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Home My WebLink About94-01452 / I / ,I " , , ", , ' / " ., I, 1 ;, ',; " 'I , " 1,'/ , " , , , , 'I , , "/.' , , " 'I , ' " " 'I 'I , / ~ J ' I, I , , , ,I" , , 'I, " " " " , , " I' I' 'I' I" , I ;, / ,( . r fl, ,I " , , " , , , ii Iii 'I '/ ii " , ,I " " , II' " " ,1/ " II, 'I " ':,1,; , ,)/; ,It, ,tl' ",I , " v, IN THE COlJRT OF COMMON PLEAS CUMDF.RLAND COUNTY, PENNSYLVANIA CIVIL. ACTION - CUSTODY 9'1- /'1 ?~;) t!u4/' .,::J-,1'I NO, CIVIL 1994 CATHERINE A. KlILP, PllIintlff CHRISTOPIIER J, KlJL.P, Defendant ORDER Or: COlJRT AND NOW, M<\/ (~, u fs I 1994, upon consideration of the attllched complaint, It is directed that the parties and their respective counsel appear before .) ""~( I L. (l"c!..... ,Esquire, the conciliator, at 5 A c,' A(. I -a\ h, ">{ Co, IIW,It,. ,Pennsylvania, on the & )t..b- day of ftp-,' ( , 1994 at II o'clock f ,m" for a Pre-Hearinl! Custody Conference, At such conference, an effort will be made to rcsolve the Issues In dlsputei or If this cannot be accomplished. to define and narrow the Issues to be heard by the Court, and to entcr Into a temporary order. Either party may bring the child who Is the subject of this custody action to the conference, but the children's attendance Is not mandatory. Failure to appear at the conference may provide grounds for entry ()f a temporary or permanent order. FOR TI~l~OlJR(T J. . . By: '~~'Httl-< 4~/-1.~, Custody Conciliator ~ I( YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF yod 1>0 NOT HAVE A LAWYER OR CANNUI' AFFORD ONE, (jO TO OR TEI.EPIJONE TIlE OFFICE SET FORTIJ BEl.OW TO FIND OUT WIIERE YOU CAN (jET LEGAL. HEL.P, OFFICE OF TIlE COIJRT AI>MINISTRATOR COURTHOUSE, 4TIJ FL.OOR, CARLISLE, PENNSYLVANIA 170L' (717) 240-6200 .' HAR 28 ~ lS PH 19~ ,"hI (/' iUf If.;~ QI It!, II' JIII'JW,lM,y OlltllJf[l1 .1//1) GI)IJ/,ry P~HII'\fl YMilA " ~ ,,) , , , , '" ;j,L " " , I I " \. , , II '" " I, " I , ' ," ,I " , , , " " " '1'1 " " , , ,\ ,I , , I, " , , with Marcia Whitlow, Plaintiff's mother, ~, The relationship of Defendantlt) the child is natural father. Defendant currently resides with Martin and Gall Kulp, Defendant's parents, 6, Plaintiff has not participated as a party or witness or In another capacity in other litillatlon concerning the custody of this child In this or another court, There have been no other custody proceedings Involving this child. Plaintiff has no knowledge of any custody proceedings concerning this child pending in any other 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 cUMody or visitation rights with respectlO the child, 7, The best Interests and permanent welfare of this child would be served by the granting of the relief requested. Plaintiff requests the court to award custody of this child to plaintiff, After the child's birth, Plaintiff and Defendant decided that Plaintiff would stay home with the child and Defendant would work full-time to t1nancially support Plaintiff and their child, consequently, Plaintiff has been the primary caregiver of this child since birth and It would be In this child's best Interests to remain in the care and custody of his mother since the child is only fourteen months old. Plaintiff contends that It would be dctrlmenll\lto this child, at thh time, for Defendant to have physical cusll>dy 1)1' thiS child because Defendant has a problem with alcl)holand drugs and only very recently, In February, 1994, started to become involved with Narcotics Anonymous. Defendant Is In recowry and Plalllllff submits that 3 ~ '1'1 'f ~ tt~ " ;f. '...:J " , ':\ 'C , M " .,\.. Ii' L;1 r; " r" " " o"j '-'" " - \~~ '~ ~-~ ' ; :~ " ~ ~ t>. ~ \~ ~ Ii, ;~ ~ ,I' , , I, 'I I, " " I '1; 'i t"l , , ' " \' ,iI. , , 1l1.t\('I<I\lII1N & :-\1'1"111'/1, , \ I/,I!rlol ~ _\ I I . ,l. "I' ,,1\1 :'<I\llh \\ 1 ~I ,I L .II \. I ',11" I ,I, l,llllo'llllll'll 1\\ I" "'1'1 ,f ,II' '1'111111'1"1 'I" , , ,l)tl!IIIHl I .' , , Sunday afternoon, On the weekends not failing on the fourth weekend of tile month, Christopher J. Kulp shall have partial physical cusllldy of Derek from 6:00 p.lO, Friday night until 6:00 p.lO, Saturday night. On the weekellds that Christopher J, Kulp has partial physical custody of Derek from 6:00 p,m, Friday until 6:00 p,lO, Saturday, In the event that Christopher J, Kulp Is requested to work by his employer on Saturday, Christopher J. Kulp IlIrees to notify Catherine A, Kulp prior to 6:00 p. m. on Friday that he has to work on that Saturday and Catherine A, Kulp has the option of cancelling that weekend. On the fourth weekend of the month when Christopher J. Kulp is scheduled to have partial physical custody of Derek from 6:00 p.m, Friday until 2:00 p.lII. Sunday, in the event that Christopher J, Kulp is requested to work by his employer on Saturday, Christopher J, Kulp agrees to notify Catherine A. Kulp prior to 6:00 p, 1tI. Friday that he has to work on that Saturday and Christopher J. Kulp, In that situation, shall have partial physical custody of Derek from 6:00 p.rn, Saturday until 2:00 p,m, Sunday, Christopher J, Kulp Is responsible for picking up and dropping off Derek at Catherine A. Kulp's house, ChrlMopher J. Kulp will not be permitted to transport Derek from Catherine A, Kulp's home unless he has a suitable car seat for Derek. ChristopheI' J. Kulp must obtain proper bedding for Derek before overnight stays are commenced, Proper bedding for Derek would be a child sized daybed with safety ralls, Christopher J, Kulp must be punctulll In the picking up and dropping off of Derek. Catherine A, Kulp must be punctual In having Derek ready at the appointed time for the visits with his 2 " father. 4, ChrblOpher J, Kulp shall have partial physical custody of Derek from 1:00 p,m, until 7:00 p.m, on Father's Day and Christopher J. Kulp's birthday, If Christopher J, Kulp'. birthday falls on a weekday, Christopher J, Kulp and Catherine A, Kulp lIjJree that Christopher J. Kulp will have the opportunity to celebrate his birthday with his son on the next available day as can be lIjJrecd upon by Christopher J. Kulp and Catherine A. Kulp and with 48 hours notic.: given to Catherine A. Kulp that Christopher J, Kulp wishes to celebrate his birthday with his son on a day other than his birthday. ,5, Christopher J. Kulp and Catherine A. KuJp agree to alternate time with Derek on the following holidays: New Years Day; Easter; Memorial Day: Independence Day; Labor Day; Thanksgiving Day; Christmas Eve; and Christmas Day. Therefore, during the remainder of 1994, Christopher J. Kulp shall have pal11nl physical custody of Derek from noon until 6:00 p.m. on Memorial Day, Labor Day and Christmas Eve. In accordance with this schedule, during 199.5, Christopher J. Kulp shall have partial physical custody of Derek from noon until 6:00 p,m. on New Years Day, Memorial Day, Labor Day alld Christmas , .' Eve, ,( 6. Christopher J. Kulp and Catherine A. Kulp agree that Christopher J. Kulp shall have partial custody or visitation with Derek at other times not specified above as can be mutually lIjJreed upon by the parties provided that the parties give each other at least 48 hours notice 3 1 ' ," " , , " " , , " , " 'I ,I " ' " , " ,I, " I' I, " , , , " 'Ii " . . . , , . " . 111,11 '1\111 '1lN ,~ SPFH'I'ZFI . \/1111 ,,' ,.. \1 I dH ,~n ,'" 1\\\11 ,\1.1111. I ',I I. , I 1\1. t 11.1111" .,1 Hlr'l 1.,\ I ',-q \ 'It'kphlll;" 1;"1'....) ;-'111 IlItfO