Loading...
HomeMy WebLinkAbout05-1362 ANDREWP. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA C-v:C, VtivL v. NO. OS - 13"'A CIVIL ACTION - LAW NICOLLE BROUGHER-SMITH, Defendant IN CUSTODY COMPLAINT FOR CUSTODY COUNT I 1. The Plaintiff is Andrew P. Smith, an adult individual, who resides at 2208 Logan Street, Camp Hill, Cumberland County, Pennsylvania 170 II. 2. The Defendant is Nicolle Brougher-Smith, an adult individual, who resides at 19 West Maplewood Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff seeks shared physical and legal custody of the following children: Name Present Residence Age Rylee N. Smith 19 W. Maplewood Avenue Mechanicsburg, P A 17055 21 months Kaylee E. Smith 19 W. Maplewood Avenue Mechanicsburg, P A 17055 4 months 4. The children were not born out of wedlock. 5. The children are presently in the custody of Defendant Nicolle Brougher-Smith at 19 W. Maplewood Avenue, Mechanicsburg, PA 17055. 6. During the past two years, the children have resided with the following persons at the following addresses: Custodians Andrew P. Smith Nicolle Brougher-Smith Addresses 19 W. Maplewood Avenue Mechanicsburg, P A 17055 Dates 6/2/03 - 1/30/05 Nicolle Brougher-Smith 19 W. Maplewood Avenue Mechanicsburg, P A 17055 1/30/05 - Present 7. The mother of the children is Nicolle Brougher-Smith who currently resides at 19 W. Maplewood Avenue, Mechanicsburg, PA 17055. The mother is married to the father Plaintiff Andrew P. Smith. 8. The father of the children is Andrew P. Smith, who currently resides at 2208 Logan Street, Camp Hill, P A 170 II. 9. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 10. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 11. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children and claims to have custody or visitation rights with respect to the children. 12. The best interest and welfare of the children will be served by granting the relief requested because: a) Plaintiff is better able to provide for, care for and love the children, b) Plaintiff can provide a loving and safe environment for the children, c) The children want to live with their father, and d) Defendant Mother is mentally unstable. 13. Each parent whose parental rights to the children have not been terminated and the person who has physical custody ofthe children have been named as Parties to this Action. WHEREFORE, Plaintiff Andrew P. Smith requests the Court to grant him shared custody ofthe children. COUNT II REOUEST FOR INTERIM VISIT A TION RIGHTS 14. Plaintiff incorporates by reference Paragraphs 1-13 of this Complaint as if said averments were fully set forth at length. 15. The parties were separated on January 30, 2005. 16. At the time of separation Defendant Nicolle Brougher-Smith retained physical possession of said children at the residence at 19 W. Maplewood Avenue, Mechanicsburg, P A 17055. 17. Since February 15, 2005 Defendant has denied Plaintiff any visitation with said children. 18. Plaintiff loves said children and desires interim visitation with said children from Friday at 9:00 A.M. to Sunday at 9:00 A.M. each week at his residence at 2208 Logan St., Camp Hill, PA 17011. 19. Plaintiff has excellent facilities for conducing visitation with said children at the .. . residence at 2208 Logan St., Camp Hill, PA 17011. WHEREFORE, Plaintiff Andrew P. Smith requests interim visitation with his two children from Friday at 9:00 A.M. to Sunday at 9:00 A.M. each week until the Custody Conciliation Conference in this case is held. March 15,2005 \~ \~,~ Peter B. Foster, Esquire Attorney for Plaintiff Pinskey & Foster 114 South Street Harrisburg, PA 17101 (717) 234-9321 . VERIFICATION I verify that the statements made in this Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 9 4904 relative to unsworn falsification to authorities. March 15.2005 M, Andrew P. Smith ~,--~ ~~ ~ .-' "'fJ ~~\:~~ -D - ;",\ ~> ~ - - .- VI \....J' - II 0- .Y-.'" i;'- ,"It ..- - ~ -J ... .' ~ - ,~" ", "' ....- r- (i) ~ v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O'5~I?h;) ANDREWP. SMITH, Plaintiff CIVIL ACTION - LAW NICOLLE BROUGHER-SMITH, Defendant IN CUSTODY PETITION FOR INTERIM VISITATION RIGHTS AND NOW, this 17th day of March, 2005, comes Petitioner Andrew P. Smith, by his attorney, Peter B. Foster, Esquire, and petitions for interim visitation rights for his two, minor children, and, in support thereof, avers as follows: I. On March 16, 2005, Petitioner filed a Custody Complaint in this case for shared physical and legal custody of his two, minor children, Rylee N. Smith and Kaylee E. Smith. A copy of said Complaint is attached a~ Exhibit "A." 2. The Parties were separated on January 30, 2005. 3. The Parties are the parents of Rylee N. Smith, age 21 months, and Kaylee E. Smith, age 4 months. 4. At the time of separation Respondent Nicolle Brougher-Smith retained physical possession of said children at her residence at 19 W. Maplewood Avenue, Cumberland County, Mechanicsburg, PA 17055. 5. Since February 15, 2005, Respondent has denied Petitioner any visitation with said children. 6. Petitioner loves said children and said children love him and he desires interim visitation with said children from Friday at 9:00 a.m. to Sunday at 9:00 a.m. each week at his v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. DS - U{,~ Ctc.-,~L~0ur ANDREW P. SMITH, Plaintiff CIVIL ACTION - LAW NICOLLE BROUGHER-SMITH, Defendant IN CUSTODY ORDER AND NOW, , upon consideration of the attached Complaint, it is hereby directed that the Parties and their respective counsel appear before , the conciliator, at ,on ,2005, at m. 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 the scheduled hearing. FOR THE COURT, By: Custody Conciliator THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY IS REQUIRED BY LAW TO COMPLY WITH THE AMERICANS WITH DISABILITIES ACT. FOR Exhibit "A" INFORMATION ABOUT ACCESSIBLE F ACIUTIES AND REASONABLE ACCOMMODATIONS AVAILABLE TO DISABLED INDIVIDUALS HAVING BUSINESS BEFORE THE COURT, PLEASE CONTACT OUR OFFICE. 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 ANDREW P. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. CIVIL ACTION - LAW NICOLLE BROUGHER-SMITH, Defendant IN CUSTODY ORDER AND NOW, this day of March, 2005, upon consideration of Plaintiff's Request for Interim Visitation Rights, said Request is granted and Plaintiff Andrew P. Smith shall have interim visitation rights with his two children, Rylee N. Smith and Kaylee E. Smith from 9:00 A.M. Friday to 9:00 A.M. Sunday each week at his residence at 2208 Logan St., Camp Hill, P A 17011 until the Custody Conciliation Conference in this case is held. BY THE COURT: J. ANDREW P. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. r, CIVIL ACTION - LAW :-~ 1",'1 NICOLLE BROUGHER-SMITH, Defendant c" IN CUSTODY COMPLAINT FOR CUSTODY f"") C~i COUNT I 1. The Plaintiff is Andrew P. Smith, an adult individual, who resides at 2208 Logan Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is Nicolle Brougher-Smith, an adult individual, who resides at 19 West Maplewood Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff seeks shared physical and legal custody of the following children: Name Present Residence Age Rylee N. Smith 19 W. Maplewood Avenue Mechanicsburg, P A 17055 21 months Kaylee E. Smith 19 W. Maplewood Avenue Mechanicsburg, P A 17055 4 months 4. The children were not born out of wedlock. 5. The children are presently in the custody of Defendant Nicolle Brougher-Smith at 19 W. Maplewood Avenue, Mechanicsburg, PA 17055. 6. During the past two years, the children have resided with the following persons at the following addresses: Custodians Andrew P. Smith Nicolle Brougher-Smith Addresses 19 W. Maplewood Avenue Mechanicsburg, P A 17055 Dates 6/2/03 - 1130/05 Nicolle Brougher-Smith 19 W. Maplewood Avenue Mechanicsburg, P A 17055 1130105 - Present 7. The mother ofthe children is Nicolle Brougher-Smith who currently resides at 19 W. Maplewood Avenue, Mechanicsburg, PA 17055. The mother is married to the father Plaintiff Andrew P. Smith. 8. The father of the children is Andrew P. Smith, who currently resides at 2208 Logan Street, Camp Hill, P A 170 II. 9. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 10. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. II. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children and claims to have custody or visitation rights with respect to the children. 12. The best interest and welfare of the children will be served by granting the relief requested because: a) Plaintiff is better able to provide for, care for and love the children, b) Plaintiff can provide a loving and safe environment for the children, '. c) The children want to live with their father, and d) Defendant Mother is mentally unstable. 13. 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 Andrew P. Smith requests the Court to grant him shared custody of the children. COUNT II REQUEST FOR INTERIM VISITATION RIGHTS 14. Plaintiff incorporates by reference Paragraphs 1-13 of this Complaint as if said averments were fully set forth at length. 15. The parties were separated on January 30, 2005. 16. At the time of separation Defendant Nicolle Brougher-Smith retained physical possession of said children at the residence at 19 W. Maplewood Avenue, Mechanicsburg, P A 17055. 17. Since February 15, 2005 Defendant has denied Plaintiff any visitation with said children. 18. Plaintiff loves said children and desires interim visitation with said children from Friday at 9:00 A.M. to Sunday at 9:00 A.M. each week at his residence at 220& Logan St., Camp Hill, P A 17011. 19. Plaintiff has excellent facilities for conducing visitation with said children at the " " residence at 2208 Logan St., Camp Hill, PA 17011. WHEREFORE, Plaintiff Andrew P. Smith requests interim visitation with his two children from Friday at 9:00 A.M. to Sunday at 9:00 A.M. each week until the Custody Conciliation Conference in this case is held. March 15,2005 ~~-('~.~-L Peter B. Foster, Esquire Attorney for Plaintiff Pinskey & Foster 114 South Street Harrisburg, PA 17101 (717) 234-9321 . ' . .' . VERIFICATION I verify that the statements made in this Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. !i 4904 relative to unsworn falsification to authorities. March 15.2005 ~) Andrew P. Smith . CERTIFICATE OF SERVICE I hereby certify that on this date, March 17,2005, I served a copy of the foregoing Petition on the Respondent, Nicolle Brougher-Smith by mailing said copy by first class mail at Harrisburg, P A to the Respondent at her address as follows: Nicolle Brougher-Smith 19 W. Maplewood Avenue Mechanicsburg, P A 17055 March 17,2005 ~~.~~ Peter B. Foster, Esquire Attorney for Petitioner -k:. \-l l.b X f't ~ IJ -- ~ -eJ \ ~ ~ F ."n 5 :p r- ANDREW P. SMITH PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLV ANIA V. 05-1362 CIVIL ACTION LA W NICOLLE BROUGHER-SMITH IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, March 23, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S, Sunday, Esq. at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, April 26, 2005 , the conciliator, at t:OO 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 mav also be present at the conference. Failure to appear at the conference mav 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 tbe conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: Isl Dawn S. Sunday, Esq. Custody Concil iator ;,1-" 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 HA VE 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 \liN\'fi1fSNl ~::1d ^"lrl~r-. ".~.~. '-". "":) .l!\' t.;... \ 'T,', '\':-:::-.11;;I!' OS : II t.!V ZZ ~VW soaz ^dVLCJ~iJ:~;.LOdd 3Hl :10 ]8H~O-"G:ni:1 . . . 4 M,~R 1 8 Z005:,rv' "v ANDREW P. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-1362 CIVIL TERM CIVIL ACTION - LAW NICOLLE BROUGHER-SMITH, Defendant IN CUSTODY ORDER AND NOW, this day of March, 2005, upon consideration of Petitioner Andrew P. Smith's Motion for Interim Visitation Rights, said Petition is granted and Petitioner Andrew P. Smith shall have interim visitation rights with his two children, Rylee N. Smith and Kaylee E. Smith from 9:00 A.M. Friday to 9:00 A.M. Sunday each week at his residence at 2208 Logan St., Camp Hill, P A 170 II until the Custody Conciliation Conference in this case is held. BY THE COURT: J. v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O'5~(!j.p~ ANDREW P. SMITH, Plaintiff CIVIL ACTION - LAW NICOLLE BROUGHER-SMITH, Defendant IN CUSTODY PETITION FOR INTERIM VISITATION RIGHTS AND NOW, this 17m day of March, 2005, comes Petitioner Andrew P. Smith, by his attorney, Peter B. Foster, Esquire, and petitions for interim visitation rights for his two, minor children, and, in support thereof, avers as follows: I. On March 16, 2005, Petitioner filed a Custody Complaint in this case for shared physical and legal custody of his two, minor children, Rylee N. Smith and Kaylee E. Smith. A copy of said Complaint is attached as Exhibit "A." 2. The Parties were separated on January 30, 2005. 3. The Parties are the parents of Rylee N. Smith, age 21 months, and Kaylee E. Smith, age 4 months. 4. At the time of separation Respondent Nicolle Brougher-Smith retained physical possession of said children at her residence at 19 W. Maplewood Avenue, Cumberland County, Mechanicsburg, P A 17055. 5. Since February 15,2005, Respondent has denied Petitioner any visitation with said children. 6. Petitioner loves said children and said children love him and he desires interim visitation with said children from Friday at 9:00 a.m. to Sunday at 9:00 a.m. each week at his ANDREW P. SMITH, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. DS - I Jt...~ C-tc.-,J,",,<-r~ CIVIL ACTION - LAW NICOLLE BROUGHER-SMITH, Defendant IN CUSTODY ORDER AND NOW, , upon consideration of the attached Complaint, it is hereby directed that the Parties and their respective counsel appear before , the conciliator, at ,on ,2005, at m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or ifthis 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 ~e scheduled hearing. FOR THE COURT, By: Custody Conciliator THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY IS REQUIRED BY LAW TO COMPLY WITH THE AMERICANS WITH DISABILITIES ACT. FOR Exhibit "A" INFORMA nON ABOUT ACCESSIBLE F ACIUTIES AND REASONABLE ACCOMMODA nONS A v AILABLE TO DISABLED INDIVIDUALS HAVING BUSINESS BEFORE THE COURT, PLEASE CONTACT OUR OFFICE. 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 ANDREW P. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. CIVIL ACTION - LAW NICOLLE BROUGHER-SMITH, Defendant IN CUSTODY ORDER AND NOW, this day of March, 2005, upon consideration of Plaintiffs Request for Interim Visitation Rights, said Request is granted and Plaintiff Andrew P. Smith shall have interim visitation rights with his two children, Rylee N. Smith and Kaylee E. Smith from 9:00 A.M. Friday to 9:00 A.M. Sunday each week at his residence at 2208 Logan St., Camp Hill, PA 17011 until the Custody Conciliation Conference in this case is held. BY THE COURT: J. ANDREW P. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. r.o. ~ , f:.' ~ CIVIL ACTION - LAW NICOLLE BROUGHER-SMITH, Defendant L.' IN CUSTODY :;"' .. COMPLAINT FOR CUSTODY COUNT I roo') ().,; I. The Plaintiff is Andrew P. Smith, an adult individual, who resides at 2208 Logan Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is Nicolle Brougher-Smith, an adult individual, who resides at 19 West Maplewood Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff seeks shared physical and legal custody of the following children: Name Present Residence Ag~ Rylee N. Smith 19 W. Maplewood Avenue Mechanicsburg, PA 17055 21 months Kaylee E. Smith 19 W. Maplewood Avenue Mechanicsburg, PA 17055 4 months 4. The children were not bom out of wedlock. 5. The children are presently in the custody of Defendant Nicolle Brougher-Smith at 19 W. Maplewood Avenue, Mechanicsburg, PA 17055. 6. During the past two years, the children have resided with the following persons at the following addresses: Custodians Andrew P. Smith Nicolle Brougher-Smith Addresses 19 W. Maplewood Avenue Mechanicsburg, P A 17055 Dates 6/2/03 - 1/30/05 Nicolle Brougher-Smith 19 W. Maplewood Avenue Mechanicsburg, PA 17055 ] /30/05 - Present 7. The mother of the children is Nicolle Brougher-Smith who currently resides at 19 W. Maplewood Avenue, Mechanicsburg, PA 17055. The mother is married to the father Plaintiff Andrew P. Smith. 8. The father of the children is Andrew P. Smith, who currently resides at 2208 Logan Street, Camp Hill, P A 17011. 9. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 10. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 11. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children and claims to have custody or visitation rights with respect to the children. 12. The best interest and welfare of the children will be served by granting the relief requested because: a) Plaintiff is better able to provide for, care for and love the children, b) Plaintiff can provide a loving and safe environment for the children, , '. c) The children want to live with their father, and d) Defendant Mother is mentally unstable. 13. Each parent whose parental rights to the children have not been terminated ,md the person who has physical custody of the children have been named as Parties to this Action. WHEREFORE, Plaintiff Andrew P. Smith requests the Court to grant him shared custody of the children. COUNT II REQUEST FOR INTERIM VISITATION RIGHTS 14. Plaintiff incorporates by reference Paragraphs 1-13 of this Complaint as if said avernlents were fu]]y set forth at length. 15. The parties were separated on January 30, 2005. 16. At the time of separation Defendant Nicolle Brougher-Smith retained physical possession of said children at the residence at 19 W. Maplewood A venue, Mechanicsburg, P A 17055. 17. Since February 15, 2005 Defendant has denied Plaintiff any visitation with said children. 18. Plaintiff loves said children and desires interim visitation with said children from Friday at 9:00 A.M. to Sunday at 9:00 A.M. each week at his residence at 2208 Logan St., Camp Hill, P A 170 II. 19. Plaintiff has excellent facilities for conducing visitation with said children at the . '. . residence at 2208 Logan St., Camp Hill, P A 170 II. WHEREFORE, Plaintiff Andrew P. Smith requests interim visitation with his two children from Friday at 9:00 A.M. to Sunday at 9:00 A.M. each week until the Custody Conciliation Conference in this case is held. March 15,2005 \~ .~.~DQ~~ Peter B. Foster, Esquire Attorney for Plaintiff Pinskey & Foster 114 South Street Harrisburg, PA 17101 (717) 234-9321 . '. . VERIFICATION I verify that the statements made in this Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. S 4904 relative to unsworn falsification to authorities. March 15. 2005 Vb Andrew P. Smith CERTIFICATE OF SERVICE I hereby certify that on this date, March 17,2005, I served a copy of the foregoing Petition on the Respondent, Nicolle Brougher-Smith by mailing said copy by first class mail at Harrisburg, PA to the Respondent at her address as follows: Nicolle Brougher-Smith 19 W. Maplewood Avenue Mechanicsburg, P A 17055 March 17,2005 ~ ~,~kc Peter B. Foster, Esquire Attorney for Petitioner ~ 3Jj -t.s () \!:) T( T't- ~ ~ --) -- ~ 11:::: \\...() ( ~ '"'0 . t n C>" +- r ,- ANDREW P SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-1362 CIVIL ACTION - LAW NICOLLE BROUGHER-SMITH, Defendant IN CUSTODY PRAECIPE TO WITHDRAW CUSTODY COMPLAINT To the Prothonotary: It appearing that the Parties have resolved their domestic difficulties, Plaintiff Andrew P Smith withdraws the Custody Complaint filed in this Action. April 7, 2005 ~ \~ ~-( Peter B. Foster, Esquire Attorney for Plaintiff Pinskey & Foster 114 South Street Harrisburg, P A 17043 (717) 234-9321 CERTIFICATE OF SERVICE 1 hereby certify that on this date, April 7, 2005, I served a copy of the foregoing Praecipe on the Defendant by mailing said copy by first class mail at Harrisburg, P A to the attorney for Defendant at the following address: Samuel L. Andes, Esquire 525 North Twelfth Street Lemoyne, P A 17043 ~r~.~t. Peter B. Foster, Esquire Attorney for Plaintiff C. C? c ...., r:=, = <'-" ". ..." Al I -J ='".~ o -n -.... :r:.." f':'p.: -orn -oy '~~1 ?~ --. ~'~l o \D " ANDREW P SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-1362 CIVIL ACTION - LAW NICOLLE BROUGHER-SMITH. Defendant IN CUSTODY PRAECIPE TO PETITION FOR INTERIM VISITATION RIGHTS To the Prothonotary: It appearing that the Parties have resolved their domestic difficulties, Plaintiff Andrew P Smith withdraws the Petition for Interim Visitation Rights filed in this Action. April 7, 2005 ~ b.~:t. Peter B. Foster, Esquire Attorney for Plaintiff Pinskey & Foster 114 South Street Harrisburg, P A 17043 (717) 234-9321 CERTIFICATE OF SERVICE I hereby certify that on this date, April 7, 2005, I served a copy of the foregoing Praecipe on the Defendant by mailing said copy by first class mail at Harrisburg, P A to the attorney for Defendant at the following address: Samuel L. Andes, Esquire 525 North Twelfth Street Lemoyne, PA 17043 ~~.~- Peter B. Foster, Esquire Attorney for Plaintiff ....' c~;) <.:,:.? cf' ~ :;:0 I _I -n o -n .-1 ~-.\ fl"?: -t1'~Q -;,..1'1'- ~.) {.....) -(~~ '~\i }~l, , ) -2; -"" - o ...0 ':q ANDREW P. SMITH, Plaintiff v. NICOLLE BROUGHER- SMITH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 05-1362 CIVIL TERM ORDER OF COURT AND NOW, this 7th day of April, 2005, upon consideration of the Praecipe To Withdraw Petition for Interim Visitation Rights, filed on April 7, 2005, the hearing scheduled for April 8, 2005, is cancelled. ) I I Nicolle Brougher-Smith ! 19 West Maplewood A venVe Mechanicsburg, PA 17055 \ Defendant Peter J. Foster, Esq. 114 South Street Harrisburg, PAl 710 I Attorney for Plaintiff Courtesy Copy: Samuel L. Andes, Esq. 525 N. 12th Street Lemoyne, P A 17043 :rc BY THE COURT, , . i . . / I. / I , .v ? J, Wesley Oler,}t., ((~ 4 -g- P / '1-V-t'-(/~ I),) }IS" II : IlliV 9- l.ldV SUOZ ""'1'..""'.'(...',' .."" r (\Q\', \ lit ';-"! '(>J ~;ru- ::JU -":brJ/CXI3ilJ RECEIVED APR 13 m )\~ \- Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ANDREW P. SMITH vs. 05-1362 CIVIL ACTION LAW NICOLLE BROUGHER-SMITH Defendant IN CUSTODY ORDER AND NOW, this 11th day of April,2005 , the conciliator, being advised by plaintiffs counsel that the parties have reconciled and the plaintiff has filed a Praecipe to Withdraw Custody Complaint, hereby relinquishes jurisdiction. The Custody Conciliation Conference scheduled for April 26, 2005 is cancelled. FOR THE COURT, D~{A Custody Conciliator ;>c. 0 a- C'? ~,;;' \;:'~ - \ \.J'=C~ ~?-{0:, -- .- ,"::.:t. c..... ,q~~:') tI') !:=:'r i~1~ \,JJ..}.... u:.t.tJ c>:: C...... :.1:: ~-5.': \-- LL if' ~:::') 0 ~ ,-4