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HomeMy WebLinkAbout08-3428JESSE E. STRAITIFF, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW :2008 - CIVIL TERM AMANDA J. TRITT, Defendant. : IN CUSTODY COMPLAINT IN CUSTODY AND NOW, comes the Plaintiff, Jesse E. Straitiff, by and through his attorneys, Irwin & McKnight, and files this Complaint in Custody against the Defendant, Amanda J. Tritt, representing as follows: 1. The Plaintiff is Jesse E. Straitiff, an adult individual of 3 Bard Road, Shippensburg, Cumberland County, Pennsylvania 17257 (hereinafter "Father") 2. The Defendant is Amanda J. Tritt, an adult individual residing at 473 East King Street, Shippensburg, Cumberland County, Pennsylvania 17257 (hereinafter "Mother"). 3. The parties are the natural parents of one (1) son named Kamren I. Straitiff, born March 27, 2006, and currently age 2 years. 4. The minor child resides with Mother, another minor child born to Mother and currently age 3 years, and, upon information and belief, Mother's current boyfriend. 5. Mother currently works full-time, and Father currently works part-time. 6. Up until May 2008, Father and paternal grandmother watched the minor child approximately more than one-half of the time each week, primarily when Mother was working. 7. Approximately three (3) weeks ago, Mother unilaterally stopped communicating with Father, and stopped allowing him regular contact with and custody of their minor son. 8. Mother has refused even minimal contact between Father and his son, despite the lack of any Order permitting her to do so. 9. Father desires primary physical custody and joint legal custody of the parties' minor son, Kamren I. Straitiff. 10. The best interests and permanent welfare of the minor child requires that the Court grant the Father's request as set forth above. 11. Father has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 12. Father 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. WHEREFORE, the Plaintiff, Jesse E. Straitiff, respectfully requests that he be awarded primary physical custody and joint legal custody of Kamren I. Straitiff, as provided herein. Respectfully submitted, IRWIN & McKNIGHT By: AA- Douglas Miller, squire Supreme Court I. D. No. 83776 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Attorney for Plaintiff Dated: June 2008 2 N_ ? Q "T7 F7 ? CIS d:; .? ?? ?Ly C. rn w JESSE E. STRAITIFF, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : 2008,1z,g,?2tCIVIL TERM AMANDA J. TRITT, ; Defendant : IN CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: . SS. COUNTY OF CUMBERLAND I, '?' -'`? being sworn according to law, deposes and says that I competent adu er 18 years of age; that I served a copy of the Complaint for Custody upon the Defendant, Amanda J. Tritt, by personally handing her a true and correct copy th o and informing her of its contents at x/73 ?z? r , . S" , on 0 e- -5 at o'clock m. Soli Pn / 513 Lt r 72 -:-7 Deponent further avers that at the time of such service the Defendant identified herself to deponent. Sworn to and subscribed Before q*..this Day of 52008. Noxary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Karen S Noel, M1iot,ry POlic Carlisle BoroCurnba ry ah! County My Commission Expires D,,(;. 8, 2011 Member, Pennsylvania Association of Notaries PJ Pn 4 ? -n m JESSE E. STRAITIFF IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-3428 CIVIL ACTION LAW AMANDA J. TRITT IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, June 10, 2008 , 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 Thursday, July 17, 2008 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. 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 . 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 d 8 ? Z Wd i I Nnr 8002 A8VIQl%&0 ,b-d =,Hi ja n ABOM C& ' K.ITLiLAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 JESSIE E. STRAITIFF, Plaintiff V. AMANDA J. TRITT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 2008-3428 CIVIL ACTION - LAW : IN CUSTODY Please enter my appearance on behalf of the Defendant, Amanda J. Tritt, in the above- captioned matter. ABOM & KUTULAKIS, L.L.P. Date ? q Michelle L. So er, Esquire 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney ID No. 93034 a ? -1b CERTIFICATE OF SERVICE AND NOW, this 9 day of July, 2008, I, Michelle L. Sommer, Esquire of ABOM & KUTULAKIS, LLP, hereby certify that I did serve or cause to be served a true and correct copy of the foregoing Praecipe for Entry of Appearance by First Class U.S. Mail addressed to the following: Douglas G. Miller, Esquire Irwin & McKnight 60 West Pomfret Street Carlisle, PA 17013 "-I- Am mpq MichelL. Somme squire m -c7 ?" c?. ? ? ?, r -+- . . - ? ? _. ? ? ?.,..... a N ?y. ? JUL 2 9 200861 JESSE E. STRAITIFF, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW AMANDA J. TRITT, NO. 2008-3428 Defendant IN CUSTODY COURT ORDER AND NOW, this day of , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The father, Jessee E. Straitiff, and the mother, Amanda J. Tritt, shall enjoy shared legal custody of Kamren I. Straitiff, born March 27, 2006. 2. Physical custody shall be handled as follows: A. On weekends, the parties shall alternate custody of the minor child on the weekends such that the Father has custody on the weekend the Mother has her normal scheduled work and Mother having custody on the weekends that she is not working. For exchange of custody, the time shall be from approximately 7:30 a.m. Saturday morning to approximately 6:00 p.m. Sunday evening when Father is having custody. B. During the weekday, Father shall have custody during the day when Mother is working and not available to provide care for the child. Mother shall have custody for sleeping hours in light of the fact that Dad often is working during the third shift. 3. The parties may modify the custody arrangement as they agree. Absent an agreement, the schedule set forth above shall control. 4. The Conciliator shall conduct a conference call with legal counsel for the parties on Thursday, September 25, 2008, at 8:00 a.m. At that time, the Custody Order shall be reviewed and a determination shall be made if the Order needs to be modified or if the case needs to be scheduled for a hSgingwith the Judge. BY Tf COURT, Judge cc: 4.14 glas G. Miller, Esquire L 0 ichelle L. Sommer, Esquire 4* too 3 i1 Y1 1 1 .c friv n3 { P JESSE E. STRAITIFF, Plaintiff vs. AMANDA J. TRITT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-3428 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: Kamren I. Straitiff, Born March 27, 2006 2. A Conciliation Conference was held on July 17, 2008, with the following individuals in attendance: The mother, Amanda J. Tritt, who appeared with her counsel, Michelle L. Sommer, Esquire, and the father, Jesse E. Straitiff, with his counsel, Douglas G. Miller, Esquire. The parties agreed to an entry of an Order in the form as attached. Date: July c? 9 2008 Hube . Gilroy, Esquire Cus dy Conciliator JESSE E. STRAITIFF, Plaintiff, V. AMANDA J. TRITT, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :2008 - 3428 CIVIL TERM : IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER AND NOW, this oC 1 day of August, 2009, comes the Plaintiff, JESSE E. STRAITIFF, by and through his attorneys, Irwin & McKnight, P.C. and presents the following Petition for Modification of Custody Order, averring as follows: 1. The Plaintiff is Jesse E. Straitiff, an adult individual of 3 Bard Road, Shippensburg, Cumberland County, Pennsylvania 17257 (hereinafter "Father"). 2. The Defendant is Amanda J. Tritt, an adult individual residing at 473 East King Street, Shippensburg, Cumberland County, Pennsylvania 17257 (hereinafter "Mother"). 3. The parties are the natural parents of one (1) son named Kamren I. Straitiff, born March 27, 2006, and currently age 3 years. 4. On August 4, 2008, after an agreement was reached between the parties, an Order of Court was entered in this matter establishing shared legal custody and a physical custody schedule with alternating weekends and a right of first refusal for Father when Mother is working and not available for custody. Said Order is attached hereto and incorporated herein by reference as Exhibit "A." 5. Since the end of the Mother's maternity leave at approximately the end of March 2009, Father has repeatedly requested that Mother provide him with copies of her work schedule to assist in the operation of his right of first refusal. 1 6. Mother has consistently failed to provide regular copies of her work schedule, and has frequently allowed unrelated third parties to provide care without first contacting the Father. 7. Mother has also been negligent in updating Father as to changes in her work schedule in order to facilitate Father having custody of the child while Mother is working. 8. Upon information and belief, Mother's work schedule has increased, thereby decreasing the time she has available for the care of the minor child. 9. Father is currently unemployed due to medical issues with his back that prevented him from performing the rigorous job responsibilities at his last employment. 10. Father therefore has more time available to care for his son until he secures new employment. 11. Father desires shared physical custody and joint legal custody of the parties' minor son, Kamren I. Straitiff. 12. Father further desires a formal document outlining the custody schedule between the parties during holidays. 13. The best interests and permanent welfare of the minor child requires that the Court grant the Father's request as set forth above. 14. Father has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 15. Father does not know of a person not a parry to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 16. Due to the nature of the Petition, it is anticipated that opposing counsel will not concur in the requested modification, and therefore the concurrence of opposing counsel in the filing of this Petition has not been requested. 17. Judge Edward E. Guido signed the previous Order in this matter. 2 WHEREFORE, Defendant respectfully seeks the entry of an Order of Court granting Defendant's Petition for Modification of Custody Order. Dated: August 24, 2009 By: Preme 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Attorney for Plaintiff, Jesse E. Straitiff Respectfully submitted, IRWIN & McKNIGHT, P.C. D as Miller, Esquire Su ourt I.D. No. 83776 3 VERIFICATION The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. J . STRAITIFF Date: e` -04-09 EXHIBIT "A" I? 1 t. JUL 2 9LU08(, 1 JESSE E. STRAITIFF, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW RECEIVED AMANDA J. TRITT, : NO. 2008-3428 Defendant IN CUSTODY rAUG 0 6 2008 IR M & MMIM COURT ORDER LAW AND NOW, this y _ day of ?, 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The father, Jessee E. Straitiff, and the mother, Amanda J. Tritt, shall enjoy shared legal custody of Kamren I. Straitiff, born March 27, 2006. 2. Physical custody, shall be handled as follows: -- A. On weekends, the parties shall alternate custody of the minor child on the weekends such that the Father has custody on the weekend the Mother has her normal scheduled work and Mother having custody on the weekends that she is not working. For exchange of custody, the time shall be from approximately 7:30 a.m. Saturday morning to approximately 6:00 p.m. Sunday evening when Father is having custody, B. During the weekday, Father shall have custody during the day when Mother is working and not available to provide care for the child. Mother shall have custody for sleeping hours in light of the fact that Dad often is working during the third shift. 3. The parties may modify the custody arrangement as they agree. Absent an agreement, the schedule set forth above shall control. 4. The Conciliator shall conduct a conference call with legal counsel for the parties on Thursday, September 25, 2008, at 8:00 a.m. At that time, the Custody Order shall be reviewed and a determination shall be made if the Order needs to be modified or if the case needs to be scheduled for a he_,?with the Judge. .T, cc: Douglas G. Miller, Esquire Michelle L. Sommer, Esquire TRUE _ , u?. ,, ?,I.. - ;,CRbdge n. ,r In Test1moriv _ t my hand an a S91 of ;a Aisle, Pe. T ...... ..... da-y of.......... s, 3 d R JESSE E. STRAITIFF, Plaintiff vs. AMANDA J. TRITT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2008-3428 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: Kamren I. Straitiff, Born March 27, 2006 2. A Conciliation Conference was held on July 17, 2008, with the following individuals in attendance: The mother, Amanda J. Tritt, who appeared with her counsel, Michelle L. Sommer, Esquire, and the father, Jesse E. Straitiff, with his counsel, Douglas G. Miller, Esquire. 3. The parties agreed to an entry of an Order in the form as attached. Date: July '2008 HGilroy , Esquire onciliator CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the persons indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: MICHELLE L. SOMMER, ESQUIRE ABOM & KUTULAKIS, LLP 36 SOUTH HANOVER STREET CARLISLE, PA 17013 Date: August 24, 2009 IRWIN & McKNIGHT, P.C. h.Aj& Do glas . W er, E quire Supreme Iourt I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Attorney for Plaintiff Jesse E. Straitiff ?i?+? ol?/?Uy7 JESSE E. STRAITIFF IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-3428 CIVIL ACTION LAW AMANDA J. TRITT IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, August 31, 2009 , 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 Count Courthouse, Carlisle on Friday, October 02, 2009 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. 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 . 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 ,- 2009 AG 3 E Pi 3: 43 fr ???. os 510 ?,.? Z ? c?"n?er ?,?/ •09' ?°?1 ?-ceb' -mss.. 15` ? o J JESSE E. STRAITIFF, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW AMANDA J. TRITT, NO. 2008-3428 Defendant IN CUSTODY COURT ORDER AND NOW, this 1 44 o day of October, 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: l . A hearing is scheduled in Courtroom No. 3 of the Cumberland County Courthouse 4p?_ day of , 2009, at (' 3d 01. in. At this hearing, the Father shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a Memorandum setting forth the history of custody in this case, the issues currently before the Court, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This Memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, the existing Court Order from August 4, 2008, shall remain in place. BY THE , / Edward E. Guido, Judge cc: ouglas G. Miller, Esquire Michelle L. Sommer, Esquire P L i-ps met t LL JESSE E. STRAITIFF, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW AMANDA J. TRITT, NO. 2008-3428 Defendant IN CUSTODY Prior Judge: The Honorable Edward E. Guido CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the child who is the subject of this litigation is as follows: Kamren I. Straitiff, born March 27, 2006. 2. A Conciliation Conference was held on October 9, 2009, with the following individuals in attendance: The father, Jesse E. Straitiff, was not in attendance but was represented by Douglas G. Miller, Esquire. The mother, Amanda J. Tritt, appeared with her counsel, Michelle L. Sommer, Esquire. 3. The parties have an existing Custody Order from August of 2008. Father is now seeking primary physical custody because he is off work and feels he can provide care for the child and for other reasons. Mother is unwilling to modify the Order and suggests that there is a laundry list of issues involving the Father that would indicate that he should not have primary custody. 4. A hearing is required in this case and the Conciliator recommends an Order in the form as attached. Date: October I l , 2009 Hubert X. ilroy, Esquire Custody onciliator RLED-C I,Dlc T!',E P;- ,':,`,.NARY 2009 OCT 15 A 11: 03 ABOM CS2' &UTLILAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 JESSE E. STRAITIFF, Plaintiff V. AMANDA J. TRITT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : 2008-3428 CIVIL ACTION - LAW IN CUSTODY MOTION FOR CONTINUANCE AND NOW comes the within, Amanda J. Tritt, Defendant, by and through her counsel, Michelle L. Sommer, Esquire of Abom & Kutulakis, L.L.P., and avers the following: 1. A Custody Hearing is scheduled for December 16, 2009 at 9:30 a.m. 2. Defendant's counsel asks for a continuance due to the fact that the Defendant has been communicating with the Plaintiff since the Conciliation Conference that was held on October 2, 2009, and she would like to request more time in the hopes the parties will be able to come to a resolution and enter into an Agreement and Stipulation regarding custody of their minor child. Defendant's counsel has contacted Plaintiff's counsel, Douglas G. Miller, Esquire, regarding this request for a continuance, and he does not concur with the filing of this Motion. WHEREFORE, Plaintiffs counsel requests your Honorable Court to make an Order approving the continuance of the Custody Hearing on December 16, 2009 at 9:30 a.m. ABOM & KUTULAKIS, L.L.P. Date (424(0 Michelle L. Sommer,,squire 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney ID No. 93034 a I CERTIFICATE OF SERVICE AND NOW, this 2nd day of December, 2009, I, Deborah L. Ryan of Abom & Kutulakis, L.L.P., hereby certify that I did serve a true and correct copy of the foregoing Motion for Continuance on the Douglas G. Miller, Esquire, Attorney for Plaintiff via Certified U.S. mail, First Class, postage prepaid, addressed as follows: Douglas G. Miller, Esquire Irwin & McKnight 60 West Pomfret Street Carlisle, PA 17013 Deborah L. Ryan Y 2 0019 0LEC -2 Fs=E 3: 5J JESSE E. STRAITIFF, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : 2008-3428 CIVIL ACTION - LAW AMANDA J. TRITT, Defendant IN CUSTODY 3 ORDER OF COURT AND, NOW this -? day of DG--'"-_ `, 2009, the Custody Hearing scheduled for December 16, 2009 at 9:30 a.m. is hereby continued until b ?- C . ;(A , oga at _ 3 = a j .m. By the Co Edward E. Guido, Judge. DISTRIBUTION: D uglas G. Miller, Esquire, For the Plaintiff 4chelle L. Sommer, Esquire, For the Defendant (20p t LL S' ? l??181v? RLUH-X OF TW THCOd Y 2009 DEC -8 AK 11: 4 7 P V Y "i L.YrU UC JESSE E. STRAITIFF, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW :2008- 3428 CIVIL TERM AMANDA J. TRITT, . Defendant : IN CUSTODY ORDER OF COURT AND NOW, this Ij day of , 2009, upon presentation and consideration of the attached stipulation and agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. BY COUR JUDGE EDWARD E. GUIDO 1 -F r it IA i i 2099 DEC 22 PM 3: 2 4 ?Wo,--4q1Y g /44y I. , I&a- ,944lt M. JESSE E. STRAITIFF, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYflb,VAlNIk- v. (r i ._: 2s+ : CIVIL ACTION - LAW s : 2008 - 3428 CIVIL TERM AMANDA J. TRITT, N Defendant : IN CUSTODY PETITION FOR SPECIAL RELIEF AND NOW, this 2nd day of August, 2011, comes the Plaintiff/Petitioner, Jesse E. Straitiff, by and through his attorneys, Irwin & McKnight, P.C., and pursuant to Rule 1915.4(e) makes the following Petition for Special Relief against the Defendant/Respondent, Amanda J. Tritt, averring as follows: 1. Petitioner is Jesse E. Straitiff, an adult individual who resides at 3 Bard Road, Shippensburg, Pennsylvania 17257. 2. Respondent is Amanda J. Tritt, an adult individual who currently resides at 473 East King Street, Shippensburg, Cumberland County, Pennsylvania 17257. 3. Petitioner and Respondent are the natural parents of Kamren I. Straitiff, born March 27, 2006. 4. A custody order was entered on December 22, 2009, pursuant to an agreement of the parties for shared legal custody and shared physical custody of the child on a week on week off basis. A true and correct copy of the Agreement signed by the parties is attached hereto and incorporated herein as Exhibit "A." 5. The parties' minor child is now of school age and to enter Kindergarten in the fall of this upcoming school year. 6. Petitioner would like to enroll the minor child in a private, parochial school for the upcoming school year. '711-06 Pee , -1-14 71? D 7. Petitioner, with the assistance of his family, is willing to incur the full cost of tuition for such a school, as well as be fully responsible for transportation, ensuring that the child is transported to and from such a school. 8. One such school option available to Petitioner is the Adams County Christian Academy, where Petitioner's stepfather has worked for many years and where the minor child would be eligible to receive a reduced rate on tuition. 9. Petitioner is also in the process of researching and investigating other private, parochial schools, in the Carlisle, Shippensburg, and Chambersburg area. 10. Petitioner also desires to enroll the minor child with a licensed counselor for assistance in dealing with the separation of the parties and the child's upcoming school enrollment. 11. Petitioner would also be fully responsible for the costs of such a licensed counselor. 12. Respondent has resisted the Petitioner's requests to enroll the minor child in a private school, but has previously expressed willingness if she does not incur any tuition expense for such an enrollment. 13. Petitioner believes that the best interests and permanent welfare of the minor child requires that the Court grant the Petitioner's special relief request as set forth herein. 14. The undersigned has contacted Respondent's legal counsel of record in this matter regarding the instant Petition, but she has been unable to reach Respondent. 15. The Honorable Edward E. Guido signed the last order in this matter entered on December 22, 2009. WHEREFORE, the Petitioner, Jesse E. Straitiff, respectfully requests this Honorable Court to enter an Order indicating that Kamren I. Straitiff, shall be enrolled and attend a private parochial school, with Petitioner being responsible for the tuition expenses and transportation for 2 said school, and that Kamren I. Straitiff also be permitted to attend sessions with a licensed counselor at the sole expense of the Petitioner. Respectfully submitted, IRWIN & McKNIGHT, P.C. By: 4??' h06 A Douglas G. filler, Esquire Supreme Court I.D. No: 83776 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 717-249-2353 Attorney for Plaintiff / Petitioner Date: August 2, 2011 VERIFICATION The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. JE E. STRAITIF Date: August 2, 2011 JESSE E. STRAITIFF, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : 2008- 3428 CIVIL TERM AMANDA J. TRITT, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this Z-day of , 2009, upon presentation and consideration of the attached stipulation and agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. BY THE COURT, z lu'wa7 &-r9.1Fj'?vE'-DWtkRD E. GUIDO in Testimoll andfi,he my hand sea! of said ;:;,u ' t rariislr, Pa. This P thon®tmy. JESSE E. STRAITIFF, Plaintiff, V. AMANDA J. TRITT, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :2008- 3428 CIVIL TERM IN CUSTODY STIPULATION AND AGREEMENT THIS STIPULATION AND AGREEMENT entered into this ?Hl day of Tq",-r , 2009, by and between JESSE E. STRAITIFF (hereinafter referred to as "Father"), and AMANDA J. TRITT (hereinafter referred to as "Mother"). WHEREAS, Father and Mother are the natural parents of Kamren I. Straitiff, born March 27, 2006 (currently age 3); and WHEREAS, Father and Mother desire to enter into a comprehensive custody stipulation and agreement, modifying any prior agreements and setting forth the physical and legal custody arrangements for their minor child, to be in effect hereafter and until altered by subsequent Order of Court; and WHEREAS, Father and Mother desire to confirm their agreement relative to custody of the minor children and execute a Stipulation and Agreement to effect the same. NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: 1. The parties shall have shared legal custody of Kamren I. Straitiff. All non- emergency decisions affecting the child's growth and development shall be considered major decisions and shall be made by the parents jointly, after discussion and consultation with each other, and with a view towards obtaining and following the child's best interests which decisions shall include, but not limited to: choice of camp, if any; medical treatment, specifically including any medications prescribed for the children; dental treatment; education; scholastic or athletic pursuits; and other extracurricular activities. 2. Pursuant to the terms of 23 Pa.C.S. § 5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious, or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher, or other authority as well as copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records, report cards, and medical insurance cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to- school nights, and the like. 2 3. The parties shall have shared physical custody of Kamren I. Straitiff on alternating weeks according to the following schedule: a. Mother shall have physical custody of Kamren I. Straitiff on the first week until Friday after work at 6:00 p.m.; and b. Father shall have physical custody of Kamren I. Straitiff on the next week until the following Friday at 6:00 p.m. In addition, Mother may have custody of the minor child on one (1) of her days off from work from 9:00 a.m. until 5:00 p.m., with at least twenty-four (24) hour advance notice to and consent from Father, which consent shall not be unreasonably withheld. For Mother's period of custody on her day off from work, Mother shall provide all transportation unless otherwise agreed by both parties; C. The parties shall have the option of using non-family member babysitters agreed to in advance by both parties, but each party shall first offer the other parent physical custody of the minor child during times when the parent in custody is working and not available to provide care for the child. Neither parent shall use a non-family member babysitter objected to by the other parent. 4. In addition to the times of custody above, all holidays shall be shared as is mutually agreed upon in advance by the parties and in accordance to the following schedule: a. Father shall have custody on Christmas Eve for his annual family dinner. Christmas shall then be divided into two Blocks. Block A shall be from 8:00 p.m. Christmas Eve to Christmas Day at 1:00p.m. Block B shall be from Christmas Day at 1:00 p.m. until December 26 at 12:00 p.m. Mother shall have physical custody of the child for Block A in odd numbered years and Block B in even numbered years and Father 3 shall have physical custody of the child for Block B in odd numbered years and Block A in even numbered years; b. In the event that Thanksgiving falls during the week that Mother has custody, Father shall have custody of the minor child on Thanksgiving Day from 9:00 a.m until 4:00 p.m., so that Father will have custody of the child on every Thanksgiving Day at such times. In the event that Thanksgiving falls during the week that Father has custody, Mother shall have custody of the minor child on Thanksgiving Day from 4:00 p.m. until Black Friday at 1:00 p.m., so that Mother will have custody of the child after 4:00 p.m. on every Thanksgiving Day; C. The parties shall alternate custody of the minor child for the holidays of New Year's Day, Easter, Memorial Day, July 4t', and Labor Day, from 9:00 a.m until 5:00 p.m. on each day. Mother shall have custody of the child on New Year's Day 2010, and the parties shall thereafter alternate each of the above listed holidays so that Father would then have custody of the child on Easter, and so on; d. Mother shall have custody of the child every year on Mother's Day from 9:00 a.m. until 5:00 p.m., and Father shall have custody of the child every year on Father's Day from 9:00 a.m. until 5:00 p.m.; e. The parties shall also endeavor to ensure that each parent spends time with the child on his birthday; f. The parties may also schedule a seven (7) day vacation one (1) time during each year when they shall have physical custody of the minor child. Each party shall provide notice of the anticipated vacation week at least thirty (30) days in advance, 4 and shall endeavor to ensure as much as possible the lease interruption in the other parent's periods of physical custody. 5. The parties also acknowledge that Father's sister has been taking the child to church on Sunday mornings, and upon seeking advance permission from the parent in physical custody, may transport Kamren to and from church. 6. Transportation for each party's periods of physical custody shall be provided by the person picking up Kamren, and shall be at the respective residence of each party. The parties may substitute a family member to provide the transportation for the minor child at the date and times for transfer of custody specified herein. 7. The parties will keep each other advised immediately relative to any emergencies concerning the minor child and shall, further, take any necessary steps to ensure that the health and well being of the child is protected. These steps shall include providing a safe, secure, and clean home environment during their respective periods of custody, and ensuring that the child has adequate meals and nutrition. During any illness or medical emergency, each party shall have the right to visit the child as often as he or she deems consistent with the proper medical care of the child. 8. The parties agree that there shall be reasonable telephone contact with the child during the periods when the child is not in the custody of that party. 9. Neither party shall do anything that may estrange the child from the other party, or injure the opinion of the child as to the other party, or may hamper the free and natural development of the child's love or affection for the other party. 5 10. Neither party shall schedule activities or appointments for the child which would require their attendance or participation at said activity or appointment during a time when he is scheduled to be in the physical custody of the other parent without that parent's express prior approval. 11. It shall be the obligation of each parent to make the child available to the other in accordance with the physical custody schedule and to encourage them to participate in the plan hereby agreed and ordered. 12. Neither party shall remove the child from the Commonwealth of Pennsylvania except for vacations when said party has custody of the minor child as provided herein. Each parent agrees to inform the other parent if he or she desires to remove the child overnight from the Commonwealth of Pennsylvania by providing notice at least ten (10) calendar days prior to the anticipated date of departure. In such an instance, the party who desires to remove the child, shall provide the other parent with a general schedule of the planned vacation and its location or locations, along with a telephone number or numbers, including area code, where the child may be reached. 13. The parties desire that this Stipulation and Agreement be made an Order of Court by the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the parties' minor child, and shall retain such jurisdiction should circumstances change and either party desires or requires modification of said Order. 14. The parties may temporarily alter the schedule of physical custody as is mutually agreeable in order to accommodate special family events or other changes in their schedule. If 6 the parties cannot agree on any such changes, the terms and provisions of this Order shall control. 15. Any permanent modification or waiver of the provisions of this agreement must be in writing and shall be effective only if made in writing and executed with the same formality as this Stipulation and Agreement. 16. The parties acknowledge that entering into this Stipulation and Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of either party. 17. The parties acknowledge that they have read and understand the provisions of this Stipulation and Agreement. Each party acknowledges that the Stipulation and Agreement is fair and equitable and that it is not the result of duress or undue influence. [THE REMAINDER OF THIS PAGE HGAS BEEN INTENTIONALLY LEFT BLANK] 7 IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms hereof, set forth their hands and seals the day and year first above written. WITNESS: 's 1-1 -V1M -M4 AMANDA J. TRITT CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, hereby certify that a copy of attached Petition for Special Relief was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: MICHELLE L. SOMMER, ESQUIRE ABOM & KUTULAKIS, LLP 2 WEST HIGH STREET CARLISLE, PA 17013 (Counsel of record for Defendant) IRWIN & McKNIGHT, P.C. Ojik Douglas Miller, Esquire Supreme Court I.D. No. 83776 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Attorney for Petitioner Date: August 2, 2011 a JESSE E. STRAITIFF, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. a..' AMANDA J. TRITT, NO. 2008 - 3428 CIVIL TERM r-- Defendant ?' CD 1 ORDER OF COURT .7 cn AND NOW, this 5TH day of AUGUST, 2011, a hearing on the Petition for Special Relief is scheduled for THURSDAY AUGUST 25 2011 at 11:00 a.m. in Courtroom 3. B .lie Court, Edward E. Guido, J. 'Douglas G. Miller, Esquire / Michelle L. Sommer, Esquire (?i6a *161 8/5,/t/ 00 :sld JESSE E. STRAITIFF, Plaintiff, V. AMANDA J. TRITT, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2008 - 3428 CIVIL TERM IN CUSTODY _ c.7 r-- r- :v i ` cal cy = C Ca x' n r) -rs D C., r,-, G Straitiff,l?y a MOTION FOR WITHDRAWAL OF PETITION FOR SPECIAL RELIEF AND NOW, this 25 h day of August, 2011, comes the Plaintiff, Jesse E through his attorneys, Irwin & McKnight, P.C., and make the following Motion for Withdrawal of Petition for Special Relief, averring as follows: 1. The above-captioned matter is scheduled for a hearing on Thursday, August 25, 2011, at 11:00 am before the Honorable Edward E. Guido. 2. The parties in this matter have reached an Agreement with regard to the issues of the minor child's school attendance and related issues involved. 3. Both parties have signed the Agreement before a notary and the Agreement is attached hereto and made a part hereof as Exhibit "A". 4. As a result, the hearing currently scheduled in this matter can be cancelled. 5. Defendant's attorney, Michelle L. Sommer, has been advised of this Motion and has no objections. WHEREFORE, it is respectfully requested that the hearing scheduled for August 25, 2011 at 11:00 am be cancelled. Date: August 25, 2011 Respectfully submitted, IRWIN & McKNIGHT, P.C. VV, By: Dou as C?fililler, Esquire Supreme Court I.D. No: 83776 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 717-249-2353 Attorney for Plaintiff EXHIBIT "A" LAW OFFICES IRON & McKNIGHT, P. C. WEST POMFRET PROFESSIONAL BUILDING 60 WEST POMFRET STREET HAROLD S. IRWIN (1925-1977) ROGER B. IRWIN CARLISLE, PENNSYLVANIA 17013-3222 HAROLD S. IRWIN, JR. (1954-1986) MARCUSA. McKNIGHT, III IRWIN, IRRM & IRWIN (1956-1986) DOUGLAS G. MILLER (717) 249-2353 IRWIN, IRWIN & McKNIGHT (1986-1994) STEPHEN L. BLOOM FAX (717) 249-6354 IRWIN, McKNIGHT & HUGHES (1994-2003) MATTHEW A. McKNIGHT WWW IRWINMCKNIGHT.COM /RWIN & McKNIGHT (2003-2008) On this the a ?? day of August, 2011, we, Jesse E. Straitiff and Amanda J. Tritt, agree that our son, Kamren I. Straitiff, will be enrolled in Shalom Christian School in Chambersburg, Pennsylvania. We agree that Kamren will attend Shalom Christian School and be able to participate in school events and programs, including but not limited to, extra-curricular events and activities, tutoring and counseling. Transportation to and from school will be provided by either Jesse Straitiff, Lisa Frampton or Roy Frampton. This is an amendment to the custody agreement dated December 22, 2009. IAN cudrx '.) - - iw A ANDA J. TRITT i SE E. STRAIT J MONWEALTH OF PENNSYLVAN NOTARIAL SEAL_ PAMELA A. SWITALSKI, Noary Public Boro of Shippensburg, Cumiuarland County My Commission Expires March 24, 2014 JESSE E. STRAITIFF, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : 2008 - 3428 CIVIL TERM AMANDA J. TRITT, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, hereby certify that a copy of attached document was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Michelle L. Sommer, Esquire Abom & Kutulakis, LLP 2 West High Street Carlisle, PA 17013 IRWIN & McKNIGHT, P.C. Douglas G. Miller, Esquire Supreme Court I.D. No. 83776 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Date: August 25, 2011 3 A JESSE E. STRAITIFF, Plaintiff, V. AMANDA J. TRITT, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2008 - 3428 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this day of Auoa$', 2011, upon consideration of the attached Motion for Withdrawal of the Petition for Special Relief filed on behalf of the Plaintiff and the signed agreement of the parties, the Motion is granted. BY THE THE cc: ? Douglas G. Miller, Esquire (for Plaintiff) Michelle L. Sommer, Esquire (for Defendant) EDWARD E. GUIDO C am (In rn 5;;Q M _0 ' r? cnr- i CD =C) W es" .7 1- V i i JESSE E. STRAITIFF, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANA V 2008-3428 CIVIL ACTION - LAW . Yy AMANDA J. TRITT Defendant IN CUSTODY AND NOW, this eday of October, 2011, upon Motion of Michelle L. Sommer, Esquire, a Rule is hereby issued upon the parties to show cause why the Petitioner should not be permitted to withdraw as counsel for Defendant, Amanda J. Tritt. Rule returnable A days after the date of service of this Order. Service to be by certified mail upon Amanda J. Tritt and regular first-class mail upon Douglas G. Miller, Esquire, counsel for Plaintiff, Jesse E. Straitiff. E C RT: J. Distribution: f ? Michelle L. Sommer, Esquire Douglas G. Miller, Esquire P lo'?lit bl6 3 Mom r il.Et~-flFFiCt *~17 I }{E PROTNONO iAR,f uTUL)kKls illichel4l. Sommer, F:ryuire 2~~; ~ 5 P~ ~ • AlGarnny 1. D. No.: 93034 [7ERLAND COUNTY 2 Ix'e.rt HidhStreet CUMp cur§sk, Pennylrun,u 17013 pENhlSYLVANIQ (71,7) 249-0900 JESSE E. STRAITIFF, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : 2008-3428 CIVIL ACTION - LAW AMANDA J. TRITT, . Defendant : IN CUSTODY MOTION TO MAKE RULE ABSOLUTE AND NOW, this 15`h day of November, 2011, comes Petitioner, Michelle L. Sommer, Esquire, of Abom & Kutulakis, L.L.P., who respectfully avers the following: 1. On October 17, 2011, Petitioner filed a Motion to Withdraw as Counsel in the above-captioned matter. 2. A Rule to Show Cause was issued on October 19, 2011, upon the Respondents to show why the Petitioner should not be permitted to withdraw as counsel for Defendant, Amanda J. Tritt. 3. On October 24, 2011, a copy of Order of Court was sent to Defendant, Amanda J. Tritt, by certified mail, return receipt requested. . • 4. On October 24, 2011, a copy of the Order of Court was sent to PlaintifPs Attorney, Douglas G. Miller by regular mail. 5. The United States Post Office left notice for defendant Amanda Tritt on October 26, 2011, a copy of the Track and Confirm report from the USPS.com website is Attached hereto marked Exhibit "A". 6. The Certified Mail that was sent to Plaintiff was returned to Plaintiff's Attorney on November 14, 2011 marked "Retum to Sender, Unclaimed, Unable to Forward", a copy of the envelope is attached hereto as Exhibit "B". 7. More than twenty days have elapsed and neither Pla.inti.fPs counsel nor the Defendant has filed a response to the Order of Court with the Rule to Show Cause. WHEREFORE, undersigned counsel respectfully requests this Honorable Court grant her request to withdraw as counsel in this ma.tter. Respectfully submitted, .A.BOM & KUTULAKIS, L.L.P. Date Michelle L. Somm , Esquire Attorney I.D. No. 93034 2 West High Street Caxlisle, PA 17013 (717) 249-0900 i CERTIFICATE OF SERVICE AND NOW, this 15`h day of November, 2011, I, Michelle L. Sommer, Esquire, of Abom & Kutulaki.c, LLP., hereby certify that I did serve a true and correct copy of the foregoing Motion to Make Rule Absolute addressed to the following: Via Certifed Mail - Return Recelpt Reguested.• Amanda J. Tritt 437 East King Street Shippensburg, PA 17257 Via Regular Mail.• Douglas G. Miller, Esquire Irwin & McKnight 60 West Pomfret Street Carlisle, PA 17013 Attorney for the Plaintz~ Respectfully submitted, AsoNr & KuTUZmws, L.L.P. , Michelle L. So er, Esquire Supreme Court ID No. 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 USPS.comOO - Track & Confirm Page 1 of 1 Engiish Customer Service USPS Mobile Register i Sign In AgVSl w/•CO J?3fCh USPS T„' ?fp k f dGM(Fia°S Ouicic `nols Ship a Packaye Send Mail Mana,ye Your hAai( Shiop 6usi;iess Solutians Track & Confirm IGETFMAILI{PUA;11:$ PRINTDGTAI;.S YvUF LABEL. NUtAftER SERVICE STATUS OF YUUR {TEM DATE n TIME LOCATIDN FEATURES 70100280000064715251 Notice Left October 26, 2011, 2:10 pm SHIPPENSBURG, PA 17257 Certified Mail" -usps.mm/redelivery or calling 806-ASK- USPS. or may pick up the item at the Post Office indicated on the notlce. If this kem is unUaimed efler 15 days then it will6e returned to the seMer. Informatbn, if available, is uptlated penodtcally ihroughout the day. Please . check again later."> Processedthrough Oclober25, 2011, 1131 pm HARRISBURG. PA 17107 USPS Sort Facility Check on Another Item WhaCs your label (or receipt) number? Find LEGAI ON USPS.COPA ON ABOUT.USPS.COM OTHER USPS SITES Pn,acy ~oliry Gavernmeni Sen-ice5> .4Gou; USPS Home ; Busl.ness GusEOmer 9atew.ay • 7erms cf U^e ~ Euy S;amps & Shop News; oom Wa,tal Inspectors ?vIk Pnnt a Label with Postage > MaU Service Updates ~ i;upecto! Ger,eral , rEAR: Aci E-C+ Da4> > Custo;ner Sewice ; Korms & Pubiicatians ; Pos?al Explorer Sita !ndex > Careers > ;.:opYrigh"1.:Z91 i iiSPS ki, Rirh?s Rese€ver.. EEXIHIBIT A https://tools.usps.com/go/TraclcConfirmAction.action 11/9/2011 n > I A r N I~ "f7 ~ 1 z 2 ~ O Z ~ ~ o ~ W v~ ~ a ~ o - o ~ ~ ; C3 p'} O ~ - 0 _ ...1 E3 I:at ~ P••j L' ~ f~r a u, h& cn CA p N ~ ~I? Cr , R~ 0 j~ ~ rD rb f] H ) - ^ ~ H -1 ' N C ;fl = 0 Z ~mi Y ~ - ~i °,@ C C (A o rx;o ta m ~ z tn -;m-4 m r4w~~ ~ _ OHO , , ~ ~mv~ - ~ ~°z . - ~u m m - CD 0 4 ~ :-s _ ' ' :EX;HIBIT . r JESSE E. STRAITIFF, Plaintiff V. AMANDA J. TRITT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 2008-3428 CIVIL ACTION - LAW : IN CUSTODY r'rj == r-- ::UM <> w C° C =s AC - . - r AND NOW, this ;0day of ?)fe4d)m, 2011, upon consideration of the within Motion to Make Rule Absolute, said Motion is hereby GRANTED, Michelle L. Sommer, Esquire and Abom & Kutulakis, L.L.P., are hereby granted leave to Withdraw as Counsel for the above-named Defendant, Amanda J. Tritt. BY THE COURT:., J? Distribution: Ai Imo`" ? chelle L. Sommer, Esquire C?P?? M 11 Douglas G. Miller, Esquire 3