IN THE SUPERIOR COURT OF NEW JERSEY
COMPLAINT FOR CUSTODY OF CHILD AND PARENTAL TIME
Plaintiff JAHMEAN JACKSON KEENAN JACKSON (“Plaintiff”), pro se, brings and hereby submits this complaint against Defendant BRIDGET SEMBER, Defendant LAURA SEMBER, Defendant DONALD SEMBER and Defendant MARCEL ROGERS (collectively referred to as “Defendants”), and in support thereof, aver as follows:
- NATURE OF THE ACTION
- This is an action for Child custody and parental time.
- Plaintiff is the Child’s biological parent.
- Plaintiff seeks custody of the Child, born on
- Plaintiff alleges it is in the best interest of the Child that this complaint be heard and orders granted as prayed herein.
- THE PARTIES
- Plaintiff Jahmean Jackson, is an adult African-American male residing within Easton, Pennsylvania.
- Defendant Bridget Sember, is an adult Caucasian female residing within the State of New Jersey.
- Defendant Laura Sember, is an adult Caucasian female residing within the State of New Jersey.
- Defendant Donald Sember, is an adult Caucasian female residing within the State of New Jersey.
- Defendant Marcel Rogers, is an adult African-American male residing within the State of New Jersey.
- JURISDICTION AND VENUE
- The court has jurisdiction of this matter pursuant to N.J.S.A. § 2A:34-65.
- FACTUAL ALLEGATIONS
- Defendant Bridget Sember enjoyed 100% custody of the Child. The Plaintiff was allowed parental time with the minor, which the Defendants were obliged by court order to allow access to the minor.
- Since Dec 18, 2019, the Plaintiff was unlawfully denied visitation rights by the Defendants herein. The Plaintiff has attempted to exercise his right to see the minor, but the same has received strong opposition from the Defendants.
Visitation rights and the Sembers
- Defendant Bridget Sember being the biological mother of the minor was awarded sole custody of the minor. In addition to the above, the Plaintiff was awarded visitation rights with the minor. Defendant Bridget Sember was obliged to provide and grant access to the minor.
- Plaintiff enjoyed visitation rights which have been conducted under supervision. Among the parties responsible for supervision of such visits are Defendants Donald Sember and Laura Sember, the grandparents to the minor.
- However, the Defendants conspired and colluded to interfere with and deny the Plaintiff his visitation rights.
- Defendant Bridget Sember justified this action by claiming and alleging that the Plaintiff’s visitation rights had been revoked. However, the Plaintiff has been served with no notice alluding to revocation of this right.
- Following denial of the Plaintiff’s visitation rights, Defendant Bridget Sember disclosed to the Plaintiff that he cannot recover his visitation rights. Defendant Bridget Sember further claimed to have engaged in relations of a sexual nature with Defendant Marcel Rogers.
- Defendant Bridget Sember further alluded that Defendant Marcel Rogers advised and duly authorized the denial of the Plaintiff’s visitation right on allegations that the Plaintiff is mentally disabled and incapacitated.
- Defendant Marcel Rogers persuaded and convinced Defendant Bridget not to allow the Plaintiff to visit the minor until such a time that the Plaintiff is subjected to a mental assessment.
- The Defendants were malicious and had no intention of recovering or preserving the Plaintiff’s visitation rights as no steps were taken to subject the Plaintiff to a mental assessment.
- Denial of the Plaintiff’s visitation rights were premised on falsehoods.
- The Sembers have for a long time demonstrated intense dislike for the Plaintiff as on several occasions he has been referred to as a nigga/nigger by the Defendants. The use of the word has at all times been coupled with intense willful dislike for the Plaintiff.
Defendant Marcel Rogers
- Defendant Marcel Rogers is an employee of the State and works as a social worker at the Somerset children and family office.
- Marcel has persuaded and convinced Defendant Bridget Sember to abandon her obligation to allow the Plaintiff access to the minor.
- Defendant Marcel Rogers has without proper justification tampered with the visitation rights of the Plaintiff. No report has been filed warranting the denial of the Plaintiff’s visitation rights.
- The Plaintiff is informed and believes, and upon such information and belief alleges Defendant Bridget Sember disclosed to the Plaintiff that he cannot recover his visitation rights. Defendant Bridget Sember further claimed to have engaged in relations of a sexual nature with Defendant Marcel Rogers.
- The Plaintiff is concerned for the best interest of the Child and submits to the authority of the Court to determine in favor of the Child’s best interest as it may see fit.
- Plaintiff is apprehensive that the Sembers intend not only interfere with his visitation rights, but also to inflict serious damage to the Plaintiff’s relationship with the minor.
- As a result of the Defendants’ actions, the Plaintiff has missed a majority of his child’s life.
- As a result of the Defendants’ actions, the Plaintiff has lived in fear of never seeing his child or being a part of the minor’s life.
- As a result of the Defendants’ actions, the Plaintiff has developed and suffered depression and post-traumatic stress disorder.
PRAYER FOR RELIEF
WHEREFORE, the Plaintiff respectfully requests the Court to:
- Award Plaintiff sole legal and sole physical custody of the Child.
- Order Defendant Bridget Sember be and is subjected to drug and substance abuse testing.
- Award the Defendants supervised visitation rights.
- Award the Plaintiff compensation for emotional distress and suffering
- Provide such other and further relief as the Court finds just and proper.
|Dated: ____________________||Respectfully submitted,|
|Suhila Cassini4370 Strathdale Ln, West Bloomfield, MI. 48323||SUHILA CASSINI Pro Se|
I, Suhila Cassini, solemnly swear or affirm under criminal penalties for the making of a false statement that I have read the foregoing complaint for custody and that the factual statements made in it are true to the best of my personal knowledge, information and belief.
|Dated: _____________________||Respectfully submitted,|
4370 Strathdale Ln,
West Bloomfield, MI. 48323
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