HomeMy WebLinkAbout03-6284MARY KULP : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,
PENNSYLVANIA
V. : CIVIL ACTION - LAW
DIVORCE, CUSTODY,
BRADLEY KULP 03 - Y
Defendant : NO. CIVIL TERM
COMPLAINT
The plaintiff, Mary Kulp, by her attorney, Anne MacDonald Fox, sets forth the
following cause of action:
COUNT I.
DIVORCE UNDER 23 Pa.C.S. SECTIONS 3301(c) & (d) OF THE DIVORCE CODE
1. Plaintiff is Mary Kulp, who currently resides at 1550 Williams Grove Road, Lot
124, Mechanicsburg, Pennsylvania 17055.
2. Defendant is Bradley Kulp, who currently resides at 207 S. York Road, Apt. B,
Mechanicsburg, Pennsylvania 17055
3. Plaintiff and defendant have been bona fide residents in the Commonwealth for at
least six months immediately previous to the filing of this Complaint.
4. Plaintiff and defendant were married on May 26, 2001 in Pleasentville,
Pennsylvania.
5. Plaintiff and defendant have lived separate and apart since November 1, 2003.
6. There have been no prior actions of divorce or for annulment between the parties.
7. The marriage is irretrievably broken.
8. Plaintiff has been advised that counseling is available and that plaintiff may have
the right to request that the court require the parties to participate in counseling.
WHEREFORE, plaintiff requests the court to enter a decree in divorce dissolving the
marriage.
COUNT II.
CUSTODY
9. Plaintiff repeats and realleges paragraphs one through eight.
10. Plaintiff seeks custody of the following child:
Name
Present Address
Age
Madison Kulp
1550 Williams Grove Rd.,
Lot 124
Mechanicsburg, PA 17055
13 months
The child is presently in the shared custody of Plaintiff, who resides at 1550 Williams
Grove Rd., Lot 124, Mechanicsburg, Cumberland County, Pennsylvania 17055 and
Defendant, who resides at 207 S. York Street, Mechanicsburg, Cumberland County,
Pennsylvania, 17055.
During the past five years, the child has resided with the following persons and at the
following addresses:
Persons Addresses
Mary Kulp 1550 Williams Grove Rd.,
Lot 124
Mechanicsburg, PA 17055
Bradley Kulp
207 S. York St.
Mechanicsburg, PA 17055
Mary & Bradley Kulp
1550 Williams Grove Rd.
Lot 124
Mehanicsburg, PA 17055
Dates
Nov. 1, 2003 - present
Nov. 1, 2003 - present
Oct. 10, 2002 - Nov. 1 2003
The mother of the child is Mary Kulp, currently residing at 1550 Williams Grove Rd.,
Lot 124, Mechanicsburg, Pennsylvania 17055.
She is married.
The father of the child is Bradley Kulp, currently residing at 207 S. York Rd., Apt. B,
Mechanicsburg, Pennsylvania 17055.
He is married.
11. The relationship of the plaintiff to the child is that of mother. The plaintiff
currently resides with the following persons:
Name Relationship
Madison Kulp Daughter
12. The relationship of defendant to the child is that of father. The defendant
currently resides with the following persons:
Name Relationship
Madison Kulp Daughter
13. The plaintiff has not participated as a party or witness, or in another capacity, in
other litigation concerning the custody of the child in this or another court.
Plaintiff has no information of a custody proceeding concerning the child pending in
a court of this Commonwealth. Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the child or claims to have custody or visitation
rights with respect to the child.
14. The best interest and permanent welfare of the child will be served by granting the
relief requested because:
a) Plaintiff has been primary caretaker of the child since birth;
b) Plaintiff provides the child with a home with adequate moral, emotional and
physical surroundings as required to meet the children's needs;
c) Plaintiff is willing and able to accept shared custody of the child;
d) Both parties continue to exercise parental duties and enjoys the love and affection
of the child;
e) It is important for the child to have an ongoing, significant relationship with both
parents.
15. 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, plaintiff requests the court to grant her shared legal and physical
custody of the child.
Date 11AI.1P3 (:?:? ( tA -j??
ANNE ANZD-F(
Attorney I # 87727
45 North Pitt Street
Carlisle, PA 17013
717/240-5204
VERIFICATION
I verify that the statements made in the foregoing complaint are true and correct, to
the best of my knowledge, information and belief. I understand making any false statement
would subject me to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to
authorities.
Date: ii I up / 0'?5 I
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MARY KULP,
Plaintiff
V.
BRADLEY KULP,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN CUSTODY
NO. 03 - G -),S / CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
Kindly allow Mary Kulp, Plaintiff, to proceed in forma pauperis.
I, Anne MacDonald- Fox, attorney for the party proceeding in forma pauperis, certify that
I believe the party is unable to pay the costs and that I am providing free legal service to the
party.
Respectfully submitted,
Date
ANNE MA DONALD- FO
Attorney ID# 87727
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
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MARY KULP, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,
PENNSYLVANIA
V. : CIVIL ACTION - LAW
:CUSTODY
BRADLEY KULP 03. &2 F V
Defendant :NO. CIVIL TERM
CUSTODY AGREEMENT
THIS AGREEMENT, made this 25 day ofNovember 2003, between Mary Kulp (hereinafter
"Mother"), and Bradley Kulp (hereinafter "Father"), concerns the custody of their child: Madison
Kulp, born October 9, 2002.
Mother and Father desire to enter into an agreement as to the custody of the child. Mother
and Father agree to the following:
Mother and Father shall have shared legal custody of their child. All decisions
affecting the child's growth and development shall be considered major decisions and shall be made
by the parents jointly, after discussion and consultation with each other, and with the view towards
obtaining and following the child's best interest. Such decisions shall include, but not be limited to,
all medical and dental treatment, religious upbringing, education, scholastic or athletic pursuits, and
other extracurricular activities.
2. Mother and Father shall have shared physical custody of the child on an alternating
"week one"/"week two" schedule:
Week One Beginning December 3, 2003, Father shall have custody of the child:
a. From 4 p.m. on Wednesday until Friday at 8 a.m. Father shall pick
the child up from daycare on Wednesdays at 4 p.m. and return her to
daycare on Fridays at 8 a.m.
Week Two Beginning December 8, 2003 Father shall have custody of the child:
a. From 4 p.m. on Monday until Wednesday at 8 a.m. AND
b. From 4 p.m. on Friday until Sunday at 4 p.m. Father shall pick the
child up from daycare at the beginning of his custodial period and
shall return her at the end of his custodial period on Wednesday. On
Sundays, he shall return the child to Mother at Mother's home.
This schedule shall continue to alternate with thereafter with Father having 2 overnights one
week and 4 overnights the next. Mother shall have custody of the child at all other times not
specifically stated in this Agreement.
3. Mother and Father shall have custody of the child on alternating holidays including
Easter, Memorial Day, Fourth of July, Labor Day, and Thanksgiving. The times for the holidays in
this paragraph shall be from 9 a.m. until 8 p.m. The holiday rotation shall begin with Easter 2004
when Mother shall have custody of the child.
4. Mother and Father shall share custody of the child on the Christmas holiday. In odd
years, Mother shall have the child from noon on December 24 until 10 a.m. on
December 25 and Father shall have the child from 10 a.m. on December 25 until noon on December
26. In even years, Father shall have the child from noon on December 24 until 10 a.m. on December
25 and Mother shall have the child from 10 a.m. on December 25 until noon on December 26.
5. Mother shall have custody of the child on Mother's Day, and Father shall have
custody of the child on Father's Day. The times for the Mother's and Father's Day holidays are
from 7:00 a.m. until 8:00 p.m. unless agreed otherwise by the parties.
6. Mother and Father shall be entitled to reasonable telephone access with the child
while the child is in the other's custody.
7. Mother and Father shall keep one another advised of their current address and
telephone number.
8. Mother and Father will notify each other of all medical care the child receives while
in that parent's care. Father and Mother will notify the other immediately of medical emergencies
which arise while the child is in that parent's care.
9. Neither parent will do anything which may estrange the child from the other party,
or injure the opinion of the child as to the other parent or which may hamper the free and natural
9. Neither parent will do anything which may estrange the child from the other party,
or injure the opinion of the child as to the other parent or which may hamper the free and natural
development of the child's love and respect for the other parent.
10. Mother and Father intend to be bound by the terms of this agreement and intend for
this Agreement to be made an Order of Court.
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ANNE ONALD- F
Attorney ID# 87727
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
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DE Y4 2003
MARY KULP, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,
PENNSYLVANIA
V. : CIVIL ACTION - LAW
:CUSTODY
BRADLEY KULP 03 - 6a2 S 2/
Defendant :NO. CIVIL TERM
ORDER
AND NOW this _A day of , 2003, the following Custody
Agreement is approved and entered as an Order of Cc
DATE
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MARY KULP, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. : CIVIL ACTION - LAW
: IN DIVORCE
BRADLEY KULP,
Defendant : NO. 03-6284 CIVIL TERM
PROOF OF SERVICE
Understanding that the making of any false statement would subject her to the
penalties of 18 Pa. C. S. §4904 (relating to unworn falsification to authorities), the
undersigned verifies that the Family Law Clinic mailed a true copy of the Divorce
Complaint to the Defendant by placing the same in the U.S. Mail, certified no.7002 0860
0001 5847 8387, restricted delivery, return receipt requested, postage prepaid, on the 9' day
of December, 2003, addressed as follows:
Bradley Kulp
207 S. York Street
Apt. B
Mechanicsburg, PA 17055
Sender's receipt number 7002 0860 0001 5847 8387 is attached hereto and incorporated by
reference.
On or about the 12`n day of December, 2003, green return receipt number 7002 0860
0001 5847 8387 was delivered to the Family Law Clinic, bearing the signature of Bradley
Kulp, and showing a date of service of the 10" of December, 2003. The return receipt is
attached hereto and incorporated by reference.
Date: Z)e l .j ?( aDv3
Anne %-c o? i
C
nald-Fox
Atty ID# 87727
FAMILY LAW CLINIC
45 N. Pitt St
Carlisle, PA 17013
(717) 342-2968
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MARY L. KULP, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
DIVORCE, CUSTODY
BRADLEY R. KULP,
Defendant : NO. 03-6284 CIVIL TERM
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on December 3,
2003.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
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 unworn
falsification to authorities.
Date
MARY L. K(JLV Plaintiff
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MARY L. KULP, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
DIVORCE, CUSTODY
BRADLEY R. KULP,
Defendant : NO. 03-6284 CIVIL TERM
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on December 3,
2003.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
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 unworn
falsification to authorities.
Date
BRADLEY R. W .P, Defendant
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MARY L. KULP, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
DIVORCE, CUSTODY
BRADLEY R. KULP,
Defendant : NO. 03-6284 CIVIL TERM
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of 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 the divorce is granted.
3. I understand that I will not be divorced until a decree of divorce 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 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 unsworn
falsifications to authorities.
Date: ! a 6
vj lp, Plaintiff
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MARY L. KULP, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
DIVORCE, CUSTODY
BRADLEY R. KULP,
Defendant : NO. 03-6284 CIVIL TERM
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
0301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of 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 the divorce is granted.
I understand that I will not be divorced until a decree of divorce 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 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 unsworn
falsifications to authorities.
Date:
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MARY L. KULP, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
DIVORCE, CUSTODY
BRADLEY R. KULP, .
Defendant : NO. 03-6284 CIVIL TERM
CERTIFICATE OF SERVICE;
I, Anne MacDonald-Fox, hereby certify that on this 13" day of April, 2004, I am serving a
true and correct copy of the Plaintiff's and Defendant's Affidavit of Consent and Waiver of
Notice of Intention to Request Entry of a Divorce Decree Under 3301(c) of the Divorce Code,
Praecipe to Transmit Record, and Divorce Information Sheet on Bradley R. Kulp, residing at 207
South York Street, Apartment B, Mechanicsburg, PA 17055, by first class U.S. mail, postage
prepaid.
Date Ann a onald-Fox
Attorney 727
FAMILY LAW CLINIC
45 N. Pitt St.
Carlisle, PA 17013
717-243-2968
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MARY L. KULP,
Plaintiff
V.
BRADLEY R. KULP,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIVORCE, CUSTODY
NO. 03-6284 CIVIL TERM
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce
Code.
2. Date and manner of service of the complaint: December 9, 2003, by U.S. mail,
certified, restricted delivery, return receipt requested, postage prepaid.
3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the
Divorce Code: by the plaintiff - April 2, 2004; by the defendant - March 28, 2004.
4. Related claims pending: none.
5. Date plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the prothonotary:
April 13, 2004.
Date defendant's Waiver of Notice in §3301(c) Divorce was filed with the
prothonotary: April 13, 2004.
DATE: // L/J/,v
ARNO"P?DONALD-?QX
Attorney # 87727
FAMILY LAW CLINIC
45 NORTH PITT STREET
CARLISLE., PA 17013
717-243-2968
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
MARY L. KULP
VERSUS
BRADLEY R. KULP
No.
03 6284
DECREE IN
DIVORCE
.)06.y
01 IT IS ORDERED AND
AvA v I
AND NOW,
DECREED THAT
AND
MARY L. KULP
BRADLEY R. KULP
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
PLAINTIFF,
,DEFENDANT,
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
BY THE
ATTEST: J.
6
PROTHONOTARY
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MARY SNYDER
f/k/a MARY KULP
Plaintiff
V.
BRADLEY KULP
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.: 2003-6284
: CIVIL ACTION -LAW
PETITION FOR MODIFICATION OF EXISTING CUSTODY ORDER
1. The Plaintiff is Mary Snyder, f/k/a Mary Kulp, hereinafter referred to as "Mother", who
currently resides at 6A North St. Johns Church Road, Shiremanstown, Cumberland
County, Pennsylvania.
2. The Defendant is Bradley Kulp, hereinafter referred to as "Father", who currently
resides at 45 Westchester Garden, Carlisle, Cumberland County, Pennsylvania.
3. The parties are the natural parents of Madison Kulp, age four, whose date of birth is
October 9, 2002.
4. Mother and Father entered into a Custody Agreement which was entered as an Order on
December 5, 2003.
5. Due to recent changes, the current Order is no longer in the minor child's best interest.
6. It would be in the minor child's best interest for the Mother to have primary physical
custody of the minor child.
WHEREFORE, Plaintiff, Mary Snyder, requests this Honorable Court grant her primary physical
custody and shared legal custody of the subject minor child, Madison Kulp.
Respectfully Submitted,
WdAq &Lq CX
Mary Sny er, Plaintiff
VERIFICATION
I, Mary Snyder, verify that the statements made in the foregoing Petition for Contempt are
true and correct. I understand that false statements made herein are subject to the penalties of 18
Pa.C.S. §4904, relating to unworn falsification to authorities.
Date Mary Sny er
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MARY SNYDER F/K/A MARY KULP IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. 2003-6284 CIVIL ACTION LAW
BRADLEY KULP
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Tuesday, August 28, 2007 _, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, September 28, 2007 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: /s/ Hubert X. Gilroy Es q.
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
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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MARY SNYDER : IN THE COURT OF COMMON PLEAS
f/k/a MARY KULP : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff .
V. : NO.: 2003-6284
BRADLEY KULP CIVIL ACTION -LAW
Defendant
CUSTODY AGREEMENT
ful
THIS AGREEMENT, made this q0 .day of 1? 2007, by and between,
MARY SNYDER, currently residing at 6A North St Johns Church Road, Cumberland County,
Pennsylvania, hereinafter referred to as "MOTHER", and BRADLEY KULP, currently residing at
45 Westchester Garden, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as
"FATHER",
WITNESSETH:
WHEREAS, the parties are the Father and Mother of the minor child, MADISON KULP,
born October 9, 2002.
WHEREAS, MOTHER and FATHER have agreed under the aforementioned
circumstances that an agreement as to custody, partial custody and visitation of their child would
be in the interest of all.
NOW THEREFORE, in consideration of the promises herein, and in pursuance thereof,
the parties mutually agree as follows, intending to be legally bound thereby:
The parties agree that major decisions concerning their child, including, but not
necessarily limited to, the child's health, welfare, education, religious training and upbringing shall
be made by them jointly, after discussion and consultation with each other, with a view toward
obtaining and following a harmonious policy in the child's best interest. Each party agrees not to
impair the other party's rights to shared legal custody of the child. Each party agrees not to
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attempt to alienate the affections of the child from the other party. Each party shall notify the other
of any activity or circumstance concerning their child that could reasonably be expected to be of
concern to the other. Day to day decisions shall be the responsibility of the parent then having
physical custody. With regard to any emergency decisions which must be made, the parent having
physical custody of the child at the time of the emergency shall be permitted to make any
immediate decisions necessitated thereby. However, that parent shall inform the other of the
emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A.
§5309, each party shall be entitled to complete and full information from any doctor, dentist,
teacher, professional or authority and to have copies of any reports or information given to either
party as a parent as authorized by statute. Mutual agreement should be made, in advance,
regarding the following matters: enrollment or termination in a particular school or school
program, advancing or holding the child back in school, authorizing enrollment in college,
authorizing their child's driver's license or purchase of an automobile, authorizing employment,
authorizing either child's marriage or enlistment in the armed forces, approving a petition for
emancipation, authorizing foreign travel, passport application or exchange student status.
2. Mother shall have primary physical custody of the minor child.
3. Father shall have partial physical custody of the minor child accordance with
the following schedule:
a. Alternating weekends from Friday at 4:00 p.m. to Sunday at 8:00 p.m.
b. On Monday from 4:00 p.m. until Wednesday 8:00 a.m.
C. Father shall pick up the child from the childcare provider at the beginning of
his custodial period and shall return the child to Mother's house at the end of his
custodial period.
4. The above-referenced schedule shall continue through August 24, 2008. As of
August 25, 2008, Father shall have partial physical custody of the minor child accordance with the
following schedule:
a. Alternating weekends from Friday at 4:00 p.m. to Sunday at 8:00 p.m.
b. On Wednesday evenings from 4:00 p.m. until 7:30 p.m. Evening
periods of custody are subject to child's extracurricular activities and level of
school work on these days.
C. Father shall pick up the child from the childcare provider at the beginning of
his custodial period and shall return the child to Mother's house at the end of his
custodial period.
d. At all other times that the parties agree.
5. The parent with physical custody during any given period of time shall
communicate in a prompt fashion with the other parent concerning the well-being of their child,
and shall appropriately notify the other parent of any changes in health or educational progress.
Each parent shall execute any and all legal authorizations so that the other parent may obtain
information from the child's schools, physicians, psychologists, or other individuals concerning
their progress and welfare.
Holidays:
a. Thanksgiving, in odd-numbered years Father will have the child on
Thanksgiving from 8:00 a.m. to 9:00 p.m., alternating with Mother on even-
numbered years.
b. Christmas, in odd-numbered years Mother will have the child from 12:00
p.m. on December 24 until 10:00 a.m. on December 25 and Father shall
have the child from 10:00 a.m. on December 25 until 12:00 p.m on
December 26. In even-numbered years Father will have the child from
12:00 p.m. on December 24 until 10:00 a.m. on December 25 and Mother
shall have the child from 10:00 a.m. on December 25 until 12:00 p.m on
December 26. Major gifts should be discussed and coordinated between the
parents.
C. Mother will have physical custody of the child on Mother's Day and Father
will have physical custody of the child on Father's Day. The times for the
..M
Mother's and Father's Day holidays are from 8:00 a.m. until 8:00 p.m.
unless otherwise agreed upon by the parties.
d. Mother will have custody on odd-numbered years and Father will have
custody on even-numbered years for the following holidays from 9:00 a.m.
until 8:00 p.m.: Memorial Day holiday; and Labor Day holiday.
e. Father will have custody on odd-numbered years and Mother will have
custody on even-numbered years for the following holidays from 9:00 a.m.
until 8:00 p.m.: Easter holiday and July 4t' holiday.
f. Monday holidays such as Martin Luther King Day, President's Day and
Columbus Day shall attach to the weekend. The return time is 7:00 p.m. on
the holiday. This also will apply to in-service days occurring on Monday.
In-service days occurring on Friday will also attach to the weekend and will
begin at 8:00 a.m.
g- The parties will not deviate from the regular custody schedule because of
the child's birthdays.
h. The holiday schedule shall take precedence over the regular custody
schedule.
6. The parents shall organize ways for their child to maintain their friendships,
extracurricular activities, and other special interests, regardless of which household they may be in.
Each parent must confer with the other parent before arranging regularly occurring extracurricular
activities for the child which might interfere with regular visitation.
7. Toys, clothes, etc. not become matters of contention as these generally are the
child's property, not the parents, entitling the toys or clothes to be taken by the child and back with
the child, as reasonably appropriate.
8. The parents shall permit and support the child's access to all family relationships.
Special family events such as weddings, family reunions, family gatherings, funerals, graduations,
etc. shall be accommodated by both parties with routine visitations resuming immediately
thereafter. Each parent shall have the option of proposing time or date variations to the other
parent when special recreational options or other unexpected opportunities arise.
9. Each parent shall exercise care in screening babysitting/child care providers. Each
parent should have the right of veto over child care providers. The telephone numbers of these
providers will be provided to both parents. Parents should provide one another with a phone
number and address where the child may be contacted at all times whenever reasonably possible.
This principle applies to situations such as vacations and overnights with friends. Each parent
should be promptly and politely responsive to the other parent's telephone calls.
10. During any period of custody or visitation the parties to this Order shall not possess
or use any controlled substance, nor shall they consume alcoholic beverages to the point of
intoxication, nor smoke cigarettes inside the residence or vehicle. The parties shall likewise
assure, to the extent possible, that other household members and/or houseguests comply with this
prohibition.
11. Telephone Contact: Each parent shall be entitled to reasonable telephone contact
with the child which shall not be excessive as well as daily contact via e-mail with the child when
in the custody of the other parent.
12. Neither parent shall permanently relocate if the relocations would necessitate a
change in the visitation schedule; change of school district for the child; or exceed a fifty (50) mile
radius without a minimum notice of ninety (90) days to the other parent. The ninety- (90) day
notice is designed to afford the parents an opportunity to renegotiate the custodial arrangements or
to have the matter listed for a Court hearing.
13. No Conflict Zone: Each parent agrees not to attempt to alienate the affections of
the child from the other and will make a special conscious effort not to do so. Both parents shall
establish a No-Conflict Zone for their child and refrain from making derogatory comments about
the other parent in the presence of the child and, to the extent possible, shall not permit third
parties from making such comments in the presence of the child whether the child is sleeping or
awake.
14. Each parent shall speak respectfully of the other whether it is believed the other
reciprocates or not. Each parental figure shall refer to the other by the appropriate role name such
as Mom, Dad, your grandmother, etc. Each parent should agree to refrain from encouraging the
child to provide reports about the other parent. Communication should always take place directly
between parents, without using the child as an intermediary.
15. Father presently maintains health insurance for the child; he shall notify Mother
immediately of any changes or anticipated change regarding health insurance within 30 days of
said change if known.
16. The parties agree that this Custody Agreement shall be entered as an Order of
Court.
IN WITNESS WHEREOF, the parties have signed this Agreement on the day and year first
above written.
WITNESS:
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M Y S ER
BRADLEY KULP
WITNESS
WIT SS
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MARY SNYDER Vk/a MARY KULP,
Plaintiff
v
BRADLEY KULP,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2003-6284
IN CUSTODY
COURT ORDER
66??
AND NOW, this a U day of C(?? 2007, the Conciliator being
advised the parties have reached an agreement, the Conciliation Conference is cancelled and
the Conciliator relinquishes jurisdiction.
?1- V
Hubert X. Gilroy, squire
Custody Concili or
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SEP 872001x'1
MARY SNYDER : IN THE COURT OF COMMON PLEAS
Vk/a MARY KULP : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO.: 2003-6284
BRADLEY KULP CIVIL ACTION -LAW
Defendant
ORDER OF COURT
AND NOW, this day of INV^ , 2007, the plaintiff (hereinafter "Mother")
and the defendant (hereinafter "Father"), having reached an agreement regarding custody and the
best interests and welfare of their minor child, it is hereby ORDERED AND DECREED as
follows:
1. Legal Custody: The parties will share joint legal custody of Madison Kulp, DOB:
October 9, 2002. The parties agree that major decisions concerning their child, including, but not
necessarily limited to, the child's health, welfare, education, religious training and upbringing shall
be made by them jointly, after discussion and consultation with each other, with a view toward
obtaining and following a harmonious policy in the child's best interest. Each party agrees not to
impair the other party's rights to shared legal custody of the child. Each party agrees not to
attempt to alienate the affections of the child from the other party. Each party shall notify the other
of any activity or circumstance concerning their child that could reasonably be expected to be of
concern to the other. Day to day decisions shall be the responsibility of the parent then having
physical custody. With regard to any emergency decisions which must be made, the parent having
physical custody of the child at the time of the emergency shall be permitted to make any
immediate decisions necessitated thereby. However, that parent shall inform the other of the
emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A.
§5309, each party shall be entitled to complete and full information from any doctor, dentist,
teacher, professional or authority and to have copies of any reports or information given to either
party as a parent as authorized by statute. Mutual agreement should be made, in advance,
regarding the following matters: enrollment or termination in a particular school or school
. . 1
program, advancing or holding the child back in school, authorizing enrollment in college,
authorizing their child's driver's license or purchase of an automobile, authorizing employment,
authorizing either child's marriage or enlistment in the armed forces, approving a petition for
emancipation, authorizing foreign travel, passport application or exchange student status.
2. Mother shall have primary physical custody of the minor child.
3. Father shall have partial physical custody of the minor child accordance with
the following schedule:
a. Alternating weekends from Friday at 4:00 p.m. to Sunday at 8:00 p.m.
b. On Monday from 4:00 p.m. until Wednesday 8:00 a.m.
C. Father shall pick up the child from the childcare provider at the beginning of
his custodial period and shall return the child to Mother's house at the end of his
custodial period.
4. The above-referenced schedule shall continue through August 24, 2008. As of
August 25, 2008, Father shall have partial physical custody of the minor child accordance with the
following schedule:
a. Alternating weekends from Friday at 4:00 p.m. to Sunday at 8:00 p.m.
b. On Wednesday evenings from 4:00 p.m. until 7:30 p.m. Evening
periods of custody is subject to child's extracurricular activities and level of school
work on these days.
C. Father shall pick up the child from the childcare provider at the beginning
of his custodial period and shall return the child to Mother's house at the end of his
custodial period.
d. At all other times that the parties agree.
5. The parent with physical custody during any given period of time shall
communicate in a prompt fashion with the other parent concerning the well-being of their child,
and shall appropriately notify the other parent of any changes in health or educational progress.
Each parent shall execute any and all legal authorizations so that the other parent may obtain
information from the child's schools, physicians, psychologists, or other individuals concerning
their progress and welfare.
5. Holidays:
a. Thanksgiving, in odd-numbered years Father will have the child on
Thanksgiving from 8:00 a.m. to 9:00 p.m., alternating with Mother on even-
numbered years.
b. Christmas, in odd-numbered years Mother will have the child from 12:00
p.m. on December 24 until 10:00 a.m. on December 25 and Father shall
have the child from 10:00 a.m. on December 25 until 12:00 p.m on
December 26. In even-numbered years Father will have the child from
12:00 p.m. on December 24 until 10:00 a.m. on December 25 and Mother
shall have the child from 10:00 a.m. on December 25 until 12:00 p.m on
December 26. Major gifts should be discussed and coordinated between the
parents.
C. Mother will have physical custody of the child on Mother's Day and Father
will have physical custody of the child on Father's Day. The times for the
Mother's and Father's Day holidays are from 8:00 a.m. until 8:00 p.m.
unless otherwise agreed upon by the parties.
d. Mother will have custody on odd-numbered years and Father will have
custody on even-numbered years for the following holidays from 9:00 a.m.
until 8:00 p.m.: Memorial Day holiday; and Labor Day holiday.
e. Father will have custody on odd-numbered years and Mother will have
custody on even-numbered years for the following holidays from 9:00 a.m.
until 8:00 p.m.: Easter holiday and July 4th holiday.
f. Monday holidays such as Martin Luther King Day, President's Day and
Columbus Day shall attach to the weekend. The return time is 7:00 p.m. on
the holiday. This also will apply to in-service days occurring on Monday.
In-service days occurring on Friday will also attach to the weekend and will
begin at 8:00 a.m.
g. The parties will not deviate from the regular custody schedule because of
the child's birthdays.
h. The holiday schedule shall take precedence over the regular custody
schedule.
6. The parents shall organize ways for their child to maintain their friendships,
extracurricular activities, and other special interests, regardless of which household they may be in.
Each parent must confer with the other parent before arranging regularly occurring extracurricular
activities for the child which might interfere with regular visitation.
7. Toys, clothes, etc. not become matters of contention as these generally are the
child's property, not the parents, entitling the toys or clothes to be taken by the child and back with
the child, as reasonably appropriate.
8. The parents shall permit and support the child's access to all family relationships.
Special family events such as weddings, family reunions, family gatherings, funerals, graduations,
etc. shall be accommodated by both parties with routine visitations resuming immediately
thereafter. Each parent shall have the option of proposing time or date variations to the other
parent when special recreational options or other unexpected opportunities arise.
9. Each parent shall exercise care in screening babysitting/child care providers. Each
parent should have the right of veto over child care providers. The telephone numbers of these
providers will be provided to both parents. Parents should provide one another with a phone
number and address where the child may be contacted at all times whenever reasonably possible.
This principle applies to situations such as vacations and overnights with friends. Each parent
should be promptly and politely responsive to the other parent's telephone calls.
10. During any period of custody or visitation the parties to this Order shall not possess
or use any controlled substance, nor shall they consume alcoholic beverages to the point of
intoxication, nor smoke cigarettes inside the residence or vehicle. The parties shall likewise
assure, to the extent possible, that other household members and/or houseguests comply with this
prohibition.
11. Telephone Contact: Each parent shall be entitled to reasonable telephone contact
with the child which shall not be excessive as well as daily contact via e-mail with the child when
in the custody of the other parent.
12. Neither parent shall permanently relocate if the relocations would necessitate a
change in the visitation schedule; change of school district for the child; or exceed a fifty (50) mile
radius without a minimum notice of ninety (90) days to the other parent. The ninety- (90) day
notice is designed to afford the parents an opportunity to renegotiate the custodial arrangements or
to have the matter listed for a Court hearing.
13. No Conflict Zone: Each parent agrees not to attempt to alienate the affections of
the child from the other and will make a special conscious effort not to do so. Both parents shall
establish a No-Conflict Zone for their child and refrain from making derogatory comments about
the other parent in the presence of the child and, to the extent possible, shall not permit third
parties from making such comments in the presence of the child whether the child is sleeping or
awake.
14. Each parent shall speak respectfully of the other whether it is believed the other
reciprocates or not. Each parental figure shall refer to the other by the appropriate role name such
as Mom, Dad, your grandmother, etc. Each parent should agree to refrain from encouraging the
child to provide reports about the other parent. Communication should always take place directly
between parents, without using the child as an intermediary.
15. Father presently maintains health insurance for the child; he shall notify Mother
immediately of any changes or anticipated change regarding health insurance within 30 days of
said change if known.
BY THE COURT:
J.
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