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Home My WebLink About01-0565 FX JEREMIAH L. GIBSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001- SGS' CIVIL TERM JODY GIBSON, Defendant CIVIL ACTION-LAW IN CUSTODY ORDER OF COURT AND NOW THIS _ day of . 2001, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before , Esquire, the conciliator, at on the _ day of ,2001 at _ A.M.lP.M., 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. BY THE COURT, BY Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF 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, PA 17013 (717) 249-3166 II "ij JEREMIAH L. GIBSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA lr. " !~ ~t v. ./ NO. 2001- 5(,5 CIVIL TERM JODY GIBSON, Defendant CIVIL ACTION-LAW IN CUSTODY :l n ri ~~. COMPLAINT FOR CUSTODY 1. The plaintiff is Jeremiah L. Gibson, an adult individual residing at 3564 ,r !! if ~: Valley Road, Marysville, Perry County, Pennsylvania 17053. 2. The defendant is Jody Gibson, an adult individual residing at 805B West Ii 1\ !f. ,. I;. Valley Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff seeks custody of the following child: Name Present residence Aae Dylan M. Gibson 805B West Valley Street Mechanicsburg, PA 17055 born June 4, 2000 The child was not born out of wedlock. The child is presently in the custody of Defendant, who resides at 805B West Valley Street, Mechanicsburg, Cumberland County, Pennsylvania. During the past five years, the child has resided with the following persons at the following addresses: Persons Residences Dates Jeremiah L. Gibson and Jody Gibson 2437 O'Hara Drive Raeford, North Carolina 28376 April 21, 1998 to August 11, 2000 I' II Jeremiah L. Gibson and Jody Gibson 805B West Valley Street Mechanicsburg, PA 17055 Jody Gibson 805B West Valley Street Mechanicsburg, PA 17055 August 11, 2000 to January 1, 2001 January 1, 2001 to to present The natural mother of the child is Jody Gibson, currently residing at 805B West Valley Street, Mechanicsburg, Cumberland County, Pennsylvania. If ;, li_ if. :;' She is married. " I'. If ii f,; ii 1" 1'1 if: 1;1 I~ fJ Il !:! i[j Ifi !I The natural father of the child is Jeremiah L. Gibson, currently residing at 3564 Valley Road, Marysville, Perry County, Pennsylvania. He is married. 4. The relationship of the Plaintiff to the child is that of natural father. The plaintiff currently resides with the following persons: Names Sherry L. Bullock Relationshio Mother 5. The relationship of the Defendant to the child is that of natural mother. The defendant currently resides with the following persons: Names Dylan Gibson Relationshio Son 6. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning the custody of the child in this or in any other Court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. I ,I . II ',li:' ii~ Ie- '" j:! 1 I' I', Plaintiff does not know of a person not a party to the proceedings who has 'I, 1 I: Ii I I' I, physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. 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 i; this action. All other persons, named below, who are known to have or claim a right to I;' ~, t custody or visitation of the child will be given notice of the pendency of this action and the right to intervene. WHEREFORE, Plaintiff requests your Honorable Court to grant him shared physical custody of the child. Respectfully submitted, O'BRIEN, BARIC & SCHERER ~>:4 Michael A. Scherer, Esquire 1.0. # 61974 17 West South Street Carlisle, PA 17013 (717) 249-6873 mas.dir/domestic/custody/gibson.com I; II , ' . VERIFICATION I verify that the statements made in the foregoing Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities, ~ -$-. ~~ Jeremiah L Gibson ':I ~1 ~j i~! ;:1 'I DATE: z.." J~f\ 0 I I ,- ", " '><> " ".. i\ir'--,' JEREMIAH L. GIBSON PLAINTIFF V. JODY GIBSON DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-565 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 31ST day of January, 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear beforeJacqueline M. Verney, Esq. , the conciliat at 4tb Floor, Cnmberland County Courthouse, Carlisle on the 28tb day of February , 200 I, at 3:30 p.m. 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 defme 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. FOR THE COURT, By: /s/ Jacqueline M. Verney. EsqJP 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 YOURATIORNEY 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 :'1-~_ ..,.,= ;:ii~fD-'()I:FiCE 0- .,., '~""-"""'V.'()"'ll'D'Y r ,!._;~"- ~- ,',,,_,;; ;I,.,i \'\'. / \rl "I 1'" '<I P<j ^. 2~ b ,..;tl:\i.,; I!' t:4 _.V cu' ;P;C"'U'J .0' 1\""'U'N'fY lV,l.,)\-h '1\ vV PENNSYLVANIA /'J/.c?1 / '..?/,t? / /:]/ .01 cd. {~ fr<"J~2 ci7f $~M ~;~~~ Juc,:~ -'0 tLjif- ti-/;7 dzac/ ~~ ,~ ,t4'1~.c-'" ,,// ;7 .7 ~ J;>/ 55 ~'j "~~",_,"%!;;-,,<,riir"~'''il''''''?1'''-'!;3!j''W~JID'f~;f!\,'<p;l'r'r'''',r.;'j1!,,,'n;~';'(i"y,~*ffilW!I'~1"""""" ,_, _" , ._~~~",,_,,=~~~POFMI~~ff"''>:f'~' ,",-."I~~~ ;..--J, ''''"'', ._.'",.' "I !:i , MAR 1 5 200ftIJ JEREMIAH L. GillSON, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA : No. 2001-565 CML ACTION - LAW JODY GillSON, Defendant : IN CUSTODY ORDER OF COURT ANDNOW,this~dayof ~. ,2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. The Mother, Jody Gibson, and the Father, Jeremiah 1. Gibson, shall have shared legal custody of Dylan M. Gibson, born June 4, 2000. Each parent shall have an equal right, to be eiercised jointly with the other parent, to make all major non- emergency decisions affecting the child's well-being including, but not limited to, all decisions regarding his health, education and religion. 2. Pending the Custody Conciliation Conference scheduled for May 9, 2001 at 9:30 a.m., in the Cumberland County Courthouse, Carlisle, Pennsylvania, Fourth Floor Jury Assembly Room, Mother shall have primary physical custody of the child with Father having periods of partial physical custody as follows: a. Alternating weekends from after work on Fridays to Sunday at 6:00 p.m. b. Every Tuesday and Thursday evening from after work to 9:00 p.m. 3. The parties shall share transportation on alternating weekends with the receiving party picking up the child. Father shall be responsible for all transportation during the weekday custody periods, 4. The parties shall share the Easter holiday with the party not having custody otherwise shall have custody of the child from 1:00 p.m. to 6:00 p.m. 5. A Custody Conciliation Conference is scheduled for May 9, 2001 at 9:30 a.m. in the Cumberland County Courthouse, Carlisle, Pennsylvania, Fourth Floor Jury Assembly Room. 6. This Order is entered pursuant to an agreement of the parties reached 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. .. ~~ y i,~ L ~ , ,. . , ~; ; r ,,/,r' BY T( COURT, cc: Michael A. Scherer, Esquire, Counsel for Father Bradley 1. Griffie, Esquire, Counsel for Mother ) I ,1flIl~lu_4 ," ".';. ---;\\'i 1W-....--.." M'" m!lll!,,,,,,^,~,~ ~ "" ,~ ~.'n'~ '_~nl '-",;._'-"" j-n ~I }..(,\fFV"'c - ;~:'i-::'_"':" " uL., ", ',]!ONOTARY o 11,(,1f( 16 Ml 10: 3S OF "U' 11"~"_'_~ '"' 1VI,:;;;:H,",o,,'f!', ('OUN1lY ~'_I ,- v t't: ~NS'I1.VANiA . "'~I-~~t!_~!l-'~~~'W~~~~ll"!~W"i'i!l~f,1,"~~- r ""'....,....,iR' <.1 ,--- ",'- ~"'- , .C ~L'; j _ ~;', '~ '.C. MAR152D01tIJ JEREMIAH L. GIBSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA : No. 2001-565 CIVIL ACTION - LAW v. JODY GIBSON, Defendant : IN CUSTODY PRIOR JUDGE: None 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 Dylan M. Gibson June 4, 2000 Mother 2. A Conciliation Conference was held on this matter on March 14, 200 I. Mother, Jody Gibson, was present with counsel, Bradley 1. Griffie, Esquire, and Father, Jeremiah 1. Gibson, was present with counsel, Michael A. Scherer, Esquire. 3. Father was seeking shared physical custody of the child, however the parties agreed to entry of an Order in the form as attached and agreed to return to the Conciliator following eight weeks of custody as set forth in the attached Order. 3 -1'--0 ( Date ~~~ Custody Conciliator ; ,,,",,1_- L,~ ~. ,... = -.~ ,~" ,,=> C~"''''- MAY 0 9 ZOO.bO JEREMIAH L. GIBSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA V. : NO. 2001-565 CIVIL TERM JODY GIBSON, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 8th day of May, 2001, the Conciliator being notified that the parties are satisfied with the prior Order, the Conciliation Conference scheduled for May 9, 200 I at 9:30 a.m. is hereby cancelled and the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, %,~ Conciliator ~ .~ <_I ,,"". ,~ ~,~ --,-,='~ """, ',,- ~ ",'" ~,. ,~~ " -.~,-,~ ,~ (\1 "',,,, II P~,'l' 1: ~.;q U i r:;oi I l " .... r'U.i\.^C'C>:Ui c"n (''J''''J' NiTY v 'J~~ lll.) \;'1'-' V PENNSYLVANiA E '",", ~~-. . ";'''l''_'l!''~~''''''''f'''~!il:1'1It.'f!!I'''f>~;<_",;;-''''~;'~~f'!''l!il76!l",_Ji~'W~1l!ll<ijF<1'''~~llj!'~j'M1 ; > ,_ __~:",'T