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Home My WebLink About02-0823CHARLES D. GALASPY, Plaintiff KANDICE L. GALASPY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.~t~-~CIVIL ACTION IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Charles D. Galaspy, residing at 45 Carlton Avenue, Carlisle, Cumberland County, Pennsylvania. 2. The defendant is Kandice L. Galaspy, residing at 233 Locust Point Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following children: Name Present Residence Age Amanda Galaspy 233 Locust Point Road 4 years Mechanicsburg, PA Charles Galaspy 233 Locust Point Road 19 months Mechanicsburg, PA Aaron Galaspy 233 Locust Point Road 7 years Mechanicsburg, PA The children were bom out of wedlock The children are presently in the custody of Kandice Galaspy who resides at 233 Locust Point Road, Mechanicsburg, Pennsylvania. During the past five years, the children have resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Charles and Kandice Galaspy 45 Carlton Avenue 1993 - May 2001 The mother of the children is Kandice Galaspy, currently residing at 233 Locust Point Road, Mechanicsburg, PA. She is married. The father of the children is Charles Galaspy, currently residing at 45 Carlton Avenue, Carlisle, PA. He is married. 4. The relationship of plaintiff to the children is that of father. The plaintiff currently resides with the following persons. Name Relationship o The relationship of defendant to the children is that of mother. The defendant currently resides with the following persons. manle George and Wanda Wright Relationship Mother and Father Plaintiffhas not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the children 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 and claims to have custody or visitation rights with respect to the child. The best interest and permanent welfare of the child will be served by granting the relief request because: Plaintiff is best able to provide the care and nurture which the children need for healthy development. A Court Order of custody and structured visitation is desired so that Plaintiff and children may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the children are not used in a manipulative fashion. Plaintiff desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the children. Defendant is engaged in an extramarital affair and is unable to provide a suitable household for the children. WHEREFORE, Plaintiffrequests this Court grant Plaintiff primary physical custody in the Father with visitation in the Mother. Date: February 14, 2002 Respectfully submitted, Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing Petition are tree 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. Date: "~harles G~_laspy -- -,~ ~ 155 SOUTI:t HANOVER STREET CARLISLE, PENNSYLVANIA 17013 I_~w O!11elC1~$ 717.241.6070 * 800.734.2132 · FAX: 717.241.6878 ADVOCACY -- ADVICE -- ANSWERS 'law~ro~ingerlaw.cor www.romingerlaw.cor CHARLES D. GALASPY : PLAINTIFF : : V. KANDICE L. GALASPY ' DEFENDANT : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-823 CIVIL ACTION LAW IN CUSTODY AND NOW, Thursday, February 21, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before,~acqueline M. Verncy, Esq. , the conciliator, at 4th Floor, Cumberland Count}, Courthouse, Carlisle on Wednesday, March 13, 2002 at 2:30 PM 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/ ]acqueline M. Verney, 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 TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 CHARLES D. GALASPY, Plaintiff V. KANDICE L. GALASPY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-823 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this [eg'~ day of ~t)~ ,2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The custody provisions of the PFA Order dated March 1, 2002 are hereby vacated by this Order. 2. The Father, Charles D. Galaspy, and the Mother, Kandice L. Galaspy, shall have shared legal custody of Amanda Galaspy, bom June 20, 1997 and Charles Galaspy, bom December 21, 1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 3. Mother shall have primary physical custody of the children. 4. Father shall have periods of partial physical custody every Tuesday at 12:00 noon to Thursday at 12:00 noon. In the event Mother is unable to transport the children due to a conflict with her employment, the time shall be amended to accommodate Mother, while still providing Father with approximately 48 hours consecutive custody. 5. The receiving party shall be responsible for transportation. Father's parents shall be permitted to transport the children. Mother is to pick up the children at paternal grandparents' home, unless otherwise notified 6. Physical and telephonic contact between the parties is permitted for the limited purpose of custody exchanges and arrangements for custody exchanges. 7. 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. Another Conciliation Conference may be scheduled by either party within sixty (60) days of the date of this Order. cc;~Karl E. Rominger, Esquire, Counsel for Father /~anne B. Costopoulos, Esquire, Counsel for Mother ,~offn Carey, Esquire, Counsel for Mother in PFA action BY THE COURT, J. fffes~eyOler, r.~ ' ~ ~ J. CHARLES D. GALASPY, Plaintiff V. KANDICE L. GALASPY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 2002-823 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Amanda Galaspy Charles Galaspy June 20, 1997 December 21, 1999 Mother Mother 2. A Conciliation Conference was held in this matter on March 13, 2002, with the following individuals in attendance: The Father, Charles Galaspy, with his counsel, Karl E. Rominger, Esquire and the Mother, Kandice L. Galaspy, with her counsel, Jeanne B. Costopoulos, Esquire. 3. A prior Order of Court, dated March 1, 2002 was entered by the Honorable J. Wesley Oler, Jr., in a Temporary PFA matter, that included physical custody of the children to Father for one day per week. 4. The parties agreed to the entry of an Order in the form as attached. Date ~cqt~line M. Vemey, Esquire Custody Conciliator