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HomeMy WebLinkAbout08-6580%P s: K [ v ELI J. HOOVER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. TYI'1'1 APRIL NICOLE HOOVER, Defendant IN DIVORCE and CUSTODY You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may also lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle. IF YOU SO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having busme3s before the court, please conw our office. All aenangemews must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. ELI J. HOOVER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. 6 9- 6S ko &..-( APRIL NICOLE HOOVER, Defendant IN DIVORCE and CUSTODY M-MA vT UNnM 5F=MS 3301()) or 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Eli J. Hoover, by and through his counsel, Michael J. Whare, Esquire and avers as follows: 1. Plaintiff is Eli J. Hoover, an adult individual, who currently resides at 241 Bobcat Road, Carlisle, Cumberland County, Pennsylvania 17015. 2. Defendant is April Nicole Hoover, an adult individual who currently resides at 241 Bobcat Road, Carlisle, Cumberland County, Pennsylvania 17015. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 9, 2006, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. COUNT 2 - CUSTODY 9. The previous paragraphs 1-8 are incorporated by reference. 10. Plaintiff seeks shared physical custody of the following child: Name Present residence DOB Ian T. Hoover 241 Bobcat Rd. 06/11/2007 Carlisle, PA 17015 11. The child was not born out of wedlock. 12. The child is presently in the custody of Mother and Father, who reside at 241 Bobcat Road, Carlisle, Pennsylvania. 13. During the past five years, the child has resided with the following persons and at the following addresses: List all Persons Father and Mother List All Addresses 419 Bobcat Road Newville, PA 17241 Dates June 2007-Aug. 2007 Father and Mother 241 Bobcat Road August 2007- present Carlisle, PA 17015 14. The Mother of the child is April Nicole Hoover, who resides at 241 Bobcat Road, Carlisle, Cumberland County, Pennsylvania 17015. She is married to the Plaintiff. 15. The Father of the child is Andrew Shaner, who resides at 241 Bobcat Road, Carlisle, Cumberland County, Pennsylvania 17015. He is married to the Defendant. 16. The relationship of Plaintiff to child is that of Father. The Father currently resides with the following persons: Name Relationship April Nicole Hoover Wife Ian T. Hoover Son 17. The relationship of Defendant to child is that of Mother. The Mother currently resides with the following persons: Nam Relationship Eli J. Hoover Ian T. Hoover Husband Son 18. 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 another court. 19. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 20. 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. 21. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Nam s Address Basis of Claim None 22. Reasons for granting relief: A) A Court Order of custody and structured visitation is desired so that Plaintiff and child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant his Complaint for shared physical custody of the child. Respectfully submitted, Date: A -0`S k Michael I Wha/b, Esquire 3 7 East Pomfret Street Carlisle, PA 17013 Supreme Ct. Id No. 89028 Attorney for Plaintiff ELI J. HOOVER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law APRIL NICOLE HOOVER, Defendant No. IN DIVORCE and CUSTODY VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. & 4904 relating to unworn falsification to authorities. Date: q -G• 07 v E Hoover, Plaintiff kj Ql CTl ? G-, ELI J. HOOVER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law :No. 08-6580 Civil Term APRIL NICOLE HOOVER, Defendant : IN DIVORCE and CUSTODY ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce and Custody. I certify that I am authorized to accept service on behalf of the defendant. 11 )(0102 Da Adams, Esquire 17 W. South Street Carlisle, PA 17013 C a ? a ? 't P" `~y (s rn ' 3s ELI J. HOOVER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. APRIL NICOLE HOOVER DEFENDANT 2008-6580 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, November 10, 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 Wednesday, December 10, 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. 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, r. 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 ?M1 Wi3d kINnC? O lS:ZNd Z# Amol 1(?'??iC??d ?E3 ELI J. HOOVER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law APRIL NICOLE HOOVER, Defendant No. 08-6580 CIVIL TERM : IN DIVORCE and CUSTODY NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may also lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle. IF YOU SO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 1F YOU DO NOT HAVE A LAWYER 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, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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. ELI J. HOOVER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law APRIL NICOLE HOOVER, Defendant : No. 08-6580 CIVIL TERM IN DIVORCE and CUSTODY AMENDED COMPLAINT UNDER SECTIONS 3301(c) or 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Eli J. Hoover, by and through his counsel, Michael J. Whare, Esquire and avers as follows: 1. Plaintiff is Eli J. Hoover, an adult individual, who currently resides at 241 Bobcat Road, Carlisle, Cumberland County, Pennsylvania 17015. 2. Defendant is April Nicole Hoover, an adult individual who currently resides at 241 Bobcat Road, Carlisle, Cumberland County, Pennsylvania 17015. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 9, 2006, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. COUNT 2 - CUSTODY 9. The previous paragraphs 1-8 are incorporated by reference. 10. Plaintiff seeks shared physical custody of the following child: Name Present residence DOB Ian T. Hoover 241 Bobcat Rd. 06/11/2007 Carlisle, PA 17015 11. The child was not born out of wedlock. 12. The child is presently in the custody of Mother and Father, who reside at 241 Bobcat Road, Carlisle, Pennsylvania. 13. During the past five years, the child has resided with the following persons and at the following addresses: List all Persons Father and Mother List All Addresses 419 Bobcat Road Newville, PA 17241 Dates June 2007-Aug. 2007 Father and Mother 241 Bobcat Road August 2007- present Carlisle, PA 17015 14. The Mother of the child is April Nicole Hoover, who resides at 241 Bobcat Road, Carlisle, Cumberland County, Pennsylvania 17015. She is married to the Plaintiff. 15. The Father of the child is Eli J. Hoover, who resides at 241 Bobcat Road, Carlisle, Cumberland County, Pennsylvania 17015. He is married to the Defendant. 16. The relationship of Plaintiff to child is that of Father. The Father currently resides with the following persons: Name Relationship April Nicole Hoover Wife Ian T. Hoover Son 17. The relationship of Defendant to child is that of Mother. The Mother currently resides with the following persons: Name Eli J. Hoover Ian T. Hoover Relationship Husband Son 18. Plaintiff has not participated as a parry or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 19. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 20. 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. 21. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Nye Address Basis of Claim None 22. Reasons for granting relief: A) A Court Order of custody and structured visitation is desired so that Plaintiff and child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant his Complaint for shared physical custody of the child. Respectfully submitted, Date: ?„ Ly,,? j chael 5Whiare, squire 37 East Pomfret Street Carlisle, PA 17013 Supreme Ct. Id No. 89028 Attorney for Plaintiff ELI J. HOOVER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law APRIL NICOLE HOOVER, Defendant No. 08-6580 CIVIL TERM IN DIVORCE and CUSTODY ATTORNEY VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of IS Pa.C.S. & 4904 relating to unworn falsification to authorities. Date: 04J ?A Michael J. Whar Esq. r._ ?.? ; ( _ "?°t ... ? ",- Y._ .ft + tlf..,_ k W ?.. V.. JJ e ?F A, .. r,aJ ELI J. HOOVER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. 08-6580 Civil Term APRIL NICOLE HOOVER, Defendant IN DIVORCE and CUSTODY ACCEPTANCE OF SERVICE I accept service of the Amended Complaint in Divorce and Custody. I certify that I am authorized to accept service on behalf of the defendant. V -'?A\?? Dat Adams, 17 W. South Street Carlisle, PA 17013 fill ELI J. HOOVER, vs. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA APRIL NICOLE HOOVER, Defendant No. 08 - 6580 Civil Term ACTION IN CUSTODY CUSTODY AGREEMENT -)14? This Custody Agreement is made Iday of 2008, by and between April Nicole Hoover, (Hereinafter referred to as "Mother"), of Carlisle, Cumberland County, Pennsylvania, and Eli J. Hoover, (Hereinafter referred to as "Father"), of Carlisle, Cumberland County, Pennsylvania; WHEREAS, Mother and Father are the natural parents of one child, namely, Ian Trevor Hoover, born June 11, 2007; WHEREAS, Mother and Father have reached an agreement relative to the future care and custody of their child, the terms of which agreement both parties desire to set forth in the present Agreement, and; WHEREAS, Mother and Father desire the provisions of the present Agreement be approved by the Honorable Court of Common Pleas of Cumberland County and entered as a Court Order, with the same force and effect as though said Order had been entered after Petition, Notice and Hearing. There is no previous Order of Court concerning the child. NOW THEREFORE, the parties, intending to be legally bound, and in consideration of the mutual promises and agreements contained herein, hereby agree as follows: 1. Joint Legal Custody. Legal custody is the legal right to make all major non- emergency decisions affecting a minor child's well being, including, but not limited to, all decisions regarding his or her health, education, and religion. Mother and Father shall have joint legal custody of their child, Ian Trevor Hoover, born June 11, 2007. Notwithstanding that both parents shall share legal custody, non-major decisions involving the child's day-to-day living shall be made by the parent then having physical custody, consistent with the other provisions of this Agreement and subsequent Order. Pursuant to this section, the parties agree that: Nlk ? A A. Each party shall confer with the other on all matters of importance including but not limited to issues relating to the child's health and education. A t0A B. Each party agrees to keep the other informed of his or her residence and telephone number to facilitate communication concerning the welfare of each child and visitation period. Each party agrees to supply the name, address, and telephone numbers of any person in whose care the child will be in for a period in excess of forty-eight (48) hours, and for each person or entity which may provide daycare for a child. ANA C// C. Pursuant to the terms of 23 Pa. C.S. §5309, each parent shall be entitled to all records and information pertaining to the child, including but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of such records or information, and such information has not been provided to the other parent, 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. A04 D. Neither party shall attempt to undermine the mutual love and affection that each child may have for the other parent and neither parent shall, in the presence of the child make any disparaging or negative remarks concerning the other parent. 2. Emergency Decisions. Emergency decisions regarding a child shall be made by the parent then having physical custody of the child. However, in the event of any emergency or serious illness of a child at any time, any party then having custody of the child shall communicate with the other party by telephone or any other means practicable, informing the other party of the nature of the illness or emergency, so the other parent can become involved in the decision making process as soon as possible. 3. Physical Custody. Physical custody is defined as actual physical possession and control of a child. The parties shall share physical custody of the child. 4. Schedule of shared physical custody. As of the date of this agreement, that parties are not separated, and are living in at the same residence with the child. The parties have discussed the arrangements, with respect to the best interest of the child, and have agreed that upon separation, the parties shall share physical custody of the child as follows: a. Bi-Weekly rotating schedule: The parties shall share custody on a two week rotating schedule, with Week A to start on November 30, 2008. Week A: Father shall have the child from Sunday at 6 p.m. through Wednesday morning. Mother shall have the child from Wednesday at 5:00 p.m. through Friday morning. Father shall have the child from Friday at 5:00 p.m. through Sunday at 6:00 p.m. Week B: Mother shall have the child from Sunday at 6 p.m. through Wednesday morning. Father shall have the child from Wednesday at 5:00 p.m. through Friday morning. Mother shall have the child from Friday at 5:00 p.m. through Sunday at 6:00 p.m. b. Holidays: For Thanksgiving, Father shall always have the child from 9:00 a.m. through 2:00 p.m. and Mother shall always have the child from 2:00 p.m. on Thanksgiving through 8:00 p.m. Christmas: Block A shall be defined as Christmas eve at 5:00 p.m. through Christmas Day at 2:00 p.m. Block B shall be defined as Christmas Day at 2:00 p.m. through Christmas Day at 8:00 p.m. During even numbered years, Father shall have the child for Block A and Mother shall have the child for Block B. During odd numbered years, Mother shall have the child for Block A and Father shall have the child for Block B. Easter: For Easter, the parent who has the child on the Saturday before Easter Sunday shall relinquish the child to the other parent for a period of physical custody on Easter which will last from 2:00 p.m. on Easter Sunday through 8:00 p.m. on Easter Sunday. Mother shall always have the child on Mother's day from 9:00 a.m. through 6:00 p.m. and Father shall always have the child on Father's day from 9.00 a.m. through 6:00 p.m. Each party may have a vacation period of one week with the child, to consist of six consecutive overnights, during a period which does not interfere with the child's EH An?-I- schooling, provided thirty (30) days notice is given to the other parent. The parent going on vacation with the child shall provide the other parent with a basic itinerary or location of the intended trip and contact telephone number(s). 5. Insurance. Mother currently provides health insurance for the child. The parties agree that they shall equally divide all unreimbursed medical expenses for the child, including but not limited to eye, dental, or orthodontist expenses. There is currently no child support order. If a child support order is entered, the terms of the subsequent order shall supercede this section. Nothing in this agreement shall prevent the parties from requesting a modification of this agreement if there is a substantial change in the circumstances of the parties, or the child, and this agreement shall not contractually obligate the Plaintiff or Defendant to pay an amount per month without regard to the circumstances of the parties or the child, or the applicable child support guidelines. 6. Transportation and Exchange. The transportation shall be shared equally by the parties, with the parent who is to receive custody at the time of the exchange to provide for transportation from the residence or location of the other parent. At all times, all children shall be secured in appropriate passenger restraints. 7. Best Interest of the Child. The parties understand that in making an order for custody, the court shall consider the best interest of the child, which may include any factor which impacts the child's physical, psychological, intellectual, and emotional well- being. Such factors may include but are not limited to: the age of the child, the child's relationship with each parent, the preference of the child, (if old enough to express a meaningful preference), the duration, adequacy and stability of the child's current living arrangements, the motive of each parent, the child's school and community, the openness of each parent to allow and encourage frequent and continuing contact between the child and the other parent, including physical access, and the capacity of each parent to cooperate with each other and teachers or child care providers. The parties have considered all of the above factors, and have attempted to craft a custody agreement which provides for the best interest of the child or children. The parties understand that while this matter could be heard by the Court, they are not requesting a hearing or court intervention on this matter, at this time, as they have been able to reach an agreement beneficial to the child or children, and it is in the best interest of the child or children and the parties to resolve this matter without litigation and with minimal conflict. 8. Binding Effect and Order. This Agreement and all of its terms and conditions shall extend to and be binding upon the parties. The parties shall request that this Agreement be incorporated into a Court Order without further hearing. The EN parties are free to modify the terms of this Agreement and Order verbally or in writing but in order to do so both parties must be in complete agreement to any different terms. That means both parties must consent on what the terms of the custody arrangement or schedule shall be. 9. Governing Law. This Agreement shall be governed and controlled by the laws of Pennsylvania. IN WITNESS WHEREOF, the parties have hereto duly executed the present Stipulation and Custody Agreement the day and year first above written. WITNESS: April icole Hoover, Mother Date: L'A fitness El J. Hoover, Father ?# 4? vZ ELI J. HOOVER, Plaintiff vs. APRIL NICHOLE HOOVER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 08 - 6580 Civil Term ACTION IN CUSTODY ORDER AND NOW, this .rvw- day of 2008, having reviewed the attached agreement between the parties dated November 25th, 2008, it is hereby ORDERED and DECREED as follows: 1. Eli J. Hoover and April Nichole Hoover shall have shared legal custody of their child, Ian Trevor Hoover, born June 11, 2007. 2. Eli J. Hoover and April Nichole Hoover shall have shared physical custody as provided in the parties' written agreement. 3. The parties' agreement, dated November 25th, 2008, and attached hereto, shall be incorporated into this Order of Court. V. cc: z Michael Whare Esquire, for father Jane Adams, Esquire, for mother (20P` 12s eraI LC4 ' r ?-: Vii., ?... ?. . ?i_ ?, i..? I ?? 4 .3-- :: t"? ?? 4-?+' @? i ?` ? r '? t? C.? ..? ??e C" .y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Eli J. Hoover, Plaintiff V. April Nicole Hoover, Defendant PRAECIPE FOR WITHDRAWAL AND ENTRY OF APPEARANCE SHARPE & SHARPE, LLP ATTORNEYS AT LAW 257 Lincoln Way East Chambersburg, PA 17201 (717) 163-8447 To the Prothonotary: Please withdraw the appearance of Jane Adams as counsel for the Defendant, April Nicole Hoover, in the above captioned case and enter the appearance of Suzanne M. Trinh as counsel for the Defendant. Date: 3 t 47 Civil Action - Law No. 08-6580 Civil Term In Divorce and Custody SHARPE & SHARPE, LLP By: J e Adams torney for Defendant ttorney I.D. # q IL/ 17 W. South Street Carlisle, PA 17013 Phone # (717) 245-8508 uz n M. Trinh Atto ey for Defendant Attorney I.D. #92747 Sharpe & Sharpe, LLP 257 Lincoln Way East Chambersburg, PA 17201 (717) 263-8447 ev ` 7 - r ftt :: ?1 Uzi s ELI J. HOOVER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law APRIL NICOLE HOOVER, Defendant : No. 08-6580 CIVIL TERM : IN DIVORCE PRAECIPE TO WITHDRAW COMPLAINT UNDER SECTIONS 3301(c) AND 3301(d) OF THE DIVORCE CODE TO THE PROTHONOTARY: Please withdraw the Complaint in Divorce filed on November on 24, 2008, on behalf of the Plaintiff in the above captioned action. Respectfully submitted, Date: ?'Iy' 69 IVI.Aj 4 1%,-A Michael J. Where, FAquire 37 East Pomfret Street Carlisle, PA 17013 Supreme Ct. Id No. 89028 Attorney for Plaintiff FILED--(j?HCE r%c PAT] !''!NOTARY 2009 AUG 2 ! AM 10: 5 5 PEIN vSYYLVA-MA