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Home My WebLink About07-49781 Troy E. Logan, IN THE COURT OF COMMON PLEAS Shelley K. Hoachlander, Plaintiffs OF CUMBERLAND COUNTY PENNSYLVANIA vs. CIVIL ACTION - CUSTODY Emmanuel Hoachlander, Marissa Brackbill , ~~'/ Defendants N0. a7-Gfl~'7~ L~ N O T I C E T O D E F E N D 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 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. 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 complaint or 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 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 PA 17013 717-249-3166 M ry Et er Dissinger Attorney for Plaintiffs Troy E. Logan, Shelley K. Hoachlander, Plaintiffs vs. Emmanuel Hoachlander, Marissa Brackbill Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTODY '1. Plaintiffs are Troy E. Logan and Shelley K. Hoachlander, residing at 93 Deerfield Drive, Camp Hill, Cumberland County, Pennsylvania. 2. Defendants are Emmanuel Hoachlander and Marissa Brackbill, residing at 93 Deerfield Drive, Camp Hill, Cumberland County, Pennsylvania. 3. Plaintiffs seek custody of the following child: Name Present Residence Age Summer Hoachlander 93 Deerfield Drive, Camp Hill DOB-12/9/03 ~. The child was born out of wedlock. i. The child is presently in the custody of all parties who 'eside at 93 Deerfield Drive, Camp Hill, Cumberland County, 'ennsylvania. ~. During the past five years, the child has resided with the ollowing persons at the following addresses: Persons Addresses Date Troy Logan 93 Deerfield Drive, Camp Hill 11/06-present Shelley Hoachlander Pennsylvania Emmanuel Hoachlander Marissa Brackbill Troy Logan Shelley Hoachlander Emmanuel Hoachlander Marissa Brackbill 100 S. 16th St. Camp Hill Pennsylvania 10/05-11/06 Emmanuel Hoachlander 400 7th St. Apt. 1, New Cumberland, Marissa Brackbill Pennsylvania Troy Logan 100 S. 16th St. Camp Hill, Shelley Hoachlander Pennsylvania Emmanuel Hoachlander Marissa Brackbill 10/04-10/05 06/04-10/04 Emmanuel Hoachlander 355 Bethel Church Rd, New Cumberland 12/03- 6/04 Marissa Brackbill 1st roommate -Jeremy (last name unknown) 2nd roommate - full name unknown 7. The mother of the child is Defendant, Marissa Brackbill who currently resides at 93 Deerfield Drive, Camp Hill, Cumberland County, Pennsylvania. 8. She is unmarried. '9. The father of the child is Defendant, Emmanuel Hoachlander who !currently resides at 93 Deerfield Drive, Camp Hill, Cumberland County, Pennsylvania. 10. He is unmarried. ',11. The relationship of Plaintiff, Shelley Hoachlander to the ',child is that of paternal grandmother. The Plaintiffs currently '!,reside with each other, Defendants, Emmanuel Hoachlander and Marissa Brackbill, and the child, Summer Hoachlander. ', 12. The relationship of Plaintiff, Troy Logan, to the child is ~Ithat of paternal grandmother's paramour of seventeen (17) years, with whom he owns their current residence. 13. The Plaintiffs currently reside with each other, Defendants, Emmanuel Hoachlander and Marissa Brackbill, and the child, Summer Hoachlander. 14. The relationship of Defendant, Emmanuel Hoachlander to the child is that of natural Father. The Defendant currently resides with Plaintiffs, Troy Logan and Shelley Hoachlander, Defendant, Marissa Brackbill, and the child, Summer Hoachlander. 15. The relationship of Defendant, Marissa Brackbill, to the child is that of natural Mother. The Defendant currently resides with Plaintiffs, Troy Logan and Shelley Hoachlander, Defendant, Emmanuel Hoachlander, and the child, Summer Hoachlander. 16. Plaintiffs have not partici ated as a p party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 17. Plaintiffs have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 18. Plaintiffs 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. 19. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiffs can provide a stable environment within which the child will grow and :lourish. ~. Each parent whose parental rights to the child has not been erminated and the person who has ave been named as parties to this acption CAllcothery of the child elow who are known to have or claim a right tpo rc stody moa isitation of the child will be given notice of the pendency of zis action and the right to intervene: NONE. WHEREFORE, Plaintiff re the child quests the Court to to Plaintiffs, Tro grant custody of ~' E• Logan and Shelley Hoachlander. Respectfully Submitted: DISSINGER AND DISSINGER By: _ ~ Mary A. E ter Dissinger Attorney for Plaintiffs Supreme Court I.D. #27736 28 N. 32nd Street Camp Hill, PA 17011 (717) 975-2840 (717) 975-3924 VERIFICATION I, Shelley Hoachlander, verify that the statements made in the Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. a~~~.J Shelley achlander, Plaintiff ~ ~ ` a - .1 ~ ~ ~ r ~ ~ 1 r...> `' t~ ~ G ~ -~, -~ r:~ --a c:'° -I` ~ l`; i i 71~, ~, ~,~ ~i ; <1 ~ , ~~' ~ 1 , _ ~_ J, ~ rt .. ~a =, ,. C..; s Troy E. Logan, Shelley K. Hoachlander, Plaintiff(s) vs. Emmanuel Hoachlander, Marissa Brackbill i Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY N0. D7-' 7/~7S And now, Petitioner, Mary A. Etter Dissinger, Esquire, hereby requests this Court not appoint a Conciliation Officer in this matter, and enters the attached Stipulation and Agreement as an Order of Court, and avers as follows: 1. Petitioner is Mary A. Etter Dissinger, Esquire, attorney for Plaintiffs in the above matter. 2. Defendants in the above matter are pro se. 3. The minor child in this matter is Summer Hoachlander (DOB - 12/9/03), natural daughter of Defendants. 4. It is the request of Petitioner, Plaintiffs and Defendants that a conciliator not be appointed in this custody matter.. 5. The parties have entered into a Custody Stipulation and Agreement regarding the minor child, that they desire to have entered as an Order of Court. Wherefore, Petitioner, requests this attached Stipulation be made an Order of Court. Respectfully Submitted, Dissinger & Dissinger ~_ Mary A. Et er Dissinger, Petit' ner Attorney for Plaintiffs Supreme Court ID# 27736 28 N. 32nd Street Camp Hill, PA 17011 (717)975-2840 (717)975-3924-fax TT ~ A a w Troy E. Logan, Shelley K. Hoachlander, s Plaintiff(s) vs. Emmanuel Hoachlander, Marissa Brackbill Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY N0. STIPIIL~-TIOl~ 11l1D AAR'P Ole' THE P111tTIS8 Troy E. Logan and Shelley K. Hoachlander, Plaintiffs and Emmanuel Hoachlander and Marissa Brackbill, Defendants hereby stipulate and agree that the Court shall enter an Order concerning custody and visitation of Summer L. Hoachlander (DOB 12/09/03) as follows: 1. Primary physical and legal custody of Summer L. Hoachlander (DOB 12/09/03) shall be in Troy E. Logan and Shelley K. Hoachlander. 2. Emmanuel Hoachlander and Marissa Brackbill will have periods of partial physical custody as the parties shall agree. Respectfully submitted, Troy Logan ~ I Shelley K. Hoachlander Emmanuel Hoachlander `L- _~~ Marissa Brackbill Commonwealth of Pennsylvania ss County of `-~4 ~~,~,, On this, the Oaf day of 2007, before me the undersigned officer, personally appea ed Troy 3. Logan, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purpose therein contained. seal. I~ ~PITNESS ~REOF, I have here unto set my hand and notarial My commission expires : ~~r ~.1, a.(~ Commonwealth of Pennsylvania Notary Public ~~~~ ~~ ~~~M ~~+4MIfi1. ~ ss County of ~`~`$ . On this, the ~ day of 2007, before me the undersigned officer, personally appeared Shsllay ~. 8oachlaadar, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purpose therein contained. seal. IN WIT~88 F, I have here unto set my hand and notarial My commission expires: 31,30 Notary blic AIU1~1~1I~M M~M~~Ii#0 ~~ w~~~1i1 ~t~i.~ lth of Pennsylvania ounty of ~.~~ ss ~, On this, the ~ day of 2007, before me the ndersigned officer, personally ap eared ~aauwl 8oachlaa~der, nown to me (or satisfactorily proven) to be the person whose name s subscribed to the within instrument, and acknowledged that he xecuted the same for the purpose therein contained. eal. IN gTITNE88 ~REOF, I have here unto set my hand and notarial commission expires:~~ 3~~~°~ lth of Pennsylvania ounty of T'..~~vv~ l~-v~.~' Notary P lic ~~ aw~~ ~_~ N~N~t~~~ woor~»~or~a.~ ss On this, the ~ day of 2007, before me the ndersigned officer, personally appe red Narissa Hrackbill, known o me (or satisfactorily proven) to be the person whose name is ubscribed to the within instrument, and acknowledged that he xecuted the same for the purpose therein contained. eal. IN OPITNSSS NBEREOF, I have here unto set my hand and notarial commission expires : ~GR- ~) ~ ~~ Notary lic ~~ rMMIN~10Mli ~~I~~COM~AII w~lo~4M~O11!!.~ Troy E. Logan, Shelley K. Hoachlander, Plaintiff(s) vs. Emmanuel Hoachlander, Marissa Brackbill Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY NO. CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, Esquire, do hereby certify that a copy of the foregoing document has been duly served upon Defendants, Emmanuel Hoachlander and Marissa Brackbill, by depositing same in the United States Mail, postage prepaid, addressed as follows: Emmanuel Hoachlander 93 Deerfield Drive Camp Hill, PA 17011 Date : ~~~/~~~ Marissa Brackbill 93 Deerfield Drive Camp Hill, PA 17011 Mary A. Etter Dissinger Attorney for Plaintiffs r-' '~1 ~ ~~ ~~ -v . y c~ -s~~, 7 . '' N ~, " :. ~~ s~ r__. T~' L -~" Co rN ( ' pt ~~-" ~ ' .+ ~+ ~.x .G Troy E. Logan, Shelley K. Hoachlander, Plaintiffs vs. Emmanuel Hoachlander, Marissa Brackbill Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY N0. ~7''~~7~ AFFIDAVIT OF MAILI~ COMMONWEALTH OF PENNSYLVANIA ss .. COUNTY OF CUMBERLAND Mary A. Etter Dissinger, attorney for Plaintiffs, being duly sworn according to law, says that she mailed by United States Certified Mail, Restricted Delivery, a true and correct copy of the Complaint in Custody in this action to the Defendants at their residence, and that Defendants did receive same as evidenced by the signed receipt dated August 23, 2007, attached hereto as Exhibit "A". Sworn to and subscribed before me this 28th day of August, 2007. Notary ublic ~. Mary A. Etter Dissinger Attorney for Defendant Supreme Court ID #27736 28 North 32nd Street Camp Hill, PA 17011 (717) 975-2840 .~.. NOi~R41t !iK AMli1E /1~~ Noiloiyll CAIIAPI~t~C11N1, M~- O~wwM1 yrMi~1lZ !00! ilk ~tflY11N aM~ ~ .it i-A. ~~~~ EXHIBIT "A" ~. r ~ C Y1 . . --r ~ . ~_: ~`, f tt ,~ `~~_•. Ct ? c' ,. ~,., ~ ~ ~ ~: f _ ~' .. ~'r-.. N ~ ~ w Bethann E. Keshish, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA vs. CIVIL ACTION Justin A. Keshish, NO. (~'~-x/9'7 y' Defendant : IN DIVORCE AFFIDAVIT OF MAILII~ COMMONWEALTH OF PENNSYLVANIA ss .. COUNTY OF CUMBERLAND Mary A. Etter Dissinger, attorney for Plaintiff, being duly sworn according to law, says that she mailed by United States Certified Mail, Restricted Delivery, a true and correct copy of the Complaint in Divorce in this action to the Defendant at his residence, and that Defendant did receive same as evidenced by the signed receipt dated August 23, 2007, attached hereto as Exhibit ~~ A ~~ ~-, . _ Mary A`. Etter Dissinger Attorney for Plaintiff Supreme Court ID #27736 28 North 32nd Street Camp Hill, PA 17011 (717) 975-2840 Sworn to and subscribed before me this 28th day of August, 2007. Notary Public ~---.~ NOiARtAt SERI ANNETIE PERK C~MA~Hri e~JRC~ ~M~D~Ar My ('~..~ ., ~, , Expires Jul 22. Z~'!0! h xv°'?~''' ~" YtiYNl~~ EXHIBIT "AK C~ c ``= ~ ~ c ~ ->- "` ._; -~.~ ~ ~" n , ~ , _. " f ~.J. ~.,~ r. f ) ~ ~...~ ~+-~ ~..~,J •` ~+~. .~ ~• SEP ~4'~00~ U Troy E. Logan, PLEAS ',,Shelley K. Hoachlander, Plaintiff(s) i vs. i Emmanuel Hoachlander, Marissa Brackbill Defendant(s) IN THE COURT OF COMMON OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY N0. 07-4978 u~ ORDER And now this 7 day of September, 2007, it is Ordered and Decreed as follows: 1. Primary physical and legal custody of Summer L. Hoachlander (DOB 12709/03) shall be in Troy E. Logan and Shelley K. Hoachlander. 2. Emmanuel Hoachlander and Marissa Brackbill will have periods of partial physical custody as the parties shall agree. By the~1(zrt J. ao ~$ ~~ },t~~~'~ ~ ~~ ~~13~l3 ;..,,.