HomeMy WebLinkAbout07-5080THOMAS D. GOULD, ESQUIRE
2 EAST MAIN STREET
SHIREMANSTOWN, PA 17011
(717j 731-1461
ROBERT SNYDER,
Plaintiff
v.
REBECCA HAINES,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO . ~ ~' v~d PO CIVIL TERM
CIVIL ACTION - LAW
CUSTODY ACTION
CUSTODY COMPLAINT
TO THE HONORABLE JUDGES OF SAID COURT:
1. The Plaintiff is Robert Snyder residing at 4513 Florence
Avenue, Apartment B, Mechanicsburg, Cumberland County, Pennsylvania
17055.
2. The Defendant is Rebecca Haines who resides at 103 West
Main Street, Shiremanstown, Cumberland County, Pennsylvania 17011.
3. Plaintiff seeks legal custody and partial physical
custody of the following child:
NAME
Aleena Joy Haines
PRESENT RESIDENCE
103 West Main Street
Shiremanstown, PA
DOB
09/23/06
The child was not born in wedlock.
The child is presently in the physical custody of Rebecca
Haines who resides at 103 West Main Street, Shiremanstown,
Pennsylvania.
The child has resided with the following persons and at the
following addresses:
Person Address Date
Mother 103 tnlest Main Street 09/06 -present
Shiremanstown, PA
The mother of the child is Rebecca Haines who currently
resides at 103 West Main Street, Shiremanstown, Pennsylvania 17011.
She is not married.
The father of the child is Robert Snyder who lives at 4513
Florence Avenue, Apartment B, Mechanicsburg, Pennsylvania 17055.
He is not married.
4. The relationship of Plaintiff to the child is that of
Father. The Plaintiff currently resides with the following
persons: None
5. The relationship of Defendant to the child is that of
mother. The Defendant currently resides with the following
persons:
Name Relationship
Aleena Joy Haines Daughter
6. Neither party has participated as a party or witness, or
in another capacity, in other litigation concerning the custody of
the child in this or another court.
Plaintiff 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.
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7. The best interest and permanent welfare of the child will
be served by granting the relief requested because:
A. Plaintiff can properly care for his child.
B. Plaintiff can provide a loving .home.
C. Plaintiff wants to be a significant part of his
daughter's life.
8. Each parent whose parental rights to the child has not
been terminated and the person who has physical custody of the
child have been named as parties to this action.
WHEREFORE, Plaintiff requests this Honorable. Court to grant
him joint legal custody and partial physical custody of his child,
at times determined to be in the child's best interest.
Respectfully submitted,
Thomas D. Gould, Esquire
ID #36508
2 East Main Street
Shiremanstown, PA 17011
(717) 731-14.61
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VERIFICATION
I, Robert Snyder, hereby certify that the foregoing CUSTODY
COMPLAINT is 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. Section 4904
relating to unsworn falsification to authorities.
DATED: ~ ~ y ~~~ ~ /" f"
/ Robert Snyder
Plaintiff
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Prepared By:
Diane G. Radcliff, Esquire
3448 Trindle Road
Camp Hill, PA 17011
Supreme Court ID # 32112
Phone:717-737-0100
Fax:717-975-0697
Email: dianeradcliff C~comcast.net
Attorney for Defendant
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ROBERT SNYDER,
Plaintiff N0. 07-5080
V. CIVIL ACTION -LAW
REBECCA HAINES, IN CUSTODY
Defendant
PRAECIPE TO ENTER APPEARANCE
To the Prothonotary:
Please enter the appearance of Diane G. Radcliff, Esquire, Supreme Court ID No.
32112, on behalf of the Defendant, Rebecca Haines.
Papers may be served at the address set forth below:
Diane G. Radcliff, Esquire
3448 Trindle Road
Camp Hill, PA 17011
Date: September 5, 2007
DIA CLIFF, ES IRE
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ROBERT SNYDER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
u' 07-5080 CIVIL ACTION LAW
REBECCA HAINES
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Thursday, Septen
it is hereby directed that parties and their rest
at 39 West Main Street, Mechanicsburg
for aPre-Hearing Custody Conference. At s~
if this cannot be accomplished, to define and
order. All children age five or older may als
provide grounds for entry of a temporary or
per 06, 2007 ,upon consideration of the attached Complaint,
active counsel appear before Dawn S. Sunday, Esq. ,the conciliator,
PA 17055 on Wednesday, October 03, 2007_ at 9:00 AM
;h conference, an effort will be made to resolve the issues in dispute; or
.arrow the issues to be heard by the court, and to enter into a temporary
be present at the conference. Failure to appear at the conference may
;rmanent order.
The court hereby directs the partie~ to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody. orders #o the conciliator 48 hours prior to scheduled hearing.
R THE COURT,
By: ~~, /s/ Dawn S. Sunda Es .
I~ Custody Conciliator
The Court of Common Pleas Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For info ation about accessible facilities and reasonable accommodations
available to disabled individuals having usiness before the court, please contact our office. All arrangements
must be made at least 72 hours prior to y 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 WHE~ZE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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=~I ~~d 9- ~3S L(~I1Z
OCT 2 5 2001
ROBERT SNYDER
Plaintiff
vs.
REBECCA HAINES
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
07-5080 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this day of ~j ~ ~ 2007, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The Father, Robert Snyder, and the Mother, Rebecca Haines, shall have shared legal custody
of Aleena Joy Haines, born September 23, 2006. Major decisions concerning the Child including, but
not necessarily limited to, her health, welfare, education, religious training and upbringing shall be
made jointly by the parties after discussion and consultation with a view toward obtaining and
following a harmonious policy in the Child's best interest. Neither party shall impair the other party's
rights to shared legal custody of the Child. Neither party shall attempt to alienate the affections of the
Child from the other party. Each party shall notify the other of any activity or circumstance
concerning the Child that could reasonably be expected to be of concern to the other. Day to day
decisions shall be the responsibility of the parent then having physical custody. With regard to any
emergency decisions which must be made, the parent having physical custody of the Child at the time
of the emergency shall be permitted to make any immediate decisions necessitated thereby. However,
that parent shall inform the other of the emergency and consult with him or her as soon as possible. In
accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from
any doctor, dentist, teacher, professional or authority and to have copies of any reports or information
given to either party as a parent as authorized by statute.
2. The Mother shall have primary physical custody of the Child.
schedule:
The Father shall have partial physical custody of the Child in accordance with the following
A. The Father shall have custody of the Child on Wednesday, October 24, 2007, when
the Mother shall transport the Child to the Father's residence when the Child awakens from her first
nap (approximately 11:30 a.m.) and the Father shall transport the Child to the Mother's residence
before work at 5:45 p.m. The parties agree that the Mother will remain at the Father's residence until
the Child begins her second nap (approximately 1:30 p.m.) so that the Mother and Father can exchange
information concerning the Child's care to ensure as much consistency as possible.
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B. The Father shall have custody of the Child on Saturday, October 27, 2007 from 9:00
a.m. unti15:45 p.m.
C. Thereafter, the Father shall have custody of the Child on an alternating bi-weekly
schedule as follows:
(1) WEEK ONE: The Father shall have custody during Week One on
Wednesday and Thursday from 9:00 a.m. unti15:45 p.m., beginning Wednesday, October 31, 2007.
(2) WEEK TWO: During Week Two, the Father shall have custody of the
Child on Tuesday, Friday and Saturday from 9:00 a.m. until 5:45 p.m. The parties agree that the
Father's first two weeks on the Week Two schedule shall include only Tuesday and Saturday from
9:00 a.m. unti15:45 p.m., which shall be expanded to include Fridays also beginning the third time that
the Father has a Week Two period of custody.
(3) Thereafter, the Father's periods of custody shall alternate between Week
One and Week Two on a regular basis and at any additional times as arranged by agreement between
the parties.
4. The parties agree that it is their intent to gradually increase the partial custody schedule to
eventually expand the Father's periods of custody to include overnight periods with the Child
consistent with the Child's adjustment and emotional well-being.
5. After January 1, 2008, counsel for either party may contact the conciliator to schedule an
additional custody conciliation conference, if necessary at that time to review expansion of the partial
custody schedule.
6. The parties acknowledge that the custody schedule set forth in this Order was intended to
maximize each parent's time with the Child during nonworking hours. The parties shall cooperate in
making any necessary adjustments to the custody schedule to accommodate changes in either party's
employment.
7. Each parent shall be entitled to have custody of the Child for one (1) uninterrupted week
each year for vacation upon providing at least thirty (30) days advance notice to the other parent. The
parties shall determine by agreement when expanded periods of custody under this provision may
begin based upon the Child's adjustment and emotional readiness.
8. The parties shall share having custody of the Child on holidays as follows:
A. Thanks ig ving~2007: In 2007, the Father shall have custody of the Child on
Thanksgiving Day from 10:00 a.m. unti12:00 p.m. and the Mother shall have custody for the
remainder of the holiday.
B. Christmas 2007: In 2007, the Father shall have custody of the Child on Christmas
Day from 10:00 a.m. until 2:00 p.m. and the Mother shall have custody for the remainder of the
holiday.
C. Easter: Beginning in 2008, the Mother shall have custody of the Child every year
on Easter Sunday.
D. The holiday custody schedule shall supersede and take precedence over the regular
custody schedule.
9. Neither party shall do or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natural development of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
10. 'This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
cc: ~ as D. Gould, Esquire -Counsel for Father
lane G. Radcliff, Esquire -Counsel for Mother
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ROBERT SNYDER IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 07-5080 CIVIL ACTION LAW
REBECCA HAINES
Defendant IN 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
Aleena Joy Haines September 23, 2006 Mother
2. A custody conciliation conference was held on October 22, 2007, with the following
individuals in attendance: the Father, Robert Snyder, with his counsel, Thomas D. Gould, Esquire, and
the Mother, Rebecca Haines, with her counsel, Diane G. Radcliff, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Date Dawn S. Sunday, Esquire
Custody Conciliator