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HomeMy WebLinkAbout00-01947 ;::.m'~ - PETER A. DELORENZO, Plaintiff, * IN THE COURT OF COMMON PLEAS * CUMBERLANDCOUNTY,PENNSYLV ANIA * vs. * NO. ()() - /9'17 ~ /b--'" * DEBBIE I. DELORENZO, Defendant. * CIVIL ACTION - LAW * CUSTODY ORDER OF COURT CUMBERLAND COUNTY I''i'l 11 ( AND NOW, this l) day of fllM'- , 2000, upon consideration of the attached complaint it is hereby directed that the parties and their respective counsel appear before U,viJ 5". S~I4.'I €.s~, , Esquire, the Conciliator, at } '. ~ vJ f/..:... S't, M~J.J4JJ'CI.~ennSYIVania, on. . ,he <1+h day of (Yl~ ' 'Hl'99 at 3: 00 o'clock, P.m., for a Pre-Hearing Conference. At such conference, 01000 - - 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 a temporary order. Either party may bring the child who is the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By"hw.-v s. Svt-:ib"A;:f ["". Custody Conciliator ) ~) 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 1 COURTHOUSE SQUARE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 . , !k~~lIIi1iillJ{'I&\~~~.i~l$jlMi;f~!lI;~l!im&);olR~')I!~""'" l;~~i~'~~~"~~"~ ._~ FILED..{)rTICr: r:r 7' ,7 'Y""O-I' \RY _;r !;T~_ ,;,-,;l'. 1-, 00 f.iJ'H -5 Prl 3: 1..2 CUMLthLJ'!<D COUNT! PENNSYLVJlN!.A, /fl;. 1M -f-y,-t(? )./- b-OCJ M-do/r~~4~ ~~ ~ -(j ~ ~ ;naJU ~ a/ff- ~ , . PETER A. DELORENZO. * IN THE COURT OF COMMON PLEAS Plaintiff. * CUMBERLANDCOUNTY.PENNSYLV ANIA * vs. * NO. 0-0, 19'17 ~ T;.-. * DEBBIE I. DELORENZO. * CIVIL ACTION - LAW Defendant. * CUSTODY COMPLAINT FOR CUSTODY AND NOW, Plaintiff, Peter Delorenzo, by and through his attorney, Edward J. Weintraub, Esquire, files a Complaint For Custody against Defendant, Debbi Delorenzo, and in support thereof, avers the following: 1. Plaintiff is Peter DeLorenzo, Father, who currently resides at 531 Bedford Road, Mechanicsburg, PA 17055. 2. Defendant is Debbie Delorenzo, Mother, who currently resides at 1830 Signal' Hill Drive, Mechanicsburg, PA 17055. 3. Plaintiff seeks custody of the following children: NAME Present Address AGE Jason Delorenzo 1830 Signal Hill Drive, Mechanicsburg, PA 17 Lauren Delorenzo 1830 Signal Hill Drive, Mechanicsburg, PA 13 4. The children were not born out of wedlock. 5. The children, Jason Delorenzo and Lauren Delorenzo, are presently in the custody of Mother, who currently reside at 1830 Signal Hill Drive, Mechanicsburg, PA. 6. During the past five (5) years, the children, have resided with the - 'w "~ , , following persons at the following addresses: Persons Both parents Both parents Address 124 Grande Boulvard, Sinking Spring, PA 1830 Signal Hill Drive, Mechanicsburg, PA .!2<llil. 1995-1998 Dec. 1998-present 7. The Mother of the children is Debbie Delorenzo, who currently resides at 1830 Signal Hill Drive, Mechanicsburg, PA. 8. The Father of the children is Peter DeLorenzo, who currently resides at 531 Bedford Road" Mechanicsburg, PA. 9. The parties are married. 10. The relationship of Plaintiff to the children is that of Father. Plaintiff currently resides with the following person: Person Relationship NONE 11. The relationship of Defendant to the children is that of Mother. Defendant currently resides with the following persons: Person Relationshio Jason Delorenzo Son Lauren Delorenzo Daughter 12. Plaintiff and Defendant have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 13. Plaintiff and Defendant have no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 14. Plaintiff and Defendant do 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. 15. The best interests and permanent welfare of the children, will be served by granting the relief requested, inter alia, because the Plaintiff Father has been one of the children's primary caretakers. 16. Each parent whose parental rights to the children have not been terminated and the persons who have physical custody of the children have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene. Name Address Basis of Claim NONE WHEREFORE, Plaintiff respectfully request that this Honorable Court enter an Order granting him shared legal custody and partial physical custody. Respectfully Submitted, By: Edward J. Weintraub, squire 2650 North Third Street Harrisburg, PA 17110 (717) 238-2200 Attorney ID. #17441 Dated: ~ 1'lJO r lTO { ATTORNEY FOR PLAINTIFF ., , ~"," "" .... ~.. . '-X VERI FICA TION I, Peter DeLorenzo, hereby swear and affirm that the facts contained in the foregoing Complaint for Custody are true and correct and are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. , Date: 3 \'L~ leu '.,', - ".'.,- , ~ -Ptt. ~ .. FiLED-OiTlCE OF T:-.!L:. r:r'~r}+J(!CTARY ~ '-!tJ,oO 5,uv nf'l'i~Rr>ll p"I').~n ..JU f,j.;; \ J", ll.L' to SJ ...L- .. I I ; cU""r"u' ,<, "'I')' "JTY IVI;)..:t\ .'o;.\L) 0.....0)' I PENNSYLVAJ\!V\ r"l~Sb S.UV ,.b .slJ, ,SO ~. ~ i I ; I I V<..1' r(., ~. 'lJ",'f . . PETER A. DELORENZO, * IN THE COURT OF COMMON PLEAS Plaintiff, * CUMBERLAND,PENNSYL VANIA * VS. * NO. 00-1947 * DEBBIE I. DELORENZO, * CIVIL ACTION - LAW Defendant. * CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF AND NOW, this 4th day of April, 2000 personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Misty D. Lehman, who being duly sworn according to law, deposes and says that on March 30, 2000, she mailed a certified copy of the Complaint in Divorce by certified mail, restricted delivery, return receipt requested, to Debbie DeLorenzo and the same was received by her on March 31, 2000 as indicated by the return receipt card which is attached hereto. ~~ .r;~tl maY) Mist D. Lehman I:, '.\' roo ,., " . , . - 1 811Jftur I-fer 8fIldllflilnal ieFVIces. I IftlWlS'3, 48. and 4t. . -Pdnt your name and addren on1he reverse 01 this 10rm so1ha1. we can retumthis I l\Ilrd to you, .ach this fonn to the front of the mallplece. or on the back It space does not m ~i!-Retum RecsJpt Requested- on the mallpiece below the article number. >. .the Return Receipt will show to whom the article was delivered and the date Ii clllliveted. ' I 3. Article A~ressed to: _ I Debbie 1)e.LDrt' n co;, II 11.)0 SK:jrJu--l t-\1\\~lC r0ecmv)l(~~ Oft' I }Q)f' 5, Received By: (Print Name) I slSIl wish Ie receive tile following services (for an extra fee): 1. 0 Addressee's Address ~ 2.Jd Restricted Delivery .i Co~sull postmaster for fee. .} 4a. Article Number ~ :c,. () Ii 4b, Servlce Type ii D'Registered &certifled ~ o Express Mail ,Po- __1.>,/ 0 Insurea i RelumRecelpt~ 0 COD " , Date ,9l9~ry i -:?!:i/ ~() ! 8. Addressee's Address (Only if requested i end fee Is paid) ~ I .!I! "', i' .lISIic Return l'Ieoei ' + ~,~ ~ I ~ -r" '<' ~I " -. . 0 C> -c~ 0 <:;; mn'" :;C z=a zc I U?'-':~ (J e;,6 - ~o '" -0 '::" t~) ;PC Z ;.".\ :< ( ~Q (,,:' --Zo ." _..,....., _,__"",,,.,_.~~~_.~I"I!II!!I;Ia_~~~ !~'IIilI~~"~._"", ~_ I~~IJ!I.T, P'" ~"!IIl'" PETER A. DELORENZO, * IN THE COURT OF COMMON PLEAS Plaintiff , * CUMBERLAND,PENNSYL VANIA * VS. * NO. OO-l9~7 * DEBBIE I. DELORENZO, * CIVIL ACTION - LAW Defendant. * CUSTODY CERTIFICATE OF SERVICE I, Misty D. Lehman, Legal Assistant to Edward J. Weintraub, Esquire, hereby certify that on March 30, 2000 I served a true and correct copy of a Complaint in Divorce filed on March 30, 2000 upon Debbie DeLorenzo, Defendant, by depositing same, certified mail, return receipt requested, restricted delivery, postage pre-paid, in the United States Mail, Harrisburg, Pennsylvania, addressed as follows: Debbie DeLorenzo 1830 Signal Hill Drive Mechanicsburg, PA 17055 Date: 1..~).3~ (jD c/J1/!Jt{ l}~ Misty D. Lehman """~ ..;; ~ Zo 'Z <I (") c: ~ "'nEb m..-~ Z;'l'-; ~~~.~. ;:S:;~-~ ~~''"-' :Z() -C) >c -, ::~ -<, ,~ . Q o ",. '" :;0 o -T, ,.~',; 'Ti '?':;; =''2f~.~ , ,~'i' g;~ ;:-'~I "~J =<: I '-Ie :~ I:'? ':...) .-:- .. ~._--"~,.. ,- I ~ ~~ = ~~~_j'!ll'!'l'f.lt;~l"I~~ilR~~__I_' PETER A. DELORENZO, * IN THE COURT OF COMMON PLEAS Plaintiff, * CUMBERLAND,PENNSYL VANIA * vs. * NO. 9.000- \qJ.t'l * DEBBIE I. DELORENZO, * CIVIL ACTION - LAW Defendant. * CUSTODY CERTIFICATE OF SERVICE I, Misty D. Lehman, Legal Assistant to Edward J. Weintraub, Esquire, hereby certify that on April 10, 2000 I served a true and correct copy of a Order of Court regarding the Custody Conference filed on April 6, 2000 upon Debbie DeLorenzo, Defendant, by depositing same, certified mail, return receipt requested, restricted delivery, postage pre-paid, in the United States Mail, Harrisburg, Pennsylvania, addressed as follows: Debbie DeLorenzo 1830 Signal Hill Drive Mechanicsburg, PA 17055 Date: f./,hO) {)O ~#tt, O~ Mis y D. L hma , - ( -" -,,~, "' ~~ (") co (~ c: 0 ,1- ~ ~ v ,-.v -0 -n n-I rn AJ f~ 2':: :r ~~~-, '-,.' ~~ , (:.J --~ --0 ;", ::J: ~Q '.' ~~ "" <__,:'1"1 ,,,-..) -.,......: ~ e::.=. -< ("1\ -<-- ~ ~ ...-, ~~","~~!!!'iIlll!ImiIIi!III!I!lIlm~'~-<QIiI~~~f" \.,. (!J~ ' . MAY 0 9 2qgf PETER A. DELORENZO, Plaintiff, * IN THE COURT OF COMMON PLEAS * CUMBERLANDCOUNTY ,PENNSYLVANIA * vs. * NO. ~1-(J. /Q'f1 ~ (p..... * DEBBIE I. DELORENZO, Defendant. * CIVIL ACTION - LAW * CUSTODY ORDER OF COURT AND NOW, this JJ!. day of vt.1 .> l DECREED that the Stipulation for an Agreed Order of Custody signed by the parties , 2000, it is ORDERED and be entered as an ORDER of Court. BY THE COURT: ??La '~ .j -I ()-Q 0 Rk3 (") c; ~ .~ .:G .C-" -""-: ~ ~f:. "n ~Q Pc 2: =< f=> 'U :x i:? r.- (n C) Cl o " ~-;:I ;~1 ;!! -Z7fTl ~39 -,~6 :}:=H 2~ ~ ?ii -< 3: J:.. --< / I ., ! , I ) PETER A. DELORENZO, * IN THE COURT OF COMMON PLEAS Plaintiff, * CUMBERLANDCOUNTY,PENNSYLV ANIA * vs. * NO. 0-0_ J9'f1 CwJ -r ..e..- * DEBBIE I. DELORENZO, * CIVIL ACTION - lAW Defendant. * CUSTODY STIPULATION FOR AN AGREED ORDER OF CUSTODY AND NOW, the parties, by and through their attorneys, stipulate and agree as follows: I. LEGAL CUSTODY 1. The parties hereby agree to share legal custody of their minor children, Jason S. Delorenzo born October 18, 1982 and Lauren A. Delorenzo born June 19, 1986. All decisions affecting the children's growth and development including, but not limited to: choice of camp, if any; choice of day care provider; medical and dental treatment; psychotherapy, psychoanalysis, or like treatment; decisions relating to actual or potential litigation involving the children, directly or as beneficiary, other than custody litigation; education, both secular and religious; scholastic athletic pursuits and other extracurricular activities; shall be considered major decisions and shall be made by the parents jointly, after discussion and consultation with each other and with a view towards obtaining and following a harmonious policy in the children's best interest. 2. Each party agrees to keep the other informed of the progress of the children's education and social adjustments. Each party agrees not to impair the other party's right to shared legal or physical custody of the children. Each party agrees to give support to the other in the role as parent and to take into account the consensus of the other for the physical and emotional well-being of the children. 3. While in the presence of the children, neither parent shall make or permit any other person to make, any remarks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the ,-~~ " " .. express duty of each parent to uphold the other parent as one whom the children should respect and love. 4. It shall be the obligation of each parent to make the children available to the other in accordance with the physical custody schedule and to encourage her to participate in the plan hereby agreed and ordered. 5. Each parent shall have the duty to notify the other of any event or activity that could reasonably be expected to be of significant concern to the other parent. 6. The parents shall communicate directly with one another concerning any parenting issue requiring consultation and agreement and regarding any proposed modifications to the physical custody schedule, which may from time to time become necessary, and shall specifically not use the children as a messenger. Furthermore, neither parent shall discuss with the children any proposed changes to the physical custody schedule, or any other issue requiring consultation and agreement, prior to discussing the matter and reaching an agreement with the other parent. 7. With regard to any emergency decisions which must be made, the parent with whom the children are physically residing at the time shall be permitted to make the decision necessitated by the emergency without consulting the other parent in advance. However, that parent shall inform the other of the emergency and consult with him/her as soon as possible. Day-to-day decisions of a routine nature shall be the responsibility of the parent having physical custody at the time. 8. Each parent shall be entitled to complete and full information from any doctor, dentist, teacher or authority and have copies of any reports given to them as a parent. Such documents include, but are not limited to, medical reports, academic and school report cards, birth certificates, etc. Both parents may and are encouraged to attend school conferences and activities. The Mother's name shall be listed with the school as the alternative parent to be contacted in the event of an emergency and to be notified regarding school events. However, it will be Mother's primary responsibility to provide Father with copies of report cards and all notifications of major school events. 2 ~ " I 9. Neither parent shall schedule activities or appointments for the children which would require their attendance or participation at said activity or appointment during a time when she is scheduled to be in the physical custody of the other parent without that parent's express prior approval. 10. The parties hereby acknowledge that they have discussed and jointly made the following decisions: a. The parties agree that Good Hope Family Practice will continue to be the children's pediatrician and accordingly, will provide medical treatment to the child when necessary. b. The parties acknowledge that the children's legal name are Jason S. Delorenzo and Lauren A. Delorenzo and that they shall be known by this names for all purposes. The parties agree that they will instruct their respective families and friends that the children should not be referred to by any other name. II PHYSICAL CUSTODY The parents shall share physical custody of the children. Mother shall have primary physical custody. Father shall have partial custody as periodically determined by mutual agreement. Failing mutual agreement to the contrary, the following schedule shall apply: A. With Jason at any time convenient to Father and son. B. With Lauren: 1 . One weekend per month with Father from Friday afternoon following the adjournment of school at approximately 3:00 p.m. until Monday morning at 8:00 a.m. 2. One other weekend per month, generally on an alternating weekend basis, from Saturday at 3:00 p.m. until Sunday at 1 :00 p.m. 3. During both weeks following Father's noncustodial weekends, one midweek visit with one or both children from 5:30 p.m. until 3 !-tl'~1F" , ( 4. '" , . " 7:30 p.m. on either Tuesday, Wednesday or Thursday night, depending on the children's schedules. Thanksgiving day will be divided into two segments; the first segment from 10:00 a.m. until 3:00 p.m.; the second segment from 3:00 p.m. until 8:00 p.m. Father shall have the first segment in 2000 and the segments shall be reversed and alternated annually. 5. Christmas Vacation will be divided into two se~~7.n!.s.; the Ll/ first segment frorl} December 24 at ~'12htil ty' _ Christmas Day at.~:OO p.m.; the second segment from .PAtJ Christmas Day at ioo p.m. uotiJthe~1 start of Fat:l'er's ~. Father shall have th~ first segment in ~~~~r 26th. 2000; Mother shall the second segment In 2000 and the segments shall be reveresed and alternated annually. 6. Easter Sunday, Labor Day, Memorial Day, President's Day, !y Veteran's Day and the Fourth of July from 9:00 a.m. until 9:00 p.m. shall be rotated and alternated by the parties, ./1;0 with Father to have Memorial Dav in 2000. New Yecu;'s Eve from 5:0D"'P.m. lmtil 4:00 p.m. on New Year's Day, with Father to have New Year's Eve in the year 2001 and in all odd number years thereafter. Father's Day weekend from Friday at 6:00 p.m. until Sunday at 6:00 p.m. with Father every year. 7. 8. Each parent shall have physical custody of the children for attendance at family funerals, near death situations and at weddings with reasonable notice to the other parent. 9. Up to Fourteen (14) days vacation annually upon thirty (30) days prior notice to Mother. III. TRANSPORTATION Father will provide all transportation necessary to exercise his partial physical custody under this agreement. IV. TELEPHONE PRIVILEGES The parties agree that there shall be reasonable telephone access between the children and both parents. The parents are encouraged to place telephone calls to the j"JmJ" 4 , ,.- '. children between 7:00 p.m. and " 0:00 p.m. so as not to interfere with dinner or bedtime. The child shall be permitted free access to place calls to her parents at any time she desires. V. RELOCATION The parties have negotiated the custody and partial custody portions of this Agreement based upon existing circumstances, and in particular, based upon Wife's and Husband's current residences in Cumberland County, Pennsylvania. If either parent desires to establish a residence more than twenty-five (25) miles from his or her present residence, he or she shall give the other parent at least sixty (60) days written notice in advance of the proposed move, in order to give the parties the opportunity to confer, prior to the relocation, and to establish a mutually satisfactory arrangement as to custody and partial custody in light of the changed circumstances. In the event that the parties are unable to reach an agreement, then the Court of Common Pleas of Cumberland County shall have jurisdiction over them to fashion an appropriate hall be entered as an Order of the Court. Edward J. Weintraub, Esquire Attorney for Plaintiff , ~ lUlu / Ie Debbie I. Delorenzo ~LJ.~ Keirsten W. Davidson, Esquire Attorney for Defendant BY THE COURT: J. Date: 5 , ,. II ~~ ,. - MHiJ'~; .... '-f . 0 C> 0 c: C> -n -:?:' ::;; '-\ -jJC~~' :r;# ;1:31. rilpl -< i_~~ Z:.Ti ~f~: \ <..r. :-D 0' <C] -0 Cc.1! .-J".... J..:;C) ~ ()~ bel fS5 ?"'c_ J;:.- c:. 0' ~ 0 ~ -< I''':> '< :~inh~~w~o_ ~_.=, ~l: MAl 03~ PETER A. DELORENZO, Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : vs. : NO. 00-1947 CIVIL TERM : . . CIVIL ACTION - LAW DEBBIE I. DELORENZO, Defendant : : IN CUSTODY ORDER OF <XX.IRT AND NCM, this 4th day of May, 2000, the Conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction in this case. The CUstody Conciliation Conference scheduled for May 9, 2000 is canceled. FOR THE COURT, ~, Dawn . Sunday, Esquire CUstody Conciliator "~~ . , , "p " " _.!!'!"""l~ ~- "p" 0 0 ~ c 0 s:: ::1l: ,-{ -;;lGJ ;pp :r: rn rT1 -< n'1~ z::n ~g~ zs: U) " ,,:) ,<2: !:=C: -0 ~:r4 'Pc:- :It 2~ z~ "~(-I 'f! 9 PC: :z: ':11 :>>' ::;:l 00 ~ 9 ."'"",,,,_0 ""_",~~mllfi~,"",, _..~I_ ~ o.~__f'lY8!tNrlOft.....-,f">"!' rL,~~! PETER A. DELORENZO, * IN THE COURT OF COMMON PLEAS Plaintiff, * CUMBERLAND,PENNSYL VANIA * VS. * NO. 00- (Ql.f7 * DEBBIE I. DELORENZO, * CIVIL ACTION - LAW Defendant. * CUSTODY CERTIFICATE OF SERVICE I, Misty D. Lehman, Legal Assistant to Edward J. Weintraub, Esquire, hereby certify that on May 11, 2000 I served a true and correct copy of a Order of Court and Stipulation for Agreed Order of Custody filed on May 10, 2000 upon Keirsten Davidson, Esquire, counsel for Defendant, by depositing same, postage pre-paid, in the United States Mail, Harrisburg, Pennsylvania, addressed as follows: Keirsten Davidson, Esquire 301 Market Street P.O. Box 109 Lemoyne, Pa 17043 Date: S -{I-W LfYUOa~ Misty D. ~timan /b. ~. , ~,' -,."..,~ - 0 <::) 0 C C"..) 'T1 5: Z ::J -00:-' c'c:ll' "~~'~' illrn ........,.; Z7J ..- ~l~~: ['"j '::;'~t~ ~~l -0 ~?j :Ii :1~~ -'~ ;'"'0 ~ ;:;;) j:;C": '=-i :;,..::: \'V 55 :.~ '< - ~"~~ ,~"~ m~"""",..."jlt'l!Il,,,,,=,=-...,.~Il!!!fI."""_~'.''''~''''''''''''''~~~""1''......,~.~~Il!! Barbara Sump1e-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 PETER A. DeLORENZO, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-1947 DEBBIE 1. DeLORENZO, Defendant CIVIL ACTION - LAW CUSTODY PRAECIPE TO WITHDRAW APPEARANCE Please withdraw my appearance on behalf of DEBBIE 1. DeLORENZO in the above- captioned matter. Respectfully submitted, Dated:O".tdoev-1 , 2001 ~w,fl Keirsten Davidson, Esquire JOHNSON, DUFFIE STEWART & WEIDNER 30 I Market Street Lemoyne, P A 17043 (717) 975-5500 Supreme Court 1.D. f)rJ{3 PRAECIPE TO ENTER APPEARANCE Please enter my appearance on behalf of DEBBIE 1. DELORENZO in the above-captioned matter. Dated: /6 - J ,2001 Barbara umple-Sullivan, Esquire 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 Supreme Court 1.D. 32317 I' ~ " ~, .-. ,-.'0-.,.-'- :;':" Barbara Sump Ie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 PETER A. DeLORENZO, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-1947 DEBBIE 1. DeLORENZO, Defendant CIVIL ACTION - LAW CUSTODY CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served the foregoing Praecipe to Withdraw Appearance and Praecipe to Enter Appearallce, in the above- captioned matter upon the following individual by first class mail, postage prepaid, addressed as follows: Edward 1. Weintraub, Esquire 2650 North Third Street Harrisburg, PA 17110 Keirsten Davidson, Esquire JOHNSON, DUFFIE, STEWART & WEIDNER 301 Market Street Lemoyne, P A 17043 Dated: October 11,2001 rbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 Supreme Court 1.D. 32317 - ~ , '--,"'-., ";'."'''''''''' >_t;.~,,"-.-.- , ~ ,~- "- . L~", > '~'-'T\~~'T;"'" - ~,' ~ -~,- - --,-_. ,-'-, ,'- --' " '-"'--""""'c'''''-'->' - -,-, 1-- ".'1.. ,: ,~-, 0 0 0 ~ - -on s.- O --:-\ ri\~ ('"') "~;}? ..... 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