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TABITHA M. BOWERS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
2010 - CIVIL TERAk
SHAUN D. BOWERS, _ q
Defendant IN CUSTODY" --Z _
COMPLAINT FOR CUSTODY
,iian
AND NOW comes the Plaintiff, Tabitha M. Bowers, by her attomeggs, I.
McKnight, P.C., and presents the following Complaint for Custody.
1.
The Plaintiff, Tabitha M. Bowers, is an adult individual with an address of 219 Meadow
Street, Rockhill Furnace, Huntingdon County, County, Pennsylvania 17249.
2.
The Defendant, Shaun D. Bowers, is an adult individual with an address of 337 North
High Street, Chambersburg, Pennsylvania 17201.
3.
The parties are the natural parents of two (2) children, namely, Brianna R. Bowers, born
February 25, 2001, and Terry J. Bowers, born April 25, 2005.
4.
The Parties were married in Shippensburg, Cumberland County, on January 3, 2007, and
the Petitioner works at the Sarah Todd Nursing Home as an LPN in Carlisle, Cumberland
County. The parties consent to venue being in Cumberland County in order to maintain the
Petitioner's employment.
5.
The Plaintiff, Tabitha M. Bowers, desires that the parties have shared legal custody of the
minor children, Brianna R. Bowers and Terry J. Bowers.
6.
The Plaintiff, Tabitha M. Bowers, desires primary physical custody of the said minor
children with periods of temporary physical custody to Defendant, Shaun D. Bowers, as the
parties can agree.
7.
The best interests and permanent welfare of the minor children requires that the Court
grant the Plaintiff's request as set forth above.
WHEREFORE, the Plaintiff, Tabitha M. Bowers, respectfully requests that she be
awarded primary physical custody and shared legal custody of the minor children, Brianna R.
Bowers and Terry J. Bowers, with periods of temporary physical custody to Defendant, Shaun D.
Bowers, as provided herein.
Respectfully submitted,
IRWIN & 1V,IcKNIGHT, P.C.
By:
Mar s A. N#Vght, III, Esquire
Attorney for ntiff
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Supreme Court I. D. No. 25476
Date: March 16, 2010
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VERIFICATION
The foregoing Complaint for Custody is based upon information which has been gathered
by counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
M. BOWERS
Date: March 16, 2010
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