Loading...
HomeMy WebLinkAbout04-0485II JACK V. COBLE, JR., Plaintiff VS. JENNIFER CAMPLESE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. O ~- ~/~J~ ~"v'~t IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, JACK V. COBLE, JR., by his attorney, Samuel L. Andes, and makes the following Complaint for Custody: 1. The Plaintiff is JACK V. COBLE, JR., an adult individual who resides at 208 4th Street, P.O. Box 285, Summerdale, Cumberland County, Pennsylvania. 2. The Defendant is JENNIFER CAMPLESE, an adult individual who resides at 250 Glenwood Drive, Dillsburg, York County, Pennsylvania. 3. The Plaintiff and Defendant were never married but are the parents of one minor child, Katelynn A. Camplese, age 5, born 17 November 1998. 4. The child currently resides in the shared legal and physical custody of the Plaintiff and Defendant. 5. During the past five years, the minor child has resided with the following persons at the following addresses: November, 1998 to Fall, 1999 Fall, 1999, through Fall, 2000 With both Plaintiff and Defendant in Dillsburg, PA With both Plaintiff and Defendant in Dauphin, Dauphin Co., PA Fall, 2000, to the present In the shared physical custody of both Plaintiff and Defendant. When with Plaintiff, at his residence at 208 4th Street in Summerdale, PA. When with Defendant, at various locations In the Harrisburg area and, since some time in mid-2002, in Dillsburg. 6. The Plaintiff resides with his grandmother, Louree Blaine, and with the minor child at 208 4th Street in New Cumberland, Pennsylvania. 7. The Defendant resides with her mother and the child at 250 Glenwood Drive in Dillsburg, Pennsylvania. 8. The Plaintiff has not participated as a party or in any other way in any litigation concerning the custody of the child in this or any other court. The Plaintiff has no information of a custody proceeding concerning the child 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 with the said child. 9. The Plaintiff seeks an award of shared legal and physical custody of the child for the following reasons: A. Such an arrangement will continue the status quo as it has been since the parties separated three years ago; and B. Such an arrangement will afford both parents and their families reasonable time with the child; and C. Such an arrangement will allow both parents to foster and maintain a good parent-child relationship with the child; and D. Such an arrangement will allow the parties to continue the non- family social arrangements for the child, including her daycare arrangements, her friends and acquaintances, and the like. 10. 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 prays this Court to award the parties shared legal custody of the child and equally shared physical custody of the child, Katelynn A. Camp~ese, on the schedule they have enjoyed up to now. Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). JACK V. COBLE, SR., Plaintiff VS, JENNIFER CAMPLESE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-485 IN CUSTODY ACCEPTANCE OF SERVICE AND ENTRY OF APPEARANCE I hereby enter my appearance for the Defendant, Jennifer Campiese, in the above- captioned action. I acknowledge receipt of a true and correct cqpy o,f the Complaint in Custody filed in the above action on behalf of the Defendant on ~ //~/ 2004. 80457 Harrisburg, PA 17106~0457~ ~ Supreme Court ID #~ JACK V. COBLE, JR. PLA/NTIFF JENNIFER CAMPLESE DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-485 CIVIL ACTION LAW 1N CUSTODY _ORDER OF COURT AND NOW, Friday, February 13, 2004 _, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before lVIelissa p. Gree , Es~L~' the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Monday, March 15, 2004 at 1:30 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in ~ispute; 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 o/der 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, Sl~ecial Relief orders, and Custody orders to the conciliator 48 hours I)rior to scheduled hearing. FOR THE COURT~ By: /s/ Melissa P. Graav_y.a~b 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 ATFORNEY 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 JACK V. COBLE, JR., Plaintiff V. JENNIFER CAMPLESE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-485 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT / AND NOW, this ~' ~ day of March, 2004, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Leqal Custody. The parties, Jack V. Coble, Jr. and Jennifer Camplese, shall have shared legal custody of the minor child, Katelynn A. Camplese, born November 17, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of 23 Pa. C. S. {}5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. The parties shall have shared physical custody accordance with the following schedule: A. Father: Commencing March 17, 2004 on alternating weeks. B. Mother: Commencing March 24, 2004 on alternating weeks. C. The custodial exchange shall occur each Wednesday after school or daycare. Dist: on Wednesday after school or daycare. Transportation shall be provided by the parent receiving custody V~amuel L. Andes, Esquire, P.O. Box 168 Lemoyne PA 17043 vf~elly Knight, Esquire, 2320 N. Second St., Harrisburg, PA 17110 Jo in JACK V. COBLE, Jr., Plaintiff V, JENNIFER CAMPLESE, Defendant I)4AR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-485 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY 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 subiect of this litigation is as follows: NAME pATE OF BIRTH Katelynn A. Camplese November 17, 1998 CURRENTLY IN THE CUSTODY OF Mother and Father 2. A Custody Conciliation Conference was held on March 15, 2004 following Father's filing of a Complaint for Custody on February 5, 2004. Present for the conference were: the Father, Jack V. Coble, Jr., and his counsel, Samuel L. Andes, Esquire; the Mother, Jennifer Camplese, and her counsel, Kelly Knight, Esquire. 3. The parties reached an agreement in th fo~'~r~an Order as attached. ~ ~fl~liss~ Peel ~eevy, Esqu/re Custody Conciliator :225629