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Home My WebLink About01-2615 FX I TIMOTHY A. STONER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. ; NO. :< (. IS CNIL TERM KRISTY L. STONER, Defendant : CNIL ACTION - CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Timothy A. Stoner, an adult individual whose residence is at 611 Market Street, New Cumberland, Cumberland County, Pennsylvania. 2. Defendant is Kristy L. Stoner, an adult individual whose residence is at 100 South 17th Street, Harrisburg, Dauphin County, Pennsylvania. 3. Plaintiff seeks custody of his children, Samantha Marie Stoner, born September 4, 1994, and Stephanie Marie Stoner, born April 2, 1997. 4. The children are presently in the custody of Plaintiff. 5. Since the children's births, they have resided with the following over the past five (5) years: Name Address Date Timothy A. Stoner 611 Market St. New Cumberland, PA February 9, 2000 to present Timothy A. Stoner and Kristy L. Stoner 611 Market St. New Cumberland, PA April 1997 to Feb. 9,2000 Terry & Sue Stoner 1002 Allen St., New Cumberland, PA February 1996 to April 1997 6. The natural mother of the children is Kristy L. Stoner, currently residing at the above-stated address. 7. The natural father of the children is Timothy L. Stoner, currently residing at the above-stated address. ,,-~,_ "I,. ~ " - - ,~, .'1:;'71:"'0""''''---" ":~'"-"--~--,'- ~-"~IY"",---'-"-""~"-""~--" ':I_~-' ,'''''''-,, "'9--0'-'" 1-"' ~'_:_"O-'~_'_~_'7'_'_'_"" ' ". 8. The relationship of the Plaintiff to the children is that of natural father. 9. The relationship of the Defendant to the children is that of natural mother. 10. The Plaintiff has not participated as a party or in any other capacity, in other litigation concerning the custody of the children in this or any other court, with the exception of a previous action filed and withdrawn by defendant in April and May 1996. 11. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 12. The best interests and permanent welfare of the child will be served by granting the relief requested because the Plaintiff is the primary care giver with respect to the child. 13. 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. No other persons are known to have or claim to have any right to custody or visitation of the child other than the parties to this action. WHEREFORE, Plaintiff requests your Honorable Court to order custody rights in regard to Samantha Marie Stoner and Stephanie Marie Stoner in accordance with the Stipulation of the parties. Respectfully submitted, .$ y1.)J,(-{ Zu::.\ \ Date ~ ROBERT P. KLINE, ES 714 Bridge Street Post Office Box 461 New Cumberland, PA 17070-0461 (717) 770-2540 Attorney for Plaintiff ~~,"~, ~ ,,-' ,_ C'" ~, ",'" - . '1"; .- - '-" 'l-:"- 1" "'''1-' , \l,~,_o ._< VERIFICATION . I verifY that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements made herein are subject to thl: penalties of 18 P A C.S. 4904 relating to unsworn falsification to authorities. tJ ~ )/i-0 I Date ~04~, ~~-"'_"""',ci"";~ _:--,,--_ "'"' '" '---,'1-,',- ~ ~ f""C''1', e !~ l,,,,,,, ~ - ,=~ -- -~ ,-UT, ," _rl' ,,~".~ ,^, ~,-, ,.;-j' I""' " C', '~'," " c_ ""d'C' -,-'<t,',""',- c,,' i"".;-.."",~"-"""','~,,,,_,,,;-,-_~9' ~-~,~~~~~..,' iTIJlII'TI'f 1 0 0 r- C - $ .~ "~I,. ''''' ni,,, ~;C'" ':2:::::[_: - 6- L~:_ I , r... " , " , . ~:::- -< , ~Cj '---' :~\ :i'"~ =C ~{:~ ~: ;~; ',;,,1 p~ C") :.0 :.;...::;: n-'1 '..~ :z: ~.), ~ =< (~ -< - _"'_ ",,,,,,,!!fj~ .~ ~ :,~~~~~~~!\,~~~-''''i_j-i,;,;-f\'''''''''''<'1'",~n~i'"O;:;O:-:_,,,,?,;-;'t^~"'HI',\',~;Q'_v0~"-"'-,n,,-;' ;-"'~k:'-=F-r:';"""'t'V"!"!:;,0"'!!!-'-'f~;fi':':J!1m:<jj!!l1t " , .' \ . . TIMOTHY A. STONER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. CIVIL TERM KRlSTY L. STONER, Defendant : CIVIL ACTION - CUSTODY STIPULATION ANT> NOW, this _ '2Ji flL day of, ~I L > 2001, it is hereby stipulated and lIgreed, between the parties as follows: I. Samantha Marie Stoner, Born September 4, 1994 and Stephanie Marie Stoner, Born April 2, 1997 are the natural children of Timothy A. Stoner (Father) and Kristy L. Stoner (Mother). 2. Shared legal custody of said children as contemplated by the Act of November 5, 1981, P.L. 322,23 P.S. Section 1001, et seq., will be in both of the parties, as the natural parents. 3. Primary physical custody of said children shall be in the Father, Timothy A. Stoner, subject to periods of partial custody and/or visitation with the Mother, Kristy L. Stoner, as the parties may mutually agree. 4. The parties hereby agree that this Stipulation shall be entered as an Order of Court by the Court of Common Pleas of Cumberland County. WITNESS: #?U-0-- RO ERT P. KLINE, ESQUIRE Attorney for Father itt~J.1-{/ .' Date (j~ (?o~ OTHY A. ST NER, Father 4- 'JC./-OI Date c2~ KRlSTY L. ONER, Mother n~~ -, '- -:"- -"":--":}"-:"", "'",",,".00 """9'. ,"^',.'" '.'- .-'~"l-- ",",,' )-~'::'T- ~,": c'- I' ,,.,-.-," -c~_"._ "~'~' 1 _, ." '~I ,~- o_"''''~ _~ co ' .. k., _" ,- '.~, , .""" -'1 "" ,'. __, 'C ~r , ",_, <," _< ,_" ~ J ltl ~ ~, '?'''-' " I ,;'!i!JlI' _""'_ c, c ". ',~ ,~ _,,~ e''',",~ - '" -I" '~, " ." ".",".~ "'"''-''-''''' ~ .C<.' ~d,""''' - .~" -~"",~, "~'~'4'_, '"......",~,~~. -'" ~ ''''''''''''IJ!!I!!!!!I,''',r,^ 1,0'", '1.0"'-~lTi\l , (') D J:::> c 'S~ -.- ;:HE) ~~ -- Z::r.:-' .......~ ~ G> ? zS' I Vt-.> (',C - -<.,.L_'_ ,... ~ r::-r--l ~ ;<-- ~"" "- :2' ", ~ z',:<-.:::::' -{) -- ~ >tl t,;O' ~ ~ ~ :2: :.", '-'\ :=2 (,~ J<\, :::-' ::> '" I'_'~"'" .dl'l,\'l~1!J!!lWIflH~m~~!!I<~~~~iflj~~~", ''''-.'r1 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01- 2(015" CIVIL TERM TIMOTHY A. STONER, Plaintiff KRISTY L. STONER, Defendant : CIVIL ACTION - CUSTODY ORDER AND NOW, this I.t day of ~ \ ,2001, upon consideration of the within Stipulation it is ordered and decreed as follows: 1. Samantha Marie Stoner, Born September 4, 1994 and Stephanie Marie Stoner, Born April 2, 1997 are the natural children of Timothy A. Stoner (father) and Kristy L. Stoner (mother). 2. Shared legal cnstody of said children as contemplated by the Act of November 5, 1981, P.L. 322, 23 P.S. Section 1001, et seq., will be in both of the parties, as the natural parents. 3. Primary physical custody of said children shall be in the Father, Timothy A. Stoner, BY THE 9JURT, ~\ ~D ,0 o subject to periods of partial custody and/or visitation with the Mother, Kristy L. Stoner, as the parties may mutually agree. J. / 'f:'1""'",_ ',_r.." -~"''- . ',_ - ,,~. "':"'- .' I ',' , '1-' ,-" ,". ". ,~I g ;~ " ~--= ^" -> -' ,'" !Ili"!":r;m. -~ ' ~'= -~" ....'-"',. -,,\ _'-1,,,-, - ,~,,-'" -~ ",\C,'_''''' ~\ - ,,~,-",'; ;,"",~-;a, I""'TI'i~-b.""-I.!~~~-'""'''r:"IDt'<TF1t~',\o'rfio/ :;!i~--~;;' iIlNVAlASNN3d AlNnO'J (1~i\'ltI38lf\ln8 0'1 :01 ~oI\I! - A'it! I 0 Al:1V.LCi\~;!'U_U,~,,:: _" ii. :10 3:Ji:L:-!()-{iJ- ::1 I~~~", ,~, "''''._~" .-mli'!!!:,JL;:;,">!1'If,~'l!q?""l:'m-'",j~i",<-~;_""1""~' ,"H"l'h1",!l*mp"\;~i1"1r.;:~"$1'ff~~)"'~J!)1""i!'!"j'JFI~~~1!(W~~!,~.V~lt1il!U~-'