HomeMy WebLinkAbout04-1062AMANDA TUCKEY,
Plaintiff,
V.
TIMOTHY BOUDER,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
: IN CUSTODY
COMPLAINT FOR CUSTODY
AND NOW, comes the Haintiff, Amanda Tuckey, by and through her attorneys,
Mancke, Wagner & Spreha, and files the following Compla'mt for Custody:
1. The Plaintiff, Amanda Tuckey, is an adult individual residing at 935
Myerstown Road, Gardners, Cumberland County, Pennsylvania.
2. The Defendant, Timothy Bouder, is an adult individual residing at 802 Torway
Road, Gardners, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant are the natural parents of one (1) child, Hayden
Tuckey, bom January 21, 2004.
4. At all times since the birth of the child, the child has resided with the Plaintiff
at the address contained in paragraph 1 above.
5. The Plaintiffhere'm is the natural mother of Hayden; the Defendant is the
natural father of Hayden.
6. Hayden Tuckey was bom out of wedlock.
7. Plainfiffknows of no other person not a pasty to this action who has physical
custody of the child or claims to have custody or visitation fights with respect to the
child.
8. Plaintiffbelieves and therefore avers that it is in the best interests of Hayden to
grant primary physical custody unto the Plaintiff herein, subject to periods of visitation
during the current period of time because of the age of the child, gradually increasing
periods of partial custody as the child grows older.
WHEREFORE, Plaintiffprays this Court to grant the relief as requested.
Respectfully submitted,
~ ~Wagner, Esquire I.D. #23103
2233 North Front Street
Harrisburg, PA 17110
(7 ! 7) 234-705 !
Attorneys for Plaintiff
Date:
-2-
VERIFICATION
I verify that the statements made in the foregoing
document are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.So
Section 4904, relating to unsworn falsification to authorities.
AMANDA TUCKEY :
PLAINTIFF :
TIMOTHY BOUDER
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
04-1062 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Thursday, March 18, 2004 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear be~bre Melissa P. Greevy, Esq. , the conciliator,
at 301 Market Street, Lemoyne~ PA 17043 on Tuesday, April 27, 2004 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 hearin!~.
FOR THE COURT,
By: Is/
Melissa P. Greevy, Esq.
Custody Conciliator
mhc
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 befbre 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
HAY 0 4 2004~/ ~
AMANDATUCKEY,
Plaintiff
TIMOTHY BOUDER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NC). 04-1062 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
ORDER OFCOURT
AND NOW, this ~ek day of May, 2004, upon consideration of the Custody
Conciliation Summary Report, it is hereby ordered and directed as follows:
1. Le,qal Custody. Mother, Amanda Tuckey, will have sole legal custody of the
minor child, Hayden Tuckey, born January 21,2004.
2. Physical Custody. Mother shall have primary physical custody subject to
Father's rights of partial custody which shall be arranged by the mutual agreement of the
parties.
and Order.
Plaintiff's Counsel shall file a return of service with the Court for the Complaint
Dist:
P. Richard Wagner, Esquire, 2233 North Front Street, Harrisburg, PA 17110
Timothy Bouder, 802 Torway Road, Gardners, PA 17324
AMANDA TUCKEY,
Plaintiff
TIMOTHY BOUDER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERILAND COUNTY, PENNSYLVANIA
NO. 04-1062 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN THE CUSTODY OF
Hayden Tuckey
January 21,2004
Mother
2. A Custody Conciliation Conference was held on April 27, 2004 following
Mother's March 11, 2004 filing of a Complaint for Custody. Attending the conference were:
the Mother, Amanda Tuckey, and her counsel, P. Richard Wagner, Esquire. The Father,
Timothy Bouder, did not attend.
3. Counsel for the Mother produced a return receipt, restricted delivery card
indicating service of the Complaint and Order scheduling the Conciliation Conference on
March 25, 2004. Because Mother's petition was unopposed and service was perfected, the
attached Order is recommended to the Court.
Date Melissa Peel Greevy, Esquire 7
Custody Conciliator
:228116