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Home My WebLink About02-6024 BRANDON P. HOOK, .. IN THE COURT OF COMMON PLEAS Plaintiff, .. CUMBERLAND COUNTY, .. PENNSYLVANIA Vs, .. C;u L'l <y 8tn-) .. NO. 0.:2- -1.&.6~'f .. HILARY M. BARBUSH, .. CIVIL ACTION - LAW Defendant .. CUSTODY COMPLAINT FOR CUSTODY AND NOW, Plaintiff, Brandon P. Hook, by and through his attorney, Stephanie L. Mihalko, Esquire, files a Complaint For Custody against Defendant, Hilary M. Barbush, and in support thereof, avers the following: 1. Plaintiff is Brandon P. Hook, Father, who currently resides at 4814 Brian Road, Mechanicsburg, Cumberland County, PA 17050. 2. Defendant is Hilary M. Barbush, Mother, who currently resides at 210 Hale Avenue Apt. #305, Harrisburg, Dauphin County, PA 17104. 3. Plaintiff seeks custody of the following child: NAME Present Address AGE Zoe A. Hook 4814 Brian Road, Mechanicsburg, PA 17050 4 years old 4. The child was born out of wedlock. 5. The child, Zoe A. Hook, is presently in the custody of Father, Brandon P. Hook, who currently resides at 4814 Brian Road, Mechanicsburg, PA 17050. 6. During the past five (5) years, the child, Zoe A. Hook, has resided with the following persons at the following addresses: Persons Brandon Hook and Hilary Barbush Address Locust Lane, Harrisburg, PA Date 11/98-2/99 Brandon Hook and Hilary Barbush 400 7th Street Apt. #5 3/99-10/99 New Cumberland, PA Brandon Hook 4814 Brian Road 10/99-4/2001 Mechanicsburg, PA Brandon Hook and 4814 Brian Road 5/01-5/02 Mechanicsburg, PA Hilary Barbush (shared custody) 3621 Brookridge Terrace. Apt. 3A 5/01-5/02 Harrisburg, PA 17104 Brandon Hook 4814 Brian Road 5/02-present Mechanicsburg, PA 7. The Mother of the child is Hilary M. Barbush who currently resides at 210 Hale Avenue, Apt. #305, Harrisburg, PA 17104 8. The Father of the child is Brandon P. Hook, who currently resides at 4814 Brian Road, Mechanicsburg, PA 17050. 9. The parties are not married. 10. The relationship of Plaintiff to the child is that of Father. Plaintiff currently resides with the following persons: Person Relationship Catherine G. Hook His Mother Ronald G. Hook His Father 11. The relationship of Defendant to the child is that of Mother. Defendant currently resides with the following persons: Person Relationship N/A : Defendant resides alone. 12. Plaintiff and Defendant have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 13. Plaintiff and Defendant have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 14. Plaintiff and Defendant do 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. 15. The best interests and permanent welfare of the child, Zoe A. Hook, will be served by granting the relief requested, inter alia, because the Plaintiff Father has been one of the child's primary caretakers. 16. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene. Name Address Basis of Claim NONE WHEREFORE, Plaintiff respectfully request that this Honorable Court enter an Order granting him shared legal custody and primary physical custody, with Defendant Mother to have liberal partial physical custody. Respectfully Submitted, BY::/../ / [)J:;~ , L- L . f?Z.~ Stephanie L. Mihalko, Esquire Edward Weintraub & Associates 2650 North Third Street Harrisburg, PA 17110 (717) 238-2200 Attorney ID. #86998 Attorney for Plaintiff Dated: ; a.. / ) ~ / lJ~ , I VERIFICA liON I, D\OJv'\JO{l ~ ~\oo~, hereby swear and affirm that the facts contained in the foregoing Complaint for Custody are true and correct and are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: / ';;J, J )/0 J W , I l~k{JM Brandon Hook ' Plaintiff N ~ -lQ.. c:' 't - c fl - 0 --, r"'-if '" .......... er, " ~ 6"- , IN 0 lU % -U ;:: O? ~ - , - ~ - \ ~, ... , ~ BRANDON P. HOOK, Plaintiff, * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, * PENNSYLVANIA * * NO. 02-6024 vs. * * CIVIL ACTION - LAW CUSTODY HILARY M. BARBUSH, Defendant. * CERTIFICATE OF SERVICE I, Misty D. Lehman, Legal Assistant to Stephanie L. ~vfihalko, Esquire, hereby certify that on December 24, 2002, I served a true and correct copy of the Complaint for Custody upon Hilary M. Barbush, Defendant, by depositing same, postage pre-paid, Certified Mail, Return Receipt Requested as well as via Regular Mail in the United States Mail, Harrisburg, Pennsylvania, addressed as follows: Hilary M. Barbush 210 Hale Avenue, Apt'. #305 Harrisburg, P A 17104 Date: IdPY j(J}- I) vAl! /JI~ ~ /J - (~ ~f/bJ ~Lehman g ;gti"l zLP ~~,: kG ~8~ 5>c 7" ~ o N o I~ C1 N 0.... o -n -0 :::Jt; ~ r:- -.I ~ ~j (n ~~J cf.l '-)\p :2f~ ~ ~ -< PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANDON P. HOOK v. 02-6024 CIVIL ACTION LAW IDLARY M. BARBUSH DEFENDANT IN CUSTODY ORDER OF COURT I AND NOW, Monday, December 23, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, January 21, 2003 at 10:30 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. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Dawn S. Sunday, Esq. t-/ Custody Conciliator I 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 ATIORNEY AT ONCE, IF YOU DO NOT HA VB AN ATIORNEY 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 ~r"'9 -b:7 rw", ~ #;o<ff~~ ~-r~~>%~'F7J J.J.N VINV/17ASNt.a /}OO O^r17tf3~n:) 85:[; 1M DE: J3a '0 dO ~o- ~ ?::I ---eO ac r:( ze't?- (/['. e'( BRANDON P. HOOK, Plaintiff, * INTHECOURTOFCOMMONPLEAS * CUMBERLAND COUNTY, * PENNSYLVANIA * VS. * NO. 02-6024 HILARY M. BARBUSH, Defendant. * * CIVIL ACTION - LAW CUSTODY * CERTIFICA TE OF SERVICE !, Misty D. Lehman, Legal Assistant to Stephanie L. Mihalko, Esquire, hereby certi/)' that on January 3,2003, I served a true and correct copy of the Order of Court scheduling a Custody Conciliation Conference upon Hilary M. Barbush, Defendant, by depositing same, postage pre-paid, in the United States Mail, Harrisburg, Pennsylvania, addressed as follows: , Hilary M, Barbush 210 Hale Avenue, Apt. #305 Harrisburg, P A 17104 Date:~ ~f)tA{ O,~ Misty D. Lehman () c 0 c W -1'1 s: .--k \Jet; J:~ (!Jrn "'"'? Z ::<) ,.".,- &j~~ I (:J\ ~L_ r: <~' ~i ~~~ j..;J .....,J ~-~, ~ :J1 cO' en ~ =< vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA BRANDON P, HOOK, Plaintiff HILARY M. BARBUSH, Defendant : NO. 02-6024 CIVIL TERM : CIVIL ACTION-LAW CUSTODY PRAECIPE TO WITHDRAW AND DISCONTINUE TO THE PROTHONOTARY: Kindly withdraw and discontinue the Custody Complaint filed on December 19,2002 in the above captioned matter on behalf of Plaintiff. , /.Lf/t,z; Stephanie L. Mihalko, Esquire 2650 North Third Street Harrisburg, P A 17110 ID #86998 (717) 238-2200 Date: I I / '-I / /J.3 JAM 1 0 2003 January 9, 2003 Edward J. Weintraub & Associates 2650 North Third Street Harrisburg, P A 17110 Attn: Stephanie L. Mihalko Re: Termination of case File #02-259 Dear Stephanie, Please cease to advance forward on the above case number and cancel the custody conciliation conference on January 21, 2003. After careful consideration I have decided in the best interest of my daughter Zoe A. Hook that I will not need to pursue any further legal actions against Hilary M. Barbush. Thank you for your time in this matter. Sincerely, Brandon p, Hook (") c <' vCL' mir' '"7 ~' ..:!:~- -~. 65S:;'.~ ~t: <- .. .';'" d.::';C 58 z :;i ... c.: (.~) c_ ,~:~:j;Q ~ (~j'-, ", :".1,.) JA~ BRANDON P. HOOK Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 02-6024 CIVIL ACTION LAW HILARY M BARBUSH Defendant IN CUSTODY ORDER AND NOW, this 13TH day of January.2003, the conciliator, being advised by the Plaintiffs counsel, that Plaintiff no longer wishes to pursue this custody matter, relinquishes jurisdiction. The Custody Conciliation Conference scheduled for January 21,2003 is cancelled. FOR THE COURT, ~- Dawn S. Sunday, EsqUIre Custody Conciliator \llN'"!i\lJ..SNN3d JJ.NrC{']H'f1.H38V4nQ LU:l\WJ ?;~\\" '" },'bfL::