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Home My WebLink About07-5328IOIA SNYDER, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY,~PENNSYLVANIA ~~~ RIC JONES, :Civil Action -Law Defendant : In Custody CONIPIA~T F4R CUSTODY 1. The Plaintiff is Gioia Snyder, an adult individual currently residing at 29 Pennway Drive, Carlisle, Cumberland County Pennsylvania. 2. The Defendant is Eric Jones, an adult individual currently residing at the 713 Ivy Lane, Tremont, IL 61568. 3. The Plaintiff and Defendant are the parents of one child namely: Sierra Dawn Jones, bom March 16, 2002. 4. The parties presently exercise custody of the child, pursuant to a Custody Stipulation and Agreement executed July 13, 2007. 5. During the past five years, the child has resided with the following FLO'V~ERIS,~ SAY 26 Wcst High Sweet Cazlisle, PA persons and at the following addresses: NAME ADDRESS FROM/TO Plaintiff and Defendant 29511 Anthony Rd. 2002-2003 Valley Center, CA Plaintiff and Defendant 1455 Zimmerman Rd. 2003-2005 Carlisle, PA Plaintiff and Defendant 29 Pennway Dr, 2005-8/06 Carlisle, PA Plaintiff 29 Pennway Dr. 8/06 to present Carlisle, PA r 6. The mother of the child is Gioia Snyder, currently residing as aforesaid. She is single. 7. The father of the child is Eric Jones, currently residing as aforesaid. He is single. 8. The relationship of the Plaintiff to the child is that of natural mother. The Plaintiff currently resides with the child at issue on a primary custody basis pursuant to the terms of the agreement dated July 13, 2007. 9. The relationship of the Defendant to the child is that of natural father. The Defendant currently resides alone. 10. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation concerning the custody of the child in this or another jurisdiction. 11. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 12. The 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. FUDWF.~t ~ LI1~1D'S~AY 26 West High Screw Carlisle, PA 13. The parties desire that the terms of the Custody Stipulation and Agreement executed by them on July 13, 2007 be incorporated into an Order of Court. 14. Pursuant to Local Rule 208.3(a), no Judge has been assigned to this custody matter previously. WHEREFORE, the Plaintiff requests this Court to grant her primary physical custody and sole legal custody of the child. Respectfully submitted, SAIDIS, FLOWER & LINDSAY Ma o atas, Es uire Attome .84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 9/ ~ ~~-~. Counsel for Plaintiff ~IS,~ IINDSAY 26 West Higfi Screct Carlisle, PA VERIFICATION I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworp falsification to authorities. 12x1 ~-, Date w r a ~• ~+~. r ~~ C G _,`. ~i ~~ ~Y> ''~~ »~ ..~ N t~ ~~i ~r ~+` ~~ r ~~ ~i-t rt~~ ~~` j~ a ti~ .~ GIOIA SNYDER, Plaintiff ERIC JONES, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . No. o ~- Sip Cam:! Tom.... Civil Action -Law In Custody STIPULATION AND AGREEMENT FOR CUSTODY THIS STIPULATION AND AGREEMENT entered into the day and year hereinafter set forth, by and between GIOIA SNYDER, (hereinafter referred to as "Mother') and ERIC JONES, (hereinafter referred to as "Father") WHEREAS, the parties are the natural parents of child, Siena Dawn Jones, bom March 16, 2002; WHEREAS, the parties live separate and apart, and wish to enter into a comprehensive stipulation and agreement relative to physical and legal custody of their children; NOW THEREFORE, in consideration of the mutual covenants, promises and agreements as herein set forth, the parties stipulate and agree as follows: 1. Mother shall exercise sole legal custody of the child. 2. Mother shall exercise primary physical custody of the child. FI~(]~VwER ~ LIIVDSAY 26 West High Stmt Cazlisle, PA 3. Father shall have periods of supervised visitation with the child at times as the parties may agree. 4. Father's periods of visitation are contingent upon his sobriety; he may not exercise custody at all if he has been drinking alcohol before his periods of custody. Father may not drink alcohol during his periods of custody with the child. Father shall attend counseling, such as Alcoholics Anonymous, to address the issue of his drinking, and shall follow the recommendations of the counselor with regard to attendance and frequency. Father shall provide proof to Mother upon her request that he is attending these counseling sessions. Father shall sign a counselor's release so that Mother's attorney may request information directly from the counselor or other therapist to ensure compliance with this provision. 5. The parties shall keep each other advised in the event of serious illness or medical emergency connsming the child and shall further take any necessary steps to ensure that the health and well-being of the child is protected. During such illness or medical emergency which might require hospital care, both parties shall have the right to visit the child at the hospital as often as he or she desires consistent with the proper medical care of the child. Father's visitation here must be supervised, as well. 6. Neither parent shall do anything which may estrange the child FZ~yV~ ~ LINDSAY 2G West High Street Carlisle, PA from the other party, injure the opinion of the child as to the other party, or which may hamper the free and natural development of the child's love and affection for the other party. 7. Any mod cation or waiver of any of the provisions of this Agreement on a permanent basis shall be effective only if made in writing, and only if executed with the same formality as this Stipulation and Agreement. 8. The parties desire that this Stipulation and Agreement be made an Order of Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody of the parties' minor child. 9. The parties stipulate that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other party. 10. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is not the result of any duress or undue influence. IN WITNESS WHEREOF, The parties hereto intending to be legally FTAWF.1t iSz LINDSAY 26 West High Sueec Cazlisle, PA bound by the terms hereof, set forth their hands and seals the day and year hereinafter mentioned. WITNESSETH: 0 Date _ioia Snyder Date Eric Jo s VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsifications to authorities. ~--- Gioia Snyder Date: -7 ~ ~ 3 ~ ~~ I verify that the statements made in the foregoing document are true FIAWlE1t'6z 26 west High street Cazlisle, PA and con-ect. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsecations to authorities. Date: p`//s'~b? to ~~ ~OMM1tTH OF PENNSYIYANIa NOTARIAL SEAL DAWN M. CAREY, Notsry Pub!!c 8oro of Catr~~N CurnbKland County ~~y ~ommlaa~n E~xplros Irv. 28, 201 r. ti,v~- Eric Jon !"t r`' O cp ~ ~, -,., -~ ~ -~' ~ r~i :' . ~ ' ~' rj°~ _~ ~.~_} "~ f_7 ~! . • see io~oo~~` GIOIA SNYDER, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA No. d'y - 5~3.2~ ~Ic.,~C l ~~ ERIC JONES, :Civil Action -Law Defendant : In Custody ORDER OF COURT ~~~ LIlVDgAY 26 w~ x;~t, s~ Carlisle, PA AND NOW, this /i ` day of ,.~,,,~-~.-- , 2007, the attached Stipulation and Agreement for Custody is hereby made an Order of Court. Cc: Marylou Matas, Esquire Attorney for Plaintiff Eric Jones, pro se Cumberland County Prison 1101 Claremont Road Carlisle, PA 17013 ~o ~~~ m~~ P Qli,~d 7 ~/~ ~ rC BY THE COURT: ~~~~~ ~t ~~ ~t era t t d~staat la~,~;u~d Lindsay Gingrich Maclay, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA ]7109 (717) 657-4795 GIOIA SNYDER, Plaintiff v. Docket No. 2007-5328 (Civil Term) ERIC JONES, Defendant ~ (~ Custody) PRAECIPE TO WITHDRAW ApPEA1~ANCE TO THE PROTHONOTARY: Kindly withdraw my appearance on behalf of Plaintiff, Gioia Sn der ' captioned custody matter. Y m the above- DATE: 8/ ~o/~~ By: a~rx.0 M atas, Esquire Saidis, ,Flower & Lindsay 26 W. Hight Street Carlisle, PA 17013 PRAECIPE FOR ENTRY OF AppE~ANCE TO THE PROTHONOTARY; Kindly enter my appearance and that of Daley Zucker Meilton Miner & G' on behalf of the Plaintiff, Gioia Snyder, in the above-captioned custod matter. mgrich, LLC, Y Date: a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Daley Zucker Meilton Miner & Gingrich, LLC By: - Li d ay Gi c M clay, Esq ~ e torney I. 87954 1029 Scenery Drive H~sb~'g, Pennsylvania 17109 (717) 657-4795 Attorney for Plaintiff ~°q ay ~, ' „1; _ C« j ,~1 _ ~ `~? i`t'"t r.~ !,t .. - ~~ ~,~ .. e~ a ~j _ ~"-i