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Home My WebLink About94-05695 ~, ~' ~. :::t. ~ J j Jr ,; . ,. ~ i ji J :\ lC) a- eX 'JAN 3 100C:;J"/L , j,Jvv --, GEORGE E. HACJCENBERGER, Plaintiff v I IN THE COURT OF COMMON PLEAS 01' ICUMBERLAND COUNTY, PENNSYLVANIA I INO. 5695 - CIVIL - 1994 I I :CIVIL ACTION - CUSTODY CHRI STINA L. HACJCENBERGER, Defendant COURT ORDER AND NOW, this IJJday of A ~ , 1995, the Conciliator being advised that the par~s hava reached an agreement in the above case, the Conciliator relinquishes jurisdiction. {/)/5fg; Hubert X. G~lro , Esqu~re Custody Concil ator VERIFICATION I verify that tile ltatementa D18de In tile foreaolni Compl8int few CWltody lU'lI &rue and correct. I underatand &hat faIIe statements herein lII'e made subject to &he penalUn or 18 Pa. C.S. Sec:tlon 4904 relatlna to unawom falslllcation to authoritln. /fl M- Y' Date . ~#iL--ar- G Ir.enberger t7 GEORGE E. HACKENBERGER, Pl8lntifF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 94-G696 CIVIL TERM :i ,j v. :i I CHRI8TINA L. HACKENBERGER, :! Defendant !i I : IN CUSTODY Ii COMPLAINT FOR CUSTODY :1 : i 1. Pl8lntifF is George E. Hackenberger, an adult individual whoee residence is at 124 II Petenbura Road, CarUsle, Cumberland COWlty, Pennsylvania. Ii 'I 2. Defendant is Christina L. Hackenberger, an adult individual, whoee Iaat known residence Ii ,j was at PIIr.e Motel, 1121 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania. Plaintiff believes ii I ii that Defendant may be residing at either 1139 Rana Villa Avenue, Camp HiJI, Cumberland CoWlty, Ii Pennsylvania, or BOO Old York Road, Dover, York County, Pennsylvania. I, Ii " s. PlalntiJT seeks custody of his children, George E. Hackenberger, born July 14, 1989, and i Catherine L. Hackenberger, born July 23, 1994, currently residing with thei!' father. i! Ii The children are presently in the custody of the PlaintiJT. 4. 5. Since the children's birth, the children have resided with the foUowina over the peat five years: " H!lU Address ~ I; , !i George Hackenberger 124 Petenburg Road 07125/96 . Pre.It , Carliale, PA 17013 George Hackenberger Pike Motel 07/04196.01/2M1l Christina Hackenberger 1121 Harrisburg Pike Carliale, PA 17013 I George Hackenberger Harvon Motel 06,127196 . 01.104JIl6 Christina Hackenberger 861 N. Hanover Street Carliale, P A 17013 George Hackenberger Keystone Inn 04/10195 . 00/27/96 Christina Hackenberger 353 Lewiaberry Road New Cumberland, PA 17070 HImt Addreu 12m Georp HackenlMrpr 90 Sprlnaen Lane l1J2N94 . 04/10/915 ChriItIna Hackenberpr Lot 13R New Cumberland, PA 17070 George Hacltenberger Knlghta Inn 10/94 . 11194 ! Chriatina Hackenberger 1.83 " LimekUn Hoed New Cumberland, PA 17070 Chriatina Hackenberger 1139 Rana VIlla Hoed 09/94 . 10/94 Deen Cody Camp Hill, PA 17011 Chriatina Hackenberpr 66 Regency Woods 08/94 . 09/94 CarUsle, P A 17013 George Hackenberger 66 Regency Woods 07/89 . 08/94 Christina Hackenberger CarUsle, PA 17013 6. The natural mother of the child is Chriatina Hackenberger, whoee current residence is unknown. 7. The natural father of the child is George L. Hackenberger, currently residing at the above-lItated address. 8. The relationship of the Plaintiff to the child is that of natural father. 9. The relationship of the Defendant to the child is that of natural mother. 10. The Plaintiff has not participated as a party or in any other capacity, in other litigation concerning the C'Wltody of the child in this or any other court. 11. Plaintiff has no information of a C'Wltody proceeding concerning the child pending in a court of this Commonwealth. 12. The best interests and permanent welfare of the child will be served by grantinjr the reIlef' requested because the Plaintiff is the primary care giver with respect to the child. 13. Each parent whose parental rights to the child have not been terminated and the perlIOIl' who has physical C'Wltody of the child have been named as parties to this action. No other penona III'lI '" known to have or claim to have any right to C'Wltody or visitation of the child other than the partielI to this ection. 'I Ii " I' , VERIFICATION I verify that the ltatemente made In the Coreaolng Complaint are true and correct. I underatand that Calle ltatemente herein made are IUbject to the penalties oC 18 Pa.C.S.A. '4904 relating to IIIIIwom II CaIIiI1cation to authorltiel. I I .3lJL~ ;)'7. 1?9) . Date JJ:li [. ~~ George . Hackenberger ~ :-.;-- ~ "'-- ,- 1<-: N I.... C.") ~.o v...J ~ "'~ -, SEP 1 II ozAH '95 ;rrll;f. f,F .' t-.j;1'I"""1f,'1' :~. "<: I..j', '", " "i rY ,,- 'I' i ' , .. l ~ I . - v IIN THE COURT OF COMMON PLBAS OF ICUMBERLAND COUNTY, PENNSYLVANIA I INO. 5695 - CIVIL - 1994 I I ;CIVLL ACTION - CUSTODY GEORGE E. HAClCBNBERGER, Plaintiff CHRISTINA L. HACKENBERGER, De fendallt CONCILIATION CONJ'ERENCE SU)MARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent inlormation pertaining to the children who are the subject of this litigation is as lollows: George E. Hackenberger, born July 14, 1989, and Catherine L. Hackenberger, born July 23, 1994. 2. A Conciliation Conference was held on September 1, 1995, with the following individuals in attendance: Robert J, Mulderig, Esquire, counsel for the Father, George E. Hackenberger, 3. The Mother, Christina L, Hackenberger, was not served with notice of the Hearing. However, Attorney Mulderig demonstrated to the Conciliator that he mailed four letters to the Mother, two of which were by certified mail, and three of the letters have been returned as unclaimed. Attorney Mulderig even used different addresses in an attempt to serve the Defendant Mother. Additionally, Attorney Hulderig prese~ted to the Conciliator a note whereby the Mother acknowledged that she was leaving the marital home and leaving the two minor children in the custody of the Father. 4. Based upon the foregoing, the Conciliator recommends an Order in the form as attached. ql.cl q.s- DATE Hubert x. Gilroy, Esqu~ e Custody Conciliator '. Complaint are ine;orporated here by reference. 6. Mother alleges that she and the children fear bodily injury from Father, for the reasons slaled her Petition and Complaint. 7. Fearing for the safety of the children, on October 31, 1998, the mother and the children leftlhe marital residence and have established a new and separale residence. 8. On November 3, 1998, while Mother was seeking to enrollhe children in school in the dislrict of their new and current residence, Father went to the school seeking to obtain custody of the children. 9. On November 4, 1998, in an effort to resolve the current situation, mother contacted the father, who indicated to mother that he was not interested in resolving the dispute, even on a temporary basis pending a court decision, and that he would fight mother for custr.>dy of the children. 10. Father followed Mother when she went to her attorneys' office on November 4, 1998. 11. The children are afraid of Father. They feel safer and happier now that they and Mother ha ve moved to a separate residence. 12. Mother will cooperate with Father in ensuring that he has reasonable and continuing contact with lhe children. pending the outcome of the lhis case. 13. Granting Mother the requested relief will promole the children's best interest, including living in a healthy. safe and stable environment, and will preserve the status quo pending a final resolution of lhe case. WHEREFORE, Petitioner asks that the Court grant the mother temporary physical custody of the children pending a custody hearing. fl14~~~~ Mallhew J. Kloibtr Cenitied Legal Intern ~~ ROBERT E. RAINS Supervising Attorney DONALD MARRITZ Staff AlIorney FAMILY LAW CLINIC 45 N. Pitt. 51. Carlisle, PA 17013 717243-2968 VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. C.)1;i"\:L",n t~~CXJJ'I\~\.V\ Christina L. Hackenberger Date: November 6, 1998 v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ~ NO. 5695 CIVIL 19911 : CIVIL ACTION - CUSTODY GEORGE E. HACKENBERGER, Plaintiff/Petitioner CHRISTINA L. HAC KEN BERGER, CefendanURespondent ORDER OF COURT AND NOW, this {'7 -f< day of November, 1998, upon consideration of the attached Petition for Special Relief, a hearing is scheduled for the /1a day of November, 1998 at [1: 3tJ o'clock CL.m in Courtroom No. 1 at the Cumberland County Courthouse in Cartisle, Pennsylvania. BY THE COURT, \,!', :.~:.?'::'.J ) If r ,,01,\ '. (' 1-";"'""') ......'.' . . ~ '. .j " I' c 1:'1 :" l';-t"J,.t f.'5" ~ '. ~. I I ... }.':;.':~: '.' '~JJ j~:J',-;',~,,: .~ (i) ... . ;:, ....... .. ....... ~ ~ '1 4 f Ii 'I GEORGE E. HACKENBERGER, I Plaintiff/Petitioner v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 'I : NO. 5695 CIVIL 199~ CHRISTINA L. HACK BERGER, : CIVIL ACTION. CUS70 DefendanURespo ent : ORDER OF COURY AND NOW, this t, tt ~y of November 1998, upon consideration of the attached Petition for Special Relier,it is here directed that the parties and their respective counsel appear before , the conciliator, at on the day of November, 1998, at M, for a Pre-Hea . g stody Conference. At such Conference, an effort will be made to resolve the islu'es in dl eute; or if this cannot be accomplished, to define and narrow the issues to e heard by th~ Court, and to enter into a temporary order. Failure to appear at Conference m~, provide grounds for entry of a temporary or permanent orde. Pending such hearin~ the Respondent is ordered to return the children to their ome and father's custody i'r\, accordance with the Order \ dated September 7, 1995. ather's counsel is directed to deliver a copy of this Order to the Cumberland County Sheriff for service upon mother at h\r place of employment, " Reeves Hoffman, Carlisle, Pennsylvania. \ FOR THE COURT, e"'" f By: l ~ u/:,/. Custody Conciliator 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, 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. II il 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-31e6 v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 5695 CIVIL 1995 : CIVIL ACTION. CUSTODY GEORGE E. HACKENBERGER, Plaintiff/Petitioner CHRISTINA L. HACKENBERGER, Defendant/Respondent PETITION FOR SPECIAL. RELIEF AND NOW, comes the Petitioner, George E. Hackenberger, by and through his attorney, Robert J. Mulderig, Esquire and moves the Court for a Special Relief in the above captioned case and states: 1. Petitioner is George E. Hackenberger, an adult individual residing at 315 Pinedale Road, Carlisle, Pennsylvania 17013. 2. Respondent is Christina L. Hackenberger, an adult individual who resided at 315 Pinedale Road, Carlisle, Pennsylvania 17013 until October 31, 1998. Her current address is unknown. 3. The parties are the natural parents of George E. Hackenberger, born July 14,1989 and Catherine L. Hackenberger, born July 23,1994. 4. On September 7, 1995, this Honorable Court through Judge J. Wesley Oler, Jr. entered a Custody Order granting Petitioner primary physical custody of the minor children. A copy of said Order is attached hereto and incorporated herein aa Exhibit "N. 5. Subsequent to the entry of this Order the Respondent moved back in with the Petitioner. 6. On or about October 31, 1998 without any warning to the Petitioner, Respondent removed the said children from their residence and their school and moved to an address unknown. 7. Petitioner has seen Respondent subsequent to her moving out of the home and requested the location of his children. Petitioner does know that Respondent works at Reeves Hoffman, Cherry and Louther Streets, Carlisle, Pennsylvania and knows that she is still in the area. I I! q ;1 I II 8. Respondent has refused to tell Petitioner where his children ere located. WHEREFORE, the Petitioner respectfully requests this Honorable Court to enter an Order scheduling a hearing In contempt before the Custody Conciliator and pending such hearing, order that the children be returned to their home and school. Respectfully Submitted TURO LAW OFFICES Ipr Date 41i1L~".. 32 South Bedford Street Carlisle, PA 17013 (717) 245-9688 Attorney for Petitioner - ..:\' - (.. t'-';: , , . ~') U.11 ~ , t:' J \ ~~ . I C~)': , ;-) , I CJ, I I , ." W I TJ .' , :-.. L. c ., :l.. ::..- . " I":'.: , (,) c; () ,J C, .:.J >: t"'!. ~;:~" 1'1' S2; ~..~ ' I,j ~ (.J~ 6 w C\ I.' . l!... Co :'1 C) ~ c) _. CJ 0' j';j 1:.)[1_ :~ (.) GEORGE E. HAC1(ENBERGER, Plaint1rt IN THE COURT or COMMON PLEAS 0' CUMBERLAND COUM'l'Y, PENNSYLVANIA v. : CIVIL ACTION.LAW IN CUSTODY CHRISTINA L, HACl(IHBERGER, Defendant . , : NO. 94-5695 CIVIL TERM ACCBPTAHCB O. .KRVXCB 1 accept service at the attached Petition to Vaaato Friar cuatody Order and Complaint tor CUstody, I certify that I .. authorized to accept service on behalf of Mr. George E. Hacken1:lerger. Date /1-111 Aqent 32 South Bedford Street carlisla, PA 17013 Ii GEORGE B, flACICENBERGER, Plaintiff . . IN THl!: COURT OF COMMON PLEAS or ClIKBDLA.NtI COUlf'l'Y, PENNSYLVANIA CIVIL ACTION-LAW IN CUSTODY . . v. s ; s : s NO. 9'-5695 CIVIL TERM CHRISTINA L. HACltENBDGD, cefendant . . I.cc_nuc. O. ...vle_ I accept .arvica of tha attached Patition f~r Spaoial Ralief. I cartify that I am authorized to acoept .arvioa on behalf of Mr. Georqa E, Hackenberqer. Date /l4-C;l ~ ..~ \ V, . l ' ' II 'f' / a n~ft!t (r L or ad Agen1; 32 South Bedford Stre.t Carliale, PA 17013 .,... C' ~~ ..;;l > l' " . ,- I" , <' -, L L~ ,; ~ " V' '-) ~'. c) f:: en ;:- .,. -'. r I. -~ ~,,-') M .. ~) ~ " ~., : .r:-: . .. ( ~. . ... ',':) " I I .' C , .. , - l.. I. 0: , ( , v' U 'I . . GEORGE E. HACKENBERGER, Plaintiff : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY CHRISTINA L. HACKENBERGER, Defendant : NO. 94-5695 CIVIL TERM ORDER OF COURT AND NOW, this '3 day of November, 1998, upon consideration of the allached complaint, it is hereby directed that the parties and their respective counsel appear before, \\...X.rr\ 't . G"'~ (\~., ' the conciliator, at 1-< 51"' fkcr \-''c'nn'''j Ru-c\of the Cumberland County Courthouse, Carlisle, Pa. on the LS' day of ...J-r-.....:fl ~ , 19~, at 8', 20 o'clock .Q.... 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 B temporary order. Either party may bring the child(ren) who is the subject of Ihis custody action to the conference, but the child/children's allendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By: _F-\\\lJe^-J.. (X .vlU1M l C#\.- Custody Conciliator 'U (.JS:) 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 2 Liberty A venue Carlisle, PA 17013 (717) 249-3166 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, please contact our oflice. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must allend the scheduled conference or hearing. 'I original process and did not have notice or an opportunity to be heard. 8. As explained in more detail helow, the Court should enter a new custody order, granting Mother primary physical custody of the children, because such an order would be in the children's best interests. PETITION TO VACATE 9. The prior allegations of this Petition are incorporated here by reference. 10. The Court did not have jurisdiction to enter the Order of September 7, 1995. 11. The Father's Complaint, which was filed on July 27, 1995, and on which the Order was based, was never served on Mother. 12. Father did not give Mother notice and she did not otherwise know of the existence of the Complaint nor of the conciliation conference. 13. Father knew where Mother was working at all relevant times, but he did not allempt to serve her there or at any other viable location. 14. At the time of the September I, 1995 conciliation conference, the parties were living together. IS. At the time the Order of September 7, 1995, was entered, the parties were living together. 16. Father did not inform Mother of the fact that this Court entered an Order on September 7, 1995. WHEREFORE, Mother prays that the Court vacate its Order of September 7, 1995. COMPLAINT FOR CUSTODY 17. The prior allegations of this pleading are incorporated here by reference. 18. The children are curremly residing with their Mother at the address listed above. 19. The mother is seeking physical custody of the children. 20. The children have resided with the following people over the past five years: a) Christina Hackenhl:rger Dennis Lilly 20 Bellmore Road 10/31/98. Presem Camp Hill, PA 17011 315 Pinedale Road 7/97 - 10/]0/98 Carlisle, PA 17013 b) Christina Hackenberger George Hackenberger c) Christina Hackenhl:rger George Hackenberger 56 Belly Nelson Court Mid 8/95 - 7/97 Lotll Carlisle. PA 17013 d) George Hackenberger 124 Petersburg Road 7/25195. Mid 8/95 Carlisle. PA 1701l e) Christina Hackenberger Pike Motel 7/4/95 - 7/25195 George Hackenberger 1121 Harrisburg Pike Carlisle. PA 17013 f) Christina Hackenberger Harvon Motel 6/27/95 - 7/4195 George Hackenberger 851 N. Hanover Street Carlish:. PA 17013 g) Christina Hackenberger Keystone Inn 4/10/95 . 6/27/95 George Hackenberger ]5] Lewisbercy Road New Cumberland. PA 17070 h) Christina Hackenberger 90 Springers Lane I 1/25/94 - 4/10/95 George Hackenberger Lot IlR New Cumhl:rland, PA 17070 i) Christina UOIckenberger Knights Inn 10/94 - 11/94 George Hackenberger 1-83 & Limekiln Road New Cumberland, PA 17070 j) Christina Hackenberger 1139 Rana Villa Road 9/94 . 10/94 Dan Koti Camp Hill, PA 17011 k) Christina Hackenberger 845 Bosler A venue 9/94 Ella Steward Lemoyne. PA 17043 (Ii)r about ore week) I) Christina Hackenberger 66 Regency Woods 8/94 - 9/94 m) Christina Hackenberger 66 Regency WOOIls 7/89 - 8/94 George Hackenberger Carlisle, PA 17013 21. Mother and Father have been panies in other litigation concerning custody of the children. which action is still pending. to wit: a) On July 16, 1993, Mother filed a Divorce/Custody complaint in this Coun at Civil No. 93-2295. which was served on Father on July 17, 1993. b) A custody conciliation conference was scheduled for January 5, 1995. in Mother's. Civil No. 93-2295. but was canceled on October 27. 1994, due to the reconciliation of the panies. The case was pending at the time Father filed the complaint in the instant action. 22. Plaintiff does not Imow of any other pending actions concerning custody, other than the case at bar and the case in this Court described immediately above. Civil No. 93-2295. 23. Plaintiff does not know of a person not a pany to the proceedings who claims to have custody or visitation rights with respect to the children. 24. The beSl interest and permanent welfare of the children will bc scrved by granting the relief requested because: a) The Father has engaged in a course of conduct which has caused the Mother and the children to have a reasonable fear of bodily injury. i) Father has abused Mother. as alleged in her October 19, 199]. Petition for Temporary Protective Order and Suppon. and her Petition to Extend Protection from Abuse Order in Civil No. 93-3328 in this Coun, which Petitions are incorporated here by reference. ii) Since at least the beginning of the school year, the father has physically VERIFICATION Underslanding thatlhe making uf any false statement would subjecI her to the penalties of 18 Pa. C.S. ~ 4904 relating 10 unsworn falsification to authorities, the undersigned states that the facts sel forth in the above ph:ading are lrue and correct, to the best of her knowledge, information, and belief. ~~:tN('), ::t. ~.\c'C~~" Christina L. Hackenberger Date: November~, 1998 ,.. c. c " ,IN 'lHE COURT OF COHHON PLBAS OF ,CUMBERIAND COUN'l'Y, PENNSYLVANIA , INO. 5695 - CIVIL - 1994 , : ,CIVIL ACTION - CUSTODY GEORGE 8. HAC1CENBERGER, PlaintiU CHRISTINA L. HACKENBERGER, Defendant CONCILIATION COl7i'l:RENCE SUHHARl" RCPORT IN ACCORDANCE fiITH CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is aB follows: George E. Hackenberger, born July 14, 1989, and Catherine L. Hackenberger, born July 23, 1994. 2. A Conciliation Conference waB held on September 1, 1995, with the following individuals in attendance: Robert J. Hulderig, Esquire, counsel for the Pather, George E. Hackenberger. 3, The Mother, Christina L. Hackenberger, was not served ",ith notice of the Hearing. However, Attorney Mulderig demonstrated to the Conciliator that he mailed four letters to the Mother, two of which were by certified mail, and three of the letters have been returned as unclaimed. Attorney Mulderig even uBed different addresses in an attempt to Berve the Defendant Mother. Additionally, Attorney Hulderig presented to the Conciliator a note whereby the Mother acknowledged that she was leaving the marital home IlInd leaving the two minor children in the custody of the Father. 4. Based upon the foregoing, the Conciliator recommends an Order in the form as attached. ql.c{qr- DATE Hubert x. Gilroy, Esqui e Custody Conciliator V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN CUSTODY GEORGE E. HACKENBERGER, Plaintiff CHRISTINA L. HACKENBERGER, Defendant NO. 94-.569.5 CIVIL TERM ORDER OF COURT tL AND NOW, this ...JL day of November, 1998, upon consideration of the Illlched Motion for General Continuance, the hearing in this mailer is continued generally. By the Court, GEORGE E. HACKENBERGER. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V AN[A v. CIVIL ACTION-LAW [N CUSTODY CHRISTINA L. HACKENBERGER, Defendant NO. 94-5695 CIVIL TERM MOT[ON FOR GENERAL CONTINUANCE The Defendant, Christina L. Hackenberger, Petitioner herein. by her attorneys, the Family Law Clinic, seeks a general continuance of the November 17, 1998, hearing before Judge Oler. and alleges the following in support: J. On or about November 6, 1998, Christina L. Hackenberger tiled a petition for special relief concerning custody of the parties' children. 2. On or about November 5, 1998, George E. Hackenberger filed a petition for special relief concerning custody of the parties' children. 3. [n response to these petitions, on November 6, 1998, the court scheduled a hearing for November 17, 1998, at 8:]0 A.M. 4. In the ensuing days. Christina L. Hackenbel'ger and George E. Hackenberger have reconciled. 5. Based upon this reconciliation, both Christina and George Hackenberger have indicated their desire to have the November 17, 1998 hearing continued. 6. On November 13. 1998, Christina L. Hackenberger's counsel, the Family Law Clinic, contacted George E. Hackenberger's counsel, Robert J. Mulde:rig, Esquire:, who concurred with Christina Hackenberger's Motion for Ge:neral Continuance. WHEREFORE, Defenant-Movant asks this Court to grant a general continuance in this action. " !L~&~~ Certified Legal Intern Th(l(J ~7/ THOMAS M. P CE ROBERT E. RAINS Supervising Allorney DONALD MARRITZ Staff Allorney FAMILY LAW CLINIC 45 N. Pill. St. Carlisle, PA 17013 71724]-2968 Date: November 16, 1998 .~ " ~1 i ...... J, ~ '" - , 'j ~ ~ GEORGE E, HACKENBERGER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION-LAW IN CUSTODY CHRISTINA L, HACKENBERGER, Defendant NO, 94-5695 CIVIL TERM CERTIFICATE OF SERVICE I, Matthew J. Kloiber, Certified Legal Intern, Family Law Clinic, hereby certify that on November 9th, 1998, I served plaintiff with a true and correct copy of the defendant's Motion for General Continuance, by hand delivering the said document to Plaintiff's Counsel, Robert J. Mulderig, located at the Turo Law Offices, 32 South Bedford Street. Carlisle, PA 17013, as evidenced by the attached acceptance of service. signed by Kristen Ann Day, secretary fC'r Mr. Mulderig. ~;1;.k- Certified Legallntem Dated: November 19, 1998 ~ ,-.., V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN CUSTODY GEORGE E. HACKENBERGER, Plaintiff CHRISTINA L. HACKENBERGER, Defendant NO. 94-5695 CIVIL TERM ACCEPTANCE or SBRVICE I accept service of the attached Motion for General Continuance. I certify that I am authorized to accept service on behalf of Mr. George E. Hackenberger. Date ~ Agent 32 South Bedford Street Carlisle, PA 17013 v, . IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA . NO, 5695 CIVIL 'Hl9& J'/'j)./ : CIVIL ACTION. CUSTODY GEORGE E. HACKENBERGER, Plaintiff/Petitioner CHRISTINA L. HACKENBERGER, DefendanlJRespondent ORD~R OF COU~T. AND NOW, this ~ day of ~ ~. -I. CJ .1999. upon consideration of the attached Petition to Vacate Custody Order, the Custody Order dated September 7,1995 is hereby vacated. BY THE COURT, 11 I I v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA : NO. 5895 CIVIL 1995 : CIVIL ACTION. CUSTODY GEORGE E. HACKENBERGER, Plaintiff/Petitioner CHRISTINA L. HACKENBERGER, DefendanlJRespondent AND NOW, comes the Petitioner, George E, Hackenberger, by and through his attorney, Robert J. Mulderig, Esquire and moves the Court to vacate the Custody Order in the above captioned case and states: 1. Petitioner is George E. Hackenberger, an adult individual residing at 315 Pinedale Road, Carlisle, Pennsylvania 17013. 2. Respondent is Christina L. Hackenberger. an adult individual residing at 315 Pinedale Road, Carlisle, Pennsylvania 17013. 3, The parties are the natural parents of George E. Hackenberger, born July 14,1989 and Catherine L. Hackenbergfilr, born July 23,1994. 4. On September 7, 1995, this Honorable Court through Judge J. Wesley Oler, Jr. entered a Custody Order granting Petitioner primary physical custody of the minor children. A copy of said Order is attad1ed hereto and incorporated herein as Exhibit 'A', 5. The parties have since reconciled. INHEREFORE. the Petitioner respectfully requests this Honorable Court to enter an Order vacating the order of September 7. 1996. Respectfully Submitted TURO LAW OFFICES l;fj/I~y Diiie , i ~ " 9 ,~ ~ ~~ .... r( ~ ...... >- l,() ;.- p- o'" u: . , , ." v' )...~ " : .' - .-,' -.": ) , j "~"" (';1 Co"'..: , , I, e. ;..:L2 ~ f;~ 'J i..J .1 ~ 4 F E) ! '111 '>, !j 1')'Yjd.6 (iFORGE E. f1ACKENBERGER. Plainti ff IN nlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYL VANIA v CIVIL ACTION. LA W CHRISTINA L. HACKENBERGER.. Defendant NO. 94 - 5695 CIVIL IN CUSTODY ~OV~1 ORDER #c, AND NOW. this;J1.4 day of January. 1999. the parties have ad..ised the ConcilialOr that an agreement has been reached. the Conciliator relinquishes jurisdiction. BY THE COURT, ~ ~i1r ,Esquire Custody Co llilltor , t fj 1 , ~, ~ J ~ \}- ,i' "-.) ~) \ , 'J--' 0- . PATTI A. FREEMAN, Plaintiff I 19 OLER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA I CIVIL ACTION - LAW REVIVAL OF JUDGMENT v. ZACK BROWN, Defendant 94-5697 CIVIL TERM IN REI PRETRIAL CONFERENCE A pretrial conference in the above-captioned matter was held in the chambers of Judge Oler on Wednesday, May 1, 1996. Present on behalf of the Plaintiff was Carol J. Lind5ay, Esquire. Present on behalf of the Defendant was Andrea C. Jacobsen, Esquire, standing in for Samuel W. Milkes, Esquire. No pretrial memorandum was received from the Defendant. This is a writ of revival action in which the factual issue seems to be whether certain payments should be credited to the Defendant. It is unclear to the Court whether this defense is a proper one, and briefs are requested from counsel on that issue at least 12 days prior to commencement of trial. Pursuant to an agreement of counsel, Defendant's counsel shall furnish to Plaintiff's counsel copies of all exhibits proposed to be utilized by Defendant at trial at least 12 days prior to August 19, 1996. No pretrial memorandum will be required from the Defendant. This will be a nonjury trial, pursuant to an agreement of counsel. By separate Order of Court, trial in the matter will be scheduled for Monday, August 19, 1996, at 9:00 I'. ~, {'1 ~ I " ~ " i .0 , l....; , ~. ,OJ PATTI A. FREEMAN, Plaintiff I I 19 OUR IN THE COURT OF COMMON PLEAS or CUMBERLAND COUNTY, PENNSYLVANIA . . v. I CIVIL ACTION - LAW REVIVAL OF JUDGMENT ZACJ( BROWN, Defendant . . : 94-5697 CIVIL TERM ORDER OF COURT AND NOW, this 1st day of May, 1996, pursuant to an agreement of counsel at a pretrial conference held on this date at which Plaintiff was represented by Carol J, Lindsay, Esquire, and Defendant was represented by Andrea C. Jacobsen, Esquire, standing in for samuel W. Milkes, Esquire, the nonjury trial herein is scheduled for Monday, August 19, 1996, at 9:00 a.m., in Courtroom No.5, Cumberland County Courthouse, Carlisle, Pennsylvania. By tv, J' Wesley CAROL J. LINDSAY, ESQUIRE For the Plaintiff ANDREA C. JACOBSEN, ESQUIRE SAMUEL W. MILXES, ESQUIRE For the Defendant Court Administrator wc'l ,,\wp51~\('jI\frccman.mcm hie ~ ~7"Il~11 PATTI A. FREEMAN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 612 CIVIL 1990 , Plaintiff VS. ZACK BROWN. Defendant I. FACTS AS TO LIABILITY AND DAMAGES ON or about December 14, 1989, judgment was entered by District Justice Correal in an action brought by the Plaintiff against the Defendant in the amount of $3,325.00. A transcript judgment was filed in the Court of Common Pleas of Cumberland County to the No, 612 Civil 1990 on February 15, 1990. On or about September 16, 1994, Plaintiff filed a Praecipe for a Writ of Revival. The Writ of Revival was served by the Sheriff on the Defendant on October 7, 1994. On or about October 21, 1994, the Defendant filed an Answer to the Writ of Revival averring that he had made a payment of $2,750.00 on the obligation to date. The Answer was filed pro se, II. ISSUES AS TO LIABILITY AND DAMAGES SO far as Plaintiff can determine from the Answer filed by Defendant, the only issue is the II amount in which the judgment should be revived, III. LEGAL ISSUES THERE are no legal issues of which the Plaintiff is aware, \ \~~t. ~1\1 j l!\wp5I\t'jl\rrecmiln,mcl11 file' 27fH-UI IV, WITNESSES PLAINTIFF will appear to testify for herself. V. EXHIBITS THE attached record of payments made by the Defendant to the Plaintiff will be admitted, Plaintiff acknowledges receipt of $780.00 on account of the judgment, but avers that a revival of the Writ in the full amount of the judgment is appropriate. VI. SETTLEMENT PLAINTIFF has provided her accounting to Defendant's counsel, but no response has been made thereto or any offer of settlement. Respectfully submitted. FLOWER. MORGENTHAL FLOWER & LINDSAY, P.C. Attorneys for By: Carol . Lindsay, Esquire 10 # 4693 11 East High Street Carlisle, PA 17013 (717) 243-5513 ! II . ....... . " ., .' , ," aeoord ot' p&11Ilentl ",0 PaUl rre__ pertalnin4r 110 1Ihe loalll Pa1l~ obtained tor zaok Bro~ allowing Z&ok 110 puroha.e a White Chevy, 11oen.e plat. - MR. Z!CX 1100.00 on Aprl1 13, 1990 1100.00 on Ma1 11, 1990 3100.00 on June 15, 1990 $100.00 on Ju11 21,1990 3 80.00 on ~gu8t, 18, 1990 S120.00 on Se~tember 17. 1990 ~loo.oo on Ootober 15. 1990 $ 80.00 on oeoember L, 1990 J47 ~O,JO- +0-11'\\ ~"I ~ -\-~\~1'\\Js~)'J..'5" c\~m- " EXHIlIIT "A' I II I: C:\Uop.~I\qIVre.:mOln,m.:m hie II 27'1H.UI PATTI A. fREEMAN, IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY, PENNSYLVANIA NO. 612 CIVIL 1990 Plaintiff Ys. ZACK BROWN, Defendant AND now, this day of 1st May , 1996, I, Carol J. Lindsay, Esquire, of the law firm of FLOWER, MORGENTHAL, FLOWER & LINDSAY Attorneys, hereby certify that I served the within Plaintiff's Pre-trial Memorandum this day by depositing same In the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: Samuel W, Milkes, Esquire JACOBSEN & MILKES 52 East High Stl'eet Carlisle, PA 17013 fLOWER, MORGENTHAL, FLOWER & LINDSAY, P,C, Attorneys for Plaintiff II II II I By: ~ Carol J Lindsay, Esquire ID # 4 693 11 East High Street Carlisle, PA 17013 (717) 243-5513 fit. I 2783-01 -no. qy- 5"6q7 ~-r~ PATTI A. FREEMAN . IN THE COURT OF COMMON PLEAS OF . PLAINTIFF . CUMBERLAND COUNTY, PENNSYLVANIA . . . v. . NO. 612 CIVIL 1990 . . . . WRIT . DEFENDANT . . ZACK BROWN fBAEClfE. TO THE PROTHONOTARY: Please revive the judgment in the captioned case entered on December 14, 1989 in the amount of $3,372.50 with interest at the legal rate.~~v~ ~ FLOWER, MORGENTHAL FLOWER & LINDSAY ATTORNEYS FOR PLAINTIFF __A--~~ 3 .:.~vr''- ~rol J~~;;1.y. Es.utre . Clc.,.L) ID # 44693 11 East High Street ~ Carlisle, PA 17013 '. \ \-\ (717) 243-5513 \.J- \'- ,., . \ \G \ ~\t\.-u j't,~,","\.. 'lc.\. C()...J\~\l' \ ~^ no\::,... fiI. , 2183-01 PATTI A. FREEMAN PLAINTI" v. ZACK BROWN DEFENDANT TO THE PROTHONOTARY: -no. q '-1- 5'6 q 7 ~ I-Vv>>v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 612 CIVIL 1990 WRIT fBAEClEE Please revive the judgment in the captioned case entered on December 14, 1989 in the amount of $3,372,50 with interest at the legal rate.~~~ $" 3t-lcL ~~'- C--a.R Lll\.". -\ \-\ \ \ () \ Q... \c..1.. '-t IY'\ci'td. lc\. c.cuJ'~\e ~A. \ \IO\~ FLOWER, MORGENTHAL FLOWER & LINDSAY ATTORNEYS FOR PLAINTIFF Esquire . , . . ' . J '" ':3" t'" Q<'> \ '" i .... , ""< .... .... '1 I 4> t. ./ \J ~ r r d- . I-j Cl - oJ 'j- ~~ . J , -:r ,.., 0'> J" "\. J J c:r- ." ,! - - oo~ eo <:) ..,S) ~ .,..." r.) Inot'<;)~ 0 ;.'"""t . - ... '... . <:) NQ . . , r- . '~ \j-, ~ lJ) 0 ~ C't - ~ 111' ::t -:\I:. \.~ _ -I'f) e -' ~ J~ ~ ~ .." ... ~ '-' = ~ -.// .~.; ./ 7" To: Mr. Lawrence E, Welker, Pronthonatary From: Mr. Zack Brown RE: Civil Action No. 612 Term 1990 Writ of Revival, Patti A. Freeman Vs. Zack Brown Answer to Writ of Revival Mr. Pronthonatary: Now comes this defendant Zack Brown bearing this petition of Answer to the Plantirf's claim entered to No. ~ /.J eo' V,'/ Term 1990 that this defendant did in fact meet the demands of the p1antiff's ciaim and hereby holds that th~re has been a rendering of $2750.00 to date. Therefore, let the record reflect said amount paid to the plaintiff and stand as an answer to the Writ of Revival dated October 5. 1~94. Further, let it be known by these presents that this defendant is in receipt of said Writ and therefore challenges the p1ain- tier's nction and veracity therein contained in a Civil Court of Law. Date Clc + ob<i'r .;/1 19 <j 4 1_L~~'-"l Ii' Deren ant U. ,/ -h.......A.--lt:..:::rcC/ 7 c.~!...(J-v-f I'" ~iGt,,";';,',!1 J HI:rb~1 K. ~1t),;(f ~k:::!'1 F':,t)i~; MiO};\;<}t.>': f:.p ~CUlljDi.'!l,,;il(~ I,:U' 11'1\1 My l.;J~~lnj".:dcn ~,lf)('.:::, Nov ?J l.lj97 ~lt.r:t...vf, h.Jftp:..~f'l;lJiJA~;M.;;dLc'n ~I NCiJtit,;.$ LAW OffiCES FLOWER, MORGENTHAL. FLOWER & LINDSAY " PlOffiMiOfolAl. COIlOM'nON II EAST HIGH STREET CAJU.lSLE, PENNSYLVANIA 17013-3016 JAMES D. PLOWl!a aoaea 101, MOROI!NT1fAL JAMES D. PLOWt!ll, JIt. CAROL J. UNDSA Y (711) :\4J..l.l1J PAX: (711) 14~IO BIETSCH . MOROENnIAL (197S-I'lIS) FLOWl!R, KMMEIl MORGI!NTHAL . PLOWER (198$-1992) TO: 5CVLvJ I { Kt,' '<Ie" DATE: 10 I ')-/.:}1./ I I I RE: -~ .d tJ11f.1.1:.{fllt V "rWJ..7 /.;.,/ 2 {~'tll/ fie; 0 THE ENCLOSED MATERIAL IS SENT: FOR YOUR INFORMATION FOR YOUR REVIEW AT YOUR REQUEST PLEASE CALL TO DISCUSS ch htlrlCl.u-:J CC<f- fwltth~~ ~~~l ~~/}~~~;~ '-tkL I 1 f\t- (tt~t ~/)~.t. PLEASE CONTACT US WITH ANY ADDITIONAL QUESTIONS. ;;\wpll\c'I\f........lu.. (l!e ,f'l79).Ul PATTIA.FREEMAN, Plaintiff/Movant , , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 812 CIVIL 1990 . . v. . . ZACK BROWN, DefendantjReapondent NOW comes Patti A. Freeman, Plalntiff, by and through her counsel, FLOWER, MORGENTHAL, FLOWER & LINDSAY, and moves this Honorable Court as follows: 1. Movant is Patti A. Freeman, an adult individual, who resides at 47 North Conley Lane, Etters, Pennsylvania 17319-9585. 2. Respondent Is Zack Brown, whose last known address is Cumberland County Prison, 1101 Claremont Road, Carlisle, Pennsylvania 17013. 3. On October 7, 1994, the Sheriff of Cumberland County served on the Respondent a Writ of Revival in the captioned case. 4. On or about October 21, 1994, Defendant/Respondent answered the Writ of Revival. A copy of Defendant's answer is attached hereto as Exhibit 'A'. 5. No Jury trial has been requested by either party. 6. Judicial economy would be served by setting the single Issue in this case for a hearing outside of the Civil Trial term. WHEREFORE, Movant prays this Honorable Court to set a hearing on the Answer to the Writ of Revival filed in the captioned case. FLOWER, MORGENTHAL FLOWER & UNDSAY Attorneys for Movant/Plaintiff ,'J. (. , //~ By: l!l/(t(,-( ,..---2; I Carol Jj Undsay, Esquire ID # 44693 11 East High Street Carlisle, PA 17013 (717) 243-5513 \._- -- EXHIBIT "A" To: Mr. Lawrence I. Welker, Prontbonatary From: Mr. Zack Brow HE: Civil Action 10. 612 Term 1990 Writ ot Revival, Patti A. Freeman V.. Zaak Brown Answer td Writ ot Rev!!!L Mr. Pronthonatary: Nov comes this defendant Zack Brown bearing tht. petition of Answer to the Plantitt'. claim entered to No. ~ I), c..' v, 'I Term 1990 that this detendant did in tact meet the demands of the plantiff'. claim and hereby holds that there has been a rendering of $2750.00 to date. Therefore, let the record reflect said amount paid to the plaintiff and stand as an answer to the Writ of Revival dated October 5, 1~94, Date October- .:1119 'fq AL~~ -~ Defen t Further, let it be known by these presents that this defendant 1s 1n receipt of said Writ and therefore challenges the p1ain- tiff's action and veracity therein contained in a Civil Court of Lav. _ Seal Herbert K_. Notary NlIc ~rwp..~Cou1Iv My Co., "-" , E>pros Nov. 20. 1997 " P~AsscaaIlcn o/NcIaneI v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION . LAW 9'1- ':i"..97~ r-,- : NO. 612 CIVIL 1990 PATTI A. FREEMAN, Plaintiff, ZACK BROWN, Defendant PRAECIPE To the Prothonotary: Please enter my appearance as counsel for Defendant, Zack Brown, in the above captioned case. Dated: ((\ ~ 9S- SAMUEL W. MI ES, Esq. JACOBSEN & MILKES 52 E. High Street Carlisle, PA 17013 (717) 249-6427 Allomey No. 33130 Counsel for ^ CPlaintifflDefendant ~ .1-'_.. r ~ ::lC c- ,I"> "" ,-...I <=> ~" '" -. -, () f- fl.17 C,i.':;'IT,;- PRAECIPE FOR LISTING CASE FOR TRIAL IM,," /J. l,p...""tI., ./llJ Jj.,Di'''tfl'Cl " ,1l4Ml41.! TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: (Check on.) for JURY trial et the next term of civil court. . I for trial without a jury. ............................................................................ CAPTION OF CASE (enti,. c.ption must b. .t.t.d in fuJn Ie/lick on.' Pleinti" ( I Assumpsit ! ) Trespass ( ) Trespass (Motor Vehicle) (. l...B.evival of Judament loth.,1 PATTI A. FREEMAN. vs. ZACK BROWN, O.fendant The t,iallisl will be called on Februarv 21. 199 and Trials commence on Pretrials will be held on (&,.13 lIf, due 5 days hfor. p"H,i./.s) (The party listing this case for trial shall provide forthwith a cop y of the praecipe to all counsel, pursuant ro local Rule 214-1.1 No. 612 Civil 1990 Indicate the attorney who will try case for the party who files this praecipe: Carol J, Lindsav. Esouire. FLOWER. MORGENTHAL. FLOWER & LINDSAY. P.C.. 11 E. Hiah Street, Carlisle. PA 17013 Indicate trial counsel for other parties if known: Samuel W, Milkes. Esauire, JACOBSEN & MILKES. 52 Eest Hiah Street, Carlisle. Pennsvlvania 17013 This case if ready for trial. Date: j, ~IJJlI Fl tiJ / f: C ~~ j. . i Signed: '(lttf.K ':':-- Prinl Narpe:81t I . ind:av~~., 44693 c, __ Attorney for: Plaint; If 32. PATTI A. FREEMAN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V ZACK BROWN 9f;- "i(.17 ~ '/..- NO, 612 CIVIL 1990 QRDER OF COURT AND NOW, December 19 1995, counsel having failed to call the above case for trial, the case Is stricken from the January Term 1996 trial list. Counsel may rellst the case for trial when ready. By the Court, Carol J. Lindsay, Esq, For the Plaintiff IV\~;~ '-1,),lfqs Samuel W. Mllkes, Esq. For the Defendants Court Administrator :br :0- m b. u~ 1..0 0.:\. ...~ . ,- .. :':'-"'4 U-1~! c.J , )n. (1....;. ~ ~) ;'.: .......\ ,~. n_ '. h, ~:.l L'-- C~I ;" "F;: 0". N :1>. f;"",t-. r.1i~1 ::i t' ~ C-J " I". u.:.. ", l',; ~. IJ.. r- -- Co:: u. l" ::1 u ,,-:', U ., - t , If'. ,. lU~ {'. - , .' Cl- , r:' . ~ ' . , ..... C) C .... ...., l' . . w;~ . " I '. Defendant. IN THB COURT OJ' COMMON PLDS OJ' CUMBBRLAND COUNTY, PBNNSYLVANIA CIVIL ACTION . LAN REVIVAL OJ' JUDGMBNT 94-5697 CIVIL TBRM PATTI A. 'RE"~, Plaintiff V. ZACJt BROWN, IN RB I REVIVAL or JUDGMENT ORDl!:R 0' COURT AND NOW, thia 19th day of Auguat, 1996, the oaptioned judgment ie revived in the amount of $~,545.00. By the Court, . f}/l Heaa, J. Carol J. Linda.y, :laquire J'or the Plaintiff c..r-;"~ ,""";""c.,t . /;/,0 ':..."';'. Samuel Milkea, Baquire ror the Defendant mal I NTH E C 0 U R T 0 F COM M 0 N P LEA S o F CUMBERLANO COUNTY, PENNSYLVANIA CIVIL DIVISION PATTI REYNOLDS(plaintiff) (formally Patti Freeman) NO. 99-7380 : vs. : : lACK BROWN (defendant) : ANSWER TO WRIT OF REVIVAL TO THE HONORABLE JUDGES,OF THE SAID COURT: PETITIONER,lack Brown, pro ~, hereby moves and represents: 1. Petitioner admits to original cash loan he obtained from plaintiff, Patti Reynolds, aka, Patti Freeman. 2. Original loan for consumated in 19~~. the amount of S2500.00; loan was 3. Petitioner was represented by counsel, Sam Milkes, (c/o Jacobsen & M.), 52 High St., Carlisle. PA 17013, (717)249 6427. 4. Petitioner avers that plaintiff admitted in open court that defendant made payments of $125.00 cash per month, and one SBOO.OO cash payment in '96 in the the court of Honorable Kevin He~s. 5. Petitioner avers 15 payments at S125.00 were made to plaintiff. 6. Petitioner avers that a total of $2775.00 cash was paid to plaintiff which satisfies dabt: paid in full. 7. Petitioner claims collateral estopple to writ of revival,EXH'A' 8. In an effort for fair play petitioner would now, pursuant to Rule 105(b), request enlargement of time in order to proced with this matter upon his release from confinement; SCI Camp Hill. WHEREFORE in regard to the foregoing information the petti toner prays this Honorable Court to grant enlergement of time; a continuance until release from confinement. Respectfully Submitteo, 'I / l:z,t rJ".-, ,- -' 7 '~f~ndan~-ia'-c~ -Brown' / vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 90 - 612 CIViL TERM PATTI REYNOLDS, formerly PATTI A. FREEMAN, Plaintiff ZACK BROWN, Defendant TO: Zack Brown, Defendant Inmate No. CT96316 Pennsylvania State Correctional Institution Camp Hill Prison P. O. Box 8837 Lisbum Road Camp Hill, PA 17011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE, UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE. A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS, YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249.3166 FLOWER, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff BYSJk;;'~~. gx~ Carel J, lindsay, Esquire 10# 44693 11 Ea~t High Street Carlisle. P A 17013 (711') 2.lJ5S13 ~. C.:n-. fretlmdfl 10 dol,! nOlir:a fib F .brlJary 17. 2000 PATTI REYNOLDS, formerly PATTIA. FREEMAN, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 90 - 612 CIVIL TERM ZACK BROWN, Defendant CERTIfiCATE OF SERVICE; I, Carol J. Lindsay, Esquire, do hereby certify that in accordance with Pa.R.C.P. Section 237.1, I have this date mailed to the Defendant in the above captioned action, Notice that unless they take action within ten (10) days. a default judgment will be entered against them. FLOWER, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff B~ Carol J. Lindsay, Esquire 10# 44693 11 East High Street Carlisle, PA 17013 (717) 243-5513 h<- e.) L- Date: t-v\.G.-1... C. k. 1 0 L t:nrO ( z o (/) a:: Cl.. ;: c:1' ~~ ~ s: (/)"',,<(..1 e -lg5roCl..<( CD:;l:=:!X&"::E tiW:r:Oc:I..I ro~Cl..CD... 0.< N:::i2c:illE~ ~-,.<( . Ul row '~ 2~UIl.:.JU..l ~ ~..., ~ :0 ~ :lz ;i( ~.-~ o(j C ' \,;;..J ~~G~ '~ a~~~~ vi> ~ _w~> \)) a~~~~ ~ ::: 6 f-o f: " z - '" z ~ .. v: <( \::J :..:.J VI:.;.J- 0", . K ~*::j " o ~ 'n - - - ~c.. . . < ;;: 0:: " :.:.J U :3: o r:-I - ': 'I \ \ \ I ') )) )) o <:J -- ~ -.. -- \\j , ,'. . ...... <'S - ~ -l- ~ Q. 3 ~ c.) , . '2 -;- <.J :J ....:1 ~ :;: 4 -{j<:LO'-l- '-\JO ('.J. '0 ('C q.. - - -l. ~ ~ <:. ;) '" ~"'fl. :t~l Il~' .~d"":..~~~ , \ ~ .' :-.~ '[ ~..- rJ I! I~ ~ - A "I'" ~ w~k . L:; '1 ~ (.-!;j:"oOF ~"'1:1 ~ I ~ '" !:: ~: ;Ii':'''-J''~''' '" ....I -c--..t' ~... U) ..(.'~~ ~...; ~ 1"1~ . 0.. ~~~;\,~. :;~~ ~,p' ../0 0#' "~'-' y!l":-". a: Z Ii'\!!; . a .~ r~'~:'s ~ IMi q~~ k~<~ ~ t-\JI "....co ~ z "U ~ ~ :"-'"\~ I'~sl[itj.~ o '" ::>t=>. .<J1. '.... o ...J l.U Vl~ 'I w. .LJJ Z a1 0 ffi-: o..-;.t.a:. , -. ..~) 55Vd 3H1 HO; 350dHnd 3H1 ;0<:: .-."- NOIB1d~OJ NOdn A 131 via 3~~1 55Vd.,;'". . 3H1 NI NHn1 15n~ nOA nOA 1SNIV9.J", NalDV AHVNlldlJSla NI i 1nSlH 111M H3aHO N3J.lIHM 51H1 Alao 013HI11IV; . PATTI REYNOLDS, : IN ~HE COURT OF COMMON PLEAS formerly PATTI A. FREEMAN, : OF CUMBERLAND COUNTY, plaintiff . PENNSYLVANIA . : . CIVIL ACTION-LAW . vs. . NO. 90-612 CIVIL TERM . . . : ZACK BROWN, . . Defendant . . CBRTII'ICATE 01' SBRVICB I, Zack Brown, pro se defendant, hereby certify that a true and correct copy of the Defendant I s Notice of Enlargement of Time was served on March 23, by regular United States mail, postage prepaid, to: Thomas Plower, Esquire 11 East High street Carlisle, PA 17013 Zack Bro'"n ~ro se Defendant ,l l)-,.-<;~? Brown, EE-3001 .p .0. Box 244 Graterford, PA 19426-0244 Date: . 3/:~,3/C'U . ,. _1' ~- 1.0: f- , . ('.j .-, -( '. .' ,- :'J r"., ;', . , .-< " r . ii,j , '. .- 1- ..;. :'1 ,-, '.' 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