Loading...
HomeMy WebLinkAbout86-2080KIMBERLY M. HOFFMAN, formerly KIMBERLY M. MYERS, Plaintiff vs. STEPHEN C. MYERS, Defendant vs. DR. GORDON MYERS and LOUISE MYERS, Additional Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0. 2080 CIVIL 1986 ORDER AND NOW, this '"Z~~ ~- day of ~ 0, upon receipt of the Conciliator's Report, it appearing that the parties have reached an agreement which was dictated in their presence and approved by them and their counsel, it is hereby ordered and directed as follows: 1. All prior Orders entered in this case are VACATED. 2. The parties shall share legal custody of the minor child, Stephanie N. Myers, d.o.b. November 8, 1985. 3. Physical custody of the minor child shall be as follows: A. The paternal grandparents shall have the child every weekend from Friday until Sunday at times to be agreed upon. B. Mother shall have custody of the child at all other times. 4. The parties shall share the holidays as agreed upon. 5. The parties shall enjoy periods of exclusive vacation time with the child as agreed upon. 6. The parties shall have access to the child on her birthday, at times to be agreed upon. 7. Such other times as the parties may agree. BY THE COJ~I'; EDGAR B. BAYLEY, J. John F. Lyons, Esquire Stephen C. Myers, pro se Robert C. Saidis, Esquire ~' .o° mlb R ~i~~~~~~n~ ISSN ~~ :tit ~~ a ~ ~ ~'~' ad __ .~: ~~~~ ~~w~ `~~r~~ i ~~ k ,~_j I, a Zvi KIMBERLY M. HOFFMAN, formerly KIMBERLY M. MYERS, Plaintiff vs. STEPHEN C. MYERS, Defendant vs. DR. GORDON MYERS and LOUISE MYERS, Additional Defendants JUDGE PREVIOUSLY ASSIGNED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2080 CIVIL 1986 The Honorable Edgar B. Bayley CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child(ren) who is(are) the subject of this litigation is as follows: NAME Stephanie N. Myers uT~ Tun e'r'F November 8, 1985 CURRENTLY IN CUSTODY OF Additional Defendants 2. A Conciliation Conference was held on March 1, 2000, and the following individuals were present: the Plaintiff and her attorney, John F. Lyons, Esquire; the Defendant appeared pro se; the Additional Defendants and their attorney, Robert C. Saidis, Esquire. 3. Items resolved by agreement: See attached Order. 4. Issues yet to be resolved: See attached Order. 5. The Plaintiff s position on custody is as follows: See attached Order. 6. The Defendant's position on custody is as follows: See attached Order. 7. Need for separate counsel to represent child(ren): Neither party requested. 8. Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe any is necessary. Date: March 20, 2000 Mic ael L. Bangs Custody Conciliator i~~Y +~ :~ ~00~ KIMBERLY M. HOFFMAN, FORMERLY KIMBERLY M. MYERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. STEVEN C. MYERS, DR. GORDON MYERS AND LOUISE MYERS, Defendants NO. 86-2080 CIVIL ACTION -LAW CUSTODY ORDER OF COURT Edgar B. Bayley, J. AND NOW, this 2/i~ day of -1~~, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parents, Kimberly M. Hoffman and Steven C. Myers, shall have shared legal custody of the minor Child, Stephanie N. Myers, born November 8, 1985. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of Pa. C. S.§5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. The present custodial arrangement indicated in the prior Order of March 23, 2000, shall continue in effect until June 6, 2001. On June 6, 2001, Father shall have primary physical custody, subject to Mother's rights of liberal partial custody which shall be exercised as the parties may agree. 3. The parents and minor Child shall participate in counseling with Dr. Ed Batista to assist them in reestablishing the parents as the primary parenting figures in the life of the minor Child. Counseling shall also address the parents' concerns regarding the Child's academic failures and behavior management issues. 4. Cumberland County Court of Common Pleas shall retain jurisdiction of this matter. ~~Pr'~~~t qi- 1 C jl 1; ~ -1 :! „ +. No. 86-2080 BY THE Edgar B. Bayley, J. Dist: Steven C. Myers, 821 Wellsville Road, Wellsville, PA 17365 John F. Lyons, Esquire, 112 Walnut Street, Harrisburg, PA 17101 Susan M. Seighman, Esquire, 111 N. Front Street, Harrisburg, PA 17108 c~~~~ v KIMBERLY M. HOFFMAN, FORMERLY IN THE COURT OF COMMON PLEAS OF KIMBERLY M. MYERS, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. STEVEN C. MYERS, DR. GORDON MYERS AND LOUISE MYERS, Defendants NO. 86-2080 CIVIL ACTION -LAW 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: as follows: The pertinent information concerning the Child who is the subject of this litigation is NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Stephanie N. Myers November 8, 1985 Paternal grand parents 2. A Custody Conciliation Conference was held on April 10, 2001, with the following individuals in attendance: the Mother, Kimberly M. Hoffman, and her counsel, John F. Lyons, Esquire; the Father, Steven C. Myers, pro se; the Paternal Grandmother, Louise Myers, and her counsel, Susan Seighman, Esquire. The Paternal Grandfather did not attend. 3. The parties reached an agreement in the form of an Order as attached. ~ ~~ D Date Melissa Peel Greevy, Esquire Custody Conciliator KIMBERLY M. HOFFMAN, formerly KIMBERLY M. MYERS, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0. 2080 CIVIL 1986 STEPHEN C. MYERS, Defendant vs. DR. GORDON MYERS AND LOUISE MYERS, Additional Respondents CIVIL ACTION - LAW CUSTODY/VISITATION 4. ' 1999, AND NOW, this ~~ day of ~ """" ~ upon review of the Conciliator's Report, it appearing that the parties, except for Stephen C. Myers, who was served but did not attend, agreed to the terms and provisions of this temporary Order, which was dictated in their presence and approved by them and their counsel, it is hereby ordered and directed as follows: 1. The parties have agreed to participate in a custody evaluation to be performed by Dr. Stanley Schneider of Guidance Associates. Both parties agree that they will cooperate in getting the evaluation scheduled and completed. Both parties agree that they shall attend all sessions as recommended by the custody evaluator. The custody evaluator is to provide a report to both parties and their counsel. The cost of said evaluation shall be shared. The parties shall reappear for another custody KIMBERLY M. HOFFMAN, formerly IN THE COURT OF COMMON PLEAS KIMBERLY M. MYERS, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Petitioner v, NO. 2080 CIVIL 1986 STEPHEN C. MYERS, Defendant/Respondent v. DR. GORDON MYERS AND LOUISE MYERS, CIVIL ACTION -LAW Additional Respondents IN CUSTODY ORDER OF COURT AND NOW, this ~ day of v 1999, upon consideration of the attached Petition to Modify Custody der, it is hereby directed that the parties and their respective counsel appear before rC10,C L . 5 ,the conciliator, at ~''~ ~C('(1 A on the ~_ day of e , 1999, at ', .for aPre-hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, the define and narrow the issues to be heard before 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. FOR THE COURT: By. (.,~` ~ ~~. Custody Conciliator (~j ,> 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. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, FOURTH FLOOR CARLISLE, PA 17013 (717) 240-6200 J ~6~~-~ t~r`~!b'~1`1,~SrVN3d ~~°~ ~~'?~~9i~~f~~ '~ ~ ~£ ~d $ I ~Il~ ~6 ~~~~~~~~ KIMBERLY M. HOFFMAN, formerly KIMBERLY M. MYERS, Plaintiff/Petitioner v. STEPHEN C. MYERS, Defendant/Respondent v. DR. GORDON MYERS AND LOUISE MYERS, Additional Respondents IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2080 CIVIL 1986 CIVIL ACTION -LAW IN CUSTODY PETITION TO MODIFY CUSTODY COMES NOW, Plaintiff/Petitioner, Kimberly M. Hoffman, formerly Kimberly M. Myers, by and through her attorney, John F. Lyons, and respectfully represents and avers as follows: 1. The Petitioner is Kimberly M. Hoffman, an adult individual who currently resides at 495B Glenn Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 2. The Respondent is Stephen C. Myers, an adult individual with a last known address of 201 Louise Court, Enola, Cumberland County, Pennsylvania. 3. The Petitioner and Respondent are the natural parents of the minor child, Stephanie N. Myers (D.O.B. 11/8/85). 4. The Additional Respondents, Dr. Gordon Myers and Louise Myers, are adult individuals who currently reside at 25 Eastgate Drive, Camp Hill, Pennsylvania. Additional Respondents are the paternal grandparents of Stephanie N. Myers. 5. Pursuant to an Order of Court dated June 6, 1989, Additional Respondents were granted temporary custody of Stephanie N. Myers, subject to visitation by both the Petitioner and Respondent. (See Order of Court dated June 6, 1989, attached hereto, incorporated herein by referenced thereto and marked Exhibit "A") 6. Since the date of entry of the aforementioned Order, Additional Respondents have continued to exercise physical custody of Stephanie. 7. Subsequent to the date of the entry of the June 6, 1989, Order of Court, the Petitioner has continued to exercise her visitation rights, which rights have been expanded to include partial custody rights in Petitioner a minimum of three nights per week by mutual agreement of the Petitioner and Additional Respondents. 8. Subsequent to the date of the entry of the June 6, 1989, Order of Court, Respondent has exercised his visitation rights at such times as were convenient for Additional Respondents. 9. Due to the failing health of Additional Respondent, Dr. Gordon Myers and the advanced age of both Additional Respondents, Additional Respondents have not been able to provide proper care, supervision and control to the child. The child had failing grades in school requiring that she attend Summer School. The child has also severely acted out at the home of Additional Respondents prompting them to call her mother and/or the local police. Petitioner believes, and therefore avers, that the best interests of Stephanie N. Myers will be served by the Court in modifying the existing Temporary Order and granting primary physical custody of Stephanie to Petitioner. WHEREFORE, the Petitioner prays your Honorable Court to modify the June 6, 1989, Order of Court and grant primary physical custody of the minor child, Stephanie N. Myers, to the Petitioner, subject to visitation and/or partial custody rights in Additional Respondents. tted, Date: ~ • Qi "qg By; J F yons, Esqu' e ttor y for Petitio er 10 12 Walnut St et arrisburg, PA 171 (717) 238-4777 (771) 238-4793 Telecopier I.D. # 23859 EXHIBIT "A" ' KIMBERLY M. MYERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTX, PENNSYLVANIA v. N0. 2080 CIVIL 1986 STEPHEN C. MYERS, Defendant ORDER ~~ At~D NOW, this ~ day of June, 1989, upon consideration of the attached Petition, it is ordered and decreed that temporary custody of Stephanie N. Myers (D.O.B. 11-8-85) is granted to Dr. Gordon Myers and Louise Myers subject to visitation by Stephen C. Myers as provided in the Order dated January 1Z, 1989 and further providing Kimberly M. Myers with periods of visitation at the residence~of the Myers' at 25 Eastgate Drive, Camp Hill, Pennsylvania at times mutually agreed to between the Myers and Respondent. Respondent's visitation subject to the express condition that she not remove the child from the residence until further order of this Court. A hearing on this matter is scheduled for Court Room No. 3, Cumberland County Court House on ~~~ j~ , 1989 at 3:0 U .M. . BY THE COURT, IU1S, GU1U0 MASLAND W. High Strtet f'Arlisle, Pa. S ~~ e rge E, ffer, TRUE COPY FROM RECQRD In Tcoam.~ ; w:~ct. f, h :. i.n o sel my hand and tit ~ ;; ~ul : ~i ~:: r, . t i-o n.;ie, ~ a. / 9 ~ f115____„„~.r..~.....- ~ N~uuwnoery ~J ~ ~ VERIFICATION I, Kimberly M. Hoffman, verify that the statements made in the attached pleading 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 unsworn falsification to authorities. Date: X131 a 9 CERTIFICATE OF SERVICE I, John F. Lyons, Esquire, attorney for Petitioner, hereby certify that I have on the date shown below, served a copy of the foregoing Petition to Modify Custody upon the following and in the manner indicated below: CERTIFIED MAIL, RETURN RECEIPT REQUESTED Dr. Gordon Myers and Louise Myers 25 Eastgate Drive Camp Hill, PA 17011 Robert C. Saidis, Esquire (Counsel for Dr. and Mrs. Myers) SAIDIS, SHUFF & MASLAND 2109 Market Street Camp Hill, PA 17011 Stephen C. Myers 821 Wellsville Road Wellsville, PA 17365 By: Date: ~ " 3 '~' John .Lyons, squire Atto ey for Pe itioner 108 112 Walnut t isburg, PA 17101 (717) 238-4777 Telecopier (717) 238-4793 Pa. I.D. No. 23859 KIMBERLY M. HOFFMAN, FORMERLY KIMBERLY M. MYERS PLAINTIFF V. STEPHEN C. MYERS DEFENDANT DR. GORDON MYERS AND LOUIS MYERS AND NOW, this 16th IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • 86-2080 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT day of February , 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. ,the conciliat at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 21st day of March , 2001, at 11:00 a.m. for aPre-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. FOR THE COURT, By: /s/ Meli a P. r s 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (71.7) 249-3166 ~~~ ~~~ ~- ~~~ ~o-~ ~ ~~ ~ ~ 2~'~'~ ~~~ ~~~~ ~ ~~~~ ~~,~ ,~~_i~ _ - KIMBERLY M. HOFFMAN, formerly KIMBERLY M. MYERS, Plaintiff v. STEPHEN C. MYERS, Defendant v. DR. GORDON MYERS and LOUISE MYERS, Additional Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2080 CIVIL 1986 CIVIL ACTION -LAW IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Petition, parties and their respective counsel appear before Custody Conference Officer, on the day of at fora 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, at the request of either attorney or party, be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, Date of Order: By: Conference Officer 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. The Dauphin County Lawyer Referral Service 213 North Front Street Harrisburg, PA 17101 Telephone No. (717) 232-7536 it is hereby directed that the KIMBERLY M. HOFFMAN, formerly KIMBERLY M. MYERS, Plaintiff v. STEPHEN C. MYERS, Defendant v. DR. GORDON MYERS and LOUISE MYERS, Additional Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2080 CIVIL 1986 CIVIL ACTION -LAW IN CUSTODY PETITION TO MODIFY CUSTODY AND NOW, comes Additional Defendants, Dr. Gordon Myers and Louise Myers, by and through their attorneys, TUCKER ARENSBERG & SWARTZ and hereby avers the following in support of their petition: 1. Plaintiff, Kimberly M. Hoffman, formerly Kimberly M. Myers, is the natural mother of Stephanie N. Myers, born November 8, 1985. 2. Defendant, Stephen C. Myers, is the natural father of Stephanie Myers. 3. Additional Defendants, Dr. Gordon Myers and Louise Myers, are the natural paternal grandparents of Stephanie Myers. 4. Since Stephanie was approximately age three (3), Dr. and Myers have been her primary caregivers and have provided her sole means of financial support. A Court Order was entered on June 6, 1989, granting temporary custody of Stephanie to Dr. and Mrs. Myers and visitation to Stephen Myers and Ms. Hoffman pending a hearing before the Court. A hearing was scheduled to be held on August 29, 1989 and upon Ms. Hoffman's failure to appear, the matter was continued generally and all provisions of the Order dated June 6, 1989 were to remain in effect, granting Dr. and Mrs. Myers custody. 5. Stephanie continued to reside with Dr. and Mrs. Myers and began attending the Cumberland Valley School District when she reached school age. 6. In November of 1999, Stephanie attempted to relocate her residence with Ms. Hoffman and began attending the Mechanicsburg School District. Prior to her change in residences, Stephanie had always attended the Cumberland Valley School District. 7. On March 23, 2000, the parties reached an agreement, whereby legal custody of Stephanie would be shared between Ms. Hoffman and Dr. and Mrs. Myers. Physical custody would be with Dr. and Mrs. Myers every weekend and Ms. Hoffman would have physical custody the remainder of the time. The parties were to also share the holidays, vacation time, the child's birthday and any other additional periods of time as mutually agreed upon. 8. This agreement was made into a Court Order, but was only followed sporadically, with a majority of Stephanie's time being spent with Dr. and Mrs. Myers and not Ms. Hoffman. 9. On May 5, 2000, at the suggestion and insistence of Ms. Hoffman Stephanie returned to live with Dr. and Mrs. Myers and has remained in their primary custody, care and control throughout the present time. 10. Stephanie continued her enrollment in the Mechanicsburg School District for the remainder of the second semester of 1999-2000 school year and Dr. and Mrs. Myers provided her with daily transportation because they lived in the Cumberland Valley School District. 11. Counsel for Dr. and Mrs. Myers at that time was Robert Saidis, Esquire. On May 8, 2000, he sent a letter to counsel for Ms. Hoffman, John Lyons, Esquire requesting that the custody order be modified to confirm the custody arrangement that was actually being followed. (A copy of the letter is attached hereto). 12. Dr. and Mrs. Myers are reaffirming their request that the custody arrangement that is being followed be confirmed and that they be given primary custody of Stephanie for the following reasons: a. They have been her primary caregiver since she was a young child; b. They have been her sole means of financial support since she was a young child; c. They are better able to provide a stable physical environment; d. They are better able to provide a healthy emotional environment; e. They are actively involved in the daily activities of Stephanie and have been throughout her upbringing; f. They have formed a strong bond and close relationship with Stephanie; g. Any disruption in the status quo would be detrimental to Stephanie's well being; h. Stephanie and Ms. Hoffman do not have a close healthy relationship; and i. Stephanie desires to remain in the custody of Dr. and Mrs. Myers. WHEREFORE, the Additional Defendants respectfully request that this Honorable Court grant the requested relief and award primary custody of Stephanie Myers to them. 36403 Respectfully submitted TUCKER ARENSBERG & SWARTZ By: ~ 'ln---` Susan M. Seigh an I.D. No. 70323 111 North Front Street Harrisburg, PA 17108 ATTORNEYS FOR ADDITIONAL DEFENDANTS JOHN E. SLIKE ROBERT C. SAIDIS. GEOFFREY S. SHUFF ALBERT H. MASLAND ]OHNNA J. DEILY RICHARD P. IvIISLITSKY fi KARL M. LEDEBOHM JOSEPH L. HITCHINGS LAW OFFICES SAIDIS, SHUFF &MASLAND APROP6SSIONAL CORPORATION 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013-2956 TELEPHONE: (717) 243-6222 • FACSIMILE: (717) 243-6486 EMAIL: law ~ ssmattys. com May 8, 2000 John Lyons, Esq. 112 Walnut Street Harrisburg, PA 17101 Dear John: WEST SHORE OFFICE: 2109 MARKET STREET CAMP HILL. PA 179 [ I TELEPHONE: (717) 737-3405 FACSDrIII.E: (717) 737-3407 REPLY TO CARLISLE On Friday, May 5, 2000, Dr. Myers called me and advised that Stephanie was returning to live with Dr. and Mrs. Myers. Apparently, the custody arrangement with your client did not work out satisfactory and with mother's agreement, Stephanie is returning to Dr. Myers residence. Could you kindly consult with your client to insure that this is correct? If so, we should examine the possibility of amending 'the Court Order. Thank you for your continuing cooperation. Very truly yours, IS~ SHUFF & MASLAND C R~ert ~ Saidis RCS/pm Cc: Dr. Gordon Myers `CERTIFIED AS A CIVIL TRIAL ADVOCATE BY THE NATIONAL BOARD OF TRIAL ADVOCACY A PENNSYLVANIA SUPREME COURT ACCREDITED AGENCY VERIFICATION I, Dr. Gordon Myers, Additional Defendant, acknowledge that the facts stated in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. ~~ Dr. Gordon Myers VERIFICATION I, Louise Myers, Additional Defendant, acknowledge that the facts stated in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. `_~.a . Louise Myers CERTIFICATE OF SERVICE AND NOW, this b day of ~.~tl U,t,~ , 2001, I, Shaun M. Kovach, secretary to Susan M. Seighman, Esquire, for the firm of Tucker Arensberg & Swartz, hereby certify that I have this day served a copy of the within document, by mailing same by first class mail, postage prepaid, addressed as follows: John Lyons, Esquire 112 Walnut Street Harrisburg, PA 17101 rn Shaun M. Kovach c-n .- r--- ~., _ ~ ;; ~- r;-, ; `.'_ i ~l! fr -',) Y ~ .. _ J