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HomeMy WebLinkAbout08-0903ALAN BOUDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law MELISSA BOYER, Defendant No. 0 Fr- 9 6 3 --tti f l +crA- IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, Alan Bouder, by and through his counsel, Michael J. Whare, Esquire and avers as follows: 1. Plaintiff is Alan Bouder, who currently resides at 31 Prospect Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Melissa Boyer, who currently resides at 7 East Orange Street, Mt. Holly, Cumberland County, Pennsylvania 17065. 3. Plaintiff seeks primary physical custody of Name Zaden Alan Bouder The child was born out of wedlock. Primary Residence DOB 31 Prospect Road 2/8/07 Carlisle, PA 17013 The child is presently in the custody of Alan Bouder, father, who resides at 31 Prospect Road, Carlisle, Cumberland County, Pennsylvania 17013. Since birth, the child has resided with the following persons at the following addresses: Name Addresses Dates Alan Bouder and 31 Prospect Road Birth- January 2007 Melissa Boyer Carlisle, PA 17013 Alan Bouder 31 Prospect Road January 2007- present Carlisle, PA 17013 The father of the child is Alan Bouder, who resides at 31 Prospect Road, Carlisle, Cumberland County, Pennsylvania 17013. He is single. The mother of the child is Melissa. Boyer, who resides at 7 East Orange Street, Mt. Holly, Cumberland County, Pennsylvania 17065. She is single. 4. The relationship of the Plaintiff to the child is that of natural father. The Plaintiff currently resides with the following persons: Name Relationship Zaden Bouder son 5. The relationship of the Defendant to the child is that of natural mother. The Defendant currently resides with the following persons: Name Relationship Tracy Griffey aunt 6. 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. 7. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 9. 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. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Names Address Basis of Claim None 10. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) Father is best able to provide the care and nurture which the child needs for healthy development. b) Father can provide the stability that the child needs for his well being. c) A Court Order of custody and structured visitation is desired so that Plaintiff and 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. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant his Complaint for primary physical custody of the child. Respectfully submitted, Date:-) - 7,07 Michael I Whare, E uire 37 East Pomfret Street Carlisle, PA 17013 Supreme Ct. Id No. 89028 Attorney for Plaintiff ALAN BOUDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law : No. 6,3,. q,6 3 MELISSA BOYER, Defendant IN CUSTODY 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.C.S. & 4904 relating to unsworn falsification to authorities. Date: Z. - ? - r?6 Alan Bouder, Plaintiff i9 V t s A Ca ? <s -Ti - m r?? = r ? c? f . ALAN BOUDER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-903 CIVIL ACTION LAW MELISSA BOYER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, February 13, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, March 07, 2008 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. 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: /s/ ,johns Mangani,L Esq? Custody Conciliator 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 arrangeme is 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 HAVE 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 ?jj 490 ( r?vpit' \AIAv N tvl2d L I :Z! W d ? ! 03d 90OZ AbVi.CN"U' ?-i.;Lt d 3N1 3Q