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Home My WebLink About09-0153ROMIIVGER & ASSOCIATES 155 South Hanover Street Carlisle, PA 17013 (717)241-6070 IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA KEITH J. BOYER Plaintiff No. 0 9- O i S"3 ~CCri~ T~.~-- v. Civil Action- Complaint for SHAWNTA M. BOYER Child Custody Defendant COMPLAINT FOR CUSTODY 1. Plaintiff is Keith J. Boyer, (father), an adult individual, sui juris, residing at 1142 Newville Road, Carlisle, Cumberland County, Pennsylvania 17015. 2. Defendant is Shawnta M. Boyer, (biological mother), an adult individual, sui juris, with a current mailing address of 45 West Baltimore Street, Cazlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks custody of the following child: Name Address Mariah L. Boyer 1142 Newville Road 17 y/o (DOB: 2-24-92) Cazlisle, PA 17015 4. The child was born out of wedlock. 5. The child is presently in the primazy physical custody of Plaintiff, Keith J. Boyer (father), 1142 Newville Road, Carlisle, Cumberland County, Pennsylvania 17015. 6. During the last five yeazs the child has resided with the following persons and at the following addresses: Name Keith J. Boyer Brian Boyer Mariah L. Boyer Keith J. Boyer Shawnta M. Boyer Mariah L. Boyer Brian Boyer Breanna Boyer Keith J. Boyer Shawnta M. Boyer Mariah L. Boyer Brian Boyer Breanna Boyer Address 1142 Newville Road Carlisle, PA 17015 45 W. Baltimore Street Carlisle, PA 17013 116 E. North Street Carlisle, PA 17013 Date January 1, 2009 to present June 2006 to December 2008 May 2001 to June 2006 7. The mother of the child is Shawnta Boyer. 8. She is married. 9. The father of the child is Keith J. Boyer 10. He is married. 11. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons: Name Relationship Brian Boyer Mariah L. Boyer Son Daughter 12. The relationship of Defendant to child is that of natural mother. The Defendant currently resides with the following persons: Name Relationship Saundra Clugh Maternal grandmother Breanna Boyer Daughter Art Bender Mother's boyfriend 13. Plaintiff, Keith Boyer, is represented by Lee E. Oesterling, Esquire in regard to this matter. 14. Defendant, Shawnta M. Boyer, is represented by Jane Adams, Esquire, 15. Plaintiff has no information of another custody proceeding concerning the child pending in a Court of this Commonwealth. 16. 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. 15. The best interest and permanent welfare of the child will be served by granting the relief requested because: 18. Plaintiff has been a responsible custodian and caregiver of the child 19. Plaintiff has maintained a relationship with the child that has provided for the child's physical, intellectual, emotional and spiritual well being. 20. Mother's lifestyle is detrimental to the child in that she has brought her new boyfriend who is a convicted felon into the residence on January 1, 2009 without any consideration of the emotional impact that this might have on the children. 21. Since father left the residence on January 1, 2009, the child has expressed a strong desire to live primarily with father and her step-brother. 22. Mother has attempted to impede this relationship by removing the child from school, disrupting her studies, and causing the child Mariah Boyer to be subject to embarrassment and ridicule in the presence of her peers due to Mother's unrestrained misconduct in public. 21. 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 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: Name Address Basis of Claim NONE 22. A copy of this Complaint has been served on Defendant by certified and first class Mail. Mail. WHEREFORE, Plaintiff, Keith J. Boyer, requests the court grant him custody of the child Mariah L. Boyer. Respectfully Submitted, I/ee E. pesterlTht$;'~squi"~ Supreme Court ID # 71320 155 South Hanover Street Carlisle, PA 17013 (717)241-6070 Attorney for Plaintiff VERIFICATION I verify that upon personal knowledge or information and belief 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. Plaintiff Date: ROMINGER & ASSOCIATES 155 South Hanover Street Cazlisle, PA 17013 (717)241-6070 IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA KEITH J. BOYER Plaintiff No. v. SHAWNTA M. BOYER Defendant Civil Action- Complaint for Child Custody CERTIFICATE OF SERVICE BY CERTIFIED AND FIRST CLASS MAIL Lee E. Oesterling, Esquire, attorney for Plaintiff in the above-captioned Divorce, deposes and says that he mailed a copy of the Custody Complaint and Order to Attend Custody Conference filed in this matter by certified mail, restricted delivery, and first class mail to the Defendant, 45 West Baltimore Street, Carlisle, PA 17013 on / - ~'~ , 200,8'• 9 Lee E. Oe3terl~xg; Esquire 155 South Hanover Street Carlisle, PA 17013 (717)241-6070 Attorney for Plaintiff . ~ ... ~ ~ ~ -~- ~ ~.. ~ d .r^. ~ ., -o ~' . ~ a ~~ .: -~, a .r~ ~.~' ~- ~ ~ ~ IN THE COURT OF COMMON PLEAS OF THE 9~ JUDICIAL DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA KETI'H J. BOYER Plaintiff No. Oq- D /53 C.t.U~.C.Y rt,~n...~ v. Civil Action- Complaint for SHAWNTA M. BOYER Child Custody Defendant EMERGENCY PETITION FOR SPECIAL RELIEF AND NOW, comes Keith J. Boyer, by and through his counsel Lee E. Oesterling, Esquire, and in support of her Emergency Petition for Special Relief, avers as follows: 1. Petitioner is Keith 7. Boyer, who resides at 1142 Newville Road, Carlisle, Cumberland County, Pennsylvania 17015. 2. Respondent is Shawnta M. Boyer who resides at 45 West Baltimore Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. Petitioner and Respondent have one (1) minor child together. 4, Petitioner is the primary care giver of Mariah L. Boyer, born February 24, 1992. 5. Respondent has removed the child from school on at least two (2) occasions with no sufficient reason. 6. Respondent has moved her boyfriend into the household who is a known convicted criminal. 7. Petitioner believes that since the child has been removed from school that this is detrimental to the child's education and being that the child is a junior in high school that it also has a detrimental affect on her social life. 8. Petitioner has filed a Complaint for Custody simultaneously with this Emergency Petition. WHEREFORE, Petitioner respectfully requests relief as follows: a. that an injunction be issued preliminarily, until a hearing, and finally thereafter, giving primary physical custody of the minor child to Petitioner; b. such other relief as your Honorable Court may deem appropriate; and c. award attorney's fees, costs and expenses. Date: January 12, 2009 Respectfully Submitted, Rominger & Associates Lee E. Oes11rr1i~Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID # 71320 Attorney for Petitioner IN THE COURT OF COMMON PLEAS OF THE 9~ JUDICIAL DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA KEITH J. BOYER Plaintiff v. SHAWNTA M. BOYER Defendant No. Civil Action- Complaint for Child Custody CERTIFICATE OF SERVICE I, Lee E. Oesterling, Esquire, certify that I this day served a copy of the within Emergency Petition for Special Relief upon the following by depositing the same in the United States Mail postage pre-paid, first class, at Carlisle, Pennsylvania, addressed as follows: Shawnta M. Boyer 45 West Baltimore Street Carlisle, Pennsylvania 17013 Respectfully Submitted, Rominger & A s~ociate Date: January 12, 2009 Lee E. Oester~g~E'squire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID # 71320 Attorney for Petitioner '~-' C7 ~' 0 ~ `° •~ .~ ~° ~ ~ rn ~ a a . `n ~-~-; .. K ~~ " •~ ~' l ~ ~ ~ S f~ A Y