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HomeMy WebLinkAbout00-00362 j,. .... " < VICKI 1. RHOADS, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :CNIL ACTION - LAW :CUSTODYNISITATION :NO. &,.H/(Y 3t.a ~ JAMES RHOADS, JR., Defendant ORDER OF COURT AND NOW, qc,v)UJ(L,Vr\dLl,OO , upon consideration of the attached complaint, it is hereby directed th~t the parties and their respective counsel appear before M.~cu.Q 1':Jw\~Q/ , the conciliator at ':';0;:2 :;. l0:A~ 9:MJ f (LJ'lf Ult.l on the ~ day 0 (11i0lCf\ ,2000, at (tJ:CO 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 defme and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: 0\L(J~ ~ ~np6j~:.fh~ ~J Custody Conciliator l ) The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE TIDS 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 . < ~L" ",""~ FlLED-..QFFiCF ""'r- 'T'l lr- .~'\"''T1' - UI- ';"1':: ~):':;)!:"iONOTJ\RY OO.Jf1N31 P!11:58 CUMBEi':;U\I"JiJ COUNTY PENNSYLVANIA /-3/~O tJ'~Ju~ -tJ4~ /'31.dtJ '7ltilid ~ ~ 4 ~ /;3u?cJ /~ ~ ~ dF' ~ ~ . ., " - """~'1',-1!!llllJlH!1III~!III '""1"'1' ^ _,. ~ , . . ~ ,~, - ,~,- - - ~, '~~V '-:0:: .. , VICKI 1. RHOADS, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :CNIL ACTION - LAW :CUSTODYIVISITA TION :NO. Qrnrv - 3(..L ~ ~ JAMES RHOADS, JR., Defendant COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Vicki 1. Rhoads, who, by and through her attorneys, Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and Beckley & Madden, of Counsel, files this Complaint for Custody, and in support thereof avers as follows: 1. The Plaintiff is Vicki 1. Rhoads, who is an adult individual residing at 601 Village Road, Orwigsburg, Schuykill County, Pennsylvania 17961. 2. The Defendant is James Rhoads, Jr., who is an adult individual and upon information and belief currently residing at RD 3, Box 349B Flat Hill Road, Pine Grove, Schuykill County, Pennsylvania 17963. 3. The Plaintiff and the Defendant are husband and wife. 4. Plaintiff and Defendant are the parents of one minor child, Adriana C. Rhoads, who was born on September 9, 1992, and is currently seven years old. Adriana was not born out of wedlock. Plaintiff is Adriana's mother; Defendant is her father. 5. Adriana C. Rhoads currently resides with her paternal grandparents, James and Sandy Rhoads, at 311 4th Street, Summerdale, Cumberland County, Pennsylvania. ~ -. ~.' ... She has lived at that address since August, 1998. Prior to that time she lived with Plaintiff and Defendant at the marital residence located at RD 3, Box 349B Flat Hill Road, Schuykill County, Pennsylvania for about three years. Before the parties moved to the Pine Grove address, they all lived with the maternal grandparents, John and Connie Metrovka at 882 Surmner Hill Road, Auburn, Schuykill County, Pennsylvania since the parties married on February 29,1992. 6. Plaintiff seeks primary physical custody, and shared legal custody, of Adriana C. Rhoads. 7. Plaintiff has not participated as a party, witness or in another capacity in other litigation concerning the custody of Adriana C. Rhoads in this or any other court. 8. Plaintiff has no knowledge of any other custody proceeding concerning Adriana C. Rhoads pending in a court ofthis Commonwealth. 9. Plaintiff does not know of any person not a party to these proceedings who has physical custody of, or who claims to have custody or visitation rights with respect to, Adriana C. Rhoads. 10. Awarding to Plaintiff primary physical custody and shared legal custody of Adriana C. Rhoads will serve her best interest and permanent welfare for the following reasons: A. Plaintiff has a close and loving bond with Adriana C. Rhoads, and was her primary caretaker since birth until she went to stay with her paternal grandparents. - =. '"'j~l~j .. B. Because Plaintiff is gainfully employed as a Registered Nurse, Plaintiff has the financial ability to ensure that all of Adriana's needs are met. Plaintiff also has the fmancial ability to ensure that Adriana receives adequate care and supervision during those hours when Plaintiff is at work. C. Plaintiff is currently pregnant with her second child which is due in April, 2000. Plaintiff is also engaged to be married once her divorce is finalized., After the baby is born in April, Plaintiff intends to return to work on a part-time basis only to ensure that she has enough time to spend with both of her children. D. Plaintiff freely acknowledges that Adriana has a close and loving bond with Defendant, and for that reason Plaintiff will ensure that Defendant enjoys liberal partial custody rights, and will ensure as well that Defendant remains a full participant in decisions affecting Adriana's growth and development. 11. Each parent whose parental rights to Adriana C. Rhoads have not been terminated, have been named as parties to this action. - -., ~~""""'" , WHEREFORE, Plaintiff, Vicki 1. Rhoads, respectfully requests the Court to award her primary physical custody, and shared legal custody, of the parties' minor child, Adriana C. Rhoads. Of Counsel DATED: 1-11{t) BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, P A 171 08 (717) 233-7691 ~~ Attorneys for Plaintiff Vicki L. Rhoads ~~~ ~ ..dll;h o o VERIFICATION I, Vicki Lee Rhoads, hereby verifY that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. DATED: J-/J'vO to>~';, ~'" ~anac(}4U Vicki Lee Rhoads , ~ ra ....n ~ C> ~ \6 \~ -J- u; ~ ~- 0 -:) ~:7 0;:1; JY) (,~ f' :c '2:; C.::r! 04, 9G, a.. L~~ "" @L: 0 ,~~ ~ ~ r0 ~ N u:~~ :;!;: ~,dLLJ ~ ~ "1 Fe C!IQ'.:.. mCl... -, 2 .... ~ t,L. 0 C> :::J "'6 0 (.) d ~~ ~@3 '<: , - .- j ... BECKLEY & M ATTORN ADDEN HARRISBURG. PE ;EYS AT I"AW ! NNSYLVANIA 1no8~ 21 ZOOQ rf! 00 '" '" ... Z 00 ri1 ;:: A" " ::; A" " ~:h H~ -,~ f1 5 rn ~ :'1l ~~O~~~ ,>;) [/] H " " " ,"l',j i>; ~ · " w ~UiU Q ~ ;j Hi ri1 ,,~ ~ ffi ... ~ ~ . ~ '. '. i ,_ '";t..,_> ~.' , ,-, ~<, .'-,"" '^ - ""_'"_ll^:'"", "J-I. ~ ";!;l " VICKI 1. RHOADS, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :CNIL ACTION - LAW :CUSTODYIVISITATION JAMES RHOADS, JR., Defendant :NO. 2000 - 362 ACCEPTANCE OF SERVICE I, Anthony M. Hopkins, Esquire, hereby accept service of the Complaint for CustodyNisitation filed in the above-captioned matter on behalf of James Rhoads, Jr.. DATED: 2,.-2-'S""cro tvm I~J~ Anthony M. Hopkins, Esq. Nikolaus & Hohenadel 212 N. Queen Street Lancaster, P A 17603 (717)299-3726 Co, :0- r-- 2:: :,J< ~3;; ..~~ ~;;--;;! >:- ~~~ U..JuJ CCID..- :2 C") C >:: ~ t;:-~ Ul';s.~ c');:;::- U:'-Oj ~.J - -r==: C).....'l ... l.~ 6c: uJ') -;:::::~tU Ll.. ;~~~. .;;: ::rr:: Q- ct.:: ~~ :!C - "') ~ 00 '" '" " Z 00 0 " I'il " @ ~ ~ " <I 8 ~ 00 ~ -<l1 ..:i 00 z ~ 8 00 " ~ ;g ~ o rn " o 0 ~ ~ J8 ~ " " d " rn >< ~ . . S z ~ 8 ' z I'il ~ ~ ~ H 0 ~ ~ ~ ~ o Z ~ c$ '" Q<li " ~ '" ~ I'il Pl ~ rn ~ ~ ~ 1 ~ ~, ~.~ '{!o, '..' -, "!,,,,--> " J }', ,," " '" ", BECKLEY & MADDEN ATTORNE1;S,~t-T LAW HARRISBURG. PENNSYLVANIA 17108~1998 " atJ'!)1 jJJ,1 l' J! ~ " 'fr'-- '" ., ' -,'-" ,~' ~""',,,'_,; _' u . ".'_ 1-"; "" ~ I "" " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VICKI L. RHOADS, Plaintiff NO. 2000-362 vs. JAMES RHOADS, JR., CUSTODYNlSITATION Defendant PRAECIPE ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Nikolaus & Hohenadel, LLP by Anthony Marc Hopkins, Esquire, on behalf ofthe Defendant, James Rhoads, Jr., in the above- captioned case. NIKOLAUS & HOHENADEL, LLP Date: ~"'--l.- '?-eft> By:. Om I~~ Anthony Marc Hopkins, Esquire Attorney for Defendant 1.0.#47394 212 North Queen Street Lancaster, PA 17603 (717) 299-3726 , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VICKI L. RHOADS, Plaintiff NO. 2000-362 vs. JAMES RHOADS, JR., CUSTODYNlSITATION Defendant CERTIFICATE OF SERVICE I hereby certify that I have this day served a true and correct copy of the attached Entry of Appearance filed in the Prothonotary's Office of Cumberland County, Pennsylvania, upon the following person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Service by First Class Mail Addressed as Follows: Elizabeth S. Beckley, Esquire Beckley &Madden Cranberry Court 212 North Third Street P. O. Box 11998 Harrisburg, PA 17108-1998 Date: L ~ 2..-'3 ....-00 NIKOLAUS & HOHENADEL By: ~/~!- ( Anthony M c Hopkins, Esquire Attorney for Plaintiff Attorney 1.0. No. 47394 212 North Queen Street Lancaster, PA 17603 (717) 299-3726 I.~O" "'~ ,.' -,.,- ~ if .J'" "c'O'" ce,"',,,, , _ ",-- 'o'C \ 0 0 0 c <::> " 5: 3: ---4 vCO t::.~ i~~;.~ n-lr;l = ~~~~ urn G) "')9 g(~) C: f) -0 ---c- -I' ''"'I ~:::- -;',... ')- ~8 - 'ie) 1:.- ;~iTl ....--: - L_ '~ Z :::> J> =2 ::q (-0 -- ~ , , ." ."'",e- ,.c-,,__..:c;'~':,;;,'>" ~_, _', o--'~" ,h -~.,;:'\,,,,';;,~'r/ ~'" ,.-0,:"",).;(;1,.-", ,~',;,^;"--"",,,';;,;!",,,;'" ;.- ''' '!;:.;~~.:>~ i,'> ,'~~I;,,-_, _'.', ;,~,~-, ':,,_ DAVID ALAN DREESE, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-364 CIVIL CRYSTAL WALKDEN DREESE, Defendant CIVIL ACTION - LAW IN DIVORCE ELECTION TO RESUME PRIOR NAME I, Crystal Walkden Dreese, do hereby elect to resume my prior name, to wit: Crystal Walkden. I have been divorced from my former husband by Decree in the Court of Common Pleas of Cumberland County, Pennsylvania, entered to the above number and term on May 30, 2000, and givEr this written notice avowing my intention in accordance with the provisions of 54 Pa.C.SA Section 704. ff:dJ ~b} ~ Cry a Walkden Dreese, be known as (I A Md iJ (PYx;.J fl41) cry;~ ~Ikden Sworn to and sUbs/fed before me this day of J.M'\.e.. , 2000. ~C?-q~ Notary Public (SEAL) 28210.1 ~ -. KEVIN E. HOBBS MY ~M!:fBION EXPIRE. - /-2n/li. ~ n oCQ. (') CJ 0 T' ~ c 0 -n s: '- f- If::. c -ucn c:: ITlf--"~ r -';'::C, ~-n ~~ .;1"'-. C .';",rn ~ ~ ,'-" :C!C-:J :'., 1 'l:) ~C~ ~~p e, :>c -0 ~ f ?=c5 ~E!S (j "- )>c ;::: ,;,~:::.rn u ~ _....I " J U1 >' ~ ~ , ~~ ~ - '., I . , VICKI 1. RHOADS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODYIVISITATION JAMES RHOADS, JR., Defendant : NO. 2000-362 "'~- ORDER AND NOW, this ~ day of ~ , 2000, it is hereby ORDERED that the Petition for Leave to Withdraw as Plaintiff's Counsel is GRANTED. Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and the Law Firm of Beckley & Madden are hereby granted leave to withdraw as Plaintiff's Counsel in this matter. topW {tjU J. 10 -/3 .00 RX..s ,""' " ,,~ oo,~ r -P _~dO ~"..,,,,..,,,, , r,:1~ ~f)--+1JfFjCE cr ~- . -r~:",iOTARY CI1'O ()f''I' t.t' '"' j~, l 13 'I" S' I" /,1"1 L' C CU',\fk':~';\li") (f")II'N'TY 'il;,.~,~, ,_1"\ ,;..... .............J PENf\SYlVAN!A , "~Q~;a.-lllJ1ll!fll. ~".,"'~""!"~. !l'lI'11r~ ,,< -, ~~, _'_, _ l!!I,lIl!!I' ~~-~ -~ ~ - I -~" VICKI 1. RHOADS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODYIVISITATION JAMES RHOADS, JR., Defendant : NO. 2000-362 PETITION FOR LEA VB TO WITHDRA W AS PLAINTIFF'S COUNSEL AND NOW comes Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and Beckley & Madden, Of Counsel, and hereby petitions the Court for leave to withdraw as plaintiff's counsel, and in support thereof avers as follows: 1. In December, 1999, at the request of the Plaintiff to Elizabeth S. Beckley, Esquire, Beckley & Madden agreed to represent Plaintiff in the above-captioned matter. 2. Counsel undertook representation in the above-captioned matter based upon a written Retainer Agreement with Plaintiff, whereby Plaintiff would pay outstanding invoices on a monthly basis. 3. On September 15, 2000, Plaintiff sent a letter to Beckley & Madden terminating services. A true and correct copy of the letter is attached hereto as Exhibit A. 4. Elizabeth S. Beckley, Esquire, contacted Anthony M. Hopkins, Esquire, Counsel for the Defendant in the above-captioned matter, by telephone to inform him of Beckley & Madden's desire to withdraw as counsel for the Plaintiff. Mr. Hopkins informed Ms. Beckley that he did not oppose Beckley & Madden's Petition to Withdraw. ~- - - " Wherefore, Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and Beckley & Madden, Of Counsel, respectfully request leave of Court to withdraw as Plaintiff s Counsel DATED: Id'{; 'Cf) Respectfully submitted, Of Counsel ~~ & ~~' BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg,PA 17108 - ,- I , . EXHIBIT A ~ ." '''~ - - , '~" t ~' , t;, I) l~ ' I, i;,: " .~ i ...,-. ",,"','_'c:' .,-,. __...'.'.<,'- September 15,2000 Beckley & Madden Attorneys at Law Cranberry Court 212 North Third Street Post Office Box 11998 Harrisburg, PA. 17108-1998 , Vicki Rhoads 601 Village Road Orwigsburg, P A. 17961 Dear Ms. Beckly: This letter is to inform you, that effective immediately, I will no longer be retaining your services. The financial hardship is too great an expense for my family to incur. Should it become necessary for me to seek legal representation in the future I will use an attorney from Schuy1kil1 County, as the minor child, Adriana Concetta Rhoads, has resided in the named county for the past ten months. Thank you for the assistance you have provided in my custody situation, and your cooperation with payment terms for my outstanding balance. Best Regards, ~~ Vicki Rhoads I" if /6L/() -," " 'il<lil~" CERTIFICATE OF SERVICE I, Elizabeth S. Beckley, hereby certify that a true and correct copy of the foregoing document was this day served upon the persons and in the manner indicated below. FIRST CLASS MATI, Anthony M. Hopkins, Esquire Nikolaus & Hohenadel 212 N. Queen Street Lancaster, PA 17603 DATED: 10-19 -00 fi: / ~ ,..- ,--, t:~2 ~;< H '. (' --.'~ j,:c','- ~ In N 0_ 1'= Z ?<c ~3~ -> C] ::J \-~&J [~~~ >1'..U (UO- C) ...' C..'- ~, ,~ <. -, -~ () . ., ',' 00 '" '" ... 00 z 0 ... ~ " @ ~ 8 ... . <i ~ . ~ 8 g z 1 >-< ~ rJJ ~ ~ ,~ ~ 0 Q ~ ~ H ~ ~ ~ ~ " ,. . 00 >d . ~ E ~ . 8 ~ ~ Z " ~ ~ H 0 ~ ~ ~ ~ 0 r5 , '" ~ Q <11 ... '" p ~ ~ rJJ ~ ~ ~ ~ <i ~ .~ BEOKLEY & MADDEN ATTORNEYS AT LAW HARRISBURG. PENNSYLVANIA 17108-1998 . Cty01 lJCr 11 ifIDiti'" VICKI 1. RHOADS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLV ANTA v. : CIVIL ACTION - LAW : IN DIVORCE JAMES RHOADS, JR., Defendant : NO. 2000-362 PRAECIPE TO WTTHDRA W TO: The Prothonotary Kindly withdraw the appearance of Thomas A. Beckley, Esq., Elizabeth S. Beckley, Esq. and the law firm of Beckley & Madden as counsel for the Plaintiff, Vicki 1. Rhoads, in accordance with the the attached Order granting leave to do so. DATED: loj;~/{Jd Of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 t VICKI 1. RHOADS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA v. : CIVIL ACTION - LAW : IN CUSTODYNISITATION JAMES RHOADS, JR., Defendant : NO. 2000-362 1 j r-......."'. ORDER AND NOW, this IV"" day of ~ , 2000, it is hereby ORDERED that the Petition for Leave to Withdraw as Plaintiff's Counsel is GRANTED. Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and the Law Firm of Beckley & Madden are hereby granted leave to withdraw as Plaintiffs Counsel in this matter. J. ~~ J ~IW!:L. CERTTFICA TE OF SERVICE I, Elizabeth S. Beckley, hereby certify that a true and correct copy of the foregoing document was this day served upon the persons and in the manner indicated below. FIRST CLASS MAIL Anthony M. Hopkins, Esquire Nikolaus & Hohenadel 212 N. Queen Street Lancaster, PA 17603 Ms. Vicki 1. Rhoads 601 Village Road Orwigsburg, P A 17961 DATED: IO//~/(jj u. " ~ !- (..) CJ o C) ;>- r- '7 5<( ~~ ~z;,,&J ~~~ ~s 5 () .~ iX; F:; LU'J ft~ L~'.. r-' u-: ~"r- ;~ , 00 '" '" ... Z 00 0 ~ ... " @ ~ ~ ... <i ~ ~ . ~ 1>-< 0 z . " ~ .~ ~ o rJJ " Q ~ ~ ~ ~ ~ ~ ~ . ,. ~ 00 ~ ~ " ~ ~ z ~ ~ ' z H ~ . 0 ~ ~ B z 0 r5 S ~ '" . ~ ~ '" p ~ ~ ~ rJJ ~ ~ ~ <i ~ . , . BEOKLEY & MADDEN ATTORNEYS AT LAW HARRISBURG. PENNSYLVANIA 17108-1998 ~JtII I -'~ <-' '), . ""0" .,':'0.>.',';;>__,,' . -":' OCT 2 0 200~ JP VICKI 1. RHOADS Plaintiff ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000-362 CIVIL TERM JAMES RHOADS, JR. Defendant CUSTODYNISTTATION ORDER OF COURT AND NOW this /1-1'- day of O:j- . , 2000, having not heard from the parties for some time, the undersigned Conciliator assumes the matter has been resolved and hereby relinquishes jurisdiction of the case. If either of the parties wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, 2 MICHAEL 1. BANGS Custody Conciliator Mrs. Vicki 1. Rhoads 601 Village Road Orwigsburg, P A 17961 Anthony Marc Hopkins, Esquire .~ """",,, ';~~~-,-",,~ .~ "__.'"'""'0" ... "',' c, o ~~~ ~rf.~ 2:::__:: 55~~. ;:$ /7-:~ J~ :?: =2 t::; ~' S? '-' :::::. '''J .'-"1 i'\.J;. " ~', :;:b :I;': '!'-.' - " ~?f~ .:::),Tl S:! ="7 -< w - ",;,::,,~ ;,' <,c, .' < __. ~ ~ I.; . ~ '~ 1" .,.; ~ ~ ....' VICKI 1. RHOADS Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-362 CIVIL TERM JAMES RHOADS, JR., CUSTODYIVISTT A TION Defendant PRAECIPE TO WITHDRAW CUSTODY COMPLAINT TO THE PROTHONOTARY: Please withdraw the Custody Complaint at the above term and number, without prejudice. Respectfully submitted, NIKOLAUS & HOHENADEL, LLP Date: / /14 lol / I BY: AnfuOn~il.~ /~ J.D. No. 47394 Attorney for Plaintiff 212 North Queen Street Lancaster, P A 17603 (717) 299-3726 "J ~- ",,' '. -., , " ," ~~', , ,..I., '" ...-' CERTIFICATE OF SERVICE 1 hereby certify that 1 have this day served a true and correct copy of the foregoing Praecipe to Withdraw Custody Complaint upon the following persons and in the following manner, which satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Service by First Class Mail Mrs, Vicki Rhoads 601 Village Road Orwigsburg, P A 17961 NIKOLAUS & HOHENADEL, UP Date: l/t~ /01 BY: Ovt~ m 1M Anthony Marc Hopkins, Esquire Attorney J.D. No. 47394 Attorney for Defendant 212 North Queen Street Lancaster,PA 17603 (717)299-3726 ..". " ,," "' ",._, ~, .."'~~"'., "., """",,"'= Illij.n.~''iiJli~ ~ ,1,,_ ".w_~~-" ""'" '., , "'"J' '.,.."t<-'d''''J.. ','"'''," "- -.. () 0 C: C .'n so: "- "Uco ,"" " rnn; ::;,: i:''':-::: Z:.u 1'.:> ~}~;P? ZS:;: (..) Q)-;:~ ~::-~ ;;.~ ;:::6 " -~ " ~ ~,1 8 ::u: '-::'0 cFI1 )>c o-l Z SJ ::< {J1 -< '.