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Home My WebLink About99-03680GLENWOOD 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'' 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. Xlenwood Brown, Jr. c/o Martha Vangorder 251 West Dekalv Pike C-308 King of Prussia, PA 17372 Plaintiff, pro se vGlenwood Brown, Jr. BOY,) Cumberland County Prison /aura J. Wright c/o Wayne and Joanne Wright 1890 Town Hill Road York Springs, PA 17372 Defendant, pro se ,Idayne and Joanne Wright 1890 Town Hill Road York Springs, PA 17372 esley Uler-,-n., i 2-a i -o ?l n BY THE COURT, ,. S, ? ,-. ? 4 ? ;7 r?,'- ; r?. P, ? ? -a . ,... __ ..r _ .. ? i :? ?i 1 Zobert O'Brien, Esq. 17 West South Street Carlisle, PA 17013-2899 Attorney for Glenwood Brown, Sr. rc DEC 1 5 2004 V 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 CUSTODY ORDER OF COURT AND NOW, this 15th day of December, 2001, 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 Court, J. Wesley Oler, Jr., J. 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 15th day of December, 2004 we Joanne E. Wright and Wayne E. Wright being the grandparents of Chris Junior Brown petition the court for emergency mlief custody of said grandson. We request this petition for the following reasons: I . 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. Wayne E. Wright Joanne E. Wright= j? 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 Dekaly 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 Cl) Y O ` E ?11 . E r ? ` I /? ...+ Y '? y Q 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 3rd 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; ,.,r J i! J 1 I ?,! 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. 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 BY THE COURT, ?2 ., J. 'dga?j A 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 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 3rd day of January, 2005, pursuant to an agreement of the parties 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., Plainti 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 Pcb zi-I GLENWOOD BROWN JR., IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-3680 LAURA J. WRIGHT, Defendant. 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 for the Pre-Hearing Custody Conference. _, in the 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. 3. 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, born 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. 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 113105 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. There is an existing Custody Order entered into effect on January 3, 2005, a copy of which is attached hereto as Exhibit 1. 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. 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, ROBINSON & GERALDO Y 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 unsworn falsification to authorities. /aui?raJ Lawl ice IN "Joanne E. q?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 3rd 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 matemal 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; 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, 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 W ne E. and Joanne E. Wright 90 Town Hill Road York Springs, PA 17372 Petitioners/Intervenors TRUE: COPY FROM RECORD In Testimoruy whereof, i here unto set my hard and the seal of said Court at Carlisle, Pa. This ....b?7?y of„,....., A-eS- 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, N7 08016 :rc P ?p - 3 d ?- c?o -XI GLENWOOD BROWN, JR. IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. LAURA J. WRIGHT DEFENDANT 99-3680 CIVIL ACTION LAW 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 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, April 07, 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 hve 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: _ /s7 Hubert X. GVroy Esq. CUStodv Conciliator The Court of Common Pleas of Cumberland County is required by law to comply rN ith 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 ltearing. 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 ? ? ?? ? ?. ?? ? ?? .- 5a. ? s?.<_ S? c f RECEIVED APR 12 2005 Y? 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 1 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. cc;J.-?aura J. Lawrence enwood Brown, Jr. I'enwood Brown, Sr. L,C,erald S. Robinson, Esquire RJR bert L. O'Brien, Esquire ,_Mt. and Mrs. Wayne E. Wrig t cf6 (\.I 1 ? . BY THE COURT, ??;J ? Y ll; ? t Y r r ?.`? ?. ?1 "+ CL ,Z ?? 1 ? .?Yr ? $ ,? , ,; ?? }?..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