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Home My WebLink About00-02117 -" '''" ~~, ~ LYNN W. GLAVIANO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO.ClO- oJ/I? ~ RICHARD T. GLAVIANO, Defendant IN CUSTODY ORDER OF COURT L .'- AND NOW, this .;2 lip." I , 2000, upon day of consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before f'n'vJl\ 5'. )..,r.c1""'f ' Esquire, the conciliator at 30;- /JI/. ;1;f AlAi ';)1 111"L,/r; 'd ,Pennsylvania, on the &t:I-o day of ~ ,2000, at 3:00 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 hard 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 chid's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. BY THE COURT, 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 II ~ '''',,"c,. ',,-,:,,_/'f ~,Dl'I'Il:'~ -~ , " ^- --", '-"I ,-- -0/J .ct'J 4/3 C?, ~ i.]. CJ?J ~ --, ~ - ---_-,~__v'.'r._' ~"-- - - _~""__""_""c_;.'"'_ -,~".^' - '~_,p ,. _ "4~,," _ '~~':::~~ DO f~PR i 3 PH 3: 55 CUi\!'f\.r:I':L'!\'L'c n.",u,\,C!.y "..,.,_ , ,~; . \ ",./ ' I PcNNSYLVANI,i\ ' < h;I-~~~ 4~ ~~ ~ Z ~ ~,<o/-~~ ~. ~ z2;c" ~ ~ ""f' . ,,.. _ ,,,:<:,S':-~ .'"''7''-'''- __"",,.I~ftl!Ii1r~."'":f'~""~ _1"" _l~~ ,1f='~I[fIIIII!JJ '7' "r-~ .ilaiie;Ji I, I, LYNN W. GLAVIANO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 0-0 - ;11)7 ~ / L.- RICHARD T. GLAVIANO, Defendant IN CUSTODY COMPLAINT IN CUSTODY AND NOW comes the Plaintiff, LYNN W. GLAVIANO, by her attorney, Samuel L. Andes, and makes the following Complaint for Custody: 1. The Plaintiff is LYNN W. GLAVIANO, an adult individual who resides at 570 Saint Johns Drive in Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is RICHARD T. GLAVIANO, an adult individual who resides at 528 Penn Ayr Road in Camp Hill, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant are husband and wife, having been married on '10 May 1974. 4. The Plaintiff and Defendant are the parents of four minor children, Stephen R. Glaviano, born 19 February 1986, Lauren M. Glaviano, born 26 December 1989, Kathryn E. Glaviano, born 9 July 1991, and Meghan L. Glaviano, born 9 July 1996. 5. Plaintiff seeks custody of the said minor children, Stephen R. Glaviano, born 19 February 1986, Lauren M. Glaviano, born 26 December 1989, Kathryn E. Glaviano, born 9 July 1991, and Meghan L. Glaviano, born 19 July 1996. 6. The children were not born out of wedlock and are presently in the custody of the Plaintiff. 7. During the past five years, the minor children have resided with the following persons at the following addresses: 1995 - April 2000 528 Penn Ayr Road Camp Hill, Pa 17011 Plaintiff & Defe,ndant April 2000 - present Plaintiff only II ':'".: " ,~ "'," . 8. The father of the children is the Plaintiff who resides at the address set out above. He is married to the Defendant. 9. The mother of the children is the Defendant who resides at the address set out above. She is married to the Plaintiff. 10. The Plaintiff is the natural father of the children. Plaintiff currently resides with the child/en. 11. The Defendant is the natural mother of the children. Defendant currently resides alone. 12. The Plaintiff has not participated as a party or in any other way in any litigation concerning the custody of the children in this or any other court. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this or any other jurisdiction. Plaintiff knows of no other person not a party to this action already who has physical custody of or claims to have custody or visitation rights to the said children. 13. The best interests and permanent welfare of the children will be served by granting the relief requested by Plaintiff for the following reasons: A. Plaintiff has been the primary care provider and the primary nurturing parent of the children since birth; and B. Because of the temperament, education, and general character of Plaintiff she is better able to provide for the needs, particularly the emotional and personal needs, of the children; and C. Because of Defendant's temperament, personality, and work schedule, the Defendant is less able than the Plaintiff to meet the needs of the children; and D. Some of the children have special needs which can best be addressed and satisfied by Plaintiff and which Defendant cannot properly address. E. Such an award is in the best interest of the children. 14. 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. II . I, I t, " II WHEREFORE, LYNN W. GLA VIANO, requests this Court to grant him custody of the children, Stephen R. Glaviano, Lauren M. Glaviano, Kathryn E. Glaviano, and Meghan L, Glaviano. r i; (> I: Ii '[i , , I: I I] [, i .' i; ~k~N)~(L IL.A~ Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 II ~ COMMONWEALTH OF PENNSYLVANIA ) ( SS.: COUNTY OF CUMBERLAND ) LYNN W. GLAVIANO, being duly sworn according to law, deposes and says that the facts set forth in the foregoing Complaint for Custody are true and correct to the best of his knowledge, information, and belief. ~W.~k^r;:J LYN W. GLAV NO Sworn to and subscribed befo~ ~~ tRis 6f-h.-- of \A\JlU&.. day ,2000. I i ~~~ MV1l~JI~ ""'~~~ II ,~~~ "C' .. , "aJlill"",",,,", ~ 'I LYNN W. GLAVIANO, Plaintiff : IN THE CDOOT OF CDMMON PLEAS OF : CUMBERLAND COUNTY ,. PENNSYLVANIA : vs. : NO. 00-2117 CIVIL TERM : RICHARD T. GLAVIANO, Defendant . . CIVIL ACTION - LAW IN CUSTODY . . ORDER OF OOURT AND 1\Di, this /J""+'" day of ~ consideration of the attached Custody Conci iation Report, and directed as follows: , 2000, upon it is ordered 1. The parties shall submit themselves and their minor Children to a custody evaluation to be performed by Arnold Shienvold, PhD. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which would best serve the interests of the Children. The parties shall equally share all costs of the evaluation. 2. Kathryn and Lauren shall begin a course of counseling with Bonnie Howard and Stephen's therapy shall be transferred from his current counselor, Lisa Lentz, to Bonnie Howard with the transition to be handled as recommended and supervised by Fran Sparrow and Bonnie Howard. The parties shall equally share all costs of the counseling which are not covered by insurance. 3. The Father and Stephen shall engage in a course of counseling with Bonnie Howard to address and resolve conflicts which have arisen in the Father/SOn relationship. 4. The Father shall resume his course of therapy with Robert Beachey as recommended by Bonnie Howard or Arnold Shienvold. 5. The Mother, Lynn W. Glaviano, and the Father, Richard T. Glaviano, shall have shared legal custody of Stephen R. Glaviano, born February 19, 1986, Lauren M. Glaviano, born December 26, 1989, Kathryn E. Glaviano, born July 9, 1991 and Meghan L. Glaviano, born July 9, 1996. 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. 6. Pending further Order of Court or agreement of the parties, the Mother shall have primary physical custody of the Children and the Father shall have partial physical custody in accordance with the following schedule: A. The Father shall have custody of the Children from Sunday, September 3, 2000 at 9:00 a.m. through Monday, September 4, 2000 at 6:00 p.m. If'' ,_._L ~~ ~- '< - -'_})":'~'I ii! ,:; :-, ::-1 ::i :'i B. The parties shall share having custody of the Children on a four weekend cycle as follows: 1.) WEEKEND I: The Father shall have custody from Friday at 6:00 p.m. through Sunday at 6:00 p.m. 2.) WEEKEND II: The Father shall have custody from Saturday at 12:00 noon through Sunday at 6:00 p.m. 3.) WEEKEND III: The Mother shall have custody of the Children. 4. ) WEEKEND IV: The Father shall have custody from Saturday at 12:00 noon through Sunday at 6:00 p.m. The weekend cycle shall corrunence with WEEKEND I beginning on Friday, September 8, 2000 at 6:00 p~m. C. The Father shall have custody of the Children every Wednesday fran after school, when the Children shall get off the bus at the Father I s residence unless otherwise agreed between the parties, until 8:30 p.m. 7. The parties shall share or alternate having custody of the Children over holidays as follows: A. THANKSGIVING: In 2000, the Father shall have custody of the Children from the Wednesday before Thanksgiving at 6:00 p.m. through Thanksgiving Day at 3:00 p.m. and the Mother shall have custody fran Thanksgiving Day at 3:00 p.m. through the following Friday at 6:00 p.m. B. CHRISTMAS: In 2000, the Mother shall have custody of the Children from Christmas Eve at 6:00 p.m. through Christmas Day at 12:00 noon. The Father shall have custody of the Children from Christmas Day at 12:00 noon through December 26 at 6:00 p.m., from December 27 at 12:00 noon through December 28 at 6:00 p.m., and from December 30 at 12:00 noon through December 31 at 6:00 p.m. C. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 8. The Mother shall ensure that the Children oontact the Father by telephone on Mondays, Thursdays and Fridays between 7:00 p.m. and 9:00 p.m. 9. The parties and counsel shall attend an additional Custody Conciliation Conference in the office of the Conciliator, Dawn S. Sunday, Esquire, on Tuesday, January 16, 2001 at 9:30 a.m. within 30 days of receipt of Dr. Shienvold' s written custody recorrnnendations, counsel for either party may oontact the Conciliator to schedule an earlier Conference in lieu of the January Conference. , l=~o~__..." -, ~ < 1>,,,,);0.\1 : 10. 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. ~~~ ,., J. cc: Edward J. Weintraub, Esquire - Counsel for Mother ~ Maria P. Cognetti, Esquire - Counsel for Father C!.'f"), - 9_ (.3-(J() ., ~ \~iiIi~_I'~'~.fu.~itlI\lI~~!II~'~""'~~"W1Jitul<;*~~""j!ii-jjil'i~l!iMM.itill'.a""':'" ,.~-~...k.. vlr~V/\lASNNjd AJ hlnl(!r) ("';'.:\..~;_:::::~=l/\J'V) . ._, ",.',,' ,,"; .'...."1.,',' lfv ~I ~ 1 .-; 1 i 1 "./ ,,--\ ." .J """ (' , ._, ~. , U,:i,) A8VJC -~'" .iI ~- ~-~ ~ ~ .,.- ,.",,~ , ,.,>~; .- ' ~~. - ........"1 I LYNN W. GLAVIANO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. : NO. 00-2117 CIVIL TERM : RICHARD T. GLAVIANO, . CIVIL ACTION - LAW . Defendant . IN CUSTODY . CUSTODY CCNCILIATICN SUMMARY REF(Rr IN ACCORDANCE WITH CUMBERLl\ND CXXlNTY 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 subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Stephen R. Glaviano Lauren M. Glaviano Kathryn E. Glaviano Meghan L. Glaviano February 19, 1986 December 26, 1989 July 9, 1991 July 9, 1996 Mother Mother Mother Mother 2. A Conciliation COnference was held on August 31, 2000, with the following individuals in attendance: The Mother, Lynn W. Glaviano, with her counsel, Edward Weintraub, Esquire, and the Father, Richard T. Glaviano, with his counsel, Maria P. Cognetti, Esquire. 3. It should be noted that a Conciliation Conference was previously held in this matter on June 6, 2000, at which time the parties also agreed to custody arrangements. However, at that time, an issue concerning the Children was under investigation by Children and Youth Services. The investigator at Children and Youth Services objected to the parties · agreement on custody and the parties agreed to hold the proposed Order pending completion of the investigation. At the time of the second Conference, the investigation was complete (complaint "unfounded"), and Children and Youth Services were no longer involved. 4. The parties agree to entry of an Order in the fom as attached. ~~ ,r-; ~o Date IOCu~~ 44~. .~ Dawn S. Sunday, Esquire Custody COnciliator " J..,~"O N ~~ " _, J - ,J._ -> " _w~Ik't, LYNN W. GLAVIANO, Plaintiff, * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, PENNSYLVANIA * vs. * NO. 00-2117 * RICHARD T. GLAVIANO, Defendant. * CIVIL ACTION- LAW * IN CUSTODY PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of Edward J. Weintraub, Esquire, on behalf of Plaintiff. Dated: V()O Edward J. Weintraub, Esquire 2650 North Third Street Harrisburg, PA 17110 (71 7) 238-2200 ID #17441 ATTORNEY FOR PLAINTIFF ~ili_.iiri_~'jfiBr.@~j!jmWIIOOill.i~~~i'~'''''8il:~","~j~~IliiiMIiI~r~'' .H "_lir~ "'= , ~~_ 0"",, .'-" o ~ i...~l...n.. ~$; =;sZ 1.::.0 ~g ~~ o o (/) Cd - .1'"" "'0 ~ ~ o \D 1iiIiIi_ ~, ~! ,~ r--c. .\>,:~ . , ._,""1JT{ ""\,:\e) '0 (-) .~t; !1 "".c> 15m -'" ~ . ~~ ~ J" .' , ~ "jt\, -. .t1~~:::,; . v LYNN W. GLAVIANO, . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . . . . vs. : NO. 00-2117 CIVIL TERM : RICHARD T. GLAVIANO, Defendant . . CIVIL ACTION - LAW CUSTODY . . ORDER OF CCXJRT AND NCW, this )~ consideration of the attached and directed as follows: l!i!: day of Custody Conciliation , 2001, upon Report, it is ordered 1. The prior order of this Court dated September 13, 2000, is vacated and replaced with this order. 2. The Mother, Lynn W. Glaviano, and the Father, Richard T. Glaviano, shall have shared legal custody of Stephen R. Glaviano, born February 19, 1986, Lauren M. Glaviano, born December 26, 1989, Kathryn E. Glaviano, born July 9, 1991 and Meghan L. Glaviano, born July 9, 1996. 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. pending further order of Court or agreement of the parties, the Mother shall have primary physical custody of the Children and the Father shall have partial physical custody in accordance with the following schedule: A. The parties shall share having custody of the Children on a four weekend cycle as follows: 1.) WEEKEND I: The Father shall have custody from Friday at 6:00 p.m. through Sunday at 6:00 p.m. 2.) WEEKEND II: The Father shall have custody from Saturday at 12:00 noon through Sunday at 6:00 p.m. 3. ) WEEKEND III: Children. The Mother shall have custody of the 4. ) WEEKEND IV: The Father shall have custody from saturday at 12:00 noon through Sunday at 6:00 p.m. B. The Father shall have custody of the Children every Wednesday from after school, when the Children shall get off the bus at the Father's residence unless otherwise agreed between the parties, until 8:30 p.m. L. ~.... ~" ,', .~ ~ '~i.!j~- ,j ,ii !I ! . 4. The parties shall share or alternate having custody of the Children over holidays as follows: A. CEIRIS'l'MAS: The parties shall share having custody of the Children over the Christmas holiday and school break in a manner to be agreed upon between the parties. B. THANKSGIVING/EASTER: The Thanksgiving and Easter holidays shall run from 4:00 p.m. on the last day of school before the holiday through 6:00 p.m. on the evening before school resumes after the holiday. In even numbered years, the Father shall have custody of the Children over Thanksgiving and the Mother shall have custody over Easter. In odd numbered years, the Mother shall have custody of the Children over Thanksgiving and the Father shall have custody over Easter. C. MEMCIUAL DAY/LABOR DAY: The Memorial Day and Labor Day holidays shall run from 4:00 p.m. on the last day of school prior to the holiday through 6:00 p.m. on the evening before school resumes after the holiday. In even numbered years, the Father shall have custody of the Children over Memorial Day and the Mother shall have custody over Labor Day. In odd numbered years, the Mother shall have custody of the Children over Memorial Day and the Father shall have custody over Labor Day. D. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 5. Both parties shall be entitled to have custody of the Children during the summer school break each year for three non-consecutive weeks, upon providing at least 30 days advance notice to the other party. 6. The parties shall engage in a course of joint counseling with a professional to be selected by agreement of the parties. The purpose of the counseling shall be to improve communication and address conflicts in order to enable the parties to effectively coparent their Children. 7. Kathryn shall continue her counseling with victoria Whitcomb, unless otherwise agreed between the parties. 8. The parties agree that the Father and Stephen shall participate in counseling with Bonnie Howard as needed to address and resolve conflicts which have arisen in the Father/Son relationship. 9. Each party shall ensure that Stephen is not responsible for supervising the other Children during that party's periods of custody. 10. The Mother shall ensure that the Children contact the Father by telephone every Tuesday between 7:00 p.m. and 9:00 p.m. The Father may contact the Children and the Children may contact the Father by telephone at any other times. 11. Counsel for either party may contact the Conciliator by the end of , _I ~I; - - O. r-- ::<lX,I' September 2001 to schedule an additional CUstody Conciliation Conference to review the custody arrangements if necessary. 12. 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 llRltual consent. In the absence of mutual consent, the terms of this Order shall control. Edward E. Guido, J. cc: Edward J. Weintraub, Esquire - Counsel for Mother Maria P. Cognetti, Esquire - Counsel for Father ~ ~ 'I_)..5()/ +. - ~~~ "h ~'iI?\;.'';~ LYNN W. GLAVIANO, . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND caJNTY, PENNSYLVANIA Plaintiff . . : vs. : NO. 00-2117 CIVIL TERM . . RICHARD T. GLAVIANO, Defendant : CIVIL ACTION - LAW : CUSTODY PRIOR JUDGE: Edward E. Guido CUSTODY CXI!lCILIATIOO SUMMARY REI?CRr IN AC<XJIDANCE WITH CUMBERLAND CXXlNTY 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 subjects of this litigation is as follows: NAME DATE OF BIRTH CURRElilTLY IN CUSTODY OF Stephen R. Glaviano Lauren M. Glaviano Kathryn E. Glaviano Meghan L. Glaviano February 19, 1986 December 26, 1989 July 9, 1991 July 9, 1996 Mother Mother Mother Mother 2. A Conciliation Conference was held on April 18, 2001, with the following individuals in attendance: The Mother, Lynn W. Glaviano, with her counsel, Edward J. Weintraub, Esquire, and the Father, Richard T. Glaviano, with his counsel, Maria P. Cognetti, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ~ Date ,;w I d-oo ( , ~ CUstody Conciliator !.iiiIiiIt........r."- ,~ - ,"'--.---" ~~,i11l:f"""'~ '~.,~ -- '~jil~!il!~ " 'i\~~~e JJ}\(\O') Q\,!(\Il,jt-jV~':) ~t tt, ~d 1](. )jd~ \G ".,' .j', JO ,t'I.ol\ r' ,,___,1 ' ,~,..: _<1- ... r-'o,"(j\,ur"',o". .;' . jJ\c\~o.(rj\d ~ ~.iIiIIti ",'0< .. I' "-+;;'-'~~ - . , .- ~~" ~ ~ ~ B ~lll.ijli~'i1!f~\'f~~L " LYNN W. GLA VIANO PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 00-2117 CIVIL ACTION LAW RICHARD T. GLA VIANO DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, January 29, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, February 21, 2002 , the conciliator, at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute:; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Dawn S. Sunday. Esq. \)".1\ Custody Conciliator U 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 1HIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VB 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 " J:laBw ~ - ;" ~ -'*ill<~iiHIMli.IDW..~it"''''&lliliH.~.w.W&WlJi!.~iallli ; . *~ liIIllifi. "_"l"O- ,< ",.,m ~-' , ~-. -".- -"'"'"'~~''"'--- .." "., " ~,.iJv.srl ~uI~/ ~,ry.,Jp ~ ~~ ~lL ,~-~~ ~-'~-?9 ('~JC'-( Y'o,.?e J C'(/'~( \iINlfi\lA8NN3d AINnOO 0i,rii::1381t~nO 90 :'] ~J,d 62: five 20 1L"/l""",,; ,'" , " " '" AO'" UliV"i.l.\,;(](,J ::j~ U ::;u j::lI:I:IO-CI:Jli:J ,_~o~" - ~- c ~,'"_~"__~ _,~,~ .~",_=_~ _, ~_ ~_~_ =. .~ _~_ c~,~ ~ ~.' J. '.~J:.=~_""_-,,,,"U,,-c.",~~~.:i,-,,-,.:"",,""~,_ . _ --___<J',.;_".___~-_ LYNN W. GLA VIANO, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00-2117 CIVIL RICHARD T. GLA VIANO, DefendantlPetitioner : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before . Conciliator, at the . Pennsylvania, on the day of , 2002, at .m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to , Esquire, 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 the entry of a temporary or permanent Order. FOR THE COURT Dated: BY: Custody Conciliator YOU SHOULD TAKE TmS 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 -;:w~~Aii','if",~'1!t~~~Nlllm!- _ ar",,,,,~=_,,,.,,,..~,~'tl$l-" '''~"""r.~,<,_o~ -~~",.",,=~ ~~,,-" ""', -~ _~"","" ''-'__''''_C",,,""J.__, <~ "'~_ -<,.&:;l;".".,-",,,,,,;~-),-," C" "_~'__'<_""_'''---'' -"",,,~,t.;.. ""_~"';;_"~_"_ ".,,-"". "-'--.. _,_,-,_,- ~_"~_ ..~_._ ,,' " MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney LD. No. 279]4 210 Grandview A venue, Suite 102 Camp Hill, PA 17011 Telephoue No. (717) 909-4060 Attorneys for DefendanVPetitioner LYNN W. GLA VIANO, PlaintifflRespondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00-2117 CIVIL RICHARD T. GLA VIANO, DefendantlPetitioner : CIVIL ACTION - LAW : IN CUSTODY PETITION TO SCHEDULE CONCILIATION AND NOW COMES, Petitioner, Richard T. Glaviano, by and through his attorney, Maria P. Cognetti, Esquire, to Petition the Court for a custody conciliation in the above matter: 1. Petitioner, Richard T. Glaviano, is an adult individual residing at 528 Penn Ayr Road, Camp Hill, Pennsylvauia, 17011. 2. Respondent, Lynn W. Glaviano, is an adult individual residing at 570 S1. Johns Drive, Camp Hill, Pennsylvauia, 17011. 3. The parties are the natural parents offour minor children, namely Stephen R. Glaviano, born February 19, 1986, Lauren M. Glaviano, born December 26,1989, Kathryn E. Glaviano, born July 9,1991, and Meghan L. Glaviano, born July 9,1996. 4. Respondent filed a formal Complaint in Custody on April 7, 2000. i.~-~'~~~%.~""~_--'"'- ~-" ~ ~,'j'~__''''lU''*,,'"''''''''_"'''''''' -~""""., - ~""'-""'r"="''''r.,,,-,-i ~, _,~__,,"__~"' "_.J-,,,"_'H!b.i~,',,-,--:,--,--,,,,,,"_~.,h,,,,--,,,,,,,,,,-,,,,,-,,,"'_'''''L '___,"""",,''';~~.,, "'u:c_"_",,,"" _'_ ,,' 5. The parties attended a conciliation with Dawn S. Sunday, Esquire, on June 6, 2000 which did not result in an Order of Custody because there was an investigation pending, involving Children and Youth Services. 6. On August 31, 2000, a second conciliation was conducted by Dawn S. Sunday, Esquire, whereby an Order of Court was issued, dated September 13, 2000, which among other things, referred the parties to Dr. Arnold T. Shienvold for a custody evaluation and directed that an additional conciliation be held. Said Order is attached hereto as Exhibit "A". 7. A third conciliation was held on April 18, 2001 before Dawn S. Sunday, Esquire, which resulted in an Order, dated April 24, 2001, vacating the September 13, 2000 Order. Said Order is attached hereto as Exhibit "B". 8. The aforementioned Order, dated April 24, 2001 and marked as Exhibit "B", awarded shared legal custody of the minor children to the parties, primary physical custody of the rninor children to Respondent and scheduled partial physical custody to Petitioner. 9. The Order also required that the parties engage in a course of joint counseling, and that counseling for the children be continued. 10. The Order also set forth that either party may petition the Court to have the case, again, scheduled before the Custody Conciliator to review the custody arrangements, if necessary. 11. Respondent has not shown a commitment to attending joint counseling nor seeing that the minor children are scheduled and attend counseling, pursuant to the terms ofthe Order dated April 24, 2001. 12. Further, the parties are unable to resolve various matters concerning the custody ofthe minor children on their own. UlIlI!I ']~~~~",,"h~~~J~l~>l!l~~~lI)w J<;j <a. "''''''''''....__ --,"",,,,_...-..,.-,,,--~., "'""~'-"""""'" "- ->";---",,^""'~'=- .~~--, & '_>_~'_i...<~,_~.~=,-,-_,__,-, ,-, .1, .>.__~~k. ,_..",--,,,,,,,-,;,_,,',,;~..,6i~i-,,,,,",,,,,,,,,,,,,,,,_~,,,--,,,,,,c WHEREFORE, Petitioner respectfully requests this Honorable Court set this matter for a conciliation conference at the earliest possible time. Respectfully Submitted: MARIA P. COGNETTI & ASSOCIATES Date: January 17, 2002 By: MARIA P. COGN T , ESQUIRE Attorney I.D. No. 2 4 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Defendant/Petitioner It """__"'''''~\~''''''''-''''~7.'''''''''~'-- - >~""-",""fu,,,~_~,'_"_"'"'" -,,,,,"~",,,,,"~,,,-,,,,*,,,,-,,.......-- ~ "~-~~- "-""-., ~ -- ~ _, C_"~C"'__""Cc.~ """,~"~,,,-,",,,,,_,,,~,,''',",--,,'', j.." ,~, u,-",,,_.<,,';_'_"'''''_-b''',_,,"k=".,,._~,~~'., " ,~"",.""",',""--,,,-,-----,, \\NtlIb\family law\Client Diredory\Glaviano-R\Pleadings\Petition fur hearing.wpd 1/17/02 CERTIFICATE OF SERVICE I, Maria P. Cognetti, Esquire, Attorney for Defendant/Petitioner herein, do hereby certifY that on this date I served the foregoing Petition to Schedule Conciliation by depositing a true and exact copy thereof in the United States mail, fIrst class, postage prepaid, addressed as follows: Edward J. Weintraub, Esquire 2650 North Third Street Harrisburg, P A 1711 0 MARIA P. COGNETTI & ASSOCIATES Date: January 17, 2002 By: MARIAP. OG ,ESQUIRE Attorney J.D. No. 27 14 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Defendant/Petitioner """ ~~~~~~~ ~~1lII_;m;Cii_~_ ~~" ,-~~- ~_."..~ ~M~_'" ""'"'=",~~,~"'"'==~-" ~~ -~~,~~~ , 1-. r " .'", ~1i<ii., , " ) 'I '~ n 1;1 n r.:W;;'j ~ ..dJUJJ.,,_.; .,~,;; ~ 3EP 1 -4 2::~G LYNN W. GLAVIANO, Plaintiff ----______m~QDC~~~~&~=~~ : IN THE OOORT OF OOMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. : NO. 00-2117 CIVIL TERM : RICHARD T. GLA VIANO, Defendant : CIVIL ACTION - LAW IN CUSTODY . . ORDER OF COURT AND NCl;", this }3 <t day of ~. I., _ consideration of the attached Custody Con iliation Report, and directed as follows: , 2000, upon it is ordered 1. The parties shall submit themselves and their minor Children to a custody evaluation to be performed by Arnold Shienvold, PhD. ,The purpose. of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which would best serve the interests of the Children. The parties shall equally share all costs of the evaluation. 2. Kathryn and. LaUren shall begin a course of counseling with Bonnie Howard and_. Stephen's therapy shall be transferred from his current counselor,'tisa Lentz, to Bonnie Howard with the .transition to be handled as recorrnnended and supervised by Fran Sparrow and Bonnie Howard. The parties shall equally share all costs of the counseling which are not covered by insurance. .3. The Father and Stephen shall engage in a course of counseling with Bonnie Howard to address and resolve conflicts which have arisen in the Father/Son relationship. 4. The Father shall resume his course of therapy with Robert Beachey as recommended by Bonnie Howard or Arnold Shienvold. 5. The Mother, Lynn W. Glaviano, and the Father, Richard T. Glaviano, shall have shared legal custody of Stephen R. Glaviano, born February 19, 1986, Lauren M. Glaviano, born December 26, 1989, Kathryn E. Glaviano, born July 9, 1991 and Meghan L. Glaviano, born July 9, 1996. 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. . 6. pending further Order of Court or agreement of. the parti",s, the Mother shall have primary physical custody of the Children, and the' Father shall have partial' physical custody' in accordance' with the following schedule: .. A. The Father shall have custody of the Children from Sunday, September 3, 2000 at 9:00 a.m. through Monday, September 4, 2000 at 6:00 p.m. .- - _J_. "' , . . ~. ~ ,,, . "'';'l!:ft~; " ,. B. The parties shall share having custody of the Children on a four weekend cycle as follows: 1.) WEEKEND I: The Father shall have custody from Friday at 6:00 p.m. through Sunday at 6:00 p.m. 2.) WEEKE1!ID II: The Father shall have custody from Saturday at 12:00 noon through Sunday at 6:00 p.m. 3.) WEEKE1!ID III: The Mother shall have custody of the Children. 4. ) WEEKE1!ID IV: The Father shall have custody from Saturday at 12:00 noon through Sunday at 6:00 p.m. The weekend cycle shall commence with WEEKE1!ID I beginning on Friday, September 8, 2000 at 6:00 p.m. C. The Father shall have custody of the Children every Wednesday from after school, when the Children shall get off. the . bus at the Father "s. residence unless otherwise agreed' between the parties, until 8:30 p.m. 7. The parties shall share or alternate h~ving custody of the Children over holidays as follows: A. THANKSGIVING: In 2000, the Father shall have custody of the Children from the Wednesday before Thanksgiving at 6:00 p.m. through Thanksgiving Day at 3:00 p.m. and the Mother shall have custody from Thanksgiving Day at 3:00 p.m. through the following Friday at 6:00 p.m. B. CBRIS'l'MAS: In 2000, the Mother shall. have custody of the Children from Christmas Eve at 6:00 p.m. through Christmas Day at 12:00 noon. The Father shall have custody of the Children from Christmas Day at 12:00 noon through December 26 at 6:00 p.m., from December 27 at 12:00 noon through December 28 at 6:00 p.m., and from December 30 at 12:00 noon through December 31 at 6:00 p.m. C. The holiday. custody schedule s.hall supersede and take precedence over the regular custody schedule. 8. The Mother shall ensure that the Children contact the Father by telephone on Mondays, Thursdays and Fridays between 7:00 p.m. and 9:00 p.m. 9. The parties and counsel shall attend an additional Custody Conciliation Conference in the office of the Conciliator, Dawn S. Sunday, Esquire, on Tuesday, January 16, 2001 at 9:30 a.m. within 30 days of receipt of Dr. Shienvold's written custody recommendations, counsel for either party may contact the Conciliator to schedule an earlier Conference in lieu of the January Conference. ~ .J.~__ - ._L" h!!'i:' ,. \ 10. 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, Cl. n H > IsI ~ c. ~ J. , I cc: Edward J. Weintraub, Esquire - Counsel for Mother Maria P. Cognetti, Esquire - Counsel for Father TRUE COPY FHOM RECO~;D In TestL'llOIlY whereof,l h0fllllmll set my h:0110 ami tll'a ~ of said c~ at Carlisle, Pa. This /3C/;- ~d'.~ ProthonCltllri ..........'-,~ - [. ____"' - " .1' ." , .,~ ' LYNN W. GLA VIANO, : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. : NO. 00-2117 CIVIL TERM . . RICHARD T. GLA VIANO, : CIVIL ACTION - LAW Defendant : IN CUSTODY CUSTODY c::cNCILIATICN SUMMARY REPCRl' IN ACCORDANCE WITH COMBERLAND COONTY 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 subjects of this litigation.is as follows: NAME DATE OF BIRTH CURRElllTLY IN CUSTODY OF Stephen R. Glaviano Lauren M. Glaviano Kathryn E. Glaviano Meghan L. Glaviano February 19, 1986 December 26, 1989 July 9, 1991 July 9, 1996 Mother Mother Mother Mother 2. A Conciliation Conference was held on August 31, 2000, with the following individuals in attendance: The Mother, Lynn W. Glaviano, with her counsel, Edward Weintraub, Esquire, and the Father, Richard T. Glaviano, with his counsel, Maria P. Cognetti, Esquire. 3. It should be noted that a Conciliation Conference was previously held in this matter on June 6, 2000, at which time the parties also agreed to custody. arrangements. . However, at that time, an issue concerning the Children was under investigation by Children and Youth Services. The investigator at Children and Youth Services Objected to the parties' agreement on custody and the parties agreed to hold the proposed Order pending completion of the investigation. At the time of the second Conference, the investigation was complete (complaint "unfounded"), and Children and Youth Services were no longer involved. 4. The parties agree to entry of an Order in the form as attached. 5"c.p~G ~6 Date ( Ow-. ..:LA, .~ Dawn S, Sunday, Esquire Custody Conciliator =' ".."~-~ ' ':Il;i> , I I ~ I , 1 , i , i 1 , I ! I I I i LYNN W. GLAVIANO, . . IN THE OOURT OF COMMON P CUMBERLAND CCX.JNTY, PENNSy;r.V t:'\r:Jn" nr-:~' '.--'1 .1 fUr r~ J~. ~.t i.'. f ~i fl.' . ': I ~'~"'-'"-'111 Aprt ') r> ,r;r;'l P: . i\ t.." 0 ...v~ i j i ~ 9J"Tn::s@ . ;I -' Plaintiff : : vs. : NO. 00-2117 CIVIL TERM . . RICHARD T. GLAVIANO, Defendant : CIVIL ACTION - LAW : CUSTODY CRDER OF COURT AND J:iICJi, this J. </ 'g,,- consideration of the attached and directed as follows: day of n ~~ , 2001, upon CUstody C09lciliation Report, it is ordered 1. The prior order of this Court dated September 13, 2000, is vacated and replaced with this order. 2. The Mother, Lynn W. Glaviano, and the Father, Richard T. Glaviano, shall have shared legal custody of Stephen R. Glaviano, born February 19, 1986, Lauren M. Glaviano, born,Decernber 26, 1989, Kathryn E. Glaviano, born July 9, 1991 and Meghan L.Glaviano, born July 9, 1996. 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. pending further order of Court or agreement of the parties, the Mother shall have primary physical custody of the Children and the Father shall have partial physical custody in accordance with the following schedule: A. The parties shall share having custody of the Children on a four weekend cycle as follows: 1. ) WEEKEND I: The Father shall have custody from Friday at 6:00 p.m. through Sunday at 6:00 p.m. 2.) WEEKEND II: The Father shall have custody from Saturday at 12:00 noon through Sunday at 6:00 p.m. 3. ) WEEKEND III: Children. The Mother shall have custody of the 4. ) WEEKEND IV: The Father shall have custody from Saturday at 12:00 noon through Sunday at 6:00 p.m. B. The Father shall have custody of the Children every Wednesday from after school, when the Children shall get off the bus at the Father's residence unless otherwise agreed between the parties, until 8:30 p.m. .~ .~ , "~ ~ " iit::' '. I 4. The parties shall share or alternate having custody of the Children over holidays as follows: A. CHRISTMAS: The parties shall share having cUstody of the . Children over the Christmas holiday and school break in a manner to be agreed upon between the parties. B. THANKSGIVING/EASTER: The Thanksgiving and Easter holidays shall run from 4:00 p.m. on the last day of school before the holiday through 6:00 p.m. on the evening before school resumes after the holiday. In even numbered years, the Father shall have custody of the Children over Thanksgiving and the Mother shall have custody over Easter. In odd numbered years, the Mother shall have custody of the Children over Thanksgiving and the Father shall have custody over Easter. C. MmIUAL DAY/LABCR DAY: The Memorial Day and Labor Day holidays shall run from 4:00 p.m. on the last day of school prior to the holiday through 6:00 p.m. on the evening before school resumes after the holiday. In even numbered years, the Father shall have custody of the Children over Memorial Day and the Mother shall have custody over Labor Day. In odd numbered years, the Mother shall have custody of the Children over Memorial Day and the Father shall have custody over Labor Day. D. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 5. Both parties shall be entitled to have custody of the Children during the summer school break each year for three non-consecutive weeks, upon providing at least 30 days advance notice to the other party. 6. The parties shall engage in a course of joint counseling with a professional to be selected by agreement of the parties. The purpose of the counseling shall be to improve communication and address conflicts in order to enable the parties to effectively coparent their Children. 7. Kathryn shall continue her counseling with Victoria Whitcomb, unless otherwise agreed between the parties. 8. The parties agree that the Father and Stephen shall participate in counseling with Bonnie Howard as needed to address and resolve conflicts which have arisen in the Father/Son relationship. 9. Each party shall ensure that Stephen is not responsible for supervising the other Children during that party's periods of custody. 10. The Mother shall ensure that the Children contact the Father by telephone every Tuesday between 7:00 p.m. and 9:00 p.m. The Father may contact the Children and the Children may contact the Father by telephone at any other times. 11. Counsel for either party may contact the Conciliator by the end of I ,~ ,,' --..,,;... ,- ~. ) September 2001 to schedule an additional Custody Conciliation Conference to review the custody arrangements if necessary. 12. 1his 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 OCURT, / ia..f" ~ .,l E'. )j,. ~ -'-0 , rd E. Guido, J. cc: Edward J. Weintraub, Esquire - Counsel for Mother Maria P. Cognetti, Esquire - Counsel for Father OI,ARfFrf In r~ COPY FROM RECOFiD and ttMi~ ny Whereat, I her. unto se! my hand ~ of said Court.Jt Car/i4le 0. ThII ),i--c."hY 01 t. '5.:~1 (~Q .:.-;:- . Prot~:r-~ ~:" ." . . LYNN W. GLAVIANO, : IN THE C:;URT OF CXJMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . . : vs. . . NO. 00-2117 CIVIL TERM : RICHARD T. GLAVIANO, Defendant : CIVIL ACTION - LAW : CUSTODY PRICR JUDGE: Edward E. Guido CUSTODY <XIiICILIATICN SUMMARY REPCRT IN ACCClIDANCE WITH CIJMBERLAND CXXJNTY RULE OF CIVIL PRCCEDURE 1915.3-8, the undersigned CUstody Ccnciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF stephen R. Glaviano Lauren M. Glaviano Kathryn E. Glaviano Meghan L. Glaviano February 19, 1986 December 26, 1989 July 9, 1991 July 9, 1996 Mother Mother Mother Mother 2. A Conciliation Conference was held on April 18, 2001, with the following individuals in attendance: The Mother, Lynn W. Glaviano, with her counsel, Edward J. Weintraub, Esquire, and the Father, Richard T. Glaviano, with his counsel, Maria P. Cognetti, Esquire. 3. The parties agreed to entry of an Order in the form as attached. (~ dO. d--o:J / , ~ Custody Ccnciliator Date ~~d:"";' ~-,---,-- -~nliiiI.iliflf"""~~~- "~-""'''~,""llI:J~'1iID1ii~lll~~-~'''''''-ll 1 . .~ . ~_~~o ,~ ,-,-" . .. ~~W a ' " C) C) ) (J ~ C f"J " c.._. ~ d ;:gp~ -::'-'1+ ~."" ! -:..- -r~ '""'.. . Z ,- , (0. .___f ---, -<' ~':''- "- & 8 ~lJ )V '" ~~r~ ~-=--=. I --) () p:! Pc:: W ,- ',;-q ~ ~ ~'.-:1 ...() ,'C.,.. c.n ::0 \)r -< --..c:: ~~ J I B&L~_,.,.~j-~~ '~-'~.lI'=.b.!lill ,~~~ ,~~ ,- -- - .~'" . '-~",i LYNN W. GLA VIANO PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA V. 00-2117 CIVIL ACTION LAW RICHARD T. GLA VIANO DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, February 20, 2002 , upon consideration of the attached Cornplaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Suuday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, February 21,2002 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute:, or ifthis 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 confereuce. 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 aud 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: Isl Dawn S. Sunday. Esq. ~ 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 AITORNEY AT ONCE. IF YOU DO NOT HAVE AN AITORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTI:! BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ..", ~/~- o~ W€AE- ~'t.cL -..to ~ LL ~l;A c!:>y ~ ~ tJ~l.V. cro~. "i.'C'O'i!J.c' 11.:" ^'I;"iIoil_~.'!I!!;~~~I"illii~j;;&1;;j,!lMiliill~IiIliII'~".-~-'o" i}i- V;N\jf\~.L\SNN:~.d )\j,;-";rlCO O~,," , ~ I{~~ ~1 ~ ''1 ""{'I '::1\ " ~,~ Q!~ =~" ~, 'J&.i --, , , I I \ (~)a "_~ r, r" (' C CI <) \' ''''I'''' I'; J; j' \ ,.~"';,' "~. , '" If 'j t v......,).'...... - \"",./ '(1/ {(l'J(l ~ :_::,:':: "'A. ....,....~,.""_...~) 1..................("\".>.1.. \ !1.~, I i. "''''j .. , t " 't'l I ._.N-- j F' .... ) I! r'-'d I, '-',. ~ \i l -,'."'1 i/! "..>., . _ _ ;"7 .~;>- t 'I."~l";\,, ' j '''--''~1~ '. .'7 ! . ~, ~., '''U ftil'-l( \~" 'I' 'jf:"Uif , . .' 1./y\(t;(G~)'" . \0'.1 ...J p<A +r, . LI\_.i'.'~C", i/; _ '-_~_"-'="'"""'Io9""",-,-"",=,,,,,,l_,,,",~,-,-,,",~~_,,,~',"'d,~,,_,,H', ,,~l', '-'__,":~," ~~ od" __-,;~~,' ___I_,",'__,-,_,._._~ ,~c ' MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney 1.0. No. 279]4 210 Grandview A venue, Suite ] 02 Camp Hill, PA 17011 Te]ephone No. (7] 7) 909-4060 Attorneys for OefendanVPetitiouer LYNN W. GLA VIANO, PlaintifflRespondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00-2117 CIVIL RICHARD T. GLA VIANO, DefendantlPetitioner : CIVIL ACTION - LAW : IN CUSTODY PETITION FOR CONTEMPT AND NOW, comes Petitioner, Richard T. Glaviano, by and through his attorney, Maria P. Cognetti, Esquire, and files the following Petition for Contempt and in support thereof avers as follows: I. The Petitioner is Richard T. Glaviano, Defendant in the above-captioned matter, who currently resides at 528 Penn Ayr Road, Camp Hill, Pennsylvania. 2. The Respondent is Lynn W. Glaviano, Plaintiff in the above-captioned matter, who currently resides at 66 Old Pioneer Road, Camp Hill, Pennsylvania. 3. The parties hereto are the parents of the minor children, namely, Stephen R. Glaviano, born February 19, 1986, Lauren M. Glaviano, born December 26, 1989, Kathryn E. Glaviano, born July 9,1991, and Meghan L. Glaviano, born July 19, 1996. 4. On April 24, 2001, the Honorable Edward E. Guido, entered an Order of Custody .. lIrJ ~~~M'i.~""~~'-~M~"'='''''~~''"~'''''''''""-','nM'_ ~ '~",c_"",="",",,,",,,,,,,,,,,"--"""""~_'-= _.~ ~ -"=,,==-~-_,,~~~~_,~ ,-"- ,~-~,--- . _ _ Hc"~,~""""""J",.~".c". _ _,--",,,1:_-,",, L,,,,.,",, in the Court of Common Pleas of Cumberland County, Pennsylvauia. A true and correct copy of said Order of Court is marked Exhibit "A", attached hereto and made a part hereof. 5. The Order provides that the parties shall share legal custody of the minor children and have an equal right in making "...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." 6. Said Order provided that primary physical custody ofthe minor children be in Respondent, subject to periods of partial physical custody in Petitioner. Said periods of partial physical custody were to include a specified weekend and holiday schedule, as well as "...every Wednesday from after school, when the Children shall get offthe bus at the Father's residence unless otherwise agreed between the parties, until 8:30 p.m." 7. The Order also specifically provides, in numbered paragraph 6, that "[t]he parties shall engage in a course of joint counseling with a professional to be selected by agreement of the parties. The purpose of the counseling shall be to improve communication and address conflicts in order to enable the parties to effectively coparent their Children." 8. Since the entry of said Order of Court, Respondent has willfully failed to comply with the custody provisions as required by this Honorable Court, in spite ofthe fact that Respondent has been and continues to be able to comply with the terms thereof. Specifically, Respondent has violated that Order by the following actions: (a) In violation of paragraph 3(B) of the Court's Order, Respondent has failed to provide Lauren for periods of partial physical custody with Petitioner after school on Wednesday on October 24, 2001, November 7, 2001, November 14,2001, November 28, ~~Ui . @i.N.'Ji:~>f~r:;w';",-"!!~;w-.~iI'mll"""1!\;~",__~~"-",,-,,",,,,_.._-,,-,"""--------~,~~-~ ,- ~ -",.- _n _ _- ~,_~_-'-"-,-==>'",~ili~_",-"-,,,-L.,,",''''_I__'~~''''--'-'__''----,-~iJ ~.i~"--'j'" ,----.'"_<1_-- -" c._.,_'d.'" 2001, December 5, 2001, December 12,2001, January 9, 2001, January 16,2002, January 23,2002, January 30, 2002, February 6, 2002 and February 13,2002. Said absences were not due to illness. (b) In violation of paragraph number 6 ofthe Court's Order, Respondent failed to appear for the counseling session, scheduled for December 6, 2001, and has refused to reschedule or participate in any way, since that date. Petitioner paid a total of $557.50 in counseling fees to date. Joint counseling was not completed, pursuant to this Court's Order resulting in a loss to Petitioner for the stated amount spent on partial counseling. In order to complete counseling, pursuant to the Court's directive, the parties will have to start over with a new counselor. (c) Respondent has failed to ensure that Lauren attend scheduled religious education classes. Specifically, Lauren did not attend classes on January 9, 2002, January 16,2002, January 23,2002, January 30, 2002, February 6, 2002, February 13,2002, in addition to numerous classes scheduled in the year 2001. Said absences were not due to illness. (d) Respondent has failed to ensure that the minor children attend religious services on May 6, 2001, June 3, 2001, July 1,2001, July 29, 2001, August 26,2001, September 23, 2001, October 21, 2001, November 18,2001, December 16, 2001, January 13, 2002, and February 10, 2002. Said absences were not due to illness. 9. Due to Respondent's obdurate behavior, Petitioner has lost substantial partial custodial time with Lauren, the minor children have been denied religious training and worship, and Petitioner has suffered monetary loss due to unfinished counseling attempts. ~~![;l~: ..LL.:Y_W;~~.L.4.l.i.~"'__~___ --~.---_._~, -~..- ^c.^^~.~__","",L~", ,,' . .:"'_~"- ,.l.3,-,.L-"-'--'--~_,-"", _--'_~'_ ~~ ,,,_ 1 O. Petitioner believes and therefore avers that Respondent has no intention of complying with the terms of the Order of Custody, dated April 24, 2001. II. Petitioner believes and therefore avers that Respondent has acted directly contrary to the dignity and authority ofthis Court and has acted in direct defiance of the aforementioned Court Order. 12. The actions of Respondent have already compelled, and will continue to compel, Petitioner to expend large amounts of time and money in the pursuit of the rights previously granted under this Court's Order. 13. A Petition for Modification of Custody is scheduled to be heard on Thursday, February 21,2002 at 8:30 a.m., before Custody Conciliator, Dawn Sunday. In the interest of judicial efficiency, Petitioner suggests this matter be heard at that time. WHEREFORE, Petitioner respectfully requests that this Honorable Court enter an order adjudicating Respondent in contempt of Court and direct the following: (a) Respondent shall ensure that the minor children attend religious education classes; (b) Respondent shall ensure that the minor children attend religious services; (c) Respondent shall provide the minor child, Lauren, after school on Wednesdays for their scheduled periods of partial physical custody with Petitioner; (d) Respondent shall reimburse Petitioner in the amount of$557.50 for counseling commenced but not completed; (e) Respondent shall make herself available for counseling and continue to .lt1l _ ~ m "" ~~-'-- - - -",--,- . . ~,___~~"-,J-,--,,-,,~~=&l"""""~'J, ,,,,,,,:;,~_,,,,~,,,,,-,,",,'~,,,,!s~.i;_,,,,_L,,-,,,_jL", ..,.'",::,~d-c",,"-_"__,'-""'-- ;_~~~d",",,__"C"_" -~_" ,,_,,~',.',,_~ attend sessions until counseling is complete; (f) Respondent shall be ordered to comply with all the terms of the Order; (g) Petitioner be granted reasonable counsel fees and costs in the amount of $500.00 for having to bring this action. Respectfully Submitted: MARIA P. COGNETTI & ASSOCIATES Date: February 19,2002 By: 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Defendant/Petitioner ~~..m...,.,..,.~~- ~.~lm$~~~~'l>I~'~~'''''7'rli .~~"";'=""""=~ ~",Jl;-'-" =<:;.~,- ~~ ~'----;"',;,.""~;,,."-~-~ .~~~~~._.'~~= -~-~'. "" " VERIFICATION I, Richard T. Glaviano, hereby verifY and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. !j4904 relating to unsworn verification to authorities. tfJc1~ r;M~~ Richard T. Glaviano . DATE: 'd\\~IOd- ~tiiPill~"I.!)$-- ~-~'ht!!i!f"Wi'i\_~~~,="'W",~,tJlv<,,,,,,~,-;,(,"~,,-,,_,__~ ""'."""",",,",<_ .w= _ __ ~" _"w,~ .. "=""""'""~'" T~ ~-1i,'"T , ., .) ) I (I h '.' !I II II II ':.'..1' !i II I II 'I II '.1' i ~ II , i' "I II I ~I ~I II i'l tl ~i !I 'I II !i il ! II I II I. 'I II II II . LYNN W. GLAVIANO, Plaintiff : IN THE COURT OF COMMON P : CUMBERLAND COUNTY, PENNS~" . . vs. : NO. 00-2117 CIVIL TERM : RICHARD T. GLAVIANO, Defendant : CIVIL ACTION - LAW : CUSTODY ORDER OF CCXlRT AND NCW, this i1 L/ ~ consideration of the attached and directed as follows: day of ()~ , 2001, upon Custody C04iciliation. Report, it is ordered 1. The prior Order of this Court dated September 13, 2000, is vacated and replaced with this Order. 2. The Mother, Lynn W. Glaviano, and the Father, Richard T. Glaviano, shall have shared legal custody of Stephen R. Glaviano, born February 19, 1986, Lauren M.Glaviano, born. December 26, 1989, Kathryn E.. Glaviano, born July 9, 1991 and Meghan L,'Glaviano;bOJ;TlJuly9, 1996. Eacl)parent shall have an equal right, to be exercised jointly with, i-h", other J;)Clrent, to' make all major--non-ernergency.: d~cisions . affe~ting the Children's general well-being including,. but :not limited to; all' decisiohsregarding their health, education and religion. 3. pending further Order of Court or agreement of the parties, the Mother ",h" 11 h""", primarv ohysical custody of the Children and the Father shall have partial physical custody in accordance with the following scheOUle: A. The parties shall share having custody of the Children on a four weekend cycle as follows: 1.) WEEKEND I: The Father shall have custody from Friday at 6:00 p.m. through Sunday at 6:00 p.m. 2.) WEEKEND II: The Father shall have custody from Saturday at 12:00 noon through Sunday at 6:00 p.m. 3. ) WEEKEND III: Children. The Mother shall have custody of the . 4.) WEEKEND IV: The Father shall have custody from Saturday at 12:00 noon through Sunday at 6:00'p.m.. B. The Father shall have Custody of the Children every Wednesday frOm after school, when. the Children shall get off the bus at the . Father's residence unless otherwise agreed between the parties, until 8:30 p.m. ....- , ,-.. =,1 i1i!!,ilillS!i;lIli.iill,ll]l;ill!i..~,:J, ~ , .) ) 4. The parties shall share or alternate having custody of the Children over holidays as follows: A. CHRISTMAS: The parties shall share having custody of the . Children over the Christmas holiday and school break in a manner to be agreed upon between the parties. B. THANJi[SGIVING/EASTER: The Thanksgiving and Easter holidays shall run from 4:00 p.m. on the last day of school before the holiday through 6:00 p.m. on the evening before school resumes after the holiday. In even numbered years, the Father shall have custody of the Children over Thanksgiving and the Mother shall have custody over Easter. In odd numbered years, the Mother shall have custody of the Children over Thanksgiving and the Father shall have custody over Easter. ,. 1: i:j !:i n C. MIM:IUAL OAY/LABCR DAY: The Memorial Day and Labor Day holidays shall run from 4:00 p.m. on the last day of school prior to the holiday through 6:00 p.m. on the evening before school resumes after the holiday. In even numbered years, the Father shall have custody of the Children over Memorial Day and the Mother shall have custody over Labor Day. In odd numbered years, the Mother shall have custody of the Children over Memorial Day and the Father shall have custody over Labor Day. D. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 5. Both parties shall be entitled to have custody of the Children during the summer school break each year for three non-consecutive weeks, upon providing at least 30 days advance notice to the other party. 6. The parties shall engage in a course of joint counseling with a professional to be selected by agreement of the parties. The purpose of the counseling shall be to improve communication and address conflicts in order to enable the parties to effectively coparent their Children. 7. Kathryn shall continue her counseling with victoria Whitcomb, unless otherwise agreed between the parties. 8. The parties agree that the Father and Stephen shall participate in counseling with Bonnie Howard as needed to address and resolve conflicts which have arisen in the Father/Son relationship. 9. Each party shall ensure that Stephen is not responsible for supervising the other Children during that party I s periods of custody. 10. The Mother shall ensure that the Children contact the Father by telephone every Tuesday between 7:00 p.m. and 9:00 p.m. The Father may contact the Children and the Children may contact the Father by telephone at any other times. 11. Counsel for either party may contact the conciliator by the end of -.- ~ ~~~~~ ~, , ,~- ~. .~"-~._, ~ '. - rr-blll~~I;.lbl;,k<t'_ '" 1 .j ): September 2001 to schedule an additional Custody Conciliation Conference to review the custody arrangements if necessary. 12. 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 CCURT, /s/ F;.,,,~...J. e 1Jt.~,,'.:> , Edward E. Guido, J. cc: Edward J. Weintraub, Esquire - Counsel for Mother Maria P. Cognetti, Esquire - Counsel for Father DIARIE[1 TRUe COPY FRO In T-in.",- . .MRSCORD and -;;:;......, Whereof.' bere unto set ml' hand u.., ~ of sald C___ Carl'''''' ThII .lfI~~ of~. '. , ""'IJ'~J (~ Q. ... .:, ~ PnItttontia .. I"f B -~ ~ ,~ ~-~ ,~ .~ . -"'" "'-~_. .' .. .> .) .~ LYNN W. GLAVIANO, . . IN THE OJORT OF OJMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : : vs. : NO. 00-2117 CIVIL TERM . . RICHARD T. GLAVIANO, Defendant : CIVIL ACTION - LAW : CUSTODY PRIOR JUDGE: Edward E. Guido I) i-' I" ;,~ CUSTODY CCIiICILIATICN SUMMARY REPORT IN Ac:cmoANCE WITH CUMBERLAND CClIJNTY RULE OF CIVlI. PR<XE>URE 1915.3-8, the undersigned Custody Conciliator submits the following report: i, '.i (\ p" ~) -'0 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: ]'; " NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Stephen R. Glaviano Lauren M. Glaviano Kathryn E. Glaviano Meghan L. Glaviano February 19, 1986 December 26, 1989 July 9, 1991 July 9, 1996 Mother Mother Mother Mother \>: i, 1';- h I , 2. A Conciliation Conference was held on April 18, 2001, with the following individuals in attendance: The Mother, Lynn W. Glaviano, with her counsel, Edward J. Weintraub, Esquire, and the Father, Richard T. Glaviano, with his counsel, Maria P. Cognetti, Esquire. I,' t 3. The parties agreed to entry of an Order in the form as attached. cPJ. d--ou ( , ~ Custody Ccnciliator . ~c~,,_~'_k~L"'2'C~. LC. __C _ _ ' ,;~_ '--'_.CO,_ \\NTSB\Family Law\Client DirectoryVJlaViano-R\Pka!ings\Petition for Contempt.wpd 2119/02 CERTIFICATE OF SERVICE I, Maria P. Cognetti, Esquire, Attorney for Petitioner herein, do hereby certify that on this date I served the foregoing Petition for Contempt by depositing a true and exact copy thereof in the United States mail, first class, postage prepaid, addressed as follows: Edward J. Weintraub, Esquire 2650 North Third Street Harrisburg, P A 1711 0 MARIA P. COGNETTI & ASSOCIATES Date: February 19,2002 By: MARIA . CO TTI, ESQUIRE Attorney LD. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Petitioner J1 ~~ ""...;,i"m;3l':!-~rltL ..... ''''~'\iWJ~#l~ltIg!S'f11,!\--'''F'';~W~-'' --~:llett.<j'~-~~'''--~ -"''''''~ -~---"".,.""'''"' ~~ ~,~-~-~, --"~ __._ ,-_I,,"., >"~,_, ....... "-> - -J) (f? -.......J ~.... .'. pp~ If:- tf C' 1'"" 0 o tJ r ~ ....--... ~ Ct) -.J ...li<ll~ . -"" :;"-b ,~-":~,,, Y"'~;-.,;(' ;3f--::~; .<.,- ' :7 -~. c-' ~. r:~ :...,;; 1~[~' ""-::. .""",;.' (") C ~. , ,,'"---;~-~""""-"' ~:'..l f\,,,J ,-""; ;-1 -'1 "1 '_);;;1 .) C:') :-D ...J ,-j :::0 -< -l'" ,1'it~~' "",~".l""'~--" ~h'"L ...__. ~_~~ - _,~~._ n. .. .. ~.' ~ -~>-~~~~.~-~="" 'iliIIl!/fJi:C'f, .. , . - LYNN W. GLA VIANO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA vs. 00-2117 CNIL ACTION LAW RICHARD T. GLA VIANO, Defendant IN CUSTODY ORDEROF COURT AND NOW, this J~ day of _p~ r ' 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated April 24, 200 I shall continue in effect as modified by this Order. 2. The parties shall participate in a minimum of three counseling sessions with Arnold Shienvold, PhD., for the purpose of assisting the parties in resolving conflicts which have arisen with regard to the custody arrangements as raised in the Father's Petitions for Modification and Contempt. The parties shall complete the first three counseling sessions within 60 days ofthe date of this Order as long as Dr. Shienvold's schedule permits. 3. The Father shall arrange a meeting with Father Kramer and Lauren during the Father's period of custody to discuss issues which have arisen with regard to Lauren's attendance at ,dCD / classes. / 4. The parties agree to continue further consideration of the Father's Petitions for Modification and Contempt pending completion of the counseling and meeting(s) with Father Kramer, at which time the Father's counsel may contact the Conciliator to schedule an additional Custody Conciliation Conference if necessary. At that time, the Mother may file a Petition to Modify with the Court, if necessary, upon which a Conference will be scheduled. 5. Paragraph 8 of the April 24, 2001 Order is vacated. Edward E. Guido, J. cc: Maria P. Cognetti, Esquire - Counsel for Father Edward J. Weintraub, Esquire - Counsel for Mother . ~ 3'O'l-O~ r Cf-. I :~;i~'o'..;'.J 'UlNli_~~I~..~~~1't~~~1..1lI11 . . \7'INViIlASNN3d ~ tUNno~ Gri\:iliJ,J8V'mo cS :01 t4V AlfV10NU" ?rJu.~:F:) 1- )ilf'J -'r; .... ",t'l G,1,,1 t;:';. (1-:1 ;,~ ;;t<':-'.w,p.. .,., '~IfiIlIfliI"~ . ~ '. ,"~- ~~~~ - . ~,<,~. . ~.. ~ --,,_lJj~;;i,,__' LYNN W. GLA VIANO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-2117 CIVIL ACTION LAW RICHARD T. GLA VIANO, Defendant IN CUSTODY PRIOR JUDGE: Edward E. Guido CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CU)\1BERLAND 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 subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Stephen R. Glaviano Lauren M. Glaviano Kathryn E. Glaviano Meghan L. Glaviano February 19, 1986 December 26, 1989 July 9, 1991 July 9, 1996 Mother Mother Mother Mother 2. A Conciliation Conference was held on February 21,2002, with the following individuals in attendance: The Mother, Lynn W. Glaviano, with her counsel, Edward J. Weintraub, Esquire, and the Father, Richard T. Glaviano, with his counsel, Maria P. Cognetti, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ~ ~~? ~ Date . Dawn S. Sunday, Esquire Custody Conciliator Johnson, Duffie, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-01 09 (717) 761-4540 Attorneys for Defendant Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LYNN W. GLAVIANO, v. NO. 00-2117 CIVIL TERM RICHARD 1. GLAVIANO, CIVIL ACTION - LAW Defendant IN CUSTODY PETITION FOR SPECIAL RELIEF PURSUANT TO Pa. R. C. P.1915.4 (e) AND NOW; this btfvday Of~ ' 2007, Petitioner, Richard T. Glaviano, by and through his attorneys, Johnson, Duffie, Stewart & Weidner, files this Petition for Special Relief, and in support of his petitions avers as follows: 1. Your Petitioner is Richard T. Glaviano. 2. Your Respondent is Lynn Bucks, formerly known as Lynn W. Glaviano. 3. Respondent is represented by J. Paul Helvy, Esquire, and Cheryl Krentzman, Esquire who are aware of the filing of the instant petition but whose client does not concur with the relief sought. 4. The most recent Orders in this matter were signed by Judge Guido on April 24, 2001 and February 28, 2002. These Orders appear at Exhibits A and B respectively. 5. The parties are the parents of three minor children: Lauren M. Glaviano, born December 26,1989; Kathryn E. Glaviano, born July 9,1991; and Meghan L. Glaviano, born July 9, 1996: 6. Respondent is leaving for a trip to Hawaii on March 10,2007, and returning on March 24, 2007. 7. Rather than asking Petitioner to assume custody of the children during her honeymoon trip, Respondent arranged for a sophomore in a local college to be the children's caregiver. 8. Petitioner attempted to work with Respondent to work out a mutually acceptable agreement concerning the care and custody of the children during Respondent's trip, without success. 9. Petitioner retained counsel who was not able to obtain an agreement by working with Respondent's counsel. 10. Petitioner does not believe it is in the children's best interests to leave them primarily in the care of a college student, who is believed to be 19 or 20 years old, during Respondent's absence, rather than a ready willing and able parent who resides two blocks away. 11. Because neither counsel, nor the parties have been able to reach an agreement, Petitioner was left with no other option but to seek Court intervention. 12. Petitioner avers Respondent's refusal to agree to his having custody of the parties' youngest child and daily contact with the older children as another act in her ongoing pattern of marginalizing his role as a parent. 13. Petitioner seeks an Order granting the following: a. Custody of Meghan to Petitioner, throughout Respondent's absence, without regard to the schedule in the Order of April 24, 2001. b. Kathryn and Lauren shall have not less than one face-to-face visit with Petitioner, for a meal, or in the evening after their work hours if they are working during the dinner hour. c. Any permission for the children to go outside of the Camp Hill! Mechanicsburg ! Lemoyne areas would be sought from Petitioner, rather than from the caregiver. d. In the event that an urgent or emergent situation arises with one of the children, such as illness, Petitioner shall be informed immediately. e. No later than March 8, 2007, Respondent shall provide the time and airport of her departure and arrival for the upcoming trip. WHEREFORE, Petitioner respectfully requests this Court to grant his Petition for Special Relief as outlined above, and any other such relief as the Court deems appropriate. 'By: Melissa Peel Greevy :292826 VERIFICA TION I, Richard T. Glaviano, do verify that the statements made in the foregoing Petition for Special Relief are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. ~~~a~~ Dated: /J1aA- ~ ;20tJ7 . CERTIFICA TE OF SERVICE AND NOW, this ~ay of March, 2007, the undersigned does hereby certify that she did this date serve a copy of the foregoing Petition for Special Relief upon the other party of record and her counsel by facsimile to (717)237-5300 and by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: J. Paul Helvy, Esquire Cheryl Krentzman, Esquire 100 Pine Street POBox 1166 Harrisburg PA 17108-1166 By: EXHIBIT "A" . 1 -- '" .-' ~~3 i : i ~ . CJL:!J LYNN W. GLAVIANO, Plaintiff IN THE (X)URT OF <X>MMON P : CUMBERLAND C<XJNTY, PENNS~1,( : vs. : NO. 00-2117 CIVIL TEF<M . . RICHARD T. GLAVIANO, Defendant . . CIVIL AcrICN - LAW CUSTODY : OODER OF CCXJRT AND R:li, this ;J. ~ ~ day of ~ ' 2001, upon consideration of the attached CUstody C ciliation Report, it is ordered and directed as follows: 1. 'Ihe prior order of this Court dated September 13, 2000, is vacated and replaced with this Order. 2. The Mother, Lynn W. Glaviano, and the Father, Richard T. Glaviano, shall have shared legal custody of Stephen R. Glaviano, born February 19, 1986, Lauren M. Glaviano, born. December 26, 1989, Kathryn E. Glaviano, born July 9, 1991 and Meghan L.Glavian";bornJuly9, 1996. Each parent shall have an equal right, to be exercised jointly with the other parent, to rna:ke all major non-emergency. decisions. affec.ting the Children's general well-being' including, bu~ not limited to; all' decisions regarding their health, education and religion. . 3. Pending further order of Court or agreement of the parties, the Mother shall have primary physical custody of the Children and the Father shall have partial physical custody in accordance wi th the following schedule: A. The parties shall share having custody of the Children on a four weekend cycle as follows: 1. ) WEEKmD I: The Father shall have custody from Friday at 6:00 p.m. through Sunday at 6:00 p.m. 2. ) WEEKmD II: The Father shall have custody from Saturday at 12:00 noon through Sunday at 6:00 p.m. 3. ) WEEKE2ID III: Children. The Mother shall have custody of the 4.) ~ IV: The Father shall have custody from Saturday at 12:00 noon through Sunday at 6:00 p.m. B. The Father shall have custody of the d1ildren every Wednesday fran after school, when the Children shall get off the bus at the Father's residence unless otherwise agreeCl between the parties, until 8:30 p.m. '. 4. The parties shall share or alternate having custody of the Children over holidays as follows: A. C8RISTMAS: The parties shall share having custody of the . Children over the Christmas holiday and school break in a manner to be agreed upon between the parties. B. THANKSGIVING/EASTER: The Thanksgiving and Easter holidays shall run from 4:00 p.m. on the last day of school before the holiday through 6:00 p.m. on the evening before school resumes after the holiday. In even numbered years, the Father shall have custody of the Children over Thanksgiving and the Mother shall have custody over Easter. In cad numbered years, the Mother shall have custody of the Childrery over Thanksgiving and the Father shall have custody over Easter. c. MEM:lUAL DAYjI.AB:R DAY: The Memorial Day and Labor Day holidays shall run from 4:00 p.m. on the last day of school prior to the holiday through 6:00 p.m. on the evening before school resumes after the holiday. In even numbered years, the Father shall have custody of the Children over Memorial Day and the Mother shall have custody over Labor Day. In odd numbered years, the Mother shall have custodY of the Children over Memorial Day and the Father shall have custody over Labor Day. D. The holiday custody schedule shall supersede and take precedence over the regular custody schedule~ 5. Both parties shall be entitled to have custody of the Children during the surmner school break each year for three non-consecuti ve weeks, upon providing at least 30 days advance notice to the other party. 6. The parties shall engage in a course of joint counseling with a professional to be selected by agreement of the parties. The purpose of the counseling shall be to improve communication and address conflicts in order to enable the parties to effectively coparent their Children. 7. Kathryn shall continue her counseling with Victoria Whitcomb, unless otherwise agreed between the parties. 8. The parties agree that the Father and Stephen shall participate in counseling with Bonnie Howard as needed to address and resolve conflicts which have arisen in the Father/Son relationship. 9. Each party shall ensure that Stephen is not responsible for supervising the other Children during that party's periods of custody. 10. The Mother shall ensure that the Children contact the Father by telephone every Tuesday between 7:00 p.m. and 9:00 p.m. The Father may contact the Children and the Children may contact the Father by telephone at any other times. 11. Counsel for either party may contact the Conciliator by the end of .. September 2001 to schedule an additional CUstody Conciliation Conference to review the custody arrangements if necessary. 12. '!his 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 IIllJtual consent, the terms of this Order shall control. BY THE OCURT, J~ f:ALI~ f. ~ , ward E. Guido, J. cc: Edward J. weintraub, Esquire - Counsel for Mother Maria P. Cognetti, Esquire - Counsel for Father DIARIF=rf I.. TT~ COPY FROM RECQr\r'?D R.f -ltJflony Whereat f ~ '. . I and ttJt. ~ .' fllllJ & unto ~ my hand . ~ u:- 01 said COUftM Car ,_ ThI8 ;'i~ . ~ '~J ( ~Q .<.~- -' .J Prothonotar)' LYNN W. GLA VIANO, IN THE mURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . . - vs. : NO. 00-2117 CIVIL TERM . . RICHARD T. GLAVIANO, Defendant . . CIVIL ACTION - LAW CUSTODY PRICE JUDGE: Edward E. Guido CUSl'ODy et::ECILIATIrn SUMMARY R.E:I?CRT m ACXXlIDANCE WITH o::MBERLAND CXlJNTY RULE OF Crvn. PRD:EDURE 1915.3-8, the undersigned CUstody Ccnciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CORRENl'Ly IN CUSTODY OF Stephen R. Glaviano Lauren M. Glaviano Kathryn E. Glaviano Meghan L. Glaviano February 19, 1986 December 26, 1989 July 9, 1991 July 9, 1996 Mother Mother Mother Mother 2. A Conciliation Conference was held on April 18, 2001, with the following individuals in attendance: The Mother, Lynn W. Glaviano, with her counsel, Edward J. Weintraub, Esquire, and the Father, Richard T. Glaviano, with his counsel, Maria P. Cognetti, Esquire. 3. The parties agreed to entry of an Order in the form as attached. /1 (~.J ;lv. ~( J D~ CUstody Ccnciliator Date EXHIBIT liB" 1/ (I'1pt e~t1 -1/' c~~_ '1 /t~~l LYNN W. GLA VIANO, 0v~.J;t- t( Plaintiff J --0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-2117 RICHARD T. GLA VIANO, Defendant IN CUSTODY ORDER OF COURT AND NOW, thi~ J-~ day of J~ · . (r , 2002, upon consideration 6fthe attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated April 24, 2001 shall continue in effect as modified by this Order. 2. The parties shall participate in a minimum of three counseling sessions with Arnold Shienvold, PhD., for the purpose of assisting the parties in resolving conflicts which have arisen with regard to the custody arrangements as raised in .the Father's Petitions for Modification and Contempt. The partieS shall complete the first three counseling sessions within 60 days of the date of this Order as long as Dr. Shienvold's schedule permits. 3. The Father shall arrange a meeting with Father Kramer and Lauren during the Father's period of custody to discuss issues which have arisen with regard to Lauren's attendance at e'CD classes. ' , I 4. The parties agree to continue further consideration of the Father's Petitions for Modification and Contempt pending completion of the counseling and meeting(s) with Father Kramer, at which time the Father's counsel may contact the Conciliator to schedule an additional Custody Conciliation Conference if necessary. At that time, the Mother may file a Petition to Modify with the Court, if necessary, upon which a Conference will be scheduled. ~ ' 5. Paragraph 8 of the April 24, 2001 Order is vacated. Edward E. Guido, J. cc: . Mana 1>. CogIietti;Esquire - Counsel for Father - Edward r Weintraub, Esqurre - Counsel for Mother T, r~ ~ ~ (i'-" ("~ ""- .,'-" .; ,"-tLi(': t.,"~:~Ar.!J'~':' In T eti~~Y~C~(f\r : ~ (j,nd K~~'~~'~.,;' .:.::. :"_:, .. '. _ < ,'" . " .; _' ~ ~ This /J7~; .}.{~ ~~~ n_....t-L . " . .~, LYNN W. GLA VIANO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-2117 CIVIL ACTION LAW RICHARD T. GLA VIANO, Defendant IN CUSTODY PRIOR JUDGE: Edward E. Guido 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 subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Stephen R. Glaviano Lauren M. Glaviano Kathryn E. Glaviano Meghan L. Glaviano February 19, 1986 December 26, 1989 July 9, 1991 July 9, 1996 Mother Mother Mother Mother 2. A Conciliation Conference was held on February 21,2002, with the following individuals in attendance: The Mother, Lynn W. Glaviano, with her counsel, Edward J. Weintraub, Esquire, and the Father, Richard T. Glaviano, with his counsel, Maria P. Cognetti, Esquire. ~ ~.ko,). Date 3. The parties agreed to entry of an Order in the form as attached. fl~ Dawn S. Sunday, Esquire Custody Conciliator 1- () i,Q. t CI) () . """'- ~ D ~ ~ ()t ~ p::J C5 ~ ~ --t:- (') r' ,~ r--3 = c;:;') __J o -n .-t :L.-n ~:~r;l 9 ~\)O ',: >"J_, ='.1."_'. :"-.".i ........... ;)(') ~ ?'')rn ~ ~ .< :t:..-_~ :;;<.J I U1 -0 1'..) 0, -! , , MAR 0 I) 2007 LYNN W. GLAVIANO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-2117 CIVIL TERM RICHARD T. GLAVIANO, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER AND NOW, this ~ day of March, 2007, during the period that the Respondent is on her trip to Hawaii, presently expected to be March 10, 2007 until March 24, 2007, it is hereby ORDERED and DIRECTED as follows: 1. Meghan Glaviano shall be in the custody of the Petitioner, throughout Respondent's . absence, without regard to the schedule in the Order of April 24, 2001 A.k ff::t ~ .f~ _-~ 2. Kathryn Glaviano and Lauren Glaviano shall have not less than one face-to-face visit with Petitioner, for a meal, or in the evening after their work hours if they are working during the dinner hour. 3. Any permission for the children to go outside of the Camp Hill I Mechanicsburg I Lemoyne areas shall be obtained from Petitioner, rather than from the caregiver. 5. No later than March 8, 2007, Respondent shall provide the date, time and airport 4. In the event that an urgent or emergent situation arises with one of the children, such as illness, Petitioner shall be informed immediately. her departure and arrival for the upcoming trip. CCt-)~ ~'F< . ~ (b.) ~~~~~ ~~c.:r~. .,,"'"'11;.... \ ~ ~ "', "'-_ 10 <\ ~ . + ;;... { ~ 'It " " l ..~.. , No: 00-2117 CIVIL TERM Edward E. Guido, J. Distribution: ~ssa P. Greevy, Esquire P. O. Box 109 Lemoyne, PA 17043-0109 v'J. Paul Helvy, Esquire P. O. Box 1166 Harrisburg, PA 17108-1166 ...._..~..--- c' .....{) CC ~/ ...,.... "~J ..,...r.(-,: I ;;:' '~: ! ~ f" h '''1 f jl-! ~'I .u r(if 6- dV!~ iDOZ . tf .1.....,... '. ,!, j ""1'11 '0 A t1; i ,~j\:'_ ""'1:' :;"(":1 ~'~i ..,. ... 1.....:-'w.1 ~.......\ ;_.',/,._.._~, __