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23 DEC I I AN I : 43
CUMBERLAND COUNTY
COGNETTI&ASSOCIATES PENNSYLVANIA
MARGARET M.SIMOK,ESQUIRE
Attorney I.D.No.89633
3304 Market Street
Camp Hill,PA 17011
Telephone No.(717)909-4060
Attorney for Defendant
KIMBERLY R. LEONHART, :IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY PENNSYLVANIA
v. :2012 -5971 CIVIL ACTION - LAW
ALAN J. LEONHART, •
Defendant :IN CUSTODY
MOTION FOR CONTINUANCE
ALAN J. LEONHART, Defendant, represented by Margaret M. Simok, Esquire, moves
this Honorable Court to continue the matter scheduled for a pre-trial conference on December
18, 2013 at 3:00 p.m. and a hearing on January 23, 2014 at 9:00 am, before The Honorable M. L.
Ebert, Jr. Defendant is are requesting a continuance for the following reason:
1. Defendant has recently retained Margaret M. Simok, Esquire to represent him in this
matter.
2. Attorney Simok requires additional time to adequately prepare for this custody case.
3. Counsel for Plaintiff, Steven Howell, Esquire, has indicated to Attorney Simok that
he will concur with her request for a continuance.
4. Attorney Howell is not available for the hearing scheduled for January 23, 2014.
•
5. Attorney Howell and Attorney Simok are available on January 22, January 24,
January 30 and January 31, 2014.
WHEREFORE, the Defendant respectfully requests that this Motion be granted.
Respectfully Submitted:
COGNETTI& ASSOCIATES
Date: By: 1i. ,, _.l a<<
ARGs ' T M. SIMOK, ESQUIRE
Attorney I.D. No. 89633
3304 Market Street
Camp Hill, PA 17011
Telephone No. (717) 909-4060
Attorney for Defendant