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HomeMy WebLinkAbout99-04528 A `)V ,u ?M ill' _ JUL . d) DONALD L. BUCHER, JR., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99 - q!5 I P Ce-La Tc--• LORI J. BUCHER, CIVIL ACTION - LAW Defendant CUSTODY ORDER OF COURT AND NOW, this day of 1999, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before _ M\Chne? l Y1c ? l the Conciliator, at on the '-t day of acApp mhP r- , 1999, at a: o O t .m. for a Pre-Hearing Custody Conference. At such Conference, an effortwill be made td 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 at the request of either attorney or party, be present at the conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order FOR THE COURT, By: n 16 Custody Conciliator l Tai 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 Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 iii a•:;i.;. PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West Louther Street Carlisle, PA 17013 (717)249-2721 Attorney for Plaintiff DONALD L. BUCHER, JR., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99 - 45 2F 12611 -51 LORI J. BUCHER, CIVIL ACTION - LAW Defendant CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, DONALD L. BUCHER, JR., by and through his attorney, Peter J. Russo, Esquire, and respectfully submits the following in support of Plaintiffs Complaint for Custody: 1. The Plaintiff is DONALD L. BUCHER, JR., residing at 349 Huntington Ave, Enola, Pennsylvania 17025. 2. The Defendant is LORI J. BUCHER. residing at 347 Huntington Ave, Enola, Pennsylvania 17025. 3. Plaintiff seeks custody of the following children: Name Present Residence DOB Thomas Joseph Bucher Huntington Ave, Enola, 8/10190 Steven Kyle Bucher Huntington Ave, Enola, 5/24192 Megan Marie Bucher Huntington Ave, Enola, 8/11/93 Lacey Janelle Bucher Huntington Ave, Enola, 515/96 4. Thomas Joseph Bucher, Megan Marie Bucher, Lacey Janelle Bucher, and Steven Kyle Bucher were not bom out of wedlock. 5. The children are presently in the shared custody of both parties, who resides at Huntington Ave, Enola, Pennsylvania 17025. 6. During the past five years, the children have resided with the following persons and at the following addresses: Persons Address Duration Both Parties 349 Huntington Ave Last five years Enola, PA 7. The mother of the children is Defendant, currently residing at 347 Huntington Ave, Enola, Pennsylvania 17025. The mother is married. 8. The father of the children is Plaintiff, currently residing at 349 Huntington Ave, Enola, Pennsylvania 17025. The father is married. 9. The relationship of plaintiff to the children is that of father. The plaintiff currently resides with the following persons: Name Relationship N/A 10. The relationship of defendant to the children is that of mother. The defendant currently resides with the following persons: Name Relationship David Boyer Father Walter Boyer Brother Carol Boyer Mother 11. 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. 12. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. 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 right with respect to the child. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff has maintained the role of primary caretaker and can provide a continuing loving and caring environment. 15. Each parent whose parental rights to the child have not been terminated and the person who has 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: Name Address Basis of Claim None WHEREFORE, Plaintiff requests this Honorable Court to order that primary physical and legal custody of the minor children, Thomas Joseph Bucher, Megan Marie Bucher, Lacey Janelle Bucher, and Steven Kyle Bucher be placed with Plaintiff. es Ily ubmitt d, Peter J. Russo Attorney for Plaintiff Date: 7 I,-1I " I, DONALD L. BUCHER, JR., verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: 7 ` o? °( ASP Pt T nJ w t ;• ?? l?? CJ J 'n 0 J M M h 14 DONALD L. BUCHER, JR., ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, 1 PENNSYLVANIA VS. ) 1 NO. 99-4526 CIVIL TERM LORI J. BUCHER, 1 Defendant ) CIVIL ACTION - LAW CUSTODYNISITATION ORDE AND NOW, this ls,4\ day of 6 1999, upon review of the Conciliator's Report, it appearing that the parties have agreed to the terms and provisions of this interim order which was dictated in their presence and approved by them and their counsel, it is hereby ordered and directed as follows: 1. The parties shall share legal. custody of the minor children, Thomas J. Bucher, d.o.b. August 10, 1990; Steven K. Bucher, d.o.b. May 24, 1992; Megan M. Bucher, d.o.b. August 11, 1993; and Lacey J. Bucher, d.o.b. May 5, 1996. 2. Father shall have custody of the children on alternating weekends from Friday after school until Sunday at 5:00 p.m. This alternating weekend schedule shall commence on Friday, September 10, 1999. 3. On the other alternating weekends, Mother shall have custody of the children through that weekend. 9. On all school nights, Mother shall have custody of the children overnight so that they sleep at the Mother's residence. 5. The parties shall work towards sharing the remainder of the time with the children during the week. This provision is intended to mean that the parties shall share the time when the children are either not at school or off from school until their bedtime. The parties will work towards an appropriate arrangement that fits with their schedules and with the children's schedule. 6. In the event that the parties are unable to reach an agreement concerning the sharing of the time as indicated above, either party's counsel may contact the conciliator for an expedited conciliation for the sole purpose of arranging this type of visitation. 7. The parties shall reconvene for another custody conciliation conference before Michael L. Bangs, Esquire, on Thursday 9:00 a.m. January 13 2000, at BY THE COURT, 10 Peter J. Russo, Esquire Attorney for Plaintiff Mark D. Schwartz, Esquire Attorney for Defendant ? ry.?ckQ.wE,/0?l8/9y. mlb i;: ?? ? ? . ';Y GC:?i I t ;"l?? i;? %l ?. ??...', )?.el i DONALD L. BUCHER, JR., ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA VS. ) NO. 99-4528 CIVIL TERM LORI J. BUCHER, ) Defendant ) CIVIL ACTION - LAW CUSTODY/VISITATION JUDGE PREVIOUSLY ASSIGNED: None. CUSTODY CONCILIATION COMRM E Q*K4s4V REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the children who are the subject of this litigation is as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY O Thomas J. Bucher August 10, 1990 Steven K. Bucher May 24, 1992 Megan M. Bucher August 11, 1993 Lacey J. Bucher May 5, 1996 2. A Conciliation Conference was held on September 9, 1999, and the following individuals were present: the Plaintiff and his attorney, Peter J. Russo, Esquire; the Defendant appeared with her attorney, Mark D. Schwartz, Esquire. 3. Items resolved by agreement: See attached Order. s 4. Issues yet to be resolved: See attached Order. 5. The Plaintiff's position on custody is as follows: See attached Order. 6. The Defendant's position on custody is as follows: See attached Order. 7. Need for separate counsel to represent children: Neither party requested. 8. Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe any is necessary. Date: October 4, 1999 , ) Michhel L. Custody Conciliat r u - 3 y /? W ? p A wc5? ? - M ?Z V JAN 12 200i? DONALD L. BUCHER, JR., ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. ) LORI J. BUCHER, ) NO. 99-4528 CIVIL TERM Defendant ) CIVIL ACTION - CUSTODY ORDER AND NOW this /)k day of 2000, it being reported to the Conciliator that the parties are continuing to work under the current existing order, the undersigned Conciliator hereby relinquishes jurisdiction and returns the matter to the Court Administrator. If either of the parties wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, MICHAEL L. BAN Custody Conciliator cc: Peter J. Russo, Esquire Mark D. Schwartz, Esquire .? i;UUNtY PENNSY %M. !A