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Home My WebLink About04-5679 EDWARD RIDOLFI and JANICE RIDOLFI, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, : PENNSYLVANIA v. No. 0 l./ - 6:1, '1,/ ROBERT C. SPENCER and RENEE RIDOLFI, Defendants CIVIL ACTION - CUSTODY STIPULATION FOR CUSTODY ORDER AND NOW this IJth day of AJoW;M. her , 2004, it is stipulated between plaintiffs, Edward Ridolfi and Janice Ridolfi (hereinafter referred to as " Maternal Grandparents"), and defendants, Renee Ridolfi (hereinafter referred to as "Mother") and Robert C. Spencer (hereinafter referred to as "Father"), as follows: 1. Maternal Grandparents, Mother and Father shall have shared legal custody of the minor child of Mother and Father, Noah Gregory Ridolfi, born June 7, 1997 (hereinafter referred to as "Noah"); provided, however, that Maternal Grandparents shall make all educational decisions for Noah. 2. Maternal Grandparents shall have primary physical custody of Noah. Page 1 of 3 3. Separately, Mother and Father shall have visitation with and partial custody of Noah at such times as Maternal Grandparents and each parent shall agree. IN WITNESS WHEREOF and intending to be legally bound hereby, the parties have executed this stipulation on the day and year first above written. WITNESS: ri1< r i ( c;}-;;/?I ~w~ / ("'J /' ! " 'i' (, / (.....<../ \ ~VU~ 1(f(cd01 h , J Renee Ridolfi II L-J "K.v-@~ (' , S ~^ ~ Robert C. Spencer ~</)1f ~~fL ' ~ice Ridolf~ r ~~7- Page 2 of 3 On this, the IJt~ day of November 2004, subscribed, sworn to and acknowledged before me by Robert C. Spencer, Renee Ridolfi, Edward Ridolfi, and Janice Ridolfi. ITN~SS(j' RE OF I hereunto set my hand and official seal. --f) '/, 'v~'->..t Notary Public mi sion Expires: Notarial Seal Oerek J. Cordier. Notary Public Harrisburg, Dauphin County My Commission Expires Feb. 14,2005 ftJl 3 ',",'\ r) (". ~~_l I '.' ~~. ::':f -, C::-) -....J .......) ~, ",. (,' ,) ......- (--) ,'I ;;:...... ( ~ :-;-J j ,: :--:: ,- fT) ,-) (' .., , ,~. i ~-i~~ ..,'~ ~ -' -:-, ~, . " ,'-", :"jfn .:--1 > o NOV 1 7 2004 i EDWARD RIDOLFI and, Janice Ridolfi, Plaintiffs : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, : PENNSYLVANIA . . ROBERT C. SPENCER and RENEE RIDOLFI, Defendants . . No. {J'I- 5~7j ~ v. . . CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW this Z [sf day of Iv c> \/' , , 2004, upon consideration of the stipulation submitted by plaintiffs, Edward Ridolfi and Janice Ridolfi (hereinafter referred to as "Maternal Grandparents"), and defendants, Renee Ridolfi (hereinafter referred to as "Mother") and Robert C. Spencer (hereinafter referred to as "Father"), it is hereby ordered and decreed as follows: 1. Maternal Grandparents, Father and Mother shall have shared legal custody of the minor child of Mother and Father, Noah Gregory Ridolfi, born June 7, 1997 (hereinafter referred to as "Noah"); provided, however, that Maternal Grandparents shall make all educational decisions for Noah '. 2. Maternal Grandparents shall have primary physical custody of Noah. Page 1 of 2 r 1. ~ ~ It- 'Pi \.I\I\\\f(\l "-SNN3d v I" I J I ,....,,..,'Mt"'Ii"\ t I Mnf"'lf", r'~,\';nr'~~'d~ 11 IV j\J.J.... P.,...!'-; '" '" ,,;!'- )..J u" \ ~ "..(: LS : \ ~d zz "ON "nUl )..'cl'1\O:>-.\OHl.O'dd 3\-\1 :\0 u - -38\~~O-G31\:I ...... ;-.. 3. Separately, Mother and Father shall have visitation with and partial custody of Noah at such times as Maternal Grandparents and each parent shall agree. BY THE COURT: (({:;( J. Page 2 of 2 , '. EDWARD RIDOLFI and JANICE RIDOLFI, Plaintiffs IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. No. 0 If- ~)7, '1,/ ROBERT C. SPENCER and RENEE RIDOLFI, Defendants CIVIL ACTION - CUSTODY STIPULATION FOR CUSTODY ORDER AND NOW this IJth day of AJOlJt#\hef , 2004, it is stipulated between plaintiffs, Edward Ridolfi and Janice Ridolfi (hereinafter referred to as " Maternal Grandparents"), and defendants, Renee Ridolfi (hereinafter referred to as "Mother") and Robert C. Spencer (hereinafter referred to as "Father"), as follows: 1. Maternal Grandparents, Mother and Father shall have shared legal custody of the minor child of Mother and Father, Noah Gregory Ridolfi, born June 7, 1997 (hereinafter referred to as "Noah"); provided, however, that Maternal Grandparents shall make all educational decisions for Noah. 2. Maternal Grandparents shall have primary physical custody of Noah. Page 1 of 3 3. Separately, Mother and Father shall have visitation with and partial custody of Noah at such times as Maternal Grandparents and each parent shall agree. IN WITNESS WHEREOF and intending to be legally bound hereby, the parties have executed this stipulation on the day and year first above written. WITNESS: -VUJ- ~1ccillL h , Renee Ridolfi . II L-J ~~v-@~ Q s ~ -- Robert C. Spencer a .v /J1 Ridolfi Page 2 of 3 . . . On this, the IJt~ day of November 2004, subscribed, sworn to and acknowledged before me by Robert C. Spencer, Renee Ridolfi, Edward Ridolfi, and Janice Ridolfi. lTN~SS?2' RE OF I hereunto set my hand and official seal. J;' /, 'v~'->..t Notary Public mi ion Expires: Notarial Seal Derek J. Cordier, Notary Public Harrisburg, Dauphin County My Commission Expires Feb. 14.2005 f,Jf. 3 ~ 1}~ '] , c ) ( ....1 C::J .....l ., .. ~ r'-' . , , ) .J;.- I :;-J j .: - ;:'"". c:' -J "; C.. -;-, ; I ;"'J ~ ,~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA EDWARD RIDOLFI and JANICE RIDOLFI Plaintiffs No,04-5679 VS, CIVIL ACTION - LAW MARK SPENCER and RENEE RIDOLFI Defendants CUSTODY MOTION FOR LEAVE TO WITHDRAW AS COUNSEL AND NOW, this 24th day of June, 2005, comes Derek J, Cordier, Esquire, Counsel for the Defendant, Renee Ridolfi and files the following Motion for Leave to Withdraw as Counsel and in support thereof avers the following: 1. Movant, Derek 1. Cordier, Esquire is presently counsel of record for the Defendant, Renee Ridolfi, 2, Respondent has failed to remit her balance due as required by a Fee Agreement executed between the Movant and the Respondent. 3, Movant avers that Respondent will not be prejudiced by Movant's withdrawal, as there are presently no scheduled hearings, conferences or court dates, 4, Movant's withdrawal as counsel for Respondent will not have any material adverse affect on Respondent's interest pursuant to Pennsylvania Rul,e of Professional Conduct 1.16, 5. In order to file for a nonpayment of fees judgment against the Respondent, Movant must withdraw as counsel. 6, Respondent, the Plaintiff's, and the Defendant, Mark Spencer's Counsel Kent Patterson, Esquire, were sent a copy of this Motion and Rule on June 24, 2005, WHEREFORE, Movant respectfully requests that this Honorable Court permit Derek J. Cordier, Esquire to withdraw as counsel for the Respond~, Renee Rido ,7 Respectfully submitte Derek rdier, E quire SC #83284 319 South treet Harrisburg, PAl 71 04 (717) 919-4002 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA EDWARD RIDOLFI and JANICE RIFOLDI Plaintiffs : No,04-5679 VS. : CIVIL ACTION - LAW MARK SPENCER and RENEE RIDOLFI Defendants CUSTODY CERTIFICATE OF SERVICE I, Derek J, Cordier, Esquire, hereby certifies that a true and correct copy of the forgoing Motion for Leave to Withdraw as Counsel was sent by U.S, Mail first class to the following: Renee Ridolfi 78 Mic Nan Drive Middletown, PA 17057 Edward and Janice Ridolfi 32 Scarsdale Drive Camp Hill, PA 17110 Kent Patterson, Esquire Attorney for Mark Spencer 221 Pine Street Harrisburg, PA 17101 Respectfully submitted, ? Date: b/~ 'i / oS- . ,- () ...., 0 = c = -n c.n so: L- ~ J2l"JJ " l{r: c: n1~ -';".0-,-". :z: &;;S <.0) ~ -<< 0 kC) :r.. -0 ~5 ;t.::c: :x bel "'..~m Pc ~ ~ &"" ?I; -<.. -...J -< (l IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA EDWARD RIDOLFI and JANICE RIDOLFI Plaintiffs No,04-5679 VS, CIVIL ACTION - LAW MARK SPENCER and RENEE RIDOLFI Defendants CUSTODY MOTION TO MAKE RULE AB,SOLUTE AND NOW, this 22nd day of August, 2005, comes Derek J, Cordier, Esquire, Counsel for the Defendant, Renee Ridolfi and files the following Motion to Make Rule Absolute and in support thereof avers the following: 1 ,Petitioner filed a Motion for Leave to Withdraw as Counsel on June 24th, 2005, 2, A Rule to Show Cause was issued by this Honorable Court on July 5th, 2005, granting the Respondent ten (10) days of service to show cause why the Motion for relief should not be granted, 3. Respondent was served with the signed Rule to Show Cause on July 21st, 2005, 4, As of the above captioned date not response has been filed by any party to this action, 5, Respondent, the Plaintiffs, and the Defendant, Mark Spencer's Counsel Kent Patterson, Esquire, were sent a copy of this Motion and Rule on June 24, 2005. WHEREFORE, Movant respectfully requests that this Honorable Court enter an order granting Derek J, Cordier, Esquire leave to withdraw from as counsel for the Respondent, Renee Ridolfi, Respectfully submitted, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA EDWARD RIDOLFI and JANICE RIFOLDI Plaintiffs VS, MARK SPENCER and RENEE RIDOLFI Defendants : No,04-5679 CIVIL ACTION - LAW CUSTODY CERTIFICATE OF SERVICE I, Derek J, Cordier, Esquire, hereby certifies that a true and correct copy of the forgoing Motion to Make Rule Absolute was sent by U,S, Mail first class to the following: Renee Ridolfi 78 Mic Nan Drive Middletown, PA 17057 Edward and Janice Ridolfi 32 Scarsdale Drive Camp Hill, PA 17110 Kent Patterson, Esquire Attorney for Mark Spencer 221 Pine Street Harrisburg, PA 17101 Respectfully submitted, Date: 8/);)/0 S IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA EDWARD RIDOLFI and JANICE RIFOLDI Plaintiffs : No,04-5679 VS, : CIVIL ACTION - LAW MARK SPENCER and RENEE RIDOLFI Defendants : CUSTODY CERTIFICATE OF SERVICE I, Derek 1. Cordier, Esquire, hereby certifies that a true and correct copy of the forgoing Rule was sent by U.S. Mail first class to the following: Renee Ridolfi 78 Mic Nan Drive Middletown, PA 17057 Edward and Janice Ridolfi 32 Scarsdale Drive Camp Hill, PA 17110 Kent Patterson, Esquire Attorney for Mark Spencer 221 Pine Street Harrisburg, PA 17101 Respectfully submitted, Date: -1/p. J,/vs-' RECEIVED JUl IJ 1 Z005, ^' ',IU!\. v' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA EDWARD RIDOLFI and JANICE RIDOLFI Plaintiffs : No.04-5679 VS, : CIVIL ACTION - LAW MARK SPENCER and RENEE RIDOLFI Defendants : CUSTODY RULE TO SHOW CAUSE AND NOW, this .5.''2:' day Of'--l'^~ ,2005, a Rule is hereby issued upon all parties to show cause why th attached MotJ.on for Leave to Withdraw as counsel should not be granted, RULE RETURNABLE I [} DAYS FROM SERVICE, By the Court; re[ fs!\."r. I I v 04 CY.f.tM, 9 Judge rf-" ,~, t',.,_"_..,,.- :0':1,,",,'/%.:, In T "d1i'1Y~d~~ ~.~,;;";;.fi .-,:/." ~,.." ,"'.. c,""" ,~.. """" '~"*"'i '" ~f;,,,,, ~N.I ill'~.. ~ W" ~~'lJili>l\,.O , ""It..-, _,."'~, '''l /' ~". {. .,..... """ >,wi ;:Umj ":.Ii.. (;:;~ lZ' ,..~.,. ":;':-'~ . ~...._.,. l':dUe-<"<r1-.~~_. ~YV*i~'i;";I:~~:;',/ C} "';,;.:;; r--'! ~ ~ ~ G'> ~ " <..-; .:1. ~ -' :r'e 0f'J :9,Q ;:::),C) '-""',' :>..-.r1 " ~)ZS ":':':f\\ ~.~ ~O, ',4 -0, ::t~ L,) .' L" ,;;;;.. - :1ECEIVED AUG 252005 ^y IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA EDWARD RIDOLFI and JANICE RIDOLFI Plaintiffs : No,04-5679 VS, : CIVIL ACTION - LAW MARK SPENCER and RENEE RIDOLFI Defendants : CUSTODY ORDER AND NOW, this ---2..5-lL day of b ,2005, based on the Motion to Leave to Withdraw as counsel and Rule to Sho ause, IT IS HEREBY ORDERED AND DECREED that leave to withdraw from representation in the above captioned matter, is hereby granted. By the Court; g:>j ~t f~t ..D t '::",:r<J S2 :01 WJ 62 8n\j soaz AtJ\Jl0NUdUJd 3H1 dO 3~)::L,O-ml!:l