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HomeMy WebLinkAbout01-1786 FX , ~. ~ _I ,I, - '" ~':j, LINDA MUSSER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO. 01-1786 (CIVIL TERM) NATHANL. MUSSER, SR.. Defendant. CIVIL ACTION - CUSTODYNISITATION ORDER AND NOW, this day of , 2001, upon consideration ofthe within Emergency Motion to Modify Partial Custody Order, the following ORDER is hereby ENTERED: 1. The Emergency Motion to Modify Partial Custody Order is GRANTED. The Consent Agreement for Custody which was approved by Order dated March 28, 2001, is modified as follows: (a) The Defendant is prohibited from exercising any partial physical custody ofthe minor children during those periods oftime when he is working. Instead, the Defendant shall transport the minor children to the Plaintiff s residence before departing for work, and the Plaintiff shall return the minor children to the Defendant's residence on the following morning. (b) Except as noted herein, the Order dated March 28, 2001, remains in full force and effect. 2. The parties are ordered to appear in person at ,on , at .M. for a a conciliation conference. BY THE COURT, , J. : II " i ,. LINDA MUSSER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO. {j 1- nfG ~ ~ I~ NATHAN 1. MUSSER, SR.. Defendant. CUSTODYIVISIT A TION MOTION FOR APPROVAL OF CONSENT AGREEMENT FOR CUSTODY NOW COMES, Plaintiff, Linda Musser, by and through her attorneys, TOMASKO & KORANDA, P .C., and files this Motion for Approval of Consent Agreement for Custody, and in support thereof, avers: 1. Plaintiff, Linda Musser, is an adult individual residing at 906 West Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant, Nathan 1. Musser, is an adult individual residing at 526 Hogestown Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff and Defendant are the natural parents of Nathan 1. Musser, Jr., date of birth March 17, 1988, and David A. Musser, date of birth July 6, 1989 (hereinafter, the "minor children"). 4. Certain circumstances have arisen in which Plaintiff and Defendant desire to live separate and apart from one another. 5. On March 19, 2001, Plaintiff and Defendant entered into a Consent Agreement for Custody of the minor children, the original of which is attached hereto as Exhibit "A" and incorporated herein. ;,!.I, , 1_ ,~ 6. Plaintiff and Defendant request that this Court enter an Order, in the form annexed hereto, approving the aforesaid Consent Agreement for Custody, WHEREFORE, Plaintiff, Linda Musser, respectfully requests that this Honorable Court enter an Order, in the form annexed hereto, approving the Consent Agreement for Custody. Respectfully submitted, TOMASKO & KORANDA, P.C. 219 State Street Harrisburg,PA 17101 Telephone: 717-238-1100 By: ~~r~ MICHAEL A. KORANDA Pa. J.D. #58808 Attorney for Plaintiff -2- I I ,. 'IiIlO ,~ LINDA MUSSER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO. NATHAN L. MUSSER, SR.. Defendant. CUSTODY /VISIT AnON CONSENT AGREEMENT FOR CUSTODY This Agreement, made this 1'1~ day of m A/tL#- ,2001, by and between Linda Musser (hereinafter, "Mother") of Mechanics burg, Cumberland County, Pennsylvania, by and through her attorney, Michael A. Koranda, Esquire, and Nathan 1. Musser, Sr. (hereinafter, "Father"), of Mechanicsburg, Cumberland County, Pennsylvania, who is not represented by counsel at this time. WHEREAS, the parties are married to one another as husband and wife; WHEREAS, the parties are the natural parents of Nathan 1. Musser, Jr., born March 17, 1988, and presently 12 years of age, and David A. Musser, born July 6, 1989, and presently II years of age (hereinafter, the "minor children"); WHEREAS, certain circumstances have arisen in which the parties desire to live separate and apart from one another; WHEREAS, the parties desire to enter into this Consent Agreement which they believe to be in the best interests of their minor children; NOW THEREFORE, intending to be legally bound, the parties hereto agree as follows: L The parties shall have joint legal custody of the minor children. The parties shall (" participate equally in all important decision regarding the well-being ofthe minor children. 2. Mother shall have primary physical custody of the minor children. 3. Father shall have partial physical custody of the minor children as follows: a, Alternating weekends beginning on Friday at 7:00 p.m. and ending on Sunday at 5:00 p.m.; b. Alternating holidays (the parties' acknowledge the following holidays: Easter Sunday; Memorial Day; Independence Day; Labor Day; Thanksgiving Day; Christmas Eve [from December 24th at 12:00 noon to December 25th at 12:00 noon); Christmas Day [from December 25th at 12:00 noon to December 26th at 12:00 noon]; c. Father's Day; d. Alternating weeks during the Summer when the minor children are not in school; and e. As such other times as the parties mutually agree. 4. The parties shall have reasonable telephone contact with the minor children at all times. 5. The party ending his or her period of custody shall be responsible for all transportation necessary to effectuate this Agreement. 6. Neither party shall move to a residence greater than 40 miles from the Cumberland County Courthouse unless he or she first provides a written notice to that effect to the other party at least sixty (60) days prior to any such move. 7, Father shall have full and complete access to the minor childrens' medical, school, -2- ,. II ~i and religious records. Additionally, Father shall be listed as a contact person with any school where the minor children are enrolled. 8. This Agreement shall remain in effect until modified by further Order of Court. 9. The parties agree to take whatever steps are reasonably necessary to effectuate the terms of this Agreement. 10. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania and shall not take effect until approved by the Court. II. Each party has read this Agreement and fully understands the provisions contained herein. IN WI1NESS WHEREOF, the parties have executed this Consent Agreement the day and year first above written. ~~ 7M .- ~rl/~ LINDA MUSSER SWOB/'! TO and subscribed before me this i'i day off{):..cc....h ,2001. A:l41....' ~4- NOTARY PUBLIC . Notarial Seal SilV:rhSpan~on ~ramer. Notary Public M C ~g . wp., Cumberl8nd County y ommlBSlon Expires Oct. 11, 2004 Member, Pennsylvania ASSoCIation 01 Notarias --::::::;;;: - .--~- ~---2!.- . _... NATHAN 1. MUSSER, SR. -.... SWO~ TO and subscribed before me this R day of {'i"b.cL" ,2001. ~4t~ ~/i?A<L NOTARY PUBaC Sha Notarial Seal Silver S~~~n ~mer. Notary Public My Commls~lon EX~i~~~:'11 County Member, Pennsylvania ASSOCialio~ 01 ~~O:s -3- i I , " : CERTIFICATE OF SERVICE AND NOW, this?i:.. day of /IIlA.f,CW. ,2001, I, Michael A. Koranda, Esquire, attorney for the Plaintiff, hereby certify that I served the within MOTION FOR APPROVAL OF CONSENT AGREEMENT FOR CUSTODY this day by: U.S. Mail, first class, postage prepaid, addressed to: Nathan 1. Musser, Sf. 526 Hogestown Road Mechanicsburg, P A 17055 By4{(f//L MICHAE A. KORANDA : 1,1 " ,., LINDA MUSSER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO. 0\ - I "IPIe. eo~L y~ NATHAN 1. MUSSER, SR., Defendant. CUSTODY NISIT ATION ORDER APPROVING CONSENT AGREEMENT AND NOW, this ~lJ~ day of (II ~ , 2001, upon consideration of the within Consent Agreement for Custody, the following ORDER is hereby ENTERED: 1. The Consent Agreement for Custody as executed by the parties is hereby Approved. 2. The Consent Agreement for Custody as executed by the parties is hereby incorporated into this Order. 3. The parties are hereby directed to comply with the terms and conditions of the Consent Agreement for Custody. ,1. !~~ 63-JQ-C) I RXS "_Ill '-"'l!!""".......J- "" ~~""l!~t; Jll Hlnnnll _' '<" '," . ","ij~!t!WJB;.t:_ilIltHlsd.diul ..,;." ..~, VifW/ilASNN3d A1NnO:) Ci~'!c:/'.)H38V\1no 9Tl:fll':::; 6;~t\i~~IO )1 II "~ " -~- ,,' ","-- ~ - ^' ,<~, . ~'iliIBliIIIr' .~ . ,~ ~ ~ .. -.....iiIIIliiIlil_ ~~ - " -"''iltl, . '. LINDA MUSSER PLAINTIFF V. NATHAN L. MUSSER, SR. DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA 01-1786 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT . , . ..' , AND NOW; "Friday; July 13, 20M' , upon consideration of the attached Complaint, it is hereby directed that paities,andtheir respective counsel appear bUoie Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, C,.inp,HiII, PA 17011',qn Thursday, August 09, 2001 at 3:00 p.m. " ' "., ',' , , ....,,, ,("" - for a Pre-Hearing Cust~dY Conference. At such conference, an efforfwill be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at.the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The conrt hereby directs the parties to furnish any and all existing Protection from Abnse orders, Special Relief orders, and Cnstody orders to the conciliator 48 honrs prior to schednled hearing. FOR THE COURT, By: Isl Melissa P. Greevy. Esq. fJ/J 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. You must attend the scheduled conference or hearing. YOU SHOULD TAKETIDS PAPER TO YOUR ATTORNEY AT ONCE. IFYOUDONOT 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 , , . ~ :jciW --',' .<>,' 1IIjHlifl'~J.ij " ~ ,~;l,.~,.,,~_ ,~ , I", ~. ..k ijlillW'ilMi~;'f." ~"~'1 ~~''''-':rJl:M:-',lliW''ll'''-,"9fl"'''''~t"",;,,,}'''''''Jlij"1lii'Mjiiil!ti!~~1ll:i~~...,~~ "'"~, ''"~''~'" '"\tI~ ~-~~~"'~ .. .Jt.J~ 1t..,aDO/'" ~. (!of',! ~Ll.u::C...j..O ~,~ ~CL mails.d....Jo DE..~. CoPt ~llLc.( -b m/y ~ cr. -< ::-..:> h] '''...n _'_~_,"__ " ,'<, _",'>"',",.,~_<,~",~_~_"'ed'~,,""_.,^,,_ _, ~: .." O~ .'". 'i ~ . ~ j I I " LINDA MUSSER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO. 01-1786 (CIVIL TERM) NATHAN 1. MUSSER, SR.. Defendant. CIVIL ACTION - CUSTODY NISIT A TION EMERGENCY MOTION TO MODIFY PARTIAL CUSTODY ORDER NOW COMES, Plaintiff, Linda Musser, by and through her attorneys, TOMASKO & KORANDA, P.C., and files the within Emergency Motion to Modify Partial Custody Order, and in support thereof, avers: I. Plaintiff, Linda Musser, is an adult individual residing at 906 West Trindle Road, Mechanicsburg, Cumberland County, Peunsylvania 17055. 2, Defendant, Nathan 1. Musser, is an adult individual residing at 133 Old Stonehouse Road South, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff and Defendant are the natural parents of the following minor children: Nathan 1. Musser, Jr., date of birth March 17,1988; and David A Musser, date of birth July 6, 1989 (hereinafter, the "minor children"). 4. By Order dated March 28, 2001, this Honorable Court approved Consent Agreement for Custody executed by the parties. A true and correct copy of the Order and Consent Agreement for Custody is attached hereto as Exhibit "A" and incorporated herein. 5. Under the terms of the Consent Agreement, the parties share legal and physical custody of the minor children. The Plaintiff has majority physical custody of the minor children, .' and the Defendant has the following periods of partial physical custody: a. Alternating weekends beginning on Friday at 7:00 p.m. and ending on Sunday at 5:00 p.m.; b. Alternating holidays; c. Father's Day; d. Alternating weeks during the Summer when the minor children are not in school; and e. As such other times as the parties mutually agree. 4. Since the minor children are presently on their summer vacation from school, the parties have been operating under the "week on/week off' partial physical custody schedule. 5, After the Consent Agreement was executed by the parties, the Defendant accepted employment with Verdelli Farms, Inc" in Harrisburg, Pennsylvania. 6. The Defendant is required to be at work at V erdelli Farms, Inc., from approximately 3 :00 p.m. until at least I I :30 p.m., Sundays through Thursdays, and he often stays as late as 3:00 a.m. to work overtime. 7. The Defendant's first week of partial physical custody was set to begin on June 10,2001. Prior to that time, the Defendant and the Plaintiff mutually agreed to modify the Consent Agreement so as to allow the Defendant to return the minor children to the Plaintiff before he left for work each afternoon. In return, the Plaintiff allowed the Defendant to have physical custody of the minor children every week day during the Summer until he left for work. 8. On June 15,2001, the Defendant announced that he no longer intended to take the minor children to the Plaintiffs residence before he went to work each day. Instead, he stated that he would take one (1) child with him to work each day, and that the child could remain in the -2- - 1"- ,1 II 'd~ - '.L, .. Defendant's vehicle or play in his employer's parking lot until his shift had ended. 8. The Plaintiff objected to the Defendant's proposed course of action, and suggested that the parties simply continue following their previous informal agreement or that the Defendant simply drop the minor children off at a relative's house on his way to work. The Defendant rejected the Plaintiff s suggestion and affirmed his stated intention of taking a child to work with him each day. 9. The Plaintiff believes, and therefor, avers that the Defendant's proposed course of action places the minor children in imminent physical and emotional jeopardy. The minor children would be forced to spend up to twelve (12) hours a night during the Summer months in or around a vehicle parked at an establishment in Harrisburg, Pennsylvania. Even if the minor children could somehow find a way to eat or sleep in the Defendant's vehicle during this period of time, their lives would be significantly disrupted by such a preposterous course of action. 10. The Plaintiff requests an Order from this Honorable Court modifying the Consent Agreement for Custody so as to prohibit the Defendant from exercising partial physical custody over the minor children during his working hours. The Plaintiff has no objection to keeping the minor children with her while the Defendant is required to work and returning them to the Defendant the next morning. WHEREFORE, Plaintiff, Linda Musser, respectfully requests that this Honorable Court enter an Order, in the form annexed hereto, modifying the Consent Agreement for Custody. -3- _,1..11 "^, .' Respectfully submitted, TOMASKO & KORANDA, P.C. 219 State Street Harrisburg, P A 17101 Telephone: 717-238-1100 By#~d MICHAEL A. KORANDA Pa. J.D. #58808 Attorney for Plaintiff -4- ,., ,,' ~- -~/jL. LINDA MUSSER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO.OI-n?b, c.-lu~t T~ NATHAN 1. MUSSER, SR.. Defendant. CUSTODYNISITATION ORDER APPROVING CONSENT AGREEMENT ANDNOW,this .2~+h dayof~o.lC.~ , 200 I, upon consideration of the within Consent Agreement for Custody, the following ORDER is hereby ENTERED: I. The Consent Agreement for Custody as executed by the parties is hereby Approved. 2. The Consent Agreement for Custody as executed by the parties is hereby incorporated into this Order. 3. The parties are hereby directed to comply with the terms and conditions of the Consent Agreement for Custody. BY THE COURT, /5/(Jwm) [, ai,;ul-<) , J. TRUE COpy FROM REC';)RD In Test;rnon\' .,.\h'x';nf, 1 h're unto set my hIlrxl. and he seul of ';d (ourt at Cariisle, 'a. , .......l.,.,q .~ j)oLf!lCLR...., . . .,.Llv.~m...J!!XHIBIT Prothonotat I A - l_. - , ,'~'" ~ ",~" . '. LINDA MUSSER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO. NATHAN 1. MUSSER, SR.. o CI ~ -ot(j rllr"', ~...:.:. ~l!;' u~ . 0~:~ = ,- -7 ::) ~ ,2001, by and .. Defendant. CUSTODY NISlT A TION ::1:: ~r::... ~v N .-J CONSENT AGREEMENT FOR CUSTODY This Agreement, made this l'lt!;.. day of m AA:L.ll between Linda Musser (hereinafter, "Mother") of Mechanics burg, Cumberland County, Pennsylvania, by and through her attorney. Michael A. Koranda, Esquire, and Nathan 1. Musser, Sr. (hereinafter, "Father"), of Mechanicsburg, Cumberland County, Pennsylvania, who is not represented by counsel at this time. , WHEREAS, the parties are married to one another as husband and wife; WHEREAS, the parties are the natural parents of Nathan L. Musser, Jr.. born March 17, 1988, and presently 12 years of age, and David A. Musser, born July 6, 1989, and presently 11 years of age (hereinafter. the "minor children"); WHEREAS, certain circumstances have arisen in which the parties desire to live separate and apart from one another; WHEREAS, the parties desire to enter into this Consent Agreement which they believe to be in the best interests of their minor children; NOW THEREFORE, intending to be legally bound. thc parties hereto agree as follows: I. The pm1ics shall havcjoint legal custody oCthc minOl' children. Thc parties shall .'~~; o ., ::;-.~ .~ "If''::: ~,rp '0 ;,-~) r-:r --I:::... /';::;J .c,() ""o.--m U ~ ::u -< . , .'^ , ' . 1 ~ h .'., participate equally in all important decision regarding the well-being of the minor children. 2. Mother shall have primary physical custody of the minor children. 3. Father shall have partial physical custody of the minor children as follows: a. Alternating weekends beginning on Friday at 7:00 p.m. and ending on Sunday at 5:00 p.m.; b. Alternating holidays (the parties' acknowledge the following holidays: Easter Sunday; Memorial Day; Independence Day; Labor Day; Thanksgiving Day; Christmas Eve [from December 24th at 12:00 noon to December 25th at 12:00 noon]; Christmas Day [from December 25th at 12:00 noon to December 26th at 12:00 noon]; c. Father's Day; d. Alternating weeks during the Summer when the minor children are not in school; and e. As such other times as the parties mutually agree. 4. The parties shan have reasonable telephone contact with the minor children at all times. 5. The party ending his or her period of custody shall be responsible for all transportation necessary to effectuate this Agreement. 6. Neither party shall move to a residence greater than 40 miles from the Cumberland County Courthouse unless he or she first provides a written notice to that effect to the other party at least sixty (60) days prior to any such move. 7. Father shall have full and complete access to the minor childrens' medical, school, -2- . I. ~ 'c, J , i I and religious records. Additionally, Father shall be listed as a contact person with any school !.. where the minor children are enrolled. 8. This Agreement shall remain in effect until modified by further Order of Court. 9. The parties agree to take whatever steps are reasonably necessary to effectuate the terms of this Agreement. 10. This Agreement shall be constmed in accordance with the laws of the Commonwealth of Pennsylvania and shall not take effect until approved by the Court. i ! 11. Each party has read this Agreement and fully understands the provisions contained herein. IN WITNESS WHEREOF, the parties have executed this Consent Agreement the day and year first above written. ~) - A_~(. /. J/'iJ L~ LINDA MUSSER SWORN TO and subscribed before me this I day of rQ,[C ~, 2001. Notarial Seal . Shannon Cramer, Notary Public SIlver Sprl~g !wp., Cumberlilnd County My CommIssIon Expires Ocl. 11, 2004 Member, PennSylvania ASSOClatlon Of Notanes ---~.-_._. /;;:"7';;; NATHAN 1. MUSSER, SR. SWORN TO and subscribed before me this R day of 1ft.., \) ,200 I. -dtV,!4 ~-~ L 14.lAA~ NOTARY PUB Ie Shan NOlariaI8e-;-, Silvar SP~~~ f~amer. Notary Public My Commission PEx~~:!!-b;.!~l~, County '\7Z0:,:,::~'r:'-:';~-;;::~:!~';~;;'i;~;~,;;i~~~;;i;~~~~;~~~t7i -3- - DELTAD~AL; ~ '~- .~ .UI 06/22/2001 07;40 FAX 717 766 8719 vERIFICATION 1 verify that the statements made in the attached EMERGENCY MOnON TO MODIFY PARTIAL CVSTOl>Y ORDER are true and correct to the best of my knowledge, infonnation and belief, I understand that false statements herein are made subject to penalties of 18 Pa. C.S. ~49D4 relating to IInswOm falsification to authorities. DATED: {-J/-tJl 0~ /rl~ LINDA MUSSER , ~~~7' ..; -" ,c '" ,J_,_II .' " ,,' , ~'-~~'...~..." . CERTIFICATE OF SERVICE t ~ AND NOW, thisa? day of W"-E , 2001, I, Michael A. Koranda, Esquire, attorney for the Plaintiff, hereby certify that I served the within EMERGENCY MOTION TO MODIFY PARTIAL CUSTODY ORDER this day by: U.S. Mail, first class, postage prepaid, addressed to: Nathan 1. Musser, Sr. 133 Old Stonehouse Road South Mechanicsburg, PA 17055 By~d MICHAEL A. KORANDA I" ,,'; J'I.L. .."""' , '''''';. LINDA MUSSER, AUG 0 2 20~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1786 Plaintiff vs. NATHAN L. MUSSER, SR., Defendant CIVIL ACTION - LAW CUSTODY ORDER TO RELINQUISH JURISDICTION AND NOW, this 31st day of July, 2001, the Conciliator, having been notified that the parties have reached an agreement and having received a request that the Conference scheduled for August 9, 2001, be therefore canceled, hereby relinquishes jurisdiction of the above-referenced matter. FOR THE Me i a Peel Greevy, Esquire Custody Conciliator ;1 j-; ,; T: " H " I j' , !'~ i ~ i,! Ij [:j i '~1 . '... '\Jo. f_"""'-4'f,\;l~~r~",i"11li"lil!f,,;<Mi.J8W~~1ihl!''1fj",liiI,;,;,k,jr!~m~<<,b<U:.!l'-'-''~~'""""~~liIlltll!il..~,j~, - ""~_&. ItINV^lASNN3d AlNnU) 01\!V'1bFl8INnO 0'1 :21 \i,d 9- Sn'ilIO ~ IU'./'('.' " , "-" ,-".. ',~ AO':;<.L ..h"~UtU.UC:',-j :li-''il jV -,C;! '-i"...a:pi-! :J,,~::L.,-, , ._ l.~. ~~'""""'-, h~~ ["' .-' J81J. '~ DL21!(U'J ~: L~ _ ~.,,",lt~-,_O.')J:-.,,,::,",~),".J:i'-:,..;,L:',j~L,___~,J.',_iJ1W"."""",~ ,"?!l'~'" ,..k?",,'n, ,~",-__~.r.k .~,_ ,'_ ", <, __ , " __, ~ ,0". ,~_~ "~li8W- J - ~"" i I 'I ,L ~ -'"''''''11 LINDA MUSSER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO. 01-1786 (CIVIL TERM) NATHAN 1. MUSSER, SR.. Defendant. CIVIL ACTION - CUSTODYNISITATION PRAECiPE TO THE PROTHONOTARY: Kindly mark Plaintiffs Emergency Motion to Modify Partial Custody Order WITHDRAWN. Respectfully submitted, TOMASKO & KORANDA, P.C. 219 State Street Harrisburg, PA 17101 Telephone: 717-238-1100 Date: 8',4-ft) BY:~~c:;;{ MICHAEL A. KORANDA Pa. LD, #58808 Attorney for Plaintiff :1 , -'-,'k" i ,I_I ... .. CERTIFICATE OF SERVICE AND NOW, this 6#.. day of h6UST ,2001, I, Michael A. Koranda, Esquire, attorney for the Plaintiff, hereby certify that I served the within PRAECIPE this day by: U.S. Mail, first class, postage prepaid, addressed to: Nathan 1. Musser, Sr. 133 Old Stonehouse Road South Carlisle, P A 17013 Melissa P. Greevy, Esquire 214 Senate Avenue, Suite 105 CampHill,PA 17011 Byd$~~ MICHAEL A. KORANDA 10, ~ '-- , I -'i) -' ",,} ~ ,