Loading...
HomeMy WebLinkAbout97-01519 J . ~ ~, t3 J~ '\ . I . 1 / / ,. € ~ J cr - l() - , c:- O- / l. . g ~ 0 ~,' - :l "'- 8 -0 i., ~;'''l ::g ~'<' .> "- ....fu ;;" - .~~,,:. N '16 .<: ~.;:~ ~:~:- "'0 .f" 1 ,~~:i.J ~, :;.< .'.~t. ) ~t.1 .i-.t'il - I"~:I' "C: ,. ~ ?:.j e:- ~) """ 0" '< \ ~ RICHARD C. HANCOCK Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - CUSTODY ~ NO.97- /$"1 CIVIL TERM : IN CUSTODY V. JENNIFER M. REA Defendant ORDER OF COURT AND NOW THIS ;X~,'dayof HeIr ( h ,1997, upon consideration of the attached complaint, it is hereby' directed th~t the parties and Iheir respective counsel appear before f~)..J\ \ _). r. ( I, h L "~Of 1\J I II:' ,the conciliator, at ~ ( f 1J Nr~\(\\(\h{'f~ (lA 0 the~~daYOf_l'-lO~ ' 1997 at L : ,M,., for a Pre- earing Custody Conference. At su 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 permanenl order. BY THE COURT, BY ("--h ";/1 u.,'l\ J. oJ.. I I n rtOI L l..:.'If}-- Custody Conciliator (N)V The Court of Common Pleas of Cumberland County is required by law to comply with the Americens with Disabilities 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 LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAl HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 The natural mother of the children is Jennifer M. Rea, currently residing in Moss Pt.,MS . She is not married. The natural father of the children is Richard C. Hancock, currently residing at Carlisle, PA, He is not rnarried. 4. The relationship of the Plaintiff to the children is that of father. The Plaintiff currently resides with the following persons: (a) Bradley Rea Hancock (b) Kelly Ann Hancock 5. The relationship of the Defendant to the children is that of mother. 6. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning the custody of the children in this or in any other Court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children, 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: (a) Mother has not paid child support I verify that the statements made in the foregoing Complaint for Custody are true and correct. I undersland that false statements herein are made subject to the penalties of 18 Pa, C.S. ~ 4904, relating 10 unsworn falsification to authorities. ":JfP.~ ~ f&~ ~ ~T\.. ..I r -,4;_ Richard C. Hancock DATE: 3-/~-.P? , . v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97-1519 CIVIL TERM RICHARD C. HANCOCK Plaintiff JENNIFER H, REA Defendant IN CUSTODY AND NOW, this ORDER OF COURT ,it day of August, 1997, upon consideration of Plaintiff's request for a custody order without service in at least substituted form upon Defendant, the request is DENIED without prejudice to Plaintiff's right to seek authorization for service by special order of court pursuant to Pa. R.C.P. 430. BY THE COURT, J. Robert L. O'Brien, Esquire 17 West South Street Carlisle, PA 17013 Attorney for Plaintiff :ml ~iI C;1-o:::i''''- ,.._ _, ',:"'7:-:~, 'I .....C u- "" -'.::"'''~''~( , _.;<1 -.1 I' - " ~, , ,-'. .-.',.'\It ~~ nQAo\d 4c ~ O'e:>ril!.C"I - D4l,~Q\ol(.~ff-l ~ CJ7 An:;-8 ,':t. ;', ,.., 'I ;'.~ I ...1. -; ... C' " '\)1.;; ,- . . " ~ i RICHARD C. HANCOCK Plaintiff Vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 97-1519 CIVIL TERM . IN CUSTODY JENNIFER M. REA Defendant ORDER OF COURT AND NOW, this _ day of August, 1997, upon review of the allached Petition and Complaint for Custody, the Plaintiff Richard C. Hancock is granted primary physical and legal custody of his children Bradley Rea Hancock, and Kelly Ann Hancock until such lime as the Defendant Jennifer M. Rea can be located, served with the Complaint for Custody and appear before the Court. By the Court, J. - 7) Petitioner's client has limited financial resources and cannot easily afford the cost of service by publication. 8) Petitioner's client has no idea where or how to locate the Defendant. WHEREFORE. Petitioner respectfully requests that the attached Order be entered until such time as the Defendant can be located and served with the custody complaint. Respectfully submitted, O'BRIEN, BARIC & SCHERER By =-J-Jlr~~ I .--- Robert L. O'Brien, Esquire Attorney for Plaintiff J.D. # 28351 17 West South Street. Carlisle, Pennsylvania 17013 (717) 249-6873 C(',' k~ Ha.-~ Cc: 9~1- ,-,-/-:h I( .".~..., -v.t Ill~ 4.-- f' ~'- /. . ../ v 1" (/lL ,/.)~ tAAR 2 5 1997lY ' , RICHARD C. HANCOCK Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION" CUSTODY V. JENNIFER M. REA Defendant NO,97.IS/9 IN CUSTODY CIVIL TERM ORDER OF COURT AND NOW THIS .s2fl~ay of ~ttul . 1997, upon consideration of the attached complai it is hereby direc:eo that the parties and their respective counsel appear before - f! , the conciliator, at ,7F 0. "Ml~", ~' ';'M.A~"'" /.'.1 (Lv.'f.: PA_ 0 the ~ oay of )'Y/r:t . 1997 at .(), M./P.M., for a Pr -Hearing Custody Conference. At Co" conference, an effort will be made to resolve the issues in dispute: or if this cannot be accornplished. 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. BY THE COURT, ". BY /.sl' n , Custody Conciliator (i1J ~1.. The Court of Common Pleas of Curnberland County is required by law to comply with the Americans with Disabilities 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 LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE. 4TH FLOOR. ' CARLISLE, PA 17013 (717) 240-6200 ' . .. . .... - .... -..-.....-'='" . . .' ., . .... .;. ~ -. ..' . : l !".' ". ': ': ,~! .,:r t.lti1d ~ , ....-...1.""....A.ap. . .. " '_..~.J..fl.,...:,.. '1,.' .', I~ ::1" ~f ......~ 19f?. ~: .,g, 'ro~~ RICHARD C. HANCOCK Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 97- IS-fer CIVIL TERM : IN CUSTODY Vs. JENNIFER M. REA Defendant COMPLAINT FOR CUSTODY 1. Plaintiff is Richard C. Hancock, an adult individual, currently residing at 122 Elm SI., Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Jennifer M. Rea. an adult individual, currently residing at 6407 E. Hwy. 90. Moss Pt., MS, 39563. 3. Plaintiff seeks custody of the following children, Bradley Rea Hancock and Kelly Ann Hancock, ages 10 and 8 respectively, born 9/12/86 and 6/2J88 respectively. The children were born out of wedlock. The children are presently in the custody of Richard C. Hancock, who resides at 122 Elm SI., Carlisle, Cumberland County, Pennsylvania During the past five years, or since the children's birth, they have resldecl with the following persons at the following addresses: (a) from 1993 to present with Richard C. Hancock at 122 Elm Sl (b) from 1991 to 1993 with Richard C. Hancock and .......... AM. 59 North Bedford St, Carlisle, PA The natural rnother of the children is Jennifer M. Rea, currently residing in Moss Pt.,MS. She is not married. The natural father of the children is Richard C. Hancock. currently residing at Carlisle. PA He is not married. 4. The relationship of the Plaintiff to the children is that of father. The Plaintiff currently resides with the following persons: (a) Bradley Rea Hancock (b) Kelly Ann Hancock 5. The relationship of the Defendant to the children is that of mother. 6. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation. concerning the custody of the children in this or in any other Court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the ptoeeedings who has physical custody of the children or claims to have custody or visitation rightS with respect to the children. 7. The best interest and permanent welfare of the children will be served by grantinQ the relief requested because: (a) Mother haS not paid child support (b) Mother has not called, written or visited with the children in the past four years. The mother has been moving frequenlly to avoid her child support obligation. The father is concerned that Defendant may attempt to take the children and wishes to have a Court Order granting him permanent physical and legal custody of the children until such time as Defendant receives notice and an opportunity to be heard. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children has been named as party to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene. NAME ADDRESS BASIS OF CLAIM None WHEREFORE, Plaintiff requests your Honorable Court to grant custody of the children to the Plaintiff and enter a temporary order granting him full physical and legal custody of the children pending Defendant's receiving notlca of this custody matter and further Order of Court. Respectfully submitted, oate;~ J BY:~A.~ . Robert L O'Brien. Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Clllllle, PA 17013 (717) 249-687 " I verify that the statements made in the ~oregoing Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C.S. S 4904, relating to unsworn falsification to authorities. ~~ ~- .....~ ~ .- -~.~~ .- Richard C. Hancock DATE: j-/~-jP?