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HomeMy WebLinkAbout00-03523LISA E. PAIGE-STONE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW DAVID H. STONE, NO. 00-3523 Defendant CIVIL ACTION - LAW IN DIVORCE RESUMPTION OF PRIOR NAME WHEREAS, a divorce decree was entered to the above action on March 25, 2003;and WHEREAS, Lisa E. Paige-Stone desires to resume her prior surname pursuant to 54 PACS Section 704(a); and WHEREAS, this notification is being filed pursuant to said statute. Lisa E. Paige-Stone is hereby resuming her prior name of Lisa E. Paige. L sa E. Paige-Stone Lisa E. Paige February 9, 2005 COMMONWEALTH OF PENNSYLVANIA, COUNTY OF )SS BE IT REMEMBERED, that on 9-005, before me the subscriber personally appeared Lisa E. Paige, also known as Lisa E. Paige-Stone, known to me (or satisfactorily proven) to be the person, whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. WITNESS my hand and seal the day and year aforesaid. nL Noty blic NOTARIAL SEAL JODY GOLDRING, Notary Public Cfly of Haztisbut0, Dat?htn Co., PA My Comrtnssion hires Nov. 03, 2005 C7 4_ N O c F , films C : ?C r vm 6 r) .m bi ca a j? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY V?k STATE OF PENNA. LISA E. PAIGE-STONE, r_ Plaintiff VERSUS DAVID H. STONE, Defendant No. 00-3523 DECREE IN DIVORCE AND NOW, DECREED THAT AND LISA E. PAIGE-STONE DAVID H. STONE ARE DIVORCED FROM THE BONDS OF MATRIMONY. IT IS ORDERED AND , PLAINTIFF, ,DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; ATTEST: D J . i PROTHONOTARY m &uk a.5e " . .. .. ?? a? .03 ?? ?ti??? ?, f1\div\1fransmitpraecipe\7-97 LISA E. PAIGE-STONE, Plaintiff V. DAVID H. STONE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-3523 CIVIL TERM : ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under § (3301(c)) 88dpct#c$ of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: June 15. 2000. US Certified Mail. Return Receipt Request. Restricted Delivery, postage prepaid 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by § 3301 (c) of the Divorce Code: by Plaintiff march 17. 2003 by Defendant March 17. 2003 (b)(1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: (2) A. Date of filing of Plaintiff's affidavit upon respondent: 4. Related claims pending: NO CLAIM RAISED 5. Complete. either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: '-a l-?3 Date Defendant's Waiver of Notice in 3301(c) the Prothonotary: _95-a-1-'la2 Attorney fo ELIZABETH Supreme C?a B. Date of service of Plaintiff's affidavit upon respondent: vorce was filed with FF) (D?ZFENDANT) = ' r , z yr= LISA E. PAIGE-STONE, Plaintiff V. IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW " - ,3.S.13CIVIL TERM DAVID H. STONE, Defendant IN DIVORCE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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. LISA E. PAIGE-STONE, Plaintiff V. DAVID H. STONE, Defendant IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c) OF THE DIVORCE CODE NOW comes the plaintiff, Lisa E. Paige-Stone, by her attorney, Marcus A. McKnight, III, Esquire, and files this Complaint in Divorce against the defendant, David H. Stone, representing as follows: 1. The plaintiff is Lisa E. Paige-Stone, an adult individual residing at 232 Poplar Avenue, New Cumberland, Cumberland County, Pennsylvania 17070. 2. The defendant is David H. Stone, an adult individual residing at 232 Poplar Avenue, New Cumberland, Cumberland County, Pennsylvania 17070. 3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on August 13, 1983, in Massachusetts. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ft - 35'x? CIVIL TERM 5. There have been no prior actions of divorce or for annulment between the parties. 6. There was three (3) children born to this marriage, namely, Anne Elizabeth Paige-Stone, born July 6, 1988, Sophie Kathryn Paige Stone, born November 5, 1991, and Peter Grissinger Stone, born May17, 1993. 7. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 8. The plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. Respectfully submitted, IRWIN, MS,INIIGHT & HUGHES By: for Plaintiff West Pomfret Profession Building 60 West Po treet Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court Y.D. No. 25476 Date: June 9, 2000 VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. 4A":?. &Paq'i LISA E. PAIGE-STONE Date June 9, 2000 LISA E. PAIGE-STONE, Plaintiff V. DAVID H. STONE, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW h _ 35.23 CIVIL TERM Defendant IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. Date: June 9, 2000 - LISA E. PAIGE-STON16 m a{ -? z r? i Yi? -'7 LISA E. PAIGE-STONE, Plaintiff V. DAVID H. STONE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 00-3523 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(0 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: AND NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the captioned action in divorce. 2. That he served a certified copy of the Complaint in Divorce upon the defendant on June 15, 2000, b . certified mail, "restricted delivery" addressed to him at 232 Poplar Avenue, New Cum er and, Pennsylvania, with Return Receipt No. Z 166 670 552. 3. That the said receipt for certified mail is signed and is attached hereto and made a part hereof. I verify that the statements made in this affidavit statements herein are made subject to the penalties of 18 falsification to authorities. i re e an d correct. I understand that false PW- (Marcus ating to unworn A. Attorney f Date: June 19, 2000 mli? Z 166 670 552 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. > 0 .C a C a a C ii Do not use for International Mail See reverse SBmto AVID H STONE;4SQ ?roR Aqm Postage $ Certified Fee i Restricted Delivery Fee Return Receipt g Whom 8 Date Delivered Realm Recdpt5ho+ririgp ` , as Date,BAddreasee's Ad&eu- TDTAL Postage & Fees Is 6,17 Pmshi r a Date STONE, LISA 06/13/00 Nam 4 if Restricted Delivery is desired. 0 ftnt your m itme and address on the reverse so that we can return the card to you. ¦ Attach,this card to the back of the mallpiece, ., or on the front if space permits. 1. Article Addressed to: - DAVID H STONE ESQ 232 POPLAR AVENUE NEW CUMBERT-AND PA 17070 A. x SkXWAUQL 0 Agent D. Is deI0GMaddreTs cliff4ent from Rem 1? ? Yes If YES, enter delivery address below: 0 No 3. Service Type M Certified Mail 0 Express Mail - 0 Registered ? Return Receipt for Merchandise 'f# Deliverv? ' -Fee - f yes 2. Article Number (Copy from service label) Z lk6 6 0. 55? r.If 4f d £ si r 3 ? ' PS Form 11159 1 ' gomastic Return Receipt 102595-99-M-179e z u,s; - ?c fl\div\lconsentaffidavit LISA E. PAIGE-STONE Plaintiff v. DAVID H. STONE Defendant : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-3523 CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on June 9, 2000, and served June 15, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint and service of the complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit 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 falsifica- tion to authorities. I Date x ?yi, Defendant ?-; c- ?;' _, ???`' ?;,?_ -- - ,_ ?` ??. Y ` ' --? ? - ?'r` _•' -3 f1\div\1.aiv...otice LISA E. PAIGE-STONE, Plaintiff v. DAVID H. STONE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-3523 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit 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 falsifica- tion to authorities. Date D D . S ON Defendant ?? ?;; _41., _- _ m?; :? ?, .? ?` ?.- _- ??- - _ - ?? _. ?'' ??_ y c .. _ != J = 1 .a{ fl\div\lwaivernotice LISA E. PAIGE-STONE, Plaintiff V. DAVID H. STONE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-3523 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER § 3301(0) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit 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 falsifica- tion to authorities. Date LISA E. PAIGE- TONE, Plaintiff C,x co .. f fl\div\lconsentaffidavit LISA E. PAIGE-STONE : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-3523 DAVID H. STONE Defendant CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on June 9, 2000, and served June 15, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint and service of the complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit 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 falsifica- tion to authorities. Z&Aa-_ /9; go CO Date Plaintiff/Fftefmn w,& C v> n .w7 LISA E. PAIGE-STONE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. DAVID H. STONE DEFENDANT 00-3523 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, this 26th day of January , 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear beforeJacqueline M. Verney, Esq. , the conciliat at 4th Floor, Cumberland County Courthouse, Carlisle on the 28th day of Feburary , 2001, at 1:30 p.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 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. FOR THE COURT, By: /s/ Jacqueline M. Verne, Eso? Custody Conciliator N The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 It jt'2S13 ?lf'?"r' C(jLr J Co rV PENNSYLVAI, IA 'N ? V LISA E. PAIGE-STONE, Plaintiff/Petitioner V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 00-3523 CIVIL TERM DAVID H. STONE, Defendant/Respondent IN CUSTODY ORDER OF COURT AND NOW, this day of 2001, in consideration of the attached petition, it is hereby directed that the parties and their respective counsel appear before Esquire, the conciliator, at on the- day of 2001 at _.m. for a Pre-hearing Custody Conference. At such conference, 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 this conference may provide grounds for entry of a temporary or permanent order. By the Court, Custody Conciliator 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. Court Administrator Cumberland County Courthouse 1 Courthouse Square Carlisle, Pennsylvania 17013 (717) 240-6200 AMERICANS WITH DISABILTTIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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. LISA E. PAIGE-STONE, Plaintiff/Petitioner V. DAVID H. STONE, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 00-3523 CIVIL TERM IN CUSTODY AND NOW comes the Petitioner, Lisa E. Paige-Stone, by her attorneys, Irwin, McKnight & Hughes, and presents the following Petition for Custody. 1. The Petitioner is Lisa E. Paige-Stone, an adult individual residing at 109 North 30th Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Respondent is David H. Stone, an adult individual residing at 232 Poplar Avenue, New Cumberland, Pennsylvania 17070. 3. The parties are the natural parents of three children, namely, Anne Elizabeth Paige Stone, born July 6, 1988, Sophie Kathryn Paige Stone, born November 5, 1991, and Peter Grissinger Stone, born May 17, 1993. 4. Petitioner desires primary physical custody of the children and joint legal custody with periods of visitation to respondent as the parties agree is appropriate and in the best interest of the children. 5. The best interest of the children requires that the court grant the petitioner's request as set forth above. WHEREFORE, petitioner respectfully seeks the entry of an Order of Court seeking primary physical custody of the children and joint legal custody with periods of visitation to respondent as listed above. Respectfully HUGHES By: Marcul A. McKnigk4jg, Esquire Attorney for Petitioner 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Date: January 19, 2001 VERIFICATION The foregoing Petition is based upon information which has been gathered by my counsel and me in the preparation of this action. I have read the statements made in this Petition and they are true and correct to the best of my lmowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unworn falsification to authorities. 5?.G9GC? cif l.Lc LISA E. PAIGE-STO?it Date: January I9 , 2001 C tom? G 'C7Cs1 f1-t ?,-, ? :: -! Z2 :L P=ai K LISA E. PAIGE-STONE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CUSTODY NO. 00-3523 DAVID H. STONE CIVIL ACTION - LAW Defendant IN CUSTODY PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY OF SAID COURT: Please enter my appearance on behalf of the Defendant, David H. Stone in the above-captioned matter. Respectfully submitted, C Laurie A.-Sa4tz?iver,`E MEYERS, DESFOR, SALTZGI & BOYLE Attorney I.D. #61382 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for Defendant MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX(717)236-2817 LISA E. PAIGE-STONE, Plaintiff VS. DAVID H. STONE Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CUSTODY NO. 00-3523 CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE I hereby certify on this 2? day of February, 2001, that a copy of the foregoing Praecipe to Enter Appearance was mailed, first-class, postage pre-paid to: Marcus A. McKnight, III IRWIN, McKNIGHT & HUGHES West Pomfret Professional Building 60 West Pomfret Street Carlisle,1PA 17013-3222 Laur14 A. Sai\tz ver, Attorney for Def ndar. MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 V17)236-9428 • FAX(717)236-2817 . %4 ! T APR 2 0 2001 LISA E. PAIGE-STONE, Plaintiff V. DAVID H. STONE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA NO. 2000-3523 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this `? 30( day of _ 2001, upon consideration of the attached Custody Conciliation Report, the attached Custody Agreement is hereby made an Order of Court. BY THE C J. or AlED-,DFFCE w raw 0I APP 24 API 8: 32 CUMEERL,44\'D COUNTY PENNXVI Wi? S j. M Cr y '? r Y f1\cust\pgestone.agr CUSTODY AGREEMENT FOR MINOR CHILDREN This custody agreement is entered into this 11 day of 2001, between LISA E.PAIGE-STONE, hereinafter referre to as the "Mother" and, DAVID HEAN STONE, hereinafter referred to as the "Father". W I T N E S S E T H: WHEREAS, the parties herein desire to set their intentions with respect to custody of the minor children, ANNE ELIZABETH PAIGE STONE, SOPHIE KATHRYN PAIGE STONE, AND PETER GRISSINGER STONE in writing, WHEREAS, three children were born of the relationship, ANNE ELIZABETH PAIGE STONE, born July 6, 1988, SOPHIE KATHRYN PAIGE STONE, born November 5, 1992, and PETER GRISSINGER STONE, born May 17, 1993; WHEREAS, it is the desire of the parties hereto to formalize their agreement with respect to the said minor children when they reside with them; AND NOW THEREFORE, the parties hereto intending to be legally bound hereby do agree that: 1. Both Mother and Father shall share legal and physical custody of the minor children. 2. During the school year the parties agree that they shall observe the following schedule: -1- I A. Mother shall have physical custody of the Annie and Sophie from Sunday through Wednesday and of Peter from Sunday through Tuesday. B. Father shall have nighttime visitation of Annie and Sophie on Wednesday night. C. Father shall have physical custody of Peter from Wednesday through Saturday. D. Father shall have physical custody of Annie and Sophie from Thursday through Saturday'. E. The parties shall rotate the custody of the children every other Saturday overnight. 3. Holidays shall be agreed by the parties so long as each party enjoys custody of the all three children equally throughout the holiday period. 4. During the summer school vacation, the parties shall have equal shared custody so as to best accommodate the parties' work and vacation schedules. Mother and Father shall be entitled to not less than two weeks vacation in the summer with all three children. These weeks do not need to be taken consecutively. In addition, it is anticipated that each party may enjoy long weekends with the children as the parties may agree. 5. Both parties agree to consult one another whenever a life decision is necessary with regard to the children. Life decisions affect medical, dental, orthodontia, religious, or moral decisions. Both parties agree to consult with one another whenever prudent. 6. Both parties agree that they shall always provide the other party with address, phone number, and or vacation location, when necessary. -2- 7. Both parties agree to be as flexible as possible, whenever possible, and to always place the best interest of their child first. 8. Father agrees to maintain the children on his health coverage and if, and when necessary, Mother agrees that if Mother's employment offers family coverage with no additional, or minimal cost, agrees to add the children as secondary coverage to her policy. 9. All unreimbursed medical bills, including, but not limited to, orthodontia, chiropractic, dental, and vision will be shared equally by the parties. 10. The parties agree that neither party shall be permitted to relocate with the children outside the state of Pennsylvania. 11. This agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of the execution of this agreement. Moreover, the parties hereby agree that the provisions of this agreement shall be entered as a custody order in the Court of Common Pleas of Cumberland County, Pennsylvania. IN WITNESS WHEREOF, the parties hereto intending to be legally bound have set their hands and seals on the date first above written. a (SEAL) LISA E.PAIGE STONE (SEAL) -3- COMMONWEALTH OF PENNSYLVANIA COUNTY OF d&nij ? H S t SS: DAVID HEAN STONE, being duly sworn according to law, deposes and says that he is a party named in the foregoing Custody Agreement for Minor Children and that he has executed the same for the purposes therein contained. DA S ONE SWORN TO AND SUBSCRIBED befo e me t is day of 2001. NIL AL Notary Public i PATRICHIA LTYOTER Notary Public New Cumberland Boro, Cumberland Co. My commission Expires Nov. 18, 2002 COMMONWEALTH OF PENNSYLVANIA ss COUNTY C>? m 4b a^ ? ) OF ) LISA E.PAIGE STONE, being duly sworn according to law, deposes and says that she is a party named in the foregoing Custody Agreement for Minor Children and that she has executed the same for the purposes therein contained. SWORN TO AND SUBSC ED before me this ay of 2001. Not ry Publi LISA PAIGE STON Notarial Seal Martha L. Noel, NotaryPublic Carlisle Boro, Cumberland County My Commission Expires Sept. 18, 2003 Member, Pennsylvania Association of Notaries -4- ?i APR 2 0 2001 ? LISA E. PAIGE-STINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. DAVID H. STONE, Defendant PRIOR JUDGE: None 2000-3523 CIVIL TERM : CIVIL ACTION -LAW : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Anne Elizabeth Paige Stone July 6, 1988 Shared Sophie Kathryn Paige Stone November 5, 1992 Shared Peter Grissinger Stone May 17, 1993 Shared 2. A Conciliation Conference was scheduled in this matter on April 18, 2001. The Conciliator was notified at 10:00 a.m. on April 18, 2001 that the parties had entered into a signed custody agreement and that they wanted it to be entered as an Order of Court. 3 An Order in the form attached was requested by the parties. 4-t r-6 Date ??? % , cq ine M. Verney, Esquire Custody Conciliator LISA E. PAIGE-STONE, Plaintiff V. DAVID H. STONE, Defendant PRIOR JUDGE: None ? Y APR 2 0 Mi : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA . 2000-3523 CIVIL TERM : CIVIL ACTION -LAW : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Anne Elizabeth Paige Stone July 6, 1988 Shared Sophie Kathryn Paige Stone November 5, 1992 Shared Peter Grissinger Stone May 17, 1993 Shared 2. A Conciliation Conference was scheduled in this matter on April 18, 2001. The Conciliator was notified at 10:00 a.m. on April 18, 2001 that the parties had entered into a signed custody agreement and that they wanted it to be entered as an Order of Court. 3. An Order in the form attached was requested by the parties. Date que e M. Verney, Esquire O Custody Conciliator - - 7" 2A/9 DEED-Trustees' Covenant - borporatloo - Individual Printed for and Sold by John C. Cie& Co.. 1326 Walnut St. Phila. ? ? u?euture ma., ? 11th day of June in the year of our Lord one thousand nine hundred and severity-=nine(19 79) 19VtweVn CCNB BANK, N.A., formerly Cumberland County National Bank and Trust Company, a corporation organized and existing under the laws of the United States of America, having its principal place of business in the Borough of New Cumberland, Cumberland County, ll?tTn>}aylyaniayNSnvaNia F,a ?. '.eyl@r, Recorder, do hereby i . Wol the foregoing its a true and _-A N D- cop a' a page(' Y?'d1 , ptness my h°ha'nd Hi ial seal this EDWARD L. KEYS and SHIRLEY I. KEYS, his wife, parties o a of? O _ ..yy.. v Recorder o Deeds of the other part, ?jtZtV99Vt# That the said parties of th`f' irP§ tp ia%1atMonday, anuary for and in consideration of the sum of One ($1.00) DOLLAR lawful money of the United States of America, unto them , well and truly paid by the said parties of the second part at and before the sealing and delivery of these presents, the receipt whereof is hereby acknowledged, granted, bargained, sold, aliened, onfeoff4 released and confirmed and by these presents grant, bargain, sell, alien, enfeoff, release and confirm unto the said and assigns, ALL THOSE CERTAIN lots or pieces of land, with the buildings and improve- ments thereon erected, situate in the Borough of West Fairview, Cumberland County, Pennsylvania, bounded and described in accordance with a survey by Ernest J. Walker, Professional Engineer, dated April 14, 1975, as follows: TRACT NO. 1-BEGINNING at a point in the center line of North Front Street, w poin is at the center of a partition wall between premises 692 and 694 North Front Street, said point being also distant South 24 degrees 40 minutes East 40.51 feet from the Southerly line of Fairmont Street; thence ,through the center of a partition wall and beyond South 56 degrees 24 min- utes West 144.02 feet to a stake on the Easterly line of a 16 feet wide public alley; thence along the same North 24 degrees 40 minutes West 35.72 !feet to a point on the Southerly line of Fairmont Street; thence along same North 64 degrees 30 minutes ESt 144.02 feet to an iron pin in the centerline ofNorth Front Street;/Rence North 71 degrees East 131 feet to a point on the Westerly line of Susquehanna River; thence along same South 22 degrees East 54.48 feet to a point; thence South 65 degrees 20 minutes West 129.55 feet to a point, the place of BEGINNING. TRACT NO. 2- BEGINNING at a point on the Westerly line of the 16 feet wide alley referred to in Tract- No. 1 hereinabove set forth and the Southerly line of Fairmont Street; thence along the Westerly line of said 16 feet wide alley South 24 degrees 40 minutes East 62 feet to a stake at the Northerly line of land now or late of Mrs. Bertha Keys; thence along same South 64 degrees 30 minutes West 115.76 feet to a stake; thence North 29 degrees 30 minutes West 62.14 feet to a stake on the Southerly s Dthence North 21 degrees 5 minutes West.26.91.feet to a point; EXHIMT BOOK /1 28 PACE 648 1 Fairmont Street, aforesaid; thence along same Nortn 64 degrees 30 minutes East 121 feet to a point, the place of BEGINNING. HAVING thereon dwelling known on Tract No. 2. erected a two and one-half story frame and asbestos as 694 North Front Street and a one story frame building BEING'the same premises which Administrator of Veterans Affairs by Deed dated March 20, 1964 and recorded at Cumberlan, County, Pa, in Deed Book E, Vol. 21, page 1102, granted and conveyed unto Cumberland County National Bank and Trust Company. AND the said Harry E. Houser, Sr. and Mary E. Houser, his wife, join herein to convey all their right, title and interest acquired by virtue of Unrecorded Articles of Agreement with Cumberland County National Bank and Trust Company, one of the Grantors herein. UNDER and subject to all restrictions, reservations, conditions and limitations of recorded against said premises. THIS is a corrective Deed given for the purpose of conveying the balance of land which was inadvertantly omitted from the original Deed dated July 30, 1975 and recorded in Deed Book E, Vol. 26 page 486. waget4Pr with all and singular the buildings, ways, waters, water-courses, driveways, rights, liberties, hereditaments and appurtenances whatsoever thereunto belonging, or in any wise appertain- ing, and the reversions and remainders, rents, issues and profits thereof; and all the estate, right, title, interest, property, claim and demand whatsoever of in law, equity, or otherwise howsoever, of, in, and to the same and every part thereof. BOOK/Yi 28 PACE 649 _ _ MV 4aUV at1b tQ 401b the said parties of the first part hereditaments and premises hereby granted, or mentioned and intended so to be, with the appurtenances, unto the said parties of the second part, their heirs and assigns to and for the only proper use and behoof of the said parties of the first part, their heirs and assigns forever. Aj1Z1 the said parties of the first part covenant, promise and agree, to and with the said parties of the second part their heirs and assigns, by these presents, that th?the said parties of the first part ha ve not done, committed, or knowingly or willingly suffered to be done or committed, any act, matter or thing whatsoever whereby the premises hereby granted, or any part thereof, is, are, shall or may be impeached, charged or incumbered, in title, charge, estate, or otherwise howsoever. inn 39itness H14trenf, these present to written. Oralra unit Drlfuered in the presence of us: the said parties of the first part have caused be duly executed, the day and year first above 04) 12 6441,lel. /z/ 4. BY: V/06 President ATTEST• f • A ?S Secretary Commonwealth of Pennsylvania County of On On this, the day of 19 before me personally appeared the undersigned officer, , known to me for satisfactorily proven) to be the person described in the foregoing instrument, and acknowledged that they executed the same in the capacity therein stated and for the purposes therein contained. In Witness Whereof, f have hereunto set my hand and official seal. bpo'f/; 28 FAit Emj . L Commonwealth of Pennsylvania ?SS:, ,. County of Cumberland On this, the' ' 11th day of -June , 1979 %cfora me the undersigned officer personally appeared - T. C. Brucklaehetr - who acknowledged himself (herself) to be the Vice President 'Of CCNBBank, N. A. a corporation, and that be as such Vice President , being authorized to do so, executed the foregoing instrument for the purposes therein contained by -signing the name of the corporation by himself (herself) as • an Officer. - IN WITNESS WHEREOF, I have hereunto set my hand and official seal.' - • !??```,',?(?•?yaib`? i?'? New Camheflrnd MY Commission Member. Pennsviv; 61 r v 1 IC Unty a n m a z w 0 41 N W 3 N C ro . x x .H a?H ox W N State of Pennsylvania ! Ss County of Cumberland f Recorded In the office for the nacording of Deaden etc., in and for Cumberland County, Pa. in _?J Book YYl Vol, aK Page 6 af- 6?e Nd EE B Hnl witness my hand and seal of office, at 9Z Carlisle, Pa.'thi c a `i9'9 alxVIMYAI SNN3Hna 33H Recorder 3"1 ?0 UOV033II ao 3a d r a V _N V U 0 $ ro C7 N lU Y ? u +J o to 1 01 oI " z) v " I s F 8 D C7 •9 W s .oo B0001) 28 PACE 651 LISA E. PAIGE, Plaintiff/Petitioner V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 00-3523 CIVIL TERM DAVID H. STONE, Defendant/Respondent IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW comes the Petitioner, Lisa E. Paige-Stone, by her attorneys, Irwin, McKnight & Hughes, and presents the following Petition for Custody. 1. The Petitioner is Lisa E. Paige-Stone, an adult individual residing at 115 Calder Street, Harrisburg, Pennsylvania 17102. 2. The Respondent is David H. Stone, an adult individual residing at 232 Poplar Avenue, New Cumberland, Pennsylvania 17070. 3. The parties are the natural parents of two minor children, namely, Sophie Kathryn Paige Stone, born November 5, 1991, and Peter Grissinger Stone, born May 17, 1993. 4. The parties have been guided by a Custody Agreement dated April 17, 2001, a copy of which is attached hereto and marked as Exhibit "A". 5. The minor child, Sophie Kathryn Paige-Stone, has been physically abused by her stepmother, Lisa H. Stone. 6. The Petitioner desires primary physical custody of Sophie Kathryn Paige-Stone and joint legal custody with periods of visitation to Respondent as the parties agree is appropriate and in the best interest of Sophie Kathryn Paige-Stone. 7. The best interest of the child requires that the court grant the Petitioner's request as set forth above. WHEREFORE,Petitioner respectfully seeks the entry of an Order of Court seeking primary physical custody of Sophie Kathryn Paige-Stone and joint legal custody with periods of visitation to Respondent as the parties can agree. Respectfully submitted, IRWIN V`McKN1 T By: Marius A. ight, I, Esquire AFlize, ey r Petitioner 6t Pomfret Street C Pennsylvania 1701 (717) 49-2353 Supreme I.D. No. 76 Date: February 20, 2008 EXHIBIT "A" f1\cust\pgestane.agr CUSTODY AGREEMENT FOR MINOR CHILDREN This custody agreement is entered into this 0 day of 2001, between LISA E.PAIGE-STONE, hereinafter referre to as the "Mother" and, DAVID HEAN STONE, hereinafter referred to as the "Father". W I T N E S S E T H: WHEREAS, the parties herein desire to set their intentions with respect to custody of the minor children, ANNE ELIZABETH PAIGE STONE, SOPHIE KATHRYN PAIGE STONE, AND PETER GRISSINGER STONE in writing, WHEREAS, three children were born of the relationship, ANNE ELIZABETH PAIGE STONE, born July 6, 1988, SOPHIE KATHRYN PAIGE STONE, born November 5, 1992, and PETER GRISSINGER STONE, born May 17, 1993; WHEREAS, it is the desire of the parties hereto to formalize their agreement with respect to the said minor children when they reside with them; AND NOW THEREFORE, the parties hereto intending to be legally bound hereby do agree that: 1. Both Mother and Father shall share legal and physical custody of the minor children. 2. During the school year the parties agree that they shall observe the following schedule: -1- A. Mother shall have physical custody of the Annie and Sophie from Sunday through Wednesday and of Peter from Sunday through Tuesday. B. Father shall have nighttime visitation of Annie and Sophie on Wednesday night. C. Father shall have physical custody of Peter from Wednesday through Saturday. D. Father shall have physical custody of Annie and Sophie from Thursday through Saturday. E. The parties shall rotate the custody of the children every other Saturday overnight. 3. Holidays shall be agreed by the parties so long as each party enjoys custody of the all three children equally throughout the holiday period. 4. During the summer school vacation, the parties shall have equal shared custody so as to best accommodate the parties` work and vacation schedules. Mother and Father shall be entitled to not less than two weeks vacation in the summer with all three children. These weeks do not need to be taken consecutively. In addition, it is anticipated that each party may enjoy long weekends with the children as the parties may agree. 5. Both parties agree to consult one another whenever a life decision is necessary with regard to the children. Life decisions affect medical, dental, orthodontia, religious, or moral decisions. Both parties agree to consult with one another whenever prudent. 6. Both parties agree that they shall always provide the other party with address, phone number, and or vacation location, when necessary. -2- 7. Both parties agree to be as flexible as possible, whenever possible, and to always place the best interest of their child first. 8. Father agrees to maintain the children on his health coverage and if, and when necessary, Mother agrees that if Mother's employment offers family coverage with no additional, or minimal cost, agrees to add the children as secondary coverage to her policy. 9. All unreimbursed medical bills, including, but not limited to, orthodontia, chiropractic, dental, and vision will be shared equally by the parties. 10. The parties agree that neither party shall be permitted to relocate with the children outside the state of Pennsylvania. 11. This agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of the execution of this agreement. Moreover, the parties hereby agree that the provisions of this agreement shall be entered as a custody order in the Court of Common Pleas of Cumberland County, Pennsylvania. IN WITNESS WHEREOF, the parties hereto intending to be legally bound have set their hands and seals on the date first above written. i VI. ANA NE (SEAL) C./ LISA E.PAIGE ST (ME (SEAL) -3- COMMONWEALTH OF PENNSYLVANIA ) } SS: COUNTY OF DAVID HEAN STONE, being duly sworn according to law, deposes and says that he is a party named in the foregoing Custody Agreement for Minor Children and that he has executed the same for the purposes therein contained. HE ` STONE SWORN TO AND SUBSCRIBED before me this I-7 day o f ", 2001. Notary Public NOTARIAL SEAL PATRICHIA L. YOTER, Notary Public New Cumberland Boro. Cumberland Co. My Commission Expires Nov. 18, 2002 COMMONWEALTH OF PENNSYLVANIA } QQ ) SS COUNTY OF C? C, )MI h V11 0-- ? } LISA E.PAIGE STONE, being duly sworn according to law, deposes and says that she is a party named in the foregoing Custody Agreement for Minor Children and that she has executed the same for the purposes therein contained. SWORN TO AND SUBSCR BED before me this il_ay of 2001. Nol(ary Public ?? LISA PAIGE S E Notarial Seat Martha L. Noel, Notary Public Carlisle Soro, Cumberland CountY My oommission Expires Sept. 18, 2x03 Member, Pennsylvania Association of Notaries -4- VERIFICATION The foregoing document is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unworn falsification to authorities. GQ?- C_ Q1C LISA E. PAIGE ??Jo 6? Date: p ?r o O /v , d LISA E. PAIGE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. DAVID H. STONE DEFENDANT 2000-3523 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Thursday, February 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 Count Courthouse, Carlisle on Tuesday, March 25, 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 Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ ac ueline M. Verne 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 kv -I-- eiv? ;14? 0 /V-Ioy ul, LISA E. PAIGE-STONE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. DAVID H. STONE 00-3523 CIVIL TERM ORDER OF COURT AND NOW, this day of March, 2008, no parent or step-parent or other adult shall physically discipline the child in this case, Sophie Kathryn Paige- Stone. By the.C?dlurt, ./ Marcus A. McKnight, III, Esquire For Lisa E. Paige ,,Barbara Sumple-Sullivan, Esquire For David H. Stone :sal f ?Jac 6j, 3la`o46 tZI , Edgar B. Bayley, J. LIJI: I 0C td C- ' OUZ !' Kjz r.s ` MAR 2 6 2008.4 ?1 LISA E. PAIGE, Plaintiff/Petitioner V. DAVID H. STONE, Defendant/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-3523 : IN CUSTODY ORDER OF COURT CIVIL ACTION - LAW AND NOW, this 25? day of JA V A 0 , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated March 3, 2008 shall remain in full force and effect. The custody agreement dated April 17, 2001, regarding Peter shall remain in full force and effect. 2. Beginning immediately, Father shall have three visits per week with Sophie. One of said visits shall be with Sally Tice, a counselor selected by Father. The duration of the visits shall be as agreed by the parties. In the event there is a dispute over the duration of the visits, counsel may contact the Conciliator for a telephone conference. Visits shall include other individuals, including step-mother, once child is comfortable with such participation. 3. Father shall attend an initial counseling session with Sophie and a counselor selected by Sophie. 4. All parties shall cooperate with counseling for Sophie and follow any recommendations, including additional participants and additional counseling, including co-parenting counseling, if appropriate. 5. This Order is entered pursuant to 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 Custody Conciliation Conference is scheduled for Friday, April 25, 2008 at 10:30 a.m. BY THE COURT Edgar B. Bayley, cc:arcus A. McKnight, Esquire, Counsel for Mother 'Barbara Sumple-Sullivan, Esquire, Counsel for Father Corks tn!Lt(ECL P.J. I .. LISA E. PAIGE, Plaintiff/Petitioner V. DAVID H. STONE, Defendant/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-3523 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edgar B. Bayley, P.J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who are the subject of this litigation is as follows: NAME DATE OF BIRTH Sophie Kathryn Paige-Stone November 5, 1991 Peter Grissinger Stone May 17, 1993 CURRENTLY IN CUSTODY OF Mother shared 2. A Conciliation Conference was held in this matter on March 25, 2008, with the following in attendance: The Mother, Lisa E. Paige, with her counsel, Marcus A. McKnight, III, Esquire and the Father, David H. Stone, with his counsel, Barbara Sumple- Sullivan, Esquire. 3. The Honorable Edgar B. Bayley, President Judge, entered an Order of Court dated March 3, 2008 preventing any parent or step-parent or other adult from physically disciplining Sophie Kathryn Paige-Stone. In addition, the parties are subject to a custody agreement dated April 17, 2001 providing for shared legal and shared physical custody of the children. Following an incident with Father and Father's wife, Sophie has not had contact with her Father, other than telephone contact. 4. The parties agreed to an Order in the form as attached. 3°ZS-o? Date qu ne M. Verney, Esquire Custody Conciliator APR 21 2008 LISA E. PAIGE, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2000-3523 CIVIL ACTION - LAW DAVID H. STONE, Defendant/Respondent : IN CUSTODY ORDER OF COURT1 AND NOW, this ? day of YL \ , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated March 3, 2008 and March 26, 2008 shall remain in full force and effect with the following modification/addition. 2. Sophie shall attend weekly counseling sessions with Sally Tice. Step- mother may be included in the counseling sessions when the counselor recommends it. 3. This Order is entered pursuant to 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. c Marcus A. McKnight, Esquire, Counsel for Mother (Barbara Sumple-Sullivan, Esquire, Counsel for Father Y??a'o8 L - co V 'APR 2128 (Yv-' LISA E. PAIGE, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2000-3523 CIVIL ACTION - LAW DAVID H. STONE, Defendant/Respondent : IN CUSTODY PRIOR JUDGE: Edgar B. Bayley, P.J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Sophie Kathryn Paige-Stone November 5, 1991 Mother 2. A telephone Conciliation Conference was held in this matter on April 19, 2008, with the following by telephone: Mother's counsel, Marcus A. McKnight, III, Esquire and Father's counsel, Barbara Sumple-Sullivan, Esquire. 3. The Honorable Edgar B. Bayley, President Judge, entered an Order of Court dated March 3, 2008 preventing any parent or step-parent or other adult from physically disciplining Sophie Kathryn Paige-Stone and March 26, 2008 providing for Father to have weekly visits and counseling with the child and Father, to include step- mother when the child felt comfortable with it. 4. The parties agreed to an Order in the form as attached. 0-1/-ur A - V Date acq line M. Verney, Esquire 01 Custody Conciliator I + 14 (JUL 0 9 2008 A LISA E. PAIGE, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2000-3523 CIVIL ACTION - LAW DAVID H. STONE, Defendant/Respondent : IN CUSTODY ORDER OF COUR AND NOW, this 1'a day of , 2008, upon consideration of the attached Custody Conci iation Repo K, N ordered and directed as follows: 1. The prior Order of Court dated March 3, 2008 shall remain in full force and effect. The custody agreement dated April 17, 2001, regarding Peter shall remain in full force and effect. The Orders of Court dated March 28, 2008 and April 28, 2008 are hereby vacated. 2. Father shall have the following periods of partial physical custody of Sophie: A. Two visits per week at times agreed by the parties. B. Overnights as the parties agree. C. Such other times as the parties agree. 3. Counseling sessions with Sally Tice shall continue as scheduled by Father. All parties shall cooperate with counseling with Sophie and follow any recommendations, including additional participants and additional counseling, including co-parenting counseling if appropriate. 4. This Order is entered pursuant to 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, September 29, 2008 at 8:30 a.m. cc: Marcus A. McKnight, Esquire, Counsel for Mother _ /0 , b P, Barbara Sumple-Sullivan, Esquire, Counsel for Father n? " JUL 12 2010 LISA E. PAIGE, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V• : N0.2000-3523 CIVIL ACTION -LAW DAVID H. STONE, n '=~'~ c_ ~- Defendant : IN CUSTODY ° ~' _ :r 1- ~.. :~ ~. N ~:; ORDER OF COURT ~. ; .s` AND NOW, this 9`h day of July, 2010, having no contact with the parties for more than ninety days to request another Conciliation Conference, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, ~• acq line M. Verney, Esquire, C tody Conciliator