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Home My WebLink About00-05233 , . - ~ ""<' " v ROBIN L. STONE PLAINTIFF V. PAUL L. STONE DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V AN1A 00-5233 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 3rd day of AU2ust ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberlllud Couuty Courthouse, Carlisle on the 13th day of October , 2000, at 10:30 a.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/ Hubert X. Gilro 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 HA VB 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 !!Mill ''-'''~~~~~~J!d,;~~,,,",,''''~ V'.' "',~" ~,-~" '=-~~'~I.-..<,"""",,,,',,,, "~~ .. -~~~ ~~~l c?a-(-;!> -p~ '2. ~ ~ (?O-(.~ ~ r ~ ~-4 It) oO-cp '4Il'N^),t~~~~n~ JJ}\\108 \J'~~ -,C>_ l- ~\I~ CO .(':~ ~d . \;) ,OJ "'\j" ",j '~.' \ l ..'," t', ..J ^'cl~~O\~1;':Ik~B-\\:l .- 3J\Cl.'- w "'~,,. ~. _ , ,.., . . e '.' ~. ~~, ~ " , ~,,~.~'~'",..~.,,== ",.' ....'iI, 'j:' ~: - .""..- , ROBIN L. STONE, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00- ~ ~ 3J CIVIL TERM PAUL L. STONE, Defendant : IN CUSTODY ORDER OF COURT AND NOW, 2000, upon consideration of the attached petition, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the day of ,1999, at 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: Custody Conciliator 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. 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 TELEPHONE: (717) 249-3166 , ~~~~~iIf~~l>~~~~ 11II. , '. - _.i!lr~'"~ .",.~- ~~ _~I '~ .J ! i i i ~ ~ ii I] ~"~~"'="'''I"(' ROBIN L. STONE, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 00- SolE CIVIL TERM PAUL L. STONE, Defendant IN CUSTODY COMPLAINT FOR CUSTODY I. The plai'i'-tiff is Robin L. Stone, residing at 6 McAllister Church Road, Carlisle, Cumberllmd County, Pennsylvania. 2. The defep.dant is Paul L. Stone, residing at 449 Crossroad School Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following children: Name Present Residence ~ Alicia N. Stone 6 McAllister Church Road 16 Carlisle, PA 17013 Melisa S. Stone 6 McAllister Church Road 11 Carlisle, PA 17013 l<rystal L. Stone 6 McAllister Church Road 8 Carlisle, PA 17013 The children were not born out of wedlock. The children are presently in the custody of mother who resides at 6 McAllister Church Road, Carlisle, PA. During the past five years, the children have resided with the following persons and at the following addresses: Person Robin L. Stone and Paul L. Stone Address 449 Crossroad School Road Carlisle, PA 17013 Dates 7/95 - 7/25/00 Robin L. Stone 6 McAllister Church Road Carlisle, PA 17013 7/25/00. present The mother of the children is Robin L. Stone, currently residing at 6 McAllister Church Road, Carlisle, PA. She is married. ,""'" I >il!mli.;,~ ,. The father of the children is Paul L. Stone, currently residing at 449 Crossroad School Road, Carlisle, PA He is married. 4. The relationship of plaintiff to the children is that of mother. The plaintiff currently resides with the following persons: Name Relationship Alicia N. Stone Daughter Melisa S. Stone Daughter I<rystal L. Stone Daughter 5. The relationship of defendant to the children is that of father. The defendant currently resides with the following persons: None. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children 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 children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent weUare of the children will be served by granting the relief requested because: a) Plaintiff can provide the children with a home with adequate moral, emotional and physical surroundings as required to meet the children's needs; b) Plaintiff is willing to accept custody of the children; c) Plaintiff continues to exercise parental duties and enjoys the love and affection of the children. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE Wherefore, plaintiff requests the court to grant her custody of the children. !Iiili;;b';""~""''''''''' 'E, VfJi-~ ; . ~ 'iIim~""~h.<"''''ru~;~i1i' 'li:Il~~(l_ '. H '"';;;, ~"",,,,,-,,~"wllillllil ,~ "- ~"~~ .. 'lr~ r" > ::. '!MI"'- h " ,. "",., ""~-~ ~l' I verify that to the best of my knowledge and belief, the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.~4904 relating to unsworn falsification to authorities. ~~J~ Robin L. Stone, Plaintiff , '. ~, ~,~~ ,. jl!Il\!flj _ " ,-...~~"",- '"""~~Jji'J-~Mf~~.iltl1'ffi~!tli!!@"'I1!~ii:m~~;i1-1~ ..lltl iii.."~ -.'-'0 p. 0 ~ ~ r;. & ~.lr?d . . O' ~ ~ &~\)() ~ ~ ~ J , ,"',<<<",," "'''' ,-""".' .,. .. ^ic,j " n S -OC:l IJ.J~: g~ -~'; ~- ?vl....j {.:o::(2 :P' c_. 2 --\ -<. (::..." C s'~::; ..' ", -' 1(0 cr., _".c", ::,:/ _.-I. -, In :::> -';, ~ ,~ . , - - ,- ~ - -<, - ~'" - .'J' __l ~'~, DEe 122000 II; ROBIN L. STONE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW PAUL L. STONE, Defendant NO. 00 - 5233 CML IN CUSTODY COURT ORDER ...~ AND NOW, this J.l..:..-.. day of December, 2000, the Conciliator being advised that the parties have reached an agreement, the Conciliator relinquishes jurisdiction. BY THE COURT, r:llir:i!4 Custody Conciliator Bill.~ ]!il' " ~~ilIi1lili&~ -r"' .'~ . ~,I~- -1lQ~ ViNVi\7ASNN3d A.l.Nno:J C'N':n,cij8vvno f 5 : II iN F: I :)]0 aD (1:1''/1(''':,. I. ~ ~" ..., '< 'h" j';"'Ji}..;O-cJ3";ld ,- ~ ~~>- ... ",~ lilillI - "'IiIiIii_"'~'. .~ '" ,-,', ., i:t: ~ II [i j I ! ! I ") "-~~"<"""" -, ..~ ~ 0'" "~.". .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA TURNPIKE COMMISSION ) ) Plaintiff, ) ) vs. ) ) USA TRUCK, INC., and JOSEPH PERDUE, ) ) Defendants. ) CIVIL DIVISION NO. 00-5223 Civil REPLY TO NEW MATTER 12. The averments of this paragraph contain a legal conclusion to which a response is not required. To the extent that a response is required, the Pennsylvania Turnpike Commission avers that it has stated a claim upon which relief may be granted. 13. The averments of this paragraph contain a legal conclusion to which a response is not required. To the extent that a response is required, the Pennsylvania Turnpike Commission avers that it has mitigated its damages. 14. The averments of this paragraph contain a legal conclusion to which a response is not required. To the extent that a response is required, the statute oflimitations is not -,..!. '.' " - ." :-'IF . applicable to the Pennsylvania Turnpike Commission because the Commission is a Commonwealth party for purposes of sovereign immunity and asserts doctrine of nullum tempus occurrit regi. Smith v. Mognet, et aI., 618 A.2d 1215. PENNSYLVANIA TURNPIKE COMMISSION BY ~~@l:Y~?? Albert C. Peters II PA ID # 49717 Assistant Counsel Pennsylvania Turnpike Commission P. O. Box 67676 Harrisburg, PA 17106-7676 (717) 939-9551 x3150 Fax (717) 986-9654 ~" """~ ~". r ' .' VERIFICATION I, Albert C. Peters II, Assistant Counsel of the Pennsylvania Turnpike Commission, state that I am authorized to make this verification on its behalf; that the facts set forth in the foregoing Reply to New Matter are true and correct to the best of my knowledge, information, and belief and are made subject to the penalties of 18 Pa. C.S.A. !i4904 relating to unsworn falsifications to authorities. ~rlf&~ , BY Albert C. Peters II Dated: 0) /oj / -"'""""',,,_." ^ ~.~." ~ ;,~". "'~, "" CERTIFICATE OF SERVICE I, Albert C. Peters II, Esquire, hereby certifY that a true and correct copy of the Reply to New Matter in the foregoing action was served upon defendants' attorney via first class mail, postage prepaid, addressed as follows: Jefferson J. Shipman, Esquire Goldberg, Katzman & Shipman, P.C. 320 Market Street P.O. Box 1268 Harrisburg, P A 17108-1268 J4J/{ df~r Albert C. Peters II Dated: r/cJ k l / /-' ,'"'"".~- ~ w ~ '^^._~'~~~,;!if'!\;!,iW.!"'b'-;d~~1Ii-'~llil8!iilf'~~-""'" n (,c" ",1;: _ .:'i"\;_, .\-4i~. .,.', " , ~ ~, ~"' , ~ , - C" [[1 tl~ <7.F!.. (;) ~' ~:-:--: ~'_J 5:S? ::J _.J , o c C) o ,', :T:1'- C;" N ."0 o ,_.~~/) cJ~ :;:---1 :5J -< :OJ Ui .-, .... ~L' " H ! I I i I I I , I I I I I " 'il 1