The URL can be used to link to this page

Home My WebLink About00-00701 ERIC W, HOERNER, Plaintiff v, BEVERLY J. HOERNER, Defendant TO THE PROTHONOTARY: . "jjgj : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2000-701 : IN CUSTODY PRAECIPE Please withdraw the Custody Complaint filed on behalf of the Plaintiff in the above captioned matter. (.)~tUJl: ..2 /7/ oc) Respectfully submitted, . e, Esquire ey or Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 s_mil'm1dl'lJ!jJHihm~&*~\ii~~"rn;1-ll-,~~m"""<I"'-~<I",jM:illII~~~~ IIliIII 0*"" .-<="' " 11 ft ~ ,. , , I n i (") 0 C2 C 0 OJ :;;: .." -oCD m OJ rnrn CO "'7 ~'r r';;;; .e;.._._'/ 21:' I ::_:~? CfJ.- "'~ ;: -.J ;::~C' '::::;C) '< ,.. V ~/ -" ~O -"".~ ~~~ ~C' )>C~ t"" 2: -oj w .". =< :0 .;;- -< - '-'~"n ' .' ERIC W. HOERNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. CIVIL ACTION - LAW : NO. .;lQXl' 7()f CIVIL TERM BEVERLY 1. HOERNER, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the conciliator, at Cumberland County, Pennsylvania, on the day of , 2000, at o'clock ,m., 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. Either party may bring the children who are the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent Order. BY THE COURT: By: Custody Conciliator ~,~ i_ I. - 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 (717) 240-3166 ~------~ .~ - " .I "'''''''~.H. ERIC W. HOERNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. CIVIL ACTION - LAW : NO, CIVIL TERM BEVERLY J. HOERNER, Defendant : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Eric W. Hoerner, an adult individual currently residing at 102 Mooredale Road, Carlisle, Cumberland County, Pennsylvania, 2. Defendant is Beverly J. Hoerner, an adult individual whose last known address was 102 Mooredale Road, Carlisle, Cumberland County, Pennsylvania, but who vacated that residence on January 31, 2000, without specific notice being given to Plaintiff as to her new address. 3, The parties are the natural parents of two (2) children, namely, Adam Wesley Hoerner, born, August 10, 1982, and Benjamin John Hoerner, born October 16, 1988, The children were not born out of wedlock. The natural mother of the children is the above-named Defendant, Beverly J. Hoerner, who resides as aforesaid. She is married. The natural father of the children is the above-named Plaintiff, Eric W. Hoerner who resides as aforesaid. He is married, 4, The relationship of the Plaintiff to the children is that of natural father. The Plaintiff currently resides with the children. ........- p-"~~"'""'1llI ~ " 5. The relationship of the Defendant to the child is that of natural mother, The Defendant's last known address was 102 Mooredale Road, Carlisle, Cumberland County, Pennsylvania but her current address is unknown and the individuals with whom she may be residing are unknown as well. 6. Plaintiff has not participated as a party or witness or in any other capacity in any litigation concerning custody of the children. 7. Plaintiff has no information of any custody proceedings concerning the child pending in any Court of his commonwealth. 8. It is in the best interest and permanent welfare of the children to remain in Plaintiffs primary physical and legal custody in this action. 9. Plaintiff does not know any person not a party to these proceedings who claims to have custody or visitation rights with respect to the children. WHEREFORE, Plaintiff requests your Honorable Court to schedule a Custody Conciliation Conference followed by a hearing, at which time he should be granted primary physical and legal custody of the children, Respectfully submitted, GRIFFIE & ASSOCIATES ey L riffie, Esquire ttorney or Plaintiff 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 ~" ~- ~ . ~I\l,,", VERIFICATION I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING DOCUMENT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.s. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Date: (j'J.jD~~ ~ W. ~A./ Eric W, Hoerner, Plaintiff ....".:.;iltiIiitll::DJ~ .. '0 l"..."""'....~~~~m~~~t~ "" ~~ !~ liIli; ~ ~I b ~ \\:'1 ~ ~ ~ ~ ~ " ~ ~~~ l 1 o C $: -un,r n1n-, Z:1j /.:-'.:r;: (/),-- -<.-..- r:: c.~' ~f~ Pc z =<! " .~ o ::;:) -" M t:;J I -' o -n ;:.:i -T'\ j.J~~ '::~:1~ f:;f~ :::.~ 5~ -< ~ is .. 'D . "" '1 II II " I' I i1 i~ ij i! Ii Ij ii !i 11 il 11 '1 11 Ii II " I .I . ~ " .' .' ERIC W. HOERNER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. (}(XJ(;'IOI CIVIL TERM : IN CUSTODY BEVERLY J. HOERNER, Defendant ORDER OF COURT AND NOW, this day of , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the conciliator, at Cumberland County, Pennsylvania, on the day of , 2000, at o'clock _.m., 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 defme and narrow the issues to be heard by the Court 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 children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent Order. BY THE COURT: By: Custody Conciliator .' . . YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB 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 (717) 240-3166 ERIC W. HOERNER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW : NO. CIVIL TERM BEVERLY 1. HOERNER, Defendant : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Eric W. Hoerner, an adult individual currently residing at 102 Mooredale Road, Carlisle, Cumberland County, Pennsylvania, 2. Defendant is Beverly J. Hoerner, an adult individual whose last known address was 102 Mooredale Road, Carlisle, Cumberland County, Pennsylvania, but who vacated that residence on January 31, 2000, without specific notice being given to Plaintiff as to her new address, 3. The parties are the natural parents of two (2) children, namely, Adam Wesley Hoerner, born, August 10, 1982, and Benjamin John Hoerner, born October 16, 1988. The children were not born out of wedlock. The natural mother of the children is the above-named Defendant, Beverly J. Hoerner, who resides as aforesaid. She is married. The natural father of the children is the above-named Plaintiff, Eric W, Hoerner who resides as aforesaid. He is married. 4. The relationship of the Plaintiff to the children is that of natural father. The Plaintiff currently resides with the children. - " ~ I " 5. The relationship of the Defendant to the child is that of natural mother. The Defendant's last known address was 102 Mooredale Road, Carlisle, Cumberland County, Pennsylvania but her current address is unknown and the individuals with whom she may be residing are unknown as well. 6. Plaintiff has not participated as a party or witness or in any other capacity in any litigation concerning custody of the children. 7. Plaintiff has no information of any custody proceedings concerning the child pending in any Court of his commonwealth. 8. It is in the best interest and permanent welfare of the children to remain in Plaintiff's primary physical and legal custody in this action. 9. Plaintiff does not know any person not a party to these proceedings who claims to have custody or visitation rights with respect to the children. WHEREFORE, Plaintiff requests your Honorable Court to schedule a Custody Conciliation Conference followed by a hearing, at which time he should be granted primary physical and legal custody of the children. Respectfully submitted, GRIFFIE & ASSOCIATES . Grif ,Esquire ey for aintiff 200 North anover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 " " -.', 'I"' VERIFICATION I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING DOCUMENT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Date: &'),.fO'l.)'J.Ot>> ~ lt0. ~"<2A.I Eric W. Hoerner, Plaintiff . " ~ ~ _L,. - .,' -, ERIC W. HOERNER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAi'ID COUNTY, PENNSYL V Al'lIA vs. : CIVIL ACTION - LAW : NO. )OOO-lol CIVIL TERM BEVERLY J. HOERNER, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of , 2000, upon consideration of the attached Complaint; it is hereby directed that the parties and: their _. respective counsel. appear before the' conciliator, at Cumberland County, Pennsylvania, on the day of , 2000, at o'clock .m., 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. Either party may bring the children who are the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent Order. BY THE COURT: By: Custody Conciliator , . ~ .",- ...i-'-----'--'-_,__ ;' -",y' ".., " H 'I !j I 11 II Ii lJ II ("l .... to 'I " 0 " I ... N <: ij .... " n ,.... :<: ... , " '" 0 .... Ii .... 0 ':' 'I " ... " '-< 'I I '" :1 ." " :>- .... '" j " 0 I " i .... :>' ... ..... 0 " 0 " " 'I .... '" ... ,J '" [I d 'I :i ! I I ~ ,J ! V",--:. ,. ! c.' ".':~' ""'1 r .... ." tt: ,9~.... '\ r, ~~....~ l'l"~"'\~J _i" " ~~J~~~~~,~'~,) ~II ~II 1:I~t~ 00' l.N ,'i! ~1 ~ Illll ffiL.,.._"~~J(li1 .. ,~'~. " .', "'~. ~;,;, i"~" 't ~ , .-,' '~ t__ , , , ="r .t_ ......:, ., ERIC W. HOERNER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLA1.'ID COUNTY, PENNSYL VA1.'ITA : CIVIL ACTION - LAW : NO. ,;>-OOD ;')0 \ CIVIL TERM BEVERLY 1. HOERNER,. Defendant : IN CUSTODY ORDER OF COURT AND NOW, this ~ day of . 2000;. upon consideration of the attached Complain~ it is hereby directed: that the parties and: their respective counsel appear before the conciliator, at , Cumberland County, Pennsylvania, on the day of , 2000, at o'clock _.m., 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. Either party may bring the children who are the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent Order. BY THE COURT: By: Custody Conciliator ""t::l') o:m 0"""'" - ..., E?:z :::! ~CM '0 :J. "-l:O'QO !I" if ;;g6~ -<~ ~~n ..- (f';- tWlfP'"" ~ @~ ~ffl ~~j'i . "'" .. , .~ l, ~~' ,o,;:,,,~ "," "" ,-,,-.', ~~;'; i: Ii I: !'J n :,', I ~ "'I ii i! 1',] 1< !', I,; ,. '< , " i; !i 'j '1 i': 'j " i; "i 1;1 Ii , Ii II , :; Ii I , '1 , 1 , 1'1 ,/- ~-~ ~~;~;:,l III b';'~Jl ~ ~1\11 lJJ Il(H III rtln -,-=~~_,~1 ";.~ f.".'~..' -I~- ~;I I~..:jl '<'I x~_,,_~ "f ~ .)- '; <;~.~,,~,,~,.,>>~,