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HomeMy WebLinkAbout91-134491- 13'F~ Archie T Shroud ~ ~S L...«urQ A. Swop G1.1I -~ilings Prior -~o J May q, aoo[~ have NDT- been scanned ARCHIE T. STROUD, III, 1N THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW NO.91-1344 LAURA A. SWOPE, Defendant IN CUSTODY ORDER AND NOW, this 4 ~ day of May, 2006, following hearing and reflection upon the testimony adduced, it is directed that, pending further order, the order of February 22, 2006, shall remain in full force and effect. It is noted that said order suspends any rights of overnight partial custody of Robie Marie Stroud, born August 8, 1990. Any future application to this court by the defendant, for overnight partial custody, should include a psychiatric evaluation of Laura Swope by a qualified psychiatrist who will be available to be examined by father's attorney and by the court at a hearing in Cumberland County, Pennsylvania. The psychiatric evaluation shall indicate whether Laura Swope suffers from any disorder that would negatively impact her ability to responsibly exercise her parental responsibilities during overnight partial custody of her daughter. BY THE COURT, -~ - ~~ Kevin .Hess, J. ~ylor Andrews, Esquire . For the Plaintiff /L~aura A. Swope, Pro Se ~ 19617 Meridian Street Cornelius, NC 28031 \, ,~ 1,~'f!"v ~'i1`~ ~f"~~J ~c~ ~ Z ~ZI Wd b- ~t ~W 9001 ~10N~}~1C~~d ~0 1 ARCHIE T. STROUD, III, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW NO. 91-1344 LAURA A. SWOPE, Defendant IN CUSTODY ORDER AND NOW, this 5' ~ day of May, 2006, following hearing and reflection upon the testimony adduced, it is directed that, pending further order, the order of February 22, 2006, shall remain in full force and effect. It is noted that said order suspends any rights of overnight partial- custody of Robie Marie Stroud, born August 8, 1990. Any future application to this court by the defendant, for overnight partial custody, should include a psychiatric evaluation of Laura Swope by a qualified psychiatrist who will be available to be examined by father's attorney and by the court at a hearing in Cumberland County, Pennsylvania. The psychiatric evaluation shall indicate whether Laura Swope suffers from any disorder that would negatively impact her ability to responsibly exercise her parental responsibilities during overnight partial custody of her KEVt A. IiESS DGE ONE COU OUSE SpUARE ;ARLISLE, PENNSYLVANIA 17013 ~- 09'06 n~+ ~~ ~ ~`c Laura A. Swope ~ \ 19617 Meridian Street Cornelius, NC 28031 c O" .y~..y~ n +s, ~. r+~^y e} .tint.: G~iV._i~;y rL~ ti VSiE ^ INSUFFICIENT ADDRE$8 ^ ATTEMPTED NOT KNOWN ^ OTHER ^ NO SUCH NUMBER/ STREET ~ NUNABLE TO FORWARDADDRESSED ~:rr~~~~ tr~~Jrr! rtri~~rif~ut~rr r t~,srr~r ~rr~~r~t~ttjil»~r~rr~ Suzanne Spencer Abel, Esq. 22 East Street, #6 Mt. Holly Springs, PA 17065 (717) 323-0046 spencer abet esq~fastmail.fm IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAURA SWOPE, Petitioner 91-1344 CIVIL TERM v. ARCHIE T. STROUD, III, CIVIL ACTION -CUSTODY Respondent NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court wi#hout further no#ice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 Aviso USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mks adelante en las siguientes paginas, debe tomar accibn dentro de los prbximos veinte (20) dial despubs de la notificacibn de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presen#adas aqui en contra suya. Se le advierte de que si usted falls de tomar accibn Como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier sums de dinero reclamada en la demands o cualquier otra reclamation o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mfis aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes pars usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-31 g6 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Gommon Pleas of Dauphin County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at 717-255-2796. A11 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAURA SWOPE, v. ARCHIE T. STROUD, III, Petitioner Respondent : 91-1344 CIVIL TERM CIVIL ACTION -CUSTODY PETITION FOR MODIFICATION OF A PARTIAL CUSTODY AND VISITATION ORDER 1. The petition of Laura Swope respectfully represents that on May 9, 2006, an Order of Court was entered for Partial Custody and Visitation, a true and correct copy of which is attached. 2. This Order should be modified because mother received a favorable psychiatric evalua#ion on May 15, 2006, from court-appointed evaluator, Dr. Jahn Hume. Since that date, the Order directed daytime custody at least two weekends per month. 3. On November 1, 2006, Petitioner relocated from Cornelius, North Carolina back to Carlisle, PA. Petitioner has been permitted to speak with her 16 year old daughter, Robie Marie Stroud, approximately once every other week since May 15, 2006, and has only been permitted to see .her daughter twice since May 15, 2006, once in August 2006, and once in November 2006. WHEREFORE, Petitioner requests this Honorable Court to modify the existing Order for Partial Custody and Visitation because it will be in the best interest of the child. Respectfully submitted, Spencer Abel Law Off ce u ne Spe er Abel, Esq. Atto ey I D #202443 22 East Street, #6 Mt Ho11y Springs, PA 17065 (717j 323-0046 spencer_abel_esq@fastmail.fm Counsel for Plaintiff, Laura Swope Page 2 ARCHIE T. STROUD, IiI, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW N0.91-1344 LAURA A. SWOPE, Defendant 1N CUSTODY ORDER AND NOW, this 9" day of May, 2006, following hearing and reflection upon the testimony adduced, it is directed that, pending further order, the order of February 22, 2006, shall remain in full force and effect. It is noted that said order suspends any rights of overnight partial custody of Roble Marie Stroud, born August 8, 1990. Any firture application to this court by the defendant, for overnight partial custody, should include a psychiatric evaluation of Laura Swope by a qualified psychiatrist who will be available to be examined by father's attorney and by the court at a hearing in Cumberland County, Pennsylvania. The psychiatric evaluation shall indicate whether Laura Swope suffers from any disorder that would negatively impact her ability to responsibly exercise her parental responsibilities during overnight partial custody of her daughter. BY THE COURT, ~--1 - /~~ Kevin Hess, 3. ~ylor Andrews, Esquire For the Plaintiff ~ura A. Swope, Pro Se ~ . 1961 ?Meridian Street Cornelius, NC 28031 (~ .L.J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAURA SWOPE, v. Petitioner ARCHIE T. STROUD, tll, Respondent 91-1344 CIVIL TERM CIVIL ACTION -CUSTODY VERIFICATION I VERIFY that I have personal knowledge of all facts not of record set forth in the foregoing pleading, and that such statements 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.A. §4904 relating to unsworn falsification to authorities. Date: ~ ~- ~ O ~ ~ d Co L ra pe IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAURA SWOPE, v. ARCHIE T. STROUD, III, Petitioner Respondent 91-1344 CIVIL TERM CIVIL ACTION -CUSTODY CERTIFICATE OF SERVICE 1 certify that, concurrent with filing the foregoing Petition fvr Modification of Custody, l am this day serving a copy of same by Certified First Class Mail, return receipt requested, to the following: Archie "Tony" Stroud 133 Kline Road Shippensburg, PA 17257 D~ I2~ Suza a Spen r Abel 22 E st Street, ~ Mt. Holly Springs, PA 17065 (717) 323-0046 spencer abel_esq(a3fastmail.fm '~'4. ~ ~ ~ r''~ P ~1+n, . © ~ ~' , n'r-- - ~ s ~~~ '" -`~ ~ ~ - Y 1 ~ ~ `__. ,.,~, ~~ ~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ARCHIE T. STROUD, III, Plaintiff v. LAURA SWOPE, Defendant Docket # 91-1344 CIVIL TERM CUSTODY PRAECIPE for ENTRY of APPEARANCE To the Prothonotary: Kindly enter my appearance on behalf of Laura Swope, Defendant. Papers may be served at the address set forth below: Suzanne Spencer Abel, Esq. Attorney ID # 202443 22 East Street, #6 Mt. Holly Springs, PA 17065 (717) 829-3206 /(~ Date: ~QV Su anne Spencer A el, Esq. Q -c~ t~'~ rni~- ~ m~ r it ' - ~ ~~ ;~ 1 i_ - . -~~ -s"i ` j 'C .C ' .U ~ . „'~ , ~ L.1 LAURA SWOPE PLAINTIFF V. ARCHIE T. STROUD III DF,FENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 91-1344 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, December 07, 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 Courthouse, Carlisle on Thursday, January 04, 2007 at 9:30 AM for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to d~:tine 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 tl~e parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR. THE COURT, By: /s/ Hubert X. Gilroy, Esq. ~~ 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 TA.{E 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 O1JT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~~ ~~ ~. ~, F 1 r ~ ~ r , ~ r.~`"9 ~~ ~~ ~~~d L- ~.~Q ~EIQZ dAN 0 S 2007nF``~ ' LAURA SWOPE, . Plaintiff . v , ARCHIE T. STROUD, III, . Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.91-1344 IN CUSTODY COURT ORDER AND NOW, this q ~ day of January, 2007, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. A hearing is scheduled in Court Room No. 4 of the Cumberland County Courthouse on the 1 ~ ~ day of G~~' ,~= , 2007 at 9 i 34 q.m. At this hearing, the mother shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, this Court's prior Order of May 9, 2006, which incorporated the prior order of February 22, 2006, shall remain in place. Mother shall have at a minimum temporary custody with the minor child on alternating Sundays from 11:00 a.m. to 7:00 p.m. Mother shall notify father on or before Sunday of each week with respect to what her schedule is the following weekend. Father is directed to try and accommodate mother's time with the minor child to fit into her work schedule, with mother being directed to take into consideration the child's social and school schedule. 3. Exchange of custody shall take place in Shippensburg at the K-Mart pursuant to the times agreed upon by the parties. Judge KEU~ nI !~~• HESS cc: uzanne Spencer Abel, Esquire ~ylor P. Andrews, Esquire E,; N ,•.~~~;;~. s: ,7 ~" ~ ~ ~ I ~y~ ~ I ~ ~~~ LL~7 LAURA SWOPE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v ARCHIE T. STROUD, III, Defendant Prior Judge: Kevin A. Hess CIVIL ACTION -LAW N0.91-1344 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. 2. 3. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Robie Marie Stroud, born August 8,1990 A Conciliation Conference was held on January 4, 2007, with the following individuals in attendance: The mother, Laura Swope, with her counsel, Suzanne Spencer Abel, Esquire, and the father, Archie T. Stroud, III, with his counsel, Taylor P. Andrews, Esquire. The parties were previously before the Court in May of 2006 at which time the Judge issued an Order confirming the prior Custody Order of February 22, 2006 but also directing that mother have a psychiatric evaluation performed. That evaluation has been performed, but it was only provided to father and his counsel at the Conciliation Conference. Mother is seeking expanded overnight visitation and, possibly, primary custody. Father is unwilling to agree to mother's request and a hearing is necessary. The Conciliator is not prepared to recommend overnight visitation in light of the circumstances of this case. However, in the interim, the Conciliator believes that the existing Order provides for mother to have alternating Sundays with the minor child from 11:00 a.m. to 7:00 p.m. in accordance with paragraph 6 of the February 22, 4. 2006 Order. That provision of the Order should be enforced. The Conciliator recommends an Order in the form as attached. / ~,'`~~ DATE V Hubert X. G' oy, Esquire Custody Co ciliator IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAURA SWOPS, Petitioner : 91-1344 CIVIL TERM v. CIVIL ACTION -CUSTODY ARCHIE T. STROUD, III, Respondent LAURA SWOPS, Petitioner v. JEFFREY SWOPS, Respondent 00-5793 CIVIL TERM CIVIL ACTION -CUSTODY MOTION TO CONSOLIDATE HEARINGS, TO REASSIGN ONE CASE, AND TO ORDER A PSYCHIATRIC EXAM AND NOW, this 18t" day of January, 2007, comes Laura Swope, Petitioner in both matters, by and through her attorney, Suzanne Spencer Abel, Esq., and who avers as follows: 1. Petitioner is Laura Swope, Plaintiff mother in the above captioned matters. She is represented by legal counsel, Suzanne Spencer Abel, Esq.. 2. Respondents are Archie Stroud and Jeffrey Swope, Defendant fathers in the above captioned matters. Respondent Stroud is represented by legal counsel, Taylor Andrews, Esq.. Respondent Swope is represented by legal counsel, Kara Haggerty, Esq.. 3. By Order dated May 5, 2006, the Honorable Judge Ebert ordered a psychiatric evaluation of Petitioner to be conducted by Dr. John Hume for the case docketed at No. 00-5793. 4. By Order dated May 9, 2006, the Honorable Judge Hess ordered a psychiatric evaluation of Petitioner for the case docketed at No. 91-1344. 5. By letter dated May 15, 2006, Dr. Hume opined that Petitioner Laura Swope "is not suffering from any mental disorder which would negatively impact her ability to exercise her parental responsibilities." A copy of Dr. Hume's letter is attached. 6. On or about the end of October 2006, Petitioner relocated back to the Carlisle area to facilitate exercising her visitation rights regarding both daughters. 7. Neither Respondent was willing to comply with the existing visitation orders. 8. On or about December 5, 2006, Petitioner filed for Modification of Custody to enforce her visitation rights and to re-establish primary custody in both above referenced matters. 9. On January 4, 2007, Conciliation Conferences were held between the respective parties before Hubert Gilroy, Esq.. Conciliator Gilroy recommended that the prior Orders for visitation be enforced as to both matters, and that both matters be scheduled for hearings before the respective Judges. 10. Counsel for both Respondents indicated their intention to cross examine Dr. Hume at the respective hearings. 11. A hearing has been scheduled for Friday, March 16, 2007, at 9:30 AM before the Honorable Judge Hess in the matter of Swope v. Stroud at No. 91-1344. 12. A hearing has not been scheduled yet before the Honorable Judge Ebert, at Petitioner's Counsel's request, pending a decision on this Motion. 13. Dr. Hume advised Petitioner's counsel that, due to the amount of time that has elapsed since the initial evaluation, he is ethically required to conduct afollow-up evaluation of Petitioner. 14. Dr. Hume further advised Petitioner's counsel that his testimony would be identical for both matters. 15. Requiring Dr. Hume to testify twice and submit to two independent cross- examinations for the same testimony is an inefficient use of precious judicial time and resources, as well as Dr. Hume's expert time and resources. 16. A consolidated hearing to take Dr. Hume's testimony promotes judicial economy of time and resources, as well as consistency. 17. The factual issues in both matters are so similar that, the further interests of judicial economy and consistency would best be served by moving one case to one Judge's docket. WHEREFORE, Petitioner respectfully requests this Honorable Court to enter an Order granting consolidation of the custody hearings; transferring one case to the other Judge's docket, and ordering afollow-up psychiatric evaluation by Dr. Hume. Respectfully submitted, Spencer Abet Law Office Suz ne Spen r Abel, Esq. Attorney ID #202443 22 East Street, #6 Mt Holly Springs, PA 17065 (717) 323-0046 spencer abel esa(a?fastmail.fm Counsel for Petitioner, Laura Swope JOHN M. HUME, M.D., J.D. 875 Valley Street Marysville, PA 17053 Telephone: (717) 957-2401 May 15, 2006 The Honorable M. L. Ebert, Jr. ,fudge, Cumberland County Court of Common Pleas 1 Courthouse Square Carlisle, PA 17013 RE: .leffre~Swop:. vs. Laura Swope Dear Judge Ebert: In accordance with court order of May 9, 2006, I saw Laura Swope for psychiatric evaluation on 05/12/06 to determine whether or not she suffers from any disorder which would negatively impact her ability to exercise her parental responsibilities. I had mistaken the time of the appointment, and I must praise Ms. Swope for tolerating my 50 minute delay with total equanimity. When asked what she understood the evaluation to be about, she responded, "I've been going through two custody hearings. The judges want to be sure I'm stable enough to have the children. The children are 12 and 15, from different fathers. I wanted to move because I've not been able to get a job that paid well enough to maintain the house I had in Carlisle. I had to sell it before it was foreclosed. I have rented a new house in North Carolina. Neither of the fathers of the girls lives in Cumberland County. I raised those kids by myself. Tony had not visited in four years, and Jeff for one year. Now they think they'll come and take the children. It's very disturbing. My 15-year-old is already in a custody issue and was in court before the Honorable Judge Hess. This ex-husband got in touch with my other ex-husband and they got together to try to get the children." When asked the reason for her job difficulties, she stated she had worked at American Standard Logistics for two years. When she bought the house she looked for a job that paid more money. She therefore moved to Keen Transport, where she was paid $2.00 more an hour and only had to pay $10.00 per week for medical insurance for her and the children vs. $65.00 that she was paying before. That job became too difficult and then she drove mail one weekday and Saturdays. She reported this required more of her than she could manage. It took her 10 hours for 8 hours of pay, and she had tc•ouble getting parcels, as well as mail delivered from her own car on a contract basis. "It was a mess. Next, Manpower sent me to Ahold. I lilted that very much, but the job lasted only a month. Then they sent me to Auto Sprinkler and I liked that, but it Page Two RE: Jeffrey Swope vs. Laura Swope was only temporary also. Then I got desperate and went to Pilot as a cashier. I never asked what the pay was until on my first paycheck I figured it came out to $7.25/hr. I couldn't live on that. Then I moved to Home Depot, but I didn't like that work and then quit after three months. I just haven't been able to find anything that I liked on an ongoing basis." She went on to indicate she had gone to North Carolina and rented a ranch home there. Having to come up to this area has really been very hard and very expensive for her. She feels as if she is imposing on a friend that she stays with when she is in this area. She continued spontaneously, "I just don't want all these problems. I went to North Carolina two months ago. Originally I had wanted to go to New York, but when I discovered the rent was $1100.00 per month it was way too scary when I was alone. I made the trips to North Carolina to check out the real estate. The place I am renting currently is only $550.00 per month, and it's a house in a development in Cornelius, NC. It's in the Lalce Norman area, where all the very large luxury homes are located. I've found a job working for The Norman Times newspaper in a secretarial position, taking ads over the phone and in person. When asked if she had made any new friends in her new location, she continued, "There are a few places I went where I met Nascar people, though not everybody. I'm trying to stay away from Nascar, since it seems to be causing trouble with how the court sees me. It's fun to run into stars on the street. It's different. At one place I ran into Jeff Gordon, and he seemed attracted to me, but I'm certainly not interested in him." When asked regarding treatment for emotional or psychological issues, she indicated that she had gone to counseling some time back for four visits to try to preserve the relationship with the man she was going with, who cheated on her all the time, that they were going together. She volunteered to do this, and wasn't ordered to. She is concerned because both of her ex-husbands have tried to say she was mentally unstable. When asked what contributed to the failure of her marriages, she answered, "Tony was married before I met him, to a child psychologist. When he was mad at you he would break furniture, cheat on me and I was pregnant before we were married. It lasted only one year. Jeff, whom I married next, had two kids I didn't even know about, acid there were other things. I was married to him one year before having Samantha. I'm not in any hurry to get remarried. I guess it was a matter of self-esteem. My sister had moved away and I was alone and uneasy. I was dumb. There were problems in my marriages and problems in another relationship. I'll never pick another loser. Gary is somebody I went with who had computer sex, cheated on me, and had sex with one of my ex-husband's daughters. I thought he was a winner since he owned Red Devil and High Line Roofing. I also dated Cassius Mulholland Page Three RE: Jeffrey Swope vs. Laura Swope of Auto Care, who was big in the community, but he was just as messed up." She denies dating anyone in North Carolina. She states on the weekends that she may. jet ski, "I'm 40 and not that desperate now. The kids fit in well with Cassius when we went together, but he was divorcing at the time. Samantha did poorly in school after Cassius broke up. I had a tutor for Samantha and she ended up calling the tutor's husband "Dad". He was an ex-lawyer from New York, and his wife, the tutor, was a learning support person at school. With the tutoring Sam got on the honor roll, but the tutor wanted her to contimle. The tutor's kids, when they got to seventh or eighth grade, were sent off to boarding school, which seemed pretty strange. I always thought people with more money and better jobs had what it takes, but I found out quite differently. When I sold my home, an injunction was slapped on me not to take the children out of Pennsylvania. Samantha, my 12-year-old, is now totally brainwashed by Rob, as she has spent the last eight months at her dad's place. I've had to do visitation from North Carolina. It has been really upsetting for me." In terms of family history, the patient has one brother who lives in Florida, a sister in California and the patient is the youngest. She has a half brother from one of her mother's affairs and another brother who was killed when hit by a car, who was homosexual and suffering with advanced AIDS at the time of his death. Her parents were divorced when she was eight or nine years old. She describes her mother as being always alcoholic. Her father was a strict Catholic, one of nine kids, including a brother as a priest. Her mother and father were the only ones among the strict Catholics ever to get divorced. She states it was very difficult as a child, but she fits in now as an adult. At age 12 she moved in with her older sister. After the divorce she was with her mother and her other siblings went with the father. "I've hit a stump in the road and I've fixed that now. There was a ten year period when I had no relationship with my parents, but now I see them periodically in an adult relationship. You learn they had screwed up issues also. My mother has been an RN forever, despite her alcohol problems. She remarried and it didn't work out because it w~;s to a man on the rebound. That man ruined our lives. My mother left for him, and then he went back to his wife. My second husband, Jeff, was adopted at 15, as his biological parents were dead. My first husband had a disruptive childhood also. I just don't want my daughter in the mess that I ran from. When asked again about contact with Nascar folks, she stated, "I do see them and they like me, but I don't hang out with them. I know Jeff Gordon, though he doesn't live in that same area. I'm not going to go off and follow the racetrack crowd. I have a regular job, and I'm going to be at home with my kids. Jeff Gordon said he loved ine three times, but he's a jerk. I didn't realize that the place down there was that Nascar loaded." She went on to remark that much of the conversation about her Nascar acquaintances had taken place off the record in the last custody hearing. "I Page Four RE: Jeffrey Swope vs. Laura Swope can't afford legal counsel and I went for free legal assistance and was turned down three times, so I have to represent myself. On one hearing they took my ex-husband out of order to accommodate his work schedule. I never got an opportunity to make my opening statement. It's been five or six months since I sold the house. I didn't like the idea of waiting around here when holding a job was so difficult. I just can't believe the Nascar business upset people so much. Jeff's family is such trash. I'd much rather talk to a psychiatrist than try to deal with the judge again." She described home circumstances with her ex-husbands, indicating Tony had worked at Frog and Switch for 20 years, then got into an affair with Tracy, who was an employee there who messed up a lot of people. Currently he is driving a truck, and often gets home at 11:00 p.m. She feels her 15-year-old daughter practically runs the place. Also living there is Tony's wife and his son, Justin, who has been arrested three times, twice for fires, aild one time for a police chase. There is one daughter between Tony and his cun•ent wife, and she indicates they are not the perfect parents and have nothing to offer her kids. "I don't want losing my kids to be based on moving out of state. The kids will be able to do everything in North Carolina that they do here. Jeff's household is a mess. His wife has a 21-year-old daughter who got pregnant at 17, so there's my daughter and a 4-year-old granddaughter. He has three kids in Carlisle that he didn't even see for six years. He has three other kids, but none were raised with Samantha. They're pigs, and I don't want my daughter raised under those circumstances. Samantha went off with a woman who slept with Jeff's brother." She went onto describe drive-by harassments, especially as Jeff's kids became old enough to operate motor vehicles. She went on to indicate that Jeff had been arrested for failure to provide child support for a kid she never even knew about. "I just wanted the opportunity to tell the judge my side of the situation. Tony, this last summer, had an affair with a former ex-wife and took the kids along with her to North Carolina. Bobby has too much freedom in Shippensburg. They stole Samantha when I was looking for places in North Carolina. I hadn't even left town before the kids were handed aver by the tutor and a friend of their father. The police wouldn't do anything to help. They now say they made a big mistake in supporting my ex- husbands. Samantha has been brainwashed by her experience. I just don't see how they can take my kids after I raised them all these years. The girls did argue when together, but now they'd be more compatible." She discussed some parenting attributes appropriately, and with good disciplinary concepts. She re-emphasized how hard it was coming from out of state for visitation, and indicates she has only missed visitation once. She currently is living on the proceeds of her house, but indicates when the custody issue is settled, her parents will help her financially. Page Five RE: .Teffi•ey Swope vs. Laura Swope When asked what she does when she gets angry, she states she asks the kids not to bother her. "The kids come after me even when I say be gone, and they blast their stereos and stay in their rooms. I don't scream much. It makes me feel like a mean person. There were four fights between the time Cassius left and Samantha went with her father. It was February to August, ?005. She called the police on me, but the police were not firm enough with her to tell her to listen to her mother. I didn't feel the police took advantage of their authority to tell them to obey their mother. One time she slapped me in thES face. and I backed her up against the stove. Robby had a lot of friends to call incessantly on the phone in the evening. These kids were on academic watch and shouldn't have been calling all the time. It was O.K. in the summer, because I had a pool and a trampoline in the back yard, and the kids liked to come over. Robby was very upset about having to sell the home to avoid foreclosure. It was devastating to all of us (she was close to tears}. Robby was allowed by her father to drop Spanish the second semester. I would have made her stick to it with a tutor. She just shouldn't have done that. She'll have problems getting through the subjects that she needs for college." When asked what she might have for tluee wishes, she listed them as 1) "children be with me in North Carolina, 2) find an adult person for a husband, and 3) a beautiful house, no I mean I should ask for the kids to be happy. Living with their dads isn't going to make them happy. We three girls should all be together. The fathers just don't want to pay child support and they're giving Robby too much freedom." When asked regarding her educational background, she indicates she graduated from Cumberland Valley High School in 1985 and started college. She dropped out when her sister, with whom she was living, moved to West Virginia. When asked about substance abuse issues, she states she tried drugs two times, once at 18, and once as an adult, and did not like it. She smokes cigarettes and notes that she uses alcohol occasionally and this has been increased some since the children have not been pith her, but not to the point of intoxication. "I avoid doing anything like that because I saw my mother's alcoholism and what it does to you. I do drink a lot of coffee, and sometimes it can snake me hyper. I have sometimes as much as 10 cups in a day, but today I've had only 4 cups. In regard to past medical history, she states she has never had any surgical procedures and rarely has headaches, which are relieved by aspirin. She notes that her daughter, Robby, gets migraines, and has been tried on anti-epileptic medications, which were not effective. Going to bed seems to be the only thing that works with any effectiveness. In terms of past interaction with the authorities, she states she had one police stop in Page Six RE: .leffrey Swope vs. Laura Swope March of this year. The officer who stopped her said, "Is it worth all this?" He got in my car on the driver's seat side that I was sitting in. The allegation was that I cut off a police car at the 81 ramp. I usually keep my mouth quiet until they attack me, and I talk back. I've pled not guilty, and I have a hearing on June 6t~'. I can't afford an attorney. If the traffic stop took place as she describes it, it clearly appears to be irregular. On mental status exam the patient appeared as an attractive, well groomed, though casually dressed Caucasian woman, appearing 5 to 10 years younger than her chronologic stated age. She was precisely oriented for time, place and person. Mood and affect were variable and appropriate to the thought content of her conversation. Psychotic distortions, such as delusions, hallucinations, grandiose ideas or paranoid distortions were not evident. I had her do a Bender Motor Gestalt exam, which reflected no evidence of organic impairment and no difficulty in terms of self control. She was able to write her name, taking more than a minute to do it, indicative of adequate self-control. Cognitive functions were congruent with her high school education. Recent and remote memory were adequate. Homicidal or suicidal ideation was denied. Speech was of normal tone and rate. Judgment is adequate. Insight is partial, in that she understands that some difficulties related to self-esteem arise out of her own childhood experiences. DIAGNOSTIC IMPRESSION: Axis I Adjustment Disorder with mixed emotional features appropriate for her current circumstances. Axis II No diagnosis. Axis III No medical problems. Axis IV Degree of stress moderately severe. Custody issues. Financial pressures. Axis V Current GAF = 80. COMMENTS: It is my opinion, with a reasonable degree of medical certainty that at the present time Ms. Swope is not suffering from any mental disorder which would negatively impact leer ability to exercise her parental responsibilities. She is at times outspoken, yet at the same time has the ability to exercise adequate control. Concerns about ideas of self-importance approaching delusional proportions were not evident in any aspect of Page Seven RE: Jeffi•e~Swo^pe vs. Laura Swope this evaluation. Thank you for the opportunity of evaluating Ms. Swope. If you have any questions, please do not hesitate to be in touch with me. Very Truly Yours, John M. Hume, M.D., J.D. JMH/asap CERTIFICATE OF SERVICE I certify that, concurrent with filing the foregoing Motion to Consolidate Hearings, to Reassign One Case, and to OrrJer a Psychiatric Exam, I am this day serving a copy of same by First Class Mail, to the following: Counsel for Respondent,.Jeffrey Swope, Docket #2000-5793: Abom & Kutulakis Kara Haggerty, Esq. 36 S. Hanover Street Carlisle, PA 17013 Counsel for Respondent,.Archie Stroud, Docket #1999-1344: Andrews & Johnson Taylor Andrews, Esq. 78 West Pomfret Street Carlisle, PA 17013 Date: ~ /~ Suza a Spen r Abe! 22 East Street, #6 Mt. Holly Springs, PA 17065 (717) 323-0046 spencer_abel_esq@fastmail.fm C? ~~.~ ~? C.:.. c°a --n c..... F ~ = ~ ~ n~ ~.~._ = --~ FT ~ --- ~~, ~ t . co ^.^~t"', -i3 r:j _.`A ~ ~ .IAN 19 ZOW~^' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAURA SWOPE, Petitioner 91-1344 CIVIL TERM .,/ v. CIVIL ACTION -CUSTODY ARCHIE T. STROUD, ill, Respondent LAURA SWOPE, Petitioner 00-5793 CIVIL TERM v. : CIVIL ACTION -CUSTODY JEFFREY SWOPE, : Respondent ORDER AND NOW, this z-~ ~ day of January, 2007, upon consideration of the foregoing Motion, it is hereby ordered that 1. A Rule is issued upon the Respondents to show why the moving party is not entitled to the relief requested; ~ cry <,~: 2. The Respondents shall file an Answer to the Motion within ~~ days of ~is~date; 3. The Motion shall be decided under Pa.R.C.P. No. 206.7; 4. Argument shalt be held , 5. Notice of the entry of this Order shalt be provided to alt parties by the moving rty. BY THE COURT: / ~~ J. r*t~ 4,r ,.,! :~,~~t I:J ~ a LAURA A. SWOPE, Petitioner vs. ARCHIE T. STROUD, III Respondent LAURA A. SWOPE, Petitioner vs. JEFFREY SWOPE, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL 91-1344 CIVIL ACTION -LAW ~ IN CUSTODY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL 00-5793 CIVIL ACTION -LAW IN CUSTODY ANSWER OF RESPONDENT, ARCHIE T. STROUD, III Respondent, ARCHIE T. STOUD III, by his attorney, Taylor P. Andrews, Esquire, respectfully answers Petitioner's Motion for Consolidation and a Psychiatric Exam as follows: 1) Respondent does not oppose the relief sought by Petitioner. 2) Respondent agrees that it is most efficient for the two captioned cases to be heard either by one judge or by two judges simultaneously. The Respondent defers to the Court's discretion in this matter. 3) Respondent repeats the same position expressed at the conciliation conference and that was reflected by each Judge's prior Order, that Respondent's counsel have an opportunity to question the examining psychiatrist prior to a change in a custody Order. Respectfully submitted, T Ibf .Andrews, Esquire 7 st Pomfret Street Carlisle, PA 17013 Pa. Supreme Ct.#: 15641 (717)243-0123 Attorney for Respondent LAURA A. SWOPE, Petitioner vs. ARCHIE T. STROUD, III Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL 91-1344 CIVIL ACTION -LAW IN CUSTODY LAURA A. SWOPE, : IN THE COURT OF COMMON PLEAS OF Petitioner :CUMBERLAND COUNTY, PENNSYLVANIA vs. :CIVIL 00-5793 CIVIL ACTION -LAW JEFFREY SWOPE, Respondent : IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on this date, OZ ~0~-- , 2007, I mailed a copy of ANSWER OF RESPONDENT, ARCHIE T. STROUD, III to the following person at the following address by U.S. Mail, first class, postage prepaid, to: Abom & Kutulakis Kara Haggerty, Esquire 36 South Hanover Street Carlisle, PA 17013 Suzanne Spencer Abel, Esquire 22 East Street #6 Mt. Holly Springs, PA 17065 I verify that the statements made in the foregoing Certificate of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. ANDREWS & JOHNSON By: Ta P. Andrews, Esq. 78 W. Pomfret Street Carlisle, PA 17013 (717)243-0123 r.,~ i _~ ~__. c.~ ""~`7 °-'^ --4 ~'` i ~ _ -~? f ~': ,.. f S''J ~_' -~ r ,.. (_..i !` ' ~ _ -- ,.,,_ ~~ ..._.. ail _ •• LAURA SWOPE IN THE COURT OF COMMON PLEAS Petitioner CUMBERLAND COUNTY, PENNSYLVANIA ~. CIVIL 91-1344 CIVIL ACTION -LAW ARCHIE T. STROUD, III Respondent IN CUSTODY LAURA SWOPE IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENN ~. NO. 00-5793 CIVIL TERM CIVIL ACTION -LAW JEFFREY SWOPE Defendant IN CUSTODY ANSWER OF RESPONDENT, JEFFREY SWOPE Respondent, Jeffrey Swope, by his attorney, Kara W. Haggerty, Esquire, and Abom & Kutulakis, respectfully answers Petitioner's Motion for Consolidation and a Psychiatric Exam as follows: 1. Respondent does not oppose the relief sought by Petitioner. 2. Respondent agrees that it is most efficient for the two captioned cases to be heard either by one judge or by two judges simultaneously. The Respondent defers to the Court's discretion in this matter. 3. Respondent repeats the same position expressed at the conciliation conference and that was reflected by each Judge's prior Order, that respondent's counsel have an opportunity to question the examining psychiatrist prior to a change in a custody Order. Respectfully submitted, ABOM ~ KUTULAKIS, L.L.P. Kara W. Haggerty, 36 South Hanover t t Carlisle, PA 17013 (717) 249-0900 Attorney ID #86914 Attorney for Respondent, Jeffrey Swope CERTIFICATE OF SERVICE AND NOW, this 20`~ day of February, 2007, I, Kara W. Haggerty, of Abom & Kutulakis, LLP, hereby certify that I did serve a true and correct copy of the foregoing Answer of Respondent, Jeffrey Swope to all parties of record by depositing, or causing to be deposited, same in the U.S. mail, First-Class, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Suzanne Spencer Abel, Esquire 22 East Street #6 Mt. Holly Springs, PA 17065 Taylor P. Andrews, Esquire 78 West Pomfret Street Carlisle, PA 17013 Respectfully submitted, DATE ~ ~ ~`'' O ABOa~r ~ Ku7vr_Axls, L.L.P ~7 ".' ~ ~ -r~ rx~ "~ ~ ~` tom, ~~ J ~.. J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAURA SWOPE, Petitioner 91-1344 CIVIL TERM CIVIL ACTION -CUSTODY v. ARCHIE T. STROUD, III, Respondent LAURA SWOPE, Petitioner 00-5793 CIVIL TERM v. CIVIL ACTION -CUSTODY JEFFREY SWOPE, Respondent PETITION TO MAKE RULE ABSOLUTE AND NOW, this 22"d day of February, 2007, comes Laura Swope, Petitioner in both above-referenced matters, by and through her attorney, Suzanne Spencer Abel, Esq., and respectfully moves #his Honorable Court to Make Rule Absolute:: 1. By Order dated January 26, 2007, the Honorable Judge Kevin Hess issued a Rule upon Respondents why the above Petitioner should not be entitled to the relief requested. 2. Said Rule to Show Cause was answerable within fifteen (15) days. 3. More than fifteen (15) days have elapsed since the issuance of the Rule to Show Cause. 4. Pursuant to Pa. R.C.P. No. 206.7(a) and (b), Petitioner asks this Honorable Court to decide the matter on petition and answers. 4 WHEREFORE, Petitioner respectfully requests that this matter be made absolute and that an Order be entered forthwith granting Petitioner's request. Respectfully submitted, Spencer Abel Law Office uz ne Spe cer Abel, Esq. Attor ey ID #202443 22 East Street, #6 Mt Holly Springs, PA 17065 (717) 323-0046 spencer abet esgCc~fastmail.fm Counsel for Petitioner, Laura Swope 4 • • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAURA SWOPE, Petitioner 91-1344 CIVIL TERM v. CIVIL ACTION -CUSTODY ARCHIE T. STROUD, III, Respondent LAURA SWOPE, Petitioner v. JEFFREY SWOPE, Respondent 00-5793 CIVIL TERM CIVIL ACTION -CUSTODY CERTIFICATE OF SERVICE I certify that, concurrent with filing the foregoing Petition to Make Rule Absolute, I am this day serving a copy of same by First Class Mail, to the following: Counsel for Respondent,.Jeffrey Swope, Docket #2000-5793: Abom & Kututakis Kara Haggerty, Esq. 36 S. Hanover Street Carlisle, PA 17013 Counsel for Respondent,.Archie Stroud, Docket #1999-1344: Andrews & Johnson Taylor Andrews, Esq. 78 West Pomfret Street Carlisle, PA 17013 Date: a/~~7~"IU~ Su nne Sp ncer Abel 22 ast Street, #6 Mt. Holly Springs, PA 17065 (717) 323-0046 spencer_abel_esq@fastmail.fm ; - - ~~7 - -~,, 1 = S r ~ ~- ;.,,] C.~ ~, ~ • T ~ ~~, ~ ~ ~ ~ . r ~,.~ ~~ r Y ,,, r+• 4 - , r h , ARCHIE T. STROUD, III, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW NO. 91-1344 t/ LAURA A. SWOPE, Defendant IN CUSTODY LAURA SWOPE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW NO. 00-5793 JEFFREY SWOPE, Defendant IN CUSTODY IN RE: PETITION TO MAKE RULE ABSOLUTE ORDER AND NOW, this ~ ~ day of March, 2007, it is ordered and directed that: 1. The custody hearings for the above referenced cases are consolidated for the purpose of hearing the expert testimony. 2. To provide judicial efficiency, the case docketed at No. 00-5793 is hereby removed from the schedule of the Honorable M. L. Ebert, Jr., and is hereby transferred to the Honorable Kevin A. Hess. 3. Dr. John M. Hume, M.D., J.D., is hereby reappointed to conduct a psychiatric evaluation of Laura Swope in order to determine whether or not she now suffers from any disorder that would negatively impact her ability to exercise her parental responsibilities. 4. Petitioner Laura Swope is hereby ordered and directed to appear for the evaluation at the time and place selected by Dr. Hume, at least one month prior to the consolidated hearing herein . 5. The hearing set for March 16, 2007, in Courtroom Number 4, and the hearing set for May 18, 2007, in Courtroom 5, are consolidated and set for Friday, June 1, 2007, at 9:30 a.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. BY THE COURT, ~~ Kevin A/Hess, J. ~ylor Andrews, Esquire For the Plaintiff Shroud uzanne Spencer Abel, Esquire For Laura A. Swope ~ara Haggerty, Esquire For Defendant Swope C' J ~ :rlm O ~' /~~~ OJ ~.~~, ~~ , f=lllr~ ARCHIE T. STROUD, III, Plaintiff/Respondent vs. LAURA A. SWOPE, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.91-1344 IN CUSTODY IN RE: DEFENDANT' S PETITION FOR MODIFICATION OF A PARTIAL CUSTODY AND VISITATION ORDER ORDER AND NOW, this ~Z ~ day of June, 2007, the motion of the defendant for modification of custody is DENIED and the existing custody order in this case is ratified and confirmed. BY THE COURT, / ~' Kev' A. Hess, J. Taylor Andrews, Esquire For the Plaintiff/Respondent Suzanne Spencer Abel, Esquire For the Defendant/Petitioner :rlm 1~»~ a~~H~ ~~ . ~„ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 91-1344 CIVIL TERM CIVIL ACTION -CUSTODY LAURA SWOPE, Petitioner v. ARCHIE T. STROUD, III, Respondent LAURA SWOPE, Petitioner v. JEFFREY SWOPE, Respondent 00-5793 CIVIL TERM CIVIL ACTION -CUSTODY MOTION TO WITHDRAW AS COUNSEL OF RECORD AND NOW comes Suzanne Spencer Abel, Esquire, attorney for Petitioner, and presents this Motion to Withdraw as Counse{ of Record, representing as follows: 1. Movant is Suzanne Spencer Abel, Esquire, attorney for Plaintiff, with an office at 22 East Street, #6, Mt. Holly Springs, Pennsylvania 17065. 2. Petitioner is Laura Swope, an adult individual whose address is 347 Old Stonehouse Road, Boiling Springs, PA 17007 3. A hearing in the above referenced matters was held on June 1, 2007, before the Honorable Judge Kevin Hess, who subsequently denied Petitioner's Modification Petitions. 4. Continued representation of Petitioner by Movant would be overly burdensome to Movant's practice. 5. Moreover, Movant cannot effectively represent Petitioner as Petitioner insisted upon appealing her cases to the Pennsylvania Supreme Court. Movant believed such an appeal lacked legal merit and recommended Petitioner seek new counsel. 6. Movant wishes to withdraw her appearance as Petitioner's counsel of record. 7. Movant has contacted Taylor Andrews, Esquire, attorney for Respondent Archie Stroud, and he has no objection to the request for leave to withdraw. 8. Movant has contacted Kara Hggerty, Esquire, attorney for Respondent Jeffrey Swope, and she has no objection to the request for leave to withdraw. WHEREFORE, Movant requests your Honorable Court to provide leave of Court and Order that Movant is withdrawn as counsel of record for Laura Swope, Petitioner. Respectfully submitted, Spencer Abel Law Office Z ne Spen r Abel, Esq. Atto y ID #202443 22 East Street, #6 Mt Holly Springs, PA 17065 (717) 264-2939 spencer abel esgCa~fastmail.fm ~ Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAURA SWOPE, v. ARCHIE T. STROUD, III, 91-1344 CIVIL TERM CIVIL ACTION -CUSTODY LAURA SWOPE, v. JEFFREY SWOPE, Petitioner Respondent Petitioner Respondent 00-5793 CIVIL TERM CIVIL ACTION -CUSTODY VERIFICATION I VERIFY that I have persona! knowledge of all facts not of record set forth in the foregoing pleading, and that such statements 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.A. §4904 relating to unsworn falsification to authorities. Date: u e Spenc r Abel, Esquire 22 t Street, #6 Mt. Holly Springs, PA 17065 (717) 264-2939 spencer_abel_esq@fastmail.fm 1' ~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 91-1344 CIVIL TERM LAURA SWOPS, Petitioner CIVIL ACTION -CUSTODY v. ARCHIE T. STROUD, III, Respondent LAURA SWOPS, 00-5793 CIVIL TERM v. JEFFREY SWOPS, Petitioner Respondent CIVIL ACTION -CUSTODY CERTIFICATE OF SERVICE I certify that, concurrent with filing the foregoing Motion to Withdraw as Counsel of Record, I am this day serving a copy of same by First Class U.S. Mail, to the following: Taylor Andrews, Esquire Andrews & Johnson 78 West Pomfret Street Carlisle, PA 17013 Sara Haggerty, Esq. ~bom & Kutalakis 36 South Hanover Street Carlisle, PA 17013 Date: ~ Hubert Gilroy, Esq. Martson Law Offices 10 East High Street Carlisle, PA !7013 Laura Swope 347 Old Stonehouse Road Boiling Springs, PA 17007 Suz ne Spen r Abel 22 t Street, #6 Mt. Holly Springs, PA 17065 (717) 264-2939 spencer_abel esq@fastmail.fm ~' ~::a ; ~~ ~. °i't !' ,. ~~ _ ^' _. _ y C'"l __~# ..1 ~.~ r~ ^ ~ -"C ~ s '4~ I JUL 2720D7/y LAURA SWOPE, Petitioner v. ARCHIE T. STROUD, III, Respondent 91-1344 CIVIL TERM CIVIL ACTION -CUSTODY LAURA SWOPE, v. JEFFREY SWOPE, Respondent 00-5793 CIVIL TERM CIVIL ACTION -CUSTODY ORDER of COURT AND NOW, this 2 ~ ' day of ~1~,,~. , 2007, upon consideration of the Motion of Suzanne Spencer Abel, Esquire, to withdraw as counsel of record for Petitioner, Laura Swope, Suzanne Spencer Abel, Esquire is hereby withdrawn as counsel of record. e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Petitioner J. 1~~fd~~1~lSDaN~c~ A.l.Nfl{:}~ fir.^;-~~ ~Ni(YJ z~ :s wv of ~~r ~o~Z ~1c~~~.~a~a ~H:t ~