HomeMy WebLinkAbout01-2615 : IN THE COURT OF COMMON PLEAS
TIMOTHY A. STONE~l~intiff : CUMBERLAND COUNTY, PENNSYLVANIA
:NO. ;? ~'/~'' CIVIL TERM
V.
:
K_RISTY L. STONER, : CIVIL ACTION - CUSTODY
De~ealdnnt :
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 S~'eet, Han'isburg, Dauphin County, Pem~sylvanla.
3. plaintiff seeks custody of his children, Samantha Marie Stoner, bom September 4,
1994, and Stephanie Marie Stoner, bom 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 611 Market St. New Cumberland, PA April 1997 to Feb. 9, 2000
Kristy L. Stoner
Terry & Sue Stoner 1002 Allen St., New Curnberland, 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.
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 Plaintiffhas not participated as a party or in any other capacity, in other litigation
concerning the custody of the children in this or any other coral, with the exception of a previous
action filed and withdrawn by defendant in April and May 1996.
11. Plaintiffhas no information ora custody proceeding concerning the child pending in a
court of this Commonwealth.
12. The best interests and permanent walfare 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 clahn to have any right to custody or visitation of the child other gum
the parties to this action.
WHEREFORE, Plaintiff requests your Honorable Court to order custody rights in regard to
Samentha Made Stoner and Slephanie Made Stoner in accordance with the Stipulation of the parties.
Respectfully submitted,
Date 714 Bridge Street
Post Office Box 461
New Cumberland, PA 17070-0461
(717) 770-2540
Attorney for Plaintiff
VERIFICATION
I verify that thc statements made in the foregoing Custody Complaint are true and correct. I
understand that false statements made herein are subject to the penalties of 18 PA C.S. 4904 relating
to unswom falsification to authorities.
TIMOTHY A. STONER~- ~x..._~.
Date
: ii'4 THE COURT OF COMMON PLEAS
TIMOTHY A. STONER,
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. CIVIL TERM
V.
: CIVIL ACTION - CUSTODY
KRISTY L. STONER, Defendant :
STi~ULATION
AND NOW this ~C~ ~ day of ~-~e~! ~ ,2001, it is hereby stivuleted and agreed
between the parties as follows:
I. Samantha Made Stoner, Bom September 4, 1994 and Stephanie Marie Stoner, Bom
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:
~VlOTHY A. STONER, Famer
Attorney for Father
Date ~,RISTY L. ~IFONER, Mo
TIMOTHY A. STONER, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
v. : NO. ~- ~6,{~' CIVIL TERM
:
KRISTY L. STONER, : CIVIL ACTION - CUSTODY
Defendant :
ORDER
AND NOW, this 1~ day of ~ ,2001, upon consideration of
the within Stipulation it is ordered and decreed as follows:
!. Samantha Marie Stoner, Bom September 4, 1994 and Stephanie Marie Stoner, Bom
April 2, 1997 are the natural children of Timothy A. Stoner (father) and Kristy L. Stoner (mother).
2. Shm'ed legal custody of said childmm as contemplated by the Act of November
1981, P.L. 322, 23 P.S. Section 1001, et seq., will be in both of the parties, as the natural parents.
3. Prinulry physical custody of said children shall be in the Father, Timothy A. Stoner,
_
subject to periods of pimial custody and/or visitation with the Mother, Kristy L. Stoner, as
parties may mumally agree.
BY THE COURT, '"~ ~'~,0
J.
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