Loading...
HomeMy WebLinkAbout09-17309. The defendant currently resides alone. 10. 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. 11. The plaintiff has no information of a custody proceeding concerning the child pending in a court in this Commonwealth or in any other court. 12. 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. 13. The best interest and permanent welfare of the child will be served by granting the relief requested. 14. 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 requests this Court to award her primary physical custody of Samantha N. Jackson. J H. Rehkanip, Esquire JUOER AND O'CONNELL 70 orth Front Street 'sburg, PA 17110 (717) 232-4551 Veriiftation I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Date: 3 /7-01 April C. Maser ?ca w tri t .. .. ra c.D lS3 -c3 -? C i"S L APRIL C. MASER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. CHAD MICHAEL JACKSON DEFENDANT 2009-1730 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Wednesday, March 25, 2009 , upon consideration of the attached Complaint, it is hereby directed that panes and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, May 01, 2009 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, 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 low Av MAY 12 ZON 6. ?? APRIL C. MASER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW CHAD MICHAEL JACKSON, NO. 2009-1730 Defendant IN CUSTODY COURT ORDER AND NOW, this ?S day of flat -- , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Court Room No. of the Cumberland County Courthouse on the a? day of , 2009 at G'f CV Am. At this hearing, the mother shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least ten days prior to the mentioned hearing date. 2. Pending further order of this court, the following TEMPORARY custody order is entered: A. The mother, April C. Maser, and the father, Chad Michael Jackson, shall enjoy shared legal custody of Samantha N. Jackson, born March 12, 2000. B. During the school year, father shall have primary physical custody with mother having periods of temporary physical custody on alternating weekends and on Wednesday evenings consistent with the schedule the parties have implemented in the past. C. When school is finished, mother shall enjoy primary physical custody during the summer time with father having periods of temporary physical custody on alternating weekends and on the one evening per week consistent with what the parties have done in the past. BY THE COURT, Judge cc: ohanna H. Rehkamp, Esquire ,--tan Kay Candiello, Esquire f 1. l1tl,{"ItUSI ? 1 .t i4 ?:. -r APRIL C. MASER, Plaintiff vs. CHAD MICHAEL JACKSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2009-1730 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: The pertinent information pertaining to the child who is the subject of this litigation is as follows: Samantha N. Jackson, born March 12, 2000. 2. A Conciliation Conference was held on May 8, 2009, with the following individuals in attendance: The mother, April C. Maser, who appeared with her counsel, Johanna H. Rehkamp, Esquire, and the father, Chad Michael Jackson, with his counsel, Susan J. Candiello, Esquire. There is no existing custody order. The father has enjoyed primary physical custody of the minor child over the past few years. Mother is now seeking primary custody and the parties are unable to reach an agreement. A hearing is required and the conciliator recommends an interim custody Order that is consistent with the status quo on custody over the past year or so. Date: May -L, 2009 V(/ Hubert X. ilroy, Esquire Custody onciliator 5 APRIL C. MASER, IN THE COURT OF COMMON PLEAS PLAINTIFF OF CUMBERLAND COUNTY, :PENNSYLVANIA vs. N0.2009-1730 CIVIL TERM CHAD MICHAEL JACKSON, :CIVIL ACTION -LAW DEFENDANT :ACTION FOR CUSTODY ORDER AND NOW, this _~ day of October, 2009, an order of custody is hereby entered pursuant to the parties' stipulation dated October 8, 2009. By the Court: '~-- ~L~~;~-~:~ri~~E ~,~ T~-fig ~,~.,~. ~., , .,,;^Tt;RY ,~„ .. 2009 GAT l 4 F~~ 2~ 59 a ~~~~ ,off! ~ f~~ - ~~, ~ S ,~~. < <~~ ,~.~ f . 2~4.~~ ~.t, s. ~~~~.c(~