HomeMy WebLinkAbout00-03512
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PATRICIA A. HANES
PLAINTIFF
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ROBERT A. HANES
2000-3512 CIVIL ACTION LAW
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, this 12th day of June ,2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear befonMelissa P. Greevy, Esq. ,the conciliator,
at 214 Senate Avenue, Snite 105, Camp Hill, PA 17011 on the 11th day of Jnly , 2000, at 9:15 AM
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.
FOR TIlE COURT,
By: Isl
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
HA VB 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
DANIELLE MARKLEY
IN THE COURT OF COMMON PLEAS OF
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PATRICIA A. HANES,
Plaintiff
vs.
)
)
)
)
)
)
)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
ROBERT A. HANES,
Defendant
CIVIL ACTION - LAW
NO. C-O-35/;2 ~
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 , Esquire, the conciliator at
, 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
I by the court, and to enter into a temporary order. Either party may bring the child who is the
I
I. subject of this custody action to the conference, but the child'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,
Custody Conciliator
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) 249-3166
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PATRICIA A. HANES,
Plaintiff
vs.
)
)
)
)
)
)
)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
ROBERT A. HANES,
Defendant
OVIL ACTION - LAW
gg _ 3.:.-/.l.. &;;J 74.v--
NO.
COMPLAINT IN CUSTODY
AND NOW comes the Plaintiff, PATRICIA A. HANES, by her attorney, Samuel L. Andes,
and makes the following Complaint for Custody:
1. The Plaintiff is PATRICIA A. HANES, an adult individual who resides at 328 Black Latch
Lane in Camp Hill, Cumberland County, Pennsylvania.
2. The Defendant is ROBERT A. HANES, an adult individual who resides at 4 Fox Run in
Hummelstown, Dauphin County, Pennsylvania.
3. The Plaintiff and Defendant are husband and wife and were married on 12 September
1981 in Steelton, Pennsylvania.
4. The Plaintiff and Defendant are the parents of two minor children, Nicole C. Hanes
born 26 March 1985 and Amy M. Hanes born 9 July 1989.
5. Plaintiff seeks custody of the said minor children, Nicole C. Hanes and Amy M. Hanes.
6. The children were not born out of wedlock and are presently in the custody of the
Plaintiff.
7. During the past five years, the minor children have resided with the following persons
at the following addresses:
Mid May 2000 to present
328 Black Latch Lane
Camp Hill, PA 17011
Plaintiff
11/1/1998 to Mid May 2000
328 Black Latch Lane
Camp Hill, Pa 17011
Plaintiff & Defendant
1995 to 10/31/ 1998
213 Allendale Way
Camp Hill, PA 17011
Plaintiff & Defendant
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8. The mother of the children is the Plaintiff who resides at the address set out above.
She is married to the Defendant.
9. The father of the children is the Defendant who resides at the address set out above.
He is married to the Plaintiff.
10. The Plaintiff is the natural mother of the children. Plaintiff currently resides with the
. children.
11. The Defendant is the natural father of the children. Defendant currently resides at 4
Fox Run in Hummelstown, Pennsylvania, with his parents Charlotte Hanes and Chaires Hanes, II.
Further details of the Defendant's living arrangements are not presently known to Plaintiff.
12. The Plaintiff has not participated as a party or in any other way in any litigation
concerning the custody of the children in this or any other court.
The Plaintiff has no information of a custody proceeding concerning the children pending
in a court of this or any other jurisdiction.
Plaintiff knows of no other person not a party to this action already who has physical
custody of or claims to have custody or visitation rights to the said children.
13. The best interests and permanent welfare of the children will be served by granting
the relief requested by Plaintiff for the following reasons:
A. She has been the primary care provider for the children during all of
their lives and a continuation of that arrangement is in the best interest of the
children; and
B. The father has a disruptive influence on the daughters, particularly
Nicole, which interferes with Nicole's school attendance, school performance, and
other behavior and which represents a detriment to both children; and
C. Plaintiff is the parent best able to provide a stable and supportive
environment for the children and the fostering healthy parent-child relationship
I with both parents for the children.
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14. 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, PATRICIA A. HANES, requests this Court to grant her custody of the
children, Nicole C. Hanes and Amy M. Hanes.
8 (}PC) ~
Samuel L. Andes
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 1th Street
Lemoyne, Pa 17043
(717) 761-5361
II
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COMMONWEALTH OF PENNSYLVANIA )
( 55.:
COUNTY OF CUMBERLAND )
PATRICIA A. HANES, being duly sworn according to law, deposes and says that the facts
set forth in the foregoing Complaint for Custody are true and correct to the best of her
knowledge, information, and belief.
P a1JuCiaJ ClJ. ~
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PATRICIA A. HANES
Sworn to and subscribed
bef~ ~~~hiS Bh day
of ~ \lL , 2000.
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SEP 18 20~
PATRICIA A. HANES,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VAN IA
NO. 00-3512
ROBERT A. HANES,
Defendant
CIVIL ACTION - LAW
CUSTODY
ORDER OF COURT
BAYLEY, J.,
AND NOW, this R. day of ~ ,2000, upon consideration of the
attached Custody Conciliation Summary Report and agreement of the parties, the following
Order is entered:
1. LeQal Custody: Patricia A. Hanes, the Mother, and Robert A. Hanes, the Father,
shall have shared legal custody of their minor Children, Nicole C. Hanes, born March 26, 1985,
and Amy M. Hanes, born July 9,1989. Each parent shall have an equal right, to be exercised
jointly with the other parent, to make all major non-emergency decisions affecting the Children's
general well-being including, but not limited to, all decisions regarding their health, education
and religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all
records and information pertaining to the Children including, but not limited to, school and
medical records and information. To-.!~e extent one parent has possession of any such records
or information, that parent shall be required to share the same, or copies thereof, with the other
parent within such reasonable time as to make the records and information of reasonable use
to the other parent.
2. Physical Custody: Primary physical custody of the Children shall be with Mother
subject to partial custody in Father as follows:
A. To commence on October 7,2000, Father shall have partial custody on
alternating Saturdays from 11 :00 AM to 6:00 PM;
B. Father shall enjoy partial physical custody at other such times as the
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NO. 00-3512
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parties may mutually agree. In the absence of the ability to communicate
by telephone or in person, the parties shall communicate regarding
additional custody arrangements for Father via e-mail, fax, or letter.
BY THE COURT,
J.
Disl: James A. Miller, Esquire, 513 N. Second Street, Suite 100, Harrisburg, PA 17 1
Samuell. Andes, Esquire, 525 N. 12th Street, Lemoyne, PA 17043 Y
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CUM8Efi.AND COUN1Y
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SEP 18 2Q~
PATRICIAA. HANES,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-3512
ROBERT A. HANES,
Defendant
CIVIL ACTION - LAW
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 CUSTODY OF
Nicole C. Hanes
Amy M. Hanes
March 26, 1985
July 9, 1989
Mother
Mother
2. A Conciliation Conference was held on September 7, 2000, with the following
individuals in attendance: Patricia A. Hanes, the Mother, and her counsel, Samuel L. Andes,
Esquire; Robert A. Hanes, the Father, and his counsel, James A. Miller, Esquire.
~;i:;totooe"~
Date Melissa Peel Greevy, Esquire
Custody Conciliator