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Home My WebLink About01-0767 FX ~- - _c " ...~,' I="EB 0 9 20~ 6- . ~J V\[. l--\\~l-tlY\ Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION LAW V · K~S4~\f ~ lY\ -H\;Io-'f\ Defendant : NO. CJ/- /& '7 CIVIL 20 : CUSTODYNlSITATION ORDER OF COURT AND NOW, this _ day of , upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before the conciliator, at , on the day of , 20 , at M., for a Prehearing 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 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: 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 FOR BELOW TO FINS OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 .. ..i ~:ll. """t.': '--,-;d cI fV /Ir~ (0 y\ : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA VS. k\~~~('1f 'r'<\, N~~~ : NO. Ol-l~ 1 CIVIL TERM NOTICE TO DEFEND TO THE RESPONDENTS NAMED HEREIN: 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 Petition 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 Petition or for any other claim or relief requested by the Plaintiffs. 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 ALA WYER 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 Two Liberty Avenue Carlisle, PA 17013 (717)249-3166 Le han demandado a usted enla corte. Si usted qui ere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partie 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 objectones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, las corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. . -,~ . ...J. '_.,~,; " ~ c.l ol \N. "'~ ~~Plaintiff IN THE COURT OF COMMON PLEAS OF v. CUMBERLAND COUNTY, PENNSYLVANIA 01 NO. :sa- '7(.7 CIVIL TERM CUSTODY l-<\Y"'btt'~ r<\- HW\~ Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is ---ro rl d (Ak-\.-,sTe.. I--J;Y\"tia, residing at --.:.. 'I Po s-t Sov--th St. rcuL"sl~ t=A. I")()I~ :. The Defendant is J..(\ ;,....J,('C'lj N\1\C~elle Hmjprresiding at -=:l=-\\....t6'f\. '. 3. Plaintiff seeks ~\i8?eal") (1llilrtiiil ';;"lii1tsay) (visitation) of the following child(ren): NAME Co ectl fa.... r<\, "', ~ '1::.h r'\ 00(,\'..0- ~ N;V\-bw\ The child(ren) ~/was PRESENT ADDRESS AGE lqB3 F'"f''j Loo,p N. ~,cldl~~T""'\r-.LL \ 9.~3 FT'i I f)Of.N. l\"\~clle~T..u'r~ not born out of wedlock. The child (ren) is presently in the custody of _l<'iYVI be r-)j 1Y\a:.d..e \)12 i:,,~trY\, who resides at 19.j~ r=-r, Lour N. 0\~J.cthiOv--. \w.Nshp' During the past five years, the child (ren) has resided with the following persons and at the following addresses: LIST ALL PERSONS ~,,{oI '$ ~,.....'o(,f'11 J.-\,'niOy-.. lJ..'',.,..,b('\lt yY\, l-\,'~1o", ADDRESSES DATES I [0.$1 ~ov...i;'h ~i:-. ll1i" fr14oNf'n~L~r ~'IOb l\ /rro - .o,-"Se,,1 , I The mother of the child(ren) is /.<\W\6~Y-)1 M, N,~~ 26 ~ - ",' "", .-~ ~".~~"",:~, '. .. .' currently residing at I q 0 ~ Fr( La elf N rv\~.lr1I.Ju.-.-, ~.lNs"f' She is (SiRJ'O) (married) (ai.ereaa) . The father of the child(ren) is~r1d W. 1.'l~.njoV"\ currently residing at "7 E'Qd: SOl1_.th Si; . CG.Q..,~de. M, He is (SiR~12)(married) (aivereea). 4. The relationship of Plaintiff to the child(ren) is jl ~ Fn:lhe't2.. The Plaintiff currently resides with: NAME RELATIONSHIP 5. The relationship of Defendant to the child(ren) is f\I\ oi::heQ The Defendant currently resides " with: NAME I 7e ~h ""-0.. r\>('~h&. ~ :'<\-tu '" 1-\ \ ",I-\JV' RELATIONSHIP 'S'C\Y\. U(\}Jo..5'h-h-Q 6. Plaintiff ( f!J(has not) participated as a party or witness, or in another capacity, in other litigation concerning the custody of this minor child(ren) in this or another court. The court, term and number, and its relationship to this action is: Plaintiff \ _ . (has no) information of a custody proceeding concerning the child(ren) pending in a court of this 27 - " ' """c " '. Commonwealth. The court, term and number, and its relationship to this action is: Plaintiff not know) of a person not a party to the proceedings who has physical custody of the child(ren) or claims to have custody or visitation rights with respect to the child(ren). The name and address of such person is: 7. The best interest and permanent welfare of the child(ren) will be served by granting the relief requested because: 8. Each parent whose parental rights to the child(ren) have not been terminated and the person who has physical custody of the child(ren) 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(ren) will be given notice of the pendency of this action and the right to intervene: NAME ADDRESS BASIS OF CLAIM WHEREFORE, Plaintiff requests this court to grant (g"~+~dy) (tgmps:E'ary ea3'l:edy) (visitation) of the child(ren) to the Plaintiff. Respectfully submitted, ?-/r /0/ I ! . Date,! ~/u/~ 28 --.- <<!!Jl<aiI!l!:~ . .'~' ...u ~". ~ ~. ~" ,L:..,=-,o,:... _" ,"...,~;, -\ ...~... , .' 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. S4904 relating to unsworn falsification to authorities. 7~~~ 29 , ~i&iili'!t...~M1*,,:t!Iil.t,;.j',:""'~O+:0ili~,~~..""'i~0ji'>~""':till'" ';"_j,_",{-~_,'p'Ci-i":;!j:,,,kt;.;~-"'~,,~i~~~ ~ < ~~lli k 1 ~ 0; l:. ~~.,~~"o. , " ~~ -'"-l'-Ii'l'mmJJld..tl_~ll;j!!la;~~~"~ B ~ \ ~ ~ ~ r,\ ~ , ) '^ ~ e-: '\~ ~ ~\ '0 s S -t.l-tJ' tT!Cn Z;~l, L,C en ~:...:_ -< ,< ,-:"", <:~. ~;t3 pc: '/-.: ::,! C) "T1 :.~l c_,J , co L_ p " ~. ;--. r t) '::='1 n_! :f:;-" l.D :=-~l ',-- :.n (..J _"" -< ., '''. = . iii" "11',"" , . TODD W. IllNTON PLAINTIFF V. KIMBERLY M. HINTON DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA 01-767 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 14th day of February, 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliat at 4th Floor, Cumberland County Courthouse, Carlisle on the 9th day of March ,2001, at 8:30 a.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 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 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 1 OJ /~ -cJ! ;;; -/IJ'O/ r , , ~ ~~I j"', ry: '.;~}fi\RY PI rr,,-p I t'~, ..), , L._ '~,1 j'"l. ....,e ~U. .~\ (; CU"A[c,r:i_'r'LJ"r'''''u''~r .v, .Ii....: :: J"".;'~ I '(}' ,\; j" ~ " '..'~ ,,! I I PENNSYLVN~:A tJ. !?jt ~ $ d!/~'~ ~~~~ y1.~yM ~-~ ~i$:< ...,.,. _B!Qlli'!I\1!l!~~~_~ n!IIlILm~11~:M1If'l'!,oJj}-~t"'~'""':'I'"'fi'8''''''-''~''''1~''''C~l,W,,''f'~''''l~'~'~~~"W~!'%l!'l~~,I/!ffl\~"'i""'~ "",":',::;'1 - " ~ -' - - ~(_',~ l1' >-'~--~"""--~:''";~ - ,~', .~ MAR 14\ 20~"" TODD W. lllNTON, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KlMBERL Y M. HINTON, Defendant NO. 01 - 767 CIVIL IN CUSTODY COURT ORDER AND NOW, this I'~day of March, 2001, upon consideration of the attached Conciliation Report, it is ordered and directed as follows: Custody 1. The Father, Todd W. Hinton, and the Mother, Kimberly M. Hinton shall enjoy shared legal custody of Cecilia M. Hinton, born September 4,1989; and Joshua T. Hinton, born September 24, 1988. 2. The Mother shall enjoy primary physical custody of the minor children. 3. The Father shall enjoy periods of temporary physical custody of the minor children as follows: A. On alternating weekends from Friday evening at 6:00 p.m. until Sunday evening at 7:00 p.m. B. On the Monday after the weekend of Mother's custody with the children, Father shall have a period of a few hours with the minor children. The parties may modifY this provision to give the Father another weekday evening depending upon the schedule of the parents and the children's schedule. C. At such other times as agreed upon by the parties. 4. During the summer months, the Father shall have physical custody of the minor children for a period of four (4) weeks, which weeks shall be non-consecutive. The parties shall work with each other in advance of the summer months to set the schedule for those weeks. Mother shall also be entitled to have the children for a full week or two in the summer if Mother has an extended vacation of any sort. 5. The parties shall alternate custody on New Year's Day, Easter, Memorial Day, July 4th, Labor Day and Thanksgiving. Father shall have Easter, July 4th and Thanksgiving on odd numbered years with Mother having New Year's Day, Memorial Day, and Labor Day on odd numbered years. The parties shall alternate these holidays on even numbered years. "~ . _c__ <'" ^ _, -""0' -,-~ ,.. ,.~_",.;.,,:;,,"_;"~,:""; c ,,-,," ,;_"_"'-'"_"""\',___C- "_,~,_" --c . 6. For the Christmas holiday, Mother shall always have custody on Christmas Eve and Christmas morning. Father shall have custody on Christmas Day from 2:00 p.m. through 2:00 p.m. on December 26th. 7. Each parent shall enjoy reasonable telephone contact with the minor children when the children are in the custody of the other parent. Additionally, in the event the custodial parent has to work or for other reasons will not be available to care for the children for a significant period of time when they have custody, they shall contact the non-custodial parent first to offer them the opportunity to provide daycare for the children. 8. This Order is entered pursuant to an agreement reached by the parties at a Custody Conciliation Conference. The parties may alter the custody schedule set forth above if the parties agree. Absent any agreement, this Order shall control. In the event either party desires to modifY this Order, that party may petition the court to have the case again scheduled with the Custody Conciliator for a conference. 1. Kimberly M. Hinton 1933 Fry Loop Avenue Carlisle, P A 17013 \ t~;,~()~O? o ~\\ cc: Todd W. Hinton 7 E. South Street Carlisle, P A 17013 ;!J , r ~ " .--ry<L" OF 01 !n;\ IQ ['ii'''\ '.... l'" '(, I"'!~ ,'DiARY r"~ I 5Q cri :, ~ C'Ulf' ';)1"1' 'I.. \J' I I.-'U' "! '1\ 'iTY v1w.....1 _.r', L_ ...' ..;" PENNSYLV'~NIA - ~ ~~.l!~~ ~lM~, __.~~I'~'!!.I11Ji'!I!l:!t~w;,-"ilI. .' . ' _ ~c __"",,,._mm~u''''''1'! . Il!tllll~, ~. ,.,-.""",,"""'" ~ ' _~ ,_"n. " _,^ 0','" _ _.,'.0','.'0,' ,_ _ ,_" _ _ _~. " - , .';. 'H"" .,.~; -_,_~':-, _ "._.-1 , . TODD W. HINTON, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA CIVIL ACTION - LAW KlMBERL Y M. HINTON, Defendant NO. 01 - 767 CIVIL IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: I [, 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Cecilia M. Hinton, born September 4, 1989; and Joshua T. Hinton, born September 24, 1988. 2. A Conciliation Conference was held on March 9, 2001, with the following individuals in attendance: The Father, Todd W. Hinton, who appeared without counsel; and the Mother, Kimberly M. Hinton, who appeared without counsel. 3. The parties agree to the entry of an order in the form as attached. J 6( DA E a