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HomeMy WebLinkAbout99-02964IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 95P...2 9/,S/1 9 CL;d Ti-?- Civil Action - (XX) Law I 1 Equity JURY TRIAL DEMANDED BOBBI J. LYTLE P.O. Box 214 Mt. Holly Springs, PA 17065 Plaintiff Is) & Address(es) MARTHA WOGAN 414 N. Bedford Street Carlisle, PA 17013 FRED WOGAN 414 N. Bedford Street Carlisle, PA 17013 PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue A Writ of Summons in the above-captioned action. Defendant(s) & Address(es) X Writ of Summons Shall be issued and forwarded to 1 )Attorney (XX)Sheriff W. Scott Henning. Esquire 319 Market Street P.O. Box 1177 Harrisburg. PA 17108 (717) 238-2000 Name/Address(relephone No. of Attorney Signature of Supreme WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. Date: `71/j / 9 9 Prothonotary by lo-?a, /.i /7tc?C< .- Deputy 1 ) Check here if reverse is used for additional information 1ROTHON.-55 7- ? nab `? O T N 4 v yi ?; O1 L1.f ?? C :7 u.f tij e SHERIFF'S RETURN - REGULAR CASE NO: 1999-02964 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LYTLE BOBBI J vs. WOGAN MARTHA ET AL BRIAN BARRICK Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon WOGAN MARTHA the defendant, at 8:26 HOURS, on the 18th day of May 1999 at 414 N BEDFORD ST CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to MARTHA WOGAN a true and attested copy of the WRIT OF SUMMONS and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answeri? 'C... Docketing 18.00 Service 3.10 Affidavit .00 Surcharge 8.00 K:Afli s oma RTine, Sheriff $23717-HANDL$R HENNING & ROSENBERG 05/19 199 epu e i Sworn and subscribed to before me this day of 19 rC A.D. w.. SHERIFF'S RETURN - REGULAR CASE NO: 1999-02964 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LYTLE BOBBI J VS. WOGAN MARTHA ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon WOGAN FRED the defendant, at 8:26 HOURS, on the 18th day of May 1999 at 414 N BEDFORD ST CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to MARTHA WOGAN (WIFE) a true and attested copy of the WRIT OF SUMMONS and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answers: Docketing 6.00 Service .00 Affidavit .00 ? Surcharge 8.00 K+I omas ine, S eri $14.UU IHA DLL Rb9HHENNING & ROSENBERG 01 by epu y eri Sworn and subscribed to before me this &.4k day of U 1UU 19 A. ? w 6 . J • rrpcnon BOBBI J. LYTLE, Plaintiff V. MARTHA WOGAN and FRED WOGAN, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-2964 CIVIL TERM CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Please mark the above captioned matter settled and discontinued. HANDLER HENNING & ROSENBERG Dater BY - W. 319 Market S11,ae P.O. Box Harrisburg, PA 1 108 (717) 238-200 ATTORNEY FOR PLAINTIFF tr =1 C\l f•: V: (1l _'j u1 (_j CANDACE L. WHITE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW IN CUSTODY CHRISTOPHER L. HOCH, Defendant No. 99-2864 CIVIL TERM ORDER OF COURT AND NOW, this 28th day of July, 2000, pursuant to an agreement of counsel reached in open court, Plaintiff's petition for contempt is deemed withdrawn. By the Court, J//Wesley Oler/,/Jr., Debra Denison Cantor, Esquire For the Plaintiff ?I? rr S / ?1 l L--cc P/l e vo James J. Bach, Esquire For the Defendant L wcy ,_ , ,? !i '? L, •\ _ ? % h?A I AIN 01 ?0?0^1n U1" CANDACE L. WHITE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER L. HOCH, Defendant CIVIL ACTION - LAW IN CUSTODY No. 99-2864 CIVIL TERM ORDER OF COURT ?"T.-ne-, Zoe l , AND NOW, upon review of the attached Stipulation for Order of Custody executed by the parties, it is hereby ORDERED and DECREED that the parties' minor children, Amber Renee Hoch and Austin Scott Hoch shall be as follows: 1. Legal Custody. The Mother, Candace L. White, and the Father, Christopher L. Hoch, shall share legal custody of the minor children, Amber Renee Hoch, and Austin Scott Hoch. The parties agree that major decisions concerning the children including, but not limited to, the children's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, and with a view toward obtaining and following a harmonious policy in the children's best interest. Each parry agrees that they shall not impair the other party's rights to share legal custody of the children. Neither party shall attempt to alienate the affections of the children from the other party. Each party shall notify the other of any activity or circumstance concerning the children that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. Without regard to any emergency decisions which must be made, the parent having physical custody of the children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent. 2. Physical Custody. Tire Mother shall maintain primary physical custody of the minor children. The Mother shall be entitled to two weeks of uninterrupted custodial time each year with a thirty-day notice to Father. Father shall have partial, physical custody of the children at the following times: A. On Thursday evenings from 5:30 p.m. until Friday morning at 8:30 a.m. or at such other return time as agreed upon by the parties. Father shall provide return transportation to the children's school or Mother's home on Friday mornings. 01 Jll I -R I,i1 9 ViL44 MA (? . 10 B. On alternating weekends from 5:30 p.m. on Friday until 7:00 p.m. on` Sunday during the school year and from 5:30 p.m. on Friday until 9:00 p.m. on Sunday during the summer months. C. On alternating federal holidays not otherwise outlined herein from 9:30 a.m. until 8:30 p.m.; provided that Mother shall always have Custody on Memorial Day Weekend through the Memorial Day Holiday and Father shall always have custody on Independence Day/Fourth of July. In the event that Memorial Day weekend falls on Father's regular alternating weekend in any year, then Father shall receive a make-up weekend for the loss of this weekend at a time mutually agreed upon by the parties. D. In even-numbered years, the Father shall have custody of the children on trick-or-treat night and Amber's birthday. In even-numbered years, the Mother shall have custody of the children on Easter, Thanksgiving and Austin's birthday. The parties shall alternate the schedule in odd- numbered years. The custodial period shall be from 9:30 a.m. until 8:30 p. M. E. For one week in June, two weeks in July and one week in August, as agreed to by the parties, provided that during these periods, the Mother shall have custody of the children on Tuesday and Thursday evenings from 5:30 p.m. until 8:30 p.m. and that during the two-week period in July, the Mother shall have custody during the weekend in the middle of the period from 5:30 p.m. on Friday until 9:00 p.m, on Sunday. Mother shall waive these periods if Father is taking the children away for vacation and provides Mother with the location and telephone number of said vacation spot. Father shall notify Mother of the dates intended to be exercised for these vacation periods by June V of each year. F. Christmas. The parties shall alternate the Christmas holiday. Schedule A shall be from Christmas Eve at 9:00 a.m. until Christmas Day at 9:00 a.m. Schedule B shall be from Christmas Day at 9:00 a.m. until the day after Christmas at 9:00 a.m. Father shall have Schedule B in the even. numbered years and Schedule A in the odd-numbered years. 3. Transnortation. Mother shall be responsible for providing transportation to the Broad Street Elementary School or another mutually agreeable neutral site for the exchange of these custodial periods, except as set forth in paragraph 2. The parties agree to ensure that the children are safe from elements during said transfers. 4. Travel. In the event that either parent intends to take the minor children for more than forty-five (45) miles from Harrisburg, Pennsylvania, overnight, each parent shall provide the other with the children's location and provide a telephone number for contact, if possible. 5. Address and Telephone Number of the Parties. Both Mother and Father must keep each other informed of any changes of address or change of telephone number. Any changes in address or telephone number shall be immediately forwarded to the other parry. 6. Notice of Whereabouts hild/Illness. Each party shall keep the other reasonably informed as to the whereabouts ofthe cren while with the other party. If either party has knowledge of illness or accident or other serious circumstances affecting the welfare of the children, he or she shall promptly notify the other party of that circumstance. 7. Telephone Contact with the Children. Both parties shall have the right to reasonable contact with the children during the other party's period of custody/visitation. Neither party shall interfere with the other party's telephone contacts with the children. Each party shall make all reasonable efforts to promptly return telephone calls or messages left by the other party regarding the children. 8. Disparaging Remarks. Neither Mother or Father shall make any disparaging remarks regarding the other party in the presence of the children, such as those that might tend to alienate the affections of the children toward the other parent. Also, each parent shall inform relatives and friends to refrain from making any disparaging remarks regarding either party in the presence of the children. 9. Modification. Any provisions of this agreement may be modified or deleted upon written mutual consent/agreement by both parties or upon petition to the Court for modification. BY THE COURT: C .9 of 9? <;y nt s Y . REAGER &*ALLER, P.C. ATTORNEYS AT LAW 2331 MARKET STREET CAMP HILL, PA 17011-4642 JUN 0 1 10L001 JUN 0 (717) 763-1383 V " i?. ?Y CANDACE L. WHITE. Plaintiff V. CHRISTOPHER L. HOCH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY No. 99-2864 CIVIL TERM STIPULATION FOR JOINT CUSTODY ORDER AND NOW, thi day of May, 2001, the parties, Candace L. White a4thristoph4 L. Hoch each agree the custody of the two minor children, Amber Renee Hoch, born February 13, 1995 and Austin Scott Hoch, born August 16, 1996, shall be as follows: 1. Legal Custody. The Mother, Candace L. White, and the Father, Christopher L. Hoch, shall share legal custody of the minor children, Amber Renee Hoch, and Austin Scott Hoch. The parties agree that major decisions concerning the children including, but not limited to, the children's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, and with a view toward obtaining and following a harmonious policy in the children's best interest. Each party agrees that they shall not impair the other party's rights to share legal custody of the children. Neither party shall attempt to alienate the affections of the children from the other party. Each party shall notify the other of any activity or circumstance concemin, the children that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. Without regard to any emergency decisions which must be made, the parent having physical custody of the children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent. 3. Physical Custody. The Mother shall maintain primary physical custody of the minor children. The Mother shall be entitled to two weeks of uninterrupted custodial time each year with a thirty-day notice to Father. Father shall have partial physical custody of the children at the following times: A. On Thursday evenings from 5:30 p.m. until Friday morning at 8:30 a.m. or at such other return time as agreed upon by the parties. Father shall provide return transportation to the children's school or Mother's home on Friday mornings. B. On alternating weekends from 5:30 p.m. on Friday until 7:00 p.m. on Sunday during the school year and from 5:30 p.m. on Friday until 9:00 p.m. on Sunday during the summer months. C. On alternating federal holidays not otherwise outlined herein from 9:30 a.m. until 8:30 p.m.; provided that Mother shall always have custody on Memorial Day Weekend through the Memorial Day Holiday and Father shall always have custody on Independence Day/July 4'^. In the event that Memorial Day weekend falls on Father's regular alternating weekend in any year, then Father shat I receive a make-up weekend for the loss of this weekend at a time mutually agreed upon by the parties. D. In even-numbered years, the Father shall have custody of the children on trick-or-treat night and Amber's birthday. In even-numbered years, the Mother shall have custody of the children on Easter, Thanksgiving and Austin's birthday. The parties shall alternate the schedule in odd-numbered years. The custodial period shall be from 9:30 a.m. until 8:30 p.m. E. For one week in June, two weeks in July and one week in August, as agreed to by the parties, provided that during these periods, the Mother shall have custody of the children on Tuesday and Thursday evenings from 5:30 p.m. until 8:30 p.m. and that during the two-week period in July, the Mother shall have custody during the weekend in the middle of the period from 5:30 p.m. on Friday until 9:00 p.m. on Sunday. Mother shall waive these periods if page -2- lr Father is taking the children away for vacation and provides Mother with the location and telephone number of said vacation spot. Father shall notify Mother of the dates intended to be exercised for these vacation periods by June I" of each year. F. Cht7_ ?stmas. The parties shall alternate the Christmas holiday. Schedule A shall be from Christmas Eve at 9:00 a.m. until Christmas Day at 9:00 a.m. Schedule B shall be from Christmas Day at 9:00 a.m. until the day after Christmas at 9:00 a.m. Father shall have Schedule B in the even-numbered years and Schedule A in the odd-numbered years. 3. Translation. Mother shall be responsible for providing transportation to the Broad Street Elementary School or another mutually agreeable neutral site for the exchange of these custodial periods, except as set forth in paragraph 2. The parties agree to ensure that the children are safe from elements during said transfers. 4. Travel. In the event that either parent intends to take the minor children for more than forty-five (45) miles from Harrisburg, Pennsylvania, overnight, each parent shall provide the other with the children's location and provide a telephone number for contact, if possible. 5. Address and Telephone Number of the Parties. Both Mother and Father must keep each other informed of any changes of address or change of telephone number. Any changes in address or telephone number shall be immediately forwarded to the other party. 6. Notice of Whereabouts/Illness. to the whereabouts of the children while with the other party. Each party shall keep the other reasonably informed as If either party has knowledge of illness or accident or other serious circumstances affecting the welfare of the children, he or she shall promptly notify the other party of that circumstance. 7. Telephone Contact with the Children. Both parties shall have the tight to reasonable contact with the children during the other party's period of custody/visitation. Neither party shall Page -3- y i interfere with the other party's telephone contacts with the children. Each party shall make all reasonable efforts to promptly return telephone calls or messages left by the other party regarding the children. 8. Disparaging Remarks. Neither Mother or Father shall make any disparaging remarks regarding the other party in the presence of the children, such as those that might tend to alienate the affections of the children toward the other parent. Also, each parent shall inform relatives and friends to refrain from making any disparaging remarks regarding either party in the presence of the children. 9. This Order shall supercede all prior Court Orders, stipulations or agreements. 10. Modification. Any provisions of this agreement may be modified or deleted upon written mutual consent/agreement by both parties or upon petition to the Court for modification. Candace L. White Joaktl: Harrison Clough, Counsel for Candace L. A f es M. Bach, Esquire ounsel for Christopher L. Hoch Page -4-