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Home My WebLink About02-2323JASON FULTON, V. ILar.mm SHAFER, Defendant :IN THE COURT OF COMMON : CUMBERLAND COUNTY, PENNSYLVANIA :NO. ~) ~ - ~7~ : CIVIL ACTION- CUSTODY : COMPLAINT FOR CUSTODY AND NOW comes Plaintiff, Jason Fulton, by and through his attorney, Nora F. Blair, Esquire, fries this Complaint for Custody and in support thereof, avers as follows: 1. Plaintiff, Jason Fulton, is an adult individual residing at 205A South Market Street, Mechanicsburg, Pennsylvania. 2. Defendant, Raelee Shafer, is an adult individual residing at 403 Fifth Street, Summerdale, Pennsylvania. 3. Plaintiff seeks primary physical and legal custody of the following minor child: Jade Fulton PRESENT ADDP~SS 403 Fifth Street Summerdale, PA The child was bom out of wedlock. The child is presently in the custody of Raelee Sharer who resides at 403 Fifth Street, Summerdale, Pennsylvania. June 18, 1997 o During the last five years, the minor child has resided with the following persons and at the following addresses: Tina Blosser Don Blosser Eric Blosser Raelee Shafer Kaela Shafer Jason Fulton Raelee Shafer Kaela Shafer Tina Blosser Don Blosser Eric Blosser Raelee Sharer Raelee Shafer Dawnell Cekovich Gary Cekovich Megan Cekovich Lauren Cekovich Raelee Shafer Heidi Shafer Jeff (Heidi's paramour) Raelee Shafer Jason Hoekenberry Jason's parents Jason Fulton Raelee Shafer 403 Fifth Street Summerdale, PA 205A South Market Street Mechanicsburg, PA 403 Fifth Street Surnmerdale, PA Wertzville Road Mechanicsburg, PA Summerdale, PA Newport, PA Newport, PA DATES September 2001 to Present August 2000 to September 2001 May 2000 to July2O00 May 2000 to July2000 March 2000to July2000 January2OOOto March 2000 September 1999to January2000 Jason Fulton 691 Caution Drive August 1999 to Raelee Shafer Dauphin, PA September 1999 Jason Fulton Raelee Sharer Jason Fulton Raelee Sharer Jason Fulton Raelee Shafer 5D Pfaust Road Duncannon, PA 691 Caution Drive Dauphin, PA 5F Pfaust Road Duncannon, PA August1998 to August1999 June 1998to August 1998 June 18,1997to June 1998 o The Father of the minor child is Jason Fulton, residing at 205A South Market Street, Mechanicsburg, Pennsylvania. Jason Fulton is not married. The Mother of the minor child is Raelee Shafer, currently residing at 205 fifth Street, Summerdale, Pennsylvania. Raelee Shafer is not married. The relationship of Plaintiff to the minor child is that of Father. The Plaintiff currently resides with the following persons: None 11. The relationship of Defendant to the minor child is that of Mother. 12. The Defendant currently resides with the following persons: NAME Tina Blosser Don Blosser Eric Blosser Jade Fulton Kaela Shafer Grandmother Grandfather Uncle Daughter Daughter 13. There had been a custody action filed in Perry County. The p~ies reconciled after an Order was entered and the provisions of that Order have not been followed by the parties recently. Plaintiff has not participated as a party or witness, or in another capacity, in any other litigation concerning the custody of this minor child in this or another court. 14. Plaintiff hss no information of a custody proceeding concerning this minor child pending in a court of this Commonwealth or in another state or commonwealth, except as indicated in paragraph 13 above. Both parties now reside in Ctunberland County and the child has resided in Cumberland County for more than six months. 15. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the minor child or claims to have custody or visitation rights with respect to the minor child. 16. The best interest and permanent welfare of the minor child will be served by granting the relief requested because Plaintiff will provide a more stable and nurturing environment for the minor child. Plaintiff currently lives in a two bedroom apartment. Defendant, the parties' daughter and Defendant's other daughter live in one bedroom at the home of Defendant's grandparents. In addition, Defendant has been unable to care for the parties' daughter on a full-time basis because of some problems in Defendant's life. 17. Each parent whose parental rights to the minor child have not been te~-i~dnated and the person who has physical custody of the minor child have been named as p~ies to this action. WHERE~ORE, Plaintiff requests that Your Honorable Court grant primary physical and legal custody of the minor child to Plaintiff with visitation to Defendant as the parties may agree. Supreme Court ID #45513 5440 Jonestown Road Post Office Box 6216 Harrisburg, PA 17112-0216 (717) 541-1428 VERr~CATION I verify that the statement made.!n the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that the statements therein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. JASON FULTON : : PLAINTIFF V. 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-2323 CIVIL ACTION LAW RAELEE SHAFER DEFENDANT : IN CUSTODY ORDER OF COURT 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 I'. Greev~, Esq. , the conciliator, at 301 Market Street, Lemo}tne, PA 17043 on Tuesday, June 18, 2002 at 2:00 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 Disabihtes 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 JASON FULTON, RAI~ ,~g. S~ Defendant :IN TI-lg COURT OF COMMON PI.PAS, : CUMBEHLAND COUNTY, PRNNSYLV~ : NO. 02-2323 Civil Term : : CIVIl. ACTION- CUSTODY : AFFIDAVIT OF SERVICE I, Nora F. Blair, Esquire, hereby certify that a true and correct copy of the Complaint for Custody was served on the Defendant by certified m~il, restricted delivery, return receipt requested, on May 23, 2002, addressed as follows: Raelee Shafer 403 Fifth Street Summerdale, Pennsylvania 17093 The return receipt card is attached hereto marked Exhibit "A" and incorporated herein by reference. DATED: l~ori~F. Blair Supreme Court ID 45513 5440 Jonestown Road Post Office Box 6216 Hm-,-isburg, PA 17112-0216 (?17) 541-1428 · CompMte Items 1, 2, and · Print your name and addre~ so that we can tatum the'card to you. · Atta~ this c, ard to the I~c,I to: If YES, enter deliv~y address below: No Certified Mall [] Expre~ Mail [] Registe~d "'Ji~,d:l~um Receipt for Memhandise PS Form ~8'11, August 200~ Domestic Return ~ece~pt 102595-01 -M-2509 JASON FULTON, plaintiff Ve Defend_ant :IN THE COURT OF COMMON PI.P. AS, : CUMBERLAND COU17I~, PENNSYLVANIA : : NO. 02~2323 Civil Term : : CIVIL ACTION - CUSTODY CERTIFICATE OF SERVICE I hereby certify that I have this date served a copy of the Order of Court dated May 24, 2002, setting a Pre-Hearing Custody Conference for July 2, 2002, at 8:30 a.m., on the person in the manner stated below which service satisfies the requirement of Pa.R.C.P. No. 440. SERVICE BY FIRST CLASS MAIL TO: Raelee Shafer 403 Fifth Strcct PO Box 95 Summerdale, Pennsylvania 17093 Date: May 28, 2002 JASON FULTON, RAELEE SHAFER, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2323 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER TO RELINQUISH JURISDICTION AND NOW, this 22nd day of August, 2002, the parties having requested a thirty (30) day continuance on July 22, 2002, and the Conciliator having received no further request for the Custody Conciliation Conference to reconvene, hereby relinquishes jurisdiction of the above captioned matter. ~ ~elissa pe~l-Greevy, Esquire ustody Conciliator :160811