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HomeMy WebLinkAbout01-03383 - , CYNlliIA S. GLOECKLER PLAINTIFF V. TIMOTHY E, GLOECKLER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-3383 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, ~onday,Junell,2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, ~echanicsburg, PA 17055 on Tuesday, July 10, 2001 at 10:00 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 defme 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. tp 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 ATIORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 "~B,! - ~,.^ ,F f. ~ , , . ,~ ~ll,li'i"iiJ;;!Jt,";;",:k,...~Jti!."'tlid;;LRW>;N1fj!i."~!l;!~ih,"';:4i"_,"""__"'~;:_,1,'I,-i~-,~;;;_ii!,',~Mc1'''''~j;''''d'-'I1'f:!~b~~~i!!IIillIIl!l_l:i\l'~ 01 '(1M 1'0 V", '- Pil 3: L.2 C'/,,..-', UlvID$HLANO COUNTY PeNNSYlVANIA &/c2-tJ/ &d. ~ ~ ~ 4 +- ~./,;?-t?/ ~. ~~ z ~- d:Q0/ /~ ~ ~. ~~ ~ 1~'7._ ~_""."'_ ,~_'"" ,. .,.,".,~., H~ ,~_'""_, ,-,_",,", M', -' -' ". - ,,,' ,~ ,~--~,~ ,"' - "': if ii ., Ii' Ii !i , , li j, , r j 1;)1 '.11 - ~ . , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CYNTEITAS.GLOECKLER, Plaintiff * * * NO. 01 -3&P2 CI'o;L '7-~ vs. * CML ACTION - LAW COMPLAINT IN CUSTODY * T~OTHYE.GLOECKLE~ Defendant * * ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before the conciliator, at on the day of , 2-, at .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 defme 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 entIy of a temporary or pennanent 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 infonnation 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 TIDS 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 LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ..',' ,'. , -~ - ," "~oj - - - ~ : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CYNTHIA S. GLOECKLER, Plaintiff * NO. 0/- 3.3f3 ~ 'T~ * * vs. * CIVIL ACTION - LAW COMPLAINT IN CUSTODY TIMOTHY E. GLOECKLER, Defendant * * * COMPLAINT FOR CUSTODY AND COMES NOW,CYNTHIA S. GLOECKLER, by her attorney, Timothy J. Colgan, Esq., and files the following Petition: I. Plaintiff, CYNTHIA S. GLOECKLER, resides at 905 Knepper Drive, Mechanicsburg, Cumberland County, pennsylvania since December 1995. 2. Defendant, TIMOTHY E. GLOECKLER, resides at 2633 South 4th Street, Steelton, Dauphin County, Pennsylvania since May 24,2001. 3. Plaintiff and Defendant are the natural parents of one minor child, Megan V. Gloecker, D.O.B. 02/13/00. 4. The child was not born out of wedlock. 5. The child currently resides with the Plaintiff at 905 Knepper Drive, Mechanicsburg, Cumberland County, pennsylvania since her birth. / 6. There are no court orders establishing custody or visitation. 7. Plaintiff has no infonnation of a custody proceeding concerning the children pending in a court of this Commonwealth. 8. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 9. The best interest and permanent welfare of the children will be served by granting the relief requested herein. ~.,;~ ~ ,~, ".e,.,_... r_ '. - "-",..f' . " ,~- ~ . , . WHEREFORE, Plaintiff requests the Court enter an Order granting primary physical custody and shared legal custody of the minor child to Plaintiff. Dated: s- /2.-'> /0/ I I' C: ISERVER-lISERVERICLlENTSiCOLGAMGLOECKLEICUST.PET ';-;-,~--- ~ '[',"~--,,-,'-' ;< - -,~' .'""'r- ~,-, -~ ~~ , Respe~lIy sUbmitte. d, /0~ TimothyJ.Cog , q' - WILEY, LENOX, COLGAN & MARZZACCO, P.C. I South Baltimore Street DilIsburg,PA 17019 (717) 432-9666 I.D. #77944 . . VERIFICATION I, CYNTHIA S. GLOECKLER, verifY that the statements made in this document are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subjectto the penalties of18 Pa. e.s. 94904, relating to unsworn falsification to authorities. Date: 5/26JDI ~ Glt~% C HIAS.GLOECKLER Plaintiff C: ISERVER-lISERVERICLlENTSlCOLGAMGLOECKLEICUST.PET 1'-__ -~', ,,,- .-, '1"-- -,"'_ - 'JUt 11 20f1/1) CYNTHIA S. GLOECKLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : VOl. : NO. 01-3383 CIVIL TERM : : CIVIL ACTION - LAW TIMDrHY E. GLOECKLER, Defendant : : IN CUSTODY CIIDER OF COORT AND Nai, this 6th day of July, 2001, the Conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction in this case. The Custody Conciliation Conference scheduled for July 10, 2001 is canceled. ) FOR THE COURT, O~~JA---.d~ Dawn S. Sunday, Esquire Custody Conciliator ,'~'_'1' "~' C~~_'_~., 0_" ,,7;,1'-' ~ , ~'~,'" " " ',- ~, tS to II; I: Ii I' 1 Ii !' l1!lI!V _ ,,,,,.,, ~~"-4",,,,,, '~< ":' ~ Ji\W\-WL ~.> '.'"1 (' C s:~- -S~.' \~t ~~; ~;~~~'i~;~ '~~ C') ',-;;; ."-~ (," eO-, C~.~l .n ()' .,~l","_ "'c_: F:'WE"._$!~~'\!~~t"W~'ie'>.'i'V"1illllWl!IffiI~~_ G~~~~If~Mll1!~~[f~__1)._Ull1::~~~ .' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CYNTHIA S. GLOECKLER, Plaintiff * NO. 01-3383 VS. * * * * * CIVIL ACTION - LAW COMPLAINT IN CUSTODY TIMOTHY E. GLOECKLER, Defendant * ORDER ADOPTING STIPULATION OF THE PARTIES AND NOW, to wit, this 11' day of q..., , 2001, upon consideration of the foregoing Stipulation and on motion of Timothy J. Colgan, Esquire, counsel for Plaintiff, Cynthia S. Gloeckler, and Defendant, Timothy E. Gloeckler, pro se, it is hereby ORDERED, ADJUDGED and DECREED that the terms, conditions and provisions of the foregoing Stipulation are adopted as an Order of Court as if set forth herein at length. BY THE COURT: IJI ;1 . -fl) all L- i:01 (!.Xs , '.."..-~,~. ~ ''", -:: . ~'~~<I!mitm~!i&Iii\*,;'~I>;-.:r!~11iW0iI!li~j!i11~1i'15j~fOiJ"",n"f:'.l~'I;'OS;.''''-r;[Jj,,;j!!\i,il',''''''i>-'''t;!-o:;!r~;i ,-F","''''!. ri'~-""'-~ '~.."~ ".&If&.~ r'" d ' i." :':;1.: CUj\,',':, L~~ - ,~__ ~.'" ",'_~'~_= ~'.'~A "'-'~-~- ~, 'MM " .... ": '-: !) !! I: I" -- " y ../ ., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CYNTHIAS.GLOECKLE~ * NO. 01-3383 Plaintiff * * vs. * CIVIL ACTION - LAW * COMPLAINT IN CUSTODY TIMOTHY E. GLOECKLER, * Defendant * STIPULATION FOR CUSTODY TIDSSTIPULATION,ismadethis S-ftt day of Jvy ,2001, by and between Cynthia S. Gloeckler, (hereinafter referred to as "Mother") and Timothy E. Gloeckler, (hereinafter referred to as "Father"). WITNESSETH: WHEREAS, Mother and Father are the natural parents of one child, Megan V. Gloeckler, date of birth, 2/13/00; and WHEREAS, the parties now desire to resolve matters concerning the custody of the minor child. NOW THEREFORE, the parties hereto, intending to be legally bound, do hereby agree as follows: 1. SHARED LEGAL CUSTODY: The parties shall share legal custody of the minor child. Shared legal custody means the right of both parents to control and share in making decisions of importance in the life of their child, including educational, medical, and religious decisions. Both parents shall be entitled to equal access to the child's school, medical, dental and other important records. As soon as practical after receipt by a party, copies of the child's school schedules, special ,~~' 1""...""",." . ,'~ ~, -- -" , _' I" , " .. o.J' ~. events notifications, report cards, and similar notices shall be provided to the other party. Each party shall notifY the other of any medical, dental, optical, and other appointments of a child with health care providers, sufficiently in advance thereof so that the other party can attend. 2. PRIMARY PHYSICAL CUSTODY: Primary physical custody of the minor child, as that term is defmed in the Custody Act of 1985, October 30th, P.L. 264, No. 66, Section 1, 23 Pa. C.S.A. 5301, ~ shall be with Mother. 3. VISITATION: Father shall have rights of visitation at times mutually agreed by the parties. Visits shall take place in the home of Mother. Visits shall be supervised by Mother or an adult family member or friend of her choice. 4. TELEPHONE CALLS: Both parties are urged to use common sense in scheduling telephone calls to talk to the child. Both parties are hereby directed to refrain from preventing the parent who may be calling from talking to a child, or preventing the child from calling the other parent, provided that the phone calls are not excessively frequent nor too long in duration that they disrupt a child's schedule. Phone calls shall be kept to a maximwn of twenty minutes, and a maximwn of three (3) calls per week. 5. DISPARAGING REMARKS: Each of the parties and any third party in the presence of the child shall take all measures deemed advisable to foster a feeling of affection between the child and the other party. Neither party shall do nor shall either parent permit any third person to do or say anything which may estrange a child from the other parent, their spouse or relatives, or injure a child's opinion of the other party of which may hamper the free and natural development of a child's love and respect for the other parent. The parties shall not use a child to convey verbal messages to the other parent about the custody situation or changes in the custody schedule. ^~ ",~ ,.. "'1\ -, ,; " " 6. FINANCIAL CARE OF CHILD: In the event that a significant matter arises with respect to the medical care, education, or fmancial care of a child, such as a change in occupation, health insurance, educational expenses, or residence of a party, those matters shall be discussed with the other parent before any change is made by either parent. 7. MUTUAL CONSULTATION: Each party shall confer with the other on all matters of importance relating to the child's health, maintenance, and education with a view towards obtaining and following a harmonious policy in the child's education and social adjustments. Each party agrees to keep the other informed of his or her residence and telephone number to facilitate communication concerning the welfare of the child and visitation. Each party agrees to supply the name, address and phone numbers of any persons in whose care the child will be for a period in excess of seventy two hours, and for each person or entity which may provide day care for a child. 8. ILLNESS OF CHILDREN: Emergency decisions regarding the child shall be made by the parent then having custody. However, in the event of any emergency or serious illness of a child at any time, any party then having custody of a child shall immediately communicate with the other party by telephone or any other means practical, informing the other party of the nature of the illness or emergency, so the other parent can become involved in the decision making process as soon as practical. During such illness, each party shall have the right to visit the child as often as he or she desires, consistent with the proper medical care of the child. The term "serious illness" as used herein shall mean any disability which confines a child to bed in for a period in excess of seventy-two (72) hours and which places the child under the direction of a licensed physician. 9. WELFARE OF CHILDREN TO BE CONSIDERED: The welfare and ,""'" , "'J -,~ - ~ - -- convenience of the child shall be the prime consideration of the parties in any application of the provisions of this order. Both parents are directed to listen carefully and consider the wishes of the child in addressing the custodial schedule, any changes to the schedule, and any other parenting issues. 10. MODIFICATION OF ORDER: The parties are free to modify the terms of this order but in order to do so the Court makes it clear that both parties must be in complete agreement to any new terms. That means both parties must consent on what the new terms of the custody agreement or visitation schedule shall be. In the event that one or the other does not consent to a change, that does not mean each follows your own idea as to what you think the arrangements should be. The reason this Court Order is set out in detail is so both parties have it to refer to and to govern your relationship with the child and with each other in the event of a disagreement. 11. ENTRY AS COURT ORDER: The parties hereto acknowledge and agree that this Stipulation for Custody shall be entered as an Order of Court and shall supersede all prior Orders or Agreements previously entered into by the parties. IN WITNESS WHEREOF, the parties hereto, after full disclosure, intending to be legally bound, have signed, sealed and acknowledge this Stipulation. Signed, sealed and delivered in the presence of: WITNESS: 4~~ ~/h.~ / ~~ G{19OtJtJ/ TffiA S. GLOECKLER '~E~H ""%:~"j.4. '~-~->'~"--"-,,~~ ',-,.,< , ~ ~-