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HomeMy WebLinkAbout99-03680 (2)?y h 3 t ft ,y 9 I RECEIVED APR 12100 GLENWOOD BROWN, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW LAURA J. WRIGHT (LAWRENCE), : NO. 99-3680 Defendant : IN CUSTODY COURT ORDER AND NOW, this 13 day of April, 2005, upon consideration of the attached Custody Conciliation report, it is ordered that this Court's Order of January 3, 2005 is vacated and replaced with the following Order: 1. The mother, Laura J. Lawrence, shall enjoy legal and physical custody of Chris Junior Brown, born November 21, 1998. 2. The mother shall endeavor to continue to have the child remain in contact with the paternal grandfather, Glenwood Brown, Sr., subject to his availability with respect to his medical condition. The mother shall have an obligation to transport the child back to the Carlisle area a reasonable amount of times in order to accomplish this contact. 3. The father, Glenwood Brown, Jr., shall enjoy periods of temporary custody with the minor child when he is released from prison, these periods of custody to be arranged between the parties. In the event the parties cannot agree upon an arrangement, Mr. Brown may Petition the Court to have the case again scheduled before the Custody Conciliator. c%eaaura J. Lawrence enwood Brown, Jr. enwood Brown, Sr. 1 f erald S. Robinson, Esquire j,Rbbert L. O'Brien, Esquire ,,Mt. and Mrs. Wayne E. Wrig t / (b b1.14 BY THE COURT, .,. FIB ?-?• : ,?. 275 ?4 ? 13 Cil ?:: 03 ;? ;u;? C;?;, ' ,t,'?::,?^, •r GLENWOOD BROWN, JR., Plaintiff v LAURA J. WRIGHT (LAWRENCE), Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 99-3680 : IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Chris Junior Brown, born November 21, 1998. 2. A Conciliation Conference was held on April 7, 2005, with the following individuals in attendance: Maternal grandparents, Wayne E. Wright and Joanne E. Wright, and the mother, Laura J. Lawrence, along with Attorney Gerald S. Robinson, Esquire who represented the maternal grandparents and the mother. The father, Glenwood Brown, Jr., was not in attendance. However, it is understood that he is incarcerated and he had sent a letter to the Court requesting the ability to attend the Custody Conciliation Conference. It is also noted that the paternal grandfather, Glenwood Brown, Sr., was not in attendance, nor was his attorney, Robert L. O'Brien, who had represented the paternal grandfather at the prior January 3, 2005 proceedings. 3. The information presented to the Conciliator at the Conciliation Conference was that the minor child resided with the mother from birth in 1998 to June of 2004. She then indicates that there were some proceedings in the Cumberland County whereby the paternal grandfather was granted custody of the child, but she is unaware as to exactly what happened because she claims she was never served within any type of Order nor did she appear at any hearing. She was advised via phone from a County Official in Cumberland County that a Court Order was entered giving the paternal grandfather custody. She then delivered the child to the paternal grandfather at that point. The child apparently then lived with the paternal grandfather from June of 2004 until January of 2005 at which time there was a hearing on petition of the maternal grandparents to get custody of the minor child. As the Conciliator understands the situation, the paternal grandfather at that time was in a nursing home and the child was being cared for by a neighbor. After a hearing, Judge Oler gave the maternal grandparents primary custody and gave the father alternating weekend custody and the paternal grandfather custody at such times as would be worked out between the parties. The maternal grandparents relate that they have taken the minor child over to visit the paternal grandfather a few times since early January. They indicate that the paternal grandfather has been released from the nursing home but is currently living at home under hospice care and that his health situation is still poor. The maternal grandparents also represent that the father exercised one weekend of custody with the minor child since January, and that he did not initiate any other periods of custody. The information the maternal grandparents and the mother have is that the father is now incarcerated, but they do not have any information with respect to the reason of incarceration or the anticipated length. 4. The maternal grandparents desire to give custody of the minor child to the mother. The mother lives in New Kensington, Pennsylvania and she resides with her husband (she was married November 2004) and three children, an older stepson, her own natural son who is age six and her newborn infant who is three months old. Mother's current spouse is a chef at a restaurant in the Pittsburgh area. 5. In light of the fact that the mother exercised custody of the minor child for almost 90 percent of the child's life and the other circumstances outlined above, the Conciliator recommends that the mother be given primary custody of the minor child subject, however, to any party retaining the opportunity to request an expedited Conciliation Conference in a effort to modify this Order. DATE Hubert X. Gilroy, Esquire Custody Conciliator ?/ J? V GLENWOOD BROWN, JR., Plaintiff V. LAURA J. WRIGHT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3680 CIVIL TERM IN RE: PETITION FOR EMERGENCY CUSTODY RELIEF FILED BY MATERNAL GRANDPARENTS BEFORE OLER, J. ORDER OF COURT AND NOW, this 3`d day of January, 2005, upon consideration of the "Petition for Emergency Relief Custody" filed by Joanne E. Wright and Wayne E. Wright with respect to their grandson, Chris Junior Brown (d.o.b. November 21, 2004), and following a hearing held on January 3, 2004, at which (a) the paternal grandfather, Glenwood Brown, Sr., who is the current custodian of the child was not present due to a medical condition but was represented by Robert L. O'Brien, Esq., (b) the father, Glenwood Brown, Jr., was present pro se, (c) the mother, Laura J. (Wright) Lawrence, was not present, and (d) the maternal grandparents, Joanne E. Wright and Wayne E. Wright, petitioners, were present pro se, it is ordered and directed, pending further order of court, as follows: 1. Legal custody of the child shall be in the maternal grandparents, Joanne E. Wright and Wayne E. Wright; 2. Primary physical custody of the child shall be in the maternal grandparents, Joanne E. Wright and Wayne E. Wright; 3. Temporary or partial physical custody of the child shall be in the father, Glenwood Brown, Jr., on alternating weekends, from Friday at 6:00 p.m. until Sunday at 6:00 p.m. 4. Temporary or partial physical custody of the child shall be in the mother, Laura Wright, at such times as the parties all mutually agree; FiLI;-Gr Z?,.J alt., ""jI ? 11 f.• L C!?! I I \f 5. Temporary or partial physical custody of the child shall be in the paternal grandfather, Glenwood Brown, Sr., at such times as the parties all mutually agree; 6. Transportation with respect to custody exchanges shall be the responsibility of the party receiving custody; 7. Nothing herein is intended to preclude the parties from deviating from the terms of this order by mutual agreement; and 8. Upon petition of any party based upon a change of circumstances, including the return home of the paternal grandfather from a nursing home or the resolution of pending criminal charges against the father, the court will review the terms of this custody order. BY THE COURT, J Glenwood Brown, Jr. 2122 Douglas Drive Carlisle, PA 17013 Plaintiff, pro se Laura J. (Wright) Lawrence 1113 Fifth Avenue, # 305 New Kensington, PA 15068 Defendant, pro se Wayne E. and Joanne E. Wright 1890 Town Hill Road York Springs, PA 17372 Petitioners/intervenors ?? O y Robert O'Brien, Esq. 17 West South Street Carlisle, PA 17013-2899 Attorney for Glenwood Brown, Sr. Courtesy Copy: Martha Vangorder 132 Andre Court Burlington, NJ 08016 :rc M F ?ep GLENWOOD BROWN, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW 99-3680 CIVIL TERM LAURA J. WRIGHT, Defendant IN CUSTODY IN RE: PETITION FOR EMERGENCY RELIEF ORDER OF COURT AND NOW, this 21st day of June, 2009, upon consideration of the Petition for Emergency Relief filed on behalf of Glenwood Brown, Sr., with respect to his grandson, Chris Junior Brown (date of birth November 21, 1998), and following a hearing at which neither Glenwood Brown, Jr., the child's father, nor Laura J. Wright, the child's mother, appeared, it is ordered and directed as follows: 1. Legal custody of the child shall be in the Petitioner, Glenwood Brown, Sr. 2. Primary physical custody of the child shall be in the Petitioner, Glenwood Brown, Sr., and temporary partial physical custody of the child shall be in Glenwood Brown, Jr., and Laura J. Wright at such times as Petitioner, Plaintiff, and Defendant agree upon. 3. The Court will hold a prompt hearing to consider the continuation, modification or termination of this order at the request of Petitioner, Plaintiff, or Defendant. j1 ) (V ?J 4. Pending further order of the Court, the terms of this temporary order shall remain in full force and effect. By the Court, J. Wesley Oler r., J. L Robert O'Brien, Esquire 17 West South Street Carlisle, PA 17013-2899 For Glenwood Brown, Sr., the Petitioner Glenwood Brown, Jr. C/o Martha Vangorder 251 West Dekalv Pike C-308 King of Prussia, PA 19406 Laura J. Wright C/o Wayne and Joanne Wright 1890 Town Hill Road York Springs, PA 17372 :mae IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3680 CIVIL TERM ORDER OF COURT for Emergency Relief Custody, a hearing is scheduled for Monday, January 3, 2005, at AND NOW, this 20`h day of December, 2004, upon consideration of the Petition 9:30 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania, GLENWOOD BROWN, JR., Plaintiff V. LAURA J. WRIGHT, Defendant BY THE COURT, Xlenwood Brown, Jr. c/o Martha Vangorder 251 West Dekalv Pike C-308 King of Prussia, PA 17372 Plaintiff, pro se ,Glenwood Brown, Jr. (BOf-) Cumberland County Prison /aura J. Wright c/o Wayne and Joanne Wright 1890 Town Hill Road York Springs, PA 17372 Defendant, pro se ,Wayne and Joanne Wright 1890 Town Hill Road York Springs, PA 17372 i .1 esley Olee'-'h-., 1. 7 12 -a i -o ?l vl .1 Xbert O'Brien, Esq. 17 West South Street Carlisle, PA 17013-2899 Attorney for Glenwood Brown, Sr. :rc DEC 1 5 2004 V LAURA J. WRIGHT, Defendant IN CUSTODY GLENWOOD BROWN, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff: CUMBERLAND COUNTY, PENNSYLVANIA V CIVIL ACTION -LAW 99-3680 CIVIL TERM IN RE: PETITION FOR EMERGENCY RELIEF CUSTODY ORDER OF COURT AND NOW, this 15th day of December, 2004, upon consideration of the Petition for Emergency Relief Custody filed on behalf of Joanne Wright and Wayne Wright, with respect to grandson, Chris Junior Brown it is ordered and directed as follows: Emergency Relief Custody shall be in the Petitioners, Joanne Wright and Wayne Wright. By the Corm, J. Wesley Oler, Jr., J. Ilo?` GLENWOOD BROWN, JR., IN THE COURT OF COMMON PLEAS OF Plantiff CUMBERLAND COUNTY, PENNSYLVANIA V CIVIL ACTION - LAW 99-3680 CIVIL TERM LAURA J. WRIGHT, Defendant IN CUSTODY RE: PETITION FOR EMERGENCY RELIEF CUSTODY And now this 15' day of December, 2004 we Joanne E. Wright and Wayne E. Wright being the grandparents of Chris Junior Brown petition the court for emergency relief custody of said grandson. We request this petition for the following reasons: 1. Glenwood Brown Sr. who now has legal custody and primary physical custody is in ill health and has been admitted to the Carlisle Hospital. 2. Glenwood Brown Sr. is not capable to care for Chris Junior Brown and meet his every day needs. 3. Glenwood Brown Sr. is not capable to insure that Chris Junior Brown gets to Kindergarten on a daily basis. ?UU Wayne E. Wright Joanne E. Wright CC: Robert O'Brien, Esquire 17 West South Street Carlisle, Pa. 17013-2899 For Glenwood Brown, Sr. Glenwood Brown, Jr. C/o Martha Vangorder 251 West Dekalv Pike C-308 King of Prussia, Pa. 17372 Laura J. Wright C/o Wayne and Joanne Wright 1890 Town Hill Rd York Springs, Pa. 17372 Wayne and Joanne Wright 1890 Town Hill Rd York Springs, Pa. 17372 L(. `_' a GLENWOOD BROWN, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW LAURA J. WRIGHT, Defendant NO. 99-3680 CIVIL TERM ORDER OF COURT AND NOW, this 3rd day of January, 2005, pursuant to an agreement of the parries or their representatives present in court in the person of Glenwood Brown, Jr., Plaintiff, and Robert O'Brien, Esquire, on behalf of Glenwood Brown, Sr., Wayne and Joanne Wright, the maternal grandparents of the child at issue in this case, are hereby permitted to intervene. By the Court, Glenwood Brown, Jr., Plaintif pro se 2122 Douglas Drive Carlisle, PA 17013 Wayne and Joanne Wright 1890 Town Hill Road York Springs, PA 17372 Petitioners/Intervenors Laura J. Wright, Defendant 1113 Fifth Avenue, 305 New Kensington, PA 15068 Robert O'Brien, Esquire 17 W. South Street Carlisle, PA 17013-2899 Attn. For Glenwood Brown, Sr. Courtesy copy: Martha Vangorder 132 Andre Court Burlington, New Jersey 08016 i J W sley 0 1 Jr., Pcb ? J GLENWOOD BROWN, JR. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION - LAW NO. 99-34PO CIVIL TERM LAURA J. WRIGHT Defendant IN CUSTODY ORDER OF COURT AND NOW THIS d( day of 1999, upon consideration of the attached complain t is hereby directed that the parties and their respective counsel appear before Hubert X Gilroy Esquire, the conciliator, at iury assembly room on the 2nd day of July 1999 at 9:30 A.M., fora 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 BY THE COURT, BY b? Custody Conciliator 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 ? a?- 9? ? ?? ? ? ?? G ?n w! U. fi s' v J ? x 41 T Q h Z Y J C] ? L z 3 ut _ C c? ? V O r i GLENWOOD BROWN, JR. Plaintiff Vs. LAURA J. WRIGHT Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.d92 2466 CIVIL TERM 9?. .J(; By IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Glenwood Brown, Jr., an adult individual, currently residing at 2122 Douglas Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Laura J. Wright, an adult individual, currently residing in Dauphin County, Pennsylvania. 3. Plaintiff seeks custody of the following child : Chris Junior Brown, age 7 months, born 11/21/98. The child was born out of wedlock. The child is presently in the shared custody of the parties as set forth in the attached custody order. The natural mother of the child is Laura J. Wright. She is single. The natural father of the child is Glenwood Brown, Jr. He is single. 4. The relationship of the Plaintiff to the child is that of natural father. The plaintiff currently resides with the following persons: Glenwood Brown, Sr. 5. The relationship of the Defendant to child is that of natural mother. 6. Plaintiff has participated as a party concerning the custody of the child in the Court in Dauphin County resulting in a temporary Order. The Defendant mother consents to the venue of the matter being in Cumberland County. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: The father's home had been the primary residence of the child since birth until the mother suddenly left the home with the child. The mother is an immature individual who is unable to manage her affairs and those of her child. The father's home can provide the stability and environment necessary for the raising of a child. The father has the support of his family in caring for the child and is employed in his home and will be available to care for the child on a regular basis. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene. NAME ADDRESS BASIS OF CLAIM None WHEREFORE, Plaintiff requests your Honorable Court to: A) grant primary custody of the child to the plaintiff; B) grant such other relief as is just and in the best interest of the child. Respectfully submitted, Robert L. O'Brien, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 Date:6 (717) 249-6873 I verify that the statements made in the foregoing Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Ayz-?O? GLENWOOD'BROWN, JR. DATE: G L'C ?/e/J 8/Du» s/a7199 LAURA J. WRIGHT IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA V. GLENWOOD BROWN, JR. No. 1978 S 1999 TEMPORARY CUSTODY ORDER AND NOW, this 19th day of May, 1999, upon consideration of the testimony, the Court grants primary physical custody of the minor child, Chris J. Brown, to Laura J. Wright, subject to the father's, Glenwood Brown, Jr., partial custody rights through supervised visits as follows: 1. The Defendant shall exercise supervised visits at the YWCA shelter at times and dates as the parties mutually agree. Those visits shall take place for two occasions. Thereafter, at dates and times as the parties mutually agree, the supervised visits may take place at the home of the Defendant's father, Glenwood Brown, Sr. The visits at the father's residence shall be supervised at all times by the Defendant's father. This is a temporary order subject to modification by I further Order of Court. (x' 1wx^ v'.•:: c..N), ?tg,, .?,,. LAURA J. WRIGHT, Plaintiff V. GLENWOOD BROWN, JR., Defendant IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA NO. S1999-1978 CIVIL TERM CIVIL ACTION-LAW IN CUSTODY CONSENT TO CHANGE IN VENUE Randi D. Blackman, Esquire is the counsel of record for the Plaintiff, Laura J. Wright, in the above captioned matter. On behalf of her client, Laura J. Wright, the undersigned Randi D. Blackman agrees to the change in venue requested by the Defendant. 13Ia? /t 213-A North Front Street Harrisburg, PA 17101 JUL - 7 199?? GLENWOOD BROWN, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LAURA J. WRIGHT, NO. 99-3680 CIVIL Defendant IN CUSTODY COURT ORDER AND NOW, this o V day of July, 1999, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: L The Father, Glenwood Brown, Jr., and the Mother, Laura J. Wright, shall enjoy shared legal custody of Chris Junior Brown, born November 21, 1998. 2. The parties shall share equally physical custody of the minor child. The times for exchange of custody for this schedule shall be worked out between the parties. 3. Both parties have the right to have an extended period of time with the minor child under the custody schedule for a period of up to 4 weeks in the event either party desires to make arrangements to take the child to their parents or other relatives. 4. The parties shall share or alternate holidays as they may agree. 5. The Father shall always have custody on Father's Day and the Mother shall always have custody on Mother's Day. 6. This order may be modified by agreement of the parties. Absent any agreement. this order shall control unless either party would petition the court to have the order modified. BY THE COURT, cc: Robert L. O'Brien, Esq. Laura J. Wright - ?' ,?d•1P. FLEA-OrF;rE GF Tp{c rr?'.;?,6?T,RY 99 JUL -9 Ah 9: 47 CLti1EEr' !Li COUi\rry FENNsm,A ,R GLENWOOD BROWN, JR., Plaintiff v LAURA J. WRIGHT, Defendant Prior Judge: M THE, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3680 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Chris Junior Brown, born November 21, 1998. 2. A Conciliation Conference was held on July 2, 1999, with the following individuals in attendance: The Father, Glenwood Brown, Jr., with his counsel, Robert L. O'Brien, Esquire; and the Mother, Laura J. Wright, without counsel but was willing to proceed without an attorney. 3. The parties have reconciled. However, to ensure that there are no problems in the event of any future separation, the parties agree to a custody order in the form as attached. 9P l a VJ ATE Hubert X. Gilr , Esquire Custody Co diator GLENWOOD BROWN, JR. Petitioner/Plaintiff vs. LAURA J. WRIGHT Respondent/Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-gerSOCIVIL TERM IN CUSTODY ;l AND NOW THIS(?'h day of 1n ,; Ai L% , 1999, upon review of the attached Petition filed by Robert L. O'Brien, Esquire, attorney for Petitioner, Glenwood Brown, Jr., a Rule is issued upon Respodent Laura J. Wright, to show cause why said relief should not be granted. SAID RULE-TO-SHOW-CAUSE returnable at hearing set for the day of A [ren mac. 1999, at 7 r A.M./P-. -, in Courtroom #--L, Cumberland County Courthouse, Carlisle, PA., 17013. BY THE COURT, J t9 P,i Fir r, GLENWOOD BROWN, JR. IN THE COURT OF COMMON PLEAS OF Petitioner/Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 99-3i,,80 CIVIL TERM LAURA J. WR)GHT Respondent/Defendant IN CUSTODY ?e'r3 PETITION FOR-@QNT€A4F_T- 'S 1' l !? L r2? LI E F 1. Petitioner is Glenwood Brown, Jr., Plaintiff in the above-captioned action. 2. Respondent is Laura J. Wright, Defendant in the above-captioned action. 3. On July 8, 1999, a Court Order was issued in regard to the custody of the parties child, Chris Junior Brown. A copy of said Order is attached hereto as Exhibit "A" and incorporated herein by reference. 4. On or about November 21, 1999, Respondent removed the child from the parties home. Subsequent to that time, she has said that she will not permit the father to have his times of shared custody with their son. 5. The father has sought the assistance of the Pennsylvania State Police in having the child returned and the State Police are unable to assist him. 6. Respondent has failed to communicate her whereabouts and Petitioner believes that she may be with her parents, Mr. and Mrs. Wayne Wright, 26 Church Road, Newport, Pennsylvania or her brother, Anthony Wright, RD 1 Box , Blaine, Pennsylvania. WHEREFORE, Petitioner respectfully requests that the Court issue a Rule to show cause in reference to the shared custody of Chris Junior Brown, and that the Court: a. find that Respondent is in contempt of the Court Order of July 8, 1999. b. the Court order and direct that Laura J. Wright pay reasonable attorney's fees to the father in reference to her violation of the custody order. C. the Court order primary physical custody of Chris Junior Brown to the father. d. the Court enter such other relief as is just and equitable. Respectfully submitted, O'BRIEN, BARIC & SCHERER t By:? A Robert L. O' rien, Esquire Attorney for Petitioner/Plaintiff I. D. # 28351 17 West South Street Carlisle, Pennsylvania 17013 robfdomeetldbro .petltlon verify that the statements made in the foregoing Petition are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 49174, relating to unsworn falsification to authories. GLENWOOD ROWN, JR. Ck° . JUL - 7 199?J GLENWOOD BROWN, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW LAURA J. WRIGHT, NO.99-3680 CIVIL . Defendant IN CUSTODY COURT ORDER AND NOW, this g;d- day of July, 1999, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1, The Father, Glenwood Brown, Jr., and the Mother, Laura J. Wright, shall enjoy shared legal custody of Chris Junior Brown, bom November 21, 1998. 2. The parties shall share equally physical custody of the minor child. The times for exchange of custody for this schedule shall be worked out between the parties. 3. Both parties have the right to have an extended period of time with the minor child under the custody schedule for a period of up to 4 weeks in the event either party desires to make arrangements to take the child to their parents or other relatives. 4. The parties shall share or alternate holidays as they may agree. 5, The Father shall always have custody on Father's Day and the Mother shall always have custody on Mother's Day. t any eement this 6. This order may be modified by agreement of the parties. thebconurt to have the o d r order shall control unless either party would petition modified. BY THE COURT, cc: Robert L. O'Brien, Esq. Laura J. Wright TRUr COPY FROM RECORD In Lsi rn .?`. I h--r- unto sat my hand and the saa: of s3 J Court at Carlish, Pa. This _.q'a....day of..._..., 19.9q ' cL.....?e.- k. Prothonotary EXHIBIT "A" GLENWOOD BROWN, JR., Plaintiff LAURA J. WRIGHT, Defendant Prior Judge: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3680 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the child who is the subject of this litigation is as follows: Chris Junior Brown, bom November 21, 1998. 2. A Conciliation Conference was held on July 2, 1999, with the following individuals in attendance: The Father, Glenwood Brown, Jr., with his counsel, Robert L. O'Brien, Esquire; and the Mother, Laura J. Wright, without counsel but was willing to proceed without an attorney. 3. The parties have reconciled. However, to ensure that there are no problems in the event of any future separation, the parties agree to a custody order in the form as attached. U DA Hubert X. Gil ,Esquire Custody Co tliator y C t: L l . L y 2 c° U W a Z3 j V U ? > $ y ? Z W J Q] ? L z a O I)EC 0 8 1999 GLENWOOD BROWN, JR. Plaintiff Vs. LAURA J. WRIGHT Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3680 CIVIL TERM IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on August _, 2001, I, Robert L. O'Brien, Esquire, did serve a copy of the Petition for Court Hearing by first class U.S. mail, postage prepaid, to the parties listed below, as follows: Bradley L. Griffie, Esquire Griffie and Associates 200 North Hanover Street Carlisle, Pennsylvania 17013 Laura J. Wright c/o Wayne and Joanne Wright 2208 Warren Way Mechanicsburg, Pennsylvania 17055 Glenwood Brown, Jr. c/o Glenwood Brown Sr. 2122 Douglas Drive Carlisle, Pennsylvania 17013 Robert L. O'Brieen,EEsquire GLENWOOD BROWN, JR. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION - LAW NO. 99-3660 CIVIL TERM LAURA J. WRIGHT Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of 2001, upon consideration of the attached petition, a hearing is scheduled for , the day of , 2001 at a.m./p.m. in Courtroom No. 1, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. BY THE COURT, J. Wesley Oler, Jr., J. Robert L. O'Brien, Esquire Attorney for Petitioner Bradley L. Griffie, Esquire Attorney for Paternal Grandmother Wayne and Joanne Wright Parents of the Respondent Laura J. Wright Defendant/Respondent GLENWOOD BROWN, JR. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION -LAW LAURA J. WRIGHT NO. 99-3680 CIVIL TERM Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of 2001, upon consideration of the attached petition, a hearing is scheduled for , the day of , 2001 at a.m./p.m. in Courtroom No. 1, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. BY THE COURT, J. Wesley Oler, Jr., J. Robert L. O'Brien, Esquire Attorney for Petitioner Bradley L. Griffie, Esquire Attorney for Paternal Grandmother Wayne and Joanne Wright Parents of the Respondent Laura J. Wright Defendant/Respondent GLENWOOD BROWN, JR. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION - LAW NO. 99-3680 CIVIL TERM LAURA J. WRIGHT Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of 2001, upon consideration of the attached petition, a hearing is scheduled for , the day of , 2001 at a.m./p.m. in Courtroom No. 1, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. BY THE COURT, J. Wesley Oler, Jr., J. Robert L. O'Brien, Esquire Attorney for Petitioner Bradley L. Griffie, Esquire Attorney for Paternal Grandmother Wayne and Joanne Wright Parents of the Respondent Laura J. Wright Defendant/Respondent GLENWOOD BROWN, JR. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION - LAW NO. 99-3680 CIVIL TERM LAURA J. WRIGHT Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of 2001, upon consideration of the attached petition, a hearing is scheduled for , the day of 2001 at a.m./p.m. in Courtroom No. 1, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. BY THE COURT, J. Wesley Oler, Jr., J. Robert L. O'Brien, Esquire Attorney for Petitioner Bradley L. Griffie, Esquire Attorney for Paternal Grandmother Wayne and Joanne Wright Parents of the Respondent Laura J. Wright Defendant/Respondent ?irP.?,5pUfj1? GLENWOOD BROWN„ IR.. IN TILE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION - LAW LAURA J. WRIGIFl'. NO. 99-3680 CIVIL Defendant IN CUS'T'ODY COURT ORDER AND NOW, this 2D_`_ day of September. 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: This shall be a temporary custody order and shall supercede any prior custody orders entered in this case. Upon the Father's release from prison, the parties will negotiate between themselves in an effort to reach a permanent custody order and, in the event there is no agreement between the parties, counsel for either party may contact the conciliator to have another custody conciliation conference. 2. Pending further order of this Court, the Paternal Grandfather. Glenwood Brown. Sr.. shall have custody of the minor child. Chris Junior Brown, born November 21. 1998, on every Friday from 9:00 a.m. until the following Monday morning at 9:00 a.m. The Mother. Laura J. Wright, shall have custody during all other times. The Mother and the Paternal Grandfather can work out between themselves an arrangement whereby the Paternal Grandfather's periods of custody shall be modified such that he is taking care of the minor child when the Mother is working or at other times convenient for the parties. Ilowever, at a minimum Paternal Grandfather's time shall be for approximately three (3) days during the week. 3. The panics acknowledge that this is a temporary order subject to modification upon change in circumstances in the future, especially when the Father is released from prison. c: 4. In the event there are any problems with respect to custody such that either party desires a more specific detailed order, counsel for either party may contact the conciliator directly to have a custody conciliation conference conducted over the telephone with the conciliator and the attorneys for the parties. cc: BY TiIE/COURT. J. esley Oler, Jr. ^ Robert L. O'Brien, Esquire David Lopez, Esquire n I Glenwood Brown, Jr. _ V 1 c/o Cumberland County Prison CCCIIh?? ?CAAA addlll 9ago? 5 GLENWOOD BROWN, JR.. Plaintiff v LAURA J. WRIGHT, Defendant Prior Judge: J. Wesley Oler. Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3680 CIVIL. IN C'UST'ODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITII THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the child who is the sul jcet of this litigation is as follows: Chris Junior Brown, born November 21, 1998. 2. A Conciliation Conference was held on September 20, 2001, with the following individuals in attendance: The Paternal Grandfather, Glenwood Brown, Sr., with his counsel Robert L. O'Brien, Esquire; and the Mother, Laura J. Wright, with her counsel, David Lopez, Esquire. The Father, Glenwood Brown, Jr. was not present. He is currently incarcerated in the Cumberland County Prison. 3. The parties agree to the entry of a temporary custody order in the form as attached. DATE Ilubert X. Custody ( GLENWOOD BROWN, JR. IN TIIE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. LAURA J. WRIGHT DEFENDANT 99-3680 CIVIL ACTION LAW IN CUSTODY AND NOW, Friday, August 31, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse Carlisle on Thursday, September 10 2001 at 8:30 a.m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. 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/ Hubert X Gilroy, 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 ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO -1-0 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 ?2 74/ ??K1 a-4 GLENWOOD BROWN, JR., Plaintiff V. LAURA J. WRIGHT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3680 CIVIL TERM ORDER OF COURT AND NOW, this 30`h day of August, 2001, upon consideration of Plaintiff's Petition for Court Hearing, this matter is referred to the custody conciliation process pursuant to Cumberland County Rule of Procedure 1915.12-1, and the Court Administrator is requested to facilitate and expedite this referral. Robert L. O'Brien, Esq. 17 West South Street Carlisle, PA 17013 Attorney for Plaintiff Bradley L. Griffie, Esq. 200 North Hanover Street Carlisle, PA 17013 nn Attorney for Paternal Grandmother Wayne and Joanne Wright 2208 Warren Way Mechanicsburg, PA 17055 Parents of Defendant BY THE COURT, Laura J. Wright c/o Wayne and Joanne Wright 2208 Warren Way Mechanicsburg, PA 17055 Defendant, Pro Se :rc GLENWOOD BROWN, JR IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION - LAW NO. 99-3680 CIVIL TERM LAURA J. WRIGHT Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of 2001, upon consideration of the attached petition, a hearing is scheduled for , the day of 2001 at a.m./p.m. in Courtroom No. 1, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. BY THE COURT, J. Wesley Oler, Jr., J. Robert L. O'Brien, Esquire Attorney for Petitioner Bradley L. Griffie, Esquire Attorney for Paternal Grandmother Wayne and Joanne Wright Parents of the Respondent Laura J. Wright Defendant/Respondent GLENWOOD BROWN, JR. Plaintiff Vs. LAURA J. WRIGHT Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3680 CIVIL TERM IN CUSTODY PETITION FOR COURT HEARING 1. Petitioner is Glenwood Brown, Sr., the paternal grandfather of Chris Junior Brown. Attached hereto is the most recently entered order of court in reference to Chris. 2. Initially, the Mother/Defendant, the maternal grandparents and Petitioner had a good working relationship as to Chris' custody situation. 3. At this time, the custody situation needs to be assessed by the Court to address the best interest of Chris. His father, Glenwood Brown, Jr., Plaintiff in this action, remains in the Cumberland County Prison with an expected release date of November, 2001. WHEREFORE, Petitioner respectfully requests that the hearing that was continued from June 29, 2001 be rescheduled. Respectfully submitted, O'BRIEN, BARIC & SCHERER By. ?d?AA-L? Robert L. O'Brien, Esquire Attorney for Petitioner I.D. # 28351 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 rlo.dir/domestic/brown.pet %- _: ,'i ,., ???S _; VERIFICATION I verify that the statements made in the foregoing Petition for Court Hearing are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Glenwood tro`wn, Sr. Date: X Z- o GLENWOOD BROWN, JR., Petitioner/Plaintiff vs. LAURA J. WRIGHT, Respondent/Defendant AND NOW, this <? +t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW 99-3680 CIVIL IN CUSTODY ORDER OF COURT day of June, 2001, upon consideration of the Petition for Special Relief filed by Glenwood Brown, Sr., in the above-captioned case, a hearing is scheduled for Friday, June 29, 2001, at 2:30 p.m. in Courtroom Number 1, Cumberland County Courthouse, Carlisle, PA. Pending the hearing, physical custody of the child, Chris Junior Brown (d.o.b. November 21, 1998), shall be in Petitioner, Glenwood Brown, Sr. Petitioner shall be responsible for causing service of this order upon all interested parties. BY THE COURT, J esley Oler, Jr., Robert L. O'Brien, Esquire For Petitioner Glenwood Brown, Sr. Ant GLENWOOD BROWN, SR. Petitioner vs. LAURA J. WRIGHT Respondent/Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3680 CIVIL TERM IN CUSTODY ORDER OF COURT , Z ? / I / open co?sI ez ton cZ#:. c c (e el, AND NOW, this 7f? ? clay of June, 2001, the hearing that was scheduled for Friday, June 29, 2001, at 2 30 p m in the above-captioned matter is continued. This matter may be re-listed by an interested person or party to the action by contacting the court and requesting another hearing. F,dbert L. O'Brien, Esquire Attorney for Petitioner Bradley L. Griffie, Esquire Attorney for Paternal Grandmother Wayne and Joanne Wright Parents of the Respondent BY THE COURT, W? D J. Wesley V. Jr., J. Molved L(Iv•!)jlic v, OVIRIF.N, SCHERER 1, If b.cl .South .surer r'ur/oh, l'rnrnrlrunrrr 1 '1)/ 3 Ruherl /. 071.1"'1 /.4n Id. 1, Barr( 1/01,1,•/.1 Scherrr June 27, 2001 The Honorable J. Wesley Oler, Jr., J. Cumberland County Courthouse One Courthouse Square Carlisle, Pennsylvania 17013 Re: Brown vs. Wright No. 99-3680 Dear Judge Oler: (717) 241-073 Fax (717) 249-5755 E-mail: uh.daircum Please be advised that we are requesting that the hearing scheduled for Friday, June 29, 2001 at 2:30 p.m. be continued in general in order to give the parties an opportunity to meet and work things out in regard to the best interest and welfare of Chris Junior Brown. My client has been in contact with Laura Wright's parents and have spoken with Brad Griffie who is currently representing the paternal grandmother of Chris. I represent Glenward Brown, Sr., the paternal grandfather. We have established a conference at my office on Monday, July 9, 2001 at 1:30 p.m. At the present time, Brad Griffie is the only other attorney involved in this matter and he concurs with this proposal. I have enclosed a proposed order to continue this matter generally. I will notify you after the meeting scheduled for July 9, 2001, as for the need for any further court involvement. Your consideration of this request is greatly appreciated. Very truly yours, O'BRIEN, BARIC & SCHERER Robert L. O'Brien, Esquire RLO/af Enc. cc: Glenward Brown, Sr. Bradley L. Griffie, Esquire Wayne and Joanne Wright file rl o.d i rllette rs/brown.ltr N-) L,tur; ? y ?.., :?1.??, _? ? _ U '?' < Z ?`?y ? ? u ? U 3 ? ? 2 5 m ? ? z y ? ? _ ? c ? b V i 0 LAW OFFICES O'BRIEN BARIC & SCHERER 17 WEST SOUTH STREET CARLISLE. PENNSYLVANIA 17013 GLENWOOD BROWN, JR. C/O GLENWOOD BROWN, SR. 2122 DOUGLAS DRIVE CARLISLE, PENNSYLVANIA 17013 I . t ?i GLENWOOD BROWN, SR Petitioner vs. LAURA J. WRIGHT Respondent/Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99.3680 CIVIL TERM IN CUSTODY ORDER OF COURT --??- { I / ?pencomsi?e2lton `?cLll?[?c?+(e vo AND NOW, this day of June, 2001, the hearing that was scheduled for n Friday, June 29, 2001, at 2 30 p m in the above-captioned matter is continued. This matter may be re-listed by an interested person or party to the action by contacting the court and requesting another hearing BY THE COURT, W? D J. Wesley V. Jr., J. C? "1 n \ Robert L. O'Brien, Esquire ?' r J 60 Attorney for Petitioner Bradley L. Griffie, Esquire Attorney for Paternal Grandmother Wayne and Joanne Wright Parents of the Respondent o?attt.et. ?? ?? lair 61jirc% 071111?N, 11;11i1r•.C,1•r'111:HP.li 17 II'ce1 .?Snnh .Cnrr1 ur•h.lr. l'rmm/I as r I'UI: Hobo I/. 0'111•1rn 1)(110.1 Boric 16c h.rr l . 1 .\'c/rnrrr June 27, 2001 The Honorable J. Wesley Oler, Jr., J. Cumberland County Courthouse One Courthouse Square Carlisle, Pennsylvania 17013 Re: Brown vs. Wright No. 99-3680 Dear Judge Oler: (717) 249-6873 1•irc (717) 249-5755 Please be advised that we are requesting that the hearing scheduled for Friday, June 29, 2001 at 2:30 p.m. be continued in general in order to give the parties an opportunity to meet and work things out in regard to the best interest and welfare of Chris Junior Brown. My client has been in contact with Laura Wright's parents and have spoken with Brad Griffie who is currently representing the paternal grandmother of Chris. I represent Glenward Brown, Sr., the paternal grandfather. We have established a conference at my office on Monday, July 9, 2001 at 1:30 p.m. At the present time, Brad Griffie is the only other attorney involved in this matter and he concurs with this proposal. I have enclosed a proposed order to continue this matter generally. I will notify you after the meeting scheduled for July 9, 2001, as for the need for any further court involvement. Your consideration of this request is greatly appreciated. Very truly yours. O'BRIEN, BARIC & SCHERER Robert L. O'Brien, Esquire RLO/af Enc. cc: Glenward Brown, Sr. Bradley L. Griffie, Esquire Wayne and Joanne Wright file rlo.d i r/letters/brown.ltr GLENWOOD BROWN, JR. Plaintiff Vs. LAURA J. WRIGHT Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3680 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this S f L day of M 2004, upon consideration of the attached petition, a hearing is scheduled for the a. day of zte 2004 at J iq a.m.(T0.. in Courtroom No. 1, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. /Robert L. O'Brien, Esquire Attorney for Petitioner Zgal Services for Laura J. Wright Defendant/Respondent ti-A/ b J.Ce. ?I b5-??-0 S BY THE COURT, U J. Wesl ler, r., . F!'_ED-ptFr?? 0. C, Z?aa;?:?? i i r?; t? i9 .-,,; ,? >?, !.ii„_ . _ GLENWOOD BROWN, 9R. Plaintiff Vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3680 CIVIL TERM LAURA J. WRIGHT Defendant IN CUSTODY PETITION FOR EMERGENCY RELIEF 1. Petitioner is Glenwood Brown, Sr., the paternal grandfather of Chris Junior Brown. Attached hereto is the most recently entered order of court in reference to Chris. Respondent is Laura Wright. 2. On March 23, 2004 Laura Wright took Chris and said that she would keep him for a couple of days and return him to Mr. Brown's home. She has never returned him. 3. When the child was not returned, Mr. Brown contacted the parents of Laura Wright to determine if that was where she was because he was under the impression that was where she had taken the child on March 23. Her parents said that she had not been there and they did not know her whereabouts. 4. Laura Wright had met and began a liaison with a man she came into contact with while he was an inmate of the Cumberland County prison. This individual is Danny Lawrence, formerly of 401 South 14`h Street, Harrisburg, PA 17103. He was paroled by Judge Oler on September 2, 2003 and is subject to a restitution order in excess of $6,000.00. 5. Mr. Lawrence had been employed by Carlisle Tire and Wheel and recently left that employment by choice or dismissal. He is believed to be traveling with Laura Wright and Chris. 6. Laura Wright is on probation with the Cumberland County Court and has a residence listed as 2208 Walker Way, Mechanicsburg, PA 17055. This had been her parents home but they have moved to 1890 Townhill Road, York Springs, PA 17372. 7. On April 1, 2004, Laura Wright came to her parents home, with her son and Mr. Lawrence in the car and collected her clothing and personal items. She would not disclose to her mother and father where she was going. Prior to her disappearance she had lived some days at her parent's home and some days at Mr. Browns home. 8. Mr. Brown has conducted searches and made inquiries in Cumberland and Dauphin Counties to locate his grandson. He has sought the assistance of the local police and the Cumberland County DA's office in filing criminal charges against Laura Wright and has not been able to achieve any assistance. 9. Mr. Brown is concerned because of Mr. Lawrence's past criminal activities which in Cumberland County alone have led to the filing of charges for M2 simple assault, F2 burglary, F2 criminal trespass, M1 theft, M2 criminal mischief, M1 receiving stolen property, F3 receiving stolen property and M2 fleeing or eluding an officer. Mr. Brown is concerned that Mr. Lawrence may return to crime to support himself and thereby expose Chris to danger. 10. Mr. Brown requests emergency relief by the Court because Laura Wright has been incommunicado since she took Chris and is in clear violation of the Court Order. Mr. Brown's son, who has been released from prison has been unable to locate his son and wishes his son returned to his father's care. Wherefore, Plaintiff respectfully requests that the Court conduct an ex parte hearing if Laura Wright continues to remain at large and award primary physical and legal custody of Chris Junior Brown, born November 21, 1998, and issue other orders as are just and equitable. Respectfully submitted, O'BRIEN, BARIC & SCHERER By: `.. G???A Q Robert L. O'Brien, Esquire Attorney for Petitioner I. D. # 28351 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 do.d it/domestic/brown.emer.pet VERIFICATION I verify that the statements made in the foregoing Petition for Emergency Relief are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Glenwood Brown, Sr. Date: ' GLENWOOD BROWN, JR. Plaintiff Vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3680 CIVIL TERM LAURA J. WRIGHT Defendant IN CUSTODY CERTIFICATE OF SERVICE 41- I hereby certify that on May 5 , 2004, I, Robert L. O'Brien, Esquire, did serve a copy of the Petition for Court Hearing by first class U.S. mail, postage prepaid, to the parties listed below, as follows: Laura J. Wright c/o Legal Services, Inc. 8 Irvine Row Carlisle, Pennsylvania 17013 Laura J. Wright c/o Wayne Wright 1890 Townhill Road York Springs, PA 17372 Robert L. O'Brien, Esquire GLENWOOD BROWN JR Plaintiff LAURA J. WRIGHT, Defendant SEp 2 5 2001 60 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LA W NO. 99-3680 CIVIL IN CUSTODY COURT ORDER AND NOW, this ??'day of September, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I • This shall be a temporary custody order and shall supercede any prior custody orders entered in this case. Upon the Father's release from prison, the parties will negotiate between themselves in an effort to reach a permanent custody order and, in the event there is no agreement between the parties, counsel for either party may contact the conciliator to have another custody conciliation conference. 2. Pending further order of this Court, the Patemal Grandfather, Glenwood Brown, Sr., shall have custody of the minor child, Chris Junior Brown, bom November 21, 1998, on every Friday, from 9:00 a.m. until the following Monday morning at 9:00 a.m. The Mother, Laura J. Wright, shall have custody during all other times. The Mother and the Paternal Grandfather can work out between themselves an arrangement whereby the Paternal Grandfather's periods of custody shall be modified such that he is taking care of the minor child when the Mother is working or at other times convenient for the parties. However, at a minimum Paternal Grandfather's time shall be for approximately three (3) days during the week. 3. The parties acknowledge that this is a temporary order subject to modification upon change in circumstances in the future, especially when the Father is released from prison. 0 4. In the event there are any problems with respect to custody such that either party desires a more specific detailed order, counsel for either party may contact the conciliator directly to have a custody conciliation conference conducted over the telephone with the conciliator and the attorneys for the parties. cc: BY THE COURT, esley Oler, J/ J. Robert L. O'Brien, Esquire David Lopez, Esquire Glenwood Brown, Jr. c% Cumberland County n I Prison 9 o2s-o i s t. ,r:c set mY ftantl GLENWOOD BROWN, JR.. Plaintiff v 2. 3. LAURA J. WRIGHT, Defendant Prior Judge: J. Wesley Oler, Jr. follows: "en, Information pertaining IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - 3680 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE 1915.3 WITH THE CUMBERLAND (b), the undersigned Custody Conciliator submits the following report: I' The perti Chris Junior Brown, born November 21, 1998 A Conciliation Conference was held on September 20, 2001, wi in attendance: th the following individuals The Paternal Grandfather, Glenwood Bro Esquire; and the Mother, Laura J Sr' with his counsel Father, Glenwood Wright with her counsel, David Loobert L. O'Brien Cumberland Col. Brown, Jr, was not present H pez, Esquire Th , mty Prison. The parties agree to the entry ofa temporary custody order in the form as attached. ?o G DATE to the child who is the subject of this litigation is as e is currently incarcerated in the N v r r E; 0 0 C? ?y LL L y I ?? ? L ,ILI ..L l\ J? C \\ ? 1 S -? c? J N GLENWOOD BROWN, JR., Petitioner/Plaintiff VS. LAURA J. WRIGI IT. Respondent/Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99-3680 CIVIL IN CUSTODY ORDER OF COURT' AND NOW, this day of June, 2001. upon consideration ofthe Petition for Special Relief filed by Glenwood Brown, Sr., in the above-captioned case, a hearing is scheduled for Friday, June 29, 2001, at 2:30 p.m. in Courtroom Number 1, Cumberland County Courthouse, Carlisle, PA. Pending the hearing, physical custody of the child, Chris Junior Brown (d.o.b. November 21, 1998), shall be in Petitioner, Glenwood Brown, Sr. Petitioner shall be responsible for causing service of this order upon all interested parties. BY THE COURT, 11 esley Oler. Jr., Robert L. O'Brien, Esquire - ?.'ol •? ?cr •;???1 9 c?rJ For Petitioner Glenwood Brown, Sr. Cop./ :rI GLENWOOD BROWN, SR. Petitioner/ VS. LAURA J. WRIGHT Respondent/Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3680 CIVIL TERM IN CUSTODY PETITION FOR SPECIAL RELIEF 1. Petitioner is Glenwood Brown, Sr., the father of the Plaintiff in the above- captioned action. 2. Respondent is Laura J. Wright, Defendant in the above-captioned action. 3. On July 8, 1999, a Court Order was issued in regard to the custody of the Petitioner's grandson, Chris Junior Brown. A copy of said Order is attached hereto as Exhibit "A" and incorporated herein by reference. 4. Subsequent to the Order the Plaintiff Father was charged with crimes resulting in his current incarceration. The Defendant Mother is scheduled for a pre trial conference on burglary charges on June 15, 2001, in Perry County. Additionally, there is an outstanding warrant for her arrest on other charges, as reported to the Petitioner by her parents. 5. Petitioner has provided much of the primary care and custody of his grandson, who has lived with him for most of the time since his birth. The Respondent Mother has also resided in Petitioners home. She most recently traveled with the child to Texas approximately five weeks ago. She returned the child to Respondent and has reported that she is in the Hagerstown area but will not disclose a specific address. 6. Petitioner is concerned for the welfare of his grandchild and desires that he be granted temporary primary custody of Chris pending the resolution of the criminal charges against the Respondent as well as a determination of where she intends to reside. 7. When the Respondent intended to enlist in the service she had prepared an agreement granting custody to the Petitioner. A copy of this agreement is attached hereto. The Petitioner believes an executed copy of this document is with the recruiting office. WHEREFORE, Petitioner respectfully requests that the Court issue a temporary Order granting him primary custody of Chris Junior Brown pending a hearing and determination of where the welfare and best interest of Chris is best served. Respectfully submitted, O'BRIEN, BARIC & SCHERER By.' R?ajs, Robert L. O'Brien, Esquire Attorney for Petitioner/Plaintiff I. D. # 28351 17 West South Street Carlisle, Pennsylvania 17013 robldomestletbrown.petWon I verify that the statements made in the foregoing Petition For Special Relief are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. GLENWOOD BROWN, SR. DATE: ..vL / 1,4`41 7. GLENWOOD BROWN, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW LAURA J. WRIGHT, NO. 99-3680 CIVIL . Defendant IN CUSTODY COURT ORDER AND NOW, this ff'& day of July, 1999, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Glenwood Brown, Jr., and the Mother, Laura J. Wright, shall enjoy shared legal custody of Chris Junior Brown, bom November 21, 1998. 2. The parties shall share equally physical custody of the minor child. The times for exchange of custody for this schedule shall be worked out between the parties. 3. Both parties have the right to have an extended period of time with the minor child under the custody schedule for a period of up to 4 weeks in the event either party desires to make arrangements to take the child to their parents or other relatives. 4. The parties shall share or alternate holidays as they may agree. 5. The Father shall always have custody on Father's Day and the Mother shall always have custody on Mother's Day. 6. This order may be modified by agreement of the parties. Absent any agreement, this order shall control unless either party would petition the court to have the order modified. BY THE COURT, -z l/ Q )4d4.4." J. cc: Robert L. O'Brien, Esq. Laura J. Wright TRUE COPY FROM RECORD In Tsstim ?:• ; !: ,,;? I h,•rc unto set my hand and the sea! of saA Court ar Carlisle, Pa. This -9. 1 .... day oE... *y ...., 19.49. ........ ........ Q..-..... l?rttl._ abf ?. Prothonotary EXHIBIT "A" GLENWOOD BROWN, JR. Plaintiff Vs. LAURA J. WRIGHT Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3680 CIVIL TERM IN CUSTODY CUSTODY AGREEMENT 1) Laura J. Wright is the natural mother of Chris Junior Brown. She resides with Chris and his fraternal Grandfather, Glenwood Brown, Sr., at 2122 Douglas Drive, Carlisle, Pennsylvania. 2) The natural father of Chris, Glenwood Brown, Jr., consents to the placement of the primary custody of Chris with his father, Glenwood Brown, Sr. 3) Ms. Wright has made arrangements to enlist in the armed forces and needs to assure the adequate care and custody of Chris. She wishes to place Chris in the primary custody of his Father, Glenwood Brown, Jr. or his fraternal Grandfather, Glenwood Brown, Sr. She also wishes to grant them the authority for medical care and treatment and has attached an executed power of attorney to this agreement. 4) Glenwood Brown, Sr., consents to accept the custody of Chris as well as the designation as power of attorney for necessary care and treatment. 5) Glenwood Brown, Jr., consents to grant the primary custody of Chris to Glenwood Brown, Sr. as well as the authority as power of attorney, until such time as he can maintain primary custody. 6) All of the undersigned agree that the natural parents shall exercise times of partial custody as their respective schedules permit. 7) All of the undersigned agree that this Custody Agreement shall be entered as an Order of Court and that it will replace and supersede all prior Orders in reference to Chris Junior Brown. IN WITNESS WHEREOF, the undersigned parties have executed this agreement this day of February, 2001. WITNESS: Laura J. Wright (SEAL) Glenwood Brown, Jr. (SEAL) (SEAL) Glenwood Brown, Sr. JUN O GLENWOOD BROWN, JR. IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 99-3680 CIVIL ACTION LAW LAURA J. WRIGHT DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, March 03, 2005 _ _.,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq, , the conciliator, at 41h Floor, Cumberland County Courthouse, Carlisl- e on Thursday, APril07, 2005 - at 10:30 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. /s/ Hubert X. Gilroy Esg 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 haying business before the court, please contact ouroffice. All arrangements must be made at least 72 hours prior to nny 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 "f0 FIND OUT WHERE YOU CAN GET LE(iAl. HELP. C'umberiand County Bar Association 32 South Bedford Street Carlisle. Pennsyh'ania 1701 3 Telephone (717)249-3160 ?? ?. : n. ,, ,-., r_,. ,, ;? ,?? 7 o.S ?- L'o? .r?? ? v? ,Pe??-n, L 1 .!b 4-/ G GLENWOOD BROWN JR., Plaintiff, V. LAURA J. WRIGHT, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3680 CIVIL ACTION -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 on the day of , 2005 at , in the for the 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. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent Order. For the Court, Date: By: Custody Conciliator GLENWOOD BROWN JR, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-3680 LAURA J WRIGHT, Defendant. : CIVIL ACTION- CUSTODY PETITION TO MODIFY CUSTODY Petitioners Laura J. Lawrence (formerly Wright), Joanne E. Wright and Wayne E. Wright, by and through their attorneys, Gerald S. Robinson, Esquire, and the law firm of ROBINSON & GERALDO, respectfully request the following: Respondent is Glenwood Brown Jr, an adult individual and the natural Father who currently resides at 2122 Douglas Drive, Carlisle, Cumberland County, Pennsylvania. 2. Petitioners are Laura J Lawrence, an adult individual and the natural Mother who currently resides at 1113 Fifth Avenue, Apt # 305, New Kensington, Westmoreland County and Joanne E. and Wayne E. Wright, maternal grandparents. Petitioners seek to have the existing Custody Order modified by awarding Petitioner/Defendant Laura J. Lawrence sole legal custody and primary physical custody of the subject minor child. 4. The child, Chris Junior Brown, bom on November 21, 1998 is presently in the custody of Petitioners Joanne E. And Wayne E. Wright (maternal grandparents), who currently reside at 1890 Townhill Road, York Springs, Adams County, Pennsylvania. 5. From birth to present, the child has resided at the following addresses with the following persons: Person(s) Addresses Dates Joanne and Wayne Wright their current address 1/3/05 to present Glenwood Brown, Sr. Respondent's address 6/21/04 to 1/3/05 Laura Wright (now Lawrence) Carlisle birth to 6/21/04 6. Petitioner does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody of the child or claims to have custody or visitation rights with respect to the child. 7. There is an existing Custody Order entered into effect on January 3, 2005, a copy of which is attached hereto as Exhibit I 8. The best interest and permanent welfare of the child will be served by modifying the Custody Order because the former custodian of child is no longer available and Petitioners, Laura J. Lawrence (natural mother) and Joanne and Wayne Wright (maternal grandparents) have agreed that Mother has the resources and stability to serve as the primary custodial parent of the said minor child. 2 9. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as a party to this action. WHEREFORE, the Petitioner respectfully requests this Honorable Court to modify the current custody order granting primary physical custody to Petitioner Laura J. Lawrence. Respectfully submitted, ?//R11O,BIINAS,ONN &?GERQALDO By: Gerald S. Robinson, Esquire Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717) 232-8525 Attorney for Petitioners VERIFICATION I verify that the statements made in this Petition To Modify Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. i taura J Law ce Joanne E. Wngghht Wayne . Wright GLENWOOD BROWN, JR., Plaintiff V. LAURA J. WRIGHT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3680 CIVIL TERM IN RE: PETITION FOR EMERGENCY CUSTODY RELIEF FILED BY MATERNAL GRANDPARENTS BEFORE OLER, J. ORDER OF COURT AND NOW, this 3`d day of January, 2005, upon consideration of the "Petition for Emergency Relief Custody" filed by Joanne E. Wright and Wayne E. Wright with respect to their grandson, Chris Junior Brown (d.o.b. November 21, 2004), and following a hearing held on January 3, 2004, at which (a) the paternal grandfather, Glenwood Brown, Sr., who is the current custodian of the child was not present due to a medical condition but was represented by Robert L. O'Brien, Esq., (b) the father, Glenwood Brown, Jr., was present pro se, (c) the mother, Laura J. (Wright) Lawrence, was not present, and (d) the matemal grandparents, Joanne E. Wright and Wayne E. Wright, petitioners, were present pro se, it is ordered and directed, pending further order of court, as follows: 1. Legal custody of the child shall be in the matemal grandparents, Joanne E. Wright and Wayne E. Wright; 2. Primary physical custody of the child shall be in the maternal grandparents, Joanne E. Wright and Wayne E. Wright; 3. Temporary or partial physical custody of the child shall be in the father, Glenwood Brown, Jr., on alternating weekends, from Friday at 6:00 p.m. until Sunday at 6:00 p.m. 4. Temporary or partial physical custody of the child shall be in the mother, Laura Wright, at such times as the parties all mutually agree; I 5. Temporary or partial physical custody of the child shall be in the paternal grandfather, Glenwood Brown, Sr, at such times as the partie,; all mutually agree; 6. Transportation with respect to custody exchanges shall be the responsibility of the party receiving custody; 7. Nothing herein is intended to preclude the parties from deviating from the terms of this order by mutual agreement; and 8. Upon petition of any party based upon a change of circumstances, including the return home of the paternal grandfather from a nursing home or the resolution of pending criminal charges against the father, the court will review the terms of this custody order. BY THE COURT, Glenwood Brown, Jr. 2122 Douglas Drive Carlisle, PA 17013 Plaintiff, pro se Laura J. (Wright) Lawrence 1113 Fifth Avenue, # 305 New Kensington, PA 15068 Defendant, pro se We E. and Joanne E. Wright 90 Town Hill Road York Springs, PA 17372 Petitioners/Intervenors J. esley Olet, r., J. L TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said Court at Carlisle, Pa. This ....Ia y of? .2........ 20 Robert O'Brien, Esq. 17 West South Street Carlisle, PA 17013-2899 Attorney for Glenwood Brown, Sr. Courtesy Copy: Martha Vangorder 132 Andre Court Burlington, NJ 08016 :rc /?l N - 4 v M off. ?, d d f J. WESLEY OLER, JR. rMCJUDGE ONE COURTHOUSE SOUARE 21'0 •r - ?.? f CARLISLE, PA 17013 V / enwood Brown, Jr. Cumberland County Prison GLENWOOD BROWN, JR., Plaintiff V. LAURA J. WRIGHT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3680 CIVIL TERM ORDER OF COURT AND NOW, this 20`h day of December, 2004, upon consideration of the Petition for Emergency Relief Custody, a hearing is scheduled for Monday, January 3, 2005, at 9:30 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. Glenwood Brown, Jr. c/o Martha Vangorder 251 West Dekalv Pike C-308 King of Prussia, PA 17372 Plaintiff, pro se Xenwood Brown, Jr. Cumberland County Prison Laura J. Wright c/o Wayne and Joanne Wright 1890 Town Hill Road York Springs, PA 17372 Defendant, pro se Wayne and Joanne Wright 1890 Town Hill Road York Springs, PA 17372 TRUE COPY FROM RECORD In Testimony wherrof, I h;?,re unfo net my held anLe of said Cour a lisle Pa. ..... ay .................................. Prothonotary BY THE COURT, Robert O'Brien, Esq. 17 West South Street Carlisle, PA 17013-2899 Attorney for Glenwood Brown, Sr. :rc J. WESLEY OILER. JR. JUDGE ONE COURTHOUSE SQUARE CARLISLE, PA 1 7013 2 I?rI -fll Nof' 0 -1 2l n ?l ' l a d ?loG (nL)r d INSUFFICIEN/T?ADDRESS ATTEMPTED NOT KNOWN ? OTHER ? NO SUCH NUMBER/ STREET UNAB TO JUL 19 1%4 U8 ` S O NOT DEL LI ERABLE ApADDRESSED 4 'r 4 GLENWOOD BROWN, JR., Plaintiff v LAURA J. WRIGHT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . CIVIL ACTION - LAW . 99-3680 CIVIL TERM IN CUSTODY IN RE: PETITION FOR EMERGENCY RELIEF ORDER OF COURT AND NOW, this 21st day of June, 2004, upon consideration of the Petition for Emergency Relief filed on behalf of Glenwood Brown, Sr., with respect to his grandson, Chris Junior Brown (date of birth November 21, 1998), and following a hearing at which neither Glenwood Brown, Jr., the child's father, nor Laura J. Wright, the child's mother, appeared, it is ordered and directed as follows: 1. Legal custody of the child shall be in the Petitioner, Glenwood Brown, Sr. 2. Primary physical custody of the child shall be in the Petitioner, Glenwood Brown, Sr., and temporary partial physical custody of the child shall be in Glenwood Brown, Jr., and Laura J. Wright at such times as Petitioner, Plaintiff, and Defendant agree upon. 3. The Court will hold a prompt hearing to consider the continuation, modification or termination of this order at the request of Petitioner, Plaintiff, or Defendant. 9. Pending further order of the Court, the terms of this temporary order shall remain in full force and effect. By the Court, Av oJ. 4fesley Oler r. , J. Robert O'Brien, Esquire 17 West South Street Carlisle, PA 17013-2899 For Glenwood Brown, Sr., the Petitioner Glenwood Brown, Jr. C/o Martha Vangorder 251 West Dekalv Pike C-308 King of Prussia, PA 19400' yLa ra J. Wright o Wayne and Joanne Wright 1890 Town Hill Road York Springs, PA 17372 :mae rRUE COPY FROM REXRD in Testimony whereof, I here unto set my hand and the seal of said p at Carlisle, Pa. iris d S ay + V Y Prothonotsrv