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HomeMy WebLinkAbout01-2812ERIC J. SNYDER, : Plaintiff : ; V. ; WENDY L. SNYDER, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2812 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, ., 2001 upon consideration of the attached Petition to Modify Custody, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the day of ,2001, at o'clock, __..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. FOR THE COURT: By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Office of the Court Administrator Cumberland County Court House, Fourth Floor Carlisle, PA 17013 (717) 240-6200 ERIC J. SNYDER, Plaintiff V. WENDY L. SNYDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2812 CIVIL ACTION LAW IN CUSTODY PETITION TO MODIFY CUSTODY Petitioner is Eric J. Snyder who resides at 125 Long Road, Newville, Pennsylvania. Respondent is Wendy L. Snyder who resides at Safe Harbor, Room 306, Carlisle, PA 17013. On June 8, 2001, the Honorable Kevin Hess, entered the Custody Order attached as Exhibit "A'. Since the entry of said Order, there has been a significant change in circumstances in that: (a) Mother has failed to exercise Custody Order. (b) Mother doesn't give adequate prior notice for cancellations in visitation. 5. The best interest of the child will be served by the Court in modifying said Order. WHEREFORE, Petitioner prays this Court to grant the modification with physical custody in the Father with partial visitation in the mother by agreement of the parties. I verify that the statements made in this petition 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. Date: ' Eric/J. Sr(yder, Petitioner/Plaintiff ERIC J. SNYDER, Plaintiff Ve WENDY L. SNYDER, Defendant o ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA NO. 2001-2812 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT ANDNOW, this ~'~., dayof'"~Lt~ ,2001,upon consideration of the attached Custody Conci{iation Report, it is ordered and directed as follows: 1. The Father, Eric J. Snyder, and the Mother, Wendy L. Snyder, shall have shared legal custody of Dakota R. Snyder, born September 10, 1995 and Christian R. Snyder, born June 1, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 2. Father shall have primary physical custody of the children. follows: Mother shall have periods of partial physical custody of the children as a. Beginning June 10, 2001, alternating weeks from Sunday at 3:00 p.m. to Tuesday at 5:00 p.m. during the summer months. b. Once school begins, alternating weekends from Friday after school to Sunday at 3:00 p.m. During the summer months, every Wednesday frpm 12:00 noon to 8:00 p.m. During school, every Wednesday from after school to 7:00 p.m. d. Such other times as the parties agree. 4. Mother agrees that the children will only spend ovemights in her residence or the residence of the children's maternal grandmother. 5. Neither party will consume alcohol or use illegal drugs while the children are in their custody. .' 11 be shared such that Father will transport the children 6. TransportaUon sha ......... ,~ .....~2~,~,~ at Savior's Market to Mother' s residence and Mother shall return me cnnm~n ,u ,-,~ .... J in Newville, unless otherwise agreed by the parties. 7. The parties shall share the Thanksgiving and Easter holidays, at times agreed by the parties. 8. The Christmas holiday shall be in two blocks which shall be alternated by the parties with Block A being December 24 at 12:00 noon to December 25 at 12:00 noon and Block B being from December 25 at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. 9. In the event that either parent is in need of babysitting services for longer than two hours during their Period of custody, the custodial parent Shall contact the other parent with the opportunity to provide care for the children before arranging for a third party to baby sit. 10. Each party shall be afforded a block of time on the children's birthdays. 11. The parties shall keep each other advised immediately relative to any medical care or medical emergencies concerning the children and shall further take any necessary steps to ensure that the health and well being of the children is protected. During such illness or medical emergency, both parents shall have the right to visit the child as often as he/she desires consistent with the proper medical care of the child. 12. Neither parent shall do anything which may estrange the children from the other party, or injure the opinion of the children as to the other party, or which may hamper the free and natural development of the children's love or affection for the other party. 13. This Order is entered pursuant to an agreement of the parties at a od Conci iation conference. The parties may modify the provisions of this Order by Cu~t_o~y~Co~ 11~~ of mutual consent, the ter~ of this Order s?all control. cc: Karl E. Rominger, Esquire - Counsel for Father Derek Clepper, certified legal intern, Family Law Clinic - for Mother Teri L. Henning, Esquire, Counsel for Mother ERIC J. SNYDER, Plaintiff V. WENDY L. SNYDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : 2001-2812 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT. 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 Dakota R. Snyder Christian R. Snyder DATE OF BIRTH September 10, 1995 June 1, 1998 CURRENTLY IN CUSTODY OF Father Father 2. sAnCOnciliation Conference was held in this matter on June.6, 2001. Father, Eric J. yder, was present with counsel, Karl E. Rommger, Esqmre, and Mother, Wendy L. Snyder, was Present with counsel, Derek Clepper, certified legal intern and Teri L. Henning, Esquire from the Family Law Clinic. 3. The parties agreed to an Order in the form attached. Date ~ne M. ~er~ey, Esquire, Custody Conciliator 155 South Hanover ~treet Carlisle, Pennsylvania 17013 ~ o~--~.~2 1 North Main Street 717,241.6070 · 800.734.0490 · FAX: 717.241.6878 Chambersburg, Pennsylvania 17201 www. romingerlaw, com* law@romlngerlaw, com ERIC J. SNYDER PLAINTIFF V. WENDY L. SNYDER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, pENNSYLVANIA 01-2812 CIVIL ACTION LAW IN CUSTODY Tuesda~ugust 21, 2001 upon consideration of the attached Complaint, d their respective counsel a~e'ar before ~M ~ -' the conciliator, it is on Wednesda , Se tember 19, 2001 at 4th Flo~ Courthouse, Carlisle 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: /si ~ - -- Custody Conciliator law to comply with the For information about accessible facilities and reasonable The Court of Common Pleas of Cumberland County is required by Americans with Disabilites Act of 1990. disabled individuals having business before the court, please contact our office. accommodations available to any hearing or business before the court. You must All arrangements must be made at least 72 hours prior to attend the scheduled conference or hearing. ONCE. IF YOU DO NOT YOU sHOULD TAKE THIS PAPER TO YOUR ATIYORNEY AT HAVE AN ATYORNEY 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 ERIC J. SNYDER, Plaintiff V. WENDY L. SNYDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : : NO. 2001-2812 CIVIL TERM : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this ~" day of O-o~4., ,2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Eric J. Snyder, and the Mother, Wendy L. Snyder, shall have shared legal custody of Dakota R. Snyder, bom September 10, 1995 and Christian R. Snyder, bom June 1, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 3. follows: Father shall have primary physical custody of the children. Mother shall have periods of partial physical custody of the children as a. Beginning June 10, 2001, altemating weeks from Sunday at 3:00 p.m. to Tuesday at 5:00 p.m. during the summer months. b. Once school begins, alternating weekends from Friday after school to Sunday at 3:00 p.m. c. During the summer months, every Wednesday frpm 12:00 noon to 8:00 p.m. During school, every Wednesday from after school to 7:00 p.m. d. Such other times as the parties agree. 4. Mother agrees that the children will only spend overnights in her residence or the residence of the children's maternal grandmother. ~NVA'~SNN3a KI.NNO0 t~O :~ 14,-,J 8- Nfl? I0 Xl:i'¥tONOl4iCti:i !ii--iL 30 5. Neither party will consume alcohol or use illegal drugs while the children are in their custody. 6. Transportation shall be shared such that Father will transport the children to Mother' s residence and Mother shall return the children to Father at Saylor's Market in Newville, unless otherwise agreed by the parties. 7. The parties shall share the Thanksgiving and Easter holidays, at times agreed by the parties. 8. The Christmas holiday shall be in two blocks which shall be alternated by the parties with Block A being December 24 at 12:00 noon to December 25 at 12:00 noon and Block B being from December 25 at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. 9. In the event that either parent is in need of babysitting services for longer than two hours during their period of custody, the custodial parent shall contact the other parent with the opportunity to provide care for the children before arranging for a third party to baby sit. 10. Each party shall be afforded a block of time on the children's birthdays. 11. The parties shall keep each other advised immediately relative to any medical care or medical emergencies concerning the children and shall further take any necessary steps to ensure that the health and well being of the children is protected. During such illness or medical emergency, both parents shall have the right to visit the child as often as he/she desires consistent with the proper medical care of the child. 12. Neither parent shall do anything which may estrange the children from the other party, or injure the opinion of the children as to the other party, or which may hamper the free and natural development of the children's love or affection for the other party. 13. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, / ~x~'ffZ j . '~. Karl E. Rominger, Esquire - Counsel for F~u,~ , _ Derek Clepper, certified legal intern, Family Law Clinic - for Mother ~> ,x0 \ Teri L. Henning, Esquire, Counsel for Mother ERIC J. SNYDER, Plaintiff V. WENDY L. SNYDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : 2001-2812 CIVIL TERM : CIVIL ACTION - LAW : : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT 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 Dakota R. Snyder Christian R. Snyder September 10, 1995 Father June 1, 1998 Father 2. A Conciliation Conference was held in this matter on June 6, 2001. Father, Eric J. Snyder, was present with counsel, Karl E. Rominger, Esquire, and Mother, Wendy L. Snyder, was present with counsel, Derek Clepper, certified legal intern and Teri L. Henning, Esquire from the Family Law Clinic. 3. The parties agreed to an Order in the from attached. Date J~cqu6t~ine M. Vemey, Esquire Custody Conciliator ERIC J. SNYDER, Plaintiff V. WENDY L. SNYDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION LAW : IN CUSTODY : : No. 01-2812 PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of the Family Law Clinic on behalf of Wendy L. Snyder, the Defendant in the above captioned matter. May 25, 2001 ~errek R. Clepper tiffed Legal Intern T~OMAS M. PLACE Supervising Attorney TERI HENNING Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 717/243-3639 ERIC J. SNYDER, Plaintiff V. WENDY L. SNYDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION LAW : IN CUSTODY : No. 01-2812 CERTIFICATE OF SERVICE I, Derek R. Clepper, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a tree and correct copy of Praecipe to Enter Appearance on Karl E. Rominger, at 155 South Hanover Street, Carlisle, PA 17013, by depositing a copy of the same in the United States mail, First Class, postage prepaid, this 25t~ day of May, 2001. Clepper C'C~eerrtified Legal Intern THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 ERIC J. SNYDER, Plaintiff WENDY L. SNYDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION LAW IN CUSTODY : No. 01-2812 PRAECIPE TO WITHDRAW APPEARANCE AND NOW, this [ ~'~ day of December, 2001, the Family Law Clinic withdraws its appearance on behalf of the Defendant, Wendy L. Snyder. December I I ,2001 Respectfully submitted, Certified Legal Intern R~O~ERT E. RA~ THOMAS M. PLACE TERI L. HENNING SUPERVISING ATTORNEYS FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 PRAECIPE TO ENTER APPEARANCE AND NOW, this I I-~'~ day of December, 2001, Thomas Flower, hereby enters his appearance on behalf of thc Defendant, Wcndy L. Snyder. December I I , 20Ol Thomas Flower, Esquire Saidis, Shuff, Flower and Linc[say 2109 Market Street Camp Hill, PA 17011 717/737-3406 OCT 1 1 200 /L ERIC J. SNYDER, Plaintiff WENDY L. SNYDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-2812 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY TEMPORARY CUSTODY ORDER AND NOW, this I/-'~ day of tge,~&~ ,2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as 'follows: 1. The Father, Eric J. Snyder, the Mother, Wendy L. Snyder and the children's maternal aunt, Cindy McClucas Herman, shall have shared legal custody of Dakota R. Snyder, bom September 10, 1995 and Christian R. Snyder, bom June 1, 1998. The parents and aunt shall have an equal right, to be exercised jointly with the others, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. children. Cindy McClucas Herman shall have primary physical custody of the 3. Mother shall have periods of partial physical custody of the children as agreed by the parties 4. Father shall have periods of partial physical custody of the children as agreed by the parties. 5. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, cc: Karl E. Rominger, Esquire - Counsel for Steve Boell, certified legal intern, Family Law Clinic - for Mother Teri L. Henning, Esquire, Counsel for Mother OGT1 1 20O] ERIC J. SNYDER, Plaintiff WENDY L. SNYDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : 2001-2812 CIVIL TERM : CIVIL ACTION - LAW : : IN CUSTODY PRIOR JUDGE: Kevin A. Hess, J. CUSTODY CONCILIATION SUMMARY REPORT 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 Dakota R. Snyder Christian R. Snyder September 10, 1995 Father June 1, 1998 Father 2. A Conciliation Conference was held in this matter on June 6, 2001. Father, Eric J. Snyder, was present with counsel, Karl E. Rominger, Esquire, and Mother, Wendy L. Snyder, was present with counsel, Steve Boell, certified legal intern and Teri L. Henning, Esquire from the Family Law Clinic. 3. A prior Order of Court, dated June 8, 2001 and entered by the Honorable Kevin A. Hess, provided for the parents to have shared legal custody, Father to have primary physical custody and Mother to have periods of partial custody including alternating weeks during the summer and alternating weekends once school started and shared holidays. 4. The parties agreed to the Temporary Custody Order in the form attached. Date acq~efine M Vemey, Esquire Custody Concflmtor