HomeMy WebLinkAbout04-3032ROBIN E. ZORN,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
V,
RALPH B. ZORN, JR.,
Defendant
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 2004 '~.~u,__. CIVIL TERM
:
: CUSTODY
COMPLAINT FOR CUSTODY
NOW come the plaintiff, ROBIN E. ZORN, by her attorney, Harold S. Irwin, Ill,
Esquire, and presents the following complaint for custody, representing as follows:
1. Plaintiff ROBIN E. ZORN, is an adult individual residing at 6206 Devonshire
Heights Road, Harrisburg, Dauphin County, Pennsylvania 17112.
2. Defendant RALPH B. ZORN, JR., is an adult individual residing at 1150
Crane's Gap Road, Carlisle, Cumberland County, Pennsylvania 17013.
3. The parties were married on February 21, 1998, but separated on June 17,
2004.
4. Plaintiff seeks custody of the following children:
Name
SETH M. ZORN
AMYN. ZORN
Present Residence
6206 Devonshire Heights Road
Harrisburg, PA 17112
ARe
14 years
DOB 10/30/1989
6206 Devonshire Heights Road 7 years
Harrisburg, PA 17112 DOB 08/10/1996
5. Plaintiff has not participated as a party or witness, or in another capacity, in
other litigation conceming the custody of the children in this or another court.
6. Plaintiff has no information of a custody proceeding concerning the children
pending in a court of this Commonwealth or any other state.
7. Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the children or claims to have custody or visitation rights with respect
to the children.
8. The best interests and permanent welfare of the children require that the
parties have joint legal custody of the children, but that the plaintiff have primary physical
custody, subject to periods of supervised visitation by the defendant.
WHEREFORE, the plaintiffs request that the court enter an order providing for the
legal and physical custody of the children as aforesaid.
June~-~,2004
~~1., III
Carlisle, Pennsylvania 17013-3220
(717) 243-6090
Supreme Court I.D. No. 29920
June~2004
VERIFICATION
I do hereby verify that the facts set forth in this petition are true and correct.
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A.
§4904, relating to unsworn falsification to authorities.
ROBIN E. zoR~
ROBIN E. ZORN
PLAINTIFF
V.
RALPH B. ZORN, JR.
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
04-3032 CIVIL ACTION LAW
:
: IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, July 13, 2004 ., upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before ltubert X. Gilroy, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Friday,. August 06, 2004 at 9:30 AM
for a Pre-Hearing Custody Conference. At such conference, an eftbrt 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. All children age five or older may also be w'esent at the conference. Failure to appem- at the conference ma,/
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/ Hubert X. Gilroy, Esq. mhc
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 beibre the court. You must
attend the scheduled conference or hearing.
YOU SItOULD TAKE THIS PAPER TO YOUR A'ITORNEY 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
SEP ~ 0
ROBIN E. ZORN,
Plaintiff
V
RALPH B ZONR, JR.,
Defendant
: IN THE COIYRT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
:
: NO. 04-3032
: IN CUSTODY'
COURT ORDER
AND NOW, thisf~~/?[ day of ~"~'g~'~'~ , 2004, the Conciliator being
advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction.
BY THE COUB',T,
cH~teo~yX~oncilia~o r