HomeMy WebLinkAbout08-5013
JOSHUA S. JUMPER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2008 -Q 3 CIVIL TERM
MELISSA J. SMITH, CIVIL ACTION-LAW
Defendant
CUSTODY COMPLAINT
1. Plaintiff is Joshua J. Jumper, an adult individual who currently resides at
221 Pine Grove Road, Gardners, Cumberland County, Pennsylvania.
2. Defendant is Melissa J. Smith, an adult individual who currently resides at
768A Lewisberry Road, Lewisberry, York County, Pennsylvania.
3. The parties are the parents one minor children, namely, Colton S. Jumper,
born July 6, 2000, age 8.
The child was born out of wedlock.
The child is presently in the custody of Plaintiff at 768A Lewisberry Road,
Lewisberry, York County, Pennsylvania.
During the past four years, the child has resided with the following
persons at the following addresses:
Persons Residences Dates
Melissa J. Smith 768A Lewisberry Road 2004 to
Matthew Fine Lewisberry, Pennsylvania 17339 Present
Amber Barrick
Darien Fine
The natural mother of the child is Melissa J. Smith, currently residing at
768A Lewisberry Road, Lewisberry, York County, Pennsylvania.
She is not married.
The natural father of the child is Joshua S. Jumper, currently residing at
221 Pine Grove Road, Gardners, Cumberland County, Pennsylvania.
He is not married.
4. The relationship of the Plaintiff to the child is that of natural father. The
Plaintiff currently resides with the following persons:
Names
Randy Shull
Brenda Shull
Relationship
Friend
Friend
5. The relationship of the Defendant to the child is that of natural mother.
The Defendant currently resides with the following persons:
Names Relationship
Matthew Fine Boyfriend
Colton S. Jumper Son
Amber Barrick Daughter
Darien Fine Son
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 Plaintiff primary physical custody and the parties shared legal custody.
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. All other persons, named below, who are known to have or claim a right to
custody or visitation of the child will be given notice of the pendency of this action and
the right to intervene: none
WHEREFORE, Plaintiff requests your Honorable Court to grant him shared legal
and primary physical custody of the child.
Respectfully submitted,
Date: 3' 19 0
O'BRIEN, BARIC & SCHERER
Michael A. Scherer, Esquire
1. D. # 61974
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
Attorney for Plaintiff
,
VERIFICATION
I verify that the statements made in the foregoing 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: ho Joshua Ju per
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JOSHUA S. JUMPER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
2008-5013 CIVIL ACTION LAW
MELISSA J. SMITH IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Wednesday, August 27, 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 Thursday, September 18, 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 Custody 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
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