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HomeMy WebLinkAbout06-5220 v, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No, CJ r,.. 5;:12 D CIVIL TERM OLIVIA A. HAIR, Plaintiff JOSEPH M, HOEGEN, Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1, The plaintiff is Olivia A. Hair, residing at 3299 Ritner Highway, Newville, Cumberland County, Pennsylvania 17241, 2, The defendant is Joseph M, Hoegen, residing at 754 Hamilton Street, Carlisle, Cumberland County, Pennsylvania 17013. 3, Plaintiff seeks custody of the following child: Name Morgan H. Hoegen Present Residence 3299 Ritner Highway, Newville Aoe 2 The child was born out of wedlock. The child is presently in the custody of Mother, During the past five years, the child has resided with the following persons and at the following addresses: Person Mother , and maternal grandparents Mother and Father Address As above 166 Breezy Point Rd" McConnellsburg 754 Hamilton St., Carlisle Dates 4/05 - present 12/04 - 4/05 10/03 -11104 The mother is married. The father is unmarried, 4. The plaintiff currently resides with the following persons: Name Relalionshio Zachary B, Hair Stepfather 10 child Morgan H, Hoegen Subject child 5, The defendant currently resides with the following persons: Name Relationshio No one 6, 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, Plaintiff has no information of a cuslody proceeding concerning the child pending in a court of this Commonwealth, 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 wilh respect 10 the child, 7, The best interest and permanent welfare of the child will be served by granting the relief requested because: a) Plaintiff can provide the child with a home with adequate moral, emotional and physical surroundings as required to meet the child's needs; b) Plaintiff is willing to accept custody of the child; c) Plaintiff continues to exercise parental duties and enjoys the love and affection of the child, 8, Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action, All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name NONE Address Basis of Claim Wherefore, plaintiff requests the court to grant custody of the child, . . I verify that to the best of my knowledge and belief, the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS ~904 relating to unsworn falsification to authorities. QJJ'll1'Il,~. tf~ Olivia A. Hair, Plaintiff /"""-.. 0, ~~~ ~'J h: "1 - -=& 0 - ~ ~ o c ;?". ,,-, = r;;;-). C'" f/) c2 I -.J -0 ::;"': o "Tl :T!:n nlr 8 C) . ~~~ ~ ~5rn ::;,.-1 ~5 -< N f'.,' -' OLIVIA A. HAIR PLA !NTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-5220 CIVIL ACTION LAW JOSEPH M. HOEGEN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, September 13, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th_f!oor,c::umberla,!d CouD!L Courthouse, Carlisle on Thursday, October 12, 2006 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 accomplishcd, to dcfinc and narrow the issues to be heard by the court, and to cnter 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 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 hearine:. FOR THE COURT, By: Isl Hubert X Gilro 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 infonnation about accessible facilities and reasonable accommodations available to disablcd 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 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 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3l66 _ ~ ~_;/- "; ~ r~ ~ "):/0-(; _ h ;2 ~ ~It, '7dD-,? ~P' ~~~ ..p9 1iPB"/? C' :7 !) "'/ ~..,f I '; NOV 1 52006 " OLIVIA A. HAIR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. NO. 06-5220 CIVIL ACTION - LAW JOSEPH M. HOEGEN, Defendant IN CUSTODY ORDER ~ AND NOW, this / V day of November, 2006, the Conciliator being advised that the parties have reached an agreement, Conciliator relinquishes jurisdiction. tJir Hubert X. Gilroy, Esquire Custody Conciliator >- a" <? ..-:::: ," U.l ;~..' 0'-'- i-;- (_2' ;.i: :.L ()~--:~ r." (;. mo: -J 0:: ~~1 t== u_ o N ->- --' N :1C Cl- l...0 :>- o z '-0 = = c--.J ., (.:: ~ ,__.J , r_'; ,-''1 $i =:> (,) tiv OLIVIA A. HAIR, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 06-5220 CIVIL TERM JOSEPH M. HOEGEN, Defendant IN CUSTODY STIPULATION FOR CUSTODY STIPULATION made IhiS)4Yi~ day of January, 2007, between Olivia A. Hair, hereinafter referred to as Mother, a d Joseph M. Hoegen, hereinafter referred to as Father. WHEREAS, the above-named Mother and Father had born to them the following child on the following date: NAME Morgan H. Hoegen BIRTH DATE October 22, 2003 AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the custody of the above-said child and to the partial custody rights of the non- custodial parent: NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and Father hereby stipulate that: 1. The parties shall share legal custody of the child. 2. The Mother shall have primary physical custody of the child. 3. The Father shall have periods of partial custody on his days off beginning at 9:00 A.M. his first day off and ending at 7:00 P,M. on the evening before he returns to work. 4. Father shall provide Mother with a copy of his work schedule each week upon receipt so that the parties can make plans including the child without interfering with the other's periods of custody. Once Father's schedule becomes available more in advance, Father will provide it to Mother accordingly. NOV-03-200B 12:38AM FROM- T-B04 P.003/003 F-438 5. Father shall have one week uninterrupted time with the ohild in the summer with notice to Mother 60 days in advance. 6. Holidays shall proceed as follows: In the even years beginning with 2006, Mother shall have the first half of the Christmas Holiday, from 2:00 on the 24th until 2:00 on the 25th1 New Year's Day, Memorial Day, labor Day and Trick or Treating. In the even years beginning with 2006, Father shall have the second half of the Christmas holiday from 2:00 on the 25th until 2:00 on the 26th, Easter Sunday, July 4th and Thanksgiving. The parties shallswJtch the holidays in the odd years. 7. Mother shall have the child on Mother's Day and Father shall have the child on Father's Day. 8. The child will celebrate her birthday on October 22 with whichever parent has her in the regular custody schedule. A second celebration may take place with the other parent on another day during the regular schedule. 9. Neither party shall be intoxicated while enjoying custody of the child. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court. Witness: ('2 ,-\. \" ~.. .\.-i it ("'4)([, /C)Lr.! ,{' . .~ Lind ay D.. BaiJd. esquire DJ)imL~ . ~ Olivia A. Hair, Mother ~ --?_-- ---::::lo~"prrM. Hoegen, Father - - ------... " . .... OLIVIA A. HAIR, Plaintiff v. JOSEPH M. HOEGEN, Defendant ~AN 2 5 200~ /Ji J : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 06-5220 CIVIL TERM : IN CUSTODY ORDER OF COURT AND NOW, this iJ<. f'I' day of ~, 2007, upon consideration of the attached custody stipulation with respect to the parties' child, Morgan H. Hoegen, born October 22, 2003, the terms of the stipulation are entered as an order of court. ky Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 Zttor y for Mother r. Joseph M. Hoegen 754 Hamilton Street Carlisle, PA 17013 Father J. 9 I :2 l~ld 92 ~j\jr LOOl Ai:J\r1Ci\CH..L~'t:d 3Hl :10 38H::l\}{Bll:l