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Home My WebLink About95-01273 ",;".-~"".~-. . ,,; -'\'. :&i~~;~~~-< .,,' :L!~ i::: . ~?~.:": i/~: r.~..". ...... . ~,../, " ,rt) r ("0 - .,-, " ~ f ' _~,i:\ , ;} ~i --;- .. . , ,,':.,,, . " n ~ 1 i ~ 1{. 8. . >-.. J) ~r. ... 0 rJ iE ..~ J' f..) @) ~u It::,:t l() In ...... (1:t:"'.' C .. N ~,:;w., .. ... ll.r 0-" , tri ~ \<J N (J t _r __, 0 lei ~ , "'.i). ::r ('t I,Ll ,I" :r l'\ 10..,'1.r Cl ~:.! i.,lI' :: 11T Ii "'_ .l'!.IIl.J 'lJ ,":t( 11. VI ,j Q: '" "<: ... ~t.1 U :c- ;1 .j.J ~ ~ ~ .... a ~ j ;::- ~ . ~ 8 ~~ j~ So iii ~ Po.!< F z 0 ~~ Po . :t > Bi 1j .. ~ . ~ I ~ ~i ~~ ~' 1;;:0: lii . , ~ ;::- ~ H So ! i u ~ .. , . , . . . CONS1:ANCll p, BRUNT -"ITORNEY -"I' lAW DENNIS E. SCHELL, JR., . IN TIlE COURT OF COMMON PLEAS OF . . CUMBERLAND COUNTY, PENNSYLVANIA . Plaintiff . . v. . CIVIL ACTION - LAW . : AMANDA L. SCHELL, . No. r15. /;)1 J . C~u"-o -f.Qll.IY\ . . Defendant . IN CUSTODY . ORDER OF COURT AND NOW, this Jbtk day of jV1~\r ( h , 1995 upon " consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before S o.m(.-\.c I L f}"J('.~ F&t, , the conciliator, at ,g(,- f\I . ( JH sl. t~y,.,,. on the ~ day of _fV):-l'! ' 1995, at '3 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. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE By: Custody Conciliator YOU SHOULD TARE 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. Office of The Court Administrator Cumberland county Courthouse 4th Floor 1 Courthouse Square carlisle, PA 17013~3387 (717) 240-6200 HAR ZO 4 06 PII '95 or ' ' !,: J,' 'JFrICf.' .fj' ',' '. CUM'";' '" ";'i HCH~I'A~t ',/,1'",0 ~r"~', y rf".1.4 ~ YI':,\';I~. .3-.;)0 {IS- 4..1 dyt/ /J?a~ -;:;; ~ ~J 3 '~09'..r ~ /~~ ~ ~' 3::>>7.5- ("~~'--'.. s:d-4 ~, . ., DENNIS E. SCHELL, JR., IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA . Plaintiff . . v. . CIVIL ACTION - LAW . . . AMANDA L. SCHELL, . No. qt~ );173 . ,) - . . Defendant . IN CUSTODY . COMPLAINT FOR CUSTODY AND NOW, comes the plaintiff, DENNIS E. SCHELL, JR., by and through his attorney, CONSTANCE P. BRUNT, ESQUIRE, and respectfully represents as follows: 1. The Plaintiff is DENNIS E. SCHELL, JR., residing at 4623 Hampden Avenue, Camp Hill, Cumberland County, pennsylvania. 2. The Defendant is AMANDA L. SCHELL, residing at 277 California Avenue, Apartment 10, wahiawa, Hawaii 96786. 3. The Plaintiff is seeking primary legal and physical custody of the following children: ~ Residence Asm Anthony James 4623 Hampden Avenue 5 years Michael Schell Camp Hill, PA 17011 Derick Scott 4623 Hampden Avenue 4 years Matthew Schell Camp Hill, PA 17011 Mason Storme 4623 Hampden Avenue 3 years Alexander Schell Camp Hill, PA 17011 ~;_ -I'-.u...-~.."...",-".-.,...",,, The children were born of the marriage between plaintiff and Defendant. The children are presently in the custody of Plaintiff, DENNIS E. SCHELL, JR., who currently resides at 4623 Hampden Avenue, Camp Hill, Cumberland County, Pennsylvania. For the past five (5) years, the children have resided with the following persons and at the fOllowing addresses: (a) 2/93 through present 4623 Hampden Avenue Camp Hill, PA 17011 With Defendant, maternal grandmother and maternal uncle (b) 4/92 to 2/93 Scofield Barracks, HI With Plaintiff and Defendant (c) 10/89 to 4/92 The Presidio of San Francisco, CA With Plaintiff and Defendant (d) 10/88 to 10/89 Camp Humphries, SeOUl, Korea With Plaintiff and Defendant The mother of the children is Defendant, AMANDA L. SCHELL, residing at 277 California Avenue, Apartment 10, Wahiawa, Hawaii. She is believed to be residing with a paramour and their child. The father of the children is Plaintiff, DENNIS E. SCHELL, JR., residing at 4623 Hampden Avenue, Camp Hill, Cumberland County, Pennsylvania. He presently resides with his mother, Sally Schell, his brother, John Schell, and the three subject minor children. 2 , , , , -. '. .', ; . 4. The relationship of Plaintiff, DENNIS E. SCHELL, JR., to the children is that of father. 5. The relationship of Defendant, AMANDA L. SCHELL, to the children is that of mother. ( 1 6. The Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the children in this or any other court. Plaintiff has no information of a custody proceeding concerning the custody of the said children pending in a court of this Commonwealth or in any other jurisdiction. Plaintiff does 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 children. 7. The best interests and permanent welfare of the children will be served by granting the relief requested because the children have been residing with the Plaintiff in their current home for the last two years, since the Defendant left Plaintiff and the children. They have enjoyed a stable and wholesome environment, and the Plaintiff is better able to continue providing such an environment than is the Defendant, who has suffered from various alcohol addictions and emotional problems, which have resulted in a suicide attempt and psychiatric hospitalization. 3 8. Each parent whose parental rights of the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff requests this Honorable Court to enter an Order granting him primary legal and physical custody of the sUbject minor children. Respectfully submitted, DATED: .//td/f',f- ~~& CONSTANCE P. BRUNT, ESQUIRE 3901 North Front Street Harrisburg, PA 17110 (717) 232-7200 Attorney for Plaintiff 4 VERIFICATION I verify that the statements made in the foregoing Complaint for custody 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. ~:~r ( lr> ~ ~~~::. ,'L... .~ ,.11':....., N .. ll' '.." ," C:l 1;;'-.' n: n.. ~';i.\ -"::; ~i ~ ~ ~! 'II tl ~ ::i ..... I !l:: t: ~ . ~ 1Xl~ !;~ ;:: ~ . ;IT . "'~ z ~ ~ 1!l ~!< ~~ 0 ~~ . ~ ~~ ~.. iE ~ ~ :> . ~ ~ '21 ~ on ~E ~~ ~ ~I I !;;'<~ ... ::i Z ~ . . 1:. rLI ...:I 0 '~ i u ~ 1:1 . - CONSTANCEP', BnUNT ^"'OR~IF.Y ^T lAW ..... . ,..vI , .. , . , '.~_"T~_""__ _., , . .'., . . . ' .. .' - ." DENNIS E. SCHELL, JR., . IN THE COURT OF COMMON PLEAS OF . . CUMBERLAND COUNTY, PENNSYLVANIA . Plaintiff . . v. . CIVIL ACTION - LAW . : No. 95-1273 CIVIL TERM AMANDA L. SCHELL, . . Defendant . IN CUSTODY . CERTIFICATE OF SERVICE I, CONSTANCE P. BRUNT, ESQUIRE, do hereby certify that: 1. On March 10, 1995, a complaint for custody was filed on behalf of Plaintiff and against Defendant in the above matter. 2. On April 17, 1995, I forwarded, by certified mail, return receipt requested, restricted delivery, a certified copy of the Complaint for custody together with the Order entered on March 16, 1995, scheduling a custody conciliation conference, to Defendant, AMANDA L. SCHELL, addressed to 2415 Lamanche, New Orleans, Louisiana 70117, as evidenced by the sender's receipt attached hereto. 3. The aforesaid certified copy of the Complaint for Custody sent to the Defendant, AMANDA L. SCHELL, was delivered on April 21, 1995, as evidenced by the return receipt card signed by the Defendant and attached hereto. 4. To the best of my information and belief, the signature ~ . - on part 5 0' t,a return receipt card ia, in ,ect, t,e aignature of the Defendant, AMANDA ~. ScRE~L. DATE: fl'L~(9r /J. ~ji. CONSTANCE p. BRUNT, ESQUIRE ,.... P ::iss IlDS 'lllll ~ ReceIpt for Certified Moll ---= No InsuraneB CO\lC'II00 PrDvlded ::'::U'J'f.~' Do not use for Inll!InnllollJ1 Mall 1500 no.o"o, I tit{::. - I J ' AcJ...u..L ~~ ';;-;:-:;;-~(Hl,::- LA 701/7 "',' --- h_ $ 1.0 I J. 10 / ,~t,I~.,t 1 ..,. . ,~" .,1'\0,',..", I.,,' 1I"'I"'I"l I~'h.... I,... ~ ,S" /, (0 a; 11.'111'" Il.,..,p' ~I"'''~'~I en III Wh'"'' ~ ",Ill ''',1"",,,,, ~ II ".'1'"..1',..".... !,t"'''''''1 '''\';1''''11 3 U.11....lIl~IMJ..\'r'\!./l('lI."" ., IIII^II"I\""J" d ~"n, o lI) M E a .. $5"/1 fa ro",..,,'" 'M"4/17/'lf1 i I I i Ie " \. .. .. "'r .. _0_" '. , . . .....<< i, I i i , , " I , , I oJ "r1!t~ -- ;;'c .:::> ,... = :;:)- ..(r". t-:r. 1",.,:'1;' U;.c"-' u: r:;," II. :r 01 , " r::--,-"-" R' ',-,-,UOG ._,~ ',-- "', 'I' 1'1' '; \ .1.; I \.' .j ;~)fl 03 :sL-o.'lr.~- CONSTANCE P. BRUNiffJG, 1"- 1.5.5#1 o:r<~i/95'21 r ATTORNEY AT LAW 3901 N. FRONT STREET HARRISBURG, PA 17110 .- ....~..___o LAWRENCE E. WELKER ~OfIlOHOfA~'t CUMBERL....ND COUNTY C....RLISLE. P.... 1701l - I.r, ~ ~ Ln ....... ^manda L. Schell 277 Califor"; ~ ...~~..- \~ahiawa, III ~.. f 4... .. 5CHea77 Qb76b.005 ~~Q5 O~/~7IQ5 5CHel.l.'AMANDA MoveD l.ePT NO ADDRess UNABl.e TO PORWARD ReTURN TO aeNDeR n: , ~. 17111H~S4 :32 111",11",0.110,11,.11."110"11",11,',,,01111,,.11,,,11"01 ~,"'i._.- ,,'.l.-j"""'~'''.'-''"-'~----.---~~ , , I \ i \ r .;..~< I l' ....... \ " , ~'> ,- 9._"_ .......-. ._;...~ ...._.... ,_" , . .'a_... - . +- CONST.AN~ P. BRUNT AlTORN AT lAW A_ .... " ---.-.-....- . IN ~IE COURT OF COMMON PLEAS OF r DENNIS E. SCHELL, JR., . . . CUMBERLAND COUNTY, PENNSYLVANIA . Plaintiff . . v. . CIVIL ACTION - LAW . . . AND NOW, consideration : No. Q5. I ;)13 C.U~O T.Q,,&, Defendant : IN CUSTODY g:~ !.;; .t~ .z .~-l "jfn.I:. ,...."", :7 In "ll~: c:::> ;~,~(;}~;. .t:.. . ~ (;, :t: ." this J 6 th. day of JV)'1r c h , 199t~'in ~ .::~ .. of the attached Complaint, it is herebydir~ed AMANDA L. SCHELL, ORDER OF COURT that the parties and their respective counsel appear before S o.mlM I LAnde's F&t, , the conciliator, at ,Q<,-III- (;;1'h sl. {t1r>'oOy;", on the ~ day of -f'lA\.f ' 1995, at '3 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. Failure to appear at the conference may provide grounds for entry of a i I I I ! temporary or permanent order. FOR THE COURT, L By: custody 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. Office of The Court Administrator Cumberland County Courthouse 4th Floor 1 Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 ,.'"'" r' MAy 08 1);95 .)!~ I "III '," :1 ii' '95 '~r G ~" . "l~. , .\'\1 .; i DENNIS 8, SCHELL, JR., Plaintiff VB. ) ) ) ) ) ) ) IN TlfB COURT OP C0H/10N PLBAS OP CUHDERLAND COUNTY, PENNSYLVANIA NO. 95-1273 CIVIL TERM CUSTODY AMANDA L. SCH8LL, Defendant !OO!!m AND NOW, this ~tL day of IM7) , 1995, upon receipt of the conciliator's report in this matter, it appearing that the three minor children which are the subject of this order, who are identified below, have been residents of Pennsylvania and living in the primary physical custody of their father since late JulY, 1993, that the mother of the children was served with notice of this proceeding and of the conciliation conference, and that the mother did not appear, we hereby enter the following orderl 1. Legal custody and primary physical custody of the minor'children, Anthony James Schell, born June 1, 1989, Derick Scott Schell, born May 16, 1990, and Mason Storme Schell, born Docember 27, 1991, is hereby awarded to their father, the Plaintiff, Dennis E. SChell, Jr. 2. The mother of the children, the Defendant, Amanda L. Schell, shall have such periods of temporary custody or visitation as the parties may agree. In the event that the parties cannot agree or that the mother or the father for 1 " " any ot~er reason vant a specific schedule of custody, ve viII set such a schedule upon the appropriate request of either party, BY the Court, J. We-? Constance P. Brunt, Bsquire Attorney for Plaintiff ~.:w ('~,:...LA_ 5/9/ q 5, -Ji"p, A~anda L. Bchell, pro se 2415 Lamanche New Orleans, Louisiana 70117 sla 2 . 111 > (:l 3 ~ 8 -: !:: ., iIl 3 ~ < c.i1 ~ II .. " $ :< , ~<5~~ , ::: 'Jj ~ x ~ (:l ~ 0 <Il ., ;.J ~ ~ II 0( ~ " d ~ . ;;.. 0 ~ ~ P- . ~ 0 lJ ~ <;< jr. ~ ~ 6 ~ ., 1- < ~ ..' .. - HAY 0 B \ggS ,\.,1' ...' ,.. , . DBNNIS B. SCHBLL, JR., I IN THB COURT OF COMMON Plaintiff I PLEAS OF CUMBERLAND I COUNTY, PENNSYLVANIA vs. I I NO. 95-1~73 CIVIL TBRM AMANDA L. SCHELL, I Defendant I CUSTODY JUDGB PREVIOUSLY ASSIGNBD: None CONCILIATOR COIlPBIlIlNCB SUItKAJIY REPORT IN ACCORDANCB WITH CUMBERLAND COUNTY RULE OF CIVIL PROCBDURE 1915.3-S(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the children who are the subject of this litigation is as follows: NAHE Anthony James Schell Derick Scott Schell Mason Storme Schell BIRTHDATB CURRENTLY IN CUSTODY OF Plaintiff/Father Plaintiff/Father Plaintiff/Father 1 June 19S9 16 Hay 1990 27 December 1991 ~. A Conciliation Conference was held on ~ Hay 1995 and the fOllowing individuals were present: the Plaintiff and his attorney, Constance P. Brunt, Esquire. The mother was properly served in this action but, because she lives in Louisiana, did not appear. 3. The mother and father last lived together in Hawaii. The father came to Pennsylvania, with all three children, in late July of 1993. He has been employed and lived here, with all three children, since that time. In the meantime, the mother remained in Hawaii until March of 1995 when she moved to Louisiana. The mother has seen the children only one time, over Christmas of 1993, since the parties separated. 4. Under the circumstances, the court should enter some type of order to stabilize the status quo. I have prepared such an order and attach it. It the mother wants a schedule of temporary custody, the burden will be on her to request it. - 5. With the entry of the attached order, no further action is necessary at this time. 4 Hay 1995 ~ Sa 1 L. Andes Custody Conciliator .. - . - , DENNIS E. SCHBLL, JR., I IN THB COURT OF COHHON Plaintiff I PLBAS OF CUHBERLAND I COUNTY, PENNSYLVANIA vs. I I NO. 95-1273 CIVIL TERM AI1ANDA L. SCHBLL, I Defendant I CUSTODY Q!Y.lllR AND NOW, this day of , 1995. upon receipt of the conciliator's report in this matter, it appearing that the three minor children which are the subject of this order, who are identified below, have been residents of Pennsylvania and living in the primary physical custody of their father since late July, 1993, that the mother of the children was served with notice of this proceeding and of the conciliation conference. and that the mother did not appear, we hereby enter the folloWing order: 1. Legal custOdy and primary physical custody of the minor children, Anthony James Schell, born June 1. 19S9, Derick Scott Schell, born Hay 16, 1990, and Hason Storme Schell, born December 27, 1991, is hereby awarded to their father, the Plaintiff, Dennis E. Schell. Jr. 2. The mother of the children, the Defendant, Amanda L. Schell, shall have such periods of temporary custody or visitation as the parties may agree. In the event that the parties cannot agree or that the mother or the father for 1 .., -, , any other reason want a specific schedule of custody, we will set such a schedule upon the appropriate request of either party. By the Court, J. Constance P. Brunt, Bsquire Attorney for Plaintiff AManda L. Bchell, pro se 2415 LalT'a.nche New Orleans, Louisiana 70117 sIa 2 . . ',' .~'''. .'0;._..:........., .~,. " ..,' ','.,' .~"'~___..:::.;~tv~r---