HomeMy WebLinkAbout94-00233
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1
JUN 22 1994d",-
VINCEN'l' P. MI'l'CHELL,
Plaintiff
: IN 'l'HE COUR'l' OF COMMON PLEAS OF
:CUMBERLAND COUN'l'Y, PENNSYLVANIA
v
.
.
:NO. 233 - CIVIL - 1994
.
.
ANNE'l''l'E C. MI'l'CHELL,
Defendant
.
.
:CIVIL AC'l'ION - CUS'l'ODY
COUR'l' ORDER \
AND NOW, this "'2..L- day of jv~, 1994, upon
consideration of the attached Custody Conciliation Report, it is
ordered and directed as follows:
1. A Hearing is scheduled in the above case for 'l'hursday,
August 11, 1994, at 8:45 A.M. in Courtroom No. 2 of the
Cumberland County Courthouse in Carlisle, Pennsylvania.
At this Hearing, the Father, Vincent P. Mitchell, shall
be deemed to be the moving party and shall proceed
initially with testimony. Counsel for the parties are
directed to file with the Court and opposing counsel a
memorandum at least ten days prior to the Hearing date,
which memorandum shall set forth a sununary of each
client's position on custody and shall also set forth
a list of each witness that will be called to testify
at the Hearing along with a brief summary of the
anticipated testimony of that witness.
2. Pending further Order of this Court, the Father, Vincent
P. Mitchell, and the Mother, Annette C. Mitchell, shall
enjoy shared legal custody of Cortney Ann Mitchell, born
December 21, 1984, and Corinne Kathleen Mitchell, born
May 24, 1987.
3. The parties shall share physical custody under the following
arrangement:
A. Mother shall enjoy physical custody on three out of
every four weekends from 'l'hursday at 8 A.M. until
Sunday at 8 P.M. These shall be consecutive weekends
and shall start on June 9. Additionally, on the
'l'hursday and Friday before the weekend where Father
shall have physical custody of the children, Mother
shall have physical custody on that Thursday and
Friday from 7 A.M. until the end of Father's working
time at which time Father shall pick up the children
on each Thursday and Friday from Mother's custody.
co:
Rebecca Hughes, Esquire _ c.,~,,- .p.l.,,,,,-<L....:., f:.f..
Bradley Griffie, Esquire U ~
...
.
B. Father shall have physical custody of the minor
children at all other times, except as agreed upon
by the parties.
4. In the event Counsel for the parties feels a Conciliation
Conference prior to the above scheduled Court Hearing will
aide in the resolution of this case, C~nsel may contact the
Custody Conciliator for another Conference an attempt to
resolve the issues in this case pri6r to t e Hear. ng.
I ':11 J 30 ' I ~ ' '9~
,..lUU U.. : fj
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VINCENT P. MITCHELL,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
v
.
.
:NO. 233 - CIVIL - 1994
.
.
ANNETTE C. MITCHELL,
Defendant
.
.
:CIVIL ACTION - CUS'I'ODY
PRIOR JUDGE: JUDGE EDGAR B. BAYLEY
CONCILIATION CONPERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the
following report:
1. The pertinent information pertaining to the children who are
the subject of this litigation is as follows:
Cortney Ann Mitchell, born December 21, 1984, and Corrine
Kathleen Mitchell, born May 24, 1987.
2. A Conciliation Conference was held on June 2, 1994, with the
following individuals in attendance:
The Father, Vincent P. Mitchell, with his counsel, Rebecca
Hughes, Esquire, and the Mother, Annette C. Mitchell, with
her counsel, Bradley Griffie, Esquire.
3. The parties were before the Conciliator in February for a
prior Conference. At that time an Agreement was reached to
undergo a Custody Evaluation. The parties have undergone a
Custody Evaluation with Nancy Small of Franco and Associates.
There is still some additional work that needs to be completed
with respect to that evaluation. The parties are not able to
reach an agreement on custody, and a Hearing is necessary.
4. The parties will continue to negotiate. The Hearing is not
scheduled until August and is scheduled in time to allow for
the issue of where the children will go to school to be
addressed at that Hearing. The parties are currently unsure
of their permanent home in that the marital home is being sold.
5. The Counsel for the parties requested the opportunity to meet
with the Conciliator again if they felt such a meeting would
be beneficial prior to the Custody Hearing.
6. The parties, upon the advise of the Conciliator, have reached
V.... ,.-~' .....
~~~:'.
an agreement relative to physical custody pending the Hearing
and that agreement is set forth in the proposed Order.
k-
-- -
.
.-j Student Progress
Gr:lIle 1
Report IStudent rOI 'innp /VI itfl.!Jp/ I
2 3 4 2 3 4
LANGUAGE MATHEMATICS
DEVELOPMENT
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olhers
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or :ani/cd v
'l"lhll: am cun.~llklalc
or olhns V
l riale limes' V -
II V V
ATTENDANCE 2 3 4
I Davs Ah<mt I g I/gl -cfl
Number tim", lale
PI.AINTlFPS
'EXHIBIT
SOCIAL STUDIES
DnIIMnlS:
I~
IS~/ENCE
(;CJm1Mnls:
I'~ I~ t~ I,
Il <J 1\ 9 I' ~ I.
1'~~~:~
Evaluation Key ror Subjects
G. Goodlndko....dll..._...,...................
npectlbona. Studcnu c::tNbil ou"Plional Wldmllftcfl"l oldie
Itunina. ClClmpktc cia.. ..iam-u. Md wort ~"'"'I,.
S . SlUl'lctory IMMlIhe.laIlIc:M II perfonnlnl ..
. Inel eapec:1Cd by Ihe cwriQlklm lor hi. CIt her Jnde. An 5 tN,
be KC:I:lrnfIMJCld wi1h.. U or.. L
H . High ,...,
L . Low'...'
N . N..ds Improvement meaftl dM: child It
hninlllirlicull,lnd lruvucUonIlaulsuMC rana, Somedma a
d\lld UrN In N by nOI comp1ebnl ...Ianmmll, raUlnl ,.
renlC.rue in dill. 0' nhibihl'lJ , ne,.".. IILlwde &ewlId
lam.,..
,"4 _--.....:...
.. .:.-
'.' -..---. ._.. ....-':.---;..--...- .'---:";.::":""=-.;~.~-:--: -- '-r--:--'-.. --~.. --- _.. -.,
COMMENT STATEMENTS
Work Hablll
I, Wori<'''dllndcpendaoly
2.FoIlo...dinleti....
],Wori<b_ondC&l)'torad
4, II ...U prqlOIOd roe d...
5, Ml.... wort duo to_
6, Copbl.olbeu<<_
7. PIe...,hid..tren
.. Strivca fer kCW-=Y
Performance
9. Showl imprvvcmcnt.
10, Tries to do hlllll<<.....
II.~
12.. Ccn:ributcl Lnclua
I], Wortdna belo..Cnd.I....
.-
Are.. to Improve
.". Needlto lUG lime wildy
IS. NeedI to compldo uaiaracnu
I6.S.....to_pl...hom.wat
17, S.....topn<lice readln& 1IdII.
.."""'.
II, Ne<d.tochcctwort
19, S.....to _... responolllilily
20. NcedI to (oUow clitecIiont
21. N..... to wort on..1lh r_
22.Necdsto_._
23. Necdlto (oUownll"
2". Shcaald pWcip.&emora inclua
2.l. Should try tobe..-
Other
31. Receivel special help
]6 I'~f'.'!-I -, I S
]7, '* rtgpj;~/Xfrg
]I, rl-'. ts
:JheaCher a. WIllI )l)rtl ,t
I Carllsla Area School District
623 West Penn Street
Carlisle PA 17013
ikill Progress Indicators
+ . EaccUnpro.,..lndWIkiU.,.
V . SaUltIClOr7P"01"*ilIbiaWU..
- . NeedlmorcworklntlUlu.W..
.0 mark mUD' tbat tbe skill ana ... Dot
rtlewrd or cmpblslud thI. report ptriod.
Promol.d to Gr.d.
R,'lln.d In Gnd.
TEACHER COMMENTS
~. (!or//)nc; 15 . trYII) q I/fry, hOld
In (',rst grode. SIte is 'tC1Hin!J
f;PI' ilJ)lE; /lid/) her reocllr'9. Oriel
IS obIt to he St./fe8ssftd in
1'f;DrllI7!i wu'd.; (1/ lei swr/eS.
PleoJe (l()/Jtinue j/I'/orkt'nQ vVltJJ
!Jet' (It heme. tOl'lnlJc lirlr/ Cf
/dUe t.J'ouh/e WI t/,I flit to }(lotJIR..
of suhtl-rlftlcn, hut Wf'v~ Lf~iJ
we/!1IIlQ ell It III (l/c/:JS.5/)6-
/'::::'1/1;/ 1.lO:; t, /}('/Jf:;/7!I!t~ '1/)
;t~'/:;~/ /~Irt:c./ ~'l.,:; jN5:l(,' .te~!J
':':/,,"- '.:J 0/1.. f't.:('111,1')8 IS (I f') cO,? pr
0.n(/ ,(;..nthuSIO'::' 7r!.- INLrkpr!oJr'
If; winne I~ r5ud> a p/etl.3VJ'C" .scCl
..first Brader. 01e fi<.2 l'e/dl:! dO'le t1
-Pine.. J 126 tY) {+r s t ,Brat!,e. Plerae
(!.{)')onl.(.e., WOf'~I~ tJfPJ1Br ffi IS
SUmmer. @
READING MATERIALS
BlSal Rudlnl ProVlm
_ <l<mncR...,..""",oc-)
..L 1Idb(l'lo.......I)
--L IlNmI ("..".".... 2)
......IL T......... (I'lo.primor l)
..1L ""- lPm'o<)
c.....~ (Book 1.2)
RUdlas Pro.rea
V" Emaaa1'Rood", Level
I. / e.ty R.... Level
_ Early Aucn:y Lev.1
OTlIE'h
An '"X-lndlClU'el CUftftt boot tc-d
-___.__...__.__.__ __ ____._.__._.._ -___ .._~_____._____.____. _ ..4
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Art
2
oS
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Skill. Gnd.
"'lIIud./Ello,!
Comments
Additional Comm,nls:
...
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Carlisle Area School District
UJ Will Plnn Sind
Carll.l. PA 17013
3
Ttach,,: /h(,UJ, cA'~? /'t L
EI,m,nla" Sp,ciallsl RtpOrl for: lJJ(Jrj 17nA /V)//;f'hr:/ / ,
93 ..q'f
Music
2
.::>
S III. Grod.
,tlllud./Ello,!
Comments
Additional Comm,nls:
T,acht': /3-, I L
Physical
Ed.2
Skill. Grode
.\llltude/Ello'l
f
r_
Com menU
Addllional COmm,nIS:
,
3
G
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4
G-
w^ o-'t-q l
3 4
c; G
G
T,ach,,:
/ /~
/ A!/~ ~,d --'"
Comm,nl SlalfmlfllS:
Work Habits
I, Malt.. good we 01 time
2. Works wclllndqlendently
3, 1'0UoWl dlm:tions
4, Work is neauncl eaoy 10 tad
5. Is ....U JlII'llU"'l r.. cIuI
6, Misscs work due 10 ablcnces
7, C""b1c olbe=.....k
AUllude Toward Subject
8, Seems 10 enjoy cw.
9. Works very hlld
10, ShoWl respect I.. othen
II. CoopeRia
12. Conlribut.. in cl...
Performance
13, EahibilJ talenl
14,Isauove
15, W...1u up to ability
16. Tri.. 10 do hiJ/ller besl
-".
Areas 10 Improve
17, Nwls to we time wiJcly
18, NoedJ tocomple'" usignmeulJ
19,Needstobe~
20, NoedJ lO.heck_
21. Nwls to usumc ..sponsibility
22. Needs to loUow direetiOllJ
23, Nwls 10 sho.. r=pccl I.. odlas
24, Should panicipaUl """" in cIuI
Olher
25,
26,
27,
EVALUATION KEY FOR SUBJECTS
G . Good
5 . Sadalactory
N . Hood. Improv.menl
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.
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Dear Parent,
We would like to share with you some aspects of your
child's progress in the Reading support program. Recently,
('{l.' ; At -~" .
. <.A-f\/f'-"'-" took a Stanford
Achievement Reading Comprehension Test, a group test which
evaluates reading
for this year is
comprehension.
Sg -;Iv
His/her percentile ranking
Your child was also given an Individual Reading
Inventory, an untimed individual test which evaluates the
level at which your child is able to read. Last year your
child was reading at th~~ntS5grade level. This year's
p,.~,-,_/tJrad~ ~
test showed that s/he is reading at the ~grade level.
Sincerely,
'ih~~
Reading Specialist
...,..- .....
.
, '
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CARLISLE AREA SCHOOL DISTRICT
-.. .".
Elementary School Reading Support Program
Progress Report to Parents
This is a report of your child's progress in the Chapter IlDistrict Reading Support Program:
(J/)rinnp. /14//1'/;(2// frfSiv;'er(V'
Student's Name School
/ ( b-nst Semester (V12nd Semester
Grade Reponing Period
. h.
~
1st
Areas of Emphasis
-j.{t (rr.s (If i/" 17!?17t1DPI
- (',,/llr "void::,
- Rhq m/Ilfj " .
- Bosic.. -:-,'/<1111 /'/Clrr0 IrVin 13~I/sj)rr..(I77'
j 1_
- J::l1i( ,'"f'/ l~i'.I/ (lo'7.:'>,onanlS-
-Shore- i/M',lI'/S QI II 0
- t. /s t-f/;?;'iIlCi A,' l'/v/t!-i~..s
- Wrl t,i,.. Sf'lle ~'ll(! f's
'" ,,'''' ',." -tee...
-" I
· Status
Report Period
sf
semester
semester
Ie S:jJItt- Vbca..6c.{la~-rru..m -<tis
p~
'hurt /tI;v.u& <<c:. i tJ U.
I " " ,
onr.'prehel1.s i~ .5/.-J/I.s'
UYfu1/:r-f k-hV"H't'S
~qra.pH (Sh I wh/ thl ~h)
CJYd.1 r-l'tl 'ft 'ra c.h ce.-'
EP
2nd
----------------------------------------r
Comments: flt;ril?/?~ (.-,~'/7tlilurs -/0 show /1?7proV.(!/n.f'/TT //7 n-Pr
1st ~?J~t~in (1' lasS. S/u:' /s dt7Vr?~1I7q a . qtJdd s(9hr-
V 0 (" d bGA ;:;..Jtf, P / Ni' Sf?.. r: (') 7 /7'n t..r e. I'ra cl bOd ks w d-A her-
Ojlfn. She. $(/elns (;0((1/1,r( a bellt- /"-.Pt:lrollq !
2nd semester {ltJr/fine.. has. rna de. -e'j(. t! e lit#.. r f>;:;~rt'SJ th/s
l5.fmts/Cr."0he. /s r<-a.I!.!I-txt!/t~d about ,...ea.~/'7;6 /7dW! <she..
I}Cls done w.tl/ /n I:fre area...s m~nt7dn~t:f a. i/e.. U'he 11////
not' nt~d r~~ti~':f <.StA./[>>rt cServ/C"t's n.e)t.r !/~ar.
~;)7A4., 7.~tt(i~.,~ J( _ 7:..~~:~.~ ~U~-f/ 1.UJ1.<. )
Reading Specialist
.EP = Excellent Progress
SP = Satisfactory Progress
U = Unsatisfactory Progress
SE = Showing Effort
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Carlisle Area Schoot District
'13 W,ll r,nn Sind
CuU.I, PA 17013
<I.m."", Sp"""'''''''' f'" kf\)( +;" J II I, f, i:W.I
Art 2 3 4
S
G-
Skills Grade
Comm,nt Stat.m.nll:
,\lIltude/Ettart
Work Habib
1. Malt.. &oad..... or u....
2. WOfb wcIJ IndopendcnUy
3, Follows direaiOllS
4, Work is neat........y III lUll
$,Is well pn;pon:d rorclAu
6, Mi.... work d.. III abocnocs
7, Copabl. or be_ w...k
Comments
Additional Comm,nts:
T~ach~r: ill., 1): ((-"~)1''- dto ,~~L-
Altitude Toward Subject
8. Seems to enjoy clau
9. WOfb very hard
10. Shows respect rot alhen
II. CoopctalCS
12. CanmbulCS in dua
Music
Skills Grade
Performance
13, Exhibits IaIcnt
14. Is c:n:aDv.
15, W...ks up to ability
16, Tri.. lD do hlslhcr best
Areas to Improve
17. Needs 10 IlSC U.... wiJeJy
18, NccdJ 10 co~I... uai&nmoats
19, Needs 10 be prepon:d
20, NccdJ lD chock ""'"'
21. Needs 10 us""", ICSpOIIIibWcy
22. Needs 10 tallow dIrocUons
23. Needs lD show _t rot adlcrs
24, Should ponicipuc ""'"' In clAu
Other
25,
2
4
Mlltude/Ettarl
Comments
Additional Comm,nll: N:c c. jo of) I (
the re.Col'<:JC!(',
T,achlr: ;' I <..:. lIt) (,\..LlL'-4 )
Physical Ed. 2
3
4
~ . .
Skills Grade .... ,
,\lIltudeIEttarl L
Comments
Additional Comm,nrs:
T,achlr: (; '..:..,-11 f,.j
26,
27,
.EVALUATION KEY FOR SUBJECTS
G . Good
S . SIUoflclary
N . NHdI Imp,avlm."t
I
-.:~"'-~.
.
.-..--------..
~.._,
-.
,STANFORD
.. ...., ..':',., ...... '1
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..- -~
ACHIEVEHENT TEST SERlES. ElGIITII EDITION
TEACHER. JONES
SCIlDOL. CRESTVIEH
DISTRICT: CARLISLE AREA SD
I
NO.
TESTS OF I RAH SCALED NATL LOCAL
lTEHS,SCORE SCORE PRoS PRoS
Total Readlng 142 I 107 624 65-6 46-5 I
Nord stdy Skill. 43: 46 686 89-8 85-7
Vocabulary 4Di 22 587 34-4 15-3
R..ding Compo 541 39 628 65-6 42-5
Total Hatll 116! 99 640 87-7 71-6
Concopts of No. 341 29 642 85-7 74-6
Coq>uta tton 441 39 646 88-7 71-6 '
Applications 381 31 632 77-7 57-5
: Total Languago 6DI 54 666 88-7 77-7
; Lang Mechanics 3D' 26 652 84-7 7D-6
Lang EMpress10n 3DI 28 684 87-7 77-7
, Spelling 36 : 28 634 71-6 69-6
,
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Racantly till. .tudent took t"" Stanford AchillV...."t T..t. Thl. brlof do.crlptton of t"" .cor..
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a global Indl..-Uon of parfonnanc. on t"" te.t.
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a varl.ty of mat.rlal. .hould be ""l~ful.
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doing wall In working with rual>er concepts. coq>utatlon .kllls. and probl_ .olvlng.
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COPY D2
PROCESS NO. 19423125-37D4-DD699-2
STUDENT SKILLS ANALYSIS
FDR
COURTH A MITCHELL
GRADE: D3
TEST DATE. D4/94
1991
NORIIS I
SPRING
LEVEL:
FORl1.
STANFORD
GRADE D3
NATIlIHAL
PRItlARY 3
J
-
RAN SCORE) RAN SCORE/
CONTENT CLUSTERS IU1IIER ..... - CONTENT CLUSTtRS IUIlER - -
OF ITEI1S ....... ....... ....... OF ITtI1S .- ....... .-
Hard Study Skills 46/ 48 J L8nguage E~ra..lon 28/ 3D J
structural Analysis 11/ 12 J Sentence Correctness 18/ 2D J
Phenotlc Analysis-Consonants 18/ 18 J Sentenc. Effactlvoness 10/ 1D J
Phonetic Analysis-Vowels 17/ 18 J Spelling 28/ 36 J
Raadlng Vocabulary 22/ 4D J Sight Hards 71 8 J
Synonym. 12/ 28 J Phonetic Prlnclp1as 12/ 16 J
ContO)(t 6) 6 J Structural Prlnclp1.s 9/12 J
I1uUlpla liaoning. 41 6 J
RlI8dlng Compr"'-nsion 39/ 54 J
Recroational 11) 18 J
TOKtua1 16) 18 J
FUlCHona1 12/ 18 J
Lltoral 21/ 26 J
Inforontial 16) 25 J
Crl Ileal 2/ 3 J
Thinking SkUls 8) 13 J
Concepts of Number 29/ 34 J I
J.oI'lole Nl..nbers 17/ 18 J
Fractions 2/ 3 J
Operations and Propertl.. 1D/ 13 J
Thinking SkUls 41 6 J
Mathematics Cooputatlon 39/ 44 J
Addltl~lo Numbers 11/ 12 J
s..Gtracllonflot>olo Numbers 111 12 J
t1uU Ipllcallonflot>ola Number. 11/ 12 J
DlvlsionlHhol. Nunbers 61 8 J
Mathemallcs Applications 31/ 38 J
Problom Solving 141 2D J
GrDphs and Chart. 6) 6 J
Gctomet rylHoa.ur.....,t 11) 12 J
Thinking Skills 12/ 12 J
language Hachanlcs 26/ 3D J
Capl tallzatlon 71 7 H.I
PlnCtuatIon 8/11 J
Appl led G,..rrmar 11/ 12 J
READING GROUP
LANGUAGE ARTS GROUP
Vocabulary
Incoq>l.t.
~ .'
IIATHEtlATICS GROUP
Enrlchmont
CllItUIICATIOIlS GROUP
Incomplat.
Scor.~ basad on NorMativ. Oat. Copyright e 199Z by Harcourt Bnte. Jovanovich. Inc. All rld'lt. ,....rved.
COpy D2 PROCESS NO. 19423125-37D4-DD699-2
.
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EDUCATION:
Master of Social Work, Temple University
December 1987
Bachelor of Social Work, Shippensburg University
December 1975
PROFESSIONAL EXPERIENCE:
Oinica1 Evaluator,outpatient Thempist
6/89-. "'1/
Stevens Center, Carlisle. PA
Provided clinical assessments, brief interventions, and treatment planning to
clients requesting services at this community mental health center.
Continued role of outpatient therapist.
Outpatient Thempist
12187-6189
Stevens Center, Carlisle, PA
Provided group, individual, play, and family therapy. Served as Acting
Director of Outpatient Services.
Counseling Coordinator
3/85-12/87
Women In Need, Chambersburg, PA
Provided group and individual counselin~ to victims of domestic violence.
Program development and staff superviSion.
Caseworker
4n8-918l
Cumberland County Office of Aging, Carlisle, PA
Assessed needs of elderly and arranged services to maintain independent
living. Supervised student intems.
Caseworker
9n5-4n8
Cumberland County Nursing Home, Carlisle, PA
Coordinated admissions and social service needs of residents.
SPECIALIZED TRAINING:
Domestic violence, sexual abuse, family therapy, relationship enhancement
skills, play and filial therapy, social skill development with children,
divorce adjustment.
PROFESSIONAL AFFILIATIONS:
PA Social Work License
NASW Member
ACSW,
REFERENCES:
Lynn Loomis, M.Ed., Director of Outpatient Services
Stevens Center, (W) 243-6033
Karen Brandon, MSW, ACSW, Private Practitioner
(W) 258-5915
Kurt Bair, M,S" Senior Counselor
Dickinson College, (W) 245-1485
f!:~EFENO:
,.......".EXH MT'8
I.'j,- IBIT
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Social Worker in Private Practice
2/91 - present
Generalist practice with additional training and focus
in family therapy, children's issues.
.
Social Worker, Mental Health Consultant
9/91 - present
Head Start Program
Shippensburg University
Supervision, consultation and direct services to staff,
children and families.
.,-, , .
;... .._..
--
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VINCENT P. MITCHELL,
Petitioner
ANNETIE C. MITCHELL,
Respondent
NO. .2 3J CIVIL 1994
IN CUSTODY
ORDER
AND NOW, this :;J /5 f- day of - ) '<1'1 . 1994, on consideration of the
attached petition, it is hereby directed that the parties and their respective counsel appear before
Hubert X. Gilroy, Esquire, the conciliator, on the 4th Floor, Cumberland County Courthouse, on
the ~l-tIay of Fr--/? r""h'Y 199!1, at ~1,9 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, Failure to appear at this conference may provide grounds for entry of a
temporary or permanent order.
By the Court,
By: 'fl(-<-IA('::I.h<-l'lf_(-~
Custody Conciliator ~~/'l'
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.
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
J~H ZI/ 2 19 f'II '91/
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VINCENT P. MITCHELL,
Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
V.
CIVIL ACTION - LAW
ANNETIE C. MITCHELL,
Respondent
.
.
NO. .B,3 CIVIL 1994
IN CUSTODY
PETITION FOR CUSTODY
AND NOW. comes the Petitioner. Vincent P. Mitchell. by his attorneys. Irwin, Irwin &
McKnight, and presents the following Petition for Custody:
1.
The Petitioner is Vincent P. Mitchell, an adult individual residing at 1910 Fry Loop
Avenue. Carlisle. Pennsylvania, Cumberland County. Pennsylvania 17013,
2.
The Respondent is Annette C, Mitchell. an adult individual residing at 510 South West
Street, Carlisle. Pennsylvania, Cumberland County. Pennsylvania 17013.
3,
The parties are the natural parents of Cortney Ann Mitchell. age nine (9), born December
21. 1984 and Corinne Kathleen Mitchell, age six (6). born May 24, 1987. The children were not
born out of wedlock.
2
4.
The parties were married on June 2, 1984 in Cumberland County, Pennsylvania, and
separated on September 14, 1993.
5.
Since the date of separation, the children have resided with the Petitioner at 1910 Fry
Loop Avenue, Carlisle, Pennsylvania 17013.
6,
Prior to the separation the children resided with both parents at the following addresses:
1. 408 Hummel Avenue, Lemoyne, Pennsylvania 17043
2. 110 West Coover Street, Mechanicsburg, Pennsylvania 17055
3. 1910 Fry Loop Avenue, Carlisle, Pennsylvania 17013.
7.
The interests and pennanent welfare of the children require that primary physical custody
of the children remain with the father, Vincent P. Mitchell, with periods of reasonable partial
custody to the Respondent.
3
WHEREFORE, Petitioner, Vincent P. Mitchell, respectfully requests that the parties be
awarded joint legal custody and that he be awarded primary physical custody of the children.
Respectfully submitted,
IRWIN, IRWIN & McKNIGHT
By:
Rebecca R. Hughes,
60 West Pomfret Stre
Carlisle, Pennsylvania 17013
(717) 249-2353
Attomey for Petitioner
Supreme Court I.D. No. 67212
Date: January /.3 ,1994
4
~ .:...
VERIFICATION
The foregoing Petition is based upon information which has been gathered by my counsel
and myself in the preparation of this action. The language of the Petition may in part be the
language of my counsel and not my own, I have read the statements made in this Petition and to
the extent that it is based upon information which I have given to my counsel, it is true and
correct to the best of my knowledge, information and belief. To the extent that the contents of
the statements are that of counsel, I have relied upon counsel in making this verification. I
understand that false statements herein made are subject to the penalties of 18 Pa,C.S.A. Section
4904, relating to unswom falsification to authorities,
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IN p. ~CHELL
Date: January {ol'M ,1994
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VINCENT P. MITCHEll,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v.
.
.
94-233 CIVIL TERM
CIVIL ACTION -LA W
.
.
ANNETTE C MITCHEll,
Defendant
:
:
IN CUSTODY
ORDER
AND NOW, this 8 day ot' August, 1994, upon consideration of the attached Motion to
Withdraw Appearance, it is hereby ORDERED that Petitioners Rebecca R. Hughes, Esquire, and
the law finn of Irwin, McKnight & Hughes, are permitted to wit~eap~~o~~ ~
Vincent P. Mitchell, Plaintiff in the above custody actio"e i~ll custody hearing Jlf8'.siO".ly
scheduled for August 11, 1994 is ~b~U~~mti1' .. . IH1,
.a- UCIOCK In \...ounrooIll14u. It Cumh"".J.Jld Cetlni] e~"llI.v...,~.
.:. :1, flCE
Of TI,l. t. ,~OHjTA~Y
CUMl'F"'~';O r0~Nn
PEHh'; (L'iANIL
6UG B 2 19 PH '9~
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r....<~..,'~"....;..~:'.~r'..."-:_ ,.~.
VINCENT P. MITCHEll,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v.
.
.
94-233 CIVIL TERM
CIVIL ACI'ION -LAW
IN CUSTODY
.
.
ANNETTE C MITCHEll,
Defendant
.
.
.
.
ORDER
AND NOW, this day of August, 1994, upon presentation of the Motion to Withdraw
Appearance, IT IS HEREBY ORDERED THAT
A rule is issued upon Plaintiff, Vincent P. Mitchell, and Defendant, Annette C. Mitchell, to
show cause why the relief requested should not be granted. If Plaintiff or Defendant has objection
to Petitioners' withdrawal, written objection must be filed with this Court within
receipt of this Order,
days of
BY THE COURT,
VINCENT P. MITCHEll,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
.
.
v.
.
.
94-233 CIVIL TERM
CIVIL ACTION -LA W
.
.
ANNETTE C MITCHELL,
Defendant
.
.
.
.
IN CUSTODY
ORDER
AND NOW, this
day of August, 1994, it is hereby ORDERED that the custody
hearing currently scheduled in the above-captioned case shall be continued, A hearing on this
matter shall be held on
o'clock in Courtroom
,1994 at
No.2 in the Cumberland County Courthouse, Carlisle, Pennsylvania,
BY THE COURT,
J.
VINCENT P. MITCHELL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v.
94-2JJ CIVIL TERM
CIVIL ACTION -LAW
IN CUSTODY
.
.
:
ANNEITE C MITCHELL,
Defendant
.
.
:
MOTION TO WlTHDRA W APPEARANCE
AND NOW, this
day of August, 1994, come the Petitioners, Rebecca R. Hughes,
Esquire, and the law finn of Irwin, McKnight & Hughes, and file this Motion to Withdraw
Appearance of which the following is a statement:
1.
On or about December 22, 1993, Petitioners were retained by the Plaintiff, Vincent P.
Mitchell, to represent his interests in the above-captioned matter, and entered into an agreement
of representation, a copy of which is attached as Exhibit II A,"
2,
Petitioners have provided representation to Plaintiff in accordance with the fee agreement
entered into by Petitioners and Defendant.
3.
Plaintiff often made representations to the Petitioners regarding his cooperation in
preparing his case, however these representations were not fulfilled, causing much difficulty for
the Petitioners to adequately represent the Plaintiff.
4.
Also, since initiating Plaintift's representation, Petitioners have provided Plaintiff with a
monthly statement for services rendered.
S.
Plaintiff made numerous representations to Petitioners promising payment of said
outstanding bill, however no payment, whatsoever, has been received from the Plaintiff since his
initial retainer fee payment as noted on the fee agreement dated December 22, 1993.
6.
Plaintift's lack of cooperation and availability regarding the merits of his case, as well as
his continual lack of payment for services provided by Petitioners has forced Petitioners to file this
Motion to Withdraw Appearance.
7.
A custody hearing is currently scheduled before this Honorable Court on August II, 1994;
however, Petitioners are requesting that a continuance be granted to allow the Plaintiff to retain
new counsel in this matter if Petitioners' Motion to Withdraw Appearance is granted.
8.
In the event that this Motion to Withdraw Appearance is not granted, Petitioners
respectfully request that the custody hearing currently scheduled for August 11, 1994, be
continued to allow Petitioner additional time to prepare for said hearing and attempt to reconcile
the delinquent balance due Petitioners from the Plaintiff.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
WHEREFORE, Petitioners respectfully request this Honorable Court to enter an Order
permitting Petitioners' withdrawal from representing Plaintiff in this action, or in the alternative,
request that a continuance be granted for the August 11, 1994 hearing.
BY.~~.~
Rebecca R. Hughes, Esquir
60 West Pomfret Street
Carlisle, PA 17013
(717) 249-2353
Supreme Court I.D. No. 67212
Date: August 8, 1994
EXHIBIT "A"
IRWIN, IRWIN & McKNIGHT
IIIltfsrl'OllFllEr S7REEr
CAllUSU, PA fTO"
/Tfl)14H>>J
F~ /Tfl)Z4U354
FEE d,GREEMENT
The firm of IRWIN, IRWIN & McKNIGHT agrees to represent VINCENT P.
MITCHELL regarding marital issues based upon the following fee arrangements:
Fees will depend primarily upon the time, effort and work product expended on your
behalf, consideration of the issues and difficulties involved, and the results achieved on your
behalf. We maintain time records which you may periodically review upon request. You may
also request an itemized bill at any time. It is to be understood that during the course of the
representation, our time will be kept at the prevailing rate for the person performing the service.
The hourly rate for Rebecca R. Hughes, Esquire is SI00.00. All time expended on your beha1f
will be recorded. This may include telephone conversations, correspondence, drafting of
documents, negotiations, legal research, court time, travel, or any other work performed on your
behalf.
During the course of the particular matter for which representation has been accepted, you
will receive bills for fees in accordance with our firm's policy, normally, on a monthly basis. As
noted on our invoices, to avoid finance charges these bills are due within thirty (30) days.
At the conclusion of the particular matter, you will receive a final bill based on the
prevailing hourly rate for the persons performing the services during the periods that the services
are performed in this matter. In addition to the hourly rate, the attorney may set an additional fee
based on the result accomplished, the novelty and difficulty of the matter, the importance of the
issue or litigation involved, the skill required to perform the legal services properly, the amount
involved, and the experience, reputation, and ability of the lawyer or lawyers performing the
services, as well as such other appropriate basis as may be appropriate in establishing the fee in
your particular legal matter. Costs, filing fees and expenses in addition to attorney fees shall be
paid or advanced by the client upon request.
The firm requires and the client agrees to pay a retainer of S 350.00, toward the fees to be
incurred in this matter.
The above appointment and agreement is hereby approved and accepted this.u day of
~ 1993.
IRWIN, IRWIN & McKNIGHT
BY:~!<<'rn N Ik;$r; I
REBECCA R. HUG
VINCENT P. MITCHELL,
PETITIONER
V.
ANNETTE C. MITCHELL,
RESPONDENT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94-0233 CIVIL TERM
ORDER OF COURT
AND NOW, this'lt-day of August, 1994, upon notification by John Wesley
Weigel, III, Esquire that he has been retained by petitioner to represent him in is
matter, the hearing scheduled for Thursday, August 11, 1994, IS CANCELLED. The
hearing is rescheduled for Thursday, August 25, 1994, at 8:45 a.m., in Courtroom
Number II.
John Wesley Weigel, III, Esquire
For Petitioner
Bradley L Griffie, Esquire
For Respondent
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vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94-0233 CIVIL TERM
VINCENT P. MITCHELL,
Plaintiff
ANNETTE C. MITCHELL,
Defendant
CIVIL ACTION - CUSTODY
BllTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of Plaintiff in the
above-captioned matter.
Respectfully submitted,
D~ 17 Ir71
Oat I
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J, hn Wesley weige III,
ttorney 10# 55811
Liberty Loft
4 East Liberty Avenue
Carlisle, PA 17013
(717) 243-4417
cc: Bradley L. Griffie, Esq.
Attorney for Defendant
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VINCENT P. MITCHELL,
PETITIONER
V.
ANNETTE C. MITCHELL,
RESPONDENT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94-0233 CIVIL TERM
CUSTODY
ORDER OF COURT
AND NOW, this 15th day of August, 1994, this petition for special relief will be
heard at 8:45 a.m., on Thursday, August 25, 1994, in Courtroo
John Wesley Weigel, III, Esquire
For Petitioner
Bradley L Griffie, Esquire
For Respondent
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VINCENT P. MITCHELL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94-233 CIVIL TERM
CIVIL ACTION - LAW
vs.
ANNETTE C. MITCHELL,
Defendant
IN CUSTODY
AND NOW, this
ORDER OP COURT
day of August, 1994, upon presentation
and consideration of the within Petition for Special Relief, it
is hereby ordered and decreed that primary physical custody of
the parties' children, cortney Ann Mitchell, born December 21,
1984, and Corinne Kathleen Mitchell, born May 24, 1987, shall be
with the Mother, with Father having periods of temporary physical
custody of the children on the following basis:
(a) On alternating weekends from 3:00 p.m. on Friday
until 8:00 p.m. on Sunday;
(b) Every Thursday evening from 4:00 p.m. until 8:00
p.m.; and
(c) At such other times as the parties may agree.
This Order shall remain in effect until further Order of
Court or agreement of the parties.
BY THE COURT,
Edgar B. Bayley, Judge
!'
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VB.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94-233 CIVIL TERM
CIVIL ACTION - LAW
VINCENT P. MITCHELL,
Plaintiff
ANNETTE C. MITCHELL,
Defendant
IN CUSTODY
PETITION FOR SPECI~L RELIEF PURSUANT
TO PENNSYLVANI~ RULES OF CIVIL PROCEDURE NO. 1915,13
AND NOW, comes Petitioner, Annette C. Mitchell, and
petitions the Court as follows:
1. Your Petitioner is Annette C. Mitchell, an adult
individual currently residing at 510 South West street, Carlisle,
Cumberland County, Pennsylvania.
2. Your Respondent is Vincent P. Mitchell, an adult
individual currently residing at 1913 Fry Loop Avenue, Carlisle,
Cumberland County, Pennsylvania.
3. The parties are the natural parents of the children,
Cortney Ann Mitchell, born December 21, 1984, and Corinne
Kathleen Mitchell, born May 24, 1987.
4. The parties are subject to an Order of Court dated June
22, 1994, which is attached hereto and incorporated herein by
reference providing for a distribution of physical or residential
custody of the children on essentially a shared arrangement.
5. The parties are jointly the owners of property located
at 1910 Fry Loop Avenue, Carlisle, Cumberland County,
Pennsylvania, which property is under an Agreement of Sale to be
sold to a third party purchaser for value with settlement to
occur on or before September 2, 1994.
6. Since the parties' separation on september 17, 1993, the
Respondent herein, Vincent P. Mitchell, has continued to reside
in the former marital residence.
7. Since at least December 1993, the Respondent has failed
and refused to pay the first mortgage and second mortgages on the
property referred to above, causing a foreclosure proceeding to
be initiated against the parties for the failure to pay the
mortgage on the property.
8. Due to Respondent's failure to pay for long distance
telephone service, no long distance telephone service is
available to him at the residence at 1910 Fry Loop Avenue,
Carlisle, Cumberland County, Pennsylvania.
9. Respondent has received notification of a termination of
water and sewer service due to his failure to maintain payment
for water and sewer services to the property at 1910 Fry Loop
Avenue, Carlisle, Cumberland County, Pennsylvania.
10. Throughout the lives of the children, your Petitioner
has been the primary custodian of the children, seeing to their
medical needs, their educational needs, their material needs and
their emotional needs.
11, Even during a brief period of time following the
parties' separation and prior to the entry of the current Order
when the Respondent had primary residential custody of the
children, Petitioner remained as the primary caretaker of the
children through her involvement with the children's schooling,
their educational needs, their medical needs, their emotional
needs, and the like.
12. At the time of presentation of this Petition, the
future residence of the Respondent is unknown.
13. The Petitioner is in the process of moving her
residence to 1:he centerville or Dickinson area of Cumberland
County, in Cook Township, Cumberland County, which will cause the
children to initiate their schooling for the 1994-1995 school
year at Oak Flats Elementary School in the Big Spring Area School
District.
14. A hearing in this matter was scheduled for August 11,
1994 before your Honorable Court.
15. Due to counsel for the Respondent withdrawing as his
counsel and the personal request of the Respondent to have the
matter continued, a hearing has been rescheduled to August 25,
1994.
16. In order for the children to acclimate themselves to
their new school and their new residence, it is in the children's
best interest to have an arrangement whereby they primarily
reside with your Petitioner and have appropriate periods of
alternating weekend and one evening per week temporary physical
contact with the Respondent.
17. In that records must be transferred and accommodations
must be made with the children's new school in order for them to
be prepared to attend school which begins on Monday, August 29,
1994, it is necessary to have a Temporary Order implemented to
allow this to occur.
..w.u
18. The evidence to be presented by the Petitioner in the
above captioned custody action will include numerous witnesses
testifying as to the Respondent's physical violence, both toward
the Petitioner and toward the parties' children.
19. The information to be presented by the Petitioner in
the hearing on this matter will include numerous witnesses
testifying to the Respondent's failure to maintain the most basic
medical needs for the parties' children.
20. Even during the period of time when the children's main
residence was with Respondent at the former marital residence,
Petitioner was responsible for going to the home and preparing
the children for school each day and picking the children up
following school into the early evening hours.
WHEREFORE, Petitioner requests your Honorable Court to enter
a Temporary Order providing for her to have primary physical
custody of the children and for the Respondent to have
appropriate periods of temporary physical custody on alternating
weekends and one evening per week pending further Order of Court
and hearing on this matter.
Respectfully submitted,
GRIFFIE & ASSOCIATES
riff squire
e or Petitioner
2 North Hanover Street
arlisle, PA 17013
(717) 243-5551
(800) 347-5552
...." .--.-, ..,.-."'..",........
VERIFICATION
I verify that the statements made in the foregoing document
are true and correct. I understand that false statements herein
are made subject to the penalties of 18 Pa.C.S. Section 4904,
relating to unsworn falsification to authorities.
DATE:
rr/t/91
I I
f2rvfVm e 7.~
ANNETTE C. MITCHELL
~idL._.-
JUN 22 JSMd,
VINCENT P. MITCHELL,
PlaintiLL
: IN THE COURT OF COMMON PLEAS OF
:CUHBERLAND COUNTY, PENNSYLVANIA
v
.
.
:NO. 233 - CIVIL - 1994
:
ANNETTE C. MITCHELL,
DeLendant
.
.
:CIVIL ACTION - CUS'l'ODY
COURT ORDER
AND NOW, this .;:t.).. day oL 0...-......- ,1994, upon
consideration oL the attached custo~nciliation Report, it is
ordered and directed as Lollows:
1. A Hearing is scheduled in the above case Lor Thursday,
August 11, 1994, at 8:45 A.M. in Courtroom No.2 oL the
Cumberland County Courthouse in Carlisle, Pennsylvania.
At this Hearing, the Father, Vincent P. Mitchell, shall
be deemed to be the moving party and shall proceed
initially with testimony. Counsel Lor the parties are
directed to Lile with the Court and opposing counsel a
memorandum at least ten days prior to the Hearing date,
which memorandum shall set Lorth a sWlllllary oL each
client's position on custody and shall also set Lorth
a list oL each witness that will be called to testiLy
at the Hearing along with a brieL sWlllllary oL the
anticipated testimony oL that witness.
2. Pending Lurther Order oL this Court, the Father, Vincent
P. Mitchell, and the Mother, Annette C. Mitchell, shall
enjoy shared legal custody oL Cortney Ann Mitchell, born
December 21, 1984, and Corinne Kathleen Mitchell, born
May 24, 1987.
3. The parties shall share physical custody under the Lollowing
arrangement:
A. Mother shall enjoy physical custody on three out oL
every Lour weekends Lrom Thursday at 8 A.M. until
Sunday at 8 P.M. These shall be consecutive weekends
and shall start on June 9. Additionally, on the
Thursday and Friday beLore the weekend where Father
shall have physical custody oL the children, Mother
shall have physical custody on that Thursday and
Friday Lrom 7 A.M. until the end oL Father's working
time at which time Father shall pick up the children
on each Thursday and Friday Lrom Mother's custody.
Exhibit "A"
B. Father shall have physical custody of the minor
children at all other times, except as agreed upon
by the parties.
4. In the event Counsel for the part ies feels a Conciliation
Conference prior to the above scheduled Court Hearing will
aide in the resolution of this case, Counsel may contact the
Custody Conciliator for another Conference in an attempt to
resolve the issues in this case prior to the Hearing.
BY THE COURT,
Isl ~ za.M
Judge Edg r B. Bayley
cc: Rebecca Hughes, Eaquire
Bradley Griffie, Esquire
TRUE CO?Y FROM RECORD
In Test,,".'n'; .::n'(:.~' I :...~: IJ':' s:t my hand
and tha seal of sa:d C()~rt at Cariisle, Pa.
This ...~Ql~~day oL.~.., 19.~.~
~:~ih!~"'.'.
..
VINCENT P. MITCHELL,
Plaintirr
IIN THE COURT OF COMMON PLEAS OF
ICUMBERLAND COUNTY, PENNSYLVANIA
I
INO. 233 - CIVIL - 1994
v
.
.
ANNETTE C. MI'rCHELL,
Derendant
I
ICIVIL ACTION - CUSroDY
PRIOR JUDGE I JUDGE EDGAR B. BAYLEY
CONCILIATION CONFERENCB SUMMARY RBPOR2'
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the
rollowing report I
1 . The pertinent inrormation pertaining to the children who are
the subject or this litigation is as rollows:
Cortney Ann Mitchell, born December 21, 1984, and Corrine
Kathleen Mitchell, born May 24, 1987.
2. A Conciliation Conrerence was held on June 2, 1994, with the
rollowing individuals in attendance:
The Father, Vincent P. Mitchell, with his counsel, Rebecca
Hughes, Esquire, and the Mother, Annette C. Mitchell, with
her counsel, Bradley Grirrie, Esquire.
3. The parties were berore the Conciliator in February ror a
prior Conrerence. At that time an Agreement was reached to
undergo a Custody Evaluation. The parties have undergone a
Custody Evaluation with Nancy Small or Franco and Associates.
There is still some additional work that needs to be completed
with respect to that evaluation. The parties are not able to
reach an agreement on custody, and a Hearing is necessary.
4. The parties will continue to negotiate. The Hearing is not
scheduled until August and is scheduled in time to allow ror
the issue or where the children will go to school to be
addressed at that Hearing. The parties are currently unsure
or their permanent home in that the marital home is being sold.
5. The Counsel ror the parties requested the opportunity to meet
with the Conciliator again ir they relt such a meeting would
be benericial prior to the Custody Hearing.
6. The parties, upon the advise or the Conciliator, have reached
.....
an agreement relative to physical custody pending the Hearing
and that agreement is set forth in the proposed Order.
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VINCENT P. MITCHELL, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs. 94-0233 CIVIL TERM
ANNETTE C. MITCHELL, .
.
Defendant : CIVIL ACTION - CUSTODY
AllSIIER '1'0 DEFBIfDAII'r'S PBTITIOII FOR SPECIAL RRr.TBP
AND NOW comes the Respondent, Vincent P. Mitchell, to answer
the Defendant's Petition as follows:
1. Admi tted.
2. Admitted in part and denied in part. Respondent resides
at 1910 Fry LOOp Avenue, not 1913 Fry Loop Avenue.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7. Admitted in part and denied in part. It is admitted that
Respondent has failed to pay the first mortgage since December
1993. However, it is further alleged that Petitioner has also
failed to pay the first mortgage. It is denied that Respondent has
failed to pay the second mortgage. On the contrary, Respondent has
continued to make payments on the second mortgage so that it is
only one month behind the payment schedule.
B. Admitted in part and denied in part. It is admitted that
long-distance service is not available at this time to Respondent.
It is also alleged, however, that Respondent has substantially
reduced telephone toill arrearages since Petitioner left the marital
residence. It is denied that the absence of long-distance service
adversely affects the children.
.:....u.~;~"
9. Admitted in part and denied in part. It is admitted that
Respondent at one point received a notice of termination of water
and sewer service. It is denied, however, that Respondent has
completely failed to make payments. He in fact forestalled
termination of service by making a payment. It is further alleged
that b2th Respondent and Petitioner, while still living together,
had difficulty making timely payments on these services.
10. Denied. It is denied that petitioner has been the
primary custodian of the children all their lives. On the
contrary, Respondent has fully shared with petitioner the
responsibilities of meeting the medical, educational, material and
emotional needs before the parties separated in september 1993.
Since the date of separation, it is Respondent who has been the
primary custodian of the children.
11. Denied. It is Respondent who has been the primary
caretaker of the children since December 1993.
12. Admitted. However, Respondent plans to establish his new
residence in carlisle before August 25, 1994.
13. Denied. After reasonable investigation the Respondent is
without knowledge or information sufficient to form a belief as to
the truth of these allegations. In addition, Petitioner's petition
wrongly presumes to know in advance that this Court will award
primary custody to Petitioner in the main custody action.
14. Admitted.
15. Admitted.
16. Denied. It is denied that awarding petitioner prmary
physical custody will be in the best interest of the children,
~k~.
whether such an award is made pursuant to this Petition for special
Relief or to the main custody action. On the contrary, it is in
the best interest of the children to make Respondent primary
custodian. It is further denied that the children will have a need
to acclimate themselves to a new school if custody is awarded to
Respondent. Petitioner's petition wrongly presumes to know in
advance that this Court will award primary custody to Petitioner in
the main custody action.
17. Denied. Records will not need to be transferred to a new
school should Respondent receive primary custody. Again,
Petitioner's petition wrongly presumes to know in advance that this
Court will award primary custody to Petitioner in the main custody
action.
18. Denied. After reasonable investigation the Respondent is
without knowledge or information sufficient to form a belief as to
the truth of Petitioner's planned presentation of witnesses.
Respondent for his part will present evidence refuting Petitioner's
reckless allegations of physical violence toward the children and
demonstrating that Respondent's alleged physical violence toward
Petitioner was limited to one brief incident approximately one
month before the parties' separation, and that this brief incident
in no way affected the children.
19. Denied. It is Peti tioner who is responsible for
maintaining medical insurance coverage pursuant to a support order
of this court, dated August 8, 1994. In addition, Respondent has
maintained medical insurance coverage of the children through Blue
Cross and Blue Shield. Furthermore, Respondent has made sure that
'~~:"::.'.
the children have proper medical care and has taken time off from
work to be with the children when they have been sick.
20. Admitted in part and denied in part. It is admitted that
Petitioner went to the marital home from September to December 1993
to prepare the children for school and that Petitioner sometimes
picked up the children from school. It is denied, however, that
this state of affairs continued past December 1993.
On the
contrary, Respondent has performed these functions on a routine
basis since December 1993.
WHEREFORE, Respondent requests this Court to dismiss this
Petition for Special Relief and preserve the status quo in its
order of June 22, 1994 pending final resolution of this custody
action.
Respectfully submitted,
1L.,rI- r'J I r ( f
Date .
Il~ LJ~
ohn Wesley We' el II , Esquire
Attorney for Respondent
Liberty Loft
4 East Liberty Avenue
Carlisle, PA 17013
(717) 243-4417
..~-~.",",-
VElUPJ:CATJ:OII OP PLEADDIG
I verify that the statements made in the attached document are
true and correct.
I understand that false statements herein are
made subject to the
relating to unsworn
penalties of 18 Pa. c.s.,;- section 49,~,?'
falsification to authorities. _-----/
f~/7~ft/
Date
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VINCENT P. MITCHELL, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs. . 94-0233 CIVIL TERM
.
.
.
ANNETTE C. MITCHELL, .
.
Defendant : CIVIL ACTION - CUSTODY
PLlUIITIPF'S PRB-'ftUAL IIIlIIDRAIIDOII
Plaintiff vincent P. Mitchell files this memorandum, as
required by the Court's Order of June 22, 1994, in preparation for
the custody hearing scheduled Thursday, August 25, 1994, at 8:45
A.M.
I. PLADI'l'IPF'S POSI'l'IOIf
Plaintiff will show that he has shared with Defendant care of
their two children throughout the children's lives. This shared
care has extended to changing diapers, preparing meals for the
children, administering appropriate discipline to the children,
caring for the children when they have been ill, and sharing
leisure time with the children. Plaintiff's extensive and positive
involvement has continued since the date the parties separated and
indeed deepened during the time Plaintiff has had primary custody
of the children. Plaintiff will present his own testimony and that
of other witnesses to refute Defendant's extreme and reckless
allegations that, "Plaintiff has shown a tremendous inability to
parent and has often exhibited an uncontrollable, violent temper,"
and that Plaintiff has committed physical abuse of the children.
II. W.L'rIISSSES
The Plaintiff plans to call the following witnesses:
A. Vincent P. Mitchell - The Plaintiff will testify on his
own behalf and describe his extensive past and current care for the
children. He will also rebut the implications raised by
Defendant's Petition for Special Relief that he has been solely
responsible for the financial difficulties of the parties.
Plaintiff's testimony will also address the allegations of physical
violence being made by Defendant.
B. Pam Snavely, 164 Texaco Road, Mechanicsburg, PA - Ms.
Snavely is the sister of Plaintiff's foster-brother. She will
testify under subpoena to Plaintiff's very positive relationship
with the children. Since she has cared for the children during the
summer days in which Plaintiff has had custody but worked, Ms.
snavely will testify to the general well-being of the children.
C. Bonnie Hoffman, 126 Wagner Street, Carlisle, PA - Ms.
Hoffman has cared for the children before and after school hours
during the school year. Ms. Hoffman will testify under subpoena to
the positive relationship Plaintiff has with his children and to
the well-being and attitude of the children.
D. Doris Dunkle, 516 S. West Street, Carlisle, PA - Ms.
Dunkle is the Plaintiff's girl-friend. She will testify to the
positive relationship Plaintiff has with the children as well as
the positive relationship she has with the children.
E. Ginger Barnhart, 260 Old Stonehouse Road, Mechanicsburg,
PA - Ms. Barnhart was Corinne Mitchell's teacher during the last
school year. It is believed that she will testify under subpoena
to Corinne's satisfactory academic performance and general well-
being during the school year.
F. Phyllis Jones, 11 Garden Drive, carlisle, PA - Ms. Jones
was courtney Mitchell's teacher during the last school year. She
will testify under subpoena to Courtney's satisfactory academic
performance and general well-being during the school year.
G. Robert snyder, 1909 Fry LOOp Avenue, carlisle, PA - Mr.
Snyder has been a neighbor and an acquaintance of the Mitchell
family since the Mitchells moved onto Fry Loop Avenue. Mr. snyder
will testify to the positive relationship plaintiff has had with
the children.
The Plaintiff respectfully reserves the right to call
additional witnesses, particularly for rebuttal of the testimony of
Defendant and her witnesses. Such witnesses may include Kathy
Snavely, 300 E. Coover Street, Mechanicsburg, PA, who is the
foster-mother of Plaintiff, and Tammy Lloyd (under subpoena), 383
Mount Rock Road, Newville, PA, wife of Defendant's witness Robert
Lloyd.
III. DllIIlIT1!ST FOR III ~ :QI'l'ERVIJlIf OP I"'RTT.nD_
plaintiff respectfully requests this Court to interview the
children in chambers, with counsel and a stenographer present, to
determine whether either child has a preference for any particular
custody arrangement and whether either child has any additional
information for the benefit of the Court.
IV. RlfRTRJ:TS
Plaintiff intends to introduce into evidence the student
progress reports on the children prepared by their teachers.
Plaintiff may also wish to introduce other school and medical
records of the children into evidence.
Respectfully sUbmitted,
_~II'/I/11 l_JC f.t- I U flU; lIJr-
J hn Wesley Weig 1 III, Esquire
Attorney 101 55811
Liberty Loft
4 East Liberty Avenue
Carlisle, PA 17013
(717) 243-4417
.~~'
VINCENT P. MITCHELL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 233 CIVIL 1994
vs.
ANNETTE C. MITCHELL,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
DEPBNDANT'S PRE-TRIAL MEMORANDUM
Defendant, Annette C. Mitchell, files her Pre-Trial
Memorandum pursuant to the Court's Order of June 22, 1994
relative to the custody hearing presently scheduled for Thursday,
August 11, 1994:
I. DEPBNDANT'S POSITION
Defendant maintains that she has been the primary custodian
throughout the children's lives.
For a brief period of time
after the parties' separation, which was caused by the
Plaintiff's abuse of the Defendant, the children continue to
reside at the former marital residence with the father. However,
the mother was responsible for preparing the children for school
each morning by going to the home after the father left for work
each morning. She was responsible for caring for the children
after school until sometime in the early to late evening hours of
each day. In addition, the parties shared time on the weekends.
Under these agreed-upon circumstances, essentially a shared
custody arrangement existed. This shared custody arrangement has
been continued and is expanded upon in the Court's Order of June
22, 1994, which Order was likewise reached by agreement.
;,> .,.,,,....
~......-
....~_:.c~.~ '
Defendant has been and continues to be the primary caretaker
for the children. It is in the best interest of the children to
continue to reside primarily with their mother so she may
continue, as she has since the children's birth, to provide
primary care, custody and control for the children.
Further, the Plaintiff has shown a tremendous inability to
parent and has often exhibited an uncontrollable, violent temper.
This violent temper has been exercised against the Defendant in
front of the children and has been exercised against the children
themselves.
II . WITNESSBS
The Defendant plans to call the following witnesses:
a. Annette C. Mitchell; The Defendant will testify on
her behalf and express her position relative to the information
set forth above, including testimony concerning her primary
custodial care of the children and the lack of involvement of the
Plaintiff in the children's lives.
b. Jeanette Pennington, 6 Pocono Drive, Mechanicsburg;
Ms. Pennington is Ms. Mitchell's sister. She will testify to the
very positive relationship that Ms. Mitchell has had with her
daughters and the strong influence she has had in caring for the
primary needs of the children throughout their lives. She will
also testify relative to the negative involvement of the
Plaintiff in the children's lives, including physical abuse
toward Ms. Mitchell in front of the children and physical abuse
toward the children themselves.
c. Charles and Vivian summy, 4055 Seneca Avenue, Camp
Hill, PAl
These are the parents of Annette Mitchell.
They,
likewise, will testify to the very positive relationship that Ms.
Mitchell has had with her daughters and the strong influence she
has had in caring for the primary needs of the children
throughout their lives. They will also testify relative to the
negative involvement of the Plaintiff in the children's lives,
including physical abuse toward Ms. Mitchell in front of the
children and physical abuse toward the children themselves.
d. Michelle Frisch, Princeton Avenue, Camp Hill, PAl
This is a close friend of Ms. Mitchell. She also will testify to
the very positive relationship that Ms. Mitchell has had with her
daughters and the strong influence she has had in caring for the
primary needs of the children throughout their lives. She will
testify relative to the negative involvement of the Plaintiff in
the children's lives, including physical abuse toward Ms.
Mitchell in front of the children and physical abuse toward the
children themselves.
e. Sandy McHeehan, Carlisle Area Counseling Service,
169 West High Street, Carlisle, PAl Ms. McHeehan was secured as
a counseling therapist for the children by Ms. Mitchell. She
will testify relative to the problems that the children were
enduring during the separation and the compounding nature of the
pressure upon the children created by the father's actions toward
them in involving them in the parties' adult difficulties.
'I~:'''., rvr'c""":
>".. ~~- -.;: --
f. Nancy Small, Franco Psychological Associates, 26
state Avenue, Carlisle, PA:
Ms. Small is the independent
counselor or therapist secured by the parties to present to the
Court a statement of her recommendation concerning the best
interest of the children in this action. As the therapist has
not prepared her final opinion at the time of preparation of this
document, her actual position is unknown,
g.
Robert Lloyd, P.O. Box 151, Newville, PA:
Hr.
Lloyd, who is Ms. Mitchell's boy-friend, is actively involved in
the children's lives and will remain involved in the children's
lives into the future.
He will testify to the very positive
relationship he has with the parties' children and also the
positive relationship he has with Ms. Mitchell. He will verify
the positive, good relationship between Ms. Mitchell and the
children.
The Defendant respectfully reserves the right to call
additional witnesses, and particularly rebuttal witnesses,
depending upon the position taken by the Plaintiff in his listing
of witnesses.
Respectfully submitted,
GRIFFIE & ASSOCIATES
. Gri squire
y or Defendant
orth Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
MA!~ 1 J 199t:\ jv
VINCENT P. MITCHELL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
v
.
.
:NO. 233 - CIVIL - 1994
.
.
ANNETTE C. MITCHELL,
Defendant
.
.
:CIVIL ACTION - CUSTODY
/' COURT ORDER" 1. ()
AND NOW, this \ '5 day of VV\.lAJL..... , 1994, upon
consideration of the attached Custody Conciliation Report, it is
ordered and directed as follows:
1. The Father, Vincent P. Mitchell, and the Mother, Annette C.
Mitchell, shall have shared legal custody of Cortney Ann
Mitchell, born December 21, 1984, and Corinne Kathleen
Mitchell, born May 24, 1987.
2. The Father shall have primary physical custody of the minor
children.
3. The Mother shall have temporary physical custody as follows:
A. On alternating weekends from Friday at 3 P.M. until
Sunday at 8 P.M.
B. Every Thursday from 3 P.M. until 8 P.M.
C. At such other times as agreed upon by the parties.
4. The parties shall submit themselves to a professional for a
custody evaluation. The professional shall be selected by
legal counsel for the parties. This professional shall act
as an independent evaluator for the purposes of evaluating
all the parties and the children and submitting a
recommendation to the parties with respect to a permanent
custody order. The parties shall split equally any costs
of this evaluation that are not paid for by insurance.
5. The parties shall meet for a second Custody Conciliation
Conference on the 2nd day of June, 1994, at 8:30 a.m.
in the fourth floor conference room at the Cumberland
County Courthouse.
6. This Order is entered pursuant to an agreement reached by
the parties at a Custody Conciliation Conference. In the
event circumstances change prior to the mentioned second
~. ':.f. . ,.,.!"'~" -,.-
~~'._1
Custody Conciliation Conference, either
the Court to accelerate the schedu .
Conference. -
may petition
onciliation
cc:
Rebecca Hughes, Esquire ~_ ,llJ...1.f:.(cf ,0',-
Bradley Griffie, Esquire
3/' ~/c;'1
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;- .'.~';
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11
'" .
.
VINCENT P. MITCHELL,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v
.
.
:NO. 233 - CIVIL - 1994
ANNETTE C. MITCHELL,
Defendant
.
.
.
.
:CIVIL ACTION - CUS'l'ODY
PRIOR JUDGE: JUDGE EDGAR B. BAYLEY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the
following report:
1. The pertinent information pertaining to the children who are
the subject of this litigation is as follows:
Cortney Ann Mitchell, born December 21, 1984, and Corrine
Kathleen Mitchell, born May 24, 1987.
2. A Conciliation Conference was held on February 25, 1994,
with the following individuals in attendance:
The Father, Vincent P. Mitchell, with his counsel, Rebecca
Hughes, Esquire, and the Mother, Annette C. Mitchell, with
her counsel Bradley Griffie, Esquire.
3. The parties agreed to the entry of an Order in the form as
attached.
3/g-(fY
'DATE
t16I-fJ
, .
VINCENT P. MITCHELL,
PETITIONER
V.
ANNETTE C. MITCHELL,
RESPONDENT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94-0233 CIVIL TERM
CUSTODY
AND NOW, this
ORDER OF COURT
~q "day of August, 1994, following a hearing on the merits,
IT IS ORDERED THAT custody of Courtney Ann Mitchell, born December 21,1984,
and Corrine Kathleen Mitchell, born May 24, 1987, between their mother, Annette C.
Mitchell, and their father, Vincent P. Mitchell, shall be as follows:
1. During the school year:
(a) The children shall be with their mother each Sunday evening from
8:00 p.m. through Friday morning before school begins.
(b) The children shall be with their father from after school Friday until
Sunday at 8:00 p.m. every four out of seven weekends, with their mother on three out
of those seven weekends as follows:
Weekend one: with father;
Weekend two: with mother;
Weekend three: with father;
Weekend four: with mother;
Weekend five: with father;
Weekend six: with father;
Weekend seven: with mother;
(c) The children shall be with their father for each entire Easter school
......
.
break and each December 27 through January 1. The children shall be with their
mother for each entire Thanksgiving break. The regular weekend schedule set forth
in paragraph 1 (b) shall be Interrupted on such occasions.
2. During each summer the father shall have the children from noon on the
second Saturday after school ends until one full week before the next school year
begins, except that the mother shall have the children for, (1) two uninterrupted
weeks during that period, and (2) every other weekend during this period from
Saturday noon until Sunday evening except for the two unintern.:pted weeks when the
father shall have the children. Each year the father and mother shall set the dates of
their respective two uninterrupted week periods before the summer schedule
commences.
3. The parents shall make their own arrangements to share holidays.
4. The children shall be enrolled in the school district where the mother lives.
They may not be enrolled in a school district to which the mother anticipates she will
move unless and until the move is made.
5.
John Wesley Weigel, III, Esquire
For Petitioner
Bradley L. Griffie, Esquire
For Respondent
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Vincent P. Mitchell, . IN THE COURT OF COMMON PLEAS OF
.
Petitioner . CUMBERLAND COUNTY, PENNSYLVANIA
.
:
vs. :
. CIVIL ACTION - LAW
.
Annette C. Mi tchell, . 94-0233 Civil Term
.
Respondent . CUSTODY
.
ORDER OF COURT
AND NOW, this ~ day of October, upon consideration of the
Petition to Withraw Appearance filed by Petitioner's counsel, it
is hereby ordered that a Rule be issued upon the Petitioner and
Respondent to show cause why the Petition should not be granted.
Rule returnable in -,.
days from service.
Service of this Rule by first-class mail.
(
J.
/
cc: Vincent P. Mitchell
Petitioner
Bradley L. Griffie, Esq.
Attorney for Respondent
John Wesley Weigel III, Esq.
Attorney fo: Petitioner
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Vincent P. Mi tchell, : IN THE COURT OF COMMON PLEAS OF
Pet! tioner . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. .
.
: CIVIL ACTION - LAW
Annette C. Mi tchell , . 94-0233 Civil Term
.
Respondent . CUSTODY
.
PETITION TO WITHDRAW APPEARANCE
NOW COMES Counsel for Petitioner, John Wesley Weigel III, to
petition the Court for a withdrawal of appearance, alleging as
follows:
1. Petitioner Vincent P. Mitchell retained his present counsel
on August 12, 1994, advancing the sum of $300.00 for attorney fees.
2. Counsel appeared on behalf of Petitioner at a hearing held
on August 25, 1994.
3. Petitioner has failed to pay anything toward the attorney
fees charged by his present counsel, apart from the $300.00 originally
advanced.
4. There is no pending litigation in the above matter.
Therefore, Petitioner will not suffer any prejudice due to withdrawal
of his counsel.
WHEREFORE, Counsel for Petitioner Vincent P. Mitchell, John
Wesley Weigel III, requests this Court to permit him to withdraw
his appearance from the above matter.
Respectfully submitted,
l:i-il ) (), 1'1 'I (,
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eigel III, Esquire
street
Carlisle, PA 17013
(717) 243-1985
-....,,:
.
VERIFICATION OF PLEADING
I verify that the statements made in the attached pleading are
true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. Section 4904, relating
to unsworn falsification to authorities.
,,:J.~-I_ J u. 1'1 r (.
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ohn Wesley Weigel
ilL
Esquire
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AFFIDAVIT OF SERVICE
I hereby certify that I am this date serving a copy of the
attached Petition to Withdraw Appearance on the following parties:
Vincent P. Mitchell
9 s. Baltimore st., #9
Dillsburg, PA 17019
Bradley L. Griffie, Esq.
200 N. Hanover st.
Carlisle, PA 17013
Service by first-class mail.
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~ohn Wesley eige II, Esq.
50 East High Street
Carlisle, PA 17013
(717) 243-1985
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AFFIDAVIT OF SERVICE
I hereby certify that I am this date serving a copy of the
attached Petition to Withdraw Appearance on the following parties:
Vincent Mitchell
406 S. Pitt St.
Carlisle, PA 17013
Service by first-class mail.
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ohn Wesley eigel 4II, Esq.
50 East High Street
Carlisle, PA 17013
(717) 243-1985
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Vincent P. Mitchell, . IN THE COURT OF COMMON PLEAS OF
.
Peti tioner . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. :
. CIVIL ACTION - LAW
.
Annette C. Mitchell , . 94-0233 Civil Term
.
Respondent . CUSTODY
.
ORDER OF COURT
AND NOW, this --1.l..- day of ~~ , 199 1-, upon
,
consideration of the Petition to Make Rule Absolute filed by
Petitioner's counsel, John Wesley Weigel III, it is hereby ordered
that the petition of Petitioner's counsel to withdraw his appearance
is granted.
By The
J.
cc: Vincent P. Mitchell
Petitioner
/
Bradley L. Griffie, Esq.
Attorney for Respondent
John Wesley Weigel III, Esq.
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Vincent P. Mitchell , . IN THE COURT OF COMMON PLEAS OF
.
Petitioner . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. .
.
. CIVIL ACTION - LAW
.
Annette C. Mitchell , . 94-0233 Civil Term
.
Respondent . CUSTODY
.
PETITION TO MAKE RULE ABSOLUTE
NOW COMES Counsel for Petitioner, John Wesley Weigel III, to
petition the Court, alleging as follows:
1. On October 1, 1996, Counsel for Petitioner filed a Petition
to Withraw Appearance. A copy of the Petition is marked Exhibit
"A", attached hereto, and incorporated herein by reference.
2. On October 2, 1996, the Court, by the Honorable Edgar B.
Bayley, issued a rule upon both parties to show cause within seven
days why counsel's petition to withdraw ,his appearance should not
be granted. A copy of the court's order is marked Exhibit "B",
attached hereto, and incorporated herein by reference.
3. Since filing his original petition, Petitioner's counsel
has learned that Petitioner currently resides at 516 S. West Street,
Carlisle, Cumberland County, Pennsylvania, and served the court's
order of October 2 upon Petitioner at that address by first class
mail on October 21, 1996.
4. No party has answered counsel's Petition to Withdraw.
WHEREFORE, Counsel for Petitioner Vincent P. Mitchell, John
Wesley Weigel III, requests this Court to make its rule absolute
and to permit him to withdraw his appearance from the above matter.
Respectfully submitted,
/~t,,~ U t?~ u q~tI1L-
n Wesley W gel I I, Esquire
Irvine Row
Carlisle, PA 17013
(717) 243-1985
'lrr
VERIFICATION OF PLEADING
I verify that the statements made in the attached pleading are
true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. Section 4904, relating
to unsworn falsification to authorities.
1'k"'7 ;.., 1777
D}l't:e
Vincent P. Mitchell, :
Petitioner .
.
.
.
vs. .
.
.
.
Annette C. Mitchell, .
.
Respondent :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
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CIVIL ACTION - LAW _ _ .
94-0233 Civil Term c::
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PETITION TO WITHDRAW APPEARANCE
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NOW COMES Counsel for Petitioner, John Wesley
petition the Court for a withdrawal of appearance,
follows:
1. Petitioner Vincent P. Mitchell retained his present pounsel
on August 12, 1994, advancing the sum of $300.00 for attorney fees.
2. Counsel appeared on behalf of Petitioner at a hearing held
on August 25, 1994.
3. Petitioner has failed to pay anything toward the attorney
fees charged by his present counsel, apart from the $300.00 originally
advanced.
4. There is no pending litigation in the above matter.
Therefore, Petitioner will not suffer any prejudice due to withdrawal
of his counsel.
WHEREFORE, Counsel for Petitioner Vincent P. Mitchell, John
Wesley Weigel III, requests this Court to permit him to withdraw
his appearance from the above matter.
Respectfully submitted,
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~hn Wesley eigel~II, Esquire
50 East High Street
Carlisle, PA 17013
(717) 243-1985
.
.
EXHIBIT A
~.,. . -. ..
................
VERIFICATION OF PLEADING
I verify that the statements made in the attached pleading are
true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. Section 4904, relating
to unsworn falsification to authorities.
.a..A-,) l!J. 17~C
om .
ilL
Esquire
AFFIDAVIT OF SERVICE
----'.
-----
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I hereby certify that I am this d~te-seiVIng a copy of the
"--_. ----
._---_.~
attached Petition to Withdraw Appearance on the following parties:
Vincent P. Mitchell
9 S. Baltimore St., #9
Dillsburg, PA 17019
Bradley L. Griffie, Esq.
200 N. Hanover St.
Carlisle, PA 17013
Service by first-class mail.
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ohn Wesley e1ge II, Esq.
50 East High Street
Carlisle, PA 17013
(717) 243-1985
.OCT 0 : i996~~
Vincent P. Mitchell,
Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
.
.
vs.
.
.
.
.
CIVIL ACTION - LAW
94-0233 Civil Term
CUSTODY
Annette C. Mitchell,
Respondent
:
.
.
ORDER OF COURT
AND NOW, this ~~day of october, upon consideration of the
Petition to Withraw Appearance filed by Petitioner's counsel, it
is hereby ordered that a Rule be issued upon the Petitioner and
Respondent to show cause why the Petition should not be grant~d.
Rule returnable in 7
days from service.
Service of this Rule by first-class mail.
BY THE COURT,
Istl'-Ar-L 713. ~
J.
cc: Vincent P. Mitchell
Petitioner
Bradley L. Griffie, Esq.
Attorney for Respondent
John Wesley Weigel III, Esq.
Attorney for Petitioner
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TRUE COpy FROM RECORD
'n r.,:t'mony whereof, I hEre unto set my hand
a,d the seal of said Court at Carlisle, Pa.
This. ;l.~~. day of.&d..:::., 19..$
.................~..".~~'h~!-i#~ .
.
.
EXHIBIT B
;t''I'LN.,V) 7. / r r 1-
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n Wesley Weigel II, Esq.
Irvine Row
Carlisle, PA 17013
(717) 243-1985
AFFIDAVIT OF SERVICE
I hereby certify that I am this date serving a copy of the
attached Petition to Make Rule Absolute on:
Bradley L. Griffie, Esq.
200 N. Hanover st.
Carlisle, PA 17013
Vincent P. Mitchell
516 S. West St.
Carlisle, PA 17013
Service by first-class mail.
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