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Home My WebLink About07-5367PETER C. BUCH, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2007- s 3 ~ ~ LISA L. BUCH, :CIVIL ACTION -LAW Defendant :CUSTODY COMPLAINT FOR SHARED CUSTODY TO THE HONORABLE, THE JUDGES OF THE SAID COURT: AND NOW comes the Plaintiff, PETER C. BUCH, by his attorney, MAX J. SMITH, JR., Esquire, and respectfully represents the following: 1. Plaintiff is PETER C. BUCH, whose address is 4971 Saddlebrook Drive, Harrisburg, Dauphin County, Pennsylvania, effective September 10, 2007. 2. Defendant is LISA L. BUCH, whose address is 1275 Windsor Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant aze married and are the pazents of three children, MADISON T. BUCH, born May 24, 1996, SYDNEY T. BUCH, born July 31, 1998 and CHASE A. BUCH, born November 18, 2003. 4. The best interests and welfaze of the minor children require that shared physical and legal custody be with both parents, on an equal basis. 5. The minor children have re"sided at 1275 Windsor Road, Mechanicsburg, Cumberland County, Pennsylvania with both parents until the parties' separation, which is to occur on September 10, 2007. Since that date they have resided with Mother. 6. Plaintiff does not have any information of any custody proceeding concerning said minor children in any court in Pennsylvania or any other State. 7. Plaintiff has not participated as a party, witness or otherwise in any other litigation concerning the custody of said minor children in Pennsylvania or any other State. 8. Plaintiff does not know of any person not a party to these proceedings who has physical custody of the said minor children or who claims to have custody or visitation rights with respect to them. WHEREFORE, Plaintiff respectfully prays that your Honorable Court order that shared physical and legal custody of the minor children, MADISON T. BUCH, SYDNEY T. BUCH and CHASE A. BUCH, be placed with both parents. Date: September 7 , 2007 Respectfully submitted, f MAX J. SMITH, ., Esquire I.D. No. 32114 JARAD W. HANDELMAN, Esquire LD. No. 82629 James, Smith, Dietterick & Connelly LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 I verify that the statements made in this Complaint are true and correct. I under- stand that false statements herein are made subject to the penalties of 1$ Pa. C.S. Section 4904, relating to unsworn falsification to authorities. _ `~- __._ -~ ~ ~ ~, ~- ~~~~~ Q -~ ..~, ~ ° ~- ~ ~ ~ ~ ~ .~, g- ~. PETER C. BUCH PLAINTIFF V. LISA L. BUCH DEFENDANT IN THE COUR CUMBERLAN' • 2007-5367 CI` IN CUSTODY T OF COMMON PLEAS OF COUNTY, PENNSYLVANIA ACTION LA W QRDER QF COURT AND NOW, Wednesday, September 12, 2007 , upo it is hereby directed that parties and their respective counsel appear bef at 4tb Floor, Cumberland County Courthouse, Carlisle on for aPre-Hearing Custody Conference. At such conference, an effort if this cannot be accomplished, to define and narrow the issues to be h order. All children age five ar older may also be present at the confer provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all Special Relief orders, and Custody orders to the conciliator 48 ho FOR THE COURT, By: /s/ Hubert X. Custody The Court of Common Pleas of Cumberland County is with Disabilites Act of 1990. For information about accessible f available to disabled individuals having business before the cour must be made at least 72 hours prior to any hearing or business b conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR AT" HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TC FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEI Cumberland County B. 32 South Bedfor Carlisle, Pennsylvax Telephone (717) ; ~ consideration of the attached Complaint, >re Hubert X. Gilroy, Esq. ,the conciliator, riday, October 12, 2007 at 8:30 AM ill be made to resolve the issues in dispute; or ird by the court, and to enter into a temporary ice. Failure to appear at the conference may -ting Protection from Abase orders, prior to scheduled hearing. equired by law to comply with the Americans ;ilities and reasonable accommodations please contact our office. All arrangements Fore the court. You must attend the scheduled RNEY AT ONCE. IF YOU DO NOT OR TELEPHONE THE OFFICE SET AL HELP. ~r Association Street is 17013 .49-3166 -7P'~P °-~' ' CO- £1 ~ b ~fNb/1l,~SNN~d 6 ~ ~~i ~d ~ I d~S tQOl ~tt~la~~J,.Q~d ~! ~E3 ~~ PETER C. BUCH, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. N0.2007-5367 LISA L. BUCH, :CIVIL ACTION -LAW Defendant ~ :CUSTODY CERTIFICATE OF SERVICE AND NOW, this 17th day of September, 2007, I, MAX J. SMITH, JR., Esquire, Attorney for Plaintiff, hereby certify that I have this day sent a copy of Complaint for Shared custody by depositing a certified copy of the same in the United States mail, postage prepaid, certified mail #7006 2150 0004 2693 5$33 at Hummelstown, Pennsylvania, addressed to: Lisa L. Buch 1275 Windsor Road Mechanicsburg, PA 17055-0626 Mailing and return receipt cards attached hereto. MAX J. SMITH, ., Esquire I.D. No. 32114 JARAD W. HANDELMAN, Esquire I.D. No. 82629 James, Smith, Dietterick & Connelly it,r P.O. Box 650 Hershey, PA 17033 (717) 533-3280 r°~ nt rrt ~O m °r A' a ~~ s 5 ..~ ti ~ }p ,..,. Y ~~.. 7 yh~' •"' r ~ CerUNed Fee ^ 0(.~S ~ ~ ~ir~ ,~ t. '~If ~ ~ Q Ratum Receipt Fes ~ndoreemeM Required) ~ f ~"~, re ', ~' ~ ~ -e ~ .• ~ _ , p (Few°raemeM Requryired) ('Q ~'~ ~~ t ~•:.' ..ww r/ ~"~ Total Postage ~ Fees ~ ~' .-[~ ~ •_:. 0~ ~~' ~ .a._.. t TO M ~, ~, Q, ~ C~ ~ ~`l~fl~... :--.t4f::`_:4I 1-° -°--•-~----°------------------~--~ M1 beef ~ ----- er Pq liar hb. ~"'~ S ~ ~f ~. _ ~~ ~ , ~~ , QQ (~o~ ~ cx~.~4 ,# A __ _ _. _._._ _ t"? tom. .... '-~~ ~ , ro ,~~-.~ 1 ~~ ~~ ~ -o ~.' N --a `.: -~". .:~' c.1` PETER C. BUCH, Plaintiff v. LISA L. BUCH, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-5367 CIVIL ACTION -LAW CUSTODY PRAECIPE Please withdraw the Complaint for Shared Custody which was filed on behalf of Peter C. Buch, in the above matter. Thank you. Date: October ~ , 2007 ~~ ~ MAX J. SMITH, JR., Es ire I.D. No. 32114 JARAD W. HANDELMAN, Esquire I.D. No. 82629 James, Smith, Dietterick & Connelly LLr P.O. Box 650 Hershey, PA 17033 (717) 533-3280 r-.~ ,--. c: " _.~ ~- ~ ~-~, ~ ,~: N ,~.., - _~ ~' , , c,a . _. r;: PETER C. BUCH, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v :CIVIL ACTION -LAW LISA L. BUCH, NO. 2007-5367 Defendant : IN CUSTODY COURT ORDER AND NOW, this ~ day of October, 2007, the Conciliator being advised by opposing counsel that the Plaintiff is withdrawing his Complaint, the Conciliator relinquishes jurisdiction. ~ ~~ `° w Hubert X. Gilroy Custody ConcyNa .. "n 3 f ~ 4.-;~ x L ~~ '. ~ " 7' ^ ^" .... 4