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Home My WebLink About01-2891DEBRA ELAM, : IN THE COURT OF COMMON PLEAS pl.l.tiff : CUMB~ COUNTY, PENNSYLVANIA : vs. : No. o/- -~ Y'~ t ~-~,,~' -'/'~_. JASON HOBBLE aud : RASHAAN ELAM. : CIVIL ACTION - AT LAW Deferments, : CUSTODY Cn~PT.~,T~ m~ ~.T~'~n¥ ~l~lle plsln~, D~ E~, thmu~ h~ a~s, ~e ~w ~s ~ Patak F. ~u~, Jr., ~es this Comp19int for C~y a~in~ ~e Ddend~n~, J~ON HOBB~ ~d ~~ E~, ~d ~ ~PP~ ~, a~ ~e f~o~g: 1. ~e ~,in~ ~ DEB~ E~, ~ ad~t ~&~du~ ~d ~e ma~ ~dmo~er, who c~fly ~ at 1826 H~shm~ G~, C~e Cmb~l~d Co,W, penn~lv~nia 17013. 2. (a). ~e Dd~8~nt h ~ ~l.~, ~ ad~t ~&~du~ ~d ~e na~ Mo~, who ~fly ~s at 652 O~e ~ad, S~pp~sb~g, C, mb~l~nd C~W, p~n~lv~nla 17013. ~). ~ a~fion~ D~end~nt, supp~ve ~ ~gin~s d~im, ~ J~N HOBBY, ~ ad~t ~&~du~ ~d ~e na~ ~, who ~ ~nfly ~a~d ~ Gra~ord S~ C~ lnsg~, Gra~, p~nnsylv~nia. 3. ~e pl~in~ s~ p~ ph~ ~ ~d leg~ ~dy, ~ ~e f~o~g chl]& LaShaan M. Hobble 652 Oakville Road DOB: 4/5/00, 1yr. Shipp~nsbu~g, PA The ~hild was born out of wedlock. 4. The child is pzesently in the custody of HAS~ ELAM, who cur~ntly resides at 652 Oakville Road, l[~hipp~nsburg, Pennsylvania 17257 with his maternal Erandfather, James Elam, and the Defen_rlant, ~_nsh~n l~.lnm. 5. The rhild ~sided with maternal ~dmother f~om birth through April /4, 2001 at the £ollowing address: Dates: Addresses: N~mes: 4/5/00 (birth) 1826 Heishman Gardens Debra Elnm Carliale, PA 17013 Rash_n_sn Elam 4/14R)1-5/1/01 221 E. Louther Street l~_n_.~hnnn Elnm Carlisle, PA 17011} Frnnk Porter Dionne Po~te~ Dionne's 2 ~hildren 5/2~01 to p~ent 652 Oakville Road ]~sh~n Elam Shippensburg, PA Jgmes Elam Laurie M"mma Lattrie'$ 2 ~hilch. en 6. The Mother of the child is RASHAAN I~,T.A..,'~, who ~tly tildes at 652 Oakville Road, Shippensburg, Cumberlsnd County, Pennsylvania 17257, with the subject of this petition. The Mother is not married to the natural Father. 7. This location is an overcrowded home; the previous location is an overcrowded apaxi~ent. 8. The Father of the child is JASON HOBBLE, who is currently inc?ceratod at SCI-Graterfercl. The Father is not married to the natural Mother. 9. The p1Ainti~has not psrfia'pated as a party or witness, or in another capacity, in other llti~tion concelming the custody of the child in this or another 10. The p1Aintiffhas no information of a custody preceedlng concerning the child currently pevding in any cou~t of this Commonwealth. 11. The P1-nlntil~ dees not kn°w of a pers°n not a party to the pt~)coedings' which have physical custody of the ohild or clslms to have physical custody or visitation rights with respect to the child. 12. The best ints~.~ts and permanent welfare of the child will be served by granting the reliof requested because: a). The pl~int~ can p~vide the child with a home .w~.?~.. adequate moral, emotional, and physical surreuvdlngs as required to meet the child's needs; b). The p1Ainti~is willing to continue Ctlstody of the ~,hilc~ c). The pl~in6ff continues to ~ pat~xtal duties and enjoys the love and affection of the ahild. 13. E_~h parent whose parental rights to the child have not been terminated and the person who has physical custody of the rhiid has been ]~med as parties to this action. All other persona, ]~med below, who a~e known to have or claim to have a right to custody or visitation of the child will be ~iven notice of the pendency of this action and the right to intervene: 1STsme: Add,ss: BAsis of CIAim~ Kimberly Hawl~ins 164 Faith Ci_wle Paternal Grenrimother Ca~lisle, PA 17013 Steve Hobble, Sr., RD1, Box 561, 3Spring, PA 17264 Paternal Ora~_rlCAther WHEREFORE, the Pla~aff re~estfully requests that t_hi~ Henarable Court enter an Order granting custocl~v of the child to the Pettener, DEBRA ELAM in accordance with any Stipulaton of the parties, or in the event the parties are unable to execute such a Stipulation, to enter an Order granting custody, paraA1 custody, or visitation of the ~hild to the petitioner. Law Offices of pa~e~ F. Laue~, ~. 2108 Market Street, Aztec Building '~/ /C] C~mp pill_ Pennsylv~ni~ 17011-4706 Date: I{ ( 1]~ 72655' TeL (717) 763-1800 PATRICK F. LAUER, JR. Attorney at Law 2108 Markel Suee! AzlecBuiIding ""~?/ ~ .~.' ',,'..j~'~ ..... ... ~;J~ Comp Hill, PA 17011 (717) 763-1800 .~ DEBtL~, ELAM, : IN THE COURT OF COklMON PLEAS Plaintiff : CLTMBERLAND COUNTY, PENNSYLV,~IA : vs. : No. : JASON HOBBLE m~d : RASHAAN ELAM, : CIVIL ACTION - AT L~W Defeqdants : CUSTODY VERIFICATION I, DEBIkl ELAM, state that I am the Plainliff in the above-captioned case and that the facts set forth in the above Complah~t for Custody m~ true and correct to the best efmy lmowledge, ilfformalion, and belief. I renli~.e that false statements he~in are subject to the penallies for unsworn falsification to autho~lies under 18 Pa. C.S. § 4940. Date: ,J)i:7/C: I ," I '~" 6' _k~0 ~. ',,[. "!<. I,_.~,,:.., ,. Debra Elam, Plaintiff i' ~ ! Ililmllglllfllllll~lllllllll~lllllllJlllllllllllllllllll IIIIBIIIIl$1111lll IllillllBlllllll~Bllllllllllllllll IIIIllllllll IIIIIIII ! II DEBi~ ELA~ PLAINTIFF : /N THE COURT OF COMMON PLEAs OF JASON HOBBLE AND RASH.RAN ELAM : CUMBERLAND COUNTy, PENNSYLvANiA DEFENDANT : 01-2891 CIVIL ACTION LAW' IN CUSTODy AND NOW', ________~. it is hereby directed that panics and their respective counsel a upon consideration of the attached Complaint, cannot be accomplished, order, to define and narrow the issues to be heard ~ mane to resolve the issues in dispute; or All children age tire or older may also the Court. and to enter into a temporary provide grounds for entry ora temporary be present at the conference. Failure to appear at the conference may or permanent order. The.court hereby directs the pattie · Special Rebeforders, and CUStod~ ~.d_=_ ~ to furnish any and all existin~ Pro*-~o:-- - ~ ~--~rs to the eonelliat.. ~o ~ o -,-..tsua ti'om AbUse orde - ~- -,o uOurs prior to scheduled - · rs, fOR THE COURT, nearing. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to COmply with Americans with Disabilites Act of 1990. accommodations available For information abgut accessible facilities and reasonablt~e 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 attend the scheduled Conference or hearing. · ..... YOU SHOULn -c^ ,. ..... coun. You must n.'~vE AN AT'r~ ...... --~, ,-re, t: t l-tlS PAPEn .~ .. FORTH B~,~'..~~EY OR CANNOT AFt,,-,~ ~ YOUR A TI'ORNEy AT r~,, .... ~=t.taW TO FIND OU'r u· ..... rurda ONE, GO TO -_¥o~t.l:. IF YOU DO Cumberland County Bar ASSOciation 2 Liberty AVenue Carlisle. Pennsylvania 17013 Telephone (717) 249-3166 . coe~°_~,,,~ - ~9~" o~,.~"~ -'oa~ d~s no~- ' r ~e chil~. -e and ~n~ Io . · ca~ - -':'s parent, pm~d~n9 the cn~u e~ ~n~rest o and ~ ~s not ~n the b ORE, .~ ~93 ~ ~eet '~ ail e, P~ a - : IN THE COURT OF COMMON PLEAS OF DEBRA ELAM, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA ~ NO. 0t - 2891 CIVIL TERM vs. : CIVIL ACTION - LAW JASON HOBBLE and : RASHAAN ELAM, Defendants : IN CUSTODY ~ERTIFICATE OF SERVICE_ day of , ~.~,..4' ~_ -' AND now, this_ '2---- - --"~ S~ 2001, I, Carol J. Lindsay, Esquire, of the law firm IDIS, UFF, FLOWER & LINDSAY, Attorneys, hereby certify that I served the within Preliminary Objections this day by depositing same in the United States Mail, First Class, Postage prepaid, in Carlisle, Pennsylvania, addressed to: Matthew J. Eshelman, Esquire 2108 Market Street, Aztec Building Camp Hill, PA 17011 SAIDI$, SHUFF, FLOWER & UNDSAY, P.C. Attorneys for Plaintiff 26 West High Street Carlisle, PA 17013 SAIDIS (717) 243-6222 StlUFF, FU3WI~ LINDSAY w. ltlsh Street Car]ia]e, PA CUMBERLAND cOUNTY. PENNSYLVANIA 01-2891 CIVIL ACTION LAW IN CUSTODY AND NOW, FrMay, August 10, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Mellssa P. Greevy, Esq. , the conciliator, at 214 Senate Avenu% Suite 10S, Camp Hill, PA 17011 on Thursday, August 09, 2001 at 3:00 p.m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made m 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 u 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 enl~y 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: Is/ M~;~cc,~ P. Greevy. 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 2 Liberty Avenue Carlisle. Pennsylvania 17013 Telephone (717) 249-3166 ,, I ~ DEBRA ELAM, : IN THE COURT OF COMMON P~.EAS OF · ! pl~i~liff :. CIJ-MB~ COUNTY, pENNSYLVANIA ~; vs. : No. 01-2891 CIVIL ACTION LAW [' . [ JASON HOBBI,E and : IN CUSTODY RAS : ~ Defena~nts, : The plaintiff, DEBRA ELAM, through her attorneys, The Law Offices of Pat~ F. Lauer, Jr., ~es ii, is Complaint for Custody a~inst the Dofenasnts, JASON HOBBI.E and RAS~ ELAM, and in supper~ thereof, avers the fonowin~. 1. The pl~inliE is DEBRA ELAM, an adult individual and the maternal gra~r]mother, who cunm~tly ~sides at 1826 Hei~hman Gardens, Carlisle, Cumberisnd County, Pepneylv~nla 17018. 2. (a). The Dofe~4~nt is RAS~ ELAM, an adult individual and the natural Mother, who cur~ntly resides at 652 Oakville Road, Shippensbu~g, C,,mberl_~nd Comity, pennsylvsniA 17013. (b). An additional Dofenri~nl, supportive of plaintiff's c]slm, is JASON HOBBLE, an adult individual and the nat~t~al father, who is currently incarcerated in (}rater~ord ~tate Correctional Tn-~itUl~ion, Gratel~erd' 3. The ~lsin/dff 8ee]~ pl~ll~ry physical custody and legal custody, of the ~' LaSbss~ M. Hobble 652 Oakvilie Road DOB: 4/5/00, 1yr. i Shipvensburg, PA The child was bom out of wedlock. 4. The child is presently in the custody of RASHAAN ELAM, who currently resides at 652 Oakv/lle Road, Shippousburg, Pennsylvsnis 17257 with his grandCsther, Jsmes Elsm~ and the Defe~dsnt, R~shssn Elam. 5. The o~ild resided with maternal grandmother tlmm birth through April 4, 2001 at the following address: Dates: Addresses: Nsmes: 4/5]00 (birth) 1826 Heishman Gardens Debra Elam C/a'lisle, PA 17013 l~shaan Elam 4/14/01-5/1/01 221 E. Louther Street l~shaan Elam Ca~llde, PA 17013 Frsnlr Porter Dioune Por~ Dionne's 2 ,hildrou 5/2/01 to p~esent 652 Oakville Road Rashaan Elam Shipp~nsbu~, PA Jsmes Elam Laulie Mnmma Laurie's 2 ~hildren 6. The Mother of the rhild is P,A~HAA.Iq ELAM, who currently ~esides al 652 Oakville Road, Shippensbur~, C~mberlsnd County, pennsylvnnli 17257, with the subject of ~hls petition. The Mother is not manied to the natural Father. 7. This locaiion is an ~ded h~me; the previous location is an ove~rowded apartment. 8. The Father of the rhilrl is JASON HOBBLE, who is currently incan~rated at SCI-C-ratedord. The Father is not married to the natural Mother. 9. The pla;ntiiT has not partleipated as a p~ ~ ~m~, or ~ ~o~ ~p~W, ~ o~ ~fi~n wn~ing ~e ~y ~ ~e child ~ thi~ or ~o~ w~- 10. ~e pl*in~ff h~ no inf~afi~ ~ a ~Wdy p~ing ~ing ~e child ~nfly pending ~ ~y ~ ~thls ~mm~we~. 11. ~e ~sln~ ~ n~ ~ ~ a p~n not a p~ ~ ~e p~dino, w~ have ph~ ~dy ~ ~e child or ~m~ m have ph~ ~Y or ~n ~ ~ ~ ~ ~e child. 12. ~e best ~s~ ~d p~t w~ ~e child ~ be s~ed by ~g ~e ~ ~e~d b~e: a). ~e ~ff ~ p~de ~e child ~ a h~e ~ a~a~ emoted, ~d ph~ S~din~ ~ ~d ~ me~ ~e child's n~; b). ~e ~in~ ~lling ~ ~n~ue ~dy ~e c). ~e ~,~ ~u~ ~ exe~ p~n~ du~ ~d ~oys ~e l~e ~d ~n ~e 13. Ea~ p~nt wh~ p~ ~h~ ~ ~e child have not been ~d ~e p~n who ~ phy~ ~Wdy ~e ~hild ~ ~ n~med ~ p~ ~ this ,. ~on. ~ o~ p~, nsmed ~, who ~ ~o~ ~ have [ or 8~im ~ ha~ a ~ht m ~dy ~ ~ta~on ~ ~e ~ ~ ~ ~n no~ ~ ~e pen~ ~this ~ ~d ~e ~ht ~ ~e: N~me: ~: Bo&s ~ C]~m: ~imb~ly Haw~n~ 164 F~ ~e Pa~ ~dmo~ C~l~]e, PA 17013 S~e Hobble, Sr.,~l, Box 561, 3~g, PA 17264 Pa~m~ WHEI~EFOHE, the pl~nfiff t~spectfu]ly ~luests that this Honorable Cou~t enter an Order granting custody of the child to the petitioner, DEBHA ELAM in accordance with any Stipulation of the psrfies, or in the event the parties a~e unable to execute s~_~_ch a Stipulation, to enter an Order granting custody, partial custody, or visitation of the child to the petitioner pursuant to §5313(a) of the Domestic 1%lstions Code. Matthew J. EsI~lman, Esquire Law ~s of Patrick F. Lauer, Jn 2108 Msrlret Street, Aztec Building (O Camp Hill; pennsylvania 17011-4706 Date: ~ '[~ ( ID~ 72655 Tel. (71'/) 763-1800 : I~ THE COURT OF COMMON pi.gAS OF DEBRA ELAM, Plainti~ : CUMBERLAND COUNTY, PENNSYLVANIA : No. 01-~891 CIVIL ACTION LAW JASON HOBBI.E and : IN CUSTODY The undersigned attorney hereby verifies and states that: 1. He is the attorney for the Plaintit~ Debra Elam; 2. He is author/zed to make this verification on behalf of the client( 3. The facts set forth in the foregoin~ Amended Complaint are known to him and not necessarily to his client; 4. This verification is intended to expedite the litigation; 5. A verification of the client will be supplied if demanded; 6. The facts set forth in the foregoing Amended Complaint are true and correct to the best of his knowledge, information, and belie~ end 7. He is aware that false slatements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unswom fals/fication to authorities. / Matthew j.~Eshelman, Esquire : IN THE COURT OF COMMON PLEAS OF DEBRA ELAM PLAINTIFF : CUMBERLAND CouNTY, PENNSYLVANIA V. JASON HOBBLE AND RASHAAN ELAM : 01-2891 CIVIL ACTION LAW DEFENDANT . : IN CUSTODY AND NOW, Friday', .~,~=.mt 10, 2001 _, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear betbre _ Mom,l P. Greevy, Esq. . the conciliator, Thursday, A~?st 09, 2001 at 3:00 p.m. . , v~.~:~- Suite 10S, Camp Hill, PA 17011 on at 214 Senate A -- , ~-~ will be made to resolve the issues in dispute; or for a pre-Hearing Custody Conference. At such conference, an erxort 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 wounds 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:_ Iai ~i4e[i~¢a P. Greevy. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans wi'th 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 ATI'ORNEY 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 2 Liberty Avenue Carlisle. pennsylvania 17013 Telephone (717)249-3166 : ~N THE coU~T OF CONSVION pLEAS OF DEBRA ELA~plsin~ : cUN~ERLAND coUNTY, pENNSYLVANIA : ~ ACTION LA~c. JASON HOBBLE em~[ IN cusTODY : Defendants, ' ?. The plaintiff, DEBHA ELAM, through her a s, The Law Ot~ces o/Patrick F. Laue~, Jr., files tiffs Complaint for Custody a~ainst the Defendants, JASON HOBBLE anti RASHAAlq ELAM, antlin support; thereof, avers the 1. The Plaintit~ is DEBHA ELAM, an adult individual anti the maternal ~anclmother, who currently resi&es at 1826 Heishman Gardens, Ca~lisle, Cumbe~lan~l County, pennsylvania 1'/01~. an adult inrllvidua~ anti the natural 2. (a). The De/eh/ant is BASHAAN ELAM, Mother, who cur~entlF ~esi~es at 652 Oakville l~atl, 5hippensbu~, Cumberlan~ CountY, pennsylvania 1'/013. (b). An additional Defen&~nt, suppo~ive of Plaintiffs clahn, is JASON HOBBLE, an adult individual anti the natural father, who is cu~ntly ~nca~ce~ated in · · G~ater/ortl, pennsylvania. Graterfor~l State Correctional Institution, 3. The pla/nti~ seeks primsry physica~ cusW~l¥ anti le~a~ custodY, of the followin~ child: ~ DOB: 4~5~00, lyf. ~ 652 Oakvil~e Road LaShaan M. Hobble Shippensbu~, PA ~ae ch/ld was born out of wedlock. . _. o~ ^ z~ ELAM, who ~nfly 4. c~d ~ P~Y ~ ~e ~swdy o~ ~' . . ~e '~ ~ ,.-~ 17257 ~ ~ ma~ ~s at 652 O~e ~ad, S~PP~b~g' ~e~sy~v ~a~er, J~es ~, ~ ~e Def~t, R~ha~ E~- . 5. ~e ~d ~ ~ ma~ ~o~er ~om b~ ~u~ ~ 4, 2001 at ~e f~o~g a~: N~: Da~s: 1826 ~ o~e~ Debra EI~ ~ha~ ~ gS/00 ~) c~e, PA 17013 221 E. ~u~er S~et R~ha~ E~ Fr~ po~r 4/1~01 ~/1/01 c~e, PA 17013 ~o~e Po~ ~o~FS 2 ~ 652 Oakville Road Eashaau FAam James FJam 5/2101 to present Shippensburg, PA Lauris Mumma Laur/e's 2 child_~en 6. The Mother d the child is EAS~ ELAN[, who cu~ently res/des at 652 Oakville Road, ShiP9ensburg' Cumberland CountY, pennsylvania 17257, with the subject of this petition. The Mother is not married to the natural Father. 7. This location is au overcrowcled home; the previous location is an .. overcrowded apartment. i. 8. The Father of the chikl is JASON HOBBLE, who is cunenflY . natural Mother. · the ~ The Father is not marnecl to i' incarcerated at SCI-(]ratederd- ! ! !. I. [o. The Plaintiff ' ' .. · ..... ~u_~t of this Commonwealth- ch/Id currently penamg m v~ ~- 11. The plainti~ dees not know of a person not a party to the preceedings, which have physical custody of the child er clailns to have physical custody or visitation rights with respect to the clxild. · -- -ent welfa~ of the child willbe served by 12. The best interests ana pertain, granting the relief requested because: a home with adequate moral, a). The plaintiff can provide the child with and physical surroundings as requixecl to meet the clfild's needs; emotional, _ _... ~.w.o ~ll~ue to continue custody of the child; b). '['l~e ytamu~ ,~ -'----- and enjoys the love c). The plaintiff continuos to exercise parental duties and affection of the child. · not been terminated 13. Each parent whose parental rights to the chilcl have and the person who has physical custody of the child has been named as parties to this ' below, who are known to have action. All other persons, name~ will be given notice of the or claim to have a right to custody or visitation of the child pendency of this action and the riF,ht to intervene: Basis of Claim: Address: paternal Grandmother l~ame: 164 Faith Circle Kimberly Hawkins Carlisle, PA 17013 Steve Hobble, Sr., RD1, Box 561, 3Spring, PA 17264 paternal Grandfather V~q-IEB~FOBE, the plaintit~ zespect~lly zequests that this Honorable Couzt enter an Ozd~z g~antin[ cusW/ly of the chikl to the petitioner, DEBRA ELA-~ in accor~lance w/th any Sfipulaton d the part/es, or in the event the pat~es aze unable to execute such a Stpulat/on, to onte~ an Ozdaz ~ranting custodY, pa~al custotlY, or visitation of the chili to the Pet/t/onez puzsuant to §5313(a) d the Domestic Relat/ons Co&. Law Oi~ces o I. 2108 Mazket Stzeet, Aztec Building Camp Hill, pennsylvania 1'~011-4q06 ti ~ ~D~ 72655 Te~. (~t'h ~63.1800 ~ Date: : IN THE cOURT OF COMMON PLEAS OF DEBRA ELANI, : cUMBE~ coUNTY, PENNSYLVANIA · No. 01-2591 CIVIL ACTION LAW VS. ~ ]1,I CusTODY JASON HOBBLE and Defanclants, ....... ~, hereby verifies and states that: The undermsnea a~u,,,,,: 1. He is the attorney for the Plaintiff', Debra Elam; 2. He is author[zed to make th~s verification on behalf of the client(s); 3. The facts set forth in the fore_~oin$ Amended Complaint are knoWn to him and not necessarily to Ms client; 4. Ttds verification is intended to expedite the litigation; A ved/ication of the client will he supplied if demanded; 5. to the best 6. The facts set forth in the foreSoieg Amended Complaint are true and correct ot'hh knowledge, information, and belief; and subject to the penalties of 1S Pa. C.S.A. 7. He is aware that false statements herein ere made § 4904, relating to unswom falsification to authorities. DEBRA ELAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 01-28~9 ~,~?1 : JASON HOBBLE AND : CIVIL ACTION - LAW RASHAAN ELAM, : CUSTODY Defendants : INTERIM ORDER OF COURT AND NOW, this ~ '~Y~)~'~'~' day of ,N~,gc~, 2001, upon consideration of the attached Custody Conciliation SummanJ Report, it is hereby ordered and directed as follows: 1. The Maternal Grandmother, Debra Elam, shall have periods of partial physical custody of the minor Child, LaShaan M. Elam, born April 5, 2000, on alternate weekends from Saturday at 10:00 a.m. until Sunday at 6:00 p.m., and at other such times as the parties may mutually agree. 2. Counsel for the Plaintiff shall serve a copy of the Order upon the Defendant. BY THE COURT, Carol J. Lindsay, Esquire, 26 W. t ~ .,?,j,~,, ?.~ 9- O V'-O/ Jason Hobble, SCl Greterford /'-t DEBRA ELAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-2819 VS. JASON HOBBLE AND : CIVIL ACTION - LAW RASHAAN ELAM, : CUSTODY Defendants : ~U.~¥ODY 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 ~ CURRENTLY IN CUSTODY OF LaShaan M. Hobble April 5, 2000 Mother tod Conciliation Conference was held on August 9, 2001, with the following . .2 A. Cu..s ay___ ,,... ~ma~'nal Grandmother, Debra Elam, and her counsel, Marhn L inaiviaua s n at~enaan~u', t.= ,,,o,~-,, ' ' Markley, Esquire; the Mother, RaShaan Elam, and her counsel, Carol J. Lindsay, Esquire; the Father, Jason Hobble, did not attend. He apparently is incarcerated at SCI Graterford. 3. The parties reached an agreement in the form of an Order as attached. - - - "'~el~a Peel Greevy, Esquire Date Custody Conciliator