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
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AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS
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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
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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
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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
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?`?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
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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
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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
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PPE ?"?R?tA