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HomeMy WebLinkAbout99-05461,'„ '-;'; 2 x ,a '', JESSICA KING Vs. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH S. BOWERS Defendant CIVIL ACTION - LAW N0. 99- -s._yL i CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW THIS ,L day of S,,n 4 1999, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at 1c ? drr(-V(l ( -, - 6? -k )Con the -a\ day of 1999 at L"hQ 1P.1 ., 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. BY THE COURT, BY ha Lx I ^ aL? n Custody Conciliator The Court of Common 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 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 LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF 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) 249-3166 JESSICA KING : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION -LAW NO. 99- SyL / CIVIL TERM JOSEPH S. BOWERS Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Jessica King, an adult individual, currently residing at 2340 Ritner Hwy., Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Joseph S. Bowers, an adult individual, currently residing at 385 Whiskey Run Rd., Newville, Cumberland County, Pennsylvania, 17241. 3. Plaintiff seeks custody of the following child : Brianne Nicole Bowers, age 2 years, born 4/14/97. The child was born out of wedlock. The child is presently in the custody of Jessica King, who resides at 2340 Ritner Hwy., Carlisle, Cumberland County, Pennsylvania. The defendant father recently removed himself from this residence when the parties separated. During the past five years, or since the child's birth, she has resided with the following persons at the following addresses: (a) from birth to the separation in late July, 1999, with the parties and Jessica's parents, James J. And Mary Ann King, at 2340 Ritner Hwy. Carlisle, PA. (b) from the date of separation to present with Jessica and her parents at the same residence. The natural mother of the child is Jesssica King. She is not married. The natural father of the child is Joseph S. Bowers. He is not married. 4. The relationship of the Plaintiff to the child is that of natural mother. 5. The relationship of the Defendant to child is that of natural father. 6. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning the custody of the child in this or in any other Court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) The mother has been the primary caretaker of the child since her birth and is capable of providing the care a child needs. (b) The mother needs to have a Court Order as father has threatened that he will take custody of Brianne from the mother and this concerns her greatly. 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. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene. NAME ADDRESS BASIS OF CLAIM None WHEREFORE, Plaintiff requests your Honorable Court to: A) grant custody of the child to the plaintiff; B) set an emergency hearing in order to set the parties rights until such time as there can be a full hearing in this matter; C) grant such other relief as is just and in the best interest of the child including the award of attorney's fees against the father. Respectfully submitted, Date: -?-/ / -7 / 4 S Robert L. O'Brien, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 (717) 249-6873 I verify that the statements made in the foregoing Complaint for Custody 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. JESSICA KING ` DATE: 11 - 0- 99 SEP - 8 is? r z1 u Ltd n a o W n U W < Z V U r o Z J Q'd z a LY1 _ z ? V 66! ?jflqqo JESSICA KING, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOSEPH S. BOWERS, NO. 99-5461 CIVIL Defendant IN CUSTODY COURT ORDER AND NOW, this 2`' day of October, 1999, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. The Mother, Jessica King, shall enjoy primary legal custody and primary physical custody of Brianne Nicole Bowers, born April 14, 1997. 2. The Father, Joseph S. Bowers, shall enjoy visitation with the minor child as follows: A. On alternating weekends. For the first four or five weekends, the time shall be from Saturday morning through Sunday evening at 7:00 p.m. Assuming those first weekends go well, Father's weekend time shall be expanded from Friday at 5:00 p.m. until Sunday evening at 7:00 p.m. B. On holidays, the parties shall make arrangements for the Father to have the minor child for some time as agreed upon by the parties. C. At such other times as agreed upon by the parties. 3. 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 Custody Conciliator for a Conference. BY THE COURT, • 4 ? J. cc: Robert L. O'Brien, Esquire ?c?? ro jlbl9 P Joseph S. Bowers , / _,Sop. .-L 99 C?1 t , P i I,'_: +0 1 JESSICA KING, Plaintiff JOSEPH S. BOWERS, Defendant Prior Judge: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-5461 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: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Brianne Nicole Bowers, bom April, 14, 1997. 2. A Conciliation Conference was held on October 21, 1999, with the following individuals in attendance: The Mother, Jessica King, with her counsel, Robert L. O'Brien, Esquire; and the Father, Joseph S. Bowers, who appeared without counsel. 3. The parties agree to the entry of an order in the form as attached. is as L? all D TE Hubert X. Gilroy squire Custody Conci ' for