Loading...
HomeMy WebLinkAbout02-1317CATHERINE E. STONER, Plaintiff JAMES A. STONER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERId~D COUNTY, PENNSYLVANIA NO. 02- J~]q CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Catherine E. Stoner, residing at $19 S. Middlesex Road, Carlisle, Cumberland County, Pennsylvania. 2. The defendant is James A. Stoner, residing at P.O. Box 21, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following children: Name Present Residence Zachary J. Stoner 519 S. Middlesex Road 16 Carlisle, PA 17013 Justin R.T. Stoner 519 S. Middlesex Road 15 Carlisle, PA 17013 The children were not born out of wedlock. The children are presently in the custody of their mother who resides at $19 S. Middlesex Road, Carlisle, PA. During the past twelve years, the children have resided with the following persons and at the following addresses: Person Address Dates Catherine E. Stoner $19 S. Middlesex Road 1/17/02 to present Carlisle, PA 17013 Catherine & James Stoner " 1990 to 1/17/02 The mother of the children is Catherine E. Stoner, currently residing at 519 S. Middlesex Road, Carlisle, PA. She is married. The father of the children is James A. Stoner, currently residing at P.O. Box 21, Carlisle, PA. He is married. 4. The relationship of plaintiff to the children is that of mother. The plaintiff currently resides with the following persons: Name Relationship Zachary and Justin Stoner ' Subject children $. The relationship of defendant to the child is that of father. The defendant currently resides with the following persons: Name Relationship unknown unknown 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person riot 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. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: a) Plaintiff can provide the children with a home with adequate moral, emotional and physical surroundings as required to meet the children's needs; b) Plaintiff is willing to accept custody of the children; c) Plaintiff continues to exercise parental duties and enjoys the love and affection of the children. 8. Each parent whose parental rights to the children has not been terminated and the person who has physical custody of the children 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 children 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 her custody of the children. ~L~dsay Dar~al~rd, Es4u~re ~ 37 South Hanover CarIisIe, PA 17013 Attorney for Plaintiff I verify that to best of my knowledge and belief, 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 unsworn falsification to authorities. Catherine E. Stoner, Plaintiff CATHERINE E. STONER PLAIN'IYFF V. JAMES A, STONER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-1317 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, March 25, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, May 01, 2002 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 ora 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: /s/ ]acqueline M. Verney. Esq. Custody Conciliator 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 HAVE 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Rpr 2g 02-11:2am BRIRD LRW OFFICE 717-243-Bl10~ p.2 CATHERINE E. STONER, Plaintiff JAMES A. STONER, Defendant :IN THE COURT Of COMMON PLEAS Of :CUMBERLAND COUNTY, PENNSYLVANIA No. 02- /~/~" CIVILTERM -IN CUSTODY STIPULATION FOR CUSTODY made this ~C~ day of ~/-~"J-' ,2002, between Catherine E. Stoner, STIPULATION hereinafter referred to as Mother, and James~toner, hereinafter referred to as Father. WHEREAS, the above-named Mother an0 Father had bom to them the following children on the following dates: Zachar~ J. Stoner Justin R.T. Stoner January 31, 1985 April 30, 1986 AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the oustody of the above-said children and to the partial custody rights of the non-cuslodial parent: NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and Father hereby stipulate that:: 1. Mother and Fa[her shall share legal custody of the children. 2. Mother shall have primary physical custody of the child. 3. Father shall have periods of partial custody at times agreed upon by the parties. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire ta have the Stipulation entered as an Order of Court. Witness: Catherine E. Stoner, Mother · Stoner, Father CATHERINE E. STONER, Plaintiff JAMES A. STONER, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA : No. 02- 1317 CIVIL TERM · IN CUSTODY ORDER OF COURT AND NOW, this ~ day of ~~__, 2002, upon consideration of the attached custody stipulation with respect to the parties' children, Zachary J. Stoner, born January 31, 1985, and Justin R. T. Stoner, born April 30, 1986, the terms of the stipulation are entered as an order of court. BY THE COURT, Lindsay Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 Attorney for Plaintiff Diane M. Dils, Esquire 1017 North Front Street Harrisburg, PA 17102 Attorney for Defendant OCT 0 ~ ~00~ CATHERINE E. STONER, Plaintiff V. JAMES A. STONER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-1317 CIVIL TERM : : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 3rd day of October, 2002, the Conciliator being notified that the parties have reached an agreement regarding custody, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, /~ltacql~line M. Vemey, Esquire, Cus~ciy Conciliator .LO0 ~0