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Home My WebLink About06-6933 0-. . .. JORDAN D. CUNNINGHAM CUNNINGHAM & CHERNICOFF, P.c. 2320 NORTH SECOND STREET HARRISBURG, P A 17110 TELEPHONE: (717)238-6570 FACSIMILE: (717) 238-4809 EMAIL: JCUNNINGHAM({V.CCLAWPC.COM A TTORNEYS FOR PLAINTIFF WILLIAM O. GEORGES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 0 ~ - ~ 9 '3:5 ELAINE A. GEORGES, Defendant CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is William O. Georges, residing at 2003 Raleigh Road, Hummelstown, Dauphin County, Pennsylvania. 2. The Defendant is Elaine A. Georges, residing at either 252 Stonehedge Lane, Mechanicsburg, Cumberland County, Pennsylvania or 707 Hill Top Drive, New Cumberland, Cumberland County, Pennsylvania. 3. The Plaintiff seeks physical and legal custody of the following child: NAME PRESENT RESIDENCE DATE OF BIRTH William O. Georges, Jr. 252 Stonehedge Lane February 20,2003 Mechanicsburg, P A 17055 ,. . 40 The child was born in of wedlock. The child is presently in the custody of Elaine A. Georges, who resides at 252 Stonehedge Lane, Mechanicsburg, Cumberland County, Pennsylvania. During the past five (5) years, the child has resided with the following persons and at the following addresses: DATES PERSONS RESIDING ADDRESS (a) 02/2003 - 10/2006 William O. Georges and Elaine A. Georges 252 Stonehedge Lane Mechanicsburg, P A (b) 10/2006 - present Elaine A. Georges 252 Stonehedge Lane Mechanicsburg, P A (c) 10/2006 - 11/2006 William O. Georges 2015 D S. Point Drive Hummelstown, P A (d) 11/2006 - present William O. Georges Inga Georges (sister) Kenneth Hoch-Georges (nephew) 2003 Raleigh Road Hummelstown, P A The mother of the child is Elaine A. Georges, currently residing at 252 Stonehedge Lane, Mechanicsburg, Cumberland County, Pennsylvania. She is married to but separated from Plaintiff. The father of the child is William O. Georges, currently residing at 2003 Raleight Road, Hummelstown, Dauphin County, Pennsylvania. He is married to but separated from Defendant. 2 ~ ... .. ." 4. The relationship of Plaintiff to the child is natural father. The Plaintiff currently resides with the following persons: NAME Inga Georges RELATIONSHIP Sister Kenneth Hoch-Georges Nephew 5. The relationship of Defendant to the child is that of natural mother. The Defendant currently resides with the following persons: NAME nJa 6. Plaintiff has not participated as a party or witness, or in another capacity, in other RELATIONSHIP litigation concerning the custody of the child in this or another Court. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because the Plaintiff can provide a stable, safe, and secure environment and can provide for the child's emotional, psychological and spiritual needs. Further, the child views the Plaintiff as a source of stability, a source of love, and a source of emotional support. 3 . .. 8. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child has been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child has been given notice of the pendency of this action and the right to intervene: None. WHEREFORE, Plaintiff requests the Court to grant shared legal and primary physical custody of the child to the Plaintiff. Respectfully submitted, Date: H/21/~ By: rdan D. .D. #231 4 2320 North Second Street P. O. Box 60457 Harrisburg, P A 17106-0457 Telephone: (717) 238-6570 Attorneys for Plaintiff F:\HOME\AHEWITT\DOCS\G-I\GEORGEWM\CUSTODY\COMPLAIN. WPD 4 " .... , . . VERIFICATION I verify that the statements contained in the foregoing 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. 94904, relating to unsworn falsification to authorities. Dated: '0\ C\ ~ \)~/ ~ William O\yorges l_.~~___.._// 0 1"00.,) ~ C <:::> ~ = ~ <.- en ~ ~ '- .~f"( a :i! ~ "'- ,.,., ~ ~ -i':-:: ('J 01fJ1 ':/) I -om C;- -"6 ~ ..F -1-..) ~. ~ !,:~; 0 ~ -~j "T a.. J> -0 -L-n - ~ ::r ')0 () ~ J~ om ~ ~ Y-! -,-1 (..,) ~ ~ a -< ""'" WILLIAM O. GEORGES PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-6933 CIVIL ACTION LAW ELAINE A. GEORGES DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, December 11, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, January 04, 2007 , the conciliator, at 1:30 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special ReHef orders. and Custody orders to the conciJiator 48 hours prior to scheduled hearinf. FOR THE COURT. By: Isl Dawn S. Sunday. Esq. V ur/ . 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 infonnation 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 HA VE 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 ~p $- ~ ~ 117. JI-r:/ ~ 'P- -f> . ~ fp ~ 'P'- .~ "7i? Nt'/ ~ ~ ~~';4/ov.~ ~'/I.'{'/ '1 r'f\ "J:Jd 1./11\1\:11\' ',(,.".1 ,r'"J _ j' "" "", r":^'f"\l"\ I I Nr\(('1 ':~!+.1~ It..) 1\.1J I". 9 I : 1 t,ld II :330 900l ltl\,f I (";I'\i:HJn~d 3H1 :10 AOV.J. J,I,.i ir-' .1'j~"'1l~-j :DH:H/'Uj ,_ JORDAN D. CUNNINGHAM, ESQUIRE SUPREME COURT LD. 23144 CUNNINGHAM & CHERNICOFF, P.C. 2320 NORTH 2ND STREET P,O. Box 60457 HARRISBURG, P A 17106-0457 TELEPHONE: 717-238-6570 FACSIMILE: 717-238-4809 ATTORNEYS FOR PLAINTIFF WILLIAM O. GEORGES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2006-6933 ELAINE A. GEORGES, Defendant CIVIL ACTION - CUSTODY STIPULATION OF PARTIES AND NOW, Plaintiff, William O. Georges, and Defendant, Elaine A. Georges, do hereby stipulate and agree as follows: 1. Plaintiff, William O. Georges (hereinafter referred to as "Father") and Defendant, Elaine A. Georges (hereinafter referred to as "Mother") agree to the following interim schedule of periods of partial custody of the parties' minor son, William O. Georges, Jr., date of birth February 20, 2003 without prejudice to either party: a. Sundays: Father shall have custody of the minor child every Sunday, beginning at 9:30 a.m and terminating at 5:00 p.m. b. Transportation: Father shall be responsible for the pick up and re-delivery of the minor child at 707 Hilltop Drive, New Cumberland, P A. 2. Mother, Elaine A. Georges, shall have custody of the minor child at all other times not covered by this Agreement. 3. This Interim Agreement shall expire upon the entry of a new Order of Custody. . 4. It is the intent of the parties that the terms of this Stipulation be incorporated into an Interim Order to be issued by this Court. 2 . ' IN WITNESS WHEREOF, the parties hereto have placed their hands and seals to this Stipulation this --Lf.- day of ~C(2ifA k2006. ~~-~~ William O. Georges 6 F:\HOME\AHEWITT\DOCS\G-I\GEORGEWM\CUSTODY\STIP 1213. WPD\file no. 401706 3 " - JORDAN D. CUNNINGHAM CUNNINGHAM & CHERNICOFF, p,c. 2320 NORTH SECOND STREET HARRISBURG, PA 17110 TELEPHONE: (717) 238-6570 FACSIMILE: (717) 238-4809 EMAIL: JCUNNINGHAMCmCCLAWPC.COM ATTORNEYS FOR PLAINTIFF WILLIAM O. GEORGES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 2006-6933 ELAINE A. GEORGES, Defendant CIVIL ACTION - CUSTODY PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Please filed the attached as Proof of Service in the above captioned matter indicating service of the Custody Complaint in this matter on December 5, 2006. dan Cunningham, Esquire LD. #23144 2320 North Second Street P.O. Box 60457 Harrisburg, P A 17106-0457 Telephone: (717) 238-6570 F:\HOME\AHEWITT\DOCS\G-I\GEORGEWM\CDSTODY\PRFSER V. WPD Dated: December /J, 2006 By: ~ - <')( NiJI I { , ) \ 11 f l r f J f 11' )[ ( lli )r. "J, I ( )",)~ I, I v! ! . Complete Items 1, 2, and 3. Also complete item 41f Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpi13Ce. or on the front if space permits. D Agent D Addressee C. Date of Delivery DYes Mll!f I:] -.: .."........!l'''''~ ~"u xpress Mail D Return Receipt for Merchandise DC.a.D. 4. Restricted Delivery? (Extra Fee) Dyes 2. ArticleNumber MAAr, J~3r..... r-v'"-.^? 0 'I (Transfer from saNies label) fl.J'-.J...J V \....) ~ 3}, 2; '7/01 J PS Form 3811. August 2001 102595-02-M-1540 --"""" A~l + t# .- CERTIFICATE OF SERVICE I do hereby state that on the ~ day of December, 2006, I served a true and correct copy of the foregoing in the captioned matter, by placing the same in the United States mail, first- class, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Maria P. Cognetti, Esquire Cognetti & Associates 210 Grandview Avenue Suite 102 Camp Hill, P A 17011 9 ~---;.. ?~ (:;? C,.J.""'" CJ \"f~l ('"'i co ~ .-1 L:-n f\1p. n', CJ {L, ':'1 ~ - ~-~ ::';~f. " l ':::\ d6 :..::.. - - <.J"l cr. ". JORDAN D. CUNNINGHAM CUNNINGHAM & CHERNICOFF, P.c. 2320 NORTH SECOND STREET HARRISBURG, PAl 711 0 TELEPHONE: (717) 238-6570 FACSIMILE: (717) 238-4809 EMAIL: JCLJ\\iI\iGIli\l\il(([)CCL.AWPC.COM A TTORNEYS FOR PLAINTIFF WILLIAM O. GEORGES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2006-6933 ELAINE A. GEORGES, Defendant CIVIL ACTION - CUSTODY MOTION OF COUNSEL FOR LEAVE TO WITHDRAW APPEARANCE 1. Petitioner is Jordan D. Cunningham, Esquire, who presently is the attorney of record for the Plaintiff, William O. Georges, in the above captioned matter. 2. Plaintiff and Defendant are involved in a custody action docketed to the above number and term. , 3. Defendant has filed a Petition for child support and a domestic relations hearing was held on December 18, 2006. 4. During and subsequent to the domestic relations hearing, Defendant's counsel brought certain information to the attention of the Petitioner which information Petitioner attempted to confirm through independent third parties and the Plaintiff. 5. As a result of Petitioner's inquires, it has become apparent that professional considerations require termination of Petitioner's representation of Plaintiff, William O. Georges. Full explanation is impossible without violation of the attorney/client privilege. 6. Petitioner orally advised Plaintiff of his position and his intent to file this Petition and confirmed the notice in writing to the Plaintiff. A true and correct copy of said correspondence is attached hereto, made part hereof, is incorporated by reference, and is marked Exhibit "P-1". 7. Your Petitioner is serving a copy of this Motion on the Plaintiff, William O. Georges, and a Certificate of Service is attached hereto. 8. Counsel for the Defendant, Maria Cognetti, Esquire, has been notified of your Petitioner's intent to file this Petition. 2 9. A Stipulation for Interim Custody of the parties' minor child has been executed by the parties and the Court's execution of a Proposed Interim Order of Custody incorporating the terms of the parties' Stipulation is pending. WHEREFORE, your Petitioner respectfully requests your Honorable Court to grant Petitioner leave to withdraw his appearance for the Plaintiff, William O. Georges, in this matter and, in the interim, continue the custody conciliation conference until Plaintiff, William O. Georges, can secure replacement counsel. Respectfully submitted, Date: December J1. ,2006 By: d .D.# 2320 orth Second Street Harrisburg, P A 17110 Telephone: (717) 238-6570 F:\HOME\AHEWITT\DOCS\G-I\GEORGEWM\CUSTODY\PETWDRA W. WPD 3 Exhibit "P-l" "" JORDAN D. CUNNINGHAM ROBERI' E. CHERNlCOFF MARC W. WITZIG BRUCE J. WARSHAWSKY JOHN M. HYAMS KELLY M. KNIGHT CUNNINGHAM & CHERNICOFF, P.C. ATTORNEYS AT LAW P.O. BOX 60457 HARRISBURG, PENNSYLVANIA 17106-0457 HERSHEY TELEPHONE (717) 534-2833 IRS NO. 23-2274135 Street Address: 2320 N. 2nd Street Harrisburg, PA 17110 TELEPHONE (717) 238-6570 FAX (717) 238-4809 December 21, 2006 William Georges 2003 Raleigh Road Hummelstown, P A 17036 Re: Georges v. Georges (Custody) Our File No. 429706 Dear William: The purpose of this letter is to confirm the substance of our telephone conference of this date. During our telephone conference, I indicated to you that my further involvement in this case was not in your best interests as I could not advance your interests to the best of my ability based upon the matters which you and I discussed. I indicated to you that I would be filing a Petition to Withdraw my representation and I would forward a copy of the same to you. It is my belief that the Court will enter an Order known as a Rule to Show Cause why my representation should not be withdrawn. I will provide a copy of this Rule to you. If you do nothing in the period of the time set by the Court, the Court will then enter an Order allowing me to withdraw my interest. If any portion of this letter does not comport with your understanding of our telephone conference, please contact me. Very truly yours, ERNICOFF, P.C. JDC/alh enclosure F:\HOME\AHEWITI\DOCS\G-I\GEORGEWM\CUSTODY\L 1221 06. WPD r" CERTIFICATE OF SERVICE I do hereby state that on t~ day of December, 2006, I served a true and correct copy of the foregoing in the captioned matter, by placing the same in the United States mail, first- class, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Maria P. Cognetti, Esquire Cognetti & Associates 210 Grandview Avenue Suite 102 Camp Hill, PA 17011 William Georges 2015 D South Point Drive Hummelstown, P A 17036 ----.. Angela L. Hewit Legal Secretary l~ "'" -) DEe 18 m,,1 WILLIAM O. GEORGES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2006-6933 ELAINE A. GEORGES, Defendant CIVIL ACTION - CUSTODY INTERIM ORDER OF COURT "\\ AND NOW, this l.fo day of n a.t.e.~,tl , 2006, the parties, Plaintiff, William O. Georges, and Defendant, Elaine A. Georges, having reached agreement regarding periods of partial custody of the parties' minor child, William O. Georges, Jr., date of birth February 20, 2003, it is hereby ORDERED and DECREED as follows: 1. Plaintiff, William O. Georges (hereinafter referred to as "Father") and Defendant, Elaine A. Georges (hereinafter referred to as "Mother") agree to the following interim schedule of periods of partial custody of the parties' minor son, William O. Georges, Jr., date of birth February 20,2003: a. Sundays: Father shall have custody of the minor child every Sunday, beginning at 9:30 a.m and terminating at 5:00 p.m. ......) c.::'.:.> .:::::-:, c:::;...... o 11 :r! i"'iljJ1 -D(~ -~; (:=; "":-3(J) -';-:T. ") ::-rj '0'.. '-) ;5 IT) -"'f ~;;". .;0 --< t::J :---;-1 C) f'0 01 :f~ ':-? c.." ....... ~ .. b. Transportation: Father shall be responsible for the pick up and re-delivery of the minor child at 707 Hilltop Drive, New Cumberland, PA. 2. Mother, Elaine A. Georges, shall have custody of the minor child at all other times not covered by this Agreement. 3. This Interim Agreement shall expire upon the entry of a new Order of Custody. 4. It is the intent of the parties that the terms of this Stipulation be incorporated into an Interim Order to be issued by this Court. BY THE COURT, ~t J. ,~\ WILLIAM O. GEORGES, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-6933 CIVIL ELAINE A. GEORGES, DEFENDANT CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this 2nd day of January, 2007, upon consideration of the Petition to Withdraw as Counsel filed by the Petitioner, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Plaintiff to show cause why the Petitioner should not be granted permission to withdraw as counsel of record; 2. The Plaintiff will file an answer on or before January 22, 2007; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Petitioner shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Plaintiff files an answer to this Rule to Show Cause, and the answer raises disputed issues of material fact, an evidentiary hearing will then be scheduled. The Prothonotary is directed to forward said Answer to this Court. By the Court, ~an D. Cunningham, Esquire Petitioner ~m O. Georges, Plaintiff ~ia Cognetti, Esquire -\ Attorney for Defendant J. bas JORDAN D, CUNNINGHAM CUNNINGHAM & CHERNICOFF, P.C. 2320 NORTH SECOND STREET HARRISBURG, PA 17110 TELEPHONE: (717) 238-6570 FACSIMILE: (717) 238-4809 EMAIL: JCUNNINGHAM(d.J.ccLAWPC.COM ATTORNEYS FOR PLAiNTiFF WILLIAM O. GEORGES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2006-6933 ELAINE A. GEORGES, Defendant CIVIL ACTION - CUSTODY MOTION TO MAKE RULE ABSOLUTE 1, Petitioner, Jordan D. Cunningham, Esquire, filed a Motion of Counsel for Leave to Withdraw Appearance in the above captioned matter on or about December 22, 2006. 2, This Court filed Rule to Show Cause on January 2, 2007 directing Respondent, William 0, Georges to file cause, if any he had, why the Motion of Counsel for Leave to Withdraw Appearance should not be grant on or before January 22, 2007. " 3, Your Petitioner served Respondent with a copy of this Court's January 2, 2007 Order on January 4, 2007, via U.S. Mail. A true and correct copy of the January 4, 2007 letter with the attached Order of Court is attached hereto, made part hereof, is incorporated herein and is marked as Exhibit "A". 4. The January 4, 2007 correspondence has not been returned to Petitioner. 5, Respondent, William O. Georges, verified receipt of Petitioner's January 4, 2007 correspondence. 6. The date on which Respondent was ordered to responded by has past and Respondent failed to file any response. WHEREFORE, Petitioner, Jordan D, Cunningham, Esquire, respectfully requests this Honorable Court to enter an Order withdrawing his appearance, and that of the law firm of Cunningham & Chernicoff, P,C., as counsel for Respondent, William O. Georges, in the above captioned matter. Respectfully submitted, Date: January ;1 ' 2007 By: unningham, Esquire 144 232 orth Second Street Harrisburg, P A 17110 Telephone: (717) 238-6570 F:\HomeW-lEWITT\DOCS\G-I\GEORGEWM\CUSTODY\MOTION TO MAKE RULE ABSOLUTE.wpd 2 Exhibit "A" JORDAN D. CUNNINGHAM ROBERT E. CHERNICOFF MARC W. WITZIG BRUCE J. WARSHAWSKY JOHN M. HYAMS KELLY M. KNIGHT CUNNINGHAM & CHERNICOFF, P.C. ATTORNEYS AT LAW P.O. BOX 60457 HARRISBURG, PENNSYLVANIA 17106-0457 HERSHEY TELEPHONE (717) 534-2833 IRS NO. 23-2274135 Street Address: 2320 N, 2nd Street Harrisburg, PA 17110 TELEPHONE (717) 238-6570 FAX (717) 238-4809 January 4, 2007 William Georges 2003 Raleigh Road Hummelstown, P A 17036 Re: Georges v. Georges Cumberland County Court of Common Pleas Docket No. 06-6399 Our File No. 429706 (Custody) Dear Mr. Georges: Enclosed is a copy of the January 2,2007 Or 'r entered in the aboye captioned matter. , P.C. KMK./ alh enclosure F: HOl11c\AHEWITT DOCSG-I' GEORGEWM\CUSTODY]O 1 0407.wpd .. WILLIAM O. GEORGES, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-6933 CIVIL ELAINE A. GEORGES, DEFENDANT CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this 2nd day of January, 2007, upon consideration of the Petition to Withdraw as Counsel filed by the Petitioner, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Plaintiff to show cause why the Petitioner should not be granted permission to withdraw as counsel of record; 2. The Plaintiff will file an answer on or before January 22, 2007; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Petitioner shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Plaintiff files an answer to this Rule to Show Cause, and the answer raises disputed issues of material fact, an evidentiary hearing will then be scheduled. The Prothonotary is directed to forward said Answer to this Court. By the Court, Jordan D. Cunningham, Esquire Petitioner J. William O. Georges, Plaintiff Maria Cognetti, Esquire Attorney for Defendant bas , .. CERTIFICA TE OF SERVICE I do hereby state that on them day of January, 2007, I served a true and correct copy of the foregoing in the captioned matter, by placing the same in the United States mail, first-class, ~ postage prepaid, in Harrisburg, Pennsylvania, addressed to: Maria P. Cognetti, Esquire Cognetti & Associates 210 Grandview Avenue Suite 102 Camp Hill, PA 17011 William Georges 2003 Raleigh Road Hummelstown, P A 17036 ., .. j; JAN S 1 2007 fYlJ WILLIAM O. GEORGES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 2006-6933 ELAINE A. GEORGES, Defendant CIVIL ACTION - CUSTODY ORDER ALLOWING WITHDRAWING OF COUNSEL AND NOW, this 'l "A day of f' e ~ 'tu().~'i-----' 2007, upon consideration of the annexed Motion ofPlaintifPs counsel for leave to withdraw, it is hereby ORDERED and DECREED that said Motion is granted and the Petitioner, Jordan D. Cunningham, Esquire, be permitted to withdraw his appearance of record for the Plaintiff in the above matter. BY THE COURT: ~ l. \. L}\ "'" \\ 1. Distribution: Jordan D. Cunningham, Esq. 2320 N. 2nd Street, Harrisburg, PA 17110 (717) 238-6570 Maria P. Cognetti, Esq. 210 Grandview Avenue, Suite 102, Camp Hill, PA 17011 (717) 909-4060 William O. Georges, 2003 Raleigh Road, Hummelstown, PA 17036 (717) 566-7790 ~~ .:/..O;J-O ~ : inJ Of I '6 liH :) > , i;!J c - fJJ:1LOOl I! It.r' I '''''"'' /, /lOfllo...;/,C,. /:;;,j :fL/' -'0 -'7.~! ! I-:'J{,,:~':.., ...hi.! .;;/( :::J"'!~"'iL'-c137!J FEB 09 200U,,{ WILLIAM O. GEORGES Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. 06-6933 CIVIL ACTION LAW ELAINE A. GEORGES Defendant IN CUSTODY ORDER AND NOW, this 5th day of February, 2007, the conciliator, having received no request from either party or their counsel to reschedule the custody conciliation conference originally set for January 4, 2007, hereby relinquishes jurisdiction. FOR THE COURT, ~o~ Dawn S. Sunday, Esquire Custody Conciliator g ,....;) ~ c:::::l c:::::l ~ --I ...., ~~ ~~ Gl ~r.;.' ~b J'.', N :.t' " r:;c'i ~-r' ::c ' ~c; -0 05 -0 :::J: Z 5>c: t.f! om ~ ~ \.:D ;;.<,