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HomeMy WebLinkAbout08-3393JARREAU DODSON, Plaintiff vs. JENNIFER BARRICK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 0g - 3 393 Civil Term ACTION IN CUSTODY CUSTODY COMPLAINT 1. Plaintiff is Jarreau Dodson, who currently resides at 245 W. North St., Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Jennifer Barrick, who lives at 119 Mills Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff is the Father of the following child and seeks a custody order regarding the following child: NAME DOB/AGE ADDRESS Julyan Alexander Dodson 6/21/2005 119 Mills Drive, Carlisle, Pa. 17013 Mother and Father are not married. Mother currently has primary physical custody of the child. During the past five years, the child has resided with the following persons and at the following addresses: NAME ADDRESSES DATES Jennifer Barrick 119 Mills Drive birth to present Carlisle, Pa. 17013 The mother of the child is Jennifer Barrick. She currently resides at 119 Mills Drive, Carlisle, Pennsylvania. She is not married. The father of the child is Jarreau Dodson. He currently resides at 245 W. North St., Carlisle, Cumberland County, Pennsylvania. He is not married. 4. The relationship of plaintiff to the child is that of Father. The plaintiff currently resides with his girlfriend and their son London Dodson, age 2. 5. The relationship of defendant to the child is that of Mother. The defendant currently lives with the child and her other child, Jaidan Barrick, age 5. 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 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: Mother currently has primary physical custody of the child and Father has had periods of partial custody. Father is seeking a court order which confirms his periods of partial custody. This request is the in the best interest of the child because it would provide stability for the child and ample contact with both parents 8. 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. WHEREFORE, Plaintiff requests the court to enter a custody order regarding the child. Respectfully submitted, Date: 5 36 6?r d9fie Adams, Esquire YD. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statements made in this Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: 300 Jarr u odson, Plaintiff 4"% Tr) +r?` • 4) -J t ? ?T k JARREAU DODSON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JENNIFER BARRICK DEFENDANT 2008-3393 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Thursday, June 05, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, July 11, 2008 at 9:30 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. 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy, Es q. 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 g ?l1Nf?1^ 9C :Z wd 5- Knr BOOZ Adviot` ORI ''' 34130 301i"D;lj AUG 1 1 20084 JARREAU DODSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW JENNIFER BARRICK, NO. 2008-3393 Defendant IN CUSTODY COURT ORDER AND NOW, this ( 2- ?A day of August, 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The father, Jarreau Dodson, and the mother, Jennifer Barrick, shall enjoy shared legal custody of Julyan Alexander Dodson, born June 21, 2005. 2. The Mother shall enjoy primary physical custody of the minor child. 3. The Father shall enjoy temporary physical custody of the minor child as follows: A. Working on the first eight weeks of the Father's work schedule where he is off work, the schedule shall be as follows: (1) For the first week being August 7", the Father shall have temporary custody during the day from noon until 8:30 p.m.; (2) On the second week when the Father is off work on two days he shall have custody from noon until 8:30 p.m.; (3) On the third week when Father has his days off on a weekend, he shall have custody from noon on the first day he is off thru 8:30 p.m. on the second day which shall include an overnight; (4) On the fourth week when Father is again off on the weekend, he shall have custody from noon on the first day he is off thru 8:30 p.m. on the second day which shall include an overnight; (5) On the fifth week when Father is off during the week, he shall have custody during the day from noon until 8:30 p.m.; and VINVAIASNN3d I :Z lid Z I OnV 80OZ Atid1Cd 3Hi JO (6) On the sixth, seventh and eighth weeks when the Father is off during the week, he shall have custody from noon on the first day he is off thru 8:30 p.m. on the second day which shall include an overnight for those days. 4. Legal counsel for the parties shall conduct a telephone conference call with the Custody Conciliator on Thursday, November 6, 2008, at 8:00 a.m. At this conference call and assuming things are progressing smoothly between the parties with respect to custody, it is anticipated that a permanent Order will be entered that would allow Father two overnights on weekends and continuing a standard one overnight on weekdays when he is off work. 5. In the event there are any issues that the Conciliator needs to address in advance of the conference scheduled above, legal counsel for the parties may contact the Conciliator directly to request an emergency telephone conference. 6. The parties may modify or alter the custody schedule set forth above as they agree. Absent an agreement, the parties shall follow the above custody schedule. cc: /aane Adams, Esquire ,,,Michael A. Scherer, Esquire BY THE COURT, JARREAU DODSON, Plaintiff vs. JENNIFER BARRICK, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2008-3393 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Julyan Alexander Dodson, born June 21, 2005 2. A Conciliation Conference was held on August 7, 2008, with the following individuals in attendance: The mother, Jennifer Barrick, who appeared with her counsel, Michael A. Scherer, Esquire, and the father, Jarreau Dodson, with his counsel, Jane Adams, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. Date: August, 2008 oy, Esquire Hubert XYnciliator Custody JAN 21 2009 JARREAU DODSON, Plaintiff VS. JENNIFER BARRICK, Defendant PRIOR JUDGE: J. Wesley Oler IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2008-3393 IN CUSTODY COURT ORDER AND NOW, this Zt day of January, 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this Court's prior Order of August 12, 2008, is vacated and replaced with the following Order: The father, Jarreau Dodson, and the mother, Jennifer Barrick, shall enjoy shared legal custody of Julyan Alexander Dodson, born June 2, 2005. 2. The mother shall enjoy primary physical custody of the minor child. 3. The father shall enjoy periods of temporary physical custody of the minor child as follows: A. When father is off work, for two overnights on the weekends consistent with the schedule the parties have been implementing. B. During the week when father is off work for two evenings starting on the first day of work at Noon for two overnights with the father delivering the child to daycare after the second overnight. C. At such other times as the parties agree. 4. This Order is entered pursuant to an agreement reached by the parties at a Custody Conciliation Conference. In the event the parties desire to modify this Order, they may petition the Court to have the case again scheduled with the Conciliator. cc: ? Jane Adams, Esquire ,Michael A. Scherer, Esquire 0-6p t:ES l?2.4(d4 ?.? ;- y(°a ?. -- .. ? , ; ?- ... ?, 1... G ? ` , ? ??;; ? ; , t-- ?., N ? 10 JARREAU DODSON, Plaintiff vs. JENNIFER BARRICK, Defendant PRIOR JUDGE: J. Wesley Oler IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-3393 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Julyan Alexander Dodson, born June 21, 2005 2. A Conciliation Conference was held on January 23, 2009, with the following individuals in attendance: The father, Jarreau Dodson, who appeared with his counsel, Jane Adams, Esquire, and the mother, Jennifer Barrick, with her counsel, Michael A. Scherer, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. Date: January ;? G , 2009 Hubert X. Gilroy, Custody Concilip