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HomeMy WebLinkAbout99-07418 I be 76 ZIAW O` SCOTT D. LAMPREY, PLAINTIFF V. SEFANIE M. LAMPREY, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 99-7418 CIVIL TERM ORDER OF COURT AND NOW, this (Q 4-" day of December, 1999, a hearing on the within petition for special relief shall be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, at 8:45 a.rn„ Friday, December 17, 19179. By the qouif,; Edgar B. Bayley, :saa I? TRUE G6PY FROM AEDAD in Taailmohy wlH?reof, ! hero unto &ftmy harrd and the dal of said Coui4 ai L'ailtslo: Pa. , 1 : IN THE COURT OF COMMON PLEAS OF ` SCOTT D. LAMPREY, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA - : NO. 99- 74/ CIVIL V. STEFANIE M. LAMPREY, CIVIL ACTION - 'CUSTODY. r .o r n ? • Defendant ? ? •, - PETITION FOR SPECIAL RELIEF " Y : t TO THE HONORABLE, THE JUDGES OF 9AID7 COURT: ca Petitioner, Scott D. Lamprey, by and through his attorneys, Stone r ? LaFaver & Shekletski, respectfully represents as followst Your petitioner is Scott D. Lamprey who resides at 5 Sussex 1 . Circle, Camp Hill, Cumberland County, Pennsylvania 17011. The respondent is Stefanie M. Lamprey who, as of December 9, 2 , resides at 814 East Pottsville Street, wiconisco, Daphin county, 9 , 199 Pennsylvania. :a The petitioner hus .filed a complaint for custody to the above 3. d number seeking custody of Coiton S. Lamprey, age 3. A true , term an F of the Complaint for Custody is attached hereto as i and correct copy Exhibit A and incorporated by reference herein as though fully set forth at length. The petitioner and respondent are husband and wife. 4 . • is j.i 5. The respondent left the marital home at 5 Sussex Circle, Camp Hill, Pennsylvania, as of December 9, 1999, and took the child Colton Re9po S. Lamprey, with her. It is believed that the ttdent and Colton 5. Lamprey are currently resi.dirng with the Resrond?nt°E parents at 814 East Pottsville Street, Wicanisco, Dauphin County, Pennsylvania. 5, plaintiff has made efforts to arrange a custody schedule with the defendant for the child, but the defendant, without justification, refused and continues to refuse to allow the plaintiff to have physi- cal custody of or any visitation with his son. 7. Petitioner seeks an order granting temporary custody of Colton S. Lamprey until ouch time ae this matter is resolved by agreement or further order of Court. a Petitioner requests this Honorable Court to enter WHEREFORE, n order granting temporary physical custody of Colton S. Lamprey. STONE LaFAVFR & SHEKLETSKI B ? Gerakti Sheklet's . Esquire 414 Br., Street, P.O. BOY. E New Cumber17n7, PA 17070 Telephone (717) Attorneys for Plaintiff -2- uufara;., ... fl?eustl3 •+erSf3.aEf .V E R I F I C A T I 0 N SCO'T'T D. LAMPREY, states that he is the Plaintiff named in the foregoing instrument and that he is acquainted with the facts set forth in the foregoing instrument; that the same are true and correct to the best of his knowledge, information and belief; and that this statement is made subject to the penalties of 1S Pa. C.S.A. §4904 relating to unsworn falsification to authorities. A. SCOTT D. LAMPREY/ Date: ?v ?t fl\:nnt \Icanci inard SCOTT D. LAMPREY, Plaintiff v, STEFANIE M. LAMPREY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this day of , 1999,upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel-appear before the Conciliator, at on the day of 1999, at , ,_,M., for a Fre-Heating 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 aye five or older may also be present at the conference. Failure to appear mt the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, 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 FORTE[ BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17015 Telephone: (717) 249-3166 t 1•.cucttl-cult Q?-. not SCOTT D. LAMPREY, Plaintiff v. SEFANIE M. LAMPREY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL AC'T'ION - LAW IN CUSTODY NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following complaint, you must take action within twenty (20) days after the complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed against you and a judgment may he entered against you by the Court without further notice for any money claimed in the com- plaint or for any other claim or relief requested by the plaintiff. You may lose money or property, or ocher rights important to yGu. 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, PA 17013 Telephone: (717) 249-31GG F%VJ/L?/T' /71 fl\eua \3anVSey.eea\IV• 9V SCOTT D. LAMPREY, Plaintiff V. STEFANIE M. LAMPREY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY NO. COMPLAINT FOR CUSTODY 1. The plaintiff is Scott D. Lamprey, an adult individual, residing at 5 Sussex Circle, Camp Hill, Cumberland County, Pennsylva- nia 17011. 2. The defendant is Stefanie M. Lamprey, an adult individual, who resided at 5 Sussex Circle, Camp Hill, Cumberland County, Pennsyl- vania 17011, until December 9, 1999, and as of this date is believed to be residing at 814 East Pottsville Street, Wiconisco, Dauphin County, Pennsylvania. 3. Plaintiff seeks custody of Colton S. Lamprey who, until December 9, 1999, resided at 5 Sussex Circle, Camp Hill, Cumberland County, Pennsylvania 17011. Colton S. Lamprey is three (3) years of age having been barn on April 1, 1996. The child was not born out of wedlock. The child is presently in the custody of the defendant who, without prior notice, left the residence at 5 Sussex Circle, camp • -1- Hill, Cumberland County, Pennsylvania 17011, and as of December 9, 1999, without prior notice to the plaintiff, moved in with her par- ents, John Sweikert and Judy Sweikert, at 814 East Pottsville Street, Wiconisco, Dauphin County. Pennsylvania, since birth, the child has'iesided with the following persons and at the following addresses: NAME ADDRESS DATES Scott D. Lamprey and 5 Sussex Circle 4/1/96 to Stefanie M. Lamprey Camp Hill, PA 17011 12/9/99 Christian Brown Stefanie M. Lamprey 814 East Pottsville St. 12/9/99 to Christian Brown Wiconisco, PA Present John Sweikert Judy Sweikert The mother of the child is defendant, Stefanie M. Lamprey, currently residing at 814 East Pottsville Street, Wiconisco, Dauphin County, Pennsylvania. She is married to plaintiff. The father of the child is plaintiff, Scott D. Lamprey, currently residing at 5 Sussex Circle, Camp Hill, Pennsylvania. He is married to defendant. 4_ The relationship of plaintiff to the child is that of father. The plaintiff currently resides with the following persons: NAME Nonw RL"LATTONSHI P -2- I 5. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons: NAME RELATIONSHIP John 5weikert Father "Judy sweikert Mother Christian Brown Sort (by prior marriage) Colton S. Lamprey Son 6. 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 child. 7. The best interest and permanent welfare of the chid will be served by granting the relief requested because: (a) The Father has been the primary care giver of the child since birth and is able to provide a stable home and family type environment for the child allowing the child opportu- nity to spend time with the child's mother consistent with a schedule the parties have arranged between themselves. -3- L S. 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 pasties to this action. wHEREFORE, plaintiff request: the court to grant primary physical custody and shared legal custody Of 'the child to the plaintiff. STONE LaH*j ii Z & GERALPI` J. 8HU]Sb SKI, ESQUIRE Supreme Court T.D. #40486 414 Bridge Street, P.O. Box E New Cumberland, PA 17070 Telephone: (717) 774-7435 Attorneys for Plaintiff -4- "V E R I F I C A T I O N SCOTT D. LAMPREY, states that he is the Plaintiff named in the foregoing instrument and that he is acquainted with the facts set forth in the foregoing instrument; that the same are true and correct to the beat of his knowledge, information and belief; and that this statement is made subject to the penalties of IS Pa. C.S.A. 94904 relating to unsworn falsification to authorities. , Leo SCOTT D. LAMP ER Y . Date;_ f' SCOTT D. LAMPREY, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW STEFANIE M. LAMPREY, Defendant 99-7418 CIVIL TERM ORDER OF COURT AND NOW, this 17th day of December, 1999, the parties having reached agreement, it is ordered: 1. Scott D. Lamprey, father, and Stephanie M. Lamprey, mother, shall have shared legal and physical custody of Colton Lamprey, born April 1, 1996. 2. The parties shall alternate weeks with Colton for which the exchange shall be at 5:00 p.m. on Sundays. The first week shall start this Sunday on December 19th at 5:00 p.m. when the father shall have Colton. 3. During each week, the parent not having Colton shall pick the child up at the end of day care on Wednesday and return the child to day care on Thursday. 4. For 1999, the mother shall pick up Colton on December 24th at 4:00 p.m., and the father shall pick him up on December 25th at 11:00 a.m. 5. For 1999, the father shall pick up Colton on December 31st at 4:00 p.m., and the mother shall pick him up on New Year's Day at 11:00 a.m. 6. Neither parent shall harass the other or make any disparaging remarks about the other in the presence of Colton. 7. Each parent shall allow reasonable telephone access of Colton with the other parent. 8. The parents shall continue to use the Magic Years Day Care facility and divide the cost. F r? f 9. The parties will engage in counseling at a counselor to be mutually chosen to deal with custodial and marital issues. 10. The mother will go to the marital residence this Saturday, December 16th at 6:00 a.m. with her brother and other helpers and shall remove those items set forth in a letter of her attorney dated December 16, 1999, as adjusted in a response of father's attorney that date and as further modified by a written note prepared this date. This action shall not prejudice either party with respect to any claim that each of them may have for the purposes of the equitable distribution of such property. 11. The custody arrangements set forth herein are temporary arrangements pending conciliation and the entry of a final order in this case and shall not prejudice either party with respect to such claims they shall make in that litigation. By the Court, Gerald Shekletski, Esquire For Plaintiff Paul J. Esposito, Esquire For Defendant Sheriff ar ?B?.yy?B?a?y?l)iey, ?T. la /7-99 RKs prs I fl\cust\l conci1 r. ord Z UEC 13 SCOTT D. LAMPREY, Plaintiff V. STEFANIE M. LAMPREY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this day of 1999,upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear, before 161. fl y. ?G the Conciliator, at >?? V\J . ` L I(? ?JS? C? C.' ?nn on the day of ')3n"_-rx at 1=`..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 also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Custody Conci i for ?"'?J\ 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, PA 17013 Telephone: (717) 249-3166 --SIN • /?•:,:C? yr' /il'lllt.e' ?c<<z?-C?? ?> r%? ?,??sclp i. !1 C1\cu0t\1-cu0cdy.not SCOTT D. LAMPREY, Plaintiff V. SEFANIE M. LAMPREY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN CUSTODY NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following complaint, you must take action within twenty (20) days after the complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed against you and a judgment may be entered against you by the Court without further notice for any money claimed in the com- plaint or for any other claim or relief requested by the plaintiff. You may lose money or property, or other rights important to you. 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, PA 17013 Telephone: (717) 249-3166 fI%cuat \ lamprey. c=m 12-99 i SCOTT D. LAMPREY, Plaintiff V. STEFANIE M. LAMPREY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY NO. COMPLAINT FOR CUSTODY 1. The plaintiff is Scott D. Lamprey, an adult individual, residing at 5 Sussex Circle, Camp Hill, Cumberland County, Pennsylva- nia 17011. 2. The defendant is Stefanie M. Lamprey, an adult individual, who resided at 5 Sussex Circle, Camp Hill, Cumberland County, Pennsyl- vania 17011, until December 9, 1999, and as of this date is believed to be residing at 814 East Pottsville Street, Wiconisco, Dauphin County, Pennsylvania. i 3. Plaintiff seeks custody of Colton S. Lamprey who, until December 9, 1999, resided at 5 Sussex Circle, Camp Hill, Cumberland County, Pennsylvania 17011. Colton S. Lamprey is three (3) years of age having been born on April 1, 1996. The child was not born out of wedlock. The child is presently in the custody of the defendant who, without prior notice, left the residence at 5 Sussex Circle, Camp -1- Hill, Cumberland County, Pennsylvania 17011, and as of December 9, 1999, without prior notice to the plaintiff, moved in with her par- ents, John Sweikert and Judy Sweikert, at 814 East Pottsville Street, Wiconisco, Dauphin County, Pennsylvania. Since birth, the child has resided with the following persons and at the following addresses: NAME ADDRESS DATES Scott D. Lamprey and 5 Sussex Circle 4/1/96 to Stefanie M. Lamprey Camp Hill, PA 17011 12/9/99 Christian Brown Stefanie M. Lamprey 814 East Pottsville St. 12/9/99 to Christian Brown Wiconisco, PA Present John Sweikert Judy Sweikert The mother of the child is defendant, Stefanie M. Lamprey, currently residing at 814 East Pottsville Street, Wiconisco, Dauphin County, Pennsylvania. She is married to plaintiff. The father of the child is plaintiff, Scott D. Lamprey, currently residing at 5 Sussex Circle, Camp Hill, Pennsylvania. He is married to defendant. 4. The relationship of plaintiff to the child is that of father. The plaintiff currently resides with the following persons: NAME None -2- RELATIONSHIP W- .. . i I 5. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons: NAME RELATIONSHIP John Sweikert Father Judy Sweikert Mother Christian Brown Son (by prior marriage) Colton S. Lamprey Son 6. 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 child. 7. The best interest and permanent welfare of the chid will be served by granting the relief requested because: (a) The Father has been the primary care giver of the child since birth and is able to provide a stable home and family type environment for the child allowing the child opportu- nity to spend time with the child's mother consistent with a schedule the parties have arranged between themselves. -3- i 8. 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 requests the court to grant primary physical custody and shared legal custody of the child to the plaintiff. STONE L4BAsi5R & GERALPT??SKI, ESQUIRE Supreme Court I.D. #40486 414 Bridge Street, P.O. Box E New Cumberland, PA 17070 Telephone: (717) 774-7435 Attorneys for Plaintiff -4- F1\cua[\1-vcrif i. -IfI V E R I F I C A T I O N SCOTT D. LAMPREY, states that he is the Plaintiff named in the foregoing instrument and that he is acquainted with the facts set forth in the foregoing instrument; that the same are true and correct to the best of his knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. SCOTT D. LAMP EY Date: ?? iU oEC 1 199 SCOTT D. LAMPREY, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. SEFANIE M. LAMPREY, DEFENDANT : 99-7418 CIVIL TERM ORDER OF COURT AND NOW, this ?*?- day of December, 1999, a hearing on the within petition for special relief shall be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, at 8:45 a.m., Friday, December 17, 1999. By the Court, :saa l.ur. ? rte ,.y fi .fl\CUat\Iamprey-pet SCOTT D. LAMPREY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA N0. 7L//Y CIVIL V. STEFANIE M. LAMPREY, CIVIL ACTION - CUSTODY Defendant PETITION FOR SPECIAL RELIEF TO THE HONORABLE, THE JUDGES OF SAID COURT: Petitioner, Scott D. Lamprey, by and through his attorneys, Stone LaFaver & Shekletski, respectfully represents as follows: 1. Your petitioner is Scott D. Lamprey who resides at 5 Sussex Circle, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The respondent is Stefanie M. Lamprey who, as of December 9, 1999, resides at 814 East Pottsville Street, Wiconisco, Daphin County, Pennsylvania. 3. The petitioner has filed a complaint for custody to the above term and number seeking custody of Colton S. Lamprey, age 3. A true and correct copy of the Complaint for Custody is attached hereto as Exhibit A and incorporated by reference herein as though fully set forth at length. 4. The petitioner and respondent are husband and wife. -1- I. P 5. The respondent left the marital home at 5 Sussex Circle, Camp Hill, Pennsylvania, as of December 9, 1999, and took the child Colton S. Lamprey, with her. It is believed that the Respondent and Colton S. Lamprey are currently residing with the Respondent's parents at 814 East Pottsville Street, Wiconisco, Dauphin County, Pennsylvania. 6. Plaintiff has made efforts to arrange a custody schedule with the defendant for the child, but the defendant, without justification, refused and continues to refuse to allow the plaintiff to have physi- cal custody of or any visitation with his son. 7. Petitioner seeks an order granting temporary custody of Colton S. Lamprey until such time as this matter is resolved by agreement or further order of Court. WHEREFORE, petitioner requests this Honorable Court to enter an order granting temporary physical custody of Colton S. Lamprey. STONE LaFAV?R & SHEKLETSKI By-- Gera A Sheklets i, Esquire 414 Bri Street, P.O. Box E New Cumberland, PA 17070 Telephone (717) 774-7435 Attorneys for Plaintiff -2- F1\cu9t\1-vcri[i.a iI V E R I F I C A T I O N SCOTT D. LAMPREY, states that he is the Plaintiff named in the foregoing instrument and that he is acquainted with the facts set forth in the foregoing instrument; that the same are true and correct to the best of his knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. SCOTT D. L REY Date: ??/y Cl\cust%Icanc-Ir.ord SCOTT D. LAMPREY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. STEFANIE M. LAMPREY, CIVIL ACTION - CUSTODY Defendant ORDER OF COURT AND NOW, this day of , 1999,upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before , the Conciliator, at on the day of 1999, at _.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 also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 f`%Cuc:%!-cus[dy.noc SCOTT D. LAMPREY, Plaintiff V. SEFANIE M. LAMPREY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN CUSTODY NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following complaint, you must take action within twenty (20) days after the complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed against you and a judgment may be entered against you by the Court without further notice for any money claimed in the com- plaint or for any other claim or relief requested by the plaintiff. You may lose money or property, or other rights important to you. 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, PA 17013 Telephone: (717) 249-3166 r /4' J II fl\cust\1aaprcy.c0m\12-99 SCOTT D. LAMPREY, Plaintiff V. STEFANIE M. LAMPREY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY NO. COMPLAINT FOR CUSTODY 1. The plaintiff is Scott D. Lamprey, an adult individual, residing at 5 Sussex Circle, Camp Hill, Cumberland County, Pennsylva- nia 17011. 2. The defendant is Stefanie M. Lamprey, an adult individual, who resided at 5 Sussex Circle, Camp Hill, Cumberland County, Pennsyl- vania 17011, until December 9, 1999, and as of this date is believed to be residing at 814 East Pottsville Street, Wiconisco, Dauphin County, Pennsylvania. 3. Plaintiff seeks custody of Colton S. Lamprey who, until December 9, 1999, resided at 5 Sussex Circle, Camp Hill, Cumberland County, Pennsylvania 17011. Colton S. Lamprey is three (3) years of age having been born on April 1, 1996. The child was not born out of wedlock. The child is presently in the custody of the defendant who, without prior notice, left the residence at 5 Sussex Circle, Camp -1- Hill, Cumberland County, Pennsylvania 17011, and as of December 9, 1999, without prior notice to the plaintiff, moved in with her par- ents, John Sweikert and Judy Sweikert, at 814 East Pottsville Street, Wiconisco, Dauphin County, Pennsylvania. Since birth, the child has resided with the following persons and at the following addresses: NAME ADDRESS DATES Scott D. Lamprey and 5 Sussex circle 4/1/96 to Stefanie M. Lamprey Camp Hill, PA 17011 12/9/99 Christian Brown Stefanie M. Lamprey 814 East Pottsville St. 12/9/99 to Christian Brown Wiconisco, PA Present John Sweikert Judy Sweikert The mother of the child is defendant, Stefanie M. Lamprey, currently residing at 814 East Pottsville Street, Wiconisco, Dauphin County, Pennsylvania. She is married to plaintiff. The father of the child is plaintiff, Scott D. Lamprey, currently residing at 5 Sussex Circle, Camp Hill, Pennsylvania. He is married to defendant. 4. The relationship of plaintiff to the child is that of father. The plaintiff currently resides with the following persons: NAME RELATIONSHIP None -2- 5. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons: NAME RELATIONSHIP John Sweikert Father Judy Sweikert _ Mother Christian Brown Son (by prior marriage) Colton S. Lamprey Son 6. 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 child. 7. The best interest and permanent welfare of the chid will be served by granting the relief requested because: (a) The Father has been the primary care giver of the child since birth and is able to provide a stable home and family type environment for the child allowing the child opportu- nity to spend time with the child's mother consistent with a schedule the parties have arranged between themselves. -3- 8. 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 requests the court to grant primary physical custody and shared legal custody of 'the child to the plaintiff. STONE La.FA?3 & GERA d. SH SKI, ESQUIRE Supreme Court I.D. #40486 414 Bridge Street, P.O. Box E New Cumberland, PA 17070 Telephone: (717) 774-7435 Attorneys for Plaintiff -4- M\aus[\f-verifi.aff V E R I F I C A T I O N SCOTT D. LAMPREY, states that he is the Plaintiff named in the foregoing instrument and that he is acquainted with the facts set forth in the foregoing instrument; that the same are true and correct to the best of his knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. SCOTT D. LAMP EY Date: z-°/6.1.1w n 1 SCOTT D. LAMPREY, Plaintiff VS. STEFANIE M. LAMPREY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 99-7418 IN CUSTODY ORDER OF COURT AND NOW, this 28th day of February, 2000, the Conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction in this case. The Custody Conciliation Conference scheduled for, March 14, 2000, is canceled. FOR THE COURT, Da S. Sunday, Esquire Custody Conciliator C.r - G'!CT1V9Y 00 PiQ? -"I All 9: 53 HNNSYLMMIA fl\cuec\lampre7.ap0\2.00 SCOTT D. LAMPREY, Plaintiff V. STEFANIE M. LAMPREY, Defendant dw NEAR 2 7 2unoa i i r, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7418 CIVIL TERM CIVIL ACTION - LAW ORDER OF COURT day of 2000, upon AND NOW, this consideration of the Stipulation and Agreement of the parties hereto, it is ordered and decreed that the order of Court dated December 17, 1999, is hereby made a final order in this matter. BY THE,COURT: .60 ?R U...- i j?? CL\eust\lamprey. etp\2-00 SCOTT D. LAMPREY, Plaintiff V. STEFANIE M. LAMPREY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7418 CIVIL TERM CIVIL ACTION - LAW STIPULATION AND AGREEMENT AND NOW come the parties hereto, representing as follows: 1. That on December 17 , 1999, this Court entered a temporary arrangement pending conciliation and the entry of a final order in this case. A true and correct copy of the Court's Order of December 17, 1999, is attached hereto and incorporated by reference herein. 2. The parties desire that the custody arrangement set forth in the Order of December 17, 1999, be made a final order in this case. WHEREFORE, the parties hereto hereby request this Court to enter an order making the Order of December 17, 1999, a final order in this case. GERATJrJ..l SHEKLETSK,GI, Witness PAUL J./ESPO ITO, Witness L SCOTT D. LAMPREY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V CIVIL ACTION - LAW STEFANIE M. LAMPREY, Def endant 99_7418 CIVIL TERM . ORDER OF COURT AND-NOW, this 17th day of December, 1999, the parties having reached agreement, it is ordered: 1. Scott D. Lamprev, father, and Stephanie M. Lamprey, mother, shall have shared legal and physical custody of Colton Lamprey, born April 1, 1996. 2. The parties shall alternate weeks with Colton for which the exchange shall be at 5:00 p.m. on Sundays. The first week shall start this Sunday on December 19th at 5:00 p.m. when the father shall have Colton. 3. During each week, the parent not having Colton shall pick the child up at the end of day care on Wednesday and return the child to day care on Thursday. 4. For 1999, the mother shall pick up Colton on December 24th at 4:00 p.m., and the father shall pick him up on December 25th at 11:00 a.m. 5. For 1999, the father shall pick up Colton on December 31st at 4:00 p.m., and the mother shall pick him up on New Year's Day at 11:00 a.m. 6. Neither parent shall harass the other or make any disparaging remarks about the other in the presence of Colton. 7. Each parent shall allow reasonable telephone access of Colton with the other parent. 8. The parents shall continue to use the Magic Years Day Care facility and divide the cost. / The parties will engage in counseling at a / y. counselor to be mutually chosen to deal with custodial and marital issues. 10. The mother will go to the marital residence this Saturday, December 18th at 8:00 a.m. with her brother and other. helpers and shall remove those items set forth in a letter of her attorney dated December 16, 1999, as adjusted in a response of father's attorney that date and as further modified by a written note prepared this date. This action shall not prejudice either party with respect to any claim that each of them may have for the purposes of 'the equitable distribution of such property. 11. The custody arrangements set forth herein are an ements pending conciliation and the entry of a arr 9 temporary final order in this case and shall not prejudice either party with respect to such claims they shall make in that litigation. By the Court,// Gerald Shekletski, Esquire For Plaintiff Paul J. Esposito, Esquire / For Defendant Sheriff Prs t 18R7J? .. :i?lh PiQ?hOIQldly r- a> u: .i utLtj •- o U SCOTT D. LAMPREY, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. SEFANIE M. LAMPREY, DEFENDANT 99-7418 CIVIL TERM ORDER OF COURT AND NOW, this IC) I- day of December, 1999, a hearing on the within petition for special relief shall be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, at 8:45 a.m., Friday, December 17, 1999. :saa 14 ?,.?'i'1. 'a'if8rl:pl,lik'/f lli'.t?E7f !( I.Q Prothonotary '^ f l lcunt\:a*tey•pet SCOTT D. LAMPREY, Plaintiff V. STEFANIE M. LAMPREY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. `Irl- -74119 CIVIL CIVIL ACTION PETITION FOR SPECIAL RELIEF TO THE HONORABLE, THE JUDGES OF SAID COURT: - CUS?ODY0 - i'y..) ' c 3 Petitioner, Scott D. Lamprey, by and through his attorneys, Stone LaFaver & Shekletski, respectfully represents as follows: 1. Your petitioner is Scott D. Lamprey who resides at 5 Sussex Circle, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The respondent is Stefanie M. Lamprey who, as of December 9, 1999, resides at 814 East Pottsville Street, Wiconisco, Daphin County, Pennsylvania. 3. The petitioner has filed a complaint for custody to the above term and number seeking custody of Colton S. Lamprey, age 3. A true and correct copy of the Complaint for Custody is attached hereto as Exhibit A and incorporated by reference herein as though fully set forth at length. 4. The petitioner and respondent are husband and wife. -1- . I M 5. The respondent left the marital home at 5 Sussex Circle, Camp er 9, 1999, and took the child Colton , Pennsylvania, as of Decemb Hill S. Lamprey, with her. It is believed that the Respondent and Colton S. Lamprey are currently residing with the Respondent's parents at 814 East Pottsville Street, Wiconisco, Dauphin County, Pennsylvania. 6. Plaintiff has made efforts to arrange a custody schedule with the defendant for the child, but the defendant, without justification, refused and continues to refuse to a11.ow the plaintiff to have physi- cal custody of or any visitation with his son. 7. Petitioner seeks an order granting temporary custody of Colton S. Lamprey until such time as this matter is resolved by agreement or further order of court. WHEREFORE, petitioner requests this Honorable Court to enter an order granting temporary physical custody of Colton S. Lamprey. STONE LaFAVER & SHEKLETSKI By Esquire Gerald Shekletsci, 414 Bri Street, P.O. Box E New Cumberland, PA 17070 Telephone (717) 774-7435 Attorneys for Plaintiff -2- rte-- Fl\C:ec \;?v.•rf :.eLf •V E R I F I C A T I O N SCOTT D. LAMPREY, states that he is the plaintiff named in the foregoing instrument and that he is acquainted with the facts set instrument; that the same are true and correct forth in the foregoing to the best of his knowledge, information and belief; and that this statement is made subject to the penalties of is Pa. C.S.A. §4904 relating to unsworn falsification to authorities. SCOTT D. LAMPREY' Date: s A " %oust\xoorilr.ord SCOTT D. LAMPREY, Plaintiff V. STEFANIE M. LAMPREY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this day of , 1999,upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel-appear before the Conciliator, at on the day of 1999, at , _.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 also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 SCOTT D. LAMPREY, Plaintiff V. SEFANIE M. LAMPREY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN CUSTODY NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following complaint, you must take action within twenty (20) days after the complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed against you and a judgment may be entered against you by the Court without further notice for any money claimed in the com- plaint or for any other claim or relief requested by the plaintiff. You may lose money or property, or other rights important to you. 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, PA 17013 Telephone: (717) 249-3166 J; r 11\c_s:\1a-pcey.cam\12.99 SCOTT D. LAMPREY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - CUSTODY STEFANIE M. LAMPREY, NO. Defendant COMPLAINT FOR CUSTODY 1. The plaintiff is Scott D. Lamprey, an adult individual, residing at 5 Sussex Circle, Camp Hill, Cumberland County, Pennsylva- nia 17011. 2. The defendant is Stefanie M. Lamprey, an adult individual, who resided at 5 Sussex Circle, Camp Hill, Cumberland County, Pennsyl- vania 17011, until December 9, 1999, and as of this date is believed to be residing at 814 East Pottsville Street, wiconisco, Dauphin County, Pennsylvania. 2. Plaintiff seeks custody of C71ton S Lamprey who, until December 9, 1999, resided at 5 Sussex Circle, Camp Hill, Cumberland County, Pennsylvania 17011. Colton S. Lamprey is three (3) years of age having been born on April 1, 1996. The child was not born out of'wedlock. The child is presently in the custody of the defendant who, without prior notice, left the residence at 5 Sussex Circle, Camp -1- ,I Hill, Cumberland County, Pennsylvania 17011, and as of December 9, 1999, without prior notice to the plaintiff, moved in with her par- ents, John Sweikert and Judy Sweikert, at 814 East Pottsville Street, Wiconisco, Dauphin County, Pennsylvania. Since birth, the child has'resided with the following persons and at the following addresses: NAME Scott D. Lamprey and Stefanie M. Lamprey Christian Brown Stefanie M. Lamprey Christian Brown John Sweikert Judy Sweikert ADDRESS DATES 5 Sussex Circle 4/1/96 to Camp Hill, PA 17011 12/9/99 814 East Pottsville St. 12/9/99 to Present Wiconisco, PA The mother of the child is defendant, Stefanie M. Lamprey, currently residing at 814 East Pottsville Street, Wiconisco, Dauphin County, Pennsylvania. She is married to plaintiff. The father of the child is plaintiff, Scott D. Lamprey, currently residing at 5 Sussex Circle, Camp Hill, Pennsylvania. He is married to defendant. 4. The relationship of plaintiff to the child is that of father. The plaintiff currently resides with the following persons: NAME None RELATIONSHIP -2- 5. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons: NAME RELATIONSHIP John Sweikert Father Judy Sweikert Mother Christian Brown Son (by prior marriage) Colton S. Lamprey Son 6. 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 child. 7. The best interest and permanent welfare of the chid will be served by granting the relief requested because: (a) The Father has been the primary care giver of the child since birth and is able to provide a stable home and family type environment for the child allowing the child opportu- nity to spend time with the child's mother consistent with a schedule the parties have arranged between themselves. -3- 6. 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 requests the court to grant primary physical custody and shared legal custody of the child to the plaintiff. STONE LaEZO? & GERALH<J. SHE SKI, ESQUIRE Supreme Court I.D. #40486 414 Bridge Street, P.O. Box E New Cumberland, PA 17070 Telephone: (717) 774-7435 Attorneys for Plaintiff -4- flMutt\t•vertf'.eff V E R I F I C A T I O N SCOTT D. LAMPREY, states that he is the Plaintiff named in the foregoing instrument and that he is acquainted with the facts set forth in the foregoing instrument; that the same are true and correct to the best of his knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.S.A. 54904 relating to unsworn falsification to authorities. SCOTT D. LAMP EY ' t ? i ,'7 Date /? ??