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HomeMy WebLinkAbout08-7525Edmund J. Berger Berger Law Firm, P.C. 2104 Market Street Camp Hill, PA 17011 (717) 920-8900 tberger@bergerlawfirm.net IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REBECCA M. HILT Plaintiff V. Docket No. BRYAN R. HILT Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: 46 Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 1-800-990-9108 (717) 249-3166 AVISO USTED HA SIDO EMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelente en las siguientes paginas, debe tomar accion dentro de los prbximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso readicando personalmente o por medio de un abogado una comparecencia escrita y radicando en las Corte por escrito sus defenses de, y objecciones a, las demanda presntadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacibn o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFOMACION A CERCA DE COMO CONSEQUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 1-800-990-9108 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REBECCA M. HILT Plaintiff V. Docket No. BRYAN R. HILT Defendant COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Rebecca M. Hilt, who currently resides at 145 Bosler Avenue, Lemoyne, PA 17043. 2. Defendant is Bryan R. Hilt, who currently resides at 333 South Catherine Street, Middletown, PA 17057. 3. Plaintiff has been a bona fide resident(s) in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were marred on February 15, 2006 in Carlisle, PA. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce. 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. Ann. § 4904, relating to unsworn falsification to authorities. Rebecca M. Hilt Date: December 26, 2008 Edmund J. Berger Attorney for Plaintiff Berger Law Firm, P.C. 2104 Market Street Camp Hill, PA 17011 Phone: (717) 920-8900 Fax: (717) 920-8901 (? w OD <?J +r W co ZZ -4 -? ?LL -J .7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REBECCA M. HILT Plaintiff V. Docket No. 000 BRYAN R. HILT Defendant AFFIDAVIT OF CONSENT 15ais 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on December 29, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint. 3. 1 consent to the entry of a final decree of divorce. 4. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. 1 verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. Cons. Stat. Ann. § 4904 relating to unsworn falsification to authorities. Date: () -00'09 ebecca M. Hilt OF TF APR ? . "'. OTARY 2049 APR Z2 PH 1: 21 G"{t; Lill i Y' CWNNIIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REBECCA M. HILT Plaintiff V. Docket No. 0'a- 15015 BRYAN R. HILT Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. Cons. Stat. Ann. § 4904 relating to unsworn falsification to authorities. Date: 9 L1.(}?.P?. 1J1? Rebecca M. Hilt RBA 40 HGE OF THE' Pi(,".~ NOTARY 2009 APP 22 Pr-4 1: 22 r ;r,• 5 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REBECCA M. HILT Plaintiff V. BRYAN R. HILT Defendant Docket No. D$ - 1525 AFFIDAVIT OF CONSENT 1 A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on December 29, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint. 3. 1 consent to the entry of a final decree of divorce. 4. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. 1 verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. Cons. Stat. Ann. § 4904 relating to unsworn falsification to authorities. Date: ,? mw-c. O CZ Bryan R. Hilt OF TH Rnr 71-l"'1,40"tA ?Y 2009 APR 22 Pl 1' 22 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REBECCA M. HILT Plaintiff V. Docket No. b% -'1ST BRYAN R. HILT Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. Cons. Stat. Ann. § 4904 relating to unsworn falsification to authorities. Date: ?ct Bryan R. Hilt OF THE r- T4 W, .?,TORY 2009 APR 22 Pi's 1. 22 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REBECCA M. HILT Plaintiff V. BRYAN R. HILT Defendant . Docket No. OS- "159.5 ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce Under Section 3301(c) of the Divorce Code. Date: Bryan R. Hilt Y I -??..i.1 r _I" ?G?Y r. 'C: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REBECCA M. HILT Plaintiff V. BRYAN R. HILT Defendant . Docket No. 08-7525 Civil Term PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c). 2. Date and manner of service of the complaint: By acceptance of service filed on April 22, 2009. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By plaintiff: March 30, 2009 By defendant: March 29, 2009 4. Related claims pending: None. 5. Date plaintiffs Waiver of Notice in Section 3301 (c) Divorce was filed with the prothonotary: April 22, 2009 Date defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the prothonotary: April 22, 2009 Dated: April 22, 2009 Edmund J. Berger Attorney for Plaintiff Berger Law Firm, P.C. 2104 Market Street Camp Hill, PA 17011 Phone: 717-920-8900 Fax: 717-920-8901 tberger@bergerlawfirm.net ':-r T4 if r "1 £? Rebecca M. Hilt V. Bryan R. Hilt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-7525 Civil Term DIVORCE DECREE AND NOW, 9. , it is ordered and decreed that Rebecca M. Hilt plaintiff, and Bryan R. Hilt , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE n By the Court, d f • ,Of &t ez?pl , ma4a z 4 Rya C2? - of W xrw. al z d t. ? Name: ???1 Address: tiloZ ?u4erG.)W C3 City: L?? , PA Zip: 1-7011 Telephone: 117- Po?- X81 Email: ),-,\a 1 ZI p 0,01 'C..eH t W?A Plaintiff V. Defendant IN THE COURT OF COMMON PLEAS bHV,,o,,')TUNTY, PENNSYLVANIA NO.y52!5CV CIVIL ACTION - LAW PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS TO THE HONORABLE JUDGES OF SAID COURT: Pursuant to Pa.R.C.P. No. 240, 1 hereby certify that I am without financial resources to pay the costs associated with my case, and therefore believe that I am entitled to proceed in forma pauperis. In support of my petition, I have attached to it a certification of indigency and incorporate it herein by reference, a certification which fully and truthfully describes my overall financial condition at the present time. WHEREFORE, the undersigned asks leave of court to proceed in forma pauperis, without the need to pay any costs in connection with the instant action. Respectfully submitted, Date - rl?? A&\A Signature o itioner Revised 9-08 0 Dauphin County Court of Common Pleas Name:.yDe?A W Address: ?1UZ u?)??Yl t?r Ge( Cg City: C(X,'! P lALKI , PA Zip: l v l Telephone: -11 -7 - Z? Email: JZI G(Jl C?V? w?&& : IN THE COURT OF COMMON PLEAS Plaintiff :(A)fte(IzlncOUNTY, PENNSYLVANIA V. : N0:625ty ?T CIVIL ACTION - LAW Defendant CERTIFICATE OF INDIGENCY 1. 1 am the "n - Defendant) in the above matter and because of my financial condition, I am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. 1 am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. 1 represent that the information below relating to my ability to pay the fees and costs is true and correct: (a) Name: ZCGw V UA- Address: 1,102 toWCY-Clon 'c' Ci CAF CS C?? l Q4 17011 Social Security Number: 1-7 ?-Lo 0 - 7 (b) Employment: If you are presently employed, state Employer: C?1Yl ?? 1?-I C71q s Revised 9-08 © Dauphin County Court of Common Pleas Address: 52 rUlJf4f/a) ? (c) (d) ltw,s b?o Salary or wages per month: 25 d ?? Type of work: C111fY)LCJ If you are presently unemployed, state Date of your last employment: P40 f I Ly" Salary or wages per month: n44 n OrQ Type of work: MT ftc)NL Other income within the past twelve (12) months Business or profession per month: N44- Oft Other self-employment per month: 0Y4. Interest per month: Fes' X11 o LL Dividends per month: Y1MX Pensions and annuities per month AoYLJ, Social Security benefits per month: OFF- YXW Support payments per month: Disability payments per month: 1(1 OVIR- 6;?rcp T,-23 tvnl> -2, 53 C,(\ hek, i Unemployment Compensation and supplemental benefits per week: _ MKA. Workers' Compensation per month: 1V) a Public Assistance per month: -TUITF YIL)K-l- Other per month: ?fCTTH n b n f - Other contributions to household support wife Cusb)and me: b h-tl 4 If your wife/husband is employed, state: Revised 9-08 0 Dauphin County Court of Common Pleas Employer: oa Salary or wages per month:9 Type of work: Contributions from children: UZD" ?2V12 Contributions from parents: Other contributions: (e) Property owned Cash: _ '?? YIpVV?- IRA Checking account: _I/10K-% - Savings account: 41- VVVI-A- Certificates of deposit: Vlyn? Real estate (including home): u Motor vehicle: Make: ftYear: Cost: 100 Amount Owed: U00 0 ' °o Stocks; bonds: _ - Other: ? ` (f) Debts and obligations - average per month Mortgage: 94- "K- Rent: -1'7 0 bl?? Loans: 2c P &---0 Other: ` m"A k ?bC4?L 1---j ae(' Apoc( U L I) 1-1 e2:) (g) Persons dependent upon you for financial support Wife/Husband Name: Children, if any: Revised 9-08 © Dauphin County Court of Common Pleas Name: Xfl6 W- ? \ ?- Age: _ Other persons dependent upon you for financial support (such as parents, grandparents, etc.): Name: Relationship: 4. 1 understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. 1 verify that the statements made in this affidavit are true and correct. I understand that false statements herein are being made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. a-Ze, -C>q Date "a&AA, - Signature etitioner Revised 9-08 0 Dauphin County Court of Common Pleas REV ?. n-F THE ,'Ply: 2009 &--p 29 f ?. l a Name:,?V! V _1( W (YourName) Address: )1 DZ Ll I Y17 VI Gt r (?i C 5 (Your Add ss) City: ?L? LL , PA Zip: 1701 Telephone: `T IT i S - ZS (Your Telephone Number) Email: 12.1 & rsnl . C_nt.A (Your Emai Address) IN THE COURT OF COMMON PLEAS fvr% OUNTY, PENNSYLVANIA Plaintiff (Your Name) :CdIA'arvar,4t V. NO.-15 CV CU ';bWCAr\ CIVIL ACTION -LAW Defendant (Name of All Other People who have CUSTODY ACTION Custody Rights) COMPLAINT FOR CUSTODY 1. The Plaintiff(s) is/are YYnL &A.A-- , residing at Y ur Na e) '\1 ° Z Q JX UMV114ou nty, PA (Street Address) (City) (County) 1'7011 . The Plaintiffs telephone number is -117- &5& • ZSB I (Zip Code) (Telephone Number of Plaintiff) 2. The Defendant(s) is/are 1-l 1,4- , residing at (Name of All Other People Who Have Custody Rights) 333 `J C' ?,?'tY]>o - ? l? Yl , T).J lr? Ydounty, PA )-705-7-. (Street Address) (City) (Zip Code) The Defendant's telephone number is P50 (Telephone number of Defendant) 3(a). Plaintiff seeks (CIRCLE ONE) primary custody) custody) (visitation) of the following child(ren): Name(s) of Child(ren) Present Residence (partial custody) (shared Date of Birth A?P,kxal,? i 1 } llo? t1PXC1(A')d r- aA CB 6 Ln Og d Revised 1-09 4 0 Dauphin County Court of Common Pleas 3(b). The child(ren) (was/were) wa no ere not) born out of wedlock. The child(ren) are presently in the custody of who resides at (Name of Person) \\bZ aUffdOn 0 r6ii146 WHC W-4 LL , PA. His or her relationship to the child(ren) is M(?4j&?. (Relationship to Child(ren) During the past five years, the child(ren) have resided with the following persons and at the following addresses: List All Persons List All Addresses 4 Dates t" I BWO V-) g?Y? I ??uG v, Man 1'0-etp? fta?j PIJA- w s 5cbier ? e_ lax' r-P Sr 00 I ?Dt? Iav??d r cIP-? ? I tit 1?2 UWC1W aroa e I Le5l?a- 08-09 t, - as-o7 3(c). The mother of the child(ren) is TV? tom" l (Name of Mother) currently residing at 1?u2 gverrlcA of r ra - A. She is (Address of Mother) (CIRCLE ONE) (married) divorced) (single). The father of the child(ren) is of Father) Revised 1-09 5 © Dauphin County Court of Common Pleas currently residing at L7cJ? -'j'• CVOWkU !. ' j&j-fjaQY-"\ , PA. He is (Address of Father) (CIRCLE ONE) (married) divorced) ingle). 4. The relationship of Plaintiff to the child(ren) is that of (CIRCLE ONE) Mothe (Father) (Other): If Other, explain: The Plaintiff currently resides with the following persons: Name "Lbejb Relationship 5. The relationship of Defendant to the child(ren) is that of (CIRCLE ONE) (Mather) (FIRMINOther): If Other, explain: The Defendant currently resides with the following persons: Name Relationship . ?? VA 6(a). Plaintiff (CIRCLE ONE) (has) has n t) participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child(ren) in this or another court. The court, term, number, and its relationship to this action is: Revised 1-09 6 © Dauphin County Court of Common Pleas 6(b). Plaintiff (CIRCLE ONE) (has) ((has no information of a custody proceeding concerning the child(ren) pending in a court of this Commonwealth or any other state. The court, term, number, and its relationship to this action is: 6(c). Plaintiff (CIRCLE ONE) (knows) does not kno 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 (set forth facts showing that the granting of the relief requested will be in the best interest and permanent welfare of the child(ren): Revised 1-09 7 0 Dauphin County Court of Common Pleas Lid 1 \11 L h( yj - -?o Y1,^cut- U ????c??-? a? >o ii (Explain in Detail What Custody Arrangement You Want and Why) 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 the court to grant (CIRCLE ONE) primary custod (partial custody) (shared custody) (visitation) of the child. I verify that the statements made in the Complaint 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. q-29-ow Date f)M,W- " Signatur Plaintiff (Your Signature) Telephone Number of Plaintiff (Your Telephone Number) Revised 1-09 8 © Dauphin County Court of Common Pleas FILM- F THE 1 t R . ,Y 2 in, 09 4 EP 29 AM 19: 13 C ?; VWa 0'r \?b o? 2 Co o b V. e Dev"-?c a ?. 0 be(-N N?V?- Onb??) 4U- CYU1G\ VkClor?q \)?VN - GYlcl FI ai n? ?? / Peber?oIan-I- l?f? CcQy}Y Ot)ec? mc.?.,?2cc' ° ??l ?-1 ?-I U?12 (- Cur-wn4-lu re5jde5 cam- \\u2 ?U2?cio,? Prcq) 4- C? e0t4yp ?'`?'` ?? 1701 JGn L-)o0L Ct?Ujej Yr1e??O &,Lk a'?b? ?la???-ebb ? Debon6evl+- to 4Lk a6Oove, W4ioneci Cvmn-Pc/ I'eSie/e 5 cx-? 333 ? cr?W?e,ru2? ?-f- VYl&W?wn ? 120 s? , `)? G'u.lcl ,'Melocl,q ?4 UJ 6 Uearc-?) ob a-y' aocl Vreyo+k/ r2?rle? L,?.?-!') YY?oWt?-r ?k,?.( ?Ai 1A cA- \l02 qverdov? G r ?f c8 ?M J'J Ic?,l,( ? ak\A blbr? bor 6wter???? Cosi-ootu (fir mq OM?AI-K mOA 'OiAa?x b?L,n? ti?eca,a5e surecaq ay'd told ML 1 1?WO nxjer l?eSa-erda.U 4 Cctwci Mc '?Pv OA-ow kA. "V gee 1LQ-? a5aAJJV). P)50 OZ)(-A 08 yyu,- -?D ?j vc-- t?F ?hm rS) bedt". 9-Z-9-0ri RLEr . 2009 SEE 29 AN I s <s, r t Plaintiff V. I a?i \A4- Defendant IN THE COURT OF COMMON PLEAS CUI,nCOUNTY, PENNSYLVANIA NO.'1525 CV tae- CIVIL ACTION - LAW ORDER GRANTING LEAVE TO PROCEED IN FORMA PAUPERIS AND NOW, this day of 20 .2) _?_, upon presentation and consideration of the within petition and attached certification, we grant the relief prayed for, and grant Petitioner leave to proceed with this case in forma pauperis, without the need to pay any costs connected therewith, all of which is pursuant to Pa.R.C.P. No. 240. BY THE COURT: rr ? Revised 9-08 C Dauphin County Court of Common Pleas FILED-Off-ICE OF THE PPOTHONOTARY 2009 OCT -5 PM 3: 00 I CNINISY LVAN A !D 5fD4 _ cofY ? a . 4;,14 vn BECKY HILT, IN THE COURT OF COMMON PLEAS OF Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. BRYAN HILT, Respondent. NO. 08-7525 CIVIL IN RE: PLAINTIFF'S EMERGENCY CUSTODY PETITION ORDER OF COURT AND NOW, this 5t' day of October, 2009, upon consideration of Plaintiff's Emergency Custody Petition, a hearing shall be held on Thursday, October 22, 2009 at 3:30 p.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, /Becky Hilt 1102 Yverdon Drive, Apt. C8 Camp Hill, PA 17011 Pro Se Petitioner ryan Hilt 333 S. Catherine St. Middletown, PA 17057 Pro Se Respondent (24r*es FILED-ICF OF THE PROT t-.: !()TARP 2009 OCT --5 Pfd 3: 01 BECKY HILT IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. BRYAN HILT 2008-7525 CIVIL ACTION LAW IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, October 07, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Friday, October 30, 2009 at 10:30 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: /s/ Dawn S. Sunda Es q. 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 FORTE{ 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 OF 2009QCT eV NC> F EZA 00ff copy n'ili< <cc -ic::) L -- p` rK?IIAC? 4,c? w?b. yu" Y BECKY HILT, Petitioner v BRYAN HILT, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 08-7525 CIVIL TERM IN RE: PLAINTIFF'S EMERGENCY CUSTODY PETITION ORDER OF COURT AND NOW, this 22nd day of October, 2009, upon consideration of Plaintiff's Emergency Custody Petition, and following a hearing at which both parties testified, and it appearing to the Court that this case should proceed to a conciliation conference which is already scheduled for October 30, 2009, the petition is referred to the Custody Conciliator, and the parties are directed to appear at the office of Dawn Sunday on Friday, October 30, 2009, at 10:30 a.m. By the Court, ? Becky Hilt 1102 Yverdon Drive Apartment 8-C Camp Hill, PA 17011 Plaintiff, pro se Marlin L. Markley, Jr., Esquire 3920 Market Street Suite 303 Camp Hill, PA 17011 For Respondent ./Dawn Sunday, Esquire 39 West Main Street Mechanicsburg, PA 17055 ;mae ?Icl ILL FU -O HCE OF THE T? .5 ORY 2,009 NOV -2 AN 94 07 PENNa is VA CIA NOV 0 9 2009 6 BECKY HILT Plaintiff VS. BRYAN HILT Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-7525 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 10 ?L day of ?J U V. , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Becky Hilt, and the Father, Bryan Hilt, shall have shared legal custody of Melody Hilt, born June 8, 2006. Major decisions concerning the Child including, but not necessarily limited to, her health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in the Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the Child. Neither party shall attempt to alienate the affections of the Child from the other party. Each party shall notify the other of any activity or circumstance concerning the Child 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. With regard to any emergency decisions which must be made, the parent having physical custody of the Child 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 with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, 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 or information given to either party as a parent as authorized by statute. 2. The Father shall have primary physical custody of the Child. 3. The Mother shall have partial physical custody of the Child on alternating weekends, beginning Friday, November 6, 2009, from Friday after work through Sunday at 5:00 p.m. In addition, the Mother shall have custody of the Child for one day every week from after work until the following morning when the Mother shall take the Child to the babysitter. The weekday period of custody shall be selected each week by agreement between the parties. 4. The parties shall share having custody of the Child on holidays as follows: A. Christmas: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 12:00 noon through Christmas Day at 5:00 p.m., and Segment B, which shall run from Christmas Day at 5:00 p.m. through December 26 at 5:00 p.m. In odd numbered years, the Mother shall have custody of the Child during Segment A and the Father shall have custody during Segment B. In even numbered years, the Father shall have custody of the Child during Segment A and the Mother shall have custody during Segment B. B. Thanksgiving: The Thanksgiving holiday shall be divided into Segment A, which shall run from Wednesday at 12:00 noon through Thursday at 5:00 p.m., and Segment B, which shall run from Thursday at 5:00 p.m. through Friday at 5:00 p.m. In odd numbered years, the Father shall have custody of the Child during Segment A and the Mother shall have custody during Segment B. In even numbered years, the Mother shall have custody of the Child during Segment A and the Father shall have custody during Segment B. C. Easter: In every year, the parent who has custody of the Child under the alternating weekly schedule on Easter Sunday shall retain custody of the Child on the holiday until 2:00 p.m. and the other parent shall have custody from Easter Sunday at 2:00 p.m. through Monday morning when that parent shall take the Child to the babysitter. D. Mother's Day/Father's Day: In every year, the Mother shall have custody of the Child for Mother's Day and the Father shall have custody for Father's Day from the Saturday before the holiday at 5:00 p.m. through Sunday at 5:00 p.m. E. Child's Birthday: The parties shall equally share having custody of the Child on her birthday each year as arranged by agreement. F. Parents' Birthdays: Each parent shall be entitled to have a period of custody with the Child on her or his birthday each year as arranged by agreement. G. Memorial Day/July Fourth/Labor Day: The parties shall share having custody of the Child on the Memorial Day holiday, Independence Day and the Labor Day holiday as arranged by agreement. H. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 5. Each party shall be entitled to have custody of the Child for vacation each year for two weeks which shall be scheduled nonconsecutively unless otherwise agreed between the parties. The Mother may exercise her periods of vacation custody in smaller increments of time but shall not schedule her vacation time to fall on more than two of the Father's custodial weekends in each calendar year. The parties shall provide each other with at least 21 days advance notice of his or her intent to schedule a period of vacation custody. The parent providing notice first shall be entitled to preference on his or her selection of vacation dates. In the event either party intends to remove the Child from the local area for a period of vacation custody, that parent shall provide advance notice to the other parent of the address and contact information for the Child. 6. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision. 7. The custody proceedings initiated by the Father at Docket Number 2009-6558 are hereby incorporated under the above-captioned Docket Number. 8. 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. cc: in L. Markley, Jr., Esquire - Counsel for Father Becky Hilt - Mother ?of t ES rn'a l BY THE COURT, BECKY HILT Plaintiff VS. BRYAN HILT Defendant Prior Judge: J. Wesley Oler, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-7525 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Melody Hilt June 8, 2006 Father 2. A custody conciliation conference was held on October 30, 2009, with the following individuals in attendance: the Father, Bryan Hilt, with his counsel, Marlin L. Markley, Jr., Esquire, and the Mother, Becky Hilt, who is not represented by counsel in this matter. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator LJU7 i`:u ti 0 F? i Lt. BECKY M. HILT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. No. 2008-7525 BRYAN HILT CIVIL ACTION—CUSTODY Defendant m rn Ao r CUSTODY STIPULATION n C-n WHEREAS, the subject of this stipulation for custody is the Plaintiffs and Defendant's child,Melody Hilt,bom June 8, 2006; and WHEREAS,the parties wish to enter into an agreement relative to custody of the child; and WHEREAS, it is in the best interest of the child that this Court decide the matter because all previous orders for custody have been issued by the Court of Common Pleas of Cumberland County, Pennsylvania, and it is the desire of both parents and all parties involved that this matter be resolved by the court in Cumberland County,thus giving this Court jurisdiction; THEREFORE, this � day of 2013, in consideration of the mutual covenants, promises, and agreements as hereinafter set forth, and intending to be legally bound, the parties agree as follows: 1. The father, Bryan Hilt shall have sole legal custody of Melody Hilt, born June 8, 2006. The parties agree that major decisions concerning their child, including, but not necessarily limited to,the child's health, welfare, education, religious training and upbringing shall be made by the father following a harmonious policy in the child's best interest. The mother agrees not to impair the father's rights to sole legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party. 2. Father,Bryan Hilt, shall have sole physical custody of the child. 3. Both parents shall refrain from making derogatory comments about the other parent in the presence of the child and to the extent possible shall prevent third parties from making such comments in the presence of the child. 4. This stipulation may only be altered by the mutual consent of mother and father. 5. It is the intention and desire of each of the undersigned parties that this Stipulation be confirmed as an order of court, without requiring their presence before the court, pursuant to Rule 1915.7. ` -,Z-I N-i2 Beck3kM. Hilt Date Bryan Hilt Date a► BECKY M. HILT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. : No. 2008-7525 BRYAN HILT, CIVIL ACTION–CUSTODY MCC m Defendant =M -'O--u -Uri PETITION TO MODIFY ORDER OF CUSTODY c — r � � U AND NOW, comes the Defendant, Bryan Hilt, by and through his attorney, Marlin L. Markley, Jr., Esquire, and files a Petition to Modify Order of Custody, and in support thereof, avers the following: 1. Plaintiff is Becky M. Hilt, Mother, an adult individual residing at 333 S. Catherine Street, Middltown, PA 17057. 2. Defendant is Bryan Hilt, Father, an adult individual residing at 116 Lotus Circle, Lancaster, PA 17602. 3. The parties are the Parents of Melody Hilt, born June 8, 2006. 4. On November 10, 2009, the Honorable J. Wesley Oler entered an order in this case granting shared legal custody, primary physical custody to father and partial physical custody to mother. 5. The parties have considered the child's best interest and agreed to the attached Custody Stipulation. N 2. 00 A4-4 C-ttf//cad WHEREFORE, Defendant respectfully requests that this Court modify the existing Order for Custody in the best interest of the child. Respectfully submitted, Marlin arkley, Jr., Esquire 3920 M,Oket Street, Suite 303 Camp Hill, Pennsylvania 17011 Date: 4 ` 0 `Z 0 q ID# 84745 Tel. (717) 635-9538 BECKY M. HILT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 2008-7525 BRYAN HILT, CIVIL ACTION—CUSTODY Defendant VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief To the extent that any of the averments are based upon an understanding or application of law,I have relied upon counsel in making this Verification. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904,relating to unworn falsification to authorities. Date: V-06 Signature: Bryan Hilt BECKY M. HILT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 2008-7525 BRYAN HILT, CIVIL ACTION—CUSTODY Defendant CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Petition upon the person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of the same in the United States Mail, Camp Hill, Pennsylvania,through first class mail and addressed as follows: Becky M. Hilt 333 S. Catherine Street Middletown,NY 17057 Respectfully submitted, Marlin L/5Tel.ley, Jr., Esquire 3920 Mreet, Suite 303 ,{ 7 Z Camp Hnsylvania 17011 Date: `1 ` 3 ID# 847 (717) 635-9538 BECKY M. HILT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. : No. 2008-7525 BRYAN HILT, CIVIL ACTION—CUSTODY Defendant CONSENT ORDER AND NOW, thisoVA4day of C(.AA4L� 2013, upon consideration of the attached r Stipulation of the parties in the above-captioned matter, consisting of two pages and bearing the written consent of the parties, AND upon direction of this court that the parties need not be present before the court in order to incorporate their Stipulation into a consent order, IT IS ORDERED that said Stipulation is incorporated herein by.reference as if set forth in full and approved as a Consent Order pursuant to Pennsylvania Rule of Civil Procedure, Rule 1915.7. BY THE COURT: C3 r Distribution: yo"-Marlin Markley,Esq.,3920 Market Street, Suite 303, Camp Hill,PA 17011 y ,Rebecca M. Hilt,333 S. Catherine Street,Middletown,PA 17057 0