HomeMy WebLinkAbout01-2431 FX
- ~~-~' ,~~,~
-',,",,'--
"'_1_,,",;',_", "'..""> ~ ~"'.,:',f~ ", ,'i",' ,';","C,"",",';.' i,,~,'>t.,,",:y.;,Y'-O:"j""':C",~;':",~,~ __~','.'_
-",__,,~":O'i:
I
RONALD SNOWBERGER and
LUCINDA SNOWBERGER,
Petitioners
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
AMY JO FRYE and
RONALD E. SNOWBERGER, JR.,
Respondents
71...e,. 0/- ~ 'f 3/ CIVIL TERM
IN CUSTODY
PETITION FOR CUSTODY
AND NOW, this 24th day of April 2001, comes the Petitioners, Ronald Snowberger and
Lucinda Snowberger, by their attorneys, Irwin, McKnight and Hughes, and presents the
following Petition for Custody.
1.
The petitioners are Ronald Snowberger and Lucinda Snowberger, adult individual
residing at 63 Faith Circle, Carlisle, Cumberland County, Pennsylvania 17013.
2.
The respondent, Amy Jo Frye, is an adult individual with the last known address c/o
Steven A. Frye, 113 Weaver Street, Altoona, Pennsylvania 16601-7001
3.
The respondent, Ronald E. Snowberger, Jr., is an adult individual residing at 240 "E"
Street, Carlisle, pennsylvania 17013.
3
u_ ,
-'--.< ~ _,_ ",1 - "f=' "e". C,.'~ ' 1","--"'~'";;';,_,--,,v <"'-S~';'-(<;;+";-:;;"i;'.,_
'o"''''--'w.:
.
4.
The parties are the natural parents of two minor children, namely, Ronald E. Snowberger,
1II, born October 7,1997, age three (3), and Miranda Marie Snowberger, born July 29, 1999, age
two (2).
5.
The Petitioners are the fraternal grandparents of the children. They desire primary
physical and legal custody of the children with periods of supervised periods of visitation to
respondents as can be mutually arranged between the parties.
6.
The best interest of the children requires that the conrt grant the petitioners' request as set
forth above.
WHEREFORE, petitioners respectfully seeks the entry of an Order of Conrt seeking
primary physical and legal custody of the children with periods of supervised visitation to
respondents as can be mutually arranged between the parties.
Respectfully submitted,
By:
Date: April 24, 2001
Marc A. Esquire
Attorney for Pe oners
60 West Pomfret Street
Carlisle, Pennsylvania 17013
(717) 249-2353
Supreme Court I. D. No. 25476
4
-'-
~'" ~~-~-"'" ,",_,-.c "c - _," ",",,-,,~_'i" "",,,,',"~',< '. ,,,' """;"~,' ^'o~"~:.~' ~"'j"f _, <.' ~-'~<--""~..'" '
, "iMf:~;
VERIFICATION
The foregoing document is based upon information which has been gathered by
counsel and myself in the preparation of this action. 1 have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
~L~
~~~~~
L A SNOWBERGER \'
Date: APRIL 24, 2001
.~~~ "i;
,''''''''' -,"
~~
~ ~
~ -<
~
~,' ~, , -..-
%
'if'';' ;,;0--_
':> iOili~~"",~;..;",,,,:,~-:.",, "iI.Wi~'
n.,~~,"~ _~,~,"~_
"" w
, .""
"~ ,.;,
~ ., ~
w
r,
!
i
f1
~ g CJ 0
-n
;;. !Q - .~\
-m:C f4:~~~
J (l}.-n '"
Z:'JJ
~~~, N ~gtrl
<.5' ",.:9
~CJ -0 \~~9~
...... .. ~o ::J' (-....._:.1
'" ~(")
.<::J <Ii ~ _0 to:? om
C J7C -.-\
'2 a c;,., ~ - ~
d ....J
"
" <-
-
>-1
~' ,~
,- ..,=,~ >, 'cO,,, ,'~" '111' U LL
RONALD SNOWBERGER AND LUCINDA
SNOWBERGER
PLAINTIFF
V.
AMY JO FRYE AND RONALD E.
SNOWBERGER, JR.
DEFENDANT
IN TIIE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-2431 CMLACTIONLAW
IN CUSTODY
ORDER OF COURT
AND NOW,
Thursday, May 03, 2001
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator,
at 4th Floor, Cumberland County Courthonse, Carlisle on Wednesday, May 23, 2001 at 9:30 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.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Cnstody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: Isl
Jacqueline M. Verney. Esq.!Jt?
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
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
.Jt
":11
J~I!I'_
5'-1/-~1
5'f/.t)1
5-tf-f)1
---, '. ~-
~
j-.
cr.: i": ,':
''', ,
, ,,"
,",' "'v ,
WI td~~ ."lr
P'~ ". "jn
I' S. .. 'wi
CUM2d:LN'lD COUNTY
PENNSYLVANIA
!te;I. ~ ~ it #/U~~
~~;l :t:::(
,,;~~I~"!~.'~~!l1!\'ffi:" _
< ~1!fIII!II!~~~""'>","1;>!~h""-:';'""'0'"1r'C''''''~,",'!,fq~'~''f't~"~-;rJ~~"f,:ott:;r!e1:,,\"""3[iIw,;~1'''~~iW'~~~~''I~'
~--
"-~'. .
'..l__
r........;,.,;"~ , ::t
-,
MAY 2 3 2001 tIJ
RONALD SNOWBERGER and
LUCINDA SNOWBERGER,
Plaintiffs
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLANDCOUNTY,PENNSYLVANIA
: NO.2001-2431 CIVIL TERM
AMY JO FRYE and RONALD
E. SNOWBERGER, JR.
Defendants
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this %.'i. day of A a.. ,2001, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The Grandparents, Ronald Snowberger and Lucinda Snowberger shall
have sole legal and physical custody of Ronald E. Snowberger, III, born October 7, 1997
and Miranda Marie Snowberger, born July 29,1999.
2. Parents, Amy Jo Frye and Ronald E. Snowberger, Jr. shall have periods of
visitation as the parties agree. ~
~q-O\
~. r.
,.
~
BY THE COURT,
d-
1.
cc: Marcus A. McKnight,III, Esquire - Counsel for Grandparents
Amy Jo Frye
C/O Steven A. Frye
113 Weaver Street
Altoona, PA 16601-7001
Ronald E. Snowberger
240 "E" Street
Carlisle, P A 17013
-
I ._ '~
. ~ '
.
RONALD SNOWBERGER and
LUCINDA SNOWBERGER,
Plaintiffs
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYLV ANIA
: 2001-2431 CIVIL TERM
AMYJOFRYEandRONALD
E. SNOWBERGER, JR.,
Defendants
: CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: None
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Children who are the subject of
this litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Ronald E. Snowberger, 1II
Miranda Marie Snowberger
October 7, 1997
July 29, 1999
paternal Grandparents
paternal Grandparents
2. A Conciliation Conference was held in this matter on May 23,2001. The
plaintiff Grandparents, Ronald Snowberger and Lucinda Snowberger were present with
counsel, Marcus A. McKnight, 1II, Esquire. Defendant, Father, Ronald E. Snowberger,
Jr., was aware ofthe conference but did not appear. Mother, Amy Jo Frye, left the area
on March 6, 2001 and has had no contact with the children. Service was attempted at
Mother's last known address in care of her brother Steven A. Frye. Mother did not
appear.
3. An Order in the form attached was requested by Grandparents.
6':?' 3 -0 I
Date
~ ,,~~tn. L .
acqieline M. Verney, Esquire d
Custody Conciliator
~o
'.
-"'~-:)'
,~,-,:""";"'?,="'_~"'-'')f0;eff;;,,~.sy;',')liii-l.:6:'0<;'{;W11tTe,,,;J;:;;~Y4'
il
:,1
"
c.
-
III '"
, l'Dm~
.}.' "';::!:
' =-
~\~ L...
.,
....
Q)
E>
C')
Q) ....,
~ g
OID~
cQ)...,e
(1).l::O:
u..i CI) .
-0 =UJ Q)
- 00
ro= :.:
co....
0..,. ro
Cl::N(.)
s
.~~~
o%,.
./4,,-.>.........;;> .J' ~
0/ y ~
/':>J? _ --...::.....:;;"
. ;r':/fr'
'"
010
~~
.- I-
D..oo
.z
"")-
-0::;
....0
roo(
-Uti:
.- :;)
0:0
u
w
'"
:3",
00
00,..
w-
~~
o -
I~
Ir~
:;)-1
0'"
ui3
w
z
o
-
c<\
-::r
C()
<:::)
o
'"
...
:l:
... a
a ...
..
o 13
Iu:i
zwa
=:;: a: c:;
~~~~;
ClI:.:: a: Wa:
ClI....w~Q
ccQICaC.....
....Z2a:Q
zQ:::twt-
LLlWZ>
C::;I-:C:::i::;
tE!eg~=
=WC4....Z
..=~QQ~
zz.
o 0
t'
19
I'
(II
I
r'
..
o
l'"
..
~~r~'t~~ti$;3!,;\:tJJ~*,.!~1ff~'1;~it!W:1J,!11Th~\'}J~1t\$;1;i~~
,"
"d _
"'-0;..
MAy 2 3 2001rf
RONALD SNOWBERGER and
LUCINDA SNOWBERGER,
Plaintiffs
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYLV ANIA
: NO. 2001-2431 CIVIL TERM
AMY JO FRYE and RONALD
E. SNOWBERGER, JR.
Defendants
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this J..9fh day of
consideration of the attached Custody Conciliatio
follows:
,2001, upon
eport, it is ordered and directed as
1. The Grandparents, Ronald Snowberger and Lucinda Snowberger shall
. have sole legal and physical custody of Ronald E. Snowberger, III, born October 7,1997
and Miranda Marie Snowberger, born July 29, 1999.
2. Parents, Amy Jo Frye and Ronald E. Snowberger, Jr. shall have periods of
visitation as the parties agree.
!
J.
cc: Marcus A. McKnight,II1, Esquire - Counsel for Grandparents
,Amy Jo Frye
C/O Steven A. Frye
113 Weaver Street
Altoona, PA 16601-7001
Ronald E. Snowberger
240 "E" Street
Carlisle, P A 17013
,'"
:.L"
~~
. . > '~~Ji'-
RONALD SNOWBERGER and
LUCINDA SNOWBERGER,
Plaintiffs
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYLV ANIA
: 2001-2431 CIVIL TERM
AMY JO FRYE and RONALD
E. SNOWBERGER, JR.,
Defendants
: CIVIL ACTION - LAW '
: IN CUSTODY
PRIOR JUDGE: None
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Children who are the subject of
this litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Ronald E. Snowberger, III
Miranda Marie Snowberger
October 7, 1997
July 29, 1999
paternal Grandparents
paternal Grandparents
2. A Conciliation Conference was held in this matter on May 23, 2001. The
plaintiff Grandparents, Ronald Snowberger and Lucinda Snowberger were present with
counsel, Marcus A. McKnight, Ill, Esquire. Defendant, Father, Ronald E. Snowberger,
Jr., was aware of the conference but did not appear. Mother, Amy Jo Frye, left the area
on March 6,2001 and has had no contact with the children. Service was attempted at
Mother's last known address in care of her brother Steven A. Frye. Mother did not
appear.
3. An Order in the form attached was requested by Grandparents.
5" ' :J."?rO I
Date
tn,
acq eline M. Verney, Esquire
Custody Conciliator
,
"'C"' ""~I~"o"" ~-- "^'-'- '",," ," ',,,,-, "" -~>' '~-, '~".,"-' _'"J:'_",",,_,"'_'.~__"'<_"-'''';M'"'~''' "~~, " ","',,, > ',., , '-Ii:
AMERICANS WITH DISABILITIES
ACT OF 1990
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 scheduling conference or hearing.
2
.~ ". - ..~O_"..__>, - ,"- "'"--"~f~[
RONALD SNOWBERGER and
LUCfflDASNOWBERGE~
Petitioners
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CNIL ACTION - LAW
AMY JO FRYE and
RONALD E. SNOWBERGER, JR..
Respondents
f'Lc,. 01- .1 'f :3 I CIVIL TERM
IN CUSTODY
ORDER OF COURT
AND NOW, this day of .2001, upon consideration of the
attached petition, it is hereby directed that the parties and their respective counsel appear
before Esquire, the conciliator, at
. 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 or older may
also be present at the conference. Failure to appear at this conference may provide grounds for
entry of a temporary or permanent order.
By the Court,
By:
Custody Conciliator
YOU SHOULD TAKE TillS 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
1-800-990-9108