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Home My WebLink About00-03643 ~- ~ ." .'"1-'",.'. - _,,-",-'~,,___-';: "'-' 0-'_ "'';~'",''~' ,_,_n,-,,- _-.",". "i.-;--.- ,_"'-'- "". -- - -, < .---"~~-,,"H-'-;'J -~'N,':' ._,',,,", ;;'~f"'-'- (,,' ~'-":_;""''-"'>' '<.'~_', .,;[._' _:-'O',:;:,:~~: CHRISTOPHER WALLOWER and his Parents and Natural Guardians, RICHARD S. WALLOWER and CHERI L. WALLOWER, Plaintiffs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW vs. NO. 06" .31.43 CIVIL TERM , JENNIFER SILVA, Defendant. IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before Esquire, the Conciliator, on the day of 2000, at o'clock .m., in , Cumberland County, Pennsylvania, 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 shall also be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a Temporary or Permanent Order. BY THE COURT: Date: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County, Pennsylvania, is required by law to comply with the Americans with Disabilities 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. BY THE COURT: Date: J. . ,: ".-" . -,,-,,'~-" - ."'-,'" - c.<_ ~ '-, ,_. " >~".)~ - '" ': ;'-- - -- .', ~ - ---,. --' - ,- ,--'.0" ,-, ,- ;"'_~C_.__-"_"_"',_._<'" " '" ,-.,: ',,;;': -,;:- ";s;~,, __;;- -''''J~~ CHRISTOPHER WALLOWER and his Parents and Natural Guardians, RICHARD S. WALLOWER and , CHERI L. WALLOWER, Plaintiffs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW vs. NO. hi- .1'- Y.J CIVIL TERM JENNIFER SILVA, Defendant. IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiffs are CHRISTOPHER WALLOWER, a minor, and his parents and natural guardians, RICHARD S. WALLOWER and CHERI l. WALLOWER, residing at 5245 Meadowbrook Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is JENNIFER SILVA a minor, residing with her parents, JOHN SILVA and SHARON SILVA, at 8 Clover Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The Plaintiffs seek custody of a newborn child, KATHARINE ANNE SILVA, one month old, and presently in the neo-natal intensive care unit at Holy Spirit Hospital. The child was born out of wedlock, and the child presently is not in the custody of either parent. The mother of the child is JENNIFER SILVA, a minor, currently residing at 8 Clover Lane, Mechanicsburg, Cumberland County, Pennsylvania. She is single. I " .,''';-',-". '--" ~.- - ",..' -, The father of the child is CHRISTOPHER WALLOWER, a minor, currently residing at 5245 Meadowbrook Drive, Mechanicsburg, Cumberland County, Pennsylvania. He is single. 4. The relationship of the Plaintiffs to the child are that of father and paternal grandparents. The Plaintiffs currently reside at 5245 Meadowbrook Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 5. The relationship of the Defendant to the child is that of mother. The Defendants currently reside at 8 Clover Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 6. Plaintiffs have not participated as parties or witnesses, or'in any other capacity in other litigation concerning the custody of the child in this or another jurisdiction. 7. The Plaintiffs have no information of a custody proceeding concerning the child pending in a court of the Commonwealth. 8. The Plaintiffs do not know of any 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 granting the relief requested because Plaintiffs are willing to raise the child in their household. 10. Each parent whose parental rights to the child have not been terminated has been named as parties to this action. No person has physical custody of the child. C"..,>;,; _ _, ,'- ", .. -' . ~, ;: , "' -"~ WHEREFORE, the Plaintiffs request this Court to grant primary physical custody of the child to them. Respectfully submitted, FLOWER, FLOWER & LINDSAY Attorneys for Plaintiffs James D. Flower, r. 11 East High Street Carlisle, PA 17013 (717) 243-5513 1.0. No. 27742 Date: s:. 1 S- -Db , ~' , -< ._. ~_, . - ,c- - > :::.. ~,,-J:,< ~:- ,iC: <~ ., .-;, : VERIFICATION I, CHERI L. WALLOWER, the undersigned and Plaintiff in the within action, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 9 4904, relating to unsworn falsification to authorities. g~1/~ td~ heri L. Wallower Date: tf-;Jrf tfD -.......;...;-, '~""'_lj[jt~Jti.illliiJ y l'!irii'" 'f.".~'~]'r 1- - 1lI!.'1~~ j l ...0 " ~ -...0 , ~"~:';'V"'- L",,'~ -~~, 6<1' ~ $ ~ ~~ ~ d 8 c:~ ~ 00 CJ ?::{P Ji (") f,; ~r:.: g~: ";'- ~;;c:: 5~~! ~ -<. (:) C.J , (:.:::::. ::,Z;: c\ J:~-. ~ :.) Cl " (") ~'q :_:~-.! ,,--, -T, I-~\ :~i i~~ r: ~~ J::-' _D -< " ---- t:l:..-c:-----------'~--' -~ -. i \0 \ l'1O-- ; No Com\ \c\'\-\()V\ - (2ea"-l Z ved - '-\--I~ hcl.~ ~w\ c\..- Custod~ S-\-l f . - ~v(c ~ L___.________ _~____ ___ __., _ _____ _ ___ __ n_ __"" - '-----" .'-" " -,-.', ",,~",_"-.'-' cc-",,, .-~~~; '-4.~'."~o.,~_ -, , .' , ~,[l \ CHRISTOPHER WALLOWER and his Par'lmts and Natural Guardians, RICHARD S. WALLOWER and CHERI L. WALLOWER, Plaintiffs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW vs. NO. ()l>~ (, ~ :1 CIVIL TERM JENNIFER SILVA, Defendant. IN CUSTODY CUSTODY ORDER AND NOW, this -z.o day of J~ ,2000, upon consideration of the attached Stipulation of the parties, it is hereby ordered that RICHARD S. WALLOWER and CHERI L. WALLOWER shall have physical and legal custody of the child, KATHARINE ANNE SILVA, and shall be said child's legal guardians. . //1 \> A; t~ 11\,00 V if ~~s . i; .j Ii ii Ie,., ,< "",,,. ., '-',.-~, nn Ii ~<! ') n r>,' L: i q ,~c ,.' ...' '" .., I.. ',,"' , . ...- C'I d'i::,~:;,':,..,; .i:,~\_: i ;"'-:--',i !/\rr'y' ""'I "'---'.." '_,' ".1,..; ~..,.J'-' , P~"""'\'L\"'f'''' -'C:i\fJ\J\)( Jf\.\};PI I ,d' ,~ lIiI).,_,_, ,~ ~, '_,. ~r~ ,~~~ .,~,.,_~J~11" ' <"-' ,~ ,c"" .,'.. d:- ~.-, /.' j.~ ,--"" , ,F- " -. """,:-,~"<"";;",,;:-,,-.i';,,,>-"_--<,,,:c" .c>, ,_';~: '_' j;', , ~_.c'_" ,_'~ ',Ii' ~~ CHRISTOPHER WALLOWER and his Parents and Natural Guardians, RICHARD S. WALLOWER and , CHERI L. WALLOWER, Plaintiffs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW vs. NO. CIVIL TERM JENNIFERSILVA Defendant. IN CUSTODY STIPULATION FOR CUSTODY 1. A Custody Complaint has been filed in this matter. 2. Plaintiffs RICHARD S. WALLOWER and CHERI L. WALLOWER, the paternal grandparents of the child in question, wish to adopt the child, KATHARINE ANNE SILVA, and all parties hereto are willing to allow such an adoption to occur. All appropriate Consents to the adoption have been signed. 3. In order for Plaintiffs RICHARD S. WALLOWER and CHERI L. WALLOWER to relocate to Nashville, Tennessee, and to, allow the child, who was born prematurely and has considerable medical needs, to be covered under the medical insurance of RICHARD S. WALLOWER, all parties request that the Court enter an Order of Custody for the child in question in favor of RICHARD S. WALLOWER and CHERI L. WALLOWER, the proposed adoptive parents. . . . - <--',-,'2:/, - ~-" ,- -."";'_'0_ ,':' '"~ '..V' 'h? ci-'~",L-.,j,_-;:,""_,~;,,;;,;,,-,:,,),, ,,- - ~"", - - "~~, The parties hereto have hereunto set their hands and seals this ' fit.. ,2000. ~h/ Christopher Wallower ~~~ Richard S. Wallower ---- (I):f#4/ 'A./A)A'//~ Cheri L. Wallower FLOWER, FLOWER & LINDSAY ------- James D. Flower, Jr. Counsel for the Wallowers 11 East High Street Carlisle, PA 17013 ~.~ nnifer Silva ~L'L-. John Silva, Parent and Natural Guardian of Jennifer Silva ~~ / Sharon Silva, Parent and Natural Guardian of Jennifer Silva METTE, EVANS & WOODSIDE By ~w~ ().' . ' (. . "~ P. Daniel Altland Counsel for the Silvas 3401 North Front Street Harrisburg, PA 17110-0950 '.-"'C.'_-- r' , " ;-~"_" J_ , /i~'-,_ " ~: '~.lriiIi. --'r j" , ~,~ ..'\--.-' , , ",...,.:,,'" II ._.'>~"n'~ . ''''''''''''''''''! . () 0 () -o(~ 0 '.n S ~~j n7rr; . ,-,~ <,~U f,l :?: C.. C'} " 0', '.', (j) -< -\ r= ,-, '":~~ Ci ':I~ :r:~" ~L +t C~> < "'~" .~,.. () > ~,' (7) :.j n 1 C.: .2: :0 b! :< - ::0 ",- -< .~