HomeMy WebLinkAbout00-03863
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SUSAN A. KARICHNER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
V.
ROBERT HILL
00-3863 CIVIL ACTION LAW
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, this 30th day of June ,2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator,
at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 17th day of July ,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 THE COURT,
By: Isl
Melissa P. Greevy. E~\
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
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JUN 26 20~
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SUSAN A. KARICHNER,
Plaintiff
v.
CIVIL ACTION - LAW
IN CUSTODY
NO. 2000- dPC..3 do~c.l~
ROBERT HILL,
Defendant
ORDER OF COURT
AND NOW, this
day of June, 2000, upon consideration of the attached
Complaint, it is hereby directed that the parties and their respective counsel shall appear before
, the Conciliator, at
on the
day of
, 2000 at
.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
TemporaryOrder. All children age five or older shall/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 THE COURT,
By:
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, P A 17013
(717) 249-3166
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SUSAN A. KARICHNER,
Plaintiff
v.
CIVIL ACTION - LAW
IN CUSTODY
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ROBERT HILL,
Defendant
NO. 2000-
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You are warned that if you fail to do
so the case may proceed without you and a judgment may be entered against you by the court without
further notice for any money claimed in the complaint or for any other claim or relief requested by
the plaintiff. You may lose money or property or other rights important to you.
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NOTICIA
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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
Le han demandado a usted en la corte. Si usted qui ere defenderse de estas demandas
expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo alpartir de la fecha de la
demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado
y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su
persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden
contra listed sin previo aviso 0 notificacion y por cualguier queja 0 alivio que es pedido en la peticion
de demanda. U sted puede perder dinero 0 sus propiendades 0 otros derechos importantes para usted.
LLEVE EST A DEMANDAA UN ABOGADO IMMEDIA TAMENTE. SINO TIENE ABOGADO
o SINO TIENE ELDINERO SOFICIENTEDEPAGAR TAL SERVICO, VA Y AEN PERSONAL
o LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRIT A
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ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
icl:lael J. Hanft, quire
Attorney ID No.5 976
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013-9142
(717) 249-5373
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SUSAN A. KARICHNER,
Plaintiff
v.
CIVIL ACTION - LAW
IN CUSTODY
NO.2000- 3ft,,3 ~ T'~
ROBERT HILL,
Defendant
COMPLAINT FOR PRIMARY CUSTODY
AND NOW, this :A. \,51' day of June, 2000, comes Plaintiff, SUSAN A. KARICHNER, by
and through her attorney, Michael 1. Hanft, Esquire, and files the following Complaint for Primary
Custody and in support thereof avers as follows:
I. The Plaintiffis Susan A. Karichner, an adult individual residing at 101 Clayhill Road,
Newburg, Cumberland County, Pennsylvania 17240.
2. The Defendant is Robert Hill, an adult individual residing at 22 East Orange Street,
Mt. Holly Springs, Cumberland County, Pennsylvania 17065.
3. The Plaintiff seeks primary custody and visitation of the following child:
Name
Cheyenne A. Hill
Present Residence
101 Clayhill Road
Newburg, P A 17240
Age
3
The child was born out of wedlock.
The child is presently in the physical custody of the Plaintiff, Susan A. Karichner.
In addition to the child's present address, during the past five years, the child has resided with
either Plaintiff or Defendant at the following addresses:
35 Broad Street, Newville, P A 17241
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The mother of the child is the Plaintiff, who resides at 101 Clayhill Road, Newburg,
Cumberland County, Pennsylvania.
The father of the child is Defendant, who resides at 22 East Orange Street, Mt. Holly Springs,
Cumberland County, Pennsylvania.
4. The relationship of Plaintiff to the child is that of mother.
5. The relationship ofthe Defendant to the child is that of father. Plaintiff believes and
therefore avers that the Defendant currently resides alone.
6. Plaintiff has not participated as a party or witness, or in any other capacity, in other
litigation concerning the custody of the child in this or another court.
The Plaintiff has no information of a custody proceeding concerning the custody of the child
in this or any other court.
The Plaintiff does not know of a person not a party to the proceedings who has physical
custody of the child or claims to have custody or visitation rights with respect to the child.
7. The best interests and permanent welfare of the child will be served best by granting
the relief requested because:
a) The Plaintiff has had primary physical and legal custody of the child since the child's
birth;
b) The Plaintiff provides the child with a home with adequate moral, emotional and
physical surroundings as required to meet the child's needs;
c) The Plaintiff is, and has always been, willing to accept custody of the child; and
d) The Plaintiff continues to exercise parental duties and responsibilities and enjoys the
love and affection of the child.
8. Each parent whose parental rights to the child have not been terminated and the
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person who has physical custody of the child has been named as parties to this action. There are no
other persons who are known to have or claim a right to custody or visitation of the child.
WHEREFORE, Plaintiff respectfully requests Your Honorable Court grant Plaintiff primary
physical and shared legal custody of Cheyenne A. Hill.
Respectfully submitted,
Mi ael J. Hanft, Es ire
Attorney ID No. 57976
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013-9142
(717) 249-5373
Attorney for Plaintiff
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Verification
I verifY that the statements made in the foregoing Complaint for Primary Custody are true
and correct to the best of my knowledge, information and belief. This Verification is made by
Plaintiff's counsel based upon information provided by Plaintiff to Plaintiff s counsel regarding the
factual averments contained herein. I understand that false statements herein are made subject to the
penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities.
F:\User Folder\Firm DQcs\Gendocs2000\1662-1verification. J .wpd
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JUL 2 0 ~~
SUSAN A. KARICHNER,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2000-3863
ROBERT HILL,
Defendant
CIVIL ACTION - LAW
CUSTODY
ORDER OF COURT
AND NOW, this 3()VIt\ day of ~ ' 2000, upon consideration of the
attached Custody Conciliation Summary R port, it is ordered and directed as follows:
1. The parties shall have shared legal custody of the minor child, Cheyenne A. Hill,
born April 2, 1997.
2. Mother shall have primary physical custody subject to Father's periods of
partial custody. Commencing on Friday, July 28, 2000, Father shall have partial custody of the
minor child from Fridays at 6:00 PM until Sundays at 6:00 PM.
3.
fashion.
Unless otherwise agreed, the parties shall share holidays in an alternating
4. Mother's Day shall be with Mother, Father's Day shall be with Father. The period
of custody for this day shall be from 9:00 AM until 6:00 PM.
5. The parties shall share transportation relative to the periods of custody with the
minor child. The party who is assuming physical custody of the child shall provide the
transportation at the beginning of their custodial period.
6. This Order is temporary in nature. Either party may return to the Conciliator for
an additional conference upon the appropriate petition to the Court.
BY THE COURT,
J.
cc:
Michael J. Hanft, Esquire, 19 Brookwood Avenue, Suite 106, Carlisle, PA 17013-9142
Robert Hill, Defendant, 22 East Orange Street, Mount Holly Springs, PA 17065
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SUSAN A. KARICHNER,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2000-3863
ROBERT HILL,
Defendant
CIVIL ACTION - LAW
CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
Cheyenne A. Hill
April 2, 1997
Mother
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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 Child who is the subject of this litigation
is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
2. A Custody Conciliation Conference was held on July 17, 2000, with the following
individuals in attendance: The mother, Susan A. Karichner, with her counsel, Michael J.
Hanft, Esquire. Counsel for the plaintiff reports that Father was served with a copy of the
Order by Certified Restricted Delivery and Return Receipt mail which was placed in the mail on
or about June 21, 2000. Plaintiffs counsel also served Defendant's prior counsel on or about
that same date. However, neither Defendant's prior counsel nor Father attended the Custody
Conciliation Conference.
3. Therefore, an order confirming primary custody in mother is recommended, with
a copy to be provided to Father.
4. The Order recommended is temporary in nature. The parties may return to
Conciliation upon proper petition to the Court.
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Date
Melissa Peel Greevy, Esquire
Custody Conciliator