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HomeMy WebLinkAbout06-2355 David F. Tamanini, Esquire Attorney 1.0. No. 27775 T AMANINI LAW OFFICE 4800 LiNGLESTOWN ROAD, SUITE 309 HARRISBURG, PENNSYLVANIA 17112-9507 Telephone (717) 541-1805 dft@TamaniniLaw.com Attornel' for Plaintiff, Tracy A Daihl TRACY A. DAIHL, PLAINTIFF v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ()l" -,J.is:5' C{~Lt~~ MICHAEL L. DAIHL, DEFENDANT CIVIL ACTION LAW - DIVORCE NOTICE TO DEFEND AND CLAIM RIGHT~ YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Room 101, Dauphin County Courthouse, Front and Market Streets, Harrisburg, PA IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone Number (717) 249-3166 TRACY A. DAIHL, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. MICHAEL L. DAIHL, DEFENDANT CIVIL ACTION LAW - DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with S 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Dated: j/;q/!J~ f Respectfully, _ ~D 'dFT' "E .~ aVI . amanlnl, squire Attorney 10 No. 27775 4800 Linglestown Road, Suite 309 Harrisburg, PA 17112 (717) 541-1805 Attorney for Plaintiff David F. Tamanini, Esquire Attorney 1.0. No. 27775 T AMANINI LAW OFFICE 4800 LINGLESTOWN ROAD, SUITE 309 HARRISBURG, PENNSYLVANIA 17112-9507 Telephone (717) 541-1805 dft@TamaniniLaw.com Attorney for Attorney for Plaintiff, Tracy A Daihl TRACY A. DAIHL, PLAINTIFF v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0/_ - ";;>.l~S C{;JLt~&L~ MICHAEL L. DAIHL, DEFENDANT CIVIL ACTION LAW - DIVORCE COMPLAINT IN DIVORCE UNDER SECTIONS 3301{c) AND 3301(d) AND NOW comes the Plaintiff, Tracy A Daihl, by and through her attorney, David F. Tamanini, Esquire, and files this Complaint in Divorce and in support thereof avers the following. COUNT I - DIVORCE 1. The Plaintiff is Tracy A Daihl, who currently resides at 2001 Rupley Road, Apt. 102, Camp Hill, Pennsylvania. 2. The Defendant is Michael L. Daihl, who currently resides at 4531 Rolo Court, Mechanicsburg, Pennsylvania 17055. 3. Both the Plaintiff and the Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 8, 1996, in Monroeville, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties during the current marriage. 6. The marriage is irretrievably broken. 7. Neither Plaintiff nor Defendant is in the military service. 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 this Honorable Court to enter a Decree of Divorce. COUNT II - CUSTODY 9. The Plaintiff incorporates by reference Paragraphs 1 through 8 of the Complaint as though more fully set forth herein. 10. The Plaintiff avers that there are children of the parties under the age of 18. Ashley Daihl Dustin Daihl Brandon Daihl Age 14 Date of Birth: 5/6/91 Age 11 Date of Birth: 11/23/94 Age 9 Date of Birth: 7/21/96 11. Plaintiff seeks shared legal and physical custody of the minor children. 12. Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the children in this or any other court. 13. The Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth. 2 14. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children, or claims to have custody or visitation rights with respect to the children. 15. 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. There are no other persons known to have or claim a right to custody or visitation of the children and therefore, no further notice of the pendency of this action and the right to intervene shall be given, other than to the parties named herein. 16. The best interest and permanent welfare of the children will be served by granting shared legal custody of the children to the parents and principal custody of the children to the Plaintiff, mother. WHEREFORE, Plaintiff requests this Honorable Court to enter an Order granting shared legal custody of the children with both parents and principal physical custody with the Plaintiff, mother. Respectfully Submitted, Date: tj/;q/o t / I ~f2~F T. E~ aVI . amanlnl, sqUire Attorney 10 No. 27775 4800 Linglestown Road, Suite 309 Harrisburg, PA 17112 (717) 541-1805 3 VERIFICATION I verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. Date: tf/I'1/0& /~. 1+. :DcdJ' TRACY A AIHL () ~ -Ie.;. ;:J R-J n ~ - ('- ~~ _.t if- 9-J :---C> - 6"- C) ~b ~ i \) \) --t:: - ~ p~ )D I " }n ~~ ---r.... David F. Tamanini, Esquire Attorney I. D. No. 27775 T AMANINI LAW OFFICE 4800 LiNGLESTOWN ROAD, SUITE 309 HARRISBURG, PENNSYLVANIA 17112-9507 Telephone (717) 541-1805 dft@TamaniniLaw.com Attorney for Plaintiff, Tracy A Daihl TRACY A. DAIHL, PLAINTIFF v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Ot- - :A 3 5~"" MICHAEL L. DAIHL, DEFENDANT CIVIL ACTION LAW - IN CUSTODY MOTION FOR CUSTODY HEARING AND ASSIGNMENT OF A CUSTODY CONCILIATOR AND NOW comes Plaintiff, Tracy A Daihl, by and through her attorney, David F. Tamanini, requests a custody hearing and the assignment of a Custody Conciliator. 1. A Divorce Complaint has been filed, containing a Count in Custody. WHEREFORE, the Plaintiff, Tracy A Daihl, respectfully requests that this Honorable Court grant the Motion for a Custody Hearing and Assignment of a Custody Conciliator, and list the matter for a hearing and assign a Custody Conciliator. Respectfully submitted, Date: 'I /J r/ 01.0 I / By: 71,~ David F. anini, Esquire Attorney 10 No. 27775 4800 Linglestown Road, Suite 309 Harrisburg, PA 17112 (717) 541-1805 Attorney for Plaintiff C:,' TRACY A. DAlHL PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 06-2355 CIVIL ACTION LAW MICHAEL L. DAIHL DEFENDANT IN CUSTODY ORDER OF COURT AND NOW. Monday, May 08, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courtbouse, Carlisle on Friday, June 02, 2006 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. Fai]ure 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 hearinl!, FOR THE COURT. By: Is! Hubert X. Gilroy, Esq. Custody Conciliator p- The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabi]ites 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 -~~-H. ~~~ ~~'$ ~-'~ 1Z ~.,~y ~Jt; ~~p .~ ~ $ ~ ;4p.~ '7(J!3.p , I/IN\fA1ASNN3d )JNnm (fi i'1lH38V'jn:) OO:CWd 9-AVW900l Al:N10NOH1OOd 3Hl:lO 3D1:Ho-a3ll:l "r t v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2355-CV TRACY A. DAIHL, PLAINTIFF MICHAEL L. DAIHL, DEFENDANT CIVIL ACTION LAW - DIVORCE PROOF OF SERVICE I, David F. Tamanini, attorney for the Plaintiff in the above-captioned matter, hereby certify that a copy of the NOTICE TO DEFEND AND CLAIM RIGHTS and the COMPLAINT UNDER SECTION 3301 (c) OR 3301 (d) OF THE DIVORCE CODE were served upon the Defendant at the following address below by depositing the same in the United States mail, Certified Mail No. 7004 1160 0004 4854 5340, Restricted Delivery, Return Receipt Requested on the 1st dav of Mav. 2006. As indicated by the green return receipt card attached hereto, the above referenced documents were received by said Defendant on 5'- Lf - )..-6 0 b Michael Lee Daihl 4531 Rolo Court Mechanicsburg, PA 17055 Respectfully, ~~ David F. Tamanini, Esquire Attorney ID No. 27775 4800 Linglestown Road, Ste. 309 Harrisburg, PA 17112 (717) 541-1805 Attorney for Tracy A. Daihl Dated: '5- L & - ?-OO to , - \ .. ..,.; · CornpIete Items 1, 2, and 3. Also complete Item 4 If Restricted Delivery Is desired. · Prtnt your name and address on the nwerse so that we can return the card to you. · Attach this card to the back of the mailplece, or on the front If space permits. 1. Article Addressed to: (Y\;c.Y\o..~\ l ~~ D~: h 1 45~\ ~o\o Cou..r t Mec...\-)~(\ic~~""j ~I\ ''l055 3. SeMce 1YPe 'D( Certifted MaH D ExpI8SS Mall D Registenld D Retum Receipt for Mert:har1cbe D Insured Mall D C.O.D. 4. Restricted Delivery? (Extra Fee) 2. Article Number (Ttansfer from BtIIVice IebeI) PS Form 38111 ~ 2004 7004 1160 0004 4854 5340 00meiIIIc AeUn F'-ipt 1~1540 o c: -offl ~rn z:O en s;: ,.... c:: c:: 0' ::a :r:a - '..) ":./ :,;;:! f-11 ~ ~~'"'1 [1-; ;-,,) l::; ':,~~~~:' :5:D --~o 2~m ~ -< -....: _.; ( ,'~ (:::> ,- ....... ; ~. , o ~ TRACY A. DAIHL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-2355 CIVIL TERM MICHAEL LEE DAIHL, Defendant : IN CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE To Curtis R. Long, Prothonotary: Please enter my appearance on behalf of the Defendant, Michael Lee Daihl, in the above captioned case. Respectfully submitted, .... Je a olst, Esquire i enn Legal Services 01 E. Louther Street Carlisle, PA 17013 (717) 243-9400 Date: 5. \<1.<Dv .. . . > -) TRACY A. DAlHL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-2355 CIVIL TERM MICHAEL LEE DAlHL, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for the Defendant, Michael Lee Daihl, hereby certify that I have served a copy of the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following date and in the manner indicated below: U.S. First Class Mail. Postage Pre-Paid David Tamanini, Esquire 4800 Linglestown Road - Suite 309 Harrisburg, PA 17112-9507 Date: 5, ,t;, Ol. Jessi a olst, Esquire Mi enn Legal Services 401 E. Louther Street Carlisle, P A 17013 (717) 243-9400 (") C :;.;:; .:.'::11., 7r" --I .-< ( ~ <::::) = CT'> ::E: :r.. -< o "TI ~ m:D -0 hi :00 C) I ;-l::!~} CJ :!l ~?O C5ril ,-1 .J> Xl -< \.0 -0 :::I;: N c...: TRACY A. DAlliL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VI. : NO. 06-2355 CNIL TERM MICHAEL L. DAlliL, Defendant CUSTODY STIPULATION FOR ENTRY OF AN AGREED ORDER OF CUSTODY ~ AND NOW, this ~day of June, 2006, the plaintiff (hereinafter "Mother") and the defendant (hereinafter "Father"), having reached an agreement regarding custody and the best interest and welfare oftheir minor children, they hereby stipulate and agree as follows: 1. Legal Custody: The parties will share joint legal custody of Ashley Daihl, born May 6, 1991, age 15; Dustin Daihl, born November 23, 1994, age 11; and Brandon Daihl, July 12, 1996, age 9. The parties agree that major decisions concerning their children, including, but not necessarily limited to, the children's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the children's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the children. Each party agrees not to attempt to alienate the affections of the children from the other party. Each party shall notify the other of any activity or circumstance concerning their children that could reasonably be expected to be of concern to the other. Day-to-day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. ~5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent authorized by statute. Mutual agreement should be made, in advance, regarding the following matters: enrollment or termination in a particular school or school program, advancing or holding the children back in school, authorizing enrollment in college, authorizing their children's driver's license or purchase of an automobile, authorizing employment, authorizing any child's marriage or enlistment in the armed forces, approving a petition for emancipation, authorizing foreign travel, passport application or exchange student status. 2. Primary physical custody of the minor children Ashley Daihl and Brandon Daihl shall be with Mother. Temporary physical custody for the purposes of visitation shall be with Father. Each parent shall have all of the children every other weekend from Friday at 6:00 p.m. until Sunday at 8:00 p.m. The first weekend of this schedule shall begin the Sunday before school starts for the new academic year and shall alternate weekly thereafter until the Sunday when the academic year ends. Primary physical custody of the minor child Dustin Daihl shall be with Father. Temporary physical custody for the purposes of visitation shall be with Mother. The parties intend to parent the children with friendly cooperation and in a spirit of compromise and flexibility. Any conflicts will be governed by the Agreement, should any occur. With respect to sporting activities for the children, the parents agree that organized sports are beneficial to the children. The parents will agree to all reasonable sporting activities as has been done in the past. If any children are involved in local teams, the parents will cooperate in transporting the children. When with Mother, she will arrange transportation to all games in the local league when she is able. Father may also transport, one or more children, upon agreement or when there are conflicts among the children's games and/or activities. When Father has the children for temporary physical custody, he shall be the primary transporter of the children and Mother may also transport upon agreement or conflicts of the children's schedules. Ifboth parents cannot agree on transporting any children participating in travel teams, the parent that enables or initiates the travel team participation shall be the primary transporter to all games. The other parent will try to be available for backup transportation. 3. The parent with physical custody during any given period oftime shall communicate in a prompt fashion with the other parent concerning the well- being of the children, and shall appropriately notify the other parent of any changes in health or educational progress. Each parent shall execute any and all legal authorizations so that the other parent may obtain information from the children's schools, physicians, psychologists, or other individuals concerning their progress and welfare. 4. Holidays: a. Thanksgiving: Every year, Father will have the children on Thanksgiving from Thursday at 10:00 a.m. until Saturday at 8:00 p.m. b. Christmas: In even-numbered years, Father shall have the children from Christmas Eve at 6:00 p.m. until Christmas Day at 1 :00 p.m. Mother shall have the children from 1 :00 p.m. Christmas Day until December 29th at 9:00 p.m. Thereafter, during the remainder of the Christmas week, the children will be with Father until January 1 st at 9:00 p.m. Mother and Father will reverse this arrangement in odd- numbered years. c. Easter: Mother will have custody of the children on Easter from 6:00 p.m. on Friday until 9:30 p.m. on Sunday. d. Mother will have physical custody of the children on Mother's Day and Father will have physical custody of the children on Father's Day. On either day, the parent shall have the children from 10:00 a.m. until 8:00 p.m. e. Children's Birthdays: Mother will have custody of the children on their birthdays in even-numbered years and Father will have custody of the children on their birthdays in odd-numbered years. f. The holiday schedule outlined above will take precedence over the regular custody schedule. All other holidays not outlined above are subject to the regular custody schedule or other agreement of the parties. 5. Summer: The parties shall follow a shared custody arrangement during the summer months on a week on/week offbasis. The summer schedule shall begin the Sunday following the end of the academic year and will end the Sunday before the beginning ofthe new academic year. With thirty (30) days notice, each parent shall be allowed to choose a two- week summer vacation time period with the children. Mother shall have the first choice in even-numbered years and Father shall have the first choice in odd-numbered years. 6. The parents shall organize ways for their children to maintain their friendships, extracurricular activities, and other special interests, regardless of which household they may be in. It is also suggested that toys, clothes, etc., not become matters of contention. Major gifts should be discussed and coordinated between the parents. 7. The parents shall permit and support the children's access to all family relationships. Special family events such as weddings, family reunions, family gatherings, funerals, graduations, etc., shall be accommodated by both parties with routine visitations resuming immediately thereafter. Each parent shall have the option of proposing time and date variations to the other parent when special recreational options or other unexpected opportunities arise. Each parent must confer with the other parent before arranging regularly occurring extracurricular activities for the children which might interfere with regular visitation. 8. Each parent will exercise care in screening babysittinglchildcare providers. Each parent should have the right to veto over childcare providers. The telephone numbers of these providers will be provided to both parents. Parents should provide one another with a phone number and address where the children may be contacted at all times whenever reasonably possible. This principle applies to situations such as vacations and overnights with friends. Each parent should be promptly and politely responsive to the other parent's telephone calls. Each parent shall have the right to first refusal to provide childcare during the weekend if the custodial parent must work. If the non-custodial parent is available to care for the children while the custodial parent is working, the children will be returned at the end of the parent's work shift. 9. Should either party have the children spend overnight at a place other than their primary residence, the other parent will be given the address and phone number. 10. During any period of custody or visitation, the parties to this Order shall not possess or use any controlled substance, nor shall they consume alcoholic beverages to the point of intoxication, nor smoke cigarettes inside the residence or vehicle. The parties shall likewise assure, to the extent possible, that other household members and/or houseguests comply with this prohibition. 11. Telephone contact: Each parent shall be entitled to reasonable telephone contact with the children, which shall not be excessive, as well as daily contact via e-mail with the children when in the custody ofthe other parent. 12. Neither parent shall permanently relocate if the relocation would necessitate a change in the visitation schedule or if the relocation would result in a change of school for the children or exceed twenty-five (25) mile radius without a minimum notice of ninety (90) days to the other parent. The ninety (90) day notice is designed to afford the parents an opportunity to renegotiate the custodial arrangements or to have the matter listed for a Court hearing. 13. No Conflict Zone: Each parent should agree to refrain from encouraging the children to provide reports about the other parent. Communication should always take place directly between the parents, without using the children as an intermediary. Each parent should encourage their children to send the appropriate holiday cards to the other parent. 14. The parties shall be entitled to custodial time outside the parameters ofthis Agreement so long as the parents agree to such changes or additions to the regular custody schedule. The parties also recognize that by agreement, they may make any changes, alterations or additions to any portion of this Agreement. In the case of a disagreement regarding such changes, the parties shall follow the custody schedule as outlined in this Agreement. t 1 {. . WHEREFORE, the parties request that this Honorable Court confirm this Stipulation in an Order Confirming Custody. Respectfully submitted: /~ f;.~ TRAC DAIHL ~\~ MIC EL L. DAIHL 'I , David F. Tam ini, Esquire 4800 Linglestown Road Harrisburg, P A 17112 (717) 541-1805 Attorney for Plaintiff les ca Holst, Esquire Mi Penn Legal Services 401 East Louther Street Carlisle, P A 17013 (717) 243-9400 Attorney for Defendant o c r.....) (:.,:) .;;:::::'") 'ooi" o ." ...... ft?1 :-1"1 '- - , N C_,".~ _.~--. -ry -...'. _.J..... I"....) .r;- TRACY A. DAIHL, Plaintiff v MICHAEL L. DAIHL, Defendant AND NOW, this ~y. \ , JUN 1 2 2006 \ IN THE COURT OF COMMO :~,=,.~ CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-2355 IN CUSTODY COURT ORDER have reached an agreement, the Conciliator relinquishes jurisdiction. day of June, 2006, The Conciliator being advised the parties Hubert X i1roy, Esquire Custody onciliator C) '" 0 = i'; = "l, "'" '-- X.." c:: ...,~ rnp'- '.-:Jm ~, r-~ c...> ;,.)' 1- ~::) "1') --'7-'_ ""<:'5 '';>? CjiTI ~:;;! W "'ij '-< r---.--- - . T..'~.'..',,,!,-<--' .r-,,_ ';:~="-~:-'~~~-..'~':~-:--_-:-':':"- ....~~~J~ .."" \, .: k' \ /'-"1 < JUN 1 ::I 2006 :--.-"/ .~-~~~ c -5 TRACY A. DAIHL, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-2355 CIVIL TERM MICHAEL L. DAIHL, Defendant : CUSTODY ORDER ~~ AND NOW, this \'1 day of June, 2006, on consideration of the attached Stipulation for Entry of an Agreed Order of Custody, it is hereby ORDERED and DECREED that the terms and conditions ofthe aforementioned stipulation are hereby entered as an Order of Court. BY THE COURT: J. ~ ; --, .'.~; ~/\~ C\ 8 \ \ ,0\ W4\1 \ ltnr qG[)2 ~ U\-II "'1'\1'-, "." 1 -:1\ J' :In I\O~.L.U\ AJ,'LL".I'-.I:J :Jnl U 3:)\:\:'0-031\:\ . . \ David F. Tamanini, Esquire Attorney 1.0. No. 27775 T AMANINILAW OFFICE 4800 lINGLESTOWN ROAD, SUITE 309 HARRISBURG, PENNSYLVANIA 17112-9507 Telephone (717) 541-1805 dft@TarnaniniLaw.com Attorney for Plaintiff, Tracy A. Daihl TRACY A. DAIHL, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2355 v. MICHAEL L. DAIHL, DEFENDANT CIVIL ACTION - DIVORCE PRAECIPE TO WITHDRAW APPEARANCE AND ENTER APPEARANCE PRO SE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please withdraw my appearance on behalf of the Plaintiff, Tracy A. Daihl, in the above-captioned matter. Respectfully, TAMANINI LAW OFFICE Dated: :i4?~ David F ~Tama ini, Esquire Supreme Court 1.0, No. 27775 4800 Linglestown Rd., Suite 309 Harrisburg, PA 17112 (717) 541-1805 Please enter me as a party pro se (representing myself) in the above-captioned matter, and consenting to withdrawal of my counsel. Respectfully, llltJ!6(; DATE' . ;J~ f} '~ T CY A. :A.IHL . . ) ,~ v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2355 TRACY A. DAIHL, PLAINTIFF MICHAEL L. DAIHL, DEFENDANT CIVIL ACTION - CUSTODY CERTIFICATE OF SERVICE I, David F. Tamanini, Esquire, attorney for the Plaintiff, hereby certify that I, on this day, served a copy of the foregoing Praecipe to Withdraw My Appearance and Enter Appearance Pro Se on the following person, at the address below, by depositing a true and correct copy of the same in the United States mail, first class, postage prepaid: Jessica Holst, Esquire MidPenn Legal Services 401 E. Louther Street Carlisle, PA 17013 TAMANINI LAW OFFICE Dated: -=:L1g..'11 0," BY:~~~ avid F. Tam "ni, squire- Attorney 1.0. 27775 4800 Linglestown Road, Suite 309 Harrisburg, PA 17112 (717) 541-1805 -"il :-::-.1 i_-.,-. ,-ni::' '-"." (); r-J (";. ("