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Home My WebLink About00-05925 .......- ~,,~, , '"-'-'tJ , SCOTT L. SOWERS PLAINTIFF V. CRYSTAL L. WINDOMAKER DEFENDANT IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-5925 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 30TH day of AUGUST ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear beforeMoIissa P. Groovy, Esq. , the conciliator, at 214 SonatoAvonuo,Suito105, Camp Hill, PA 17011 onthe 2ND dayofOCTOBER,2000,at 9:15 A.M 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. FOR TIlE COURT, By: Isl Melissa P. Greevy. Esq. fj!J Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with DisabiIites 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 TIllS 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 ""' r; <5r. 0tJ 0/ s' o,?! ~ -.s~' 0 tJ , ~~"< ~~ '" -~." ., ~- '~ ~ ,-- T ~ -- ,-, -" ',,:rJl?HY 00 SFP -5 h'; 2: Ii~. CUlvki~-,:i:~;-1~~~<[) CQU[\rr)" PENNSYLI/,AN!/\ &;. to/'1lf4~ Z, 4' ~~ y;cnfd ~ ~ ~ t~ /n~ ~ I4~ ',' ~,<,~. . ~~~.-. :11'""';1, J" _1'l,Wl~~,_""~__""~;;r" _ ~.. ,,~ _,,_~~ .!l'.!ll~~~""~"~>llm~tml!lWlffl'~n~.t!if:I~""'!"!!!l!':jfl!I1~~~ '...-~--, ~-; .. SCOTT L. SOWERS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : N0a1-S9dS Civil Term CRYSTAL L. WINDOMAKER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this day of , 2000, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before , Esquire, the conciliator, at , Pennsylvania, on , the day of , 2000, at o'clock .m. 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. Either party may bring the child who is the subject ofthis custody action to the conference, but the child's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By 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. OFFICE OF THE COURT ADMINISTATOR CUMBERLAND COUNTY COURTHOUSE, 4TH FLOOR CARLISLE, PA. 17013 (717) 240.6200 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of COIl1lIlon Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accomodations 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. SCOTT L. SOWERS, Plaintiff v. CRYSTAL L. WINDOMAKER, Defendant ~ -" . -" .~. ..... . : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. OV" 69.:l j' Civil Tenn : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is SCOTT L. SOWERS, (hereinafter referred to as FATHER), who currently resides !it 309 Pine Road, Mount Holly Springs, Cumberland County, Pennsylvania. 2. Defendant is CRYSTAL L. WINDOMAKER, (hereinafter referred to as MOTHER), who currently resides at 253 Pine Grove Road, Gardners, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody and visitation of the following child: NAME Alyssa Marie Sowers ADDRESS AGE 253 Pine Grove Road Gardners, Pa. 4 The child was born out of wedlock. The child is in the custody of: MOTHER During the past five years, the child has resided with the following persons and at the following addresses: NAME Crystal Windowmaker Charles Windomaker Patricia Windomaker Matthew Windomaker ADDRESSES DATES 253 Pine Grove Road Gardners, Pa. 5/31/96 to present. .~~~ "II:ii~""""."" ~ ~ ~"""~ ----~ ~. " .. The mother of the children is: Crystal Windowmaker, currently residing at: 253 Pine Grove Road, Qardners, Pa. She is unmarried. The father of the children is: Scott Sowers, currently residing at: 309 Pine Road, Mount Holly Springs, Pa. He is married to Kelly Sowers. 4. The relationship of plaintiff to the children is that of F ATHER. The plaintiff currently resides with his wife, Kelly Sowers, Keefer Bemhisel (son of Kelly Sowers), and Lance Bernhisel (son of Kelly Sowers.) 5. The relationship of defendant to the children is that of MOTHER. The persons that the defendant currently resides with are: Charles Windomaker (father of defendant), Patricia Windomaker (mother of defendant), and Matthew Windomaker (brother of defendant). 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: Plaintiff has been denied all visitation with his daughter by Defendant. Plaintiff wants to see his daughter on a regular basis and spend QJ.Iality time with her. It would be in the best interest of the child for liberal and regular visitation to be granted because she would greatly benefit from her father's meaningful participation in her life. 8. 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 parties to this action. -r.'" ~~" .... "~ ~ '.- iltl;ii"c(I.: "". . WHEREFORE, Plaintiff requests the court to grant custody and visitation of the child. J 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 unsworn falsification to authorities. ( .pdJ6"~ :PraIntiff ' Respectfully submitted, Date: <6/ ct/ (jJ ane Adams, Esquire J.D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF '~;'a:i;'jja~ ~~~M1i1lm .~Jlilf~1 ..... ~ "~"'>7' '~_1Jj"V"'= _ __"'". " 'r-,c_e, -"~,. '1111 r .M - ...._,,~ ., . ~ ~ 0 0 8t c c::> 0 ~ :':;::.0" ,1 -od_' "., "~ ~ mf"-' c.= ~- Z-'-" "' ;-ii.JJ :Z',y "'- F ~ U)~> 1'0 -._")r-n &: -r" CO ~;~JO ~G !"-, t )> v ::':-';(.:J VJ ZO :::z: ~~~ j;lJ ~ c: r:~ OfTl Z :.[;i ~ =< W :0 -< " " . '>~,. d,', . ~c,j .\ OCT 2 0 200of/J r SCOTT L. SOWERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-5925 CRYSTAL L. WINDOMAKER, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this JIIAt day of O~ ,2000, upon consideration of the attached Custody Conciliation Summary Report, it is hereby directed and ordered as follows: 1. Legal Custody. The Father, Scott l. Sowers, and the Mother, Crystall. Windomaker, shall have shared legal custody of the minor Child, Alyssa Marie Sowers, born May 31, 1996. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof. with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Mother shall have primary phYSical custody subject to Father's rights of partial physical custody as follows: A. Father shall have a two-day overnight stay twice per month. Because Father's work schedule is a rotating, swing shift, his days off may occur on different days each week. However, presently Father's overnight twice- monthly overnight visitation shall be from Friday at 5:00 PM until Sunday at 5:00 PM. Additionally, Father shall have one Thursday overnight until Friday morning per month and one Thursday evening followed two weeks later by one Thursday evening from 5:00 until 9:00 PM. The parties shall share with each other their work schedules so that each are aware of Father's days off and which days he shall have for his periods of custody. 3. Holidays. A. Christmas. For Christmas 2000, Father shall have December 2200 through December 24th at 3:00 PM, and 9:00 AM until 2:00 PM on Christmas Day. To commence 2001, Father shall have custody Christmas Eve until 3:00 PM and on December 25th from 2:00 PM until December 29th each year. ~ ~"'~ . .,"- ,,",',;., '-- "" , No. 00-5925 B. Thanksgiving and Easter. Father shall have physical custody from 9:00 AM until 3:00 PM on Thanksgiving and Easter Days. C. Vacation. Father shall have one uninterrupted seven-day period of vacation during the first week of August each year when Father's employer closes business for that week. Father shall also have an additional four- day period of vacation time in the summer in a month other than August, unless otherwise agreed. Additionally, Father shall have four days after Christmas during the Child's school break and during which time Father's employer is closed for business. 4. In the event that either party takes the Child out of the jurisdiction for a period of 48 hours or more that party will notify the other parent of the telephone number and location where they will be staying. 5. This Order is temporary in nature and may be modified upon agreement of the parties. In the event that the parties may not agree, either party may petition the Court for modifICation and return to a Custody Conciliation Conference. ~ ~ r:P , ~. ,\/I,o'?- ~ Dis!: Jane Adams, Esquire, 117 S. Hanover Street, Ca~isle, PA 17013 Ka~ Rominger, Esquire, 155 S. Hanover Street, Ca~isle. PA 17013 " I I I ~ II lit '110.. - " ..-l!I!lt ~" ,- ~" .. i:'y' c".'.... ",., l __' (~. . u. '< CU1\/i;-::,::::' ,,~-, ,( /.J ;;\\"f\l Dp.J\'..~\l1 1//,\,,;:'" , I _J .1 'V I ~~/, _; '" , - ~,~ ...,.~--"-.,,,.,,~,.""'" ,I PliN' J l,DIJliFi;'LT r !JI!"'I""'J!, 0'" ,~ , - ,- '-~-" ., -,<<--- '-j"'i . , SCOTT L. SOWERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-5925 CRYSTAL L. WINDOMAKER, Defendant CIVil ACTION - LAW CUSTODY CUSTODY CONCILIATION SUMMARY REPORT 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 Alyssa Marie Sowers May 31. 1996 Mother 2. A Conciliation Conference was held on October 2, 2000, with the following individuals in attendance: the Father, Scott l. Sowers, and his attorney, Jane Adams, Esquire; the Mother, Crystall. Windomaker. Mother's counsel, Karl E. Rominger, Esquire, participated in part of the conference by telephone. 3. The parties agreed to an Order in the form as attached. }DJ;P(uuJ ()~~ \ Melissa Peel Greevy, Esquire Custody Conciliator Date