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Home My WebLink About99-06134x v' \• 4 f1 s s t ,y 4h ?d ¢ rE t`IV!`Sf F 3 x Y £ Y t?,? .??. i ? ? ? Z it 4 ?yfC.r . tN o t l t • 1 f MEN ?f I t \ ? ? ? f } " v +'r?y z Taxis}*$ ? ,,??' fl r F f ? yt j ??tLBJ ?I y?' r ? d F1Xf ` kin 2 n ? y °? v x S ' t '`?L' ,off ? f 11 f l?'?M1k ' I y 4!^?41k ? M' t f Y ~ " 1 0 4 r l' ? `? # t ` b F f? ? I, 1 \T 'AS. P s n }L j , to a w 4 01 E ¢# TAX T NOW" EI hT"? -? t s ' ' Cf «a K'??'e. dS f \ ,iS 3c z n?_y: a ry ?f 4 ? 1 1 k? fil ; > n eS iyU ?. t I nFtx ? ?7 X 1 1 ski ff Y :, t i I l ?? r tY,? ?f h 1 ? 1 T S.t Y { v L Ey { F ? _ 1,Y1?? ? ? 4 ? \( r4 V.? riw , ,`. Z1% ;V THERESA C.STOPFEL (formerly Theresa C. Keller), Plaintiff VS. DAVID E. STOPFEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99.6134 CIVIL TERM IN CUSTODY AND NOW this _?4/ day of ?) 1.(1_ , 2001, based upon the Stipulation of the parties which is attached hereto, we hereby order and decree as follows: 1. Legal custody of the minor children, Nolan M. Stopfel, born 24 June 1997, and Anna L. Stopfel, born 4 January 2000, is awarded to and shall remain in their mother, the Plaintiff, Theresa C. Stopfel. 2. Primary physical custody of the said minor children shall continue with their mother, the Plaintiff, Theresa C. Stopfel. 3. The father of the children, the Defendant, David E. Stopfel, shall have such periods of visitation or temporary custody as the parties may mutually agree. If the parties cannot agree upon arrangements for the father's visitation and temporary custody, either of them may petition the Court for the entry of an order setting a schedule for such matters. BY THE COURT, , J. DISTRIBUTION: Samuel L. Andes, Attorney for Plaintiff, 525 N. 121" Street, Lemoyne, PA 17043 f David C. Stopfel, 313 Hummel Avenue, Lemoyne, PA 17043Py h 'bo C `E ti. ?.?"-)TARY PEN,%*lsy&? Vry THERESA C.STOPFEL Iformerly Theresa C. Keller), Plaintiff VS. DAVID E. STOPFEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION • LAW NO. 99.6134 CIVIL TERM IN CUSTODY AND NOW come the above named parties, and stipulate and agree as follows: 1. Legal custody of the minor children, Nolan M. Stopfel, born 24 June 1997, and Anna L. Stopfel, born 4 January 2000, is awarded to and shall remain In their mother, the Plaintiff, Theresa C. Stopfel. 2. Primary physical custody of the said minor children shall continue with their mother, the Plaintiff, Theresa C. Stopfel. 3. The father of the children, the Defendant, David E. Stopfel, shall have such periods of visitation or temporary custody as the parties may mutually agree. If the parties cannot agree upon arrangements for the father's visitation and temporary custody, either of them may petition the Court for the entry of an order setting a schedule for such matters. The parties enter into this stipulation with the intention that it be entered as an order of court and jointly request the Court to enter such an order. IN WITNESS WHEREOF, the parties hereto have set their hands and seals this day of .4eetA 2001. Witness r ..,ti 02. Itb-pul THE ESA C. STOPFEL ss DAVID E. S PFE COMMONWEALTH OF PENNSYLVANIA 1 SS.: COUNTY OF CUMBERLAND 1 On this, the 134day of /)j-PjW, 2001, before me, the undersigned officer, personally appeared THERESA C. STOPFEL known to me for satisfactorily proven) to be the person whose name Is subscribed to the within instrument, and acknowledged that said person executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission Expires: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NOTARIAL SEAL MICHAEL. R. CARANCI, Noin Public Campp Hill Boro. Cumberland County My Commisslon Expires June 15.9M 1 SS.. 1 On this, the /3'40day of 105Aeall , 2001, before me, the undersigned officer, personally appeared DAVID E. STOPFEL known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that said person executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ?a y Commission Expires: NOTARIAL SEAL MICHAELR.CARANCI, Notary Public Camp Hill Bono. Cumberland County My .ommIzIonEmlres.tnnnt5 ?m t THERESA C. STOPFEL (formerly Theresa C. Keller), Plaintiff VS. DAVID E. STOPFEL, Defendant 1 IN THE COURT OF COMMON 1 PLEAS OF CUMBERLAND 1 COUNTY, PENNSYLVANIA 1 1 CIVIL ACTION - LAW 1 NO. 99-6134 CIVIL TERM IN CUSTODY AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and amends her original Complaint In Custody and petitions the Court for the entry of a custody order, based upon the following: 1. The Plaintiff herein is Theresa C. Stopfel, formerly Theresa C. Keller. Her name changed as a result of her marriage to the Defendant on 3 June 2000. Her address remains 1026 Swarthmore Road, New Cumberland, Pennsylvania, 17070. 2. The Defendant in this matter is still David E. Stopfel. His current address is 313 Hummel Avenue, Lemoyne, Pennsylvania, 17043. 3. The parties hereto are husband and wife and are the parents of two children born to them, Nolan M. Stopfel, born 24 June 1997, and Anna L. Stopfel, born 4 January 2000. Plaintiff seeks an award of physical and legal custody of both children. 4. Both children were born out of wedlock but were subsequently legitimatized by the marriage of Plaintiff and Defendant, who are the biological parents of both children. 5. Since the children's birth, they have resided at the following addresses with the following persons: 24 June 1997 4975 Hamilton Drive Mother and Father to April, 1998 Harrisburg, PA April, 1998, to 339 Herman Avenue Mother and Father May, 1999 Lemoyne, PA May, 1999, to 1026 Swarthmore Road Mother and Father 12 August 1999 New Cumberland, PA 12 August 1999 to 1026 Swarthmore Road Mother 3 June 2000 New Cumberland, PA 3 June 2000 to 1026 Swarthmore Road Mother and Father 14 December 2000 New Cumberland, PA 14 December 2000 1026 Swarthmore Road Mother to present New Cumberland, PA 6. The other averments set out in Plaintiff's original complaint in this matter are incorporated herein by reference. 7. Plaintiff seeks an award of physical and legal custody of both children to her for the following reasons: A. She has been the primary care provider for both children since their birth. 8. The Defendant in his current situation is not able to care properly for the children. i C. Because of her other children, the stability of her home, and her care of both children, Plaintiff is better able to provide for the needs of the children. WHEREFORE, Plaintiff prays this Court to award her primary physical and legal custody of the children, Nolan M. Stopfel and Anna L. Stopfel. Samuel L. Andes Attorney for Plaintiff Supreme Court ID 17225 525 North 12" Street Lemoyne, PA 17043 (717) 761-5361 I verify that the statements made in this Petition are true and correct. I understand that any false statements in this Petition are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). DATE: 03) 13101 r6--o. THERESA C. STOP EL 3 THERESA C. KEGLER, Plaintiff va. DAVID E. STOPFEL, Defendant : IN THE COURT OF COMMCN PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 99-6134 IN CUSTODY ORDER OF COURT AND NOW, this 7th day of March, 2000, the Conciliator, being advised by Plaintiff's counsel that the parties are currently resolving all custody issues by agreement and the Conciliation Conference scheduled for March 30, 2000 is unnecessary, hereby relinquishes jurisdiction in this case. The Custody Conciliation Conference scheduled for March 30, 2000 is canceled. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator THERESA C. KELLER, Plaintiff VS. DAVID E. STOPFEL, Defendant IN THE. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. "M-6 13'1 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this Qa day of - ('( 1999, upon consideration of the Complaint filed in this matter, it is hereby directed that the parties and their respective counsel appear before the conciliator, at,31W Hoona,i *06 6n Pennsylvania, on _Ahx_CS , the M_ day of L?(1Xt`nM(_ , 1999, at o'clock V.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 a temporary order. All children aged 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. 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 FOR THE COURT, BY A111 t CUSTODY CONCILIAT (??l 99OrT 13 PH 2: S4 F:N?'SYi1! ?. J?1 10••3 -W Z .. • } A I= THERESA C. KELLER, Plaintiff VS. DAVID E. STOPFEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. n9- 613 Y CIVIL TERM IN CUSTODY COMPLAINT IN CUSTODY AND NOW comes Theresa C. Keller, by her attorney, Samuel L. Andes, and makes the following Complaint for Custody based upon the following: 1. The Plaintiff is THERESA C. KELLER, an adult individual who resides at 1026 Swarthmore Road in New Cumberland, Cumberland County, Pennsylvania. 2. The Defendant is DAVID E. STOPFEL. His exact residential address is not known but he can be served as his place of employment Pagliaros Trattorias Restrauant at 6301 Grayson Road in Harrisburg, Dauphin County, Pennsylvania. 3. The parties are not married and have never been married, but are the biological parents of one minor child, Nolan M. Stopfel, age 2, born 24 June 1997. 4. Plaintiff seeks custody of the minor child, Nolan M. Stopfel. 5. The child was born out of wedlock and is presently in the custody of the Plaintiff and Defendant. 7. Since the child's birth, the child has resided at the following addresses with the following persons: 24 June 1997 to April 1998 4975 Hamilton Drive Father & Mother both Harrisburg, PA April 1998 to May 1999 339 Herman Avenue Father & Mother both Lemoyne, PA May 1999 to 12 August 1999 1026 Swathmore Road Father & Mother both New Cumberland PA 12 August 1999 to present 1026 Swathmore Road Mother alone New Cumberland, PA 8. The father of the child is the Defendant who resides at the address set above. 9. The mother of the child is the Plaintiff who resides at the address set above. 10. The Plaintiff is the natural mother of the child. Plaintiff currently resides in a single family residence at 1026 Swarthmore Road in New Cumberland, with the minor child and with her four children by a prior marriage, who live there approximately 50% of the time, those children are Rachel Keller, age 19, Laura Keller, age 16, Jennifer Keller, age 14, and Justin Keller, age 11. 11. The Defendant is the natural father of the child. The details of the Defendant's living arrangements are not known at this time. 12. The Plaintiff has not participated as a party or in any other way in any litigation concerning the custody of the child in this or any other Court. The Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this or any other jurisdiction. Plaintiff knows of no other person not a party to this action already who has physical custody of or claims to have custody or visitation rights with the said child. 13. The best interests and permanent welfare of the child will be served by granting the relief requested by Plaintiff for the following reasons: A. The Plaintiff has been the primary care provider for the child since the child's birth; and B. The Defendant has an acute alcohol problem which prevents him from being able to care properly for the child; and C. The Defendant is not sufficiently responsible to properly care for the child and to provide for the child's needs; and D. An award of custody to Plaintiff will continue the child in the family situation in which he has lived all of his life. 14. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff prays this Court to award her primary custody of the minor child, Nolan M. Stopfel. By 4? - 5 nuel L. des Attorney for Plaintiff Supreme Court ID # 17225 525 N. 120' Street Lemoyne, PA 17043 (717) 761-5361 COMMONWEALTH OF PENNSYLVANIA (SS.: COUNTY OF CUMBERLAND Theresa C. Keller, being duly sworn according to law, deposes and says that the facts set forth In the foregoing Complaint In Custody are true and correct to the best of her knowledge, Information, and belief. 4". C. *'0Q('" Theresa C. Keller Sworn to and subscribed before me this LOIL) day of *&ffl/1W ,1999. oxa?`M P,Mc C Notary ubilc. lc Lwga?O?at?red?irl6 Q1"1? 2 = r s CtiS n? ? r7"S { ? , A Lj 1n Ll rtc r s '?+i,J F a??8v w p ?FsF o J < LL a UCT D 9 loor, v"`