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HomeMy WebLinkAbout02-3265 ICHAEL L. BUCHER, Petitioner ANGELA COOK, Respondent : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. o.z. :CUSTODY COMPLAINT FOR CUSTODY ¢'~ -<2 AND NOW this ':~ day of July, 2002, comes Petitioner, MICHAEL L. BUCHER, by and through counsel, Lawrence J. Rosen, Esquire, and offers the following averments in support of the within Complaint: Petitioner is Michael L. Bucher residing at 211 Wyoming Avenue, Enola, Pennsylvania, 17025. The Respondent is Angela Cook residing at 9841 Cypress Park Drive, Orlando, Florida 32824 3. Petitioner seeks custody of the following children: NAME PRESENT ADDRESS AGE Jennie L. Bucher Same as Petitioner (11/15/94) 7 Jerade M. Bucher Same as Petitioner (4/4/93) 9 Jerade M. Bucher was born out of wedlock. Jennie L. Bucher was not born out of wedlock.. The children are presently in the custody of Petitioner who resides at 211 Wyoming Avenue, Enola, PA 17025. During the past five years, the children have resided at various places two numerous to mention. Respondent has lived in three states including Florida, Arizona and Georgia at various and have lived with various people, too numerous to mention. Respondent's failure to provide a stable living environment is one of the bases for this petition. The mother of the children is Angela Cook who currently resides at 9841 Cypress Park Drive, Orlando, Florida 32824. She is married. The Father of the children is Michael L. Bucher who currently resides at 211 Wyoming Avenue, Enola, PA 17025. He is single. The relationship of Petitioner to the child is that of father. Petitioner currently resides with the following persons: Brother and sister-in-taw and their two minor children The relationship of Respondent to the children is that of mother. Respondent currently reside with the following persons: Boyfriend and her two children, Jeffrey Ward (5) and Jonathon (12). Petitioner 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. Petitioner has no information of a custody proceeding conceming the child pending in a court of this Commonwealth. Petitioner 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. The best interests and permanent welfare of the child will be served by granting the relief requested because Respondent has demonstrated her inability of properly care for the children. Due to her inability to so care, they have not had a stable or proper living environment for years. 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. WHEREFORE, Petitioner requests the court to grant him legal and physical custody of the minor children, Jenny L. Bucher and Jerade M. Bucher. Respectfully submitted: KREVSKY & ROSEN, P.C. By: ~t ~ ~1 ~0 lr~nc e J~' °SNorth Fron:n~trE;eqtuire Harrisburg, PA 17102 ID# 10625 (717) 234 4583 MICHAEL L. BUCHER, Petitioner : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. ANGELA COOK, :CUSTODY Respondent : VERIFICATION I, MICHAEL L. BUCHER, hereby verify that the information contained in the foregoing Complaint for Custody is true and correct to the best of my knowledge, information and belief. I also understand that false statements made herein are subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. MICHAEL L. BUCHER MICHAEL L. BUCHER, Petitioner : 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. ANGELA COOK, : Respondent :CUSTODY CERTIFICATE OF SERVICE AND NOW, this ~4~- day of July, 2002, I, Aimee L. Paukovits, for the law firm of Krevsky & Rosen, P.C., hereby certify that I have this day served a copy of the Complaint in the above-captioned matter, by U.S. FIRST CLASS CERTIFIED MAIL on the following: ANGELA COOK 9841 CYPRESS PARK DRIVE ORLANDO, FLORIDA 32824 Aimee L. Paukovits Krevsky & Rosen, P.C. 1101 North Front Street Harrisburg, PA 17102 (717) 234-4583 MICHAEL L. BUCHER, Petitioner ANGELA COOK, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 0 CUSTODY EMERGENCY PETITION FOR CUSTODY AND NOW, this z(~r~ day of July, 2002, comes Petitioner, Michael L Bucher, by and through counsel, Lawrence J. Rosen, Esquire and offers the following averments in support of the within Emergency Petition for Custody: 3. 4. 5. 6. 7. Petitioner is the father of the minor children, Jenny L. Bucher (DOB 11/15/94) and Jerade M. Bucher (DOB 4/4/93). Petitioner resides at 211 Wyoming Avenue, Enola, Pennsylvania 17025. Respondent is the mother of aforesaid minor children. Respondent resides at 9841 Cypress Park Drive, Orlando, Florida 32824. The parties were married and are currently divorced. The minor children are currently living with Petitioner. For much of the past several years, the minor children were living with Respondent. Due to Respondent's chaotic lifestyle, Petitioner had little contact with her or the minor children. During the past several years, Respondent has lived at numerous locations in Arizona, Florida and Georgia. During this period she has co-habited with various different men. 10. 11. 12. 13. 14. There was a report of sexual abuse filed against Respondent's former husband, Jeffery Ward regarding Jenny L. Bucher. Respondent fled Florida to her parent's home in Arizona to avoid the investigation. She later returned to live with Ward notwithstanding the report that he abused her daughter. Respondent brought the minor children to stay with Petitioner last summer for one month. Notwithstanding concerns which he had at that time, he returned the children to the care of Respondent. Respondent brought the children to stay with Petitioner on June 7, 2002. When the children arrived they were all their clothes were wet and mildewed, they were wearing shoes two sized too small, they'were filthy and both children had horrible dental hygiene. Each child has already lost one tooth due to their lack of dental hygiene. Due to Respondent's chaotic lifestyle the children have not been regularly enrolled in school. Respondent has not demonstrated the ability to hold gainful employment. The reason that the children were brought to Pennsylvania was that she was facing eviction from her current residence, a eight foot wide, one bedroom mobile home where she was residing with her current boyfriend, the two minor children who are the subjects of the current Petition and two other minor children. 15. Respondent's mother, Pat Phipps who lives near Respondent has reported that: In addition to facing eviction from her current home, the power in her home has been shut off. Therefore, no air conditioning unit or fan can operate in Florida in the middle of summer. There has been no food in the house for the past two months and she has been forced to bring food to the family. Jerade has repeatedly called her to tell her that they were going hungry. The children were homeless in December and were forced to flee to Georgia as Respondent was being investigated for falling to have the children enrolled in school. The children do not have beds and are forced to sleep anywhere they can find space in the seriously overcrowded trailer. The children have no sheets, clean, proper clothing nor do they have toothbrushes. 16. 17. 18. 19. Respondent has told her mother that she has been diagnosed as suffering from bi-polar disorder. On Easter morning, Jerade told his grandmother, Pat Phipps, that his mother had been away all night and left the children alone and that she does that regularly. Petitioner has filed a Custody Complaint concomitantly with the instant Petition for Emergency Custody. Pat Phipps has indicated that she will be available to testify via telephone at any future hearing(s). Should the instant Petition be denied, the minor children are in grave danger of continued neglect due to: B. C. D. E. F. The probability that Respondent will be evicted from her already insufficient home. Lack of power at said home Respondent's history of unstable residence and inability to maintain stable employment. Respondent's failure/inability to feed children. Respondent's failure to provide children with proper education. Respondent's failure to provide children with proper sleeping accommodation, clean sheets, clean clothes and toothbrushes. Respondent's history of leaving the children alone overnight on a regular basis. Respondent's failure to protect Jenny Bucher from her reported abuser, Jeff Ward, Respondent's husband. Respondent's psychiatric condition. Petitioner has lived in central Pennsylvania for more than five years. He currently lives with his brother, sister-in-law and their two minor children. Petitioner's children are also loved and welcome in their home. 20. Petitioner has been employed at Arnold Logistics for more than four years. 21. Petitioner is prepared and able to provide his children with a loving, stable environment where they have proper clothes, sleeping accommodations, nutritious meals, regular schooling, proper hygiene and proper structure; all things the children currently lack when with Respondent. WHEREFORE, Petitioner asks Your Honorable Court to grant him legal and physical custody of the minor children on an emergency basis pending further action. Respectfully submitted: KREVSKY & ROSEN, P.C. ~l~a~vrenc~. Rosen, Esquire 1101 North Front Street Harrisburg, PA 17102 ID# 10625 (717) 234 4583 MICHAEL L. BUCHER, Petitioner : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO. : ANGELA COOK, :CUSTODY Respondent : VERIFICATION I, MICHAEL L. BUCHER, hereby verify that the information contained in the foregoing Emergency Complaint for Custody is true and correct to the best of my knowledge, information and belief. I also understand that false statements made herein are subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. MICHAEL L. BUCHER LAW OFFICE OF DARRELL C. DETHLEFS By: Michael J. Pykosh Attorney Identification No. 58851 3805 Market Street Camp Hill, PA 17011 (717) 975-9446 Attorney fo~ plaintiffs, Rothman, Schubert & Reed Realtors, LLC ROTHMAN, SCHUBERT & REED REALTORS, LLC, Plaintiff V. STEPHEN EBERLY and MARGARET EBERLY, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION - LAW ARBITRATION CASE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice have been served. To defend against the aforementioned claims, a written appearance stating your defenses and objections must be entered and filed in writing by you, the Defendant, or by an attorney. You are warned that if you fail to take action against these claims, the court may proceed without you and a judgment for any money claimed in the complaint or for another claim required by the Plaintiff may be entered against you in Court without further notice. You may lose money, property or other rights important to you. 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) :149-3166 NO~C~ Le hah demandado a usted en la cone. Si usted quiere defenderse de estas demandas expuastas en las paginas siguiemes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presemar una apariencia escrita o en persona o pot abogado y archivar en la cone en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisdao que si usted no se defiende, la cone tomara medidas y puede entrar una orde contra usted sin previo aviso o notificacion y pot cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o oU'os derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIAMENTE. SI NO TIENNE ABOGAD O SI NO TIENNE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONE A LA OFICINA CUYA PUEDA CONSEGUIR ASSISTENCIA LEGAL: LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Date: Michael $. ~k~sla('Es~uir~?'~ Attorney I.D. 58851 3805 Market Street P.O. Box 368 Camp Hill, PA 17001 (717) 975-9446 MICHAEL L. BUCHER, Petitioner V. ANGELA COOK, Respondent : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. : :CUSTODY CERTIFICATE OF SERVICE AND NOW, this ~ day of July, 2002, I, Aimee L. Paukovits, for the law firm of Krevsky & Rosen, P.C., hereby certify that I have this day served a copy of the Emergency Complaint for Custody in the above-captioned matter, by U.S. FIRST CLASS CERTIFIED MAIL on the following: ANGELA COOK 9841 CYPRESS PARK DRIVE ORLANDO, FLORIDA 32824 Aimee L. Paukovits Krevsky & Rosen, P.C. 1101 North Front Street Harrisburg, PA 17102 (717) 234-4583 MICHAEL L. BUCHER, Petitioner ANGELA COOK, Respondent : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO: 0.~- $2_~' : CUSTODY : EMERGENCY PETITION FOR CUSTODY AND NOW, this ~day of July, 2002, comes Petitioner, Michael L Bucher, by and through counsel, Lawrence J. Rosen, Esquire and offers the following averments in support of the within Emergency Petition for Custody: 3. 4. 5. o Petitioner is the father of the minor children, Jenny L. Bucher (DOB 11/15/94) and Jerade M. Bucher (DOB 4/4/93). Petitioner resides at 211 Wyoming Avenue, Enola, Pennsylvania 17025. Respondent is the mother of aforesaid minor children. Respondent resides at 9841 Cypress Park Drive, Orlando, Florida 32824. The parties were married and are currently divorced. The minor children are currently living with Petitioner. For much of the past several years, the minor children were living with Respondent. Due to Respondent's chaotic lifestyle, Petitioner had little contact with her or the minor children. During the past several years, Respondent has lived at numerous locations in Arizona, Florida and Georgia. During this period she has co-habited with various different men. 10. 11. 12. 13. 14. 15. There was a report of sexual abuse filed against Respondent's former husband, Jeffery Ward regarding Jenny L. Bucher. Respondent fled Florida to her parent's home in Arizona to avoid the investigation. She later returned to live with Ward notwithstanding the report that he abused her daughter: Respondent brought the minor children to stay with Petitioner last summer for one month. Notwithstanding concerns which he had at that time, he returned the children to the care of Respondent. Respondent brought the children to stay with Petitioner on June 7, 2002. When the children arrived they were all their clothes were wet and mildewed, they were wearing shoes two sized too small, they were filthy and both children had horrible dental hygiene. Each child has already lost one tooth due to their lack of dental hygiene. Due to Respondent's chaotic lifestyle the children have not been regularly enrolled in school. Respondent has not demonstrated the ability to hold gainful employment. The reason that the children were brought to Pennsylvania was that she was facing eviction from her current residence, a eight foot wide, one bedroom mobile home where she was residing with her current boyfriend, the two minor children who are the subjects of the current Petition and two other minor children. Respondent's mother, Pat Phipps who lives near Respondent has reported that: A. In addition to facing eviction from her current home, the power in her home has been shut off. Therefore, no air conditioning unit or fan can operate in Florida in the middle of summer. B. There has been no food in the house for the past two months and she has been forced to bring food to the family. Jerade has repeatedly called her to tell her that they were going hungry. C. The children were homeless in December and were forced to flee to Georgia as Respondent was being investigated for failing to have the children enrolled in school. The children do not have beds and are forced to sleep anywhere they can find space in the seriously overcrowded trailer. The children have no sheets, clean, proper clothing nor do they have toothbrushes. 16. 17. 18. Respondent has told her mother that she has been diagnosed as suffering from bi-polar disorder. Fo On Easter morning, Jerade told his grandmother, Pat Phipps, that his mother had been away all night and left the children alone and that she does that regularly. Petitioner has filed a Custody Complaint concomitantly with the instant Petition for Emergency Custody. Pat Phipps has indicated that she will be available to testify via telephone at any future heating(s). Should the instant Petition be denied, the minor children are in grave danger of continued neglect due to: Ao B. C. D. Fo The probability that Respondent will be evicted from her already insufficient home. Lack of power at said home Respondent's history of unstable residence and inability to maintain stable employment. Respondent's failure/inability to feed children. Respondent's failure to provide children with proper education. Respondent's failure to provide children with proper sleeping accommodation, clean sheets, clean clothes and toothbrushes. Respondent's history of leaving the children alone overnight on a regular basis. Respondent's failure to protect Jenny Bucher from her reported abuser, Jeff Ward, Respondent's husband. Respondent's psychiatric condition. 19. Petitioner has lived in central Pennsylvania for more than five years. He currently lives with his brother, sister-in-law and their two minor children. Petitioner's children are also loved and welcome in their home. 20. Petitioner has been employed at Arnold Logistics for more than four years. 21. Petitioner is prepared and able to provide his children with a loving, stable environment where they have proper clothes, sleeping accommodations, nutritious meals, regular schooling, proper hygiene and proper structure; all things the children currently lack when with Respondent. WHEREFORE, Petitioner asks Your Honorable Court to grant him legal and physical custody of the minor children on an emergency basis pending further action. Respectfully submitted: KREVSKY & ROSEN, P.C. ~1101 el~; ~h' FRr~ Sn~n~l rEeSeqtuire Harrisburg, PA 17102 ID# 10625 (717) 234 4583 MICHAEL L. BUCHER, Petitioner Vo ANGELA COOK, Respondent : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. : :CUSTODY yERIFIC___ATION I, MICHAEL L. BUCHER, hereby verify that the information contained in the foregoing Emergency Complaint for Custody is tree and correct to the best of my knowledge, information and belief. I also understand that false statements made herein are subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. MICHAEL L. BUCHER MICHAEL L. BUCHER, Petitioner ANGELA COOK, Respondent : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. :CUSTODY CERTIFICATE OF SERVICE AND NOW, this ~ day of July, 2002, I, Aimee L. Paukovits, for the law firm of Krevsky & Rosen, P.C., hereby certify that I have this day served a copy of the Emergency Complaint for Custody in the above-captioned matter, by U.S. FIRST CLASS CERTIFIED MAIL on the following: ANGELA COOK 9841 CYPRESS PARK DRIVE ORLANDO, FLORIDA 32824 Aimee L. Paukovits Krevsky & Rosen, P.C. 1101 North Front Street Harrisburg, PA 17102 (717) 234-4583 MICHAEL L. BUCHER V. ANGELA COOK : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . : NO. 2002-3265 CIVIL TERM ORDER OF COURT AND NOW, this ! 1TM day of JULY, 2002, a hearing on Petitioner's Emergency Petition for Custody is scheduled for FRIDAY~ JULY 19~ 2002~ at 1:00 p.m. Pending said hearing the parties shall have joint legal custody of the children. It is further ordered that neither party shall remove the children from Pennsylvania prior to said hearing without further order of this court. Lawrence J. Rosen, Esquire For the Petitioner Angela Cook 9841 Cypress Park Drive Orlando, Fla. 32824 :sld Edward E. Guido, J. MICHAEL L. BUCHER, : Plaintiff : : : V. : : ANGELA COOK, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-3265 CIVIL TERM QRDER OF COUR~ AND NOW, this 19th day of July, 2002, it not being clear to the Court that service has been effectuated on the emergency petition for custody, this matter is continued until Friday, August 16, 2002, at 8:30 a.m. Plaintiff is directed to effectuate service of the petition, along with a copy of this order, upon Defendant by certified mail, return receipt requested, and first class mail. Pending said hearing, the parties shall have joint legal custody of the children. It is further ordered that neither party shall remove the children from Pennsylvania prior to said hearing without further order of this court. By the court, ~dward E. Guido, J. Lawrence J. Rosen, Esquire Krevsky & Rosen, P.C. 1101 North Front Street Harrisburg, PA 17102-3324 Attorney for Plaintiff Angela Cook - 9841 Cypress Park Drive Orlando, Fla. 32824 ars MICHAEL L. BUCHER : PLAINTIFF : ._ V. : 02-3265 : ANGELA COOK DEFENDANT : 1N CUSTODY : ORDER OF COURT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW AND NOW, Friday, July 19, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Monday, August 19, 2002 at 8:30 AM 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. 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. The court hereby directs the parties to furnish any and aH existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Melissa P. Greevy. Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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 ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 L~ .... ,3'~ Z 0 C~ (.-) MICHAEL L. BucHER, Plaintiff V. ANGELA cOOK, Defendant : IN THE COURT OF coMMON pLEAS OF : CUMBERLAND coUNTY, pENNSYLVANIA : : : : : 02-3265 CIVIL TERM IN RE: cUSTODY ORDER OF COURT AlqD NOW, this 16th day of August, 2002, after conference with the parties, we will enter the following temporary order pending the conciliation process in this matter: The parties shall have joint legal custody of their children, jennie L. Bucher, born NovenfDer 15, 1994, and Jerade M. Bucher, born April 4, 1993. The Father shall have primary physical custody of the children subject to periods of partial physical custody with Mother as agreed upon by the parties- Both parties shall keep each other apprised of their address and telephone number at all times. Mother may have liberal telephone contact with the children. since Mother has recently been served with the papers in connection with this matter and has indicated she is attempting to get legal counsel, the conciliation conference scheduled for Monday, August 19, 2002, shall be continued. A new conciliation conference shall be scheduled at the earliest 9851 cypress park Drive orlando, Florida practical date thereafter'By~ ' °'--~----Edward E Guido, · Angela cook ~ 32824 Lawrence J- Rosen, Esquire Attorney for Plaintiff OCT ] 5 ZOOZ y MICHAEL L. BUCHER, Plaintiff V. ANGELA COOK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3265 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY GUIDO, J.--- ORDER OF COURT AND NOW, this / "/t~ day of October, 2002, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Michael L. Bucher and Angela Cook, shall have shared legal custody of their children, Jennie L. Bucher, born November 15, 1994 and Jerade M. Bucher, born April 4, 1993. 2. Physical Custody. The Father shall have primary physical custody of the children subject to periods of partial custody with Mother as agreed upon by the parties. 3. Both parties shall keep each other apprised of their address and telephone number at all times. 4. Mother may have liberal telephone contact with the children. 5. Counsel for Plaintiff is directed to serve a copy of this Order on the Defendant at her last known address and to subsequently file an Affidavit of Service indicating service has been accomplished. 6. In the event that Mother is aggrieved by the terms of this Order, she may, within thirty (30) days of the date of this Order, make a written request to the Custody Conciliator to reconvene the Custody Concili n~~e. Dist: Edward E. Guido, J. Lawrence J. Rosen, Esquire, 1101 N. Front Street, Harrisburg, PA 17102 Angela Cook, 9612 Eighth Avenue, Orlando, FL 32824 '~ ~ MICHAEL L. BUCHER, Plaintiff V, ANGELA COOK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3265 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, 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 Jennie L. Bucher Jerade M. Bucher DATE OF BIRTH CURRENTLY IN THE CUSTODY OF November 15, 1994 Father April 4, 1993 Father 2. A Custody Conciliation Conference was held on September 17, 2002 with the following individuals in attendance: the Father, Michael L. Bucher, and his counsel, Lawrence J. Rosen, Esquire; the Mother, Angela Cook, did not attend the Conciliation Conference. The Conciliation Conference was scheduled at the direction of Judge Guido following a telephone conference with the parties. The Order scheduling the Custody Conciliation Conference was sent to the Defendant through restricted delivery mail at the address which she had provided to the Court on the day of the Confer~e~.ce with Judge Guido. The restricted delivery mail notifying the Defendant of the Conference was returned as unclaimed. Counsel for the Plaintiff indicates that he received information from the children on Friday, September 13, 2002 that the Defendant has moved to a new address in Orlando, Florida. The Custody Conciliator attempted to contact the Defendant at the telephone number which she had provided to the Plaintiff. The Conciliator was informed that the Defendant no longer lives there, has no telephone at her residence, but comes by occasionally. 3. The Conciliator provides a recommended order confirming much of the content of Judge Guido's order of August 16, 2002, adding two additional requirements. A. A requirement on Plaintiff to serve a copy of the Order on Mother at her last known address. NO. 02-3265 CIVIL TERM B. To provide Mother a thirty-day window from the date of the Order to request an additional Custody Conciliation Conferee event that she is aggrieved by the terms of the Order. I/~/~ J Date Custody Conciliator :163659 MICHAEL L. BUCHER Plaintiff Ve ANGELA COOK, Defendant : IN THE COURT OF COMMON PLEAS OF : DAUPHIN COUNTY, PENNSYLVANIt~ : : NO. 02-3265 CIVIL TERM : : CIVIL ACTION - IN DIVORCE AFFIDAVIT OF SERVICE I, Lawrence J. Rosen, attorney for the P!aintiff, MICHAEL L. BUCHER, hereby certify that a copy of the October 17, 2002 Orde] of Court entered by the Honorable Richard E. Guido, relative to the above-referenced matter, ~vas served by Certified Mail, Return Receipt Requested on October 30, 2002, on the following: DATE: ANGELA COOK 9612 8TM AVENUE ORLANDO, FLORIDA 3282~. ~me;}ef~ } ~:ien~ f~squir~--- 1101 North Front Street Harrisburg, PA 17102 (717) 234-4583 Atlb'. I.D. NO. 10625 I ]" ~ - ' ~" i 7001 1940 0004 1686 1664 ~sflc R~um R~ipt