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Home My WebLink About03-2619Michele Avery and : IN THE COURT OF COMMON PLEAS Karen S. Sowers, : CUMBERLAND COUNTY PENNSYLVANIA Plaintiffs v :NO. O 02619 CIVIL TERM George Sowers and Kristi Dean-Sowers Defendants : IN CUSTODY CUSTODY COMPLAINT 1. Plaintiff Michele Avery is an adult individual currently residing at 830 Bosler Ave. Lemoyne, Pennsylvania 17043. 2. Plaintiff Karen S. Sowers is an adult individual currently residing at 1307 West College Ave. York, Pennsylvania 17404. 3. Defendant George Sowers and Kristi Dean-Sowers are adult individuals currently residing at 423 Walnut Street, York Pennsylvania 17403. 4. Plaintiff Avery is the maternal aunt and Plaintiff Karen S. Sowers is the paternal grandmother of the two minor children of defendant Sowers, Taryn Shea Dean born April 28, 1994 and Brennen Hammish Dean born December 30, 1997. 5. The parties hereto have executed a custody stipulation which they request be entered as an Order of Court. DATE ffully Submitted, Res ur Offi i T 9ec Ron Turo 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Fri ri ( O J r ? (t - s Michele D. Avery and : IN THE COURT OF COMMON PLEAS Karen S. Sowers, : CUMBERLAND COUNTY PENNSYLVANIA Plaintiffs NO. ?o3 -.261q CIVIL TERM V. George Sowers and : Kristi Dean-Sowers : IN CUSTODY Defendants STIPULATION 1. Plaintiff Michele D. Avery is the maternal aunt of the minor children referenced below. 2. Plaintiff Karen S. Sowers is the paternal grandmother of the minor children. 3. George Sowers and Kristi Dean-Sowers are the natural parents of the minor children. 4. The minor children, Taryn Shea Dean born April 28, 1994 and Brennen Hammish Dean born December 30, 1997 are the minor children of the defendants George and Kristi Dean-Sowers. 5. The natural parents, George and Kristi Dean-Sowers, by this stipulation, hereby agree as follows: a. Primary physical custody of the minor child, Taryn Shea Dean, shall be in her maternal aunt, Michele Avery. b. Primary physical custody of the minor child, Brennen Hammish Dean, shall be in the paternal grandmother Karen S. Sowers. c. The natural parents, George Sowers and Kristi Dean-Sowers, shall enjoy temporary custody for the purpose of visitation at such times and in such places as the parties may mutually agree. All parties hereto agree to this stipulation shall be entered as an Order of Court. '?-Id4 6 3 Date D e` Dat 1? a6 d Date ,,M,,?.?cf f f Mich Ie D. Avery, maternal u t S san Somers, paternal grandmother RfisTle Dean-Sowers, natural mother C? ? ? - ?. ,_ ,.l _ ,' _ ,°; .n ?n Michele D. Avery and : IN THE COURT OF COMMON PLEAS Karen S. Sowers, : CUMBERLAND COUNTY PENNSYLVANIA Plaintiffs : NO. rJ3 d(oii CIVIL TERM v. George Sowers and Kristi Dean-Sowers ; IN CUSTODY Defendants STIPULATION 1. Plaintiff Michele D. Avery is the maternal aunt of the minor children referenced below. owers is the paternal grandmother of the . Plaintiff Karen S. S 2 minor children. d Kristi Dean-Sowers are the natural parents . George Sowers an 3 of the minor children. 4. The minor children, Taryn Shea Dean born April 28, 1994 and Brennen Hammish Dean born December 30, 1997 are the minor children of the defendants George and Kristi Dean-Sowers. 5. The natural parents, George and Kristi Dean-Sowers, by this stipulation, hereby agree as follows: a. Primary physical custody of the minor child, Taryn Shea Dean, shall be in her maternal aunt, Michele Avery. b. Primary physical custody of the minor child, Brennen Hammish Dean, shall be in the paternal grandmother Karen S. Sowers. C. The natural parents, George Sowers and Kristi Dean-Sowers, shall enjoy temporary custody for the purpose of visitation at such times and in such places as the parties may mutually agree. All parties hereto agree to this stipulation shall be entered as an Order of Court. 5-144 (03 Date Date S ?3 Dat Datead 0 1t t ele D. N paternal ther Kfis ie Dean-Sowers, natural mother C) o C-- w F7 T ? i r:I o a Michele Avery and : IN THE COURT OF COMMON PLEAS Karen S. Sowers, : CUMBERLAND COUNTY PENNSYLVANIA Plaintiffs V. : NO, c> , abr g CIVIL TERM George Sowers and Kristi Dean-Sowers Defendants : IN CUSTODY ORDER OF COURT AND NOW, this /zt day of _G.-., , 2003, upon consideration of the within Stipulation, the parties agreement is hereby made an Order of Court BY THE COURT, O? bl?lxq?,{S'tP l' ?c MICHELE AVERY AND KAREN S. SOWERS, Plaintiffs vs. GEORGE SOWERS AND KRISTI DEAN-SOWERS Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO. 03-2619 CIVIL TERM IN CUSTODY STIPULATION - MODIFICATION OF CUSTODY 1. The minor children, Taryn Shea Dean born April 28, 1994 and Brennen Hammish Dean born December 30, 1997, are the minor children of the defendants George Sowers and Kristi Dean-Sowers. 2. Plaintiff Michele D. Avery is the maternal aunt of the minor children and has legal custody of minor child Taryn Shea Dean. 3. Plaintiff Karen Sowers is the paternal grandmother of the minor children and has legal custody of minor child Brennen Hammish Dean. 4. Custody was decided by stipulation of all parties and said Stipulation was made an Order of this Court on June 12, 2003. 5. Minor child Taryn Shea Dean has been returned to the primary custody of her natural mother, defendant Kristi Dean (Sowers). 6. Minor child Brennen Hammish Dean has been returned to the primary custody of his natural mother, defendant Kristi Dean (Sowers).. ?? r c? t_= •? -n . ? i ? 1 J`, ?. ? --. _.i ..? . ; - C?3 ° :? Cv : 7. The natural father, George Sowers, shall continue to enjoy temporary custody of the minor children for the purpose of visitation at such times and in such places as the parties may mutually agree. All parties hereto agree that this stipulation shall be entered as an Order of Court. Y-a?,- 0? Date 2? 7 Date. Datta I ,5/2L 107 Date grandmother Kristi Dean (Sowers), natural mother 7.0 AUG 8727 MICHELE AVERY AND IN THE COURT OF COMMON PLEAS KAREN S. SOWERS, CUMBERLAND COUNTY PENNSYLVANIA Plaintiffs vs. NO. 03-2619 CIVIL TERM GEORGE SOWERS AND KRISTI DEAN-SOWERS Defendants IN CUSTODY ORDER OF COURT AND NOW, this ZT day of 4--f .,,? , 2007, upon consideration of the within Stipulation, the parties agreement is hereby made an Order of Court. BY THE COURT, DISTRIBUTION: Michele Avery, 830 Bosler Avenue, Lemoyne, PA 17043 Kristi Dean, 529A Hummel Avenue, Lemoyne, PA 17043 Karen Sowers, 1307 West College Avenue, York, PA 17404 George Sowers, York County Prison 3400 Concord Road, York, PA i e 5 /,CJ 1 eod 17402 C :C kld LZ 9nV LOOZ 1?l 3 JiV fi i ? uc? 3HI J0