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HomeMy WebLinkAbout03-5044RANDALL A. JOHNSON, Plaintiff VS. MEGAN E. JOHNSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. IN CUSTODY CIVIL ACTION - LAW COMPLAINT FOR CUSTODY AND NOW COMES Plaintiff, Randall A. Johnson, attorneys, Purcell, Custody Complaint: 1. Plaintiff is currently resides Cumberland County, by his Krug &Haller, and files the following Randall A. Johnson, an adult individual who at 1210 Edinburg Circle, New Cumberland, Pennsylvania 17070. 2. Defendant is Megan E. Johnson, an adult individual who currently resides at 100 Penns Run Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff seeks shared legal and physical custody of the following child: Name Chase Randall Johnson Present Residence 100 Penns Run Road 4. The child was not born out of wedlock. Date of Birth/Ace 10/25/00 (age 2) 12. will be WHEREFORE, Honorable Court custody of the minor child. Date: The best interests and permanent welfare of the child served by granting the relief requested. the Plaintiff respectfully requests this to grant them shared physical and shared legal PU~ELL, KRUG & HALLER By Esq. /1719 No~th ~nt~ Street / Harrisbhrg, PA 17102 I.D. No. 79866 (717)234-4178 Attorney for Plaintiff VERIFICATION I, Randall A. Johnson , hereby verify that the facts contained in the foregoing Complaint for Custody are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. CERTIFICATE OF SERVICE I, TRICIA KOWALCZYK, an employee of the law firm of Purcell, Krug &Haller, counsel for Plaintiff, hereby certify that service of the foregoing COMPLAINT IN CUSTODY was made upon the following by Certified Mail, Return Receipt Requested, Postage Prepaid on Megan E. Johnson c/o Mark K. Emery, Esquire 410 North Second Street Harrisburg, PA 17101 RANDALL A. JOHNSON PLAINTIFF V. MEGAN E. JOHNSON DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-5044 CIVIL ACTION LAW iN CUSTODY ORDER OF COURT AND NOW, Thursday, September 25, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Tuesday, October 28, 2003 at 10:30 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 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/ Melissa P. Greevy. Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law m 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 TItlS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT ItAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ltELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3 166 RANDALL A. JOHNSON, Plaintiff V. MEGAN E. JOHNSON, Defendant DEC I 6 2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5044 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY TEMPORARY ORDER OF COURT AND NOW, this ~ day of December, 2003, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Randall A. Johnson and Megan E. Johnson, shall have shared legal custody of the minor child, Chase Randall Johnson, born October 25, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, 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. Pursuant to the terms of Pa. C. S. §5309, each parent shall 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. 2. Physical Custody. Mother shall have primary physical custody subject to Father's rights of partial custody which shall be arranged as follows: A. Each week after preschool on Thursday until 7:15 p.m. B. To commence November 30, 2003, each Sunday from 11:00 a.m. to 5:00 p.m. C. To commence November 22, 2003, on alternating weekends from Saturday at 6:00 p.m. until Sunday at 5:00 p.m. The parties contemplate that Father's overnight periods of custody for the period from Saturday at 6:00 p.m. until Sunday at 6:00 p.m. shall occur each week, commencing June 5, 2004. NO. 03-5044 CIVIL TERM D. Father shall have custody from January 2nd at 7:00 p.m. until January 3rd at 6:00 p.m. This shall replace Father's ordinary Saturday to Sunday overnight. 3. The custodial exchange shall occur with the parties meeting at Marshall's in Silver Spring Township. 4. Holidays. The following holiday schedule shall supersede the regular schedule. A. Mother's Day / Father's Day. Mother shall have custody for Mother's Day. Father shall have custody for Father's Day. B. Thanks.qiving. Father shall have custody on Thanksgiving Day each year from 9:00 a,m. to 2:00 p.m. C. Christmas. Christmas shall be shared on an A/B schedule. Segment A shall be from December 24th at Noon until December 25th at Noon. Segment B shall be from December 25th at Noon until December 26th at Noon. In odd-numbered years, Mother will have Segment A and Father will have Segment B. In even-numbered years, Father will have Segment A and Mother will have Segment B. The return time for Father on the years that he has Segment A may vary, dependent upon his work schedule. D. Easter. Father will have custody for Easter each year from Saturday at 6:00 p.m. until Sunday at 11:00 a.m. Mother will have custody each Easter Day commencing at 11:00 a.m. Sunday. E. Alternatinq Holidays. The parties will alternate the following holidays commencing with Father having custody in 2004 for Memorial Day: Memorial Day, Independence Day, and Labor Day. The custodial period for Memorial Day and Labor Day shall be from Sunday at 6:00 p.m. until Monday at 10:00 p.m. If there are no fireworks on Monday, the return time shall be 6:00 p.m. The custodial period for Independence Day shall be from July 3rd at 6:00 p.m. until July 4th at 10:00 p.m. F. New Year's Eve / New Year's Day. Each year the parties will alternate the New Year's holiday which shall be defined as that period from December 31st at 4:00 p.m. until January 1st at 6:00 p.m. Father shall have custody for this holiday in 2003 and subsequent odd-numbered years. Mother shall have custody for this holiday in even-numbered years. NO. 03-5044 CIVIL TERM 5~ Cumberland County Court of Common Pleas for the Commonwealth of Pennsylvania shall retain jurisdiction of this matter. 6. Within six (6) months of the date of this Order, Father shall participate in a parenting class. 7. The Custody Conciliation Conference shall reconvene on February 23, 2004 at 9:30 a.m. at the office of the Custody Conciliator, Melissa Peel Greevy, Esquire, 301 Market Street, Lemoyne, PA 17043. At the time the Custody Conciliation Conference reconvenes, by mutual agreement of the parties, it is contemplated that Father's request for long weekends, vacation time and a four-day period of custody, to run from Thursday to Monday in May 2004 will be discussed. Dist: BY THE COURT: ~l¢l~aCOle M. Staley O'Gorrnan, Esquire, 1719 N. Front Street, Harrisburg, PA 17102 rk K. Emery, Esquire, 510 N. Second Street, Harrisburg, PA 17101 RANDALL A. JOHNSON, Plaintiff V. MEGAN E. JOHNSON, Defendant DEC 1 $ 2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5044 CIVIL TERM 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 child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Chase Randall Johnson October 25, 2000 Mother 2. Father flied a Complaint for Custody on September 24, 2003. A Custody Conciliation Conference was held on November 18, 2003 with the following individuals in attendance: the Father, Randall A. Johnson, and his counsel, Nicole Staley O'Gorman, Esquire; the Mother, Megan E. Johnson, and her counsel, Mark K. Emery, Esquire. 3. The parties reached an agreement in the f/proof an Order as attached. Date v Mefissa Peel Greevy, Esquire Custody Conciliator :221782 BEC 1 0 ~.BI3 RANDALL A. JOHNSON, Plaintiff V. MEGAN E. JQHNSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5044 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUMBERLAND COUNTY COURT ADMINISTRATOR ONE COURTHOUSE SQUARE CARLISLE, PA 17013 TEMPORARY ORDER OF COURT 510 N. SECOND STR~EET ~"'-~ HARRISR~ ~R~ PA/t7101 ~ ~A ~ ~SUFFICIENTADDRESS~ ~ ( ~p ~ATTEMPTED NOT KNOWN ~ OTHER - UNABLE TO FORWARD MAR 0 2 ~004 ~ RANDALL A. JOHNSON, Plaintiff V. MEGAN E. JOHNSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5044 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY OLER, J. --- TEMPORARY ORDER OF COURT AND NOW, this .2, ,,- ~ day of 1~ ~j ~_~ ,2004, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. This Court's prior Order of December 17, 2003 is vacated in its entirety. 2. Le.qal Custody. The parties, Randall A. Johnson and Megan E. Johnson, shall have shared legal custody of the minor child, Chase Randall Johnson, born October 25, 2000. Each parent shall have an equal right, to be exemised jointly with the other parent, 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. Pursuant to the terms of Pa. C. S. §5309, each parent shall 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. 3. Physical Custody. Mother shall have primary physical custody subject to Father's rights of partial custody which shall be arranged as follows: A. Each week after preschool on Tuesday until 7:15 p.m. B. To commence February 28, 2004 on alternate weekends from Saturday at 6:00 p.m. until Sunday at 5:00 p.m. In addition, if Father has the day off from work on Saturday of his regularly scheduled custodial weekend, Father's custodial weekend shall commence at 8:00 p.m. on Friday. Should this occur, Father will inform Mother by Monday preceding his Saturday off. 4. The custodial exchange shall occur with the parties meeting at Marshall's in Silver Spring Township. NO. 03-5044 CIVIL TERM 5. Holidays. The following holiday schedule shall supersede the regular schedule. A. Mother's Day / Father's Day. Mother shall have custody for Mother's Day. Father shall have custody for Father's Day. B. Thanks,qivin,q. Father shall have custody on Thanksgiving Day each year from 9:00 a.m. to 2:00 p.m. C. Christmas. Christmas shall be shared on an NB schedule. Segment A shall be from December 24th at Noon until December 25th at Noon. Segment B shall be from December 25th at Noon until December 26th at Noon. In odd-numbered years, Mother will have Segment A and Father will have Segment B. In even-numbered years, Father will have Segment A and Mother will have Segment B. The return time for Father on the years that he has Segment B may vary, dependent upon his work schedule. D. Easter. Father will have custody for Easter each year from Saturday at 6:00 p.m. until Sunday at 11:00 a.m. Mother will have custody each Easter Day commencing at 11:00 a.m. Sunday. E. Alternatin,q Holidays. The parties will alternate the following holidays commencing with Father having custody in 2004 for Memorial Day: Memorial Day, Independence Day, and Labor Day. The custodial period for Memorial Day and Labor Day shall be from Sunday at 6:00 p.m. until Monday at 10:00 p.m. If there are no fireworks on Monday, the return time shall be 6:00 p.m. The custodial period for Independence Day shall be from July 3rd at 6:00 p.m. until July 4th at 10:00 p.m. F. New Year's Eve / New Year's Day. Each year the parties will alternate the New Year's holiday which shall be defined as that period from December 31St at 4:00 p.m. until January 1st at 6:00 p.m. Father shall have custody for this holiday in 2003 and subsequent odd-numbered years. Mother shall have custody for this holiday in even-numbered years. 6. Cumberland County Court of Common Pleas for the Commonwealth of Pennsylvania shall retain jurisdiction of this matter. NO. 03-5044 CIVIL TERM 7. Vacation. A. Each parent shall be entitled to eight (8) consecutive days for vacation upon thirty (30) days prior written notice to the other party. In the event that the parties have arranged conflicting schedules for vacation, the party first providing written notice to the other party shall have choice of the vacation time. Additionally, the vacationing parent shall provide a telephone number and location where they can be reached during the vacation. B. Father will have custody from May 28, 2004 through June 1, 2004. C. Father will have ten (10) additional custodial days each year to add to his weekends such that, when combined with his existing weekend time, he will have custody for a long weekend totaling four (4) consecutive days. Father will provide Mother with ten (10) days notice of any intended use of the additional days under this subpart. 8. In light of the parties' existing school and work schedules and the potential for changes in those schedules, it is contemplated that the custodial time provided herein may need to be rearranged. The parties are encouraged to make such adjustments in order to facilitate the frequent and continuing contact of the child with both parents. Dist: BY THE COURT: J~ye~ley Oler<~. ~.- Nicole M. Staley O'Gorman, Esquire, 1719 N. Front Street, Harrisbu~, PA 17102 Mark K. Emery, Esquire, 410 N. Second Street, Harrisburg, PA 17101 RANDALL A. JOHNSON, Plaintiff V, MEGAN E. JOHNSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY; PENNSYLVANIA NO. 03-5044 CIVIL TERM 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 child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLYIN THE CUSTODY OF Chase Randall Johnson October 25, 2000 Mother 2. The Custody Conciliation Conference was reconvened on February 24, 2004 with the following individuals in attendance: the Father, Randall A. Johnson, and his counsel, Nicole Staley O'Gorman, Esquire; the Mother, Megan E. Johnson, and her counsel, Mark K. Emery, Esquire. 3. The parties reached an agreement in the f~ Order as attached. Date ' sa Peel Greevy, Esquir~ Custody Conciliator :224859 MEGAN E. JOHNSON Plaintiff · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA vs. · NO. 03-5044 RANDALLA. JOHNSON De~ndant · CIVIL ACTION -LAW · IN DIVORCE MOTION TO COMPEL ANSWERS TO INTERROGATORIES AND NOW, comes Plaintiff, Megan E. Johnson, by and through her attorney, Mark K. Emery, Esquire, and files this Motion to Compel Answers to Interrogatories, as follows: 1. Plaintiff served upon Defendant Interrogatories on February 9, 2003. A copy of those Interrogatories is attached hereto as Exhibit '%". 2. At the time of service Defendant, through his counsel, was advised that a motion to Compel would be filed immediately upon the expiration of the 30 day period for a response as set by the Rules of Civil Procedure. 3. The purpose for such demand is that Defendant has filed a petition to Terminate Alimony Pendente Lite, yet continues to evade and refuse requests for information which would allow the parties to resolve all economic issues in their divorce. 4. It is believed and therefore averred that absent an Order compelling a response, Defendant will not provide the requested, and necessary, information. WHEREFORE, Plaintiff respectfully requests this Honorable Court order Defendant to provide full and complete responses to the Interrogatories within fifteen (15) days of the date of the order, or suffer the appropriate sanctions. Respectfully submitted, LAW OFFICES OF MARK K. EMERY DATE: By: Mark K. Emery, Esquire Supreme Court I.D. No. 72787 410 North Second Street Harrisburg, PA 17101 (717) 238-9883 Attorney for Plaintiff EXHIBIT A MEGAN E. JOHNSON Plaintiff VS, RANDALL A. JOHNSON Defendant IN THE COURT Of COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-5044 · CIVIL ACTION - LAW : IN DIVORCE INTERROGATORIES TO: Randall A Johnson c/o Nichole M. Staley O'Gorman 1719 North Front Street Harrisburg, PA 17102-2392 These Interrogatories are propounded pursuant to the Pennsylvania Rules of Civil Procedure and are to be answered by the Defendant in accordance therewith· Defendant is required to answer these Interrogatories in writing under oath, based upon all information available to her and to her attorneys, employees, and other agents, or representatives. Defendant is also required to serve answers to these Interrogatories within thirty (30) days, to the offices of Plaintiffs' counsel, The Law Offices of Mark K. Emery, 410 North Second Street, Harrisburg, PA 17101, and supplement her answers in accordance with the Pennsylvania Rules of Civil Procedure. These Interrogatories are to be answered by the Defendant. Instructions 1. The following Interrogatories are to be answered in writing, verified, and served upon the undersigned within thirty (30) days of service upon you. Objections must be signed by the attorney raising the objection. In answering, you must furnish any and all information available to you, your employees, ~representatives, agents and attorneys. Your answers must be supplemented and amended as required by the Pennsylvania Rules of Civil Procedure. 2. With respect to any claim of privilege or immunity from discovery, you must identify the privilege or immunity asserted and provides sufficient information to substantiate the claim. 3. In lieu of identifying documents in response to these Interrogatories, you may provide copies of such documents with appropriate references to the corresponding Interrogatories. 4. These Interrogatories shall be construed and interpreted in accordance with the Pennsylvania Rules of Civil Procedure. Definitions 1. "Document", when used herein, means any record, including any object which contains written, printed, typed or magnetically recorded information, a graphic or photographic representation or sound, however produced or reproduced. Document includes an original or any copy of any statement, report, letter, memorandum, book, article, note, blueprint, drawing, sketch, photograph, motion picture, videotape, phonograph, compact disc or any other sound recording. Document also includes any card, disc, magnetic tape, printout, data cell, drum and any other data compilations designed for the storage of information in conjunction with a computer or any other word/data processing system. 2. "Identify" or "Identity", when used herein with respect to: a. A natural person means to state: i. the person's full name; ii.the person's present or last known address; and iii. the person's employer and employer's address at the time of the events referred to in the Interrogatory. b. An entity other than an individual, including a corporation, partnership, limited liability company or partnership, unincorporated association, governmental agency, etc. or a subsidiary, division, or subdivision thereof, means to state: i. Its full corporate name; ii.the date and place of incorporation, if known; iii. the present or last known address of the entity; and iv.if applicable, the full names and present or last known address of the entity's subsidiary, division or subdivision. c. A document, as defined above, means to state: i. the nature of the document (i.e. whether it is a report, statement, letter, etc.); ii.the title of the document, or if no title, a description of the document sufficient to identify same; iii. the identity of the person(s) who prepared the document; iv.the identity of the person(s) for whom the document was prepared or to whom the document was directed; v. the date the document was prepared; and vi.the identity of the present custodian of the document or any copy of the document. d. An oral communication means to state: i. the date the communication occurred; ii.the place where the communication occurred; iii. the substance of the communication; iv.the identify of the person(s) who made the communication; v. the identity of each person to whom such communication was made; and vi.the identity of each person who was present when s;uch communication was made. e. Any other context means to provide a description with sufficient particularity that the thing may thereafter be specified and recognized, including relevant dates and places, the identification of relevant people, entities, and documents. 3. "Person", when used herein refers to a natural person, association, partnership, corporation, or government agency. 4. "You" or "Your", when used herein, refers to Defendant, his agents, representatives, servants, and/or employees. Please indicate and itemize your yearly income from any source whatsoever, including wages, salaries, dividends and director's fees, as well as return on investment income or business investments. Attach copies of your personal income tax returns for the past three years. ANSWER: Please list any and all life insurance policies on which you are the owner, insured, or beneficiary for the past three years. For each policy, state: the name of the policy and the policy number'; 2. the face amount of the policy; 3. the cash value of the policy; 4. amount of any loan against said policy; 5. the named beneficiaries of said policy; 6. the annual premium payment for said policy, and name the payor; and 7. identity of owner, insured, and beneficiary and any relationship to you. ANSWER: If you have at present, or if you have had within the last seven years, an account with any security dealer or broker, state: 1. the name of broker or dealer; 2. business location; and 3, attach monthly statements of account for the past seven years. ANSWER: Identify any automobile, truck, camper, mobile home, motorcycle, boat, airplane or vehicle of any nature that you own or any business owns for your benefit or that you have an interest therein and set forth (use supplemental sheets, if necessary): 1. make, model and year; 2. date acquired; 3. purchase price or value at acquisition; 4. your opinion as to current fair market value; 5. how title is held; 6. name and address of any co-owners or interest holders; and 7. date and initial amount of any liens, present balance of any liens or encumbrances thereon, including identity of the lien holder. ANSWER: Please list any and all checking accounts, savings accounts or brokerage accounts held by you, either in your name alone, jointly with another person, or which you have signature power over, or which are held for your benefit for the past five years. For each such account, state: 1. the name of the institution where held; 2. the account number; 3. initial deposit and date account was opened; 4. current balance in the account; and 5. titled owners of said account. ANSWER: Please list any and all debts and/or liabilities which you are presently aware of for which you are liable, either individually or jointly with another person, including but not limited to child support obligations. Please include any and all liens or judgments which may be held against you, either individually or with another person. For each such debt or liability, please state the amounts due and owing. ANSWER: Please list any and all pensions, retirement accounts, profit sharing accounts, 401K plans, IRA's or any other retirement vehicle which is held by you, or for your benefit, or which is held in your name individually or jointly with another person within the past five years. For each such retirement vehicle, please state the institution where held, the current balance therein and the value to you upon reaching retirement age. ANSWER: List any and all witnesses whom you plan to call at a Master's hearing on equitable distribution and state what they will testify to. Please list all witnesses, whether expert or non-expert. ANSWER: Do you anticipate receipt of any devise, bequest, gift or inheritance? If so, set forth: 1. when receipt is anticipated; 2. amount to be received; 3. from whom the receipt is anticipated; and 4. attach any documents in support of such bequest, devise, gift or inheritance. ANSWER: 10. State the extent, type and location of all books, papers, records, journals or other documents in your possession or control which would reflect your income or assets. Attach a copy of each such document. Also, attach a copy of your current financial statement. ANSWER: Respectfully submitted, LAW OFFICES OF MARK K. EMERY DATE: By: Mark K. ~--rr¢~, EsqUire Supreme, Court I.D. No. 72787 410 North Second Street Harrisburg, PA 17101 (717) 238-9883 Attorney for Plaintiff CERTIFICATE OF SERVICE AND NOW, this 9th day of February, 2003, I, Mark K. Emery, Esquire do hereby certify that I have served the foregoing First Request for Production of Documents by mailing a true and correct copy via United States first class mail, addressed as follows: Nichole M. Staley O'Gorman, Esquire 1719 North Front Street Harrisburg, PA 17102-23921 LAW OFFICES OF MARK K. EMERY Mark K. Emery CERTIFICATE OF SERVICE AND NOW, this 11th day of March 2004, I, Mark K. Emery, Esquire do hereby certify that I have served the foregoing Motion~ to Compel Answers to Interrogatories by mailing a true and correct copy via United States first class mail, addressed as follows: Nichole M. Staley O'Gorman, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 LAW OFFICES OF MARK K. EMERY By: ~"'/,//' ~"',,'""' ~ '"~ Mark K. Emery MEGAN E. JOHNSON, : Plaintiff : .- V. : : RANDALL A. JOHNSON,: Defendant : 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COIINTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-5044 CIVIL TERM ORDER OF COURT AND NOW, this 25th day of March, 2004, upon consideration of Plaintiff's Motion To Compel Answers to Interrogatories, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, ,,(Mark K. Emery, Esq. 410 North Second Street Harrisburg, PA 17101 Attorney for Plaintiff ~Nicole M. Staley O'Gorman, Esq. 1719 North Front Street Harrisburg, PA 17102-2392 Attorney for Defendant J. Wesley O~, Jr.,~ Jo :rc