HomeMy WebLinkAbout10-1016FILED-OFFICE
OF I ME F;IRt THONOTARY
2010 FEB -9 AM 8: 56
HELEN A. HOAG, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : Cuio 14, "WENNSYLVAN
v. : CIVIL ACTION-- 1 AW r
NO. 2010 , -CIVIL TERM
MARK A. PETERSON,
Defendant : IN CUSTODY
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COMPLAINT FOR CUSTODY
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NOW comes the plaintiff, HELEN A. HOAG, by her attorney, Harold S. Irwin, III, Esquire, and
presents the following complaint for custody, representing as follows:
1. The plaintiff is HELEN A. HOAG, an adult individual residing at 117 South Hanover Street,
Apartment 1, Carlisle, Cumberland County, Pennsylvania 17013.
2. The defendant is MARK A. PETERSON, an adult individual residing at 202 Second Street,
Apartment 2A, Highspire, Dauphin County, Pennsylvania 17034.
3. The parties are the natural parents of a minor son, namely, ROBERT A. PETERSON (born
December 8, 2002)
4. The child resided with both parties until the parties' separation on or about February, 2006.
Since then, the child has lived primarily with the plaintiff.
5. 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.
6. Plaintiff has no information of a custody proceeding concerning the child pending in a court
of this Commonwealth or any other state.
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7. 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.
8. The best interests and permanent welfare of the child require that the parties have joint
legal custody of the child, but that plaintiff have primary physical custody and that defendant have
specified periods of partial physical custody of the child on a schedule to be determined at a
conciliation conference.
WHEREFORE, the plaintiff requests that the court enter an order providing for the legal and
physical custody of the child as aforesaid.
January , 2008
HAROLD S. IRWIN, I
Attorney for Plaintiff
64 South Pitt Street
Carlisle, Pennsylvania 17013-3220
(717) 243-6090
Supreme Court I.D. No. 29920
VERIFICATION
I do hereby verify that the facts set forth in this petition are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to
unsworn falsification to authorities.
JanuaryQ:D , 2010
HELEN A. HOAG
HELEN A. HOAG IN THE COURT OF COMMON PLEAS OF
PLA[NTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
MARK A. PETERSON
DEFENDANT
• 2010-1016 CIVIL ACTION LAW
. IN CUSTODY
ORllER OF COURT
AND NOW, _~ _ Friday, Febru~ 12, 2010 _ _, upon consideration of the attached. Complaint,
it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. ,the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, March 25, 2010 at 10:30 AM
for aPre-I-Iearin~ Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot he 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 12elief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR. THE COUK"T,
By: /s/ john J. ManganZ Jr., Esq.~~ _`_
Custody Conciliator
The Court of Common Pleas of Cumberland Countyrs 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. Ali 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
FORTI i BELOW TO FIND OUT WI-fERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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