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HomeMy WebLinkAbout01-05832 ~ :-~ JASON l. SEAMAN PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 01-5832 CIVIL ACTION LAW BOBBI JO 1ROU1MAN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, October 15, 2001 , upon consideration ofthe 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, Mechanicsburg, FA 17055 on Tuesday, November 13, 2001 at 10:30 AM 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 aU existing Protection from Abuse orders, Special Relief orders, and Cnstody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S, Sunday. Esq~ 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 '" ,"",'.- . , , -' tHj:&mf''''WI''''~.'l',d>:",fd<'~,'';;;"''''h:""",'-,'lli'",,,",U,nrill'dH:/!a;,..1!lfur-",1','i':" >"""""",,,ij",(,,d",,:c,~'''d''ciiili.:i<ll~~'''i&!!_g,o;;ll!<~)/Ri(,~'''';lUSWI~~~~1i - r" rr r"Fll'r; r\L,t'.U'--U, ....,L. C" ",;." ""''''''''l'''C)TARY Jr" \;~;::.. ;, ,',\) i' "."q o I OCT \6 PH~: 09 CUIviBERlJ\ND COUNTY PENNSYLVANIA J/J'/lrfJ! twI.. ~ ~ 'k 4 Gi~ /t?/tf,.t?/ 'J!~ ~ :7~. /tJ/~.p? drp ~ p 4~ ~" .. mr:l:;~,~;1~;td~~~J!!ofJL,J~"'_:"~~t\~~J,,]~-;J~.~~;,~~,.1,~L\JJ~",;",;,. ~':?,Aj" J ,r"",'d','.'~ ,., ',,,,_~" ~,' " ~ ; ,- ,,' v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : DOCKET NO. tJ 1- 5f1 32. Cu.n.J T "-'- JASON J. SEAMAN, Plaintiff BOBBI 10 TROUTMAN, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER 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 , the conciliator, at on the day of ,2001, at 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. FOR THE COURT, By: Custody Conciliator 'T>~__., ,~ ;,p, ."";,0, f--n"'1I,:1".'^,'_ .,. ~, ~~ " 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. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYElR AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FINJI) OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 "'''''JlI'''$ffl:'~ = '.. -, "'", I~,,- ,,~, " -I"," ~~ "r"~~ ~;n; ! " JASON J, SEAMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLANDCOUNTY,PENNSYL V ANIA BOBBI JO TROUTMAN, Defendant : CIVIL ACTION - LAW : IN CUSTODY ~ T.l>>-. () r.::::-, Jj~' g ;g~ t:'-_ -: ,~ D v. : DOCKET NO. 01- 5F3.L if '" ' COMPLAINT FOR CUSTODY ~c, ~~ =c! 'j C:J Ci) , -' ~:~~ :0'1 (..) .< 1. 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 child: Name Present Address Date of Birth Dominick Alexander Hess 1550 Williams Grove Road, 10/02/97 Lot 75, Mechanicsburg, Cumberland County, P A 17055 4. The child was born out of wedlock. 5. The child 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: I-'M;:'_,,~ - -'''~~, 'C C:_" <.~ "H n..'", I', '--1-""- - .f,- .. "".'", ~ r -' Name Address Dates Bobbi Jo Troutman 1550 Williams Grove Road, 1997 - Present Lot 75, Mechanicsburg, Cumberland County, P A 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 currently resides with the following persons: Name Relationship Patricia Seaman Wife 10, The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons: Name Relationship Dominick Alexander Hess Son David J. Troutman Husband 11. 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. -2- 'F1f'~B:~,l,~", -~, '~~,'- - ~"",,-~ " . -r". ~ ,""-- . ',. .'-- - r---.-.--'" or 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, 7Vu::d.ft q 1 t QJ..1N Heather M. Faust Attorney ID #77947 Killian & Gephart 218 Pine Street Harrisburg, PAl 710 1 (717) 232-1851 Dated: October 8, 2001 Attorneys for Plaintiff -3- -f"""-~'''',", '_~,''"\,_, .'.. ',-,r., ,," ,,~', ""'I" .','" .- - , J VERIFICATION I hereby verify that the statemelits offact made in the filregolng document are Inw and COl'I'cct to the best elf my kllowledge, infotqlati~m ,~d belief. I understand that any ftdse , < ',: I . statements made therein are sl,lbject to th~ ~~altle~4~nhtined in 18 ,fla.C.S.A. ~4904,telaHng ": " , ' "" ",,: ::(,: ", ~ < . tc I IlfISVI'Om ,falsifit:ationto81JIhor1ties. " . Dated: October 8, 2001 . h/ ~..&? '~. :' oj.o- . ' '. 11 Seaman --" -...............-..-, .,.~,.~.._, .....,..- " // - ///,,'., ,- i/ " / ' /" ," :~';""-!''''''''~ ~,-" ~"~ -, - ~','1< ,,". ,,' '-I~ . -, , T~ "" ,~ "_~'""" 0' ",.' ~ """""''''-''''_~''''''''' '-"-%h''',\~"" "'''-<= ',j ,.1', <~iTIJ'~r~':"-rn",*&'~li~fnimjt!'j'Y:''1~;lift-'" ;,;'l~1 -, 0 c::- "b r"" , ..,-,'- .." ):I; ~T} mn) r eLl -I t ~ <'" n ..--=- \L, s: "- I'---':~: ;..:. "- .. - '" -<;:, .z i~t:_. r"_"- <- 'I:> '" ;V'C:, 'Z "- "- ?...:: ,. , -, ..... G -< C'--., -, "" (0, Vi v :~, ~,~.tii~~~~'~~lII~~~"lr'&**~~'lJ'!i(\llfW'W-cW;":'""";''''''''''.I~'',c""'- ;:>..- """'''~'1'-,' "'fiQ-,'?'-,iW'C"f';'" "".";~,,-,,, .< "T;I~"'!"'''.~f{i!101~~~~ JASON J, SEAMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, 01-5832 CNIL ACTION LAW BOBBI JO TROUTMAN, Defendant IN CUSTODY ORDER OF COURT AND NOW, this z,o" day of tJ~ , 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 Starner from ParentWorks, Inc, present on Tuesday evenings from 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 Starner 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 from 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, i' .M~~~1t ~'"~, ,I "/'~ ' - -- "'~~."-,-,'I . . ~ ~- 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 ofthis Order shall control. BY THE COURT, . II#.. 1. cc: Heather M. Faust, Esquire - Counsel for Father Joan Carey, Esquire - Counsel for Mother ~ ~ ~. 1/.';1.1.01 r'~,~1 ~, .-.- -, .. .,,', ,~.-'.' ~ -' t' ~ . . _',,10'. -, _.", . "f _..".~ ,k~~f~!iiio,~-!ii'~*'~;';'':i!,*,j;j(,>;:,;(~;"di;I'ilhi'''If~K"""",,-l:i'''''''~'''G!~ ~';I"-",i,:".""J''''B,j;,,,-''~;,:,,-~~1Iti1l!i Iii :bWiill Ui.:~rj'~~" ~~@I'=" ".~~,~, '-~1 '~-! .~::i:' .()(FiCC:: CI~ '<j-' V:i-.IDTt\RY o I ~mv 2 [I "1'0; 3' I h . j ,,' J.Q CUMGEii~AI'O COUNW PENNSYLV!\NIA ::;'t'J\","~"<!il,!Jil!!ilIl!l,,w.'~eJ! lJ!,l[!!IlLUl,~,,,,<, ",,;, ""_~",,"",,b',',',,','" ", ,',' ~~-- JASON J, SEAMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 01-5832 CIVIL ACTION LAW BOBBI JO TROUTMAN, Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 19153-8, the undersigned Custody Conciliator submits the following report: L 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, 4~r~, . Dawn S, Sunday, Esquire I Custody Conciliator tV~ I '). 'Jm! , ~"''''P''', '<, .,'~ ".' ""'~,"'" rr',rH~~"'" . . " ~ II ~'. JAN 2 42lm ~l Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA JASON J, SEAMAN, vs. : NO. 01-5832 CIVIL ACTION LAW BOBBI JO TROUTMAN, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 16TH day of January, 2002, the Conciliator, being advised by Plaintiffs counsel that all custody issues have been resolved by agreernent of the parties, hereby relinquishes jurisdiction in this case. The Custody Conciliation Conference scheduled for January 17, 2002 is canceled, FOR THE COURT, D~ Custody Conciliator ""1"if",,,",j,~,,,, "," , ~ , -" - rr 1,_ ......'r' t'" '<',~"" ~, ,M> ~" , JASON J, SEAMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v, 01-5832 CIVIL BOBBI JO TROUTMAN, Defendant IN CUSTODY ORDER OF COURT ,u' AND NOvV, this ., day of Febmary, 2002, :Jpon consideration oftbe parties' consent agreement, the following Order is entered regarding cnstody of the parties' child Dominic Alexander Hess D,O,B. October 2,1997: , , L Defendant, Bobbi Jo Troutman, hereinafter referred to as the mother, shall have primary physical and legal custody, 2, , <:1 , "'I ',. 3, 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. 4, 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, Kev' , Hess, Jud If entered pu~suant to the conse~~ of Plaintiff and Defen, ,~ ~ ~~ ~/A',ov~~,",a-c -~"';;;.: Bobbi Jo T outman, Defendant aso eaman, Plaintiff ~) / ~/U ,/ ~ V /.I6M Carey v1Ieather M, Faust LlAttorney for Defendant Attorney for Plaintiff MIDPENN LEGAL SERVICES KILLIAN & GEPHART 8 Irvine Row 218 Pine Street Carlisle, PA 17013 Harrisburg, PA 17101 V t.. opieS P)o.i I~J 01-/'1 -02- "R){S r ,~ ,- . ~ T' QJJ tJ: ""f-'!';' ~ , ~, ,"-" , ~, 0"1 I ,,~ - , 1 " --I ~ ~~ ~" , - ,_ ~,~=, __rl,,' . - -~~,~~~. - :~(~ 111r;!:llrnlll" m'I:Tf" -'1 "I .:.~) ;'.-, <,..' ~s SH '~, """,,~~[~,-;~,.,,~."7~_~1~~I~"Tl "",_Il,i11Il!!M,~('1_~I~lr;II~Jt~~,~~;II'JW~~1"1'-':!":;\;-$:':'''S;'<;"~-\''''1I;Wh''f;~;#t~''~'''Jf:'0*,,'')~j}~~~J,'-1t.~~i';~'&l\!f~~~~~';