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Home My WebLink About05-4072 KELLI JO BOWERMASTER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. DA VlD L. BOWERMASTER Defendant ; NO.d-'t"7LcwIL TERM : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Kelli Jo Bowermaster, residing at 160 SME, Shippensburg, Cumberland County, Pennsylvania 17257. 2. The defendant is David L. Bowermaster, residing at 23 Cleversburg Road, Shippensburg Cumberland County, Pennsylvania 17257. 3. Plaintiff seeks custody of the following child: Name Kara Page Bowermaster Present Residence 160 SME Shippensburg, P A 17257 DOB 3/8/99 Age 6 yrs. 4 mos. The child was born in wedlock. 4. The child is presently in the custody of Kelli Jo Bowermaster, residing at 160 SME, Shippensburg, Cumberland County, Pennsylvania 17257. During the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Kelli Jo Bowermaster 160 SME Shippenburg, Pa May 2002 to Present Kelli J 0 Bowermaster 320 South Penn Street Shippensburg, Pa April 2002- May 2002 Kelli Jo Bowermaster David L. Bowermaster 488 Furnace Hollow Road Shippensburg, Pa March 1997 to April 2002 5. The mother of the child is ofKelli Jo Bowermaster, residing at 160 SME, Shippensburg, Cumberland County, Pennsylvania 17257. He is married. The father of the child is David L. Bowermaster, residing at 23 Cleversburg Road, Shippensburg, Cumberland County, Pennsylvania 17257. He is married. 6. The relationship of plaintiff to the child is that of mother. The plaintiff currently resides with the following persons. Name Kara Page Bowermaster Relationship Daughter 7, The relationship of defendant to the child is that of father. The defendant currently resides with the following persons. Name Summer Cassell Lucas Cassell Relationship Girlfriend Girlfriend's son 8. Plaintiff has not participated as a party or witness, or in another capacity, in other 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 a court ofthis Commonwealth. 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. 9. The best interest and permanent welfare of the child will be served by granting the relief request because: A Court Order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. Plaintiff desires to maintain the family household which has been established, and the continued stability ofthe household is in the best interest of the child. A Court Ordered determination of custody is required to avoid continuing conflict between the parties regarding responsibility for custody and support. WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody subject to visitation by the Defendant. Respectfully submitted, ROMINGER, BAYLEY & WHARE Date: ?-9~t>s- ~ w/l Michael 1. Whare, Es uire 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court LD. # 89028 Attorney for Plaintiff KELLI 10 BOWERMASTER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. DAVID L BOWERMASTER Defendant : NO. 2003-1690 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. ~ 4904 relating to unsworn falsification to authorities. tLt1~ KELLI 10 BOWERMASTER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, DAVID L. BOWERMASTER Defendant : NO. 2003-1690 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE I, MICHAEL J. WHARE, Esquire, attorney for Plaintiff do hereby certify that I this day served a copy of the within Custody Complaint (after filing) upon the following by depositing same in the United States mail, Certified mail/ Return Receipt/Restricted Delivery at Carlisle, Pennsylvania, addressed as follows: David L. Bowermaster 23 Cleversburg Road Shippensburg, Pa 17257 Dated: f -q..-()~ /11~ ~vA- Michael 1. Whare, E qUIre Attorney for Plaintiff 1.~ ~ ~. ~~ ~ ~ "- ~ C> C ~~ -()::\\ ,~~c: r:,- ~--;;-- 7,~y tI;--^ ~",.c:< 'L\_r' :P"C1 -:.~-(., 7~ ? ~ i~ 3~ ~ ~:S ~ ,.."rt' r-:? "'" r ~ ""' ~ -a. ~ ,,-, I U> KELLl 10 BOWERMASTER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 05-4072 CIVIL ACTION LAW DAVID L. BOWERMASTER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, August 17,2005 , upon consideration ofthe attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, September 22, 2005 , the conciliator, at 8:30 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 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 48 hours prior to scheduled hearing. FOR THE COURT, By: Is! Hubert X Gilroy, Esq. Custody Conciliator rr- 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 HA VE 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 .~~~ ~~ ~ >>/}r?~ . /;Ifp -2 ~ ~It; 5t?~.$. ~ ~~ ~*'~-~ 5'r?/>('.,,$ '. , "-I!',j~!tq-.j I,./'I\I\J J'\'J\,..),,,.'.:....'.... n8 V'. 1, I ':" ""-1.:.\1 "^irri" ",. '"' 1\...t.I\' " 9 \ :5 WJ \ll 'JfW SOUl ''''''''I:"';.'.I:JHl :30 Ati\!! \)\'>.\0:'\,;.'......\.... -: - 381:lJC:--Q3ld ) i~, / I RECEIVED SEP 27 Z005 \\) KELLI JO BOWERMASTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW DAVID L. BOWERMASTER, Defendant NO. 05-4072 IN CUSTODY COURT ORDER AND NOW, this 4!" day of ~ , 2005, upon consideration of the attached Custody Conciliation report, it is ordered and directed as foDows: 1. The mother, Kelli Jo Bowermaster, and the father, David L. Bowermaster, shaD enjoy shared legal custody of Kara Page Bowermaster, born March 8, 1999. 2. The mother shaD enjoy primary physical custody of the minor child. 3. The father shaD enjoy periods of temporary physical custody of the minor child at such times and under such circumstances as agreed upon by the parties. 4. Neither party shaD consume alcoholic beverages while that parent has custody of the minor child. 5. In the event either party desires a modification of this Order, that party may petition the Court to have the case again scheduled for a Conference with the Custody Conciliator. c~avid L. Bowermaster ~~~~JUdge .)fichael J. Whare, Esquire ~ ~~ \\if::) LS : II !IV fl_ .1.30 SOOZ AtJV1Ci\i()--ilC<-::d 3Hl jO 38H;!G-QcJl!:l KELLI JO BOWERMASTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW DAVID L. BOWERMASTER, Defendant NO. 05-4072 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: Kara Page Bowermaster, born March 8,1999. 2. A Conciliation Conference was held on September 22, 2005, with the following individuals in attendance: The mother, Kelli Jo Bowermaster, with her counsel, Michael J. Whare, Esquire, and the father, David L. Bowermaster, who appeared without couusel. 3. The Conciliator recommends an Order in the form as attached. fl;) {;/ 0 ~ DATE ( Hubert X. Gilroy, Esqu. e Custody Conciliator