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Home My WebLink About01-0484 FX ~ ~~ ..., ,", ,. ,.I, C,' _"" " i'~,;__';, 0,'" , ' , . . . . . .. ~~ ~ ~~ ~ ~ ~ ~~ ~~ ~ ~ ~ ~~~~~ . . c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . PENNA. STATE OF No. 01-484 CIVIL TERM . DECREE IN DIVORCE AND NOW,OlIoirv- 1- 2001 , IT IS ORDERED AND . it {(:q,~,( DECREED THAT SUSAN D. KOELLNER PLAINTIFF, . . . . MARK S. KOELLNER , DEFENDANT, AND . ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE . BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE . . ~' ~~ OTHONO~ARY . . . . . ~ ~"'~ ~ ~ ~ ~ ~ ~ ~ . ~"'~~~ ... . . . ''..,-.i,.";'''' ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . SUSAN D. KOELLNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 01-484 CIVIL TERM MARK S. KOELLNER, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD o THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a ivorce decree: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c). 2. Date and manner of service of the Complaint: Acceptance of Service filed by Plaintiff's ounsel indicating service on or about 5 February 2001. 3. Complete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: By Plaintiff: 20 August 2001 By Defendant: 20 August 2001 (b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 4. Related claims pending: None. 5. Complete either (a) or (b): (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Dated 20 August 2001, filed contemporaneously herewith. Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Dated 20 August 2001, filed contemporaneously herewith. Date: 2-9 ~~+2.ml By~,.~9 Attorney for Plaintiff II YiARY o 'I f~.Ur;? 9 t\f~l g: SL;. CUtv'ibLi":; L/~i\JJ COUNTY PEr'\f\!SYLVANi!\ , '"" , 1 , 4. .. SUSAN D. KOELLNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 01-484 CIVIL TERM MARK S. KOELLNER, Defendant IN DIVORCE ~D DOME~NS ORDER AND NOW this ~ day of ~ ' 2001, upon the joint , motion of the parties, and to implement a provision of their Property Settlement Agreement i dated, May 14, 2001, and in accordance with the Domestic Law of Pennsylvania, we hereby ! find as follows: ! A. The above-named parties are Husband and Wife and have requested this Court, in !accordance with the Domestic Law of Pennsylvania and in accordance with the terms of a i !Property Settlement Agreement signed by them and dated May 14, 2001, and in connection with the final decree of divorce to be entered in this matter, to enter a Qualified Domestic Relations Order pursuant to Section 408 (d) (6) of the United States Internal Revenue Code. B. The Defendant herein is Mark S. Koellner, an adult individual who resides at 344 ,Hillside Drive in New Cumberland, Cumberland County, Pennsylvania. He is an adult and his IsoCial security number is 480-82-4813. He is the owner of and the participant in an " individual retirement account held for his benefit by the Prudential Insurance Company of American. which is identified as Contract No. E0116557 (hereinafter referred to as the "Plan") in which he had funds on deposit as of 31 December 2000 in the approximate amount of $63,794.66. The Defendant is the plan participant with regard to the Plan and is referred to hereinafter as "Participant". C. The Plaintiff herein is Susan D. Koellner, an adult individual who resides at 15 'George Circle in Mechanicsburg, Cumberland County, Pennsylvania. She is an adult and her ~ - ~~~, ..T . . ocial security number is 228-94-7152. She is referred to hereinafter as the "Alternate D. Participant and Alternate Payee have agreed that Participant shall transfer from the lan, into an IRA held by the Alternate Payee, the sum of $17,000.00, increased or ecreased by investment activity within the Plan after 14 May 2001, pursuant to a Qualified omestic Relations Order entered in this divorce action and the parties wish to have that rder entered to accomplish the transfer in accordance with the Internal Revenue Code so as o make it a tax-free rollover of tax deferred assets. ! NOW, THEREFORE, based upon the above findings and the joint motion of the parties, nd the Domestic Law of the Commonwealth of Pennsylvania, we hereby order and decree s follows: 1. The Plan shall, promptly upon a receipt of a copy of this Order, transfer and emove from Participant's IRA (Contract No. E0116557) the sum of $17,000.00, increased r decreased by investment activity within the said IRA from and after the date of 14 May 001. 2. The funds transferred and removed from the Participant's IRA pursuant to Paragraph 1 hereof, shall be transferred and delivered to an individual retirement account eld for the benefit of Alternate Payee with Oppeheimer Funds, (being identified as Account No. 702 7022 634434 857 8570 246466) to be held in accordance with the terms and Irovisions of the Alternate Payee's individual retirement account documents. ! 3. Following the transfer of funds contemplated by Paragraphs 1 and 2 hereof, Participant shall be the sole owner of the funds and assets remaining in the Plan, free of any urther claim by Alternate Payee, and Alternate Payee shall be the sole and exclusive owner f the funds and assets in her individual retirement account, free of any further claim by Participant. 4. Participant and Alternate Payee shall comply fully with the provisions of the Internal Revenue Code and the regulations duly promulgated pursuant thereto, specifically I · including, without limitation, Section 414 (p) (4) (A) (i) of the Internal Revenue Code. II - ~ ~ . . - 5. This order is intended to be and shall be treated by all persons and entities as a ualified Domestic Relations Order, as defined by the United States Internal Revenue Code nd it is the intention of this Order, and this Court, that the transfer of funds made pursuant o this Order shall be a tax-free rollover of retirement assets. 6. This Court shall retain jurisdiction of this matter for purposes of interpreting, pplying, amending, or enforcing the terms and provisions of this order. BY THE COURT, J. I ! ~ ; i! i " " II ~', 'l.iM~i'lllilliim!D-b,- ~-.' * '~~.\t~I~M!ili,#w;,',;,_~ r ......~' .' ""'''''"', -','",-""',' . lilNV/',lASNN3d 'I ~!'I"nrl rq~!::L!'ln:) 1\_. j',j\, " ,._"..,'! .'. 9~ :r~ 11 '-1"10 ! n l "I 'I'., :~I~:i C' ,'" '-'"_04'" ... .r .. ';, . i " .. . SUSAN D. KOELLNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW \ NO. 01-484 CIVIL TERM MARK S. KOELLNER, Defendant IN DIVORCE JOINT MOTION FOR ENTRY OF QUALIFIED DOMESTIC RELATIONS ORDER AND NOW comes the above-named parties and jointly move the court to enter the ttached Qualified Domestic Relations Order to implement a provision of the Property ettlement Agreement signed by them on May 14, 2001. -nd~ ~. KOELLNER Date: 7- ?tf-I/ . USAN D. KOELLNER i:' I' Date: /}-/()-()/ ,':>-'~" """",~~. -"'-~i~iiiIt*l'ii~!l!iil~,_~""~~~~~" ;"~~~.1IUIlil& .. . .~" "~". ,~,,' ." ~,,_.'--' "" . , ....J. . '. . .... # (") c-:' C ~~~ 'j:;'", eJ f";' ,~ rn r.::: '.::~) :;-~ ?= ;~~ " ,) ~ \..'.::) r:: C ",. ~ (-,:! 5> Ci w C 2: :n --...: -' '::'0 ~ -, .,...,J -< ~," " -,"- .. ..;. , SUSAN D. KOELLNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA vs. CIVIL ACTION - LAW MARK S. KOELLNER. Defendant NO.(}/- LJ8l./ Ct'Ot'/ IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the foregoing pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 II .. , - SUSAN D. KOELLNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. MARK S. KOELLNER, Defendant IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. ;1 /I ~,,' > . ... , SUSAN D. KOELLNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. cPl-'IJ>'I ~ t..u-- MARK S. KOELLNER, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, SUSAN D. KOELLNER, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is SUSAN D. KOELLNER, an adult individual who currently resides at 32 North Ben Hogan Drive in Etters, York County, Pennsylvania. 2. The Defendant is MARK S. KOELLNER, an adult individual who currently resides at 1150 Brockton Circle in New Cumberland, Cumberland County, Pennsylvania. 3. Both the Plqintiff and Defendant have been bona fide residence of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 4 August 1984. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. Date: 1- /:?-t1/ _ x1)j.A041 -' Jj ~c-e J jfU J/~ SUSAN D. KOELLNER ~ Samue L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 II SUSAN D. KOELLNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 01-484 CIVIL TERM MARK S. KOELLNER, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (cl of the Divorce Code was filed on 24 January 2001 and served upon the Defendant on or about 5 February 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. I consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~t0;t. dC), (Z()C)/ Date .kill JfJ J}( ./ ~ _.A M J,J fI.L, I SUSAN D. KOELLNER -'-''"~ ~~" '-"~~ = ... 1 ...,-,- ~"n!!l!-"lt.~~~!Ollll.\1f~"'" '~"'-_l'Jl!iii ,,~~ ,,_ ,~= ~,",-",~,,'.__~ ,""' r~' ".' < ~" "..iin.tdl~' " ~ '" -~ tkL ;,--'-"~',' '. ,'~'~" -, o ,-" ~ -"'JC' rhr:~: ~S c::: i~ ......~, =< ,', ~ - ,~ ~ '~<' :t:ilo ;:.,'") i"\',; l"c;. If,.) ~.- n- ;:f :1] -< :)1 (...) ~" ~~ ,', ,,~,0"~" ~. .. "'i~ , r 8 !1 ;" ~l ! Ii Ii II Ii I: ~ , I I I I I d . SUSAN D. KOELLNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 01-484 CIVIL TERM MARK S. KOEL.LNER, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 24 January 2001 and served upon the Defendant on or about 5 February 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. I consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Ol1tt"nt 020,r9-0/ Date -nt~5(/~- MARK S. KOELLNER ,'i,!i.',', '~~,~'Z~ijZ~-,:.i;.s.;:;,~;,2::.i.;;S'o-:,:;~,f'i7'2O;.;:E.:~ ':;~,'-7,_ ";~: ;I"r::;:....'~U;.;.;:i:.',"-;'-;;:::.'-'"--,,=c---~.;-"'~-o~'~""'=='~::!:'- , ",1 ~ !!~I :~; 29 r.i'"j ':}; ~,~~ CUI'i:b::Oi..iLJ ,,;uu;\rry PENNSYLVN'iLiI I I . . I I I I ~ " "C" ~:'_~'" ;"';;' SUSAN D. KOELLNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 01-484 CIVIL TERM MARK S. KOELLNER, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 ICI OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. flu q.t iLl.;/-. ::71'1 a()()/ Date ~5~ MARK S KOELLNER :C;':'::'":~::''-;; "'.'ii"-:::,'"~::;:,,,"""-,:3.i,~;~o, ';'''-;'''''''";",:3~:~&~~w",.'~c,,,,",.o,~';:;'l',,,,,,~b;l,at>0 --.-'''~~ ::;-., ~ ;-":':,n',\!OTARY ~'il ,'!l('?Q f,~J Q. c~ u', J-.I~._,;,'~ ,",.,# n, j ",' ,.1..... cu",c"-,, i, 'I ' n("';ut\ITY' . l\'il-iC:!,_n,' LJ 1..) j " PEriNSYLVN-JiA I I , ~:i i I . i I i I I ~ .. .. ~ ' " " "D,'-( ,," ' , ' " '- quO," SUSAN D. KOELLNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 01-484 CIVIL TERM MARK S. KOELLNER, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 ICI OF THE DIVOR~E CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. f1-!!f}Lu:J;;L <:2L) ,4 t'J '" / Date .x;}J lDn fJ, I)I'1-U j /lO Cj SUSAN D. KOELLNER :iiiIIl:I''"''''"'~'''~~~[;J" ~"""''i!~.Iil4~killll',@i;H!~tj~IlI;l':lt''''''''~ 'u>l\l.klll ~ ~--- ~..".-. ,~ '.=.'~ ""fii~iR~1 .~ , , '.'~"" --~ ',," "',',:,,'C () c- .-';:' -op;;~, !P!~r ::2(.. (I) c,., ::<:'" r--"::':--- K~"'" :f;:C) "'~t...... >"--} c: ?.: :;:'1 __~,' ,= ,n',_ ^'. .,. 1~ :'~;: ~, I"\) \.0 J~', :::: ~c ~n (......) ;'1 u i1 11 I: L: I: Ii I! ;j ~ lj [1 C::) C) --1'1 . . . il. SUSAN D. KOELLNER, PLAINTIFF ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 01-484 CIVIL TERM MARK S. KOELLNER, DEFENDANT IN DIVORCE ACCEPTANCE OF SERVICE The undersigned, MARK S. KOELLNER, does hereby accept service of the Divorce Complaint filed against him in this matter and acknowledges receipt of a certified copy of that Complaint. Date: ct;?--os -0 / ?1/../ ~/~ MARK S. KOELLNER If Ci-' -; ik!'C9ii(?\~T,6\RY O I Fcfl .. '-1 Pj"I' 2: 31. 1,,,, ;~, . ",.,. C' /'/";':, " ;".1,', ('10' UN1Y \...d' li.X~1 "ILi "'10 V j PENNSYLVANIA ~ _""","",.~"",,,",,w,""""=''''''''=:;;;='''''=='''~'''''' .:;;;:::;:,",,::..::,a I I I ~ ! ~ ~ I . =.~":;:~-~~,;:;,~=-."';~.'~.","~, >" -" . . '>.-,--'" ~ JILL ANN KULIG, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION - LAW NO. 01-484 DANIEL K. KULIG, Defendant IN CUSTODY ORDER OF COURT AND NOW this t~ ~ day of M 11 ' 200.3. ,upon the Stipulation of the parties by their attorneys, we hereby modify our interim order of court dated March 12, 2001 and replace it with the following: 1. LEGAL CUSTODY. The parties, Jill Ann Kulig and Daniel K. Kulig shall have shared legal custody of the minor chid, Gabrielle Marie Kulig, born December 14, 1993. 2. PHYSICAL CUSTODY. The parties shall have shared physical custody in accordance with the following schedule: A. Father shall have the child each Monday at 4:00 p.m. until Wednesday morning when the child has returned to school or daycare. B. On alternating weekends to commence March 2, 2001, Father shall have physical custody from Friday at 4:00 p.m. until Monday when he returns the child to school or daycare. C. In the event that the child is out of school, the parent who has custody for that night shall have the responsibility to arrange for the child's care during that day. 3. VACATION. Each parent shall be entitled to two non-consecutive seven-day periods of vacation time. Such vacation time shall run from Friday at 4:00 p.m. until the following Friday at 4:00 p.m. and shall commence with the weekend of the vacationing parent. The parties shall provide each other with at least a thirty-day notice of their vacation plan. In the event that the parties have chosen conflicting vacation schedules, the party first providing written notice to the other parent shall prevail. The holiday schedule shall take precedence over vacation. 4. HOLIDAYS. Holidays shall be arranged as follows: Odd Years Even Years Easter Independence Day Thanksgiving New Year's Eve New Year's Day Mother Mother Father Father Mother Father Father Mother Mother Father II . .. '. The custodial period for Easter, Independence Day, Thanksgiving, New Year's Eve and New Year's Day shall be from 6:00 p.m. the day before the holiday until 6:00 p.m. the day of the holiday. In addition, Father shall have the child each Father's Day, from 6:00 p.m. the day before until 6:00 p.m. on Father's Day, and Mother shall have the child each Mother's Day, from 6:00 p.m. the day before until 6:00 p.m. on Monday's Day. Further, whichever parent does not have physical custody of the child on the child's birthday (December 14 of each year) shall be entitled to have the child from 3:00 p.m. until 6:00 p.m. 5. CHRISTMAS. Christmas shall be shared in accordance with an A/B schedule. Segment A of the Christmas holiday shall run from 6:00 p.m. on December 23,d until 10:00 p.m. on December 24th. Segment B shall run from December 24th at 10:00 p.m. until December 25th at 10:00 p.m. In odd-numbered years Father shall have Segment A and Mother shall have Segment B. In even-numbered years Mother shall have Segment A and Father shall have Segment B. 6. MEMORIAL DAY / lABOR DAY. In odd-numbered years Father shall have Memorial Day weekend and Mother shall have labor Day weekend. In even-numbered years Mother shall have Memorial Day weekend and Father shall have labor Day weekend. Memorial Day and labor Day holiday shall not change the schedule for alternating weekends. 7. The parties shall participate in co-parenting counseling which shall be provided through Mother's Employee Assistance Program, unless otherwise agreed. The focus of this counseling shall be to assist the parents in improving communication regarding child custody issues and to aid them in supporting their child as she adjusts to their separation. BY THE COURT, Distribution: Samuel L. Andes, Esquire (Attorney for Plaintiff) P.O. Box 168, lemoyne, Pa 17043 Mary A. Etter Dissinger, Esquire (Attorney for Defendant) 28 North 320d Street, Camp Hill, PA 17011 1/ J. <:r<<';~ j'. /3.0.3 G- J JILL ANN KULIG, vs. DANIEL K. KULIG, Plaintiff Defendant s'_'. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-484 IN CUSTODY STIPULATION AND NOW come the above-named parties, with their attorneys, and stipulate and agree that the order of March 12, 2001 previously entered in this case shall be modified and replaced with the attached order. ~; tlu 'It/lit III Ann Kulig ~ II tY/(J3 ~,,~~ el L. An es Zf.:,~c.'o~ Attorney for Plaintiff ~~cf~~.' Mary A. Etter Dissinger Attorney for Defendant . ," ,- I FllED-QmCE OJ: TI '~. -I"."'l'~l '!-.~IRY I ,,-.:to_ \', ':1,)' i-,:,_ i,..j'_}lr-. 0'3 tWt - 1 f\H 8: 1 9 CU~ '.:-',1">;'"; -,- ,'"""'.' ",q-,.; lVIDC1r."f:.,j v'-)u;'~ I I PENi\SYLV;\NJA ~ I ~ I ~ I ~ I I