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HomeMy WebLinkAbout07-0947DAVID E. JUMPER, II, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 07 CIVIL TERM DEBRA A. JUMPER, Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is David E. Jumper, II, residing at 74 Cave Hill Drive, Carlisle, Cumberland, County, Pennsylvania 17013. 2. The defendant is Debra A. Jumper, residing at 66 Cave Hill Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks custody of the following child: Name Present Residence DOB Age Russell A. Jumper 74 Cave Hill Drive 5/22/98 8 years Carlisle, PA The child was not born out of wedlock The child is presently in the custody of David E. Jumper who resides at 74 Cave Hill, Carlisle, Cumberland County, Pennsylvania. During the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates David E. Jumper Debra A. Jumper 66 Cave Hill Drive Carlisle, PA 7/1/01-2/13/07 David E. Jumper 74 Cave Hill Drive 2/13/07-present 4. The mother of the child is Debra A. Jumper residing at 66 Cave Hill Drive, Carlisle, Cumberland County, Pennsylvania. She is married. The father of the child is David E. Jumper, currently residing at 74 Cave Hill Drive, Carlisle, Cumberland County, Pennsylvania 5 6. 7 8 He is married. The relationship of plaintiff to the child is that of Father. The plaintiff currently resides with the following persons. Name Tiffany R. Jumper Russell A. Jumper Relationship Daughter Son The relationship of defendant to the child is that of Mother. The defendant currently resides with the following persons. Name Self Relationship 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 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 and claims to have custody or visitation rights with respect to the child. The best interest and permanent welfare of the child will be served by granting the relief request because: Plaintiff has undertaken and performed the primary parental responsibilities for the children . Plaintiff is best able to provide the care and nurture which the children need for healthy development. A Court Order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. Plaintiff desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the child. A Court Ordered determination of custody is required to avoid continuing conflict between the parties regarding responsibility for custody and support. Plaintiff continues to maintain the same family household for the child that has been maintained since birth. WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody with structured visitation in the Defendant. Respectfully submitted, ROMINGER & WHARE Date: a-a-- Cq- Michael O. Palermo , Esquire 155 South Hanover Otreet Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 93334 Attorney for Plaintiff VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Date,) - Da"'. Jumper, Plaintiff a 8 114 `t;,. 4 0 - n 1.; n . ;. c ? o :t' \. . l N11 r . , .. CZ n r M' DAVID E. JUMPER, II IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 07-947 CIVIL ACTION LAW DEBRA A. JUMPER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, February 26, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, March 30, 2007 _ at 1:00 PM 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 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 hearing. FOR THE COURT. By: /s/ john j. Mangan, r. Es q. 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 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE 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) 249-3166 aa, ( i J L WJ H 833 LODZ i7 ,-f-_ -1 il -4 ot David E. Jumper, II, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07 - 947 CIVIL ACTION LAW Debra A. Jumper, IN CUSTODY Defendant ORDER OF COURT AND NOW this day of Wl ?- :) , 2007, upon consideration of the attached Custody Conciliation Report, it is Ordered and Direc ed as follows: 1. The Father, David E. Jumper, III and the Mother, Debra A. Jumper, shall have shared legal custody of the minor child, Russell A. Jumper, born 5/22/1998. The parties agree that major decisions concerning the child's health, welfare, education and religion shall be made by them jointly, after discussion and consultation with the other, with a view toward obtaining and following a harmoniously policy in the child's best interest. 2. Primary physical of Russell Jumper shall be with Father. The Mother shall have partial physical custody of Russell Jumper every other weekend from 9:00 am Saturday through Sunday 5:00 pm and two evenings per week from 4:15 pm until 7:30 pm. Should Mother desire to pick Russell Jumper up from school, two days notice shall be given to Father and the visits with Mother shall be from 3:20 pm until 7:00 pm. 3. The pick up and drop off location shall be at Nell's Supermarket on Spring Road, Carlisle, PA. 4. It is directed that the child's visitation with Mother shall be in Mother's apartment and not in the upstairs residence of the. McCabe's. 5. The Mother and the Father are directed to utilize appropriate safety restraints while transporting the minor child, Russell Jumper. 6. Should either Mother or Father desire to take Russell Jumper out of state for a day trip or take him on an over-night trip, one week's prior notice shall be given to the other party. 7. Telephone contact between Russell Jumper and the non-custodial parent shall be liberal as agreed upon between the parties. 8. Holidays: Holidays shall be mutually agreed up by the parties; in the absence of agreement, the parties shall conduct the holiday schedule as attached. t V , ' `? 9. In the event that the custodial party is in need of a babysitter for more than two hours, the custodial parent shall contact the non-custodial parent and offer said babysitting opportunity to the non-custodial parent. 10. This Order is entered pursuant to 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. Another Conciliation Conference is scheduled for the first week of June 2007, the time and date to be determined by mutual agreement of the parties. Distribution: vMichael O. Palermo Esquire ,Mne Adams, Esquire ohn J. Mangan, Esquire By the Court, HOLIDAYS AND TRIES EVEN ODD SPECIAL DAYS YEARS YEARS Easter Day From 6 pm the evening before the Father Mother holiday to 6 pm the day of the holiday Memorial Day From 6 pm the evening before the Mother Father holiday to 6 pm the day of the holiday Independence Day From 6 pm the evening before the Father Mother holiday to6 m the day of the holiday Labor Day From 6 pm the evening before the Mother Father holiday to 6 pm the day of the holiday Thanksgiving 1 S From 6 pm the evening before Father Mother Half Thanksgiving Day to 3 pm on Thanks ivin Da Thanksgiving 2° From 3 pm on Thanksgiving Day to Mother Father half 6 m the day after Thanksgiving Da Christmas 1 s Half From 9 am on 12/24 to 3 pm on Father Mother 12/25 Christmas 2° Half From 3 pm on 12/25 to 3 pm on Mother Father 12/26 Mother's Day From 6 pm the evening before the Mother Mother holiday to 6 pm the day of the holiday Father's Day From 6 pm the evening before the Father Father holiday to 6 pm the day of the holiday wor1sW 0 y David E. Jumper, II, Plaintiff V. Debra A. Jumper, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 947 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CPAL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: DATE OF BIRTH QF41 6 1? 5/22/1998 Russell A. Jumper Currently in the Custody of Father, David E. Jumper, II. 2. A Conciliation Conference was held with regard to this matter on March 30, 2007 with the following individuals in attendance: The Father, David E. Jumper, II, with his counsel, Michael O. Palermo, Esquire and the Mother, Debra A. Jumper, with her counsel, Jane Adams, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. Date Johr . angan, Esquire Cu o Conciliator AUG 0 6 2007 0</ O David E. Jumper, II, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07 - 947 CIVIL ACTION LAW Debra A. Jumper, IN CUSTODY Defendant Prior Judge: J. Wesley Oler, Jr. . ORDER OF COURT AND NOW this _4?L9day of , 2007, upon consideration of the attached Custody Conciliation Report, it is Ordered anbirected as follows: 1. The Father, David E. Jumper, III and the Mother, Debra A. Jumper, shall have shared legal custody of the minor child, Russell A. Jumper, born 5/22/1998. The parties agree that major decisions concerning the child's health, welfare, education and religion shall be made by them jointly, after discussion and consultation with the other, with a view toward obtaining and following a harmoniously policy in the child's best interest. 2. Primary physical custody of Russell Jumper shall be with Father. The Mother shall have partial physical custody of Russell Jumper every other weekend from 9:00 am Saturday through Sunday 9:00 pm and when school is in session for Russell two evenings per week from the time of school dismissal until 8:30 pm. Should Mother desire to pick Russell Jumper up from school, one day's notice shall be given to Father. It is directed that Russell's homework shall be completed before returning to Father's custody. On non- school days during the week, Mother shall have custody of Russell two days from 9:00 am until 9:00 pm. 3. The pick up and drop off location shall be at Father's residence or as mutually agreed upon. 4. The Mother and the Father are directed to utilize appropriate safety restraints while transporting the minor child, Russell Jumper. 5. Should either Mother or Father desire to take Russell Jumper out of state for an overnight trip, the non-custodial parent is required to give his/her permission and the non-custodial parent shall be informed of telephone contact information, the destination and the individuals going on said trip.. Should either Mother or Father desire to take Russell out of state for a day trip, the non-custodial parent is required to be informed of said trip. 6. Telephone contact between Russell Jumper and the non-custodial parent shall be liberal as agreed upon between the parties. 7. Holidays: Holidays shall be mutually agreed up by the parties; in the absence of agreement, the parties shall conduct the holiday schedule as set forth in the May 23, 2007 Order. VN"Alk'-jNJ d Nno c 8 l :Z Wd L-- 90V LOOZ AbV ONuHir",l id 'HI ?0 3ild-+0113 8. In the event that the custodial party is in need of a babysitter for more than two hours, the custodial parent shall contact the non-custodial parent and offer said babysitting opportunity to the non-custodial parent. 9. This Order is entered pursuant to 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. Distribution: C/ Acra hael O. Palermo Esquire Jumper, 431 N. Hanover Street, Apt. 3, Carlisle, PA 17013 ,Ihn J. Mangan, Esquire C) By the Court, David E. Jumper, II, Plaintiff v. Debra A. Jumper, Defendant Prior Judge: J. Wesley Oler, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 947 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL. PROCEDURE 1915.3-8, the undersigned Custody. Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: NAME Russell A. Jumper DATE OF BIRTH 5/22/1998 Currently in the Primary Custody of Father, David E. Jumper, II. 2. A status update Conciliation Conference was held with regard to this matter on August 3, 2007 with the following individuals in attendance: The Father, David E. Jumper, II, with his counsel, Michael O. Palermo, Esquire and the Mother, Debra A. Jumper, pro-se. 3. The parties agreed to the entry of an Order in the form as attached. Date John gan, Esq ' e Cu ody onciliator • v AUG .1420070 David E. Jumper, II, Plaintiff V. Debra A. Jumper, Defendant Prior Judge: J. Wesley Oler, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 947 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this day of August, 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: 1. The prior Order of Court dated August 6, 2007 shall remain in full force and effect with the following modifications. 2. In regard to paragraph 2 of the Order dated August 6, 2007, primary physical custody of Russell Jumper shall be with Father. The Mother shall have partial physical custody of Russell Jumper every other weekend from 9:00 am Saturday through Sunday 5:00 pm and when school is in session for Russell two evenings per week from the time of school dismissal until 8:30 pm. Should Mother desire to pick Russell Jumper up from school, one day's notice shall be given to Father. It is directed that Russell's homework shall be completed before returning to Father's custody. On non-school days during the week, Mother shall have custody of Russell two days from 9:00 am until 9:00 pm. This Order is entered pursuant to a status update 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. Ai ' tribution: chael O. Palermo Esquire i ebra Jumper, 431 N. Hanover Street, Apt. 3, Carlisle, PA 17013 hn J. Mangan, Esquire By the Court, 0+ :01 V S I glty 1001 V, David E. Jumper, II, Plaintiff V. Debra A. Jumper, Defendant Prior Judge: J. Wesley Oler, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 947 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH Russell A. Jumper 5/22/1998 Currently in the Primary Custody of Father, David E. Jumper, II. 2. The Honorable J. Wesley Oler, Jr. previously entered an Order of Court dated August 6, 2007 following a status update conference. 3. A clarification of a pickup time in paragraph 2 of the Order dated August 6, 2007 is requested in the form as attached. /3 U Date Jo angan , Esquire - C to Conciliator