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HomeMy WebLinkAbout10-3892OM CSC TA U UI AKIS Kara W. Haggerty, Esquire Attorney I.D. #. 86914 2 West High Street Carlisle, PA 17013 (717) 249-0900 SCOTT L. HOOVER, Plaintiff V. AMY S. HOOVER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. CIVIL TERM CIVIL ACTION - LAW IN CUSTODY 1. Plaintiff is the Father, Scott L. Hoover, who currently resides at 14 Osprey Way, Shippensburg, Cumberland County, Pennsylvania 17257. 2. Defendant is the Mother, Amy S. Hoover, who currently resides at 1301 Mary Avenue, Shippensburg, Cumberland County, Pennsylvania 17257. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. Paragraphs one (1) through three (3) of this Complaint are incorporated herein by reference as though set forth in full. 5. The Plaintiff seeks shared custody of Tyler Hoover, born October 3, 2000. 6. Tyler was born in wedlock. Fn 34 2010 ' i 1 ;s3UNTY Cl)1tl? i haNE,? 0JAN41 Pv' A1q .??3 Ulu 7. The child is in the primary custody of the Defendant, residing at 1301 Mary Avenue, Shippensburg, Pennsylvania. During the child's lifetime, he has resided with the following persons and at the following addresses: Name Address Date 1301 Mary Avenue Birth to present Amy Hoover Shippensburg, PA 8. The father of the child is Scott Hoover, who currently resides at 14 Osprey Way, Shippensburg, Cumberland County, Pennsylvania 17257. 9. The mother of the child is Amy Hoover, who currently resides at 1301 Mary Avenue, Shippensburg, Cumberland County, Pennsylvania 17257. 10. The mother and father of the child are currently married, but have been separated for several years. 11. The relationship of Plaintiff to the child is that of Father. 12. The relationship of Defendant to the child is that of Mother. 13. The Plaintiff currently resides with his fiancee, Ronda Carver and her daughter, Tiffany Myers, age 10. 14. The Defendant currently resides with their minor child, Tyler Hoover, and her fiancee, Matthew Stouffer. 15. The 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 any other court 16. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 17. The Plaintiff does not know of a person nor 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. 18. The best interest and permanent welfare of the child will be served by granting the relief requested for reasons including the following: a. Since October 2009 Father has been exercising regular and routine custody of Tyler. b. Since October 2009 the custody arrangement has been very open ended with both Mother and Father working together to permit Father custody time with Tyler. c. The parties have been in the process of trying to reach a custody agreement; however, those negotiations have not yet been completed. d. Father is seeking a regular and specifically outlined custody schedule for custody of Tyler to insure that his contact remains uninterrupted. e. The parties reside in very close proximity to one another that would allow an easy transition to a shared custody arrangement. f. Father is equally able to insure for the child's safety and care. g. Father is able to provide a stable home for the child. h. The child has a psychological bond with his Father. i. Father can provide for the child both financially and emotionally. 19. Each parent whose parental rights to the child have not been terminated has been named as parties to this action. t?IYEREF'ORE, the Plaintiff requests that This Honorable Court grant shared legal and physical custody of the minor child to both the Plaintiff/Father and the Defendant/Mother. Respectfully submitted, ABom & SuTutA"S, L.L.P. DATE V U' V 0 Kara W. Haggerty Supreme Court ID 8 9 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaintiff 1?1x I, SCOTT L. HOOVER, verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information, and belief. 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 l ! /D J ? . ?ko? SCOTT L. HOOVER CERTIFICATE OF SERVICE AND NOW, this day of June, 2010, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Custody Complaint, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, Certified mail and First-class mail, postage prepaid addressed to the following. Jerry A. Weigle, Esquire Weigle & Associaets, P.C. 126 East King Street Shippensburg, PA 17257 Respectfully submitted, ABOM & SUTULA"S, L.L.P. Kara W. Haggerty, ID No. 86914 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff .;, _, SCOTT L. HOOVER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 2010-3892 CIVIL ACTION LAW m AMY S. HOOVER TN CUSTODY n1F1-NDANT ^~ ~ , ORDER OF COURT ,AN D NOVV, Monday, June 21, 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 conciliar at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, July_22, 2010 ___ at .9:00 All for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; of 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, Suecial Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By; /s/ ohn .Man an r. 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 a~~ailable 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"1'TORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FOR'T'1-{ BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. l ' Cumberland County Bar Association `/~ < <~ 32 South Bedford Street nw_ ' ~1 f ~ I ~~ K• Carlisle, Pennsylvania 17013 (,•~I ~ (£~(,,~p ~fI'elephone (717) 249-3166 ear ~.~.~. ~o ~,.,.~, I ~~