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HomeMy WebLinkAbout05-5349RALPH B. ZORN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ROBIN E. ZORN, NO. ` .5 3/ CIVIL TERM Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Ralph B. Zorn, an adult individual currently residing at 1150 Cranes Gap Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Robin E. Zorn, an adult individual currently residing at 517 Adams Road, Carlisle, Cumberland County, Pennsylvania. 3. The parties are the natural parents of one (1) child, namely, Amy Zorn, born August 10, 1996. The Defendant is the natural mother and the Plaintiff is the adoptive father of a second child, Seth Zorn, born October 30, 1989. 4. The child at issue has resided with the following persons at the following addresses for the following periods of time over the past five years: NAME ADDRESS Ralph B. Zorn 1150 Cranes Gap Road Robin E. Zorn Carlisle, PA 17013 Seth Zorn Amy Zorn Ralph B. Zorn 1150 Cranes Gap Road Robin E. Zorn Carlisle, PA 17013 Amy Zorn Seth Zorn Ryan Zorn DATES Prior to September 2000 to April 8, 2005 April 8, 2005 to August 25, 2005 NAME Robin E. Zorn Seth Zorn Amy Zorn Marvin Keller Pam Keller ADDRESS 517 Adams Road Carlisle, PA 17013 DATES August 25, 2005 to present The natural mother of the children is Robin E. Zorn who resides as aforesaid. She is married. The natural father of the child is Ralph B. Zorn who resides as aforesaid. He is married. 5 6 7 8. 9 The relationship of the Plaintiff to the child is that of natural father. The Plaintiff currently resides with his son, Ryan Zorn. The relationship of the Defendant to the child is that of natural mother. Defendant currently resides with Seth Zorn and Amy Zorn, and her parents. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the child. Plaintiff has no information of any custody proceedings concerning the child pending in any Court of this Commonwealth. It is in the best interest and permanent welfare of the child to grant the relief requested because: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RALPH B. ZORN, Plaintiff NO. 2005-5349 CIVIL ACTION - LAW V. ROBIN E. ZORN Defendant . IN CUSTODY PRAECIPE FOR WITHDRAWAL OF APPEARANCE To the Prothonotary: Please withdraw the appearance of Harold S. Irwin, II, Esquire, on behalf of Robin E. Zorn, Defendant in the above captioned matter. Date: //z `'/? <? Harold S. Irwin, II 65 South Pitt Street Carlisle, PA 17013 (717) 243-6090 I. D. No. 29920 a) Plaintiff has a strong and close relationship to his daughter Amy and desires to maintain and expand that relationship; b) Until Mother withdrew Amy from the home, Father maintained close contact and was actively involved in the child's life on a day-to-day basis; C) Plaintiff can provide greater stability for the child than can Defendant; WHEREFORE, Plaintiff requests your Honorable Court to schedule Custody Conciliation Conference followed by a hearing at which time he should be granted shared legal custody and primary physical custody of Amy Zorn. Respectfully submitted, 4rneyft riffle, Esquire orPlaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. J DATE: *Ralph. . RALPH B. ZORN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ROBIN E. ZORN, : NO. CIVIL TERM Defendant : IN CUSTODY CERFICATE OF SERVICE I, Bradley L. Griffie, Esquire, hereby certify that I did, the / / day of October, 2005, cause a copy of Plaintiff's Complaint for Custody to be served upon Defendant's attorney via facsimile and first class mail, postage prepaid, certified, return receipt, restricted delivery at the following addresses: Harold S. Irwin, III, Esquire 64 South Pitt Street Carlisle, PA 17013 DATE: tb ? it DS u-11-` y for Plaintiff/Respondent GRI''FIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 ? ? r..., _,,,,r (? 3 r ? ? ? Yl ?? - ? r ;jam C v 1 ` ? -+??a W r-? ?..: - - ? ? 4 _ (y? ? ?/`, C1 RALPH B. ZORN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 05-5349 CIVIL ACTION LAW ROBIN E. ZORN DEFFNDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, October 19,2005___ upon consideration o'f the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle.. on Tuesday, November 29, 2005 at 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. 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 scheduled hearing. FOR THE COURT, By /s/ JacgueGne M. Veme Es q, 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 homy prior to any hearing or business before the court. You must attend the schedulec 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, Pennsylvania 17013 Telephone (717)249-3166 .,,,.. ?? ?? so ? f_ of ? ?? ? ? ?? ?,_. ,:: RALPH B. ZORN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ROBIN E. ZORN, : NO. 05- 53L6 CIVIL TERM Defendant IN CUSTODY TEMPORARY CUSTODY STIPULATION & AGREEMENT THIS TEMPORARY CUSTODY STIPULATION AND AGREEMENT entered into the day and year hereinafter set forth, by and between RALPH B. ZORN, (hereinafter referred to as "Father") and ROBIN E. ZORN, (hereinafter referred to as "Mother") WHEREAS, the parties are the natural parents of one children, namely AMY ZORN, born August 10, 1996 (hereinafter referred to as "Child"); and WHEREAS, the parties live separate and apart, such that is necessary to establish arrangements for the child, AMY ZORN, to maintain contact with both parties; and WHEREAS, the parties wish to enter into a temporary arrangement pending further proceedings in the above docketed matter, it is hereby agreed as follows: 1. The parties shall have shared legal custody of the child. 2. Mother shall have primary physical custody of the child with Father having periods of temporary physical custody on the following schedule: a. Every other weekend from after school on Friday until 7:30 p.m. rav?.?cd !''o?7'tU' ?n?cavGs ?at' on Sunday evenin `t G? e e c 5„o H•ee5 (? c_ c Gt c ! S !N A)'IC1 10 w ?l ? ? ? ? ?dltx a,.ti Q ?.41e 6.117 e.?e ?Aa- Every-Wednesday _ r_, 4f4e P,.,.,.,., Ptil Tt o/-"/r 4,aer+tifig when he sees that she is delivered +o soh84; aod c. At other times as the parties may agree. PIZ d. In addition, the parties shall share custody of Amy on any holidays that occur pending entry of a more comprehensive Order in this matter. The terms of sharing the holidays shall be agreed upon between the parties and counsel. J. The parties wish to have the within Stipulation and Agreement entered as an Order of Court to the above-docketed action as a temporary Order pending further proceedings in this matter. IN WITNESS WHEREOF, The parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year hereinafter mentioned. G??*LPI3. /, ate D ate a ROtiN E. Z RN i W 1TNES SETH: ??: r,. OCT 2 6 2005 f V, RALPH B. ZORN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CIVIL TERM ROBIN E. ZORN, Defendant NO. 0''.. 3tt 1 IN CUSTODY ORDER OF COURT AND NOW, this ?1 Jr, day oft) /??? upon presentation and consideration of the with Stipulation and Agreement, it is hereby ORDERED and DIRECTED that pending further proceedings in this matter the parties, and on a temporary basis, RALPH B. ZORN (hereinafter referred to "Father") and ROBIN E. ZORN (hereinafter referred to as "Mother) shall have shared legal custody of their daughter, AMY ZORN, born August 10, 1996. In addition, on a temporary basis, physical custody shall be exercised with Mother having primary physical custody and Father having periods of partial physical custody on the following schedule: a. Every other weekend from after school on Friday until 7:30 p.m. on Sunday evening; aad ?/err J J cC*?' -7'1 7 Cy rl. A?? 0,9 S ° 4' ?f ?l?'^' /lr/l BLS ?'>r SvG?E?[ firwt¢S •?iuo9/?evL& eS Gw - b - ooeal,'rSs Of% ? Fr?j &J$xle / 1w c. At other times as the parties may agree. lje fts?/?t f In addition, the parties shall share custody of Amy on any holidays that occur pending entry of a more comprehensive Order in this matter. The terms of sharing the holidays shall be agreed upon between the parties and counsel. J. Cc; ,Bradley L. Griffie, Esquire Attorney for Plaintiff gold s. Irwin, III, Esquire Attorney for Defendant 10"3 DEC 2 7 2005.?n RALPH B. ZORN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. ROBIN E. ZORN, : NO. 2005-5349 CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this ;-)day of 2005 upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. , of the Cumberland County Court House, on the (o?t'?'1 day of F , 2006, at 9-:36 o'clock, A . M., at which time testimony will be taken. For purposes of this Hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Order of Court shall remain in full force and effect except as modified hereinafter: 3. The Father, Ralph B. Zorn, and the Mother, Robin E. Zorn shall have shared legal custody of Amy Zorn, born August 10, 1996. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding her health, education and religion. 4. Mother shall have primary physical custody of the child. Father shall have the following periods of partial physical custody of the child: A. Alternating weekends from Friday at 7:30 p.m. to Sunday evening. B. From after school until Mother picks her up after work. C. Such other times as the parties agree. 6. Transportation shall be as agreed by the parties. The parties shall have reasonable telephone contact with the child. 8. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. cc: Bradley L. Griffie, Esquire, counsel for Father Harold S. Irwin, III, Esquire, counsel for Mother l?'??-L'S- ?lt o J"? r. C E :5 1",""1 8Z ?'9 ",I"'! 1?Ur?l`" i? -' 1 w JEC 2 7 200?j?\ RALPH B. ZORN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. ROBIN E. ZORN, : NO. 2005-5349 CIVIL ACTION - LAW Defendant IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Amy Zorn August 10, 1996 Mother 2. A Conciliation Conference was continued from November 29, 2005. Counsel have exchanged correspondence concerning the parents' respective positions with regard to custody arrangements with the Conciliator since November 29, 2005. On December 22, 2005 the Conciliator met with Father's counsel, Bradley L. Griffie, Esquire and held a telephone conference with Mother's counsel, Harold S. Erwin, III, Esquire. 3. The Court previously entered an Order on October 27, 2005 providing for shared legal custody, Mother having primary physical custody and Father having alternating weekends from Friday at 7:30 p.m. to Sunday evening. 4. Father's position on custody is as follows: Father seeks shared legal and shared physical custody on a week on/week off basis. Father receives a veteran's disability for Persian Gulf Syndrome but maintains that he is available and able to properly care for the child. Father alleges that Mother suffers from depression and a shared physical custody arrangement would be beneficial to Mother and child. 5. Mother's position on custody is as follows: Mother seeks shared legal custody and primary physical custody with Father having alternating weekends and after school until Mother picks her up after work. Mother maintains that Father's condition prevents him from caring for the child on a shared physical custody basis. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and granting the parents shared legal custody, Mother primary physical custody and Father having alternating weekends and two evenings per week. It is expected that the Hearing will require one day. Date acq ine M. Verney, Esquire Custody Conciliator IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RALPH B. ZORN, Plaintiff V. ROBIN E. ZORN, Defendant NO. 2005-5349 : CIVIL ACTION - LAW IN CUSTODY PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of Diane G. Radcliff, Esquire, Supreme Court ID No. 32112, on behalf of the Defendant, Robin E. Zorn. Papers may be served at the address set forth below: Diane G. Radcliff 3448 Trindle Road Camp Hill, PA 17011 Phone: (717) 737-0100 Date: t 13 b (10 ! !__ _. I;I T ?'i r. l ?_- I11 RALPH B. ZORN, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ROBIN E. ZORN, : NO. 2005-5349 CIVIL TERM Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 601' day of ( , 2006, following the presentation of the parties' agreement in open Court, it is hereby ORDERED AND DIRECTED as follows: 1. Ralph B. Zorn ("Father") and Robin E. Zorn ("Mother") shall have shared legal custody of their child, Amy Zorn ("Amy"), born August 10, 1996. 2. Mother shall have primary physical custody of Amy. 3. Father shall have periods of physical custody of Amy on the following schedule: (A) During the school year as follows: (i) Every other weekend from after school on Friday until 7:30 p.m. on Sunday; (ii) One evening per week during the weekdays from after school until Father delivers Amy to school the following morning; and (iii) One evening per week from after school until the end of Mother's workday. (iv) At other times as the parties may agree. It is understood that the weekday periods of custody are to routinely coincide with evenings when Mother is working. (B) During the summer vacation months, the parties will alternate physical custody of Amy on a week-on week-off basis with the party who otherwise would have the first weekend of custody after the school year has ended, retaining custody from that Friday evening until the following Friday at 6:00 p.m. The other party shall then secure custody and retain custody until the following Friday at 6:00 p.m. The parties shall then alternate retaining custody on a weekly basis with exchanged occurring on Fridays at 6:00 p.m. throughout the summer months ac?- 0( enot:,,S -Me- 1a& I- Fr.oto-j be-to, c- scA,,?ol beb ^s -A' Fst ' 4 The parties will share custody of Amy on holidays by alternating the following holiday for the period from 9:00 a.m. to 6:00 p.m.: Easter Sunday, Memorial Day, the 4th of July, Labor Day and Thanksgiving. Father shall have custody of Amy for Easter Sunday 2006 and the parties will alternate the named holidays from that point forward, such that Father shall have Easter Sunday, the Fourth of July and Thanksgiving, and Mother shall have Memorial Day and Labor Day in 2006, and all even numbered years. Mother shall have custody on Easter Sunday, the Fourth of July and Thanksgiving and Father shall have Memorial Day and Labor Day in 2007 and all odd numbered years. 5. During the Christmas holiday season, the parties shall alternate physical custody between the following two periods: a.) From 9:00 a.m. on Christmas Eve until 1:00 p.m. on Christmas Day; and b.) From 1:00 p.m. on Christmas Day until 5:00 p.m. on December 26. Mother shall have the first period and Father shall have the second period for Christmas 2006 and all even numbered years thereafter. Father shall have the first period and Mother shall have the second period for Christmas 2007 and all odd numbered years thereafter. In addition, the party who has the second Christmas 2 period set forth above shall also have custody of Amy on New Year's Eve for the period from 9:00 a.m. on December 31, until 12:00 Noon on January 1. 6. Amy shall always be with Mother on Mother's Day and with Father on Father's Day for the period from 9:00 a.m. until 6:00 p.m. on those days. ?/)I/ 7. The parties shall share responsibility for transportation by the party who is securing " custody providing the transportation for the custody exchange. 8. The parties shall keep each other advised in the event of serious illness or medical emergency concerning the child and shall further take any necessary steps to ensure that the health and well-being of the child is protected. During such illness or medical emergency, both parties shall have the right to visit the child as often as he or she desires consistent with the proper medical care of the child. 9. Neither party shall do anything which may estrange the child from the other party, injure the opinion of the child as to the other party, or which may hamper the free and natural development of the child's love and affection for the other party. 10. This Court retains jurisdiction of this matter. Distribution: Bradley L. Griffie, Esquire Attorney for Plaintiff Diane G. Radcliff, Esquire Attorney for Defendant D q. 0 4 4. 3 Edward E. Guido, J. SS :Z !11j 9- SIA'J"Gl RALPH B. ZORN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ROBIN E. ZORN, NO. 2005-5349 CIVIL TERM Defendant IN CUSTODY PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF CUSTODY AND PARTIAL CUSTODY ORDER AND NOW COMES, Petitioner, Ralph B. Zorn, by and through his counsel of record, Bradley L. Griffie, Esquire and Petitions the Court as follows: 1. Petitioner is the above named Plaintiff, Ralph B. Zorn, an adult individual currently residing at 1916 Ester Drive, Carlisle, Pennsylvania, 17013. 2. Respondent is Robin E. Zorn, the above named Defendant and an adult individual currently residing at 1152 North Pheasant Run, Carlisle, Pennsylvania, 17013. 3. The parties are the natural parents of one child namely Amy Zorn, born August 10, 1996. 4. The parties are subject to an Order of Court dated February 6, 2006, which is attached hereto and incorporated herein as hereby reference as Exhibit "A" setting forth their rights with respective custody of the child, Amy. 5. The Respondent has willfully failed to abide by the Order as follows: (A) During the weeklong period beginning August 11, 2006 at 6:00 p.m., when Amy was to have been with Petitioner for the period from Friday, August 11, 2006 at 6:00 p.m. to Friday, August 18, 2006 at 6:00 p.m., Respondent failed and refused to allow Amy to be in Petitioner's custody thereby violating paragraph 3(B) of the Order; (B) Respondent willfully failed to allow Petitioner to have Amy in his custody from Friday, August 25, 2006 from 6:00 p.m. until Sunday evening at 7:30 p.m. therby violating paragraph 3(A)(i) of the Order; (C) During the week of August 28, 2006, which was the first week of school for Amy, Respondent failed and refused to allow Amy to be in the Petitioner's custody for one evening per week, from after school until the following morning thereby violating of paragraph 3(A)(ii); (D) During the week of August 28, 2006, Respondent willfully failed and refused to allow Amy to be in Petitioner's custody for one evening per week, from after school until the end of the mother's work day thereby violating paragraph 3(A)(iii) of the Order. (E) Respondent willfully failed and refused to allow Petitioner to have custody of Amy from the end of Amy's school day on Friday, September 1, 2006 until 7:30 p.m. on Sunday through September 3, 2006, therby violating paragraph 3(A)(i) of the Order; (F) During the week of September 5, 2006, Respondent willfully failed and refused to allow Petitioner to have custody of Amy for one evening per week from after school until the following morning when Amy was to go to school, thereby violating of paragraph 3(A)(ii) of the Order; (G) During the week of September 5, 2006, Respondent willfully failed and refused to allow Petitioner to have custody of Amy for one evening per week, from after school until the end of the mother's work day thereby violating paragraph 3(A)(iii) of the Order; and (H) Respondent willfully failed and refused to allow Petitioner to have custody of Amy from the end of Amy's school day on Friday, September 10, 2206, thereby violating paragraph 3(A)(i) of the Order; 6. Petitioner made repeated requests of Respondent to have custody of Amy pursuant to the Court Order and Respondent has refused to allow those periods of custody. 7. Counsel for Petitioner corresponded with counsel for Respondent specifically requesting and demanding that Respondent comply with the terms of the Court Order, and more specifically that she provide Petitioner with his weekend of custody for the weekend of September 1, 2006 to September 3, 2006 and counsel for Respondent indicated that Respondent would not comply with the Order. 8. Until August 11, 2006, when Respondent began refusing to allow contact between the child and Petitioner, during the school year, Petitioner's weekend period of custody and his week day periods of custody began by Amy going to Respondent's home on the school bus, as this is the same school bus hat is used by Petitioner's son, who is in Petitioner's sole custody. 9. Petitioner has not been advised by Respondent of who is providing care for Amy after school during periods of time that Petitioner is to have custody and, since the parties' separation, Respondent has used at least four different childcare arrangements for Amy after school. 10. Since Petitioner does not know Amy's whereabouts after school and Respondent has failed and refused to communicate this information to him, and has failed and refused to communicate to Petitioner Respondent's work schedule, Petitioner has no means of making arrangements to pick up Amy from whatever childcare arrangements have been established by Respondent. 11. Respondent, without any basis whatsoever, has threatened Petitioner with the filing of a Protection from Abuse action, which causes Petitioner great fear, as Respondent has made false claims of abuse in the past and Petitioner anticipates that if he is in the vicinity of the Respondent or her home, she will make these false claims of abuse again in order to secure a Protection from Abuse Order. 12. While Petitioner understands Respondent continues to work at the same establishment of where she worked on February 6, 2006, when the Order was entered and continues to have the same work hours, Respondent has failed to provide Petitioner with information as to evenings when she is working, which was to be the days when Petitioner had custody of the child for the evening and for an overnight during the week. 13. Petitioner is deserving of make-up time and should be afforded additional time to make-up for the periods of time that he lost with his daughter. 14. Respondent, who is in willful violation of the Court Order, should be obligated to pay counsel fees and expenses associated with the filing and prosecution of the within Petition for Contempt. 15. Petitioner should be awarded attorneys fees and costs that he has incurred in these proceedings, to be paid by the Respondent. Wherefore Petitioner requests you Honorable Court to enter an Order finding the Respondent in Contempt, ordering make-up time for lost custodial time, ordering Respondent to compensate Petitioner for his costs and attorney fees associated with this proceeding, Ordering Respondent to post a bond to assure her compliance with this Order in the future and Order such other relief as the Court deems just and proper. Respectfully submitted, 200 ri e, Esquire orney for etitioner 4V- North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 VERIFICATION I verify that the statements made in the foregoing document 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 unworn falsifications to authorities. DATE: ?//CZ/00 RALP ZORN61 M RALPH B. ZORN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ROBIN E. ZORN, NO. 2005-5349 CIVIL TERM Defendant IN CUSTODY ORDER OF COURT j ._ a;„.. . AND NOW, this ?O day of 2006, following,,the presentation of the parties' agreement in open Court, it is hereby ORDERED AND DIRECTED as follows: Ralph B. Zorn ("Father") and Robin E. Zorn ("Mother") shall have shared legal custody of their child, Amy Zorn ("Amy"), born August 10, 1996. 2. Mother shall have primary physical custody of Amy. 3. Father shall have periods of physical custody of Amy on the following schedule: (A) During the school year as follows: (i) Every other weekend from after school on Friday until 7:30 p.m. on Sunday; (ii) One evening per week during the weekdays from after school until Father delivers Amy to school the following morning; and (iii) One evening per week from after school until the end of Mother's workday. (iv) At other times as the parties may agree. It is understood that the weekday periods of custody are to routinely coincide with evenings when Mother is working. (B) During the summer vacation months, the parties will alternate physical custody of Am EXHIBIT basis with the party who otherwise would have the first weekend of custody after the school year has ended, retaining custody from that Friday evening until the following Friday at 6:00 p.m. The other party shall then secure custody and retain custody until the following Friday at 6:00 p.m. The parties shall then alternate retaining custody on a weekly basis with exchanged occurring on Fridays at 6:00 p.m. throughout the summer months a? C'nd', -S -Me- I as 7- Fr • oto -j beta, c s c l oo l 6ea ^s - -4, F? (k - p^ 4 The parties will share custody of Amy on holidays by alternating the following J holiday for the period from 9:00 a.m. to 6:00 p.m.: Easter Sunday, Memorial Day, the 4`h of July, Labor Day and Thanksgiving. Father shall have custody of Amy for Easter Sunday 2006 and the parties will alternate the named holidays from that point forward, such that Father shall have Easter Sunday, the Fourth of July and Thanksgiving, and Mother shall have Memorial Day and Labor Day in 2006, and all even numbered years. Mother shall have custody on Easter Sunday, the Fourth of July and Thanksgiving and Father shall have Memorial Day and Labor Day in 2007 and all odd numbered years. 5. During the Christmas holiday season, the parties shall alternate physical custody between the following two periods: a.) From 9:00 a.m. on Christmas Eve until 1:00 p.m. on Christmas Day; and b.) From 1:00 p.m. on Christmas Day until 5:00 p.m. on December 26. Mother shall have the first period and Father shall have the second period for Christmas 2006 and all even numbered years thereafter. Father shall have the first period and Mother shall have the second period for Christmas 2007 and all odd numbered years thereafter. In addition, the party who has the second Christmas 2 period set forth above shall also have custody of Amy on New Year's Eve for the period from 9:00 a.m. on December 31, until 12:00 Noon on January 1. 6. Amy shall always be with Mother on Mother's Day and with Father on Father's Day a? for the period from 9:00 a.m. until 6:00 p.m. on those 4ftftwdays. 7. The parties shall share responsibility for transportation by the party who is securing i custody providing the transportation for the custody exchange. 8. The parties shall keep each other advised in the event of serious illness or medical emergency concerning the child and shall further take any necessary steps to ensure that the health and well-being of the child is protected. During such illness or medical emergency, both parties shall have the right to visit the child as often as he or she desires consistent with the proper medical care of the child. 9. Neither party shall do anything which may estrange the child from the other party, injure the opinion of the child as to the other party, or which may hamper the free and natural development of the child's love and affection for the other party. 10. This Court retains jurisdiction of this matter. Dis ution: adley L. Griffie, Esquire Attorney for Plaintiff Diane G. Radcliff, Esquire Attorney for Defendant TRUE COP'S' F OM RECORD to TsdbmW whereof, I here unto St M waRd MW N UW C9un at Cyr" iP 3 _- -? Prothonowre Edward E. Guido, J. RALPH B. ZORN, V. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROBIN E. ZORN, NO. 2005-5349 CIVIL TERM Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire, hereby certify that I did, the 4Z, P1day of { t? 2006, cause a copy of Plaintiff s Petition for Civil Contempt for Diso edience of Custody and Partial Custody order to be served upon Defendant by serving his attorney of record, Dianne G. Radcliff, Esquire, by first-class mail, postage prepaid at the following addresses: Dianne G. Radcliff, Esquire Attorney for Defendant/Respondent 3448 Trindle Road Camp Hill, PA 17011 DATE: fa. 0 G riffle, Esquire A r ey for Petitioner GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 r-<? ,? ,, -?, ,??, p } Y? C A _ -? ? .s r ? 1 y? V? ? N t».? -... `? ? .3i c.a ti . ,. p. 'mot ,? J ? Cy,?7 '?^`? P RALPH B. ZORN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. ROBIN E. ZORN : NO. 2005 - 5349 CIVIL TERM ORDER OF COURT AND NOW, this 13TH day of SEPTEMBER, 2006, this contempt petition is to be listed before a custody conciliator as soon as practical in accordance with the local rules of court. .14radley L. Griffie, Esquire For the Plaintiff/Petitioner ,16ianne G. Radcliff, Esquire For the Defendant/Respondent y /I:z By the Court, Edward E. Guido, J. xl Cl\ Court Administrator :sld RALPH B. ZORN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 05-5349 CIVIL ACTION LAW ROBIN E. ZORN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, September 19, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, October 17, 2006 at 9:30 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. 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 scheduled hearing. FOR THE COURT. By: /s/ Jacqueline M. Verne Es q. 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 32 South. Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 10 Loe V!NVATSi4N ld S < 61 :11 WV N d3S 900Z KdViCNCi-#iCdd 3.41 dO OCT 3 12006 RALPH B. ZORN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-5349 CIVIL ACTION - LAW ROBIN E. ZORN, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 31St day of October, 2006, the Conciliator, having been advised that the Petitioner has withdrawn his Petition for Contempt, hereby relinquishes jurisdiction in this matter. FOR THE COURT, A.V acq line M. Verney, Esquire, stody Conciliator U-) co L. l + i f= t,? N RALPH B. ZORN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ROBIN E. ZORN, NO. 2005-5349 CIVIL TERM Defendant IN CUSTODY To Prothonotary: PRAECIPE Please withdraw the Petition for Special Relief and Contempt filed by Plaintiff, Ralph B. Zorn, Jr., in the above captioned matter. Date: (yp Z4 y iffie, Esquire A torn y f r Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 f"i r,J C --Q RALPH B. ZORN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. ROBIN E. ZORN, To Prothonotary: Defendant CIVIL ACTION - LAW NO. 2005-5349 CIVIL TERM IN CUSTODY PRAECIPE Please withdraw the Petition for Special Relief and Contempt filed by Plaintiff, Ralph B. Zorn, Jr., in the above captioned matter. Date: r ? ? 1 U Otey c Piaintif7?v FI E & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 - 4`? t'?? <-^ C.:'? - ?. ?-:' t _y G `' '? ?<. -, ?? -?., .?.- ? ''? .,.-• ?.? t ?`. & • :w Re: Passport Agreement gyre' ad By: 'Of Diane G. Radcliff, Esquire 3448 Trindle Road, Camp Hill, PA 17011 SUpreme Court ID # 32112 Phone: 717-737-0100; Fax: 717-975-0697 Email: dianeradcliff @comcast.net Attorney for Robin E. Zorn IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RALPH B. ZORN, JR. Plaintiff NO. 20C5-5349 CIVIL ACTION - LAW V. ROBIN E. ZORN, Defendant IN CUSTODY STIPULATION AND AGREEMENT AND NOW, this ?U'day of , 2007, the Plaintiff, Ralph B. Zorn, Jr. and the Defendant, Robin E. Zorn, ereby s ulate and agree as follows: 1. Upon request of Defendant, Robin E. Zorn, a passport shall be secured for the Child, Amy Zorn. 2. To secure that passport, the parties and the child, Amy Zorn, shall arrange through counsel and, pursuant to those arrangements, shall meet at the Cumberland County Prothonotary's Office to sign the passport application. 3. The parties will execute any and all other documents to effectuate the terms of this Stipulation and Agreement. IN WITNESS WHEREOF, Ralph E. Zorn, Jr., intending to be legally bound hereby, has set his hand and seal the day and year below written. (SEAL) Witne as to WBorn 4 Dated: , Jr. Ralph .Zorn, r. _::2_ -7 b(D7 Dated: 7?(_ 7 - 1 - 4 ' v\ Prepared By: y Diane G. Radcliff, Esquire '.3448 Trindle Road, Camp Hill, PA 17011 Supreme Court ID # 32112 Phone: 717-737-0100; Fax: 717-975-0697 Email: dianeradcliff @comcast.net Attorney for Robin E. Zorn IN WITNESS WHEREOF, Robin E. Zorn, intending to be legally bound hereby, has set her hand and seal the day and year below written. c? W1 ness to Robin E. Zorn Dated: Z.f 0 G ??-(SEAQ Robin E. Zorn Dated: 1--2- (tr-1 -2- N C 1 ? ? 'r ? .?-t F ( :, ?"w? _ .. i :; , i., n !?? .??_ k.?.J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RALPH B. ZORN, NO. 2005-5349 Plaintiff CIVIL ACTION - LAW V. IN CUSTODY ROBIN E. ZORN, Defendant PETITION FOR EMERGENCY RELIEF/CUSTODY AND NOW, comes the Petitioner, Robin E. Zorn, by her attorney, Diane G. Radcliff, Esquire, and files the above referenced Petition, and represents that: 1. This is a custody case. This Petition involves a request for an order for the retrun of custody of the subject child to Petitioner. 2. The following attorneys have entered their appearances in this case: (a) Bradley L. Griffie, Esquire for Plaintiff /Respondent; (b) Diane G. Radcliff for Defendant/ Petitioner . 3. A copy of this Petition was faxed to Respondent's legal counsel immediately prior to the filing of this Petition. Said counsel was also called at 10:00 am on December 21, 2009 but because he was not available a voice mail message was left advising him of this filing. 4. The following Judge was previously assigned to this case: The Honorable Edward E. Guido, who entered the February 6, 2009 Custody Order attached hereto as Exhibit "A". 5. Your Petitioner is Robin E. Zorn, (hereinafter referred to as "Mother"), and is the Defendant in the above captioned custody action. 6. Your Respondent is Ralph B. Zorn (hereinafter referred to as "Father"), and is the Plaintiff in the above captioned custody action. 7. The parties are the parents of a minor child, Amy'Zorn, (hereinafter, the "Child"), born August 10, 1996. 8. On February 6, 2006, an Order of Court was entered by the Honorable Edward E. Guido, in which Mother was granted primary physical custody of the Child, and Father was granted partial physical custody of the Child. A true and correct copy of the 2/6/2006 Order is attached hereto, marked Exhibit "A" and made a part hereof. 9. For approximately two (2) years, Father did not exercise his partial physical custody rights with the Child, but recently after breaking up with his girlfriend he started seeing the child again. -2- 10. Father requested and mother agreed that Father would have the child over the weekend of December 18-20, 2009. 11. On Sunday, December 20, 2009, Father refused to return the child to the custody of Mother. Instead he called Children and Youth claiming Mother has abused the Child because one of her friends was in a motorcycle gang and this frightened the child and because she did not provide enough food in the house for the child. 12. A representative of Children and Youth, "Shelly", told Father that this was not abuse and that he needed to return the Child to the custody of Mother, which he refused to do. 13. Mother was in contact with the police who refused to become involved because this was a "civil matter" telling mother to deal with this situation through her attorney. 14. Father did not take the child to school on December 21, 2009, reporting that the child was being interviewed by Children and Youth today, which Mother confirmed was untrue. 15. An emergency exists because Father refuses to return the Child to Mother's custody as required by the 2/6/06 Order of Court and because the police will not be involved without direction by the Court. 16. As a result of Father's actions aforesaid, Mother has incurred legal fees and costs in an amount of no less than $600.00 and claim is made therefore. WHEREFORE, based on the foregoing, Wife respectfully requests this Honorable Court to enter an Order containing the following terms: 1. Requiring Father to immediately return the Child to the custody of Mother. 2. Directing the Sheriff of Cumberland County or the Carlisle Borough Police Department or any other police department of any jurisdiction in which the Child, Amy Zorn, is located shall obtain custody of the Child, Amy Zorn, from Father, Ralph B. Zorn, and transfer custody of her to Mother, Robin E. Zorn. 3. Requiring Father to pay for all reasonable attorneys fees and costs incurred by Mother in bringing this Petition; 4. For such other and further relief as the Court may deem appropriate. Respectfully submitted, DIANE G. DCLIFF, ESQUIRE 8 Trin le Road Cam I , PA 17011 Phone: (717) 737-0100 Supreme Court ID # 32112 Attorney for Petitioner, Robin E. Zorn - 3 - VERIFICATION I verifies that the statements made in this Petition 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. Robin E. Zorn Date: -4- CERTIFICATE OF SERVICE I hereby certify that I am this day serving the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure: Service by First Class Mail Addressed as Follows: Bradley L. Griffie, Esquire 200 North Hanover Street Carlisle, PA 17013 Phone: 717-243-5551 a Fax: 717-243-5063 (Counsel for Respondent) and by fax to said counsel at: 717-243-5063 DIANE G. DCLIFF, ESQUIRE egistration No 32112) 3448 Trindle Road Camp Hill, PA 17011 Email: dianeradcliff@comcast.net Phone: (717) 737-0100 Fax: (717) 975-0697 Counsel for Robin E. Zorn Dated: 2 - 5 - EXHIBIT "A" 2/6/2006 ORDER OF COURT -6- RALPH B. ZORN, Plaintiff V. ROBIN E. ZORN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2005-5349 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this day of &??_ ?, 2006, following the presentation of the parties' agreement in open Court, it is hereby ORDERED AND DIRECTED as follows: 1. Ralph B. Zorn ("Father") and Robin E. Zorn ("Mother") shall have shared legal custody of their child, Amy Zorn ("Amy"), born. August 10, 1996. 2. Mother shall have primary physical custody of Amy. 3. Father shall have periods of physical custody of Amy on the following schedule: (A) During the school year as follows: (i) Every other weekend from after school on Friday until 7:30 p.m. on Sunday; (ii) One evening per week during the weekdays from after school until Father delivers Amy to school the following morning; and (iii) One evening per week from after school until the end of Mother's workday. (iv) At other times as the parties may agree. It is understood that the weekday periods of custody are to routinely coincide with evenings when Mother is working. (B) During the summer vacation months, the parties will alternate physical custody of Amy on a week-on week-off basis with the party who i otherwise would have the first weekend of custody after the school year has ended, retaining custody from that Friday evening until the following Friday at 6:00 p.m. The other party shall then secure custody and retain custody until the following Friday at 6:00 p.m. The parties shall then alternate retaining custody on a weekly basis with exchanged occurring on Fridays at 6:00 p.m. throughout the summer months)-ac.- Qt EnOt\ r* -Me- I o s j' Fr:. AcA-1 be-t-a, c sc.(,ao k bed .^s :i 4, F.-,t ? . 4 The parties will share custody of Amy on holidays by alternating the following holiday for the period from 9:00 a.m. to 6:00 p.m.: Easter Sunday, Memorial Day, the 0 of July, Labor Day and Thanksgiving. Father shall have custody of Amy for Easter Sunday 2006 and the parties will alternate the named holidays from that point forward, such that Father shall have Easter Sunday, the Fourth of July and Thanksgiving, and Mother shall have Memorial Day and Labor Day in 2006, and all even numbered years. Mother shall have custody on Easter Sunday, the Fourth of July and Thanksgiving and Father shall have Memorial Day and Labor Day in 2007 and all odd numbered years. 5. During the Christmas holiday season, the parties shall alternate physical custody between the following two periods: a.) From 9:00 a.m. on Christmas Eve until 1:00 p.m. on Christmas Day; and b.) From 1:00 p.m. on Christmas Day until 5:00 p.m. on December 26. Mother shall have the first period and Father shall have the second period for Christmas 2006 and all even numbered years thereafter. Father shall have the first period and Mother shall have the second period for Christmas 2007 and all odd numbered years thereafter. In addition, the party who has the second Christmas 2 period set forth above shall also have custody of Amy on New Year's Eve for the period from 9:00 a.m. on December 31, until 12:00 Noon on January 1. 6. Amy shall always be with Mother on Mother's Day and with Father on Father's Day for the period from 9:00 a.m. until 6:00 p.m. on those sIffiW-days. 7. The parties shall share responsibility for transportation by the party who is securing custody providing the transportation for the custody exchange. 8. The parties shall keep each other advised in the event of serious illness or medical emergency concerning the child and shall further take any necessary steps to ensure that the health and well-being of the child is protected. During such illness or medical emergency, both parties shall have the right to visit the child as often as he or she desires consistent with the proper medical care of the child. 9. Neither party shall do anything which may estrange the child from the other party, injure the opinion of the child as to the other party, or which may hamper the free and natural development of the child's love and affection for the other party. 10. This Court retains jurisdiction of this matter. Distribution: Bradley L. Griffie, Esquire Attorney for Plaintiff Diane G. Radcliff, Esquire Attorney for Defendant 3 Qti Edward E. Guido, J. od tk it- ? 5"? b ptf- a5?? 6 TYPE OF PLEADING: PREPARED AND SUBMITTED BY: Petition for Emergency Relief Diane G. Radcliff, Esquire ?p© Attorney for Defendant 0?- ASSIGNED JUDGE Edward E. Guido, Judge APPEARANCES BY ATTORNEYS ATTORNEY FOR PLAINTIFF ATTORNEY FOR DEFENDANT Bradley L. Griffie, Esquire 200 North Hanover Street Carlisle, PA 17013 Phone: 717-243-5551 • Fax: 717-243-5063 Email: BgriffieCgriffielaw.com Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 Phone: 717-737-0100 9 Fax: 717-975-0697 Email: dianeradcliffCcomcast.net IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RALPH B. ZORN, V. ROBIN E. ZORN, Plaintiff Defendant NO. 2005-5349 CIVIL ACTION - LAW IN CUSTODY /r ORDER AND NOW, this r day of 2009, upon consideration of the within hi Petition, IT IS HEREBY ORDERED that: e t n 1. Ralph B. Zorn shall immediately return the Child, Amy Zorn, to the custody of Mother. Ajv W.--- -0'o tee Jo _ Lon" TRM 04-0c q?.. 2. III is tv! . Zorn, ??-? door CIZ /o;do q. 3. 3. by _L? , . .. .... kA THE C EDWARD E. GUIDO, JUDGE DISTRIBUTION TO: 3 Attorney for Petitioner: Diane G. Radcliff, Esquire, 3448 Trindle Rd., Camp Hill, PA 17011 -? Attorney for Respondent: Bradley L. Griffie, Esquire, 200 North Hanover Street, Carlisle, PA 17013 -coP FILE 7- U-?rs; c 2009 DEC 21 NMI 1. 21 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RALPH B. ZORN, NO. 2005-5349 Plaintiff CIVIL ACTION - LAW V. IN CUSTODY ROBIN E. ZORN, Defendant ORDER AND NOW, this )P day of December, 2009, this Court having been advised that the Respondent/ Plaintiff, Ralph B. Zorn has returned the Child, Amy Zorn, to the custody the Petitioner/ Defendant, Robin E. Zorn, upon request of Petitioner's Attorney, Diane G. Radcliff, Esquire, given with the consent of the Respondent through counsel, Sean Shultz, Esquire, IT IS HEREBY ORDERED that the hearing scheduled for December 22, 2009 at 10:00 a.m. is cancelled and all issues raised in the Emergency Petition are deemed to be resolved. EDWARD E. GUIDO, JUDGE DISTRIBUTION TO: Attorney for Petitioner: Diane G. Radcliff, Esquire, 3448 Trindle Rd., Camp Hill, PA 1701 despondent: Ralph B. Zorn 1039 Northfield Drive, Carlisle, PA 17013 eo ES i-n? tL L i 1 ?.??.3 !off l CLOQ Q -IK? PROTNNO Tl{Ry pfF=CE 1Jecem?eR q, a 00 9 st RALPH B. ZORN, Plaintiff VS. ROBIN E. ZORN, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 2005-5349 CIVIL TERM : IN CUSTODY : JUDGE EDWARD E. GUIDO PRAECIPE As there are no pending matters or proceedings in the instant custody action, please withdraw my appearance previously entered in these proceedings on behalf of the Plaintiff, Ralph B. Zorn. DATE: _],. b y )09 Gri ' , Esquire 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 ?i.n? fl r?Ct+ p [, c? t 4u?7 L.?LE? ?U i ! i i..' ?f