HomeMy WebLinkAbout04-2504MICHELLE LYNN McLAUGHLIN,
Plaintiff
Defendant
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
JASON BRADY JUMPER,
IN THE COURT OF COMMON PLEAS OF
NO.04- 2YOLI CIVILTERM
CUSTODY
COMPLAINT FOR CUSTODY
1. The plaintiff is Michelle Lynn McLaughlin, hereinafter referred to as "mother".
Plaintiff's permanent residence is 202 Gull Court, Mechanicsburg, Cumberland County,
Pennsylvania, 17055.
2. The defendant is Jason Brady Jumper, residing at 3 Dranoel Drive, Carlisle,
Cumberland County, Pennsylvania 17013.
3. The mother seeks custody of the minor child:
Name
Christian McLaughlin
Present Residence
believed to be residing at
3 Dranoel Drive
Carlisle, PA 17013
The child, Christian McLaughlin, was born out of wedlock.
Age
2/17/04 DOB, 3 months old
The child is presently in the custody of the defendant, who resides at 3 Dranoel Drive,
Carlisle, PA 17013.
During the child's lifetime, he has resided with the following persons and at the
following addresses:
Name
Address
Michelle Lynn McLaughlin 202 Gull Court
Jason Heckendom Mechanicsburg, PA 17055
Jason Brady Jumper 3 Dranoel Drive
Carlisle, PA 17013
Date
Birth to 5/21/04
5/21/04 to present
The mother of the child is Michelle McLaughlin, currently residing at 202 Gull Court,
Mechanicsburg, Pennsylvania 17055.
She is single.
The defendant is Jason Jumper, currently residing at 3 Dranoel, Carlisle, PA 17013
He is single.
4. The relationship of plaintiff to the child is that of mother.
The mother currently resides with the following persons:
Name
Michelle Lynn McLaughlin
Jason Heckendorn
Kari McLaughlin
Relationship
Self
Boyfriend
Plaintiff's daughter (alternate wknds)
5. The defendant has denied paternity of the child and has demanded a paternity test, but
it is believed and alleged by the mother that the defendant is the biological father of the minor
child.
It is believed that the defendant currently resides with the following persons:
Name
Jason Brady Jumper
Christian McLaughlin
Relationship
Self
Son with Plaintiff
6. The mother 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.
7. The mother has no information of a custody proceeding concerning the child pending
in a court of this Commonwealth.
8. The mother 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 children.
9. The best interest and permanent welfare of the child will be served by granting the
relief requested for reasons including, but not limited to the following:
a) The mother has provided for the child's emotional, physical, educational, and
medical needs since birth, including establishing a stable home environment
for child, and she can continue to provide for the child.
b) The mother's current boyfriend, Jason Heckendorn, has been with her since
Christian was born and has cared for Christian as his own. He is willing and
prepared to continue to contribute to Christian's well being and provide a
healthy environment in which to raise a child.
c) The mother is the parent who can best facilitate any interaction between the
child and the defendant.
d) The defendant has not acted in the best interest of the child in ways including
but not limited to the following:
i) The defendant has denied paternity of the child and has demanded
a paternity test through the Domestic Relations Office.
ii) Until the mother filed for child support, the defendant had liberal
periods of partial custody with the child and had never been denied
access to the child. When the mother filed for child support, the
defendant took the child from the mother on May 21, 2004, for the
scheduled weekend visit and then refused to return the child to her.
iii) The defendant refuses to allow the mother to see the child, refuses
telephone access to the child, and refuses to provide the mother
with information as to who is caring for the child while the
defendant is working during the day. This leaves the mother with
no knowledge as to whether the child is receiving the care that is
necessary and appropriate for a three-month old infant.
iv) The child has a doctor's appointment at the end of the month and
the defendant is unaware of this appointment because he has not
participated in a single medical appointment for the child.
V) The defendant was not present for the child's birth and did not
attempt to visit the child until after the mother and child were
released from the hospital.
vi) The defendant's arbitrary exercise of partial custody with the child
is not healthy and creates instability for the child.
vii) The mother fears that without a Court Order in place, the defendant
will not return the child to her and will continue to hide the child
from her.
10. 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, the plaintiff requests this Court:
a) Grant her primary physical and legal custody of the child.
b) Grant the defendant periods of partial custody on alternating weekends
from Friday 7:00 p.m. until Sunday at 7:00 p.m.
c) Any additional relief the Court finds just and proper.
Respectfully
Jessica iamondstone
Attorney for Plaintiff
Mid Penn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
VERIFICATION
The above-named PLAINTIFF, Michelle Lynn McLaughlin,
verifies that the statements made in the above Complaint For
custody are true and correct. Plaintiff understands that false
statements herein are made subject to the penalties of 18 Pa.
C.S. §4904, relating to unsworn falsification to authorities.
Date: A/MJc'Laugh?
MICHELLE LYNN McLAUGHLIN,
Plaintiff
VS.
JASON BRADY JUMPER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04- CIVIL TERM
CUSTODY
AFFIDAVIT OF SERVICE BY MAIL
I, Jessica Diamondstone, do hereby swear that I served Jason Brady Jumper with a
Complaint For Custody on '41' - 2004 by certified mail, return receipt, restricted
delivery, to the person and a dress below:
Jason Brady Jumper
3 Dranoel Drive
Carlisle, PA 17013
I, Jessica Diamondstone, verify that the statements made in this Affidavit of Service are
true and correct. I understand that false statements herein are made subject to the penalties of 18
Pa.C.S. Section 4904 relating to unswom falsification to authorities.
Date: 6- 3 - Coq Signature:
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MICHELLE LYNN McLAUGHLIN,
Plaintiff
VS.
JASON BRADY JUMPER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04- SOY CIVIL TERM
CUSTODY
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Michelle Lynn McLaughlin, Plaintiff, to proceed in forma au eris.
I, Jessica Diamondstone, attorney for the party proceeding in forma au eris, certify that
I believe the party is unable to pay the costs and that I am providing free legal services to the
party.
Jessica amondstone
Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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MICHELLE LYNN MCLAUGHLIN : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA
VS.
No. 04-Z-OCIVU, TERM
JASON BRADY JUMPER
Defendant IN CUSTODY
PETITION FOR SPECIAL RELIEF
Petitioner, Michelle McLaughlin, by and through her counsel, Jessica
Diamondstone of MidPenn Legal Services, states the following:
1. Petitioner is the above-named Plaintiff, hereinafter referred to as the mother, who
resides at 202 Gull Court, Mechanicsburg, Cumberland County, Pennsylvania
17055.
2. Defendant resides at 3 Dranoel Drive, Carlisle, Cumberland County, Pennsylvania
17013.
3. The above-named Petitioner is the natural mother of Christian McLaughlin, born
February 17, 2004.
4. The Defendant has denied paternity and demanded a paternity test through the
Domestic Relations Office.
5. The mother resides with Jason Heckendom and the child.
6. The defendant had liberal periods of partial custody with the child until May 21,
2004, when he took the child for a weekend and refused to return the child to the
mother.
7. The defendant is not acting in the child's best interest for reasons including, but
not limited to, the following:
a. The defendant took the child from the mother on May 21, 2004, for a
scheduled weekend visit and then refused to return the child in retaliation
for the mother's decision to file for child support against the defendant.
b. The defendant refuses to provide the mother with information as to who is
caring for the child while the defendant is working
c. The mother has no knowledge as to whether the child is receiving
appropriate daycare for a three-month-old infant.
d. The child has a doctor's appointment at the end of June 2004. The father
is not aware of this appointment because he has refused to participate in
any of the medical appointments for the child.
e. The defendant was not present for the child's birth and did not attempt to
see the child until the day after the mother's and child's release from the
hospital.
f. The mother does not know if defendant has the appropriate items needed
to care for a three-month old infant, including an age appropriate child car
seat, a crib, a walker or stroller, and items of clothing.
8. The mother is the parent who can best provide for the child for reasons including,
but not limited to, the following:
a. The mother is presently able to provide for the child by giving the child a
nurturing and stable home environment and providing for his emotional,
physical, medical and educational needs.
b. Since the child's birth, the mother is the person who has primarily
provided for the daily needs of the child and is the person most capable of
caring for the needs of a three-month-old infant.
c. The mother can best facilitate and maintain any contact between the child
and the defendant.
9. Without this Court's intervention, the mother and child are at risk of irreparable
harm by being denied contact with each other.
10. Plaintiff is not aware that the father has legal counsel and, therefore, cannot
attempt to contact her/him to obtain a concurrence for the relief requested.
WHEREFORE, Petitioner respectfully requests the following:
a. That the Court order the defendant to immediately return the child to the
mother.
b. That the Court grant her primary legal and physical custody of the child.
c. That the Court grant the defendant periods of partial custody on
alternating weekends from Friday at 7:00 p.m. until Sunday at 7:00 p.m.
d. Petitioner also requests any other relief this court deems just and proper.
Respectfully submitted,
Jessie iamondstone
Attorney for Plaintiff/ Petitioner
MidPenn Legal Services
8 Irving Row
Carlisle, PA 17013
VERIFICATION
The above-named PLAINTIFF, Michelle Lynn McLaughlin,
verifies that the statements made in the above complaint For
Custody are true and correct. Plaintiff understands that false
statements herein are made subject to the penalties of 18 Pa.
C.S. §4904, relating to unsworn falsification to authorities.
Date: //l?C`l111/ / // L '
Michelle Lyn McLaug?in
MICHELLE LYNN McLAUGHLIN,
PENNSYLVANIA
vs.
JASON BRADY JUMPER,
Plaintiff
Defendant
: IN THE COURT OF COMMON PLEAS
OF
CUMBERLAND COUNTY,
NO. 04- :ZSV?j CIVIL TERM
CUSTODY
AFFIDAVIT OF SERVICE BY MAIL
I, Jessica Diamondstone, do hereby swear that I served Jason Brady Jumper
with a Complaint For Custody on 4ke 3 , 2004 by certified mail, return
receipt, restricted delivery, to the person and address below:
Jason Brady Jumper
3 Dranoel Drive
Carlisle, PA 17013
I, Jessica Diamondstone, verify that the statements made in this Affidavit of
Service are true and correct. I understand that false statements herein are made subject to
the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities.
Date: (") - 3 " C) V Signature: ?._.
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JUN 0 4 2004 \V
MICHELLE LYNN McLAUGHLIN, IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
vs. : NO. 04- )-YOL1 CIVIL TERM
JASON BRADY JUMPER,
Defendant : CUSTODY
ORDER OF COUR
AND NOW, this 2#day of v All J40
upon consideration of the Petition For Special
Relief, tbo n ..,:„s -?': ;?.. f? ?.i.?'??.?n .Ls Y'?-?•. JQ+-+?
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Distribution:
Jessica Diamondstone, Esquire; MidPenn Legal services, 8 Irvine Row; Carlisle, PA
Jason Brady Jumper, pro se; 3 Dranoel Drive; Carlisle, PA 17013
17013
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MICHELLE LYNN MCLAUGHLIN IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. 04-2504 CIVIL ACTION LAW
JASON BRADY JUMPER IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Wednesday June 09, 2004 , 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 Tuesday, June 29, 2004 at 8:30 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. All children age five or older may also be present at the conference. 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/ Jacqueline M Verney, Esq. mnc
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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MICHELLE LYNN McLAUGHLIN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
JASON BRADY JUMPER, NO. 04-2504 CIVIL TERM
Defendant CUSTODY
ORDER OF COURT
AND NOW, this 11th day of June, 2004, this Court
adopts the parties' agreement as an Order of Court. They are
directed to comply therewith.
Grace D'Alo, Esquire
For the Plaintiff
Kara W. Haggerty, Esquire
For the Defendant
By the Cou
Edward E. Guido, J.
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MICHELLE LYNN MCLAUGHLIN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
JASON BRADY JUMPER, NO. 04-2504 CIVIL TERM
Defendant CUSTODY
TRANSCRIPT OF PROCEEDINGS
IN RE: AGREEMENT
Proceedings held before the
HONORABLE EDWARD E. GUIDO, J.
Cumberland County Courthouse, Carlisle, Pennsylvania
on Friday, June 11, 2004,
in Courtroom No. 5
APPEARANCES:
GRACE D'ALO, Esquire
For the Plaintiff
KARA W. HAGGERTY, Esquire
For the Defendant
1
1 THE COURT: Good afternoon. I understand you
2 have reached an agreement. Do you want to articulate it for
3 record?
4 MS. D'ALO: Yes, if I may. Your Honor, if I
5 make any misstatements along the way or misstate something, I
6 just invite Ms. Haggerty to correct me, because we've been
7 making notes as we go along here.
8 The parties agree that the Plaintiff,
9 Michelle McLaughlin, will pick up Christian McLaughlin at 5:00
10 today at the Defendant's house, and that is Jason Jumper's
11 house. They agree that up until the time of June 29th, when
12 there is a conciliation scheduled in this matter, that they
13 will follow the agreed-upon terms that I'm going to articulate
14 and that these terms do not prejudice in any way their
15 position at the conciliation.
16 The first term is that there will be one
17 night of visitation per week for the Defendant, and it will be
18 at 6:00 on Tuesday evening until 6:00 on Wednesday evening.
19 The Defe ndant will pick up Christian at the Plaintiff's home,
20 and the Plaintiff will pick up Christian for the return of the
21 child at the Defendant's home on Wednesdays.
22 The Defendant will have one weekend of
23 custody from 6:00 on Friday, June 18th, until 6:00 on Sunday,
24 June 20th, and, again, the transportation will be the same
25 way, with the person who is receiving the child picking up the
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child. So, in that case, it would be the mother picking up
the child at the Defendant's house.
Both parties agree that they will share
information with each other on how to contact each other and
with respect to any baby-sitters that they use and how to
contact those baby-sitters.
I think that's it. Did I miss anything?
MS. HAGGERTY: Language for other times as
the parties do agree.
MS. D'ALO: Should the parties be able to
reach an agreement about other periods of visitation, they can
make those agreements between themselves;: but otherwise, this
order prevails.
THE COURT: Mr. Jumper, are you agreeable to
those terms that were just dictated?
MR. JUMPER: Yes, sir.
THE COURT: Ma'am, are you agreeable?
MS. McLAUGHLIN: Yes.
THE COURT: We'll enter the following Order:
"AND NOW, this 11th day of June, 2004, this
Court adopts the parties' agreement as an Order of Court.
They are directed to comply therewith."
Okay. Good luck. Court is adjourned.
(The proceeding was concluded.)
3
CERTIFICATION
I hereby certify that the proceedings are
contained fully and accurately in the notes taken by me on the
above cause and that this is a correct transcript of same.
Susan Rice Stoner
Official Stenographer
The foregoing record of the proceedings on the
hearing of the within matter is hereby approved and directed
to be filed.
6l /0, 4
Date
Edward E. Guido, J.
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MICHELLE LYNN McLAUGHLIN,
Plaintiff
V.
JASON BRADY JUMPER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2004-2504 CIVIL TERM
CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
IJUN 2,9 ?
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AND NOW, this day of A? ?, 2004, upon A_X consideration of the attached Custody Con iliation Report, it is ordered and directed as
follows:
The Prior Order of Court dated June 11, 2004 is hereby vacated.
2. The Mother, Michelle Lynn McLaughlin, and the Father, Jason Brady
Jumper, shall have shared legal custody of Christian McLaughlin, born February 17,
2004. Each parent shall have an equal right, to be exercised jointly with the other parent,
to make all major non-emergency decisions affecting the Child's general well-being
including, but not limited to, all decisions regarding his heahh, education and religion.
3• The parties shall share physical custody of the Child beginning June 30,
2004 on a 2/3/2 alternating, repeating basis with Mother having the first 2-day period.
The exchange time shall be 6:00 p.m.
4. Transportation shall be shared such that the receiving party shall be
responsible for transportation.
5. The parties may modify the terms of this Order by mutual consent. In the
absence of mutual consent, the terms of this Order shall control. Another Conciliation
Conference is scheduled for September 30, 2004 at 8:30 a.m.
cc: Grace D'Alo, Esquire, Mid Penn Legal Services, Counsel for Mother
Kara Haggerty, Esquire, Counsel for Father
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MICHELLE LYNN McLAUGHLIN, : IN THE COURT OF COMMON PLEAS OF JUN 2 g
Plainti CGCI
ff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
:2004-2504 CIVIL PERM
JASON BRADY JUMPER,
: CIVIL ACTION - LAW
Defendant
: IN CUSTODY
PRIOR JUDGE: Edward E. Guido, J.
CUSTODY CONCILIATION SUMMARY_ RED
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
I • The pertinent information concerning the Chi ld subject of this
litigation is as follows: who is the
NAME DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Christian McLaughlin February 17, 2004
Mother
2. A Conciliation Conference was held in this matter on June 29, 2004, with
the following in attendance: The Mother, Michelle Lynn McLaughlin, with her counsel,
Grace D Alo, Esquire, Mid Penn Legal Services; and Father, Jason Brady Jumper, with
his counsel, Kara Haggerty, Esquire.
3. The Honorable Edward E. Guido entered an Order of Court dated June 11,
2004 in response to Mother's Petition for Special Relief, granting Mother primary
physical custody and Father periods of partial physical custody every Tuesday overnight
and alternating weekends from Friday to Sunday.
4. The parties agreed to an Order in the form as attached.
G -a -S-O'
Date
c eline M. Verney, Esquire
Custody Conciliator
ocl012004
MICHELLE LYNN McLAUGHLIN, ? : IN THE CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V :CIVIL ACTION -LAW
JASON BRADY JUMPER, : NO. 2004-2504 CIVIL TERM
Defendant . IN CUSTODY
ORDER OF COURT
AND NOW, this 7 -- - day of Q ?d? 2004, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. A Hearing is sched led in Court Room No. of the Cumberland
County Court House, on the Is-r day of n& Y , 2004, at Y OQ
o'clock,. M., at which time testimony will be taken. For purposes of this Hearing,
the Mother shall be deemed to be the moving party and shall proceed initially with
testimony. Counsel for each party shall file with the Court and opposing counsel a
Memorandum setting forth each party's position on custody, a list of witnesses who will
be expected to testify at the Hearing and a summary of the anticipated testimony of each
witness. These Memoranda shall be filed at least ten days prior to the Hearing date.
2. The prior order of Court dated July 1, 2004 is hereby vacated. Pending
further Order of Court or agreement of the parties, the following shall remain in effect:
3. The Mother, Michelle Lynn McLaughlin, and the Father, Jason Brady
Jumper shall have shared legal custody of Christian McLaughlin, born February 17,
2004. Each parent shall have an equal right, to be exercised jointly with the other parent,
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.
4. The parties shall have shared physical custody of the child on a week
on/week off basis.
5. Except when the parties are working, if either party is in need of
babysitting services for the child for longer than one hour, they shall contact the other
parent in a timely manner so that the non-custodial parent may exercise said period of
custody. Said periods may include overnight so that the child is not transferred at
unreasonable hours.
6. Thanksgiving shall be shared such that Father shall have physical custody
of the child from 9:00 a.m. to 3:00 p.m. and Mother shall have physical custody of the
child from 3:00 p.m. to 9:00 p.m.
7. Transportation shall be shared such that the receiving party shall be
responsible for transportation.
g. The parties may modify this Order by mutual agreement. In the absence
of mutual consent, the terms of this Order shall control.
J.
cc race D'Alo, Esquire, Mid Penn Legal Services, counsel for Mother
Xara Haggerty, Esquire, counsel for Father
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MICHELLE LYNN McLAUGHLIN, : IN MT BERLAND T
Plaintiff CCOUNTY, PEN SYLVANIA
V.
JASON BRADY JUMPER,
Defendant
PRIOR JUDGE: None
CIVIL ACTION - LAW
NO. 2004-2504 CIVIL TERM
IN CUSTODY
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 DATE OF BIRTH CURRENTLY IN CUSTODY OF
Christian McLaughlin February 17, 2004 shared
2. A Conciliation Conference was held September 30, 2004 with the
following individuals in attendance: The Mother, Michelle Lynn McLaughlin, with her
counsel, Grace D'Alo, Esquire, Mid Penn Legal Services and the Father, Jason Brady
Jumper, with his counsel, Kara Haggerty, Esquire.
3. A previous Order of Court was entered by the Honorable Edward E.
Guido dated July 1, 2004 providing for shared legal and shared physical custody on a
2/3/2 day schedule. Shortly after the Order was entered, the parties agreed to a week
on/week off schedule.
4. Mother's position on custody is as follows: Mother seeks shared legal
custody and primary physical custody with Father having an alternating weekend
schedule and one overnight per week. She asserts that Father has an anger problem when
he is drinking. He recently received a disorderly conduct citation and is on probation for
an undetermined alcohol related incident. Mother maintains that she is the more
appropriate caregiver, as Father recently separated from his girlfriend and is currently
living with his Mother.
5. Father's position on custody is as follows: Father seeks shared legal and
primary physical custody although he is willing to accept shared physical custody. Father
asserts that Mother has two other children whom she does not have primary physical
custody of. One child lives with her Father and the other child lives with maternal
grandmother in Michigan. Father maintains that Mother is a former cocaine addict who
used as recently as immediately prior to becoming pregnant with this Child. Father
cannot recall the exact charge he is on probation for, but admits to being drug tested
randomly by the probation department, with no positive indication of drug or alcohol use.
He also admits to the recent disorderly conduct citation. He believes he can provide
appropriate care for the Child.
6. The Conciliator recommends an Order in the form as attached scheduling
a Hearing and granting the parents shared legal custody and shared physical custody. It is
expected that the Hearing will require one-half day.
%o -I -oq_ 0
Date acq eline M. Verney, Esquire
Custody Conciliator
Michelle McLaughlin,
Plaintiff
V.
Jason Brady Jumper
Defendant
MOTI
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-2504 CIVIL TERM
CUSTODY
CE
Plaintiff, Michelle McLaughlin, through MidPenn Legal Services, by Grace D'Alo and
Jessica Diamondstone, moves the Court for an Order rescheduling the hearing in the above-
captioned case on the grounds that:
1. This matter was originally scheduled for a hearing on November 1, 2004 at 9:00
a.m.
2. Counsel for Plaintiff, Grace D'Alo, is out for medical leave and will not be
returning to the office until October 28, 2004.
3. Counsel for Plaintiff will not be able to fully prepare for a custody hearing
immediately following her return from the extended medical leave.
4. Counsel for Defendant indicates no objection to a continuance of this matter to
the next available hearing date.
WHEREFORE, Plaintiff requests that the Court grant this Motion and reschedule
the hearing in this matter.
Respectfully Submitted,
Grace D Esquire
Jessica Diamondstone, Esquire
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
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Michelle McLaughlin,
Plaintiff
V.
Jason Brady Jumper
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-2504 CIVIL TERM
CUSTODY
ON FOR CO
ANCE
Plaintiff, Michelle McLaughlin, through MidPenn Legal Services, by Grace D'Alo and
Jessica Diamondstone, moves the Court for an Order rescheduling the hearing in the above-
captioned case on the grounds that:
1. This matter was originally scheduled for a hearing on November 1, 2004 at 9:00
a.m.
2. Counsel for Plaintiff, Grace D'Alo, is out for medical leave and will not be
returning to the office until October 28, 2004.
3. Counsel for Plaintiff will not be able to fully prepare for a custody hearing
immediately following her return from the extended medical leave.
4. Counsel for Defendant indicates no objection to a continuance of this matter to
the next available hearing date.
WHEREFORE, Plaintiff requests that the Court grant this Motion and reschedule
the hearing in this matter.
Respectfully Submitted,
Jessica Diamondstone, Esquire
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
1 -1.
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OCT 1 9 20041
Michelle McLaughlin, : IN THE COURTOF COMMON PLEAS OF
Plaintiff
V.
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-2504 CIVIL TERM
Jason Brady Jumper
Defendant :CUSTODY
ORDER FOR CONTINUANCE
AND NOW, this away of October, 2004, upon consideration of the attached Motion
for Continuance, the matter scheduled for hearing on November 1, 2004 at 9:00??a.m. by this
Court's Order of October 4, 2004, is hereby rescheduled for hearing on I "'??, 2004 at
(0: gym. in Courtroom No. 5 on the 4`s Floor of the Cumberland County Courthouse, 1
Courthouse Square, Carlisle, Pennsylvania.
By the Court
Edward E. Guido, Judge
Grace D'Alo, Esquire
,,,,IvlidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
&Aara Haggerty, Esquire
36 South Hanover Street
Carlisle, PA 17013
> eA?
MICHELLE LYNN McLAUGHLIN
Plaintiff
V.
JASON BRADY JUMPER
Defendant
TO THE HONORABLE JUDGE GUIDO:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-2504 CIVIL TERM
CUSTODY
MOTION TO CONTINUE
AND NOW, this 3rd day of December, 2004, comes the defendant, Jason B. Jumper, by
and through his attorney, Kara W. Haggerty, Esquire, of ABOM & KUTULAKIS, LLP, and files
the following Motion to Continue, and in support thereof avers as follows:
1. A Custody Complaint was filed on or about June 3, 2004.
2. The parties appeared for a custody conciliation conference on June 29, 2004, and
September 30, 2004, following which the parties have enjoyed shared legal and physical custody
of the subject minor child.
3. A Hearing in this matter is scheduled for December 10, 2004.
4. Defendant would like additional time to produce witnesses and prepare for the above-
referenced Hearing.
5. Counsel for the Defendant has attempted to contact but has been unable reach Grace
D'Alo, Esquire, of Mid-Penn Legal Services, counsel for Plaintiff.
WHEREFORE, the Defendant respectfully requests that this court grant the Motion for
Continuance.
Respectfully submitted,
ABOM & KUTULAKIS, L.L.P.
Kara W. Haggerty
Attorney I.D. No: 8691
36 South Hanover Street
Carlisle, PA 17013
(717) 249-0900
Attorney for the Defendant
MICHELLE LYNN McLAUGHLIN IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
JASON BRADY JUMPER
NO. 04-2504 CIVIL TERM
Defendant CUSTODY
CERTIFICATE OF SERVICE
AND NOW, this 3`d day of December, 2004, I, Kara W. Haggerty, Esquire, of Abom &
Kutulakis, L.L.P., hereby certify that I did serve a true and correct copy of the foregoing Motion
to Continue upon the following by First Class Mail addressed as follows:
Grace D'Alo, Esquire
MIDPENN LEGAL SERVICES
8 Irvine Row
Carlisle, PA 17013
ABOM & KUTULAKIS, L.L.P.
Kara W. Haggerty
Attorney for Defendant
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MICHELLE LYNN McLAUGHLIN IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 04-2504 CIVIL TERM
JASON BRADY JUMPER
Defendant CUSTODY
ORDER FOR CONTINUANCE
AND NOW this 0
day of December, 2004, upon learning that both parties are in
agreement to continue the hearing scheduled for December 10, 2004, at 10:00 a.m., to the next available
court date, IT IS HEREBY ORDERED AND DIRECTED that the hearing is rescheduled for
t'? \
??^, the !y day of 201, at f- /m. in Courtroom No. 5 of the
Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania.
BY T OLI T:
Edward E. Guido, J.
Distribution:
? `Jute D'Alo, Attorney for Plaintiff
MIDPENN LEGAL SERVICES
8 Irvine Row
Carlisle, PA 17013
Kara W. Haggerty, Attorney for Defendant
ABOM & KUTULAKIS, LLP
36 South Hanover Street
Carlisle, PA 17013
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MICHELLE LYNN McLAUGHLIN,
Plaintiff
V.
JASON BRADY JUMPER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2004-2504 CIVIL TERM
IN CUSTODY
ORDER OF COURT
AND NOW, this 14th day of January, 2005, by
agreement of the parties, our prior Order of October 4, 2004,
shall remain in full force and effect except as modified herein.
The following additional provisions shall be added to that Order:
1. Neither party shall smoke or allow anyone else to
smoke in the presence of the child.
2. Neither party shall use alcohol or illegal drugs
during those time periods when the child is in his or her primary
physical custody.
Grace D'Alo, Esquire
For the Plaintiff
Kara W. Haggerty, Esquire
For the Father
B}
Edward E. Guido, J.
srs
MICHELLE LYNN McLAUGHLIN: IN THE COURT OF COMMON PLEAS
Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 04-2504 CIVIL TERM
JASON BRADY JUMPER
Defendant/Respondent CUSTODY
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow Michelle Lynn McLaughlin, Plaintiff to proceed in forma ,pauperis.
I, Grace D'Alo, attorney for the party proceeding in forma pauperis, certify that I
believe the party is unable to pay the costs and that I am providing free legal services to
the party.
G e D'Alo
At mey for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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MICHELLE LYNN MCLAUGHLIN IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. 04-2504 CIVIL ACTION LAW
JASON BRADY JUMPER
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Wednesday, September 21, 2005 , 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 Thursday, October 13, 2005 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. All children age five or older may also be present at the conference. 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/ Jacqueline M. Verney, Esq. J-
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 schedulec
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 Wl[ERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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't 2005
MICHELLE LYNN McLAUGHLIN, : IN THE COURT OF COMMON PLEAS OF
PlaintifVPetitioner : CUMBERLAND COUNTY, PENNSYLVANIA
V. :NO. 2004-2504 CIVIL TERM
JASON BRADY JUMPER, : CIVIL ACTION - LAW
Defendant/Respondent:
: IN CUSTODY
ORDER OF COURT
AND NOW, this 110A day of P , 2005, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The prior Orders of Court dated October 4, 2004 and January 14, 2005
shall remain in full force and effect with the following modifications.
2. The parties shall exchange custody of the child on Fridays at 6:00 p.m. at
the parties' residences.
Thanksgiving and Easter shall be shared from 9:00 a.m. to 3:00 p.m. and
3:00 p.m. to 9:00 p.m. as agreed by the parties.
4. Christmas shall be divided into two Blocks. Block A shall be from 12:00
noon on Christmas Eve to 12:00 noon on Christmas Day. Block B shall be from
Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A
in odd numbered years and Block B in even numbered years. Father shall have Block A
in even numbered years and Block B in odd numbered years.
5. Mother shall have physical custody of the child on Mother's Day and
Father shall have physical custody of the child on Father's Day both at times agreed by
the parties.
6. The parties shall alternate Memorial Day, July 4th and Labor Day at times
agreed by the parties. Mother shall have Memorial Day in 2006.
Father shall explore anger management counseling.
8. The parties shall keep each other informed of a current telephone number.
9. Mother shall have physical custody of the child in the event Father is
incarcerated.
10. This Order is entered pursuant to an agreement of the parties at 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.
J.
c race D'Alo, Esquire, Mid Penn Legal Services, Counsel for Mother
,I .ara Haggerty, Esquire, Counsel for Father
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MICHELLE LYNN McLAUGHLIN: IN THE COURT OF COMMON PLEAS
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 04-2504 CIVIL TERM
JASON BRADY JUMPER
Defendant/Respondent CUSTODY
PETITION TO MODIFY CUSTODY
Petitioner, Michelle Lynn McLaughlin, by and through her counsel, Grace D'Alo,
Esquire of MidPenn Legal Services, states the following:
1. Plaintiff/Petitioner, hereinafter referred to as Mother, resides at 202 Gull
Court Road, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. Defendant/Respondent, resides at 3 Dranoel Drive, Carlisle, Cumberland
County, Pennsylvania 17055.
3. The above-named parties are the natural parents of Christian McLaughlin,
born February 17, 2004.
4. The original custody order in this matter is dated October 4, 2004. That Order
is attached as Exhibit A and incorporated herein by reference.
5. The parties are also subject to two additional provisions added by an Order
dated January 14, 2005, which, in pertinent park, prohibits smoking and the
use of alcohol or illegal drugs by either party or third persons in the presence
of the child. That order is attached as Exhibit B and incorporated herein by
reference.
6. Mother seeks a modification to address concerns regarding Defendant's recent
behavior and to clarify details regarding exchange times and locations.
7. Defendant is not acting in the Christian's best interest for reasons including,
but not limited to, the following:
a. Defendant has created an unstable lifestyle for Christian by taking the
child out late at night to accommodate Defendant's drinking habit.
This behavior directly violates the Court Order of January 14, 2005,
which forbids the use of alcohol during custodial periods with the
child;
b. Defendant was recently in a bar room altercation in which he
physically harmed another patron;
c. Defendant uses profanity and is rude and unpleasant towards Mother
when she arrives to pick up Christian at Defendant's residence;
d. Defendant's actions interfere with Mother's ability to exercise her
shared legal custody right to participate in major decisions regarding
Christian.
8. Mother seeks a modification of the existing Order, which will serve the best
interest and permanent welfare of Christian, for reasons including, but not
limited to the following:
a. Mother has a stable home environment and she can provide for
Christian's financial, mental, emotional and physical needs on a daily
basis;
b. Defendant's behavior is potentially dangerous and self-destructive and
interferes with his ability to care for Christian;
c. Mother is the parent who can best ensure that Christian maintains
contact with Defendant and will continue to encourage the father/son
relationship they have developed;
d. Mother believes that Christian's behavioral issues are directly
influenced by Defendant's behavior. Decreased exposure to such
behavior will help Christian improve his behavior and develop
appropriate social skills for his age.
9. Defendant is currently represented by Kara Haggerty, Esq. Mother's Counsel
has contacted Attorney Haggerty who does/does not concur with the relief
requested in this matter.
WHEREFORE, the plaintiff requests this Court to grant:
a) Mother seeks a neutral spot for exchanges in an effort to minimize
conflict with the defendant and to shield Christian from defendant's behavior.
b) Grant mother primary physical custody of Christian subject to
Defendants periods of partial physical custody.
c) Establish a specific holiday schedule for the holidays.
d) Establish a neutral location for custody exchanges.
e) Allow Mother to have the right of first refusal for babysitting.
f) Direct Defendant to attend anger management classes and undergo an
evaluation for drug and alcohol abuse.
Respectfully submitted,
e 'Alo, Esquire
Mi Penn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
MICHELLE LYNN McLAUGHLIN,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
VS.
JASON BRADY JUMPER,
Defendant/Respondent
NO. 05-4327
CIVIL TERM
CUSTODY
CERTIFICATE OF SERVICE
I, Grace E. D'Alo, counsel for Plaintiff, hereby certify that a copy of the forgoing Petition
for Contempt and Modification to the Defendant has this 15`h day of September, 2005, been
served by regular mail upon:
Kara Haggerty, Esq.
36 South Hanover Street
Carlisle, PA 17013
Jason Brady Jumper
3 Dranoel Drive
Carlisle, PA 17013
I, Grace E. D'Alo, verify that the statements made in this Affidavit of Service are true and
correct. I understand that false statements herein are made subject to the penalties of 18 Ps.C.S.
Section 4904 relating to unsworn falsification to authorities.
Dab P
r ce E. D'Alo
Mo?aging Attorney
MfflPenn Legal Services
8 Irvine Road
Carlisle, PA 17013
VERIFICATION
The above-named PLAINTIFF, Michelle Lynn McLaughlin, verifies that the
statements made in the above Petition for Modification are true and correct. Plaintiff
understands that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904, relating to unswom falsification to authorities.
Date: -??->
Michelle Lyrm McLaughlin
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NOV 1 a 2005
MICHELLE LYNN McLAUGHLIN, : IN THE COURT OF COMM? Plaintiff /Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
V. :2004-2504 CIVIL TERM
JASON BRADY JUMPER, : CIVIL ACTION - LAW
Defendant/Respondent:
: IN CUSTODY
PRIOR JUDGE: Edward E. Guido, J.
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
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Christian McLaughlin
February 17, 2004
shared
2. A Conciliation Conference was held in this matter on November 14, 2005,
with the following individuals in attendance: Mother, Michelle Lynn McLaughlin with
her counsel, Grace D'Alo, Esquire, Mid Penn Legal Services and Father's counsel, Kara
Haggerty, Esquire.
3. The Honorable Edward E. Guido entered previous Orders of Court, dated
October 4, 2004 and January 14, 2005 providing for shared legal and shared physical
custody on a week on/week off basis.
4. The parties agreed to an Order in the form as attached.
,x t-r
Date ac eline M. Verney, Esquire
Custody Conciliator
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2310 A'R 13 A 8 ?
•?•v ? err:; ^ "MICHELLE LYNN McLAUGHLIN, : IN THE COURT OF COMMON PLEAS
Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA,
vs.
NO.: 2004-2504 CIVIL TERM
JASON BRADY JUMPER,
Defendant/Petitioner : IN CUSTODY
PETITION FOR MODIFICATION OF CUSTODY
1. The Petitioner is Jason Brady Jumper, who resides at 30 Willow Grove Rd., Carlisle,
Pennsylvania 17013.
2. The Respondent is Michelle Lynn McLaughlin, who resides at 1840 Trindle Rd., Carlisle,
Pennsylvania 17015.
3. Petitioner is requesting that he be granted Primary Physical Custody of said child, Christian
McLaughlin (D.O.B. 02/14/04).
4. Respondent is not getting the child to school when she has said child in her custody (See
copy of letter dated March 9, 2010 from Carlisle Area School District).
5. Petitioner recently found out that Respondent has been driving on a Suspended Driver's
License. (See copy of Docket Sheet from Cumberland County Court of Common Pleas) Petitioner is
unaware as to the reason the Respondent loss her Pennsylvania Driver's License.
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WHEREFORE, the Petitioner requests a Modification of Custody whereby Petitioner is granted
Primary Physical Custody of said child and Respondent be granted Partial Visitations of said child.
Respectfully Submitted,
Date: `"I I ? Q By:
Paul Bradford Orr, Esquire
Attorney for Defendant/Petitioner
50 East High Street
Carlisle, PA 17013
(717) 258-8558
Superior Court ID # 71786
VERIFICATION
I verify that the statements made in the foregoing Petition 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: /a
Jas rady Jumper, efe ant/ titioner
MICHELLE LYNN McLAUGHLIN, : IN THE COURT OF COMMON PLEAS
Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA,
vs.
NO.: 2004-2504 CIVIL TERM
JASON BRADY JUMPER,
Defendant/Petitioner : IN CUSTODY
CERTIFICATE OF SERVICE
I hereby certify that on this A-y of, A?J , 2010, 1 mailed a copy
of the Petition for Modification of Custody to the following persons at the following
address by First Class Mail as follows:
Grace D'Alo, Esquire
Mid Penn Legal Services
8 Irvine Row
Carlisle, PA 17013
Paul Bradford Orr, Esquire
Attorney for Defendant/Petitioner
50 East High Street
Carlisle, PA 17013
(717) 258-8558
Superior Court ID #: 71786
Q?es SCh°o,\
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March 9, 2010
Jason Jumper
30 Willow Grove Road
Carlisle, PA 17013
RE: Christian Jumper
Dear Jason:
CARLISLE AREA SCHOOL DISTRICT
623 W. Penn Street
Carlisle, Pennsylvania 17013
Telephone: 717-240-6800
Mary Kay Durham, Superintendent
As of March 9, 2010, Christian has been absent a total of 11'h days without a medical excuse of the 115
days that Bellaire Elementary School has been in session. This is 10% of the days on which school has
been in session during the current school year.
While I do not expect Christian to attend school when he is ill, the number of absence accumulated thus
far is cause for concern. School attendance is important for student achievement, and parents are
valuable educational partners in helping the school district to establish regular attendance habits for our
students.
I will continue to monitor Christian's attendance pattern closely. If the absences continue, then a
medical excuse may be required.
This is a form letter sent to parents to ensure that the total number of absences is correct and that all
pertinent information is communicated. If you have any questions about the contents of this letter, or if
there are special problems that have not been brought to my attention, then please feel free to contact me
at 240-6800, ext. 12802.
Thank you for your anticipated cooperation in this matter.
Sincerely,
Jim Burgess
Principal
Bellaire Elementary School
cc: Student file
Home & School Visitor
Michelle McLauglin
C:hnstian Jumper - Grade U Bellaire Elements School
Total Days Absent
Marking Period 1 = 1.0 Marking Period 2 = 8.5
Marking Period 3 4.0 Marking Period 4 = 0.0 Year Total = 13.5
M) Absences
A - Thursday, October 1, 2009 6U1,
M2 Absences
A - Thursday, November 12, 2009
A - Tuesday, December 1, 2009 )
A - Thursday, December 3, 2009 J
A - Thursday, December 10, 2009
A - Tuesday, December 15, 2009 Is
Q -Monday, December 21, 2009 M
Q - Tuesday, December 22, 2009
A -Tuesday, January 19, 2010 1m
M3 Absences
A -Tuesday, February 2, 2010
A - Tuesday, February 16, 2010
A - Wednesday, February 17, 20101M
A - Wednesday, March 3, 2010 NI
M4 Absences
Ml Tardies
U -Thursday, September 17, 2009 m
U - Wednesday, September 23,2009's
G - Tuesday, October 27, 2009 1f h
M2 Tardies
G - Monday, November 9, 2009 M
G - Wednesday, January 6, 20101h
ln??? r7
1041
Attendance Codes: A-Full Day Excused B=Full Day Unexcused C=Full Day Illegal D=Half Day Excused! E=Half Day Unexcused I F=Half Day Illegal G=Tardy Excused I I I=Tardy Unexcused I I=Tardy Illegal
1 J=Suspended In School K=Half Day Suspended In School I L=Suspended Out of School I M=Half Day Suspended Out of School 1 N=Early Release I O=Full Day Medically Excused 1 P=Half Day Medically
Excused ! Q=Pre-Arranged Absence I R-Half Day Pre-Arranged Absence S=Religious Observance T=Illegal Early Release U=College Visit
Magisterial District Judge 09-2-02
Docket Number: TR-0000451-10
Traffic Citation Docket
COMMONWEALTH OF PENNSYLVANIA
V.
MCLAUGHLIN, MICHELLE L
Page 1 of 1
Judge Assigned: BREWBAKER, JESSICA Issue Date: 01/21/2010
OTN: File Date: 01/21/2010
Arresting Agency: CARLISLE BORO, POLICE DEPT Case Disp: Guilty By Plea
Arresting Officer: BUCHER, JOSHUA J Disp Date: 01/21/2010
Complaint/Incident # B7512026-4 Requested: $0.00
County: CUMBERLAND Judgment: $0.00
Township: CARLISLE BORO Case Status: Adjudicated
Name: MCLAUGHLIN, MICHELLE L Address: CARLISLE, PA 17013
Date Of Birth: 03/21/1977 Sex: Female
Race: Unknown
# Charge Grade Description Disposition
1 75 § 1543 §§ A S DRIV WHILE OPER PRIV SUSP OR REVOKED Guilty Plea
Total Due: $350.00 Total Adj: $0.00
Total Paid: $0.00 Balance: $350.00
Name: BUCHER, JOSHUA J
1200
Printed: 04/09/2010 4:54 pm
Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of
the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or
omissions on these docket sheets. Docket chest information should not be used in place of a criminal history background check, which can only be
provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S.
Section 9101 et seq.) maybe subject to civil liability as set forth in 18 Pa.C.S. Section 9183.
Magisterial District Judge 09-2-02
Docket Number: TR-0000450-10
Traffic Citation Docket
COMMONWEALTH OF PENNSYLVANIA
V.
MCLAUGHLIN, MICHELLE L
Page 1 of 1
Judge Assigned: BREWBAKER, JESSICA Issue Date: 01/2112010
OTN: File Date: 01/21/2010
Arresting Agency: CARLISLE BORO, POLICE DEPT Case Disp: Guilty By Plea
Arresting Officer: BUCHER, JOSHUA J Disp Date: 01/21/2010
Complaint/Incident # B7512025-3 Requested: $0.00
County: CUMBERLAND Judgment: $0.00
Township: CARLISLE BORO Case Status: Adjudicated
Name: MCLAUGHLIN, MICHELLE L Address: CARLISLE, PA 17013
Date Of Birth: 03/21/1977 Sex: Female
Race: Unknown
# Charge Grade Description Disposition
1 75 § 4703 §§ A S OPERAT VEH W/O VALID INSPECT Guilty Plea
Total Due: $109.50 Total Adj: $0.00
Total Paid: $0.00 Balance: $109.50
Name: BUCHER, JOSHUA J
1200
Printed: 04/0912010 4:55 pm
Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of
the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or
omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be
provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S.
Section 9101 at seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183.
MICHELLE LYNN MCLAUGHLIN IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
2004-2504 CIVIL ACTION LAW
JASON BRADY JUMPER
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, ___ __ Monday, April 19, 2010 , 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 Tuesday, May 18, 2010 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ Jacqueline 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.
/,.ate ! /I, _? UD `_ t
?d Cumberland County Bar Association ?
32 South Bedford Street Q
+0 QCC' Carlisle, Pennsylvania 17013
Telephone (717)249-3166
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