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HomeMy WebLinkAbout02-2153MICHAEL T. KULP, DOREEN C. KULP, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. Oil-, .2./.~ CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiffis Michael T. Kutp, who currently resides at 649 Baltimore Pike, Cumberland County, Gardners, Pa. 17324. 2. Defendant is Doreen C. Kulp (also formerly known as Siekerman) who currently resides at 104 Schofield Drive, East Berlin, Adams County, Pennsylvania, 17316. 3. Plaintiff seeks primary custody of the following children: NAME ~ DOB Kristel Kulp 649 Baltimore Pike 3-23-87 Gardners, Pa. 17324 Heather Kulp 649 Baltimore Pike 10-4-89 Gardners, Pa. 17324 Michael T. Kulp and Doreen C. Kulp were married on December 30, 1987 and were divorced on March 23, 1995. The children are in the custody off FATHER. During the past five years, the children have resided with the following persons and at the following addresses: NAME ADD~SSES DATES Michael T. Kulp 649 Baltimore Pike Cumberland County Gardners, Pa. 17324 4-2-02 to present. Doreen C. Kulp David Wehler 104 Schofield Drive Adams County East Berlin, Pa. 17316 June 2000 through 4-2-02. Doreen C. Kulp Doreen C. Kulp Loysville, Pa. Perry County New Bloomfield, Pa. Perry County March 2000 - June 2000 1997 -March2000 The mother of the children is: Doreen C. Kulp, currently residingat: 104 Schofield Drive, East Berlin, Adams County, Pennsylvania, 17316. - ' She is divorced. The father of the children is: Michael T. Kulp, currently residing at: 649 Baltimore Pike, Gardners, Cumberland County, Pennsylvania, 17324. He is divorced. 4. The relationship ofplalntiffto the children is that of FATHER. The plaintiff currently resides with Lois Homer. 5. The relationship of defendant to the children is that of MOTHER. The defendant currently resides with David Wehler. 6. Plalntiffhas participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Previous Orders were entered in Perry County (Please see Exhibit A), however, neither the parties or the children currently live in Perry County. Plaintiff has no information of a custody proceeding concerning the children currently pending in a court of this Commonwealth. Plaintiff does not know of a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: The children have expressed their desire to live with father, and father can provide a stable and loving home. Mother has recently indicated that she did not want the children to reside with her and a case was opened with Adams County_ Children and Youth 8. Each parem 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 custody of the children. Respectfully submitted, ~j. D.~eNAo~,6~squire ~ 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF I verify that the statements made in this Complaint are tree and correct. I understand that false statemems herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. MICHAEL T. KULP DOREEN (KULP SIEKERMAN IN THE COURT OF COMMON PLEAS OF THE 41ST UUD/(2iA[. [II~T OF PENNSYLVANIA PERRY COUNTY BRANCH NO. 94-228 OR'DER AND NOW, November 22, 1999, the record in the captioned matter is hereby kept open to give Kathy Morrow, Esquire, attorney for the children, an opportunity to meet with the children and discuss this matter with them and, upon request of counsel of record, this matter shall be rescheduled for a hearing or a conference call by the Court Administrator. The status quo shall be maintained pending further order of court. cc: ~erry Philpott, Esq. Joanne Clough, Esq. Kathy Morrow, Esq. File BY THE COURT: C. J~E MICHAEL T. KULP, Petitioner VS. DOREEN SIEKERMAN, Respondent IN THE COURT OF COMMON PLEAS OF THE 41ST JUDICIAL DISTRICT, PERRY COUNTY BRANCH No. CIVIL ACTION - CUSTODY ORDER & RULE AND NOW, this lC /'~ day of )k]OUlnq [va K ,19]__~, upon consideration of the within application for special relief and on motion of Jerry A. Philpott, Esquire, attorney for petitioner, the following relief is hereby immediately ordered, pending a hearing onthe o~o~~--'' day of_ {qO~)aa~)ve& , 1999, at 9Z~o'clock/J.m., prevailing time, in Court RoometS~ of the Perry County Courthouse: BY THE COURT: MICHAEL T.- KU~SP DOREEN C. KULP : IN THE COURT OF COMMON'PLEAS OF THE 415T JUDICIAL DISTRICT OF PENNSYLVANIA .: PERRY COUNTY BRANCH NO. 94-228 ORDER AND NOW, August 15, 1994, this matter having come forward for a hearing and upon agreement of the parties, it is hereby ORDERED AND DIRECTED that the parties enjoy a shared legal and physical custody arrangement with respect to their two (2) minor children, Heather Lynn Kulp and Kristel Kathryn Kulp as follow: Mother shall have the children in her primary custody every weekend from Friday at 5:30 P.M. until Sunday at 8:30 P.M., except for the second weekend of each month at which time father shall have custody of the children: Every Monday and Tuesday mother shall have custody of the children from 5:30 P.M. until 8:30 P.M. Mother shall pick up and drop off the children at father'~-:residen~ for the Monday and Tuesday visitations and on the -~ekeFrds ~z~ck up and delivery shall be at the Duncannon Assembl~6~f G~' ChUrch; Father shall have custody.'~Of t~e c~ildren at all other times not mentioned above; -..: ,~o :~. ,-o rT.. Heather Lynn Kulp shall c~ntinue i-~ -day care and the parties shall share equally the costs of all day care expenses; As far as a holiday schedule is concerned, the parties shall, by agreement, work out a holiday schedule and if an agreement cannot be reached, each party shall submit to the Court a proposed holiday schedule and this Court shall adopt one or the other schedule; · During the week, if mother has a holiday, she shall have the children until 5:30 P.M.; During the summer months, each party shall have one (1) week continuous temporary custody of the children per calendar year. The parties may, by mutual agreement, alter or change any of the periods of temporary custody or custody outlined in this agreement. cc: Michael Hanft, Esq. R. Scott Cramer, Esq. File BY THE COURT: C. J~~P, JUDGE MICHAEL T. KULP, DOREEN C. KULP, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : :NO. 02-2153 CIVILTERM : : IN CUSTODY AFFIDAVIT OF SERVICE OF NOTICE TO DEFEND AND COMPLAINT AND NOW, this May 13, 2002, I, Jane Adams, Esquire, hereby certify that on May 10, 2002, a true and correct copy of the CUSTODY PETITION was served, via certified mail, return receipt requested, addressed to: Doreen Kulp 104 Schofield Drive East Berlin, Pa. 17316 DEFENDANT Respectfully Submitted: //~J~e )kd-a/ns, ~sq"t~ire - ~ 3~)6 ~oNu°~7p9it?~t. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF · Complete items 1', 2, and 3. Also complete Nern 4 if Restricted Delivery is desired. · Print your name and address on the mveme so that we can return the card to you. · Attach th~'~card to the back of the mailpiece, or o~ the front if space permits. 1. Article Addressed to: I ,~ Received by {Pteas~ Pr/nt Clearly) B. Date of D. Isdeiiveryad~diffe~fTomlteml? r-lyes If YES, enter delivery address below: 3. Service Type ,~ Ce..~rtified Mail [] Express Mail 1'3 Registered [] Retum Receipt for Me~charldee [] Insured Mail [] C.O.D. 4. Restricted Delivery? (Ex~a Fee) [] Yes 2. ArticleNumbe~(Copyfiomservicelabel) 7(~/ ~4~'~ 000 ~ ~'~'~ ~.~--A ~'~ PS Form 3811, July 1999 Domestic Return Receipt 102595-0~-M-0~52 MICHAEL T. KULP : : PLAINTIFF ., V. : DOREEN C. KULP DEFENDANT : IN CUSTODY .. ORDER OF COURT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-2153 CIVIL ACTION LAW AND NOW, Thursday, May 16, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jaequeline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, June 04, 2002 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this earmot be accomplished, to del'me 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 ali existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ]acqueline M. Verney. Esq.·,t'ky 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 heating. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 MICHAEL T. KULP, DOREEN C. KULP, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2153 CIVIL ACTION - LAW IN CUSTODY PRELIMINARY OBJECTIONS TO COMPLAINT FOR CUSTODY AND NOW, this ~(-~ C?'~L'-- day of May, 2002, comes the Petitioner/Defendant Doreen C. Kulp and files these Preliminary Objections to the Complaint for Custody filed by Respondent/Plaintiff Michael T. Kulp on May 2, 2002 and in support thereof avers as follows: 1. Petitioner/Defendant Doreen C. Kulp is an adult individual who currently resides at 104 Schofield Drive, East Berlin, Adams County, Pennsylvania 17316. 2. Respondent/Plaintiff Michael T. Kulp is an adult individual who currently resides at 649 Baltimore Pike, Cumberland County, Gardners, Pennsylvania 17324. 3. On May 2, 2002, Respondent/Plaintiff Michael T. Kulp filed a Complaint for Custody with the Court of Common Pleas of Cumberland County, Pennsylvania. 4. Respondent files a preliminary objection challenging the jurisdiction of the Court of Common Pleas of Cumberland County, Pennsylvania to hear this action when a custody action is currently pending before the Court of Common Pleas of the 4 l~t Judicial District of Pennsylvania, Perry County Branch at Civil Action 94-228. a. A current Custody Order was issued by the Court of Common Pleas of Perry County on November 22, 1999 and a previous Custody Order was issued on -1- eo August 15, 1994. (See Attached Exhibits A and B). A custody trial was held before the Court of Common Pleas of the 41 st Judicial District of Pennsylvania, Perry County Branch on August 15, 1994 and a second hearing was held on November 22, 1999. On November 22, 1999, Judge C. Joseph Rehkamp issued an Order of Court specifically directing the parties minor children meet with Kathy A. Morrow, Esquire, the Court appointed attorney, to represent the children in this action directing that she meet with the children and discuss the issues then pending with the Court and upon request of either counsel of record the Respondent Michael T. Kulp's Petition for Modification of Custody, which he filed on November 16, 1999, be scheduled for hearing if necessary. The children met with their Court appointed Kathy A. Morrow, Esquire who recommended that the parties participate with their children's counselor to resolve the outstanding issues, no further action was taken by Respondent father for approximately 3 years. Respondent father now has attempted to circumvent the current Custody Order and the Perry County courts and their specific knowledge of the issues in this case and attempt to shop for a forum he believes more favorable with the Court of Common Pleas of Cumberland County. The Court of Common Pleas of Perry County has previously held 2 evidentiary hearings concerning the custody and permanent welfare of the minor children and therefore jurisdiction should properly remain with the Court of Common Pleas of Perry County. The Court of Common Pleas of Cumberland County, Pennsylvania does not have -2- jurisdiction to hear a Complaint for Custody when there is a valid pre-existing Custody Order issued by the Court of Common Pleas of the 4 l't Judicial District, Perry County Branch. f. Petitioner mother has primary physical custody of the children pursuant to the Court Orders and Respondent father is illegally keeping the minor child Heather in direct violation of the Perry County Custody Order. WHEREFORE, the Petitioner Defendant Doreen C. Kulp respectfully requests this Honorable Court to sustain her Preliminary Objections and refuse to accept jurisdiction of this matter since there is a Custody Action currently pending in the Court of Common Pleas of Perry County and evidentiary testimony has been taken concerning the custody of the minor children Crystal Kulp and Heather Kulp before that Court, and direct this matter be transferred or refiled in Perry County. By: Respectfully submitted, REAGER & ADLER, PC i ' /? Jo .a~._/5~arriso"-fi Clough, l~sqtgre~ ID #36461 [ \ 2331 Market Street Camp Hill, PA 17011 717-763-1383 Attorneys for Petitioner/Defendant -3- I, Doreen C. Kulp, hereby verify and state that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. Doreen C. Kulp DAVE: MICHAEL T. KULP, DOREEN C. KULP, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2153 CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE I, Joanne Harrison Clough, do hereby certify that on this date I served the foregoing Preliminary Objections to Complaint for Custody by depositing a true and exact copy thereof in the United States mail, first class, postage prepaid, addressed as follows: Michael T. Kulp c/o Jane C. Adams, Esquire 117 S. Hanover Street Carlisle, PA 17013 REAGER & ADLER, PC Joanne Harrison Clough / MICHAEL T. KULP DOREEN (KULP) SIEKERMAN : IN THE COURT OF COMMON PLEAS : OF THE 41ST JUDICIAL DISTRICT : OF PENNSYLVANIA : PERRY COUNTY BRANCH : NO. 94-228 OR'DER AND NOW, November 22, 1999, the record in the captioned matter is hereby kept open to give Kathy Morrow, Esquire, attorney for the children, an opportunity to meet with the children and discuss this matter with them and, upon request of counsel of record, this matter shall be rescheduled for a hearing or a conference call by the Court Administrator. The status quo shall be maintained pending further order of court. cc: ~er~y Philpott, Esq. .~anne Clough, Esq. Kathy'Morrow, Esq. File BY THE COURT: --.% MIdHAEL T.-KULP V. DOREEN C. KULP IN THE COURT'OF COMMON PLEAS OF THE 415T JUDICIAL DISTRICT O? PENNSYLVANIA PERRY COUNTY BRANCH NO. 94-228 ORDER AND NOW, August 15, 1994, this matter having come forward for a hearing and upon agreement of the parties, it is hereby ORDERED AND DIRECTED that the parties enjoy a shared legal and physical custody arrangement with respect to their two (2) minor children, ~eather Lynn Kulp and Kristel Kathryn Kulp as follow: Mother shall have the children i'n her primary custody every weekend from Friday at 5:30 P.M. until Sunday at 8:30 P.M., except for the second weekend of each month at which time father shall have custody of the children: Every Monday and Tuesday mother shall have custody of the children from 5:30 P.M. until 8:30 P.M. Mother shall pick up and drop off the children at father'~residen~ for the Monday and Tuesday visitations and on the .-~_-.eke~ds ~.'ck up and delivery shall be at the Duncannon assembl~i~f G~ ChUrch: Father shall have custody..~of t~e c~ildren at all other .~.'...~ ~ -' times not mentioned above; -' ~eather Lynn Kulp shall cantinue xTn -day care and the parties shall share equally the costs of all day care expenses; As far as a holiday schedule is concerned, the parties shall, by agreement, work out a holiday schedule and if an agreement cannot be reached, each party shall submit to the Court a proposed holiday schedule and this Court shall adopt one or the other schedule; During the week, if mother has a holiday, she shall have the children until 5:30 P.M.; During the summer months, each party shall have one (1) week continuous temporary custody cf the children per calendar year. The parties may, by mutual agreement, alter or change any of the periods of temporary custody or custody outlined in this agreement. Michael Banft, Esq. R. Scott Cramer, Esq. File BY TBE COURT: P, JUDGE MICHAEL T. KULP, DOREEN C. KULP, Plaintiff : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2153 CIVIL ACTION - LAW IN CUSTODY PRELIMINARY OBJECTIONS TO COMPLAINT FOR CUSTODY AND NOW, this <~ (--~-~ day of May, 2002, comes the Petitioner/Defendant Doreen C. Kulp and files these Preliminary Objections to the Complaint for Custody filed by Respondent/Plaintiff Michael T. Kulp on May 2, 2002 and in support thereof avers as follows: 1. Petitioner/Defendant Doreen C. Kulp is an adult individual who currently resides at 104 Schofield Drive, East Berlin, Adams County, Pennsylvania 17316. 2. Respondent/Plaintiff Michael T. Kulp is an adult individual who currently resides at 649 Baltimore Pike, Cumberland County, Gardners, Pennsylvania 17324. 3. On May 2, 2002, Respondent/Plaintiff Michael T. Kulp filed a Complaint for Custody with the Court of Common Pleas of Cumberland County, Pennsylvania. 4. Respondent files a preliminary objection challenging the jurisdiction of the Court of Common Pleas of Cumberland County, Pennsylvania to hear this action when a custody action is currently pending before the Court of Common Pleas of the 4 l~t Judicial District of Pennsylvania, Perry County Branch at Civil Action 94-228. a. A current Custody Order was issued by the Court &Common Pleas of Perry County on November 22, 1999 and a previous Custody Order was issued on -1- bo do August 15, 1994. (See Attached Exhibits A and B). A custody trial was held before the Court of Common Pleas of the 41st Judicial District of Pennsylvania, Perry County Branch on August 15, 1994 and a second hearing was held on November 22, 1999. On November 22, 1999, Judge C. Joseph Rehkamp issued an Order of Court specifically directing the parties minor children meet with Kathy A. Morrow, Esquire, the Court appointed attorney, to represent the children in this action directing that she meet with the children and discuss the issues then pending with the Court and upon request of either counsel of record the Respondent Michael T. Kulp's Petition for Modification of Custody, which he filed on November 16, 1999, be scheduled for hearing if necessary. The children met with their Court appointed Kathy A. Morrow, Esquire who recommended that the parties participate with their children's counselor to resolve the outstanding issues, no further action was taken by Respondent father for approximately 3 years. Respondent father now has attempted to circumvent the current Custody Order and the Perry County courts and their specific knowledge of the issues in this case and attempt to shop for a forum he believes more favorable with the Court of Common Pleas of Cumberland County. The Court of Common Pleas of Perry County has previously held 2 evidentiary hearings concerning the custody and permanent welfare of the minor children and therefore jurisdiction should properly remain with the Court of Common Pleas of Perry County. The Court of Common Pleas of Cumberland County, Pennsylvania does not have -2- jurisdiction to hear a Complaint for Custody when there is a valid pre-existing Custody Order issued by the Court of Common Pleas of the 41st Judicial District, Perry County Branch. f. Petitioner mother has primary physical custody of the children pursuant to the Court Orders and Respondent father is illegally keeping the minor child Heather in direct violation of the Perry County Custody Order. WHEREFORE, the Petitioner Defendant Doreen C. Kulp respectfully requests this Honorable Court to sustain her Preliminary Objections and refuse to accept jurisdiction of this matter since there is a Custody Action currently pending in the Court of Common Pleas of Perry County and evidentiary testimony has been taken concerning the custody of the minor children Crystal Kulp and Heather Kulp before that Court, and direct this matter be transferred or refiled in Perry County. Date: Respectfully submitted, REAGER & ADLER, PC .// 2331 Market Street \ ca}rip Hill, PA 17011 717-763-1383 Attorneys for Petitioner/Defendant -3- I, Doreen C. Kulp, hereby verify and state that the facts set forth in the foregoing pleading are tree and correct to the best of my infoLmation, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. Doreen C. Kulp DATE: MICHAEL T. KULP, DOREEN C. KULP, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2153 CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE I, Joanne Harrison Clough, do hereby certify that on this date I served the foregoing Preliminary Objections to Complaim for Custody by depositing a tree and exact copy thereof in the United States mail, first class, postage prepaid, addressed as follows: Michael T. Kulp c/o Jane C. Adams, Esquire 117 S. Hanover Street Carlisle, PA 17013 Date: REAGER & ADLER, PC Joan_ne Harrison Clough MICHAEL T. KULP v. DOREEN (KULP) SIEKERMAN : IN THE COURT OF COMMON PLEAS : OF THE 41ST JUDICIAL DISTRICT : OF PENNSYLVANIA : PERRY COUNTY BRANCH : NO. 94-228 ORDER AND NOW, November 22, 1999, the record in the captioned matter- is hereby kept open to give Kathy Morrow, Esquire,..'= attorney for the children, an opportunity to meet with the children and discuss this matter with them and, upon request of counsel of record, this matter shall be rescheduled for a hearing or a conference call by the Court Administrator. The status quo shall be maintained pending further order of court. cc: Jer_.Ey Philpott, Esq. .4<Yanne Clough, Esq. Kathy'Morrow, Esq. File BY THE COURT: C. ~GE JOSEPH MIdHAEL T.'KULP DOREEN C. KULP : IN THE COURT'OF COMMON PLEAS : OF THE 41ST JUDICIAL DISTRICT : OF PENNSYLVANIA .: PERRY COUNTY BRANCH : NO. 94-228 ORDER AND NOW, August 15, 1994, this matter having come forward for a hearing and upon agreement of the parties, it is hereby ORDERED AND DIRECTED that the parties enjoy a shared legal and physical custody arrangement with respect to their two (2) minor children, Heather 5ynn Kulp and Kristel Kathryn Kulp as follow: Mother shall have the children fn her primary custody every weekend from Friday at 5:30 P.M. until Sunday at 8:30 P.M., except for the second weekend of each month at which time father shall have custody of the children: Every Monday and Tuesday mother shall have custody of the children from 5:30 P.M. until 8:30 P.M. Mother shall pick up and drop off the children at father'm-residen~ for the Monday and Tuesday visitations and on the -~na'eke~s ~.'ck up and delivery shall be at the Duncannon Ass~mbl~'~f Father shall have custody.'~f t~e c~ildren at all other times not mentioned above; -'~- Heather Lynn Kulp shall continue ~-~ -day care and the parties shall share equally the costs of all day care expenses; As far as a holiday schedule is concerned, the parties shall, by agreement, work out a holiday schedule and if an agreement cannot be reached, each party shall submit to the Court a proposed holiday schedule and this Court shall adopt one or the ot~er schedule~ '. During the week, if mother has a holiday, she shall have the children until 5:30 P.M.; During the summer months, each party shall have one (1) week continuous temporary custody cf the children per calendar year. The parties may, by mutual agreement, alter or change any of the periods of temporary custody or custody outlined in this agreement. cc: Michael Hanft, Esq. R. Scott Cramer, Esq. File BY TEE COURT: ~. J~)SJ~ JUDGE MICHAEL T. KULP, DOREEN C. KULP, Plaintiff : ; : ; ; Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2153 CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, this ~ ~ day of ~7~ ,2002, Preliminary Objections raised to the Complaint for Custody raised by Doreen C. Kulp shall be scheduled for a hearing before the Court for the ~4~ day of~, 2002, in Courtroom No. ~ at//:~9 o,.m. BYTHECOURT: MICHAEL T. KULP, Plaintiff/Respondent VS. DOREEN C. KULP, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-2153 CIVIL CIVIL ACTION - LAW IN RE: PRELIMINARY OBJECTIONS TO COMPLAINT FOR CUSTODY ORDER AND NOW, this ~ ~3 day of June, 2002, the preliminary objections of the defendant are SUSTAINED and the within custody complaint is DISMISSED. BY THE COURT, ~Jeane C. Adams, Esquire For the Plaintiff/Respondent ~Joanne Clough, Esquire For the Defendant/Petitioner Kev'lng. Hess, J. :rim