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HomeMy WebLinkAbout00-05204 .,=,,", ~" ,-~ ',,~ JOHN K. HESS, II IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF V. ANNE D. HESS AND RICHARD STEHMAN 00-5204 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 27th day of July ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on the 12th day of September ,2000, at 3:00 PM 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 TIllS 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 FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 . " " -. "'=" ~,," ,~, . '" " ~~ -,'. .,,,, N_"" "'I ~t-:, ~:' OD JUL c: 8' rOI- i';! ,JJ CL'j\r:~~},:~,!:';' f '/':i i\!'ry PEj\iN;iYLVi]~jiX'" ~, l"df.ciJ w- ~J;7' tu4 ~ ~ ~ 7gg-Q:;? 7t~ .~ Z~ )-,}.g"-C/&.? ~ /l"-~ d q ~"'.~ . ,,,.,.,..,.... , -, ~J~I ~ ~"'-, ~ !~......~~.~~",,~--?11'~Wi~:!i'~ffi~~~,,",,~~ ~ ~~._ ,'", ',;'~ "..", ,. 'e""_ -- ,,'''''~.I",~,','~'', "" "~" JOHN K. HESS II, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. m - f;),OL/ ~ ANNE D. HESS and RICHARD STEHMAN, Defendant. CIVIL ACTION- CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , on the day of , 2000 at , in the , for the 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. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent Order. For the Court, Date: By: Custody Conciliator ~-- -0'.' " --~ - ,~'- ,. -... - . ..: -.. ~'~'''^' ,., ", h 'jfu'jD " '. JOHN K. HESS II, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. tlJ - 5020,/ ta/J ANNE D. HESS and RICHARD STEHMAN, Defendant. CIVIL ACTION- CUSTODY NOTICE TO DEFEND 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 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. Your 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 of for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Court Administrator Cumberland County Courthouse Carlisle, Pennsylvania 17013 (717) 240-6200 ,. ,_, 'H~". ~~ ,'_ 'l" ''',0,;, ,,""~-ii ,-. .'-"""..- - "'''' H ~_,'q" 'LJ. i,' __'''-" L,", Ji:nrj '. JOHN K. HESS II, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. (H.> .5:).0'/ ~/~ v. ANNE D. HESS and RICHARD STEHMAN Defendant. CNIL ACTION- CUSTODY COMPLAINT FOR CUSTODY Plaintiff, JOHN K. HESS II, by and through his attorney Gerald S. Robinson, Esquire, and the law film of ROBINSON & GERALDO, respectfully requests the following: 1. Plaintiff is JOHN K. HESS II, an adult individual and the stepfather ofthe minor child who cun.ently resides at 3509 Beech Run Lane, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is ANNE D. HESS, an adult individual and the natural mother of the minor child who currently resides at 504 Harrisburg Pike, Dillsburg, York County, Pennsylvania. 3. Defendant is RICHARD STEHMAN, and adult individual and the natural father of the minor child whose current residence is unknown, but is employed at State Street Station, located at 225 State Street, West Fairview, Dauphin County, Pennsylvania. II I~~ , , ""',,~.~,, "".;;,( "~,,"',"-"ci' ',~ ' ,,. ',,", ~," ~..;;j.,,;., """;'"' ,; 'J'_-[;:'~"~',... ' 'c',';,;;> ~," ~~ 3, Plaintiff seeks visitation with Vance M, Stehman born on in July of 1992, residing at 504 Harrisburg Pike, Dillsburg, Pennsylvania with Defendant, Anne D. Hess. 4. The child is presently in the custody of Defendant, Anne D, Hess who currently resides at 504 Harrisburg Pike, Dillsburg, Pennsylvania, 5. For the past five (5) years, the child has resided with the following persons at the following addresses: PERSON(S) ADDRESS DATES Plaintiff and Defendant, Anne D. Hess 3059 Beech Run Lane January 1995 to March 1999 Mechanicsburg, P A 17055 Defendant, Anne D. Hess 504 Harrisburg Pike March 1999 to Present Dillsburg, PA 17019 6. The mother of the child is Defendant, Anne D. Hess, currently residing at 504 Harrisburg Pike, Dillsburg, Pennsylvania. She is married. 7. The stepfather of the child is John K. Hess, 11, whose currently resides at 3509 Beech Run Lane, Mechanicsburg, Pennsylvania. He is married. 8. The natural father of the minor child is Richard Stehman, whose current residence is unknown, but is employed at State Street Station, located at 225 State Street, West Fairview, Dauphin County, Pennsylvania. 2 II ",,"c/;'l','" . ,",~, -,d","'''" -,~, ,"Co" '~ 1 ' - $ 9. Plaintiff has 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. 10. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 11. 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. 12. The best interest and permanent welfare of the child will be served by awarding visitation to Plaintiff. 13. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as a party to this action. 3 Ii II i..'" k" ,,-" ""'u ~',"-- .~ , ,,'~, !;" "",k ",;c_ c",~ ,"" ~oAck:,""", ,C ,"',. ';:.';' "",'~~ , . ..;"""; ~ WHEREFORE, the Plaintiff respectfully requests this Honorable Court to visitation to Plaintiff. Respectfully submitted: ROBINSON & GERALDO BY~ Gerald S. Robinson, Esquire Attorney J.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110 (717) 232-8525 Attorney for Plaintiff 4 II II " "'" '.,J '""";,"',-- ,.:' ""~ _C',', . ,"- o~~;.0..'';;'',:> -':,i'.,- ',='.,.".,"".1-" .,,", ,_, R_ .. VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification t '\ ,).,oW -, ~"~ j,:, , ,'r." C___';.,"! -," ~" ~ ~~ ' .';:".'~' '"A",ll'~,,'F':';"')-" .., , ,.",~, "" ,,' ",'~', -"";"~IIt.t: CERTIFICATE OF SERVICE I, Gerald S. Robinson, Esquire, do hereby certify that on the 21 st day of July, 2000, I caused a true and correct copy ofthe Complaint to be served upon the following individual by certified mail restricted delivery to addressee only by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. John J. Connelly, Jr., Esquire P.O. Box 650 Hershey, P A 17033 Respectfully submitted, ROBINSON & GERALDO By: G aid S. Robinson, Esquire Attorney LD. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, PAl 711 0 (717) 232-8525 Attorney for Plaintiff . -'] ....' , - ,";,~,""", l_ -~ . JOHN K. HESS II, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-05204 ANNE D. HESS and RICHARD STEHMAN Defendant. CIVIL ACTION- CUSTODY PROOF OF SERVICE The undersigned makes the following return of service: the Complaint in Custody was served upon Anne D. Hess, the Defendant, on July 29,2000 at 174 Logan Road, Dillsburg, York County, Pennsylvania. The signed receipt is attached as Exhibit 1. SIGNATURE AND AFFIDAVIT I, Gerald S. Robinson, Esquire, certify that I am a competent adult not a party to this action. I verify that the statements made in this affidavit and return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsfication to authorities. Respectfully submitted, ROBINSON & GERALDO Dated: 8/7 I cP BY.~ Gerald S. Robinson, Esquire Attorney LD. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff ,I 1\ ~ Complete items 1, 2. an'd' 3. Also-- compi~te item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back. of the mallpiece, or on the front if space permits. 2. Article NT.ber~. '.~.'. [11. ~-qr61~. , 7'7 \q 0 !, . .." ,.' z:::: , ,,' '..' ! '! PS Form 3811, July 1!l99 r o Agent o Addressee DYes ~NO D. Is delivery address different from item 11 If YES, enter delivery address below: nL.J LOr:,p\0 '"gO. "D,L-'-S80RL-..""Pp\.170/Cj 3. ~rvice Type 11J Certified Mail 0 Express Mail o Registered )tI Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) Yes i: 1'; Domestic Return Receipt 102595-99-M-1789 d' '_ .. ~ D D a EXHIBIT 1 , ~ r JOHN K. HESS ll, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-05204 ANNE D. HESS and RICHARD STEHMAN Defendant. CIVIL ACTION- CUSTODY PROOF OF SERVICE The undersigned makes the following return of service: the Complaint in Custody was served upon Richard Stehman, the Defendant, on July 28,2000 at 225 State Street, West Fairview, Dauphin County, Pennsylvania. The signed receipt is attached as Exhibit 1. SIGNATURE AND AFFIDAVIT 1, Gerald S. Robinson, Esquire, certify that 1 am a competent adult not a party to this action. I verify that the statements made in this affidavit and return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsfication to authorities. Respectfully submitted, ROBINSON & GERALDO Dated: 8/7/00 BY:~~ Gerald S. Robinson, Esquire Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff :,0 , " t-'-'--'---' ,n -----------------.".- ii" C'ompfefe items +;-'2. antf3~ A'jsb,'compii9te item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. c. x D Agent Addressee DVes 'l(No (\7~~dto~\-e~~ 8@S ~te <:::)\-(eel, lJ-.2d=, F'al(DieWJ pR n 3. irviC8 Type Certified Mall 0 Express Mail Registered crI Return Receipt for Merchandise o Insured Mail d C.O.D. 4. Restricted Delivery? (Extra Fee) Ves rvice labeJ4 .. ':l.:?-, ..... ; 'l CD1--Jl 1 i ' . ;,11 Domestic Return Receipt 102595-99-M-1789 EXHIBIT ~ D S 1 . SEP 11 2~ JOHN K. HESS, II, . IN THE OOURT OF CDMMON PLEAS OF . plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. . NO. 00-5204 CIVIL TERM . . . : CIVIL ACTION - LAW ANNE D. HESS and RICHARD STEHMAN, . . Defendant . IN CUSTODY . ClIDER OF 0ClUR:r AND NCM, this 7th day of September, 2000, the Conciliator, being advised by Plaintiff's counsel that Plaintiff did not wish to pursue his Complaint for custody, hereby relinquishes jurisdiction in this case. The Custody Conciliation Conference scheduled for September 12, 2000 is canceled. FOR THE OOURT, rf2~ ~~'7 Dawn S. Sunday, Esquire Custody Conciliator . , . '-.! ','jT,\RY C.rn ,';-,l' <--l'._' ,,~ p;~ Z::~8 ., " ",",.'l\I"IV r'UI l;', ,'1..:''':'-'1- ~ ,l)'! i,'-J l v j\ '-,,--.. ,..\. J. FEr\Ji'<SYl~\//\NI.l\ ~ ~~ ,~~,",,' ~""~,~b" ." "!.."....~mj~~'~~...., ~I'~~~,.,~.~, ",,,~Jl!li.