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Home My WebLink About00-00146 1 "'., DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW WilLIAM R. SCHNEIDER, Defendant NO..;{OOC> -/'-fCc, CIVIL TERM IN CUSTODY ORDER OF COJ.LBI AND NOW, this 41 'C-,\ 00 day of , , upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before ~s,,~ \ 1 ' Esquire, the conciliator, at?F1 ~,\-ki\(\ -S-\-., ~i(Sb.~ ,Pennsylvania, on'\)\ 1'S, the 9 day of ~~ ,2000, at 0.\ ~C) o'clock _0. .m., 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. Either party may bring the child who is the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By ~t~W\~ ~lr<\~t) \~, Custody Conciliator ' ~ '" '\ , \::.i? J 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. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR ;} 1 COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-6200 "'t - ..... {', T' fJc.E2,-q~CE ~F ,r". P"OIHONOTARY , 00 JM~ 24 AM 9: 53 CUMBERLAND COUNTY PENNSYLVP-NlA j.O?fAC:/!? W, &'ij_.l-n~ 7b a#~ I;;?f,/:,w ';o/~ ~ z:; ~- /02VC7d ~"~ ~ 4- ~ 1 ,..q.- DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVil ACTION - lAW NO. ;;Lv>W-/V?> CIVil TERM WilLIAM R. SCHNEIDER, Defendant IN CUSTODY COMPLAINT IN CUSTODY AND NOW comes DOROTHY SCHNEIDER, by her attorney, Samuel L. Andes, and makes the following Complaint for custody based upon the following: 1. The Plaintiff is DOROTHY SCHNEIDER, who resides at 103 November Drive, Apartment 5, in Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is WilLIAM R. SCHNEIDER, who resides at 207 Pennsylvania Avenue in Camp Hill, Cumberland County, Pennsylvania. 3. The parties are the parents of two minor children, who are the subject of this custody action, Brian William Schneider, born 14 August 1983 and Jonathan lee Schneider, born 25 February 1985. Both of the children are currently in the custody of the Plaintiff. 4. The Plaintiff and Defendant are husband and wife, having been married on 9 April 1982 and separated in November of 1999. 5. Plaintiff seeks an award of primary legal and physical custody of the minor children, Brian William Schneider and Jonathan lee Schneider. 6. The children were not born out of wedlock and are presently in the custody of the Plaintiff. 7. During the past five years, the minor children have resided with the fOllowing persons at the following addresses: 1 - January 1995 to November 1999 207 Pennsylvania Avenue Camp Hill, PA 17011 Plaintiff/ Defendant November 1 999 to present 103 November Drive, Apt. 5 Camp Hill, PA 17011 Plaintiff 8. The father of the children is the Defendant who resides at the address set out above. He is married to the Plaintiff. 9. The mother of the children is the Plaintiff who resides at the address set out above. She is married to the Defendant. 10. The Plaintiff is the natural mother of the children. Plaintiff currently resides with the children. 11. The Defendant is the natural father of the children. Defendant currently resides alone. 12. The Plaintiff has not participated as a party or in any other way in any litigation concerning the custody of the children in this or any other court. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this or any other jurisdiction. Plaintiff knows of no other person not a party to this action already who has physical custody of or claims to have custody or visitation rights with the said children. 13. The best interests and permanent welfare of the children will be served by granting the relief requested by Plaintiff for the following reasons: A. Plaintiff has been the primary care provide for both children since their birth. B. The children are more comfortable and happier in Plaintiff's custody and under Plaintiff's supervision. II ..,:;f7 C. Defendant is not able to provide a suitable and stable home environment for the children D. The children's best interests, social, academic, personal, and all others, will be best be served by continuing them in the custody of Plaintiff. 14. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff requests this Court to grant her custody of the children, D~~~ ~~~~ Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 \ r ,.'''> , , COMMONWEALTH OF PENNSYLVANIA ) ( SS.: ) COUNTY OF CUMBERLAND DOROTHY SCHNEIDER, being duly sworn according to law, deposes and says that the facts set forth in the foregoing Complaint for Custody are true and correct to the best of her knowledge, information, and belief. MAd, L'- . "- EIDER ,.,.,"1, ~ ~~, Sworn to and SUbS~ibed bef~m0 f~ih. ~I'I~ day of 'iUJ~v\ ' 2000. Orn~t vn. lktMPJ L Notar Public. il tIDTMt~~ ! i Q~u.RQSEU,I.Nmay~ ' ~~e;.~~J . , SAMUEL L. ANDES JAN 11 2.0~~ --".... ~ -~ --.... ATTORNEY AT LAW 0525 NORTH TW"ELFI'H STREET P. o. -aOX 168 LEMOYNE, PENNSYLVANIA 17043 TELEPHONE (717') 761-5361 7 January 2000 FAX (717) 761-1435 Richard Pierce, Court Administrator Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 RE: Dorothy Schneider VS. William R. Schneider In Custody Dear Mr. Pierce: When you assign the above case to the conciliator, I request that you advise the conciliator of a scheduling problem with the Plaintiff has so that we can get a time set which will not have to be rescheduled. Mrs. Schneider is employed by the Pennsylvania House of Representatives and is forbidden to take time off of her work when the House is in session. I enclose a notice she has received from her supervisor advising her of the dates the House will be in session during the first half of 2000. These are the dates she cannot be excused from work and we request that the conciliation conference be scheduled at a date other than any of these. Any consideration the conciliator can give us in scheduling this matter will be appreciated. \.-\wt.1r-.. ~ q". ",0 (::W\ Sincerely, ~ Samuel L. Andes amh Enclosure ....~.. - ~.. -.,.. ---,---- TED MAZIA THE Q-l,IEF CL.ERK NDV 24 1999 (,""::!" :.\\:;.~\ .!,~: .~ .' ~.4 ",#;."",.;/t), ...., ':..::/{ -~~~., '.....~" ( ,,, /,,!'~ 'w""'~.h . il,O!.'~...,~.' '1'.'1\' \;/h ~\~[,\~'~f~~ to.:' " ...~.....~">Si. '" ...l.,::",~..i.;. R~\I'"(';Jq~~?~~~~\t,l;':";v HOUSE OF REPRESENTATIVES COMMONWE'.ALlH OF PENNSYLVANIA HARRISBURG NOTICE SESSION TIME HOUSE OF REPRESENTATIVES Notice is hereby given, in accordance with the Act of July 3, 1986, P.L. 388, Number 84, that the House of Representatives will convene in open session in the Hall of the House on the following dates: January F~bruary March April May June 4, 24, 25, 26, & 31 1,2,7,8,9,14, & 15 13,14,15,20,21, & 22 10,11,12,17,18, & 19 1,2,3,8,9,10,15, & 16, 5,6,7, 12, 13, 14, 19,20,21,26, & 27, & 28 The time of convening on the first day of each session week will be at 1 :00 p.m., prevailing time (as per House Rules), and on each other session day at 11 :00 a.m., prevailing time, unless a different time is previously announced by the Speaker in open session of the House. 1999 ~J~ Ted Mazia, Chief Clerk Tuesday, November 23, ROOM . 129 MAIN CAPITOl. BUI1..CING PHONE: <717l 787.2372 fJ fJ l; '- OORarHY SCHNEIDER, : IN THE COURT OF CXlMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-146 CIVIL TERM : WILLIAM R. SCHNEIDER, : CIVIL ACTTON - LAW Defendant : IN CUSTODY ORDER OF COURT AND fIO'l, this II.. . consideration of the attached and directed as follows: day of;')?a.<--U. , 2000, upon Custody Conciliation Report, it is ordered 1. The Mother, Dorothy Schneider, and the Father, William R. Schneider, shall have shared legal custody of Brian William Schneider, born August 14, 1983, and Jonathan Lee Schneider, born February 25, 1985. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 2. The Mother shall have primary physical custody of the Children. 3. During the school year, the Father shall have custody of the Children on alternating weekends from Tnursday at 5:00 p.m. through sunday at 5:00 p.m. and, during the interim weeks, from Thursday at 5:00 p.m. through Friday before school., During the summer school break, the Father shall have custody of the Children on alternating weekends from Thursday at 5:00 p.m. through sunday at 9:00 p.m. and, during the interim weeks, from Wednesday at 5:00 p.m. through Friday at 8:00 a.m. The Father may also have custody of the Children at any additional times arranged by agreement of the parties. -, 4. The parties shall share or alternate having custody of the Children on holidays as follows:- A. CllRIS'l'MI\S: The Christmas holiday shall be divided into Segment A, which shall run from December 23 at 5:00 p.m. through December 27 at 5:00 p.m., and 8egment B, which shall run fran December 28 at 5:00 p.m. through January 1 at 7:00 p.m. The Father shall have custody of the Children during Segment A in odd numbered years and during Segment B in even numbered years and the Mother shall have custody of the Children during segment A in even numbered years and during 8egment B in odd numbered years. ' The Thanksgiving holiday shall run from the B. THANKSGIVING: Wednesday before Thanksgiving at 5:00 p.m. through the Sunday after Thanksgiving at 5:00p.m. The Father shall have custody of the Children oVer the Thanksgiving holiday in even numbered years and the Mother shall have custody of the Children over the Thanksgiving holiday in odd numbered years. C. EASTER: The Easter holiday shall run from Good Friday at 5:00 p.m. through Easter sunday at 5:00 p.m. The Father shall have custody of - the Children over the Easter holiday in even numbered years and the Mother shall have custody over the Easter holiday in odd numbered years. D. MOTHER'S DAY/FATHER'S DAY: The Mother shall have custody of the Children every year on Mother's Day and the Father shall have custody of the Children every year on Father's D;3.y from the Saturday before the holiday at 5:00 p.m. through Sunday at 8:00 p.m. E. REMAINING HOLIDAYS: The parties shall share having custody over holidays not specifically designated in this Order with the specific arrangements to be made by agreement. F. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. G. In the event the Father's holiday period of custody falls iImnediately preceding or following, his regular period of custody, the period of holiday/regular custody shall run continuously. 5. Each party shall be entitled to have custody of the Children for 3 weeks (consecutive or non-consecutive) during each summer school break. The parties shall notify each other of the dates he = she has selected under this provision by May I of each year. The party providing notice first shall be entitled to preference on the dates he = she has selected. 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. BY THE CCURT, /l;i ..'~~ p1f' 0,1 ':> ~y.. cc: Samuel L. Andes, Esquire - Counsel for Mother Barbara sumple-sullivan, Esquire - Counsel for Father ~.. ~ . IJORarHY SCHNEIDER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CuMBERLAND COONTY, PENNSYLVANIA : vs. : NO. 00-146 CIVIL TERM : WILLIAM R. SCHNEIDER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ClJSTCDY CCNCILIATICIiI SUMMARY REPCRT IN .ACCClIDl\NCE WITH a:JMBERLI\ND OJUNTY RULE OF CIVIL PROCEOORE 1915.3-8, the undersigned Custody Conciliator spbmits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is astollows: NAME DATE OF BIRTH CllRREN.l'Ly IN ClJSTCDY OF Brian William Schneider Jonathan Lee Schneider August 14, 1983 February 25, 1985 Mother Mother 2. A Conciliation Conference was held on March 9, 2000, with the following individuals in attendance: The Mother, Dorothy SChneider, with her counsel, Samuel L. Andes, Esquire, and the Father, William R. SChneider, with his counsel, Barbara Sumple-sullivan, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ~o; Date ,.l.ov2) f ,~~ Custody Conciliator " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOROTHY SCHNEIDER, Plaintiff v. : NO. 2000-247 CIVIL ACTION - LAW : IN DIVORCE WILLIAM R. SCHNEIDER, Defendant DOROTHY T. SCHNEIDER, Plaintiff v. : NO. 00-146 : CIVIL ACTION - LAW : IN CUSTODY WILLIAM R. SCHNEIDER, Defendant DOROTHY SCHNEIDER, Plaintiff v. DOCKET NO. 846 S 1990 PACSES Case Nwnber: 179101847 WILLIAM R. SCHNEIDER, Defendant RULE fA AND NOW, this{~ day of )();}Ar. . ,2000 on consideration of the Petition for Leave to Withdraw as Counsel, a RULE is issued on Plaintiff and Defendant to show cause, if any, why the Court should not grant the relief requested. The Rule is returnable within ~ days from the date of service hereof. BY THE COURT: ~ ~3'OO t? \\'\~ J. filfD-C)\:F\CE or lvr; PPOTHOHOTARY 00 NOli \ 3 t\Ji 8: 32 CUMBERLA~D CQUN1Y PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOROTHY SCHNEIDER, Plaintiff v. : NO. 2000-147 : CIVIL ACTION - LAW : IN DIVORCE WILLIAM R. SCHNEIDER, Defendant DOROTHY SCHNEIDER, Plaintiff v. : NO. 00-146 : CIVIL ACTION - LAW : IN CUSTODY WILLIAM R. SCHNEIDER, Defendant DOROTHY T. SCHNEIDER, Plaintiff v. DOCKET NO. 846 S 1990 PACSES Case Number: 179101847 WILLIAM R. SCHNEIDER, Defendant PETITION FOR LEAVE TO WITHDRAW AS COUNSEL ?f? .... -:-:-r ~ AND NOW, this a[lh day of October, 2000, comes Barbara Sumple-Sulli~~n, Esq;Jre, '" 0-'" '~C'o '- J ~Yl and files the within Petition for Leave to Withdraw as Counsel for the following r~.~ns: ~ -.:-=il'l1 ~ --,coo; ~ -<::.. ~ 0> g I. On or about January 17, 2000, William R. Schneider, Defendant contracted with the law firm of Barbara Sumple-Sullivan, Esquire in connection with the above-referenced actions. / / 2. Pursuant to that representation, the litigation involving this case is continuing. 3. Despite numerous requests, William R. Schneider has refused to make payment to counsel as agreed or otherwise contact and cooperate with counsel regarding this matter. 4. Defendant has not been cooperative in providing requested information and has not fulfilled his obligations to Movant and it would be a hardship for Movant to incur additional time and expense incident in this representation. WHEREFORE, Barbara Sumple-Sullivan, Esquire, requests that she be withdrawn as counsel and that William R. Schneider, be ordered and/or directed to find another counseL DATE: OctoberQ 2000 Barbara Sump Ie-Sullivan, Esquire 549 Bridge Street New Cwnberland, PA 17070-1931 (717) 774-1445 Supreme Court LD. 32317 2 ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOROTHY SCHNEIDER, Plaintiff v. : NO. 2000-247 CIVIL ACTION - LAW : IN DIVORCE WILLIAM R. SCHNEIDER, Defendant DOROTHY T. SCHNEIDER, Plaintiff v. : NO. 00-146 : CIVIL ACTION - LAW : IN CUSTODY WILLIAM R. SCHNEIDER, Defendant DOROTHY SCHNEIDER, Plaintiff v. : DOCKET NO. 846 S 1990 : PACSES Case Number: 179101847 WILLIAM R. SCHNEIDER, Defendant CERTIFICATE OF SERVICE I, BARBARA SUMPLE-SULLlV AN, ESQUIRE, do hereby certify that on this date, I served a true and correct copy of the PETITION FOR LEAVE TO WITHDRAW AS COUNSEL, in the above-captioned matter upon the following individuals by first class mail, postage prepaid, addressed as follows: Mr. William R. Schneider 207 Pennsylvania Avenue Camp Hill, P A 17011 Samuel L. Andes, Esquire 525 North Twelfth Street P.O. Box 168 Lemoyne, P A 17043 DATE: October ~ 2000 B ara Sumple-Sullivan, Esquire 549 Bridge Street New Cwnberland, PA 17070-1931 (717) 774-1445 Supreme Court LD. 32317