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HomeMy WebLinkAbout07-0679Anthony T. McBeth, Esquire 407 North Front Street Harrisburg, PA 17101 (717) 238-3686 Attorney for Plaintiff SANDRA CADO, : IN THE COURT O COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA . V. :NO. O'7 - to 79 JEROME J. RAHM, II, Defendant CIVIL ACTION - LAW CUSTODY COMPLAINT FOR CUSTODY, PARTIAL CUSTODY OR VISITATION 1. The Plaintiff is Sandra Cado, residing at 600 Cumberland Pointe Circle, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant is Jerome J. Rahm, 11, residing at 82 Linda Drive, Lot #19, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Plaintiffs seek custody of the following children: Name Present Residence Age Toriana Rahm 600 Cumberland Pointe Circle 5 Years Mechanicsburg, PA 17055 The child was born out of wedlock. The child is presently in the custody of Sandra Cado, whose current address is 600 Cumberland Pointe Circle, Mechanicsburg, Pennsylvania, 17055. During the past five years, the child has resided with the following persons and at the following addresses: Persons Addresses Dates Sandra Cado 600 Cumberland Pointe Circle 7/06 to Mechanicsburg, PA 17055 Present Sandra Cado and 82 Linda Drive, Lot #19 9/01 to Jerome J. Rahm, 11 Mechanicsburg, PA 17050 6/06 The mother of the child is Sandra Cado, currently residing at 600 Cumberland Pointe Circle, Mechanicsburg, Cumberland County, Pennsylvania, 17055. She is not married. The father of the child is Jerome J. Rahm, 11, residing at 82 Linda Drive, #19, Mechanicsburg, Cumberland County, Pennsylvania, 17050. He is not married. 4. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently resides with the following persons: Name Toriana Rahm Derion Cado Relationship Daughter Son 5. The relationship of Defendant is that of father. The Defendant currently resides with the following persons: Name Relationship Unknown 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 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 child would be served by granting the relief requested herein because, the mother has always been the child's 2 primary caretaker and the father is not capable of that responsibility. 8. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child has 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 child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim None WHEREFORE, Plaintiff request the Court to grant custody, and legal custody of the child as the Court deems appropriate. I e1?40 Date Attorney for a7l 407North F t., First Floor Harrisburg, 01 (717) 238-3686 Supreme Court I.D. # 53729 3 VERIFICATION I, Sandra Cado, Plaintiff in the foregoing action, verify that the facts set forth in the attached document are true and correct to the best of my knowledge, information and belief. I so state subject to the penalties of 18 Pa. C. S. §4904 (relating to unsworn falsification to authorities). FEBRUARY 1, 2007 v Date andra Cado O b ? P C:;7 C1I .?i i { N SANDRA CADO IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JEROME J. RAHM, II DEFENDANT 07-679 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, February 12, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor, Cumberland Coun Courthouse, Carlisle on Friday, March 02, 2007 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gglro Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 b`N"VA ASW43d I Z M Wd Z 193J LOOT AdVi JNiJHin, ad 3H,! 30 301:44-0311 /o•el.0 AFFIDAVIT OF SERVICE NO O '/ ` / S ? KAREN L. GREEN E . CA STATE G ? ? 1 4201 Catalina Lane Carl1 c COUNTY r Harrisburg, PA 17109 COURT z (? Q? (717) 545-3479 (717) 503-7464 Plantiff Vs. VAJ Defendant I.- ?04 Cal I being duly sworn, depose and say that on the day of a , 2007 executed sere ce by delivering a true copy of the `? in accordance with the state statutes in the manner. rte,,` l;a?? d? N INDIVIDUAL SERVICE: served the within named person. SUBSTITUTE SERVICE: By serving as POSTED SERVICE: after attempting service on at and at to a conspicuous place on the property described herein. OTHER SERVICE: as described in the comments below by serving as NON-SERVICE: for the reason detailed in the comments below. Comments I certify that I have no interest in the above action, am of legal age and have proper authority in the jurisdiction in which this service was made. j? Sworn to and Subscribed before me an the A'f day ?aAJ, ZOCJby the *ocesser, Affiant who is personally known to me. No ry Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Karen L. Green, Notary Public CCi of Harrisburg, Dauphin Cour?tY Commission Expires Feb. 21, 2 Member, Pennsyivani.Asscvciation of Notaries . :. Q°. MAR 22 WKr SANDRA CADO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW JEROME J. RAHM, II, NO. 07-679 Defendant IN CUSTODY COURT ORDER AND NOW, this z`' day of March, 2007, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The mother, Sandra Cado, and the father, Jerome J. Rahm, II, shall enjoy shared legal custody of Toriana J. L. Rahm, born September 12, 2001. 2. The mother shall enjoy primary physical custody of the minor child. 3. The father shall enjoy periods of temporary physical custody of the minor child at such times and under such circumstances as agreed to by the parties. 4. In the event father desires to have a more specific schedule of visitation set in this case, father may Petition the Court to have the case again scheduled with the Custody Conciliator for a Conference. cc: horsy T. McBeth, Esquire r. Jerome J. Rahm, II A F:\FILES\DATAFILE\Generai\Current\12321\12321 Cado v Cado Conciliation Report-Order BY THE COURT. / V,Sol . SANDRA CADO, Plaintiff v JEROME J. RAHM, II, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-679 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Toriana J. L. Rahm, born September 12, 2001. 2. A Conciliation Conference was held on March 16, 2007, with the following individuals in attendance: The mother, Sandra Cado, with her counsel, Anthony T. McBeth, Esquire, and the father, Jerome J. Rahm, II, who appeared without counsel. 3. The parties agree to the entry of an Order in the form as attached. DATE: March 21, 2007 Z2??? Hubert X. Gilroy, Esquire Custody Conciliator 4 PETITION TO MODIFY CUSTODY ORDER 1. The Defendant/Petitioner is Jerome J. Rahm, II, THOMAS D. GOULD, ESQUIRE 2 EAST MAIN STREET SHIREMANSTOWN, PA 17011 (717) 731-1461 SANDRA CADO, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA U-75 NO. 2007-0{9q CIVIL TERM CIVIL ACTION - LAW CUSTODY ACTION V. JEROME J. RAHM, II, Defendant hereinafter referred to as Father, residing at 82 Linda Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Plaintiff/Respondent is Sandra Cado, hereinafter referred to as Mother, residing at 600 Cumberland Pointe, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Father and Mother are the biological parents of Torianna J.L. Rahm, born September 12, 2001. 4. Father seeks to Modify the Order dated March 26, 2007, by continuing to share joint legal custody and increasing his shared physical custody time with Torianna 5. Father is requesting a regular, consistent parenting schedule maximizing each parents' time with their child, including but not limited to more overnights, weekends and days related to holidays, and to be an integral part of decisions related to 4 Torianna's health education and general welfare, to be informed by Mother of significant events in Torianna's life and to be allowed to claim Torianna as a dependent and his childcare expenses for which Father is paying the majority of support and expenses. . 6. Torianna's best interest will be served if Father's requests are granted because: A. Father will place the interest of Torianna before his own. B. Father has the ability and desire to be a more active parent in Torianna's life. C. Father can provide a stable and consistent environment for Torianna's life. D. A more equal sharing of the parenting responsibilities of Torianna will more equitably distribute the benefits each parent can give and Torianna can receive. WHEREFORE, Father requests that this honorable court grant him joint legal and regular increased periods of physical custody of Torianna and a providing that Father may claim Torianna as a dependant for his tax returns with a credit for childcare expenses. Respectfully submitted, Thomas D. Gould, Esquire ID #36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 • VERIFICATION I, Jerome J. Rahm, II, hereby certify that the foregoing PETITION TO MODIFY CUSTODY ORDER is true and correct to the best of my knowledge, information and belief. 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. -7Q OS1 DATED: Jerome JJ. Rahm, II 3 i 1 gn{?,ZR C a Tnl rtn? cau?r e r Ca.r?,on PLE7,4J a r m -Ld•" j)_ .-C-Pa nTy, , P.??Ys/4v4'V14 . E v CIVIL ACTION - LAVE Ain ? ?ME J. Itt111M, Ii, NO. 07-679 j Defendant IN CUSTODY r? COURT ORDER jA I' VOW, this !I-A day of March, 2007, upon consideration of the attached Custody C. no l liation report, it is ordered and directed as follows: 1 Z Ile mother, Sandra Cado, and the father, Jerome J. Rahm, TI, shall enjoy shared legal ? e istody of Toriana J. L. Rahm, burn September 12, 2001. f 2. ( ie mother shall enjoy primary physical custody of the mirror child. l t 3.1 T I e father shall enjoy periods of temporary physical custody of the minor child at suet, to rtes and under such circumstances as agreed to by the parties. 4.: lit ; the event father desires to have a more specific schedule of visitation set in this case, Oft iher may 'petition the Court to have the case again scheduled with the Custody C" lbeiliator for a Conference. BY THE OUR!', Judge eea ?1, i thony T. McBeth, Esquire -N. i. Jerome J. Rahm,11 f •J klji?iJ). I.?FtLe?CacraF.S'w'7wu`IJ+tVi_s_t Vann v r,y? conciliation Kc{nnt Unier In TRUE C^Py F?V%hA RECORD 'eat{mcrnr -;t my hand 7_ n. car '? I r? SANDRA CADO IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA. V. JEROME J. RAHM, II DEFENDANT 2007-679 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, July 22, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, August 08, 2008 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 f yy 3 ?'". kr f ?f..I ?.S..'V i_ ? ..ir ?.? r?4W H ?,.,, . _ 1? i?? F AUG 7 8 2008 SANDRA CADO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW JEROME J. RAHM, II, NO. 2007-679 Defendant IN CUSTODY COURT ORDER AND NOW, this cVjdt day of August, 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Courtroom No. 4 of the Cumberland County Courthouse on the a- day of 2008, at 9•3d . m. At this hearing, the Father shall be the moving party and shall proceed initially with testimony. Counsel for the parties, or the parties themselves if they do not have counsel, shall file with the Court and the other parties/counsel a Memorandum setting forth the history of custody in this case, the issues currently before the Court, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This Memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, this Court's prior Order of March 26, 2007, shall remain in place subject to the following provisions: A. Father shall enjoy custody of the minor child on three out of four weekends with the weekend of not having custody being the weekend he is working on Saturday. Custody shall be from Friday at 5:30 p.m. thru Monday morning when he shall return the child to Mother or take the child to school. N -s WV ZZ snv OCR nevi, " ,.`: -lHl K) 4L B. Father shall also have custody at such other times as agreed. BY THE COURT, Kevin A.p6ss, Judge cc: A homas D. Gould, Esquire ?W Sandra Cado V 04, SANDRA CADO, Plaintiff vs. JEROME J. RAHM, II, Defendant Prior Judge: The Honorable Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007-679 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE 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 child who is the subject of this litigation is as follows: Torianna J. L. Rahm, born September 12, 2001 2. A Conciliation Conference was held on August 8, 2008, with the following individuals in attendance: The father, Jerome J. Rahm, II, who appeared with his counse_l Thomas D. Gould, and the mother, Sandra Cado, who appeared without counsel. 3. There is a prior custody Order giving the Mother primary custody. Father believes there are some issues and he is seeking primary custody or, in the alternative, some type of 50-50 arrangement. Mother is not willing to agree to a transfer of primary custody to Father and a hearing is required. 4. The Conciliator recommends an Order in the form as attached. J? Date: August le , 2008 Hubert X. Milroy, Esquire Custody onciliator SANDRA CADO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW JEROME J. RAHM, II, NO. 07-679 CIVIL Defendant ORDER AND NOW, this Z-/* day of November, 2008, at the request of counsel for the parties, hearing in the above-captioned matter set for November 26, 2008, is continued to Wednesday, January 14, 2009, at 9:30 a.m, in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. BY THE COURT, " Anthony T. McBeth, Esquire For the Plaintiff VThomas D. Gould, Esquire For the Defendant rlm ?o «<<eCL -. 4,4-k Hess, J. ? ? ac' - ?'" ? :, , ? r '': " _ . ?,;_ : f ??;- ?' w? t, ° __., c` 2 '? ?;_ , ???? :? ? ? ?''? ?.. C i ?.? ? c : JAN 16 2009&, SANDRA CADO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : 6 74 V. : NO. 2007-069T-Civil Term JEROME J. RAHM, II, Defendant CIVIL ACTION - LAW CHILD CUSTODY ORDER AND NOW, this 2 i c day of January, 2009, upon consideration of the Motion of Anthony T. McBeth, Esquire for the Entry of Order Pursuant to the Parties' Stipulation, and the record showing that the Parties have stipulated in writing to what they believe to be the custody arrangement that would be in the best interest of and promote the permanent welfare of the child, Toriana J. L. Rahm (born September 12, 2001), the Court hereby adopts the Parties' Stipulation as an Order, and accordingly, orders as follows: 1. The prior Orders of this Court dated March 26, 2007 and August 21, 2008 shall be vacated and replaced with this Order. 2. The Mother, Sandra Cado, and the Father, Jerome J. Rahm, II, shall share having legal custody of Toriana J. L, Rahm, born September 12, 2001. Major decisions concerning the Child, including but not necessarily limited to, her health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a viewtoward obtaining and following a harmonious policy in the Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the Child. Neither Party shall attempt to alienate the affections of the Child from the other party. Each party shall notify the other of any activity or circumstance concerning the Child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. 3. The parties shall have physical custody of the child as follows: A. School Year: 1. During the school year, the Father shall have custody of the Child on three (3) out of every four (4) weekends from Friday after work, between 5:00 p.m. and 5:30 p.m.,through Sunday at 7:00 p.m. The fourth (4th) weekend, which shall be the Mother's weekend period of custody, shall be scheduled to coincide with the weekend on which the Father has to work. 2. During every week, the Father shall have custody of the Child on Wednesdays and Thursdays from after work, between 5:00 p.m. and 5:30 p.m. until 7:15 p.m. The Father shall ensure that the Child has completed her homework during his period of weekday evening custody. The Father's period of weekday evening custody may be expanded to overnight if agreed between the parties. B. Summer School Break: 1. During the summer school break each year, the parties shall share having custody of the Child on an alternating weekly basis, with the exchange to take place every week on Monday at 5:30 p.m. Unless otherwise agreed between the parties, the summer custody schedule shall begin on the first Monday following the end of the school year with the Father having custody of the Child. Unless otherwise agreed between the parties, the summer custody schedule shall end each year at least one week prior to the first day of school, with the Mother having custody of the Child. C. Afterfollowing the summer custody schedule for at least one (1) month in 2009, the parties shall cooperate in assessing whether a more shared custody schedule during the school year would be in the Child's best interests in light of the experience on the alternating weekly schedule. The parties agree to initiate discussions concerning possible adjustments to the school year schedule in sufficient time to have the issue resolved prior to the beginning of the 2009-2010 school year. 4. The parties shall share having custody of the Child on holidays as follows: A. Christmas: The Christmas holiday shall be divided in to Segment A, which shall include all of Christmas Eve day through Christmas Eve in the evening, and Segment B, which shall run from Christmas Eve in the evening through Christmas Day. In even- numbered years, the Mother shall have custody of the Child during Segment A and the Father shall have custody of the Child during Segment B. In odd-numbered years, the Father shall have custody of the Child during Segment A and the Mother shall have custody during Segment B. The specific time for exchanges of custody shall be arranged by agreement between the parties. B. Thanksgiving: In even-numbered years, the Mother shall have custody of the Child for Thanksgiving Day and in odd-numbered years, the Father shall have custody of the Child for Thanksgiving Day, with the specific times for exchanges to be arranged by agreement between the parties. C. Mother's Day/ Father's Day: In every year, the Mother shall have custody of the Child for Mother's Day and the Father shall have custody of the Child for Father's Day, with the specific times for exchanges of custody to be arranged by agreement between the parties. D. The holiday custody schedule shall take precedence over the regular custody schedule. 5. Each party shall be entitled to have vacation custody with the Child each year, which shall be scheduled during the his or her alternating weeks of custody unless otherwise arranged by agreement. 6. Unless otherwise agreed between the parties, the parent receiving the custody of the Child shall be responsible to provide transportation for the exchange of custody. 7. Both parents shall promptly ensure that the other parent has all medical/dental insurance coverage information, cards or copies thereof or any other essential information pertaining to the Child's insurance coverage. It is further ORDERED that the parties shall cooperate in obtaining and sharing medical/dental information concerning the Child's care and treatment. Each party shall notify the other on the same day that he or she makes a medical or dental appointment for the Child. BY THE COURT: Kevin X. Hess, Judge Distribution: ,,Anthony T. McBeth, Esq. 407 North Front Street, Harrisburg, PA 17101 , Xhomas D. Gould, Esquire, 2 East Main Street, Shiremanstown, PA 17011 j c n ?? o c-s v: 'I C?? `J LY C" (17 T C, ;!J/r,,OTiRY 2010 APR - I Ali 8: 4 4 N'Ty LAW OFFICES OF DILS & DILS DIANE M. DILS, ESQUIRE Attorney I.D. No. 71873 1400 North Second Street, First Floor, Front Harrisburg, PA 17102 Telephone No. (717) 232-9724 Attorney for Defendant, Jerome J. Rahm, II SANDRA CADO Plaintiff vs. JEROME J. RAHM, II Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 2007-0679 CIVIL TERM : CIVIL ACTION -LAW : IN CUSTODY PRAECIPE Please withdraw and terminate the above-captioned custody matter on behalf of the above-named parties. Respectfully submitted, BY: - '41 Dickinson Sc of Law Family Law Clinic Dale F. Shughart Community Law Center 45 North Pitt Street Carlisle, PA 17013 Attorney for (X) Plaintiff ( ) Defendant Sandra Cado Respe lly submitted BY ? ZVI Diane A Dils, squire 1400 North Second Street First Floor, Front Harrisburg, PA 17102 (717) 232-9724 Attorney for ( ) Plaintiff (X) Defendant Jerome J. Rahm, II Date: ?.S" Q