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HomeMy WebLinkAbout09-6169 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MATTHEW DAWSON, Plaintiff V. KATRINA CARILLO, Defendant CIVIL ACTION 06. 01-6/4-7 CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Matthew Dawson who currently resides at 209 Key West Boulevard, Carlisle, Pennsylvania, which is in Cumberland County, Pennsylvania. 2. The defendant is Katrina Carillo who currently resides at 209 Key West Boulevard, Carlisle, Pennsylvania, which is in Cumberland County, Pennsylvania. 3. The plaintiff is seeking custody of the following child: Name Residence Age Cameron Matthew Dawson 209 Key West Boulevard Carlisle, PA 17013 Cristian Curtis Dawson 209 Key West Boulevard Carlisle, PA 17013 2 (DOB - 8/27/2007) 5 mo. (DOB 3/31/2009) The children were born out of wedlock. The children are under the age of five. During the children's life, the children have resided with the following persons and at the following addresses: (List all Persons) (List all Addresses (Dates) Matthew(Plaintiff), 209 Key West Boulevard March 2008 Katrina (Defendant), and Carlisle, PA 17013 - present Kristine Carillo (Katrina's child) Matthew, Katrina, Kristina and Mary B O'Donnell (Katrina's mother) 3023 Derry Street Harrisburg, PA Jan 2008 - March 2008 Matthew, Katrina and Karina 22 Lincoln Street York, PA birth - Jan. 2008 The mother of the children is Katrina Carillo, currently residing at 209 Key West Boulevard, Carlisle, Pennslyvania. Upon information and belief, Katrina is planning to move from this address and Plaintiff will update the Court as necessary and appropriate. She is single. The father of the child is Matthew Dawson, currently residing at 209 Key West Boulevard, Carlisle, PA. He is single. 4. The relationship of plaintiff to the children is that of father. The plaintiff currently resides with the following person. None. 5. The relationship of defendant to the children is that of mother. The defendant currently resides with the following person. Mary B. O'Donnell (mother) 6. 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. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. 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 children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: Plaintiff is willing and able to perform the primary parental responsibilities for the children. Plaintiff is in the best position to provide the care and nurture which the children need for healthy development due to the defendant's lack of housing and resources. Defendant is not able to provide for the children's physical, psychological or social needs while they are in her care and has made statements that she does not want the responsibility of caring for the children. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, plaintiff requests the court to grant him custody of the minor children. Sheri D. Coover, Esquire Attorney ID 92385 44 S. Hanover Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MATTHEW DAWSON, CIVIL ACTION Plaintiff V. KATRINA CARILLO, CUSTODY Defendant VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Date: Q_ ID. zw 9 f A/ atthew Dawson OF THEE ° ;.?TAFY 2 0 0 9 SEP I I P 141 12: 310 kiN jo cea L, ,2-3oy73 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MATTHEW DAWSON, CIVIL ACTION Plaintiff 09-6169 vi. KATRINA CARILLO, CUSTODY Defendant PETITION FOR SPECIAL RELIEF AND NOW, comes Plaintiff Matthew Dawson, by and through his attorney, Sheri D. Coover, Esquire and files the following PETITION FOR SPECIAL RELIEF PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE RULE 1915.13 and in support thereof avers as follows: 1. On or around September 11, 2009 around 7:00 p.m., Defendant Katrina Carillo left the residence that she shared with the Plaintiff with the minor child Cristian Curtis Dawson (DOB 3/31/2009). 2. At the time that she left, Defendant Carillo failed to advise the Plaintiff as to where she was going with their child. 3. That evening and during the days of Saturday, September 12, and Sunday, September 13, 2009, the Plaintiff tried on numerous occasions to contact the Defendant to find out where she went with their child, but the Defendant failed to answer his telephone calls and failed to return his call. 4. As of the date of the filing of this document, Defendant has failed to let the Plaintiff know where she is staying with their minor child and who is taking care of their child during the time that the Defendant is at work. 5. Defendant left the minor child Cameron (DOB 8/27/2007) with the Plaintiff and has not inquired about him with the Plaintiff or asked to see him despite the fact that she knew that Cameron was staying with the Plaintiff in the residence that she had shared with them prior to her leaving and that Plaintiff had told the Defendant that she was welcome to see or visit with the children at any time while they are in his care. 6. Defendant has previously left the residence that she shared with the Plaintiff on four other occasions when she would take the couple's two children with her and not advise the Plaintiff for a matter of days that she has taken the children out of the area without his permission and without notifying him. 7. On the four other occasions that she left, Defendant failed to provide the Plaintiff with any information concerning the whereabouts or wellbeing of their children and failed to provide a legitimate telephone number where he could reach the children. 8. The Defendant works the 3-11 shift at her job and often stays out all night until the following morning or afternoon and then sleeps while Cameron (two years old) is awake and wandering around the home, making him vulnerable to any kinds of dangers. 9. The Defendant is under the care of a doctor for depression and has not been taking the medication that has been prescribed for her. 10. The Plaintiff is the primary care provider for the children. 11. At times, when the Defendant has had the children, she keeps them out until unreasonably late times, despite the fact that it is in the best interest of the children for them to be in bed. 12. The Plaintiff has consistently lived in the residence with the children and is able and willing to provide the children with a stable home. 13. A custody complaint was filed by Plaintiff with this Court on September 11, 2009 in which he sought primary physical custody of the minor children. As of the time of the filing of this Petition for Special Relief, a conciliation conference has not yet been scheduled. 14. Undersigned counsel attempted to contact the office of Defendant's counsel but was unsuccessful. At the time of the filing of this petition, his position on the foregoing Petition for Special Relief is unknown. WHEREFORE, plaintiff requests the court to grant him custody of the minor children. submitted, ?eri D. Coover, Esquire Attorney ID 92385 44 S. Hanover Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MATTHEW DAWSON, CIVIL ACTION Plaintiff ?q - 6 we q v. KATRINA CARILLO, CUSTODY Defendant VERIFICATION I verify that the statements made in this Petition for Special Relief are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. /4agw aDatel q-ly-zoo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MATTHEW DAWSON, CIVIL ACTION Plaintiff 09-6169 vii. KATRINA CARILLO, CUSTODY Defendant CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certify that on this 14' day of September, 2009, I caused the foregoing PETITION FOR SPECIAL RELIEF to be served upon Defendant's counsel via United States First class mail addressed as follows: Justin McShane, Esquire 4807 Jonestown Road Harrisburg, PA submitted, S ri 0-Coover, Esquire Aitorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 FILED, OF THE 2009'SEP 14 PM x:00 _ T ????h'+t E `u? 1.1,,11;.,.1 ,d • ?'. *'TO.OC Po ATTY Cy.*# 385 pa's 'g.1,058 r MATTHEW DAWSON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KATRINA CARILLO DEFENDANT 2009-6169 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, September 17, 2004 , 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 16, 2009 at 8:30 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 hearinji. FOR THE COURT, By: /s/ Hubert X. Gilroy, Es q. lid\ 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 infonnation 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 Fit FD-1 OF THE Ry 2009 SEP 17 PM 2: 1 1 eil MATTHEW DAWSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V, CIVIL ACTION - LAW KATRINA CARILLO, Defendant NO. 09-6169 CIVIL TERM IN RE: PLAINTIFF'S PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 21" day of September, 2009, upon consideration of Plaintiff s Petition for Special Relief, following a telephone conference on September 21, 2009, with Sheri D. Coover, Esq., representing the Plaintiff, and Shawn Dorward, Esq., representing the Defendant, and it appearing to the court that the parties are communicating with each other and that the parties' children are not in immediate danger, Plaintiffs Petition for Special Relief is referred to Hubert X. Gilroy, Esq., the custody conciliator assigned to this case, for consideration at the conciliation conference scheduled for October 16, 2009. BY THE COURT, ? Sheri D. Coover, Esq. 44 South Hanover Street Carlisle, PA 17013 AA mey for Plaintiff Shawn Dorward Esq. ./ 4807 Jonestown Road Harrisburg, PA 17109 Attorney for Defendant C T1-es m? i lScl, Q/oa(4lo? 2009 SEP 24 AM 10: 19 Shawn M. Dorward, Esquire Attorney ID No. 209595 4807 Jonestown Road, Suite 148 Harrisburg, PA 17109 (717) 657-3900 Fax: (717) 657-2060 smd@themcshanefirm.com MATTHEW DAWSON, Plaintiff VS. KATRINA CARRILLO, Defendant :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION No. 2009-6169 CIVIL ACTION LAW IN CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY OF DAUPHIN COUNTY: Enter my appearance on behalf of the Defendant, Katrina Carrillo, in the above- captioned matter. Please note the correct spelling of Ms. Carrillo's name. Papers may be served at the address set forth below. Respectfully submitted, THE MCSHANE FIRM, LLC r? Shawn M. Dorward, Esquire Attorney ID No.: 209595 4807 Jonestown Road, Suite 148 Harrisburg, PA 17109 Telephone: (717) 657-3900 Fax: (717) 657-2060 Attorney for Plaintiff CERTIFICATE OF SERVICE I, Cathi Leigh McAdams, an employee of The McShane Law Firm, LLC, hereby certify that a copy of the foregoing Praecipe for Entry of Appearance was made via first class, postage prepaid mail, on October 8, 2009, to: Sheri D. Coover, Esquire 44 South Hanover St. Carlisle, PA 17013 r ? Date athi Leigh cAdams, Legal Assistant LED, Apy 2009 OCT 1 2 A E0: 364 0 ANDREW J. BENDER, ESQUIRE PA Supreme Court ID #: 205763 Allied Attorneys of Central Pennsylvania, L.L.C. 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 (717) 249-4514 Fax . CIVIL ACTION - LAW IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MATTHEW DAWSON, Plaintiff V. KATRINA CARILLO, Defendant STEPHEN R. MAITLAND, ESQUIRE PA Supreme Court ID#: 204853 Allied Attorneys of Central Pennsylvania, L.L.C. 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 (717) 249-4514 Fax NO. 09-6169 : IN CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the undersigned, and Allied Attorneys of Central Pennsylvania, L.L.C., as counsel for the Plaintiff, Matthew Dawson. 4z' ANDREW J. B ER, ESQUIRE PA Supreme Court ID# 205763 Allied Attorneys of Central Pennsylvania, L.L.C. 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 (717) 249-4514 Fax 40 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MATTHEW DAWSON, CIVIL ACTION - LAW Plaintiff : NO. 09-6169 V. KATRINA CARILLO, Defendant IN CUSTODY CERTIFICATE OF SERVICE The undersigned does hereby certify that a true and correct copy of the foregoing was served on the following by forwarding same U.S. Postal Service, postage pre-paid: Sean Darwood, Esquire 4807 Jonestown Road Harrisburg, PA 17103 DATE: l V jG 0 Andrew J. Bender, Esquire Attorney for Plaintiff PA Supreme Court ID # 205763 Allied Attorneys of Central Pennsylvania, L.L.C. 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 (717) 249-4514 Fax !{ry y?"' tJ rl 2009 OCT 16 AM 8. 12 OCT 19 2009 MATTHEW DAWSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW KATRINA CARILLO, NO. 2009-6169 Defendant IN CUSTODY COURT ORDER AND NOW, this day of October, 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Courtroom No. 1 of the Cumberland County Courthouse aoio on the day of , 3999, at. M. At this hearing, the Father shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a- Memorandum setting forth the history of custody in this case, the issues currently before the Court, a list of witnesses who will be called to testimony on behalf of each party and a summary of the anticipated testimony of each witness. This Memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, the following TEMPORARY Custody Order is entered: A. The father, Matthew Dawson, and the mother, Katrina Carillo, shall enjoy shared legal and shared physical custody of Cameron Matthew Dawson, born August 27, 2007, and Cristian Curtis Dawson, born March 31, 2009. B. Physical custody shall be handled on a two week schedule as follows: (1) In week one, Father shall have custody from Tuesday at 11:00 a.m. through Friday at 11:00 a.m., and Mother shall have custody from Friday at 11:00 a.m. through Tuesday at 11:00 a.m. (2) In week two, Father shall have custody from Tuesday at 11:00 a.m. through Saturday at 11:00 a.m., and Mother shall have custody from Saturday at 11:00 a.m. until Tuesday at 11:00 a.m. (3) The parties may modify or alternate the custody schedule as they agree. Absent an agreement, the terms of this Order shall be followed by the parties. C. The non-custodial parent shall pick the minor children up for exchange of custody unless agreed otherwise by the parties. cendrew J. Bender, Esquire Shawn M. Dorward, Esquire ?v?zo%ri BY THE COURT, MATTHEW DAWSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW KATRINA CARILLO, NO. 2009-6169 Defendant IN CUSTODY Prior Judge: The Honorable J. Wesley Oler, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Cameron Matthew Dawson, born August 27, 2007 Cristian Curtis Dawson, born March 31, 2009 2. A Conciliation Conference was held on October 16, 2009, with the following individuals in attendance: The mother, Katrina Carillo, who appeared with her counsel, Shawn M. Dorward, Esquire, and the father, Matthew Dawson, with his counsel, Andrew J. Bender, Esquire. 3. The parties have been separated for a few months and are unable to agree upon a Custody Order. Both parties are seeking primary physical custody. The parties have somewhat irregular work schedules which make the situation difficult for arranging a Temporary Order pending the hearing. However, the parties were able to reach an agreement at the Conciliation only for purposes of a Temporary Order, and each party is reserving the right to claim primary custody at the hearing. 4. Based upon the above, the Conciliator recommends an Order in the form as attached. Date: October 2009 /'2- y 'q Hubert X. Gilr , Esquire Custody Co liator ?? THE S 1 Ede" 3 'llG ,l i 2099 OCT 20 PH 2; 20 ITY CUM w JUL 1 U Yu~it! ~ • ~) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MATTHEW DAWSON PLAINTIFF VS. CASE NO. 2009-6169 KATRINA CARILLO DEFENDANT CUSTODY c .~. _~ ~,a; .a.~.. (~. ._ f„_ -- _ ;.,_, - ~,~ , .; ,, ;~ _ _ ORDER ~-- ~ r~ :: J AND NOW, this 7Jo~1 date, of , 2010, after due consideration of the Defendant's Motion to Continue, IT IS HEREBY ORDERED AND DECREED that the Defendant's Motion is hereby GRANTED, and this matter is continued to the ~~~ day of ~~, 2010, in Courtroom No. of the Cumberland County Courthouse ~' ~= 30~ ~ /n Distribution: Pr thonotary awn M. Dorward, Esquire, 4807 Jonestown Rd, Suite 148, Harrisburg, PA 17109 ~/5tephen Maitland, Esquire, 61 West Louther St., Carlisle, PA 17013 7~xc~td ?-ao ~a ~~ BY THE COURT: MATTHEW DAWSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS NO. 2009-6169 CIVIL KATRINA CARILLO, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 25th day of October, 2010, upon consideration of Plaintiff's Petition for Modification of a Partial Custody Order and following a hearing held on October 25, 2010, with respect to the parties children, Cameron Matthew Dawson(date of birth August 27th, 2007) and Cristian Curtis Dawson (date of birth March 31, 2009), the record is declared closed and the matter is taken under advisement. By the Court, J Wesley r, Stephen Maitland, Esquire For the Plaintiff ~hawn M. Dorward, Esquire For the Defendant :mlc I ~o~z~/~~ _'".'' - 1 c ~ ~ ~ ~, ~~ ~ ~rn cA'~ N a° -< z '~ , C --+c~ ~ <~ a ~ z't O Z O On t~1 37'~ -G "". -4 ORDER OF COURT 0 n c o -ri -~ w e z-n ~ r*r c~ c-~ rn r" ~ ~ ~ ~._ -~ rn ~ ~ ~ ~~ n ~ ~ ~ N ~ i Tt - ~ 't3 ; AND NOW, this 26`~ day of October 2010, upon consideration of Plaintiffls MATTHEW DAWSON, Plaintiff v. KATRINA CARILLO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.09-6169 CIVIL TERM IN RE: PLAINTIFF'S PETITION FOR MODIFICATION OF PARTIAL CUSTODY ORDER BEFORE OLER, J. Petition for Modification of Partial Custody Order, and following a hearing held on October 25, 2010, with respect to the parties' children, Cameron Matthew Dawson (d.o.b. August 27, 2007) and Cristian Curtis Dawson (d.o.b. March 31, 2009), it is ordered and directed as follows: 1. Legal custody of the children shall be shared by the parties; 2. Physical custody of the children shall be shared by the parties as follows: a. In week one, Father shall have physical custody of the children from Tuesday at 11:00 a.m. through Friday at 1:00 a.m., and Mother shall have physical custody of the children from Friday at 11:00 a.m. through Tuesday at 11:00 a.m.; and b. In week two, Father shall have custody from Tuesday, at 11:00 a.m. through Saturday at 11:00 a.m., and Mother .shall have physical custody of the children from Saturday at 11:00 a.m. until Tuesday at 11:00 a.m.; c. Each party shall keep the other advised at all times of the phone number where he or she can be reached; d. Nothing herein is intended to preclude the parties from deviating from the custodial terms herein by mutual agreement; and . ~ e. The parties are directed to participate in family counseling, the costs of which shall be shared equally by the parties. BY THE COURT, J~ esley O , Jr., J. tephen R. Maitland, Esq. 61 West Louther Street Carlisle, PA 17013 Attorney for Plaintiff awn M. Dorward, Esq. 4807 Jonestown Road Suite 148 Harrisburg, PA 17109 Attorney for Defendant :rc r ~ ! ES i'Yl~ t `~i..~ I ~a~a~~rv ,~ MATTHEW DAWSON, Plaintiff vs. KATRINA CARILLO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2009-6169 IN CUSTODY ORDER AND NOW this / day of November, 2011, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. r Hubert X. Gilro Esquire Custody Concil for ha (?. YF y-M O ! T r <> d ? r-= 4C? C:) C') M C5 n ..? ?- Y MATTHEW DAWSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-6169 CIVIL TERM KATRINA CARILLO, CIVIL ACTION- LAWS Defendant IN CUSTODY - = PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly withdraw the Petition to Modem Custody filed on September 21, 2011, in' the above captioned matter. Date: I 1411 Respectfully submitted, Rominger & Associates Karl . ominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Matthew Dawson ??? c??'r ??? r ?a?~?} . ``?' nn ^St r?\ ? 2312 APR -4 AN I I: J Shawn M. Dorward, Esquire Attorney ID No. 209595 'U,.,DERLAND COUNT'' 4807 Jonestown Road, Suite 148 F N N S Y LVA N I A Harrisburg, PA 17109 (717) 657-3900 Fax: (717) 657-2060 smd@themcshanefirm.com MATTHEW DAWSON, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. KATRINA CARILLO Defendant NO. 2009-6169 CIVIL ACTION - LAW IN CUSTODY TO THE HONORABLE JUDGE OF SAID COURT: PETITION TO WITHDRAW AS COUNSEL AND NOW, this 2nd day of April 2012, comes the Petitioner, Shawn M. Dorward, Esquire and petitions This Honorable Court to allow him to withdraw as counsel for the Defendant in the above- captioned matter and avers in support thereof as follows: 1. On October 12, 2009, the Petitioner, Shawn M. Dorward, Esquire, entered his appearance on behalf of the Defendant, Katrina Carillo and represented Ms. Carillo at several proceedings to present day. 2. This matter was most recently scheduled for a Custody Conciliation Conference on November 4, 2011. Undersigned counsel attempted by telephone and by correspondence to contact the Defendant to confirm she wanted the undersigned to represent her at the conference and also to request an additional retainer. The telephone number available to the undersigned had been disconnected and all mail was returned marked "Moved Left No Address". 3. As of this date, undersigned counsel has not been able to get in contact with the Defendant. 4. Neither party will be prejudiced by the withdrawal of the Petitioner, as counsel for the Defendant. WHEREFORE, Petitioner, Shawn M. Dorward, Esquire of The McShane Firm, LLC, hereby respectfully requests This Honorable Court enter an Order permitting the undersigned to withdraw as counsel for the Defendant in the above-captioned matter. Respectfully submitted, The McShane Firm, LLC o' Shawn M. Dorward, Esquire Attorney for Defendant 4807 Jonestown Road, Suite 148 Harrisburg, PA 17109 Tel: 717-657-3900 Fax: 717-657-2060 Attorney ID: 209595 CERTIFICATE OF SERVICE I, Denise M. Kendall, an employee of The McShane Firm, LLC, do hereby certify that a true and correct copy of the attached Motion to Withdraw as Counsel, was mailed by First Class, postage prepaid mail on April 2, 2012 to: Karl E. Rominger, Esquire 155 S. Hanover St. Carlise, PA 17013 Katrina Carillo 502 Water St. New Cumberland, PA 17070 Date: De se M. Kendall, Legal Assistant `n MATTHEW DAWSON, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-6169 KATRINA CARILLO : CIVIL ACTION - LAW Defendant : IN CUSTODY RULE TO SHOW CAUSE all ,_ ?ll AND NOW, this 5 day of n2012, a Rule is issued upon t? Vvtkek" pa&) Defeadaa to show cause, if any, why the Petitioner's Petition to Withdraw as Counsel should not be granted. This Rule is returnable within days of service thereof. Thomas A. Placeye Common Pleas Judge Distribution: Prothonotary's Office ?Shawn M. Dorward, Esquire., 4807 Jonestown Road, Suite 148, Harrisburg, PA 17109 Karl E. Rominger, Esquire, 155 S. Hanover St., Carlise, PA 17013 Katrina Carillo, 502 Water St., New Cumberland, PA 17070 q A///? ? 417 ? 10) t r, r° MATTHEW DAWSON V. KATRINA CARILLO IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL- VANIA No.: 2009-6169 CIVIL ACTION - LAW IN CUSTODY ORDER 1! .2 z AND NOW, this day of , 2012, after due consideration nd after considering response, if e a of the Counsel's Petition to Make Rule AbMOTU any, by the Plaintiff, IT IS HEREBY ORDERED AND DECREED that the Motion to Withdraw as Counsel is hereby GRANTED. It is further ORDERED AND DECREED that upon due consideration of counsel's Petition to Withdraw, counsel's motion is hereby GRANTED. BY THE UDGE Thom s A. Piacey Distribution: Common Pleas Judge Prothonotary's Office ? Shawn M. Dorward, Esq., 4807 Jonestown Road, Suite 148, Harrisburg, PA 17109,-) Karl E. Rominger, Esq., 155 S. Hanover St., Carlisle, PA 17013 iZ Katrina Carillo, 502 Water St., New Cumberland, PA 17070 MW zM ?r- ? r- d k s ?L mc:) j>C- _% C'\ N N -?-1 -< a r C? CD C}s W Cj c.s1