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Home My WebLink About01-1288 FX '., ',--,,-. 0',,'-," , ';.,i.",,' '", n.e ;c_ ,- _ ',_,'0.; " - '- -.' " -, --,,, ;,~._~ ;:i --:Ci">--'~;5<-_~~__"-"_ '_~ -",{' ,",;,,--',{: '--" ,,-,:,:_,-,,;~,;._:~ ;-,. :..''" -____ +_';'" .__,,' ,_ ,~ - o,:o,~;'; JOSJllJA W. PETIT, Plaintiff v. : IN TIIE COURT OF COMMON PLEAS OF : CUMBERlAND COUNTY, PENNSYLVANIA : NO. 01-/.<S".r CIVll.TERM NATALIE S. PETTY, Defendant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. I j , I , I , , 1 ,1 ;1 When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. 'I , , ;1 j :l 1 'I I ! IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. The Court of Common Pleas of Cumberland County is required by law to comply with the Americans With Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. YOU 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 ~ ~_ _,,_ "0 ~ "c 'v' '""" ~ ~''-''''~_ _, ."'f< ,. ~ .' ,__. __'" _~_,. -. ;,,,:"_,,,:__-,,~. ~, -,-";-"-.;i~,,,--'_,,'--,,.),;,' ",~<"-~" '."-,,, ",. ' '''- -';-~-":~1 JOSlRJA W. PETIT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERlAND COUNTY, PENNSYLVANIA v. . . : NO. 01- /.:? 'iJ't CIVIL TERM NATALIE S. PETIT, Defendant : IN DWORCE COMPLAINT IN DWORCE COUNT I - DWORCE 1. Plaintiff is JOSHUA W. PETrY, presently residing at 121 Third Street, Boiling Springs, Cumberland County, Pennsylvania, 17007. 2. Defendant is NATALIE S. PETrY, presently residing at 327 East Louther Street, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and defendant were married September 29,1998. 5. There have been no prior actions of divorce or for annulment between the parties in this or any other jurisdiction. 6. Neither party to this action in divorce is currently a member of the Armed Forces of the United States of America. 7. Plaintiff has been advised that counseling is available and that the plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. The marriage between the parties hereto is irretrievably broken. 9. Plaintiff requests the Court to enter a decree of divorce. 2 , .< . '-'. .._.. __ ___~' " - ,. c-' .~ ",,-<-_, _""':: ," ~ ,"~,;'i_.,',,'" ., - ..c'. _~_~ L'r.\'- '~o,.,;.:~, ' ~,~,,_.<. _._ "",- '~~'b"':: COUNT I I - EQUITABLE DISTRIBUllON 10. The parties are the owners of real and personal property subject to equitable distribution between them as marital property. 11. The parties have incurred obligations during their marriage that constitute marital debt. 12. Plaintiff requests the Court to equitably divide such items of marital property and debt between the parties. WHEREFORE, the Plaintiff requests this Court to: a. Enter a final Decree of Divorce divorcing the plaintiff from the defendant; and b. Grant equitable distribution of the marital property and debts of the parties; Respectfully submitted, 7~ Co( ~. " JACOBSEN & MILKES 52 E. High Street Carlisle, PA 17013 (717) 249-6427 (717) 249-8427 - Fax Attorney No. 30130 . ,',.~ - - , -~ , ---~" .__~^ ' ',',;_ , '0 ,-.'_'-;_, ,"'C-.o' ",,"-,~-;--." ;",'.,.---,--,-,' - - ~'-'-'<'~ .".~~'",." ,'-- "'-~-'d!f'::j . I hereby verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: Mv.rJ (n Job \ Jl~~, ~~, ~ JOSHUA W. PETTY ,,'r~-':-"" , ; '. ., , j ,~ ~k? ~ 't;> <;:,. '-.. ....., 'tI -<: "'1 -:) 1,,""' ",...." -. ~~"-, -= '.' ~"L:l.'-" ,C'.,' ,f ~~~""",,,'~"--:'- ",,_",,~....,,;' J, ,_,.,-~""_*u,__,_,",~ _J,~~ <, .'.oM," , .. ~ ~1I111"~' ,,~ ' .~' 'f-' 0.'<" '" .",,,,,"' 8 iB,~ ~::D 6.)>- -,<2: kO ),00 ~o ::i>':c: '~ o o j--l ~ -~ "'~ ::0 I ....J -0 :x N .. --' i~4~13 r- -om' .".n {.:s.l :;;9 ,wl-,+t 0= 2M ~ ~ -.t ~ ~ ~I \ F,:> :;1 ~ $ Y,I 'i:\ "<;II ," vi . ~l '-'\" 011 g ~\ ~ Lr-, I ~ i ~ I ~ \ t: t ~ G> ~ ~ '\ GS ~ , J'-" ',m,__,-"; "", ' ,,; .'i,.j,-'"",,, -" ;,,,,;_,-h;_,,,-,~,;,,',~_ "'''"'-0.-', """,-",l,,:', "" -" "",'. '__..,~~ JOSHUA W. PElTY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. . : NO. 01- I'd gg CIVIL TERM NATALIE S. PElTY, Defendant : IN DIVORCE WAIVER OF COUNSELING JOSHUA W. PETTY, Plaintiff herein, hereby states and certifies as follows: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court requITe that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not request that the Court requITe that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: ~...dr- G ]O{), ~4,~ JOSHUA W. PE ' , ~ ~,~....,,<-~~'P'lF- '-'-''''''""''- ~-, .,--"" . lli~~~\'k4l~~~~2J~~-'~ "~~. "-~", = . .'~~",,-~,"<=- ,.,".' ," .'_..'.,.-"",>", ~' '" -. -~- .,-,",""". -..'" ." """",,"" ~-~: - , -' .~ .~ ~ ~" (;) Q 0 C ~T1 s:: ::l!: -~~ ~ro ".. i~1iill ' g) = :z: f""' I ~gt9'-" en,>' -.J 22' 00. cJ ~-I ::;:: -0 f1~=H' " ~o :x '5'0 >8 ~ O\iT1 :z: N s;! ,~ w ::;0 -< B ~ ._u, . ~. ~ "" , -~ ;-, ._-, ,--e'."",,-,--,,-"" ""J__ ~_ ",,","," .-,-, "'-->." '", .';&i JOSIruA W. PETTY, Plaintiff v. IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- \JS8 CIVIL TERM NATALIE S. PETTY, Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Shelley Eichelberger, hereby certify that a true and correct copy of a Notice To Defend Rights and Claim Rights and a true and correct copy of a Complaint In Divorce Under Section 3301(c), was duly served for the Defendant, Natalie S. Petty, by a registered letter deposited in the U.S. Mail on March 7,2001, addressed as follows: Natalie S. Petty 327 East Louther Street Carlisle, PA 17013 And further that this attached card demonstrates that on March 8,2001, the Defendant was served. I hereby verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.s. Section 4904, relating to unsworn falsification to authorities. Date: 3/1 d) 01 ~~ ~rl~_~~ SHELLE ICHELBER R- '{ I U.S. postal Service . CERTIFIED MAIL RECEIPT (Domestic Mail OnlYi No Insurance Coverage Provided) [J"'" Aeturn Recslpt Fee CJ (Endorsem~_n~~~uln::d) Cl Aestricted Delivery Fee Cl (Endorsement Required) t::I _ Total postage & Fees ru ru JTl postage Jl =t' JTl IT' o:::I l"- U1 '"" CeFtif)!il.dFee Name (Please Print Clearly) (To be camp/arad by mailer) , ' ~ . ~ IT' ~~~~~~'iio.\2-g,\_\_'j-'---;-:c::'-'----~'---"---"---- IT' .3_2:1_.._.C;;_~.__h~,,",~u.:_._.;;;?_---_t..~::'S:_---_._-_., ~ CIty, Stat., ZIPt,\ \1 \) \ . Complete items 1, 2, and 3. Also complete item 4 if RestrIcted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailplece, or on the front if space permits. 1. Article Addressed to: f\o.-\-O_.\;e... ~, ~e..~ .~. 3 'dl. t::o.'s\- U::,\J.-\\-,<<J' .6\.~~k C-o-..('\.~s\e...\ ? A \, D\3 . nature x o. ]s delivery address different from item If YES, enter delivery address belo 3. Service Type JX:J Certified Mail jii:t RegIstered o Insured Mail o Express Mail ~ Return Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) )lev.. 2. Article Number ((;cpy from setvice label) ,o'1'13;:;rJboOOCJ\Si'i'>q3t.f C., PS Form 3811 , July 1999 Domestic Return Receipt 102595-QO.M.0952 >;;:llil~;.,;'; , ""'lii[".k~".. ':-. ',_"~c ~jO;:2F"'~- h'"_' c;;."'~'."h;'''''-_~~~'<' '" ".'--,~'- ,,~ ,~_^ ,., h___ "';;"'0'_"" -.---~" , " ,,- .-",~- ,,~- -- =-',-- " " .-,~~,- I I (') C "'" ~ff; - [T)n, ')" Z:T;J - ~.. 2'r-'. Wp. <. fSe {..) ~ ,~ -"j ~ '1 ~8 .-..!("') ..c- :--',f-n ~ ':::I ~ =< ::0 ''V "< ~ !@ ., 'C-1"d-. d- " h.-.Mi,'-i JOSHUA W. PETTY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA VI. NO. 01-1288 NATALIE S. PETTY, Defendant IN DIVORCE RULE TO SHOW CAUSE IN RE: PETITION TO WITHDRAW AS COUNSEL AND NOW, this E day of July, 2001, upon presentation and consideration of the Petition to Withdraw as Counsel, submitted by Samuel W. Milkes, counsel for the Plaintiff, a Rule is issued upon the Plaintiff and Defendant to show cause why Mr. Milkes should not be allowed to withdraw as counsel for Plaintiff in this divorce action. This Rule is returnable in 15 days, by which time either party must present reasons to the Court as to why he or she believes Mr. Milkes should not be allowed to withdraw as Plaintiff's attorney. If no valid reasons are presented, upon the issuing of a Rule Absolute, Mr. Milkes would be allowed to withdraw as counsel. Ifreasons are presented, the Court will determine whether they are sufficiently valid reasons to deny the Petition. J. ;r ~~ r~~~\ \:Y v t1; ,>0 I ~~- -, . "M ~' - '.^ ---,'.-,- -','.-- -"." f JOSHUA W. PETTY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. NO. 01-1288 NATALIE S. PETTY, Defendant IN DIVORCE PETITION TO WITHDRAW AS COUNSEL COMES NOW, counsel for the Plaintiff in the above matter, Samuel W. Milkes, Jacobsen & Milkes, and respectfully requests of this Honorable Court that he be allowed to withdraw as counsel for Plaintiff, for the reasons stated above: I. The undersigned counsel has accepted a position as Executive Director of Pennsylvania Legal Services in Harrisburg, Pennsylvania. 2. Funding source requirements dictate that this position is prohibited from engaging in the private practice oflaw. 3. Effective August 1, 200 I, counsel is prohibited from engaging in the private practice oflaw. 4. Counsel has discussed this with Plaintiff and Plaintiff has expressed a desire to represent himself and that he has no objection to counsel withdrawing from representing him. 5. While the Defendant has been represented by Thomas S. Diehl, Esq. in some matters involving custody and support between the parties, Mr. Diehl has not entered an appearance in the above action. - ',-'- ,'.;,' 1;,_ "-~ ~,- ~..>t.."' 6. This case has not yet been referred to the Divorce Master, nor has a request to do so been made. WHEREFORE, for the above reasons, Samuel W. Milkes respectfully requests of this Honorable Court that it grant him permission to withdraw as Plaintiff's counsel. Respectfully Submitted, {[~5l01 Samuel W. Milkes Jacobsen & Milkes 52 E. High Street Carlisle, PA 17013 7l7-249-6427 Attorney No. 30130 -.- , ,- -,,~ """'....f i!;l!~,::l' j JOSHUA W. PETTY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Vll. NO. 01-1288 NATALIE S. PETTY, Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Samuel W. Milkes, Jacobsen & Milkes, certify that on the 25th day of July, 2001, I served the attached Petition to withdraw as counsel in the above matter by placing a copy of the same in the United States mail, postage prepaid, and addressed to the following: Joshua W. Petty 18 E. Big Spring Avenue Newville, P A 17241 Natalie S. Petty 327 E. Louther Street Carlisle, P A 17013 WITH A COPY TO: Thomas S. Diehl, Esq. One West High Street P.O. Box 1290 Carlisle, P A 17013 Respectfully Submitted, 1 ~sio! Samuel W. Milkes Jacobsen & Milkes 52 E. High Street Carlisle, PA l7013 717-249-6427 Attorney No. 30130 n.: 'j'- ~,I~''';'1illf~~' ~"'tJ'm"~"->'" - _lIIim~;~~!r~";~l~!ii'~ ...:.ll-"""-,-k'''"-'.....'''''' .L _" ."~~ ~1~0l1"~~ ~~ II! ---'-" . ~ ~ _" 1'<" '-. -~'~"_'"I:..''-o__'__" -,-- =,' ,-- " "'" --;:, -c,>,," .,'-""d'M"O._ '.<' ;;,.'",', .'i., .'~" "~,' , -- , ,". .', -,;--"'. -'" ~'" ..... - -, ~, ;" .,1 " JOSHUA W. PETIY, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlY, PENNSYLVANIA NO. 01-1288 CML TERM NATALIE S. PETTY, Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Dana A. Dunkle, hereby certify that a true and correct copy of a Rule to Show Cause In Re: Petition to Withdraw as Counsel, was duly served upon counsel for the Defendant, Natalie S. Petty, by depositing it in the U. S. Mail, postage paid, on August 2, 2001, addressed as follows: Thomas S. Diehl One West High Street PO Box 1290 Carlisle, PA 17013 I hereby verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.e.S. Section 4904, relating to unsworn falsification to authorities. Date: CO\~\~ \ ~ -V\ ~~~4 DANA . DUNKLE . 0 c::' () c: "1"1 ~ "'" -oce c:: ~:.: cprrJ G) , .L- ~\,_' 1'-' 1----;"' 2T ,'J c7) C' ,~ I f -<~ ;-? r:;: c --I 'J , ~~ -~" (') -,.>-.. c~-) () -~ :> 0 ;,~~ rT~ c: -7 i"'V );l ~ (';:) ~ "",,-., . - , ~ ..", __0_ .- ' ,." ~, , -- ".,.~_ 'j' .." '.' ,. __'....r-:_...:.-"""~,lli~__"'.:-", ,~'__';,_-i,/' __ ><-.-. .c!..' ;";"'''"' ;':'~~,~, -; "n ',-,,', ",,"0" ,.'~.';~';' .. '.--", -- '" " . ""Il , ~ e , JOSHUA W. PETIY, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF , : CUMBERLAND COUNlY, PENNSYLVANIA NO. 01- 1288 CML TERM NATALIE S. PETTY, Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Dana A. Dunkle, hereby certify that a true and correct copy of a Rule to Show Cause In Re: Petition to Withdraw as Counsel, was duly served upon the Plaintiff, Joshua W. Petty, by depOSiting it in the U. S. Mail, postage paid, on August 2, 2001 , addressed as follows: Joshua W. Petty 18 East Big Spring Avenue Newville, PA 17241 I hereby verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: b \ 'd- \ 'd-OO ~ ~~A~ t,::;:.-" "'-;-~'-' \";~"--- > ,"~' , " '" ' .~"il,;..",.',,~-r~';_-'-i"~,;:';' " ",-;;;,-;. ,', "l;' , ,.-~..;_,,;--, .,';\ 0<:'.> .... . I. . ;;,__:;;h?;"'":"';;;"'_""'~.. "' ...", , !Ii ~.', ;',';' , ',;'" "~"',--'-'~,;;;-" .,"^ ..;c',,,,-y,, _, ' 1 0 a 0 C <1 :s: );70 -00._] G:; mrTi ":1f-: Z:r" r';) '],--:-, zc::' C:' (f),,:.;:' I -<.--:' r"~, ~Cj v ,~~b ~C) ~~;~~ -=c., :J>c: '''--1 Z 1'0 '" =< :0 0 -< ". , ~ " _~'lO " ''-'' . JOSHUA W. PETIY, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1288 CML TERM NATALIE S. PETTY, Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Patricia Fischer, hereby certify that a true and correct copy of a Motion to Make Rule Absolute RE: Counsel for Plaintiff's Petition to Withdraw Appearance for Joshua W. Petty, was duly served upon counsel for the Defendant, Natalie S. Petty, by depositing it in the U. S. Mail, postage paid, on Septemb~ 5c.::.20QJ" c: -- "1\ " (/') addressed as follows: -08 rn IT1('1 ~ -0 Z::3' 1 ZC , ~":; C.', I~ ': 4_ ;--".) ~: ('0 Thomas S. Diehl One West High Street PO Box 1290 Carlisle, PA 17013 I hereby verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: q.. o-() / , r&ujl~dVl~ P ATRlClA FISCHER " .,,'" , .<''- J.,. .;.. '".,,'. '.t,. '~"'.,., ,,'~ ,~.., ~..:,-,:' ~': JOSlWA W. PETIY, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- 1288 CML TERM v. NATALIE S. PETTY, Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Patricia Fischer, hereby certify that a true and correct copy of a Motion to Make Rule Absolute RE: Counsel for Plaintiff's Petition to Withdraw Appearance for Joshua W. Petty, was duly served upon the Plaintiff, Joshua W. Petty, by depositing it in the U. S. Mail, postage paid, on September 5, 2001 , ad~es~@ a~~ "l; C[' rrt -- .:- nlr:', -0 follows: z ~', \ 2,~t::: u' ~~:L: <c: ,. ~~~-~ -' pc ~ :?~ "0 -< r'~' Joshua W. Petty 18 East Big Spring Avenue Newville, PA 17241 I hereby verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: C; ~6----o I & ~ , '-Ib~V~ PATRICIA FISCHER r"""~~'~';'''';'~~~ri!I.Y'''~~' ,~ ~,' "--^ ~~.~ i;ill'lllffiIiUtlQl!~m2~~W-- -," "' ~ ~ "-'" . .~'~.wf L ~ ^~ ~. '^~'."~'-- ^" o ~:. 'i."Jtr:; rllrT' z:: ' --?"f- ~~( ~c. -f~ (~\ "".-''----..- -.7 :::1 -< o U) 1"'f1 -0 \ c...J'1 ~1;! ;':--:' ,-' 10 ~ ,~" , "::',J__ ~ ",. ".,'. .: ~', , , ~";' f JOSHUA W. PETTY, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1288 CIVIL TERM NATALIE S. PETTY, Defendant IN DIVORCE RULE ABSOLUTE AND NOW, this --Lfl- day of September, 2001, upon presentation and consideration of the Motion to Make Rule Absolute, submitted by Samuel W. Milkes, counsel for the Plaintiff, the Rule issued on July 30, 2001 is made absolute. Samuel W. Milkes is hereby declared released from this case. He is no longer considered counsel for Plaintiff. j J. ""';"-''''''';';'''''''''^''',' ;;"'""-c"~';;'ifjHt4~~i,", ;,,_0 ,,' "~^,,'''''~" _m..."""-,""""",,,== ~i~!f!^1:f~1.~_~5ij~1 i t. 0,() I f ~ - - - ~," ~ '."" ,,' ""~, '"'-"'~__v ,'" t'W""""' . V/NVI\lASNN3d AlNnm ON\Ill-ElflV'lna OZ:6 H~ 0 I d3S 10 lUC"O'\'(" i"(,:":;~,, )0 AOV,i ! '~"''-!,i':''.i ."'~ u,. ~,I..I 38HX}{Er/!.:! ,^J, " b"''''Ill'' ",,,,,,;U ""' ",,'"" ,;",;,," ;, ~ ~ ." , ""' ,,' "~ - ,.~o , '-"'.F~i , " JOSHUA W. PETTY, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1288 CIVIL TERM NATALIE S. PETTY, Defendant IN DIVORCE MOTION TO MAKE RULE ABSOLUTE RE: COUNSEL FOR PLAINTIFF'S PETITION TO WITHDRAW APPEARANCE FOR JOSHUA W. PETTY COMES NOW, Samuel W. Milkes, attorney for Joshua W. Petty, the Plaintiff in the above referenced divorce action, and requests of his Honorable Court that it make absolute the Rule issued upon the Defendant and the Plaintiff regarding counsel for Plaintiff's Petition to Withdraw as Counsel. In support of this Motion, counsel represents as follows: 1. On July 25, 2001, counsel filed with this court a Petition to Withdraw as Counsel, citing as a basis the combined events of counsel's imminent departure from the practice of law (effective July 31, 2001). 2. This Petition was served upon the Defendant (through counsel) and the Plaintiff himself on August 2, 2001. 3. On July 30, 2001, the Honorable Edgar B. Bayley issued a Rule to Show Cause, returnable in 15 days, "by which time Mr. Petty and/or Defendant must present reasons to the Court as to why he believes Mr. Milkes should not be allowed to withdraw as his attorney." 4. No response has been filed, nor has the Plaintiff individually made any contact with the undersigned counsel. ~t~ ,'.- "" '.' ",L' .'.:..c'" --.; , I WHEREFORE, for the reasons stated above, counsel Samuel W. Milkes respectfully requests that the Rule previously issued upon the Plaintiff and Defendant to show cause why he should not be allowed to withdraw as counsel be made absolute. Respectfully Submitted, -, ~' /'~ "", BY: a uel. . Milkes JACOBSEN & MILKES 52 East High Street Carlisle, PA 17013 (717) 249-6427 (717) 249-8427 - Fax Attorney No. 30130 ~.,; 1 'lu '.';',~J"'"~~1!"H"iill!l:,II~~">'~"""~m:m~"A!!i&!f'~Y,i&!oit~": """"-~aLi1!l:jjr = J1ilfl~ilIilliilllli'"" f ~~, ~ ,=~" 1, _. _, ~ nlll/" -, 2?}" .-"~ ", .<:.:':r (/) J 2C,) -'~'~ C) ~~ ::;l C.) (":? ~~:;: ,,., ;;, '''U (.0' f'.j '0 f'0 ",,,. E:! 'I I' II II II 1 I I ~::J '5J -< ~