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Home My WebLink About96-04644 FRANK M. SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 90' l/(~ '/1 CIVIL TERM PATRICIA A. SNYDER, Defendant CIVIL ACTION - LAW ORDER OF COURT AND NOW, this ;>,1 day of /~, , 1996, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before " ,I .1),;1,;,1, /.,(I/i,1 the conciliator, at "", i 1)1 1 . ,';",11> "'/1.(. .'(;'1 .r,./);' 1'/; I' on the day of (\~ r"'d,f))i,.;. j-' , 1996, at if I,', J\ .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. Either party may bring the child who is the subject of this custody action to the conference, but the child/children'S attendance is not mandatory. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By: ,I r~ ;:).#. (~. custody conciliator 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 Courthouse Fourth Floor Carlisle, PA 17013 (717) 240-6200 roo _ F!I.:[} CTeo: . , ..,~' . .~-. ,.'.7~~"'T'"~\/ ~.:~ !\: .'~ .... . 'I:,: I J' '~'. ,..; " .. 1 ~ r: ;' .....U., Fi~,;',' ~':-rL\ " ," ."" I .j Iv :I',:'''.',~., /.n<~ ,~.(, IJp;,'~", /'l~' l/ 1l,~;I " -/~. " ~ _ v ,:~; '~':. : I'" _ "'t"-: ," '~{?, -..-0,' "foo, Y ,.),) , /! 7:':f.cc 1J'.Jt,/ ~ t'l ;6 );1';'( {'o/-i ;rr"Ji>t ,,: ~5,:...?IJ FRANK M. SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. CIVIL TERM PATRICIA A. SNYDER, Defendant CIVIL ACTION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR 4th FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717)-240-6200 FRANK M. SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. qC, J/(, "/~! CIVIL TERM PATRICIA A. SNYDER, Defendant CIVIL ACTION - LAW COMPLAINT FOR CUSTODY 1. The plaintiff is Frank M. Snyder, residing at 116A W. Vine Street, Shiremanstown, cumberland county, pennsylvania 17011. 2. The defendant is Patricia A. snyder, residing at 609B Geneva Drive, #35, Mechanicsburg, Cumberland county, Pennsylvania 17055. 3. Plaintiff seeks custody of the following children: Name Present Residence Age Robert Andrew Snyder 116A W. Vine Street Shiremanstown, PA 12 D.O.B. 6/5/84 The child was not born out of wedlock. The child is presently in the custody of Frank M. snyder, who resides at 116A W. Vine Street, Shiremanstown, PA. During the past five years the child has resided with the following persons and at the following addresses: Persons Address Dates Frank M. Snyder 5337 Oxford Circle 1990-95 Patricia A. Snyder Mechanicsburg, PA Frank M. snyder 116A W. Vine Street 7/31/95 - Patricia A. Snyder Shiremanstown, PA 6/27/96 Frank M. Snyder 116 W. vine Street 6/27/96 - Shiremanstown, PA Present The mother of the child is patricia A. snyder currently residing at 609B Geneva Drive, #35, Mechanicsburg, PA. She is married. The father of the child is Frank M. Snyder currently residing at 116A W. vine Street, Shiremanstown, PA. He is married. 4. The relationship of plaintiff to the child is that of father. The plaintiff currently resides with the following persons: Robert Andrew Snyder - the child in question Frank R. Snyder - eldest son of plaintiff 5. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons: Jeff Greene, Karen still, Michael Still and David still 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child is this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) Plaintiff is the father of the child and has played an intricate and intimate role in the raising of this child from the VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. ~'J / (F ----7 <), ("" .~ ~ .-' ./"1..-.,. :- /, .;7 :// Date: -7~5 /Pb' >-.. -..,c -.,.. '::t "- ro-. --.J e<; ;.. c- d:!. ~JC:' - ~ ........ (j J c.,' , -,,; ~ I :~ ., 0 ~ (i " , . ,J C1 '"j l0 u, ,) 'l" -, L..' (, ~ ~ (-. ':J " . ;'. ~ ::p 1_) I'.' .1 ~ ~ t.) U "V ,'1 ~ ..... ',' '. :;1 ,. U I' () .; c::-: ,. 9, c. '" L::.:' r: I v. ,. (~ ,: FRANK M. SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 96-4644 CIVIL TERM PATRICIA A. SNYDER, Defendant CIVIL ACTION - LAW AND NOW, this , J ,i I .', day ORDER of September, 1996, upon consideration of the attached Stipulation regarding custody of the minor child, Robert Andrew Snyder, born June 5, 1984, it is hereby ordered as follows: (al The parties shall share legal custody of the minor child; (b) Husband will have primary physical custody of the minor child; (cl Wife shall the following periods of partial custody: i. Wife will have the opportunity to visit with the minor child for three (3) hours each day Monday through Friday at the father's home. Wife will also be permitted on two occasions each week to remove the minor child from the marital residence for the purpose of taking him to a movie or restaurant or other location so long as the parties hereto agree to the place which Wife wants to take minor child; ii. Wife may have partial custody of the minor child for two (2) weekends per month provided that the minor child consents to the weekends selected by Wife with the weekend commencing on Friday at 4:00 p.m. and FRANK M. SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 96-4644 CIVIL TERM PATRICIA A. SNYDER, Defendant CIVIL ACTION - LAW STIPULATION AS TO CUSTODY OF MINOR CHILD The parties to this custody action hereby enter into this Stipulation with respect to custody of the minor child, Robert Andrew Snyder, born June 5, 1984. 1. The parties were married on May 30, 1981. 2. The minor child, Robert Andrew Snyder, was born as a result of this marriage on June 5, 1984. 3. The parties separated on or about June 27, 1996, when the wife left the marital residence with the husband and the minor child remaining in the marital residence. 4. On or about July 24, 1996 the parties entered into a comprehensive Marriage Settlement Agreement which included a clause concerning custody of the minor child. 5. The parties agree as follows with regard to custody of the minor child, Robert Andrew snyder: (a) The parties shall share legal custody of the minor child; (b) Husband will have primary physical custody of the minor child; (c) Wife shall the following periods of partial custody: i. Wife will have the opportunity to visit with the minor child for three (3) hours each day Monday through Friday at the father's home. Wife will also be permitted on two oc=asions each week to remove the minor child from the marital residence for the purpose of taking him to a movie or restaurant or other location so long as the parties hereto agree to the place which Wife wants to take minor child; ii. Wife may have partial custody of the minor child for two (2) weekends per month provided that the minor child consents to the weekends selected by Wife with the weekend commencing on Friday at 4:00 p.m. and ending on sundays at 8:00 a.m. In the event that minor child does not consent to spending the weekend with Wife, Wife agrees that that weekend visit will be forfeited; iii. with regard to holidays, the minor child will have input into determining with which parent he will spend the holiday. Reference to holidays includes only the major holidays which are Easter Sunday, Memorial Day, Independence Day, Labor Day, Thanksgiving and Christmas; iv. It is understood and agreed between the parties that wife will not be in the presence of other adult individuals, particularly Jeff Greene, during her periods of partial custody of the minor child unless the minor child agrees to that other adult individuals presence; and (d) Husband hereby agrees to advise Wife of all school activities so that Wife may participate in same. 6. The stipulations set forth in the preceding paragraph