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HomeMy WebLinkAbout08-4405LEEANN DERRICK JSEL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 0 r- q VO VI BISHOP, CIVIL ACTION -LAW Defendant CHILD CUSTODY NOTICE claims set i this Compl attorney an forth again you and a j any money Plaintiff. ) child Gusto, YOU HAVE BEEN SUED IN COURT. If you wish to defend against the firth in the following pages, you must take action within twenty (20) days after int and Notice are served, by entering a written appearance personally or by filing in writing with the Court your defenses or objections to the claims set you. You are warned that if you fail to do so the case may proceed without dgment may be entered against you by the Court without further notice for Jaimed in the Complaint or for any other claim or relief requested by the )u may lose money or property, or other rights important to you, including y, or child visitation. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU D NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR N FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse a las demandas que se presentan mas adelante en las siguientes piginas, debe tomar acci6 dentro de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparece cia escrita y radicando en la Corte por escrito sus defensas de, y objeccionnes a, las dem das presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accib como de describe anteriormente, el caso puede proceder sin usted y un fallo por cualqui r suma de dinero reclamada en la demanda o cualquier otra reclamaci6n o remedio sol citado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso a icional. Usted puede perder dinero o propiedad u otros derechos importantes para. usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIA AMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUI TE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA E COMO CONSEGUIER UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGAD , ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMA ION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O AJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 LEEANN DERRICK 4SEL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0-r- V Y6,5" / c -cam. 4 7.e.,.. VI BISHOP, CIVIL ACTION -LAW Defendant CHILD CUSTODY COMPLAINT FOR CHILD CUSTODY attorney, her reaso avers the AND NOW comes the Plaintiff, LeeAnn Hansel, by and through her T. Silliker, Esquire, and respectfully requests this Honorable Court award rights of partial custody of the subject minor child, and in support thereto, 1. Plaintiff is LeeAnn Hansel, an adult individual residing at 105 Paradise Road, Dun on, Perry County, Pennsylvania. 17020. 2. Defendant is Derrick Levi Bishop, an adult individual residing at 659 Saw Mill Mechanicsburg, Cumberland County, Pennsylvania. 17055. 3. The subject child is Bryson Levi Bishop, born November 26, 2004. 4. The relationship of the Plaintiff to the subject minor child is that of maternal erindmother. 5. The relationship of the Defendant to the subject minor child is that of natural fath$r. 6. The subject minor child's natural mother, Mandi Bishop, passed away on June 19, 7. The minor child has resided at the following addresses, in the custody of the following individuals: a. From December 1, 2007 - Present, the subject minor child resides at 659 Saw Mill Road, Mechanicsburg, Cumberland County, Pennsylvania in the care and custody of Defendant, Derrick Levi Bishop. b. From March 2006 - December 1, 2007, the subject minor child resided at 105 North Crest Drive, York Haven, York County, Pennsylvania in the care and custody of natural mother, Mandi Bishop, and natural father, Defendant, Derrick Levi Bishop. c. From Birth - March 2006, the subject minor child resided at Sheep Bridge Road, Newberrytown, York County, Pennsylvania in the care and custody of natural mother, Mandi Bishop, and natural father, Defendant, Derrick Levi Bishop. 8. Plaintiff, LeeAnn Hansel, believes there may have been a prior custody action between Mother and Father. There was a divorce action indexed to 2007 FC 01180-Y03 in York County, Pennsylvania. Plaintiff does not know if a Custody Order was ever g erated to this number. It should be noted that Plaintiff, LeeAnn Hansel, was not a party to the prior action. It is further noted that the subject minor child has resided in Cumberl d County for a period in excess of six months. Therefore, Cumberland County wo d seem to be the proper venue for any new actions that might be filed. 9. The Plaintiff is not aware of the existence of any other individuals who have any type of claim whatsoever regarding the custody of the subject minor child. 10. Plaintiff, LeeAnn Hansel, would specifically request this Honorable Court grantl her Grandparent Rights of Visitation, based upon the fact that the current custodial p4rty, Derrick Levi Bishop, does not allow her to exercise any sort of reasonable fights of visitation regarding the subject minor child. 11. Plaintiff feels it would be in the best interests of the subject minor child that h? have an ongoing relationship with her because she represents his mother's side of the WHEREFORE, pursuant to 23 Pa.C.S.A. 5312, Plaintiff LeeAnn Hansel requests this Honorable Court grant her reasonable periods of partial custody, relative to the subject minor child. Date: Respectfully submitted, THE LAW OFFICES OF SILLIKER & D M T. Silliker, Esquire 5922 Linglestown Road Harrisburg, PA 17112 (717) 671-1500 I.D. No. 33671 Attorney for Plaintiff, LeeAnn Hansel AFFIDAVIT and correct hereby certify that the aforegoing is true the best of my knowledge, information and belief. I understand that false statements horein are made subject to the penalties of 18 Pa. C. S. 4909 relating to unworn falsifications to authorities. Dated: * On On n - 7C7 Lb V 1 r"} ha C .3 O Co r-- W 70 rr: ,P T CD K LEEANN HANSEL IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. DERRICK LEVI BISHOP DEFENDANT 2008-4405 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, July 25, 2008 , 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, August 22, 2008 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. Gilroy, Ems. j y1'? 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 "0 50- 5f c VAIL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION LEEANN HANSEL, VS. Plaintiff DERRICK L. BISHOP Defendant No. 2008-4405 Custody Action NOTICE TO PLEAD TO: Leeann Hansel c/o Mark T. Silliker, Esquire 5922 Linglestown Rd. Harrisburg, PA 17112 You are hereby notified to file a written response to the enclosed Preliminary Objections within twenty (20) days from service hereof or a judgment may entered against you. MORRIS & VEDDER MORRIS & VEDDER 32 N. DUKE ST. YORK, PA DATED: July 29, 2008 Doc. No. Cwv2242 BY: Clyde W. Veddet,-E-squire 32 N. Duke St. PO Box 544 York, PA 17405 (717) 843-9815 Supreme Court No. 32098 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION LEEANN HANSEL, Plaintiff VS. DERRICK L. BISHOP Defendant No. 2008-4405 Custody Action PRELIMINARY OBJECTIONS TO THE HONORABLE, THE JUDGES OF THE SAID COURT: AND NOW, TO WIT, this 29th day of July, 2008, comes the Defendant, Derrick L. Bishop, by his attorneys, Morris & Vedder, and preliminarily objects to the Complaint in Custody filed by Plaintiff in this action, of which the following is a statement: BACKGROUND 1. Plaintiff is LeeAnn Hansel, hereinafter "Maternal Grandmother." 2. Defendant is Derrick L. Bishop, hereinafter "Father." 3. Father is the parent of one child, namely: Bryson L. Bishop, a male, born November 16, 2004, age 3. The child is MORRIS & VEDDER presently in the custody of Father. 32 N. DUKE ST. YORK, PA 4. Mother of the child is Mandi R Bishop, deceased, having died on June 19, 2008. PROCEDURAL HISTORY OF CASE IN YORK COUNTY 5. On or about June 21, 2007, Father commenced a custody action against the child's mother before the Court of Common Pleas of York County, Pennsylvania, captioned as "Derrick L. Bishop, Plaintiff vs. Mandi R. Bishop, Defendant, docketed to No. 2007 FC 01180-Y03 by the filing of a Complaint for Custody. 6. By Order of Court dated February 27, 2008, Father has primary physical custody of the child. A true and correct copy of the docket entries as maintained by the Prothonotary of the Court of Common Pleas of York County are attached hereto, marked Annex "A" and incorporated herein by reference as if fully set forth at length. 7. At no time did Maternal Grandmother make even a modicum of effort to ascertain whether a custody action exists in York County. 8. Although Maternal Grandmother was not a party to such MORRIS & VEDDER 32 N. DUKE ST. YORK, PA action, she is well aware that the child's parents were separated and Father had filed matrimonial claims against her daughter, having called Father's counsel after her daughter's death making inquiry as to the status of the divorce action in lYork County. 2 PROCEDURAL HISTORY OF CASE IN CURMERLAND COUNTY 9. On or about July 25, 2008, Maternal Grandmother commenced the above-captioned custody action against Father. 10. Father was served in the instant action within the last several days. 11. Paragraph 2 of Maternal Grandmother's Complaint for Child Custody states as follows: Defendant is Derrick Levi Bishop, an adult individual residing at 659 Saw Mill Road, Mechanicsburg, Cumberland County (sic), Pennsylvania 17055. 12. A Pre-Hearing Custody Conference is scheduled for Friday, August 22, 2008 at 8:30 a.m. before Hubert X. Gilroy, Esquire, Custody Conciliator. JURISDICTIONAL OBJECTION MORRIS & VEDDER 32 N. DUKE ST. YORK, PA 13. The Pennsylvania Rules of Civil Procedure at Rule 1915.2, entitled "Venue," provides that except under special circumstances not applicable here an action for custody shall be brought in the home county of the child at the time of the commencement of the action. Pa.R.C.P. No. 1915.2. 14. Pennsylvania has adopted the Uniform Child Custody Jurisdiction Act (the UCCJA). 23 Pa.C.S.A. § 5341, et seq. 15. The UCCJA has intrastate application. 23 Pa.C.S.A. § II 5364. 3 16. York County is the home county of the child at the time this custody proceeding was commenced. 17. As stated in Maternal Grandmother's custody complaint, the child is residing at 659 Saw Mill Rd., Mechanicsburg, Pennsylvania 17055, which is in York County, not Cumberland County. See York County Tax Assessment Record for the property in question, which is attached hereto and marked Annex "B." I MORRIS & VEDDER 32 N. DUKE ST. YORK, PA 18. York County has long been the home county of the child well before the commencement of the York County custody proceeding and Father and the child continue to live in York County. 23 Pa.C.S.A. § 5344(a) (1) (ii) . 19. The child and Father have a significant connection with York County, but relatively none with Cumberland County. 23 Pa.C.S.A. § 5344(a) (2) (i) . 20. There is available in York County substantial evidence concerning the present and future care, protection, training and personal relationships of the child. 23 Pa.C.S.A. § 5344 (a) (2) (ii) . 21. The UCCJA should require Cumberland County to decline jurisdiction where, as here, a proceeding exists in York County. 23 Pa.C.S. § 5347(a); Simpkins v. Disney, 416 Pa.Super. 243, 610 A.2d 1062 (1992) (affirming a decision 4 entered by the Court of Common Pleas, York County, the Honorable Sheryl Ann Dorney, Judge, presiding). 22. Alternatively, the custody proceeding should be transferred to York County based upon the legal doctrine of forum non conveniens. Pa.R.C.P. No. 1915.2(d). WHEREFORE, Defendant, Derrick L. Bishop, respectfully requests your Honorable Court to refuse to exercise jurisdiction and to transfer the instant proceeding to the Court of Common Pleas of York County for further processing. Respectfully submitted, MORRIS & VEDDER BY: Clyde W. Vedddrr, Esquire 32 N. Duke St. PO Box 544 York, PA 17405 (717) 843-9815 Supreme Court No. 32098 I Doc. No. Cwv17691 MORRIS & VEDDER 32 N. DUKE ST. YORK, PA 5 2007-FC-001180-03 BISHOP, DERRICK L vs. BISHOP, MANDI R Date Action Type Pages 04/09/2008 *CERTIFICATE OF COMPLETION OF DERRICK BISHOP 05397 FOR KIDS FIRST (Volume: 00053-Blip: 00238) WORKSHOP ON MARCH 18, 2008 02/29/2008 *SHERIFF'S PROCESSING FEE FOR BENCH WARRANT 04093 (Volume: 00030-Blip: 00209) 02/29/2008 *CERTIFICATE OF SERVICE OF OF THE CUSTODY 04025 STIPULATION & ORDER BY MAIL (Volume: 00033-Blip: 00204) 02/27/2008 *CUSTODY STIPULATION 04491 (Volume: 00029-Blip: 00242) 02/27/2008 *ORDER APPROVING CUSTODY STIPULATION BY CT 04263 MARIA MUSTI COOK JUDGE (Volume: 00029-Blip: 00242) (SERVICE NOT REQUIRED BY PROTHY) 02/26/2008 *ORDER RE: CUSTODY HEARINGS THAT DEFT 04104 FAILED TO APPEAR ON FOUR (Volume: 00029-Blip: 00068) SEPARATE OCCAISIONS CT FINDS DEFT IN CONTEMPT AND WILL SENTENCE HER TO A PERIOD OF TIME SERVED PLUS PAYMENT OF COST IN AMT OF 146.60 TO BE PAID BY CLOSE OF BUSINESS 2/25/08 FAILURE TO APPEAR ON 2/27/08 WILL RESULT IN DEFTS AT LEAST 30 DAY JAIL SENTENCE BY THE COURT MARIA MUSTI COOKJUDGE 02/26/2008 *NOTICE GIVEN RE: PA RCP 236 W/DOCUMENTS 05032 FILED AND MAILED TO MANDI (Volume: 00029-Blip: 00068) BISHOP AT BOTH ADDRESSES GIVEN ON 2/26/08 AT 3PM AND FAXED TO CLYDE VEDDER ESQ ON 2/26/08 AT 1:57PM 02/25/2008 *CIVIL BOND (Volume: 02008 02/25/2008 *FINE PAID BY DEFT (Volume: 99999-Blip: 99999) 02/25/2008 *BILL OF COSTS - SHERIFF TRANSPORT (Volume: 00027-Blip: 00244) 02/25/2008 *ORDER DISPOSING OF BW AND/OR RELEASING PRISONER MANDI BISHOP BY CT (Volume: 00027-Blip: 00246) MARIA MUSTI COOK, JUDGE 02/25/2008 *NOTICE GIVEN RE: PA R. C. P. 236 FAXED TO YCP ON 2/25/08 @ 11 AM (Volume: 00027-Blip: 00246) 02/25/2008 *BENCH WARRANT CANCELLED: CANCELATION #808873 OPER #15 (Volume: 00028-Blip: 00165) 06958 05483 04679 03095 06908 06955 Annex "A" 2007-FC-001180-03 BISHOP, DERRICK L vs. BISHOP, MANDI R Date Action Type Pages 02/25/2008 *COURT MINUTE SHEET BEFORE JUDGE MUSTI 88888 COOK, ROMESBERG, CT RPR (Volume: 00028-Blip: 00102) 02/21/2008 *ORDER OF COURT RESCHEDULING CUSTODY TRIAL 03022 FOR 2/27/08 AT 9:30 AM (Volume: 00026-Blip: 00303 ) IN HEARING ROOM 3 BY THE COURT MARIA MUSTI COOKJUDGE 02/21/2008 *NOTICE GIVEN RE: PA RCP 236 W/DOCUMENTS 05032 FILED AND MAILED TO MANDI (Volume: 00026-Blip: 00303) BISHOP AT BOTH ADDRESSES GIVEN ON 2/21/08 AT 11AM AND FAXED TO CLYDE VEDDER ESQ ON 2/21/08 AT 9:58AM 02/20/2008 *ORDER DIRECTING YORK CO CHILDREN & YOUTH 03084 SVCS SHALL DELIVER ENTIRE (Volume: 00026-Blip: 00105) FILE TO JUDGE MARIA MUSTI COOK BY CT SHERYL ANN DORNEY JUDGE W/CERT OF SVC 02/19/2008 *COURT MINUTE SHEET BEFORE JUDGE DORNEY, B 88888 FUHRMAN CT RPR (Volume: 00026-Blip: 00255 ) 02/15/2008 *ORDER FOR BENCH WARRANT-FAILURE TO APPEAR 03070 AT PRE-TRIAL CONFERENCE (Volume: 00024-Blip: 00142) DISCONNECTED THE PHONE CALL AND FAILED TO APPEAR FOR THE CALL OF THE LIST ON 2/11/08 AND CT DIRECTS THAT PRIMARY PHYSICAL CUSTODY SHALL BE TRANSFERRED TO DERRICK L BISHOP UNTIL SUCH TIME AS THIS MATTER GOES TO TRIAL AND OUTLINED IN THIS ORDER BY THE COURT MARIA MUSTI COOK JUDGE 02/14/2008 *PETITION FOR DISCOVERY OF CYS RECORDS 04847 W/CERT OF NOTICE OF PRESENTATIO (Volume: 00023-Blip: 00308 ) & SERVICE 02/13/2008 *COURT MINUTE SHEET BEFORE JUDGE MUSTI 88888 COOK, RANDT, CT RPR (Volume: 00022-Blip: 00230) 02/13/2008 *ORDER FOR BENCH WARRANT-FAILURE TO APPEAR 03070 AGAINST MANDI BISHOP (Volume: 00022-Blip: 00362) BY THE CT MARIA MUSTI COOK JUDGE 02/13/2008 *CIVIL BENCH WARRANT ISSUED & INTEROFFICED 91 05021 (Volume: 00022-Blip: 00362) 02/13/2008 *FATHERS EXPERT REPORT W/CERT OF SERVICE 05103 (Volume: 00023-Blip: 00211 ) 2007-FC-001180-03 BISHOP, DERRICK L vs. BISHOP, MAND/ R Date Action Type Pages 02/12/2008 *ORDER RE: DEFT TO SHOW CAUSE AS TO WHY SHE 04104 FAILED TO APPEAR AT CALL (Volume: 00021-Blip: 00480) OF CUSTODY TRIAL LIST AND CT DIRECTS DEFT WHY SHE SHOULD NOT BE HELD IN CONTEMPT OF COURT BY THE COURT RICHARD K RENN PRES JUDGE 02/12/2008 *NOTICE GIVEN RE: PA RCP 236 W/DOCUMENTS 05032 FILED AND MAILED TO MANDI (Volume: 00021-Blip: 00480) BISHOP AT BOTH ADDRESSES GIVEN ON 2/12/08 AT 11AM AND FAXED TO MICHAEL KROUT ESQ AND CLLYDE VEDDER ESQ ON 2/12/08 AT 9:31 AM 02/04/2008 *RULE TO SHOW CAUSE WHY DEFT SHOULD NOT BE 04957 HELD IN CONTEMPT FOR (Volume: 00018-Blip: 00027) FAILING TO COMPLY WITH THIS COURTS ORDER OF 1/11/08 RULE RETURNABEL IS 2/13/08 AT 9AM IN CT ROOM 9 BY THE COURT MARIA MUSTI COOK JUDGE 02/04/2008 *NOTICE GIVEN RE: PA RCP 236 W/DOCUMENTS 05032 FILED AND FAXED TO MANDI (Volume: 00018-Blip: 00027) R BISHOP ON 2/4/08 AT 3PM AND FAXED TO CLYDE VEDDER ESQ ON 2/4/08 AT 1:42PM 02/04/2008 *ORDER SCHEDULING CUSTODY TRIAL FOR FEB 08 03010 TERM CUSTODY INTERIM ORDER (Volume: 00018-Blip: 00028) SCHEDULED FOR 2/19/08 AT 2:30PM IN HEARING ROOM 3 PENDING TRIAL PARTIES SHALL COMPLETE KIDS WORKSHOP AND FILE THEIR CERT OF COMPLETION BY 2/22/08 CURRENTLY PARENTS SHARE LEGAL AND PHYSICAL CUSTODY BY INTERIM ORDER ENTERED 1/14/08 BY THE COURT MARIA MUSTI COOK JUDGE 02/04/2008 *NOTICE GIVEN RE: PA RCP 236 W/DOCUMENTS 05032 FILED AND MAILED TO MANDI (Volume: 00018-Blip: 00028) R BISHOP ON 2/4/08 AT 3PM AND FAXED TO CLYDE VEDDER ESQ ON 2/4/08 AT 1:42PM 01/29/2008 *PLTFS MEMORANDUM FOR CUSTODY PRE-TRIAL 04185 CONFERENCE W/CERT OF SVC (Volume: 00015-Blip: 00236) 01114/2008 *ORDER FOR PRE-TRIAL CONFERENCE SCHEDULED 04117 OF 2/4/08 AT 9:30AM IN (Volume: 00006-Blip: 00298) 2007-FC-001180-03 BISHOP, DERRICK L vs. BISHOP, MANDI R Date Action Type Pages HEARING ROOM 3 BY THE COURT MARIA MUSTI 04117 COOKJUDGE 01/14/2008 *NOTICE GIVEN RE: PA RCP 236 W/DOCUMENTS 05032 FILED AND MAILED TO MANDI R (Volume: 00006-Blip: 00298) BISHOP ON 1/14/08 AT 3PM AND FAXED TO CLYDE VEDDER ESQ ON 1/14/08 AT 1:29PM 01/14/2008 *INTERIM ORDER FOR CUSTODY PENDING TRIAL FOR FEB 08 TERM A DEPENDENCY (Volume: 00006-Blip: 00299) HEARING IS SCHEDULED FOR 1/2/08 CT WILL TEMP AWARD JOINT LEGAL CUSTODY AND SHARED PHYSICAL CUSTODY BETWEEN THE PARTIES AS OUTLINED IN ORDER BY THE COURT MARIA MUSTI COOK JUDGE 05457 01/14/2008 *NOTICE GIVEN RE: PA RCP 236 W/DOCUMENTS 05032 FILED AND MAILED TO MANDI R (Volume: 00006-Blip: 00299) BISHOP ON 1/14/08 AT 3PM AND FAXED TO CLYDE VEDDER ESQ ON 1/14/08 AT 1:28PM 12/28/2007 *CONCILIATION CONFERENCE MEMORANDUM 04928 SUBMITTED BY CLYDE W VEDDER ESQ (Volume: 00193-Blip: 00300) COUNSEL FOR PLTF W/CERT OF SVC 12/21/2007 *AFFIDAVIT OF PROOF OF SERVICE OF COMPLAINT FOR CUSTODY AND (Volume: 00192-Blip: 00357 ) DIRECTIVE UPON DEFT BY REG AND CERT MAIL ON 12/20/07 12/12/2007 *CASE REACTIVATED (Volume: 00185-Blip: 00317) 12/12/2007 *COMPLAINT FOR CUSTODY= W/ CERT OF SVC (Volume: 00185-Blip: 00318) 12/12/2007 *DIRECTIVE APPOINTING CUSTODY CONCILIATOR JAMES HOLTZER ON 12-31-07 (Volume: 00185-Blip: 00318) @ 9:00 HR 7 07/30/2007 *CASE FILED IN BOX NUMBER 2007.41 (Volume: 02007-Blip: 00041 ) 07/05/2007 *ORDER RE: CUSTODY (IN ADVANCE OF PRE-TRIAL CONFERENCE SCHEDULED FOR (Volume: 00099-Blip: 00059) 7/2/07 COUNSEL FOR PLTF FILED A PRAECIPE TO REMOVE THE ACTION AS WITHDRAWN WITHOUT PREJUDICE AND IT IS SO ORDERED BY THE COURT RICHARD K RENN PRESIDENT JUDGE 04505 05100 05085 04929 99999 04104 2007-FC-001180-03 BISHOP, DERRICK L vs. BISHOP, MANDI R Date Action Type Pages 07/05/2007 *NOTICE GIVEN RE: PA R. C. P. 236 MAILED TO MANDI 04089 R BISHOP AT 11 AM (Volume: 00099-Blip: 00059) AND FAXED TO CLYDE VEDDER ESQ AT 3:32PM 06/27/2007 *AFFIDAVIT OF PROOF OF SVC OF THE COMPLAINT 04505 AND THE DIRECTIVE BY (Volume: 00095-Blip: 00191 ) CERT MAIL TO DEFT ON 6/25/07 06/26/2007 *CASE WITHDRAWN WITHOUT PREJUDICE W/CERT 04510 OF SVC BY PLTF (Volume: 00094-Blip: 00391 ) 06/21/2007 *DIRECTIVE APPOINTING CUSTODY CONCILIATOR 04929 JAMES A HOLTZER ESQ (Volume: 00092-Blip: 00264) 07/02/2007 AT 1 PM IN HEARING ROOM 7 ON 4th FLOOR 06/21/2007 *COMPLAINT IN CUSTODY ACTION= 04076 (Volume: 00092-Blip: 00264) 06/21/2007 *CUSTODY FEE RE: ACT 119-96 05188 (Volume: 00092-Blip: 00264) Party Type Party Name P BISHOP, DERRICK L A VEDDER, CLYDE WILLIAMSON D BISHOP, MANDI R Total Number of Pages : 0 • York County Assessment Report Window 27000PE0024DO00000 BISHOP EARL R JR & CAROLYN L 659 SAWMILL RD Property Location - 659 SAWMILL RD Acreage - 4.270 Land Class -107 Book/Page - 78P-667 Clean/Green Status - N Assessment Date: 1/1/1998 Land: 59720 Building: 106720 Total: 168440 Grantor. BISHOP EARL R JR & CAROLYN L Sale Price/Date: on 1/1/1940 Homestead Code: H Homestead Approved/Denied: A Homestead %:100.00 Farmstead Code: Farmstead %: Close Print Wlndow ! Prir! Report Annex "B" http://216.174.25.68/york/report.asp?p=2 Page 1 of 1 7/29/2008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION LEEANN HANSEL, No. 2008-4405 Plaintiff . VS. DERRICK L. BISHOP Defendant Custody Action CERTIFICATE OF SERVICE I, Stephanie M. Warehime, Secretary to Clyde W. Vedder, Esquire, of the law firm of Morris & Vedder, 32 North Duke Street, PO Box 544, City of York, York County, Commonwealth of Pennsylvania, 17405, do hereby certify that on this 29th day of July, 2008, I served a true and correct copy of the Preliminary Objections, by placing the same in the United States mail, postage prepaid to: Mark T. Silliker, Esquire 5922 Linglestown Rd. Harrisburg, PA 17112 Hubert X. Gilroy, Esquire 10 E. High St. Carlisle, PA 17013 MORRIS & VEDDER MORRIS & VEDDER 32 N. DUKE ST. YORK, PA r BY: S phanie M. Warehime, Secretary to Clyde W. Vedder, Esquire r•:3 f- SFP 0 z /008 LEANN HANSEL, : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v CIVIL ACTION - LAW DERRICK LEVI BISHOP, NO. 2008-4405 Defendant IN CUSTODY COURT ORDER AND NOW, this day of August 2008, the Conciliator being advised the parties have reached an agreement and a Conciliation Conference is no longer needed, the Conciliator relinquishes jurisdiction. '?4x Hubert X. Custody S y, Esquire ? .-?, r- ? .? i°i`t N ?? .. ? ?: rw A