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Home My WebLink About01-0841 FX ,'- ,,, -,_ 'c-,>,_ .- - ., ~,-,,-':;--I .- --"-.,--"..,-~- -',' ""-0 ',.d->. ._ ,-"'G-<-"i"_,--,~",~_ ~_ ') ~_~ PATRICIA K. COBURN, Plaintiff v. ~ ~ ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, P A NO. tJl-~LfI 200./ CIVIL TERM MAX GONZALEZ, Defendant CIVIL ACTION - CHILD CUSTODY ORDER OF COURT YOU, Max Gonzalez, Defendant, have been sued in court to OBTAIN custody of the children: Jordan Gonzalez and Jaylen Gonzalez. YOU are ordered to appear in person at (Address) , on (Day and Date) (Time) , _.M., for: L a conciliation or mediation conference. a pretrial conference. a hearing before the court. at If you fail to appear as provided by this order, an order for custody may be entered against you or the court may issue a warrant for your arrest, yOU SHOULD TAKE THIS PAPER TO YOUR LA WYERAT 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 717-249-3166 --~ . ,_ .. h' ""~' "- _ _: ~~, ^-" ~)W_ 4 PATRICIA K. COBURN, Plaintiff v. ~ ~ ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, P A NO. 01- l''I1 200( CIVIL TERM MAX GONZALEZ, Defendant CIVIL ACTION - CHILD CUSTODY CUSTODY COMPLAINT AND NOW, comes the Plaintiff, Patricia K. Coburn, by her attorney, Roger R. Laguna, Jr., and represents as follows: 1. Plaintiff, Patricia K. Coburn, resides at 2021 Arlington Street, Camp Hill, Cumberland County, Pennsylvania 170 II. 2. Defendant, Max Gonzalez, lives at an undisclosed location in Steelton with a "friend", but receives mail at his mother's house at 1610 Hunter Street, Harrisburg, Pennsylvania, 17104. 3. The parties are the natural parents of the following two (2) minor children: Jordan Gonzalez, born 2/9/96, and Jaylen Gonzalez, born 5/14/99. 4. Since birth, the children have resided with the following persons at the following addresses: Name Address Date With Plaintiff only 2021 Arlington St. Camp Hill, P A August 25th - Present With both parties 2021 Arlington St. Camp Hill, P A February 99 - August 25th ..1."" - -=--' "-.-.,,' '- J ,"nh'" ~- - ~-"-' -----'] f With both parties 40 West Green St. Mechanicsburg, P A August 97 - February 99 With Plaintiff only 2907 Derry St. Harrisburg, P A August 96 - August 97 5. The Plaintiff currently lives alone. 6. The Defendant currently resides with the an unidentified "friend". 7. The best interest and permanent welfare of the children will be served by granting the relief requested. The quality of the child's physical, intellectual, moral, and spiritual environment would be improved by Plaintiffs proposed custody and supervision. Date: WHEREFORE, Plaintiff requests the Court to grant her !J;tOdY of the children. /1 1\ ,/ f ! . , i \ 1 R4spectfully sub~~ted, I 'if 1 II , A \ ~.; By:~ l oger R. Laguna: . r., Esquire Supreme Court I. No.: 75900 Attorney for Plainti f 2//( /CT( I ! ..",_n..'''";~_'''U''_.'_' ' LAGUNA REYES MALONEY, LLP IS North Front Street, Suite 203 Steelton,PA 17113 (717) 939-4429 - - ~ , ~ J'~ . ' ~"'1"l~l&l\;Ij),j-,,-; VERIFICATION I verifY that the statements made in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein may subject me to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. "0' _--, _~__'o,"-''', L _, ,. o'-c " "0" ".,,-, .-" .~J'-~-i PATRICIA K. COBURN, Plaintiff v. ~ ~ ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLANDCOUNT~PA NO. 2000 CIVIL TERM MAX GONZALEZ, Defendant CIVIL ACTION - CHILD CUSTODY CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I served a certified copy of the Custody Complaint filed in the above-captioned matter upon the Defendant, by certified mail, return receipt requested on d - 1.;( -0 \ , addressed to: Max Gonzalez 1610 Hunter Street Harrisburg, P A 17104 Date: l. / I <- /0 ( I I , f) / ~ j ( Resp ctfully sutitted, \ ( /\ ~10 ger R. Lagun~,\Jr., Esquire Supreme Court 1.11>. No.: 75900 ~!!;~!:ilil;l;'~WJ!illii'1il',M!illI:w,.'ml'l,,,,~>il~~@j;~m-'i,->!,"';~,!J&liblid..WF~'l<!HJHi.illi%<J!l!'~iu\li)o~_tlm)lll;~~~'-~ ~;';"",~~~~I'!l"~ rIi' " ~ 1_ ~ ~ ~ ~ C) C~) ", C '~---'h ~ ~ (~ ," .." -r,; :-": '"J dJr<"; r"1 0,\ ~ ,\ z:: .:' G-] - W 2i-"- ~ \\1 \A, C/~ ):;.-: f,) -..J "- X\1 -, r- ~ 'l\ -:;::;: ~-":' --J '- \ ~~~ -:,. W ,~ '::' () :::; ::; . :=2 ::0 ~ ~ -< ~ "- >l_, . '~ " .,. . .,~ ".~-' ~~ .. l " ,0 PATRICIAK. COBURN PLAINTIFF V. MAX GONZALEZ DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-841 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 14th day of Fehruary, 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawu S. Sunday, Esq. , the conciliat at 39WestMainStreet,Mechanicshurg,PA 17055 on the 27thdayofFehruary ,2001, at 3:00 p.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 defme 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 Dawn S. Sunda s 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 an'angements 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 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 11. ';;-;5-t:J1 Ol. /S~I -:2/S'-f)/ - OF ~<: 0', ~~., r",,' l'~ D'-, 'J. !:)Q I.. - ;,.; i: ~ ,) . t ",,' ! 1 I ~_:..; ,." . "", r...."llo"Y CU~tlb~"\-'<'":'1 1'__~,:,'.1,; \_/,,,h._I~ i I ~, 1-" ,.., ..... PENNS'Il\!i\NIA f!uI ~ Jet~ ~ 4' ~ ~~g,~. /~ A4~ "# aJf ~:fr f: ~ I i; I' i i II Ii , Ii II 1 , il Ii , I I ~ 'I 11 " "1._- ~~.......",J: _ -~~~, _1,illml~I$le~~~~~~'!'!!f1"""~'plflJ:l>,,,,!,,'j\I;~11hW,B'~"qc'q"'~~f!;ffi1,!&;.",-,*"",,~rnr;~.~;'ff"''1'~f1L:;~;CIi!;f';l'''4''Fa~~~!~~ , ' -1- ,.-~ ^ ,",^ :,"'....".~. !'->":'''" ~"" , . nBl1lil~!!i-l!!'i~ c PATRICIA K. OOBURN , . IN THE OOURT OF OOMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . NO. Ol-84l CIVIL TERM . : MAX GONZALEZ, : CIVIL ACTION - LAW Defendant : IN CUSTODY aIDER OF <XXlRT AND NCIIT, this 11ft! day of 7J1~ consideration of the attached Custody Concili ion and directed as follows: , 200l, upon Report, it is ordered 1. The Mother, patricia K. Coburn, and the Father, Max Gonzalez, shall have shared legal custody of Jordan Gonzalez, born February 9, 1996, and Jaylen Gonzalez, born May l4, 1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 2. The Mother shall have primary physical custody of the Children. 3. The Father shall have partial physical custody of the Children on alternating weekends from Friday at 6:00 p.m. through Sunday at 7:00 p.m. The parties shall strictly adhere to the exchange times stated in this Order unless agreed otherwise in advance. 4. The parties shall share having holidays as arranged by agreement. custody of the Children on 5. Each party shall ensure that the other party has his or her current address and residential telephone number. 6. consent. control. The parties may modify the provisions of this Order by mutual In the absence of mutual consent, the terms of this Order shall cc: Roger R. Laguna, Jr., Esquire - Counsel for Mother Max Gonzalez, Esquire, Father !tI;'"""-""''''-~it~" "~~~~:ti1'il1il.~"iii1Wl~~;;:""iEn:'i'''-':i:!'\'ill<1ibikJf~'-siJ.!U'!-_,",,~~''>' '~:, '~ \;IiN\;I/\lASNN3d AlNrD:--i C,I'nii?PiNna LS :8 f' J ~.:d L t Aill~ 10 :~o !!" ~ ~"~ "" ~, ", -'"~ <~ -," ~-- .- LA "-lIi'"~''''''''~'d , , - ~~" ~-, -~-=':iiiil~ ~ . -W~~"._"""""" ~ . l i i il II II ;j !l , 'I I'! " I i " il ,I ! " " II il il :1 :i " 'I ! " I '1 '. ^ h"~' ,1_ ;;--, ,"-- ., ,,'.,.. ".."'J lfM' PATRICIA K. COBURN , : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 01-84l CIVIL TERM . . . MAX GONZALEZ, . CIVIL ACTION - LAW . Defendant . IN CUSTODY . CUS'lWY CXl.'lCILIATIOO SUMMARY REPmT IN ACCORDANCE WITH CUMBERLl\ND CXXlN'JY RULE OF CIVIL 1'KU;JSUURE 19l5.3-8, the undersigned Custody Conciliator submits the following report: l. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CllRREN'l'LY IN CUS'lWY OF Jordan Gonzalez Jaylen Gonzalez February 9, 1996 May l4, 1999 Mother Mother 2. A Conciliation Conference was initially scheduled for February 27, 200l in this matter. Although the Father was present at the time of the Conference, the Mother's counsel, Roger R. Laguna, Jr., Esquire, advised that he never received notice of the scheduling of the Conference from the Court and therefore neither he nor the Mother were present. Consequently, the Conference was rescheduled to May 3, 2001. The Mother, Patricia K. Coburn, and her counsel, Roger R. Laguna, Jr., Esquire, were present at the Conference. The Father, Max Gonzalez, agreed, by telephone, to the custody arrangements set forth in the proposed Order. 3. The parties agreed to entry of an Order in the form as attached. tn.~ Date I ~o(J I , rOtL-. j Je~~ Dawn S. Sunday, Esquire Custody Conciliator