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Home My WebLink About99-05347d t S i O 0 { r Ti r a Q I11 U. lil ? J N J \ v \V t ? e U a d ? a < ( 7 3 ^N U <E ¢v VAS > '? 4 .-. w vu fp X a¢vos a li p a 3 SEP ?yys BRENDA C. MOORE and HAROLD E. MOORE IN THE. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. JOYCE A. BUCHER and SHAWN M. BUCHER No. qy - ! J4 ^/ C? Defendant CIVIL ACTION -- LAW ORDER OF COURT AND NOW, 911 14a upon consideration of the attached complaint, it is hgfeby irected that the parties and their respective counsel appear bef re J, the conciliator, at3 %0'466Q byi t __?_day of e-9d, at !?q p.m., fora 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. 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: .I Custody Conciliator t ?> 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 LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 Cc- LL' /'L `4. rLw ?l??` g. gy h,u lid 4 4 BRENDA C. MOORE and HAROLD E. MOORE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. No. 9`). 6-377 ('b?iJ 7,e4- JOYCE A. BUCHER and SHAWN M. BUCHER Defendant I CIVIL ACTION - LAW PETITION FOR CUSTODY AND COMES NOW, BRENDA C. MOORE and HAROLD E. MOORE, by their attorney, Timothy J. Colgan, Esq., and files the following Petition: 1. Petitioners, BRENDA C. MOORE and HAROLD E. MOORE, resides at 1716 Orrs Bridge Road, Enola, Cumberland County, Pennsylvania 17025. 2. Respondent Joyce Ann Bucher's last know address was 1716 Orrs Bridge Road, Enola, Cumberland County, Pennsylvania 17025.. 3. Respondent Shawn M. Bucher resides at 169 Enola Road, Enola, Cumberland County, Pennsylvania 17025. 4. Respondents are the natural parents of the minor child, Jacqueline L. Bucher, bom 11/30/98. 5. The Petitioners are the matemal grandparents of the minor child. 6. The Petitioners have been in care and custody of the minor child since January 26, 1999 when Respondent Joyce A. Bucher abandoned the child. 7. The child is in need of medical attention for a suspected ear infection. ?1. 9. There are no court orders establishing custody or visitation. 10. No other person or persons aside from the parties hereto asserts a right of custody or visitation with respect to the minor child. WHEREFORE, Petitioner prays that the Court enter an Order granting them primary physical and legal custody of the minor children. Dated: 8- nrT? I South Baltimore Street Dillsburg, PA 17019 (717) 432-9666 l.D. #77944 Respectfully submitted, Timothy J. CNitl5n, C"quire WILEY, LENOX & COLGAN, P.C. VERIFICATION 1, BRENDA C. MOORE and HAROLD E. MOORE, verify that the statements made in this document are true and correct to the best of my knowledge, information, and belief. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: $ 1-I -!?.q D BRENDA C. MOORE Petitioner Date: 7 - 99 %f? 'gooe E yr! HAROLD E. MOORE Petitioner c r .- i V. -` m U a z v y a ? O 3 .? a voa U <E;N Q y.=C 7 ?d Z m M? x Co a¢v'or a ni p 3 BRENDA C. MOORE and HAROLD E. MOORE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. No. 99-5347 CIVIL JOYCE A. BUCHER and SHAWN M. BUCHER Defendant CIVIL ACTION -- LAW ORDER ADOPTIN STIPULATION OF pARTIFS AND NOW, to wit, this l??day of D t? _ 1999, upon consideration of the foregoing Stipulation and on motion of Timothy J. Colgan, Esquire, counsel for Plaintiffs, BRENDA C. MOORE and HAROLD E. MOORE, and Defendants, JOYCE A. BUCHER and SHAWN M. BUCHER, pro se, it is hereby ordered, adjudged and decreed that the terms, conditions and provisions of the foregoing Stipulation dated q1 JD 1'Fti are adopted as an Order of Court as if set forth herein at length. BY THE COURT, 6' R?K +• i i 1 ?i?i_.' '1'11 BRENDA C. MOORE and HAROLD E. MOORE Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 99-5347 CIVIL JOYCE A. BUCHER and SHAWN M. BUCHER Defendant CIVIL ACTION -- LAW ACKNOWLEDGMENT OF PARTIES TO ENTRY OF STIPULATION AS ORDER OF COURT AND NOW, to wit, this day of SD D.Qx„ 1999, the parties in the above-referenced action do hereby agree that the attached Stipulation shall be entered as an Order of Court. Brenda C. Moore Harold E. Moore Jo?ce,A. uchu? Shawn M. Bucher BRENDA C. MOORE and HAROLD E. MOORE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. No. 99-5347 CIVIL JOYCE A. BUCHER and SHAWN M. BUCHER Defendant CIVIL ACTION - LAW THIS AGREEMENT is made this atNay of 1999 by and between BRENDA C. MOORE and HAROLD E. MOORE, (hereinafter referred to as "Plaintiffs") and JOYCE A. BUCHER and SHAWN M. BUCHER, (hereinafter referred to as "Defendants"). WITNE TH WHEREAS, Defendants are the natural parents of one child, Jacqueline L. Bucher, born 11/30/98. WHEREAS, as the Defendants are unable to adequately provide the proper care, supervision, medical treatment, and necessaries to the minor child at the present time; WHEREAS, the Plaintiffs, as maternal grandparents of the minor child, are able to provide the proper care, supervision, medical treatment, and necessaries to the minor child; WHEREAS, the parties wish to specify the respective rights and obligations of each with respect to the custody of the minor child; NOW THEREFORE, the parties intending to be legally bound, do agree as follows: A. Ltgal . tod The parties agree to share legal custody as that term is defined in the Custody Act 1985, October 30, P.L. 264, No. 66, Section 1, 23 Pa.C.S.A. 5301 rd =q, B. Primary Phvsic_ a^ I Custody. Primary physical custody of the minor child, as that term is defined in the Custody Act 1985, October 30, P.L. 264, No 66, Section 1, 23 Pa.C.S.A. 5301 rd 8gq., is confirmed in the Plaintiffs. The Defendants shall enjoy periods of partial physical custody as the parties shall mutually agree. 3. Holidays shall be divided between the parties as the parties shall mutually agree. 4. Transportation for all periods of partial physical custody shall be provided by Defendants provided they have adequate means to transport the child safely, including but not limited to an approved child car safety seat. IN WITNESS WHEREOF, the parties hereto, after full disclosure, intending to be legally bound, have signed, sealed and acknowledged this Stipulation. Brenda C. Moore Harold E. Moore Jo$be A-.?Bucher Shawn M. Bucher COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF On this, the -80 day of 1999, bet-ore me, the undersigned officer, personally appeared BRENDA C. MOORE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, 1 have hereunto set my hand and official seal. EAL) NOTARY(PUBLIC ---- Notarial Seal MY COMMISSION EXPIRES: S awn Gladfelter. Notary Punic illsburg Boro, York County commission Eepires May 17, 2001 . ennsylv ama Association of otanes COMMONWEALTH OF PENNSYLVANIA COUNTY OF / SS On this, the day of , 1999, before me, the undersigned officer, personally appeared HAROLD E. MOORE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. MY COMMISSION EXPIRES: AL) NOTARY BLIC Notarial Seal ~ S Dawn Gladlelter. Notary Pu011C Dillsburg Boro. York Coumy My COmmi55'0n Evpires May 17. 2001 Walter, ennsylvama Assooallon of Nofmie< COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUM &7- bl4d SS On this, the _19-6tay of ??°Pll9GCY 1999, before me, the undersigned officer, personally appeared JOYCE A. BUCHER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. Q J'SEAL) N ARY BLIC MY COMMISSION EXPIRES: CATHY A?FL?ECIK NS ry Public Camp HIII Boro, Cumberland County My Commission Expires Dec. 24, 2001 COMMONWEALTH OF PENNSYLVANIA COUNTY OF C'Gl?1YlQ/1 ; ss On this, the'R day of r Q 1999, before me, the undersigned officer, personally appeared SHAW M. BUCHER, to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereuntg*et my hand and official seal. 'ARY MY COMMISSION EXPIRES: NOTARIAL SEAL CATHY A. FLECK, Notary Publlc Camp HIII Boro, Cumbedand County My Commission Expires Dec. 24, 2001 OCT 0 5 199 BRENDA C. MOORE and HAROLD E. MOORE, Plaintiffs VS. JOYCE A. BUCHER and SHAWN M. BUCHER, Defendants IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 99-5347 IN CUSTODY ORDER OF COUR'P AND NOW, this 29th day of September, 1999, the Conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction in this case. The Custody Conciliation Conference scheduled for today, September 29, 1999 is canceled. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator r `-" ' c-. ? . - _ i-= i( i i ,: ra is ' r- CG c_ ._ l.V L fl