The URL can be used to link to this page

Home My WebLink About06-6149 .' II '. , ERIN M. BOWE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06- (PfQq CIVIL TERM TIMOTHY G. LAVANISH Defendant : CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Erin M. Bowe, an adult individual whose residence is at 38 Konhaus Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Timothy G. Lavanish, an adult individual whose residence is at 171 E. Pine Grove Road, Pine Grove, Center County, Pennsylvania, 16866. 3. Plaintiff seeks custody of her child Braeden P. Lavanish born on December 14, 2003. 4. The child is presently in the custody primarily of plaintiff and partially of defendant. 5. The child has lived at the following addresses: Name Address Dates Braeden P. Lavanish 38 Konhaus Road Jan 2006 - present Mechanicsburg, PA 17055 201 E Main Street Nov 2003 - Jan 2006 Mechanicsburg, PA 17055 6. The relationship of the plaintiff to the child is that of natural mother. 7. The relationship of the defendant to the child is that of natural father. 8. The plaintiff has not participated as a party or in any other capacity in other litigation concerning the custody of the child in this or any other Court. 9. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 10. No other persons are known to have or claim to have any right to custody or visitation of the child other than the parties to this action. T . . i . II , 13. The best interest and permanent welfare of the child will be served by granting the relief requested because the Plaintiff is the primary care giver with respect to the child. 14. The father was plead guilty to a felony drug charge on or about February 15, 2002 in Blair County, Pennsylvania, Docket # CP-07 -CR98-2002. 15. Father was released from Cumberland County Adult Probation on or about February 15, 2005. 16. Father has a drug and alcohol dependency problem. 17. Father's residence does not have the proper furnishings to accommodate a child. 18. Father resides with the landlord, Ronald Korman. 19. Father smokes cigarettes while in the presence of the child and allows third parties to smoke cigarettes in the presence of the child. 20.lt is feared that if Father is allowed to have unsupervised visitation with the child he will consume illegal drugs and alcohol in the presence of the child and allow third parties to do the same. 21. 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. WHEREFORE, Wherefore, plaintiff requests your Honorable Court schedule a conciliation conference and subsequently grant the plaintiff's requests for shared legal custody and primary physical custody of the child to the plaintiff with supervised visitation of the child to the defendant. Respectfully Submitted TURO LAW OFFICES /o/r,h d Da(e / alen R. Wal , 28 South Pitt S t Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff, Mother .- II :1 I I I I , , VERI FICA TION I verify that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. /~/;<1!o~ , ~~~f3j-fAl'f> Erin M. Bowe Date .- rr ~-I , " , .. CERTIFICATE OF SERVICE I, Galen R. Waltz, Esquire hereby certify that I served a true and correct copy of the Custody Complaint, by certified return receipt requeste2 and depositing same in the United States Mail, first class, postage pre-paid on th~(}~ay of ()ct.fd ~e~ ,2006, from Carlisle, Pennsylvania, addressed as follows: Timothy G. Lavanish 171 E. Pine Grove Road P.O. Box 339 Pine Grove, PA 16866 TURO LAW OFFICES c Galen R. Waltz, EsquiJ'i 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688; FAX 717.245.2165 - ~~~~ .......:3 C> '" d 0 ~ ~ ~ -0 "'00 t1 ~ 1 ~ -&. o c ?;: <J(li [i) (f': ",,;"~..-j" ; ?--r.... .~~~ :~". f~- ~~~.~ Z --l -< /'0.3 = = er- a n --I N o ~ ~~ -ok; :ut;J C~(.I.., -0 ,""-To i-':}::!:! :Jr. :;;. () w om :v .,.,~ - ERIN M. BOWE PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 06-6149 CIVIL ACTION LAW TIMOTHY G. LA VANISH DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, November 15,2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Monday, December 04,2006 at 10:30 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 pennanent 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 hearin2. FOR THE COURT. By: /s/ lacqueline M. Vemey, Esq. iJ1' Custody Conciliator i The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infonnation 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 p;;< ~ izr ~ ~4pl 717. 3/.// ' .~ 2 ~ ~ 7t?_r/.11 ~p 2. ~~ /'9 ~'5/ _// '. .' '~-1 f I""'t\ !\\\jf-l V~;\"I t1i/ \ ('\:)~,~~,~ :,,::';;~~^tnl"'\ f ..., r_ r\,_~, !'" ~,~'I ( ~ I ....J Alt\:f ; I,) I . 00 :'1 Hd S t AON 90Ul "', I,IY!,-; 3Hl:lO AtlVLUi,,,-, ,i.,:;.'}';':: 'Y:I.!,,\ ~!J:nH :1\./1_ t.." .,.,' II ERIN M. BOWE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-6149 CIVIL TERM TIMOTHY G. LAVANISH Defendant : CIVIL ACTION - CUSTODY PRAECIPE TO WITHDRAW CUSTODY COMPLAINT TO THE PROTHONOTARY: Please withdraw the Custody Complaint filed at the above captioned docket number for the parties have reconciled. Respectfully Submitted TURO LAW OFFICES I~~ D e n R. Waltz, Esq . 8 South Pitt Str Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff a c. ::~~=--, r-':> c:::> '3 c..- -.-.;'" ~ ::?-n ~;;~ ,:'..S(:~) ~\ ...:;..,- :? ;... '":~)~~" '::.\ 'J:'" ~ r:-? .- .... t..C FEB 0 8 2007}11 ERIN M. BOWE, Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2006-6149 : CIVIL ACTION - LAW TIMOTHY G. LA VANISH, Defendant : IN CUSTODY , , ORDER OF COURT AND NOW, this 5th day of February, 2007, being advised that the complaint has been withdrawn, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, fttt.~ dy Conciliator ~ <:::::l ~ -...., ..." fT1 co , 0"\ -0 ~ -.i;.~ o ." ~ nl~ \:J rn gZ :::~~: Om j;:! :0 --<: N .$.-