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COUNT' OF COOK
STATE OF ILLINOIS
OFFICE OF THE COUNTY CLERK zn,
CERTIFICATION OF MARRIAGE
LICENSE NUMBER: 9926648-0
BETEEN
GROOM'S NAME: GUSTAVO W GUTIERREZ MUNOZ
AGE: 26
A
BRIDE'S NAME: HAYDEE N D AGE: 28 FIGUEROA
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DATE OF MARRIAGE: SEPTEMBER 03, 1999
WERE UNITED IN MARRIAGE IN THE COUNTY OF COOK, AND STATE OF ILLINOIS`
I N A
CIVIL CEREMONY
NAME: GEORGE W. COLE B Y
OFFICIATE TITLE: JUDGE
A T
PLACE OF MARRIAGE: CHICAGO, ILLINOIS
DATE RECORDED: SEPTEMBER 03, 1999
APPLICATION DATE: SEPTEMBER 02, 1999-
This is to Certify that this 'IS a -trueend correct abstract from the official record r
Q173443 6 '°ad with the efflee of the Cook County Clerk.
O,r ISSJED AT: COUNTY LI
C CHICAGO. ILLINOIS 60602- qOx ff' LLIaL? aJ///11LaQaLL[rrr q?N// rx'` f1r..
p DAVID D. ORR 11/12/1999 12 43 COUNTY CLERK Thls copy Is not veiitl unloas displaying .. om0ossetl seals of Caok Cauntr and Countv Clerk aia nature cur
pj [G>;p W 126 STATE
c7?--7".; "? .. HARRISBURG
'ATTORNEY AT.'LAW ;?
JUAN A. PEREZ, IN THE COURT OF COMMON PLEAS
Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. qq - `7 oZU L
HAYDEE FIGUEROA
Defendant CUSTODY
ORDER OF COURT
AND NOW, upon consideration of the attached Petition, it is hereby directed that the
parties an their respective counsel appear before Qp?c 1 S 24, , the
Conciliator, on the 1-day of bLC 1999/--1994, at1 OU p. m., at
' T Q } PA for a Pre-Heating Custody Conference. At
such Conference, an effort will be madthe issues in dispute; or if this cannot be
accomplished, to define and narrow the issues and 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,
Date of Order-21:1. {99 By: r Cl>J -sA. ?3I11C1na?- C d2
Custody Conciliator" --)
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YO 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
4"' FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 240 6200
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JUAN A. PEREZ, IN THE COURT OF COMMON PLEAS
Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. C/ ri.
CIVIL ACTION-LAW
HAYDEE FIGUEROA, CUSTODY
Respondent
PETITION FOR CUSTODY
AND NOW, this _ day of _t t l" 1999, comes the Petitioner Juan A. Perez
by and through his attomey oseph J. Dixon, Esquire who respectfully requests a Hearing
scheduled concerning the custody of his children.
1. Your Petitioner is Juan A. Perez, an adult individual who resides at 1395
Grandview Court, Carlisle, Cumberland County, Pennsylvania 17113.
2. The respondent is Haydee Figueroa, an adult individual who now resides at 5526
W. 26's Street, Apt. 4, Cicero, Illinois 60804-3300.
3. Your Petitioner and Respondent are natural Father and Mother of two (2) minor
children: Elizabeth Marie Perez born August 11, 1991 and Juan A. Perez, Jr. born
July 7, 1993.
4. The Petitioner and Respondent have resided at their home at 1395 Grandview
Court in Carlisle, Cumberland County, Pennsylvania from April 1, 1999 through
November 5, 1999.
5. The Petitioner, Juan A. Perez still resides at that location with his son Jordan
Bany Perez, age 10 years old.
6. There has been no prior custody action in this or any other jurisdiction.
Your Petitioner believes and therefore avers that he can provide a good and
proper home environment for the minor children Elizabeth Marie Perez and Juan
A. Perez, Jr..
Your Petitioner believes and therefore avers that it is in the minor children's
interest to be reunited with their Father and Brother at their home at 1395
Grandview Court, Carlisle, Cumberland County, Pennsylvania.
9. Your Petitioner believes and therefore avers that as of the date of this Petition, the
Respondent has not enrolled the children in a school in Cicero, Illinois.
10. Your Petitioner believes and therefore avers that the Respondents move from
their home on November 5, 1999 without any notice to himself created a
substantial hardship upon the minor children.
1 I. Your Petitioner believes and therefore avers that the sudden move from the
family home has significantly disrupted the children's education in the third and
first grade at Hamilton Elementary School in Carlisle Pennsylvania.
12. Your Petitioner believes and therefore avers that the respondent is currently
residing with a boyfriend she met through the Internet in Cicero Illinois.
13. Your Petitioner believes and therefore avers that the Respondent is not providing
a good and proper home environment for the children.
14. Since birth, the children have resided at the following addresses:
181 201 Avenue, Patterson, New Jersey from 1991 through 1993. The parties the
resided at 21 South 19'h Street, in Harrisburg, Dauphin County, Pennsylvania
from 1993 through 1997. The parties resided at 2639 North 61 Street in
Harrisburg, Dauphin County, Pennsylvania from 1997 trough April of 1999.
15. Your Petitioner believes and therefore avers that the Pennsylvania courts in the
Court of Common Pleas of Cumberland County has Jurisdiction over the minor
children.
WHEREFORE, Your Petitioner prays this Honorable Court enter a court order granting
custody of the minor children to the Petitioner.
Respectfully submitted,
By:
.10 PH J. DIXON, ESQUIRE
126 STATE STREET
HARRISBURG, PA 17101
717-236-8515
ATTORNEY FOR THE PETITIONER
DATE:;/ ``i? 'l
VERIFICATION
I verify that the statements made in this -66)}r
are true and correct. I understand that false
statements herein are made subject to the penalty of 18 Pa. C.S.
54904, relating to unsworn falsification to authorities.
DATED:
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JUAN A. PEREZ, : IN'rHE COURT OF COMMON PLEAS OF
Petitioner . CUMBERLAND COUNTY, PENNSYLVANIA
Vs. 99-7207 CIVIL
CIVIL ACTION - LAW
FIAYDEE FIGUEROA,
Respondent CUSTODY
IN RE: PETITION FOR EMERGENCY RELIEF
ORDER
AND NOW, this 2 t4p day of December, 1999, a brief hearing on the within
petition for emergency relief is set for Thursday, December 16, 1999, at 3:30 p.m. in Courtroom
Number 4, Cumberland County Courthouse, Carlisle, PA.
Joseph J. Dixon, Esquire
For the Petitioner
Haydee Figueroa
5526 W. 26'h Street
Apt. 4
Cicero, IL 60804-330
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BY THE COURT,
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JUAN A. PEREZ,
Petitioner
V.
HAYDEE FIGUEROA
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 9c - 'MV 7 ?
CUSTODY
ORDER OF COURT
AND NOW, this day of , upon consideration of the Petition for
Emergency Relief it is hereby ordered and decreed that the minor children Elizabeth Marie Perez
and Juan A. Perez, Jr. be returned to the custody of their Father Juan A. Perez. It is further
ordered that the Respondent Haydee Figueroa shall have an opportunity to have a Hearing on the
issue of custody at a Custody Heating scheduled in the Court of Common Pleas of Cumberland
County in Carlisle, Pennsylvania.
Date:
By:
J.
JUAN A. PEREZ, IN THE COURT OF COMMON PLEAS
Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2 9- 7J u r ?? ?( ?.?
V. CIVIL ACTION-LAW
HAYDEE FIGUEROA, CUSTODY
Respondent
PETITION FOR PENN PENNSYLVANIA RULES OF CIVIL PROCEDURE 1915.13 OF THE
AND NOW, this 24' day of November 1999 comes the Petitioner Juan A. Perez by and
through his Attorney, Joseph J. Dixon, Esquire who respectfully avers as follows:
1. Your Petitioner is Juan A. Perez, an adult individual who resides at 1395 Grandview Court,
Carlisle, Cumberland County, Pennsylvania 17113.
2. The Respondent is Haydee Figueroa, an adult individual whose last known address is 1395
Grandview Court, Carlisle, Cumberland County, Pennsylvania 17113.
3. Your Petitioner and Respondent are natural Father and Mother of two (2) minor children,
Elizabeth Marie Perez, born August 11, 1991 and Jaun A. Perez, Jr., born July 7, 1993.
4. The Petitioner and Respondent have resided at their home at 1395 Grandview Court in
Carlisle, Pennsylvania from April 1, 1999 through the present.
5. On November 5, 1999, the Respondent without any notice to your Petitioner, moved out of
the residence at 1395 Grandview Court and took the parities two (2) minor children with her.
6. The Petitioner at the time the Respondent left the home did not know exactly where she was
going. It was his understanding she was going to Chicago, Illinois. You" Petitioner has
recently found out that she is residing with a boyfriend she met through the Internet whose
residence is, 5526 W. 2611 Street, Apartment 4, Cicero, Illinois 60804-3300.
7. The Petitioner believes and therefore avers it is not in the best interest of his two (2) minor
children to be moved to an unknown location in Chicago, Illinois.
8, Your Petitioner believes and therefore avers that he could provide a good and proper home
environment for his children.
9. Your Petitioner believes and therefore avers that the childrens' education in third and first
grade at Hamilton Elementary School in Carlisle, has been seriously disrupted by the move
made by the Respondent.
10. Your Petitioner believes and therefore avers that the Respondent is moving to Chicago,
Illinois to be with a boyfriend she met through the Internet.
11. Your Petitioner believes and therefore avers that the Respondent will not have a good and
proper home environment for the minor children.
12. Since birth, the children have resided at the following addresses:
181201 Avenue, Patterson, New Jersey from 1991 through 1993. The parties then resided at
21 South 19' Street, in Harrisburg, Dauphin County, Pennsylvania from 1993 through 1997.
13. The parties resided at 2639 North 6" Street in Harrisburg, Dauphin County, Pennsylvania
from 1997 through April of 1999.
14. Your Petitioner believes and therefore avers that the Pennsylvania Courts in the Court of
Common Pleas of Cumberland County has jurisdiction over the minor children at this time.
WHEREFORE, Your Petitioner prays this Honorable Court enters a Court Order
retuming the children to the Petitioner until a full custody hearing can be held on this matter.
Respectfully submitted,
By: 1
SEP DIX N, ESQUIRE
126 STATE STREET
HARRISBURG, PA 17101
717-236-8515
ATTORNEY FOR THE PETITIONER
DATE:
VERIFICATION
M t,t 9?"4v c?/
y? I verify that the statements made in this
I& b 4/ 42A) -- are true and correct. I understand that false
statements herein are made subject to the penalty of 18 Pa. C.S.
§4904, relating to unsworn falsification to authorities.
DATED:
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JUAN A. PEREZ,
Plaintiff
V.
HAYDEE FIGUEROA,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99-7207 CIVIL TERM
IN RE: PETITION FOR EMERGENCY RELIEF
ORDER OF COURT
AND NOW, this 16th day of December, 1999, after
hearing, the petition for emergency relief is granted in
part, in that while temporary physical custody is confirmed
in the mother it is ordered and directed that the children
be returned to the father for the Christmas school vacation.
By the Court,
Joseph J. Dixon, Esquire
For the Plaintiff
James Kayer, Esquire
For the Defendant
ri A. Hess,/ J. ,
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/7-99
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JUAN A. PEREZ,
VS.
PLAINTIFF,
HAYDEE FIGUEROA,
DEFENDANT,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 99-7207
IN CUSTODY
ORDER OF COURT
AND NOW, this 15th day of December, 1999, the Conciliator, hereby
relinquishes jurisdiction in this case based on the fact that the
Defendant/Mother did not appear for the Custody Conciliation Conference
scheduled on this date and Plaintiff's counsel indicated that the Mother
probably did not receive notice of the Conference. The Conciliator was
advised that a Hearing is scheduled on the Father's Petition for Emergency
Relief before The Honorable Kevin A. Hess on December 16, 1999.
FOR THE COURT,
Dawn S. Sunday, Esquire
Custody Conciliator
i SHERIFF'S RETURN - U.S. CERTIFIED MAIL
CASE NO: 1999-07207 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PEREZ JUAN A
VS.
FIGUEROA HAYDEE
R. THOMAS KLINE Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according to law,
served the within named RESPONDANT, FIGUEROA HAYDEE
by United States Certified Mail postage prepaid, on the 8th day of
December 1999 , at 8:00 HOURS, at 5526 WEST 26TH STREET
APT 4
CICERO,_ IL 60804-3300
a true and attested copy of the attached PETITION FOR EMERGENCY RELIEF
The returned receipt card was signed by HAYDEE FIGUEROA
on 12/13/1999.
Sheriff's Costs: S
Docketing 18.00
Cert Mail 3,99
Affidavit .00
Surcharge 8.00
$Z9-4T'JOSEPH
12/16/1
Sworn anj subscrib to before me
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or 2 for additional services.
and 4b.
ldmss on the reverso of this form so that we can return this
front of the mailpieae, or on the back it space does not
Haydee Figueroa
5526 West 26th St
Apt. 4
Cicero, I11 60804
PS Form 3811, December 1994
I also wish to receive the
following services (for an
extra fee)'
1. ? Addressee's Address Z ,
2. ? Restricted Delivery m
Consult postmaster for fee. !
4a. Article Number
bag
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4b. Service Type
II Certified 3
? Registered insured c '
? Express Mail
? Return Receipt for Merchandise ? COD
7. Date of Delivery
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8. Addressee' Addres oral
it requesfed T t
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and fee is paid) i
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1x2595.98 13-0229 Domestic Return Receipt i
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JUAN A. PEREZ, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS.
HAYDEE FIGUEROA,
Defendant
NO. 99-7207 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 13' day of 2000, upon
consideration of the attached Custody Conci iatio Report, it is ordered
and directed as follows:
1. The Father, Juan A. Perez, and the Mother, Haydee Figueroa, shall
have shared legal custody of Elizabeth Marie Perez, born August 11, 1991,
and Juan A. Perez, Jr., born July 7, 1993. 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. Pursuant to the terms of this paragraph, each
parent shall be entitled to all records and information pertaining to the
Children including, but not limited to, school and medical records and
information.
2. The Mother shall have primary physical custody of the Children.
3. The Father shall have partial physical custody of the Children
during any periods of time when the Children are not in school, including
the summer school break each year and school holiday breaks. The Father's
periods of custody during the summer school vacation shall end two weeks
prior to the beginning of the next school year. In addition, the Father
shall have custody of the Children at any time when the Father travels to
Illinois.
4. The parties shall share responsiblity for providing transportation
for exchanges of custody.
5. Each party shall ensure that the other party has his or her
current address and telephone number.
6. The Mother shall provide the Father with the school calendar for
the current year within 15 days of the date of this Order and shall provide
the Father with the school calendar for future years upon receipt from the
school district.
7. The parties agree that this Court shall retain jurisdiction over
this custody matter.
OF 10-
00 JAIN 13 AM I k 50 T
?U wSC?H? .U Ccui oY
PENINSY0,1MIA
8. This Order is entered pursuant to an agreement of the parties at a
Custody Conciliation Conference. The parties may modify the provisions of
this order by mutual consent. In the absence of mutual consent, the terms
of this Order shall control.
BY THE COURT,
cc: Joseph J. Dixon, Esquire - Counsel fp?r Father
James J. Kayer, Esquire - Counsel for Mother
11?164
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1-1.3-00
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JUAN A. PEREZ,
Plaintiff
VS.
HAYDEE FIGUEROA,
Defendant
PRIOR JUDGE: Kevin A. Hess
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7207 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the children who are the
subjects of this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Elizabeth Marie Perez August 11, 1991 Mother
Juan A. Perez, Jr. July 7, 1993 Mother
2. A Custody Conciliation Conference was held on December 30, 1999,
with the following individuals in attendance: The Father, Juan A. Perez,
with his counsel, Joseph J. Dixon, Esquire, and the Mother, Haydee
Figueroa, with her counsel, James J. Kayer, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
? 3-T-- Da S. Sunday, Esq ?
Date
Custody Conciliator