HomeMy WebLinkAbout07-3214YON R. CHIN, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2007- 3 z ~ `~ C~ ~~
BORAH L. CHIN,
Defendant :CIVIL ACTION -LAW
CUSTODY
COMPLAINT FOR CUSTODY OF MINOR CHILDREN
Plaintiff Kayon R. Chin, by his attorneys, Snelbaker & Brenneman, P. C., hereby avers
following:
1. Plaintiff is Kayon R. Chin, an adult individual residing at 5252 Meadowbrook Drive,
Cumberland County, Pennsylvania.
2. Defendant is Deborah L. Chin, an adult individual residing at 6017 Robert Drive,
burg, Cumberland County, Pennsylvania.
3. Plaintiff seeks custody of the following children:
NAME PRESENT RESIDENCE AGE
Jason L. Chin 6017 Robert Drive (15/D.O.B. 11/18/91)
Mechanicsburg, Pennsylvania
Samantha J. Chin 6017 Robert Drive (13/D.O.B. 9/11/93)
Mechanicsburg, Pennsylvania
D. Chin 6017 Robert Drive (10/D.O.B. 7/23/96)
Mechanicsburg, Pennsylvania
The children named above were born in wedlock.
The children named above are presently in the custody of Defendant at her residence as
indicated in Paragraph 2, above.
During the last five (5) years, the children subject to this custody action resided with
LAW OFFICES
SNELBAKER 8C
BRENNEMAN, P.C.
following persons and at the following addresses:
ZSONS ADDRESSES DATES
endant Deborah L. Chin 6017 Robert Drive Apri12007 to
Mechanicsburg, PA Present
ntiff and Defendant 5252 Meadowbrook Drive 1997 to Apri12007
Mechanicsburg, PA
The mother of the children is Defendant Deborah L. Chin, who is currently residing at the
s indicated in Paragraph 2, above. She is married to Plaintiff.
The father of the children is Plaintiff, who is currently residing at the address indicated in
aph 1, above. He is married to Defendant.
4. The relationship of Plaintiff to the children is that of father. The Plaintiff currently
with the following persons:
NAME RELATIONSHIP
N/A N/A
5. The relationship of Defendant to the children is that of mother. The Defendant
y resides with the following persons:
NAME
Jason L. Chin
Samantha J. Chin
Kevin D. Chin
RELATIONSHIP
Son
Daughter
Son
6. Plaintiff has not participated as a party in other litigation that involved custody of the
' children.
LAW OFFICES II _2
SNELBAKER &
BRENNEMAN, P.C.
Plaintiff has no information of a custody proceeding concerning the children pending in a
of this Commonwealth.
Plaintiff does not know of a person not a party to these proceedings who has
custody of the children or claims to have custody or visitation rights with respect to the
7. The best interest and permanent welfare of the children will be served by granting
physical custody to Plaintiff because Plaintiff can and has provided an emotionally
stable home and nurturing environment for his children.
8. Each parent whose parental rights to the children have not been terminated and the
person who has physical custody of the children have been named as parties to this action. All
persons, named below, who are known to have or claim a right to custody or visitation of
children will be given notice of the pendency of this action and the right to intervene: None.
WHEREFORE, Plaintiff Kayon R. Chin requests this Court to grant him primary
custody of his children Jason L. Chin, Samantha J. Chin and Kevin D. Chin.
SNELBAKER & BRENNEMAN, P. C.
By:
Keith O. Brenneman, Esquire
44 West Main Street
Mechanicsburg, PA 17055
(717) 697-8528
May 30, 2007 Attorneys for Plaintiff Kayon R. Chin
LAW OFFICES
SNELBAKER &
BRENNEMAN, P.C.
-3-
VERIFICATION
I verify that the statements made in the foregoing Complaint 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.
Kayon R. C in
Date: May 30, 2007
LAW OFFICES
SNELBAKER &
BRENNEMAN, P.C.
CERTIFICATE OF SERVICE
I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date,
caused a true and correct copy of the foregoing Custody Complaint to be served upon the person
and in the manner indicated below:
FIRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS:
Linda A. Clotfelter, Esquire
5021 East Trindle Road
Suite 100
Mechanicsburg, PA 17050
SNELBAKER & BRENNEMAN, P.C.
By:
Keith O. Brenneman, Esquire
44 W. Main Street
P. O. Box 318
Mechanicsburg, PA 17055
(717) 697-8528
Attorneys for Plaintiff Kayon R. Chin
Date: May 30 , 2007
LAW OFFICES
SNELBAKER &
BRENNEMAN, P.C.
o
~ Z? C~L~
f7: r~-;
r.~ t Y
~,
~ ~
~ ~! W ~~
R
' -
~', ~ ~ a ~'
~.
~.~j ~ ~ '~ C_..~ j
9 A
A
CG ~-
C
, - ~
KAYON R. CHIN IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
DEBORAH L CHIN
DEFF,NDANT
• 07-3214 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Monday, June 04, 2007 ,upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator,
atJ 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, June 26, 2007 at 9:30 AM
fora :Pre-Hearing Custody Canference. 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 furnish 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: /s/ 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
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
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
~ ~i
. ~ LOfi~
~p0 -.,
~~,.. ,~ ,
3~'~'.-,. v'~~'1
fl2 ~~ bdd ~- t~(' t~0~
h~~.Gs~1~~i-~1wd 3~ ~fl
~~':~;~~lt~
•.
KAYON R CHIN,
Plaintiff,
vs.
DEBORAH L. CHIN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0.2007-3214 CIVIL
CIVIL ACTION -LAW
CUSTODY
ANSWER TO PLAINTIFF'S COMPLAINT FOR CUSTODY OF MINOR CHILDREN
AND NOW, comes Defendant, Deborah L. Chin, by and through his counsel Linda A.
Clotfelter, Esquire, who responds to Plaintiff s Complaint as follows:
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7. Denied. It is specifically denied that the best interest and permanent welfare of
the children would be served by granting Plaintiff' primary physical custody. It is also
specifically denied that Plaintiff is able to provide the children with an emotionally stable and
nurturing home environment. In further answer hereof, it is in the best interest of the children to
be within the primary care of their mother, Defendant for the following reasons:
a. Father is very short tempered and as a result he is unable to control his anger.
While irate he grabbed Jason, pinned him on the sofa, and pulled his closed fist back as if
he intended to punch Jason. He also pulled Jason's arm, swung him azound and shook
him, and he has in the past spanked Samantha hard enough to leave welts. Father's
conduct has also included emotional and verbal abuse of Mother and the children by
degrading and belittling them. This abuse has been directed at the children as recently as
the past two weeks and he has at times brought the children to tears.
b. Father's current living conditions are unhealthy and unsafe. More specifically,
due to ongoing renovations there are exposed wires, mold, and no kitchen. All cooking is
done inside using a propane outdoor camp stove and Mother truly fears for the children's
safety while in the residence.
c. Father is often unavailable in that he travels out of state for two to three weeks
every couple of months and he often participates in training for work, which requires him
to be out of town for a week at a time.
d. Mother has a traditional job and is available to regularly care for the children and
take them to doctors' appointments and other obligations as she always has. She has also
moved into a safe environment in close proximity to facilitate the children's contact with
him.
8. Admitted.
WHEREFORE, Defendant, Deborah L. Chin, respectfully requests that this court grant
her primary physical custody of the parties' children, Jason L. Chin, Samantha J. Chin, and
Kevin D. Chin, and grant partial custody to Plaintiff.
Respectfully submitted,
Date: ? ! 19 C
LAW FIRM OF LINDA A. CLOTFELTER
L' da A. Clotfelter, Esquire
A orney ID No. 72963
21 East Trindle Road, Suite 1
Mechanicsburg, PA 17050
(717) 796-1930 telephone
(717) 79b-1933 facsimile
Attorney for Defendant
KAYON R CHIN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA
vs. : N0.2007-3214 CIVIL
DEBORAH L. CHIN, :CIVIL ACTION -LAW
Defendant :CUSTODY
VERIFICATION
I, DEBORAH L. CHIN, verify that the statements in the foregoing document are true and
correct to the best of my knowledge, information and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to
authorities.
Date: ~~ ~ ~' ~
~ ~ ~~,:,
DEBORAH L. CHIN
KAYON R. CHIN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA
vs. : NO.2007-3214 CIVIL
DEBORAH L. CHIN, :CIVIL ACTION -LAW
Defendant :CUSTODY
CERTIFICATE OF SERVICE
AND NOW, this,~~'day of ~dL+.~ , 2007 the undersigned hereby certifies that a
true and correct copy of the foregoing S WER TO PLAINTIFF'S COMPLAINT FOR
CUSTODY OF MINOR CHILDREN, was served upon the interested parties by facsimile and
United States First Class Mail, postage prepaid, addressed as follows:
Keith Brenneman, Esquire
44 West Main Street
Mechanicsburg, PA 17055
Jacqueline Verney, Esquire
44 South Hanover Street
Carlisle, PA 17013
By:
Respectfully submitted,
LAW FIRM OF LINDA A. CLOTFELTER
mda A. Clotfelter, Esquire
ttorney ID No. 72963
5021 East Trindle Road, Suite 1
Mechanicsburg, PA 17050
(717} 796-1930 telephone
(717) 796-1933 facsimile
Attorney for Defendant
~ N
c ~ i
.--3
c:s
~_.. ,;~~:~..
- ~
~'Y,t „
r
~~
~"
-n-}
-i
r
{''~~ .;~~
;~
sue of ~~
KAYON R. CHIN,
Plaintiff
VI.
DEBORAH L. CHIN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0.2007-3214
IN CUSTODY
ORDER OF COURT
CIVIL ACTION -LAW
AND NOW, this ~ `~ day of dlz. •~,-~ , 2007, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The Father, Kayon R. Chin and the Mother, Deborah L. Chin, shall have
shared legal custody of Jason L. Chin, born November 18, 1991, Samantha J. Chin, born.
September 11, 1993 and Kevin D. Chin, born July 23, 1996. 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 regarding their health, education and religion. Pursuant to the
terms of 23 Pa.C.S. §5309, 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 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 use to the other parent. Both parents
shall be entitled to full participation in all educational and medical/treatment planning
meetings and evaluations with regard to the minor children. Each parent shall be entitled
to full and complete information from any physician, dentist, teacher or authority and
copies of any reports given to them as parents including, but not limited to: medical
records, birth certificates, school or educational attendance records or report cards.
Additionally, each parent shall be entitled to receive copies of any notices which come
from school with regard to school pictures, extracurricular activities, children's parties,
musical presentations, back-to-school nights, and the like.
2. Mother shall have primary physical custody of the children.
3. Father shall have the following periods of partial physical custody:
A. During the summer:
1. Every Wednesday overnight from 6:00 p.m. to Thursday at
7:00 a.m.
~iNt~f1`~~tSN~~
iy
Jlki'd10~v1-l.I.~ ~S~J. ~
2. The first three full weekends per month from Friday at 6:00
p.m. to Sunday at 8:00 p.m., except that this will begin with the
second weekend in August, 2007 and continue for 3 weekends.
B. During the school year:
1. The first three full weekends per month from Friday at 6:00
p.m. to Monday until after school.
2. The Wednesdays before Father's weekend custodial time from
6:00 p.m. to 9:00 p.m.
3. The Wednesday before Mother's weekend custodial time,
overnight from 6:00 p.m. to Thursday after school.
4. The parties shall cooperate with family counseling.
5. In the event that the custodial parent is not available to care for the
children overnight during their custodial period, the custodial parent must offer said time
to the non-custodial parent in a timely fashion so that the non-custodial parent may take
advantage of the time.
6. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control. Another
Custody Conciliation Conference is scheduled for September 28, 2007 at 9:30 a.m.
BY THE COURT,
~~~~~
J.
cc:~ ` O. Brenneman, Esquire,
mda A. CLotfelter, Esquire,
1'for Father
for Mother
KAYON R. CHIN,
Plaintiff
V.
DEBORAH L. CHIN,
Defendant
PRIOR JUDGE: None
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0.2007-3214 CIVIL ACTION -LAW
IN 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
Jason L. Chin November 18, 1991 Mother
Samantha 3. Chin September 11, 1993 Mother
Kevin D. Chin July 23, 1996 Mother
2. A Conciliation Conference was held in this matter on July 31, 2007, with
the following in attendance: The Father, Kayon R. Chin, with his counsel, Keith O.
Brenneman, Esquire, and the Mother, Deborah L. Chin, with her counsel, Linda A.
Clotfelter, Esquire.
3. The parties agreed to an Order in the form as attached.
~-31-b7 /~(.V
Date ac eline M. Verney, Esquire
Custody Conciliator
,SEP 2 8 2D01
KAYON R. CHIN,
Plaintiff
V.
DEBORAH L. CHIN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0.2007-3214
CIVIL ACTION -LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this t ~ ' day of _ , 2007, upon
consideration of the attached Custody Conciliat on Report, it is ordered and directed as
follows:
1. The prior Order of Court dated August 1, 2007 is hereby vacated.
2. The Father, Kayon R. Chin and the Mother, Deborah L. Chin, shall have
shared legal custody of Jason L. Chin, born November 18, 1991, Samantha J. Chin, born
September 11, 1993 and Kevin D. Chin, born July 23, 1996. 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 regarding their health, education and religion. Pursuant to the
terms of 23 Pa.C.S. §5309, 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 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 use to the other parent. Both parents
shall be entitled to full participation in all educational and medical/treatment planning
meetings and evaluations with regard to the minor children. Each parent shall be entitled
to full and complete information from any physician, dentist, teacher or authority and
copies of any reports given to them as parents including, but not limited to: medical
records, birth certificates, school or educational attendance records or report cards.
Additionally, each parent shall be entitled to receive copies of any notices which come
from school with regard to school pictures, extracurricular activities, children's parties,
musical presentations, back-to-school nights, and the like.
3. The parents shall have shared physical custody of the children on a week
on/week off basis with Friday at 6:00 p.m. being the exchange day and time. Father shall
have the first week beginning October 5, 2007. The non-custodial parent shall have
physical custody of the children Wednesday evening from 6:00 p.m. to 9:00 p.m.
4. Holidays:
.~ ~~
~ ')1' ....,fy
i
f~_d..i X51 l•... i~
. ,L, r1 "7 -i.-.
y Ir p
~lE+i .. "~:` k.~. rte?
A. Thanksgiving shall be alternated between the parties. Thanksgiving
shall be defined as Wednesday after school to Sunday at 6:00 p.m.
Father shall have physical custody of the children in odd numbered
years and Mother shall have physical custody of the children in even
numbered years.
B. Christmas shall be alternated between the parties. Christmas shall be
defined as Block A being from 6:00 p.m. on December 23 to after
church or 8:00 p.m. on December 24. Block B shall be from
December 24 from after church or 8:00 p.m. to December 25 at 8:00
p.m. Father shall have Block A in odd numbered years and Block B in
even numbered years. Mother shall have Block A in even numbered
years and Block B in odd numbered years.
C. Easter shall be alternated between the parties. Easter shall be defined
as Thursday after school to Sunday at 6:00 p.m. Father shall have
physical custody of the children in even numbered years and Mother
shall have physical custody of the children in odd numbered years.
D. Memorial Day shall be alternated between the parties. Memorial Day
holiday shall run from Friday at 6:00 p.m. to Tuesday morning.
Mother shall have physical custody in even numbered years and Father
shall have physical custody in odd numbered years.
E. Labor Day shall be alternated between the parties. Labor Day shall
run from Friday at 6:00 p.m. to Tuesday morning. Father shall have
physical custody of the children in even numbered years and Mother
shall have physical custody of the children in odd numbered years.
5. The parties shall cooperate with family counseling.
6. In the event that the custodial parent is not available to care for the
children overnight during their custodial period, the custodial parent must offer said time
to the non-custodial parent in a timely fashion so that the non-custodial parent may take
advantage of the time.
7. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
BY THE COURT,
~,
Kevin .Hess, J.
cc• eith O. Brenneman, Esquire, Counsel for Father
~da A. CLotfelter, Esquire, Counsel for Mother
J
KAYON R. CHIN,
Plaintiff
V.
DEBORAH L. CHIN,
Defendant
PRIOR JUDGE: None
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0.2007-3214 CIVIL ACTION -LAW
IN 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
Jason L. Chin November 18, 1991 Mother
Samantha J. Chin September 11, 1993 Mother
Kevin D. Chin July 23, 1996 Mother
2. A Conciliation Conference was held in this matter on September 28, 2007,
with the following in attendance: The Father, Kayon R. Chin, with his counsel, Keith O.
Brenneman, Esquire, and the Mother, Deborah L. Chin, with her counsel, Linda A.
Clotfelter, Esquire.
3. The Honorable Kevin A. Hess previously entered an Order of Court dated
August 1, 2007 providing for shared legal custody, Mother having primary physical
custody and Father having three weekends per month and every Wednesday overnight.
4. The parties agreed to an Order in the form as attached.
Date ac line M. Verney, Esquire
Custody Conciliator
0
KAYON R. CHIN,
Plaintiff
VS.
DEBORAH L. CHIN,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNS-fLV26N
NO. 2007-3214
. Zn
CIVIL ACTION - LAW ra
?
IN CUSTODY c k?j --a
c?
Prior Judicial Assignment: Kevin A. Hess, Judge r.?
Concurrence - Counsel for Defendant, Keith O. Brenneman, Esquire, presumably does not
concur with this Motion.
- Respondent/Plaintiff, Deborah L. Chin has been non-responsive to notice so
we presume she does not concur with this Motion.
PETITION TO WITHDRAW APPEARANCE
1. Petitioner is Linda A. Clotfelter, Esquire, (hereinafter "Petitioner") counsel
record for Defendant, Deborah L. Chin.
2. Respondent is Deborah L. Chin, (hereinafter "Respondent"), Defendant in
above-captioned matter.
3. Petitioner and Respondent have reached an impasse in their
relationship.
4. Petitioner asks to be released from this case to permit her to devote her time
other clients. There are no proceedings scheduled and thus Petitioner's request will not prej
Respondent.
5. Petitioner, a sole practitioner will face significant hardship if her request
withdraw as counsel is denied.
6. Denying Petitioner's request to withdraw as counsel will further
-3
damage Petitioner and her business.
7. Opposing counsel, Keith Brenneman, Esquire concurs with this request.
8. Petitioner sought Respondent's concurrence/nonconcurrence during a
telephone conversation but she would not take a position on either. She was to provide a
response but Petitioner has not heard from Respondent.
9. Petitioner now seeks leave of court to immediately withdraw as counsel
Respondent in this proceeding.
WHEREFORE, Petitioner respectfully requests the Court grant her leave to withdraw
appearance on behalf of Deborah L. Chin and terminate her representation of Deborah L. Chin.
Respectfully submitted,
Date: -7 /A q l ? 91 A
LAW FIRM OF LINDA A. CLOTFEL
LJ? DA A. CLOTFELTER, ESQUIRE
Allorney I.D. 72963
5021 E. Trindle Road, Suite 100
Mechanicsburg, PA 17050
(717) 796-1930 telephone
(717) 796-1933 facsimile
KAYON R. CHIN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVAN
VS. : NO. 2007-3214
DEBORAH L. CHIN, : CIVIL ACTION - LAW
Defendant : IN CUSTODY
CERTIFICATE OF SERVICE
AND NOW, this day of July, 2012, the undersigned hereby certifies that a
and correct copy of the foregoing PETITION TO WITHDRAW APPEARANCE was
upon the interested parties by United States First Class Mail, addressed as follows:
Keith Brenneman, Esquire
44 West Main Street
Mechanicsburg, PA 17055
(Attorney for Plaintiff)
Deborah L. Chin
5252 Meadowbrook Drive
Mechanicsburg, PA 17050
(Respondent)
Respectfully submitted,
LAW FIRM OF LINDA A. CLOTFELTER
.
Li da A. ClotfeTter, Esquire
A omey ID No. 72963
021 East Trindle Road, Suite 100
Mechanicsburg, PA 17050
(717) 796-1930 telephone
(717) 796-1933 facsimile
KAYON R. CHIN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
t-.
VS. : NO. 2007-3214
'
'tom -'Orr,
DEBORAH L. CHIN, : CIVIL ACTION - LAW v> rn
Defendant : IN CUSTODY r -? ; - `--=
y C ..
lea
RULE
AND NOW this 2 (Iday. of , 2012, upon consideration of the
Petition of Linda A. Clotfelter, Esquire, to withdraw as counsel for the Defendant, a Rule is
issued upon all parties to show cause why the Petition should not be granted, returnable 20
days from date of service.
BY THE COURT:
Distribution:
Linda A. Clotfelter, Esquire, 5021 E. Trindle Road, Suite 100, Mechanicsburg, PA 17050,
Attorney for Defendant
1/ Keith Brenneman, Esquire, 44 W. Main Street, Mechanicsburg, PA 17055, Attorney for Plaintiff
Deborah L. Chin, 5252 Meadowbrook Drive, Mechanicsburg, PA 17050, Respondent
4t es ma,'),ed '4acs ,a
le4c
GUw7-Ca i=lt
KAYON R. CHINS. PpTNONOTA? THE COURT OF COMMON PLEAS OF
plaintiff
ZB 12 AUG _ 2 AN 11: 40 CUMBERLAND COUNTY, PENNSYLVANI
VS. cUMBERLAND CQ A TYNO. 2007-3214
P'ENNSYLVAN
DEBORAH L. CHIN, : CIVIL ACTION - LAW
Defendant : IN CUSTODY
AFFIDAVIT OF SERVICE
I, Linda A. Clotfelter, Esquire, do hereby affirm that the Rule dated July 26, 2012, a
copy of which is attached) was sent by United States First Class Mail, postage prepaid, addressed
as follows. The undersigned understands that the statements herein are made subject to the
penalties of 18 P.S. § 4904 relating to unworn falsification to authorities.
Keith Brenneman, Esquire
44 West Main Street
Mechanicsburg, PA 17055
(Attorney for Plaintiff
Deborah L. Chin
5252 Meadowbrook Drive
Mechanicsburg, PA 17050
(Respondent)
Dated:
Respectfully submitted,
LAW OFFICE OF LINDA A. CLOTFELTER
L" da A. Clotfelter, Esquire
o
P rney ID No. 72963
5021 East Trindle Road, Suite 100
Mechanicsburg, PA 17050
telephone (717) 796-1930
facsimile (717) 796-1933
Attorney for Defendant
KAYON R. CHIN,
Plaintiff
VS.
DEBORAH L. CHIN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSY-UVANI
NO. 2407-3214 rn' t-' cr
-r !,l
. CIVIL ACTION - LAW =' rn
: IN CUSTODY =c c
-,
c.
RULE
AND NOW this mil- W, day of ?"2 al' . 2012, upon consideration of 1
Petition of Linda A. Clotfelter, Esquire, to withdraw as counsel for the Defendant, a Rule
issued upon all parties to show cause why the Petition should not be granted, returnable
days from date of service.
Distribution:
BY THE COURT:
J.
TRUE COPY FROM RECCR
In Testimony whereof, I here unto set my
and the seat of said Co n at Parlisle, Pa.
This day of
20 1
Prothon
Linda A. Clotfelter, Esquire, 5021 E. Trindle Road, Suite 100, Mechanicsburg, PA 17050.
Attorney for Defendant
Keith Brenneman, Esquire, 44 W. Main Street, Mechanicsburg, PA 17055, Attorney for Plaintiff
Deborah L. Chin. 5252 Meadowbrook Drive, Mechanicsburg, PA 17050, Respondent
r
KAYON R CHIN,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF '
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2007-3214
~:
~~ . t
C., ! Cw +-
~ .--- ~~ ,
DEBORAH L. CHIN, :CIVIL ACTION -LAW ~ *-~ °_. ~ ~,
Defendant : IN CUSTODY ~-~ ~ ~ ~_
2~ ~ r
Prior judicial assignment: Kevin A. Hess, Judge ~~ `s' ':'
Concurrence/Nonconcurrence: See paragraph 3 below v ~ ~ N
PETITIONER'S MOTION TO MAKE RULE ABSOLUTE ~ ~ E,,,,
.ter C', ° ~'
1. On July 24, 2012, Petitioner, Linda A. Clotfelter, Esquire, filed a Petition to
Withdraw Appearance and on July 26, 2012, a Rule was issued upon Defendant to show cause
why the relief requested should not be granted.
2. On July 31, 2012, Petitioner served Defendant with the Rule to show cause on
Petition to Withdraw Appearance and terminate representation as Defendant's counsel.
3. As per the Rule dated July 26, 2012, the 21-day return date was passed without
answer by Defendant, and Petitioner now seeks to have the Rule made absolute.
WHEREFORE, Petitioner respectfully requests the Court to make the Rule absolute
to grant her permission to withdraw as counsel for Defendant, Deborah L. Chin, in the above-
captioned proceeding.
Respectfully submitted,
LAW FIRM OF LINDA A. CLOTFEL
Date: $ 1
nda A. Clotfelter, Esquire
ttorney ID No. 72963
021 East Trindle Road, Suite 1
Mechanicsburg, PA 17050
(717) 796-1930 telephone
(717) 796-1933 facsimile
KAYON R CHIN,
Plaintiff
vs.
DEBORAH L. CHIN,
DefendAnt
IN THE COURT OF COMMON PLEAS OF ~
CUMBERLAND COUNTY, PENNSYLVANI.~
NO. 2007-3214
CIVIL ACTION -LAW
IN CUSTODY
VERIFICATION
I, Linda A. Clotfelter, Esquire, verify that the statements in the foregoing
Rule to Make Motion Absolute are true and correct to the best of my knowledge,
and belief. I understand that false statements herein are made subject to the penalties of 18
C.S. § 4904, relating to unsworn falsification to authorities.
Date:
Lin A. Clotfelter, Esquire
Att rney ID No. 72963
East Trindle Road, Suite 100
Mechanicsburg, PA 17050
(717) 796-1930 telephone
(717) 796-1933 facsimile
s
KAYON R CHIN, : IN THE COURT OF COMMON PLEAS OF ~
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
vs. : NO. 2t~7-331
HEBORAH L. CHIN, :CIVIL ACTION -LAW
Defendant : IN CUSTODY
CERTIFICATE OF SERVICE
AND NOW, this /~ $t~ day of - , 2012, the undersigned hereby
that a true and correct copy of the foregoing Petitioner's Motion to Make Rule Absolute
served upon the opposing party by United States First Class Mail, postage prepaid, addressed
follows:
Keith Brenneman, Esquire
44 West Main Street
Mechanicsburg, PA 17055
(Attorney for Plaintiff)
Deborah L. Chin
5252 Meadowbrook Drive
Mechanicsburg, PA 17050
(Respondent)
Respectfully submitted,
LAW FIRM OF LINDA A. CLOTFELTER
L' da A. Clotfelter, Esquire
ttorney ID No. 72963
5021 East Trindle Road, Suite 100
Mechanicsburg, PA 17050
(717) 796-1930 telephone
(717) 796-1933 facsimile
ICAYON R. CHIN,
Plaintiff
vs.
DEBORAH L. CHIN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2007-3214
CIVIL ACTION -LAW
IN CUSTODY
ORDER
AND NOW, this ~' day of Sa~~r 2012 upon consideration of
Petitioner's Motion to Make Rule Absolute, said motion is hereby GRANTED.
BY THE COURT,
-,~ 3 -~,~
cn ~
~~ cn
~° a
r~
_~ ~
A.... ..
i~A~ Hess, Judge ~ `-
Distribution:
c,__•
_,~
m ~'
~--
-~~:
c '~'
~-' s=,
--sue'
~~
Linda A. Clotfelter, Esquire, 5021 E. Trindle Road, Sure 100, Mechanicsburg, PA 17050,
Attorney for Defendant
/ Keith Brenneman, Esquire, 44 W. Main Street, Mechanicsburg, PA 17055, Attorney for Plaintiff
/ Deborah L. Chin, 5252 Meadowbrook Drive, Mechanicsburg, PA 17050, Respondent
~' ~~eS tMa; l-eQ ~'/,S~i~