HomeMy WebLinkAbout10-1137Edmund J. Berger
Attorney I.D. # 53407
Attorney for Plaintiff
BERGER LAW FIRM, P.C.
2104 Market Street
Camp Hill, PA 17011
Phone: (717) 920-8900
Fax: (717) 920-8901
E-mail: tberger@bergerlawfirm.net
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FEB 1l'ID17
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LENIEL SOTO,
Plaintiff '
V. Docket No. -113I
JESSICA SIERRA,
Defendant
COMPLAINT IN CUSTODY
1. Plaintiff, LENIEL SOTO, currently resides at 4710 Crown Avenue,
Harrisburg, Dauphin County PA 17109.
2. Defendant, JESSICA SIERRA, currently resides at 500 Geneva Drive,
Apartment G2, Mechanicsburg, PA 17055.
3. Plaintiff requests that he be granted legal and physical custody of the
following children:
Name Present Residence Age Date of Birth
Melena L. Soto 500 Geneva Dr., Apt. G2 8 Y2 7-17-01
Mechanicsburg, PA 17055
Melissa M. Soto 500 Geneva Dr., Apt G2 6 Y2 8-18-03
Mechanicsburg, PA 17055
4. Both children were born in wedlock to Plaintiff and Defendant in July 2001
and August 2003 respectively.
5. The relationship of Plaintiff to the children is that of father.
6. The relationship of Defendant to the children is that of mother.
7. Since December, 2006, Plaintiff and Defendant have been divorced.
8. From December, 2006 until the present, no custody order has been in
effect.
9. Since December 2006, the parties have, for the most part, shared custody
of the children.
10. In January 2010, Plaintiff filed for modification of the existing child support
order because of a change in his circumstances, i.e. he was laid off from his
employment and has been unable since then to find other employment.
11. As a result of Plaintiff's decision to seek modification of child support, he
was advised by Defendant Mother that she would not let him see the children.
12. Defendant Mother also advised Plaintiff Father that she might relocate the
children out of state as a result of his filing to modify his support obligation.
2
13. Defendant Mother is clearly attempting to turn the children against Father
as they have told Father that he is a "bad man" and, given their impressionable age, are
clearly responding to Mother's efforts to alienate the children toward their Father.
14. 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.
15. Plaintiff has no information of a custody proceeding concerning the
children pending in a court of this Commonwealth or any other state.
16. 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.
17. The best interest and permanent welfare of the children will be served by
granting the relief requested because Plaintiff is the natural father, has actively
participated in the raising of both children, and will provide a. stable, healthy and loving
environment for the children in which to grow while allowing Mother reasonable access
to the children.
18. 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 respectfully requests this Honorable Court grant primary
physical and legal custody of the children, Melena L. Soto and Melissa M. Soto, to
Plaintiff, evaluate Defendant's home to determine whether the Defendant's home is a
safe environment for the children, provide Defendant Mother with visitation or partial
custody as the Court deems appropriate based on the circumstances, and order such
3
other relief as the Court deems appropriate, including directions to Mother to refrain
from making derogatory comments about Father.
Edmund J. Berger
Attorney I.D. # 53407
Attorney for Plaintiff
BERGER LAW FIRM, P.C.
2104 Market Street
Camp Hill, PA 17011
Phone: (717) 920-8900
Fax: (717) 920-8901
E-mail: tberger@bergerlawfirm.net
February 12, 2010
4
VERIFICATION
I, Leniel Soto, 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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Date
Leniel Soto
5
Edmund J. Berger, Esq. r r ?,,r4y
B
erger Law Firm 2010 F
24 Market Street
Camp Hull, PA 17011 ??
717-920-8900
tberger@bergerlawfirm.netti
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LENIEL SOTO, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PA
V. NO. CV 1 13 7
JESSICA SIERRA,
Defendant CIVIL ACTION - LAW
PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS
TO THE HONORABLE JUDGES OF SAID COURT:
Pursuant to Pa.R.C.P. No. 240, Petitioner hereby submits that he is without
financial resources to pay the costs associated with this proceeding, and therefore
submits that he is entitled to proceed in forma pauperis. In support of this Petition,
attached is Petitioner's Affidavit of Indigency, which is incorporated herein by reference,
detailing Petitioner's overall financial condition at the present time.
WHEREFORE, Petitioner, by and through his counsel, asks leave of court to
proceed in forma pauperis, without the need to pay any costs in connection with the
instant action.
February 12, 2010
Edmund J. Berger, Esk
Pa. I.D. No. 53407
Berger Law Firm, P.C.
2104 Market Street
Camp Hill, PA 17011
Phone: 717-920-8900
Fax: 717-920-8901
E-mail: tberger@bergerlawfirm.net
Edmund J. Berger
Attorney I.D. # 53407
Attorney for Petitioner
BERGER LAW FIRM, P.C.
2104 Market Street
Camp Hill, PA 17011
Phone: (717) 920-8900
Fax: (717) 920-8901
E-mail: tberger@bergerlawfirm.net
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LENIEL SOTO
Plaintiff
V.
JESSICA SIERRA,
Defendant
Docket No.
AFFIDAVIT OF INDIGENCY
1. I am the Plaintiffin the above matter and, because of my financial
condition, I am unable to pay the fees and costs of proceeding.
2. 1 am unable to obtain funds from anyone, including my family and
associates, to pay the costs of litigation.
3. 1 represent that the information below, relating to my ability to pay
the fees and costs, is true and correct:
a. Name: Leniel Soto
Social Security No. 581-75-6469
Address: 4710 Crown Avenue
Harrisburg, PA 17109
b. Employment:
If you are presently employed, state the employer's name and
address: Unemployed
c. Salary or wages per month:
d. Type of work:
e. If you are presently unemployed, state the date of last employment
12/13/2009
1. Salary or wages per month: $18.75/hour
2. Type of work: Technician
3. Other income within the past twelve (12) months: None
4. Business or profession: Dish Network
5. Other self-employment: None
6. Interest: None Dividends None
7. Pension and annuities: None Social Security
Benefits None
8. Support Payments Received None
9. Disability Payments Received None
10. Unemployment compensation and Supplemental
Benefits: $1,029/month
11. Workman's Compensation: None Public
Assistance: None
12.Other(please describe)
None
13. Other contributions to household support
i. Wife's Name: Susan Soto
ii. If wife is employed, state name of employer:
Unemployed
iii. Salary or wages per month: None
iv. Type of work: Not Working
f. Contributions from parents: None
g. Contributions from children: None
h. Other Contributions: None
i Property Owned: See Below
i. Cash:
ii. Checking Account: $826
iii. Savings Account: $100
iv. Certificates of Deposit: None
v. Stocks; bonds: None
vi. Real Estate (including home): None
vii. Motor Vehicle:
a. Make: Honda Odyssey
b. Year: 2004
c. Cost: $13,633
d. Amount Owed: $6,000
viii. Other: None
j. Debts and Obligations:
i. Mortgage: None
ii. Rent: $745.00/month
iii. Loans: None - except car loan above
iv. Other: None
k. Persons dependent upon you for support:
i. Wife's Name: Susan Soto
ii. Names and ages of children: Melena L. Soto - 8
Mellisa M. Soto - 6
Marcus M. Soto - 3
iii. Name and relationship of other persons:
1. Additional Expenses: Regular Bills - Electric -- $125/month;
Water - $100/month; Cable TV - $59.99/month; Phone and Internet -
$59.99/month; Oil and Gas -- $80/month; Groceries -- $300/month
4. 1 understand that I have a continuing obligation to inform the court
of improvement in my financial circumstances, which would permit me to pay
the costs incurred herein.
5. 1 verify that the statements made in this affidavit are true and
correct. I understand that false statements herein are made subject to
penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsifications to
authorities.
6
Date: e: //,/// Cj
Z
Petitioner '
7
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Phonf(:
LENIEL SOTO,
Plaintiff
V.
JESSICA SIERRA,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. CV
CIVIL ACTION - LAW
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow Leniel Soto, Plaintiff to proceed in forma pauperis.
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I, Edmund J. Berger, attorney for the party proceeding in forma pauperis, certify that I
believe the party is unable to pay the costs and that I am providing free legal service to
the party. --? .e1 I--,\
February 17, 2010
Edmund J. Berger, Esq. L?
Pa. I.D. No. 53407
Berger Law Firm, P.C.
2104 Market Street
Camp Hill, PA 17011
Phone: 717-920-8900
Fax: 717-920-8901
E-mail: tberger@bergerlawfirm.net
.y
In the Court of Common Pleas of Cumberland County
Commonwealth of Pennsylvania
Leniel Soto,
Plaintiff _ //,37
: No:
V.
Jessica Sierra
Defendant Civil Action
FEW '9 'U'UC17
-P
ORDER OF COURT
And now, this `?2 3 day of 1 2Q y
upon consideration of the foregoing Petition, the Petitioner is hereby granted
leave to proceed In Forma Pauperis. All court costs assessed by the
Prothonotary or Sheriff of Cumberland County in the above-captioned matter for
filing, copying, certifying, and serving pleadings or for issuing subpoenas are
waived as to the Petitioner. The Petitioner shall inform this Court of any
improvement in his financial circumstances which would permit him to pay the
court costs.
BY THE C URT
i J.
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a4 4'*';r-4
LENIEL SOTO IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
2010-1137 CIVIL ACTION LAW
JESSICA SIERRA
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Wednesday, February 24, 2010 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 Monday, March 22, 2010 at 10:30 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 he 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 Esq.jbi
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
FORTI-I 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
FILED--1:
2010 FED' 26 ?.ti 19: 0 1
tFILCH,-, r.
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Stanley H. Mitchell, Esquire
6oo N. Second Street, Suite 305 L? ( 0 KelIR 15) Ail 10: 5- u
P.O. Box 425
Harrisburg, PA., r7io8
iT
Pa., Atty., I.D. No. 32093
(717) 233-3339
SHMitchell9 comcast.net
Attorney For Plaintiff
LENIEL SOTO, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V
No. 2010 -1137 CIVIL ACTION LAW
JESSICA SIERRA, IN CUSTODY
Defendant
DEFENDANT'S ANSWER AND COUNTERCLAIM
TO COMPLAINT IN CUSTODY
AND NOW, comes Defendant Jessica Sierra, by and through her attorney Stanley H.
Mitchell, Esquire, to answer the Complaint In Custody filed by Plaintiff and to aver a
Counterclaim in response thereto. Defendant avers as follows:
i. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted. By way of further answer, Defendant Sierra has been the primary caretaker for the
minor children since birth. Defendant Sierra has maintained day to day contact with the children
since said time and the children have depended on Defendant for satisfying their basic physical
and psychological needs.
7. Specifically Denied; To the contrary, the parties have been divorced since July 19, 2005.
8. Admitted.
9. Specifically denied; To the contrary, Defendant Sierra has enjoyed primary physical custody of
the minor children since February 7, 2004 when the parties separated.
io. After reasonable investigation, Defendant Sierra is without sufficient knowledge or
information to form a belief as to the truth of the averment.
ii. Specifically Denied; To the contrary, Defendant Sierra has never sought to deny Plaintiff partial
custody with the minor children.
12. Specifically Denied; To the contrary, Defendant has never advised Plaintiff that she "might"
relocate as a result of Plaintiffs alleged filing to modify child support. Defendant Sierra indicated
to Plaintiffs mother that she was considering relocating to Carlisle. By way of further answer,
Carlisle is in the Commonwealth of Pennsylvania and a short distance from Mechanicsburg,
Pennsylvania.
13. Specifically Denied; To the contrary, Defendant has encouraged continuing contact between
Plaintiff and the minor children and does not speak negatively of Plaintiff to the minor children.
Defendant Sierra has not attempted to alienate the minor children from Plaintiff and is unaware
of any statements by the minor children wherein Plaintiff is allegedly called a "bad man".
14. Admitted.
15. Admitted.
16. Admitted.
IT Specifically Denied; To the contrary, the best interests and permanent welfare of the minor
children rests in primary physical custody being placed in the Defendant. Defendant Sierra has
been the primary caretaker of the minor children since February 7, 2004. Defendant Sierra has
been the parent providing for the children's physical, intellectual, emotional, and spiritual well
being. Defendant Sierra - not Plaintiff- has maintained the day to day contact with the children
since February 2004 and it is Defendant Sierra - not Plaintiff - that the minor children have
depended on for satisfying their basic needs. Contrary to the averment of Plaintiff, Plaintiff has
not actively participated in the raising of the minor children. Indeed, Plaintiff has never attended
a parents/teachers meeting or school conference in connection with the minor children.
Defendant Sierra had to literally beg Plaintiff to attend two end of year dance programs for the
minor child Melena. Since the date of separation, February 7, 2004, Plaintiff has not participated
in a single doctor's visit associated with the minor children. Plaintiff has curiously not been
present when the minor children have been ill and as such, has not offered to purchase medicine
for the minor children because he "did not have money or gasoline". Incredibly, Plaintiff does not
call the minor children on their birthdays nor does he assist the minor children with homework.
18. Admitted.
WHEREFORE, Defendant Jessica Sierra respectfully requests that primary physical
custody of the subject minor children be placed with her, subject to partial physical custody rights
to Plaintiff.
COUNTERCLAIM FOR PRIMARY PHYSICAL CUSTODY
19. The averments of paragraphs one through eighteen are incorporated herein by reference as if
set forth in full.
20. The best interests and permanent welfare of the subject minor children are served by placing
primary physical custody of Melena L. Soto, dob 7/17/o1 and Melissa M. Soto, dob 8/18/03, with
Defendant Jessica Sierra.
21. Defendant's home is stable and appropriate for the minor children. The minor children enjoy a
flourishing relationship with their mother, Defendant Sierra. Defendant has been the primary
caretaker for the children since February 7, 2004.
21. Plaintiff, unemployed, has not exhibited the maturity to raise the minor children inasmuch as
Plaintiff has not been an active participant in the physical, emotional, and psychological well
being of the minor children since February 7, 2004.
22. Plaintiff made the minor children sleep on the floor for a substantial period of time while he
slept comfortably in a bed until the minor children complained to Defendant and Defendant
contacted Plaintiff when the parties were separated.
23. Plaintiff permitted his young son to take a bath with the 6 year old minor child Melissa which
was not in the best interests or permanent welfare of the children.
24. The best interests and permanent welfare of the minor children require that primary physical
custody of the children be placed with Defendant Jessica Sierra, subject to partial
physical custody rights of Plaintiff. The parties should share legal custody of
the minor children.
WHEREFORE, Defendant Jessica Sierra respectfully requests that primary physical
custody of the minor children be placed with her, subject to partial physical custody rights in
Plaintiff.
Respectfully submitted,
Stanley H. Mitchell, Esquire
Attorney I.D. No. 32093
P.O. Box 425
Harrisburg, PA., 17108
(717) 233-3339
Date: March 15, 2010
VERIFICATION
I, Jessica Sierra, hereby verify that the statements made in this Answer To Complaint In Custody
And Counterclaim are true and correct to the best of my knowledge, information and belief.
I am aware that false statements herein are made subject to the penalties of 18 PA.C.S. 4904
relating to unsworn falsification to authorities.
Date: March 15, 2010
Jessi a Sierra
CERTIFICATE OF SERVICE
I, Stanley H. Mitchell, Esquire, do hereby certify that I served a true and correct copy of the
foregoing Defendant's Answer and Counterclaim upon the following via U.S. Mail, postage
prepaid, first class, on the 15`h day of March 2010:
EDMUND BERGER, ESQUIRE
2104 Market St.,
Camp Hill, PA 17on
1??
Stanley H. Mitchell, Esquire
6oo N. Second St., Suite 305
P.O. Box 425
Pa., Atty., I.D. No. 32093
(717) 233-3339
SHMitchellg@comcast.net
Attorney For Plaintiff
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff A
Jody S Smith
Chief Deputy 2010 2: 22
Edward L Schorpp
Solicitor OuIV `
Leniel Soto Case Number
vs. 2010-1137
Jessica Sierra
SHERIFF'S RETURN OF SERVICE
03/15/2010 04:24 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on
March 15, 2010 at 1624 hours, she served a true copy of the within Complaint in Custody, Notice and
Order of Court, upon the within named defendant, to wit: Jessica Sierra, by making known unto herself
personally, at 500 Geneva Drive Apt. G2, Mechanicsburg, Cumberland County, Pennsylvania 17055 its
contents and at the same time handing to her personally the said true and correct copy of the same.
1
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AMA DA COBAUGH, DEPUTY U
March 16, 2010
SO ANSWERS,
RONI'TY R ANDERSON, SHERIFF
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2010 ill 22 F111 2. 13
Edmund J. Berger
Attorney I. D. # 53407
Attorney for Plaintiff
BERGER LAW FIRM, P.C.
2104 Market Street
Camp Hill, PA 17011
Phone: (717) 920-8900
Fax: (717) 920-8901
E-mail: tberger@bergerlawfirm.net
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LENIEL SOTO,
Plaintiff
V.
JESSICA SIERRA,
Defendant
Docket No. z; U / 0 - 11'3 7
PLAINTIFF'S ANSWER TO DEFENDANT'S COUNTERCLAIM
FOR PRIMARY PHYSICAL CUSTODY
AND NOW COMES PLAINTIFF and files this Answer to Defendant's
Counterclaim for Primary Physical Custody of the minor children, Melena Soto and
Melissa Soto:
19. This is an incorporation paragraph to which no response is required.
20. It is specifically denied that the best interests and permanent welfare of
the children would be served by them being placed with Mother as primary physical
•
custodian. To the contrary, their best interest and permanent welfare is best served by
placing them with Plaintiff Father as the primary legal custodian.
21. Admitted in Part and Denied in Part. It is admitted that Defendant has
been the primary caretaker for the children since February 7, 2004. It is denied that
Mother's home is stable and appropriate and Plaintiff has asked that a home study be
done of Mother's home. Plaintiff is without information sufficient to forma belief as to
whether the minor children "enjoy a flourishing relationship" with their Mother or the
meaning of such a phrase.
21. (mistakenly numbered as 21 in Defendant's Counterclaim) It is admitted
that Plaintiff is unemployed. It is denied that Plaintiff lacks the maturity to raise the
minor children. It is also denied that Plaintiff has not been an active participant in the
physical, emotional, and psychological well being of the minor children since February
7, 2004. Plaintiff has attempted to maintain such a relationship with the children but has
been kept from seeing the children as frequently as he would like due to the whims and
actions of Mother and also due to difficulty coordinating visits at times that did not
conflict with Father's work schedule. It is noted that Mother would not adhere to an
agreement that had been reached regarding custody and has denied Plaintiff's requests
to see the children on frequent occasions, usually depending on whether she was angry
with Plaintiff or not.
22. Denied. Plaintiff maintains separate beds for the children. On occasion,
Plaintiff has "camped out" with the children by sleeping with them on the floor, but has
never prevented them from sleeping in their beds.
2
.
23. Denied as stated. When Plaintiff's son was an infant, he allowed his infant
son to bathe with Melissa, then 2 years old. Plaintiff believes that there is no harm in
allowing children of such ages to bathe together.
24. It is denied that primary physical custody of the children should be placed
with Mother. Although Mother has had primary physical custody in the past, Mother has
shown a repeated inability to respect Father's custodial rights and interests and has
attempted to turn the children against Father. In this light, Plaintiff should have primary
physical custody and Mother should be permitted visitation or partial physical custody
consistent with the relief requested in Plaintiffs Complaint.
WHEREFORE, Plaintiff respectfully requests this Honorable Court grant primary
physical and legal custody of the children, Melena L. Soto and Melissa M. Soto, to
Plaintiff, evaluate Defendant's home to determine whether the Defendant's home is a
safe environment for the children, provide Defendant Mother with visitation or partial
custody as the Court deems appropriate based on the circumstances, and order such
other relief as the Court deems appropriate, including directions to Mother to refrain
from making derogatory comments about F
March 19, 2010
BERGER LAw FIRM, P.C.
2104 Market Street
Camp Hill, PA 17011
Phone: (717) 920-8900
Fax: (717) 920-8901
E-mail: tberger@bergerlawfirm.net
?MIIIMI I<A V. 6d%illclul
Attorney I.D. # 53407
Attorney for Plaintiff
VERIFICATION
I, Leniel Soto, verify that the statements made in this Answer to
Counterclaim 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.
i e
Date Leniel Soto
4
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LENIEL SOTO,
Plaintiff c7 , ,
v. c
Docket No. 2010-11W o
JESSICA SIERRA, cv
Defendant
?_ _ rv p
01
CERTIFICATE OF SERVICE
I, Edmund J. Berger, hereby certify that a true and correct copy of the foregoing
document, Plaintiff's Answer to Defendant's Counterclaim for Primary Physical
Custody, was served upon the Defendant's counsel by First Class Mail on Friday,
March 19, 2010.
BY FIRST CLASS MAIL
Stanley H. Mitchell, Esq.
122 Locust St.
P.O. Box 425.
Harrisburg, PA 17108
BERGER LAw FIRM, P.C.
2104 Market Street
Camp Hill, PA 17011
Phone: (717) 920-8900
Fax: (717) 920-8901
tberger _bergerlawfirm.net
Edmund J. Berger
Attorney for Plaintiff