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HomeMy WebLinkAbout01-04591P f - ~ LISA 7. SCHAPPELL IN THE COURT OF CONIMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. MITCHELL E. SCHAPPELL DEFENDANT 01-4591 CML ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Tuesday, September 04, 2001 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. ,the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, September 13, 2001 at 8:30 a.m. for aPie-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/ Dawn S Sunday Esc 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. A11 an-angements 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717)249-3166 r - ' y ~'~ ~~SI 1 ~r,~,~,r,,^ _ u, a:~~ ^r,~,~ ;., ,,. ;' ;.. _, -- ,,; ..,;_ ~ :a;akr=,~ w. a, r v~-a= x-r'V"~ c~~.,v_R.rrmr w w ~m~+s~'~n~+q ~~~ ~ ~ 2001 LISA J. SCHAPPELL, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW MITCHELL E. SCHAPPELL, Defendant :CUSTODY N0. QI- ~,/S~/ ~~~,~~ ORDER OF COURT And now, this day of , 2001, upon consideration of the attached complaint, it is hereby directed that the above parties and their respective counsel appear before Esquire, the Conciliator, at Pennsylvania, on the day of 2001, at A.M./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 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 be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary Or permanent order. FOR THE COURT: Custody Conciliator YOU SHOULD TAKE THIS APPEAR 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 2493166 (800) 990.9108 ...,~ LISA !. SCHAPPELL, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW MITCHELL E. SCHAPPELL, Defendant :CUSTODY NO. CUSTODY COMPLAINT AND NOW, comes Plaintiff, Lisa J. Schappell, through his attorney, the Law Office of Darrell C. Deth{efs, and avers the following: 1. Plaintiff is Lisa J. Schappell, an adult individual with a residence located at 234 East Mulberry Avenue, Carlisle, Pennsylvania 17013. 2. The Defendant is Mitchell E. Schappell, an adult individual with a residence located at 1160 Harrisburg Pike, Carlisle, Pennsylvania 17013. 3. Plaintiff seeks primary physical and joint legal custody of Amanda Schappell, born 12/7/83, Alesha Schappell, born 9/28/88,and Ariel Schappell, born 12110/91, (hereinafter known as Children). 4. Plaintiff, Lisa J. Schappell, and Defendant, Mitchell E. Schappell are married. Alesha Schappell and Ariel Schappell were born during the marriage. 5. Plaintiff and Defendant are the natural parents of the children. 6. Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth. 7. The best interests and permanent welfare of the children will be served by granting the relief requested because the Plaintiff is better able to provide a stable, secure environment in which to raise the children. 8. Plaintiff is requesting joint legal custody and primary physical custody of the children. 9. Neither party hereto are members of the Armed Forces of the United States or any of its allies. WHEREFORE, Plaintiff respectfully requests this Court to grant joint legal custody and primary physical custody of the children and the right of first refusal for child care to Plaintiff. Respectfully Submitted, Date: ~ ~ Mic~el ykosh Attorney .D. 58851 3805 Market Street Camp Hill, PA 17011 (717) 975-9446 -~m~ LISA J. SCHAPPELL, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW MITCHELL E. SCHAPPELL, Defendant :CUSTODY N0. I hereby verify that the statements of fact made in the foregoing Petition for Custody, are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa C. S. Section 4904, relating to unsworn falsification to authorities. Date: ~-1~- ~~ /~. ~~~~U ~~~ (~is~a~Sc pp ~' .. , - . LAW OFFICE OF DARRELL C. DETHLEFS Darrell C. Dethlefs* Michael J. Pykosh* 3805 Market Stree[ Brian K. Zenner Camp Hill, PA 17011 Phone: (717) 975-9446 Fax: (717) 975-2309 E-mail: DDethlefs@aol.com Web Site: http://www.lawyers.com/dethlefslawoffice Legal Assistants Sherry L. Deckman* •Licensed PA Title Agents July 25, 2001 Prothonotary ;- Court of Common Pleas Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Re: Schapell v. Schapell Custody Matter To the Prothonotary: Enclosed please find an original and two copies of a Complaint relative to the above. Please note that Mrs. Schapell was a referral to me from Mid-Penn Legal Services. I have enclosed a copy of the letter dated July 12, 2001 from Dru Hewitt. It is my understanding that there will be no charge for the filing of this Complaint as the same is a pro-bono referral. Please forward the extra time-stamped copies to my attention in the self-addressed envelope provided herein. Should you have any questions, please do not hesitate to contact me. Very truly yours, %, !~ Michael J. ykosh MJP/rss Enclosure Mailing Address: P.O. Box 368, Camp Hill, PA 17001-0368 t=i1.E•tvo:5£5 07/12 'Ol 1548 ID~f1PLS CARLISLE OFFICE FA%~7172438O26 PAGE 2 ~~~~~1 Midl'enn Legal Services 8 1»Vine Raw, i"nrlisle, I'A t70I~ Phone 717-243-9406 I-BUU-H22-5288 PAX 717-243-AU26 ]uly !2, 2001 Michael Pykosh, Esquire I.aw Offices of Darrell i5ethlefs 3803 Market Street Camp Hiil, 1'A 17001 Dear Mr. Pykosh: We wish to refer a case involving Lisa J, Schappell. She is a conflict for our office and is in need of assistance with a custody matter, The father, Mitchell Schappeil, is denying her contact with her children. Wease let us know as soon as possible if you can take thls case, Thank you for your Cooperation in making the pm bnrw system a success, Sincerely, LLGAL SERVICES, INC, 17ru Hewitt Private Bar Coordinator DH: sw Il~~ ~~~ tip-/ v C ~ ~' ~ x. ~. ~ ~=~ -_ Z E- rn~; ~ " T:i ~ ~ O C rv "' r' ~' Z _ i0 ~ LAW OFFICE OF DARRELL C. DETHLEFS By: Michael 7. Pykosh, Esquire Attorney Identification No. 58851 3805 Market Street Camp Hill, PA 17011 (717) 975-9446 LISA J. SCHAPPELL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA C1VII. ACTI~OjN -LAW . NO. ~ l~ l ~~' v. MITCHELL E. SCHAPPELL, Defendant PRAECIPE To the Prothonotary: Please forward the Complaint, which I filed on behalf of Lisa Schappell to a Custody Conciliator. This matter was referred to me as a pro bono case by Mid-Penn Legal Services. Therefore, there was no filing fee forwarded to my attention by my office. Respectfully Submitted, Date:~~ O By:~ ~~G%' Michael J. Pykosh, Esquire LAW OFFICE OF DARRELL C. DETHI.EFS Darrell C. Dethlefs* Michael J. Pykosh* 3805 Market S[reet Brian K. Zellner Camp Hill, PA 17011 Phone: (717) 975-9446 Fax: (717) 975-2309 E-mail: DDethlefs@aol.com Web Site: http://www.lawyers.com/dethlefslawoffice Leeal Assistants Sheny L. Deckman* •Licensed PA Title Agents October 1,2001 Office of the Prothonotary Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Re: Schappell v. Schappell Custody Nfatter, No. 01591 To the Prothonotary: Please mark the above-captioned matter withdrawn. Very truly you , Michael J. Pykosh MJPlrss cc: Mitchell E. Schappell Dawn Sunday, Esquire Mailing Address: P.O. Box 368, Camp Hill, PA 17001-0368 {'... _ _' - ~wryamx+~,sxr~x+~ ,... _ ~.. ~mz~.., ... ._.... i'::x>~waz w_;n~^»3$-"fit st:Lk~.kraa^'~7,h`iE~sS~273 OC~p 112001 LISA J. SCHAPPELL, Plaintiff vs. MITCHELL E. SCHAPPELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4591 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 3`a day of October, 2001, the Conciliator, being advised by Plaintiff's counsel that the parties have reconciled, hereby relinquishes jurisdiction in this case. The Custody Conciliation Conference scheduled for October 4, 2001 is canceled. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator ~~ iJ C3 ' 'r1 G- •..-~ ..~ i'S'~f'' "-6 -r- h -A G~, ~,+ ~ _ 3~ c~ { ices , _ ~L'' ~ _ a ~~-1 ~.. 3> G ~ ==~ ~S ~~