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Home My WebLink About94-02882 " QJ ] j1 I , - I I - I - I , ~""') w t .--.> "" N ~ . -=- ..... 0"> ~ {~ <:t. i. t - ~ =-= <T $ 1 "U ~ IT> 0:) e .0 .... 0 - . -.:) ~ ? . ~ I.t) 1.It ... ~ ,'r.) t..; - ~ I.A :t' J =~ :J- ~ ~ 1&.< 0.... Z [1)< <> .Jl ~ ~ W..:I ..:1>< ll.[I) Z ZZ ow ~ll. ..... ..., ~ ~~~~~ o ':3: '<I' p::.... P::= u><< 0\ W Wn! E-<..:I 0\ 0..... 0'0 0 ~f~c I&.Z .... z'" z= Eo< Zj_ <= tIl . .... 0::>1 <41 ..,. - ..:I..... l:l '" 0 ..:I.... E-<UZ ..:I ::<:n! ::<:41 U P:: 0 .... u.... uo >< ::>0.... > <ll. . < 0 aZE-< .... 0 > 0 0 u<u U ::<: ::<: E-< ..:1< ..:I Ul WP:: E-< ::> ::<:W..:I >< E-< U E-<1Il.... P:: 0 ~> W U Z z::>.... 0 ::<: [I) .... .lll.l'li~1 .7 .'i;'(!fj(/~I .. . JUN - 2 100.4 ~ ~ CHERYL HOACHLANDER, Plaintiff IN THE COURT OF COMMON PLEAS OF v. CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No3tf...;J.8'B'JcIVIL ~ SCOTT HOACHLANDER, Defendant 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 S".::t,nlAr J L. Al1c(r-$.':s.:., the conciliator, at Lern {1{>on the I ~ t~ day of ::Fl.! 1'-1 ~ , , 1994, .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 and narrow the issues to be heard by the court, and to enter into a temporary [hE:;.:/ order. All children age five or older ~ also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. By the Court, ,A.,>LfdA A-nlM(~. r '~rJ 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. COURT ADMINISTRATOR, 4th FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 240-6200 JUN 3 2 57 I'M '9~ . ; ,l,t J. ~.~ft'. r~,f,'( r I, .',: y . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHERYL HOACHLANDER, Plaintiff No. civil v. . . . . SCOTT HOACHLANDER, Defendant IN CUSTODY NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the following pages, you must take prompt action. You are warned that, if you fail to do so, the case may proceed without you. You may lose money or property or other rights important to you, including custody or visitation of your children. 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. Court Administrator Cumberland County Courthouse 4th Floor 1 Courthouse Square Carlisle, Pennsylvania 17013 (717)240-6200 CHERYL HOACHLANDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. CIVIL 1994 SCOTT HOACHLANDER Defendant COMPLAINT FOR CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Cheryl Hoachlander, residing at 114 South Arch Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is Scott Hoach1ander, residing with his Paramour, Joyce Erickson, at an unknown location somewhere in Newville Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following children: Name Present Residence Age 10 Justin Hoachlander D.O.B. 6/26/84 with father at paramour residence Jordan Hoachlander D.O.B. 5/15/87 with father at paramour residence 07 The children were not born out of wedlock. The children are presently in the custody of the Father who resides with his paramour in the Newville area. During the children's lifetime, they have resided with the following persons and at the following addresses: Name Address Date Father, Paramour unknow Danny Erickson and Donna Erickson, paramour's children May 1994 - present Father 2124 Newville Road April 1994 - May 1994 Carlisle, PA 17013 Father and Mother 2124 Newville Road Carlisle, PA 17013 February 1994 to April 1989 The Mother/Plaintiff of the children is Cheryl Hoachlander, currently residing at 114 South Arch street, Mechanicsburg, Pennsylvania. She is married to the Defendant The Father/Defendant of the children is Scott Hoachlander, currently residing with his paramour in the Newville area. He is married to the Plaintiff 4. The relationship of Plaintiff to the children is that of Mother. 5. The relationship of Defendant to the children is that of Father. The Defendant currently resides with the following persons: Name Relationship Joyce Erickson Danny Erickson Donna Erickson Justin Hoachlander Jordan Hoachlander Paramour none none son son 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 7. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 8. 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. 9. The best interest and permanent welfare of the children Austin F. Attorney or 24 North 32nd. Camp Hill, PA 717-737-1956 will be served by granting the relief requested because: a. Mother is able to provide the children a home with adequate emotional and physical surroundings as required to meet the children's needs; b. Mother is willing to accept custody of the children; c. Father has physically abused the Mother in front of the children to the point where the Mother has obtained a Protection From Abuse Order directing the Father to refrain from abusing or placing the Mother in fear of abuse for one year; d. Father has unilaterally restricted Mother's contact with and continues to manipulate contact between the children and the Mother. 10. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, the plaintiff requests this Court to grant primary physical custody of the child to the plaintiff with partial custody in the defendant every other weekend from Friday at 6:00 p.m. until Sunday at 6:00 p.m., and any other times that my be mutually agreed upon by the parties. Respectfully submitted, '" ". VERIFICATION I, cheryl Hoachlander, verify that the statements made in the foregoing complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. S?f~(~ t/nX.1LL9- chery~oacnlander Date: