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HomeMy WebLinkAbout04-1870 Nathan R. Hockenberry, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 04 - 1~1o CIVIL TERM Tasha Marie Wilson, Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Nathan R. Hockenberry, residing at IS Rehobeth Road, Shippensburg, Cumberland County, Pennsylvania 17257. 2. The defendant is Tasha Marie Wilson, residing at 20 Fairfield Street, Newville, Cumberland County, Pennsylvania 17241. 3. Plaintiff seeks custody of the following child: Name Lariah-Ann Wilson Present Residence 20 Fairfield St. Newville, PAl 7241 DOB 09/1 I/03 Age 7 months The child was born out of wedlock 4. The child is presently in the custody of Tasha Marie Wilson, residing at 20 Fairfield Street, Newville, Cumberland County, Pennsylvania 17241. During the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All AddresseS Dates Tasha Marie Wilson 20 Fairfield St. Newville, PA 17241 09/1 I/03 7 months 5. The mother of the children is Tasha Marie Wilson, residing at 20 Fairfield Street, Newville, Cumberland County, Pennsylvania 17241. She is unmarried. 6. The father of the children is Nathan R. Hockenberry, residing at 15 Rehobeth Road, Shippensburg, Cumberland County, Pennsylvania 17257. He is unmarried. 7. The relationship of plaintiff to the child is that offath(:r. The plaintiff currently resides with the following persons. Name Kelly & Sandra Hockenberry Relationship Parents 8. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons. Name Scott & Marie Wilson Relationship Parents 9. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. 10. The best interest and permanent welfare of the child will be served by granting the relief request because: A Court Order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. WHEREFORE, Plaintiff requests this Court grant Plaintiff shared physical custody subject to Plaintiff and Defendant. Respectfully submitted, ROMINGER, BAYLEY & WHARE Date: Lf- J{g-Oll( M{::l~~uirf ~Jl 155 S. Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court J.D. # 89028 Attorney for PlaintilJ VERIFICA nON 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. S 4904 relating to unsworn falsification to authorities. Nathan R. Hockenberry laintiff 8 ....." "'" ~ ~ ~ ".. <=> 0 -ore .c- - :> ~:!J =f=. ~ - CCI r-~-l ...., <;:> ...::.~ ',', -:,:'.... ;:.-,~ :;;0 d (h~:" N :g~ 'S ~ ;~,.^ ....... .- 0 -I:> -' :=?::rl ~ ~ <s.:::o -0 -U ~ !Cc;. (--~ ::l:: >c~: 2(~ z ~ or ~ =< ~ .r :::s- >> '~ ,.., NATHAN R. HOCKENBERRY PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 04-1870 CIVIL ACTION LAW TASHA MARIE WILSON DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, May 11, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, May 27, 2004 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 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 existin!: Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Hubert X. Gilroy.. Esq. Custody Conciliator mhc 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 A TIORNEY 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 ~~-# ~~~ ~ -# 1 .'~~~ ~u., fr4p. ~ ~ ~~v>'1 ~ 'P9 Vit<\jr~l\Si\Jr\r~ld I I NIV','-' '-"-'Aln" 1\.1..1 'l'~',,) ,""::dr~ V LO:~ !4d II AVIHDDZ AUlflONOH108d 3Hl .:10 3:J!=!30-G31H /trJ-/I.> ACl-//y /117//.7' SEP 0 5 20~ NATHAN R. HOCKENBERRY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. NO. 04-1870 CIVIL ACTION - LAW TASHA MARIE WILSON, Defendant IN CUSTODY ORDER AND NOW, this r-..,c day of September, 2006, the above ease being previonsly assigned to the Conciliator and there being no activity on this case for a period of six months or more, the Conciliator relinquishes jurisdiction. Hubert X. Gilroy squire Custody Concilia or 00.11 UP l'j . I ..,' ,I . .. ,,,lJ g.- ens SuUl