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HomeMy WebLinkAbout06-6214 KIRK A. PERKINS, Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A v. NO. CIVIL TERM LORIEN A. PERKINS-MICKELSON, Respondent CIVIL ACTION pETIl'I9N FO~ SPECIAL IWQ~TlVE REUID<: AND NOW, this 25th day of October, 2006, comes the Petitioner, Kirk A. Perkins, by and through his undersigned counsel, Jason P. Kutulakis, petitions this Court on his behalf for the issuance of a special injunction pursuant to Pa. R.c.P. No. 1531, and in support alleges as follows: 1. Petitioner, Kirk A. Perkins, is an adult individual who resides at 6030 Creekview Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Petitioner resides at the above address with his wife, N aney E. Perkins, Mrs. Perkins' adult daughter, Becky Eichelberger, and her minor daughter, B.E., age two. 3. Respondent, Lorien Perkins-Mickelson, is an adult individual who is believed to reside at 1811 Knights Circle, Coantonment, Florida, 32533. 4. The Petitioner, Kirk A. Perkins, is represented by John A. Abom, Esquire, of Abom & Kutulakis, L.L.P., in a Petition to Vacate Divorce Decree and related Pleadings. 5. Respondent is represented by Diane Radcliff, Esquire in her Petition to Vacate Divorce Decree and related Pleadings. 6. Due to the allegations being made in the Petition to Vacate Divorce Decree and related Pleadings, criminal charges were filed against the Petitioner, Mr. Perkins, in Dauphin County, Pennsylvania. 7. On or about September 12, 2006, Petitioner, Mr. Perkins, was acquitted of all charges in a bench trial before the Honorable Lawrence F. Clark, Jr. 8. On or about September 28-29, 2006, Petitioner received multiple phone calls from the Respondent that were in a threatening and harassing manner. 9. Petitioner, Mr. Perkins, recognized the voice of the caller as his ex-wife, Respondent Lorien Perkins-Mickelson. 10. Upon answering the second telephone call on September 28, 2006, the caller stated, "this is your ex-wife" and the Petitioner, Mr. Perkins, directed that she was not to call his home any more and all conversations should occur between their attorneys. 11. The third telephone call was answered by Mr. Perkins and the Respondent proceeded to threaten and swear at him at which time Mr. Perkins once again advised the Respondent to cease calling his residence. 12. The Respondent proceeded to call an additional four to five times and hung up when the answering machine picked-up. 13. Respondent called again and left a message in which she stated, "Hi, sweetie you know who this is, I know that Lori isn't home right now." 2 14. The final telephone called came in at approximately 12:30 a.m., on September 29, 2006, in which the Respondent left a message making slanderous remarks regarding Judge Clark, Mr. Abom and the Petitioner himself. 15. Due to the Petitioner no longer answering his home telephone, the Respondent called Mr. Perkins' cell phone and left a detailed message including accusations and profanity. 16. On the same dates, Mr. Abom also received multiple hang-up telephone calls in the middle of the night that are believed to be from the Respondent. 17. It is believed and therefore averred that the chambers of The Honorable Judge Clark received a harassing telephone call from the Respondent. 18. It is believed and therefore averred that all above-referenced telephone calls originated from a T-Mobile telephone out of Tampa, Florida. 19. On or about October 24, 2006, Petitioner received their first telephone call that evening at 9:23 p.m., at his home residence. 20. Petitioner received three (3) hang-up telephone calls prior to answering the telephone. 21. Upon answering the fourth phone call, the caller stated "pay your fucking bills, you fucking asshole." 22. The Petitioner, Mr. Perkins, believes and therefore avers that the caller is the Respondent. 3 23. Petitioner, Mr. Perkins, directed the Respondent to cease calling and stated that he would be contacting the local police department. 24. In a subsequent telephone call, Respondent stated that "Kirk was a fucking cheat and liar" and proceeded to state that "[she] was not going to be going away and they should get used to it." 25. Respondent then called another time; however, Petitioner did not answer the telephone call. 26. Petitioner proceeded to disconnect the telephone in order to stop the threatening and harassing telephone calls. 27. Petitioner has retained copies of all voicemail messages left on his answering machine. A transcript of the messages shall be provided to the court. 28. Petitioner, Mr. Perkins, learned that his counsel, Mr. Abom received two harassing and threatening telephone calls at his home residence that same everung. 29. On or about October 24, 2006, Petitioner, Mr. Perkins proceeded to contact the Hampden Township Police Department to report the threatening and harassing telephone calls that he and his wife received that evening. 30. On this date, Petitioner, Mr. Perkins, contacted his attorney and requested that the within Petition be @ed in an effort to cease all contact with the Respondent whatsoever. 4 31. It is believed and therefore averred that Respondent's inappropriate behavior is escalating in its threatening and harassing nature. 32. It is believed and therefore averred that the escalation of Respondent's behavior is the reason the filing of the within Petition has become necessary. 33. Petitioner requests this Honorable Court to enjoin the Respondent from making any contact, harassing or otherwise, with them and their family. 34. Petitioner has posted a One-Hundred Dollar ($100.00) bond contemporaneously with the filing of said Petition. 3S.John A. Abom is filing a similar petition for protective relief on behalf of his family simultaneously with the filing of this petition. 5 WHEREFORE, Petitioner respectfully request that this Honorable Court award the following relief: (a) Enter a Preliminary Injunction in favor of the Petitioner and his family as against the Respondent; (b) Order and direct the Respondent to have no contact with the Petitioner and his family, including but not limited to through third parties, at their home, places of employment, the minor children's schools, or any other location in which they may be found; (c) Respondent to be responsible for the costs associated with any court costs and attorney's fees associated with the filing of this action; and (d) Award such other relief as the Court deems appropriate. Respectfully submitted, M & KUTULAKIS, L.L.P. DATE~gS )~(, n P. Kutulakis S reme Court ID 80411 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 6 VERIFICATION PURSUANT TO Pa.RC.P. 1024(c) Jason P. Kutulakis, Esquire, states that he is the attorney for the party filing the foregoing document; that he makes this affidavit as an attorney, because the party he represents lacks sufficient knowledge or information upon which to make a verification and/ or because he has greater personal knowledge of the information and belief than that of the party for whom he makes this affidavit; and/or because the party for whom he makes this affidavit is outside the jurisdiction of the court, and verification of none of them can be obtained within the time allowed for the filing of the document; and that he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification of authorities. Date: October 25,2006 ~ 7 (') ~ ~ c::' s::; c:> 0' \..1', 0 ~-n CJ (11 p" ~ , \J..l \1-- \::) --, ~ -n (T1 ,\ N ~()CJ ~ V\ c...n r" \ '0 ~ ::-~Cl ~ '""'1'""~ ^"') I \ ~ 'S ~ ~ ~ -0 ( ~2~:; ~ > f-:J K1 ~ ~ ~ "b 0) -'-\ ~ . . JO ~ '). 0 :;.<::, ~ . CO ~ t C\ "- ~ G , ~ \ - KIRK A. PERKINS, Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. NO. 0& -~:;../ Y CIVIL TERM CIVIL ACTION - EQUITY LORIEN A. PERKINS-MICKELSON, Respondent PETITION FOR -eRELIMINARY INlUN~T~ELIEF AND NOW, comes the Petitioner, Kirk A. Perkins, by and through his counsel, Jason P. Kutulakis, Esquire, of ABOM & KUTULAKIS, L.L.P., and petitions this Court on his behalf for the issuance of a preliminary injunction pursuant to Pa. R.C.P. No. 1531, and in support thereof avers as follows: 1. Petitioner, Kirk A. Perkins, is an adult individual who resides at 6030 Creekview Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Petitioner resides at the above address with his wife, Nancy E. Perkins, Mrs. Perkins' adult daughter, Becky Eichelberger, and her minor daughter, B.E., age two. 3. Respondent, Lorien Perkins-Mickelson, is an adult individual who is believed to reside at 1811 Knights Circle, Coantonment, Florida, 32533. 4. The Petitioner, Kirk A. Perkins, is represented by John A. Abom, Esquire, of Abom & Kutulakis, L.L.P., in a Petition to Vacate Divorce Decree and related pleadings. 5. Respondent is represented by Diane Radcliff, Esquire in her Petition to Vacate Divorce Decree and related pleadings. 6. Due to the allegations being made in the Petition to Vacate Divorce Decree and related pleadings, criminal charges were filed against the Petitioner, Mr. Perkins, in Dauphin County, Pennsylvania. 7. On or about September 12, 2006, Petitioner, Mr. Perkins, was acquitted of all charges in a bench trial before the Honorable Lawrence F. Clark, Jr. 8. On or about September 28-29, 2006, Petitioner received multiple telephone calls from the Respondent that were threatening and harassing in nature. 9. Petitioner, Mr. Perkins, recognized the voice of the caller as his ex-wife, Respondent, Lorien Perkins-Mickelson. 10. Upon answering the second telephone call on September 28, 2006, the caller stated, "this is your ex-wife" and the Petitioner, Mr. Perkins, directed that she was not to call his home any more and all conversations should occur between their attorneys. 11. Mr. Perkins answered the third telephone call and the Respondent proceeded to threaten and swear at him at which time Mr. Perkins once again advised the Respondent to cease calling his residence. 12. The Respondent proceeded to call an additional four to five times and hung up when the answering machine picked-up. 13. Respondent called again and left a message in which she stated, "Hi, sweetie you know who this is, I know that Lori isn't home right now." 2 14. The final telephone called came in at approximately 12:30 a.m., on September 29, 2006, in which the Respondent left a message making slanderous remarks regarding Judge Clark, Mr. Abom and the Petitioner himself. 15. Due to the Petitioner no longer answering his home telephone, the Respondent called Mr. Perkins' cell phone and left a detailed message including accusations and profanity. 16. On the same dates, Mr. Abom also received multiple hang-up telephone calls in the middle of the night that are believed to be from the Respondent. 17. It is believed and therefore averred that the chambers of The Honorable Judge Clark received a harassing telephone call from the Respondent. 18. It is believed and therefore averred that all above-referenced telephone calls originated from a T-Mobile telephone out of Tampa, Florida. 19. On or about October 24, 2006, Petitioner received a telephone call at 9:23 p.m., at his home residence. 20. Petitioner received three (3) hang-up telephone calls prior to answering the telephone. 21. Upon answering the fourth phone call, the caller stated, "pay your fucking bills, you fucking asshole." 22. The Petitioner, Mr. Perkins, believes and therefore avers that the caller is the Respondent. 3 23. Petitioner, Mr. Perkins, directed the Respondent to cease calling and stated that he would be contacting the local police department. 24. In a subsequent telephone call, Respondent stated that "Kirk was a fucking cheat and liar" and proceeded to state that "[she] was not going to be going away and they should get used to it." 25. Respondent then called another time; however, Petitioner did not answer the telephone call. 26. Petitioner proceeded to disconnect the telephone in order to stop the threatening and harassing telephone calls. 27. Petitioner has retained copies of all voicemail messages left on his answering machine. A transcript of the messages shall be provided to the court. 28. Petitioner, Mr. Perkins, learned. that his counsel, Mr. Abom received two harassing and threatening telephone calls at his home residence that same everung. 29. On or about October 24,2006, Petitioner, Mr. Perkins proceeded to contact the Hampden Township Police Department to report the threatening and harassing telephone calls that he and his wife received that evening. 30. On October 25, 2006, Petitioner, Mr. Perkins, contacted his attorney and requested that the within Petition be filed in an effort to cease all contact with the Respondent whatsoever. 4 31. It is believed and therefore averred that Respondent's inappropriate behavior is escalating in its threatening and harassing nature. 32. It is believed and therefore averred that the escalation of Respondent's behavior is the reason the filing of the within Petition has become necessary. 33. Petitioner requests This Honorable Court to enjoin the Respondent from making any contact, harassing or otherwise, with him or his family. 34. Petitioner has posted a One-Hundred Dollar ($100.00) bond contemporaneously with the filing of said Petition. 35. John A. Abom is filing a similar petition for protective relief on behalf of his family simultaneously with the filing of this petition. 36. The law firm of Abom & Kutulakis, L.L.P. contacted Diane Radcliff, Esquire to inquire about accepting service of the within petition, and Ms. Radcliff advised that she would contact her client to detennine that she is authorized to do so. 37.As Attorney Radcliff represents the Respondent in the Petition to Vacate Divorce Decree and related pleadings, undersigned counsel is serving Attorney Radcliff of the within petition via facsimile and United States Mail. 38. As undersigned counsel does not have confirmation that Attorney Radcliff is authorized to accept service as of the time of filing the within petition, undersigned counsel is also personally serving the petition on the Respondent. 5 WHEREFORE, Petitioner respectfully requests that this Honorable Court award the following relief: (a) Enter a Preliminary Injunction in favor of the Petitioner and his family as against the Respondent; (b) Order and direct the Respondent to have no contact with the Petitioner and his family, including but not limited to through third parties, at their home, places of employment, the minor children's schools, or any other location in which they may be found; (c) Order Respondent to be responsible for any court costs and attorney's fees associated with the filing of this action; and (d) Award such other relief, as the Court deems appropriate. Respectfully submitted, DATE ABOM & KUTULAKIS, L.L.P. J ,,/' "..,' K'a.Tlai L; .-- 6r Jason P. Kutulakis Supreme Court ID 1 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attornry for Petitioner 6 VERIFICATION PURSUANT TO Pa.R.C.P. 1024(c) Jason P. Kutulakis, Esquire, states that he is the attorney for the party filing the foregoing document; that he makes this affidavit as an attorney, because the party he represents lacks sufficient knowledge or information upon which to make a verification and/ or because he has greater personal knowledge of the information and belief than that of the party for whom he makes this affidavit; and/or because the party for whom he makes this affidavit is outside the jurisdiction of the court, and verification of none of them can be obtained within the time allowed for the filing of the document; and that he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification of authorities. Date: October 26, 2006 ~rwJi) wason P. Kutulakis, 7 CERTIFICATE OF SERVICE AND NOW, this 26th day of October, 2006, I, Jason P. Kutulakis, Esquire, of ABOM & KUTUL4KIS, UY, hereby certify that I did serve a true and correct copy of the foregoing Petition for Preliminary Injunctive Relief in the manner indicated below and addressed as follows: Wa Facsimile and United States Mail: Diarie G. Radcliff, Esquire 3448 Trindle Road Camp Hill, P A 17011 Wa Personal Service: Lorien Perkins-Mickelson 1811 Knights Circle Coantonment, Florida 32533 Date -1Il1 Zl; I rll~ Respectfully submitted, ABOM & KUTULAKIS, L.L.P. t4~1D ~Jason P. Kutulakis 36 South Hanover tteet Carlisle, Pennsylvania 17013 (717) 249-0900 ID# 80411 (") ,-- :":y :'?;.. .... "'.." <.::::> c;::) ~ o C) --i r--.) m -0 -.... -- o .." :r nlflJ -r.m -:'10 C) 1) -:;J~i ',':;.- 'k'rl {o(. ("") ....;...rn ,....-l ~-l S; ~ 04-:- C> KIRK A. PERKINS, Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTI, P A v. NO. 06-6214 CIVIL TERM LORIEN A. PERKINS-MICKELSON, Respondent CIVIL ACTION - EQUITY JURY TRIAL DEMANDED NOTICE TO DEFEND 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 without further notice, for any money claimed in the Complaint or for any other claim for 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNIY BARASSOGATION 32 SOUTI-I BEDFORD STREET CARUSLE, PA 17013 (717) 249-3166 OR (800)990-9108 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas sigiuentes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. U sted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATEMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DlRECCION SE ENCUENTRA ESCRITA ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNIY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARUSIE, P A 17013 (717) 249-3166 OR (800)990-9108 KIRK A. PERKINS, Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A v. NO. CIVIL TERM LORIEN A. PERKINS-MICKELSON, Respondent CIVIL ACTION - EQUITY GQM:fLAlN'f IN EQUITY AND NOW, comes the Petitioner, Kirk A. Perkins, by and through his counsel, Jason P. Kutulakis, Esquire, of ABOM & KUTULAKIS, L.L.P., and files this complaint, and in support thereof avers as follows: 1. Petitioner, Kirk A. Perkins, is an adult individual who resides at 6030 Creekview Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Petitioner resides at the above address with his wife, Nancy E. Perkins, Mrs. Perkins' adult daughter, Becky Eichelberger, and her minor daughter, B.E., age two (2). 3. Respondent, Lorien Perkins-Mickelson, is an adult individual who is believed to reside at 1811 Knights Circle, Coantonment, Florida, 32533. 4. The Petitioner, Kirk A. Perkins, is represented by John A. Abom, Esquire, of Abom & Kutulakis, L.L.P., in a Petition to Vacate Divorce Decree and related pleadings. 5. Respondent is represented by Diane Radcliff, Esquire in her Petition to Vacate Divorce Decree and related pleadings. 6. Due to the allegations being made in the Petition to Vacate Divorce Decree and related pleadings, criminal charges were filed against the Petitioner, Mr. Perkins, in Dauphin County, Pennsylvania. 7. On or about September 12,2006, Petitioner, Mr. Perkins, was acquitted of all charges in a bench trial before the Honorable Lawrence F. C1ark,]r. 8. On or about September 28-29,2006, Petitioner received multiple telephone calls from the Respondent that were threatening and harassing in nature. 9. Petitioner, Mr. Perkins, recognized the voice of the caller as his ex-wife, Respondent, Lorien Perkins-:Micke1son. 10. Upon answering the second telephone call on September 28, 2006, the caller stated, "this is your ex-wife" and the Petitioner, Mr. Perkins, directed that she was not to call his home any more and all conversations should occur between their attorneys. 11. Mr. Perkins answered the third telephone call and the Respondent proceeded to threaten and swear at him at which time Mr. Perkins once again advised the Respondent to cease calling his residence. 12. The Respondent proceeded to call an additional four to five times and hung up when the answering machine picked-up. 13. Respondent called again and left a message in which she stated, "Hi, sweetie you know who this is, I know that Lori isn't home right now." 2 14. The final telephone called came in at approximately 12:30 a.m., on September 29, 2006, in which the Respondent left a message making slanderous remarks regarding Judge Clark, Mr. Abom and the Petitioner himself. 1S. Due to the Petitioner no longer answering his home telephone, the Respondent called Mr. Perkins' cell phone and left a detailed message including accusations and profanity. 16. On the same dates, Mr. Abom also received multiple hang-up telephone calls in the middle of the night that are believed to be from the Respondent. 17. It is believed and therefore averred that the chambers of The Honorable Judge Clark received a harassing telephone call from the Respondent. 18. It is believed and therefore averred that all above-referenced telephone calls originated from a T-Mobile telephone out of Tampa, Florida. 19. On or about October 24,2006, Petitioner received a telephone call at 9:23 p.m., at his home residence. 20. Petitioner received three (3) hang-up telephone calls prior to answering the telephone. 21. Upon answering the fourth phone call, the caller stated, "pay your fucking bills, you fucking asshole." 22. The Petitioner, Mr. Perkins, believes and therefore avers that the caller is the Respondent. 3 23. Petitioner, Mr. Perkins, directed the Respondent to cease calling and stated that he would be contacting the local police department. 24. In a subsequent telephone call, Respondent stated that "Kirk was a fucking cheat and liar" and proceeded to state that "[she] was not going to be going away and they should get used to it." 25. Respondent then called another time; however, Petitioner did not answer the telephone call. 26. Petitioner proceeded to disconnect the telephone in order to stop the threatening and harassing telephone calls. 27. Petitioner has retained copies of all voicemail messages left on his answering machine. A transcript of the messages shall be provided to the court. 28. Petitioner, Mr. Perkins, learned that his counsel, Mr. Abom received two harassing and threatening telephone calls at his home residence that same everung. 29. On or about October 24, 2006, Petitioner, Mr. Perkins proceeded to contact the Hampden Township Police Department to report the threatening and harassing telephone calls that he and his wife received that evening. 30. On October 25, 2006, Petitioner, Mr. Perkins, contacted his attorney and requested that the within Petition be filed in an effort to cease all contact with the Respondent whatsoever. 4 31. It is believed and therefore averred that Respondent's inappropriate behavior is escalating in its threatening and harassing nature. 32. It is believed and therefore averred that the escalation of Respondent's behavior is the reason the filing of the within Petition has become necessary. 33. Petitioner requests This Honorable Court to enjoin the Respondent from making any contact, harassing or otherwise, with him or his family. 34.John A. Abom is filing a similar complaint for equitable relief simultaneously with the filing of this complaint. 35. The law firm of Abom & Kutulakis, L.L.P. contacted Diane Radcliff, Esquire to inquire about accepting service of the within complaint, and Ms. Radcliff advised that she would contact her client to detennine that she is authorized to do so. 36. As Attorney Radcliff represents the Respondent in the Petition to Vacate Divorce Decree and related pleadings, undersigned counsel is serving Attorney Radcliff of the within complaint via facsimile and United States Mail. 37.As undersigned counsel does not have confirmation that Attorney Radcliff is authorized to accept service as of the time of filing the within complaint, undersigned counsel is also personally serving the complaint on the Respondent. 5 WHEREFORE, Petitioner respectfully requests that this Honorable Court award the following relief: (a) Order and direct the Respondent to have no contact with the Petitioner and his family, including but not limited to through third parties, at their home, places of employment, the minor children's schools, or any other location in which they may be found; and (b) Award such other relief, as the Court deems appropriate. Respectfully submitted, ABOM & KUTULAKIS, L.L.P. DATE-IRlll/O& ~w.H {rr- Jason P. Kutulakis / Supreme Court ID 80 11 36 South Hanover Street Carlisle, Pennsylvania 17013 [117) 249-0900 Attorney for Petitioner 6 VERIFICATION PURSUANT TO Pa.RC.P. 1024(c) ] as on P. Kutulakis, Esquire, states that he is the attorney for the party filing the foregoing document; that he makes this affidavit as an attorney, because the party he represents lacks sufficient knowledge or information upon which to make a verification and/ or because he has greater personal knowledge of the information and belief than that of the party for whom he makes this affidavit; and/or because the party for whom he makes this affidavit is outside the jurisdiction of the court, and verification of none of them can be obtained within the time allowed for the filing of the document; and that he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification of authorities. 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