Loading...
HomeMy WebLinkAbout01-07057 HAROLD S. IRWIN, III. ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-8090 ATTO_ev FOR PETITIONERS .JOAN E. LESCALLEET, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . v. : CIVIL AC1'ION - LAW DANIEL R. LESCALLEET and TERESA M. WILSON, , Defendants . : NO. 01 .7oS! CIVIL TERM : CUSTODY ORDER OF COURT AND NOW, this ~ day of December, 2001, upon presentation and consideration of the attached stipulation and agreement and upon agreement of the parties. it is hereby ordered and decreed that the attached agreement is made an Order of Court. BY Tf:'I,I:COU ( UM( J. \ . <WJ L~{,tRX5 )W(~r~~," , '~', ~,_-;:~" "'''-;'.' -::;"('~o."'~~' ':~},",~--l"-'~, ',~ "': "~':"'~I;"" ,~,~ ~"; :,"",'~7,,?~~,,',>_''- '"'''~''' -r'.,."_"', ;-'_~', ",,,,r,'" """, ,"", -'-- ,< '. ~ ;--! "'" -",--, ~ .'.. ~, ~, - "~' ~ =>>'" .,....'".=,,,,~' '"~ " -" ~ ~ ~'"-^"",' ~,,~ , ~~~ ~I)~~~t{)''\~ ~U.' ' G\A/~)V.:1d 'I 'f) , ;,y,'h '<1/I:/I<I,\tllo 'P I I!() .-{&);,7-. '. 2' " ""(/'\,;-"\ I. 0..iO I ~r..... '~":i .""." , III ...J\jIS~'"'6'- " '<, (':-/ ,:<; ..::'0 "',~,,~ " ."." ,~ ~"", C'~.'-': ~"',... -" . ES ~~ :~~~~~Wr~'lfflll~.@Jr(i_~~~~~~~Iiik"";''''~7t:1'J3 , , " .JOAN E. LESCALLEET, Plaintiff ; IN THE COURT OF COMMON PLEAS OF ; CUMBERLAND COUNTY, PENNSYLVANIA v. ; CIVIL ACTION. LAW DANIEL R. LESCALLEET and TERESA M. WILSON, Defendants ; NO. 01 4Q~7 CIVIL TERM : CUSTODY STliP'lJ.LATION AND AG!REEMiE,NT THIS STIPULATION AND AGREEMENT entered into this /SWdayof December, 2001, by and between JOAN E. LESCALLEET (hereinafter referred to as "Grandmother") and DANIEL R. LESCALLEET and TERESA M. WILSON (hereinafter referred to as "Parents"). NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, the Parents are the natural parents of a minor child, namely Anthony Daniel Wilson (age 3 years, born April 27, 1998); and WHEREAS, the Grandmother is the paternal grandmother of the child and has been the primary caretaker of the child since January, 2001; and WHEREAS, the parties wish to enter into an agreement relative to the custody and visitation of the child. NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: 1. The Grandmother shall have legal custody of the child. '~'~~"'," _':ITY~I~,: :',;-;-~:,:'- ,,-1i:-'~,-;;,' "",~, ",>, " ,', ""''\1'':' ,,' ,'-[,,""1 ;,',,'d~~'%o",","'__'_,_,,""" ,_ , " ",'--':N "--'''-'''''''~''''!!''N',"f','',""1~''"",~~, __ .> ',0"" ",_, 1 _, , ~,," ." ~ , 2. The Grandmother shall have primary physical custody of the child. 3. The Parents shall have visitation and partial custody of the child as the parties may mutually agree from time to time. 4. The parties will keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to ensure that the health, welfare and well being of the child is protected. 5. The parties shall do nothing that may estrange the child from the other parent or injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's love or affection for the other parent. 6. The Parents shall each pay support to the Grandmother on behalf of the child in the amount of $25.00 per week. Said payments shall be made by the Parents to the Grandmother through the Cumberland County Domestic Relations Office and lor P.S.C.D.U. The Father shall also continue to pay $12.50 bi-weekly for the arrears which have accumulated until all arrears are paid in full. 7. Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing and only if executed with the same formality of this agreement. 8. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 9. The parties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County, and further aCknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over these issues and "~>Ji~,. ','~, '. """-'--">,:',,,","C'>~,'""',~"f~,,,',. "i'TIj"':,"',"", ~J ,-',',,~.'_ -'..__1'"" -~,!+~},-~,,:,~,'''''<,~'-' ~'__""~,,,'".:=,",,~, ....L, ."'_'~ ", COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND :SS: On this, the I~ day of December, 2001, before me, the undersigned officer, appeared DANIEL R. LESCALLEET,known to me (or satisfactorily proven) to be the same person whose name is subscribed to the instrument, and acknowledged that he executed this agreement for the purposes therein contained. Notarial Seal . Harold S. Irwin Ill, Notary PU~~ Carlisle Boro, CUn:'ber~ndptC~3 2~02 My Commission Expires e., . Member, Pennsylvania {'ssocia,tior. ct Notaries (SEAL) COMMONWEALTH OF PENNSYLVANIA :SS: COUNTY OF CUMBERLAND r?'< On this, the /..} day of December, 2001, before me, the undersigned officer, appeared TERESA M. WILSON, known to me ( or satisfactorily proven) to be the same person whose name is subscribed to the instrument, and acknowledged that she executed this agreement for the purposes therein contained. Notarial Sea! Harold S. Itwin 111, Notary pUblic Carlisle Bora, Cumberland county My-Commission Expires Sept. 2'3'.2002 Member, Pennsylvania /'3sc:;:1~'tior; cl Notaries (SEAL) ~-'~~-'ll!!1~,j!!:fij:!i1l!,_,~", ,';.-',;" ~,) :'i,"':":;~''''''''''<'' ", l -;"""fi','", .,.-.-.: .,']' ~-- -- - '-"",. ., ~~~", "'_<".' ".,.,~ "_',' '"~ ,.r . " p.~" , , . ,~, z shall retain such jurisdiction should circumstances change and either party desire further or require further modification of said Order. 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 herein set forth. WITNESSETH: Date: I~~I Date: ~I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ~ /" ~~tI'J.x (SEAL) J AN E. LESC LLEET !f!~~ (SEAL) dv<. .....- ...-v- ("z.<./ d Lkn:1SEAL) TERESA M. WILSON :SS: On this, the I~ay of December, 2001, before me, the undersigned officer, personally appeared JOAN E. LESCALLEET, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set y hand and official seal. Notarial Sea! publiC Harold S. Irwin Ill, Nota~ County Carlisle Boro, cun:ber\~~pt 23, 2002 t>fty commission Expires . .' I NQtrarlfJl;\ ber pennsylvania f\.ssOC\at\on O. - Mem I (SEAL) :~:i,~ 1,~Al!l:.,t" "","_""V,',1,,,.+,,~'"/,.-!T!'__' ;'__,~'," ,-','f,""','~,"" l't..!"1',';"'P'~'c--~"'" . _ ":-_'i' "~",-' .,.(, ,J',~ ''''t" '1" 1.>- ,. ~" , __ ' . ", ," ~ t~t r.o~ ft l' '" "'-. .... ~ " ;s\ ~ I , ~ 'r '0 .~ f ~ ~ r ~ 'r r LT .- ..".', " ,'~ ',''':'',''',!-, ^,-~ '~"c'F,R"t ' ~.~ ~ ., C) f"'"' ~ ~~ ~ ~ "[1 r, -------:-! ?2 [- , }f ::< , ..c: (j) -~j -' .. ~ "Q ~~ ,. .Q 41~1 -i> ..... '" " , ., " C- "? ~ .:.:-' c:: ~ " ~ ...< \ C\ =< , (;/-, _, ~~~'iH~~""~~I'~',~$:-:_~--""",."",~. .~,~~~,~:.~,~~ . ""';~")~ JOAN LESCALLEET PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v, 01-7057 CIVIL ACTION LAW DANIEL LESCALLEET DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, October 20, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacgueline M. Verll"Y-,_Es'l-n' the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, November 21,2006 at 8:30 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 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 court hereby directs the parties to furuish 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: Isl ac ueline M. Verne Es 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 TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VE 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 '(~~'W"~!fl'1'\',,;-:c~' ~.'"":"'....,.,. __,. "_""~' ;--<" --1"'''' " . ~ '0 .,.,....,~ ~ ,- - "" -- --~ ' >"'~,__."",,~C'_'" ',," >"'.., "--~'_,~_'"~',=~,,_~" ~"-, ", "~~,'"~. ~'.~"~.Iff. ~ ~ ~ ,Jr ~ ~ ~ 1{J.(lC"-ol ~ P z ~~ ~'oe'(J/ ~cI - ~ ~ ~ ~. -/Y} '7t;?r;n->.0/ , VIN\li\lASNN3d ,il,~nO~J 'Jr'\;,'!F:Pf'^'n" .,,'~,Lf'V Iv , ~:/ lid 02 130 900l Al:NIONOHlOad 3H1. ;:I() 30l:!.::iQ-{ffil:l f!CP t~,_, " ~, _.",.,1!iJ!liUi!ll[.""~~...".d""~>"",,, " , ,,[ -l ," ,'__' :-,,~!f~tl.v,o, ~ < _ i.~~~~'i~1i'!_ii'~!"'Y.;"~~c!ibh'";'\'~'W''''''''' ~'1""\-';"'NC<;"i~!"'~"'-0i1'-W'~~l~1?i-l~1~!~!'''''~~lr.:'~1iitjBl~:tl:ii1i~'Wj!iH~I!J~' ...,."'-----'--------'-' -"":--:"""'-':',-1-- ~' v. DANIEL LESCALLEET, Defendant " n rT 1 7 2006 , \ ! L_'(A _==cc==cJ : IN THE COURT.OF COMMON PLEAS OF , : CUMBERLANDCOUNTY,PENNSYLV ANIA : CIVIL ACTION LAW : NO: 01-7057 : IN CUSTODY JOAN LESCALLEET, Plaintiff ORDER OF COURT AND NOW, , 20~, upon consideration of the attached Complaint, it is hereby direct.ed that the parties and their respectivecounse1 appear before , the conciliator , at on the day of , 200---" at o'clock, _.m., for a Pre-Hearing Custody Conference., At such confer~nce,aIi 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 may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By: Custody Conciliator The Court of ComII1on 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 accomII1odations available to disabled individuals having business before the court, please contact our office. All arrangements must be made af.least 72hoursptiortoany hearing or business before the court. Yon must attend the scheduled conference or hearing. YOU SHOULD TAKE TIDS PAPER TOYOURLAWYERATONCE. IFYOU DO NOT HAVE ALA WYEROR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cwnberland County Bar Association 32 North Bedford Street Carlisle, P A 17013 7l7~249-3l66 ,,. '-1:tw~" ,~ '-Nl,. H "",r,'''--"'e-' ,',"1--IP . ,,- ", ". ~_' _ "~ 1" ~ : ~ ,~ ~ .' " ~ 0Ji-"~',"""~1'=""~'''~J! I ~~" ,-~. "*'''''O~,'= .... < JOAN LESCALLEET, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA v. DANIEL LESCALLEET, Defendant : CIVIL ACTION LAW : NO: 01-7057 : INCUSTO])Y' . PETlTON TO MODIFY CUSTODY FOR VISITATION 1. The plaintiff is Joah Lescalleet residing at 101 Lawrence Lane, CaJ:"lisle, Cumberland Coun~,Pennsylvroria17013 2. The defendant is Droriel R. Lescalleet, residing at 44 Conway Street, CaJ:"lisle, Cumberland Coun~, Pennsylvroria 17013. 3. The minor child is Anthony D. Lescaleet, date of birth April 27, 1998. 4. On December 1,2001, the Honorable Edgar B. Bayley, entered a Stipulatibnfor Custody signed by the parties, Attached as Exhibit "A. 5. Y our petitioner lived with the respondent and the minor child at 44 Conway Street, Carlisle, Pennsylvroria until recently and therefore petitioner had consistent contact with the child and shared parental responsibilities for the child. 6. Your petitioner has moved out of the family residence and has no scheduled visitations with the minor child. 7. Although your petitioner signed a Stipulation granting guardianship to the respondent, he has maintained contact with the minor child and has formed a parental bond with the child. 8. The best interest of the child will be served by the Court in modifying said Order. '-"l~-?",.~_ ,,~""" ~ ~~-1 "'''W.' . "r"''''' ',"'..",-- ",~,~ " " " ,~ .. ~ , '-- '~ ""'''''jj!:r'i~J!JUiiV' ' " WHEREFORE, Petitioner prays this. Court to grant the modification of custody/visitation Order as follows: (a), The petitioner is granted visitation with the minor child with a schedule to be agreed upon by the parties, Date: _Dd: /"3;, po ~ , Respectfully submitted, ROMINGER & WHARE ~- Michael O. Palermo, If., squire 155 South Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court ID # 93334 Attorney for DefendantlPetitioner ;~"' ~~.. '.' .'" ,. ,- - ~, ''I' " ,,',~... iT _. , , . . " .- .. . . ~... it":---- ::-r":"';~~''- -.- VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. cons. Stat. S 4904 relating to unsworn falsification to authorities. Date: /01 r /Ck ;$l~ Daniel Lescalleet DH6,S,QQ ":c_W'ff::, ", '. co-, ?~, '-""":i'-'!1"''',o' _ ,~~ __" ___~ ,"'?'I",.~ > __,'.. ---~, ". " D'EG 101';01 HAROLD S. IRWIN, III, eSQUIRE ATTORNIY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-8090 ATTORNEY FOR PETITIONERS .JOAN E. LESCALLEI!T, Plaintiff : IN THE COURT OIP COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION. LAW DANIEL R. LESCALLEET and TERESA M. WILSON, Defendants . : NO. 01 ;JD51 CIVIL TERM : CUSTODY ORDER OF COURT AND NOW, this :<. '] day of December, 2001, upon presentation and consideration of the attached stipulation and agreement and upon agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. BY THE COURT, }5/ tdj>^l-B 1f}f ....... t <~ ,."."....... ~ ". ::~ ~ ' . Ex/u/)./t "Yf (/ ~,"flI;!p; - ,~ " ,. c ,.. .". ~~~~ JOAN E. LESCALLEET, Plaintiff I IN THE CCURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA v. I CIVIL ACTION. LAW () c.~ ~:~ e' ~-; DANIEL R. LESCALLI!ET and TERI!SA M. WILSON, Defendants . I NO. 01 .7u.',-1 CIVIL TI!RM ,11(" z', ;:::J 'I ~") .:1 : CUSTODY i/.'" . -,~ -' !.},~ '...j ~ -, . .,. .~ ...;, -,.; :'"":..., STIPULATION AND AGREiEMENT ....f; -<c ....,) '..."1 -...! THIS STIPULATION AND AGREEMENT entered into this day of December, 2001, by and between JOAN E. LESCALLEET (hereinafter referred to as "Grandmother") and DANIEL R. LESCALLEET and TERESA M. WILSON (hereinafter referred to as "Parents"). NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, the Parents are the natural parents of a minor child, namely Anthony Daniel Wilson (age 3 years, born April 27, 1998); and WHEREAS, the Grandmother is the paternal grandmother of the child and has been the primary caretaker of the child since January, 2001; and WHEREAS, the parties wish to enter into an agreement relative to the custody and visitation of the child. NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: 1, The Grandmother shall have legal custody of the child. ",~<-"J_,,_"__<__,_..,. ". ~.. ~ ", ,-- . , .. ',,' . "." I" - "' ~ ,~~ 2. The Grandmother shall have primary physical custody of the child. 3. The Parents shall have visitation and partial custody of the child as the parties may mutually agree from time to time. 4. The parties will keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to ensure that the health. welfare and well being of the child is protected. -~.. 5. The parties shall do nothing that may estrange the child from the othel: parent or injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's love or affection for the other parent. 6. The Parents shall each pay support to the Grandmother on behalf of the child in the amount of $25.00 per week. Said payments shall be made by the Parents to the Grandmother through the Cumberland County Domestic Relations Office and I or P,S.C.D.U. The Father shall also continue to pay $12.50 bi-weekly for the arrears which have accumulated until all arrears are paid in full. 7. Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing and only if executed with the same formality of this agreement. 8. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 9. The parties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over these issues and '{~!,h"c"""".."..,-", r_''' , ~ ' ~~~ 'OW' ~,',__ 'T f[ :T~__~'l_ n " . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND :55: On this, the I~ day of December, 2001, before me, the undersigned officer, appeared DANIEL R. LESCALLEET, known to me ( or satisfactorily proven) to be the same person whose name is subscribed to the instrument, and acknowledged that he ex\ecut:~~~:,~~;:~~;:::~cforth\e purposes therein contained. carti Ie Bom cumoerhil"ld County / Mv co~missio~ ~xpires sept. 23. :~.2 (SEAL) , p 'ns""'ar'~ ,,"~"'-"ll~r.::' .lQtarles Member. en ," ~ ., ,J" ' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND :SS: On this, the I S-.....day of December, 2001, before me, the undersigned officer, appeared TERESA M. WILSON, known to me ( or satisfactorily proven) to be the same person whose name is subscribed to the instrument, and acknowledged that she executed this agreement for the purposes therein contained. I Notarial,.", J Hamid S. IrWin :II, Nor:t1y Public Cel1is1e Bora, Cum\:leriand Ccunty My commiSsion El<pireS SilO.. 2:3,.2002 . Mamt::er, Pennsyl"~r'a " ,';.~ ;: ,,:,' c: :.': lr~eS (SEAL) ';;'&)<,"1", ~. " .'.,- --"-",,, ""..,.", '-1" ~ r-- - ~ " -. ,',q - ~~~ ~-"Trnl1T 'i[ TI . .. . shall retain such jurisdiction should circumstance~ change and either party desire further or require further modification of said Order. 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 herein set forth. WITNESSETH: Date: !WI 1-6a+t.. ~ --AA .. ~tt4 (SEAL) J~AN E.LESClLLEET Iit{~ (SEAL) Date: 0/,),,1., . dv~ 4r-- ...--.,r 'tc/"'./A-u\. iSEAL) TERESA M. WILSON COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND :5S: On this, the I~ay of December, 2001, before me, the undersigned officer, personally appeared JOAN E. LESCALLEET, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set Notan"'! Sea! ubi' Harold $. ~rM" \It, NO'~ ~ou~ty cal1~~:~ ~~~~ Sep!. 23, 2002 MY Co fll> ciation 01 NQ1,rlQ$ Mem'Oer, pennsyNanl3. .so Notary Public (SEAL) 'J<~'imM'~f" '"",,,<r"),--";, " '~,1~' ~^ ~' i" -," ~,~"~ ^," 1,"" ,- - I-~""""'- ';Sf1~fr.f\ '~'--'''''''>'~~ ~" ,~ -,~~- - >:~Y;.1 ~ '~- ',,'n--'-.~~~""~y ,~' " ",?'F!: ~ ~- I" /'"'-..~ _<::>C\ --t ~ )oJ r ~ (' ..t- oot ~, .0_ ~ 9=- It , ::';1'; ; ~: .~ u: -< r.(.' .-' 2'.,' (- ;' J:' ,~ V\ '" \1\ <::- n ~.;. Ie' ~ ',' '.:'1 '\ ." :-~; ':J ",." ;...,) ;',", , r' .'-' , :;(.l 9 .-t' '.C'" -,; ...- :~~5 ~~ \: ,., JI ....~ 'jJ -' -< " -<. ~ ~~ ."""~ ,]f" ,'= ,~ . 1 ,~_, ' ~~Jf, '~'" < '.> ~,,",", , .,,,, ,,,,ii\J;1..,, "- - ,~. ~ ,~'. ,~'"^" """-"'-"'-"~"*'<,dE',">,,,.';w,c>'-'",~~" ", ""n '-'~fI":'" -1rt ,'"'~,' ~:rtrirnfl\(r_~t1rfc'Yt)~ii~~;(;T%Ji.i ~ ~ R~ 1'\-. -. ~VJ D ~ ;;~ ~ \,:> I>' 5>- fJ vJ (> ~ ~ r ~ ~ '" '\ (, '''' -r:~-:::-J () ,~~ C~ " ""~ cr>. ("I (:::J -l c,".., -,- p.;-n "''' 'IF :P!~...: Co" .,~J C~i__' ":-::;(~l --.:) , ..~ f~''::; (A) /Srn (.0 S;~ C.) :< JB'f~,~" ,.. " J~~,~l\~~;!J'lj~j~~l"~~~rwf7W&i'!~~~~!lilif~~~~~r~'r&~~~~'i~~!"1f~~fill~.'~mt~~!a~!f!j'~"'-' , ~' .. v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW JOAN E. LESCALLEET, Plaintiff : 01-7057 CIVIL TERM i, DANIEL R. LESCALLEET and TERESA M. WILSON, Defendants : IN CUSTODY RAECIPE TO WITHDRAW APPEARANCE To Curtis R. Long, Prothonotary: Please withdraw the appearance of Harold S. Irwin, ill, Esquire, on behalf of the Plaintiff, Joanne E. Lescalleet, in the above captioned case. Harold S. Irwin, ill, Esquir 64 South Pitt Street Carlisle, P A 17013 (717) 243-6090 PRAECIPE TO ENTER APPEARANCE Dated: October 2.1., 2006 To Curtis R. Long, Prothonotary: Please enter my appearance on behalf of the Plaintiff, Joan E. Lescalleet, in the above captioned case. RespectfuHy Submitted, IRWIN & McKNIGHT Date: October JD ,2006 Dougl G. Miller, Esquire Supreme Court I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 '<'~-""'^' .~~, ,=~~~~ " ~r M,~' ~"">I"",n>_,",=,"',~,>-;__~,,_,,,;,,".~._-"~",","" ,', "!,,, , _ -,,-,c,-, ,'"- _~ _ ,A ,', ". ~ -, " .' ~,-"-~ ~ ~ 'JJ,'~ 1 . .. ,.? - CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the persons indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: MICHAEL O. PALERMO, JR., ESQUIRE 155 SOUTH HANOVER STREET CARLISLE, PA 17013 Date: October 30, 2006 IRWIN & McKNIGHT .. Miller, Esquire Supreme ourt I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 ,-',\~",~- -=- ,~~ d'~_"'~ <"',", ", _~_,_ .~ ~ ,~ . ~, -~~ ,",", ,~,' -- ~.~ , r",,""^~ .<" ~,,,.,,,,,,,,,,,,.,,._~,,, ,~, , H' ~ :-:!."- ~, . "'~, "' " ~"'" '.', -"~ ,,,"~. " ;.t-";,;,,:,;i,,'i,f~"'&& '~,~'. "tlir>i~'~'~-'l !1l1~ r~r' ') TI'.. r~-"'"'n';'-~""";T'-"ti" 'l")r.;;--"fiir:J~ 4 . - "... (') ,...., = 0 C = " ,: Z <>"" (jJ CJ :r!.." [- if\ C ,) . -~T -i n'F ,,' :2'::: (...) ,,1Tl ~;; ::,.~ Cl ?Py ~~ ~C) i:, ,:;;c '-0 ~"5:.ri ~~r ~ 0,0 ']c- ~:~:' (~) Om 2: )~ ~ ('0.,) ::0 0 -< , (i' i:') <-i ,"': ):-: ~, i , l, ~: !....~ ,,': ;,,, ~ ~ ",: "-f ,,--' i:i .,"'-~'--t;:., ,~~~~~\-.p:r,,~ ~, ,.,~~~~~~ii!.ri*"';:'