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HomeMy WebLinkAbout08-5167Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Scott F?ingerhoot SCOTT FINGERHOOT, Plaintiff V. ELLEN M. COLEMAN and SCOTT COLEMAN, Defendants IN THE COURT OF CO MON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. CIVIL ACTI - LAW IN NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to de fend against in the following pages, you must take action within twenty (20) days after Notice are served, by entering a written appearance personally or by aft writing with the Court your defenses or objections to the claims set forth ac warned that if you fail to do so the case may proceed without you and a entered against you by the Court without further notice for any money claim( or for any other claim or relief requested by the Plaintiff. You may lose me other rights important to you. s claims set forth s Complaint and ney and filing in nst you. You are idgment may be in the Complaint :y or property or YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. F YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORI AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 S. Bedford Street Carlisle, PA 171013 (717) 249-3166 kTION ABOUT T A REDUCED AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea d fenderse de las demandas que se presentan mas adelante en las siguientes p6ginas, debe to ar accibn dentro de los prbximos veinte (20) dias despu6s de la notificacibn de esta Demanda Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radi ando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aq i en contra suya. Se le advierte de que si usted falla de tomar accibn como se describe ante ormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacibn o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin m6s aviso adicional. Usted puede perder dinero o ropiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INME IATAMENTE. SI LISTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO ONSEGUIR UN ABOGADO. SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SC QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A I CUALIFICAN. Cumberland County Bar Association 32 South .Bedford Street Carlisle, Pennsylvania 17013 ABOGADO, ES BRE AGENCIAS 'ERSONAS QUE (717) 249-3166 Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 Attorneys for Scott 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 SCOTT FINGERHOOT IN THE COURT OF COM MON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA Plaintiff NO. S" / W7 GNr( V. CIVIL ACTION - LAW ELLEN M. COLEMAN and SCOTT COLEMAN, Defendants COMPLAINT FOR CUSTODY AND NOW, this ? day of August, 2008 comes the Plaintiff, SCOTT FINGERHOOT, by and through his undersigned attorneys, Johnson, uffie, Stewart & Attorneys, and files this Complaint for Custody and in support thereof avers as follows: 1. The Plaintiff, SCOTT FINGERHOOT, resides at 801 Walnut Street, Apt. 12, Lemoyne, Cumberland County, Pennsylvania 17043. 2. The Defendant, ELLEN M. COLEMAN, resides at an addres which she has concealed. It is believed that her last known address is 385 Cumb erland Parkway, Mechanicsburg, PA 17055. 3. Defendant, Scott Coleman, resides at 195 Beagle Club Ro ad, Carlisle, PA 17013. 4. The Plaintiff and Defendant, Ellen Coleman, are biological p arents of two (2) minor children: DREW M. COLEMAN, born May 15, 1997 and SAMANTHA N. COLEMAN, born October 13, 1999. 5. The children were born out of wedlock. 6. Plaintiff seeks custody of the children who presently reside with heir mother. 7. Plaintiff/Mother and the children have resided at an undisclos ed address since early June 2008. 8. In the last five years the children have resided with the followin g persons at the following addresses: A. From 2002 to August 1, 2006, with Mother, Father, Sc tt Coleman and stepbrother at 779 Erford Road, Camp Hill, PA 17011. B. From August 1, 2006 to October 2006, with Mother, Father, Scott Coleman, Tammy and Randy Rager, and Kaitlyn Rager at 779 Erford Roa , Camp Hill, PA 17011. C. From October 2006 to January 31, 2007, with Mot er, Father, Scott Coleman and children at 779 Erford Road, Camp Hill, PA 17011. D. From January 31, 2007 to April 2, 2007, with Mother, Father, Scott Coleman, children and Randy Rager at 779 Erford Road, Camp Hill, PA 17011 E. From April 2, 2007 to May 4, 2007, with Mother, Scott Coleman, Randy Rager and children at 779 Erford Road, Camp Hill, PA 17011. F. From May 4, 2007 to June 2008, with Mother, Randy R ger and children at 779 Erford Road, Camp Hill, PA 17011 G. From June 2008 to date, with Mother, stepbrother and infant twins upon information and belief, at the Wingate by Wyndham Hotel, 385 Cum eland Parkway, Mechanicsburg, PA 17055. 9. Since the Plaintiff left the Erford Road residence, he has mad contact with the children through Mr. Coleman's custodial periods, after he became aware that it had been determined that the children where not genetically the children of Mr. Coleman 10. Some time after June 1, 2008, Mother moved from the Erford Road address and has cut off contact with the children and Mr. Coleman as well as the Plaintiff, refusing to respond to email, voicemail or disclose her new address. 11. Mother has set about to conceal the identity of the children's genetic father and has openly stated her intent to withhold the children from the Plaintiff. 12. Mother's actions are such that it is clear that she will not wovidd the children with access to a relationship with their Father in the absence of a Court Order requiring Mother's participation and compliance with custodial exchanges. 13. Mr. Coleman has rights of partial custody pursuant to this Court's Order at Docket Number 07-3330. A copy of the most recent Order is attached hereto as Exhibit "A". 14. It is believed, and therefore averred, that Mother has been in contempt of this Order on multiple occasions and that a contempt action is pending in this court docketed at 07- 3330, filed on February 21, 2008. 15. The relationship of the Plaintiff to that of the children is that of Father. 16. Father currently resides alone. 17. The relationship of the Defendant, Ellen Coleman, to the children is that of Mother. 18. Mother is divorced from Scott Coleman, whom she had originally alleged to be the Father of the children. It was later genetically determined that is not the rase and that the Plaintiff herein is the genetic Father. 19. Plaintiff has participated as a witness in other litigation concern ng the custody of these children in this court, appearing before Judge Hess. The conciliator was John Mangan. 20. Plaintiff has information regarding other custody proceed concerning the children in this court, a copy of the most recent Order is attached hereto as Ex ibit "A". 21. Plaintiff names Scott Coleman, Mother's former husband, a a party to the proceedings who has rights of partial custody to the children and who has alleged that he has stood in loco parentis with respect to these children. 22. Scott Coleman is represented by Barbara Sumple-Sullivan, Esquire and his counsel is aware of the filing of this action. 23. The best interests and permanent welfare of the children would be serve by granting the relief requested because: A. The Defendant, Ellen Coleman, has sought to alienate the children from both Scott Coleman and Scott Fingerhoot, each of whom have played a parental role in the lives of these children. B. Defendant's, Ellen Coleman, actions advance her interests ahead of those of the children. C. Defendant has an unstable lifestyle as illustrated by her deceiving all of her children as to the identity of the infant twins' whom it is believed she has borne as the result of a relationship with Randy Rager during the time that Mr. Rager and his wife were residing in her residence. D. The Defendant, Ellen Coleman, has concealed her address and made consistent attempts to interfere with and otherwise failed to support the children's relationship with Scott Coleman and the Plaintiff. E. Mother, Randy Rager, Tyler Coleman, Mr. Rager's twins, and Plaintiffs two children are crammed into an efficiency hotel room which provides little privacy for Samantha and inadequate sleep, study and play areas for the children. 24. Each parent whose parental rights to the children have not bee terminated and the person who has physical custody of the custody of the children have been ames as parties to this action. WHEREFORE, Plaintiff request the Court granting an Order granting him primary physical custody and shared legal custody of the minor children. submitted, DUFF)% STEWART $ WEIDNER Melissa Peel Greevy, Esquire I.D. No 77950 301 Market Street P.O. Box 109 Lemoyne, PA 17043 Telephone: (717) 761-4540 VERIFICATION I, SCOTT FINGERHOOT, verify that the statements made in this Com?laint For Custody are true and correct to the best of my knowledge, information and belief. 11 understand that false statements made herein are made subject to the penalties of 18 Pa. C.S?A §4904, relating to unsworn falsification to authorities. Date: OTT FINGERHOOT CERTIFICATE OF SERVICE 110-11 AND NOW, this day of August, 2008, the undersigned does hereby certify that she did this date serve a copy of the foregoing Complaint for Custody upon he other party of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Barbara Sumple-Sullivan 549 Bridge Street New Cumberland, PA 17070 JOHWON, DIJFFIE,..S.,TEWART $ WEIDNER Melissa Peel Greevy :341406 N V ((yyam? C:,a l.J?j c: 7 rt-? r , rv _ Cj-% aC SCOTT FINGERHOOT IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-5167 CIVIL ACTION LAW ELLEN M. COLEMAN AND SCOTT COLEMAN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, September 02, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, September 12, 2008 at 2:30 PM 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/ John J. Mangan, Jr., Esq. ILL 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 77 i{ 'tv..r ?`?41 V SCOTT FINGERHOOT Plaintiff V. ELLEN M. COLEMAN AND SCOTT COLEMAN Defendants Prior Judge: Kevin A. Hess, J. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 08-5167 Civil Term : ACTION IN CUSTODY COURT ORDER AND NOW, this 330 day of September 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: 1. This Order is entered pursuant to a Custody Conciliation Conference. A Custody Hearing is hereby scheduled on the / day of , 2008 at 3 am/pm in Courtroom number in the Cumberland County Court of Common Pleas, Carlisle, PA 17013 at which time testimony will be taken in regard to allocation of costs for the custody evaluation. For purposes of this hearing, the Scott Fingerhoot shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least five days prior to the hearing date. 2. A Custody Hearing is hereby scheduled on the 174 day of 2009 at 9: 30-am/pm in Courtroom number 41 in the Cumberlan d Coun Court of Common Pleas, Carlisle, PA 17013 at which time testimony will be taken in regard to the physical custody for the subject Children. For purposes of this hearing, the Scott Fingerhoot shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least five days prior to the hearing date. 3. Legal custody: Scott Coleman, the Mother and Scott Fingerhoot shall have shared legal custody of Drew M. Coleman, born 5/15/97 and Samantha N. Coleman, born 10/13/99. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all i_. 1 records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 4. Physical Custody: Mother shall have primary physical custody of the Children subject to Scott Fingerhoot's partial physical custody as follows: a. Commencing 9/13/08, Scott Fingerhoot shall have physical custody of Drew and Samantha the first and second weekend of every month. Scott Fingerhoot shall have custody of Drew and Samantha from Friday 6:00 pm until Sunday 6:00 pm. The non- custodial party shall pick the Children up. b. Scott Fingerhoot shall have physical custody of Drew and Samantha every Tuesday and Thursday from after school until 7:30 pm. The non-custodial party shall pick the Children up. C. For the purpose of determining when a weekend starts, Friday shall be the start of a weekend. d. Scott Fingerhoot shall have physical custody of the Children at such other times as the parties may mutually agree. 5. Counseling: The parties are directed to engage in therapeutic family counseling with a mutually-agreed upon professional. In the absence of agreement, the parties shall engage Guidance Associates. Father has agreed to initiate said counseling. The cost of said counseling, after appropriate payment through insurance, shall be split equally between the parties. 6. It is agreed that a custody evaluation may be beneficial to the instant matter with a mutually agreed upon professional. In the absence of agreement, Riegler Schienvold and Associates shall be utilized. The allocation of costs for the evaluation shall be determined at the scheduled hearing. 7. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. 8. Holidays: Christmas shall be broken into three blocks. Block A shall be from 12/23 at 6:00 pm until 12/24 6:00 pm. Block B shall be from 12/24 6:00 pm until 12:00 pm on 12/25. Block C shall be from 12:00 pm on 12/25 until 12/26 at 12:00 pm. For 2008, Mother has Block A, Scott Fingerhoot has block B and Scott Coleman has block C. In succeeding years, whomever has Block C shall then have Block A, whomever has Block A shall then have Block B and whomever has Block B shall then have Block C. v Thanksgiving shall be broken into three blocks. Block A shall be from 6:00 pm on Wednesday before Thanksgiving until 12:00 pm Thursday. Block B shall be from Thursday 12:00 pm until Friday at 12:00 pm. Block C shall be from Friday 12:00 pm until Saturday 6:00 pm. For 2008, Mother has Block A, Scott Fingerhoot has Block B and Scott Coleman has Block C. In succeeding years, whomever has Block C shall then have Block A, whomever has Block A shall then have Block B and whomever has Block B shall then have Block C. A summer vacation schedule shall be addressed after the custody evaluation has been done and family counseling has started. 9. In the event the custodial parent should take the Child out of state, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. 10. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Children. 11. In the event of a medical emergency, the custodial party shall notify the other parties as soon as possible after the emergency is handled. 12. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 13. The parties may modify this Order by mutual agreement in writing. In the absence of mutual consent, the terms of this Order shall control. BY T COURT/, ?G J. Distribution: Ellen Coleman, 29 East Locust Street, Mechanicsburg, PA 17055 Melissa Peel Greevy, Esquire ??-?-- /, 0- 0/_ 0J, Barbara Sumple-Sullivan, Esquire John J. Mangan, Esquire,, co l y yy. 't?y G 4 ^'. ?J 1 i"3' N a SCOTT FINGERHOOT Plaintiff V. ELLEN M. COLEMAN AND SCOTT COLEMAN Defendants Prior Judge: Kevin A. Hess, J. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 08-5167 Civil Term : ACTION IN CUSTODY CONCIIdATION CONFERENCE SUNIlVIARY 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 children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Drew M. Coleman 5/15/97 Primary with Mother Samantha N. Coleman 10/13/99 Primary with Mother 2. A Conciliation Conference was held on September 12, 2008 with the following individuals participating: The in loco parentis Father of Drew and Samantha, Scott Coleman, with his counsel, Barbara Sumple-Sullivan, Esquire The Mother, Ellen Coleman, pro se. The biological Father of Drew and Samantha, Scott Fingerhoot, with his counsel, Melissa Peel Greevy, Esq. 3. Scott Fingerhoot's position on custody is as follows: Father has been determined to be the biological father of Drew and Samantha and seeks shared legal custody and primary physical custody of the Children. Paternity Father asserts that he is better able to offer the Children a stable home environment. 4. Mother's position is as follows: Mother seeks shared legal custody and primary physical custody of the Children. Mother states that she has been the primary care-giver for the Children for all of their lives. Mother states that she is better able to assist the Children with the school work and that she is able to give the Children a stable home environment. 5. The Conciliator recommends an Order in the form as attached scheduling a Hearing and entering an Order of Court granting Mother and Scott Fingerhoot a shared legal custody and Mother to have primary physical custody subject to Scott Fingerhoot's partial physical custody as outlined. It is the Conciliator's belief that this would be in the Children's best interest. It is expected that the Hearing will require one day. 6. The proposed recommended Order may contain a requirement that the parties file a pre-trial memorandum with the Judge to whom the matter has been assigned. Date: ? / , S G ?.- Jo J. angan, Esquir C to Conciliator SCOTT FINGERHOOT, Plaintiff V. ELLEN M. COLEMAN and SCOTT COLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-5167 CIVIL TERM IN CUSTODY IN RE: REQUEST FOR CUSTODY EVALUATION WITHDRAWN ORDER OF COURT AND NOW, this 18th day of December, 2008, for the reasons stated by counsel, the request for a custody evaluation is withdrawn. This matter is referred to the conciliator for the purpose of establishing a schedule of partial custody. By the Court, Kevi A. Hess, J. Melissa Peel Greevy, Esquire Fgr Plaintiff Ellen M. Coleman, Pro se :bg l? 1 z Ex t ,ice ?} t?,,, Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 SCOTT FINGERHOOT Plaintiff V. ELLEN M. COLEMAN and SCOTT COLEMAN Defendants Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-5167 CIVIL ACTION - LAW MOTION FOR LEAVE TO WITHDRAW APPEARANCE AND NOW, comes the law firm of Johnson Duffie Stewart & Weidner and respectfully represents as follows: 1. Your Movant currently represents the Plaintiff, Scott Fingerhoot, in the within action. 2. Certain circumstances have arisen between Plaintiff and the undersigned counsel which make termination of the relationship mutually beneficial. 3. In correspondence dated August 11, 2009, the undersigned provided Plaintiff with notice of that she undersigned could not continue to represent him. 4. Plaintiff has not responded to several attempts to contact him. 5. The undersigned has not been contacted by new counsel for Plaintiff. 6. There are no other custody matters currently scheduled before this Court which would cause prejudice to Plaintiff if this Petition is granted. There may be a support matter pending for hearing before Support Master, Michael Rundle. 7. The Honorable Kevin A. Hess was previously assigned to this case. The Honorable Edward E. Guido has previously been assigned to the parties' support matter, No. 12 S 2008; PACSES No. 084109715. 8. The undersigned attempted to reach Defendant Ellen Coleman to obtain concurrence without success. She did not answer two calls. A recording indicated her "voicemail box had not been set up yet." 9. Mr. Coleman's counsel was contacted for concurrence and did not object to the withdrawal of the undersigned. 10. The undersigned again attempted to contact Mr. Fingerhoot for a response his concurrence, he has not returned the call. WHEREFORE, it is respectfully requested that this Honorable court grant the undersigned counsel's request for leave to withdraw. JOHNSON,_DUFFIE, STEWART & WEIDNER lissa Peel Greevy CERTIFICATE OF SERVICE AND NOW, this dS day of , 2009, the undersigned does hereby certify that she did this date serve a copy of the foregoing Motion for Leave to Withdraw upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Scott Fingerhoot 801 Walnut Street Apt. 12 Lemoyne, Pennsylvania 17043 Barbara Sumple Sullivan 549 Bridge Street New Cumberland, Pennsylvania 17070 Ellen Coleman 29 E. Locust Street Mechanicsburg, Pennsylvania 17055 JOHNGON, DgFFIE, STEWART & WEIDNER 16a? Melissa Peel G :378388 ??W l ?IV OF THE 2009 SEP 28 PH O 51 SEP 2 9 2009 Johnson, Duffie, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 SCOTT FINGERHOOT Plaintiff V. ELLEN M. COLEMAN and SCOTT COLEMAN, NO. 08-5167 CIVIL ACTION - LAW Defendants ORDER OF COURT AND NOW, this 30 ` day of Ts,. , 2009, upon review of the Motion for Leave to Withdraw filed by Plaintiff's counsel, the Motion for Leave to Withdraw is GRANTED. Dist: elissa P. Greevy, Esquire, P. O. Box 109 Lemoyne, PA 17043 vl!f ott Fingerhoot 801 Walnut Street Apt. 12, Lemoyne, Pennsylvania 17043 ? ; -"bara Sumpie Sullivan, Esq.,549 Bridge Street, New Cumberland, Pennsylvania 171 e&len Coleman 29 E. Locust Street, Mechanicsburg, Pennsylvania 17055 4 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALM-OfFa OF THE PROTK, MARY 2009 SEP 30 AM 11: 54 CL#AB PPE ?"?R?tA