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HomeMy WebLinkAbout98-01915 ~ t a ~, ~ 'lo. ~ ~ q ~ u J , , .I I I I f /tl J/" ~ ~ " ..... .. . ') .. :'\h t~.j"<t-'i.'" ~I"'''' ''9. '1""'" , ,\....:,'...!- U ., "''" ~p"..,." ;~ .,-1 I,,"' " ."\'ft::'f.ti ,', \ t'~. " "',}.: ^".);: , , ., 'of". 'I' ',', . l~' I ~\ ';; ,'":' tl \', , \ ~ ",' :;" " ~ot ';,~. '" , ~. " 'f ''''- , i \1f4. '1*' (f, \ .,~ tI t''- '.. I.. ....... '.,.-' \ j , ' \ , I I ~, \ ~. i' I! .~. , " ..."",ll' " '" " ,,',l;~., ~ MICHAEL BUCHENAUER, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA , ; NO. 98- I'll ,>' CIVIL TERM , JENNIFER SCHWALM, Defendant , , : CIVIL ACTION - IN CUSTODY ORDI;R Of COURT AND NOW, this & day of April, 199B, upon consideration of the attached Complaint, It Is hereby directed that the parties and their respective counsel appear before ,\:O\tJ'\-S ,\.f,{~, the conciliator, at 3C1 \j, H()\L\.-S-t.) \'\:rLU\tl..A(~)eA on the -126. day of May, 1998, at \ \ " (10 ,I.;;.M, 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, FOR THE COURT, ~ ~ By: "~ Ul \ ){\ ~ . "^ .:- Custody Conciliator ~\))") 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 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 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3168 , MIOHAEL BUOHENAUER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, , . : NO, 98- / r; I ~' CIVIL TERM JENNIFER SCHWALM, Defendant , , : CIVIL ACTION - IN CUSTODY COMPLAINT FOR CUSTODY 1, Plaintiff Is Michael Buchenauer, an adult Individual whose residence Is at 251 Pine HIli Road, Carlisle, Cumberland County, Pennsylvania. 2, Defendant Is Jennifer Schwalm, an adult Individual whose resldenoe Is at 1185 Bower Road, Shermans Dale, Perry County, Pennsylvania. 3, Plaintiff seeks custody of his ohlld, Tyler Michael Buchenauer, whose date of birth Is February 2, 1996. 4, The child Is presently in the oustody of Plaintiff and Defendant. 5, Since the child's birth, the child has resided with the Plaintiff and the Defendant at 251 Pine HIli Road, Carlisle, Cumberland County, Pennsylvania, until the Defendant unilaterally left with the ohlld on February 27, 1998 to resldo 111 Perry County with the child on a part-time basis, 6, The natural mother of the child Is the Defendant, Jennifer Schwalm. 7. The natural father of the child Is the Plaintiff, Mlohael Buohenauer. 8. The Plaintiff has not participated as a party or In any other capacity, in other litigation concerning the custody of the child In this or any other oourt. 9. Plaintiff has no information of a oustody proceeding conoernlng the child pending In a court of this Commonwealth, () -1 o :J' .. "J ,-'~ ') '1 .s r: F) , "1 5 I." ~ \'<') ,. t', (>. \P ,:;. "'~ ~~ (~ ~ l:::: j~~ l,JJ( (J. a=!-, Ci!: J'( [U: f."/ . J: ~' r~" 'I (j '(\J (,1\ C:'J /:',:' (\) ';" iT r"~ I (.. ~:~~ "'- . MICHAEL DlICIIENAlIER. Rcsllondcnt : IN THE COURT OF COMMON I)U~AS ()/<' : CUMBERLAND CotINTY. PENNSYLVANIA v. CIVIL ACTION - LAW .IENNIIIER SCIIW ALM, Pctltlonl1f 9H-1915 CIVIL n:RM IN CllSTODY PETI'rION FOR SPECIAL RELIEF AND NOW, comes the Petitioner, Jennifer Schwahn. by and through hcr attorneys, Irwin, McKnight & Hughes. and tiles this Petition for Special Relief making the tllllowing statement: I. The Petitioner is Jenni fer Schwalm, an udull individual rcsiding at 1185 Bower Road, Shennans Dale. Perry County. Pennsylvania, 2, Thc Respondent is Mh:hael Buchcnauel', an adult individual residing at 251 Pine Hill Road. Carlisle, Cumberland County, Pennsylvania, 3, The parties arc thc natural parents of Tyler Michael Buehenauer, horn Febnwty 2, 1996; the child was bol'l1 out of wedlock, 4, The parties were residing together through February 27, 1998, when the Petitioner moved out of the home where the parties werc ""siding with their minor child and the Petitioner's minor child from a previous rclationship (Christophel' Alun SeW: born June 13, 1986), \.~\\\I\tC RO\\ 1: \IN , "' . \ S\tCC\ ,~'2>0\1\'\\ ~C\\~ot\,,\\\\\"1 \W\, \' \C \' C\\\\~'i ,\'C\\\ C\\t l'!o ' \,\\C RC~\'O\\' ' ~\\OI'\\C'i ~,)t, U\lc,\\C\\\\\\ct w.\c\\\\O,v -, ',/ /....--'...,_.,- , " p ~~ .' ., ,,\\\tC . ,,~ \l t\.t"'C\\\' ",\... ~ '. \l~ \ ~ . \ : yc\\\\O\\ct t\.\\ot\\C'i 0 ~Ct"Cl\ 1\ \t\IO 1\\\'\ C\)ttCC\ '~ \\\\\\ \ \\\I~C . . 1 \\ \1\ \ \ -tC\''i cct\1 " \ -\\\ '0'1 \,\\lCI\\\!. \" \\\tc. C ,) ~c " . RC~\'o\\C c "" "",," .'" . .",."" ,,,,,, . ", ,I< \ \)\\\\\0\ \}J. '..\\\.c\\c\ \\'(1,)1\ c ~\"\I\\\\\ \10\'?> \\\' . ' " t s,,,oCI~ '\ \,c\\\\~,' \ ,\,C\\\\\)I\ ,0 .." ' \ \\\ C\\t\\~ C. "",,~ o~ \\\C ~otc\bo \\\!. . .\.."~ "o~\I\\bc \'tc\,\I\C .....,' I '\ \\t~\ \) ~". ,. w.\I\' . . \\\0 \\\\\\c\\ S\\\\C~ ~o\\o\'l\\\\b" . st\\~ , 1'\\,\C~{~'~~ ct~;--o.-"~ ;;.- ~"t\\ '].~, \\)\)% \l~\C\ r>t" MICHAEL BUCHENAUER, Plaintiff vs. I IN THE COURT OF COMMON PLEAS OF I CUMBFoRLAND COUNTY, PE.'NNSYf, VANIA I l NO. 98-.1915 CIVIL TERM JENNIFER SCHWALM, Defendant CIVIL ACTION - f,AW CUSTODY OODER OF COORT AND I<<M, this ~ day of consideration of the at.Custody Con 1 at and diret1ted as follows: , 1998, upon Report;'1t is ordered 1. The Father, Michael Buchenauer, and the Mother, Jennifer Schwalm, shall have shared legal custody of 'l'yler Michael Buchenauer, born February 2, 1996. Each parent shall have an equal right, to be eX<lrcised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being inclUding, but 1I0t limited to, all dec.!sions regarding his health, education and religion. 2. The parties shall share having physical custody of the Child in accordance with the following schedule: During every week, the Father shall have custody of the Child from Monday through Wednesday, when the Father shall transport the Child to the babysitter before wot'k and the Mother shall have custody of the Child from Wednesday after work, when the Mother shall pick up the Child from the babysitter through Friday when the Mother shall return the Child to the babysitter before work. The ~'rties shall alternate having custody of the Child on weekends, beginning with the Father having custody of the Child af.ter work on Friday, May 29, 1998. 3. Each party shall be enUtled to have custody of the Child for three (3) uninterrupted non-consecutive weeks during each summer upon providing thirty (30) days advance notice to the other party. 4. The parties shall share or alternate having custody of the Child on holidays as follows: A. Chl'istmas: In eve~l' year, the Mother shall have custody of the Child on Christmas Eve from 10:00 s.m. until 9:00 p.m. and the Father shall have custody of the Child every year fr.om Christmas Eve at 9:00 p.m. until Christmas Day at 9:00 p.m. B. Alternating Holidays: In even numbered years, the Mother shall have custody of the Child from 9:00 a.m. until 8:00 p.m. on Easter, July 4th and Thanksgiving, and the Father shall have custody of the Child from 9:00 a.m. until 8:00 p.m. on Memorial Day, Labor Day and the Friday after Thanksgiving. In odd numbered r:! .,,' . ';';-";'1' ~~):) J~'J.."I r ': '::" t ,. , i; ; Ii' ! 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