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HomeMy WebLinkAbout04-1462DORA V. RAMOS, Plaintiff JOSE LOUIS RAMOS, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW CHILD CUSTODY NOTICE YOU HAVE BEEN SUED 1N COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this 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 without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property, or other rights important to you, including child custody, or child visitation. 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 DORA V. RAMOS, Plaintiff JOSE LOUIS RAMOS, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA m CIVIL ACTION - LAW CHILD CUSTODY COMPLAINT FOR CHILD CUSTODY AND NOW comes the Plaintiff, Dora V. Ramos, by and through her attorney, Kristin R. Reinhold, Esquire, and respectfully requests this Honorable Court award her custody of the subject minor children, and in support thereto, avers the following: l. Plaintiffis Dora Ramos, an adult individual residing at 8 North Regency Wood, Carlisle, Cumberland County, Permsylvania, 17013. 2. Defendant is Jose Louis Ramos, Jr., an adult individual believed to be residing at 5702 Tappan Street, Columbus, GA 31907. 3. The subject children are DiAnna Ramos, born January 26, 2002, and Jessica Ramos, born February 1, 2001. 4. The relationship of the Plaintiffto the subject minor children is that of natural mother. 5. The relationship of the Defendant to the subject minor children is that of natural father. 6. The minor children have resided at the following addresses, in the custody of the following individuals: a. From birth until September, 2003 - The subject minor children resided at 8 North Regency Wood, Carlisle, Ctunberland County, Pennsylvania, in the care and custody of Plaintiff, Dom V. Ramos. b. September, 2003 until March 16, 2004 - The subject minor children resided at 8 North Regency Wood, Carlisle, Cumberland County, Pennsylvania, in the care and custody of Plaintiff, Dora V. Ramos and Defendant, Jose Louis Ramos, Jr. c. March 16, 2004 until present - The subject minor children reside at 8 North Regency Wood, Carlisle, Cumberland County, Pennsylvania, in the care and custody of Plaintiff, Dora V. Ramos. 7. There have been no prior actions for custody of the subject minor children in this or any other jurisdiction. 8. The Plaintiffis not aware of the existence of any other individuals who have any type of claim whatsoever regarding the custody of the subject minor children. 9. The Plaintiffbelieves and therefore avers that she is much better able to meet the needs of the subject minor children than the Defendant. 10. The Plaintiff believes and therefore avers that it is in the best interest of the subject minor children that they be placed in her legal and physical custody. WHEREFORE, Plaintiffrequests this Honorable Court award her custody of the subject minor children. Respectfully submitted, THE LAW OF} ICES OF SILLIKER & R ~INHOLD ~ einl ~ 5922 ~wn Road Harrisburg, PA 17112 (717) 671-1500 I.D. No. 57911 Attorney for Dora V. Ramos AFFIDAVIT I, i fi~ [ft~ 0~ , hereby certify that the aforegoing is tree and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. 4909 relating to unswom falsifications to authorities. DORA V. RAMOS PLAINTIFF V. JOSE LOUIS RAMOS, JR. DEFENDANT iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-1462 CIVIL AC:TION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, April 16, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear belbre. Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Thursday, May 20, 1004 at 10:30 AM for a Pre-Hearing Custody Conference. A~ such conference, an eflbrt will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard b;y the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to apvear 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, By: /si Melissa P Greevy. Esq. Custody Conciliator mhc The Court of Common Pleas of Cumberland County is required by law to comply with the Americans w/th 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 HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FOR'IH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 171) 13 Telephone (717) 249-3166 -~ V. RAMOS, Plaintiff JOSE LOUIS RAMOS, JR., Defendant IN THE CCI JRT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-1462 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY TEMPORARY ORDER OF COURT AND NOW, this I ~ day of May, 2004, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. ~. The Mother, Dora V. Ramos, shall have primary physical custody of the minor children, DiAnna Ramos, born January 26, 2002, and Jessica Ramos, born May 1, 2001. Father shall have periods of partiial custody to be exercised in Pennsylvania at Mother's residence. Father's periods of custody shall be for two to four (2 to 4) hours duration and shall be arranged by the mutual agreement of the parties with Father providing Mother not less than one (1) week's notice of a request for his visit. Mother's consent to such visit shall not be unreasonably withheld. These visits may occur on the weekend, or on weekdays after Mother's work hours. In the event that Father would like to visit with the children outside of Mother's residence, he shall provide Mother with notice of where he intends to be with the children. 2. For a period of twelve hours before and continuing throughout any period of supervised visitation or partial custody with the minor children, the parties shall consume no alcoholic beverages nor possess or use controlled substances whatsoever. The parties shall likewise ensure, to the extent possible, that the other household members and/or house guests comply with this prohibition. 3. The parties shall exchange and keep each other advised of their current daytime and work telephone numbers in order to facilitate parental communication regarding the children, and in particular in an emergency situation regarding the children. 4. Mother will share the car seats with Father for his use during his custodial visits in Pennsylvania. At the conclusion of his visit, Father will reinstall the car seats in Mother's vehicle and secure them properly so that they are ready for use by the children. 5. Cumberland County Court of Common Pleas for the Commonwealth of Pennsylvania shall retain jurisdiction of this matter. NO. 04-1462 CIVIL TERM 6. The Custody Conciliation Conference shall reconvene on October 5, 2004, at 1:00 p.m. at the office of the Custody Conciliator, Melissa Peel Greevy, Esquire, 301 Market Street, Lemoyne, PA 17043. Dist: BY THE COURT: ~ri~ R. Reinhold, Esquire, 5922 Linglestown Road, Harrisburg, PA '17112 /,~endolyn S. Hailey, Esquire, 315 Chapel Hill Street, Suite 405, Durham, NC 27701 DORA V. RAMOS, : Plaintiff : : JOSE LOUIS RAMOS, JR., : Defendant : IN THE coURT oF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NC). 04-1462 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 subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF DiAnna Ramos Jessica Ramos January 26, 2002 February 1, 2001 Mother Mother 2. A Custody Conciliation Conference was held on May 12, 2004 following Mother's April 6, 2004 filing of a Complaint for Custody. Attending the conference were: the Mother, Dora V. Ramos, and his counsel, Kristin R. Reinhold, Esquire; Father's counsel, Gwendolyn S. Halley, Esquire. The Father did not ar(end nor did he participate by telephone. 3. Father's counsel represented that she had authority to consent to the terms of the O~der negotiated at the Custody Conciliation Conference. Part of the parties' agreement provides for the Custody Conciliation Conference to reconvene in October 2004. Father shall be required to participate in the conference at that time if he seeks to change the terms of the Order as attached. Me'lit y, q ire Custody Conciliator :228881 DORA V. RAMOS, Plaintiff JOSE LOUIS RAMOS, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-1462 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY HESS, J. --- ORDER OF COURT AND NOW, this /Y' day of October, 2004, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Physical Custody. The Mother, Dore V. Rarnos, shall have primary physical custody of the minor children, DiAnna Ramos, bom January 26, 2002, and Jessica Ramos, born February 1, 2001. Father shall have periods of partial custody to be exemised in Pennsylvania at Mother's residence. Father's periods of custody shall be for two to four (2 to 4) hours duration and shall be arranged by the mutual agreement of the parties with Father providing Mother not less than one (1) week's notice of a request for his visit. Mother's consent to such visit shall not be unreasonably withheld. These visits may occur on the weekend, or on weekdays after Mother's work hours.. In the event that Father would like to visit with the children outside of Mother's residence, he shall provide Mother with notice of where he intends to be with the children. 2. For a period of twelve hours before and continuing throughout any period of supervised visitation or partial custody with the minor child, the parties shall consume no alcoholic beverages nor possess or use controlled substances whatsoever. The parties shall likewise ensure, to the extent possible, that the other household members and/or house guests comply with this prohibition. 3. The parties shall exchange and keep each other advised of their current daytime and work telephone numbers in order to facilitate parental communication regarding the children, and in particular in an emergency situation regarding the children. 4. Mother will share the car seats with Father for his use during his custodial visits in Pennsylvania. At the conclusion of his visit, Father will reinstall the car seats in Mother's vehicle and secure them propedy so that they are ready for use by children. NO. 04-1462 CIVIL TERM 5. Cumberland County Court of Common Pleas for the Commonwealth of Pennsylvania shall retain jurisdiction of this matter. BY THE COURT: ,/~n A. Hess, J. Dist: i/~dstin R. Reinhold, Esquire, 5922 Linglestown Road;, Harn'sburg, PA 117112 ' ~,~wendolyn S. Halley, Esquire, 315 Chapel Hill Street, Suite 405, Durham, NC 27701 DORA V. RAMOS, Plaintiff V. JOSE LOUIS RAMOS, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-1462 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 subject of this litigation is as follows: NAME DiAnna Ramos Jessica Ramos DATE OF BIRTH January 26, 2002 February 1, 2001 .CURRENTLY IN THE CUSTODY OF Mother Mother 2. A Custody Conciliation Conference was held on October 5, 2004 as provided in this Court's Order of May 18, 2004. Attending the conference were: the Mother, Dora V. Ramos, and her counsel, Kdstin R. Reinhold, Esquire. Father did not appear. Father's counsel, Gwendolyn S. Halley, Esquire, did not appear. 3. Mother reports that since the Conference on May 12, 2004, that the children have seen Father twice. One visit occurred when Mother notified him that they were going to be visiting family in Florida. After Mother initiated the contact, Father came to the hotel where Mother was staying with the children at 11:30 p.m. On another occasion, Father was in town for a hearing. Mother offered the opportunity for tihe children to see their Father. She took the children to see him at a local truck stop because that was the only place where he would agree to see the children. She states that he now refuses to see the children at her home. 4. Father's position on custody is unknown as he failed to attend the Conference. It is also noted that occasion, did Father Date~ :237009 he failed to attend the first Conferenge~ matter. On neither ~articipate by telephone. I /~ Melissa Peel Greevy, Esquir,~ Custody Conciliator ~