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JILL ANN KULIG,
PLAINTIFF
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 6/- '-li'S'~f~
DANIEL K. KULIG,
DEFENDANT
IN CUSTODY
COMPLAINT IN CUSTODY
AND NOW comes the Plaintiff, JILL ANN KULIG, by her attorney, Samuel L. Andes,
and makes the following Complaint for Custody:
1. The Plaintiff is JILL ANN KULIG, an adult individual who resides at 35 Nathan Drive
in Enola, Cumberland County, Pennsylvania.
2. The Defendant is DANIEL K. KULIG, an adult individual who resides at 905
Maplewood Lane in Enola, Cumberland County, Pennsylvania.
3. The Plaintiff and Defendant are husband and wife.
4. The Plaintiff and Defendant are the parents of one minor child, Gabrielle Marie
Kulig, born 14 December 1993.
5. Plaintiff seeks custody of the said minor child, Gabrielle Marie Kulig.
6. The child was not born out of wedlock and are presently in the custody of the
Plaintiff.
7. During the past five years, the minor child has resided with the following persons at
the following addresses:
12/1996 through 1/2001 Plaintiff & Defendant
905 Maplewood Lane
Enola, PA 17025
1/2001 through present Plaintiff only
35 Nathan Drive
Enola, PA 17025
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8. The mother of the child is the Plaintiff who resides at the address set out above.
She is married to the Defendant.
9. The father of the child is the Defendant who resides at the address set out above.
He is married to the Plaintiff.
10. The Plaintiff is the natural mother of the child. Plaintiff currently resides with the
child.
11. The Defendant is the natural father of the child. Defendant currently resides
alone.
12. The plaintiff and defendant were the parties to a child custody action filed during a
previous separation, in which they shared legal and physical custody of their child. A copy of
that order is attached hereto and marked as Exhibit A. The order lapsed when the parties
resumed cohabitation and remarried in December of 1996.
Plaintiff knows of no other person not a party to this action already who has physical
custody of or claims to have custody or visitation rights to the said child.
13. The best interests and permanent welfare of the child will be served by granting
the relief requested by Plaintiff for the following reasons:
A. She has provided the primary care for the child for the past several
years; and
B. Because of her age and other factors, the child will be better served by
being in the custody of Plaintiff; and
C. Plaintiff is better able to meet the personal, emotional, and other needs
of the child; and
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D. The child's best interests will be served by her residing primarily with
Plaintiff.
14. Each parent whose parental rights to the child have not been terminated and the
person who has physical custody of the child have been named as parties to this action.
WHEREFORE, JILL ANN KULIG, requests this Court to grant him custody of the child,
Gabrielle Marie Kulig.
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Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
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JILL ANN KULIG, being duly sworn according to law, de'poses and says that the facts
set forth in the foregoing Complaint for Custody are true and correct to the best of his
knowledge, information, and belief.
Sworn to and subscribed
before me this I q -II.,
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LL ANN KULIG '1
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JUILL ANN KULIG
PLAINTIFF
V.
DANIEL K. KULIG
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-485
CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 26th day of January, 2001, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliat
at 214 Senate Avenue, Suite 105, Camp HiD, FA 17011 on the 21st day "{February, 200], at 1:00 p.m.
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.
FOR THE COURT,
By: Isl
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Melissa P. Greevy. Er0
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
HA VB 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
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MAR 0 5 2001/P
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JUILL ANN KULIG,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-485
vs.
DANIEL K. KULIG,
Defendant
CIVIL ACTION - LAW
CUSTODY
INTERIM ORDER OF COURT
AND NOW, this t"-- day of ~ , 2001, upon consideration of
the attached Custody Conciliation Summary Report, it is hereby ordered and directed as
follows:
1. Legal Custody. The parties, Juill Ann Kulig and Daniel K. Kulig, shall have shared
legal custody of th.e minor Child, 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 each Tuesday at 4:00 p.m. until Thursday morning
when the Child is 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.
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No. 01-485
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
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.
5. Christmas. Christmas shall be shared in accordance with an AlB schedule.
Segment A of the Christmas holiday shall run from 6:00 p.m. on December 23rd until 1 0:00
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 holidays shall not change the schedule for alternating weekends.
7. The parents 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.
8. This Order is temporary in nature and may be modified upon agreement of the
parties. In the event that the parties cannot agree to a modification, the terms of this Order
shall control.
BY THE COURT, .
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Samuel L. Andes, Esquire, 525 N. 12th Street, Lemoyne, PA 17043
Mary A. Dissinger, Esquire, 28 N. 32'" Street, Camp Hill, PA 17011
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JUILL ANN KULIG,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01-485
DANIEL K. KULIG,
Defendant
CIVIL ACTION - LAW
CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is
as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Gabrielle Marie Kulig
December 14, 1993
Mother
2. A Custody Conciliation Conference was held on February 21, 2001, with the
following individuals in attendance: the Mother, Juill Ann Kulig, and her counsel, Samuel L.
Andes, Esquire; the Father, Daniel K. Kulig, and his counsel, Mary C. Dissinger, Esquire.
3. The parties reached an agreement as to an Interim Order in the form as attached.
e issa Peel Greevy, Esquire
Custody Conciliator
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Date
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