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HomeMy WebLinkAbout00-02418 ",' ~---- - - ,- "~-., IFP J3S: O() PUt' Cou f1 -Iy . . " - ~' , ,~- ,', "-'. '" ... ",,0" . . .. . ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . STATE OF . . . . . BILLY J. SNIDER . ~l;lint-;Tf . VERSUS . ~T~H~Rn ~ ~~IDER, JR., Defenn"nt . . . AND NOW, . . DECREED THAT Ri lly ,T ~nioer , PLAINTIFF, . PENNA. No.. 00-2418 CIVTT, DECREE IN DIVORCE ~?Hl 7_b , z.oo I , IT IS ORDERED AND AND Richard R. Snider, Jr. , DEFENDANT, . . ARE DIVORCED FROM THE BONDS OF MATRIMONY, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . Nnnp . . . . . . . AT E . T(!~~ P"OTHONOTA": ! . . '" ;f. 'f. ff. ff.:Ii '" ,Inli '" '" '" '" Of. ',.,."" "'''~' ~ . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '; ,=, ".,. ~_d .'__'" __ "< -- -, - .-, ~ , -~ ~--<~"~<'-- -~,~ h' \; , ' , '> '11' . Jd7~t' W~~~~ R~ J;S/;';/ 71~ ~ ~~ a:?f ,{}~ - .~"'~ ,p, e- P_'-~"'" ~-~, ~ .~,~~~"._, ~i ~, ,,,.,,~._ ~J1l!IIIIl!lI!l!R""~. ~:" ~I ,~. ' . ~...-'",- , BILLY J. SNIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, No. 00-2418 Civil Term RICHARD R. SNIDER, JR., Defendant CIVIL ACTION LAW DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1.. Grounds for divorce: irretrievable breakdown under S 3301(c) ofthe Divorce Code. 2.. Date and manner of service of the Complaint: Certified mail April 26, 2000, 3. Date of execution of the affidavit of consent required by S 330l(c) of The Divorce Code: by the P1aintiffMarch 12, 3001; by the Defendant February 18, 2001. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in S330l(c) Divorce was filed with the Prothonotary: March 16, 2001.. Date Defendant's Waiver of Notice in S330l(c) Divorce was filed with the Prothonotary: March 16, 2001.. Date: March 16,2001 ----/ ~/ ;---' --- Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court ID No.. 81924 ~~U~~liIiijW~'~"~-~-~~~""" <~ ......iiIIiI'll..1i:-K.~~ "",.. 8 0 0 - ~n s: - -.-\ ~ ~~:D -0 OJ :0- rnfT' ::0 .1,(,,_ Z:YJ ~g9 ZC~ 0' 9Z ::2: 9c,_ N-"-:"ll ,<0 -0 ",'--rl '?2:0 Z ~2B "'-:..rn ;p:g ~ S ~ - ~ - "< o ~ - ~ ,i ';Z '-' ';Zt;-o ?Q'/-C::' l:2' he) ~~ -, -~\ - (,;) "_' co, _,~__ ~"_ '.c_ '-','" ~, _~,".'__'''' . ~;",' 'I- -~,_~__""'~_ ~- ,,-- ~, v. " -~ - ,"" ~--". - -' _ ,"__~ '___ " ,r,,- ".~^__ ,"". _ . ,r "",,_I; . ~ ~ ~ - " " , ~ " \ APR 1 8 2~ :t " Billy J. Snider, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN CUSTODY v. Richard R. Snider, Jr., Defendant : NO, 00-.;)418 CIVIL TERM ORDER OF COURT AND NOW, this/; fJay of Ap. 1 ,2000, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before, tit-I:. X. f/~ &1 , the conciliator, at t-h- tjt4;t, Cumberland County Courthouse, on the I5t1ciay of ~n<.... ,2000, at 'O:~., for a Pre-Hearing Custody Conference, At such conference, an effort will be made to resolve the issues in displlte; 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 children who is the subject of this custody action to the conference, but the 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 d/..-l X (/JJ., I ~1 Custody Concilia or r.F J 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 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. .. } ., , '. ,,", "I ~- "'J ~Dr:> 'L' '....', ~~l L {,.) {Iii If}: St.:. CUiVj,:::-i--F:, ~J.:, -~ . "1--' I- rl'" :::1':::.- ,,-' ': it."' 'J,-...!I,-,i\.~ ( r'cNNSYLv/\N!;\ 1f",}S:CV u- t'6f)'2//U~ ~ ~X l/-;lS--0cJ 7l~ ~ ~ dff- ~06-t'~ c~ ~ ~ -II-~;rU. _ 'IiJI'1I'lI!-",_, "~ _ _"",'.". '_.'~ ~,Rl'IlIl!, i~~~<l!1!~i.WiI~FlfJWfIQ(i;>i"nm~rrn!f!lllliWW;1!jf,!)l~~~~~ '. 'Jiklllllllu ~J!!i!lilr.li:LiiY"O, ,\ Billy J. Snider, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : IN DIVORCE Richard R. Snider, Jr., Defendant : NO, 00- dL+\ '6 CIVIL TERM NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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, Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 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. _h ',^ - ,-, ,- ~'~ ' '" ~ , ~-. \ Billy J. Snider, Plaintiff , IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : DIVORCE, CUSTODY Richard R. Snider, Jr., Defendant : NO. 00- dl\\8 CIVIL TERM COMPLAINT FOR DIVORCE AND CUSTODY The plaintiff, Billy l Snider, by her attorneys, the Family Law Clinic, sets forth the following cause of action: COUNT!. DIVORCE UNDER 23 Pa,C.S, SECTION 330l(c).. 3301 (d) AND 330!(a)(6) OF THE DIVORCE CODE I. Plaintiff is Billy J. Snider, who currently resides at 127 Long Road Apt. I, Newville, Pennsylvania 1724 L 2, Defendant is Richard R. Snider, Jr., who currently resides at 7073 Carlisle Pike Lot 49, Carlisle, Pennsylvania 17013. 3, Plaintiff and defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and defendant were married on May 19, 1995 in Maryland. 5, Plaintiff and defendant have lived separate and apart since March 10, 2000, 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff avers that defendant, in violation of his marriage vows under the laws of the COInnlonwealth of Pennsylvania, has offered such indignities to the person of the plaintiff, his ".,< . injured and innocent spouse, as to render the condition of the plaintiff intolerable, and her life burdensome. 9. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, plaintiff requests the Court to enter a decree in divorce dissolving the marriage. COUNT II. CUSTODY 10. Plaintiff repeats and realleges previous paragraphs of this complaint. 11, Plaintiff seeks custody of the following children: Name Present Address Age Kyle A. Snider 127 Long Road Apt. I, Newville, PA 6/17/95 Rebecca M. Snider 127 Long Road Apt. I, Newville, PA 11/23/99 The children are presently in the custody of Billy J. Snider, who resides at 127 Long Road Apt. 1, Newville, Pennsylvania. During the past five years, the children have resided with the following persons and at the following addresses: Persons Addresses Dates Billy J. Snider Sam Bubb Judy Bubb 127 Long Road Apt. 1, Newville, PA 3/10/00 - present Billy J. Snider & Richard R. Snider, Jr.. 7073 Carlisle Pike Lot 49, Carlisle, P A 6/17/95 - 3/10/00 ~ ~ .- .-<~ '.i . The mother of the children is Billy J, Snider, currently residing at 127 Long Road Apt 1, Newville, Pennsylvania. She is currently married to the defendant The father of the children is Richard R. Snider, Jr., currently residing at 7073 Carlisle Pike Lot 49, Carlisle, Pennsylvania. He is currently married to the plaintiff. 12, The relationship of the plaintiff to the children is that of mother. The plaintiff currently resides with the following persons: Name Relationship Sam Bubb father Judy Bubb mother Kyle A. Snider son Rebecca M, Snider daughter 13. The relationship of defendant to the children is that offather. The defendant currently does not reside with any persons. 14. The 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 Conunonwealth. 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. 15, The best interest and permanent welfare of the children will be served by granting the relief requested because: a) Plaintiff has been primary caretaker of the children since birth; -~ , . b) Plaintiff provides the children with a home with adequate moral, emotional and physical surroundings as required to meet the children's needs; c) Plaintiff is willing to accept custody of the children; d) Plaintiff continues to exercise parental duties and enjoys the love and affection of the children; e) Defendant has not indicated to plaintiff an interest in accepting custody of the children. 16. 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 requests the Court to grant her custody of the children. Date 1//l! ")101 ~(lf~ Stacy A. arker Certified Legal Intern An; h, C{--, THO S M. PLACE ROBERT E. RAINS Supervising Attorney DONALD MARRITZ Staff Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717/243-2968 ,;.-. - - ~- ' -, ;., -<' . - ;, '---;-"'---<JI .. , . VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa,C.S, g4904, relating to unsworn falsification to authorities, D", .~ 1~Iti_liViGl~;~'= ,,""""'"-"""" ~ ~ ~~~I~ooIer- ~~ ...d!i&l~..llff8.1U .,.,,,,, j , ~ ~'"'" IIil;ii "~~ t ~ C) ~:;, <" ""Dr,- rneT Z:;.,1 ~;;~ -'.. '--: r<'~~ ~2; PC 7. =< '::;J 'c.;) '.-::J -::!j .......] j ~~4 ~.-rJ ......,.. Cf? ,'V (...> ~l -,...... ~.'.1 ::< '~ , ,.-^- " m,j ~.. APR 1 8 2~ Billy J. Snider, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW Richard R. Snider, Jr., Defendant NO, 00- d.q\~ CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Bil1y 1. Snider, Plaintiff, to proceed in forma pauperis. I, Stacy Barker, Certified Legal Intern in the Family Law Clinic, for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party, The party's affidavit showing inability to pay the costs of litigation is attached hereto. ~~ Stacy A. Barker Certified ~al Intern ()~rv,~ ROBERT E. RAINS THOMAS M. PLACE Supervising Attorney DONALD MARRITZ Staff Attorney THE F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PAl 70 13 (717) 243-2968 " ~ "' , ~" . ,.. .~. - - ,~- --~ :-, - - J - Billy 1. Snider, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW Richard R. Snider, Jr., Defendant : NO. 00- aq\'i? CIVIL TERM AFFIDAVIT SUPPORTING PRAECIPE FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1, I am the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding, 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation, 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct (a) Name: Billy 1. Snider Address: 127 Long Road Apt I, Newville, PA 17241 Social Security No.: 176-56-1398 (b) Employment If you are presently employed, state Employer: Address: Salary or wages per month: Type of work: If you are presently unemployed, state Date of last employment: 11/22/99 Salary or wages per month: $750/hour Type of work: billing clerk (c) Other income within the past twelve months Business or profession: $0 Other self-employment: $0 Interest: $0 Dividends: $0 Pension and annuities: $0 Social security benefits: $0 '_~ '_~ -0 . ~j . , ~" Support payments: $0 Disability payments: $0 Unemployment compensation and supplemental benefits: $0 Workman's compensation: $0 Public Assistance: applied Other: $0 (d) Other contributions to household support Husband Name: Richard Snider If your husband is employed, state Employer: Rollins Truck Rental Salary or wages per month: $12.25/hour Type of work: diesel mechanic Other contributions: $0 (e) Property owned Cash: $0 Checking account: $0 Savings account: $0 Certificates of deposit: $0 Real estate (including home): $0 Stocks; bonds: $0 Other: $0 (f) Debts and obligations Mortgage: $0 Rent: $0 Loans: $0 Other: $0 (g) Persons dependent upon you for support Children, if any: Name: Age: Kyle A. Snider 4 years Rebecca M. Snider 4 months 4. I understand that I have a continuing obligation to inform the court of improvement in my fmancial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct I understand that false statements herein are made subject to the penalties of 18 Pa.C.S, 9 4904, relating to unsworn falsification to authorities. . D,,, 4111 J (5D ',,_ r, . . ,'-,', , ~.~... ~ --,,~_L'~"lbiiIiiI!I_d~~ " ~~'If'-&i:l, ..~~..- -"-JilQ. ~ ~ - ~ . 0 (--' '" c: C::J " <' '"' -;:J ::-;r-' i:J rr; C; , ::"J 2; <- ::_~) (n .-J -<' :~ ~- r:;' (-J -j :?; 0,._' C ~', ' , Z -.->~ .. t---, P '---' [...) c.: i~j ~:- ," =< :0 <-.) -< .. --, ,-. , -~ _ ~__" 0' , BILLY J.. SNIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RICHARD R.. SNIDER, JR., Defendant NO. 00-2418 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1.. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on April 24, 2000. 2.. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a fmal decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C.S. S 4904, relating to unsworn falsification to authorities.. Date: '3/12 j a \ , ~.....~._- ,," .....:.....,-'~ ~ ,~" <. .~. -- I. _". ,-,,0 ,-- ._ o'~ . ~. , <I,' ("') 0 ri? ~ - -o~ :::;e ::;j !pfB "'" "<J "1.=D :Z:c ,:i~r; OJ....':> 0> =<2 I ~c ""1:J ~~~? ~: :J:>:() ~- ..... c.J---4 5€o --:.-C) ~ ~ ODl - ~ ~ ::n c -< ,. "-^ ,;--,.'; i. ,~,""d', -'__ ' w-- - .' ~_'!,",.cl,_. _0;,_ 'L"~ :'~~-__' ",,' -;;.- _!-,__ <.."d,O BILLY J.. SNIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RICHARD R. SNIDER, JR., Defendant NO. 00-2418 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT L A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on April 24, 2000, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree.. I verify that the statements made in this Affidavit 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. Date: ~ ~-/8-oJ IIliIir- ~~' ,,," ,"". , ~ -,~',"" ~"~- , ,~-~-, -~ -~ ~; 0 0 0 C " $: :x ,) iJ] :I::~ ~;~ n1rn AI Z::1:1 ZS:: 0" C,~y (1),,--::: ~"- ~_-..-_jO _0 "". Me =R "'- ~o :x ~'.....,- :'"70 --0 ""'-rn Pc 0 -~ z: ~ :::! 0 -< - --"~ "--. ~" .. ,~"" -"0'_" ~ :. BILLY J. SNIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RICHARD R. SNIDER, JR., Defendant NO. 00-2418 IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. 2.. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C..S. g4904, relating to unsworn falsification to authorities. Date:1\D\ lllilllriii ~-'Iio.o,;-' -, ".''':' "~' ;-,.;.;,.""~ ."-", K'_i ~- (") <:) 0 C -n ;;: .- -"" -0&3 ".,. ;:-'::;;~~ rnfT! ::::0 Z::D '~3~ m~: 0" -=<.-c.:" _,,0 ,<0 "" ::(=+4 ~o :-1: (.Y'o Zrr. -0 ~ O. )>c ~ Z - ~ ::<! <:> -< ~ -~ M ,_, __, _ -,; ~_- C._, .-_'"'_' "' _~ _ -. _" N'_'A.' ." ,_ ~" - V, _'.; ,n _~___",,_",,;,__,,_<_, -';' BILLY J. SNIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RICHARD R. SNIDER, JR., Defendant NO. 00-2418 IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1.. I consent to the entry of a final decree of divorce without notice.. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C..S. 94904, relating to unsworn falsification to authorities. Date: ;)-J)t,o/ ~r?~ Richard R. Snide ., Defend ..~... ....;~~ --- WiIIIIlliiMililllw . ~ ,- " ~, .', ->~-"r. 8 0 0 ,., s:: ::ii: -< '1Jro :r;,. Ffi"';J;! 'PIT! "" :3::1 -l1DJ 2::C CD"",; 0'\ ~U''-rl () - ~C5 -_.,C) ::<;.. J';~~ );>0 ::JJ:: ~;;;:c3 ~8 - Om - 2:: ~ -< 0 -< < ",'. --. - . '- --~,--'- - --,-,,;" -.'-': ',,~,-", N , . .' ~ L~~, _ . "'--1 Billy J, Snider, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE Richard R. Snider, Jr., Defendant : NO. 00-2418 CIVIL TERM VERIFICATION OF SERVICE Understanding that the making of any false statement would subject me to the penalties of 18 Pa. C.S. !l4904 (relating to unsworn falsification to authorities), the undersigned verifies that Stacy Barker mailed a true copy of Complaint for Divorce, In Forma Pauperis Petition, and the Affidavit Supporting the In Forma Pauperis Petition on the Defendant by placing the same in the U.S. Mail, certified nO.L.3.3~ 7(0.) wl.f, restricted delivery, return receipt requested, postage prepaid, on the 24th day of April, 2000 addressed as follows: Richard R. Snider, Jr. 7073 Carlisle Pike Lot 49 Carlisle, PA 17013 Sender's receipt no. Z b'b~ 7 (OS- c,.oy is attached hereto and incorporated by reference. On the cn+h day of .---8.or'/) - , ,2000, green return receipt no. Z~7~S-c.o~was delivered to the Family Law Clinic, bearing the signature Ri c~Cl..ro.. !(. Snlc\er;s1and showing a date of service of 1/0?0 (00.. The return receipt is attached hereto and incorporated by reference. --Jxa~~JL(); f-l Certified Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, P A 17013 717-243-2968 Dated: /f/Qg!ro liIIliIiii 'J(~~ ~ ~. "~ -"-~'--'~-~./ ~- ":"':"'lfJ!lI "c,_ ,~.;. . . " C) f~' ~p g~--'-'~ c- j>~. '.::~ l : ~;=c:} ..-' f~'" -, t,e ,--. .. ...:; u ;_~i -r! T:?1" '"I ::-,J t,,) CD ~~n t~,) '" "J - " -, . .' Z 338 765 6Dli US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mail See reverse to Restricted Den~~.E~ ~ Return Re98iPt Sh _ Whom &,Date vera .5.-RetumR,Sceipt .ng-to <( Dale,& 's Q Q TOTA ~ Postm Ii' If ~ 'Ii "- . Complete items 1, 2, and 3. Aiso corli~ ~te item 4 ifJlestricted 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 mailpiece, ;' or on the front if space permits. 1. Article Addressed to: "B.\~rd R .5r\la{;f Jr. l Dl~ Lox\\,,::>\e. 'VI 'ilL l;y\-df49 U~f\\~\t, 171+ \ID\~ 3. Service Type ~rtified Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise DC.O,D, 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number (Copy from service label) PS Form 3811 , July 1999 Domestic Return ReceIpt 102595-99.M-1789 !f!ltMIll~~~~'" ~=~ ~,,~ ~,", ,.".;1,-" ",'~ , - ~- ~- ,,-' N ., / . .~ - F? 7)~~ r'lr"", Z::-;' 0S~~ e:~1 ~;:~ S:c, i;f2 -=-'j -<.' '" . ~ ".........'" .- ., - ,"",J o :;:::,. -'::'"1 o 'Tl ~ ~._'. ~",-, N G,) i__ -r; .;i~ 8f~ :~~~ 0?J -, i"'-.J \,.0 " '7~ _, L _,', ., ,,. .'''' ~-"" "o~.". "" .." ",">>"" _ ",~". "" :U ~ BILLY 1. SNIDER, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, No. 00-2418 Civil Term RICHARD R SNIDER, JR., Petitioner CIVIL ACTION LAW DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE To the Prothonotary: Please enter my appearance on behalf of the Respondent, Billy 1. Snider, in the above captioned case. Respectfully submitted, 22 ,,~ Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ill # 81924 Attorney for Billy 1. Snider Dated: C;Vj (? Z OcN "~ -ole "~ _ . =" ~,_~>c, ,. . ~ '.' ;,- .''-kti ,,," '. ~ BILLY J. SNIDER, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No, 00-2418 Civil Term RICHARD R SNIDER, JR., Petitioner CIVIL ACTION LAW DIVORCE CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Billy 1. Snider, do hereby certify that I this day served a copy of the Praecipe for Entry of Appearance upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Peunsylvania, addressed as follows: Daniel F. Wolfson, Esquire Wolfson & Associates, P.C. 267 East Market Street York, PA 17403 C-/ ---- Karl E. Rominger, Esquire Attorney for Dated: ft J; f7(' L,.co '~i ..."; ~ -'~"'I .~,'" AUG 2 2 ?rn~ I 1\]11 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BILLY J. SNIDER, No. 00-2418 Civil Term Respondent/Plaintiff vs. CIVIL ACTION - LAW RICHARD R. SNIDER, JR., Petitioner/Defendant DIVORCE ACTION RULE AND NOW, this ~day of _f\ u '()",.sf ' 2000, upon consideration of the within Petition for Special Relief, a hearing shall be scheduled for the 'l ~day of ~~, 2000, at Y:t.{S- ~/p.m., in Court Room Number '2 of the Cumberland County Court House. BY THE COURT: I ( ~ 77~(o~ M./ H ,~ . r't ~. ' :'- -Il!!l '., . <--< ~' '- ~ ,-^ ~ .~ C" .. r~'\ rf\..-./,',!-':r\('F ;-iLt:L.i -,-,I I,.;,J j~"t-rfoR" 1'-- :'~~,'~\T!..I; !"'.~ 1\1\ 'i .... :-,','1: ,,,,Jl"_ "D r,,1(' 2 '" ~J t\t)\, .--: 0',.\ L. 1 h ,i. i..\. v , " ,",' ,'.r' ('I"'U"I'rrv (':1 1\/1\";;\ "hU-"J\~U uU \II i vU" ~",' ' NI^ PENt,ISY0,fAi ,r, "I,. ~_~"""",,~1i\!!I~111!1.~I'_I'~Nfi.tlIi.UMlI!!!I"f<l'lI~lIIJ~IIIij!Wl~~_~!'I'-'''l,~i''''''''~illFl;"-$'fh"'N;Wi"~,~~I:;H:g,",'llf'":'W~!I~[\$!!:"ii5\~lf,""~~!ijI[!~ ~ ... . "~~-",,,,,,,' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BILLY J. SNIDER, No. 00-2418 Civil Term II II Respondent/Plaintiff vs. CIVIL ACTION - LAW RICHARD R. SNIDER, JR., Petitioner/Defendant DIVORCE ACTION ORDER AND NOW, TO WIT, this _ day of , 2000, upon consideration of the Defendant's Petition for Special Relief, it is ORDERED and DIRECTED that: a. Immediate visitation of the Petitioner with the children commence pursuant to the schedule which has been consistently followed by the parties of alternating weekends and Wednesdays and Thursdays, pending the outcome of the Conciliation Conference scheduled for Thursday, September 28,2000; b. The Cumberland County Sheriff's Office and/or local/state police are permitted to aid in the enforcement of the visitation, if necessary; and c. Respondent/Plaintiff shall reimburse Petitioner/Defendant for reasonable attorneys fees and costs incurred in pursuit of this Petition in the amount of $350.00. BY THE COURT: J. II " . _I. ~-'-~-"":frl't~~'-tAt.;w,"'r"'- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BILLY J. SNIDER, No. 00-2418 Civil Term Respondent/Plaintiff vs. CIVIL ACTION - LAW RICHARD R. SNIDER, JR., Petitioner/Defendant DIVORCE ACTION PETITION FOR EMERGENCY RELIEF AND NOW, this 16th day of August, 2000, comes the Defendant, Richard R. Snider, Jr., by and through his attorney, Daniel F. Wolfson, Esquire, and the law firm of Wolfson & Associates, P.c., and files the following Petition for Emergency Relief of which the following is a statement: 1. The Petitioner, Richard R. Snider, Jr., is an adult individual currently residing at 7073 Carlisle Pike, Lot #49, Carlisle, Cumberland County, Pennsylvania 17103. The Petitioner is the Defendant to the above captioned action. 2. The Respondent, Billy Jo Snider, is an adult individual currently residing at 127 Long Road, Newville, Cumberland County, Pennsylvania 17241. The Respondent is the Plaintiff to the above captioned action. 3. The Petitioner and Respondent were married on or about May 19, 1995 in Maryland. Ii 4. The Petitioner and Respondent were separated on or about March 10, 2000. II ~"&:...tii<t_I4,o!i.a,",,,_~~.,I- "L ~"~~H!lj"fuJ.!i;'",,!': " ..' 5. On or about April 17,2000, the Respondent filed a Complaint in Divorce in the Court of Common Pleas of Cumberland County at the above docket no. 00-2418- Civil Term. 6. As a result of this marriage, two (2) children were born, namely: Kyle Andrew Snider, born June 17, 1995; and Rebecca Mae Snider, born November 23, 1999. 7. Since the date of separation, the parties have agreed to a visitation schedule which has been consistently followed by both parties for a period of three (3) months. 8. The said visitation schedule permitted the father visitation with the children on every other weekend, as well as weekdays during the week that were agreeable with both parties. 9. It was a regular routine during the above three (3) month period that the Petitioner would have the parties' son, Kyle, on Wednesdays and Thursday. On some occasions the Petitioner would have the parties' son, Kyle, on even more days during the week. 10. Initially, upon the parties' separation, the Petitioner did not have visitation with the parties' daughter, Rebecca. However, after discussion between the parties, the Respondent agreed to permit visitation of the parties' daughter, Rebecca, with the Petitioner. Said visitation has been consistent for a period of two (2) months after separation. 1 1. There has never been any physical or emotional abuse to the parties' children and Children & Youth Services has never been contacted or notified by either party or any agency. 2 II , "~"= 'f ~n 12. The Petitioner has a close and loving relationship with the children and speaks to the parties' son, Kyle, by telephone three (3) times per week on the days that he does not visit with him. 13. The Petitioner and Respondent sought to work out a visitation schedule. Although the details of this visitation schedule were not finalized, it was a defacto schedule between the parties and they consistently adhered to alternate weekends and numerous days during the week for the Petitioner to visit with the children. 14. Due to issues of visitation and custody, a Conciliation Conference has been scheduled for September 28,2000, where an Order of Court could be finalized between the parties. 15. On or about August 11, 2000, counsel for the Respondent indicated that after speaking with his client, he advised his client to suspend all visitation and all phone contact of the children with the Petitioner until September 28, 2000. He indicated that this was done because his client indicated that there were two (2) incidents in the past that made counsel for the Respondent believe that the Petitioner was unstable. 16. One of the incidents involved the Petitioner tying up the Respondent in the basement in 1996. 1 7. The Petitioner avers that above incident was a mutual arrangement, whereby i I both parties were jokingly having fun with each other. " 18. In regard to the above incident, the Respondent never called the police, never notified any public or private agency of any concerns, and the incident passed without any notice for four (4) years until counsel for the Respondent deemed it significant. 3 II . -"'!I,;,--''_ 19. The other incident occurred on or about September of 1996, whereby the Petitioner pointed a gun at the Respondent while she was holding the parties' minor son, Kyle. 20. The Petitioner avers that this incident occurred upon the Petitioner learning of the Respondent having an extra-marital relationship with another man. 21. Shortly after the incident involving the gun, the Petitioner and Respondent went on a two (2) day vacation to the beach, resolved their difficulties, and lived a husband and wife for the next 3 Y2 years. 22. It is alleged and therefore averred that the above incidents, although not commendable, do not, in any way, reflect on the stability or instability of the Petitioner in his ability to care for his children. 23. The Respondent has repeatedly permitted visitation with the children and there have been no incidents of any nature that would indicate that the children are not happy and content to be with their father. 24. Since the Petitioner has requested custody of the children in a custody proceeding, this is a tactic by Respondent and her counsel to gain advantage in a potential custody action. 25. If the Petitioner is not able to visit with his children until the Conciliation Conference, there will not be a Court Order until October 1, 2000, which will preclude the Petitioner from visiting with his children for a period in excess of 1 0 weeks, even though he has had an extremely close relationship with his children. 4 il , . >~ ji,-" ~3:"':i 26. Said unilateral termination of visitation of the Petitioner with the children would be detrimental to the parent/child relationship. WHEREFORE, the Petitioner respectfully requests this Honorable Court grant this Petition and order the following relief: a. Order and Direct immediate visitation of the Petitioner with the children pursuant to the schedule which has been consistently followed by the parties of alternating weekends and Wednesdays and Thursdays, pending the outcome of the Conciliation Conference scheduled for Thursday, September 28,2000; b. Order and Direct the Cumberland County Sheriff's Office and/or local/state police to aid in the enforcement of the visitation, if necessary; c. Order and Direct Respondent/Plaintiff to reimburse Petitioner/Defendant for reasonable attorneys fees and costs incurred in pursuit of this Petition in the amount of $350.00; and d. Such other relief as the Court deems necessary and appropriate. Respectfully submitted, ~:;,;;.,~'" WOLFSON & ASSOCIATES, P.c. 267 East Market Street York, PA 17403 (717) 846-1252 ID No. 20617 Attorney for Petitioner/Defendant 5 il , . ~~". illfifii~:"IiJ~d!;;1<. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BILLY J. SNIDER, Respondent/Plaintiff vs. RICHARD R. SNIDER, JR., Petitioner/Defendant No. 00-2418 Civil Term CIVIL ACTION - LAW DIVORCE ACTION CERTIFICATE OF SERVICE AND NOW, this 16th day of August, 2000, I, Daniel F. Wolfson, Esquire, do hereby certify that I have served a copy of the foregoing Petition for Emergency Relief upon the parties and/or counsel of record by regular mail, postage pre-paid and addressed as follows: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (VIA - FAX (717) 241-6878 and REGULAR MAIL, POSTAGE PRE-PAID) (Counsel for Plaintiff) II !I Ii Respectfully submitted, ~~~~ Daniel F. Wolfso Ire WOLFSON & ASSOCIATES, P.c.. 267 East Market Street York, PA 17403 (717) 846-1252 ID No. 20617 Attorney for Defendant 1.~E<i~I'<N:"""lb"""~",~I~l;o-""I',~_C.~>l~__'h,.""",",,,,"-"~,'e"'''''~l!,jU"':';'''W'':illlll,ri-1liI;I!l_I~..d~' ,,~- "li iiIl.'!lalli!liIlfi'iililliOOjDi~~~;!MMi'i~~~Jjlj...til!llllllllilWlir"''''''- () C ? -OED n1nl Z:.x:i 65$: r>' <:0 Po ~O ~ " . L~. ^ ,~,_ I - "millJJJllW[- IlI_M . .' <:::> a "'" G=; 1'..> o '"n t~f~: J4~ -=::;;.(") ?~~m :-::1 1> 5J -< ;0 -\~ -,'.. i3 .;;:- ~ 5 (\)) t>6R- vs. ::.-;-- ~N\O~ OO-z....L1I~ (l'vil.- B~rt~\l) \ is 1(0 ~ ~\j:I "_". L'u ~ ',,- ,'-A .-..."-.~. ,-- '""c. ., do. _~~ 0'- '", ---" ~O#U7~ ()().J4 J~ (I Yaw f?!J)#c O ~ ~ llir ~ 'VI :F~ r;:\ c,~_._,~:::_l!..._---"c:cl i Ii! AUG 11 2000 i!!! ,ll If "'-j I L. 155 South Honover Street 0 Carlisle. Pennsylvania 17013 Charribersburg, Pennsylvania 17201 717.241.6070 . 888.241.9679 . Fax: 717.241.6878 law@rorrilnge~aw.com . wviw.romingerlaw.com Please reply to Carlisle office. August 10, 2000 Via: FAX No, 848-1146 Daniel F. Wolfson, Esq, Wolfson & Associates, P,C. 267 East Market Street York, PA 17403 Re: Billy J Snider v, Richard R Snider, Jr. Dear Attorney Wolfson: As you may be aware, I am currently representing Billy J Snider in regard to her divorce and custody of her minor children. While I am more than happy to work with you on these issues, your client's repeated harassment of my client makes this matter difficult to end, Enclosed please find copies of applicable letters which I have sent to the State Police. We asked that Richard R. Snider not call or set foot on my client's property, While we are more than happy to work with him in regard to the custody of the children, his repeated threats and insults via the telephone make communication impossible, Additionally, there are substantial safety issues in regard to the children. Apparently, your client has engaged in a pattern and practice of abuse, including, but not limited to hitting, restraining, and threatening murder/homicide scenarios. Therefore, I have advised my client not to provide custody to your client at this time. However, once your client has enrolled with a counselor and the counselor clears him for visitation with the children, we would be happy to reconsider this matter. If your client attempts to exercise custody, we will ask that he be arrested for trespassing, and will seek an emergency order from the Court of Common Pleas. If you have any questions or concems, please feel free to contact me, While we are quite serious about denying your client visitation for safety and abuse issues, it is our hope that with proper professional help, he can fulfill his role as a father. Sincerely, ~ ~ Karl E. Rominger, Esquire KER/jem Enclosures cc: Billy J Snider "-'7-06 6Il5 Advocacy Advice Answers c f!Jl &nu/njJ€/}{ :::&U(J , ,"" '. '-i . ,~:"" r. --.,'""'--_--~_._-_ ,~', . rc:~- re (gl?:c, If.:' 1'1 VJ I1'=' rnI 1:= c=' l 'E' .. 0 0 ;c?__=2-____0:':' r\ i I (hfiVlft'\i... I AUG 1 1 2000 Ilu,' i! t~ r;c ,I " 'J! U L..-' -'1 155 South Hanover Street CarUsle. PenO$ylvania 17013 717.241.6070 . 888.241.9679 . Fax: 717.241.6878 law@romlngerlaw.com . www.romlngerlaw.com Please reply to Carlisle office. August 10,2000 Richard R, Snider, Jr. c/o Daniel F. Wolfson, Esq, Wolfson & Associates, P,C. 267 East Market Street York, PA 17403 Dear Mr, Snider: This letter gives you official notice that you will be considered a defiant trespasser, in Violation of 18 PA CSA-3503 if you come to 127 Long Road, Apartment 1, Newville, PA I 7241. The penalty for Defiant Trespass, a misdemeanor, is up to one year in jaiL Furthermore, if you continue to commit acts which alarms or seriously annoys my client, and which acts serve no legitimate purchase, you will be charged with harassment, a summary offense under 18 P A CSA-2709, The penalty for Harassment is a fine up to $300 plus cost, and up to 90 days in jail, or both, A copy of this letter is on file at the Pennsylvania State Police Department, If you defY this request and come to Ms, Snider's home at 127 Long Road, Apartment I, or continue to harass her, charges will be filed! Very truly yours, ?--:::::- ~ . ~ Karl E, Rominger, Esquire KER/jem cc: Pennsylvania State Police Billy 1. Snider "Z. q~, ,00 .5IlS Advocacy AdvIce Answers - j-. -- '~, o FAMILY LAW n~~fRI IIIII i A service to the community by students from The Dickinson School of Law of The Pennsylvania State University June 15,2000 Daniel F. Wolfson, Esq. WOLFSON & ASSOCIATES, P.C. 267 East Market Street York, PA 17403 Re: Billy J. Snider v. Richard R. Snider, Jr. Cumberland County No. 00-2418 Dear Mr. Wolfson: Thank you for your proposed Postnuptua1 Agreement. I have reviewed this agreement with my client, Billy J. Snider, and she is not willing to sign such a comprehensive agreement at this time. I have prepared a simple Custody Agreement to resolve the custody dispute in this case. Please review this document with your client. Ifhe is agreeable, please obtain his signature, with you as his witness, and return the document to me. I will then file the original with the Court and send you a certified copy.. If you notify me that your client does not agree with the terms of the Custody Agreement I have prepared, I will ask that Hubert X. Gilroy, Esq. re-schedule a custody conciliation for this case. If you have any questions or concerns, please do not hesitate to call me. Sincerely, r:J~:U' -H~ Certified Legal Intern Enclosure cc: Billy J.. Snider -3 C;~, -00 srt5 PENNSrATE .. The Dickinson School of Law An Equal Opportunity University . .-,-, ''';- ,,- ---"- . _?,,~ - .c'''' '~,_",,o, - _ ~" -'.:., ,,-.' ' ,._"c_,"" - ""'il . BILLY J. SNIDER.. Plaintiff' v. :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION- LAW :IN CUSTODY :NO. 00-2418 CIVIL TERM RICHARD R. SNIDER, JR., Defendant ORDER OF COURT AND NOW, this _day of , 2000, upon presentation and consideration of the attached agreement and upon agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of the Court. This Order shall remain in force unless and until modified by further Order of the Court, BY THE COURT, J. i . -, ~ '-', ,', '-'-:'.' . , '-,- C"", . .. BILLY J, SNIDER, Plaintiff v. :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION- LAW :IN CUSTODY :NO. 00-2418 CIVIL TERM CUSTODY AGREEMENT RICHARD R.. SNIDER, JR., Defendant THIS AGREEMENT, made this _ day of , 2000, between Billy J, Snider, hereinafter Mother, and Richard R. Snider, Jr., hereinafter Father, concerns the custody of the children: Kyle A. Snider, born June 17, 1995, and Rebecca M. Snider, born November 23,1999. Mother and Father desire to enter into an agreement as to the custody of the children.. Mother and Father agree to the following: 1. Mother and Father shall share legal custody of the children. 2. Mother shall have primary physical custody of the children. 3. Father shall have partial physical custody of the children during the following times: a. Every other weekend during the school year, from Saturday at 5 :00 PM until Monday at 5 :00 PM, unless otherwise agreed by the parties. b. Every Wednesday and Thursday evening during the school year, at times agreed upon by the parties prior to the time of pick up, unless otherwise agreed by the parties. c. During the school year, transportation for these periods of partial physical custody shall be shared by the parties. d. During the summer months when school is not in session, every other week to begin one week after the last day of school in the spring, and to end one week prior to the beginning of school the following fall. Times of the exchanges shall be by agreement of the parties prior to the exchange. Each parent will be responsible to pick the children up from the custody of the other parent for their period of custody, unless otherwise agreed by the parties. e. At such other times as the parties have mutually agreed in advance. 4. Mother and Father shall share physical custody of the children on holidays as mutually DEfENDANT'S EXHIB~n q--, -'0 S/t-8 ~ - ,": . . , -~ --~ ,~-~ " - ,- --" ",","- ,--"-,--,,-,~ .::; o ~ agreed between the parties. 5. Mother shall have physical custody ofthe children on Mother's Day, and Father shall have physical custody of the children on Father's Day. 6. Mother and Father shall be entitled to reasonable telephone access with the children while the children are in the other's custody. 7. Mother and Father shall promptly notifY each other of all medical care the children receive while in that parent's care. Mother and Father shall notifY the other immediately of medical emergencies which arise while the children are in that parent's care. 8. Neither parent shall do or allow someone else to do anything which may estrange the children from the other party, 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 and respect for the other parent.. 9.. The parties intend to be bound by the terms of this agreement. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms hereof, set forth their hands and seals the day and year first written above. Richard R. Snider, Jr. Daniel F. Wolfson WOLFSON & ASSOCIATES, P.C. Attorneys at Law 267 East Market Street York, PA 17403 (717) 846-1252 Counsel for Richard R. Snider, Jr. ~QJnA1A'Q DAidj Mel 'eD. Walz Certified Legal I tern Robert E. inS Thomas M. Place SUPERVISING ATTORNEYS Donald Marritz STAFF ATTORNEY F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Counsel for Billy J, Snider ~IS ~U-Clc ~~-Jd;~ ,-"',, , --~. '" -~ " - ..'. ""'- BILLY J. SNIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v.. NO.. 00-2418 CIVIL TERM RICHARD R. SNIDER, JR., Defendant CIVIL ACTION - LAW IN RE: PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 7th day of September, 2000, upon consideration of the Defendant's Petition for Special Relief with respect to the parties' children, Kyle Andrew Snider (date of birth June 17, 1995) and Rebecca Mae Snider (date of birth November 23, 1999), and following a hearing at which the Plaintiff was represented by Karl E.. Rominger, Esquire, and the Defendant was represented by Daniel F.. Wolfson, Esquire, it is ordered and directed as follows: 1. Legal custody of the children shall be shared by the parties. 2. Primary physical custody of the children shall be in the mother. 3. Temporary or partial physical custody of the children shall be in the father on alternating weekends from Friday at 6:00 p.m.. until Sunday at 5:00 p.m. and on Wednesday evenings from 6:00 p.m. until 9:00 p.m.. Exchanges of custody shall be made at the State Police Barracks in Carlisle, Pennsylvania.. Neither party shall inflict corporal punishment on the children during his or her periods of custody.. This Order is entered on a temporary basis pending the custody conciliation conference scheduled for September 26, 2000, and further Order of Court.. ~ i ! )': ii ij ~,I H \') Ii !l II it :'1 I :! >1 '1 I "' ~,' \r" ,~ ,.,~~....- ,~ c:~:; S~:-~' - 8 no' 'it- \":0. i\t 1 L~' ,,'.... '-~'''-\'i \f,r\"Y '_.J',.Jvl' ._ ,.."q !\'"ne, \-,: \J1\,~.,j L\lr':' '~I' " ..'C\.l'\...... ' . ~,.""- , ''If'l!_1l8lIl~~~m~~~~-!!jl~~!~'''' e. ~!I{Iflt.~"'f';~ c:' >- #;. . Karl E. Rominger, Esquire Rominger Law Offices 155 South Hanover Street Carlisle, PA 17013 Attorney for Plaintiff Daniel F. Wolfson, Esquire Wolfson & Associates, P.C. 267 East Market Street York, PA 1740.3 Attorney for Defendant Sheriff srs By the Court, """ l~_$:OO 1.)\~ , lMl.~", IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BILLY J. SNIDER, No. 00-2418 Civil Term Plaintiff vs. CIVIL ACTION - LAW RICHARD R. SNIDER, JR., Defendant DIVORCE ACTION NOTICE TO PLEAD TO: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 YOU ARE HEREBY NOTIFIED, pursuant Pa.R.C.P. No. 1018.1, to file a written response to the enclosed Counterclaim within twenty (20) days from service hereof or a default judgment may be entered against you. Respectfully submitted, ~~~~ ~~baniel F. Wolfs , quire WOLFSON & ASSOCIATIES, P.c. 267 East Market Street York, PA 17403 (717) 846-1252 ID No. 2061 7 Attorney for Defendant :; II IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BILLY J. SNIDER, No. 00-2418 Civil Term Plaintiff vs. CIVIL ACTION - LAW RICHARD R. SNIDER, JR., Defendant DIVORCE ACTION " ! I I I I ANSWER TO COMPLAINT FOR DIVORCE AND CUSTODY AND COUNTERCLAIM FOR CUSTODY AND NOW, this 6th day of September, 2000, comes the Defendant, Richard R. : Snider, Jr., by and through his/her/their attorney, Daniel F. Wolfson, Esquire, and the law firm of Wolfson & Associates, P.C, and files the following Answer and Cross-Petition of which the following is a statement: ANSWER COUNT I. . DIVORCE 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. I, ! 8. Denied. It is specifically denied that the Defendant has offered any indignities to the person of the Plaintiff. It is further denied that the Plaintiff is the injured and innocent spouse. To the contrary, the Defendant is the injured and innocent spouse. Strict proof is demanded at Trial. 9. Denied. After reasonable investigation, Defendant is without sufficient information or knowledge to form a belief as to the truth or veracity of this allegation. Therefore, same is denied and strict proof is demanded at trial. COUNT I. - CUSTODY I:! 10. Paragraph 10 of Plaintiff's Complaint is an incorporation paragraph to which no response is required. To the extent that a response is necessary, same is denied and the allegations contained in Defendant's above responses are incorporated herein by reference as if set forth in full. 11. Admitted. 12. Admitted. 13. Admitted. 14. Admitted. 15. Admitted in part and denied in part. a) Admitted in part and denied in part. It is admitted that the Plaintiff was the primary caretaker, but only assumed this role because she was not employed. It is denied that the fact that she was the primary caretaker makes her more amenable to having majority physical custody. It is further 2 II alleged and therefore averred that the Defendant was significantly involved in every aspect of the lives of this children, including their care, feeding, and physical and emotional activities. It is further alleged that for approximately one (t ) year, Defendant took complete care of the parties' son, Kyle, prior to the birth of the parties' daughter, Rebecca, while the Plaintiff worked day shift and the Defendant worked night shift. b) Admitted in part and denied in part. It is admitted that the Plaintiff provided the children with a home. However, it is denied that the home has adequate moral, education and physical ~urroundings to meet the chiidren's needs. To the contrary, it is averred that the parties' son, Kyle, has no room for himself, nor does the daughter (who is 8 months old). It is also alleged and therefore averred that the Plaintiff does not engage the chiidren in any meaningful activities other than having them "sit" in front of a computer for a majority of the time they are with the mother. c) Admitted in part and denied in part. It is admitted that the Plaintiff is willing to accept the custody of the children. It is denied that she is an adequate majority physical custodian for the children's needs. d) Admitted in part and denied in part. It is admitted that the Plaintiff continues to exercise parental duties. However, it is specifically denied that said duties are in the best interest of the children. e) Denied. It is specifically denied that the Defendant has not indicated to Plaintiff an interest in accepting custody of the children. To the contrary, 3 "" it is averred that the Defendant is desirous of obtaining majority physical custody of the children. 16. Admitted. COUNTERCLAIM 17. The answers and allegations contained in Defendant's above responses are incorporated herein by reference as if set forth in full. 18. It is believed and therefore averred that the best interest and permanent welfare of the children will be served by granting majority physical custody to the Defendant for the following reasons: a) Because the Defendant has been actively involved in ever phase of the children's lives since birth, and has fully and completely provided for their needs. b) The Defendant is willing to accept majority physical custody of the children and is able to maintain a sound physical and psychological relationship with the children. c) Defendant is more stable, and more capable of providing the proper parental care, and can better provide for the physical and emotional needs of the children and the necessary continuity. 4 , , , WHEREFORE, the Defendant respectfully requests this Honorable Court grant majority physical custody of the children to the Defendant, subject to the mother's rights of minority physical custody. Respectfully submitted, ~~~ Daniel F. Wolfso, uire WOLFSON & ASSOCIATES, P.c. 267 East Market Street York, PA 17403 (717) 846-1252 ID No. 20617 Attorney for Defendant 5 , , VERIFICATION Daniel F. Wolfson, Esquire, hereby states that he is the attorney for the Defendant, Richard R. Snider, Jr., and he is authorized to take this verification on behalf of said Defendant in the within action and verifies that the statements made in the foregoing Answer and Counterclaim are true and correct to the best of his knowledge, information, I, Ii and belief based upon information provided by the Defendant. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: ~/ (, J(,f) I ' ~~ /~c;e Daniel F. Wolfson, quire WOLFSON & ASSOCIATES, P.c. 267 East Market Street York, PA 17403 (717) 846.1252 ID No. 20617 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BILLY J. SNIDER, No. 00-2418 Civil Term Plaintiff vs. CIVIL ACTION - LAW I !i, RICHARD R. SNIDER, JR., Defendant DIVORCE ACTION CERIIFICA IE OF SERVICE AND NOW, this 8th day of September, 2000, I, Daniel F. Wolfson, Esquire, do hereby certify that I have served a copy of the foregoing Answer and Counterclaim upon I the counsel of record by regular mail, postage pre-paid and addressed as follows: il , Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (Counsel for Plaintiff) ~~~ Daniel F. Wolfson, re WOLFSON & ASSOCIATES, P.c. 267 East Market Street York, PA 17403 (717) 846-1252 ID No. 20617 Attorney for Defendant ~ 1<J"lt~!'l;'ijftij,~m.~iW'!W'J&lIIli"';'~*'1!OMilWl,wjjJir.ol-",;>ill;;m",Hi!~Ollr~~~iP"""'-- ~, ~~" ~ = " . ~. , ~ " ~~lIl _ -., -- (') c c:: L_J -;" ;/) ::-j , -,' l ; {",I , /. .-0 ~'--- , U;.; h~ _.J f~ ~.-~ , -'j,) L- - ;,.< C , <' , "c"- :..~) ;.:::-1 ~< t=", ::JJ -< _yo, ~-, . --~- ".'.'~ .'= , ~.", .', ',:d",- '. ,,~. '. J=,' ~",~~,,-: --.'i;.i""'''-'\;_r'; ,:_,;,"i;;.'_,,- - w -,.' '.'c"'<h- &;';-"'__ ""'"'' BILLY 1. SNIDER, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v, iCIVIL ACTION- LAW :IN CUSTODY RICHARD R SNIDER, JR., Defendant :NO. 00-2418 CIVIL TERM CERTIFICATE OF SERVICE I, Melanie Walz Scaringi, hereby certifY that I served copies of my Withdrawal of Appearance on Billy 1. Snider at 127 Long Road, Apartment 1, Newville, Pennsylvania 17241; Karl E. Rominger, Esq., new counsel for Billy 1. Snider, at 155 South Hanover Street, Carlisle, Pennsylvania 17013; Daniel F. Wolfson, Esq" counsel for Richard R Snider, Jr., at 267 East Market Street, York, Pennsylvania 17403; and Hubert X Gilroy, Esq" Custody Conciliator, at 4 North Hanover Street, Carlisle, Pennsylvania 17013, by placing the same in the United States mail, fIrst class, postage prepaid. Date:~. ft ,rooD t!/;}: A1~ g1{l ~ 1M ~ Mel 'e Walz Scaringi CertifIed Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 , " "oj'.' ~'-'_~r. "~ ,- "'->'''''I~i''~'--''''''''~'''''''''i.i;nJ ,^;,;.' ,- I, " ~ ,~" - ~. r , o S -0;::\' rni"';--. Z:T' Oic- -< r;:: ~C) ''-c >c :-2": =< 11 ~ I I ! ! c:} C) u') , ''1 .'tJ Co..:: :::;; ::::> C::) .', , . ~ , ,,---.. , " " ,,',-' ,.~:, -,.-, -, "" ,~~. ~ ' . 'I ' , I . . . ., " .'.'-. -~-..,,;- .'_."_"00_" Vc": .,;,~~:i~-&",';"__'. "^~'-'_ __ . _'<,~, Billy J Snider, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CML ACTION - LAW IN DIVORCE/CUSTODY Richard R. Snider, Jr, Defendatlt : NO,00-2418 CIVIL TERM WITHDRAWAL OF APPEARANCE The Family Law Clinic hereby withdraws its appearance as attorney of record for Billy J. Snider, the plaintiff in the above-captioned case. Date:~ i!:b.Jt1M~ g ~~Mj Aled Mel 'e Walz Scaringi Certified Legal Intern ~,~ ROBERT E. RAINS THOMAS M, PLACE Supervising attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013-2899 I\IJIIIftl.., ~_~~u.-i ~'_~.!!'llJJ.li~i I" ~'''''''i'''''''' "........'..;.- - - (') ;p(~~ -!.Iri-, l!j:~?> _!/It:. .~{j' -<:':" -::; -< Ii [i II II II 11 II 1C.::; C;:; [:;} -~ c,: -- -- ::::; (~) > '( ",~" 0' '" -- <_ _" " ,,:,., , -"~' --~-" .,."" .~ , .. SEP 2 9 zoootiJ BILLY J.. SNIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW RICHARD R. SNIDER, JR., Defendant NO. 2000 - 2418 CIVIL IN CUSTODY COURT ORDER AND NOW, this ~ day of D c1 \) L 0 , 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. This Court's prior Order of September 7, 2000 is vacated. 2. The Mother, Billy 1. Snider, and the Father, Richard R. Snider, Jr.., shall enjoy shared legal custody of Kyle A. Snider, born June 17, 1995; and Rebecca M.. Snider, born November 23,1999. 3. The Mother shall enjoy primary physical custody of the minor children during the school year. 4. During the school year, the Father shall enjoy periods of temporary physical custody as follows: A. On alternating weekends from Friday at 6:00 p.m. until Sunday at 5:00 p..m. B. Upon Father giving Mother reasonable notice on or before Sunday of each week, Father may exercise custody with the minor children during the week while the Mother is working. If the children do not have school the following moming, the Father may elect the opportunity to keeping the children overnight at which time they will be returned by Noon the following day.. The parties shall work out an arrangement as to when the Father would get the children on the weekday evenings, and the return of the children to the Mother's custody shall be no later than 9:00 p.m. unless Father has elected to keep the children overnight when the children do not have school the following day.. 5. During the summer months, the parties shall alternate physical custody on a week on/week off basis with an exchange of custody to take place on Friday at 5:00 p.m.. unless agreed otherwise between the parties. The first week shall commence the Friday after the children are released from school. J u -< .~ ;; f:iLED'-D;'=VICE cr C:\.JOTARY 00 OCT -3 Pr1 3: 38 CUM8EhL,\lU COUN1Y PENNSYLVANiA ,." I"'"' '" -.-, .,-,-~~ -~, ~.. ~ ~.,?,~ .-- "~'-"' "-_.,~~ ,~.-, ~'---.-'''''''="~'~- ,_.-_,' ,,>, -~__c ,,_ ~_,_ .. 6. The parties shall share custody on the following holidays: Memorial Day, July 4th, Labor Day, Thanksgiving, New Year's Day and Easter. Unless the parties agree otherwise, the Mother shall have each holiday from 8:00 a.m. until Noon and the Father shall have from I :00 p.m. until 5:00 p.m.. on each day. 7. The Christmas holiday shall be handled separately and divided between two segments with the first segment being from December 24th at Noon until December 25th at Noon and the second segment being from December 25th at Noon until December 26th at Noon.. Father shall enjoy custody on the fIrst segment in the year 2000 with the parties altemating thereafter.. 8. Mother shall always have custody of the children on Mother's Day and the Father shall always have custody of the minor children on Father's Day.. The time will be from 9:00 a.m. until 9:00 p.m. This provision shall supercede any other provision of this Order.. 9. Neither parent shall make any comments or allow any comments to be made in the children's presence which would in any way disparage the other parent or alienate the children's affections from the other parent.. 10. This Order is entered pursuant to an agreement reached by the parties at a Custody Conciliation Conference. The parties may modifY the custody arrangements by agreement between themselves. However, absent any agreement, the terms of this Order shall control. Furthermore, in the event the parties desire to modifY this Order, either party may petition the court at which time the case again would be assigned to the Custody Conciliator for a Conference.. 11.. Both parties shall enjoy reasonable telephone contact with the minor children when they are in the custody of the other parent.. 12. Father shall handle transportation for exchange of custody.. Exchange of custody shall be made at the State Police Barracks in Carlisle, Pennsylvania unless agreed otherwise by the parties. 13. Neither party shall consume alcohol or be under the influence of alcohol when they have the minor children in their custody. 14. Both parties shall ensure that the children wear the appropriate child seats and/or safety belts when the children are being transported in a motor vehicle by that parent.. 15. Neither parent shall relocate out of Cumberland County without first notifying the other parent in advance.. - ,,-- ,,> ,-= --' ,"" -, "'-"~""""""'- -- ~,-, "..-y ",-- -.-" ,,-' ~;" """'~' ' "'." ,'- -,,1 16. In the event either parent shall take the minor children away overnight when they have custody of the minor children, they shall alert the other parent of the location where they are taking the children and also a phone number where they may be reached. 17. Both parents shall keep the other parent informed with respect to all medical, educational and social matters pertaining to the minor children. Furthermore, all medical personnel and school personnel are authorized to share information on both children with both parents equally.. BY THE COURT, cc: Daniel F.. Wolfson, Esquire John Baranski, Esquire J. ,,-- ,-.-, ,-",<;'''.'. ,---",.< .', - 'j ~ BILLY J.. SNIDER, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RICHARD R. SNIDER, JR., Defendant NO. 2000 - 2418 CIVIL IN CUSTODY Prior Judge: 1. Wesley Oler, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Kyle A. Snider, born June 17, 1995; and Rebecca M. Snider, born November 23, 1999. 2.. A Conciliation Conference was held on September 28, 2000, with the following individuals in attendance: The Mother, Billy J.. Snider, with her counsel, John Baranski, Esquire; and the Father, Richard R. Snider, Jr., with his counsel, Daniel Wolfson, Esquire. 3.. The parties agree to the entry of an order in the form as attached. fPr/ (lO HAT --;." , "L'L ~,--' . ",: -- ,., ,"; -,-- '- ; ,- . -- - ' ;":,','_;:'2~';' -;-,,,,-~:,-_',,;__~___-_"_,::___,-,~;-,j- :z_~ '~'.' ,',', , "--j Billy 1. Snider, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION - LAW IN DNORCE/CUSTODY Richard R. Snider, Jr. Defendant : NO,00-2418 CNIL TERM WITHDRAWAL OF APPEARANCE The Family Law Clinic her~by withdraws its appearance as attorney of record for Billy 1. Snider, the plaintiff in the above-captioned case, Datel II/BOIOt) ~~h4W df!k~ Mel 'e Walz Scaringi 7!i1i& ROBERT E. RAINS THOMAS M, PLACE Supervising attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013-2899 ENTRY OF APPEARA."l'CE Please enter the appearance of Karl E. Rominger, Esq" as counsel of record for Billy J Snider, the plaintiff in the above-captioned case. Date: (\(01/. l~ 2.011' / /~ ~ Karl E. Rominger, Esq, 50 East High Street Carlisle, PA 17013 l:i;--~'-<^-,,- " .,' ",,- 'U" k, :.,.. 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