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Home My WebLink About01-5832JASON J. SEAMAN, Plaintiff Vo BOBBI JO TROUTMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : DOCKETNO. o/- : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY The plaintiff is Jason J. Seaman, residing at 2706 Boas Street, Harrisburg, Dauphin County, Pennsylvania, 17103. 2. The defendant is Bobbi Jo Troutman, residing at 1550 Williams Grove Road, Lot 75, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff seeks custody of the following chid: marne Present Address Date of Birth Dominick Alexander Hess 1550 Williams Grove Road, Lot 75, Mechanicsburg, Cumberland County, PA 17055 10/02/97 4. The child was bom out of wedlock. 5. The chid is presently in the custody of Bobbi Jo Troutman, defendant herein, who resides at 1550 Williams Grove Road, Lot 75, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 6. During the past five (5) years, the child has resided with the following persons and at the following addresses: Name Address Dates Bobbi Jo Troutman 1550 Williams Grove Road, 1997 - Present Lot 75, Mechanicsburg, Cumberland County, PA 17055 7. The mother of the child is Bobbi Jo Troutman, currently residing at 1550 Williams Grove Road, Lot 75, Mechanicsburg, Cumberland County, Pennsylvania, 17055. She was never married to Jason J. Seaman. 8. The father of the child is Jason J. Seaman, currently residing at 2706 Boas Street, Harrisburg, Dauphin County, Pennsylvania, 17103. He was never married to Bobbi Jo Troutman. 9. The relationship of plaintiff to the child is that of father. The plaintiff curremly resides with the following persons: Name Patricia Seaman Wife 10. currently resides with the following persons: Name Dominick Alexander Hess David J. Troutman The relationship of defendant to the child is that of mother. The defendant Relationship Son Husband 11. Plaintiff has not participated as a party or wimess, or in another capacity, in other litigation concerning the custody of the child in this or another court. -2- 12. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 14. The best interest and permanent welfare of the child will be served by granting the relief requested. 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff respectfully requests the Court to grant him custody of Dominick Alexander Hess. Respectfully submitted, Dated: October 8, 2001 Heather M. Faust Attorney ID//77947 Killian & Gephart 218 Pine Street Harrisburg, PA 17101 (717) 232-1851 Attorneys for Plaintiff -3- VERIFICATION I herebY verify that the statements of fact made in the fbregoing document are truc mid eom'eot to Ihe but of my kllowledge, information and belief. 1 understand that any raise slatements made therein ar~ subject to the p~na!tle$ oont~ined in 18 Pa.C.S.A. §4904, relati~sg 1,~ ~mSwom falsificatton to authorxttcs, Dated: October 8, 2001 JASON J. SEAMAN PLAINTIFF V. BOBBI JO TROUTMAN DEFENDANT IN THE COURT OF COMMON PLEAS oF CUMBERLAND COUNTy, PENNSYLVANIA 01-5832 CIVIL ACTION LAW 1N CUSTODY AND NOW, _ Monday, October 15, 2001 U-on ' ' ' , P consmerat~on of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechaniesburg, PA 17055 on Tue for a Pre Heanng Custody Conference At s-~ ~. tuesday, November 13, 2001 at 10:30_._AM - ' · ~- ~omerence, an exIort 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. Fa/lure 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 ~ The Cour~ 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 available to disabled indiv/duals having business and reasonable accommodations 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. Cumber/and County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 JASON J. SEAMAN, Plaintiff VS. BOBBI JO TROUTMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-5832 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this '~' day of ~0~-~,..,c,,~ , 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Bobbi Jo Troutman, shall have primary physical custody of Dominick Alexander Hess, born October 2, 1997. 2. The Father, Jason J. Seaman, shall have periods of visitation with the Child at the Mother's residence, with Jennifer Stamer from ParentWorks, Inc. present on Tuesday evenings fi.om 6:30 p.m. until 8:30 p.m. beginning November 20, 2001. The Father shall attend the first introductory period of visitation without being accompanied by his wife. Thereafter, the parties shall follow the recommendations of Jennifer Stamer with regard to the appropriate time for introduction of the Father's wife to the Child. The Father may have additional periods of visitation or custody with the Child as agreed between the parties. 3. The parties shall cooperate in attempting to establish a gradually expanding custody schedule for the Father on an ongoing basis by agreement. 4. The parties and their counsel shall attend a second Custody Conciliation Conference in the office of the Conciliator, Dawn S. Sunday, on Tuesday, December 18, 2001 at 8:30 a.m. for the purpose of addressing an ongoing partial custody schedule in the event the parties have been unable to reach an agreement. 5. Neither parent shall do or say anything which may estrange the Child fi.om the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision. 6. 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. BY THE COURT, cc: Heather M. Faust, Esquire - Counsel for Father Joan Carey, Esquire - Counsel for Mother JASON J. SEAMAN, Plaintiff VS. BOBBI JO TROUTMAN, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-5832 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 concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Dominick Alexander Hess October 2, 1997 Mother 2. A Conciliation Conference was held on November 13, 2001, with the following individuals in attendance: The Father, Jason J. Seaman, with his counsel, Heather M. Faust, Esquire, and the Mother, Bobby Jo Troutman, with her counsel, Joan Carey, Esquire. Date 3. The parties agreed to entry of an Order in the form as attached. Dawn S. Sunday, Esquire / Custody Conciliator JASON J. SEAMAN, Plaintiff BOBBI JO TROUTMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-5832 CIVIL IN CUSTODY ORDER OF COURT AND NO~, this _ fY*,,,,y'~°" ~,- -e Fcbraar,-'~j, 200~-, ,~"on °onsiderati°n nfthe parties't ~ consent agreement, the following Order ~s entered regarding custody of the pattie child Dominic Alexander Hess D.O.B. October 2, 1997: 1. Defendant, Bobbi Jo Troutman, hereinafter referred to as the mother, shall have primary physical and legal custody. Plaintiff, Jason J. Seaman, hereinafter referred to as the father, shall have partial custody at times agreed upon by the mother and father. The mother and father shall cooperate in attempting to establish a gradually expanding partial custody schedule for the father on an ongoing basis by agreement. The mother and father shall inform each other immediately of any medical emergencies which may occur when the child is in that parent's custody. This Order shall remain in effect pending further Order of Court in the above captioned case. KILLIAN & GEPHART 218 Pine Street Harrisburg, PA 17101 ol-lq BY THE COURT, If entered pursuant to the consent~ of Plaintiff and Def~~ Bobbi Jo T(~outman, Defendant /asof~aman, Plaintiff /TLan Care /I ,~deather M. Faust v/~At~mey 7or Defendant ~/ Attorney for Plaintiff MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013