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Home My WebLink About06-5288 . " II LISA J. SHAULIS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO. O(...5.:L~~ ~ lL<-- Plaintiff vs. GERALD R. SHAULIS, Defendant CIVIL ACTION - LAW IN DIVORCE AND CUSTODY NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within tweJ).ty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BEWW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO IllRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 .. II LISA J. SHAULIS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO. Plaintiff vs. GERALD R. SHAULIS, Defendant CIVIL ACTION - LAW IN DIVORCE AND CUSTODY A VISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion con prontitud. Se Ie avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio 0 anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja 0 compensacion reclamados por el demandant. Usted puede perder dinero, 0 propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, 17013. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL HONORARIOS DE ABOGADO U OTROS GASTOS ANfES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA MEITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVARESTE PAREL A UN ABOGADO DE INMEDIATO. SI NO TIENE 0 NO PUEDE PAGAR UN ABOGADO, VA Y A 0 LLAME A LA OFICINA INDICADA ABAJO PARA A VERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 II " 'I , LISA J. SHAULIS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO. Ot... 5' ~gr; ~ T......... Plaintiff V5. GERALD R. SHAULIS, Defendant CIVIL ACTION - LAW IN DIVORCE AND CUSTODY COMPLAINT UNDER SECTION 3301(c)OF THE DIVORCE CODE COUNT I AND NOW, this B~ day of 6 -,~b<<- , 2006, comes the Plaintiff, Lisa 1. Shaulis, by her attorney, Jane M. Alexander, Esquire, and files this Complaint upon a cause of action of which the following is a statement. I. Plaintiff is Lisa 1. Shaulis, 36 years of age, who currently resides at 4208 Carlisle Road, Gardners, Dickinson Township. Cumberland County, Pennsylvania 17324. 2. Defendant is Gerald R Shaulis, 35 years of age who currently resides at 4208 Carlisle Road, Gardners, Dickinson Township, Cumberland County, Pennsylvania 17324. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 22, 1992 in York Springs, Adams County, Pennsylvania by a Minister. 5. There were four (4) children born between the parties during the marriage: Jessica Shaulis, age 13, born April 5, 1993, Casie Shaulis, age 10, born August 16, 1996, Summer Shaulis, age 5, born June 14,2001 and Ntki Shaulis, age 3, born March 31,2003. 6. There have been no prior actions of divorce or for annulment between the parties. .. II 7. The parties have not entered into a written agreement as to alimony, counsel fees, costs and property division. S. 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. 9. While the parties were domiciled within the Commonwealth of Pennsylvania, and through no fault of Plaintiff, the innocent and injured spouse, the Defendant, in violation of the marriage vows and the laws of the Commonwealth, has offered such indignities to the person of the Plaintiff as to render her condition intolerable and life burdensome. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNT n 10. The allegations of Paragraph one (1) through nine (9) are incorporated herein by reference and made a part hereof. 11. The marriage is irretrievably broken. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNT m 12. The allegations of Paragraph one (1) through eleven (11) are incorporated herein by reference and made a part hereof. 13. During the marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under Chapter 35 of the Divorce Code. .. II r- 'I I 14. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property of whatsoever kind and whosesoever situate and for such further relief as the Court may deem equitable and just. COUNT IV COMPLAINT FOR CUSTODY 15. The Plaintiff seeks primary physical custody and joint legal custody of the following children, Jessica Shaulis, age 13, born AprilS, 1993, Casie Shaulis, age 10, born August 16, 1996, Summer Shaulis, age 5, born June 14, 2001 and Niki Shaulis, age 3, born March 31, 2003. 16. The children were born during this marriage. 17. The children are presently in the custody of Plaintiff and Defendant. 18. The children have resided with the Plaintiff and Defendant since December 31, 1993 at 4208 Carlisle Road, Gardners, Dickinson Township, Cumberland County, Pennsylvania 17324. 19. The relationship of the Plaintiff to the children is that of natural mother. 20. The relationship of the Defendant to the children is that of natural father. 21. The Plaintiff is seeking joint legal custody of the children and primary physical custody for purpose of visitation schedule. 22. The Plaintiff has not participated as a party or witness, or in any other capacity, in other lixiviation concerning the custody of these children in this or any other Court. . . II 23. The Plaintiff has no information of a custody proceeding concerning the children pending in any other court within this Commonwealth. 24. The Plaintiff knows of no other persons, not a party to these proceedings, who has visitation or custody rights with respect to the children. 25. The best interest and permanent welfare of the children will be best served by granting the Plaintiff primary physical custody and joint legal custody of all of the children because Defendant claims to be too disabled to work but takes excessive medication which affects his temper and his medical condition. WHEREFORE, the Plaintiff requests your Honorable Court to grant her primary physical custody and joint legal custody of the subject children and that Defendant have scheduled periods of visitation when he establishes a permanent residence. Respectfully submitted, .. II Verification I verify that the statements made in this Complaint in Divorce and Petition for custody are true and correct. 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. DATE: 9/9/0((J &!~ .~~vt~) Lisa 1. Shaulis . COMMONWEALTH OF PENNSYLVANIA S.S. COUNTY OF YORK Before me, the undersigned officer, a Notary Public, in and for the said Commonwealth and County, Personally appeared Lisa 1. Shaulis who, being affirmed according to law, deposes and says that the facts and matters set forth in the foregoing Complaint are true and correct to the best of her knowledge, information and belief. ~,~ Lisa 1. Shaulis 9 ' Sworn to and subscribed before me this % ~ day of <:'(~M....b<<. 2006. ~. _P^~A~ Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal NarumoI Alexander. Notary Public DilIsburg Boro. York County MyConvnission expiresApi'. 7, 2010 Member, Pennsylvania Association of Notaries ~ (") ......, = C) C. C:':::J ;;P" W'''' " '-':-'; (/) :;:!" j r1"1 f f -".J rtlp 8 -n(n .. ~-~j6, }> -0 ()~:-; '- -.. ,,.- "" 0- to<) ..:l. ~ ...0 r;-? :,,:cn .J ..., l"" l-> - 0 "':;';:\ :::-1 \J,I <.';') .... ~ .-<: {'.) :< ~ 0;:, - 8 ~ ~ ~t 'l }~ , LISA J. SHAULIS PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-5288 CIVIL ACTION LAW GERALD R. SHAULIS DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, September 14,2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, P A 17055 on Thursday, October 19, 2006 at 10:30 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 hearine;. FOR THE COURT. By: /s/ Dawn S. Sunday, Esq. Custody Conciliator fJD- 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 VE 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 ~ ~?_ ~V1/ ~ tff.")/- (; _~ ~ ~ ~ tj/A,>l-f ~yz~4W.P; ~:5I6 ..1 !~ 'J :) "~l (~j'" ,..1 .' ) :' In the Court of Common Pleas or Cumberland County, Pennsylvania No. cJ ,~- 5,;1 ~) y Civil. ~c, , ). _ t-;;'.? ~.-\..-07 o. '" .d 7J: ~ -4,"~4- _/'1 y-.:::'~~~ "~f_~r To (f/~~A~ 9 ( Prothonotary iR eo C ~11<<:~ (/ Au mey fo< Plai 'iff '-I: ~l No. Tenn, 19 _ 2UD6 C.~T - 9 h, 3: LIB C L: II C vs. PRAECIPE Filed 19 , Atty. 6 LISA J. SHAULIS Plaintiff OCT 2 ,~ 7nn~c/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. 06-5288 CIVIL ACTION LAW GERALD R. SHAULIS Defendant IN CUSTODY ORDER OF COURT AND NOW, this 11" ~ day of 0 c..\<:>\oc..f" , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Lisa J. Shaulis, and the Father, Gerald R. Shaulis, shall have shared legal custody of Jessica Shaulis, born AprilS, 1993, Casie Shaulis, born August 16, 1996, Summer Shaulis, born June 14, 2001, and Niki Shaulis, born March 31, 2003. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education, and religion. Pursuant to the terms ofthis paragraph, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 2. Pending the follow-up conciliation conference and further Order of Court or agreement of the parties, the Mother shall have primary physical custody of Jessica, subject to the Father's periods of partial custody with Jessica as arranged by agreement between the parties and the parties shall share having physical custody of Casie, Summer and Niki on an alternating weekly basis, with the exchange to take place every week on Sunday at 6:00 p.m. The alternating weekly schedule shall begin with the Father having custody on Sunday, October 22, 2006. 3. The Father shall ensure that all of his medications are locked up and inaccessible to the Children during his periods of custody. 4. The Father shall ensure that all firearms are unloaded and stored in a locked cabinet to ensure that the Children do not have access during his periods of custody. 5. The Father shall ensure that the Children wear helmets at all times when riding the 4 wheeler during his periods of custody. 6. Both parties shall ensure that the Children complete all homework and assigned schoolwork during his or her periods of custody. 7. Each parent shall be responsible for transportation of the Children to and from school during his or her periods of custody. 8. In the event the Father requires medical care, including hospitalization, or is incapacitated by his medical condition or treatment during his periods of custody, the Father shall contact the Mother to offer her the opportunity to provide care for the Children during the period of incapacity or unavailability. t. 9. Each party shall ensure that each Child has her own separate bed when sleeping at that parent's residence. 10. The parties and counsel shall attend an additional Custody Conciliation Conference in the office of the Conciliator, Dawn S. Sunday, on December 19,2006, for the purpose of reviewing the custodial arrangements. 11. The Mother shall have custody of the Children on Thanksgiving in 2006. BY THE COURT, \"l~ cc: ;<1:arcus A. McKnight, Esquire - Counsel for Father ,/1ane M. Alexander, Esquire, Counsel for Mother \;fiN,; /\F.S.\\J .\=.\d I \ t 11'"\ r ," -, C"C,\/,lllf'\ I \J,.I"I I'..', . ." ,'j t'~\ t.J L 0 :t: \.,!d L Z 1:)0 qUOl "tj' >t ("_ '.' " , .' , 1 -\ li. jr ^ Y; I ,','t :.., '. \ 't" .-' - \ y_'.)I'\...,.1'\t~,~"j'_I..,). \00#' 'j"\ . ,,.. ;'j~':l , . ,1,--\1 \..... i - ,\.. \..It,..-.. .~# "IJ_. t LISA J. SHAULIS Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 06-5288 CIVIL ACTION LAW GERALD R. SHAULIS Defendant IN CUSTODY Prior Judge: None 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 Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jessica Shaulis Casie Shaulis Summer Shaulis Niki Shaulis April 5, 1993 August 16, 1996 June 14,2001 March 31, 2003 MotherlFather MotherlFather MotherlFather MotherlFather 2. A Custody Conciliation Conference was held on October 19, 2006, with the following individuals in attendance: The Mother, Lisa J. Shaulis, with her counsel, Jane M. Alexander, Esquire, and the Father, Gerald R. Shaulis, with his counsel, Marcus A. McKnight, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Ockbe4 ~J ~ooV . Date tf2A---~ Dawn S. Sunday, Esquire Custody Conciliator LISA J. SHAULIS, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PA vs. : NO. 06-5288 GERALD R. SHAULIS, Defendant : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY ACCEPTANCE OF SERVICE I, Marcus A. McKnight, III, attorney for the Defendant, Gerald R. Shaulis, in the above- captioned matter, do hereby accept service of the complaint on behalf of Gerald R. Shaulis, on rJ,. /'I1_l_ this /9 day of~, 2006. Date: Oc....f.d.w It:; ~, . Esquire ~.=::." . ~.'-d~'~;l) ;;; . N N - c::) c;;: N " LISA J. SHAULIS, VS. GERALD R. SHAULIS, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PA : No. 06-5288 Civil Term : CIVIL ACTION - LAW : IN CUSTODY PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Please kindly withdraw the appearance of Jane M. Alexander, Esquire as counsel for Plaintiff, Lisa 1. Shaulis, in the above-captioned matter. Respectfully submitted, Date:! 0~/.I, ~/ ~ / Ja e M. Alexande , Esquire S preme Court ID # 07355 48 South Baltimore Street P.O. Box 421 Dillsburg, PA 17019-0421 (717) 432-4514 , g. c:.:> cr o \" ('"'J - cP ~ ~, --:..,. "";").;f' ~-f1 In f:. _r1,-r1 -.:;9 i::i~ ~\\ f--~" -~_. "'-;.(~ :""1'\\ '::::--\ ~~ {~,? c.f\ o .. .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA J. SHAULIS, Plaintiff 2006 - 5288 CML TERM v. GERALD R. SHAULIS, CIVIL ACTION - LAW IN DIVORCE & CUSTODY Defendant PRAECIPE for ENTRY of APPEARANCE To the Prothonotary: Kindly enter my appearance on behalf of Lisa J. Shaulis, Plaintiff. Papers may be served at the address set forth below: Spencer Abel Law Office Suzanne Spencer Abel, Esq. Attorney ID # 202443 22 East Street, #6 Mt. Holly Springs, P A 17065 (717) 323-0046 Date: Ia-flu/ov o c <:: -r:) i': :~: "', <=:> <:.:::> a-.. o rq C".l o 1I ~::D r- -rfT1 ~~ ,-) ---1 '> :JJ -< co w U1 C) DEe 26 2006t1~ !J LISA J. SHAULIS Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 06-5288 CNIL ACTION LAW GERALD R. SHAULIS Defendant IN CUSTODY ORDER OF COURT AND NOW, this 11 '\'1\ day of Oe..c,e...'M ~l{ , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated October 2006, shall continue in effect as modified by this Order. 2. The Mother shall have primary physical custody of Jessica, subject to the Father's periods of partial custody with Jessica as arranged by agreement between the parties and the parties shall share having physical custody of Casie, Summer, and Niki in accordance with the following alternating biweekly schedule: A. WEEK I: During Week I, the Mother shall have custody of the Children from Friday at 5:00 p.m. through Sunday at 5:00 p.m., the Father shall have custody from Sunday at 5:00 p.m. through Tuesday at 5:00 p.m. and the Mother shall have custody from Tuesday at 5:00 p.m. through Friday at 5 :00 p.m. B. WEEK II: During Week II, the Father shall have custody of the Children from Friday at 5:00 p.m. through Sunday at 5:00 p.m., the Mother shall have custody from Sunday at 5:00 p.m. through Tuesday at 5:00 p.m. and the Father shall have custody from Tuesday at 5:00 p.m. through Friday at 5 :00 p.m. C. The alternating biweekly schedule shall begin on Friday, December 29,2006 at 5:00 p.m. with the Mother having the weekend period of custody. 3. In 2006, the Father shall have custody of the Children over the Christmas weekend until December 26 at 9:00 a.m., the Mother shall have custody from December 26 at 9:00 a.m. through December 27 at 5:00 p.m., the Father shall have custody from December 27 at 5:00 p.m. through December 29 at 5:00 p.m., after which the custody schedule set forth in the preceding paragraph shall begin. The parties shall share having custody of the Children over the Christmas holiday in future years as arranged by agreement. 4. The parties shall cooperate with each other and the school officials to ensure that the Children can get off the school bus at each of the parents' bus stops on the appropriate days, while riding the same bus each day. A1Nf\"i'-',' 00 ,t, !,',d . l 1I_ f 7 'I1P Qfluf1"l .... \.J v,..jjJ ..J ut:" A'tJ"rJJ{),\ 5. The parties shall cooperate in selecting a pediatrician for the Children. 6. Within 90 days of the date of this Order, counsel for either party may contact the conciliator to schedule a follow-up custody conciliation conference if necessary to review the custodial arrangements. 7. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, ,~~ J. 00:11 Hd LZ 'J3QQnG! l'>--~\q f",\..... . (.,;.'\ :11 11' .lOr I\D ~",,,,''''<'''l '1\...:. ,_~:""'V\......an :J ::.\,:)+\0 <Bl\:\ LISAJ. SHAULIS Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 06-5288 CIVIL ACTION LAW GERALD R. SHAULIS Defendant IN 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 Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jessica Shaulis Casie Shaulis Summer Shaulis Niki Shaulis April 5, 1993 August 16, 1996 June 14, 2001 March 31, 2003 MotherlFather MotherlF ather MotherlFather MotherlFather 2. A custody conciliation conference was held on December 19, 2006, with the following individuals in attendance: the Mother, Lisa J. Shaulis, with her counsel, Suzanne Spencer Abel, Esquire, and the Father, Gerald R. Shaulis, with his counsel, Marcus A. McKnight, Esquire. 3. The parties agreed to entry of an Order in the form as attached. .OR-~ ~Ol J-oo~ Date Da~cd~ Custody Conciliator