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HomeMy WebLinkAbout03-1733NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF AMANDA S. LOSH, : IN THE COURT OF COMMON PLEAS OF Plaintiff GEORGE R. BOWERMASTER Defendant :CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 03- /")$3 CIVIL : IN CUSTODY COMPLAINT FOR CUSTODY NOW comes the Plaintiff, Amanda S. Losh, by her attorney, Nathan C. Wolf, Esquire, and respectfully represents as follows: 1. Plaintiff is Amanda S. Losh (hereinafter "Mother"), who resides at 43 Subdivision Road, Newville, Cumberland County, Pennsylvania, 17241. 2. Defendant is George R. Bowermaster (hereinafter, "Father"), who resides at 101 South Side Drive, Newville, Cumberland County, Pennsylvania, 17241. 3. The parties are the natural parents of one minor child, namely: Tyler Michael Bowermaster, born February 2, 2003, age 2.5 months 4. The child has lived with the mother from the time of his birth until present. 5. Mother and Father are the natural parents of the child. 6. The child was born out of wedlock. 7. The child is presently in the custody of the mother. 8. The parties are currently unmarried. 9. Mother 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. 10. Mother has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 11. Mother 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. 12. Mother maintains a stable household and environment within which to raise the child. 13. The best interests and permanent welfare of the child requires that the relief requested herein be granted because the father has made unreasonable demands to see the child in terms of scheduling and because the father refuses to permit mother to inspect father's residence to make sure that father possesses those items necessary for the proper care and welfare of a young, infant child. 14. Mother has permitted Father to have periods of visitation in her home and has brought the child to father's home for visitation since the child was born. 15. On multiple occasions however, father has demanded to have extended periods of unsupervised visitation despite his failure to show up for periods of supervised visits on at least ten (10) separate occasions. 16. Father has threatened that even if he signs a custody agreement that he will not abide the terms, even if such agreement is made an Order of Court. 17. Mother believes that these threats will be carried out, thus threatening the best interests of the child and impeding the relationship between the mother and the child. 18. Mother believes and therefore avers that if father's rights to visitation and partial custody are not established and limited pursuant to an Order of Court, that the child will suffer irreparable harm as a result of father's actions. 19. Mother believes that the child's best interests would be served by an award of primary physical custody to her, and that an order should be entered establishing well- defined limits to father's rights to visitation and partial physical custody. WHEREFORE, Plaintiff, Jacob S. Kleckner, Jr., respectfully requests that the Court enter an order providing joint legal custoe',/and that the plaintiff have primary physical custody of the child. April ~_., 2003 Respectfully submitted, 35 East High Street, Suites 201/202 Carlisle, Pennsylvania 17013-3052 (717) 243-6090 Supreme Court I.D. No. 87380 VERIFICATIOI I I do hereby verify that the facts set forth in this petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. AMANDA S. LOSH AMANDA S. LOSH PLAINTIFF GEORGE R. BOWERMASTER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-1733 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, April 25, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, June 05, 2003 at 10:30 AM 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 apl~ear 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/ Hubert X. Gilroy, 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 Asseciation 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 JUL 0 g 2003 AMANDA S. LOSH, Plaintiff V GEORGE R. BOWERMASTER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2003 - 1733 CIVIL : IN CUSTODY COURT ORDER AND NOW, this t¥' day of ,~.~.~ ,2003, upon consideration of the attached Custody Conciliation Report,~ ~t i~ ordered and directed as follows: The Mother, Amanda S. Losh, and the Father, George R. Bowermaster, shall enjoy shared legal custody of Tyler Michael Bowermaster, born February 2, 2003. 2. Mother shall enjoy primary physical custody of the minor child. Father shall enjoy periods of temporary physical custody of the minor child as follows: On alternating weekends from Friday through Sunday, the times to be arranged between the parties. Every Wednesday evening and such other evenings during the week as the parties agree. At such other times as the parties agree, with the understanding that Father shall have liberal opportunity to enjoy custody with his minor child. Father shall handle transportation for exchange of custody, with the understanding that Father will not himself be driving the minor child until he has a license and an insured vehicle. Additionally, Father shall accommodate Mother to allow Mother a reasonable inspection of the Father's home in order for Father to verify that he has sufficient cribs, car scats and other necessary materials in order to care for the minor child on an overnight basis. For holidays, the parties shall share or alternate physical custody on holidays pursuant to a schedule worked out between the parties. This shall include all major holidays. The parties will work out their schedules so Father always has custody of the minor child on Father's Day and Mother always has custody of the minor child on Mother's Day. In the event either party is exercising a summer vacation and would like to have custody of the minor child during that time, that party shall notify the other parent at least thirty (30) days in advance and shall be entitled to exercise at least one week of uninterrupted vacation time with the minor child. This order is entered pursuant to an agreement reached by the parties at a custody conciliation conference. In the event either party desires to modify this order, that party may petition the court to have the case again scheduled with the conciliator for a custody conciliation conference. CC: Nathan C. Wolf, Esquire BY THE COURT, / George R. Bowermaster 101 South Side Drive Newville, PA 17241 AMANDA S. LOSH, Plaintiff V GEORGE R. BOWERMASTER, Defendant Prior Judge: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003 - 1733 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the child who is the subject of this litigation is as follows: Tyler Michael Bowermaster, born February 2, 2003. A Conciliation Conference was held on June 20, 2003, with the following individuals in attendance: The Mother, Amanda S. Losh, with her counsel, Nathan C. Wolf, Esquire; and the Father, George R. Bowermaster who appeared without counsel. 3. The parties agree to the entry of an order in the form as attached. Hubert X. Gil.r..oy, Esquire// Custody Concdmtor / W ' AMANDA S. LOSH PLAINTIFF V. GEORGE R. BOWERMASTER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2003-1733 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, February 04, 2011 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, March 17, 2011 at 8:30 AM 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. 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/ Hubert X. Gilroy, Es q. ?ik _ 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 rnCa .:? ,;2/7/// -/? 32 South Bedford Street r ?co Carlisle, Pennsylvania 17013 a17111 X G Telephone (717) 249-3166 ;<v -? S 17 AMANDA S. LOSH, IN THE COURT OF COMMON PLEAS OF (::? Plaintiff CUMBERLAND COUNTY, PENNS)VANIA-q ?_ vs. CIVIL ACTION - LAW x= Z -um x,rn r GEORGE R. BOWERMASTER, NO. 2003-1733 ??. =° Defendant IN CUSTODY i? =a o-.s 11 ?„C w C ) QM Prior Judge: The Honorable Kevin A. Hess -+ COURT ORDER AND NOW, this a day of March, 2011, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Court Room No. 4 of the Cumberland County Courthouse on the /G -4 day of , 2011 at ??c?..m. At this hearing, the father shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, this court's order of July 14, 2003, shall remain in place. 3. In the event legal counsel for the parties feel that additional involvement of the custody conciliator prior to the hearing may help resolve the case, counsel may contact the conciliator directly to request either a second conciliation or, possibly, a telephone conference with the conciliator and legal counsel. BY THE COURT, Mailed cc: ane Adams, Esquire 1Drew F. Deyo, Esquire Kevin A. ess, Judge AMANDA S. LOSH, Plaintiff VS. GEORGE R. BOWERMASTER, Defendant Prior Judge: The Honorable Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003-1733 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Tyler Bowermaster, born February 2, 2003 2. A Conciliation Conference was held on March 17, 2011, with the following individuals in attendance: The mother, Amanda S. Losh, with her counsel, Jane Adams, Esquire, and the father, George R. Bowermaster, with his counsel, Drew F. Deyo, Esquire. 3. Father has filed a petition to modify and is seeking additional periods of custody with the minor child. Although there was some significant negotiations at the conciliation conference, an agreement could not be reached. A hearing is required in this case. 4. The Conciliator recommends the entry of an Order in the form as attached: Date: March /9 '2011 xg 41' Hubert X. roy, Esquire Custody C nciliator Cn, ! ! +, IANE ADAMS ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esgadams@gmail.com AMANDA S. LOSH, VS. 2 ` I I V, !.i 14 PM 2: 1, u' `;UMBERLA iil D C0J'; : PENNSYLVAIWl Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW GEORGE R. BOWERMASTER, Defendant NO. 2003 - 1733 IN CUSTODY MOTION FOR CONTINUANCE AND NOW COMES, Amanda S. Losh, now known as Amanda S. Goodwin, by and through her Attorney, Jane Adams, Esquire and respectfully avers the following: 1. Plaintiff is Amanda S. Goodwin, (hereinafter "Mother"), formerly Amanda S. Losh. 2. Defendant is George R. Bowermaster, (hereinafter "Father"). He is represented by Attorney Drew Deyo. 3. The parties are the natural parents of Tyler Bowermaster, born February 2, 2003, age 8. 4. A custody conciliation was held on March 17, 2011. 5. The hearing in the above-captioned matter has been scheduled for June 16, 2011 at 9:30 a.m. before this Honorable Court. 6. Mother is requesting a continuance and anticipates that the parties are close to reaching a comprehensive agreement regarding this matter. 7. Father's counsel, Drew Deyo was consulted regarding the request for a continuance and agrees with this request. 8. This matter was previously scheduled before Judge Hess. WHEREFORE, Mother requests that the court continue the hearing in this matter. Respectfully submitted, Date: ?,, l Alhe Adams, Esquire I. . No. 79465 7 7 West South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR MOTHER AMANDA GOODWIN AMANDA S. LOSH, Plaintiff VS. GEORGE R. BOWERMASTER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAN18 - x - w W m C G CIVIL ACTION - LAW - NO. 2003 - 1733 -r--a1 T IN CUSTODY -- 5;c:: :. ORDER AND NOW, this 16 Day of ??-- , 2011, after review of the attached Motion for Continuance, the Motion is hereby granted and the hearing is continued generally, and may be rescheduled upon the request of either party. BY THE COURT: AGE J. cc: /Drew Deyo, Esquire Jane Adams, Esquire coP 41(0/? oi6 Amanda. Acc At in