HomeMy WebLinkAbout09-3560NATHAN C. WOLF, ESQUIRE
ATTORNEY ID NO. 87380
10 WEST HIGH STREET
CARLISLE PA 17013
cm) 241-4436
ATTORNEY FOR PLAINTIFF
CHERIESE N. THOMAS,
Plaintiff
V.
THOMAS-LEE THOMAS, : NO. 2009 - 35-606 CIVIL TERM
Defendant : IN CUSTODY
COMPLAINT FOR CUSTODY
NOW comes the plaintiff, Cheriese N. Thomas, by her attorney, Nathan C. Wolf, Esquire, and
presents the following complaint for custody, representing as follows:
1. The plaintiff is Cheriese N. Thomas, an adult individual residing at 20 East Pomfret Street,
Carlisle, Cumberland County, Pennsylvania 17013.
2. The defendant is Thomas-Lee Thomas, an adult individual residing at 1361 Zimmerman
Road, Carlisle, Monroe Township, Cumberland County, Pennsylvania 17015.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
3. Plaintiff seeks equal primary physical custody of the following child:
Name
Present Residence
Age
Thomas-Lee Thomas, Jr.
20 East Pomfret Street
Carlisle, PA 17013
4. Plaintiff and defendant are the natural parents of the child.
5. The child was born of the marriage of the parties.
2 years
D.O.B. 5/14/2007
6. The parties were married August 10, 2005 and have been separated since October 2006.
7. Mother moved to Pennsylvania with the child on April 8, 2009, and has resided at the
above-address since that time.
8. Mother moved to Pennsylvania with the child in an attempt to relocate to an area which
was near the child's father and because she believed that Father would provide her with financial and
emotional assistance as she established herself.
9. Prior to that time Mother and the child had resided in Havelock, Craven County, North
Carolina since the child's birth in 2007.
10. Mother's parents and siblings reside in Havelock, and Mother had resided in Havelock,
North Carolina since 2000 with the exception of the three month time period when Mother resided
with Father at Camp Lejuene, North Carolina, until Father kicked Mother out of their home while
Mother was approximately three months pregnant.
11. Mother has had sporadic contact with Father since their separation in approximately
October 2006.
12. Father was discharged from the United States Marine Corp in September 2007, when he left
North Carolina and moved to south central Pennsylvania where his parents reside.
13. Mother made numerous attempts to communicate with Father concerning the child and his
progress, and Father had essentially dismissed or ignored Mother's attempts.
14. Shortly after arriving in Pennsylvania, Mother had arranged for Father to have some
supervised visits with the child, but Mother would not agree for Father to have unsupervised visits as
Father did not have a valid driver's license
15. The child is presently in the custody of Father and but resided primarily in Mother's
custody since the child was born. Father has not previously had periods of partial physical custody of
the child. Father's visitation with the child was always supervised by Mother.
16. On or about May 23, 2009, Father requested to see the child and Mother refused because
she believed that Father was under the influence of alcohol. Father came to the area of Mother's
residence but Father has been excluded from Mother's residence because of prior incidents of
harassment of Mother, which resulted in a criminal citation for the same.
17. Father approached Mother and the child on the sidewalk in front of Mother's residence
and continued to ask Mother for the opportunity to exercise custody of the child. Mother again
refused to allow Father to leave with the child as Mother was able to observe that Father was
intoxicated.
18. Father thereafter acted as if he was merely giving the child a hug when he snatched the child
and placed him in his car and then drove away.
19. Mother has been denied any contact with the child since that time.
20. Mother has been denied any assistance from various police agencies from whom she sought
assistance.
21. Contemporaneous with the filing of this complain, Mother has filed a petition for special
relief.
22. 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.
23. Plaintiff has no information of a custody proceeding concerning the child pending in a
court of this Commonwealth or any other state.
24. Plaintiff does not know of a person not a parry to the proceedings who has physical custody
of the child or claims to have custody or visitation rights with respect to the child.
25. Mother has been solely responsible for the child's medical, educational, psychological and
recreational needs for all of the child's life.
26. Mother requests that custody be granted to her and reserves the right to seek permission to
relocate to her home state of North Carolina with the child and will be prepared to address such a
request at the time of a future conciliation conference or hearing in this matter.
27. The best interests and permanent welfare of the child will be served by granting Mother
primary physical custody, granting Father periods of visitation, and by granting the parties shared legal
custody.
WHEREFORE, for the reasons set forth herein, Plaintiff, Cheriese N. Thomas, respectfully
requests that the Court enter an order granting equal shared legal custody of the child to the parties,
granting her primary physical custody of the child and permission to return with the child to North
Carolina, granting Father partial physical custody of the child, along with any additional relief that the
Court deems appropriate and just.
WOLF OLF, Attorney at Law
Dated: May M 2009
olf, Esquire
HFwh Street
Carlisle, PA 17013
Supreme Court I.D. No. 87380
(717) 241-4436
Attorney for Plaintiff
VERIFICATION
I do hereby verify that the facts set forth in this complaint are true and correct to the best of my
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.
May 2009 kiuyy ?
Cheriese N. Thomas
NATHAN C. WOLF, ESQUIRE
ATTORNEY ID NO. 87380
10 WEST HIGH STREET
CARLISLE PA 17013
(717) 2414436
ATTORNEY FOR PLAINTIFF
CHERIESE N. THOMAS,
Plaintiff
V.
THOMAS-LEE THOMAS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2009 - CIVIL TERM
IN CUSTODY
CERTIFICATE OF SERVICE
I, Nathan C. Wolf, Esquire, have served a true and correct copy of Complaint for Custody
upon the following person and in the matter indicated:
SERVICE BY U.S. MAIL:
Thomas-Lee Thomas
1361 Zimmerman Road
Carlisle, PA 17015
Respectfully submitted,
WOLF & WQLF, Attorney at Law
Dated: May Z:, 2009
Nath old Esquire
10 High Street
Carlisle, PA 17013
Supreme Court I.D. No. 87380
(717) 241-4436
Attorney for Plaintiff
ck # O-9I 3
2-A: )- 1-6- IF/T
NATHAN C. WOLF, ESQUIRE
ATTORNEY ID NO. 97380
10 WEST HIGH STREET
CARLISLE PA 17013
(717) 2414436
ATTORNEY FOR PLAINTIFF
CHERIESE N. THOMAS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
THOMAS-LEE THOMAS, : NO. 2009 - 3 ,,60 CIVIL TERM
Defendant : IN CUSTODY
PETITION FOR SPECIAL RELIEF
AND NOW comes the Petitioner, Cheriese N. Thomas, by her attorney, Nathan C. Wolf,
Esquire, and files this petition for special relief respectfully representing as follows:
The plaintiff is Cheriese N. Thomas, an adult individual residing at 20 East Pomfret Street,
Carlisle, Cumberland County, Pennsylvania 17013.
2. The defendant is Thomas-Lee Thomas, an adult individual residing at 1361 Zimmerman
Road, Carlisle, Monroe Township, Cumberland County, Pennsylvania 17015.
3. The plaintiff and defendant are the natural parents of one minor child, namely:
Name Present Residence Age
4. Thomas-Lee Thomas, Jr. 20 East Pomfret Street 2 years
Carlisle, PA 17013 D.O.B. 5/14/2007
5. Mother and Father are married but have been separated since October 2006, which was
prior to the child's birth and when Mother was approximately three months pregnant.
6. Mother moved to Pennsylvania from Havelock, North Carolina with the child on April 8,
2009.
7. Shortly after arriving in Pennsylvania, Mother had arranged for Father to have some
supervised visits with the child, but Mother would not agree for Father to have unsupervised visits as
Father did not have a valid driver's license and she believes Father does not have a car seat for the child
or automobile insurance.
8. The only contact Father has had with the child since birth has been visitation supervised by
Mother.
9. On or about May 23, 2009, Father requested to see the child and Mother refused because
she believed that Father was under the influence of alcohol. Father came to the area of Mother's
residence but Father has been excluded from Mother's residence because of prior incidents of
harassment of Mother, which resulted in a criminal citation for the same.
10. Father approached Mother and the child on the sidewalk in front of Mother's residence and
continued to ask Mother for the opportunity to exercise custody of the child. Mother again refused to
allow Father to leave with the child as Mother was able to observe that Father was intoxicated.
11. Father thereafter acted as if he was merely giving the child a hug when he snatched the
child and placed him in his car and then drove away.
12. Upon information and belief, Father does not have a valid driver's license, does not have an
appropriate car set within which to secure the child, and does not have valid insurance for his
automobile.
13. Mother has been denied any contact with the child since that time.
14. Mother has been denied any assistance from various police agencies from whom she sought
assistance.
15. Mother has, simultaneously with the filing of the instant Petition, also filed a Complaint for
Custody with the Court.
16. Mother is willing to supervise Father's visitation of the child for at least two (2) hours per
week.
17. Mother is willing to remain in the jurisdiction with the child pending a conciliation
conference in this matter, at which time she reserves the right to request Court approval to return to
her home state of North Carolina with the child.
18. Mother believes and therefore avers that it would be in the best interests of the child for
this Court to issue an Order for Special Relief, directing Father to return the child to Mother's custody
and to grant temporary primary physical custody to Mother and shared legal custody of the child to the
parties pending the opportunity for a hearing before the Court on the permanent custody of the child.
WHEREFORE, Petitioner, Cheriese N. Thomas, prays this Honorable Court enter a
Temporary Custody Order directing Respondent, Thomas-Lee Thomas, to return immediately return
the child to Mother's custody, and granting temporary primary physical custody of the child to Mother
pending the opportunity for a hearing before the Court or a conciliation conference concerning the
permanent custody of the child, granting periods of supervised visitation to Father, and granting shared
legal custody of the child to the parties pending further Order of Court, and directing the Court
Administrator to schedule an expedited hearing to address the issues raised in this matter.
Dated: May _, 2009
y?QMolf, Esquire
High Street
PA 17013
Supreme Court I.D. No. 87380
(717) 241-4436
Attorney for Plaintiff
VERIFICATION
I do hereby verify that the facts set forth in this petition are true and correct to the best of my
information and belief. I understand that false statements herein are made subject to the penalties of
18 Pa.C.S. §4904, relating to unworn falsification to authorities.
May a-, 2009
0 )'-0 n-A.-4
Cheriese N. Thomas
1 ? ? of
NATHAN C. WOLF, ESQUIRE
ATTORNEY ID NO. 97380
10 WEST HIGH STREET
CARLISLE PA 17013
(717) 2414436
ATTORNEY FOR PLAINTIFF
CHERIESE N. THOMAS,
Plaintiff
V.
THOMAS-LEE THOMAS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 2009 - CIVIL TERM
: IN CUSTODY
CERTIFICATE OF SERVICE
I, Nathan C. Wolf, Esquire, attorney for Plaintiff, do hereby certify that I have served a
copy of the foregoing Petition for Special Relief upon the following individual by postage prepaid
mail, addressed as follows:
Thomas-Lee Thomas
1361 Zimmerman Road
Carlisle, PA 17015
Respectfully submitted,
Na a f, Esquire
Att for Plaintiff
Date: May A 2009
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CHERIESE N. THOMAS IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
2009-3560 CIVIL ACTION LAW
THOMAS-LEE THOMAS IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Friday, May 29, 2009 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, June 03, 2009 at 1:30 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/ ac ueline M. Verne Es .
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
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CHERIESE N. THOMAS,
Plaintiff
V.
THOMAS-LEE THOMAS,
Defendant
MAY Z 9 Mgc4
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2009 - 3 66 CIVIL TERM
IN CUSTODY
ORDER OF COURT
tIN day MOV , 2009 upon consideration of the Attached Petition for
NOW this y o
Special Relief, the following Order is hereby issued:
1. Pending further Order of Court in this matter, Father is directed to immediately return the
child to Mother's custody, and primary physical custody of the child shall be with Mother
and that legal custody shall be shared by the parties.
2. Any law enforcement agency having jurisdiction over the child is authorized to assist
Mother in securing custody of the child from Father.
3. Pending further Order of Court, Father is granted periods of supervised visitation with the
child by agreement of the parties, but shall not be less than two hours per week.
4. Mother is directed to file a Complaint for Custody within five (5) days.
5. The Court Administrator's office is directed to schedule an expedited hearing in this matter
to fully address the issues presented in this matter.
By the Court,
Nathan C. Wolf, Esquire C,?,; 15 rnatio? of "Vtr"d
For the Plaintiff S 0?
do
Thomas-Lee Thomas, pro-se -,el A (ed S%l5-a4
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CHERIESE N. THOMAS,
Plaintiff
vs.
THOMAS-LEE THOMAS,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2009 - 3560 Civil Term
IN CUSTODY
PLAINTIFF'S RESPONSE TO
DEFENDANT'S PETITION FOR SPECIAL RELIEF
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7. Denied. Father did go to see Mother and the child at her residence and
Father and Paternal Grandmother did have periods of unsupervised visits beginning
April 8, 2009. Father does have a car seat for the child.
8. Denied. Since Mother came to Pennsylvania, Father has had periods of
supervised and unsupervised partial custody with the child.
9. Denied in part, admitted in part. On or about May 23, 2009, Mother called
Father and asked, "Are you going to come pick up your son today?" Father asked to
pick the child up in the morning, and Mother indicated she wanted Father to pick up the
child in the afternoon. Father did not enter Mother's residence due to a prior alleged
incident.
10. Denied in part, admitted in part. Father did not enter the residence property
or sidewalk. Father had just gotten off of work and was not intoxicated. Mother had
indicated earlier that she wanted Father to get the child.
11. Denied. Father did not snatch the child; the parties had agreed earlier that
Father would have a period of partial custody with the child.
12. Denied in part. Father does have a car seat and the vehicle is insured.
13. Denied. On or about May 29, 2009, Mother obtained an emergency custody
Order granting her custody. On the evening of May 29, 2009, she came to Father's
employment, and was subsequently told to leave by a Steelton Police Officer. Mother
then returned at 10:00 p.m. with a State Constable and the emergency custody Order.
The Constable called paternal grandmother, and a meeting was set whereby the child
was returned to Mother pursuant to the emergency Order. Since that time, Mother has
denied Father all contact with the child.
14. Admitted in part, denied in part. Mother did not get any assistance from the
local police, but she did get assistance from a constable. See item 13.
15. Admitted.
16. Father does not believe that supervised visits are warranted, as Children
and Youth has recently had had contact with both parents and did not express any
concerns which would warrant supervised visitation.
17. Father objects to Mother leaving the jurisdiction with the child and requests a
relocation hearing on this matter.
18. Father believes it would be in the best interest of the child to enter a court
order providing Father with shared legal custody and substantial periods of partial
physical custody.
WHEREFORE, Plaintiff requests the court to DENY Petitioner's request for sole
custody and relocation and enter an Order for custody providing shared legal and
physical custody for both parties.
Date: 6(Y0/
Respectfully submitted,
I. D. Po. 79465
17 )AI. South St.
rlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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 unsworn falsification to authorities.
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Tho s e omas, and t
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CHERIESE N. THOMAS,
Plaintiff
V.
THOMAS-LEE THOMAS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2009-3560
: IN CUSTODY
ORDER OF COURT
CIVIL ACTION - LAW
AND NOW, this U- day of ?v vie_. , 2009, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
The prior Order of Court dated May 29, 2009 is hereby vacated.
2. The Mother, Cheriese N. Thomas and the Father, Thomas-Lee Thomas,
shall have shared legal custody of Thomas Lee Thomas, Jr., born May 14, 2007. Each
parent shall have an equal right, to be exercised jointly with the other parent, to make all
major non-emergency decisions affecting the Child's general well-being including, but
not limited to, all decisions regarding his health, education and religion. 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 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. Both parents shall be
entitled to full participation in all educational and medical/treatment planning meetings
and evaluations with regard to the minor child. Each parent shall be entitled to full and
complete information from any physician, dentist, teacher or authority and copies of any
reports given to them as parents including, but not limited to: medical records, birth
certificates, school or educational attendance records or report cards. Additionally, each
parent shall be entitled to receive copies of any notices which come from school with
regard to school pictures, extracurricular activities, children's parties, musical
presentations, back-to-school nights, and the like.
3. Mother shall have primary physical custody of the child.
4. Father shall have periods of partial physical custody the first week of July,
August and September, from Sunday to Sunday at a time and location near Richmond
Virginia agreed to by counsel for the parties.
5. Only a licensed driver shall transport the child.
r
6. Father shall have his mother care for the child during his week of physical
custody when he is working or not otherwise available.
7. Neither party may drink alcoholic beverages or use illegal drugs
immediately before or during their period of physical custody.
8. The parties shall have reasonable telephone contact with the child.
9. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control. Another
Custody Conciliation Conference is scheduled for September 29, 2009 at 10:30 a.m.
BY THE COURT,
14,-\, u-,\\
M.L. Ebert, Jr., J.
C. Wolf, Esquire, Counsel for Mother
cc: athan
,"Jane Adams, Esquire, Counsel for Father
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CHERIESE N. THOMAS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2009-3560 CIVIL ACTION - LAW
THOMAS-LEE THOMAS,
Defendant : IN CUSTODY
PRIOR JUDGE: M.L. EBERT, JR., J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME
Thomas Lee Thomas, Jr.
DATE OF BIRTH CURRENTLY IN CUSTODY OF
May 14, 2007
Mother
2. A Conciliation Conference was held in this matter on June 25, 2009, with
the following in attendance: The Mother, Cheriese N. Thomas, by telephone, with her
counsel, Nathan C. Wolf, Esquire, and the Father, Thomas-Lee Thomas, with his counsel,
Jane Adams, Esquire.
3. A prior Order of Court was entered by the Honorable M.L. Ebert, Jr. dated
May 29, 2009 providing for shared legal custody, Mother having primary physical
custody and Father having a 2-hour supervised visit.
4. The parties agreed to an Order in the form as attached.
S- g A ??z
Date ac eline M. Verney, Esqui e
Custody Conciliator
JAN 222ota ~
NATHAN C. WOLF, ESQUIRE
ATTORNEY ID NO. 87380
10 WEST HIGH STREET
CARLISLE PA 17013
(717) ?A1-4436
ATTORNEY FOR PLAINTIFF
CHERIESE N. THOMAS,
Plaintiff
v.
THOMAS-LEE THOMAS,
Defendant
IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 2009 - 3560 CIVIL TERM
IN CUSTODY
ORDER OF COURT
~j day of ~a'^ • , 2010, upon consideration of the
AND NOW this
foregoing Petition for Leave to Withdraw as Counsel for Plaintiff Cheriese N. Thomas, the
requested xelief therein his hereby GRANTED and counsel is hereby authorized to file a praecipe to
withdraw as counsel with the Prothonotary and to serve notice of this Order and such praecipe
upon Plaintiff Cheriese N. Thomas and counsel for all other parties to this matter.
M. L. Ebert, Jr., J.
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~~eriese N. Thomas, pro se ...~
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Court Administration -='. ~o '`-
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NATHAN C. WOLF, ESQUIRE
ATTORNEY ID NO. 57380
10 WEST HIGH STREET
CARLISLE PA 17013
(717) 241-4436
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CHERIESE N. THOMAS, : Il~]`T~I~' O'i~RT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v.
THOMAS-LEE THOMAS,
Defendant
CIVIL ACTION -LAW
NO. 2009 - 3560 CIVIL TERM
IN CUSTODY
PRAECIPE TO WITHDRAW APPEARANCE OF
COUNSEL OF RECORD
TO THE PROTHONOTARY:
Please withdraw the appearance of NATHAN C. WOLF, ESQUIRE, as attorney of record
for Plaintiff, CHERIESE N. THOMAS, in this matter.
January~%0 , 2010
~'C. WOLF, ESQUIRE
& WOLF
10 West High Street
Carlisle, PA 17013
717-241-4436
SUPREME COURT ID #87380
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 2009 - 3560 CIVIL TERM
IN CUSTODY
CERTIFICATE OF SERVICE
I, Nathan C. Wolf, Esquire, hereby certify this day that I mailed a true and correct copy of the
NATHAN C. WOLF, ESQUIRE
ATTORNEY ID N0.87380
WOLF & WOLF
10 WEST HIGH STREET
CARLISLE PA 17013
(717) 241-4436
CHERIESE N. THOMAS,
Plaintiff
v.
THOMAS-LEE THOMAS,
Defendant
foregoing Praecipe to Withdraw Appearance of Counsel of Record, by U. S. Mail, postgage prepaid,
to the following:
Cheriese N. Thomas
c/o Carolina Simmons
220 Shipman Road, Apt. D19
Havelock, NC 28532
Jane E. Adams, Esquire
17 W. South Street
Carlisle, PA 17013
Counsel for Defendant
Dated: January Z~, 2010
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Cheriese Thomas,
Plaintiff
v.
Thomas-Lee Thomas,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0.2009-3560
IN CUSTODY
ORDER OF COURT
CIVIL ACTION-LAW
d
AND NOW, this ~3 day of February, 2010, upon consideration of the attached
Motion for Continuance, the hearing scheduled for February 26, 2010 is conAAti~~nued to the
(~/ZC3U~- ~oZ.
5~" day of 2010. (,1~ a-- D D p ~ ~...
BY THE COURT:
Cc: Jane Adams, Esquire
For Defendant
17 W. South Street
Carlisle, PA 17013
" Family Law Clinic
For Plaintiff
45 North Pitt Street
Carlisle, PA 17013
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M.L. Ebert, Jr.
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JUL 12 2010
CHERIESE N. THOMAS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V. : N0.2009-3560 CIVIL ACTION -LAW ~
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THOMAS-LEE THOMAS, -' c-- -~t`_ -n
Defendant : IN CUSTODY `=! ~ ` -`~" -r,`~-j
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ORDER OF COURT 1r ~-- '~•'
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AND NOW, this 9th day of July, 2010, having no contact with the parties to
request another Conciliation Conference, the Conciliator hereby relinquishes jurisdiction
in this matter.
FOR THE COURT,
~~- ~
acq line M. Verney, Esquire, stody Conciliator