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HomeMy WebLinkAbout02-4289JASON L. CASSEL, Plaintiff, VS. : _. CHRISTY M. ANDREWS, : Defendant, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA : Civil Action At Law---Custody : Case No.._~_A~_~./:~ COMPLAINT FOR CUSTODY 1. The plaintiff is Jason Cassell., residing at 12 East Front Street, Shiremanstown 17011 County of Cumberland, Commonwealth of Pennsylvania, 2. The defendant is Christy M. Andrews, currently residing at 408 South Washington Street, Milford, Deleware County of Sussex, State of Deleware. 3. Plaintiff seeks custody of the following child: Name Address Age Corbin L. Cassel same as mother's dob 12/18/2000 lyf. 8 mo. 4. The child was bom out of wedlock. 5. The child is presently in the custody of Christy M. Andrews, who resides at 408 South Washington Street, Milford, Deleware County of Sussex, State of Deleware. 6. The biological mother of the child is Christy M. Andrews, currently residing at: 408 South Washington Street, Milford, Deleware County of Sussex, State of Deleware. 7. The mother has been separated from the father since 5/8/02, and is currently unmarried to the same. 8. The father of the child is Jason L. Cassel and is currently residing 12 East Front Street, Shiremanstown 17011 County of Cumberland, Commonwealth of Pennsylvania. 9. The father is separated but currently unmarried to the mother.. 10. The relationship of the plaintiffto the child is that of a biological Father. The Plaintiff currently resides with the following persons: Name Relationship Corbin L. Cassel Son 11. The 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. 12. The plaintiff has no other information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 13. 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. 14. The best interest and permanent welfare of the child will be served by Granting the relief requested because: VERIFICATION I verify that the statements made in this Complaint 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 falsification to authorities Date: lason L. C~sell, Plaintiff departed from the Commonwealth of Pennsylvania and is believed to be living within the State of Deleware (b) Defendant Mother has not provided father with any information as to her place of residence nor has she made any effort to disclose to father where or with whom the child may be residing. For these reasons father has been deprived of any rights of custody to his child on any level. (c) The mother heretofore has not had a stable environment within which to adequately raise the child and has during the recent past resided in a women's shelter. (d) The father is a resident of Pennsylvania in employed and can accommodate the child's needs by providing a stable, consistent and predictable environment. (e) Plaintiff, believes and therefore avers that he can continue to provide a predictable and stable lifestyle for which, which will be in the best interest of the child during his formative years and throughout his life. WHEREFORE, Plaintiff, Jason L. Cassell, respectfully requests for the aforementioned reasons, that the court grant and award her primary physical custody of the child. Dated: I -! GREGORY S. HAZLETT _ _~.outh. Marl~t Street Mechamcsburg, PA. 17055 (717) 790-5500 JASON L. CASSELL PLAINTIFF CHRISTY M. ANDREWS DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-4289 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, September 13, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , thc conciliator, at 39 West Main Street, Meehaniesbur{[, PA 17055 on Thursday, October 10, 2002 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve thc issues in dispute; or if this cannot be accomplished, to define and narrow thc issues to bc heard by the court, and to enter into a temporary order. All children age five or older may also bc present at thc 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/ Dawn S. Sunday, 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 JASON L. CASSELL, Plaintiff VS. CHRISTY M. ANDREWS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-4289 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this ~ dayof ~'~ , 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Jason L. Cassell, shall obtain a psychological evaluation to be performed by a professional selected by the Father. The purpose of the evaluation shall be to obtain an assessment of the Father's parenting capabilities in connection with the allegations concerning the Father's conduct in the ongoing Children and Youth Agency's investigation and to obtain recommendations regarding contact between the Child and the Father. The Father's counsel shall provide the evaluator with all available information concerning the Children and Youth investigation. The Father shall sign all authorizations deemed necessary by the evaluator in order to obtain information. The Father shall be responsible for all costs of the evaluation. The Father shall provide the results of the evaluation through counsel to the Mother's counsel promptly upon receipt. 2. The Mother, Christy M. Andrews, shall have primary physical custody of Corbin L. Cassell, bom December 18, 2000. 3. The Father shall have periods of supervised visitation on the Father's day off, one time per week, at an agency selected by agreement of the parties. During alternating weeks, the Father's supervised visitation shall take place at an agency located near the Mother's residence in Delaware and during the interim weeks, the visitation shall take place at an agency located near the Father's residence in Cumberland County, Pennsylvania. The Father's periods of visitation shall be scheduled to accommodate both parties' work schedules. Within 10 days of the date of the Custody Conciliation Conference, the parties shall select the supervising agencies in each party's locale and shall contact the agencies to schedule the first sessions. 4. Within 60 days of receipt of the evaluator's report, counsel for either party may contact the Conciliator to schedule an additional Custody Conciliation Conference to review the custody arrangements, if necessary. BY THE~~ CC.' Gregory S. Hazlett, Esquire Joan Carey, Esquire JASON L. CASSELL, Plaintiff VS. CHRISTY M. ANDREWS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-4289 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORi 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 Corbin L. Cassell December 18, 2000 Mother 2. A Conciliation Conference was held on October 10, 2002, with the following individuals in attendance: The Father, Jason L. Cassell, with his counsel, Gregory S. Hazlett, Esquire, and the Mother, Christy M. Andrews, with her counsel, Joan Carey, Esquire. The maternal grandmother, Barbara Harley, also attended the Conference. 3. The parties agreed to entry of an Order in the form as attached with the exception of the provision providing that the location for supervised visitation will be alternated between the parties' areas of residence, which requires the parties to share transportation on an alternating weekly basis, which is the recommendation of the Conciliator. Date ' Custody Conciliator