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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,
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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),
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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
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