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HomeMy WebLinkAbout03-0060CHRISTOPHER SNYDER, Plaintiff, V. DAN/CRIPE, Defendant. · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW · IN CUSTODY COMPLAINT IN CUSTODY AND NOW, comes the Plaintiff, Christopher Snyder, by and through his attorneys, Mancke, Wagner, Tully & Spreha, and files the following Complaint in Custody: 1. The Haintiff, Christopher Snyder, is an adult in individual currently residing at 375 York Road, Carlisle, Cumberland County, Pennsylvania, 17013. 2. The Defendant, Dani Cripe, is an adult individual currently residing at 643 Alcott Drive, Hummelstown, Derry Township, Pennsylvania, 17036· 3. Plaintiff seeks custody of the following children: A. Jordan Tyler Snyder, currently residing with the Defendant at 643 Alcott Drive, Hummelstown, Pennsylvania; DOB: 6/13/91; B. Jakab Steven Snyder, currently residing with the Defendant at 643 Alcott Drive, Hummelstown, Pennsylvania; DOB: 4/22/99. 4. Jordan Tyler Snyder was born out of wedlock, and the parties were subsequently married. Jakab Steven Snyder was born in wedlock. 5. The children are currently in the custody of the Defendant who resides at the aforementioned address. 6. During the past five (5) years, the children have resided with the following persons at the following addresses: From the Summer of 2002, to present, the children resided with their mother, a maternal sister and brother-in-law at the Hummelstown address; From December 1999 to December 2002, the children resided at 151 Wilson Street, Carhsle, Cumberland County, Pennsylvania, with their mother, maternal grandmother, and maternal great- grandmother. From 1995 to December 1999, the children resided at 375 York Road, Carhsle, Cumberland County, Pennsylvania, with both Plaintiff' and Defendant. Do From 1991 to 1995, the oldest child resided at 151 Wilson Street, Carhsle, with the mother, maternal grandmother, and maternal great-grandmother. -2- 7. The mother of the children is the Defendant who currently resides at the Hummelstown address, and she is currently divorced. 8. The father of the children is the Plainfiffwho currently resides at the 375 York Road address in Cumberland County, Pennsylvania, and he is divorced. 9. The relationship of the Plaintiff to the children is that of natural father, and he resides alone at the aforementioned address. 10. The relationship of the Defendant to the children is that of natural mother, and he resides at the aforementioned Hummelstown address with the children, her sister and brother-m-law. 11. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation concerning the custody of the children in this or any other court. 12. Plaintiff has no information of any custody proceedings concerning the children pending in any court of the Commonwealth. 13. Plaintiff does not know of any other person not a party to these proceedings who has any physical custody of the children or any clahns for custody or visitation rights to the respective children. 14. The best interest and permanent welfare of the children will best be served by granting the relief sought because the father has consistently been a caregiver to the children, and would be in a better position to ensure appropriate visitation and contact with beth parents. 15. Each parent whose parental rights to the children which have not been terminated and the person who has physical custody of the children have been named as parties to this present action. 16. No other persons with custody or visitation rights are known to Plaintiff. WHI~.REFORE, Plaintiff requests this Court to grant custody of the children to him. Respectfully submitted, Mancke, Wagner, Tully & Spreha Date: / a/.~ William T. Tully, Esquire I.D.# 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Plaintiff 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.A. §4904, relating to unsworn falsification to authorities. CHRISTOPHER SNYDER PLAINTIFF DANI CRIPE DEFENDANT IN THE COURT OF COMMON PLEAS OF , y CUMBERLAND COUNT , PENNSYLVANIA 03-60 CIVIL ACTION LAW IN' CUSTODY ORDER OF COURT AND NOW, _ Friday, January 10, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear befbre Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Tuesday, February 11, 2003 at 11:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Melissa P. Greevy, Esq. Custody Conciliator - d The Court of Common Pleas of Cumberlan County is required by law to comply ~vith the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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, Pennsylvania 170 l 3 Telephone (717) 249.-3166 SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2003-00060 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SNYDER CHRISTOPHER VS CRIPE DANI R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: CRIPE DANI but was unable to locate Her deputized the sheriff of DAUPHIN in his bailiwick. He therefore County, Pennsylvania, to serve the within COMPLAINT - CUSTODY On February 19th , 2003 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin Co 18.00 9.00 10.00 29.25 .00 66.25 02/19/2003 Sheriff of Cumberland County MANCKE WAGNER TULLY SPREHA Sworn and subscribed to before me this ~ day ~ A.D. Prothonotary Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania : SNYDER CHRISTOPHER vs County of Dauphin : CRIPE DANI Sheriff' s Return No. 0042-T - - -2003 OTHER COUNTY NO. 2003 60 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for CRIPE DANI the DEFENDANT named in the within CUSTODY COMPLAINT and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, February 6, 2003 CUSTODY COMPLAINT EXPIRED. Sworn and subscribed to before me this 12TH day o~EBRTY, 2003 PROTHONOT~¥ So Answers, Sheriff of Dauphin County, Pa. By Deputy Sheriff Sheriff's Costs: $29.25 PD 01/08/2003 RCPT NO 173894 in Th~ Court of Common Pleas of Cumberland County, Pennsylvania Chris topher Snyder VS. Dani Cripe -No. 2003-60 Civil TeTM NOW, January 7, 2003 ,20 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of .... Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA ~XIow, within Affidavit of Service ,20... , at o'clock M. served the upon at by handing to a and made known to copy of the original So answers, the contents thereof. Sworn and subscribed before me this ~ day of ,20 Sheriff of COSTS SERVICE MILEAGE AFFIDAVIT County, PA CHRISTOPHER SNYDER, Plaintiff DANI CRIPE, Defendant M^R t ~. ~03 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-60 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY TEMPORARY ORDER OF COURT AND NOW, this 1,~-~,,~ day of March, 2003, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Christopher Snyder and Dani Cripe, shall have shared legal custody of the minor children, Jakab Steven Snyder, born April 22, 1999, and Jordan Tyler Snyder, born June 13, 1991. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to, medical, dental, religious or school records, the residence address of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Mother shall have temporary primary physical custody subject to Father's rights of supervised visitation which shall be arranged as follows: A. To commence March 5, 2003, each Wednesday evening from 6:00 p.m. until 8:30 p.m. Father's visits shall be supervised by one or more of the following individuals: Lori, Ron, or Jean Adams. 3. Transportation incident to these visits shall be provided by Mother. 4. The parties shall submit themselves and their minor children to an independent custody evaluation to be performed by Arnold Shienvold, Ph.D. The parties shall sign all necessary releases and authorizations for the evaluator to obtain medical and psychological information pertaining to the parties and the children, the children's educational records and reports from Children & Youth, and the Children's Resource Center. Additionally, the parties shall extend their full cooperation in completing this evaluation in a timely fashion and in the scheduling of appointments. NO. 03-60 CIVIL TERM 5. Through counsel, and by letter, either party may request a date for the Custody Conciliation Conference to reconvene if such request is made within ten (10) days of the receipt of the custody evaluator's report by counsel. Dist: BY THE COURT: William T. Tully, Esquire, 2233 N. Front Street, Harrisburg, PA 17110 Gary L. Rothschild, Esquire, 2215 Forest Hills Drive, Harrisburg, PA 17112 CHRISTOPHER SNYDER, Plaintiff V. DANI CRIPE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-60 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ,CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the children who are the subject of this litigation is as follows: .NAME Jakab Steven Snyder Jordan Tyler Snyder pATE OF BIRTH April 22, 1999 June 13, 1991 CURRENTLY IN THE CUSTODY OI- Mother Mother 2. A Custody Conciliation Conference was held on March 3, 2003 pursuant to Father's Complaint for Custody filed on January 6, 2003. Present for the conference were the Father, Christopher Snyder, and his counsel, William T. Tully, Esquire; the Mother, Dani Cripe, and her counsel, Gary L. Rothschild, Esquire. 3. Father's position on custody: Father filed a Complaint because Mother was withholding his contact from the children since November 2002. There was apparently a report made to Children & Youth Services alleging sexual abuse of the youngest child. The investigation was reportedly "unfounded." However, the State Police investigation has not been concluded. Father also alleges that Mother has cut off all contact with the paternal grandparents and members of the extended family. Prior to this allegation, the status quo provided Father with periods of custody each Saturday from 11:00 a.m. to 8:00 p.m. as well as Wednesday evenings for a family dinner. Father seeks primary custody because he believes that Mother will not now support his continued relationship with the children. Father reports that Mother has expressed a great deal of protectiveness of the children. For example, he reports that since September 11, 2001, the children were not allowed to drink water unless it was in a bottle. He also reports that Mother has demonstrated a fear of the children being kidnapped when she objected to their birth announcements appearing the newspaper and at times has objected to them playing outside. It is also significant to note that the parties' youngest child has been evaluated by the Capital Area Intermediate Unit and has been identified to having developmental delays. NO. 03-60 CIVIL TERM 4. Mother's position on custody: Mother reports that the parties' youngest child made statements to her which she then reported to Children & Youth Services in November 2002. While she acknowledges the Children & Youth report was "unfounded," she also points out that the child who was approximately three and a half (3~) at the time of the investigation, was not cooperative with the interview process at the Children's Resource Center. Mother reports that she wants the children to have a relationship with their Father. However, because she is concerned that something may have happened, she insists that all visits and contact with Father be supervised. She also reports several years ago that the older child had made some statements about someone having had inappropriate contact with him. 5. It is notable that the parties have been able to work out custodial arrangements since their separation in 1999 up until November of 2002 in the absence of a formal or written agreement. 6. The parties agreed to participate in a custody evaluation with Dr. Shienvold and ask the Conciliator to provide an opportunity to return to Conciliation after the custody evaluation report was completed. The parties also agreed to resume Father's contact with the children on Wednesday evenings upon the condition of supervision by one or more of three people upon whom they agreed. Date Melissa PeeI-Greevy, I~squire Custody Conciliator :210572 CHRISTOPHER SNYDER, Plaintiff V. DANI CRIPE, Defendant D~2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-60 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY OLER, J. --- ORDER OF COURT AND NOW, this ~ -~ ~.- day of December, 2003, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. This Order shall VACATE all prior Orders related to the custody of the minor children, Jakab Steven Snyder, born April 22; 1999, and Jordan Tyler Snyder, born June 13, 1991. 2. Legal Custody. The parties, Christopher Snyder and Dani Cripe, shall have shared legal custody of the minor children, Jakab Steven Snyder, born April 22, 1999, and Jordan Tyler Snyder, born June 13, 1991. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to, medical, dental, religious or school records, the residence address of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Mother shall have primary physical custody subject to Father's rights of partial physical custody which shall be arranged as follows: A. Effective December 7, 2003, each Sunday from Noon until 8:00 p.m. B. Each Wednesday evening from 6:00 p.m. until 8:30 p.m. C. At such other times as the parties agree. NO. 03-60 CIVIL TERM 3. Transportation. The parent relinquishing custody shall provide transportation incident to Father's periods of partial custody. 4. During any period of custody or visitation the parties to this Order shall not possess or use controlled substances, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise ensure, to the extent possible, that the other household members and/or house guests comply with this prohibition. 5. Holidays. A. Thanksgiving. For Thanksgiving 2003, Father shall have custody from Noon until 6:00 p.m. on Thanksgiving Day. B. Christmas. Father shall have custody for Christmas 2003 from 3:00 p.m. until 8:00 p.m. C. The parties shall share custodial time for subsequent holidays by their mutual agreement. Dist: BY THE COURT: arn T. Tully, Esquire, 3964 Lexington Street, Suite B, Harrisburg, PA 17109 ry L. Rothschild, Esquire, 2215 Forest Hills Drive, Harrisburg, PA 17112 DEC 0 1 20113 CHRISTOPHER SNYDER, Plaintiff DANI CRIPE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-60 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Jakab Steven Snyder Jordan Tyler Snyder April 22, 1999 June 13, 1991 Mother Mother 2. The Custody Conciliation Conference reconvened on November 25, 2003 after the parties participated in a comprehensive custody evaluation with Dr. Arnold T. Shienvold. Present for the conference were: the Father, Christopher Snyder, and his counsel, William T. Tully, Esquire; the Mother, Dani Cripe, and her counsel, Gary L. Rothschild, Esquire. an agreement in th ~b'~'m o an Order as attached. Date e :221461 I ~'. i I.. '._. Ti `.' F LAW OFFICE OF WILLIAM T. TULLY a~~d /~(Np ~(p PAS ~• yS '•.s' 1 . William T. Tully, Esquire ~ , .: ,_ 3964 Lexington Street, Suite B L( V ~ ;.; is :~ ~ i7 i :' ~ -: w Harrisbwg, PA 17109 717/540-6833 ~~~~~, _ ~ ~ y ~:. ~ Attorney ID #36410 i ".., . . DANI M. CRIPE : IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 03-60 CIVIL TERM CHRISTOPHER SNYDER :CIVIL ACTION -LAW DEFENDANT : IN CUSTODY COMPLAINT FOR CUSTODY MbD~F~~A'noty AND NOW, comes the Defendant, Christopher Snyder, by and through his attorney, William T. Tully, Esquire, and avers as follows: 1. The Defendant, Christopher Snyder, is an adult individual currently residing at 375 York Road, Carlisle, Cumberland County, Pennsylvania. 2. The Plaintiff, Dani M. Crips, is an adult individual currently residing at 105 Stanford Court, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are the natural parents of Jakab Steven Snyder, born April 22, 1999. 4. Since the birth of the child, the child has resided at the following locations with the following persons: a. From birth to summer of 2002, child has resided at 150 Wilson Street, Carlisle, Cumberland County, Pennsylvania, with mother, maternal grandmother, and maternal great-grandmother; b. From Summer of 2002 to summer of 2007, child has resided with Mother, a maternal sister and brother-in-law at 785 Cardinal Drive, Harrisburg, #'10.00 P~ Ai'r`/ CASH ,Q.*a~e~ Dauphin County, Pennsylvania. c. From summer of 2007 to present, child has resided at 105 Stanford Court, Mechanicsburg, Cumberland County, Pennsylvania, with Mother. 5. Defendant believes and therefore avers that it is in the best interests of the child, Jakab Steven Snyder, that primary physical custody of him be granted unto the Defendant herein, as he is able to care for the day to day needs of the child and provide the necessary love and affection for the child, subject to periods of partial custody in the Plaintiff herein. 6. Plaintiff is currently denying Defendant reasonable access to and visitation with the child. WHEREFORE, Defendant prays this Court to grant the relief requested by granting primary physical custody of Jakab Steven Snyder, born April 22, 1999, unto the Defendant herein. Respectfully Submitted, Date: / l!'~ ~ ~~,. William T. Tully, Esquire 3964 Lexington Street, Suite B Harrisburg, PA 17109 (717) 540-6833 I.D. #36410 LAW OFFICE OF WILLIAM T. TULLY William T. Tully, Esquire 3964 Lexington Street, Suite B Harrisburg, PA 17109 717/540-6833 Attorney ID #36410 DANI M. CRIPE : IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 03-60 CIVIL TERM CHRISTOPHER SNYDER :CIVIL ACTION -LAW DEFENDANT : IN CUSTODY CERTIFICATE OF SERVICE I, Betty A. Geeting, hereby certify that on this date, a true and correct copy of the foregoing document was served upon all interested parties by first class mail and addressed as follows: VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED Dani M. Cripe 105 Stanford Court Mechanicsburg, PA 17055 Date: ~ l `~/l~ DANI M. CRIPE PLAINTIFF V. CHRISTOPHER SNYDER DEFENDANT . IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA 2003-60 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, August 20, 2010 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, October 01, 2010 at 9:30 AM 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. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: _ /s/ Hubert X. Gilroy, Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. Ali arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT- p HAVE AN ATTORNEY 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 tf? 6-23 • 10 0AC4. CC7?tJ? 32 South Bedford Street ` Q Carlisle, Pennsylvania 17013 W -rte f k6 Telephone (717) 249-3166 ?s a3??v ?Jari co- M, eSJ, +C) $•?stD ek+ NOV 17 2010; DANI M. CRIPE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA • n N VS. CIVIL ACTION - LAW c -° -? 3 0 -n -t coca = M C=) CHRISTOPHER SNYDER, NO. 2003-2003-60 Nr ° rn-n z CO Defendant IN CUSTODY MQ o -< DC=) © _ Prior Judge: The Honorable J. Wesley Oler, Jr. mco c)--n F5 o < COURT ORDER NOW, this day of November, 2010, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this court's prior order of December 2, 2003, shall remain in effect subject to the following modifications: 1. Father's periods of custody as found in paragraph two of the existing order shall be replaced with the following: A. Father's periods of temporary custody shall include alternating weekends from Saturday at noon until Sunday at 5:00 p.m. After father exercises five weekends of custody under this schedule from Saturday to Sunday alone, father's alternating weekends shall be expanded to go from Friday at approximately 2:30 or after school until Sunday at 5:00 p.m. B. On the Monday evening following mother's weekend, father shall have custody from after school until 8:30 p.m. C. Father's periods of time shall also be at such other times as agreed upon by the parties. 2. For the upcoming Thanksgiving holiday, father shall have custody from Thanksgiving day at approximately 2:00 p.m. overnight until Friday at noon. f -1 3. For the Christmas holiday of 2010, the holiday shall be divided into two segments: Segment A shall be from December 24 at noon until December 25 at noon and Segment B shall be from December 25 at noon until December 26 at noon. Mother shall have Segment A and father shall have Segment B for 2010 with the parties alternating thereafter. 6. The parties shall meet again for a custody conciliation conference on Thursday, February 24, 2011, at 8:30 a.m. Additionally, in the event any issues develop prior to this second conciliation conference, counsel for the parties may contact the conciliator directly to schedule an expedited conciliation conference which may be via telephone with the conciliator and legal counsel for the parties. 7. In all other respects, this court's prior order of December 2, 2003, shall remain in place. cc: W'lliam T. Tully, Esquire /Linda A. Clotfelter, Esquire Pt FS r xu5 t Lik ///jIe//v t=1111 r - DANI M. CRIPE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW CHRISTOPHER SNYDER, NO. 2003-2003-60 Defendant IN CUSTODY Prior Judge: The Honorable J. Wesley Oler, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Jakob Steven Snyder, born April 22, 1999 2. A Conciliation Conference was held on November 12, 2010, with the following individuals in attendance: The mother, Dani M. Cripe, with her counsel, Linda A. Clotfelter, Esquire, and the father, Christopher Snyder, with his counsel, William T. Tully, Esquire. 3. The parties agree to the entry of an Order in the form as attached. Date: November /f, 2010 Hubert X. Gilroy, Custody Concilia y 0 DANI M. CRIPE, Plaintiff vs. CHRISTOPHER SNYDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW _.) NO. 2003-60 r IN CUSTODY cc) r-c , -71 ._ j COURT ORDER AND NOW, this Z to day of i^ 2011, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Courtroom No. 1 of the Cumberland County Courthouse on the ? day of , 2011, at m. At this hearing, the Father shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a Memorandum setting forth the history of custody in this case, the issues currently before the Court, a list of witnesses who will be called to testify at the hearing and a summary of the anticipated testimony of each witness. This Memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, this Court's prior Order of November 17, 2010, shall remain in place. 3. Should legal counsel for the parties believe that another custody conciliation conference would aide in resolving this case prior to the hearing scheduled above, legal counsel may contact the custody Conciliator directly for purposes of scheduling such a conference. cc William T. Tully, Esquire ? Linda A. Clotfelter, Esquire eop; P5 MA. 16d 4-0-6-111 vv- , I BY THE COURT, M ? 1 DANI M. CRIPE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CHRISTOPHER SNYDER, Defendant CIVIL ACTION - LAW NO. 2003-60 IN CUSTODY Prior Judge: The Honorable J. Wesley Oler, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Jakob Steven Snyder, born April 22, 1999 2. A Conciliation Conference was held on February 24, 2011, with the following individuals in attendance: the mother, Dani M. Cripe, who appeared with her counsel, Linda A. Clotfelter, Esquire, and the father, Christopher Snyder, with his counsel, William T. Tully, Esquire 3. The parties had conducted a conciliation conference in November after which they agreed upon an Order. Father has been exercising limited custody with the minor child pursuant to the existing Order. Father is seeking more time with the minor child and Mother is reluctant to agree to additional time for a variety of reasons. A hearing is necessary and the Conciliator recommends an Order in the form as attached. S Date: February 2011 , 610 e?. - Hubert X. Gilroy squire Custody Conci or DANI M. CRIPE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ' c e VS. : NO. 2003 - 60 CIVIL -per = --+ =M =m =-n SNYDER, : CIVIL ACTION - LAW CC/)r- ' -°rn M Defendant : IN CUSTODY m ° WITHD RAWAL OF APPEARANCE C:) CZ) A Kindly withdraw the appearance of Linda A. Clotfelter, Esquire, for Plaintiff, Dani M. Cripe, in the above-captioned matter. Date: hto II y. Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER LINDA A. CLOTFELTER, ESQ A IL orney I.D. 72963 701:21 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile ENTRY OF APPEARANCE Kindly enter the appearance of Benjamin D. Andreozzi, Esquire, of Andreozzi & Associates, P.C. for Plaintiff, Dani M. Cripe, in the above-captioned matter. Respectfully submitted, ANDREOZZI & Date: -/a By: BENJAMIN D. D Attorney I.D. 8 v 215 Pine Street Harrisburg, PA 17101 (717) 229-1055 telephone (717) 525-9143 facsimile TES, P.C. ESQUIRE A DANI M. CRIPE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 2003 - 60 CIVIL CHRISTOPHER SNYDER, : CIVIL ACTION - LAW Defendant : IN CUSTODY CERTIFICATE OF SERVICE AND NOW, this day of April, 2010, the undersigned hereby certifies that a true and correct copy of the foregoing WITHDRAWAL AND ENTRY OF APPEARANCE was served upon the interested parties by way of United States first class mail, postage prepaid, addressed as follows: Linda A. Clotfelter, Esquire 5021 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 William T. Tully, Esquire 2595 Interstate Drive Harrisburg, PA 17110 Respectfully submitted, ANREOZZI & ASSOCIATES P.C. By: BEN AMIN A Attorney I. 89 1 215 Pine reet ESQUIRE Harrisbur , P 17101 (717) 22 - 55 telephone (717) 52 -9143 facsimile Benjamin D. Andreozzi Attorney ID #89271 ANDREOZZI & ASSOCIATES, P.C. 215 Pine St., Ste. 200 Harrisburg, PA 17101 717-525-9124 Ben@midstatelaw.com Attorney for Plaintiff DANI M. CRIPE, Plaintiff vs. CHRISTOPHER SNYDER, Defendant OF THE PRprNO SCE NOTARY 2011 MAY 20 py 1: 04 CUPENNSYNO COUNTY YLYANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2003-60 CIVIL ACTION - LAW IN CUSTODY CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Plaintiff, Dani M. Cripe, certifies that: 1. A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party on May 11, 2011; 2. A copy of the notice of intent, including the proposed subpoena, is attached to this certificate; Defense counsel has waived the 20 day notice requirement and does not object to the issuance of this subpoena; and 4. The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date: l ANDREOZZI & ASSOCIATES, P.C. l By: Benjamin D. d eozzi, Esquire Attorney ID 89 71 215 Pine S , St . 200 Harrisbur P 17101 (717) 525- 24 Attorney for Plaintiff Benjamin D. Andreozzi Attorney ID #89271 ANDREOZZI & ASSOCIATES, P.C. 215 Pine St., Ste. 200 Harrisburg, PA 17101 717-525-9124 Ben@midstatelaw.com Attorney for Plaintiff DANI M. CRIPE, vs. CHRISTOPHER SNYDER, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2003-60 CIVIL ACTION - LAW IN CUSTODY NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Plaintiff, Dani Cripe, intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. Date: ANDREOZZI & By: Benjamin D. Andre z: Attorney ID 4 8927 215 Pine St., S ' . 00 Harrisburg, P 7101 (717) 525-912 ` Attorney for Plaintiff TES, P.C. Esquire DANI M. CRIPE PLAINTIFF V. CHRISTOPHER SNYDER DEFENDANT : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003-60 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY PROPOSED ORDER AND NOW, this t S1 day of I,,, I ?1 , 2011, upon agreement of the parties, the custody arrangements between the parties relative to their minor son, Jakob Steven Snyder, shall be modified as follows: 1. In order to maximize father's non-working time with his son, visitation shall be adjusted to coincide with father's unusual work schedule as much as possible. (A copy of the schedule is attached hereto and made a part hereof highlighting father's days off). 2. On father's weeks, father shall have Jakob for two days and overnights which will coincide with his days off (picking him up after school and returning him to mother at 5:00 p.m. the evening of the second day). 3. On mother's weeks, father shall be able to pick up Jakob after school or at 2:30 p.m. and return him at 8:00 p.m. during the school year and 8:30 p.m. during the summer on each of the two days he has off that week. 4. When father :has three days off in a given week, he shall advise mother of which two days he selects. 5. In order to maintain continuity with the previous Order of November 17, 2010, the Modified Order will commence with father's day time visits on the week commencing March 29th (May 31 St and June 1St), and father's overnights the week of June 5th (June 8th and 91h) 6. Father shall be entitled to one full week of uninterrupted vacation during the -A 0 summer with Jakob, during which time Jordan shall be welcome as well. 7. All other aspects of the November 17, 2010 Order shall remain in place. 8. Mother and father agree to discuss and consider additional custodial periods with father as Jakob becomes accustomed to them. 9. It is the desire of the parties, and the Court, to have mother and father communicate and negotiate additional changes without the need for Court intervention, however, the parties shall be allowed to return to the Conciliator at the end of the summer to address additional changes if necessary. J. C: CS -r? -03 ?' rn 1 ..y x -M t`? rn? , n tom- t rn `? S C4 c5, °-? :r A ??tn r eee L z ?.Sr . 7 ?i pry, _ ??C?? t'S iket . ??6f 7/(? f 11 RY THF. COT TRT-