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HomeMy WebLinkAbout03-0158JAMIE IC DUPERT, Plaintiff JASON M. DUPERT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW C>,ff-/5'~ CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Jamie K. Dupert, by her attorneys, Irwin, McKnight and Hughes, and presents the following Complaint for Custody. The Plaintiff is Jamie K. Dupert, an adult individual residing at 270 West Ridge Street, Carlisle, Cumberland County, Pennsylvania 17013. The Defendant is Jason M. Dupert, an adult individual residing at 85 Willow Mill Park Road, Mechanicsburg, Pennsylvania 17055, and is the named father of Gretchen Alexis Dupert, born April 14, 1999. The Plaintiff is the natural mother of one (1) minor child, namely Gretchen Alexis Dupert, born April 14, 1999. The Plaintiff desires primary physical custody of the minor child, Gretchen Alexis Dupert, and primary legal custody with periods of visitation to Defendant as can be mutually arranged between the parties. o The best interests and permanent welfare of the minor child requires that the Court grant the Plaintiff's request as set forth above. WHEREFORE, the Plaintiff, Jamie K. Dupert, respectfully requests that he be awarded primary physical custody and primary legal custody of Gretchen Alexis Dupert, as provided herein, with periods of temporary custody to Defendant as provided herein. Date: January 8, 2003 By: Respectfully submitted, IRWIN, McK~IGHT & HUGHES 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court I. D. No. 25476 VERIFICATION The foregoing Complaint for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have head the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. · DUI~ERT Date: January 8, 2003 JAMIE K. DUPERT PLAINTIFF JASON M. DUPERT DEFENDANT 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-158 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, January 17, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqneline M. Verney, Esq. ., the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, February 12, 2003 at 3:30 PM for a Pre-Heating 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: /si Jacqueline M. Verne~. Esa. \,,/~ CustodyConciliat~)} ' ~ 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 JAMIE K. DUPERT, Plaintiff V. JASON M. DUPERT, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2003-158 CIVIL TERM : : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this ~" day of t[~l~--- ~ ,2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Jamie K. Dupert, shall have sole legal and physical custody of Gretchen Alexis Dupert, bom April 14, 1999. 2. This Order is entered pursuant to an agreement of the parties at 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. THE Jo cc:/(Marcus A. McKnight, III, Esquire, Counsel for Mother /Jason M. Dupert, pro se 660 Boas Street Harrisburg, PA 17102 v' , 02-1q-03 JAMIE K. DUPERT, Plaintiff V. JASON M DUPERT, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2003-158 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, thc undersigned Custody Conciliator submits the following report: 1. The pertinent information conceming the Child who is the subject of this litigation is as follows: NAME Gretchen Alexis Dupert DATE OF BIRTH April 14, 1999 CURRENTLY IN CUSTODY OF Mother 2. A Conciliation Conference was held in this matter on February 12, 2003, with the following individuals in attendance: The Mother, Jmnie K. Dupert, with her counsel, Marcus A. McKnight, III, Esquire and Father, Jason M. Dupert, pro se. 3. Father contested the paternity of the Child 4. The parties agreed to the entry of an Order in the form as attached. 02 -/0, -o 3 Date ~cquff4~ne M. Vemey, Esquire Custody Conciliator