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HomeMy WebLinkAbout01-4591 LISA $. SCHAPPELL PLAINTIFF M/TCHELL E. SCHAPPELL : DEFENDANT : IN THE COURT OF COMMON PLEAs OF CUMBERLAND COUNTy, PENNSYLVANIA 01-4591 CIVIL ACTION LAW INCUSTODY AND NOW, Tuesda , Se tember 04, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunda , Es . , the conciliator, a~;~''1;~;;'~ on Thurs..._day, Se tember 13,2001~ at 8:30 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 a/so be present at the cunferencc. provide grounds for entry of a temporary or permanent order. Failure to appear at the conference may 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/ n . d Custody Conciliator The Cotwt of Common Pleas of Cumberland County is required by law to comply with the Americans w/th Disabilites Act of 1990. For in/brmation 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. HAVE YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT 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 Liber~ Avenue Car/isle, Pennsylvania 17013 Telephone (717) 249-3166 LISA J. SCHAPPELL, Plaintiff MITCHELL E. SCHAPPELL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION. LAW : CUSTODYNO. ~1~- '/-/.O~/ 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: ByL 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) 249-3166 (800) 990-9~ 08 LISA J. SCHAPPELL, Plaintiff V. MITCHELL E. SCHAPPELL, Defendant IN THE COURT OF' COMMON PLEAS CUMBERLAND COUNTy, PENNSYLVANIA CIVIL ACTION ~ LAW CUSTODy NO. CUSTODy COMPLAINT AND NOW, comes Plaintiff, Lisa J. Schappell, through his attorney, the Law Office of Darrell C. Dethlefs, and avers the following: 1. Plaintiff is Lisa J. Schappell, an adult individual with a residence lOCated at 234 2. East Mulberry Avenue, Carlisle, Pennsylvania 17013. The Defendant is Mitchell E. Schappell, an aclu t individua with a residence 3. located at 1160 Harrisburg Pike, Carl sie, Pennsylvania 17013. P/aintiff Seeks Primary physical and joint legal custody of Amanda Schappell, born 12/7/83, Alesha Schappell, born 9~28~88,and Ariel Schappell, born 12/10/91, (hereinafter known as Children). 4. Plaintiff, Lisa J. Schappell, and Defendant, Mitchell E. SchappeU are married. Alesha SchappeU 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 8. stable, Secure environment in which to raise the children. 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, Plaint ff respecffu physical custody of t~,-, ~,-:,-. Ily requests this C ,.~ ,_ . "~ ~,,aren and the right of ,:,.o_.,,,, t.u grant joint legal cus* ...... · -~[ refusal for chi/,~ ..... ~.u~y anc~ primary ..... ~-,,-~ ~o r'lamtiff. Respectfully Submitt~-~ 3805 Market Street Camp Hill, PA 17011 (717) 975-9446 LISA J. SCHAPPELL, Plaintiff V. MITCHELL E. SCHAPPELL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW CUSTODY NO. 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 '$904, relating to unsworn falsification to authorities. Date: ~7-/,¢~'-~/ .~-'~"~' ../', /¢ (~ ,~ _ ~L~ ~Sc Ppell - ~ Darrell C. Dethlefs* Michael J. Pykosh* Brian K. Zellner LAW OFFICE OF DARRELL C. DETHLEFS 3805 Market Street CampHill, PA 17011 Phone: (717) 975-9446 Fax: (717) 975-2309 E-maih DDethlefs@aol.com Web Site: http://www, lawyers.com/dethlefslawoffice Sherry L. Deckman *Licensed PA Title Agent 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~, ~ vlichael j. ~ykosh MJP/rss Enclosure P.O. Box 368, Camp Hill, PA 17001-0368 ' FiLE I~o.5~5 07×1£ '01 15:48 ID:~PLS CARLISLE OFFICE t/dPenn Lega/Services $ Irvine Rnw, C~rli~ie, I:.A 170~3 Phone 717'2~-9400 l~00.822.$288 FAX 717-243-8026 ,.__~...FAX:7172438028 DH:~w Law Ofrices of Darrell Dethlef$ 3805 Mark=t Street Camp Hill, PA 17~1 D~ Mr. Pykolfl: Suly 12, 2001 We Wish to refer a caae involving Lisa j, SChaPpell. and i3 in need ofassisiance With a custody matter. ,She is a conflict Ibr our office her contact With her Children. The father, MitChell $chappeIl, is denying Piea,~e let us know as soon as PO~lble if you can take th/~ eaae. Thank you/'or your cooperation in making the p~'o &o,o ~ya~em a success. ,S/neerely, LI~GAL ,SSRVICES, INC. Dru ltewltt Private Bar COordinator LSC LISA 1. SCHAPPELL : PLAINTIFF : V. MITCHELL E. SCHAPPELL : DEFENDANT : 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-4591 CIVIL ACTION LAW IN CUSTODY 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, Es~qt _, the conciliator, at 39 West Main Street, Mechaniesburg, PA 17055 on Thursd~ay, September 13, 2001 at 8:30 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. The court hereby directs the parties to furnish auy 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/ l!a vn s. $unclay. e. sq._ 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 conlbrence 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 Cra'lisle, Permsylvania 17013 Telephone (717) 249-3166 LISA J. SCHAPPELL, Plaintiff MITCHELL E. SCHAPPELL, Defendant : IN TIlE COURT OF' COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA .. .. : CIVIL ACTION - LAW : CUSTODy NO. ~1~ 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: By:__ 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) 249-3166 (800) 990-9108 LISA J. SCHAPPELL, Plaintiff MITCHELL E. SCHAPPELL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : CUSTODY NO. CUSTODY COMPLAINT AND NOW, comes Plaintiff, Lisa J. Schappell, through his attorney, the Law Office of Darrell C. Dethlefs, 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 12/10/91, (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 Submit~'"~ Attorney I.D. 58851 3805 Market Street Camp Hill, PA 17011 (717) 975-9446 LISA J. SCHAPPELL, Plaintiff MITCHELL E. SCHAPPELL, Defendant IN THE COURT OF' COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODY NO. 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: /h/, £Li-s'~ 3. Scl~pell '" Darrell C. Dethlefs* Michael J. Pykosh* Brian K. Zellner LAW OFFICE OF DARRELL C. DETHLEFS 3805 Market Street Camp Hill, PA 17011 Phone: (717) 975-9446 Fax: (717) 975-2309 E-mail: DDethlefs~aoLcom 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: Schapellv. 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 ~s 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_, MJP/rss Enclosure ~ Addres_s: P.O. Box 368, Camp Hill, PA 17001-0368 · F~LE t~o.5~o5 07/12 'Of ~5:48 ID:/'lPL$ CARLISLE OFFICE FAX:7172435026 PAGE M. idPenn Legal Services Pgone ?17-243-9400 1-800-822-5288 FAX 717-243-,q026 Michael Pykosh, Esquire Law Offices of Darrell D~thlcfs 3505 Market Street Camp blill, PA 17001 July 12, 2001 Dear Mr, Pykosh: We wish to refer a case involving Lisa .1'. Schappe~l. She is a conflict tbr our office and id in need of assistance with a custody matter, The father, Mitchell Schappell, is denying her contact with her children. Please let us know as soon as possible if you can take this case. Thank you For your cooperation in making the pro bono sys~era a suCceSS, Sincerely, LEGAL SERVICES, INC, DH:aw Dru ltewitt Private Bar Coordinator ' LLSC LAW OFFICE OF DARRELL C. DETHLEFS By: Michael J. Pykosh, Esquire Attorney Identification No. 58851 3805 Market Street Camp Hill, pA 17011 (717) 975-9446 LISA J. SCHAPPELL, Plahlfiff MITCHELL E. SCHAPPELL, Defendant To the Prothonotary: : IN 1'HE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW PRAECIPE Please fonvard 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, Michael J. Pykosh, Esquire Darrell C. Dethlef$* Michael J. Pykosh* Brian K. Zellner LAW OFFICE OF DARRELL C. DETHLEFS 3805 Market Street Camp Hill, PA 17011 Phone: (717) 975-9446 Fax: (717) 9?5-2309 E-mail: DDethlefs@aol.com Web Site: http://v~vw.lawyemcom/dcthlefslawoffiee Legal Assistants Sherry 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. 8chappell Custody Matter, No. 01-459t To the Prothonotary: Please mark the above-captioned matter withdrawn. Michael J. Pykosh MJP/rss cc: Mitchell E. Schappell Dawn Sunday, Esquire Mailing Address: P.O. Box 368, Camp Hill, PA 17001-0368 LISA J. SCHAPPELL, Plaintiff VS. MITCHELL E. SCHAPPELL, Defendant 2001 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-4591 CiVIL ACTION LAW : IN CUSTODY ORDER OF COURT AND NOW, this 3rd 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