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HomeMy WebLinkAbout00-08631 ~ ,,- , '" ,-~ -0 ll"~-; KENNIE M. JAMISON, JR., Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. t>v- SY~.31 ~ /p-.. . . . . . . v. . . . . HELEN D. JAMISON, Defendant : CIVIL ACTION - AT LAW : FOR CUSTODY ORDER OF COURT .--"'- AND NOW, upon consi ration of t,he attach Complaint/Petition it is hereby directed that the parties and t ir respective counsel appear before the Custody nference Of . er at the day of 2000, at o'clock a.m./p.m. fo a Cody Conciliation Conference. At such Conference, an effort wi e made to resolve the issues to be heard by the Court and to into a Temporary Order. Children need not be esent'\,at the Conference unless their presence is requested by e Custo~ Conference Officer. Failure to appear at the Conf ence may proyide grounds for entry of a temporary or permane Order. ", Date: FOR THE COURT: By: Custody Conference Officer YOU SHOULD TAl(E THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO THE OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association Two Liberty Avenue 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 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 <"~,; KENNIE M. JAMISON, JR., IN THE COURT OF COMMON PLEAS Plaintiff . OF CUMBERLAND COUNTY, . . PENNSYLVANIA . . . ~l~ v. . No. ().{) - Jr.. 31 . HELEN D. JAMISON, . CIVIL ACTION - AT LAW . Defendant . FOR CUSTODY . COMPLAINT FOR CUSTODY The Plaintiff, Kennie M. Jamison, by and through his attorney, The Law Offices of Patrick Lauer, Jr., files this Complaint for Custody against the Defendant, Helen D. Jamison, and in support thereof, avers the following: 1. The Plaintiff is Kennie M. Jamison, an adult individual and the natural Father, who currently resides at 216 Silver Springs Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant is Helen D. Jamison, an adult individual and the natural Mother, who currently resides at 23 South Main Street, Robertsdale, Huntingdon County, Pennsylvania 16674. 3. The Plaintiff seeks custody of the following child: Name Present Residence Aqe Kennie A. Jamison 216 Silver Springs Rd. Mechanicsburg, PA 17050 13 (March 10, 1987) The child was not born out of wedlock. The child is presently in the custody of his father, Kennie M. Jamison, Jr., who resides at 216 Silver Springs Road, Mechanicsburg, Pennsylvania. ;&~,&>III"'~') During the past five years, the child resided with the following persons and at the following addresses: Name Address Dates Kennie M. Jamison, Jr., Carrie Jamison, and Heather C. Simmons 216 Silver Springs Road, Mechanicsburg, Pennsylvania 11/00-Present Helen D. Jamison and Kristopher Jamison 23 South Main Street Robertsdale, Pennsylvania birth - 11/00 The Father of the child is Kennie M. Jamison, currently residing at 216 Silver Springs Road, Mechanicsburg, Pennsylvania 17050. He is married. The Mother of the child is Helen D. Jamison, currently residing at 23 South Main Street, Robertsdale, Pennsylvania 16674. She is divorced. 4. The relationship of the plaintiff to the child is that of natural Father. The plaintiff currently resides with the following persons: Name Relationship Carrie Jamison wife Heather C. Simmons step dauahter 5. The relationship of the defendant to the child is that of natural Mother. The defendant currently resides with the following persons: Name Relationship Kristopher R. Jamison Son 6. Plaintiff has not participated as a party in other litigation concerning the custody of the child in another court. , I ! , ,,#~ 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 or claims to have physical custody or visitation rights with respect to the child. 7. The best interests and permanent welfare of the child will be served by granting the relief requested because: (a) Plaintiff is the natural Father of the child. (b) The child currently resides with Plaintiff. Plaintiff and Defendant have and conditions set forth Stipulation. 8. 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 aa parties to this action. No other persons are known to have or claim a right to custody or visitation of the child to be given notice of the pendency of this action and the right to intervene. (cl agreed to the terms in the attached WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an Order granting to him custody of his child in accordance with the Stipulation of the parties. Respectfully submitted, /l~ ---- Marlin L. Markley, Esquire Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 PA Supreme Ct. ID No. 84745 Phone: (717) 763-1800 ATTORNEY FOR PLAINTIFF II ~~di KENNIE M. JAMISON, JR. , IN THE COURT OF COMMON PLEAS Plaintiff . OF CUMBERLAND COUNTY, . . PENNSYLVANIA . v. . No. . . . HELEN D. JAMISON, : CIVIL ACTION - AT LAW Defendant . FOR CUSTODY . VERIFICATION I, Kennie M. Jamison, Jr., state that I am the Plaintiff in the above-captioned case and that the facts set forth in the above Complaint for Custody are true and correct to the best of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S. S 4940. Date: )2-;3-Z-P()O c ~ _J , , .< 'I,""",J_~~,~_', KENNIE M. JAMISON, JR. , : IN THE COURT OF COMMON PLEAS Plaintiff . OF CUMBERLAND COUNTY, . : PENNSYLVANIA : No. ttv- f/..3/ ~ ., L<- v. . . HELEN D. JAMISON, : CIVIL ACTION - AT LAW Defendant . FOR CUSTODY . AND NOW, this CONSENT ORDEI! n A. _ }, \~ day of X ~ 2000, upon consideration of the attached Stipulation of the parties in the above-captioned matter, consisting of two pages and bearing the written consent of the parties, AND upon direction of this court that the parties need not be present before the court in order to incorporate their Stipulation into a consent order, IT IS ORDERED that said Stipulation is incorporated herein by reference as if set forth in full and approved as a Consent Order pursuant to Pennsylvania Rule of Civil Procedure, Rule 1915.7. J;l.YTHE'/..C-~ / / // ..1V ,,--. 1 ',< t~~ J 2-J9-do ~Xs J. I I I! II I' . >, 'I . ~, '" _"'I ,. CoI'''r', ",\'-" ,: ~',')-Ili'I!r-;- ',< --,:,~._ ",~_rL ,_~':-'C :-: ~,,' r;U;\/OIARY 00 DFC 18 PN ~: /1 . (''''1 1'. r , 1.....UPliDC,-:.{ 21.\/]"'" r'/-'''lJ'rM '''__r \>.<J v;.) 'l J'lf PENNSYLVANiA '" , - lJ~.!1il!t<4~'"""'''''"' ._"~ ;_~,_..i~~~~!!ffill!l!lijll!l!~9.~'fi'"-~*-<;j;!~""'!ii'ifi""f'-';*~0""~;-'IM?'%'f;:~'J'"''fr'1ll-!ir,~'m"""'-#'m!~R~lj!i_.,,,,>;<",'1'''R''''''''''-''1"'''''''~_~ ~; . KENNIE M. JAMISON, JR. , . IN THE COURT OF COMMON PLEAS . Plaintiff : OF CUMBERLAND COUNTY, . PENNSYLVANIA . . . In>-.I'('31 ~ T.u...- v. No. . . HELEN D. JAMISON, : CIVIL ACTION - AT LAW Defendant . FOR CUSTODY . STIPULATION WHEREAS, the parties have born to them two children, namely Kennie A. Jamison, born March 10, 1987, and Kristopher R. Jamison, born March 10, 1989; and WHEREAS, the parties wish to enter into an agreement relative to custody, partial custody, and visitation of the child, Kennie A. Jamison; and WHEREAS, it is in the best interest of the child that this Court decide the matter because the child and his father live in cumberland County, it is the desire of both parents that the child continue to live with his father in Cumberland County, and the child continue his education in Cumberland County, thus giving this Court jurisdiction; THEREFORE, this 13'~ day of f) i!.LLnb u- 2000, in consideration of the mutual covenants, promises, and agreements as hereinafter set forth, and intending to be legally bound, the parties agree as follows: 1. Father and Mother shall share jointly legal custody of the Child, Kennie A. Jamison. - ,I. fl._ ~""~ ~.~~, .. 2. The Father, Kennie M. Jamison, shall have primary physical custody of the Child, subject to periods of partial physical custody in Mother as follows: a. Mother shall have no periods of visitation prior to March 1, 2001. b. After March 1, 2001, mother shall have visitation periods subject to father's reasonable discretion. 3. This stipulation may only be altered by the mutual consent of Mother and Father, however both parents desire that beginning one ( 1) year after this stipulation is entered into, where the child wishes to live will be taken into consideration for future custody decisions. 4. This stipulation is being entered into because both parents recognize the special needs of the child and have determined that this custody arrangement is in the best interests of the child. 5. It is the intention and desire of each of the undersigned parties that this Stipulation be confirmed as an order of court, without requiring their ~resence before the court, pursuant to Rule .... W NESS . ~ II