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HomeMy WebLinkAbout02-2291JAMI K. SMITH, Plaintiff, LEANDER JAMES JORDAN, Defendant. : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO.O,~- .,7,2q/ ~ : CIVIL ACTION- CUSTODY COMPLAINT FOR CUSTODY Plaintiff, Jami K. Smith, by and through her attorney Gerald S. Robinson, Esquire, and the law firm of ROBINSON & GERALDO, respectfully requests the following: 1. Plaintiffis Jami K. Smith, an adult individual and the natural mother who currently resides at 321 Pratt Avenue, Carlisle, Cumberland County, PA. 2. Defendant is Leander James Jordan~ an adult individual and the natural father residing at 9510 Northdowns Lane, Huntersville, North Carolina. 3. Plaintiff seeks legal custody of Leander James Jordan, Jr., September 3, 2000, residing at 321 Pratt Avenue with Plaintiff. The child was bom out of wedlock. 4. The child is presently in the custody of Plaintiff, Jami K. Smith, who currently resides at 321 Pratt Avenue. 5. During the past five years, the child has resided Plaintiff at her current address. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 7. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. 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 with respect to the child. 9. The best interest and permanent welfare of the child will be served by awarding custody to Plaintiff. 10. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as a party to this action. WHEREFORE, the Plaintiff respectfully requests this Honorable Court to grant Custody to Plaintiff. Respectfully submitted, ROBIN~ ~ERALDO By: Gerald S. Robinson, Esquire Attorney I.D. No. 27423 4407 No~h Front S~'eet P.O. Box 5320 Harrisburg, Pennsylvania 17110 (717) 232-8525 Attorney for Plaintiff JAMI K. SMITH, Plaintiff, V. LEANDER J. JORDAN, Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.¸ CIVIL ACTION-LAW IN CUSTODY CERTIFICATE OF SERVICE I, Gerald S. Robinson, Esquire, do hereby certify that on the 7th day of May, 2002, I caused a true and correct copy of the Order to be served upon the following individual by certified first class mail/restricted delivery by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. Robert S. Dougherty Dougherty Law Office 737 Water Street Indiana, PA 15701 Respectfully submitted, ROBIN~/~;~'/. By: _~Ant~-~x-~t~'~'~ t9 Gerald S. Robinson, Esquire Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717) 232-8525 VERIFICATION I verify that ~he statements made in this Complaint are ~u¢ and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. JAMI K. SMITH : : PLAINTIFF : V. : 02-2291 : LEANDER J. JORDAN DEFENDANT : IN CUSTODY ORDER OF COURT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW AND NOW, Thursday, May 16, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Tuesday, June 11, 2002 at 12:30 PM 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 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 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/ Melissa 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 JAMI SMITH, Vo LEANDER J. JORDAN, Plaintiff Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2291 CIVIL ACTION- Custody PROOF OF SERVICE The undersigned makes the following return of service: the Complaint in Custody was served upon Robert S. Dougherty, Attorney for the Defendant, on May 9, 2002 at 737 Water Street, Indiana, Indiana County, Pennsylvania. The signed acceptance of service is attached hereto as Exhibit 1. SIGNATURE AND AFFIDAVIT I, Gerald S. Robinson, Esquire, certify that I am a competent adult not a party to this action. I verify that the statements made in this affidavit and return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsfication to authorities. Respectfully submitted, ROBINSON & GERALDO Dated: ~17~0 Gerald S. Robinson, Esquire Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaimiff · Complete items 1, 2, and 3. Also complete item 4 if Restfictsd Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: A. Received by (P/ease Pr/hr Clearly) [] Addressee tern 17 []Yes If YES, enter delivery address beiow: [] No 3. Service Type 1~ Certified Mail [] Registered [] Insured Mail [] Express Mail I~ Return Receipt for Merchandise [] C.O.D. 2. Article Number (Copy from service label) 7001 1940 0004 1686 ~416 102595-99-M- 1789 JAMI K. SMITH, Plaintiff LEANDER J. JORDAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2291 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER TO RELINQUISH JURISDICTION AND NOW, this 8th day of July, 2002, the counsel for parties having requested a thirty (30) day continuance on June 7, 2002, and the Conciliator having received no further request for the Custody Conciliation Conference to reconvene, hereby relinquishes jurisdiction of the above captioned matter. FOR~ [ Melissa Peel Greevy, Esquire/' ~,Custody Conciliator :159290 ¥iNVAqASNN~d ~LN ~0 .... '