The URL can be used to link to this page

Home My WebLink About06-2271 SARAH R. ROUNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYL VANIA vs, NO. 06- ,J,J, 11 CIVIL TERM BRANDON A. HETRICK Defendant CUSTODY COMPLAINT FOR CUSTODY I. Plaintiff is Sarah R. Rouner, hereinafter referred to as Mother. Mother resides at 180 Old State Road, Gardners, Cumberland County, Pennsylvania 17324. 2. Defendant is Brandon A. Hetrick, hereinafter referred to Father. Father resides at 115 Chapel Avenue, Carlisle, Cumberland County, Pennsylvania 17013, 3. Mother seeks primary physical custody of the minor child: Name Present Residence Samarah Kay Louise Hetrick 180 Old State Road Gardners, P A 17324 Age 12/2/04 DOB; I year old Samarah was born out of wedlock 4, Samarah is in Mother's custody, During her lifetime, Samarah has resided with the following persons and at the following addresses: Name Address Date Sarah Rouner Brandon Hetrick Deborah Rouner David Rouner David Rouner, Jr. Daniel Lee Rouner Kevin Rouner Ellen Zink Austin Snyder-Rouner 180 Old State Road Gardners, P A birth - 3/05 - Sarah Rouner Deborah Rouner David Rouner David Rouner, Jr. Daniel Lee Rouner Kevin Rouner Ellen Zink Austin Snyder-Rouner 180 Old State Road Gardners, P A 180 Old State Road Gardners, P A Sarah Rouner Brandon Hetrick Deborah Rouner David Rouner David Rouner, Jr. Daniel Lee Rouner Kevin Rouner Ellen Zink Austin Snyder-Rouner 180 Old State Road Gardners, PA Sarah Rouner Deborah Rouner David Rouner David Rouner, Jr. Daniel Lee Rouner Kevin Rouner Ellen Zink Austin Snyder-Rouner 5. Mother currently resides with the following persons: Name Deborah Rouner David Rouner David Rouner, Jr. Daniel Rouner Austin Snyder-Rouner Kevin Rouner Ellen Zink 6. It is believed that Father lives with the following persons: 3/05 - 6/05 6/05 - 2/23/06 2/23/06 - present Relationship Mother Father Brother Brother Nephew Brother Kevin Rouner's Girlfriend -- Name Melissa (Jumper) Hetrick Five (5) children Relationship Wife Melissa's Children 7. Mother has not participated as a party or witness, or in another capacity, in other custody litigation concerning the custody of Samarah in this or another court. 8. Mother has no information of a custody proceeding concerning Samarah pending in a court of this Commonwealth. 9. Mother does not know of a person not a party to the proceedings who has physical custody of Samarah or claims to have custody or visitation rights with respect to Samarah. 10. The best interest and permanent welfare of Samarah will be served by granting the relief requested for reasons including, but not limited to the following: a. Mother is presently able to provide for Samarah by giving her a nurturing and stable home environment and providing for her emotional, physical, medical and educational needs and she has done so since Samarah was born. b, Mother lives with her immediate family and all members are willing and able to provide child care, emotional support, and ongoing assistance to Mother and Samarah. c. Since Samarah was born, Mother has been the parent responsible for his daily needs and has done so with minimal, if any, assistance from Father. d. As a result of Father's minimal involvement in Samarah's first year, there is no established father/daughter relationship and forcing Samarah to spend extensive - amounts of time with Father without providing time to develop that relationship would not be in her best interests. e. Mother is the parent who is most inclined to work with the non-custodial parent to develop and parent/child relationship and ensure that Father is able to see Samarah on a regular basis. II. Father has not acted in Samarah's best interests in ways including but not limited to the following: a. On two occasions after Samarah was born, Father left the residence he shared with Mother. The first occasion was when Samarah was three (3) months old and Father was gone for three (3) months. During that three month period, Father did not try to see Samarah and called Mother only to discuss issues pertaining to their relationship, not issues pertaining to Samarah. b. Father returned to live with Mother and Samarah when Samarah was six (6) months old and he stayed in the home until February 23,2006. During that time, Father did not assist Mother in daily parenting duties and frequently expressed resentment that Mother insisted on bringing Samarah out with them rather than leave her in the care of the maternal grandmother or other child-care provider. c. Father left a second time on February 23, 2006. Since that time, he has called generally to discuss issues pertaining to his relationship with Mother and has made minimal inquiry into Samarah's development or life. d. Father has an extensive history of drug use and has also been involved in the sale of drugs. Mother fears that Father's drug problems will interfere ,.I with his ability to provide for Samarah's needs for any long-term period of time. e. Father recently married a woman and moved into her home that she shares with her five children. Additionally, Mother is aware of other people who stay at the home for extended periods of time. The home has only three (3) bedrooms and Mother is concerned that Samarah would not have appropriate sleeping arrangements to spend overnight time with Father. f. Mother has additional concerns about Father's ability to provide appropriate care and supervision for Samarah because of telephone calls she has received from Father's wife regarding their excessive use of drugs and alcohol in the home. 12. Every person with rights to custody or having actual physical custody of Samarah has been named as parties to this action. WHEREFORE, Mother requests this Court to grant her the following relief: 1. That the parties shall share legal custody of Samarah. 2. That Mother shall have primary physical custody of Samarah. 3. That Father shall have periods of supervised visitation. 4. That the non-custodial parent shall have reasonable telephone contact with Samarah while she is with the other parent. 5. That the parties shall have an appropriate holiday schedule so that both parents can spend time with Samarah. -' 6. Any other relief this Court finds just and equitable. Jes . c Is , Esquire M' Penn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 ./' VERIFICATION The above-named PLAINTIFF, Sarah R. Rouner, 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. 94904, relating to unsworn falsification to authorities. ~o -Ht Date: ~{, / 'J 2itJp Sarah R. Rouner SARAH R. ROUNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06- CIVIL TERM BRANDON A. HETRICK Defendant CUSTODY AFFIDA VII OF SERVICE BY MAIL I, Jessica Holst, do hereby swear that I served Brandon A. Hetrick with a Complaint For Custody on;;'; 0,,/, I , 2006 by certified mail, return receipt, restricted delivery, to the person and address below: Brandon A. Hetrick I 15 Chapel Avenue Carlisle, PA 17013 I, Jessica Holst, 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: /}<I !2.:tJr;! d().)~ Signatur I SARAH R. ROUNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06- a;) 7{ CIVIL TERM BRANDON A. HETRICK Defendant CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Sarah R. Rouner, Plaintiff, to proceed in forma pauperis. I, Jessica Holst, 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 Ie al services to the party. Je s' a olst, Esquire idPenn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 . - SARAH R. ROUNER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 06-2271 CIVIL ACTION LAW BRANDON A. HETRICK DEfENDANT IN CUSTODY ORDER OF COURT AND NOW, _._\-Vednesd'!}',.J\1-"L 03, 20(jii._.._____, upon consideration of Ihe attached Complaint. it is hereby directcd that parties and their respective counsel appear before Jacqneline M. Verney, Esq. . the conciliator, at___.._._. 4tl1.F'loor,<::~Illb~r1an_<!.<::~.unty Courthouse, Carlisle on ____ Tuesday, May 30, 2006 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 detine 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 present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or penn anent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to tbe conciliator 48 hours prior to scheduled hearine. FOR THE COURT. By: fsf Tacqueline 1l1..Vemev. Esq. Custody Conciliator Ii'') The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infonnation aboul accessible facilities and reasonable accommodations available to disabled individuals having business bef()re the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business bef("e the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE_ IF YOU DO NOT HA VE 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 Soutb Bedford Street Carlisle, Pennsylvania 170 \3 Telephone (7 I 7) 249-3166 . .~. ' (' 7>"77 (!",.~, /14- 7?,?V;Y(I' ~QJ;7 P" ~71 ~- . . 7 . - .~7 2 "1r~ ?~~lI, '" ~s . 7 'W .z /tfl~1 1-4J f 7?J .-1 ,.: '" .,', , "7<J /". <' r '7<J f" ;- ,7JcJ [)7 . 1-'" -,,"..~ ..'-~ r~ "'. '..7. "-.~ .;.:-. -...' '~J'-~_/,. ~' ~:-~.~ ~ l - -\ t .:: L\ SARAH R. ROUNER, Plaintiff i MAY 3 I 2006 Ipy, ~ ~....:.;.;.,--~.:':::::::~-.-- -." IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL VANIA V. NO. 2006-2271 CIVIL ACTION - LAW BRANDON A. HETRICK, Defendant IN CUSTODY ORDER OF COURT AND NOW, this '2"'" day of C\~ ,2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Sarah R. Rouner, and the Father, Brandon A. Hetrick, shall have shared legal custody of the Samarah Kay Louise Hetrick, born December 2,2004. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. 2. Mother shall have primary physical custody of the child. 3. F ather shall have periods of supervised visitation as agreed by the parties. 4. This Order is 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. BY THE COURT, cc:..J6sica Holst, Esquire, Mid Penn Legal S rvices - Counsel for Father JM"andon A. Hetrick, pro se 180 Old State Road ~ . Gardners, P A 17324 ,4d., J. 0\0 ~ 0\9 ~z :b ~~~ z- Hnf q~Ul \' 1\.1\(" I"~ " '" 1 ::Illl ..10 f\b'i_~!i\jUr'U.LjCl -,l"'U- ::l 38\:bO-G:f\\j