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HomeMy WebLinkAbout07-7097TIERNA TUCKEY, Plaintiff VS. ADAM J. PALLIS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. Q ? - '7 0 9 7 Ov, (''crµ CIVIL ACTION - AT LAW - IN DIVORCE/ CUSTODY 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 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 the Cumberland County Courthouse, Carlisle, Pennsylvania. 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, PA 17013 (717) 249-3166 TIERNA TUCKEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 0?-76q7 G tv -d _fcr A, ADAM J. PALLIS, CIVIL ACTION - AT LAW - IN DIVORCE/ Defendant CUSTODY COMPLAINT IN DIVORCE The Plaintiff, Tierna Tuckey, by and through her attorneys, The Law Offices of Patrick F. Lauer, Jr., L.L.C., makes the following Complaint in Divorce: COUNT I - NO-FAULT DIVORCE - §§ 3301(c) or 3301(d) 1. Plaintiff, Tierna Tuckey, is an adult individual who currently resides at 1104 Floribunda Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant, Adam J. Pallis, is an adult individual who currently resides at 1104 Floribunda Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The parties have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The parties were married on July 15, 2005, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 8. This action is not collusive. WHEREFORE, the Plaintiff requests this Honorable Court enter a Decree of Divorce in this matter. COUNT II - CUSTODYNISITATION - § 5303 9. Paragraphs one (1) through eight (8) are incorporated herein by reference. 10. There is one dependent child to this marriage as follows: Lilyan Pallis, born September 30, 2002 (age 5). The child was born out of wedlock. 11. The Plaintiff seeks primary physical custody of the child. 12. The minor child is presently in the custody of both the Plaintiff and Defendant, who reside at 1104 Floribunda Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 13. During the past five years, the child has resided at the following address with the following persons: Dates: Addresses: List All Persons: Birth - 9 months 117 South Baltimore Street Mother, Tierna Tuckey Dillsburg, PA 17019 Father, Adam Pallis 9 months - Current 1104 Floribunda Lane Mother, Tierna Tuckey Mechanicsburg, PA 17055 Father, Adam Pallis 14. The Mother of the child is the Defendant, currently residing at 1104 Floribunda Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. She is married to the Defendant. 15. The Father of the child is the Defendant, currently residing at 1104 Floribunda Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. He is married to the Plaintiff. 16. The relationship of Plaintiff to the child is that of natural mother. She currently resides with the child and defendant. 17. The relationship of Defendant to the children is that of natural father. He currently resides with the child and Plaintiff. 18. The 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. 19. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 20. The 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. 21. The best interest and permanent welfare of the child will be served by granting the relief requested, because: a. Plaintiff can provide the child with adequate moral, emotional, and physical surroundings as required too meet the child's needs; b. Plaintiff is willing to continue custody of the child; C. Plaintiff continues to exercise parental duties and enjoys the love. and affection of the child. 22. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. No other persons are known to have or claim a right to custody or visitation, and therefore no notice will be given of the pendency of this action and the right to intervene, save as to the Defendant. WHEREFORE, The Plaintiff respectfully requests this Honorable Court approve any settlement reached between the parties; or, in the event they are unable to reach a settlement, grant the Plaintiff rights of primary physical custody. Respectfully subraitt@d, arlin L. ar ey, Esquire Law Offices Patrick F. Lauer, Jr., L.L.C. 2108 Market Street, Aztec Building - 2 7.2 On? Camp Hill, Pennsylvania 17011-4706 Date: ID# 84745 Tel. (717) 763-1800 TIERNA TUCKEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. No. ADAM J. PALLIS, CIVIL ACTION - AT LAW - IN DIVORCE/ Defendant CUSTODY 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. § 4904, relating to unworn falsification to authorities. -kJ Date: ierna Tuckey It C> BAs 4 IL4 Cr W O' C, n ? c N N C! ' . r ; ,az f'F7 t ! TIERNA TUCKEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. No. Q 7_ 7 6 4 7 C) u,) can., ADAM J. PALLIS, CIVIL ACTION - AT LAW - IN DIVORCE/ Defendant CUSTODY The Plaintiff, Tierna Tuckey, by and through her attorneys, the Law Offices of Patrick F. Lauer, Jr., L.L.C., seeks to obtain custody of her minor child and makes the following averments in support thereof: 1. The Plaintiff is "Mother", Tierna Tuckey, and is an adult individual who currently resides at 1104 Floribunda Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is "Father", Adam J. Pallis is an adult individual who currently resides at 1104 Floribunda Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. There is one dependent child to this marriage as follows: Lilyan Pallis, born September 30, 2002 (age 5). The child was born out of wedlock. 4. The Plaintiff seeks primary physical custody of the child. 5 The minor child is presently in the custody of both the Plaintiff and Defendant, who reside at 1104 Floribunda Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. COMPLAINT FOR CUSTODY 6. During the past five years, the child has resided at the following address with the following persons: Dates Addresses: List All Persons: Birth - 9 months 117 South Baltimore Street Mother, Tierna Tuckey Dillsburg, PA 17019 Father, Adam Pallis 9 months - Current 1104 Floribunda Lane Mother, Tierna Tuckey Mechanicsburg, PA 17055 Father, Adam Pallis , 7. The Mother of the child is the Defendant, currently residing at 1104 Floribunda Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. She is married to the Defendant. 8. The Father of the child is the Defendant, currently residing at 1104 Floribunda Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. He is married to the Plaintiff. 9. The relationship of Plaintiff to the child is that of natural mother. She currently resides with the child and defendant. 10. The relationship of Defendant to the children is that of natural father. He currently resides with the child and Plaintiff. 11. The Plaintiff has not participated as a party or witness, or in another capacity, in I other litigation concerning the custody of the child in this or another court. 12. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. The 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. 14. The best interest and permanent welfare of the child will be served by granting the relief requested, because: a. Plaintiff can provide the child with adequate moral, emotional, and physical surroundings as required too meet the child's needs; b. Plaintiff is willing to continue custody of the child; C. Plaintiff continues to exercise parental duties and enjoys the love and affection of the child. 0 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. No other persons are known to have or claim a right to custody or visitation, and therefore no notice will be given of the pendency of this action and the right to intervene, save as to the Defendant. WHEREFORE, The Plaintiff respectfully requests this Honorable Court approve any settlement reached between the parties; or, in the event they are unable to reach a settlement, grant the Plaintiff rights of primary physical custody. Respectfully submitted, zz? arli arkley, Esquire Law Offices of Patrick F. Lauer, Jr., L.L.C. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 Date: ?r Z 7 ?v7 ID# 84745 Tel. (717) 763-1800 a TIERNA TUCKEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. No. ADAM J. PALLIS, CIVIL ACTION - AT LAW - IN DIVORCE/ Defendant CUSTODY 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. § 4904, relating to unworn falsification to authorities. Date: 11-,)7-?7 I° Tierna Tuckey f`J C" C:", llz: TIERNA TUCKEY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ADAM J. PALLIS DEFENDANT • 2007-7097 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Tuesday, November 27, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, January 03, 2008 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/ Dawn S. Sunday, Esq. 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 f 6 PLEAS Of Ot1RT OF COMM P , VLV ANIA NNS IN T BERL?ID CONY' : CUM TIERN P' TU C Plaintiff ; N0.07-1091 ? DIVORCEI : T1O?1-AT LAW vs. ; CIVIL AC CUSTODY ADAM 1. PAL De endant T OF SERVICE AFFIDAVI Y ivorce and Complaint for TPIE PROTHONOTAK the Complaint i. D TO ESquireI Verify' service by a lin L• Markley, ve by personal sere I, Mar t indicated abo served upon the Defendan has been C p 1930.4. Custody he requirements Of pa' R etent adult pursuant to t comp ffidavit. plea5e see attached A ReSpeclWy submitted, arkley, ? Esquire C Lauer Jr'' LL Marliri of Patrick F . Law Offic seC Building 4706 arket Street, 2108M pennsylvarua 1'011- camp Full, 717) 763'1800 ,D#94145 Tel. 11-3 0 -2003 -Date-. ,.. ` AFFIDAVIT State of Pennsylvania County of Dauphin ) SS: ) Before me the subscriber personally appeared ? to me known, being duly swo ?Y B' Kerns and say that on No rn according to law, doth de vember 28 pose 2007 at 5:02 .?. I served ?jdam Dallis ersonall- at 1104 Floribunda Zane a Notice Com Mechanicsbur laint in Divorce PA Order an in the matter and Cora laint in Custod of Cumberland Count Court Action 07-7097 of CoMMon Pleas T1erna Tucke vs. Civil Adam the documents to Mr. Dallis J• Dallis b handin and further deponent sayeth not. Sworn and subscribed before ??me this day o f 2007 N ary lic fifir' B B. rns 5235 N. Front St. Harrisburg, PA 17110 COMMONWEALTHLa O ENNSYLVANIA Wendy tary Public Susque phin County My Com+ct. 24, 2009 Member, PennsyIv an'a 4Gsociation of Notaries -,? ?, ? t _?_r-- fw'? ?,--t C€ f :-°e ,? .. _ -?? ??? .? JAN 0 7 2008 TIERNA TUCKEY Plaintiff vs. ADAM J. PALLIS Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 07-7097 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this ? 4- ! day of a n , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Tierna Tuckey, and the Father, Adam J. Pallis, shall have shared legal custody of Lilyan Pallis, born September 30, 2002. Major decisions concerning the Child including, but not necessarily limited to, her health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in the Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the Child. Neither party shall attempt to alienate the affections of the Child from the other party. Each party shall notify the other of any activity or circumstance concerning the Child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. 2. The Child shall primarily reside with the Mother and the Father shall have liberal, reasonable periods of custody with the Child when he is not working. ?ti 3. Within ninety (90) days of the date of this Order, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary to establish a specific schedule for exchanges of custody if either party feels it is necessary. Vt?,LjPlytb ?? t 4. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. cc: Marlin L. Markley, Esquire - Counsel for Mother n Thomas M. Clark, Esquire - Counsel for Father l20P E'MS' m BY THE COURT, TIERNA TUCKEY Plaintiff VS. ADAM J. PALLIS Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 07-7097 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 CUSTODY OF Lilyan Pallis September 30, 2002 Mother/Father 2. A custody conciliation conference was held on January 3, 2008, with the following individuals in attendance: the Mother, Tierna Tuckey, with her counsel, Marlin L. Markley, Esquire, and the Father, Adam J. Pallis, with his counsel, Thomas M. Clark, Esquire. 3. The parties agreed to entry of an Order in the form as attached. 6? ..vul U Date Dawn S. Sunday, Esquire Custody Conciliator TIERNA TUCKEY, Plaintiff/Petitioner, VS. ADAM J. PALLIS, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 07-7097 CIVIL ACTION - AT LAW-IN DIVORCE/ CUSTODY AND NOW, comes the Petitioner, Tierna Tuckey, by and through her attorney's, the Law Offices of Patrick F. Lauer, Jr., LLC, and files this Petition for Emergency Relief and in support thereof, avers as follows: 1. Petitioner, Tierna Tuckey, an adult individual, who resides at 1104 Floribunda Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055, is the Plaintiff in the above-captioned Divorce action. 2. Respondent, Adam J. Pallis, an adult individual, who resides at 1104 Floribunda Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055, is the Defendant in the above- captioned Divorce action. 3. The parties in this matter are husband and wife, having been married on July 15, 2005 in Cumberland County, Pennsylvania. 4. On November 27, 2007, petitioner filed a Complaint in Divorce. 5. Petitioner believes that a situation exists that requires emergency relief due to the following: a. Petitioner purchased the residence prior to the marriage, and the property is titled and mortgaged in her name only. b. During October of 2007 respondent punched a hole in the door to petitioner's bedroom c. Respondent drinks often and when he drinks he is verbally and emotionally abusive towards petitioner. d. Petitioner recently found a tin belonging to respondent in her house containing marijuana 6. Respondent has created a hostile environment. 7. A voice mail message was left on March 24, 2008, with Respondent's counsel, Thomas Clark, Esq., regarding this petition. It is assumed that opposing counsel does not concur with the requested relief. 8. The Honorable J. Wesley Oler has previously signed a custody order for this case. WHEREFORE, Petitioner respectfully requests that this Honorable Court enter an Order granting Petitioner exclusive possession of the marital residence located at 1104 Floribunda Lane, Mechanicsburg, Pennsylvania, and evicting Respondent from the premises and prohibiting Respondent from reentering until further determination by this Honorable Court. Date: V2 Val !Respectfull mi d, -!Marlin L. kl y, Esquire 2108 Market S et, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 TIERNA TUCKEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner, CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 07-7097 ADAM J. PALLIS, CIVIL ACTION - AT LAW-IN DIVORCE/ Defendant/Respondent CUSTODY I verify that the statements made in this Petition for Special Relief 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: Tierna Tuckey TIERNA TUCKEY, Plaintiff/Petitioner, vs. ADAM J. PALLIS, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07-7097 CIVIL ACTION - AT LAW-IN DIVORCE/ CUSTODY I hereby certify that I am this day serving a copy of the foregoing Petition upon the person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy in the United States first class mail, postage prepaid, addressed as follows: Thomas M. Clark, Esquire The Wiley Group 130 W. Church Street Suite 100 Dillsburg, PA 17019 Respectfully submitted, Date: 3/z Z a v j Marliaarkley, Esquire 2108 M et Street, Aztec Building Camp Hil, Pennsylvania 17011-4706 ID4 84745 Tel. (717) 763-1800 LJ? .e!^q .-4 1 r?w Z r,«t TIERNA TUCKEY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ADAM J. PALLIS, Defendant NO. 07-7097 CIVIL TERM ORDER OF COURT AND NOW, this 4th day of April, 2008, upon consideration of Plaintiffs Petition for Emergency Relief. Exclusive Possession of Marital Residence, a hearing is scheduled for Tuesday, May 6, 2008, at 9:30 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. -Marlin L. Markley, Esq. 2108 Market Street Camp Hill, PA 17011 Attorney for Plaintiff Thomas M. Clark, Esq. 130 W. Church Street Suite 100 Dillsburg, PA 17019 Attorney for Defendant :rc CO I" rn".t6L BY THE COURT, 14,0 J. esley Oler r., J. ?n?A t, t" 91:1 tad _ 84Y z A8VIOINC)HI08d :alt XuqtP-40 TIENRA TUCKEY, Plaintiff v ADAM J. PALLIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 07-7097 CIVIL TERM IN RE: PLAINTIFF'S PETITION FOR EMERGENCY RELIEF ORDER OF COURT AND NOW, this 6th day of May, 2008, upon consideration of Plaintiff's Petition for Emergency Relief: Exclusive Possession of Marital Residence, and pursuant to an agreement of the parties in open court with their respective counsel, it is ordered and directed as follows: 1. Defendant, Adam J. Pallis, shall vacate the premises no later than August 1st, 2008. Marlin L. Markley, Esquire 2108 Market Street Camp Hill, PA 17011 /For Plaintiff v Thomas M. Clark, Esquire 130 W. Church Street Suite 100 Dillsburg, PA 17019 For Defendant :mae (2DF fS' r»atI Lcc By the Court, A 15 sc wa 9- ANI - JO P. Richard Wagner, Esquire PA Supreme Court ID# 23103 Mancke, Wagner & Spreha 2233 North Front Street Harrisburg, PA 17110 Telephone (717) 234-7051 Fax (717) 234-7080 Attorney for Plaintiff TIERNA TUCKEY, V. ADAM J. PALLIS Plaintiff, Defendant. TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO: 07-7097 CIVIL TERM : CIVIL ACTION - LAW IN CUSTODY PRAECIPE Please withdraw the appearance of the un igned as counsel for the Plaintiff, Tierna Tuckey, in the above-captioned action. Date: ?p ck auer, sq. I.D. # 2108 Market Street Camp Hill, PA 17011 (717) 243-0220 Please enter the appearance of the undersigne as counsel for the Plaintiff, Tierna Tuckey, in the above-captioned action. P. Wagner, Esquire I.D. #23103 Date: 7 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Plaintiff OF THE 'RY L ^009 AL -8 PH ):136 }