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HomeMy WebLinkAbout00-05705 , "~'-jj,,,;,,,,~, ~."';:'~,,~:;,~ .-~~,,," ,,';"',d- " . .. '" '" "'''':1::''';1;", '" . .. . "':f. "'ff. . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . STATE OF PENNA. CHRISTA BRADLEY SNYDER, Plaintiff NO. 2000-05705 . . . . VERSUS SeOTT GREGORY SNYDER, . Defendant . . . DECREE IN DIVORCE . AND NOW, D c.f,..loc.J ? 2... ,,?-ool , IT IS ORDERED AND DECREED THAT Christa Bradley Snyder , PLAINTIFF, AND , DEFENDANT, g,..,(')rr ~,...e:>g/"lry gnyne:>r 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; The Property Settlement Agreement between the parties is hereby incorporated but not merged. . . . '" '" '" '" "'''' '" '" '" '" '" . . . . . . . . . ATTES . . PROTHONOTARY . . ~" >,' J. ~~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I , i ~~ "'" /tJ -;23 -tJI /t?,; 3 ./J/ 1"1ilM!j.~_"'7'"". -~-" -,_. --- "', ~,'. ~ .- .._- . ...'. .^",,, <' (}d- ~ ~-# a1. )!~ 7l~~Z~ . "l'~ r. r~.~,-'~~~' .,~tl[!l!l.~iJ!lW:r ~lI\IiI-o:;r;,,_~,~~~~,~~~_ I ~, ,-- SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS-AT-LAW 26 W. High Street Carlisle, PA i - -, ';: ; -W'; 0 r _0.",", , "', _ __ ',' _ ~__; " '", ,- ' " ::A.l, CHRISTA BRADLEY SNYDER, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 2000-05705 SCOTT GREGORY SNYDER, : CIVIL ACTION - LAW Defendant : IN 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: Code, 1. Ground for divorce: Irretrievable breakdown under Section 3301(c)ofthe Divorce 2. Date and manner of service of the Complaint: Regular mail, Acceptance of Service signed by Attorney John Connelly, Jr., attached hereto as Exhibit "A". 3. Date of execution of the Affidavit of Consent required by Section 330l(c) of the Divorce Code: By the Plaintiff: September 21,2001 By Defendant: September 21,2001 4. Related claims pending: No claims raised. 5. Date Plaintiffs Waiver of Notice in 9 3301(c) divorce was filed with the Prothonotary: October 9, 20001 Date Defendant's Waiver of Notice in 9 3301(c) divorce was filed with the Prothonotary: October 9, 2001 Date: ()d '? ~ "z-oc I eck, A orney Plaintiff 26 West High Street Carlisle, P A 17013 (717) 243-6222 II ~...;" ~ - '"':'~<>""'_.""''''ii'.wzJ,,' iil",I~aw."..J..;,,,,',, .~. . ,.,,^, ~~~ ,-,',e,,,",,, ,~ ,'c q,,~ ,,~, - . .,,- -~ ,'- "< . '--~ - ,,~ " ri~ ~~~~ -:;;-~ ....,.. zC (/) ~, ~</'-, r::::C.-,' ~~~:;', :):-~S =:..1 -< () C "lliIi ''''''''''''"':1! mi II ~1 t~) 'I! ~j I, i i ']! !i " '! ': , C-'''' .J i , i i , I I I I i I I I I C"::> 'I-J o ~.~ \.,.C) '~,) ~ ,::;. j ~'~, " .. "]i;t:.;'q . CHRISTA BRADLEY SNYDER PLAINTIFF V. SCOTT GREGORY SNYDER DEFENDANT IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-5705 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 23rd day of August ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp HiD, FA 17011 on the 18th day of September ,2000, at 9:15 a.m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defme 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. FOR THE COURT, By: Isl 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, 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 TIllS 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 17013 Telephone (717) 249-3166 iliIllIiii~~~$\a"''l!i<~ll<Iiil!il!l;"~~M'j~j!!!d~,,~l:l'ftI!IlMoi!'''' JiI.1 ,.' ~ .. ~,~ ~ _ _ . ~^ V,-', ,~", ~',~~'~ ,~ jililUJ T'lll!i!liililliil'lt.. .. ~fp'7 ~~ ~~~~f< ro p z ~ 4I:l~' Vfl\l~~ A.LP'J'tlcJ:) ~q~.~~t~~~ "j~:~7/vn:) 6u ." "/ 'c. he! C ~J (,~" vC>JliflCO :.10 ",~",'" ,~. " ~ -'--- ,.,..,-~="..",~ - ~ ~ IllIII;Mt:;~.aii!lWll!l.:tIi;jl- 'l~i ,: rt: ~~ " Ii ! !,I,: !~ t:J (;'. ,jJ(? j t:JCl-ae? 00-,$(':.$ . .'<'., . -" ,"" ",,, -""-" "'.'. ""," :h.,;', ;," ,- ~-..-,,- ,~, , ~'" '-',h'~ CHRISTA BRADLEY SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000- ..57t2S CIVIL TERM SCOTT GREGORY SNYDER, Defendant CIVIL ACTION - LAW IN DIVORCE & CUSTODY ORDER OF COURT AND NOW, , upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the conciliator, at on the day of , 2000, at ___.m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older shall also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, BY: Custody Conciliator 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. 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, Pennsylvania 17013 (717) 249-3166 SAlOIS, SHUFF & MASLAND ATIORNEYS.AT-LAW 26 W. High Street Carlisle, PA II' ~" - '~ - "~ --,-,<", CHRISTA BRADLEY SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000- CIVIL TERM SCOTT GREGORY SNYDER, Defendant CIVIL ACTION - LAW IN DIVORCE & CUSTODY NOTICE 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 counselling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Street, Carlisle, Pennsylvania. IF YOU DO NOT FILE PROPERTY, LAWYER'S FEES ANNULMENT I S GRANTED, YOU THEM. A CLAIM FOR ALIMONY, DIVISION OR EXPENSES BEFORE A DIVORCE MAY LOSE THE RIGHT TO CLAIM ANY OF OR OF 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 SAIDIS, SHUFF & MASLAND By: Jo II SAlOIS, SHUFF & MASLAND ATIORNEYSeAT.LAW 26 W. High Street Carlisle. PA - "" ,,~ ,-' ~lli&~' ^" '')0'' .<" "''"'" CHRISTA BRADLEY SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000- .5'705' v. CIVIL TERM SCOTT GREGORY SNYDER, Defendant CIVIL ACTION - LAW IN DIVORCE & CUSTODY COMPLAINT UNDER SECTION 330l(c) OR 330l(d) OF THE DIVORCE CODE 1. Plaintiff is Christa Bradley Snyder, who currently resides at 113 McAllister Church Road, Carlisle, Cumberland County, pennsylvania. 2. Defendant is Scott Gregory Snyder, who currently resides at 513 8th Street, New Cumberland, Cumberland County, Pennsylvania. 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. The Plaintiff and Defendant were married on November 7, 1997 in New Cumberland, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to 2 SAlOIS, SHUFF & MASLAND ATI'OR~YSeA"'LAW 26 W.lllgh Street Carlisle, PA request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce. COUNT II - CUSTODY 8. The allegations set forth in paragraphs 1 through 7 above are incorporated by reference as though fully set forth herein. 9. The parties are the parents of a minor child, Jason Snyder, DOB 11/11/99. 10. Since birth, the child has lived with both parents until January 3, 2000, and since January 3, 2000 to the present, has lived with the mother. 11. The child was not born out of wedlock. 12. Plaintiff has not participated as a part or witness, or in another capacity, on other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 3 II SAIDlS, SHUFF & MASLAND AlTORNEYS.AT-LA.W 26 W. High Street Carlisle, PA 13. The best interest and permanent welfare of the child will be served by granting Plaintiff primary physical custody subject to periods of partial physical custody and/or visitation to the Defendant. WHEREFORE, Plaintiff requests the court to grant her primary physical custody of said child. Respectfully submitted, SAIDIS, SHUFF & MASLAND Date: ~ 8, 2.00D By JOh~{(sr;2quire Supreme Court ID # 53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff 4 Ii of_ SAIDIS, SHUFF & MASLAND ATrORNBYSeAT.LAW 26 w. High Street Carlisle, PA ',k ."""";;'.">x.'""."" ~~~ AFFIDAVIT I, Christa Bradley Snyder, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counselling and understand that I may request that the court require that my spouse and I participate in counselling. (2) I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. (3) Being so advised, I do not request that the court require that my spouse and I participate in counselling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: ~ 8, "2-000 ~&jrLu Christa Bradley yder V Plaintiff II SAlOIS, SHUFF & MASLAND ATrORNEYS-AT-LAW 26 W. High Street Carlisle. PA , - -:. '-'. .' ~"., . " "'~ r VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subj ect to the penal ties of 18 Pa. C. S . Sect ion 4904, relating to unsworn falsification to authorities. Dated: A.^:f <6 '200 c) , ~~a~~ Christa Bradley Snyder Plaintiff II '..' ",,;,10. " -'llikl~";- ~d.Hl.f!iJ. \~ ....... ~ ~ t> '-J ?v " v "'\\ "=~_.~, .,~ ,~- , ~ ~ \ , " ~ ,"""""""~ 1,;1 ,;;1 11..1:,: "j c'i 'Ii f: "I"":': "I ;~I ,'1,,1' I, ,il 1:1 '::,1 :1 'I ,I Ii ,j II II :1 I: I , : I I ~ () C:J C' C:. CJ " --,," ;~ --;:... -OCt.) G~1 --~\ p"lr;") " Z.~J" >:-, ~ ,-~ CO \-.=} cO ?C-. l., -< .-{.-- '. J r:::U :;CJ..'" -T' iC :eO _~<,b ,'-"j "'-C ? '7~; \', : J>C:: '~ ? t-:"' '.p- ~ 01 ~ ,.. ,[ , ~,~, '" ~"'""""f, .. ~"", - CHRISTA BRADLEY SNYDER PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000 - 05705 SCOTT GREGORY SNYDER, DEFENDANT : CIVIL ACTION - LAW : IN DIVORCE & CUSTODY ACCEPTANCE OF SERVICE I, John J. Connelly, Jr., Esquire, accept service of the Complaint in Divorce on behalf of my client, Scott Gregory Snyder, Defendant therein. Date: el , Jr., Esquire .th, urkin & Connel Post Offi ' 650 Hershey,PA 17033 (717) 533-3280 ~ ~~, '--"~'~",' " ''"'~~-- ~ - .'~ IililiilI !:? t:: ,-'~;rD ~~-' s:C ~~:_:: ~'-~~ --' -< it n ;) ~r 'I-!, ~i R~ ~l "', < F.,' i~'"i :\' ~~ ~~ It ~ f' C:) 1~ :" ~ , ~,_O -C! ::..,.,." ~-'-) co SAInlS SHUFF, FLOWER & LINDSAY ATTORNEYS'A.T'LAW 26 W. High Street Carlisle, P A CHRISTA BRADLEY SNYDER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COTJNTY, PENNSYLVANIA Plaintiff v. NO. 2000 - 05705 SCOTT GREGORY SNYDER, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on August 18, 2000 . 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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 to the best . of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unswom falsification to authorities. CJvW.j-b-.., En q cIJJ4 ~r/..u. Christa Bradley Snyder, Plaintiff Date: q I~ J) () I Ii ",.""., I :.0..,'- . b' llIIIi~'lirJ"-.'~l!iili"''" '. '.". h _ .. . -~. - >~- o c ........;~, V..j- IT! ;'~. -7--' .,.:....--,'. 2:"': ~;:'~~ r;:C,' .-' ;'~: ~ 2: -< --., >. _NW c' r~ .,-~ '-", "i ~ il rl "1 I 'I I \.Q." .'"':'") :.....) -:..~) ()i -~ .. ,~~~ SAIDIS SHUFF, FLOWER & LINDSAY ATIORNf:YS'AT'LAW Z6 W. IlIgh Street Carlisle, PA CHRISTA BRADLEY SNYDER, IN THE COURT OF' COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 2000 - 05705 SCOTT GREGORY SNYDER, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 I 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. ~t0 Bta.c.U..ut ~rlvv Christa BradleySndyer, Plaintiff Date: JjJ'\ 101 . .' - ll;il!;M(i'U" ~~~~ ,,,-"-- e. I: t".! I i".! f-l ! I: iii' i q I'i re, I:l I H !: I; I~ Ii i~ 0 c 0' ;:":) Q3~f! ':...~ ....., j 1 ~L t,..o I V I :~ "'-', ;?: , .. I C) ~.-'? ;::j :;;.~ c: ~ J) ~q -< (Jl -, . ,~ ~...~ ~. ~ J .. ",,,,~~ -" - ,~,,,,,,,. - '.--,~..--" -..-,-"' __.k-' >'- ""lh';-'''-"'',''''''''""",,, -;;"-;:"":;,~_ - ;,,'-.0 '~"-;' "!I' CHRISTA BRADLEY SNYDER, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANlA : NO. 2000 - 05705 SCOTI GREGORY SNYDER, Defendant : CIVIL ACTION - LAW : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on Auo~ 2E ,2000. - 0 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of both the filing and service of 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. 4. I have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. 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.A. Section 4904, relating to unsworn falsification to authorities. Date: if J-( I 0 ( ~<J ~jv- Scott G. Snyder, Defendant :>o.J, "'0':') ,,~." ~ =~~.~ C) c:' (J S 'T1 -r:r n~ ~ ~ C-) .' ._".~ /~' , ~} ~ ID ~, i' ~- " _c- '.' ,- " .2 C) >- :::'';; ....-.~ /:. <~ ".-. -~.,) -< (Ii ., , ~,.~- -~ - ,~",,, "-- ~ - ~ , "I ~ I , .1 -'1 J !~ ~j 11 i :1 'I ~ " ~ t 't'" ~ -_ 1_ _, - '. _:,,,~,c., _ ix ., '''>.. ':~~'::-;';__>-4'~;J;-,;/.,-'/,,_- _.i-~- " . -,,'~',:_,,<-;- - - - ~ . >-;;;'";;,\.:::" --,< . CHRISTA BRADLEY SNYDER, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 2000 - 05705 SCOTT GREGORY SNYDER, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(~) OF TIm 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 in 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.A. Section 4904, relating to unsworn falsification to authorities. Date: ~(d1I{){ M~-~ Scott G. Snyder, Defen t _I ,>; ~-", --,' -.c-' ~, "__"0,'., ~ "~ , , "' '""-~~ ~ ""-~..." -, N_/,>~~ . . ~ ~ --- .~ C' . _ < -"'~ .> '1 'f! ~-~ ~~;: ~ -J ~, - - ~'_~ - _~" U" ,~~ _,d , " c:-. rJ :~~~ I \,D u, :..,) -:'f~) (fj -.1J -< ^~ -"" .~ -~ , .- -",,',.- ~"""""),,-,}:;.- - -,~--; '., __ '_"'~ ,:'_.~~,,~,. ;-,,,,,',,~'" -,'''''~'''"",: :" ,--.;i,,_,. _ ~. .. .. CHRISTA BRADLEY SNYDER PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000 - 05705 SCOTTGREGORYSNYDE~ DEFENDANT : CIVIL ACTION - LAW : IN DIVORCE & CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTIIONOTARY: Please enter the appearance of John 1. Connelly, Jr., Esquire on behalf of the Defendant, Scott Gregory Snyder, in the above-captioned action. JAMES, SMITII, DURKIN & CONNELLY Date: 8-3/-0D ", ~.i ~. .,,,,,',';,y ,,,,,,..'-' '''''-''' - ',- .--' ,~-,> { .. "~- _-_,. _,__~,. .,=.._,..~,,~. C_~L~ _,r' '''''", ~-j""'-' '-,- ,'" - ~ ",.' ~ 'n.j ^', '-- ,-,.,/:.:-,- -.'< ,__.__~'_=''''''', ,. '--~-_'''''-''~w -- -~......... "t . 0 = (; C 0 --",':' ::;:;.. :.n -0 O. ;''1 1.1 f.~ - D "~'l :z: r:-- ~; "'::... I -, Cf) J-: cr ,-'] -< " r r' t~.: C) ~ ---- 00 C-' : ";"1 2::: LJ <:. --) > D I [ , c ;:i z :..,) ~ lJ -<' --J ~< '-y b, =- = ,-- ~ ~~ lmllii!t,' , OCT 0 3 2000JP CHRISTA BRADLEY SNYDER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5705 SCOTT GREGORY SNYDER, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this 1/t day of 0 ft k, c5 , 2000, upon consideration of the attached Custody Conciliation Summary Report, it is ordered and directed as follows: 1, The parties, Christa Bradley Snyder and Scott Gregory Snyder, shall share legal custody of the minor Child, Jason Snyder, born November 11, 1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 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 of the minor Child subject to Father's period of partial physical custody which shall be arranged as follows: A. To commence on September 22, 2000, Father shall have custody on alternating Fridays from 3:30 PM until 7:15 AM Saturday morning, B. To commence on September 30, 2000, Father shall have custody on alternating Saturdays from 9:00 AM until Sunday at 4:00 PM. Ch' o' '" ~",'~.- ~~~ _."""';'':'''''.- - ~~~~!iill.l'Ol ~ o. "~< ~ ~, "0,' ^_ '. -". ,,,,,=, --- ViNYi\1;Si'IN3d , "I'; "C' '1 'rl' I~rll"~<"\ /\..1..\\\ lU ,; (,,>\\: ;~,:'~t)ll\ 1-..1 ~" oil' ''"I ov' (~k \ \ 13000 l~I',"<:(I' ...'" I\\.r!.\- ... ",)',"'i.'_'_;' 1-..1 38\j:K}{[1"1\.:-1 ~""-, -, 10, :J.~J Iii "_n ._k_ ~"" , NO. 00-5705 C. Father shall have the option of exercising one evening visit per week from 3:30 PM until 7:00 PM upon a 48-hour notice to Mother. D. Father shall have one week of summer vacation subject to a 3D-day notice to the Mother 3. The parties shall share transportation in that the party receiving custody shall provide transportation, 4, Holidays. A. The following holidays shall be shared by mutual agreement of the parties: New Year's Day, Easter, Memorial Day, Independence Day, Labor Day and Thanksgiving. B. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall commence from December 24th at Noon and continue until December 25th at Noon. Segment B shall commence from December 25th at Noon and continue until December 26th at Noon. In even-numbered years, Mother shall have Segment A and Father shall have Segment B. In odd- numbered years, Father shall have Segment A and Mother shall have Segment B. 5. In the event that Father is unable to exercise any of his periods of partial custody he shall notify Mother prior to his change in plans. 6. This Order is temporary in nature and may be modified by the mutual consent of the parties. In the event that the parties cannot agree, either party may seek modification of the Order upon proper petition to the Court whereafter the matter shall be scheduled for a Custody Conciliation Conference, ~ BY THE COURT, J. Dist: Johnna Deily, Esquire, 26 W. High Street, Carlisle, PA 17013 John J. Connelly, Jr., Esquire, 134 Sipe Avenue, Hummelstown, PA 17036 ~ t~~\\.oo \0' ~ - -.~---- 0010"'_;, ,"-", ""<i,' OCT 0 3 2000bP CHRISTA BRADLEY SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO, 00-5705 SCOTT GREGORY SNYDER, Defendant CIVIL ACTION - LAW 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 Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jason Snyder November 11, 1999 Mother 20 A Conciliation Conference was held on September 18, 2000, with the following individuals in attendance: The Mother, Christa Bradley Snyder, and her counsel, Johnna J. Deily, Esquire; the Father, Scott Gregory Snyder, did not attend. Father's counsel, John Connelly, Esquire, did not attend but participated by telephone. 3. The Order attached represents the agreements which the counsel for the parties have been negotiating in correspondence prior to the conference date. In the event that Father objects to the Order as recommended he may petition for modification of the Order and attend a Custody Conciliation Conference as has been r viously directed. Date M a Peel Greevy, Esquire Custody Conciliator -;j,= ~~ ~-- no ~ .....~~ . ~ ill.. .- .tll.~0i' . CHRISTA BRADLEY SNYDER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 00-5705 CIVIL ACTION LAW SCOTT GREGORY SNYDER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, February 12, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, P A 17043 on Tuesday, March 19, 2002 at 11 :00 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 aU existing Protection from Abnse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Melissa P. Greevy. Esq.!sY'^ 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. 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 TOYOURATIORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTII BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 1-$ . t"" -~~ d. -/tf'-oc;; c1 "/f/'-t?C}.. ;2 "/t(, 0,) '" co, o ~ .<." ;'F:"'/\FT'{ I ' Fd?: Q ~ r" '\f,'"_ ; " ('-('1\ i\F'\I t,)Jjli;I:'~~i":_J"" '-,',,Ji.Jl ~ I PErlNSYLY/\N1A ... w- ~/t<-~ ~ $" ~ r<)L-t"' 71~o~&4~ Co/? M~~4 ~ ~~,...,.~=~,~_!'iJ'i;mii<\'!P\!I~~1!l\Il~~I!i;~~tffi-,'{l-i'i'[!8l!'%m'-'D}'7*'11i'j'f!':];~~~~~_!J-oh,,~ :j/IlfIl'jIlI1~ . SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW Z6 W. High Street Carlisle, P A ~,.' ,.- .'-,,-~- - -"'<... -, " ~" -, , -~ r_, \f\ FEB,:L 2002 ~ CHRISTA BRADLEY SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-5705 SCOTT GREGORY SNYDER, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, , upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at , on the_____ day of , 2002, at .m., for a Pre- Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age ,five or older shall also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, BY: Custody Conciliator 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. 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, Pennsylvania 17013 (717) 249-3166 SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW Z6 W. High Street Carlisle, P A " Co'_,_" . < 'C' - "_~' ''' ,,,",l;-, "'" '""-- >~ L' . " __~ CHRISTA BRADLEY SNYDER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW v. SCOTT GREGORY SNYDER, NO. 00-5705 CUSTODY Defendant PETITION FOR MODIFICATION OF CUSTODY AND NOW, comes the parties, by and through counsel to stipulate for custody as follows: 1. The Plaintiff is Christa Bradley Snyder, an adult individual residing at 131 McAllister Church Road, Carlisle, Cumberland County, PA. 2. The Defendant is Scott Gregory Snyder, an adult individual residing at 513 8th Street, New Cumberland, I, PA. 3. The parties are the natural parents of Jason David Snyder, date of birth April 11, 1999. 4. The parties had previously been subject to an Order of Court dated October 9, 2000 which is attached hereby and made apart hereof and marked as Exhibit "A" whereby the Plaintiff has primary physical custody of the minor child, subject to periods of partial physical custody in the Defendant. Ii SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS-AT-LAW 26 W. High Street Carlisle, P A ,-,'.';-' 5. At the present time, the Defendant has only been exercising very minor periods of physical custody, and not been having a mid-week visit. 6. Since the inception of this Order, the subject child has exhibited erratic behavior, and has been quite upset after returning from visits with the Defendant. 7. Because of these problems, the Plaintiff has enrolled the subject child for play therapy in the Family Enhancement and Play Therapy Center under the direction of Cynthia Sniscak; the counselor has advised that she needs both parents consent, before she may proceed with therapy for the subject child. 8. Because the Defendant refuses to authorize the play therapy, the child is getting worse instead of better. WHEREFORE, the Plaintiff respectfully requests Your Honorable Court to enter an Order limiting his contact with the child to visitation only, and to order him to cooperate in getting the child to play therapy as described above. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY / John ky, Esq. Atto y for laintiff 26 W. High Street Carlisle, PA 17013 II '! ~~ ''''l ' .~ , ". "' - ..,6 ~"~'-iill;,,, OCT 0 3 200afP , CHRISTA BRADLEY SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-5705 SCOTT GREGORY SNYDER, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this 9 t-h day of lOd:abe R, ,2000, upon consideration of the attached Custody Conciliation Summary Report, it is ordered and directed as follows: 1. The parties, Christa Bradley Snyder and Scott Gregory Snyder, shall share legal custody of the minor Child, Jason Snyder, born November 11, 1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 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 of the minor Child subject to Father's period of partial physical custody which shall be arranged as follows: A. To commence on September 22, 2000, Father shall have custody on alternating Fridays from 3:30 PM until 7:15 AM Saturday morning. B. To commence on September 30, 2000, Father shall have custody on alternating Saturdays from 9:00 )\M until Sunday at 4:00 PM. EXHIBIT I .. A . ~l"""""" . '-1LI " - -," ~"---!RiIki " NO. 00-5705 C. Father shall have the option of exercising one evening visit per week from 3:30 PM until 7:00 PM upon a 48-hour notice to Mother. D. Father shall have one week of summer vacation subject to a 30-day notice to the Mother 3. The parties shall share transportation in that the party receiving custody shall provide transportation. 4, Holidays. A. The following holidays shall be shared by mutual agreement of the parties: New Year's Day, Easter, Memorial Day, Independence Day, Labor Day and Thanksgiving. B. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall commence from December 24th at Noon and continue until December 25th at Noon. Segment B shall commence from December 25th at Noon and continue until December 26th at Noon. In even-numbered years, Mother shall have Segment A and Father shall have Segment B. In odd- numbered years, Father shall have Segment A and Mother shall have Segment B. 5. In the event that Father is unable to exercise any of his periods of partial custody he shall notify Mother prior to his change in plans. 6. This Order is temporary in nature and may be modified by the mutual consent of the parties. In the event that the parties cannot agree, either party may seek modification of the Order upon proper petition to the Court whereafter the matter shall be scheduled for a Custody Conciliation Conference. ,~~ . - ^'-' "\,. " BY THE COURT, /5 Dist: Johnns Deily, Esquire, 26 W. High Street. Carlisleo PA 17013 John J. Connelly, Jr., Esquire, 134 Sipe Avenue. Hummelstown, PA 17036 TRUE COpy FROM RECORD In Testimony .,..h:,rEOf, I here Ucto set my hand and t seal of sai Court at (iJrlisle, Pa. .....Jl."......~y 0' .:....J~....:...:~..~.. , I , , ,rothonotary , ,~ -~ -',- "t .',.- " CHRISTA BRADLEY SNYDER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5705 SCOTT GREGORY SNYDER, Defendant CIVIL ACTION - LAW 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 Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jason Snyder November 11, 1999 Mother 2. A Conciliation Conference was held on September 18, 2000, with the following o individuals in attendance: The Mother, Christa Bradley Snyder, and her counsel, Johnna J. Deily, Esquire; the Father, Scott Gregory Snyder, did not attend. Father's counsel, John Connelly, Esquire, did not attend but participated by telephone. 3. The Order attached represents the agreements which the counsel for the parties have been negotiating in correspondence prior to the conference date, In the event that Father objects to the Order as recommended he may petition for modification of the Order and attend a Custody Conciliation Conference as has been r viously directed. Me a Peel Greevy, Esquire Custody Conciliator Date - =~,~ "" ~, ...... . - Ii. - --.:J\t<-; VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated:J./I.J I 0 J.. ~r~~fi;Yde~ cI0u ~fulH.f;__~;!;..'lr'4;!i",i>#!~""~:!tMlifj;::~~!ci\lJi!'!.-t~'"!1i~_bl!iii~mr~'" ~, ~ ;lit] "'"'lII8tl --~-.. ~ -. , ~ ,.. , ~ ~~-illi ~ 0 <::) (-=:J C , --J "T,( " ,." ~ V'-I 'lJ[D r-~ rr',,: cO C): Z-:[I I 2'!~_ , cry --,,' CJ Q, ~e~' -"1 --, - 0 ~'fj , . .sD '0 :"J ~, .) ~ ,).";;> c: -j V, , -"'. =J "J ::::J -N --<. (::> -< vt ~ ~ ~ ~ () ~ VI s-' . - ~~ SAlOIS SHUFF, FLOWER & LINDSAY A'ITORNEYS-AT-LAW 26 W. High Street Carlisle, P A .1.- ,-'''''- - '--~.~,-.. - ,. -" - ~ CHRISTA BRADLEY SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS .' CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-05705 CIVIL ACTION - LAW IN DIVORCE v. SCOTT GREGORY SNYDER, Defendant NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in divorce from the bonds of matrimony on the 22lld day of October, 2001, hereby elects to retake and hereafter use her previous name of Christa Bradley. ~ ~~ ~oU>> Christa Bradley S yder TO BE KNOWN AS: ~~ Christa Bradle~ COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBE~~ND ~ On the JJ..!"~Of A. .--I, 2002, before me, a Notary Public, personally appeared Christa Bradley Snyder to be known as Christa Bradley, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. NOTARIAL SEAL RENEE L. MURRAY. Nolary Public Carlisle Boroo Cumberland Co., PA My Commission Expires December 13, 2005 II ~' ~ ;- '".,w _' ",-,;, "i,;.-(;'-;.',;.,;""",. ;;;--);'~"i ,._, , ^ .".-.__~- ~"'( ,i_^ >,.;,,",,,~,._,,'" , ",C, ' ,-^~-;-, .'- ",--.. .--,~' , - ,,,~'.' ,,, /\) ~ 0 CJ C) -Sl c: t"':;' . '~'1 t:: s: '::r-: ~-..J I:) -au,: '-':--,. 4::: nln" ~~CJ I:> Z:~1-:. ~\ ~ ""'\ :z: \:,^ ej) ,:_: (r' R.) W -<.../ 8 r:: ,- ~s ..::'"\..,. :;>.;"" V) ~D "-> ~ J;'c: '2 , ~ 2: ~n '" ~ to ~ 1:3 "Jt ~ r. , ,.. c:-'- ^O :} "{ !' .~"1' i ~ ~i i' i I ~~ """'""" ~" --~. "~'''''''''<r(~ I. ... MAR 2 8 (002) CHRISTA BRADLEY SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5705 CIVIL TERM v, CIVIL ACTION - LAW SCOTT GREGORY SNYDER, IN CUSTODY Defendant OLER, J. --- ORDER OF COURT AND NOW, this 7 clu. day of o/vt Z I Coot , 2002, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 10 This Court's Order of October 9, 2000 shall remain in full force and effect with the following modifications: A. Sniscak, Both parties will cooperate with the play therapist, Cynthia B. Counsel for Father will provide two (2) weeks notice to counsel for Mother in the event that Father chooses to exercise his rights of partial custody pursuant to the schedule indicated in the October 9, 2002 Order. BY THE COURT: Dis\: Johnna J. Kopecky, Esquire, 26 W. High Street, Carlisle, PA 17013 ~ ~ John J. Connelly, Jr., Esquire, PO Box 650, Hershey, PA 17033 f '1,0.) ,O~ (), .Ji1"M_~.!''- ..). '-t,. MAR 2 8 2002 '? CHRISTA BRADLEY SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5705 CIVIL TERM v. CIVIL ACTION - LAW ;'Ii <I SCOTT GREGORY SNYDER, IN CUSTODY Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE' 1915.3-8, the undersigned Custody Conciliator submits the following report: i;~1- 1 . The pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Jason David Snyder April 11, 1999 Mother 2. A Custody Conciliation Conference was held on March 19, 2002 upon Mother's Petition to Modify Custody filed on February 8, 2002. Present for the conference were: the Mother, Christa Bradley Snyder, and her counsel, Johnna J. Kopecky, Esquire; the Father did not attend, however his counsel, John J. Connelly, Jr., participated by telephone. This was the parties' second Custody Conciliation Conference, neither of which was attended by the Father. ,I ,II ':',1' :J i\ 1 1 3. attached. Counsel for the parties reached an agreement in the form of an Order as (J,jo,0!rR . \~r;aL~ Melissa Peel Greevy, Esquire Custody Conciliator :.::j '!1 ':!' Date :156187 .'!, . ~"- , -. ~". .~-. "t~j~L CHRISTA BRADLEY SNYDER PLAINTIFF IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 00-5705 CIVIL ACTION LAW SCOTT GREGORY SNYDER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, March 27, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lernoyue, PA 17043 on Mouday, April 28, 2003 at 11:00 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 defme 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 hearin2. FOR THE COURT. By: Isl Melissa P. Greev:y. Esq. 1/ 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, 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 TIDS PAPER TO YOURATTORNEY AT ONCE. IF YOU DO NOT HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 r ".~ -" ~-,~~ I I I ~ I II I[ II I , I I Ii II' , !,,"I " " I, 1,"1','.' " Ii I iI' I~. !! i)l :,:,'1' i' 1:11 ";,J I,: IJ Ii " 1;) I:. 'lj ';1 I",.',,': lij 1:\ !,. -~~ ~~~-'" .'." -W!l!~~lIlOflI\I_ ." .. w _, _r _ __~" " _J n__ _ _ , _~ - ,- "-, - "~-, -"', ",.- -~ .! f._,. {\"~L;AF!Y [!~! i;; ~I;.{ p:._.( 'f. ':!J ,. '"" j j: L* ,off CUrv,P,;'''', !,," ""-'1' 'fd'ry , '-'7' ,...../"'! ,(.) 1...{~Uj"l PENNSYLVANIA 3-;l??03 w- ~ ~"'t,~ -0~ 3dt)oJ ~~~~ ~ J~f"~ ~ ~ ~'d7I ~ ~1'I'1l!1__ ~. _~~~~!,","~.,.",....._oo,A:>l~~I!,"h--Rl\""!'>'ijllE-''''',,!'l:!.'i''i''c'-~I~!!!;!:~W~!l\f~l'-~1.f'~~_41_",,_,~ ~- __,_ .(' MAR 26 2003 . u CHRISTA BRADLEY SNYDER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : VS. : NO. 00-5705 . . SCOTT GREGORY SNYDER, Defendant . . CIVIL ACTION - LAW IN CUSTODY : ORDER OF COURT AND NOW, , upon consideration of the attached Complaint, to is hereby directed that the parties and their respective counsel re-appear before the conciliator, Melissa Peel Greevy, at on the day of , 2003, at .m., for a Pre-Hearing Custody Conference in regards to Jason David Snyder. 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 shall also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, BY: Custody Conciliator MELISSA PEEL GREEVY, ESQ. 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. 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, Pennsylvania 17013 (717) 249-3166 CHRISTA BRADLEY SNYDER, . IN THE COURT OF COMMON PLEAS . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . VS. . NO. 00-5705 . . . SCOTT GREGORY SNYDER, . CIVIL ACTION - LAW . Defendant : IN CUSTODY PETITION FOR MODIFICATION OF ORDER OF THE CUSTODY OF JASON DAVID SNYDER AND NOW, comes the Plaintiff, by and through her counsel alleges as follows: 1. The Plaintiff is Christa Bradley Snyder, an adult individual residing at 131 McAllister Church Road, Carlisle, Cumberland County, PA. 2. The Defendant is Scott Gregory Snyder, an adult individual residing at 513 8th street, New Cumberland, PA. 3. The parties are the natural parents of Jason David Snyder, date of birth April 11, 1999. 4. The parties are now subj ect to an Order of Court dated October 9, 2000, which is attached hereby and made a part hereof and marked as Exhibit "A" whereby the Plaintiff has primary physical custody of the minor child, subject to periods of partial physical custody of the Defendant. Plus the parties are subject to a Modification of that Order dated March 29th, 2002, also part of Exhibit "A". 5. At the present time, the Defendant has not been exercising any physical custody. - 2 - .0 ", ,~ .". "-'-" ,,"," , '.- -~ -" ~ . 6. On or around December 16th, 2003, Cumberland County Children and Youth, after an in-depth investigation, have determined, or have "INDICATED" that Sexual Molestation and Child Abuse have in fact been committed by the Defendant, father, against their son, Jason David Snyder. 7. A copy of that Child Protective Service Investigation Report on this matter is attached and marked as Exhibit "B". This official report was issued by the Pennsylvania Childline and Abuse Registry in the Department of Public Welfare. 8. In fact, Defendant pulled on the child' s peniS and stuck his finger in Jason David Snyder's anus, which is a sexual assaul t. These outrageous actions by Defendant, Father, were committed numerous times when in the Custody of the Defendant, Father. 9. It is asked for this and other reasons, that the future and emotional state of Jason David Snyder that the be granted SOLE PHYSICAL AND LEGAL CUSTODY by the physical Plaintiff Court. - 3 - ,.; "- , - """' --"-'.-.-" . ."~"" ", _J ~~,.G " - ~,~ -, "--', ,'..- -- ''''.,- ~ . ' ~- WHEREFORE, the Plaintiff respectfully requests Your Honorable Court to enter an Order granting Sole Legal and Physical Custody to Christa Bradley Snyder, Plaintiff and Mother of Jason David Snyder. Respectfully Submitted, GOLDSTE S reet P. O. Box 10363 Harriburg, PA 17105-0363 (717) 236-6491 Counsel for the Plaintiff LD. # 07182 - 4 - 1 . " , , OCT 0 3 200atP CHRISTA BRADLEY SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, NO, 00-5705 SCOTT GREGORY SNYDER, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this 91:h day of &~(] be R ,2000, upon consideration of the attached Custody Conciliation Summary Report, it is ordered and directed as follows: 1. The parties, Christa Bradley Snyder and Scott Gregory Snyder, shall share legal custody of the minor Child, Jason Snyder, born November 11, 1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion, Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 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, Phvsical Custodv, Mother shall have primary physical custody of the minor Child subject to Father's period of partial physical custody which shall be arranged as follows: A. To commence o'n'September 22,2000, Father shall have custody on alternating Fridays from 3:30 PM until 7:15 AM Saturday morning, B. To commence on September 30,2000, Father shall have custody on alternating Saturdays from 9:00 AM until Sunday at 4:00 PM, , . , " '... , NO. 00-5705 C, Father shall have the option of exercising one evening visit per week from 3:30 PM until 7:00 PM upon a 48-hour notice to Mother. D. Father shall have one week of summer vacation subject to a 3D-day notice to the Mother 3. , The parties shall share transportation in that the party receiving custody shall provide transportation. 4. Holidavs. A. The following holidays shall be shared by mutual agreement of the parties: New Year's Day, Easter, Memorial Day, Independence Day, Labor Day and Thanksgiving. B. Christmas shall be divided into two segments, Segment A and Segment 80 Segment A shall commence from December 24th at Noon and continue until December25th at Noon. Segment 8 shall commence from December 25th at Noon and continue until December 26th at Noon. In even-numbered years, Mother shall have Segment A and Father shall have Segment 8, In odd- numbered years, Father shall have Segment A and Mother shall have Segment B. 5. In the event that Father is unable to exercise any of his periods of partial custody he shall notify Mother prior to his change in plans, 6. This Order is temporary in nature and may be modified by the mutual consent of the parties. in the event that the parties cannot agree, either party may seek modification of the Order upon proper petition to the Court whereafter the matter shall be scheduled for a Custody Conciliation Conference. .. -~.-_. - ---.-w:, " -\. BY THE COURT, /5 Dis!: Johnna Deily, Esquire. 26 W. High Street. Carlisle, PA 17013 John J, COnnelly, Jr.. Esquire, 134 Sipe Avenue, Hummelstown, PA 17036 TRUE Copy FROM RECORD In Testimonv '...h:..rEof, I hEre ti:"l:O set my hand and t ssa I or sai Court at C.:;r/isle, Pa. ,..../1....,......1.0......, LM'. ) . - . ... ''OJ' _ ,Iothonotary I , V . t , .,-. . " ~ i CHRISTA BRADLEY SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, NO. 00-5705 SCOTT GREGORY SNYDER, Defendant CIVIL ACTION - LAW 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 Child who is the subject of this liti9ation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jason Snyder November 11, 1999 Mother 2. A Conciliation Conference was held on September 18, 2000, with the following individuals in attendance: The Mother, Christa Bradley Snyder, and her counsel, Johnna J, Deily, Esquire; the Father, Scott Gregory Snyder, did not attend. Father's counsel, John Connelly, Esquire, did not attend but participated by telephone, 3, The Order attached represents the agreements which the counsel for the parties have been negotiating in correspondence prior to the conference date, In the event that Father objects to the Order as recommended he may petition for modification of the Order and attend a Custody Conciliation Conference as has been r viously directed, , f;J f/2trrl Date M61 "a Peel Greevy, Esquire Custody Conciliator ~ . . ^ ' '.............. ~"-~'-J _..~ -~ ~"'1t'J; 11ft ""1' , . MAR 2 8 2007 J> . c AP~ . c "~2 l'\ D 'i iiJlJ CHRISTA BRADLEY SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5705 CIVIL TERM v. CIVIL ACTION - LAW SCOTT GREGORY SNYDER, IN CUSTODY Defendant OLER, J. --- ORDER OF COURT AND NOW, this .J..9 ~ day of ~ , 2002, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. This Court's Order of October 9, 2000 shall remain in full force and effect with the following modifications: A. Sniscak. Both parties will cooperate with the play therapist, Cynthia B. Counsel for Father will provide two (2) weeks notice to counsel for Mother in the event that Father chooses to exercise his rights of partial custody pursuant to the schedule indicated in the October 9, 2002 Order. BY THE COURT: ./ Is} q Lo,.p~ {O~". () , I I ' J. Wesl Oler, J. Dist: Johnna J. Kopecky, Esquire, 26 W. High Street, Carlisle, PA 17013 John J. Connelly, Jr., Esquire, PO Box 650, Hershey, PA 17033 In r: ,',: :!,,:'(r~ !~!'\ ,. ,; ,,' ',,~O',,/- il ,,)r~,J rrtt~E arai thQ ".,: "h' '1~lld ,:~" ~ j r. 'J' i Oi "',:fi n.''lI ij,,,, Fa. This :l rJ. ,;~: ~~f~ {i~~ coL Prothonotary - -----"',,;-- " .. VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated:J,.; U lOA CkL~ fuCl d1t~ ~ cLUJ Christa Bradley Sn der ... , ......"~J;1'CM , OFFICE OF CHILDREN, YOUTH & FAMILIES COMMONWEALTH eF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE HARRISBURG, PENNSYLVANIA 17120 Mailing Date December 16, 2002 CHILDLlNE & ABUSE REGISTRY DEPARTMENT OF PUBLIC WELFARE HILLCREST, 2ND FLOOR ' P.O. BOX 2875 HARRISBURG, PA 17105-2875 TELEPHONE NO. (717) 783-1964 CHRISTA BRADLEY 131 MCALLISTER CHURCH ROAD CARLISLE PA 17013 Child: JASON SNYDER Report No : 210005748 Status: INDICATED Agency: CUMBERLAND COUNTY CYA DEAR MS. BRADLEY: A report of suspected abuse involving the above named child was investigated by the agency listed above. The status is Indicated. This means the agency determined that the child was abused. The report will remain on file in the state and county offices until 23 years after the child's birth. At that time, the report will be expunged. However, the information on the perpetrator will remain on file indefinitely if the social security number or date of birth is known. You are listed on the report as the Mother. You may have the right to receive services, which are intended to prevent further abuse or neglect, through the county children and youth agency. You also have the right to receive a copy of the report by writing to that agency or this office. Please refer to the report number listed above when making your request. Should your address change before the child becomes age 23, please inform this office. If you have questions about your rights, involvement in the report, or this letter; we suggest you contact the investigating agency at (717) 240-6120. Esta carta contiene informacion que es importante para usted sobre sus derechos bajo la Ley de Servicios para la Proteccion de nino. Si usted es nombrado como el perpetrador del abuso en este reporte, esto va a afectar SU oportunidad de obtener empleo en agencia 0 program a para cuido de nino y en escuela publica 0 privada. Copia de este carta es disponible en espanol. Por favor pongase en contacto con nosotros tan pronto como Ie sea posible a la direccion mecionada arriba 0 Issued by : Childline & Abuse Registry ; , I tJ N-,' IT P ~ ",,", ,~' ; ,. ".~. " ~-. "" '~,".' ~ COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE HARRISBURG, PENNSYLVANIA 17120 OFFICE OF CHilDREN, YOUTH & FAMiliES JAN 1 4 2003 CHilD liNE & ABUSE REGISTRY DEPARTMENT OF PUBLIC WELFARE HillCREST, 2nd FLOOR P.O. BOX 2675 HARRISBURG, PA 17105-2675 TELEPHONE NO, (717) 763-1964 FAX NO. (717) 772-6857 CHRISTA BRADLEY 131 MCALLISTER CHURCH ROAD CARLISLE PA 17013 Dear Ms. Bradley: We have received recent correspondence and have taken the following action: ~ D D D Enclosed is a copy of the Child Protective Services Investigation report(s) you requested. The report(s) have been redacted in accordance with the Child Protective Services Law with respect to the referral source and individuals who may have cooperated with the investigation. If you have specific questions about the findings, please contact the Child Protective Services Supervisor shown on page 2 of the report at the Cumberland County Children and Youth 717-240-6120. Based on the information available tq us, we have researched our records and it appears there are no records in our files in which your name is listed" Enclosed is a copy of the preliminary report. When the final report is received in this office, a copy will be sent to you. This is a follow-up to our previous letter in which we stated that upon receipt, a copy of the final Child Protective Services Report would be forwarded to you; that report is now enclosedo Report # is unfounded. Please note: This letter is in response to the form received in our office from the District Attorney's Office in Philadelphia. You previously completed this form in order to work with children, OTHER: ISSUED BY: ChildLine and Abuse Registry ~j;ttBl) . ,-~'~ ~ lil/ ~~lliii~~:4i1I~jjJI;;"~jfu'~!1b~'!;_~ifu"~lO~'-II;<~;~ji'iii~~~t" -',-"-' <, ~ ~f w ...0 fI) ........ ~.!iS ~ --It;;). ~ o 0' --u r -1 , _ T_~._ ~ ,. ~ _ . , ~, """",,", -:.:. >'--~~ 'M_ '.'.,. ~, o c -;:.; ~~tf; c'-:' ~~-~ f; .....'" ---, -"< Ii t: [I ,I Ii ,I Ii 'I i-I H I' I I' fl !.J i;1 :1 !I 'I 11 t:j :1 rj II !I II II II II II C:) L) X ~. ~ :. J t',,) " ~"J ~ --:J " ~r, \-) TO,);' ---1 ~y :J1 (,..> ~ -..........;.,~~- ......."""" - , w'~.~ ,~-,'", "'""~ ,A~1 '~ "f~ . CHILD PROtECTIVE SERVICE INVESTIGATION (Title 23Pa C.S.A. Chapter 63) . << REPORT ~~~, "-0 ' \1\ []J A. DATE OF INC.'OENT ongom9 between 9/01/00 and 02/23/02 s. NAME OF CHILD/STUDENT (Last, First. Middle'lnitiall Snyder, Jason D. ADDRESS Unclude Street, City. State. Zip Codel 131 McAllister Church Road, Carlisle, PA 17013 c. S,DLO I Al A. OP I 0 8st. First. Middle Initia Bradley, Christa E. ADDRESS (Include Street, City, State. Zip Code) . AG L A E PO 5 L Other,t an u lie s~x ro!"'OF SQ,CIAL SeC,URI:TY' NO. Cumberland 187-78-1560 CIAL o. 191-66-6231 vY 72 COUNTY Cumberland SOCIAL SECURITY NO. BIRTHOATE -"M , DD COUNTY Cumberland geney A 0 D ,- SOCIAL SECURITY NO. I COUNTY 81RTHDATE MM I DO vY AT SHI L rnM OF Father COUNTY BIRTHDATE MY DD vY 131 McAllister Church Road, Carlisle, PA 17013 o. BIOLOGICALlADOPTIVE FATHER Clast, First, Middle Inidall Snyder, Scott G. ADDRESS (Include Street, City, State, Zip Codel ADDRESS (Include Street, City, State, ZiP Codel F. ERPETRA TOR SCHOOL EMPLOYEE Last. First. Middle Initial Snyder, Scott G. ADDP-ESS (Include Street. City, State, Zip Codel Cumberland G. fAMILY HOUSEHOLD COM!>OSITIOIII (DO NOT COM!>LETE;, FOR STUDENT AIIUSE) NAME (Last. First. Initial) 'RELATIONSHI!> TO VICTIM NAME (Last. ~irst. Initial) Bradley, Rebecca P. Sis.t<;l:'~7F".'.' Bradle Dave MaL,.' GIf".*her.'~c::-:o-.'. Bradl ey, Sharon r1aJ;.-Grilndrl)(jthe'r RELATIONSHI!> TO VICTIM .'~,:;~1:::-! ",_.,,---,,,,~,: it," , ::-', 01 o. Welts/Ecchymosis 11 Asphyxiation/Suffocation rn Drowning 0: Fractures 07 lacerations! Abrasions 1: l'!ternaJ Injuries/Hemorr,hage '" Other 03 Skull Fractures o. Punctures/Bites 13 Dismemberment o. Subdural Hematoma 09 Brain Damage ,. Sprains/Dislocations 06 Bruises '0 Poisoning ,. Drugs/Alcohol m 2. Mental Injuries (DO NOT COM!>LETE FOR STUDENT ABUSE) 3. Sexual Abuse or Exploitation o Rape '[]I] Incest ~ Statutory Rape ~Deviate Sexual Intercourse 00 Sexual Assault ~ Promoting Prostitution o !>ornography 4. !>hysical Neglect \Do NOT. COM!>LETE FOR STUDENT ABUSE) tE Malnutrition r-:;s--l Lack ~f S.upervisio~ ~ ~edical ~eglect (r!!~uJting 26 ~ (resulting In a physical ~ In a physical condition) 27 Failure to Thrive condition) 5. Imminent Risk 100 NOT COM!>LETE FOR STUDENT ABUSE) B !>hysical Injury B DESCRIBE THE INJURIES/CON ITIONS CHECKED ABOVE PerDetrator Dull ed on assault and molestation and stuck his fin er in the child's anus molestation and a ravated indecent assault o Other @!] Sexual Abuse or Exploitation the child's penis (indecent (indecent assault, 00046A ommonwea o ennsY,y~n.! ,_ .'P.~l men (J 1I c e iII"s cv 48 . B/t$ 1~"j!llj~~il!tI.iW"IMaiEi;ir.1!tl1i<i"""#4.*~,,,.>,ml1t,H;!"'i$i..""i,,~~,"i~$&Wif,,,~~ "..i~'''%"'''M~,''"i,,''"'',___'''_~''___''''.'''_..''''_;__~'''''''''~"'''''''''''':''~,i:'____''l , 0 \" I A WAS CHILD ALLeGEDLY ABUSED WHILE IN A "CHILD CARE SERVICE" (as defined by CPSLl. B.. WAS CHILD REMOVED FROI\l1 THE ALLeGED ABUSIVE SETTING? (includes move by self, agency, others) C. WERE LAW ENFORCEMENT OFFICIALS NOTIFIED OF THIS REPORT? (CY 104 sent> DYES [] YES [] YES [X] NO o NO o NO D. SERVICES PLANNeD OR PROVIDED: {Please check the appropriate blocks. (Abbrevi.tions: PL=Planned. PR=Provided. and PERP=Perpetrator). CHILD PARENT PERP. PL/PR PL/Pll PL/PR 1J4>:4IX~IIX<l61 041 ~ Counseling CHILD PL/PR PARENT PERP. PL/PR PLlPR ~ ~ Homemaker/C.:lretaker Services r;;-r;1 r;.;T;;l Instruction and Education for L:.L_:~.~ ~ Parenthood ~ r;-T;l ~ Referral to Self-Help L.L::J ~ ~ Group ~ ~ ~ Referral to Intra-agency LL::J ~ ~ Services ~ ~ ~ ~:~r~:~ to Community PL/PR 1 40 1,- 4...,' I M"uit,' ,i,di,SCi,P, ,I,inarv Team ~ 'Case R~vlew G Emergency Medical Care ~~ EG Other o No Services ~Ianned or provi~ed t,; " d ,:! ~:~ PENOING JWENlLE COURT ACTION (Updated PENDING ,CRIMINAL COURT ACTION CV 48 required when court action completed) ~~~i~~e~o~Y I~~drequired when court r;n INDICATED, 1.0, Medical Evidence 2.m CPS Invesiigation 3.'0' Perp,:,tr~or D. t:..J (If che~ked. answer 1. 2, or 3) L.:.:J AdmiSSion 'i i 'I E. 0 UNFOUNDED PLEASE EXPLAIN IN DETAIL THE BASIS FOR THE CASE STATUS YOU CHECKED AND SPECIFY CRIMINAL ACTION, The indicated status is supported by the consistent description by the child, his mother, maternal grandmother, other vari ous re 1 ati ves and fami 1 y fri end$, therapi st, and caseworker of the sexual acts that occurred. The perpetrator had ample access to the child during his court ordered visitations. The child exhibits behaviors during play therapy consistent with children who are sexually abused. A criminal investigation has begun but has yet to be concluded. c~/;~ " roll ",_'.JI'.". ,\',.. )' : i ' / ~ ' WAS THERE A RELIGIOUS BASIS FOR CHILD'S CONDITION? (Applicable only if E is c:hecked) DYES D NO DID THE CHILD DIE AS A RESULT OF THIS INCIDENT OF ABUSE/NEGLECT?' (Applicable oniy if C or 0 is checked) NO _,)': ,1''I#lillI:m'fr ',:r" Please check ts: ms:,y as three factors and rank them in order of re.levance (" 1" being most relevant). Evidence -musi exist to confirm the selection of the factor(s) which appears to contribute to abuse. D SUBSTANCE ABUSE lINCLUDES DRUGS. CHEMICALS, ALCOHOL, ETC.) D STRESS jDUE TO FINANCIAL PROBLEMS, UNEMPLOYMENT. DIVORCE, ETC.) o MA:RGINAL PARENl"AL SKILLS OR KNOWLEDGE (INCLUDES UNREALISTIC EXPECTATIONS, LIMITED KNOWLEDGe OF CHILDHOOD DEVELOPMENT, ETe) o VULNERABILITY OF CHilD (DUE TO CHILD'S AGE, PHYSICAL LIMITATION, DEVELOPMENTAL DELAYS, ETC.) D seXUAL DEVIANCY OF PERPETRATOR (BASeD ON A DIAGNOSIS OR CRIMINA1. CONVICTION) D ABUSE BETWEEN PARENT FIGURES (HISTORY OF FIGHTING BETWEEN PARENTS OR PARENT SUBSTITUTES) o INSlJF!=tC!ENT FAMILV{:;OCiAL SUPPORT (SUCH AS FAMILY AND FRIENDS UNAVAILABLE TO HELP WITH FAMILY OR PERSONAL NEEDS) o IMPAIRED JUDGEMENT OF PERPETRATOR (CAUSED BY PHYSICAL. MENTAL OR EMOTIONAL LIMITAtiONS) o PERPETRATOR ABUSED AS A CHILD PAGE 2 )00465 '\.. i~ ,1 -!C--r./,~ INVESTIGATING COUNTY Cumberland -~a~li9tk'li{",cl;~~itij.iliWMdWW CHiLClINE WORKER Zid:.! COUNrY WHERE ABUSE OCCURREO Cumberl and COUNTY AGENCY WORKER Audra Hennessey COUNTY AGENCY SUPERVISOR Edward Rouse ,lir, ,.w ""'Y"'f ---" CY 48 . 6/95 ;,',.,;f '-if ' ~ . ... CHRISTA BRADLEY SNYDER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00-5705 CML TERM SCOTT GREGORY SNYDER, Defendant : CML ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this ~ day of ~ lJ.l) (' , 2003, based upon the attached , I , , ! , ! I i Stipulation of the parties, Christa Bradley Snyder, PlaintiffiMother, and Scott Gregory Snyder, Defendant/Father, parents of Jason David Snyder, and stipulating as per agreement, primary legal and physical custody of the minor child, Jason David Snyder, born April 11, 1999, is hereby awarded to Christa Bradley Snyder, PlaintiffiMother. Any visitation/custody rights given to the Defendant/Father, Scott Gregory Snyder, must be specifically set forth by a future Order of this Court. BY THE COURT: 1. j\~~ ~Jf\ ~~ C), OJ C)\,' \ \ '- -,' '" .. , , ",,-- --.- ,'~. ' V!\I'/~I 'M V Ii ~~;/ l '/\,":\ 1/0... l:Jd I !!_ :f'" "_'," :.: ~)! \Ji'_J I\.U\! Ir__).._~ : i:--:i,r~H::'I::}1Nn:) - -, "~ J 11 J i\:; :t.: lid 6- Nilf SO Ab\iJ.C\:_;HCiJ;~!!.L :10 30tj:~O-Dj"{j3 ' ~ "~ ,,~" " .~- ~ 0', ,t-.:;) I I ! i ~^ " ~ ~J ~';,',"",'""',"."'"",.",..":,.,,.,,,. ~>__-__,_ _ -,'d l"-- n",,-," I . .",' , . CHRISTA BRADLEY SNYDER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-5705 CIVIL TERM SCOTT GREGORY SNYDER, Defendant : CIVIL ACTION - LAW : IN CUSTODY CUSTODY STIPULATION WHEREAS, Christa Bradley Snyder, Plaintiffi'Mother, and Scott Gregory Snyder, Defendant/Father, are the parents of Jason David Snyder, born April 11, 1999; and WHEREAS, a custody conciliation on this matter was scheduled for May 12, 2003 at 11:00 a.m. before Melissa P. Greevy, Esquire; and WHEREAS, the parties wish to enter a Stipulation to resolve the pending action. WHEREAS, it is the desire of the parties to enter into the following Custody Stipulation. NOW THEREFORE, the parties mutually agree as follows: 1. The Plaintiff is Christa Bradley Snyder, an adult individual, residing at 131 McAllister Church Road, Carlisle, Cumberland COU..'lty, Pennsylvania. 2. The Defendant is Scott Gregory Snyder, an adult individual, residing at 513 8th Street, New Cumberland, Pennsylvania. 3. The parties are the natural parents of Jason David Snyder, date of birth April 11, 1999. 4. The parties are now subject to an Order of Court dated October 9, 2000, which is attached hereto and marked Exhibit "A", whereby the Plaintiff has primary physical custody of the """,,,,~,,"-,,,-,j---~ --,"-'. j, . minor child subject to periods of partial physical custody of the Defendant. The parties are also subject to a subsequent Order dated March 29, 2002 attached hereto and marked Exhibit "B". 5. The Defendant has not been exercising any physical custody or contact with Jason David Snyder. 6. It is agreed to by both parties that primary legal and physical custody of Jason David Snyder is awarded to the PlaintifflMother, Christa Bradley Snyder. Any visitation/custody rights given to Scott Gregory Snyder, Defendant/Father, must be specifically set forth in a future Order of this Court. 7. The Plaintiff and Defendant respectfully request Your Honorable Court to enter an Order as written and attached to this Stipulation. WHEREFORE, the parties hereto set forth their signatures intending to be legally bound. 9/ii~ 1 ess e ~Ybc~~~~ Christa Bradley Snyder ',. 11)1: ~~oko-, Scott Gregory Snyder ,-,- c_co,.,' . ".".<- . ."".j "".~ ,-,;- ~,-- I I ~Cl 0 0 ,~ c: ~."~ ~ ""n ~ S:: -orA_1 fTl-rT: -..", 'T' Z ~I-;. .,...- {";:;:; Z , rOll 51 '. - C"J - r.::o C , CJ ~ _riJ -'f " :~-~~~ -1'1 o~., ,r': _....-, (-.;:;;; '7 c-.: $;- .- - <;::, f'J (5 I'D -1 ~1 ~0 ;;.> -<~ ....l ::0 -< ^~ " ~~ ., """",000f~~~~._-"",~~~;?,': Plaintiff JUN u 9 Z003 (/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5705 CIVIL TERM CHRISTA BRADLEY SNYDER, v, SCOTT GREGORY SNYDER, CIVIL ACTION - LAW IN CUSTODY Defendant ORDER TO RELINQUISH JURISDICTION AND NOW, this 6th day of June, 2003, the parties having reached an agreement which has been memorialized in a Stipulation and filed with this Court, the Conciliator hereby relinquishes jurisdiction of the above captioned matter. ::RTH:?~~ ~ssa Peel Greevy, Esquire Custody Conciliator :214402 ~ ...'=' ",..oL~.; ~ 0 ~ ~~~"'~~~~!'<iMjd@";1;'''{''!.'C';';'''''iLi!-''''''~,o.!'<3.<!-~'_~iH-S;i;iR~'icll'I,!1i;~~ -,- - e~_ _ ~" _ ~_~~" ,o...^~.~_ - -.~--" e,""' 0' -- '.' .-.< d ~ e ~., _ .' .'''~,'_" , . c'5 c ~ n"U1 Cfi r,i 2-;-; 2( C/) ;0' ;:c;, ~~' ;;;:r ~~' =U ""'C Z :;! --'~ __lIIiIiIl!I!I <=:, (,0 '- c: ~ <::> c) __J """ ::r rJ~ Orn '-1 2? :rJ -< S? U1 <::l 1, if l t l; [ i I I I , ~ , . ",~r:; .of '-... ... CHRISTA BRADLEY, formerly known as, CHRISTA SNYDER, Plaintiffi'Respondent v. : IN TIlE COURT OF COMMON PLEAS , : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-5705 CML TERM SCOTT GREGORY SNYDER, DefendantJPetitioner : CIVIL ACTION - LAW : IN CUSTODY PRAECIPE TO WITHDRAW PETITION TO MODIFY CUSTODY , TO THE PROTHONOTARY: Please withdraw the Petition to ModifY of Custody filed on February 19, 2004 in the above- captioned action on behalf of the DefendantJPetitioner, Scott Gregory Snyder. JAMES, SMIill, DlETTERlCK & CONNELLY Date: .3 -9-()/f - =-',,-,-, ,"_, _'f>-'-~=' -. "~,",,,,. ='-',''''- -"-,, -."'-" ,- --,i' '-~'1'm: .., .... CHRISTA BRADLEY, formerly known as, CHRISTA SNYDER, PlaintiIDRespondent v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-5705 CIVIL TERM SCOTI GREGORY SNYDER, Defendant/Petitioner : CIVIL ACTION - LAW : IN CUSTODY CERTIFICATE OF SERVICE I, John 1. Connelly, Jr., Esquire, of James, Smith, Dietterick & Connelly, attorney for the Defendant/Petitioner, Scott Gregory Snyder, hereby certifY that I have served a copy of the foregoing Praecipe to Withdraw Petition to ModifY of Custody on the following on the date and in the manner indicated below: U.S MAlL, FIRST CLASS, PRE-PAID Herbert Corky Goldstein, Esquire 204 State Street P.O. Box 10363 Harrisburg, P A 17105-0363 JAMES, SMITH, DIETTERICK & CONNELLY Date: j -q-O+ '. ~' ~.-,~ ~ ><-=-,-- " o ~ ~~'l' ~0J;' l-~ ::c.'- ~::..~-l __' ~ ~~~~ :c: ~ i -~ .i ,"- "" c;? c-:> .C- ~ ~ :;;.;J o .T1 --1 rR:TI ,- -on"'"' --"0 O-T --4() ~::f-i '::o-~r ?')rrl ~-=l o~ ~~ -0 -'" '.>? w \l "". , . ---.- , ,'~ "llii- MAR t'20~ CHRISTA BRADLEY, F/KlA CHRISTA SNYDER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5705 CIVIL TERM v. CIVIL ACTION - LAW SCOTT GREGORY SNYDER, IN CUSTODY Defendant ORDER TO RELINQUISH JURISDICTION AND NOW, this 15th day of March, 2004, counsel for the DefendanUPetitioner having filed a Praecipe to Withdraw Petition to Modify Custody in this action, the Conciliator hereby relinquishes jurisdiction of the above captioned matter. ~; elissa Peel Greevy, Es uire Custody Conciliator :225521 '.,co. B:~ 1;";:'" ,e-:=; \~~~~ '__L),--", (,'Q 09;- 0..;<-- 'r-fi..\.! o,..;-:!- y- '6 ,'. .~.,. ~~ c0 o :::r ..,.- <,''''' 0- Cf> - ." "Y ~ .:~J ,,:C I ;.:;~" ::'~3~ c' .%:1: ~~ .- -& ~ . ,"" ,-'. "'"~ ~:...\ 7;:, '~t \'~ ~:: c.,;; _'0 _,.;'n__ ,-,;",,' .-~-."~: ~--~ ~, - . --,,",,~-"~' ", -, .