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HomeMy WebLinkAbout399 S 2007 RICCI-FIBER V FIBER (2) CHRISTINE J. RICCI-FIBER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : DOMESTIC RELATIONS SECTION v. : : DANNY R. FIBER, : PACSES CASE NO. 253109192 Defendant : NO. 00399 SUPPORT 2007 IN RE: PLAINTIFF’S EXCEPTIONS TO SUPPORT MASTER’S REPORT BEFORE HYAMS, J. OPINION and ORDER OF COURT HYAMS, J., June 22nd, 2021. In this child support case, Plaintiff mother has filed exceptions to a support 1 master’s report which recommended a basic support obligation for one child on the part 2 of Defendant of $773.00 per month as of March 15, 2020. Plaintiff’s contentions have been delineated in her brief in support of the exceptions as follows: A. The Support Master erred in calculating \[Plaintiff’s\] income. B. The Support Master erred in failing to consider \[Plaintiff’s\] request for an upward deviation of Father’s child support obligation pursuant to Pa. R.C.P. 1910.16-4 \[relating to support guidelines’ assumption that child spends 30% of time with obligor\]. C. The Support Master erred in disallowing \[Plaintiff’s\] childcare expenses as of March 15, 2020. D. The Support Master \[consequently\] erred in calculating \[Defendant’s\] 3 arrears. 4 Oral argument on Plaintiff’s exceptions was held on April 9, 2021.For the reasons stated in this opinion, the case will be remanded to the Support Master on one issue. 1 Mother’s Exceptions to Support Master’s Report and Recommendation Filed May 18, 2020, filed June 8, 2020 (hereinafter Plaintiff’s Exceptions to Support Master’s Report). 2 Support Master’s Report and Recommendation, filed May 18, 2020 (hereinafter Support Master’s Report). The recommendation was three-tiered, with monthly obligations being recommended of $901.00 for the period from July 23, 2019, through December 31, 2019, $936.00 for the period from January 1, 2020, through March 14, 2020, and $773.00 thereafter, plus a one-time charge for Defendant’s share of the child’s extracurricular activity expenses of $1,118.00. Id., at 17. 3 Mother’s Brief, at 5-8, filed November 15, 2020 (hereinafter Plaintiff’s Brief). 1 STATEMENT OF FACTS 567 Plaintiff is Christine Jean Ricci,also known as Christine J. Ricci-Fiber,48,a 8 resident of Camp Hill, Cumberland County, Pennsylvania.Defendant is Danny Roy 9 Fiber, 49, a resident of Palm Harbor, Pinellas County, Florida. The parties are the 101112 parents of a boy born in 2006,who resides primarily with Plaintiff/Mother; the 13 parties were divorced in 2011. Plaintiff commenced support proceedings against Defendant by a complaint for 14 support filed in 2007.As of January 19, 2017, a child support order was in effect against Defendant/Father in the basic amount of $1,148.00 per month, premised upon a monthly net income of Plaintiff of $1,759.14 and a monthly net income of Defendant of 15 $4,798.21. 16 On July 23, 2019, Defendant/Father filed a petition to modify the support order, 17 citing a physician’s letter submitted to the Domestic Relations Office. This letter opined 4 See Order of Court, dated April 9, 2021. 5 N.T. 55, Support Master’s Hearing, April 24, 2020, and April 27, 2020 (hereinafter N.T. __). 6 See Divorce Decree, dated July 8, 2011, No. 2007-3720 Civil Term (Cumberland County) (Oler, J.). 7 See Complaint for Support, filed May 25, 2007 (hereinafter Plaintiff’s Complaint for Support). 8 N.T. 55. 9 N.T. 8. 10 N.T. 45. 11 N.T. 92; Plaintiff’s Exhibit 26, Support Master’s Hearing, April 24, 2020, and April 27, 2020 (Custody Order) (hereinafter Plaintiff’s/Defendant’s Exhibit __, \[___________\]). 12 N.T. 45-46; Plaintiff’s Exhibit 26 (Custody Order). 13 Divorce Decree, dated July 8, 2011, No. 2007-3720 Civil Term (Cumberland County) (Oler, J.). 14 Plaintiff’s Complaint for Support. 15 Order of Court, dated January 18, 2017 (entered January 19, 2017) (Masland, J.). The effective date of this amount for child support was January 9, 2017. Id. 16 Petition for Modification of an Existing Support Order, filed July 23, 2019 (hereinafter Defendant’s Petition To Modify). 17 Defendant’s Petition To Modify, ¶2. 2 that a medical condition known as ankylosing-spondylitis necessitated Defendant’s 18 relocation from Pennsylvania to an area with a warmer climate, as existed in Florida. A Domestic Relations Office conference produced an interim order of court dated October 3, 3019, assigning Defendant a basic monthly child support obligation of $894.00, premised upon a monthly net income of Plaintiff of $2,006.55 and a monthly net 19 income of Defendant of $3,839.10.In response to this order, Plaintiff demanded a 20 hearing de novo, which was held by the Cumberland County Support Master on April 24, 2020, and April 27, 2020. At the hearing, testimony was received from both parties, Plaintiff secured the admission of 25 exhibits, and Defendant secured the admission of three exhibits. The evidence at the support master’s hearing, in pertinent part, tended to show the following: 21 The then-13-year-old child of the parties who is the subject of this support 22 proceeding has autism and attention deficit/hyperactivity disorder, as a result of which he receives medical assistance by way of Medicaid pursuant to a determination of special 23 need by the Pennsylvania Department of Human Services, takes medication in the form 2425 of Adderall prescribed by a psychiatrist, receives weekly therapy, is socially 2627 disadvantaged, and is not able to maintain a disciplined lifestyle without supervision. According to Plaintiff/Mother’s testimony, 18 Defendant’s Exhibit 3 (physician verification form and letter). 19 Order of Court, dated October 3, 2019 (Masland, J.). 20 Letter from Plaintiff’s counsel to Cumberland County Domestic Relations, dated October 10, 2019. 21 N.T. 92. 22 N.T. 82, 89. 23 N.T. 82; Plaintiff’s Exhibit 14(Medicaid approval notice). 24 N.T. 90-91. 25 N.T. 91. 26 N.T. 90. 27 N.T. 92-93. 3 . . . \[H\]e has a hard time from eye contact to understanding what people are saying to him. He’ll actually have a lot of arguments with people because the way we 28 hear things he’s not hearing it. . . . * * * * . . He has a hard time focusing. And even when he’s in regular school I have to constantly check up and make sure he’s doing things, doing things correctly because he doesn’t always hear the assignment right or write it down, turn in papers. . . . \[E\]ven on 29 the medication, he has a hard time focusing. * * * * . . . \[A\] babysitter makes sure that he does his homework. She feeds him food. If he came home, he would play video games the whole time, and he could burn the house down because he doesn’t know how to use the toaster, or he’d eat a whole box of Cheez-its. . . . And in the morning, especially when I’m working, she makes sure that he gets up and eats breakfast and takes his pill and gets him to school because he has no concept 30 of time. * * * * \[The child cannot be left alone to carry out appropriate activities, b\]ecause he won’t. There’s no concept of time, especially in the morning. We try to keep—you know, when I’m here we have a routine, like, this is the time we do that. And nine out of ten days it’s still a struggle to stay on the routine. We always try to get up at the same time to keep the routine going. Same thing with after school. He wants a snack first so he can have a 30-minute break, but he still has to do homework. But if he was here by himself, all of a sudden he starts looking at You Tube and playing video games, and the next thing you know it 31 would be 7:00 and nothing’s done. * * * * Q . . . \[I\]s \[he\] not capable of taking medication on his own? A No. Q And why is that? A Because he doesn’t like it. It has to be put in candy. He doesn’t like to swallow pills. He has the gag reflex. . . . And he’ll try to run out of the room quick. And 32 I’ll be, like, No, no. come back. Let’s do your pill. 28 N.T. 90. 29 N.T. 90-91. 30 N.T. 92. 31 N.T. 92-93. 32 N.T. 93-94. 4 In terms of income, the child receives a social security derivative benefit (arising out of his mother’s disability) of $690 per month, for which Plaintiff/Mother is the 33 representative payee. 34 Plaintiff/Mother lives alone with the parties’ child. As a result of a medical 35 condition, she has been deemed permanently disabled for purposes of social security. She described her medical situation as follows: In 2008 I was diagnosed with Crohn’s Disease, and it was something that I apparently had for a while. And shortly after my diagnosis my health actually went downhill quickly. In January of 2009 I was admitted into the hospital where I spent the next five months. And what happened is the Crohn’s actually ate through my colon, and they had to remove it. And then my body went into septic shock and lots of other complications. And that's what started all my health issues and why I’m on disability 36 right now. * * * * Q \[Your doctor\] lists on \[a physician verification form\] the nature of your illness and injury is—hopefully, I’ll pronounce this right—ulcerative colitis, SIP colostomy \[sic\] with—maybe you can pronounce it—i-l-e-o-a-n-a-l. What is that? Anamosis? A Yeah, it’s adding a day pouch. Q What is a day pouch? A I had my colon fully—the whole thing is—I had my colon fully removed, and all I have is my—the ileum is the small intestine. So all I have is the small intestine which is still ruptured. That’s what that is, which causes me the chronic pouchitis. Q What are the symptoms of chronic pouchitis? A Cramping—cramping and the extensive diarrhea. Sometimes the pain is 37 so bad I can’t even get out of bed. * * * * Q . . . \[Y\]our doctor indicated here that you’re permanently disabled and can only work a few hours per week due to diarrhea and rectal bleeding. Is that accurate? 38 A Yes. 33 N.T. 69-70; Plaintiff’s Exhibits 8-9 (social security statements). 34 N.T. 55-56. 35 N.T. 67. 36 N.T. 66-67. 37 N.T. 77-78. 5 Diarrhea and rectal bleeding make it impossible for Plaintiff to work more than a 39 few hours per week. In the past, an accommodating employer has facilitated her part- 40 time engagement as an on-air radio personality,although a four-or-five hour shift at the 41 radio station will cause her “difficulties” fifty percent of the time. “Fortunately,” 42 according to her testimony, “the bathroom is close by, but I’ve had accidents.” 43 The hourly rate of pay for Plaintiff at the radio station has been about $11.00, and she testified that on average in the past ten years she worked about 10 or 11 hours a 4445 week, but more recently has averaged about 16 hours a week.The number of hours she worked in 2019 was unusually high, according to her testimony, due to an increase in 46 hours attributable to layoffs of other employees, commencing in October of that year. Thus, for instance, it appears that during the second half of October, 2019, she worked 50 47 hours (about 25 hours a week); on the other hand, it appears that during the second half 48 of November, 2019, she worked only 28.5 hours (about 14.25 hours per week). In any event, Plaintiff testified that I cannot commit to working 20 hours a week consistently. I get flares the more I try to work, and then I’m back at the doctor’s office. In fact he scolds me if I work more than ten because of all of the issues I can have. . . . I have serious issues where I can’t 49 even hold it the more I try to do. 38 N.T. 79. 39 N.T. 79. 40 N.T. 126; Plaintiff’s Exhibit 5 (e-mail from employer). 41 N.T. 77. 42 N.T. 77. 43 See Plaintiff’s Exhibit 1 (pay stubs). 44 N.T. 155. 45 N.T. 155. 46 N.T. 155-56; Plaintiff’s Exhibit 5 (2019 W-2 form). 47 See Plaintiff’s Exhibit 1 (pay stubs) The parties have treated Plaintiff’s semi-monthly pay periods as bi- weekly pay periods, and the court will do likewise for the sake of consistency. See, e.g., N.T. 154-55. 48 See Plaintiff’s Exhibit 1 (pay stubs). 49 N.T. 149. 6 50 Plaintiff’s wages in 2019 totaled $8,182.45,of which $7,182.45 was attributable 51 to her hourly rate. This suggests an average workweek of about 12.6 hours. Unfortunately, as of March 15, 2020, her access to her place of employment was 52 suspended due to the COVID-19 pandemic, and her income thereafter has included 53 neither wages nor unemployment compensation. In addition to her employment income, averaging $681.87 per month in 2019, Plaintiff effectively received $239.75 per month under the federal government’s tax- 54 related “earned income credit” and “additional child tax credit” programs. She also 55 receives $1,380.00 per month in social security disability payments. Her monthly net income available for support thus totals $2,301.62 prior to suspension of her employment on March 15, 2019, and $1,380.00 thereafter. 5657 Defendant/Father is remarried. He has a degenerative arthritic medical condition known as ankylosing-spondylitis, which affects the joints and spine and can 50 Plaintiff’s Exhibit 5 (2019 W-2 form). 51 Plaintiff’s Exhibit 1 (pay stubs). 52 N.T. 72; Plaintiff’s Exhibit 10 (e-mail from employer). 53 N.T. 72-75. 54 See Plaintiff’s Exhibit 2 (2019 federal income tax return). By way of explanation, Plaintiff’s 2019 income tax obligation, in the absence of credits, would have been $560.00, of which $453.00 had been paid via withholding, leaving a putative balance due of $107.00. However, she was entitled to a payment from the federal government under the earned income credit program of $2,644.00 and a payment of $793.00 under the additional child credit program, for a total credit payment of $3,437.00. This obligation of the federal government was, in effect, applied (a) to pay the balance due on Plaintiff’s federal income tax ($107.00), (b) to finance a refund to her of the money withheld for taxes ($453.00), and (c) to pay to her the balance due on the federal obligation ($2,877.00). Stated more simply, if less comprehensively, Plaintiff’s credit ($3,437.00) was applied to her putative tax liability ($560.00), prior to distribution to her of the balance ($2,877.00), which represented the actual increase in her disposable income. 55 Plaintiff’s Exhibit 7 (social security statement). Inadvertently, at one point in the Support Master’s Report this figure is given as $1,390.00. See Support Master’s Report and Recommendation, at 8, filed May 18, 2020. 56 N.T. 27. 57 N.T. 51. 7 58 cause inflammation and severe chronic pain.To ameliorate this condition, he reasonably moved from Pennsylvania to a warmer climate in Florida in late 2016 or early 5960 2017,where he resumedhis employment as a police officer,albeit at a somewhat 61 reduced salary level. His wages have since become comparable to what he was earning 62 in Pennsylvania. As of July 23, 2019, when his modification petition was filed, Defendant’s monthly net income available for support was $4,253.97; since January 1, 2020, this 6364 figure has risen to $4,505.34. His wife’s gross monthly income is about $4,386.00. With respect to custody of the child, an agreed-upon custody order dated May 28, 2019, provides for the parties to have shared legal custody by the parties, for Plaintiff/Mother to have primary physical custody, and for Defendant/Father to have 65 partial physical custody. Under the order, Defendant is entitled to physical custody (a) in even-numbered years at Thanksgiving for a most of the child’s Thanksgiving vacation, at Christmas for 48 hours, and during the summer for 35 days, and (b) in odd-numbered years at Thanksgiving for 48 hours, at Christmas for most of the child’s Christmas vacation, and during the summer for 35 days; provided, that during the summer of 2019 66 his entitlement period was 27 days. Notwithstanding this rather limited entitlement to partial physical custody, Defendant in 2019 did not exercise his Thanksgiving custodial period, exercised only 58 Defendant’s Exhibit 3 (physician verification form and letter). 59 N.T. 30, 36-39, 52. 60 N.T. 9-10. 61 N.T. 52. 62 Defendant’s Exhibit 1 (2019 W-2 form). 63 Support Master’s Report, at 15-16, filed May 18, 2020. Inasmuch as Plaintiff’s exceptions do not challenge these figures, their derivation will not be discussed in this opinion. 64 N.T. 26-27. 65 Plaintiff’s Exhibit 26 (Custody Order). 66 Custody Order, ¶3. 8 three overnights during his Christmas period, and relinquished ten days of his summer 67 custodial period, as a consequence of which he had fewer than 30 overnights with the 68 child in 2019.Nor, as of the support master’s hearing in late April of 2020, had he 69 provided notice, due more than a month earlier, of plans for exercise of his 2020 70 summer custodial rights. This lack of custodial contact was consistent with an established pattern, according 71 to Plaintiff, and she characterized communications between Defendant and the child as “aloof”: THE MASTER: . . . When was the last time—to your knowledge when was the last time the father and the child spoke? THE WITNESS: I don’t believe \[Defendant\] and \[the child\] have had a phone conversation since Christmas. I know the last time \[the child\] had a texting talk with him 72 was Easter. And they are very aloof. They are nothing of importance. In requesting a deviation upward from the support guidelines with respect to Defendant’s support obligation, Plaintiff said . . . \[E\]very day I have to feed him and I have to clothe him and I do everything to provide for this child versus spending two and a half, three weeks with him and having 73 fun visits. Following the hearing, utilizing the parties’ monthly net income figures cited previously, and applying the prescribed methodology, the support master recommended standard guideline support obligations for Defendant in the basic monthly amounts of $901.00 for the period from July 23, 2019, through December 31, 2019, $936.00 for the period from January 1, 2020, through March 14, 2020, and $773.00 thereafter, plus a one- time charge for Defendant’s share of the child’s extracurricular activity expenses of 67 N.T. 45-46. 68 N.T. 46, 109. 69 Plaintiff’s Exhibit 26 (Custody Order, ¶3). 70 N.T. 109-10. 71 N.T. 112-13. 72 N.T. 162. 73 N.T. 109. 9 74 $1,118.00.In this regard, the master largelyaccorded Plaintiff/Mother the benefit of the 75 doubt on issues related to (a) the reasonableness of her childcare expenses, excluding, 76 however, such expenses following suspension of her employment,(b) Defendant’s 77 responsibility for a share of various extracurricular activity expenses, (c) the extent of 78 Plaintiff’s disability in terms of employment, and (d) the effective date of the 79 modification order to be entered. However, the report did not discuss the question of whether an upward deviation from the guidelines in Defendant’s support obligation would be warranted under the circumstances. And, for a variety of reasons, the record does not appear to have been fully developed on this issue. Plaintiff’s exceptions to the support master’s report and recommendation sub judice were filed June 8, 2020. Plaintiff challenges the master’s use of her 2019 wages for purposes of calculating her net monthly earning capacity, noting her testimony that 80 “she typically works on average about 10-11 hours per week,” and, in addition, she “believes it was unfair to add back in her tax refund to the income available for support 81 purposes” and to disregard childcare expenses following her suspension of 82 employment. Further, she challenges the failure of the master to consider and recommend an upward deviation in Defendant’s child support obligation from the guideline figure inasmuch as 74 Support Master’s Report, at 17. 75 Support Master’s Report, at 7-8. 76 See Support Master’s Report, Exhibit “F”. 77 Support Master’s Report, at 8-15. 78 N.T. 6-7. 79 Support Master’s Report, at 3-5. 80 Plaintiff’s Brief, at 5. 81 Plaintiff’s Brief, at 5. 82 Plaintiff’s Brief, at 7-8. 10 \[t\]he record clearly shows that \[Defendant\] does not spend 30% parenting time with the Child and that \[Plaintiff\] is the one who pays for a majority of the child’s expenditures without contribution from \[Defendant\]. \[Defendant\] admitted that he only exercised 27 overnights with the child in 2019 even though the Custody Order that he fought for provides him with more custodial time. . . . He conceded that he cancelled his second week of custody time in summer of 2019, failed to exercise his time at Thanksgiving and exercised less time than what he was entitled to at Christmas. . . . Additionally, as of April 2020 he had not provided any notice to \[Plaintiff\] of his intentions to exercise 83 custody for summer 2020. Finally, Plaintiff suggests a recalculation of Defendant’s arrears in accordance 84 with the requested revisions. DISCUSSION Statement of law. In Pennsylvania, a support master’s “report and recommendation, although only advisory, is to be given the fullest consideration, particularly on the question of credibility of witnesses, because the master has the opportunity to observe and assess the behavior and demeanor of the parties. . . . However, it is advisory only, and the reviewing court is not bound by it and it does not come to the 85 court with any preponderate weight or authority which must be overcome.” As a general rule, “the support guidelines \[set forth in the Pennsylvania Rules of Civil Procedure\] determine the amount of support that a spouse or parent should pay based on the parties’ combined monthly net income, as defined in Pa.R.C.P. No. 1910.16-2, and the number of persons being supported.” Pa. R.C.P. 1910.16-1(a)(1). The purpose of the guidelines is to ensure that “persons similarly situated shall be treated similarly,” and they “place primary emphasis on the net incomes and earning capacities of the parties.” 23 Pa. C.S. 4322(a). To this end, “\[i\]f the trier-of-fact determines that a party has a duty to pay support, there is a rebuttable presumption that the guideline- calculated support amount is the correct support amount.” Pa. R.C.P. 1910.16-1(d). 83 Plaintiff’s Brief, at 6-7. 84 Plaintiff’s Brief, at 8. 85 Frey v. Frey, 1 Pa. D. & C.5th 116, 121, 2006 WL 5166597 (Monroe Co. 2006) (citations omitted); see also Goodman v. Goodman, 375 Pa. Super. 504, 507, 544 A.2d 1033, 1035 (1988); Wiser v. Wiser, No. 1076 Support 2009 (Cumberland Co. 2010). 11 However, (1) The presumption is rebutted if the trier-of-fact concludes in a written finding or states on the record that the guideline support amount is unjust or inappropriate. (2) The trier-of-fact shall consider the children’s and parties’ special needs and obligations, and apply the Pa.R.C.P. No. 1910.16-5 deviation factors, as appropriate. Id. With respect to deviations from the guidelines, Pennsylvania Rule of Civil Procedure 1910.16-5 provides as follows: (a) Deviation. If the amount of support deviates from the amount of support determined by the guidelines, the trier of fact shall specify, in writing or on the record, the guideline amount of support, and the reasons for, and findings of fact justifying the amount of the deviation. (b) Factors. In deciding whether to deviate from the amount of support determined by the guidelines, the trier of fact shall consider: (1) unusual needs and unusual fixed obligations; (2) other support obligations of the parties; (3) other income in the household; (4) ages of the children; (5) the relative assets and liabilities of the parties; (6) medical expenses not covered by insurance; (7) standard of living of the parties and their children; (8) in a spousal support or alimony pendente lite case, the duration of the marriage from the date of marriage to the date of final separation; and (9) other relevant and appropriate factors, including the best interests of the child 86 or children. Finally, “\[t\]he basic support schedule incorporates an assumption that the children spend 30% of the time with the obligor and that the obligor makes direct expenditures on their behalf during that time.” Pa. R.C.P. 1910.16-4, Explanatory Comment—2010. Variable expenditures, such as food and entertainment, that fluctuate based upon parenting time were adjusted in the schedule to build in the assumption of 30% parenting time. Upward deviation should be considered in cases in which the obligor has little or no contact with the children. However, an upward deviation may not be appropriate if an obligor has infrequent overnight contact with the child, but provides meals and entertainment during daytime contact. Fluctuating expenditures should be considered rather than the extent of overnight time. . . . 86 Pa. R.C.P. 1910.16-5. 12 Id. Application of law to facts. In the present case, after a careful review of the record, the court is of the view that the master’s assessment of Plaintiff’s net monthly earning capacity prior to the suspension of her employment was consistent with her work- tolerance level, as indicated by the factual recitation above, and that the inclusion of her income tax refund as a component of disposable income was correct, as also indicated by 87 the recitation. It further appears to the court that the suspension of Plaintiff’s employment in March of 2019 warranted an exclusion of childcare expenses from the support calculation as of that date. With respect to Plaintiff’s request for an upward deviation from the amount of support determined by the guidelines, it is clear that both parties can be described as valiant in their responses to harsh medical conditions, and Plaintiff’s conduct in raising an autistic child while suffering from a crippling illness and struggling to maintain employment seems little short of heroic. Given the fact that Defendant’s court-ordered entitlement to partial physical custody falls well below the 30% assumption upon which the guidelines are based, and that his practice has been to exercise even less than authorized, and that his household income is augmented by that of his wife, an upward deviation would appear to be within the intended ambit of the rules. However, as noted, the record has not been fully developed on this issue. For this reason, the case will be remanded to the master for further hearing and consideration of Plaintiff’s request for an upward deviation. ORDER OF COURT nd AND NOW, this 22day of June, 2021, upon consideration of Mother’s Exceptions to Support Master’s Report and Recommendation Filed May 18, 2020, which was filed June 8, 2020, and for the reasons stated in the accompanying opinion, the case is remanded to the Cumberland County Support Master for purposes of further hearing 87 See note 54 supra and accompanying text. 13 and consideration of Plaintiff’s request for an upward deviation from the support guidelines. BY THE COURT, _______________ Carrie E. Hyams, J. Jeff R. Lawrence, Esq. Cumberland County Support Master 13 North Hanover Street Carlisle, PA 17013 Debra R. Mehaffie, Esq. Suite 102 The Executive Offices at Rossmoyne 5000 Ritner Road Mechanicsburg, PA 17055 Attorney for Plaintiff Nathan C. Wolf, Esq. WOLF & WOLF 10 West High Street Carlisle, PA 17013 Attorney for Defendant 14