Loading...
HomeMy WebLinkAbout10-36071+1? OF THE FP^ i C-? OTARY 2010 ,"U4 -2 AM 10: 3 1 Lindsay Gingrich Maclay, Esquire Supreme Court # 87954 :. DALEYZUCKER MEILTON PEtZ,1SYLVX4A MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 lmaclaX(aa)dzmmglaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTINE E. POTTEIGER, Plaintiff ROGER K. POTTEIGER, Defendant No. 10 - Z (p©-4 0,-t v t l erm CIVIL ACTION - LAW (In 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 action within twenty (20) days after this Complaint and Notice are served, be entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Petition or for any other claim or relief requested by the Petitioner. You may lose money or property or other rights important to you. 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 4I'7q.00 PD ?'?'? ?# q5a3 '14 a9ga NOTICIA Le han demando a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archiver en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas u puede entrar una orden contra usted sin previo aviso o notificacion y por cualguir queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiendades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SOFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONAL O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGAUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 DALEY ZUCKER WILTON MINER & GINGRICH, LLC By: AttLn yGi i h M clay, Esq i e ey I.D. No. 87954 1029 Scenery Drive Harrisburg, Pennsylvania 17109 (717) 657-4795 Attorneys for Plaintiff Lindsay Gingrich Maclay, Esquire Supreme Court # 87954 DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 lmaclaya.dzmmglaw com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTINE E. POTTEIGER, : Plaintiff No. CIVIL ACTION - LAW ROGER K. POTTEIGER, : Defendant (In Custody) COMPLAINT FOR CUSTODY AND NOW, this day of 2010, comes Plaintiff, Kristine E. Potteiger, by and through her attorneys, Daley Zucker Meilton Miner & Gingrich, LLC, and files the following Complaint for Custody, and in support thereof avers as follows: 1. Plaintiff, Kristine E. Potteiger, is an adult individual who currently resides at 669 Lindsey Road, Carlisle, Cumberland County, Pennsylvania (hereinafter referred to as "Mother"). 2. Defendant, Roger K. Potteiger, is an adult individual who also currently resides at 669 Lindsey Road, Carlisle, Cumberland County, Pennsylvania (hereinafter referred to as "Father"). 3. It is anticipated that a physical separation is imminent, once Plaintiff files her Complaint in Divorce and this Complaint in Custody and Defendant is served with same. 4. Plaintiff has two (2) different places that she can move with the child, if necessary, at a moment's notice. 5. Plaintiff, Kristine E. Potteiger, is the natural mother of two (2) children, namely, Jessica Potteiger, whose date of birth is June 28, 1991 and who is, therefore, emancipated and no longer subject of this Custody Action; and Levi Potteiger, whose date of birth is June 16, 1999, who is still a minor and subject of this Custody action. 6. Defendant, Roger K. Potteiger, is the natural father of the children. 7. Both children were born to the parties in wedlock. 8. Mother's and Father's current addresses are above. As the parties have not physically separated, there is no formal physical custody arrangement; however, Mother has been the primary caregiver of the children since birth, due to Father's long work hours as an over-the-road truck driver. 9. The relationship of Plaintiff to the children is that of natural mother. 10. The relationship of Defendant to the children is that of natural father. 11. Mother has no information of any other custody proceeding concerning the children pending in any court of this Commonwealth. 12. Mother does not know of a person, not a party to this proceeding, who has physical custody of the subject child or claims to have physical custody or visitation rights with respect to the subject child. 11. The best interest and permanent welfare of the subject child will be served by granting the relief requested because: a. Plaintiff is the natural mother of the subject child; b. Plaintiff has a warm and loving relationship with the subject child, which has helped foster his development and growth. C. Plaintiff has in the past, and will continue to provide a stable, loving home environment for the subject child. d. Plaintiff has in the past and will continue to promote the relationship between the subject child and Defendant. e. Plaintiff has the ability and the schedule to allow her to care for the subject's child's daily needs. 12. Each parent whose parental rights to the subject child have not been terminated and the person(s) who has physical custody of the subject child has been named as a party to this action. There are no other persons who are known to have or claim to have a right to custody or visitation of the subject child. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order granting the parties shared legal custody and granting Plaintiff primary physical custody of the subject child, with periods of partial custody to Defendant. Respectfully submitted, DALEYZUCKER MEILTON MINER & GINGRIC , LLC Date: *IU-111 13y: n say Gi c Mac ay, Esqu ttomey I. 7954 1029 Scenery Drive Harrisburg, Pennsylvania 17109 Attorneys for Plaintiff VERIFICATION I, Kristine E. Potteiger, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. 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. Dated: p??/? Lindsay Gingrich Maclay, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 Imaclay~a,dzmmglaw.com ~< 2010 Jilin 29 ~~`- 8~ t 8 ..~, ~~^~~r~~~~ ~~~~~,~~~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTINE E. POTTEIGER, Plaintiff No. 2010-3607 v. CIVIL ACTION -LAW ROGER K. POTTEIGER, Defendant (In Custody) AFFIDAVIT OF SERVICE I, Lindsay Gingrich Maclay, Esquire, being duly sworn according to law, deposes and says that I am an attorney at law duly authorized to practice in the Commonwealth of Pennsylvania, and that on the 8th day of June, 2010, I did serve upon Roger K. Potteiger, Defendant in the foregoing case, a true and correct certified copy of the June 2, 2010 Custody Complaint and the by sending a copy of same to Roger K. Potteiger via certified mail, restricted delivery, return receipt requested to 669 Lindsey Road, Carlisle, Pennsylvania, 17013. A copy of the Return Receipt is attached hereto as Exhibit "A". The original Return Receipt is filed under the Divorce Docket. Sworn to and subscribed before me this ~ of ~~(n 20 l o B y y ;~~ ' c WI~A~fONWEAL'IH OF PENNSYI,v NOTARIAL SEAL Gloria M Rine, Notary Pub)jc .,. Lower Paxton Towoslup, Dauphin commission expires NovembEr 13,- DALEY ZUCKER MEILTON MINER & GINGRIC]-I, LLC /Li~hc~say Gin~idh M~~lay, Esquire ttorney I. o. 87954 1029 Scenery Drive Harrisburg, PA 17109 (717) 65?-4795 Exhibit "A" U.S. Postal Service, GERTIFIEI~ MAIL REGEiP r (Domesfic Mail Only; No Insurance Coverage Provided) r7 ~' r1^1 Postepe C~ CertBfed Fee O Re1um Receipt Fee (Endorsement Required) Q' ~ pu (EndorsemeM b rU O M1 ^ Complete Items 1, 2, end 3. Also complete Item 41f Restricted Delivery is desired. ^ Print your name and address on the reveres so that we can return the card to you. ^ Attach this card to the back of me mailpkrce, ', or on the front if space permits. 1. Article Addressed to: MY. ~a cr ~,. Po~1-ci e~ 9 g U~~q u n~ls~y ~~ ~Q,~liS1~l ~X~ 1~~3 A Sign r X ~ ~i O Addressee s• (Pri ) c. bane of Delivery G (o`~~Cn D. b address dRYererrt from Rem 1 T ~ Yes M YES, enter delivery address t~elow: ^ No 3. Service Type ~Certllled Mall ^ Express Mall O Registered ^ ReQum Receipt for Merchandise O Ir~red MaG ^ C.O.D. 4. Restricted Delhrery? (DrtYa Feel Yes 2. ArtfdeNumber 7I7fl4 289Q ^QQ1 39ZQ 5311;: (llanslbrfiom service ~berJ PS Form 3811, Fetxuary 2004 Domest~ Return Receipt ioZ.l„Fryw ; Lindsay Gingrich Maciay, Esquire bALBY ZtlCxriR MEIL'rON MINER 8f CIINC}RiCH, LLC 1029 Scenery Drive Harrisiwrg, PA 17109 (717j 6571795 lmaclay~dzmmgla~v.ccxn HMI ~} '`_ r , i r~ _ L L I J 3' ~.! i. ~ :' E~ t i ...~ ' ~' /~U(r ~' I~n1 /0~5'/ v _ E r' ``~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, FENNSYLVANIA KRIS7fINE E. POTTEIGER, Plaintiff No. 2010-3607 ~~ CIVIL ACTION - LAW ROGER K. POTTEIGER, . Defendant (In Custody} STIPULATION .AND AGREEMENT FOR CUSTODY THIS AGREEMENT is made this day of .2010, BY and BETWEEN Kristine E. Potteiger, of 669 Lindsey Road, Carlisle, Cumberland County, Pennsylvania (hereinafter referred to as "Mather"} A N D Roger K. Potteiger, also currently of 669 Lindsey Road, Carlisle, Cumberland County, Pennsylvairia {hcreiuafter referral to as "Father"). RE R.1: The parties hereto were husband and wife joined in marriage on January 4,1986 in Carlisle, Cumberland County, Pennsylvania; and R.2: Mother filed for Bivorce on June 2, 2014; and R.3: The parties hereto are the natural parents of two (2} children, Jessica E. Potteiger, whose date of birth is June 28, 1991 (now emancipated); and Levi J. Potteiger, whose date of birth is June 16,1999 {the subject child of this Stipulation and Order); and R.4: The parties separated on June 2, 2010; however, due to economic circumstances, the parties plan to continue to reside together for a period of time; and R.S: The parties have reached an agreement and wish to memorialize their parenting plan to be effective once their physical separation takes place; and R.6: A Custody Conciliation Conference is scheduled for September 9, 2010 at 9:30 a.m. before Hubert X. Gilroy, Esquire; and R.7: The parties have negotiated, with the assistance of counsel, an agreement with regard to a parenting plan far the child; and R.8: Upon execution of this Stipulation, the parties desire that this Stipulation and Agreement be adopted as an Order of Court. NOW THEREFORE, wi#h the aforegoing recitals being hereinafter incorporated by reference and deemed an essential part hereof and in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration, receipt of which is hereby acknowledged, and the parties, intending to be legally bound, hereby agree as follows: 1) The parties shall have joint legal eastody of their minor child, Levi J. Potteiger. Joint legal custody means the right of both parents to control and to share in making decisions of importance in the life of their child, including educational, medical, and religious decisions. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being, including, but not limited to, all decisions regarding their health, education and religion. The custodial parent shall inform the non-custodial parent immediately of all medical and dental appointments and problems pertaining to the child. If the child is sick and is unable to attend school or extracurricular activities the custodial parent will notify the non-custodial parent as soon as practicably possible. Each parent shall provide names, addresses, and telephone numbers for all of the child's medical, dental and other healthcare providers, school contact information as well as the school's website and any website's relating to the child's activities. In the event that either parent cannot obtain information or schedules directly, the other parent shall provide the documentation upon r~uest. The custodial parent shall notify the other parent of any medical, dental, optical, counseling and other appointrr;ents of the child with health care providers, sufficiently in advance thereof so that the other party can attend, if he or she so chooses. Pursuant to the terms of Pa.C.S. §5309, each parent shall be entitled to equal access to all records and i~ormation pertaining to the child, including, but not limited to, the child's school, medical, dental, religious and other important records, the residence address of the child and the other parent. As soon as practical after the receipt by a ~ party, copies of the child's school schedule, special events notifications, report cards, and similar items shall be provided to the other party. To the extent one (1) parent has possession of any such records or information, that parent shall be required to share same, or copies thereof, with the other parent within such reasonable time as to make the records or information of reasonable use to the other parent. The custodial parent shall provide copies of the child's report cards and other reasonable papers affeetiug the child's education, medical condition or welfare. 1~Iotwithstanding that bath parents shall share Legal custody, non-major decisions involving the child's day-to-day living shall be made by the parent then having custody, consistent with the other provisions of this Stipulation and Order. 2) Physical custody of the child, as that term is defined in the Custody Act, shall be primarily with Mother, subject to Father's periods of partial custody as the parties may agree. 3) Transportation for custody purposes shall be divided by the parties as equally as possible. Unless otherwise agreed, the parent receiving custody shah transport the child from the home of the other parent. 4} The parties shall share custody of the child during the holidays as they mutually agree. 5} Each patty shall be entitled to take vacatfon with the child after giving the other party advance notice of their intent and the dates of the vacation. 6) The parties shall provide each other with a written schedule or website address to ascertain a schedule for the child's school, sporting, and extxaeurricular activities. Both patties shall agree to hour and participate in the activities in which the child wishes to engage. During the tunes that each parent has custody of the child, each parent will make certain that the child attend any previously-scheduled extracurricular activities. The parties are directed to be supportive of the child's activities and will transport the child to and from such activities and the preparations and practice for the activities that are scheduled, in such time so that the child is able to participate in thane events. r In the event that the custodial parent is unable to deliver either child to an agreed upon activity, the non-custodial parent shall be permitted to transport the child to the agreed upon activity. The custodial parent shall make certain that the child is transported to appropriate custody exchange location in a time su~cierrt to enable the child to timely attend the activity. 7) The custodial parent shall ensure that the children complete any and all school assignments ar projects during their period of custody. 8) in the event that either child is unable to attend school due to illness, it is the respansibiiity of the parent then having custody to arrange alternate care for that day and to notify the non-custodial parent of the child's illness. 4) In the event that either party is planning to take either child away from home for an overnight trip, they shall provide the nan-custodial parent with reasonable notice and contact information where the child will be staying. 1Q) Each party shall confer with the other on ail matters of importance relating to the child's health, maintenance, and education with a view towards obtaining and following a harmonious policy in the child's education and social adjustments. Each party agrees to keep the other informed of his or her residence and telephone number to facilitate communication concerning the welfare of the child and the custody situation. Each party shall supply the name, address and phone numbers of any persons in whose care the child will be in for a period in excess of seven#y-two (72) hours, and for each person ar entity which may provide daycare for the child, excluding current daycare providers, relatives, or public school institutions. 11) Emergency decisions regarding the child shall be made by the parent then having custody. However, in the event of any emergency or serious ilhzess of the child at any time, any party then having custody of the child shall immediately connmunicate with the other party by telephone or any other means practical, informing the other party of the nature of the illness or emergency, so the other parent can become involved in the decision:-making process as soon as practical. The term "serious illness" as used herein shall mean any disability which confines either child to bed for a period in excess of seventy-two {72} hours and which places either child under the direction of a licensed physician. 12) The weI[are and convenience of the child shall be the prime consideration. of the parties in any application of the provisions of this Stipulation and Agreement. Both parents are directed to listen carefully and consider the wishes of the child in addressing the cue#odial schedule, any changes to the schedule, and any other parenting issues. 13) Any madit~CCations of this Stipulation and Agreement need to be in writing, and agreed to by both parties. Minor, short team changes can be made orally, if agreed upon by both parties. In the event that either party is not in agreement with a proposed change, this Stipulation, Agreement, and Order will control the custodial arrangement until such time as the parties are able to agree. 14} This Stipulation, Agreement and/or Order Supersedes all previous custody Agreements and/or Otders. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals to this Agreement the day and year first above written. WITNESS: Michael A. Scherer, uire Atrorrrey for llefendant Roger Potteiger, fendant AUG ~ 12010 KRISTINE E. POTTEIGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CNIL ACTION -LAW RQGER K. POTTEIGER, NO. 2010-3607 Defendant IN CUSTODY ORDER AND NOW, this l D day of August, 2010, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. ~~ Hubert X. Custody C ~ Esquire -~- ~ - - , ~, -e ~= ~~ - ~ .. ~~ ~iUti ~ 0 2010 IN TIDE COURT OF COMMON PLEAS OF CUMBERt,AND COUNTY, PENNSYLVANIA KRISTINE E. POTTEIGER, Plaintiff v. ROGER K. POTTEIGER, Defendant No. 2010-3647 ,. CIVIL ACTION -LAW - (In Custody) s~r ~' W ORDER OF COURT ~ AND NOW, this ~ Z~ .day of ~_ 20I0, upon presentation and __~ consideration of the Stipulation and Agreemem, and upon agreement of the parties, it is hereby ORDERED and DECREED as follows: 1) The parties shall have joint legal custody of their minor child, Levi J. Potteiger. Joint legal custody means the right of both parents to control and to share in making decisions of importance in the life oftheir child, including educational, medical, and religious decisions. Each parent shall have an equal right, to be exercised jointly with the other paren#, to make all major non emergency decisions affecting the child's general well-being, including, but not limited to, all decisions regarding their health, education and religion. The custodial parent shall inform the non-custodial parent immediately of all medical and dental appointments and problems pei4aining to the child. If the child is sick and is unable to attend school or extracurricular activities the custodial parent will notify the non-custodial parent as soon as practicably possible. Each parent shall provide names, addresses, and telephone numbers for all of the child's medical, dental and other healthcare providers, school contact information as well as the school's website and any website's relating to the child's activities. In the event that either parent cannot obtain information or schedules directly, the other parent shall provide the documentation upon request. ~-~ =~, ~-; The custodial parent shall notify the other parent of any medical, dental, optical, counseling and other appointments of the child with health care providers, sufficiently in advance thereof so that the other party can attend, if he or she so chooses. Pursuant to the terms of Pa.C.S. §5349, each parent shall be entitled to equal access to all records and information pertaining to the child, including, but not limited to, the child's school, medical, dental, religious and other important records, the residence address of the child and the other parent. As soon as practical after the receipt by a party, copies of the child's school schedule, special events notifications, report cards, and similar items shall be provided to the other party. To the extent one {l}parent has possession of any such records or information, that parent sha11 be requixed to share same, or copies thereof, with the other parent within such reasonable time as to make the records or information of reasonable use to the other parent. The custodial parent shall provide copies of the child's report cards and other reasonable papers affecting the child's education, medical condition or welfare. Notwithstanding that both parents shall share legal custody, non-major decisions involving the child's day-to-day living shall be made by the parent then having custody, consistent with the other provisions of this Stipulation and Order. 2) Physical custody of the child, as that term is defined in the Custody Act, shall be primarily with Mother, subject to Father's periods of partial custody as the parties may agree. 3) Trunsportxtinn for custody purposes shall be divided by the parties as equally as possible. Unless otherwise agreed, the parent receiving custody shall transport the child from the home of the other parent. 4) The parties shall share custody of the child during the holidays as they mutually agree. 5) Each party shall be entitled to take vacation with the child after giving the other party advance notice of their intent and the dates of the vacation. 6) The parties shall provide each other with a written schedule or website address to ascertain a schedule for the child's school, sporting, and eatracurricularcctivities. Both patties shall agree to honor and participate in the activities in which the child wishes to engage. During the times that each parent has custody of the child, each parent will make certain that the child attend any previously-scheduled extracurricular activities. The parties are directed to be supportive of the child's activities and will transport the child to and from such activities and the preparations and practice for the activities that are scheduled, in such time so that the child is able to participate in those events. In the event that the custodial parent is unable to deliver either child to an agreed upon activity, the nan-custodial parent shall be permitted to transport the child to the agreed upon activity. The custodial parent shall make certain that the child is transported to appropriate custody exchange location in a time sufficient to enable the child to timely attend the activity. 7) The custodial parent shall ensure that the children complete any and all school assignments or projects during their period of custody. 8) In the event that either child is unable to attend school due to illness, it is the responsibility of the parent then having custody to arrange alternate care for that day and to notify the non-custodial parent of the child's illness. 9) In the event that either party is planning to take either child away from home for an overnight trip, they shall provide the non-custodial parent with reasonable notice and contact information where the child will be staying. 10) Each party shall confer with the other on all matters of imiportance relating to the child's health, maintenance, and education with a view towards obtaining and following a harmonious policy in the child's education and social adjustments. Each party agrees to keep the other informed of his or her residence and telephone number to facilitate communication concerning the welfare of the child and the custody situation. Each party shall supply the name, address and phone numbers of any persons in whose care the child will be in for a period in excess of seventy-two (72) hours, and for each person or entity which may provide daycare for the child, excluding current daycare providers, relatives, or public school institutions. 11) Emergency decisions regarding the child shall be made by the parent then having custody. However, in the event of any emergency or serious illness of the child at any time, any party then having custody of the child shall immediately communicate with the other party by telephone or any other means practical, informing the other party of the nature of the illness or emergency, so the other parent can become im+olved in the decision-making process as soon as practical. The term "serious illness" as used herein shall mean any disability which confines either child to bed for a period in excess of seventy two (72) hours and which places either child under the direction of a licensed physician, 12) The welfare and convenience of the child shall be the prime consideration of the parties in any application of the provisions of this Stipulation and Agreement. Both parents are directed to listen carefully and consider the wishes of the child in addressing the custodial schedule, any changes bo the schedule, and any other parenting issues. 13) Any madificatlons of this Stipulation and Agreement need to be in writing, and agreed to by both parties. Minor, short-term changes can be made orally, if agreed upon by both parties. In the event that either party is not in agreement with a proposed change, this Stipulation, Agreement, and Order will control the custodial arrangement until such time as the parties are able to agree. 14) This Stipulation, Agreement and/or Order supersedes all previous custody Agreemerrts and/or Orders. BY THE COURT, ~~ ,3. Distribution: "Lindsay Gingrich Maclay, lssquire, UALBY ZiIC%ER MEIL'FCIN M1N8R & GINCRiCH, I.LC, 1x29 Scenery Drive, Harrisburg, PA 17109 -Attorney jor Plainti„~' ~ Michael A. Scherer, Ssc{uire, BARK 8t SCHERER, 14 West South Street, Carlisle, PA 17013 - Attorneyfor Defendant t E.S rn~t l.~c~-.~ ~3 rz, f cc~ .~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIAN -� KRISTINE E. POTTEIGER, Plaintiff No. 2010-3607 -� V. CIVIL ACTION- LAW ROGER K. POTTEIGER, Defendant (In Custody) PRAECIPE TO THE PROTHONOTARY: Kindly withdraw the appearance of Daley Zucker Meilton Miner & Gingrich, LLC, as counsel for Plaintiff in the above-captioned matter. Daley Zucker Meilton Miner& Gingrich, LLC Date: 3- ig- 1 :3 WJZA�_� andra L. Meilton, Esq ire Attorney I.D.No. 32551 635 N. 12th Street, Suite 101 Lemoyne, PA 17043 (717) 724-9821 smeilton @dzmmglaw.com Kindly enter the appearance of Lindsay Gingrich Maclay, Esquire as counsel for the Plaintiff in the above-captioned matter. Law Offices of Peter J. Russo, P.C. Date: 3 1 M/1113 r '� A'�� m say Gin 4Road.,ySuite squire 50 6 East Tn dle 203 Mechanicsburg, PA 17050 (717) 591-1755 lgmaclay @pjrlaw.com