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Home My WebLink About05-4842 II CORINNE L. BOYER, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNA. ; NO. Os. '/ 7'0 C...t00 ...,-;_ VS. JEFFREY A. BOYER, Defendant : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY NOTICE 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 served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses 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. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. Cwnberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 II CORINNE L. BOYER, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNA. VS. : NO. JEFFREY A. BOYER, Defendant : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY A VISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion con prontitud. Se Ie avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio 0 anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja 0 compensacion rec1amados por el demandante. Usted puede perder dinero, 0 propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, 17013. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA MEITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEV AR ESTE P AREL A UN ABOGADO DE INMEDIA TO. SI NO TIENE 0 NO PUEDE P AGAR UN ABOGADO, VA Y A 0 LLAME A LA OFICINA INDICADA ABAJO PARA A VERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 II CORINNE L. BOYER, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. ; NO. O~. ~'if''t.2.. ~ lib- VS. JEFFREY A. BOYER, Defendant : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY COMPLAINT UNDER SECTION 330Hc)OF THE DIVORCE CODE COUNT I AND NOW, this $;Of ~05, comes the Plaintiff, Corinne L Boyer, by her attorney, Jane M. Alex er, Esquire, and files this Complaint upon a cause of action of which the following is a statement. I. Plaintiff is Corinne L Boyer, 43 years of age, who currently resides at 28 N. Pine Street, Enola, Borough of Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is Jeffrey A. Boyer, 45 years of age who currently resides at 9 Brandywine Drive, Mechanicsburg, Silver Springs Township, Cumberland County, Pennsylvania 17050. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 9, 1981 in Harrisburg, Pennsylvania by a Minister. 5. There were three (3) children born between the parties during this marriage: Jeffrey A. Boyer, Jr., age 22, who is no longer a minor, Krystopher Charles Boyer, age 16, born June 13, 1989, and Nathan Daniel Boyer, age 13, born November 4, 1991. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The parties have not entered into a written agreement as to alimony, counsel fees, costs and property division. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. II il 9. While the parties were domiciled within the Commonwealth of Pennsylvania, and through no fault of Plaintiff, the innocent and injured spouse, the Defendant, in violation of the marriage vows and the laws of the Commonwealth, has offered such indignities to the person of the Plaintiff as to render her condition intolerable and life burdensome. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNT II 10. The allegations of Paragraph one (1) through nine (9) are incorporated herein by reference and made a part hereof. 11. The marriage is irretrievably broken. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNT III 12. The allegations of Paragraph one (1) through eleven (11) are incorporated herein by reference and made a part hereof. 13. During the marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under Chapter 35 of the Divorce Code. 14. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property of whatsoever kind and whosesoever situate and for such further relief as the Court may deem equitable and just COUNT IV COMPLAINT FOR CUSTODY 15. The Plaintiff seeks joint legal custody and primary physical custody of the two children with supervised custody for purpose of visitation on a scheduled arrangement for the Defendant of the following children, Krystopher Charles Boyer, age 16, born June 13, 1989 and Nathan Daniel Boyer, age 13, born November 4,1991. 16. The children were born during to this marriage. II 17. The children are presently in the custody of the Plaintiff. 18. The children have resided with the Plaintiff and Defendant from 1995 at 28 N. Pine Street, Enola, Cumberland County, Pennsylvania 17025 to the current date. 19. The relationship of the Plaintiff to the children is that of natural mother. 20. The relationship of the Defendant to the children is that of natural father. 2 L The Plaintiff is seeking primary physical custody and joint legal custody of the children with custody for purpose of visitation schedule to the Defendant 22. The Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of these children in this or any other Court 23. The Plaintiff has no information of a custody proceeding concerning the children pending in any other court within this Commonwealth. 24. The Plaintiff knows of no other persons, not a party to these proceedings, who has visitation or custody rights with respect to the children. 25. The best interest and permanent welfare of the children will be served by granting the Plaintiff primary physical custody and joint legal custody of the children with a limited visitation schedule to the Defendant because Plaintiff is able to care for and provide a stable home environment WHEREFORE, the Plaintiff requests your Honorable Court to grant her joint legal custody and primary physical custody of the subject children with reasonable rights of visitation and that the Defendant shall not remove the children from the jurisdiction of the Pennsylvania Courts. 7 II Verification I verify that the statements made in this Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C$. Section 4904 relating to unsworn falsification to authorities. Date: st?/05 COAl~rtO ~. PxUjlA Corinne L. Boyer [J COMMONWEALTH OF PENNSYL VANIA S.S COUNTY OF YORK Before me, the undersigned officer, a Notary Public, in and for the said Commonwealth and County, Personally appeared Corinne L. Boyer, who, being affirmed according to law, deposes and says that the facts and matters set forth in the foregoing Complaint are true and correct to the best of her knowledge, information and belief. Ccu,ffirllo ~ ,(l)WOA Corinne L. Boyer IJ Notarial Seal Leslie K. Neidig, Notary Public Wanington Twp, Yol1< County My Commission Expires Feb. 4, 2007 . Member, Pennsylvania Association Of Notanes r-~ '- '-- ",: UJ "'" '-", 22 ~ \ ~ () '" ~ c = ~ ."-> --:::-<: c.n fT,t. C/) ~;;m F ;-::.:!_- rr1 ......: ,J ~ C'). ~~ ./ o.D !;.:: i": ~ >vI ~~! :p" 3-1~ ... -'---,1 ~I :J:: g~ ~ ~ -- - -{) ~ co <:> .-.~I \)-, a ~ N 55 ~ ~ -< rt ~~ ~ ^ t " CORINNE L. BOYER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 05-4842 CIVIL ACTION LAW JEFFREY A. BOYER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, September 23, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at MDJ Manlove's, 1901 State St, Camp Hill, Pi\-'.?.fl!L on Friday, November.Q.'!,}.flQ~. at 1:00 PM 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 scbeduled hearing. FOR THE COURT, By: /s/ Melissa P. CreeV}', Esq. Custody Conciliator f!ltV 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 HA VE 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 ~ p .~ ~TfIAI /v ~J( 4r6,;l S'o. FC.p .h?' ~ ~&; 5(7'FC'.tf ~~&#' frv % ~~il';:W 5C7Ee./J /jj() 10 :1] Wd 82 d3S ~aoz AbVIONCiHLOdcl 3Hl :10 3JI:!:iO-Djil:J II CORINNE L. BOYER, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. VS. NO. 05-4842 Civil Term JEFFREY A. BOYER, Defendant CIVIL ACTION - LAW IN DIVORCE AND CUSTODY AFFIDAVIT OF SERVICE AND NOW, this $1fA.4ay of , 2005 personally appeared Jane M. Alexander, Esquire who swear ccording to law, that a true and correct copy of a COMPLAINT IN DIVORCE was caused to be served by certified mail with return receipt requested upon the said, Mr. Jeffrey A. Boyer 9 Brandywine Drive Mechanicsburg, P A 17050 on September 20, 2005 by leaving the same at the Dillsburg Post Office with postage pre- paid thereon as evidenced by the mailing receipt and return receipt hereto attached and made a part hereof. Sworn and subscJjPed before me is dl / day of ,2005. . .t~ otary Public t Notarial Seal Leslie K. Neidig. Nota'Y Public Warrington Twp. Yorl< County My Commission Expires Feb. 4, 2007 Member. p,g.'1r:~'m-',"ni" /;I"~ocf:;)tion Of Notanes (') s-;; "" = = c.n (/l rq '""""0 '" 1') CD o -" :tI-n rnp'::. ::88 ;:~~Q ~~f~ ...~ ' ,....,..., -;'::' -- .r;::- 0'. II CORINNE L. BOYER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. VS. NO. 05-4842 Civil Term JEFFREY A. BOYER, Defendant CIVIL ACTION - LAW IN DIVORCE AND CUSTODY PROOF OF SERVICE II II I I 0- ::T ::T .-'l ..II Ul rn ..II U.S. Postal Service", CERTIFIED MAIL RECEIPT (Domestic Mall Only, No Insurance Coverage Provided) Postage $ rn o o o Retum Reclept Fee (Endorsement Required) o Restricled Delivery Fee U1 (Endorsement RequIred) "- o Certified Fee $2.30 U.75 <11 tl- C/) =:l ,- $3.50 0- W 'tJ1'1II!5 ::T ~ .=:~~u.t0::':uo;r.~0.:(.~uoA..uo_~.9J_0::UUOUO_dUUO____'uo '/:":/,.::::; q B n\",::Swlk Dliv'e... CitY.-Si8;.;;ZiP+"~i~s ~'~----uop;;:uol:';-~;;uo------uouo,. $ $8.15 Total Postage & Fees . Complete items 1, 2, and 3. Also complete item 411 Restricted Delivery is desired. . 'Prir.lt your name and address on the reverse 1st we can return the card to you. ; .. ,,;ocn this card to the back of the mail piece, or on the front if space permits. 1. Article Addressed to: C. Signature D Agent o Addressee DYes x D. Me J.e..~r-tl A 'Bo~~ C1 ~b""~ "DrtV~ M~V\lcslo\A.r5t P+. no5'D 3. Service USPS )zk:;ertlfied a 0 Express Mail o Registered D Return Receipt for MerchanQise o Insured Mail 0 C.O.D. . 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number (Copy from service label) 7004 0750 0003 6356 1449 PS Form 3811, July 1999 Domestic Return Receipt 10259S-OO-M-0952 0 N 0 = ~? = -n <J' ..... (/) ff,-n \-n -" r _niT'- N ~'f,C c:> (::~(.L, :::;.'!.~'; -C _.~_-n , ::r: (].O (~S(rt C,~ ::- -'4 -? Y 2 - :Q CJ"> ,,\ Plaintiff DEe 0 ~ L005 cj IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-4842 CIVIL TERM CORINNE L. BOYER, v. CIVIL ACTION - LAW JEFFREY A. BOYER, Defendant IN CUSTODY TEMPORARY ORDER OF COURT AND NOW, this /"" day of December, 2005, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. The Mother, Corinne L. Boyer, shall have primary physical custody of the minor children, which shall be subject to Father's partial custody upon request of the children and by agreement of the parties. BY THE COURT: Ad- J. Dist: AapeM. Alexander. Esquire, 148 S. Baltimore Street. Dillsburg. PA 17019 .Paul J. Esposito. Esquire, P.O. Box 1268. Harrisburg, PA 17108-1268 --.) no;; ;;; .oj I ;.\. :1 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-4842 CIVIL TERM CORINNE L. BOYER, v. CIVIL ACTION - LAW JEFFREY A. BOYER, IN CUSTODY Defendant 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 Krystopher Charles Boyer Nathan Daniel Boyer June 13, 1989 November 4, 1991 Mother Mother 2. A Custody Conciliation Conference was held on December 2, 2005 in response to Mother's filing of a Divorce Complaint with a Count for Custody on September 20, 2005. The Conference had been previously scheduled for November 4, 2005. However, at Father's counsel's request, the date was continued. Present for the Conference were: the Father, Jeffrey A. Boyer, Sr., and his counsel, Paul J. Esposito, Esquire; the Mother, Corinne L. Boyer, and her counsel, Jane M. Alexander, Esquire. 3. attached. The parties reached an agreement in the form of a Temporary Order as () uJuJ Jl~b~ Melissa Peel Greevy, Esquire Custody Conciliator I J-ff (o{ Date clr:264472 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION - LAW CORINNE L. BOYER, Plaintiff No. 2005-4842 Civil Term vs. IN DIVORCE JEFFREY A. BOYER, Defendant PRAECIPE AND POWER OF ATTORNEY FOR SATISFACTION AND/OR TERMINATION TO THE PROTHONOTARY OF SAID COURT: You are hereby authorized, empowered, and directed to enter, as indicated, the following on the records thereof: The within suit is Settled, Discontinued, Ended and costs paid. The within suit is Settled, Discontinued, Ended WITH Prejudice and costs paid. The within suit is Settled, Discontinued, Ended WITHOUT Prejudice and costs paid. Satisfaction of the A ward in the within suit is acknowledged. Satisfaction of Judgment, with interest and costs, in the within matter is acknowledged. X Other: Discontinue the Divorce and the related Divorce Counts from the action filed to the above-referenced term number. Date: fr\rur~ ~O aOOt1 - ) c.(U,~o rR, 'N'tf^- Corinne L. Boyer, pro s COST PAYMENT VERIFICATION I UNDERSTAND THAT THE ABOVE ACTION CANNOT BE FILED AND DOCKETED UNTIL ALL COSTS HAVE BEEN PAID, INCLUDING SHERIFF'S COSTS; AND HEREBY VERIFY THAT ALL COSTS HAVE BEEN PAID. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE IL TIES OF 18P.A.S. SEC. 4904 RELATING TO UNSWORN F ALSIFICA TION TO AUTHORITIES. ~ (A k/.1~ , (\}J,l~ft.Q rR, hW Notary Pu ~c Corinne L. Boyer pro s My Commission Expires: ' Notarial Seal Tracy A. Schoch, Notary Public City of Allentown, Lehigh County My Commission Expires May 24, 'ZOO7 Date: March 20, 2007 J;i~j'~rJ P;'::1f1s:/ i'~rania t.GS.OCialion ci' ~ ,': :~, b'j'ios -<:: f"'..;) = = -..J :li: ;p... :;;0 N \.0 o ." :2 m::W , ..,..,m ~_tj '-...; :::Jh --:;::I... ;.~.~ -T1 ~.~c5 Om ..:;.j ~ -< -0 3 C1? w