HomeMy WebLinkAbout04-1244BRENDA KLrNKLEMAN
and CHARLES KUNKLEMAN,
Plaintiffs
LISA K. KELLEY
and ALAN R. OTT,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. c9~/- /z
IN CUSTODY
CIVIL TERM
COMPLAINT FOR CUSTODY
Plaintiffs are Brenda Kunkleman and Charles Kunkleman, adult individuals curremly
residing at 350 Strohm Road, Shippensburg, Cumberland County, Pennsylvania.
Defendant, Alan R. Ott, is an adult individual currently incarcerated at the Franklin
County Prison.
Defendant, Lisa K. Kelly, is an adult individual whose current whereabouts are
unknown.
Plaintiffs are the maternal grandparents of two children, namely, Emily E. Ott, bom
February 24, 1992, and Erika K. Ott, bom August 2, 1994.
For the past five (5) years, or since the children's birth, the children have resided with
the following persons at the following addresses for the following periods of time:
NAME
Brenda Kunkleman
Charles Kunkleman
Lisa Kelley
Glenn Kelly
ADDRESS
350 Strohm Road
Shippensburg, PA
Upper Strasburg, PA
DATES
July, 2001-present
May 1999~July 2001
10.
NAME
Brenda Kunkleman
Charles Kunkleman
Lisa Kelley
Alan Ott
Brenda Km~kleman
Charles Kunkleman
ADDRESS
350 Strohm Road
Shippensburg, PA
728 Mains Run Road
350 Strohm Road
Shippensburg, PA
DATES
November 1997- May 1999
Sept. 1997-Nov. 1997
July, 1997-September 1997
The natural mother of the children is Lisa K. Kelley whose whereabouts are
unknown. She is believed to be married.
The natural father of the children is Alan R. Ott who resides as aforesaid. He is
unmarried.
The relationship of the Plaintiffs to the children is that of maternal grandparents. The
Plaintiffs currently reside alone with the children.
The relationship of the Defendant, Lisa K. Kelley, to the children is that of natural
mother. It is unknown who Defendant, Lisa K. Kelley currently resides with.
The relationship of Defendant, Alan R. Ott, to the child is that of natural father.
Defendant, Alan R. Ott, is currently incarcerated in the Franklin County Prison.
Plaintiffs have not participated as a party or witness, or in any other capacity in other
litigation, concerning custody of the children.
Plaintiffs are aware that there was a prior custody action between the Defendants in
Cumberland County Court of Common Pleas, by which a Custody Order was entered
11.
12.
January 20, 1998. This action was captioned 97-6183. A copy of the 1998 Court
Order is attached hereto and incorporated herein by reference as Exhibit "A."
Plaintiffs are unaware of any custody proceedings, other than mentioned in paragraph
10, concerning the children pending in any Court of this Commonwealth.
It is in the best interest and permanent welfare of the children to grant the relief
requested because:
a)
Plaintiffs have been and continue to be the primary custodians for the children
from July 2001 through present;
b)
Defendant, Alan R. Ott, has shown an inability to provide for the financial,
physical, or emotional needs of the children. Defendant, Alan R. Ott, last had
contact with the children for a one (1) hour visit in July of 2003 while on work
release from prison;
e)
Defendant, Alan R. Ott, has demonstrated a lack of interest in the children
through his limited contact and absence of affection. Defendant, Alan R. Ott,
has, in the past, gone several years without having any contact with the children;
Defendant, Lisa K. Kelley, has shown an inability to provide for the financial,
physical, or emotional needs of the children;
e)
Defendant, Lisa K. Kelley, has an extensive drug and alcohol problem for which
she refuses to seek treatment. Defendant, Lisa K. Kelley, will disappear for
months at a time without having any contact with the children;
t)
Plaintiffs have provided substantial support and custodianship to the children
since their birth. The children view Plaintiffs as their primary caretakers;
Plaintiffs would be able to add the children to their insurance if they are granted
legal and physical custody. The children are currently without health insurance
and Plaintiffs have been paying all medical costs out of their own pockets as
both parents provide no financial support.
10.
Plaintiffs do not know any person not a party to these proceedings who claim to have
custody or visitation rights with respect to the children.
WHEREFORE, Plaintiffs request your Honorable Court to schedule Custody
Conciliation Conference followed by a hearing at which time they should be granted legal and
physical custody of the children.
Respectfully submitted,
Brian C. Bomman, Esquire
Attorney for Plaintiffs
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4904, relating to unsworn falsifications to authorities.
BRENDA KUNKLEMAN, Plaintiff
LISA K. KUNKLEMAN,
Plaintiff
V
ALAN R.
Defendant
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:CIVIL ACTION - LAW
:NO: 97-6183 CIVIL TERM
:IN CUSTODY
COURT ORDER
AND NOW, this ~6~day of January, 1998.. u~on consideration of
the attached Custody Conciliation Report, it is ordered and
directed as follows:
The Mother, Lisa K. Kunkleman, and the Father, Alan R. Ott,
shall enjoy shared legal custody of ~nily E. Ott, born
February 24, 1992; and Erika K. Ott, born August 2, 1994.
The Mother shall enjoy primary physical custody with the minor
children.
The Father shall enjoy periods of temporary physical custody
with ~ '
=~Je minor children as follows:
On alternating weekends from Friday at 6:00 p.m. until
Sunday at 6:00 p.m.
Be
On holidays pursuant to a schedule arranged between the
parties.
C. At such other times as the parties may agree.
The Father shall not be under the influence of any illegal
drugs when he has custody of ~ ~i~o~ ~ ~ ~'-~ ......
the Father shall not be under the influence of alcohol when he
has any requirement to drive the children·
Bother parties shall enjoy reasonable telephone contact with
the minor children when the children are in the custody of the
other parent.
EXHIBIT
This Order is entered pursuant to an agreement reached by the
parties at a Custody Conciliation Conference. In the event
either party desires to modify this agreement, that party may
petition the Court to have the case again scheduled with the
Custody Conciliator for a conference.
BY THE COURT,
Sally J. Winder, Esquire
Alan R. Ott
728 Mains Run Road
Shippensburg, PA 17257
In 't'e?,'~ir~s,'~rv whereof, I h~re unlo set my hand
and the s~al of sa~d Court at ~arlisle, Pa.
This .,~.~.~.. day of....~..~-;-.., 19..]~
~, Prothonota~
LISA K. KUNKLEMAN,
Plaintiff
V
ALAN R. OTT,
Defendant
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:
:CIVIL ACTION - LAW
:
:NO: 97-6183 CIVIL TERM
:IN CUSTODY
CONCILIATION CONFE}L~NCE S .[TM~.._~_Rj' REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the
following report:
The pertinent information pertaining to the children wilo are
the subject of this litigation is as follows:
Emily E. Ott, born February 24, 1992; and Erika K. Ott, born
August 2, 1994.
e
A Conciliation Conference was held on January 9, 1998, with
the following individuals in attendance:
The Mother Lisa K. Kunkleman, with her attorney, Sally J.
Winder, Esquire; and the Father Alan R. Ott, who appeared
without counsel.
3. The parties agree to the entry of an Order in the form as
attached.
BRENDA KUNKLEMAN AND CHARLES
KUNKLEMAN
PLAINTIFF : CUMBERLAND COt;NTY, PENNSYLVANIA
V.
: 04-1244 CIVIL ACTION LAW
LISA K. KELLEY AND ALAN R. OTT
: IN CUSTODY
DEFENDANT
: IN THE COURT OF COMMON PLEAS OF
ORDER OF COURT
AND NOW, Thursday, April 01, 2004 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before ~Jacqueline M. Verue~', Esq. _, the conciliator,
at 4th Flour, Cumberland County Courthouse, Carlisle on Tuesday, April 27, 2004 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. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grotmds 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.
FORTHECOURT.
By: /s/ ~ey, .Esq.
Custody Conciliator
rnhc
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites Act of 1990. For infom~ation 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 WItERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
BRENDA KUNKLEMAN and
CHARLES KUNKLEMAN
Plaintiffs
LISA K. KUNKLEMAN and
ALAN R. OTT,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION .- LAW
NO. 04-1244 CIVIL TERM
IN CUSTODY
AFFIDAVIT OF SERVICE
AND NOW, this ~_~ .~7~ day of April, 2004, comes Brian C. Bomman, Esquire,
counsel of record for Plaintiffs, Brenda & Charles Kunkleman, and states that a tree and attested
copy of a Complaint for Custody and related Order of Court dated April 1, 2004, was sent to
Defendant, Alan R. Ott, to the Franklin County Prison, 625 Franklin Farm Lane, Chambersburg,
17201, by certified mail, return receipt requested. A copy ,of said receipt is attached hereto
indicating that a prison employee signed for the mail on April 20, 2004. Also attached is a
statement from the Assistant Warden of the Prison stating that Officer Marvin Carbaugh
delivered the letter and witnessed Defendant, Alan Ott, sign that the letter was opened in front of
him, on April 20, 2004, as evidenced by an excerpt from the prison mail log.
Brian C. Bomman, Esquire
Attorney for Plaintiff
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
Sworn and subscribed to
before tme t, hJ~s ~ day
of_ ~ \~ .~ ., 2004
BRENDA KUNKLEMAN and
CHARLES KUNKLEMAN
Plaintiffs
LISA K. KUNKLEMAN and
ALAN R. OTT,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 04-1244 CIVIL TERM
IN CUSTODY
AFFIDAVIT OF SERVICE
AND NOW, this o~37~ day of April, 2004, comes Brian C. Bomman, Esquire,
counsel of record for Plaintiffs, Brenda & Charles Kunkleman, and states that a true and attested
copy of a Complaint for Custody and related Order of Court dated April 1, 2004, was sent to
Defendant, Lisa Kelley, to the Franklin County Prison, 625 Franklin Farm Lane, Chambersburg,
17201, by certified mail, return receipt requested. A copy of said receipt is attached hereto
indicating that a prison employee signed for the mail on April 23, 2004. Also attached is a
statement from the Assistant Warden of the Prison stating that Officer Carol Lane delivered the
letter and witnessed Defendant, Lisa Kelley, sign that the letter was opened in front of her on
April 23, 2004, as evidenced by an excerpt from the prison mail log.
Sworn and subscrib~to
before ~e this ~ day
of ~ [/ _ ,2004
OTARYyUflL'~C
Brian C. Bornman, Esquire
Attorney for Plaintiff
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
Postage
Certified Fee
Return Receipt Fee
(E~ldorsement Required)
Restricted Delivery Fee
(Endorsement Required)
3 be completed by mailer)
BRENDA KUNKLEMAN and
CHARLES KUNKLEMAN,
Plaintiffs
V.
LISA K. KELLEY and ALAN R.
OTT,
Defendants
APR 2 7 2004
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 2004-1244 CIVIL TERM
:
: CIVIL ACTION - LAW
:
: IN CUSTODY
ORDER OF COURT
ANDNOW, this ~Ot~ dayof Pq[9 ~, ( ,2004, upon
consideration of the attached Custody ConciliatiSn Report, it is ordered and directed as
follows:
1. The prior Order of Court at Docket No. 97-6183 is hereby vacated.
2. The maternal grandparents, Brenda Kunkleman and Charles Kunkleman,
shall have sole legal custody of Emily E. Ott, bom February 24, 1992 and Erika K. Ott,
bom August 2, 1994.
Children.
The maternal grandparents shall have prim~u~ physical custody of the
4. Mother shall have periods of partial physica/[ custody as agreed by
maternal grandparents.
5. Father shall have periods of partial physical custody as agreed by maternal
grandparents.
6. The parties may modify the terms of this Order by mutual consent. In the
absence of mutual consent, the terms of this Order shall corttrol.
BY THE COURT, ,/ ? .,~}
cc: Brian C. Bomman, Esquire, Counsel for maternal grandparents .z~
Lisa K. Kelley, Franklin County Prison, 625 Franklin Farm Lane, Chambersburg, Pa. j'-
17201
Alan R. Ott, Franklin County Prison, 625 Franklin Farm Road, Chambersburg, PA
17201
BRENDA KUNKLEMAN and
CHARLES KUNKLEMAN,
Plaintiffs
V.
LISA K. KELLEY and ALAN R.
OTT,
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: 2004-1244 CIVIL TERM
:
: CIVIL ACTION - LAW
:
: IN CUSTODY
PRIOR JUDGE: J. Wesley Oler, Jr., J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Clfildren who are the subject of
this litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN CUSTODY OF
Emily E. Ott
Erika K. Ott
February 24, 1992
August 2, 1994
maternal grandparents
maternal grandparents
2. A Conciliation Conference was held in this ]matter on April 27, 2004, with
the following in attendance: The maternal grandparents, Brenda Kunkleman and Charles
Kunkleman, with their counsel, Brian C. Bomman. Neither Mother nor Father appeared
although they received notice of the conference. Both Mother and Father are incarcerated
in the Franklin County Prison.
3. The Honorable J. Wesley Oler, Jr. previously entered an Order of Court at
Docket No. 97-6183 in Lisa Kunkleman v. Alan Ott, dated January 20, 1998 providing
for shared legal custody, Mother having primary physical custody and Father having
alternating weekends.
4. The maternal grandparents have had physic,fl custody of the Children
since July 2001.
attached.
Date
Maternal grandparents requested an Order of Court in the form as
Vemey, Esquire ~'
Custody Conciliator
BRENDA KUNKLEMAN and
CHARLES KUNKLEMAN,
Plaintiffs
LISA K. KELLEY and ALAN R. OTT,
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
:
: NO. 04-1244 CIVIL TERM
:
: IN CUSTODY
ACCEPTANCE OF SERVICE
I, Lisa K. Kelley, acknowledge that I received tree and attested copy of Plaintiffs'
Complaint for Custody and related Order of Court dated Thursday, April 1, 2004, in the above
captioned action by certified mail, postage prepaid on the date listed below.
!
MARIANNA LEE KELLEY (NOW IN THE COURT OF COMMON PLEAS OF
HOROWITZ)
PLAINTIFF
V.
SHAWN PATRICK KELLEY
DEFEN DANT
AND NOW,
CUMBERLAND COUNTY, PENNSYLVANIA
-2—CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
Thursday, June 12, 2014 , 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 Wednesday, July 02, 2014 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.
You must file with the Court a verification regarding any criminal record or abuse history regarding you and
anyone living in your household on or before the initial in-person contact with the court (including, but not limited to,
a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition.
No party may make a change in the residence of any child which significantly impairs the ability of the other party
to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and
Pa.R.C.P. No. 1915.17 regarding relocation.
FOR THE COURT,
By: /s/ Hubert X. Gilroy, Esq.,�I�`'
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 CANNET LEGAL HELP.
pi
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�s iflI 'it"
,0kelt ay, 'be-&
,Ke l/.v, P/ 4C
Esr.
4/x,6/1V
tie
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
w
CJ7
Karl R. Hildabrand, Esquire
Lavery Faherty Patterson
225 Market Street, Suite 304
P.O. Box 1245
Harrisburg, PA 17108-1245
(717) 233-6633 (telephone)
(717) 233-7003 (facsimile)
Attorney No. PA30102
khildabrand@laverylaw.com
Attorney for Interveners
OF T1j FILED -OFF -1G 1
HDNp TA f
20111 JUL -7 All [I
CUMBERLAND TY
PENNSYLVANIA y
MARIANNA LEE KELLEY,
Plaintiff
v.
SHAWN PATRICK KELLEY,
Defendant
v.
RICHARD E. KELLEY, JR. and
BABETTA E. KELLEY,
Interveners
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 04-1224
•
: CIVIL ACTION LAW
: IN CUSTODY
•
NOTICE TO PLEAD
To: Marianna Lee Kelley, Pro Se
753 South 21st Street
Harrisburg, PA 17104
You are hereby notified to plead to the enclosed Answer and Counterclaim of Interveners
within twenty (20) days from service hereof or a default judgment may be entered against you.
DATE: i/3 1l
LAVERY FAHERTY PATTERSON
By r. ;
arl R. Hildabrand, Esquire
225 Market Street, Suite 304
Harrisburg, PA 17108-1245
(717) 233-6633 (telephone)
(717) 233-7003 (facsimile)
Attorney No. PA30102
khildabrand@laverylaw.com
Attorney for Interveners
Karl R. Hildabrand, Esquire
Lavery Faherty Patterson
225 Market Street, Suite 304
P.O. Box 1245
Harrisburg, PA 17108-1245
(717) 233-6633 (telephone)
(717) 233-7003 (facsimile)
Attorney No. PA30102
Ichildabrand@laverylaw.com
Attorney for Interveners
MARIANNA LEE KELLEY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 04-1224
SHAWN PATRICK KELLEY,
Defendant
v. : CIVIL ACTION LAW
: IN CUSTODY
RICHARD E. KELLEY, JR. and
BABETTA E. KELLEY,
Interveners
ANSWER AND COUNTERCLAIM OF INTERVENERS
RICHARD E. KELLEY, JR. AND BABETTA E. KELLEY
1. Admitted except that it is believed that the Petitioner resides in a half -way house
in Harrisburg and is still under probation.
2. Admitted.
3. Admitted.
4. Admitted.
5. Denied as stated. The averments of paragraph 5 and subparagraphs a. through d.
are specifically denied and proof thereof is demanded. On the contrary, Petitioner is currently
residing in a half -way house and is on probation. While Interveners do not object to a visitation
schedule with Petitioner, and in fact a visitation schedule is already in place, nevertheless,
Interveners have concerns about Petitioner's residence, her ability to have the children for any
extended period, and Petitioner's stability.
COUNTERCLAIM
6. Pursuant to paragraph 14 of Judge Oler's Order of April 6, 2010, when both
Plaintiff and Defendant became unavailable to exercise their custodial rights with the children,
the paternal grandparents assumed those custodial rights and have been doing so ever since.
The minor children have resided with Interveners from 2012, when both Plaintiff and Defendant
were arrested and incarcerated to the present.
7. Interveners respectfully request that this Court enter an Order granting them
shared legal custody and primary physical custody.
8. The requested Order will facilitate Interveners in registering the children for
school, carrying out medical care, and protecting other important rights for the children.
Date: 7- 31 By:
Respectfully submitted,
LAVERY FAHERTY PATTERSON
arl R. Hildabrand, Esquire
Attorney I.D. No. 30102
225 Market Street, Suite 304
P. O. Box 1245
Harrisburg, PA 17108-1245
(717) 233-6633 phone
(717) 233-7003 fax
Attorney for Interveners
2
VERIFICATION
We, Richard E. Kelley, Jr. and Babetta E. Kelley, verify that the statements made in the
foregoing Answer and Counterclaim are true and correct to the best of our knowledge,
information and belief. We understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities.
Date:
Date: 024 *-1—e- d/9'
Richard E. Kelley, Jr.
ildevi5-31r
Babetta E. Kelley
CERTIFICATE OF SERVICE
I, Karl R. Hildabrand, Esquire, with the law firm of Lavery Faherty Patterson, do hereby
certify that on this 3 day of July, 2014, I served a true and correct copy of the foregoing
Answer and Counterclaim of Interveners, via U.S. First Class mail, postage prepaid, addressed as
follows:
Marianna Lee Horowitz
753 South 21st Street
Harrisburg, PA 17104
Plaintiff
Mr. Shawn Patrick Kelley
c/o SCI Houtzdale
LC7756
P.O. Box 1000
Houtzdale, PA 16698
Defendant
Hubert, X. Gilroy, Esquire
Martson Law Offices
10 East High Street
Carlisle, PA 17013
Conciliator
rl R. Hildabrand, Esquire