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Home My WebLink About07-4345BERNADETTE R. BRANSOM, Plaintiff vs. THOMAS L. BRANSOM, 1. Plaintiff is Bernadette Bransom, hereinafter referred to as Mother. Mother's mailing address is 106 South Fourth Street, Halifax, Dauphin County, Pennsylvania, 17032. 2. Defendant is Thomas L. Bransom, residing at 402 Normand Road, Camp Hill, Cumberland County, Pennsylvania 17011. Hereinafter, Mr. Bransom will be referred to as Father with the understanding that the oldest child, Chase Miller, is not his biological child and was never legally adopted. 3. Daniel Hewitt is the biological father of the oldest child, Chase Miller, but has not been actively involved in the child's life. By his actions, it is believed that he has acquiesced to the child remaining in Father's care. Mr. Hewitt's address is 736 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania 17043-1818. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.07- ~{35~~Y CIVIL TERM CUSTODY Defendant COMPLAINT FOR CUSTODY 4. Mother seeks a schedule for partial custody of the minor children: Name Present Residence Age Chase Miller 402 Normand Rd. 9/4/1991 DOB, 16 years old Camp Hill, PA Brenee Bransom 402 Normand Rd. Camp Hill, PA 6/25/94 DOB, 13 years old Carly Bransom 402 Normand Rd. Camp Hill, PA 8/27/96 DOB, ~11 years old Nathan Bransom 402 Normand Rd. 3/13/98 DOB, 9 years old Camp Hill, PA Chase is Mother's son from a prior relationship and is not Father's biological child. Chase's biological father has not been actively involved in Chase's life. There have been no adoption proceedings but Father has been actively involved in raising Chase. Brenee was born out of wedlock. Carly and Nathan were born during the parties' marriage. The children are all presently in the custody of Father. During Chase's lifetime, he has resided with the following persons and at the following addresses: Name Bernadette Bransom William Miller Carol Miller Bernadette Bransom Thomas Bransom Diana Thomas Skip Colter Bernadette Bransom Thomas Bransom Bernadette Bransom Thomas Bransom Brenee Bransom Bernadette Bransom Thomas Bransom Brenee Bransom Bernadette Bransom Thomas Bransom Brenee Bransom Bernadette Bransom Thomas Bransom Brenee Bransom Carly Bransom Address 1156 Kingsley Rd Camp Hill, PA 112 Creekwood Dr. Camp Hill, PA 7tn Street New Cumberland, PA 7t'' Street New Cumberland, PA Stn Street New Cumberland, PA 402 Normand Rd. Camp Hill, PA 402 Normand Rd Camp Hill, PA Date birth -10/93 10/93 -11 /93 11/93 - 6/25/94 6/25/94 -11/95 11/95 - 5/96 5/96 - 8/27/96 8/27/96 - 3/13/98 ~ Bernadette Bransom 402 Normand Rd 3/13/98 - 9/99 Thomas Bransom Camp Hill, PA Brenee Bransom Carly Bransom Nathan Bransom Thomas Bransom 402 Normand Rd 9/99 -10/03 Brenee Bransom Camp Hill, PA Carly Bransom Nathan Bransom Bernadette Bransom 402 Normand Rd 10/03 - 7/04 Thomas Bransom Camp Hill, PA Brenee Bransom Carly Bransom Nathan Bransom Thomas Bransom 402 Normand Rd 7/04 -present Brenee Bransom Camp Hill, PA Carly Bransom Nathan Bransom During Brenee's lifetime, she has resided with the followin g persons and at the following addresses: Name Address Date Bernadette Bransom 7th Street birth -11 /95 Thomas Bransom New Cumberland, PA Chase Miller Bernadette Bransom 8th Street 11/95 - 5/96 Thomas Bransom New Cumberland, PA Chase Miller Bernadette Bransom 402 Normand Rd. 5/96 - 8/27/96 Thomas Bransom Camp Hill, PA Chase Miller Bernadette Bransom 402 Normand Rd 8/27/96 - 3/13/98 Thomas Bransom ~ Camp Hill, PA Chase Miller Carly Bransom Bernadette Bransom Thomas Bransom Chase Miller Carly Bransom Nathan Bransom Thomas Bransom Chase Miller Carly Bransom Nathan Bransom Bernadette Bransom Thomas Bransom Chase Miller Carly Bransom Nathan Bransom Thomas Bransom Chase Miller Carly Bransom Nathan Bransom 402 Normand Rd Camp Hill, PA 402 Normand Rd Camp Hill, PA 402 Normand Rd Camp Hill, PA 402 Normand Rd Camp Hill, PA 3/13/98 - 9/99 9/99 - 10/03 10/03 - 7/04 7/04 -present During Carly's lifetime, she has resided with the following persons and at the following addresses: Name Bernadette Bransom Thomas Bransom Chase Miller Brenee Bransom Address 402 Normand Rd Camp Hill, PA Date birth - 3/13/98 Bernadette Bransom Thomas Bransom Chase Miller Brenee Bransom Nathan Bransom 402 Normand Rd Camp Hill, PA 3/13/98 - 9/99 Thomas Bransom 402 Normand Rd 9/99 - 10/03 Chase Miller Camp Hill, PA Brenee Bransom Nathan Bransom Bernadette Bransom 402 Normand Rd 10/03 - 7/04 Thomas Bransom Camp Hill, PA Chase Miller Brenee Bransom Nathan Bransom Thomas Bransom 402 Normand Rd 7/04 -present Chase Miller Camp Hill, PA Brenee Bransom Nathan Bransom During Nathan's lifetime, he has resided with the following persons and at the following addresses: Name Bernadette Bransom Thomas Bransom Chase Miller Brenee Bransom Carly Bransom Address 402 Normand Rd Camp Hill, PA Date birth - 9/99 Thomas Bransom Chase Miller Brenee Bransom Carly Bransom Bernadette Bransom Thomas Bransom Chase Miller Brenee Bransom Carly Bransom Thomas Bransom Chase Miller Brenee Bransom Carly Bransom 402 Normand Rd Camp Hill, PA 402 Normand Rd Camp Hill, PA 402 Normand Rd Camp Hill, PA 5. Mother currently lives alone. 6. Father currently resides with the following persons: Name Relationship 9/99 -10/03 10/03 - 7/04 7/04 -present Chase Miller Mother's son from a prior relationship Brenee Bransom Daughter Carly Bransom Daughter Nathan Bransom Son 7. Mother has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 8. Mother has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Mother believes that in 2000, Father filed a complaint that incorporated divorce and custody but was later dismissed by the Court as a result of the parties' inaction on the matter. 9. Mother does not know of a person not a party to the proceedings who has physical custody of Brenee, Carly or Nathan, or who claims to have custody or visitation rights with respect to Brenee, Carly or Nathan. Mother has served Chase's biological father with a copy of this petition. 10. The best interest and permanent welfare of the children will be served by granting the relief requested for reasons including, but not limited to the following: a) Mother has a safe and appropriate home environment where she can exercise periods of partial physical custody with the children. b) Mother tried to remain actively involved with the children after the parties separated and attempted to maintain aparent/child relationship with each of them. ~ c) Even when Mother has been unable to see the children, she has continued to demonstrate a genuine concern for their well-being and maintains contact via telephone, internet and delivery of care-packages. d) Mother believes it is important for the children to know both parents and seeks to maintain and nurture aparent/child relationship with the children. e) Mother has worked hard to better her situation and has established herself in a safe and nurturing home, actively participates in her church, and is pursuing her education in Criminal Justice. f) Father has not acted in the children's best interests in ways including but not limited to the following: i) Father has been arbitrary in allowing Mother to visit with the children; interfering with the mother/child relationships. ii) Father makes negative comments about Mother to the children and Mother believes this has led to the older children developing a negative perspective about Mother's character. iii) Father is critical, rude and demeaning to Mother within earshot of the children, contributing to Mother's concerns about the perception the children are developing about her character. 11. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. Additionally, Chase Miller's biological father has been served with a copy of the Complaint filed in this matter. WHEREFORE, Mother requests this Court to grant her periods of partial physical custody and shared legal custody of the children and any other relief that is just and proper. tted, 7es~ca/Holst, Esqui~ Mid Penn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 VERIFICATION The above-named PLAINTIFF, Bernadette Bransom, verifies that the statements made in the above Complaint For Custody are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date : 1 ' i -1'~,C~~"" Bernadette Bransom BERNADETTE R. BRANSOM, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.07- CIVIL TERM THOMAS L. BRANSOM, . Defendant :CUSTODY AFFIDAVIT OF SERVICE BY MAIL I, Jessica Holst, do hereby swear that I served Thomas L. Bransom and Daniel Hewitt with a Complaint For Custody on , 2007 by certified mail, return receipt, restricted delivery, to the persons and addresses below: Thomas L. Bransom 402 Normand Road Camp Hill, PA 17011 Daniel Hewitt 736 Bosler Avenue Lemoyne, PA 17043-1818 Date: ~'~~ °~~ Signature: "~C (? c ~ _.~ Cj t- -- ~ T ~' ~ ' r ~-, .__.. -= _~ .. -, ~~-i ,:. 4 ~-^ ~ BERNADETTE R. BRANSOM, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.07- 43~i~' CIVIL TERM THOMAS L. BRANSOM, Defendant CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Bernadette Bransom, Plaintiff, to proceed in forma au eris. I, Jessica Holst, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providin ee legal services to the party. ssi 1st, squire Mid nn Legal Services 401 ast Louther Street Carlisle, PA 17013 (717) 243-9400 ~ C~' ~ _, --~ r ICJ ~' ~' - ry . .~ ;'-. ` 613 ~w7 BERNADETTE R. BRANSOM IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. THOMAS L. BRANSOM DF,FF,NDANT • 2007-4345 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, July 30, 2007 ,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, August 09, 2007 _ ,_ at 10:30 AM 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 4$ hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilro Es . 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~~~~ <~~ ~- ~ «- ~~ ~ ~ o- ~~ ~'i~it/i1~iA~~~I~~d Q~ ~Z ~d ~- ~#1~ LGOZ A~J.~Jf~u~, ~~.u~c~ ~H.i ~a ~ul~,~?C~~'1~ ,, .. r ~ BERNADETTE R. BRANSOM, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. N0.2007-4345 CIVIL ACTION -LAW THOMAS L. BRANSOM, Defendant IN CUSTODY COURT ORDER 1~ l AND NOW, this ~ day of Se.~~c,w~\DbJ , 2007, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. Thomas L. Bransom shall have legal and physical custody of Chase Miller born September 4, 1991, Brenee Bransom born June 25, 1994, Carly Bransom born August 27, 1996 and Nathan Bransom born March 13, 1998. 2. Bernadette R. Bransom shall have periods of temporary custody of the minor children as follows: (a) Pursuant to a schedule arranged between the parties. The father shall ensure that the mother has liberal periods of custody during the week or on the weekends with the minor children, which schedule shall be subject to the various school, social and athletic requirements of the children. (b) To ensure mother has some time with the children and as a default in the event a schedule is unable to be arranged between the parties, mother shall have temporary custody of the minor children every Sunday from noon until 5:00 p.m., unless other arrangements are made pursuant to subparagraph (a) above. 3. Assuming the custody arrangements are going well, it is anticipated that mother's periods of time will be expanded with the minor children as this case progresses. 4. Subject to the obvious ages of the children, father is directed to encourage the children to participate in the custody visits with the mother. 5. In the event any counseling sessions are required in order to reacquaint the mother with the children as required by her counselor, the father shall cooperate with those sessions and shall ensure that the children participate as needed. 6. Transportation for exchange of custody with respect to this visitation schedule shall be handled by the mother. ., ~.` a• 7. The mother shall also enjoy reasonable telephone contact with the minor children. 8. In the event there are any problems with the Custody Order as set forth above or in the event that either party desires to modify that Order, legal counsel for the parties may contact the Custody Conciliator directly to set up a telephone conference between legal counsel and the conciliator. cc: Jessica Holst, Esquire ~bara Sumple-Sullivan, Esquire Mr. Daniel Hewitt _ ^~ J BY THE COURT, Judge c~ ~~ :Z ~~,,~;~. ~~~ :1~~ ~ a SEP 2 s 200 ~y BERNADETTE R. BRANSOM, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. N0.2007-4345 CIVIL ACTION -LAW THOMAS L. BRANSOM, Defendant 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: Chase Miller born September 4, 1991; Brenee Bransom born June 25, 1994; Carly Bransom born August 27,1996; and Nathan Bransom born March 13, 1998. 2. A Conciliation Conference was held on September 21, 2007, with the following individuals in attendance: The mother, Bernadette R. Bransom, with her counsel, Jessica Holst, Esquire, the father of Chase Miller, who is Daniel Hewitt and appeared without counsel, and the father of the other three children, Thomas L. Bransom, with his counsel, Barbara Sumple-Sullivan, Esquire. 3. The parties agree to the entry of an Order in the form as attached. Date: September 26, 2007 ITubert X. Gilroy, E! Custody Conciliator