HomeMy WebLinkAbout09-8057ROGER ROWE,
Plaintiff
V.
NICOLE MARIE ROWE and
KENNETH JAMES CLARK,
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 0 9 -- ?4 C>w
IN CUSTODY
COMPLAINT FOR CUSTODY
1. The Plaintiff is Roger Rowe, an adult individual, residing at 174 Big Spd
Terrace, Newville, Cumberland County, Pennsylvania, with his son, Nathan Rowe.
2. The Defendants are Nicole Marie Rowe and Kenneth James Clark, II, ad
individuals, residing at the Cumberland County Prison.
3. Plaintiff seeks custody of the following child: Kenneth James Clark, 11, August
24, 2008.
The child was bom out of wedlock.
The child is presently in the custody of the maternal grandfather, Roger Rowe, who
SA DIS,
FLOWER &
LE%Ms"
26 West High Street
Carlisle, PA
resides at 174 Big Spring Terrace, Newville, Cumberland County, Pennsylvania.
During the past five years, the child has resided with the following persons and at the
following addresses:
Name Address Dates
Nicole Rowe and Kenneth 33 Parker Road, Newville, Birth until December 1, 2008
Clark Pennsylvania
Roger Rowe and 174 Big Spring Terrace, Newville December 1, 2008 to
Nathan Rowe Pennsylvania present
The mother of the child is Nicole Marie Rowe, currently residing at the Cumberland
County Prison.
She is single.
The father of the child is Kenneth James Clark, currently residing at the Cumberland
County Prison.
He is divorced.
4. The relationship of Plaintiff to the child is that of maternal grandfather.
5. The relationship of Defendant Rowe to the child is that of mother. The
relationship of Defendant Clark to the child is that of father.
6. Plaintiff has not participated as a party or witness, or in another capacity, in
litigation concerning the custody of the child in this or another court.
Plaintiff has no information of a custody proceeding concerning the child pending in
court of this Commonwealth or any other state.
Plaintiff does not know of a person not a party to the proceedings who has
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 granti
the relief requested because Plaintiff can best provide for the child's spiritual, physical
emotional welfare.
8. Each parent whose parental rights to the child have not been terminated and
person who has physical custody of the child have been named as parties to this action.
WHEREFORE, Plaintiff requests the Court to grant legal and primary physical custody
the child.
SAIDIS, FLOWER &
111i'l_
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SAIDIS,
FLONV
R&
LEND
MUMPY-M
26 West High Street
Carlisle, PA
Carol J. Lindsay
I D No. 44693
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in the foregoing document are true and correct.
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §49041
relating to unsworn falsifications to authorities.
,/r-C? ?i11Lt
Rog o?ve
Date: 11- I R - C7 I
SAII)IS,
"WER &
LINDSAY
A %r&AT [A
26 West High Street
Carlisle, PA
BLED-OFFICE
OF THE PROTHONOTARY
2009 NOV 19 PM 3: 36
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