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Home My WebLink About01-0180AMY CHAPPIE, JOHN CHAPPIE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff * Defendant * NO. CIVIL ACTION - LAW COMPLAINT IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, AMY L. CHAPPIE, by her attorney, Timothy J. Colgan, Esquire, of WILEY, LENOX, COLGAN & MARZZACCO, P.C., and files the following Petition for Custody: 1. Plaintiff, AMY L. CHAPPIE, resides at 6234 Stanford Court, Mechaniesburg, Cumberland County, Pennsylvania since April of 2000. 2. Defendant, JOHN CHAPPIE., resides at 9 Morari Drive, Dillsburg, York County, Pennsylvania. 3. Plaintiff and Defendant are the natural parents of one minor child, Jonathan D. Chappie, D.O.B. 09/28/98. 4. The child was not bom out of wedlock. 5. Jonathan D. Chappie, currently resides with the Plaintiff at 6234 Stanford Court, Mechanicsburg, Cumberland County, Pennsylvania since April of 2000. 6. There are no court orders establishing custody or visitation. 7. Plaintiffhas no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. Plaintiffdoes not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the child. 9. The best interest and permanent welfare of the child will be served by granting the relief requested herein. WHEREFORE, Plaintiff requests the Court enter an Order granting primary physical custody and shared legal custody of the minor child to Plaintiff. Dated: Respe..ctfully submitted, Timothy J. WILEY, LENOX, COLGAN & MARZZACCO, P.C. 1 South Baltimore Street Dillsburg, PA 17019 (717) 432-9666 I.D. #77944 C:ISERVER-IISERVERICLIENTSICOLGAN~CHAPPIEICUSI~PET VERIFICATION 1, AMY CHAPPIE, verify that the statements made in this document are tree and correct to the best of my knowledge, information, and beliefi I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. {}4904, relating to unswom falsification to authorities. Plaintiff '~ ~/ C.'ISERVER-I~SERVERICLIENTS~COLGAN~CHAPPIEICUSI~PET AMY CHAPPIE, Plaintiff VS. JOHN CHAPPIE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-180 : : CIVIL ACTION - LAW : CUSTODY ORDER OF COURT AND NOW, this ~'~'~ day of /~_~ ~_[-~ ,2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Amy Chappie and John Chappie, shall have shared legal custody of the minor Child, Johnathan D. Chappie, born September 28, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of Pa. C. S. § 5309, each 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. Mother shall have primary physical custody. Father shall have partial physical custody according to the following schedule: For the weekends of February 24, 2001, and March 10, 2001, from Saturday morning at 8:30 a.m. until 4:00 p.m. Monday. For the weekends of March 23, 2001, and April 6, 2001, from Friday morning at 8:45 a.m. until 4:00 p.m. on Monday. For the weekends of April 19, 2001, and May 3, 2001, from 8:45 Thursday morning until 4:00 p.m. Monday. Effective May 16, 2001, on alternate weeks, from 8:45 a.m. Wednesday until 4:00 p.m. Monday. Effective February 28, 2001, each Wednesday from 8:45 a.m. until 4:00 p.m. From February 23, 2001, through March 16, 2001, each Friday from 8:45 a.m. until 4:00 p.m. AMY CHAPPIE PLAINTIFF V. JOHN CAPPIE DEFENDANT 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-180 CIVIL ACTION LAW 1NCUSTODY ORDER OFCOURT AND NOW, this 12th _ day of January ,2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear beforeMelissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 20th day of February ,2001, at 11:00 a.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 THECOURT, By: /s/ Melissa P. Greevy, 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 No. 01-180 3, Each party will keep the other informed of a telephone number where they can be reached concerning issues related to custody of the Child. 4. Holidays. The parties shall alternate the following holidays: Memorial Day, Labor Day, Independence Day. In odd-numbered years Father shall have Memorial Day and Labor Day and Mother shall have Independence Day. In even-numbered years Father shall have Independence Day and Mother shall have Memorial Day and Labor Day. New Year's Eve/New Year's Day shall be shared according to an NB schedule. Segment A shall be from December 31't at 9:00 p.m. until January 1`t at 2:00 p.m. Segment B shall be January 1,t at 2:00 p.m. until January 2"~ at 7:00 p.m. In odd-numbered years Father shall have Segment A and Mother shall have Segment B, In even-numbered years Mother shall have Segment A and Father shall have Segment B. Christmas shall be shared in an NB schedule. Segment A shall be from December 24th at 9:00 p.m. until December 25th at 2:00 p.m. Segment B shall be from December 25t~ at 2:00 p.m. until December 26th at 7:00 p.m. In odd-numbered years Father shall have Segment A and Mother shall have Segment B, In even-numbered years Mother shall have Segment A and Father shall have Segment B. Each year Father shall have from the Wednesday before Thanksgiving until 3:00 p.m, Thanksgiving Day. E. Mother's Day shall be with Mother and Father's Day shall be with Father. F. The holiday schedule shall supercede the regular custodial schedule. 5. Vacation. Each party shall be entitled to two non-consecutive seven-day periods which shall run from Saturday to Saturday commencing with the vacationing parent's custodial weekend. Each party shall provide at least a thirty-day notice to the other parent with regard to their vacation plans. In the event that the parties have scheduled conflicting vacation plans, the party first providing written notice to the other parent shall have the choice of vacation time. 6. Transportation. The parties shall exchange custody at the daycare center unless otherwise agreed. Transportation shall be provided at the commencement of the parent who is commencing their period of custody. No. 01-180 Dist: BY THE COURT, Timothy J. Colgan, Esquire, One S. l~altimore Street, Dillsburg, PA 17019 Barbara Sumple-Sullivan Esquire, 549 Bridge Street, New Cumberland, PA 17070 AMY CHAPPIE, VS. JOHN CHAPPIE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-180 .' : CIVIL ACTION - LAW Defendant : 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 CURRENTLYIN CUSTODY OF Johnathan D. Chappie September 28, 1998 Mother 2. A Custody Conciliation Conference was held on February 20, 2001, with the following individuals in attendance: the Mother, Amy Chappie, and her counsel, Timothy J. Colgan, Esquire; the Father, John Chappie, and his counsel, Barbara Sumple-Sullivan, Esquire. Date The parties reached an agreement in the form of an Order as attached. Melissa Peel Greevy, Esquire Custody Conciliator IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY J. CHAPPIE, Plaintiff NO. 01-180 CIVIL ACTION - LAW JOHN I. CHAPPIE, JR., Defendant IN CUSTODY PRAECIPE TO THE PROTHONOTARY: Please withdraw my appearance on behalf of Plaintift; Amy J. Chappie, in the above-captioned action. Dated Timothy J. Co~g~re The Wiley Group 1 South Baltimore Street Dillsburg, PA 17019 Please enter my appearance on behalf of Plaintiff, Amy J. Chappie, in the above- captioned action. 3~Iv(or ~ Dated P P.O. Box 886 Harrisburg, PA 17108 (717) 232-1851 Atty. I.D. #75954 CERTIFICATE OF SERVICE I do certify that I served a tree and correct copy of the within document upon the following by depositing a copy of same in the United States mail, postage prepaid, addressed as follows: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 Dated: March 15, 2001 Peggy Hile, Secretary to J. Paul Helvy, Esquire Killian & Gephart, LLP 218 Pine Street P. O. Box 886 Harrisburg, PA 17108-0886 (717) 232-1851