HomeMy WebLinkAbout97-02170
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IN THB COURT or COMMON PLEAS rOR
CUMBBRLAND COUNTY, PBNNSYLVANIA
JOY A. SINOBR, I CIVIL ACTION - LAN
PLAINTIrr/PBTITIONER I
I 1. I -to
V. I NO. 97- CIVIL TBRM
I
LONNIB R. CORLE, I
DEFENDANT/RESPONDENT I CUSTODY
4'"
AND NON, this ~oJ
day of
, 1997, upon
ORDER OF
consideration of the attached Petition for Special Relief, it is
hereby ORDERED that plaintiff/petitioner, JOY A. SINGER sh~ll have
primary physical custody of the child, DAVID A. CORLE, DOB October
29, 1996, pending further order of court. Defendant/Respondent
shall exercise partial custody of the child from Friday evening to
sunday evening each week, commencing Friday, May 2, 1997.
Respondent may seek a hearing prior to conciliation if he
wishes to challenge this order.
J.
IN THB COURT OF COMMON PLEAS FOR
CUMBBRLAND COUNTY, PBNNSYLVANIA
JOY A. SINGER, I CIVIL ACTION . LAW
PLAINTIFF/PBTITIONBR I
I
V. I NO. 97- CIVIL TBRM
I
LONNIB R. CORLE, I
DEFENDANT/RBSPONDENT I CUSTODY
ORDBR OF COURT
AND NOW, this
day of
, 1997, in
consideration of the Petition for special Relief filed by the
plaintiff/Petitioner, JOY A. SINGER, it is hereby ordered and
decreed that a rule is issued upon the Defendant/Respondent, LONNIE
R. CORLE, to show cause why primary custody should not be awarded
to Plaintiff/petitioner pending a conciliation conference, subject
to partial custody by Defendant/Respondent on weekends.
THIS RULE SHALL BE RETURNABLE with counsel only, or Defendant/
Respondent if unrepresented, in chambers on
1997 at .M.
Pending said conference, temporary custody of DAVID A. CORLE,
date of birth 10/29/96, is hereby awarded to Petitioner, JOY A.
SINGER.
BY THE COURT:
J.
IN THB COURT OF COMMON PLEAS FOR
CUMBBRLAND COUNTY, PENNSYLVANIA
JOY A. SINGBR, I CIVIL ACTION - LAW
PLAINTIFF/PBTITIONBR I
I
V. 1 NO. 97- CIVIL TBRM
I
LONNIB R. CORLB, I
DBFENDANT/RESPONDENT I CUSTODY
PBTITION FOR SPBCIAL RBLIBr
AND NOW COMBS the plaintiff/Petitioner, JOY A. SINGER and
files this Petition for Special Relief pursuant to Pa.R.C.P.
1915.13, averring the following:
1. plaintiff/Petitioner is JOY A. SINGER, of 16 Deadend Lane,
Shippensburg, Cumberland County, Pennsylvania.
2. Defendant/Respondent is LONNIE R. CORLE, of 310 Walnut Dale
Road, Shippensburg, Cumberland County, Pennsylvania.
3. The parties are the natural parents of a minor child, DAVID A.
CORLE, DOB October 29, 1996.
4. Since birth, the child has been in the primary cust;'dy of
Plaintiff/Petitioner.
5. Defendant/Respondent saw the child twice during the first two
months following the birth of the child.
6. From approximately January 1, 1997 to the present, the partieo
have followed a schedule whereby plaintiff/petHioner has exercised
primary custody of the child, while Defendant/Respondent has
exercised partial custody of the child on weekends.
7. On or about Sunday, April 20, 1997, Defendant/Respondent refused
to return the child to Plaintiff/Petitioner following a weekend
where he exercised partial custody.
8. On Monday, April 21, 1997, plaintiff/petitioner contacted the
undersigned attorney for purposes of having the child returned to
her custody.
9. plaintiff/Petitioner learned that Defendant/Respondent attempted
to transfer the child's medical records, all without her knowledge
and consent.
10. On April 23, 1997, plaintiff/Petitioner retrieved the child
from Defendant/Respondent's mother, who was babysitting the child
at her place of employment.
11. plaintiff/Petitioner has present custody of the child.
12. On Friday, April 25, 1997, Defendant/Respondent threatened to
take the child again.
13. A Complaint for Custody has been filed by plaintiff/Petitioner
simultaneously with this Petition. A copy of said Complaint is
attached hereto and labeled as Exhibit "A".
14. It is anticipated that a Conciliation Conference will not take
place for approximately 1 month.
15. Defendant/Respondent is not represented by Counsel, to the best
knowledge of Petitioner and her undersigned attorney.
WHEREFORE, Plaintiff/Petitioner respectfully request that
your Honorable Court enter a temporary Order granting primary
custody of the child to her pending further order of court, subject
to partial custody for Defendant/Respondent.
Respectfully submitted,
.7'V/l"""l.. (1/
Richard L. west;er, ~r.
Attorney for Plaintiff/
Petitioner
366 Green Spring Road
P.O. Box 40
Newville, PA 17241-0040
(717) 776-6566
"
I verify that the statements made in this Petition are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 pa.C.S.A. Section 4904 relating to
unsworn falsification to authorities.
Date: (~:fh ~"" \CB:3..-
~ 0
o "
JO 'GINGE~~tiff/
Petitioner
"
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IN THB COURT OF COMMON PLBAS FOR
CUMBBRLAND COUNTY, PBNNSYLVANIA
JOY A. SINGBR, I CIVIL ACTION - LAW
PLAINTIFF I
I
V. I NO. 97- CIVIL TBRM
I
LONNIB R. CORLB, I
DBFENDANT I CUSTODY
ORDER OF COURT
AND NOW, , 1997 upon consideration of
the attached complaint, it is hereby directed that the parties and
their respective counsel appear before
, the conciliator, at
on the
,
1997, at .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. 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.
day of
FOR THB COURT,
Custody Conciliator
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.
BY,
YOU SHOULD TAJtB THIS PAPBR TO YOUR LAWYER AT ONCB. IF YOU DO
NOT HAVB A LAWYBR OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THB
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Office of the Court Administrator
Courthouse, 4th Floor
Carlisle, PA 17013
Telephone (717) 240-6200
Exhibit "A-I"
IN THE COURT OF COMMON PLEAS FOR
CUMBERLAND COUNTY, PENNSYLVANIA
JOY A. SINGER, I CIVIL ACTION - LAW
PLAINTIFF I
I
V. I NO. 97- CIVIL TERM
I
LONNIE R. CORLE, I
DEFENDANT I CUSTODY
COMPLAINT FOR CUSTODY
1. The Plaintiff is Joy A. Singer, residing at 16 Deadend Lane,
Shippensburg, Cumberland County, PA.
2. The Defendant is Lonnie R. Corle, residing at 310 Walnut Dale
Road, Shippensburg, Cumberland County, PA.
3. Plaintiff seeks custody of the following child:
~
Present Residence
~
David A. Corle
16 Deadend Lane
Shippensburg, PA 17257
6 months
(DOB 10/29/96)
The child was born out of wedlock.
The child, David A. Corle is presently in the custody of Joy A.
Singer who resides at 16 Deadend Lane, Shippensburg, PA 17257.
During the past five years the child has resided with the
following persons and at the following addresses:
NMle.
List all Addresses
Dates
Joy A. Singer
16 Deadend Lane
Shippensburg, PA 17257
(DOB) 10/29/96
to present
The mother of the child is Joy A. Singer, currently residing at
16 Deadend Lane, Shippensburg, PA 17257.
She is married to Ronald Singer, Jr. but separated.
Exhibit "TI-2"
.~
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The father of the child is Lonnie R. Corle, currently residing
at 310 walnut Dale Road, Shippensburg, PA 17257.
He is single.
, .
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4. The relationship of Plaintiff to the child is that of natural
mother.
The Plaintiff currently resides with the following persons:
~
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NmIW
Relationshio
brother
William Heberlig
James E. Forest
uncle
5. The relationship of Defendant to the child is that of natural
father.
The Defendant currently resides with the following persons:
timne.
Relationshio
Rolla Corle and Nancy Corle
parents
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 does not have information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
Plaintiff is not aware of a person not a party to the
proceedings who has physical custody of the child and claims to
have custody or visitation rights with respect to the child.
7. The best interest and permanent welfare of the child will be
served by granting the relief request because:
a. Plaintiff is better able to care for the physical,
emotional, educational and medical needs of the
child;
b. Plaintiff has been the primary caretaker of the child
since birth; and
c. Shortly after the birth of the child, Defenaant exhibited
a lack of interest in the child and furthermore signed
documentation consenting to the adoption of the child.
Exhibit "A-3"
B. Each parent who parental rights to the child have not been
terminated and the person who has physical custody of the
child has been named as parties to this action.
WHEREFORE, Plaintiff requests the court to grant custody of the
child to her, subject to reasonable partial custody rights for
Defendant.
-rV /1.~/l-1
Richard L. Webber, Jr.
Attorney for Plaintiff
366 Green Spring Road
P.O. Box 40
Newville, PA 17241-0040
(717) 776-6566
Exhibit "A-II"
I verify that the statements made in this Complaint are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to
unsworn falsification to authorities.
Date:~\pt) \cp,,,:\
~(,>,f:-';~
J Singer
Pla ntHf
Exhibit "A-5"
IN THB COURT OF COMMON PLEAS FOR
CUMBBRLAND COUNTY, PBNNSYLVANIA
JOY A. SINGER, . CIVIL ACTION - LAW
PLAINTIFF I
. NO. g'7-J...I7L)
V. . CIVIL TERM
.
LOrmIE R. CORLE, .
DEFENDANT . CUSTODY
ORDER or COURT
c- J ,-,
AND NOW,-> 6 , 1997 upon consideration of
the attached complaint, it is hereby directed that the parties anti
their respective counsel appear before I \ hpr ~ Y... C, ,\ r Cl'J , E 'Sq .
, the conciliator, (~t 'I \' ['I. (,.,,\.,rnl (. (\,..." ri mr,r'rICI\('\ Cr/1'l~
('t,-,'\k:.0~~e- on the II day of ..LJI1t'" ,
1997, at 10 ',;0 n, .m., for a Pre-Hearing Custody
Conference. At such conference, an effort will be made to resolve
the j Rsues 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.
FOR THE COURT,
f~~~~~*c1i~~'
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.
BY.
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
Courthouse, 4th Floor
Carlisle, PA 17013
Telephone (717) 240-6200
F'I [n "c.',.
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IN THB COURT OP COMMON PLBAS POR
CUMBBRLAND COUNTY, PBNNSYLVANIA
JOY A. SINGBR, I CIVIL ACTION - LA"
PLAINTIFP I
I
V. I NO. 97- CIVIL TBRM
I
LONNIB R. CORLB, I
DBFBNDANT I CUSTODY
COMPLAINT FOR CUSTODY
1. The Plaintiff is Joy A. Singer, residing at 16 Deadend Lane,
Shippensburg, Cumberland County, PA,
2. The Defendant is Lonnie R. Corle, residing at 310 walnut Dale
Road, Shippensburg, Cumberland County, PA.
3. Plaintiff seeks custody of the following child:
~
2resent Residence
~
David A. Corle
16 Deadend Lane
Shippensburg, PA 17257
6 months
(DaB 10/29/96)
The child was born out of wedlock.
The child, David A. Corle is presently in the custody of Joy A.
Singer who resides at 16 Deadend Lane, Shippensburg, PA 17257.
During the past five years the child has resided with the
following persons and at the following addresses:
~
List all Addresses
Dates
Joy A. Singer
16 Deadend Lane
Shippensburg, PA 17257
(DaB) 10/29/96
to present
The mother of the child is Joy A. Singer, currently residing at
16 Deadend Lane, Shippensburg, PA 17257.
She is married to Ronald Singer, Jr. but separated.
The father of the child is Lonnie R. Corle, currently residing
at 310 walnut Dale Road, Shippensburg, PA 17257.
He is single.
4. The relationship of plaintiff to the child is that of natural
mother.
The Plaintiff currently resides with the following persons:
rwne.
RelatlonshiD
William Heberlig
brother
James E. Forest
uncle
5. The relationship of Defendant to the child is that of natural
father.
The Defendant currently resides with the following persons:
rwne.
RelationshiD
Rolla Corle and Nancy Corle
parents
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 does not have information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
Plaintiff is not aware of a person not a party to the
proceedings who has physical custody of the child and claims to
have custody or visitation rights with respect to the child.
7. The best interest and permanent welfare of the child will be
served by granting the relief request because:
a. Plaintiff is better able to care for the physical,
emotional, educational and medical needs of the
child;
b. Plaintiff has been the primary caretaker of the child
since birth; and
c. Shortly after the birth of the child, Defendant exhibited
a lack of interest in the child and furthermore signed
documentation consenting to the adoption of the child.
8. Each parent who parental rights to the child have not been
terminated and the person who has physical custody of the
child has been named as parties to this action.
WHBREFORB, Plaintiff requests the court to grant custody of the
child to her, subject to reasonable partial custody rights for
Defendant.
-2l ;/ /1 ,~~(-{
Richard L. Webber, Jr.
Attorney for Plaintiff
366 Green Spring Road
P.O. Box 40
Newville, PA 17241-0040
(717) 776-6566
I verify that the statements made in this Complaint are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to
unsworn falsification to authorities.
Date: 0QR\ P6 \0.0.':\
~~~
J Singer~
Pla ntiff
.1
P
IN THB COURT OF COMMON PLEAS FOR
CUMBBRLAND COUNTY, PBNNSYLVANIA
JOY A. SINGER,
PLAINTIFF
I
I
I
I
I
I
I
CIVIL ACTION - LAW
v.
NO. 97-2170 CIVIL TBRM
LONNIB R. CORLE,
DEFENDANT
IN CUSTODY
ORDBR OF COURT
AND NOW, this ~ day of June, 1997, upon consideration
of the verified Peti tion of Plaintiff's Counsel for Leave to
withdraw Appearance, it is hereby ORDERED that said petition is
GRANTED and that Petitioner, Richard L.Webber, Jr., Esquire, be
permitted to withd~aw his appearance of record for the plaintiff/
petitioner, Joy A. Singer in the above-captioned matter.
//
/ / .
\JJ;v/
l
J.
Richard L. Webber, Jr., Petitioner
Joy A. Singer, Plaintiff
James J. Kayer, Attorney fo~ Defendant
_ ~~tJ.. 1D/,,/9'l.
..JJ. fJ.
IN THE COURT OF COMMON PLEAS FOR
CUMBERLAND COUNTY, PENNSYLVANIA
JOY A. SINGER,
PLAINTIFF
I
I
I
I
I
I
I
CIVIL ACTION - LAW
V.
NO. 97-2170 CIVIL TERM
LONNIE R. CORLE,
DEFENDANT
IN CUSTODY
"
RULE TO SHOW CAUSE
AND NOW, this
day of June, 1997, upon
consideration of the attached Petition of Counsel for Leave to
withdraw Appearance, a Rule to Show Cause is issued upon Respondent
Joy A. Singer to show cause why Petitioner, Richard L. Webber, Jr.
should not be granted leave to withdraw his appearance as counsel
for Respondent.
THIS RULE RETURNABLE and a hearing is scheduled for
.m. in Courtroom
of the Cumberland County Court
House, Carlisle, Pennsylvania.
Service of this Rule to Show Cause shall be made upon
Respondent, Joy A. Singer, by certified mail, restricted delivery,
and upon the Defendant, Lonnie R. Corle, by regular mail to his
attorney, James J. Kayer, Esquire.
J.
Richard L. Webber, Jr., Petitioner
Joy A. Singer, Plaintiff
James J. Kayer, Attorney for Defendant
IN THE COURT OF COMMON PLEAS FOR
CUMBERLAND COUNTY, PENNSYLVANIA
JOY A. SINGER,
PLAINTIFF
I CIVIL ACTION - LAW
I
I
I NO. 97-2170 CIVIL TERM
I
I
I IN CUSTODY
V.
LONNIE R. CORLE,
DEFBNDANT
PETITION OF COUNSEL FOR LEAVE TO WITHDRAW APPEARANCE
AND NOW comes the petitioner, Richard L. Webber, Jr., Esquire
and files this motion to withdraw as counsel, pursuant to Pa.R.C.P.
No. 10l2(bl, averring the following:
1. Petitioner is Richard L. Webber, Jr., 366 Green Spring Road,
P.O. Box 40, Newville, PA 17241.
2. Respondent is Joy A. Singer, 16 Deadend Lane, Shippensburg,
PA 17257.
3. Petitioner is presently the attorney of record for
Respondent.
4. On or about April 21, 1997, Respondent contacted Petitioner
concerning an emergency custody situation that she was
experiencing involving her son, David A. Corle
5. Specifically, the Defendant, Lonnie R. Corle, took the child
from her possession and refused to return the child.
6. As a result, Petitioner met with Respondent on April 23, 1997.
7. At the meeting on April 23, 1997, Respondent indicated Lhat
she waD unable to pay a retainer but did verbally agree to pay
$ 50.00 per week, commencing April 25, 1997.
8. On April 25, 1997, Petitioner and Respondent met and executed
a Fee Agreement. A copy of said Agreement is attached hereto,
incorporated by reference herein and labeled as Exhibit "A".
9. Additionally, on April 25, 1997, Petitioner prepared and
filed a Petition for Special Relief and a Complaint in Custody.
10. On that same day, the Honorable Edgar B. Bayley entered an
Order of Court granting primary custody to the Respondent.
11. Respondent has not made any weekly payments to Petitioner as
required by the Agreement, nor has she reimbursed Petitioner for
some of the costs that he advanced.
12. Paragraph 6 of the fee letter states that Petitioner reserves
the right to terminate his representation for failure to pay on her
account.
13. For purposes of discussing his continued representation,
Petitioner has made telephone calls to Respondent on the following
dates and requested that she contact him immediately:
May 7
May 19
May 22
May 29
June 2
14. On May 12, 1997, Petitioner wrote a letter to Respondent
indicating that he would terminate his representation if he did not
receive the payments that were due. A copy of said letter is
attached hereto, incorporated by reference herein, and labeled as
Exhibit "B".
15. In spite of the telephone calls and letter mentioned in
Paragraph 13 and 14 above, Respondent failed to contact Petitioner.
16. On June 5, 1997, the undersigned Petitioner called Respondent
and spoke to her directly.
17. During the conversation, the undersigned stated his intention
to withdraw his representation unless a satisfactory resolution
concerning fees was reached. Respondent indicated that she needed
to "think about" a proposal. Respondent was informed that the
undersigned would file a Petition to Withdraw on Friday, June 6,
1997, if he did not hear from her by the end of the day on June 5.
Respondent acknowledged that she was aware of the requirement to
contact Petitioner by the end of that day.
18. There has been no further response by Respondent.
19. The Defendant, Lonnie R. Corle, is represented by James J.
Kayer, Esquire.
20. A Conciliation Conference is scheduled for June 19, 1997 at
10:30 A.M.
21. The undersigned was informed by both the Respondent and
Defendant's attorney that a verbal agreement concerning custody had
been reached.
---
RICHARD L. WEBBER, JR.
Attorney al Law
366 Green Spring Road
P.O. Box 40
Newville, PA 17241.0040
Telephone (717) 776-6566
FAX (717) 776-6086
April 25, 1997
Ms. Joy A. Singer
16 Deadend Lane
Shippensburg, PA 17257
FEE AGREEMENT
1. General
This Agreement confirms my representation of you with respect
to custody of your son, David. As your attorney, I am required by
pennsylvania law to enter into a written fee agreement with
you. It is always proper for you, as my client, to discuss fee
arrangements, progress in the matter, or the details of a
particular bill.
2. Fee
My fee will be charged at an hourly rate of $95.00 per hour,
which is my customary hourly rate. I will bill in increments of
not less than one-eighth (1/81 hour for each occasion that I work
on your file. Additionally, you will be responsible for any
expenses incurred with respect to the matter. In the event that I
forward any costs, you will reimburse me within 15 days.
The time charged includes, but is not limited to meeting with
you and court appearances, such activities as drafting and review-
ing pleadings and correspondence. telephone conversations and
conferences with you, the opposing counsel and other parties, time
spent with witnesses, legal research and preparation for court
proceedings. I will not bill for travel within Cumberland or
Franklin County.
Notary fees will be charged at $ 2.00 per notarization.
I will not bill for general overhead costs such as long-
distance telephone charges, copying, or routine postage costs.
These costs are included within the hourly rate.
f-L1. I ,4
2
During the course of my representation, I will take any action
that I consider to be in your best interest, unless directly
contrary to your instructions. Such actions include the services
previously listed as well as communications from opposing attorney
and the other party.
Bear in mind that you are paying me for my time spent in
assisting you. The results can not always be measured in a
quantified manner. By retaining me, you are telling me that you are
unable to handle your matter on your own and that you desire legal
assistance. I will certainly, however, attempt to minimize your
fees as best as possible while providing quality representation.
3. Retainer Fee
I will not request a retainer fee of $ 45.00 for the filing
fee.
4. Billina Statements
I will bill you at least one time per month. You are required
to pay $ 50.00 per week.
If you have any questions concerning any items on the bill or
disagree with a charge, notify me within 15 days of receipt of Lhe
statement. As time goes on, it is more difficult to resolve any
discrepancies or disagreements.
There will be a $ 20.00 fee for any checks written to me that
are dishonored, plus any bank fees.
5. Prompt PaYment of Fees Reauired
Failure to pay as agreed in a timely manner is treated
seriously. I, as well as many other business owners, have
encountered this problem. Given my present fee structure, I simply
cannot afford to maintain a law office if I am not paid for my
services. Failure to receive payments ultimately results in higher
fees for other clients, and I will simply not allow that to happen.
I cannot give priority to clients that do not pay. As a
result, delays for your case would be inevitable.
By signing this Fee Agreement, you are acknowledging that you
have the ability to pay me as agreed and that you intend to do so
throughout the course of my representation. If you later determine
that you cannot make payments when due, please contact me
immediately.
Termination of Reoresentation
I reserve the right to terminate my representation for failure
to pay on your account.
You have the right to terminate my services at any time, for
any reason. As stated above, I reserve the right to terminate my
representation upon your failure to pay our fees and reimbursable
expenses in a timely mannflr. I reserve the right to terminate the
relationship immediately in the event that cause exists under the
pennsyl vania Rules of Professional Conduct, which governo
attorneys.
I also reserve the right to terminate our relationship, for
any other reason, upon fifteen (151 days written notice to you.
In the event that the relationship is terminated, I reserve
the right to retain your file pending payment in full on your
balance. This includes any instance where you switch attorneyo.
If you desire a copy of any items in your file upon
termination of our representation, there is a charge of 10 cents
per copy.
If I initiate litigation to attempt to recover my fees, and if
it is determined that you are obligated to pay me, you shall also
be obligated to compensate me for my time spent in doing BO. The
compensation shall be paid at the same hourly rate as stated above.
7. Final
I appreciate your business and look forward to serving you.
While it is not possible for an attorney to guarantee results for
a legal matter, I certainly hope that this matter can be resolved
to your satisfaction and consistent with your legal rights.
The parties hereto intending to be legally bound, have signed
this Fee Agreement on the date(sl listed below.
ATTORNEY
Date:
/.-f(:Jc;.-/c, 7
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Richard L. Webber, Jt.
Date:~R\ 95 \~-=t
CLIENT
~tf ~o~~
Jo inger -
IN TH~ COURT OF COMMON PLEAS FOR
CUMBERLAND COUNTY, PENNSYLVANIA
JOY A. SINGER,
PLAINTIFF/PETITIONER
.
.
CIVIL ACTION - LAW
v.
NO. 97-2170
CIVIL TBRM
LONNIE R. CORLE,
DEFENDANT/RESPONDENT
CUSTODY
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA I
SS
COUNTY OF CUMBERLAND
Richard L. Webber, Jr., being duly sworn according t.o law,
deposes and says that he mailed the Complaint for custody 111 tlll./I
matter by certified, restricted mail, return receipt relJut1f1Lr,\,
addressee only, to the Defendant/ Respondent LONNIE R. COIH,I~, .1)(1
Walnut Dille Road, Shippensburg, Pennsylvania 17257 on May 19, I~J!I'I.
The return receipt signed by the Defendant/Respondent ia 03V I d"!I1(~{j
of delivery to him and is attached hereto as Bxhibit "A".
,
.} V ,A .,,~dv~1___._...
Richard L. Webber, Jrt:' AttlJt'nI!Y
for Plaintiff/Petitioner
366 Green Spring ROAd
P.O. Box 40
Newville, PA 17241
(7171 776-656r.
Sworn to andpubscribed before
me this /r'!!l day of
i}"d" , 1997.
9_.'''''/ l:::::;><'~:-#-
Notary p~
NoI"n,1 SlIol
.loaM r. Tr It. tIt,' ilY Public
NuwvllIll Uoro. ClJI\ll),III,HUI Coull1.,
My Commlf.slofl f~plrt',i ^lfU, n. !l1'JH
~nbL1f', Poflllsy~Jijl'~J k""CJ..J,lttWl flt t ict.\r\ltJ
IN THE COURT OF COMMON PLEAS FOR
CUMBERLAND COUNTY, PENNSYLVANIA
JOY A. SINGER,
PLAINTIFF/PETITIONER
CIVIL ACTION - LAW
.
.
v.
I
I
NO. 97-2170
LONNIE R. CORLE,
DEFENDANT/RESPONDENT
I
I
CUSTODY
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DOMESTIC RETURN RECEIPT
,;
CIVIL TERM
P 411l Sb4 143
US Postal SalVles
Receipt for Certified Mall
No Insurance Coverage Provided,
Do not use for International Mail 598 revers8
Senllo
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PoSl Otflce. Stale, IP ode
Postage $
.55
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Certified Fee
Special Defrwery Foe
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IN THE COURT OP COMMON PLEAS FOR
CUMBERLAND COUNTY, PENNSYLVANIA
JOY A. SINGER,
PLAINTIFF/PETITIONER
V.
CIVIL ACTION - LAW
I
NO. 97-2170
CIVIL TBRM
.
.
LONNIE R. CORLE,
DEPENDANT/RESPONDENT
I
I
CUSTODY
AFFIDAVIT OP SERVICE
COMMONWEALTH OF PENNSYLVANIA I
I SS
COUNTY OF CUMBERLAND :
Richard L. Webber, Jr., being duly sworn according to law,
deposes and says that he mailed the Order of Court and Petition for
Special Relief dated April 25, 1997 in this matter by certified
mail, return receipt requested, addressee only, to the Defendant/
Respondent LONNIE R. CORLE, 310 Walnut Dale Road, Shippensburg,
Pennsylvania 17257 on April 29, 1997. The return receipt signed by
the Defendant/Respondent is evidence of delivery to him and is
attached hereto as Exhibit "A".
'71;:/ 4.~~
Richard L. Webber, Jr., Attorney
for plaintiff/Petitioner
366 Green Spring Road
P.O. Box 40
Newville, PA 17241
(7171 776-6566
Sworn to a~ubscribed
me this / day of
~~U , 1997.
before
~v ,q ~':1"~
f . Notary Public
Not3ltal Bonl
Jo~nn E lllll. NolarV Public
NIJwvil!t~ 0010, CllmhfJrl:111d Coun'x
My Coml1ll!:slon E'Plfl':; ^ug.ll. 1'J. H
t,".'11'ot:x'f, Pl1IlO:"rylvapia K,'1:X;, \rorl 01 r-k>~\ljn':)
IN THE COURT OF COMMON PLEAS FOR
CUMBERLAND COUNTY, PENNSYLVANIA
JOY A. SINGER, CIVIL ACTION - LAW
PLAINTIFF/PETITIONER I
.
. CIVIL TERM
V. I NO. 97-2170
LONNIE R. CORLE, I
DEFENDANT/RESPONDENT I CUSTODY
f;'~~<''<:'-';:~~.'',~r<:'' ".' , . ' .' . "
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!if . """"'........._.._..___ond...._
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ml ?i-il\ 10: 4.. AIlIcIe Number
" ;!ij$ t~'~' ,.t ' ..' J
of ' ,,~.-X;~nni. R.' Cot'l.
~r-!~Q;"'ni1\t~ pale. Ro,ad ~'A=::::JYPl D Inlu,'"
~. :._~pp~n'~.ut'.g' PA17257 DC.IIII"" DCOD j
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f,;i;ci" 8. :,r~3'~Ir::~1 ..I (Only '''IClU'''''' J
~I ~_'_1U ~~ ~~N RECEIPT
P lUll Sb4 14'1
US P051a! Service
Receipt for Certllled Mall
No Insurance Coverage Provided.
00 not U!.8 for Inlemational Mail Sse reverse
Senllo
Mr. Lonnie R. Co
Srut & tlJmber
310 Walnut Dale
POll Otlt", Stale, & IP odo
Sh i ens bur PA
P"!age
$
Certlflad Fe.
SpeaalOeli.dryFeo
-
IN THI COURT 0' COMMON PLaAS FOR
CUMBBRLAND COUNTY, PENNSYLVANIA
JOY A. SINGER,
PLAINTIFF
CIVIL ACTION . LAM
v.
I
I
I
I
I
I
I
NO. 97-2170 CIVIL TBRM
LONNIE R. CORLE,
DEFBNDANT
IN CUSTODY
PRAECIPE TO WITHDRAW APPBARANCI
Dated:
t //(,(C/7
appearance in the above-captioned
~/l'~~~
Richard L. Webbe Jr.
366 Green Spring Road
P.O. Box 40
Newville, PA 17241
Phone (7l71 776-6566
action.
TO THE PROTHONOTARY I
Please withdraw my
,
,
i
I
!
I
I
i
i
,
I
I
i
i
!
i
'.
8. This Order is entered pursuant to an agreement reached by the
parties at a Custody Conciliation Conference. In the event
either party desires to modify this Order, that party may
petition the Court to have the case again scheduled with the
Custody Conciliator.
/,/
BY THE COURT, /
J.
cc:
James J. Kayer, Esquire
Joy A. Singer
16 Deadend Lane
Shippensburg, PA 17257
)~,~~
rn ':u 1 ~\
~
?/p):n
v
IIN THE COURT OF COMMON PLEAS OF
rCUMBERLAND COUNTY, PENNSYLVANIA
r
ICIVIL ACTION - LAW
r
INOr 97 - 2170 CIVIL TERM
rIN CUSTODY
JOY A. SINGER,
Plaintiff
LONNIE R. CORLE,
Defendant
Prior Judger Edgar B. Bayley
CONCILIATION CONFERENCE SUMMARY Rl!:PORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the
following reportr
1. The pertinent information pertaining to the child who is the
subject of this litigation is as follows:
David A. Corle, born October 29, 1996.
2. A Conciliation Conference was held on June 19, 1997, with the
following individuals in attendance:
The Mother, Joy A. Singer, who appeared without counsel and
the Father, Lonnie R. Corle, who appeared with his counsel,
James J. Kayer, Esquire.
3. The parties agreed to the entry of an Order in the form as
attached.
Ct hD{ q1
DATE