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Home My WebLink About09-5067 JEREMY S. W. LOPER, SR. Plaintiff vs. JAMIE L. LOPER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. c' 9 CIVIL ACTION -LAW CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Jeremy S. W. Loper, Sr., residing at 531 Bosler Avenue, Lemoyne, Pennsylvania 17043. 2. The defendant is Jamie L. Loper, residing at 324 Second Street, West Fairview, Pennsylvania 17025. 3. Plaintiff seeks custody of Amber M. Loper, born July 11, 1995, Jordan L. Loper, born March 14, 2000, and Jeremy S. W. Loper, Jr., born March 6, 2002. 4. The children were born in wedlock. The children currently reside with defendant. 5. For the past five years, the children have resided with the following persons at the following addresses: Custodian Jamie L. Loper Jeremy S. W. Loper, Sr. Jamie L. Loper Jeremy S. W. Loper, Sr. Jamie L. Loper Jeremy S. W. Loper, Sr. Jamie L. Loper Address Dates 324 Second Street 1/09 - present West Fairview, PA 17025 324 Second Street 2/08 - 1 /09 West Fairview, PA 17025 318 N. Enola Drive Fall 2006 - 2/08 Enola, PA 17025 3204 1h Street 7/04 - Fall 2006 West Fairview, PA 17025 6. The mother of the children is Jamie L. Loper, who currently resides at 324 Second Street, West Fairview, Pennsylvania 17025. She is single. 7. The father of the children is Jeremy S. W. Loper, Sr., currently residing at 1138 Laurel Avenue, Camp Hill, Pennsylvania 17011. He is single. 8. The plaintiff currently resides with his girlfriend, Karen Stevens. 9. The defendant currently resides with her boyfriend, Dennis Heck, and the three children. 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 Partial periods of physical custody to plaintiff. with his children without defendant interfering with his periods of physical custody. 14. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, plaintiff requests this Court to award him partial periods of physical custody of Amber M. Loper, Jordan L. Loper, and Jeremy S. W. Loper, Jr. Respectfully submitted, o a H. Rehkamp, Esquire J?ner and O'Connell 1 North Front Street Harrisburg, PA 17110 (717) 232-4551 The best interest and permanent welfare of the children will be served by granting Plaintiff would like to maintain a relationship JEREMY S. W. LOPER, SR. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. JAMIE L. LOPER CIVIL ACTION -LAW Defendant CUSTODY Verification 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 unworn falsification to authorities. Date: 7117 1,,57 J y S. W. Loper, Sr. _ ?' TARY 2t'" t; •? 416!5.!50 p o I%YH Cy j` 4s35 U4 aa$y ra JEREMY S. W. LOPER, SR. IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-5067 CIVIL ACTION LAW JAMIE L. LOPER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, July 29, 2009 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, August 27, 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, Esq., 11A 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 OF 11-11 2 0 0 9 J U L 29 Pil 3': 2: CUP,°!- _F JEREMY S. W. LOPER, SR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW JAMIE L. LOPER, NO. 2009-5067 Defendant IN CUSTODY COURT ORDER AND NOW, this day of Q%fi Z10 1br"Z-- -*-1 , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The father, Jeremy S. W. Loper, Sr., and the mother, Jamie L. Loper, shall enjoy shared legal custody of Amber M. Loper, born July 11, 1995, Jordan L. Loper, born March 14, 2000, and Jeremy S. W. Loper, Jr., born March 6, 2002. 2. The mother shall enjoy primary physical custody of the minor children. 3. The father shall enjoy temporary physical custody of the minor children as follows: A. During the summer months, from noon until 4:00 p.m. on Monday, noon until 4:00 p.m. on Wednesday and noon until 4:00 p.m. on Friday. B. During the school year, from 4:00 p.m. 6:00 p.m. on Monday, Wednesday and Friday. C. Every month on the first Saturday of each month from 11:00 a.m. until 6:00 p.m. 4. For the holiday schedule, the holidays shall handled with the father enjoying a Christmas vacation on December 24 from noon until 5:00 p.m., a Thanksgiving vacation every year the day before Thanksgiving from noon until 4:00 p.m., New Years Eve every year from noon until 5:00 p.m., the day before Easter every year from 1:00 p.m. until 4:00 p.m., every Labor Day from 2:00 p.m. until 5:00 p.m., every July 4 `h holiday on the day before from noon until 4:00 p.m., every Father's Day from noon until 5:00 p.m.. Mother shall have custody on the other holidays that are not specified. 5. During times of visitation with minor children by the father, father must be present with children at all times when father's girlfriend is around children. 6. This Order is entered pursuant to an agreement reached by the parties at a Custody Conciliation Conference. In the event either party desires to modify this Order and the parties cannot agree upon a modification, that party may petition the Court to have the case again scheduled before the Custody Conciliator for a Conference. cc: Johanna H. Rehkamp, Esquire ? Abraham Prozesky, Esquire Cpl? t£S eVx,aXLL JEREMY S. W. LOPER, SR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JAMIE L. LOPER, NO. 2009-5067 Defendant 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 children who are the subject of this litigation is as follows: Amber M. Loper, born July 11, 1995, Jordan L. Loper, born March 14, 2000, and Jeremy S. W. Loper, Jr., born March 6, 2002. 2. A Conciliation Conference was held on August 27, 2009, with the following individuals in attendance: The father, Jeremy S. W. Loper, Sr., who appeared with his counsel, Johanna H. Rehkamp, Esquire, and the mother, Jamie L. Loper, who appeared with her counsel, Abraham Prozesky, Esquire. 3. The parties agree to the entry of an Order in the form as attached. Date:, 2009 Hu ert X. Gilroy, quire Custody Concilia r OF THE 2PC1) SE P -3 P li' ; c,: C), J FEB Q ~ Z01U~ JEREMY S. W. LOPER, SR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNS VIA .i. vs. CIVIL ACTION -LAW JAMIE L. LOPER, NO. 2009-5067 r" Defendant IN CUSTODY +aQ COURT ORDER AND NOW, this ~~ day of February, 2010, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this Court's Order of September 3, 2009, is ratified subject to the following modifications: Father's periods of temporary physical custody with the minor children shall be during the school year on alternating weekends from Friday at 5:30 p.m. until Sunday at 5:00 p.m., unless other times are agreed upon by the parties. Additionally, during the summer months, Father shall enjoy custody of the minor children on two evenings per week from 6:00 p.m. until 9:00 p.m., with the evenings to be agreed upon by the parties subject to the Father notifying Mother at least by Sunday of each week as to when he intends to exercise the weekday visitation. 2. For exchange of custody, unless the parties agree otherwise, the non-custodial parent shall pick up the children. Father shall pick the children up at Mother's sister's residence, and Mother shall pick the children up at Father's residence. 3. For the holidays including Thanksgiving, Christmas, New Year's Day, Easter, Memorial Day and Labor Day, the holidays shall be split between the parties with the Mother having 9:00 a.m. until 3:00 p.m. and Father having 3:00 p.m. unti19:00 p.m. on those holidays. For the July 4`~ holiday, the same schedule shall apply except it shall be alternated each year to ensure that Mother can take the children to the fireworks on the evening of July 4`h. For the holiday exchange of custody, exchange shall take place on City Island as the parties have done in the past unless the parties agree otherwise. 4. Both parents shall keep the other parent advised with respect to their mailing addresses and also with respect to phone numbers where they may be contacted in the event of an emergency. BY THE COURT, J" ~ ge cc: "J anna H. Rehkamp, Es uire q s. Jamie L. Loper et~~ ~'~ rnat~sc.L. a/~c~~ ~•'~ JEREMY S. W. LOPER, SR., Plaintiff vs. JAMIE L. LOPER, Defendant Prior Judge: The Honorable Edgar B. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO, 2009-5067 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 children who are the subject of this litigation is as follows: Amber M. Loper, born July 11, 1995 Jordan L. Loper, born March 14, 2000 Jeremy S. W. Loper, Jr., born March 6, 2002 2. A Conciliation Conference was held on January 29, 2010, with the following individuals in attendance: the father, Jeremy S. W. Loper, Sr., with his counsel, Johanna H. Rehkamp, Esquire, and the mother, Jamie L. Loper, who appeared without counsel. 3. The parties agreed to the entry of an Order in the form as attached. Date: February I , 2010 Hubert X. Gilroy, quire Custody Concili or