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Home My WebLink About00-06807 ",-0'" . " -~'o< l,_ f I ~I --, ,-,.-,' .",,,,--,, r~,~ KELLY R. SNYDER PLAINTIFF V. MATIN CHOWDHURY DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-6807 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 10th day of October, 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 Hill, PA 17011 on the ~ day of November ,2000, at....!!:OO 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 tempolCary 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 TIIE COURT, By: Isl Melissa P. Greevy. Es%i. Custody Conciliator I) 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 HA VB 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 ~ i ~-~,,-~ - " __"_-0.'_"". ,L}-II- cZJ /tJ -//tJtJ /f)- /h10 ~ ,./, . OF FIL f['-q"[:l~:~)]:'\RY OOorT I ' -'--II j I P{-;; J2: I)') , .~ '--'':'- CUI.'C'.'.... ..- v!-,,---..;: 1[' .'--. -'.....'.:".,,""'J\ , I -I /;)\/"'-v DE'" -,,' '_''-.l "I, . -i'iJ~(){; \/'Ai\I!^ -. ,.",,,,-\ M~~$ <;7!.n1z, ~ $" ~.~ -, t'. ~~ r~ ,~,-"~~~, ~~" ,n:"'~~, :""u~il!'''''~~'''';P''-:\'!~'''""''$'m0M!1-'f.~l';>'''-W'CISIj>,,,*~ . , ", ,. _' i\1f!'P.~I!ffltjQJ-'1!MJ~!l!i~~ ~l ,,~[! C:"., ,,,,"' . ~I, " <I 1lIII#,;!ilW..>. / . , KELLY R. SNYDER Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAINIA NO. 00 - t:.f67 CI~J~1..rn MATIN CHOWDHURY Defendant CIVIL ACTION - LAW CHILD CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS You, Matiu Chowdhury, defendant, have been sued in court to OBTAIN custody, partial custody or visitation of the child: Amber Chowdhury . ORDER OF COURT AND NOW, upon eonsideration of the attached Complaint, it is hereby direeted that the parties and their respective counsel appear before , Esquire, the conciliator, at on the day of ,2000, at o'clock _.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 the entry of a temporary or permanent order. FOR THE COURT: By Date Custody Conciliator AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of ClUllberland County is required by law to comply with the Americans with Disabilities At 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 ,~-""""". I.. , ' ...JI .J k ~-~IlIil-.-~ "Jt.",,^, KELLY R. SNYDER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. d-O- {,J'6 7 ~ ~ v. MATIN CHOWDHURY Defendant CIVIL ACTION - LAW CHILD CUSTODY CUSTODY COMPLAINT 1. The plaintiff is Kelly R. Snyder, residing at 106 Garrison Lane, Apt. 3, Carlisle, Cumberland County, Pennsylvania 17013. Her home telephone number is (717) 243-7867. 2. The defendant is Matin Chowdhl!Jry, DOB 11/30/54, Soc. Sec. #119-82-3975, residing at 540 S. 1ih Street, Harrisburg, Dauphin County, Pennsylvania 17104. His home telephone number is (717) 233-0665 and he is employed by D & H Distribution. 3, Plaintiff seeks custody of the following child: Amber Chowdhury, born October 14,1997, presently residing at 106 Garrison Lane, Apt. 3, Carlisle, PA. 4, The child was not born out of wedlock. The child is presently in the custody of the Plaintiff, Kelly R. Snyder, who resides at 106 Garrison Lane, Apt. 3, Carlisle, PA. 5. Since birth, the child has lived with the following people at the following address for the periods indicated: Names Kelly R. Snyder Address Dares 106 Garrison Lane, Apt. 3, 9/4/00 - Present Carlisle, PA 17013 540 S. 17th St. Harrisburg, Birth - 9/4/00 PA 17104 Kelly R. Snyder Matin Chowdhury -~__I'" ... , , , I. " ~~;! The mother of the child is Kelly R Snyder, who resides at 106 Garrison Lane, Apt. 3, Carlisle, PA 17013 She is married. The father of the child is Matin Chowdhury who resides at 540 S. 1ih St., Harrisbu~g, PA 17104 He is married. 6. The relationship of the Plaintiff to the children is that of mother. The Plaintiff currently resides with the following persons: Name Amber Chowdhury Relationship Daughter 7. The relationship of the Defendant to the children is that of father. The Defendant currently resides with the following persons: Name Self Relationship 8. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or any other court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proeeedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 9. The best interest and permanent welfare of the child will be served by granting the relief requested because mother has been the child's primary caretaker since birth. 2 "",_~~,~I - : I J~ ~. ~"ih~_- 1 O. Each parent whose parental rights to the ehild have not been terminated and the person who has physical custody of the child have been named as parties to this aetion. WHEREFORE, pursuant to the Custody Act, 23 Pa.C.S. ~5301 et sea., Plaintiff requests the court to grant her custody of the ehild. RESPECTFULLY SUBMITTED: ItJ(5/<70 Date I f cL~ ser, Esquire Attorne No, 75899 4810 Derry Street Harrisburg, PA 17111 PHONE (717) 564-1084 FAX (717) 564-5158 Attorney for Plaintiff 3 ,~...,.,_I tJ . . ,~ \IW.' VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. q-;;;(!rOO Date ~/~ ~ A ~ Kelly R nyder, Plai~ - 4 :i(~--' ..~ .-, .:.' .- ("j- ,,;,,_ ",i~'%l@ij~l_~,ir!J~it;&{;~ilid~~""--" ;.1." '. - ..0 (2 ",~.~'-Iii!iil!lLill i_ 700 ~I[ . D ota&DO - (), , I ~~ S~ ~ o{q ~ ~ o ,~.~. ~" , ';", (") c v6:~ rnr:-' 2:1:_1 ~~,: r:C ~ " ;S~: ;r-...C z =< . . o o o (J -J ~0 " '-'-', r~ ~._i -n --,j ----J ~~i , "I ~ ",") =< ~w, '" I"." ~. ~" , : ,I ~ , .0 ----!lUW' Plaintiff NOIf 22 2~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-6807 ... ... KELLY R. SNYDER, vs. MATIN CHOWDHURY, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this J 1 ~ dayof,J ~ , 2000, upon eonsideration of the attaehed Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody: The parties, Kelly R Snyder, and Matin Chowdhury, shall have shared legal custody of the minor Child, Amber Chowdhury, born October 14, 1997. Eaeh parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergeney decisions affeeting the Child's general well-being including, but not limited to, all deeisions regarding her health, edueation and religion. Pursuant to the terms of this paragraph, eaeh parent shall be entitled to all reeords and information pertaining to the Child including, but not limited to, sehool and medical reeords and information. To the extent one parent has possession of any such reeords or information, that parent shall be required to share the same, or eopies thereof, with the other parent within sueh reasonable time as to make the reeords and information of reasonable use to the other parent. 2. Physical Custody: Mother shall have primary physieal eustody of the minor Child. Father shall have physieal custody on alternating weekends from 2:00 p.m. Saturday through 5:00 p.m. Sunday to commence November 18, 2000. This is the minimal amount of custody for Father. He shall have additional periods of custody arranged at sueh other times as the parties may agree. 3. Holidays: The parties shall share holidays: Christian, Seeular, and Islamic, as they shall mutually agree. 4. Neither party shall remove the Child from the Commonwealth of Pennsylvania without the expressed written consent of the other parent. 5. This Order is temporary in nature. It may be modified by the mutual agreement of the parties. In the absenee of an agreement, this Order shall control pending further Order of Court. ,~' .. . '-'- If No. 00-6807 Dist: , '''" -;:~--- rl!1i BY THE COURT, 4B t. ~ -fll aJJ- J/-'z1-00 RK.') Matin Chowdhury, 540 S. 17th Street, Harrisburg, PA 17104 Cindy L. Koser. Esquire, 4810 Derry Street, Harrisburg, PA 17111 J. .'''''''''t~,- ~'<I'1I __, I ~~ . ~.- ~,~,,,,- il ~-, " .-;., -..", ."'.. ..-,' ..~} " KELLY R. SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-6807 vs. MATIN CHOWDHURY, 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 eoneerning the Child who is the subjeet of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF: Amber Chowdhury Oetober 14, 1997 Mother 2. A Conciliation Conferenee was held on November 14, 2000, with the following individuals in attendance: the Mother, Kelly R. Snyder, and her counsel, Cindy Koser, Esquire; the Father, Matin Chowdhury, who appeared Pro Se. 3. The parties reached an agreement in the form of an Order as attaehed. I ) ---11- c2ff[T7J Date ~ft9t7~ ~ Melissa eel Greevy, Esquire ') Custody Coneiliator