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Home My WebLink About99-05558 4`I ry' A? v nA'L f Nd ? rr ?Nw. y ?l Y t°r M fi tiN f? ' 1 l I 4 err ? Ch n 'S v J IWO ? 4"1 tl rte ? p e Y6 KEVIN D. MORRISON, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA V5. il?r 555p O ? 1 rerrn NO. Y CIVIL HEATHER J. STONER, Defendant CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this day of 1999, upon consideration of the attached complaint, it is hereby directed that the a ove parties and their respective counsel appear before Esquire, the conciliator, at 3CQ - Pennsylvania, on the day of ?CLO 1999, at X. till A.M. or 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 be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent order. FOR THE COURT: By. 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. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 o. /? , /999 ?vr • /HRLA /-^( n i : cn ?. , U ?n KEVIN D. MORRISON, Plaintiff VS. HEATHER J. STONER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA 99- 5558 NO.9CZ27U CIVIL CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTODY The plaintiff is Kevin D. Morrison, residing at 208 Barnett Street, New Bloomfield, Petry County, Pennsylvania. 2. The defendant is Heather J. Stoner, residing at 603 Market Street, New Cumberland, Cumberland County, Pennsylvania. 3. Plaintiff seeks partial custody of the following child: Name Present Residence Age Brenton Dale Morrison 603 Market Street 5 years New Cumberland, PA The child was born out of wedlock. The child is presently in the custody of defendant, who resides as stated in paragraph 2. During the past five years, the child has resided with the following persons and at the following addresses: RD 2 Box 325 birth to 5/98 Newport, PA mother and maternal grandparents (Harry and Lydia Zimmerman) 603 Market St. 5/98 to present New Cumberland, PA mother, stepfather, then stepbrother too The mother of the child is defendant, currently residing as stated in paragraph 2. She is married but not to plaintiff. The father of the child is plaintiff, currently residing as stated in paragraph 1. He is married but not to defendant. 4. The relationship of plaintiff to the child is that of father. The plaintiff currently resides with the following persons: Name Regina Morrison Relationship wife 5. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons Name Relationship Matt Stoner Brenton Dale Morrison husband Kyle Stoner son son 6. Plaintiff has trot 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 in another court of the 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 father has always been an active and supportive part of his life and wants it to remain that way. 8. Each parent whose parental custody 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. 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 him tody rights of the child. Dated: q-q-gq 116 (717) 834-3( Attorney for I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904 relating to unswom falsification to authorities. ilativr?,u/1? ?Q 141w, J Kevin D. Morrison Plaintiff 1 1 C m ? ? V 00 a 20 o cr o? "' n m d ?n ?Mn d? Odd 80 z a M00 ; a -3 °z r o0 o d Vj ° ty ITf Ch < O a AO b wybr ? p z CD 0 -j W 0 a 5' d C a En I ¦ SEP 14 19?6 KEVIN D. MORRISON, Plaintiff VS. HEATHER J. STONER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-5558 CIVIL CIVIL ACTION - CUSTODY ORDER AND NOW, this day of , 1999, upon receipt of the Conciliator's Report, it appearing that the parties have agreed to the terms and provisions of this Order which was dictated in their presence and approved by them, it is hereby ordered and directed as follows: 1. The parties shall share legal custody of their minor child, Brenton Dale Morrison, d.o.b. April 11, 1994. 2. Mother shall have primary physical custody of the minor child subject to periods of partial custody and visitation with Father as follows: A. On alternating weekends, beginning on Friday at 6:00 p.m., and ending on Sunday at 5:00 p.m. This alternating weekend schedule shall commence on October 29, 1999. 3. The parties shall alternate the major holidays, those holidays being defined as Thanksgiving, Easter, Memorial Day, Fourth of July, and Labor Day. These periods of partial custody and visitation shall be from 8:00 a.m. until 5:00 P.m. This alternating schedule shall commence with Mother having Thanksgiving in 1999. 4. Christmas shall be broken into two segments. Segment A shall be from Christmas Eve at 12:00 p.m. until Christmas Day at 1:00 p.m. Segment B shall be from Christmas Day at 1:00 p.m. until December 26'h at 5:00 p.m. Father shall have Segment A in 1999 and all odd years thereafter and Segment B in 2000 and all even years thereafter. Mother shall have Segment A in 2000 and all even years thereafter and Segment B in 1999 and all odd years thereafter. 5. Mother shall have the child on Mother's Day and Father shall have the child on Father's Day. These periods of partial custody and visitation shall be from 8:00 a.m. until 5:00 p.m. 6. Father shall be entitled to three (3) separate weeks of exclusive custody with the child during the summer months. He shall notify Mother thirty (30) days in advance as to when he intends to exercise these periods. These weeks shall not be consecutive. The weeks are intended to coincide with his time off from work. 7. The transportation shall be shared such that the party who is picking up the child to begin their period of custody shall provide the transportation. 8. Father is entitled to regular telephone access with the child; however, those telephone calls must be made prior to 7:30 p.m. 9. Such other times as the parties may agree. BY J. Jerry A. Philpot, Esquire /11'61g4 IwL? Ms. Heather J. Stoner, pro se nc FCrD_4rFn -'?';07ARY KEVIN D. MORRISON, ) Plaintiff ) Vs. ) HEATHER J. STONER, ) Defendant ) JUDGE PREVIOUSLY ASSIGNED: None IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-5558 CIVIL CIVIL ACTION - CUSTODY CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child(ren) who is(are) the subject of this litigation is as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY OF Brenton Dale Morrison April 11, 1994 Defendant 2. A Conciliation Conference was held on October 28, 1999, and the following individuals were present: the Plaintiff and his attorney, Jerry A. Philpot, Esquire; the Defendant appeared pro se. 3. Items resolved by agreement: See attached Order. 4, Issues yet to be resolved: See attached Order. 5. The Plaintiff's position on custody is as follows: See attached Order. 6. The Defendant's position on custody is as follows: See attached Order. 7. Need for separate counsel to represent child(ren): Neither party requested. 8. Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe any is necessary. Date: November 2, 1999 L Michael L. Bangs Custody Conciliator ??