HomeMy WebLinkAbout95-03935
REAGER , ADLER, PC
BY' DEBRA A. DBNISON, BSQUIRE
Attorney I.D. No. 66378
2331 Market Street
Camp Hill, PA 17011
Telephone: (717) 763-1383
Attorneys for Plaintiff
BARBARA HANNA,
Plaintiff
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
.
.
v.
.
.
NO.
DONALD R. HANNA, JR.,
.
.
Defendant
CIVIL ACTION - CUSTODY
COMPLAINT FOR CUSTODY
AND NOW, comes Barbara Hanna, by and through her attorneys,
Reager & Adler, P.C., and avers the following:
1. Plaintiff is Barbara Hanna, an adult individual currently
residing at 1335 Lambs Gap Road, Mechanicsbu~g, Cumberland County,
Pennsflvania, 17055.
2. Defendant is Donald R. Hanna, Jr., an adult individual
whose current address is unknown.
His work address is Ingram
Micro, 6455 Allentown BOUlevard, Harrisburg, Dauphin County,
Pennsylvania, 17112.
3. plaintiff seeks custody of the following children:
liAM
Present Residence Ala
1335 Lambs Gap Road 2
Mechanicsburg, PA 17055
DOB 09/09/92
1335 Lambs Gap Road 1
Mechanicsburg, PA 17055
COB 10/05/93
Allison Marie Hanna
Brandon David Hanna
4. The children were not born out of wedlock.
5. The children are presently in the custody of their
mother, Barbara Hanna, who currently resides at 1335 Lambs Gap
Road, Mechanicsburg, pennsylvania, 17055.
6. Since birth, the children have resided with the following
persons and at the following addresses:
Plaintiff and Defendant
4517C Florence Avenue
Mechanicsburg, PA 17055
9/92-1/95
plaintiff and Lester
and Beverly Hess
(Maternal grandparents)
1335 Lambs Gap Road
Mechanicsburg, PA 17055
l/95-Present
7 . The mother of the children is Barbara Hanna who currently
resides at 1335 Lambs Gap Road, Mechanicsburg, Pennsylvania, 17055.
She is married.
2
3. Plaintiff seeks custody of the following children:
liAlu
Present Residence Agg
1335 Lambs Gap Road 2
Mechanicsburg, PA 17055
DOB 09/09/92
1335 Lambs Gap Road 1
Mechanicsburg, PA 17055
DOB 10/05/93
Allison Marie Hanna
Brandon David Hanna
4. The children were not born out of wedlock.
5. The children are presently in the custody of their
mother, Barbara Hanna, who currently resides at 1335 Lambs Gap
Road, Mechanicsburg, Pennsylvania, 17055.
6. Since birth, the children have resided with the followinq
persons and at the following addresses:
Plaintiff and Defendant
4517C Florence Avenue
Mechanicsburg, PA 17055
1335 Lambs Gap Road
Mechanicsburq, PA 17055
l/95-Present
9/92-1/95
Plaintiff and Lester
and Beverly Hess
(Maternal grandparents)
7. The mother of the children is Barbara Hanna who currently
resides at 1335 Lambs Gap Road, Mechanicsburq, Pennsylvania, 17055.
She is married.
2
~
8. The father of the children is Donald R. Hanna, Jr. whose
current residence is unknown. He is married.
9. The relationship of the Plaintiff to the minor children
is that of natural mother. The Plaintiff currently resides with
her parents, Lester and Beverly Hess, the children's maternal
grandparents.
10. The relationship of the Defendant to the minor children
is that of natural father. Defendant currently resides with Judy
George, his girlfriend.
11. 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 custody proceeding concerning the children pending in a court
of this Commonwealth. Plaintiff does not know of a person not a
party to the proceeding who has physical custody of the children or
claims to have custody or visitation rights with respect to the
children.
12. The best interest and permanent welfare of the children
will be served by granting the relief requested for the following
reasons:
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