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HomeMy WebLinkAbout05-3024LINDA C. KIRBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION- LAW ARTHUR L. KIRBY, DIVORCE, ALIMONY, AND Defendant EQUITABLE DISTRIBUTION 05-3r-,,Z'4 CIVIL TERM COMPLAINT FOR DIVORCE, ALIMONY, AND EQUITABLE DISTRIBUTION The plaintiff, Linda C. Kirby, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: COUNTI DIVORCE UNDER 23 Pa.C.S. 4§3301(c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Linda C. Kirby, an individual residing at 7073 Carlisle Pike, Lot 171, Leiby's Trailer Park, Carlisle, Cumberland County, PA. 2. Defendant is Arthur L. Kirby, an individual who currently resides at 1326 Morway Maple Court, New Cumberland, PA 17072. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. The plaintiff and defendant were married on September 20, 1983 in Mechanicsburg, Pennsylvania. Plaintiff and defendant have lived separate and apart since on or about June 4, 2002. 6. There have been no prior actions for divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. COUNT II ALIMONY 9. Plaintiff repeats and realleges paragraphs one through eight. 10. Plaintiff requires support to adequately maintain herself according to a reasonable standard of living. 11. Plaintiff has been and will continue to be the primary caretaker of the parties' minor child. 12. Plaintiff worked for a period of time at the beginning of the marriage, but has been inconsistently involved in the workforce and has not had steady employment since 1996. Plaintiff, now age 49, is finding it difficult to find and maintain employment. 13. Plaintiff is not a citizen of the United States. 14. Plaintiffs first language is Chinese and she has great difficulty reading and writing English. 15. Even with considerable training, Plaintiff would be at a great disadvantage in obtaining employment because of her age and language barrier. 16. Defendant is financially able to provide for his reasonable needs and the reasonable needs of the Plaintiff. WHEREFORE, Plaintiff requests the Court to enter an award of reasonable alimony, and such other relief as the Court deems just. COUNT III EQUITABLE DISTRIBUTION 17. Plaintiff repeats and realleges paragraphs one through sixteen. 18. Plaintiff and Defendant have acquired property during the marriage, including, but not limited to: a) A trailer located at 7073 Carlisle Pike, Lot 171, Leiby's Trailer Park, Carlisle, Cumberland County, PA. b) A pension and/or retirement benefits from the Harrisburg Hilton. WHEREFORE, Plaintiff requests the Court to enter an award for equitable distribution of property, and such other relief as the Court deems just. Respectfully Submitted, Date #oz RENDA COPPED Certified Legal Intern Z6d LUCY TONON? LSH Supe ing Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. Date 6 / C Plaintiff. Akfirb Lin C ^' => o -?, t= ?^ .? _,= ?; _,,, -; 4 .?'. .,? '?t _ _ )?'? :^< 4'1 LINDA C. KIRBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE ARTHUR L. KIRBY, Defendant : NO. 05-3? IL TERM NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter- affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301fd1 OF THE DIVORCE CODE 1. The parties to this action separated in June 2002 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit 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. Date L- Linda C. Kirby, P aintr -Tj LINDA C. KIRBY, Plaintiff V. ARTHUR L. KIRBY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW IN DIVORCE 05- ))4 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Linda C. Kirby, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date 6 ff/j- Respe ully submitted A?al?lt ??" RENDA COPPEDE Certified Legal Intern I ANN AC ONALD-FOX LUC O STON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 r> ?, c? c. w -?, ..° ?_t _ ??'. ? Ci3 {Q i? _ W f i ?C.J -cq C:1 _i ?: _- 't7 u? -"= LINDA C. KIRBY, Plaintiff V. ARTHUR L. KIRBY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW DIVORCE, ALIMONY, AND EQUITABLE DISTRIBUTION 05-3024 CIVIL TERM CERTIFICATE OF SERVICE I, Brenda Coppede, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Complaint for Divorce on Mr. Lawrence Rosen, Esquire, Krevsky & Rosen, P.C., 1101 Front Street, Harrisburg, PA, 17102, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested on June 16, 2005. Service was complete upon receipt by Mr. Lawrence Rosen, Esquire, on the day of June 17, 2005, as evidenced by the attached green card with the article number 7003 3110 0004 5774 2709. ?+ A0 k ye?t BRENDA COPPEDE Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 Office: (717) 243-2968 Fax: (717) 243-3639 N '?C3 MOln9 y "WON ? 000=0 t0YOU- so 000 IND 00 bolou ON AftsichX6=1 woo vo"*'- a on tw: X .." ? ?oWdb!(NrewY wd?lw+?? pwo ?vea+?arVwr tR, 0L ? Poo ?aie?'"F?sa L?4 P8 ram 00 . LINDA C. KIRBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION-LAW DIVORCE, ALIMONY, AND EQUITABLE DISTRIBUTION ARTHUR L. KIRBY, Defendant : No. 05-3024 CIVIL TERM INVENTORY OF PLAINTIFF. LINDA C. KIRBY Plaintiff files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Plaintiff verifies that the statements made in this inventory and appraisement are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Plaintiff reserves the right to correct and/or supplement this Inventory to the extent that she acquires additional information regarding assets and/or liabilities. Plaintiff, Lid C. Irby ASSETS OF THE PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. (X) 1. Real property ()2. Motor vehicles () 3. Stocks, bonds, securities and options () 4. Certificates of deposit () 5. Checking accounts, cash ()6. Savings accounts, money market and savings certificates () 7. Contents of safe deposit boxes () 8. Trusts ()9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) ()10. Annuities O 11. Gifts O 12. Inheritances ()13. Patents, copyrights, inventions, royalties ()14. Personal property outside the home O15. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) () 16. Employment termination benefits - severance pay, workman's compensation claim/award ()17. Profit sharing plans (X) 18. Pension plans (indicate employee contribution and date plan vests) ()19. Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments () 21. Litigation claims (matured and unmatured) () 22, MilitaryN.A. benefits ( ) 23. Education benefits ()24, Debts due, including loans, mortgages held ()25, Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) ( ) 26. Other MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Description Names of Number of Property All Owners 7073 Carlisle Pike Arthur L. Kirby Lot 171 Linda C. Kirby Leiby's Trailer Park Carlisle, PA 17013 18 Pension from Arthur L. Kirby Harrisburg Hilton NON-MARITAL PROPERTY Plaintiff lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: Item Number Description Reason for of Property Exclusion PROPERTY TRANSFERRED Item Number Description Date of Consideration of Proaerty Transfer Person to Whom Transferred LIABILITIES Item Description Names of Names of Number of Prove rty All Creditors All Debtors Ci r? _? O t? cr -?7 -- r? = r r rv r , ? ?.+ ?-?? ,- -; :? ? ` i ;??i - c. , _ r? ca ,,? LINDA C. KIRBY, Plaintiff V. ARTHUR L. KIRBY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW DIVORCE, ALIMONY, AND EQUITABLE DISTRIBUTION 05-3024 CIVIL TERM CERTIFICATE OF SERVICE I, Brenda Coppede, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Inventory of Plaintiff, Linda C. Kirby, on Mr. Lawrence Rosen, Esquire, Krevsky & Rosen, P.C., 1101 Front Street, Harrisburg, PA, 17102, by depositing a copy of the same in the United States mail on July 22, 2005. /;iBRENDA COPPF Certified Legal Intern FAMILY LAW CLINIC 4:5 North Pitt Street Carlisle, PA 17013 Office: (717) 243-2968 Fax: (717) 243-3639 _ Fir, r-i . , I - r LINDA C. KIRBY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW ARTHUR L. KIRBY, DIVORCE, ALIMONY, AND Defendant EQUITABLE DISTRIBUTION NO. 05-3024 CIVIL TERM PETITION FOR RULE TO SHOW CAUSE WHY DEFENDANT SHOULD NOT BE COMPELLED TO FILE AN INVENTORY The Plaintiff, Linda C. Kirby, by her attorneys, the Family Law Clinic, petitions this Court to issue a Rule to Show Cause why Defendant shall not be compelled to file an Inventory pursuant to Rule 1920.33. In support of her Petition, Plaintiff states as follows: I. Plaintiff and Defendant were married on September 20, 1983. 2. Plaintiff filed a divorce complaint with an Equitable Distribution count on June 13, 2005. 3. On July 22, 2005, Plaintiff served on Defendant an Inventory of all property owned and possessed by Plaintiff. 4. Defendant failed to file his own Inventory of property. 5. As a courtesy, on August 11, 2005, Plaintiff sent Defendant a letter requesting that he give prompt attention to this matter. 6. Defendant has failed to file an Inventory or to respond to these requests. 7. Pursuant to Pa.R.C.P. 1920.33(a), each party shall file an inventory specifically describing all property owned or possessed at the time the action was commenced. Pursuant to Pa. R.C.P. 1920.33(c), if a party fails to file an inventory, the court may make an appropriate order addressing sanctions. 8. As of the filing date of this Motion, Defendant has failed to provide the Family Law Clinic with his Inventory. 9. In accordance with Rule 208.2(d) of Cumberland County Rules of Civil Procedure, concurrence of opposing counsel, Lawrence Rosen, Esquire, was sought and was not obtained. WHEREFORE, Plaintiff respectfully requests that this Court enter a Rule to Show Cause why the Defendant should not be compelled to file an Inventory within twenty (20) days. Submitted, BRENDA COPPE91j Certified Legal Intern A DONALD-FOX ANN LUC JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 ._o _. rte, O ?.h -,-? C? ']--n ?-'1 i ?l ? :'. `",i i1 ? ? -) l. C: i ?' ("7 IJ -i-. :1 S?J .? RECEIVED OCT 0 6 2005 LINDA C. KIRBY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION- LAW ARTHUR L. KIRBY, DIVORCE, ALIMONY, AND Defendant EQUITABLE DISTRIBUTION NO. 05-3024 CIVIL TERM ORDER AND NOW, this 1a4 day of 4 & jgAJ 2003, upon consideration of the foregoing petition, it is hereby ordered that 1) a rule is issued upon the respondent to show cause why the petitioner is not entitled to the relief requested; 2) the respondent shall file an answer to the petition within twenty days of service upon the respondent; 3) the petition shall be decided under Pa.R.C.P. No. 206.7; 4) depositions shall be completed within -days of this date; 5) argument shall be held on a / in Courtroom ? of the Cumberland County Courthous 6) notice of entry of this order shall be provided to all parties by the petitioner. BY THE COURT, J. LINDA C. KIRBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW ARTHUR L. KIRBY, DIVORCE, ALIMONY, AND Defendant EQUITABLE DISTRIBUTION NO. 05-3024 CIVIL TERM PETITION FOR RULE TO SHOW CAUSE WHY DEFENDANT SHOULD NOT BE COMPELLED TO FILE AN INVENTORY The Plaintiff, Linda C. Kirby, by her attorneys, the Family Law Clinic, petitions this Court to issue a Rule to Show Cause why Defendant shall not be compelled to file an Inventory pursuant to Rule 1920.33. In support of her Petition, Plaintiff states as follows: 1. Plaintiff and Defendant were married on September 20, 1983. 2. Plaintiff filed a divorce complaint with an Equitable Distribution count on June 13, 2005. 3. On July 22, 2005, Plaintiff served on Defendant an Inventory of all property owned and possessed by Plaintiff. 4. Defendant failed to file his own Inventory of property. 5. As a courtesy, on August 11, 2005, Plaintiff sent Defendant a letter requesting that he give prompt attention to this matter. 6. Defendant has failed to file an Inventory or to respond to these requests. Pursuant to Pa.R.C.P. 1920.33(a), each party shall file an inventory specifically describing all property owned or possessed at the time the action was commenced. Pursuant to Pa. R.C.P. 1920.33(c), if a party fails to file an inventory, the court may make an appropriate order addressing sanctions. 8. As of the filing date of this Motion, Defendant has failed to provide the Family Law Clinic with his Inventory. 9. In accordance with Rule 208.2(d) of Cumberland County Rules of Civil Procedure, concurrence of opposing counsel, Lawrence Rosen, Esquire, was sought and was not obtained. WHEREFORE, Plaintiff respectfully requests that this Court enter a Rule to Show Cause why the Defendant should not be compelled to file an Inventory within twenty (20) days. Submitted, BRENDA COPPEV Certified Legal Intern A DONALD-FOX LUC JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 ?? ?°? ? -n 5 f fl (.-i 'L -rt ? ? ??? U'. ?. t J r?-,'. ?C1 ?n? _, . . _ ?r3 :? SJ LINDA KIRBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 05-3024,480 S 1989 CIVIL TERM ARTHUR L. KIRBY, Defendant : IN DIVORCE AND SUPPORT PETITION FOR LEAVE TO WITHDRAW Petitioner, The Family Law Clinic, hereby petitions for leave to withdraw from further representation of Linda Kirby, pursuant to Pa.R.P.C. 1.16(a) and Pa.R.C.P. 1012(b), and in support therefore avers the following: 1. The Family Law Clinic entered an appearance in the above captioned matter on behalf of Linda Kirby March 15, 2004. 2. On April 14, 2004, the Family Law Clinic attended a Support Conference with Linda Kirby and an Interim Order of Court was entered on said date. 3. On May 20, 2004, the Family Law Clinic represented Linda Kirby at a Support Hearing and an Interim Order of Court was entered on May 24, 2004. 4. On June 1, 2005, the Family Law Clinic filed a Complaint for Divorce, Alimony, and Equitable Distribution on behalf of Linda Kirby. 5. On July 22, 2005, the Family Law Clinic filed an Inventory of property and assets for Linda Kirby. 6. On October 5, 2005, the Family Law Clinic filed a Petition for Rule to Show Cause Why Defendant Should Not Be Compelled to File an Inventory. 7. On October 12, 2005, an Order was entered by the Court compelling the Defendant to show cause why Linda Kirby was not entitled to the relief requested and scheduling arguments for December 16, 2005. On December 16, 2005, the arguments were continued, to be rescheduled at the request of either party. 8. The Family Law Clinic has not had any contact with Linda Kirby since the beginning of March 2006. 9. Since March 2006, the Family Law Clinic has made several attempts to contact Ms. Kirby, both by telephone and mail. a. On March 3, 2006, March 23, 2006, March 24, 2006, and April 18, 2006, telephone messages were left for Ms. Kirby and none were returned. On November 20, 2006, the Family Law Clinic called Ms. Kirby and the telephone number had been disconnected. Ms. Kirby has not called the Family Law Clinic with an update of her new telephone number. b. On April 21, 2006, June 6, 2006, August 28, 2006, October 11, 2006, November 13, 2006, November 27, 2006, December 1, 2006, January 18, 2007, February 15, 2007, March 21, 2007, April 23, 2007, May 23, 2007, and June 12, 2007, letters were sent to Ms. Kirby's home requesting that she contact the Family Law Clinic. Ms. Kirby never responded to the letters and none were returned. 10. The Family Law Clinic is unable to proceed with Ms. Kirby's divorce action at this time as Ms. Kirby has ceased communicating with the Family Law Clinic. 11. On June 12, 2007, the Family Law Clinic sent a letter to Ms. Kirby indicating that if we had not had contact from her by June 26, 2007, we would petition the Court to withdraw as her representation. As of the date of filing, Ms. Kirby has not contacted the Family Law Clinic. 12. The Honorable Kevin A. Hess, previously presided over this case. 13. Pursuant to Local Rule 208.2(d), concurrence of opposing counsel was sought and received on June 27, 2007. WHEREFORE, pursuant to Pa.R.P.C. 1.16(a) and Pa.R.C.P. 1012(b), the Family Law Clinic respectfully requests permission for leave to withdraw as Plaintiff's counsel from this action. Date: Respectfully Submitted, Susan C. Plano Certified Legal Intern MEGAN RIESMEYER THOMAS M. PLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ?? ?? ?-' ?, ` ?y 3? ?_ r? c ? c ?. ?.J; ; , ' 4 _ fir.. , ? ?„ t ?t ? : F? . ?? ? h JUN 8920D7* LINDA KIRBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 05-3024, 480 S 1989 CIVIL TERM ARTHUR L. KIRBY, Defendant : IN DIVORCE AND SUPPORT RULE TO SHOW CAUSE AND NOW, this day of _ ,,?h , 2007: 1. A rule is issued upon Linda Kirby to show cause why the Family Law Clinic should not be granted leave to withdraw as counsel of record; 2. Linda Kirby shall file an answer to the petition within Z-V days of service upon her; 3. The petition shall be decided under Pa.R.C.P. 206.7; 4. Notice of the entry of this order shall be provided to all parties by the Family Law Clinic. D V 'P1-71E7 Of-IT TD T. L 4l T v d V °. iv 11 ?;! 0 I li(' POZ LINDA KIRBY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE ARTHUR L. KIRBY, Defendant NO. 05 - 3024 CIVIL TERM CERTIFICATE OF SERVICE I, Susan C. Plano, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Petition for Leave to Withdraw and the Rule to Show Cause on the following persons by depositing a copy of the same in the United States mail, first class, postage prepaid, from Carlisle, Pennsylvania, on July 17, 2007, addressed as follows: Linda Kirby Lawrence J. Rosen, Esq. 7073 Carlisle Pike 1101 N. Front St. Leiby's Trailer Park Harrisburg, PA 17102 Carlisle, PA 17013 C?b?& Susan C. Plano Certified Legal `Intern MEGAN RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 N G._7 LINDA KIRBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 05-3024, 480 S 1989 CIVIL TERM ARTHUR L. KIRBY, Defendant : IN DIVORCE AND SUPPORT PETITION TO MAKE RULE ABSOLUTE AND NOW, comes the Family Law Clinic, and files this Petition to Make the Rule issued on July 9, 2007 Absolute and states in support thereof as follows: 1. On June 28, 2007, the Family Law Clinic filed a Petition for Leave to Withdraw from representation of Plaintiff, Linda Kirby. 2. On July 9, 2007, the Honorable Judge Kevin A. Hess issued a Rule upon Plaintiff to show cause why the relief requested should not be granted, Rule Returnable within twenty (20) days of service. A copy of the Petition for Leave to Withdraw and Rule to Show Cause is attached as "Exhibit A." 3. A copy of the Petition for Leave to Withdraw and Order of Court - Rule to Show Cause, was served upon Plaintiff, Linda Kirby, by first class mail, postage prepaid, at her last known address at 7073 Carlisle Pike, Leiby's Trailer Park, Carlisle, Cumberland County, Pennsylvania 17013, on July 17, 2007. 4. A copy of the Petition for Leave to Withdraw and Order of Court - Rule to Show Cause, was served upon Opposing Counsel, Lawrence J. Rosen, Esq., by first class mail, postage prepaid, at 1101 North Front Street, Harrisburg, Pennsylvania 17013, on July 17, 2007. 5. More than twenty (20) days have elapsed since the Order of Court - Rule to Show Cause was served on Plaintiff and Defendant's counsel and no response has been filed. 6. The Family Law Clinic has not been contacted by the Plaintiff since March 2006. 7. Pursuant to Local Rule 208.2(d), concurrence of opposing counsel was sought and received on June 27, 2007. WHEREFORE, the Family Law Clinic requests that the Court make the Rule Absolute and grant the Family Law Clinic's Petition for Leave to Withdraw. Dat Respectfully Submitted: Susan _C. Plano Certified Legal Intern '?4 4z LUCY TO_WSTON-WALSff? ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX MEGAN RIESMEYER FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013-2899 (717) 243-2968 Fax: (717) 243-3639 -_-' .-? c._.. Ill ?.== .....- --R C. .?" ?-, r-?. ?-- ? ' _? , ?: ;j?t? ,. ?, ? ? F ?? :? G} ?IU616 2001„?, ?F LINDA KIRBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA vi. :NO. 05-3024, 480 S 1989 CIVIL TERM ARTHUR L. KIRBY, Defendant : IN DIVORCE AND SUPPORT ORDER OF COURT AND NOW this the /S`" day of i , 2007, upon consideration of the attached petition, it is hereby ordered that the Family Law Clinic is granted leave to withdraw from further representation of Plaintiff, Linda Kirby. BY THE COURT: J. S i?t ?i.fff /1LUJ ` f'' ''.