HomeMy WebLinkAbout07-3983T
ERICA L. HOOVER,
Plaintiff
v.
BRAD FAILOR,
Defendant
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 67 -3 y g 3 CIVIL TERM
CIVIL ACTION-LAW
IN CUSTODY
CUSTODY COMPLAINT
1. Plaintiff is Erica L. Hoover, an adult individual who currently resides at 8
Wagner Drive, Shippensburg, Cumberland County, Pennsylvania.
2. Defendant is Brad Failor, an adult individual who currently resides at, 826
Doubling Gap Road, Newville, Cumberland County, Pennsylvania.
3. The parties are the parents one minor child, namely, Caleb E. Failor, born
July 27, 2005.
The child was born out of wedlock.
The child is presently in the custody of Plaintiff at 8 Wagner Drive,
Shippensburg, Cumberland County, Pennsylvania.
During the past five years, the child has resided with the following persons
at the following addresses:
Persons Residences Dates
Erica L. Hoover 8 Wagner Drive March, 2007 to
Nancy Hoover Shippensburg, Pennsylvania Present
Dale Hoover
Erica L. Hoover 6046 N. Baltimore Avenue March, 2006 to
Mt. Holly Springs, Pennsylvania March, 2007
Erica L. Hoover Plaza Drive April, 2005 to
Brad Failor Boiling Springs, Pennsylvania March, 2006
The natural father of the child is Brad Failor, currently residing at 826 Doubling
Gap Road, Newville, Cumberland County, Pennsylvania.
He is not married.
The natural mother of the child is Erica L. Hoover, currently residing at 8
Wagner Drive, Shippensburg, Cumberland County, Pennsylvania.
She is not married.
4. The relationship of the Plaintiff to the child is that of natural mother. The
plaintiff currently resides with the following persons:
Names Relationship
Caleb E. Failor Son
Nancy Hoover Mother
Dale Hoover Father
5. The relationship of the Defendant to the child is that of natural father. The
defendant currently resides with the following persons:
Names
Relationship
6. Plaintiff has not participated as a party or witness, or in another capacity,
in other litigation concerning the custody of the child in this or another court.
Plaintiff has no information of a custody proceeding concerning the child
pending in a court of this Commonwealth or any other state.
Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the child or claims to have custody or visitation rights with respect to
the child.
7. The best interest and permanent welfare of the child will be served by
granting the relief requested because mother has been the primary physical custodian
of the child.
8. Each parent whose parental rights to the child have not been terminated
and the person who has physical custody of the child have been named as parties to
this action. All other persons, named below, who are known to have or claim a right to
custody or visitation of the child will be given notice of the pendency of this action and
the right to intervene: none
WHEREFORE, Plaintiff requests your Honorable Court to grant her shared legal
and primary physical custody of the child.
Date: ~~ ~' ~ 7 Respectfully submitted,
O'BRIEN, BARK & SCHERER
~ti~
Michael A. Scherer, Esquire
I.D. # 61974
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
VERIFICATION
I verify that the statements made in the foregoing Custody Complaint are true
and correct. 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: ~u-~Q., 2 S ~ ~ a~ ~'
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ERICA L. HOOVER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
BRAD FAILOR
DEFENDANT
• 07-3983 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Monday, July 09, 2007 ,upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. ,the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, August 09, 2007 at 1:00 PM
for aPre-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 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/ ohn .Man an r. 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
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ERICA L. HOOVER, IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. .
No. 07-3983 Civil Term
BRAD FAILOR
Defendant :ACTION IN CUSTODY
COURT ORDER
AND NOW, this ~' ~ay of August, 200?, upon consideration of the attached
Custody Conciliation Report, it is ordered and directed that:
1. The Mother, Erica Hoover and the Father, Brad Failor, shall enjoy shared legal
custody of Caleb E. Fallor, born July 27, 2005. The parties shall have an equal
right to make all major non-emergency decisions affecting the Child's general
well-being including, but not limited to, all decisions regarding his health,
education and religion.
2. The Mother shall enjoy primary physical custody of the Child.
3. The Father shall have partial physical custody of the Child one day per week for
four hours, or overnight as the parties may mutually agree, and every other
weekend from Saturday 9:00 am until Sunday 7:00 pm.
4. The non-custodial party, or their representative, shall pick up Caleb Failor for the
exchanges.
5. Holidays with Caleb Failor shall be shazed as mutually agreed upon.
6. In the event of a medical emergency, the custodial party shall notify the other
parties as soon as practicable after the emergency is handled.
7. The parties shall refrain from making derogatory comments about the other party
in the presence of the Child, and to the extent possible, shall prevent third parties
from making. such comments in the presence of the Child.
8.
This Order is entered pursuant to 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.
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Cc: Michael A. Scherer, Esquire
John J. Mangan, Esquire
Brad Failor, 826 Doubling Gap Rd., Nevwille, PA
ERICA L. HOOVER,
Plaintiff
v.
BRAD. FAILOR
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 07-3983 Civil Term
ACTION IN CUSTODY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF
PROCEDURE 1915,,3-8(B), the undersigned Custody Conciliator submits the following
report:
1. The pertinent information pertaining to the child who is the subject of this
litigationis as follows;
Caleb E. Failor, born July 27, 2005, currently in the primary physical custody of
Plaintiff Mother.
2. A Conciliation Conference was held on August 9, 2007 with the following
individuals in attendance:
The Father, Brad Failor did not appear and is apparently pro se
The Mother, :Erica HooverNicole Engle, with her counsel, Michael Scherer,
Esquire.
3. .The parties agreed to the entry of an Order in the form as attached.
Date: August 9, 2007 ~- _ .
Jo J. gan, Esq ' e
C tody Conciliato
OM ~'
LILAKIS
Michelle L. Sommer, Esquire
AttorneyZD. #: 93034
2 West High Street
Carlisle, PA 17013
(717) 249-0900
ERICA L. HOOVER,
Plaintiff/Petitioner
v.
BRAD FAILOR,
Defendant/Respondent
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-3983 CIVIL TERM
CNIL ACTION -LAW
IN CUSTODY
AND NOW, comes the Petitioner, ERICA L. HOOVER, by and through her
attorney, Michelle L. Sommer, Esquire, of ABOM & KUTULAKIS, L.L.P., and respectfully
Petitions for Modification of Custody, and in support thereof avers the following:
1. Petitioner is Erica L. Hoover, Plaintiff/Petitioner (hereinafter referred to as
"Mother"), who currently resides at 775 Hamilton Court, Carlisle, Cumberland
County, Pennsylvania.
2. Respondent is Brad Failor, Defendant/Respondent (hereinafter referred to as
"Father"), who currently resides at 924 Gobin Drive, Carlisle, Cumberland County,
Pennsylvania and is represented by Jane Adams, Esquire.
3. On or about June 7, 2010, .the parties executed a Custody Stipulation and
Agreement, wherein the parties share legal custody of Caleb E. Failor .(hereinafter
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referred to as "ChiIc~') as set forth in the Custody Stipulation and Agreement
attached hereto and made a part hereof marked "Exhibit A".
4. Father has primary physical custody of the Child.
5. Mother has liberal periods of partial physical custody with the Child, including
every other weekend from Friday at 7:00 p.m. to Sunday at 7:00 p.m.
6. The Order was signed by the Honorable J. Wesley Oler, Jr., on June 14, 2010.
7. Paragraphs one (1) through six (6) of this Complaint are incorporated herein by
reference as though set forth in full.
8. This Agreement should be modified because:
a. Mother has experienced a change in circumstances that allow her to
devote more attention to the Child based on her having a more stable
personal life, and so she is requesting shared physical custody of the Child.
b. Mother was previously in an abusive relationship, which required her to
allow Father to have the Child on a consistent basis; as well as remove the
Child from the unsafe situation that was occurring in Mother's home.
c. The arrangement between the parties was entered into on a temporary
basis until Mother was able to establish stability in her personal life.
i. Unfortunately,- Mother was pro se during the signing of this Custody
Stipulation and was unclear about several provisions; however, she was
reassured by Father that this was a temporary agreement until Mother
could remove herself from the difficult situation that she was currently
experiencing at that specific. time in her life.
ii. Prior to the signing of the Custody Stipulation, Mother is the one who
had primary physical custody of the Child with Father having periods
of partial custody; therefore, by the signing of the Custody Stipulation
it reversed the roles completely.
d. Mother has dealt with the issues that raised concerns earlier; and as a
result is seeking to share custody with Father so the Child can benefit
from the love and care that both parents can provide for the Child.
e. With Mother no longer having personal issues, there is no compelling
reason to not allow her to share in the physical custody of the Child.
f. Mother and Father only have approximately 15 houses in between them;
therefore, a shared custody arrangement would be beneficial to the Child
in that he could spend a significant time with both his parents.
g. Mother would also like to modify the current Custody Stipulation since
the agreement states that the parties have Shared Legal Custody of the
Child; however, it further states that "[i]n the event of an emergency, the
party with physical custody shall make any emergency decisions, and
contact the other party as soon as practicable after the emergency is
handled."
i. Since Father has physical custody of the Child, Mother is unable to be
involved in emergency situations should one happen to arise and is not
to be contacted until after the emergency is handled.
ii. It is believed and therefore averred that this is not considered "shared
legal custody" and the Custody Stipulation that was signed on June 7th
was not an accurate reflection of what Mother wanted regarding legal
custody.
h. Mother would also like to modify the current Custody Stipulation since
the agreement needs to be more specific in that the current holiday
schedule is extremely vague in that it states "[t]he parties shall divide
holidays, on a generally equal basis, with each party to have a -block of
time with -the child on each holiday."
' i. It is believed and therefore averred that without a complete .listing of
the holidays and times the parties are to have the Child, the parties are
setting themselves up for conflict and debate for each and every
holiday that approaches.
ii. It is believed and therefore averred that since the Stipulation signed on
June 7th is so vague it should more specifically outline the holidays and
times the parties are to have the Child for the day.
WHEREFORE, the Petitioner requests that this Court modify the existing Custody
Stipulation and Order to accommodate the changed circumstances in Mother's life and
address the outstanding issues regarding Legal Custody and the holiday schedule in the
existing Stipulation.
Respectfully submitted,
ABOM ~r KUTULAKIS, L.L.P.
DATE 1 I~~~ { W v
Michelle L. Sommer, Esquire
Supreme Court ID 93034
2 West High Street
Carlisle, Pennsylvania 17013
(717) 249-0900
Attorney for Plainti~/Petitioner
I, ERICA L. HOOVER, verify that the statements .made in this Petition for
Modification of Custody 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.
9
Date
E A L.
JUN ~ ~~ 2010
ERICA L. HOOVER,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 07 - 3983 Civil Term
BRAD TAILOR, CIVIL ACTION -LAW
Defendant IN CUSTODY
ORDER
AND NOW, this /y'~'~ day of -~i-wE , 2010, having reviewed
the attached agreement between the parties, it is hereby ORDERED and DECREED
that the stipulation entered by the parties on June 7, 2010, .shall be entered and
incorporated into this Order of Court.
BY THE COURT:
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cc: Jane Adams, Esquire, for father
Erica L. Hoover, self-represented
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TRUE Copy {~RO~ RECtJRD
In Testimony whereof, I here into set my hand
and then sea of said C urt at Carlisle, pa,
This -~L' tiay of , j, , ~ ~ ,.
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1ANE ADAMS _~ ~~,"'~~
ATTORNEY AT LAW
Attorney LD. No. 79465
17 W. South St.
Carlisle, Pa. 17013
(717) 245-8508
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ERfCA L. HOOVER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. 07 - 3983 Civil Term
BRAD FAILOR, CIVIL ACTION -LAW
Defendant IN CUSTODY
CUSTODY STIPULATION
WHEREAS, the parties are the natural parents of one child, namely,
Caleb E. Faitor, born July 27, 2005, and;
WHEREAS, the parties wish to enter their stipulation as a court Order, without
the necessity for a hearing; the parties hereby stipulate and agree as follows:
1. Legal Custody. The Father, Brad Faitor, and the Mother, Erica L. Hoover,
shall have shared legal custody of their child, Caleb E. Faitor, born July 27, 2005.
The parties shah have an equal right to make all major non-emergency decisions
affecting their child's general well-being, including,. but not lim-ted #o, ?II decisions
regarding health, education, and religion. Pursuant to the terms of 23 Pa.C.S. §5309,
each parent sha{I be entitled to all records and information pertaining to .the child,
including, but not limited to, medical, dental, religious, or school records, the residence
address of the child and of 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.
In the event of an emergency, the party with physical custody shall make any
emergency decisions, and contact the other party as soon as practicable after the
emergency is handled.
2. Physical Custody. Father shall have primary physical custody of the child.
Mother shall have liberal periods of partial physical custody, with the child, including the
times as follows:
a. Every other weekend from Friday at 7:00 p.m. Through Sunday at 7:00 p.m.
b. Additional times as mutually agreed by the parties.
3. Vacations and HOlidays. Regarding vacations and holidays, the parties
agree as follows:
a. .Each party may have the child for an up to one-week period, when school is
not in session, for vacation, upon thirty days notice to the other parent. One week
consists of six overnights. A party exercising vacation time shall inform the other
parent as to the location, basic itinerary, and a contact address and telephone number
for the hotel or lodging for the trip. The child shall not be taken out of state by either
party without the approval of the other; however, such approval shall not be
unreasonably withheld.
b. The parties shall divide holidays, on a generally equal basis, with each party
to have a block of time with the child on each holiday.
Transportation: The parties shall share transportation for all exchanges. The
receiving party will provide transportation for each exchange.
4. EXPENSES. THE PARTIES SHALL COOPERATE IN OBTAINING HEALTH INSURANCE FOR
THE CHILD AT THE LOV\lEST COST POSSIBLE AND SHALL EXCHP,NGE ALL INFORMATION AND
IDENTIFICATION CARDS REGARDING THE CHOSEN HEALTH INSURANCE. THE PARTIES WILL
EQUALLY DIVIDE ALL UNREIMBUR$ED MEDICAL EXPENSES FOR THE CHILD. THE PARTIES WILL
ALSO EQUALLY DIVIDE ANY EXPENSES FOR THE CHILD RELATING TO EXTRACURRICULAR OR
OTHER REASONABLE ACTIVITIES.
NOTHING IN THIS SECTION SHALL AFFECT THE FACT THAT CHILD SUPPORT IS MODIFIABLE
UPON A SUBSTANTIAL CHANGE OF CIRCUMSTANCES, OR OBLIGATE EITHER PARTY TO PAY AN
AMOUNT OF CHILD SUPPORT, WITHOUT REGARD TO THE APPLICABLE CHILD SUPPORT
GUIDELINES.
5. Disgaraginq Remarks. Neither party may say or do anything nor permit a
third party to do or say anything that may estrange the child from the other party, or
injure the opinion of the child as to the other party, or may hamper the free and natural
development of the child's love and affection for the other party. To the extent possible,
both parties shall not allow third parties to disparage the other parent in the presence of
the child.
6. Telephone contact: Telephone contact between the child and the
non-custodial parent shall be reasonable and liberal as agreed upon between the
parties.
7. Stipulation, Modification, and Order. This Stipulation is entered pursuant to
an agreement of the parties. The parties agree that this stipulation may be
incorporated as an Order of Court and may be enforceable as an Order of Court. The
parties may modify the provisions of this Order by mutual consent. If a substantial
modification is to be made to the schedule, the party requesting the modification will
provide at least seven days notice. In the absence of mutual consent, the terms of this
agreement and Order shall control.
WITNESSETH:
I
WIT ESS ICA L. HOOVE ,MOTHER
DATE: ,
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WITNESS RAD FAILO ATHER
DATE:. Cn ` I? - ~`
AND NOW, this 2nd day of September 2010, I, Michelle L. Sommer, Esquire, of
Abom & Kutulakis, L.L.P., hereby certify that I did serve a true and correct copy of the
foregoing Petition for Modification of Custody, upon the Defendant's Attorney by
depositing, or causing to be deposited, same in the United States Mail, postage prepaid
addressed to the following:
Jane Adams, Esquire
17 W. South Street
Carlisle, PA 17013
Attorney for the Defendant/I~e.-~iondent
Respectfully submitted,
Abom ~ Kutulakis, L.L.P.
Michelle L. So er, Esquire
Attorney ID No. 93034
2 West High Street
Carlisle, PA 17013
(717) 249-0900
Attorney for Plainti~/Petitioner
ERICA L. HOOVER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. 2007-3983 CIVIL ACTION LAW
BRAD FAILOR
DEFF,NDANT
IN CUSTODY
ORDER OF COURT
AND NOW, _ Wednesday, September 08, 2010 upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, October 12, 2010 at 2:30 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. 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/ . john . Man an r. Es .
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to complN "N ith 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. I
Cumberland County Bar Association
10 1c) Cd?? Via:, ?? 32 South Bedford Street r -,
c?
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
to, to
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ABOM dZ'
Kurur_nxis
Michelle 1,. Sommer, 1?syuire
Attomcy Lll. #: 93034
2 ~X/est High Street
Carlisle, PA 17013
(717) 249-0900
ERICA L. HOOVER,
Plaintiff/Petitioner
v.
BRAD FAILOR,
Defendant/Respondent
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-3983 CIVIL TERM
CIVIL ACTION -LAW
IN CUSTODY
TO THE PROTHONOTARY OF SAID COURT:
PRAECIPE TO WITHDRAW PETITION FOR MODIFICATION OF CUSTODY
AND NOW, comes the Petitioner, ERICA L. HOOVER, by and through her
attorney, Michelle L. Sommer, Esquire, of ABOM & KUTULAKIS, L.L.P., respectfully requests
to Withdraw her Petition for Modification of Custody that was filed on September 2, 2010,
and requests that Conciliation scheduled for October 12, 2010, before Conciliator John J.
Mangan, Jr., Esquire, be cancelled.
D~~ ~ ~ (~
Respectfully submitted,
ABOM ~ KUTULAxIS, L.L.P.
Michelle L. Sommer, Esquire
Supreme Court ID No. 93034
2 West High Street
Carlisle, Pennsylvania 17013
(717) 249-0900
Attorney for the Plaint/Petitioner
('FRTIFICATE OF SERVICE
AND NOW, this 21~t day of September 2010, I, Michelle L. Sommer, Esquire, of
Abom & Kutulakis, L.L.P., hereby certify that I did serve a true and correct copy of the
foregoing Praecipe to Withdraw the Petition for Modification of Custody, upon the
Defendant's Attorney by depositing, or causing to be deposited, same in the United States
Mail, postage prepaid addressed to the following:
Jane Adams, Esquire
17 W. South Street
Carlisle, PA 17013
Attorney for the Defendant/Ke,rpondent
John J. Mangan, Esquire
17 W. South Street
Carlisle, PA 17013
Custody Conciliator
Respectfully submitted,
ABOM ~ KUTULAKIS, L.L.P.
~-
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Michelle L. So r, Esquire
Supreme Court ID No. 93034
2 West High Street
Carlisle, Pennsylvania 17013
(717) 249-0900
Attorney for the Plaint/Petitioner