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HomeMy WebLinkAbout00-01340 JUDY L. SNYDER, Petitioner v. : IN THE COURT OF COMMON PLEAS FOR : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00- / 3 yo CIVIL TERM CHARLES E. SNYDER, Respondent : CUSTODY ORDER OF COURT NOW, TY!drcJ, J ]<- ,2000, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: 1. MOTHER and FATHER shall share legal custody of their minor children, ALAN WAYNE SNYDER (DaB 11/30/86) and VALERIE RAE SNYDER (DaB 6/5/92), and pursuant to this grant of shared legal custody, each parent shall have equal access to all pertinent information and reports that may be generated by medical, educational, psychological and other professionals who may work with their child. Each parent shall discuss major decisions effecting the child's well being in the areas of medical, educational, emotional, spiritual, social, and material needs with the opposite parent. 2. MOTHER shall exercise primary residential custody of said minor children. 3, FATHER shall exercise partial custody as can be agreed by the parties. MOTHER shall not unreasonably withhold her consent to partial custody, as the purpose of this Agreement is to allow each party to maintain strong and meaningful relationships with the children, FATHER'S periods of partial custody shall be based on the convenience of the parties, the desire of the children and other appropriate considerations, 4, Time is of the essence regarding the FATHER'S pick-up and return of the children for periods of partial custody. The parties agree that if the children are not picked up within one hour of the set time, that period of partial custody is forfeited and the waiting parent and children are free to make other plans. 5. The parties shall notify each other in a timely fashion if it is necessary due to an emergency or unforeseen circumstance for him or her to be delayed at any of the times set out herein, It is intended, however, i..;.:.'- ":,I,,,",~~ -~- ,.._c""... .'.',',." ',." , .-, () ,~/~ l55-.s~~: ~:Z:~ ~~~;2 ~ -< '+, " ., '" a a --,.. ?:;; ;''J 'i? -,,:,",- --I ;':;,.'~';g ,'::--;8 ,(){~ :;::: ~!', ,~?i~ ,5;;! '0 ~ -, '"'--" - *' .:.r, 0') .:;J that time be of the essence, and that the parties as strictly as possible comply with the times set forth herein. This agreement will be modified in the event there is significant change to be made in these arrangements. 6, FATHER is to provide transportation to and from his periods of partial custody. 7. The parties agree that if a child is away overnight from the residence of the parent who is exercising custody or partial custody at that time, the other parent shall be advised as to an address and phone number where the child can be reached. Further, either parent may have reasonable telephone contact with the children when not in the calling parent's custody, 8. The parties will notifY and consult with the other party immediately in cases of medical emergencies that occur while the children are in their custody, 9. The parents agree to assure the children attend activities scheduled for the children during periods of partial custody, such as but no limited to school events, activities and outings, swimming and other such lessons, birthday and other parties to which the children are invited by their friends. 10. Such other exercises of partial custody may be scheduled hereafter as the parties may agree upon with due deference and respect to the child's interest, schedule and ultimate welfare. I L Neither party shall do anything 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 natural development of the children's love or respect for the other parent. By the Court, / 00 ~' 3'\ ~ ~{- cc: Richard 1. Webber, Jr., Attorney for Petitioner Charles E, Snyder, Respondent Pro se JUDY L. SNYDER, Petitioner : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 00- /3 t.j <.J CIVIL TERM CHARLES E. SNYDER, Respondent CUSTODY PETITION FOR ENTRY OF AGREEMENT AND NOW come the Petitioner, JUDY L SNYDER, by and through her attorney, Richard L Webber, Jr., and files this Petition pursuant to Pa,R.C.P. No. 1915,7, averring the following: L Petitioner is Judy L Snyder, who resides in Cumberland County, Pennsylvania, at 3 Central Street, Newville. 2. Respondent is Charles E, Snyder, who resides at 632 North Second Street, Wormleysburg, P A 17043. 3. The Petitioner and Respondent are natural parents of ALAN WAYNE SNYDER, born 11/30/86 and VALERIE RAE SNYDER, born 6/5/92. 4. On or about February 25, 2000, the parties entered into an Agreement regarding custody of the children. Said Agreement is attached hereto and incorporated by reference herein. 5. The best interest of the children would be served by the entry of an Order of Court reflecting the terms of the Agreement. WHEREFORE, Petitioner requests your Honorable Court to approve the attached Agreement and enter it as an Order of Court. Respectfully submitted, Date: S-).-Ol> N~'~44- Richard L Webber, Jr. Attorney for Petitioner 366 Green Spring Road P.O. Box 40 Newville, P A 17241-0040 (717) 776.6566 "" , -'_ ."" ""'" "".".-,,"C ""..':_,' ~,,~_,," '_ '_;" < C_~"__ ",,-_,' , ,- 1,"'-' " I verify that the statements made in this Petition are true and correct I understand that false statements herein are made subject to the penalties of 18 Pa.C,S.A. Section 4904 relating to unsworn falsification to authorities, Date: 3/.J-koo . ~~~~~ m, fER, itioner --' , me, r,":>'!1> .. .,- '-.-' .r'~''''-_-~-?0;~~'-'- ___d"',~_>'-" " -'_J, , , ., ,,_.j, ,.,. ~ -~--.",",,"-- " -_..~- , ,',- ., , " JUDY L. SNYDER, Petitioner IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA V. NO.OO- } 3'10 CIVIL TERM CHARLES E. SNYDER, Respondent CUSTODY ~H THIS STIPULATION AND AGREEMENT is made this J day of Pr--j,(,v'r 7 ' 2000, by and between JUDY L. SNYDER, the "PETITIONER," and CHARLES E. SNYDER, the "RESPONDENT." 1. PETITIONER is JUDY 1. SNYDER, of 3 Central Street, Newville, PA, hereinafter referred to as "MOTHER". 2. RESPONDENT is CHARLES E. SNYDER, of 632 North Second Street, W ormleysburg, P A 17043, hereinafterreferred to as "FATHER", 3, MOTHER and FATHER are the natural parents of ALAN WAYNE SNYDER, born 11/30/86, and VALERIE RAE SNYDER, born 6/5/92. 4. MOTHER and FATHER were married Apri114, 1984, at Newville, Cumberland County, Pennsylvania, and separated on or about January 28,1999. 5, With the exception of this action, neither party has participated as a party in other litigation concerning the custody of the child in this or any other court. 6. None of the parties has information of a custody proceeding concerning the children pending in a court within or outside this Commonwealth. 7. None of the parties knows of any 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, . .' \-,~ -',. "r. -'"- ':' ,,"Or_., ~,_"_, <. _." -10',,':0 ..,.,'" 7-, _,,_,~"_. ,<.._,~ - -~, ;' ~"- - ., -, < -,'. P..""'" F. _ _'__~_'" 8, During the past five (5) years, the children have resided with the following persons and at the following addresses: NAME ADDRESS DATE Judy L. Snyder 3 Central Street, Newville, P A 17241 1/28/99 to present Judy L. Snyder and Charles E. Snyder 3 Central Street, Newville, P A 17241 8/93 to 1/28/99 9.The parties have reached an agreement with respect to the custody of their minor children and desire to reduce and incorporate their agreement to an order of court. 10. The parties further agree that, in procuring this Agreement, there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. NOW, THEREFORE, the parties intend to be legally bound and waiving their right to be present when this Agreement and Order are presented and executed, hereby stipulate and agree that the Court may enter the following Order of Court in the above captioned case: ORDER OF COURT NOW, ,2000, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: 1. MOTHER and FATHER shall share legal custody of their minor children, ALAN WAYNE SNYDER (DaB 11/30/86) and V ALERlE RAE SNYDER (DaB 6/5/92), and pursuant to this grant of shared legal custody, each parent shall have equal access to all pertinent information and reports that may be generated by medical, educational, psychological and other professionals who may work with their child. Each parent shall discuss major decisions effecting the child's well being in the areas of medical, educational, emotional, spiritual, social, and material needs with the opposite parent , :^ _-r_~_,__,_.'",-.,:5;pm;_;~,_,"_,,,,:,_,, ,,___;-~__ ,,_?}',"..c ,- ,~~.,<_ .",,'J. "~- . , . ~ "~- ~ ,"'H ,~ f~', ,-'-__y ;~_r?--. 2. MOTHER shall exercise primary residential custody of said minor children. 3. FATHER shall exercise partial custody as can be agreed by the parties. MOTHER shall not unreasonably withhold her consent to partial custody, as the purpose of this Agreement is to allow each party to maintain strong and meaningful relationships with the children. FATHER'S periods of partial custody shall be based on the convenience of the parties, the desire of the children and other appropriate considerations. 4, Time is of the essence regarding the FATHER'S pick-up and return of the children for periods of partial custody. The parties agree that if the children are not picked up within one hour of the set time, that period of partial custody is forfeited and the waiting parent and children are free to make other plans. 5, The parties shall notify each other in a timely fashion if it is necessary due to an emergency or unforeseen circumstance for him or her to be delayed at any of the times set out herein. It is intended, however, that time be of the essence, and that the parties as strictly as possible comply with the times set forth herein. This agreement will be modified in the event there is significant change to be made in these arrangements. 6. FATHER is to provide transportation to and from his periods of partial custody. 7. The parties agree that if a child is away overnight from the residence of the parent who is exercising custody or partial custody at that time, the other parent shall be advised as to an address and phone number where the child can be reached. Further, either parent may have reasonable telephone contact with the children when not in the calling parent's custody. 8, The parties will notify and consult with the other party immediately in cases of medical emergencies that occur while the children are in their custody. 9. The parents agree to assure the children attend activities scheduled for the children during periods of partial custody, such as but no limited to school events, activities and outings, swimming and other such lessons, birthday and other parties to which the children are invited by their friends, 10. Such other exercises of partial custody may be scheduled hereafter as the parties may agree upon with due deference and respect to the child's interest, schedule and ultimate welfare. ",-- r,~o~ ~.'7''''c,,_ , - _ '. ~.<, 'r''''':'~ =< ," ,~ "; "n_ .",e _'~_ ~_ ,,_ :'-~ " "_/ __,,,d.,,>,. "1 11. Neither party shall do anything 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 natural development of the children's love or respect for the other parent. By the Court, 1. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, do execute this Stipulation and Agreement. Date: z/zsloo , , Date: ~d5I&COO ! , ,.-~ ". ,- ., .~ ,'_'_~i7.,'~"_"',_} '^, -<r--:::~ ',,,,"0 " '0; ,-~_,-" "'_,_,"', ,o,~,__,~",_,,, ___..._"",~j,':' ,e~_':-,,:,,! - ,,~ ,." ~'r_, -". "':,;,-,!+:-,,- ,t-., I verify that the statements made in this Stipulation are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Date: 62/a.6Iaax:> I ' ij :i , . Jj 11 11 :'\ I verify that the statements made in this Stipulation are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. i ! I ;1 Date: 2/25/00 , , c1ft (~""-dcrn 'j ;1 .1 -'I 1) .i I I . "', - ..---.", '''''-O:;.'F!'_'_ __,~, . .r' <." ._... _~__~_- .. ,_" ._, ..,.,,__._">. ~ ,., , "" ' ,-~ ,#""," ,.' - -' ~- - ... . . j 1 1 'j , I ~i ~! 'I I I i I I i .. JUDY L. SNYDER, Petitioner : IN THE COURT OF COMMON PLEAS FOR : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO.00-1340 CIVIL TERM CHARLES E. SNYDER, Respondent IN CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF CUMBERLAND Richard L, Webber, Jr., being duly sworn according to law, deposes and says that he mailed the Order of Court in this matter by certified mail, return receipt requested, addressee only, to the Defendand, Charles E. Snyder, of 632 North Second Street, Wormleysburg, P A 17043 on March 17, 2000, The return receipt signed by the Respondent is evidence of delivery to him and is attached hereto as Exhibit "A". ~/L.~~ Richard 1. Webber, Jr. Attorney for Petitioner 366 Green Spring Road P,O. Box 40 Newville, PA 17241 (717) 776.6566 Sworn to and subscribed before me this ;l f"i' day of m~ ,2000, ~r::. /;( };JJV-I N ary Public NOTARIAL SEAL lERRYE. WAlKER, NOTARY PUBUC NORTH NEWTON TWP., CUMBERLAND co. MY COMMISSION EXPIRES MARCH 31 2003 . ,,-~ '-'_"'[",.1" . '- ", """-."3'- _<,',~ ",~"_,f"'_" "'<',_,' ,- ,-9_' - . .,,'- - - ~ I " . JUDY L. SNYDER, Petitioner IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA V. NO.00-1340 CIVIL TERM CHARLES E. SNYDER, Respondent IN CUSTODY "ComPi~t;;ite;;;-~'t~z;'ai1dY'Af~j);';;;;;;;lete' .. item-A if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . . Attach this card to the back of the mail piece, or on the front if space penn its. 1. Article Addressed to: D. Is delivery address different from Item 1? If YES, enter delivery address below: " 0 Agent o Addressee DYes o No x Mr. Charles E. Snyder 632 North Second Street wonnleysbur9, FA 1 7043 \ 3. ServIce Type X;XCertified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) XXVes 2. ~iqle:;Nvmp~r- (C;:dpy. fro."! ~ervi~- fabeQ . : : ;';::; ,I,,,jl ';'1~_J:. )~. i.,l~; -'{~i;~;k Ll i>\3\Fbrn\ 3a'ftq~I~\jlg~?}}:': .,11 i,,:2! 328oi173 H6 . fUlj iii' ; . Dome$tlc fltettlm ~ . -.", ; f;,.;"'- 10259S-99-M-1789' _.. ~'"~"'_~""r~"'''''';'''_",","",,''''',:.;.' Exhibit "A" t, "",I '-0/ ~,. ,",,_,. _. _'_~'/"'_'"~_,.__,'__~i ". __n., =_ _, '_..0 --~. ,.. 1_'