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HomeMy WebLinkAbout00-06705 j}"' ,. L '-0 .L-~ ~<, : I , 0' 'I, " '~ il.Jl:~~o . TERRY LEE SHOEMAKER PLAINTIFF V. TINA KAY SHOEMAKER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-6705 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 10th day of October, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenne, Suite 105, Camp Hill, PA 17011 on the ~ day of November ,2000, at -.l.l!:00 a.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 ma,y provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Isl Melissa P. Greevy. E~ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. Yon 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 -~ " ~ /o./lr9t1 !{)'/I-a;J !()/l 00 I ',-'Ii ~ 0,"" ',-, "_''''''c''''^''.., .,"'"~'~'-"""'W~,d,'"",,,,,,~~,,, ';","'0.l'~"~"-"""~"'-'fu__'~'1.'_,," " ,,'~ "',~ OF 00, nrT I i j)'" )'" r,' Lt,.-, . ,n' t':'. .~l.t Cllh'IDC::C" ,. n,,, '1\' ~Ji._, :LI ,,~L! \j,)dNTY PENNSYLVI\,\JI/\ ad. ~~.~' 4.~~ 7W!a~~z4;L;~ ~~ $4~ ~~R!!i"f,rwV'" ~~... ,,~~ ,~ ~~"<<!~~'T}i''''''''1('"",,;a;''~,'-''JI\~l'!W~';!'''1'Illi~''':>~>;<'''~llW~MNi'$~~~03i!I''H"iWF"~fl!~';','~;0~';'lT'1["'5~]m!@Ji!~:m~ ^.~'" ~ L . ~; .. TERRY LEE SHOEMAKER Plaintiff :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYL VANIA VS. . :NO:" CO- '-7D5 CuJ_~l TINA KAY SHOEMAKER Defendant : CIVIL ACTION-LAW :IN CUSTODY ORDER OF COURT AND NOW, this _ day of ,2000, upon consideration of the attached complaint, it is hereby directed that the above parties and their respective counsel appear before , Esquire, the conciliator, at , Pennsylvania, on the Day of A.M./P.M., for a Pre-hearing Custody Conference. At such , 2000, at 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 be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent order. FOR THE COURT: By: Custody Conciliator YOU SHOULD TAKE TillS 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 FlND OUT WHERE YOU CAN GET LEGAL HELP. DAlJi>IElN COOiU 1 LA W rill<.. ~ SbK V lCb ::IJ l~vJ.dl Fluut SUv~L I&mislnl'g,1>A 17101 (711)2,32-7'336 ~. ~. ~~ {);>>Oc..I~---hG~ ~ J...,i€dy /)LE- CaI2Ls-l€( M /7ol3 .;('19- J If.. b - I ~. ..u, , "" ,. .,'$0'-' I ~ .. TERRY LEE SHOEMAKER Plaintiff VS. :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA b1J _ "70S' :NO: 846 S 1999 TINA KAY SHOEMAKER Defendant : CIVIL ACTION-LAW :IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Terry Lee Shoemaker, residing at 153 Birdshill Rd., Pine Grove, Schuylkill County, Pennsylvania 17963. 2. The Defendant is Tina Shoemaker, residing at 11 Maurice Rd., Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 3. The Plaintiff seeks physical and legal custody of the following children: Name: Ashley Ann Shoemaker Date of Birth: October 1, 1985 Name: Alysia Shoemaker Date of Birth: February 4, 1993 4. The child was not born out of wedlock. 5. The children are presently in the cusotdy of the mother. 6. For the past five years the children have resided with both parents at 11 Maurice Rd, Mt. Holly Springs, Pa 17065. 7. The mother of the child is the Defendant. 8. The Father of the child is the Plaintiff. 9. The relationship of the Plaintiff to the child is that of the father. 10. The relationship of the Defendant to the child is that of the mother. 11. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning custody of the children in this or another court. ,', .'." Ilf "r,-.w<:.:',; 12. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 13. The best interest and permanent welfare of the children will be served by granting primary physical custody to the Plaintiff, Terry Shoemaker. 14. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, the Plaintiff, Terry Shoemaker respectfully requests this Honorable Court grant physical and legal custody of the minor children, Ashley and Alysia to him. V~ -. :l -~~ . , ~d"j~,,! . . TERRYLEESHOE~R Plaintiff :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY ,PENNSYLVANIA VS. :NO: 846-S-1999 TINA KAY SHOE~R Defendant :CIVIL ACTION-LAW :IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on the 'dr#-. day of ~k,yyhcr , 2000, I served by first class mail, restricted delivery return receipt requested, a copy of the Plaintiff's Complaint upon the person named below as well as an additional custody by U.S. first class mail, postage prepaid, in accordance with the applicable Rules of Procedure, addressed as follows: Tina Kay Shoemaker 11 Maurice Rd. Mt. Holly Springs, Pa 17065 R. Eric Pierce, Esquire PO Box 775 Hershey, Pa 17033 ryan S. Walk Attorney ill No. 63881 108-112 Walnut Street Harrisburg,PA 17101 (717) 238-5113 Counsel for Plaintiff ,," ~~ . 1. ~ ' ~ ~ ' . "~~ ,. "I~'-' , VERIFICATION I verify that the 'statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904, relating to unsworn falsification to authorities. Date: ~rq/rJrJ ~1~/L .d~~~,.-~"_I ".1 ~ ~ .1.-. "~,,'i , NOV 2 2: 200~ I' TERRY LEE SHOEMAKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-6705 TINA KAY SHOEMAKER, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this <'2,..'1- day of ~ ~ , 2000, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody: The parties, Terry Lee Shoemaker and Tina Kay Shoemaker, shall have shared legal' custody of the minor Children, Ashley Ann Shoemaker, born October 1, 1985, and Alysia Shoemaker, born February 4, 1993. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regardin~l their health, education and religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time .as to make the records and information of reasonable use to the other parent. 2. Physical Custody: The Mother shall have primary physical custody of the minor Children. Father shall have partial physical custody as follows: A. November 17,2000, from 9:00 p.m. until November 19, 2000, until he returns the Children between 8:00 p.m. and 9:00 p.m. B. Effective November 24, 2000, Father shall have alternating weekends from Friday at 9:00 p.m. until he returns the Children between 8:00 p.m. and 9:00 p.m. on Sundays. 3. Holidays: A. Mother's Day and Father's Day: Mother's Day weekend shall be with Mother and Father's Day weekend shall be with Father. This plan shall supercede the alternating weekend schedule if necessary. ,1'- ~ '" .';-';:> ,~,.:-:,,' , '.'~, ,",,' r~ or No. 00-6705 B. Thanksgiving: Custody for the Thanksgiving holiday 2000 shall be arranged as follows: Mother shall have physical custody from Thanksgiving eve until Friday, November 24, 2000, at 9:00 p.m. Father shall have custody from 9:00 p.m. on Friday, November 24, 2000, until he returns the Children between 8:00 p.m. and 9:00 p.m. on November 26, 2000. C. Christmas 2000: Father shall have custody for Christmas from December 22nd at 9:00 p.m. until December 24th at 4:00 p.m., at which time he will return the Children to their Mother. D. New Year's Eve 2000 and New Year's Dav 2001: Mother shall have physical custody for this holiday time. 4. If either party is going to be away from their home overnight during their period of custody, that party will provide the other parent with the phone number where they can be reached for that period of custody. 5. This Order is temporary in nature. The parties have agreed to attend a second Conciliation Conference. The Conciliation Conference shall reconvene at 11 :00 a.m. on January 16, 2001 at the offices of Melissa Peel Greevy, Esquire 214 Senate Avenue Suite 105 Camp Hill, Pennsylvania. Dist Brian S. Walk, Esquire, 108-112 Walnut Street, Harrisburg, PA 17101 R. Eric Pierce, Esquire, PO Box 775, Hershey, PA 17033 J .;} f' -^~,p~ 0 ~ ay- \ \' ?:-I).' D ~ . '" t( . ,__"~,,~. .il~r; r;:rw,..... ~ ~ ~' .".~:ltH'l \~, /,\ \ i :) ') \" _0.._ 'l' '?Lc .:-' (.' "--ll'rfY "-"'1 1',/ ,,:,:':"':':", j"i<U ulJ )\~ Vvl,i";:';:-'-"I'\i','!\n,' Pd~N~lL:,,\l ,1(\ . ;tL__,<.,~, "_. ""."< ~. ~"~,.,,.,,..,~~~1""t'Pi''';I[~~i#--'l;~~~I~~.,,,,~,,~,,'!rJ!lJ, ,~, p"llf:N~" ~)', .,,,,.1 ,~<~ , "~I,~ I~ ~..' ' ,. ',j ."-' , ",J,",_ ,",,' S''i'l,: , TERRY LEE SHOEMAKER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-6705 TINA KAY SHOEMAKER, Defendant CIVIL ACTION - LAW CUSTODY 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 Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF: Ashley Ann Shoemaker Alysia Shoemaker October 1, 1985 February 4, 1993 Mother Mother 2. A Custody Conciliation Conference was held on November 8, 2000, with the following individuals in attendance: the Father, Terry Lee Shoemaker, and his counsel, Brian S. Walk, Esquire; the Mother, Tina Kay Shoemaker, and her counsel, R. Eric Pierce, Esquire. 3. The parties reached an agreement with regard to a temporary Order in the form as attached. //-/1- ~ Me i eel Greevy, Esquire Custody Conciliator Date ,.dloilil_'~ I~" ", . .~ .'"" <". d/~,,',. .J '''"" ".""'~' . ;'--'1 "':, , , MAR 2 2 2001!9t' TERRY LEE SHOEMAKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-6705 TINA KAY SHOEMAKER, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT BAYLEY, J., MARCH _,2001 AND NOW, this 2-1 day of March, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Terry Lee Shoemaker and Tina Kay Shoemaker, shall have shared legal custody of the minor Children, Ashley Ann Shoemaker, born October 1, 1985, and Alysia Shoemaker, born February 4, 1993. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regardin~1 their health, education and religion. Pursuant to the terms of Pa. C. S.g5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable USH to the other parent. 2. Physical Custody. Mother shall have primary physical custody of the minor Children. Father shall have partial physical custody on alternating weekends from Friday at 9:00 p.m. until he returns the Children between 8:00 p.m. and 9:00 p.m. on Sundays. 3. Holidays. A. Mother's Day/Father's Day. Mother's Day weekend shall be with Mother and Father's Day weekend shall be with Father. This plan shall supercede the alternating weekend schedule if necessary. lm~" L.~ 1.,,<,,; ., ,,' , ;, ~'>"~. , , No. 00-6705 B. The parties shall share the following holidays: 1. Easter 2. Memorial Day 3. Labor Day 4. Thanksgiving 5. Christmas 6. New Year's Eve/New Year's Day In odd-numbered years, Father has the odd-numbered holidays and Mother has the even-numbered holidays. In even-numbered years, Mother has the odd-numbered holidays and Father has the even- numbered holidays. In the event that Father does not have to work on Easter Monday, he will return the Children at 6:00 p.m. on Easter Monday. In the event that Father is working on Easter Monday, he shall return the Children between 8:00 p.m. and 9:00 p.m. on Easter Sunday. The holiday schedule shall supercede the regular schedule. 4. In the event that either party is going to be away from their home overnight during their period of custody, that party will provide the other parent with the phone number where they can be reached during that period of custody. 5. Birthdays. Birthdays will be celebrated on the next custodial weekend without regard to the actual date of the child's birth. 6. Compensatory Time. The parties shall be allowed to trade custodial weekends without regard to the alternating weekend schedule when circumstances such as illness or important social events for the Children occur. The parties shall provide each other with notic:e as early as possible of any potentially needed changes in the Children's custodial schedule. Neither party shall schedule activities for the Children during the other parent's custodial weekend. 7. The Children shall not be used as a means of communication between the parents. When all possible the parents shall communicate directly with each other regarding the Children. 8. Mother shall provide a copy of Ashley's schedule to Father. j'''' l-",,<o~ J~ ~ ," '",,>,,' '.'1'~~' . , No. 00-6705 9. Summer. Each parent shall be entitled to up to two weeks, non-consecutive, to commence with the vacationing parent's custodial weekend. The parties shall provide each other with at least a thirty-day written notice, and address and telephone number where they can be reached during the vacation period. There shall be telephone contact on alternating days between the Children and the non-vacationing parent. For the summer of 2001, neither parent shall have their vacation during the period of June 18 through July 13, 2001, due to Ashley's attendance in summer school. 10. The parties are directed to attend the Seminar for Separating Families as provided by Inner Works. The parties shall, through counsel, provide each other with certificates indicating the completion of this parent education seminar. Edgar B. Bayley, J. BY THE COURT, Dist Brian S. Walk, Esquire, 108-112 Walnut Street, Harrisburg, PA 17101 R. Eric Pierce, Esquire, PO Box 775, Hershey, PA 17033 .~ O .0. \ ,yO ~ ?>'?:. ,I:, D ~\'\ \ . ~,..,.,,~ ,~ "-ijIl-.- IlJi!!IfI ", I!-.~, ~ .. cr "', ,<....,-~ :Gc ''':i';:'-lf^RV -.,' 1, I 0'/"""''' J '''i.f". , .. "'!\ t"..: "" 10 iU'i ' : 49 \.""1 I! ~ I'"~ .- " ' I '\;i",',C;c---,,;:r "''''''U' NTY Pr' ','-;,..;,' ,U \-,U .- !". 11111' I ,--Ni\j~YL\f-\I\"A ~~~'~fi;'l0J-;:'!;)'<l"l\li-'i]''""'"'''!~~~!ifu:~ijll''~';<!I'':!;~--''l!1!~~'''-@l'i1~j>i"'Mr"j"~1i'cm~ ]. ~,~r~":"",,,! ',Qd_~ . ~ ~ I.~ >I- '. I ,"" .'~"r_', L ,. .' ,,, ". ,:" ~"<:~ ,~;., ~ :,> . , TERRY LEE SHOEMAKER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-6705 TINA KAY SHOEMAKER, Defendant CIVIL ACTION - LAW CUSTODY 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 Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY Of Ashley Ann Shoemaker Alysia Shoemaker October 1, 1985 February 4, 1993 Mother Mother 2. A Custody Conciliation Conference was held on March 5, 2001, with the following individuals in attendance: the Father, Terry Lee Shoemaker, and his counsel, Brian S. Walk, Esquire; the Mother, Tina Kay Shoemaker, and her counsel, R. Eric Pierce, Esquire; 3. The parties reached an agreement in the form of an Order as attached. ",re d/d;/D! LfJ.!:!k1::::::' Custody Conciliator ,"~ , ' ,'. '~ '- I, ~ .' ~~~ ',;.;;, ,"- ';.' - "'olt,. , TINA KAY SHOEMAKER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. No. 00-6705 TERRY LEE SHOEMAKER, Defendant CIVIL ACTION - DIVORCE RULE TO SHOW CAUSE WHY BIFIJRCA TION SHOULD NOT BE GRANTED AND NOW, This ---.9h- day of April, 2001, upon the consideration of the Defendant's Motion For Bifurcation, a Rule is granted on the Plaintiff, Tina K. Shoemaker, to show cause why the Motion For Bifurcation should not be granted. RULE RETURNABLE ~O DAYS AFTER SERVICE. BY THE COURT: ...------ / ~J. .~ ,~. \! l~ >if ( 11lI ,. '.." T, Q i fJ'r: -9 {:,j'j in: :S9 C'u'":,c,.,, < l ,"'" 'fl!'I'v lV.L;-..J .Lr-" ),./"0 '. I PENNSYLVANIA " ,_."""".. ~ ,0_~' ,"C_"k ~ ,~<-,;,,, ",,~ '" ~'~",-"" '-'" ,,'" ,< "".JI!IIII!!II!l,. "" .11I1,"'....-, . "-""""'" "",l.. t1!'m1r pgr u ~~!il~"C __._~ ~ . .""-~~')lf_ ''_---.''-_-." , _, J1JJlll~~_~i.~_[fI: l"W"""", ~ '~',~ , -j " a," ~>, .. "1" ,;.-' ~-- ';" " - , , .~ ; -""-Cd' ~ ;,:"-;l; ,-_--'.~- : ""-Mit: '. .' TINA KAY SHOEMAKER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. No. 00-6705 TERRY LEE SHOEMAKER Defendant CIVIL ACTION - DIVORCE MOTION FOR BWURCATION NOW COMES, the Plaintiff, Terry L. Shoemaker, by and through his attorney, Bryan S, Walk, Esquire and filed this Motion for Bifurcation, and in support the following is averred: I, Plaintiff, Tina K Shoemaker, resides at II MauriceRoad, Mt Holly Springs, Cumberland County, Pa, 17065. The Plaintiff is represented by R Eric Pierce, Esquire, 2, Defendant, Terry L. Shoemaker, resides at 153 Birdshil1 Road, Pine Grove, Schuykill County, Pa 17963, 3, On April 27, 1999, the Plaintiff initiated this divorce action by filing his complaint seeking a divorce under section 330lc and d of the Divorce Code. 4. The Parties have been separated in excess of two years, 5, When the dlvorce action was initially filed, the Defendant was led to believe that the Plaintiff would consent to the entry of a divorce and that all economic issues between the parties would be resolved through a marital settlement agreement, However, as of this date an agreement has not been reached. 6, Given the lack of progress and the fact that the Defendant has been led to believe that an agreement cannot be reached, it is believed that the ultimate resolution of the parties' , , I,' - 1,,--- ~'" I ~ -,' ""') --.' "n,'."" ",c.,.,;o.:;" -,' -r-----.~'.T . respective equitable distribution issues will possibly, by necessity or design, be protracted for several more weeks or months, 7, Since the parties' marriage is irretrievably broken under section 3301c of the Divorce Code and the parties' respective economic claims have ben preserved through Count II of the Plaintiff's Complaint which seeks equitable distribution of marital assets, neither party will be prejudiced if a divorce is granted to the Plaintiff prior to the adjudication of the property and economic issues claims as the Court can expressly so provide in its Decree under section 3503 of the Divorce Code, 8, The Plaintiff desires to restructure and move on with her life without having to be held hostage to a marriage that has been dead for over two years while all of the equitable distribution issues are litigated. Moreover, the inunediate entry of a divorce decree will not adversely affect the property rights of either party, 9, Pursuant to section 3503 of The Divorce Code, this Court has the power to grant a divorce to the Plaintiff and to reserve jurisdiction over the remaining ancillary claims of either party, WHEREFORE, Terry L. Shoemaker, respectfully requests this Honorable Court to issue an order permitting the above captioned action to be bifurcated for the purpose of the equitable distribution issues between the parties over which This Court shall retain jurisdiction, Respectfully Submitted, Dated: t;J-2-o; , 1irh/~ Ban. Walk 1 08-112 Walnut Street Harrisburg, PA 17101 (717) 238-5113 Counsel for Plaintiff ~ - . ~ , "~; . VERWICATION I verifY that the statements made herein are true and correct I understand that false statements herein are made subject to the penalties of 18 Pa, c.S. S4904, relating to unsworn falsification to authorities, Date:g- J-Q ) ~~/#l./1 Te L Shoemaker / / ~,Q\]""==~" >= ~ I 'l'~""'i CERTIFICATE OF SERVICE I hereby certifY that on this :3 ru Day of April, 2001, A copy of the foregoing was served upon the person named below, in accordance with the applicable Rules of Procedure, addressed as follows: R Eric Pierce, Esquire 73 Cedar Avenue Hershey, Pa 17033 ~/?0d~ BanS, Walk Attorney ill No, 63881 108-112 Walnut Street Harrisburg,PAl7101 (717) 238-5113 "'~~ti.l~!'!!~ ~,"~'~, .",;- -....~:~il';~"'~I~;"';J~~'~lljlJl..-m~:..,,;. i - ~. -,~~- .' ,~-~':~; ...., ""... .... wtlllfiC.J ''"'lili' ,-_","=>"'-,'''''''~''h''','',-,,' ",,,, 0 C:;l " S; ~"j -n J:~ " ;:R ~-;~ '," ;::: -- ;':0 .- 7 r"--- -;-, C/) '" J ~ (::) :r;: .'.U (:-~.. :::1.' , ('C ~ C) --::;f'l"l >- <= ,~ ," :2 Ul )::; ..-\ :::0 .-< (,.-1- ,< '"