HomeMy WebLinkAbout96-03235
JEFFREY R. STOCKDALE,
Plaintiff
vs.
AIMEE L. STOCKDALE.
Defendant
.
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION. LAW
NO. 96.3236 CIVIL TERM
IN CUSTODY
AND NOW, thl. ~.Y :;0..
the Concilistor's Report, it appearing that the pa
, 1 996, upon receipt of
. s have agreed to the terms and
provisions of this Order which was dictated in their presence and approved by them
and their counsel, it is hereby ordered and directed as follows:
1. The parties shall share legal custody of their minor child,
Britteny K. Stockdale, d.o.b. 29 June 1993.
2, Mother shall have primary physical custody of the minor
child subject to periods of partial custody and visitation with Father in
accordance with the fOllowing phase-in schedule:
A. On Sunday. 28 July 1996, and Sunday. 4 August
1996, from 9:00 a,m. until 8:00 p.m.
B, On 10 August and 11 August 1996, from 10:00
a.m, until 6:00 p.m.
C. On 24 August and 25 August 1996, from 10:00
a.m. until 6:00 p,m.
D. On 7 September and 8 September 1996, from 9:00
a,m. until 8:00 p.m.
E. On 21 September and 22 September 1996, from
9:00 a.m. until 8:00 p.m.
F. On 6 October 1996 at 9:00 a.m. until 6 October
1996 at 8:00 p.m,
G. On 19 October 1996 at 9:00 a.m. until 20 October
1996 at 8:00 p.m.
H. Beginning 2 November 1996, from Saturday at 9:00
a.m. until Monday at 12:00 noon,
This schedule will continue on an alternating weekend basis
such that Father will have the child on an alternating weekend
basis from Saturday at 9:00 a.m. until Monday at 12:00 noon.
I. Beginning with the week of 12 August 1996 and
every week thereafter, Father shall have the child for one day,
the time and date to be agreed upon by the parties.
3. The parties shall alternate the major holidays, those holidays
being defined as labor Day, Thanksgiving, Easter, Memorial Day, and
Fourth of July. These periods of partial custody and visitation will be
from 9:00 a,m. until 8:00 p.m., except that If they occur on a
Monday, then the party who Is entitled to exercise this period of
partial custody and visitation will be entitled to include the entire
weekend such that the party will have the child for a full weekend,
Including the holiday. This schadule shall start with Mother having
labor Day, 1996, and the schedula will alternate thereafter.
4. The Christmas holiday will be broken Into two segments.
Segment A will occur from Christmas Eve at 12:00 noon until
Christmas Day at 12:00 noon; Segment B will occur from Christmas
Day at 12:00 noon until 26 December at 12:00 noon. The parties
shall alternate this schedule whereby Mother will have Segment A In
1996 and all even-numbered years thereafter, and Segment B in 1997
and all odd-numbered years thereafter. Father shall have Segment A In
1997 In all odd-numbered years thereafter, and Segment B In 1996
and all even-numbered years thereafter. In addition, the parties agree
to evenly share the Christmas week not otherwise covered by
Segment A and Segment B. Tha Christmas week will be defined from
the period ending 26 December until New Year's Day.
5. Mother shall have the child on Mother's birthday, and Father
shall have the child on Father's birthday.
6. Mother shall have the child on Mother's Day, and Father will
have the child on Father's Day.
7. Father will ensure that he has appropriate sleeping
accommodations for the child.
8. Both partlea agree that they will not drink to excess while
the child Is In their custody.
9. Mother agrees that she will not relocate out of Pennsylvania
without prior Order of Court, and further agrees that she will not leeve
the child unattended with Craig.
J.
Sandra L, Mellton, Esquire
Attorney for Plaintiff
_ l'~ ~~ 8'/8/q~.
""If' - - "A, '61.
Joseph J. Dixon, Esquire
Attorney for Defendant
mlb
~:
1\,'
11 It) t
.:J
M "-'j
;)~
g :1:: :J~
u... .~~
() r- "-~~
B: I " .
lE c..'1 ,j
-, ~~
-
oU
\5 ~~ a ~~
C'b.
6. The Plaintiff's position on custody Is as follows: Plalntlf'lnltlally flied a
Petition for primary custody based upon an allagatlon that someone that the Mother
knew had Improper contact with the child. Plaintiff, however, was willing to
resolve the esse In accordance with the attached Order. provided that that
Invsstlgatlon continues to be unfounded, It should be noted that the Cumberland
County Children & Youth Indicated that ths allegation was unfounded. but the West
Shore Regional Pollee Is following through with their Investigation and as of the
date of the conciliation, had not rendered Its decision as to whether or not It would
move forward. In addition. the Fcther requested a significant block of time over
next summer, but since the parties were not able to agree at this point on that
schedule, the Conciliator suggested that we hold off on any determination about
next summer until some time In the spring,
6. The Defendant's position on cUlltody Is as follows: Mother beliaves that
the report Is unfounded and that she would never have the child In a situation that
would put the child in danger. She did agree to a phase-in schedule to get the child
accustomed to being with the Father. She could not make any decision as to next
summer because she wants to walt and see how the Father does with the phase-In
schsdule,
7. Need for separate counsel to represent child: None requested,
2
'.
.
8. Need for Independent psychological evaluation or counseling: Neither
party requested.
9. Other matters end comments: The parties were able to agree upon a
phase-In schedule which eventually will get the Father regular and consistent
contact with the child. The Conciliator believes that once this Is In place, the
parties will be able to work out any differences they may have concerning the
summer months or the custody schedule In general.
Date: 5 August 1996
"l ~.& .
;1 f/ 1 < / /
t"7 ),L./.' '...i )-,,/)
Michael L. Bangs
Custody Conciliator
3
, , "
:
J
, '.
!
, , >'
, j, 'I
( t.. '-
, I ,,)
LJ CJ
1Il
~
IU
o-l
Po ~ -
.... .... ><
Z ~ .... r.: r..
0.0: p: ..... nl H
~; r.. ... ....... '<1 P
F- o-l ~ . ~ 0
0 . ;? .0:.... ...OJ ~-: 'C.Il33I~~
Ul>' o-l .0; P nl o-J....
E. H .J 1<:'" . o<t:l!! 0 ~~~~~
~E5 ::- Up.. > PO ""
... 0 I<: 3 ~ ~
0 U E-< U :<:
1'-' u Z 1Il 0 0 '~ ~!S
2~ ,n 0 F' H
l', HI>o . III E-
t'. E-<O l>'. H ~
uot: In uo . ""
o-l I <'( [- l>' o-l I.L!
"'1>, It, Ul ... Ie
D: ~ ll' --,p PI ~l
[. ~ l....j CJ 10. I.',:
. > lu ..
:. 0 HZ IU ...
,.. U Z UH '" ..:
. ,II
,
.
.
iIM/li! .7: .V/'f/,/flll
i l U 2 2 2000 I JI )
. ,"'
,
-
,
.
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY , PENNSYLVANIA
NO, 96.3235 CIVIL TERM
JEFFREY R, STOCKDALE,
Plaintiff
AIMEE L. STOCKDALE,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this \', day of f(' h ,2000, upon consideration of the
allached complaint, it is hereby directed that the parties and their respective counsel appear
before"..hc.~C\'t'\ L, em}, the conciliator, at'~ ,,\, \R'V\,\-\-.)~on
the G-, day of ~n \ , 2000, atU.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 in to a temporary order, Either party may bring the child/children who is/are the subject
of the custody action to the conference, but the child's/children's allendance is not mandatory.
Failure to appear at the conference may provide grounds for entry of a temporary or permanent
order.
For the Court,
By:~ffiit~q\-oO ~:J ,{K\/~..:-
Custody Conciliator - I.J' t &..))
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 OFrICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
OFFICE 010' THE COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE, FOURTH FLOOR
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
JEFFREY R. STOCKDALE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
NO. 96-3235 CIVIL TERM
v,
AIMEE L. STOCKDALE,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
PETITION TO MODIFY
AND NOW, this ...!!J.J.J...J.lay of February 2000, the Defendant, Aimee L. Stockdale, by
and through her attorney, Austin F, Grogan, Esquire, avers the following:
1. The parties are the natural parents of Brittany K, Stockdale, born June 29, 1993;
2. A conference was held before the Conciliator, Michael L, Bangs, Esquire, on or
about July 24, 1996 at which point a custody schedule was agreed upon which was reduced to
an Order dated August 7, 1996 (copy attached);
3. Since the August 7, 1996 Order was placed into effect various issues regarding
the father's fitness to raise his daughter and to provide a safe environment have developed to
the point that the Defendant/Petitioner respectfully requests a new custody conference to limit
the father's time to supervised visitation.
WHEREFORE, the Defendant/Petitioner respectfully requests this Honorable Court to
schedule a Custody Conference and to narrow the issues for further Court review,
Date
,~0~)
,
.
", ' J t
~ f, '" ;J(;fJ)Il"jl< ,<--.
Austin F. Grogan,Esqllire
24 North 32nd Street ..
Camp Hill, PA 17011
(717) 737-1956
Allorney for Defendant
ID #59020
"
D, On 7 September and 8 September 1996, from 9:00
a,m, until 8:00 p,m,
E, On 21 September and 22 Septamber 1996, from
9:00 a,m, until 8:00 p.m,
F. On 6 October 1996 at 9:00 a,m. until 6 October
1996 at 8:00 p,m.
G, On 19 Octobar 1996 at 9:00 a,m, until 20 October
1996 at 8:00 p.m,
H, 8eglnnlng 2 Novamber 1996, from Saturday at 9:00
a,m. until Monday at 12:00 noon.
This schedule will continue on an alternating weekend basis
such'that Father will have the child on an elternatlng weekend
besls from Saturday at 9:00 a,m. until Mondey at 12:00 noon.
I. Beginning with the week of 12 August 1996 and
every week theraafter, Father shall have the child for one day,
the time and date to be agreed upon by the parties,
3, The parties shall alternate the malor holidays, those holidays
being defined as Labor Day, Thanksgiving, Eester, Memorial Day, and
Fourth of July, These periods of partial custody and visitation will be
from 9:00 o,m. until 8:00 p.m., except thot If they occur on a
Monday, then the party who Is entitled to exercise this period of
. ,
partial custody and visitation will be entitled to Include the entire
weekend such that the party will have the child (or a full weekend,
Including the holiday, This schedule shall start with Mother having
labor Day, 1996, and the schedule will alternate thereafter.
4. The Christmas holiday will be broken Into two segments,
Segment A will occur from Christmas Eve at 12:00 noon until
Christmas Day at 12:00 noon; Segment B will occur from Chrlstmes
Day at 12:00 noon unlil 26 December at .12:00 noon. The parties
shall alternate this schedule whereby Mo:her will heve Segment A In
1996 and all e,:,en-numbered yeers thereafter, and Segment B In 1997
and all odd-numbered years thereefter, Father shell have Segment A In
1997 111 all odd-numbered years thereafter, and Segment B In 1996
and all aven-numbered years thereafter. In addition, the parties agree
to evenly share the Christmas week not otherwise covered by
Segment A and Segment B. The Christmas week will be defined from
the period ending 26 December until New Year's Day.
5, Mother shall have the child on Mothar's birthday, and Father
shall have the child on Father's birthday.
6. Mother shall hava the child on Mother's Day, and Father will
have the child on Father's Day,
VERIPICATION
I, AIMEE L, STOCKDALE, certify that the statements made In the foregoing Petition to
Modify are true and correct to the best 01' my knowledge, Infonnatlon, and belief and that this
verification Is subject to the penalties of 18 Pa. C,S, Section 4904, relating to unsworn
falsification 10 authorities,
Date ,(( / !~) /~)D
~~ f{. i I ~<<j/~,
IMEE L, STOCKDALE ......
unl! j 'l ZOOIJt/)
-
JEFFREY R. STOCKDALE,
(,Ialntin'
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYL VANIA
NO, 96.3235 CIVIL TERM
CIVIL ACTION - LA W
IN CUSTODY
vs.
AIMEE L, STOCKDALE,
Delcndunl
OIWEI{
AND NOW this) b U, day of f\/i>.r-..L,
, 2000, It being reported to lhe
Conciliator that the parties have reuched un ugreelllent which Illukes lilrther proceedings
unnecessary, the undersigned Conciliulor hereby relinquishes jurisdiction and returns the mailer
to the Court Administrator, If either of the purtles wishes further proceedings in this uetlon, they
should petition the Court unew,
FOR 'HIE COURT,
~17.
. MICHAEL L. BANGS
Custody Conciliator
ee: Elizabeth S. Beckley, Esquire
Austin F, Grogan, Esquire
, .
.. ru r--;
I l,~ \...;
"
. ~(
, ,
.. , ..
" -!::1
,I in
l'l 'I:,'
" -',
(' :'il"il
~ , ~ t l..
".
, (-1 :-)
" I C) (.)
,90
-ii'
<)o~
-
rl
~
~ 0 1;: -1
&.n
I~ N 8~ \
x:
0... ~~~
~ r-- ~
I
~ ;I: b.1~
~ I()
@ -:: s:'
.'-
1,1., U) a
Cl en
~ ~ !-
~... r::.....
""I! --
jall"'!ii~
~n~J''''
~ . -
-... ...
j~j~1
~= I..
~ -
fu =
::c :c
6. During the parties' separation, Father has
consistently had custody of Brittany on a weekly basis, normally
on Sunday from 3:00 p.m. through 9:00 p.m.
7. Father and Mother would typically communicate via
telephone on a Friday or Saturday to confirm Father's weekly
custodial periods.
8. On Friday morning, May 31, 1996, Mother telephoned
Father in an urgent tone of vo~ce and left a message on his
answering machine indicated that it was very important for the
parties to meet that day and discuss a problem concerning their
daughter, Brittany.
9. Immediately after that message, Brittan~" s maternal
grandmother, Yvonne Davis, left a message on Father's answering
machine indicating that he should contact her immediately
concerning Brittany.
10. Father tried repeatedly on May 31, 1996 to reach
Mother by telephoning her home telephone number.
11. Father contacted Ms. Davis, on May 31, 1996 after
not being able to speak with Mother, and was advised by Ms. Davis
that an alleged child abuse incident had occurred against Brittany
and that Cumberland County Children and Youth Services was
commencing an investigation. She related the abuse situation as
follows:
a. During the week of May 20, 1996, when
Ms. Davis was getting Brittany ready for bed,
Brittany told Ms. Davis not to "scratch my
buttercup". It is alleged that "buttercup" is
Brittany's name for her vagina.
b, When Ms. Davis questioned Brittany
about this comment, Bri ttany indicated that
"Craig" scratched her buttercup.
12. It is alleged that Craig is a friend of Mother and
her boyfriend, Matthew Sullivan, and that Craig spends considerable
time at Mother's home.
13. It is alleged that Brittany was examined at the
Milton S. Hershey Medical Center on May 29, 1996 and that Mother
and Ms. Davis were present for the examination. Copies of the
medical records from said examination are attached hereto as
Exhibit "A".
14. It is Father's understanding that as a result of
this examination, the alleged child abuse incident was reported by
Hospital personnel to ChildLine for an investigation by Cumberland
County Children & Youth Services.
15. On May 31, 1996 and the early hours of June 1, 1996,
Father continued to attempt to contact Mother and finally learned
that she and her boyfriend, Matthew Sullivan, had left the
Commonwealth of Pennsylvania and were in the Commonwealth of
Virginia.
16. This information was obtained from a contact with
Matthew Sullivan's father; however, Father was refused any
additional information regarding Brittany's whereabouts.
17. At that point in time, Father retained Hepford,
Swartz & Morgan and an emergoncy petition w~s prepared alleging
that Mother had left the Commonwealth with the child; however,
prior to the filing of that document, Mother returned to
Pennsylvania and has resumed her residence with Matthew Sullivan
at 414 Meadow Drive, Riverview Heights, Camp Hill, Pennsylvania.
18. To Father's knowledge, Mother has returned to the
same environment in which the alleged abuse occurred and continues
to permit Brittany to have contact with the same individuals who
may have abused the child.
19. Mother fails to recognize the seriousness of the
incident and continues to allow Brittany contact with individuals
who could potentially have been the perpetrator of the alleged
abuse currently under investigation.
20. Further, Mother has already taken Brittany out of
the jurisdiction of the Commonwealth of Pennsylvania without
advising Father of her intention to do so and Father is concerned
that Mother may permanently leave the jurisdiction of the
Commonwealth of Pennsylvania without notice to him.
PENNSTATE
;; (;01le8e of Medicine
Unl.."iIY IImpilul ' Children', lIu'pilul
. The Millun S, lIer'hey Medicul Cenler
OObl1081
, .1
sraCKOAlE, 8R/TTAHT r
GbIZ'l1l 9')3 F
A X
AMBULATORY HEALTH VISIT
D Health Maintenance
Referred by/Address:
o Consultation
o Acute Care
-
,
I &ctYIfY)
SubJ.ctlv.
1. ~ ("r)Uf/1t i^ ~ ev~ i
2. to-w;,~ tt4"' ht1 h!J S / IA .
3. ~.
4.
5.
Signature
/fJSf,ihk ..f~u.d qlJlo-k-/
$e ~ c YLt'l1;... ~
ObJ.ctlv.:
Vital Signs: BP Pulse
Measurements: Weight I~ ,j-Kg It) % Length ~ 7 cm 7tJ
. I b:l
~L4h~~~' N~ '~e/;j~~~'P<~I/lAJJ7~.
~ "'A- G;Jt Pvf(IJ.. /V1l(5)
AJd Sff!1 Mj AI 0 (rrJ As .
~ ~ ~ 't.t.~IJ.)e,. I oM' JY'lNt~'" 1",C64...,..*-
....~r~.rr a~J1W.I-f~f-/ge.;'n M brt1A'J~ '
,
00 RD AxO
cm. %
Lab
A.....m.nt/DI.gno.I./PI.n A ~ +fA Ms./-"'-
1. Phr!1l~~ ~~n~ 1M) .~?
:: Pf5~ h~ M~ ~.,.. 6f'~ .nld
4.
5. t4tu /,{. e ~
NeKt vlsll:
SIGNATURE
cYt(7 ~be.'IIk4.
~
~
MA 187 4/85
AMBULATORY HEALTH VISIT
EXHIBIT "A"
ACrlCH rAllI...
"'" I'<'.-.I<:..~ 5/.1."/ fl.",
I!pa~ . _IN. ~
Ch-C:. c~~
ill
I Ii
g
ill
f!u
in
II.
irt
,.
,.
~
H~
Hi;
,. f~
Ujm
l~
~&t
7-
~
::6;"u....-L.'..~.. ~. ....u..'Yu.~
<"~... .' d~t.l - ..~(.-I ~l". (t.. k
a
!~ I
IIi
..k.~_
.....""',
PHAAY4CY ~. NO "" II..
I"..:..=... ..
S/~l'/t;l- P.
MUIAOI 111...1. IlOkArUAI.Tllll
- ~).t ~ J~
AlUMlfl
I
04/15/96
0945
University
CLINICAL
Hospital,
LABORATORY CUMULATIVE RESULTS REPORT
HMC, Hershey, Pa./ M.B.Bongiovanni,M.D"
Director
Page
1
Outpatient Final Cumulative
To Se Filed By. HIS/RHER
6710S7 STOCKDALE,BRITTANY K F 33M
..........................................................................................
Activity from. 02/29/96 to 02/29/96
..........................................................................................
..........................................................................................
Microbiology Direot Detection
Strep A
Antigen
02/29/96 1430
-------.------------------------------------------------------------------
Negative
,
04/15/96 0945 Outpatient Final CumUlative
671087 STOCKDALE, BRITTANY K END OF REPORT
Page
1
----.-....--......
Cumbertand County
Children & Youth
Services
~oI..m,,? ~II""""
&......~....., j7~
Agency
AdmlnIolralDt
lIoIyL"""".UW
~
"'R.~
Ilonoy A._
_L_
Sulle 200
Human Services Building
16 Wesl High Street
Carlisle, PA 17013-2961
(717) 240-6120
(717) 697-0371, Ext. 6120
(717) 532-7286, Ex!. 6120
May 29. 1996
Jpffrey Slockdale
6731 Evelyn Slreel, ApI. 3
1I.lrrlsburg,PA 17/01
RE. BrlllanySlodrdalo!
Dear Mr. Slockdole:
A report of suspecled child abuse concerning Ihe above named child has
been made 10 our Agency and Ihe Pennsylvania Deparlmenl of Public Welfare.
Under Ihe law. our Agency musl conducl an Invesllgallon 10 delermlne whelher
or nollhe child was abused Also, we are required bylaw 10 reporl cerlaln types
of suspecled abuse 10 Ihe police.
You are receiving Ihls leller because as Ihe subjecl of a suspecled child
abuse reparl, Ihalls. as a parenl aneVor alleged perpelralor of abuse o..flhe
above named child Ihe ChildProlecllve Services Loll' repSL) and Deparlment qf
Public Welfare regulallam require Ihe county children and youlh agency 10
n011fy all subjecls In a reparl of suspecled child abuse aboUllhe exlslence oflhe
reporl, Ihe nalure oflhe allegal/ons, Ihelr rlghllo receive a copy oflhe reporl.
Ihelr legal rlghls, Ihe possible Impact of a confirmed reporl onfuture
employment, and Ihe social services available 10 protect children,
The Agency Is required to complele the Investigation wi/hln 30 days
after the reporl Is received and delermlned If the report Is Hunfounded",
"indlcale"., or 'Jauncle(J': All ulifuunded repurl Is OIlY reparl in which Ihere is
no evidence of child abuse as defined by 11m law. An Indlcaled reporl Is a report
III which Ihe county agency determllle.r Ihallhe child was abused Afounded
reporlls a reporl in which a caurl delermllles Ihallhe child was abused
As a subjecl of the report. you may receive a copy of Ihe reporl by
wrlllllg 10 Ihls Agellcy or 10 Ihe ChlldLlne U1,d Abuse Reglslry, P. O. Box 2675,
lIarrlsburg,PA 17/05.2675.
rhe name of Ihe person who made Ihe report or allY olher person who
cooperaled in Ihe hlvesligalion /IIay nol be released excepl by Ihe Secrelary of
)>ublic Welfare uprm II'rlllen reqlle.rl. Such requesl.rhould be sent 10 Secrelary
(if Public Welfare ill care oflhe Chi/dUne alld Abll.\'e Regl.rlry. P. O. Box 2675,
IiClrri.l'burg.I'A 17105.2675.
Exhibi t '13"
Cumberland Coullly
Children and Youlh Services
Page 2
Iflhe reporl i.f delermined 10 be lIIifollllded. Ihe reporl will be expunged wi/hin 120 days from the
date the report was received by the Departmenl. However, If the investigation reveals that Ihe child and
family need social services provided by or arranged by our Agency, the records will be retained and
Indicate that the report of suspected child abuse was unfounded.
If the report Is determltled to be indlcaled, Ihe person responslblefor the abusl' may request tl/(/t
the report br. amended oJr expunged If he or she feel.f the r.'JX'rt Is not accurale. Suclr ri!quesls must be
made to the Secretary (If Public lYelfarc at the above addrcs.f within 4S days after being notified that tire
report Is Indicated.
Not all abuse matters go to Ju~'cnile Cuurt. HOlVev~r. where Ihere Is I/O ':/Jop"rallol1 tv ossure
safety of the child, Cumberland County Children and Youth Services will petition Juvenile Court. If the
case goes to Juvenile Court, you have the right to have an attorney, Introduce evidence and
cross-examIne witnesses. If you cannot afford an attorney, the Court may appolnl an aUomey to
represent you at no cost. If the Courtjlnds a perpetrator Is an abuser, thatjlndlng may not be appealed
to the Department of Public Welfare.
A person responsible for Ihe abuse In afounded report may not be employed In any child care
sen.'lce, publlc or private school, or be afoster or adoptive parent within jive (5) years of when the abuse
was committed.
A person convicted of any of the crimes llsud In Section 6344 of the Child Prote.:tlve Service
Law (SS Po. C,S.A. 96344) may never be employed In any child care service, publlc or private school, or
be afoster or adoptive parent.
The goal of our Agency Is to protect children from harm and where possible to keep them In their
own homes. To help parents and other caregivers to keep children In their own homes. our Agency
provides or arrangesfor social servlcesfor the child andfamlly. /wlll gladly discuss with you services
that are available.
If you have any questions during the Invesllgatlon, please call me. The Agency telephone
number Is 240-6120: 697-0371 ext. 6120 or 532-7286 ext. 6120.
Sincerely,
~~7;P4,
Kelly J. Milk;
Caseworker
/ acknowledge receipl of a copy of Ihis letter.
Signature: .....
Date:
CCC& YS I-II-A Rev. 3196
f {
~ ,... [; 1. $ "R_
.:t ~
.. :; 0 g
N i:l~ ';J-
fj :r. '~, lt) I..J ~ .'J
a.. :J trj ':t
~ trj r- ~
,.... '. ~ n ;t)
'I
I ...
~1I _. :1i I
f;!: co' ~ ~I
i?, !!,.] \I ~
~
u,. Ul ::i .,;I roC
0 en u eJ
.
.
~ !
j~ 1:!3
~~i~~~
.~~'~"'I
j~!~~
ciie I
DOl = t-
~-
fu =
::c :=
.
JUI,; 1 Q 199~
JEFFREY R. STOCKDALE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
NO. (11.,_ .3:,)3 '.5 ('
UI -ll..J) Te,l"'l
AIMEE L, STOCKDALE,
Defendant
IN CUSTODY
ORDER
AND NOW, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel
appear before lJJKSJ"/ .lih{H5 , Custody
Conciliator, on .the , , y of ,lll-t , 1996,
at 7? ..!:m, at Ol SovtJ, ji"~ +.' .
, Pennsylvan a,
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, at the request of either attorney or party,
be present at the Conference. Failure to appear at the Conference
may provide grounds for the entry of a temporary or permanent
Order.
If you fail to appear as provided by this Order, an Order
for custody may be entered against you or the Court may issue a
warrant for your arrest,
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.
Lawyer Referral Service
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6:<:00
FOR THE COURT:
Date:
(P/I,Vr,r,
I ,
~dii
Custod
Defendant and
Defendant's
Mother (Yvonne
Davis)
2333 Penn Street
Harrisburg, PA
2/96 - end of
3/96
Defendant and
Matthew Sullivan,
and Matthew
Sullivan's mother
Unknown address in
Camp Hill, PA
end of 3/96
- mid 4/96
Defendant and
Matthew Sullivan
414 Meadow Drive
Camp Hill, PA
mid 4/96 -
Present
The mother of the child is Aimee L. Stockdale, who
currently is residing at 414 Meadow Drive, Riverview Heights, Camp
Hill, Pennsylvania.
She is married.
The father of the child is Jeffrey R. Stockdale,
currently residing at 6731 Evelyn Street, Apartment 3, Harrisburg,
Pennsylvania.
He is married,
4. The relationship of Plaintiff to the child is that
of father. The Plaintiff currently resides with the following
persons:
Name
Relationship
Paul Stockdale
Brother
5. The relationship of Defendant to the child is that
of mother. Defendant currently resides with the following persons:
Name
Matthew Sullivan
Relationship
Friend
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 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:
a. While under the Defendant's supervision and
custody, the child is associating with individuals of
unsatisfactory character,
b. The Plaintiff is better able to serve the needs
of the minor child and to provide the love and affection
necessary for her physical, emotional and social well
being and growth.
B. 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.
WHEREFORE, Plaintiff requests the court to grant him
primary physical custody of the child to him with supervised visits
1n Defendant,
HEPFORD, SWARTZ & MORGAN
By, L""",j~
,/ Sandra L, 1 ton
P.O, Box 889
Harrisburg, PA 17108
(717) 234-4121
Attorneys for Plaintiff
VERIFICATION
I, Jeffrey R. Stockdale, acknowledge that the facts
stated in the within document are true and correct to the best of
my knowledge, information and belief.
I understand that any false statements herein are
made subject to the penalties of 18 Pa,C.S. Section 4904 relating
to unsworn falsification to authorities.
'~
Je~tockdale
DATED:
(p .. r;, - q&
~
~ Ii
o ~ ~
~~ !SE
ge~~~i~
.... 0 M ;0. "'"
~~.a~;::
.s~=d~~
(/)O~D;~O
ciz d
"':.: ~ to
~ ~
.. .
"' .
::c :c
\;)
j';: \.CI .-
.' u; ,..
j:; 0" ,.
~' ' ~ .-:t~
~.: :t: .)
~ \" ,...~
.i' .:.1: - :'4
C' ~: ~~:.i
It. n .~G
I I~.'
5:\: ' 1 d;(6
<",
r~.:. ::;; '.~ 1 C0l-
li- .0 :?
(,) u' u
-,
Z 1.67 5113 5e3
~. Receipt for
- Certified Mell
No InSUfO"":. Co~el8Ue Provided
"1=' 00 not UI. lor 1I11010lJllonll MI~I
ISee Rlverll}
~ '''''''Aimee L, Stockdale
~
11
~
g
~
!
~
'"".\
1'0 ~!\1'IIti".1t1'11 , FA 1701
I'nlt. .
ftttll',M$ ,,,.
~,"C"" O..Io~"V '..r
Hnlhcl.ll(Jot.It.t1yf.1I
H"'UU,tlll'lfll'fjl!.hO""'f1\1
I"Wlum' & tl.tll OUl,...,<1
AlIlulllfll'l.'lltShu""IfI\lluWtlum.
tl~". "1(1 AUlll,n..u'.Ad!j,en
1Il'''l''u'''Il' $
6f.u
Poitmal. Of U""
6/18/96
,.'"
:, .~';"I_I"'_-
.QomIlIoIO _.. 4" ond"".
I ."'~_ond_on"'_"lhIolDrm""""''''I1l...1h1t
.::.. J::_ 1O...1ronI................ or on'" _. _ - naI
I .="_R....,,__on..... 0.::'_"'__'
.'111I..................--..-... __ondll1ldlll
-
I
I Mrs. 'Aimee ~. Stoci~da1e
414 Meadow Drive
Riverview Heights
c~rnp Hill, PA 17011
111Io wlIh III rICIlYIh
following HrvIcIl (for In
,m IN):
I. [J AddrUHI"~
2. R,ItrIcIId D111V1/Y
ConIUt pol
"
Z 543 523
4b.' \'P'
o Regll1Ired
o Expllll MIll
o ReIun RIOIipIIor
7.0,1' IV
8. Add,,_', Add"
IJId IN" pMI)
I
..
PS Fann3"', OIcImbIr 1884
-
Ul ~
? 14
~~u
..l ~ E j
~>l ~ e ..
G ~ ~
~ 8 iii
~ ~
. .
"
~il" 11'1" 'n'" [,I.
'., I,. L.:. ~'.\ ,"
. .