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HomeMy WebLinkAbout08-5665OM' A &N ULAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 GREGORY H. MILLIGAN, Plaintiff V. TERESA E. MILLIGAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 6?- 6UU5 OI U! l Tlvhl CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Gregory Milligan, who currently resides at 96 Pine Creek Drive, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Teresa E. Milligan, who currently resides at 6592 Hollow Drive, East Petersburg, Lancaster County, Pennsylvania. 3. The Plaintiff seeks custody of the following children: Name: Jacob Gregory Milligan Date of Birth: October 17, 1996 Name: Benjamin Douglas Milligan Date of Birth: July 15, 1999 4. The children were born during wedlock. 5. The children are presently in the custody of the Plaintiff, who resides at 96 Pine Creek Drive, Carlisle, Cumberland County, Pennsylvania. 6. The mother of the child is Teresa Milligan, who currently resides at 6592 Hollow Drive, East Petersburg, Lancaster County, Pennsylvania. 7. The mother of the child, Teresa Milligan, is separated. 8. The father of the child is Gregory Milligan, who currently resides at 96 Pine Creek Drive, Carlisle, Cumberland County, Pennsylvania. 9. Father of the child, Gregory Milligan, is separated. 10. The relationship of Plaintiff to the children is that of Father. 11. The relationship of Defendant to the children is that of Mother. 12. The Plaintiff currently lives with his paramour, Carol Maravic, and her children, Sarah and Nicholas Maravic. 13. The Defendant is temporarily, as of September 19, 2008, residing with her Father and Step- Mother Richard and Lynn Szafran, in Philadelphia. 14. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or any other court. 15. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 16. The Plaintiff originally filed a Complaint for Custody in Lancaster County on March 17, 2006. 17. However, a Praecipe to Withdraw and Dismiss the Complaint for Custody was entered on April 26, 2006. 18. The parties entered into a private agreement for custody of the children on June 19, 2006, but this Agreement was never made an Order of Court. 19. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 20. Each parent whose parental rights to the children have not been terminated has been named as a party to this action. 21. Simultaneously with the filing of this Complaint for Custody Plaintiff is also filing a Petition for Special Relief to be heard prior to a Custody Conciliation being scheduled. WHEREFORE, the Plaintiff/Father requests that this Court grant Sole Legal and Physical Custody of the children to the Plaintiff/Father with a visitation schedule to be determined. Respectfully submitted, DATE g -og ABom&KoTUTAKi4 L.L.P. 4 - Michelle L. Sommer, quire Supreme Court ID No. 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff I, GREGORY H. MILLIGAN, verify that the statements made in this Petition for Special Relief are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date 1,A 4 GREG . MILLIGAN AND NOW, this 24`h day of September 2008, I, Michelle L. Sommer, Esquire, of Abom & Kutulakis, L.L.P., hereby certify that I did serve a true and correct copy of the foregoing Complaint for Custody, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, First-class, postage prepaid addressed to the following: Kurt A. Gardner, Esquire Gardner and Stevens, P.C. 109 West Main Street Ephrata, PA 17522 Attorney for the Defendant Respectfully submitted, ABOM&KOTULAKrs; L.L.P. Michelle L. Somme , squire Supreme Court ID No. 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plain tiff Orr Xic -TI 7 Y > t TAB OM & U ULAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 GREGORY H. MILLIGAN, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 7-erM TERESA E. MILLIGAN, Defendant CIVIL ACTION - LAW IN CUSTODY 1. The Plaintiff is Gregory Milligan, who currently resides at 96 Pine Creek Drive, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Teresa E. Milligan, who currently resides at 6592 Hollow Drive, East Petersburg, Lancaster County, Pennsylvania. 3. The Plaintiff seeks custody of the following children: Name: Jacob Gregory Milligan Date of Birth: October 17, 1996 Name: Benjamin Douglas Milligan Date of Birth: July 15, 1999 4. The children were born during wedlock. 5. The children are presently in the custody of the Plaintiff, who resides at 96 Pine Creek Drive, Carlisle, Cumberland County, Pennsylvania. 6. The Plaintiff originally filed a Complaint for Custody in Lancaster County on March 17, 2006. 7. However, a Praecipe to Withdraw and Dismiss the Complaint for Custody was entered on April 26, 2006. (A copy of said Praecipe is attached hereto as Exhibit "A".) 8. The parties entered into a private agreement for custody of the children on June 19, 2006, but this Agreement was never made an Order of Court. (A copy of said Agreement is attached hereto as Exhibit `B".) a. In the Agreement the parties agreed that the Plaintiff would have partial physical custody and Defendant would have primary physical custody of the children. 9. The mother of the children, Teresa E. Milligan, is currently residing with her Father and Stepmother, Richard and Lynn Szafran in Philadelphia in order to undergo psychiatric evaluations in order to determine her current medical stability. a. In fact, her Father was so concerned about her current emotional and mental stability he flew to Philadelphia from his current home in Florida on September 22, 2008 to be at his daughter's side during her fragile condition. b. It is believed and therefore averred that her family is taking the necessary steps to intervene in their daughter's life to help her regain her emotional and mental stability. 10. On or about the first week of June the Defendant's electricity had been shut off for one (1) day. 11. On or about September 11, 2008, the Defendant's electricity had been turned off for six (6) days. a. As a result the minor children had been residing in their home with their Mother without power, running water and power to cook their food and wash their clothes. 12. The Defendant's electricity was able to be restored because the Defendant borrowed $51.00 from her minor children's piggy banks in order to pay the back-due utility bill. 13. On or about early March 2008, the Defendant's cable and internet service had been shut off for a period of time due to lack of payment for both services. 14. Also around that same time period the Defendant's cellular service had been shut off for a period of time due to lack of payment. 15. On or about September 20, 2008, Defendant's neighbor, Steve Amadon, delivered four bags of food to Defendant's household after having conversations with the children that there was no food in the house for them to eat. 16. It is believed and therefore averred that Defendant is driving a vehicle that is eight months delinquent for inspection. 17. It is believed and therefore averred that Defendant's vehicle registration is delinquent and car insurance is in arrears. 18. A Domestic Relations Order was entered in Lancaster County November 29, 2007, which awarded the Defendant $1,980.00 in child support and spousal support. (A copy of said Order is attached hereto as Exhibit "C".) a. Included in the support amount are tuition payments that the Defendant is to be making directly to Lancaster County Day School on behalf of each of the children every month. b. However, the Defendant was unable to make a single payment for the 2007-2008 school year and the extra support that the Plaintiff paid in child support that was to be paid to the school was never paid and as a result the school is in arrears approximately $2,360.00 per child. (A copy of said document is attached hereto as Exhibit "D".) 19. On August 28, 2008 a Domestic Relations Order was entered in Lancaster County that reduces the amount of child support Plaintiff will be paying to Defendant by $521.47. (A copy of said Order and all support calculations are attached hereto as Exhibit "E".) a. According to Domestic Relations, the reduction would take affect on or about the week of September 22, 2008. b. This reduction was agreed upon by the parties on August 28, 2008 in order for the tuition payments to be made directly to Lancaster County Day School on behalf of the children by both of the parties individually in order for the payments to be made for the 2008-2009 school year. c. It was determined at this Domestic Relations Conference that the tuition payments were pro-rated for the year and the Plaintiff would pay the school directly at a rate of $231.25 per month and the Defendant would pay the school directly at a rate of $77.08 per month. 20. It is believed and therefore averred that the Defendant was unable to pay her monthly bills prior to the reduction in the Domestic Relations Support Order even though she failed to pay the tuition and kept the additional money to support herself and the children. 21. It is believed and therefore averred that as a result of the reduction the Defendant will in no way be able to support herself and the children since she was unable to do so prior to the reduction. 22. It is believed and therefore averred that the Defendant is emotionally and mentally unstable and as a result is unable to take care of herself as well as the children at this time. 23. Plaintiff believes and therefore avers that at this time it would be in the minor children's best interest to reside full time with their Father. 24. It is believed and therefore averred that with the help of Defendant's family she will be able to concentrate on her financial and emotional stability knowing that the children are in a stable environment with their Father. 25. Plaintiff has contacted the Carlisle School District to make arrangements to enroll the children for the 2008-2009 school year. 26. Each parent whose parental rights to the children have not been terminated has been named as a party to this action. 27. Simultaneously with the filing of this Petition for Special Relief Plaintiff has also filed a Complaint for Custody. WHEREFORE, the Plaintiff/Father requests that this Court grant Sole Legal and Physical Custody of the children to the Plaintiff/Father with a visitation schedule to be determined. Respectfully submitted, DATE g1 19W08 ABom&KUTUTAKI3, L.L.P. hWUOU ?- 6affil? Michelle L. Sommer squire Supreme Court ID No. 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff I, GREGORY H. MILLIGAN, verify that the statements made in this Petition for Special Relief are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ? 4904 relating to unsworn falsification to authorities. Date rA 'A ©Z GREGO Y M AN +1 R GREGORY MILLIGAN, IN THE COURT OF COMMON PLEAS . Plaintiff LANCASTER COUNTY, PA V. CI-06-02431 - . ?, TERESA MILLIGAN, CIVIL ACTION - LAW i Defendant IN CUSTODY ':1 _ PRAECIPE TO WITHDRAW AND DISMISS TO THE PROTHONOTARY: Please withdraw and dismiss Plaintiffs Custody Complaint in the above- referenced custody action. Respectfully submitted, ABOM& KUTULAKUS, L.L.P. Date: LINDA ASST. OEPU l I ATT KROTHUNOTARY Kara W. Haggerty, u e 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff EXHIBIT A . : } OR DECREE R.C.R NO. 236 ,?a n ,r=si-i'd - THE ATTACHED DOCUMEN, I-iA 1JEEN FILED IN THIS CASE PROTHONOTARY OF LANCASTER CO.,'?A r ?. a?• ? o?c .m CERTIFICATE OF SERVICE AND NOW, this 26" day of April 2006, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, LIT, hereby certify that I did serve a true and correct copy of the foregoing document, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Holly S. Fi us Russell, Krafft, & Gruber, LLP Hempfreld Center, Suite 300 Lancaster, PA 17601 DATE G`' I ZZ< Respectfully submitted, AaOM & KUTULAKIS, L.L.P. i 7 ` 9 tit ?.C L ? ? v Kara W. Haggerty 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff ID No. 86914 /it VISITATION (V` `'ice Mom and Dad switch every other weekend. On weekends with Dad, kids will be picked up at 5:30 pm on Friday and dropped off at ??1\ 7:00 pm on Sunday at an agreed-upon location. Dad will visit every Monday from 5:30-7:30 pm. On Thursdays before a weekend with Dad, there will be a Dad visit from 5:30-7:30 pm. G ,;,n.r On Thursdays before a weekend with Mom, kids will be picked up by Dad at 5:30 pm at an agreed-upon location. Kids will spend night with Dad. During school year, Dad will take kids to school the following morning. Work schedules and er circumstances will require occasional adjustments to the visitation schedule. oth parents will give every reasonable effort to accommodate these changes. During extended breaks in the school year (Christmas Vacation, etc.), parents will make every reasonable effort to share the tim uch as possible. P? - In other unusual circumstances (such as child sick days), parents will make every reasonable effort to assist one another, considering work schedules, etc. HOLIDAYS G One full week for each parent every summer - given advanced notice Option for one full week per year for Maternal Grandparents, given advanced notice I Option for one full week per year for Paternal Grandparents, given advanced notice Monday Holidays (Martin Luther King Day, President's Day, etc.) The kids stay with the parent they were with the weekend immediately before that holiday, given that parent and the kids are both off. Due to potential work/school schedule conflicts on these weekends, parents will need to remain flexible and be willing to work out a compromise if necessary. 4aster - alternate years (Mom even-numbered years, Dad odd-numbered years) Mother's Day - with Mom (make drop-off arrangements if necessary) emorial Day - alternate years (Mom even-numbered years, Dad odd-numbered years) G Father's Day - with Dad (make drop-off arrangements if necessary) EXHIBIT B Labor Day - alternate years (Dad even-numbered years, Mom odd-numbered years) Thanksgiving - alternate years (Dad even-numbered years, Mom odd-numbered years) CHRISTAIASLk_? 2006 <? iW Saturday, December 23 - with Dad until 3:00 pm on Sunday, December 24 Monday, December 25 - with Mom 2005 Sunday, December 23 - with Dad until 3:00 pm on Monday, December 24 Tuesday, December 25 - with Mom 2008 Thursday, December 25 - with Mom Friday, December 26 - pick up 10:00 am with Dad until 5:00 pm on Saturday, December 27 2009 Friday, December 25 - with Mom Saturday, December 26 - pick up at 10:00 am with Dad until 5:00 pm on Sunday, December 27 2010 Thursday, December 23 - pick up at 5:30 pm with Dad until 3:00 pm on Friday, December 24 Saturday, December 25 - with Mom 2011 Friday, December 23 - pick up at 5:30 pm with Dad until 3:00 pm on Saturday, December 24 Sunday, December 25 - with Mom 2012 Sunday, December 23 - pick up at 5:30 pm with Dad until 3:00 pm on Monday, December 24 Tuesday, December 25 - with Mom 2013 Wednesday, December 25 - with Mom Thursday, December 26 - pick up at 10:00 am with Dad until 5:00 pm on Friday, December 27 2014 Thursday, December 25 - with Mom Friday, December 26 - pick up at 10:00 am with Dad until 5:00 pm on Saturday, December 27 Greg Teri Milligan Date &//0& Date In the Court of C--,non Pleas of LANCASTER ?:ounty, Pennsylvania DOMESTIC RELATIONS SECTION TERESA E. MILLIGAN Order Number 2.0 0 7 - 33 L0 fI0t1S SEC.iP Plaintiff vs. ) PACSES Case Number 679109515 GREGORY H. MI LL I GAN ) Docket Number 2007-03305 Defendant ) Other State ID Number ORDER OF COURT ® Final Q Interim O Modified AND NOW, 1 DAY OF NOVEMBER, 2007 based upon the Court's determination that the Payee's monthly net income is $ 3, 646.81 and the Payor's monthly net income is $ 772.58 , it is hereby ordered that the Payor pay to the Pennsylvania State Collection and Disbursement Unit One Thousand Nine Hundred Eighty and 00/100 Dollars ($1, 98o. o o ) a month payable MONTHLY as follows: first payment due Immediately in the amount of $1800.00 current support and $180.00 arrears The effective date of the order is 10/05/07 . Arrears set at $ 1022.81 as of NOVEMBER 28, 2007 are due in full IMMEDIATELY. All terms of this Order are subject to collection and/or enforcement by contempt proceedings, credit bureau reporting, tax refund offset certification, driver's license revocation, and the freeze and seize of financial assets. These enforcement/collection mechanisms will not be initiated as long as obligor does not owe overdue support. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all the means listed above. For the Support of: Name BENJAMIN DOUGLAS MILLIGAN TERESA ELLEN MILLIGAN, SPOUSE JACOB GREGORY MILLIGAN Service Type M EXHIBIT C Birth Date 07/15/99 10/29/66 10/17/96 Form OE-519 Rev. 3 Worker ID 36219 MILLIGAN PACSES Case.Number: 679109515 The defendant owes a total of $ 1, 9 a o . o o per month payable MONTHLY ; $ 1,800.00 for current support and $ 18 o . o o for arrears. The defendant must also pay fees/costs as indicated below. V. MILLIGAN Said money to be turned over by the Pa SCDU to: TERESA ELLEN MILLIGAN . Payments must be made by check or money order. All checks and money orders must be made payable to Pa SCDU and mailed to: Pa SCDU P.O. Box 69110 Harrisburg, Pa 17106-9110 1 Payments must include the defendant's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. The monthly support obligation includes cash medical support in the amount of $250 annually for unreimbursed medical expenses incurred for each child and/or spouse. Unreimbursed medical expenses of the obligee or children that exceed $250 annually shall be allocated between the parties. The party seeking allocation of unreimbursed medical expenses must provide documentation of expenses to the other party no later than March 31st of the year following the calendar year in which the final medical bill to be allocated was received. The unreimbursed medical expenses are to be paid as follows: e2 % by defendant and 18 % by plaintiff. ® Defendant 0 Plaintiff Q Neither party to provide medical insurance coverage. Within thirty (30) days after the entry of this order,- the 0Plaintiff 0 Defendant shall submit to the person having custody of the child(ren) written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at a minimum, of : 1) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. Page 2 of 4 For n OE-519 Rev. 3 Service Type M Worker ID 36219 MILLIGAN V- MILLIGAN PACSES Case Number: 679109515 Other Conditions: By agreement of the parties, payment of support is allocated as $1,400.00 per month for child support and $400.00 per month for spousal support. By agreement of the parties, the amount of support is a deviation from the guidelines. Defendant received credit in the amount of $2,400.00 for direct payments. Defendant shall pay the following fees: Fee Total Fee Description $ 10.00 for 2ND JUDICIAL COMPUTER FEE $ 15.00 for INITIAL FILING FEE $ 0.00 for $ 0.00 for $ 0.00 for Payment FreauencX Payable at $ 10 .00 per ONE TIME Payable at $ is. o 0 per ONE TIME Payable at $ 0.0 0 per Payable at $ 0 . o o per Payable at $ o . o o per IMPORTANT LEGAL NOTICE PARTIES MUST WITHIN SEVEN DAYS INFORM THE DOMESTIC RELATIONS SECTION AND THE OTHER PARTIES, IN WRITING, OF ANY MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT TO THE LEVEL OF SUPPORT OR THE ADMINISTRATION OF THE SUPPORT ORDER, INCLUDING, BUT NOT LIMITED TO, LOSS OR CHANGE OF INCOME OR EMPLOYMENT AND CHANGE OF PERSONAL ADDRESS OR CHANGE OF ADDRESS OF ANY CHILD RECEIVING SUPPORT. A PARTY WHO WILLFULLY FAILS TO REPORT A MATERIAL CHANGE IN CIRCUMSTANCES MAY BE ADJUDGED IN CONTEMPT OF COURT, AND MAYBE FINED OR IMPRISONED. PENNSYLVANIA LAW PROVIDES THAT ALL SUPPORT ORDERS SHALL BE REVIEWED AT LEAST ONCE EVERY THREE (3) YEARS IF SUCH REVIEW IS REQUESTED BY ONE OF THE PARTIES. IF YOU WISH TO REQUEST A REVIEW AND ADJUSTMENT OF YOUR ORDER, YOU MUST DO THE FOLLOWING: CALL YOUR ATTORNEY. AN UNREPRESENTED PERSON WHO WANTS TO MODIFY (ADJUST) A SUPPORT ORDER SHOULD CONTACT THE DOMESTIC RELATIONS SECTION. ALL CHARGING ORDERS FOR SPOUSAL SUPPORT AND ALIMONY PENDENTE LITE, INCLUDING UNALLOCATED ORDERS FOR CHILD AND SPOUSAL SUPPORT OR CHILD SUPPORT AND ALIMONY PENDENTE LITE, SHALL TERMINATE UPON DEATH OF THE PAYEE. Page 3 of 4 Form OE-519 Rev. 3 Service Type M Worker ID 36219 MILLIGAN V. MILLIGAN PACSES Case Number: 679109515 A MANDATORY INCOME ATTACHMENT WILL ISSUE UNLESS THE DEFENDANT IS NOT IN ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO OR GREATER THAN ONE MONTH'S SUPPORT OBLIGATION AND (1) THE COURT FINDS THAT THERE IS GOOD CAUSE NOT TO REQUIRE IMMEDIATE INCOME WITHHOLDING; OR (2) A WRITTEN AGREEMENT IS REACHED BETWEEN THE PARTIES WHICH PROVIDES FOR AN ALTERNATE ARRANGEMENT. UNPAID ARREARAGE BALANCES MAY BE REPORTED TO CREDIT AGENCIES. ON AND AFTER THE DATE IT IS DUE, EACH UNPAID SUPPORT PAYMENT SHALL CONSTITUTE, BY OPERATION OF LAW, A JUDGMENT AGAINST YOU, AS WELL AS A LIEN AGAINST REAL PROPERTY. IT IS FURTHER ORDERED that, upon payor's failure to comply with this order, payor may be arrested and brought before the Court for a Contempt hearing; payor's wages, salary, commissions, and/or income may be attached in accordance with law; this Order will be increased without further hearing by o % a month until all arrearages are paid in full. Payor is responsible for court costs and f s. Copies delivered to parties at Juuge Service Type M Worker ID 36219 Consented: Page 4 of 4 Form OE-519 Rev. 3 \ ?CC r ^f1t??°3 LANCASTER l s COUNTRY DAY August 21, 2008 W' 4 SCHOOL Ms. Teresa Milligan 6592 Hollow Drive East Petersburg, PA 17520 Dear Teri, The Financial Aid Committee has completed its careful reconsideration of your application for financial aid for Jacob for the 2008-2009 school year. I am pleased to report that, based on the report from the School and Student Service for Financial Aid and the additional information you provided, you have been awarded financial aid in the amount of $15,250.00. This leaves a balance of $1,800.00 to be paid by you. I hope that you will find this amount both fair and possible. If you have any questions about your financial aid award, please give me a call. This award is contingent.upon payment in full of the 2007-2008 tuition balance of $2,360.95 by February 20, 2009. You have already received your child's Enrollment Contract for the 2008-2009 school year. Please return both copies of this Enrollment Contract, along with your Reservation Deposit of $180.00, by 8/27/08 to reserve a place for your child for next year. Since the Enrollment Contract obligates you to pay unconditionally the above stated balance, I strongly urge you to participate in the Tuition Refund Plan. Information about this plan is on the Enrollment Contract and also in the enclosed brochure. Please check "yes" or "no" in the appropriate box on the Enrollment Contract. For the 2008-2009 school year, we will be offering four options for payment of tuition: 1. Pay 100% of the tuition balance by August 27 by credit card or check. 2. Pay 50% of the tuition balance by August 27 and 50% by December 15. This option is very helpful to the School and we would appreciate parents exercising this option if they are able to do so. Credit Card payments are only accepted for Option 1.- 3. Sign up for one of the LCDS Monthly payment Plans by electronic payment. These plans require an enrollment fee $50.00 per child and payer authorization as well as enrollment in the Tuition Refund Plan. 4. Sign up for one of the LCDS Monthly Payment Plans by check payments. These plans require an annual enrollment fee of $150.00 per child and regular monthly payments as well as enrollment in the Tuition Refund Plan. Your cost for this plan is $15.30. Please check one of the boxes on your Enrollment Contract for your preferred payment plan. Please see the enclosed brochure for details on the payment plans. The monthly plans are an excellent way to spread out your tuition payments without incurring interest costs. These payments must be made in full and on time, or after missing three payments your child may be disenrolled from Lancaster Country Day School. If you have any questions about these options, please call our Business Office at 717-392-2916, Ext. 267. We look forward to having Jacob with us next year, and we are pleased to be able to offer you financial assistance. Sincerely yours, Junior K. Thiry Business Manager cc: Greg Milligan Beth Stine E)CFHBIT D 725 Hamilton Road • Lancaster, PA • 17603 • www.e-lcds.org • Phone: (717) 392-2916 • Fax: (717) 392-0425 ?` LWI LANCASTER L' COUNTRY DAY 9 0 4 August 21, 2008 SCHOOL Ms. Teresa Milligan 6592 Hollow Drive East Petersburg, PA 17520 Dear Teri, The Financial Aid Committee has completed its careful reconsideration of your application for financial aid for Ben for the 2008-2009 school year. I am pleased to report that, based on the report from the School and Student Service for Financial Aid and the additional information you provided, you have been awarded financial aid in the amount of $14,475.00. This leaves a balance of $1,800.00 to be paid by you. I hope that you will find this amount both fair and possible. If you have any questions about your financial aid award, please give me a call. This award is contingent upon payment in full of the 2007-2008 tuition balance of $2,360.84 by February 20, 2009. You have already received your child's Enrollment Contract for the 2008-2009 school year. Please return both copies of this Enrollment Contract, along with your Reservation Deposit of $180.00, by 8/27/08 to reserve a place for your child for next year. Since the Enrollment Contract obligates you to pay unconditionally the above stated balance, 1 strongly urge you to participate in the Tuition Refund Plan. Information about this plan is on the Enrollment Contract and also in the enclosed brochure. Please check "yes" or "no" in the appropriate box on the Enrollment Contract. For the 2008-2009 school year, we will be offering four options for payment of tuition: 1. Pay 100% of the tuition balance by August 27 by credit card or check. 2. Pay 50% of the tuition balance by August 27 and 50% by December 15. This option is very helpful to the School and we would appreciate parents exercising this option if they are able to do so. Credit Card payments are only accepted for Option 1. 3. Sign up for one of the LCDS Monthly payment Plans by electronic payment. These plans require an enrollment fee $50.00 per child and payer authorization as well as enrollment in the Tuition Refund Plan. 4. Sign up for one of the LCDS Monthly Payment Plans by check payments. These plans require an annual enrollment fee of $150.00 per child and regular monthly payments as well as enrollment in the Tuition Refund Plan. Your cost for this plan is $15.30. Please check one of the boxes on your Enrollment Contract for your preferred payment plan. Please see the enclosed brochure for details on the payment plans. The monthly plans are an excellent way to spread out your tuition payments without incurring interest costs. These payments must be made in full and on time, or after missing three payments your child may be disenrolled from Lancaster Country Day School. If you have any questions about these options, please call our Business Office at 717-392-2916, Ext. 267. We look forward to having Ben with us next year, and we are pleased to be able to offer you financial assistance. Sincerely yours, Junior K. Thiry Business Manager cc: Greg Milligan Beth Stine 725 Hamilton Road - Lancaster, PA - 17603 - www.e-lcds.org - Phone: (717) 392-2916 - Fax: (717) 392-0425 In the Court of C upon rteas of LANCASTER County, Pennsyly#nia DOMESTIC RELATIONS SECTION TERESA E. MILLIGAN ) Order Number 2007-3305 ' - Plaintiff ) vs. ) PACSES Case Number 679109515 GREGORY H. MILLIGAN ) Docket Number 2007-03305 Defendant ) Other State ID Number ORDER OF COURT Q Final ® Interim O Modified AND NOW.? ? DAY OF AUGUST, 2008 based upon the Court's determination that the Payee's monthly net income is $ 1, 225.51' and the Payor's monthly net income is $ 3, 529.55 , it is hereby ordered that the Payor pay to the Pennsylvania State Collection and Disbursement Unit One Thousand Four Hundred Fifty-Eight and 53/100 Dollars ($1, 458.53 ) a month payable monthly as follows: first payment due immediately in the amount of $1328.53 current support and $130.00 on arrears. The effective date of the order is 0 8 / 2 7 / 0 8 Arrears set at $ 775.22- as of AUGUST 28, 2008 are due in full IMMEDIATELY. All terms of this Order are subject to collection and/or enforcement by contempt proceedings, credit bureau reporting, tax refund offset certification, driver's license revocation, and the freeze and seize of financial assets. These enforcement/collection mechanisms will not be initiated as long as obligor does not owe overdue support. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all the means listed above. For the Support of: Name BENJAMIN DOUGLAS MILLIGAN JACOB GREGORY MILLIGAN TERESA ELLEN MILLIGAN (SPOUSE) EXI HBIT Form OE-519 Rev.5 Service Type M E Worker ID 36221 Birth Date 07/15/99 10/17/96 10/29/66 MILLIGAN V. MILLIGAN PACSES Case Number: 679109515 The defendant owes a total of $ 1, 458.53 per month payable monthly ; $ 1,800.00 for current support and $ 18 0.0 0 for arrears. The defendant must also pay fees/costs as indicated below. Said money to be turned over by the Pa SCDU to: TERESA ELLEN MILLIGAN . Payments must be made by check or money order. All checks and money orders must be made payable to Pa SCDU and mailed to: Pa SCDU P.O. Box 69110 Harrisburg, Pa 17106-9110 Payments must include the defendant's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. The monthly support obligation includes cash medical support in the amount of $250 annually for unreimbursed medical expenses incurred for each child and/or spouse. Unreimbursed medical expenses of the obligee or children that exceed $250 annually shall be allocated between the parties. The parry seeking allocation of unreimbursed medical expenses must provide documentation of expenses to the other party no later than March 31st of the year following the calendar year in which the final medical bill to be allocated was received. The unreimbursed medical expenses are to be paid as follows: 75 % by defendant and 2 5 % by plaintiff. ® Defendant Q Plaintiff Q Neither party to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the 0Plaintiff Q Defendant shall submit to the person having custody of the child(ren) written proof that medical insurance coverage has been obtained or that application for coverage has been made.. Proof of coverage shall consist, at a minimum, of : 1) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. Page 2 of 4 Form OE-519 Rev.5 Service Type M Worker ID 36221 MILLIGAN V. MILLIGAN PACKS Case Number: 679109515 Other Conditions: Support is allocated as follows: $400.00 per month spousal support and $928.53 child support. Tuition at Lancaster Country Day to be handled outside support order with Defendant responsible for $231.25 per month and Plaintiff $77.08 per month. No credit is give to Defendant for past payments through DRS unless he makes additional payments toward outstanding balance of $4721.79. Defendant to receive credit, pending verification, of any future payments he makes on behalf of the Plaintiff for 2008-2009 school year. Effective date is date reservation payment is due for 2008-2009. Defendant shall pay the following fees: Fee Total Fee Description $ 15.00 for MODIFICATION FEE $ 0.00 for $ 0.00 for $ 0.00 for $ 0.00 for Payment Frequency Payable at $ 15. 00 per ONE TIME Payable at $ 0.0 0 per Payable at $ 0.0 0 Per Payable at $ 0.00 per Payable at $ 0.0 0 per IMPORTANT LEGAL NOTICE PARTIES MUST WITHIN SEVEN DAYS INFORM THE DOMESTIC RELATIONS SECTION AND THE OTHER PARTIES, IN WRITING, OF ANY MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT TO THE LEVEL OF SUPPORT OR THE ADMINISTRATION OF THE SUPPORT ORDER, INCLUDING, BUT NOT LIMITED TO, LOSS OR CHANGE OF INCOME OR EMPLOYMENT AND CHANGE OF PERSONAL ADDRESS OR CHANGE OF ADDRESS OF ANY CHILD RECEIVING SUPPORT. A PARTY WHO WILLFULLY FAILS TO REPORT A MATERIAL CHANGE IN CIRCUMSTANCES MAY BE ADJUDGED IN CONTEMPT OF COURT, AND MAYBE FINED OR IMPRISONED. PENNSYLVANIA LAW PROVIDES THAT ALL SUPPORT ORDERS SHALL BE REVIEWED AT LEAST ONCE EVERY THREE (3) YEARS IF SUCH REVIEW IS REQUESTED BY ONE OF THE PARTIES. IF YOU WISH TO REQUEST A REVIEW AND ADJUSTMENT OF YOUR ORDER, YOU MUST DO THE FOLLOWING: CALL YOUR ATTORNEY. AN UNREPRESENTED PERSON WHO WANTS TO MODIFY (ADJUST) A SUPPORT ORDER SHOULD CONTACT THE DOMESTIC RELATIONS SECTION. ALL CHARGING ORDERS FOR SPOUSAL SUPPORT AND ALIMONY PENDENTE LITE, INCLUDING UNALLOCATED ORDERS FOR CHILD AND SPOUSAL SUPPORT OR CHILD SUPPORT AND ALIMONY PENDENTE LITE, SHALL TERMINATE UPON DEATH OF THE PAYEE. Page 3 of 4 Form OE-519 Rev.5 Service Type M Worker ID 36221 MIL LIGAN V. MILLIGAN PACSES Case Number: 679109515 A MANDATORY INCOME ATTACHMENT WILL ISSUE UNLESS THE DEFENDANT IS NOT IN ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO OR GREATER THAN ONE MONTH'S SUPPORT OBLIGATION AND (1) THE COURT FINDS THAT THERE IS GOOD CAUSE NOT TO REQUIRE IMMEDIATE INCOME WITHHOLDING; OR (2) A WRITTEN AGREEMENT IS REACHED BETWEEN THE PARTIES WHICH PROVIDES FOR AN ALTERNATE ARRANGEMENT. UNPAID ARREARAGE BALANCES MAY BE REPORTED TO CREDIT AGENCIES. ON AND AFTER THE DATE IT IS DUE, EACH UNPAID SUPPORT PAYMENT SHALL CONSTITUTE, BY OPERATION OF LAW, A JUDGMENT AGAINST YOU, AS WELL AS A LIEN AGAINST REAL PROPERTY. IT IS FURTHER ORDERED that, upon payor's failure to comply with this order, payor may be arrested and brought before the Court for a Contempt hearing; payor's wages, salary, commissions, and/or income may be attached in accordance with law; this Order will be increased without further hearing by o % a month until all arrearages are paid in full. Payor is responsible for court costs and fees. Copies delivered to parties ; Date Consented: Plaintiff Defendant A" DAY OF AUGUST, 2008 Date Service Type M Plaintiff's Attorney Defendant's Attorney BY THE COURT: v Judge Page 4 of 4 Form OE-519 Rev.5 Worker ID 36221 8t I In the Court of Common Pleas of LANCASTER County, Pennsylvania DOMESTIC RELATIONS SECTION TERESA E. MILLIGAN Plaintiff vs. GREGORY H. MILLIGAN Defendant Docket Number 2007-03305 PACSES Case Number 679109515 ) Other State ID Number NOTICE OF RIGHT TO REQUEST A HEARING The parties are hereby advised that they have until SEPTEMBER 18, 2008 to request a hearing de novo before the Court. File requests in person at: DOMESTIC RELATIONS SECTION 150 N QUEEN ST SUITE 220 LANCASTER PA 17603 or mail to: DOMESTIC RELATIONS SECTION PO BOX 83479 LANCASTER PA 17608-3479 Form OE-572 Service Type M Worker ID 36114 • L ? In the Court of Common Pleas of LANCASTER County, Pennsylvania DOMESTIC RELATIONS SECTION PACSES Case Number: 679109515 Docket Number: 2007-03305 Other State ID Number: Please note: All correspondence must include the PACSES Case Number. AUGUST 26, 2008 SUMMARY OF TRIER OF FACT Plaintiff Information Defendant Information TERESA E. MILLIGAN Address: 6592 HOLLOW DR EAST PETERSBURG PA 17520-1017 Employer: CONESTOGA VALLEY SCHOOL DISTRICT 160 NEWPORT RD LEOLA PA 17540-1824 Attorney KURT A GARDNER ESQ GREGORY H. MILLIGAN Address: 96 PINE CREEK DR CARLISLE PA 17013-9668 Employer: SENATE OF PA C/O OFFICE OF CHIEF CLERK 89E E WING HARRISBURG PA 17120-0001 Attorney: MICHELLE L. SOMMER, ESQ. ® Petition for Modification Filed 0 4 / 0 7 / 0 8 ? Other ? Complaint for Support Reason for Conference: Defendant requesting removal of tuition from support order. Conference held 8/21/08. Parties attending: Plaintiff, Defendant, and Defendant's attorney. Dependent(s) BENJAMIN DOUGLAS MILLIGAN 07/15/99 JACOB GREGORY MILLIGAN 10/17/96 - -7624 - -8980 Current Order: $1,800.00 / per month Service Type M Agreement dated November 29, 2007. Form CM-022 Rev.3 Worker ID 36221 MILLIGAN ?• MILLIGAN Pr,.:SES Case Number: 679109515 Plaintiff Information Defendant Information Current Income: Employed p/t 4 years. YTD paystub Employed 8 years. Defendant's dated 6/6/08 indicates a biweekly biweekly salary, gross is $2580.96 gross of $531.39 and a calculated calculated net is $1731.00. net of $428.77. See below. See below. Tax Return: Did not present. Reports filed 2007 Did not present. Reports filed 2007 married -jointly with 4 exemptions married -jointly with 4 exemptions. Medical Coverage: Provided through Defendant's Provided through employer at a cost employer. of it of his salary for self, Plaintiff, and 2 children: $25.81 biweekly. Child Care/Tuition: Lancaster Country Day. Lancaster Country Day. SEE BELOW. SEE BELOW. Additional Obligations: No additional obligations. No additional obligations. Resides with children. Resides with girlfriend and her 2 children. Other Information: Plaintiff pays $39.86 biweekly in mandatory retirement Plaintiff only works 40 weeks per year; above average is per week worked not annualized Adjusted monthly gross for unpaid summer weeks is $885.65, calculated net is $694.45. Defendant pays $161.31 biweekly in mandatory retirement Prior conference held 5/1/08 as Defendant recruested removal of private school tuition from the Order. 11/29/07 Agreement included cost of tuition in the guideline calculation Guideline amount was $1890.97 per month Parties agreed to $1800.00 per month as a compromise as Defendant disputed whether children should continue at Lancaster Country Day and Plaintiff agreed to an earning capacity of 40 hours per week for inclusion of tuition in order. Order allocated $4.00.00 for spousal and $1400.00 for children, of which tuition was included Defendant's portion of the monthly tuition was $477.57, or 82% At 5/1/08 conference, Plaintiff had not made any payments for the tuition and reported a balance of $3500.00. Parties stated, and Country Day confirmed, if the balance Page 2 of 3 Form CM-022 Rev.3 Service Type M Worker ID 36221 . MILLIGAN V. MILLIGAN PACSES Case Number: 679109515 Other Information (continued): was not paid by first day of school for the 08-09 school year, the children would not be permitted to re-enroll. Defendant requested he be given credit for payments made that were not put toward the tuition and that children be enrolled in public school for the 08-09 school year. Plaintiff's attorney See page # 4. Facts Agreed Upon: Lancaster Country Day is a very good school. Facts in Dispute and Contentions with Respect to Facts in Dispute:. LCD is too expensive for Plaintiff. Recommendation: Defendant to pay $130.00 toward arrears. Defendant to provide medical coverage. Sup ort is allocated as follows: $400.00 per month spousal support and $928.53 child support Unreimbursed medical expenses exceeding $250.00 annually per arty to be aid 75t by Defendant and 25t by Plaintiff. Tuition at LCD to be handled outside support order with Defendant responsible for $231.25 per month and Plaintiff $77.08 per month No credit is given to Defendant for past payments through DRS unless he makes additional payments toward outstanding balance of $4721.79. Defendant to receive credit pending verification, of any future payments he makes on behalf of Plaintiff for 2008- Guideline Amount: $ 1, 328.53 / Month 2009 school year. DRS Recommended Amount: $ 1, 3 2 8.5 3 / Month DRS Recommended Order Effective Date: August 27, 2008- Parties to be Covered by Recommended Order Amount: 2 children, Benjamin and Jacob. *Effective date is date reservation payment is due for 2008-2009 Guideline Deviation: Q YES or Q NO Reason for Deviation: OF .. Submitted by: ? OIWEP• Date Prepared: ME: of 3 Service Type M D AUGUST 26, 2008 Form CM-022 Rev.3 Worker ID 36221 MILLIGAN v AILLIGAN PACSE,. ase Number: 679109515 Other Information (continued): requested a continuance to give the Plaintiff time to attain full time employment and pay the tuition balance. Defendant agreed. 8/21/08 conference held to review Plaintiff's employment status, tuition balance, and whether the children were returning to Country Day. (Plaintiffs attorney attended 5/1/08 conference, but not 8/21/08) At 8/21/08 conference, Plaintiff stated she had not found a full time position. Reported during the summer she had looked at school districts, county positions, hospitals, nursing homes, and Kellogg's. Parties also reported the outstanding balance was $4721.79, not $3500 as previously noted. Defendant had enrolled the children at Hempfield as balance had not been paid by deadline. Defendant produced letter from LCD dated 8/7/08 stating financial aid for 08-09 was contingent upon payment in full of balance by 8/22/08. Plaintiff submitted letter from LCD dated 8/21/08, day of conference, stating that an increased financial aid package, dropping 08-09 tuition costs to $1800 per child instead of the $3500 per child for 07-08, was contingent upon payment in full of balance by 2/20/09. Defendant had not been aware of Plaintiff s letter. Plaintiff subsequently stated children were enrolled at LCD for 08-09 at $1800 per child cost. There is also a $50.00 per child enrollment fee for the payment plan Plaintiff has chosen. Defendant's attorney then requested tuition costs be handled outside of child support order as during the period of the continuance Plaintiff still had not remitted any payment to LCD despite its continued inclusion in the Defendant's obligation. Attorney also requested Defendant's previous payments be considered as an overpayment at a rate of $477.57 per month as that was his portion paid to Plaintiff for 07-08 tuition costs. Parties agree LCD is a very good school, however, Defendant feels it is too expensive as evidenced by Plaintiffs failure to send in payments. Plaintiff stated she spent the support money on bills. For calculation, Plaintiff is assigned $10.70 per hour (current rate is $10.68 or $10.73 dependent on job performed) at 32 hours per week for a monthly gross of $1487.81 and a calculated net of $1225.51. Filing status used is head of household with 3 exemptions consistent with establishment conference. Defendant is initially assigned true current earnings of monthly gross $5607.44 and calculated net of $3760.80. Filing status used is single with 1 exemption consistent with establishment conference. Defendant's income is 75% of parties' total. Tuition cost for 08-09 is $3700.00 (including $100.00 payment plan enrollment fee). Defendant's monthly obligation at 75% is $231.25. ($3700 * 75% _ $2775.00/12 = $231.25) Defendant's monthly net adjusted downward in consideration of this payment directly to LCD for a net of $3529.55. Plaintiffs obligation for tuition is $77.08 per month, or 25%. Under these conditions guideline amount is $1328.53. Ifs no adjustment is made for Defendant's obligation for tuition on his net income and tuition is included in a straight calculation, the guideline amount would be $1575.23. After removing Defendant's portion, $231.25, monthly obligation is $1343.98. 4 l • MILLIGAN v ULLIGAN PACSE_ 'ase Number: 679109515 Other Information (continued): No credit to be awarded to Defendant at present. Outstanding balance for tuition is considered Plaintiff's obligation as Defendant made all full payments as directed. Should Defendant make payments toward $4721.79 balance, pending verification, he will receive credit at that time. If necessary, case may be reviewed at that time for liquidation of a possible overpayment. In the Court of Common Pleas of LANCASTER DOMESTIC RELATIONS SECTION PO BOX 83479, LANCASTER, PA. 17608-3479 Phone: (717) 299-8141 AUGUST 28, 2008 MICHELLE L. SOMMER, ESQ. CIO ABOM & KUTULAKIS 36 S HANOVER ST CARLISLE PA 17013-3306 Distribution Cover Letter County, Pennsylvania Fax: (717) 293-7270 Plaintiff Name: TERESA E. MILLIGAN Defendant Name: GREGORY H. MILLIGAN PACSES Case Number: 679109515 Please note: All correspondence must include the PACSES Case Number. Dear MICHELLE L. SOMMER, ESQ. Please note the attached document and/or correspondence. This information is being sent to update you on the above captioned case. Sincerely, CONFERENCE Form CM-520 Service Type m Worker ID 36221 AND NOW, this 24`h day of September 2008, I, Michelle L. Sommer, Esquire, of Abom & Kutulalds, L.L.P., hereby certify that I did serve a true and correct copy of the foregoing Petition for Special Relief, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, First-class, postage prepaid addressed to the following: Kurt A. Gardner, Esquire Gardner and Stevens, P.C. 109 West Main Street Ephrata, PA 17522 Attorney for the Defendant Respectfully submitted, ABOM & KUTULAKIS, L.L.P. IkMichelle L. Somm squire Supreme Court ID No. 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff V C`! 11 Q r-•,) a%3 r.? C? cF? GREGORY MILLIGAN, PLAINTIFF V. TERESA MILLIGAN, DEFENDANT AND NOW, this IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 08-5665 CIVIL TERM ORDER OF COURT day of September, 2008, IT IS ORDERED that a hearing on the within petition for special relief for an emergency change in the custodial arrangements for Jacob Milligan and Benjamin Milligan shall be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania at 2:00 p.m., Monday, October 6, 2008. ,,,,,,Michelle L. Sommer, EsquirE `? For Plaintiff ,xu'rt A. Gardner, Esquire J For Defendant :sal Edgar B. Bayley, J. N l u =e ?-- ? ;?_? s Y cc? '? GREGORY H. MILLIGAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. TERESA E. MILLIGAN DEFENDANT 2008-5665 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Friday, September 26, 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 Friday, October 17, 2008 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. Gilro Es q. 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 R d3S 90x1 rttC?i ,vr 'W , 3 3'11 JO 101 1.:,a110.-013111 GREGORY H. MILLIGAN, Plaintiff V. TERESA E. MILLIGAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 08-5665 CIVIL ACTION - LAW IN CUSTODY PRAFCIPE TO WITHDRAW AN DI M SS TO THE PROTHONOTARY: Please withdraw and dismiss Plaintiff's Custody Complaint and Petition for Special Relief in the above-referenced custody action. Date: lqlo jok Respectfully submitted, ABOM & KUTULAKI,? L.L.P. AA1 Michelle L. So , Esquire 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney ID #93034 Attorney for Plaintiff AND NOW, this 100' day of October 2008, I, Michelle L. Sommer, Esquire, of Abom & Kutulakis, L.L.P., hereby certify that I did serve a true and correct copy of the foregoing Motion to Withdraw and Dismiss, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, First-class, postage prepaid addressed to the following: Kurt A. Gardner, Esquire Gardner and Stevens, P.C. 109 West Main Street Ephrata, PA 17522 Attorney for the Defendant Respectfully submitted, Awm&KUTULAKis; L.L.P. ?- 0 Michelle L. So er, Esquire Supreme Court ID No. 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plainto ,r-, c-- ?,, -> ?" c? c-, -? ;:? -n - -? ti T"; JCX : ?« °%? ., .. ~ •y._ (OCT So?L11 GREGORY H. MILLIGAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW TERESA E. MILLIGAN, NO. 2008-5665 Defendant IN CUSTODY COURT ORDER AND NOW, this day of October, 2008, the Conciliator being advised the venue needs to be changed to Lancaster County, the Conciliator relinquishes jurisdiction. ??x -- Hubert X. Gi y, Esquire Custody C ciliator ?"`} ?,? p ? 5,.. . ?7? °; ? --H ? ? ., 3V 'c., ?: _a,? .-. ? ?1.} "17 -,?, C;:: :?? :? ~? .. ,„.? -M--