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Home My WebLink About95-03338 RONNIE E. HONICK, SR. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : CUSTODYNISITATION . J'l? ; NO. 95_33 CIVIL TERM v. MICHELLE R. RABENSTEIN Defendant AND NOW, ,::TIA,," ~ ORDER OF COURT , 19 9S,-upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before ~. 'f.. 6-: l,uy tsq , the conciliator, at L ....0), (Un-.b, ((l. ("'.r1h>"/I on the 115'/ k day of ;!}v.,'JIAd-' , 199..2...., at )D: 3:.> . o'clock, Pm., for a Pre-Hearing Custody Conference. At such conference, an effort wilJ 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. FOR THE COURT: By: ~<-{L;~k -fi I 'J~I#L~ ~ConciliatOr -t~~1 The Court of Common Pleas of Cumberland 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. 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 nus 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. Office of the Court Administrator Cumberland County Court House, Fourth Floor Carlisle, PA 17013 (717) 240-6200 ! /.-. JUL 3 3 25 I'n '95 _, '.'.., );HlE Of .tli '!li}I1' !'f I Gill,' . ,..,1 ''JI''":!'t' "1,,1, ,. . f" ., ".;^ ,. . , t ~ ...', .. ! L ... ,ij ... 7/3/95" ad. tbf;; Iffd..d./ ~ 4- j~~ '7/3/95 ~ ~ ,0 df! '1/3/93 ~ ~eI -4. 0/1. ~ # RONNIE E. HONICK, SR., PlaintiCC v. : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . : CIVIL ACfION - LAW : CUSTODYNISITATION : NO. 95- CIVIL TERM MICHELLE R. RABENSTEIN, Defendant COMPLAINT FOR CUSTODY 1. The PlaintiCC is RONNIE E. HONICK, SR, residing at 8 Franklin Street, Lot 4, Mt. Holly Springs, Cumberland County, Pennsylvania, 17065. 2. The DeCendant is MICHELLE R. RABENSTEIN, Connerly MICHELLE R. PORTER, whose last-known residence is 1016 Hullview Avenue #A, NorColk, VA 23503. 3. Plaintiff seeks custody of the following children: NAME RESIDENCE DOB 3/22/89 AGE 6 yr. 3 mth. Autumn R. Honick Ronnie E. Honick Jr. 8 Franklin Street, Lot 4 Mt. Holly Springs, PA 17065 8 Franklin Street, Lot 4 Mt. Holly Springs, PA 17065 The children were born out of wedlock. 10/12/90 4 yr. 8 mth. The children are presently in the physical control of the Defendant, Michelle R. Rabenstein. However, in accordance with an agreement between the parties dated October 25, 1993, and since October 25, 1993, the children have been in the custody of the Plaintiff, Ronnie E. Honick, Sr. During their lives, the children have resided with the following persons and at the following addresses: NAME ADDRESS DATES Ronnie E. Honick Sr. 8 Franklin Street, Lot 4 Mt. Holly Springs, PA 17065 Michelle R. Porter, now 538 W. Louther Street Michelle R. Rabenstein Carlisle, PA 17013 10/93 to Present 4/93 to 10/93 ft> Ronnie E. Honick, Sr. (Ronnie E. Honick Jr. only) Michelle R. Porter 538 W. Louther Street (Autumn R. Honick only) Carlisle, PA 17013 8 Franklin Street, Lot 4 Mt. Holly Springs, PA 17065 1/93 to 4193 1193 to 4193 Ronnie E. Honick, Sr. Michelle R. Porter 538 W. Louther Street Carlisle, PA 17013 To 1193 The mother of the children is MICHELLE R. RABENSTEIN, formerly MICHELLE R. PORTER, who it is believed currently resides at 1016 Hullview Avenue #A, Norfolk, Virginia, 23503. She is married. The father of the children is RONNIE R. HONICK, SR., currently residing at 8 Franklin Street, Lot 4, Mt. Holly Springs, Pennsylvania, 17065. He is unmarried. 4. The relationship of the Plaintiff to the children is that of Father. The Plaintiff currently resides alone with the children. 5. The relationship of the Defendant to the children is that of Mother. The Defendant currently resides with her current husband, Edward L. Rabenstein II. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested for the following reasons: A. On October 25, 1993, Plaintiff and Defendant entered into a written agreement which provided that Plaintiff, Ronnie E. Honick, Sr., would have custody of the two children who are the subject of this Complaint. A copy of that agreement is marked Exhibit A, attached hereto, and made a part hereof. B. Since October 25, 1993, the children have continuously resided with the Plaintiff, Ronnie E. Honick, Sr., at his home at S Franklin Street, Lot 4, Mt. Holly Springs, Pennsylvania, 17065. C. Since October 25, 1993, Defendant, Michelle R. Rabenstein, formerly Michelle R. Porter, has only had sporadic contact with the children and, in fact, up until June S, 1995, had not seen them for approximately S months. D. By the agreement of the parties and at the initia lion of the Plaintiff, Ronnie E. Honick, Sr., because he thought it was in the best interest of the children, arrangements were made for Michelle R. Rabenstein to pick up the children on June S, 1995, and as part of that agreement she was to return them to Plaintiff on Father's Day, June IS, 1995. E. The Defendant has failed to return the children to the Plaintiff as previously agreed upon, has failed to contact the Plaintiff regarding the children's whereabouts, and when Plaintiff has attempted to phone Defendant Plaintiff has been advised that the phone has been disconnected. F. Plaintiff has undertaken and performed the primary parental responsibilities for the children and specifically has been their primary caretaker since October 1993. G. Plaintiff is bcst able to provide thc carc and nurture which the children need for healthy dcvc10pmcnt and, in fact, thc children have consistently bcen enrollcd at the Bethel Christian Acadcmy which Plaintiff has paid for. H. A court ordcr of custody is nccessary so that thcre are no misunderstandings rcgarding custody and partial custody and so that the children are not used in a manipulative fashion. I. Plaintiff desires to maintain the family household which has been established since October 1993 and thc continucd stability of the household is in the best interest of the children. J. Defendant is erratic and apparcntly attempted suicide in approximately April 1994, and her behavior poscs a threat of harm to the children. 8. Each parent whose parental rights to the children havc not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff respectfully rcquests this Honorable Court to enter an order granting custody of the children to Plaintiff. Rcspectfully submitted, ANDREWS & JOHNSON Ronald E. Jo s Attorney for I' tiff 78 West Po f t Strcct Carlisle, P~ 17013 Tclephone: (717) 243-0123 Supremc Court Ib No. 16453 ~ COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of IS Pa.C.S. g4904, relating to unsworn falsification to authorities. DATE: c"TuAJ' p~ 9-r ~~.~;/ Ronnie E. Honic , Sr., Plainl1ff ':-;"~:.~~:~~~:-~~:~::~,':::.:::.;.", ~.:.':~':'7:~~.._~::':~'.7;~ :~-~.: "" . ! .... .~ .,., . . . .. ~':' ~_............ , 6f10lS; /7'93 O~ ,4~/,~;4?E/U1 1 ~;AJ/~' c! /L,'cJ ,H~J ~c~~ z g~1/f" 'fY~f<:' ~I ~~~~ cr. 4/c~~ /A.JI'/I- ~A(J<- i euslcct/ .3';: oU'~ 7UJO ~,;{/~/J, !A~/F7~ )(~/l~ /~/'c/ ~d ~/wE. E, #,v/c/( -r-4k /N~O ?VI'/( ,}z AiS~ 5r;1/:;:;- :14/ ,8- frHNPt $1 o~ (1~ 4f~~.5, ~C:I7~& . ~/C c: :7 i to 6 I' 5 \ ~ U ,'I\..l t9 /071 #;r.A!!"...-e/', chI! d 1Ci.^J <2.U<i-tey o1k<i.K W ~ ~k5N e>~A ~1\~ ON /1- '5"- 93 ~t:At,l~ R i ;:z,&,<'.:!:>j /rJ ~~j(~Nds ~{ftJ;ef.:s ' slL I IV/It ~f.56 ,,5.4t.1'L /k Ch/~~A.J /I- ~A//' /1 ~7 6MJ /1/1 Aol"t'l1ys /?/Vd ~~C,l~/ oce /9.;5/0"/f./..:3 :5ucf{, I,4S };I'~d~/,.s c>r<: /Z~l~/;v'i.5 UISI/,'tj9"" /11 - e:2S'- 73 l 0 -;;":5" . 'lJ.. I :1~ ~ ~~ OrJJwuo?y'/ /C{q3 ~~~~~~J~L,;t . "" .~.. I.~l/.'.. \1 ~.. I f ~I.:~....;. 'rCIl-:-: ~'t":.R', '::1;:1. r I' O:;Arctlt.Ll 60F\tllh~l, (1.11l'r:( fit Al;("l UJUPtlV _ H\' l:OMMI~SION [~pr~lS AH\II ..Z '~97 ..............-..-- e,K /I ::::J . .. ..... .r:>- ~ -r"- Q..; "', I ..- N ufOl,:..;<j r:) 4:;;;-:"~ t'o... ;'; jl:- ~:~ ,! - ,;;.'.oj.-.' ",o" ~i 1'1 ~ """":1':;; .,;,.[jj!,o.J ,~~ :.~;'" \~ ",'.' '1j ~ \'i t') \ '1~ ~\) ~ ^~ " \:P ~~ ~~ J ~ ~ ~ ~ -4-< - O!~ it z ~] 0 -~U@i cn~1 ~ I ~ r- I~ ~ ~~ ~~ r · . I i~I~~ d~1 . a: w > i ! ~I~!~ ~ u2B !fl ~<~ . . .' . . . . . /If. ~l'<{ f; ,. -. Ju~ 29 RONNIE E. HONICK, SR., Plaintif~, : I l~f~ '9~N THE COURT OF COMMON PLEAS OF . , ":' : CUMBERLAND COUNTY, PENNSYLVANIA !:', ~I.:, ~ ,> , v. ,: ,; CIVIL ACTION - LAW MICHELLE R. RABENSTEIN, Defendant . . . . 95-3338 CIVIL TERM IN RE: CUSTODY TEMPORARY ORDER OF COURT AND NOW, this 29th day of June, 1995, upon consideration of the Plaintiff's Petition for Special Relief Pursuant to Pa. R.C.P. 1915.13, and following a hearing at which the Defendant did not appear notwithstanding that she was served with notice of the hearing, it is ordered and directed as follows: 1. Legal custody of the parties' children, Autumn R. Honick, born March 22, 1989, and Ronnie E. Honick, Jr., born October 12, 1990, shall be shared by the parties. 2. Primary physical custody of the said children shall be in the Plaintiff, Ronnie E. Honick, Sr. Temporary or partial custody of the children shall be in the Defendant, Michelle R. Rabenstein, on alternating weekends from 7:00 p.m. on Friday until 7:00 p.m. on Sunday, on a half-day on each holiday, and on a half-day on special occasions such as birthdays or visitation of relatives. This Order is a Temporary Order which shall remain in effect only until the custody conciliation conference - is held in this matter and further Order of Court. Both parties are advised that any violation of this Order could result in sanctions for contempt of court. By the Court, RONALD E. JOHNSON, ESQUIRE 78 West Pomfret Street Carlisle, PA 17013 For the Plaintiff Michelle R. Rabenstein 1016 HUlview Avenue, #A Norfolk, VA 23503 wcy _ ~ ~ t,/.Jq(QS' .Jl~. - RONNIE E. HONICK, SR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. MICHELLE R. RABENSTEIN, Defendant 95-3338 CIVIL TERM CERTIFICATE OF SERVICE I, Wendy C. Yinger, Court Reporter, do hereby certify that I have served a true and correct copy of the attached Order of Court by depositing the same in the United States Mail at Carlisle, Pennsylvania, first class postage prepaid, on the date indicated below, upon the following person at the following address: Michelle R. Rabenstein 1016 Hulview Avenue, #A Norfolk, VA 23505 Date: June 29, 1995 ..-..: - RONNIE E. HONICK, SR., Plaintiff v. 1 1 1 1 1 1 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MICHELLE R. RABENSTEIN, Defendant NO. 95-3338 CIVIL TERM ORDER OF COURT AND NOW, this 2{~t day of June, 1995, upon consideration of Plaintiff's Petition for Special Relief Pursuant to Pa. R.C.P. 1915.13, a hearing is SCHEDULED in this matter for Thursday, June 29, 1995, at 8130 a.m., in Courtroom No.5, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, Ronald E. Johnson, Esq. 78 West Pomfret Street Carlisle, PA 17013 Attorney for Plaintiff :re [r .t1 -l: iA-El- {: t~ , , ~ ~f ~ . ,,,,, ....t( .. viH1:",S!iH3d H""o)~ OIIV'1l31nn~ ':''lV1:'HC\llo)~'! 11li. JO 3~IHO"P-''' 56. "J EO 2 IZ NOr " RONNIE E. I-IONICK, SIt Petitioner/Pla in tiff IN TIlE couln OF COMMON PLEAS OF CUM/lEl~LANI> COUNTY, I'ENNSYLVANIA CIVIL ACTION. LAW NO. 95"33J~ CIVIL TERM CUSTOI>Y/vISITATION V. MICHELLE R. I~ABENSTElN Respondent/Defendant ORI)I~R m" COURT AND NOW, this dllY of June, 1995, in consideration of the attached Petition for Special Relief, the I'etltlon is grantcd and custody of Autumn R. Honick and Ronnie E. Honick, Jr., is hereby awarded to Petitioner, RONNIE E. HONICK, SR., pending the conciliation conference which shall be scheduled on the custody complaint which has been filed, or until further order of this Court. IT IS FURTHER ORDERED AND DECREED that Respondent, MICHELLE R. RABENSTEIN. shall inunediately deliver custody of Autumn R. Honick and Ronnie E. Honick, Jr., to the Petitioner, RONNIE E. HONICK, SR., upon service of this Order of Court. BY THE COURT: J. RONNIE E. HONICK, SR. Petitioner/Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 95- CIVIL TERM CUSTODYNISITATION V. MICHELLE R. RABENSTEIN RespondentlDefendant PETITION FOR SPECIAL RELIEF PURSUANT TO PA. R.C.P. 1915.13 Pursuant to Pennsylvania Rules of Civil Procedure 1915.13, the above-named Plaintiff, RONNIE E. HONICK, SR., by and through his attorneys, Andrews & Johnson and Ronald E. Johnson, Esquire, respectfully sets forth the following in support of his Petition for Special Relief pertaining to custody: 1. Petitioner is RONNIE E. HONICK, SR., an adult individual residing at 8 Franklin Street, Lot 4, Mt. Holly Springs, Cumberland County, Pennsylvania, 17065. 2. Respondent is MICHELLE R, RABENSTEIN, formerly MICHELLE R. PORTER, an adult individual, whose last-known residence is 1016 Hulview Avenue, #A, Norfolk, Virginia, 23503. 3. Petitioner and Respondent herein are the parents of Autumn R. Honick born March 22, 1989, and Ronnie E. Honick, Jr., born October 12, 1990, said children being the subject of this custody action. 4. Contemporaneously herewith, Petitioner has filed a Complaint for Custody. A copy of the Complaint for Custody is attached hereto for reference as Exhibit and the averments of the Complaint for Custody are incorporated herein. t..___ 5. On October 25, 1993, l'etitioner and Respondent entered into a written agreement which provided that Petitioner, Ronnie E. HOllick, Sr., would have custody of the two children who are the subjects of this custody action. A copy of that agreement is marked Exhibit A, attached hereto and made a part hereof. 6. Since October 25, 1993, the children have continuously resided with Petitioner, Ronnie E. Honick, Sr., at his home at 8 Franklin Street, Lot 4, Mt. Holly Springs, Cumberland County, Pennsylvania, 17065. 7. Petitioner herein, following the execution of the written agreement referred to in paragraph 5 above on October 25, 1993, filed a support action through the Domestic Relations Section of the Court of Common Pleas of Cumberland County. An Order of Court dated December 14, 1993, ordering the Respondent herein to pay the Petitioner support for the two children was entered based upon the agreement of the parties. A copy of the Agreement and Order of Court for support is marked Exhibit B, attached hereto and made a part hereof. 8. In support of Petitioner's averment in paragraph 6 above that the children have continuously resided with him since October 1993, a copy of a recent print-out from the Domestic Relations Office dated May 17, 1995, indicating the continuing support obligation due from the Respondent to the Petitioner is marked Exhibit C, attached hereto and made a part hereof. 9. Since October 25, 1993, Respondent, Michelle R. Rabenstein, formerly Michelle R. Porter, has only had sporadic contact with the children and, in fact, as of June 8, 1995, had not seen the children for approximately eight months prior thereto. 10. As a result of questions posed to Petitioner by the children regarding their mother and her failure to see the children, Petitioner initiated contact with Respondent and suggested that she spend some time with the children. 11. As a result of said contact, Petitioner and Respondent reached an agreement whereby Respondent was to pick up the children on June S, 1995, and return the children to Petitioner on Father's Day, June IS, 1995. 12, Respondent did not return the children as previously agreed to on Father's Day, Sunday, June IS, 1995, and in fact as of the date of the filing of this Petition Respondent has not had any contact with Petitioner. 13. Petitioner has attempted to telephone Respondent at two separate phone numbers which he had available to him and he has been advised in both instances that those telephone numbers have been disconnected. 14. Petitioner is unsure as to the whereabouts of his children and is extremely concerned regarding their whereabou ts and their safety and welfare since he has had absolutely no contact regarding their whereabouts and Respondent has breached the oral agreement previously entered into to return the children. 15. Petitioner has contacted the Mt. Holly Springs Police Department to obtain their assistance in having the children returned to him, but to date the Mt. Holly Springs Police have been unable to be of any assistance in that regard. 16. Petitioner is afraid for the safety of his children, is unsure as to where they may be, and believes that unless an immediate order granting him custody of the children pending a conciliation hearing is granted, that the Respondent will fail to respond and appear at said hearing and that the safety and best interest and permanent welfare of the children will be in jeopardy. WHEREFORE, Petitioner prays your Honorable Court pursuant to Pennsylvania Rule of Civil Procedure 1915.13 to enter an interim order granting Petitioner, RONNIE E. HONICK, SR., custody of Autumn R. Honick and Ronnie E. Honick, Jr., until the conciliation conference or until further order of this Court and to further order that Respondent deliver custody of the children immediately to the Petitioner. Respectfully submitted, ANDREWS & JOHNSON By: COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) I verify that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of IS Pa.C.S. g49Q4, relating to unsworn falsification to authorities, DATE: ~..'I ,;} I,; ?~ ?I~. ~~~/ J . Ronnie E, Hoilic, r., Petitioner . -~a1t..:::~~;;:~"': . '-:i~;::;~.'~~:.:.~~;. :.~.:;\;~:v,::::,<'/.::-: . , . ' _.__........._..u.:.....,......_~., ....... _..... ., ,. 6f10lS; /7'93 O~ ,4~~~;4?E/U11 ~;AJ/~' c! /L,'cJ ,H~J ~c~~ z ~~,,< 'fY~5<:' ~I ~~~~ cr. 4/c~~ /A.JI,'/I- ~A(J<- I euslcct/ .3';: oU'~ ~o ~.;{/~/J, I A~/F7~ )(~%~ /~/C/ ~d ~/wE. E, /A; I 'e/(E', IN.)o ?VI'/( .Jz AiS~ 5r;1/:;:;- :14/ 8 -r-4 kHNPt $1 ou"V/ (1~~ ~~s. ~'ct7..1k . Z <!: /? to 6 " 5 \ ~ U.'I\:I t9 /071 ///f'",e'",e/' Chtlct1Ci.^J <2.u<i-rey 01('\<(')(' W~~k5N e>~A ~1\~ ON /1- '5"- 93 ~t:At,l~ R ;:z,&,<'.:!:>j /rJ ~~j(~Nds ~{~Jef.s . $JL IO/If /J{56 ~/1t/!.. ;/l~ C~/~EAJ ~ hA/~ /I ~/ eN ~/I Aolt'/1ys /?/Vd ~~C,l/;/ ace /l~/O.N..:3 :5C/cf[. ,,4:5 ,b1'~;r/~yrS 01< /Z~/AliV~.5 U,SI htvj>.- I ~Wvw, ~ ~~ {Jd!~ ,xy/ I W3 ~~~ ~~"'~. , '~uTl.';' \1 s:' I f, ~;,:~~~:, ~ h)tJ:;.: f't. :.R', '~:Hl, f I i CA~l,t.ll &OFltjU\,~, Cll,.h:d';[ AI; ['I' C.OUft!V MY \~OMMI~SION EXPIHlS ^P;,U ~z 1~~1 1_ l .. /d -e2:9- 93 {O-;vs.'{J. A/ &/9 AGREEHENT rOil OIUlER or 5UI'I'OHT "bovl' llilmJd \>lailltiff and Defendant hereby ar,ree that the Defendillll shall pay the 35.00 per week for and toward the support of hilr children. Autumn R.. 22 89 and Ronnie E. born 10 12 90. There is no affordable e available at the resent time. Arreara es are set at 155 direct a ment of 20.00. Defendant to a 5 00 er wee -- IlCHELLE R. PORTER , llEn:NIlANT DR _U..H.L_ IN TIl~: COURT 01' COHMON PU:AS OF CUHBERLAND COUNTY, P~:NNSYLVAN1^ DOMESTIC R~:LATIONS SECTION CIVIL ACTION - SUPPORT NO. lliL2_ OF 1993 :ONNIE E. 1l0NICK , PLAINTlFF v. which sum shall be paid through the Domestic Relations Office, P.O. Box 320, Carlisle, PA 17013, beginning 11116/93 The Defendant agrees to pay the costs in the amount of S 16.00 which sum includes the pro-rated Service Fee of $ 1.00 , payable 90 davs fhe parties further agree to inform the Domestic Kelations uttice of any change in writing within seven days of such change. Should a party wilfully fail to inform the Domestic Relations Office of the required information, the court may adjudge the party to be in con- tempt of court pursuant to Rule 1910.21 and may order tbe party to be punished by one or more of the following: jail, fine or probation. X l./hen accumulated arrears equal or exceed one month's support obligation the Defendant 's i~me will automatically be attached. The defendant's income is attached, Dated: This 14th day of December J .' _~.1 ~ .J. ~.u_ \Htness to ignatures . , 19-21.., L/?~. , #, tit" !:, De' n~nt ORDER OF COURT AND NO\~. this 14th day of December . 19 93 . upon consideration of the above Agreement. IT IS HEREBY ORDERED AND DIRECTED that the iie1Cndant pay through the Domestic Relations Office. P.O. Box 320, Carlisle, PA 17013, the sum of S 35.00 per week for and toward the support of her children, Autumn R.. born 3/22/89 and Ronnie E.. born 19/12/90. There is no affordable medical insurance coveraRe available at the oesent time. Arrearages are set at $155.00 as of this date due to direct payment of $20.00. Defendant to pay $5.00 per week on the arrearages. The first payment shall be due on 11/16/93 and subsequent payments shall be due every week thereafter, The Defendant shall pay the costs of $ 16.00 . which sum in- cludes the pro-rated Service ree of S 1.00 ,payable 90 days IT IS FURTHER ORDERED that the parties inform the Domestic Relations Office of any change of address of any child receiving support, and/or employ",ent in writing within seven days of such change. Should a party wilfully fail to inform the Domestic Relations Office of the required infor- mation, the court may adjudge the party to be in contempt of court pursuant to Rule 1910.21 and may order the party to be punished by one or more of the following: jail. fine or pro- bation. X ~len accumulated arrears equal or exceed one month's support obligation the Defendant~ncome will automatically be attached. The Defendant's income is attached. BY THE COURT. ~ ~~ Sally S. Kreilzer Plaintiff & Defendant U;$ J. ORO: XC: -. -------, n;'197~j 11.'5 fi '1:1 filiP P !lH'1 05/\7/95 'II'NGIUN, MICliFI.II' ,t, A filii I I V H W AVI. .'FOLK, '.'/1 1 cJ 1 6'r.!'lll,;!6 II/071l1 2350~J r 0 . I 950;~0~? linN I C K. IlIlNN I E 1'. 1/25,',/,'/H5 f1 f HAN"'I 1 tI filllEr 1 O;'/O;'I'I~I IIII' IJ ~n. HDlI Y !;l'fU NG!l, I'A \70b!d 1(1(1 1 C N 4~041 :l~l. on W It 116/<,':1 l;'/;Jl/l/:1 ('", KH :15 I~!I~ 1 ~1 ." n.oc) o. DO 'IEARS 1461.58- t t /~1;2I94 40.00 PAY/"IEN rH Co. 00 n.oo 0.1)0 ';'18 15. on,. 10/~!1I94 3~~. 42 ClI/lnm H 105.00- ~!45. 00, "i/O.OO 1"-) 53.00- 10/lt/94 80.00 AD.)",} r,:; 0.00 c.. 00 a.oo \JMS 0.00 0.00 f'^YMFNH~ 0.00 0.00 0.00 'irITUl ION 0.00 0.00 PAYMENlS 0.00 0.00 O.O!) 'II II 0.00 94081EI 40.00 PAY/"lFNn: 0.00 0.00 (1,(10 0,INNING BALANCE 726.58- ';'1/94 nUl: 85.00- 761.5B- (II 1c)3/95 DUE :35.00- 1'76. 58- 0:2 105/95 FEF!i 2t.. no- 796. 58, Or.~ 110/95 DUE 35.00 - 831.58- 03 117icl~i DUl: :15. 00,- f166. 58,' 04 1~~4/95 DUE 35.00- 901.58- 05 131/95 DUF :15.00- 936. 58- 06 '/07/95 DUE 85. 00- 971. 58- 07 114/9~, DUE': 35.00" 1006.58- 08 '/21195 DUE :15.00- 1041.58- 09 '/28/'/~, nur :l~,_ 00- 1076.58- 10 1/07/95 1)1),= 35.00 . 1111.58-- 11 1/14/95 nllE :<';,00- 114b.5EI- 12 1/21/95 DUE :15.00, 1181. 58- 13 :;;'8/'15 DUE :1~,. 00-- 1;'16.5EI' 14 1/04/95 DUE 35. 00 - 1 :~51. 58- 15 ',I 111'15 DUI: :lti.OO- 12E16.5H' It. .f/18/95 DUE 35.00 - 1321. 58- 1 7 1/25/95 Dl!F' 3~I, 00- 1356. 58, 1[1 i/02/95 OUt-: 35.00- 1391 . 58 ' 19 ,,/09/95 DUE :l~j. 00- 1421>. 58,. t:!O .~ / I h/fi5 DIIE :l~;. 00" 1 4 t, 1. 58- 21 4.c... RONNIE E. HONICK, SR. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : CUSTODYNISITATI0N . : NO. 95- CIVIL TERM v. MICHELLE R. RABENSTEIN Defendant ORDER OF COURT AND NOW, , 19_, upon consideration of t~e attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the day of , 199-, at o'clock, _.m., 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. FOR THE COURT: By: Custody Conciliator The Court of Common Pleas of Cumberland 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. 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 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. Office of the Court Administrator Cumberland County Court House, Fourth Floor Carlisle, PA 17013 (717) 240.6200 f1< tJ "...~ RONNIE E. HONICK, SR., Plaintiff v. : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : CUSTODYNISITATION : NO. 95. CIVIL TERM MICHELLE R. RABENSTEIN, Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is RONNIE E. HONICK, SR, residing at 8 Franklin Street, Lot 4, Mt. Holly Springs, Cumberland County, Pennsylvania, 17065. 2. The Defendant is MICHELLE R. RABENSTEIN, formerly MICHELLE R. PORTER, whose last-known residence is 1016 Hullview Avenue #A, Norfolk, VA 23503. 3. Plaintiff seeks custody of the following children: NAME RESIDENCE DOB AGE Autumn R. Honick 8 Franklin Street, Lot 4 3122189 6 yr, 3 mth. Mt. Holly Springs, PA 17065 Ronnie E. Honick Jr. 8 Franklin Street, Lot 4 10/12190 4 yr. 8 mth. Mt. Holly Springs, PA 17065 The children were born out of wedlock. The children are presently in the physical control of the Defendant, Michelle R. Rabenstein. However, in accordance with an agreement between the parties dated October 25, 1993, and since October 25, 1993, the children have been in the custody of the Plaintiff, Ronnie E. Honick, Sr. During their lives, the children have resided with the following persons and at the following addresses: NAME ADDRESS DATES Ronnie E. Honick Sr. 8 Franklin Street, Lot 4 Mt. Holly Springs, PA 17065 Michelle R. Porter, now 538 W. Louther Street Michelle R. Rabenstein Carlisle, PA 17013 10193 to Present 4193 to 10193 ...'.... Ronnie E. Honick, Sr. (Ronnie E. Honick Jr. only) Michelle R. Porter 538 W. Louther Street (Autumn R. Honick only) Carlisle, PA 17013 8 Franklin Street, Lot 4 Mt. Holly Springs, PA 17065 1193 to 4193 1/93 to 4/93 Ronnie E. Honick, Sr. Michelle R. Porter 538 W. Louther Street Carlisle, PA 17013 To 1/93 The mother of the children is MICHELLE R. RABENSTEIN, formerly MICHELLE R. PORTER, who it is believed currently resides at 1016 Hullview Avenue #A, Norfolk, Virginia, 23503. She is married. The father of the children is RONNIE R. HONICK, SR., currently residing at 8 Franklin Street, Lot 4, Mt. Holly Springs, Pennsylvania, 17065. He is unmarried. 4. The relationship of the Plaintiff to the children is that of Father. The Plaintiff currently resides alone with the children. 5. The relationship of the Defendant to the children is that of Mother. The Defendant currently resides with her current husband, Edward L Rabenstein II. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested for the following reasons: A. On October 25, 1993, Plaintiff and Defendant entered into a written agreement which provided that Plaintiff, Ronnie E. Honick, Sr" would have custody of the two children who are the subject of this Complaint. A copy of that agreement is marked Exhibit A, attached hereto, and made a part hereof. B. Since October 25, 1993, the children have continuously resided with the Plaintiff, Ronnie E. Honick, Sr., at his home at 8 Franklin Street, Lot 4, Mt. Holly Springs, Pennsylvania, 17065. C. Since October 25, 1993, Defendant, Michelle R. Rabenstein, formerly Michelle R. Porter, has only had sporadic contact with the children and, in fact, up until June 8, 1995, had not seen them for approximately 8 months. D. By the agreement of the parties and at the initiation of the Plaintiff, Ronnie E, Honick, Sr" because he thought it was in the best interest of the children, arrangements were made for Michelle R. Rabenstein to pick up the children on June 8, 1995, and as part of that agreement she was to return them to Plaintiff on Father's Day, June 18, 1995. E. The Defendant has failed to return the children to the Plaintiff as previously agreed upon, has failed to contact the Plaintiff regarding the children's whereabouts, and when Plaintiff has attempted to phone Defendant Plaintiff has been advised that the phone has been disconnected. F. Plaintiff has undertaken and performed the primacy parental responsibilities for the children and specifically has been their primacy caretaker since October 1993. G. Plaintiff is best able to provide the care and nurture which the children need for healthy development and, in fact, the children have consistently been enrolled at the Bethel Christian Academy which Plaintiff has paid for. H. A court order of custody is necessary so that there are no misunderstandings regarding custody and partial custody and so that the children are not used in a manipulative fashion. I. Plaintiff desires to maintain the family household which has been established since October 1993 and the continued stability of the household is in the best interest of the children. J. Defendant is erratic and apparently attempted suicide in approximately April 1994, and her behavior poses a threat of harm to the children. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an order granting custody of the children to Plaintiff. Respectfully submitted, ANDREWS & JOHNSON By: Ronald E. Johnson, Esq. Attorney for Plaintiff 78 West Pomfret Street Carlisle, PA 17013 Telephone: (717) 243-0123 Supreme Court Ib No. 16453 COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of IS Pa.C.S. g4904, relating to unsworn falsification to authorities. DATE: c"TuAJ' ;1'., ?~ 6~o~~~ In ~ ;.. Jl ttY;, f:::! t, ,~ ~ L.) :.. ", :;; ~ J .,j-.l -... "; ,'~ ''oJ .. 1"; lJo; , ". ..:.~: ~~ '-)' il ~ i!~~~ ~ ~~~ ~ e!i8 J I-I !liE '" -~ ~ ti~ I ~D . ~ .~ a<J! i > ~ Ii! ~~ II z o fI):tll ~j~~!:l g~l!"e olj!!il::~ fI)~lff~ ~~~~6 ~<Ie . . . .' . - . . . ,-~--".. ,/'-) -_____<'1/ \.' '" . . . . RONNIE E. HONICK, SR. Petitioner/Pll'intiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 95- CIVIL TERM CUSTODYNISITATION V. MICHELLE R. RABENSTEIN Respondent/Defendant AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) . . COUN1Y OF CUMBERLAND ) AND NOW, this ~ "" day of 9",,-,,- , hereby swear that on June ;; ;;1 , 1995, at approximately , 1995, I, MIKE SUA W, ;;l :;;J. ~ o'clock, r:J .m., I personally served a true copy of the Order of Court scheduling an emergency , hearing regarding custody pursuant to Plaintiffs Petition for Special Relief upon the Defendant at her residence at 1016 Hulview Road, #A, Norfolk, Virginia, 23503, by handing the same to her. /~~~ d MIke Shaw Sworn and SUbSCri':'.d to before me this ';}f'~ day of r.....,.,. , 1995. t/ ~,'d_ .v ~.._u(';._ Notary Pub Ie NOTARIAl. SfAl IABlDA L 1IftEH1l. IIOTARY f1UBUC CAllUSU 1IlllO. CUII8ERlMD COUNTY llY ClIIIIIISSIOII EXPIRES JAIlUARY e. 1tlI8 :~~~:~.'-'~~:7-.~~:."'- . . '. ,. .~ . ",~'. ~.. ~ . ... ,,--~~ ....--_.~-.-...-... . " - .... - ... ..._-- ...~.'_......., 6f10l5j /7'93 O~ ,4Y;/,~;4?E/U11 ~/V/~' c! /k,'cl:. ,HAl' /7:%'c~~ ~ g~1A' ~~ ~ i euslcct/ ..~.;: DuX' 7UJO y~/C/A~:/J I At~/F7~ ;1;{1~ Atv,.c/ A d t'J",v/ll~E. E, :14/ 8r4 frHNj'tt $1 ou~/ (1~ 4f~~.5.. ~'cI7~& . & c: :7 to 6 115 \~u,'1\,) t9 /071 ~.A!!"",e~'. chi! ct1Ct^J <2.u<i-rey o1k<(.)(' w ~~k5N e>~A ~1\~ ON /1- '5"- 93 ~cAE,I~ R i ;:z,&,<'.:!:>j /rJ ~~fC~Nds c5).{M;ef~. slL /Vilt ~(.J6 ~~cJ~ /k c.4/,704'~A.J /I hAIl" ,A ~y eN ;4/1 ,ho/'l1ys I /?,;vd ~2CIA/ ace /1~/o'/LI..:3 SclC/{, ,,4S ,b1'/t!'7/~Y'rS 01'< ,R~/AI/lI~.5 Ut'SIJ,.tJj>... I i .J~I ~ ~itJ OcJo.kuo?y/ fW3 ~~_r:1dO"'~ . r ' ':0TA~'.L sr., , (,',~~.., .,... 'tOUI\"~ ~!(.' :,p.', "r,lr:l,r I' CAAli~ll fl~i~I'j:Jl1'1 i:U~ira r.lMW C.OllNTV MY t:OMM!~S'ON EXPI~(S N'RII ,2 1997 I 1:Q....... '" /d -.;<97'3 {O-"J-:S.'{i 'f/ Elc/'9 . f'\.AJtmFP8 EXHIBIT . 0- ~/o>r, W~ 0fY RONNIE E. HONICK, SR. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA : CIVIL ACTION. LAW : CUSTODYNISITATION . J'b' ; NO. 95.33 CIVIL TERM v. MICHELLE R. RABENSTEIN Defendant ORDER OF COURT AND NOW, , 19_, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counse:l appear before . the conciliator, at on the day of ,199_, at 0'c1ock, _.m" 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, FOR THE COURT: By: Custody Conciliator The Court of Common Pleas of Cumberland 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, 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 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, Office of the Court Administrator Cumberland County Court House, Fourth Floor Carlisle, PA 17013 (717) 240-6200 RONNIE E. HONICK, SR., Plaintiff : IN TIm COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACfION - LAW : CUSTODY/vISITATlON : NO. 95. CIVIL TERM v. MICHELLE R. RABENSTEIN, Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is RONNIE E. HONICK, SR, residing at 8 Franklin Street, Lot 4, Mt. Holly Springs, Cumberland County, Pennsylvania, 17065. 2. The Defendant is MICHELLE R. RABENSTEIN, formerly MICHELLE R. PORTER, whose last-known residence is 1016 Hullview Avenue #A, Norfolk, VA 23503, 3. Plaintiff seeks custody of the following children: NAME RESIDENCE DOB AGE Autumn R. Honick 8 Franklin Street, Lot 4 3/22/89 6 yr. 3 mth. Mt. Holly Springs, PA 17065 Ronnie E. Honick Jr. 8 Franklin Street, Lot 4 10/12/90 4 yr. 8 mth. Mt. Holly Springs, PA 17065 The children were born out of wedlock, The children are presently in the physical control of the Defendant, Michelle R. Rabenstein. However, in accordance with an agreement between the parties dated October 25, 1993, and since October 25, 1993, the children have been in the custody of the Plaintiff, Ronnie E. Honick, Sr. During their lives, the children have resided with the fOllowing persons and at the following addresses: NAME ADDRESS DATES Ronnie E. Honick Sr. 8 Franklin Street, Lor 4 Mt. Holly Springs, PA 17065 Michelle R. Porter, now 538 W. Louther Street Michelle R. Rabenstein Carlisle, PA 17013 10/93 to Present 4/93 to 10/93 ''j''. ~ Ronnie E. Honick, Sr. (Ronnie E. Honick Jr, only) Michelle R. Porter 538 W. Louther Street (Autumn R. Honick only) Carlisle, PA 17013 8 Franklin Street, Lot 4 Mt. Holly Springs, PA 17065 1193 to 4193 1193 to 4193 Ronnie E. Honick, Sr. Michelle R. Porter 538 W. Louther Street Carlisle, PA 17013 To 1/93 The mother of the children is MICHELLE R. RABENSTEIN, formerly MICHELLE R. PORTER, who it is believed currently resides at 1016 Hullview Avenue #A, Norfolk. Virginia, 23503. She is married. The father of the children is RONNIE R. HONICK, SR., currently residing at 8 Franklin Street, Lot 4, Mt. Holly Springs, Pennsylvania, 17065. He is unmarried. 4. The relationship of the Plaintiff to the children is that of Father. The Plaintiff currently resides alone with the children. 5. The relationship of the Defendant to the children is that of Mother. The Defendant currently resides with her current husband, Edward L. Rabenstein II. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested for the following reasons: A. On October 25, 1993. Plaintiff and Defendant entered into a written Rgreement which provided that Plaintiff, Ronnie E. Honick, Sr" would have custody of the two children who are the subject of this Complaint. A copy of that agreement is marked Exhibit A, attached hereto, and made a part hereof. 8. Since October 25, 1993, the children have continuously resided with the Plaintiff, Ronnie E. Honick. Sr., at his home at S Franklin Street, Lot 4, Mt. Holly Springs, Pennsylvania. 17065. C. Since October 25, 1993, Defendant, Michelle R. Rabenstein, formerly Michelle R. Porter, has only had sporadic contact with the children and, in fact, up until June S, 1995, had not seen them for approximately S months. D. By the agreement of the parties and at the initiation of the Plaintiff, Ronnie E. Honick, Sr., because he thought it was in the best interest of the children, arrangements were made for Michelle R. Rabenstein to pick up the children on June S, 1995, and as part of that agreement she was to return them to Plaintiff on Father's Day, June IS, 1995. E. The Defendant has failed to return the children to the Plaintiff as previously agreed upon, has failed to contact the Plaintiff regarding the children's whereabouts, and when Plaintiff has attempted to phone Defendant Plaintiff has been advised that the phone has been disconnected. F, Plaintiff has undertaken and performed the primary parental responsibilities for the children and specifically has been their primary caretaker since October 1993. G. Plaintiff is best able to provide the care and nurture which the children need for healthy development and, in fact, the children have consistently been enrolled at the Bethel Christian Academy which Plaintiff has paid for. H. A court order of custody is necessary so that there are no misunderstandings regarding custody and partial custody and so that the children are not used in a manipulative fashion. I. Plaintiff desires to maintain the family household which has been established since October 1993 and the continued stability of the household is in the best interest of the children. J. Defendant is erratic and apparently attempted suicide in approximately April 1994, and her behavior poses a threat of harm to the children. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an order granting custody of the children to Plaintiff. Respectfully submitted, ANDREWS & JOHNSON COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of IS Pa.C.S. g4904, relating to unsworn falsification to authorities, DATE: C h.,.,u, p~ ?~ L~.~~ Ronnie E. Honic , Sr., Plainllff 7tz:~."-':~~~~';~'~;'~.'~';'-'.'.-.~:..". .. :.:'....', ': . .' ... .>....._.-....~yo1''"'.....-~"W....,.-......._ 6f10lS; /7'93 O~ r1~/~/J?E/U1 1 ~;AJ/~';:" /L,'cJ ,H/V ~c~~ Z &1/t" 'fY;e'.~C:' ; eU.5~C7 .,3';: DuX' 7!.uo ~,;{Ic~~, ! ,4;'~/F7~ )(<J%~ /~/'c/ ~d C0//w:; E, #,v/C/( ,E'. IN~O ?VI'/( ,}z ~~5r;v~ ;::1/ 8 -r-4 frH^-I. 1~ $'/' ou~/ (1/t~ i tN 6 I 5 \ \ U 1'1\:} t9 /0 71 ~",e/ ' I chI! ct 1Ci.^J <2.u<i-rey 01(",<(.)(' w ~~k5N e>~A~1\~ ON 11-'5"-93 ~t:AtR~ )? ! ;:z,6,<'.:!:>j /rJ ~'l..j(~Nds ~/~~i.s .slL I IV//( /J{56 ,ht4L1!- /k c~j;A,~A.J. /l- ,,7A//' ~. ~/ eAJ ./1/1 hCJ!'ci1ys .h'/Vd ..p2C/A/ occ /1~JC/N,:5 $c.lcf[, I,4S ,b/,tf!' //~/rS C!>,e /<~/Ali(/Z..5 u, S i I,'tvy.. , I ,J'wvwJ t ~ {)d!o.k o?y/ /f{q3 ~~~~,~~~, I. :;Akl.:....l hDF:..;:j.~\1 \.11r.r-. r.~ ftl.rl r;')qfc"f ur l~OMMI!:SION l>>:PhtlS AI'::II ~~ 1~~1 ~-.._-- /tJ -e2S- 73 lO~~)5.'?3. ex /I , , : / / "1,_._ ' ~" .jJ QI QI .tl~ :Z:1Il0 o r- 1Il.jJ.... ~fl OIl-lICC hElI14 o .., 114 . QI 1Il.jJ.... ~cncn QI.... ~.-l eo:>~ :;;!r-U , I- o~ 0< ~: ,~.. . Q< cd'" <!I .. c Z... lil! ., OZ ~I VI.. ZO 1l ~~ " - , CO... 0... 5'\ilo p- 12< xE ....... '~...........-.--:'----- .~ ~.. .----:-..~ v. I I I I I I I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RONNIE E. HONICKH, SR., Plaintiff/Respondent, MICHELLE R. RABENSTEIN, Defendant/Petitioner NO. 95-3338 CIVIL TERM AND NOW, ORDER OF COURT this Z.S(t,day of August, 1995, upon consideration of Petitioner's Petition for Emergency Relief, a hearing is SCHEDULED for Thursday, October 19, 1995, at 9100 a.m., in Courtroom No.5, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, J. Ronald E. Johnson, Esq. 78 West Pomfret Street Carlisle, PA 17013 Attorney for Plaintiff/Respondent Robert L. Buzzendore, Esq. 4407 North Front Street P.O. box 5320 Harrisburg, PA 17110-5320 Attorney for Defendant/Petitioner ~,~ 8J~~/9S: ~. 'f! :rc t~HY',~ I '~;tHj)d 41Nt..JJ fJ"V":tP'iHno .~~\'1~IIOHJ.) .! ": In 'lOljji:' :" 56, Ud EE I BZ onv ,,~.. .. . . , , 'i Ii ii ii " d i' I ,I II 1 I I I Ii II II Ii Ii " Ii I' I' I I, Ii i! Ii I: 1\ Ii i' !I II II r IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA RONNIE E. HONICHK, SR., Plaintiff/Respondent, VS. I I I I I I I I NO. q5 ~ 3338 MICHELLE R. RABENSTEIN, Defendant/Petitioner. CIVIL ACTION--CUSTODY ORDER AND NOW, this day of 1995, upon consideration of the within Petition for Emergency Relief, it is hereby ordered and decreed that the June 29, 1995, Order of Court granting Plaintiff/Respondent temporary primary physical custody of the Parties' two minor children is vacated and the December 23, 1992, Order granting Defendant/Respondent primary physical custody shall be upheld and binding pending further order of court. BY THE COURT: J. II ,I II 'I Ii ,I !l , !! p ii ii il , . Ii iI i' I: I d II r I II II i- II II Ii Ii Ii Ii II I' II II I' I I II II rI Ii i I I , I II II II II II I I RONNIE E. HONICHK, SR., Plaintiff/Respondent, vs. I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA I I I NO. 'IS' 333~ I I I CIVIL ACTION--CUSTODY MICHELLE R. RABENSTEIN, Defendant/Petitioner. PETITION FOR EMERGENCY RELIEF Petitioner, MICHELLE R. RABENSTEIN, through her attorneys, Robert L. Buzzendore, and Gerald S. Robinson, of Robinson' Geraldo, requests this Honorable Court to grant her emergency relief by vacating the temporary order of court granting primary physical custody to Plaintiff/Respondent (hereinafter Respondent) and upholding the previous order of court granting Defendant/Petitioner (hereinafter Petitioner) primary physical custody. In support of this request Petitioner provides the following: 1. Petitioner is MICHELLE RABINSTEIN, an adult individual currently residing at 1016 Hulview Avenue, 'A, Norfolk, Virginia. 2. Respondent is RONNIE E. HONICK, an adult individual currently residing at 8 Franklin Street, Lot 4, Mt. Holly Springs, Pennsylvania. 3. The Parties are the natural parents of two children to wit: Autumn R. Honick, born March 22, 1989, and Ronnie E. Honick, Jr., born October 12, 1990. 4. In or around December 1992, Petitioner filed a custody action in conjunction with a Protection from Abuse action which was docketed by this Honorable Court at 4379 Civil 1992. ii 'I q " ii !i jI ! 5. On or about the 23rd day of December 1992, an Order of Court was entered relative to the custody of the above children giving Petitioner primary physical custody of the Parties' children. Respondent was given a limited custody schedule which included alternating weekends and holidays and one uninterrupted week in the summer. A copy of this order is hereto attached as "Exhibit A." 6. In or around October 1993, the Parties mutually agreed to allow Respondent to assume primary physical custody of the children, and to allow Petitioner to assume limited custody. Petitioner maintained contact with the children as often as she was permitted. 7. In or around June 1995, the Parties mutually agreed to resume their prior custody agreement as articulated in the December 23, 1992, Order of Court. 8. On or about June 21, 1995, Respondent, despite his knowledge of the December 23, 1992, custody order, filed a Petition to Confirm Custody alleging that "Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court." 9. On or about June 21, 1995, Respondent, also filed a Petition for Special Relief alleging that Petitioner had failed to return the children to him. 10. On or about June 22, 1995, Respondent and a friend traveled to Petitioner's home in virginia. When they arrived, in an apparent state of intoxication, they began threatening Petitioner and demanding that she relinquish the children. Petitioner was alone at the time and quite fearful for her health as well as that of the II II II I ii I ~ Ii II I! Ii II II I I I I I I II II I, I I i Ii II il Ii il Ii II if I, I :1 Ii , I' I " Ii ~ Ii ~ U " I: ~ children. In addition, Petitioner was experiencing difficulties with her pregnancy and was unable to aggressively react to Respondent's threats. As a result, Respondent took the children from Petitioner's home in Virginia and returned with them to Pennsylvania. Since that time, Petitioner has attempted to maintain contact with the children, but Respondent has violently and repeatedly denied her any contact. 11. On or about June 29, 1995, this Honorable Court held a hearing on Respondent's Petition for Special Relief, and entered a temporary custody order wherein primary physical custody was with Respondent. 12. Petitioner was neither aware of this hearing, nor was she able to physically travel the distance due to her current health condition. 13. As a result of the Petition to Confirm Custody filed by Respondent, a custody conciliation conference has been scheduled before Hubert X. Gilroy on October 6, 1995. 14. Petitioner has taken the steps necessary to enroll the children in school in Virginia. With the current temporary order, however, the children will be unable to attend the first days of school in Virginia, as would be proper based on the custody arrangement established by the December 23, 1992, order of court. 15. It is in the best interest of the children to be returned to Petitioner's care. i: J U f 'i " ~ , ~ ~ r j ~ u I ~ ~ ~ I I I j l ~ ~ U o r J ~ ~ Ii ~ i I: !I Ii :' ii " d Ii WHEREFORE, Petitioner prays this Honorable Court to vacate the June 29, 1995, temporary custody order, and uphold the December 23, 1992, order of court granting primary physical custody of the minor children to Petitioner pending further order of court. 'I I, !I il Ii II II Ii I' ii Ii I! Ii II Ii I: II Ii 'I 'I II Ii II II I I I II " !I II II Ii I' II II Ii 'i !, Respectfully submitted, Dated: ~I iJ-~(q5 I I By- Rob r . uzzen , Attorney I.D. . 5 7 Gerald S. Robinson, Esquire ROBINSON & GERALDO Attorney I.D. No. 27423 4407 North Front street P.O. Box 5320 Harrisburg, Pennsylvania 17110 (717) 232-8525 Attorney for Petitioner VERIFICATION I verify that the statements made in this Petition for Emergency Relief are true and correct based on information provided to me by my client. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. ~~i&~~ er L. uzze re, squ re Ii :1 Ii Ii I' ,I ii i: " Ii " , Ii , Mlcnelle Porter, Plaintiff IN THE COURT ~ COMMON PLEAS OF CUMBERLANO COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. NO. 4379 CIVIL 1992 Ronnie E. Honick, Defendant PROTECTION FROM ABUSE AND CUSTODY AND NOW, this c;eI,d ~~SlP'UY_OR!:L1;,,13 day of December, 1992, upon consideration of the parties' Consent Agreement, the fOllowing Order is entered with regard to custody of the parties' children, Autumn Robin Honick and Ronnie E. Honick, Jr. 1. The plaintiff, hereinafter referred to as the mother, will have primary physical and legal custody of the children. , 2. The defendant, hereinafter referred to as the father, will have partial custody of the childrAn evepy Dt~ar weekend from Friday at 6:00 p.m. until Sunday at 6:00. p.m. beginning December 25, 1992. 3. The father and mother will alternate Christmas Eve and Christmas Day each year, one parent having the children on Christmas Eve Day at noon until Christmas Day at noon and the other parent having the children from Christmas Day at noon until December 26, at noon with the mother having the child beginning on Christmas Eve in 1993. 4. The mother and fath,~ will share the fOllowing hOlidays, at times to be mutually agreed upon by the parties; Easter, Thanksgiving, Memorial Day. the Fourth of July, Labor Day, and New Years' Day. 5. Each party will have the right to partial custody of the : Exhibit nAn children for ono'woek of oach Gummor including two weekends. Each party will givo the other party 0 thlrty notice as to when the period of summer custody hill take place. 6. ' The mother and father. by mu tuo 1 ngreement, may vary from this schedule at any time. 7. The fLlther Vlill ,::it It:''J 1110901 dl'lIgE' or alcohol or be under the influence of illegal drugs or alcohol when the children are in his custody. 8. Each parent will notify the other immediately of medical emergencies which arise while the children are in that parent's care. 9. Neither party sholl do anythlng which may estrange the . children from the other parent. or injure the opinion of the children as to the other parent or which may hamper the free and n~tural development 01 thE children's love or respect for the other parent. By the Court. jsJlt.'!L.IL./J..~ ',,\ K~vin A. Hess, J. TRUE COpy FROM RECORD In Tcsllmno1Y wlJ~rf:O', I hora UOlo sot my hand ;\11~ tfl.n ~~I o~ s'3!d Cr.orl a,I C.1rl/sle, fW. ThlG.2.L'-'~d"Y 01 ~ 1Q Q:z- ._.__.._-;.~- (.I~;~(I('f:: . ~i . Prothonotary , \ !, " CERTIFICATE OF SERVICE o I h 1 ~ " I ~ h I! r ~ ~ u I I I, Robert L. Buzzendore, Esquire do hereby certify that on the ~ day of August 1995, I caused a true and correct copy of the Petition for Emergency Relief to be served upon the following counsel of record by depositing same in first-class U.S. Mail in Harrisburg, Pennsylvania: ROnald E. Johnson, Esquire ANDREWS & JOHNSON 78 West Pomfret Street Carlisle, Pennsylvania 17013 ~ ~ I, U f ~ i i ~ " I I I I I I ~ Respectfully Submitted, ~ By Ro e . uzzen or ROBINSON & GERALDO Attorney 1.0. No. 977 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 h i ~ Ii h Ii II , . (717) 28US25 " ~ E ..., ~ N ~f: :;!~ w,,~:;J:! ~':I:Oz ",,"OU.. 1"'%'0> O"'-:"OE'~ . ... ~-~ "'t.": 0- ...,J.... .., -.c;,;:z!: .J,.Jl.lJ:6:, ....,,,..It; i:: x{L. ;..0 ::,.... . ~ ..... .', CeA~fp:I~~ i~~E6l AND.CORRECT COPY ROBINSON AND GERALDO . , AlTORNEYS AND COl~SI!LLORS AT LAw P.O. 80"5320, HARRisBuRo. '~EeR'f'6IN1\t ..~., -.."..,"" !'nd.~ ~,~' . ; }__7::"':4.:s.~ ~ "'":c..-::-:~~;;::. __ '-.. } ..... ...... g - , RONNIE E. HONICKH, SR., Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW . . v. MICHELLE R. RABENSTEIN, Defendant/Petitioner . . 95-3338 CIVIL TERM AND NOW, ORDER OF COURT this \~1Lday of October, 1995, upon relation of Ronald E. Johnson, Esquire, counsel for Plaintiff, that issues raised in Defendant's Petition for Emergency Relief have been resolved through the custody conciliation process, the Petition is DEEMED MOOT and the hearing scheduled for October 19, 1995, is CANCELLED. By the Court, RONALD E. JOHNSON, ESQUIRE 78 West Pomfret Street Carlisle, PA 17013 For the Plaintiff/Respondent ROBERT L. BUZZENDORE, ESQUIRE 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110-5320 For the Defendant/Petitioner ~ (. . ~, c:, :::::> --.; <.0 v-. - c-F'" ~ I c/,'ilqs', ...&. "f. - :. wcy ,~ c, -, ~ OCT 25 1995 tJ . RONNIB B. HONICK, SR., Plaintiff IIN THB COURT OF COMMON PLBAS OF ICUMBBRLAND COUNTY, PBNNSYLVANIA I INO. 3338 - CIVIL - 1995 I I ICIVIL ACTION - CUSTODY v MICHBLLB R. RABBNSTBIN, Defendant COURT ORDER AND NOW, this ~day of "'M~t_., 1995, upon consideration of the attached Custody CO~Report, it is ordered and directed as follows I 1. The Hearing scheduled in the above case for October 19, 1995, is cancelled. 2. The parties shall submit themselves and their two minor children to a custody evaluation to be performed by a professional as agreed upon by legal counsel for the parties. Costs of this evaluation shall be shared equally by the parties with an adjustment such that the Mother shall incur any expenses directly related to involvement of her husband in the evaluation process. Upon completion of this evaluation and in the event the parties are unable at that time to reach an agreement, counsel for either party may contact the Custody Conciliator at which time the Conciliator can either convene a second Conciliation Conference or file a report with the Court to schedule this case for a Hearing before a judge. 3. Pending further Order of the Court, this Court's Order of June 29, 1995, shall remain in effect. BY THB COURT, Judg cc: Ronald E. Johnson, Esquire Gerald S. Robinson, Bsquire - Cof~fl>'<\,~,t>/a."'IIjs". A.i'. 56 ,.. (7 nl ", !~O ' I <, ... t t....1 , . RONNIE E. HONICK, SR., Plaintiff IIN THE COURT OF COMMON PLEAS OF ICUMBERLAND COUNTY, PENNSYLVANIA I INO. 3338 - CIVIL - 1995 I I ICIVIL ACTION - CUSTODY v MICHELLE R. RABENSTEIN, Defendant PRIOR JUDGEI JUDGE J. WESLEY OLER, JR. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following reportl 1. The information pertaining to the children who are the subject of this litigation is as follows I Autumn R. Honick, born March 22, 1989, and Ronnie E. Banick, Jr., born October 12, 1990. 2. A Conciliation Conference was held on October 9, 1995, with the following individuals in attendance I The Father, Ronnie E. Honick, Sr., with his counsel, Ronald E. Johnson, Esquire, and the Mother, Michelle R. Rabenstein, with her counsel, Gerald S. Robinson, Esquire. 3. The parties reached an agreement in the form as attached. 16/~~ qs'" . DPi E re {;)(M- ,\L....~...:, ,,'", : jJ:~~u'-'J.: ".J " , , , RONNIE E. HONICK, SR., Plaintiff v. I I I I I I I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MICHELLE R. RABENSTEIN, Defendant NO. 95-3338 CIVIL TERM AND NOW, this Z..cl. day of October, 1996, upon consideration of the Motion to Withdraw, a Rule is hereby ISSUED upon the Defendant and Plaintiff to show cause why the relief requested should not be granted. RULE RETURNABLE within 10 days of service. BY THE COURT, J Wesley Michelle B. Stokes, Esq. 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110-5320 Attorney for Defendant . A.J. . ~V'U"- 11.~ lol'>lflf~"r- Michelle Rabenstein 9421 Atwood Avenue Apt. B Norfolk, VA 23503 Michelle Rabenstein c/o Thomas , Connie McConnell 30 Ray Road Middletown, PA 17057 Ronald E. Johnson, Esq. 78 West Pomfret Street Carlisle, PA 17013 :re ~'\"\~ 1 ""11,:'"1.' \j, " " "..", J" ."'- ! ' . . I ".., ," .. 'I .'~ :,. ,- '0,/'''; - ' t:v .', , " '. - . . . t . RONNIE E. HONICK, SR., P lllinti ff, VS. IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA I I NO. 3338 1995 CIVIL TERM MICHELLE R. RABENSTEIN, Defendant. I I I CIVIL ACTION--CUSTODY ORDER AND NOW this day of 1996, it is hereby ORDERED and DECREED that Defendant's Counsel's Motion to Withdraw is granted, and the appearance of the law firm of Robinson & Geraldo is hereby withdrawn as counsel of record for Defendant for the above proceedings. BY THE COURT: ... J. . . . , RONNIE E. HONICK, SR., Plaintiff, VII. I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA I I I NO. 3338 1995 CIVIL TERM I MICHELLE R. RABENSTEIN, Defendant. CIVIL ACTION--CUSTODY roM AND NOW, this day of , 1996, a Rule is hereby issued upon all parties to show cause why the Motion to Withdraw should not be granted. RULE RETURNABLE DAYS FROM SERVICE. J. -,,,:,, , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA RONNIE E. HONICK, SR., Plaintiff, vs. I I I NO. 3338 1995 CIVIL TERM CIVIL ACTION--CUSTODY MICHELLE R. RABENSTEIN, Defendant. MOTION TO WITHDRAW AND NOW COMES Michelle B. Stokes, Esquire of Robinson' Geraldo, Petitioner, who, in support of this Motion to Withdraw, avers the following: 1. On or about August 22, 1995, Defendant, MICHELLE R. RABENSTEIN, retained the law firm of Robinson , Geraldo to represent her throughout the above-docketed custody proceedings. See Exhibit "A" attached hereto and incorporated herein. 2. Petitioner has prepared various court documents, attended a custody Conciliation Conference, and corresponded with Defendant and Plaintiff's counsel with regard to the custody proceedings. 3. Defendant currently has an outstanding balance with Robinson , Geraldo in the approximate amount of $927.50. 4. Defendant has refused to cooperate in attending her scheduled appointments for the custody evaluation, as ordered by the October 25, 1995 Court Order. See Exhibits "B" and "C" attached hereto and incorporated herein. 5. Petitioner has been unable to contact the Defendant by telephone or by letter. 6. Upon telephoning Defendant's home telephone number, Petitioner discovered that the telephone number had been disconnected. 7. Petitioner has made numerous attempts to contact Plaintiff, and her parents, by first class mail. See Exhibits "D", "E", "F", "G", "H", "I", and "J" attached hereto and incorporated herein. The correspondence sent to Defendant by first class mail is not returned, however, Defendant has not contacted Robinson & Geraldo as requested. 8. Petitioner has been unable to locate Defendant's whereabouts. 9. Petitioner's continued representation of Defendant has been rendered unreasonably difficult by virtue of the client's absence, and good cause exists under Rule 1.16b(5) of the Pennsylvania Rules of Professional Conduct for Petitioner's withdrawal of appearance in the case. 10. Despite a fee agreement requiring payment by Defendant for Petitioner's services and the submission of bills to Defendant, Defendant currently has an outstanding balance of $927.50. 11. The continued representation of Defendant without payment of Petitioner's fees, or the prospect of such payment, has resulted and will further result in an unreasonable financial burden on Petitioner, and good cause exists therefore under Rule 1.16b(5) of the PennJylvania Rules of Professional conduct for Petitioner's withdrawal. WHEREFORE, petitioner, Defendant's counsel, respectfully requests this Honorable Court to grant this Petition of Counsel for Withdrawal of Appearance. Respectfully submitted, /J1Pq;\~ :rche{~~e'i;, Esquire ROBINSON & GERALDO Attorney I.D. No. 76272 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Defendant p, ROBINSON &. GERALDO .. ....O.IS'.ONaL CQllflO""'rO". ATTORNtYS AT LAW Poll OffICe 80, 5320 Harnsburg. Pennsytva0l8 17110-5320 WIll Shote 351Q nondlO Rood Camp Hili, PA 170" (717) r.J7.2779 Hartlabutg ..01 No<1h Front 51. H.lfllbutg. PA 17110 (717) 2328525 Wls/WlglOn, DC 1318 Ponn_ No, S E WIs/WlglOn, DC 2OllO3 (202) 5<0.2888 RETAINER AND FEE AGREEMENT 1. This is a Retainer and Fee Agreement entered into between THOMAS AND CONNIE MCCONNELL (CLIENT) and ROBINSON AND GERALDO (ATTORNEYS). 2. Client does, hereby, retain ROBINSON AND GERALDO as attorneys concerning: Representation of Michelle Rabenstein regarding Custody. 3. The following matters are to be undertaken by ATTORNEYS for the CLIENT pursuant to this Agreement: Representation of Michelle Rabenstein regarding Custody including preparation and filing of all necessary and pertinent documents, and providing legal counsel as necessary. 4. The CLIENT agrees to pay the following costs for services performed: a. The CLIENT agrees to pay $150.00 per hour for ATTORNEY time. b. The CLIENT agrees to pay $150.00 per hour for ATTORNEY time in regard to all Court appearances, hearings or depositions. c. The CLIENT agrees to pay $125.00 per hour for Associate Attorney time. d. The CLIENT agrees to pay $50.00 per hour for Paralegal time. e. The CLIENT agrees to pay $20.00 per hour for word- processing services. 5. CLIENT also agrees to pay for all out-Of-pocket expenses, including, but not limited to, expenditures for filing fees, transcripts, subpoena and deposition fees, long distance telephone calls, postage, xeroxing, travel and all disbursements necessary for the proper performance of legal services. 6. CLIENT will be billed on the basis of the time spent and services performed on this matter. Telephone conversations between the ATTORNEY and the CLIENT will be billed at a minimum of one-quarter (1/4) hour. Telephone conversations between the ATTORNEY and opposing counsel, party or other interested party in this matter will be billed at a minimum of one-quarter (1/4) hour. Exhibit ROBINSON &. GERALDO ,. II II , t 'j '} I ., ... ... l C q " to 'I II ~ , , .) " RETAINER AND FEE AGREEMENT Page 2 7. The CLIENT agrees to pay ATTORNEYS a retainer of $600.00 against which the charges described in Paragraph 4 will be deducted. This Agreement will not be effective until the retainer fee is paid and this Agreement is signed by ROBINSON AND GERALDO. 8. ROBINSON AND GERALDO will bill the CLIENT as work progresses on the matter as itemized in Paragraph 3. The CLIENT agrees to pay ROBINSON AND GERALDO when billed, but in no circumstances later than ten (10) days after receipt of the statement. A 12' annual interest charge will be added to all accounts with balances due for more than ten (10) days. 9. The CLIENT understands that ATTORNEYS may not ethically bear the costs of litigation for CLIENTS. Therefore, ROBINSON AND GERALDO, at their sole option, may withdraw as counsel should CLIENT'S account become delinquent by a period exceeding sixty (60) days. ROBINSON AND GERALDO relinquishes no legal claim against CLIENT for any unpaid balances as a result of such withdrawal and will utilize the law to its fullest extent as a means of recourse to fully protect their interests. If it becomes necessary for ROBINSON AND GERALDO to pursue their legal rights, CLIENT agrees to bear the cost of all attorners' fees associated with the litigation of the matter at preva ling attorney rates. 10. If CLIENT disputes any charges, the CLIENT must notify ROBINSON AND GERALDO in writing within thirty (30) days. ROBINSON AND GERALDO will make every effort to clarify or correct any disputed charge. 11. The CLIENT understands and agrees that this Fee Agreement does not include legal services in connection with the appeal of this case. CLIENT will have the choice to retain ROBINSON AND GERALDO under a new Fee Agreement should this matter involve an appeal. 12. I have read this Fee Agreement in its entirety, and it has been explained to me, to my satisfaction. I understand the ~~a;~~~:;;in the Agreement and hereby agree to abide by ~~~~~ & ~~ DATE 0#. . to?hq ~ /JP' ~~h'NRtLL ?/~ENT) /) . -'//J'!:/J, a~ ~NYt Mcc6NNfa.~":'" (CLIENT) ~.:s/95 /f-:;(.;?- 95- DATE . ' Pauline' Wallin, Ph.D. Licensed Psychologlsl & Associates 201 Soulh 32nd SIICCI Camp Hill. PA 17011 (717)761.1814 PAX (717)761.1~42 July 9, 1996 Ms. Michelle Rabenstein 9421 Atwood Avenue (Apartment B) , Norfolk, VA 23503 Dear Michelle: I'm sorry you missed your appointment with me today. As you will recall, when we spoke on the phone a few weeks ago, I set aside 2 hours today, July 9, and 2 hours tomorrow, to see you and the children. This Is the second time you have failed to show for an appointment. Although the appointment was for 2 hours, I am billing you for only 1 hour for a missed appointment. Because this time was reserved for you, no one else could be scheduled. If you wish to re-schedule, please be advised that all future appointments must be paid for IN ADVANCE. I regret that we need to do chis, but I cannot continue to reserve blocks of time when you do not show up. Sincerely, .,~' ~ ~- I '- U.t 11/( ~E WALLIN, Ph.D Licensed Psychologist PW/eg cc: Gerald Robinson, Esq. ~ , Exhibit CONSl PSYCIIOTIIERAPY B ( .' 1}I;r 2 5 1995 , -.. OCT, 27 1995 RONNIB B. HONICK, SR., Plaintiff IIN THE COURT OF COMMON PLEAS OF ICUMBBRLAND COUNTY, PBNNSYLVANIA I INO. 3338 - CIVIL - 1995 I I :CIVIL ACTION - CUSTODY v MICHELLB R. RABENSTEIN, Defendant COURT ORDER ~ ~ AND NOW, this .dL Ciay of , 1995, upon consideration of the attached Custody Conc 1 at on Report, it is ordered and directed as follows: 1. The Hearing scheduled in the above case for October 19, 1995, is cancelled. " 2. The parties shall submit themselves and their two minor children to a custody evaluation to be performed by a professional as agreed upon by legal counsel for the parties. Costs of this evaluation shall be shared equally by the parties with an adjustment such that the Mother shall incur any expenses directly related to involvement of her husband in the evaluation process. Upon completion of this evaluation and in the event the parties are unable at that time to reach an agreement, counsel for either party mar contact the Custody Conciliator at which time the Conc liator can either convene a second Conciliation Conference or file a report with the Court to schedule this case for a Hearing before a judge. 3. Pending further Order of the Court, this Court's Order of June 29, 1995, shall remain in effect. BY THB COURT, lS/ ~. 1.s'A~ &.J a-v. Judg J. Wesl y Oler~qJr. CC: Ronald E. Johnson, Esquire Gerald S. Robinson, Esquire -~.,- - ',' ":";""'1 ':".......\ "l:"'ORD t-.. . .... ~ I ',~ ;.;' 17Iy hand (,'. . '. - . .. " ."a~.'.! p , .1::t:..' . .., ...1. -,..J, a. TIi:. .;{ 10 " ' /f'\..... , ,,-~ cr ~c.LO;"" J9,?€. .......,,~,tt. )~cAf.V. ~. PrOjt:or.~I~ry ............. exhibit . c ,',~ ';, ..... , " :f~i:t:'f> ,~> .' .. ." ....~.l..~/,...., "~:~;~~?~';..:.:~ .. ... ;.~~. .. . ,><!<~",:.- '. ,". r..~.. , ';" , . '...~~. .'," . ;r~J':';; :~~F~7<(~';"': . ..1;~.';.',' . :;?~':':'." I;Y';i,~.: , -... ~...' . . " ...;", v.;..... .......~.ll. '~t I~:~?:. ',t.~..,. JMl.~, '..\..:.... :............... .;r.".l..... :~~~ . , , , '. :.~ ROBINSON &.. GERALDO .. ~.O""'a..., cO..o..t,o.. ATTO.NtvS AT LAW Post OffICe 90. 6320 H.,,/IbuIg. Penn..,.."n.. 17110.6320 cno. "EaIl..,_ CoAtoo, "" 171113 171 ~ l'H'~t >w-..g <<<<0' """",.... St. ~""",.o ('m 13H~15 June 28, 1996 Michelle Rabenstein 9421 Atwood Avenue Apt. B Norfolk, Virginia 23503 Rei Dear MBBljmm CCI Outstandina Bill Ms. Rabenstein: " ~lon. D.C, '3'0 PrnI\+N>il AVI" S.E, Walhi"oglon, D,C, 10003 I202l &<<.2889 .-:. .. . '" ,~. ". ~~~ -:. , .~ :..:~j!.': ,I ., :r.~.f.. 'f...,;.~.~:a;... ~'.:. "',' ;,; .... ", ',.. f" ',' T. & C. McConnell Exhlbll D . ~'. ..::;~~~~t~::,: .......... I . ".\'" '.. . '. ..~';~' ,:: '.~:. ". H:", \~!':.., ". ..~', ~ . '..' . ". <1\,:,.,'...' . ..'I...:..;-'\'~..:l~. ,,;.~!-,. 'J '?' - , ~( '! . . ROBINSON &. GERALDO ,. '.0.....0...' cO..o....o.. ,', AnoINtl'S AT IJ\W PDII 0Ila !IoI ~ Herlllbulg. ~... 1711l).53:!O c.. "bolHQll_ c... '" 'ro,~ 11tlU4HOSI ........... -__II. .......... '" "" 0 (1I7UJ2'_ '_'ll"""D,C, '~Ie PlMI)lvIniI A..,. 5 E, ~ton, D,C, 20003 l202l&4HlIH 'J July 10, 1996 . ;". ,', r\~ '.>:~' , ..... ...... . . :1' 0/ . ,p.' ::-':1 "..; ';'. . .... " .: . " '~.:: . ) '.' .", .." (rJ~~;~~~;', . "'::. ...~'\ -;~.. ~ \'.j""" ( ',~'i/;}}~~;:' ;~: ;t~~ '_ . -.;; ~:;~f~~;\"l~~.~~~:iq:...)~!,~~. " -'.""', :-''''~;;''' ~~.i,~~'I'\.;ii' . '...... ~..~:.,~,.~, .":\~'? I have attempted to contact you by telephone but' have''i'::;::''~e~l\'~:';'I~!';': discovered that your phone has been disconnected. Additionally, :;:'~":,:{,", I forwarded letters to you on June 18 and 28, 1996, but you',have';:.'",,:;~/~; not responded. It is important that you get in touchwith':me,:~l!o~k':'~"}+i,.:: that we can communicate. Therefore, please contact me w~~~~~~~f;~~~:.~~~ correct new phone number. """'~'.N""'''': ,;,"W/"", . ,f. .. ...... '.~,,-'. ...,. ::?."__ .., . .., 'f,.:;", """1.tf';-:"""'~'~~' "Jf?~',-i I am still waiting to receive from you Ronnie Honick.'s :',~1R~;'".~f~(,1:~~\'~':', Social Security number and date of birth. Please send this;,~~,~':~~~:i,;:~.t: information to me as soon as possible so that we can request,'.;an\:>;I'ol,<;;:~~<;.r.::::,""'~" i i 1 d h k ','..,.. ., ...~ ",le""~.",,. cr m na recor c ec . '~;"""~'f..:."1'i"('"o:;".;": . ' ,'ff~ ..,'- '~.:, f~~~;: ;,~~:t'~..': ::~'., 8'; Please note that I was co"tacted by Dr. Wallin today,:. a,nd~h"'''''<$:' ...', IIhe informed me that you did ,not appear for your sChedule~.::,!~;;,t:d~0:!l~,,;\" appointment with her. Obviously, she had lIet aside an amount..of f':\ time to meet with you and was inconvenienced when you ,did, not ~' ~1:~~~ appear or call her in advance to cancel the appointment. i!:'Dr";~,.. ,1{:~!..~:': , Wallin ill now going to require that you pay in advance forr alr:'l~., ,,':,f.-f:\:':, future appointments. You should be aware that your failure tci:t ,?~~<,.,,(.,. ' . appear for your appointment is not onlr delaying the progre'ss":of"~",;,'''', ' your calle, but is also causing Dr. Wal in to believe that' you1' 'f,;. ~~;g;i~;-:'1' are not cooperating. . !:' :':, "i.;'!o."tt..f;J';', , . .... "'lotI!:rf.I~ ~ "'....... ..,.,C\t~,'v. . . }~m~1'0'f , . . ::;' '~., '...- . "':,'.., , :', ::".~,~,,~,::.~",:,\'.: .'. ~.:,..~'ti' $'~ . ...,.:J!. '. "<\'fo"';f.ii-Il.' "'.: ::'.' "'/':';'.;Y';;,.,.r.:: '.' "~-,>?,':'. ;~. , ,;~ ., ~"'~~~~~'.;\ i.:. 't(.;:t;.!,.~:.,~ .;",. :~~ :'.;f;:.~~ , " " Michelle Rabenstein 9421 Atwood Avenue Apt'. B Norfolk, Virginia 23503 ReI Custody Dear Ms. Rabenstein: . . I'. .. .~.", " : ,.~. ~. .. .,\'1/-, ...,t. ""1''':. .-' :-~'?..: '. . . ......... ..., ..... Exhibit ..-. . 'f . ~, . . . - 100.;'" ... .: ." " ," ..,--....-.. .' " 'J;'!"'\ .it. !t9~1!'!~~!'!.8:- ~~~~~ l Michelle Rabenetein July 10, 1996 Page Two " Thank you for your prompt attention to this matter. 'have any questions, please do not hesitate to contact me. . Sincerely yours, ROBINSON , GBRALDO '. BY~ Miene . 0 es, .:.~..' MBS I jllllll CCI T.' C. MCConnell :'~~;;~\;' . . ''f>" ',' '. " - ... ....~.J. :. . .:;,.,\;.... '1i:,!. ' ,i,;";, . ,',,;, ',.r.~ .1; ...> I' '. ... " "." ... : t. J' '-:~ L. , , ~~.. .. ' .::' '~" ""'.,.;', . '...~.4.;' . , .,', ~';":~.f~:;~;" , t:;,. :,\J!,h<:.., . ',......, !J". If: yoi(~; ': . . .', l' ,~ ,. ." '1':' .'. " .' ~'. EsqUire,!:;, _~':' 1:\ . 0,:""" ,~:"t~:\;..~~.,. .. ..,'. :~.:' ~ .'h<.iJ.I:i~~~:' . . .~'~~' '~, ,;-~~: ;t7{:::::~~ '- .t ,.,..,'..1" ';'\\:~r:r~' , . '\". . " ~L' ,,' ~" ,~. .:' I' , I .... .,i, ,......,,;,..... . 'j I :'~'" ..;}::~;~j$~~~~~~~j~~~;~f I. . :. . \'~:,~~\.:.:.;...:~~t~.:i~\~!..::.. ',' ~.i':...,.:..:....~.....:\.~_...,...J . - . .~, ... '~'~'1i.......;t.,' .. ...:{~.........:.~.~ul.tt~ .... i ,.~..'.:I ~,'~~it...(I:;~~~',~t~.:~.I' ~;:.;. .1::'.<::' .',1' ~~t.~'.i;~';;;'" . ... ~.. -y,"'''' ~:~,. , .' :~\.-'J~:f[/~~~tr;'i;g: . 'l"'~'.'" :(..I.'f...W...... ~-~ ~:,..;;'::. .:-..:~~{~'-'..,., .(''1''';.':'~ ;.. ....~-....?!t.: \ . ',:':' I;".<r!. - ::.:,,"'~'. . ,'t. '.~ .....\i,'jJ..". .' ,~. .; '~''''-;:';'i.,j.. . . .: l::\(..~ 't~':'~ ~. -7: :~ I <!~t.~.. ~; '. " ,..,'~..;. : . j_.;-,:t'..... ,: '{.. . ,__i t. . :'.: .'~...' ," " , ROBINSON &. GERALDO .. '.0....10...." cO_'O...tIO" AnoRNtVS AT LAW Poll Oflice Box 5320 Hlrrilburg. PennlylYlnil ,7110.5320 CIo'oIo I7E"I~Sl"'1 C"'Ilo, "" 17013 1717)2C~'1l'~1 -......g ceo, ,....,"""Sl. -......g. "" 17110 (7'7)23208$25 WaINngton. D,C, 131e~Ave" s,e, WaINngton. D,C, 200lXI (202) 54C.2880. ... I : .~'. ~.1(,/f ~ :.'~l~;r:':,' ". . d., , " 10 JUly 26, 1996 '" Thomas & Connie McConnell 30 Ray Road Middletown, Pennsylv~nia 17057 Re: Michelle Rabenstein Dear Mr. and Mrs. McConnell: "\ ..I),t~'kf~: ,-\.,' ~" . . , I am writing to you in an attempt to reach "ichelle i Rabenstein. She apparently missed her appointment with Dr. Wallin without calling in to cancel. Additionally, I have attempted to contact her numerous times by telephone and by . letter, but I have been unable to reach her. Recently, I have discovered that her home telephone number has been . disconnected. Obviously, her case will not proceed if she is unwilling to communicate with me. Also, she does have an outstanding balance with this firm. Any help you can provide, me ' would be appreciated. I look forward to hearing from you in::the,':... .oor 'uturo o. thot hor cuotOOy ..t:::C:::1~0 y:::::V"":(~'[t ROBINSON & GERALDO,' i'~<ir';",~'.\l' :rc..~. -.;..1ro :'i~~~'~ .. '; ;.~:'~'.\ ";~::i:~~ .;~:.\:'. ~ ~ ' . t..:. ~~"-;'~~'';.''~ '. "...:,.,11; ',~,:.:; ,;, ~ ....Yo... ;.I:~. t.' "'f~" .,11J....J ~. ";~ ,,;,'~'l:,fQri ,:.1..:. ~ ': , ,\ ','.);;.' . .... ~'"..'I~": .,: .. .' :::',:: .~t~:~:: " .,.... ,I: .' . : ""..~., ,~1:,~}F,'-: .' . ~ ~.: \!':- ~~ ~f~")., .?T.\~;'i. : " , ....<.... " ' .... ..... "."r.: .:' .t.- ,:-.'..;.: ~ . '. . .. MBS:jmm ," .' cc: M. Rabenstein !', . ,;,'. "". ' , . , .' .;:~'~ .. ~:.::';:.h .'... " . . . .~. ..:' . Exhibit :',i~i:..: . . ~\~ ~ ~~~~ :';'" ~# :.... --. . 'I {':, .......- .' 'J,i: ~~'.. .~'. :!I~!':..' ". .? . ,~. . '; , .', . I j . ~ i I .' , ,. I .~.-i;..: .~~: I -.. ?.l':.,.... i i I I I I , i I . ROBINSON &. GERALDO . 1t1l0'.".0""., cO."O.."O"" AnoRNtYS AT LAW Poll OtIce Bo. 5320 H.rrllbYrg, "'nnsylYenll 17110.5320 ~ ..07 NooIn'""" SI. ~,""'17\10 (l'7lU2,.m WlI/Wlg.on, D.C, 131.,..,."........ "VO.. S.E, WloIWlglon. D,C, 20003 12021....21l1l9 ea..... 17 E.II Hto" StlWll ~,""'170'3 17171 2..,04.' August 12, 1996 :~ ./:~~~J'f.,~:"',,' ..,... .'.....,... .~ . Thomas & Connie McConnell 30 Ray Road Middletown, Pennsylvania 17057 ReI Michelle Rabenstein Dear Mr. and Mrs. McConnell: '. ~\'...; / ." i....... , , .. '., . ',. \' I am writing to you in an attempt to reach Michelle .' " .,. Rabenstein. She missed an appointment with Dr. 'Wallin, and she ..~ ,~/ ;, has not answered my letters. Additionally, I ha,ve attempted ,to.:', '....,;.' contact her by telephone, but have discovered that her home "'.:"'':'''<'' telephone number has been disconnected. As I indicated .in a', ;':',' . ',';' previous letter to you, her case will not proceed if she is ,','., '., , unwilling to communicate with me. Also, she does have an '. "::~:> :'. ' outstanding balance with this firm. If she does not intend, ,t,~,;o':.!:~':;';:;:r';':' proceed ',lith this custody mattor, I am requesting that she '. :"~:~;'I'.":,I;,,\ inform me of that decision so that we can close her flle,with',i~~\>i'I':"'" this firm. . ;,:.:,', I~:-'> " . >:,!: ';::,. ~ ~. , Thank you for your help you can provide me hearing from you in the can be resolved. prompt attention to this matter. Any""....:' would be appreciated. I look forward'to ", near' future so that her custody matter" ,I,. " ., . .:-: t .:~<;., '; ,::~,:, ..~:.~~:.: ' -', '" ."'~' " " ;. ~. Sincerely yours, ROBINSON , GERALDO .. B~ . Me. 0 es, Esquire " .. " ~ ',0. MBS: jmm CCI M. Rabenstein " '. \ .' . ~ j- , exhibit . , " 1 1 I 1 ;' ! '.,.~,' j) .;'.~' 1 ,t .~ .'" ',_ "1 .: I' .'. , ,,~ 1: .. ;.; . 11 ' ,\ il " , j " ,i,,' . .. . ' . ' 'ROBINSON &. GERALDO .. '.0""10"'" cO."O.."OH AnOIN[\'S AT LAW Poll OKce Bo. 5320 H.rr~bu'g, PennSylvan,. 171t()'5320 !:Milo 17 EIII H9" Sl,", C....... PA 11013 (711J24~.9451 HImtWg "07 Nc>1" ,.... $1. ~,PAIIIIO 171FJ :32.&525 WaSlwlglon. O,C, 131' PIM~ Ave.. SE. Walll"lllon, 0,0, 20003 l202l6'Haell August 12, 1996 Michelle Rabenstein 9421 Atwood Avenue Apt. B Norfolk, Virginia 23503 ReI Custodv Dear Ms. Rabenstein I I have attempted to contact you by telephone but have ':.. " discovered that your phone has been disconnected. Additionally,'.. I forwarded letters to you on June 18 and 28, and July 20,' 1996, but you have not responded. It is important that you get in touch with me so that we can communicate. Therefore, please contact me with your correct new phone number. 't' . ;, .; :," :~ ';' , I am still waiting to receive from you Ronnie Honick's Social Security number and date of birth. Please send this information to me as soon as possible so that we can request criminal record check. ('.;.~[~?' -',f, . :',', . .~:.;;, + . . .... ~ . .:;.. a' ,'. " Also, please contact me regarding any appointments you have made with Dr. Wallin. Your custody matter will not proceed. , until you have completed your evaluations. If you do not intend .:, to pursue this custody matter, please contact me regarding that- .':' . decision so that I can close your file with this firm. Thank~. ..:' ..,,' : you for your prompt attention to this matter. If you have any" ': ~. questions, please do not hesitate to contact me. ' Sincerely yours, ROBINSON & GERALDO " :r~~~ Esquire MBS I jmm cc: T. & c. McConnell Exhlbll II . ., .', t' . . ROBINSON &. GERALDO .. '110.1...0....' CO.'01l"'10.. ATTORNtl'S AT LAW Post O"'CI Bo. S320 Harrisburg. Pennsytvania 17111).5320 C...... 17Ea,'H.gloS'roeI C....., PA 170'3 (711) 2'5'U'51 -..wv U01 NotIh Fronl 51. HamsbuIg, PA 17110 (7'1) 23208525 WaslWlgl.... D,C, '''0 Pomsylyl"'" Avo,. S,E. WaShington. D,C, 20003 i:!02) 0".2BllU September 4, 1996 Thomas & Connie McConnell 30 Ray Road Middletown, ~ennsylvania 17057 Re: Michelle Rabenstein Dear Mr. and Mrs. McConnell: I am writing to you in an attempt to reach Michelle Rabenstein. She has not answered my letters or telephone calls. Therefore, if she does not contact us by Friday, September 13, 1996, we will file a Motion to Withdraw from her case. Thank you for your prompt attention to this matter. Any help you can provide me would be appreciated. I look forward to hearing from you in the near future so that her custody matter can be resolved. Sincerely yours, ROBINSON & GERALDO :t~~ Esqu1re MBS: jmm cc: M. Rabenstein Exhibit I . ", ,', . . ' . ROBINSON &. GERALDO " ".Olll'IO""L COIII'O..'IO.. AnoRNtVS AT LAW Pall Off",. Box 5320 Hamlburg, Pennsytvanil 1711()'532O c...... 11 East Ho" SIIUlI eo.o..., "" 11013 (717)2'H'!1 -~ "07 Notl" FI!XIl SI. Hamsllulll, "" 171 10 (717) 232.8!2! WaSllirlgIOll,D,C, 1318 ~Ave.. S.E. WaSllirlglon. D,C, 20003 I202l54H889 September 4, 1996 Michelle Rabenatein 9421 Atwood Avenue Apt. B Norfolk, Virginia 23503 Re: Custody Dear Ms. Rabenstein: I have attempted to contact you numerous times through letters and telephone calls, but have been unable to reach you. Therefore, I am writing to inform you that if you do not contact us by Fridav. SeDtember 13. 1996.we will begin proceedings to withdraw from" your case. Thank you for your prompt attention to this matter. I look forward to hearing from you in the near future. Sincerely yours, ROBINSON & GERALDO :r~s, Esquire MBS:jmm cc: T. & c. McConnell Exhibit - I I .. . ." \ . , . " ' I VERIFICATION I verify that the statements made in the foregoing Motion to Withdraw are true and correct to the best of my knowledge. I understand that false statements herein are made subject to the penaltie~ of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ~l qL~ Ifl'~ d4ffi{(~ ROBINSON & GERALDO Petitioner Esquire ~ ., . . . ' . , . RONNIE E. HONICK, SR., Plaintiff, vs. I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA I I I NO. 333B 1995 CIVIL TERM I I MICHELLE R. RABENSTEIN, Defendant. CIVIL ACTION--CUSTODY CERTIFICATE OF SERVICE ~ ~, Michelle B. Stokes, Esquire, do hereby certify that on the ~ ~day of September 1996, I caused a true and correct copy of t e Motion to withdraw to be served upon the following individual and counsel of record by first class mail by depositing same in the United States Mail, postage prepaid, in Harrisburg, Pennsylvania: Michelle Rabenstein 9421 Atwood Avenue Apt. B Norfolk, Virginia 23503 Michelle Rabenstein c/o Thomas & Connie McConnell 30 Ray Road Middletown, pennsylvania 17057 Ronald E. Johnson ANDREWS & JOHNSON 7B West Pomfret Street Carlisle, pennsylvania 17013-3216 Respectfully submitted, :rd~~~~qU1re ROBINSON & GERALDO Attorney 1.0. No. 76272 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-B525 Attorney for Defendant \ i I \ ::-.~ - I Lr; (''; , -, , , . ! 11 ,~ (.; .- u' , \ f" \ 7-- r''': " ~r . ~ ~.I I-:~ ,- \ lJ.! ('J ; ~,.~ -', I L'';; ; CL ;'~iJ \ 'l. v; .<1.. I' ,.,") ::) U C;"\ (..) ..... ..... .~i~ i , \ \ \ I ! , .. i (717~. 231:25 ROBINSON AND GERALDO AtTORNEYS AIjD ~OH'sE("'R5 AT LAW 1',0. Box 5320. HARRISBURG. I'ENNSYLVANIA 17110,5320 'OCT C 1 1996_~ CERTIFIED TRUE AND @"ORREe"r COPY ..I...., . ". . RONNIE E. HONICK, SR., Plaintiff, v. : IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA : : : NO. 3338 1995 CIVIL TERM : CIVIL ACTION--CUSTODY MICHELLE R. RABENSTEIN, Defendant. ORDER \? tl.day of orl-a/" "r 19961 upon AND NOW this consideration of the attached Motion to Make Rule Absolute, it is hereby ORDERED and DECREED that the Rule which was Issued on October 2, 1996, to show cause why Defendant's Counsel should not be permitted to withdraw her appearance of record for the Defendant in the above matter, is made absolute, and that Defendant's Counsel's Motion to Withdraw is granted, and the appearance of the Law Firm of Robinson & Geraldo is hereby withdrawn as counsel of record for Plaintiff for the above proceedings. BY THE COURT: 't.tN,\l,\C;\lN3d Al'ln:r'J C;'I,'(Elimn~ 9S:!) I!\J BllJiJ% ^li/1C~::;i'llI.;8J 3'-t~ ~:> 301:1:10"Olltl .. , . .. . ~ RONNIE E. HONICK, SR., Plaintiff, v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA MICHELLE R. RABENSTEIN, Defendant. NO. 3338 1995 CIVIL TERM CIVIL ACTION--CUSTODY MOTION TO MAKE RULE ABSOLUTE The Petition of Michelle B. Stokes, Esquire, of the Law Offices of Robinson & Geraldo, respectfully moves this Court to make the Rule to Show Cause absolute and in support thereof represents: 1. On or about september 30, 1996, Defendant's Counsel filed a Motion to Withdraw from the above-captioned case. See Exhibit "A" attached hereto and incorporated herein. 2. On or about October 2, 1996, the Court issued a Rule upon Defendan~ and Plaintiff to show cause why Defendant's Counsel's Motion to Withdraw should not be gr~nted. The rule was returnable within 10 days of service. See Exhibit "B" attached hereto and incorporated herein. 3. As of October 14, 1996, the parties have not answered Defendant's Counsel's Motion to Withdraw nor the Rule to Show Cause issued by the Court on October 2, 1996. The ten (10) days from which the Rule was returnable has now expired. I! ".... . . , WHEREFORE, Counsel for Defendant requests that this Court make the Rule to Show Cause absolute and grant the Motion to Withdraw, thus allowing Defendant's Counsel to withdraw her appearance, and the appearance of the law firm of Robinson & Geraldo, for Defendant in this action. Respectfully submitted, I t :r~~::es, Esqu1re ROBINSON & GERALDO 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110 Attorney I.D. '76272 (717) 232-8525 Attorney for Defendant ~ . , RONNIE E. HONICK, SR., Plaintiff, vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : : NO. 3338 1995 CIVIL TERM : : : CIVIL ACTION--CUSTODY MICHELLE R. RABENSTEIN, Defendant. ORDER AND NOW this day of 1996, it is hereby Motion to Withdraw is ORDERED and DECREED that Defendant's Counsel's granted, and the appearance of the law firm of Robinson & Geraldo is hereby withdrawn as counsel of record for Defendant for the above proceedings. BY THE COURT: J. CC(Q)rP~ Exhibl: ItAII RONNIE E. HONICK, SR., Plaintiff, VII. MICHELLE R. RABENSTEIN, Defendant. AND NOW, this . , , I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA I I I NO. 3338 1995 CIVIL TERM CIVIL ACTION--CUSTODY mu& day of , 1996, a Rule is hereby issued upon all ~arties to show cause why the Motion to Withdraw should not be granted. RULE RETURNABLE DAYS FROM SERVICE. J. :1 . RONNIE E. HONICK, SR., Plaintiff, VB. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA I I I NO. 3338 1995 CIVIL TERM I CIVIL ACTION--CUSTODY MICHELLE R. RABENSTEIN, Defendant. MOTION TO WITHDRAW AND NOW COMES Michelle B. Stokes, Esquire of Robinson & Geraldo, Petitioner, who, in support of this Motion to Withdraw, avers the following: 1. On or about August 22, 1995, Defendant, MICHELLE R. RABENSTEIN, retained the law firm of Robinson & Geraldo to represent her throughout the above-docketed custody proceedings. See Exhibit "A" attached hereto and incorporated herein. 2. Petitioner has prepared various court documents, attended a CustOdy Conciliation Conference, and corresponded with Defendant and Plaintiff's counsel with regard to the custody proceedings. 3. Defendant currently has an outstanding balance with Robinson & Geraldo in the approximate amount of $927.50. 4. Defendant has refused to cooperate in attending her scheduled appointments for the custody evaluation, as ordered by the October 25, 1995 Court Order. See Exhibits "B" and "C" attached hereto and incorporated herein. 5. Petitioner has been unable to contact the Defendant by telephone or by letter. 6. Upon telephoning Defendant's home telephone number, Petitioner discovered that the telephone number had been disconnected. ~ " ~ -, ., '. , . , I '., ". '.., ,-. ..., '-- ? '-. ,:,..., .'') " , ,(') " : rn I . 7. Petitioner has made numerous attempts to contact Plaintiff, and her parents, by first class mail. See Exhibits "D", "E", "F", "G", "H", "I", and "J" attached hereto and incorporated herein. The correspondence sent to Defendant by first class mail is not returned, however, Defendant has not contacted Robinson , Geraldo as requested. 8. Petitioner has been unable to locate Defendant's whereabouts. 9. Petitioner's continued representation of Defendant has been rendered unreasonably difficult by virtue of the client's absence, and good cause exists under Rule 1.16b(5) of the Pennsylvania Rules of Professional Conduct for Petitioner's withdrawal of appearance in the case. 10. Despite a fee agreement requiring payment by Defendant for Petitioner's services and the submission of bills to Defendant, Defendant currently has an outstanding balance of $927.50. 11. The continued representation of Defendant without payment of Petitioner's fees, or the prospect of such payment, has resulted and will further result in an unreasonable financial burden on Petitioner, and good cause exists therefore under Rule 1.16b(5) of the PennJylvania Rules of Professional conduct for Petitioner's withdrawal. WHEREFORE, Petitioner, Defendant's counsel, respectfully requests this Honorable Court to grant this Petition of Counsel for Withdrawal of Appearance. Respectfully submitted, , :r~~~qu~e ROBINSON & GERAL~ Attorney I.D. No. 76272 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Defendant ROBINSON &. GERALDO ...0...'110....." CO."OlllA'IO.. ATTORNtVS AT LAW Pos' 0"":0 Bo. 5320 Hatrlsbutg. PennlVtvln14 17110,5320 WIll 5/10<. 35'0 R_ Road Comp H., PA IIllII (711) 737,2779 HAfIlIbUlQ "lI7 NOIth FrOIlt 51 HamSOurg. PA 171 to 1711) 23US25 WlohonglOn, DC t3te~...... SE. WlohonglOn, DC 20003 (202) "".2N1 RETAINER AND FEE AGREEMENT 1. This is a Retainer and Fee Agreement entered into between THOMAS AND CONNIE MCCONNELL (CLIENT) and ROBINSON AND GERALDO (ATTORNEYS). 2. Client does, hereby, retain ROBINSON AND GERALDO as attorneys concerning: Representation of Michelle Rabenstein regarding Custody. 3. The following matters are to be undertaken by ATTORNEYS for the CLIENT pursuant to this Agreement: Representation of Michelle Rabenstein regarding Custody including preparation and filing of all necessary and pertinent documents, and providing legal counsel as necessary. 4. The CLIENT agrees to pay the following costs for services performed: The CLIENT agrees to pay $150.00 per hour for ATTORNEY time. The CLIENT agrees to pay $150.00 per hour for ATTORNEY time in regard to all Court appearances, hearings or depositions. The CLIENT agrees to pay $125.00 per hour for Associate Attorney time. The CLIENT agrees to pay $50.00 per hour for Paralegal time. The CLIENT agrees to pay $20.00 per hour for word- processing services. 5. CLIENT also agrees to pay for all out-of-pocket expenses, including, but not limited to, expenditures for filing fees, transcripts, subpoena and deposition fees, long distance telephone calls, postage, xeroxing, travel and all disbursements necessary for the proper performance of legal services. a. b. c. d. e. 6. CLIENT will be billed on the basis of the time spent and services performed on this matter. Telephone conversations between the ATTORNEY and the CLIENT will be billed at a minimum of one-quarter (1/4) hour. Telephone conversations between the ATTORNEY and opposing counsel, party or other interested party in this matter will 6e billed at a minimum of one-quarter (1/4) hour. E.h,b'l A ROBINSON &. GERALDO .- II.. 'f r I I I I .. .. .- L .; II '1 .. '1 n 4 r , ., of RETAINER AND FEE AGREEMENT Page 2 7. The CLIENT agrees to pay ATTORNEYS a retainer of $600.00 against which the charges described in Paragraph 4 will be deducted. This Agreement will not be effective until the retainer fee is paid and this Agreement is signed by ROBINSON AND GERALDO. 8. ROBINSON AND GERALDO will bill the CLIENT as work progresses on the matter as itemized in Paragraph 3. The CLIENT agrees to pay ROBINSON AND GERALDO when billed, but in no circumstances later than ten (10) days after receipt of the statement. A 12' annual interest charge will be added to all accounts with balances due for more than ten (10) days. 9. The CLIENT understands that ATTORNEYS may not ethically bear the costs of litigation for CLIENTS. Therefore, ROBINSON AND GERALDO, at their sole option, may withdraw as counsel should CLIENT'S account become delinquent by a period exceeding sixty (60) days. ROBINSON AND GERALDO relinquishes no legal claim against CLIENT for any unpaid balances as a result of such withdrawal and will utilize the law to its fullest extent as a means of recourse to fully protect their interests. If it becomes necessary for ROBINSON AND GERALDO to pursue their legal rights, CLIENT agrees to bear the cost of all attorners' fees associated with the litigation of the matter at preva ling attorney rates. 10. If CLIENT disputes any charges, the CLIENT must notify ROBINSON AND GERALDO in writing within thirty (30) days. ROBINSON AND GERALDO will make every effort to clarify or correct any disputed charge. 11. The CLIENT understands and agrees that this Fee Agreement does not include legal services in connection with the appeal of this case. CLIENT will have the choice to retain ROBINSON AND GERALDO under a new Fee Agreement should this matter involve an appeal. 12. I have read this Fee Agreement in its entirety, and it has been explained to me, to my satisfaction. I understand the ~~~;m~a~~~~tain~~in the Agreement and hereby agree to abide by i~ )z a.~ ~ 08 & GERALDO DATE ~~~~h:/iCT) /) . ???!/J I'JJ: C&lf~ Mcc6NN~<<""'d""f-(CLIENT) ~;S/95 R - :;;(.;<- 9 s- DATE Pauline Wallin, Ph.D. LIClnlld PJ)/ChO/II,IJI '" Associates 201 S.u,h nnd Slreel Camp Hill. PA 17011 (117)161.1114 PAX (111) 161.1942 July 9, 1996 Ms. Michelle Rabenstein 9421 Atwood Avenue (Apartment BI . Norfolk, VA 23503 Dear Michelle: I'm sorry you missed your appointment with me today. As you will recall, when we spoke on the phone a few weeks ago, I set aside 2 hours today, July 9, and 2 hours tomorrow, to see you and the children. This is the second time you have failed to show for an appointment. Although the appointment was for 2 hours, I am billing you for only 1 hour for a missed appointment. Because this time was reserved for you, no one else could be scheduled. If you wish to re-schedule, please be advised that ail future appointments must be paid for IN ADVANCE. I regret that we need to do this, but I cannot continue to reserve blocks of time when you do not show up. Sincerely, C7y{,jJ ~ ~L1NE vJAlJN, Ph.D licensed Psychologist PW/eg cc: Gerald Robinson, Esq. ;" Exhibit CONSl PSYCHOTHERAPY B 'J';r 2 5 1995 OCT. 27 1995 RONNIE E. HONICK, SR., Plaintiff IIN THB COURT OF COMMON PLBAS OF ICUMBBRLAND COUNTY, PBNNSYLVANIA . . v INO. 3338 - CIVIL - 1995 MICHBLLB R. RABBNSTBIN, Defendant . . . . ICIVIL ACTION - CUSTODY COURT ORDER AND NOW, this .;)S"1J.,day of ~j;;J~. , 1995, upon consideration of the attached CUstody Concil-iatlon Report, it is ordered and directed as followsl 1. The Hearing scheduled in the above case for October 19, 1995, is cancelled. 2. The parties shall submit themselves and their two minor children to a custody evaluation to be performed by a professional as agreed upon by legal counsel for the parties. Costs of , this evaluation shall be shared equally by the parties with an adjustment such that the Mother shall incur any expenses directly related to involvement of her husband in the evaluation process. Upon completion of this evaluation and in the event the parties are unable at that time to reach an agreement, counsel for either party may contact the Custody Conciliator at which time the Conciliator can either convene a second Conciliation Conference or file a report with the Court to schedule this case for a Hearing before a jUdge. 3. Pending further Order of the Court, this Court.s Order of June 29, 1995, shall remain in effect. .-J' BY THB COURT, J~i/gl J!1~;!ily ~~~.' CCI Ronald E. JOhnson, Esquire Gerald S. RObinson, Bsquire ;:1"-:" ~-.~" !":'~J"'lrl~1 "t"""'ORD 'I- ~ .'. '. '.' . ......... . ~.',' ",: .':, ' , '.:' '1, ~.:, my hand .. ". .";" \' '''''J'','"", Pa I ~.t:It. .., - . I ..oJ, . Tn,. ,:u.. =~y c; ~. ~ ~"., 19,~-:t ....,,,,, , (( .)~ ."'" "", .'P~~jh:nt:a~"'.""'''' Exhibit c ..-; . .. ..' 0'. .~'::~~~::};;:~' . 'r! ...t~'. "'. ':~,&;:j.;~ ';~..:. .5f:...~.....-t~. . . 'l'~~~i':~:;::" '",I"A':;I''''' "(lt~;i>: ," I', .t.!'"..... .;-.... .' " , ~J~~l~,\:...:~. .~....'.. . ,~i~.'f::,":~~ ' ,.... a~ftl....~ ," ..i"f.I..J..... ,:f~,r;~:D. , .~~~~:;... ., ""~.. ~ , t;'I.." ." , ;,,~.:t--.... "," .oJ . i.~~:;;'. ...,~I"'.: ., . .. .. ~...' ~. ~ ~,:}:\> 'C!t.~. . '~N' ," "~"'''''' .4:..... iti", t... .' " , . .: li:.." "1r".. ~l... I~' .......,' . I .. ROBINSON &. GERALDO . ".0.....0..., cO."O_."O" AnoRNM AT LAW Poll 0IIce Ilolr S320 Hltlllllutg. ~... 1711()'5.:J20 Michelle Rabenltein 9421 Atwood Avenue Apt. B Norfolk, Virginia 23503 ReI Out:8tandlna BIll Dear MI. Rabenltein: " HBSljmm eel T. , C. McConnell Exhibit - o ~ "bel...,.","" ~,~'ro" (711l7'H.S' .-., .co,......,....... ......." ~ ""0 (71 II m,M7S June 28, 1996 Sincerely yourl, ROBINSON , GERALDO ~",".D,C. ':lllS".II~Aw.. S,E. WI~.... D,C. 7COO3 1207l54C.21le8 . j: . :" !.:f~.:;;,; ~ c, :.:; ~. ";,.., , ., .....~.. .:. ~. . " .., to...'.,' ...~...;:~:. ". ',I, ':or' ,.I 'j ROBINSON &. GERALDO . ""'.'1"".' cO..O.."O_ ATTOlNM AT LAW PllIl 0IIlCI1IclI ~ HIIftIburg. Pw~ 17110.5:120 c.. ,'.......,.- ~"""OIJ (J"Ut:l-..,. """""" ..o,......_ec. ~""""O (J1'lDl._ WUI*'og'on, DC, IJ,ePtM_A",..SE. WUI*'og'on. D,C, 2DOO:J l2D2l ,tHII89 July 10, 1995 .".. ... .' .... '. ,'-~' ': '. '. " .:.... .' .' '. .../ ;. ;,;'.',?i,:J>>: '".1. \1:"': :" '. '.. .'- _:..~. ",;1..- .' :,.~~J~::i~~.;~~~~:~:: . .. .'.:: :';'..;':"'~"\"i\!.:r;'~1-'S~' . ......,....,.!.':1.~ ~.,~.~....., 1. .' "':";"r-.'~-r...~':t"A- I have attempted to contact you by telephone but' have.::"'~!i:9..~,\\~~:'t~i.:, discovered that your phone hils been disconnected. Additiorially~,::,;..:>:,':;" . . I forwarded letters to you on June 18 and 28, 1995, but you.'.have"':';.:,.:;~'.: ,'.' '.. not responded. It ill important that you get in touch .withl;!li~:l!.ot,:'~;,:3.:;~ : )..., that we can communicate. Therefore, please contact me witll'~your.~ ,"'L~' . . ',:, correct new phone number. :f~~~tt~J~:~i. ,:""0',_ .' . -_. ~~f~?'~,~'''''~",,~'~~~-' ,. ..' I am lltHl waiting to receive from you Ronnie Honick.r, s ::';!lO~~\~~;f.~~:, Social Security number and date of birth. Please send th'iIil:~.;.:~~J~;'=':~t:i': ~-_~.':.,~,!._".'":.,'._:,',:;,.;,'.~.:.,.,, ~~f~~:~i~~c~~dm~h:~k~oon as POSSibl~ so that we can re~€~l~ii~~~( . . Please note that I was cOf\tacted by Dr. Wallin tOdayt~nal;;;";"::;:{:C:t:,' ,,..,, , " she informed me that you did .not appear for your scheduled..~.!t.,..jf.~:'tii:!~'; :.;: . :';::':'0::" , appointment with her. Obviously, she had set aBide an amount;::Of.~:k':t:. '..i.7":,":ftf'~.~ ,time to meet with you and was inconvenienced when you. didhno,t~.f -'!'}~':%.: l..~.~i:;,:,t:'j;_,..appear or call her in advance to cancel the appointment; :,!Dr~~~ . .'~;,;'j.' ,.."" ." 'q",.;-: Wallin is now going to require that you pay in advance. for~ all-::1~""~'::"';'~:'.\ ...,/ future appointments. You should be aware that your failure,:to:~' '~0~i:"" .:'~ :~,appear for your appointment is not Onl! delaying the progr,ess'::of:-;rii,':" "",~1,:.~.. your case, but i8 also causing Dr. Wal in to believe that' you~'? ~:"i';,;',:::: .': ll<i"" are not cooperating '. ',.' ....,"'.. ... , ",,~lS~:~,::~~::i~!~. .-' , . !~:,~::,~Y~~$~t;r ';"" . ',:::. ;:. '.. . . . ~. : ~ .... ".:. :: , . ";'. ii ~:. .,...-. ;.i:....~...: ;" .: '..~: . .~ Michelle Rabenstein 9421 Atwood Avenue Apt'. B Norfolk, Virginia 23503 Rei CUIlt:odv Dear Ms. Rabenstein I :~.:.,~ ' i;:::, -"'v, . .' . ' ",:;::"'::~;~:~:.i . '. .... .'r:"'~'..tc.'.'. .: '.:~~ .:~.;.?:",.'. . " ..:...:.'.. .~. . . '.-' . ," '" . ....:. · ;:, ~(.,.1i:~'; E.h,b,1 ,'. - E .' ..--- .. ,;. . \:\~:'~;~" . .' . ~. ll':.';" ''','', "';"'/l.!I-.' , "..' " ';..'-;'. ;;. Il:';',,' '1'hanJc you tor your prompt attention to this matter. "It.you" '.' , any questions, please do not hesitate to contact me. '. , , :1'\:':' .....:. .~; ,~ti~,~ - ROBINSON &. <..iRALDO ,1!:~.. · ..0....'0..' .0..0..'... ;]"J..' '\ ,f' Michelle Rabenstein '" July 10, 1996 Page Two '.. .i.' " 'have Sincerely yours, ROBINSON , GERALDo '. :::,. .1'. . ")Jl: .... MBS I jllllll Br~~ M cne . 0 es, CCI '1'. , C. McConnell . ;i)::i':;, " fIp:.....)J,', ~ ."~~":~' :,\: -'''''' ' ....~.:~' . .' " .' :;.... ,,;. '.. .. ';'..S~:~',~~:.!' ~1..'~'.~;;~' ; ; .1k.~~"'" . ~'.. ..~ " , ~;:r,:,:. ." ~J;' ' ~::'< " - " ,. " 'r "," I:.:'. ; " '::,/ ~. " ." . ..:t ..' ,,' .,' .'t,;..... EsqUire ",:f;,::. ",'c', ' '::,,:: ;,':f.~::::~;:~~\~:;~. "::;:I7.f:.~:;E:,~J,'::~1' ..:.... :.~:!-~~P.~i::.. ;A',<',~ t; ;?~,:~~:~r~.::' "fi:f.... ..~,..- ,'~',~'~"!' ....."'."" . -.,..$ :......,.' 'If.,~ ,...~.r.'\,..~. ''j;'" -: \. :i~',,~,~.' . t~;:.:::..;',"f'~;?~ ,:0- ~'"I''' ..~ .......,.,.,.-...1'.. ...,:,~:.~ t: ~:~r""J~,I\C.;:-~',,, ~~::.~:ll'~\i~::~:'.~~~~;f. . '-.~ .. 1:. ,:~)"ri;..;'~~~''''~ '," .', ;......':~..,.... :~"': .:;~~: ~~:.. ::',,":,,'1. ",; ". .,...".;,....."........0.;,.: "..... "::::;:.}ti~:'4f.f~~h1:. ,.' i. ~. ';:"';;:"::'::"~':':fJfi"fttft(:~~~. :;., ,;.~. '~'i>!i:'!.;:...~. ; ":~:';~!, .,. ~..~.~1',~".~...~.<t...t' t ,," Iklt..,~..,.. ......~~,'t;'- '~;'. fl": ,!\"'::-:"::. ::r"..\:t..~...:. .~. "",;, .~-~. :'.,: :gr, ;~;~.,.r" . .:1.,::~ .>1f:ir.;'~i;/;:~.~:r\.~' :.- .t..::. ~{~).~' '''f..~:r::::~.:.. :~.,! ;:,,;;),:-~.:.::':.::';i!:~":'. 'r ~':::" .:... "ij~q:,)..;: 'i I..' ,~. ......~'~~~. . .;,' "t: ';:.; :;~~\~~:\~1. '. r..'O. \'~~:~~:' ~ ! i[}~~ti , -;' ::t.;;':~..'\:l-":i.": lJ, -.'.., ~: ''', ',.1, ".;,".;- " . ,.:.:~.... .':' ~-: "" '~, '.' .' ......... .,: ...,J'I,t...... ..' .?, + ..:...:,.... .' ., , II I. ~. , .- "':':. : '-l\..~:.... " .... '" .. :.~.., ...... .. .:~.r~: ',::;: ,,:.;~~"..;. "..........0.,. :""'0\. /~~. ....~..,.~~...... . oQl...~~...ri:.;...:. . .~~f l:'.~.i,~' . .).~'''lr''',,,,:,, .~..:. ~~..\.. ~7~~;~~:}~. . "'...."...t:...;l. "f . "l.i":~f;' .". '". f) . . ?'\,ii. "" '9(. ->.'\.'i _i~ , !-.oll',:l'. . .'.~,; ..."., ,'. ROBINSON &. GERALDO · '.0'....0...' cO.IIlO."'to.. AnoRNtvS AT IJ\W Pool 0IIice Boll 5320 Hllriabutg. ~ 17110.5320 c...... 'FEIII"IJII_ eM........ !F013 171 II 20s.o0S1 ~ O<OF ..... ,.... Sl. HItrlIIug..... !FIIO P1IIm.8SJS WaIllinglon,D,C. , 1311 PoM......... A.... SE, lYiII*lo..... D,C. 20003 C202J SrW.2118 ." I .:: ~~l/" : " ..f~~F' July 26, 1996 .. . Thomas , Connie McConnell 30 Ray Road Middletown, pennsylv~nia 17057 Rei Michelle Rabenstein , " '. Dear Mr. and Mrs. McConnell: ';, " , . , ~. . " .' . i;,.' ._, ;.1-;' ~~-i~:';~:.~.~' I am writing to you in an attempt to reach l!fichelle'j' '. ,,~:: ):.r> , Rabenstein. She apparently missed her appointment with Dr.,- . ' :.:"',:~,, Wallin without calling in to cancel. Additionally, I have " ", 0.:. ,-. attempted to contact her numerous times by telephone and by " ' " ",~,:' letter, but I have been unable to reach her. Recently, I have ':~:'O:::" discovered that her home telephone number has been ' ;'.' , . ~ ..'.'~:. ' disconnected. Obviously, her case will not proceed if she is ,._:' ,:", , unwilling to cOllllllunicate with me. Also, she does have an:,., ", ,;:'" outstanding balance with this firm. Any help you can provide, me ,.' ::':, would be appreciated. I look forward to hearing from yoU:"'i~:rthe::> ';;: ' near future so that her custody matter can be resolved. '.... "'::::'~;;:;:\~"i:;r'~I":' . ,'. ~ ," :.~<~,:: :':~~~!'~:::f~:: . .It.' ......~. ... :.:i}::-~'.~;;' ''':'.' ~"'~'\~'" ....' _c"~.~.\r":.r~~f'- :. . .,~ .I.f.... McWo~~, -.~qu'".:~~~t~: '},J':: A~~~:;~~f~~!j' , '.." .'.'."I'~~'i:1i. A.:, Ift~r .0 . '.;;~.ta.~').i::~~.~"&. '.';. )';??~::{i.;' , .....\".. . :> ::~.. '.:r::. . . I :~:: '.~\ !. . .. . . ~ .. Sincerely yours, ROBINSON , GERALDO " MBSI:l1IIllI CCI M. Rabenstein . . .. .. ;r .... ..... Exhibit , . . :: I ,i..: . . . i:;.;/ ~~ ~;.~: ~.l~:~:"~_'~' '. .. .- F ;.... ;..; . ~.;. ~:~:.'tt'~ . )."'..;t.,;~ ~~ : ~./t:~::'~ f ", .' .... "... '.. '_f, '. ...... :.~l::~r::.. ~. t. "~fi"~..~ .... ....... - ROBINSON &. GERALDO . 1l1l0'C"10"., CDIIIlOII..,O" ATTO.NtYS AT LAW Poll Offoce &0.. 5320 HllriIburg. ~... 11110.5320 c...", I' Eo., "V" 51..., c:"q", '" "Ol~ I' "1 ~'H'51 -...g .og'......,.... SL -...g, '" ""0 l''''un.&lD Wlww.g..... D,C, '~IIPtm_",-,. se, WI~..... D,C, 2000:1 l20ZJ "'.zen August 12, 1995 .:. ...~:...... .' '.' ..,;,~~:(,! ;' .~::: :.',. . Thomas , Connie McConnell 30 Ray Road Middletown, Pennsylvania 17057 .. .' ~.' ~'1'~'4 ,. ," .........:; . , ' '.. r:'..~'::, ~. ;, '.... Re: Michelle Rabenstein Dear Mr. and Mrs. McConnell I ;', " ::. l~ ' I am writing to you in an attempt to reach Michelle , :". ~~>:'r, Rabenstein. She missed an appointment with Dr. 'Wallin, and IihfL:;:,~l:';:'" has not answered my letters. Additionally, I ha.ve attemp,ted .,.tc?,~/"~':'<: contact her by telephone, but have discovered that her home ;"I"",.:~,,;'\t:,,:;, ' telephone number has been dillconnected. As I indicated .in a }t~,:,: \'i( ", ' previous letter to you, her case will not proceed if she Is, ,f,Y,.';.:""." unwilling to communicate with me. Also, she does have an. ,',:' :.;:{.: <.".:L.., ' outstanding balance with this tirm. If she does not intend, to,'r"f;",:;::,'Jk'" proceed 'dth this custody mattor, I am requesting that sh'e .:I::~,~'''''!''''1',:t:.;:'\ inform me of that decillion so that we can close her f.1le.,;:wit~.~il;i'~~~f~~h'('" this firm. " "',,1- . _.",'" , . ;,.. . ~':"~it~$:'~.~~'~";" Thank you for your prompt attention to this matter.:', Any':.~:~":::}~" help you can provide me would be appreciated. I look forward' to "1!'" hearing from you in the near' future so that her custody matter',; ':-,.",t " can be resolved. ".:".~.... 00 ,.;. .f.... Sincerely yours, ':~~;'~ij~J':::' ROBINSON' GERALlJO . ...f"...\ :':~ .~:.::~.;~~~~ ::.:.' MBSljmm CCI M. Rabenstein =~es, ~ " , . ":~'" .' Esquire " '. :"'" ", . ~ .1.. _:..:.'. . . , ,.' ". ,.. . " " 't. . , \ ',.., . ,', " , .:...., '. ", ,./ ., Exhlbll ::~ ;.., , . 'I' G "," . - -- --,_,-"c~, ,,_~,_. '__, -, ...........:-,,---, ,.,,' '. ..', ., ~,. '. " { I:: I". ' I'~': :",: ,.,;. " ..... .... 10' , l ",. .'. ; '~ . i \.. .. i , ROBINSON &. GERALDO , '.0'.11'0".' cO."O..'IO.. AnolNtl'S AT LAW Potl OtIC' eo. 5320 H,lrIlbutg. Pennrytven.. 17110-5320 c...... '7 Ea""'1'SI..., c:......."" 11013 1"7)~4H4~1 "-Wg 4407 ......,..... 51. H.JmslIuog. "" 17"0 (717) ~3z.aS~S \YNIwlg..... D,C. 131IPOM~A".. 5e. \YNIwlgton, D.C. 2000:1 I20JJ SOHII8 August 12, 1996 Michelle Rabenstein 9421 Atwood Avenue Apt. n Norfolk, Virginia 23503 ReI Custody Dear Ms. Rabenstein: r, '.... I have attempted to contact you by telephone but have ;} ';,; _,;..,. " discovered that your phone has been disconnected. Additionally,.',~ I forwarded letters to you on June 18 and 28, and July 20,' 1996,.... " ,', but you have not responded. It is important that you get in ',,'. .:, ". touch with me so that we can communicate. Therefore, please. .' '::. ,,'. contact me with your correct new phone number. . .:,_.' >J,:~ :,;,,; ,'. , ':',"::,'~'~:-'.:':"':f:~'.:':';:', I am still waiting to receive from you Ronnie Honick's ";:< '.;':'.':F>" Social Security number and date of birth. Please send this ...';::::.,,!..(~':..::, information to me as soon as Possible so that we can request:' a': "~"':~' criminal record check. , , '..: ':'::,' . ,. . . - " ~. Also, please contact me 'regarding any appOintments you'have made with Dr. Wallin. Your custody matter will not proceed .'..' .. until you have completed your evaluations. It you do not intend. '';',' to pursue this custody matter, please contact me regarding that"" ,.'., decision so that I can close your file with this firm. Thank~, ,':: ~"': ' you for your prompt attention to this matter. If you have any...::,',. ;~' questions, please do not hesitate to contact me. : . .,.. . .. , .' Sincerely yours, ROBINSON & GERALDO ".. ".: ~" . '. ~l~~~ EsqUire MBS l;Jmm CCI T. & C. MCConnell E.h,blt H .-.-..-...- ROBINSON &. GERALDO . ..O'."IO".L cO."O..'ID'" ATTOINtl'S AT LAW Poll Ofl'el Bo. 5320 HllriIbuIg. l'Innoylyenil 1711()'532O c...... '7 elS'HogIISI...1 CIIttIo. "" '70'3 11"12'5"'51 HlnOSllutV "07 _. F.... 51. Hamtllurv. "" III 1 0 11"1232,1S25 WltftinV.....O,C. '311~.Ioo..s.e, Washing..... O,C, 200lXl ~5U.2en September 4, 1996 Thomas & Connie McConnell 30 Ray Road Middletown, ~ennsylvania 17057 Re: Michelle Rabenstein Dear Mr. and Mrs. McConnell: I am writing to you in an attempt to reach Michelle Rabenstein. She has not answered my letters or telephone calls. Therefore, if she does not contact us by Friday, September 13, 1996, we will file a Motion to Withdraw from her case. Thank you for your prompt attention to this matter. Any help you can provide me would be appreciated. I look forward to hearing from you in the near future so that her custody matter can be resolved. Sincerely yours, ROBINSON & GERALDO :I~~ Esqu1re HBS: jmm ce: M. Rabenstein Exhlb.1 I · '.0'....0...." CO.~O..'IO.. ROBINSON &. GERALDO ATTORNtl'S AT LAW Poll OHIC. eo. 5320 H.,t1,bu,g. "-nnsy/vlnit 17110.5320 COlt'" .7EoIlHogllSIIlltI c......."".7013 17'7)20500451 ~ 0007 NotI" ,..... 51. Ham~'''''17''0 (7171232'e.l25 Was/WlgI.... O,C, 1318 Ponnl)lvlnil "..." s,e, WalNngton, O,C. 2OOO:l l202l ,.0.2_ September 4, 1996 Michelle Rabenstein 9421 Atwood Avenue Apt. B Norfolk, Virginia 23503 Re: Custody Dear Ms. Rabenstein: I have attempted to contact you numerous times through letters and telephone calls, but have been unable to reach you. Therefore, I am writing to inform you that if you do not contact us by Fridav. SeDtember 13. 1996.we will begin proceedings to withdraw from. your case. Thank you for your prompt attention to this matter. forward to hearing from you in the near future. Sincerely yours, ROBINSON & GERALDO I look MBS: jrnm cc: T. & C. MCConnell =r~s, ESqui.re " E,'"bll (" \ " ( , , . VERIFICATION I verify that the statements made in the foregoing Motion to Withdraw are true and correct to the best of my knowledge. I understand that false statements herein are made subject to the penal tied of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ~ ROBINSON , GERALDO Petitioner Esquire RONNIE E. BONICK, SR., Plaintiff v. MICHELLE R. RABENSTEIN, Defendant , " . . . , . I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW . . . . . . . . . . . . NO. 95-3338 CIVIL TERM AND NOW, this Z..c:l. day of October, 1996, upon consideration of the Motion to Withdraw, a Rule is hereby ISSUED upon the Defendant and Plaintiff to show cause why the relief requested should not be granted. RULE RETURNABLE within 10 days of service~ BY THE COURT, Michelle B. Stokes, Esq. ,/4407 North Fr~nt Street V P.O. Box 5320 Harrisburg, PA 17110-5320 Attorney for Defendant Michelle Rabenstein 9421 Atwood Avenue Apt. B Norfolk, VA 23503 Michelle Rabenstein c/o Thomas , Connie McConnell 30 Ray Road Middletown, PA 17057 Ronald E. Johnson, Esq. 78 West Pomfret Street Carlisle, PA 17013 :rc TRUE COpy FROM .RECORD In Testimony whereof, I hire unto ,set my hand and the seel of Slid Court at Carlisle, Pa. ~Is .~~~... day of,..&.d;,.:...., 19?-'_ ~./l~...~.t'.~ Prothonotary Exhibit liB II . . , . . t I . . . . . VERIFICATION I verify that the statements made in this foregoing Motion to Make Rule Absolute are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. MiC~~SqUire ROBINSON & GERALDO Counsel for Defendant ~ .. - . . I ., . . - , . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA RONNIE E. HONICK, SR., Plaintiff, '/8. NO. 3338 1995 CIVIL TERM MICHELLE R. RABENSTEIN, Defendant. CIVIL ACTION--CUSTODY CERTIFICATE OF SERVICE I~Michelle B. Stokes, Esquire, do hereby certify that on the ay of October, 1996 I caused a true and correct COP! of the Mo on to Withdraw to be served upon the following individua and counsel of record by first class mail by depositing same in the United States Mail, postage prepaid, in Harrisburg, Pennsylvania: Michelle Rabenstein 9421 Atwood Avenue Apt. B Norfolk, Virginia 23503 Michelle Rabenstein c/o Thomas & Connie McConnell 30 Ray Road Middletown, Pennsylvania 17057 Ronald E. Johnson ANDREWS & JOHNSON 78 West Pomfret Street Carlisle, Pennsylvania 17013-3216 Respectfully submitted, :t~~~~es, :EsqUire ROBINSON & GERALDO Attorney 1.0. No. 76272 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Defendant " ~: i' i ~. ~; ~' \@ ,", ,. 11: i~-'-: IU;: <..)".- E~" '[' ~f-, ~" u:l' r::= l\.. o (') f:: c , ("') :!< ,17 -'~~ 4J.. .;~ ...:> :'~/? 1-' J:Ji5 (..., ~~-~ u. c;..: ~.:: V'l ::> u' <J . . '5 .'... . . . (717) 232.8525' ROBINSON ^l'.:!:> Gtn.ALDO ATTORNEYS AND ~OUlist~J.ORS AT LAW P.O. Box S3Z0. HARRISDURCi. PENNSYLVANIA 17110.5)ZO .. .. .~ ~, )r .. ~ .... .~ J s=- . ; III ! .. ~EnTIFJED TRUE ^ D CO'''''ECT COPY :J6