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HomeMy WebLinkAbout01-4584BRYON N. JUMPER, Plaintiff/Petitioner Vo AMY S. FISHER, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CIVIL TERM IN CUSTODY PETITION FOR CUSTODY AND NOW comes the Petitioner, Bryon N. Jumper, by his attorneys, Irwin, McKnight and Hughes, and presents the following Petition for Custody. The Petitioner is Bryon N. Jumper, an adult individual residing at 33 South High Street, Newville, Cumberland County, Pennsylvania 17241. The Respondent is Amy S. Fisher, an adult individual residing at 19 Rays Drive, Newville, Cumberland County, Pennsylvania 17241. The parties are the natural parents of one minor child, namely Alexis S. Jumper, bom December 28, 1999, age sixteen (16) months. The Petitioner desires primary physical custody and primary legal custody of Alexis S. Jumper, with periods of visitation to Respondent as the parties agree. The best interests and permanent welfare of the child require that primary physical and primary legal custody of the child be in Petitioner. WHEREFORE, Petitioner, Bryon N. Jumper, respectfully requests that he be awarded primary physical custody and primary legal custody ofAlexis S. Jumper, as provided herein, with periods of custody to Respondent as the patties agree. By: Respectfully submitted, ~/~IRWIN' McKN~UGHES Marcus A. McKni//II~I, Esquire Attorney for Petitioner, Bryon N. Jumper 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court I. D. No. 25476 Date: July 30, 2001 VERIFICATION The foregoing Petition for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unswom falsification to authorities. BP~Y~",I N. JU1VI~EK/ Date: July 30, 2001 BRYON N. JUMPER PLAINTIFF V. AMY S. FISHER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 014584 CIVIL ACTION LAW IN CUSTODY AND NOW, Monday, August 06, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse~ Carlisle on Wednesday, September 05, 2001 at 10:30 for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to del'me and narrow the issues to be heard by the court, and to enter in~o a temporary order. AIl children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or pe~'manent order. The court hereby directs the parties to fnrnish 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/ _l'acqueline M. Verney. Esq. i~ 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 BYRON N. JUMPER, Plaintiff AMY S. FISHER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA _. : NO. 2001-4584 CIVIL TERM : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this ~19 dayof .~~ ,2001, upon consideration of the attached Custody Conciliatl~'~-R~ort, it is ordered and directed as follows: 1. The Father, Byron N. Jumper, and the Mother, Amy S. Fisher, shall have shared legal custody of Alexis S. Jumper, born December 28, 1999. Each parent shall have an equal right, to be exemised jointly with the other 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, with Father having periods of partial physical custody as the parties agree. 3. Mother shall withdraw the formal request for child support, since the parties have worked out an informal support agreement. 4. This Order is entered pursuant to an agreement of the parties 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. cc: Marcus A. McKnight, III, Esquire, Counsel for Father Amy J. Fisher, pro se ~ ~,~i~ ~'./0. o/ 19 Rays Drive / )~,~-, Newville, PA 17241 BRYON N. JUMPER, Plaintiff V. AMY S. FISHER, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 2001-4584 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY 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 1N CUSTODY OF Alexis S. Jumper December 28, 1999 Mother 2. A Conciliation Conference was held in this matter on September 5,2001, with the following individuals in attendance: Father's counsel, Marcus A. McKnight, III, Esquire, and the Mother, Amy S. Fisher, pro se. 3. The parties agreed to entry of an Order in the form as attached. Date ~ey, Esquire~-~ Custody Conciliator