HomeMy WebLinkAbout94-05344
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AMANDA S, STOUT,
Plaintiff
tIN THE COURT OF COMMON PLEAS OF
'CUMBERLAND COUNTY, PENNSYLVANIA
,
INO. 5344 - CIVIL - 1994
I
I
ICIVIL ACTION - CUSTODY
v
TERRY L, STOUT,
Defendant
COURT ORDER
AND NOW, this 1.'fH.day of ~ , 1995, it is ordered and
directed as folIGWBt -,
1,
..
A Hearing is scheduled in Courtroom No, of the Cumberland
County Courthouse on the 1:..!..:.!.' day of '.' r:-,,', .' 1995,
at II Ii' (j,M. at which time testimony in t e above case will
be heard, At this Hearing, the Mother, Amanda S, Stout,
shall be deemed to be the moving party and shall proceed
initially with testimony, Counsel for the parties shall
file wi~h the Court and opposing counsel a Memorandum
set~ing forth the history of the custody in this case,
a 1 ist n[ IIi tnesses that will be called to testify at
the Head. ng, and a summary of the anticipated testimony
of each witness, This Memorandum shall be filed at least
ten days prior to the mentioned Hearing date.
Pending further Order of this Court, the Court enters a
Temporary Order whereby the Fath~r, Terry L. Stout, and
the Mother, Amanda S. Stout, shall enjoy shared legal
and snared physical custody of Dustin R, Stout, born
March 23, 1987, Brittany N. Stout, born May 14, 1990,
and Cody 0, Stout, born July 28, 1992. Physical custody
of the minor children shall be handled as fo110wst
2,
A. For the remainder of the summer months, the parties
shall al ternate physical custody on a weekly basis,
B. Fo.r. the school year starting in the fall of 1995,
the Mother shall have physical custody on three out
of (our weekends from Friday at 4 P,M. until Sunday
at 8 P.M. Mother shall also have custody during
th~ week from Wednesday at 1 P,M. until Thursday
at 6 P.M, Father sha.Il have physical custody of
the minor chi,ldren when the children are not in the
custody of the Mother.
3, The restriction in the prior Orders relating to Mr,
Marlin Drownawell is removed from the Custody Order,
4. Baoh party shall have reasonable telephone oontaot with
the minor children during the time that the children are
in the custody of the other parent, For transportation,
the non-custodial parent shall pick up the children at
the other parent's home,
5, During the school year, it is noted that the Mother is
unemployed and that the Father may be working, Father
shall advise the Mother on sunday of each week as to
what days he will be working the following week, During
those days when the Father is working and the Mother is
available to care for the younger child, Cody, Mother
shall have the opportunity of providing daycare for the
younger child while the Father is working, The parties
shall arrange between themselves to share transportation
for exchange of custody on those days.
BY THE COURT,
Jud
,
00' Joan Carey, Esquire
Stephen B, Lips~n, Esquire
c. '''r\~'''~.'- "....,: t ,.l
AMANDA S, STOUT,
Plaintiff
v
IIN THE COURT OF COMMON PLEAS OF
ICUMBERLAND COUNTY, PENNSYLVANIA
I
INO, 5344 - CIVIL - 1994
I
I
ICIVIL ACTION - CUSTODY
TERRY L. STOUT,
Defendant
PRIOR JUDaEI JUDGE J, WESLEY OLER, JR.
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915,3-8(b), the undersigned Custody Conciliator submits the
following reportl
1. The pertinent information pertainir.g to the children who are
the subject of this litigation is as follows:
Dustin R, Stout, born March 23, 1987, Brittany N, Stout, born
May 14, 1990, and Cody o. Stout, born July 28, 1992,
2, A Conciliation Conference was held on July 14, 1995, with the
following individuals in attendance:
,
The Father, Terry L, Stout, with his counsel, Stephen B,
Lipson, Esquire, and the Mother, Amanda S. Stout, with her
counsel, Joan Carey, Esquire.
3, This is the third Conciliation Conference held in this case,
The initinl Conference was in February and took place after
the Mother had delivered custody of the children to the
Father when the Mother did not have housing, At that time,
the parties agreed to the entry of a Temporary Order whereby
the Father was primary physical custodian with the Mother
having periods of temporary custody. The second Conciliation
Conference was in late May at which time the parties
essentially continued the prior Order for the remainder of
the sch~ol year and agreed upon an alternating week schedule
for custody during the slimmer months.
4, The parties are now before the Conciliator and the Mother is
seeking the return of primary physical custody to her, The
Father is suggesting that the children should remain in his
custody. A Hearing cannot be scheduled until after the
start of the school year, so some type of Temporary Order
needs to be issued in order for the children to start
attending school.
. '
.
5, ~he Mother expresses serious concerns over the Father's
unwillingness to abide by the prior Order and send all
three children to visit the Mother as scheduled, ~he
Father suggests that some of the children have been
reluctant to go with the Mother, The parties also
disagree on which parent is better able to be the
primary custodian for the childr6n during the school
year,
6, ~he prior Orders included a restriction that Mr, Marlin
Brownawell, II, would not be in the company of the children
while the children were with their Mother. The Mother had
agreed to this previously, but now seeks to have this
restriction lifted, There is no evidence that Mr, Brownawell
has been abusive to the children. The Father expresses
concern about Mr. Brownawell merely because he has a simple
assault charge to which he plead guilty and because the
Father believes that Mr, Brownawell has a short temper,
Absent objective information suggesting that Mr, Brownawell
has in any way threatened or abused the children, the
Conciliator does not feel that such a restriction needs to
continue unless the Mother was in agreement,
7, In light of the fact that the minor children have been
under the primary custody of the Father since the fall of
1994, the Conciliator feels that the children should be in
the primary custody of the Father starting into the school
year. This recommendation is not to be construed as the
Conciliator feeling the Father is the better primary
custodian. The recommendation is based solely on the fact
that the Father has been the primary custodian since last
October. It is anticipated that evidence will be produced
at a Hearing in this case which will allow the Court to
make an appropriate choice on the issue of primary
custodian,
8, The Conciliator recommends an Order in the form as
attached,
1!t<(/q S-
DATE
Hubert x. Gilroy, Es
Custody Conciliator
.'
AMANDA S. STOUT, I ,IN THE\~OURT OF COMMON PLEAS OF
plaintifff!CI I :tmNBSR ND COUNTY, PENNSYLVANIA
I
V. I 94-6344 CIVIL TERM
I
TERRY L. STOUT, I CIVIL ACTION - LAW
Defendant c IN CUSTODY
ORDER OF COURT
AND NOW, this 27th day of september, 1995, with
respect to the custody of the parties' children, Dustin R,
stout, born March 23, 1987, Brittany N, stout. born May 14,
1990, and Cody 0, stout, born July 28, 1992, and following a
heari~g it is ordered and directed as follows:
1, Legal custody of the said children shall be
shared by the parties,
2, Physical custody of the said children shall
be as follows:
(a) During the summer months the parties
shall alternate physical custody on a weekly basis.
(b) During the school year, the mother shall
have physical custody on three out of four weeks from Friday at
4:00 p.m, until Sunday at 8:00 p.m. The mother shall also have
custody during the week from Wednesday at 1:00 p.m. until
Thursday at 6:00 p.m., so long as such custody does not
interfere with the school day for a given child, Father shall
have physical custody of the said children when the children are
not in the custody of the mother.
"
,
3, Each of the partieG shall have reasonable
telephone contact with the said children during the time that
the children are in the cUBtody of the other parent.
4. For tranBportation, the non-custodial parent
shall pick up the children at the other parent's home.
5. On ChriBtmas day and Thanksgiving day the
children Bhall be in the physical cUBtody of the mother from
9:00 a.m. until 1:00 p.m, and in the physical custody of the
father from 1:00 p.m. to 6:00 p.m. notwithstanding any other
~rovisions of this order.
By the Court,
Joan Carey, Esquire
For the Plaintiff
_ L, \}'.' "",""'\ lei'" /95
U' 0) .s, "
stephen B. Lipson, Esquire '. .1.". ""'..,.le, '.)..'.., '" lei f,:,-
For the Defendant ,. ~ ",~'~ ~ ,j , ...g,31
It
.
7, Neither party Bhall do anything which may estrango the
children from the other parent, or injure the opinion of the
children as to the other parent or which may hamper the free
and natural development of the children's love or respect for the
other parent,
By the Court,
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AMANDA S, S'l'OUT, l:IN THE COURT 01' CONNON PLEAS OF
Plaintiff 'CUMBERLAND COUNTY, PENNSYLVANIA
,
v 'NO, 5344 - CIVIL - 1994
,
TERRY L. S'l'OUT, ,
Defendant :CIVIL ACTION - CUSTODY
COURT ORDER
AND NOW, this 1..J day of ~ l1 "L. , 1995, upon consideration
of the attachedCustody Conciliation Report, it is ordered and
directed as follows:
1, The Father, Terry L. Stout, and the Mother, Amanda S, Stout,
shall enjoy shared legal custody of Dustin R. Stout, born
March 23, 1987, Brittany N, Stout, born May 14, 1990, and
Cody 0, Stout, born July 28, 1992.
2, The Father shall enjoy primary physical custody of the minor
children,
3, The Mother shall enjoy temporary physical custody of the
minor children as follows:
A, On three out of four weekends from Saturday at noon
until Sunday at 5 P,M, This overnight temporary
custody shall be at the home of Christopher Smith or
at the home of some other adult individual as the
parties may agree upon, Mother shall insure that she
is with the children personally during overnight
custody and she shall also insure that she provides
appropriate sleeping accommodations for the children,
B, On every Wednesday from 1 P.M. until 9 P,M,
4, Father shall handle all transportation for exchange of custody,
5, Mother shall be afforded reasonable telephone contact with the
minor children, with the times to be at a minimum of every
Tuesday and Thursday evening.
6, While the children are in the custody of the Mother, the Mother
shall not allow Marlin Brownawell, II, to be with the children
unsupervised by the Mother, While the children are in the
custody of the Father, the Father shall not permit the children
to be in the custody of Lori Smith unsupervised by the Father,
,
(
(
LEGAL SERVICES, INC.
8 Irvine Row
Curll~le, Pennsylvania 17013
(717) 243.~4IK)
FlIX (717) 243.H021\
,
Wesl Shure (717) 71\1\,H47S
September 9. 1994
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11.7)'.II5,'IIU
Mr, Terry Stout
801 Gutshall Road
Bailing Springs, PA 17007
Dear Mr. stout:
Amanda Stout recently came to our office to discuss
incidents in which she says you physically abused her and
threatened to abuee her, She has been advised of the criminal
and civil remedies available to her.
You should be aware that the criminal laws apply to acts of
violence even when they occur between boyfriend and girlfriend
(husband and wife) (members of the same household). The penalty
for simple assault, which can include "attempts by physical
msnace to put another in fear of imminent serious bodi ly injury"
is up to two years imprisonment and a $6,000,00 fine. For
harassment (including striking, shoving, kicking, alarming or
seriously annoying a person), the puniShment is up to a $300.00
fine and 90 days imprisonment, Harassment by communication is
also a crime punishable by up to one year in prison or a $2600
fine. The crime of stalking includes engaging in a course of
conduct such as following someone without proper authority
intending to cause the person fear of bodily injury or
substantial emotional distress. Stalking is punishable by
imprisonment for up to seven years.
Ms. Stout has also been advised of a civil remedy available
under the Protection from Abuse Act. Under this Act, she can
petition the court to issue a Protective Order. If such an order
is entered, it will be placed on file with the police, and if you
violate the order, you will be taken before the judge who issued
the order, The judge will then decide what puniShment is
appropriate, A person who violates such an order can be
imprisoned for up to six months,
Ms. Stout does not wish to pursue her legal remedies against
you at this time, but she does want you to be aware that if there
is further violence or threat of vi01ence towerd her she ie
prepared to take legal action.
I hope your awareness of the consequences of violent acts
will help to prevent the recurrence of such acts in the future.
I wou 1 d a Iso 1 i ke you to be aware that there are counsel ore in
I
PLAINTIFF'.
EXHIBIT
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SERVING ADAMS. CUMBERLAND, FRANKLIN AND FULTON COUNTIES
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, IN THE COURT OF COMMON PLEAS OF
'CUMBERLAND COUNTY, PENNSYLVANIA
,
,NO. 5344 - CIVIL - 1994
,
AMANDA S, STOUT,
Plaintiff
TERRY L, STOUT,
Defendant
.
.
,CIVIL ACTION - CUSTODY
COURT ORDER
AND NOW, this ~ day of ~..H'c.. , 1995, upon consideration
of the attached Custody Conciliation Report, it is ordered and
directed as follows,
1, This Court's prior Order of March 2, 1995 is vacated,
2, The Father, Terry L. Stout, and the Mother, Amanda S, Stout,
shall enjoy shared legal and shared physical custody of
Dustin R, stout, born March 23, 1987, Brittney N, Stout,
born May 14, 1990, and Cody 0, Stout, born July 28, 1992,
3, Physical custody of the minor children shall be handled as
follows:
A, For the remainder of the school year, the Mother shall
have physical custody on three out of four weekends from
Friday at noon until Sunday at 6 P,M, Mother shall also
have custody during the week from Wednesday at 1 P,M,
until Thursday at 6 P.M. Father shall have physical
custody of the minor children when the children are not
in the custody of the Mother.
B, During the summer months and starting on June 11, 1995
at 6 P,M" the parties shall alternate physical custody
on a weekly basis with the children going to live with
the Mother on June 11 for the first week,
4, The parties shall meet for another Custody Conciliation
Conference on Friday, July 14, 1995, at 8:30 A,M,
5, During the time Mother is with the children, Mother shall
insure that Mr. Marlin Brownawell, II, shall not be in the
company of the children or at the home where the children
are staying. Furthermore, Mother's periods of custody with
the children sh.,ll be at the Mother's parent's home or at
any home that the Mother is able to obtain for herself,
#
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 5344 CIVIL 1994
IN CUSTODY
AMANDA S, STOUT,
Plaintiff
TERRY L. STOUT,
Defondant
ORDIlR or COURT
lIfD 1I0W, this ~,d day of 1.)...Jt'....J.v , 1994, upon
consideration of the within Petition for Modification ot Custody
Order, a hearing on Petitioner/Defendant Terry L. stout's request
for temporary physical custody pending the conciliation
conference is scheduled for the I -' t day of .L' <', '" {~':'l-j 1994
atl.L.a:.o'clock A.M., in Courtroom No. ,',-
courthouse, Carlisle, Pennsylvania.
, Cumberland county
BY THE COURT,
tl~
cc: Joan Carey, Esq.
for Respondent, Amanda S. stout
stephen B. Lipson, Esq.
tor Petitioner, Terry L. stout
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v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
AMANDA S. STOUT,
Plaintiff
TERRY L. STOUT,
Defendant
NO. 5344 CIVIL 1994
IN CUSTODY
PETITION FOR MODIFICATION
~ CUSTODY ORDIR
1. Petitioner is Defendant, TERRY L, STOUT, an adult
individual who currently resides at 601 Gutshall Road, Boiling
springs, Cumberland County, Pennsylvania.
2. Respondent is Plaintiff, AMANDA a, STOUT, an adult
individual who currently resides at 103 North Baltimore Avenue,
Mt. Holly springs, Cumberland county, Pennsylvania.
3, Respondent's counsel of record is Joan carey, Esq., of
Legal services, Inc.
4, By Order of Court dated September 16, 1994, the
Honorable J. Wesley Oler, Jr., incorporating the terms of a
consent agreement between the parties, established the respective
custody rights of the parties with regard to their three
children, namely, Dustin R, stout, d.o.b. 3/23/87, Brittany N.
stout, d.o.b. 5/14/80 and cody O. stout, d.o.b, 7/28/92. A copy
of this Order is attached hereto and incorporated herein as
Petitioner's Exhibit ~.
5. Subsequent to the entry of this Order the parties agreed
that primary phYBical and legal custody of Dustin R. stout,
d.o.b, 3/23/87 is to be given to Defendant Terry L. stout, In
fact, this change of physical custody occurred on October 3, 1994.
6. Consistent with this change of custody of Dustin the
partieB Bigned an Agreement to effectuate a Consent Order for
change of phYBical custody, However, before this Agreement could
be executed by Joan Carey, Esq" Petitioner was compelled to
take phYBical custody of the other two children as well. A copy
of the Agreement concerning Dustin is attached hereto and
incorporated herein as Petitioner'B Exhibit "B".
7, At the time of the afore-referenced change of physical
custody for DUBtin, Petitioner had significant concerns with
regard of the other two children. These problems have increased
in recent weeks, including, but not limited to:
(a) a lack of heat and hot water in Respondent's
apartment;
(b) Respondent does not change the diapers of Cody
frequently enough and occasionally runs nut of diapers;
(c) Respondent often did not put the children in bed
until after 10:00 P.M., which is too late for all of
them;
(d) there have been occasions when, at the time that
the children were picked up for Petitioner's partial
custody period, it is apparent that the children are in
need of baths;
(e) Petitioner also has grave concerns about
Respondent's supervision of the children and whether
the children have been left alone with Respondent's
boyfriend Marty Brownawell, who has not been shown to
be a suitable custodian for the children;
"-
SEP 16 199. Jc.,
, ..-..........,.J,
.
.
vs,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, ()3lflf CIVIL 1994
Amanda S, stout,
Plaintiff
Terry L, Stout,
Defendant
CUSTODY
~1!llQQY OBQfR
AND NOW, this .I~Hv day of September, 1994, upon
consideration of the parties' Consent Agreement, the following
Order is entered with regard to custody of the parties'
children, Dustin, Brittany, and Cody Stout,
1, The plaintiff, hereinafter referred to as the mother,
will have primary physical and legal custody of the children.
2, The defendant, hereinafter referred to as the father,
will have partial custody of the children every weekend from
Friday at 4:00 p,m, until Sunday at 5:00 p,m,
3, The father and mother will alternate Christmas Eve and
Christmas Day each year, one parent having the children on
Christmas Eve until Christmas Day at 10:00 a,m, and the other
parent having the children from Christmas Day at 10:00 a,m, until
Christmas Day at 8:00 p,m,
4, The parties will alternate the following holidays:
Easter, Memorial Day, the Fourth of July, Labor Day, and
Thanksgiving,
5, The father will have the right to see the children on
their birthdays at a time to be agreed upon by the mother and
father,
t
6, The father will have the right to partial custody of the
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AMANDA S. STOUT,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
TERRY L. STOUT,
Defendant
NO, 5344 CIVIL 1994
IN CUSTODY
g~HBBNT AGRBB~
This agreement is entered into thiB
day of October,
1994, by Plaintiff, Amanda S, stout and Defendant, Terry L,
stout. Plaintiff is represented by Joan carey, Esq., of Legal
Services, Inc,; Defendant is represented by Stephen B, Lipson,
Esq.
1. By Order of Court dated September 16, 1994, the Honorable
J. Wesley Oler, Jr" incorporating the terms of a consent
agreement between the parties, establiBhed the respective custody
rights of the parties with regard to their three children,
namely, Dustin R. stout, d,Q.b, 3/23/87; Brittany N. stout,
d.o.b. 5/14/90; and Cody 0, stout, d,o.b. 7/28/92.
2. Subsequent to the entry of this Order the parties have
agreed that primary physical and legal custody of Dustin R.
stout, d.o,b. 3/23/87 is to be given to Defendant Terry L. stout,
In fact, this change of physical custody occurred on October 3,
1994.
3. Plaintiff shall have reasonable partial custody with
Dustin as the parties shall agree,
4. The prior Order of Court shall continue to govern the
respective custody rights of the parties with regard to Brittany
and Cody.
v.
l~affi UvOO9lid,.~
NOV 0 7 199~ ,~L-
IN 'rilE cotJR'r Of' COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
AMANDA S. STOUT,
Plaintiff
TERRY L, STOU'r,
Defendant
NO. 5344 CIVIL 1994
IN CUSTODY
ORDER OF~.Y.&'l
AND NOW, -"ILlv 1 U, 1,,'1,'1 'I
, upon consideration of
the attached Complaint, it is hereby directed that the parties
and their respective counsel appear before H,,},)),,') f. 1,-1)/,,:.'
, the conci liator, at I. { II, rl,"" ("'h L ("
( 'J'A'~~'U<,\I on the _,~dl, day of Q"C(l'ltJrr
199.0, at --/i) ,'-5il o'clock, I!..m" for a Pre-Hearing cu!!tody
Confer.ence, 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
shall also be present at the conference. Failure to appear at
the conference may provide grounds for entry of a temporary or
permanent order.
FOR THE COURT:
/J" //,/ )(.-/~.j<c1-, (y(
Custody conciliator 'Jl"-~/'~;r
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.
By:
Office of the Court Administrator
Cumberland County Court House, Fourth Floor
Carlisle, PA 17013
(717) 240-6200
AMANDA s. S'rOUT, t IN THE COURT OF COMMON PLEAS OF
Plaintiff t CUMBERLAND COUNTY, PENNSYLVANIA
t
v. t CIVIL ACTION - LAW
t
TERRY L. STOUT, t NO. 5344 CIVIL 1994
Defendant t IN CUSTODY
ORDl!lR Ol...QQID\~
AND NOW, this ,,' ,.-:t- day of 'I" l'( ..(" ,. , 1994, upon
conBideration of the within Petition for Modification of cUstody
order, a hearing on Petitioner/Defendant Terry L, Stout's request
for temporary physical custody pending the conciliation
conference is scheduled for the 1".-\' day of t,,,. , ,..l., " , 1994
at/c:c.: o'clock Ll,M., in Courtroom No. ,~I-
Courthouse, Carlisle, Pennsylvania.
, Cumberland county
BY THE COURT,
Isl
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cc: Joan Carey, Esq.
for Respondent, Amanda S. stout
~phen B. Lipson, Esq,
~or Petitioner, Ter.ry L, stout
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M,d Ii.\.' ~...~.i (~ ~'.i'~ ~'...Jli :It C61<i!le, Pa.
Ti',ls .3.1!l GJ'Y of T1c:v:-", 19?,~..
............~"p,~;~~r.~,...-
AMANDA 6, 6'1'OU'1',
Plaintiff
v.
IN THE COUR'1' OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSVLVANIA
CIVIL ALTION - LAW
TERRY L. 6TOUT,
Defendant
NO. 5344 CIVIL 1994
IN CUSTODY
~TI9~FOR HODIFICATION
_Q.r_~j.lmLQJUU1B
1, Petitioner is Defendant, TERRY L, STOUT, an adult
individual who currently resides at 601 Gutshall Road, Boiling
Springs, Cumberland County, Pennsylvania.
2, Respondent is Plaintiff, AMANDA S, STOUT, an adult
individual who currently resides at 103 North Baltimore Avenue,
Mt. Holly Springs, Cumberland county, Pennsylvania,
3. Respondent's counsel of record is Joan Carey, Esq., of
Legal Servic~s, Inc.
4, By Order of Court dated September 16, 1994, the
Honorable J, Wesley Oler, Jr" incorporating the terms of a
consent agreement between the parties, established the respective
custody rights of the parties with regard to their three
children, namely, Dustin R. stout, d.o.b. 3/23/87, Brittany N.
Stout, d,o,b. 5/14/80 and Cody 0, stout, d.o.b. 7/28/92. A copy
of this Order is attached hereto and incorporated herein as
Petitioner's Exhibit A.
5. Subsequent to the entry of this Order the parties agreed
that primary physical and legal custody of Dustin R. stout,
d,o.b. 3/23/87 iB to be given to Defendant Terry L. stout. In
fact, this change of physical custody occurred on October 3, 1994.
6, Consistent with this change of custody of DUBtin the
parties signed an Agreement to effectuate a Consent Order for
change of physical custody. However, before thiB Agreement could
be executed by Joan carey, Esq" Petitioner was compelled to
take physical custody of the other two children as well, A copy
of the Agreement concerning Dustin is attached hereto and
incorporated herein as Petitioner's Exhibit "B",
7. At the time of the afore-referenced change of physical
custody for Dustin, Petitioner had significant concerns with
regard of the other two children, These problems have increased
in recent weeks, including, but not limited to:
(a) a lack of heat and hot water in Respondent's
apartment;
(b) Respondent does not change the diapers of Cody
frequently enough and occasionally runs out of diapers;
(c) Respondent often did not put the children in bed
until after 10:00 P,M" which is too late for all of
them;
(d) there have been occasions when, at the time that
the children were picked up for Petitioner's partial
custody period, it is apparent that the children are in
need of baths;
(e) Petitioner also has grave concerns about
Respondent's supervision of the children and whether
the children have been left alone with Respondent's
boyfriend Marty Brownawell, who has not been shown to
be a suitable custodian for the children;
0,-
SEP 16 1994 J{!.;
, ,........,.., :
" ,
Amanda S, stout,
Plaintiff
vs,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, ()3 tlt( CIVI L 1994
Terry L, Stout,
Defendant.
CUSTODY
!;:.lLSTOOY_QI3Pli.f3
AND NOW, this .llli~, day of September, 199,~, llpon
consideration of tho parties' Consent Agreement, tho following
Order is entered with regard to custody of the parties'
children, Dustin, Brittany, Hnd Cody Stout,
1, The plaintiff, hereinafter referred to OB the mothor,
will have primary physical and legal custody of the childron,
2, Tho defendant, here I nafte,' refer'rQd to 813 the father,
will have partial custody of the children every weekend from
Friday at 4:00 p,m, until Sunday at 5:00 p.m,
3, The father and mother will alternate ChristmaB Eve and
Christmas Day each year, one parent having the children on
Christmas Eve until Christmas Day at 10:00 l\,m, and the other
parent having the children from Christmas Day at 10:00 a,m, until
Christmas Day at 8:00 p,m,
4, The parties will altemate the following holidays:
Easter, Memorial Day, the Fourth of July, Labor Day, and
Thanksgiving,
5, The father will have the right to see the children on
their birthdays at a time to be agreed upon by the mother and
fathor,
6. :The father will have the right to partial custody of the
~
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v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION ... LAW
AMANDA S, STOUT,
Plaintiff
TERRY L. STOUT,
Defendant
NO. 5344 CIVIL 1994
IN CUSTODY
CONSENT AGREEMENT
This agreement is entered into this
day of October,
1994, by Plaintiff, Amanda s, stout and Defendant, Terry L.
stout. Plaintiff is represented by Joan Carey, Esq., of Legal
services, Inc.; Defendant is represented by Stephen B. Lipson,
Esq.
1. By Order of Court dated September 16, 1994, the Honorable
J, Wesley Oler, Jr" incorporating the terms of a consent
agreement between the parties, established the respective custody
rights of the parties with regard to their three children,
namely, Dustin R. stout, d,o.b, 3/23/87; Brittany N. stout,
,
d,o.b. 5/14/90; and cody 0, stout, d.o,b, 7/28/92.
2. subsequent to the entry of this Order the parties have
agreed that primary physical and legal custody of Dustin R.
stout, d,o,b. 3/23/87 is to be given to Defendant Terry L. stout.
In fact, this change of physical custody occur.ed on october 3,
1994.
3. Plaintiff shall have reasonable partial custody with
Dustin as the parties shall agree.
4. The prior Order of Court shall continue to govern the
respective custody rights of the parties with regard to Brittany
and Cody,
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Amanda S, Stout,
Plaintiff
va.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, S"N'1 CIVIL 1994
Terry L. Stout,
Defendant
CUSTODY
CU,STODY ORD.tR
AND NOW, th i s_' ell day of September, 1994, upon
consideration of the parties' Consent Agreement, the following
Order is entered with regard to custody of the parties'
children, Dustin, Brittany, and Cody Stout,
1, The plaintiff, hereinafter referred to as the mother,
will have primary physical and legal custody of the children.
2, The defendant I hereinafter referred to as the father,
will have partial custody of the children every weekend from
Friday at 4:00 p,m, until Sunday at 5:00 p,m,
3, The father and mother will alternate Christmas Eve and
Christmas Day each year, one parent having the children on
Christmas Eve until Christmas Day at 10:00 a,m, and the other
parent having the children from Christmas Day at 10:00 a,m, until
Christmas Day at 8:00 p,m,
4, The parties will alternate the folloWing holidays:
Easter, Memorial Day, the Fourth of July, Labor Day, and
Thanksgi v i ng,
5, The father will have the right to see the children on
their birthdays at a time to be agreed upon by the mother and
father,
6, The father will have the right to partial custody of the
Amanda S, Stout,
Plaintiff
va,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. CIVIL 1994
Terry L. Stout,
Defendant
CUSTODY
Wti2f.NLA..GBff,;M.fNI
of
Thia Agreement is entered on this JSL_ day of September,
1994, by the plaintiff, Amanda S, Stout, and the defendant, Terry
L, Stout, The plaintiff is represented by Joan Carey of Legal
Services, Inc.; the defendant is unrepresented but is aware of
his right to have an attorney,
The defendant and the plaintiff agree to the entry of the
following Custody Order regarding their children, Dustin,
Brittany, and Cody Stout,
1, The mother will have primary physical and legal
custody of the children,
2. The defendant, hereinafter referred to as the father,
will have partial custody of the children every weekend from
Friday at 4:00 p,m, until Sunday at 5:00 p,m,
3, The father and mother will alternate Christmas Eve and
Christmas Day each year, one parent having the children on
Christmas Eve until Christmas Day at 10:00 a,m, and the other
parent having the children from Christmas Day at 10:00 a.m, until
Christmas Day at 8:00 p.m,
4. The parties will alternate the following holidays:
Easter, Memorial Day, the Fourth of July, Labor Day, and
Thanksgiving,
.....
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Stocks; bonds:
Othe r :
(f) Debts and obligations
Mortgage: N/A ,__,
Rent: '.. ,_,,_,_J.2.~, 00
Loans: persona] $10,5,QO __'___'''__
Month 1 y Expenses: G.rQC!~rJ~s_1J9,LGQY_~L!!.CL bv food st..amos
H2.'(LQQ,;,_J~J~Phone HO, 00; E leGtrjG..,l4b 00: Gas for car
$!!Q,OQ; Insurance forc@r $3.2, OO;M t~tG,L__!tx..Q.enses lQ.Q.."QQ
(g) Persons dependent upon you for support
(Wife) (Husband) Name :,N/A
Children, if any:
Name: _pustjn Stou..t Age: ,__----.:z_ ,vears _'_
_ ,_~r i tt?lny Stout:, , 4 vears
God)' .5tO\,),t:". ___.._~ vears
4, I understand that I have a continuing obligation to
inform the court of improvement in my financial circumstances
which would permit me to pay the costs incurred herein,
5. I verify that the statements made in this affidavit are
true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa. C,S, 4904, relating to
Savings Account: $0,00__,...._____....__,_,__
Cert if i cates of DepoB it.: _ ___,..MIA......,___,...._m
Real Estate (inclllding home): ..,..,,,jjLA______
Motor veh i c 1 e: Make P9nt j !lG..__, _,_ Year _tj86
COB t $8QO"Qo,_u,,_, Amount owed__..tQ...Q...L_
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, 5,~L.jif- CIVIL 1994
Amanda 6, Stout,
Plainti ff
Terry L. Stout,
Defendant
CUSTODY
COMI:'!.A,INL f9R C!JSTO,O'r:
1, The plaintiff iB Amanda S, Stout residing at 103 N,
Baltimore Avenue, Mt. Holly Springs, Cumberland County,
Pennsylvania 17065,
2, The defendant is Terry L, Stout residing at 601 Gutshall
Road, Boiling Springs, Cumberland County, Pennsylvania 17007,
3, The plaintiff seeks custody of the following children:
~J)'I~ PCf,! .!Hmt...J:l!lf1,isl!l ns:!! Ag!!
Dustin Stout 103 N, Baltimore Ave, 7 yrs, old
Mt, Holly Springs, PA DOB 3/23/87
Brittany Stout 103 N, Baltimore Ave, 4 yrs, old
Mt, Holly Springs, PA DOB 5/14/90
Cody Stout 103 N. Baltimore Ave, 2 yrs, old
Mt, Holly Springs, PA DOB 7/28/92
Dustin Stout was born out of wedlock, Brittany and Cody
Stout were not born out of wed10ck
The children are presently in the custody of the plaintiff,
Amanda S. Stout who resides at 103 N, Baltimore Avenue, Mt, Holly
Springs, Pennsylvania.
During the past five years, the children have resided with
the following persons and at the following addresses:
Name iI_c:!c!r!l!l.!? QA!&
Plaintiff, Defendant, 78 Big Spring Terrace 7/1/89 to
IInd Dustin Stout Newville, PA 5/14/90
Plaintiff, Defendant, 78 Bi9 Spring Ter'race 5/14/90 to
Dustin and Brittany Newville, PA 2/1/91
Stout
Plaintiff, Defendant,
Dustin and Brittany
stout, and Defendant's
family
Plaintiff, Defendant,
Dustin and Brittany
Stout
Plaintiff, Defendant,
Dustin, Brittany, and
Cody Stout
Plaintiff, Dustin,
Brittany, and Cody
Stout
601 Gutshall Road
Boiling Springs, PA
2/1/91 to
5/1/91
103 N, Baltimore Ave, 5/1/91 to
Mt, Holly Springs, PA 7/28/92
103 N, Baltimore Ave, 7/28/92 to
Mt. Holly Springs, PA 9/4/94
103 N, Baltimore Ave, 9/4/94 to
Mt, Holly Springs, PA present
The mother of the children is the plaintiff, Amanda S, Stout,
currently reBiding at 103 N. Baltimore Avenue, Mt, Holly Springs,
Pennsy 1 van i a,
She is married,
The father of the children is the defendant, Terry L, Stout
currently residing at 601 Gutshall Road, Boiling Springs,
Pennsylvania,
He is married,
4, The relationship of plaintiff to the children is that of
mother, The plaintiff currently resides with the following persons:
~_Ii!J!]~
Dust in Stout
Brittany Stout
Cody Stout
RelationillQ
Son
Daughter
Son
5, The relationship of defendant to the children is that of
father, The defendant currently resides with the following
persons:
!'-!.Ml.Q
Norman Stout
Arlane Stout
Norman Stout, Jr.
Christine Stout
Christopher Stout
Samatha Stout
B~JAtj.Qn!>bJ_p
father
mother
brother
sister-in-law
nephew
neice
6. The plaintiff has not participated as a party or witness, or
in another capacity, in other litigation concerning the custody of the
children in thiB or another court,
7, The plaintiff has no information of a custody proceeding
concerning the children pending in a court of this Commonwealth.
8, The 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 viBitation rights with respect to the children,
9, The best interest and permanent welfare of the children will
be served by granting the relief requested because the plaintiff has
been the primary caretaker of the children and wants to continue in
that role,
10, Each parent whose parental rights to the children have not
been terminated and the person who has physical custody of the
children have been named as parties to this action,
WHEREFORE, the plaintiff requests this Court to grant primary
physical custody of the children to the plaintiff with partial custody
in the defendant,
Respectfully submitted,
I ~'.I'
. (,
J6~".fciey '4.'..1'--'/'-_____
Attorney for Plathtiff
LEGAL SERVICES, INC,
8 Irvine Row
Car11sle, PA 17013
(717) 243-9400
The above-named plaintiff, Amanda S. stout, verifies that
the statements made in the above Complaint are true and correct.
The plaintiff understands that false statements herein are made
sUbject to the penalties of 18 Pa, C.S. g 4904, relating to
unsworn falsification to
authorities.
:;Il~"~) 'Kl-
~da S. Stout, Plai tiff
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