HomeMy WebLinkAbout97-02725
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No, 601
Stipulations Against Li~ns
Raskas Foods, Inc..
..........111.....................................
Owner
In Ih, Courl of Common PI,as Counly of
, PmrlS)llvania,
v,rsus
, .
Numb" t) 7- d ") 33 1>1 L/) r"m, 19
t' ~.q'1.i.l}. .Tt,..J.lP.~tn. .CP.,. 10....................
Controctor
~(lerellS,
of P,nnsylvania
is aboulIa "'ICul, conl,mporan,ously htt,wilh. a conlract, with Ras kas Foods, Inc.
of 165 N. Mcramcc ^vc., St. Louis, MO PmrlS)llvania,
for Ih, rrxail!U!O! stllll)X kl(i~IJ(RioAl'Ii<WR,*fill'll!(
office addition at 208 E. Dykeman Road, Shippensburg,
cumberland County
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No. 601
Stipulations Against Liens
In Ih, Courl of Common PI,Ol Counl)' of
Raskas Foods Inc.
...................1.............................
Owner
, Plnnsyluonia,
UtrSUS
Numbtr t1"7"";J""13;t /11 LJ) Ttrm, 19
Edwin L. Heim Co.
.................................................
Cont""clor
~llerel1S,
P.nns)'luonio
of
is oboul 10 '.,,,ul. conl.mporon.ousl)' htr.wilh, 0 controcl, wilh Raskas Foods, Inc.
of 165 N. Heramec live. st. Louis, MO 11~'1iK.
JX<K7> :IIK~'" IIX<Hl9/dP1l<< Jti~lf
warehouse expansion at 208 E. Dykeman Road,
. Cumberland County
for th. lIttll:lox ll>t lIlX
Refrigerated
Sh ippens burg
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No. 601
- ,
Stipulations Against Li~ns
Raskas Foods Inc.
...................(.............................
Owner
In Ih, Courl of Common PI,Ol Counl)' of
, P,nnsyluania,
UtrSUS
Numbtr 1'7- .;2/3/ MLi)
Ttrm, 19
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Cont""ctor
~llerel1S,
of
is aboul 10 ....cul. conl.mporan,ousl" h."wilh, d contracl, wilh Raskas Foods, Inc.
~ 165 N. Meramec Ave., St.
far Ih.li~<<01aXclfr..'< K~~
Bakers Cheese project at 208 E. Dykeman
Cumberland County
P.nns)'luania
Louis ~Q. ll'x~OlIlIiq,
'b"K<#M<KM1fl('i9MJ.XWlf~~
Road, Shippensburg,
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UTILITY CUSTOMER ACCOUNTING
Customer 10: GORMAFCOO 1
location 10: 688704
Service locallon: 6347 Stephens Crossing, Mechanicsburg
Date Cd Srv CI Rt Balance
05/19/97 BA 02 SW 01 $550.69
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UTILITY CUSTOMER ACCOUNTING
Customer 10: CLAPPMCOOI
Location 10: 203904
Service Location: 9 Creekside Lane, Camp Hill
Date Cd Srv CI Rt Balance
05/19/97 BA 02 SW 01 $437.73
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@NOV 1 0 1997
MELANIE ANN AEPPLI, . IN THE CXllJRT OF COMMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
:
vs. . NO. 97-2725 CIVIL TERM
.
:
MARK ALAN AEPPLI, . CIVIL ACTION - LAW
.
Defendant . IN CUSTODY
.
OODER OF COORT
AND NOW, this 5th day of November, 1997, the Conciliator, having
been advised by the Court that this matter has been dismissed upon a
finding of lack of jurisdiction, hereby relinquishes jurisdiction in this
case.
(C~Jj~~
Dawn S. Sunday, Esquire
Custody Conciliator
gEo~9E dl1 'J~Eed
Allomey ellaw
125 E, Nonh Streel
Temple Bldg, Sune 316
New CasUe, PA 16101
Phone (412) 657.9630
Fa. (412) 657-9651
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Mark Aeppli, CIVIL ACTION
Petitioner
No, 2725 CIVIL DIVISION of 1997
-vs-
CUSTODY
Melanie Aeppli,
Respondent
SPECIAL OBJECTIONS
NOW COMES the Petitioner Mark Aeppli by his Attorney, George M. Freed,
Esq., and files the within objections to the Order setting the pre-hearing custody
conference in the County of Cumberland,
I, At all times relevant herein both the Petitioner Mark Aeppli and the Child
Matthew Aeppli are residing at R.D, #8 Box 316 New Castle, Lawrence County,
Pennsylvania 16101
2, Petitioner returned to Lawrence County from North Dakota when
Respondent Melanie Aeppli was incarcerated,
3. Primary and legal custody of the child has been with his father Mark Aeppli
since February 1997,
4, Petitioner Mark Aeppli filed a Complaint in Custody, No, 10476 of 1997
C.A. with the Lawrence County Court on May 14th, 1997.
5, Respondent Melanie Aeppli's last known address is in Adams County.
6, Melanie Aeppli filed a Motion for Special Relief on May 22, 1997 from
Cumberland County with the Prothonotary's Office of Lawrence County.
7, Petitioner Mark Aeppli filed Objections to the Respondent's Motion for
Special Relief on May 28, 1997,
8. On May 28, 1997 the Honorable Dominick Motto Judge in Lawrence
County issued a stay and set a hearing in this matter for June 26, 1997.
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MELANIE ANN AEPPLI,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
MARK ALAN AEPPLI,
DEFENDANT
97-2725 CIVIL TERM
ORDER OF SPECIAL RELIEF
AND NOW, this 22nd day of May, 1997, upon representation by plaintiff that
other than for the last month she had lived in Cumberland County with her son
Matthew D. Aeppli, since he was bom on December 18, 1994, Jurisdiction in this
custody case thus being in Cumberland County, the following order of special relief is
entered:
(1) Temporary physical custody of Matthew D. Aeppli, bom December 18,
1994, shall be with his mother Melanie A. Aeppli.
(2) The father, Mark A. Aeppli, shall have visitation with his son as agreed to
by the parties. If there is no agreement, the father may petition this court for an
amendment of this order of special relief pending conciliation.
(3) The Court Administrator shall assign the mother's custody complaint to
conciliation,
By the Court, 1
;' 7
/
Conti
D.) Mark Alan Aeppli has taken knifes and held them to his
wrist and threaten to slash them in front of said minor
children Matthew Aeppli and Brittnany Sampson . His
mental state is not good. Mark Aeppli would come home
at two in the morning and flip on the lights and start
screaming acting like a maniac wake the children up and
take his anger out on anyone in sight.
E.) Mark Aeppli has no job and is living at home with his
parents who take care of said minor child most of the
time. They are older and not able to due to the fact
they have there own lives and travel alot.
Plaintiff is in fear for said Minor child Matthew D. Aeppli
due to the fact of no contact and the sexual abuse against
Step - Daughter Brittnany D. Sampson and also the allegation
of sexual abuse of Matthew D. Aeppli. Due to fact there is
mental unstibility and the fact that he has used alchol in
the past.
Also Mark Alan Aeppli has warrants out of four District
Justices offices which are:
A.) District Justice Days office
B.) District Justice Correals office
C.) District Justice Manloves office
D.) District Justice Howes office
because these all are misdeminors and he lives so far away
and they all are under the amount of $ 500.00 they are not
activley arresting the defendant.
Your Honor I'm pleading with you to grant my request
for Temporary Custody till the defendant deals with all
his legal issues and gets some help. I fear for my childs
life. And I'm asking that his visits be supervised by Child
and youth in Cumberland County so that these issues can be
dealt with and the court can see who will be the better
parent for long term.
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Conti
D.) Mark Alan Aeppli has taken knifes and held them to his
wrist and threaten to slash them in front of said minor
children Matthew Aeppli and Brittnany Sampson . His
mental state is not good. Mark Aeppli would come home
at two in the morning and flip on the lights and start
screaming acting like a maniac wake the children up and
take his anger out on anyone in sight.
E.) Mark Aeppli has no job and is living at home with his
parents who take care of said minor child most of the
time. They are older and not able to due to the fact
they have there own lives and travel alot.
Plaintiff is in fear for said Minor child Matthew D. Aeppli
due to the fact of no contact and the sexual abuse against
Step - Daughter Brittnany D. Sampson and also the allegation
of sexual abuse of Matthew D. Aeppli. Due to fact there is
mental unstibility and the fact that he has used alchol in
the past.
Also Mark Alan Aeppli has warrants out of four District
Justices offices which are:
A.) District Justice Days office
B.) District Justice Correals office
C.) District Justice Manloves office
D.) District Justice Howes office
because these all are misdeminors and he lives so far away
and they all are under the amount of $ 500.00 they are not
activley arresting the defendant.
Your Honor I'm pleading with you to grant my request
for Temporary Custody till the defendant deals with all
his legal issues and gets some help. 1 fear for my childs
life. And I'm asking that his visits be supervised by Child
and youth in Cumberland County so that these issues can be
dealt with and the court can see who will be the better
parent for long term.
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MELANIE ANN AEPPLI
Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
MARK ALAN AEPPLI,
Defendant
97-2725 CIVIL TERM
MODIFICATION OF PETITION FOR SPECIAL RELIEF
AND NOW comes Melanie Ann Aeppli, by and through her
attorneys, Griffie and Associates, to seek modification to the
Order for special relief dated May 22, 1997, by the Honorable
Edgar B. Bayley, and in support thereof avers the following:
1. Based upon the prior Petition filed by the Plaintiff on
or about May 22, 1997, an Order of Special Relief was entered
placing temporary physical custody of Matthew D. Aeppli with his
mother, Plaintiff, Melanie A. Aeppli; a copy of said Order
attached hereto and incorporated herein by reference as "Exhibit
All.
2. Defendant Mark A. Aeppli is an adult
individual
currently residing at R.D. #3, 319 Fording Road, New Castle,
Lawrence County, Pennsylvania.
3. When the Pennsylvania State Police served Defendant with
the Order of Special Relief, Mr. Aeppli refused to turn the child
over to the custody of the Pennsylvania State POlice, or to
Plaintiff, Melanie A. Aeppli.
4.
The
current Order of special Relief
does
not
specifically order or direct the local police (of appropriate
jurisdiction) or the Pennsylvania State Police to remove the
minor child, Matthew D. Aeppli from the custody of Mark Alan
~
Aeppli or any other individual with whom the child may be found
and return said child to the custody of Plaintiff, Melanie A.
Aeppli.
5. Because of the lack of that paragraph in the Order, the
child remains in the physical custody of Defendant, Mark A.
Aeppli, who has a history of abuse.
6. The child is and will continue to be in danger for his
welfare and well-being as long as he is in Defendant's physical
custody.
WHEREFORE Petitioner requests this Honorable Court to modify
the Order of special Relief incorporating in said Order that the
local police of appropriate jurisdiction and/or the Pennsylvania
state Police where the child, Matthew D. Aeppli, is currently
residing are hereby ordered and directed to remove said child,
Matthew D. Aeppli, from the custody of Mark Alan Aeppli or the
custody of any other individual with whom said child is staying,
and return the child to the custody of his mother Melanie A.
Aeppli on receipt of this Order of Special Relief.
RESPECTFULLY SUBMITTED,
/,
Anne M. Shepard Esquir
Attorney for Plaintiff
Griffie and Associates
200 North Hanover st.
carlisle, PA 17013
(717) 243-5551
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
:CUHBERLAND COUNTY, PENNSYLVANIA
.
.
V
* Mal''L A \0\1 Aq:p\ \
Defendant
:CIVIL ACTION - LAr.,
~No.crl6S CIVIL
:CUSTODY/VISI-TATION
19Cf'1
"
ORDER OF COURT
AND NOW, this (date)S/?)J,cIl, upon consideration of the
attached complaint, it is hereby directed that tpe arties and
their respective counsel appear bee ,re ;...) S, '- (1'..
the concil,iator, at ,~C \".] l', "
on the ~ day of \oJI'-.1 , 19 -, , a
A,M.., for a Prehearing Custddy 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 temporazy order. Either
party may bring the child who is the subject of this custody
action to the conference, but the child/children's attendance is
not mandatozy. Failure to appear at the conference 'may provide
grounds for entry of a temporazy or permanent order.
. ,
FOR THE COURT:
By: rf-s-OJ. ,Ii\. ~ '_~"u ndC\..~ ~
' Custody Conciliator UJC~.)
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, FOURTH FLOOR
CARLISLE PA 17013
(717 )240-6200
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MAY 2 2 19Q7DY
PETITION FOR SPECIAL RELIEF
Pia inti ff:
Melanie Ann Aeppli
vs.
Defendant:
Mark Alan Aeppli
County of:
Cumberland
Ref: Special Relief for Temporary Custody of Minor Child
Matthew David Aeppli OOB: 12/18/94
'.
Your Honor on this day May 22cd, 1997, I'm asking the
court to return my biologal son Matthew David Aeppli, born
December 18th, 1994 at Carlisle Hospital. His biologcial
father Mark Alan Aeppli who resides at r.d.03 319 Fording
Road, New Castle, Pa 16101 took said child and won't let
Melanie Aeppli have any contact at all.
Plaintiff who resides at 37 West Middle Street, Gettys-
burg, Pa 17325 as of now. Before that Plaintiff lived at
118 Peach Lane, Carlisle,Pa 1994-1995 . Also at 30 Sheryl Dr
Newville, Pa 17012 1995-1996. At Carlisle Domestic Violence
Shelter 1997. The said Minor Child resided at these addresse
too.
These, are the facts true to my belief:
A.) Mark Alan Aeppli has been and is still being invest-
gated for child sexual abuse and molestation which has
been in fact proven that Defendant did indeed touch
said Minor Step-Child Brittnany Dawn Sampson and Beat
and Shake and Mentally Abuse Brittnany Sampson.
B.) Brittnany Dawn Sampson has alleged that Mark A. Aeppli
did touch and fondled her brother Matthew David Aeppli.
C.) Mark A. Aeppli has a history of Domestic Violence to
his family including wife and children. Which includes
Slaming Mathhew Down on the bed calling him a little
Bastard and little fucker. Taking Brittnany shaking
by her hair and slaping her calling her a little bitch
and telling her hes glad she is not his real child. Sh~
should die.
.
Conti
D.) Mark Alan Aeppli ~as taken knifes and held them to his
wrist and threaten to slash them in front of said minor
children Matthew Aeppli and Brittnany Sampson . His
mental state is not good. Mark Aeppli would come home
at two in the morning and flip on the lights and start
screaming acting like a maniac wake the children up and
take his anger out on anyone in sight.
E.) Mark Aeppli has no job and is living at home with his
parents who take care of said minor child most of the
time. They are older and not able to due to the fact
they have there own lives and travel alot.
Plaintiff is in fear for said Minor child Matthew D. Aeppli
due to the fact of no contact and the sexual abuse against
Step - Daughter Brittnany D. Sampson and also the allegation
of sexual abuse of Matthew D. Aeppli. Due to fact there is
mental unstibility and the fact that he has used alchol in
the past.
Also Mark Alan Aeppli has warrants out of four District
Justices offices which are:
A.) District Justice Days office
B.) District Justice Correa Is office
C.) District Justice Manloves office
D.) District Justice Howes office
because these all are misdeminors and he lives so far away
and they all are under the amount of $ 50D.00 they are not
activley arresting the defendant.
Your Honor I'm pleading with you to grant my request
for Temporary Custody till the defendant deals with all
his legal issues and gets some help. I fear for my childs
life. And I'm asking that his visits be supervised by Child
and youth in Cumberland County so that these issues can be
dealt with and the court can see who will be the better
parent for long term.
~~~ 9~1i O~~~J.~
..---
@MAY 2 7 1997
MELANIE ANN AEPPLI,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNlY, PENNSYLVANIA
V.
MARK ALAN AEPPLI,
DEFENDANT
97-2725 CIVIL TERM
ORDER OF SPECIAL RELIEF
AND NOW, this 22nd day of May, 1997, upon representation by plaintiff that
other than for 'l~e I~st month she had lived in Cumberland County with her son
Matthew D, Aeppli, since he was bom on December 18, 1994, jurisdiction in this
custody case thus being in Cumberland County, the following order of special relief i!;
entered:
(1) Temporary physical custody of Matthew D. Aeppli, bom December 18.
1994, shall be with his mother Melanie A. Aeppli,
(2) The father, Mark A. Aeppli, shall have visitation with his son as agreed to
by the parties. If there is no agreement, the father may petition this court for an
amendment of this order of special relief pending conciliation.
(3) The Court Administrator shall assign the mother's custody complaint to
conciliOltion.
/