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HomeMy WebLinkAbout07-5618-J NATHAN C. WOLF, ESQUIRE ATTORNEY M NO. 87380 10 WES'r HIGH STREET CARLISLE PA 17013 cn7) 2414436 ATTORNEY FOR PLAINTIFF FRANCIS D. HOCKENBRAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW SUSAN M. HOCKENBRAUGH, : NO. 2007 - -4/9 CIVIL TERM Defendant : IN DIVORCE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment maybe entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 717-249-3166 i NATHAN C WOLF, ESQUIRE ATTORNEY ID NO. 87390 10 WEST HIGH STREET CARLISLE PA 17013 cm) 241-4436 ATTORNEY FOR PLAINTIFF FRANCIS D. HOCKENBRAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW SUSAN M. HOCKENBRAUGH, : NO. 2007 - CIVIL TERM Defendant : IN DIVORCE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Francis D. Hockenbraugh, an adult individual residing at 9 East Beale Avenue, Enola, Cumberland County, Pennsylvania 17025. 2. The defendant is Susan M. Hockenbraugh, an adult individual residing at 9 East Beale Avenue, Enola, Cumberland County, Pennsylvania 17025. 3. The plaintiff and defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were marred on August 13, 1988, in York Springs, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. f . % WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as this Honorable Court may deem equitable and just. I verify that the statements made in this 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 unswom falsification to authorities. 'jE 2 .2007 ZS 2007 4?,?Zt- rancis D. Hockenbraugh, Plaintiff NATIJKN . WOLF, ESQUIRE a ourt ID #87380 Sup On A 10 a igh Street Carlisle, Pennsylvania 17013 (717) 241-4436 Attorney for Plaintiff pG?J C S' -l' 'LI U elff ?_ '. --c N ? C 0 0 ..r -0 MM L' W p NATHAN C. WOLF, ESQUIRE ATTORNEY ID No. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF FRANCIS D. HOCKENBtiff CBE COURT COSY, PENNSYLVANIA Plain v. CIVIL ACTION - LAW SUSAN M. HOCBENBRAUGH, : NO. 200.7 - CIVIL TERM Defendant : IN DIVORCE PLAINTIFF'S MARRTA(?rF COUNSFT TN AFFIDAVIT 'The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down- I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. CS. Section 4904 relating to unswom falsification to authorities. I-e-7 2 1 2007 o -n C v Lu co M ±'+ r r , M -o 7'' C G? NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF FRANCIS D. HOCKENBRAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW SUSAN M. HOCKENBRAUGH, : NO. 2007 - SW D CIVIL TERM Defendant : IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court regl-?ire that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. 2007 `?j4-?? SUSAN M. H RE?? NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF FRANCIS D. HOCKENBRAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW SUSAN M. HOCKENBRAUGH, : NO. 2007 - EAPN% CIVIL TERM Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, SUSAN M. HOCKENBRAUGH, certify that I am the defendant in this matter. Furthermore, I hereby certify that on 2007, I received a certified copy of the divorce complaint filed in this action. ?007 Letenaant RECEIVED NON 19 2007 C 3 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013-2922 (717) 2414436 ATTORNEY FOR PLAINTIFF FRANCIS D. HOCKENBRAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. SUSAN M. HOCKENBRAUGH, Defendant : CIVIL ACTION - LAW : NO. 2007 - 5618 CIVIL TERM : IN DIVORCE/CUSTODY COMPLAINT FOR CUSTODY NOW comes the plaintiff, by his attorney, Nathan C. Wolf, Esquire, and files this complaint for custody, representing as follows: 1. The plaintiff is Francis D. Hockenbraugh, an adult individual residing at 9 East Beale Avenue, Enola., Cumberland County, Pennsylvania 17025. 2. The defendant is Susan M. Hockenbraugh, an adult individual residing at 9 East Beale Avenue, Enola, Cumberland County, Pennsylvania 17025. 3. The parties are the natural parents of two minor children, namely, Antonio Lee Hockenbraugh (born August 31, 1997, age 10) and Vincent Charles Hockenbraugh (born December 30, 1998, age 8). 4. From birth the children have resided with both parents and continue to do so pending the patties' separation. 5. The parties have agreed to the sale of their marital residence,settlement for which is scheduled for December 14, 2007. 6. The children were born of the marriage of the parties. The parties separated on or about September 25, 2007 and an action in divorce is being filed contemporaneously herewith. 7. Father has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 8. Father has no information of a custody proceeding concerning the children pending in any court of this Commonwealth or any other state. 9. Father does not know of a person not a parry to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 10. The best interest and permanent welfare of the child will be served by granting the relief requested herein because the parties' separation will necessitate a formal custody order, and the parties have shared caretaking responsibilities for the children. Father's work schedule will permit him to primarily provide for the children's needs on a primary basis, with significant periods of partial custody or shared physical custody with Mother. 11. Father believes that he can continue to provide for the children in his household, whether or not he relocates from the marital residence and seeks an Order confirming his rights to primary or shared physical and legal custody of the children. 12. Plaintiff, as of December 1, 2007 will be renting an to an apartment which is located at 5 Adams Street, Enola, Cumberland County, Pennsylvania, 17025. 13. Said residence would allow the minor children to remain in the same school, and even on the same school bus route as the children are currently accustomed to. 14. Father believes that without an order confirming his custodial rights, that Mother will continue to threaten his role as the children's caretaker and that such a result would be detrimental to the children's best interests and permanent welfare. WHEREFORE, for the reasons set forth herein, Plaintiff, Francis D. Hockenbraugh, respectfully requests that this Honorable Court enter an order establishing shared legal and physical custody to Father, along with granting any other relief the Court deems appropriate. ?4-t" 2007 N'AT . WOLF, ESQUIRE At4WtHigh for Plaintiff 10 Street Carlisle, Pennsylvania 17013-2922 (717) 241-4436 Supreme Court I.D. No. 87380 VERIFICATION I do hereby verify that I am the Plaintiff in the foregoing action and that the facts set forth in this complaint are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsification to authorities. ,Q1?e 14, 2-7 , 2007 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013-2922 (717) 241-4436 ATTORNEY FOR PLAINTIFF FRANCIS D. HOCKENBRAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. SUSAN M. HOCKENBRAUGH, Defendant CIVIL ACTION - LAW : NO. 2007 - 5618 CIVIL TERM : IN DIVORCE/CUSTODY CERTIFICATE OF SERVICE I, Nathan C. Wolf, Esquire, attorney for Plaintiff, do hereby certify that this date, I have served a copy of the foregoing Complaint for Custody upon the following person, by United States Mail, addressed as follows: James A. Miller, Esquire Miller Lipsitt LLC 356 North 21st Street Camp Hill, PA 17011 Susan M. Hockenbraugh 9 East Beale Avenue Enola, PA 17025 Respectfully submitted, WOLF & WOLF, Attorneys at Law Dated: 2007 By: Nathg , Esquire 10 W t H' Street Car s1 A 17013 Supreme Court I.D. No. 87380 (717) 241-4436 Attorney for Plaintiff ?. Q r\3 rt ° t rte' °- _ ? 0 0 Q FRANCIS D. HOCKENBRAUGH IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 2007-5618 CIVIL ACTION LAW SUSAN M. HOCKENBRAUGH DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, November 30, 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, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, December 20, 2007 at 9:30 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 tem ora order. Failure to appear at the conference ma p ry v 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 3A3?0 ?-w Qv, ' -)73747 ?, 460 lqw !fir} a ..? rl. i t,a ' ?'.. -1-10 (f r xi7 (E tj, DEC 1 3 znoiri //5z FRANCIS D. HOCKENBRAUGH,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-5618 CIVIL ACTION - LAW SUSAN M. HOCKENBRAUGH, : Defendant : IN CUSTODY ORDER OF COURT AND NOW, this/ r * I day of?, , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. , of the Cumberland County Court House, on the 157* day of , 2008, at .' 30 _fO o'clock,. M., at which time testimony will be take. For purposes of this Hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the following shall remain in full force and effect. 3. The Father, Francis D. Hockenbraugh, and the Mother, Susan M. Hockenbraugh, shall have shared legal custody of Antonio Lee Hockenbraugh, born August 31, 1997 and Vincent Charles Hockenbraugh, born December 30, 1998. 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. 4. Mother shall have primary physical custody of the children every Thursday morning to Monday after school. 5. Father shall have periods of partial physical custody every Monday from after school to Thursday morning. 6. In the event that either parent is in need of a babysitter for more than two hours, they shall contact the non-custodial parent and offer said time to that parent. 7. Christmas shall be divided into two Blocks. Block A shall be from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Father shall have Block A in 2007 and Mother shall have Block B in 2007. 8. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. BY J. cS;Xathan C. Wolf, Esquire, counsel for Father .dames A. Miller, Esquire, counsel for Mother J VWW?tQd i 330 LOOZ 3 .40 DEC 1820DJ? FRANCIS D. HOCKENBRAUGH,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-5618 CIVIL ACTION - LAW SUSAN M. HOCKENBRAUGH, : Defendant : IN CUSTODY PRIOR JUDGE: None 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 Antonio Lee Hockenbraugh August 31, 1997 Mother Vincent Charles Hockenbraugh December 30, 1998 Mother 2. A Conciliation Conference was held December 13, 2007 with the following individuals in attendance: The Father, Francis D. Hockenbraugh, with his counsel, Nathan C. Wolf, Esquire, and the Mother, Susan M. Hockenbraugh, with her counsel, James A. Miller, Esquire by telephone. 3. Father's position on custody is as follows: Father seeks shared legal and primary physical custody, with Mother having every weekend Friday to Monday. Father maintains that he works weekends and is available during the week for the children, while Mother works during the week during the day and is not available for the children. Father asserts that he has stabilized his mental health following a suicide attempt. 4. Mother's position on custody is as follows: Mother seeks shared legal and primary physical custody with Father having two overnights per week, although she was willing to compromise with Father having three overnights per week. Mother maintains that she has been the primary caregiver to the children and that Father's mental health is unstable, evidenced by a recent suicide attempt. Mother asserts that the children are afraid of Father. 5. The Conciliator recommends an Order in the form as attached scheduling, a Hearing and granting the parties shared legal custody, Mother primary physical custody with Father having three overnights each week. It is expected that the Hearing will require one day. i2-?4-07 A - V Date cq line A Verney, Esquire Custody Conciliator NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013-2922 (717) 241-4436 ATTORNEY FOR PLAINTIFF FRANCIS D. HOCKENBRAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. SUSAN M. HOCKENBRAUGH, Defendant : CIVIL ACTION - LAW NO. 2007 - 5618 CIVIL TERM IN CUSTODY MOTION FOR CONTINUANCE NOW comes the Plaintiff, by his attorney, Nathan C. Wolf, Esquire, and presents the following motion for general continuance of the February 15, 2008 hearing, representing as follows: 1. The plaintifft is Francis D. Hockenbraugh, an adult individual residing at 5 Adams Street # 8, Enola, PA 17025. 2. The defendant is Susan X Hockenbraugh, an adult individual residing at 5 Adams Street # 3, Enola, PA 17025. 3. The parties are the natural parents of two minor children, namely, Antonio Lee Hockenbraugh (born August 31, 1997, age 10) and Vincent Charles Hockenbraugh (born December 30, 1998, age 9). 4. The parties separated on or about September 25, 2007 and an action in divorce was filed on or about September 25, 2007. 5. The plaintiff filed a Complaint for Custody on or about November 27, 2007. 6. A Conciliation Conference was held December 13, 2007 at 9:30 a.m. before Jacqueline M. Verney, Esquire and upon consideration of said conference a hearing has been scheduled for February 15, 2008 at 9:30 a.m. before the Honorable Edward E. Guido. 7. Though the instant petition is being filed by counsel for Plaintiff, said filing is being presented as a joint request of Plaintiff and Defendant and therefore each party concurs in the relief requested. a 8. Thus, Plaintiff and Defendant, jointly, respectfully request a general continuance of this hearing to be re-listed at the request of either party so that the parties may have more of an opportunity to resolve the instant matter by stipulated agreement. 9. The relief requested would therefore be in the best interests of the children. WHEREFORE, Plaintiff, Francis D. Hockenbraugh, on behalf of both parties hereto, respectfully requests that the Court issue an Order for a general continuance for the hearing currently scheduled for February 15, 2008 for parties to resolve the matter by agreement. Respectfully submitted, WOLF & WOLF Dated: January, 2008 By: Supreme Court I.D. No. 87380 Attorney for Plaintiff VERIFICATION I, the undersigned, do hereby verify I am counsel for Plaintiff, and the facts set forth in this motion 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 Pa.C.S. Section 4904, relating to unworn falsification to authorities. January -ZI , 2008 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013-2922 (717) 241-4436 ATTORNEY FOR PLAINTIFF FRANCIS D. HOCKENBRAUGH, Plaintiff V. SUSAN M. HOCKENBRAUGH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2007 - 5618 CIVIL TERM : IN CUSTODY CERTIFICATE OF SERVICE I, Nathan C. Wolf, Esquire, hereby certify that I have served a true and correct copy of Plaintiff's Motion for Continuance upon the following person and in the matter indicated: SERVICE BY U.S. MAIL: James A. Miller, Esquire Miller Lipsitt LLC 765 Poplar Church Road Camp Hill, PA 17011 Respectfully submitted, WOLF & WOLF Dated: January, 2008 By: N, Esquire 10 est Street FarlisW,TA 17013 M241-4436 Supreme Court I.D. No. 87380 Attorney for Plaintiff gn r+? FRANCIS D. HOCKENBRAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW SUSAN M. HOCKENBRAUGH, : NO. 2007 - 5618 CIVIL TERM Defendant : IN CUSTODY ORDER OF COURT AND NOW this /o day of , 2008, upon consideration of the attached Motion, it is hereby ordered that the hearing scheduled for February 15, 2008 at 9:30 a.m., be continued generally and said hearing may be re-listed by either party upon receipt by the Court of such a request. TWCOT: Edward E. Guido, J. D' 'b *on: an C. Wolf, Esquire For the Plaintiff .-Ta-*mes A. Miller, Esquire For the Defendant VlEN"Y'AlASNcJ-::J)d :01 WV 1- 933 9901 KdViONORIC ud 3Hi 33 L-HC}-0311i NATHAN C. WOLF, ESQ. SUPREME COURT ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 717-2414436 ATTORNEY FOR PLAINTIFF FRANCIS D. HOCKENBRAUGH, Plaintiff v. SUSAN M. HOCKENBRAUGH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2007 - 5618 CIVIL TERM : IN DIVORCE/CUSTODY PRAECIPE TO WITHDRAW DIVORCE AND CUSTODY COMPLAINT TO THE PROTHONOTARY: Please mark the Divorce Complaint filed by Plaintiff on September 25, 2007 and the Custody Complaint filed on November 27, 2007, in the above-captioned matter WITHDRAWN, without prejudice to plaintiff. Respectfully submitted, WOLF & WOLF Dated: December /2'2008 By: (717) 241-4436 Supreme Court I.D. No. 87380 Attorney for Plaintiff C!