HomeMy WebLinkAbout04-5550KAREN ANNE HOSTETLER,
Plaintiff
VS.
BRIAN HOSTETLER,
Defendant · CUSTODY
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04- .5~.56~6 CIVIL TERM
COMPLAINT FOR CUSTODY
1. The plaintiff is Karen Anne Hostetler, hereinafter referred to as Mother. Mother's
current residence is 320 Bridge Street, PO BOX 104, Mardela Springs, Wicomico County,
Maryland 21837.
2. The defendant is Brian Hostetler, hereinafter referred to as Father, residing at 139 East
Columbia Road, Cumberland County, Enola, Pennsylvania 17025.
3. Mother seeks a schedule for partial custody of the minor child:
Name Present Residence
Brendan Hostetler 139 East Columbia Road
Enola, PA 17025
The child, Brendan Hostetler, was bom prior to the parties being married.
Brendan is presently in the custody of Father.
During Brendan's lifetime, he has resided with the following persons and at the
following addresses:
Name
Karen and Brian Hostetler
Address
4517 Linden Ave Unit D
Mechanicsburg, PA 17055
Age
9/18/99 DOB, 5 years old
Date
Newborn - 3 years
Karen and Brian Hostetler
139 East Columbia Road
Enola, PA 17025
3 yrs - 4 yrs / 11 mo.
Brian Hostetler
Mother and Father are separated.
139 East Columbia Road
Enola, PA 17025
4 yrs/11 mo. - present
4. Mother currently resides with the following persons:
Nallle
Bonita Humphreys
Gary Humphreys
Relationship
Mother
Step-Father
5. It is believed that Father currently resides with the following persons:
Name Relationship
Brendan Hostetler Son
6. Mother has not participated as a party or witness, or in another capacity, in other
litigation concerning the custody of Brendan in this or another court.
7. Mother has no information of a custody proceeding concerning Brendan pending in a
court of this Commonwealth.
8. Mother does not know of a person not a party to the proceedings who has physical
custody of Brendan or claims to have custody or visitation rights with respect to Brendan.
9. The best interest and permanent welfare of Brendan will be served by granting the
relief requested for reasons including, but not limited to the following:
a) Mother has a stable home environment that is safe and appropriate for periods
of partial custody with Brendan.
b) Mother lives with her parents, who are Brendan's grandparents, and there is a
very supportive family environment
c) Mother is willing to communicate with and work cooperatively with the
Father to co-parent Brendan and will encourage both the mother/son and
father/son relationship.
d) On her own initiative, Mother took a parenting course, when Brendan was a
baby so she could further educate herself with positive and effective parenting
skills.
10. Father has not acted in the best interest of Brendan in ways including but not limited
to the following:
a) Father did not want Mother to give birth to Brendan and requested that
Mother abort the pregnancy.
b) When Brendan was two years old, Father dropped Mother and Brendan off at
a shelter and told Mother not to return. Mother was eventually able to return
to the home two days later.
c) Father had little parental interaction with Brendan until August 2004, when
Father told Mother to leave the marital residence but kept Brendan.
d) Father has been arbitrary in deciding when and if Mother can visit with
Brendan, despite Mother's offers to travel the entire distance from her home
in Maryland to Enola, Pennsylvania.
e) Father has a beach house in Ocean City, Maryland, that is forty-five minutes
from Mother's residence in Maryland. Father will not bring Brendan on trips
to the beach house in an effort to preclude Mother from spending even
minimal amounts of time with Brendan. Mother specifically asked Father to
bring Brendan so she could spend time with him and Father refused, instead
leaving Brendan with the paternal grandmother to baby-sit.
f) Father prevents the healthy development of a bond between Mother and
Brendan by refusing to allow them to have regular contact with each other.
g) Father, on a regular basis, screamed at and abused Mother in front of Brendan.
On at least one occasion, Father spanked Brendan so hard that he had welts on
his skin. Additionally, Father has used excessive and inappropriate physical
punishment to correct Brendan's behaviors.
h) Mother fears that without a custody order in place, Father will continue to
deprive her of regular contact with Brendan, which will further deteriorate
their relationship.
11. Each parent whose parental fights to Brendan have not been terminated and the
person who has physical custody of Brendan have been named as parties to this action.
WHEREFORE, Mother requests this Court to grant her the following relief:
a) Grant the parties shared legal custody of Brendan.
b) Grant Father primary custody of Brendan.
c) Grant Mother periods of partial custody of Brendan subject to the
following schedule:
1. At least one weekend every month from Friday at 4 p.m. until
Sunday at 4 p.m.
e)
g)
2. In addition to the one weekend per month, any weekend
Brendan has a Monday or Friday off of school for an extended
three-day weekend. This weekend would last either from
Thursday at 4 p.m. until Sunday at 4 p.m. or from Friday at 4
p.m. until Monday at 4 p.m.
3. During summers from the week after school ends, until the
week before school begins in the fall.
Establish an appropriate holiday schedule so that each party is able to have
time with Brendan.
Order that the parents shall share transportation responsibilities to meet at
a halfway point between their residences.
Order that Mother shall have reasonable telephone contact with Brendan
while he is in Father's custody.
Any additional relief the court deems proper.
Respectfully submitted,
Attorney for Plaintiff
Mid Penn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
VERIFICATION
The above-named Plaintiff, Karen Anne Hostetler, verifies
that the statements made in the above Complaint For Custody are
true and correct. Plaintiff understands that false statements
herein are made subject to the penalties of 18 Pa. C.S. §4904,
relating to unsworn falsification to authorities.
Date' /'C'/q'r'"?~
Karen Anne Hostetler
KAREN ANNE HOSTETLER,
Plaintiff
VS.
BRIAN HOSTETLER,
Defendant · CUSTODY
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04- CIVIL TERM
AFFIDAVIT OF SERVICE BY MAIL
I, Jessica Diamondstone, do hereby swear that I served Brian Hostetler with a
Complaint For Custody on-~//~/{A/{/o9 b-g~ , 2004 by certified mail, return receipt, restricted
delivery, to the person and address below:
Brian Hostetler
139 East Columbia Road
Enola, PA 17025
I, Jessica Diamondstone, verify that the statements made in this Affidavit of Service are
true and correct. I understand that false statements herein are made subject to the penalties of 18
Pa.C.S. Section 4904 relating to unsworn falsification to authorities.
Date: 5 //~4/~,9'/~2~ ZC2~/ Signature: ~
KAREN ANNE HOSTETLER,
Plaintiff
VS.
BRIAN HOSTETLER,
Defendant · CUSTODY
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04- ~5~.5'~3 CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Karen Anne Hostetler, Plaintiff, to proceed in forma vauperis.
I, Jessica Diamondstone, attorney for the party proceeding in forma pauperis, certify that
I believe the party is unable to pay the costs and that I am providing free legal services to the
Jessica Diamondstone
Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
KAREN ANNE HOSTETLER
PLAINTIFF
BRIAN HOSTETLER
DEFENDANT
IN THE COURT OF C, OMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
04-5550 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, November 16, 2004 ., upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday,. December 02, 2004 at 9:30 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. Ali 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 existing Protection from Abuse orders,
Sl~ecial Relief orders, and Custody orders to the conciliator 48 hours l~rior to scheduled hearing.
FOR THE COURT,
By: /s/ .[acqueh'~e M. Vetae. y~ 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 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 170 ~I 3
Telephone (717) 249-3166
NOV 0 & 200~
KAREN ANNE HOSTETLER,
Plaintiff
VS.
BRIAN HOSTETLER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04- ,5'3'37) CIVIL TERM
CUSTODY
ORDER OF COURT
AND NOW, upon consideration of the attached complaint, it is hereby directed that the
parties and their respective counsel appear before ,
the conciliator, at on the day of ., 2004, at __ .m.,
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 mad 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.
By the Court,
Date:
Custody Conciliator
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER 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, PA 17013
(717) 249-3166 OR (800) 990-9108
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
Pease 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.
KAREN ANNE HOSTETLER,
Plaintiff
VS.
BRIAN HOSTETLER,
Defendant 'CUSTODY
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04- ~-~%"6 CIVIL TERM
COMPLAINT FOR CUSTODY
1. The plaintiff is Karen Anne Hostetler, hereinafter referred to as Mother. Mother's
current residence is 320 Bridge Street, PO BOX 104, Mardela Springs, Wicomico County,
Maryland 21837.
2. The defendant is Brian Hostetler, hereinafter referred to as Father, residing at 139 East
Columbia Road, Cumberland County, Enola, Pennsylvania 17025.
3. Mother seeks a schedule for partial custody of the minor child:
Name Present Residence
Brendan Hostetler 139 East Columbia Road
Enola, PA 17025
The child, Brendan Hostetler, was born prior to the parties being married.
Brendan is presently in the custody of Father.
During Brendan's lifetime, he has resided with the following persons and at the
following addresses:
Name
Karen and Brian Hostetler
Address
4517 Linden Ave Unit D
Mechanicsburg, PA 17055
Age
9/18/99 DOB, 5 years old
Date
Newborn - 3 years
Karen and Brian Hostetler
139 East Columbia Road
Enola, PA 17025
3 yrs- 4 yrs / 11 mo.
Brian Hostetler
Mother and Father are separated.
139 East Columbia Road
Enola, PA 17025
4 yrs/11 mo. - present
Name
Bonita Humphreys
Gary Humphreys
Mother currently resides with the following persons:
Relationship
Mother
Step-Father
5. It is believed that Father currently resides with the following persons:
Name Relationship
Brendan Hostetler Son
6. Mother has not participated as a party or witness, or in another capacity, in other
litigation concerning the custody of Brendan in this or another court.
7. Mother has no information of a custody proceeding concerning Brendan pending in a
court of this Commonwealth.
8. Mother does not know of a person not a party to the proceedings who has physical
custody of Brendan or claims to have custody or visitation rights with respect to Brendan.
9. The best interest and permanent welfare of Brendan will be served by granting the
relief requested for reasons including, but not limited to the following:
a) Mother has a stable home environment that is safe and appropriate for periods
of partial custody with Brendan.
b) Mother lives with her parents, who are Brendan's grandparents, and there is a
very supportive family environment
c) Mother is willing to communicate with and work cooperatively with the
Father to co-parent Brendan and will encourage both the mother/son and
father/son relationship.
d) On her own initiative, Mother took a parenting course, when Brendan was a
baby so she could further educate herself with positive and effective parenting
skills.
10. Father has not acted in the best interest of Brendan in ways including but not limited
to the following:
a) Father did not want Mother to give birth to Brendan and requested that
Mother abort the pregnancy.
b) When Brendan was two years old, Father dropped Mother and Brendan off at
a shelter and told Mother not to return. Mother was eventually able to return
to the home two days later.
c) Father had little parental interaction with Brendan until August 2004, when
Father told Mother to leave the marital residence but kept Brendan.
d) Father has been arbitrary in deciding when and if Mother can visit with
Brendan, despite Mother's offers to travel the entire distance from her home
in Maryland to Enola, Pennsylvania.
e) Father has a beach house in Ocean City, Maryland, that is forty-five minutes
from Mother's residence in Maryland. Father will not bring Brendan on trips
to the beach house in an effort to preclude Mother from spending even
minimal amounts of time with Brendan. Mother specifically asked Father to
bring Brendan so she could spend time with him and Father refused, instead
leaving Brendan with the paternal grandmother to baby-sit.
f) Father prevents the healthy development of a bond between Mother and
Brendan by refusing to allow them to have regular contact with each other.
g) Father, on a regular basis, screamed at and abused Mother in front of Brendan.
On at least one occasion, Father spanked Brendan so hard that he had welts on
his skin. Additionally, Father has used excessive and inappropriate physical
punishment to correct Brendan's behaviors.
h) Mother fears that without a custody order in place, Father will continue to
deprive her of regular contact with Brendan, which will further deteriorate
their relationship.
11. Each parent whose parental rights to Brendan have not been terminated and the
person who has physical custody of Brendan have been named as parties to this action.
WHEREFORE, Mother requests this Court to grant her the following reliefi
a) Grant the parties shared legal custody of Brendan.
b) Grant Father primary custody of Brendan.
c) Grant Mother periods of partial custody of Brendan subject to the
following schedule:
1. At least one weekend every month from Friday at 4 p.m. until
Sunday at 4 p.m.
f)
g)
2. In addition to the one weekend per month, any weekend
Brendan has a Monday or Friday off of school for an extended
three-day weekend. This weekend would last either from
Thursday at 4 p.m. until Sunday at 4 p.m. or from Friday at 4
p.m. until Monday at 4 p.m.
3. During summers fi.om the week after school ends, until the
week before school begins in the fall.
Establish an appropriate holiday schedule so that each party is able to have
time with Brendan.
Order that the parents shall share transportation responsibilities to meet at
a halfway point between their residences.
Order that Mother shall have reasonable telephone contact with Brendan
while he is in Father's custody.
Any additional relief the court deems proper.
Respectfully submitted,
'-'~J~s sic a/Ig~amondstone ~-~
Attorney for Plaintiff
Mid Penn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
VERIFICATION
The above-named Plaintiff, Karen Anne Hostetler, verifies
that the statements made in the above Complaint For Custody are
true and correct. Plaintiff understands that false statements
herein are made subject to the penalties of 18 Pa. c.s. §4904,
relating to unsworn falsification to authorities.
Date: /4~'/~;'~ ~'
Karen Anne Hostetler
KAREN ANNE HOSTETLER,
Plaintiff
VS.
BRIAN HOSTETLER,
Defendant · CUSTODY
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04- CIVIL TERM
AFFIDAVIT OF SERVICE BY MAIL
I, Jessica Diamondstone, do hereby swear that I served Brian Hostetler with a
Complaint For Custody on~//~/(~ff/~ , 2004 by certified mail, return receipt, restricted
delivery, to the person and address below:
Brian Hostetler
139 East Columbia Road
Enola, PA 17025
I, Jessica Diamondstone, verify that the statements made in this Affidavit of Service are
tree and correct. I understand that false statements herein are made subject to the penalties of 18
Pa.C.S. Section 4904 relating to unswom falsification to authorities.
Date: 5 //~/~,~/r//ge/ ZC2_~/~ Signature:
Z~:
KAREN ANNE HOSTETLER,
Plaintiff
VS.
BRIAN HOSTETLER,
Defendant · CUSTODY
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04- 55'.5~c~ CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Karen Anne Hostetler, Plaintiff, to proceed in forma pauperis.
I, Jessica Diamondstone, attorney for the party proceeding in forma pauperis, certify that
I believe the party is unable to pay the costs and that I am providing free legal services to the
party.
Jessica Diamondstone
Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
DEC 0 2004,
KAREN ANNE HOSTETLER,
Plaintiff
V.
BRIAN HOSTETLER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 2004-5550 CIVIL TERM
: CIVIL ACTION - LAW
:
: IN CUSTODY
ORDER OF COURT
AND NOW, this (,,," day of ~e.r,.,~,~r ., 2004, upon
consideration' of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The Mother, Karen Anne Hostetler, and the Father, Brian Hostetler, shall
have shared legal custody of Brendan Hostetler, born September 18, 1999. Each parent
shall have an equal right, to be exercised jointly with fhe other parent, to make all major
non-emergency decisions affecting the Child's general well-being including, but not
limited to, all decisions regarding his health, education and religion.
2. Father shall have primary physical custody of the Child.
3. Mother shall have partial physical custody of the Child on Sunday
December 26, 2004 from 12:00 noon to 4:00 p.m. Said partial custody shall take place in
Cumberland County and the Mother shall not remove the Child from Cumberland
County.
4. This Order was entered pursuant to an agreement of the parties at a
Custody Conciliation Conference. The parties may modify the provisions of this Order
by mutual consent. In the absence of mutual consent, the terms of this Order shall
control. Another Conciliation Conference is scheduled for January 14, 2005 at 1:30 p.m.
on the fourth floor of the Cumberland County Court. House.
BY TIlE COURT,
/l~chard Rupp, Esquire, Counsel for Father
Jo
KAREN ANNE HOSTETLER,
Plaintiff
BRIAN HOSTETLER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: 2004-5550 CIVIL TERM
: CIVIL ACTION - LAW
:
: IN CUSTODY
PRIOR JUDGE: None
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME
Brendan Hostetler
DATE OF BIRTH
September 18, 1999
CURRENTLY IN CUSTODY OF
Father
2. A Conciliation Conference was held in this matter on December 2, 2004.
Mother, Karen Anne Hostetler, was present by telephone, with her counsel, Jessica
Diamondstone, Esquire, Mid Penn Legal Services and Father, Brian Hostetler, was
present with counsel, Richard Rupp, Esquire.
3. The parties agreed to an Order in the form attached.
Date
~acq~line M. Vemey, Esquire
Custody Conciliator
JAN 1 8
. \[..
IUlh "
~j1'
KAREN ANNE HOSTETLER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
V.
: NO. 2004-5550 CIVIL TERM
: CIVIL ACTION - LAW
BRIAN HOSTETLER,
Defendant
: IN CUSTODY
ORDER OF COURT
AND NOW, this J q' day of f~~ ' 2005, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
I. The prior Order of Court dated December 6, 2004 shall remain in full
force and effect with the following modification and additions:
2. Mother shall submit to an independent psychiatric evaluation by a doctor
agreed to by the parties' counsel. In this regard, Mother shall sign the appropriate
releases so that the psychiatrist may review all prior mental health records of Mother.
Father shall pay the cost of the independent psychiatric evaluation and all medical
records.
3. Pending the psychiatric evaluation, Mother shall have periods of partial
physical custody of the child on alternating weekends, Saturday and Sunday from 12:00
noon to 4:00 p.m. Said partial physical custody shall begin the weekend of February 5
and 6, 2005 and continue thereafter on an alternating weekend schedule. Mother shall
not remove the child from Cumberland County.
4. Mother shall have additional periods of partial physical custody as the
parties agree.
5. Mother shall be entitled to call the child every Tuesday at 8:00 p.m. and
every Thursday at 7:00 p.m.
6. This Order was entered pursuant to an agreement of the parties at a
Custody Conciliation Conference. The parties may modify the provisions of this Order
by mutual consent. In the absence of mutual consent, the terms of this Order shall
control. Another Conciliation Conference may be scheduled by either party once the
psychiatric evaluation is complete.
l.S:8
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BY THE COURT,
/I~
cc: Jessica Diamondstone, Esquire - Counsel for
Richard Rupp, Esquire, Counsel for Father
1.
/uru" .~i!e..{ j- oZ/-()$'
C)-,
JAN 1 8 2CC5
jL\l
KAREN ANNE HOSTETLER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: 2004-5550 CIVIL TERM
: CIVIL ACTION - LAW
BRIAN HOSTETLER,
Defendant
: IN CUSTODY
PRIOR JUDGE: Kevin A. Hess, J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN CUSTODY OF
Brendan Hostetler
September 18, 1999 Father
2. A Conciliation Conference was held in this matter on January 13,2005.
Mother, Karen Anne Hostetler, was present with her counsel, Jessica Diamondstone,
Esquire, Mid Penn Legal Services and Father, Brian Hostetler, was present with counsel,
Richard Rupp, Esquire.
3. A prior Order of Court dated December 6,2004 was entered by the
Honorable Kevin A. Hess providing for shared legal custody, Father having primary
physical custody with Mother having a period of partial physical custody on December
26, 2004 for four hours.
4. The parties agreed to an Order in the form attached.
1- /(-{})
Date
i . 11. II
."" 'r....-k'--f IV ~ ~.?5"
Mcqu6!ine M. Verney, Esquire
Custody Conciliator
KAREN ANNE HOSTETLER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
V. 2004-5550 CIVIL ACTION LAW
BRIAN HOSTETLER a=?,?
IN CUSTODY =
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DEFENDANT Wr-
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ORDER OF COURT ca
?n
AND NOW, Wednesday, April 20, 2011 , upon consideration of the attached-Coniclai n
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, May 20, 2011 at 9:30 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/ , acqueline M. Verney, 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
ik
KAREN ANNE HOSTETLER,
Plaintiff
V.
BRIAN HOSTETLER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2004-5550 CIVIL TERM
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
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AND NOW, this / Y' day of <Z,, 2011, upon
consideration of the attached Custody Concilia iof n R port, it is ordered and directed as
follows: mr
I . The prior Orders of Court dated December 6, 2004 and January 19, 2005
shall remain in full force and effect with the following modifications.
2. Mother shall have periods of partial physical custody on July 9, 2011 from
1:00 p.m. to 6:00 p.m. and one Saturday per month at the same time provided she give
Father reasonable notice of said day and time.
3. Father shall provide counsel for Mother with a copy of the child's IEP and
medications as soon as practicable.
4. Counsel for Mother shall attempt to obtain Mother's
psychiatric/psychological evaluations.
5â This Order was entered pursuant to an agreement of the parties at a
Custody Conciliation Conference. The parties may modify the provisions of this Order
by mutual consent. In the absence of mutual consent, the terms of this Order shall
control. Another Conciliation Conference is scheduled for July 26, 2011 at 8:30 a.m. on
the fourth floor of the Cumberland County Court House.
BY THF?'COURT,
c Patrick Boyle, certified legal intern,
Robert Rains, Esquire Family Law C
Brian Hostetler, pro se
165 Lee Ann Court
KevX A. Hess,
for Mother ⢠? J
CoP1es M i?
q /Agh
P.J.
Enola, PA 17025
KAREN ANNE HOSTETLER,
Plaintiff
V.
BRIAN HOSTETLER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:2004-5550 CIVIL TERM
: CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: Kevin A. Hess, P.J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Brendan Hostetler September 18, 1999 Father
2. A Conciliation Conference was held in this matter on June 8, 2011.
Mother, Karen Anne Hostetler, was present by telephone, with her counsel, Patrick
Boyle, certified legal intern, Robert Rains, Esquire, Family Law Clinic and Father, Brian
Hostetler, pro se.
3. The Honorable Kevin A. Hess previously entered Orders of Court dated
December 6, 2004 and January 19, 2005 providing for shared legal custody, Father
having primary physical custody with Mother having alternating weekends Saturday and
Sunday from 12:00 p.m. to 4:00 p.m.
4. The parties agreed to an Order in the form attached.
Date 9J!ace i ne M. Verney, Esquire
Custody Conciliator
KAREN ANNE HOSTETLER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2004-5550 CIVIL ACTION - LAW
BRIAN HOSTETLER, ?,
Defendant --
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IN CUSTODY
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ORDER OF COURT z®
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AND NOW, this 21St day of July, 2011, being advised that the parties do not need
a follow-up conciliation conference, the Conciliator hereby relinquishes jurisdiction in
this matter.
FOR THE COURT,
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)a7 qine MV Esquire, Custody onciliator
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