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Home My WebLink About05-3792 Lori K. Serratelli, Esquire Pa. Supreme Court ID No. 27426 Serratelli, Schiffman, Brown and 2080 Linglestown Road Suite 201 Harrisburg, pennsylvania 17110 Telephone (717) 540-9170 Fax (717) 540-5481 Attorney For Plaintiff Calhoon, P.C. DONALD E. STONER, JR., Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 S- - :5 "19~ c.~uc' L '----r ~ CIVIL ACTION - LAW KAREN L. STONER, Defendant CUSTODY CUSTODY COMPLAINT TO THE HONORABLE, THE JUDGES OF SAID COURT: 1. The Plaintiff is Donald E. Stoner, Jr., who currently resides at 6257 Stanford Court, Mechanicsburg, Cumberland County, PA 17050. 2. The Defendant is Karen L. Stoner, who currently resides at 1819 13th Street, Altoona, Blair County PA 16601. 3. Plaintiff seeks primary physical custody and shared legal custody of the parties' two minor children: Justin Stoner, born October 24, 1989 and Alexandria Stoner, born July 15, 1994. 4. Justin was born out of wedlock and Alexandria was born in wedlock. 5. The children are currently in the custody of the plaintiff who resides at 6257 Stanford Court, Mechanicsburg, Cumberland County, PA 17050. 6. During the past five years the children have resided with the following persons and at the following addresses: Persons Donald E. Stoner, Jr. Karen L. Stoner Justin Stoner Alexandria Stoner Karen L. Stoner Justin Stoner Alexandria Stoner Karen L. Stoner Justin Stoner Alexandria Stoner Boyfriend(Jim Rinker) Donald E. Stoner, Jr. Justin Stoner Alexandria Stoner Address Dates 261 Briner Road Elliotsburg, PA 17024 8-2001 to 3-2003 Loysville (exact address unknown) 3-2003 to 10-2003 1819 13th Street Altoona, PA 16601 10-2003 to 3-25- 2005 6257 Sanford Court Mechanicsburg, PA 17050 3-25-2005 to Present* (*except that Alexandria has been taken for several weeks on camping trips and to Altoona) 7. The father of the children is Donald E. Stoner, Jr., who currently resides at 6257 Stanford Court, Mechanicsburg, cumberland County, PA 17050. 8. The relationship of plaintiff to the children is that of father. The Plaintiff currently resides with the children. 9. The relationship of Defendant to the children is that of mother. The Defendant currently resides with her boyfriend, Jim Rinker. 10. Plaintiff has not participated as a party, witness, or otherwise in litigation concerning the custody of the said children. 11. Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth. 12. 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. 13. The best interests and permanent welfare of the children will be served by granting the relief requested because the Plaintiff can provide a more stable, safe and nurturing environment than Defendant Mother whose paramour is endangering the safety and wellbeing of the children. Both children attended Cumberland Valley School District from March through June, 2005 and wish to continue attending school in the Cumberland Valley School District in the Fall of 2005. 14. Each parent whose parental rights to the children has not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, Plaintiff respectfully prays that Your Honorable Court award primary physical custody and shared legal custody of the children to the Plaintiff. Respectfully submitted, Lor Serratelll, Esquire S RATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2040 Linglestown Road Suite 106 Harrisburg, FA 17110 (717)540-9170 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Fa. C.S. Section 4904, relating to unsworn falsification to au rities. Date: ~~~ ) CERTIFICATE OF SERVICE I, J:lri K. Se this ~ day of foregoing Custody in the Post Office person (s) : Esquire, do hereby certify that on , 2005, I served a copy of the mp int by first-class mail, postage prepaid, at Harrisburg, Pennsylvania, to the following Karen L. Stoner 1819 13th Street Altoona, PA 16601 With a courtesy copy to: Marcus A. McKnight, III, Esq. IRWIN & MCKNIGHT 60 West Pomfret Street Carlisle, PA 17013-3222 Serratelli, Esquire S RATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2040 Linglestown Road Suite 106 Harrisburg, PA 17110 (717) 540-9170 ~ {,Q... ~ -- ..... \\. ..... V( --- Vv C> ~ ..0 -J \"" -- ~ -4:) P- -{:::, - P -I- ---..L:... 71 ~ ~ ::;J~~ c.... h::.\;'.~:: ", U i) , r,) cr', ~:) <.,0 (-:-:"""'; \..0 DONALD E. STONER, JR. PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 05-3792 CIVIL ACTION LAW KAREN L. STONER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, July 28, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4tb Floor, Cumberland County Courthonse, Carlisle on Thursday. Septemher 01, 2005 , the conciliator, at 10:30 AM 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. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours priolr to scheduled hearing. FOR THE COURT. By: /s/ Hubert X Gilroy, Esq. Custody Conciliator rt 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 VE 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 . ?7'> ~;J<. - ~ "<D -h""t. ~ -" ~ ~'" JI?;,<,." .~? "'~""/.>"9 g.6<'.~ j ! ~ \ r"' ....! 'vJ 7 "1"1" ~Di]Z ., "I r:.,... j I .. C7 " '", '__ ':..... -t, ,',." .. . .....'.:) :JH1:{0 AH1L)'iu~\,~.. r:~nr.l > j8l~:;:U._.\"L. - RECEl'/ED S~P C 6 ~OO5f DONALD E. STONER, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v NO. 05-3792 CIVIL ACTION - LAW KAREN L. STONER, Defendant IN CUSTODY COURT ORDER AND NOW, this L day of September, 2005, upon representation that the parties have reached an agreement, the Conciliator relinquishes jurisdiction. ~. a,: ~~~' ~5 ~~~, c"\~..'-- (;:)U_ ~u.J u...~ t5 '<D -r 0.. \.j,O . ~"'J v> L'-:> C::'.:> C;;~ C'-' ;.>-. =.;"; ~--:j -) . .;~~ :.5 u - Lori K. Serratelli, Esquire Pa. Supreme Court ID No. 27426 Serratelli, Schiffman, Brown and Calhoon, P.c. 2080 Linglestown Road Suite 201 Han'isburg, Pennsylvania 1711 0 Telephone (717) 540-9170 Fax (717) 540-5481 Attomey For Plaintiff DONALD E. STONER, JR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 05-3792 Civil Action KAREN 1. STONER, Defendant IN CUSTODY PRAECIPE TO THE PROTHONOTARY: Please withdraw the Custody Complaint filed by the Plaintiff in the above captioned matter. Lo~;K. erratelli, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.c. 2080 Linglestown Rd., Suite 200 Harrisburg, P A 1711 0 (717)540-9170 Attorney for Plaintiff n ~'I c~, c.) co