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HomeMy WebLinkAbout00-08615 ""_..'..k~~'~' - "' 'l' 1- I -~-. "'-'-'~, LISA A. GLEICH SCHLAGER PLAINTIFF V, STEPHEN 1. SCHLAGER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-8615 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 19TH day of December, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Snite 105, Camp HiII, PA 17011 on the 24th day of Jannary, 2001 , at 1:00 p.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 defme 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. Fai]ure to appear at the conference may provide grounds for entry of a temporary or permanent order, FOR THE COURT, By: Isl Melissa P. Greevy. Esq.JiJ 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, AI] 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 HA VB 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 Carlis]e, Pennsylvania 17013 Telephone (717) 249-3166 .. ' / ~ .o:;tJ -C2:'? /;1- ~ -t?1' /;;l. -,;){) ',to -~ . Or r';-- 00 [Wr '0 '." -.' PN 2: n? .. C1 j;~,l"',._, Ui"li"<i.'l;' . "'-', '";.11:',',., PENI'"';;"u COUNTY V""YLVANiA ad- ~ %:Jb ~ 4X~ 71~~~4fI' ~ fr';""W -t 4' ~ -.""I"",m_.....~" _.."..,~j~,l~'~::w::::;rnIlRI;$!j'IIJIIW!~~;r'!i~.,"'.''',~~"~I.p'I,..>!!!~-"!t~~iB"f'~Ci,.,.U(-,\~,ii'iirf','i')m'i~~~j!li'j;j_~!i;tm,, 11 M , ,"",,.co, l - , -._,~)f LISA A. GLEICH SCHLAGER, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.06-f'IoJS CIVIL 2000 . . vs. STEPHEN J. SCHLAGER, Defendant . . CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, it is hereby directed that the parties and their respective counsel appear before , the Custody Conference Officer, on the day of , 2000, at .m., in Room, Cumberland County Court House, Carlisle, Pennsylvania, 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 the entry of a temporary or permanent Order. By The Court, DATED: By: Custody Conciliator 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 Court Administrator, 4th Floor 1 Courthouse Square Cumberland County Court House Carlisle, PA 17013 (717) 240-6200 , _' L "C ~~"', ,<mm",',,___ LISA A. GLEICH SCHLAGER, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.tJt)-N"fs CIVIL 2000 . . vs. STEPHEN J. SCHLAGER, Defendant : CIVIL ACTION - LAW CUSTODY 2 g <:;; <:" 0 -om (." " O1nl n ~~ Z-J1 ~,_"f.;.; COMPLAINT FOR CUSTODY :z: ~ 'G (f) ";> .t="" ',_",> ,J-, ~ ~~~ -0 :---i~:~ 1. The Plaintiff is LISA A. GLEICH SCHLAGER, res~g ~~ ~~~ >c: .. ,-\ Parkside Road, Camp Hill, Cumberland County, pennsYlvania~70~. ~ 2. The Defendant is Stephen J. Schlager, residing at 6261 Battersea Parkway, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Plaintiff seeks custody of the following child: NAME PRESENT ADDRESS Alexander Paul Schlager 428 Parks ide Road, Camp Hill, PA 17011 AGE 2 and 6261 Battersea Parkway, Mechanicsburg, PA 17050 The child was not born out of wedlock. The child is presently in the custody of both Defendant and Plaintiff who reside at their respective residences. Since birth, the child has resided with the following persons at the following addresses: PERSON ADDRESS DATE Plaintiff & Defendant 6261 Battersea Parkway, Mechanicsburg, PA 17050 10)1)98 - 7/1)00 7/1/00 - Plaintiff & Defendant 428 Parkside Road, ,I, ~I - ~~ Camp Hill, PA 17011 Present and 6261 Battersea Parkway, Mechanicsburg, PA 17050 The mother of the child, Plaintiff Lisa A. Gleich Schlager, is currently residing at 428 Parkside Road, Camp Hill, Cumberland County, Pennsylvania 17011. She is married to Defendant. The father of the child, Defendant Stephen J. Schlager, is currently residing at 6261 Battersea Parkway, Mechanicsburg, Cumberland County, Pennsylvania 17050. He is married to Plaintiff. The relationship of Plaintiff to the child is that of 4. mother. basis. 5. father. basis. 6. The Plaintiff currently resides with her son on a part time The relationship of Defendant to the child is that of The Defendant currently resides with his son on a part time Plaintiff 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. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff 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 said child. 7. The best interests and permanent welfare of the subject child will be served by granting Plaintiff primary physical custody of him because she is better able than Defendant to nurture and care for him and because also, unlike Defendant, she is able to not let the differences between her and Defendant effect the manner in which " ...1 - ,1,,- ~ ~-~-..--~ approaches Defendant's relationship with their child. 8. Each parent whose parental rights to the child has not been terminated and the persons who have physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant her custody ) of the child the subject hereof. DATED: 12/6/00 R~f:L~~ Submitted: HERSCHEL LOCK, ESQUIRE ATTORNEY FOR PLAINTIFF 3107 North Front Street Harrisburg, PA 17110 (717) 238-6661 , ~........ ,~ ........,.~ ,.~ ~ _ ~ L "",,",,'>WJ<l.t<k VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 12/6/00 ."~"~ J LJ', ," I , ~_~ ,- H"~~"" VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 12/6/00 ~i;!J~~W"-t!\""~ht!D';" ! , "-'''ir",~'~l\W;",~ ;'-":""'-"ilii!i,~'- "'ltilE~~l~,:m"'L, ", ~~ ~.lUjj! lill.il<>lIldi!;~lMW ' ,- '~milllj-jl.irtni~~ "",:'~,;";,tL,M*;;,-i';l<',",d'-:":ffi!~.&;l:J&Miiii~ J "--'~_ ,,"",- ~'~'''~;:, ~ ~ ~ 0 a ~ ',", 1l ~ c: 0 -n 7GJ s:: '-' :. ~:J h ~o ':UCG fT1 'il~ rllfTl (J 6 & Z:JJ -.--.~ "- ~ g a z~: .c- l:~9 ~-' ~~':jQ C\ :J I I !< "U ('\23 ~ ~ ~(; 3: ~70 --- P? ~ '""0 ""rfJ ~ :Pc: ~. 1- z: ':Jl ~ ~ =< (',,;) -< - :-.~' I" , '" -~....~'" FEB 06 2~ LISA A. GLEICH SCHLAGER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8615 STEPHEN J. SCHLAGER, Defendant CIVIL ACTION - LAW CUSTODY INTERIM ORDER OF COURT AND NOW, this ~ day of February, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Cl!lstody. The parties, Lisa A. Gleich Schlager and Stephen J. Schlager, shall have shared legal ~wstody of the minor Child, Alexander Paul Schlager, born October 1, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergel1cy decisions affecting the Child's general well-being including, but not I, limited to, all decisipns regarding his health, education and religion. Pursuant to the terms of Pa. C. s. 9 5309, eqch parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Physical custody for the interim shall be arranged as follows: A. Mother shall have custody on Mondays until Tuesday morning, Additionally, Mother shall have custody Tuesday through Friday mornings from 8:00 a.m. until 10:00 a.m., when she goes to work. Mother shall have custody on Tuesdays through Fridays from 4:00 p.m. until 6:00 p,m. Mother shall have custody from 10:00 a.m. each Saturday until 1 :30 p.m, each Sunday. B. Father shall have custody from Tuesday through Thursday evenings from 6:00 p.m. overnight until the following morning at 8:00 a,m.; Fridays at 6:00 p.m. until Saturdays at 10:00 a.m.; Sundays at 1 :30 p.m, until Mondays at 8:00 a.m. C. In the event that Father is out of town and therefore unable to exercise his periodS of partial custody, Mother shall have physical custody during that time. -,'-~ I~"" ' L ul ,r , '-", " 't;' . No. 00-8615 3. The parties shall participate in co-parenting counseling for a minimum of eight sessions with Jeff Verrecchio. The portion of counseling which is un-reimbursed by health insurance shall be shared equally by the parties. The parties shall proceed apace to schedule these counseling sessions. 4, In the event that the parties are not able to reach an agreement regarding a custody schedule for the minor Child, counsel for either party may request an additional Custody Conciliation Conference within sixty days of the date of this Order. J, l ~ 11 ailil 01-()~.ol ~K5 Dis!: Kathleen Carey Dilley, Esquire. 1029 Scenery Drive, Harrisburg, PA 17109 Herschel Lock, Esquire, 3107 N. Front Street, Harrisburg, PA 17110 i II " ~< 'C":FiCE . )';'I.~:_~"t, .!CHARY ()' ~r-~ J t"t::5 n -0 or, :. ~ (i;-! 9: i 0 Ct:: ~U'::I'_:: .- \'i'., "'-., L U.V.Wi... l1~F'i '1;.) \')...JUJ1JTY PENNSYLIjN~II~ ~, ,AMlf!l'I~o4If ~,~ ~,'f_Wi1lif;l'n!lj "O,""'.~""""ff~~~~:fil\';iP~~W!-~~!if!'f~MHW:~\Wl~~~I.\\'!~~~-~!~~ ,.1""" . "> ',- .1", . ~ ~.... " . j , LISA A. GLEICH SCHLAGER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8615 STEPHEN J. SCHLAGER, Defendant CIVIL ACTION - LAW 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 Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Alexander Paul Schlager October 1, 1998 Father and Mother 2. A Custody Conciliation Conference was held on January 31,2001, with the following individuals in attendance: the Mother, Lisa A. Gleich Schlager, and her counsel, Herschel Lock, Esquire; the Father, Stephen J. Schlager, and his counsel, Kathleen C. Daley, Esquire. 3. The parties reached an agreement as to an Inte im Order in the form as attached. cfJ 6: ;?en I Date