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Home My WebLink About07-2802Ivelisse Alemany- Martinez, Plaintiff v. Michael Vega- Castro, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. 0 `~ -1-~f0~ CIVIL IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Ivelisse Alemany- Martinez, residing at 5003 Muirfield Place, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The defendant is Michael Vega- Castro, residing at HCO1 Box 8644, San German, Puerto Rico, 00683. 3. Plaintiff seeks shazed custody of the following children: Name Present Residence DOB Age Christina M. Vega 5003 Muirfield Place 5-19-01 5 Years Mechanicsburg, Pa 17050 Mikayla A. Vega 5003 Muirfield Place 3-06-OS 2 Yeazs Mechanicsburg, Pa 17050 4. The children were born out of wedlock 5. The children aze presently in the custody of Ivelisse Alemany- Martinez, residing at 5003 Muirfield Place, Mechanicsburg, Cumberland County, Pennsylvania 17050. 6. During the past five years, the children have resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Michael Vega-Castro & San German, 2001-2003 Ivelisse Alemany- Martinez Puerto Rico 00683 7. 8. 9 Michael Vega-Castro & 2003 -2004 Ivelisse Alemany- Martinez Dominican Republic Ivelisse Alemany- Martinez 607B 13 Geneva Drive 2004-2006 Mechanicsburg, Pa 17055 Ivelisse Alemany- Martinez 5003 Muirfield Place 2006-present Mechanicsburg, Pa 17050. The mother of the children is Ivelisse Alemany- Martinez, residing at 5003 Muirfield Place, Mechanicsburg, Cumberland County, Pennsylvania 17050. She is married. The father of the children is Michael Vega- Castro, residing at HCO 1 Box 8644, San German, Puerto Rico, 00683. He is married. The relationship of plaintiff to the children is that of Mother. 10. The plaintiff currently resides with the following persons. Name Relationship Carl W. Hintz Boyfriend Christina M. Vega Daughter Mikayla A. Vega Daughter 11. The relationship of defendant to the children is that of Father. The defendant currently resides with the following persons. Name Relationship Samuel Vega Father Miguelina Castro Mother 12. 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 and claims to have custody or visitation rights with respect to the children. 13. The best interest and permanent welfare of the children will be served by granting the relief request because: Plaintiff has undertaken and performed the primary pazental responsibilities for the children. Plaintiff is best able to provide the care and nurture which the children need for a healthy development. A Court Order of custody and structured visitation is desired so that the Plaintiff and the children may plan their schedules accordingly, and so that misunderstandings and unmet expectations regazding custody and visitation can be avoided, and also so that the children are not used in a manipulative fashion. Plaintiff desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the children. A Court Ordered determination of custody is required to avoid continuing conflict between the parties regarding responsibility for custody and support. WHEREFORE, Plaintiff requests this Court primary custody of the children to Plaintiff subject to structured partial custody by the Defendant. Respectfully submitted, ROMINGER & ASSOCIATES r--- Date: 2 b~''- Michael O. Palermo, Jr., uire 155 South Hanover Street Cazlisle, PA 17013 (717) 241-6070 Supreme Court LD. # 93334 Attorney for Plaintiff Ivelisse Alemany- Martinez, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Michael Vega- Castro, No. CIVIL Defendant IN CUSTODY VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C. S_§ 4904 relating to unsworn falsification to authorities. ~,~11,~~--' tvelisse Alemany- Martinez, Plaintiff G Ivelisse Alemany- Martinez, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Michael Vega- Castro, No. CIVIL Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Michael O. Palermo, Jr., Esquire, attorney for Plaintiff do hereby certify that I this day mailed a copy of the within Motion upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Michael Vega- Castro HCOI Box 8644 San German, Puerto Rico 00683 Date: ~$-~ ~s~- -~ Michael O. Palermo, Jr., Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 93334 Attorney for Plaintiff ~ r-~ ~ Q ~~~ r- °~ _ i ~ ,. ~ ~`~ C' ' ~ ~ s ~ =, ~t~r'~ ~ ~r ~ _ a ~~~ N -T ~~ '`b --~: ~ Ga ~" c~,.. ~ P ~h - \ ~ c,~ -, h IVELISSE ALEMANY-MARTINEZ IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. MICHAEL VEGA-CASTRO I)IFI;NDANT • 07-2802 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, __ Monday, May 14, 2007 ` ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at_ ___ _4th Floor, Cumberland Coun Courthouse, Carlisle on Thursday, June 07, 2007 at 9:30 AM for aPre-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 ale 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. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. Bv: /s/ ac uelrne M. Verne Es . Custody Conciliator The Court of C:ommon 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 THIS PAPEK TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT H,4VE 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 .~~-~~~ ~ ~ ~,~ ~, o-~ ~~s ~~~ hi ~~ CO~h/ - f ~f ,-,