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Home My WebLink About97-05502 J ~ ~ l-J ~ 'j i ~. " ~ ~ ~ ql ~ ~ - ,-5 ~ rot ~ 'c) , to-- ' Q'- (~ PATSY JEAN BARNHART, and TIMOTHY TODD BROUSE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, NO. 97-5502 CIVIL TERM DEANNA STONE, CIVIL ACTION - CUSTODY Defendant ORDER J1J ' AND NOW this / 'III, day of / V'I'V'~J",^ , 1997, It being reported to the Conciliator that the parties have reached an agreement which makes further proceedings unnecessary, the undersigned Conciliator hereby relinquishes jurisdiction and returns the matter to the Court Administrator. If either of the parties wishes further proceedings in this action, they should petition the Court anew, FOR THE COURT, ?1' .l-?4.~, / X-~=-. ~ MICHAEL L. BANGS Custody Conciliator cc: Arthur K, Oils, Esquire Charles E. Petrie, Esquire , PATSY JEAN BARNHART, AND TIMOTHY TODD BROUSE, Plaintiffs Vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 97- !iJIJL NO, Civil, ~ DEANNA STONE, Defendant CIVIL ACTION-LAW OftDER QF COllJn AND NOW, upon consideration ofthe attached Complaint, it is hereby directed that the p~ies and their respective counsel appear before Mlc mt' \ L. Rcn~, the Conclhator. on \'C\,-lr ~,>d(\".....~ ,the I ~ day of ~\.JeN'\'Cc r, 1997 at I \ ~ CJ(') 0. .m, in t e office of said concIliator located at 3CJ a. ~ \\-h \ '(\IA \~ I I (D,y,f" \~ \ \, PA 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 the entry of a temporary or permanent order, FOR THE COURT: Date:~ BY: c-c Custody Conciliator (",.\ - r. ',I \. L ',: ~ '_ ( , .'" ' ,'/.. 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" ..:',' , ';. ,-: ~, :' r, . ., , , 3, The Defendant, Deanna Stone, is an adult individual, who currently resides at Whydern Courts, 113 Elk Street, Mechanicsburg, Cumberland County, Pennsylvania 17055, 4, The Plaintiffs, Patsy Jean Barnhart and Timothy Todd Brouse, are mother and son, 5, The Plaintiff, Timothy Todd Brouse, and Defendant, Deanna Stone, are the natural parents of one child; namely: Brian Keith Brouse, born June 13, 1990, 6. The minor child, Brian Keith Brouse, has resided at the following addresses since birth: 202 N. Second Street, West Fairview, Pa, From birth until September of 1990; 151h Street, New Cumberland, Pa. From September of 1990 until March of 1991; N. Enola Drive, Enola, Po. From March of 1991 until March of 1991; -2- Country Meadows Trailer Park, Carlisle, Pa, From 1992 until 1993; 516 North Second Street. Wormleysburg, Pa, From 1993 until March of 1997; (Resided with Plaintiffs) Whydem Court, Mechanicsburg, Pa, From March of 1997 until September 9, 1997; 516 North Second Street, Wormleysburg, Pa. From September 9, 1997 to the present. 7, There has been no prior action for custody or visitation of the minor child in this or any other jurisdiction, 8, The Court of Common Pleas of Cumberland County have full jurisdiction in this matter as all parties reside in Cumberland County, Pennsylvania. 9, The Plaintiffs believe it is in the best interest of the minor child that he remain in the primary physical custody of them, -3- 4. The Plaintiffs are able to provide stability, consistency and guidance to the minor child. 5. It is believed that the Defendant's life. at this time, is unstable, and that it would not be in the best interest of the minor child to be with his mother, WHEREFORE, it is respectfully requested that primary physical custody of the minor child be granted to the natural father, Timothy Todd Brouse, and his mother, the paternal grandmother, Patsy Jean Barnhart, Respectfully submitted, BY: 'Itl ;L, rthur K. Dils, Esquire 1017 N. Front Street Harrisburg, Pa. 17102 (717) 232-9724 I.D. No. 07056 -4- , ~ " -- ^. . ...-....... .. . - - , . . . ~ ~' , tl, ,- i , I verify that the statements made in this coMelftl NT FOR PR I MARY PHY~ I r.AI CI15Tony , are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. /&,JiJ Date: SEPT. 29, 1997 PATSY J AN BARNHART ~~ rJj.~M - T [ THY TODD BROUSE ;r,rl H n i :l(); , ." .. .. 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Ph ;::--, ", I::> :< C C" ',I , DEe 1 0 1997u41 \ PATSY JEAN BARNHART and TIMOTHY TODD BROUSE, Plaintiffs IN TH~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. NUMBER: 97-5502 DEANNA STONE, IN CUSTODY ORDER AND NOW, this 'D~day of December, 1997, upon consideration De fendan'c of the within Stipulation, IT IS HEREBY ORDERED AS FOLLOWS: 1. It is the intention of the parties and the parties agree that they will share joint legal custody of their minor child, The parties agree that major decisions concerning the child, including, but not necessarily limited to, the child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interests, Each party agrees not to impair the other party's right to shared legal custody of the child, Each party agrees not to attempt to alienate the affections of the child from the other party nor to permit any third person to attempt to so alienate the affections of the child from the other party, Each party shall notify the other of any activity or cirr.umstance concerning the child that could reasonably be expected to be of concern to the other. Day-to-day decisions shall be the responsibility of the party then having physical custody. With regard to any emergency decisions which must be made, the party having physical custody of the child at t- , ' I'~ i , .. f" i.'.1 1;"'.', t\';""" - 'Ii'n ':\ :1: " l.l .. ~ ~J lb " ..-. \.<., .' " , the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that party shall inform the other of the emergency and consult with him or her as soon as possible, Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party. 2. The parties shall share physical custody of the subject minor child. Each party shall have cllstody of the child for seven consecutive days, with the parties exchanging the child on Sunday evenings, 3. The parties shall alternate the major holidays (Easter, Memorial Day, Independence Day, Labor Day, Thanksgiving, and Christmas), with the exact details to be worked out by the parties. 4, Father shall immediately petition the Dauphin County Domestic Relations Office to terminate the support action against Mother, BY THE COURT: DEe 1 0 199Zft; PATSY JEAN BARNHART and TIMOTHY TODD BROUSE, PlainUffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. NUMBER: 97-5502 DEANNA STONE, Defendant IN CUSTODY STIPULATION AGREEMENT, made this 10 day of November, 1997, by and between PATSY JEAN BARNHART, hereinafter referred to as "Grandmother;" TIMOTHY TODD BROUSE, hereinafter referred to as "Father;" and DEANNA STONE, hereinafter referred to as "Mother;" WITNESSETH: WHEREAS, the parties hereto are the natural parents and paternal grandmother of a minor child, BRIAN KEITH BROUSE, born June 13, 1990; and WHEREAS, the parties have reached an agreement with respect to the issues of custody; and WHEREAS, the parties desire that this Stipulation be entered as an Order by the Court of Common Pleas of Cumberland County, Pennsylvania; NOW, THEREFORE, intending to be legally bound, it is hereby agreed as follows; 1, It is the intention of the parties and the parties agree that they will share joint legal custody of their minor child. The parties agree that major decisions concerning the child, including, but not necessarily limited to, the child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each , , other, with a view toward oocaining and following a harmonious policy in the child's best interests. Each party agrees not to impair the other party's right to ~hared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party nor to permit any third person to attempt to so alienate the affections of the child from the other party, Each party shall notify the other of any activity or circumstance concerning the child that could reasonably be expected to be of concern to the other, Day-to-day decisions shall be the responsibility of the party then having physical custody. With regard to any emergency decisions which must be made, the party having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that party shall inform the other of the emergency and consult with him or her as soon as possible, Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party. f: U) !?, CXI ~ '- "Or't'i .-:} ;2!TJ :I:JIt ''-:1J :;z;: '11;- ?OC' I "g vl,'~ N .~ ('-"if:.- :-: ..' ~ 'i!:B .:::(') ;:,: 9~ :i.' .., ~ ..(~. d -~ -~ ~ ~ ;t- .../ ~