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HomeMy WebLinkAbout09-8225STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF MICHELLE L. SCHOCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff' : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW CHRISTOPHER W. SCHOCK, : NO. 09 - CIVIL TERM Defendant : 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 in 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 lose money or property or other rights important to you, including custody or visitation of your children. When the ground for 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. IF YOU DO 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, Pennsylvania 17013 717-249-3166 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF MICHELLE L. SCHOCK, Plaintiff v. CHRISTOPHER W. SCHOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 09 - CIVIL TERM IN DIVORCE AND CUSTODY COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301 OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: The plaintiff is Michelle L. Schock, an adult individual residing at 1331 Mountain Road, Newburg, Pennsylvania 17240. 2. The defendant is Christopher W. Schock, an adult individual residing at 169 CME, Newville, Pennsylvania 17241. 3. The plaintiff and defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on April 17, 1998 in Newville, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. The plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. COUNTI REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE The averments of Paragraphs 1 through 6 hereof are incorporated herein by reference. 8. The marriage between the parties is irretrievably broken. 9. After ninety (90) days have elapsed from the date of the filing and service of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. WHEREFORE, if both parties file Affidavits consenting to a divorce after ninety (90) days have elapsed from the filing and service of this Complaint, Plaintiff respectfully requests this Honorable Court enter a decree of divorce pursuant to ? 3301(c) of the Divorce Code. COUNT II REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(d) OF THE DIVORCE CODE 10. The averments of Paragraphs 1 through 9 hereof are incorporated herein by reference. 11. The marriage of the parties is irretrievably broken. 12. The parties are living separate and apart and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two years as specified in § 3301(d) of the Divorce Code. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter a decree of divorce pursuant to § 3301(d) of the Divorce Code. COUNT III CUSTODY 13. The averments of Paragraphs 1 through 12 hereof are incorporated herein by reference. 14. Plaintiff seeks custody of the following children: Name Present Mailing Address Age Branda L. Schock 1331 Mountain Road 10 years Newburg, PA 17240 D.O.B. 2/2/1999 Charlee J. Schock 1331 Mountain Road 2 years Newburg, PA 17240 D.O.B. 2/28/2007 15. Plaintiff and Defendant are the natural parents of the children. 16. The children were born during the marriage of the parties. 17. The children are presently in the custody of Plaintiff. 18. Since the children's birth, the children have resided with the following persons at the following addresses: Persons : Plaintiff Plaintiff/Defendant Address: 1331 Mountain Road Newburg, PA 17240 169 CME Newville, PA 17241 Dates: 11/18/2009-present birth-11/18/2009 19. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 20. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. 21. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 22. Mother has been the primary caregiver of the children since their birth. 23. The best interests and permanent welfare of the children will be served by granting the relief requested herein. WHEREFORE, for the reasons set forth herein, Plaintiff, Michelle L. Schock, respectfully requests that the Court enter an order granting her primary physical custody of the children. WOLF & 2009 BY: ?// STACY I WOIP, ESQUIRE Supreme Court ID #88732 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 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. Section 4904, relating to unsworn falsification to authorities. 2009 ( , I /Z ARY ?0 9 NOV 25 2 ! ! ? ? { a1e ? ?! i' f 1 9- 33 ct-k P-( 3 'k P d-3 z11 91 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF MICHELLE L. SCHOCK, Plaintiff V. CHRISTOPHER W. SCHOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 09 - er') -S CIVIL TERM IN DIVORCE AND CUSTODY PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. I Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities 2009 Mi helle L. ock, Plaintiff ' -- r Vey! MICHELLE L. SCHOCK, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLV ANIA CIVIL ACTION -LAW v, 9~~5-CIVIL TERM NO.2009- n nY V ~~ ~' CHRISTOPHER W. SCHOCK, rT ~ Defendant IN DIVORCE AND CUSTODY "~'~~- ~ ;~ v? _ ~~ N PRAECIPE ~., '~==.- `~ -s ~~ TO THE PROTHONOTARY: =~ c,~ c,,; WITHDRAWAL OF APPEARANCE Please withdraw my appearance on behalf of the Plaintiff in the above-captioned matter. Respectfully submitted, Date: ~~ ~= `" Stacy B. W ,Esquire Wolf & Wol 10 West High Street Carlisle, PA 17013 (717)241-4436 ENTRY OF APPEARANCE Please enter my appearance on behalf of the Plaintiff in the above-captioned matter. Respectfully submitted, Date: ~- 13r~ ie, Esquire F & ASSOCIATES 200 orth Hanover Street Carlisle, PA 17013 (717) 243-5551 ~_l -~ .....~ _~~ ,:~_ _~a 4 r f -~~ ~~~ .~ FEB 2 2 2010 MICHELLE L. SCHOCK, 1N THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v• N0.2009- ~e'~ CIVIL TERM CHRISTOPHER W. SCHOCK, IN DIVORCE AND CUSTODY Defendant J. WESLEY OLER, JR., JUDGE ORDER OF COURT AND NOW this ~, > day of ~ ~ ~ , 2010 upon presentation and consideration of the within Petition, the hearing previously scheduled in this matter for March 18, 2010 at 9:30 a.m. is hereby continued to _//~~u~ ,the ~?Q ,~, day of ~) ~_, 2010 at ~jL~o'clock Q .m. in Courtroom Number One of the Cumberland County Courthouse, Carlisle, Pennsylvania. All other provisions of our Order of December 22, 2009 scheduling the initial hearing in this matter shall remain in effect. A-i v r l.~ j~~ C..61 ~ ~~"~ 1 ~t r S c' f?~i~~ ~ +r1J~ C C. By the Court, ,- ` //:~ L•- `--~ ,~` J. Cc: Bradley L. Griffie, Esquire Attorney for Plaintiff ~rri D. Coover, Esquire Attorney for Defendant cs o ~-;; ~_, f; ..,.~ .~., ~ 'W ' 7'i f"" jJt ES /YL~ ~ ~ ,~ n ~~ I ~_ ~ ~ c _~ x. _, ~/a~r~w ~, ~~~ ~r~ ~ ~_, w :~ ~~ MICHELLE L. SCHOCK, Plaintiff v. CHRISTOPHER W. SCHOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW ~ ~? d ~_~ NO.2009-~ CIVIL TERM ~'`^-,, ~' -- c-a ~ ~' IN DIVORCE AND CUSTODY J. WESLEY OLER, JR., JUDGE "° {?~ - .~, ~ -} ,_~~; -_, ~-, PETITION FOR CONTINUANCE -= rv ~j r~i `-- ~, AND NOW comes Petitioner, Bradley L. Griffie, Esquire, and petitions the Court a`~s follows: 1. Your Petitioner is counsel of record for the above named Plaintiff, Michelle L. Schock. 2. Defendant, Christopher W. Schock, is represented by counsel, Sherri Coover, Esquire. 3. Plaintiff was represented previously in this matter by Stacy B. Wolf, Esquire. 4. Upon assumption of representation of the Plaintiff by your Petitioner, Petitioner and Plaintiff reviewed all of the details associated with custody of the children involved in this matter. 5. Petitioner and Plaintiff further reviewed the Order of December 22, 2009 entered in this matter which has caused a hearing to be scheduled for March 18, 2010 at 9:30 a.m., a copy of which Order is attached hereto and incorporated herein by reference as Exhibit "A". 6. Petitioner has been advised by the Court that the hearing is scheduled to occur from 9:30 a.m. until 12:00 noon on March 18, 2010, or a total period of two and one half (2%) hours. 7. Based upon the extensive information provided to Petitioner by Plaintiff and in anticipation of the need to call multiple witnesses in this involved custody matter, it is quite evident that the hearing will not be able to be concluded in a two and one half hour time period. 8. Upon recommendation of your Petitioner to Plaintiff, Plaintiff concurs in Petitioner's advice that the matter be continued to a later time so that the hearing can be scheduled for at least one (1) full day of testimony. 9. By correspondence dated February 5, 2010, Petitioner requested a concurrence to this continuance request from opposing counsel, Sherri D. Coover, Esquire, but no response has been forthcoming from Attorney Coover. 10. Any additional delay in the request for the continuance will simply mean additional delay until this matter can be heard and resolved by the Court. 11. The Order presently in effect is not in the children's best interest and should be modified after hearing. WHEREFORE, Petitioner requests your Honorable Court to reschedule the hearing presently scheduled for March 18, 2010 at 9:30 a.m. to a later date and for at least a full day hearing. Respectfully Submitted, y L/ riffie, Esquire Attorney for Plaintiff GRIFFIE AND ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: ~(~ ~ I (c~ Y . GRIFFIE MICHELLE L. SCHOCK, Plaintiff v. CHRISTOPHER W. SCHOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2009-~5~ CIVIL TERM ~~aS IN DIVORCE AND CUSTODY J. WESLEY OLER, JR., JUDGE CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire, hereby certify that I did, the ~_ day of February, 2010, cause a copy of Plaintiff/Petitioner's Petition for Continuance to be served upon DefendandRespondent's attorney by first class mail, postage prepaid at the following address: Sherri D. Coover, Esquire 44 South Hanover Street Carlisle, PA 17013 DATE: 1 ~ ` l J ~Jfbrney for Plaintiff/Petitioner GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 ' ~• n MICHELLE L. SCHOCK, Plaintiff/Respondent vs. CHRISTOPHER SCHOCK, Defendant/Petitioner MAY 1 12010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • ~iS N0.2009-3~5 CIVIL ACTION -LAW IN DIVORCE RULE TO SHOW CAUSE AND NOW, to wit, this C ~ day of ~ ~ ') 2010 u n po consideration of Plaintiff s Petition for Special Relief, a Rule is hereby issued upon Defendant to show cause, if any, why the relief requested should not be granted. RiJLE RETURNABLE IN - ~ -~-___ DAYS FROM SERVICE. cc: ~ieri D. Coover, Esquire, counsel for Petitioner/Defendant ./Bradley Crtiffie, Esquire, counsel for Defendant/Respondent I s~!3/!!~ ~~ n w ~..Y ~ z '. ~..~: ~c ~~> ~~ c N 0 0 a -~ w sa• c~ r l..y ~~r ~~_ ~~ ,~~+ ,~ -~ :., -; , MICHELLE L. SCHOCK, Plaintiff v. CHRISTOPHER SCHOCK, Defendant To the Prothonotary: ~~ S 'Pm ;~~ti ~~. ~ , , ._ r,.": IN THE C~(~U'1~T~OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 09-8225 CIVIL TERM IN DIVORCE/CUSTODY PRAECIPE TO WITHDRAW APPEARANCE Please withdraw the appearance of Sheri D. Coover, Esquire on behalf of the Defendant, Christopher Schock, in the above captioned case. .Submitted, Dated: July ~ , 2010 S eri D. Coover, Esquire upreme Court I.D. No. 94285 44 South Hanover Street Carlisle, Pennsylvania 17013 (717) 960-0075 To the Prothonotary: PRAECIPE TO ENTER APPEARANCE Please enter my appearance on behalf of the Defendant, Christopher Schock, in the above captioned case. Respectfully Submitted, IRWIN & McKNIGHT, P.C. Date: July ~`l , 2010 Douglas G i11er, Esquire Supreme C urt I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle; Pennsylvania 17013-3222 (717) 249-2353 CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the persons indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: BRADLEY L. GRIFFIE, ESQUIRE GRIFFIE & ASSOCIATES 200 NORTH HANOVER STREET CARLISLE, PA 17013 Date: August 5, 2010 IRWIN & McKNIGHT t` tbd , ougla G. Miller, Esquire Supreme Court I.D. # 83776 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 t - ~ . k` t,.f ~ l z ~ ~- Y~~ ~ e~~ l' ~'I' .?~~~2 AUK i 3 A~ 9~ S~ P~~d~l~YL~'~~h~!~"k MICHELLE L. SCHOCK, Plaintiff v. CHRISTOPHER W. SCHOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAI CIVIL ACTION -LAW NO.2009-8225 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on about November 25, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (9~0) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDA ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HER ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING UNSWORN FALSIFICATION TO AUTHORITIES. ,, ,-, _ ~ ~ DATE: /~ _ r I LLE L. O , Plai i , ii C i t ~ ,. r' ~ ~,i~C 13 AID S- ~;11~'9tEiLr''~i:~ ~:~:~~ .. . F~~'SYL~`~'~~~i MICHELLE L. SCHOCK, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVAl v. :CIVIL ACTION -LAW CHRISTOPHER W. SCHOCK, N0.2009-8225 CIVIL TERM Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE I . I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by Court and that a copy of the decree will be sent to me immediately after it is with the Prothonotary.. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDA ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HER ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING UNSWORN FALSIFICATION TO AUTHC_'_T_.." DATE: MICHELLE L. SCHOCK, Plaintiff, v. CHRISTOPHER W. SCHOCK, Defendant. IN THE COURT OF COMMON PLEAS a CUMBERLAND COUNTY, PENNSYLVAI CIVIL ACTION -LAW ~ G;;,;; f: . -~ .~ 2009 - 8225 CIVIL TERM ;~ ~ ~' ~i ~~:;. IN DIVORCE w DEFENDANT'S AFFIDAVIT OF CONSENT ~_~ ~ -r~ c° ~ ~;:.~ ,a _ C....3 ~. r~a.? ;~~ 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on or about November 25, 2009. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand tha false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating ~ unsworn falsification to authorities. Date: AUGUST 6, 2012 . SCHOCK Defendant T ./.. C°` °-`-~ r-= ~, ,, ~" ~ ~, .~:i.. s MICHELLE L. SCHOCK, Plaintiff, v. CHRISTOPHER W. SCHOCK, Defendant. IN THE COURT OF COMMON PLEAS O1F CUMBERLAND COUNTY, PENNSYLVAN CIVIL ACTION -LAW a ~.w1 2009 - 8225 CIVIL TERM ~ `~=' ~~ -~;r IN DIVORCE `~~~~~ ~ .~ - WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. -<~'°~ w ,--.~~ _. ~-- .y c-_ ,~.. c.~a :~_:,.. e. f i..7 ;__, 2. I understand that I may lose rights concerning alimony, division of property, fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the C and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand tr false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating unsworn falsification to authorities. Date: AIIGIIST 6, 2012 ~_`~~(-~y CHRIS PHER W. Defendant x: -, ~. ~:~, `~ .~. ==-~; r•: -~•r r.. s MICHELLE L. SCHOCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -LAW NO. 2009-8225 CIVIL TERM CHRISTOPHER W. SCHOCK, IN DIVORCE Defendant J. WESLEY OLER, JR., JUDGE ACCEPTANCE OF SERVICE I, Christopher W. Schock, acknowledge that I received a copy of Plaintiff's Complaint in Divorce in the above captioned action on or about '??5/0 °r X V.J# - /",/ J"k/ py'.-A'?4 /I IF A CHRIS P R W. SCHOCK c -o V rr; r n -? Un :.; MICHELLE L. SCHOCK, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL DIVISION CHRISTOPHER W. SCHOCK, No. 2009-8225 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Tray smit the record, together with the following information, to the court for entry of a &Wjfe decree: rnm 1. Ground for divorce: m Irretrievable breakdown under § (3301(c)) and § (3301(d)(1)) of the Divorce Code. An (Strike out inapplicable section.) Q c 2. Date and manner of service of the complaint: Acceptance of Service by Defendant on 12/5/2009. -: 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce code: by plaintiff 8/10/12 ; by defendant 8/6/12 (b) (1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: N C/) rn -v v rv CD (2) Date of filing and service of the plaintiff's § 3301(d) affidavit upon the respondent opposing party: 4. Related claims pending: None 5. Complete either (a) or (b) (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintiffs Waiver of Notice was filed with the Prothonotary: 8/13/2012 Date defendant's Waiver of Notice was filed with the Prothonotary: 8/13/2012 y for Plaintiff/Defendant c Wit== M C C3 7ri 6F? it' f X`* .r: