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Home My WebLink About07-6004 JACQUELYN S. COOK, IN THE COURT OF COMMON PLEA5 OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 'j % ~(~UOy GJ•I ~~~ JANSON E. DAMS, CIVIL ACTION -CUSTODY Defendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TARE 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717)249-3166 800-990-9108 ' a NOTICIA Le han demandado a usted en la Corte. Si usted guiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la Corte en forma escrita sus defensas o sus objectiones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la Corte tomara medidas y puede entrar una Orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes Para usted. LLEVE ESTA D~lAPTDA A UN ASODAGO INMEDIATA~NTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SIIFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLA~ POR TELEFONO A LA OFICINA CIIYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGIIAR DONDE SII PIIEDE CONSEGIIIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717)249-3166 800-990-9108 JACQUELYN S. COOK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA JANSON E. DAVIS, CIVIL ACTION -CUSTODY Defendant . COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, by and through her attorneys, Cleckner and Fearen, and in support of the within Complaint, avers as follows: 1. The plaintiff is JACQUELYN S. COOK, an adult individual, residing at 118 Hummel Avenue, Apt. B, Lemoyne, Cumberland County, Pennsylvania, 17043. 2. The defendant is JANSON E. DAVIS, an adult individual residing at 109 Ross Avenue, New Cumberland, Cumberland County, Pennsylvania, 17070. 3. Plaintiff seeks custody of Aidan Michael Davis, who was born May 25, 2007, and presently resides at 118 Hummel Avenue, Apt. B, Lemoyne, Pennsylvania, 17043. The child was born out of wedlock. The child is presently in the custody of Plaintiff, who resides at the address indicated in paragraph 1 hereof. Since birth, the child has resided with the following persons and at the following addresses: List of Persons List of Addresses Dates Jacquelyn S. Cook, 1617 Fox Hollow Rd. Birth to 6/9/2007 Albert Jacobs and Mechanicsburg, PA Michelle Jacobs Jacquelyn S. Cook 118 Hummel Ave., Apt. B 6/9/2007-9/4/2007 and Janson E. Davis Lemoyne, PA Jacquelyn S. Cook 118 Hummel Ave., Apt. B 9/4/2007-Present Lemoyne, PA The mother of the child is Jacquelyn S. Cook, currently residing at 118 Hummel Avenue, Apt. B., Lemoyne, Pennsylvania, 17043. She is single. The father of the child is Janson E. Davis, currently residing at 109 Ross Avenue, New Cumberland, Pennsylvania, 17070. He is single. 4. The relationship of Plaintiff to the child is that of natural mother. The Plaintiff currently resides with the following persons: Name Relationship Aidan Michael Davis Son 5. The relationship of Defendant to the child is that of natural father. The Defendant currently resides with the following persons: Name Relationship Ethel Davis Mother Peggy Vanderslice Grandmother Jake Davis Brother 6. 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. Plaintiff has no information • .y of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff is more responsible and mature than Defendant, and can provide a more stable and safe living arrangement for the child. 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 as parties to this action. No other person is known to have or claim a right to custody or visitation of the child, and therefore no notice of the pendency of this action and the right to intervene will be given to any other person. WHEREFORE, Plaintiff requests the Court to grant her custody of the child. Date . ~• l~ ~~ CLECKNER AND FEAREN By iDennis J. Shatto, Esquire Attorney I.D. No. 25675 119 Locust Street P.O. Box 11847 Harrisburg, PA 17108-1847 (717) 238-1731 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ;~ A QUE S. OK DATE: ~G~. l~ 2007 CERTIFICATE OF SERVICE I, DENNIS J. SHATTO, hereby certify that I served a true and correct copy of the foregoing document upon the person(s) and in the manner indicated below, this 11th day of October, 2007: Certified Mail, Restricted Delivery, Return Receipt Requested and U.S. Regular Mail Janson E. Davis 109 Ross Avenue New Cumberland, PA 17070 CLECKNER AND FEAREN By Dennis J. Shatto, Esquire PA Attorney ID #25675 119 Locust Street P.O. Box 11847 Harrisburg, PA 17108-1847 (717) 238-1731 .i/ ~ A ~ V ~ n7 ~F. °- ~-, .~ 00 -0 N 17 t~:l _.. 1. ~,..r_7 ~ _~.~ _„ "T : ~ ' ; 4f E ~.~ JACQUELYN S. COOK IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JANSON E. DAMS DF..,FF..,NDANT • 2007-6004 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, October 18, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, November 13, 2007 at 8:30 AM for aPre-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: /s/ ac ueline M. Verne Es 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 32 South. Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~O A~ 0/ ` ~' ~j~~}~i'_~ , ~ ~ ~~ ~~ $ ~ ~~o ~oaZ ~~~p~~~~ ~3~gH1 ~~ ~t_,_~ .~ NOV 132007 ~~ JACQUELYN S. COOK, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :2007-6004 CIVIL ACTION -LAW JANSON E. DAVIS, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this ! ? ~` day of ~vc..G~ , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. Mother, Jacquelyn S. Cook shall have sole legal custody of Aidan Michael Davis, born May 25, 2007. 2. Mother shall have primary physical custody of the child. 3. Father shall have periods of partial physical custody as agreed by the parties. 4. This Order is entered pursuant to 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. BY THE COURT, ~~ cc: Dennis J. Shatto, Esquire, counsel for Janson E. Davis, pro se 109 Ross Avenue New Cumberland, PA 17070 n J. l ~.S' /)'15,.1 ~ ~ ~~ /!3 f o? ~i ,^ ~ ~~ JACQUELYN S. COOK, Plaintiff V. JANSON E. DAMS, Defendant PRIOR JUDGE: None IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2007-6004 CIVIL ACTION -LAW IN CUSTODY CUSTODY CONCILIATION SifNIMARY 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 Aidan Michael Davis May 25, 2007 Mother 2. A Conciliation Conference was held in this matter on November 13, 2007 with the following individuals in attendance: The Mother, Jacquelyn S. Cook, with her counsel, Dennis J. Shatto, Esquire. Father, although served with notice of the conference, did not appear. 3. Mother requested an Order in the form as attached. ~~-~ 3 "~7 Date / V acq ine M. Verney, Esquire Custody Conciliator