HomeMy WebLinkAbout10-1534STEPHANIE BOWER, § IN THE COURT OF COMMON PLEAS OF
Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA
§ CIVIL ACTION - LAW
V. §
§ CUSTODY/VISITATION
BRADLEY BOWER,
Defendant § NO. ! V - ! S3«`???
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COMPLAINT FOR CUSTODY
AND NOW, comes the Plaintiff, Stephanie Bower, by her attorney, Tanner Law
Offices, LLC, and represents as follows:
1. Plaintiff is Stephanie Bower, an adult individual currently residing at 1022
Country Club Road, Camp Hill, Cumberland County, Pennsylvania 17011.
2. Defendant is Bradley Bower, an adult individual whose current residence is
unknown to the Plaintiff.
3. Plaintiff seeks primary custody of the following child:
Name Present Address Age
0
Collin James Bower 1022 Country Club Road 8 c •v
Cam Hill, PA 17011 (D.O. /2@f2) :V
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4. The child was born in wedlock.
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5. The child is presently in the custody of the Plaintiff, StephaniAow r,
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resides at 1022 Country Club Road, Camp Hill, Cumberland County,
Pennsylvania 17011, with the child's grandmother, Charlotte Berges.
6. During the last five years, the child has resided with the following persons at
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the following addresses:
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Persons : Address: Dates:
Stephanie Bower 1022 Country Club Road 6/08 - present
Charlotte Berges Camp Hill, PA 17011
(maternal grandmother)
7.
8.
9.
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11.
12.
Stephanie Bower 1022 Country Club Road 4/02 - 6/08
Bradley Bower Camp Hill, PA 17011
Charlotte Berges (maternal grandmother)
The mother of the child is Plaintiff, Stephanie Bower, currently residing at 1022
Country Club Road, Cam Hill, Cumberland County, Pennsylvania 17011.
The father of the child is Defendant, Bradley Bower, whose current resididence
is unknown to the Plaintiff.
The relationship of the Plaintiff to the child is that of mother. The Plaintiff
resides with her mother, Charlotte Berges.
The relationship of the Defendant to the child is that of father. The Defendant
resides with his girlfriend, Morgana Von Hager.
Plaintiff has not participated as a party in other litigation concerning the
custody of the child in a court of this Commonwealth or any other state.
Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the child and claims to have custody or visitation rights
with respect to the child.
13. 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.
14. The best interests and permanent welfare of the child will be served by granting
the relief requested. The quality of the child's physical, intellectual, moral and
spiritual environment would be improved by Plaintiff's continuation of primary
physical custody.
WHEREFORE, Plaintiff requests the Court to grant primary physical custody of the
child.
Respectfully submitted,
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Tabetha A. Tanner, Esquire
Supreme Court I.D. No.: 91979
Attorney for Plaintiff
TANNER LAW OFFICES, LLC
1300 Market Street, Suite 10
Lemoyne, PA 17043
(717) 731-8114
VERIFICATION
I verify that the statements made in this Complaint for Custody are true and correct.
I understand that false statements made herein may subject me to penalties of 18 Pa.C.S.
§4904 relating to unsworn falsification to authorities.
Date: atr
Stephanie ower
STEPHANIE BOWER
PLAINTIFF
V.
BRADLEY BOWER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2010-1534 CIVIL ACTION LAW
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Tuesday, March 09, 2010 upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, April 13, 2010 at 10:00 AM
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 detine and narrow the issues to be heard by the court, and to enter into a temporary
order. Failure to appear at the conference may provide grounds for entry ot. 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 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ Dawn S. Sunday, Esq.
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
FORT[ I 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
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