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HomeMy WebLinkAbout01-2891 FX ,,_ c _ d-, -'__h'-j_ '" "._,,_ ,_ , ,,__', ~.},-.,,~ t ; ; { , , " 1 i I , , DEBRA ELAM, Plaintiff f; vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 01-2891 CIVIL ACTION LAW , , JASON HOBBLE and RASHAAN ELAM, Defendants, : IN CUSTODY I ~ , ORUIi'R OF rOTTRT ~, And now, this day of , 2001, upon consideration of the attached '. \ 1 , i: " \ f i Amended Complaint, it is hereby directed that the above parties and their respective counsel appear before M"li<<. P (''''''''''''Yo F<qnir", the conciliator, at ?14 """.t" A\I"nn", "nit" 10~, r.mp Hill, PA I ( .l1Oll on Thnr<n.y, Angn<t l), ?001 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 be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or pennanent order. I r t ~ I ~ FOR THE COURT: By: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIDERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 OR 1-800-990-9108 Ii r i& "'-i'~ DEBRAELAM, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : "J1...c,.{J/-) P9} ~ -r~ : CIVIL ACTION -AT LAW : CUSTODY o~nF.~ You, RASHAN ELAM, Defendant in the above-captioned custody action, have been sued in court to obtain custody of the following child: LaSHAAN M. HOBBLE. JASON HOBBLE and RASHAAN ELAM, Defendants You are ordered to appear in person at on the day of M. for 2001, at - a Conciliation or Mediation Conference. - a Pre-Trial Conference. - a Hearing before the Court. If you fail to appear as provided by this Order, an Order for custody may be entered against you, or the Court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT W:H:ERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Dauphin County is reg.uired 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 J!rior to any hearing or business before the court. You must attend the scheduled conference or hearing. FOR THE COURT: DATE: CUSTODY CONCILIATOR II ! ;,~S-~ ". ~ J~ t,;:' ffi J:' ,'J ,.\ '" :~~ ,~:, fr ~: i' '~i " ;1' \~: ;:1' \_" " ,{ ,,' ? :." , t, i ':(~ ,;~ :~ I ,~': /, ..,; ~', j ~. , l' , 'jii 'g !~ :to t I i:' ;~' !I l' ':~' I j ~:' :'; I .,~. ..' oj "l' t i 1 'I }, 1 f " ..'{ , j F 'j' I 1 t t.. ~]$!illi*,!j.'f.;il> DEBRA ELAM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 01-2891 CIVIL ACTION LAW VB. JASON HOBBLE and RASHAAN ELAM, Defendants, : IN CUSTODY ORnER OF rOTTRT And now, this day of . 2001, upon consideration of the attached Amended Complaint, it is hereby directed that the above parties and their respective counsel appear before M"]i,,o P ('''''''''''Y. F"<jl1im, the conciliator,at 7.14 ~"""t" AVP.fll1P, ~l1it" 1O~. r.omp Hill. PA 11ill.l on Thl1r..-lOY. Al1g,,'t q. 7.001 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 be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or pennanent order. FOR THE COURT: By: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 OR 1-800-990-9108 II I" ! II iig~Ill'iM'lI!i~ j ~ " :~ oj """'-, '[lint - ~iil,'- ~;-- " DEBRA ELAM, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~ No. CJ (. ..l. f9 f Ct.;.rJ I~ vs. JASON HOBBLE and RASHAAN ELAM, Defendants, : CIVIL ACTION -ATLAW : CUSTODY /:l)MPT.A TNT FOR /:TT~T()nV The Plaintiff, DEBRA ELAM, through her attorneys, The Law Offices of Patrick F. Lauer, Jr., files this Complaint for Custody against the Defendants, JASON HOBBLE and RASHAAN ELAM, and in support thereof, avers the following: 1. The Plaintiff is DEBRA ELAM, an adult individual and the maternal grandmother, who currently resides at 1826 Heishman Gardens, Carlisle, Cumberland County, Pennsylvania 17013. 2. (a). The Defendant is RASHAAN ELAM, an adult individual and the natural Mother, who currently resides at 652 Oakville Road, Shippensburg, Cumberland County, Pennsylvania 17013. (b). An additional Defendant, supportive of Plaintiff's claim, is JASON HOBBLE, an adult individual and the natural father, who is currently incarcerated in Graterford State Correctional Institution, Gratterford, Pennsylvania. 3. The Plaintiff seeks primary physical custody and legal custody, of the following child: II ,. q " If j: i; I: , ~~ ..' 'j'-." _'W:iP,ld Na'Ue P-cesI>nt A dd...ess Age LaShaan M. Hobble 652 Oakville Road Shippensburg, PA DOB: 4/5/00, lyr. The child was born out of wedlock. 4. The child is presently in the custody of RASHAAN ELAM, who currently resides at 652 Oakville Road, Shippensburg, Pennsylvania 17257 with his maternal grandfather, James Elam, and the Defendant, Rashaan Elam. 5. The child resided with maternal grandmother from birth through April /4, 2001 at the following address: Dates: Addresses: Names: 4/5/00 (birth) 1826 Heishman Gardens Debra Elam Carlisle, PA 17013 Rashaan Elam 4/14/01-5/1101 221 E. Louther Street Carlisle, P A 17013 Rashaan Elam Frank Porter Dionne Porter Dionne's 2 children 5/2/01 to present 652 Oakville Road Shippensburg, P A Rashaan Elam James Elam Laurie Mumma Laurie's 2 children 6. The Mother of the child is RASHAAN ELAM, who currently resides at 652 Oakville Road, Shippensburg, Cumberland County, Pennsylvania 17257, with the subject of this petition. The Mother is not married to the natural Father. 7. This location is an overcrowded home; the previous location is an overcrowded apartment. II . .----~,'f;,- 8. The Father of the child is JASON HOBBLE, who is currently incarcerated at SCI -Graterford. The Father is not married to the natural Mother. ',:-! If 9. The Plaintiff has not participated as a party or witness, or in another i,oJ capacity, in other litigation concerning the custody of the child in this or another court. 10. The Plaintiff has no information of a custody proceeding concerning the child currently pending in any court of this Commonwealth. !;' 11. The Plaintiff does not know of a person not a party to the proceedings, which have physical custody of the child or claims to have physical custody or " .:; visitation rights with respect to the child. 'I' 12. The best interests and permanent welfare of the child will be served by granting the relief requested because: a). The Plaintiff can provide the child with a home with adequate moral, emotional, and physical surroundings as required to meet the child's needs; b). The Plaintiff is willing to continue custody of the child; c). The Plaintiff continues to exercise parental duties and enjoys the love and affection of the child. 13. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. All other persona, named below, who are known to have or claim to have a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name: Kimberly Hawkins Address: 164 Faith Circle Carlisle, PA 17013 Basis of Claim: Paternal Grandmother Steve Hobble, Sr., RDl, Box 561, 3Spring, PA 17264 Paternal Grandfather '-@;,~-;,,,; WHEREFORE, the Plaintiff respectfully requests that this Honorable Court enter an Order granting custody of the child to the Petitioner, DEBRA ELAM in accordance with any Stipulation of the parties, or in the event the parties are unable to execute such a Stipulation, to enter an Order granting custody, partial custody, or visitation of the child to the Petitioner. Respectfully sub "tted, Date: &tC(/or Matthew J. shelman, Esquire Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 72655 Tel. (717) 763-1800 "T '!fli\,'~mt0.l\ DEBRA ELAM, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. JASON HOBBLE and RASHAAN ELAM, Defendants : CIVIL ACTION -ATLAW : CUSTODY VERIFICATION I, DEBRA ELAM, 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. ~ 4940. Date. sl1o/o I I / Qo~(1, 1<- UA/L Debra Elam, Plaintiff .' "_ -~ DEBRA ELAM PLAINTIFF V. JASON HOBBLE AND RASHAAN ELAM DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-2891 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 17, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on Tuesday, June 05, 2001 at 11:00 a.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. 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: Isl Melissa P. Greevy. Esq.lJb 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 , 1!l!iI=_ _~ ,_~"'_c~ __ '__M"~_<~_ ,_~,,~~"~~___ _~,~ _ _~.~__~., "'~~.~~ . ~- c ,,, II:' f..: ' .1 \ 'f~ \ \ V,?,\ ,- . . "'. \\-.!y{ ,..,\ . ,,~_ '- C}J\.' \ , r'~ \\\h0~\\;\S~~J~~,[~ \,,)v \Yd"I1.\"''' Slf.,j( M~_~ ;:;~-~ 5' /,f' /)1 'J1~ It.a. a.", ~ ~ f'/f-Ol ~ ~ ~ a1.~ 1 . ._,~"",",~~oo~..~!I'!Vi~,ill!lffi"W~"'i'''''~\'f~,:,j-<:!?f'il''irr'''~~:<'''''f'!j_IT'+^''''-';';:'_'';\'*'''",;;''I,qj:~~~~J!!Imf~ii!fffifl'''!l\~~~~€i!~Im!l!&F- - -~ SAlOIS SHUFF, FLOWER & LINDSAY ATI'ORNEYS-AT-LAW 26 W. High SITeet Carlisle, P A ~, DEBRA ELAM, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01 - 2891 CIVIL TERM : CIVIL ACTION - LAW Plaintiff vs. JASON HOBBLE and RASHAAN ELAM, Defendants : IN CUSTODY NOTICE YOU ARE HEREBY NOTIFIED to plead to the within Preliminary Objections within twenty (20) days after service of this Preliminary Objection. Ii - SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS'ATlLAW 26 W. High Street Carlisle, P A '-_"1:.- DEBRA ELAM, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01 - 2891 CIVIL TERM : CIVIL ACTION - LAW Plaintiff vs. JASON HOBBLE and RASHAAN ELAM, Defendants : IN CUSTODY PRELIMINARY OBJECTIONS NOW COMES Rashaan Elam, by and through her counsel, SAlOIS, SHUFF, FLOWER & LINDSAY, and files the following preliminary objections: 1. Objection pursuant to 23 Pa.C.SA S5313(b)--Standing. Debra Elam does not have standing to bring a Complaint for Custody. She does not have genuine care and concern for the child. She has not assumed the role and responsibilities of the child's parent, providing for the physical, emotional and social needs of the child and it is not in the best interest of the child to be in the custody of Plaintiff. WHEREFORE, Defendant, Rashaan Elam, prays this Honorable Court to dismiss the Complaint. SAlOIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: , Esquire II , . SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS.AT-LAW 26 W. High Street Carlisle, PA , -- .- ^ -",~;f, __1,- ",. - J "_'~ ,~ _,_ '"~<- '-"~, I.. ,I _" _~ _ VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 9 4904, relating to unsworn falsification to authorities. Date: ,j) ~ ~ tll LL~~ Rashaan Elam iI - SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS.AY.LAW 26 W. High Street Carlisle, PA _.. DEBRA ELAM, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01 - 2891 CIVIL TERM : CIVIL ACTION - LAW Plaintiff vs. JASON HOBBLE and RASHAAN ELAM, Defendants : IN CUSTODY CERTIFICATE OF SERVICE AND now, this day of '2---' 2001, I, Carol J. Lindsay, Esquire, of the law firm LINDSAY, Attorneys, hereby certify that I served the within Preliminary Objections this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: Matthew J. Eshelman, Esquire 2108 Market Street, Aztec Building Camp Hill, PA 17011 SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: . Linds squire 4693 26 West High Street Carlisle, PA 17013 (717) 243-6222 iI ---., - ">.. '. ","",-"P',,", ,:_' _"___ ~~#- ~'c~ ~~.& 4j ~y~--- ~'.~'. i ,,1-- .' _ -.:.' ,-~ -. . . -:'_~_:" 0'__, '(t;t>,:, , ,-^, .J.oJ , '_<c.:, ,"--, " Aill ! o DEBRA ELAM PLAINTIFF V. JASON HOBBLE AND RASHAAN ELAM DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-2891 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, August 10, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hin, PA 17011 on Thursday, August 09, 2001 at 3:00 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 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 aud all existiug Protection from Abnse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to schednled hearing. j FOR TIlE COURT, By: Isl Melissa P. Greevy. Esq. tJ(J 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 TIlE 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 I,;,,"'~- -,' i ~ I) ~ '" :~ ~; f ~i',,; 't- It d' .i' ~ lIi ~. jf " r i~ f, ?~ :.j I:: Ii I Ii Ii " I: \' i,'i ( t b , I" ~ I , '" " ~ i~ fC I. ,. ~.. , ~! ~ ' i' ,; :l ; "'-' - DEBRA ELAM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 01-2891 CIVIL ACTION LAW : IN CUSTODY vs. JASON HOBBLE and RASHAAN ELAM, Defendants, !1ae"al.e.bf C!OMPT .,uNT FOR C!TTgT()nv The Plaintiff, DEBRA ELAM, through her attorneys, The Law Offices ofPatri.ck. F. Lauer, Jr., files this Complaint for Custody against the Defendants, JASON HOBBLE and RASHAAN ELAM, and in support thereof, avers the following: 1. The Plaintiff is DEBRA ELAM, an adult individual and the maternal grandmother, who currently resides at 1826 Heishman Gardens, Carlisle, Cumberland County, Pennsylvania 17013. 2. (a). The Defendant is RASHAAN ELAM, an adult individual and the natural Mother, who currently resides at 652 Oakville Road, Shippensburg, Cumberland County, Pennsylvania 17013. (b). An additional Defendant, supportive of Plaintiffs claim, is JASON HOBBLE, an adult individual and the natural father, who is currently incarcerated in Graterford State Correctional Institution, Graterford, Pennsylvania. 3. The Plaintiff seeks primary physical custody and legal custody, of the following child: Name LaShaan M. Hobble Present AddreS'il 652 Oakville Road Shippensburg, P A Age DOB: 4/5/00, 1yr. -""",-._,.,-,,," ~. ~, r " " , '1: The child was born out of wedlock. l~ 4. The child is presently in the custody of RASHAAN ELAM, who currently resides at 652 Oakville Road, Shippensburg, Pennsylvania 17257 with his maternal grandfather, James Elam, and the Defendant, Rashaan Elam. 5. The child resided with maternal grandmother from birth through April 4, 2001 at the following address: Dates: Addresses: Names: 4/5/00 (birth) 1826 Heishman Gardens Debra Elam Carlisle, P A 17013 Rashaan Elam " 4/14/01-5/1101 221 E. Louther Street Carlisle, P A 17013 Rashaan Elam Frank Porter Dionne Porter Dionne's 2 children I , 5/2/01 to present 652 Oakville Road Shippensburg, P A Rashaan Elam James Elam Laurie Mumma Laurie's 2 children ~ " .~ ~ W II II Ii 6. The Mother of the child is RASHAAN ELAM, who currently resides at 652 Oakville Road, Shippensburg, Cumberland County, Pennsylvania 17257, with the subject of this petition. The Mother is not married to the natural Father. 7. This location is an overcrowded home; the previous location IS an ~ overcrowded apartment. f i, t, t Ij 8. The Father of the child is JASON HOBBLE, who is currently incarcerated at SCl -Graterford. The Father is not married to the natural Mother. (, ~~ ,,' N " l t " " ' i It t ~) I:;; .co :~: "fJ 11 " '1 ',',' i i,' " i: I, 'l , . t " ,f , ~: 'r; ". " J '1 , .' , , ~,i'~J!i,,' 9. The 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. 10. The Plaintiff has no information of a custody proceeding concerning the child currently pending in any court of this Commonwealth. 11. The Plaintiff does not know of a person not a party to the proceedings, which have physical custody of the child or claims to have physical custody or visitation rights with respect to the child. 12. The best interests and permanent welfare of the child will be served by granting the relief requested because: a). The Plaintiff can provide the child with a home with adequate moral, emotional, and physical surroundings as required to meet the child's needs; b). The Plaintiff is willing to continue custody of the child; c). The Plaintiff continues to exercise parental duties and enjoys the love and affection of the child. 13. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. All other persons, named below, who are known to have or claim to have a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name: Kimberly Hawkins Address: 164 Faith Circle CarlUUe,P1\ 17013 Basis of Claim: Paternal Grandmother Steve Hobble, Sr., RD 1, Box 561, 3Spring, P 1\ 17264 Paternal Grandfather 4 'd g .~ f: iii i1 ~ Fi ~ i' J.~ ',-~, t " Ii V .-,;! , r Ii: f . ~- i i- F t .;i '~, WHEREFORE, the Plaintiff respectfully requests that this Honorable Court enter an Order granting custody of the child to the Petitioner, DEBRA ELAM in accordance with any Stipulation of the parties, or in the event the parties are unable to execute such a Stipulation, to enter an Order granting custody, partial custody, or visitation of the child to the Petitioner pursuant to ~5313(a) of the Domestic Relations Code. Date: -ilih Matthew J. Es elman, Esquire Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 72655 Tel. (717) 763-1800 II I... 'A'Wi<J~\Ii_ f A {. DEBRAELAM, Plaintiff vs. : IN THE COURT OF COMM:ON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 01.2891 CIVIL ACTION LAW JASON HOBBLE and RASHAAN ELAM, Defendants, ; IN CUSTODY A TTORNRV VRRTFT("A TION The undersigned attorney hereby verifies and states that: .' 1. He is the attorney for the Plaintiff, Debra E1am; 2. He is authorized to make this verification on behalf of the client(s); J I ~ ,~ I , ~ {), Ii :'u: " 'j"' r .' ~; !r \, I 3. The facts set forth in the foregoing Amended Complaint are known to him and not necessarily to his client; 4. This verification is intended to expedite the litigation; 5. A verification of the client will be supplied if demanded; 6. The facts set forth in the foregoing Amended Complaint are true and correct to the best of his knowledge, information, and belief; and 7. He is aware that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 9 4904, relating to Unsworn falsification to authorities. " " " t 1 1;. ':~ , .:, it i 'j. r ,j Matthew J. shelman, Esquire J " '\ 'I' '" " '.'" ;1 " , -:,.fIO&':t;)W"'r.;i,_I~~fc",''!>-''''!ril>l;i'J.1.'''[1'''-41,J),~,i",;:,;tjil.Iltl!~;~~''''fl.~,'OI,.1,:O",'O'4',J "",_!,,,,;,,,,::i;H,,,,"'Iii;;",,ad,,'~~iiie~~~:t!MiMli_fr~~"'-~~_~~'~ ctr- l'"O"~. , /'..-N;~-/ .il - ,,~,~ -,<- <~ [, ',' " Ii [1 Ii ti H ::1 h I' [:J fj ,] " 0 a 0 c <' ~n -oeD ",. :-=:< mr..,.... C :i'i;TI z:l-,: L, Z, I ",-,;'n Q~.~: co :]'-7 roc "'<C') $ -' -u ~);l ~~~ ~C) :x --0 Pc r:? c5rn ::::::: --! =< I',) ~ 10 -< _M -., " ..- " t-_ 1<~ ~ .;'-j,'-,,,,_--i'_>'< ~ -,'. [,'~,; DEBRA ELAM PLAINTIFF V. JASON HOBBLE AND RASHAAN ELAM DEFENDANT IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ,I 01-2891 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, August 10, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on Thursday, August 09, 2001 at 3:00 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. 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: Isl Melissa P. Greevy. Esq.O/l 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 ATIORNEY AT ONCE. IF YOU DO NOT HA VB AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ,.' -. 'c" 1-'-'; ",' ,- "--J.'" ,','" -"~_&>i:J,::;,_~,.--".- _-1'" "~', W-"'>,:.w:, ""_,~ ,::i.(~;~.:,'J: t I , I , i, . DEBRA ELAM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . ,4/l1t(..."tI Ld COMPT.A TNT FOR r.TT!':'JY)DV : No. 01-2891 CIVIL ACTION LAW> <=> c: :;;: vCJ 1i1rn z:x, ~5 ~Ci )> ~--"'" ZL-= )>~ Z =< > c:: ~-, vs. t:iJ o -n :::: r ~~; :<J ~'~';8 '~ j ,1...) ---\~ I~~~~ om ~ ?O -< JASON HOBBLE and RASHAAN ELAM, Defendants, : IN CUSTODY I co --0 .'0 '-0 The Plaintiff, DEBRA ELAM, through her attorneys, The Law Offices of Patrick F. Lauer, Jr., files this Complaint for Custody against the Defendants, JASON HOBBLE and RASHAAN ELAM, and in support thereof, avers the following: 1. The Plaintiff is DEBRA ELAM, an adult individual and the maternal grandmother, who currently resides at 1826 Heishman Gardens, Carlisle, Cumberland County, Pennsylvania 17013. 2. (a). The Defendant is RASHAAN ELAM, an adult individual and the natural Mother, who currently resides at 652 Oakville Road, Shippensburg, Cumberland County, Pennsylvania 17013. (b). An additional Defendant, supportive of Plaintiffs claim, is JASON HOBBLE, an adult individual and the natural father, who is currently incarcerated in Graterford State Correctional Institution, Graterford, Pennsylvania. 3. The Plaintiff seeks primary physical custody and legal custody, of the following child: Name LaShaan M. Hobble P'"e~ent AddrE'~~ 652 Oakville Road Shippensburg, P A Age DOB: 4/5/00, lyr. .. " > , ,,~.,',. ~"-, .".-< '~__d , i'" '"__ i'- I c 0 , '. ..>.(O'''-':';;''-j The child was born out of wedlock. 4. The child is presently in the custody of RASHAAN ELAM, who currently resides at 652 Oakville Road, Shippensburg, Pennsylvania 17257 with his maternal grandfather, James Elam, and the Defendant, Rashaan Elam. 5. The child resided with maternal grandmother from birth through April 4, 2001 at the following address: Dates: Addresses: Names: 4/5/00 (birth) 1826 Heishman Gardens Debra Elam Carlisle, P A 17013 Rashaan Elam 4/14/01-5/1/01 221 E. Louther Street Carlisle, P A 17013 Rashaan Elam Frank Porter Dionne Porter Dionne's 2 children 5/2/01 to present 652 Oakville Road , Shippensburg, P A Rashaan Elam James Elam Laurie Mumma Laurie's 2 children 6. The Mother of the child is RASHAAN ELAM, who currently resides at 652 Oakville Road, Shippensburg, Cumberland County, Pennsylvania 17257, with the subject of this petition. The Mother is not married to the natural Father. 7. This location is an overcrowded home; the previous location IS an overcrowded apartment. 8. The Father of the child is JASON HOBBLE, who is currently incarcerated at SCI-Graterford. The Father is not married to the natural Mother. :"-= . , " .\_' , :i~ j . ..., . .i_"."',,., ",__,1,1,__, - ,''', -'.,-".::.; , : :~';::{jj ( "; , t r ( " i, l f [ 9. The 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. 10. The Plaintiff has no information of a custody proceeding concerning the child currently pending in any court of this Commonwealth. l I t ~ i I: f ! " , I t; f' s t 11. The Plaintiff does not know of a person not a party to the proceedings, which have physical custody of the child or claims to have physical custody or visitation rights with respect to the child. 12. The best interests and permanent welfare of the child will be served by granting the relief requested because: , f " l F l' ~~ I, I: f t ) i e a). The Plaintiff can provide the child with a home with adequate moral, emotional, and physical surroundings as required to meet the child's needs; b). The Plaintiff is willing to continue custody of the child; c). The Plaintiff continues to exercise parental duties and enjoys the love and affection of the child. 13. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. All other persons, named below, who are known to have or claim to have a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name: Kimberly Hawkins Address: 164 Faith Circle Carlisle,PA 17013 Steve Hobble, Sr., RDl, Box 561, 3Spring, PA 17264 Paternal Grandfather Basis of Claim: Paternal Grandmother . _M " . 1" _, 3~ ".- l: I " , ,. _ " _ ,-,_ ""' '_"~__", .,;_ --",,;'., , j I WHEREFORE, the Plaintiff respectfully requests that this Honorable Court ~ :~ '. enter an Order granting custody of the clrild to the Petitioner, DEBRA ELAM in accordance with any Stipulation of the parties, or in the event the parties are unable to execute such a Stipulation, to enter an Order granting custody, partial custody, or visitation of the child to the Petitioner pursuant to ~5313(a) of the Domestic Relations Code. f , l ~ , 3'/:,10(' Date;~ lGjrb~ _ """'- ".1"", &quire Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 72655 Tel. (717) 763-1800 "~~ ;_-"jl'CN'_', -r; ,'_ _'__ _'~'__' ,__iO" < '"';.,''' -".' -""'," ,,--,-- , ,-- ;,~ i DEBRA ELAM, Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 01-2891 CIVIL ACTION LAW JASON HOBBLE and RASHAAN ELAM, Defendants, : IN CUSTODY A TTORNRV VRRTFWA TTON The undersigned attorney hereby verifies and states that: 1. He is the attorney for the Plaintiff, Debra Elam; 2. He is authorized to make this verification on behalf of the client(s); 3. The facts set forth in the foregoing Amended Complaint are known to him and not necessarily to his client; 4. This verification is intended to expedite the litigation; 5. A verification of the client will be supplied if demanded; 6. The facts set forth in the foregoing Amended Complaint are true and correct to the best of his knowledge, infonnation, and belief; and 7. He is aware that false statements herein are made subject to the penalties of 18 Pa. C.S.A. \\ 4904, relating to unsworn falsification to authorities. Matthew J. "'" - ; ",. ";. -~ ." C_'",' "'0" , ,I---,j .~' ,._,. _'~' " ~ AUG%~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.01-2e*9 2'i?( DEBRA ELAM, Plaintiff vs. JASON HOBBLE AND RASHAAN ELAM, CIVIL ACTION - LAW CUSTODY Defendants INTERIM ORDER OF COURT J.,.;~ AND NOW, this ~r day of ^I:lgtl~l, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. The Maternal Grandmother, Debra Elam, shall have periods of partial physical custody of the minor Child, LaShaan M. Elam, born April 5, 2000, on alternate weekends from Saturday at 10:00 a.m. until Sunday at 6:00 p.m., and at other such times as the parties may mutually agree. 2. Counsel for the Plaintiff shall serve a copy of the Order upon the Defendant. BY THE COURT, rrJ J. Dis!: Marlin L. Markley, Esquire, 2.108 Market Street, Ca Hill, PA 17011-4706 Carol J. Lindsay, Esquire, 2.6 W. High Street, Carlise. PA 17013 L.JJJ'~ ~ Jason Hobble, SCI Gratertord ,-- q. 9-D'f.OI ~~~:._~~~lil!t~llli;jI,Iil~~~~iM'!_<'-~!>'")A,;J-'Thl~,j,Mia~;;';&1i'ill ,,'f1 ."ifiJ! ,''7-.!J !9 ,,"CO' j' " , ~~ -' " , ,~. . \-/!I\I',-.lr110 A.i t\:n':,;~;"!~f:'~:!YNjd _, ,. '__" ' \ ",' II (- C~" . '. '""_','/~no : I "~, ; f ,I _ ' ~-, J ')~, I ,...., q.J,) I~..i . . , v'......ur \ !'~; ; , ... I 1< I:; i ,: , , I I I I I f: I: Ii Ii t -~,~-. , - . ~. ",' - >- . -. .' ,- -~ ' ,_ :J.. I ,_~ J~- ~ ,. _ J,'..- ':_'-.1-,- i DEBRA ELAM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2819 vs. JASON HOBBLE AND RASHAAN ELAM, CIVIL ACTION - LAW CUSTODY Defendants 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 LaShaan M. Hobble April 5, 2000 Mother 2. A Custody Conciliation Conference was held on August 9, 2001, with the following individuals in attendance: the Maternal Grandmother, Debra Elam, and her counsel, Marlin L. Markley, Esquire; the Mother, RaShaan Elam, and her counsel, Carol J. Lindsay, Esquire; the Father, Jason Hobble, did not attend. He apparently is incarcerated at SCI Graterford. 3. The parties reached an agreement in the form of an Order as attached. ~1/()1 ~ Date e ssa Peel Greevy, Esquire Custody Conciliator