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HomeMy WebLinkAbout08-7459 KENNIE M. JAMISON, JR., Plaintiff V. ANGEL LASH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODYNISITATION : NO. 08- -7y,?2 CIVIL TERM COMPLAINT FOR CUSTODY 1. The Plaintiff is Kennie M. Jamison, Jr., residing at 810 Fairview Rd., Carlisle, Pennsylvania 17013. 2. The Defendant is Angel Lash, residing at 810 Fairview Rd., Carlisle, Pennsylvania 17013. 3. Plaintiff seeks custody of the following children: NAME RESIDENCE Kaplyn J. Jamison 810 Fairview Rd., Carlisle, PA 17013 4. The child was born out of wedlock. DOB AGE 06/09106 2yrs 5mths 5. The child is presently in the custody of Kennie M. Jamison, Jr. and Angel Lash (Mother and Father). 6. During his life, the child has resided with the following persons and at the following addresses: NAME ADDRESS DATES Angel Lash, Kennie M. Jamison, 810 Fairview Rd., Carlisle, PA 17013- 0612008-Current Kennie Allen Jamison, Kristopher Ryan Jamison, Zachary Gohn, Kaitlyn Kiner Angel Lash, Kennie M. Jamison, 3789 Spring Rd., Carlisle, PA 17013 06109106- 0612008 Kennie Allen Jamison, Kristopher Ryan Jamison, Zachary Gohn, Kaitlyn Kiner 7. The mother of the child is Angel Lash, currently residing at 810 Fairview Rd., Carlisle, Pennsylvania 17013. She is unmarried. 8. The father of the child is Kennie M. Jamison, Jr., currently residing at 810 Fairview Rd., Carlisle, Pennsylvania 17013. He is unmarried. 9. The relationship of the Plaintiff to the child is that of Father. The Plaintiff currently resides with the following persons: Kennie Allen Jamison, Kristopher Ryan Jamison, Kaplyn Jamison, Zachary Gohn, and Kaitlyn Kiner 10. The relationship of the Defendant to the child is that of Mother. The Defendant currently resides with the following persons: Kennie Allen Jamison, Kristopher Ryan Jamison, Kaplyn Jamison, Zachary Gohn, and Kaitlyn Kiner 11. 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. 12. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. 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. 14. The best interest and permanent welfare of the child would be served by granting the relief requested for the following reasons: A. Plaintiff has undertaken and performed the primary parental responsibilities for the child; and B. Plaintiff is best able to provide the care and nurture which the child needs for healthy development; and C. Plaintiff desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the child. D. Defendant is erratic and abusive behavior poses a threat of harm to the child. E. Defendant is pregnant and expecting another child. F. Defendant has threatened to move out and take child with her. 15. 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 grant custody of the child to Plaintiff subject to structured partial custody by the Defendant pending the hearing. Additionally, pending the scheduling of a hearing, neither party shall remove the child from the child's existing household with a residential address of 810 Fairview Rd., Carlisle, PA 17013, without further Order of Court. Respectfully submitted, By: Paul Bradford Orr, Esquire Attorney for Plaintiff 50 East High Street Carlisle, PA 17013 Telephone: (717) 258-8558 Supreme Court ID No. 71786 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: 2- A3 O 8 Kennie M. Jamison, Jr., P i ' ner r?-? ?? ? -? < ""t ? i"?'3 ; ?l ? ? . w_ 1: , ?. - Z-t. N . { a. ?.,. '_ ('?e._ ?+ _ ? Z ? \ . KENNIE M. JAMISON, JR. IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ANGEL LASH DEFENDANT 2008-7459 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Wednesday, December 31, 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, January, 29, 2009 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 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 Irv/ - , f ' j KENNIE M. JAMISON, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW CUSTODYNISITATION ANGEL LASH, Defendant : NO. 08-7459 CIVIL TERM AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) AND NOW, this 5th day of January, 2009, I, Paul Bradford Orr, attorney for Kennie M. Jamison, Jr., Plaintiff, in the above-captioned action, hereby swear that I have served a true copy of the Custody Complaint, executed by the Plaintiff in the above-captioned matter, upon the Defendant by depositing the same in the U.S. Mail, postage prepaid, certified, return receipt requested. The original return receipt card signed by Angel D. Lash on January 2, 2009, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. Dated: Q? LAW OFF S OF P By: Paul Bradford Orr, Esquire Attorney for Plaintiff 50 East High Street Carlisle, PA 17013 (717) 258-8558 Supreme I.D. #71786 ORR jr ¦ Complete items 1, 2, and 3.'Also complete Item 4 H Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the hack of the mailpiece, or on the front if space permits. 1. Article Addressed to: A. (Pffrrtea Npw) I C. D. Is eleilvery address different from item 17113 If YE% enter delivery address below: jj Agent Lwh 3. Service Type 1 IV i 3 ? Certltied Malt 0 Express Mall Return Receipt for Merdtarrclise ? Insured Mail C.Q.D. 4. Restrictad Delivery? Xxba Fee) Dbes 2. Article Number 7003 3110 0004 5773 6814 R?« ? s +1 PS Form 3811, February 2004 Domestic Rdurn ReoNpt 102595-02-M-1640 EXHIBIT "A" ._, ": C., - ,?.z `?'? ?,,+' m_ . c c cs? ?? ;?_ ==?; :? ?, ..? .- JUN U [(ltly KENNIE M. JAMISON, JR., Plaintiff v ANGEL LASH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-7459 IN CUSTODY ORDER k4 AND NOW, this reached an agreement, the Conciliator relinquishes jurisdiction. day of May, 2009, the Conciliator being advised the parties have Hubert X. GXoy, Esquire Custody Conciliator ; 2G09 JUN -3 PH 2: f?"-