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HomeMy WebLinkAbout00-06279SHERRY L. SNYDER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. TODD OGDEN DEFENDANT 00-6279 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 22nd day of September , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear beforeMelissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 24th day of October , 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 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. FOR THE COURT, By: /s/ Melissa P. GreevY. EsQ-_ 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 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 Mf i ? ?'2i !r1 3: ? CUNIBLF+--l NCI COUNTY PENNSYLVANIA eld- SEP 15 2000 o SHERRY L. SNYDER, : IN THE COURT OF COMMON PLEAS OF Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. pp G27q 1.1 U r TODD OGDEN, : CIVIL ACTION - CUSTODY L Respondent ORDER OF COURT You, TODD OGDEN, are ORDERED to appear at on at o'clock a.m./p.m. for a Custody Conciliation 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 issue to be heard by the Court, and to enter into a Temporary Order. All children age five or older may, at the request of either attorney or party, be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. If you fail to appear as provided by this Order, an Order for custody may be entered against you or the Court may issue a warrant for your arrest. 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 Legal Services 7 North Hanover Street Carlisle, PA 17013 (717) 243-9400 Custody Conciliator: DATE: SHERRY L. SNYDER, : IN THE COURT OF COMMON PLEAS OF Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 0-o - G 2-'79 7-ez- TODD OGDEN, : CIVIL ACTION - CUSTODY Respondent COMPLAINT FOR CUSTODY The Petitioner is Sherry L. Snyder, a citizen of Pennsylvania, residing at 150 Wyoming Avenue, Enola, Cumberland County, Pennsylvania, 17025. 2. The Respondent is Todd Ogden, a citizen of Pennsylvania, residing at 3324 Derry Street, Harrisburg, Dauphin County, Pennsylvania, 17111. 3. Petitioner seeks custody of the following child: Name Present Residence Age Amanda Ogden 150 Wyoming Avenue 1 Year Enola, Pennsylvania 17025 The child is presently in the custody of Petitioner, Sherry L. Snyder, who resides at 150 Wyoming Avenue, Enola, Cumberland County, Pennsylvania. From the date of birth, the child has resided with the following persons and at the following addresses: From To With Whom Address 6/11/99 10/16/99 Petitioner & Respondent 3324 Derry Street Harrisburg, Pennsylvania 10/16/99 10/20/99 Petitioner & Rick Powell 150 Wyoming Avenue Enola, Pennsylvania 10/20/99 1/4/00 Petitioner & Respondent 3324 Derry Street Harrisburg, Pennsylvania 1/4/00 2/10/00 Petitioner 150 Wyoming Avenue Enola, Pennsylvania 2/10/00 5/22/00 Petitioner & Respondent 3324 Derry Street Harrisburg, Pennsylvania 5/22/00 Present Petitioner 150 Wyoming Avenue Enola, Pennsylvania 4. 5. 6. 7 8. 9. Amanda Ogden was born out of wedlock. The mother of the child is Sherry L. Snyder, currently residing at 150 Wyoming Avenue, Enola, Cumberland County, Pennsylvania, 17025. She is not married. The father of the child is Todd Ogden, currently residing at 3324 Derry Street, Harrisburg, Dauphin County, Pennsylvania, 17111. He is not married. The relationship of Petitioner to the child is that of mother. The Petitioner currently resides with the parties' child. The relationship of Respondent to the child is that of father. The Respondent currently resides alone. Respondent has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Petitioner has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Petitioner does not 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. The best interest and permanent welfare of the child will be served by granting the relief requested because she offers her child a more stable and secure environment. 10. 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 parties to this action. WHEREFORE, Petitioner requests the Court to grant custody of the child. DATE: `I 11 fJv a ence J. osen, Esquire Attorney for Plaintiff 1101 North Front Street Harrisburg, Pa 17102 ID # 10625 (717) 234-4583 SHERRY L. SNYDER, : IN THE COURT OF COMMON PLEAS OF Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. TODD OGDEN, : CIVIL ACTION - CUSTODY Respondent VERIFICATION I, SHERRY L. SNYDER, hereby verify that the information contained in the foregoing Complaint is true and correct to the best of our knowledge, information and belief. I also understand that false statements made herein are subject to the penalties of 18 Pa. C.S. § 4904, relating to sworn falsification to authorities. DATE: SHERRY L. SNY SHERRY L. SNYDER, : IN THE COURT OF COMMON PLEAS OF Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. TODD OGDEN, : CIVIL ACTION - CUSTODY Respondent CERTIFICATE OF SERVICE AND NOW, this ? day of September, 2000, I, Lawrence J.Rosen, for the Law Firm of Krevsky & Rosen, P.C., attorneys for Petitioner SHERRY L. SNYDER, hereby certify that I have this day served a copy of the Complaint via First Class U.S. Mail, Certified Mail on the following: TODD OGDEN 3324 DERRY STREET HARRISBURG, PA 17111 Harrisburg, PA 17102 (717) 234-4583 SAL--? OCT 2 6 20QQJ SHERRY L. SNYDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 00-6279 TODD OGDEN, : CIVIL ACTION - LAW Defendant : CUSTODY ORDER OF COURT AND NOW, this .? I/W day of ©417to'Ll , 2000, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Sherry L. Snyder and Todd Ogden, shall have shared legal custody of the minor Child, Amanda Ogden, born June 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 her 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. The Mother shall have primary physical custody subject to Father's rights of partial physical custody at such time and places as the parties shall agree. BY W, J Dist: Lawrence J. Rosen, Esquire 1101 North Front Street, Harrisburg, PA 17102 \ o© Todd Ogden 3324 Derry Street Harrisburg, PA 17111 ^ ? 0 OF ' " NARY 0U U?1 010:37 CU VIBL-1,Lj NdL) CQUN Y PENNSYLVANIA SHERRY L. SNYDER, Plaintiff Vs. TODD OGDEN, 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: IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-6279 : CIVIL ACTION - LAW : CUSTODY 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Amanda Ogden June 11, 1999 Mother 2. A Conciliation Conference was held on October 24, 2000, with the following individuals in attendance: the Mother, Sherry L. Snyder, and her counsel, Lawrence J. Rosen, Esquire; the Father, Todd Ogden, who appeared pro se , 3. The parties reached an agreement in the form of an Order as attached. Date Lar ` C? Melissa Peel Greevy, Esquire Custody Conciliator SHERRY L. SNYDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No: 00-6279 : CIVIL ACTION -LAW TODD OGDEN, : CUSTODY Defendant PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Todd Ogden, with regard to the above-captioned matter. Respectfully submit)6d, NEALON GOVE,R & By: James G. Nealon, III, Esquire I.D. #: 46457 NEALON GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 Date: 3 717/232-9900 CERTIFICATE OF SERVICE AND NOW, this day of March, 2008, 1 hereby certify that I have served the foregoing Praecipe for Entry of Appearance on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Lawrence J. Rosen, Esquire 1101 North Front Street Harrisburg, Pennsylvania 17111 James G. Nealon, III, Esquire {'asp Zill SHERRY L. SNYDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No: 00-6279 : CIVIL ACTION - LAW TODD OGDEN, : CUSTODY Defendant PETITION OF TODD OGDEN FOR EMERGENCY RELIEF 1. Petitioner/Defendant, Todd Ogden, ("Father") is an adult individual who currently resides at 1 Nottingham Drive, Mechanicsburg, Pennsylvania 17050. 2. Respondent/Plaintiff, Sherry L. Snyder, ("Mother") is an adult individual who currently resides at either 4072 Fawn Drive, Harrisburg, Pennsylvania or c/o Gloria and Rick Powell, 107 R N. Enola Drive, Enola, Pennsylvania. 3. The parties are the parents and natural guardians of one minor child, Amanda Ogden (DOB: June 11, 1999). 4. On October 31, 2000, This Honorable Court issued an Order regarding the custody of the minor child. A true and correct copy of the Order is attached hereto and incorporated herein by reference as "Exhibit A." 5. Recently, Father learned that Mother has been charged with one count of delivery of cocaine and one count of criminal conspiracy. A true and correct copy of the Criminal Docket is attached hereto and incorporated herein by reference as "Exhibit B." 6. The arrest was part of an extensive investigation coordinated by the Pennsylvania State Attorney General's office entitled "Operation Triple Threat." A true and correct copy of the article published by WGAL.com regarding the arrest is attached hereto and incorporated herein by reference as "Exhibit C." 7. The report indicates that Mother was part of a "multimillion drug ring ...that brought cocaine, heroin and marijuana into Dauphin, Lebanon, Cumberland, Berks and Philadelphia counties." 8. Mother's boyfriend, Cesar Jaen, with whom she resides, has also been charged in connection with the operation. 9. Mother has advised Father that the cocaine charge involved one ounce of cocaine. 10. The crimes with which Mother has been charged carry a three year mandatory minimum sentence. 11. Contemporaneously with the filing of the instant Petition for Emergency Relief, Father is filing a Petition to Modify Custody. A true and correct copy of the Petition to Modify Custody is attached hereto and incorporated herein by reference as "Exhibit D." 12. Given Mother's arrest, the involvement of her live-in boyfriend and the extensive nature of the drug operation, the minor child is in danger and needs to be removed from Mother's household. 13. The child is currently enrolled in Thomas Holtzman Elementary School of the Central Dauphin School District. Father will maintain the child in her current school so as to lessen the traumatic impact on the child. 14. Mother will suffer no prejudice if custody is transferred to Father pending a hearing or conciliation. WHEREFORE, Petitioner, Todd Ogden, urges this Honorable Court to modify the October 31, 2000, so as to award Father primary physical custody pending further Order of Court. Respectfully submitted, NEALON GOAsR t PER By: Date: 3 a 7 d-6 1) ' James G. Nealon, III, Esquire I.D. #: 46457 2411 North Front Street Harrisburg, PA 17110 717/232-9900 VERIFICATION I, Todd G. Ogden, verify that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. TODD G. OGDEN Dated: 3 /a ??e? b?j? ? ??? SHERRY L. SNYDER, Plaintiff V8. TODD OGDEN, : CIVIL ACTION - LAW Defendant : CUSTODY ORDER OF COURT AND NOW, this .? P*- day of 0&12tol , 2000, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: ocr 24 2T IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-6279 1. Legal Custody. The parties, Sherry L. Snyder and Todd Ogden, shall have shared legal custody of the minor Child, Amanda Ogden, born June 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 her 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. The Mother shall have primary physical custody subject to Father's rights of partial physical custody at such time and places as the parties shall agree. BY THE , J. Dist: Lawrence J. Rosen, Esquire 1101 North Front Street, Harrisburg, PA 17102 Todd Ogden 3324 Derry Street Harrisburg, PA 17111 0 ??j ???- ? Magisterial District Judge 12-1-06 Docket Number: CR-0000109-08 Criminal Docket COMMONWEALTH OF PENNSYLVANIA V. SNYDER,SHERRY Page 1 of 1 Judge Assigned: LINDSEY, JOSEPH S Issue Date: OTN: K 535464-6 File Date: 03/19/2008 Arresting Agency: ATTORNEY GENERAL, NARCOTICS Case Disp: Arresting Officer: DILLER, RONALD L Disp Date: Complaint/Incident # 3000607 Requested: $0.00 County: DAUPHIN Judgment: Township: LOWER PAXTON TWP Name: SNYDER, SHERRY Address: ENOLA, PA 17025 Date Of Birth: 12/16/1971 Sex: Female Race: White Bail Type: Unsecured Status Date: 03/24/2008 Bail Status: Set Posting Date: Bail Amount: $150000.00 O/S Amount: $150000.00 # Charge Description Disposition 1 35 § 780-113 §§ A30 DELIVERY OF COCAINE 2 18 § 903 §§ Al CRIMINAL CONSPIRACY Schedule Date Event Type Status 03/24/2008 Arraignment _ 04/02/2008 Preliminary Hearing CONT 05/16/2008 Preliminary Hearing Total Due: $0.00 Total Adj: $0.00 Total Paid: $0.00 Balance: $0.00 Name: DILLER, RONALD L 1200 Printed: 03/26/2008 10:55 am Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 at seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. r,?jb;+ AG: Major Bust Starter With Low-Level Buy - Print This Story News Story - WGAL La... WGAL.com AG: Major Bust Started With Low-Level Buy Related To Story POSTED: 3:56 prn EDT March 24, 2008 UPDATED: 2:09 prn I_DT March 25, 2008 HARRISBURG, Pa. -- The breakup of an 18-dealer, multimillion-dollar drug ring in the Susquehanna Valley started with a small undercover purchase from a low-level street dealer in Cumberland County, officials at the Pennsylvania State Attorney General's office said. The attorney general's office announced Monday that it "shattered" the operation that brought cocaine, heroin and marijuana into Dauphin, Lebanon, Page 1 of 3 Cumberland, Berks and Philadelphia counties. Attorney General Tom Corbett said at its peak, the organization moved about 81 kilos a year into the area, with translated to about $2.9 million. Throughout the investigation, agents seized more than 5.5 kilos of cocaine, 24 pounds of marijuana, 70 grams of heroin and more than $56,500 in cash, the attorney general's office said. "It's disappointing that people who are intelligent enough to have a complex network that operates much like a legitimate business choose to go down this road," Corbett said in a news release. "The drug business can be very profitable for these people, until inevitably, they end up in prison." A complete list of the defendants as provided by the attorney general's office can be found below. You can also click the image above for a larger graphic showing the pictures of those accused: • Julio "Bling-Bling" Rodriguez-Ortiz, 35, 855 North Park Road, Wyomissing, is charged with two counts of delivery of cocaine, one count of possession with intent to deliver cocaine, one count of criminal use of a communications facility and one count of corrupt organizations. . Miguel Ortiz, 36,131 Pear St., Reading, is charged with one count of possession with intent to deliver cocaine and one count of criminal conspiracy. • Joseph "Josey" Rosario, 24,528 Robeson St., #1, Reading, is charged with two counts of delivery of cocaine, two counts of corrupt organizations and one count of criminal use of a communications facility. He is currently incarcerated in Reading County Jail. • Samuel "Sammy" Lopez, 28, 838 Bingamin St., Reading, is charged with two counts of http://www.wgal.com/print/I 5694044/detail.html 3/26/2008 Officials said "Operation Triple Threat" led to the arrest of 18 drug dealers. AG: Major Bust Started With Low-Level Buy - Print This Story News Story - WGAL La. Page 2 of 3 delivery of cocaine, two counts of corrupt organizations, one count of criminal conspiracy and one count of criminal use of a communications facility. He is currently incarcerated in Reading County Jail. . Jose Azcona, 31, 850 Carsonia Ave., Apt. D-302, Reading, is charged with two counts of delivery of cocaine, two counts of corrupt organizations, one count of criminal conspiracy and one count of criminal use of a communications facility. He is currently incarcerated in Reading County Jail. . Purnell McCalvin, 33, 447 Elm St., Pottstown, is charged with one count of possession with intent to deliver cocaine and one count of criminal conspiracy. . Jesus "Cann" Garcia, 42, 221 North 8th St., Lebanon, is charged with four counts of delivery of cocaine, three counts of criminal conspiracy, two counts of corrupt organizations and one count of criminal use of a communications facility. . Alex Emilio Rodriguez, 38, 830 Skull St., #3, Lebanon, is charged with one count of delivery of cocaine, one count of criminal conspiracy and one count of criminal use of a communications facility. . Luis Mojica, 39, 315 North 8th St., Lebanon, is charged with three counts of criminal conspiracy, two counts of delivery of cocaine and two counts of corrupt organizations. . Angel Rodriguez, 44,1001 Willow St., #3, Lebanon, is charged with four counts of delivery of cocaine, two counts of criminal conspiracy, two counts of corrupt organizations and one count of criminal use of a communications facility. . Rosalio Marez, 40,1o6 Chestnut Hill Road, Fredericksburg, is charged with two counts of delivery of marijuana and one count of criminal conspiracy. • Cesar Jaen, 45, 4072 Fawn Drive, Harrisburg, is charged with five counts of delivery of cocaine, one count of possession with intent to deliver cocaine, one count of possession with intent to deliver marijuana, one count of criminal conspiracy and one count of criminal use of a communications facility. . Sherry Snyder, 36, 4072 Fawn Drive, Harrisburg, is charged with one count of delivery of cocaine and one count of criminal conspiracy. . Victor "Pisano" Valdez, 46,182o Harrison Ave., 4 M, Bronx, N.Y., is charged with one count of delivery of cocaine, one count of possession with intent to deliver heroin and one count of criminal use of a communications facility. http://www.wgal.com/print/l 5694044/detail.html 3/26/2008 AG: Major Bust Started With Low-Level Buy - Print This Story News Story - WGAL La... Page 3 of 3 . Harry Tolbert, 37, ioo Delmont Avenue, Harrisburg, is charged with three counts of delivery of cocaine, one count of criminal conspiracy and one count of criminal use of a communications facility. . Kevin Evanoff, 25, 212 Summer Lane, Enola, is charged with one count of delivery of cocaine, one count of criminal conspiracy and one count of criminal use of a communications facility. • Juan Albert "Rooster" Ortiz, 43, 343o Kip St., Philadelphia, is charged with three counts of delivery of heroin, two counts of corrupt organizations, one count of delivery of cocaine, one count of delivery of a non-controlled substance, one count of criminal conspiracy and one count of criminal use of a communications facility. . Jose "Blue" Alvarez, 43, 427o Lawnside Road, Philadelphia, is charged with one count of delivery of heroin, one count of criminal conspiracy and one count of criminal use of a communications facility. Copyright 2008 by WGAL.com. All rights reserved. This material may not be published, broadcast, rewritten or redistributed. http://www.wgal.com/print/15694044/detail.html 3/26/2008 Page 1 of 1 http://www.wgal.com/2008/0324/15694040.jpg 3/26/2008 g)? ? 1 b r CERTIFICATE OF SERVICE AND NOW, this c•? day of March, 2008, 1 hereby certify that I caused a true and correct copy of the foregoing Petition to Modify to be served via fax and regular mail to: Lawrence J. Rosen, Esquire 1101 North Front Street Harrisburg, Pennsylvania 17111 In addition, Counsel will cause the Petition upon Sherry Snyder as soon as practical. served personally James G. Nealon, III, Esquire Vt s.5 ?.'7 tr',i rri. uiy!L SHERRY L. SNYDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No: 00-6279 : CIVIL ACTION - LAW TODD OGDEN, : CUSTODY Defendant PETITION OF TODD OGDEN TO MODIFY CUSTODY 1. Petitioner/Defendant, Todd Ogden, ("Father") is an adult individual who currently resides at 1 Nottingham Drive, Mechanicsburg, Pennsylvania 17050. 2. Respondent/Plaintiff, Sherry L. Snyder, ("Mother") is an adult individual who currently resides at either 4072 Fawn Drive, Harrisburg, Pennsylvania or c/o Gloria and Rick Powell, 107 R N. Enola Drive, Enola, Pennsylvania. 3. The parties are the parents and natural guardians of one minor child, Amanda Ogden (DOB: June 11, 1999). 4. On October 31, 2000, This Honorable Court issued an Order regarding the custody of the minor child. A true and correct copy of the Order is attached hereto and incorporated herein by reference as "Exhibit A." 5. Recently, Father learned that Mother has been charged with one count of delivery of cocaine and one count of criminal conspiracy. A true and correct copy of the Criminal Docket is attached hereto and incorporated herein by reference as "Exhibit B." 6. The arrest was part of an extensive investigation coordinated by the Pennsylvania State Attorney General's office entitled "Operation Triple Threat." A true and correct copy of the article published by WGAL.com regarding the arrest is attached hereto and incorporated herein by reference as "Exhibit C." 7. The report indicates that Mother was part of a "multimillion drug ring-that brought cocaine, heroin and marijuana into Dauphin, Lebanon, Cumberland, Berks and Philadelphia counties." 8. Mother's boyfriend, Cesar Jaen, with whom she resides, has also been charged in connection with the operation. 9. Upon information and belief, Father avers that the crimes with which Mother has been charged carry a three year mandatory minimum sentence. 10. The October 31, 2000, Custody Order should be modified so as to provide Father with primary physical custody and award Mother periods of supervised visitation. WHEREFORE, Petitioner, Todd Ogden, urges this Honorable Court to modify the October 31, 2000, so as to award Father primary physical custody and provide Mother with periods of supervised visitation. Respectfully submitted, NEAVGOVER ERRY By: Date: g /-)- -2?/o -? James G. Nealon, III, Esquire I.D. #: 46457 2411 North Front Street Harrisburg, PA 17110 717/232-9900 cx??gff A 1 SHERRY L. SNYDER, Plaintiff ; vs. ; TODD OGDEN, Defendant OCT 81 2T IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-6279 CIVIL ACTION - LAW CUSTODY ORUER OF CO.URRTi AND NOW, this .3 1' day of 2000, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Sherry L. Snyder and Todd Ogden, shall have shared legal custody of the minor Child, Amanda Ogden, born June 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 her 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. P 2. Physical Custody. The Mother shall have primary physical custody subject to Father's rights of partial physical custody at such time and places as the parties shall agree. BY THE , J. nO Dist: Lawrence J. Rosen, Esquire 1101 North Front Street, Harrisburg, PA 17102 `? Todd Ogden 3324 Deny Street Harrisburg, PA 17111 • ?Vl ? 111> L? Al?? ?x ??? ?+ ? Magisterial District Judge 12-1-06 JIM Docket Number: CR-0000109-08 oft Criminal Docket COMMONWEALTH OF PENNSYLVANIA V. SNYDER,SHERRY Page 1 of 1 Judge Assigned: LINDSEY, JOSEPH S Issue Date: OTN: K 535464-6 File Date: 03/19/2008 Arresting Agency: ATTORNEY GENERAL, NARCOTICS Case Disp: Arresting Officer: DILLER, RONALD L Disp Date: Complaint/incident # 3000607 Requested: $0.00 County: DAUPHIN Judgment: Township: LOWER PAXTON TWP Name: SNYDER, SHERRY Address: ENOLA, PA 17025 Date Of Birth: 12/16/1971 Sex: Female Race: White Bail Type: Unsecured Status Date: 03/24/2008 Bail Status: Set Posting Date: Bail Amount: $150000.00 O/S Amount: $150000.00 # Charge Description Disposition 1 35 § 780-113 §§ A30 DELIVERY OF COCAINE 2 18 § 903 §§ Al CRIMINAL CONSPIRACY Schedule Date Event Type Status 03/24/2008 Arraignment 04/0212008 Preliminary Hearing CONT 05/16/2008 Preliminary Hearing Total Due: Total Paid: $0.00 $0.00 Total Adj: Balance: $0.00 $0.00 Name: DILLER, RONALD L ? i 1200 Printed: 03l26f2008 10:55 am Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 et seq.) maybe subject to civil liability asset forth in 18 Pa.C.S. Section 9183. C, 11 -? ,-x ?jj) AG: Major Bust Started With Low-Level Buy - Print This Story News Story - WGAL La... Page 1 of 3 WGAL.com AG: Major Bust Started With Low-Level Buy POSTED: 3:56 prn EDT March 24, 2008 UPDATED: 2:09 pm EDT March 25, 2008 HARRISBURG, Pa. -- The breakup of an 18-dealer, multimillion-dollar drug ring in the Susquehanna Valley started with a small undercover purchase from a low-level street dealer in Cumberland County, officials at the Pennsylvania State Attorney General's office said. The attorney general's office announced Monday that it "shattered" the operation that brought cocaine, heroin and marijuana into Dauphin, Lebanon, Officials said "Operation Triple Threat" led to the arrest of 18 drug dealers. Cumberland, Berks and Philadelphia counties. Attorney General Tom Corbett said at its peak, the organization moved about 81 kilos a year into the area, with translated to about $ 2.9 million. Throughout the investigation, agents seized more than 5.5 kilos of cocaine, 24 pounds of marijuana, 70 grams of heroin and more than $56,500 in cash, the attorney general's office said. "It's disappointing that people who are intelligent enough to have a complex network that operates much like a legitimate business choose to go down this road," Corbett said in a news release. "The drug business can be very profitable for these people, until inevitably, they end up in prison." A complete list of the defendants as provided by the attorney general's office can be found below. You can also click the image above for a larger graphic showing the pictures of those accused: . Julio "Bling-Bling" Rodriguez-Ortiz, 35, 855 North Park Road, Wyomissing, is charged with two counts of delivery of cocaine, one count of possession with intent to deliver cocaine, one count of criminal use of a communications facility and one count of corrupt organizations. . Miguel Ortiz, 36,131 Pear St., Reading, is charged with one count of possession with intent to deliver cocaine and one count of criminal conspiracy. . Joseph "Josey" Rosario, 24,528 Robeson St., #i, Reading, is charged with two counts of delivery of cocaine, two counts of corrupt organizations and one count of criminal use of a communications facility. He is currently incarcerated in Reading County Jail. . Samuel "Sammy" Lopez, 28, 838 Bingamin St., Reading, is charged with two counts of http://www.wgal.com/print/15694044/detail.html 3/26/2008 Related To Story AG: Major Bust Started With Low-Level Buy - Print This Story News Story - WGAL La... Page 2 of 3 delivery of cocaine, two counts of corrupt organizations, one count of criminal conspiracy and one count of criminal use of a communications facility. He is currently incarcerated in Reading County Jail. . Jose Azcona, 31, 850 Carsonia Ave., Apt. D-302, Reading, is charged with two counts of delivery of cocaine, two counts of corrupt organizations, one count of criminal conspiracy and one count of criminal use of a communications facility. He is currently incarcerated in Reading County Jail. . Purnell McCalvin, 33, 447 Elm St., Pottstown, is charged with one count of possession with intent to deliver cocaine and one count of criminal conspiracy. . Jesus "Cano" Garcia, 42, 221 North 8th St., Lebanon, is charged with four counts of delivery of cocaine, three counts of criminal conspiracy, two counts of corrupt organizations and one count of criminal use of a communications facility. . Alex Emilio Rodriguez, 38, 830 Skull St., #3, Lebanon, is charged with one count of delivery of cocaine, one count of criminal conspiracy and one count of criminal use of a communications facility. . Luis Mojica, 39, 315 North 8th St., Lebanon, is charged with three counts of criminal conspiracy, two counts of delivery of cocaine and two counts of corrupt organizations. . Angel Rodriguez, 44,1001 Willow St., #3, Lebanon, is charged with four counts of delivery of cocaine, two counts of criminal conspiracy, two counts of corrupt organizations and one count of criminal use of a communications facility. . Rosalio Marez, 40, io6 Chestnut Hill Road, Fredericksburg, is charged with two counts of delivery of marijuana and one count of criminal conspiracy. . Cesar Jaen, 45, 4072 Fawn Drive, Harrisburg, is charged with five counts of delivery of cocaine, one count of possession with intent to deliver cocaine, one count of possession with intent to deliver marijuana, one count of criminal conspiracy and one count of criminal use of a communications facility. . Sherry Snyder, 36,4072 Fawn Drive, Harrisburg, is charged with one count of delivery of cocaine and one count of criminal conspiracy. . Victor "Pisan" Valdez, 46,182o Harrison Ave., 4 M, Bronx, N.Y., is charged with one count of delivery of cocaine, one count of possession with intent to deliver heroin and one count of criminal use of a communications facility. http://www.wgal.com/print/15694044/detail.html 3/26/2008 AG: Major Bust Started With Low-Level Buy - Print This Story News Story - WGAL La... Page 3 of 3 . Harry Tolbert, 37, loo Delmont Avenue, Harrisburg, is charged with three counts of delivery of cocaine, one count of criminal conspiracy and one count of criminal use of a communications facility. . Kevin Evanoff, 25, 212 Summer Lane, Enola, is charged with one count of delivery of cocaine, one count of criminal conspiracy and one count of criminal use of a communications facility. . Juan Albert "Rooster" Ortiz, 43, 343o Kip St., Philadelphia, is charged with three counts of delivery of heroin, two counts of corrupt organizations, one count of delivery of cocaine, one count of delivery of a non-controlled substance, one count of criminal conspiracy and one count of criminal use of a communications facility. . Jose "Blue" Alvarez, 43, 427o Lawnside Road, Philadelphia, is charged with one count of delivery of heroin, one count of criminal conspiracy and one count of criminal use of a communications facility. Copyright 2008 by WGAL.com. Ali rights reserved. This material may not be published, broadcast, rewritten or redistributed. http://www.wgal.com/print/I 5694044/detail.html 3/26/2008 Page 1 of 1 http://www.wg4l.com/2008/0324/15694040.jpg 3/26/2008 VERIFICATION I, Todd G. Ogden, verify that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. TODD G. OGDEN Dated: ?,. ?? CERTIFICATE OF SERVICE AND NOW, this ?`day of March, 2008, 1 hereby certify that I caused a true and correct copy of the foregoing Petition to Modify to be served via fax and regular mail to: Lawrence J. Rosen, Esquire 1101 North Front Street Harrisburg, Pennsylvania 17111 In addition, Counsel will cause the Petition to be served personally upon Sherry Snyder as soon as practical. q4 James G. Nealon, III, Esquire j 90 pp v ? a r MAR 8 8 2008 SHERRY L. SNYDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No: 00-6279 : CIVIL ACTION - LAW TODD OGDEN, : CUSTODY Defendant ORDER AND NOW, this Ak day of March, 2008, upon consideration of the Petition for Emergency Relief filed by Todd Ogden, it is hereby Ordered and Decreed that the custody rights of Sherry L. Snyder are suspended pending further Order of Court. Todd Ogden shall have=ph? yrcal custody of Amanda Ogden (DOB: June 11, 1999) pending f MI! m Oider 86.hearing is scheduled forAwut o-"k 2008, atb:.Wt4.m. in Courtroom No. -7of the Cumberland County Courthouse. ?uR?-e- • BY T COURT: t.t7 ?' a ? ? ?- ?• .??-- ?? ?'. ?-' w,, w, , . ?:.., ??i?-- ,^ttr. ?-- rs `cam-' t SHERRY L. SNYDER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 00-6279 CIVIL TODD OGDEN, Defendant CUSTODY ORDER AND NOW, this z " day of April, 2008, following conference with counsel in chambers, it is ordered and directed that: 1. The parties shall have shared legal custody of the child, Amanda Ogden born June 11, 1999. 2. Father shall have primary physical custody with partial custody in the mother every other weekend from Friday evening until Sunday evening, and a visit during the week at such times as the parties shall agree. 3. The parties shall share holidays as they agree. 4. The mother is prohibited from allowing the child to have any contact whatsoever with Cesar Jean. This order is entered without prejudice to either party to file a motion for modification of the custody arrangement. BY THE COURT, Kevin. Hess, J. ? ? l' -i.J a:r?! i ??? ,'?.S s ?, , ; ???, ?.-3 ? Lawrence J. Rosen, Esquire For the Plaintiff /James G. Nealon, 111, Esquire For the Defendant Am CoPrE..r n,at . L SHERRY L. SNYDER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2000-6279 CIVIL ACTION LAW TODD OGDEN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, April 04, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, May 01, 2008 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy, Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 lllwy? rvw ,qw-'\VMO? WVI SHERRY L. SNYDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 00-6279 CIVIL ACTION - LAW TODD OGDEN, Defendant : IN CUSTODY ORDER AND NOW, this ?j day of May, 2008, upon being advised by the Petitioner's attorney that a Conciliation is no longer necessary, the Conciliation scheduled for May 29, 2008, is canceled and the Conciliator relinquishes jurisdiction. ??M)Cel Hubert X. G' oy, Esquire Custody C ciliator ff Q C Cm ( ?? }