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HomeMy WebLinkAbout08-1303Codi M. Tucker, Esquire Guida Law Offices 111 Locust Street Harrisburg, PA 17101 (717) 236-6440 STEVEN R. SNYDER IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. SARAH BRADSHAW No. 0 13 ° ? Cc ! -7' Defendant CIVIL ACTION - LAW CUSTODY COMPLAINT FOR CUSTODY Plaintiff, Steven R. Snyder, through his attorneys the Guida Law Offices and Codi M. Tucker, hereby petitions this Court for custody of his minor child. In support thereof, Plaintiff offers the following: 1. The plaintiff is Steven R. Snyder, residing at 138 Linda Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The defendant is Sarah Bradshaw, residing at 6609 Salem Church Circle, Mechanicsburg, Cumberland County, Pennsylvania 17050 3. Plaintiff seeks custody of the following child: Name DOB Skylar Bradshaw 5/26/07 A 4 The child was born out of wedlock. The child is presently in the custody of both parents, the parties have been exercising a shared custody schedule. During the past five years, the child has resided with the following persons and at the following addresses: Person Address Dates Steven Snyder- father 1-58 Linda Drive birth- Ray Snyder- grandfather Mechanicsburg, PA present Kathi Snyder- grandmother Sarah Bradshaw- mother 6609 Salem Church Circle 10/07- Steve Bradshaw- grandfather Mechanicsburg, PA present Stephanie Bradshaw- step gran dmother Sarah Bradshaw- mother Trindle Road 9/07- Maternal Aunt Mechanicsburg 10/07 Sarah Bradshaw-mother 6609 Salem Church Circle birth- Steve Bradshaw- grandfather Mechanicsburg, PA 9/07 Stephanie Bradshaw The mother of the child is Sarah Bradshaw, currently residing at 6609 Salem Church Circle, Mechanicsburg, Cumberland County, PA. She is single. The father of the child is Steven R. Snyder currently residing at 138 Linda Drive, Mechanicsburg, Cumberland County, PA 17050. He is single. 4. The relationship of the plaintiff to the child is that of father. The plaintiff currently resides at 138 Linda Drive, Mechanicsburg, Cumberland County, Pennsylvania. 5. The relationship of defendant to the child is that of mother. The defendant currently resides at 6609 Salem Church Circle, Mechanicsburg, Cumberland County, Pennsylvania. 6. Plaintiff has not participated in other litigation concerning the custody of the child in this court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because Father will provide structure and stability for the minor child. Further, Father will cooperate with Mother to provide periods of custody. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been names as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: there are no persons who are known or claim a right to custody. Wherefore, Plaintiff requests the court to grant his primary physical custody of the child subject to Defendant's periods of visitation. Respectfully submitted, Date: aly/0, By: Codi M. Tucker, Esquire Attorney for Plaintiff Guida Law Offices 111 Locust Street Harrisburg PA 17101 I . VERIFICATION I verify that the statements made in this Complaint are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. sec. 4904 relating to unsworn falsification to authorities. Date Steven R. Snyder, Plaintiff nn -- (31 VI O o > s f 1 r''? rj t _. - if : ?? J STEVEN R. SNYDER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-1303 CIVIL ACTION LAW SARAH BRADSHAW IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, March 05, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, April 03, 2008 at 12:00 PM 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunda Es q. ., LA 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 ono,,) " 9 Z :Z Wd S- avw 80QZ &VIONORLG d 3HI JO 30JUj +-•C331id STEVEN R. SNYDER IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. SARAH BRADSHAW No. 2008-1303 Civil Action Defendant CIVIL ACTION - LAW CUSTODY CERTIFICATE OF SERVICE I hereby certify that on March 12, 2008, 1 served a copy of the Custody Complaint upon Sarah Bradshaw and in the manner indicated below, which service satisfies the requirements of Pennsylvania Rule of Civil Procedure. 403. Service by U.S. Certified Mail to: Sarah Bradshaw 6609 Salem Church Road Mechanicsburg, PA 17050 Cmcli Codi M. Tucker, Esquire Guida Law Offices, P.C. 111 Locust Street Harrisburg, PA 17101 717-236-6440 Dated: March 14, 2008 0 n _ Postal CERTIFIED M AIL REC EIPI (Domestic Only; o M CO Postage $ F E ru certified Fee ' DF C3 Return Receipt Fee r 4';' , t _? `? Postmark aa ? He ?aa` NQ G (Endorsement Required) p 0 q Q- Restricted Delivery Fee (Endorsement Required) CO rU Total Postage & Fees $ 3? d ? ?f1SS1 ? C3 ent To h h ----- ....... `` orPOB `nw."le(nfllQ - Cr:Anry-) G1JR'a(1 ------- ¦ Complete items 1, 2, and 3. Also complete Nwn 4 If Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to yod. ¦ Attach this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: n 4DkNIA-) bto0 q ?1eam c??' ?' B. Recelved by (PrhKed Memo) D. Is delivery If YES, slivery addr?i 10 ? Addressee C. Dam DeMwry Ow- 00 3. Sendce types 13 certified Mail o Exp ose MaN ? Registered ? %tum Reoelpt for Merchendlee ? brewed man ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. NLrf6w 7004 2890 0002 8003 0104 (1?rmAr Aanr asrnioa hd P8 Form 3811, February 2004 Domestic Ream Reoeipt 1025e5-02-M-1540 1 e- rT7 31 +:1 (APR 1 i 200 STEVEN R. SNYDER Plaintiff VS. SARAH BRADSHAW Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-1303 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this /&A day of / / pzi , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Steven R. Snyder, and the Mother, Sarah Bradshaw, shall have shared legal custody of Skylar Bradshaw, born May 26, 2007. 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 parties shall share having physical custody of the Child on an alternating weekly basis with the exchange to take place every week on Sunday at 7:00 p.m. During the Mother's custodial week, the Father shall have custody of the Child from Thursday overnight into Friday, with the exchanges of custody to take place at the Child's daycare. During the Father's custodial weeks, the Mother shall have custody of the Child from Wednesday overnight through Thursday, with the exchanges of custody to take place at the Child's daycare. The alternating weekly schedule shall begin on April 3, 2008 with the Father having custody of the Child and the first exchange to take place on Sunday, April 6, 2008 at 7:00 p.m. with the beginning of the Mother's custodial week. 3. The parties shall share or alternate having custody of the Child on holidays as follows: A. Christmas: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 8:00 p.m. through Christmas Day at 1:00 p.m., and Segment B, which shall run from Christmas Day at 1:00 p.m. through December 26 at 8:00 p.m. In even-numbered years, the Father shall have custody of the Child during Segment A and the Mother shall have custody during Segment B. In odd-numbered years, the Mother shall have custody of the Child during Segment A and the Father shall have custody during Segment B. B. Thanksgiving: The Thanksgiving holiday shall be divided into Segment A, which shall run from the Wednesday before Thanksgiving at 8:00 p.m. through the Friday following Thanksgiving at 9:00 a.m., and Segment B, which shall run from the Friday following Thanksgiving at 9:00 a.m. through Sunday at 8:00 p.m. In even-numbered years, the Father shall have custody of the Child during Segment A and the Mother shall have custody during Segment B. In odd-numbered years, the Mother shall have custody of the Child during Segment A and the Father shall have custody during Segment B. C. New Year's/Easter/Memorial Da /yy July Fourth/Labor Day: The periods of custody for the New Year's, Easter, Memorial Day, July Fourth and Labor Day holidays shall run from 8:00 p.m. on the evening before the holiday through 8:00 p.m. on the day of the holiday. For purposes of this provision, the New Year's holiday shall be deemed to fall entirely within the same year as New Year's Day. In even-numbered years, the Mother shall have custody of the Child for New Year's, Memorial Day and Labor Day and the Father shall have custody for Easter and July Fourth. In odd- numbered years, the Father shall have custody of the Child for New Year's, Memorial Day and Labor Day, and the Mother shall have custody for Easter and July Fourth. D. Mother's Day/Father's DM: In every year, the Mother shall have custody of the Child for Mother's Day and the Father shall have custody for Father's Day from 8:00 p.m. on Saturday through the regular time for the exchange of custody on Sunday, unless that party is retaining custody under the regular schedule. E. The holiday custody schedule shall supersede and take precedence over the regular custody schedule and the summer vacation schedule. 4. During the summer every year, each parent shall be entitled to have custody of the Child for an uninterrupted full week for up to three (3) times each year, upon providing at least 30 days advance notice to the other party. The parties shall schedule periods of custody under this provision during his or her regular alternating weeks of custody. 5. Unless otherwise agreed between the parties, the parent receiving custody shall be responsible to provide transportation for the exchange of custody. Both parties shall transport the child only in registered, inspected vehicles. The Father shall not transport the Child in his Porsche. Both parties shall use proper child restraints in accordance with the law at all times. 6. Within ten (10) days of notice provided by the Mother, both parties shall undergo drug testing for detection of marijuana use, the costs of which shall be paid in full by the Mother. 7. Both parties shall ensure that the other party has his or her current address and telephone number at all times. 8. In the event either party intends to remove the Child from his or her residence for an overnight period or longer, that parent shall provide the address and telephone number where the Child can be contacted to the other parent in advance. 9. The non-custodial parent shall be entitled to have reasonable telephone access with the Child. 10. 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. 11. The parties and their counsel shall attend an additional custody conciliation conference in the office of the conciliator, Dawn S. Sunday, on Tuesday, July 18, 2008 at 9:00 a.m., at which time the custodial arrangements shall be reviewed. 12. 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. BY TYE COURT, J. cc: '?Codi M. Tucker, Esquire - Counsel for Father ?Jaime D. Wassmer, Esquire - Counsel for Mother l:O ? E'er rYl cl? l£rJ? C 0 : i l P, V 91 L? d- V G0CZ STEVEN R. SNYDER Plaintiff vs. SARAH BRADSHAW Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-1303 CIVIL ACTION LAW 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 Skylar Bradshaw May 26, 2007 Father/Mother 2. A custody conciliation conference was held on April 3, 2008, with the following individuals in attendance: the Father, Steven R. Snyder, with his counsel, Codi M. Tucker, Esquire, and the Mother, Sarah Bradshaw, with her counsel, Jaime D. Wassmer, Esquire and her law clerk, Sarah Prather. 3. The parties agreed to entry of an Order in the form as attached. -7 o)- o j Date Dawn S. Sunday, Esquire Custody Conciliator JUL 2 5 2008 STEVEN R. SNYDER Plaintiff VS. SARAH BRADSHAW Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-1303 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this ? /P A day of G-ra 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated April 16, 2008, shall continue in effect as modified by this Order. 2. The parties and their counsel shall attend a custody conciliation conference in the office of the conciliator, Dawn S. Sunday, on Wednesday, August 13, 2008, at 8:30 a.m. for the purpose of reviewing the custodial arrangements. 3. Pending the follow-up conciliation conference and further Order of Court or agreement of the parties, the Mother's overnight periods of custody with the Child shall take place at the maternal grandparents' residence. cc: ?Codi M. Tucker, Esquire - Counsel for Fathe. v,$ ah Bradshaw - Mother soot 5 z inr Edward E. Guido J. ? .'.?? ?? rL ' .r ??" _ i.... f`1 1 '- . i? ?- ?? ?' l?.t,,-? c.a _„? ? -,?' c STEVEN R. SNYDER Plaintiff vs. SARAH BRADSHAW Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-1303 CIVIL ACTION LAW 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 Skylar Bradshaw May 26, 2007 Father/Mother 2. A custody conciliation conference was held on July 18, 2008, with the following individuals in attendance: the Father, Steven R. Snyder, with his counsel, Codi M. Tucker, Esquire. The Mother did not attend the conference or contact the conciliator. The Father's counsel had been notified that the Mother is no longer represented by counsel in this matter. 3. This Court previously entered an Order in this matter on April 16, 2008, under which the parties agreed to share custody of the Child on an alternating weekly basis. This follow-up conciliation conference was scheduled as part of that Order. 4. According to the Father, the Mother had moved out of her parents' residence since the initial conciliation conference but that the Child was staying with the maternal grandparents during the Mother's periods of custody while the Mother is residing with her boyfriend. The Father expressed concerns about the Child's well-being while in the Mother's care outside of the maternal grandparents' residence. However, those concerns could not be addressed due to the Mother's absence from the conference. 5. Based upon the representations of the Father at the conference and the fact that the Mother did not attend or contact the conciliator, the conciliator recommends an Order in the form as attached confirming the current arrangements for the Child during the Mother's weeks of custody and scheduling an additional conference to ensure the Mother's participation. o to _ Date Dawn S. Sunday, Esqui Custody Conciliator 3 AUG 18 2008 STEVEN R. SNYDER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2008-1303 CIVIL ACTION LAW SARAH BRADSHAW Defendant IN CUSTODY ORDER OF COURT AND NOW this -l * day of k4o-?? , 2008, upon consideration of the attached Custody Conciliation Report, i is ordered and directed as follows: 1. The prior Order of this Court dated April 16, 2008 shall continue in effect. 2. The prior Order of this Court dated July 29, 2008 is vacated. 3. The parties shall make arrangements to attend the Seminar for Separating Parents as soon as possible following the custody conciliation conference. 4. The parties shall make arrangements for regular and continuing communication regarding issues related to the Child or the custodial schedule either by scheduled meetings or telephone calls. 5. The parties acknowledge the importance of maintaining communication and cooperation in co-parenting their Child. The parties agree to enlist the support of their friends and family members in ensuring non-interference with direct communications between the parties. 6. 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: keodi M. Tucker, Esquire - Counsel for Father ,?iarah Bradshaw - Mother A Edward E. Guido J. ! ,:2, : ! Pj 6 I o v oooz ?tGlt f ?J!'V"?xt .ill JC .3"Hi jQ STEVEN R. SNYDER Plaintiff vs. SARAH BRADSHAW Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-1303 CIVIL ACTION LAW 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 Skylar Bradshaw May 26, 2007 Father/Mother 2. A custody conciliation conference was held on August 13, 2008, with the following individuals in attendance: the Father, Steven R. Snyder, with his counsel, Codi M. Tucker, Esquire, and the Mother, Sarah Bradshaw, who is not represented by counsel in this matter. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator STEVEN R. SNYDER : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA VS CIVIL ACTION- CUSTODY SARAH BRADSHAW DEFENDANT : NO. 2008-1303 NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. Your are warned that if you fail to do so the case may proceed without you and a decree of devorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM 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 32 SOUTH BEDFROD STREET CARLISLE, PA 17013 (717) 249-3155 STEVEN R. SNYDER : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION- CUSTODY SARAH BRADSHAW DEFENDANT : NO. 2008-1303 PETITION TO INTERVENE Plaintiff, Ray and Kathy Snyder, by their attorney Gail Guida Souders, Esquire, respectfully avers the following counts through Civil Procedure Rule 1915.15 (a): 1. Plaintiff is Steven R. Snyder (hereinafter called "Father") residing at 138 Linda Drive, Mechanicsburg, PA 17050. 2. Defendant is Sarah Bradshaw (hereinafter called "Mother") residing at 6609 Salem Park Circle, Mechanicsburg, PA 17050. 3. Interveners are Ray Snyder and Kathy Snyder (hereinafter called "Grandfather and Grandmother") residing at 138 Linda Drive, Mechanicsburg, PA 17050. 4. Steven R. Snyder and Sarah Bradshaw are parents to one minor child namely Skylar Bradshaw born May 26, 2007. S. There is an existing custody Order entered on April 16, 2008, a true and correct copy of which is attached. See Exhibit A. 6. Grandparents are seeking to intervene the current Order because: a. When Father exercised his custodial rights, the child has resided in their home since birth. b. Father has had shared physical custody since the child was born. c. Since August or September, Mother and her then live in boyfriend have been under investigation by Social Services for Children and Youth. d. Mother has been barred from having unsupervised visits pursuant to the investigation. e. There is also a criminal investigation against Mother and then live in boyfriend for allegation of physical abuse. f. Mother has not consistently exercised her supervised visitation rights. g. Grandparents have assumed the primary caretaking role since the investigation. h. Father's work scheduled has become demanding which required him to leave child alone with Grandparents for periods of time. i. Father is young and his future is unknown. j. Grandparents can and will provide a stable environment for the child. k. Grandparents are able to provide food, shelter, and health insurance for the child. 1. Father consents with this request. See Exhibit B. in. Mother is not permitted to have unsupervised visits until further notice from Social Services from Children and Youth. 7. For all these reasons stated above, Interveners request that the court grant them shared physical custody and legal custody of Skylar Bradshaw with Father. 8. Moreover, the parties' request that the court grants partial custody to Mother in lieu of supervised visitation pursuant to Social Services for Children and Youth. WHEREFORE, Plaintiff and Interveners request that the Court modify the existing Order for shared physical custody and legal custody of Skylar Bradshaw with Father because it would be in the best interest of the child. M Gail Guida Souders Attorney for Petitioners Guida Law Offices, P.C. I I 1 Locust Front Street Harrisburg, PA 17101 717-236-6440 Supreme Court ID #68740 ,2n,;7 C 569' P.CCS .'00 I, Rey Snyder, verify that the statements made in this Petition are true and correct. I tmderstand that false statements herein are wade subject to the penalties of 18 Pa.C.S.A § 4904, relating to ttnsworn falsification to authorities. DATE{ 1 1 11 01 F A- VAN A G 11 1 XW 1 Is Ll\ 1, Kathy Snyder, verify that the statements made in this Petition are true and correct. I understand that false statements herein are trade subject to the penalties of 18 Pa.C.S.A § 4904, relating to unsworn falsification to authorities. KA S /? DATE, It W13 ? l ATTORNEY FOR PETITIONER l (APR 11200er- STEVEN R. SNYDER Plaintiff vs. SARAH BRADSHAW Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA 2008-1303 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this ? day of 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Steven R. Snyder, and the Mother, Sarah Bradshaw, shall have shared legal custody of Skylar Bradshaw. born May 26, 2007. 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 parties shall share having physical custody of the Child on an alternating weekly basis with the exchange to take place every week on Sunday at 7:00 p.m. During the Mother's custodial week , the Father shall have custody of the Child from Thursday overnight into Friday, with the exchanges of custody to take place at the Child's daycare. During the Father's custodial weeks, the Mother shall have custody of the Child from Wednesday overnight through Thursday, with the exchanges of custody to take place at the Child's daycare. The alternating weekly schedule shall begin on April 3, 2008 with the Father having custody of the Child and the first exchange to take place on Sunday. April 6, 2008 at 7:00 p.m. with the beginning of the Mother's custodial week. 3. The parties shall share or alternate having custody of the Child on holidays as follows: Exhibit A A. Christmas: The Christmas holiday shall-be divided into Segment A. which shall run from Christmas Eve at 8:00 p.m. through Christmas Day at 1:00 p.m.. and Segment B, which shall run from Christmas Day at 1:00 p.m. through December 26 at 8:00 p.m. In even-numbered years, the Father shall have custody of the Child during Segment A and the Mother shall have custody during Segment B. In odd-numbered years, the Mother shall have custody of the Child during Segment A and the Father shall have custody during Segment B. B. Thanksgiving: The Thanksgiving holiday shall be divided into Segment A, which shall run from the Wednesday before Thanksgiving at 8:00 p.m. through the Friday following Thanksgiving at 9:00 a.m., and Segment B, which shall run from the Friday following Thanksgiving at 9:00 a.m. through Sunday at 8:00 p.m. In even-numbered years, the Father shall have custody of the Child during Segment A and the Mother shall have custody during Segment B. In odd-numbered years, the Mother shall have custody of the Child during Segment A and the Father shall have custody during Segment B. C. New Year's/Easter/Memorial Day/July Fourth/Labor Day: The periods of custody for the New Year's, Easter, Memorial Day,. July Fourth and Labor Day holidays shall run from 8:00 p.m. on the evening before the holiday through 8:00 p.m. on the day of the holiday. For purposes of this provision, the New Year's holiday shall be deemed to fall entirely within the same year as New Year's Day. In even-numbered years, the Mother shall have custody of the Child for New Year's, Memorial Day and Labor Day and the Father shall have custody for Easter and July Fourth. In odd- numbered years, the Father shall have custody of the Child for New Year's, Memorial Day and Labor Day, and the Mother shall have custody for Easter and July Fourth. D. Mother's Day/Father's Day: In every year, the Mother shall have custody of the Child for Mother's Day and the Father shall have custody for Father's Day from 8:00 p.m. on Saturday through the regular time for the exchange of custody on Sunday, unless that party is retaining custody under the regular schedule. E. The holiday custody schedule shall supersede and take precedence over the regular custody schedule and the summer vacation schedule. 4. During the summer every year, each parent shall be entitled to have custody of the Child for an uninterrupted full week for up to three (3) times each year, upon providing at least 30 days advance notice to the other party. The parties shall schedule periods of custody under this provision during his or her regular alternating weeks of custody. 5. Unless otherwise agreed between the parties, the parent receiving custody shall be responsible to provide transportation for the exchange of custody. Both parties shall transport the child only in registered, inspected vehicles. The Father shall not transport the Child in his Porsche. Both parties shall use proper child restraints in accordance with the law at all times. 6. Within ten (10) days of notice provided by the Mother, both parties shall undergo drug testing for detection of marijuana use, the costs of which shall be paid in full by the Mother. 7. Both parties shall ensure that the other party has his or her current address and telephone number at all times. Exhibit A 8. In the event either party intends to remove the Child from his or her residence for an overnight period or longer, that parent shall provide the address and telephone number where the Child can be contacted to the other parent in advance. 9. The non-custodial parent shall be entitled to have reasonable telephone access with the Child. 10. 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. 11. The parties and their counsel shall attend an additional custody conciliation conference in the office of the conciliator, Dawn S. Sunday, on Tuesday, July 18, 2008 at 9:00 a.m., at which time the custodial arrangements shall be reviewed. 12. 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. BY J. cc: Cod] M. Tucker, Esquire - Counsel for Father Jaime D. Wassmer, Esquire - Counsel for Mother i h S ""''' xhibit A STEVEN R. SNYDER Plaintiff vs. SARAH BRADSHAW Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA 2008-1303 CIVIL ACTION LAW 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 Skylar Bradshaw May 26, 2007 Father/Mother 2. A custody conciliation conference was held on April 3, 2008, with the following individuals in attendance: the Father, Steven R. Snyder, with his counsel, Codi M. Tucker, Esquire, and the Mother, Sarah Bradshaw, with her counsel. Jaime D. Wassmer. Esquire and her law clerk, Sarah Prather. 3. The parties agreed to entry of an Order in the form as attached. -7 ao??? 1 Date Dawn S. Sunday, Esquire Custody Conciliator Exhibit A AFFIDAVIT I, Steven R. Snyder, agree to a share physical and legal custody of Skylar Bradshaw with my parents, Ray Snyder and Kathy Snyder. Date: /l /11 /0?40j _" - 7 ? ?- ? e. ??? Steven R. Snyder Exhibit B .,.F T HIE Y 2003 K'u`i 2 F 2% -70,06 fct ck 41 ?b STEVEN R. SNYDER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-1303 CIVIL ACTION LAW SARAH BRADSHAW IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, December 03, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, January, 05, 2010 at 1:00 PM 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/ Dawn S. Sunda Es o. 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 IARY 20,09 DEC -3 RH I3 G 'iv`: ?z STEVEN R. SNYDER Plaintiff VS. SARAH BRADSHAW Defendant JAN 111010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-1303 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 4k day of 2( I, upon consideration of the attached Custody Conciliation port, it is or ered and directed as follows: 1. The Father, Steven R. Snyder, and the Mother, Sarah Bradshaw, shall have shared legal custody of Skylar Bradshaw, born May 26, 2007. In the event primary physical custody of the Child transfers to the paternal grandparents pursuant to this Order, the paternal grandparents shall also have shared legal custody of the Child. 2. The Father shall have primary physical custody of the Child on the condition that the Father continues to reside in the paternal grandparents' residence. In the event the Father discontinues residing in the paternal grandparents' residence, primary custody of the Child shall transfer to the paternal grandparents and the Father shall have partial physical custody of the Child as arranged by agreement between the Father and the paternal grandparents. The terms of primary custody under this provision shall be without prejudice to the Mother's right to reassert her request for resumption of the shared physical custody schedule at such time as permitted in connection with the Children and Youth Services involvement. 3. The Mother shall have periods of supervised visitation with the Child as required by the plan established by Children and Youth Services. At such time as Children and Youth Services completes the investigation and determines that the Mother is able to resume having periods of shared physical or partial physical custody with the Child, an additional custody conciliation conference shall be scheduled by the conciliator upon the Mother's request and provision of written confirmation of the determination by Children and Youth Services. 4. The Mother shall provide copies of the Child's Social Security card and Birth Certificate to the Father within seven days of the custody conciliation conference and shall thereafter provide an original Birth Certificate to the Father as soon as possible. B 2 THE T N Edward E. Guido J. w cc: ?al1 Guida Souders, Esquire - Counsel for paternal grandparents /Steven R. Snyder - Father -- arah Bradshaw - Mother co -2S (2?r f ?f?a f?v .2 N 22 c_x 7 d STEVEN R. SNYDER Plaintiff VS. SARAH BRADSHAW Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-1303 CIVIL ACTION LAW 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 Skylar Bradshaw May 26, 2007 Father 2. A custody conciliation conference was held on January 5, 2010, with the following individuals in attendance: the paternal grandparents, Ray and Kathy Snyder, with their counsel, Gail Guida Souders, Esquire, and the Father, Steven R. Snyder, pro se and the Mother, Sarah Bradshaw, who appeared with her father, Steve Bradshaw, but is not represented by counsel. 3. The paternal grandparents filed this Petition to Intervene in this previously filed custody matter between the parents. This Court entered an Order in this matter on April 16, 2008 under which the Father and the Mother shared physical custody of the Child on an alternating weekly basis. In September 2009, Children and Youth Services initiated an investigation involving the Mother, her boyfriend, and the maternal grandparents (because the Mother was living in their residence at the time) and the Court held a hearing on that matter on January 4, 2010. The parties represented that Children and Youth Services has imposed restrictions on the Mother's contact with the Child to the extent that the Mother is limited to supervised visitation pending completion of the Children and Youth Services investigation and completion by the Mother of imposed requirements. 4. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator