HomeMy WebLinkAbout09-8396Jason B. Edwards, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION -LAW
Wendy Ann Smith, NO. - p 3 96' FZ
Defendant IN CUSTODY
COMPLAINT FOR CUSTODY
AND NOW comes Plaintiff, Jason B. Edwards, by and through his attorney,
Joseph D. Buckley, Esquire and seeks custody of his daughter, Hayley Rayanne Smith, a
minor, based on the following:
1. Plaintiff is Jason B. Edwards who resides at 338 Greason Road, West Pennsboro
Township, Carlisle, Cumberland County PA 17015.
2. Defendant is Wendy Ann Smith currently residing with her mother at 4 East
Ordorf Drive, lea Brunswick, MD 21716
3. Plaintiff seeks custody of the following child:
Name
Current address
Age
Hayley Rayanne Smith 338 Greason Road, Carlisle, PA 17015
The child was born November 5, 1998 out of wedlock.
11
The child is presently in the custody of Plaintiff and his wife at their residence at
338 Greason Road, Carlisle, PA 17013.
During the past five years, the child has resided with the following persons at the
following addresses:
Name Address
Jason & April Edwards 338 Greason Road, Carlisle, PA
Wendy Ann Smith & Roy Davis P.O. Box 62 Jefferson, MD
Dates
02/13/09 - present
11/01/04 - 02/12/09
The mother of the child, Wendy Ann Smith, currently resides 4 East Ordorf Drive, TIN4
Brunswick, (Frederick County) MD 21716. Mother's current status is single.
The father of the child, Jason B. Edwards, resides at 338 Greason Road, Carlisle,
Cumberland County PA 17015. Father's current marital status is married to April
Edwards.
4. The relationship of plaintiff to the child is father. The plaintiff currently resides
with the following persons:
Name Address
April Edwards (wife) 338 Greason Road, Carlisle, PA 17015
5. The relationship of defendant to child is that of biological mother.
6. Plaintiff has physical custody of the child, and Defendant has visitation and
partial custody by virtue of a verbal agreement, every other weekend. Plaintiff
knows of no other person other than himself and Defendant who has, or claims to
have custody or visitation rights with respect to the child with the exception of
Defendant.
7. The best interest and permanent welfare of the child will be served by granting
custody to Plaintiff. The child has been enrolled in Big Springs school district
since August, has adjusted well and has been presented with a stable, loving
environment in her new home.
8. 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. There are no other persons who are known to have or claim to have any
custody or visitation rights concerning the child.
WHEREFORE, Plaintiff requests this Honorable Court grant him custody of the child,
Hayley Rayanne Smith.
Supreme Court I.D.# 38444
1237 Holly Pike
Carlisle, PA 17013
(717) 249-2448
JoeBLaw@aol.com
VERIFICATION
The undersigned, Jason B. Edwards, hereby certifies that the statements made in
the foregoing Petition are true and correct to the best of his knowledge, information and
belief.
It is understood that statements made herein are subject to the penalties of 18 Pa.C.S.
Section 4904 relating to unsworn falsification to authorities.
Date:
Ja n B. Edwards
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JASON B. EDWARDS,
Plaintiff
vs.
WENDY ANN SMITH,
Defendant
JAN ~ ~ 2010 ~
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
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NO. 2009-8396 ~~~'~" ~
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IN CUSTODY =~ ~ -' "°
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COURT ORDER 7w ~:~
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AND NOW, this ~ ~ day of January, 2010, upon consideration of the attached
Custody Conciliation Report, it is ordered and directed as follows:
The mother, Wendy Ann Smith, and the father, Jason B. Edwards, shall enj oy shared
legal custody of Hailey Rayanne Smith, born November 5, 1998.
2. The Father shall enjoy primary physical custody of the minor child.
3. The Mother shall enjoy liberal periods of temporary physical custody pursuant to a
schedule as arranged between the parties.
4. This Order is entered subject to the understanding that the Mother may seek a return
of primary custody to her and, in the event the parties cannot reach an agreement at
that time, Mother may petition the Court to have the case again scheduled with the
Custody Conciliator for a hearing.
BY THE ,
cc: / J~seph D. Buckley, Esquire
/Ms. Wendy Ann Smith
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Judge
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JASON B. EDWARDS,
Plaintiff
vs.
WENDY ANN SMITH,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 2009-8396
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 child who is the subject of this litigation
is as follows:
Hailey Rayanne Smith, born November 5, 1998
2. A Conciliation Conference was held on January 8, 2010, with the following
individuals in attendance:
the father, Jason B. Edwards, with his counsel, Joseph Buckley, Esquire,
and the mother, Wendy Ann Smith, who appeared without counsel.
3. The parties agree to the entry of an Order in the form as attached.
Date: January ~, 2010
Hubert X. Gilroy squire
Custody Conci 'tor