HomeMy WebLinkAbout01-2431RONALD SNOWBERGER and : IN THE COURT OF COMMON PLEAS OF
LUCINDA SNOWBERGER, :
Petitioners : CUMBERLAND COUNTY, PENNSYLVANIA
:
v. : CIVIL ACTION - LAW
:
AMY JO FRYE and : 7Lo at- ,~ 7 3! CIVIL TERM
RONALD E. SNOWBERGER, JR., :
Respondents : IN CUSTODY
PETITION FOR CUSTODY
AND NOW, this 24th day of April 2001, comes the Petitioners, Ronald Snowberger and
Lucinda Snowberger, by their attorneys, Irwin, Mcliniffht and Hu~hes, and presents the
following Petition for Custody.
The petitioners are Ronald Snowberger and Lueinda Snowberg~r, adult individual
residing at 63 Faith Circle, Carlisle, Cumberland County, Pennsylvania 17013.
The respondent, Amy Jo Frye, is an adult individual with the last known address c/o
Steven A. Frye, 113 Weaver Slrcot, Altoona, Pennsylvania 16601-7001
The respondent, Ronald E. Snowberger, Ir., is an adult individual residing at 240 "E"
Street, Carlisle, Pennsylvania 17013.
o
The parties are the natural parents of two minor childish, namely, Ronald E. Snowberger,
HI, bom October 7, 1997, age three (3), and Miranda Marie Snowberger, bom July 29, 1999, age
two (2).
The Petitioners are the fraternal grandpa~nts of the children. They desire primary
physical and legal custody of the childre~ with periods of supervised periods of visitation to
respondents as can be mutually arranged between the parties.
The best interest of the children requires that the court grant the petitioners' request as set
forth above.
WHEREFORE, petitioners respectfully seeks the enlry of an Order of Court seeking
primary physical and legal custody of the children with periods of supervised visitation to
respondents as can be mutually arranged between the parties.
Respectfully submitted,
IRWIN, ,~IGlt,~./& HUGHES
By: ~
~0 West Pomfret S~reet
Carlisle, PenmIIvania 17013
(717) 249-23fl3
Date: April 24, 2001 Supreme Court I. D. No. 2fl476
4
VERIHCATION
The foregoing document is based upon information which has been gathered by
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.
Date: APRIL 24~ 2001
RONALD SNOWBERGER AND LUCINDA
SNOWBERGER : IN THE COURT OF COMMON PLEAS OF
PLAINTIFF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
AMY JO FRYE AND RONALD E.
SNOWBERGER, JR. : 01=2431 CIVIL ACTION LAW
DEFENDANT
IN CUSTODY
AND NOW,. Thursday, May 03, 2001 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before JaequeHne M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland Coumy Courthouse, Carlisle on Wednesday, May 23, 2001 at 9:30 a.m.
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 existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: M faeq~eline ~.f. Verney. Esq. t~ 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 eontant 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 AT'FORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATlrORNEY 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
2 Liberty Avenue
Carlisle. Pennsylvania 17013
Telephone ('717) 249-3166
RONALD SNOWBERGER and : IN THE COURT OF COMMON PLEAS OF
LUCINDA SNOWBERGER, : CUMBERLAND COUNTY,PENNSYLVANIA
Plaintiffs :
V. : NO. 2001-2431 CIVIL TERM
:
AMY JO FRYE and RONALD : CIVIL ACTION - LAW
E. SNOWBERGER, JR. :
Defendants : IN CUSTODY
ORDER OF COURT
·. AN.D NOW, this zq~ day of r'q~,. ,2001, upon
~co,n, slaerauon of the attached Custody Conciliation ~.eport, it is ordered and directed as
IOllOWS;
1. The Grandparents, Ronald Snowberger and Lucinda Snowberger shall
have sole legal and physical custody of Ronald E. Snowberger, III, bom October 7, 1997
and Miranda Marie Snowberger, bom July 29, 1999.
2. Parents, Amy Jo Frye and Ronald E. Snowberger, Jr. shall have
visitation as the parties agree. 'o~ periods of
cc: Marcus A. MeKnight,III, Esquire - Counsel for Grandparents
Amy Jo Frye
C/O Steven A. Frye
113 Weaver Street
Altoona, PA 16601-7001
Ronald E. Snowberger
240 "E" Street
Carlisle, PA 17013
RONALD SNOWBERGER and : IN THE COURT OF COMMON PLEAS OF
LUCINDA SNOWBERGER, : CUMBERLAND COUNTY,PENNSYLVANIA
Plaintiffs :
V. : 2001-2431 CIVIL TERM
:
AMY JO FRYE and RONALD : CIVIL ACTION - LAW
E. SNOWBERGER, JR., :
Defendants : IN CUSTODY
PRIOR JUDGE: None
CUSTODY CONCILIATION SUMMARY REPORi'
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 Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Ronald E. Snowberger. III October 7, 1997 paternal Grandparents
Miranda Marie Snowberger July 29, 1999 paternal Grandparents
2. A Conciliation Conference was held in this matter on May 23, 2001. The
plaintiff Grandparents, Rona[d Snowberger and Lucinda Snowberger were present with
counsel, Marcus A. McKnight, III, Esquire. Defendant, Father, Ronald E. Snowberger,
Jr., was aware of the conference but did not appear. Mother, Amy Jo Frye, left the area
on March 6, 2001 and has had no contact with the children. Service was attempted at
M '
other s last known address in care of her brother Steven A. Frye. Mother did not
appear.
3. An Order in the form attached was requested by Grandparents.
Date /Jacqlfeline M. Vemey, ~squire ,f
Custody Conciliator