Loading...
HomeMy WebLinkAbout05-0221 MICHAEL R. MEYERS, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. 0 s~ ;).) / ~'t4 1';- HANNAH YODER, Defendant : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is MICHAEL R. MEYERS, currently residing at 141 Peach Lane, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is HANNAH YODER, whose mailing address is 69 Fairview Road, New Providence, Lancaster County, Pennsylvania 17560. 3. Plaintiff seeks primary custody of the following children: Name present Address Casey Ray Meyers 141 Peach Lane Carlisle, P A 17013 Age 5 (DaB 10/31/99) Alexandra Paige Meyers 141 Peach lane Carlisle, P A 17013 2 (DaB 7/4/02) 4. The children were born out of wedlock. The children are presently in the custody of Plaintiffwho resides at 141 Peach Street, Carlisle, Cumberland County, Pennsylvania 17013. 5. During the past five years they resided with the following persons at the following addresses: Name(s) Address Dates The children lived in various places with either or both parents in either Dillsburg or Litiz. 2000 to June 2004 Plaintiff and Barbara Meyers (Grandmother) 48 Longwood Drive June 2004 to December 2004 Mechanicsburg, P A 17050 Plaintiff 141 Peach Lane December 2004 to Present Carlisle, P A 17013 6. The mother of the children is Defendant, HANNAH YODER, whose current mailing address is 69 Fairview Road, New Providence, Lancaster County, Pennsylvania 17560. She is single. 7. The father of the children is Plaintiff, MICHAEL R. MEYERS, currently residing at 141 Peach Lane, Carlisle, Cumberland County, Pennsylvania 17013. He is single. 8. The relationship of Plaintiff to the children is that of Father. The Plaintiff currently resides with the following persons: ~ Relationship Casey Ray Meyers Son Alexandra Paige Meyers Daughter 4 9. The relationship of Defendant to the children is that of Mother. The Defendant does not have a permanent residence at this time. 10. Plaintiff has not participated as a party or a witness, or in any other capacity in other litigation concerning the custody of the children in this or any other court. 11. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 12. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or who claims to have custody or visitation rights with respect to the children. 13. The best interest and permanent welfare of the children will be served by granting the relief requested. 5 14. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant shared legal custody and primary physical custody of the children. Respectfully submitted, By: rJJMM'~I~JJ. ~ JeJ;;~..r;hman, Esquire l\ttorneyI.J).#52784 27 South Arlene Street P.O. Box 6130 Harrisburg, Pl\ 17112 (717) 671-1200 Date: J I {D I O( 6 VERIFICATION I verify that the statements made in the foregoing Complaint in Custody 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. ~4904 relating to unsworn falsification to authorities. Date: /$~;r/// 4~~ _ MICHAEL R. ~E~fy 7 ~ ~ ~ "- t.~ ~ ~ c ........ w ..c::. -c It -,.. /- :~ ;-~ n S ,~ .. " =) r--J c~ 0 <:..1' .n <- r- - _4_ - ~ I'll ::D r- ..,.., rn <J (1~ :r::~.a :.1..: U) ~ f~ ~. ..J ~....~ ,. .. MICHAEL R. MEYERS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 0 'i. ...)cJ./ -CIVIL TERM Defendant : CIVIL ACTION ~ LAW : IN CUSTODY HANNA YODER, STIPULATION FOR ENTRY OF CUSTODY ORDER AND NOW, this '6 day of -::;FWlU.~ ' 2005, comes the Plaintiff, MICHAEL R. MEYERS, (hereinafter referred to as Father) and the Defendant, HANNAH YODER, (hereinafter referred to as Mother) who stipulate as follows: 1. The parties are the parents of two minor children, namely Casey Ray Meyers, born October 31, 1999, and Alexandra Paige Meyers, born July 4, 2002. 2. Mother and Father shall have joint legal custody of Casey and Alexandra as such is defined by Pa. C.S.A. ~5301, ~~. This will permit Mother to have direct access to information concerning the children such as medical information or educational information. 3. Primary physical custody of Casey and Alexandra shall be with Father. 4. The parties agree that given the current circumstances, each parent should spend as much time with the children as possible. Accordingly, Mother shall have partial physical custody of Casey and Alexandra on a liberal basis at such times as agreed upon between the parties. 5. The parties agree that this Stipulation may be entered as a Court Order and waive their right to be present at the time it is submitted to the Court for signature. ~d.. ~v--I Jennifer L. Lehman, Esquire w~~ Witness ~~!J}-- COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~M.~le....~ J :SS. ~ day of .Jc:.".........r, the undersigned officer, personally appeared MICHAEL R. MEYER, known to me (or On the ,2005, before me, a Notary Public, satisfactorily proven) to be the person whose name is subscribed to the foregoing and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereun t my hand and official seal. Notaria1 Seal Joseph L ~~UbliC SlIwr Spring lWp.. d County My Commission Exp1res June 18. 2005 Meml!ler. Pennsylvflnia Association of Notaries COMMONWEALTH OF PENNSYL ANIA COUNTY OF CJr-'-~&4('\c::1 :SS. On the ~ day of J a.l\v~.,r'i , 2005, before me, a Notary Public, the undersigned officer, personally appeared HANNAH YODER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunt y hand and official seal. Notarial Seal Joseph L. Grove, Notary PublIc SillIer Spring Twp., Cumberland COUntY lAy Commission Expires June 18, 2005 Member, PennsylVania AsSOCiation otNotaries -r: r+~ !~, .. 6\~~,. ../ .- r:;r:; "- ~~_:: z :2 (") ~ -c" ~ _ . ~ ~ " ~ <.:.~ = r;n <- ~ z o ,.1 -I :r: -,., rnh; -=Be; (~)<.~) W2f,\~ :::':1 )13 :< ;:->> ::r- '-:9 .r;- w iJAN 1 2 ?D~55 tJ. \'-" v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 0 ';!. )..2-/ ~ T;.- MICHAEL R. MEYERS, Plaintiff Defendant : CIVIL ACTION - LAW : IN CUSTODY HANNA YODER, ORDER OF COURT AND NOW, this l't' day of </-'/ , 2005, upon presentation of the Stipulation for Entry of Custody Order dated January 8, 2005, which was executed by the parties and attached hereto, it is hereby Ordered and Decreed as follows: 1. MICHAEL R. MEYERS, hereinafter referred to as Father, and HANNA YODER, hereinafter referred to as Mother, shall have joint legal custody of Casey Ray Meyers, born October 31,1999, and Alexandra Paige Meyers, born July 4, 2002. 2. Primary physical custody of Casey and Alexandra shall be with Father. 3. Mother shall continue to have liberal contact with. the children and shall have partial physical custody of the children at such times as agreed upon between the parties. BY THE COURT: <...0- /1 J. / rrr , v, ~ ZS :11 'I I"'~ 1'1 ':"0" _ J ~~~ '0 f.,1 ~. ..... ;01 ::(C\ MICHAEL R. MEYERS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 05-221 CIVIL TERM Defendant : CIVIL ACTION - LAW : IN CUSTODY HANNAH YODER, ACCEPTANCE OF SERVICE I hereby accept service of the following documents: 1. Custody Complaint filed on January 12, 2005; and 2. A copy of the Order of Court dated January 14, 2005. Date: \ -' ;('1 - Q 1? By:k~ ().fif I HANNAH YO ER ~'" c~\ ~') o~ HANNAH YODER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA Ys. No. 05- 221 C1VlL TERM MICHAEL R. MEYERS, Defendant IN CUSTODY COMPLAINT FOR MODIFICATION OF CUSTODY AND REQUEST FOR EXPEDITED CONCILIATION Petitioner, HANNAH YODER, by and through his counsel, Grace E. D'Alo of MidPenn Legal Services, states the following: 1. Petitioner, hereinafter referred to as the Mother, resides at 924 Bonny Lane, Mechanicsburg, Cumberland County, P A, 17055. 2. The above Defendant, MICHAEL R. MYERS, currently resides at 141 Peach Lane, Carlisle, PA 17013. 3. Mother and Defendant are the natural parents of: Casey Ray Meyers born October 31, 1999, and Alexandra Paige Meyers, born on July 24,2002. 4. Mother and Defendant were never married. 5. A custody order concerning the above-named children was entered at the docket number in this caption based on a stipulation signed by Mother and Defendant on January 15,2005. 6. Mother was living with the Defendant and their two children, Casey and Alexandra, at 141 Peach Lane, Carlisle, P A, at the time she signed the stipulation. 7. Mother was not represented in the custody matter. 8. Mother never met or talked with Defendant's counsel nor was she advised by Defendant's counsel that she should secure counsel because her interests were in conflict with the interests of Defendant. 9. Since the date of the last custody order, January 15,2005, the children have lived continuously with both parents at 141 Peach Lane, Carlisle, up until January 4, 2006, when Mother left the residence due to domestic violence. 10. There is a history of domestic violence between the parties and repeated attempts by Mother to extricate herself from this abusive relationship that posed a danger to herself and the children and also contributed to Mother's becoming clinically depressed as described more fully below. 11. Mother left the relationship in August of 2000 because of domestic violence. At that time she was living in Mechanicsburg, Pennsylvania. During this time Mother lived in Dillsburg with her son Casey, in DilIsburg, Pennsylvania. 12. In September of 2001, Mother reconciled with the Defendant and together with Casey, they found another apartment in Dillsburg, Pennsylvania. 13. Mother left the relationship in December of 200 I because of domestic violence: a. Mother filed a PF A in York County pro se and withdrew it when she reconciled with the Defendant. b. During the time Mother was separated from Defendant, the parties' only child Casey stayed with the Mother. c. Mother lived in a domestic violence shelter for approximately one month before reconciling with the Defendant and moving back to 1 09 Twin Hills Rqad, Apt, #22, Dillsburg, P A, in January, 2002. 14. Between January 2002 and May 2004. Mother left the marital home for one month and lived with her parents, Sharon and Jack Yoder, and her children, Cassie and Alexandra, in Lititz, P A. This separation was also due to domestic violence and lasted for approximately one month. 15. In May 2004, Mother again left the relationship because of domestic violence and moved, with Casey and Alexandra, to 610 Lititz Manor Drive, Lititz, PA. During this period, Mother had both children in her care and custody. 16. In December, 2004, Mother was hospitalized for depression. Prior to her hospitalization, and knowing that she could not care for the children while being treated, Mother asked the Defendant to assume custody 17. When Mother was released from the hospital, she returned to the Lititz Manor address above. 18. Mother reconciled with the Defendant and reswne living with him and the children in mid January 2005. 19. While living at the Peach Lane address in Carlisle, Mother was subject to continued and ongoing threats to her life and to the lives of her children. 20. As a result of Defendant's abuse, Mother moved out of the residence at Peach. 21. The Defendant is not acting in the child's best interest for reasons including, but not limited to, the following: a. Defendant failed to secure medical coverage for the children in a timely manner due to his desire not to reveal that Mother has been living with him; b. The Defendant has threatened to kill and dismember the children; c. The Defendant has abused Mother in the children's presence; d. The Defendant has not been an active part ofchildren's education development; 22. Mother is the parent who can best provide for the child for reasons including, but not limited to, the following: a. The Mother is presently able to provide for the child by giving the child a nurturing and stable home environment and providing for his emotional, physical, medical and educational needs; b. Mother has been the consistent and primary caregiver in her children's lives; c. Mother has been primarily responsible for the children's medical needs; d. Mother has been the parent who primarily interacts with the children's teachers and daycare providers; e. Mother can best facilitate and maintain any contact between the child and the Defendant. 23. Mother requests that the Court grant primary physical and legal custody of the child to him and grant the defendant periods of partial custody and visitation with the child. WHEREFORE, Petitioner respectfully requests the following: a. Mother be granted primary custody; b. Defendant be granted periods of partial custody and visitation; c. The conciliation in this matter be expedited in light of coercive and uninformed consent of Mother to the previous custody stipulation; ". d. Any other relief this court deems just and proper. ~tfu:~Y SUb;itted, L [,I " ( ctOe qr e E. D'Alo At! . lD: #26146 Attorney for Petitioner 401 E. Louther Street Carlisle, PA 17013 VERIFICATION The above-named plaintiff, HANNAH YODER, verifies that the statements made in the attached complaint for Custody and Request for Expedited conciliation. Plaintiff understands that false statements herein are made subject to the penalties of 18 pa. c.s. ~4904, relating to unsworn falsification to authorities. Date: l-/'';{ - ()( c Lr--.. HANNAH YODER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA vs. No. 05- 221 CIVIL TERM MICHAEL R. MEYERS, Defendant IN CUSTODY AFFIDAVIT OF SERVICE BY MAIL I, Grace D' Alo, do hereby swear that I served Jennifer Lehman, counsel for the defendant, with a Complaint in Custody and Request for Expedited Conciliation on January 13, 2006, by first class, prepaid mail at the following address: Jennifer Lehman 27 South Arlene Street P.O. Box 6130 Harrisburg, PA 17112 1, Grace E. D' Alo, verify that the statements made in this Affidavit of Service are true and correct. 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. !j Date: /C(/y\ I~. It "X:;h / Signat(/ " I , \ ~.<) l) -1'1 :.~ CJ f'-":" -J _......_~._---._----'"_.,>_. D HANNAH YODER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYL V ANlA vs. No.OS- 221 ClVtL TERM MICHAEL R. MEYERS, Defendant IN CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, HANNAH YODER, Plaintiff, to proceed in forma pauperis. I, Grace E. D' Alo, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. (/': ~< rr e D'Alo AJt JD #26146 Jessica Diamondstone Geoffrey Biringer Attorneys for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ~ I !..-.." ;-,,) ""I - , -, c_ c.,) HANNAH YODER PLAINTIFF IN THE COURT OF COMMON PLEP S OF CUMBERLAND COUNTY, PENNSY VANIA v. 05-221 CIVIL ACTION LAW MICHAEL R. MEYERS IN CUSTODY DEFFNDANT ORnER OF COURT AND NOW, Friday, January 20, 2006 , upon consideration of the att ched Complaint, it is herehy directed that pat1ies and their respective eounscl appear before Hnbert x., Gilroy, sq. , the conciliator, at 4th Floor, Cumberland (;onnty Conrt.J1~s...,_<::a-"lisle on Thursday, Febrnary Q9, 20~6 at 9:30 AM for a Pre-Hearing Custody Conference. At such conferenee, an effort will be made to resolve tl e issues in dispute; or if this cannot bc accomplished, to define and narrow the issucs to be heard by the court. and to ntcr into a temporary ordcr. All childrcn agcfive or oldcr may also bc prcsent at the confcrcncc. Failure to appcar at thc confcrence may provide grounds for entry of a temporary or penn anent 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 hI aring. FOR THE COURT, By:~_ Hubert X Gilrox.psq. 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 ac ommodations available to disabled individuals having business before the co1l11, 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. IF' OU DO NOT HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE ( FFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (7 I 7) 249-3166 ~ ".y ,,;;?;J'Vf'1 tlc6; '. . d:.~' pl.. r?nVM r F 'fl"' // /?JT7 1"",1,1 .."1 . '!l.7 /" '~"7 '7 ~dkl.f'l )\ / I .T ,. ._ . . (,I. i r)~'. ."r' . ;'_ .,.' ~: 'i .-! "w 0('-' I tJCl tlf'J '7V or ( - _._-_._--"----_.--.""--_.__..~....- -, r~[CE::'J[O_"_ :~r[l :t:~!G )/'( HANNAH YODER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-221 CIVIL ACTION - LAW MICHAEL R. MEYERS, Defendant IN CUSTODY COURT ORDER AND NOW, this I S-' day of February, 2006, upon consideration of the attached Custody Conciliation Report, this Court's prior Order of January 14, 2005 is vacated and replaced with the following Order: 1. The Mother, Hannah Yoder, and the Father, Michael R. Meyers, shall enjoy shared legal custody of Casey Ray Meyers, born October 31, 1999, and Alexandra Paige Meyers, born on July 4, 2002. 2. The Father shall enjoy primary physical custody of the minor children. 3. The Mother shall enjoy periods of temporary physical custody of the minor children as follows: A. On alternating weekends, the weekends to be arranged between the parties subject to their respective work schedules; B. On one evening per week to be arranged between the parties; and C. At such other times as the parties agree. 4. In the event either party becomes dissatisfied with this Order, that party may petition the Court to have the case again scheduled with the Custody Conciliator for a conference. BY THE COURT, Cc: Grace D' Alo, Esquire Jennifer Lehman, Esquire .//i- A. Hess, Judge '{'fU'" ",~'.<..L...( )./).0[. C~L ,'!' ".~ ., I d.:l . ~ n,.'.' t i '-,f-. , , ",i -! .... ,. "-.~ - . ... HANNAH YODER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 05-221 CIVIL ACTION - LAW MICHAEL R. MEYERS, Defendant IN CUSTODY Prior Judge: The Honorable Kevin A. Hess CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Casey Ray Meyers, born October 31, 1999 Alexandra Paige Meyers, born on July 4, 2002 2. A Conciliation Conference was held on February 9, 2006 with the following individuals in attendance: The Mother, Hannah Yoder, with her counsel, Grace D' Alo, Esquire, and The Father, Michael R. Meyers, with his counsel, Jennifer Lehman, Esquire 3. The parties agreed to the entry of an Order in the form as attached. Date: :</[>/0& W-fJ Hubert X. Gilroy, Esq Custody Conciliator a r'-E nr4 p IL ~F lan Susan E.Good,Esquire 1"Fri��1:�(3�� r �t f DALEY ZUCKER gg 't R f MEILTON&MINER, LLC 2013 JUL 18 635 North 12`h Street,Suite 101 44 It : 2 Lemoyne,PA 17043 CUMBERLAND C%t (717)724-9821 PENNSYLVANIA � ; s d dzmmlawxom IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA MICHAEL R. MEYERS, Plaintiff CIVIL ACTION-LAW V. No. 05-221 CIVIL TERM HANNA YODER, IN CUSTODY Defendant PETITION TO MODIFY CUSTODY 1. The Plaintiff, Michael R. Meyers (hereinafter "Father"), is an adult individual currently residing at 141 Peach Lane, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, Hanna Yoder (hereinafter"Mother"), is an adult individual currently residing at 201 Landis Valley Road, Apt. 7, Lititz, Lancaster County, Pennsylvania 17543. 3. The parties are the natural parents of two (2) minor children, namely Casey Ray Meyers, age 13, born October 31, 1999 and Alexandra Paige Meyers, age 11, born July 4, 2002. 4. Pursuant to an Order of Court adopting a Stipulation for Entry of a Court Order (hereinafter "Order") entered on January 14, 2005, the parties share legal custody, Father has primary physical custody and Mother has partial physical custody as agreed upon by the parties. A copy of the Order is attached hereto as Exhibit "A" and k., incorporated herein by reference. ���`�� 5. The Order was entered when the parties were not living together; however, approximately a year after the Order was entered,the parties resumed living together until approximately June, 2010. 6. When Mother moved out on or about June, 2010, the children lived primarily with Mother in Lancaster, Pennsylvania while she attended nursing school. Father had physical custody every weekend. 7. When Mother finished nursing school, Father's custodial periods were reduced to alternate weekends when Mother worked. 8. Approximately two to three nights a week Mother works the evening shift, which means that she was not home when the children got home from school and they would be alone until her shift ended at 11:00 p.m.. During the summer, the children are alone until Mother's night shift ends. 8. Due to Mother's night shift, Father would drive to Lancaster after his job ended at approximately 5:00 p.m. to ensure the children completed their homework and were not left alone until 11:00 p.m. 9. The parties' son, Casey, has been diagnosed with Attention Deficit Hyperactivity Disorder and requires additional assistance with homework, which Father believes he does not get while in Mother's custody. 9. Casey, has expressed a desire to live with Father and since July 7, 2013, Casey has been living with Father. 10. Father believes and therefore avers that it is in Casey's best interest to primarily reside with Father. 10. Father believes and therefore avers that it is in Alexandra's best interest to have increased physical custody time with Father. 12. Father is seeking to modify the order such that he would have primary physical custody of Casey and shared physical custody of Alexandria. WHEREFORE, Plaintiff respectfully requests this Honorable Court to grant Plaintiffs Petition to Modify Custody and enter an Order granting Father primary physical custody of the parties' son, Casey, and shared physical custody with the parties' daughter, Alexandria. Respectfully submitted, DALEY ZUCKER MEILTON & GINGRICH, LLC Date: -7 1- /3 By; usan E. Good, Esquire Attorney ID # 93295 635 N. 12th Street, Suite 101 Lemoyne, PA 17043 (717) 724-9821 Attorneys for Plaintiff VERIFICATION I, Michael R. Meyers, verify that the statements made in this pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. 17 3 Date Michael . Meyers EXHIBIT "A" " JAN 12 2005� MICHAEL R. MEYERS, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA .v. : NO. LAS'. HANNA YODER, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW,this day of , 2005, upon presentation of the Stipulation for Entry of Custody Order dated January 8,2005,which was executed by the parties and attached hereto, it is hereby Ordered and Decreed as follows: 1. MICHAEL R. MEYERS, hereinafter referred to as Father, and HANNA YODER, hereinafter referred to as Mother,shall have joint legal custody of Casey Ray Meyers, born October 31, 1999, and Alexandra Paige Meyers, born July 4, 2002. 2. Primary physical custody of Casey and Alexandra shall be with Father. 3. Mother shall continue to have liberal contact with the children and shall have partial physical custody of the children at such times as agreed upon between the parties. BY THE COURT: J. Ft Ya`ltt�i7(� i�Y�ir[G7'fs�l 1 tF4eG�.5..c�'.erG�� 1:G7�G� f I�J'l��F icN�O 7 J MICHAEL R. MEYERS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. OS-a-21 -CIVIL TERM CIVIL ACTION- LAW c o HANNA YRDER, _ �., Defendant IN CUSTODY L -� r i r STIPULATION FOR ENTRY OF CUSTODY ORDER � T t� -i- u`_... : L AND NOW, this _day of , 2005, comes the Plaaiff,={ MICHAEL R. MEYERS, (hereinafter referred to as Father) and the Defendant, HANNAH YODER, (hereinafter referred to as Mother) who stipulate as follows: 1. The parties are the parents of two minor children,namely Casey Ray Meyers, born October 31, 1999, and Alexandra Paige Meyers, born July 4, 2002. 2. Mother and Father shall have joint legal custody of Casey and Alexandra as such is defined by Pa. C.S.A. §5301, et seq. This will permit Mother to have direct access to information concerning the children such as medical information or educational information. 3. Primary physical custody of Casey and Alexandra shall be with Father. 4. The parties agree that given the current circumstances, each parent should spend as much time with the children as possible. Accordingly,Mother shall have partial physical custody of Casey and Alexandra on a liberal basis at such times as agreed upon between the parties. 5. The parties agree that this Stipulation may be entered as a Court Order and waive o their right to be present at the time it is submitted to the Court for signature. Jennifer LL'Lehman, Esquire MICHAEL R. M YE �i Witness AH YOUti COMMONWEALTH OF PENNSYLVANIA I :SS. COUNTY OF On the I-Lday of JG n -.{ , 2005, before me, a Notary Public, the undersigned officer, personally appeared MICHAEL R. MEYER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereun et my hand and official seal. Notarial Seal Joseph L Grave,Notary Public Silver Spring Twp.,Oberland County My Commission Expires Juno 18, 2005 ^ t Member,Pennsvivaria Association otNotaries otary P b COMMONWEALTH OF PENNSYL ANIA COUNTY OF C Je-� n�I :SS. On the day of 1 r-�( , 2005, before me, a Notary Public, the undersigned officer, personally appeared HANNAH YODER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I qN y hand and official seal. Notarial Seal Joseph L. Grove, Notary Public S+&w Spring Twp.,Cumberland County my commission Expires June 18,2005 Pu Member,Pennsylvania Association of Notaries CERTIFICATE OF SERVICE I, Pamela S. Myers, Paralegal, hereby certify that on this day of July, 2013, a true and correct copy of the foregoing Petition to Modify Custody was served on Defendant by mailing same addressed as follows: Ms. Hanna Yoder 201 Landis Valley Road Apt. 7 Lititz,Pennsylvania 17543 Pamela S. Myers, Paralegal MICHAEL R. MEYERS, i IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA s. V. : No. 05-221 CIVIL TERM Q HANNA YODER, : CIVIL ACTION-LAW r,nr' —n Defendant : IN CUSTODY cis 'C") Gam°D AFFIDAVIT OF SERVICE ° COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF CUMBERLAND AND NOW, this 23`d day of July, 2013, personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Pamela S. Myers, Paralegal with Daley Zucker Meilton& Miner, LLC, who being duly sworn according to law, deposes and says that on July 18, 2013, she mailed a certified copy of a Petition to Modify Custody to Hanna Yoder, 201 Landis Valley Road, Apt. 7, Lititz, Pennsylvania 17543, by certified mail no. 7008 2810 0001 6235 3062, return receipt requested, restricted delivery and the same was received on July 19, 2013, by her, as indicated by the return receipt card which is attached hereto. Pamela S.Myers Sworn to and subscrihed before me this c day of "�� , 2013. M co MONVVEALTH of EL . MVANU► NOTARIAL SEAL AMY-EMNG, ary Pubic of (� irot�rno ,Cd Gounry_ Notary ublic 11 M4 (SEAL) ' Postal CERTIFIED RECEIPT ru (Domesti M M � � e C� FF1- 1AL. � � � M i rtJ Postage $ Certified Feed O Return Receipt Fee ostm Pa Q r(Endorsement Required) . Here RasMctad Delivery Fee.. E3 (Endorsement Required) r-3 . ep Total Postage 8 Fees rU sent To 9, ..4..Odl. CD Street,Apt.No.; 1,.. --,• ..... .......f s:•:.;... ..::.sy.:... '� tE3 or PO Box No ta2Ul ..���.��/. ' siaie;ziF•�•a�L i�jw�`-� ..��3 I P 3 Form 3800,August 2006 See Reverse forInstioctionr i • i ! ON • Complete Items 1,2,and 3.Also complete A SI re item 4 If Restricted Delivery is desired. ge " • Print your name and address on the reverse X O Addressee so that we can Tatum the card to you. B Received by{Printed Name) G'}Da, f Delivery C • Attach this card#o the back of the mailpiece, 6" t�1 or on the front If space permits. i D. Is delivery address diBerent from kern 14 0 Yes i. Article Addressed to: -tf YES,enter delivery address below: 0 No 3. Service Type PA 175-Y,3 Pcertiffed Mail 13 Express Mail f I / 0 Registered Weturn Receipt for Merchandise ,{ ❑Insured Mail 13 C.O.D. y - 4. Restricted Delivery?(Extra Fee) ` 4 Eyes f 2. Article Numtrer 7 0 0 8 e2 810 '-0901 '6 2 3 5 3062 MarWer from seMlce label) -1_11 ,k r.._ r j , Y PS Form 3811,February 2004 Domestic Return Receipt 102595.02-M-1540 + w. MICHAEL R.MEYERS IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2005-221 CIVIL ACTION LAW CQ r 1"o c HANNA YODER l IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday,July 23,2013 upon consideration of the attached Complaint, it is hereby directed that pat-ties and their respective counsel appear before Hubert X.Gilroy,Esq. the conciliator, at 4th Floor,Cumberland County Courthouse,Carlisle on Friday,August 30,2013 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. 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 Gikov,Esqj, le 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. 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 1 A 10�lej' Tin 32 South Bedford Street TO Carlisle, Pennsylvania 1.7013 Telephone (717)249-3166 a� MICHAEL R. MEYERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v 2005-221 CIVIL ACTION - LAW HANNA YODER, ; Defendant IN CUSTODY r PRIOR JUDGE: The Honorable Albert H. Masland r ZIC COURT ORDERy =,<'- i u..E AND NOW,this day of August, 2013,upon consideration of the attached Custody,; Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Court Room No. 1 of the Cumberland County Courthouse on the 16`h day of August, 2013 at 1:00 p.m. At this hearing, the father shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a detailed memorandum setting forth the history in this case,each party's position on the current custodial situation,a summary of the testimony that would be offered by each party at the hearing and a list of any exhibits the parties would be submit to the Court. This memorandum shall be filed with opposing counsel and the Court in Chambers on or before Friday, August 13, 2013. 2. Pending further Order of this Court, the existing custodial situation shall remain in place. No party shall be permitted to relocate the residence of the child where said relocation will significantly impair the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation or the court approves the proposed relocation. Any party proposing to relocate MUST comply with 23 Pa. C.S. § 5337. B C , 4!0-�o Albert H. Masland, Judge cc: �(san E. Good, Esquire ,/Andy Norfleet, Esquir • (W MICHAEL R. MEYERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v 2005-221 CIVIL ACTION - LAW HANNA YODER, Defendant IN CUSTODY PRIOR JUDGE: The Honorable Albert H. Masland CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Casey Ray Meyers,born October 31, 1999, and Alexandra Paige Meyers,born July 4, 2002. 2. A Conciliation Conference was held on August 7,2013,with the following individuals in attendance: The father, Michael R. Meyers, with his counsel, Susan E. Good, Esquire, and the mother, Hanna Yoder,with her counsel, Andy Norfleet, Esquire. 3. This is a situation where there was an order from 2005 giving the father primary custody. However,the parties then reconciled and separated again after which mother had primary custody for a long period of time including the past two years. The older child Casey is now living with the father as he has suggested he would prefer to live with the father. Mother is not in agreement with that change as she believes it is in the best interest for both children to remain with her in Lancaster. A hearing is necessary, and the Conciliator met with Judge Masland and arranged for a hearing scheduled in accordance with the attached Order. 4. The Custody Conciliator recommends the entry of an Order in the form as attached. Date: August / , 2013 (�� Hubert X. Gilro , Esquire Custody Con ' iator i MICHAEL R. MEYERS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYL AN�Ijk CZ V. : No. 05-221 CIVIL TERM CD -ri:f?i rte• ;-,_._: HANNAH YODER, : CIVIL ACTION-LAW Defendant : IN CUSTODY - y' ZK STIPULATION AND AGREEMENT FOR CUSTODY THIS STIPULATION is entered into this L�` Cday of !/ 2013; by and between Michael R. Meyers (hereinafter referred to as "Father") and Hannah Yoder (hereinafter referred to as "Mother"). NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, the parties are the natural parents of two minor children, namely, Casey Ray Meyers, whose date of birth is October 31, 1999 (hereinafter referred to as "Casey") and Alexandra Paige Meyers, whose date of birth is July 4, 2002 (hereinafter referred to "Alexandra"); and WHEREAS, the parties wish to work together to make decisions that they believe are in the best interest of Casey and Alexandria; and WHEREAS, the parties have reached an agreement with regard to legal and physical custody of Casey and Alexandra and they wish to formalize and memorialize the terms of their agreement; and WHEREAS, the parties request that the following Custody Stipulation and Agreement be entered as a Court Order. NOW THEREFORE, the parties agree as follows: 1. Legal Custody: The parties agree to share legal custody of Casey and Alexandra. Major decisions concerning the children's health, welfare, education and religion shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the children's best interest. Each party agrees not to impair the other party's right to shared legal custody of the children. Each party agrees not to attempt to alienate the affections of the children from the other party. Each party shall notify the other of any activity or circumstances concerning the children that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the party then having physical custody. With regard to any emergency decisions which must be made, the party having physical custody of the children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that party shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent pursuant to 23 Pa.C.S. §5336. To the extent necessary, either party will, upon presentation thereof, execute authorizations necessary to allow the other parent to obtain information directly from schools, medical providers or treatment institutions. 2. Physical Custody: Mother shall have primary physical custody of Casey and Alexandra. Father shall have periods of partial physical custody as follows: A. Beginning on August 16, 2013 and during the school year, Father shall have three consecutive weekends out of four from Friday at 6:30 p.m. until Sunday at 8:00 p.m. On the first and third of Father's three weekends out of four, Father shall have custody of both Casey and Alexandra. On the second weekend of Father's three weekends out of four, Father shall have custody of Casey. B. Father shall have extended periods of physical custody, which the parties shall agree upon in advance, during any breaks from school. C. During the summer, physical custody shall alternate on a week on/week off basis with the parents exchanging physical custody on Sunday afternoons, or at such other times agreed upon by the parties. 3. Summer Vacation: Either parent may exercise their summer vacation(s) with Casey and Alexandra during their regular custodial week. If necessary,,the parties agree to reasonably accommodate the other parent's request for adjustment to the weekly custodial schedule to allow for the vacation period. The parents agree to provide advanced written notice to the other parent of their intended vacation. Both parents shall provide the other parent of the address and telephone number where the children will be during any vacation. Prior to the vacation, the parent taking vacation shall provide the other parent with all relevant travel information, including, but not limited to, airline and flight.information, hotel information and itinerary. The responsibility is on the parent having custody to provide reasonable notice that the children have arrived safely at the vacation destination and have returned safely. 4. Holiday Schedule: Physical custody of Casey and Alexandra on all holidays shall be shared or alternated as the parties agree. ar 5. Transportation: Unless otherwise provided herein or agreed to by the parties, the parent ending his or her custodial period shall be responsible for providing transportation of the children to the other parent. 6. Controlled Substances/Alcohol: During any period of custody the parties shall not possess or use any controlled substance, nor shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or houseguests comply with this prohibition. 7. Communication: Each parent shall make a commitment to communicate directly with the other parent regarding the children without using the children as intermediaries. Each :parent shall communicate in a positive manner. Neither parent shall use profanity or hostile language in addressing the other parent or the children nor shall they permit anyone else in their household to do so. Each parent shall refrain from encouraging the children to provide reports about the other parent. Both parents shall refrain from making derogatory comments about the other parent in the presence of the children and, to the extent possible, shall prevent third parties from making such comments in the presence of the children. Each parent shall speak respectfully of the other whether it is believed the other reciprocates or not. Neither parent shall do or say anything that may estrange the children from the other parent, or injure the opinion of the children as to the other parent or hamper the free and natural development of the children's love and respect for the other parent. Upon request, parents shall provide one another with a phone number and address where the children may be contacted at all times. This principle also applies to situations such as vacations and overnights with friends. Should either parent have the children spend an overnight at a place other than their primary residence, the other parent shall be given the address and phone number. 8. Telephone Contact: Both parents shall permit reasonable telephone contact between the children and the non-custodial parent regardless of whether the other parent initiates the call or the children request to speak to the other parent. 9. Extended Family: The parents shall permit and support the children's access to all family relationships. Both parents shall reasonably accommodate special family events such as weddings, family reunions, family gatherings, funerals, graduations, etc., with the regularly scheduled custody arrangement resuming immediately thereafter. Each parent shall have the option of proposing time or date variations to the other parent when special recreational options or other unexpected opportunities arise. 10. Counseling: The parties agree that they will endeavor to co-parent with one another in an effort to foster a loving, meaningful relationship between the children and each parent. The parties agree that the parents will attend co-parenting counseling, the children will attend individual counseling and, if necessary, the family will attend family counseling with a mutually agreed upon counselor. The family shall continue all counseling until the counselor recommends that the counseling end or until the parties mutually agree to end the counseling. Until a support agreement or order is entered proportioning responsibility for unreimbursed medical expenses,the parties agree to share equally the costs of any co-pay for this counseling. 11. Relocation: No party shall relocate with Casey and Alexan dra if such relocation will significantly impair the ability of the non-relocating party to exercise his or her custodial rights unless (a) every person who has custodial rights to the children consents to the proposed relocation or (b) the court approves the proposed relocation. The party seeking relocation must , follow the procedures required by 23 Pa.C.S. §5337 as set forth in Exhibit "A" attached to this Stipulation and Order. 12. Modification: The parents may, by mutual agreement verbally or in written or electronic communication, modify or alter the schedule set forth in this Order. Any mutually agreed upon modification of the terms of this Order shall not affect or diminish the enforceability of the terms of this Order. Any permanent changes to this Order shall be made in writing, executed by the parties and entered as an Order of Court. 13. Order: The parents agree that the terms of this stipulation shall be entered as an Order of Court. NOW WHEREFORE, the parties hereto, intending to be legally bound, hereby set their hands and seals on the day and year first written above. Witness Michael R. eyers Witn s annah Yoder MICHAEL R. MEYERS, : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA PLAINTIFF V. :No. 05-221 CIVIL TERM ; . C x , HANNAH YODER, : CIVIL ACTION—LAW c-) IN.CUSTODY DEFENDANT ail. th CP ORDER . �m AND NOW,this _day of August, 2013,upon consideration of the foregoing Stipulation And Agreement For Custody, it is hereby Ordered and Decreed that the same shall be adopted as the Final Order of Court. BY THE COURT: The Honorable Albert H. Masland, Judge D' tribution: ' drew W.Norfleet,Esquire, 1300 Market Street, Suite 202B, Lemoyne, PA 17043 �san E. Good, Esquire, 625 N. 12t' street, suite 101, Lemoyne,Pa 17043 Court Administration ha� /;J 4' lv_' CS tz nj I R Susan E. Good, Esquire lit P c. Daley Zucker Meilton&Miner,LLC S � Q {�TA 635 N. 12'h Street, Suite 101 tp —9 P Lemoyne,PA 17043 cu " - , �? sgood @dzmmlaw.com PEWS YLVANIA �Y i MICHAEL R. ME Y ERS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :No. 05-221 CIVIL TERM HANNAH YODER, : CIVIL ACTION - LAW Defendant : IN CUSTODY JUDGE ASSIGNED: Albert H. Masland i i i i PETITION TO WITHDRAW AS COUNSEL i AND NOW comes Susan E. Good, Esquire, for the law firm of Daley Zucker Meilton & Miner, LLC and hereby avers the following: i 1. Plaintiff/Respondent, Michael R. Meyers, currently resides at 141 Peach Lane, i Carlisle, Cumberl�nd County, Pennsylvania 17013. i 2. Petitioner began performing legal services on behalf of Plaintiff/Respondent in i June, 2013. I i 3. A Bearing in the above custody matter was scheduled for August 16, 2013 before I the Honorable Albert H. Masland; however, the parties entered into a Custody Stipulation signed by Plaintiff of August 15, 2013 and by Defendant on August 15, 2013. The Custody Stipulation I i was submitted to the Court on August 16, 2013 by counsel for Defendant. I 4. On August 14, 2013, after signing the Custody Stipulation, Plaintiff/Respondent e seeking other representation in the above custody matter. advised Petitioner that he would b s g p y 5. For.this reason, Petitioner desires to sever the representation relationship of Susan E. Good, Esquire and Daley Zucker Meilton& Miner, LLC with Plaintiff. 6. Petitioner spoke with counsel for the Defendant via telephone on August 16, 2013. Counsel for.Defendant does not object to the relief requested by Petitioner. WHEREFORE, Petitioner respectfully requests that this Honorable Court grant permission to Susan E. Good, Esquire, and the law firm of Daley Zucker Meilton & Miner, LLC to withdraw as counsel for Plaintiff, Michael R. Meyers. Respectfully Submitted, DALEY ZUCKER MEILTON & MINER, LLC Date: 4-4-11a By: Susan E. Good, Esquire Attorney I.D. #93295 635 N. 12th Street, Suite 101 Lemoyne, PA 17043 (717) 724-9821 sgood @dzmmlaw.com Petitioner CERTIFICATE OF SERVICE I, Gloria M. Rine, Paralegal to Susan E. Good, Esquire, hereby certify that on this day of September, 2013, a true and correct copy of the foregoing document was served on Plaintiff and counsel for Defendant, by mailing same by first class mail, addressed as follows: Andrew W.Norfleet 1300 Market Street, Suite 202B Lemoyne, PA 17043 (counsel for Defendant) Michael R. Meyers 141 Peach Lane Carlisle, PA 17013 (Plaintiff Gloria M. Rine i MICHAEL R. MEYERS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA 4 ' V. : No. 05-221 CIVIL TERM HANNAH YODER, : CIVIL ACTION- LAW Defendant : IN CUSTODY JUDGE ASSIGNED: Albert H. Masland RULE TO SHOW CAUSE AND NOW, this �,r� ay of d kel , 2013, upon consideration of the Petition to Withdraw as Counsel, a Rule is issued upon Plaintiff, Michael R. Meyers, and Defendant, Hannah Yoder, to show cause why Susan E. Good; Esquire and Daley Zucker Meilton &Miner,LLC, should not be granted leave to withdraw as counsel for Plaintiff in this case. RULE RETURNABLE DAYS FROM THE DATE OF SERVICE. Service shall be accomplished by first class mail to Plaintiff and Defendant's counsel. BY THE COURT: DISTRIBUTION: -a=$ C/3 - �:� Susan E. Good,Esquire, 635 N. 12 cn Street, Suite 101,Lemoyne, PA 17043 (Petitioner) cnr— a Andrew W.Norfleet, 1300 Market Street, Suite 202B, Lemoyne, PA 17043 (counsel fq,� cvt D ndant) -r ichael R. Meyers, 141 Peach Lane, Carlisle, PA 17013 (Plaintiff} a �. at ES / 'C`mil 4 CO Susan E.Good,Esquire ;(r 1 F' , ?Cl o (; , Daley Zucker Meilton&Miner, LLC 635 N. 12th Street,Suite 101 :if 3 OCT -;.1, Ali 8: 20 Lemoyne,PA 17043 (717)724-9821 rUMBE;RL'A D COUNTY sgood @dzmmlaw.com PENNSYLVANIA MICHAEL R. MEYERS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 05-221 CIVIL TERM HANNAH YODER, : CIVIL ACTION - LAW Defendant : IN CUSTODY : JUDGE ASSIGNED: Albert H. Masland MOTION TO MAKE RULE ABSOLUTE This Motion of Susan E. Good, Esquire and Daley Zucker Meilton & Miner, LLC, respectfully represents: 1. Movants are Susan E. Good, Esquire and Daley Zucker Meilton& Miner, LLC, who are presently counsel of record for Plaintiff, Michael R. Meyers, in the above-captioned matter. 2. The Respondent is Michael R. Meyers, a party in the above-captioned matter. 3. On September 9, 2013, Movants filed a Petition to Withdraw as Counsel in the above-captioned matter, which Petition was served via U.S. Mail, Postage Pre-paid upon both Michael R. Meyers, and also upon counsel for Defendant, Hannah Yoder, by and through her attorney, Andrew W.Norfleet, Esquire. 4. The Honorable Albert H. Masland issued a Rule to Show Cause regarding said Petition on September 12, 2013, returnable fourteen(14)days after service. 5. Copies of said Rule were served via First Class U.S. Mail upon Respondent, Michael R. Meyers, and Defendant, Hannah Yoder, by and through her attorney, Andrew W. Norfleet, Esquire. 6. No response objecting to the Petition to Withdraw as Counsel has been received from either Respondent,Michael R. Meyers or Defendant, Hannah Yoder. 7. The allotted time frame within which Respondent or Defendant could respond has now elapsed. WHEREFORE, Movants, Susan E. Good, Esquire and Daley Zucker Meilton & Miner, LLC, respectfully request this Honorable Court make the Rule Absolute and thereby grant Movants leave to withdraw as Counsel for Respondent, Michael R. Meyers, in the above-captioned matter. Respectfully submitted, DALEY ZUCKER MEILTON & MINER, LLC Date:1013//3 By: Susan E. Good, Esquire Attorney I.D. #93295 635 N. 12th Street, Suite 101 Lemoyne, PA 17043 (717) 724-9821 sgood @dzmmlaw.com Petitioner VERIFICATION Upon my personal knowledge, information and belief, I, Susan E. Good, Esquire, do hereby verify that the facts averred and statements made in the foregoing Motion to Make Rule Absolute are true and correct. I understand that false statements or averments therein made will subject me to the criminal penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: lo///(3 Susan E. Good CERTIFICATE OF SERVICE AND NOW, this ' day of October, 2013, I, Susan M. Hudson, Paralegal for Daley Zucker Meilton & Miner, LLC, hereby certify that I have this day served a copy of the within document, by mailing same by first class mail, postage prepaid, addressed as follows: Andrew W. Norfleet 1300 Market Street, Suite 202B Lemoyne, PA 17043 (Counsel for Defendant) Michael R. Meyers 141 Peach Lane Carlisle, PA 17013 (Respondent) ) &bt2-10L39) °?:kidfv,oc. Susan M. Hudson MICHAEL R. MEYERS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 05-221 CIVIL TERM HANNAH YODER, : CIVIL ACTION- LAW Defendant : IN CUSTODY : JUDGE ASSIGNED: Albert H. Masland ORDER AND NOW, this $ day of OCA , 2013, upon consideration of the Petition to Withdraw as Counsel, it is hereby ORDERED and DECREED that Susan E. Good, Esquire, and Daley Zucker Meilton & Miner, LLC, are granted leave to withdraw as counsel of record for the Plaintiff, Michael R. Meyers, in the above-captioned matter. BY THE COURT: 10"I 1°- a I I .., r DISTRIBUTION: ✓ Susan E. Good,Esquire, 635 N. 12th Street, Suite 101,Lemoyne, PA 17043 (Petitioner) ./Andrew W.Norfleet, 1300 Market Street, Suite 202B, Lemoyne, PA 17043 (counsel for Defendant) Michael R. Meyers, 141 Peach Lane, Carlisle, PA 17013 (Plaintiff) • etr es fr,-- 1 rri Ofretta,,, rrl c"-) cnr- C