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Home My WebLink About09-62971 IRIS ENID REYES 104'/z Ross Avenue New Cumberland, PA 17070 (717) 773-1170 gatasalvaie3@yahoo.com IRIS ENID REYES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND CCj?- PENNSYLVANIA ytc.p9- G•297 V. : NO. CV CU RAYMOND L. CINTRON, ; CIVIL ACTION Defendant IN CUSTODY PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS TO THE HONORABLE JUDGES OF SAID COURT: Pursuant to Pa.R.C.P. No. 240, I hereby certify that I am without financial resources to pay the costs associated with my case, and therefore believe that I am entitled to proceed in forma pauperis. In support of my petition, I have attached to it a certification of indigency and incorporate it herein by reference, a certification which fully and truthfully describes my overall financial condition at the present time. WHEREFORE, the undersigned asks leave of court to proceed in forma pauperis, without the need to pay any costs in connection with the instant action. Respectfully submitted, Date: August 6, 2009 jv-'? ?Aj Lv-j his Enid Reyes IRIS ENID REYES 104 1, Ross Avenue New Cumberland, PA 17070 (717) 773-1170 99asalvaie3 @ yahoo ? IRIS ENID REYES, : IN THE COURT OF CO PLEAS OF Plaintiff :CUMBERLAND COUNTY, O PENNSYLVANIA V. : NO. CV __ CU RAYMOND L. CINTRON, Defendant : CIVIL ACTION : IN CUSTODY CERTIFICATE OF INDIGENCY 1 I am the Plaintiff in the above matter and because of my financial condition I am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct: (a) Name: Iris Enid Rees Address: 1041, Ross Avenue New Cumberland PA 17070 Social Security Number: 584-93-5669 (b) Employment: If you are presently employed, state Employer.: Never Quit Enterohse_ Address: New Cumberland PA Salary or wages per month: $12.98/hour with 40 hours/week Type of work: Custodial (c) Other income within the past twelve (12) months Business or professional per month: 0 Other self-employment per month: Interest per month: 0 Dividends per month: n Pensions and annuities per month: 0 Social Security benefits per month: 0 Support payments per month: 0 Disability payments per month: 0 Unemployment Compensation and supplemental benefits per week: 0 Workers' Compensation per month: 0 Public Assistance per month: X522.00 in food stamps Other per month: -Occasional help from father. (d) Other contributions to household support Wife/Husband Name: If your wife/husband is employed, state: Employer: Salary or wages per month: Type of work: Contributions from children: Contributions from parents: Other contributions: (e) Property owned Cash: 0 Checking account: 75 Savings account: 0 Certificates of deposit: 0 Real estate (including home): 0 Motor vehicle: Make: Year: Cost: Amount Owed: Stocks; bonds: Other: (f) Debts and obligations -average per month Mortgage: Rent: $770.00 Loans: $95.00 Other: Utilities: $415.00; Car Insurance $65.25; Babysitter: $300.00 (g) Persons dependent upon you for financial support Wife/Husband Name: Children, if any: Jamaris Cintr6n, 1041/2 Ross Avenue, New Cumberland, PA 17070, born June 15, 2001. Jailene Cintr6n, 1041/2Ross Avenue, New Cumberland, PA 17070, born June 11, 2004. Jarelis Cintron, 1041/2 Ross Avenue, New Cumberland, PA 17070, born April 15, 2006. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are being made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Date: August 6, 2009 ?-?- Iris Enid Reyes, Petitioner OF THE 'r CRY 2009 SEP c P,? 1 3 3 ?4 ; cut, r ! is IRIS ENID REYES 1041/2Ross Avenue New Cumberland, PA 17070 (717) 773-1170 gatasalvaje3@yahoo.com IRIS ENID REYES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA p q. G a 9 ? C'?cucJ ?.? V. : NO. CV CU RAYMOND L. CINTRON, : CIVIL ACTION Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Iris Enid Reyes, residing at 104 1/2 Ross Avenue, New Cumberland, Cumberland County, PA 17070. The Plaintiff's telephone number is 717-773-1170. 2. The Defendant is Raymond L. Cintron, residing at 209 Bridge Street, Apt. 1, New Cumberland, Cumberland County, PA 17070. The Defendant's telephone number is 717-370-9510. 3(a). Plaintiff seeks primary custody of the following child(ren): Jamaris Cintron, 1041/2Ross Avenue, New Cumberland, PA 17070, born June 15, 2001. Jailene Cintron, 1041/2Ross Avenue, New Cumberland, PA 17070, born June 11, 2004. Jarelis Cintron, 1041/2 Ross Avenue, New Cumberland, PA 17070, born April 15, 2006. 3(b). The children were not born out of wedlock. The children are presently in the custody of Iris Enid Reyes, who resides at 104 1/2 Ross Avenue, New Cumberland, PA 17070. Her relationship to the children is mother. During the past five years, the children have resided with the following persons and at the following addresses: Iris Enid Reyes (Mother) and Raymond L. Cintr6n (Father) at: 1. 1615 Derry Street, 2nd Floor, Harrisburg, Pa. 2. 1931 Forester Street, Harrisburg, Pa. 3. 2211 J. Cedar Run Drive, Harrisburg, Pa. 4. 1531 Berry Hill Street, Harrisburg, Pa. 5. 221 State Street, Enola, Pa. 17025. 3(c). The mother of the children is Iris Enid Reyes, currently residing at 1041/2 Ross Avenue, New Cumberland, PA. She is single. The father of the children is Raymond L. Cintr6n, currently residing at 209 Bridge Street, Apt 1, New Cumberland, PA. He is single. 4. The relationship of Plaintiff to the children is that of Mother. The Plaintiff currently resides with the following persons: Name & Relationship Jamaris Cintr6n, daughter. Jailene Cintr6n, daughter. Jarelis Cintr6n, daughter. 5. The relationship of Defendant to the children is that of Father. The Defendant currently resides with the following persons: Name Relationship Juana Davila, friend and co-worker. 6(a). 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. 6(b). Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. 6(c). 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 the children need stability in a home. Defendant has never been stable in a home as the previous addresses reflect that the Plaintiff has constantly had to move because of Defendants actions and instability. He is comingling with other people and demanding phone conversations with the children at unacceptable times or visitations at unreasonable periods. It is in the best interest of the children to be in the best health environment as Defendant has been constantly asked to care for the personal hygiene of the children. It is also in the best interest to grant this relief because of the children's safety and well-being. Defendant has threaten Plaintiff with applying physical harm upon her as well as the burning of a house if he finds out she is involved with other people. Defendant has constantly threatening the Plaintiff with taking off with the children. Defendant provides no meals for the children when they are in his care. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, plaintiff requests the court to grant primary custody of the child. I verify that the statements made in the 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. Date: August 6 2009 L- ??d ? I I a A Iris Enid Reyes V T 717-773-1170 Plaintiff's telephone number OF THE Ry 2009 SEP 21 PM 1: 33 NOV 1 d 2009 4 IRIS ENID REYES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA 0q - G a 97 ?.? -7 -z4.-- v. : NO. CV CU RAYMOND L. CINTRON, : CIVIL ACTION Defendant IN CUSTODY ORDER GRANTING LEAVE TO PROCEED IN FORMA PAUPERIS AND NOW, this --1=? day of M t q P-l " Q, f , 20-ft, upon presentation and consideration of the within petition and attached certification, we grant the relief prayed for, and grant Petitioner leave to proceed with this case in forma pauperis, without the need to pay any costs connected therewith, all of which is pursuant to Pa.R.C.P. No. 240. BY THE COURT: Judge THP??€=r=1GE . ROT'H NOTMY 2009 NOV 23 PM 12* 17 Q.W?. , ,"'A , "U 4t" %a NTY PENNSYLVANIA IRIS ENID REYES IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-6297 CIVIL ACTION LAW RAYMOND L. CINTRON IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, November 20, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Monday, December 07, 2009 _ at 1:30 PM 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. 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. By: _/s/ Dawn S. Sunda Es q. 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 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 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 ALES- F ?i C/ F 2009 NOV 23 P i2: 23 3 L/Gf}l iNT Y ?t t/ r 1-a3 oy, ??' f