HomeMy WebLinkAbout10-0972
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DALE P. FALLON, 4
Plaintiff NO. 2010- q'7a -II' ,IVII.4ER
V. CIVIL ACTION - LAW w j I
C LT cn
JULIE E. FALLON, IN CUSTODY
Defendant SP Qrn
cn 9
CUSTODY COMPLAINT co ?
1. The Plaintiff is Dale P. Fallon, residing at 126 Red haven Road, New Cumberland,
Cumberland County, PA 17070.
2. The Defendant is Julie E. Fallon, residing at 822 Hummel Avenue, Lemoyne, Cumberland
PA 17043.
3. The parties are husband and wife. They were married on 3/31 /1990 and separated
physically in separate houses on June 2007.
4. The parties are the parents of three (3) children, to wit:
NAME PLACE OF RESIDENCE AGE D.O.B.
Kyra M. Fallon 822 Hummel Ave, Lemoyne, PA 19 9/14/1990
Zachery M. Fallon 126 Red Haven Road, New Cumberland, PA 17 7/27/92
Brenna E. Fallon 822 Hummel Ave, Lemoyne, PA 11 6/3/1998111
5. Plaintiff seeks custody of the following child:
NAME PLACE OF RESIDENCE AGE D. 0. B.
Brenna E. Fallon 822 Hummel Ave, Lemoyne, PA 11 6/3/1998
6. The child was not born out of wedlock.
7. The child is presently in the custody of the Defendant, Julie E. Fallon who resides at
822 Hummel Ave, Lemoyne, PA.
*11q.00 PO ATT-1
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8. During the past five years, the child has resided with the following persons and at the
following addresses:
PERSONS ADDRESSES DATES
Julie E. Fallon 822 Hummel Ave Summer 2009 to
Kyra M. Fallon Lemoyne, PA present
Julie E. Fallon 1708 Josiah Chowning Way 11 /2007 to
Krya M. Fallon New Cumberland, PA Summer 2009
Dale P. Fallon 832 Limekiln Road Summer 2003 to
Julie E. Fallon New Cumberland, PA 11 /2007
Kyra M. Fallon
Zachery M. Fallon
9. The mother of the child is Julie E. Fallon currently residing at 822 Hummel Ave.,
Lemoyne, PA.
10. The mother is married to the Plaintiff /Father.
11. The father of the child is Dale P. Fallon currently residing at 126 Red Haven Road, New
Cumberland, PA.
12. The father is married to Defendant /Mother.
13. The relationship of Plaintiff to the child is that of Father.
14. The Plaintiff currently resides with the following persons:
NAMES RELATIONSHIP
Zachery M. Fallon Son
15. The relationship of Defendant to the child is that of mother.
16. The Defendant currently resides with the following persons:
NAMES RELATIONSHIP
Kyra M. Fallon (when not at college) Daughter
Brenna E. Fallon Daughter
- 2 -
17. 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.
18. Plaintiff has no information of a custody proceeding concerning the child pending in a
court of this Commonwealth.
19. Plaintiff does not know of a person not a party to the proceedings who has physical
custody of the child or claims to have custody or visitation rights with respect to the
child.
20. The best interest and permanent welfare of the child will be served by granting the
relief requested because:
A. Father has a close relationship with the child;
B. The child wants to live with father 50% of the time;
C. Father is able to provide for the child's physical, and emotional needs;
D. Father already spends a substantial period of time with 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.
WHEREFORE, Plaintiff requests the Court to grant joint legal and physical custody of
the Child to the parties.
Respectfully submitted,
DI E G. DCLIFF, ESQUIRE
3448 Trindle Road
Camp Hill, PA 17011
Phone: (717) 737-0100
Fax: (717) 975-0697
ID No. 32112
Date: 02 I
- 3 -
VERIFICATION
i verify that the statements made in this Custody 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
Date:_ 2 '2`b
DALE P. FALLON IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
JULIE E. FALLON
DEFENDANT
2010-972 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Friday, February 12, 2010 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, March 18, 2010 at 9:00 AM
_ .. ....... ....._..
for a Pre Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing,
FOR THE COURT,
By: /s/ _ Dawn S. Sunday, E'sq?
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
FORTII 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
,gyp,
2Q10 FEB 1 6 H 12: 39
cuml.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
0
a
DALE P. FALLON C C=
Plaintiff NO. 2010- 0972 CIVIL TE 1,
r,
V. CIVIL ACTION - LAW
9
JULIE E. FALLON IN CUSTODY =
'='
Defendant
C7.. {
ACCEPTANCE OF SERVICE
I, Melissa P. Greevy, Esquire, attorney for the Defendant in the above captioned
action, hereby accept service of the Custody filed in the above captioned matter on
February 5, 2010. 1 certify that I am authorized to accept service on behalf of the
Defendant.
Date:
Melissa P. Greevy
Supreme Court ID No. 77950
301 Market Street
Lemoyne, PA 17043
MAR 2 2 2010 r `
.7
DALE P. FALLON
Plaintiff
vs.
JULIE E. FALLON
Defendant
AND NOW, this
consideration of the attached
1. The parties shall ma
with a professional to be selec
parties in establishing sufficie
parent their Child. The parties
parenting relationship so that t]
well-being. The parties shal
following the custody conciliar
a minimum of four joint couns(
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
n
2010-972 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
-Ti
F}5) J
tl) J
CX) C
_ day of, RsC GN , 2010, upon
Conciliation Report, it is ordered and directed as follows:
arrangements to engage in a course of therapeutic family counseling
1 by agreement. The purpose of the counseling shall be to assist the
communication and cooperation to enable them to effectively co-
;knowledge that they are committed to addressing the conflict in their
y can make the changes necessary to promote their Child's emotional
select the counselor and contact the counselor's office promptly
n conference to schedule the initial sessions. The parties shall attend
sessions.
2. The parties shall ake arrangements for Brenna to participate in counseling with a
professional to be selected by greement between the parties. The purpose of the counseling shall be
to assess the Child's emotional and adjustment needs with respect to the family situation and provide
guidance to the parents, as app opriate, to assist their efforts in meeting those needs. The parties shall
schedule the Child's counselin sessions to begin during the last two weeks of May.
3. The Father, Dale P. allon, and the Mother, Julie E. Fallon, shall have shared legal custody
of Brenna Fallon, born June 3, 998. Major decisions concerning the Child including, but not
necessarily limited to, her healt , welfare, education, religious training and upbringing shall be made
jointly by the parties after disc ssion and consultation with a view toward obtaining and following a
harmonious policy in the Child s best interest. Neither party shall impair the other party's rights to
shared legal custody of the Chi d. Neither party shall attempt to alienate the affections of the Child
from the other party. Each p shall notify the other of any activity or circumstance concerning the
Child that could reasonably be xpected to be of concern to the other. Day to day decisions shall be
the responsibility of the parent en having physical custody. With regard to any emergency decisions
which must be made, the paren having physical custody of the Child at the time of the emergency
shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall
inform the other of the emerge cy and consult with him or her as soon as possible. In accordance with
23 Pa.C.S.A. §5309, each part shall be entitled to complete and full information from any doctor,
dentist, teacher, professional o authority and to have copies of any reports or information given to
either party as a parent as auth rized by statute.
4. Pending the follow- p conciliation conference and further agreement of the parties or Order
of the Court, the Mother shall have primary physical custody of the Child and the Father shall have
partial physical custody for the remainder of the 2009-2010 school year on alternating weekends from
Friday after school through S day at 9:00 p.m. and during the interim Tuesdays from after school
until 9:00 p.m.
5. Pending the concilia ion conference scheduled in this Order, during the summer school
break, the Father shall have cu tody of the Child from June 11 through June 18 and from June 25
through July 2 as vacation custody and the Mother shall have custody of the Child at all times not
otherwise specified for the Father.
6. Pending the follow- p custody conciliation conference, in 2010, the Father shall have
custody of the Child for Easter and the Mother shall have custody for July Fourth. The parties shall
establish custodial arrangemen s for the Memorial Day holiday through the therapeutic family
counseling.
7. The parties and counsel shall attend a follow-up custody conciliation conference in the
office of the conciliator, Dawn S. Sunday, on Wednesday, June 30, 2010 at 9:00 a.m. for the purpose
of reviewing the custodial arrangements following the co-parenting counseling and the counseling for
the Child.
8. Unless otherwise ag eed between the parties the Father shall provide all transportation for
exchanges of custody.
9. Neither party shall d or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natural development of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with thi provision.
10. This Order is
conference. The parties may
mutual consent, the terms of
cc: " D' e G. Radcliff Es q
Melissa P. Greevy, Esc
L piles ,
3?a 3 f ?a
pursuant to an agreement of the parties at a custody conciliation
lify the provisions of this Order by mutual consent. In the absence of
Order shall control.
- Counsel for Father
- Counsel for Mother
'RV TNR CM TI? T
DALE P. FALLON IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 2010-972 CIVIL ACTION LAW
JULIE E. FALLON
Defendant IN CUSTODY
IN ACCORDCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the tuidersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Brenna Fallon Jude 3, 1998 Mother
2. A custody concilia ion conference was held on March 17, 2010, with the following
individuals in attendance: the Father, Dale P. Fallon, with his counsel, Diane G. Radcliff, Esquire, and
the Mother, Julie E. Fallon, with her counsel, Melissa P. Greevy, Esquire.
3. The parties agreed tol entry of an Order in the form as attached.
Date
(at ? ? , ? "//,
Dawn S. Sunday, Esquire
Custody Conciliator
DALE P. FALCON IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 2010-972 CIVIL ACTION LAW
^' ~
JULIE E. FALCON ~ ~ ' ~=''
Defendant IN CUSTODY ~'
_ c~ ~
b
'.~
ORDER OF COURT =_ '~'
.. ..
AND NOW, this ~V day of ~ w ~' 2010, upon
consideration of the attached Custody Conciliation Report, itis ordered and directed as follows:
1. The prior Order of this Court dated March 23, 2010 is vacated and replaced with this Order.
2. The Father, Dale P. Fallon, and the Mother, Julie E. Fallon, shall have shared legal custody
of Brenna Fallon, born June 3, 1998. Major decisions concerning the Child including, but not
necessarily limited to, her health, welfare, education, religious training and upbringing shall be made
jointly by the parties after discussion and consultation with a view toward obtaining and following a
harmonious policy in the Child's best interest. Neither party shall impair the other party's rights to
shared legal custody of the Child. Neither party shall attempt to alienate the affections of the Child
from the other party. Each party shall notify the other of any activity or circumstance concerning the
Child that could reasonably be expected to be of concern to the other. Day to day decisions shall be
the responsibility of the parent then having physical custody. With regard to any emergency decisions
which must be made, the parent having physical custody of the Child at the time of the emergency
shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall
inform the other of the emergency and consult with him or her as soon as possible. In accordance with
23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor,
dentist, teacher, professional or authority and to have copies of any reports or information given to
either party as a parent as authorized by statute.
3. The parties shall have physical custody of the Child in accordance with the following
schedule:
A. From the date of the custody conciliation conference through August 24, 2010 the
parties shall continue to follow the custody schedule set forth in the March 23, 2010 Order.
B. Beginning on August 24, 2010, the Father shall have primary physical custody of
the Child and the Mother shall have partial custody every weekend from Friday through Sunday and at
additional times as arranged by agreement until the Mother relocates to Seattle, Washington.
C. After the Mother moves to Seattle, Washington, the Father shall have primary
physical custody of the Child and the Mother shall have partial custody for up to eight weeks during
the summer school breaks, with the specific dates to be arranged by agreement between the parties
based upon the Child's activity schedule. The Child shall be returned to the Father's custody at least
one week before school starts each summer. In addition, the parties shall make arrangements for
substantial custodial time for the Mother over Thanksgiving, Christmas and Easter by agreement to
maintain flexibility.
4. The parties shall make arrangements by agreement for payment of the Child's airfare for
exchanges of custody taking into consideration both parties' financial circumstances.
5. The Child shall be enrolled in the Crossroads Middle School in the West Shore School
District for the 2010-2011 school year and shall continue to attend the West Shore School District
thereafter unless otherwise agreed between the parties or ordered by the Court.
6. Neither party shall do or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natural development of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
7. 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.
cc:
/ Diane G. Radcliff, Esquire -Counsel for
/ Melissa P. Greevy, Esquire -Counsel for Mother
Copr~s r~%lu~ ~~/o~/a
RV TNF. C ni iRT_
DALE P. FALCON IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs.
JULIE E. FALCON
Defendant
2010-972 CIVIL ACTION LAW
IN CUSTODY
Prior Judge: Kevin A. Hess
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 DATE OF BIRTH CURRENTLY IN CUSTODY OF
Brenna Fallon June 3, 1998 Mother
2. A custody conciliation conference was held on July 22, 2010, with the following individuals
in attendance: the Father, Dale P. Fallon, with his counsel, Diane G. Radcliff, Esquire, and the
Mother, Julie E. Fallon, with her counsel, Melissa P. Greevy, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
02 ~~26 L~
Date Dawn S. Sunday, Esquire
Custody Conciliator
1'N THE COURT OF CONIMMOfI~ PLEAS
CUMBERLAND COUNTY, FENNSYLVAN
CI'TIMORTGAGE,13`TC. S~B/M TO ABN AMRO Court of Common pleas
°" lvi'GR'I"GAGL GROUP, ING
pl~~ Civil Division
.
v.
EHD1 T. ATAR
1ODI L. ATAR
Defendants
CUMBERLAND County
No. CTVL-lfl-1132
. ORDER
AND NOW, this~day of. r~J~ 2010 the Prothonotary is ORDERED to
amend the in rem judgment and the Sheriff is ORDERED to amend the writ nunc.pro tune in this..
case as follows:
Principal. Balance
Interest Through September 8 2011
Per Diem $37.83
Late Charges
Legal fees
Cost of Snit and Title
Sheriffs Sale Costs
property Inspections/ Property Preservation
Appxaisal/Brokers Price Opinion.
Mortgage Insurance Premium 1
Private Mortgage. Insurance
Non Suil'icent Funds Charge
SuspenseJMisc. Crecli`ts
Escrow Deficit
$235,015.31
$32,481.59
$0.00
$1,32.00
$920.00
$0.00
$2,614.p0
:$0.00
$2,75fl.66
$0`.00
($0.00)
$7,564.61
TOTt~.I. $2$2,671.17
Pius interest frt>m September 8, 2010 through`the date of sale at six percerYt per annum.
Note: 'The above figure is nat a payoff 9uolke, Sheriffs commission is nc~t included in the abt~ve
figure..
BY " E COURT
7.
U• V~~ S/' ~ U~.S~ittJR~ ~~~
~A~oi~S~~ nut .`~Cd ~/i~/iD
~~
229613
Johnson, Duffle, Stewart & Weidner
By: Melissa Peel Greevy
I.D. No. 77950
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
DALE P. FALLON,
Plaintiff
V.
JULIE E. FALLON,
Defendant
• 4 ? ih
?'bt3 k1t? ti# 4 ! ?
Attorneys for Defendant
IN THE COURT OF COMMON PLEAS OF THE
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2010-972
CIVIL ACTION - LAW
IN CUSTODY
UNCONTESTED PETITION FOR LEAVE TO WITHDRAW APPEARANCE
AND NOW, comes the law firm of Johnson Duffle Stewart & Weidner and respectfully represents as
follows:
Your petitioner currently represents the Defendant, Julie Fallon, in the within action.
2. Certain circumstances have arisen between Defendant and your petitioner which make
termination of the relationship mutually beneficial.
3. Despite numerous attempts, Defendant has not recently responded to phone calls, letters, or
e-mail communications from the undersigned's office.
4. Petitioner has had no contact with Defendant since the Custody Conciliation Conference on
July 22, 2010.
5. In correspondence dated June 15, 2010 Petitioner informed Defendant that her inability to
communicate with Defendant severely impairs the undersigned's ability to represent her and may cause the
undersigned to need to file a request for Leave to Withdraw Appearance as her attorney.
6. Defendant failed to respond to letters dated August 23, 2010 and September 3, 2010.
7. In correspondence dated September 3, 2010, the undersigned informed the Defendant that
she could not continue representation under circumstances where she fails to respond to correspondence in
a reasonable time frame.
8. Your Petitioner has provided Defendant with a copy of this Petition via U. S. Mail to her last
known home address on September 16, 2010.
9. Defendant has failed to respond to Petitioner's correspondence dated September 16, 2010.
10. Petitioner visited Defendant's home on September 16, 2010 and observed that the home
appeared to be vacant.
11. Defendant has failed to provide Petitioner with a new address, as required by the terms of her
representation agreement.
12. This lack of communication makes it impossible to continue an attorney/client relationship.
13. There are no hearings scheduled in this matter scheduled before this Court as the parties
reached an agreement at the Custody Conciliation Conference.
14. The Custody Order in this matter was signed by the Honorable Kevin A. Hess, P.J.
15. In the absence of any pending hearing, Defendant has sufficient opportunity to obtain new
counsel, should she so desire.
16. The undersigned has contacted Plaintiff's counsel and has received her concurrence with this
Petition.
WHEREFORE, it is respectfully requested that this Honorable court grant Petitioner's Request for
Leave to Withdraw.
JOHNSO, FIE, STEWART & WEIDNER
Melissa Peel Greevy
CERTIFICATE OF SERVICE
AND NOW, this 1 day of , 2010, the undersigned does hereby
certify that she did this date serve a copy via of the foregoing Uncontested Petition for Leave to
Withdraw on the Defendant and upon the other counsel of record and Defendant by causing same
to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania,
addressed as follows:
Julie Fallon
822 Hummel Avenue
Lemoyne, Pennsylvania 17043
Diane G. Radcliff, Esquire
3448 Trindle Road
Camp Hill, Pennsylvania 17011
JOHNSO UFFIE, STEWART & WEIDNER
Melissa Peel Greevy
:414340
i
a
4
Johnson, Duffle, Stewart & Weidner
By: Melissa Peel Greevy
I.D. No. 77950
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
FILED-OFFICE
OF THE PROTHONOTARY"
2010 NOV 19 AM 11: 00
CUMBERLAND COUNTY
PENNSYLVANIA
NOV 172010
Attorneys for Defendant
DALE P. FALLON,
V.
JULIE E. FALLON,
Plaintiff
Defendant
ORDER OF COURT
IN CUSTODY
AND NOW, this -"I day of Nw e,, - , 2010 upon review of the Uncontested
Petition for Leave to Withdraw filed by Defendant's counsel, the Uncontested Petition for Leave to Withdraw
is GRANTED.
,
n A. Hess, P.J.
Dist: ,Mahssa P. Greevy, Esquire, P. O. Box 109 Lemoyne, PA 17043
ne G. Radcliff, Esquire 3448 Trindle Road, Camp Hill, PA 17011
///Julrle Fallon 822 Hummel Avenue, Lemoyne, PA 17043
l
i £s r>n? 6L
e< tQ?lo
IN THE COURT OF COMMON PLEAS OF THE
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2010-972
CIVIL ACTION - LAW
II a: fMi?l_r^,td0 CGLINT
SYI_ 4?1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DALE P. FALLON
JULIE E. FALLON
Plaintiff NO. 2010- 0972 CIVIL TERM
V. CIVIL ACTION - LAW
Defendant
IN CUSTODY
Motion to Withdraw as Legal Counsel for Defendant
Submitted by: Diane G. Radcliff, Esquire
PREVIOUSLY ASSIGNED JUDGE
Kevin A. Hess
APPEARANCE FOR PLAINTIFF:
Diane G. Radcliff, Esquire
3448 Trindle Road,
Camp Hill, PA 17011
Phone: 717-737-0100
Facsimile: 717-975-0697
Email: dianeradcliffa-comcast.net
APPEARANCE FOR DEFENDANT:
Julie E. Fallon
Pro Se
(Address Unknown)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DALE P. FALLON
Plaintiff
NO. 2010- 0972 CIVIL TERM
JULIE E. FALLON
v.
Defendant
CIVIL ACTION - LAW
IN CUSTODY
MOTION TO WITHDRAW AS LEGAL COUNSEL
Diane G. Radcliff, Esquire, attorney for the Plaintiff, Dale P. Fallon, hereby requests this
Honorable Court to issue an Order granting her leave to withdraw as legal counsel for the
Plaintiff, Dale P. Fallon. Plaintiff, Dale P. Fallon consents to this request as evidenced
by his consent attached hereto and made a part hereof.
Dated: b t Z Respectfully submitted,
Q? L
RADCL ESQUIRE
e Court ID #32112
3448 Trindle Road
Camp Hill, PA 17011
Telephone: (717) 737-0100
Attorney for Plaintiff
Page -1-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DALE P. FALLON
JULIE E. FALLON
Plaintiff NO. 2010- 0972 CIVIL TERM
V. CIVIL ACTION - LAW
Defendant
IN CUSTODY
PLAINTIFF'S CONSENT TO WITHDRAW OF APPEARANCE OF LEGAL COUNSEL
I, Dale P. Fallon, Plaintiff, hereby consent to the request of Diane G. Radcliff, Esquire to
withdraw her appearance as legal counsel for the Plaintiff, Dale F. Fallon, and consent
tc the entry of any order providing for the following:
"Diane G. Radcliff, Esquire is hereby granted leave to withdraw her
appearance as legal counsel for the Plaintiff, Dale I. Fallon, in the above
captioned case."
Dated: , -12,
?-(at a r
3. y d
CUMBERLAND COUNTY
RENtisYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DALE P. FALLON :
Plaintiff NO. 2010- 0972 CIVIL TERM
V. CIVIL ACTION - LAW
i
JULIE E. FALLON IN CUSTODY
Defendant
ORDER
AND NOW, this 21` day of twAA , 2012, upon consideration of the within
Motion, IT IS HEREBY ORDERED that Diane G. Radcliff, Esquire is hereby granted
leave to withdraw her appearance as legal counsel for the Plaintiff, Dale P. Fallon.
Distribution to:
?Attorney for Plaintiff: Diane G. Radcliff, Esquire, 3448 Trindle Road, Camp Hill, PA 17011
?Plaintiff: Dale P. Fallon, 126 Red Haven Road, New Cumberland, PA 17070
60p.es h .? ed s?a l?/ a
BY THE COURT
• ? '-_ to ? iC ?
Zu 12 JUN 20 AM 0. ? U
' ??-', EI'tL A t 0 C o ?','I
PENN 113YLVA,illA
Diane G. Radcliff, Esquire
Supreme Court ID Number 32112
3348 Trindle Road, Camp Hill, PA 17011
Telephone: 717-737-0100 • Fax: 717-975-0697 • Email: dianeradcliff@comcast.net
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DALE P. FALLON
Plaintiff NO. 2010- 0972 CIVIL TERM
V. CIVIL ACTION - LAW
JULIE E. FALLON IN CUSTODY
Defendant
PRAECIPE TO WITHDRAW APPEARANCE
To the Prothonotary of the said Court:
Pursuant to the attached Order of Court dated May 21, 2012, please withdraw the
appearance of Diane G. Radcliff, Esquire, as Attorney for Plaintiff, Dale P. Fallon.
Dated: June 20, 2012 -----.Respectfully s
DI CLIFF, ESQUIRE
S m rt ID #32112
3448 Trindle Road, Camp Hill, PA 17011
Telephone: (717) 737-0100
= L ED-OFFK'?-
fir? H0N0 ,- + .
MAY 21 PM 12: 02
(CUMBERLAND COIJNT (
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DALE P. FALLON
Plaintiff NO. 2010- 0972 CIVIL TERM
V. CIVIL ACTION - LAW
JULIE E. FALLON IN CUSTODY
Defendant
ORDER
AND NOW, this day of , 2012, upon consideration of the within
Motion, IT IS HEREBY ORDERED that Diane G. Radcliff, Esquire is hereby granted
leave to withdraw her appearance as legal counsel for the Plaintiff, Dale P. Fallon.
BY THE COURT
KEVIN A. HESS, P.J.
Distribution to:
Attorney for Plaintiff. Diane G. Radcliff, Esquire, 3448 Trindle Road, Camp Hill, PA 17011
Plaintiff: Dale P. Fallon, 126 Red Haven Road, New Cumberland, PA 17070
TRUE COPY FROM RECORD
In Tes*nony whereof, I here unto-set my hand
and the seal of said Court at Carlisle, Pa.
This 2 1 day of . -, 20 / a
??Prothonotary
CERTIFICATE OF SERVICE
I, Diane G. Radcliff, Esquire, hereby certify that on June 21, 2012 1 am serving a copy of
the foregoing pleading as follows:
Service by First Class Mail, Postage Prepaid and Addressed as Follows:
Dale P. Fallon,
126 Red Haven Road
New Cumberland, PA 17070
(Plaintiff)
Dated: June 20. 2012
DCLIFF, ESQUIRE
S eme urt ID #32112
3448 Trindle Road
Camp Hill, PA 17011
Phone: (717) 737-0100