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HomeMy WebLinkAbout04-0669MARTICE I. HOCKLEY and IN THE COURT OF COMMON PLEAS OF TERRY L. HOCKLEY, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. CIVIL ACTION - LAW NO. 2004 - 6 69 CIVIL TERM TABITHA M. HOCKLEY and JASON M. STROHECKER, Defendants IN CUSTODY CUSTODY COMPLAINT 1. Plaintiffs are Terry L. Hockley and Martice I. Hockley, adult individuals, currently residing at 310 Bonnybrook Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant Tabitha M. Hockley, is an adult individual, currently residing at 760 Longs Gap Road, Carlisle, Pennsylvania 17013. Defendant Jason M. Strohecker, is an adult individual residing in the Conodoquinet Mobile Home Park, Newville, Pennsylvania 17241. 3. Plaintiff seeks custody of the following child: Tristan Michael Strohecker, age 7, born May 12, 1996. The child was born out of wedlock. The child is presently in the primary custody of the Plaintiffs with partial custody in the Defendants. There is no current Court Order. During the past five years, or since the child's birth, he has resided with the following persons at the following addresses: (a) From April 2002, to the present with the Plaintiffs in Carlisle, Cumberland County, Pennsylvania. (b) From birth until April 2002, with Tabitha M. Hockley at various locations in Cumberland County. 4. The relationship of the Plaintiffs to the child is that of grand uncle and grand aunt. They reside with Tristan. 5. The relationship of the Defendant, Jason M. Strohecker, to the child is that of natural father. He is currently an inmate residing in the Cumberland County Prison. 6. The relationship of the Defendant, Tabitha M. Hockley is that of natural mother she currently resides at 760 Longs Gap Road Carlisle, Pennsylvania. 7. The parties have not participated as a party or witness in reference to the custody of their child. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 8. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) The Plaintiffs have served as the primary caretakers of Tristian since he moved to their home in April of 2002. He is established in school and activities associated with the school and the local community . (b) The natural parents have shown little interest in maintaining a relationship with their son and in consequence, Tristian has indicated a strong desire to remain in the Plaintiffs home. He is very concerned that his mother intends to remove him from the home in the near future. 9. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene. NAME ADDRESS BASIS OF CLAIM None WHEREFORE, Plaintiff's requests your Honorable Court to: A. Grant primary custody of the child to the Plaintiffs; B. Enter a temporary order confirming primary custody in the Plaintiffs', pending conciliation conference; C. D child. Date: 211-7 jV? Grant times with temporary custody to the parents; Grant such other relief as to just and in the best interest to the Respectfully submitted, i p Robert L. O'Brien, Esquire Attorney for Plaintiffs 17 West South Street Carlisle, PA 17013 (717) 249-6873 rio.dirlhockley/domestic/custody.com VERIFICATION We, the undersigned, verify that the statements made in the foregoing Complaint To Modify Custody are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Terry L. Hock Date: o? - /a -6 '?z h)d66,u 2 IVZ Martice I. Hockley Date: ??% ^? c-p > ('? h'7 il] ?J ? . , ,? d? : _<-, _.. '? J J v \ .. •i ? ? ? r ? ? 4i r d MARTICE I. HOCKLEY AND TERRY L. HOCKLEY PLAINTIFF V. TABITHA M. HOCKLEY AND JASON M. STROHECKER . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-669 CIVIL ACTION LAW . IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, February 23, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. _ , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, April 02, 2004 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy, Esq. c/ 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 ha r Martice L Hockley and Terry L. Hockley, Plaintiffs, v. Tabitha M. Hockley and Jason M. Strohecker, Defendants TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF COUNTY, PENNSYLVANIA CIVIL ACTION NO. 2004-669 IN CUSTODY PRAECIPE Please enter my appearance on behalf of the Tabitha M. Hockley C-? Date: Mark F. Bayley, Esquire 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 87663 Attorney for Defendant N ?] C- ?., r,? .?7 m? ?,?„ _: W CJ ?? r'. 1' ^? ? ?;T rj -? ? , y C CJ ? ".J -2 Cif . -` f V ' APR U 8 2004V' MARTICE I. HOCKLEY and, TERRY L. HOCKLEY, Plaintiffs v TABITHA M. HOCKLEY and, JASON M. STROHECKER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-669 IN CUSTODY COURT ORDER AND NOW, this i y a day of April, 2004, upon consideration of the attached Custody Conciliation report, it is ordered and directed that the prior custody order entered in this case is vacated and the following order is entered: 1. The maternal great-uncle and his wife, Martice I. Hockley and Terry L. Hockley, shall enjoy primary physical custody of Tristan Michael Strohecker, born May 12,19%. 2. The mother, Tabitha M. Hockley, shall enjoy temporary physical custody with the minor child as follows: a. On alternating weekends from 12 noon until 5:00 p.m. on both Saturday and Sunday. b. On alternating Thursdays from 5:00 p.m. until 7:30 p.m. and on alternating Tuesdays from 5:00 p.m. until 7:30 p.m. c. At such other times as agreed upon by the parties. 3. Upon the father's release from prison, father, Jason M. Strohecker, shall enjoy periods of temporary physical custody with the minor child at such times as agreed upon with the Hockleys. It is understood that the Hockleys shall be liberal in providing the father opportunities to enjoy temporary custody with the minor child. 4. The parties shall meet again with the custody conciliator for a custody conciliation conference on June 17, 2004 at 9:30 a.m. ! :1 !-1,J 1s I 111'. v ?icc L 5. This is a temporary order and does not prejudice any of the parties from advancing a different position at a court hearing if this matter is scheduled for a hearing. BY THE COURT, Judge evin A. Hess cc: Mark F. Bayley, Esquire Robert L. O'Brien, Esquire Jason M. Strohecker 5?1 4 APR 0 8 2004 MARTICE I. HOCKLEY and, TERRY L. HOCKLEY, Plaintiffs v TABITHA M. HOCKLEY and, JASON M. STROHECKER, Defendants Prior Judge: Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-669 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Tristan Michael Strohecker, born May 12, 19%. 2. A Conciliation Conference was held on April 2, 2004, with the following individuals in attendance: The maternal great-uncle and his wife, Martice I. Hockley and Terry L. Hockley, with their counsel, Robert L. O'Brien, Esquire, and the mother Tabitha M. Hockley, with her counsel, Mark F. Bayley, Esquire, and the father, Jason M. Strohecker, who appeared without counsel. 3. The parties reached a temporary agreement on custody, and the conciliator recommends an order in the form as attached. ?L--/o DATE Z??,g ? Hubert X. Custody C , Esquire JUL 2 8 2004 V MARTICE I. HOCKLEY and TERRY L. HOCKLEY, Plaintiffs v TABITHA M. HOCKLEY and, JASON M. STROHECKER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2004 - 669 IN CUSTODY COURT ORDER AND NOW, this Zg' day of JP1-L , 2004, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. Paragraph 2 (a) of this Courts April 14, 2004 order is modified such that mother's alternating weekend custody with the minor child shall be from Friday at 6:00 p.m. until Saturday at 6:00 p.m. unless agreed otherwise between the parties. 2. In the event any party desires to modify this order, that party may have their attorney contact the Custody Conciliator directly for the scheduling of a conference, which may be a telephone conference call. BY THE COURT, Kevin A. Hess cc: Mark F. Bayley, Esquire Michael A. Scherer, Esquire ` Gr.. 6 Jason M. Strohecker ' (? WXVaNV,i:!qN d f ON, ;;'?t10 9£ :01 WV 0C !1f hDoz kiViONOHiOUd 3Hi d0 MARTICE L HOCKLEY and TERRY L. HOCKLEY, Plaintiffs v TABITHA M. HOCKLEY and JASON M. STROHECKER, Defendants Prior Judge: Kevin A. Hess : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N0.2004 - 669, IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT The Conciliator met with the parties and the attorneys again for a second Custody Conciliation conference and the parties agreed to the entry of an order in the form as attached. °1/aLr o DATE Hubert X. Gilroy, Custody Conciliay MARTICE I. HOCKLEY and TERRY L. HOCKLEY, Plaintiff's V. TABITHA M. HOCKLEY and, JASON M. STROHECKER, Defendant's IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO: 04-669 - CIVIL TERM CIVIL ACTION - LAW IN CUSTODY The Honorable Kevin A. Hess PETPI'ION TO MODIFY CUSTODY 1 2. 3 4. 5 6. Petitioner is Tabitha M. Hockley, who resides at 801 Sandbank Road, Lot 6, Mt. Holly Springs, Pennsylvania 17065. Respondents are Martice I. Hockley and Terry L. Hockley, who resides at 310 Bonnybrook Road, Carlisle, Cumberland County, Pennsylvania 17013. On April 14, 2004, the Honorable Kevin A. Hess entered a Custody Order attached as Exhibit "A". On July 29, 2004, the Honorable Kevin A. Hess entered a revised Order of Court amending the Order of Court dated April 14, 2007, attached as Exhibit "B". Since the entry of said Order, there has been a significant change in circumstances in that: a) Father is not abiding by the previous Order. b) Mother has improved her situation greatly since the last Order was entered. The best interest of the children will be served by the Court modifying said Order. 7. Robert O'Brien, Esquire was copied on this petition it is believed that his client will be opposed. WHEREFORE, Petitioner prays this Court to grant the modification of the Custody Order and grant shared custody. Respectfully submitted, Rominger & Associates Date: July 16, 2007 Kaff E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Petitioner Hockley MARTICE I. HOCKLEY and : IN THE COURT OF COMMON PLEAS TERRY L. HOCKLEY, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff's : V. : NO: 04-669 -CIVIL TERM TABITHA M. HOCKLEY and, CIVIL ACTION -LAW JASON M. STROHECKER, IN CUSTODY Defendant's The Honorable Kevin A. Hess ATTORNEY VERIFICATION Karl E. Rominger, Esquire, states that he is the attorney for, Tabitha M. Hockley 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. Pa.C. S. §4904, relating to unworn falsification to authorities. c Date: July 16, 2007 Karl E. Rominger, Esquire Attorney for Petitioner APR U 8-2,004 .1 MARTICE I. HOCKLEY and, IN THE COURT OF COMMON PLEAS OF TERRY L. HOCKLEY, Plaintiffs CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW TABITHA M. HOCKLEY and, NO. 04-669 JASON M. STROHECKER, Defendants IN CUSTODY COURT ORDER AND NOW, this 11' day of April, 2004, upon consideration of the attached Custody Conciliation report, it is ordered and directed that the prior custody order entered in this case is vacated and the following order is entered: 1. The maternal great-uncle and his wife, Martice I. Hockley and Terry L. Hockley, shall enjoy primary physical custody of Tristan Michael Strohecker, born May 12, 1996. 2. The mother, Tabitha M. Hockley, shall enjoy temporary physical custody with the minor child as follows: a. On alternating weekends from 12 noon until 5:00 p.m. on both Saturday and Sunday. b. On alternating Thursdays from 5:00 p.m. until 7:30 p.m. and on alternating Tuesdays from 5:00 p.m. until 7:30 p.m. c. At such other times as agreed upon by the parties. 3. Upon the father's release from prison, father, Jason M. Strohecker, shall enjoy periods of temporary physical custody with the minor child at such times as agreed upon with the Hockleys. It is understood that the Hockleys shall be liberal in providing the father opportunities to enjoy temporary custody with the minor child. 4. The parties shall meet again with the custody conciliator for a custody conciliation conference on June 17, 2004 at 9:30 a.m. 5. This is a temporary order and does not prejudice any of the parties from advancing a different position at a court hearing if this matter is scheduled for a hearing. BY THE COURT, 5 Judge evin A. Hess cc: Mark F. Bayley, Esquire Robert L. O'Brien, Esquire Jason M. Strohecker TRUE k.110" v in TeSt`iii(?nyi ?r`,.yrn and the s?al of sa' ...,.?.., Thk...... { hand I here InTr setp?my MARTICE I. HOCKLEY and, TERRY L. HOCKLEY, Plaintiffs v TABITHA M. HOCKLEY and, JASON M. STROHECKER, Defendants Prior Judge: Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-669 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Tristan Michael Strohecker, born May 12, 1996. 2. A Conciliation Conference was held on April 2, 2004, with the following individuals in attendance: The maternal great-uncle and his wife, Martice 1. Hockley and Terry L. Hockley, with their counsel, Robert L. O'Brien, Esquire, and the mother Tabitha M. Hockley, with her counsel, Mark F. Bayley, Esquire, and the father, Jason M. Strohecker, who appeared without counsel. 3. The parties reached a temporary agreement on custody, and the conciliator recommends an order in the form as attached. q - DATE zo ? Hubert X. Custody C , Esquire MARTICE I. HOCKLEY and TERRY L. HOCKLEY, Plaintiffs v °PBITHA M. HOCKLEY and JASON M. STROHECKER, Defendants Prior Judge: Kevin A. Hess s : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2004 - 669 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT The Conciliator met with the parties and the attorneys again for a second Custody Conciliation conference and the parties agreed to the entry of an order in the form as attached. r/a'?' o DATE c? - ? ?Z7/ Hubert X. Gilroy, Custody Conciliate kk ig I I JUL 2 8 2004 MARTICE I. HOCKLEY and TERRY L. HOCKLEY, Plaintiffs v TABITHA M. HOCKLEY and, JASON M. STROHECKER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2004 - 669 IN CUSTODY COURT ORDER AND NOW, this day of 2004, upon consideration of the attached Custody Conciliati " n eport, is ordered and directed as follows: 1. Paragraph 2 (a) of this Courts April 14, 2004 order is modified such that mother's alternating weekend custody with the minor child shall be from Friday at 6:00 p.m. until Saturday at 6:00 p.m. unless agreed otherwise between the parties. 2. In the event any party desires to modify this order, that party may have their attorney contact the Custody Conciliator directly for the scheduling of a conference, which may be a telephone conference call. BY THE COURT, cc: Mark F. Bayley, Esquire Michael A. Scherer, Esquire Jason M. Strohecker Judge Kevin A. Hess M1 gyp/ h?? Tr'[?' ? Q _Z!? .. [ ? n:? y f ? •?±?y MARTICE I. HOCKLEY and : IN THE COURT OF COMMON PLEAS TERRY L. HOCKLEY, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff's : V. : NO: 04-669 - CIVIL TERM TABITHA M. HOCKLEY and, CIVIL ACTION - LAW JASON M. STROHECKER, IN CUSTODY Defendant's The Honorable Kevin A. Hess CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, do hereby certify that I this day served a copy of the within Petition to Modify Custody upon the following by depositing the same in the United States Mail, postage prepaid addressed as follows: Robert L. O'Brien, Esquire O'BRIEN, BARIC & SCHERER 19 West South Street Carlisle, Pennsylvania 17013 Respectfully submitted, Rominger & Associates Date: July 16, 2007 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Petitioner Hockley C.? _..-a -? ...: ?,.1 ? ? ?? ?' ? _ ,z. ?? s??' ? f .? ? Y?? w MARTICE I. HOCKLEY AND TERRY L. HOCKLEY PLAINTIFF V. TABITHA M. HOCKLEY AND JASON M. STROHECKER DEFENDANT IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA 04-669 CIVIL. ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, July 24, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, August 31, 2007 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy, Es q. lw-J 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 -? O IG, GdSi` C f ?. w SEP 10 2007,W MARTICE I. HOCKLEY and TERRY L. HOCKLEY, Plaintiff v TABITHA M. HOCKLEY and JOSEPH M. STROHECKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 9i- IN CUSTODY COURT ORDER Judge Iin A. Hess cc: Karl E. Rominger, Esquire Johnna J. Kopecky, Esquire ?o?+? 7 p:WffX. ZK9WU2321 Cgoody Coneftdone112321.8oddey v Hoddey C-Aa&n RAP0h-0raer..vpa AND NOW, this l / r day of September, 2007, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. This Court's prior Order of April 14, 2004, as modified by Order of July 29, 2004 , shall remain in place except as modified below. 2. The parties shall submit themselves and the minor child to a counseling evaluator who shall determine the appropriateness of mother's reintroduction to the child and a proposed schedule along those lines. This counselor shall also, if possible, make arrangements for an appropriate drug evaluation for the mother. Legal counsel for the parties shall work together to facilitate these evaluations. 3. Mother shall exercise temporary custody with the minor child pursuant to a recommendation of the counselor. 4. In the event mother becomes dissatisfied with the pace of the proceedings or with the recommended result, mother's counsel may contact the Custody Conciliator directly to set up a telephone conference between legal counsel for the parties after which the Conciliator may recommend an Order to this Court to schedule a hearing or address a Custody Order as agreed upon by the parties. BY THE COURT, / VIN'df1WNN3d 6? :1 W I I AS LOOZ 30 L-140-0378- . 41'M 7 MARTICE I. HOCKLEY and TERRY L. HOCKLEY, Plaintiff v TABITHA M. HOCKLEY and JOSEPH M. STROHECKER, Defendant Prior Judge: Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.0"19t 09•4Lq IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Tristan Michael Strohecker, born May 12,1996. 2. A Conciliation Conference was held on August 31, 2007, with the following individuals in attendance: The maternal great-uncle and his wife, Martice I. Hocley and Terry L. Hockley, with their counsel Johnna J. Kopecky, Esquire, and the mother, Tabitha M. Hockley, with her counsel Karl E. Rominger, Esquire. 3. The parties agree to the entry of an Order in the form as attached. Date: ? Q vy- Hubert X. Troy, Esquire Custody nciliator MARTICE I. HOCKLEY and TERRY L. HOCKLEY, Plaintiffs V. TABITHA M. HOCKLEY and, JOSEPH M. STROHECKER, Defendants : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO: 04-669 : IN CUSTODY PRAECIPE TO WITHDRAW APPEARANCE To the Prothonotary: Kindly withdraw my appearance on behalf of the Plaintiffs, Martice I. Hockley and Terry L. Hockley. Date: 10 07 Respe lly subtpifttk? Ro ert J. Dailey ire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Kindly enter my appearance on behalf of the Plaintiffs, Martice I. Hockley and Terry L. Hockley.Date: Respectfully submitted, Date: /0 - Z 3 - tI? Jo a J. Kopec Y, Esquir The Shagin Law Group LLC 300 North Second Street, 8`'' Floor Harrisburg, PA 17101 cv C, ? t " : - = ---t r?? ?: `?? ? r? -.._ T.3 ?:?? ' _?, ? ? ".r ? - : (. _._ w.., C l _ W _ SS `,._l .? ? ?