HomeMy WebLinkAbout00-07449
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MARK WILLIAMSON,
Plaintiff
IN mE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANlA
v
Docket No, 0C)- 744- q ~I\)'l \
VIRGINIA Fox,
Defendant
IN EQUITY
ORDER
AND NOW, this _ day of October 2000, upon consideration of Petitioner's
Complaint for Injunctive Relief, and after a review of the record in this matter, it is hereby
ORDERED that Respondent Virginia Fox's petition for modification of a support order filed in
Cumberland County Domestic Relations Section Docket No, 240 S 1987, P ACSES Case No,
888000025 is hereby DISMISSED with prejudice, and it is further ORDERED that Defendant
Virginia Fox shall not file a petition for modification of the support order until a date that is three
years from the date of the parties' August 31, 1999 consent agreement, as that agreement was
incorporated into this Court's Order dated September 7, 1999,
BY THE COURT:
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MARK Wrr.LIAMSON,
Plaintiff
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V AN1A
v
Docket No. ()O - 7449 E' ~~'ty
IN EQUITY
VIRGINIA Fox,
Defendant
COMPLAINT FOR INJUNCTIVE RELIEF
AND, NOW, comes the Plaintiff, Mark Williamson, by and through his
attorney, Richard C. Gaffney, Esquire, who files the within Petition for Injunctive Relief
and who, in support thereof, states as follows:
1. Plaintiff Mark Williamson is an adult individual residing at 9207 Stephanie Street,
Manassas Park, Commonwealth of Virginia 20111.
2. Defendant Virginia Fox is an adult individual residing at 320 East North Street,
Carlisle, Commonwealth of Pennsylvania 17013.
3, On August 31, 1999, as part of a consent Order for support, Plaintiff and
Defendant entered into an indemnity agreement (the "Indemnity Agreement") that
provided, in relevant part that:
"[Plaintiff] agrees to pay to the [Defendant] and [Defendant] agrees
to accept [Plaintiff's] payment of $350.00 montWy in full
satisfaction of [Plaintiff's] obligation to pay support to [Defendant].
In order to provide a period or repose, [Defendant] and [Plaintiff]
mutually agree that neither of them will thereafter file a petition for
modification of support against the other for a period of at least
three (3) years following the date of this Agreement."
A copy of the Indemnity Agreement is attached hereto as Exhibit A.
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4, The Court of Common Pleas of Cumberland County, Pennsylvania incorporated
the Indemnity Agreement into an Order of Court dated September 7, 1999, A
copy of the Order of Court is attached hereto as Exhibit B,
5. From the date of the Indemnity Agreement to the present date, the Plaintiff has
performed fully under the terms of the Indemnity Agreement and the Court Order.
6, On August 11, 2000, the Defendant file a Petition for Modification of the Support
Order in Cumberland County Court of Common Pleas Docket No. 240 S 1987,
PACSES Case Number 888000025, A copy of the Defendant's Petition for
Modification is attached hereto as Exhibit C,
7. The Plaintiff has requested the Defendant to withdraw the Petition for
Modification. The Defendant has refused,
8. The Indemnity Agreement provides, in relevant part, that:
"(i)n the event of any breach or alleged breach of any of the terms of this
Agreement, then in that event, the breaching party will indemnifY and hold
harmless the non-breaching party from and against all damages, claims, suits,
actions, demands, and costs, including reasonable attorneys fees and court
costs, incurred by or suffered by the non-breaching party on account of the
breaching party's breach of this Agreement,"
9. Defendant breached the Indemnity Agreement with the Plaintiff in that she failed
to fully perform under the terms of the contract by filing a petition to modifY the
support order less than three (3) years from the date of the Indemnity Agreement.
10, lfthe domestic relations section hears the Defendant's petition, the Plaintiff will
suffer immediate and irreparable harm including, without limiting the generality
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of the foregoing, lost wages, travel costs, attorney's fees, and a possible increase
in the support order in an undetermined amount for an indefinite period of time.
11. Plaintiff's damages are not compensable at law.
12. Ifinjunctive relief to stay the domestic relations hearing is not granted, the
Plaintiff will suffer immediate and irreparable harm.
WHEREFORE, the Plaintiff prays this Honorable Court for injunctive relieffor a
DECREE staying the domestic relations proceeding in Cumberland County Court of
Common Pleas Docket No, 240 S 1987, P ACSES Case Number 888000025 until a date
that is three years from the date of the parties' agreement as it was ordered in this
Honorable Court's ORDER dated September 7, 1999. In the alternative, the Plaintiff
prays this Honorable Court for an ORDER dismissing with prejudice the Defendant's
Petition for Modification in Cumberland County Court of Common Pleas Docket No. 240
S 1987, PACSES Case Number 888000025, and for a DECREE finding the Defendant in
willful contempt of this Honorable Court's September 7,1999 ORDER.
Respectfully submitted,
Dated:2."? ocr. 20:0
LAW OFFICES OF RICHARD C, GAFFNEY
P,O, Box 627
10 1 Front Street
Boiling Springs, PA 17007-0627
Attorney for Plaintiff
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10/20/00 FRI 14:23 FAX 703 696 6626
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USAF CONY DIV
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MARK WILUAMSON,
Plaintiff
1N1lIE COURT OF COMMON PLEAS OF
CUMBERLAND COUNlY, PBNNSYL VANIA
v
Docket No.
VIR.GlNlA Fox,
Defendant
IN EQUllY
VIiRIFIC A TION
I. Mark Williamson, do hereby verify that the information provided in the
foregoing COMPLAINT FOR INJUNCTIVE RELIBF is true and correct to the best of my
knowledge, information and betief, and I understand that false statements herein are made
subject to the penalties of 18 Pa. Cons. Stat. ~4904 (relating to unsworn falsifications).
DATE: IJ'''I>/'1l
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Mark Williamson
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MARK WILLIAMSON,
Plaintiff
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLV ANlA
v
Docket No.
VlRGINIAFox,
Defendant
IN EQUITY
CERTIFICATE OF SERVICE
I, the undersigned counsel, certity that on October 23, 2000, I served a true and
correct copy of the foregoing Complaint for Injunctive Relief on the Respondent via
United States Certified Mail, Return Receipt Requested, postage prepaid, at the following
address:
Virginia A. Fox
320 East North Street
Carlisle, PA 17013
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AGREEMENT
This AGREEMENT is made effective as of this 3<> day of August 1999 by and
between Mark Williamson, an adult individual residing at 6232-L Ridge Pond Road,
Centreville, Virginia 20121 ("Father") and Virginia A. Fox, an adult individual residing
at 320 East North Street, Carlisle, Pennsylvania 17013 ("Mother").
WHEREAS, Father is obligated to pay support to Mother in an amount of$258.00
monthly for support of their daughter, Jessica A. Williamson ("Daughter"); and
WHEREAS, on August 17, 1999, Mother filed a Petition for Modification of an
Existing Support Order in the Court of Common Pleas of Cumberland County;
Pennsylvania Domestic Relations Section in Docket No. 240 S 1987, P ACSES Case
Number 888000025 (the "Petition"); and
WHEREAS, Mother and Father both desire to avoid the expense and uncertainty
involved with litigation; and
WHEREAS, Mother and Father have reached an agreement as to the amount of
support which Father will pay Mother for the support of Daughter.
NOW, THEREFORE, in consideration of the premises and mutual covenants
contained herein and intending to be legally bound, Mother and Father agree as follows:
1. Beginning on September 1, 1999 and continuing each and every month thereafter,
Father will pay to Mother an amount of$350.00 monthly for support of Daughter.
Father will make monthly payments by the first day of each and every month.
2. Mother agrees to accept Father's payment of$350.00 monthly in full satisfaction of
Father's obligation to pay support to Mother.
3. Mother shall withdraw the Petition with prejudice by Praecipe to Discontinue the
action pursuant to Pa.R.Civ.P. Rule 229.
4. In order to provide a period of repose, Mother and Father mutually agree that neither
of them will thereafter file any petition for modification of support against the other
for a period of at least three (3) years following the date of this Agreement.
;, Mother and Father mutually agree and covenant that in the event of any breach or
alleged breach of any of the terms of this Agreement, then in that event, the breaching
party will indemnify and hold harmless the non-breaching party from and against all
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damages, claims, suits, actions, demands, and costs, including reasonable attorneys
fees and court costs, incurred by or suffered by the non-breaching party on account of
the breaching party's breach of this Agreement.
6. This Agreement contains the entire agreement of the parties with respect to the
subject matter hereof. All prior agreements, contracts and understandings of the
parties with respect to the subject matter hereof are merged into this Agreement. No
modification of this Agreement shall be valid or enforceable unless made in a writing
signed by the party against whom enforcement is sought.
7. This Agreement shall be interpreted under the laws of the Commonwealth of
Pennsylvania. Enforcement of any provision of this Agreement may be made in any
court of competent jurisdiction.
WHEREFORE, intending to be legally bound thereby, the parties hereto set their
hands and seals on the day and month first above written.
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Vir a Fox (Mother)
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COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OF CUMBERLAND
On this, the 317;tl day of ~.~.. -:I- , 1999, before me, a Notary Public the
undersigned officer, personally appeared Mark Williamson, known to me (or satisfactorily
proven) to be the person whose name is subscribed to the within instrument, and acknowledged
that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal.
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NOTARIAL SEAL' ,: \)'
PATRICIA A SHATTO, NOlityP~tik
Carlisle Boro, Cumberland County
My Commission Expires December 17, 2001
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
On this, the 3od. day of ~~r
, 1999, before me, a Notary Public the
undersigned officer, personally appeared Virginia Fox, known to me (or satisfactorily proven) to
be the person whose name is subscribed to the within instrument, and acknowledged that she
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereuntosetmy,hand and notarial seal.
--W~A~
NOTARY PUBLIC
NOTARIAL SEAL
PATRICIA A, SHATTO, Notary Public
CarllsleBoro, Cumberland County
My Commission Expires December17, 2001
DOMESTIC RELATIONS SECTION
P.O. BOX 320
CARLISLE PA 17013
RICHARD C GAFFNEY, II
PO BOX 627
BOILING SPRINGS PA 17007-0627-27
Generi.: Address Sheet
Service Type M
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Form CM-521
Worker ill 21105
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In the Court of Common Pleas of CUMBERLAND County, Peunsylv~ia
DOMESTIC RELATIONS SECTION
VIRGINIA A. FOX ) Order Number 240 S 1987
Plaintiff )
vs. ) PACSES Case Number 888000025
MARK WILLIAMSON ) Docket Number 240 S 1987
Defendant ) Other State ID Number J~Jo7
ORDER OF COURT
o Final 0 Interim (i) Modified
AND NOW, 7TH DAY OF SEPTEMBER, 1999 ,based upon the Court's
determination that the Payee's monthly net income is $ N/A
and the Payor's
monthly net income is $ N/A
, it is hereby ordered that the Payor pay to the
Pennsylvania State Collection and Disbursement Unit
THREE HUNDRED AND FIFTY
Dollars ($ 350.00
) a month payable
MONTHLY
as follows: first payment due
N/A, PAYMENTS DUE BY THE FIRST OF EACH MONTH.
The effective date of the order is 09/01/99 .
Arrears set at $ o. 00
as of SEPTEMBER 7, 1999 are due in full
IMMEDIATELY. All terms of this Order are subject to collection and/or enforcement by
contempt proceedings, credit bureau reporting and tax refund offset certification and will not
be initiated as long as obligor does not owe overdue support. Failure to make each payment on
time and in full will cause all arrears to become subject to immediate collection by all the
means listed above.
.For the Support of:
Name
JESSICA WILLIAMSON
Birth Date
07/23/86
Service Type M
Exhibit B
Form OE-518
Worker ID 21105
FOX
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v. WILLIAMSON
PACSES Case Number: 888000025
The defendant owes a total of $ 350.00
MONTHLY
$350.00
per month payable
for current support and $ 0 . 00
for arrears. The defendant must
also pay feeslcosts as indicated below. This order is allocated and monies are to be applied as
follows:
Frequency Codes:
Payment Amountl
FrPiluem:y
$ 350.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
1 =000 Time B =BiWeekly 2 =Bi-Monthly M =Monthly
5 =Semi-Annually S =Semi-Monthly A =AnnuaJly W =Weekly
Q = Quarterly
n~ht TJ{Pe ne!ii:c:nptinn
Renefir.1:1ry
1M CHILD SPT ALLOe JESSICA WILLIAMSON
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Said money to be turned over by the Pa SCDU to:
VIRGINIA A. FOX
. Payments must be made by check or
money order, All checks and money orders must be made payable to Pa SCDU and mailed to:
Pa SCDU
P.O. Box 69110
Harrisburg, Pa 17106-9110
Payments must include the defendant's PACSES Member Number or Social Security Number
in order to be processed, Do not send cash by mail.
Service Type M
Page 2 of4
Form OE-518
Worker ID 21105
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FOX
v. WILLIAMSON
PACSES Case Number: 888.00002!i
Unreimbursed medical expenses that exceed $250.00 annually per child andlor spouse
are to be paid as follows: 50 % by defendant and 50 % by plaintiff. The plaintiff is
responsible to pay the first $250.00 annually (per child and/or spouse) in unreimbursed
medical expenses, ~ DefendantO Plaintiff 0 Neither party to provide medical insurance
coverage. Within thirty (30) days after the entry of this order, the 0 Plaintiff
~ Defendant shall submit to the person having custody of the child(ren) written proof that
medical insurance coverage has been obtained or that application for coverage has been made.
Proof of coverage shall consist, at a minimum, of: 1) the name of the health care coverage
provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage;
4) the address to which claims should be made; 5) a description of any restrictions on usage,
such as prior approval for hospital admissions, and the manner of obtaining approval;
6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and
co-payments; and 8) five copies of any claim forms.
Other Conditions:
ORDER IS BY STIPULATION AND AGREEMENT OF THE PARTIES.
SHOULD THE DEFENDANT DEVELOP AN ARREARAGE IN EXCESS OF ONE MONTH'S SUPPORT
OBLIGATION. A WAGE ATTACHMENT WILL BE ISSUED TO HIS EMPLOYER AND THE SUM OF
$25 PER MONTH WILL BE ADDED FOR COLLECTION OF ARREARS.
THE ATTACHED AGREEMENT IS INCORPORATED HEREIN BY REFERENCE.
THE CONFERENCE SCHEDULED FOR SEPTEMBER 8. 1999. AT 9 AM IS CANCELLED .
Defendant shall pay the following fees:
Fee Total
$ 0.00
$ 0 .00
$ 0.00
$ 0.00
$ 0.00
Fee Description
P.l\Yment Freql1ency
Payable at $ 0.00
Payable at $ 0.00
Payable at $ 0.00
Payable at $ 0.00
Payable at $ 0.00
per
per
for
for
for
for
for
per
per
per
Page 3 of 4
Form OE-518
Worker ID 21105
Service Type M
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FOX
v. WILLIAMSON
PACSES Case Number: 888000025
IMPORTANT LEGAL NOTICE
PARTIES MUST WITHIN SEVEN DAYS INFORM THE DOMESTIC RELATIONS SECTION AND
THE OTHER PARTIES, IN WRITING, OF ANY MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT
TO THE LEVEL OF SUPPORT OR THE ADMINISTRATION OF THE SUPPORT ORDER, INCLUDING,
BUT NOT LIMITED TO, LOSS OR CHANGE OF INCOME OR EMPLOYMENT AND CHANGE OF
PERSONAL ADDRESS OR CHANGE OF ADDRESS OF ANY CHILD RECEIVING SUPPORT. A PARTY
WHO WILLFUUY FAILS TO REPORT A MATERIAL CHANGE IN CIRCUMSTANCES MAY BE ADJUDGED IN
CONTEMPT OF COURT, AND MAY BE FINED OR IMPRISONED,
PENNSYLVANIA LAW PROVIDES THAT ALL SUPPORT ORDERS SHALL BE REVIEWED AT LEAST
ONCE EVERY THREE (3) YEARS IF SUCH REVIEW IS REQUESTED BY ONE OF THE PARTIES. IF
YOU WISH TO REQUEST A REVIEW AND ADJUSTMENT OF YOUR ORDER, YOU MUST DO THE
FOLLOWING: CALL YOUR ATIORNEY, AN UNREPRESENTED PERSON WHO WANTS TO MODIFY
(ADJUST) A SUPPORT ORDER SHOULD CONTACT THE DOMESTIC RELATIONS SECTION.
A MANDATORY INCOME ATIACHMENT WILL ISSUE UNLESS THE DEFENDANT IS NOT IN
ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO OR GREATER THAN ONE MONTH'S SUPPORT
OBLIGATION AND (1) THE COURT FINDS THAT THERE IS GOOD CAUSE NOT TO REQUIRE
IMMEDIATE INCOME WITHHOLDING; OR (2) A WRI'ITEN AGREEMENT IS REACHED BETWEEN
THE PARTIES WHICH PROVIDES FOR AN ALTERNATE ARRANGEMENT.
UNPAID ARREARAGE BALANCES MAY BE REPORTED TO CREDIT AGENCIES. ON AND
AFTER THE DATE IT IS DUE, EACH UNPAID SUPPORT PAYMENT SHALL CONSTITUTE, BY
OPERATION OF LAW, A JUDGMENT AGAINST YOU, AS WELL AS A LIEN AGAINST REAL
PROPERTY .
IT IS FURTHER ORDERED that, upon payor's failure to comply with this order, payor may be
arrested and brought before the Court for a Contempt hearing; payor's wages, salary,
commissions, andlor income may be attached in accordance with law; this Order will be
increased without further hearing by 0 % a month until all arrearages are paid in full. Payor
is responsible for court costs and fees.
Copies delivered to parties
Date
Consented:
Plaintiff's Attorney
Plaintiff
Defendant's Attorney
Defendant
ORO:
ce:
ee:
Melissa S. Heckard
Plaintiff & Defendant
Richatd Gaffney II, ESQ.
1iervlce Type M
BY THE COURT:
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Judge
Form OE-5I8
Worker ID 21105
09/28/00 TBU 14:32 FAX 703 896 8828
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USAF CONV DIV
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In the Court of COJlllllon Pleas of . CllMBERLAND
DOMESTIC RELA1'IONS SECTION
Connty, Peunsyl'fania .
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VIRGINIA A, FOX ) Docket Number 240 S 1987
PJaimiff )
V5. ) PACSES Case N\ll1l~r 888000025
MARX WILLIAMSON )
Defendant ) Oth<!:r Slate ID Num~r
PETITION FOR MODmCATION
OF AN EXISTING SUPPORT ORDER
1. The petition of
VIRGINIA A. FOX
respectfully
represents that on JULY 1, 1988
support of
JESSICA WILLIAMSON
, an Order of Court was entered for the
A true and correct copy of the order is attached to tbis petition.
Exhibit C
Service Type 114
Fonn OM-501
Wodcer ID 21105
09/28/00 THU 14:32 FAX 703 896 8826
lTSAF CONY DIV
,002
FOX
v, WILLIAMSON
PACSES Case Number: 888000025
2. Petitioner is entitled to Ci) increase 0 decrease 0 termination 0 reinstatement
o other of this Order because of the following material and substantial change(s) in
circumstance:
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WHEREFORE, Petitioner requests that the Coun modify the existing order for suppon.
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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. e.s. ~ 4904 relating to
unsworn falsification to authorities.
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Page 2 of 2
Form OM-SOl
Worker ID 21105
Service Type M
09/28/00 TBlT 14:33 FAX 703 696 8828
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USAF CONY DIV
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In the Court of Common Pleas of . CUMBERLAND County, Pennsylvania .
DOMESl1C RELATIONS SECTJON
VIRGINIA A. FOX ) Docket Number 24.0 S 1981
Plaintiff )
VS. ) PACSES CaM: Number 888000025 I 14,307
MIlRK WILLiAMsoN )
Dekndanl ) Other Slate ID Number
ORDER OF COURT - APPEAR AT A MODIF1CATION CONFERENCE
o Initial Conference
Gl Rescheduled Conference
You,
MIlRK WJ:LLIAMSON
, Respondent have been sued
in Court to modify an existing support order. You,
MARX WILt.IAMSON
Respondem, and You,
VIRGINIA A. FOX
Petitioner, are ordered to appear in penol1
at CUMBERIJlND co DRS
13 NORTH HANOVER STREET, ~ISLE, FA. 17013
on the :14TH DAY OF OCTOBER, 2000
at 9 : OOAM for a conference and remain umil
dismissed by the Coun. If the Petitioner of this action fails to appear as provided in this
Order. this petition may be dismissed. If the Respondem of this action fails to appear as
pr()videdili llils Order ,aif order for Modification may be entered against the Respondent.
You are ftiMer required to bring to the conference:
1. a true copy of your most recent Federoil Income Tax Return, including W.2II, as filed.
2. your pay S1Ubs for the pll'Ceding six (6) montbs,
3. the Income aud Expeuse Sl3teJDem attached 1Il1bis order as required by Rule 1910.11 (e).
4. verification of child care expenses, and
5. proof of medical coverage whith you may have, or may have available 10 you,
r.nnf~TAn~e will ~ held before Melissa S. Heokard
Service Type M
Form OM-S03
Worker ID 21203
09/28/00 TOO 14: 33 FAX 703 896 6828
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FOX
V. WILLIAMSON
P ACSES Case Numbc;r: 888000025"
THE EXISTING ORDER MAY BE MODIFIED OR TERMINATED IN ANY AI'PROPRlATE
MANNER BASED UPON THE EVIDENCE PRESENTED.
If you fail to appear for the conference or to bring the required documents. the
court may issue a warrant for your arrest or enter an order in your absence.
BY THE COURT:
Date of Order: Au~ust:]1 '000
Kevin A. Hess
JUDGE
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE
AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFOlU> ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU MAY GET LEGAL HELP:
CUMBEIlLAIlll CO BAR ASSOCIATION
2 LIBIlRn' AVE
CARLISLE PA 17013-3308-02
(7l7) 24~-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The CQUrt. of Common Pleas, of CUMBERLAND County is required by law to
comply with the Americans wit" Disabilities Act of 1990. For information about accessible
facilities and reasonable accommodati9ns available to disabled individuals having business
before !be coun, please contact our office at: (717) 240-6225. All arrangements must be
made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled conference.
Page 2 on
Form OM-503
Worker ID 21203
Service Type M
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MARK WILLIAMSON,
Plaintiff
v
VIRGINIA Fox,
Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Docket No. 00-7449 6iW. ~lA'rl-,/
CIVIL TERM
PRAECIPE TO DISCONTINUE
To the Prothonotary of the Said Court:
Pursuant to Pa.R.Civ,P, Rule 229, please discontinue the above captioned action.
DATE: \\)-2.4-=
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Richard C. Gaffuey, q
LAW OFFICES OF RICHARD C, GAFFNEY
P.O. Box 627
101 Front Street
Boiling Springs, PA 17007-0627
Attorney for Plaintiff, Mark Williamson
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