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HomeMy WebLinkAbout10-2984TIMOTHY R. COUPE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. JEANNIE MARIE CRAMER, CIVIL ACTION - CHILD CUST(?DY, Defendant C_: o .T? COMPLAINT IN CUSTODY? ' 1. Plaintiff is Timothy R. Coupe, an adult individual residing at 1445 Holl ike. Lot A, Carlisle, Pennsylvania 17015. 2. Defendant is Jeannie Marie Cramer, an adult individual residing at 1808 West Philadelphia Street, York, Pennsylvania 17404. 3. The parties are the natural parents of the following minor children: Kassidy Ruth ohn M.err 5020 Ritter Road suite 109 MechaNcsbiug, PA 17055 PHONE: 717.766.4008 FAx: 717.766.4066 Coupe, born March 23, 2008; Cayden James Coupe, born March 30, 2007; and Jocelyne Grace Coupe, born March 28, 2010 (hereinafter, "the children"). 4. The children were born out of wedlock. 5. The children are presently in the custody of Plaintiff, who resides at 1445 Holly Pike, Lot A, Carlisle, Pennsylvania 17015. 6. During the past five years, the children have resided with the following persons and at the following addresses: Names Timothy R. Coupe Timothy R. Coupe Jeannie Marie Cramer Timothy R. Coupe Jeannie Marie Cramer Addresses 1445 Holly Pike, Lot A Carlisle, PA 17015 1445 Holly Pike, Lot A Carlisle, PA 17015 1445 Holy Pike, Lot B Carlisle, PA 17015 Dates 3/10 - present 6/07 - 3/10 3/07 - 6/07 /0d -?,/-7y ,?# dy?sx 7. The mother of the children is Defendant Jeannie Marie Cramer, who resides at 1808 West Philadelphia Street, York, Pennsylvania 17404. She is not married. 8. The father of the children is Plaintiff, Timothy R. Coupe, who resides with the children at 1445 Holly Pike, Lot A, Carlisle, Pennsylvania 17015. He is married. 9. The relationship of the Plaintiff to the children is that of father. The Plaintiff currently resides with the following persons: Name Relationship No one other than himself 10. The relationship of the Defendant to the children is that of mother. The Defendant currently resides with the following persons: Name Relationship Mark Cramer Father Susan Pavitch Father's paramour 90Z7M. err 5020 Ritter Road suite 108 Mechanicsburg. PA 17055 Pliow 717.766.4008 FAx: 717.766.4066 11. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 12. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. 13. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 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. 15. The best interest and permanent welfare of the children will be served by granting the relief requested because: a. the Plaintiff Father provides the most stable environment for his children; b. the children are prospering under the present arrangements, living with their Father continuously since birth; c. the safety of the children are endangered while in Defendant Mother's care, because i) she has threatened to "wrap the van around the tree with baby in it"; ii) she does not have the means to care for the children; iii) she suffers from depression and other mental health issues; and iv) she has written father that she is afraid "she may hurt children" d. the emotional, physical and/or spiritual development of the children will be enhanced by granting sole legal and primary physical custody rights to the children to Plaintiff Father and limiting Defendant Mother's custody rights to some form of supervised visitation only. WHEREFORE, Plaintiff requests that the Court grant to him sole legal and primary physical custody of the children, Kassidy, Cayden, and Jocelyne. Respectfully submitted, caw o; go, ;!?e, 5020 Ritter Road Suite 109 WcharkSburg, PA 17055 PHONE: 717.766.4008 FAx: 717.766.4066 Joh M. Kerr, Esquire Attorney I. D. # 26414 Law Office of John M. Kerr, Esquire 5020 Ritter Road, Suite 109 Mechanicsburg, Pennsylvania 17055 (717) 766-4008 Attorney for Plaintiff, Timothy R. Coupe Dated: May 4, 2010 VERIFICATION The undersigned, Timothy R. Coupe, hereby states that he is the Plaintiff in the foregoing custody action and, as such, is authorized to execute this Verification, and that any factual statements contained in the Custody Complaint are true and correct to the best of his knowledge, information and belief. He understands that false statements are subject to the penalties provided at 18 Pa. C.S.§4904, relating to unsworn falsification to authorities. Timothy R. Coupe TIMOTHY R. COUPE PI.:IINTIFF v. -IEANNiE MARIE CRAMER I)fFF;NDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • 2010-2984 CIVIL ACTION LAW IN CUSTODY ORDF.,R OF COURT AND NOW, _ Tuesda~,_May 11, 201.0, _J ,upon consideration of the attached Complaint, it is hereb} directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator, at 4th Floor ,Cumberland County Courthouse, Carlisle on Thursday, June 10, 2010 at 10:30 AM for a Prc-l-fearing 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. Gilro Es . ~ _ Custody Conciliator T11e 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 he 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 NU"t HAVI AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE T HE OFFICE SEA FORTI-I BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. c /!e~-1 Cumberland County I3ar Association /~ •' O tom' `' • ~ 1,~ MQtJ1 \~ Jr' ~ Vin'" ` ~ sa- --c t 32 South Bedford Street ~_ r : ~ zL -~~ ~C'. Carlisle, Pennsylvania 17013 crs<: ~~: to ~ ~ ~ Telephone {7l7) 249-3166 la~t~ ~c~- Ma.;le.r~ -~4-0 •',;-~ ~ ~ s°" ~` "~")=r~ ~~~ ~• ~~~ 1O ~ '~tGtcea ~n ~ ~-Llrou~S -~ 4Q.• JUN 3 0 2010 TIMOTHY R. COUPE, IN THE COURT OF COMMON PLEA OF~ -~; Plaintiff CUMBERLAND COUNTY, PENNS~VA-iIA -+ ny:;, rA; t _' ~~~-r, r vs. ~ CIVIL ACTION -LAW - . ~~ m ~°~ ~=- ~- a JEANNIE MARIE CRAMER, ~r ~ . : NO. 2010-2984 ~ ~;; ; ~ - -' Defendant IN CUSTODY .~y ~ ~:' . ,. ' _. ~t r ~,; --~ COURT ORDER NOW, this t ~~ day of __ ~~~ , 2010, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. 'The father, Timothy R. Coupe, and the mother, Jeannie Marie Cramer, shall enjoy shared legal custody of Kassidy Ruth Coupe, born March 23, 2008, Cayden James Coupe, born March 30, 2007 and Jocelyn Grace Coupe, born March 28, 2010. 2. The father shall enjoy primary physical custody of the minor children. 3. The mother shall enjoy periods of temporary physical custody of the minor children at such times and under such circumstances as agreed to by the father. 4. As a condition to mother having periods of temporary custody of the minor children, mother shall keep father advised with respect to her ongoing counseling sessions and, as appropriate, provide father with reports from her counselor. 5. In the event the mother desires periods of additional temporary custody and is unable to work out an agreement with the father, mother may petition the court to have the case again scheduled with the Custody Conciliator for a conference. cc: '' J ~n M. Kerr, Esquire /Jessica Holst, Esquire c©~`~~~ ~ ,~.~c~c~ ~' lfto I BY THE COURT, ~ r TIMOTHY R. COUPE, Plaintiff vs. JEANNIE MARIE CRAMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2010-2984 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 Custody Conciliator conducted a telephone conference with legal counsel for the parties and the parties agree to the entry of an Order in the form as attached. Date: June ~ ~ , 2010