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HomeMy WebLinkAbout07-5740TRACI J. MATTERN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. CASE NO. e"7-5 7qO JOHN SCOTT MATTERN, JR., CIVIL ACTION - LAW Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS 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 of Divorce or annulment may be 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 minor children. When the ground for the 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 at Dauphin County Courthouse, Harrisburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 Telephone: (717) 849-3166 Date: September 27, 2007 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 P. O. Box 60457 TRACI J. MATTERN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CASE NO.O 9- 5'7 Yo V. JOHN SCOTT MATTERN, JR., CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE COUNT I - DIVORCE AND NOW, comes the Plaintiff, Traci J. Mattern, by and through her counsel, Cunningham & Chernicoff, P.C., and seeks to obtain a Decree in Divorce from the Defendant, John Scott Mattern, Jr., and support thereof avers as follows: 1. The Plaintiff, Traci J. Mattern ("Plaintiff'), currently resides at 508 West Main Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. The Plaintiff is a citizen of the United States of America. Plaintiff s Social Security Number is 164-70-0062. 2. The Defendant, John Scott Mattern, Jr., ("Defendant"), currently resides at 555 First Street, Carlisle, Cumberland County, Pennsylvania 17013. The Defendant is a citizen of the United States of America. Defendant's Social Security Number is 177-60-2399. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the last six (6) months immediately previous to the filing of this Complaint. 4. The Defendant has been a bona fide resident of the Commonwealth of Pennsylvania for at least the last six (6) months immediately previous to the filing of this Complaint. 5. The Plaintiff and Defendant were married on October 13, 2005, in Cumberland County, Pennsylvania. 6. There has been no prior action for divorce or annulment of marriage between the parties in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. The Plaintiff has been advised of the availability of counseling and that Defendant may have the right to request that the Court the parties to participate in counseling. WHEREFORE, Plaintiff, Traci J. Mattern, hereby respectfully requests this Honorable Court to enter a Decree in Divorce from the bars of matrimony. COUNT II - EQUITABLE DISTRIBUTION 9. The averments of Paragraphs 1 through 8 are incorporated herein by reference as if fully set forth. 10. During the course of the marriage, the parties acquired marital property. 2 WHEREFORE, Plaintiff, Traci J. Mattern, hereby respectfully requests this Honorable Court to determine, divide, distribute and assign the marital property of the parties pursuant to Section 35 of the Divorce Code. COUNT III - CUSTODY 11. The averments of Paragraphs 1 through 10 are incorporated herein by reference as if fully set forth. 12. The Plaintiff seeks primary physical of the following child: Name Katelynn Mackenzie Mattern Present Residence 508 West Main Street Mechanicsburg, Cumberland County, Pennsylvania 17055 Date of Birth May 6, 2006 13. The minor child, Katelynn Mackenzie Mattern ("Minor Child"), was not born out of wedlock. 14. The Minor Child is presently in the custody of the Plaintiff, who currently resides at 508 West Main Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 15. During the past five (5) years, the Minor Child has resided with the following persons at the following addresses: 3 Persons Address Dates Plaintiff; Defendant 105 East Main Street Box 103 Plainfield Cumberland County Pennsylvania 17081 Birth to July 10, 2007 Plaintiff, Maternal Grandparents (Victor and Sara Miller) 508 West Main Street Mechanicsburg, Cumberland County, Pennsylvania 17055 July 10, 2007 to present 16. The Mother of the Minor Child is Plaintiff, Traci J. Mattern. She is married to the Defendant. 17. The Father of the Minor Child is Defendant, John Scott Mattern, Jr., He is married to the Plaintiff. 18. Plaintiff has no information of another custody proceeding concerning the Minor Child pending in a Court of this Commonwealth. 19. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the Minor Child or claims to have custody or visitation rights with respect to the Minor Child. 20. The best interest and permanent welfare of the Minor Child will best be served by granting the relief requested because the Plaintiff has been the primary caretaker of the Minor Child; remains the primary caretaker of the Minor Child; can provide a stable, safe and secure environment and can provide for the Minor Child's emotional, psychological, and spiritual needs. Furthermore, the Minor Child views the Plaintiff as a source of stability, a source of love and a source of emotional support. 4 21. Each parent whose parental rights to the Minor Child has been terminated and all persons who have physical custody of the Minor Child has been named as a party of this action. All other persons named below, who are known to have a claim or right to custody of visitation of the Minor Child have been given notice of the pendency of this action and their right to intervene; NONE. WHEREFORE, Plaintiff, Traci J. Mattern, hereby respectfully requests this Honorable Court to grant primary physical custody of the Minor Child to the Plaintiff and grant her such further relief as is just and proper. tted, OFF, By: PA Supfeme Cdu I.D.-K87365 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 Date: September 27, 2007 Attorneys for Plaintiff, Traci J. Mattern F:\Home\KKNIGH'I'\DOCS\Mattem\Complaint. W PD 5 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. §4904, relating to unsworn falsification to authorities. JLI? 1C'' TRACI MATTERN Date ,? / , 2007 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN ss; The Plaintiff, being duly sworn according to law, deposes and says that she is the Plaintiff in the above captioned matter and that she personally knows that the Defendant is over the age of eighteen (18) years. The Plaintiff further avers that the Defendant is not in the Military Service or in any branch of the Armed Forces of the United States of America or its Allies or otherwise within the provisions of the Soldier's and Sailors' Civil Relief Act of Congress of 1940 and its Amendments. Tjw"k fflattmik-', TRACI MATTERN SWORN and Subscribed to Before }tee this?3ed day of t (? c r , 2007. AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN . ss; I, TRACI MATTERN, being duly sworn according to law, depose and say: (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 Domestic Relations 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 by the court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. 0 ffloUJ &-I TRACI MATTERN SWORN and Subscribed to Befor me this J-' l? day of let 2007. OTARY PUBLIC ,20WAONIXE&TH. OF EINNiYLVAIIA NOTARIAL SEAL JULIEANNE AMETRANO, Notary Pubk City of Harrisburg, Dauphin County My Commission Expires Feb. 22, 2011 -0 ? 00 C31 D \ccr r h -TI 1 --? -ri w TRACI J. MATTERN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CASE NO. O'7 • S7'1g6 V. JOHN SCOTT MATTERN, JR., CIVIL ACTION - LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Julieanne Ametrano, Legal Assistant with the firm of Cunningham & Chemicoff, P.C., do hereby certify that a true and correct copy of the Complaint in Divorce, with regard to the above captioned matter was served on Michelle L. Sommer, Esquire as attorney for John Scott Mattem, Jr., on October 1, 2007, as per the attached Acceptance of Service, marked as Exhibit "A„ Date: October 3, 2007 CUNNINGHAM & CHERNICOFF, P.C. B y: Iulieanne Ametrano Cunningham & Chemicoff, P.C. 2320 North Second Street Harrisburg, PA 17110 Telephone: (717) 238-6570 TRACI J. MATTERN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CASE NO. O `? --57y a V. JOHN SCOTT MATTERN, JR., Defendant CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Michelle L. Sommer, Esquire, of the Law Firm Abom and Kutulakis, 36 South Hanover, Carlisle, Pennsylvania 17013, hereby state that I represent the Defendant in the above- captioned matter, John Scott Mattern, Jr. Therefore, I accept service of the attached Divorce/Custody Complaint and submit that I am authorized to do so. By. Michelle L. Sommer, squire Date: 10- 1-Cn- F:V Iome\KKNIGHIIDOCS\Mattem\Complaint. WPD r.3 f`? r.a C?5 C?. c:a a? Yi -? -r, F r•a _ .. z:a TRACI J. MATTERN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2007-5740 CIVIL ACTION LAW JOHN SCOTT MATTERN, JR. IN CUSTODY DFFF,NDANT ORDER OF COURT AND NOW, Wednesday, October 10, 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, October 25, 2007 at 9:00 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/ John J. Mangan,,Lr., Es q. I 1 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 --ter ??c??? ??. ??/ - D/ ?' ? i? ?? .?? ?? o? ??Q i?o? !h'?i44t.?v??' ?'?' ?Q ?????y?, ??«T? _* Nov 13 2007,,?? 0? TRACI J. MATTERN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07-5740 CIVIL ACTION LAW JOHN S. MATTERN, JR., IN CUSTODY Defendant ?''? ORDER OF COURT AND NOW this A_ day of November, 2007, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. Legal Custody: The Father, John Mattern, Jr., and the Mother, Traci Mattern, shall have shared legal custody of Katelynn Mackenzie Mattern, born 5/6/2006. 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 her 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 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. Commencing November 7, 2007 through November 14, 2007, paternal grandmother, Lynette Hassinger, shall have visitation with the subject Child in her residence as often as reasonable and/or practicable as mutually agreed by paternal grandmother and Mother. b. Commencing November 15, 2007 through November 29, 2007, Father shall have partial custody of the Child supervised at paternal grandmother's residence one (1) evening per week (mutually agreed upon) from 6:00 pm until 8:00 pm. C. Commencing November 29, 2007 through December 13, 2007, Father shall have partial custody of the Child supervised at paternal grandmother's residence one (1) evening per week (mutually agreed upon) from 6:00 pm until 8:00 pm. and one afternoon on either Saturday or Sunday from 2:00 pm until 5:00 pm. 3. Father shall continue with his counseling at Pennsylvania Counseling Services until successfully discharged. 4. Holidays: Shall be addressed at updated conciliation conference December 14, 2007 at 9:00 am. 5. Transportation: Transportation of the Child shall be arranged by the parties. 6. Neither party may say or do anything nor permit a third party to do or say anything that may V7NMt'iI-L; S,NNgd 91 :9 RV 91 AON IOQZ dl?b!lOf NtC?c`d :7t4 j© lid 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 or affection for the other party. To the extent possible, both parties shall not allow third parties disparage the other parent in the presence of the Child. 7. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 8. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 9. 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. A status update conference is tentatively scheduled for December 14, 2007 at 9:00 am at the Cumberland County Court of Common Pleas. The parties are directed to contact the assigned Conciliator to request a telephonic conference or to cancel/ reschedule the scheduled conference as necessary. Distribution: ,MfS'helle Sommer, Esq. elly Knight, Esq. ,, o m J. Mangan, Esq. 4 By the Court, r TRACI J. MATTERN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07-5740 CIVIL ACTION LAW JOHN S. MATTERN, JR., IN CUSTODY Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVEL 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 litigation is as follows: Name Date of Birth Currently in the Custody of Katelynn Mackenzie Mattern 5/6/2006 Primary-Mother 2. A Conciliation Conference was held with regard to this matter on November 7, 2007 with the following individuals in attendance: The Mother, Traci Mattern, via telephone and with her counsel, Kelly Knight, Esquire The Father, John Mattern, with his counsel, Michelle Sommer, Esquire 3. The parties agreed to the entry of an Order in the form as attached. Date Jo J. angan, Esq ' e stody Conciliator euTou= NOW_ Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 TRACI J. MATTERN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CASE NO. 07-5740 JOHN SCOTT MATTERN, JR., CIVIL ACTION -LAW Defendant MOTION TO WITHDRAW AS COUNSEL AND NOW, this _ day of May, 2008, comes undersigned counsel, ABOM & KUTULAKIS, L.L.P., by Michelle L. Sommer, Esquire, who respectfully requests This Honorable Court grant this Motion to Withdraw as Counsel for the above-named Plaintiff and, in support thereof, respectfully avers the following: I • A Complaint in Divorce was filed by the Plaintiff, Traci J. Mattern, by and through her counsel Kelly M. Knight, Esquire of Cunningham & Chernicoff, P.C. 2. The Complaint in Divorce which had an additional count for Custody was filed with the Cumberland County Prothonotary's Office on October 5, 2007. 3. On or about July 31, 2007 undersigned counsel was retained by Defendant, John Scott Mattern, Jr., to represent him in the above-captioned divorce and custody action. 4. A Pre-Hearing Custody Conference was held on November 7, 2007 before Conciliator John Mangan. ' 5. An Order was entered on November 15, 2007 by the Honorable J. Wesley Ole which both Plaintiff, Traci J. Mattern and Defendant, John Scott Matte r, Jr. in rn, Jr. were given shared legal custody. Mother was given primary physical custody and Father was given partial custody. 6. It is believed and therefore averred that the parties have reconciled and are currently residing together at 105 East Main Street, Box 103, Plainfield, Pennsylvania 17081. 7. As a result of the reconciliation undersigned counsel's services are no longer r either the divorce or custody matter. required in 8. Kelly M. Knight, Esquire does not oppose this Motion. WHERERFORE, undersigned counsel respectfully requests This Honorable Court request to withdraw as counsel in this matter. grant her Respectfully submitted, Date (U8 ABOM & KUTULAKIS, L.L.P. Michelle L. Somme 36 South Hanover Street' quire Carlisle, PA 17013 (717) 249-0900 Attorney ID No. 93034 AND NOW, this q CE_ IF day of May, 2008, I, Michelle L. Sommer, Esquire of ABOM & KUTULAKIS, L.L.P., hereby certify that I did serve or cause to be serve the foregoing Motion to Withdraw as Counsel b First by Class U.S. Mail addressed to the following: John Scott Mattern 105 East Main Street Box 103 Plainfield, PA 17081 Kelly M. Knight, Esquire Cunningham & Chernicoff, P.C. 2320 North 2°d Street Harrisburg, PA 17110 4X4i,le L. Sommer, Esquire ?:? _, =;? ? ? _?? ?i ?:,s ,. _? c,,.' ?, ,1* ,_ TRACI J. MATTERN, Plaintiff V. JOHN SCOTT MATTERN, JR., Defendant WN o $ 2M 8 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CASE NO. 07-5740 CIVIL ACTION -LAW RULE TO SHOW CAUSE A I a.h e AND NOW, this day of J?,4ay, 2008, upon Motion of Michelle L. Sommer, Esquire, a Rule is hereby issued upon the parties to show cause why the Petitioner should not be permitted to withdraw as counsel for John Scott Mattern, Jr. Rule returnable (D days after the date of service of this Order. Service to be by certified mail upon John Scott Mattern, Jr. and upon Tracy J. Mattern's attorney of record, Kelly M. Knight, Esquire. Distribution: ?Kelly M. Knight, Esquire hn Scott Mattern, Jr. ichelle L. Sommer, Esquire tFs rn?i tccL BY THE COURT: J. esley O er Jr., J. ?ONVAUSNN3d A Jf1G- ??: ,;ByVr-a 60:8 WV o l Nflf AUViONGHiO8d *U X 30H-40--CMH Alom & LITLILAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 TRACI J. MATTERN, Plaintiff V. JOHN SCOTT MATTERN, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CASE NO. 07-5740 : CIVIL ACTION -LAW AND NOW, this30_ day of June, 2008, comes Michelle L. Sommer, Esquire, of Abom & Kutulakis, LLP, and respectfully moves this Court to make absolute the Rule to Show Cause, which was issued in the above-captioned matter on June 6, 2008, and in support of this Motion states the following: 1. Michelle L. Sommer, Esquire and Abom & Kutulakis, LLP (hereinafter "moving party"), filed a Petition for Leave to Withdraw as Counsel on May 29, 2008. 2. On June 6, 2008, this Court issued a Rule on Kelly M. Knight, Esquire, Plaintiffs counsel; and John Scott Mattern, Jr., Defendant, to show cause, if any they have, why the appearance of moving party on behalf of the Defendant, John Scott Mattern, Jr., should not be allowed to be withdrawn. This Court's Rule to Show Cause is attached as Exhibit "A." 3. The Rule to Show Cause was returnable 10 days after service. 4. The Rule to Show Cause was distributed to all responding parties by the Cumberland County Prothonotary. 5. More than ten days have elapsed since June 6, 2008 and all responding parties have failed or refused to respond to the Rule to Show Cause. WHEREFORE, Michelle L. Sommer, Esquire, and Abom & Kutulakis, LLP, respectfully request that this Court make the Rule to Show Cause absolute and grant their Petition to Withdraw as Counsel. M Date Respectfully submitted, ABOM & KUTULAKIS, L.L.P. I h(A1_ &VWL'-0 Michelle L. So e , Esquire 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney ID No. 93034 o' 'JUN 0820 r TRACI J. MATTERN, Plaintiff V. JOHN SCOTT MATTERN, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CASE NO. 07-5740 CIVIL ACTION -LAW RULE TO SHOW CAUSE Jiwq-, AND NOW, this )_4'LY_ay of MW, 2008, upon Motion of Michelle L. Sommer, Esquire, a Rule is hereby issued upon the parties to show cause why the Petitioner should not be permitted to withdraw as counsel for John Scott Mattern, Jr. Rule returnable ) 0 `'days after the date of service of this Order. Service to be by certified mail upon John Scott Mattern, Jr. and upon Tracy J. Mattern's attorney of record, Kelly M. Knight, Esquire. Distribution: Kelly M. Knight, Esquire John Scott Mattern, Jr. Michelle L. Sommer, Esquire BY THE COURT: lei Oler, Jr., E)&HBIT 'We Opt) TRUE CORY ?n Tejsfn,0jty whersof, I h®r® u("! C !e rf + Fa LEM i o'h?tt?te?C CERTIFICATE OF SERVICE AND NOW, this ?? day of June, 2008, I, Michelle L. Sommer, Esquire of ABOM & KUTULAKIS, L.L.P., hereby certify that I did serve or cause to be served a true and correct copy of the foregoing Motion to Make Rule Absolute by First Class U.S. Mail addressed to the following: John Scott Mattern 105 East Main Street Box 103 Plainfield, PA 17081 Kelly M. Knight, Esquire Cunningham & Chernicoff, P.C. 2320 North 2nd Street Harrisburg, PA 17110 ?Va? yr"", lrumoo Michelle L. Sommer, Esquire c"`7 ? c°7 ?-- ? ?-? K _ --? r r. - • i t -? ?, ? ?;C?1 GJ i.? 'j ? a.: _..? ??: _ -= l '? - - S` t"? > { J:; !"] i3 JUN 9 42006 ? TRACI J. MATTERN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CASE N0. 07-5740 JOHN SCOTT MATTERN, JR., CIVIL ACTION -LAW Defendant AND NOW, this ZL( (day of 2008, upon consideration of the within Motion to Make Rule Absolute filed by Michelle L. Sommer, Esquire, and Abom & Kutulakis, UP the Motion to Withdraw as Counsel on behalf of Defendant, John Scott Mattern, Jr., is hereby GRANTED. BY THE COURT, Distribution: elly M. Knight, Esquire jhn Scott Mattern, Jr., G----Michelle L. Sommer; Esquire tES rnQtLL 'IT . y'?/tee J esley Oler, J. LU cL- Lu CV -`a LLJ ? b N U