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Home My WebLink About01-2769MABEL M. VAZQI.~7... : THE COLTRT OF COIV~VION P!.~AS OF Plainti~ : CUMBERLAND COUNTY, PENN'SYLV~N'IA .. ERNESTO ROLD.,~Jq'-VAZQUEZ, .JR.., : CIVIL ACTION - AT LAW Defendant : CUSTODY COMPl .A[N'T IN CI AND NOW, thc Plaintiff, IVtmbol M. V~zqucz, by and thmngh her attorney, Jcann~ B. Costopoulos, Esquire, makes thc following Complaim in Custody: 1. Thc Plaimiff, Mabel lvL Vazqucz, is an adult individ.ml who currently resides at 818 Wcrizvillc Road, Enola, Cumberland County, Pennsylvania 17025. 2. Thc Defendant, Errgsto Roldan-V~uez, Jr., is an adult individual who is believed to bc residing a~ 1743 Slate Road 100, Iv~lmsc, Florid~ 3. Thc proxies have two dependcm children, namely Chase Va~ugz, bom ~ 4, 1997, and Erika Vazqucz, bom September 1, 1~)8. 4. Thc Plaimiffsccks pdmmy of thc following children: Chase V~-quez 1743 Stutc Road 100 3 lV~lrosc, Florida bom 10/4/97 Erika Vazquez 818 Werlzvillc Road 2 Enola, PA 17025 bom 9/1/98 The children were n~ bom out of wedloclc 5. The child Erika Vazquez is presently in ~e custody of her ~, whose curre~ address is 818 Werlzville Road, Em}la, Cumberland County, Pennsylvania 17025. The child Chase Vazquez is presently in the custody of his Father, whose current address is believed to be 1743 Stnt,~ Road 100, Melrose, Florida. 6. During the past five years, the child~-n have resided with the following persons and at the Emesm Roldan-Vazquez - Dcf~dant 1743 State Road 100 4/28/01-present Melrose, Florida Clmse Vazqucz only Mabel Vazqucz- Plaintiff 818 Weflzville Road 4/28/01 -present Charles Buckles, Jr. (Plaintiff's father) Enola, PA 17025 Erika Vazquez only Mary Buckles (Plaintiff's mother) Mabel Vazquez - Plaintiff 818 Wc~ville Road 4/26/01-4/28/01 Charles Buckles, Jr. (Plainliff'sfather) Enola, PA 17025 Mary Buckles (Plaimiff's mother) Mabel Vazquez- Plaintiff 818 Wertzville Road 1/01-4/26/01 Emesto Roldan-Vazquez- Defendant Enola, PA 17025 Charles Buckles, Jr. (Plaintiff's father) Map/Buckles (Plaintiff's mother) Mabel Vazquez-Plnimiff 818 Werlzville Road 5/1/99- 1/01 ChnrlesBucldes, Jr. (Plaintiff's father) Enola, PA 17025 Mary Buckles (Plaintiff's mother) Mabel Vazquez- Plairdiff 414 Myrtle Avenue !/99- 5/1/99 Charles Buckles, Jr. (Plaimiff's fatt~) Marysville, PA 17053 Ma~y Buckles (Plaimiirs mother) Hany Buckles (Plaintiff's brother) Mabel Vaa:lUeZ - Plaint/ff 414 Myrtle Avenue 10/98-1/99 EmesmRoidan-Vnzquez-Defendant Mmysviile, PA 17053 Charles Buckles, Jr. (Pla/miff's Ivimy Buckles (Phintifl's mother) Harry Buc. kles (Plaintiff's brother) MUb~ Vazquez- Pla/nt/ff 414 My~le Avenue 2/1/98- 10/98 ChadesBuckles, Jr. (Fla/nt/ff'sfather) Matysv/lle, PA 17053 Mary Buckles (Plaimiff's mother) Hazy Buckles (Pla/nt/ff's brother) Mabel Vn=quez- Pla/nt/ff 307 B. Front Slreet 10/4/97-2/1/98 ErnestoRoldan-Vazquez-Defendant Marysv/ll¢,PA 17053 Chase Vazquczonly (Er/ka bom 9/!/98) 7. Tbe mother of the children is Mabel M. Vanqucz, Pla/miff, cun'emiy res/d/nE at 1743 S~t_e Road 100, Melrose, Flodda. Pla/miff resides w/th Efika Vazquez, one of the subjea ch/idmm, her parents. Mary Buckles and Chades Buckles, Jr., and her paternal grandmother, Ma~y Buekle~ 8. The father of the children is Emesto Roldan-Vazquez, Jr., Defendant, believed to be currently re~d/n8 at 1743 S~ate Road 100, Melrose, Florida. It is unknown w/th whom Defendant resides, other than one of the subject children, Chase Vazquez It is believed Defendant went to Flor/da w/th h/s mother. 9. Flaimiffand Defendant are married to each other. 10. The relafionskip of the Plaimiffto the children is that of natural mother. I I. The relat/onship of the Defendant to the children is that of natural father. 12. Pla/nt/ff has not {xgt/c/pated as a party or w/mess, or in another capacity, in other l/t/gat/on concerning the custody of the children in this or another court 13. Plaintiff does not know of a person not a pan'y to the proceedings who has physical custody of either of thc children or claims to have physical custody or visitation rights with respect to the childre~ 14. The be~t interests and l~m~e~t welfare of the children will be s~rv~d by granting the reli~ m~t~-l~l I~cause: (a) Plaintiff is tl~ natmal tootler of lh~ children and has ~stablish~l a relalior~hip with the children. 00) Plaintiff desires to con~nue exercising pnrenlnl duties nmi enjoys the love nnd affection o£the children, she has been their pr~ carelnker since birth. (c) The chil,~ should be permitted to e~joy U~e love, affec~on, and em~onal support which can be provided by their nnttwal mother. (d) The children have lived in Pennsylvania since birth. The children's maternal extended fmuily who reside in Pennsylvania hnve eslnblished slrong bonds with the children. (e) The children are siblings and should not be sepaml~d f~om each other. person who hns physical cuslody of the children hnve been named as pnrties to this ac~on. No olher persons are known to hnve or claim a fight to custody or visilnlion of the children to be given noOce of the pendency of this nc~on nnd the right to inu~rvene. of her children subject to periods of visi~tion with ~ Respectfully submitl~d, 1400 N. Second S1~et l-lnrrisburg, PA 17102 ("Z~?) 22~-0~00 Supreme Ct. ID No. 68735 PA 17102 MABEL M. VAZOU[-.'Z. : TH]_..' COURT OF COMMON PLEAS OF Plaintiff' : CLJMBERLAND COUNTY. PENNSYI.VANIA vs. : No. ERNESTO ROLDAN-VAZQLII":Z, JR.. : CIVIl_ ACTION - A'I' LAW Del~ndant : CUSTODY yF~R! F'II'~AT ION I. Mabel M. Vazqaez. hereby verify that thc statements made in the foregoing Complaint itl Custody, are true and correct to the best of my knowledge, infi)rmation, and belid~ I undemtand that thl~ statemenls herein am made subject to the penalties of 1 g Pa. CS. § 4004. relating to unsworn falsification to authorities. MABEL M. VAZQUEZ: IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND coUNTY, PENNSYLVANIA ERNESTO ROLDAN-VAZQUEZ, ~R. ; 01-2"/69 CIVIL ACTION LAW DEFENDANT . : IN cUSTODY AND NOW, W~,~,,~a,y, May 0~, 2001 ., upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before _ Me!i**i P. GreeVy, E~I. , the conciliator, ,.~I~.n'~ay, Juue 04, 2001 at 9:15 a.m. at 214 $-6~ Av;;:::, Suite 105, Camp Hill, PA 17011. on 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. 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. 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: 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 : THE COURT OF COMMON PLEAS OF MABEL M. VAZQUF-.Z, Plaintiff : CUMBF-~ COUNTY, pENNSYLVANIA *VS. :CIV]L A. CTI. O~ - AT LAW E~STO ROt.DA~-VAZQUEZ, I~femdant : CUSTODY AND NOW, upon consideration ~t* Plaintiffs Petition for Emergenc~ Relief, it is ordered and decreed ~ tempom~ prima~ physical custody of the pa~ies' minor childm~ O~ase Erika Vn~q. uez,. ~., Vnzquez, bom ~ 4, 1997, and born September 1, 1998, shall be with Plaintiff _ _, ... Father, Emesto Roldnn-Vnzquez, Jr., is ~ to immediately return the child to DATED: ~:2~, ~; 2-~)° ! MABEL M. VAZQUF~ : THE COURT OF COMMON pLFAS OF Plainl~ff : CUMBERLAND COUNTY, PENNSYLVANIA :No. V~. EI~Ip__~TO ROLDAN-VAZQUF--Z, J-~, : CI¥1L AC'TION - AT LAW Def~.ndant : CUSTODY F(IR TI~,MI~IRA R¥ PRIM'A~ ~ NOW, ~mm ~ P~i~ff, ~1 M. V~ ~ ~ ~ ~ a~m~, J~ B. C~ ~&~, ~ ~ly a~ ~ foll~ in s~ ~s P~fion f~ Em~ Relief: 1. ~e ~nfiff, ~i M. V~ is ~ ~t in~ ~o c~y ~i~ at ~!8 W~II~ R~ ~o1~ ~1~ ~, P~l~a 1 2. ~ ~ E~o RoI~V~ Jr., ~i&ng ~ 1743 S~ R~ 1~, ~1~, 3. ~~~c~l~elyC~V~~4, !~, md ~ V~ ~m ~r 1, 1~8. 4. ~t ~1~ P~ff ~ ~, A~I 28, 2~1, ~ ~ to ~ ~ir mn, C~ V~ to a ~r's ~1 ~. P~ff ~o~ ~d ~ ~ ~r~ ~ ~ ~ m~ ~d ~ C~ ~ he ~d ~ck ~m ~ ~r 5. ~ ~1~ Pl~ff I~ ~ ~Y, A~I 28, 2~1, ~ C~ m Ci~ lsl~ 6. Lam' on S~ ,rday, April 25, 2001, Plaintiff learned that Defendant did not attend the Senator's/nme. hme~ without Plaintiff's consent or permission, Defendant left for Florida with his mother and had taken Chase with him. 7. Plaintiff went to Fiodda late on Apfil 2~, 2001 in an effo~ ~o retrieve her son. Sinceshe had no court order, however, ihe local authorities would not/ntervene. 8. Defendant informed Plaintiffby e-mail that he would leave Fioddn nnd So to a dif~rem state with Chase if she filed for e~x~xly. 9. plaintiff is concerned for the welfare of her sort Defendnnt has been abusive in the past nnd was incarcerated from Janun~ 1999 to Jnnun~y 2001. 10. Plaintiffhns been both child~n's prinu~y carte~aker since birth. 11. Phimiffobjects to her son living in Florida with Defendnnt and requests that her son be returned immediately pending a determination by the couCc 12. Plnintiff hns filed a Comphint for Custody simultaneously with this PetMon and it is incorporated herein as though fully set fortk WHEREFORE, Plaintiff respectfully requests this Honorable Court ~o enter an Em~ Ordn' /nntini to her prima~ physical custody of both children pending the s~heduling of a conference or hearing on the matter. ~¢speet~ly su~mitt~t, 1400 lq. S~eond Strut H~sbur~ PA 17102 (71~ 221~ MABEL M VAZ¢)IJb:Z., Plaintiff' : THE Ct)lJhl'r OI-' C(.')MM(.)N PLEAS (_)F : CIJMBI~RLAND COUNI.'y. PENNSYLVANIA : No. L:RNESTO ROI.DAN-VAZQUF!Z..IR.. : CIVIl. ACTION - Al'' [.AW I~li:ndant : CUSTODY ~"£1{11;'!{?.A1'I/}~ I, Mabel M. Vazquez, hereby ~,'cri~ lhat the statements made in thc lbre~uoing Petition for ~mnergenc>. C.'uslody arc true and correct to the best or'my knowledge, intbrmation, and belie£ understand that I~lse statements herein are made subject to the penalties of' Ig ['a. C' $..~ 4904, relating to unsworn t~lsification to authoriti~. IIII III lllll I IIIIIIIIIIII III III IN TIlE coURT OF coMMON PLEAS OF MABEL M. VAZQUEZ, :: cUMBERLAND coUNTY, pENNSYLVANIA Plaintiff : : CIVIL ACTION - LAW ¥. ERIqESTO ROLDAN' : yAZQUEZ, IR., : NO. 01-2769 CIVIL TERM Defendant : AND NOW, this 16t~ day of May, 2001, upon consideration of the attached letter from Defendant r~questing a hearing on the continuation or modification of the order of court dated May 8, 2001, a hearing is scheduled for Tuesday, May 29, 2001, at 8:30 a.m., in Courtroom No. 1, cumberland County Courthouse, Carhsle, Pennsylvama. BY THE cOURT, Jeanne B. Costopoulos, Esq. 1400 lq. Second Street Harrisburg, PA 17102 Attorney for Plaintiff Ernesto Vazquez 1743 State Road 100 Melrose, FL 32666 Defendant, Pro Se Dear Judge Wesley Oler, Sir I am not going to be able to make it back to Pa in an immediate time frame, I would like to appeal the order and request a hearing on the matter. I have not yet re*mined an attorney but I spoke to one, and he is willing to take my case. Thank you for your consideration on this matter, Ernesto Vazquez Jr ~/0i 14:B4 I)OE]~EN KEEUICRN k, JEIS~ e 241~,462 pA~- ~3 : tN 'i'HE cOUP'I' OF COMMON pLEAS OF : CUMBERLAND cOUNTY, pENNSYLVANiA MABEL M. yAZQUEZ, plaintiff ; : NO. 01-2769 vs. : CIVIL AC'I'ION - LAW oRDER OF cOUR'I' this ~ day of June, 2001, the parties having failed AND NOW, attend the Custody Conciliation conference scheduled for June 4, 2001, the either to Custody concitiator hereby retinquisheS iufisdiction, in the event that party desires to modi~J the order of MaY 8, 2001, another Custody conciliation with the court. proper pet~ted conference may be scheduted upo~ Custody Conciliator DaVid T Kluz, Esquire, 212. Lo~. _st CouP, ~ardsburg. PA 17101 Diet: ,Jeanne: B. CoStopOUlOS, Esquire, 1400 N SecOnd Street, Hawieburg, PA 17102 JUN 1 4= 2001~ IN THE COURT OF COMMON PLEAS OF NIABEL M. VAZQUEZ, :: CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : : NO. 01-2769 VS. ._ : CIVIL ACTION - LAW ERNESTO ROLDAN-VAZQUEZ, JR., Defendant : CUSTODY R P 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: ~ ~ _CURRENTLY IN CUSTODY OF Chase Vazquez October 4, 1997 Mother September 1, 1998 Mother Erika Vazquez 2. A Custody Conciliation Conference was schedu, led for June 4, 2001. The Conference was attended by counsel for Plaintiff, Jeanne B. Costopoulos, Esquire, and David T. Kluz, Esquire. Neither party attended the Conference- After meeting with counsel it was agreed that the present Order of May 8, 2001, would remain in full force and effect, the thator would relinquish jurisdiction of the matter, and in the event that either party would Conc' ' · ...... "-r of Ma" 8, 2001, that party may petition for modification and an desire to rnoat~Y the vru= · additional Conference will be scheduled. - e,ssa Pee ree , Esq,."re D-ate ' ' Custody Conciliator Dist: David T. Kluz, Esquire, 212 Locust Court, Harrisburg, PA 17101 Jeanne' B. CostOpoulos, Esquire, 1400 N. Second Street, Harrisburg, PA 17102