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Home My WebLink About08-6124 SAMUEL A. BOORS & : IN THE COURT OF COMMON PLEAS OF ELAINE M. BOORE, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : Civil Action- Law : No. WAY ABDULLAH ALJUWAIE &: LISA MARIE ALJUWAIE Defendants : IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiffs, Samuel A. Boore and Elaine M. Boore, by and through their counsel, Michael J. Whare, Esquire and avers as follows: 1. Plaintiffs are Samuel A. Boore and Elaine M. Boore, who currently reside at 6516 Liptak Drive, Harrisburg, Dauphin County, Pennsylvania 17112. 2. Defendants are Luay Abdullah Alujwaie and Lisa Marie Alujwaie, who currently reside in Riyadh, Saudi Arabia. 3. Plaintiffs seek primary physical custody of. Name Primary Residence DOB Leena Luay Aljuwaie Riyadh 12/08/91 Saudi Arabia Lamis Luay Aljuwaie Riyadh 05/11/93 Saudi Arabia The children were not born out of wedlock. The children are presently in the custody of Luay Abdullah Alujwaie and Lisa Marie Alujwaie, parents, who reside in Riyadh, Saudi Arabia. Since birth, the children have resided with the following persons at the following addresses: Name Luay Abdulla.h Aljuwaie and Lisa Marie Aljuwaie Luay Abdullah Aljuwaie and Lisa Marie Aljuwaie Luay Abdullah Aljuwaie and Lisa Marie Aljuwaie The father of the children is L Saudi Arabia. He is married. Addresses Dates 267 Lawrence Dr. 1996-03/06 Harrisburg, PA 17112 365 Dietz Lane 03/06-05/07 Harrisburg, PA 17112 817 Meadow Lane 05/07-07/08 Camp Hill, PA 17011 uay Abdullah Aljuwaie, who resides in Riyadh, The mother of the children is Lisa Marie Aljuwaie, who resides in Riyadh, Saudi Arabia. She is married. 4. The relationship of the Plaintiffs to the children is that of grandparents. The Plaintiffs currently reside with the following persons: Name N/A Relationship 5. The relationship of the Defendant to the children is that of natural parents. The Defendants currently reside with the following persons: Name Relationship Leena Luay Aljuwaie daughter Lamis Luay Alujwaie daughter Lemma Luay Alujwaie daughter Layth Luay Alujwaie son Latif Luay Alujwaie son 6. Plaintiffs have 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. 7. Plaintiffs have no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 8. Plaintiffs do 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. 9. 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 action. 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: Name(s) Address Basis of Claim None 10. The best interest and permanent welfare of the children will be served by granting the relief requested because: A. The Defendants are consenting to allow the children to move back to the United States and live with the Plaintiffs B. The parents and grandparents are working together to make the move easier on the children and facilitate grandparents ability to enroll the children in school and to make medical decisions on behalf of the children if necessary. WHEREFORE, Plaintiffs respectfully request that this Honorable Court grant their Complaint for primary physical custody of the children. Respectfully submitted, Date: U -/0 - 0? Michael I Whare, squire 3 7 East Pomfret Street Carlisle, PA 17013 Supreme Ct. Id No. 89028 Attorney for Plaintiffs SAMUEL A. BOORS & : IN THE COURT OF COMMON PLEAS OF ELAINE M. BOORE, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : Civil Action- Law : No. WAY ABDULLAH ALJUWAIE &: LISA MARIE ALJUWAIE : Defendants : 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 Date: Q Samuel A. Boore, Plaintiff 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: Elaine M. Boo lain.r I;z cm 'S ?` SAMUEL A. BOORE & : IN THE COURT OF COMMON PLEAS OF ELAINE M. BOORS, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : Civil Action- Law : No. LUAY ABDULLAH ALJUWAIE &: LISA MARIE ALJUWAIE : Defendants : IN CUSTODY STIPULATION AND CUSTODY AGREEMENT This Stipulation and Custody Agreement is made this -I A- day of OGToL, r` , 2008 by and between Samuel A. Boore and Elaine M. Boore (Hereinafter referred to as "Grandparents") of 6516 Liptak Drive, Harrisburg, Dauphin County, Pennsylvania, 17112 and Luay Abdullah Aljuwaie and Lisa Marie Aljuwaie(Hereinafter referred to as "Parents") of Riyadh, Saudi Arabia WHEREAS, Parents are the natural parents of the following children: Leen Luay Aljuwaie, date of birth, December 8, 1991, age 16; Lamis Luay Aljuwaie, date of birth, May 11, 1993, age 15; and WHEREAS, Parents and Grandparents have reached an agreement relative to the future care, custody and visitation of the children, the terms of which agreement both parties desire to set forth in the present Stipulation and Custody Agreement, and; WHEREAS, Parents and Grandparents desire the provisions of the present Stipulation and Custody Agreement be approved by the Honorable Court of Common Pleas of Cumberland County and entered as a Court Order, with the same force and effect as though said Order had been entered after Petition, Notice and Hearing. NOW THEREFORE, the parties, intending to be legally bound, and in consideration of the mutual promises and agreements contained herein, hereby agree as follows: 1. Parents, Luay Abdullah Aljuwaie and Lisa Marie Aljuwaie and Grandparents, Samuel A. Boore and Elaine M. Boore shall share legal custody of the Children. Each party shall have an equal right, to be exercised jointly with the other party, to make all non-emergency decisions affecting the Children's general well- being including, but not limited to, all decisions regarding their health and education. 2. Grandparents shall have primary physical custody of the Children. 3. Parents shall have periods of partial physical custody of the Children at such times as mutually agreed upon by the parties. 4. Grandparents agree to voluntary relinquish primary physical custody of the children upon demand by the Parents without further action by the Court. 5. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 6. Both parties agree that the terms of this agreement have been fully explained to them by their respective legal counsel or that both parties have had the opportunity to have legal counsel review and fully explain the terms of this agreement. Grandparents are represented by Michael I Whare, Esquire. 09/27/2008 13:32 717-541-1187 FEDEX KINKQ'S 1230 PAGE 04 7. The parties hereto agree that this agreement shall be recorded and incorporated into an order enforceable by the Court. 8. Consented to: y Sa cl A. Boore C CT M6,? Date with s for Samuel A. B re 1d q 6g Date Elaine M. Boore - ®7 ate ?- itness £or Elaine M. Boore Date LM Abdullab All ie - L, I LIOJ-.? -0-01 L Date Witne or Luay Abdullah Alj ie _? QCT0B??2 2w Date sa Aljuwaie 6 -10.- 200 Date Witness for Lisa NCarie Atjuwaie -ZF SAMUEL A. BOORS & : IN THE COURT OF COMMON PLEAS OF ELAINE M. BOORS, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs : V. : Civil Action- Law No. 4J-& 1 2U dl v, l T4Yrh LUAY ABDULLAH ALJUWAIE &: LISA MARIE ALJUWAIE Defendants : IN CUSTODY ORDER OF COURT AND NOW, this /7' day of pc,h, lv/ , 2008, based upon the Stipulation of the parties, the Court hereby Orders as follows: 1. Parents, Luay Abdullah Aljuwaie and Lisa Marie Aljuwaie and Grandparents, Samuel A. Boore and Elaine M. Boore shall share legal custody of the Children. Each party shall have an equal right, to be exercised jointly with the other party, to make all non-emergency decisions affecting the Children's general well- being including, but not limited to, all decisions regarding their health and education. 2. Grandparents shall have primary physical custody of the Children. 3. Parents shall have periods of partial physical custody of the Children at such times as mutually agreed upon by the parties. 4. Grandparents agree to voluntary relinquish primary physical custody of the children upon demand by the Parents without further action by the Court. cc: Michael J. Whare, Esq. Counsel for Plaintiffs - cv pt es Luay and Lisa Marie Aljuwaie, Pro Se _ Go P7 d /d - r7-0 g- ?OL /O- / 7-OFl VNVA IASINN3d R 11 WV L l 1300001 301-'0--0311 SAMUEL A. BOORE & ELAINE M. BOORE PLAINTIFF V. LUAY ABDULLAH ALJUWAIE & LISA MARIE ALJUWAIE DEFENDANT . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • 2008-6124 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, October 15, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, November 21, 2008 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. 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/ Hubert X. &*o Esq..jjA 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 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 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 ??.Sr dl o.,Y-Dl viNvAWM3d Z h --Zl Wd S 1 130 fill J W'oNrll llll 40 30 ? OCT SQ 7---1 SAMUEL A. BOORE and ELAINE M. BOORE, Plaintiff V. LUAY ABDULLAH ALJUWAIE and LISA MARIE ALJUWAIE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-6124 IN CUSTODY COURT ORDER AND NOW, this day of October, 2008, the Conciliator being advised the parties have filed a Stipulation and a Conciliation is no longer needed, the Conciliator relinquishes jurisdiction. Hubert X. Gilroy, Esquire Custody Conciliator ??:; -?,