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HomeMy WebLinkAbout07-1382db. ROBIN C. SCHEID, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2007. ) 3 ?2 CIVIL TERM RUSSELL F. SCHEID, III, Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Robin C. Scheid, by her attorneys, Irwin & McKnight, and presents the following Complaint for Custody. 1. The Plaintiff, Robin C. Scheid, is an adult individual with an address of 17 West Mulberry Hill Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, Russell F. Scheid, III, is an adult individual with an address of 17 West Mulberry Hill Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of two (2) children, namely, Levi T. Scheid, born September 9, 1996, and Nolen T. Scheid, born February 23, 1998. I W. 4. The Plaintiff, Robin C. Scheid, desires that the parties have shared legal custody of the minor children, Levi T. Scheid and Nolen T. Scheid. 5. The Plaintiff, Robin C. Scheid, desires primary physical custody of the said minor children with periods of temporary physical custody to Defendant, Russell F. Scheid, III, as the parties can agree. 6. The best interests and permanent welfare of the minor child requires that the Court grant the Plaintiff's request as set forth above. WHEREFORE, the Plaintiff, Robin C. Scheid, respectfully requests that he be awarded primary physical custody and shared legal custody of Levi T. Scheid and Nolen T. Scheid as provided herein, with periods of temporary physical custody to Defendant, Russell F. Scheid, III as provided herein. Respectfully submitted, IRWIN & By: Marcu A. ight, Esquii Attorne r Plaintiff 60 W t Pomfret Street Carlis Pennsylvania 17 -3222 (717) 24 - Supreme Court I. D. No. 25476 Date: March 9, 2007 VERIFICATION The foregoing Complaint for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. //? 4 4, ; 2? a &? ROBIN C. SCHEID Date: March 9, 2007 a C> ?- W a S? A _s ROBIN C. SCHEID IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. RUSSELL F. SCHEID, III DEFENDANT 07-1382 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, March 19, 2007 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, April 19, 2007 at 10:30 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 all 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/ Hubert X. Gilroy, Es q. j,A 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 -vw WA I APR If inn? PV ROBIN C. SCHEID, Plaintiff v RUSSELL F. SCHEID, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-1382 IN CUSTODY COURT ORDER AND NOW, this 1 1?, day of April, 2007, upon consideration of the attached Custody Conciliation report, and it appearing that the Defendant has not advanced any objection to this Court exercising jurisdiction over the parties and the minor children on the custody issue, the following Order entered: 1. In light of the fact that both parents are still living together, the Court declines to issue a specific Custody Order. 2. It is directed that neither party shall relocate the children from the marital home absence an agreement of the parties on custody or a Court Order on custody. In the event one party decides to relocate, counsel for the parties may contact the Custody Conciliator directly to schedule an expedited Custody Conciliation Conference. BY THE COURT, 1* Judge --? ??A cc: Marcus A. McKnight, II, Esquire Joanne Harrison Clough, Esquire y' J1-d s ur J 4' `a 4 I -% ROBIN C. SCHEID, Plaintiff v RUSSELL F. SCHEID, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-1382 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Levi T. Scheid, born September 9,1996 and Nolen T. Scheid, born February 23,1998. 2. A Conciliation Conference was held on April 12, 2007, at which time the Conciliator spoke with Attorney's Marcus McKnight, II and Joanne Harrison Clough who represent the parties. Based upon that discussion, the Conciliator recommends an Order in the form as attached. DATE Hubert X. Gil y, Esquire Custody C ciliator ROBIN C. SCHEID, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2007 -1382 CIVIL TERM E ° RUSSELL F. SCHEID, III, Defendant IN CUSTODY 5 C, z PETITION FOR MODIFICATION OF CUSTODY rv cn w AND NOW comes the Plaintiff, Robin C. Scheid, by her attorneys, Irwin & McKnight, P.C., and presents the following Petition for Modification of Custody. 1. The Plaintiff, Robin C. Scheid, is an adult individual with an address of 17 West Mulberry Hill Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, Russell F. Scheid, III, is an adult individual who has been transferred on January 4, 2010, to work for Excel, Inc., in Fayetteville, North Carolina. 3. The parties are the natural parents of two (2) children, namely, Levi T. Scheid, born September 9, 1996, and Nolen T. Scheid, born February 23, 1998. 4. The parties are governed by an Order of Court dated April 17, 2007, a copy of which is attached hereto and made a part of this Petition. 5. The Plaintiff, Robin C. Scheid, desires that the parties have shared legal custody of the minor children, Levi T. Scheid and Nolen T. Scheid. 6. The Plaintiff, Robin C. Scheid, desires primary physical custody of the said minor children with periods of temporary physical custody to Defendant, Russell F. Scheid, III, as the parties can agree. :$,to• oO P p RYH cc-* (0319 vt431a10i 3 7. The children need to complete the school years and adjust to the separation of their parents. They want to remain as residents of Cumberland County, Pennsylvania and in the Cumberland Valley School District. 8. The best interests and permanent welfare of the minor child requires that the Court grant the Plaintiff's request as set forth above. WHEREFORE, the Plaintiff, Robin C. Scheid, respectfully requests that he be awarded primary physical custody and shared legal custody of Levi T. Scheid and Nolen T. Scheid as provided herein, with periods of temporary physical custody to Defendant, Russell F. Scheid, III as provided herein. By: Date: February 4, 2010 Respectfully submitted, IRWIN & McKNIGHT, P.C. Marcus Al. McKni"t III, Esquire Attorney for Plaintiff 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court I. D. No. 25476 4 1 APR 1 6 2002M? ROBIN C. SCHEID, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW RUSSELL F. SCHEID, III, : NO. 07-1382 Defendant : IN CUSTODY COURT ORDER AND NOW, this 17 el day of April, 2007, upon consideration of the attached Custody Conciliation report, and it appearing that the Defendant has not advanced any objection to this Court exercising jurisdiction over the parties and the minor children on the custody issue, the following Order entered: 1. In light of the fact that both parents are still living together, the Court declines to issue a specific Custody Order. 2. It is directed that neither party shall relocate the children from the marital home absence an agreement of the parties on custody or a Court Order on custody. In the event one party decides to relocate, counsel for the parties may contact the Custody Conciliator directly to schedule an expedited Custody Conciliation Conference. BY THE COURT, is/ -A ' ?4 1_ Judge cc: Marcus A. McKnight, II, Esquire Joanne Harrison Clough, Esquire 11S431VII NOR 18 2007 IIZWIN & McKNIGHT TRUE OD" FROM RECOM of cow PA. am court At . PmthnnnMr? ROBIN C. SCHEID, Plaintiff v RUSSELL F. SCHEID, III, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-1382 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Levi T. Scheid, born September 9,1996 and Nolen T. Scheid, born February 23,1998. 2. A Conciliation Conference was held on April 12, 2007, at which time the Conciliator spoke with Attorney's Marcus McKnight, II and Joanne Harrison Clough who represent the parties. Based upon that discussion, the Conciliator recommends an Order in the form as attached. ce-- (3, a"? DATE l y, Esquire Hubert X;c-iliator Custody APR 16 200744j ROBIN C. SCHEID, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW RUSSELL F. SCHEID, III, : NO. 07-1382 Defendant : IN CUSTODY COURT ORDER AND NOW, this / 7 16, day of April, 2007, upon consideration of the attached Custody Conciliation report, and it appearing that the Defendant has not advanced any objection to this Court exercising jurisdiction over the parties and the minor children on the custody issue, the following Order entered: 1. In light of the fact that both parents are still living together, the Court declines to issue a specific Custody Order. 2. It is directed that neither party shall relocate the children from the marital home absence an agreement of the parties on custody or a Court Order on custody. In the event one party decides to relocate, counsel for the parties may contact the Custody Conciliator directly to schedule an expedited Custody Conciliation Conference. BY THE COURT, /'/ -"ht? Judge cc: Marcus A. McKnight, II, Esquire Joanne Harrison Clough, Esquire ARR 18 2007 tRWIN 8z, WK.NIGT 4'x'3" FROM MUM w, ' m ow ot am court tom, Ft do GLe2mil"Id Pm+hrr ROBIN C. SCHEID, Plaintiff v RUSSELL F. SCHEID, III, Defendant t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-1382 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Levi T. Scheid, born September 9,1996 and Nolen T. Scheid, born February 23,1998. 2. A Conciliation Conference was held on April 12, 2007, at which time the Conciliator spoke with Attorney's Marcus McKnight, II and Joanne Harrison Clough who represent the parties. Based upon that discussion, the Conciliator recommends an Order in the form as attached. (6_ (3- ?,e? DATE Hubert X. l Esquire Custody APR 16 200744 ROBIN C. SCHEID, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW RUSSELL F. SCHEID, III, : NO. 07-1382 Defendant : IN CUSTODY COURT ORDER AND NOW, this f 7 ell day of April, 2007, upon consideration of the attached Custody Conciliation report, and it appearing that the Defendant has not advanced any objection to this Court exercising jurisdiction over the parties and the minor children on the custody issue, the following Order entered: 1. In light of the fact that both parents are still living together, the Court declines to issue a specific Custody Order. 2. It is directed that neither party shall relocate the children from the marital home absence an agreement of the parties on custody or a Court Order on custody. In the event one party decides to relocate, counsel for the parties may contact the Custody Conciliator directly to schedule an expedited Custody Conciliation Conference. BY THE COURT, Judge cc: Marcus A. McKnight, II, Esquire Joanne Harrison Clough, Esquire APR 18 200 mwiN & McKNIG T "W E G PY FROM Rill M 'Immabomm AL ?_. aM. ROBIN C. SCHEID, Plaintiff v RUSSELL F. SCHEID, III, Defendant k : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-1382 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Levi T. Scheid, born September 9,1996 and Nolen T. Scheid, born February 23,1998. 2. A Conciliation Conference was held on April 12, 2007, at which time the Conciliator spoke with Attorney's Marcus McKnight, II and Joanne Harrison Clough who represent the parties. Based upon that discussion, the Conciliator recommends an Order in the form as attached. y-- (3, G-? DATE Esquire Hubert X. =iliyator Custody VERIFICATION The foregoing document is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unworn falsification to authorities. ROBIN C. SCHEID Date: FEBRUARY 4, 2010 ROBIN C. SCHEID, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2007 -1382 CIVIL TERM RUSSELL F. SCHEID, III, Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached document was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Jordan D. Cunningham, Esq. Cunningham & Chernicoff, P.C. P. O. Box 60457 Harrisburg, PA 17106-0457 IRWIN & McEMGHT, P.C. By: Marcus A. Mc gh , III, Esquire 60 West Po eet Carlisle, PA 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Date: February 4, 2010 5 ROBIN C. SCHEID IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2007-1382 CIVIL ACTION LAW RUSSELL F. SCHEID, III IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, _ Monday, February 08, 2010 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, March 12, 2010 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. 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 all 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/ Hubert X. Gilro Es _ 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 RB)-C''FFiCE OF IT PROW 10TARY 2010 FEB -8 Pty 3: 48 I 1j Nly PE: IN's N A /o 4 ROBIN C. SCHEID, Plaintiff vs. RUSSELL F. SCHEID, III, Defendant PRIOR JUDGE: The Honorable M. L. Ebert MAR .i 0 Z010 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW n Q NO. 2007-1382 IN CUSTODY COURT ORDER NOW, this day of March , 2010, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The mother, Robin C. Scheid, and the father, Russel F. Scheid, III, shall enjoy shared legal custody of Levi T. Scheid, born September 9, 1996, and Nolen T. Scheid, born Febraury 23, 1998. 2. The mother shall enjoy primary physical custody of the minor children. 3. The father shall enjoy liberal periods of temporary custody of the minor children as follows: A. On alternating weekends from Friday evening through Monday morning. B. At such other times as the parties agree. 4. This order is TEMPORARY in that it addresses the current living situations of the parties in light of the fact that the father's employment has required him to move to North Carolina where he is currently staying in a hotel. In the event father relocates back to Cumberland County and moves into the joint marital home, this order shall be suspended and shall revert to a shared physical custody arrangement as it was in the past. In the event the father relocates back to Cumberland County and lives in a different residence than the mother, legal counsel for the parties shall attempt to work 4 G -o o? out a satisfactory custody arrangement. If nothing can be worked out between the parties, either party may again petition the court to have the case referred to the Custody Conciliator. Additionally, in the event the father decides to relocate to North Carolina on a permanent basis, the parties shall attempt to work out a more permanent custody order and, absent an agreement, either party may request the court address this case with another Custody Conciliation Conference. 5. In the event there are any issues between the parties relative to this temporary schedule, legal counsel for the parties may contact the Custody Conciliator who may conduct another Custody Conciliation Conference via telephone with the attorneys and, as appropriate, recommend further order to this court in this case. BY THE COURT, cc: arcus A. McKnight, III, Esquire Jordan Cunningham, Esquire a//411v ?:Trn ROBIN C. SCHEID, Plaintiff VS. RUSSELL F. SCHEID, III, Defendant PRIOR JUDGE: The Honorable M. L. Ebert IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007-1382 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Levi T. Scheid, born September 9, 1996, and Nolen T. Scheid, born Febraury 23, 1998. 2. A Conciliation Conference was held on March 12, 2010, with the following individuals in attendance: The mother, Robin C. Scheid, who appeared without counsel, Marcus A. McKnight, III, Esquire, and the father, Russel F. Scheid, III, participated via telephone, with his counsel, Jordan Cunningham, Esquire. 3. The parties agree to the entry of an Order in the form as attached. Date: March 7 , 2010 L (0// Hubert X. Gil y, Esquire Custody Co iliator