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Home My WebLink About06-2384KITTY M. GLASSER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :No. OG- .2 3Sv' Civil Term DAVID E. GLASSER, : IN CUSTODY Defendant CUSTODY 1. Plaintiff is Kitty M. Glasser, currently resides at 219 N. West St., Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is David E. Glasser, who currently resides at 711 Bloserville Road, Newville, Pa. 17241. 3. Plaintiff is the mother of the following child and seeks custody of the following child: NAME DOB/AGE ADDRESS Donavan J. Glasser Mother and Father married on March 2, 2002- Mother has been the primary caretaker of the child and currently has primary physical custody of the child. September 28, 2002 (3) 219 N. West St. Carlisle, Pa. 17013. During the past five years, the children have resided with the following persons and at the following addresses: NAME ADDRESSES DATES Kitty M. Glasser David E. Glasser 711 Bloserville Rd. Newville, Pa. 17241. Birth to April 22, 2006. Kitty M. Glasser 219 N. West St. April 22, 2006 to present. Carlisle, Pa. 17013 The mother of the child is Kitty M. Glasser and she lives at 219 N. West St., Carlisle, Pa. 17013. She is married to: David E. Glasser. The father the children is David E. Glasser, and he currently resides at 711 Bloserville Rd., Newville, Pa. 17241. He is married to Kitty M. Glasser 4. The relationship of plaintiff to the children is that of Mother. The persons that the Plaintiff currently resides with are: the child. 5. The relationship of defendant to the child is that of Father. The Defendant currently resides alone 6. Plaintiff has 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 child pending in a court of this Commonwealth. Plaintiff does not know of a party to the proceedings who has physical custody of the child or anyone who 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: Mother has been the primary caretaker of the child since birth. The parties recently separated on Anil ')) ')0n4 „__ 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff requests the court to grant custody of the child. Respectfully submitted, Date: gDan. e Adams, Esquire No. 79465 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.s. §4904 relating to unsworn falsification to authorities. Date: y12?11o1. 1C? Glasser, Plaintiff C?? ??J v .? KITTY M. GLASSER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. DAVID E. GLASSER DEFENDANT 06-2384 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 04, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4tb Floor, Cumberland County Courthouse, Carlisle on Tuesday, June 06, 2006 at 9:30 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/ Jacqueline M. Verney, Esq. 1? y Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 G ito, vNvMASNN3d z I .h W8 S- Ow 9002 AEMl ??L??'?Q31l3111 d0 3 JUN 1 6 2006 KITTY M. GLASSER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-2384 CIVIL ACTION - LAW DAVID E. GLASSER, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 1-2* day of -9 0 t3 f, , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Kitty M. Glasser and the Father, David E. Glasser, shall have shared legal custody of Donavan J. Glasser, born September 28, 2002. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and 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 reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any' reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. Mother shall have primary physical custody of the child. 3. Father shall have the following periods of partial physical custody: A. Alternating on a weekly basis, Friday at 6:00 p.m. to Tuesday at 9:00 p.m. B. On the off week, Monday at 6:00 p.m. to Tuesday at 9:00 p.m. 4. Holidays: A. Mother's Day/Father's Day. Mother shall have physical custody of the child on Mother's Day from 9:00 a.m. to 9:00 p.m. Father shall have physical custody of the child on Father's Day from 9:00 a.m. to 9:00 P.M. B. Memorial Day, July 4m and Labor Day. The parties shall alternate these holidays from 9:00 a.m. to 9:00 p.m. Father shall have July 4`h 2006. C. Thanksgiving. Mother shall always have physical custody of the child from 9:00 a.m. to 3:00 p.m. and Father shall always have physical custody of the child from 3:00 p.m. to 9:00 p.m. D. Christmas shall be divided into two Blocks. Block A shall be from 12:00 noon on Christmas Eve to 12:00 noon on Christmas Day. Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in even numbered years and Block B in odd numbered years. Father shall have Block A in odd numbered years and Block B in even numbered years. E. Easter shall be divided into two Blocks. Block A shall be from Saturday at 12:00 noon to Easter Sunday at 12:00 noon. Block B shall be from 12:00 noon Easter Sunday to Easter Monday at 12:00 noon. Father shall have Block A in odd numbered years and Block B in even numbered years. Mother shall have Block A in even numbered years and Block B in odd numbered years. F. Child's birthday. Each party shall have at least a two hour block of time with the child on the child's birthday. 5. Transportation shall be shared such that the receiving party shall transport. 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, c5;,d'ane Adams, Esquire, Counsel for Mother /ane Alexander, Esquire, Counsel for Father J `oo A Lz i1: GR KITTY M. GLASSER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-2384 CIVIL ACTION - LAW DAVID E. GLASSER, Defendant : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Donavan J. Glasser September 28, 2002 Mother 2. A Conciliation Conference was held in this matter on June 15, 2006, with the following in attendance: The Mother, Kitty M. Glasser, with her counsel, Jane Adams, Esquire, and the Father, David E. Glasser, with his counsel, Jane Alexander, Esquire. The parties agreed to an Order in the form as attached. Date cq ine M. Verney, Esquire Custody Conciliator KITTY M. GLASSER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA I W : No. 06 - 2384 Civil Term DAVID E. GLASSER, : IN CUSTODY Defendant PETITION FOR MODIFICATION 1. Plaint ff is Kitty M. Glasser, (hereinafter referred to as "Mother"), who currently resides at 219 N. West St., Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defen ant is David E. Glasser, (hereinafter referred to as "Father"), who currently resides at 711 Bloserviile Road, Newville, Cumberland County, Pennsylvania, 17241. 3. The parties were married on March 2, 2002. They were separated on April 22, 2006 and a divorce is currently pending. 4. PlaintiO, and Defendant are the natural parents of the following children: NAME Donavan J. Glasser Madison Glasser DATE OF BIRTH September 28, 2002 (6) November 8, 2006 (1) 5. A custody order was entered June 27, 2006, a copy of which is attached as Exhibit A. 6. Since the last custody Order was entered, born. 7. The p?rties' older child, Donavan Glasser, fail of 2008. the couple's second child was will be starting Kindergarten in the 8. The current custody schedule would be disruptive during the school year. il? 9. Due o these change in circumstances, Mother is requesting that the current custody schedu a be modified. WHEREFORE, Plaintiff requests the court to modify the custody order regarding the children. Date: 5/0 Respectfully submitted, e Adams, Esquire I No.79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF .JLJN I o ; 006 i KITTY 1V. GLASSER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006-2384 CIVIL ACTION - LAW DAVID E. GLASSER, Defendant IN CUSTODY ORDER OF COURT AND NOW, this ? day o , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Kitty M. Glasser and the Father, David E. Glasser, shall have shared le0al custody of Donavan J. Glasser, born September 28, 2002. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergenc? decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and 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 reasonable time as to make the records aiid information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete infonnation from any physician, dentist, teacher or authority and copies of any reports gNen to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2 Mother shall have primary physical custody of the child. 3 Father shall have the following periods of partial physical custody: A. Alternating on a weekly basis, Friday at 6:00 p.m. to Tuesday at 9:00 p.m. B. On the off week, Monday at 6:00 p.m. to Tuesday at 9:00 p.m. Holidays: - ?Xwg -11 A. Mother's Day/Father's Day. Mother shall have physical custody of the child on Mother's Day from 9:00 a.m. to 9:00 p.m. Father shall have physical custody of the child on Father's Day from 9:00 a.m. to 9:00 P.M. B. Memorial Day, July 4`" and Labor Day. The parties shall alternate these holidays from 9:00 a.m. to 9:00 p.m. Father shall have July 4`h 2006. C. Thanksgiving. Mother shall always have physical custody of the child from 9:00 a.m. to 3:00 p.m. and Father shall always have physical custody of the child from 3:00 p.m. to 9:00 p.m. D. Christmas shall be divided into two Blocks. Block A shall be from 12:00 noon on Christmas Eve to 12:00 noon on Christmas Day. Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in even numbered years and Block B in odd numbered years. Father shall have Block A in odd numbered years and Block B in even numbered years. E. Easter shall be divided into two Blocks. Block A shall be from Saturday at 12:00 noon to Easter Sunday at 12:00 noon. Block B shall be from 12:00 noon Easter Sunday to Easter Monday at 12:00 noon. Father shall have Block A in odd numbered years and Block B in even numbered years. Mother shall have Block A in even numbered years and Block B in odd numbered years. F. Child's birthday. Each party shall have at least a two hour block of time with the child on the child's birthday. Transportation shall be shared such that the receiving party shall transport. 6. This. Order is entered pursuant to an agreement of the parties at a Custody Clonciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, '9 ,, - A - - - 1 J. ?I cc: Jane dams, Esquire, Counsel for Mother Jane A exander, Esquire, Counsel for Father I? TRUE COPY FROM RECORD In i : s ' ??any whereof, f here unto set my hadd 4and sal f said urt gU?rlisle, . h' d of .... ? T .. aY .. i KITTY N?. GLASSER, Plaintiff V. DAVID E? GLASSER, Defendant PRIOR DODGE: None CUSTODY CONCILIATION SUMMARY REPORT IN CCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 19153-8, the undersigned Custody Conciliator submits the following report: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-2384 CIVIL ACTION - LAW IN CUSTODY I. The pertinent inforniation concerning the Child who is the subject of this litigation is'? as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Donavan J.il Glasser September 28, 2002 Mother 2. A Conciliation Conference was held in this matter on June 15, 2006, with the followhi g in attendance: The Mother, Kitty M. Glasser, with her counsel, Jane Adams, Esquire, and the Father, David E. Glasser, with his counsel, Jane Alexander, Esquire. ;. The parties agreed to an Order in the form as attached. Mcqu ine M. Verney, Esquire Custody Conciliator VERIFICATIO I verify that the statements made in this PETtrIo,,S are true and correct. I understand tha? false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 elating to unsworn falsification to authorities. Date:,-) Z ZGGII Plaintiff v .? o v s e v ? IXI s KITTY M. GLASSER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. DAVID E. GLASSER DEFENDANT 2006-2384 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, July 28, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, August 26, 2008 at 9:30 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. 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ acqueline Al. Verney, Es Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 op- ?t 1 %p 2 6 2008 C KITTY M. GLASSER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-2384 CIVIL ACTION - LAW DAVID E. GLASSER, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 11 ( _ day of C CA bar , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated June 27, 2006 shall remain in full force and effect except as modified hereinafter. 2. The Mother, Kitty M. Glasser and the Father, David E. Glasser, shall have shared legal custody of Donavan J. Glasser, born September 28, 2002 and Madison Glasser, born November 8, 2006. 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. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the children and 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 reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 3. The physical custody schedule for Donavan shall remain the same except the return time shall be 8:00 p.m. 4. Mother shall have primary physical custody of Madison. 5. Father shall have periods of partial physical custody of Madison on alternating weekends from Friday at 6:00 p.m. to Sunday at 8:00 p.m. and every Tuesday from after work to 8:00 p.m. 6. All other provisions of the Order of Court dated June 27, 2006 shall apply to Madison. 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 is scheduled for Monday, November 24, 2008 at 9:30 a.m. BY THE COURT, ?* I ?AA\ I M.L. Ebert, Jr., J. cc: Jane Adams, Esquire, Counsel for Mother David E. Glasser, pro se "2", / 0 , 0 r - ?? 711 Blosserville Road Newville, PA 17241 41 I?j Z Z '6 V 1-100 OOOZ 0.0 KITTY M. GLASSER, Plaintiff V. DAVID E. GLASSER, Defendant PRIOR JUDGE: M.L. Ebert, 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: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006-2384 CIVIL ACTION - LAW : IN CUSTODY 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Donavan J. Glasser Madison Glasser September 28, 2002 November 8, 2006 Mother Mother 2. A Conciliation Conference was held in this matter on September 25, 2008, with the following in attendance: The Mother, Kitty M. Glasser, with her counsel, Jane Adams, Esquire, and the Father, David E. Glasser, pro se. 3. The Honorable M.L. Ebert, Jr. entered an Order of Court dated June 27, 2006 regarding Donavan J. Glasser, providing for shared legal custody and Mother having primary physical custody with Father having five overnights every two weeks. 4. The parties agreed to an Order in the form as attached. S7- Date ?- Date cq ine M. Verney, Esquire Custody Conciliator SEP 1 A 2009 G? KITTY M. GLASSER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-2384 CIVIL ACTION - LAW DAVID E. GLASSER, . Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 10`h day of September, 2009, ninety days having passed and neither party having requested a Conciliation Conference, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, '4 V 14cq&4ine M. Verney, Esquire, Cu dy Conciliator FILEG-4a.-F1CE OF THE P, ,r?-, o?c T Ajgy 2009 SEP 14 PM 2: 2 7