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ZOE MARIE STERNER-BELLIDO,
plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
FAMILY DIVISION
NO. 606 . 1995
CIVIL ACTION - LAW
IN DIVORCE
RAFAEL BLAS BELLIDOb
efondant
ORDER OF COURT
AND NOW, to wit, this (,.. day of /("t"~f ' 1995,
upon consideration of the Plaintiff's Petition For Final order,
filed in conjunction with the Plaintiff's Application For
Special Relief, on February 3, 1995, a RULE TO SHOW CAUSE is
hereby issued upon the Defendant, Rafael Blas Bellido, to show
what cause he may have, why the relief sought by the Plaintiff
in the said Application For Special Relief, seeking exclusive
possession of the parties' marital home, located at 879 Mandy
Lane, Camp Hill, Hampden Township, Cumberland County,
Pennsylvania, should not be granted. However, this Court's
Order issued on February 3, 1995, granting temporary exclusive
possession of the parties' marital home to the Plaintiff, Zoe
Marie SUrner-BelUdo, shall remain in full force and effect
until otherwise modified by this Court.
"~iI { /' I .'
THIS RULE IS RETURNABLE on/the -"I,.J day of / , I ( i if d i II' ,
19913, in Courtroom No.' at. ;), . 'l( I 0' clock, -rl,/)n.,
in the Cumberland County Courthouse, Carlisle, Pennsylvania.
BY THE COURT:
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ZOE MARIE STERNER-BELLIDO,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
FAMILY DIVISION
NO. 606 - 1995
CIVIL AC'TION . LAW
IN DIVORCE
RAFAEL BW BELLIDOb
efendant
PETITION FOR FINAL ORDER
I
AND NOW, to wit, this 6th day of February, 1995, comes the
Plaintiff, loe Marie Sterner.Bellido, by and through her
undersiQned attorneys, Clark Law Associates, P.C., and f11es
this Petition For Final Order for exclus'.ve possession of the
parties' marital home, and offers the following to this
Honorable Court in support thereof:
1 . On February 3, 1996, the Plaintiff f Hed a Consolidated
Complaint in Divorce against the Defendant.
2. On February 3, 1995, the Plaintiff filed an Application For
Special Relief pursuant to the aforesaid Divorce action, wherein
the Plaintiff sought exclusive possession of the parties'
marital home, located at 879 Mandy Lane, Camp Hill, Hampden
Township, Cumberland County, Pennsylvania.
:3. 01' February 3, 1995, this Honorable Court granted the
Plainti ff' s said Pet! tion For Special Relief, and issued a
Temporary Order, but conditioned such Temporary Order upon the
requirement that the Plaintiff file a Petition For A Final Order
in said matter within five (5) days of the entry of the Court's
said Order.
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Cu". LAW AIIIIlClATlIlI, P.O.
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Statlls government I and is not a natural1zed oi Unn 01 the
United States of America.
3. On even date herewith, the Plaintiff has filed a Complaint
In Divorce, a Complaint for Custody of Minor Children, and an
Application For Special Relief in said Custody Action, all
against the said Defendant, Rafael Blas Oellido.
4. The Plaintiff, Zoe Marie Sterner-Bellido, togflther with the
parties' four (4) minor children, all reside in the family home
located at 879 Mandy Lane, Camp Hill, Hampden Township,
Cumberland County, Pennsylvania 17011.
5. On or about October 24, 1994, shortly after the birth of the
parties' youngest child, the Defendant informed the Plaintiff
that he (Defendant) was unhappy living with the Plaintiff, and
that he (Defendant) was "entitled to his happiness", and that he
(Defendant) was leaving the Plaintiff and the childJ'en, and
intended to live elsewhere.
6. On or about October 24, 1994, the Defendant did, in fact,
move out of the marital household, took all his necenary
personal clothing, belongings and effects from the marital home,
2
and took up ~iving in and about the City of Harrisburg, Dauphin
County, Pennsylvania.
7, Sinoe the Defendant moved out of the marital home, he
(Defendant) has visited the Plaintiff and the ohildren in the
marital home on Sunday afternoons, between the hours of
approximately 1 :00 p.m. and 6:00 p.m., on almost a weekly basis.
8. During very reoent disoussions between the Plaint! ff and the
Defendant, the Defendant informed the Plainti tf that he
(Defendant) was considering taking the children, in particular
the minor ohild Alexander Rafad Bellido (Alexander), age ~,
with him and returning to his native homeland, the country of
Peru, without the Plaintiff.
9. On Sunday, January 29, 1995, the Defendant was temporarily
Visiting with the Plaintiff and the minor children, at the
marital home, at which time he (Defendant) made specific
inquires concerning the precise age of the minor child,
Alexander, age G, which information would be applicable in the
applioation for a passport for said child,
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10. On Sunday, January 29, 1995, after making the said inquires
conoerning the age of Alexander, the Defendant informed the
Plaintiff that he (Defendant) was intending on returning to his
native homeland (Peru) in the next few weeks, and wanted to take
the minor child Alexander, with him (Defendant) for said trip.
11. When the Plaintiff refused to permit the Defendant to take
the 'minor child Alexander to Peru, as aforesaid, the Defendant
beoame visibly upset and terminated the conversation.
12. On Tuesday evening, January 31, 1995, during a telephone
conversation between the Plaintiff and Defendant, the Defendant
informed the Plaintiff that when he (Defendant) obtained
suffioient money for a divorce action, that he (Defendant) was
intending on fighting for his son (Alexander), and that he
(Defendant) would kidnap the said minor child Alexander, and
return to his native homeland (peru) with said child.
1 G. During the aforesaid telephone conversation between the
parties on Tuesday, January 31, 1995, the Defendant informed the
Plaintiff that he (Defendant) would make arrangements to have
his (Defendant's) mother raise the said minor child Alexander in
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his native homeland (Peru), and not return said child to the
Plaintiff in the marital home.
14. During the aforesaid telephona conversation between the
parties on Tuesday, January 31, 1995, the Defendant informed the
Plaintiff that he (Defendant) was prepared to go to the home of
the children's babysitter, Nancy I. Williams, located at 12
Briar Lane, Lower Allen Township, Cumberland County,
Pennsylvania, and take the minor child Alexander, and not to
return said minor child to the custody and care of the Plaintiff
in the marital home.
15. The Plaintiff believes, and therefore avers, that the
Defendant owns and possesses a firearm.
16. The Defendant, in the past, has committed and threatened
violence against the person of the Plaintiff when the Plaintiff
did not submit to the will of the Defendant, and the Plaintiff
believes, and therefore avers, that if the within Application
For Special Relief is not immediately granted, that the
Defendant, upon service of a copy of the Complaint for Custody
and Complaint In Divorce, will return to the marital home in an
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enraged state, and take violent aotions against the Plaintiff
and possibly the ohildren, as aforesaid,
17. The Dofendant's rights to reside peaoeably in the mar1tal
home, together with the ohildren, will be in grave jeopardy if
an Order is not issued whereby the Defendant's aooess to the
marital home is not restricted,
18. The entry of an Order whereby the Plaintiff and the ohildren
are granted exolusive possession of the marital home, thereby
maintaining the status QUo between the parties, would not
substantially harm the Defendant'a interests in this oase,
pending a tinal d1sposi tion of the issues by this Honorable
Court.
WHEREFOR~, the Plaintiff, Zoe Marie Sterner-Bellido,
respectfully requests this Honorable Court to issue an Order
immediately, whereby the Plaintiff, Zoe Marie Sterner-Bel11do,
is temporarily awarded exclusive possession of the parties I
marital home, located at 879 Mandy Lane, Hampden Township,
Cumberland County, Pennsylvania, pending further proceedings
before this Honorable Court.
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va.".. LAW A..')CIAr... P.C.
ArtokN'n1 It COliNl',li,)AI A r lAW
ill HllJAIJRN AIIAIl
lIOn OHlc., RO)l; ~H
H.....\', P............ J7OB$.,ISS$
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:('fr-.
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
FAMILY DIVISION
NO. '1 <;~_. <.: 0(.
CIVIL ACTION - LAW
IN CUSTODY
ZOE MARIE STERNER-BELLIDO,
Plaintiff
RAFAEL BLAS BELLIDOb
Gfen~ant
ORDER OF COURT
AND NOW, to wit, this J J day of l(t.../ "} , 1995,
,
upon consideration of the attached Application For Special
Relief, IT IS HEREBY ORDERED, that pending a further Order of
this Court,
1. The Plaintiff, Zoe Marie Sterner-Bellido, is awarded full
legal and physical custody of the minor children of the parties,
to wit: Sarah Giovanna Bellido, Alexander Rafael Bellido,
Brianna Fanua Bellido, and Elizabeth Gabina Bellido, subject to
the following rights of visitation for the Defendant, Rafael
Blas Bellido~
a. The Defendantl Rafael BIas Bellido, shall be permitted
to have supervised visitation with the said children in the
parties I marital home, located at 879 Mandy Lane, camp
Hill, Hampden Township, Cumberland County, Pennsylvania, on
Sunday afternoons, between the hours of 1:00 p.m. and 6:00
p.m., and at such other times as the parties may mutually
agree.
2. Neither the Defendant, nor any other person, shall remove
or attempt to remove the said children from the said custody and
care of the Plaintiff.
3, Neither the Defendant, nor any other person, shall remove
or attempt to remove the said minor children from this
Commonwealth and/or the United States of America.
4, Any and all paosports or similar type visa documents whioh
have been issued for the parties' minor ohildren, to witt Sarah
Giovanna Bellido, Alexander Rafael Bellido, Brianns Fanua
Bellido, and Elizabeth Gabina Bellido, are hereby specifically
ordered to be surrendered immediately to this Court I and the
parties, or any person acting on behalf of the parties, are
hereby specifically directed not to apply for a passport or
similar visa type document for said minor children, without the
I
specific written permission of this Court.
6. A copy of this Order shall be immediately served upon the
Sheriff of Cumberland County, the Hampden Township Police
Department, the Lower Allen Township Police Department, and the
Pennsylvania State Polioe, for notice and enforcement,
6. A copy of this Order shall also be immediately forwarded to
the United States Department 0 r State, for the purpose of
enforcement of that portion of this Order pertaining to the
custody of any and all passports or other visa type documents
whioh may have been issued to the parties' minor chlldren, to
wit: Sarah Giovanna Bellido, Alexander Rafael Bellldo, Brianna
Fanua Bellido, and Elizabeth Gabina Bellido.
BY THE COURT:
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Sarah Giovanna Bellido
Alexander Rafael Bellido
Brianna Fanua Bellido
Elizabeth Gabina Bellido
5 years & 1 month
3 years ^ 5 months
2 years
4 months.
4. The children are presently in the physical custody and care
of the Plaintiff, Zoe Marie Sterner-Bellido, and they all reside
in ~he family home located at 879 Mandy Lane, Camp Hill, Hampden
Township, Cumberland County, Pennsylvania 17011.
5. On or about October 24, 1994, shortly after the birth of the
parties' youngest child, the Defendant informed the Plaintiff
that he (Defendant) was unhappy living with the Plaintiff, and
that he (Defendant) was "entitled to his happiness", and that he
(Defendant) was leaving the Plaintiff and the children, and
intended to live elsewhere,
6. On or about October 24, 1994, the Defendant did, in fact,
move out of the marital household, and take up living in and
about the City of Harrisburg, Dauphin County, Pennsylvania.
7. Since the Defendant moved out of the marital home, he
(Defendant) has visited the Plaintiff and the children in the
marital home on Sunday afternoons, between the hours of
approximately 1 :00 p.m. and 8:00 p.m., on almost a weekly basis.
8. During recent discussions between the Plaintiff and the
Defendant, the Defendant informed the Plaintiff that he
2
(Defendant) was considering taking the children, in particular
the minor child Alexander Rafael Bellido (Alexander), age 3,
with him and returning to his native homeland, the country of
Peru, without the Plaintiff.
9. On Sunday, January 29, 1995, the Defendant was temporarily
visiting with the Plaintiff and the minor children, at the
marital home, at which time he (Defendant) made specific
inquires concerning the precise age of the minor child,
Alexandar, age 3, which information would be applicable in the
application for a passport for said child.
10. On Sunday, January 29, 1995, after making the said inquires
concerning the age of Alexander, the Defendant informed the
Plaintiff that he (Defendant) was intending on returning to his
native homeland (peru) in the next few weeks, and wanted to take
the minor child Alexander, with him (Defendant) for said trip.
11. When the Plaintiff refused to permit the Defendant to take
the minor child Alexander to Peru, as aforesaid, the Defendant
became visibly upset and terminated the conversation.
12. On Tuesday evening, January 31, 1995, during a telephone
conversation between the Plaintiff and Defendant, the Defendant
informed the Plaintiff that when he (Defendant) obtained
sufficient money for a divorce action, that he (Defendant) was
intending on fighting for his son (Alexander), and that he
(Defendant) would kidnap the said minor child Alexander, and
return to his native homeland (Peru) with said child.
3
13. During the aforesaid telephone conversation between the
parties on Tuesday, January 31, 1996, the Defendant informed the
Plaintiff that he (Defendant) would make arrangements to have
his (Defendant's) mother raise the said minor child Alexander in
his native homeland (Peru).
14. During the aforesaid telephone conversation between the
parties on Tuesday, January 31, 1995, the Defendant informed the
Plaintiff that he (Defendant) was prepared to go to the home of
the childrens' babysitter, Nancy I. Williams, located at 12
Briar Lane, Lower Allen Township, Cumberland County,
Pennsylvania, and take the minor child Alexander, and not to
return said minor child to the custody and care of the
Plaintiff.
15. The Plaintiff belioves, and therefore avers, that the
Defendant owns and possesses a firearm.
18. The Defendant's recent business and employment endeavors
have not been successful, and he (Defendant) does not have
significant ties to the local community, other than the said
children.
17. The Defendant's rights to visitation with the Plaintiff and
the children would not be harmed by the entry of an Order
whereby the status QUO would be maintained between the parties
pending a final disposition of the issues by this Honorable
Court.
18. If the Defendant were to take the children from the custOdy
and care of the Plaintiff, and transport them to a foreign
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county, i,e., Peru, the Plaintiff would be without the resources
neces8~ry to recover the custody of her ohildren.
19. The Defendant, in the past, has committed and threatened
violence against the person of the Plaintiff when the Plaintiff
did not submit to the will of the Defendant, and the Plaintiff
believes, and therefore avers, that if the wi thin Application
For Special Relief is not granted immediately, that the
Defendant, upon service of a copy of the Complaint for Custody,
will take steps to deprive the Pia inti tt of the children, as
aforesaid.
WHEREFORE, the Plaintiff, Zoe Marie Sterner-Bellido,
respectfully requests this Honorable Court to issue an Order
immediately, whereby the Plaintiff, Zoe Marie Sterner-Bellido,
is temporarily awarded full legal and physical custody ot the
children, Sarah Giovanna Bellido, Alexander Rafael Bellido,
Brianna Fanua Bellido, and Elizabeth Gabina Bellido, pending
further determination of this Court, and that the Defendant,
Rafael Bias Bellido, is permitted to continue to have supervised
Visitation with the parties' minor children in the marital home,
looated at 879 Mandy Lane, Camp Hill, Hampden Township,
Cumberland County, Pennsylvania, on Sunday afternoons, between
the hours of 1:00 p.m. and 6:00 p.m., and at such other times as
the parties may mutually agree i and that the Defendant is
specifically prohibited from removing or attempting to remove
the said children from the custody and care of the Plaintiff, or
from this Commonwealth; and that any and all passports or other
Visa type documents be immediately surrendered to the Oourt.
And she will forever pray.
5
Respectfully submitted,
OLARK LAW ASSOCIATES, P.C.
825 Fishburn Road
Post Office Box 555
Hershey, Pennsylvania 170~3.0556
Telephone: (717) 533-4049
Facsimile: (717) 533.660B
Datedt Februar~ ~, 1995
VERIFICATION
I HEREBY VERIFY that the facts and statements made in the
foregoing Application For Special Relief are true and correct to
the best of my knowledge, information and belief. I understand
that false statements therein are made subject to the penalties
of 18 Pa.C.S.g4904, relating to unsworn falsification to
authorities.
Dated t .;') i 'i ,)
/:1)/)""" ,fit"",. /)t't'..t"
,oe Marie sterner.Bellido, Plaintiff
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ZOE MARIE STERNER-BELLIDO,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
FAMII. Y DIVISION
NO. 15--- (; of;:, C)_~v.LL j OA..-yr'--/
CIVIL ACTION - LAW
IN CUSTODY
RAFAEL BLAS BELLIDOb
ofondant
ORDER OF COURT
-~
AND NOW, to wit, this ~ day of -1.--" bruc,rf ,1995, upon
oonsideration of the attaohed Complaint for Custody, IT IS HEREBY
ORDERED, that the parties (and their respeoUve oounsels appear before
~:..",,<'\..(,I L. Andc-) , Esquire, the Conoiliator,
at ,~-~,,- AI, 11)..t", ')t. Lt-(hl>\//1('
Pennsylvania, on J",w!t:L..'1 ,the lisP,' day of _~~\r,h _,
1995, at I o'olook, p m., for a Pre.Haaring Custody
Conferenoe. At suoh conference, an effort will be made to reeolve the
issues in dispute; or it this cannot be accomplished, to define and
narrow the issues to be heard by the COUt't, and to enter into a Temporary
Order. Either party may bring the children who are the subject of this
custody action to the conference, but the child's attendance is not
mandatory. Failure of a party to appear at the conference may provide
grounds for entry of a Temporary or Permanent Order.
FOR THE COURT:
Date of Order:
'd.;r.qr
.,,~ ~.~~
us 0 y Cono 11a or 7
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONEJ 00 TO OR TELEPHONE THE OFFICE SET
~ORTH BELOW TO FIND OUT WHERE YOU ~AN OET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
COUR1.tlOUSE 4TH FLOOR
CARLISLEL PENNSYLVANiA 17013
(717) 240-6200
G. The Plaintiff seeks custody of the following children:
NAME. PRESE~T RESIQe~CE AGE.
Sarah Giovanna Bellido 879 Mandr Lane 5
Camp Hil , PA 17011
Alexander Rafael Bellido 879 Mandr Lane G
Camp Hil , PA 17011
Brianna Fanua Bellido 879 Mandr Lane 2
Camp Hil , PA 17011
Elizabeth Gabina Bellido 879 Mandr Lane 4 M>.
Camp Hil , PA 17011
(a) The children were not born out of wedlock.
(b) The children are presently in the custody of the
Plaintiff, loe Marie Sterner-Bellido, who resides at 879
Mandy Lane, Camp Hill, Hampden Township, Cumberland
county, pennsylvania 17011.
(c) During the past five (5) years, the children have
resided with the following persons and at the following
addresses:
tiAMe.
Rafael BlaB Bellido a
loe Marie Sterner-Bellido
Rafael BlaB Bellido a
loe Marie 8terner-Bellido
Zoe Marie Bterner-Bellido
ADDRESSES
5145 E. Trindle Rd.
Mechanicsburg, PA
879 Mandy Lane
Camp Hill, PA
879 Mandy Lane
camp Hill, PA
2
DATEe
Dec.'89 to
June '92
June '92 to
Oct. '94
Oct. '94 to
present
(d) The natural mother of the ohildren is the Plaintiff,
loe Marie Bterner-Bellido, who resides at 879 Mandy Lane,
Camp Hill, Hampden Township, Cumberland County,
Pennsylvania 17011. The Plaintiff is married to the
Defendant.
(e) The natural father of the ohildr'en is the Defendant,
Rafael Blas BeUido, last known to reside at 318 South
Fourteenth Street, City of Harrisburg I Dauphin County,
Pennsylvania 17101. The Defendant is married to the
Plaintiff.
4. The relationship of the Plaint! ff to the ohildren is
that of natural mother. The Plaintiff currently resides with
the ohildren, as aforesaid.
5. The relationship of the Defendant to the ohildrerl is
that of natural father. It is unknown if the Defendant
currently resides with any other persons.
6. Plaintiff has not partioipated as a party or witness,
or in another oapaoity, in other litigation oonoerning the
custody of the ohildren in this or any other oourt.
( a) Plaintiff has no information of a oustody proceeding
conoerning the ohildren pending in a court of this
Commonweal th .
(b) Plaintiff knows of no persons not parties to the
prooeedings who have physical custody of the children or
3
lOE MARIE STEANER-BELLIOO,
Plaintiff
v.
IN THE COUAT OF COMMON PLEAS
CUMBERLAND COUNTY; PENNSYLVANIA
FAMILY DIVISION
NO. 96 . 606
CIVIL ACTION . LAW
IN CUSTODY
RAFAEL BLAS BELLIOOb
efendant
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c.E.BI.lfl.CAI.~
I, Lawrence F. Clark, Jr., Esquire, hereby certify that I
have this 6th day of February, 1995, served a Custody Order in
the above-captioned matter by personally delivering the same to
the following t
Sheriff of Cumberland County
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 1701G
Desk Off icer
Hampden Township Police Department
2GO Sporting Hill Road
Mechanicsburg, PA 17055
Desk Officer
Lower Allen Township Police Department
199G Hummel Avenue
Camp Hill, PA 17011
Desk Officer
Pennsy vania State Police Barracks
1501 Commerce Avenue / ! , '/''>/,)'
carlisle, PA 1701 G ,'_ I ' ~,/' /
I' ) ""') ~. ~ I
By: (. ,',.", I ,
rence. ar r.
CLARK LAW ASSOCIATES,'
825 Fishburn Road
Post Office Box 555
Hershey! PA 1703G-0556
(717)+/5"G-4049
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w'" DQ fll~I8Y C'RTIFY TtI~T
t~\ ... nllN III A TKu< AND COR
"loT '':OPY OF Tm, O~IOINAL
'ILIO IN nus ACTION
1j;;::-.-7.TlrJANIY.'..
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ZOE MARIE STERNER.BELLIDO,
Plaintiff
v,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
FAMILY DIVISION
NO, 7r , (J {,
CIVIL ACTION . LAW
IN CUSTODY
RAFAEL BLAS BELLIDO b
efondant
ORDER OF COURT
AND NOW, to wit, this "i"'{ day of' /1.,/,,,i3J;'
upon consideration of the attached Appli~tion For
Relief, IT IS HEREBY ORDERED I that pending a fu rther
this Court,
, 1995,
Special
Order of
1. The Plaint~ff, Zoe Marie Sterner-Bellido, is awarded full
legal and physical custody of the minor children of the parties,
tv wit: Sarah Giovanna Bellido, Alexander Rafael Bell1do,
Brianna Fanua Bellido, and Elizabeth Gabina Bellido, subject to
the following rights of visitation for the Defendant, Rafael
Blas Bellido:
a. The Defendant I Rafael Blas Bellido, shall be permitted
to have supervised visitation With the said children in the
parties' marital home I located at 879 Mandy Lane, Camp
Hill, Hampden Township, Cumberland County, Pennsylvania, on
Sunday afternoons, between the hours of 1 :00 p.m. and 6:00
p ,m. I and at such other timl!lS as the parties may mutually
agree.
2 , Neither the Defendant, nor any other person I shall remove
or attempt to remove the said children from the said custody and
care of the Plaintiff.
...
3 . Neither the Defendant, nor any other person, shall remove
or attempt to remove the said minor children from this
Commonwealth and/or the United States of America.
4, Any and all passports or similar type visa documents which
have been issued for the parties' minor children, to wit: Sarah
Giovanna Bellido, Alexander Rafael Bellido, Brianna Fanua
Bellido, and Elizabeth Gabina Bellido~ are hereby specifically
ordered to be surrendered immediately to this Courtj and the
parties, or any person acting on behalf of the parties, are
hereby specifically directed not to apply for a passpor't or
similar visa type document for said minor children, without the
specific written permission of this Court.
5. A copy of this Order shall be immediately served upon the
Sheriff of Cumberland County, the Hampden Township Police
Department, the Lower Allen Township Police Department, and the
pennsylvania State Police, for notice and enforcement.
6. A copy of this Order shall also be immediately forwarded to
the United States Department of State, for the purpose of
enforcement of that portion of this Order pertaining to the
custody of any and all passports or other visa type documents
which may have been issued to the parties' minor children, to
wit: Sarah Giovanna Bellido, Alexander Rafael Bellido, Brianna
Fanua Bellido, and Eli!ab~~h ~nbina Eel11do,
BY THE COURT:
TRUt; COpy I~ROM RECORt>
In rliatlm(lfl~ whflr'Ji)!, f h~r~ lln!1'l ;,oJlmy ~"In(j
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ZOE MARIE STERNER.BELLIDO,
Plaintiff
v,
. IN THE COURT OF COMMON PLEAS
CUMBERLANDCOUNTY,PENNSYLVANIA
FAMILY DIVISION
NO, q j' ,- &oc, e (,(}.I.,( .J LLff\--
CIVIL ACTION . LAW
IN DIVORCE
RAFAEL BLAS BELLIDO b
efendant
NOTICE TO DEFEND AND CLAIM ALL RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against
the claims set forth in the following pages, you must take
prompt action within twenty (20) days, You are warned that if
you fail to do so, the case may proceed without you and a decree
of divorce or annulment may be entered against you by the court.
A judgment may also be entered against you for any other claim
or relief requested in these papers by the Plaintiff. You may
lose money or property or other rights important to you,
including custody or visitation of your children.
When the ground for the divorce is indignities or
irretrievable br~akdown of the marriage, you may reguest
marriage counseling. A list of marriage counselors is available
in the Office of the Court Administrator, Fourth Floor,
Cumberland County Courthouse, 1 Courthouse Square, Carlisle,
Pennsylvania,
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNULMENt IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF
THEM,
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.
Court Administrator
4th Floor, Cumberland County Courthouse
1 Courthouse Square
CarliSle, Pennsylvania 1701a
Telephone: 117/240-6200
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ZOE MARIE STERNER-BELLIDO,
. PlainU ff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
FAMILY DIVISION
NO. 96 - 606
CIVIL ACTION - LAW
IN DIVORCE
RAFAEL BLAS BELLIOO b
, efendant
I, Gail C. Balliet, Legal Assistant in the firm of Clark Law
Associates, P,C., hereby certify that I have this 27th day of
February, 1995, served a final Order in re: Pet! tion for
Special Relief in the above - captioned matter by deposi Ung a
true and correct copy of same in the U,S. mail, postage pre-
paid, addressed as follows:
Rafael Blas Bellido
318 South 14th Street
Harrisburg, PA 17101
BYl
,~h..l C & t f,;}-
lam. Balt(~
tegal Assistant
CLARK LAW ASSOCIATES, P.C.
$26 Fishburn Road
Post Offioe Box 65~
Hershey! PA 17033.0556
(717)+/533-4049
2. The Father shall have the right to periods of temporary
custody of the children, as follows:
A, WIlkindI: The Father shall have the right to have the
children on two (2) weekends per month, beginning in June,
1995, from Saturday evening, not earlier than 6:00 pm,
until Sunday evening, not later than 7:00 pm. Said pickup
and delivery time shall include a two (2) hour window
period from 5: 00 pm to 7: 00 pm on Saturday evening and
likewise from 6:00 pm to 7:00 pm on Sunday evening, during
which time the Father shall personally pick up the children
from the Mother's residence and shall personally deliver
the children to the Mother's residence. The Father shall
give the Mother at least five (5) days advance notice of
the weekend (s) that he wishes to exercise his right to
temporary custody, as aforesaid.
The Father shall have suitable and reasonable living,
sleeping, and eating facilities for the children whom he
opts to have during such weekend periods, and further, he
shall either personally supervise the activities of said
children during such temporary custody periods, or have the
children properly supervised by an adult person who is
known to and approved by the Mother. The Father may take
less than all four (4) minor children at one time for his
weekend periods of temporary custody,
The Mother shall provide the children with suitable
clothing and related necessities for their periods of
visitation with the Father, and said clothing and other
items shall be returned to the Mother when the children are
2
returned by the Father, as aforesaid. The Father shall
give the Mother reasonable advance notice of any special
circumstance or condition which may require specific
clothing or other necessities for the children,
B,~: The children shall remain with their Mother
during the family holidays of New Year's Eve, New Year's
Day, Easter Sunday, Thanksgiving Day, Christmas Eve, and
Christmas Day. The Father shall have the right to visit
with the children' at the residence of the Mother during
those family holidays, on such terms and at such times as
the parties may mutually agree.
The parties shall also share the holidays of Memorial
Day, Independence Day and labor Day, on which holidays the
Father shall have the right to have temporary custody of
the children, during such times, and according to such
terms as the parties may mutually agree, The Father shall
personally pick up and deliver the children at the
residence of the Mother on such holidays.
C, Other Times: The Mother and Father may arrange such
other times of either temporary custody and/or visitation
as they may mutually agree, However, no such additional
periods of temporary custody and/or visitation shall be
deemed or otherwise construed as a waiver or permanent
modification of the terms and conditions of this Order.
G, The Father shall be permitted to take a child or children
away from the vicinity of Harrisburg, pennsylvania, for a
distance not greater than two hundred fifty (250) radius miles
G
from Harrisburg, for on aforesaid period of temporary custody,
wi thout the specific permission of the Court. However, the
Father shall not, under any circumstances, take, or attempt to
take, any of the children from the continental United States of
America.
4. Neither the Mother nor the Father, nor any person acting
either directly or indirectly on behalf of either party, shall
have, obtain or attempt to obtain a passport for any of the said
children, without the speoifio permission of the Court.
6. The Father shall continue to pay support for the children
through agreement of the parties, or as a Court may hereafter
direct. The Father shall also proVide full medical , hospital,
dental, vision and prescription insurance for the children, as
may be available through the Father's employer. And in any
event, the Father shall be responsible for the payment of any
uninsured, medical, hospital, dental, vision and prescription
expenses for said children which are not covered by any
available health insurance.
8. This Order shall amend and supersede the previous Order
issued by this Court, dated February 3, 1995.
7, A copy of this Order shall be served upon the Sheriff of
Cumberland County, the Hampden Township Police Department, the
Lower Allen Township Police Department, and the Pennsylvania
State Police, for notice and enforcement, as may be required,
6, A copy of this Order shall also be forwarded to the United
States Department of State, for the purpose of enforcement of
4
3. The parties are the natural parents of the following minor
children:
$arah Giovanna Bellido
Alexander Rafael Bellido
Brianna Fanua Bellido
alizabeth Oabina Bellido
Born on December' 29, 1989
Born on September 1, 1991
Born on January 17, 1993
Born on Ootober 1, 1994
4, On February G, 1995, the Plaintiff, Zoe Marie Sterner-
Bellido, filed a Consolidated Complaint In Divorce and a
Complaint For Custody, against the Defendant, Rafael Bla8
Bellido, in Cumberland County, Pennsylvania, both actions being
docketed to Civil Action No. 95-606,
6, In addition to the aforesaid Divorce and Custody actions,
the Plaintiff, Zoe Marie Sterner-Bellido, filed ~n Application
For Special ReUef concerning the custody of said children,
which Application was granted by the Court, on February 3, 1996,
wherein the said Plaintiff was temporarily granted full legal
and physical custody of the said minor children, and further
providing for limited Bupervised visitation of the said minor
children by the Defendant, Rafael Bla8 Bel11do, and also
providing for certain other restrictions and limitations
concerning the said Defendant's access to, control of, and
transportation of said minor children.
8. The parties have had an opportunity to consider and discU8S
the continuing custody of their said minor children, and have
entered into a Stipulation For Custody concerning the legal and
physical custody of the said children, dated May 30, 1995,
attached hereto, and marked as Exhibit "A".
2
IxhIbIt A
G. The parties are the natural parents of the following minQr
ohildren:
Sarah Giovanna Bellido
Alexander Rafael Bellido
Brianna Fanua Bellido
Elilabeth Gabina Bellido
Born on December 29, 1989
Born on September 1, 1991
Born on January 17, 1993
Born on October 1, 1994
4, On February 3, 1995, the Plaintiff, Zoe Marie Sterner-
Bellido, filed a Consolidated Complaint In Divorce and a
Complaint For Custody, against the Defendant, Rafael Bla8
Bellido, in Cumberland County, pennsylvania, both actions being
docketed to Civil Action No. 95-606.
5. In addition to the aforesaid Divorce and Custody actions,
the Plaintiff, loe Marie Sterner..Bellido, filed an Application
For Special Relief concerning the custody of said children,
which Application was granted by the Court, on February G, 1995,
wherein the said Plaintiff was temporarily granted full legal
and physical custody of the said minor children, and further
providing for limited superVised visitation of the said minor
ohildren by the Defendant, Rafael Blas Bellido, and also
providing for certain other restrictions and limitations
concerning the said Defendant's access to, control of, and
transportation of said minor children.
6. The parties have had an opportunity to consider and discUS8
the continUing custody of their said minor children, and now
wish to enter into this Stipulation concerning the legal and
physical oustody of the said children, as follows:
2
A. The Mother, Zoe Marie Sterner-Bel11do, shall have full
legal and physical custody of the parties' minor children,
Sarah Oiovanna Bellido, Alexander Rafael Bellido, Brianna
Fanus Bel11do, and Elizabeth Oab~na Bellido, subject to the
hereinafter stated riQhts of the Father, Rafael Bla8
Bellido, to periods of temporary custody and visitation.
B. The Father shall have the right to periods of temporary
custody of the children, as follows:
Weekends: The Father shall have the right to have the
children on two (2) weekends per month, beginning in
June, 1995, from Saturday evening, not earlier than
5:00 pm, until Sunday evening, not later than 7:00 pm.
Said pickup and delivery time shall include a two (2)
hour window period from 5:00 pm to 7:00 pm on Saturday
evening and likewise from 5:00 pm to 7:00 pm on Sunday
evening, during which time the Father shall personally
pickup the children from the Mother's residence and
shall personally deliver the children to the Mother's
residence, The Father shall give the Mother at least
five (6) days advance notice of the weekend(s) that he
wishes to exercise his right to temporary custOdy, as
aforesaid.
The Father agrees to have suitable and reasonable
living, sleeping, and eating facilities for the
children which he opts to have during such weekend
periods, and further agrees to either personally
supervise the activities of said children during such
temporary custody periods, or have the children
3
properly supervised by an adult person who is known to
and approved by the Mother. It is also understood and
agreed that the Father may take less than all four (4)
minor children at one time for his weekend periods of
temporary custody.
The Mother shall provide the children with
suitable clothing and related necessities for their
periods of visitation with the Father, and said
clothing and other items shall be returned to the
Mother when the children are returned by the Father,
as aforesaid. The Father shall give the Mother
reasonable advance notice of any special circumstance
or condition which may require specific clothing or
other necessities for the children.
Holidays: The children shall remain with their Mother
during the family holidays of New Year's Eve, New
Year's Day, Easter Sunday, Thanksgiving Day, Christmas
Eve, and Christmas Day, The Father shall have the
right to visit with the children at the residence of
the Mother during those family holidays, on such terms
and at such times as the parties may mutually agree,
The parties shall also share the holidays of
MeMorial 'Day, Independence Day and Labor Day, on which
holidays the Father shall have the right to have
temporary custody of the children, during such times,
and according to such terms as the parties may
mutually agree. The Father shall personally pickup
4
and deliver the children at the residence of the
Mother on such holidays.
Other Times: The Mother and Father may agree to such
other times of either temporary custody and/or
visitation as they may mutually agree, tiowever, no
such additional periods of temporary cllstody and/or
visitation shall be deemed or otherwise construed as
a waiver or permanent modification of the terms and
conditions of this Stipulation.
7, The Father shall be permitted to take a child or children
away from the vicinity of Harrisburg, Pennsylvania, for a
distance not greater than two hundred fifty (250) radius miles
from Harrisburg, for an afores~id period of temporary custody,
without tile specific permission of the Court. However, the
Father shall not, under any circumstances, take, or attempt to
take any of the children from the continental United States of
America,
8, Neither the Mother nor the Father, nor any person acting
either directly or indirectly on either of their behalfs, shall
have, obtain or attempt to obtain a passport for any of the said
children, without the specific permission of the Court.
9, The Father shall continue to pay support for the children
through agreement of the parties, or as a Court may hereafter
direct, The Father shall also prov,ide full medical, dental,
v,18ion and prescription insurance for the children, as may be
available through the Father's employer. And in any event, the
Father shall be responsible for the payment of any uninsured,
5
medioal, hospital, dental, vision and prescription expenses for
said children which are not covered by any available health
insurance.
10. Both parties acknowledge and oonfirm that they have had the
full and complete opportunity to consult with legal counsel
ooncerning. the terms, condi tions and meaning of this
Stipulation, and that they are executing this Stipulation as
their free, knowing and voluntary act, and intend to be legally
bound hereby.
3 'I/....
IN WITNESS WHEREFORE, on this- 0 day of May, 1996, the
Plaintiff/Mother, loe Marie Sterner-Bellido, and the
Defendant/Father, Rafael BlaB Bellido, have executed this
Stipulation, oonsisting of six (6) typewritten pages, and
respectfully request the Court to accept thiB Stipulation
concerning the custody of their minor children, Sarah Giovanna
Bellido, Ale~ander Rafael Bellido, Brianna Fanua Bellido, and
Elizabeth Gabina BelUdo, and to enter an Order whereby the
terms and conditions of this Stipulation are made an Order Of
Court.
WITNESS:
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lOE MARIE STERNER-BELLIDO,
Plaintiff
v,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
FAMILY DIVISION
NO. 96 - 606
CIVIL ACTION - LAW
IN CUSTODY
RAFAEl.. BLAS BELLIOO b
efendant
Cf8Ilf.I..CAIf~
I, Gail C. Balliet, Legal Assistant in the firm of Clark Law
Associates, P.C" hereby certify that I have this 5th day of
June, 1996, served a Custody Order in the above-oaptioned matter
by depositing a true and correct copy of same in the U,S. mail,
postage pre-paid, addressed as follows:
Rafael Blas Bellido
498 High Street
Elizabethtown, PA 17022
Sheriff of Cumberland County
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
Hampden Township Police Department
230 Sporting Hill Road
Mechanicsburg, PA 17055
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Lower Allen Township Police Department
1993 Hummel Avenue
Camp Hill, PA 17011
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Penn8ylvan1a State Police Barraok8
1601 Commeroe Avenue
Oarlisle, PA 17013
United States Department of State '
OfUce of Passport Policy and Advisory Servioes
Room 260
1111 19th Street NW
Washington, DC 20522
BYI ~4fi~1 ~ Plt{ltcl-
Gill C. Balliett egal Assistant
CLARK LAW ASSOCIATES, P,C.
825 Fishburn Road
Post Office Box 555
HersheYl PA 17033-0556
(717)+5\:13-4049
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