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Home My WebLink About05-2250 JACQUELEE J. GRAHAM PLAINTIFF, : IN THE COURT OF COMMON PLEA OF : CUMBERLAND COUNTY, PENNSYL ANIA v. : CIVIL ACTION - LAW JACK E. REEDER, DEFENDANT. . . CIVIL TERM 0 y. :2.2 Sb ~:J ItA.-- : IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, Jacquelee 1. Graham, by and through her attorne IRWIN & McKNIGHT, and files the following Complaint for Custody: 1. The Plaintiff, Jacquelee J. Graham, is an adult individual residing at 15240 axton Run Road, Shippensburg, Pennsylvania. 2. The Defendant, Jack Reeder, is an adult individual currently residing at Yor County Prison, 3400 Concord Road, York, Pennsylvania, and is scheduled to be released J ne 3, 2005. 3. The parties are the natural parents of one (1) minor children, namely Cheyle e Graice Reeder, born May 14, 2004, age 11 months. 4. The child was born out of wedlock. 5. The natural mother of the child is the Plaintiff; the natural father of the child . s the Defendant. 6. The child has resided since birth at the following addresses: A At Apartment 134 Meadow Drive, Shippensburg, Pennsylvania, from birt until October of 2004, with Plaintiff and Defendant; 3 B. At 5145 Orrstown Road, Orrstown, Pennsylvania, from October 2004 unti February of 2005 with Plaintiff. C. From February of 2005 until the present, with Plaintiff at the address 1 sted in paragraph 1 above. 7. Plaintiff currently resides with the following persons: Name Relationship Wade Graham Jr. Grant Graham Dillin Graham Husband Son Son 8. Plaintiff knows of no other person who has a right to custody or partial cust dyof the child. 9. The Plaintiff desires primary physical and legal custody of the minor child, Cheylene Graice Reeder, subject to periods of supervised visitation with Defendant. 10. The best interests and permanent welfare of the minor child requires that the Court grant the Plaintiff's request as set forth above. WHEREFORE, Jaccqulee 1. Graham, respectfully requests that she be awarded pri ary physical custody and legal custody of the minor child, Cheylene Graice Reeder, as provided herein, with periods of supervised visitation for the Defendant as provided herein. 4 Date: May ;; ",f , 2005 Respectfully submitted, IRWIN & McKNIGHT By: /t t(;i=- Matthew A. McKnight, Esquire Attorney for Plaintiff 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court I. D. No. 93010 5 VERIFICA TION The foregoing document is based upon information which has been gathered your counsel and ourselves in the preparation of this action. We have read the statements made in this document and they are true and correct to the best of our knowledge, information and beli f. We understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. 4904, relating to unsworn falsification to authorities. Date: ~I/ Co:).;, .~CC:.) CERTIFICA TE OF SERVICE I, the undersigned hereby certify that on this 1.1 day of May, 2005, a copy of the C mplaint for Custody was served by first-class, postage prepaid United States mail in Carlisle, Pennsylvan'a upon the following: Jack E, Reeder York County Prison Inmate #: 87937 3400 Concord Road York, P A 17402-9007 IRWIN & McKNIGHT drltt///t/c // Matthew A. McKnight, Esquire Supreme Court J.D, No: 93010 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Attorney for the Plaintiff Jacquelee J. Graham ~ '~-r .., ~ ~ Jf ....... 0 ....... v~ " l:XJ l)o, u., ....... V; ......... - t (r 0 I'-,~ -:-0 ~:t;; o -n -..... ::L--:f lni~" '-~ I j. 17 C;l ,,r,, t -4...' \ .--..> "'----- ~-".. p..... ):~ -"";;': . , ..';'-1 t N -""i") I:') ern ) -':1 'f'- ~~ ~..... 1'.) c.., tY; JACQUELEE 1. GRAHAM PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 05-2250 CIVIL ACTION LA W JACK E. REEDER DEFFNDANT IN CUSTODY ORDER OF COURT AND NOW. Thursday, May 05, 2005 , upon consideration of the attached Complaint. it is hereby directed that parties and their respective counsel appear bcfore Jacqueline M. Verney, Esq. . tbe conciliator, at 4th Floor,. Cumberland County Courthouse'--~llrH~-,,- on ~.__Thu!sday,_~....,,,-Q2~}_o.O~___.. at 8:30 .AM for a Pr~-Hearing Custody Confcrence. At such conference, an effort will be made to resolve the issues in dispute; or if this c~nnot be accomplished, to detine and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older mav also be present at the conference. Failure to appear at the conference may provide, grounds for entry of a temporary or permanent order. Irhe court hereby directs the pllrties to furnish llny llnd llll existing Protectio-n from Abuse orders, Specilll Relief orders, llud Custody o-rders to the concililltor 48 hOurs prior to scheduled hearing. FOR THE COURT. By: /s/ facqueline M. Verney, E~_# Custody Conciliatorf" The Court of Common Pleas of Cumberland County is required by law to comply with thc Americans wilh Disabilitcs Act of 1990. For information about accessible facilities and reasonable accommodations av~ilable to disabled individuals having business before the court, please contact our office. All arrangements m$st be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled copference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT H,/\ 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 Bedfi.1rd Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ,'rf '*"'''f! ,frp ~ ,-pd /JpJ 9 ~ , . b 1 1IfT';V'1.t r1d'U1 _9) /l 5- . /b ~lW ~~' 11- ftif!"" Iilbr If! pJ"lf o\.' .") 'll CV .(. 'Y/ " 1." \ n."" ...~ .~ _.' , '" I ~ II ' '" ;, \- ...00t. -----------------------------/.. - .' . . . RECEIVED JUN 2 2 2005~' V JACQUELEE J. GRAHAM, Plaintiff : IN THE COURT Ol? COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-2250 CIVIL TERM JACK E. REEDER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this p:s \,,J day of ~~]) L- , 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Jacquelee J. Graham, and the Father, Jack E. Reeder, shall have shared legal custody ofCheylene Graice Reeder, born May 14,2004. Each parent shall have an equal right, to be exercised jointly with the otner parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. 2. Mother shall have primary physical custody of the child. 3. parties. Father shall have periods of partial physical custody as agreed by the 4. This Order is entered pursuant to an agreement reached 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. Another Conciliation Conference is scheduled for August 23, 2005 at 8:30 a.m. BY THE COURT, J. >- (I: Ln r ..? I'-~ 6;" ~z c- t:5~::: ~1 ccC2 .-- .-) !..L....i- .~ c)c. ~g: .s N -"!"" a:::LU ,,-"- F: :::::> -> ll_ U? =5 0 = t=::l "'"' (..) JACQUELEE J. GRAHAM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : 2005-2250 CIVIL TERM JACK E. REEDER, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: None 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 Cheylene Graice Reeder May 14,2004 Mother 2. A Conciliation Conference was held in this matter on June 21, 2005, with the following individuals in attendance: The Mother, Jacqudee J. Graham, with her counsel, Matthew A. McKnight, Esquire. Father, Jack E. Reeder, appeared pro se. 3. The parties agreed to the entry of an in Order in the form as attached. G,-;)/-{;':J~ Date f. L.-< /L< Vc'~ acq line M. Verney, Esquire J Custody Conciliator IY RECEIVED AUG 23 Z005 f' JACQUELEE J. GRAHAM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND t:;OUNTY, PENNSYLVANIA V. : NO. 2005-2250 CIVIL TERM JACK E. REEDER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this z..c; ~ day of 1<1 ,,-' ,2005, upon consideration of the attached Custody Co~ it is ordered and directed as follows: I. The prior Order of Court dated June 23, 2005 is hereby vacated. 2. The Mother, Jacquelee 1. Graham, shall have sole legal and sole physical custody ofCheylene Graice Reeder, born May 14,2004. 3. 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. BY THE COURT, I / J. cc: Matthew A. McKnight, Esquire, Co Jack E. Reeder, pro se 17995 Fannettsburg Road Fannettsburg, P A 17221 sel for Mother ?U-oo ~~ Vi ;-"'.;/!\TJ\~)i',: >;'-Jd ,UNnnr; , ':'F,~:,(,~j(tJ SS :;; Hd 9;; ~nv SUUl AtNlONOf-lLOt'd 3Hl :10 3CIJ:lO-(l31!:l JACQUELEE J. GRAHAM, Plaintiff RECEIVED AUG 23 ?nn, : IN THE COURT OF COMMON PLEAS OF r : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2005.2250 CIVIL TERM JACK E. REEDER, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., 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 Cheylene Graice Reeder May 14, 2004 Mother 2. A Conciliation Conference was held in this matter on August 23, 2005, with the following individuals in attendance: The Mother, Jacquelee J. Graham, with her counsel, Matthew A. McKnight, Esquire. Father, Jack E. RI~eder, did not appear. 3. The Honorable J. Wesley Oler, Jr. entered an Order of Court dated June 23, 2005 providing for shared legal custody, with Mother having primary physical custody and Father having periods of physical custody as agreed by the parties. 4. Mother requested the entry of an Order in the form as attached. .f-~3 v S- Date c ~~ A. k Jac line M. Verney, Esquire r Custody Conciliator .-.....\,rj" . :;~i *: v rs :2 Hd 92 ~nv SOUl lUW\"'. "('.' 1 3Hl:lO AOVi.l'l'lVn.LJUa . 301~:lO-{13ll:l