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HomeMy WebLinkAbout96-05993 1 ..~. \ .. \ 7 .tJ 1 8'\ . ~" ~ r- J ell 0- cr to \ / , " , i,I},! [) 11996 tf v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : ACTION FOR CUSTODY MEUSSA OLATZ Plaintiff, NOAH JEFFCOAT Defendant. . . : ''1'13 : NO. 96- 5 CIVIL TERM ORDER OF COURT AND NOW, this C.l~y ofl 0 ",'" ~\996, upon consideration of the attached comPt~. \, I it is hereby directed that the parties and their respective counsel appear before ~!"-It-'I. ~ e conciliator, atLtl h ('''''', Cumberland County Courthouse, on thel vtllay of .1M"':l~, atft.~ :, for a Pre-Hearing Custody Conference. At sueh conference, an effort wil1 be ~:Z'to resolve the issues in disputej 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. Either party may bring the child who is the subject of this custody action to the conference, but the child's attendance is not mandatory. Failure to appear at the conference provide grounds for a entry of a temporary or permanent order. FOR ~ CO~ // of) By: - ./u .....eu;(~ i: ,$.'1. Custody Coneiliator " r~ 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 COURTHOUSE, 4th Floor CARLISLE, PA 170\3 717/240-6200 AMERICANS wml DISABILITIES ACT OF 1990 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 faeilities 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. v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY MELISSA GLATZ, Plaintiff NOAH JEFFCOAT, Defendant NO. 96- CIVIL TERM NOTICE TO DEFEND AND CLAIM RIOHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may procu:d without you and a judgment may be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEOAL HELP. Court Administrator, Fourth Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 (717)240-6200 AMERICANS WITII DISABILITIES ACT OF 1990 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. MEUSSA GLATZ, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY NOAH JEFFCOAT, Defendant NO. 96- CIVIL TERM COMPLAINT FOR CUSTODY NOW COMES the plaintiff, MEUSSA GLATZ, by her attorneys, the Family Law Clinic, and sets forth the following cause of action: 1. The plaintiff is the mother of Brianna Glatz, residing at 600 South Hanover Street, Apt #3, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is the father of Brianna Glatz, residing at 5911 Dan Drive, Killeen, Texas 76543. 3. Plaintiff seeks custody of the following child. ~ lm~ent Residence AG Brianna Glatz 600 South Hanover Street, Apt. #3, Carlisle, Pa 17013 1811Dh The child was born out of wedlock. The child is presently in the custody of Melissa Glatz, who resides at 600 South Hanover Street, Apt. #3, Carlisle, Pa 17013. During the past five years, the child has resided with the following persons and at the following addresses: Persons Addresses ~ Plaintiff and her Aunt and Uncle 1896 Mary Lane, Carlisle, PA 17013 3/95 to 9/95 a) Plaintiff is able to provide a loving environment for the child, and has done so for her entire life; b) Plaintiff is able to provide proper care and supervision for the child and has done so for her entire life; c) Plaintiff is able to provide a safe, proper physical environment for the child and has done so for her entire life; d) Plaintiff believes it is in the best interest of the child to have a meaningful, ongoing relationship with her mother exclusively. 8. 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. WHEREFORE, plaintiff requests the court to grant to her custody of the child. Date /u/~Ih~ /;~ n ',~......l""- ,l~'-l:;)r- PETER IMBROGNO Certified Lega11ntem -fe, ~ HERlNE C. PEARSON Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 -f t d 1 0 ~ "&. -g 0 C>> a. cr- .,,' ..:J .- 0 ?b -:r 1-.: ..., S 0 ~{' .. ~.. l() :t - '.~~.~ u" ~~i .:t.: 11 >l ~. a.. ..J ~~ a 1f) If) ? ''lL. ,-; ;J:J :r ':t (,) " Jl'- .- -' - n . :---; '~: 1 Vi U:~II I- ;:j~. ... r-'.c u l~" !J] 'L. c.;; ....~ 0 \1~ :5 a, U ~ l/) "- r... .:t ..:J Z >- a. ~-:) r.:J: Q ,.) ;:~: ~~ :E: (J;:: u i!' oo:z: f'.""\~ ~c en ::~I.a K I :~ffi ~l:' m ~, L..J Ula.. u.. ..~; IS ro :5 CI' U "