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HomeMy WebLinkAbout08-6811HEATHER RAISIG, vs. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA JESSE HEAD, and NATHAN FUREMAN, Defendants No. Qa'_ ? r // Civil Term IN CUSTODY CUSTODY COMPLAINT 1. Plaintiff is Heather Raisig, (hereinafter referred to as "Grandmother'), who currently resides at 811 Factory Street, Carlisle, Pennsylvania, 17013. 2. Defendant Jesse Head, (hereinafter referred to as "Mother'), has a current address of 170 Virginia Ave., Carlisle, Pa. 17013. Nathan Fureman, (hereinafter referred to as "Father"), lives in Texas. His exact address is currently unknown. 3. Plaintiff is the Maternal Grandmother of the following child and seeks a custody order regarding the following child: NAME DOB/AGE ADDRESS Travis Fureman 2/12/07 (1) 811 Factory Street Carlisle, Pa. 17013 Maternal Grandmother currently has physical custody and stands in loco parentis to the child. During the past five years, the child has resided with the following persons and at the following addresses: NAME ADDRESSES Heather Yohe 811 Factory St. E.J. Yohe (son) Carlisle, Pa. 17013 Jaime Cunningham (daughter) Brian Cook (son) Jesse Head DATES Birth - Dec. `07 Jesse Head Fox Mount Pleasant, Pa Nicholas Fox Heather Yohe 811 Factory St. E.J. Yohe (son) Carlisle, Pa. 17013 Jaime Cunningham (daughter) Brian Cook (son) Jesse Head Fox Jesse Head Fox Spring Road, Pa. 17013 and friend Jesse Head Fox 170 Virginia Ave. And friend Mike Carlisle, Pa. 17013 Heather Yohe 811 Factory St. E.J. Yohe (son) Carlisle, Pa. 17013 Jaime Cunningham (daughter) Brian Cook (son) Dec. '07 - May '08. May '08 - Aug. '08 Aug. '08 - Sept. '08 Sept. '08 - Oct. '08 Oct., '08 - present The mother of the child is Jesse Head. She currently resides at 170 Virginia Avenue, Carlisle, Pa. 17013. She is married to Nicholas Fox. The father of the child is Nathan Fureman. He lives in Texas. 4. The relationship of plaintiff to the child is that of Maternal Grandmother. The plaintiff currently resides with the child and her other children, E.J. Yohe, Jaime Cunningham and Brian Cook. 5. The relationship of defendant Nathan Fureman to the child is that of Father. It is unknown who the defendant lives with. The relationship of defendant Jesse Head is that of Mother. Mother currently lives with her boyfriend. 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 and the child have lived in Grandmother's home during various periods since the child was born. Grandmother has had an integral part in providing for the child's care. Mother is currently undergoing some difficulties during which she is unable to care for the child. Father is in Texas and has not been involved in the child's care. Grandmother is requesting a formal custody Order which would provide her with shared physical and legal custody. This request would be in the best interest of the child because it would provide safety and stability 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 has been named as parties to this action. WHEREFORE, Plaintiff requests the court to enter a custody order regarding the child. Respectfully submitted, Date: 09 e Adams, Esquire 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: Heather Raisig, Plaintiff 6 r- N Q Fri ?,, w _=-4 HEATHER RAISIG IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JESSE HEAD AND NATHAN FUREMAN DEFENDANT 2008-6811 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, November 21, 2008 , 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 Monday, December 22, 2008 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 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/ j acqueline M. Verney, 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 FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ?? " ;?' ?/ U? 37 DEC 2 2 2008 HEATHER RAISIG, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-6811 CIVIL ACTION - LAW JESSE HEAD and NATHAN FUREMAN : IN CUSTODY Defendants TEMPORARY ORDER OF COURT AND NOW, this 7i day of , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Maternal grandmother, Heather Raisig, and Mother, Jesse Head, shall have shared legal custody of Travis Fureman, born February 12, 2007. Each party shall have an equal right, to be exercised jointly with the other party, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each party 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 the other party. To the extent one party has possession of any such records or information, that party shall be required to share the same, or copies thereof, with the other party within such reasonable time as to make the records and information of reasonable use to the other party. Both parties shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each party shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parties including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each party shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to- school nights, and the like. 2. Maternal Grandmother shall have primary physical custody of the child. 3. Mother shall have periods of supervised visitation of the child 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. Either parent may contact the Custody Conciliator and request another Conciliation Conference within ninety days of this Order. -11 cc: ane Adams, Esquire, Counsel for? -/Jesse Head, pro se c/o Heather Raisig 811 Factory Street / Carlisle, PA 17013 V/ Nathan Fureman, pro se P.O. Box 8641 Amarillo, TX 79114 c"f f5 3Ib? ?.. cry tiS C-D w (".; ? ;mot 6 HEATHER RAISIG, Plaintiff V. JESSE HEAD and NATHAN FUREMAN Defendants PRIOR JUDGE: None 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 subject of this litigation is as follows: NAME Travis Fureman : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-6811 CIVIL ACTION - LAW IN CUSTODY DATE OF BIRTH CURRENTLY IN CUSTODY OF February 12, 2007 maternal grandmother 2. A Conciliation Conference was held in this matter on December 22, 2008, with the following in attendance: The maternal Grandmother, Heather Raisig, with her counsel, Jane Adams, Esquire. Mother, Jesse Head, was aware of the conference, but did not attend. Father address was unknown prior to the hearing, but he had not had contact with the child for a long time. 3. Maternal Grandmother requested an Order in the form as attached. Date acq line M. Verney, Esquire Custody Conciliator Ff HEATHER RAISIG, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-6811 CIVIL ACTION - LAW JESSE HEAD and NATHAN FUREMAN, : IN CUSTODY Defendants ORDER OF COURT AND NOW, this 14th day of September, 2009, neither party having requested another conciliation conference and ninety days having passed since the last conference, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, Acq ine M. Verney, Esquire, Custo Conciliator 'FILE ?.i..} r. OF THE P' C a.-:^,;", ,'WARY 2009 SEA' 15 hi I