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HomeMy WebLinkAbout09-2505IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CHRISTINA M. BOTTORF, Civil Action At Law---Custody Plaintiff, Case No. ?- VS. MICHAEL L. SNYDER, Defendant, COMPLAINT FOR CUSTODY 1. The plaintiff is Christina M. Bottorf, an adult individual currently residing at 19 Cassatt Street, Enola 17055 in the County of Cumberland, Commonwealth of Pennsylvania, The defendant is Michael L. Snyder, currently residing at PO Box 624 New Kingston, Pennsylvania 17072. 3. Plaintiff seeks custody of the following children: Name Address Age Samara M. Snyder Same as Mother's dob 5/24/2006 2 Years 4. The child was born outside of wedlock. 5. The child is presently in the custody of plaintiff Christina M. Bottorf, who resides at 19 Cassatt Street, Enola 17055 in the County of Cumberland, Commonwealth of Pennsylvania, 6. Since the childs' birth she has resided with the mother. 7. The biological mother of the child is Christina M. Bottorf, who currently resides at 19 Cassatt Street, Enola 17055 in the County of Cumberland, Commonwealth of Pennsylvania, 8. The mother is separated from the father and remains unmarried to the same. 9. The father of the child is Michael L. Snyder, and he is currently residing at PO Box 624 New Kingston, Pennsylvania 17072. 10. The father is separated from the mother and remains unmarried to the same. 11. The relationship of the plaintiff to the child is that of a biological Mother. The Plaintiff currently resides with the following persons: Name Relationship Samara A Snyder Daughter 12. The plaintiff has not participated as a parry or witness, or in another capacity, in any other litigation concerning the custody of the child in this or another court. 13. The plaintiff has no other information of a custody proceeding concerning the child Pending in a Court of this Commonwealth to the extent that the Order issued in the State of Virginia while it remains the only Order entered heretofore relative to the issue of custody neither party has resided within the State over a one year period prior to the effective date of this complaint. 14. 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. 4 < < M 15. The best interest and permanent welfare of the child will be served by Granting the relief requested because: (a) The mother can and has provided a stable, predictable and permanent environment for the children within which the children have a sense of stability and predictability with regard to their residence. (b) The child currently resides with her mother who has and continues to be the primary caretaker and caregiver to the child and within which the child feels a sense of comfort, permanency, and familiarity. (c) Plaintiff, believes and therefore avers that she can continue to provide a predictable and stable lifestyle which will be in the best interest of the children during her formative years and throughout her life. WHEREFORE, Plaintiff, Christina M. Bottorf, respectfully requests for the aforementioned reasons, that the court grant and award her Sole physical and Legal custody of the child, Samara M. Snyder. Dated: >a 44f GREGORY S. HAZLETT 7 Wes Main Street Mec nicsburg, PA. 17055 Phone: (717) 790-5500 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. & 4904 relating to unsworn falsification to authorities Date: W -a -a 9 Christina M. Bottorf, Plaintiff FILE', -U OF THE nv, ?TAp 2C199 APR 21 fd. 11: 51 C l.. t NITi"TP?f ! 4Il05. so PD ,AT'1 Y (.4a) l7K p 14y • C>y74. !01`1 CHRISTINA M. BOTTORF IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-2505 CIVIL ACTION LAW MICHAEL L. SNYER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, April 24, 2009 , 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 Courthouse, Carlisle on Tuesday, May 26, 2009 at 9:30 AM 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/ ac uellne M. Verne Es . 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 FILED-'Di ,E OF THE 2009 APR 27 At i; 2. 2 ??aT(af - &A.4 &ry 4y AVMLCCL :. '' CHRISTINA M. BOTTORF, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : N0.2009-2505 CIVIL ACTION -LAW MICHAEL L. SNYDER, . Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 14'h of September, 2009, having been advised that the parties have reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, /" ~ ac line M. Verney, Esquire, Cust dy Conciliator ~^ -.r,r j~ ~~~- l:vS'r4.fL. Z~~9 5~~ 15 ~~:' ~= ~'