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HomeMy WebLinkAbout04-2940 Shawn Lee Snyder, Plaintiff, v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. oL/- ;1.. qq. 0 Heather Lynn Miller, Defendant. IN CUSTODY COMPLAINT FOR CUSTODY I. The plaintiff is Shawn Lee Snyder, residing at 46 Walnutdale Road, Shippensburg, Cumberland County, Pennsylvania. 2. The defendant is Heather Lynn Miller, believed to be residing at 237 S. Washington Street, Greencastle, Pennsylvania. 3. Plaintiff seeks custody ofthe following children: Name Present Residence DOB Age Dylan M. Snyder 46 Walnutdale Road Shippensburg, P A 17257 5/1/99 :; Derek M. Snyder 46 Walnutdale Road Shippensburg, P A 17257 10/17/00 :; The children were born out of wedlock The children are presently in the custody of Shawn Snyder who resides at 46 Walnutdale Road, Shippensburg, Cumberland County, Pennsylvania. During the past five years, the children have resided with the following persons and at the following addresses: List All Persons Heather Miller and Shawn Snyder List All Addresses 46 Walnutdale Road Shippensburg, P A 17257 Dates Birth to 6/21/04 The mother of the children is Heather Lynn Miller, believed to be residing at 237 S. Washington Street, Greencastle, Pennsylvania. She is unmarried. The father of the children is Shawn Lee Snyder, residing at 46 Walnutdale Road, Shippensburg, Cwnberland County, Pennsylvania. He is unmarried. 4. The relationship of plaintiff to the children is that of father. The plaintiff currently resides with the following persons. Name Dylan M. Snyder Derek M. Snyder Relationship Son Son 5. The relationship of defendant to the children is that of mother. The defendant is believed to currently be residing with the following persons. Name Deb Highlands Terry Highlands Relationship Mother Step-father 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and 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 request because: Plaintiff has undertaken and performed the primary parental responsibilities for the children. Plaintiff is best able to provide the care and nurture which the children need for healthy development. Defendant does not currently have housing arranged for herself and the children. 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 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 thc right to intervene: N/A WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody in the Father with visitation in the Mother as agreed to by the parties. RespectfulJy submitted, Rominger, BAYLEY & WHARE .---:- Date: ./,",I?~.:l-,,; L <7,,,,, 7 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff Shawn Lee Snyder, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. Heather Lynn Miller, Defendant. IN CUSTODY 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. Cons. Stat. ~ 4904 relating to unsworn falsification to authorities. ~g Shawn Lee Shawn Lee Snyder, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. Heather Lynn Miller, Defendant. IN CUSTODY CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Plaintiff, do hereby certify that I this day served a copy of the Petition for Emergency Reliefupon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Heather Lynn Miller 237 S. Washington Street Greencastle, P A 17225 - '-----, . ./ < Date: ./v 1~ .l ~ 2 CI'? ;/ Karl E. Rominger, Esquire Attorney for Plaintiff iOptJ:t0 ~ ::t:-:::.::> .~ D:ft: t d' W 0\D G\ 0 00<) ~ 3 - ~' (b 7J ,.. :> -', ~-~ ~~ r-i Shawn Lee Snyder, Plaintiff, v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ; NO. 0 4(- ;.q'fQ Heather Lynn Miller, Defendant. IN CUSTODY PETITION FOR EMERGENCY RELIEF AND NOW, comes the Petitioner, Shawn Lee Snyder, by and through his attorney, Karl E. Rominger, Esquire, and avers the following in support of this Petition for Emergency Relief: I. The Plaintiff, Shawn Lee Snyder, is an adult individual who currently resides at 46 Walnutdale Road, Shippensburg, Cumberland County, Pennsylvania. 2. The Defendant, Heather Lynn Miller, is an adult individual who is currently believed to be residing at 237 S. Washington Street, Greencastle, Pennsylvania. 3. There are children of the parties, Dylan M. Snyder, DOB: 5/1/99, and Derek M. Snyder, DOB: 10/17/00. 4. Petitioner seeks primary custody of the following children: Name Present Residence Age Dylan M. Snyder 46 Walnutdale Road Shippensburg, P A 17257 5 Derek M. Snyder 46 Walnutdale Road Shippensburg, P A 17257 3 The children were born out of wedlock The children are currently residing with Plaintiff, Shawn Lee Snyder, who resides at 46 Walnutdale Road, Shippensburg, Cumberland County, Pennsylvania. The father of the children is Plaintiff, currently residing at 46 Walnutdale Road, Shippensburg, Cumberland County, Pennsylvania.. The mother of the children is Defendant, currently believed to be residing at 237 S. Washington Street, Greencastle, Pennsylvania. 5. The relationship ofthe Plaintiff to the children is that of natural father. The relationship of the Defendant to the children is that of natural mother. 6. There is currently no Court Order. 7. Petitioner does not know of a person not a party to the proceedings who has physical custody of any of the children or claims to have physical custody or visitation rights with respect to the children. 8. The best interests and permanent welfare ofthe children will be served by granting the relief requested because: (a) Petitioner is the natural father of the children; (b) Petitioner has established a relationship with the children; (c) Petitioner desires to continue exercising parental duties and enjoys the love and affection of the children; (d) The children would benefit from custody being given to their natural father because of the current situation, which is explained in detail in paragraph 9 below. 9. Father and Mother currently split custody of the children. When Mother has custody, she has told Father that the children are staying with her at her mother's home, where she is believed to be residing. Upon information and belief, Mother is not exercising her custody at that location but is taking the children for overnight stays at various locations unknown to Plaintiff. 10. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. No other persons are known to have or claim a right to custody or visitation of the children to be given notice of the pendency of this action and the right to intervene. WHEREFORE, Petitioner respectfully requests this Honorable Court to enter an Emergency Order granting temporary primary physical custody with Father, with visitation in the Mother as agreed to by the parties, pending the scheduling of a conference or hearing on the matters alleged herein. Respectfully submitted, ROMINGER, BAYLEY & WHARE -- Dated: JI/'l. 2/1 1.11 '1 / ~ /-' Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff Shawn Lee Snyder, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. Heather Lynn Miller, Defendant. IN CUSTODY 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. Cons. Stat. 9 4904 relating to unsworn falsification to authorities. ~ Lee Sny er, P~ Shawn Lee Snyder, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. Heather Lynn Miller, Defendant. IN CUSTODY CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Plaintiff, do hereby certify that I this day served a copy of the Petitionfor Emergency Reliefupon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Heather Lynn Miller 237 S. Washington Street Greencastle, P A 17225 ~ :7 Date: J $-"1. 2. "f ~ AtJY _ Karl E. Rominger, Esquire Attorney for Plaintiff ~ ~9-~ r;'F \ ~ ~ _ 7\JW . tAoDD ~ 3 0<) 0 U\. -,- (Ad - ~ ~ ) t .. ~ , .., < ( -" . . ~'r I :~ i," ~'.'J "T'-' / I. ~ JUN 2 5 2004 1J v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 t./ - ;) ? 4 0 Shawn Lee Snyder, Plaintiff, Heather Lynn Miller, Defendant. IN CUSTODY ORDER OF COURT AND NOW, this ;;1' J+- day of -t ~ , 2004, upon consideration of -t"k 1tA..oo:;- Petitioner's Petition f~1~:~~f, it is hereby ordered and decreed that tIlHl"flf~' ~~t; ., . ~~..,-.J'~)J1~~. '7'7---~ PTlrrHuT p....Yc;.....<:l1 IT Hlta.l., ....f d.l~ }JWLlt:S mInor ~ulldlCll, nylall Id. ~l~ut:r, uvn: )/l/~'j a ~., ~ ~: ;c,;. ct, ~ II. U, () Ii,,: ~/::.;..:t t,,, ",l,h raUler, With Vlslta on III e 0 er as agreed to h~P~P:;~t-::Cs ~'~HW' 1.,,=Lo, v. l.:"l ~u II ! lllMt! . J. Distribution: 'N~ ""'f''''' -n1. .10. \ 1<aM.-- E... ~---+ (E; ) 7V{~t..o (./.1i"/'PY ~ A~J<r'"':_-""'" . /T'iJ SS'S i!J n(; iii' ",aDZ I" :,:...J SHAWN LEE SNYDER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 04-2940 CIVIL ACTION LAW HEATHER LYNN MILLER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, June 30, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before _Hnbert X. Gilroy, Esq. at 4th Floor, Cnmberland County Courthouse, Carlisle on Thursday, July 22, 2004 , the conciliator, at 10:30 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. All children age five or older may also be present at the conference. 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 existinl: Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: Isl Hubert X. Gilro.y. Esq. Custody Conciliator mhc The COUll 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 befon: the court, please contact our otlice. 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 TIns 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 Assoclation 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249.3166 -~ ~-ff. ~~ ~J #-e7F..'l ,~ z~ ~~ ;'~O[.'l ~ fj ~ ~ 4/,tl.~ pC? OE'? """r hen1 gc S ',',' G. "",' ivut. . -'''':J \."" ,,' ...,l' .' ~,,''-',_'..\ :;1111 YJ ",'. I' "',\'\,< '....," I \ I, ,'J _" ..l.. -' 1,.lJ'-7.L''-..-d ',-..I' '",o.,..l""'(I-r'"" \ t .' ::n\,~\:\C:- . ~ 1',:] SEP 0 5 200" SHAWN LEE SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-2940 CIVIL ACTION - LAW HEATHER LYNN MILLER, Defendant IN CUSTODY ORDER .,s, AND NOW, this r day of September, 2006, the above case being previously assigned to the Conciliator and there being no activity on this case for a period of six months or more, the Conciliator relinquishes jurisdiction. Hubert X. Gilroy, Custody Concilia .-.......') 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