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Home My WebLink About01-2446 FX ,," \-"'\~. . ;." '~ '" ',-., -,-" ., -;--- -~,.,,~ ,,-,,-,..' - "..,C, ',:", " : _,:', ,~o, L cO,'_" - '.' ,J,.. ",.', -" ""'. d~- '_' ~,~ """"" ',.' >'_, '___'''--,.,. -"d~ ~ ANTHONY M, JONES, Defendant : NO, 0 t. ;LW+v CIVIL TERM . I I i I I I I I I , '1 1 1 I I I I I i .1 , I I ! CINDY BOONIE, Plaintiff v. : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 1N CUSTODY ORDER OF COURT AND NOW, this_ day of ,~consideration of the attached complaint, it is ~ereby directed that the parties ~ir respective counsel appear before "; the conciliator, at ..---/ ..........' on the _ day of "",,200_, at..--- m., for a Pre-Hearing Custody Conference. At such .... // conference, an effort will he ad€ to resolve the issues in dispute; or if this cannot be accomplished, / to defme and narrow the jSBues e heard by the court, and to enter into a temporary order. All / children age five Or}llder may also be sent at the conference. Failure to appear at the conference may provide ~p~ds for entry of a tempor or permanent order. /? / ..' / FOR THE COURT: By: Custody Conciliator YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities andreasonable 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. '" ,.:.-." '1-_ '. ,~-ik.:",.~,o", ..:--,:.:>.,- _-,.'>-",;,,'-~ :.-; ~ --~.->:.,;~;~-;"~"S::;:~';';.-,' .- , ".~ A CINDY BOONIE, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION - LAW IN CUSTODY ANTHONY M. JONES, Defendant NO. 0 I. .J..,lflJ.(.a CNIL TERM COMPLAINT FOR CUSTODY The plaintiff, Cindy Boonie, by her attorneys, the Family Law Clinic, sets forth the following cause of action: 1. The plaintiff is Cindy Boonie residing at 17 Birch Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The defendant is Anthony Jones, current residence unknown. Upon information and belief,the defendant receives mail at P. O.Box 1313, Carlisle, Cumberland County, Pennsylvania,17013. 3. Plaintiff seeks custody of the following children: Name Present Residence Date of Birth Kayenta Boonie 17 Birch Street, Mechanicsburg, 09/21/00 Cumberland County, P A 17055 The child was born out of wedlock. The child is presently in the custody of Cindy Boonie, who resides at 17 Birch Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. During the past five years, the child has resided with the following persons and at the following addresses: Persons Address Dates Cindy Boonie 17 Birch Street, 09/21/00 - Present Mechanicsburg, PA 17055 ,d _ _~ _c, , - ;:-. -; - - k .'- > c'''_- ,-.; "L" ~"" ;C, .__ '" -~_5'-__i''''_ .;_,;.;.-", .. """, The mother of the child is Cindy Boonie currently residing at 17 Birch Street, Mechanicburg, Cumberland County, Pennsylvania, 17055. She is single. The father of the child is Anthony Jones, currently residence is unknown. Upon information and belief, the defendant receives mail at P.O. Box 1313, Carlisle, Cumberland County, Pennsylvania, 17013. He is single. 4. The relationship of the plaintiff to the child is that of Mother. The plaintiff resides with the following persons: Name Relationshin Kayenta Boonie Daughter Alicia Boonie Daughter 5. The relationship of defendant to the child is that of Father. The defendant currently resides with the following persons: Name Relationship Unknown Unknown 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending 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 children or claims to have custody or visitation rights with respect to the children. -',"1.-,,' ~ . ".'-,',F .".0;,'- '.;-, -,-~ '".,.-'".,!:',. J_;. ;" _'__,,--;-,/~,,~ ';,', ---';,i;-~_";--"'~_,-_''''eY- ;wp 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) The Father has not had a relationship with the child b) Father has never played an active role in the social, emotional, or psychological well being of the child. c) Mother has been the only active parent in child's life 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, plaintiff requests the court to grant her sole legal and primary physical custody of the child. Date: Lf Jzo '0 \ .)(JilJW ?J C~ Matthew J. Goodrich Certified Legal Intern ~ ~ /--- SM~ ROBERT E. RAINS TERI L. HENNING Supervising Attorneys FAMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717/243-2968 "" ,'< .. ,,' ... -~'-,,, ,<'-,- .."0' .. , ;" ,',-; L"., .. "-Ie:': .. " ,=-" ... "' .~, ".- . , r~ ,', l VERIFICATION I verifY that the statements made in this Custody Complaint are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: ~ - 11- 0\ t~~ em"~. ~- - '- ,',- ';'Jit,jjg'i!ttM~M",>&oi'EHH~""la-i~ '. -'. -"<.-"'i1rJ'i..if.lllllIt~Ji!iW<_ - - '- - -"I:mih~ttlir~ w ';'i'-~~-~," ~ ""'j ~A'l.m. IV, ~......"...f.., _ . ......LAi.~J,.,.~~~4:. ......~.. PRO'fHON6TARY .........'............. ~' if: III!. -, .~=~ _~", , _N~_._ ,_ ~~ . "m . .. ~,~_.-."-; H \. 'b .... .,.,~ Q<(' , (") ~ "S... -ot0 - r:p [~.~ ""_......J :zC- (f).o- ~~ '~H >8 Z ~ I~( <::, --<\, C7'\:) "'- .".""""",., " ..... "I Q c) "TI ",",' ..,,. ;0 N 0'. ... 'f.f1~1 -"7~n -dy ~~~ "'z-.cv om -.; ?b -< >." ::l!:' 9 N , ,-, . ~, " ,.~-, -,,, - -" '-- ~~- -" " lir.i..:"_ " - ~'PR :3 0200P (/ -. -'0' CINDY BOONIE, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLV ANlA :CIVIL ACTION . LAW :IN CUSTODY v. :NO. 0/-), <($Ie. CIVIL TERM ANTHONY M JONES, Defendant CUSTODY AGREE.MENTAND ORDER THIS AGREEMENT, made this ,,;I' day of /VI. '<t" 2001, between Cindy Boonie, hereinafter mother, and Anthony Jones, hereinafter father, concerns the custody of the child: Kayenta J, Boonie, born September 21,2000. Father and mother desire to enter into an agreement as to the custody of the child, Father and mother agree to the following: 1. The Mother shall have sole legal custody of the child, 2. The Mother shall have primary physical custody of the child 3, The father shall have supervised visitation with the child, at times to be agreed upon by the parties. 4, The father shall give the mother at least two (2) weeks notice when he would like to schedule a supervised visit, If the proposed date and time are acceptable t'? the mother, the parties may then schedule the visit. 5, All visits will occur at the mother's residence and under the mother's supervision, 6, Father agrees that none of his visits with the child shall occur outside the Commonwealth of Pennsylvania. b ;". -'0,-- T. _';' ",-_~. ,,' .1-:.-""<_ - "."_,,;,.;';'-'," --";' ,- ,-,,-' > " ,,~ -~ - ,,0 -. 7, The father shall be entitled to reasonable telephone access with the child while the child is in the mother's custody. 8. Neither parent will do anything which may estrange the child from the other party or injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's love and respect for the other parent, 9. The parties intend to be bound by the terms of this agreement and intend for this agreement to be made an Order of Court. 10. The father understands that the Family Law Clinic represents only the mother's interests in this matter and cannot give him any legal advice, except that he should seek the advice of legal counsel if he has any questions or concerns. Father understands this and has chosen to proceed without counseL {c;:"rlrLA~f/ ~~ Anthony Jones, Defendant Cindy Boonie, Plaintiff .J!.dtJ.uw9~~ Matthew J. Goodrich Certified Legal Intern Attorney for Defendant , -. -,;,--' ..~ "........ _ J___ f'\/ v ~~ L Th as M. Place Robert E. Rains Teri L. Henning SUPERVISING A TIORNEYS FAMILY LAW CLINIC 45 North Pitt Stteet Carlisle, P A 17013 (717) 243.2968 ORDER -~' 0,. , ;1 ., . ". , ", '-'",- -'i, ",.' - -: ,.-"::'>': - -~-p.",,"-'-" "-,.",,y-, AND NOW, this I~ day of)Vlh. ,2001 this cusrod agreement is entered as an Order of the Court, (j BY J. iiii't"'" "'IiiOi1,~:."',,",,",_"i'.'" ";*.__",_,,,,,.,',w,,i..,,,,,,_,,.~,. , IfiNYJ\lASNN3ri I 'Nr,^,~ "II <, I\J. I tlAJ \.L\\f!i:-.l:i8iVnCJ 11U:I lid I !Hfl I ~ - I\~i'j U AtJVIC): m ".-..- "1;; ~ ,=,.<~o. ~_~ ....,;;,'"'~Iillillilllll~~nlll!"" "<" ,~~, -~"'~- " ." ~~ '-"~"il:'i ~ . jjj ><,- , , ~, ,,- -.,,--~ >c >,' .-,-;,c_,__,.;_,."_ _;""_~ -~ ,",_'0,_::>,.,__, - _,' ~"_,'C d-,""fc~-,<,i,'c-"'- ,';'.;." , '--~"--I': .. CINDY L. BOONIE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA v. CMLACTION-LAW ANTHONY M. JONES, Defendant NO.O/- ;)'-/</:-<., CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Cindy L. Boonie, Plaintif:(, to proceed in forma pauperis. I, Matthew 1. Goodrich, Certified Legal Intern in the Family Law Clinic, for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. ~/ZOlbl }jJJ;bM;>{! ~.a;..J.-- Matthew 1. Goodrich Certified Legal Intern / ~~-I:/ - ~T E. RAINS'-/' THOMAS M. PLACE TERl L. HENNING Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 ,~~- ~, .-~'~-~ !~&l~ 1J.. ~ .Jjj1. -" .~ ,. ~ ~_~- '."""'~~'" ~.0~ - ;-,-~ ""'~~:lIi",~~I~~~~ -. VIIW,~7^SNN3d AlNnoO G!'/'vli:f]8/!'inO 'Z:OI IJV 9Z (Jd'i 10 j U\i'O'\'(~'!Ji{....,.; Cr.! i -'uA I\U~1. I .v, i.Lv"_,,... '~J 1..+ -l :;"!~4r,..('j"lu ~__V!;...'-- '-' ",~J, I.') ,~ -' " L...:;.','__ ',0; ..... ... Ill! ~ ~ . ~ ", CO,,"; __ i--,~ -, . ,_,c__,' .,,5>_ ' ,._c-'_ "_',- _c'. ~, '----"-,~,','- i;-",'---,' -,: ~ CINDY L. BOONIE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLV ANlA v. : CIVIL ACTION - LAW ANTHONY M. JONES, Defendant : NO. 6/. ;),..,,,,fd CIVIL TERM AFFIDAVIT SUPPORTING PRAECIPE FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am the PlaintifflPetitioner in the above rnatter and because of rny fmancial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs oflitigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: Cindy L. Boonie Address: 17 Birch Street, Mechanicsburg, P A 17055 Social Security No.: 160-58-3351 (b) Employment If you are presently employed, state Employer: Value City Furniture Address: 6520 Carlisle Pike, Mechanicsburg, 17050 Salary or wages per month: $1,148.40 Type of work: Clerical If you are presently unemployed, state Date of last employment: Salary or wages per month: Type of work: ( c) Other income within the past twelve months Business or profession: Other self-employment: Interest: Dividends: Pension and annuities: Social security benefits: Support payments: $65 /month. Child Support - Alicia Boonie Disability payments: Unemployment compensation and supplemental benefits: Workman's compensation: Public Assistance: Other: (d) Other contributions to household support (Wife)(Husband) Name: If your (wife)(husband) is employed, state Employer: Salary or wages per month: Type of work: Contributions from children: Contributions from parents: Other contributions: Property owned Cash: Checking account: Yes- Waypoint Bank, Current Balance $28.00 Savings account: No Certificates of deposit: Real estate (including home): Motor vehicle: Cost, Amount Owed $ Stocks; bonds: Other: Debts and obligations Mortgage: $635.00 /month Rent: Loans: Other: Real Estate Tax Debt $600 CW Fritz $375 Tree Trimmers Utilities Persons dependent upon you for support Name: Children, if any: Name: Alicia Boonie Kayenta Boonie (e) (f) (g) Age: 5 Age: 7 months Other persons: Name: Relationship: -~ --~ " "; --:~ ,~.. '.- ,,,' ,~ _,,",___,-'c,c -,__,-T_~'d_h;:,~_~__,--_~:" '-.y- -.--,',-~"-,~,,--c,,,''';,,;--;;' ,~--" ~---.i,,,,:ti<c;;,.;~:"i<~,;l,';-;:;~~>_-l__'~ ""j- , < 4. I understand that I have a continuing obligation to inform the court of irnprovernent in my fmancial circumstances which would permit me to pay the costs incurred herein, 5. I verify that the statements rnade in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. 4904, relating to unsworn falsification to authorities. Date L\-21D-D\ J I~tr -"':'''':''-:;i..i:~;il~l!t:;t!ill:-ll\J~CWitiW -- ~_u ~~.m.Wl!i[!'~~-~~-'''"~'"-;;' -, .. > w ~_. . ~ _ 0 ... -,,~' '.;,J,,' ,n H'""'r,~, "'l (') Cl 0 c: '1'1 $. J::o .-, -OW '-0 ":1e tp lJ; ^' ..-.;;.....1.,' ZC' ''0 ;~jFi (j) "':~; CT. "_>..1 -<L_ c:c:; ~._......J ;z>> .'f" ~" -... "")-,, ~8 ~ - ~7l-; s:? "'-m )>c: ~ Z 0...) -.,. =< ~ '" \-= ".-- " -'-,,' ~'" '-;'0" '~'~""c"'1"..II;.",,;~i : CINDY BOONIE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA v. CIVIL ACTION-LAW IN CUSTODY ANTHONY M. JONES, Defendant NO. 01 - 2446 CIVIL TERM PRAECIPE TO REINSTATE THE COMPLAINT To the Prothonotary: Please reinstate the complaint in the above-captioned case. Date: June 14,2001 ...1M\^-"[) ~ ~~~~ Certified Legal Intern cii21: ~j , Robert E. Rains Teri L. Henning Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 .~ ~_'-~-W"m"llfiljiiltB~-'W&_"W;%."'i"d;~~t0.1kr-.tigtH1W~""SM,(ih;@d"i;lO.:i'!i~;"lt"l?1;:.1ili-<iliLq-f2L~M,~u~illt&i!;~~liflW"""""-""~"" $ !"';'l~:,,~~,~- - f[, - ,,"~-'~- "'~"--"'-~~._'"-~, .. -~ ~ -' "~ "~-~< "~'L~i:IIliI;liifli.il."'~ ~. li!r~ "Jrl 0 C' ~ C .,! s:. t..- -ow oS; ._- -;~ rnrn - " -"' Z::rJ '~~'i 2' .:;i~), 65.~- ~/~ \:20 ".. :;=',-:;,:0 ~8 ~ ;dC) 'f! ;:;;:,rn J>'C ::::{ ~ :.n 55 -1 :<: ~?];;~