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HomeMy WebLinkAbout09-6558BRYAN HILT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. (? G 5 S? ?.un.? -7 REBECCA M. HILT, CIVIL ACTION -CUSTODY Defendant COMPLAINT FOR CUSTODY The Plaintiff, Bryan Hilt, by and through his attorney, Marlin L. Markley, Jr., seeks to obtain joint legal custody and primary physical custody of his minor child and makes the following averments in support thereof- 1 . The Plaintiff, Bryan Hilt, is an adult individual who currently resides at 333 South Catherine Street, Middletown, Dauphin County, Pennsylvania 17057. 2. The Defendant, Rebecca M. Hilt, is an adult individual who currently resides at 1102 Yverdon Drive, Apartment C8, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff seeks custody of the following child: Name Present Address Age Melody M. Hilt 333 S. Catherine St. 3 Middletown, PA 17057 1102 Yverdon Dr., Apt. C8 Camp Hill, PA 17011 The child was not born of out wedlock. The child is presently in the custody of Bryan Hilt who resides at 333 S. Catherine St., Middletown, Pennsylvania, and Rebecca M. Hilt' who resides at 1102 Yverdon Drive, Apartment C8, Camp Hill, Pennsylvania 17011. During the past five years, the child has resided with the following persons and at the following addresses: Dates: 8/2009 - present 8/2009 - present 8/2008 - 8/2009 8/2007 - 8/2008 Birth - 8/2007 Addresses: List All Persons: 333 S. Catherine St. Father, Bryan Hilt Middletown, PA Paternal Grandfather, Bethamy Hilt 1102 Yverdon Dr., Apt.C8 Mother, Rebecca Hilt Camp Hill, Pa 145 Bosler Ave. Lemoyne, PA 1100 Yverdon Dr. Camp Hill, PA 333 S. Catherine St. Middletown, PA Father, Bryan Hilt Mother, Rebecca Hilt Father, Bryan Hilt Mother, Rebecca Hilt Father, Bryan Hilt Mother, Rebecca Hilt The mother of the child is Rebecca M. Hilt, currently residing at 1102 Yverdon Drive, Apartment C8, Camp Hill, Cumberland County, Pennsylvania 17011. She is divorced. The father of the child is Bryan Hilt, currently residing at 333 South Catherine Street, Middletown, Dauphin County, Pennsylvania 17057. He is divorced. 4. The relationship of plaintiff to the child is that of natural father. The plaintiff currently resides with his parents and the child. 5. The relationship of defendant to the child is that of natural mother. The defendant currently resides with the child. 6. Plaintiff has participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. The court, term and number, and its relationship to this action is: Dauphin County Court of Common Please, Docket No. 2009-CV-11856-AB, a temporary PFA has been awarded on Plaintiff's behalf and against the Defendant, the PFA awards temporary custody of the minor child to the Plaintiff. Other than the above mention PFA action Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. Plaintiff does 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Plaintiff can provide the child with adequate moral, emotional, and physical surroundings as required to meet the child's needs; b. Plaintiff would accommodate the child developing a healthy relationship with both parents. C. Plaintiff is willing to look out for the child's best interest. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child 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 will be given notice of the pendency of this action and the right to intervene: none. WHEREFORE, plaintiff requests the court to grant him primary physical custody of his child. Respectfully ?Mazliri kley, Jr., Esquire 39,20 Mar t Street, Suite 303 Camp Hil, Pennsylvania 17011 Date: 3 ?, Z 4a /q ID# 8474 Tel. (717) 635-9538 BRYAN HILT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. No. REBECCA M. HILT, CIVIL ACTION - CUSTODY Defendant 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.C.S. § 4904, relating to unsworn falsification to authorities. Date: O ?? ?%?????/?1?;? Bryan Hilt OF error orNn M©CT-1 AMIIs49 CuwkFx.40 COL MY PDJMVANiA *I WS .!50 PO ATM &'+ Ioo4 P.,T+ -A31310 BRYAN HILT IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-6558 CIVIL ACTION LAW REBECCA M. HILT 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. Sunday, Esq. 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 FIt ?6 `?rs ,NARY 2009 D? - AM I 1: 5 !o/£3/U4 - ar: a, oy,yA LCL -?6 n?, ' t . ITY eYtc%Ltq4 -4c3 R.