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Home My WebLink About99-01855 ~ ~.~ 8 ~ Prothonotary ~ * ~ -~.~~-~,~--_..-.. .. - ,..""~-~,---,-~,-,------,.. - ,.)~ ~-'~~~~-----~ro*-*--****~*__*ro__' ~ ~ ~ ~.I ',' ~ ~.I ~ ~ ~.I ~ ..' ~ ~ ... ~ ~ fo~ ;.~ ~ ~ ~~ i~~':~~':'~- ')O:,:;oe. .;oe. ':c, :lI!' .:C':'!C' .,",: :~. "",. '~',::':- ..~, .~, :0:,:0:., ..... ......... ~,:l!_~~..'~_.:!!:~ ~i .. ~i IN THE COURT OF COMMON PLEAS g ~i . 81 OF CUMBERLAND COUNTY . ~ . ~ -~ g ~, STATE OF ~~ PENNA, . ~ 8 ~ Krystal L. BoucIer I 8 ~ '.' ~ '.' Plaintiff i\ 099-1855 ........~ ~ 8 ~ 3 ~ ~ ~ ~ ~ g ~ !oJ', '.' ~. \' l'1',~ II... $ Clarence E. Beucler I ~ tefendant ~ '.' ," ~ ~.' ~ DECREE IN D I V 0 R ;; d"" I/:S3 c;,~ . AND NOW, .. '" /~"1' ..1..... ..... '. ~....., it is ordered and decreed that ...... .~.st~.I. .~'. .~~~~ . .. . .. . . . . . .... .. '" . . . . '. plaintiff, and......... .<;1~~~.~, .~1,l~~.............................. defendant, are divorced from the bonds of matrimony. ~ ~': ~ :~ ~ ~ ~.I .'~ ~ ,', ~ ~ '.' s ~ '.~ ~ '.' ~~ ~ " ~ ~.I The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; '!be property settlement is incorporated but not merged into the decree. ............ ................. ... .......... ......... ......... .... ........... ~ ~ ........... ............. ~ ~ ~ ~ '.' Alle.l: J. ~ ..jl~14 ~ ~ , PROPERTY SETTLI~MENT AGREEMENT THIS IS AN AGREEMENT madc this .')3r! day of ~ ( / ,2000, by and between Krystnl J. Bouder, of 860 Carl wynne Manor. Apart ent #306, Carlisle, Cumberland County, Pennsylvania,(hercinaficr rcrerred to as Wife) and Clarence E. Bouder, Jr., of272 South West Street, Carlisle, Cumberland County, Pennsylvania, (hereinafter referred to as Husband). WHEREAS, Husband and Wire were married on April 23, 1983, in Cumberland County, Pennsylvania; and WHEREAS, various differences have arisen between Husband and Wife, whereby they have been living separate and apart since September 1998; and WHEREAS, the parties have agreed to maintain separate and permanent domiciles and to live apart from each other; and WHEREAS, the parties desire to enter into an amicable settlement to provide for all of the property rights of the parties and to dispose of the rights and obligations or each to the other in respect to support, maintenancc, alimony, counsel fees, equitable distribution, and all other rights and obligations under the Divorce Code of 1980, as amended, and it is the intention and agreement of the parties that this Agreement be a full, complete and final settlement of all of those rights and obligations under said Divorce Code; and NOW, THEREFORE, for and in exchange of mutual considerations, and intending to be bound by the provisions hereof, the parties agree that their recitals form a part of this Agreement and waive any right to counseling under the Divorce Code of 1980, as amended, and right to counsel fees, costs, alimony, support, maintenance, and any other rights under the said Divorce Code not provided for herein and agree as follows: 1. SEPARATION. The parties agree that it shall be lawful for each party, at all times hereafter, to live separate and apart from the other, at such place or places as he or she may, from time-to. time, choose or deem fit. Each party shall be free from interference, authority or contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement and as may be necessary to exchange information that pertains to the parties' minor child. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart, from the other. 1 . 2. REAL ESTATE. Thc partics have sold thc marital rcsidence locatcd at 240 A Street, Carlislc, Pcnnsylvania 17013. At that timc Ihc lI10rtgnge which was outstanding was sntisfied. 3. AUTOMOBILES. Wifc shall have as hcr solc and cxclusivc property, title to and posscssion of the 1992 Subaru Legacy. Wife shall indcmniry and hold the other harmless from and liability on any loan encumbering the vchiclc, cost ofrcpairs, maintenance, rcgistration, insurancc and/or inspection of thc vehicle which each is taking as her sole and cxclusivc property. Husband agrees that he will sign olT on Ihe title 10 Wifc's vehicle within lhirty days of signing this agreement. 4. PERSONAL PROPERTY. The parties have divided or have agreed to a division of their pcrsonal property which includes bank accounts, certificates of deposit, life insurance policies, jcwelry, clothing, fumiture and other personal items. After the aforesaid division of the personal property is complete, any and all property in the possession of Husband shall be his solc and separate property. Any and all property in the possession of Wife shall be her sole and separate property. Each party forever renounces whatever claims he/she may have with respect to the property which thc other is taking. Each party understands that he/she has no right or claim to any property acquired by the other after the signing of this Agreement. 5. PENSION/RETIREMENT PLANS. Wife hereby releases any and all claims or demands shc may have on Husband's pension or retirement plans. Husband hereby rcleases any and all claims or demands he may have on Wife's pension or retirement plans. 6. DEBTS. The parties represent and warrant to each other that neither has incurred any other debts nor made any other contracts for which the other or hislher estate may be liable, from date of separation forward. Neither party shall contract nor incur any debt or liability for which the other or hislher property or estate might be responsible and agrees to indemnify the other from any claims made against the other because of debts/obligations not incurred by thc other. 7. ALIMONY, ALIMONY PENDENTE LITE, SUPPORT OF SPOUSE. The parties waive any and all right to receive from the other any payment of alimony, alimony pendente lite, and/or spousal support. 8. EFFECTIVE DATE. The effective date of this Agreement shall be the date of execution by the parties if they had each executed the Agreement on the same date. Otherwise, the execution date of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 9. DIVORCE. The parties agree that should either party file a Complaint in Divorce, claiming that the marriage is irretrievably broken under the no-rault mutual consent provision of 2 Section 3301(e) of the Pennsylvania Divorce Codc,thcn both panies agree to execute any and all affidavits or other documents necessary for thc partics tOllbtain an absolulC divorce pursuant to Sections 3301(c) of the Divorce Code including wuivcr orall rights to rcquest Court ordered counseling. It is agreed and understood bclwecn thc parties that in the cvent a divorce proceeding is filed by either party in any other jurisdiction, thatlhe parties shall nnt contest, but instead consent to such proceedings and shall execute any and all documcnts necessary so as to proceed with and obtain an absolute and final divorce. 10. INCORPORATION INTO DECREE. Should a decree, judgment or order ofscpararion or divorce be obtained by either of the parties in this or any othcr state, country, or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order or further modification and revision thereof shall alter, amcnd or vary any term of this Agreement, whether or not either or both of the parties shall remarry, it being understood by and between the parties hereto that this Agreement shall survive and shall not be merged into any decree, judgment, or order of divorce or separation. It is specifically agreed, however, that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any divorce, judgment or its decree. This incorporation, however, shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. II. MUTUAL RELEASE. Husband and Wife do hereby mutually remise, release, quit claim or forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, from any and all rights, title and interest, or claims in or against the estate of such other, of whatever nature and wherever situate, which he or she now has or at anytime hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy of claims in the nature of dower or curtesy, or widow's or widower's rights, family exemption or similar allowance or under the intestate laws; or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary or all or other rights of the surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory of the United States, or any other country or any right which either party may now have or at anytime hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of Husband and Wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and 3 obligations ofwhatsocvcr nature urising or which may urisc undcr this Agreemcnt or for the breach of any prnvision thcrcol: 12. COUNSEL FEES. Each party individually covenants and agrees that he or she will individually assume thc rull and solc responsibility ror legal expcnscs for his or her altomey and court costs in conncction with uny divorcc action which may be brought by cither party and shall makc no claim against the othcr ror such eosts or fces. 13. ADDITIONAL INSTRUMENTS. Elll'h oflhe parties shall, from time.co.time, at the request of the othcr, execute, acknowledge and deliver to the othcr party any and all further instruments or documents that :nay be reasonable rcquired to give full force and effect to thc provisions of this Agreement. 14. MOD/FICA TION OR WAIVER. A modification or waiver of any of the provisions of this Agreement shall be elTective only ifmade in writing and executed with the same formality as this Agreement. The failure of either party to insist upon the strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default ofche same or similar nature. 15. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the parties and there arc no representations, warranties, covenants or undertakings other than those expressly set forth herein. 16. SEPARATE PARAGRAPHS. It is specifically understood and agreed by and between the parties thereto that each paragraph hereof shall be deemed to be a separate and independent agreement. 17. BREACH. If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her and the party breaching this Agreement shall be responsible for payment oflegal fees and costs incurred by the other in enforcing the rights under this Agreement, or in seeking such other remedies or relief as may be available to him or her. 18. CONTROLLING LAW. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 19. INVALIDITY OF PROVISIONS. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement, and, in all other respects, this Agreement shall be valid and eontinue in full force, effect and operation. 4 20. BINDING NATURE. Except as othcrwise sct lilrth hcrein, this Agreement shull be binding und shall inure tolhc bcnefitof the partics hcrclo "nd thcir respcctive heirs, executors, administrutors, successors and ussigns. IN WITNESS WIIEREOF, the parties have hereunto seltheir hands and seals the day and year first above written. WITNESS ~~a.eQ~cUv Kryst I J. Bobaer /?,a Jd h/JC 7 /If!- ? ~/!..?-. Clarence E. Bouder. Jr. f;; ('J -,. ~- ~ N <~ -c ~JP "":i 't" () ::~ lEt' ,'- ::,\::;~ ('J." ..-.~ @t;~ '" :.S~ .u '.- I ~":. /~ 0:": >- . '.~ u..l Kt :-.lU. ~: ll.. n ~'j 0 0 U >- <'j ..... ~ 1- % '"' N =-=-'.- 0 ~~-. ~~<~~ -.. ~ C, ~. '-~ ~f' a... :);;= gf: C"') -~. ':1) I )~..... LLlI,". :::2 -!I.l' ;:.... : ~; t:J U;.. """ ~;J('L ., , .- .... tI. a ::') 0 c::.. U KRYSTALJ. BaUDER, PlaintilT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO.99. /8.sS CIVIL TERM v. CLARENCE E. BaUDER, JR., Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE Plaintiff, Krystal J. Bouder, by her attorney, Lindsay D. Baird, Esquire, sets forth the following: Plaintiff, Krystal J. Bouder, is an adult individual residing at 860 Carlwynne Manor #306, Carlisle, Cumberland County, Pennsylvania. 2 Defendant, Clarence E. Bouder, Jr., is an adult individual residing at 240 A Street, Carlisle, Cumberland County, Pennsylvania. 3 The parties were married on April 23, 1983, in Carlisle, P A. 4 Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the commencement of this action. 5 This action is not collusive. 6 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff 7 In accordance with Scction 3301(c) of the Divorce Code, thc marriagc betwcen thc partics is irrctricvable broken. 8 Plaintiff has been advised that counscling is available and that PlaintilT may have the right to requcst that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the PlaintilTbe divorced from thc Defendant. COUNT II. EQUITABLE DISTRIBUTION 9 Paragraphs I through 8 of the Complaint are incorporated herein by reference as though set forth in full. 10 Plaintiff and Defendant have acquired property, both real and personal during their marriage from April 23, 1983 until September 8,1998, the date of their separation. 11 Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property. Yli-~ Lindsay D. Baird, Esquire Attomey for the Plaintiff 37 S. Hanover Street Carlisle, PA 17013 717 - 243-5732 I";'; ; '::T- ('0 I~ t -;. ..sl .,.. ~ 0 ~ I - I . '\\ I ~ ~ , I i ~ 10 ;~ ~ ~ I "" Ir: ~l I ~p ". I i -( , ; ~G .. ~ , c._ I " a, - ...., (\J l; 0.: ~, c.. Fl.' ..' ., j ....- I LI, ..... ~ . I . 0 0\ ., 0'\ ! '-' , I I I >- ,-, - ~r: 1.__ ~ 'b '~~ M ~(f) ~g: I :')Z a:Z lt~J >- UJlL.l ':J.: """ .:nU- ..... ;,c "'" u_ D :5 0 0 U .."" ~~ KRYSTALJ. BaUDER, Plaintiff IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA v. NO. 99.1855 CIVIL TERM CLARENCE E. BaUDER, Jr., Defendant : IN DIVORCE AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOnCE OF INTENTION TO REQUEST ENTRy OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on March 29, 1999. 2. Defendant acknowledged receipt and accepted service of the Complaint on March 31, 1999. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 6. I understand that I will not be divorced until a divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: Y- -'-J-OO , d! Clarence ? 1f~- E. Bouder,J"r. ~ lLl~ ~~. -0 9~"; @o. li! ~i .,. t- 1-'. o C') N ;;.:: (") I >- .ct ::i: o c::> b. S<e ~)~ '.J." c,:3 '~~:in :::J:--:: <CZ; 'dLO .ilO_ -;: ~j Cl , . . , . " ' , , .........-..-- KRYSTAL J.BOUDER, I'luintilT IN TIlE COURT OF COMMON PLEAS OF CUMBERI.AND COUNTY PENNSYLVANIA v. NO. 99. 1855 CIVIL TERM CI.ARENCE E. BaUDER, Jr., Dclcndant : IN DIVORCE AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION '1'0 REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 330l(C) of the Divorce Code was filed on March 29, 1999. 2. Defendant acknowledged receipt and accepted service of the Complaint on March 31, 1999. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without not ice. 5. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 6. I understand that I will not be divorced until a divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: r..j.:>?C'0 ~.ld1,~ Krys al L. Bouder " .' , .. .":.., .'" r '.' . . ~ ,~ ,....~~}' /:'\~,' , " ,roM '. : '., .~'" ")'" i:"1 ..,I::\,..:.:",...I~ '':''r:;.>:\....'..-.!.C'...A}.&'-~.tt ~.I:r;, . '1_~., .,' . " ~ ,': .....'.~ .tr"~ ~.j......J.tf..r::.;.-~ \1~.~ '. ,..U"u.~YD"DIII'r::Il............ -.~ ,', \~. "}. .,t'..J'j'.~r"':''.J>"-,':'"''.l''' ~~"" " p' "t.~ ...__~ ......._.~~_..",...........i4 .~.. . A'M'()JUfhA.T'.aw .:'..'-~ -", .... -",." ~... "'T-'l"-~i.'77""'~A4"~.;Jn:~ " - ".1o?ii\ "--'" ':,'..,; '...l",..-.I'.~If,.'aoi. .(....,.!.~'" .. .780 u....__il!h....:...;..-..~..~...; ,.'..' "A~i:'~"~" 1 ..v~~ OJ tmt 6JN1IUV."g'j,KAIi.r .f. 'I" " '" 4, I .. , '.li." ~ - .... < "f' . h-.,.:~ . "'-. '~.. ~'.,' > '" ~t "'_". "", ~,~,. "" ~. .,~ . CAJU.t8LC.I'ZHNiYWAHIA 1701~.S807"" :"~: /0.': ':., ," -,':: ....t. ;.,:,,(f!~:{:OO'...~.f...~.:r.=:1:'. t"~~!':/' . (717)243,0732 'All(717)~.8110:,.(:. ,(.,'.).': .,.',.. ..,';~.~.:...."1',,;:tfr-"l11,. . 6. . "'.L ~~ ~...,\. .....-:.';;~~. I't,.' ',"'".-, ~"",~"'-Io.#....r...,. ~(:1,,~ lll..~' ., 1. KRYSTAL J. BaUDER, Plaintifl' v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA NO. 99- 13 sS" CIVIL TERM CLARENCE E. BaUDER, JR., Defendant IN CUSTODY ORDER AND NOTICE AND NOW, A?r\ \,. 1999, upon consideration of the attached complaint, It is hereb directed that the parties and their respective counsel appear before ' r. . t::S . , the eonciliator, ~ r ~ G rm~ ~~ of~ ,19 , at " ~ 0. rn., 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. FOR THE COURT, By:~\J!ho\~ 'I. if) I O~ ~. Custody Conciliator ( .\ 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 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 eonference or hearing. YOU SHOULD TAI<E THIS 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, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 1',1 rr, ," .~ ~.:.:: .....r-.., t";il r~ ~s f,;-; -'') 1'.. 2: 15 cu;' ::1' '. -" 1- L ~" . j L'p , )j.f.ff &d- ~ At~ t- cilf ~ 4~.7P 7t~ ~~~ dffV' ~f'fi '" lao'/ LOJ'Z7 /'- ,,4/"";"" # ~~ ~ f '," ,.' . II ':' ~.'/ ,.... ,J,' .:'-I'.........,/.j. ...U\j,.~,;.c.r.~;':j' ? ,:":,;~,,,,:,./:..,.,.,., " ,. . ..' <\~",~";","",-\(~,,,(,,'Ji;;;'''!''\.t',,::,'}.l '1 .r..:" ~ "... . .,. " .,,r L'.~....:j'r:'!'{:rjo'l:'";i'\.!,:"~~~I' ""...;y./.., ' .,' . .,.' ,.,' . ,1, J. "", 'r "'" ',' ~,/ <!J.\J"I':\-~I:(';;~f. ':.ro.,'l'. . '; ~.~',::'.',:;' "j ,.", Y' I 'I. I. ,"". ....;.~ ,~~.:-.;.: ~ , t"':\:;l\,<,;"l;:"<;~''''I\J. /' :. .',' t,": ", ~ ~." .,;.,...... ""';",>'~"'~"'K':~'~f~.-';"~_r>';i~r'.4(/>."Jl?~' ,.., ",- ,-. "r. I:' ," '0',..' '.~".; i.~I,...o.t'''''''~If~'''f.'~''~'~''d';;;'J:o'O:W''' ,"" r.. .~;'r: r. ......-;- .,".,.'-,,' ,\./.~t'~"'/l"",\~);i'Z'.tJo....t;?\[..~l" ,..,1'- .,.... "'-""{""';"""'~~''''''''I''!.'':ill-''''''1I1>'&~~n~ r. /..: . ,,~,' ':'i):<~~,';.'. ,: /~~~/)y:-..~,{, :~;.\:.:~<.:; "::f~~{;;:1!~;:~\\:~~~~}t~ig~~.~~~:l ' - .....'.. "';;'",'!:- '. ..' \~ ~,',,;':, ,:->j~~"'., ,^~l"';:-:";;!"":K;~'~'~~~ '''''~vN'.t',.;:.t~ ' .,' .......: :, "'...' I:.. ..:.)>/!..I:,..;..~!.:;',~ ~.-.-: }.~,/,..... ....,,11 .:~;-'Z !~,!J:5.'tf;. ~~. .. KRYSTAL J. HOUDE/{, Plaintiff IN TIlE COURT OF COMMON PI.EAS OF CUMBERLAND COUNTY I'ENNSYL VANIA v. NO. 91). /8 $5 CIVIL TERM CI.ARENCE E. [lOUDER, JR., Dclcndant IN CUSTODY COMPlAINT FOR CUSTODY J. The plaintiff is I<rystal J. Bauder, residing at 860 Carlwynne Manor #306, Carlisle, Cumberland County, Pennsylvania. 2, The defendant is Clarence E. Bauder, Jr., residing at 240 A Street, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following children: Nww: Ashley Bauder Alicia Bauder Present Residence 860 Carlwynne Manor #306, Carlisle, PA 860 Carlwynne Manor #306, Carlisle, PA ~ 15 Years 12 Years The children were not born out of wedtock. The children are presently in the custody of the mother who resides at 860 Carlwynne Manor, Carlisle, PA. During the past five years, the children have resided with the following persons and at the following addresses: Person Mother and Father Ashley with Father Alicia with I<en Sjoberg(uncle) Mother Address 240 A Street, Carlisle, PA 240 A Street, Carlisle, PA 350 Old Mill Rd., Carlisle, PA 860 Carlwynne Manor #306 ~ Mar. '94-Sept. '98 Sept. . Nov. 1998 Sept. . Dec. 1998 Nov!Dec '98. now The mother of the children is I<rystal J. Bouder, currently residing at 860 Carlwynne idanor #306, Carlisle, PA. She is married. The father of the ehildren is Clarence E. Bouder, currently residing at 240 A Street, Carlisle, PA. He is married. ". 4. The relationship of plaintiff to the children Is that of mother. The plaintiffs household Includes the following persons: ~ Relationship KrystaJ J. Bouder Mother Ashley Bouder Daughter Alicia Bouder Daughter S, The relationship of defendant to the children Is that of father, The defendant's household Includes the following persons: NlIIw: Relationship Clarence E. Bouder Father Galen Bouder Father's Brother 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. Plalntlff 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. 7. The best Interest and permanent welfare of the children will be served by granting the relief requested because: a) Plaintiff can provide the children with a home with adequate moral, emotional and physical surroundings as required to meet the children's needs; b) Plaintiff Is willing to accept custody of the children; c) Plaintiff continues to exercise parental duties and enjoys the love and affection of the children. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this aetion. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to Intervene: J:!IJl!!!l: Address Basis of Claim NONE Wherefore, plaintiff requests the court to grant custody of the children. ~~t&.M-C~ Lindsay Dare Baird, Esquire 37 South Hanover Carlisle, PA 17013 Attorney for Plaintiff >- t :l- ~ 0> r L-; ," ~ J-C ,. IJJ:) C(. J \lQ 0.' ~ fE '~~ . '0 (" ~I. ....L. ~1\ ".', I -' C.J 11' rr!. c:,' 0 (j~ f~-: C'( It .'. ~ C) c", c' , U " FiIID-0iFiCC or n-:: f':v.-r.J('}:i)TAAY 99 JUH -3 AM 9: 26 CUMiiEfl~!) COUNTY PENNSYlVANv\