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HomeMy WebLinkAbout04-3973RUSSELL A. FLUEVOG Plaintiff V. BETH A. HOTOVCIN Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2004 - ,.~? ?.3 CIVIL TERM : IN CUSTODY COMPLAINT FOR CUSTODY Plaintiff is Russell A. Fluevog, an adult individual who currently resides at 6 Wagner Drive, Mechanicsburg, Pennsylvania 17050. 2. Defendant is Beth A. Hotovcin, an adult individual who currently resides at 83 Partridge Circle, Carlisle, Pennsylvania 17013. 3. Plaintiff and Defendant have been bonafide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 21, 1985 and divorced on January 16, 2004. 5. Plaintiff seeks primary custody of Chelsey Ann Fluevog, born October 19, 1990 and Caitlin Alexandra Fluevog, born October 26, 1989. The children were bom while the parties were married. The children are presently in the shared custody of the parties, but the Defendant has been interfering with the Plaintiff's time with his children. During the past five years, the children have resided with the following persons at the following addresses: Persons Beth A. Hotovcin Michael Hotovcin Residences 83 Partridge Circle, Carlisle, Pennsylvania Dates March 2004 to present Beth A. Hotovcin 6 Wagner Drive, Mechanicsburg, Pennsylvania February 2004 to March, 2004. Beth A. Hotovcin Russell A. Fluevog Her parents home in Dillsburg, Pennsylvania 6 Wagner Drive, Mechanicsburg, Pennsylvania The natural father of the children is Russell A. Fluevog. He is divorced from the Defendant. August, 2003 to February, 2004 Birth to August, 2003 The natural mother of the children is Beth Hotovcin who divorced the Plaintiff and married her current husband in March, 2004. 6. The relationship of the Plaintiff to the children is that of natural father. The Plaintiff currently resides with the following persons: No one currently, although he is going to marry Tricia Kolodzi within the next month and relocate to her home at 571 F Street, Carlisle, Pennsylvania. 7. The relationship of the Defendant to the children is that of natural mother. The Defendant currently resides with Michael Hotovcin and the children. 8. 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 in any other Court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person nor 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. 9. The best interest and permanent welfare of the children will be served by granting the relief requested because: la) The parties had worked out a shared custody agreement but the Defendant unilaterally changed that arrangement and because of pressure from her current husband changed the parties commitment to enrolling the children in Christian-based schooling. At a support conference in late June she sought and was awarded as support the sum of $350.00 per month over the basic child support for the Christian education. lb) The Defendant has enrolled the daughter Caitlin in public school and the Plaintiff intends to file an Emergency Relief Petition in conjunction with this Complaint to secure a hearing prior to the staff of the school year to enroll her in a Christian academy. lc) Father wants to be accommodating to permit "frequent and continuing contact and physical contact" between the children and Mother. 23 PA C.S.A. 5303 la). (d) Chelsey has a seizure disorder and the Defendant has neglected to include the Plaintiff in arrangements for medical care and monitoring. The Father had a similar problem as a young person and can better understand and provide care for Chelsey in his home. (e) Prior to the parties separation the Plaintiff/Father had performed more of the parenting duties for the children, than the Defendant. 10. 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. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene. None. WHEREFORE, Plaintiff requests your Honorable Court to grant him primary custody of Chelsey and partial custody of Caitlin as well as shared legal custody of both children. Respectfully submitted, O'BRIEN, B^RIC & SCHERER Robert L. O'Brien, Esquire Attorney for Plaintiff I.D. # 28351 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 rlo~OomestictFluevogtcustody complaint RUSSELL A. FLUEVOG Plaintiff V, BETH A. HOTOVClN Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2004 - CIVIL TERM : IN CUSTODY VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. Russell A. Fluevog Date: August ~; ,2004 RUSSELL A. FLUEVOG Plaintiff V. BETH A. HOTOVCIN Defendant : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW : NO. 2004 - .3~'1 ~ CIVIL TERM : IN CUSTODY ORDER OF COURT Upon consideration of the attached Petition For Emergency Relief, the Court sets a hearing for the sole question to determine whether Caitlin Alexander Fluevog should attend Bible Baptist School in Shiremanstown, Pennsylvania. A hearing on this matter is scheduled for ~.~~,the ~ ~ .day of _ ~ __ _, Cumberland County Courthouse, .~___~, 2004 in Court Room No. Carlisle, Pennsylvania, ~ ¢/:00 ~./¢[. /2, A. FLUEVOG Plaintiff V. BETH A. HOTOVCIN Defendant : IN THE COURT C!F COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - I_AW : NO. 2004 - CIVIL TERM : IN CUSTODY ~ETITION FOR EMERGENCY R_ELIEF 1. Petitioner is Russell A. Fluevog. He is the father of Caitlin Alexandra Fluevog age 14. Attached is a complaint for custody which the Petitioner is filing in conjunction with this Petition for Emergency Relief. 2. Respondent is Beth A. Hotovcin who is the natural mother of Caitlin. 3. The parents of Caitlin, prior to their divorce, had made a commitment to send Caitlin to private Christian schooling. The mother, most recently, in June of 2004 sought support to pay the expenses of private schooling for both children. The father is paying and is agreeable to pay for the enrollment of Caitlin in a Christian school. 4. More recently, the mother has unilaterally decided that she does not want Caitlin to attend Christian schooling and has encouraged the girl to enroll at the Carlisle High School. The father believes that this is not in the best interest of Caitlin and requests a hearing prior to the beginning of the school year to determine whether the child should attend the Bible Baptist School in Shiremanstown for which enrollment applications have been made. WHEREFORE, Petitioner respecffullY requests that the Court set a hearing for the sole question of determining whether Caitiin Alexandra Fluevog should attend Bible Baptist School in Shiremanstown, Pennsylvania. Respectfully submitted, O'BRIEN, BARIC & SCHERER Rober~. O'Brien, Esquire Attorney for Plaintiff I.D. # 28351 19 West South Street CarlislE;, Pennsylvania 17013 (717) 2.49-6873 rlo\Domestlc~Ftuevog~emergpet' VERIFICATION I verify that the statement made in the foregoing Petition For Emergency Relief are true and correct. I understand that false statements herein are made subject to the relating to unsworn falsification to authorities. penalties of 18 Pa. C.S. § 4904, . ~, Date: August ~ --, 2004. RUSSELL A. FLUEVOG Plaintiff v. BETH A. HOTOVCIN Defendant iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2004 - CIVIL TERM : IN CUSTODY ORDER OF COURT _, 2004, upon consideration of the attached AND NOW, THIS day of . _ - · eb -directed that the parties and their re.,,pective counsel appear before COMPLAINT, ~t is her Y , Esquire, the conciliator, at ,2004 at A.M./PM., for a Pre- on the day of Headng Custody Conference. At ,~uch conference, an effort withe made t-o resolv~ 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. Absent a special request and prior arrangements with the conciliator, children are discouraged from attending the conciliation 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 at least 48 hours prior to the scheduled conference. FOR THE-' COURT, BY Custody Conciliator The Court of Common Pleas of Cumberland Coulnty is required by law to comply with the ' formation about accessible facilities and reasonable ^~,,,r~,.~,,~ 'th Disabilit es Act of 1990...F.or !n _ . - ,-- ~ nes before the Court please contact our ~,,, ........ w.! -:,-,-,-. +,- ,~ led inaivlauals having u~ s accommodations ava,~u~ 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 LAWYER A'l" 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, PA 17013 (717) 249-3166 RUSSELL A. FLUEVOG : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff i CIVIL ACTION - LAW v. : NO. 2004 - CIVIL TERM BETH A. HOTOVCIN Defendant i IN CUSTODY _COMPLAINT FOR CUSTODY 1. Plaintiff is Russell A. Fluevog, an adult individual who currently resides at 6 Wagner Drive, Mechanicsburg, Pennsylvania 17050. 2. Defendant is Beth A. Hotovcin, an adult individual who currently resides at 83 Partridge Circle, Carlisle, Pennsylvania 17013. 3. Plaintiff and Defendant have been bonafide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 21, 1985 and divorced on January 16, 2004. 5. Plaintiff ~seeks primary custody of Chelsey Ann Fluevog, born October 19, 1990 and Caitlin Alexandra Fluevog, born October 26, 1989. The children were born while the parties were married. The children are presently in the shared custody of the parties, but the Defendant has been interfering with the Plaintiffs time with his children. During the past five years, the children hove resided with the following persons at the following addresses: Persons_ Beth A. Hotovcin Michael Hotovcin Residences 83 Partridge Circle, Carlisle, Pennsylvania Dates March 2004 to present Beth A. Hotovcin 6 Wagner Drive, Mechanicsburg, Pennsylvania February 2004 to March, 2004. Beth A. Hotovcin Russell A. Fluevog Her parents home in Dillsburg, Pennsylvania 6 Wagner Drive, Mechanicsburg, PennsyNania August, 2003 to February, 2004 Birth to August, 2003 The natural father of the children is Russell A. Fluevog. He is divorced from the Defendant. The natural mother of the children is Beth Hotovcin who divorced the Plaintiff and married her current husband in March, 2004. 6. The relationship of the Plaintiff to the children is that of natural father. The Plaintiff currently resides with the following persons: No one currently, although he is going to marry Tricia Kolodzi within the next month and relocate to her home at 571 F Street, Carlisle, Pennsylwania. 7. The relations, hip of the Defendant to the children is that of natural mother. The Defendant currently resides with Michael Hotovcin ,-md the children. 8. 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 in any other Court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person nor 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. 9. The best interest and permanent welfare of the children will be served by granting the relief requested because: (a) The parties had worked out a shared custody agreement but the Defendant unilaterally changed that arrangement and because of pressure from her current husband changed the parties commitment to enrolling the children in Christian-based schooling. At a support conference in late June she sought and was awarded as support the sum of $350.00 per month over the basic child support for the Christian education. (b) The Defendant has enrolled the daughter Caitlin in public school and the Plaintiff intends to file an Emergency Relief Petition in conjunction with this Complaint to secure a hearing prior to the start of the school year to enroll her in a Christian academy. (c) Father wants to be accommodating to permit "frequent and continuing contact and physical contact" between the children and Mother. 23 PA C.S.A. 5303 (a). (d) Chelsey has a seizure disorder and the Defendant has neglected to include the Plaintiff in arrangements for medical care and monitoring. The Father had a similar problem as a young person and can better understand and provide care for Chelsey in his home. (e) Prio~ to the parties separation the Plaintiff/Father had performed more of the parenting duties for the children, than the Defendant. 10. 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. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene. None. WHEREFORE, Plaintiff requests your Honorable Court to grant him primary custody of Chelsey and partial custody of Caitlin as well as shared legal custody of both children. Respectfully submitted, O'BP, IEN, BARIC & SCHERER By: Robert L. O'Brien, Esquire Attorney for Plaintiff I.D.. # 28351 19 West South Street Carlisle, Pennsylvania 17013 (71~ 7) 249-6873 rlo\Oomestic~Fluevog\custody complaint RUSSELL A. FLUEVOG Plaintiff ~/. BETH A. HOTOVCIN Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW : NO. 2004 - CIVIL TERM IN CUSTODY VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Russell A. Fluevog Date: August _ ., 2004 RUSSELL A. FLUEVOG Plaintiff V. BETH A. HOTOVClN Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW · NO. 2004-;.~q13 CIVIL TERM : IN CUSTODY CERTIFICATE OF SFRVICF I hereby certify that on August I~-- , 2004, I, Robert L. O'Brien, Esquire of O'Brien, Baric & Scherer, did serve a copy of the Complaint For Custo,rly and Petition For Emergency Relief, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Beth A. Hotovcin 83 Partridge Circle Carlisle, Pennsylvanie 17013 Robert L. O'Brien, Esquire RUSSELL A. FLUEVOG, PLAINTIFF V. BETH A. HOTOVICIN, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 04-3973 CIVIL TERM ORDER OF COURT AND NOW, this ~,(~ day of August, 2004, upon agreement of counsel, the hearing currently scheduled for August 19, 2004, is cancelled and rescheduled to Monday, August 23, 2004, at 11:00 a.m., in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania. Edgar B. Bayley, J~,~ .¢,l~'obert L. O'Brien, Esquire For Plaintiff ¢/F~ilip H. Spare, Esquire For Defendant :sal RUSSELL A. FLUEVOG, PLAINTIFF : IN TH.E COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA BETH A. HOTOVCIN, DEFENDANT : 04-3973 CIVIL TERM ORDER OFCOURT AND NOW, this ~day of August, 2004, following a hearing on the petition of Russell A. Fluevog for emergency relief, IT IS ORDERED: (1) The petition for emergency relief, IS DENIED. (2) Caitlin Fluevog shall attend a school operated by ~e~i;Ce~chool District. ~B.~the~Co Edgar lB. Bayley, J. ~'~/bert L. O'Brien, Esquire For Plaintiff '~' - "~ ' .J~li~ip H. Spare, Esquire For Defendant LAW OFFICES SNELBAKER BRENNEMAN & SPAR~ RUSSELL A. FLUEVOG, Pla'mtiff, VS. BETH A. HOTOVCIN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO: 04-3973 CIVIL TERM : : IN CUSTODY NOTICE TO: RUSSELL A. FLUEVOG, Plaintiff and ROBERT L. O'BRIEN, Esquire, Attorney for Plaintiff You are hereby notified to file a written response to the enclosed Defendant's Answer to Plaintiff's Petition for Emergency Relief with New Matter twenty (20) days from service hereof or a judgment may be entered against you. SNELBAKER, BRENNEMAN & SPARE, P.C. By Phi[l[p~H. Spare, Esquire 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055-0318 (717) 697-8528 Attorneys for Defendant/Respondent Beth A. Hotovcin Dated: August 23, 2004 LAW O~FICE$ RUSSELL A. FLUEVOG, Plaintiff, VS. BETH A. HOTOVCIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 04-3973 CIVIL TERM IN CUSTODY DEFENDANT'S ANSWER TO PLAINTIFF'S PETITION FOR EMERGENCY REI,IEF WITH NEW MATTER AND NOW, comes the Defendant/Respondent, ]Beth A. Hotovcin, through her Attorneys, Snelbaker, Brenneman & Spare, P.C., and files the within Answer to Plaintiff's Petition for Emergency Relief as follows: 1. Admitted. By way of further response, it is averred that Caitlin's middle name is "Alexandria" not Alexandra as set forth in Father's Petition. 2. Admitted. 3. Admitted in part and denied in part. It is admitted that prior to their divorce, the )arents made a commitment to send Caitlin to private Christian schooling through eighth grade. t is denied that the parents made a commitment that she should continue in Christian schooling until graduation from high school. It is admitted that in June of 2004, Mother sought support to pay the expenses of private schooling for both Caitlin and her younger sister for the 2004-05 school year. It is admitted that at present Father is paying and is agreeable to pay for the enrollment of Caitlin in a Christian school. However, by way of further answer, it averred that Father's position regarding payment and agreement for the enrollment of Caitlin in a Christian school has been inconsistent as more fully explained in New Matter below. BRENNEMAN SPARE 4. Denied. It is denied that more recently, the Mother has unilaterally decided that she does not want Caitlin to attend Christian schooling and has encouraged the girl to enroll at the Carlisle High School. To the contrary, Mother discussed the choice of schools for Caitlin with Father after the June 23, 2004 Child Support Confixence and at that time, Father was agreeable to enrolling Caitlin at the Carlisle High School. Carlisle. 6. NEW MATTER Caitlin currently resides with her Mother, her younger sister and her stepfather in Transportation will be difficult if Caitlin were to attend Bible Baptist School in Shiremanstown. Based upon information provided to IVIother, it is averred that the cost of transportation will be approximately $85.00 per month. Caitlin would have to spend many hours per week on a bus if she attended Bible Baptist School in Shiremanstown. The cost and duration of transportation would not be an issue if she attended Carlisle High School. 7. Course selection is limited at Bible Baptist School. Carlisle High School provides a wider variety of courses for Caitlin's education. 8. Father has been inconsistent in his positiun regarding his ability and willingness to pay for Caitlin's Christian schooling. Prior to the June 23, 2004 Child Support Conference, Father informed Caiflin that he would not pay for private school tuition. 9. Caitlin is going to be a ninth grade student in the upcoming school year. Ninth grade is an ideal time for a student to transfer into the Carlisle School District as two middle school classes are merging into the ninth grade class and[ numerous private school students from other local private schools will be attending Carlisle High School for the first time. Mother 2 LAW OFFICES SNELBAKER BRENNEMAN believes that it is in Caitlin's best interest to transfer to ,Carlisle High School for ninth grade rather than transferring later in her high school years. 10. Mother believes it would be in Caitlin's best interest for the parties to save on school tuition now and use those funds to save for Caitlin's future college expenses. If Caitlin attends Bible Baptist School, the parties will not have sufficient funds to put money away for Caitlin's college expenses. 11. Caitlin has numerous friends attending Carlisle High School. Caitlin also attended an orientation program at Carlisle High School this summer and met several new people. 12. Caltlin has expressed a career goal of becoming a teacher. She would like to experience the teacher "shadowing" program at Carlisle High School. The "shadowing" program allows students to spend time with a teacher to learn more about the teaching ~rofession. 13. 14. It is in Caitlin's best interest to attend C~rrlisle High School. Caitlin is a mature fourteen year old student who has expressed mature reasons vhy she would prefer to attend Carlisle High School rather than Bible Baptist School. 15. The decision to have Caitlin attend Carlisle High School was not unilaterally made by mother. Rather, Mother consulted with Father in June of 2004 and Father agreed at that time to enrolling Caitlin in Carlisle High School. 16. Father's filing of an "emergency" Petition is unwarranted given his earlier approval of Caitlin's attendance at Carlisle High School. ~ SPARB WHEREFORE, Respondent Beth A. Hotovcin respectfully requests your Honorable Court to deny Plaintiff s Petition for Emergency Relief and to permit Caitlin Fluevog to attend the Carlisle High School. Respectfully submitted, SNELBAKER, BRENNEMAN & SPARE, P.C. Dated: August 23, 2004 By Ph~[p H~. S,l~are, ~squire Pa. Supreme Ct. I.D. # 65200 44 West Main Street P.O. Box 3,18 Mechanicsburg, PA 17055-0318 (717) 697-8528 Attorneys :For Defendant/Respondent Beth A. Hotovcin 4 LAW OFFICES SNELBAKER. BRENNEMAN ~ SPARE VERIFICATION I verify that the statements made in the foregoing Defendant's Answer to Plaintiff's Petition for Emergency Relief are true and correct. I m~derstand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unswom falsification to authorities. Beth A. Hotovmn Date: August t27,.~ ,2004 BRENNEMAN CERTIFICATE OF SERVICE I, PHILIP H. SPARE, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Defendant's Answer to Plaintiff's Petition for Emergency Relief With New Matter to be served upon the person and in the manner indicated below: FIRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Robert L. O'Brien, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 Date: August 23, 2004 Pa. Supreme Ct. I.D. # 65200 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055-0318 (717) 697-:8528 Attorneys for Defendant/Respondent Beth A. Hotovcin RUSSELL A. FLUEVOG : PLAINTIFF : V. : BETH A. HOTOVCIN : DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-3973 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, August 19, 2004 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear betbre ltubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle_ on _ Friday, September 03, 2004 at 8:30 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 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/ Hubert X. Gilroy, Esq. Custody Conciliator mhc 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 TttlS 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 GE F LEGAL HEL . Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 RUSSELL A. FLUEVOG, Plaintiff V BETH A. HOTOVCIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04 - 3973 IN CUSTODY COURT ORDER ~-~ f AND NOW, this c~/x.~ day of October, 2004, the, Conciliator being advised the parties have reached an agreement, the Conciliator relinquislaes jurisdiction. BY THE COURT,. Hubert X./Gilroy Custo~/Conciliator