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HomeMy WebLinkAbout09-6670CINDY A. SNYDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2009- CIVIL TERM KEITH A. WINDEMAKER, Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Cindy A. Snyder, by her attorneys, Irwin & McKnight, P.C., and presents the following Complaint for Custody. 1. The Plaintiff, Cindy A. Snyder, is an adult individual with an address of 42 Wagner Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, Keith A. Windemaker, is an adult individual with an address of 75 Bonneybrook Road, Lot #1, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of three (3) children, namely, Austin L. Windemaker, born June 8, 1997; Bradley S. Windemaker, born September 6, 1999; and Desteny N. Windemaker, born May 21, 2001. 4. The Plaintiff, Cindy A. Snyder, desires that the parties have shared legal custody of the minor children, Austin L. Windemaker, Bradley S. Windemaker, and Desteny N. Windemaker. 5. The Plaintiff, Cindy A. Snyder, desires primary physical custody of the said minor children with periods of temporary physical custody to Defendant, Keith A. Windemaker, as the parties can agree. 6. The best interests and permanent welfare of the minor child requires that the Court grant the Plaintiff's request as set forth above. WHEREFORE, the Plaintiff, Cindy A. Snyder, respectfully requests that she be awarded primary physical custody and shared legal custody of the minor children, Austin L. Windemaker, Bradley S. Windemaker, and Desteny N. Windemaker as provided herein, with periods of temporary physical custody to Defendant, Keith A. Windemaker, as provided herein. Respectfully §ubmi By: IRWIN &McKNIGHT Marc "A. McK igkf, M, Esquire Atto y for Plaintiff 60 W st Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court I. D. No. 25476 Date: October 7, 2009 VERIFICATION The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. I 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. V-IN-DY A. E Date: October 7, 2009 FILED-.O FFir;F OF THE PP`s' t,.',',)TARt' 2009 OCT -l Alf 9: 52 €'EINNSYL.VAJ 4o S- - 0 A? fi ml9?w CINDY A. SNYDER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-6670 CIVIL ACTION LAW KEITH A. WINDEMAKER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, October 29, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, November 18, 2009 at 8:30 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/ Hubert X. Gilroy, Es q. 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 r 2?tf9 OCT 29 Am 11: 18 /V I?ip 'or I U CINDY A. SNYDER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW KEITH A. WINDEMAKER, NO. 2009-6670 Defendant IN CUSTODY COURT ORDER AND NOW, this p day of November, 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows. cc: 1. The mother, Cindy A. Snyder, and the father, Keith A. Windemaker, shall enjoy shared legal custody of Austin L. Windemaker, born June 8, 1997, Bradley S. Windemaker, born September 6,1999 and Desteny N. Windemaker, born May 21, 2001. 2. The mother shall enjoy primary physical custody of the minor children and the father shall enjoy liberal periods of temporary physical custody of the minor children at such times as the parties agree. 3. Commencing January 1, 2010 and assuming father relocates into the Cumberland Valley School District with the children, the parties shall have shared physical custody of the minor children pursuant to a schedule as agreed upon by the parties. 4. The parties shall also share holidays pursuant to a schedule as agreed upon by the parties. 5. In the event either party desires to modify this Order, that party may petition the Court to have the case again scheduled before the Custody Conciliator for a Conference. Marcus A. McKnight, III, Esquire Mr. Keith A. Windemaker?' 2 FkLEl--&- r"ICE jWr Pp, )T,,P 0TARY 2004 NOV 23 AM 9., 22 l.l4t ! PENNSYLVANIA CINDY A. SNYDER, Plaintiff vs. KEITH A. WINDEMAKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2009-6670 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Austin L. Windemaker, born June 8,1997, Bradley S. Windemaker, born September 6,1999 and Desteny N. Windemaker, born May 21, 2001. 2. A Conciliation Conference was held on November 18, 2009, with the following individuals in attendance: The mother, Cindy A. Snyder, who appeared with her counsel, Marcus A. McKnight, III, Esquire, and the father, Keith A. Windemaker, did not attend. However, the mother related that she and the father had worked things out and the father did not attend because he was going to be at work. 3. The Conciliator recommends an Order in the form as attached. Date: (('( , 2009 CJ Hubert X. Gilroy, E uire Custody Conciliato FILED, 0r fir P ` 7I''-'I')1, 7 AJW 2009 NOV 23 AM 9: 2; Nlr rPE?.'Yi