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Home My WebLink About03-5788DENNIS E. ROBINSON, JR., § Plaintiff § V. § DEANNA M. ROBINSON, § Defendant § IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. D3 --00V l..tCaiC,?fQ? CIVIL ACTION - 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 will proceed without you and a decree in divorce or annulment may 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, 1 Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 DENNIS E. ROBINSON, JR., § Plaintiff § V. § DEANNA M. ROBINSON, § Defendant § IN THE COURT OF COMMON PENNSYLVANIA OF CUWERLAND COUNTY, ! g?V NO. 03- s7PP CIVIL ACTION - IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Dennis E. Robinson, Jr., by and through his attorneys, Laguna Reyes Maloney, LLP, and represents as follows: 1. Plaintiff is Dennis E. Robinson, Jr., an adult individual currently residing at 610 Erford Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Deanna M. Robinson, an adult individual currently residing at 610 Erford Road, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff is both bona fide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married in July of 2002, in Dauphin County, Pennsylvania. 5. Plaintiff and Defendant are citizens of the United States of America. 6. The Defendant is not a member of the Armed Forces of the United States of America or its Allies. 7. Plaintiff avers that are no children born to this marriage. COUNTI IRRETRIEVABLE BREAKDOWN 3301(c) of the Divorce Code 8. Paragraphs l through 7 are hereby incorporated by reference and made a part hereof. 9. The marriage is irretrievably broken: Plaintiff and Defendant have lived separate and apart since September 28th, 2003, and continue to live separate and apart as of the date of filing this Complaint. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. 10. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 11. Plaintiff requests the Court to enter a decree of divorce. COUNT 11 INDIGNITIES 3301 (a)(6) of the Divorce Code 12. Paragraphs 1 through 11 are incorporated herein by reference as if set forth in their full text. 3. Such other additional relief as the Court deems necesjary and just. Date: lel"T c 3 Ro r . Laguna, Jr.Esquire Supreme Court I.D. N'o.: 75900 Attorney for Plaintif: LAGUNA REYES MALONEY, LLP 1119 North Front Street Harrisburg, PA 17102 (717) 233-5292 VERIFICATION I verify that the statements made in the foregoing document(s) are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein may subject me to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. iDcnn6s&? b' on. Jr. r rl) -d9 IL) ?' O Q •O c wnn .1 L DENNIS E. ROBINSON, JR., Plaintiff V. DEANNA M. ROBINSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 3-5788 CIVIL TERM CIVIL ACTION - IN DIVORCE DEFENDANT'S PETITION FOR ALIMONY PENDENTE LITE 1. Petitioner Deanna M. Robinson is the Defendant is the above-referenced divorce action which was filed on November 3, 2003. 2. Simultaneously with this Petition, Defendant has filed an Answer to the Divorce Complaint which included a Count for Alimony Pendente Lite ("APL"). 3. Petitioner requires reasonable support and/or APL to sustain herself adequately within the standard of living established during the marriage and to maintain properly and adequately the within action for divorce. 4. Petitioner seeks APL effective as of the date the claim was filed in the Answer to Divorce Complaint. 309135-1 WHEREFORE, Petitioner requests that this Court enter an Order awarding alimony pendente lite in this matter. Respectfully submitted, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By Andrew C. Spears, Esquire Attorney I.D. No. 87737 P.O. Box 5300 3211 North Front Street Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Defendant Dated: August 12, 2004 309135-1 VERIFICATION I, Deanna M. Robinson, verify that the statements made in the foregoing Petition for Alimony Pendente Lite are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. a M. R bitkn Dated: 2 ?? L{ 309135-1 CERTIFICATE OF SERVICE I, Andrew C. Spears, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served a true and exact copy of the Petition for Alimony Pendente Lite with reference to the foregoing action by first class mail, postage prepaid, thist2-day of August, 2004, on the following: Roger R. Laguna, Jr., Esquire Laguna Reyes Maloney, LLP 1119 North Front Street Harrisburg, PA 17102 Andrew C. Spears, Esquire 309135-1 (-) N S w O n L n r*t -n ti?m ^zi FE6=26-Gw 10:30 FROM-Cumberland County Domestic Relations 7172406248 T-713 P.002/003 F-704 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DENNIS E. ROBINSON JR. NO 03-5788 Plaintiff V CIVIL ACTION - LAW IN DIVORCE DEANNA M. ROBINSON Defendant DRS ATTACHMENT FOP, TPL PROCEEDINGS NAME Deanna M. Robinson ADDRESS BIRTH DATE SOCIAL SECURITY NUMBER HOME PHONE WORK PHONE EMPLOYER NAME EMPLOYER ADDRESS ,TOB TITLE/POSITION DATE EMPLOYMENT COMMENCED GROSS PAY NET PA`s OTHER INCOME ATTORNEY'S NAME ATTORNEY'S ADDRESS ATTORNEY'S PHONE NUMBER- PETITIONER. Deanna Marie R 102 W. High St., # 6/24/78 163-66-3351 f 503-7412 730-9454 Sculutured Images Child support Andrew CSe 3211 N. Front 238-8187 FEc 26-04 10:30 FROM-Cumberland County Domestic Relations TI724062,ts T-713 P.003/003 F-704 RESPONDENT NAME Dennis E. Robinson, Jr. ADDRESS 610 Erford Road„_ Camp Hill, PA 17011 BIRTH DATE 3/2/74 SOCIAL SECURITY NUMBER 199-68-4266 HOME PRONE " 761-1660 WORK PHONE 554-9366 EMPLOYER NAME Self-em to ed EMPLOYER ADDRESS " JOB TITLE/POSITION Entreprenaur DATE EMPLOYMENT COMMENCED GROSS PAX NET PAY OTHER INCOME " ATTORNEY'S NAME Roger R. Laguna, Jr., Esq. ATTORNEY'S ADDRESS 1119 N. Front St., Harrisburg, PA 17102 ATTORNEY'S PHONE NUMBER 233-5292 MARRIAGE' DATE OF MARRIAGE 7/20/02 PLACE OF MARRIAGE DATE OF SEPARATION ADDRESS OF LAST MARITAL HOME DESCRIPTION OF DOCUMENT RAISING APL CLAIM DATE APL DOCUMENT FILED 610 Erford Road Camp Hill, PA 17011 Answer to Divorce Complaint With Additional Costs t 9, 2004 DENNIS E. ROBINSON, JR., Plaintiff V. DEANNA M. ROBINSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 3-5788 CIVIL TERM CIVIL ACTION - IN DIVORCE PETITION TO MODIFY CUSTODY AND NOW, this 12th day of August, 2004, comes the Petitioner/Defendant, Deanna M. Robinson, by and through her attorneys, Metzger, Wickersham, Knauss & Erb, P.C., and files the within Petition of which the following is a statement: Petitioner is Defendant Deanna M. Robinson (hereinafter "Mother"), natural Mother of the Minor Child, Eva M. Vasquez, dob: 10/27/2003 (hereinafter "the Minor Child"), who currently resides at 102 West High Street, No. 303, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Respondent is Plaintiff Dennis E. Robinson, Jr. (hereinafter "Father"), natural father of the Minor Child, who currently resides at 610 Erford Road, Camp Hill, Cumberland County, PA 17011. 3. On or about May 6, 2004, a Stipulated Temporary Custody Order was entered by this Honorable Court following an agreement reached at a Custody Conciliation held on April 27, 2004. 309164-1 4. The Custody Order dated May 6, 2004 is attached hereto as Exhibit A and incorporated herein by reference and provides, inter alia, that the custody of the Minor Child shall be exercised between the parties as follows: a. Plaintiff Dennis E. Robinson, Jr., shall have sole legal custody of the Minor Child; Plaintiff Dennis E. Robinson, Jr., shall have sole physical custody of the Minor Child; 5. Mother only agreed to the May 6, 2004 Custody Order because she was under extreme duress due to the fact that the prior custody arrangement was forcing her to have continuous contact with Father who had a Protection From Abuse Order entered against him at the Giant Grocery Store parking lot where he would continue to abuse, harass and stalk Mother at the custody exchanges. 6. These exchanges would often result in threats and damage to Mother's vehicle. Mother now wishes to reclaim her custody rights as to the Minor Child, as she has not seen the Minor Child in some time. Further, Mother has serious concerns regarding Father's ability to care for the Minor Child. 9. Father has a long history of violence, criminal conduct, drug abuse and spousal abuse which makes Mother question the Minor Child's safety while in Father's care. Further, Mother feels that it would be in the best interest of the Minor Child if this Honorable Court would modify the aforementioned Custody Order, granting shared legal custody of the Minor Child to both parties and granting Mother primary physical custody of the Minor Child. 309164-1 WHEREFORE, Petitioner/Defendant Deanna M. Robinson respectfully requests that this Honorable Court grant the modification to the Custody Order as set forth above. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By Andrew C. Spears, Esquire Attorney I.D. No. 87737 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Deferldant/Petitioner Dated: 1S -S 309164-1 VERIFICATION I, Deanna M. Robinson, do hereby verify that the facts set forth in the foregoing Petition to Modify Custody Order are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Deanna M. Robinson Date: -7" awl- 09 309135-1 CERTIFICATE OF SERVICE I, Andrew C. Spears, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served a true and correct copy of the Petition to Modify Custody Order with reference to the foregoing action by first class mail, postage prepaid, this is- -e day of August, 2004, on the following: Dennis E. Robinson, Jr. c/o Roger R. Laguna, Jr., Esquire Laguna Reyes Maloney, LLP 1119 North Front Street Harrisburg, PA 17102 Andrew C. Spears 309135-I N ? O Q Q IZ- prn C.7 DENNIS E. ROBINSON, JR., IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 3-5788 CIVIL TERM V. DEANNA M. ROBINSON, CIVIL ACTION - IN DIVORCE Defendant NOTICE TO PLEAD TO: Dennis E. Robinson, Jr. c/o Roger R. Laguna, Jr., Esquire Laguna Reyes Maloney, LLP 1119 North Front Street Harrisburg, PA 17102 You are hereby notified to plead to the enclosed Answer to Divorce Complaint With New ce hereof or a default judgment may be entered against Matter within twenty (20) days from servi you. Respectfully submitted, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By Sl v Andrew C. S •s, Esquire Attorney I.D. No. 87737 P.O. Box 5300 3211 North Front Street Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Defendant Dated: August 12, 2004 309129-1 DENNIS E. ROBINSON, JR., Plaintiff V. DEANNA M. ROBINSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 3-5788 CIVIL TERM CIVIL ACTION - IN DIVORCE NOW COMES, Defendant Deanna M. Robinson, by and through her attorneys, Metzger, Wickersham, Knauss & Erb, P.C., and files the following Answer to the Complaint: Admitted. 2. Denied. Defendant Deanna M. Robinson currently resides at 102 West High Street, No. 303, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Admitted. 4. Denied. By way of clarification, plaintiff and Defendant were married on July 20, 2002. 5. Admitted. 6. Admitted in part; denied in part. It is admitted that Defendant is not a member of the Armed Forces. By way of further clarification, neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provision of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its Amendments. 7. Denied. The Minor Child, Eva Robinson (DOB: marriage. 10/27/03) was born to this 309129-1 ,COUNT I g. No response required. 9. Admitted. 10. Admitted. 11. No response required. COUNTII INDIGNITIES-. 3301 a 6 OF DIVORCE 12. No response required. 13. No response required. 14. Denied. On the contrary, plaintiff has offered such indignities to Defendant, the innocent and injured spouse, as to render her condition intolerable and life burdensome. WHEREFORE, Defendant requests this Court to dismiss Count 11 of Plaintiff s Complaint. COUNT III 15. No response required. 16. Admitted. 17. Admitted. WHEREFORE, Defendant requests this Court to enter an Order equitably dividing marital property at the appropriate time. 309129-1 ADDITIONAL COUNTS COUNT IV 18. The prior paragraphs of this Answer are incorporated herein by reference thereto. 19. Defendant has offered such indignities to plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. COUNT V 20, The prior paragraphs of this Answer are incorporated herein by reference thereto. 21. By reason of this action, Defendant will be put to considerable expense in the preparation of her case and in the employment of counsel and the payment of costs. 22. The Defendant is without sufficient funds to support herself and to meet the costs and expenses of this litigation and unable to appropriately maintain herself during the pendency of this action. 23. The Defendant's income is not sufficient to provide for her reasonable needs and pay her attorneys' fees and the costs of this litigation. 24. The Plaintiff has adequate earnings to provide support for the Defendant and to pay her counsel fees and expenses. COUNT VI ALIMONY 25. The prior paragraphs of this Answer are incorporated herein by reference thereto. 26. Defendant lacks sufficient property to provide for her reasonable needs. 309129-1 27. Defendant is unable to support herself sufficiently through appropriate employment. 28. Plaintiff has sufficient income and assets to provide continuing support for the Defendant. WHEREFORE, Defendant prays this Honorable Court to: a. Compel Plaintiff to pay alimony pendente lite to defendant; b. Compel Plaintiff to pay alimony to defendant; C. Equitably distribute all property, both real and personal, owned by the parties; d. Compel Plaintiff to pay Defendant's counsel fees, costs and expenses and the costs and expenses of this action; e. As to Count IV, that a decree in divorce be entered divorcing Defendant and Plaintiff from the bonds of matrimony; and f Grant such further relief as the Court may deem equitable and just. Respectfully submitted, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Andrew C. Spears 3211 North Front Street P. O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Defendant Date: -? 309129-1 VERIFICATION I, Deanna M. Robinson, verify that the statements made in the foregoing Answer to Divorce Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. Dated: ?- Qu - O `A-- 309129-1 CERTIFICATE OF SERVICE 1, Andrew C. Spears, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served a true and exact copy of the Answer to Divorce Complaint with reference to the foregoing action by first class mail, postage prepaid, thisl u? day of August, 2004, on the following: Roger R. Laguna, Jr., Esquire Laguna Reyes Maloney, LLP 1119 North Front Street Harrisburg, PA 17102 Andrew C. Spears, Esquire 309129-1 ^w v/ , C . Y ? . q 1 C t'?J ? l: it ? rv DENNIS E. ROBINSON, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 2003-5788 CIVIL TERM DEANNA M. ROBINSON, IN DIVORCE Defendant/Petitioner Pacses# 215106670 ORDER OF COURT AND NOW, this 27`h day of August, 2004, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav on September 24, 2004 at 9:00 a.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.110 (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Mail copies on Petitioner 8-24-04 to: < Respondent Andrew Spears, Esquire Roger Laguna, Esquire Date of Order: August 27, 2004 r R. J. Sha ay, Conference Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 CC361 tr; .c a c t W vn DENNIS E. ROBINSON, JR. IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 03-5788 CIVIL ACTION LAW DEANNA M.ROBINSON IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, August 25, 2004 , 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 Monday, October 11, 2004 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 Greevv Esq. mnc 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 4np-? fwr -,* 17W --e? ?a c-?> 7-?2:7r' f W "p, /Orvw , °m;t?-° *-V ? -"krv v.vtr? ?,sra:au Cl .g ENIC.I 0£ 00V Quz -33, ho o-r-15 wlloNO'r4LOtii 331i3Hi do 3;I.4o-a OCT 1 9 200 DENNIS E. ROBINSON, JR., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 03-5788 CIVIL TERM V. DEANNA M. ROBINSON, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER TO RELINQUISH JURISDICTION AND NOW, this 11th day of October, 2004, counsel for the parties having agreed to cancel the Custody Conciliation Conference scheduled for October 11, 2004, the Conciliator hereby relinquishes jurisdiction of the above captioned matter FOR THE BY: Int fssa Peel Greevy, Esquire Custody Conciliator :237183 C:+ r i In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION DENNIS E. ROBINSON, Jr., ) Docket Number 03-5788 CIVIL ) Plaintiff /Respondent VS. ) PACSES Case Number 215106670 DEANNA VASQUEZ, ) Defendant/ Petitioner ) Other State ID Number ORDER AND NOW, to wit on this 9TH DAY OF MARCH, 2005 IT IS HEREBY ORDERED that the ® Complaint for Support or Q Petition to Modify or Q Other filed on AUGUST 12, 2004 in the above captioned matter is dismissed without prejudice due to: THE PLAINTIFF NOT PURSUING THE MATTER THROUGH THE DOMESTIC RELATIONS SECTION SINCE THE FILING DATE OF AUGUST 12, 2004. ® The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. DRO: RJ Shadddy xC: plaintiff defendant Roger Laguna, Esquire Andrew Spears, Esquire BY TH URT: Kevin A. Hess JUDGE Form OE-506 Service Type M Worker ID 21005 -;, <t , F:\FILES\DATAFILE\General\CuL cnt\I I37131_pral C, a. Rd 9/20/04 006PM Revised 3/7/05 W 53AM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant DENNIS E. ROBINSON, JR., Plaintiff V. DEANNA M. ROBINSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-5788 CIVIL ACTION - LAW IN DIVORCE AND CUSTODY PRAECIPE TO THE PROTHONOTARY: Please withdraw the appearance of Metzger Wickersham Knauss & Erb on behalf of Defendant in the above matter. METZGER WICKERSHAM KNAUSS & ERB By: Q U . _/ Andrew C. Spears, Esquire I.D. No. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110 (717) 238-8187 Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of Defendant in the above matter. MARTSON DEARDORFF WILLIAMS & OTTO By Jenni r L. Spears, Esquire I.D. No. 87445 Ten East High Street Carlisle, PA 17013 (? C (717) 243-3341 Date: Attorneys for Defendant CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Roger R. Laguna, Esquire 1119 North Front Street Harrisburg, PA 17102 MARTSON DEARDORFF WILLIAMS & OTTO Tncia D. Eckenroad Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: ,1 *7 /0 ??? ??'?, ,:... Curtis R. Long Prothonotary office of the Vrotbonotarp Cumberianb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 0_ - .57788 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573