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Home My WebLink About99-07476(tea -1 >I i 0 l a + + 4 l„? ^'1%6 is *ka Yl ?? a r74 PLC 15 1999 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THANE E. SHOWERS, Plaintiff V. CIVIL ACTION - LAW IN CUSTODY TIFFANY D. SHOWERS, NO. 99- 7y76, 6jAJ Defendant ORDER OF COURT AND NOW, this day of 1?t? PMhe(- 1999, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel shall appear before the Conciliator, atq 1? .1 ??C1 S )?j CQA 00 day of Kh on the at _Lf .(Il q .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 shall/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 THE COURT, Custody Conciliator (TD 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)249-3166 r, n i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THANE E. SHOWERS, Plaintiff V. CIVIL ACTION - LAW IN CUSTODY TIFFANY D. SHOWERS, NO. 99- Defendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and ajudgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONETHE 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 NOTICIA Le han demandado a usted en la cone. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, In. corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notification y por cualguier queja o alivio que es pedido en la petition de demanda. Usted puede perder dinero o sus propiendades o otros derechos importantes para usted. LLEVE ESTA DEMANDAA UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO 0 SINO TIENE EL DINERO SOFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONAL 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Mi thael J. Hanft, E uire Attorney ID No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THANE E. SHOWERS, Plaintiff CIVIL ACTION - LAW V. IN CUSTODY TIFFANY D. SHOWERS, Defendant NO. 99- 7'i7ro e0;'j 74. COMPLAINT FOR PRIMARY CUSTODY AND NOW, this 10'" day of December, 1999, comes Plaintiff, THANE E. SHOWERS, by and through his attorney, Michael J. Hanft, Esquire, and files the following Complaint for Primary Custody in support thereof avers as follows: The Plaintiff is Thane E. Showers, an adult individual residing at 24 Hogestown Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is Tiffany D. Showers, an adult individual residing at 175 Meadows Road, Newville, Cumberland County, Pennsylvania. 3. The Plaintiff seeks primary custody and visitation of the following child: Name Present Residence Age Date of Birth Arie Logan Showers 175 Meadows Road 5 February 2, 1994 Newville, PA 17241 The child was not born out of wedlock. The child is presently in the physical custody of the Defendant, Tiffany D. Showers. In addition to the child's present address, during the past five years, the child has resided with either Plaintiff or Defendant at the following addresses: 739 Old Silver Spring Road, Mechanicsburg, PA 17055 12/97-10/98 24 Hogestown Road, Mechanicsburg, PA 17055 10/98-present The mother of the child is the Defendant, who resides at 175 Meadows Road, Newville, Cumberland County, Pennsylvania 17241. The father of the child is Plaintiff, who resides at 24 Hogestown Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 4. The relationship of Plaintiff to the child is that of father. 5. The relationship of the Defendant to the child is that of mother. The Defendant currently resides with child and third person named Rod. 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 another court. The Plaintiff has no information ofa custody proceeding concerning the custody of the child in this or any other court. The 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 interests and permanent welfare of the child will be served best by granting the relief requested because: a) The Plaintiff has had shared physical and legal custody of the child since the child's birth; b) The Plaintiff provides the child with a home with adequate moral, emotional and physical surroundings as required to meet the child's needs; C) The Plaintiff is, and has always been, willing to accept custody of the child; and d) The Plaintiff continues to exercise parental duties and responsibilities and enjoys the love and affection of the child. h_1 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. There are no other persons who are known to have or claim a right to custody or visitation of the child. WHEREFORE, Plaintiff respectfully requests Your Honorable Court grant Plaintiff sole physical and sole legal custody of Arie Logan Showers. Respectfully submitted, Midhael J. Hanft, 49quirct' Attorney ID No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 Attorney for Plaintiff Verification I verify that the statements made in the foregoing Complaint for Primary Custody are true and correct to the best of my knowledge, information and belief. This Verification is made only as to the factual averments contained herein, and not to legal conclusions and averments authored counsel in his capacity as attorney for the party or parties hereto. 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. Thane E. Showers F 1U- FOId&F'- du:a?G<ndocaa91U9Bhttificaiion I <`';?i _,_ u n u? b:,? ?_ llJ =. c w LJ il(L U a? U n Oz o Q ? a w W N W a cn Z _ off Wu gW w P U U Z a A s O¢z a ? x m ?: U ¦ Ci w 3 fcn c w a z x H vi w x? G1 w ?- A u, t= ? i THANE E. SHOWERS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 99 - 7476 TIFFANY D. SHOWERS, Defendant : IN CUSTODY COURT ORDER AND NOW, this 23" day of December, 1999, the following temporary custody order is entered: I. The Mother, Tiffany D. Showers, and the Father, Thane E. Showers, shall enjoy shared legal custody of the minor child Arie Showers, born February 2, 1994. The Mother shall enjoy primary physical custody. 2. The Father, Thane E. Showers, shall enjoy Christmas with the minor child from Friday, December 24a' at 4:00 p.m. through Sunday, December 26'h at 11:00 a.m. at which time the Father shall deliver the minor child to the Mother. For New Year's, the Father shall have custody from Thursday, December 30m when the Father gets off from work through Saturday, January 1, 2000 at 4:00 p.m. 3. After the Christmas holiday, the Mother shall continue to maintain primary physical custody of the minor child with the Father enjoying temporary custody on alternating weekends from Friday at 6:00 p.m. through Sunday evening at 6:00 p.m. and at such times as the parties may agree. 4. The alternating weekend schedule shall commence after the holidays with Father having the weekend of January 7, 2000. 5. This is a temporary custody order subject to further modification by order of court and is entered pending the Custody Conciliation Conference scheduled in this matter. BY T];; T, J. cc: Hubert X. Gilroy, Esquire- tf?m/ -ez Michael J. Hanft, Esquire - sto=/ci 4111?// [? 112 ? '?/n -a :i .in 1I I i J Sent My: aICIUtt J. MAW I, LSWIMt; /I/ 2=U 0,151; Ue: 27 W t8:2a; ._ _.. .... ....o .a raertl2[! ts`.Q0305 GILMOJ M 1 I•ege 21W TRANS E. SHOWER:. : LY flB COURT OF COMMON PLEAS OF PlelaUB : CtRZKRLAND COUNTY, PENNSYLVANIA t N0. 99.7476 TIFFANY D. SHOWERS, Delkndent IN CUSTODY The pad" to the above cwioned =Uon by their M=FJ baeby epee and etip Ufa Ihnt the Ai1erII&I 9roPowA order may be tilled by the Coun. Date: December 27, 1999 Dele: Deoenlber 27,1999 1- ubmXGUroy. e Attorney for Def t Mi et J. Ilmlt, tqube Attomuy for PWnUA FEs - ?mn) THANE E. SHOWERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW No. 99-7476 TIFFANY D. SHOWERS, Defendant IN CUSTODY ORDER OF COURT AND NOW, this let day of February, 2000, the Conciliator, being advised by counsel for the parties that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiciton in this case. The Custody Conciliation Conference scheduled for today, February 1, is canceled. FOR THE CDURT, S?f"i?.ulyy?v Dawn S. Sunday, Esquire Custody Conciliator I. Al - -19