HomeMy WebLinkAbout09-7860
MELISSA K. BOYER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. O q- q g4-° Civil Term
ALAN E. BOUDER, JR. IN CUSTODY
Defendant
1. Plaintiff is Melissa K. Boyers, who currently resides at 7 East Orange Street,
Mount Holly Springs, Cumberland County, Pennsylvania, 17965.
2. Defendant is Alan E. Bouder, Jr., who currently resides at 31 Prospect Road,
Carlisle, Cumberland County, Pennsylvania, 17013.
3. Plaintiff is the Mother of the following children and seeks a custody order
regarding the following children:
NAME DOB/AGE ADDRESS
Zaden Bouder 2/8/07 7 East Orange St.
Mount Holly Springs, Pa. 17965
Bella Bouder 8/5/09 7 East Orange St.
Mount Holly Springs, Pa. 17965
Mother and Father were never married. The parties currently share physical
custody of the children.
CUSTODY COMPLAINT
During the past five years, the children have resided with the following persons
and at the following addresses:
NAME
ADDRESSES
DATES
Melissa Boyer
Melissa Boyer
Alan E. Bouder, Jr
7 East Orange St.
Mount Holly Springs, Pa.
31 Prospect Road
Carlisle, Pa. 17013
June 2009 - present
birth - June 2009
The mother of the chidren is Melissa Boyer. She currently resides at 7 East
Orange Street, Mount Holly Springs, Pa. 17965. She is not married.
The father of the child is Alan E. Bouder, Jr. He currently resides at 31 Prospect
Road, Carlisle, Pa. 17013. He is not married.
4. The relationship of plaintiff to the child is that of Mother. The plaintiff currently
resides with the children.
5. The relationship of defendant to the child is that of Father. The defendant
currently lives alone and has periods of partial custody with the children.
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 or any other state.
Plaintiff 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: The parties recently separated in June 2009.
Mother is seeking a custody order which provides for shared legal custody and confirms
that she will retain physical custody of the children on the days that she is off work.
8. Each parent whose parental rights to the children have not been terminated
and the person who has physical custody of the children has been named as parties to
this action.
4.
WHEREFORE, Plaintiff requests the court to enter a custody order regarding the
children.
Date:
//0
Respectfully submitted,
6 Adams, Es#ire
No. 79465
A7 W. South St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
VERIFICATION
I verify that the statements made in this Custody 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.
oar / / 'ia?6y
(Vw
Melissa K. Boyer, Plaintiff
F (i ED'!'i"L
17 Y
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2009 NOV 12 F ii 2: 13
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$16-5.66
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Rec?t? a 33'? 0 3
MELISSA K. BOYER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
2009-7860 CIVIL ACTION LAW
ALAN E. BOUDER, JR
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Tuesday, November 17, 2009 , 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 Monday, December 21, 2009 _ at 10:00 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ john . Mangan, r. Es q. -
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
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