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GL LNN M, PLANK, ,R,
Plainti l'fs
Vs,
IN TI-IF COURT ON COMMON PLEAS
(,IIMBI-RLAN1) COUN'T'Y,
PENNSYLVANIA
BARBARA ANN 00(,11)1Z1C'l1, NO. ?Ij ?,?Sr , 1999
Defendant CIVII, M."PION-LAW
AND NOW, upon consideration 0I* (lie attached Complaint, it is hereby directed
Thal the parties and their respective counsel appear belore
the Conciliator, on ?? - { - -1 Y q
tic _. 1. day ofd
1999 at the office of Said conciliator located at
for a pre hearing custody conference. At such conlcrr nee, an effort will be made to
resolve the issues in dispute, or ifthis cannot be accomplished, to define and narrow
the issues to he heard by the Court, and to enter into a Tcmporary Order. failure to
appear at the conference may provide grounds for the entry of a temporary or
permanent order.
NOR THE COURT:
Custody Conciliator ?y?
YOU SHOULD TAKl3 TI IIS PAPER TO YOUR 1,AWYI3R
AT ONCF'. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TFI,EPHONE
THE OFFICI? SET FOR'l 11 13FL,OW TO FIND OUT
WI IFIRF YOU CAN (IF F LEGAL HELP,
Court Administrator
Cumberland County Court I-louse
One Court House Square
Carlisle, Pa. 17013
(717) 240-6200
GILENN M, PLANK, JR„
Plaintiff
vs.
BAR13ARA ANN GOODRICH,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUN'T'Y,
PENNSYLVANIA
No. V ,l • -f 6-0 1999
CUSTODY
COMPLAINT FOR SHARED t ' A AND
PARTIAL Cll TUDY
AND NOW, this J /' Day of',Ianuary, 1999, comes the Plaintiff,
Glenn M. Plank, Jr., by his attorney, Arthur K. Dils, Esquire, and respectfully requests
the following:
1. The Plaintiff is Glenn M. Plank, Jr., an adult individual who currently resides at
5836 Locust Lanc, Harrisburg, Dauphin County, Pennsylvania 17109,
2. The Defendant is Barbara Ann Goodrich, an adult individual, who currently
resides at 93 Hillside Circle, Camp I till, Cumberland County, Pennsylvania 17011,
3. Plaintiff and Defendant had one child born to them; namely:
Maxwell Otto Plank, having been bom September 2, 1993.
4. Plaintiff requests shared legal and partial custody of his son, Maxwell Otto Plank.
5. Plaintiff previously filed an action for custody in November of 1995 in the Court
of Common Pleas of York County, docketed to No. 95-S[J-05184-03, which was
discontinued on May 20, 1996 due to Plaintiff's inability at that time, to pursue the
matter,
6, Plaintiff has been seeing his son; however, the partial custody has not been on a
regular basis, and Plaintiff desires an Order of Court setting forth a partial custody
schedule.
7. 'rhe Court of Common Pleas of Cumberland County has jurisdiction in this matter
as the minor child and the Dcfendant have resided in ('timberland County since
February of 1997, and continue to reside in Cumberland County,
-2-
Wl-lrRFl' )RF,, plaintiff, Glenn M. Plank, Jr,, prays your Ilonorable
Court to grant him shared legal and partial custody of his son, Maxwell Otto Plank.
Respectfully submitted,
BY:
Arthur K. Dils, is-quire
1017 N. Front Street
Harrisburg, Pa. 17102
(717) 232-9724
I.D. No. 07056
,3.
VEUIFICATION t
L
1.
1 verify that the statements made in this COMPLAINT
are true and correct, I understand that false statements herein are made
subject to the penalties of 18 Pa, CS, Section 4904 relating to unsworn falsification
to authorities.
GLENN M. PLANK, R?
Date; DECEMDER 30, 1998
u1N?` ;31999, ? ,
GLENN M. PLANK, JR. ) IN THE: COURT OF COMMON PLEAS
Plaintiff ) OF CUMBERLAND COUNTY,
PENNSYLVANIA
VS. )
NO. 99-350 CIVIL 'PERM
BARBARA ANN GOODRICH, )
Defendant ) CIVIL ACTION - LAW
OEME
AND NOW, this _? . day of 1999,
upon review of the Conciliator's Report, it appearing that the
parties have agreed to the terms and, provisions of this interim
agreement which was dictated in their presence and approved by them
and their counsel., it is hereby ordered and directed as follows:
1. The custodial arrangement for the minor child, Maxwell
Otto Plank, is as follows:
A. Father shall have two (2) weekends a month in
accordance with the following schedule:
(l) For the first two visitation weekends on
Saturday from 12:00 p.m. to 4:00 p.m.,
(2) 'Cho following two visitation weekends on
Saturday from 10:00 a.m. to 6:00 p.m.; and
(3) For the following two weekends on both
Saturday and Sunday from 10:00 p.m. to 6:00
p.m.
In the event that any of these weekends
conflict with Father's reserve weekend, Father
shall have the option of picking another weekend to
make up that period of time lost to the reserves.
Father 'shall Drovi tie Mnt hu?r wIVV, fk- ...,...?_.._
schedule within seven (7) days of the date of this
Order and in addition, shall pick. the specific
weekends that will. make up for those weekends in
which he loses his time to the reserves,
H, Father will be providing all transportation. In
addition, Father understands that these periods of
visitation are for him and should not be spent with
any other day care provider,
2. The purpose of this Order is to reestablish a
relationship with the [Fattier and the son. The parties
recognize that it is important for the Father to follow
this schedule unless an emergency arises,
3. The parties shall reconvene for another custody
conci ation before Michael L, Hangs, Esquire, on
BY TIiF; COURTArthur K. Di.ls, Csquire
Attorney for Plaintiff
Marla Cognetti, Esquire wS 7`'.
Al-orney for Defendant
1999, at A m,
,,? /
ml b
i
GLENN M. PLANK, JR. ) IN THE COURT OF.' COMMON PLEAS
Plaintiff ) OF CUMBERLAND COUNTY,
PENNSYLVANIA
Vs. )
1 NO. 99-350 CIVIL TERM
BARBARA ANN GOODRICH, )
Defendant ) CIVIL ACTION - LAW
JUDGE PREVIOUSLY ASSIGNED: None.
CUSTODY CONCILIATION CONFEILW?d z 81MARY n PORT
'IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL, PROCEDURE
1915.3-8(b), Che undersigned Custody Conciliator submits the
following report:
1. The pertinent information concerning the child who is the
subject of this litigation is as follows:
t?9Nli: UIRTHDATE CURRENTLY IN
CUSTODY OE
Maxwell. Otto Plank September 2, 1.993 Defendant
2. A Conciliation Conference was held on March 25, 1999, and
the following Individuals were present: the Plaintiff and his
attorney, Arthur K. Dias, Esquire; the Defendant appeared with her
attorney, Maria CognetCa, Esquire.
3. Items resolved by agreement: See attached Order,
4. Issues yet to be resolved: See attached Order.
5. The Plaintiff's position on custody is as follows: See
attached Order.
6. The Defendant's position on custody is as follows: See
attached order.
7. Need for- separate counsel to represent child: Neither
party requested,
B, Need for independent psychological evaluation or
counseling: None requested and the Conciliator does not believe
any Is necessary,
Date: April 26, 19991.x+ C- }'c
Nmichael L, Bangs
Custody Concili or
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GLENN M. PLANK,, JR, ) IN THE COURT OF
Plaintiff ' COMMON PLEAS
) OF CUMBERLAND COUNTY,
vs. ) PENNSYLVANIA
1
BARBARA ANN GOODRICH, 1 NO 99-350 CIVIL TERM
Defendant 1
1 CIVII, ACTION - LAW
1 CUSTODY/VISITATION
QBQRB r
AND NOW, this
day of i- AT!7-- , 1999,
upon review of the conciliator's Report, it appearing that the
parties have agreed to the terms and provisions cf this Order which
was dictated in their presence and approved by them and their
counsel, it is hereby ordered and directed as follows:
1. The parties shall share legal custody of their minor
child, Maxwell Otto Plank, d.o.b. September 2, 1993,
2. Mother shall have primary physical custody of the minor
child, subject to periods of partial custody and
visitation with Father as follows:
A. On alternating weekends from Friday at 6:30 p.m.
until. Sunday at 6:30 p.m. This alternating weekend
shall commence with the weekend of July 9`°, except
that for the very first weekend, Father shall pick
up the child on July 10"' at 10:00 a am and have the
child until July 11 at_ 6:30 p.m, This schedule
shall alternate thereafter,
In the event that any of these weekends
conflict with Father's reserve weekend, Father
shall notify Mother. ghat a conflict is present and
Mother, shall be entitled to pick an alternate
weekend to make-up that lost time with Father,
Mother shall provide Father' with the make-up
weekend within seven (7) days of the lost weekend.
3, The parties shall alternate the major holidays. Those
holidays are being defined as 4"' of July, Labor Day,
Thanksgiving, Faster and Memorial Day. This alternating
schedule shall commence with Mother having the July 4"
in 1999 and the schedule shall alternate thereafter,
Those periods of time shall. be from 9:00 a.m. to 8:00
p.m.
4, Father shell be entitled to a period of time over.
Christmas with the child every year from December 26" at
10:00 a.m, until December 29" at. 6:30 p.m. Mother shall
have the reriainder of the Christmas holiday,
5, 1 Father shall have the child on Father's Day and Mother
shall have the child on Mother's Day. These periods of
time shall be from 9:00 a.m, uniji 8:00 p.m.
6, Feather shall be entitled to a week of vacation with the
child in 1.999, This week shall be from August I'll at
6:30 p.m. until August. W at 6:30 p,m, In the year
20001 Father shall be entitled to two (2) non-consecutive
weeks with the child, lie shall provide Mother with
thirty (30) days advance notice, In the year 2001 and
all summers thereafter, Father shall be entitled to one
(1) week In June, July and August, respectively, He
shall provide Mother with thirty (30) days advance notice
as to when ho intends to exercise these perlods of
vacation. These weeks shall. not run consecutively,
7. Both parents are enkitled to celebrate the birthday with
the ch.ld within a few days of his birthday, The party
who will not have custody of the child on his birthday
shall notify the other parent, within seven (7) days as to
what days he or she Intends to spend that birthday time
with the child. These periods shall be from 10:00 a,m,„ until 6:30 p.m. If Ills a non-school day, If It's a
school day, it: shall he from after school or after work
until 6:30 p.m.
s, The paternal grandmother may sharer an providing
transport.aticn with the father to offectUate this custody
schedule.
9: SuOh other times as the parties may agree,
BY THE COURT,;
"RY
EDGAR B. Arthur K. Dils, Esquire
Attorney for Plaintiff
Maria Cognetti, Esquire / .,d• dp.
Attorney for Defendant
mlb
GLENN M. PLANK, JR.
Pl.aInt.If f
VS.
BARBARA ANN GOODRICH,
Defendant
IN THIS COURT OF' COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 99-350 CIVIL TERM
CIVIL ACTION - LAW
CUSTODY /V I S I TAT I ON
JUDGE PREVIOUSLY ASSIGNED: The Honorable Edgar B. Bayley
CUSTODY CONCILIATION CONFF?A*+ 8(?$Y_R6 =
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the
following report:
1. The pertinent Information concerning the child who is the
subject of this litigation is as follows;
NA HL BIRTHDATE; CURRENTLY IN
?QDY OF
Maxwell. Otto Plank September. 2, 1993
2. A Conciliation Conference was held on July .l, 1999, and
the following individuals were present:: the Plaintiff and his
attorney, Arthur K. D:ils, Esquire; the Defendant appeared with tier
attorney, Maria Cognetti, Esquire.
3, Items resolved by agreement: See attached Order.
9. Issues yet to be resolved: See attached Order.
5. The Plaintiff's position on custody is as follows: See
attached Order.
6. The Defendant's position on custody is as fo:llgws: See
attached Order.
7. Need for separat::e counsel t.o represent child: Neither
party requested.
8. , Need for independent psychological evaluation or
counseling: None requested and the Conciliator does not believe
any is necessary,
Date: July 28, 1990,
&
THOMAS D. GOULD, ESQUIRE
2 EAST MAIN STREET
SHIREMANSTOWN, PA 17011
(717) 731-1461
GLENN M. PLANK, JR.,
Plaintiff
V.
BARBARA ANN GOODRICH,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999-0350 CIVIL TERM
CIVIL ACTION - LAW
CUSTODY ACTION
PETITION TO MODIFY CUSTODY ORDER
1. The Plaintiff/Petitioner is Glenn M. Plank, Jr.,
hereinafter referred to as Father, residing at 5836 Locust Lane,
Harrisburg, Dauphin County, Pennsylvania 17109.
2. The Defendant is Barbara Ann Goodrich, hereinafter
referred to as Mother, residing at 611 Shannon Road, Boiling
Springs, Cumberland County, Pennsylvania 17007.
3. Plaintiff and Defendant are the biological parents of
Maxwell Otto Plank, born September 2, 1993.
4. Father seeks to Modify the Order dated August 4, 1999, by
continuing to share joint legal custody and increasing his shared
physical custody time with Max and equalizing the transportation.
5. Father is requesting more vacation weeks, overnights
related to holidays, to be a part of decisions related to Max's
health education and general welfare, to be be informed by Max's
t
primary caretaker of significant events in Max's life and to be
allowed to claim Max as a dependent and his childcare expenses for
which Father is paying the majority of support and expenses.
6. Max's best interest will be served if Father's requests
are granted because:
A. Father will place the interest of Max before his own.
B. Father has the ability and desire to be a more
active parent in Max's life.
C. Max desires and needs his Father to be more active
in his life.
D. A more equal sharing of the parenting
responsibilities of Max will more equitably
distribute the benefits each parent can give and
Max can receive.
WHEREFORE, Father requests that this honorable court grant him
joint legal and increased periods of physical custody of Max with
a sharing of the transportation and a providing that Father may
claim Max as a dependant for his tax returns with a credit for
childcare expenses.
Respectfully submitted,
Thomas D. Gould, Esquire
ID #36508
2 East Main Street
Shiremanstown, PA 17011
(717) 731-1461
VERIFICATION
I. Glenn M. Plank, Jr., hereby certify that the foregoing
PETITION TO MODIFY CUSTODY ORDER is true and correct to the best of
my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
3 /11 //Q -7
DATED:
Glenn M. Plank, Jr.
3
GLENN M. PLANK, JR..
Plaintiff
vs.
BARBARA ANN GOODRICH,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
1
NO.-99-350 CIVIL TERM
CIVIL ACTION - LAW
CUSTODY/VISITATION
QRDER
AND NOW, this r ti day of 4A1-1X 1999,
upon review of the Conciliator's Report, it appearing that the
parties have agreed to thE? term,,3 and provisions of this Order which
was dictated in their presence and approved by them and their
counsel, it is hereby ordered zmd directed as follows:
1. The parties shall share legal custody of their minor
child, Maxwell Otto Flank, d.o.b. September 2, 1993.
2. Mother shall have primary physical custody of the minor
child, subject to periods of partial custody and
visitation with Father as follows:
A. On alternating weekends from Friday at 6:30 p.m.
until Sunday at 6:30 p.m. This alternating weekend
shall commence with the weekend of July 9t`', except
that for the very first weekend, Father shall pick
up the child on July 10' at 10:00 a.m. and have the
v.„ rte'
child until'July 11th at 6:30 p.m. This schedule
shall alternate thereafter.
In the event that any of these weekends
conflict with Father's reserve weekend, Father
shall notify Mother that a conflict is present and
Mother shall be entitled to pick an alternate
weekend to makeup that lost time with Father.
Mother shall provide Father with the make-up
weekend within seven (7) days of the lost weekend.
3. The parties shall alternate the major holidays. Those
holidays are being.defined as 4th of July, Labor Day,
Thanksgiving, Easter and Memorial Day. This alternating
schedule shall commence with Mother having the July 4th
in 1999 and the schedule shall alternate thereafter.
These periods of time shall be from 9:00 a.m. to 8:00
p.m.
4. Father shall be entitled to a period of time over
Christmas with the child every year from December 26th at
10:00 a.m. until December 29th at 6:30 p.m. Mother shall
have the remainder of the Christmas holiday.
5. Father shall have the child on Father's Day and Mother
shall have the child on Mother's Day. These periods of
time shall be from 9:00 a.m. until 8:00 p.m.
.. _ , ... ;.-.? .. , . ?_ :. .. ...:. . „_.: ?.. :.> -mac .
Father shall be entitled to a' week of vacation with'the
child in 1999. This week shall be from August 1st at
6:30 p.m. until August 8th at 6:30 p.m. In the year
2000, Father shall be entitled to two (2) non-consecutive
weeks with the child. He shall provide Mother with
thirty (30) days advance notice. In the year 2001 and
all summers thereafter, Father shall be entitled to one
(1) week in June, July and August, respectively. He
shall provide Mother with thirty (30) days advance--notice
as to when he intends to exercise these periods of
vacation. These weeks shall not run consecxtively.
7. Both parents are entitled to celebrate the birthday with
the child within a few days of his birthday. The party
who will not have custody of the child on his birthday
shall notify the other parent within seven (7) days as to
what day he or she intends to spend that birthday time
with the child. These periods shall be from 10:00 a.m.
until 6:30 p.m. if it's a non-school day. If it's a
school day, it shall be from after school or after work
until 6:30 p.m.
8. The paternal grandmother may share in providing
transportation with the Father to effectuate this custody
schedule.
z =
9 Such other times as`the parties may agree.
BY THE COURT,
EDGAR B. %AYLEY, J.
Arthur K. Dils, Esquire
y Attorney for Plaintiff
Maria Cognetti, Esquire -
Attorney for Defendant
mlb
T,RlJ-;:, C')py _n0M RECORD
and 1rJ? saa( o; - J nre ^tp set my hand
d Ccurt a- Carlisl'a Pa.
This ?f day of.... ..
I9. y.`l..
41
d? notary
v
f ? rlo
GLENN M. PLANK, JR. IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
99-0350 CIVIL ACTION LAW
BARBARA ANN GOODRICH
. IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Thursday, March 15, 2007 , 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, Mechanicsburg, PA 17055 on Wednesday, April 18, 2007 at 9:00 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 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: /s/ Dawn S. Sunda Es .
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 ATTORNEY 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
VNVAIASN13d
AiNno%
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1011M.-avull do
I -
APR 2 5 2007 Of
GLENN M. PLANK, JR.
Plaintiff
vs.
BARBARA ANN GOODRICH
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-0350 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this _ C:,o_ day of Av? 1 , 2007, upon
consideration of the attached Custody Conciliation Report, it i ordered and directed as follows:
1. The prior Order of this Court dated August 4, 1999, shall continue in effect as modified by
this Order.
2. Paragraph 3 of the August 4, 1999 Order shall be modified as follows pertaining to the
Easter and Thanksgiving holidays: the Easter holiday period of custody shall run from the Thursday
before Easter at 7:00 p.m. through Easter Sunday at 8:00 p.m. The Father shall have custody of the
Child for the Easter holiday in even-numbered years and the Mother shall have custody in odd-
numbered years. The Thanksgiving holiday period of custody shall run from the Wednesday before
Thanksgiving at 7:00 p.m. through the Monday following Thanksgiving at 8:00 p.m. The Father shall
have custody of the Child for Thanksgiving in even-numbered years and the Mother shall have custody
for the Thanksgiving holiday in odd-numbered years. In the event the Mother is not home to receive
custody of the Child at 8:00 on Monday evening following the Father's period of Thanksgiving
custody, the Father shall retain custody of the Child and transport the Child to school on Tuesday.
3. Paragraph 4 of the August 4, 1999 Order is vacated and replaced with the following
provision: In every year, the Mother shall have custody of the Child from Christmas Eve through
December 28 at 10:00 a.m. and the Father shall have custody from December 28 at 10:00 a.m. through
January 1 at 6:30 p.m.
4. In the event a party's period of regular/holiday custody falls within 12 hours of a subsequent
period of regular/holiday custody, the period of custody for that party shall run continuously without
interruption.
5. Paragraph 6 of the August 4, 1999 Order is vacated and replaced with the following
provision: During the summer school break each year, the Father shall have custody of the Child on an
alternating weekly basis beginning with the first Sunday after the end of the school year and ending
with the last Sunday preceding the first Monday in August. During this period, the parties shall
exchange custody of the Child every Sunday at 8:00 p.m. The school year custodial schedule shall
resume as of the first Monday in August or at the beginning of regular daily football practice,
whichever first occurs. The Father shall ensure that supervision is provided for the Child during any
extended periods while the Father is working. In the event the Father is unable to arrange for a
grandparent to provide care for the Child, the Father shall contact the Mother to offer the Mother the
opportunity to provide care for the Child during the Father's unavailability before contacting third
party caregivers. In the event the Mother is providing care for the Child during the Father's period of
custody under this provision, the Mother shall pick up the Child at the Father's residence or the
paternal grandmother's residence in the morning and the Father shall pick up the Child at the Mother's
residence after work. Both parties shall ensure that the Child is not left unsupervised for extended
periods during his or her periods of custody through the end of the 2007-2008 school year, whereupon
the parties shall review the need for continued supervision in light of the Child's maturity at the time
and shall cooperate in considering whether a modification to the ongoing need for supervision is
appropriate.
6. Unless otherwise agreed between the parties, the parent receiving custody of the Child shall
be responsible to provide transportation for the exchanges of custody during the school year, summer
and holidays. Each party shall be considerate in providing notice to the other party if he or she will be
late to pick up the Child due to unforeseen delays.
7. The Mother shall provide information to the Father on a timely basis concerning the Child's
activities which are not listed on the school website, notice of parent-teacher conferences, notice of
emergencies involving the Child or information as to any major developments regarding the Child's
social, educational or physical well being. The Mother shall also provide the Father with copies of the
Child's report cards on a timely basis.
8. The parties agree to further consider the possibility of initiating co-parenting counseling in
an effort to improve communications and reduce conflict to further the Child's emotional well being.
9. 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.
cc: Thomas D. Gould, Esquire - Counsel for Father
Richard S. Friedman, Esquire - Counsel for Mother
R L E D ? i F1°uE
OF THE P7`,Cl I ' `;Nf
?JT„rFY
2007 APR 30 AM 11: 52
GLENN M. PLANK, JR.
Plaintiff
VS.
BARBARA ANN GOODRICH
Defendant
Prior Judge: Edgar B. Bayley
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-0350 CIVIL ACTION LAW
IN CUSTODY
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 Child who is the subject of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Maxwell Otto Plank September 2, 1993 Mother
2. A custody conciliation conference was held on April 18, 2007 with the following
individuals in attendance: the Father, Glenn M. Plank, Jr., with his counsel, Thomas D. Gould, Esquire
and the Mother, Barbara Ann Goodrich, with her counsel, Richard S. Friedman, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Date Dawn S. Sunday, Esquire
Custody Conciliator
THOMAS D. GOULD, ESQUIRE
2 EAST MAIN STREET
SHIREMANSTOWN, PA 17011
(717) 731-1461
GLENN M. PLANK, JR.,
Plaintiff
V.
BARBARA ANN GOODRICH,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999 - 0350
IN LAW
CUSTODY
PETITION TO MODIFY CUSTODY ORDER
1. The Plaintiff/Petitioner is Glenn M. Plank, Jr.,
hereinafter referred to as Father, residing at 5836 Locust Lane,
Harrisburg, Dauphin County, Pennsylvania 17109.
2. The Defendant is Barbara Ann Goodrich, hereinafter
referred to as Mother, residing at 661 Shannon Road, Boiling
Springs, Cumberland County, Pennsylvania 17007.
3. Plaintiff and Defendant are the biological parents of
Maxwell O. Plank (Max), born September,2, 1993.
4. Father seeks to modify the Order dated April 30, 2007, by
granting him legal custody and primary physical custody with Mother
having period of partial custody as mutually agreed. A copy of the
Order is attached as exhibit A.
5. Father and Mother have agreed to a modification of their
April 30, 2007 Order. A copy of the Custody Agreement is attached
as exhibit B.
6. Max's best interest will be served if Father's request is
granted because:
A. Father will place Max's interests before his own.
B. Father_ has the ability and desire to be the primary
caretaker for Max.
C. Max desires and needs his Father's structure.
WHEREFORE, Father requests that this honorable court approve
the parent's Custody Agreement dated June 6, 2009 which gives
Father legal custody and primary physical custody of Max, subject
to Mother's period of partial custody as mutually agreed.
Respectfully submitted,
D. '?J?
Thomas D. Gould, Esquire
ID #36508
2 East Main Street
Shiremanstown, PA 17011
(717) 731-1461
VERIFICATION
I, Glenn M. Plank, Jr., hereby certify that the foregoing
PETITION TO MODIFY CUSTODY ORDER is true and correct to the best of
my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
DATED: (/n /O / to 4X4
Glenn M. Plank, Jr.
3
APR 8 b 2007 W
GLENN M. PLANK, JR.
Plaintiff
vs.
BARBARA ANN GOODRICH
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-0350 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 3D day of ( , 2007, upon
consideration of the attached Custody Conciliation eport, it is ordered and directed as follows:
The prior Order of this Court dated August 4, 1999, shall continue in effect as modified by
this Order.
2. Paragraph 3 of the August 4, 1999 Order shall be modified as follows pertaining to the
Easter and Thanksgiving holidays: the Easter holiday period of custody shall run from the Thursday
before Easter at 7:00 p.m. through Easter Sunday at 8:00 p.m. The Father shall have custody of the
Child for the Easter holiday in even-numbered years and the Mother shall have custody in odd-
numbered years. The Thanksgiving holiday period of custody shall run from the Wednesday before
Thanksgiving at 7:00 p.m. through the Monday following Thanksgiving at 8:00 p.m. The Father shall
have custody of the Child for Thanksgiving in even-numbered years and the Mother shall have custody
for the Thanksgiving holiday in odd-numbered years. In the event the Mother is not home to receive
custody of the Child at 8:00 on Monday evening following the Father's period of Thanksgiving
custody, the Father shall retain custody of the Child and transport the Child to school on Tuesday.
3. Paragraph 4 of the August 4, 1999 Order is vacated and replaced with the following
provision: In every year, the Mother shall have custody of the Child from Christmas Eve through
December 28 at 10:00 a.m. and the Father shall have custody from December 28 at 10:00 a.m. through
January 1 at 6:30 p.m.
4. In the event a party's period of regular/holiday custody falls within 12 hours of a subsequent
period of regular/holiday custody, the period of custody for that party shall run continuously without
interruption.
5. Paragraph 6 of the August 4, 1999 Order is vacated and replaced with the following
provision: During the summer school break each year, the Father shall have custody of the Child on an
alternating weekly basis beginning with the first Sunday after the end of the school year and ending
with the last Sunday preceding the first Monday in August. During this period, the parties shall
exchange custody of the Child every Sunday at 8:00 p.m. The school year custodial schedule shall
resume as of the first Monday in August or at the beginning of regular daily football practice,
EXHIBIT A
whichever first occurs. The Father shall ensure that supervision is provided for the Child during any
extended periods while the Father is working. In the event the Father is unable to arrange for a
grandparent to provide care for the Child, the Father shall contact the Mother to offer the Mother the
opportunity to provide care for the Child during the Father's unavailability before contacting third
party caregivers. In the event the Mother is providing care for the Child during the Father's period of
custody under this provision, the Mother shall pick up the Child at the Father's residence or the
paternal grandmother's residence in the morning and the Father shall pick up the Child at the Mother's
residence after work. Both parties shall ensure that the Child is not left unsupervised for extended
periods during his or her periods of custody through the end of the 2007-2008 school year, whereupon
the parties shall review the need for continued supervision in light of the Child's maturity at the time
and shall cooperate in considering whether a modification to the ongoing need for supervision is
appropriate.
6. Unless otherwise agreed between the parties, the parent receiving custody of the Child shall
be responsible to provide transportation for the exchanges of custody during the school year, summer
and holidays. Each party shall be considerate in providing notice to the other party if he or she will be
late to pick up the Child due to unforeseen delays.
7. The Mother shall provide information to the Father on a timely basis concerning the Child's
activities which are not listed on the school website, notice of parent-teacher conferences, notice of
emergencies involving the Child or information as to any major developments regarding the Child's
social, educational or physical well being. The Mother shall also provide the Father with copies of the
Child's report cards on a timely basis.
8. The parties agree to further consider the possibility of initiating co-parenting counseling in
an effort to improve communications and reduce conflict to further the Child's emotional well being.
9. 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,
Edg ra ayley
cc: Thomas D. Gould, Esquire - Counsel for Father
Richard S. Friedman, Esquire - Counsel for Mother
HUE COPY FROM RECORD
Te0mi WtteW, ! here wde set any haoc
,A the sag of Said Court at Q d W. Pa.
?*ntfin?rR?f d
. i
GLENN M. PLANK, JR.,
Plaintiff
V.
BARBARA ANN GOODRICH,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999 - 0350
IN LAW
CUSTODY
CUSTODY AGREEMENT
THIS AGREEMENT, made this day of Tr ne , 2009, by
and between BARBARA ANN GOODRICH, hereinafter referred to as
Mother, and GLENN M. PLANK, JR., hereinafter referred to as Father.
WITNESSETH:
WHEREAS, Mother and Father are the parents of MAXWELL OTTO
PLANK, born September 2, 1993, hereinafter referred to as Max; and
WHEREAS, Mother and Father wish to enter into this Custody
Agreement to settle and resolve the outstanding issues regarding
the custody of Max;
NOW THEREFORE, it is agreed by the parties that:
1. Father shall have legal custody of Max. Each parent
shall have equal access to the Max's personal, school and medical
records and each parent is to inform the other of significant
events that occur in Max's life.
EXHIBIT B
2. Father shall have primary physical custody of Max subject
to Mother's periods of partial custody as the parties may agree.
3. This Agreement may be modified in the best interest of
Max by mutual agreement of the parties.
4. Each party is to inform the other of any change in
employment, residence and/or telephone number.
5. This Agreement shall supersede any and all other Orders,
Agreements or Stipulations concerning the custody of Max and is to
be entered as an Order of Court.
DATE BARBARA ANN GOODRICH
6AZoo`} )e aw,
DATE GLENN M. PLANK, JR.
2
Commonwealth of Pennsylvania:
ss
County of
PERSONALLY APPEARED BEFORE ME, this G day of :?U n e,' ,
2009, a notary public, in and for the Commonwealth of Pennsylvania,
BARBARA ANN GOODRICH, known to me (or satisfactorily proven to be)
the person whose name is subscribed to the within custody agreement
and acknowledged that she executed the same for the purposes herein
contained.
Notary Public.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Heather Plumley, Notary Public
Camp Hill Boro, Cumberland County
My Commission F=h,&& Jan. 23, 2013
Member, Pennsylvania Association of Notaries
Commonwealth of Pennsylvania:
ss
County of ,
PERSONALLY APPEARED BEFORE ME, this 6 day of furl Pi ,
2009, a notary public, in and for the Commonwealth of Pennsylvania,
GLENN M. PLANK, JR., known to me (or satisfactorily proven to be)
the person whose name is subscribed to the within custody agreement
and acknowledged that he executed the same for the purposes herein
contained.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Heather Plumley, Notary Public
Camp Hill Boro, Cumberland County
My Commission Ezppas Jan. 23, 2013
Member, Pennsylvania Association of Notaries
3
elf
Atff
JUN 15 2009 (,7
GLENN M. PLANK, JR., IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 1999 - 0350
BARBARA ANN GOODRICH, IN LAW
Defendant CUSTODY
ORDER OF COURT
AND NOW this h day of 2009, the terms
and conditions of the attached CUSTODY AGREEMENT dated June 6,
2009, is hereby incorporated and made an Order of this Honorable
Court.
UlbTRIBU11UN :
? THOMAS D. GOULD, ESQ., 2 EAST MAIN STREET. SHIREMANSTOWN, PA 17011
/RICHARD S. FRIEDMArN, ESQ., 300 N. 2ND ST, STE 402, HARRISBURG, PA 17101
i/4' l0?
iflrl
-, ;
FILED-1 '
2009 JUN {6 Aii 9. 0 d