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Home My WebLink About01-04615DANA L. BOWMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. SCOTT E. BOWMAN • 01-4615 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, August 06, 2001 ,upon consideration of the attached Complaint, it is hereby duected that parties and their respective counsel appear before Dawn 5. Sunday, Esq. ,the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, September 04, 2001 at 11:00 a.m. for aPre-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. 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~ ls/ Dawn S. Sunda, Esc~~~~ 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 ~fr~~ni,~sNrJ~~ ur~nc~~ a~~.~n:ya~~vn~ Gc ~~ l~c; i.- ~Cit1 'J ~Ji-'~-.__ is -~~w~~~~e_ ~_ _ _ ~. DANA L. BOWMAN, Plaintiff v. SCOTT E. BOWMAN, Defendant r IN TBE COURT OF COMMON PLEAS COb18ERLATID COUNTY, PENNSYLVAN NO. 2001 4(, f, CIVIL TERM CIVIL ACTION - LAW CUSTODY ACTION ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before _ Esquire, the Conciliator, at on , 2001, at _.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 children who are the subject of this custody action to the conference, but the children'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, 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, PA 17013 (717) 240-3166 DANA L. BOWMAN, Plaintiff v. SCOTT E. BOWMAN, Defendant IN THE COURT OF COMMON PLEAS CUN~ERLAND COUNTY, PENNSYLVAN NO. 2001 - 4G /J~ CIVIL TERM CIVIL ACTION - LAW CUSTODY ACTION CUSTODY COMPLAINT TO THE HONORABLE JUDGES OF SAID COURT: 1. The Plaintiff is Dana L. Bowman residing at 226 Susquehanna Avenue, Enola, Cumberland County, Pennsylvania 17025. 2. The Defendant is Scott E. Bowman residing at 2404 New York Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff seeks legal custody and primary physical custody of the following children: NAME PRESENT RESIDENCE Q Scott E. Bowman, Jr. 226 Susquehanna Avenue 08/10/85 Enola, PA Jayson R. Bowman 08/20/95 Joshua S. Bowman 08/20/95 The children were born in wedlock. The children are presently in the custody of Dana L. Bowman who resides at 226 Susquehanna Avenue, Enola, Cumberland County, Pennsylvania. ~} During the past five years, the children have resided with the following persons and at the following addresses: Persons Addresses Dates Mother 226 Susquehanna Avenue 08/99 - present Enola, PA Mother 410 Brick Church Road 04/98 - 08/99 Enola, PA Mother & 125 Altoona Avenue 10/97 - 04/98 Father Enola, Pa Mother & 4 Marshal Drive 94 - 10/97 Father Camp Hill, Pa The mother of the children is Dana L. Bowman who currently resides at 226 Susquehanna Avenue, Enola, Pennsylvania. She is married. The father of the children is Scott E. Bowman who currently resides at 2404 New York Avenue, Camp Hill, Pennsylvania. He is married. 4. The relationship of Plaintiff to the children is that of mother. The Plaintiff currently resides with the following persons: Name Scott E. Bowman, Jr. Jayson R. Bowman Joshua S. Bowman Jean Stimeling Relationship Son Son Son Mother 2 ~~ J P 5. The relationship of Defendant to the children is that of father. The Defendant currently resides with the following persons: Name Relationshiv Patricia Bowman Mother 6. Neither party has participated as a party nor witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff does not know of a person not 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: A. Plaintiff can properly care for her children. B. Plaintiff can provide a loving home. C. Plaintiff will place her children's interest before her own. 8. Each parent whose parental rights to the children has not been terminated and the person who has physical custody of the children has been named as parties to this action. 3 • J Plaintiff requests this Honorable Court to grant her legal custody and primary physical custody of her children, subject to defendant's right to partial physical custody. Respectfully submitted, ~ ~ ~ Thomas D. Gould, Esquire ID #36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 VERIFICATION I, Dana L. Bowman, hereby certify that the foregoing CUSTODY COMPLAINT is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 10 14~ '~r~/~()) ~LI.I~-' /i ~Q(,10 Dana L. Bowman Plaintiff 4 [ 4 ~~ ti ~ J v~ ~ C `~ c ~~ ~~ A ~C~ " ~~ ~ Cf ; Z~? vJ _ `: T Gl:.; _ '. 'cam ~ ~~: , C > ~ C - r'~ n ~ ~ -< <n ~ ~~ ~ g, ° c `d ~.~ DANA L. BOWMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO.O1-4615 CNIL TERM SCOTT E. BOWMAN, :CIVIL ACTION -LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this /O' day of f~/~s...rG_ci 2001, upon consideration of the attached Custody Conciliation Report i't is ordered and directed as follows: 1. The Mother, Dana L. Bowman, shall have primary physical custody of Scott E. Bowman, Jr., born August 10, 1985, Jayson R. Bowman, born August 20, 1995, and Joshua S. Bowman, born August 20, 1995. 2. The Father, Scott E. Bowman, shall have partial physical custody of the Children as arranged by agreement of the parties. 3. The Father may file a Petition with the Court to request the scheduling of an additional Custody Conciliation Conference, if necessary, to review the custody arrangements. BY THE COURT, cc: Thomas D. Gould, Esquire -Counsel for Mother ~ ~; ~ 9 ~ 1 _ o I Scott E. Bowman, Father ~' :. q ~: .tlJV~Q~~7~ ~~~ ~~ ~~a i5.~ ~'d ~t d3S 1J ~, ~~d~~~:+...vy tl~'~: ~'~ ~,,. DANA L. BOWMAN, Plaintiff vs. SCOTT E. BOWMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.Ol-4615 CIVIL TERM CIVIL ACTION -LAW IN 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: The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Scott E. Bowman, Jr. August 10, 1985 Mother Jayson R. Bowman August 20, 1995 Mother Joshua S. Bowman August 20, 1995 Mother 2. A Conciliation Conference was held on September 4, 2001, with the following individuals in attendance: The Mother, Dana L. Bowman, with her counsel, Thomas D. Gould, Esquire. The Father, Scott E. Bowman, did not attend the Conference. 3. The Mother filed this Petition seeking primary physical custody of the Children. The Mother indicated that the Father usually stops by her residence every day to spend time with the Children for short periods of time. The Mother indicated that she would prefer a more detailed partial physical custody schedule for the Father, including a schedule for holidays. However, as the Father was not present at the Conference, the Mother indicated she would repetition for an additional Conference in the future if the parties were not able to establish a schedule. 4. The Conciliator recommends an Order in the form as attached, based upon representations made by the Mother at the Conference. Date Dawn S. Sunday, Esquire Custody Conciliator