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KEITII " LONG.
"I"intil!'
vs
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL TERM '"I, (. f.. '~,( (;".~{ T-".......
SUSAN SA YTAR,
Defendant
CIVIL ACTION. CUSTODY
CUSTODY
STIPULATION AND AGREEMENT
THIS STIPULATION AND AGREEMENT entered into the day and year
hereinafier written by and bel ween KEITH A. LONG. (hereinafter referred to as "Father")
and SUSAN SA YT AR, (hereinafter referred to as "Mother").
WHEREAS. the panics arc the natural parents of: BRIANNA MICHELLE
SA YTAR. born October 9, 1996 (hereinallcr relerrcd to as "child"); and
WHEREAS, the parties are, at present. living separate and apart; and
WHEREAS, the parties wish to enter into an agreement establishing arrangements
relative to custody, temporary custody, and visitation of the children;
,
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,
NOW, THEREFORE, in consideration of the mutual covenants, promises and
1
agreements as hereinaficr set forth, the panies stipulate and agree as follows:
1. The parties shall have joint or shared legal and physical custody of the child,
2. The parties shall follow a physical custody schedule whereby Father shall
secure physical custody of the child at 7:00 a.m. on the day following his last
day of work for his routine work week. Father shall then retain physical
custody of the child from that time until 7:00 p,m. on the evening before the
day he must return to work begin his regular work week. It is understood
and recognized the Father's work days per week and his days off from work
per week can range Irom as Icw as two days to as many as livc days, The
within schedule for physical custody is based upon that understanding,
3. The parties rccognize and acknowledgc that there will be periods of time
when one parent or the other has physical cuslody for a period of in excess
of three days. In the event that either parent has physical custody of the child
for a period of in excess of three days, the other parent shall be entitled to
have contact with the child for a period of time as may be agreed upon by the
parties.
4. Parties agree that they shall share physical custody of the child during all
holidays. Parties will attempt to share physical custody in a manner
agreeable to both of them. In the event that they arc unable to agree to other
terms. for the following holidays, the parties shall alternate physical custody
from 8:00 a,m, 10 2:00 p.m. or from 2:00 p,m. to 8:00 p.m, The holidays
include the following: New Years' Day, Easter Sunday, Memorial Day, 4"'
of July, Labor Day, Thanksgiving Day and Christmas Day.
5. Each party shall be entitled to take one seven (7) day period of summer
vacation each year by providing the other party with no less than thirty (30)
days written notice of their desire to so exercise a period of summer
vacation,
6, The parties agree that they will continue using the services of the child's
paternal great.grandparents. Lloyd & Martha Stetler as the child's primary
baby-sitter. Any change in the child's primary baby. sitter shall be done by
mutual agreement.
7. The parties will keep each other advised immediately relative to any medical
emergencics concerning the children and shall further take any necessary
steps to ensure that the health and well being of the children is protectcd
During such illness or medical emergency, both parents shall have the right to
visit the children as oftcn as he or she desires consistent with the proper
medical care of the children,
8. Neither parent shall do anything which may estrange the childrcn from the
other party. or injure the opinion of the children as to the other party, or
which may hamper the free and natural development of the children's love or
atTection for the other party,
9, Any modification or waiver of any of the provisions of this Agreement on a
permanent basis shall be ell'ective only if made in writing. and only if
executed with the same formality as this Stipulation and Agreement.
10, The parties desire that this Stipulation and Agreement be made an Order of
Court to the Court of Common Pleas of Cumberland County, and further
acknowledge that the Court of Common Pleas of Cumberland County docs,
in fact, have jurisdiction over the issue of custody of the parties' minor
children, who have resided for their entire lives in Cumberland County,
Pennsylvania. The Court of Common Pleas of Cumberland County shall
retain such jurisdiction should circumstances change and either party desire
or require modification of the Order resulting from this Agreement.
.'
II The parties agree that in making this Agreement. there has been no fraud.
concealmcnt, ovcrrcaching. cocrcion. or olher lInHlir dealing on the part of
the other party.
12, The parties acknowledge that they have read and understand the provisions
of this Agreement. Each party acknowledges that the Agreement is fair and
equitable and that it is not the resull of any duress or undue influence.
IN WITNESS WHEREOF. the parties hereto intending to be legally bound by the
terms hereof, set forth their hands and seals the day and year hcreinafier mentioned,
WITNESSETH:
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Date KElT. LONG
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Date SUSAN SA YT AR
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COMMONWEALTII OF I'ENNSYL VANIA
SS
COUNTY OF CUMBERLAND
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On this the ( day of
'LG L (i,t/--C \, 1998. before me, the undersigned
officer, personally appeared KEITH A, LONG. known to me (or satisfactorily proven) to
be the person whose name is subscribed to the within Agreement and acknowledged that
she executed the same for the purposes therein contained. " '. ..- -iJ'-
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IN WITNESS WHEREOF, I hereunto set my hand and filcl~<S~f.::::", ="",.. rob 4, :,..'~
Mefr.l;u" f'u1"b'YoVli,.d A.'l.'iOCiatlcn d Noui'.a1
It i IdV' I L~' ~A{}7yr1c'Y?
COMMONWEALTH OF PENNSYLVANIA:
SS.
COUNTY OF CUMBERLAND
On this the ( {j day of ,~[it/(I'v(2-'C'l., 1998, before me, the undersigned
officer, personally appeared SUSAN SA YT AR, known to me (or satisfactorily proven) to
be the person whose name is subscribed to the within Agreement and acknowledged that
he executed the same tor the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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KElTII A. I.ONG
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1)8.101I34 ('IVII. ,\( 'lioN /',\1\'
SUSAN SA YTAR
f)J,FENDA:\T
IN n :STOIlY
OIUlER OF ('01 RI'
AND NOW, Tuesday. April 08. 2003 ,_' IIpon e"nsiderali"n "I'the allaehed Complainl.
it is hereby direclcd Ihal parties and their respective eOllnsel appear bel()re nawn S. Sunda)'. ~:sq. . the conciliator.
at 39 West Main Street, Meehanlcsbur2, I' A 17055 on Tuesda)'. Ma)' 06. 2003 at 1 :00 PM
for a Pre.llearing CIlSlody Conlercncc. AI sllch conl"renee. 'Ill en"rl will he mmle 10 resolve Ihe issues in displllc: 01'
il'lhis cannot be accomplished, to dcline and narrow the isslles to he heard hy the eOllrt. and 10 enler into a lemporary
order. All childreo age live or older mav also he present allhe eonf"renee, Failnre to appear atlhe conference mav
provide grollnds lor entry 01' a tempol':ll'Y 01' permanent order.
The court hereby directs the parties to fllrnish any '11111 all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to schedllled hearing.
FOR TilE COURT.
By: /s/
Dawll S. SI/IldaY-Jim.
Cllsllldy Conciliator
'n,e Cllllrl ofCommlln Pleas ol'Cllmherland County is reqllil'ed hy law 10 comply with Ihe
Americans with Disabililcs Act 01' 1990. For informalion abollt accessible facilities and reasonable
accommodations available to disabled individllals having business hefore the eOllrt. please contact our office,
AlIlIITangements mllst be made at least 72 hours prior to any hearing or business before Ihe court. You must
atlend the scheduled conference or hearing,
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO NOT
HAVE AN ATJ'ORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTI.r BELOW TO FIND OUT WHERE VOU CAN GET LEGAL HELP,
Cumherland Cllunty Bar Associmion
32 South BedJ()J'(1 Street
Carlisle. Pcnnsylvania 17013
Telephone (717) 249-3166
". ...
KEITH A. LONG,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 98.6634.CIVIL
Plaintiff
v.
SUSAN SAYTAR.
CIVIL ACTION - LAW
IN CUSTODY
Defendant
ORDER OF COURT
You, Keith A. Long, Plaintiff, have been sued in court to modify custody/partial
custody of the child, Brianna Say tar.
You are ordered to appear in person at
on
at_.m., for
a conciliation or mediation conference.
a pretrial conference.
a hearing before the court.
If you fail to appear as provided by this order, an order for custody, partial
custody or visitation may be entered against you or the court may issue a warrant for
your arrest.
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, PA 17013
717-249-3166
800-990-9108
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
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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 THE COURT:
J.
Dated:
-2-
-
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KEITH A. LONG,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v,
No, 98.6634.CIVIL
SUSAN SAYTAR,
CIVIL ACTION - LAW
IN CUSTODY
Defendant
DEFENDANT'S PETITION TO MODIFY ORDER OF CUSTODY
AND NOW COMES, Defendant, Susan Saytar, by and through her attorneys,
McNees Wallace & Nurick LLC, and hereby petitions the Court to modify the Order of
Custody entered on November 25, 1998 pursuant to the Stipulation of the parties, and
in support thereof, avers the following:
1. Plaintiff is Keith A. Long (hereinafter "Father"), who currenlly resides at
124 Altoona Drive, Enola, Cumberland County, Pennsylvania.
2. Defendant is Susan Say tar (hereinafter "Mother"), who currently resides at
824 West Keller Street, Mechanicsburg, Cumberland County, Pennsylvania,
3. The parties hereto are the parents of the following minor child:
NAME
PRESENT RESIDENCE
D.O.B~
Brianna Michelle Saytar
824 West Keller Street
Mechanicsburg, PA
October 9, 1996
AND
124 Altoona Avenue
Enola, PA
4. On November 25, 1998, the Court entered an Agreed Order of Custody
pursuant to the Stipulation of the Parties. Under the Stipulated Order, the parties have
,-
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joint legal and physical custody of the child, A true and correct copy of this Stipulation
and Order is marked Exhibit "A," allached hereto and made part hereof.
5. The actual experience under the Stipulated Order since November 25,
1998 has demonstrated that the Order must be modified to give Mother primary physical
custody and give father partial physical custody due to Father's work schedule, The
experience has demonstrated that the best interests of the child will be met by Father
having partial physical custody every other weekend and one overnight during the
week, with the rest of the custody with Mother. Currently, Father is at work during
almost all of his periods of custody with the child during the week and the child is forced
to spend that lime in the custody of a third party when she could be in the custody of
Mother.
6. The best interests and permanent welfare of the child will be served by the
following modifications of the current Order:
A. Paragraph 1 should be modified to read as follows:
1. Mother shall have primary physical custody of the
child. Father shall have partial physical custody of the child. The parties
shall have joint legal custody of the child.
S, Paragraph 2 should be modified to read as follows:
2, The parties shall follow a physical custody schedule
whereby Father shall have physical custody of the child from Friday at
7:00 PM until Sunday at1 0:00 AM every other weekend, Father shall also
.2.
7160 3901 98~~ 1911 2091
TO: Keith ^, l.ong
124 ^lIoon. Drive
Enol.. "^ 17025,2541
SENDER:
Pamela L. Purdy
REFERENCE: 21644,0001
PS Form 3800 June 2000
RETURN Postage
RECEIPT Certified Fee
SERVICE
Relurn Receipt Fee
Restricted Dalivery
Total Postage & Fees
o
US Postal S."ice
Receipt for
Certified Mail
No Insul'll/'lC8 Coverage Provided
00 Not Use tot Intimatlonal Mall
.................... ....... .........._....... ............. ....... .......... ".n ...
KElTII A, LONG.
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
Plaintiff
vs,
'lX.(.(.34
CIVIL ACTION LAW
SUSAN SA YTAR
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this '2--q day of vV~ , 2003,
consideration of lhe attached Custody Conciliation Report, it is ordered and directed as follows:
upon
I. The prior Order ofthis Court dated November 25, 1998 is vacated and replaced with this
Order.
2. The Father, Keith A. Long, and the Mother, Susan Say1ar, shall have shared legal custody of
Brianna Michelle Say1ar, bom October 9. 1996, Each parent shall have an equal right, to be exercised
jointly with the other parent, to make all major non-emergency decisions affecting the Child's general
well.being including, but not limited to, all decisions regarding her health, education and religion.
Pursuant to the terms of this paragraph each parent shall be entitled to all records and information
pertaining to the Child including, but not limited to, school and medical records and information.
3, The parties shall have physical custody of the Child in accordance with the following
schedule:
A. During the school year, commencing at the beginning of the 2003 -2004 school
year, the Father shall have custody of the Child every weekend from Friday after school
through Monday before school. The Mother shall have custody of the Child when the
Father works during his weekend periods of cllstody and at all other times not specified
for the Father under this provision.
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B, During the summer school break, the Father shall have custody of the Child on
altematillg weekends from Friday when the Mother begins work through Monday when
the Mother gets off work. In addition, the Father shall have custody of the Child every
day while the Mother is working, The Mother shall have custody of the Child at all
times not otherwise specified for the Father in this provision. The parties agree to
cooperate in scheduling the Mother's altemating weekend periods of custody with the
Child on the same weekends when the Mother also has custody of her son,
5. E;lch party shali he entitled to have cllstody of the Child 1l1r extended Jleriods inlhc summer
for vacation. upon providing at least thirty days ;ulvance notice to the other party,
6. In the event either party is unavailahle to provide cmc for thc Child during his or hcr pcriod
of custody for a period of at least four hours. thai party shall first coni act the olhcr party to offer the
opportunity to provide care for the Child before making olhcr arrangements.
7. For all exchanges of custody which do not take place at the Child's school. the party
rccciving custody shall be responsible to provide transportal ion unless otherwise agrccd between the
parties.
8. Both parties shall ensure that the Child is pcnniltcd 10 contact the other party hy telephone
during his or her periods of custody.
9, Neither party shall do or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as 10 the other parent, or hamper the free and natural development of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision,
10, This Order is entered pursuant to an agreement of the parties at a Custody Conciliation
Conference. The parties may modify the provisions of this Order by mutual con~cnt. In the absence of
mutual consent, the terms of this Order shall control.
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BYTHECOUR~;'; /
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Edgar B. Bayley J,
cc: ~GriffiC, Esquire - Counsel for Father
~ela L. Purdy, Esquire. Counsel for Mother
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06-J,<1-03
Ihe MOlher's allcmaling weckcnd pcriods of cnslody with Ihc Child on the same
weekends whcn Ihe MOlhcr also has cuslody of her son,
4. The parties shall sharc or ahcrnale having cnslody of thc Child on hulid:IYs :IS arrangcd hy
"gr~cmcnl.
5. Each party shall he cntillcd 10 have custody oflhe Child for cxtcndcd pcriods illlhc sumlller
for vacation. UpOIl providing at Icaslthirty days advancc notice 10 Ihc other party,
6. In the event cilhcr party is unavailahle 10 provide cmc for the Child during his or her period
of custody for a period of at least four hours, thai party shall first contact the other party to offer the
opportunity 10 provide care for thc Child hefore making olhcr arrangements,
7. For all exchanges of custody which do not take placc atlhc Child's school, thc party
receiving custody shall be rcsponsiblc to provide transportation unless otherwise agreed between the
parties.
8. Both parties shall ensure that the Child is penlIincd to contact the other party by telephone
during his or her periods of custody.
9. Neither party shall do or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natural developmcnt of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision,
10. This Order is entered pursuant to an agreement oflhe parties at a Custody Conciliation
Conference. The parties may modify the provisions oflhis Order by mutual consent. In the absence of
mutual consent, the temlS of lhis Order shall control.
BY THE COURT..
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Edgar B. Bayley
J.
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cc: Bradley L. Griffie, Esquire - Counsel for Father
Pamela L. Purdy, Esquire - Counsel for Mother
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SUSAN SI'~lIC
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1:--: ('USTlJIlY
OIWER OF COl1RT
AND ~O\\'.
,_'Y-"c1n.~~d.)'.\I.lI}:!I, 20_0.?.._________'. UpOIl cOllsidcratioll orthe anached Complaillt.
it is h..:n:hy din:Ch:U (full parlk's and thdr n:sr'-"dj\\.~ l.:ounscl appear hcltm: l>lm'lI S. Sundu)'. Es((.
. till: l.:uJlciliator.
at 39 We.. i\I~I-,,-.,s,lre~, l\I.ch.ni~~lJ.IlIJl.J>'~ .J.'-I!5~_ 011 .T~~,;<I~v'.~!~L~,t,2110.5_____ m 1.o,:!llJ...MI
for a Prc.llcaring Custody Conference. At slIch conlcrcncc. an effort will be made to resolve lhe issw..'s in dispute; or
if this cannot be accomplished. to dcline and narrow the isslIes to he 11I.'ard hy the court. and to enter into a temporary
oroer, All children a~e live or older ma\' also be present at the eonlcrellee, Failure to appear at the cOlllcrenec ma\'
provide grounds Illr cntry of a temporary or permanent order.
The eourl hereby dlreels Ihe parties 10 fnrnish any and all e,istlng Protection from Abuse orders,
Special Relief orders. and Cnslodv orders 10 Ibe conciliator -t8 hOllrs Ilrior to scheduled hearlne.
FOR THE COURT.
By: /s/
Dm..n S. Sund,'L Esq.
Custody Conciliator
.r
The Court of COl11monl'leas of CUl11bcrland County is required by law to comply with the Americans
with Disabilites Act of 1990, For inlormnlion about accessible IilCilitics and reasonable aceoml11odations
available to disabled individuals having business bel"ore the court, please contact Olll' omcc. All nrrangcmcnts
must be made at least 72 hours prior to an)' hearing or bllsiness bel\lre the eOllrt. You must mtend the scheduled
conlerence or hearing.
YOU SHOULD TAKE T1.IIS 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 8edl\1[(1 Street
Carlisk, Pennsylvania 170 I J
Telephone (717) 249.J 166
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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 bofore tho court, You must attend tho
scheduled conference or hearing,
BY THE COURT:
J.
Dated:
-2-
KEITH A, LONG.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No, 98.6634.CIVIL
Plaintiff
v.
SUSAN SEMIC. formerly known as
Susan Saytar
CIVIL ACTION - LAW
Defendant
IN CUSTODY
DEFENDANT'S PETITION TO MODIFY ORDER OF CUSTODY
AND NOW COMES. Defendant, Susan Semic, formerly known as Susan Saytar,
by and through her attorneys, McNees Wallace & Nurick LLC. and hereby petitions the
Court to modify the Order of Custody entered on June 19, 2003, and in support thereof,
avers the following:
1. Plaintiff is Keith A. Long (hereinafter "Father"), who currently resides at
240 Glenn Road, Camp Hill, Cumberland County, Pennsylvania,
2. Defendant is Susan Semic (hereinafter "Mother"), who currently resides at
146 Tory Circle. Enola, Cumberland County, Pennsylvania,
3. The parties hereto are the parents of the following minor child:
NAME
PRESENT RESIDENCE D,O.B.
Brianna Michelle Saytar
146 Tory Circle October 9,1996
Enola, PA
4. On June 19, 2003, after a conciliation with Dawn Sunday, Esquire, the
Court entered an Order of Custody, A true and correct copy of this Order is marked
Exhibit "A," attached hereto and made part hereof.
5, The actual experience under the Order since June 19,2003 has
demonstrated that the Order must be modified to give Mother primary physical custody
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and give father partial physical custody by agreement of the parties, The experience
has demonstrated that the best interests of the child will be met by Father having partial
physical custody by agreement and upon 24 hours' notice to Mother with the rest of the
custody with Mother, Currently, Father very rarely exercises his periods of custody, and
when he does, he often is late by hours in picking up the child,
6, The best interests and permanent welfare of the child will be served by
granting Mother primary physical custody and Father partial physical custody by
agreement of the parties.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court modify
the Order entered on June 19.2003 as set forth above.
Respectfully submitted,
McNEES WALLACE & NURICK LLC
BY~&p~y r~
I.D.#85783
100 Pine Street
P,O, Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
Attorney for Plaintiff
Date: May 3, 2005
-2,
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on the 3'd day of May 2005, a true and
correct copy of the foregoing document was served by first.c1ass mail, postage prepaid,
upon the following:
Keith A, Long
240 Glenn Road
Camp Hill, PA 17011
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Pamel L. Purdy
Of counsel for Defendant
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RECEIVED JUN 1 31orh(f'
IN TilE COllin OF COMMON PLEAS OF
CUMBERLAND COUNTY, I'ENNSYL VANIA
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KErn I A. LONG
Plaintiff
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CIVIL ACTION LA \V
SUSAN SEMIC
Defendant
IN CUSTODY
ORDER OF COURT
.,
AND NOW, this ~_ day 01' ~ I )\.AP , 2005. upon
consideration of the attached Custody Conciliation Report, it is ordered :lI1d dircctcd as follows:
I, The prior Order of this Court datcd June 19.2003, shall continue in effect as modified by
this Order.
2. Paragraph 3B of the June 11),2003 is vacated and replaced with the following: During the
summer school break in 2005, the parties shall share having custody of the Child on weekends in
accordance with the following schedule:
The Father shall have custody from June 11 at 11:00 a,m, through June 12 at 7:00 p.m,
The Mother shall have custody over the weekend of June 18,
The Father shall have custody from June 25 at II :00 a.m. through June 26 at 7:00 p,m.
The Mother shall have custody ovcr the weekends of July 2 and July 9,
The Father shall have custody from July 16 at 11:00 a,m, through July 18 before daycare.
The Father shall have custody from July 23 at 11 :00 a.m, through July 25 before daycare.
The Mother shall have custody over the weekends or July 30 and August 6,
The Father shall have custody from August 13 at 11:00 a,m. through August 15 before daycarc.
The Father shall have custody from August 20 at 11:00 a,m, lhrough August 22 before daycare.
The Mother shall have custody over the weekend of August 27.
3. The parties agree that the Child shall be enrolled rulltime in daycare during the summer in
2005. The Father shall be entitled to pick up the Child at daycare for periods during which the Father
is not working on weekdays whcn the Mothcr is at work, The Father shall return the Child to daycare
prior to going to work,
4. In the event thc Father is more than 30 minutcs late in picking up the Child at the Mother's
residence for a period of custody, the Mother shall be entitled to make other plans for herself and the
Child during the time which would otherwise havc been the Father's pcriod of custody. The Mother
shall be reasonable in exercising her rights under this provision in the event of an emergency or other
extraordinary circumstances which may have caused the Father's delay,
JECEIVED AUG 042005
KEITII A. I.ONG
PI~inlifT
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
\'S.
lJS.(,(,34
CIVIL ACTION LAW
SUSAN SEMIC
[)cfend~nt
IN CUSTODY
ORDER
AND NOW, this 2nd day of AUl!ust,2005 ,the conciliator, being advised by
plaintiffs counsel that all custody issues have been resolved by agreement of the parties, hereby
relinquishes jurisdiction. The Custody Conciliation Conference scheduled for August 16,2005 is
cancelled.
FOR THE COURT,
~~o (??y
Dawn S. Sunday, Esquire
Custody Conciliator
KEITH A. LONG,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 98-6634-CIVIL
Plaintiff
v.
SUSAN SEMIC, formerly known as
Susan Saytar
CIVIL ACTION - LAW
IN CUSTODY
Defendant
ORDER
AND NOW, this _ day of
, 2005, upon consideration of the
Petition for Leave to Withdraw as counsel for Defendant Susan Sem/c, it is hereby
ORDERED and DECREED that Pamela L. Purdy, Esquire is granted leave to withdraw
as counsel for Defendant Susan Semic.
BY THE COURT:
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
KEITH A. LONG,
v.
No. 98-6634-CIVIL
SUSAN SEMIC, formerly known as
Susan Saytar
CIVIL ACTION - LAW
Defendant
IN CUSTODY
BY THE COURT: /
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ORDER
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AND NOW, this ---1"L day of ~.2J}05, upon consideration of
Defendant's Petition for Rule Absolute, it is ORDERED that the appearance for Defendant of
McNees Wallace & Nurick LLC is hereby withdrawn.
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 98-6634-CIVIL
CIVIL ACTION - LAW
IN CUSTODY
v.
SUSAN SEMIC, formerly known as
Susan Saytar
Defendant
RULE
AND NOW, this ..J S day of 0, Lr.r , 2005, upon consideration of the
Petition of Pamela L. Purdy, Esquire for Leave to Withdraw as counsel for Defendant
Susan Semic, a Rule is hereby entered upon Susan Semic, to show cause, if any, why
the Petition should not be granted and why Pamela L. Purdy, Esquire should not be
permitted to withdraw as counsel for Susan Semic.
Rule returnable in ~ days of service.
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BY THE COURT:
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
KEITH A. LONG,
v.
No. 98-6634-CIVIL
SUSAN SEMIC, formerly known as
Susan Saytar
CIVIL ACTION - LAW
Defendant
IN CUSTODY
DEFENDANT'S PETITION TO MODIFY ORDER OF CUSTODY
AND NOW COMES, Defendant, Susan Semic, formerly known as Susan Saytar,
by and through her attorneys, McNees Wallace & Nurick LLC, and hereby petitions the
Court to modify the Order of Custody entered on June 19, 2003, and in support thereof,
IlVers the following:
1. Plaintiff is Keith A. Long (hereinafter "Father"), who currently resides at
?40 Glenn Road, Camp Hill, Cumberland County, Pennsylvania.
2. Defendant is Susan Semic (hereinafter "Mother"), who currently resides at
~46 Tory Circle, Enola, Cumberland County, Pennsylvania.
3. The parties hereto are the parents of the following minor child:
~AME
~rianna Michelle Saytar
PRESENT RESIDENCE D.O.B.
146 Tory Circle October 9,1996
Enola, PA
4. On June 19,2003, after a conciliation with Dawn Sunday, Esquire, the
~ourt entered an Order of Custody. A true and correct copy of this Order is marked
~xhibit "A," attached hereto and made part hereof.
5. The actual experience under the Order since June 19, 2003 has
!:lemonstrated that the Order must be modified to give Mother primary physical custody
and give father partial physical custody by agreement of the parties. The experience
has demonstrated that the best interests of the child will be met by Father having partial
physical custody by agreement and upon 24 hours' notice to Mother with the rest of the
custody with Mother. Currently, Father very rarely exercises his periods of custody, and
When he does, he often is late by hours in picking up the child.
6. The best interests and permanent welfare of the child will be served by
~ranting Mother primary physical custody and Father partial physical custody by
~greement of the parties.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court modify
1he Order entered on June 19, 2003 as set forth above.
Respectfully submitted,
McNEES WALLACE & NURICK LLC
By
..-'
Pamela L. Purdy
1.0.#85783
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
Attorney for Plaintiff
pate: May 3, 2005
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RiEITH A. LONG,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
98-6634
CNIL ACTION LAW
stSANSAYTAR
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this I <1. day of ~I!)V $;7 , 2003,
c sideratian afthe attached Custody Conciliation Report, it is ordered and directed as follows:
upon
I. All prior Orders of this Court in this matteI are vacated and replaced with this Order.
2. The Father, Keith A. Long, and the Mother, Susan Saytar, shall have shared legal custody of
B 'anna Michelle Saytar, born October 9,1996. Each parent shall have an equal right, to be exercised
jo ntly with the other parent, to make all major non-emergency decisions affecting the Child's general
w ll-being including, but not limited to, all decisions regarding her health, education and religion.
P suant to the terms of this paragraph each parent shall be entitled to all records and information
pe aining to the Child including, but not limited to, school and medical records and infonnation.
3. The parties shall have physical custody of the Child in accordance with the following
sc edule:
A. During the school yeaI, commencing at the beginning of the 2003 -2004 school
year, the Father shall have custody of the Child every weekend from Friday after school
through Monday befoIe school. The Mother shall have custody ofthe Child when the
Father works during his weekend periods of custody and at all otheI times not specified
for the Father under this provision.
B. During the summeI school break, the FatheI shall have custody of the Child on
alternating weekends from Friday when the Mother begins work through Monday when
the Mother gets off work. In addition, the Father shall have custody ofthe Child every
day while the Mother is wOIking. The MotheI shall have custody ofthe Child when the
Father works during his weekend periods of custody and at all times not otherwise
specified for the Father in this provision. The parties agree to cooperate in scheduling
EJ:PIBIT A
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the Mother's alternating weekend periods of custody with the Child on the same
weekends when the Mother also has custody of her son.
4. The parties shall share or alternate having custody of the Child on holidays as arranged by
agreement
5. Each party shall be entitled to have custody of the Child for extended periods in the summer
for vacation, upon providing at least thirty days advance notice to the other party.
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! 6. In the event either party is unavailable to provide care fOI the Child during his or her period
o~ custody for a period of at least four hours, that party shall fiIst contact the other party to offer the
o~portunity to provide care fOI the Child befoIe making otheI arrangements.
,
i 7, For all exchanges of custody which do not take place at the Child's school, the party
reteiving custody shall be responsible to provide transportation unless otherwise agreed between the
pties.
8. Both parties shall ensure that the Child is permitted to contact the otheI party by telephone
d1ring his or her periods of custody.
i 9. Neither party shall do or say anything which may estIange the Child from the other parent,
in~ure the opinion ofthe Child as to the otheI parent, or hampeI the free and natural development ofthe
C ild' s love and respect for the other parent Both parties shall ensure that third parties having contact
w' h the Child comply with this provision.
I
, 10. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation
Cqnference. The parties may modify the provisions of this Order by mutual consent In the absence of
m~tual consent, the terms ofthis Order shall control.
,
!
Edgar B. Bayley
J.
\
Bradley L. Griffie, Esquire - Counsel fOI Father
Pamela L. Purdy, Esquire - Counsel for Mother
TRUE COP'f' FROM FlECORD
In Testimony wheroof, I here unto wI my hiln(l
ant the S~I of said C9UJ1 at CarUsie, Pl..
Ibis )9~ ~y ot~l;:~i-~ ,;2bvJ
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ProtllOnotanl
VERIFICATION
I verify that the statements made in the foregoing document are true and correct
to the best of my knowledge, information and belief. I understand that false statements
are made subject to the penalties of 18 Pa. C.S. S4904, relating to unsworn falsification
10 authorities.
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CERTIFICATE OF SERVICE
The undersigned hereby certifies that on the 3rd day of May 2005, a true and
correct copy of the foregoing document was served by first-class mail, postage prepaid,
upon the following:
Keith A. Long
240 Glenn Road
Camp Hill, PA 17011
p'm.f~~ l~
Of counsel for Defendant
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PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
98-6634 CIVIL ACTION LAW
SUSAN SEMIC
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW.
Wednesday, May 11,2005...
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq.
at 39 West Main Street, Mechanicsburg, PA 1705..5.. on Tuesday, May 31, 2005..
. the conciliator,
at 10:00 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 mav also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or pelTl1anent 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/
_ Dawn S. Sunday, Esq.
Custody Conciliator
:r
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For infonnation about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All anangements
must be made at least 72 hours prior to any hearing or business bef()re 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
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RECEIVED JUN 13 2owy/'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
..
KEITH A. LONG
vs.
98-6634
CIVIL ACTION LAW
SUSAN SEMIC
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this ~ day of ~ U~ , 2005,
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
upon
I. The prior Order ofthis Court dated June 19, 2003, shall continue in effect as modified by
this Order.
2. Paragraph 3B of the June 19, 2003 is vacated and replaced with the following: During the
summer school break in 2005, the parties shall share having custody ofthe Child on weekends in
accordance with the following schedule:
The Father shall have custody from June 11 at 11 :00 a.m. through June 12 at 7:00 p.m.
The Mother shall have custody over the weekend of June 18.
The Father shall have custody from June 25 at 11 :00 a.m. through June 26 at 7:00 p.m.
The Mother shall have custody over the weekends of July 2 and July 9.
The FatheI shall have custody from July 16 at 11:00 a.m. through July 18 before daycare.
The Father shall have custody from July 23 at 11 :00 a.m. through July 25 before daycare.
The Mother shall have custody over the weekends of July 30 and August 6.
The Father shall have custody from August 13 at 11 :00 a.m. through August IS before daycare.
The Father shall have custody from August 20 at II :00 a.m. through August 22 before daycare.
The Mother shall have custody over the weekend of August 27.
3. The parties agree that the Child shall be enrolled full time in daycare during the summer in
2005. The Father shall be entitled to pick up the Child at daycare for periods during which the Father
is not working on weekdays when the Mother is at work. The Father shall return the Child to daycare
prior to going to work.
4. In the event the Father is more than 30 minutes late in picking up the Child at the MotheI's
residence for a period of custody, the Mother shall be entitled to make other plans fOI herself and the
Child during the time which would otherwise have been the Father's period of custody. The Mother
shall be reasonable in exercising her rights under this provision in the event of an emergency or other
extraordinary circumstances which may have caused the Father's delay.
,
5. The parties and their counsel shaIl attend an additional custody conciliation conference for
the purpose of addressing the school year schedule on August 16, 2005 at 8:30 a.m. in the office ofthe
conciliator, Dawn S. Sunday. In the event disputes or concerns arise with regard to the summer
custody schedule as provided in this Order, counsel for either party may contact the conciliator to
reschedule the foIlow-up conciliation conference for an earlieI date.
6. This Order is entered pursuant to an agreement ofthe parties at a custody conciliation
conference. The parties may modify the provisions of this OrdeI by mutual co. nse.?!. ~ absence of
mutual consent, the terms of this Order shaIl control.
BY THE COURT, /'
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cc:~ane M. Dils, Esquire - Counsel for Father
~ela L. Purdy, Esquire - Counsel for Mother
ALED-OFflCE
OF THE PP:OTHONOTARY
Z005 JUN 14 PH [;: 00
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KEITH A. LONG
Ys.
98-6634
CIVIL ACTION LAW
SUSAN SEMIC
Defendant
IN CUSTODY
Prior Judge: Edgar B. Bayley
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Brianna Michelle Saytar
October 9, 1996
Mother
2. A conciliation conference was held on June 6, 2005, with the following individuals in
attendance: The Father, Keith A. Long, with his counsel, Diane M. Dils, Esquire, and the Mother,
Susan Semic, (formerly Saytar), with her counsel, Pamela L. Purdy, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
~ I, ;)005
Date
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Dawn S. Sunday, Esquire
Custody Conciliator
KEITH A. LONG,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No. 98-6634-CIVIL
SUSAN SEMIC, formerly known as
Susan Saytar
Defendant
CIVIL ACTION - LAW
IN CUSTODY
PETITION TO WITHDRAW APPEARANCE
Pamela L. Purdy, Esquire, counsel at McNees Wall.3ce & Nurick LLC,
respectfully petitions this Honorable Court for Leave to Wil.hdraw her Appearance as
counsel for Defendant, and, in support thereof, avers as follows:
1. Plaintiff Keith A. Long and Defendant Susan Semic have come to an
agreement in the above-captioned action and are in the process of executing the
necessary papers.
2. Defendant Susan Semic wishes to proceed pro se from this point forward.
3. Petitioner Purdy has sought the concurrenCEi of counsel for Plaintiff in this
Petition, and said counsel concurs in this Petition.
WHEREFORE, Petitioner Pamela L. Purdy, Esquin3 respectfully request leave to
withdraw her appearance as attorney for Defendant.
By
Pamela L. Purdy
1.0. #85783
100 Pine Street
P.O. Box 1166
HarrisburU, PA 17108-1166
(717) 232-8000
Dated: tl, '&1 (J.r{'
CERTIFICATE OF SERVICE[
The undersigned hereby certifies that on the Ji clay of August 2005, a true
and correct copy of the foregoing document was served by first-class mail, postage
prepaid, upon the following:
Diane M. Oils, Esquire
1017 North Front Street
Harrisburg, PA 17102
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KEITH A. LONG,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 98-66,34-CIVIL
v.
SUSAN SEMIC, formerly known as
Susan Saylar
Defendant
CIVIL ACTION - LAW
IN CUSTODY
RULE
AND NOW, thiSQ.;y of ~..I\ , 2005, upon consideration of the
Petition of Pamela L. Purdy, Esquire for Leave to Withdraw as counsel for Defendant
Susan Semic, a Rule is hereby entered upon Susan Semic, to show cause, if any, why
the Petition should not be granted and why Pamela L. Purdy, Esquire should not be
permitted to withdraw as counsel for Susan Semic.
Rule returnable in tv days of service.
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KEITH A. LONG,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No. 98-6634-CIVIL
SUSAN SEMIC, formerly known as
Susan Saytar
Defendant
CIVIL ACTION - LAW
IN CUSTODY
PETITION TO MAKE RULE ABSOLUTE
And now comes Defendant Susan Semic, by and through her attorneys, McNees
Wallace & Nurick LLC ("MWN"), and fully represents as follows:
1. On August 22, 2005, MWN filed a Petition to Withdrawal as counsel for
Defendant.
2. In response to the Petition, this Court on August 2:5, 2005 issued a Rule upon
Plaintiff Keith A. Long to show cause why MWN should not be granted leave to withdraw its
appearance. Said Rule was returnable within ten (10) days. A copy of the Petition and the
Rule is attached hereto as Exhibit "A."
3. More than ten (10) days have passed since the date of the Rule. To date,
Plaintiff has not filed a written response requested by the Rule dated August 25, 2005.
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WHEREFORE, for the reasons set forth in Defendant's Petition to Withdraw
Appearance, Defendant respectfully requests that the Court make the Rule absolute and
enter an Order granting the withdrawal of MWN as counsel for Defendant.
McNEES WALLACE & NURICK LLC
BL~f-.F"1:
I.D. No. 8578:1
100 Pine Strel9t
P.O. Box 116!l
Harrisburg, PA 17108-1166
(717) 237-5479
Dated: September 6, 2005
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RECEIVED AUG 23 2001
KEITH A. LONG,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No. 9S-6634-CIVIL
SUSAN SEMIC, formerly known as
Susan Saytar
CIVIL ACTION - LAW
Defendant
IN CUSTODY
RULE
AND NOW, this .25 day of (I, 'J'ut' , 2005, UpOI1 consideration of the
Petition of Pamela L. Purdy, Esquire for Leave to Withdraw as counsel for Defendant
Susan Semic, a Rule is hereby entered upon Susan Semic, to show cause, if any, why
the Petition should not be granted and why Pamela L. Purdy, Esquire should not be
permitted to withdraw as counsel for Susan Semic.
Rule returnable in ~ days of service.
BY THE COURT:
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In TIN~lmony W4reroof, IlIere liflio 001 my hand'
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KEITH A. LONG,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No. 98-6634..CIVIL
SUSAN SEMIC, formerly known as
Susan Saytar
CIVIL ACTION - LAW
Defendant
IN CUSTODY
ORDER
AND NOW, this _ day of
, 2005, upon consideration of the
Petition for Leave to Withdraw as counsel for Defendant Susan Semic, it is hereby
ORDERED and DECREED that Pamela L. Purdy, Esquire is <granted leave to withdraw
as counsel for Defendant Susan Semic.
BY THE COURT:
J.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 98-6634-CIVIL
KEITH A. LONG,
Plaintiff
v.
SUSAN SEMIC, formerly known as
Susan Saytar
CIVIL ACTION - LAW
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Pamela L. Purdy, Esquire, counsel at McNees WallaCl3 & Nurick LLC, ~h~~ :1t
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respectfully petitions this Honorable Court for Leave to Withdraw her Appearan~ ast;
Defendant
IN CUSTODY
PETITION TO WITHDRAW APPEARANCE
counsel for Defendant, and, in support thereof, avers as follows:
1. Plaintiff Keith A. Long and Defendant Susan Semic have come to an
agreement in the above-captioned action and are in the proCElSS of executing the
necessary papers.
2. Defendant Susan Semic wishes to proceed pro se from this point forward.
3. Petitioner Purdy has sought the concurrence of counsel for Plaintiff in this
Petition, and said counsel concurs in this Petition.
WHEREFORE, Petitioner Pamela L. Purdy, Esquire respectfully request leave to
withdraw her appearance as attorney for Defendant.
By
WALLACE ,3. NURICK LLC
I
Dated: ~\l i[o<
Pamela L. Purely
1.0. #85783
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
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CERTIFICATE OF SERVI E
The undersigned hereby certifies that on the L day of August 2005, a true
and correct copy of the foregoing document was served by first-class mail, postage
prepaid, upon the following:
Diane M. Oils, Esquire
1017 North Front Street
Harrisburg, PA 17102
CERTIFICATE OF SERVICE
I hereby certify that I served a true and correct copy of the within document upon the
following by depositing a copy of same in the United States mail, first class, postage prepaid,
addressed as follows:
Diane M. Oils, Esquire
1017 North Front Street
Harrisburg, PA 17102
Dated:
September 6, 2005
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 98-6634-CIVIL
KEITH A. LONG,
v.
SUSAN SEMIC, fqrmerly known as
Susan Saytar
CIVIL ACTION - LAW
Defendant
IN CUSTODY
ORDER
AND NOW, this -----1;[. day of ~05, upon consideration of
Defendant's Petition for Rule Absolute, it is ORDERED that the appearance for Defendant of
McNees Wallace & Nurick LLC is hereby withdrawn.
BY THE COURT:
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