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Home My WebLink About01-2324 FX . ROBERT A. KARNS, JR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001 -~J.'1 CIVIL TERM VICKI J. HACKENBERGER, Defendant CIVIL ACTION - LAW CUSTODY ACTION ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before _ . Esquire, the Conciliator, at on , 2001, 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 temporary order. Either party may bring the children who are the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. For the Court, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU DO NOT THE OFFICE SET CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 240-3166 I, Y,,,-, ,,,"'~"q. ~? . "..- . ._~_,,,:,," ," ','11"', .. ROBERT A KARNS, JR PLAINTIFF V. VICKI J, HACKENBERGER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA 01-2324 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, April 27, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Snnday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, May 22, 2001 at 10:00 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 defme 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,lJ!; 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 HA VB 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 ."-"..,,,.,~'fo_, "~',,"-"'1~-'"' ~I"" ~1iii4Mll!l:!~I~lki.t>':l,t,*'oIi!'!1~li!,;ili';;!Ii'!:,<r~'''~<~'tili.,<,C', .,-"/.:"-,,,,,"'-,0 3_,_~,,,,,,",,,_"__.i~'ffi""""<t-,",.b;""-."""NiWit4l~~..1ilI' "-~~".,..",. "j!lt:~~_,.,. ',I " ii " ,I II ;1 " Ii u ,I !I II Ii " il 1 I ,I I I I ~ cr ' f~':L~p-CFFiCE ,;r;:\!OTf\RY 01 APR 27 PI': I: I a . ~"" CUMBJ~RLNJD COUN1Y PeNNSYLVANIA 1./-,;17-0/ tML, f~ ~ ~.-s8~ 'I',; ).{')/ <-,/1. +-, ~-? rftYUU. ft-ta ~ -/ ~ . tf"J.'i'~/ I'fY1Zp ~ ~ 4~ " >~m'tL~U.LLL ,0 ~~~, ""__"""'""... ~___"(""_"'''',. ~_,. do', """"_'.,, ,_.~l '_"<'_"",-.""''7S"",.>" N,'.'<-"'''''~'""''~'''__-'''''" 'v, ~"',"~_, ,"_, "'~","",,""'_" ,-" '.<, -,^'''''--~''-,-' -~'~-""',-,,'"~' ~ ,-- . ~~"--"""~~-'"-- . -.- ---,,", "iffl~.._ . ,~ .. . ROBERT A. KARNS, JR., : IN THE COURT OF COMMON PLEAS OF plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. : NO. 01-2324 CIVIL TERM . . VICKI J. HACKENBERGER, : CIVIL ACTION - LAW Defendant : IN CUSTODY OODER OF COORT AND 1Df, this .3/)/- day of consideration of the attached Custody and directed as follows: mPlY Conciliation , 2001, upon Report, it is ordered 1. The Father, Robert A. Karns, Jr., and the Mother, vicki J. Hackenberger, shall have shared legal custody of Richard Brian Karns, born September 25, 1992, and Jessica Nicole Karns, born March 31, 1995. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 2. The Mother shall have primary physical custody of Children. 3. At such time as the Father moves to a separate residence, the Father shall have partial physical custody of the Children on alternating weekends from Friday at 6:00 p.m. through Sunday at 6:00 p.m. The Father's alternating weekend periods of custody shall begin on either the first or the second weekend following the Father's relocation, as arranged by agreement of the parties. The Father may have additional periods of custody with the Children as arranged by agreement of the parties. 4. The parties shall have custody of the Children on holidays as follows: A. CBRIS'l'MAS: In every year, the Mother shall have custody of the Children from Christmas Eve at 6:00 p.m. through Christmas Day at 6:00 p.m., and the Father shall have custody of the Children from Christmas Day at 6:00 p.m. through December 26 at 6:00 p.m. B. MEMCIUAL DAY 2001: The Father shall have custody of the Children on Memorial Day in 2001, with the times to be arranged by agreement of the parties. C. REMAINING HOLIDAYS: The parties shall share or alternate having custody of the Children on the remaining holidays as arranged by agreement. D. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. ~, . I'!"'I,~' ,~ ~ -, r ~ ,~ ~ 5. Counsel for either party may contact the Conciliator within four months of the date of the Conciliation Conference to schedule an additional Conference, if necessary. 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. J. l~\O\ ~ * cc: Thomas D. Gould, Esquire - Counsel for Father Vicki J. Hackenberger, Mother ~,,,,l(l',l!lj."_._r,, - .~-"'" , . F'"' .,,~. L - ~ \fli\:\,li\lAS;\jr~3 :.! )dNnn;i '--:u:" ~':1:i\J(lC} s;~ :8 -~- I~,~) (, f." ;--~ UH ". AHfY:, 41!J 11 " ,"~ ."",,,,,,,,, , -~'~'-<' ~~.~~'~,~ ,=_ ~,_ _~~M ~",'~ <~ ~,~. , ""," ~ II' ..... n ="T'=".~~~~~~~$'_~,e~~"~..'I":$"~"""<<;'<"""'O""""":<'F(;.?'!"i'fJ\~i'lOO~!"li~:~,..:;!.tt\il~~rp~~~~~L~~ "_'~:""!Wif ROBERT A. KARNS, JR., : IN THE OOURT OF OOMMON PLEAS OF plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 01-2324 CIVIL TERM . : VICKI J. HACKENBERGER, : CIVIL ACTION - LAW Defendant . IN CUSTODY . CU&J:OuI' CXXiIClLIATIClSI SUMMARY REPCRT IN ACCORDANCE WITH CUMBERLAND <XXlNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH alRRENTLY IN cos:roDY OF Richard Brian Karns Jessica Nicole Karns September 25, 1992 March 31, 1995 Mother Mother 2. A Conciliation Conference was held on May 22, 2001, with the fOllowing individuals in attendance: The Father, Robert A. Karns, with his counsel, Thomas D. Gould, Esquire, and the Mother, vicki J. Hackenberger, who was not represented by counsel at the Conference. The Mother's boyfriend attended the Conference but did not participate. 3. The parties agreed to entry of an Order in the form as attached. (!itlj dA-(, d-ov I Date ~~"/ Custody Conciliator ;-i\'l',l'.,_ - ". " ~r .1""'1 '-' " ROBERT A. KARNS, JR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 1T. NO. 2001 -:23.2'1 CIVIL TERM VICKI J. HACKENBERGER, Pefendant CIVIL ACTION - LAW CUSTODY ACTION CUSTODY COMPLAINT TO THE HONORABLE JUDGES OF SAID COURT: 1. The Plaintiff is Robert A. Karns, Jr. residing at 926 Nixon Drive, Mechanicsburg, Cumberland County, PA 17055. 2. The Defendant is vicki J. Hackenberger residing at 926 Nixon Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff seeks joint legal custody and shared physical custody of the following children: NAME PRESENT RESIDENCE DOB Richard Brian Karns Jessica Nicole Karns 926 Nixon Drive Mechanicsburg, PA 09/25/92 03/31/95 The children were not born in wedlock. The children are presently in the shared physical custody of Robert A. Karns, Jr. and Vicki J. Hackenberger who reside at 926 Nixon Drive, Mechanicsburg, Cumberland County Pennsylvania. iW~"", f' ^'.' " , ~ ~I-. < " , . . ~ During the past five yea~s, the children have resided with the following persons and at the following addresses: Persons Addresses Dates Mother & Father 926 Nixon Drive Mechanicsburg, PA 04/99 - present Mother & Father 118 Betty Nelson Trailer Ct Carlisle, PA 09/92 - 04/99 The mother of the children is Vicki J. Hackenberger who currently resides at 926 Nixon Drive, Mechanicsburg, Pennsylvania. She is not married. The father of the children is Robert A. Karns, Jr. who currently resides at 926 Nixon Drive, Mechanicsburg, Pennsylvania. He is not married. 4. The relationship of Plaintiff to the children is that of father. The Plaintiff currently resides with the following persons: Name Relationship Richard Brian Karns Jessica Nicole Karns Vicki J. Hackenberger Son Daughter Former girlfriend 5. The relationship of Defendant to the children is that of mother. The Defendant currently resides with the following persons: Name Relationship Richard Brian Karns Jessica Nicole Karns Robert A. Karns, Jr. Son Daughter Former boyfrientl 2 r!;~ ~ ... _ <," ~ ~ "'" , . ", ~~.~ . ",,"I"l'., ~ .. 6. Neither party has participated as a party nor witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 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. Plaintiff can properly care for his children B. Plaintiff can provide a loving home. C. Plaintiff will place his children's interest before his own. 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 parties to this action. WHEREFORE, Plaintiff requests this Honorable Court to grant him joint legal custody and shared physical custody of his children, subject to defendant's right to joint legal custody and shared physical custody. Respectfully submitted, ~o.~ Thomas o. Gould, Esquire 10 #36508 2 E. Main Street Shiremanstown, PA 17011 (717) 731-1461 3 !fl--,--,,-...,,,,,o,._ .' . ,'{lie, 1""', ,.n _c."'__.C -" . ~ iU VERIFICATION I, Robert A. Karns, Jr., hereby certify" that the foregoing CUSTODY COMPLAINT is true and correct to the best of my knowledge, information and belief. 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. DATED: '-I /;9 hi I / 4 -~,ll!.Il~_~ ""," - ._'. ~ ~_ _ ""I""l,,