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Home My WebLink About05-3851 KAREN L. STONER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DONALD E. STONER, JR., Defendant : Of; - $PS-/ CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Karen L. Stoner, by her attorneys, Irwin & McKnight, and presents the following Complaint for Custody. 1. The Plaintiff, Karen L. Stoner, is an adult individual with an address of 1819 13TH Street, Altoona, Pennsylvania 16601. 2. The Defendant, Donald E. Stoner, Jr., is an adult individual with an address of 6257 Stanford Court, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. The parties are the natural parents of two (2) children, namely, Justin Stoner, born October 26, 1989; and Alexandria Stoner, born July 15, 1994. 4. The children have been in the primary physical custody of the Plaintiff since the date of separation on March 14,2003, until April 1,2005. The children were placed in the temporary physical custody of the Defendant until June 10,2005. The children now reside primarily with the Plaintiff. 5. The Plaintiff desires that the parties have shared legal custody of the minor children, Justin Stoner and Alexandria Stoner. 6. The Plaintiff desires primary physical custody of the minor children, Justin Stoner and Alexandria Stoner, with periods of temporary physical custody to Defendant as the parties can agree. 7. The best interests and permanent welfare of the minor children requires that the Court grant the Plaintiff's request as set forth above. WHEREFORE, the Plaintiff, Karen L. Stoner, respectfully requests that she be awarded primary physical custody and shared legal custody of Justin Stoner and Alexandria Stoner, as provided herein, with periods of temporary physical custody to Defendant as provided herein. Respectfully . McKmght, III, Esquire Attorney or Plaintiff 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court I. D. No. 25476 By: Date: July 26, 2005 VERIFICATION The foregoing Complaint for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. ~i:!L.!orwo Date: July 26, 2005 (~ 0. ~ .' -- ~ ~ -- -- l/{ -- ~ 0 I;;"- r ~ p..J :g ()-J C) ~ --c... 7~ ~ j~> '~f--'.,:~~, _J ","'.' :c ..-1 :"', -= -. ,,: r\ "":.\ ('."? ;,,.. <Ci f.,) '.~ <...i-I KAREN L. STONER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 05-3851 CIVIL ACTION LA W DONALD E. STONER, JR. DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, August 04, 2005 , upon consideration ofthe attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, September 09, 2005 , the conciliator, at 9:30 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 prior to scheduled hearing. FOR THE COURT. By: Isl Hubert X. Gilroy, Esq. Custody Conciliator y 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 w:f ~tf - ~ 44rl JI/:f,J .~ ~ ft I'v' ":" '?!PW-. 5v.5,$ ~e"; f" ~~Mp-/V ,%'5'$ n" ,7 \ )1, C- '1"\1 e\~7 0'::.1"'J (J-, ...' ...' l.~ .,\" v ='0 KAREN L. STONER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CML ACTION - LAW v. 2005-3851 CIVIL TERM DONALD E. STONER, JR., Defendant IN CUSTODY CUSTODY STIPULATION AND NOW, this "3-cJ.,day of September, 2005, the: parties, KAREN L. STONER and DONALD E. STONER, JR., hereby enter into the following Custody Stipulation and Agreement regarding their two (2) minor children, Justin Stoner and Alexandria Stoner: 1. The Plaintiff, Karen L. Stoner, is an adult individual with an address of 3 Chestnut Circle, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant, Donald E. Stoner, JI., is an adult individual with an address of 6257 Stanford Court, Mechanicsburg, Cumberland County, Pemlsylvania 17050. 3. The parties are the natural parents of two (2) minor children, namely, Justin Stoner, born October 26, 1989 and Alexandria Stoner, born July 15, 1994. 4. The parties shall have shared legal custody of the minor children, Justin Stoner and Alexandria Stoner. 2 5. The Plaintiff shall have primary physical custody of said minor children with periods of temporary physical custody to Defendant as the parties agree is in the best interest of said children. 6. The parties shall provide for custody of said minor children, during all holidays pursuant to their best interest. 7. The Plaintiff agrees to reside in the Cumberland Valley School District as long as she retains primary custody of said children. 8. The Plaintiff agrees that the children will have no contact with Harry James Rinker who currently resides in Altoona, Pennsylvania. 9. The parties shall keep each other advised immediately in the event of serious illness or medical emergency concerning the children, and shall take any necessary steps to ensure that the health and well-being of the children are protected. During such illness or rnedial emergency, both parties shall have the right to visit the child as often as he' or she desires consistent with the proper medical care of the children. 3 10. The parties shall not do anything that may estrange the ,children from the other party, or injure the opinion of the children as to the other party, or hamp,er the free and natural development of the children's love and affection for the other party. 11. The parties may make such alternate arrangements regarding the physical custody of the children so long as they may mutually agree. The parties anticipate regularly varying from the terms of this Stipulation in order to accommodate the schedules of each other and the children. However, if the parties cannot reach a mutual agreement, the tenns of this Stipulation and Order shall control. 12. Any modification or waiver of any other provisions of this Agreement shall be effective only if made in writing and only if executed with the same formality as this Stipulation and Agreement. 13. The parties desire that this Stipulation and Agreement be made an Order of the Court of the Court of Common Pleas of Cumberland County, and further adrnowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody of the parties' minor child who has resided in Cumberland County for more than six months and shall retain such jurisdiction should circumstances change and either party desires or requires modification of said Order. 4 14. Th, -~ -'wl.." Ifuot """ "'" "'" '"" """"''''''' "" _""" of /hi, A""""",,- - "'"" -'wl.."" "", "" _, i. "" '"" "''''''''I, '"" "", i, i, no, the result of duress or undue influence. 15. - "'"" ... "'" M o_'Y<o """",, """""",,,,, le,,, 00_ of hi, ~ "" ow<> "''''''00 Eoclt "'"" ""'"" "" ,_ of /hi, A"""""" M fiti'Md "'''''''''' Md ""'''' """.. it """" Md "I"""",y Witho", "'~"" _ My __on ,,"" """ tho" expressly set forth herein. IN "'"-S WHEREoF, tIt, -~ "- ,_ to b, I'golly """"" by tIt,_ set forth above, enter their hands and seals the date first set forth above. \lOf~ (SEAL) DONALD E. STONER, JR. (SEAL) 5 < :':\1;;'>'> .:,\J "-;.,..,:,,., ;;:\(.'i-:':;:-\t?-\i'!.-i;: ~, C-,') ~:}1 en r'-\ - ~) o -n :.--j r\~?J ~,'~E', ),,:) ~ ' '~ . ~ _ "1 \ -") ',~:} ~ \" ~.-) [ =--\ '" :.0 .-<. <...) -'-j (-:: -1 7 ,.. )'RECFIVEO SEP 142005 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA KAREN L. STONER, Plaintiff v. CIVIL ACTION - LAW 2005-3851 CIVIL TERM DONALD E. STONER, JR., Defendant IN CUSTODY ORDER OF COURT tl" AND NOW, this ,f day of September 200S, upon presentation and consideration of the attached Custody Stipulation and Agreement, it is hereby Ordered and Directed that it be entered as an Order of Court. J. Marcus A. McKnight, III, Esq. Attorney for Plaintiff Lori K. Serratelli, Esq. Attorney for Defendant ~ ~ 'I-It.of ~ . VIN\;lAlASNN.:Jd JJ.Nno:} ni'"t11~:~38~n~ S8 :2 Wd S I d3S SOUl AtI\llONOH10tJd 3111 :10 3ClI:J:lCl--C131lj