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Home My WebLink About10-0171NICOLE LEE KLINGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 10- 171 CIVIL TERM MICHAEL EUGENE SNYDER, : Defendant CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Nicole Klinger, hereinafter referred to as Mother. Mother resides at 316R Eutaw Ave, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant is Michael Snyder, hereinafter referred to as Father. It is believed that Father is residing at 524 North Second Street, Lykens, Dauphin County, Pennsylvania 17048. 3. Mother seeks primary physical custody of the minor child: Name Present Residence Age Kaitlyn Snyder 524 North Second Street 8/12/05 DOB, 4 years old Lykens, PA 17048 Kaitlyn was born out of wedlock. Kaitlyn is presently in the custody of Father. During her lifetime, Kaitlyn has resided with the following persons and at the following addresses: Name Nicole Klinger Michael Snyder Curtis Trutt Michael Snyder Nicole Klinger Curtis Trutt Gary Buffington Address 120 Pearl Street Millersburg, PA 120 Pearl Street Millersburg, PA 747 Railroad St. Millersburg, PA Date birth - 7/06 7/06 - 8/07 7/06 - 8/06 Nicole Klinger 200 Denison Drive 8/06 - 2/09 Jason Donn Dauphin, PA Curtis Trutt Michael Snyder Nicole Klinger Curtis Trutt Nicole Klinger Curtis Trutt Greg H?llrison Williamstown, PA 405 High Street Dauphin, PA 316R Eutaw Ave New Cumberland, PA 8/06 - 8/07 2/09 - 8/09 8/09 - 12/09 Michael Snyder Mandy Welcomer Christopher Snyder Kirkland Snyder Phoenix Snyder Bailey Snyder 524 N. Second Street Lykens, PA 5. Mother lives with the following persons: Name Greg Harrison Curtis Trutt 8/07 - present Relationship Boyfriend Son from prior relationship 6. It is believed that Father lives with the following persons: Name Relationship Mandy Welcomer Girlfriend Christopher Snyder Son Kirkland Snyder Son Phoenix Snyder Son Bailey Snyder Son 7. Mother has not participated as a party or witness, or in another capacity, in other custody litigation concerning the custody of Kaitlyn in this or another court. 8. Mother has no information of a custody proceeding concerning Kaitlyn pending in i court of this Commonwealth. 9. Mother does not know of a person not a party to the proceedings who has physical custody of Kaitlyn or claims to have custody or visitation rights with respect to Kaitlyn. 10. Kaitlyn's best interest and permanent welfare will be served by granting the relief requested for reasons including, but not limited to the following: a. Since Kaitlyn was born, Mother has shared equally in the responsibility for her emotional, physical, educational, financial and medical needs. b. Mother is fully capable of caring for Kaitlyn on a primary basis. c. Mother is willing to communicate with and work cooperatively with Father to co- parent Kaitlyn and will encourage their father/daughter relationship. d. Kaitlyn is about to start school and Mother believes that her school district will provide a better education for Kaitlyn. 11. Defendant is not acting in Kaitlyn's best interests for reasons including, but not limited to, the following: a. Father has unilaterally decided to stop Mother's ability to spend time with Kaitlyn despite the fact that until the beginning of December 2009, the parties had been following a week-on/week-off custody schedule. b. Father has reconciled with his ex-girlfriend who has become confrontational with Mother during Mother's attempts to speak to Father about Kaitlyn. c. Father either refuses to respond to Mother's calls or refuses to return Mother's messages regarding Kaitlyn. d. Father's decision to withhold Kaitlyn from Mother demonstrates a total disregard for Kaitlyn's best interests. 12. Every person with rights to custody or having actual physical custody of Kaitlyn has been named as parties to this action. WHEREFORE, Mother requests this Court to grant her the following relief: 1. That the parties shall share legal custody of Kaitlyn. 2. That Mother shall have primary physical custody of Kaitlyn. 3. That Father shall have periods of partial physical custody with Kaitlyn. 4. That the parties shall have an appropriate holiday schedule so that both parents can spend time with Kaitlyn. 5. Any other relief this Court finds just and equitable. Respectfully submitted, Je sica Holst, Esquire MidPenn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 VERIFICATION The above-named PLAINTIFF, Nicole Klinger, verifies that the statements made in the above COMPLAINT FOR CUSTODY are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: ? v? Nicole Lee Kling r NICOLE LEE KLINGER, IN THE COURT OF COMMON PLEAS OF Plaintiff vs. MICHAEL EUGENE SNYDER, Defendant : CUMBERLAND COUNTY, PENNSYLVANIA NO. 10- CUSTODY AFFIDAVIT OF SERVICE BY MAIL CIVIL TERM I, Jessica Holst, do hereby swear that I served Michael Eugene Snyder, with a Complaint in Custody on JA/WC%rq S , 2010 by certified mail, return receipt, restricted delivery, to the person and address below: Michael Eugene Snyder 524 North Second Street Lykens, PA 17048 I, Jessica Holst, verify that the statements made in this Affidavit of Service are true and correct. 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. Date: Signature: r NICOLE LEE KLINGER, vs. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL EUGENE SNYDER, Defendant NO. 10- ('? : CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: CIVIL TERM 1.: 1 . y Kindly allow, Nicole Lee Klinger, Plaintiff, to proceed in forma au eris. I, Jessica Holst, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Jes ica Holst, Esquire MidPenn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 NICOLE LEE KLINGER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. MICHAEL EUGENE SNYDER DF:F FNDANT 2010-171 CIVIL ACTION LAW IN CUSTODY ORDER OF C0U12T AND NOW, Thursday, January 07, 2010 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 Monday, February 08, 2010 at 12:00 PM for a Pre-f-learing, 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, Bv: /s/ Dawn S. Sunday?Esq. I,Yy? 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 o)TARy 2010 JA; 3 9 CU NICOLE LEE KLINGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2010-171 CIVIL TERM MICHAEL EUGENE SNYDER, Defendant CUSTODY PRAECIPE TO WITHDRAW COMPLAINTf FOR CUSTODY To the Prothonotary: Please withdraw without prejudice the Complaint for Custody brought by Plaintiff, Nicol Lee s Klinger, in the above captioned case. ?'! L zi Resp ly submitted: = rr, Holst, Esquire NN LEGAL SERVICES 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 I.D. # 82214 a S JAN : g 20)0 NICOLE LEE KLINGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2010-171 CIVIL TERM MICHAEL EUGENE SNYDER, Defendant CUSTODY . C? N ORDER OF COURT c:) ?? oil AND NOW, this _--?,-_- day of 4J?? 2010, upon consideration of the Praecipe to Withdraw Petition filed on behalf of Plaintiff, Nicole Lee Klinger, the Complaint for Custody is withdrawn without prejudice. By the Court, t Judge D' tribution: essica Holst, Esquire 401 East Louther Street Carlisle, PA 17013 mily Long Hoffman, Esquire 105 North Front Street P.O. Box 11475 Harrisburg, PA 17108-1475 CCFI;u eyv?tt(F-C'L I f ?c? f !v ^J nl? -r? rn -r7 c,J y NICOLE LEE KLINGER, Plaintiff VS. MICHAEL EUGENE SNYDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-171 CIVIL TERM CUSTODY PRAECIPE TO WITHDRAW COMPLAINTS FOR CUSTODY To the Prothonotary: Please withdraw without prejudice the Complaint for Custody brought by Plaintiff, Nicole Lee a Klinger, in the above captioned case. r n Resp ly submitted: rnry -`? X- Jes ica Holst, Esquire M PENN LEGAL SERVICES 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 I.D. # 82214 V? o 2o?a NICOLE LEE KLINGER Plaintiff vs. MICHAEL EUGENE SNYDER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2010-171 CIVIL ACTION LAW IN CUSTODY ORDER C) C) ?? CJ c 4 o 1 p Y; c: N c5 AND NOW, this 26th day of January, 2010 , the conciliator, having been notified by Plaintiff s counsel that the Complaint for Custody has been withdrawn, hereby relinquishes jurisdiction. The custody conciliation conference scheduled for February 8, 2010 is cancelled. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator