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HomeMy WebLinkAbout03-3073JAYLENE A. BLOSSER, PLAINTIFF VS, CHARLES M. BLOSSER, III, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0~" IN CUSTODY COMPLAINT IN CUSTODY AND NOW comes the Plaintiff, JAYLENE A. BLOSSER, by her attorney, Samuel L. Andes, and makes the following Complaint for Custody: 1. The Plaintiff is JAYLENE A. BLOSSER, an adult individual who resides at 230 Smith Road in Shippensburg, Cumberland County, Pennsylvania. 2. The Defendant is CHARLES M. BLOSSER, III, an adult individual who resides at Building 10-102, Fort Indiantown Gap, Annville, Pennsylvania 17003. 3. The Plaintiff and Defendant are husband and wife. 4. The Plaintiff and Defendant are the parents of two minor children, Charles M. Blosser, IV, age 13, born 5 June 1990; and Christian T. Blosser, age 10, born 7 March 1993. 5. children, Plaintiff seeks an award of primary legal and physical custody of the said minor Charles M. Blosser and Christian T. Blosser. 6. The children were not born out of wedlock and are presently in the custody of the Plaintiff. 7. During the past five years, the minor children have resided with the following persons at the following addresses: 1995 to October 2002 230 Smith Road Shippensburg, PA Plaintiff & Defendant October 2002 to present 230 Smith Road Shippensburg, PA Plaintiff only 8. The mother of the children is the Plaintiff who resides at the address set out above. She is married to the Defendant. above. He is married to the Plaintiff. 10. The Plaintiff is the natural mother of the children. Plaintiff currently resides with the children. 11. The Defendant is the natural father of the children. Defendant currently resides alone. 12. The Plaintiff has not participated as a party or in any other way in any litigation concerning the custody of the children in this or any other court. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this or any other jurisdiction. Plaintiff knows of no other person not a party to this action already who has physical custody of or claims to have custody or visitation rights to the said children. 13. The best interests and permanent welfare of the children will be served by granting the relief requested by Plaintiff for the following reasons: A. She has been the primary care provider for the children for all of their lives; and B. Defendant has had very little contact with the children since he moved out of the family residence more than six months ago; and C. Plaintiff is in a better position to provide for the emotional needs of the children and to provide for them a stable home life; and D. It is in the best interest of the children that they continue to reside in the primary care of Plaintiff. 14. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, JAYLENE A. BLOSSER, requests this Court to grant her custody of the children, Charles M. Blosser, IV and Christian T. Blosser. The father of the children is the Defendant who resides at the address set out Attorney for Plaintiff Supreme Court ID # 17225 525 North 12~h Street Lemoyne, Pa 17043 (717) 761-5361 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: ~ J ~ ~00~ JA~ENJ~ A. BLOSSER-- CERTIFICATE OF SERVICE I hereby certify that I served an original of the foregoing Complaint upon the Defendant herein by regular mail, postage prepaid, addressed as follows: Charles M. Blosser, III Building 10-102 Fort Indiantown Gap Annville, PA 17003 Date: 25 June 2003 Secretary for Samuel L. Andes JAYLENE A. BLOSSER : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 03-3073 CIVIL ACTION LAW C~S M. BLOSSER, IH : IN CUSTODY DEFENDANT ORDER OFCOURT AND NOW, Thursday, July 03, 2003 ., 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 301 Market Street, Lemoyne, PA 17043 on Thursday, August 07, 2003 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 de£me 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 apl~ear at the conference may provide grounds for ~ntry 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 TIlE COURT, By: /si Melissa P. Greevy. 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 F1ND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 AUG 4 ZOO3 JAYLENE A. BLOSSER, Plaintiff V, CHARLES M. BLOSSER, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3073 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER TO RELINQUISH JURISDICTION AND NOW, this 11th day of August, 2003, upon the request by counsel for the Plaintiff, the request for a Custody Conciliation has been withdrawn. Accordingly, the Pre-hearing Custody Conference previously scheduled for August 19, 2003 is hereby CANCELED. The Conciliator hereby relinquishes jurisdiction of the matter. Melissa Peel Greevy, Esquire Custody Conciliator Dist: :217021 Samuel L. Andes, Esquire, PO Box 168, Lemoyne, PA 17043 Charles M. Blosser, Ill, Building 10-102, Fort Indiantown Gap, Annville, PA 1700~~'~-~''~ ~ ~' /~' o.:.t