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Home My WebLink About06-5447 vs. : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. O(,.5l./41 Civil Term EDWARD AULENBACHER, Plaintiff V ALLERY CLOUSE, Defendant : ACTION IN CUSTODY CUSTODY COMPLAINT 1. Plaintiff is Edward Aulenbacher, who currently resides at 40 Parsonage Street, Newville, Cumberland County, Pennsylvania, 17241. 2. Defendant is Vallery Clouse, who lives at 1104 Chelmsford Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Plaintiff is the fathlr of the following child and seeks a custody order regarding the following child: NAME DOB/AGE ADDRESS Elizabeth Aulenbacher 3/11/95 (11) 1104 Chelmsford Dr. Mechanicsburg, Pa. 17050 Mother and Father married in 1992 and divorced in 1999. During the past five years, the child has resided with the following persons and at the following addresses: NAME ADDRESSES DATES Vallery Clouse 1104 Chelmsford Dr. 2005 - present Mechanicsburg, Pa. 17050 Vallery Clouse 118 Stonehedge Dr. 2004 - 2005 Carlisle, Pa. 17013 Vallery Clouse maternal grandfather 2075 Ritner Highway 2003 Carlisle, Pa. 17013 Vallery Clouse step-father, Roger McKeehan 95 McAllister Church Rd. 2001 - 2003 Carlisle, Pa. 17013 The mother of the child is Vallery Clouse. She resides at 1104 Chelmsford Drive, . Mechanicsburg, Pa. 17050. She is not married. The father of the child is Edward Aulenbacher. He currently resides at 40 Parsonage Street, NewvIlle, Pa., 17241. He is married to Crystal Aulenbacher. 4. The relationship of plaintiff to the child is that of Father. The Plaintiff currently resides with his wife, Crystal Aulenbacher, his child, Joseph E. Aulenbacher (age 4), and step- daughter, Jesse Keim, (age 8). 5. The relationship of defendant to the child is that of Mother. The persons that the Defendant currently resides with are the child. 6. Plaintiffhas not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not knO\V of a party to the proceedings who has physical custody ofthe child or anyone who claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: The parties divorced in March 1999. There is no custody Order regarding the child. Father believes it would be in the best interest ofthe child to have a custody Order with arrangements that promote family cohesiveness. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical cust09Y of the child has been named as parties to this action. WHEREFORE, Plaintiff requests the court to enter a custody order regarding the child. Date: qlIC~ c. Adams, Esquire .n No. 79465 4 ,.'outh Pitt Street 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. S4904 relating to unsworn falsification to authorities. Date: j1 Yo ~ ~~~ ~J 0- ~ ~ """" -.J-- ~.~ ~ .-\ (,-r, -1-:' " ' c:' ~. -~.,. \,.- . EDWARD AULENBACHER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-5447 CIVIL ACTION LAW VALLERY CLOUSE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, September 25,2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, October 12, 2006 , the conciliator, at 9:30 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 accompiished, 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 scheduled hearine:. FOR THE COURT. By: /s/ Hubert X Gilroy, Esq. 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 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 . rI- ~;.t ~ ~ ~ 1l? 5t'(; : -h -? ~ PJpK.., ~. 5"(". P ~ ~ '2. ~ ~.-n; '7c?-5C-~ VIl\Vt\lASNN3d , ._, ....,,..,!Mnr"l i j ~ !f'.r-'-'l ":." i;< -~D-~l '1 'u I\.L!\. f<..Le" ", _ '", 6S :2 ~!d S2 d3S 900Z .,. ..,"',l "n' If ::lHl ~V..." ^tlVl())\v;~.L'vCd... ,;;j 3c.)!:HO..Q31H