HomeMy WebLinkAbout00-05715
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SARAH M. SNYDER and
DANIEL LEE ROUNER
Plaintiffs
Vs.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 2000- 57/S~ CIVIL TERM
: IN CUSTODY
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DEBORAH K ROUNER and
DAVID T. ROUNER, SR.
Defendants
ORDER
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And now this (J day of August, 2000, the attached Custody Agreement of
the parties is hereby incorporated as an Order of Court.
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SARAH M. SNYDER and
DANIEL LEE ROUNER
Plaintiffs
Vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY: PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000- CIVIL TERM
IN CUSTODY
DEBORAH K. ROUNER and
DAVID T. ROUNER, SR.
Defendants
CUSTODY AGREEMENT
The parents and paternal grandparents of Austin Robert Snyder-Rouner born,
May 1, 2000, enter into this agreement in regard to the custody of Austin Robert
Snyder-Rouner. The parties agree that Deborah K. Rouner and/or David T. Rouner,
Sr., shall have primary physical custody of Austin. The parents, Sarah M. Snyder and
Daniel Lee Rouner, shall have times of partial physical custody as the parties may
agree to from time to time. The parents agree, that in the event they are unable to
establish a joint household for themselves, to co-operate and attend counseling in
order to establish custody and partial custody schedules. If the parents establish their
own joint household and are employed, within the next year, the paternal grandparents
agree that they will relinquish custody of Austin to the parents. In the event of a conflict
between the parties they agree to submit to conciliation prior to requesting a judicial
determination.
The parties agree that they will inform each other if they intend to take Austin out
of the area and provide an address and phone number where they can be reached.
The parties agree that they will not disparage or speak unkindly of one another irt-
Austin's presence and will make it their goal to cultivate Austin's love and respect for
each parent and grandparent. The parties further agree that they will share legal
custody of Austin.
The parties agree that this Custody Agreement shall be incorporated as an
Order of Court.
IN WITNESS WHEREOF, the parties, hereto, intending to be legally bound,
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have hereby affixed their hands and seals to this Custody Agreement, this ~ day of
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WITNESS:
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SARAH M. S DER,' '-
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DANIEL LEE ROUNER
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DAVID T. ROUNER, SR.
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SARAH M. SNYDER and
DANIEL LEE ROUNER
Plaintiffs
Vs.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 2000- CIVIL TERM
: IN CUSTODY
DEBORAH K. ROUNER and
DAVID T. ROUNER, SR.
Defendants
, COMPLAINT FOR CUSTODY
1. Plaintiffs are Sarah M. Snyder, a minor, and Daniel Lee Rouner, an
adult individual, both residing at 561 Criswell Drive Ext., Bailing Springs, PA 17007,
Cumberland County, Pennsylvania.
2. Defendants are Deborah K. Rouner and David T. Rouner, Sr.,
husband and wife, both adult individuals who also reside at 561 Criswell Drive Ext.,
Boiling Springs, PA 17007, Cumberland County, Pennsylvania.
3. Plaintiffs and Defendants wish to enter a custody agreement in
reference to custody of the following child: Austin Robert Snyder-Rouner, age 2
months, born May 1, 2000.
The child was born out of wedlock.
The child is presently in the custody of all the parties, while they reside in
the same home.
During the past five years, or since the child's birth, he has resided with
the all the parties.
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4. The relationships of the Plaintiffs to the child are those of natural
father and natural mother.
5. The relationship of the Defendants to the child is that they are the
paternal grandparents.
6. The parties have not participated as a party or witness, or in any other
capacity in other litigation, concerning the custody of the child in this or in any other
Court.
Plaintiff does know of a person not a party to the proceedings who has
physical custody of the child or claims to have custody or visitation rights with respect
to the child.
7. The best interest and permanent welfare of the child will be served by
a Court Order confirming primary custody of the child with the Defendants with the
parents to have times of partial physical custody as the parties are able to agree to.
The parents agree that in the event they are unable to establish a joint household for
themselves, that they agree to co-operate and attend counseling in order to establish
custody and partial custody scheduleso If the parents establish their own joint _
household and are employed, within the next year, the paternal grandparents agree
that they will relinquish custody of Austin to the parents. In the event of a conflict
between the parties they agree to submit to conciliation prior to requesting a judicial
determination.
8. Each parent whose parental rights to the child have not been
terminated and the person who has physical custody of the child have been named as
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parties to this action. All other persons, named below, who are known to have or claim
a right to custody or visitation of the child will be given notice of the pendency of this
action and the right to intervene.
NAME
ADDRESS
BASIS OF CLAIM
None
9. The parties agree that they have requested that Robert L. O'Brien, Esquire,
place their agreement in a format suitable for the entry of an appropriate Court Order
confirming custody in the paternal Grandparents, and that he has not represented any
of the parties in this matter.
WHEREFORE, Plaintiff requests your Honorable Court to enter the
parties agreement as a Court Order.
Respectfully submitted,
Date: '6/;0.1 DO
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Robert L. O'Brien, Esquire
O'BRIEN, BARIC & SCHERER
17 West South Street
Carlisle, PA 17013
(717) 249-6873
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I verify that the statements made in the foregoing Complaint for
Custody are true and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to
authorities.
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SARAH M. SNYDER
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SARAH M. SNYDER AND DANIEL LEE ROVNER:
PLAINTIFF
V.
DEBORAH K. ROVNER AND DAVID T,
ROVNER, SR.
DEFENDANT
IN TIIE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
00-5715 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW,
Monday, August 06, 2001
, 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 214SenateAvenue,Suitel05,CampHill,PA 17011 on Monday, September 10,2001 at 11:00 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 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 auy and all existing Protectiou from Abuse orders,
Special Relief orders, and Custody orders to the couciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: Isl
Melissa P. Greevy. Esq.M
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 TO YOUR ATIORNEY AT ONCE. IF YOU DO NOT
HA VB AN ATIORNEY 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
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CUMBi:FiLAi~O COUN1Y
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SARAH M. SNYDER and
DANIEL LEE ROVNER,
Plaintiffs
IN THE COURT OF COMMON PLEAS,
CUMBERLAND COUNTY,
PENNSYLVANIA
:
,
v.
No. 2000 - 5715 - CIVIL TERM
DEBORAH K. ROVNER and
DAVID T. ROVNER, Sr.,
Defendants
CNIL ACTION- CUSTODY
ORDER of COURT
AND NOW, this day of ,2001, upon due
consideration of the attached Complaint in Custody, it is hereby ORDERED and
DECREED that the parties and their respective counsel appear before
,Esquire, the Conciliator, at the . on the
day of ,2001 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 (5) or
older shall be present at the conference. Failure to appear at the conference may provide
grounds for a temporary or pennanent order.
FOR TIlE COURT:
By:
Custody Conciliator
YOU SHOULD TAKE TIDS PAPER TO YOUR LAWYER 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 COURT ADMINISTRATOR
FLOOR 3A
CUMBERLAND COUNTY COURTHOUSE
1 COURTHOUSE SQUARE
CARLISLE, P A 17013
(717) 240-6200
SARAH M. SNYDER and,
DANIEL LEE ROUNER,
Plaintiffs
:
IN TIIE COURT OF COMMON PLEAS,
CUMBERLAND COUNTY,
PENNSYLVANIA
v.
No. 2000 - 5715 CML TERM
DEBORAH K. ROUNER and
DAVID T. ROVNER, Sr.,
Defendants
CNIL ACTION- CUSTODY
. ..If, J'_ Complaint for Custody
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AND NOW, ".j:J day orb. 2001 """" DEBORAH K ROVNEB ond
DAVID T. ROUNER, Sr., husband and wife., Defendants above named, by and through
his attorney, John M. Glace, Esquire, joined by above named Plaintiff DANIEL LEE
ROUNER and respectfully presents the below Complaint for Custody, and , in support
thereof, avers the following:
I, Plaintiff, SARAH M SNYDER, is a adult individual, who presently resides at
different locations in Cumberland County and, upon knowledge and belief resides at
divers times at 371 C Street, Carlisle, Cumberland County, P A with an individual known
to Movants as Nathan Wright and sometimes with her parents, Randy and Kathy Snyder,
Jr. at 48 Searer Run Road, Newville, Cumberland County, P A and sometimes with her
grandparents who reside in the Borough of Carlisle..
2. Plaintiff DANIEL LEE ROUNER is an adult individual, who now joins this
Complaint as a Movant, resides at 180 Old State Road, Gardners, Cumberland County,
PA
3. Defendants DEBORAH K ROUNER and DA VID T. ROUNER, Sr. are adult
individuals, who have resided for all times relevant to this Complaint at 180 Old State
Road, Gardners, Cumberland County, P A.
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4. Plaintiffs SARAH M SNYDER and DANIEL LEE ROVNER are the biological
parents of AUSTIN ROBERT SNYDER-ROVNER (DaB: May 1, 2000) and Defendants
DEBORAH M ROVNER and DA VlD T. ROVNER, Sr. are the paternal grandparents of
said minor child.
5.. The above minor child was born out of wedlock. At that time Plaintiff resided
with Defendants DEBORAH M ROVNER and DAVID T. ROVNER, Sr.; but she left that
residence almost immediately after the birth of the minor child, in effect abandoning said
child to the care of his paternal grandparents, the Defendants. Defendants thereafter have
provided primary care and sustenance to the child for the entirety of his life.
6. Due to Plaintiffs life choices, lack of pennanent address, lack of mature and
responsible child-rearing skills and general lack of insight, a Custody Agreement was
negotiated and executed on August 9, 2000 wherein primary custody of the minor child
was granted for a term of one (1) year only to above Defendants, the paternal
grandparents with certain lllutually agreed requisites for the Plaintiffs. This Agreement,
which was subsequently ratified by this Honorable Court, is attached hereto as Exhibit
"A" and made part hereof.
7. Subsequent to this Agreement's ratification, Plaintiff DANIEL LEE ROVNER
has returned to his parent's house and resides there with his son. He is fully compliant
with the Custody Agreement's directives
8. Plaintiff SARAH M SNYDER however has not established a permanent
address. Additionally, she has not attended any counseling as specifically required by the
August 9, 2000 Custody Agreement (Exhibit "A''). Plaintiff SARAH M SNYDER has
been discharged from several different jobs that she has held, been arrested several times
for summary offenses, continued to drink to excess and ingest unlawful drugs, failed to
establish any permanent address and engaged in multiple sexual relationships.
9. Because of the above described circumstances, Plaintiff SARAH M SNYDER
has only been permitted supervised visits with her son at her grandparents residence in
the Borough of Carlisle, her parents' residence in Borough of Newville and the Plaintiff's
house near Gardners, P A. Her attendance at these arranged supervised visitations has
been sporadic. At the times she did attend these arranged visitations, she did not
demonstrate any appreciable parenting skills.
10. Upon knowledge and belief, Plaintiff SARAH M SNYDER is pregnant
11. Defendants DEBORAH M ROUNER and DA VID T. ROUNER, Sr. seek to
extend indefinitely the existing Custody Agreement ( Exhibit "A") as it relates to Plaintiff
SARAH M SNYDER because she has not complied with any of the terms of said
Agreement and has, in point of fact, continued to demonstrate irresponsible and
deleterious behavior as to her own person and clearly does not possess the insight nor the
ways and means to support and nurture her minor son.
12. It is in the best interests of the minor child to continue the existing Custody
Agreement ( Exhibit "A") indefinitely until such time as the Plaintiff fully complies with
its terms and demonstrates the desire and ability to be granted any custody rights.
13. Each parent, whose parental rights have not been terminated, has been made
party to this action.
WHEREFORE, above Defendants Deborah K. Rouner and David To Rouner,
Sr. joined by Plaintiff Daniel Lee Rouner respectfully requests this Honorable Court to
extend indefinitely the Custody Agreement until such time as the Plaintiff Sarah M.
Snyder can demonstrate she has fully complied with the terms of the original Agreement
and that the health and welfare of the minor child would not be jeopardized by any
custody grant.
Respectfully Submitted,
of JOHN M. GLACE
ace, Esquire
ill: 23933
alnut Street
Hanisb 17101-1612
(717) 238-55
Attorney for Defendants and joined Plaintiff
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Vs.
DEBORAH K ROUNER and
DAVID T. ROUNER. SR.
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNlY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 2000- 516 CIVIL TERM
: IN CUSTODY
SARAH M. SNYDER and
DANIEL LEE ROUNER
Plaintiffs
CUSTODY AGREEMENT
The parents and paternal grandparents of Austin Robert Snyder-Rouner born,
May 1, 2000, enter into this agreement in regard to the custody of Austin RQbert
Snyder-Rouner. The parties agree \hat Deborah K Rouner and/or David T. Rouner,
Sr., shall have primary phy$icalcustody of Austin. The parents, Sarah'M. Snyder and
Daniel Lee Rouner, shall have times of partial physical custody as the parties may
agree to from time to time. The parents agree. that in the event they are unable to
establish a jOint household for themselves, to co-operate and attend counseling in
order to establish custody and partial custody schedul8l!. '!the parents establish their
own jOint household and are employed. within the next year. the paternal grandparents
agree that they will relinquish custody of Austin to tne parentS, In the event Of II '-'lo'lflict
between the parties they ~,..... to "'I\lmit to conclIlauon ptlor to requesting a judicial
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determination,
The parties agree that they will inform each other if they intend to take Austin out
of the area and provide an addren and phone number where they can be reached.
The parties agree that they will not disparage or speak unkindly of one another in-
Austin's presence and will make it their goal to cultivate Austin's love and respect for
each parent and grandparent. The parties further agree that they will share legal
custody of Austin.
The parties agree that this Custody Agreement shall be incorporated as an
Order of Court,
IN WITNESS WHEREOF. the parties, hereto, intending to be legally bound,
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have hereby effiXecl their hands and seals to this Custody Agreement, this ~ day of
Au~~ ,2000.
WITNESS: .
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SARAH M. . DER
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DANIEL LEE ROUNER
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DAVID T. ROUNER, SR.
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VERIFICATION
The Undersigned hereby verifies that the facts averred in the foregoing Petition to
Modify Custody Order are true and correct to the best of his knowledge, information,
and belief.
This verification is made subject to the penalties of 18 Pa C.S.A., Section 4904
relating to unsworn falsification to authorities.
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Daniel Lee Rouner
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VERIFICATION
The Undersigned hereby verifies that the facts averred in the foregoing Petition to
Modify Custody Order are true and correct to the best of her knowledge, information,
and belief.
This verification is made subject to the penalties of 18 Pa C.s.A., Section 4904
relating to unsworn falsification to authorities.
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Deborah . Rouner
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VERIFICATION
The Undersigned hereby verifies that the facts averred in the foregoing Petition to
Modify Custody Order are true and correct to the best of his knowledge, information,
and belief.
This verification is made subject to the penalties of 18 Pa. C.S.A., Section 4904
relating to unsworn falsification to authorities.
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David T~Rouner, Sr.
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I HEREBY CERTIFY that this day ,2001 I have served a true and
correct copy of the foregoing Complaint for Custody, by First Class Mail, Postage
Pre-paid, upon:
Sarah M. Snyder
c/o Nathan Wright
371 C Street
Carlisle, PA 17013
Sarah M. Snyder
c/o Randy and Kathy Snyder
48 Searer Run Road
Newville, PA 17241
Robert 1. O'Brien, Esquire
O'BRIEN, BARIC & SHEARER
17 West South Street
Carlisle, P A 17013
LAW OFFICES of JOHN M. GLACE
. Glace, Esquire
Walnut Street
,PA.17101-1612
1 ) 238-5515
Identification No. 23933
Counsel for Defendants/joined
Plaintiff
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that this day of July, 2001 I have served a true and
correct copy of the foregoing Complaint for Custody, by First Class Mail, Postage
Pre-paid, upon:
Sarah M. Snyder
c/o Nathan Wright
371 C Street
Carlisle,PA 17013
Sarah M. Snyder
c/o Randy and Kathy Snyder
48 Searer Run Road
Newville, P A 17241
Robert L. O'Brien, Esquire
O'BRIEN, BARIC & SHEARER
17 West South Street
Carlisle, P A 17013
LAW OFFICES of JOHN M. GLACE
John M Glace, Esquire
132-134 Walnut Street
Harrisburg, PA. 17101-1612
(717) 238-5515
Identification No. 23933
Counsel for Defendants/joined
Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SARAH M, SNYDER AND
DANIEL lEE ROUNER,
vs.
NO^ 00-5715
DEBORAH K. ROUNER AND
DAVID T. ROUNER, SR.,
CIVIL ACTION - LAW
CUSTODY
Defendants
TEMPORARY ORDER OF COURT
AND NOW, this ^ rr. day of ~y~ ,2001, upon consideration
of the attached Custody Conciliation Summary Rep rt, it is hereby ordered and directed as
follows:
1. Legal Custody. Daniel Lee Rouner and Sarah M. Snyder shall have shared legal
custody of the minor Child, Austin Robert Snyder-Rouner, born May 1, 2000. 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 PR C. S^s
5309, each parent shall be entitled to all records and information pertaining to the Child
including, but not limited to, medical, dental, religious or school records, the residence address
of the Child 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. Primary physical custody shall be with the Father, Daniel Lee
Rouner, and the Paternal Grandparents, Deborah K. Rouner and David T. Rouner, Sr. Partial
physical custody shall be with. the Mother, Sarah M. Snyder, each weekend from Friday at
Noon until Sunday at 7:00 p.m.
3. Transportation. Father shall arrange transportation of the minor Child to the
Maternal Grandparents' home for the exchange of custody. Transportation back to the
Paternal Grandparents and Father shall be provided by the Mother.
4. Holidays. Custody for the holidays shall be shared by the parties at such times as
they may agree.
5. Mother shall participate in a chemical dependency evaluation and shall comply with
any treatment and/or abstinence recommendations made by the evaluator. The cost of the
evaluation, if any, shall be born by the Mother.
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SARAH M. SNYDER AND
DANIEL LEE ROUNER,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
vs.
NO. 00-5715
DEBORAH K. ROUNER AND
DAVID T. ROUNER, SR.,
CIVIL ACTION - LAW
CUSTODY
Defendants
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
Austin Robert Snyder-Rouner May 1, 2000
Father and Paternal Grandparents
2. A Custody Conciliation Conference was held on September 10, 2001, with the
following individuals in attendance: the Paternal Grandparents, Deborah K. Rouner and David
T. Rouner, Sr., and the Father, David T. Rouner, and their counsel, John M. Glace, Esquire;
the Mother, Sarah M. Snyer, and her counsel, Carol J. Lindsay, Esquire.
3. The parties reached an agreement in the form of an Order as attached for a
temporary custodial plan.
9/; sID I
Date
.
No. 00-5715 Civil Term
6. No party having physical custody of the minor Child shall consume alcohol on any
day in which they have custody of the Child. Neither may they possess or use illegal drugs
during their period of custody.
BY THE COURT,
./J
J.
Dis!: John M. Glace, Esquire, 132:134 Walnut Street. Harris urg, PA 17101-1612 _':?r
Carol J. Lindsay, Esquire, 26 W. High Street, Cartisle; PA 17013 ~.
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