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Home My WebLink About05-2157 VS. IN THE COURT OF COMMON PLEA CUMBERLAND COUNTY PENNSYLVANIA NO. i.) S - ;2)~J ~ CIVIL ACTION - LAW CUSTODY STEPHANIE LYNN JACKSON, PLAINTIFF NELSON EZRA CHAMBERS, DEFENDANT CUSTODY COMPLAINT 1. The Plaintiff is Stephanie Lynn Jackson, an adult individual residing at 24 Fieldstone Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. Plaintiff resi s III a single family home owned by her father. 2. The Defendant is Nelson Ezra Chambers, an adult individual residing at 50 oan Drive, York Haven, York County, Pennsylvania 17370. 3. Plaintiff seeks shared legal custody and primary physical custody of her so a. CARTER EZRA CHAMBERS (D.O.B. 10/16/04, Age 6'/z Month) residing with Plaintiff at 24 Fieldstone Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. b. The child was bom out of wedlock. 4. Since his birth on October 16,2004 the infant has always resided with the Plaintiff as his primary caregiver at the following addresses: Plaintiffs home in Mechanicsburg (approximately 3V2 months); and Defendant's home in York Haven (approximately 3 months) 5. The Mother of the child is Plaintiff Stephanie Lynn Jackson. 6. The Father of the child is Defendant Nelson Ezra Chambers. 7. The relationship of the Plaintiff to the child is that of Mother. ~ 8. The relationship of the Defendant to the child is that of Father. 9. Plaintiff has not participated as a party or witness or in any other capacity in 0 her litigation concerning the custody of the child in this or another court. 10. Plaintiff has no information of a custody proceeding concerning the child pe mg in another court of this Commonwealth. 11. 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 of the child. 12. The best interests and permanent welfare of the child will be served by gran ing the relief requested becanse: a. Mother has been the primary caregiver for the child since his birth. b. Father's work schedule and social life do not permit him to properly care for an infant c. Father has repeatedly told Mother that if she "does something stupi "he will seek primary custody and/or keep the child from being with hi Mother. d. Father has repeatedly told Mother that if she does not seek child s pport he does not want to be part of the child's life. In fact, he voluntari y chose not to see the child for several weeks from December 2, 2004 thr gh February 1, 2005 for this reason. e. Father refused to have his name placed on the child's birth certifi ate at the hospital at birth. 2 , 13. Each parent whose parental rights to the child have not been terminated and th person who has physical custody of the child have been named as parties to this action. 14. The best interests of the child will be served by granting the requested relief. WHEREFORE, Mother seeks an Order granting her primary physical custody oft e child and shared legal custody with periods of visitation with Defendant. Respectfully submitted, ./ BY: / ,/ Steven owell, Esquire 619 Bridge Street New Cumberland, P A 17070 (717) 770-1277 Supreme Court LD. 62063 Attorney for Plaintiff ,/ 3 VERIFICATION I hereby verify that the statements made in the foregoing document are true and corre to the best of my knowledge, information and belief. I understand that false statements herein e made subject to the penalties of 18 Pa. C.S.A. 94904, relating to unsworn falsification to authorities. BY: ~J-4lh~~~V!M / Stephanie Lynn Jackson ~ v Date: 1/ I ...., c.~ -.-,-.110-, ';' t./\ v '-...../ /.-,~,.- ,~ . 7::s ')~. ~\..) -- 0"'\'- u-:1 .::::-> '-"~ ~ ~. ~ <...f".. ~ --" "-'- -- ,-... ~ ~ ""')> (") .....> ~ c g ::~ <J' -:::) i.~: ~ ..-\ :;:::..,., n":l f-n .-- ::;. ~~:;:'\ ;;:0 -0\0; /, . "" U~'rl: -n i!? ~ ("") \ -<'-., ~ .-0 r~" f ",,"'."" :JI-"', ~,::;: ? .,,,.--1"1, :2:(- ::;<: C;>'B ,.t(;:-I, - c5f'"1 C.: - ~.A ~7 JO ~ .r:- U> _-<C STfPHANIE LYNN JACKSON i PLAINTIFF i I I , I I I N~LSON EZRA CHAMBERS , DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 05-2157 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, _~Thu~sday, April 28, 2005 , upon consideration of the attached Complaint. it is he eby directcd that parties and their respective counsel appear heforc Melissa P. Groovy, Esq. . the conciliator, at DJ l\:flllll.ov.e's,I.901 State St., Camp Hill, PA l70Il on .___J'ridaY,l.llll_o_03,_~005 ___._ at 1:00 PM for aPe-Hearing Custody Conference. At such conference, an effort will be made to rcsolve the issues in dispute; or if this annen bc accomplished, to define and narrow the issues to be heard by the court, and to cnter into a temporary order. All children agc five or older may also be present at the confercnce. Failure to appear at the conference may provid 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, Sped' I Relief orders, and Custody orders to tbe conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: _/sl Meliss,a P. Gree~'1:.-.~ Custody Conciliator I J The Court of Common Pleas of Cumberland County is required by law to comply with the Americans .ith Disabilites Act of 1990. For infon11ation about acccssible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements nlust be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled c~nference Or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT A VE 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 Carli sic, Pennsylvania 17013 Telephone (717) 249-3 166 dl?t~ t07?"J::;< fzo /1 f?VjI~'7)vt( /fd-4j ~J ~ ~I ?'J1j;1i1, fiv1- rl1YW~) -r?J 9S:\ lid 2- l'dI.IS,:r,7 f.;, uUv ----- ------------->--------- 50 c 5- .517 r5 >17 f';; STEPHANIE LYNN JACKSON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO. 05 - 2157 VS. NELSON EZRA CHAMBERS, DEFENDANT CIVIL ACTION - LAW CUSTODY PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Upon Plaintiffs request please mark the above captioned case as discontinued without prejudice. Respectfully SUb. m~itted' / / BY: .. ,A~ ~en Howell, Esquire /619 Bridge Street New Cumberland, P A 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney for Plaintiff Date: May 26, 2005 Certificate of Service I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served upon all counsel of record via postage prepaid, first class United States Mail addressed as follows: Melissa Greevy, Esquire (Custody Conciliator) (Via Telecopier 761-3015) Johnson Duffie 301 Market Street Lemoyne, PA 17043 Richard Rupp, Esquire (Counsel for Defendant) Rupp & Meikle P.O. Box 395 Camp Hill, PA 17001-0395 - Date: May 26, 2005 C) ,..., 0 = (.- C::::J -n ,;;";'\ -< \\1 -<... c,;, -;:; (,,) 01 C-. -' RECEIVED JUN 07 Z005;V STEPHANIE LYNN JACKSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-2157 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY v. NELSON EZRA CHAMBERS, Defendant ORDER TO RELINQUISH JURISDICTION AND NOW, this 6th day of June, 2005, counsel for the Plaintiff having filed a Praecipe to Discontinue on May 31, 2005 in the above captioned action, the Conciliator hereby relinquishes jurisdiction of the above captioned matter. FOR THE COrL) ~U) lV- Melissa Peel Greevy, Esquire Custody Conciliator :252178 0 .-.> ~ ~.-' g <. <:;.1'\ <- ~--n r C' n'"\;.:;;;:; .- :Bf~:1 - Cf' '?, () ~i-l :0" ) --j, -~~ ,>' .(~) ;;'" '2 ::2, [11 U1 :1J u:> ...;; -