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Home My WebLink About05-6772 JULIANNE MARIE GLASS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05- (J 7- 7-~ CIVIL TERM v. CHRISTOPHER GLASS, Defendant CUSTODY COMPLAINT FOR CUSTODY I. Plaintiff is Julianne Marie Glass, hereinafter referred to as Mother. Mother's permanent residence is 4 West Main Street, Walnut Bottom, Cumberland County, Pennsylvania 17266. 2. Defendant is Christopher Glass, hereinafter referred to Father. It is unknown where Father resides, but he received mail at Post Office Box 86529, San Diego, San Diego County, California 92138. 3. Mother seeks primary physical custody ofthe minor children: Name Jordan Glass Present Residence 4 W. Main Street Walnut Bottom, P A 17266 Leigha Glass 4 W. Main Street Walnut Bottom, P A 17266 Mackenziane Glass 4 W. Main Street Walnut Bottom, P A 17266 Courtnie Glass 4 W. Main Street Walnut Bottom, P A 17266 Alyssa Glass 4 W. Main Street Walnut Bottom, P A 17266 Mackayla Glass 4 W. Main Street Walnut Bottom, PAl 7266 Age 7/8/89 DOB, 16 years old 5/11/91 DOB, 14 years old 7/8/92 DOB, 13 years old 4/28/94 DOB, II years old 1/9/96 DOB, 9 years old 1/19/98 DOB, 7 years old The child, Jordan Glass was born prior to the parties' marriage and was adopted by Father. The children, Leigha, Mackenziane, Courtnie, Alyssa and Mackayla were born during the parties' marriage. The children are presently in the custody of Mother. During his lifetime, Jordan has resided with the following persons and at the following addresses: Name Lester Keck Andrea Keck Julianne Glass Jessica Keck Julianne Glass Julianne Glass Chris Glass Julianne Glass Chris Glass Leigha Glass Julianne Glass Chris Glass Leigha Glass Julianne Glass Chris Glass Leigha Glass Mackenziane Glass Julianne Glass Chris Glass Leigha Glass Mackenziane Glass Lester Keck Andrea Keck Nicholas Huffman Julianne Glass Leigha Glass Mackenziane Glass Julianne Glass Chris Glass Leigha Glass Mackenziane Glass Address Date 322 Greason Road Carlisle, PA 17013 Birth - 9/89 30 Betty Nelson Court Carlisle, P A 17013 9/89 - 5/90 30 Betty Nelson Court Carlisle, PA 17013 5/90 - 5/91 30 Betty Nelson Court Carlisle, PA 17013 5/91 - 2/92 1445 A Holly Pike Carlisle, PA 17013 2/92 - 7/92 1445 A Holly Pike Carlisle, PA 17013 7/92 - 11/92 341 Greason Road Carlisle, PA 17013 11/92 - 5/93 322 Greason Road Carlisle, PA 17013 5/93 -- 11/93 Pecks Trailer Park McConnellsburg, P A 11/93 - 4/94 Julianne Glass Pecks Trailer Park 4/94 - 1/96 Chris Glass McConnellsburg, P A Leigha Glass Mackenziane Glass Courtnie Glass Julianne Glass Pecks Trailer Park 1/96 - 9/96 Chris Glass McConnellsburg, PA Leigha Glass Mackenziane Glass Courtnie Glass Alyssa Glass Julianne Glass 496 E. Queen Street 9/96 - 9/97 Chris Glass Chambersburg, P A Leigha Glass Mackenziane Glass Courtnie Glass Alyssa Glass Julianne Glass 16 W. Main Street 9/97- 1/98 Chris Glass Newville, PA Leigha Glass Mackenziane Glass Courtnie Glass Alyssa Glass Julianne Glass 16 W. Main Street 1/98 - 4/00 Chris Glass Newville, P A Leigha Glass Mackenziane Glass Courtnie Glass Alyssa Glass Mackayla Glass Julianne Glass 329 Farmington Drive 4/00 -- I/O 1 Chris Glass Shippensburg, P A Leigha Glass Mackenziane Glass Courtnie Glass Alyssa Glass Mackayla Glass Julianne Glass 329 Farmington Drive 1/01 - 5/01 Leigha Glass Shippensburg, P A Mackenziane Glass Courtnie Glass Alyssa Glass Mackayla Glass Julianne Glass Chris Glass Leigha Glass Mackenziane Glass Courtnie Glass Alyssa Glass Mackayla Glass 329 Farmington Drive Shippensburg, P A 5/01 - 10/01 Julianne Glass 329 Farmington Drive Chris Glass Shippensburg, P A (only on random occasions) Leigha Glass Mackenziane Glass Courtnie Glass Alyssa Glass Mackayla Glass 10/01 - 9/02 9/02 - 7/03 Julianne Glass 79 W. Main Street Chris Glass Newville, PA (only on random occasions) Leigha Glass Mackenziane Glass Courtnie Glass Alyssa Glass Mackayla Glass Julianne Glass Leigha Glass Mackenziane Glass Courtnie Glass Alyssa Glass Mackayla Glass Julianne Glass Leigha Glass Mackenziane Glass Courtnie Glass Alyssa Glass Mackayla Glass Chris Glass Unknown Persons 79 W. Main Street Newville, P A 7/03 - 1/04 4 W. Main Street Walnut Bottom, P A 1/04 - 7/04 Bedford Street Carlisle, P A 7/04-12/04 Julianne Glass Leigha Glass Mackenziane Glass Courtnie Glass Alyssa Glass Mackayla Glass Maddison Glass Julianne Glass Leigha Glass Mackenziane Glass Courtnie Glass Alyssa Glass Mackayla Glass Maddison Glass Alan Kendall 4 W. Main Street Walnut Bottom, P A 12/04 - 2/05 4 W. Main Street Walnut Bottom, P A 2/05 - present Since birth, the remammg children, Leigha, Mackenziane, Courtnie, Alyssa and Mackayla, have lived with the same people and at the same places outlined for Jordan. The sole exception is the time period between July 2004 and December 2004, when Jordan lived with Father while Leigha, Mackenziane, Courtnie, Alyssa and Mackayla lived with Mother at 4 West Main Street, Walnut Bottom, Pennsylvania. 5. It is unknown whether Father resides with anyone else. 6. Mother has not participated as a party or witness, or in another capacity, in other custody litigation concerning the custody ofthe children in this or another court. 7. Mother has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 8. Mother does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 9. The best interest and permanent welfare of the children will be served by granting the relief requested for reasons including, but not limited to the following: a. Since the children were born, Mother has provided for the children's emotional, physical, educational, and medical needs. b. Mother has a stable home environrnent that is safe and appropriate for the daily care of the children. c. Mother has immediate and extended family in the local area and they are willing to provide assistance and support for Mother in providing for the children's needs. d. Mother is willing to communicate with and work cooperatively with Father to co- parent the children and will encourage father/child relationships with all of the children. 10. Father has not acted in the children's best interests in ways including but not limited to the following: a. Last year, Father moved to California and has weekly telephone contact with the children, but has not seen them since leaving for California. b. Father's currently lives in a Recreational Vehicle (RV) and does not have the ability or capacity to care for the needs of all six (6) children for extended periods of time. c. Mother's understanding of Father's current proposal for summer visits with the children consists of driving across-country in the RV, leaving the children in the RV in his employer's parking lot, and eating lunch with the children during his workday. Mother received this information from the children following conversations they had with Father. d. Father regularly promises to send the children items for various holidays and fails to follow through without explanation, leaving the children disappointed in disinclined to trust Father. 12. Every person with rights to custody or having actual physical custody of the children has been named as parties to this action. WHEREFORE, Mother requests this Court to grant her the following relief: 1. Mother and Father shall share legal custody of the children. 2. Mother shall have primary physical custody of the children. 3. Father shall have periods of partial custody as follows: a. For one half of the children's winter vacation when he is in Pemlsylvania for the holidays. The schedule for specific dates and times of this visit will be arranged by the parties prior to the children's vacation. b. For a period of time during the summer to be determined by the parties. If Father must work during his summer visit, Father must demonstrate that he has a place for the children to live other than his RV parked in the employer's parking lot. 4. The non-custodial parent shall have reasonable telephone contact with the children while they are with the other parent. 5. Any other relief this Court finds just and equitable. Respec~fd'l)Yf . , -"" / / ./ I ,. . I l J es Ie, olst, Esquire dPenn Legal Services 4 1 East Louther Street Carlisle, P A 17013 (717) 243-9400 . VERIFICATION The above-named PLAINTIFF, JULIANNE MARIE GLASS, verifies that the statements made in the above complaint For Custody are true and correct. plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. Date: /)-;);) .OS- , /7 /j, ( [~~/;;!;~ N~J5? Julianne Marie Glass . . JULIANNE MARIE GLASS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05- CIVIL TERM CHRISTOPHER GLASS, Defendant CUSTODY AFFIDAVIT OF SERVICE BY MAIL I, Jessica Holst, do hereby swear that I served Christopher Glass with a Complaint For Custody onJ}ftYrn 1J.u' .;;?n-, 2005 by certified mail, return receipt, restricted delivery, to the person and address below: Christopher Glass Post Office Box 86529 San Diego, CA 92138 I, Jessica Holst, verify that the statements made in this Affidavit of Service 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. Date: IJ. dd- ()\ Signature: C) ...., t'\ c:- (:...:;l 0 o:.:;~.:.t O::.,n ., C1 --1 .:-'1 p , :-.r:11 d 111_ ,- .\] 1"',) '-',';!;1 CD , r,;'~: --~ r:_' -"', -:"'\ C-":: ;-n ., ..:>' .< ~:'---:J -, -< c JULIANNE MARIE GLASS, Plaintiff IN THE COURT OF COMMON PLEAS OF v. CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05- u -N"). CIVIL TERM CHRISTOPHER GLASS, Defendant CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Julianne Marie Glass, Plaintiff, to proceed in forma pauperis. I, Jessica Holst, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. j(/ Jessi a olst, Esquire Mid enn Legal Services 401 East Louther Street Carlisle, P A 17013 (717) 243-9400 :~';n--; :--1 <C~ .~ --.J --< ~J ~~ c.::-::l C-JI o fq en) 1~,J C::> () -1] :;:! ".:'.~ -r-r li1r' :._::0.::1 ~. "-- ~;~~J )-:::.-;-' JULIANNE MARIE GLASS PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 05-6772 CIVIL ACTION LA W CHRISTOPHER GLASS IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday,__~ecem!>.er_~O,l_l!!I~___..___, upon consideration of the attached Complaint. it is hereby directed that pmiies and their respective counsel appear before Hubert X. Gilroy, Esq. , the coneiliator, at_.___~t~ Floor, Cumberland Cou_n~o~E!_ltouse!Carlisl,,-. on Friday, Januaq}O, 200~...__ 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 eourt, and to enter into a temporary order. All ehildren 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 hearin\!. FOR THE COURT. By: isi Hubert X Gilrov, Esq. Custody Conciliator I r: " r _00 t' " 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 conlact our offiee. 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 HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORnI 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 , ld3~ Qj--- /J3t,I~ ACI<:l() -">">V' 7<.!ry "~-P'2V "t ~ Y"!j'f"3u -x;jsj' , '-"1111.' In "L 'I' I 'Ul ,. ~ n 1,.!)Ji'" nn))? ~f- ';'\)i :J-tl'o.l\.. AU';" "11' lr , , :,.-.L :l'.) -" c!:'n!:f Ms. Julianne Glass PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PE?-JNSYL VANIA 05-6772 CIVIL ACTION LAW v. Mr. Christopher Glass DEFENDANT IN CUSTODY PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance ofthe Family Law Clinic on behalf of the Defendant, Christopher Glass, in the above-captioned matter. .~...~ {, d7~~_~ .// / Lauren Navalkowsky / Certified Legal Intern Family Law Clinic 45 N. Pitt Street Carlisle, PA 17013 (717)243-2968 January 24, 2006 !J r- 1 Op <:j JULIANNE MARIE GLASS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v : NO.05-6772 CIVIL ACTION - LAW CHRISTOPHER GLASS, Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~~~ day of February, 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Julianne Marie Glass, and the Father, Christopher GIass, shall enjoy shared Iegal custody of: Jordan Glass, boru July 8, 1989 Leigha GIass, born May 11, 1991 Mackenziane Glass, born July 8, 1992 Courtnie Glass, born April 28, 1994 Alyssa Glass, born January 9, 1996 Mackayla Glass, born January 19, 1998 Each parent shaD have an equal right, to be exercised jointly with the other parent, to make all major, non-emergency decisions affecting the chiIdren's general well- being including, but not limited to, all decisions regarding their health, education and religion. Each parent shall be entitled to all records and information pertaining to the children, including, but not limited to, medical, dental, religious or school records, and the resident address of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonabIe time as to make the records and information of reasonable use to the other parent. 2. Mother shall have primary physical custody of the children. 3. While Father resides in California, during visits to the Cumberland County, PennsyIvania area, he shall enjoy periods of partial physical custody of the children at times agreed upon by the parties. 4. While Father resides in California, he shall have reasonable contact with the children by telephone, written correspondence or email. . 5. Mother and Father agree that each shall notify the other immediately of medical emergencies that arise while the chiIdren are in that parent's care. 6. Neither party shall do anything which may estrange the children from the other parent, or injure the opinion of the children as to the other parent or which may hamper the free and natural deveIopment of the children's love or respect for the other parent. Both parties shall provide the children with a "safety zone" by discouraging third parties from making negative remarks about either parent when the children are within earshot. 7. The parties may modify the schedule in the event they reach an agreement between themseIves. Absent an agreement, the custody schedule set forth above shall control. 8. It is the understanding of the parties that Father intends to return to the local area within the next three months. Upon Father's return, the parties may contact the Conciliator to schedule another conciliation conference with the intent to modify the current Order as appropriate for the new situation. BY THE COURT: \'tW\(/ 'i Judge Cc: Jessica Holst, Esquire } C.. . t.t-L Ms. Lauren Navalkowsky --f-".~ ,)- 5-6" 1* \ :'I"tJ ("'.1 .1111" U j .; I'"" " C-' J en'? b - '.,~;..:LJ '.;il.;iJ(. , :~; .f I .. I,i..'!l....: " -" ,. :1) ,':1 ~.Jnl \ . :;',HJTHJ . JULIANNE MARIE GLASS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v NO.OS-6772 CIVIL ACTION - LAW CHRISTOPHER GLASS, Defendant IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE Willi THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the foIIowing report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as foIIows: Jordan GIass, born July 8, 1989 Leigha GIass, born May 11, 1991 Mackenziane Glass, born July 8,1992 Courtnie Glass, born ApriI 20, 1994 Alyssa Glass, born January 9, 1996 Mackayla Glass, born January 19, 1998 2. A Conciliation Conference was held on February 2, 2006, with the foIIowing individuals in attendance: The Mother, Julianne Marie glass, with her counsel, Jessica HoIst, Esquire Appearing on behalf of the Father was his student attorney, Lauren Navalkowsky 3. The parties agreed to the entry of an Order in the form as attached. Date: February J ,2006 r .. ? RtCEIVED JUL ~ 12006 <;( (6 JULIANNE MARIE GLASS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v : NO.05-6772 CML ACTION - LAW CHRISTOPHER GLASS, Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~,,~ day of _~ uq , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this Court's prior Order of February 8, 2006 is vacated and replaced with the following Order: 1. The Mother, JuliAnne Marie Glass, and the Father, Christopher Glass, shall enjoy shared legal custody of: Jordan Glass, born July 8, 1989 Leigha Glass, born May 11,1991 Mackenziane Glass, born July 8, 1992 Courtnie Glass, born April 28, 1994 Alyssa Glass, born January 9, 1996 Mackayla Glass, born January 19, 1998 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. Each parent shall be entitled to all records and information pertaining to the children, including, but not limited to, medical, dental, religious or schooI records, and the resident address of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasouable time as to make the records. and information of reasonable use to the other parent. 2. Father shall have primary physical custody of Jordan, and mother shall have primary physical custody of Leigha, Mackenziane, Courtnie, Alyssa and Mackalya. 3. Father shall have temporary custody of the five girls on alternating weekends from Saturday at 8:00 a.m. until Sunday at 8:00p.m. Additionally, father shall have temporary custody of the girls at such other times as agreed upon by the parties. 4. Mother shall have temporary custody of Jordan on alternating weekends from Saturday at 8:00 a.m. until Sunday at 8:00 p.m. and at such other times as the parties agree. . .. S. The parties shall alternate/share holidays pursuant to the schedule that has been in place by the parties. 6. During the summer months, father shall have temporary custody of the five girls for a period of four weeks pursuant to a schedule as arranged between the parties. These maybe consecutive at father's request. 7. In the event father's military assignment moves him out of the Cumberland County area, primary custody of Jordan would shift back to mother so that Jordan may continue in the Big Spring School District. 8. When either parent has custody of the minor children and that parent is not available to care for the children for a period of three hours or more because of work or other commitments, the custodial parent shall contact the other parent and give that parent the opportunity to provide daycare for the children rather than employing a babysitter. 9. Father shall handle transportation for exchange of custody of the minor children until such time as mother obtains a vehicle that is in working order. At that time, the parties shall share transportation. BY THE COURT: '-L Judge M.L. Ebert Cc: Jessica Holst, Esquire ~ Jill HAmmill, Student Attorney (Cfff.~~ /h<.4.= i--..l f~O.J'Ot. 0-. -"",") " ! {> I ! ! t :j; , < q (' :', :". . ... JULIANNE MARIE GLASS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v : NO.05-6772 CIVIL ACTION - LAW CHRISTOPHER GLASS, Defendant IN CUSTODY Prior Judge: M.L. Ebert CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conclliator submits the following report: 1. The pertinent information pertAining to the children who are the subject of this litigation is as follows: Jordan Glass, born July 8, 1989 Leigha Glass, born May 11, 1991 Mackenziane Glass, born July 8, 1992 Courtnie Glass, born April 20, 1994 Alyssa Glass, born January 9, 1996 Mackayla Glass, born January 19, 1998 2. A Conciliation Conference was held on July 26, 2006, with the following individuals in attendance: The father, Christopher Glass, with his counsel Student Attorney, JilllfAmmill, and the Mother, JuliAnne Marie glass, with her counsel, Jessica Holst, Esquire. 2. The parties agreed to the entry of an Order in the form as attached. ,---)."")- t1P DATE ~ Hubert X. Gilroy, Esquire Custody Conclliator