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Home My WebLink About10-2845T WALKER, CONNOR & SPANG, LLC 247 Lincoln Way East Chambersburg, PA 17201 (717) 262-2185 (717) 262-2187-Fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Angela L. Boardman, ) Civil Action - Law Plaintiff, ) 10 _ x845 (INI I Tf''r m N VS. No. of 2010 C Edward A. Boardman, ) Judge Defendant, ) Custody - r» 3 , , z;w CI ' _j z, NOTICE co -43 kD -< YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are serve, by entering a written appearance personally or by attorney and filing in writing with the Court your defense or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about assessable facilities and reasonable accommodations available to disable 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. CUMBERLAND COUNTY BAR ASSOICATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 $17q . oo p 1) ATr? Ce a54o?a9?13 WALKER, CONNOR & SPANG, LLC 247 Lincoln Way East Chambersburg, PA 17201 (717) 262-2185 (717) 262-2187-Fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Angela L. Boardman, Plaintiff, VS. Edward A. Boardman, Defendant, Civil Action - Law No. of 2010 Judge Custody COMPLAINT FOR CUSTODY 1. The Plaintiff is Angela L. Boardman, (natural Mother), residing at 306 Cranes Gap Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Edward A. Boardman, (natural Father), residing at 108 Mainsville Road, Shippensburg, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks custody of the following children: Name Address Britton Robert Boardman 306 Cranes Gap Road Carlisle, PA 17013 Kylee June Boardman 306 Cranes Gap Road Carlisle, PA 17013 The children were born in wedlock. Age 5 02/06/2005 3 09/24/2006 The children are presently in the custody of Angela L. Boardman (Mother), currently residing at 306 Cranes Gap Road, Carlisle, Cumberland County, Pennsylvania, 17013. 4. During the past five years, the children have resided with the following persons and at the following addresses: Name Address Date Mother and Father 108 Mainsville Road birth - Shippensburg, PA 17251 June 2008 Mother and Father 306 Cranes Gap Road June 2008 Carlisle, PA 17013 January 14, 2009 Mother 306 Cranes Gap Road January 19, 2009 Carlisle, PA 17013 present 5. The mother of the children is Angela L. Boardman of 306 Cranes Gap Road, Carlisle, Cumberland County, Pennsylvania 17013. She is married. 6. The father of the children is Edward A. Boardman of 108 Mainsville Road, Shippensburg, Cumberland County, Pennsylvania 17257. He is married. 7. The relationship of Plaintiff to the children is that of natural Mother. The Plaintiff currently resides with the following persons: Name Relationship Britton Robert Boardman son Kylee June Boardman daughter 8. The relationship of Defendant to the children is that of natural Father. The Defendant currently resides with the following persons: Name Relationship None 9. Plaintiff, Angela L. Boardman is represented by Martha B. Walker, Esquire with regard to this matter. 10. Defendant, Edward A. Boardman, is represented by Kelly Knight, Esquire with regard to this matter. 11. 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 any other court. 12. Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth. 13. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 14. The best interests and permanent welfare of the children will be served by granting the relief requested because Plaintiff is able and willing to provide for the children's needs at this point in time and specifically: a. Mother has been the primary caretaker for the children. b. Mother remains in the marital home where the children are more comfortable. c. Mother's schedule permits her to be more available to meet the children's needs. 15. 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: NONE 16. Plaintiff requests that the following Temporary Order be entered: A. Mother and Father shall share legal custody of the children. B. Mother shall have primary physical custody of the children. C. Father shall have periods of partial custody of the children as follows: i. Father shall have partial custody of the children every Wednesday from 5:00 p.m. until Thursday morning at 8:30 a.m., when he return the children to Mother's residence. ii. Father shall have partial custody of the children every Saturday evening from 7:00 p.m. until Sunday at 7:00 p.m. 17. A true and attested copy of this Complaint has been sent to Defendant's counsel by first-class U.S. mail. WHEREFORE, Plaintiff requests this Honorable Court to grant her primary residential custody of the children. Respectively submitted; WALKER, CONNOR & SPANG, LLC ?J BY. GG B. Walker,'Es y for Plaintiff v I.D. # 15989 247 Lincoln Way East Chambersburg, PA 17201 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. Section 4904 relating to unworn falsification to authorities. Date: `1 121IO AAnge L. an, Plaintiff WALKER, CONNOR & SPANG, LLC 247Lincoln Way East Chambersburg PA 17201 (717) 262-2185 (717) 262-2187 -Fax MAY 12 2010 I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Angela L. Boardman, ) Civil Action -Law vs. Edward A. Boardman, Plaintiff, ) Defendant, ) No. 10 -2845 Judge _ Custody /y ORDER OF COURT AND, NOW, this ~ day of ~ , 2010, upon consideration of the within Motion, IT IS HEREBY ORDERED THAT, the Custody Complaint filed by Plaintiff, which is docketed to 10-2845, shall be consolidated to and be heard as part of the Custody Complaint filed by Defendant, which is docketed to 10-2843, and is currently scheduled for aPre-Hearing Custody Conciliation on June 16, 2010. J. N d . C ~~ Ss. ~.. :. ,1.. , -- ~ ,~ r~~~-; w x ~ :~ ~.~ r'> y4~, ~ ~']--~ ~- ~~ ~~ C..~ f ~;Tt