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HomeMy WebLinkAbout08-3092Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 RICHARD E. LALLY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -CUSTODY DANIEL J. SMITH and ELIZABETH L. NO. J 8. 369,Z, Lt?d- 7i,,.. SHUNK, ; Defendants CUSTODY COMPLAINT 1. The Plaintiff is Richard E. Lally (hereinafter referred to as "Maternal Grandfather"), who currently resides at 11020 West Amity Road, Boise, Idaho 83709. Plaintiff is the Maternal Grandfather of the children at issue in this litigation. 2. The Defendant is Daniel J. Smith (hereinafter referred to as "Father"), who's last know address was 307 E. Main Street, Mechanicsburg, Cumberland County, Pennsylvania. It is believed that he may currently be residing at 1513 Market Street, Camp Hill, Cumberland County, Pennsylvania 17025. 3. The Defendant is Elizabeth L. Shunk (hereinafter referred to as "Mother"), who currently resides at 19 Dartmouth Court, Mechanicsburg, Cumberland County, Pennsylvania. 4. Plaintiff seeks to establish a formal order for partial physical custody of the following children: NAME PRESENT RESIDENCE DATE OF BIRTH Asher Smith 1513 Market Street December 24, 1998 Camp Hill, PA Lydia Smith 1513 Market Street April 1, 2003 Camp Hill, PA 5. The children are presently in the custody of Father whose last know address was 307 E. Main Street, Mechanicsburg, Cumberland County, Pennsylvania. It is believed that he may currently be residing at 1513 Market Street, Camp Hill, Cumberland County, Pennsylvania. 6. During the past five years the children have resided with the following persons at the following addresses: DATES 9/1/02-10/15/05 10/16/05-11/26/05 10/16/05-11/26/05 11/27/05-4/20/06 4/21/06 -6/8/06 6/9/06-8/06 ADDRESSES 307 E. Main Street Mechanicsburg, PA 309 E. Main Street Mechanicsburg, PA 307 E. Main Street Mechanicsburg, PA 307 E. Main Street Mechanicsburg, PA 1660 E. Caracas Avenue Hershey, PA 1660 E. Caracas Avenue Hershey, PA NAMMS OFPERSONS IN HOUSEHOLD Mother, Father and children Mother, children and Dennis and Leona Englin (shared physical custody) Father and children (shared physical custody) Father and children Mother, Gary Shunk, Margo Lally and children Mother, Gary Shunk, Margo Lally and children (shared physical custody) 2 6/9/06-8/06 307 E. Main Street Father and children Mechanicsburg, PA (shared physical may) 8/06-12/15/06 1660 E. Caracas Avenue Mother, Gary Shunk Hershey, PA Margo Lally and children (primaryphysical custody of Asher and shared physical custody of Lydia) 8/06-12/15/06 307 E. Main Street Father and children Mechanicsburg, PA (shared physical custody of Lydia) 12/15/06-4/20/07 19 Dartmouth Court Mother, Gary Shunk and Mechanicsburg, PA children (shared physical custody) 12/15/06-4/20/07 307 E. Main Street Father and children Mechanicsburg, PA (shared physical custody) 4/21/07-5/07 307 E. Main Street Father and children Mechanicsburg, PA 5/07- unknown 307 E. Main Street Father, Christa Gray and Mechanicsburg, PA children unknown-present 1513 Market Street Father, Chnsta Gray and Camp Hill, PA and children 7. The Father of the children is Daniel J. Smith, whose last known address was 307 E. Main Street, Mechanicsburg, Cumberland County, Pennsylvania. However, it is believed that he and the children are presently residing at 1513 Market Street, Camp Hill, Cumberland County, Pennsylvania 17025. 3 8. The Mother of the children is and Elizabeth L. Shunk, currently residing at 19 Dartmouth Court, Mechanicsburg, Cumberland County, Pennsylvania. 9. The relationship of the Plaintiff to that of the children is that of maternal grandfather. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP Dr. Richard E. Lally Self Kathleen Lally Wife 10. Father currently resides with the following persons: NAME RELATIONSHIP Daniel J. Smith Self Christa Gray Girlfriend Asher Smith Son Lydia Smith Daughter 11. Mother currently resides with the following persons: NAME RELATIONSHIP Elizabeth L. Shunk Mother Gary Shunk Mother's Husband 4 12. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 13. Plaintiff has information of various custody proceedings concerning the children pending in the Court of Common Pleas of Cumberland County, being: Elizabeth L. Smith (n.k.a. Elizabeth L. Shunk) v. Daniel J Smith Docket No. 06-2411; Daniel Smith v. Elizabeth Smith, Docket No. 06-2422; and Margo E. Lally v. Elizabeth L. Shunk and Daniel J Smith Docket No. 08- 1718. These actions have all been consolidated to Docket No. 06-2422. Plaintiff desires this action to also be consolidated to Docket No. 06-2422. 14. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 15. The best interest and permanent welfare of the children will be served by granting the relief requested because Maternal Grandfather has always had a good, loving and stable relationship with the children. His daughter does not have custody of the children and voluntary contact has been restricted and precluded by the Father. Maternal Grandfather seeks mail contact, phone contact and physical visitation with the children. 16. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. 5 WHEREFORE, Maternal Grandfather requests the Court to grant partial physical custody of the children to him in accordance with Sections 5312-5313 of the Domestic Relations Code and consolidate this matter with the ongoing custody proceeding at Cumberland County Docket No. 2006-2411. DATE: May 13, 2008 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Plaintiff 6 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 RICHARD E. LALLY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -CUSTODY DANIEL J. SMITH and ELIZABETH L., NO. SMITH : Defendants VERIFICATION I, Richard E. Lally, hereby certify that the facts set forth in the foregoing CUSTODY COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: C) D l rs cn 3a tL1 O ni,. --cm, _r; z ern ?17 --C 0 RICHARD E. LALLY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-3092 CIVIL ACTION LAW DANIEL J. SMITH AND ELIZABETH L. SMITH IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, June 11, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, June 26, 2008 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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/ acqueEne M. Verney, Esc 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 ! S :Z Wd C I Nnr Gooz RICHARD E. LALLY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-3092 CIVIL ACTION LAW DANIEL J. SMITH AND ELIZABETH L. SMITH IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, June 20, 2008 , 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 Wednesday, July 16, 2008 at 11:30 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. 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. Sunda Es q. 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 cI -IIIOZ F'lrBUZ Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 RICHARD E. LALLY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -CUSTODY DANIEL J. SMITH and ELIZABETH L., NO. 08-3092 SMITH Defendants ACCEPTANCE OF SERVICE I, Lindsay Gingrich Maclay, Esquire, hereby accept service and acknowledge receipt of the above-captioned CUSTODY COMPLAINT AND CONCILIATION ORDER on behalf of my client, Margo E. Lally, having received same on the day of 2008. I hereby indicate I am authorized by my client to accept service on her behalf. 4_?,Aj A'AALA Li?ki!ay Gin 'C?i *clay, Esquire aley Zuc Meilton Miner & Gingrich, LLC 1029 Scenery Drive Harrisburg, PA 17109 r4 t ?J =i w` (ji Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 RICHARD E. LALLY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -CUSTODY DANIEL J. SMITH and ELIZABETH L., NO. 08-3092 SMITH Defendants ACCEPTANCE OF SERVICE I, Mary A. Dissinger, Esquire, hereby accept service and acknowledge receipt of the above- captioned CUSTODY COMPLAINT AND CONCILIATION ORDER on behalf of my client, Elizabeth L. Smith, having received same on theme "/day of 2008. I hereby indicate I am authorized by my client to accept service on her behalf. Mary A. Dissinger, Esquire Dissinger and Dissinger 400 South State Road Marysville, PA 17053 C") ?" ?,, ,,_ ? t.-. ? -r^ ?-tin ,-' ?` ?.. Y -L^; Ira ? 9 ? .? u ..?q .Z''? F? ? n.+r^ . ?' a,? Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 RICHARD E. LALLY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - CUSTODY DANIEL J. SMITH and ELIZABETH L., NO. 08-3092 SMITH Defendants ACCEPTANCE OF SERVICE ptio ed I, Mark F. Bayley, Esquire, hereby accept service and acknowledge receipt ofthe above-ca CUST Y MPLAINT on behalf of my client, Darnel J. Smith, having received same on theme day of vO k 2008. I hereby indicate I am authorized by my client to accept service on his behalf. Mark F. Bayley, Esquire Bayley & Mangan Law 57 W. Pomfret Street Carlisle, PA 17013 C q rQ a1 RICHARD E. LALLY IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : 2008-3092 CIVIL ACTION LAW DANIEL J. SMITH AND ELIZABETH L. : SMITH IN CUSTODY Defendant MOTION TO DISMISS COMPLAINT FOR PLAINTIFF'S LACK OF STANDING AND NOW, comes Daniel J. Smith, by and through his attorney, Mark F. Bayley, Esquire, and in support of the within motion avers as follows: 1. No Judge has been assigned to the above caption matter to date; however, the Honorable M. L. Ebert, Jr. is assigned to related matters. 2. Richard E. Lally, Plaintiff, filed a custody complaint with regard to his grandchildren on May 15, 2008. 3. Mr. Lally lacks standing in accordance with 23 Pa.C.S. §5313 (when grandparents may petition). 4. Plaintiff and Defendant, Elizabeth Smith, presumably object to the within motion. WHEREFORE, Defendant, Daniel J. Smith, respectfully requests the Court to dismiss Mr. Lally's complaint for lack of standing. Respectfully submitted, BAYLEY & Date: Mark F. Bayley, Esq e 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 Attorney for Daniel J. Smith RICHARD E. LALLY Plaintiff V. DANIEL J. SMITH AND ELIZABETH L. SMITH Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-3092 CIVIL ACTION LAW IN CUSTODY VERIFICATION Mark F. Bayley, Esquire, states that he is the attorney for Daniel J. Smith in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. (?-- I Date: -?- 0 ?' L"'? Mark F. Bayley, Esquire Attorney for Daniel J. Smith a. . y RICHARD E. LALLY Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-3092 CIVIL ACTION LAW DANIEL J. SMITH AND ELIZABETH L. SMITH : IN CUSTODY Defendant CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Daniel J. Smith do hereby certify that I this day served a copy of the foregoing document upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 Mary A. Dissinger 28 North Thirty-Second Street Camp Hill, PA 17011 Mark F. Bayley, Es ire Attorney for Daniel J. Smith Dated: AUG 0 4 goo RICHARD E. LALLY : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-3092 CIVIL ACTION LAW DANIEL J. SMITH AND ELIZABETH L. SMITH IN CUSTODY Defendant RULE TO SHOW CAUSE ?h AND NOW, this Jr day of y ?y 3 , 2008 a Rule is hereby issued upon Plaintiff to show cause why the Defendant's Motion to Dismiss Complaint for Lack of Standing should not be granted. Said Rule is returnable within 10 days. 7ark bution: F. Bayley, Esquire ,,Barbara Sumple-Sullivan, Esquire ,,a A. Dissinger, Esquire ?7. MW? :r . l "Ino '01 ,11,31 c-- ` I,V 8 a 0 Z w PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: (List the within matter for the next Argument Court.) CAPTION OF CASE (entire caption must be stated in full) RICHARD E. LALLY V5. DANIEL J. SMITH and ELIZABETH L. SMITH No 2008-3092 Term 1. State matter to be argued (i.e., plaintiffs motion for new trial, defendant's demurrer to complaint, etc.): Defendant, Daniel J. Smith's, motion to Dismiss Complaint for Plaintiff's LacK or stancung 2. Identify all counsel who will argue cases: (a) for plaintiffs: Barbara Sumple-Sullivan, Esquire, 549 Bridge St., New Cumberland, PA 17070 (Name and Address) (b) for defendants: Mark F. Bayley, Esquire, 57 W. Pomfret Street, Carlisle, PA 17013 (Name and Address) Counsel for Mary A. Dissinger, Esquire, 400 South State Road, Marysville, PA 17053 Additional party of interest: Lindsay Gingrich Maclay,Esquire 1029 Scenery Dr., Harrisburg, PA 3. 1 will notify all parties in writing within two days that this case has been listed for 17109 argument. Yes 4. Argument Court Date: September 3, 2008 Date: ???/ ` Barbara Sumple-Sullivan, Esquire Print your name Plaintiff Attorney for INSTRUCTIONS: 1. Two copies of all briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) before argument. 2. The moving party shall file and serve their brief 12 days prior to argument. 3. The responding party shall file their brief 5 days prior to argument. 4. If argument is continued new briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) after the case is relisted. 1% Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 RICHARD E. LALLY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -CUSTODY DANIEL J. SMITH and ELIZABETH L., NO. 08-3092 SHUNK Defendants CERTIFICATE OF SERVICE I, BARBARA SUMPLE-SULLIVAN, ESQUIRE, do hereby certify that on this date, I served a true and correct copy of the Praecipe for Listing Case for Argument, in the above- captioned matter upon the following individual(s), by United States first-class mail, postage prepaid, addressed as follows: Mark F. Bayley, Esquire Bayley & Mangan Law Office 57 W. Pomfret Street Carlisle, PA 17013 Lindsay Gingrich Maclay, Esquire Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive Harrisburg, PA 17109 DATE: Q Mary A. Dissinger, Esquire Dissinger and Dissinger 400 South State Road Marysville, PA 17053 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Plaintiff W CAD V Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 RICHARD E. LALLY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -CUSTODY DANIEL J. SMITH and ELIZABETH L., NO. 08-3092 SHUNK Defendants NOTICE TO PLEAD TO: Mark F. Bayley, Esquire Bayley & Mangan Law Office 57 W. Pomfret Street Carlisle, PA 17013 Lindsay Gingrich Maclay, Esquire Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive Harrisburg, PA 17109 Mary A. Dissinger, Esquire Dissinger and Dissinger 400 South State Road Marysville, PA 17053 You are hereby notified to file a written response in reply to the enclosed Plaintiff's New Matter to Defendant Smith's Motion to Dismiss Complaint within twenty (20) days from service hereof or a judgment may be entered against you. Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Plaintiff 4 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 RICHARD E. LALLY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - CUSTODY DANIEL J. SMITH and ELIZABETH L., NO. 08-3092 SHUNK Defendants PLAINTIFF'S ANSWER AND NEW MATTER TO MOTION TO DISMISS COMPLAINT FOR PLAINTIFF'S LACK OF STANDING AND NOW, comes Richard E. Lally, by and through his attorney, Barbara Sumple-Sullivan, Esquire, and in support of this answer, avers as follows: 1. Admitted. 2. Admitted. 3. Denied. It is denied that Plaintiff lacks standing. Paragraph 3 is denied as a conclusion of law to which no response is due. It is also averred that Plaintiff has standing in accordance with 23 Pa. C.S.A. §5312. It is further averred, visitation and contact between Plaintiff and the children would be in the best interest of the children and would not interfere with the parent/child relationship. 4. Admitted in part. Denied in part. It is admitted that Plaintiff objects to the motion of Defendant, Daniel J. Smith. To the best of Plaintiff's knowledge, Defendant, Elizabeth L. Shunk, does not concur in the filing of the motion of Defendant, Daniel J. Smith. However, Plaintiff is without the knowledge sufficient to form a belief as to the truth of the averment. In any event, Defendant, Daniel J. Smith, did not seek concurrence prior to filing. NEW MATTER 5. Paragraphs 1 through 4 of Plaintiff's Answer and New Matter to Motion to Dismiss Complaint for Plaintiff's Lack of Standing are incorporated herein by reference. 6. Plaintiff is the maternal grandfather of the minor children, Asher Kaylor Smith and Lydia Keran Lally Smith. 7. Defendant, Daniel J. Smith, and Defendant Elizabeth L. Shunk, are the natural parents of said children. 8. Defendant, Daniel J. Smith, and Defendant, Elizabeth L. Shunk, were separated in October, 2005 and were subsequently divorced. The Defendants have been living separate and apart since that time. 2 9. Since the children's births, Plaintiff has maintained contact with the children through telephone calls, personal visits, cards and letters. 10. Defendant, Daniel J. Smith, has terminated any and all contact with Plaintiff since April, 2007. 11. Defendant, Elizabeth L. Shunk, has no physical custody rights with the children. 12. Defendant, Daniel J. Smith's, filing of Preliminary Objections are untimely. WHEREFORE, Plaintiff respectfully requests this Honorable Court deny Defendant, Daniel J. Smith's, Motion to Dismiss Complaint for Plaintiff's Lack of Standing. DATE: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Plaintiff 3 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 RICHARD E. LALLY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -CUSTODY DANIEL J. SMITH and ELIZABETH L., NO. 08-3092 SHUNK Defendants CERTIFICATE OF SERVICE I, BARBARA SUMPLE-SULLIVAN, ESQUIRE, do hereby certify that on this date, I served a true and correct copy of Plaintiff's Answer to Motion to Dismiss Complaint For Plaintiff's Lack of Standing, in the above-captioned matter upon the following individual(s), by United States first-class mail, postage prepaid, addressed as follows: Mark F. Bayley, Esquire Mary A. Dissinger, Esquire Bayley & Mangan Law Office Dissinger and Dissinger 57 W. Pomfret Street 400 South State Road Carlisle, PA 17013 Marysville, PA 17053 Lindsay Gingrich Maclay, Esquire Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive Harrisburg, P 17,109 DAT Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Plaintiff 4 . ?° '?? ?t ?? ? ?? .-.; ?? w r-P I'll Richard E. Lally, Plaintiff VS. Daniel J. Smith Elizabeth L. Smith (n.k.a. Elizabeth L. Shunk) Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY NO. 2008-3092 ANSWER TO RULE TO SHOW CAUSE DATED AUGUST 5 2008 REGARDING DEFENDANT'S MOTION TO DISMISS COMPLAINT FOR LACK OF STANDING FILED BY DR. RICHARD E. LALLY And now comes Elizabeth L. Shunk by and through her attorneys Dissinger & Dissinger and avers as follows. ADMITTED. 2. ADMITTED. 3. DENIED. It is denied that Dr. Richard E. Lally lacks standing in accordance with 23 Pa.C.S. Section 5313. By way of further answer it is averred that Dr. Lally also has standing under PA.C.S. Section 5312. ?. ADMITTED. Respectfully Submitted: Mary A. Etter Dissinge Supreme Court ID 27736 28 N. 32nd Street Camp Hill, PA 17011 (717)975-2840 Richard E. Lally, Plaintiff VS. Daniel J. Smith , Elizabeth L. Smith (n.k.a. Elizabeth L. Shunk) Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY NO. 2008-3092 CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document on Mark Bayley, Esq., Barbara Sumple-Sullivan, Esq., and Lindsay Maclay, Esq., by First Class United States mail addressed as follows: Mark F. Bayley, Esq. 17 W. South Street Carlisle, PA 17013 AND Barbara Sumple-Sullivan, Esq. 549 Bridge Street New Cumberland, PA 17070 AND Lindsay Maclay, Esq. 1029 Scenery Drive Harrisburg, PA 17109 te: c/ Mary A Etter Dissinger CO RICHARD E. LALLY, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. DANIEL J. SMITH AND ELIZABETH L. SMITH SHUNK NO. 08-3092 CIVIL ORDER OF COURT AND NOW, this 12th day of August, 2008, upon consideration of the Defendant, Daniel J. Smith's Motion to Dismiss Complaint for Lack of Standing, and the Plaintiff's Answer in New Matter, IT IS HERBY ORDERED AND DIRECTED that: A. A hearing/argument solely on the grandparents standing shall be held on Wednesday, September 10, 2008, at 9:30 a.m. in Courtroom No. 5 of the Cumberland County Courthouse, Carlisle, Pennsylvania. B. The Parties shall file concise memorandums of law on this issue on or before September 3, 2008. C. The case shall be removed from the argument court list for September 3, 2008. By the Court, -?, UA ,y\ M. L. Ebert, Jr., J. arbara Sumple Sullivan, Esquire Attorney for Plaintiff Xark F. Bayley, Esquire Attorney for Daniel J. Smith ...,M/ary A. Dissinger, Esquire Court Administrator , bA S Slo-1 of bas ? ? :? Nd Z f ony goof A8ViGNCX-I; Wd 3Hi 3a 301:YO-C 314 RICHARD E. LALLY IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : 2008-3092 CIVIL ACTION LAW DANIEL J. SMITH AND ELIZABETH L. : SMITH Defendant : IN CUSTODY MOTION TO WITHDRAW / DISMISS DEFENDANT'S MOTION TO DISMISS COMPLAINT FOR PLAINTIFF'S LACK OF STANDING AND NOW, comes Daniel J. Smith, by and through his attorney, Mark F. Bayley, Esquire, and in support of the within motion avers as follows: 1. The Honorable M. L. Ebert, Jr. is assigned to the above captioned matter. 2. Defendant, Daniel J. Smith, filed his Motion to Dismiss Complaint for Plaintiffs Lack of Standing on or around August 1, 2008; a hearing with regard to the motion was subsequently scheduled for September 10, 2008. 3. Mr. Smith now wishes to withdraw said motion. WHEREFORE, Mr. Smith respectfully requests the Court to dismiss his Motion to Dismiss Complaint for Plaintiffs Lack of Standing filed on or around August 1, 2008. Date: -< Respectfully submitted, BAYLEY & MAN Mark F. Bayley, Esquire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 Attorney for Daniel J. Smith RICHARD E. LALLY IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-3092 CIVIL ACTION LAW DANIEL J. SMITH AND ELIZABETH L. : SMITH IN CUSTODY Defendant VERIFICATION Mark F. Bayley, Esquire, states that he is the attorney for Daniel J. Smith in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: t t C) S---- Mark F. Bayley, Esquire Attorney for Daniel J. Smith RICHARD E. LALLY Plaintiff V. DANIEL J. SMITH AND ELIZABETH L. SMITH Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-3092 CIVIL ACTION LAW IN CUSTODY CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Daniel J. Smith do hereby certify that I this day served a copy of the foregoing document upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 Mary A. Dissinger, Esquire 28 North Thirty-Second Street Camp Hill, PA 17011 Dated. Lindsay Gingrich Maclay, Esquire 1029 Scenery Drive Harrisburg, PA 17109 Mark F. Bayley, Esquire Attorney for Daniel J. Smith -Tl 77 N - U? .y AUG 2 5 2008 %%j? RICHARD E. LALLY IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-3092 CIVIL ACTION LAW DANIEL J. SMITH AND ELIZABETH L. SMITH IN CUSTODY Defendant ORDER AND NOW, this day of S 2008, upon Defendant's request to withdraw his Motion to Dismiss Complaint for Lack of Standing, said motion is hereby DISMISSED. The hearing previously scheduled for September 10, 2008 is cancelled. Distribution: ,245'rk F. Bayley, Esquire Barbara Sumple-Sullivan, Esquire ;Zmd .4!ary A. Dissinger, Esquire s ay Gingrich Maclay, Esquire J I I 'S WV C- d3S 80OZ t ELIZABETH L. SMITH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. :2006-2411 CIVIL ACTION LAW DANIEL J. SMITH, : IN CUSTODY Defendant MARGO E. LALLY, Plaintiff VS. ELIZABETH L. SHUNK, and DANIEL J. SMITH Defendants RICHARD E. LALLY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. :2008-3092 CIVIL ACTION LAW DANIEL J. SMITH, and : IN CUSTODY ELIZABETH L. SMITH Defendants MOTION BY DANIEL SMITH TO ALTER RECOMMENDED ORDER PENDING A HEARING AND NOW, comes Daniel Smith (hereafter "Father"), by and through his attorney, Mark F. Bayley, and in support of the within motion avers as follows: 1. The Honorable M. L. Ebert, Jr. is assigned to the above dockets. 2. Elizabeth Smith (n.k.a. Elizabeth Shunk) (hereafter "Mother") and her husband, Gary Shunk, are currently indicated by Cumberland County Children and Youth Services for sexual abuse relating to one of the children involved, Lydia Smith (D.O.B. April 1, 2003); the other child involved is Asher Smith (D.O.B. December 24, 1998). 3. By Order dated February 26, 2008 under juvenile docket 128-2007, the Honorable M. L. Ebert, Jr., adopted a recommendation stating that, with regard to Mother, "there not be visitation at this time. Before visitation would be granted either in this juvenile case or in a custody case, it would appear appropriate to receive guidance from the investigating police officer and counselor for the children." 4. Mother and Margo Lally (hereafter "Maternal Grandmother") subsequently filed custody complaints. 5. A conciliation was held on March 25, 2008 which resulted in a stipulated Order; with regard to Mother, said Order ratified the February 26, 2008 Juvenile Order; regarding Maternal Grandmother, paragraph 4 states: The parties shall make arrangements for the Children to participate in counseling ... for the purpose of assessing the Children's readiness and well-being in reestablishing contact between the Children and the maternal Grandmother. In the event the counselor determines that the Children are ready, the reunification process shall take place initially within the counseling process or as otherwise recommended by the counselor. The parties shall follow the recommendations of the counselor with regard to participation in counseling, either individually or with the Children by the maternal Grandmother or the Father. The parties shall follow the recommendations of the counselor with regard to the timing of reunification .... 6. Dr. Kasey Shienvold has since been involved with counseling the children for the above purposes (previous to Dr. Shienvold's involvement and up and through the present the children have been seeing another therapist, Michael Zug). 7. Richard Lally (hereafter "Maternal Grandfather"), who resides in Idaho, filed a custody complaint on May 15, 2008 and, to undersigned counsel's knowledge, has not been involved in relation to Dr. Shienvold's counseling sessions. 8. Dr. Shienvold provided a letter dated September 17, 2008 to counsel which summarized his reunification efforts to date. (Attached as "Exhibit A"). 9. Said letter states the current position of the children, i.e., "Asher and Lydia continue to express an unwillingness to see [Maternal Grandmother]. They both independently have described incidences of inappropriate behavior and discipline by [Maternal Grandmother].... As a result, they each stated that they are afraid of their ... [Maternal Grandmother]." 10. To date, no qualified professional has recommended the children, at least one being a victim of sexual abuse, to be forced to have contact with Maternal Grandmother against their will. 11. A conciliation took place on September 18, 2008, wherein agreement could not be reached and a hearing was requested. 12. The conciliator indicated that her recommendation would include accelerating Dr. Shienvold's counseling by forcing the children to have contact with Maternal Grandmother in following counseling sessions regardless of their readiness to do so. 13. The conciliator indicated that her recommendation would include allowing Maternal Grandfather to have immediate telephone and other miscellaneous contact even though Maternal Grandfather has not participated or been addressed in the reunification counseling. 14. Both grandparents rely on 23 Pa.C.S. 5312 which allows grandparents partial custody and/or visitation rights where "[the Court] finds that visitation rights or partial custody, or both, would be in the best interest of the child and would not interfere with the parent-child relationship." 15. The Court will not have an opportunity to make the above inquiry until after a hearing is held. 16. Based upon the history of this matter, the abuse the children have suffered, and the unwillingness of both children to have contact with Mother and her family at this time, contact between grandparents and the children should not occur until grandparents have met their burden pursuant to Section 5312. 17. Mother and Maternal Grandparents are presumably opposed to the within motion. WHEREFORE, Father respectfully requests the Court to amend the recommended Order to prevent any forced contact with grandparents until further Order of Court. 9 - ? ?-c? Respectfully submitted, BA EY & GAN Mark F. Bayley, Es ire 17 West South Str et Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D.#87663 VERIFICATION Mark F. Bayley, Esquire, states that he is the attorney for Daniel J. Smith in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: U\-4 Mark F. Bayle , Esquire Attorney for Daniel J. Smith Sep 1( Ud U4:35p Riegler . Shier old Associates September 17, 2008 Attorney Lindsay Gingrich Maclay Fax: 657-4996 Attorney Mary Dissinger Fax: 975-3924 Attorney Mark Bailey Fax: 241-2456 Attorney Barbara Sumple-Sullivan Fax: 774-7059 Re: Lally v. Shunk v. Smith v. Lally Dear Attorneys, 717-540-1416 p.2 Elliot Riegler, Ph.D. (1948-1999) Arnold 1. Shienvold, Ph.D. Melinda ['.ash, MS James Eash, LSW Bonnic Howard, Ph.D. Amy K. Keisling. ACSW. LCSW Tracy Richards, QCSW. LCSW Dyanne Sage, QCSW, LCSW Jeffrey Pincus, Ph. D. Ann 4ergales.ACSW, LCSW Kasey Shienvold, Psy.D. Shanen Turk-Geller, LCSW John Sivley, LCSW, CAC: Janes Frankel Staub, LCSW, QCSW I am writing this letter in reference to my reunification work with these parties. I have on one occasion met with Ms. Lally, Ms. Shunk and Mr. Smith. I have met on two separate occasions with Asher and Lydia. At the current time, Asher and Lydia continue to express an unwillingness to see Ms. Lally. They both independently have described incidences of inappropriate behavior and discipline by Ms. Lally and their mother, Ms. Shunk. As a result, they each stated that they are afraid of their mother and maternal grandmother. However, there is some evidence which indicates that these children may be hearing disparaging remarks about their mother and grandmother from Mr. Smith and his wife. As such, it is unclear the validity and credibility of the children's recollections. It is my belief that if reunification is to occur, we can no longer wait for the children to express a readiness to begin the process. In order for this process to be effective Mr. Smith and his wife have to play a key role in encouraging the children's reebWouships with Ms. Lally. If this does not occur, I fear that any attempts to reunify are futile. If any questions, please feel free to contact me. Sincerely, Kasey Shienvold, Psy. D. 2151 Linglestown Road, Suite 200 . Harrisburg, Pennsylvania 17110 • (717) 540-1313 • Fax: (717) 540-1416 www.rie;giersliienvold.com CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Daniel J. Smith, do hereby certify that I served a copy of the foregoing document upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 t 4, 7-7H-766 9 Mary A.Dissinger 28 North Thirty-Second Street Camp Hill, PA 17011 Lindsay Gingrich Maclay (x r ?? r 1029 Scenery Drive c- Harrisburg, PA 17109 Dated: vl'?Zj - Mark F. Bayley, Es ire 9__ I i Attorney for Daniel J. Smith r-a rn .Jo s ORDER OF COURT AND NOW, this 1St day of October, 2008, upon consideration of the Motion by ELIZABETH L. SMITH, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. DANIEL J. SMITH, DEFENDANT V. MARGO E. LALLY, PLAINTIFF V. ELIZABETH L. SHUNK, AND DANIEL J. SMITH, DEFENDANTS NO. 06-2411 CIVIL RICHARD E. LALLY, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. (consolidated to 06-2411 Civil by Order of Court dated October 1, 2008) DANIEL J. SMITH AND ELIZABETH L. SMITH SHUNK NO. 08-3092 CIVIL Father to Alter Recommended Order pending a Hearing, IT IS HEREBY ORDERED AND DIRECTED that the Motion is DENIED. By the Court, `v` Imo, ?14\ M. L. Ebert, Jr., J. Mark F. Bayley, Esquire Attorney for Father Mary A. Dissinger, Esquire Attorney for Mother io- a l - o Q P - Too re' t??.d X,6v v ,,,y ii r 1f'` 1S Barbara Sumple Sullivan, Esquire Attorney for Maternal Grandfather Lindsay Gingrich Maclay, Esquire Attorney for Maternal Grandmother bas AUTHORITY TO PAY COURT APPOINTED COUNSEL 1. COURT J 2. VOUCHER N_ 13302 ? District ustice Common Pleas ? Appellate ? Other E) 3. FOR (D.J., C.P., APP L` 4. AT ITY/STATE ` 5. BUDGET CODE G M_ _ . Rld S 6_1S kkp 6. IN THE CASE OF V S vs . f n 7. CHARGE/OFFENSE (PURDON CITATION) ` e. ? PETTY OFFENSE ? FELONY ? MISDEMEANOR 9. PROCEEDINGS (Describe briefly) 11. PERSON REPRESENTED 12. CIVIL DOCKET NO. 1 ? Defendant - Adult n V L _ ( 2 O Defendant-Juvenile ntt (? ` ,/ L lj Q .TI?n /1 /] f?l l{Lhw?(/? ' / l/JI U I IY! N? b't? I ?I f{ 3 ? Appellant 4 ? Appellee 13. CRIMINAL DOCKET NO. l/ t/ ` 5 O Habeas Petitioner 6 ? Material Witness 10. PERSON REPRESENTED (Full Name) 7 ? Parolee Charged With Violation 6 ? Probationer Charged With Violation 14. APPEALS DOCKET NO. (? r l ? ? WI Vl V I f l'? T ? 9 ?I Otner. ?rhildr?n Z ?? O (7 16. NAME OF ATTORNEY/PAYEE AND MAILING ADDRESS Appt Date d Lau ofi,ee of Se" M,Shu1h,pe-. M, Lr 1 ,rat Tr, ?- N koM NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE PA )1013 k(1isli , 0166&6 17. TELEPHONE No. 18. SOCIAL. sECURITY NO OR E IN NO Z - CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOURS DATES AMOUNTS CLAIMED a. Arraignment and/or Plea Multiply rate per hour times total hours to obtain "In Court" com- b. Preliminary Hearing pensation. Enter total below. c. Motions and Requests d Bail Hearings Q e. Sentence Hearings U Z 1. Trial g. Revocation Hearings h. Juvenile Hearings i. Appeals Court 19A. TOTAL IN COURT COMP. j. Other (Specify on additional sheets) F TOTAL HOURS = X $55 PER HOUR $ 20. a- Interviews and conferences Multiply rate per hour times total f Court" t tot l "O t h E n er u o ours. a U b. Obtaining and reviewing records compensation below. . F Cf M c. Legal research and brief writing i,_ O d. Investigative and other work (Specify on additional sheets) 20A. TOTAL OUT OF COURT COMP. TOTAL HOURS = O X $45 PER HOUR qq z $ I U` 21. ITEMIZATION OF REIMBURSABLE EX PENSES AMT. PER ITEM ( ?' Mile a $.48 per mile x \ ®®® a w ?/t F 21 A. TOTAL ITEMIZED EXP. O a $ 22. CERTIFICATION OF ATTORNEY/PAYEE / 23. GRAN TAL CLA EO Has compensation and/or reimbursement for work In this case previoushr-been a ll)(led for? 'YES Q'No = $ Z U if yes. were you paid? ''/£S ? NO If yes. bywhom were you paid?. _ _Howmuch7 24. DEDUCT. PRIOR P1fMTS. Has the person represented paid any money to you. or to your knowledge anyone else, In connection with the matter for a $ pointed to provide representation O YES O If yes, give details on additional he its were a hi h o p w y u c I I M D9 N CLAI D NET 1 swear or affirm the truth or correctness A 25: If the above statements Signature of Attomey! syea Date z $ [2EinPPn6VE U Fu Signature of I , Date: 3 O 27. AMT. APPROVED gir //-' ° _ FNil Judge Copy 1 - Mail to Court Administrator at completion of service t- r, -8,Aw OFFIC- OF SEAN M. SHULTZ, r.c. 4 Irvine Row Carlisle, PA 17013 Phone(717)701-8412 Fax(717)701-8416 billing@ShultzLawOffice.com www.ShultzLawOffice.com Invoice submitted to: Asher and Lydia Smith 1513 Market Street Camp Hill, PA 17011 November 09, 2009 In Re: GAL Invoice #10173 Professional Services Hrs/Rate Amount 9/11/2009 Draft Order of Court 2.00 90.00 45.00/hr 9/15/2009 Revise Order of Court 0.50 22.50 45.00/hr 10/7/2009 Receive and review Order 0.10 4.50 45.00/hr Telephone conference with Dan Smith 0.10 4.50 45.00/h r 10/16/2009 Attempt to call Dan Smith 0.10 4.50 45.00/hr 10/26/2009 Receive and review email from Beth Shunk 0.10 4.50 45.00/hr 10/27/2009 Telephone conference with Beth Shunk regarding conflict with school issues 0.50 22.50 45.00/hr 10/30/2009 Telephone conference with Dan Smith 0.50 22.50 45.00/hr 11/3/2009 Receive and review letter from Mark Bayley, Esquire 0.10 4.50 45.00/h r Asher and Lydia Smith Page Hours Amount For professional services rendered 4.00 $180.00 Balance due $180.00 F! LE D--'.: ? 2009 NOY 20 PH 2: 4 8 ? 212010 AUTHORITY TO PAY COURT APPOINTED COUNSEL JM 1. COURT 2. VOUCHER N_ 13303 O District Justice Common Pleas ? Appellate o Other 3. FOR (D.J., C.P., APPELLATE) I /? ?/ 1 4. AT CITY/ T#T`E) I J 5. BUDGET CODE /00 ' 6 /?/0 40 6 N THE CASE OF ,Ll 4 c 1 7. CHARGE/OFFENSE (PUROON CITATION) 8. O PETTY OFFENSE O FELONY O MISDEMEANOR 9. PROCEEDI GS (Describe briefly) 11. PERSON REPRESENTED 12. CIVIL DOCKET NO. ?Q 1 O Defendant -11dult enile f D J d uv anr • en 2 O De ?t O Appellant 13. CRIMINAL DOCKET NO 3 4 J M a O Appellee ? ? 1 L ( l r 3 ? (? 5 O Habeas Petitioner 6 O Material Witness 7 O Parolee Charged With Violation 14. APPEALS DOCKET NO. 10. PERSON REPRESENTED (Full Name) e O Probationer Charged With Violation 6rn 9 e Other l? ? J W ( ??? jlO 16. NAME OF ATTORNEY/PAYEE AND ??Q?d ? V d MAILING ADDRESS ? ??? ?, Appr Dare 1 Law OPkeP EdegA 44' R ow ro'?.Q ." 1?r? 4 NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE 00_rn,&I ,, 04 );0)3 _ 17. TELEPF{QNE No. IQ. SOCIAL ECUAITY NO O NO & q D Z T? , CLAIM FOR S ERVICES OR EXPENSES tg SERVICE HOURS OATES AMOUNTS CLAIMED a. Arraignment and/or Plea Multiply rate per hour times total hours to obtain 'in Court" com- b. Preliminary Hearing pensation. Enter total below. c. Motions and Repuests d. Bail Hearings O e. Sentence Hearings 0 1. Trial Z g. Revocation Hearings h. Juvenile Hearings i Appeals Court 19A. TOTAL IN COURT COMP. i. Other (Specify on additional sheets) 1 TOTAL HOURS >• X $55 PER HOUR 3 20. a interviews and conferences Multiply cute per hour times total Enter total 'Out of Court' hours b. Obtaining and reviewing records . compensation below. O W c Legal research and brief writing 0- M 3 U d. Investigative and other work (Specify on additional sheets) 20A. TTOTA OUT OF COURT COMP, TOTAL HOURS i 4J X $45 PER HOUR $ 211-50 21. ITEMIZATION OF REIMBURSABLE EX PENSES AMT. PER ITEM Millaglit ¢.48 per mile x Q, e l t= ?J ?j,C S 21A. TOTAL ITEMIZED EXP. O =S 22. CERTIFICATION OF ATTORNEY/PAYEE / ti d for! l YES t 0 23. GRAND TOTAL CLAIMED 2 , E ?, e f?, Has compensation and/or r imbursement for work M this cane previous been a : 1 i (1 /lit r if yes, were you paid? Vi"YES O NO If yea, bywhom were you paid? How much or to your knowledge anyone el , in connection with the matter for money to you aid an n r resented h H 24. DEDUCT. PRIOR PYMTS. y , p e perso ep as t S O It yes, give details on addifi nal heets on9 O Y were appointed to provide representat hi h o S w y u c lk E I swear or affirm the truth or correctness __S_1V_ S&=9E5__ 1112110 of the above statements Signstu a of AWSmey/Payee Date 25: NET AMOUNT CUU EO 28.Ar'POuv1. C. ctrl, 1 Spnaturs of 27. AMT. APPIIOV9O = f 2 "AYMENr q Judpe q Copy 1 - Mail to Court Administ +r at completion of service Y -?,Aw 2mql?. OF SEAN M. SHULTZ,r. 4 Irvine Row Carlisle, PA 17013 Phone (717) 701-8412 Fax(717)701-8416 billing@ShultzLawOffice.com www.ShultzLawOffice.com Invoice submitted to: Asher and Lydia Smith 1513 Market Street Camp Hill, PA 17011 January 19, 2010 In Re: GAL Invoice #10381 Professional Services Hre/Rate Amount 12/9/2009 Letter to Dan Smith and Beth Shunk 0.30 13.50 45.00/hr Receive and review email from Beth Shunk 0.10 4.50r 45.00/hr Email to Attorneys Dissinger and Bayley 0.10 4.50- 45.00/hr 12/10/2009 Receive and review email from Beth Shunk 0.20 9.00- 45.00/hr 12/29/2009 Telephone conference with Attorney Bayley's staff 0.10 4.50 45.00/hr Telephone conference with Attorney Bayley's staff 0.10 4.50 45.00/hr 12/30/2009 Email to/from Beth Shunk regarding 1/12/2010 meeting 0.10 4.50,1 45.00/hr 1/11/2010 Receive and review letter from Dan Smith 0.20 9.00-1 45.00/hr 1/1212010 Meeting with Dan Smith and Beth Shunk to resolve ongoing custody issues 3.50 157.5(' 45.00/hr ? t a Asher and Lydia Smith For professional services rendered Previous balance Accounts receivable transactions 12/7/2009 Payment - Thank You No. 747274 Total payments and adjustments Balance due Page 2 Hours Amount 4.70 $211.50 / $180.00 ($180.00) ($180.00) $211.50 ,/ V,?Vq • AUTHORITY TO PAY COURT APPOINTED COUNSEL p? 1.000FT 2. VOUCHER 13304 N0 ? District Justice Common Pleas ? Appellate ? Other - 3. FOR (D.J., C.P., APPELLATE) 4. A (CITY/ i TE?? S Q1 ( / 5. BUDGET CODE' lr 6. IN THE CASE OF 7. CHARGEIOFFENSE (PURDON CITATION) 8. ? PETTY OFFENSE n r? f' 1r vs sk ah ? FELONY ? MISDEMEANOR . U1, , 1 n _ 9. PROCEI= INGS (Describe briefly) 11. PERSON REPRESENTED 12. CIVIL DOCKET NO. 1 ? Defendant - Adult t2 -2 2 ? Defendant -Juvenile 01-30114- ? Appellant 3 4 ? Appellee 13. CRIMINAL DOCKET NO. 5 ? Habeas Petitioner 6 ? Material Witness 10. PERSON REPRESENTED (Full Name) 7 ? Parolee Charged With Violation 8 ? Probationer Charp d With violation 14. APPEALS DOCKET NO. Lv 1 (S ms`+-h ? 9 91 Ctherehi* V.f,n / 16. NAME OF ATTORNEY/PAYEE AND , Er f LM ? U? MAILING ADDRESS . Appl Date ? Law rFf?`eQ D?' Sian ?I.Sh?clt? ??C- ??, ? . ?-?T - ?. Irvine POW NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE PA !IN hr)'sle no , n a 17. L HO to. - L Z 18. 50(st1TlSE 9A7rYNO6'AEINNO Z- CLAIM FOR SERVICES OR EXPENSES =? ?= 19. SERVICE HOURS DATES AMO S CL"Rt D a. Arraignment and/or Plea Miply rate per houFlirtiek total r -t btIM "In o rt" com- ho g P u u o o - b. Pietimine Hearin ry 0 pt :I"htion. Ea Ur total teaw. c. Motions and Requests rn' I-- d. Bail Hearings =O e. Sentence Hearings CD U z I. Trial _ g. Revocation Hearings h. Juvenile Hearings i. Appeals Court 19A. TOTAL IN COURT COMP. I. Other (Specify on additional sheets) TOTAL HOURS = X $55 PER HOUR - $ 20. a. Interviews and conferences Multiply rate per hour times total f " " b. Obtaining and reviewing records hours. Enter total Out o Court compensation below. O ¢ c. Legal research and brief writing O O d. Invesdgative and other work (Specify on additional sheets) 20A. TOTAL OUT OF COURT COMP. TOTAL HOURS = 2 z X $45 PER HOUR (? = $ 0 21. ITEMIZATION OF REIMBURSABLE EXPENSES AMT. PER ITEM Millage $.48 per mile x , o o I? a?j r ? /f d w u? l 1 tll lJ "K ?,, UL 2 ? 21A- TOTAL ITEMIZED EXP. O a $ 22. CERTIFICATION OF ATTORNEY/PAYEE // Has compensation and/70 imbursement for work In this case previous een a piled foR Lr9?YES ? NO MED 23. GRAND TOTAL FAO =$ If yes, were you paid? fd YES ? NO If yes bywhom were you paid? How much?_ 24. DEDUCT. PRIOR PYMTS. Has the person represented paid any money to you, or to your knowledge anyone els , in connection with the matter for = S ??? which you were appointed to provide representation? ? YES "Cl If yes, give details on additional sheets D I swear or affirm the truth or correctness '4 I' 25: NET AMOUNT CLAIMED of the above statements Signature of Atto ey/Payee Date = $ ? L 26nr21 PI I u Signature of , ? Date: 4 ?ENt Judge 3 ?' (O 27. AMT. APPROVED = $ ? -- Copy 1 - Mail to Court Adminl6rator at completion of service -?,p,W OFFICE OF SEAN A SHULTZ, r.c. 4 Irvine Row Carlisle, PA 17013 Phone(717)701-8412 Fax(717)701-8416 billing@ShultzLawOffice.com www. ShultzLawOf fice.com Invoice submitted to: Asher and Lydia Smith 1513 Market Street Camp Hill, PA 17011 April 16, 2010 In Re: GAL Invoice #10660 Professional Services Hrs/Rate Amount 3/18/2010 Meeting with Asher and Lydia at their home with Mrs. Shunk For professional services rendered Previous balance Accounts receivable transactions 2/16/2010 Payment -Thank You No. 752917 Total payments and adjustments Balance due 2.20 99.00 45.00/hr 2.20 $99.00 $211.50 ($211.50) ($211.50) $99.00 ? AUTHORITY TO PAY COURT APPOINTED COUNSEL 0 2010 I., COURT 2. VOUCHER ? District Justice Common Pleas ? Appellate ? Other _ N0_133 3. FOR (D.J., C.P., P ATE) 4. ( ITY T) 5. BUDGET CQDF_ 21 , PA 101-4 N THE CASE OF 7. CHARGE/OFFEN E (PURDON CITATION) a. ? PETTY FENo if I, V ? ? FELONY G.dISDEMEANOR 4s & Ili ffi. t& P9. PROCEEDINGS (Describe briefly) 11. PERSON REPRESENTED 12. CIVIL DOCKET NO. //?? /? 1 ? Defendant - Adult ? Defendant • Juvenile ?AL D ?? q Z 3 ? Appellant 13. (( CRIMINAL DOCKET NO. 4 ? Appellee 5 ? Habeas Petitioner 6 ? Material Witness 10. PERSON REPRESENTED (Full Name) 7 ? Parolee Charged With Violation e ? Probatio of rge r' Appt Date 0 , „ tion 14. APPEALS DOCKET NO. Asher r -Othe /d1 Z Z 0 f 16. NAME OF ATTORNEY/PAYEE AND #? O MAILING ADDRESS 1v1. L. ?- r, Law Mee ofse? N,?hxjfz, PG -+Try(W P_ 6 w NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE ? air Ij`s f ,e, {?A 17013 17. TE P ON NO 18. SOCIAL SECURITYNO OR IN O r' 1 2_7_ D1 I CLAIM FOR SERVICES OR EXPENSES O 19. SERVICE HOURS DATES OHRTS C IMED a. Arraignment and/or Plea rat r h ?}ps total b. Preliminary Hearing = o I . com• pgR36i n. r toll fe'Tow. Wrn C. Motions and Requests - ¢ d Bail Hearings r =C3 rte' cn O I O a. Sentence Hearings f -T._ -10 U 1. Trial K` q z O'71 g. Revocation Hearings O CD C-) y C '- "'tf rt It. Juvenile Hearings D i. Appeals Court 19A. TO-VAL W COURT COMP. 4 Other (Specify on additional sheets) TOTAL HOURS X $55 PER HOUR _ $ 20. a. Interviews and conferences Multiply rate per hour times total U. Q Obtaining and reviewing records hours. Enter total "Out of Court- 0 j c. Legal research and brief writing compensation below. O d. Investigative and other work (Specify on additional sheets) 0 O 20A TOTAL OUT OF COURT COMP. TOTAL HOURS = ` I X $45 PER HOUR $ Ll 9 , 5 D 21. ITEMIZATION OF REIMBURSABLE EXPENSES AMT. PER ITEM Mil a $.48 per mile x W S f- O 21 A. TOTAL ITEMIZED EXP . _$ 22. CERTIFICATION OF ATTORNEY/PAYEE 23. GRANC TOTAL CLAIMEE Has compensation and;?ES tmbursement for work In this case previou been applied for? ffES ? NO $ / If yes, were you paid? ? NO If yes bywhom were you psl How much?1o, 151 Has the person represented paid any money to you, or to your knowledge anyone else, n connection with the matter for 24• DEDUCT. PRIOR PYMTS. which you were appointed to provide representati ? ? YES OoIQb If yes, give details on additional sheets ' $ I swear or affirm the truth or correctness _ _Izz f 2 f /O 25: NET AMOUNT CLAIMED of the above statements Signature of Ant ey/Payee Date 26.APPROVtr1Sign lure of 27. A T. APPR VED rcrn a eA 1,014 r Judge L-?\ Date: I? ID 'b a$ '7 • d V L,Dpy I -snail to Court Administrator at completion of service ?p,W OFFICE OF SEAN M. SHULTZ, rc. 4 Irvine Row Carlisle, PA 17013 Phone(717)701-8412 Fax(717)701-8416 billing@ShultzLawOffice.com www.ShultzLawOffice.com Invoice submitted to: Asher and Lydia Smith 1513 Market Street Camp Hill, PA 17011 November 29, 2010 In Re: GAL Invoice #11562 Professional Services Hrs/Rate Amount 10/18/2010 Email from Beth Shunk; Email to Beth Shunk 0.20 9.00 45.00/h r 11/4/2010 Telephone conference with Dan Smith 0.80 36.00 45.00/hr 11/8/2010 Receive and review correspondence from Dan Smith 0.10 4.50 45.00/hr For professional services rendered 1.10 $49.50 Previous balance $22.50 Accounts receivable transactions 10/12/2010 Payment -Thank You ($22.50) Total payments and adjustments ($22.50) Balance due $49.50 " AUTHORITY TO PAY COURT APPOINTED COUNSEL ?PZ MAR 1 4 2011 1. COURT 2. VOUCHER ? District Justice Common Pleas ? Appellate ? Other N0- 13303-1 3. FOR (D.J., C.P., APPELLATE) 4. AT CITY/ T#TE) 5. BUDGET CODE + p f , S -?s-ra?a • o?yod 6 N THE CASE OF`, A + d 7. CHARGE/OFFENSE (PURDON CITATION) 8. ? PETTY OFFENSE , 1 GY, is M '1 ? FELONY ? MISDEMEANOR 9. PROCEEDI GS (Describe briefly) 11. PERSON REPRESENTED 12. CIVIL DOCKET NO. t ? Defendant, Adult D (; r A T 11aa /? ///11? 2 ? Defendant • Juvenile 9 U 1?(t /1 / w/ / llvv ,/•t`' Il.? YU vy 3 ? Appellant 4 ? Appellee 13. CRIMINAL DOCKET NO. V ( / y If J 5 ? Habeas Petitioner 6 ? Material Witness 10. PERSON REPRESENTED (Full Name) 7 ? Parolee Charged With Violation 8 ? Probationer Charged With Violation 14. APPEALS DOCKET NO. ASW4 LQ,r?? 9? Other ?y ? J W (t4 Ja 16. NAME OF ATTORNEY/PAYEE AND Appt Date 0 y MAILING ADDRESS (I Law OFhee f dean 44, 5 h9/)?,AP, r 4 n NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE 3 00_4'-6?t 0A I4 03 17. TELEPHANE No. T tQ. :o AL SECURITY NO OR ND 2?'1l . CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOURS DATES AMOUNTS CLAIMED a. Arraignment and/or Plea Multiply rate per hour times total b. Preliminary Hearing hours to obtain "In Court" com- pensation Enter total below c. Motions and Requests . . .,? e•-; a d Bail Hearings =7 °i =. O e. Sentence Hearings _ _ --_-' _ Z I. Trial " . "T'^ _? ..... g. Revocation Hearings L h. Juvenile Hearings CO i r ,. i. Appeals Court 19A AL thLCOOMP. 1. Other (Specify on additional sheets) TOTAL HOURS = X $55 PER HOUR . IN-) 20. a. Interviews and conferences Multiply rate per hdur times total LL ?- b. Obtaining and reviewing records hours. Enter total "Out of Court- compensation b l O Cr a Legal research and brief writing ow. e Q O d. Investigative and other work (Specify on additional sheets) 20A TOTAL OUT OF COURT COMP. TOTAL HOURS = 2 '2 X $45 PER HOUR $ 99-00,/, 21. ITEMIZATION OF REIMBURSABLE EXP ENSES AMT. PER ITEM . Milage $.48 per mile x Q tt W S ? J x O 21 A. TOTAL ITEMIZED EXP. I r a $ - 22. CERTIFICATION OF ATTORNEY/PAYEE 23. GRAND T TALZLAIMED Has compensation and/or r imbursement for work in this case previous n a plied for? ?'YES O I If yes, were you paid? fy?YES O NO If yes bywhom were you paid? much? Q Q - -UlL Has the person represented paid any money to you, or to your knowledge anyone else, In connection with the matter for 24. DEDUCT. PRIOR PYMTS. which you were appointed to provide representation ? YES ONO If yes give details on additiona sheets l a $ I swear or affirm the truth or correctness - I il , 1 of the above statements Signature of A mey/Pe a Date 25: NET AMOUNT CLAIMED _$ 26 nrwnuvt u Fuu ?ArrwENr Signature of Judge ?Date. 27. AMT. AP OVED T OJ _ C i $ i all IN P ` a Copy 1 - Mail to Court Administr)tor at completion of service ?,AW OFFICE OF SEAN A SHULTZ,P.c. 4 Irvine Row Carlisle, PA 17013 Phone(717)701-8412 Fax(717)701-8416 billing@ShultzLawOffice.com www.ShultzLawOffice.com Invoice submitted to: Asher and Lydia Smith 1513 Market Street Camp Hill, PA 17011 In Re: GAL Invoice #11794 Professional Services March 08, 2011 Hrs/Rate Amount 12/20/2010 Telephone conference with Dan Smith 0.10 4.50 45.00/hr 12/31/2010 Email from Beth Shunk 0.20 9.00 45.00/hr 1/3/2011 Voicemail from Beth Shunk 0.10 4.50 45.00/hr 1/27/2011 Telephone conference with Dan Smith 0.20 9.00 45.00/hr 2/9/2011 Receive and review Email from Beth Shunk 0.20 9.00 45.00/hr 2/10/2011 Emails to and from Beth Shunk 0.20 9.00 45.00/hr Telephone conference with Dan Smith 0.10 4.50 45.00/h r 2/15/2011 Telephone conference with Dan Smith 0.10 4.50 45.00/h r 2/17/2011 Meeting with Beth Shunk and Gary Shunk 1.00 45.00 45.00/hr Asher and Lydia Smith For professional services rendered Previous balance Accounts receivable transactions 1/3/2010 Payment -Thank You No. 802994 Total payments and adjustments Balance due Page 2 Hours Amount 2.20 ? $99.00 $49.50 ($49.50) ($49.50) $99.00 i n A n RAAA AUTHORITY TO PAY COURT APPOINTED COUNSEL t COURT 2. VOUCHER 14264 NO ? District Justice artommon Pleas ? Appellate ? Other 3. FOR (D.J., C.P., P ATE) 4. AIM(CITY/ TAT) PA 5. BUDGET CODE 66 I:03 as IN THE ASE OF 7.C RGE/OFFENS (PURDON CITATION) 8. ? PETTYENSE . 9 "? / ? FELONY ? fMkDEMEANOR s M r j 4 , 9. PROCEEDI GS (Describe briefly) 11. PERSON REPRESENTED 1 . CIVIL OCKET NO. 1 O Defendant - Adult y 2 ? Defendant" Juvenile 3 ? Appellant 13. CRIMINAL DOCKET NO. L 4 ? Appellee 5 ? Habeas Petitioner 6 O Material Witness 7 ? Parolee Charged With Violation APPEALS DOCKET NO. 14 10. PERSON REPRESENTED (Full Name) 8 ? Probation lation . 9 ? Otner. h Mir 16. NAME OF ATTORNEY/PAYEE AND 111? Ito O &lb Appt Date MAILING ADDRESS Z a ?v D r ?e ?l Sh ?f, f.r4i Try 4 Tr'(; nt ko w NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE CA,) 15 fle PA 1V 13 17.T O 18. SOCIALS RITYN O MO CLAIM FOR SERVICES OR EXPENSES 19 SERVICE HOURS DATES AMOUNTS CL ED . a. Arraignment and/or Plea Multip is our t es total hou bta n Cow" com- b. Preliminary Hearing pen EnuKjotalz" ON c. Motions and Requests d Bail Hearings 1"' N .1Dp O e. Sentence Hearings Z ©cD 0 Z Trial 1. ?? -0 Q - g. Revocation Hearings +C N 0 h. Juvenile Hearings I. Appeals Court 19A. TO .IWU*iiiCOMP. 4 Other (Specify on additional sheets) ^^ '" TOTAL HOURS = X $55 PER HOUR _ $ 20. a. Interviews and conferences Multiply rate per hour times total Enter total "Out of Court" hours . U b. Obtaining and reviewing records compensation below. . O M G Legal research and brief writing ? O d. Investigative and other work (Specify on additional sheets) 20A. TOTAL OUT OF COURT O U COMP. TOTAL HOURS = X $45 PER HOUR = $ S , 21. ITEMIZATION OF REIMBURSABLE EX PENSES AMT. PER ITEM Miles e $ per mile x w Please contact Court Administrator for current mileage rate x 21A. TOTAL ITEMIZED EXP. I- O _$ 22. CERTIFICATION OF ATTORNEY/PAYEE ? 23. GRAND TAL CLA D Has compensation and/orrrr imbursement for work In this case provious en a ll d foci fJ<S N om / -S n _Hiwmuch7 If yes, were you paid? ®'YES ? NO Ifyea,bywhom were youpaid? 24. DEDUCT. PRIOR PYMTS. Has the person represented paid any money to you, or to your knowledge anyone else, In connection with the matter for $ give details on additi naI sheets resentation? ? YES NO If yea r vide re i d t t i , n p ch you were appo e o p o wh t swear or affirm the truth or correctness 5e==s'2 59a==: f Z / r r 25: NET AMOUNT CLAIMED % - of the above statements Signature of Attorney/Payee Date : $ / F U 28.ni' Fq6+ E G r' Signature of (/Date' J d Z4 k 1 27. AMT. APPROVED = $ ' _/? 00 AYMENF fl, u ge !'w • Copy 1 - Mail to Court Adm4trator at completion of service -?,Aw Omcz, SEAN M. SHULTZ, ra 4 Irvine Row Carlisle, PA 17013 Phone (717) 701-8412 Fax (717) 701-8416 billing@ShultzLawOffice.com www. ShultzLawOffice. com Invoice submitted to: Asher and Lydia Smith 1513 Market Street Camp Hill, PA 17011 December 14, 2011 In Re: GAL Invoice #13228 Professional Services Hrs/Rate Amount 11/29/2011 Telephone conference with Beth Shunk 0.30 13.50 45.00/hr 12/2/2011 Telephone conference with Chris Roland of CYS 0.20 9.00 45.00/hr Telephone conference with Chris Roland of CYS 0.30 13.50 45.00/hr Telephone conference with Dan Smith 0.10 4.50 45.00/hr 12/5/2011 Telephone conference with Beth Shunk 0.10 4.50 45.00/hr Meeting with clients and CYS caseworker 3.30 148.50 45.00/hr 12/7/2011 Voicemail from Amy Ford of CYS 0.10 4.50 45.00/hr For professional services rendered 4.40 $198.00 Previous balance x•50 Asher and Lydia Smith Accounts receivable transactions 10/13/2011 Payment -Thank You No. 827008 Total payments and adjustments Balance due Page 2 Amount ($85.50) ($85.50) $198.00 ,? 1 Q ?fJ?a AUTHORITY TO PAY COURT APPOINTED COUNSEL !v in 1. COURT / ?_.VOUCNER 7 ? District Justice a ommon Pleas ? Appellate ? Other A*t_ qdlyr NO 3. FOR (D.J., C.P., AP LL ) 4. ( ITY/ ?AT) S ! 5. BUDGET GUUt ` /ea - rs7a?Q- G o??r?h P - THE A E OF 6 _ 7. CHARGEJOFFENSE PUROON CITATION) a. O PETTY OFFENSE . O FELONY O MISDEMEANOR vs _ 41ROCE Df GS (Describe briefly) 11. PERSON REPRESENTED 12. CIWL DOCKET NO. 7 ? Defendant -Adult 2 O Defendant-Juvenile -- 3 ? Appellant 13. CRIMINAL DOCKET NO 4 O Appellee 5 O Habeas Petitioner 6 O Material Witness 7 O Parolee Charged With Violation APPEALS DOCKET NO. 14 10. PERSON REPRESENTED (Full Name) a O Probationer Charged With Violation , Lv A (L- a Sm 9 W Other- Z 16. NAME OF ATTORNEY/PAYEE AND MAILING ADDRESS Apot Date S j0(,1 LjS 'VI(i? Mr Lje7 Lrr jY.. ZV w, 4( 14 A, NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE Cictof'51e ( ------- - - --- - - -------- - 17.7 P ON NLZ2 -- - 18. SOCIAL SEC lTYNO OR EIN NO -2`1-?D3_ ---- FOR SERVICES OR EXPENSES CLAIM -- - - - ---------- ------- 19. SERVICE HOURS__ DATES L Cl4Mj*TS"CLAIMED__ a. Arraignment and/or Pies - - - _- Mu y rawer "or times total " b. Preliminary Hearing com- ?to fain "hilt ion. or t?l low. . c. Motions and Requests yr;;+ ,'^"?,,,, '" r •r k?'. d sail Hearings . tJl ? N CD O= e. Sentence Hearings tom'' fir= °Y r? V I. Trial g. Revocation Hearings Z O^• ~: h. Juvenile Hearings ' 4 I. Appeals Court 19A. T AL COtf T COMA. i Other (Specify on additional sheets) TOTAL HOURS a X $55 PER HOUR - $ 20. a. Interviews and conterencea Multiply rate per hour times tote 0. Obtaining and reviewing records hours. Enter total "Out of Court U. compensation below. ¢ c. Legal research and brief writing o O d. Investigative and other work (Specify on additional sheets) 20A. TOTAL OUT OF COURT COMP. TOTAL HOURS = J I X $45 PER HOUR 3 $ y r 21. ITEMIZATION OF REIMBURSABLE EX PENSES AMT. PER ITEM Mileage $ per mile x W Please contact Court Administrator for current mileage rate ILJ{ v//? O Z 21 A. TOTAL ITEMIZED EX : $ 22. CERTIFICATION OF ATTORNEY/PAYEE / Has compensation and/or reimbursement for work in this case previous 1 ed for? M YES a 23. GRANDTTAL IM it yes were you paid? i3 YES ? NO If yes by whom were you psld? y How much?? -S , . _ - Has the person represented paid any money to you, or to your knowle a anyone else. in connection with the matter for 24. DEDUCT. PRIOR PYM' which you were appointed to provide representatf 7 ? YES NO if yea give details on additional sheets I swear or affirm the truth or correctness - 25: NET AMOUNT CLAIM of the above statements Signature of A may/Payee ? Date T 041, .C'lJ 2t'j,nr?Pr 4 rvu ?avxrt Nt t Signature of Judge ! D I 0L 7. AMT. APPROVED ?© 0 ate: . Coot' 1 - Mail to Court Administrator at completion of service Law Offices of SAIDIS, SULLIVAN & ROGERS A PROFESSIONAL CORPORATION 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 EMAIL: attorney@ssr-attorneys.com www.ssr-attomeys.com Invoice submitted to: Asher and Lydia Smith 1513 Market Street Camp Hill, PA 17011 Make checks payable to Saidis, Sullivan & Rogers. January 13, 2012 In Re: GAL Invoice #13419 Professional Services Hrs/Rate Amount 12/19/2011 Draft Memo to file 0.10 4.50 45.00/hr For professional services rendered 0.10 $4.50 Previous balance $198.00 Accounts receivable transactions 1/312011 Payment - Thank You No. 834341 ($198.00) Total payments and adjustments ($198.00) Balance due $4.50 AUTHORITY TO PAY COURT APPOINTED COUNSEL , fV HB 10 2012 1 COURT ?? O Di i t t J ti 2. VOUCHER N 0 14484 r us s c ce LYC ommon Pleas ? Appellate ? Other _ 3. FOR (DJ., C.P.. APPELLATE) 4. A ITY /S ATE) 5. BUDGET CODE ( ` _ N THE ASE OF? c ' 7. CHARGE/OFFENSE PUROON CITATION) 8. ? PETTY OFFENSE vs MA '04al ? FELONY ? MISDEMEANOR 9. PROCEEDINGS (Describe briefly) 11. PERSON REPRESENTED 12. CIVIL DOCKET NO. ? Defendant -Adult /? /I ry // ? L 2 O Delandant - Juvenile ? 3 U fi! U 7 ? 7 r l ./ t 3 ? Appellant 4 ? Appellee 13. CRIMINAL DOCKET NO. 5 ? Habeas Petitioner 6 O Material Witness TED (Full Name) 10. PERSON RREPRESEN 7 ? Parolee Charged With Violation e ? Probationer Charged with violation 14. APPEALS DOCKET NO. 1 A-s l?? lr- d C 6? h 9? Others h J ?re? off 16. NAME OF ATTORNEY/PAYEE AND ?i/aN3y Appt Date MAILING ADDRESS S,A / 0A sa (d f s NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE ) 2 w? ML s?. 1h C (0-Is IP PA 11013 , 17.TELEPHON No _ 1 SOCIAL SECURITY NO OR EINNO CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOURS DATES AMOUNTS CLAIMED a. Arraignment and/or Plea Multiply rate per hour times total b. Preliminary Hearing hours to"tairy„°Ip COOT com- pensatio ta:frilee Stal bVIII C Motions and Requests - -a t ;z -I a d. Bail Hearings M CD * 1 ' f- ^, 1`i 1 e. Sentence Hearings CU l" r r: U f. Trial g. Revocation Hearings ?C:) ^^t} h. Juvenile Hearings C-) I. Appeals Court 19A. L Ity1VCOU CAMP. i. Other (Specify on additional sheets) co :.r7 TOTAL HOURS - X $55 PER HOUR 20. a. Interviews and conferences Multiply rate per hour times total b. Obtaining and reviewing records hours. Enter total "Out of Court" U.F compensation below. 0 W C. Legal research and brief writing t- :3 0 0 d. Investigative and other work (Specify on additional sheets) 20A. TOTAL OUT OF COURT CO P. TOTAL HOURS = Z X $45 PER HOUR M n = $ / D 3. 5D 21. ITEMIZATION OF REIMBURSABLE EX PENSES AMT. PER ITEM Mileage $ per mile x W Please contact Court Administrator for current mileage rate "'ext A 2 21 A. TOTAL ITEMIZED EXP. a $ 22. CERTIFICATION OF ATTORNEY/PAYEE ?// Has compensation and/orr reimbur em t f k I t i f ' 23. GRAND TOL CLAIMED 3 en s or wor n h s case previous Iled or? fr YES NO id7sell a H 11 yes were you paid? 7 YES C3 NO If es b whom were m h? = $ /0 -50 , , y , y you pa ow uc Has the person represented paid any money to you, or to your knowle anyone 9(9 4, in connection with the matter for 24. DEDUCT. PRIOR PYMTS. which you were appointed to provide representation ? YE O If yes, give details on addition I sheets ' $ I swear or affirm the truth or correctness 25: NET AMOUNT CLAIMED of the above statements Signature of A may ayee Date = $ /02- n 26 nr on V [C) ruu nAYW NI Signature of 1 Judge ) ? Dat 27. AMT. APPROVED e. ?? Copy 1 - Mail to Court Administrator at completion of service LEMOYNE OFFICE 635 NORTH 12TH STREET SUITE 400 LEMOYNE, PA 17043 TELEPHONE: (717) 612-5800 FACSIMILE: (717) 612-5805 Law Offices of Saidis, Sullivan & Rogers A PROFESSIONAL CORPORATION 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 EMAIL: attorney@ssr-attorneys.com www ssr-attorneys. com REPLY TO CARLISLE February 3, 2012 Asher & Lydia Smith 3528 September Dr. Apt. 4 Camp Hill, PA 17011 Our file# 81029 Invoice# 5307 S880089 EIN: 27-2700453 RE: GAL Payments received since last invoice Accounts receivable balance carried forward $0.00 $0.00 DATE DESCRIPTION HOURS 01/17/2012 Telephone conference with Daniel Smith; Notes to 0.40 file 01/23/2012 Telephone conference with Dan Smith; Office 0.10 conference with SMS 01/23/2012 Voicemail to Dan Smith; Telephone conference 0.20 with Dan Smith 01/25/2012 Office consultation with Asher Smith 1.60 TOTALS 2.30 LAWYER SMS DMH DMH SMS $103.50 S880089 ` GAL Invoice# 5307 Page 2 Billing Summary Total professional services $103.50 Total of new charges for this invoice $103.50 Total balance now due $103.50 * * Trust account remaining balance is $0.00 PRIVACY POLICY: During this firms representation of you, we may receive nonpublic, personal information from you or from sources about you. It is our policy and practice that our attorneys and staff do not at any time reveal information relating to our representation of you unless you consent after consultation, except for disclosures that are impliedly authorized to carry out the representation, and except for disclosures required or authorized by the Pennsylvania Rules of Professional Conduct. Interest at 1 1/2% per month on unpaid balance after 30 days MAR 2 3 2012 -0, AUTHORITY TO PAY COURT APPOINTED COUNSEL itle 1.000R7 ? 4 2. VOUCHER NN 0 4 5 6 ? District Justice C9 m Comon Pleas ? Appellate ? Other 3. FOR (D.J., C.P., APPE TE r 4. AT TY/ST TEL) 5. BUDGET CODE . 6'W (ya - 6 THE a C SE OF L ? 4 I d 7. CHARGE/OFFENSE (P RDON CITATION) 8. C1 P OFFENSE ? FELONY ? MISDEMEANOR ,__).M I ( - A a , vs M'i - I 9. PROCEEDINGS (Describe briefly) 11. PERSON REPRESENTED 12. CIVIL DOCKET NO. 1 ? Defendant - Adult O ^ 2 ? Defendant - Juvenile Y j A 3 ? Appellant 13. CRIMINAL DOCKET NO. (L 4 ? Appellee 5 ? Habeas Petitioner 6 ? Material Witness - 10. PERSON REPRESENTED (Full Name) ? Parolee Charged With violation g ? Probationer Charged With violation 14. APPEALS DOCKET NO. - 1 9 x Other A V 1114- k dw ?? • ? L 16. NAME OF ATTORNEY/PAYEE AND MAILING ADDRESS . Apot Date NAME OF COMMON PLEAS J DGE ASSIGNED TO CASE ),I S (l? P H03 17.T LE HONE No. 2-L J1 18. SOCIAL SECURITY NO OR EINNO 2-1--Z 5 CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOURS DATES A UNCLAIMED a. Arraignment and/or Plea Mult' " e pour mbes total h i b M : c C n om ou tgrg ta b tt b. Preliminary Hearing penftgm Entgjotal bM6w c. Motions and Requests r- rV - % l9 D ? d. Bail Hearings O e. Sentence Hearings < LL = y _ ' O I. Trial - C_' g. Revocation Hearings ' h. Juvenile Hearings r' I. Appeals Court 19A. TOTAL IN COURT COMP. j. Other (Specify on additional sheets) TOTAL HOURS = X $55 PER HOUR - $ 20. a. Interviews and conferences Multiply rate per hour times total r Ent r t l "Out f Court" h t ou s. e o a o U b. Obtaining and reviewing records compensation below. ? . O X c. Legal research and brief writing O d. Investigative and other work (Specify on additional sheets) 20A. TOTAL OUT OF COURT O U COMP. TOTAL HOURS = K $45 PER HOUR i $ ` L I a. O f 21. ITEMIZATION OF REIMBURSABLE EX PENSES AMT. PER ITEM Mileage $ per mile X W Please contact Court Administrator for current mileage rate = 21 A. TOTAL ITEMIZED EXP. t- O a $ 22. CERTIFICATION OF ATTORNEY/PAYEE ? 40 ? orr imbursement for work in this case previ slylbeen applied for? W S Has compensation and/ 23. GRAND TOTAL CLAIMED = S 12- + ? It yes. were you paid? V YES ? NO If yes, by whom were youpai How much? 24. DEDUCT. PRIOR PYMTS. Has the person represented paid any money to you, or to your knowle anyone else, in connection with the matter for a $ give details on addition I sheets tion? ? YES NO If yes id r r s nt i t d t , o prov e ep e e a n e which you were appo I swear or affirm the truth or correctness _ / Z- Date 25: NET AMOUNT CLAIMED of the above statements Signature omey/Payee = $ vv vv L ,()14 Signature of 26."5Erl III, qq ?6 l2 L Date: J -? z ? I'li 27. AMT. APPRO VED =S / 60 ! %YMF 1'AVME NI Judge , k p , Copy 1 - Mail to Court Admi istr or at completion of service Law Offices of Saidis, Sullivan & Rogers A PROFESSIONAL CORPORATION 26 WEST HIGH STREET LEMOYNE OFFICE CARLISLE, PENNSYLVANIA 1701.3 635 NORTH 121-H STREET TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 SUITE 400 EMAIL: attorney@ssr-attorneys.com LEMOYNE, PA 17043 ww?v.ssr-attorneys.com TELEPHONE: (717) 612-5800 FACSIMILE: (717) 612-5805 REPLY TO CARLISLE March 2, 2012 Asher & Lydia Smith 3528 September Dr. Apt. 4 Camp Hill, PA 17011 Our file# 81029 Invoice# 5871 5880089 EIN: 27-2700453 RE: GAL Balance forward as of invoice dated February 3, 2012 Payments received since last invoice Accounts receivable balance carried forward $103.50 $103.50 $0.00 DATE DESCRIPTION HOURS LAWYER 02/02/2012 Leave message for Beth Shunk 0.10 SMS 02/02/2012 Telephone conference with Beth Shunk regarding 0.40 SMS conversation with Asher 02/03/2012 Telephone conference with Asher Smith 0.20 SMS 02/06/2012 Telephone conference with Dan Smith regarding 0.20 SMS concerns about Beth Shunk's neighbor 02/13/2012 Telephone conference with Attorney Bayley 0.20 SMS 02/16/2012 Telephone conference with Asher 0.20 SMS 02/17/2012 Telephone conference with Dan Smith 0.10 DMH 02/17/2012 Telephone conference with Asher; Memo to file 1.20 SMS 02/21/2012 Receive voicemail and email from Beth Shun; Reply 0.20 SMS to email TOTALS 2.80 $126.00 S880609 GAL Invoice# :5871 Page 2 Billing Summary Total professional services Total of new charges for this invoice Total balance now due * * Trust account remaining balance is $0.00 $126.00 $126.00 $126.00 PRIVACY POLICY: During this firms representation of you, we may receive nonpublic, personal information from you or from sources about you. It is our policy and practice that our attorneys and staff do not at any time reveal information relating to our representation of you unless you consent after consultation, except for disclosures that are impliedly authorized to carry out the representation, and except for disclosures required or authorized by the Pennsylvania Rules of Professional Conduct. Interest at 1 1/2% per month on unpaid balance after 30 days. AUTHORITY TO PAY COURT APPOINTED COUNSEL DEC 11: 2013 1.COURT 2.VOUCHER /� Q Q ❑ District Justice ❑ Common Pleas ❑ Appellate ❑ Other N0- 14882 8 8 2 3.FOR(D.J.,C.P.,A P"i i PEL ATE) 4.A CITY/STAT 5.BUDGET CODE LS�� On-157- io-Go n IN THE CASE OF 7.CHARGE/OFFENS (PURDON CITATION) S. ❑ PETTY OFFENSE vs w ❑ FELONY❑MISDEMEANOR 9.PROCEE INGS(Describe briefly) 11.PERSON REPRESENTED 12.CIVIL DOCKET NO. 1 ❑ Defendant-Adult n 2 ❑ Defendant-Juvenile � G 3 ❑ Appellant 4 O Appellee 13.CRIMINAL DOCKET NO. 5 ❑ Habeas Petitioner 6 ❑ Material Witness 7 ❑ Parolee Charged With Violation 10.PERSON REPRESENTED(Full Name) a O Probationer Charged With Violation 14.APPEALS DOCKET NO. � ^ 9 10 Other. v` 16. NAME OF ATTORNEY/PAYEE AND Appt Date / OU MAILING ADDRESS 'VLA 5, Sow" NAME OF COMMON PLEAS JUDGE ASSIGNED TO.CASE 22 y P)q I�O13 17.TELEPHONE No. 18. SOCIAL SECURITY NO ORE IN NO Z - Z 2 -Z CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOURS DATES AMOUNTS CLAIMED a. Arraignment and/or Plea Multiply rate per hour times total b. Preliminary Hearing hours to obtain "In Court" com- pensation.Enter total below. c. Motions and Requests d. Bail Hearings IM 'O e. Sentence Hearings U I. Trial Z g. Revocation Hearings r`R C 7 C::, :j1 x h. Juvenile Hearings I. Appeals Court 19A yAL I11,1111-COUITT, MP. i. Other(Specify on additional sheets) ; , 'TT —'---''i TOTAL HOURS= X$55 PER HOUR CD Zn` 5D___� r 20. a. Interviews and conferences likit4ily rate per hourifim'es total hourr°Entr{ratbtal"'dot of Court" Obtaining and reviewing records compS'nsaticT6 below:' TO c. Legal research and brief writing 0 Ov d.Investigative and other work(Specify on additional sheets) 20A TOTAL OUT OF COURT COMP. TOTAL HOURS= 1 X$45 PER HOUR =$ r OD 21. ITEMIZATION OF REIMBURSABLE EXPENSES 1 AMT.PER ITEM Mileage$ per mile x /) , w Please contact Court Administrator for current mileage rate �u)�(/•cp L0 L� 21 A TOTAL ITEMIZED EXP. 22.CERTIFICATION OF ATTORNEY/PAYEE LF' AND TO AL IMED Has compensation and/or imbursement for work in this case previously been applied for? Q'YES ❑ NO $ If y es,were you paid? 2 YES O NO Ifyes,by whom were you paid? How much?J2.-V lo, 24.DEDUCT.PRIOR PYMTS. Has the person represented paid any money to you,or to your knowledge anyone else,in connection with the matter for $ which you were appointed to provide representation? ❑ YEt O If yes,give details on additional sheets = I swear or affirm the truth or correctness 17-41o120 1 25:NET AMOUNT CLAIMED of the above statements Signature of Attorney/Paye Date =$ .&.6 26.APPRO EO 27.AMT.APPROVED rug+ Signature of ► II Date: PAYMENT Judge Copy 1 -Mat to Court Admini or at completion of service Law Offices of Saidis, Sullivan & Rogers A PROFESSIONAL CORPORATION 26 WEST HIGH STREET LEMOYNE OFFICE CARLISLE, PENNSYLVANIA 17013 635 NORTH 12TH STREET TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 SUITE 400 EMAIL: attorney@ssr-attorneys.com LEMOYNE,PA 17043 wwwssr-attorneys.com TELEPHONE: (717) 612-5800 FACSIMILE: (717) 612-5805 REPLY TO CARLISLE December 2, 2013 Asher &Lydia Smith Our file# 81029 S880089 3528 September Dr. Apt. 4 Invoice# 14225 Camp Hill, PA 17011 EIN: 27-2700453 RE: Elizabeth L. Shunk, Daniel J. Smith, Margo E. Lally, Richard E. Lally Balance forward as of invoice dated January 4, 2013 $9.00 Payments received since last invoice $9.00 Accounts receivable balance carried forward $0.00 DATE DESCRIPTION HOURS AMOUNT LAWYER 10/08/2013 Review and respond to email from Elizabeth Shunk 0.20 $9.00 SMS 10/09/2013 Email to Elizabeth Shunk 0.20 $9.00 SMS TOTALS 0.40 $18.00 I 880089 GAL Invoice# 14225 Page 2 Billing Summary Total professional services $18.00 Total of new charges for this invoice $18.00 Total balance now due $18.00 ** Trust account remaining balance is $0.00 PRIVACY POLICY: During this firms representation of you,we may receive nonpublic,personal information from you or from sources about you. It is our policy and practice that our attorneys and staff do not at any time reveal information relating to our representation of you unless you consent after consultation,except for disclosures that are impliedly authorized to carry out the representation,and except for disclosures required or authorized by the Pennsylvania Rules of Professional Conduct. Interest at 1 1/2%per month on unpaid balance after 30 days. Saidis Sullivan & Rogers is excited to be able to offer you the opportunity to receive your statements via email. To sign up or for more information email billing @ ssr-attorneys.com AUTHORITY TO PAY COURT APPOINTED COUNSEL AR 92014 1. COURT 0 District Justice 0 Common Pleas 0 Appellate 0 Other 2. VOUCHER N 1488 3 3. FOR (D.J., C.P., APP . AT . li 4. AT ( ,TY/STA ' E _ I I I 5. BUDGET CODE a - 1- 0-Go,bra. 6. THE CASE OF WI 1 4iki SA*1 vs ill.144"),% .0/ ((i) 7. CHARGE/OFFENSE (PU -DON CITATION) 8. 0 PETTY OFFENSE 0 FELONY 0 MISDEMEANOR 8. PROCEEDINGS (Describe briefly) A L 11. PERSON REPRESENTED 1 0 Defendant-Adult 2 0 Defendant • Juvenile 3 0 Appellant 4 0 Appellee 5 0 Habeas Petitioner 6 0 Material Witness 7 0 Parolee Charged With Violation 8 0 Probationer Charged With Violation Omer. 12. CIVIL DOCKET NO. 0 3 3092 13. CRIMINAL DOCKET NO. 10. PERSON REPRESENTED (Full Name) PS h el 4 LdiiAcchi i k 14. APPEALS DOCKET NO Apot Date /242,9 )0 g 16. NAME OF ATTORNEY/PAYEE AND MAILING ADDRESS SaidTs SRO ItYttft .t iQ.0 ei S )--1-t- h 6f, M, L . Fki,j)-,-:-J-K, NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE _ z to 0, eir)islo )c7-oL3 17. TELEPHONE No. 2143-149222- 18. SOCIAL SECURITY NO OR EIN NO 21-230055 CLAIM FOR SERVICES OR EXPENSES it) IN COURT SERVICE HOURS DATES AMOUNTS CLAIMED a. Arraignment and/or Plea MultiriRraterper hour limes total hourt, obfaA "In Curt" com- p4a4on. Eater total below, rri CO M Xs.. rl -- , -..',":i .-30 cf)r- ,,,...„, —‹ r -,,, C.; r-:---7 .---1 --. ):'-' c- --a. cD C) C7: b. Preliminary Hearing c. Motions and Requests d. Bail Hearings, e. Sentence Hearings f. Trial g. Revocation Hearings h. Juvenile Hearings i. Appeals Court 1. TOTAL 'IN COURTCOMP. ---:: r\:, _., • = $ J. Other (Specify on additional sheets) TOTAL HOURS = X $55 PER HOUR OUT OF re:, COURT a. Interviews and conferences Multiply rate per hour times total hours. Enter total "Out of Court" compensation below. b. Obtaining and reviewing records c. Legal research and brief writing d. Investigative and other work (Specify on additional sheets) 20A TOTAL OUT OF COURT COMP. . .,, L I 210, 00 TOTAL HOURS = , 2 8, X $45 PER HOUR 1 OTHER :2 ITEMIZATION OF REIMBURSABLE EXPENSES AMT. PER ITEM ti 1bd 61 Mileage $ per mile x Please contact Court Administrator for current mileage rate 21A TOTAL TEMIZED EXP. = $ 22. CERTIFICATION OF ATTORNEY/PAYEE Has compensation and/orfilmbursement for work In this case previous en a plied for? YES AO NO ,,....7 If were paid? r'YES 0 NO It yes, by whom were you paid? How much? I 'Zvi 3 1) 23. GRAND TOTAL CLAIMED '' $ I 2.Lp, 07) 24. DEDUCT. PRIOR PYMTS. $ yes, you Has the person represented paid any money to you, or to your knowlele anyone else, In connection with the matter for which you were appointed to provide represerlation? 0 YES 81•10 If yes, give details on additional sheets I swear or affirm the truth or correctness .-->--"--..."---- .5// 3//4 25:NET AMOUNT CLAIMED = $ In) of the above statements Signature of Attomey/Paye Data 26.APPnovi Er f()14 a AYMENT Signature of Judge \\P 1\k‘■ Date: 3 1 1 0 f II 27. AMT. A PROVED -s pto.,0 Copy 1 Mail to Court Administrator at completion of service LEMOYNE OFFICE 635 NORTH 12TH STREET SUITE 400 LEMOYNE, PA 17043 TELEPHONE: (717) 612 -5800 FACSIMILE: (717) 612 -5805 Law Offices of Saidis, Sullivan & Rogers A PROFESSI.ONA1.. CORPORATION 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 243 -6222 - FACSIMILE: (717) 243 -6486 EMAIL: attorney @ssr - attorneys.com www.ssr-attorneys.com March 3, 2014 Asher & Lydia Smith 3528 September Dr. Apt. 4 Camp Hill, PA 17011 REPLY TO CARLISLE Our file# 81029 S880089 Invoice# 15444 EIN: 27- 2700453 RE: Elizabeth L. Shunk, Daniel J. Smith, Margo E. Lally, Richard E. Lally Balance forward as of invoice dated March 3, 2014 Payments received since last invoice A/R adjustments made since last invoice Accounts receivable balance carried forward DATE 02/04/2014 02/10/2014 02/12/2014 02/12/2014 02/14/2014 02/21/2014 02/24/2014 02/24/2014 DESCRIPTION $144.00 $0.00 ($144.00) Emails to and from Beth Shunk Office conference with clients Telephone conference with Attorney Sunday's office Receive and review email from Elizabeth Shunk; Telephone conference with Attorney Dissinger; Email to Attorney Dissinger Email to Attorneys Dissinger and Bayley Telephone conference with Attorney Bayley's office Voicemail from Attorney Bayley's staff Receive letter from Attorney Bayley $0.00 HOURS AMOUNT LAWYER 0.20 1.00 0.20 0.60 0.20 0.20 0.20 0.20 TOTALS 2.80 $9.00 DMH $45.00 SMS $9.00 DMH $27.00 SMS $9.00 DMH $9.00 DMH $9.00 DMH $9.00 SMS $126.00 SS8R008* GAL Invoice# 15444 Page 2 Billing Summary Total professional services Total of new charges for this invoice $126.00 $126.00 Total balance now due $126.00 ** Trust account remaining balance is $0.00 PRIVACY POLICY: During this firms representation of you, we may receive nonpublic, personal information from you or from sources about you. It is our policy and practice that our attorneys and staff do not at any time reveal information relating to our representation of you unless you consent after consultation, except for disclosures that are impliedly authorized to carry out the representation, and except for disclosures required or authorized by the Pennsylvania Rules of Professional Conduct. Interest at 1 1/2% per month on unpaid balance after 30 days. AUTHORITY TO PAY COURT APPOINTED COUNSEL 1. COURT District Justice 0 Common Pleas 0 Appellate 0 Other ... .. _ 2. VOUCHER 14884 N° . FOR ( . ., C.P : PPDLATE) 4. AT I IS AT ) / • 4 / 5. BUDGET CODE fp -- i c)ipe / lIva . IN THE C SE OF IA , 4i 9. PROCEED GS Cyr A / 7. CHARGE/OFFENSE vs 'ii / I (Describe briefly) L (PURDON CITATION) 1. PERSON REPRESENTED t 0 Defendant-Adult 2 0 Defendant - Juvenile 3 0 Appellant 4 0 Appellee 5 0 Habeas Petitioner 6 0 Material Witness 7 0 Parolee Charged With Violation 8 0 Probationer Charged With Violation Other. _ 8. 0 PETTY OFFENSE 0 FELONY 0 MISDEMEANOR 12. CIVIL DOCKET NO. 2 13. CRIMINAL DOCKET NO. 10, PERSON REPRESENTED (Full Name) kSheir k) yofia &TINA 14. APPEALS DOCKET NO. Appt Date 2..., OS •T ,r4,e. 16. NAME OF ATTORNEY/PAYEE AND MAILING ADDRESS . Creg-s- Sufi/lice/1.4- )2 Eq(ei6 2te I u1 4-i-Iii 6-4-. 61)41S/et PA 11013 111l.) Ehe • NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE 17. TELHHONE No. '211l- EP1-2-2- 18. SOCIAL SECURiTY NO OR E IN NO 2-1-27012 qn-3 CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOURS DATES AMOUNTS CLAIMED a. Arraignment and/or Plea unip_ ' hour times total hours $.:5 obtain."In Court" com- pensetiOn. Errtii. total m f._1) =am. - = M t:7 _.... I: ...,,.) ur--,-, _.<> C) "7 (--- ...-1.--- ‹ [ID '''' (7) CD -7 ---, --- f. -4- — C:i :::. b. Preliminary Hearing C. Motions and Requests d. Bail Hearings a. Sentence Hearings . Trial g. Revocation Hearin a h. Juvenile Hearings i. Appeals Court 19A:4707UL I COURT COMP. ---i -/ -- -,.: = $ j. Other (Specify on additional sheets) TOTAL HOURS = X $55 PER HOUR OUT OF ?) COURT a. Interviews and conferences Multiply rate per hour times total hours. Enter total "Out of Court" compensation below. b. Obtaining and reviewing records c. Legal research and brief writing d. Investigative and other work (Specify on additional sheets) 20A. TOTAL OUT OF COURT COMP. = $ ) Y 0 4 VD TOTAL HOURS = L--) X $45 PER HOUR OTHER ITEMIZATION OF REIMBURSABLE EXPENSES AMT. PER ITEM Mileage $ per ile x Please contact Court Administrator current mileage rate 21A. TOTAL ITEMIZED EXP. . s 22. CERTIFICATION OF ATTORNEY/PAYEE Has compensation and/oyiimbursement for work In this case previous., If yes, were you paid? C? 'YES 0 NO If yes. by whom were you palcf? '., = en p. led for? ES a pct %.1 .4, .i, voi , How much? 12 23. GRAND TOTAL CLAIMED . $ 'O. 1)2) 24. DEDUCT. PRIOR PYMTS. =1 S ,..: Has the person represented paid any money to you, or to your knowle yone els In connection with the matter for which you were appointed to provide representation? 0 YES 0 If yes, give details on additional,sheets I swear or affirm the truth or correctness 4/P-1// il 25.-NET AMOUNT CLAIMED = 16 (n) of the above statements Signature of Attorney/Pay e Dale 26.Appnov,I, f OR PAYMENI Signature of Judge III, Date: ll 1014 27. AMT. APPROVED = $ Ito. 0 0 Copy 1 - Mail to Court Administratdk at completion of service .4, LEMOYNE OFFICE 635 NORTH 12TH STREET SUITE 400 LEMOYNE, PA 17043 TELEPHONE: (717) 612-5800 FACSIMILE: (717) 612-5805 Law Offices of Saidis, Sullivan & Rogers A PROFESSIONAL CORPORATION 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 EMAIL: attomey@ssr-attorneys.com www.ssr-attorneys.com April 2, 2014 Asher & Lydia Smith 3528 September Dr. Apt. 4 Camp Hill, PA 17011 REPLY TO CARLISLE Our file# 81029 S880089 Invoice# 15604 EIN: 27-2700453 RE: Elizabeth L. Shunk, Daniel J. Smith, Margo E. Lally, Richard E. Lally Balance forward as of invoice dated March 3, 2014 $126.00 Payments received since last invoice $0.00 Accounts receivable balance carried forward $126.00 DATE DESCRIPTION 03/19/2014 Review file 03/19/2014 Attend Custody Conciliation HOURS AMOUNT LAWYER 0.40 3.60 TOTALS 4.00 $18.00 SMS $162.00. SMS $180.00 ./ S880a,9 GAL Invoice# 15604 Page 2 Billing Summary Total professional services $180.00 Total of new charges for this invoice $180.00 Plus net balance forward $126.00 Total balance now due $306.00 ** Trust account remaining balance is $0.00 PRIVACY POLICY: During this firms representation of you, we may receive nonpublic, personal information from you or from sources about you. It is our policy and practice that our attorneys and staff do not at any time reveal information relating to our representation of you unless you consent after consultation, except for disclosures that are impliedly authorized to carry out the representation, and except for disclosures required or authorized by the Pennsylvania Rules of Professional Conduct. Interest at 1 1/2% per month on unpaid balance after 30 days. Saidis Sullivan & Rogers is excited to be able to offer you the opportunity to receive your statements via email. To sign up or for more information email billinggssr-attorneys.com