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HomeMy WebLinkAbout98-058083 0 i 3 0 1 ti C.1 a 0 o. C? ' O?! ------ ------ Gaston A. Snowden, Jr., IN'I'Illi ('Ol It'I' OI' COMMON I'LI:AS OI Plaintiff CUbIBBRLAND C'OVNTY. PENNSYLVANIA v. CIVIL ACTION - LAW Jncquell Snowden, No. %-,Sgoy CIVIL TERM Defendant IN DIVORCE ORDER OF COURT AND NOW, this I Cl day of 00Ct?C C , 1998 upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before' Ukt C-C 4 'X. CD 1+i I,Q(4he conciliator, at 0,e Hwt V7kct:) cyl7c\t4ct t?m?Y?l,?urber(C(?C? (C.n 1 (t_0l)0-).?C Cumberland County, Pennsylvania on the _ day of ?-(rube' L , 1998, at 9 ;Q _ o'clock Q . 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. FOR THE COURT, By: 1a?oA X 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 abouot accessible facilities and reasonable accomodations available to disabled individuals having business before the court, please contact our office (See Court Administrator Office listed below). 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 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, PENNSYLVANIA 17013 'T'ELEPHONE: 717-249-3166 /We Gaston A. Snowden, jr., IN' HI: COURT OFCOMMON PLEAS 01' Plaintiff CUMBERLAND COUNTY. PENNSYLVANIA V. : CIVIL ACTION - LAW Jacquell Snowden, No. 9H- CIVIL TERM Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM OF RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 240-6195 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 717-249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 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. Gaston A. Snowden, jr., : IN TI IE COIJR'1' OF COMMON PI.BAS OP Plaintiff :Ct1MliI:RI.AND COUN'T'Y. PENNSYLVANIA V. CIVIL ACI'ION - LAW ,Iacquell Snowden, : No.98- '1.tL,J CIVIL. TERM Defendant IN DIVORCF, COMPLAINT COUNT I - DIVORCE UNDER 3301(c) OF THE DIVORCE CODE AND NOW cones Gaston A. Snowden, Jr., by and through Frey and Tiley, attorneys for Plaintiff, and makes the following statement: I. Plaintiff is Gaston A. Snowden, Jr., who currently resides at 705 Stanwick, Circle, Apartment F, Carlisle, Pennsylvania 17013. 2. Defendant is Jacque] I Snowden, who currently resides at 705 North Hanover Street, Apartment B, Carlisle, Pennsylvania 17013. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 3, 1993 in Las Vegas, Nevada. 5. There have been no prior actions of divorce or f'or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiffmay have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, Divorcing Plaintiff and Defendant. COUNT II - DIVORCE UNDER 3301(d) OF THE DIVORCE CODE 8. The allegations in Paragraphs I through 7 are incorporated herein by reference and are made a part hereof. 9. Plaintiff and Defendant are now living separate and apart and have lived separate and apart since August 9, 1998, at the appropriate time, Plaintiff will submit an affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests your Honorable Court to enter it Decree in Divorce, divorcing Plaintiff and Defendant. COUNT III EQUITABLE DISTRIBUTION 10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as though set forth in full. 11. Plaintiff and Defendant have acquired property, both real and personal during their marriage from July 3, 1993 until August 9, 1998, the date of separation. 12. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property. COUNT IV CUSTODY 13. Paragraphs l through 12 of this Complaint are incorporated herein by reference as though set forth in full. 199314. The parties are the natural parents of Gaston A. Snowden, 111, born December 22, . The child was not born out of wedlock. The child is presently living with Plaintiffs parents, Rubin Williams and Betty Williams, who reside at 412 Mesa Verde, Palm Dale, California 93551. During the past five years, or since the child's birth, the child has resided with the following persons at the following addresses for the following periods of time: NAME ADDRESS DATE Father & Mother Birth to 12/94 Father 12/94 to 5195 Mother & Father 5/95 to 7/95 Rubin Williams and Betty Williams 7/95 to 12/95 Father 12/95 to 3/96 Mother 3/96 to 5/96 Rubin and Betty Williams 5/96 to 12/96 Mohler k Father 12/96 to 6/98 Father 6/98 to 9/23/98 Rubin and Betty Williams 9/23/98- The natural mother of the child is Jacquell Snowden, Defendant, currently residing as stated in paragraph 2 herein. She is married to Plaintiff' The natural father of the child is Gaston A. Snowden, Jr., Plaintiff'. currently residing as stated in paragraph I herein. He is married. 15. The relationship of the Plaintiff to the child is that of Father. The Plaintiff resides with the following persons: NAME RELATIONSHIP None. 16. The relationship of the Defendant to the child is that of Mother. The Defendant resides with the following persons: NAME RELATIONSHIP Staff Sergeant Coleman Boyfriend 17. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning the custody of the child in this or in any other Court. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 18. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) Plaintiff can provide a more stable home for the child; (b) During the life of the child, Plaintiff has provided the primary care, custody, and control of the child; (c) During the life of the child, Plaintiff has provided the primary physical, mental, and emotional guidance and the primary physical, mental, and emotional care for the child. 19. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been maned parties to this action. No other persons are known to have or to claim any right to custody or visitation of the child other than the parties to this action. WHEREFORE, Plaintiff requests your Ilonorable Court to set a time and place for a hearing at which Plaintiff requests the Court to grant him custody of his child, Gaston A. Snowden, III. Frey & 'racy, Attorneys for Plaintiti' Robert G. Frey, Esquire Supreme Court Number 46397 5 South Hanover Street Carlisle, Pennsylvania 17013 (717) 243-5838 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. 4904 relating to unsworn falsification to authorities. Dated: aston A. Snowden, Jr. , ;PP GAST ON A. SNOWDIX JR.. IN I I II? ('OI IR'I' OF ('OMMON I'I.I?AS OF I'I:aimit3' ('t 1%1111:1(I,AND ('OI IN'I')', pl?NNS)'I.VANIA CIVIL AC HON - LAW JAC'Q1110,1, SNOWDI'.N, NO. 98 - 5808 CIVII. D&II(l ut IN C'l1S'FODY COURT ORDI?R AND NOW, this t%" day al' January. 1999, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follo«:s: This Court's temporary Order entered December 8. 1998 is vacated. 2. The Father, Gaston A. Snowden. Jr., and the Mother. Jacyuell Snowden, shall enjoy shared legal custody of Gaston A. Snowden. 111. born December 22. 1993. 3. 'file Father shall enjoy primary physical custody ofthe minor child. 4. The Mother shall enjoy periods of temporary physical custody of the minor child as hollows: A. On alternating weekends on Friday at 6:00 P.M. until Sunday at 6:00 p.m. Mother's periods of alternating weekends shall start on Friday. January 15"' 13. On alternating major holidays to include New Year's Day, Easter. Memorial Day, July 4°i and Labor Day. The alternating custody schedule for holidays shall start with Father having Easter 1999 and the panics alternating therealicr. C. For a period of 2 weeks vacation during the summer months. Mother shall give Father at least 30 days written notice as to when she intends to exercise summer vacation. Thanksgiving holiday shall be handled separately with the parties sharing Thanksgiving or alternating between themselves. In the event the parties cannot agree. Thanksgiving shall be split in 2 times between 9:00 a.m. until 3:00 p.m. and 3:00 p.m. until 9:00 p.m. with the parties to alternate that schedule on a yearly basis with the Father having the first part of the day in 1999. bt' GAS 'TON A. SNOWDIXJR., IN I'I II: ('OI Ilt'f OF ('OMMON PLI?AS OI' I'laintill• : ('l I,Ilil:RI.AND ('OI INI )'. 1'1'.NNSYI.VANIA v : CIVIL AC] ION - LAW JACQI II LL SN'O11'DI{N. NO. 98 - 5809 CIVII. Defendant IN CUSTODY C01111T ORDER AND NOW, this t ml day of January. 1999. upon consideration of' the attached Custodv Conciliation Report, it is ordered and directed as hollows: This C'ourt's temporary Order entered December 8. 1999 is vacated. 2. The Father, Gaston A. Snowden, Jr., and the Mother, .Iacyuell Snowden, shall enjoy shared legal custody of Gaston A. Snowden, 111, born December 22, 1993. 3. The Father shall enjoy primary physical custody of the minor child. 4. The Mother shall enjoy periods of temporary physical custody of the minor child as hollows: A. On alternating weekends on Friday at 6:00 p.m. until Sunday at 6:00 p.m. Mother's periods of alternating weekends shall start on Friday, Januarv 15"' 13. On alternating major holidays to include New Year's Day, Easter, Memorial Day, July 4°i and Labor Day. The alternating custody schedule for holidays shall start with Father having Easter 1999 and the parties alternating thereafter. C. For a period of 2 weeks vacation during the summer months. Mother shall give Father at least 30 days written notice as to when she intends to exercise summer vacation. 5. Thanksgiving holiday shall be handled separately with the parties sharing "Thanksgiving or alternating between themselves. In the event the parties cannot agree. 'T'hanksgiving shall be split in 2 times between 9:00 a.m. until 3:00 p.m. and 3:00 p.m. until 9:00 p.m. with the parties to alternate that schedule on a yearly basis with the Father having the first part of the day in 1999. 6. Over file Christmas holiday, the panics shall attempt to share the Christmas holiday with the minor child. In the event the parties cannot reach an agreement on sharing the Christmas holiday, the Christmas holiday shall be divided into 2 sections from Christmas Eve at noon until Chrisunas Day at noon and from Christmas Day at noon until December 2ti1' at noon. In the event there is no agreement between the parties for the Christmas holiday of 1999, it shall start with Father having the first segment with the child which will be from Christmas live at noon until Christmas Day at noon. 7. The Father shall always hate custody on Father's Day and the Mother shall always have custody on Mother's Day, the time frame is to be from 9:00 a.m. until 9:00 p.m. "Phis provision shall supcrcede any other provision of this Order. 8. Except by agreement of the parties to the contrary, the exchange of custody shall take place in the parking lot of the Wendy's Restaurant on South Hanover Street in Carlisle. 9. In the event either party desires to modify this order, that party may petition the Court to have the case again scheduled for a Conference with the Custody Conciliator. BY TFIE COUI; Edgar B. cc: Michael R. Rundle, Esquire ,..a,. d- Robert G. Frey, Esquire M GASTON A. SNOWDI{N. JR- Plaintill' JACOI TI.I. SNOWDI{N, Defendant Prior.ludge: Edgar li. Bayley IN I'111; ('01IRT OF COMMON PLEAS OF ('I IMHNRLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 98 - 5808 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDAN(T WI I'll THE CUMBERLAND COUNTY CIVIL RULE 01: PROCEDURE 1)15.3.81)1, the undersigned Custody Conciliator submits the following report: the pertinent inibrmation pertaining to the child who is the subject ol'this litigation is as lbllaws: (inston A. Snowden. III, bom December 22, 1993. 2. A Conciliation Conference was held on January 5, 1999 with the following individuals in attendance: Ilse Father. Gaston A. Snowden, Jr., with his counsel, Robert Prey, Esquire; and the Mother, Jacqucll Snowden, with her counsel, Michael Rundle, Esquire. 3. The Conciliator recommends an order in the form as attached pursuant to an agreement reached by the parties at the Conciliation Conference. UA 11: Hubert X. Gilroy, Esquire Custody Conciliator 11 11Fr - 7 lggR GASTON A. SNOWDEN, JR., IN TI Ili COURT OF COMMON PLEAS OF I'laimil3' CUMlil:lZI.AND COIJN'I'Y, PENNSYI.VANIA CIVII. ACTION - LAW JACQUELL SNOWDI?N, NO. 98 - 5808 CIVII. Defendant IN CUSTODY COURT ORDER AND NOW, this <y day of December, 1998, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The following temporary custody order is entered: A. The Father Gaston A. Snowden, Jr. and the Mother Jacquell Snowden shall enjoy shared legal custody of Gaston A. Snowden, III, bom December 22, 1993. 13. 'file parents shall enjoy shared physical custody of the minor child with physical custody to be alternated on a week to week basis. Father shall have physical custody through Monday, December 14, at which time he shall deliver the child to the daycare center as agreed upon by the parties. Mother shall have custody starting on that Monday with the parties alternating weekly thereafter. C. On the Christmas holiday, the Mother shall have Custody of the minor child from noon until 6:00 p.m. D. The Mother shall not have anyone co-habitate with her or sleep over at her apartment while she has custody of the minor child. E. The parties may modify this order by agreement between the parties. However, absent any agreement, the parties shall abide by the terms of this order. 2. The parties shall meet for a Custody Conciliation Conference with the Custody Conciliator on Tuesday, January 5, 1999 at 2:00 p.m. 3. The above order is a temporary Custody Order and is done with the understanding that neither party waives any claims that party may assert for primary custody or for any other issues at a hearing in this case. 11 4. In the event either party retains a profession to do either a custody evaluation or any type of family counseling arrangement, the other party will cooperate with that evaluation or counseling and ensure that they participate along with the participation of the minor child. This provision is issued with the premise that the parent who desires to initiate the evaluation or counseling shall incur the expense for that procedure unless agreed otherwise by the parties. BY THE COURT, cc: Robert G. Frey, rsquirc Michael R. Rundle, Esquire 2e fr «.; n, 4 iJ. 5. i F OAS'I'ON A. SNON'DIiN,.IR.. Plaintiff JACQt ITI. SNOWDEN. Delcndamt Prior Judge: IN'I'I II? C'OI IR I OF ('OMMON PLEAS 01' ('lI;VIBERI AND('OIINIT.I'FNNS)I.VANIA CIVIL A(' I*ON - LAW NO. 98 - 5908 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE. OF PROCEDURI: 1915.3-8(b), the undersigned Custody Conciliator submits the following report: I. The pertinent infonnation pertaining to the child who is the subject of this litigation is as fiol lows: Gaston A. Snowden. Ill, born December 22. 1993. 2. A Conciliation Conference was held on December 4, 1998, with the billowing individuals in attendance: The Father, Gaston A. Snowden, with his counsel, Robert Frey, Esquire: and the Mother, Jacquell Snowden, with her counsel, Michael Rundle, Esquire. 3. 'fhe Conciliator recommends an order in the form as attached. l2 9 O/ DAT E Hubert X. Gilroy, E u Custody Concilia r GASTON A. SNOWDEN, JR., Plaintiff V. JACQUELL SNOWDEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 98-5808 CIVIL TERM IN DIVORCE AND NOW, comes the Defendant, Jacquell Snowden, by and through her counsel, Addams & Rundle, and files a counterclaim in divorce under Section 3301(a) (6) of the Divorce Code, more specifically set forth as follows: 1. The Defendant is Jacquell Snowden, who resides at 705 North Hanover Street, Apt. B, Carlisle, Cumberland County, Pennsylvania since September, 1998. 2. The Plaintiff is Gaston A. Snowden, Jr., who currently resides at 43 Eastwick Lane, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the commencement of this action. 4. The parties were married on July 3, 1993 in Las Vegas, Nevada. 5. The Plaintiff has offered such indignities to the Defendant, who is the innocent and injured spouse, as to render her condition intolerable and her life burdensome. 6. There has been no prior action for divorce of annulment between the parties in this or any other jurisdiction. 7. The Defendant han boon .:advised of the availability of counselling and that she may have the right to request that the court require the parties to participate in counselling. 8. The Defendant requests the court to enter a decree of divorce. I verify that the statements made in this counterclaim are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to al, Date: February /!", 1999 ADDAMS & RUNDLE ? I Y: Michael R. Rundle Supreme Court I.D. No. 06265 28 South Pitt Street P.O. Box 208 Carlisle, PA 17013 (717) 249-8300 Attorneys for Defendant CERTIFICATE OF SERVICE AND NOW, this 19th day of February, 1999, I, Michael R. Rundle, of Addams & Rundle, attorneys for Defendant Jacquell Snowden, hereby certify that I have served a copy of the Counterclaim by mailing a copy of the same by United States mail, postage prepaid, addressed as follows: Robert G. Frey, Esquire Frey & Tiley 5 South Hanover Street Carlisle, PA 17013 II ,. r ? ?j ry - :J ?? ;i -t 1. r[7 _ a? V: i _ :-f -• rn -`? Jennifer A. Strock, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA :NO. 99-5808 CIVIL TERM Heath A. Strock, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Adam Britcher, Certified Legal Intern, hereby certify that I am serving, via United States Mail, First Class, a true and correct copy of the PETITION FOR LEAVE TO WITHDRAW, on Defendant, Mr. Heath A. Strock, at 828 Fishing Creek Road, New Cumberland, PA, 17070, and on counsel for Plaintiff, Jaime D. Wassmer, Esquire at 2505 North Front Street, Harrisburg, PA, 17110 on May 14, 2009. I verify that the statements made in this Certificate of Service are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. _51 0 Date Adam Britcher Certified Legal Intern i S?Rr?t? 2 009 r 0 JENNIFER A. STROCK, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 1999-5808 CIVIL TERM : HEATH A. STROCK, CIVIL ACTION -LAW DEFENDANT ACTION FOR CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE Please enter my appearance on behalf of the Defendant, HEATH A. STROCK. Respectfully submitted, Dated: May 13, 2009 LAW FIRM OF SUSAN KAY CANDIELLO, P.C. Susan Kay Candiel PA I.D. # 64998 4010 Glenfinnan ] Mechanicsburg PA (717) 724-2278 e., l TAP I 2069 MA^ P =: ' c JAIME D. WASSMER, ESQUIRE Attorney I.D. No. 200705 Robinson & Geraldo, P.C. 2505 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717)232-8525 Fax (717)232-5098 jwassmer@robinson-geraldo.com JENNY STROCK, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERAND COUNTY, PENNSYLVANIA V. : NO. 99-5808 HEATH A. STROCK, Defendant. : CIVIL ACTION CUSTODY PROOF OF SERVICE The undersigned makes the following return of service: the Order for Custody Conference was served upon Heath Strock on May 11, 2009 at 828 Fishing Creek Road, New Cumberland, Cumberland County, Pennsylvania. The signed acceptance of service is attached hereto as Exhibit 1. SIGNATURE AND AFFIDAVIT I, Jaime D. Wassmer, Esquire, certify that I am a competent adult not a party to this action. I verify that the statements made in this affidavit and return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsfication to authorities. Respectfully submitted, ROBINSON & GERALDO Dated: May 13, 2009 By: .- - Le"' )ie D. Wassmer, Esquire Attorney for Plaintiff ¦ Complete items 1, 2, and 3. Also complete ibm 4 if Restricted Delivery is desired. f Print your name and address on the reverse so that we can return the card to you. ¦ Assch this card to the back of the maiipiece, or on the front if space permits. 1. Article Addressed to: ?h s/?-o Ck- MVAJ cm by-ldpn', fA /7070 A. Signature X rt ' B. Receive by (Printed Name) C. , g rif D l?E 4 rta A S rata lG D. Is delivery address different from item 11 ? Yes If YES, enter delivery address below: ? No 3. Service Type g4gtifled Mail 13 Expeas Mail istered 17K@tum Receipt for Merchandise ? Insured Mail ? C.C.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. AA bleNumber 7008 1140 0004 4438 1333 Mormfer ftm so &W Ps Form 3811, Feb uitry 2W DamMtic lbtlnn w.©.ipe 102595-02-M-IM rI, UNITED STATES POSTAL SERVICE First-Class Mail Postage & Fees Paid USPS Permit No. G-10 • Sender: Please print your name, address, and ZIP+4 in this box • ROBINSON & GERALDO Attorneys At Law P.O. Box 5320 Harrisburg, PA 17110 1111111141111111111111111111.iii, 11111:1 i rllis 111 III III111111111 EXHIBIT {'il?S....l....i.{` 1. ..fr_ '"log N f??i ar +`t VAIN!A