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KOPE & ASSOCIATES, LLC
JULIE A. WEHNERT, ESQ.
ATTORNEY I.D. 307900
395 St. Johns Church Road
Camp Hill, PA 17011
(717) 761-7573
jwehnert@kopelaw.com
TIMOTHY E. BUSHEY,
Plaintiff,
vs.
SHEENAH M. DORSEY,
Defendant.
2010APPI ?IJ F'IN 1: 4
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rv ,
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 10 - IS
CIVIL ACTION - LAW
IN CUSTODY
CUSTODY COMPLAINT
AND NOW comes the above-named Plaintiff, TIMOTHY E. BUSHEY, by and
through his attorney, JULIE A. WEHNERT, ESQ., and makes the following Complaint in
Custody:
1. The Plaintiff is TIMOTHY E. BUSHEY, an adult individual who currently resides
at 40 Fox Hollow Road, Shermans Dale, Perry County, Pennsylvania 17090 (hereinafter
"Plaintiff" or "Father"). Plaintiff will be relocating to his permanent address at 21
Regency Woods, North, Carlisle, Cumberland County, Pennsylvania 17015 on June 1,
2010.
2. The Defendant is SHEENAH M. DORSEY, an adult individual who currently
resides at 21 Regency Woods, North, Carlisle, Cumberland County, Pennsylvania
17015. Defendant will be moving out of this residence on or before June 1, 2010.
(hereinafter "Defendant" or "Mother").
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3. Plaintiff seeks shared legal and primary physical custody of the following
unemancipated child: Xander P. Bushey, born October 23, 2008.
4. Xander P. Bushey (hereinafter the "child") was born out of wedlock.
5. During the past two years, the child has resided with the following persons and at
the following addresses:
PERSONS
ADDRESSES
DATES
Timothy E. Bushey
Sheenah M. Dorsey
Timothy E. Bushey
Edward Bushey
Lynne Beckley
21 Regency Woods, North
Carlisle, PA 17015
40 Fox Hollow Road
Shermans Dale, PA 17090
Birth - 3/19/10
3/19/10 - present
Sheenah M. Dorsey 21 Regency Woods, North 3/19/10 - present
Carlisle, PA 17015
6. The father of the child is Timothy E. Bushey, currently residing at 40 Fox Hollow
Road, Shermans Dale, Perry County, Pennsylvania, 17090. He is unmarried.
7. The mother of the child is Sheenah M. Dorsey, currently residing at 21 Regency
Woods, North, Carlisle, Cumberland County, Pennsylvania 17015. She is unmarried.
8. The relationship of Plaintiff to the children is that of Father. Father currently lives
with Edward Bushey, his father and Lynne Beckley, his step-mother.
9. The relationship of Defendant to the child is that of Mother. Mother currently
resides alone.
10. There has been a temporary custody order as part of a final Protection From
Abuse Order dated March 19, 2010 that grants custody of the minor child with Mother.
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Defendant has periods of partial custody as agreed upon. Since the issuance of the
PFA Order, Plaintiff has had majority physical custody of Xander.
11. Plaintiff does not know of a person not a party to the proceeding who has
physical custody of the child or claims to have custody or visitation rights with respect to
the child.
12. Plaintiff is requesting shared legal and primary physical custody of the child.
13. The best interest and permanent welfare of the child will be served by the
granting relief requested because:
(a) Father has played the instrumental role in the raising of the child since his
birth. As such, the child will benefit from continued physical custody with
Father;
(b) Father has concerns for the physical safety of the minor child while he is in
the custody of the Mother;
(c) Mother only exercises custody when it is convenient for her; she drops the
child off with her grandmother to babysit during most of the times she
exercises custody;
(d) Mother does not properly bathe, dress or feed the child during her periods
of physical custody. Mother is not attentive to the child's eczema which
causes the child to have bad flares up of the skin condition;
(e) Father is able to provide a stable home and emotional environment for the
child; and
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(d) Father has the facilities to provide for the care, comfort and control of the
child, as well as the intention and desire to do so.
14. Each parent whose parental rights to the child have not been terminated and the
persons who have physical custody of the child have been named as parties to this
action.
WHEREFORE, Plaintiff requests that this Honorable Court grant the following
relief: Award Plaintiff shared legal and primary physical custody of the child.
Respectfully Submitted,
PE & ASSOCIATES
Dated: c . 3 110
lie A. Wehnert, Esq.
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VERIFICATION
I, Timothy E. Bushey, the Plaintiff in this matter, have read the foregoing
Complaint. I verify that my averments in this Complaint are true and correct and based
upon my personal knowledge. I understand that any false statements herein are made
subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifications to
authorities.
Dated: d1? a
Timot .Bushey
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