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HomeMy WebLinkAbout01-7192 SAIDIS SHUFF, FLOWER & LINDSAY ATrORI~YS~AT*IAW 26 W. High Street Carlisle, PA BRINTON E. FOX, MELISSA A. FOX, Plaintiff VS. Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 01- 7/9oQ' CIVIL TERM : : IN CUSTODY COMPLAINT FOR PARTIAL CUSTODY 1. The Plaintiff is Brinton E. Fox, residing at 138 Gardners, Cumberland County, Pennsylvania. 2. The Defendant is Melissa A. Gardners, Cumberland County, Pennsylvania. Fox, residing at Pine Grove Road, 388 Oxford Road, FROM/TO birth to 10-29-01 10-29-01 to present Melissa A. Fox Maternal grandparents and at the following addresses: NAME Brinton Fox and Melissa A. Fox ADDRESS 138 Pine Grove Road Gardners, PA 388 Oxford Road Gardners, PA 3. The Plaintiff seeks partial custody of the following children: Allyson Olivia Fox, born June 1, 1991; and Shane Brinton Fox, bom March 16, 1993 who resides at 388 Oxford Road, Gardners, Cumberland County, Pennsylvania. Allyson was born prior to the parties' marriage and out of wedlock, but Shane was born in wedlock. The children are presently in the custody of mother who resides at 388 Oxford Road, Gardners, Cumberland County, Pennsylvania. During the past five years, the children have resided with the following persons SAIDIS SI-lUFF, FLOWER & LINDSAY A~rORNIgYS*AT*LAW 26W. High Street Carlisle, PA The mother of the children is Melissa A. Fox, currently residing at 388 Oxford Road, Gardners, Cumberland County, Pennsylvania. She is married. The father of the children is Brinton E. Fox, currently residing at 138 Pine Grove Road, Gardners, Cumberland County, Pennsylvania. He is married. 4. The relationship of the Plaintiff to the children is that of Father. The Plaintiff currently resides alone. 5. The relationship of the Defendant to the children is that of Mother. The Defendant currently resides with the children and her parents. 6. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation concerning the custody of the children in this or another jurisdiction. 7. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of the Commonwealth. 8. The 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. SAIDIS SHUFF, FLOWER & LINDSAY ATrORNEYS,AT,.LAW 26 W. High Street Carlisle, PA requested because: a) b) The best interest of the children will be served by granting the relief Plaintiff is a good and loving father. The children's best interest will best be served by an expanded relationship with his father. 10. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, the Plaintiff requests this Court to grant partial physical custody of the children to the Plaintiff. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By ~uire West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY ATfORNEYS*AT*LAW 26 W+ High Street Carlisle, PA VERIFICATION I, the undersigned, hereby verify that the statements made herein 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. Brinton E. Fox Date: /~.' IH' O I BRINTON E. FOX PLAINTIFF V. MELISSA A. FOX DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-7192 CIVIL ACTION LAW IN CUSTODY AND NOW, Tuesday, January 08, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Varney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, January 30, 2002 at 2:30 PM 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. All children age five or older may also be present at the conference. 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/ lacaueline M. Vernev. Esa. ~ ' ' 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 heating or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 BRINTON E. FOX, Plaintiff V. MELISSA A. FOX, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-7192 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this 5"" day of ~¥.,4~, ~ c~o,n, sideration of the attached Custody Conciliation Rep~, ,2002, upon it is ordered and directed as IOIIOWS~ 1. The custody provisions of the PFA Order dated January 11, 2002 and the stipulated custody provisions in the Mutual PFA Order (undated at the time of the writing of this Order), are hereby vacated. 2. The Father, Brinton E. Fox, and the Mother, Melissa A. Fox, shall have shared legal custody of Allyson Olivia Fox, born June 1, 1991 and Shane Brinton Fox, born March 16, 1993. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 3. The parties shall have shared physical custody of the children on the following schedule: A. Father shall have physical custody of the children January 30, 2002 to Friday, February 1, 2002 after school when Mother shall pick up the children at school. B. Mother shall have physical custody of the children from after school on February 1, 2002 to Sunday, February 3, 2002 at 6:00 p.m. C. Thereafter the parties shall have physical custody of the children on a week on/week offbasis. Father's week shall begin Sunday February 3, 2002 at 6:00 p.m. Thereafter the parents shall alternate physical custody of the children on a week on/week off basis with the exchange day and time being Sunday at 6:00 p.m. D. The parties shall split the Easter Sunday holiday such that the exchange time shall be at 2:00 p.m. 4. The exchange of physical custody shall take place with the "receiving p nt prow&ng transportation so that the parties have no contact with each other. The parties shall remain in their vehicles at pick up, remain parked on the roadway or at the end of the driveway while the children walk to the parent's vehicle. 5. While the children are in Mother's physical custody, she shall arrange to transport the children to and from school. 6. The parties shall be entitled to nightly telephone contact with the children. 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. Another Conciliation Conference is scheduled for May 8, 2002 at 8:30 a.m. BY THE COURT,  1 Lindsay, Esquire, Counsel for FatherJ ' a./'Rebecca Hughes, Esquire, Counsel for Mother 2 BRITON E. FOX, Plaintiff Ve MELISSA A. FOX, Defendant PRIOR JUDGE: Kevin A. Hess, J. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 2001-7192 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ..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 Children who are the subject of this litigation is as follows: NAME Allyson Olivia Fox Shane Brinton Fox DATE OF BIRTH June 1, 1991 March 16, 1993 CURRENTLY IN CUSTODY OF Mother Father 2. A Conciliation Conference was held in this matter on January 30, 2002, with the following individuals in attendance: The Father, Brinton E. Fox, with his counsel, Carol Lindsay, Esquire and the Mother, Melissa A. Fox, with her counsel, Douglas Miller, Esquire for Rebecca Hughes, Esquire. 3. A prior Order of Court, dated January 11, 2002 was entered by the Honorable Kevin A. Hess, in a Temporary PFA that included physical custody of Shane to Father. The parties further signed a Stipulation at the conciliation conference that entered mutual PFA Orders and custody provisions. That Stipulation had not been entered as an Order of Court at the time of the conciliation conference. 4. The parties agreed to the entry of an Order in the form as attached. Date /~i cq(~line M. Vemey, Esquire Custody Conciliator BRINTON E. FOX, Plaintiff/Respondent VS. MELISSA A. FOX, DefendanffPetitioner 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-7192 : CIVIL ACTION - LAW : CUSTODY PETITION TO MODIFY CUSTODY ORDER The Defendant/Petitioner, Melissa Fox, by and through her attorney, Jeaun6 B. Costopoulos, Esquire, avers the following in support of this Petition: 1. The Petitioner, Defendant above, is Melissa Fox, an adult individual who currently resides at 14 Larken Lane, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 2. The Respondem, Defendant above, is Brinton E. Fox, an adult individual who currently resides at 138 Pine Grove Road, Gardners, Cumberland County, Pennsylvania 17324. 3. Plaintiffand Defendant are married. However, a divorce action is pending between the parties at Cumberland County Docket No. 02-3875. 4. The Petitioner seeks modification of an Order of Court dated February 5, 2002 regarding the following children: Allyson Fox, bom June 1, 1991, and Shane Fox, bom March 16, 1993. 5. The relationship of the Petitioner to the child is that of natural mother. The relationship of the Respondent to the child is that of natural father. 6. Respondent previously filed a complaint at the above docket number and an agreed upon order of court was entered on February 5, 2002. This order is attached as Exhibit A. 7. Petitioner does not know of a person not a party to the proceedings who has physical custody of the children or claims to have physical custody or visitation rights with respect to the children. 8. The best interests of the children and permanent welfare of the children will be served by modifying the February 5, 2002 Order of Court by granting primary physical custody of the children to Petitioner subject to periods of partial custody/visitation with Respondent, preferably on an alternating weekend basis. The reasons for Petitioner's request are as follows: (a) The children are unhappy under the current order. They feel they are living from a suitcase and have requested Petitioner to change their current situation. (b) The child Allyson has told Petitioner that Respondent has said that "[her mother] doesn't want her and that [he's] going to find a new mom for [them]." (c) Respondent recently violated the Protection from Abuse Order and as a result of spending a mght in jail is now ptmishing Petitioner by not allowing her any contact with the children during his periods of partial custody. WHEREFORE, Petitioner respectfiflly requests this Honorable Court to modify its February 5, 2002 Order as stated above. RESPECTFULLY SUBMITTED: Je~, Esquire COSTOPOULOS & WELCH 1400 North Second Street Harrisburg, Pennsylvania 17102 PA Supreme Court ID No. 68735 Telephone: (717) 221-0900 Fax: (717) 221-0904 ATTORNEY FOR DEFENDANT/PETITIONER BRINTON E. FOX, Plaintiff/Respondent VS. MELISSA A. FOX, Defendant/Petitioner IN THE COURT OF COMMON PI : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-7192 : CIVIL ACTION - LAW : CUSTODY VE.I~II~ICATION I, Melissa Fox, Petitioner, hereby verify and state that the facts set forth in the foregoing Petition are txue 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 unswom falsification to authorities. Dated: Melissa Fox BRINTON E. FOX, Plaintiff/Respondent VS. MELISSA A. FOX, Defendant/Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2001-7192 : CIVIL ACTION - LAW : CUSTODY CERTIFICATE OF SERVICE I, Jeann6 B. Costopoulos, Esquire, hereby certify that this day I served a copy of the foregoing document upon the persons, and in the manner, indicated below, which service satisfies the requirements of the PA Rules of Civil Procedure, by depositing a copy oftbe same with the United States Post Office at Hamsburg, Pennsylvania, through first class mail, p~paid, and addressed as follows: Carol J. Lindsay, Esquire 26 West High Street Carlisle, PA 17013 BY: Jean6 B. Costopoulos, Esquire ATTORNEY FOR DEFENDANT/PETITIONER 1400 N. Second SUeet Han'isburg, PA 17102 (717) 221-0900 Supreme Ct. ID No. 68735 EXHIBIT a OCT-ZZ-ZOOZ 11 50AM FROM-IR~tlL ~KNI~.H? & HUGHES [,~W OFFICES +?lr2,tSSH4 T-SE6 P.OO1/O0~ F-722 BRENTON E. FOX, Plaintiff V, MELISSA A. FOX, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-?192 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY oonstderalion of the attached Custody Conciliation Repo~_j~is ordm*ed and directed as follows: 1. Th~ custody provisions of tha PFA Order dated January 11, 2002 and the stipulated custody provisions in the Mutual PFA Order (undated at thc time of thc writing of tiPs Order), are hereby vacated. 2. The-Father, Brlnton E. Fox, and the Mother, Melissa A. Fox, shall have shared legal custody of Allyson Olivia Fox, bom June l, 1991 and Shane Brinton Fox, bom March 16, 1993. Each parer shall have an.equal fight, to 1~ excised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-bcin~ including,, but not limited to, all decisions regatdin$ their health, education and religion, 3. The parties shall have shared physical custody of the children on the following schedule: A. Father shall have physical custody of the chil~en January 30, 2002 to Friday, February 1, 2002 after school when Mother shall pick up the children at school. B. Mother shall have physical custody of thc children from after school on February I, 2002 to Sunday, February 3, 2002 at 6:00 p.m. C. Thereafter the parties shall have physical custody of the children on a week on/week offbasis. Father's week shall begin Sunday February 3, 2002 at 6:00 p.m. Thereafter the parents shall alternate physical custody of the children on a week on/week offbasis wilh the exchsn~e day and time beina Sunday at 6:00 p~. D. The panics shall split the Eas~er Sunday holiday such that the exchange time shall be at 2:00 p.n~ 4. The exchange of physical custody shall take place with the '~eceiving parent;' providing transportation so t_h_st the parties have no contact with each other. The pa~ties shall remain in Qleir vehicles at pick up, remain parked on the roadway et at the end of the driveway white the children walk to the parent's-vehicle. OCT-ZZ-2OOZ I~:EDAM FRC~IRWI~, ~KNIGHT & HUGHES LAW OFFICES +?l?24983E4 T-SS8 P.002/003 F-?2Z While the children aze in Mortimer's physical custody, she shall arrani~e to transport the children to and from school. 6. The partie~ shall be entitled to nightly ~elephone contact with the children. ?. This Orde~ is ent~-red pursuant to au a~,eeme~ of the pazti~s at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the ~erms of this Order shall con~rol, Another Conciliation Cct~emnce is scheduled for May 8, 2002 a~ $:130 a.m. cc: Carol Lindsay, Esqulm, Co~_~el for l~ather Rebecca Hu~hes, Esquire, Counsel far Mothe~ 0¢T-22-2002 11:51AM F~OI,/,..I~Wlfl, ~KNIGHT & HUGHES LAW OFFICES +7172406354 T-686 P 003/003 F-?22 BRFrON E. FOX, Plaintiff MELISSA A. FOX, Defeudan! : IN TH~ COURT OF COMMON PLEAS OF : CUlVIB~ COUNTY, PENNSYLVANIA 2001-~192 CIVIL TERM CIVIL ACTION - L&W IN CUSTODY PRIOR JUDGE: Kevin A. Hess, J. CUSTODY CONCILIATI_ON S~Y REPORT IN ACCORDANCE WITH CUB~ERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the followin$ 1. The pe/~ineat information concerning the Childr-~ who are the subj~'~ of this litigation is as follows: NAME DATB OF BIRTH CURRI~TLY IN CUSTODY OF Allyson Olivia Fox June 1, 1991 Metier Shane Brinton Fox ' March 16, 1993 Father 2. A Conoiliation Conf~mce was held in '~his matter on January ~0, 2002, with ~he following individuals in attendance: The Father. Brinton E. Fox. with his counsel. Carol Lindsay. F. squire and the Me,er. Melissa A. Fox. with her counsel. Douglas Miller, Esquire for Rebecca Hu~hes, Esquire. 3. A prior Order ofCour~ dated Sanuary 11, 2002 was entered by thc Honorable Kevin A. Hess, in a Temporary PFA ~mt included physical custody of Shane to lra~r. The parties further si~ned a Stipulation a~ the conciliation conference that entered mutual Pi:A Orders and custody provisions. Ti~ Stipulation had not been untored as an Order of Court at the time of the conciliation conference. 4. The parties al:reed to the unlry of an Order in the form as attached.' Cus~ociy Conciliator BRINTON E. FOX PLAINTIFF MELISSA A. FOX DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : 01-7192 CIVIL ACTION LAW : IN CUSTODY : ORDER OF COURT AND NOW, Wednesday, November 06, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before .Jacqueline M. Verney, Esq. , the conciliator, at4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, December 04, 2002 at 2:30 PM 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. All children age five or older may also be present at the conference. 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, Sl~ecial Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl ]acqueline M. Verney, Esq. ca 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. I.F YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 BRINTON E. FOX, Plaintiff/Respondent MELISSA A. FOX, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2001-7192 CIVIL TERM : : IN CUSTODY ORDER OF COURT AND NOW, this 5-' day of ~e,~o- ., 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. A Hearing is scheduled in Court Room No. z~/ , of the Cumberland County Court House, onthe o~1,o-6 dayof '~9't~t,~,- ,2003, at / o'clock, fO. M., at which time testimony will be taken. For purposes of this Hearing, the Mother shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing, a summary of the anticipated testimony of each witness and any new theories of the case. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. This Order supercedes the custody provision:; contained in the Exhibit attached to the Order of Court dated November 12, 2002. Pending further Order of Court or agreement of the parties, the Order of Court dated Febrmrry 5, 2002 is reaffirmed except as modified by the Order of November 12, 2002, with the following additional modification: 3. The children shall initiate a telephone call to lhe non-custodial parent at 6:00 p.m. every day. In the event that they will not be available to call at 6:00 p.m., they shall call earlier to advise the non-custodial parent that they will be unable to call at the designated time. If they do not speak to the non-custodial parent they shall leave a message and attempt to call again at a later time. 4. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, 7 . Hess, j. cc~eanne B. Costopoulos, Esquire, counsel ~or Mother /'} t7'~, a'ts) ! t,/Carol J. Lindsay, Esquire, counsel for Father BRINTON E. FOX, Plaintiff/Respondent Ve MELISSA A. FOX, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2001-7192 CIVIL TERM : : IN CUSTODY PRIOR JUDGE: Kevin A. Hess, J CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, thc undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME Allyson Fox Shane Fox 2. DATE OF BIRTH CURRENTLY IN CUSTODY OF June 1, 1991 shared March 16, 1993 shared A Conciliation Conference was held December 4, 2002 with the following individuals in attendance: The Mother, Melissa A. Fox, with her counsel, Jeanne B. Costopoulos, Esquire, and the Father, Brinton E. Fox, with his counsel, Carol J. Lindsay, Esquire. 3. The Court previously entered Orders on February 5, 2002find November 12, 2002, providing for shared legal and physical custody of'the childre~i. 4. Mother's position on custody is as follows: Mother seeks shared legal and primary physical custody with Father having alternating weekends. She maintains that the children oppose the week on/week off arrangement, wishing to not live out of a suitcase, that the children want a permanent home. 5. Father's position on custody is as follows: Father believes that the shared arrangement has worked well since February, 2002. That there is not reason to change it now. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing continuing the present Orders with a modification allowing for daily telephone contact. It is expected that the Hearing will require one half day. Date ~cq~~-~erne~y,'Es~Z~'~quire ,~ Custody Conciliator BRINTON E. FOX, Plaintiff VS. MELISSA A. FOX, Defendant IN THE COURT OF cOMMON PLEAS · CUMBERLAND cOUNTY, PENNSYLVANIA · No. 2001-7192 CIVIL ACTION - LAW · CUSTODY PRAECWE TO WITHDRAW PETITION TO THE PROTHONOTARY: Please mark the Petition for Modification filed on October 31, 2002 by Defendant, Melissa A. Fox, withdrawn and settled and cancel the Hearing currently scheduled to take place before the Honorable Kevin A. Hess on March 21, 2003 at 1:30 p.m. per Order of Court dated December 5, 2002. RESPECTFULLY SUBMITTED: Dated: ATTORNEY FOR DEFENDANT 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Phone: (717) 790-9546 Supreme Ct. ID No. 68735 BRINTON E. FOX, Plaintiff VS. MELISSA A. FOX, Defendant IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · No. 2001-7192 CIVIL ACTION - LAW CUSTODY CERTIFICATE OF SERVICE I, Jeann6 B. Costopoulos, Esquire, hereby certify that this day I served a copy of the foregoing document upon the persons, and in the manner, indicated below, which service satisfies the requirements of the PA Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Harrisburg Pennsylvania, through first class mail, prepaid, and addressed as follows: Carol J. Lindsay, Esquire 26 West High Street Carlisle, PA 17013 Dated: BY: Jeann6 B. Costopoulos, Esquire ATTORNEY FOR DEFENDANT 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Phone: (717) 790-9546 Supreme Ct. ID No. 68735