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HomeMy WebLinkAbout97-02725 ~ . -::: ;:: " ~ o -:::; I I I I i ! , i i , \ '. "'" "- \ \ /' / ' ( ! 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 (~ If:> (') r::. -J '0 t 'ttt. .-. : . .-,in ~ I ~ .; ~ , ",) -11"":1 2 r...1 -:e' \:.' !6 .- b r:..., ~ -,.' 11 :-. '." ~ ~'~ : ..- . ~ (") )iB , : .:' ~ ~ ~'1 'I) ~ (,oJ '< ~ 'it 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 n .<:' n c -J -n "0 ! -rjl ~... , ~ ~ '. "1 ~~; '. -...,; ,It";." "J -l'-n ~ 1''0.) ,0 \.'.'. :;(1 ~ -. I.~~'- -l" "'J t.., '}p, .' _,.C' ~ " . ''',' ~; ,:)1'11 , :;... L ~-:-l 9.J " :...r1 ii . -< w f '\) ~ ~ 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 ..~q~.~t'. '~"" JI.q ~Jf1. ~Q#.... to..o...........f... 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, (") ..n 0 ~ -I -,1 ~ -;-.; '--.f c;J ~ r,'l: ...: :~ :-n ~ -. - "r" :'V H-rn ~ U? N '9 f:; ':~o .',~, lo-n ~'. '-n ~ -- -,-- "" " ...("J , ;:; :jI1' 9.J ~ ~';. . . --, ~ "::;. VI .- ::0 l::l -< ~ ~ ~ ~ ~ ~ . ~ '" (', \ iY-: - , , ~ '. ~ 'I. : ". '~ " ,. -'. ~ t " ". - ~ c;, , .-~ ". . . l'_~ "'.', : ';', \,; L, .~ - :.1.. r:t" " (. ' . (.;~ " . 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 ~ ~... ~ "'" r-- 0- N' ..sl q ~ - - t i\~ >- Cl ;~ ~~ a; i-." '.:: ~ . tuf.... ~ ~;.~ ~ <.)~.. .' :_~: rE- '." .-. ":--j 0 y; "I . (;) C'), '_'l W' N J:'~ ~ ... > L:" ., '~'J ~ , .u... " I,'. r- ::i '-, (I' U . { 1 ~ .. '.:'J ~ ~ (;': . , !~. " ~ '.;:. ~ \l<l ::= : ~ ~ 1..1 ~ ~ .. : ; ..../ ~ ~ :~i: " ~ ,~ . lJ ~ "" , .~ , I, c: .:' l.; (..J' U 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 ""oIIt ~ J r- ~ l'/') ....g ~ - .... f ~ ":fl. i~: (Xl - ~ { i.-: <:: ;.~ . l~~ '-, ... ~ 11f. ) '-;:. I )- /U . :( C.. > (~) ; i :,~l ~ t' , ".. ~,o. C. (''\1 ." t'.l '::> "1' N ~ t.:.1o .'," !rt1 . .; .'c.\.. ~ I ",. ..- u. ,.... -i U 0' 0 . @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 >- \0 ~ u; ..:r .., ~, s..'( I~ .. ("", - I;.)..;; 1 Ll.::--. (-dC- :c :';-:'l (J:;i.- '-'- -'::1 9f .,.:~- '" ;~~~~ ~~ ._;z ":"-:'l' ;::,. ;h1!1 lJ..'f' e ':la. r:', ..; - -<, ". r- 'J e- Ol b 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. ~ C"l -- t~ u: [-. c- , I.:: .. ~t: wi;'") C.~ (.).' ,~" , ~I ;~: {'C' Ci.: '-;) ~:' I' I ~ '.- It~. .:r ."in N --:'-:.-" -JU! -' !1.'(.b Li'"l" ::.> !.:";1.J- I":: -, ~ ,... 5 C'I 0 I 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. -~~~~~ 9~~i (\~'?~~' 7f7- 334- qg~, - ~ ~ ~ "* ~ ~ ~i "- ~ :':h 11') ,.. ~ ;~'; C.: r' o. "- Lt... -. , -;' t: ~ "I:':;: ~ 4..... ..:. ~ c, ':__i "0 >0 C'; "I . ~ <:> . IJ...... ("J 'I: ~ 10 ~ cC' . :.. \0 ." . .~~ j, :Q ~ ,", '" ..2. 'i'I= Q r.. , ~ (J @ J- . ~, Eo ~ . ~ } >- l() I ~; c: ?:: I I' 11.I~:: S .' I ("...' ' ) ." .-"l ... I)' . H--: . - '~i ;~~ ! ~(- oot;: <).--, . I Ct:. .. :;..~ l1J " I (~ -' ' . LC" L'~ ;,,'. '. ----, 1"- :':;J j~? LL ....4- ..:! U r- ::'> cr U I 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. '~~~9~n ()~V~,,~ 717- 33'-/- qgJ..' - .. ... 2; ..... ca. -UJ OUJ "a: .~ I>> ~ =:1 -....... o '~lilJ~ ~ ~ ;~~'([~Q , ~~I o~8'f!t - ~~~<i' 'J,,~~Q~ ~ <--C I\r1 ~I/!):I " / ~o ........ ~ <'J '---- \"\, " ~ ~ V) ..... ~~~ -::!t: 'U - o vi \-li- <:"-..c !1 J - o ~ r::::t: c::J~8 ~ ~ ~~ \3 ^~ ! ~ ..~~ ........ 'f1 .!ir~ ~ ~.~ ~s rt1 --L V) ~ ~ 6 ~-L- ' ~ d+~ d ~ \ CV) ~ ~ ~ ~ ~ ~ ~ ~ -, 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 ~ .... :::: i.~ U~ 'C .. , ~ t~ (~-: ,.....,. ut~ ' -.).... 0- ':': " , ..... If' 'I~ . :1 '-'- O~ . ';- r-' -',I) t. 'I~; f:2i, N ~_. Ii. :- ,-'in r' i 1, ...t ..'!~ .. ~.: ~) to, ,- U '" U . * Me\D()\ e.. A0.1\ t\e~p\ i 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 ~ .sa ~ "* ~ ~ ~~ "- ~ >- VI c; ~ .~ c: -, .... . lU(" .. - I ..~ ',.I- - " '~. G:' " ~ "- "';" ";:.. ~ u~ ,- -0 i:J <> {.r. "J , <;:) "" . IJ;:""': ('''''' . , ~ J-, !:j. \t) ~ r," l ~.- \0 '.' .'- .... j:: :.~:: <::J ~ ", .- :. Ifj_ 19= 0 r, , 01 (.) \ , 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. /