESS 47 West Main Street New Kingstown, PA DATES Birth to June, 2000 Florinda M. Bruce 1590 Route 17K Montgomery, NY June, 2000 to present The mother of the children is the defendant, FLORINDA M. BRUCE, currently residing at 1590 Route 17K, Montgomery, New York 12549. She is married to the plaintiff. The father of the children is the plaintiff, RONALD L. BRUCE, currently residing at 47 West Main Street, New Kingstown, PA 17072. He is married to the defendant. 4. The relationship of plaintiff to the children is that of father. The plaintiff currently resides with the following persons: NAME RELATIONSHIP NONE 5. The relationship of defendant to the children is that of mother. The defendant currently resides with the following persons: NAME RELATIONSHIP Luis Estrada Carmela Estrada Luis L. Bruce Christina M. Bruce Father Mother Son Daughter -2- ......; ~ ". ..,' , .1,'." . '~-"'-'. - - - ""-I- --.' ~,,' <; , ~ilt.lij > 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth. 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. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because granting the relief requested will allow the children to have a continuing relationship with their father, who is able to provide them with a stable and caring environment. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the chil- dren have been named as parties to this action. WHEREFORE, plaintiff requests the court to grant custody of the children. , ) EKLETSKI, ESQUIRE Supreme Court I.D. #40486 414 Bridge Street, P.O. Box E New Cumberland, PA 17070 Telephone: (717) 774-7435 Attorneys for Plaintiff -3- ~ c c 1---- ~_d. ,. -_;00'" ' - "--::,,-'~>~<:J~- j~iIioi~ @l\cust\~-verifi VERIFICATION RONALD L. BRUCE, states that he is the Plaintiff named in the foregoing instrument and that he is acquainted with the facts set forth in the foregoing instrument; that the same are true and correct to the best of his knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.B.A. ~4904 relating to unsworn falsification to authorities. ~~J~ RONALD L. BRUCE Date: r 5 ,5"~ c9~IJ() ^"<, , .. .-, - "_"_"'-;_N"'-'~ '"',, i~~~:(,,_-' , '.""-'-'" - , , " ':';;':. ,-'--"'-" ,.~---,,;;: -;,.<'-~ ldillililt fl\div\lmailsrv.aff "" f - , -. RONALD L. BRUCE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-6137 CIVIL TERM FLORINDA M. BRUCE, Defendant CIVIL ACTION - CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA) ) ss: COUNTY OF CUMBERLAND ) I, GERALD J. SHEKLETSKI, of Stone LaFaver & Shekletski, attorneys for the plaintiff hereby certify that I served the Complaint for Custody in the above captioned matter on the defendant, Florinda M. Bruce, at 1590 Route 17K, Montgomery, NY 12549, by United States Certified Mail, postage prepaid, on September 14, 2000, as evidenced by the attached Certified Mail return receipts. ~~C . GERALD S EKLETSKI Attorney at Law SWORN TO AND SUBS~IBED befo~s 11- day of , 2000. / ~.'-A? ~ No y Public NOTARIAL SEAL KAYE R. LUCKEY, Notary Public ~ew CumberlandBoro. Cumberland Co Y Commission Expires March 27, 2001' ",~.,~ 'I, -" _.J>_ --'rI.~ J'_ - "Ai," -'-"0; , ~ .-~ ,- .. .'- c,c..~.,,<...,",. "',," .,. . '-,,-, \ ,b' "". ,., ."..,...~ .H ,. , - t 0 0 0 C c::> ''1 g: "" "'U\;P !"1 :::; rnlT~ -0 2::0 ~f,Jh1 2C \D ',-,}'-,'" (f) j...--' ~~: _;,~l t:' ,<Co ~...... ,-~- .. )>r"; ::fi ~:t ;; 20 5>c yr Om -I ~ N )0' W ~ l~ ,~" -., .' -,- , .-"~,--,' ." -~.... ,"," <"'-''''' ~ .', ,- .,'i'-, ~ . ... ..-'1 o tr o Postage ~, -~~'~ ~, '" 81 .", ~ . 0' "3.:::: ~~ ~H~ "v /,,- ,'~:': $1\1 ~ ~ ,]1 ~ "is. ~-c ~ ::i:a 8.~~g,E "- " ~~ 1::.8-5 " :a:;!a ~'Eo~ .;~~BilE "'C~"'C ID ~ 8- fai"-g-5Q)ID C'liO:-C E -5 ~ ~i -fa i'g g- -,(I)-t) Q) n~ 'E.'" ~ ""-. ~ Q) 1;) a; B B-,I:: ;!::: CD C iD (I)-g Cl)C:5~:21D 1D~ I)" ~.c: 1S.. 'V >. 'tU.s::: ..... !~i,:Eli:5~6 !IJ;U!ili!a ::. . . Certified .Fee I"- Ritwn A_eoelpt Fee CJ (Enc:fdi'Sement RequIred) C f1...;M1edpellvery Fee . d (End~rilent Required) .-........ &.... $ o nJ ru Name (PIIJBBIJ Ptlnt Clearly) (To be comp"18d_by mailer) m MrS. Florinda M. Bruce D"'" $iiQ;'-Aiii:iio:~-oi;iiirBOi-NO:..n.---------_...~~--~~~-----~--___._nu~..n_._.~____h tr l$~O . ... te 17K o ... ... .4'...-.............-.......-....-...............--......-...-.... l'- ~ '" .,. 1!1 '" ~ ',-,'':;;,-';.- ':""-,_~\" -',CO-""'-, ';,;.,.<:" ~,j~ Q 1'[ .- w . g ~'O: ~Ed o.i 6 Llla:d ODD 'iij 'iij 8.~~~ ~~ *-~ .~ i .~ ~ ~-'u 0:_-= clll!!lDD .; m " l\i .<: e o. ::;. .. &l m 0 ~ ;, " 9~ 0 III ~ N ., ;;- ~ ! ~ .~ " " '0 ~ 1'[ '0 i .. a: ~ a: oi E " li a: 0 'ii 0 E 8 M lri :~;: .,;;.'0 m''''' lEE '" ~J::> '" '" ~ ~ >- :; :_-&;O ..., '1,.._,,~. ~-e ~ , . "~ ~ <Xl "'.<Xl '" '. E }Q 0'\ ~:G\ ,E .i(C (~.'" (/) ... .-1 '0 lD.r-1 Q.) ~ .. .p e 6 :;l '0,,",.0 iI '" p: o :g ':0 "Ill'" <~ I1'l ...:""'-''"'"'" ,~. ~ j,- "" ,,"-' , t-""'..~ J ";:~Jliiil. ~"-> '~ .<.~;- .~ 1 I I ! () c:; c c:; ~ ~') :-0 f::n ", ""1, n-'r-'_ -0 Z-+i ~.- Zf" :~~;~ (l),,~ >..0 ;::E<- 0 ~ ~'f) :'~ ~T;; ~~ ~R ZO ....,It;,,. :$>0 SJ """"ri! c: () , ~ -., I'\) :> :l:3 eN -< '" RONALD L. BRUCE, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 00-6137 Civil Action - Law FLORINDA M. BRUCE, Defendant. In Custody ORDER OF COURT .', '-. '.... -~,' .......... NOV 2 2 20~ AND NOW, this 20th day of November, 2000, the Conciliator, being advised by Plaintiff's counsel that the pprties have reached an agreement, hereby relinquishes jurisdiction in this case. Melissa Peel Greevy, Esquire Custody Conciliator ~. {" \:0 \ t~" '~. \:- , l. ;'i J '.:";3,:.':10' "~o'J~~~,-,>",.-.,"W"~.rt" ,~~"~~--~_.,,, ., ~,~ }!f t l ;,\1 $ i' 'C' ,-- < .~ ,.." ~'. ~., ' - ~'"" 'IIlr o c Z -0'\:)_' f\:P'"; Z~:;C, '.2<:: ~2. .~~~' l.2C ~'t~) )-::--C. ~ " c> o -."'" ~;i~ ~, CO 7':':" -~ --:.'~ !I , ,) ;::;-, \,9 " ....l .-: :~ :.( ~