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ANTHONY T. M<BETII
^TIORNf.Y AT LAW
~07 NORTH FlIONT SllIEEr
FIRsrROOR
HARJl1SDURO;PA l.llOI
PIlONEI7l1J138.1^B_/l
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ERIC P. KELLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
NO. 98- tjtltl..{' CIVIL TERM
CUSTODY
RACHEL L. BUFFINGTON,
NANCY D. BUFFINGTON,
Defendants
ORDER OF COURT
You, Rachel L. Buffington and Nancy D. Buffington, Defendants,
have been sued in Court to obtain custody, partial custody or
visitation of the child: Alexander James Buffington.
You are ordered to appear in person at
,on at .m.,for
conciliation or mediation confe~~
a pretrial conference.
a hearing before the court.
If you fail to appear as provided by this order, an order for
custody, partial custody or visitation may be entered against you
or the court may issue a warrant for your arrest.
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) 249-3166
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 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. Your must attend the scheduled conference of hearing.
BY THE COURT:
Date:
J.
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 98- 'I'I'I)~ CIVIL TERM
CUSTODY
ERIC P. KELLER,
Plaintiff
RACHEL L. BUFFINGTON,
NANCY D. BUFFINGTON,
Defendants
AND
attached
their
S
QRDER OF COURT
NOW, i)! II , upon consideration of the
Complaint, l.t is hereby directed that the parties and
respective counsel appear before
S , tpe .Conciliator, on the
ayof ~fY\''c-.('>r , 1998, atqCJ..)Q.m., at the location
of ~ at a pre-Hearing Custody
Conference. At uch Conferen ,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.
FOR THE COURT:
By: ~\\ ~.J\. J)l\('(\~
Custody Conference Off c r IT:D. ')
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 scheduled 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
NO~ HAVE A Ll\WYER 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) 249-3166
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.,.'If
She is not married.
The father of the child is Eric P. Keller, currently residing
at 687 South Middlesex Road, Carlisle, PA 17013.
He is not married.
4. The relationship of Plaintiff to the child is that of
father.
The plaintiff currently resides with the following
persons:
Hmn.!il. Relationship
Roger M. and Carol J. Keller Paternal Grandparents
5. The relationship of Defendant Rachel L. Buffington to the
child is that of mother. Defendant Rachel L. Buffington currently
resides with the following persons:
Name
Relationshi~
Nancy D. Buffington
Alexander James Buffington
Tyler Buffington
Mother
Son
Brother
The relationship of Defendant Nancy D. Buffington to the child
is that of maternal grandmother. Defendant Nancy D. Buffington
currently resides with the following persons:
Name
Relationship
Rachel L. Buffington
Alexander James Buffington
Tyler Buffington
Daughter
Grandson
Son
6. Plaintiff has 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.
2
Plaintiff has no information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the child or 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 it is imperative
for the child to be in his Father's custody at predictable, set
intervals so that the child can regularly receive the benefit of
his Father's parenting as the child grows up.
8. Each parent whose parental rights to the child have not
been terminated and the persons who have physical custody of the
child 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 child will be given notice of the
pendency of this action and the right to intervene:
~ Address Basis of Claim
None
3
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ERIC P. KELLER,
Plaintiff
IN THE CCURT OF COMMON PLEAS OF
CUMBERr.AND COUNTY, PENNSYLVANIA
vs.
NO. 98-4445 CIVIL TERM
RACHEL L. BUFFINGroN,
NANCY D. BUFFINGroN,
Defendants
CIVIL ACTION - LAW
CUSTODY
ORDER OF CCURT
J\ND NCkl, this ~.0\ day of ~
considecation of the attached custody Concihatlon Report, it is
directed as follows:
199B, upon
ordered and
1. The Fathec, Eric P. Keller, and the Mother, Rachel L. 8uffington, shall
have shared legal custody of Alexander James Buffington, born June 24, 199B. Each
parent shall have an equal right, to be execcised jointly with the other parent, to
make all major non-emergency decisions affecting the Child's general well-being
including, but not limited to, all decisions regarding his health, education and
religion.
2. The Mother shall have primary physical custody of the Child.
3. The Father shall have physical custody of the Child from 6:00 p.m. until
B:OO p.m. every Monday, Thursday and Saturday beginning september 3, 199B. The
Father's periods of custody shall take place on alternating Mondays beginning on
September 7, 199B at the Mother's residence and on the interim Mondays beginning
September 14, 199B at the Father's residence (Father's gcandparents' home). The
Father's periods of custody with the Child on Thursdays shall always take place at
the Mother's residence and the periods of custody on Saturdays shall always take
place at the Father's residence (Father's gcandparents' home).
4. The Futher shall have a period of custody with the Child for a minimum of
one hour on each of the following holidays, with the specific times to be arranged
by mutual agreement of the perties: Thanksgiving Day, Christmas Day, New Years Day,
Easter, Father's Day, July 4th, and the Father's family reunion on the first
Saturday in August each year.
5. The Mother shall provide all transportation for the Child to and from the
Father's residence.
6. This order is entered pursuant to an agreement of the parties at a custody
conciliation Conference. The parties may modify the provisions of this Order by
mutual consent. In the absence of mutual consent, the terms of this order shall
control.
cc:
J.
Anthony T. McBeth, Esquire - Counsel for Father 1
Lindsay Dare Baird, Esquire - Counsel for Mother and maternal ~ ~ ?_?9
grandmother