The URL can be used to link to this page

Home My WebLink About08-6758 LUANN KARPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW KRISTINA HOAGLAND, : NO. 08- 05 CIVIL TERM Defendant. : IN CUSTODY COMPLAINT FOR CUSTODY NOW comes the Plaintiff, LuAnn Karper, by and through her attorney, Mark F. Bayley, Esquire, and presents the following complaint for custody, representing as follows: 1. The Plaintiff, LuAnn Karper, is an adult individual residing at 104 Central Way, Shippensburg, Pennsylvania, 17257. 2. The Defendant, Kristina Hoagland, is an adult individual residing at 15 South Baltimore Avenue, Apt. #5, Mount Holly Springs, Pennsylvania, 17065. 3. Plaintiff seeks custody of the following children: Name Present Residence Age D/OB Jordan Stoltzfus 15 S. Baltimore Ave., Apt. #5 10 5/21/1998 Mount Holly Springs, PA Kenneth Stoltzfus 15 S. Baltimore Ave., Apt. 45 8 8/4/2000 Mount Holly Springs, PA 4. The children were born out of wedlock 5. The relationship of the Plaintiff to the child is that of maternal grandmother. The Plaintiff currently resides with her husband James Karper. Plaintiff is married. 6. The relationship of the Defendant to the children is that of natural mother. Defendant currently resides with her boyfriend, Scott Godhard, and Mr. Godhard's daughter, Paris. The Defendant is not married. 7. 8. of 2007. 9 During the past five years, the child has resided with: Name Address Defendant 15 S. Baltimore Ave., Apt. 5 Mount Holly Springs, PA Defendant Florida Date Approx. 2004-Present For Several Months in Approx. 2004 (Jordan resided with Plaintiff at her current address for a couple of months in Pennsylvania while Defendant was in Florida with Kenneth.) Defendant Mount Holly Springs 2003-. Approx. 2004 The natural father to the children, Kenneth Stoltzfus, died in approximately July The Plaintiff has not participated as a parry or witness, or in another capacity in other litigation concerning the custody of the children is this or any other Court. 10. Plaintiff has no information of a custody proceeding concerning the children pending in any Court of this Commonwealth or any other state. 11. Other than as noted above, Plaintiff does not know of a person nor a party to the proceeding who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 12. Up until September of 2008, Plaintiff had substantial contact with the children and they enjoyed a healthy and loving relationship. 13. Continuing said relationship is in the best interests of the children. 14. Plaintiff has standing to file the within complaint under, including but not limited to, 23 Pa.C.S. §§5311, 5312, and 5313. WHEREFORE, Plaintiff requests this Honorable Court to schedule a custody conciliation conference. Respectfully submitted, BAYLEY & MAJWAl Date: [ ?' Mark F. Bayley, Esquire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 LUANN KARPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW KRISTINA HOAGLAND, : NO. 08- CIVIL TERM Defendant. : IN CUSTODY 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. Cons. Stat. § 4904 relating to unsworn falsification to authorities. 9,21 &M J22A, LuAnn Karp et, Pl ' ti o a 41, Nl- 'NZ N O - ta O u m r' d .cam..... i !: VJ ? CA) w q LUANN KARPER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KRISTINA HOAGLAND DEFENDANT 2008-6758 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, November 17, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Monday, December 15, 2008 at 9:30 AM 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. 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: Is1 ac ueline M. Verne Es . 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 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 , O? 81 ON sovz jAN 9 7 2009 LUANN KARPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-6758 CIVIL ACTION - LAW KRISTINA HOAGLAND, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 27`h day of January, 2009, the parties no longer in need of a conciliation conference, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, acq line M. Verney, Esquire, Cust y Conciliator ` ? C ._ --i i ?M _- ri ?? . .1.: